IR 05000250/1981031

Ack Receipt of IE Insp Repts 50-250/81-31 & 50-251/81-31.No Proprietary Info.Corrective Actions:Overpressure Mitigating Sys Test Revised & Procedure for Alignment of Root Valves Changed

ML17341A978
Person / Time
Site:	Turkey Point
Issue date:	03/04/1982
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML17341A977	List: IR 05000250/1981031 ML17341A978
References
L-82-80, NUDOCS 8203250307
Download: ML17341A978 (8)

Text

82 fvMR 9 AB.fD FLORIDA POWER 8(LIGHT COMPANY March 4, 1982 L-82-80 Mr.James P.O'Reilly Regional Administrator, Region II U.S.Nuclear Regulatory Commission 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303

Dear Mr.O'Reilly:

Re: Turkey Point Units 3 and 4 Docket Nos.50-250 and 50-251 IE Ins ection Re or t 81-31 Florida Power and Light Company has reviewed the subject inspection report and a response is attached.There is no proprietary information in the report.We have reviewed the performance of the overpressure mitigating system during the over pressure transient.

We feel that the corrective actions taken provide a high degree of assurance that the overpressure mitigating system will in the future properly perform its safety function.Robert E.Uhrig Vice President Advanced Systems and Technology REU/DWJ/mbd cc: Harold F.Reis, Esquire 8203250307 8203l6~G..PDR ADOCK 05000250 PDR PEOPLE...SERVING PEOPLE II II il H IH=II'f I U ATTACHMENT RE: TURKEY POIHT UNITS 3 AND 4~~DOCKET NOS.50-250, 50-251 IE INSPECTION REPORT 81-31 FINDING A: Technical Specification 6.8.1 requires that written procedures be established and implemented that meet or exceed the requirements and recommendations of Section 5.1 and 5.3 of ANSI N18.7-1972.

Section 5.3.6 of ANSI N18.7 requires measurements to keep safety parameters within operational and safety limits.Contrary to the above, the Overpr essure Mitigating System (OMS)functional test was inadequate in that the summator circuitry was not tested.This resulted in failure to discover the OMS was inoperable and contributed to the reactor cool,ant system overpressure events of November 28 and 29, 1981.RESPONSE: (A-1)FPL concurs with the finding.(A-2)The Overpresure Mitigating System (OMS)functional test requires the introduction of a simulated overpressure signal.During the test, the summator was bypassed because the summator is used to provide a constant D.C.signal as a reference or setpoint for the OMS circuitry.

In this operating region the summator output does not change with the input Reactor Coolant system temperature change.Because of this it was determined that the best testing method would be to introduce the test signal at the summator output.A-3)As corrective action and in order to prevent recurrence, we have A-4)evaluated the OMS performance during the over pressure incident and made the following revisions:

a)Operating Procedure 1001.1, Filling and Venting the Reactor Coolant System, has been changed to include verification that instrument block valves a'e correctly aligned.The procedure has been updated to include testing of OMS at two differ ent steps in the procedure, and addition of transmi tter and summator checks to the tests.b)Operating Procedure 1004.4, Over pressure Mitigating System Functional Test of Nitrogen Back-up System has been changed to include checks on applicable pressure transmitters, summator output, and recording of actual test data.c)Operating Procedure 0205.2, Reactor Shutdown, Hot Shutdown to Cold Shutdown Conditions, has also been revised to include additional checks on OMS summator s.(A-5)Full compliance was achieved on March l, 1982.

A FINOING 8 Technical Specification 6.8.1 requires that written procedures be established that meet or exceed the requirements and recommendations of Section 5.1 and 5.3 of ANSI N18.7-1972.

ANSI N18.7-1972 Section 5.3.4.1 requires instructions for starti ng up including the requi rement that valves be properly aligned.Contrary to the above, alignment of instrumentation root valves were not included in station procedures prior to reactor coolant system fill after refueling or plant startup.RESPONSE: (B-l)FPL concurs with the finding.(8-2)These valves were inadvertently omitted from the plant startup procedures.

(8-3)As corrective action and in order to prevent recurrence, Operating and Procedure 0202.1, Reactor Startup, Cold Conditions to Hot Shutdown (8-4)Conditions, will be changed to include root valve alignment checks on instruments affecting alarm functions, automatic action, and transient control.(8-5)Full compliance will be by April 15,.1982.

~~'f STATE OF FLORIDA))COUNTY OF DADE)J.W.Williams, Jr., being first duly sworn, deposes and says: That he is Vice President Light Company, the herein;of Florida Power That he has executed the foregoing document;that the state-ments made in this said document are true and correct to the best of his knowledge, information, and belief, and that he is authorized to execute the document on behalf of said J.W.Williams, Jr.Subscribed and sworn to before me this day of l9 g&XOTZ.-RY,.PUBLI in and for the County of Dade,-State of Florida Votary Fu~i;c, S.te of Florida at Largo Ny COmmiSSiOn eXpireS~My Comm~on spirea October 30, 1983 J~V)*C-I)e I