IR 05000250/1986026
| ML20214J914 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 08/12/1986 |
| From: | Brewer D, Elrod S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20214J871 | List: |
| References | |
| 50-250-86-26-EC, 50-251-86-26, EA-86-020, EA-86-20, NUDOCS 8608150221 | |
| Download: ML20214J914 (66) | |
Text
{{#Wiki_filter:I n o UNITED STATES [pm Afog%,' NUCLEAR REGULATORY COMMISSION REGION 18
3* I I*I S 101 MARIE TTA STREET.N.W.
E f ATLANTA. GEORGI A 30323 \\...../ Report Nos.: 50-250/86-26 and 50-251/86-26 . Licensee: Florida Power and Light Company 9250 West Flagler Street hiiami, FL 33102 Docket Nos.: 50-250 and 50-251 License Nos.: DPR-31 and OPR-41 Facility Name: Turkey Point 3 and 4 Inspection Conducted: January 8, 1986 and February 17 - May 15, 1986 Inspector: a,,I [[ M% j'd ' D. R. Brewer, Senior,Resi ent Inspector Date' Signed Approved by: d M [?Vlh Stephed A. Elrod, Sect' ion Chief Date ' Signed Division of Reactor Projects SUMMARY Scope: This special report concerns the Enforcement Conferences held with licensee representatives at the NRC Region II office on January 8,1986 and at FPL's Juno Beach Office on May 9, 1986. The January 8, 1986 conference addressed issues from NRC Inspection Report 250, 251/85-40.
The May 9, 1986 conference addressed a number of other unresolved issues and potential violations including (1) component cooling water (CCW) system flow imbalances, (2) intake cooling water (ICW) system failure modes and testing, (3) Unit 4 CCW piping errors, (4) unanalyzed emergency diesel generator (EDG) load changes, (5) residual heat removal (RHR) syst o stop valve throttling and (6) a Unit 3 reactor startup with only three operable safety injection (SI) pumps. This report alsc provides the genesis of the violations included in Enforcement Action EA 86-20.
Results: Items 1-4 and item 6 were determined to be violations and were included in Enforcement Action EA 86-20. Item 5 will undergo further review and will be addressed separately.
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.. REPORT DETAILS 1.
Personnel Attending the May 9, 1986 Enforcement Conference a.
Licensee Personnel Attenc.ng E. A. Adomat, Executive Vice President J. W. Dickey, Vice President Nuclear Operations H. J. Dager, Vice President, Engineering Project
Management and Construction C. M. Wethy, Site Vice President, Turkey Point C. J. Baker, Plant Manager, Turkey Point J. K. Hays, Director of Licensing G. J. Boissy, Director of Quality Assurance L. D. Slepow, Director of Projects H. D. Mantz, Project General Manager, Nuclear T. C. Grozan, Nuclear Licensing V. A. Kaminskas, Acting Operations Supervisor D. D. Grandage, Operations Superintendent J. M. Donis, Site Engineering Supervisor J. Arias, Jr., Compliance Supervisor E. Preast, Site Engineering Manager R. D. Phillips, Project Management b.
NRC Personnel Attending J. N. Grace, Regional Administrator, NRC, Region II' J. M. Taylor, Director, Office of Inspection and Enforcement (IE) L. A. Reyes, Acting Director, Division of Reactor Projects (DRP) A. F. Gibson, Director, Division of Reactor Safety (DRS) G. R. Jenkins, Director, Enforcement and Investigation Coordination Staff D. M. Verrelli, Chief, Reactor Projects Branch 2, DRP S. A. Elrod, Chief, Reactor Projects Section 2C, DRP D. R. McGuire, Chief, Physical Security Section E. Holler, Enforcement Specialist, IE D. R. Brewer, Resident Inspector Turkey Point J. D. Ennis, Physical Security Inspector 2.
Enforcement Conference - May 9, 1986 An Enforcement Conference was held on May 9,1986, in FPL's Juno Beach Office with the attendees ~ identified in paragraph 1.
The topics of discussion concerned a number of unresolved issues and potential violations.
These issues are addressed individually in paragraph 3 of this repor IT } . .
During the discussion, FPL addressed the management to resolve the issues and prevent their recurrence.
3.
Resolution of Unresolved Issues Five of the six issues discussed during the Enforcement Conference were addressed in _ previous NRC inspection reports and were a.
Unresolved information was required to determine whether they were acceptable or These items are resolved as involve violations or deviations.
may follows: (Closed) UNR _250, 251/86-10-04 - Resolve NRC concerns that improper throttling setpoints for CCW valves 748A and 748B might (1) have, under certain accident colditions, rendered the CCW system unable to supply adequate cooling water to safety-related This report updates previous report 250, 251/86-10 in this area.
The outline used by FPL to discuss this UNR is components.
provided as Attachment 1 to this report.
FPL did not show that the course of corrective action taken by FPL after discovering that the CCW flow to the RHR heat exchangers may not have satisfied post-accident design requirements was adequate In mid-January 1986, it was determined that the RHR and timely.
heat exchangers may not be guaranteed sufficient cooling flow unoer all accident scenarios with the CCW throttle valves at th The engineering evaluation which followed 30 percent position.
attempted to determine why the CCW valves were throttled and whether the minimum CCW flowrate recommended by the vendor could It was not until February 24, when FPL realized that be reduced.
any reanalysis of the minimum acceptable flowrate would take time, that action was taken to increase the CCW flowrate to the RHR No analysis was exchangers by fully opening the throttle valves. impact this action wo performed to determine whatflowrates to other safety-related compo It was not until March 4, when flow test results on the shutdown unit revealed that CCW flow to the emergency containment coolers had been reduced below the design values, that the conservative course of action was taken to shut down Unit 3.
This failure to take prompt and prudent action to evaluate and correct a condition adverse to quality is Violation 250, 251/86-26-01.
(2) (Closed) UNR 250, 251/86-10-03 - Resolve NRC concerns over the adequacy of the Turkey Point ICW system design.
This report 250, 251/86-10 in this area.
ICW system updates previous Reportcontrol valves (CV) 2202 and 2201 were det . - - - -- ., .- ._ _
. .
"as is" position upon loss of instrumer.t air. During an accident response, the ICW system could be configured in a lineup different from any analyzed in the Final Safety Analysis Report (FSAR). The outline used by FPL during the discussion of this UNR is provided as Attachment 2 to this report.
Concerns regarding the single failure properties of ICW CV-2201 were initially raised during the latter half of 1984, however, it was not until February 13, 1986, that the engineering evaluation concluded that a single failure could cause CV-2201 to fail as-is, i.e., full or partially open, thereby providing less than the design ICW flow requirements to the CCW heat exchangers following an accident. A Justification for Continued Operation requiring _ compensatory operator action to ensure that CV-2201 was closed within five minutes following receipt of a safety injection signal was finally issued on February 14, 1986.
This failure to promptly evaluate and correct a condition adverse to quality is Violation 250, 251/86-26-02.
Resolve NRC concerns (3) (Closed) Violation 250, 251/86-18-03 - regarding the design deviation of the as-built Unit 4 CCW system piping to the safety injection pump coolers. This report updates report 250, 251/86-18 in this area.
The outline used by FPL during the discussion of this UNR,is provided as Attachment 3 to this report.
The ariginal Unit 4 CCW piping installation.to the high head safety injection (SI) pumps failed to conform to the system design requirements.
This adverse condition was known to exist since prior to 1980 yet no comprehensive safety hazard evaluation was performed until after tne discrepancy was identified during an NRC inspection.
The licensee had, on at least four occasions since 1980, attempted to resolve the issue but had failed to adequately address the safety and operability concerns.
Two CCW operating procedure revisions in June 1982 and October 1984 failed to establish adequate administrative cor. trol s to ensure that sufficient Unit 3 CCW redundancy was maintained per the Technical Specifications when only Unit 4 was operating.
Osring at least two periods of time (August 3 - September 17, 1981 and September 21 - October 22, 1981) Unit 4 was operated while all four SI pumps were technically inoperable because only one train of Unit 3 CCW was available for SI pump cooling.
The third opportunity to evaluate and correct the problem came in January 1983 when Plant Change / Modification 83-08 was initiated tu restore the CCW piping to its design configuration; however, three years later tne problem remained uncorrected. The existence of the erroneous CCW piping configuration was acknowledged for the fourth time during the Phase I Select Sjstem Review Program in March 1986 as punch list item CCW-028; yet no safety evaluation was performe E . .
1hese repeated failures to evaluate and correct a condition adverse to quality is Violation 250, 251/86-26-03.
Resolve NRC concerns 250, 251/86-24-08 (Closed)-Violation - (4) regarding the addition of unanalyzed loads to an engineered safety features bus creating the potential for exceeding emergency diesel generator (EDG) load limitations without conducting the requisite safety evaluation. The outline used by FPL during the discussion of this ';NR is provided as Attachment 4 to this report.
FPL's Justification for Continued Operation with One Unit at Power and One Unit in Cold Shutdown Relating to Emergency Diesel Generator Loads (JPE-L-86-59, Revision 1) required that breakers feeding specific cold shutdown loads be opened to ensure that auto-connected EDG loads remained below 2750 kw.
The associated 10 CFR 50.59 evaluation stated that following the actions and recommendations specified in JPE-L-86-59, Revision 1, would limit EDG loading to 2845 kw during an accident.
These actions and recommendations were not followed when, on April 14, 1986, the "4B" 480 volt load center was energized from the "4A" 4160 volt This bus via crosstie breakers with the "4A" 480 load center.
created an EDG loading configuration that had not been analyzed in JPE-L-86-59, Revision 1, and was not analyzed prior to imple-mentation..This unanalyzed condition existed for approximately 16 hours prior to restoration of a power supply alignment consistent with JPE-L-86-59, Revision 1.
This failure to analyze a deviation from a previously approved Justification for Continued Operation and safety evaluation prior to proceeding with the deviation represents a failure to meet the requirements of 10 CFR 50.59 - violation (250,251/86-26-04).
UNR 251/85-03-02 - Resolve NRC concerns regarding the (0 pen) (5) throttling of residual heat removal (RHR) system motor operated stop valves (M0V-872).
This UNR was previously discussed in 250, 251/85-03 and 250, 251/86-06. The outline used by Reports FPL during the discussion of this UNR is provided as Attachment 5 to this report.
The NRC inspection documented in Report No. 251/85-03 discovered that MOV-4-872 had been throttled in March 1978 and subsequently in April 1984 without any apparent evaluations unthrottled completed to determine whether those changes involved unreviewed safety questions. While reviewing the historical positioning of MOV-4-872, FPL was unable to produce sufficient documentation' to justify a required position for the valve. FPL concluded that, in ._
.. .
the absence of written justification for a required valve position, the repositioning of MOV-4-872 had been assumed to be thereby not requiring a safety evaluation.
In inconsequentialFPL evaluated the repositioning of MOV-4-872 and January 1985, concluded that the actual position of the valve did not represent a safety concern.
This failure to maintain adequate design basis documentation and to evaluate the safety significance of changes in the position of still being reviewed by the Nuclear Regulatory M0V-4-872 is Commission Staff and will be addressed separately, The sixth issue discussed during the Enforcement Conference involved of a Unit 3 reactor startup with only three of four b.
the conduct required SI pumps operable, contrary to the requirements of Technical Attachment 6 to this report outlines the FPL Specification 3.4.1.4.
presentation regarding the "4B" SI pump event and the corrective actions taken to prevent recurrence.
1986, the operations staff determined that a Unit 3 On February 17, reactor startup had been performed on February 12, 1986, while only three of four required SI pumps were operable.
The discrepancy occurred because the licensee erroneously believed that discharge isolation valves for the system would be opened following operability testing when they actually remained closed. Subsequent to maintenance on the "4B" 4160 volt bus, the "48" SI pump was tested for operability The pump discharge using recirculating piping to establish a flowpath.
valves were known to be closed but the valves were not required to be procedure, OP 4101.1, High Head Safety Injection open by the test The operators thought that the valves would be System Periodic Test.to reactor criticality following the operability test.
opened prior Due to an administrative error, the valves remained closed, as required 17, 1986.
by attached clearance tags, until identified on February This problem was self-disclosed when the licensee attempted to fill the The pump started but Unit 3 accumulators by running the "4B" SI pump.
failed to raise accumulator level. A system discharge pressure gage Upon investigation, the licensee found did not indicate pump output.
that the discharge isolation valve for the "48" SI pump had not been The valve remained tagged closed opened prior to the reactor startup.This problem occurred because the operability until February 17, 1986.
test did not address the verification of valve alignment in addition to recirculation flow performance criteria.
Additionally, the required startup was not review of outstanding clearances prior to reactor adequate in that it did not identify that the pump discharge valves were tagged closed.
Daily reviews of the clearance tag log between February 12-17 also failed to identify the prob.lem.
This failure to meet the requirements of Technical Specification 3.4.1.4 is Violation 250, 251/86-26-0. .
4.
Personnel Attending the January 8, 1986 Enforcement Conference a.
Licensee Personnel Attending . J. W. Dickey, Vice President, Nuclear Operations C. M. Wethy, Site Vice President, Turkey Point J. K. Hays, Director of Licensing C. J. Baker, Plant Manager, Turkey Point W. H. Rogers, Jr., Chief Engineer, Power Plant S. G. Brain, Engineering Project Manager F. G. Flugger, Manager of Technical Licensing
E. E. Preast, Assistant Project Manager J. W. Kappes, Maintenance Superintendent, Turkey Point L. Craig, Supervisor, Electrical Engineering T. J. Vogan, Supervisor, Mechanical Engineering D. A. Chaney, Section Supervisor, Operations Licensing J. Arias, Jr., Supervisor, Regulation and Compliance, Turkey Point S. H. Cornell, Engineer b.
NRC Personnel Attending J. N. Grace, NRC Region II Administrator J.
.A. Olshinski, Deputy Regional Administrator, NRC Region II R. D. Walker, Director, Division of Reactor Projects (DRP), NRC Region II A. F. Gibson, Director, Division of Reactor Safety (DRS), NRC Region II C. A. Julian, Chief, Operational Programs Branch, NRC Region II G. R. Jenkins, Director, Enforcement, NRC Region II S. A. Elrod, Projects Section Chief, NRC Region II F. Jape, Test Programs Section Chief, NRC Region II T.E. Conlon, Section Chief, NRC Region II L. J. Callan, Performance Appraisal Section Chief, IE Headquarters D. G. Mcdonald, Licensing Project Manager, NRR B. T Debs, Operational Programs Section Chief, NRC Region II T. A. Peebles, Senior Resident Inspector, Turkey Point D. A. Brewer, Resident Inspector, Turkey Point S. F. Guenther, Project Engineer (DRP), NRC Region II M. D. Hunt, Reactor Inspector S. D. Stadler, Reactor Inspector N. Merriweather, Reactor Inspector D. P. Falconer, Reactor Inspector J. A. Arildson, Reactor Inspector F. R. McCoy, Reactor Inspector L. P. Modenos, Enforcement Specialist, NRC Region II , A. B. Beach, Senior Reactor Engineer, IE Headquarters
_ ._ . .
5.
Enforcement Conference - January 8, 1986 An Enforcement Conference was held on January 8, 1986, in the NRC Region II of fice in Atlanta, GA to discuss a number of issues, primarily the issues identified in Inspection Report 250, 251/85-40 'concerning the design inspection of the Auxiliary Feedwater (AFW) System. Attendees are listed in paragraph 4.
NRC personnel identified several types of potential violations involved but emphasized the management aspects of the problems.
Licensee personnel identified many things being done to correct AFW system weaknesses and to reconstitute the design basis of a large group safety systems.
6.
Genesis of Enforcement Action EA 86-20 Items.
Enforcement Action EA 86-20 is composed of elements discussed in several NRC inspection reports, including: 250, 251/85-32 and 85-40; and 250, 251/86-02, 06, 10, 11, 18, 24 and 26.
Since many of the reports contain other followup, unresolved, or enforcement items not included in or superceded by EA 86-20, the following table is provided to pinpoint the genesis of the items included in EA 86-20.
, EA 86-20 Notice of Violation Enforcement Conference Action Item Number Origin or Item Number Change I.A.1 UNR 250,251/85-40-04 I.A.2 250,251/85-40 paragraph 15, pages 21-23 I.A.3 250, 251/85-40 paragraph 9, page 9 I.A.4 UNR 250,251/85-40-09 I.A.5 UNR 250, 251/85-40-14 I.B UNR 250, 251/85-40-06 I.C.1 UNR 250, 251/85-40-05 I.C.2 UNR 250, 251/85-40-32 1.D.1 250, 251/85-40 paragraph 12, pages 11-14 I.D.2 250, 251/85-40 paragraph 12, pages 11-14 I.D.3 250, 251/85-40 paragraph 12, pages 11-14
- ._ . ...
EA 86-20 Notice.of Violation Enforcement Conference Action Item Number-Origin or Item Number Change , 1.D.4 250, 251/85-40 paragraph 12, pages 11-14 I.E UNR 250, 251/85-40-22 I.F UNR 250, 251/85-40-26 II.A UNR 250, 251/85-40-10 II.B UNR 250, 251/85-40-18 II.C UNR 250, 251/86-24-08 VIO 250, 251/86-26-04 III.A UNR 250, 251/86-02-03 VIO 250, 251/86-11-02 III.B VIO 250, 251/86-26-06 VIO 250, 251/86-26-06 IV.A.1 UNR 250, 251/85-40-03 IV.A.2 UNR 250, 251/85-40-17 IV.B UNR 250, 251/ 85-40-20 V.A.1 UNR 250, 251/85-40-34 V.A.2 UNR 250, 251/85-40-35 V.B.1 UNR 250, 251/86-02-04 VIO 250, 251/86-11-03 V.B.2 UNR 250, 251/85-40-19 V.B.3.a UNR 250, 251/85-40-02 V.B.3.b UNR 250, 251/ 85-40-01 VI.A UNR 250, 251/86-10-04 VIO 250, 251/86-26-01 VI.B UNR 250, 251/86-10-03 VIO 250, 251/86-26-02 VI.C VIO 250, 251/86-18-03 VIO 250, 251/86-26-03 Attachments: 1.
C.C.W. Notes 2.
I.C.W. Notes 3.
C.C.W. to H.H.S.I. Pumps Notes 4.
4B 4160 Volt Bus Notes 5.
MOV *-872 Alternate R.H.R. Notes 6.
48 HHSI Pump Event Notes
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. . . CCW FLOW BALANCE BACKGROUND IHE CCW SYSTEM PROVIDES COOLING WATER TO PLANT ESSENTIAL AND NON-ESSENTIAL COMPONENTS.
THE SYSTEM CONSISTS OF THREE (3) 100% PUMPS AND THREE i (3) 50% HEAT EXCHANGERS.
DURING NORMAL OPERATION i TWO CCW PUMPS PROVIDE FLOW TO THREE CCW HEAT EXCHANGERS.
DURING AN ACCIDENT.
ONLY ONE CCW PUMP PROVIDING FLOW TO TWO CCW HEAT EXCHANGERS l IS REQUIRED.
.._._ _ _ .. _. _ __ .. - . .. - . _ _ _ _ - _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _
o . PROBLEM STATEMENT PHASE i REVIEW OF THE SELECT SAFETY SYSTEMS IDENTIFIED THE FOLLOWING CONCERNS:
FLOW THROUGH THE RHR HEAT EXCHANGERS COULD BE LESS THAN THE REQU: RED AMOUNT PER HEAT EXCHANGER.
O IHE POTENTIAL FOR CCW PUMP RUNOUT EXISTS WHEN ONLY ONE CCW PUMP IS AVAILABLE FOR POST-LOCA RECIRCULATION PHASE CONDITI0hS.
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CCW FLOW BALANCE SEQUENCE OF EVENTS
i PHASE I REVIEW OF SELECT SAFETY SYSTEMS IDENTIFIES 1/86 - CONCERN WITH CCW SYSTEM SUPPLY 70 THE RHR HEAT , ! EXCHANGERS AND POTENTIAL FOR CCW PUMP RUNOUT.
i i 2/1/86 - ENGINEERING EVALUATION OF CONCERN COMMENCES.
2/21/86 - SHORT TERM MITIGATION ACTION IS TAKEN BY OPENING THE CCW SUPPLY TO THE RHR HEAT EXCHANGERS TO 1005 , 3/4/86 - UNIT 4 CCW SYSTEM 15 TESTED. TEST RESULTS SHOW THAT CCW FLOW RATE TO THE RHR HEAT ESCHANGER AND EMERGENCY CONTAINMENT COOLERS WERE BELOW . DESIGN VALVES WITH THE CCW SUPPLY TO THE RHR l HEAT EXCHANGERS AT 305 OPEN.
l l l 3/4/86 - CONSERVATIVE COURSE OF ACTION IS TAKEN AND UNIT 8315 SHUTDOWN.
3/18/86 - UNIT 83 CCW SYSTEM 15 BALANCED BY FLOW TEST.
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. . S&FETY SIGNIFICANCE O REDUCTION IN CCW FLOWRATE TO THE EMEP.GENCY CONTAINMENT COOLERS WILL NOT INCREASE THE PEAK CONTAINMENT PRESSURE AND TEMPERATURE.
O REDUCTION IN CCW FLOWRATE TO THE RHR HEAT EXCHANGERS WILL NOT INCREASE THE PEAK FUEL CLAD TEMPERATURE.
O IHE LONG TERM CONTAINMENT C00LDOWN MIGHT BE EXTENDED IF THE MHA OCCURS DURING PERIODS OF HIGH INLET CANAL TEMPERATURE AND FOULING OF THE CCW HEAT EXCHANGERS.
,
_ _ _ _ - . . CORRECTIVE ACTION 1.
THE CCW SYSTEM HAS BEEN TESTED AND BALANCED.
2.
CCW PUMP RUNOUT IS llPSH LIMITED.
ADEQUACY OF CCW PUMP AVAILABLE NPSH HAS BEEN VERIFIED THROUGH TESTING.
3.
OPERATING AND MAINTENANCE PROCEDURES HAVE BEEN REVISED TO INSURE THAT THE CCW SYSTEM IS MAINTAINED IN A BALANCED CONDITION FOLLOWING OPERATIONAL AND MAINTENANCE ACTIVITIES.
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. . ICW SYSTEM VALVE 2201 SYSTEM BACK6ROMD THE ICW SYSTEM PROVIDES COOLING WATER TO THE CCW AND TPCW HEAT EXCHANGERS.
DURING NORMAL - OPERATION, TWO ICW PUMPS PROVIDE FLOW TO THREE CCW HEAT EXCHANGERS AND TO BOTH TPCW HEAT EXCHANGERS.
DURING AN ACCIDENT, ONLY ONE ICW PUMP PROVIDING FLOW TO TWO CCW HEAT EXCHANGERS IS REQUIRED.
THE AEC LICENSED DESIGN PROVIDES FOR A SINGLE FLOW PATH WITH A SINGLE AIR OPERATED VALVE DOWNSTREAM OF THE CCW AND TPCW HEAT EXCHANGERS.
VALVE 2201 ISOLATES THE ICW FLOW TO THE TPCW SYSTEM UPON A SAFETY INJECTION SIGNAL TO INSURE THAT ALL ICW FLOW IS DIVERTED TO THE CCW SYSTEM.
- _ _ _ _.. __ .. . -_ -_ .. _ - _ . _ _ .. . - .. ..-. ..
. . PR0RIFM STATEENT ISOLATION OF THE TPCW HEAT EXCHANGERS IS REQUIRED IN CASE A SINGLE ACTIVE FAILURE RESULTS IN ONLY ONE ICW PUMP BEING OPERABLE.
SINGLE ACTIVE FAILURES DO EXIST, HOWEVER, WHICH WILL LEAVE CV-2201 OPEN WHEN ONLY ONE ICW PUMP IS OPERABLE.
IN THIS CONFIGURATION, THE ICW SYSTEM WILL PROVIDE LESS THAN THE DESIGN FLOW REQUIREMENTS TO THE CCW HEAT EXCHANGERS FOR AN ACCIDENT.
, __ . - - . _ _ _ _ _ _ _ _ . . .. _ .- - . . . - - - - -
_ _ _.__ _ _ _ _ _ _ ._ _ - _ _ _ _ .- ! . . ICW SYSTEM VALVE 2201 SEQUENCE OF EVENTS , l CONCERNS ARE RAISED REGARDING THE SINGLE 9/84 - FAILURE PROPERTIES OF VALVE 2201 9/84-3/85-SYSTEM TESTS ARE PERFORMED TO 08TAIN HYDRAULIC PERFORMANCE DATA FOR ICW SYSTEM.
ENGINEERING PROVIDES CURVES ( FOR C.C.W. HEAT EXCHANSER) 12/85 - TO CORRELATE I.C.W. INLET TEMPERATURE VS.1.C.W. FLOW VS. HEAT TRANSFER COEFFICIENT. THESE GRAPHS ENABLE THE i PLANT OPERATORS TO ASSESS THE PERFORMANCE OF THE C.C.W. HEAT EXCHANGERS.
, 2/13/86 - ENelNEERING EVALUATION CONCLUDES THAT A SINGLE , ' FAILURE COULD CAUSE VALVE 2201 TO Fall AS IS (PARilALLY OR FULLY opt.N). A JC0 15 PROVIDED THAT
REQUIRES OPERATOR ACTION TO INSURE VALVE 2201 CLOSES.
2/I4/86 - JC0 IS REVISED TO REQUIRE OPERATOR ACTION WITHIN 5 MINNUTES OF RECElPT OF S.I. Sl8NAL. PLANT STATIONS OPERATOR BY VALVE 2201 TO INSURE ACTION IS TAKEN AS REQUIRED BY JCO.
l l 2/16/86 - JC0 IS REVISED TO INCLUDE RESULTS OF PREVIOUS ENelNEERING ' EVALUATION AND TO PROVIDE ADDITIONAL FLEX 181LITY IN THE OPERATION OF THE ICW SYSTEM. PLANT PROCEDURES ARE REVISED TO INCORPORATE THE ADDITIONAL SUIDANCE.
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. o O SMETY SIGNIFICANCE O REDUCTION IN ICW FLOWRATE TO THE CCW HEAT EXCHANGERS WILL NOT INCREASE THE PEAK FUEL CLAD TEMPERATURE OR THE PEAK CONTAINMENT PRESSURE AND TEMPERATURE.
O THE LONG TERM CONTAINMENT COOLDOWN MIGHT IF THE MHA OCCURS DURING PERIODS BE EXTENDED OF HIGH INLET CANAL TEMPERATURE AND FOULIN OF THE CCW HEAT EXCHANGERS.
. . _- _ - - - . - - - _ _ - -- . - _ _ _ _ _ _ _
. . CORRECTIVE ACTION 1.
PLANT OPERATING PROCEDURES HAVE BEEN REVISED TO REQUIRE OPERATOR ACTION AS DESCRIBED.
2.
DESIGN MODIFICATION IN PROGRESS TO INSTALL SAFETY RELATED, FAIL-CLOSED VALVES IN THE ICW SYSTEM UPSTREAM OF THE TPCW HEAT EXCHANGERS.
VALVES ARE EXPECTED TO BE DELIVERED MID-MAY.
INSTALLATION IN UNIT
- 4 WILL FOLLOW SHORTLY THEREAFTER.
3.
PROGRAM IN PLACE TO TEST THE EFFICIENCY OF THE CCW HEAT EXCHANGERS AND TO PROVIDE FOR CLEANING OF THE TUBE SIDE OF THE HEAT EXCHANGERS AS REQUIRED.
4.
SYSTEM FOR PROCESSING AND TRACKING SAFETY EVALUATIONS IN PLACE AS DESCRIBED BY E.
PREAST PREVIOUSLY.
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_ __ .__ _ _. _ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ __. _ _ __ ATTACHMENT 3 . C.C.W. TO H.H.S.I. PUMPS PRESENTED BY: J. ARIAS,JR.
- COMPONENTS / FUNCTION DESCRIPTION
- SYSTEM CONFIGURATION (FIGURE 4) - DESIGN DESCRIPTION e PROBLEM DESCRIPTION - C.C.W. PIPING CONFIGURATION (FIGURES 5 &6 ) - PROCEDURAL CONTROLS
i e SAFETY SIGNIFICANCE
- TEC. SPECS.
! - SYSTEM OPERATION & PROCEDURAL GUIDANCE ' - OPERATOR TRAINING & RESPONSE . . e ROOT CAUSE-l - C.C.W. FLOW REVERSAL l - PROCEDURAL CONTROLS ,
- i
' e CORRECTIVE ACTIONS I - C.C.W. FLOW REVERSAL - PROCEDURAL CONTROLS e CONCLUSION (FIGURES 7 & 8)
I .
, l l
, . CCW TO HHSI PUFF C001FR I.
SYSTEM CONFIGURATION . II.
DESIGN DESCRIPTION CCW SYSTEM SUPPLIES WATER TO A NUMBER OF COMPONENTS INCLUDING HHSI PUMPS SEALS AND THRUST BEARING COOLERS.
THE SUPPLY CAN BE SELECTED FROM EITHER UNIT 3 OR UNIT 4 CCW SYSTEM.
EACH SYSTEM IS PROVIDED WITH REDUNDANT COMPONENT COOLING HEADERS FOR THE UNLIKELY EVENT OF COMPONENT COOLING HEADER BREAK FOLLOWING A LOSS OF COOLANT ACCIDENT.
-1-
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. _. - - _ - _ _ _. _ . _ ____ __ _ _ _ .. _ ! . ,. ! PROBLEM DESCRIPTION: l f A. CCW PIPING CONFIGURATION - UNIT 4 ONLY - i ! ! I \\ Q c r- ' . .m.
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, _ X Xgt-X . X E'~" ! ' a:a:s ~~ , ! =M , taam - 4" * '.*.= ) m @ j j e .% e E' ..... - N , l i, i ! AS DE310NED A3 - FOUNO l F100RE 5 FIGURE 6
' NOTE: UNIT 3 CCW PIPING WAS INSTALLED CORRECTLY l F100RE 6 DEPICTS THE UNIT 4 AS - FOUND CONDITION, WHICH SHOWS THE CCW WATER l FLUW 00E5 THROUGH A FLOW IMOICATOR IN
A REVERSE DIRECTION AND THE 4A AND 48 i HEADERS ARE CROS5 TIED.
I ' l
j ) , - -
.. . .. . . PROCEDURAL CollTROLS B.
PROCEDURAL CONTROLS DID NOT ENSU OF CCW SYSTEM ON UNIT 3, WHILE SHUTDOWN, TO , SEAL AND THRUST BEARING COOLING SUPPORT HHSI PUMPS FOR UNIT 4 AT POWER OPERATI
. l . ' i I !
< i i t
i ) l-3- - _ - - - - - . - -
. . IV.
SAFETY SIGNIFICANCE EVENTHOUGH THIS INADEQUACY OF PROCEDURAL GUIDANCE COULD HAVE RESULTED IN DEGRADATION IN THE PERFORMANCE OF THE HHSI PUMPS DURING AN ACCIDENT CONDITION ASSUMING A SINGLE FAILURE OF 1 EDG, THE LIKELlHOOD OF THIS CONDITION AFFECTING THE ABILITY TO MITIGATE THE CONSEQUENCES OF AN ACCIDENT IS SMALL.
FOR THIS CONDITION TO CONSTITUTE A SIGNIFICANT SAFETY CONCERN, THE FOLLOWING SET OF CONDITIONS NEED TO BE PRESENT: 1) TECHNICAL SPECIFICAIl0llS , EVENTHOUGH TS REQUIREMENTS ARE NOT APPLICABLE AT THIS MODE, CCW SUPPLY TO SFP HX IS REQUIRED TO ENSURE ACCEPTABLE TEMPERATURE CONDITIONS IN THE SFP.
. UNIT 3 NEEDS TO BE AT A REFUELING - SHUTDOWN WITH THE CORE DEFUELED AND UNIT 4 AT POWER OPERATION.
WITH UNIT
AT CSD TECHNICAL - SPECIFICATIONS REQUIRE (2) COOLANT LOOPS TO BE OPERABLE WITH (1) IN OPERATION.
IO SUPPORT THIS REQUIREMENT CCW SYSTEM IN UNIT 3 IS MAINTAINED OPERABLE AND WITH WATER SUPPLY AVAILABLE TO BOTH RHR HEAT EXCHANGERS.
_q-J -__ - - _ _. _-. _ _ - - _ - _-___-_-- -- __ . .,..., _ - - .- _ - -__ _- __
o . WITH UNIT 3 AT HSD, HSB AND POWER - OPERATION CCW SYSTEM OPERABILITY IS REQUIRED TO SUPPLY COOLING WATER TO RCPS AND OTHER COMPONENTS NECESSARY TO SUPPORT HEAT-UP AND CONTINUED UNIT OPERATION.
ADDITIONAL TECHNICAL SPECIFICATIONS ARE APPLICABLE DURING MODES
& 2 THAT PLACES A UNIT ON A LC0 SHOULD MAIN COMPONENTS AND/OR SYSTEM VALVES BE REQUIRED TO BE TAKEN 00S, 2) SYSTEM OPERATION AND PROCEDURAL GUIDANCE SEVERAL ALARMS AND INDICATIONS - IN THE CONTROL RMM WHICH MONITOR CCW SYSTEM PERFORMANCE NEED TO MALFUNCTION FOR A POTENTIAL INADEQUATE CCW WATER SUPPLY CONDITION TO GO UNNOTICED BY CONTROL ROOM OPERATORS.
THESE ALARMS AND INDICATIONS PROVIDE THE OPERATORS WITH AN-ASSESSMENT OF SYSTEM OPERABILITY, SHOULD OFF-NORMAL CONDITIONS BE ENCOUNTERED, PROCEDURAL GUIDANCE IS PROVIDED TO ENSURE PROPER CCW SYSTEM OPERATION AT DIFFERENT MODES OF OPERATION.
-5- . _ - _ - - _ _ - - -. - - _ _. _ . -. - _ - -. . EXAMPLES: LOW HEADER PRESSURE (78.5 - PSIG) (PC-611X) TRIGGERS THE CCW PUMPS LOW PRESSURE ALARM IN THE CONTROL ROOM AND IN PARALLEL WILL GENERATE A START SIGNAL FOR THE STAND-BY CCW PUMPS.
AND RETURN HEADERS CCW SUPPLY TEMPERATURE INDICATORS (TE-607A - & 8) WHICH PROVIDE AN INPUT TO A COMMON HIGH TEMPERATURE ALARM IN THE CONTROL ROOM.
CCW FLOW INDICATORS (FT-613 - A& B) PROVIDE THE OPERATOR WITH THE INFORMATION REQUIRED VERIFY MINIMUM AND MAXIMUM TO FLOW REQUIREMENTS AS PROVIDED IN PROCEDURES.
OPERATOR TRAINING AND RESPONSE 3) - CONTROL ROOM OPERATORS NOT NOTICING DEGRADED CCW SYSTEM PERFORMANCE.
THE OPERATORS HAVE BEEN TRAINED ON THE CCW PIPING CONFIGURATION TO THE HHSI PUMPS.
SHOULD AN OFF-NORMAL CONDITION ARISE THE OPERATORS WILL BE LIKELY TO RECOGNIZE THE UN!QUE SITUATION OF CCW SUPPLY TO THE PUMPS AND WITH THE ABILITY TO COMMUNICATE WITH THE OPPOSITE IN THE COMMON CONTROL ROOM, OPERATORS IT IS UNLIKELY THAT A DEGRADED CCW SUPPLY TO THE HHSI PUMPS WILL GO UNNOTICED AND UNCORRECTED FOR A LO PERIOD OF TIME TO IMPAIR THE OPERABILITY OF HHSl PUMPS.
-6- . -_ -- - ---_ __ _ _ --- _ -- _.
- - - -- - - - _ -.-. ..-
} . . Il ROOT CAUSE A.
CCW FLOW REVERSAL ORIGINAL INSTALLATION OF CCW PIPING IN UNIT 4 TO THE HHSI PUMPS, WAS NOT IMPLEMENTED IN ACCORDANCE WITH DESIGNED DOCUMENTS.
B.
PROCEDURAL CONTROLS . FROM INITIAL IDENTIFICATION OF FLOW REVERSAL CONDITION, IT WAS CONSIDERED TO BE A RELIABILITY / AVAILABILITY CONCERN.
JUSTIFICATIONS AT THE TIME WERE: 1) PROCEDURAL CONTROLS EXIST TO SUPPLY CCW TO THE HHSI PUMPS FROM UNIT 3 ONLY AND 2) 'PC/M 83-08 We .D BE IMPLEMENTED.TO CORRECT THE DISCREPANT CONDITION.
THE PROCEDURAL CONTROLS NECESSARY FOR THE CORRELATION BETWEEN THE UNIT 3 STATUS AND SYSTEM CONFIGURATION TO SUPPORT UNIT
HHSI PUMPS OPERATION WERE NOT IDENTIFIED AS INADEQUATE UNTIL RECENTLY.
. _ _ _ _. . _ - - -. . __ _ _ .. - __
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Vll. CURRECTIVE ACTIONS '
A.
FLOW REVERSAL UPON IDENTIFICATION OF CCW FLOW - REVERSAL CONDITION, ENGINEERING REVIEWS WERE INITIATED WHICH ' RESULTED IN THE ISSUANCE OF PC/M 83-08 WHICH RETURNS THE PIPING TO ORIGINAL DESIGN CONFIGURATION.
DUE TO PHYSICAL CONTRAINTS OF UNIT STATUS AND THE UNAVAlLABILITY , OF SUFFICIENT ISOLATION VALVES FROM THE CCW PUMPS TO THE HHS1 PUMPS TO FACILITATE THIS MODIFICATION, DELAYS HAVE OCCURRED IN THE IMPLEMENTATION OF PC/M 83-08.
PC/M 83-08 PRESENT STATUS - IMPLEMENTATION WILL BE COMPLETED PRIOR TO UNIT 4 RESTART.
B.
PROCEDURAL CONTROLS PRIOR TO DISCOVERY OF FLOW REVERSAL CONDITION PROCEDURAL CONTROLS WERE IN PLACE TO ENSURE NORMAL ALIGNMENT OF CCW SYSTEM FROM UNIT 3 TO HHS1 PUMPS COOLERS EVENTHOUGH LINE UPS WERE AVAILABLE FROM EtTHER UN!T, (OP 3100.1) 06-10-82 - UPON DISCOVERY OF FLOW REVERSAL (UP 3100.1) CONDITION PROCEDURAL CONTROLS WERE PUT IN PLACE TO ENSURE THAT UNIT
CCW LINE-UP WAS MAINTAINED ISOLATED UNTIL PIPING CONFIGURATION WAS CORRECTED.
-8- _ _ _. _. _
. . 12-14-84 - AS A RESULT OF OUR PROCEDURE UPGRADE PROGRAM OP 3100.1, NORMAL OPERATION OF CCW SYSTEM, WAS SUPERSEDED BY OP-30.
THIS NEW PROCEDURE IN SECTION 6.0, SHUTDOWN CONTAINS THE FOLLOWING NOTE: NOTE: THE COMPONENT COOLING WATER SYSTEM IS REQUIRED TO BE IN OPERATION AT ALL TIMES DUE TO THE HEAT SINK PROVIDED FOR THE SFP COOLING SYSTEM AND THE RECIRCULATION PHASE OF A LOCA, INDIVIDUAL COMPONENT OUTAGES WILL BE ACCOMPLISHED UNDER ADMINISTRATIVE PROCEDURE 0103.4, IN-PLANT EQUIPMENT CLEARANCE ORDERS.
l _g.
- _. .--__ __ - _ _- . - - - - - - - - - ---- ---- - --- - - - - - - - - - - - - -- -
O
03-26-86 - PROCEDURE CHANGES WERE MADE TO THAT CCW As B HEADERS SUPPLY TO THE HHSl PUMPS IS NOT INTERRUPTED.
04-15-86 - PROCEDURE CHANGES (OTSCS) WERE M TO ENSURE THE ' REDUNDANCY OF THE UNIT
CCW SYSTEM ALIGNED TO THE HHS1 PUMPS.
IN ADDITION, THE AVAILABILITY OF THE CCW SYSTEM SHALL BE GOVERNED BY THE MOST RESTRICTIVE TECHNICAL SPECIFICATIONS BASED ON
THE OPERATING MODES OF UNIT 3 Ag.
UNIT 4.
PRESEllT STATUS: FOLLOWING IMPLEMENTATION OF PC/M 83-08 AND PRIOR WILL 4 RESTART ADDITIONAL PROCEDURE CHANGES TO UNIT INSTRUCT THE OPERATORS OF ACTIONS REQU BE MADE TO TO LINE-UP THE HHSI PUMPS COOLING FRO CCW SYSTEM AND FOLLOW THE MOST RESTRIC SPECIFICATION IN ACCORDANCE WITH APPLICABLE UNITS OPERATION MODE.
AS PART OF PROCEDURAL CONTROLS Al. READY IN PLACE, IMPLEMENTATION OF PC/M 83-08, TRAIN!!iG FOLLOWING THE THE NEW P! PING , BE PROVIED TO THE OPERATORS ON WILL CONFIGURATION AND APPLICABLE PROCEDURAL CONTROLS TO BE IMPLEMENTED.
- 10- _ .. . -.. ._ _- . - - _ _ - - - -. _ - _ - --.
. . WILL BE PROVIDED TO THE OPERATORS ON THE NEW PIPING CONFIGURATION AND APPLICABLE PROCEDURAL CONTROLS TO BE IMPLEMENTED.
X.
COELUSION IN SUMMARY, IT BECOMES APPARENT THROUGHOUT THIS PRESENTATION THAT TWO DISTINCT DEFICIENT AREAS WERE DISCOVERED 1) THE ACTUAL PIPING CONFIGURATION NOT IN ACCORDANCE WITH ORIGINAL DESIGN DOCUMENTS AND 2) ADEQUATE REVIEW OF AS-FOUND CONDITION WAS NOT PERFORMED.
IN REVIEWING THE RESOLUTION PATH THAT THIS CONCERN,TOOK (FIGURE 4) VERSUS THE PRESENT EFFECTIVE SYSTEM OF EVALUATING AS-FOUND CONDITIONS (AS SHOWN (FIGURE 5) BY E. PREAST) CURRENTLY IMPLEMENTED AT PTN, WE ARE CONFIDENT , THAT THIS TYPE OF CONDITION IS AND WILL CONTINUE TO BE PROPERLY REVIEWED AND ADEQUATELY RESOLVED IN A TIMELY AND EFFICIENT MANNER.
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. . . , ' .. . 4B 4160 Volt Bus , I e What Happened e Safety Significance
- Engineering Evaluation
- Prevention-
- - - .
'O . VAK 05-08-86 Page 1 of 2 THAT HAPPENED? In order to oerform required Aopendix 'R' work, the 4B 4160 Bus was required to be out of service.
In removing the 4B 4160 Bus f rom service, we f elt we were inside the bounds of the JCO.
'Vhy did we assume that? Secause we had taken an additional normal containment cooler out of service to give us additional margin.
Throttled CCW/ICW flow at the component and at the discharge of the Heat Exchanger to ersure the 3CO was ccmplied with.
All our actions were very conservative.
- On Sunday, Aoril 13, 1936, 48 4160 Bus was removed f rom service in preparation to do the required Apendix R wor'<. (Notch 1) Bus removed via approved olant procedure.
2) Unit in cold shutdown the required load is greatly reduced.
- On Monday, Aoril 14,1936, the Operations Department held a general discussion on the 3CO and one of the topics discussed was the 4B 4160 bus wor'< (not considered a problem because of previous cornervative actions) - \\t that time, % erat [ons called Engineering to see if removal of 48 bus was considered in 3CO.
-
.. YAK 05-08-86 Page 2 of 2 . The 3CO did not specifically address the removal of the bus from service.
idering the Engineering was asked to review our electrical linevo cons The initial evaluation found that removal of 4B bus out of service.
the 48 5us did not violate the 3C0. No significant saf ety concern.
) l i Engineering was then asked to perf orm a f armal (written eva uat on 'Vhile the iormal evaluation was Seing written, the bus was returne - to service. Additional cornervative action.
Turkey Point, - Later that week, the f ormal evaluation Was received at 4B bus removed from service, and Aopendix 'R' work continued.
f PREVEPfTION: i s 30s tie breakers racked out to Operatf oru Suoerintendent, Ooerat on electrical Supervisor, and Plant Supervisor Nuclear to ensure realignment are aporoved. All three must aporove cSange.
l f rom Requested f ormal evaluation on 4 A 410 bus orlor to renova service.
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-.. _ _ _ _ _ _ _ _ _ _ _ _ _. "o ATTACHMENT 5 e I MOV
- - 872 ALTERNATE R.H.R.
PRESENTED BY: J. ARIAS,JR.
SYSTEM CONFIGURATION (FIGURE 1) e e DESIGN DESCRIPTION e PROBLEM DESCRIPTION - MOV *-872 THROTTLED - MOV *-872 NOT THROTTLED e SAFETY SIGNIFICANCE - MOV *-872 THROTTLED - MOV-*-872 NOT THROTTLED e ROOT CAUSE e CORRECTIVE ACTIONS - PROCEDURAL CHANGES - POSITIONING OF MOV-*-872 e CONCLUSION
__ _ _ _
- - - __ ______ , . M0V 872 ALTERNATE RHR I.
SYSTEM CONFIGURATION
f , - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
- - . _ _ _ _ _ _ _ - . . 1s M*M OHV SdunS ~351335 WOIIA
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- 2
.. - . -.. -. .. - . -..... . -. _ _ _.
. '. II.
DESIGN DESCRIPTION THE NORMAL LOW-HEAD ECCS FLOW PATH WAS DESIGNED TO ACCOMMODATE ANY SINGLE ACTIVE FAILURE.
IN ADDITION AN ALTERNATE LOW HEAD ECCS FLOW PATH WAS PROVIDED TO ACCOMMODATE SOME SINGLE PASSIVE PIPING FAILURES.
ISOLATION OF THIS ALTERNATE FLOWPATH IS ACCOMPLISHED BY A REMOTE MANUAL MOTOR OPERATED VALVE, MOV *-872.
THIS ALTERNATE FLOW PATH IS ONLY TO BE USED IN THE LONG TERM POST-LOCA OPERATING MODE AFTER SWITCH OVER TO THE RECIRCULATION MODE AND IN THE EVENT A PASSIVE FAILURE OCCURS IN THE NORMAL LOW HEAD FLOW PATH.
-2- . _, -- ___ _.
_.
.. . ._
- _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ . , III. PROBLEM DESCRIPTION DURING START-UP TESTING OF TURKEY POINT, UNIT 4 IT WAS DETERMINED THAT THE PIPING RESISTANCE l AND RHR PUMP PERFORMANCE CHARACTERISTICS WERE l SUCH THAT THE RHR PUMPS WOULD RUN OUT TO A FLOW RATE WHICH COULD NOT BE ACCOMODATED WITH THE SUCTION PRESSURE AVAILABLE DUR,ING POST ACCIDENT RECIRCULATION FROM THE CONTAINMENT SUMP.
IN ORDER TO PRELUDE THIS, VALVES IN THE RECIRCULATION FLOW PATHS WOULD HAVE TO BE THROTTLED TO AVOID PUMP RUNOUT.
(VALVES THROTTLED 4-872, 4-758, 4-887) A.
M0V *-872 THROTTLED THIS CONDITION DOES NOT REPRESENT A CONCERN SINCE THE THROTTLING OF MOV-872 ENSURES: 1) FLOW TO ALL REQUIRED FLOW PATHS IN THE UNLIKELY EVENT OF A PASSIVE FAILURE IN THE NORMAL LOW HEAD FLOW PATH.
2) PREVENTION OF RHR PUMP RUNOUT WITH INSUFFICIENT NPSH AVAILABLE.
3) LOW HEAD INJECTION FLOW IS SUFFICIENT TO MAINTAIN CORE COOLING.
I I-3- -_ _____
. , B.
M0V*-872NOTTHROTTja . THIS CONDITION REPRESENTS A CONCERN ONLY IN THE SITUATION WHERE. A PASSIVE FAILURE IN THE NORMAL LOW HEAD FLOWPATH DURING LONG TERM POST-LOCA OPERATING MODE AFTER SWITCH OVER TO RECIRCULATION MODE REQUIRES THE OPERATOR TO SWITCH OVER TO THE ALTERNATE LOW HEAD FLOWPATH WHICH CAN ONLY BE PLACED IN OPERATION PROVIDED BOTH RHR PUMPS ARE AVAILABLE.
IN THIS SITUATION IT IS POSTULATED THAT THE HEAD REQUIRED FOR NPSH CONSIDERATIONS MAY NOT BE SUFFICIENT.
IV.
SAFETY SIGNIFICANCE A.
M0V *-872 THROTTLED AN EVALUATION WAS PERFORMED PURSUANT TO
CFR50.59 TO DETERMINE THE ACCEPTABILITY OF THROTTLING OF MOV-872 ENSURES FLOW TO ALL REQUIRED FLOW PATHS IN THE UNLIKELY EVENT OF A PASSIVE FAILURE IN THE NORMAL LOW HEAD FLOW PATH, THE THROTTLING OF MOV-872 DOES NOT INVOLVE ANY UNREVIEWED SAFETY QUESTIONS OR AFFECT THE f ' PROPER OPERATION OF ANY EQUIPMENT IMPORTANT
- TO SAFETY.
i _q_ - .- - - -.
. . .. . . , . . THE THROTTLED POSITION ALSO ASSURES THAT LOW HEAD INJECTION FLOW IS SUFFICIENT TO MAINTAIN CORE COOLING.
B.
MOV *-872 NOT THROTTLED EVENTHOUGH, DURING POSTULATED UNIQUE SITUATIONS FOLLOWING A LOCA, MOV *-872 FULLY OPEN COULD CAUSE RHR PUMPS SUCTION HEAD TO BE LESS THAN REQUIRED NPSH CONSIDERATIONS, THE LIKELIHOOD OF THIS CONDITION HAVING AN EFFECT ON THE LONG TERM STABLE POST LOCA OPERATING MODE IS SMALL.
THIS IS BASED ON: 1) DURING A DESIGN BASIS ACCIDENT, (1) EDG IS ASSUMED TO FAIL THUS RENDERING (1) TRAIN OF ESF EQUIPMENT INOPERABLE.
IN THIS CONDITION, THE NORMAL LOW HEAD FLOWPATH IS ASSUMED TO BE OPERATING SINCE DOUBLE FAILURES DURING AN ACCIDENT CONDITION IS BEYOND THE DESIGN BASIS.
IN ADDITION, E0PS RESTRICT THE USE OF THIS ALTERNATE FLOWPATH TO HAVING BOTH RHR PUMPS AVAILABLE SINCE FLOW TO THE HHSI PUMPS FOR RECIRCULATION TO THE HOT LEGS MUST BE MAINTAINED AND FLOW TO ALL PATHS CAN NOT BE SATISFACTORILY l l SUPPLIED BY ONE PUMP.
-5- - - - - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. ~ 2) E0PS INSTRUCT THE OPERATOR TO VERIFY ADEQUATE RHR DISCHARGE PRESSURE.
IT IS REASONABLE TO ASSUME THAT WHEN THIS POSTULATED CONDITION, THE OPERATORS WILL TAKE PROMPT ACTION TO EITHER: A) SECURE FLOW THROUGH M0V-872 OR B) DISPATCH AN OPERATOR TO THROTTLE THE DISCHARGE > VALVES OF THE RHR PUMPS TO INCREASE PUMP OPERATING PRESSURE.
ALTHOUGH SUSTAINED OPERATION OF RHR PUMP BELOW THEIR REQUIRED NPSH MAY DAMAGE THE PUMPS VIA PROLONGED CAVITATION, IT IS NOT CONSIDERED LIKELY THAT THE SHORT TERM OPERATION THAT MAY OCCUR IN THIS POSTULATED SCENARIO WOULD CAUSE ANY CONSEQUENTIAL DAMAGE TO THE PUMP.
THE PUMP WOULD BE EXPECTED TO EXPERIENCE MILD CAVITATION (NPSH AVAILABLE BEING CLOSE TO NPSH REQUIRED) FOR THE SHORT PERIOD OF TIME REQUIRED TO CORRECT THE PUMP'S DISCHARGE PRESSURE BY PROMPT OPERATOR ACTION AS INSTRUCTED BY ! PROCEDURES.
I SINCE NO CREDIT IS TAKEN IN THE FSAR FOR THE AVAILABILITY OF THE ALTERNATE LOW HEAD FLOWPATH, AND THAT CONSIDERATIONS OF THE NEED TO DESIGN AGAINST SINGLE FAILURES OF PASSIVE COMPONENTS-6- ... - - _.
. - -. _ _ ___ __. _. _ _. .. _
__ __ _ .. . IN FLUID SYSTEMS IS BEYOND GDC (36 FR 3255 2/71), IT CAN BE CONCLUDED THAT ANY REGULATORY OR SAFETY CONCERN ASSOCIATED WITH FULL OPENING OF MOV-872 IN THE LONG TERM POST-LOCA ENVIRONMENT IS BEYOND THE DESIGN BASIS OF THE FACILITY.
ROOT CAUSE INITIAL START-UP TESTING OF UNIT 4, REQUIRED I MOV-4-872 TO BE THROTTLED BY FLOW ADJUSTMENT.
SUBSEQUENT POSITIONING OF MOV-872 WAS GOVERNED Bf: 1) INSUFFICIENT DOCUMENTATION DETAILING THE BASIS FOR THROTTLING MOV-872.
2) ON JUNE 30, 1977 THE NRC ISSUED A LETTER TO FPL REQUESTING AN EVALudTION OF PUMP RUNOUT CONSIDERATIONS IN THE HIGH HEAD AND LOW HEAD INJECTION SYSTEMS.
AS A RESULT, HCV *-758 WERE THROTTLED AND SUBSEQUENT NRC CONCURRENCE WAS RECEIVED.
3) ADDITIONAL CONCERNS BY PLANT STAFF ON RHR PUMP RUNOUT, RESULTED IN THROTTLING MOV *-872 IN THE EARLY 1978 TIME FRAME.
NO JUSTIFICATION COULD BE FOUND FOR THIS EVOLUTION.
4) APRIL 1984 WHILE VERIFYING PROPER VALVE i -/- __ . _ _ _ -. ..- -.--.. _.
._ .. - - -.
.
SEATING AND NOT BEING ABLE TO FIND JUSTIFICATION FOR THROTTLING CONDITION, MOV-4-872 WAS RETURNED TO FULL OPEN CONDITION.
IN REVIEWING THE ABOVE SEQUENCE OF EVENTS, IT BECOMES CLEAR THAT INSUFFICIENT WRITTEN JUSTIFICATION FOR REQUIRED MOV *-872 POSITION ALLOWED THE REPOSITIONING OF THIS VALVE WITHOUT EVALUATIONS.
'
V.
CORRECTIVE ACTIONS - SUBSEQUENT TO THE LAST POSITIONING OF MOV-4-872 ENGINEERING WAS REQUESTED TO PROVIDE GUIDANCE FOR THROTTLING VALVES TO PROTECT THE RHR PUMPS AGAINST RUNOUT FLOW IF THE ALTERNATE FLOW PATH WAS UTILIZED DURING POST-LOCA RECIRCULATION.
THIS GUIDANCE WAS ISSUED ON JANUARY, 1985 TO THROTTLE RHR PUMP DISCHARGE MANUAL VALVES *-754 A8B, PRIOR TO OPENING MOV *-872.
THIS INFORMATION WAS INCORPORATED INTO - EMERGENCY OPERATING PROCEDURE, (E-1), LOSS OF REACTOR COOLANT, TO PROVIDE ADDITIONAL GUIDANCE TO PREVENT RHR PUMP RUNOUT, ON FEBRUARY ,
8, 1985.
A SAFETY EVALUATION WAS COMPLETED BY - ! ENGINEERING ON JUNE 12, 1985 TO ALLOW THE THROTTLING OF MOV-872.
M0V-3-872 WAS THROTTLED ON JUNE 12, 1985 WHILE UNIT 3 WAS IN A REFUELING OUTAGE.
-8-i _ __ _ . .. - _... _ - - _ _
. , - ON AUGUST 5, 1985 AN EVALUATION WAS TRANSMITTED TO THE NRC THAT WAS PERFORMED PURSUANT TO 10 CFR50.59 CONCERNING TH E-PREVIOUS CONDITION ON UNIT 4 WITH MOV-872 NOT THROTTLED AND FOR i THE ACCEPTABILITY OF THROTTLING MOV-872.
THIS EVALUATION DETERMINED THAT AN UNREVIEWED SAFETY QUESTION DID NOT EXIST FOR EITHER CASE.
DURING THE CURRENT UNIT 4 REFUELING OUTAGE, - MOV-4-872 HAS BEEN THROTTLED, HOWEVER, TESTING TO VERIFY THE PROPER VALVE POSITION WILL BE ACCOMPLISHED PRIOR TO RESTART OF UNIT 4.
PRESENT PROCEDURAL GUIDANCE INSTRUCTS THE - OPERATOR TO THROTTLE THE RHR PUMP DISCHARGE VALVES (754 A8B) PRIOR TO OPENING MOV-872.
MECHANICAL STOPS ARE INSTALLED ON 758 TO - ENSURE PROPER THROTTLED POSITION.
RHR SYSTEM LINE-UP PROCEDURES REQUIRES VALVE - 887 TO BE LOCKED THROTTLED.
CONCLUSION IN SUMMARY, AFTER REVIEWING THE MATERIAL IN l THIS PRESENTATION, IT BECOMES APPARENT THAT: l 1) INSUFFICIENT DOCUMENTATION FOR REQUIRED ' MOV-872 POSITION ALLOWED THE VALVE TO BE REPOSliIONED WITHOUT THE NEED FOR ENGINEERING EVALUATION.
_g_ _ _ . _.
. _.
-.
.
2) EVENTHOUGH, THE REPOSITIONING OF THE VALVE WAS NOT EVALUATED PRIOR TO JANUARY 1985, THE ACTUAL CONDITION DID NOT REPRESENT A SAFETY CONCERN.
3) SINCE THE LOW HEAD ALTERNATE FLOWPATH IS NOT ASSUMED TO BE REQUIRED IN THE DESIGN BASIS, REPOSITIONING OF MOV-872 DID NOT CHANGE THE FACILITY AS DESCRIBED IN THE FSAR.
IN CAN BE CONCLUDED THAT ANY REGULATORY OR SAFETY CONCERN ASSOCIATED WITH POSITIONING MOV-872 IN THE IS BFYOND THE DESIGN LONG TERM POST-LOCA ENVIRONMENT BASIS OF THE FACILITY AND THE UNREVIEWED SAFETY QUESTION DETERMINATION OF
CFR50.59 IS INAPPROPRIATE.
i IN REVIEWING THE RESOLUTION PATH THAT THIS CONCERN TOOK (FIGURE I4) VERSUS THE PRESENT EFFECTIVE SYSTE l 0F EVALUATING AS-FOUND CONDITIONS (AS SHOWN (F 5) BY E. PREAST) CURRENTLY IMPLEMENTED AT PTN, WE ARE CONFIDENT THAT THIS TYPE OF CONDITION IS AND WILL CONTINUE TO BE PROPERLY REVIEWED AND ADEQUAT RESOLVED IN A TIMELY AND EFFICIENT MANNER.
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48 HHSI PUMP EVENT , \\ ' i WHAT HAPPENED ' o ..
I WHY IT HAPPENED e
, A
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. . 48 HHSI PUMP I.
WHAT HAPPENED: A.
4B 4KV BUS OUT-OF-SERVICE.
B.
RENDERS 4B HHSI OuT-OF-SERVICE.
C.
CLEARANCE ISSUED ON MOV-4-869 RENDERS 4B HHSI OuT-0F-SERVICE.
D.
UNIT
TRIPS DUE TO CONSTRUCTION ACTIVITY.
E.. FOR UNIT
TO RETURN TO SERVICE (CRITICAL) ALL
HHSI PUMPS MUST BE OPERABLE.
F.
4KV BUS RETURNED TO SERVICE AND 4B HHSI PUMP TESTED.
G.
CLEARANCE NOT RELEASED ON MOV-4-869.
H.
UNIT 3 TAKEN CRITICAL AND PLACED ON-LINE.
_
__ a.
'
11.
WHY IT HAPPENED
PRIOR TO UNIT 3 CRITICALITY OPERATIONS MAINTENANCE COORDINATOR INSPECTS - 4B 4160 VOLT bus
OPERATIONS MAINTENANCE COORDINATOR INVESTIGATES CLEARANCE TAG ON BREAKER 4AB12 (4B HHSI PUMP BREAKER)
OPERATIONS MAINTENANCE COORDINATOR INFORMS NUCLEAR WATCH ENGINEER OF CLEARANCE TAG ON 4AB12
NUCLEAR WATCH ENGINEER RECEIVES PERMISSION TO TEMPORARILY LIFT THE CLEARANCE ON BREAKER 4AB12, BUT NOT THE ASSOCIATED VALVES (ASSUMES MAINTENANCE' IS CHECKING OUT REST OF VALVES (MOV-4-869)
REACTOR CONTROL OPERATOR (RCO) UNIT
TEMPORARILY LIFTS 4AB12 BREAKER AND PERFORMS OP-4104.1 HHSI PERIODIC TEST (IHE RC0 ASSUMES REST OF CLEARANCE IS BEING CHECKED OUT)
RCO LOGS OP 4104.1 TEST SATISFACTORY INFORMS THE PLANT SUPERVISOR-NUCLEAR AND WHO IN TURN LOGS OP 4104.1 TEST SATISFACTORY.
- . - _ _ _ _ - _____ _ . -.. - _ _ _. _ - - _ _ _ _ _ _ _ _ - -. _. _- .
i .
RCO ASSUMES NUCLEAR WATCH ENGINEER IS GOING TO CHECK OUT REMAINING VALVES.
NUCLEAR WATCH ENGINEER ASSUMES RCO IS GOING TO CHECK OUT REMAINING VALVES.
O PEAK SHIFT RCO HAD NO REASON TO SUSPECT PROBLEM ON 4B HHSI PUMP LOG ENTRIES - SAT. AND CONTROL ROOM INDICATION NORMAL.
O UNIT 3 GOES CRITICAL .
.
Ill. SAFETY SIGNIFICANCE A.
TIME LINE FOR EVENT.
IIME SHORT WHEN OTHER PUMPS COULD HAVE BEEN REMOVED FROM SERVICE.
B.
WESTINGHOUSE SENSITIVITY STUDY FOR SINGLE SI PUMP.
. , _ -. -. ._ .
e
IV.
PROCEDURAL STRENGTHS To PREVENT OCCURRENCE A.
STARTING FROM COLD SHUTDOWN THERE ARE
SEPARATE AND DIFFERENT METHODS USED TO VERIFY SAFETY SYSTEM FLOWPATHS.
A.
LOCKED VALVE CHECK B.
CLEARANCE BOOK REVIEW C.
RELATED SYSTEM STATUS D.
EQUIPMENT OUT OF SERVICE REVIEW E.
TABLE 1 WALKDOWN B.
CLEARANCE BOOK CHECK TO VERIFY E00S ON UNIT BEING RESTARTED FROM HSB.
< l l
,. . V.
CORRECTIVE ACTION To PREVENT RECURRENCE o CLEARANCE BOOKS REVISED TABLE 1 (OC) INCORPORATED INTo 0202.2 o i l I ! .. - - - -.- . _ _ _. - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ __ _ _
. - - . _ _ _ _ - - _ ... _ - - - _ _ _ - _ - _ _ __ >.... l - l 4B HHSI PUMP SEC!UENCE ' Iltig M EVENT
22:00 FEB.4,1986 48 4160 (86-2-011) 4A812 003
07:05 FEB. 5,1986 48 HHS1 DISCHAR8E VALVE CLOSED ] (86-2-033) 4A812 005 i l 13:31 FEB.11,1986 UNIT 3 TRIPS 12:20 FEB.12,1986 TEMP LIFT 48 HMSI BREAKER 4A812 (86-2-033) l ' ! 12:23 FE8.12,1986 86-2-0114A812 (48 HHSI) IN SERVICE 16:52 FEB.12,1986 UNIT 3 CRITICAL 19:24 FEB.12,1986 UNIT 3 ON LINE 14:13 { 09:37 i l FEB.12,1986 48 4160 003 Rx 555 POWER 22:00 FEB 16,1986 86-2-011 48 BUS RETURNED TO SERVICE ! 2:18 { 00:18 l FEB.17,1986 86-2-011 48 4160 IN SERVICE (N0 FLOW) ! i 01:05 FEB.17,1986 86-2-033 4A812 (HHSI) 005 TEMP LIFT , l 06:20 FEB,17,1986 86-2-033 4512 IN SERVICE ! ! ! ! ! i t i ! - , i.
- - - . - . -..- -- }}