L-85-109, Responds to Violations Noted in Insp Repts 50-250/84-39 & 50-251/84-40.Corrective Actions:Operating Procedure 7304.1 Re Periodic Test of Auxiliary Feedwater Sys & Tech Spec 3.8 Revised to Clarify Limiting Conditions for Operation
| ML20113D727 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 03/18/1985 |
| From: | Walker R, Williams J FLORIDA POWER & LIGHT CO. |
| To: | Grace J, Williams J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20113D725 | List: |
| References | |
| 850319, L-85-109, NUDOCS 8504150558 | |
| Download: ML20113D727 (5) | |
Text
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85 nia 18 A 9. 4 i econio^ rowen a ticar cove 4~v ISR 131985 L-85-109 Dr. J. Nelson Grace Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101 Marietta Street NW, Suite 2900 Atlanta, Georgia 30323
Dear Dr. Grace:
Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Inspection Report 250-84-39 and 251-84-40 Florida Power and Light Company has reviewed the subject inspection report and a response is attached.
There is no proprietary information in the report.
Very truly yours, J. W. Williams, Jr.
Group Vice President Nuclear Energy JWW/JA/js Attachment ec: Harold F. Reis, Esquire PNS-LI-85-103-1 8504150558 850322 PDR ADOCK 05000250 G
PDR PEOPLE.. SERVING PEOPLE
,s ATTACimENT Re: Turkey Point Units 3 and 4 Docket No. 50-250, 50-251 IE Inspection Report 84-250-39 and 84-251-40 EINDING 1:
Technical Specification 3.8.4.b requires that three Auxiliary Feedwater (AFW) punps be operable when both units are heated above 350 degrees. The allowable out-of-service time applies only to units that are above 2% power.
If the TS Limiting Condition of Operation cannot be met, a cooldown of units not above 2% power is required.
Contrary to the above, while Unit 4 was heated above 350 degrees on December 3,1984, the "A" AFW pump was declared out of service at 10:44 a.m.
bu: a cooldown was not commenced for several hours.
RESPONSE
1)
FPL concurs with the finding.
2)
The reason for the finding was a misinterpretation of Technical Specification (TS) 3.8 by plant personnel.
The Plant Supervisor Nuclear considered that since the AFW pump test was being conducted on Unit 3 and Unit 3 was in power operation, declaring the "A" AFW pump out of service constituted a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> limiting condition for operation (LC0) as per TS 3.8.
The status of Unit 4, which was undergoing a reactor startup, was not considered.
Plant management thought the testing was being done as part of the Unit 4 startup, which would have placed Unit 4 above 2% rated power.
Under these conditions, TS 3.8 would allow a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO.
Therefore, the requirement to immediately initiate a reactor coolant system cooldown on Unit 4 was deemed not to be applicable to this event.
3)
Subsequent review of this incident by plant management determined that a cooldown on Unit 4 was required until the operability of the "A" AFW pump could be determined.
A temporary system alteration to isolate the differential pressure (DP) cell on the "A" AFW pump was written and I
approved.
The DP cell 'was isolated and the "A" AFW pump was retested satisf actorily and placed back in service.
Additionally, operating l
procedure (0P) 7304.1, " Auxiliary Feedwater System - Periodic Test", has been revised to specify actions to be taken when an AFW pump is declared I
out of service depending upon the status of both units.
4)
To preclude recurrence, a revision to TS 3.8 is being developed.
This revision includes the introduction of Applicability Modes of Operation and Action Statements which are consistent with Standard Technical Speci-l fication format.
The proposed revision will enhance and clarify the requirements for LC0 applicability and compliance.
b)
Full compliance for item 3 above was achieved on December 13, 1984 L
J
b:
IE Inspection Report 250-84-39 and 2b1-84-40 Page 2 FINDING 2:
Technical Specification 4.10.4 requires that when testing of the AFW pumps is performed, that the tests shall be considered satisfactory if control panel indication and visual observation of the equipment demonstrate that all compo-nents have operated properly.
Contrary to the above, testing of the "A" AFW pump was declared satisfactory on December 3,1984, at 1:00 p.m., when the pump differential pressure cell was known to not operate properly.
RESPONSE
1)
FPL concurs with the finding.
2)
The reason for the finding was the failure mode of the differential pressure (DP) cell, as encountered on this incident, reflected itself identically to a DP cell being removed from service (0 output). For this reason, a determination was made that-failure of the DP cell did not impai r operability of "A"
AFW pump.
This was based on previous engineering evaluations performed justifying proper pump operation with DP cell removed.
3)
Subsequent review of this incident by plant management revealed that the "A" AFW pump should be declared out of service until its operability could be determined.
A temporary system alteration to isolate the DP cell was written and approved by plant management.
The DP cell was isolated and the "A" AFW pump was satisfactorily retested and placed back in service.
4)
To preclude recurrence, the Procedure Upgrade Program is revising surveillance procedures to clarify acceptance criteria to be used during surveillance testing and to provide guidance on what actions to take when acceptance criteria cannot be met.
The procedures are also being reviewed for proper documentation, independent verification and record retention requirements.
Completion of this action is presently covered under the Performance Enhancement Program (PEP) schedules and controls.
b)
Full compliance for item 3 above was achieved on December 3,1984 FINDING 3:
Technical Specification 3.5, Table 3.5-1, delineates the conditions of the instrumentation and safety circuits necessary to ensure reactor safety.
Items 3 and 4 require that a minimum degree of redundancy of 1 exist for the overpower delta-T (OPDT) and overtemperature delta-T (0 TDT) protective circuits.
Contrary to the above, between February 23, 1983, and October 31, 1984, a minimum degree to redundancy of one channel did not exist for the OPDT and the OTDT protective circuits because, for one channel, the delta-T trip setpoint was not automatically reduced as rec ui red.
The corrective factor did not begin penalizing the OPDT and 0 TDT trip setpoints at the proper percentage of flux imbalance. Additionally, the amount of the penalization was not correct.
R;:
IE I~spection Report 250-E4-39 and 251-84-40 Page 3
RESPONSE
1)
FPL concurs with the finding.
2)
The reason for the finding was inadequate procedural guidance to the operator when acceptance criteria could not be met.
Operating Procedure (0P) 12304.2,
" Power Range Nuclear Instrumentation Periodic Channel Functional Test",
required the operator to investigate and take corrective action when surveillance testing indicated acceptance criteria could not be met.
In these instances, the operator submitted a plant work order to have the discrepancy corrected, but did not remove the channel from service.
3)
The affected channel of reactor protection was taken out of service and the associated bistables tripped when maintenance personnel began to work on the channel.
The problem was corrected and the channel returned to service.
Additionally, OP 12304.2 has been revised to provide guidance to the operators on actions to be taken when acceptance criteria cannot be met.
An analysis was performed on the significance of the axial flux imbalance input to the differential temperature trip setpoints.
The analysis revealed that values as high as +28% axial flux imbalance would have had no adverse affect on the departure from nucleate boiling (DNB) core safety analysis.
Additionally, this variable axial flux imbalance correction factor is part of a defense-in-depth design which includes an axial flux deviation alarm and target flux requirements.
There is no indication that any core safety limits were exceeded and no transients were experienced which would have had to have been terminated by the axial flux imbalance input.. Additionally, both' Channel II and Channel III ci rcuitry have been fully operational and properly calibrated during the period since February 1983.
4)
To preclude recurrence, the Procedure Upgrade Program is revising surveillance procedures to clarify acceptance criteria to be used during surveillance testing and to provide guidance on what actions to take when acceptance criteria cannot be met.
The procedures are also being reviewed for proper documentation, independent verification and record retention requirements.
Completion of this action is presently covered under the Performance Enhancement Program (PEP) schedules and controls.
b)
Full compliance for item 3 above was achieved on December 4,1984 FINDING 4:
Technical Specification 6.8.1 requires that written procedures and administra-tive policies shall be established, implemented and maintained that meet or exceed the requirements and recommendations of Sections 5.1 and 5.3 of ANSI N18.7-1972 and Appendix "A" of USNRC Regulatory Guide 1.33
R;:
IE I"spection Report 250-84-39 and 251-84-40 Page 4 Section 9 of Appendix "A " of USNRC Regulatory Guide 1.33 recommends that maintenance that can affect the performance of safety-related equipment should be performed in accordance with written procedures, documented instructions or drawings appropriate to the circumstances.
Contrary to the above, on February 23, 1983, adequate maintenance procedures or instructions were not established, in that a Unit 3 power range nuclear instrument drawer was installed without benefit of an approved procedure.
Troubleshooting performed in October 1984, revealed that the drawer was incor-rectly installed.
RESPONSE
1)
FPL concurs with the finding.
2)
The reason for the finding was that independent verification was not performed to ensure that a Unit 3 power range nuclear instrumentation (NIS) drawer was installed properly.
3)
Subsequently, the NIS drawer was installed correctly and the NIS and Hagan System were verified to be operating correctly.
Maintenance Procedure (MP) 12307.3,
" Quarterly and Standard Calibration of the Nuclear Power Range Instrumentation, Axial Flux Deviation Process Instru-mentation to OPSP and 0 TSP, and Nuclear Power Range Axial Flux Deviation Alarm", has been revised to incorporate steps which test the interconnec-tions between the NIS cabinet and the Hagan System.
This procedure is used to verify that maintenance has been performed satisfactorily.
4)
To preclude recurrence, a new procedure is being developed which will serve as a generic Instrumentation and Control trouble-shooting and repair procedure.
The procedure will include items such as independent verification of removed leads and components, procedures for replacement of components, and Supervisory and Quality Control of trouble-shooting and repair.
b)
Full compliance for item 3 above was achieved on December 20, 1984