L-91-329, Responds to NRC Ltr Re Violations Noted in Insp Repts 50-250/91-42 & 50-251/91-42.Corrective Actions:Reactor Power Was Reduced Below 90 Percent & Indicated Axial Flux Was Returned to within Target Band on 911018

Responds to NRC Ltr Re Violations Noted in Insp Repts 50-250/91-42 & 50-251/91-42.Corrective Actions:Reactor Power Was Reduced Below 90 Percent & Indicated Axial Flux Was Returned to within Target Band on 911018

ML17348B299
Person / Time
Site:	Turkey Point
Issue date:	12/18/1991
From:	Goldberg J FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-91-329, NUDOCS 9112270131
Download: ML17348B299 (8)

Text

ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

CESSION NBR:9112270131 DOC-DATE: 91/12/18 NOTARIZED:

NO DOCKET FACIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 50-251 Turkey Point Plant, Uni.'t 4, Florida Power and Light C 05000251 AUTH.NAME AUTHOR AFFILIATION GOLDBERG,J.H.

Florida Power

& Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC ltr re violations noted in Insp Repts 50-250/91-42

& 50-251/91-42.Corrective actions: reactor power was reduced below 90 percent,

& indicated axial flux was returned to within target band on 911018.

DISTRIBUTION CODE:

IE01D COPIES RECEIVED LTR

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ENCL i

SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES RECIPIENT ID CODE/NAME PD2-2 PD INTERNAL: AEOD AEOD/DSP/TPAB NRR HARBUCK,C.

NRR/DLPQ/LHFBPT NRR/DOEA/OEAB NRR/DST/DIR 8E2 NUDOCS-ABSTRACT OGC/HDS3 RGN2 FILE 01 EXTERNAL: EG &G/BRYCE,J. H.

NSIC COPIES LTTR ENCL

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1 RECIPIENT ID CODE/NAME AULUCK,R AEOD/DEIIB DEDRO NRR MORISSEAU~D NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NRR/PMAS/ILRB12 OE DIR REG~ I NRC PDR COPIES LTTR ENCL 1

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1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE IYASTE! CONTACT THE DOCUMENT CONTROL DESV, ROOil Pl-37 (EXT. 20079) TO ELlillNATEYOUR NAiXIEFRO'Al DISTRIBUTION LISTS FOR DOCUih!ENTS YOU DON'T NEED!

TAL NUMBER OF COPIES REQUIRED:

LTTR 22 ENCL 22

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'r{ L P.O. Box14000, Juno Beach, FL 33408-0420 DEC 3 8 )99)

L-91-329 10 CFR 2.201 U. S. Nuclear Regulatory Commission Attn:

Document Control Desk Washington, D.

C.

20555 Gentlemen:

Re:

Turkey Point Units 3 and 4

Docket No. 50-250 and 50-251 Reply to Notice of Violation NRC Ins ection Re ort 91-42 Florida Power and Light Company has reviewed the subject inspection report and pursuant to 10 CFR 2.201, the required response is attached.

e If there are any questions please.contact us.

Very truly yours, r

J Aj.

J.

H. Goldbe President Nuclear Division'HG/CLM/cm Attachment cc:

Stewart D. Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Nuclear Plant

Reply to NOV 91-42 Page 1 of 3 ATTACHMENT REPLY TO A NOTICE OP VIOLATION RE:

Turkey Point Units 3 and 4

Docket Nos.

50-250 and 50-251 NRC Inspection Report 91-42 FINDING "Technical Specification (TS) 3.2.1 requires that the indicated axial flux difference (AFD) be maintained within a +54 target band.(flux difference units) about the target flux difference.

TS 3.2.1 action statement

a. requires that, with the indicated AFD outside of the above required target band and with thermal power greater than or equal to 90% of rated thermal power, within 15 minutes either:

1) restore the indicated AFD to within the target, band limits, or 2) reduce thermal power to less than 90%

of rated thermal power.

Contrary to the above, on October 18, 1991, during the performance of OP 12304.8, Inducing Xenon Oscillations to Produce Various Incore Axial Offsets, the 'indicated AFD was allowed to-deviate outside the

+5% target band for approximately two hours with Unit 3 at 1004 power.

This is a Severity Level IV violation (Supplement 1)."

RESPONSE

TO FINDING 2

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FPL concurs with the finding.

This event was caused by a procedure that was not adequately reviewed to reflect the revised TS, and by an error that was discovered in the plant TS.

TS 3.2.1 has a footnote that incorrectly references TS 3.2.1, Action statement b(2); the footnote states that, "A

total of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> operation may be accumulated with the AFD outside of the above required target band during testing without penalty deviation."

This same footnote is referenced to the correct applicability statement in the January 9,

1991, draft edition of NUREG-1431, Westinghouse Owner's Group Methodically Engineered, Restructured, and Improved TS (MERITS).

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Reply to NOV 91-42 Page 2 of 3 The Turkey Point TS were revised to reflect the standard TS format August 28, 1990.

The previous TS and the governing

,procedure for the calibration, OP-12304.8, allowed operation outside of the axial flux target values while inducing xenon oscillations to perform the incore/excore calibration.

Operation outside the target band had been a standard practice at Turkey Point, to acquire accurate data for calibration of the high flux trip setpoint.

This practice led the reviewers to believe that the procedure accurately reflected the revised TS as well.

As a result of that belief, despite considerable discussion of that particular TS by the personnel tasked with implementation of the revised TS, the disparity between the TS and the procedure was not identified.

3.

Corrective steps which have been taken and the results achieved:

a ~

Reactor power was reduced below 90 percent and the indicated axial flux value was returned to within the target band on October 18, 1991, at 0150 EDT (Reference LER 250-91-'009-00).

b.

A temporary waiver of compliance was issued on October 31, 1991, allowing Turkey Point a total of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> operation at less than 90% power outside the target

band, during testing, without penalty.

c ~

A TS amendment request was submitted on October 31,

1991, (FPSL Letter No. L-91-301) to correct the TS error.

d.

Procedure OP 12304.8 was revised,to require performance of the procedure at a power level less than or equal to 90~.

OP 12304.8 has since been replaced by 0-OP-059.3, which contains the same restriction.

e.

The procedures implementing TS 3.2.1 were subsequently reviewed by an independent consultant to ensure they accurately 'reflect the requirements in the Technical Specifications.

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Corrective actions which will be taken 'to avoid further violations include:

No additional corrective actions are deemed necessary to preclude recurrence of this event.

5.

The date full compliance will be achieved:

Reply to NOV 91-42 Page 3 of 3 Full compliance was achieved on October 18,

1991, when reactor power was reduced below 90 percent and the indicated axial flux value was returned to within the.,target band.

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