ML112220608

Response to Enforcement Action from FPL Energy Point Beach, LLC, IR-01-017

ML112220608
Person / Time
Site:	Point Beach
Issue date:	04/29/2002
From:	NRC/RGN-III/DRMA
To:
References
EA-03-057 IR-01-017
Download: ML112220608 (11)

Text

e 11-02:-03/

Point Beach Potential Common Mode Failure of Auxiliary Feedwater Regulatory Conference April 29, 2002 NRC Inspection Report 50-266/01-17; 50-301/01-17

Agenda Regulatory Conference

• Opening Remarks

.. J. Grobe, Director, DRS

• Description of Issues

.. R. Langstaff, Inspector, DRS

• Licensee Presentation

• Closing Remarks

.. J. Dyer, Regional Administrator

Potential Common Mode Failure Auxiliary Feedwater Pumps

• AFW recirculation valves require IA to open

• Loss of IA causes AFW recirculation valves to fail shut by design

• Operator actions to control AFW flow (in conjunction with recirculation valves failed shut) could result in low/no flow conditions for AFW pumps

• Pump damage would result within a short period of time due to low/no flow conditions

Operator Actions EOP Guidance

• EOPs directed operators to control AFW flow in response to

... Res Overcooling

... SG Overfill

• EOPs did not specify method to control AFW

• flow (i.e., throttling/closing valves versus securing pumps)

• Operators would typically throttle/close valves versus secure pumps

Operator Actions Overcooling of Res

• Operator actions to control AFW flow may be required within a few minutes of the transient

• At the time operators control flow, recirculation valves may still be open due to remaining IA header pressure

• Recirculation valves may subsequently shut due to decreasing IA header pressure

Operator Actions Overfilling SG's

• Operator actions to control AFW flow to mitigate SG overfill typically required> 1 0 minutes into transient

• Recirculation valves expected to already have failed shut due to loss of IA

• Operators may fail to recognize recirculation valves had failed shut and associated consequences

Inadequate Procedure Guidance Regulatory Issue

• EOPs for Reactor Trip Response were not appropriate for the circumstances

• Procedures did not provide adequate guidance to operators regarding the potential to damage AFW pumps while controlling AFW flow upon low IA header pressure

• Apparent Violation of 1 0 CFR 50, Appendix B, Criterion V

Inadequate Corrective Action Regulatory Issue

• Licensee had seven prior opportunities to focus on the impact of recirculation valve closure

• Apparent Violation of 1 0 CFR 50, Appendix B, Criterion XVI

Risk Significance Preliminary Red (High Safety Significance)

• Relatively high frequency of applicable initiating events involving loss of IA

~ Loss of IA

~ Loss of Off-Site Power

~ Loss of Service Water

~ Seismic Event

• Substantially reduced mitigation capability

~ Main Feedwater Reliance on IA

~ Pressurizer PORV Reliance on IA

Abbreviations

.. AFW - Auxiliary Feedwater

.. CFR - Code of Federal Regulations

.. EOP - Emergency Operating Procedure

.. GL - Generic Letter

.. IA - Instrument Air

.. PORV - Power Operated Relief Valve

.. RCS - Reactor Coolant System

.. SG - Steam Generator

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Point Beach Potential Common Mode Failure of Auxiliary Feedwater Regulatory Conference April 29. 2002 NRC Inspection Report 50-266/01-17; 50-301/01-17 Room 03B4 - Video Conference Location at One White Flint North Organization Deirdre Spaulding NRC/NRRlDLPM/PDIII Tim Frye NRC/NRR Mindy Landau NRC/EDO Daniel Horner McGraw - Hill Michelle Johnson ABS Consulting for NRC/RES Eliezer B. Goldfeiz NRC/RES Peter Wilson NRC/NRRlDSSA S. Sing Bajwa NRC/NRRIDLPM/PDIII Dave Nelson NRC/OE