ML17341B455

Forwards Completed Audit of Procedures & Training Re Pressurized Thermal Shock.Results Indicate Operations Personnel Capable of Dealing W/Pressurized Thermal Shock

ML17341B455
Person / Time
Site:	Turkey Point
Issue date:	09/28/1982
From:	John Kramer Office of Nuclear Reactor Regulation
To:	Lainas G Office of Nuclear Reactor Regulation
Shared Package
ML17341B453	List: ML17341B452 ML17341B455
References
REF-GTECI-A-49, REF-GTECI-RV, TASK-A-49, TASK-OR NUDOCS 8211030533
Download: ML17341B455 (43)

Text

Docket No.

50-251 t

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O. C. 20555 September 28, 1982 MEMORANDUM FOR:

Gus C. Lainas, Assistant Director for Operating Reactors Division of Licensing FROM:

SUBJECT:

Joel J.

Kramer, Deputy Director Division of Human Factors Safety PRESSURIZED THERMAL SHOCK AUDIT REPORT TURKEY POINT PLANT, UNIT 4 We have completed our audit of the Turkey Point Plant, Unit 4 procedures and training on pressurized thermal shock (PTS) and the audit report is enclosed.

The audit report should be forwarded to the licensee for information.

Based on the results of the audit, we feel the Turkey Point operations personnel are capable of dealing with PTS.

The audit was conducted by personnel from Battelle Corporation.

Enclosure:

Audit Report cc w/enclosure:

S.

Hanauer R.

Woods F'. Litton S.

a M. Groten u

R.

o e

1 J. Agles el J.

amer, Deputy Director Division of Human Factors Safety 821 i030533 82iOf3 PDR ADOCK 0500020t PDR I

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Audit af Turkey Paint Procedures and Training for Pressuri-ed Thermal Shack CONTENTS Paoe INTRODUCTION

1. 1 Short-Term Objectives and Scope af Review......

1 1.2 Current Status of the Generic PTS Issue....

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Turkey Point Conf iguration...........

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2 SHORT-TERN CRITERIA USED FOR-TURKEY POINT AUDIT..

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2. 1 Transient and Accident Analyses............

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1 Intraductian.................

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2. 1. 2 Turkey Paint Cooling Events Summary

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2. 1. 2. 1 Event 1:

December 2, 1971......

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2. 1. 2. 2 Event 2:

November 28, 1981.....

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2. 1. i Termxnatxon Criteria..

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Reactor Coolant Pumps,CPs)

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Feedwater

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Charging Pumos

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2. 1.c.4 SI Terminat ion During Loss of Reactor Cool ant

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2. 1. ~. 6 SI Termination During Steam Gener ator Tube Ruptur e

2. 1.4 NCAP-10019 Vessel Integrity Analyses 11 I

2.2 Criteria for Procedural Reviews... ~....

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2. i In-Plant. Training Program.............

13 KEY FINDINGS FRON THE TURKEY POINT AUDIT.........

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Comparison of Training With Audit Criteria 18

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Summary on Training

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Procedures Audit

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Comparison af Procedures Nith the Audit Crz teri a a

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Findings an Procedures

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Summary e

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RECQMMENDATIONS

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1. 1 Short-Term Objectives and Scope of Revi ew Qn July 1~,

1982, an interdisciplinary audit team visited Turkey Point Nuclear Station to evaluate certain aspects of the Pressuri=ed Thermal Shocl.'PTS) issue.

'The question that the audit team focused dn was:

ARE CORRECTIVE ACTIONS REQUIRED THAT MUST BE INITIATED BEFORE THE LQNGER TERM PTS PROGRAM PROVIDES GENERIC RESOLUTIQN AND ACCEPTANCE CRITERIA'merqency procedures and operator training were the only areas in

'hich the Turkey Poi.nt audit team app) ied the above general ques" ion ~

'As noted in the NRR March 9, 19S2 presentation to the Commission:

"... we wil1 undertake a

program to verify that e>;isting operating procedures contain the steps necessary to prevent and/or mitigate PTS

events, and to.verify that operator education/training programs

. regarding PTS are acceptably thorough."

Due to the limitation of the review to training and procedures, the resolution of various technical questions on PTS (thermal-hydraulic

=nalyses.

fracture mechanics.

probabilities) was not part of the audit,

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team chartel

Alsa, implementati on of any cammendatians (see Sect.ian 4> is sub.ject ta coardinatian and consistency with the longer term generic program (USI A

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and NRC staff cancurrence.

A visit ta Turkey Point taok place an Duly 1~-15, 1982 during which time

~ he audi t team eval uated pl ocedul es and training

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The key

~Findinas of the graup are discussed in Section

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ln preparation for the Turkey Point audit the audit team used the general criteria addressed in Sectian 2.

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Current Status of the Generic PTS Issue Efforts to pursue an integrated PTS program involving a

variety of technical areas are continuing under USI A-49.

The summer af 198's the current schedule for finalizing the generic regulatory requirements for PTS along with required corrective actions if the

- generic requirements are not met.

Key issues are yet to be resolved and e>:tensive pragrams e>:ist ta provide the foundation far the generic regulatory requirements.

BeFare he above effort resulting

~ in regulatory requirements is completed

however, the staff has committed to the Cammi ssi on to have developed an interim initial position for the summer af 1982.

The interim initial position will consist of NRC evaluation of the safety af 'contiriued alant operation (and initial corrective actions required) far the eight plants previously identified as representative of. plants

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having the highest RTNDT ~

Technical assistance is being provided by 2

P3'3L multi-dirci p ary team.

PNL has been ntracted to work with the staff to prov'de recommendations regarding the initial position on the safety of continued operation and to recommend any additional corrective actions that PNL believes should be initiated before the NRC generic resolution and acceptance criteria are adopted.

Turkey Point Configuration Turkey Point, Units 2 and 4 are twin three-loop Nestinghouse PNRs each'ated at 2200 NNt (666 NNe).

Normal pressurizer level is controlled by the chemical and positive displacement utili"es medium head volume control system which contains three pumps.

The saf ety i nject ion system (SI) pumps which will initially discharge the boron injection tank (BIT) into the cold legs of the reactor coolant system.'here are four pumps which are used for the two plants.

interconnection between plants is possible.

The SI pumps have a shut-off head of 1400 psig and have a

ratinq of 450.

gpm at S6? psig.

The SL system also contains three accumulators which discharge at 650 psig and two low head pumps (RHR) rated at

<<000 gpm at 165 psl g I Fegdwater generator is delivered from the condenser hotwell to the steam by

<< condensate pumps (two operate during normal oper'ation and the third is an installed spare) and two motor driven main "eedwatel pumps.

0 closed secondary cycle of two trains of feedwater

heater 0 is uti li "ed nd incorporates two he~

~r drain pumps which di scharge to the suction side of the main feed pumps.

The au>;ili ary feedwater system consists o~ three turbine-driven pumps For the two reactors.

Each pump can supply 100/ ai6:iliary flow for one reactor and the third oump is a spare.

Steam generator pressure control is performed by the steam dump system which includes 4

valves with a

total full load steam flow caoacity of 40/one atmospheric dump on each steam generator with a total flow of 10/

'and the main steam code safety relief valves.

The Turkey Point hluclear Station control room board contains the controls and displays necessary for the operation of.Units

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'P The following table contains the major parameters. available to an operator at Turkey Point that would assi st in monitoring PTS events.

Parameters Displ ay RCS Pressure Nide and low range. meters and narrow range recorder RCS Temperature T-hot wide. range recorder T-cold wide range recorder.

These'emperatures could also be displayed on a

CRT

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In-Care Temperature Read an a

CRT Subcaol ing Manitor Digital readout showing

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'I Reactor Water Level subcoa'ing margin in either temperature or pressure uses in-care temperature signals Inadequate core caaling system will be added during the steam generator.

outage in 1982 gC f>c VV

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TI' SHORT-TERM CRITER1A USED FOR TURKEY POINT AUDIT

2. i Transient and Accident Analyses

2. i ~ i Intraducti an Overcool ing events in PIJRs may occur as a result af steam line breaks (e>;cess'i ve steam f 1 aw),

feedwater system mal funct ians, or fV

,Vg lass-of-caalant accidents ar any situation which leads to the injectian of cold water inta the reactar.

l'lultipl e failures and/or operator errors can resul t in more severe over cooling events.

Of particular concern are those events in which repressurizatian of the

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primary system occurs following the severe avercooling.

This section

s! tmmari "es aur revi ew 0'h e Turkey Point event, at occurred since the pl ant was built.

A summarv af the hermal-hydraulic analyses

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/m Lvai 1 ab1'e fnr evaluating pressuri z ed thermal shock events is pravi ded in Sectian

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2. 1.2 Turkey Paint Cooling Events Summary exceeding, the cooldown rate limit if.nat mitigated by automatic plant

'cantrols and protective functinns and operator.

action and

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aver-pressuri".ation occurred when the reactor coolant system was in a

caid candition.

I 2 ~ 1. 2. 1 Event 1:

December 2.

1971 Prior to plant startup three cade safety -elief valves were blown free fram the unit three "A" loop main steam line.

The "A"

loop steam generator had na feed water flaw at the time of the event:

The RCS cabled from 54?

F ta 49O F.

Further caaldawn was prevented by aperatar

. action.

The cooldawn rate was nat exceeded and pressure temperature relationship pressuri".er and loops "8" was within limits.

The levels in the and "C" steam genel atol s were rerovered and a normal caoldown was initiated appraximately one hour after the event detailed review of the operating history af Turkey Paint has identified no events that resulted in exceeding the cooldawn rate limit af 1OO F/hr.

One event was identified that could have led to started.

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November 28.

1981 Prior to heatup with the reactor coolant system (RCS) in a water solid condition and the RCS temperature and pressure 110 F

and ilO psig respectively.

two aver pressure conditions develaped far whirh the averpressure mit'ating system (Gl'1S) failed to operate.

The cause

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.prrblem was faund to be a failed summator on the OPS circuitry coupled with a pressure transmitter which was unintentionally left isolated.

The

-peak pressure and duration were 1100 psig for twa minutes during.the first occurrence and 7 0 psig for one minute on the secar{d.

2.1.3 Termination Criteria

2. 1. ~. 1 Reactor Coolant Pumps (RCPs) h on a

reactor trip or safety I

procedures (EQPs)

The emergency operating The RCPs do not.trip automatically injection (SI) actuation.

incl ude injection instructions to manua)ly stop al)

RCPs ance high head safety (SE) p{(mp aperatian has been verified and reactar coolant sYstem (RCS) pressure is at. or below 1400 psig.

This criteria does not apply far controlled depressurizatian steps in the EOPs.

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Fet=td watel The main Feedwater pumps trip automatically on SI act'uation.

Thi s causes auN i 1 lary feedwater (AFVl) pumps to start

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Charging Pumps The charging pumps trip on S I actuation.

The steam generator tube rupture (SBTR)

EOP instructs the 'perator to restart all charging pumps just prior to depressuri".ation steps (to maintain pressurizer 1'evel

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Charging pumps are not restarted in loss of reactor coolant or loss of secondar y coolant procedures.

2. l. <<.4 SI Termination During Loss of Reactor Coolant 4

SI must, remain in operation until all of the following conditions are met

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RCS pressure

> 1400 psig. and in'creasing Pressuri=.er (P=-r) level

> 50/

RCS subcooling

<<0 F AFN f 1 ow

> 570 GPM ol At least one SG'evel in the narrow range

A cauter on is included which states."

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RCS nressure may be in excess of the plant pressure temperature (PT>

curve limits.

Refer to the PT cur ves and verifY that. the current plant condi tions are below and to the right of the 100 degree per hour cooldown curve.

IF THE PT CURVES ARE BEING VIOLATED, CAREFULLY REDUCE RCS PRESSURE TO' VALUE THAT

@ILL NOT VIOLATE THE PT CURVES..

BUT DO NOT ALLOW SUBCOQLING TO DROP.

BELOW ~0 F.

'2. 1. '.5 "SI Termination Durino Loss of Secondary Coolan+

In this procedure.

RCS cold leg temperature determines the termi'nation criteria.

If 1 cold is less than

~50 F, all of the following criteria must be met for SI termination:

RCS pressure

> 700 psig and stabl,e or, increasing P"r level

> 20/ and rising RCS subcooling

> 60 F

AFN flow isolated to Faulted SG<s)

t AFN f 1 ow

> 57 Pl'1 or SG level in.the narrow range in at least one non-f aul ted SG.

If T cold is greater than 350 F, all of the following criteria must be satisfied before SI is stopped:

RCS pressure

> 1400 psig and stable or increasing P"=r level

> 50/

RCS subcooling

> 60 F

AFN flow isolated to faulted SG(s)

AFN flow > 570 GPtl or SG level in the narrow ranoe in at least one non-faulted SG.

A caution is included which states:

CAUTION:

RCS pressure may be in e"cess of the plant pressur e temperature (PT) curve limits.

Refer to the PT curves and verify that the current plant conditions are below and to the right of the 100 degree per hour cooldown curve.

IF THE PT.

CURVFS ARE BEIblG VIOLATED, CAREFUI LY REDUCE PCS PRESSURE TQ A

VALUE THAT NILL NOT VIQLATE THE PT CURVES.,

BUT DO NOT ALLON SUBCOOLING TO DROP BELOW 60 F.

2. 1.. <<.6 SI Termination Dcirina Steam Gener ator Tube Rctp Outre The following termination criteria apply after the RCS has been depressur ized to match the steam pressure in the faulted SG.

All of these conditions must be met:

PCS pressure has increased by at least, 200 psi (after shutting the spray valves or verified closure of Pzr PORVs)

Pzr level indication has returned RCS subcooling

> 40 F

2. 1.4 WCAP-10019 Vessel Inteor ity Analyses The analyses provided in NCAP-10019 are typical of FSAR-type design bases events.

However, the boundary conditions have been selected to enhance the overcooling.

Na>:imum safety injection and feedwter flows are

assumed, minimum water temperatures are used, and heat sources are either omitted or are conservatively underestimated.

Large and small t QCAs have been addressed>>

a well as large and small steam line break"-.

ln addition, the Rancho Seco overcool ing e rent was included.

Nest Inghouse ind i=ates that "he dynami cs of thi s event.

woul d be imilar to a

low probability small steam line break (including additional Failures).

Operator action is identified for two events 11

'rg ented 1 n NCAP-i(3t)

For the isol at ah 1 e LQ

< a stuck open PGRV) s assumeo that the opel ator isol ated the break in 30 minutes.

For the large steam line break, it is assumed that au>:iliary feedwater to the faulted steam generator and makeuo injection flow to the RCS is terminated within LO minutes.

2.2 Criteria for Procedural Reviews The procedures to be reviewed were selected based on the perceived likelihood of conditions occurring that miqht. subject the reactor vessel to pressure i ed thermal shock conditions and based on the potential consequences of less likely transients.

Such procedures selected included normal startup and shutdown, steam generator tube r upture, steam supply system rupture and loss of coolant accidents.

The audi'- cri teria for the content of procedures was somewhat fle>;ible td account for operator knowledge and to identify which procedures mush be used to respond to a given transient.

In addition, detailed oper ator knowledge of action~ for preventing or mitigating PTS could offset; 'ome weaknesses in procedures.

Nith this in

mind, the following criteria were established for the procedures audit:

Procedures hould not instruct operators to take actions that would violate NDT limits.

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Procedui should provide guida on recovering from transient or acc-dent conditions without violating NDT ol satul ation limits~

Pa ocedul es should PTS conditions.

provide guidanc on recovering from PTS procedural guidance should have a

supporting technx cal basi s.

High pressure in.jection and charging system operating instructions should reflect a consideration for PTS

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Feedwat r and/or au>:iliary feedwater operating instructions should reflect PTS concerns.

(7)

An idol cut ve and satur ati on cur ve should be provi ded in the control room.

(Appendi>;

G limits for cooldowns not e>;ceeding '10V F/hr).

2. 2 In-P) ant Training Program The audit team used training criteria developed by the staff as a

standard for all plant PTS audits.

The criteria covers three general eas

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Training should include specif ic instruction on NDT vessel 1 imits for f IDRI'IAL modes of operati on.

T, a'inq should inc'de spec fic instruction on NDT vessel limit-for transients and accidents.

Training sh'oui d particularly emphasi "e

those events known to require operator response to mitigate PTS.

Training in I~lDT limits should include the knowledge that irradiation adversely 'ffects fracture toughness properties of the reactor vessel Operators should know that the vessel and welds will lose ductile material properties and trend toward embrittlement.

Operators should be, aware that NRC has. sent letters to FPL on the PTS issue and that FPL had responded that additional training was underway.

Operators should understand that a

rapid reduction in reactor vessel temperaturelpressure can raise the Nore specific criteria were also developed to aid in the review of -the-training program and in preparation for interviews with operating personnel.

These included:

'ay

possibi 1

oF crack propagatio par ticul arly if pressure rises

. after the temperature reaches its lowest value

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Qp ra oF s snoul d be aware of the types of events wh'h are known to involve PTS

<such as l SL breaks and secondary side mal functi ons).

Operators should appreciate that other safety limits (such as core cooling and shutdown margin) must also be balanced with the PTS limits.

Training should emphasize the instrumentation available tn observe key parameters as they approach limits.

Strategies/options which are under operator control should be emphasized.

(7)

Qperators should understand the basis for current emphasis on

PTS, specifically that

'more severe transients have occurred 'han expected (Rancho

Seco, Cr yst:al Ri ver )

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FPl.was asked to furnish an outline of their training program on PTS and the lesson plan which was used in the training classes.

They were also questioned on the method used to evaluate the effectiveness of

~ "e training s sions.

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KEY FINDINGS QF THE TURKEY PO" NT AUDlT The following is a description of how the audit was conducted and the key fir:dings resulting from the audit.

Description of 'Audit Prior io the plant visi t to Turkey Point, PNL reviewed the procedures li ted in

~. ~. 1, the Tur key Point training outline which included a

aescripti on of past events and the Turkey Poi nt 150 day response dated 193=.

.During the plant visit, PNL reviewed the training schedule and interviewed key members of the training staff.

Procedures which dealt with PTS were reviewed against the audit criteria.

Past Turkey Point potential evenis,and potential overcooling transient scenarios used. in the FPL simulations (as repor ted in NCAP-10019) were reviewed along with thc procedures and these served as a basis plant operating personnel to determine the "raining program and operator knowledge on PTS.

for interviews ei th effectiveness of the Si, operations people were interviewed.

Each interview was preceded by a discussion of the reason for the audi t and acknowl edgment tha+ the indi vidual coul d use al I mater ial available in the control room. particularly the follow-up or recovery steps in the emergency procedures.

Several interview aids were used to provide the operators a point of reference "or discussion and to la

a ow chem to predict

=ponses or execute re ery N

mitigate PTS or challenges to other limits.

strategies to Trainina

~.2 ~ 1 Intraduction The pudit of Turkey Point's training program consisted of a review of the PTS training outline which included a

lecture on the minimum pressure temperature (NPT) curve, a description of the requalif ication program and a 'etai led t'raining schedule and syl lab'us.

'tAe

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interviewed two key members of the training s aff and the following licensed operations personnel:

2 STAs (only 1 licensed>

1 Nuclear Natch Engineer (SRO) 1, Nuclear Pl ant Super visor (SRG) 2 nuclear control operators (RO) 17

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~ Comnari son of inina ~with Audit Criteri Trainino houl d include specific instruction on NDT vessel limits for NORMAL mode of operation.

The

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Periodic Training Requalification includes a

discussion of the PTS issue and NDT vessel limits as they apply to both normal and off-normal operations.

All interviewees

-hewed good knowledge in this area.

Tr2inino shoul d include speci fi c instructi ons on NDT vessel 1 imits for ma in'ransi ents and acci dents.

The requal i F ication training deals with NDT vessel limits and their use during transients.

The lectures included discussion on material properties and the changes that are caused by fast neutron irradiation.

These topics are covered in shift training when there are changes to procedures which have PTS implications.

Al 1 int rviewees were questioned in this area and demonstrated a good understanding.

Training should par icularlv emohasi "e

those events known to require operator response to mitiqati PTS.

'Training in the classroom.

on shift and on the generic simulator does cover these topics.

The emphasis is on preventing PTS and includes using the PORVs to prevent over pressuri".ation, termination criteria for Sl, use of 18 oA W>>>> M

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P-T di,ams and how to est ish and maintain subcooling margins and not exceed cooldown rates.

Sugimarxi on Trai ni ng The training program appeal s to have covel ed PTS subject and NPT curve adequately.

The operators are taught that if they find the plant in a potential PTS condition "hey are to stabili"e at, tha point and slowly work the plant to a

more desirable condition of pressure and temperature.

The training program involves continuous requalification training which is designed to ensure that operators are constantly.

aware of PTS rather than being retrained only once a year.

Both the r eview of the training program and interviews with the

'supervisors, STAs

'understanding of an) control operators indicated that they had a good PTS.

They demonstrated a knowledge of transients that could result in PTS and a generally good understanding of how to avoi d PTS.

P;ocedures

~. ~. 1 Pr ocedures Audi" Cur audit included a

review of selected procedures as discussed in S=~ction 2.2. 'iscussions with a

licensee representative on the

instructions relating to PTS and the basis for these instructions, and an audit of the control room copy of the procedures to determine its legibility and currency.

Our audit included the following Qperat,ing Procedures and Emergency Procedures.

A2A2. 2 Unit Start-up Hot Shutdown Power Operation 020~~, 2 Reactor Shutdown Hot Shutdown to Cold Shutdown Condition 20001 (E-1)

Loss of Reactor Coolant.

20A0" (E-2)

Loss of Secondary Coolant 2000~

(E-~)

Steam Generator Tube Rupture

< ~ ~. ", Comparison of Proc dures With the Audit Criteria Procedures should not instruct operators to take actions that. would violate MDT limits.

The procedures that. were audited. generally did not appear to contain instructions that would cause an operator to viol.ate MDT limits..

(2)

Procedures should provide getidance on recoverina from transient or accident conditions without viola"ina

NDT,

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or saturate an limit.

The procedures direct the operator s to stay within the acceptable regian an the INAPT graph.

This may involve SI termination or operating the PORVs.

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Procedures should provide guidance on recovering from PTS conditions.

The procedures provide instructions far.

maintaining the RCS within canditions allowed by the NDT curve and also cover cases where a

PTS event has occurred bef ore "he operators are able to begin to contral plant conditions.

The procedures da nat give guidance to the operator given that the cooldown rate has been" e>;ceeded,

however, these recovery procedures Icnaw) edgeab) e af the appropriate action.

are al so adequately covered in the training course.

and the licensed operators were\\

(4)

PTS grocedural guidance should have supgor ting technical ba i'he pracedural guidance on PTS is based

. an analyses and studies conducted by Westinghouse and reported in the 150.day response (NCAP-10019).

High pressure in iegtion and charging system operating instructions should reflect a

consi deration for PTS.

'The subcaaling criteria far Sl termination reflect PTS

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concerns by use of notes and cautions.

Feedwater (FM) and/or au" iliarv feedwater (AFN) aperating instructions should reflect PTS cancer ns.

Instructions are provided in the steam generator tube rupture and the loss-of-coolant, procedures to terminate FN/AFN flow to the faul ted steam generator.

These procedures also provide instructions to maintain steam generator levels in the nonf aul ted steam generators within a def ined band.

(7)

An NDT curve and a saturation curve should be provided in the control room.

These curves are provided in the control room.

Finding= on Procedures in general the procedures give the operator guidance on preventing a

PTS event.

The guidance deals with such items as terminating SI and use of the PORVs.

2 ~ 4 SUQiniar Si>>, individuals were interviewed.

'They ranged in e>:perience from a.

shift supervisor to a

control operator.

They all e>:hibxted an

under=-"anding of the basic PTS issue and why PTS was

. a concer n to pl ant.

~aJe presented a

number of detai 1 ed scenar ios whi ch P

involved the notenti ml for aver-coaling or over-cooling with epl essur iz at ion and al 1 intervi ewees knew what to do.

The peop 1 e we interviewed in the control room were able to describe the right actions and demonstrate that they knew the Iocation and functions of the displays and controls involved in their actions.

The training program covers PTS subjects in the classroom, during shift training and in the simulator.

The procedures are oenerally adequate in thei-coverage of PTS and include instructions on how to recover from a situation where the plant is operating outside the acceptable zones on the P-T diagrams.

4 REC~JNI1EI'HDAT IONG Based on the findings presented in Section 3, the Turkey Point audit team nas no recommendati ons.

REFERENCES (1) 'CAP-10019 "Summary Report on Reactor Vessel Integrity for westinghouse Operating Plants".

4

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tlUREB-0737, "Clarification to the Action Plan",

1980.

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l icensee

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Day Resnonee to NRC on PTB, Florida Power and Liaht.

Company, Turkey Point Nuc 1 ear Stat. ion,

December, 1981.

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