ML17341B624

Responds to Violations Noted in Insp Repts 50-250/85-06 & 50-251/85-06.Corrective Actions:Surveillance Procedures Being Revised to Ensure That Requirements of Tech Specs Re Fire Protection Water Flowpaths Properly Implemented

ML17341B624
Person / Time
Site:	Turkey Point
Issue date:	06/06/1985
From:	Williams J FLORIDA POWER & LIGHT CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
L-85-222, NUDOCS 8507110128
Download: ML17341B624 (6)

Text

y4 lh qP FLORIDA POWER & LIGHT COMPANY 35 Jgw lQ P l ~ 32 6 1II85 L-85-222 Dr. J. Nelson Grace Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 At 1 anta, Georgi a 30303

Dear Dr. Grace:

Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 5 -251 Ins ection Re ort 250- -06 251-85-06 Florida Power and Light Company has reviewed the subject inspection report and a response is attached.

There is no proprietary information in the report.

Yery truly yours, J.~ W.~ Wil ams, Jr.~

Group V'resident Nuclear Energy Department JWW/JA/ms/

Attachment cc: Harold F. Reis, Esquire 8507ii0128 850606 9 PDR ADOCK 05000250 8 PDRQ PEOPLE... SERVING PEOPLE

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ATTACHMENT Re: Turkey Point Units 3 and 4 Docket No. 50-250, 50-251 IE Ins ection Re ort 85-250-06 and 85-251-06 FINDING 1:

Technical Specification (TS) 4. 1, Table 4. 1-1, requires that each power range nuclear instrument (NI) channel be calibrated quarterly. TS 1.7.3 requires that a channel calibration encompass the entire channel.

Contrary to the above, as of April 1, 1985, quarterly calibrations of the Power Range NI channels did not encompass the entire channel in that the Power Range NI output signal from each instrument's lower detector was not verified to supply an input to the over temperature delta temperature (OTDT) and over power delta temperature (OPDT) protective circuits.

RESPONSE

1) FPL concurs with the finding.

2) Previously, the nuclear instrumentation system (NIS) and OTDT and OPDT circuits as well as the axial flux drawers were checked independently of each other. The procedures used did not take into account the inter-connecting wiring and, therefore, did not test the enti re channel as required by TS.

3) Maintenance Procedure (MP) 12307.3, "quarterly and Standard Calibration of the Nuclear Power Range Instrumentation, Axial Flux Deviation Process Instrumentation to Over Power Set Point (OPSP) and Over Temperature Set Point (OTSP), and Nuclear Power Range Axial Flux Deviation Alarm", wi 11 be revised to require testing of the entire channel. The test wi 11 originate at the NIS cabinet and verify proper voltage and polarity at the OPSP and OTSP inputs as well as the axial flux inputs.

4) To preclude recurrence, the Procedure Upgrade Program is revising

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surveillance procedures to ensure that the requi rements of the Technical Specifications are properly implemented. Completion of this action is presently covered under the Performance Enhancement Program (PEP) schedules and controls.

5) Full compliance for Item 3 above will be achieved by duly 1, 1985.

FINDING 2:

TS 4. 15.2.a.b requires that each testable valve in the fire protection water system be cycled annually. TS 4.15.2.a.3 requi res that each valve in the fire protection water system flow path be verified to be in its correct position monthly. TS 4.18. 1 requires a monthly fire suppression water system walkdown to verify that each accessible valve is in its correct position.

Re: IE Ins ection Re ort 250-85-06 and 251-85-06 Page 2 Contrary to the above, prior to April 1, 1985, four accessible and testable valves in the fire protection (suppression) water system were neither cycled annually nor verified monthly to be in their correct positions.

RESPONSE

1) FPL concurs with the finding.

2) The reason for the finding was that the fire water protection flowpaths for Units 3 and 4 were not clearly defined. The drawing for the fire water protection system included the flowpath around fossil Units 1 and 2 but this flowpath was not considered part of the flowpath for Units 3 and

4. Because of this, these valves were not cycled as part of the annual or monthly fire water protection system survei llances.

3) Post indicator valves (PIVs) 7, 8, 10, 11 and 31 located in the Units 1 and 2 flowpath were visually inspected and cycled. No discrepancies were found with the valves.

4) a) Surveillance procedure, 0-0SP-016.3, "Annual Surveillance of Fire Suppression System Flow Path Valves", will be revised to include visual inspection of PIVs 7, 8, 10, 11 and 31.

Administrative Pr ocedure AP 0103.19, "Monthly Verification of Safety-Related Systems Flowpaths", will be revised to include visual inspection of PIVs 7, 8, 10, 11 and 31 located in the flowpath for Units 1 and 2. These changes will remain in effect until an assess-ment is performed on the results of the engineering evaluation and the appropriateness of the corrective actions.

b) In the interim, a plant work order for the fossil Units 1 and 2 will be written on a monthly basis to visually inspect PIVs 7, 8, 10, ll and 31.

c) An engineering evaluation will be performed to clearly specify what are the bounds of fire water suppression system flowpath for the nuclear Units 3 and 4. An assessment will be performed of the engineering evaluation and corrective actions will be taken as necessary.

5) a) Full compliance for Item 3 above was achieved by April 5, 1985.

b) Full compliance for Item 4.a above will be achieved by July 1, 1985.

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