ML19325D996
| ML19325D996 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/14/1989 |
| From: | Saporito T NUCLEAR ENERGY ACCOUNTABILITY PROJECT |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#489-9339 OLA-4, NUDOCS 8910310125 | |
| Download: ML19325D996 (15) | |
Text
_ .-
. j3d i
1 NUCLEAR ENERGY ACCOUNTABILITY. .u.U PROJECT l 1202 Sloux Street . Jupiter, Florida 33458 . (407) 743-077d" j/. 1 Environmental Protection Involvement . Utigation . Information
'R0 r0T ?"4 p? :?d BlUT
\
UNITED STATES OF AMERICA E m., (4.0CI,1% l NUCLEAR REGULATORY COMMISSION p;a;u .
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD !
In the Matter of ) 8Em'EDOCT 2 3 1989
) Dockets Nos. 50-250 OLA-4 FLORIDA POWER & LIGHT COMPANY ) 50-251 OLA-4
)
(Turkey Point Plant, ) (Pressure / Temperature Limits)
Units 3 and 4) )
)
RELEVANT INFORMATION FOR CONSIDERATION The Nuclear Energy Accountability Project (NEAP) was formed for the specific and primary purposes to operate.for the advancement of the environment and for other educational purposes, particularly for i
research. relative to the environment and the impacts of technology e on the environment.
(
We have grave concerns germane to operations of the Turkey ,
Point Nuclear plant and that an accident at the Turkey Point Nuclear [
plant could have severe adverse impacts on the environment and the public as a whole. Therefore, in light of recent significant events >
L at the Turkey Point Nuclear plant and because these significant l events are relevant to the subject of these proceedings (pressure / temperature limits), we are providing information to this ALSBP as represented in the attached Exhibits #1 and #2 and #3.
1 1 Exhibit #1 is herein described for the record as a NRC morning report notification dated September 15, 1989 which is a 2 page l document describing an EVENT NO. 16594 at the Turkey Point Nuclear l , plant.
Exhibit #2 is herein described for the record as a NRC letter dated September 21, 1989 with a subject of DAILY HIGHLIGHT - Turkey i Point Unit 4 and signed by Gordon E. Edison, Sr. Project Manager. ,
l This document consists of 2 pages and an additional 2 pages of a supplemented sequence of events print out.
l 8910310125 091014 'O
, PDR ADOCK 0500 l
)s o1
., i l
l l
Exibit #3 is herein described for the record as a Florida Power '
and Light letter L-89-325 dated September 1, 1989 and titled Reply to Notice of Violation Inspection Report 89-27. This exhibit consists of 6 pages.
As' evidenced in Exhibit #1, Westinghouse plans to submit a ,
final report to the Licensee concerning any effects the rapid I cooldown may have had on Unit 4. We request that this ALSBP require the Licensee to supply this Westinghouse report to all parties in this proceeding as it is most relevant to these proceedings.
Exhibit #2 further evidences the circumstances of"the event <
documented in Exhibit #1 and the fact that the Licensee appears to have lost the administrative and physical control of the Turkey Point Nuclear plants.
Exhibit #3 at page 2 and 3 evidences that the Licensee operated-the Turkey Point Nuclear plant in a manner which resulted its the Unit '3 and 4 Power Operated Relief Valves (PORV) being unable to maintain Reactor Coolant System (RCS) pressure below the 10 C.F.R. 50, Appendix G limits had the most limiting design baeis transient occurred. This condition existed on several occasions from May 1984 to June 1988, as exhibited by a review of PORV stroke timing records.
C1early, the Licensee has a well documented history of unsafely r
operating the Turkey Point Nuclear plants outside of NRC requirements and regulations and therefore, the Licensee can not provide reasonable assurances that the Turkey Point Nuclear plants will be operated in compliance with NRC requirements and regulations L as required by the issuance of the license amendments which are the '
subject of these proceedings.
, In the interest for public safety and the protection of the l environment, we request that this ALSBP move forward in granting a j public hearing on these proceedings and deny the Licensee's Summary Disposition Motion.
cc: Steward Ebneter, NRC RII Sincerely, Center / Nuclear Responsibility Florida Power / Light Counsel __2 ._J.
Thomas J. Sapor to, Jr.
Executive Director, NEAP 1
1
__ _. _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _.._ _ _. . . _ _ _ . . _ _ _ . . _ _ _ _ _ _ _ . _ __ .__ m . _ _
n, -!
y;y. p -
i .' , l-
[
. l 4
o, h ,
&g :'. $
1, '. , p.v.W k
D,5
. I , .
i '
gi - . ; -
. 7 W ,
oe L W e 1 l
> . e i
.4 W.
I I I 5 l i
, l -
, w
- W W >
! b- 0 !
- = zw O => w -
gwt !> w w eJL3 3'e m o> SJ W '
>3V>g 45 O. O i W W '
. mm33 OM eJ>J EWEED A
. metw> s>@ su We>3 e e s' eunux GP W W m
L
>$sa644 wm4- Wewwte WM *b J
4 *EGE zuer-W A
m e WMD- WE WOW w >> N g >. WIWpmem>wezWpue W3e us
.w w w gueSWWW mWpW WOECJ W e M E m m e d > > e s s ut w w w d 3 *
'u 9 > e M Om k m W S h S J t4 4 W O J l- t .p w * @ w k. 5 4 N W M&Ekb4 QW t p) a b O 2 5 4 'M W 4" E W WD bSJW5 W L,> m 3 m us w WNebsmuG3JM E
- l
,p .% 4 uw& E6mesw ew Wpw SM Oma >
( .a wt m. 3 D 's ougloe www n w iu
== w 8: = ,
e c ==
wg wen =
G W e wup BWWW se 3 36WE s ,> MSp e N % .BEWWMSRMS W * .
4eewww W @! W W w '
W '3 4 wk. ess E W
( d' W N b iW > J e > mtwed >W EE a L
3 w S>g w>s95W = WMM eJM WW D l 0 m & S us > > wmwaE5 mW JeddE W E j I;c w www a > WeSWE4 - Edew mg
,-lzn >
o Wee es*
w WWW2JEEwB 95=Wm MusW@mwe W EWW3JB J w
.ga 4 f !, F.
g u .www au wWmu a >Mt>>wwJEW MBE m
EMS WWRJ w
v swswezad$ik 3 433>G4& ! *>En3m Jed
= zw- >W> M 3 .
su m. ed GS mW M N
>E4 M J54 e 3 @ w3 D > > ha * *> Q S> E* s *OWOww3pm w@M >
- Q G,4 O D E > me s m e * *W F. U OBW WW UMWkJcored W EMMSWJ M4&D49WW@>g &
m 9 O W M 8W W W QsepE aa WW4MWWESWOW3mg@EO> 2 W 4 W e'U E m > owd gm ew s w O WW WW WWemwspee>C W $ Jew 3Sdmew m W eiu s e v w W D wm 45WS .W > ONW 3 m- WWTT.EEmbWewOME w>c W e W *Wme WC9McW2WeezO a e J-
- O -
E3 W LWO*4 .wm m m '
W -
W O W C W e e w w aa m > e e .
M #2 *MW> E 4e W>e=WW W e P4WWWM 2 4
- MMMWs >SW WS>O g .g>gg>g3 OmW>
N&WW WE a '
m W
D D SOg>WW '
eg H > > #> JUS S WWWE we@ E ee w - 3 m w M w
e Ww3J4 3Eumg>mmam 3 m 1 4 d w iu 3 OJ u g g iu g g w 3w g p ee W m 3 , SOde4EbWmwamaresa = m
>. W. E New .g> 3m36W>mWW > e s. .
> d W ASEWW E @MWGW st w AS I C E
- WW IEW e
P N
O' W
W i eEW>
W W >e> isweso Q 3 W S M > w w wgWmm, zews .
lW3dRM wdW44W a i ee W
W
- Q 4 W W O S A E 3 0 W W M1u e m e g
- i W
3 A&D>&QW 3 > S > g > v, y g U *
- W J S W E N M & J M m e so 'W M 4 e g O #' N z WCas &we 4W w > m i w .
l W W J su g m e tu w w Mme >WgggW @ 2 8
% " A > 2 W W W R E & m O W 4W W E E 34u g g w .
o i 4 J E W QWAm>>>>3wde gemqwn g g i,
4
, i t
I
' eeoeeeoeeeeeoeeeeaeeeeoeoeeaeeoeeeee i
wNeveemame=NM+e4>##OwNM+m4>emo*NM+m@ en se en su eq see et om aus 64 t sp rg f W t es s w t w e q 4 9 Py ry e l e l M1 A l M M M i
=
l I . - - .- .... - - - - -
8.. i
. =: > 1 w* 35 1 n-
.g 3 "Wg .
)
4>. 3*. w
- l a SEM =
I l 1
I.E_gW o*s.E O* ]$ _
l
- gW .>, M e 1 W545
> - W5 ~gg ~3.
W
. .e W ..W.,ww .. 3.*3 3 88 2502'= *-* : :
C , i f*Ef*E*EN a! g 5:
1 g
a
- J..C>[":
t- g-=.3Wga W
E g
.3 .
=5
.g E~
h s
>t 2
. mot. n -a..gr E e:W a ==
e n.
W 5 E n- 5 E oeW = = ****
- W =
w i ->
...I.W.=.sW W se ! :-
W
. .. e . 5 === -
3 g
e5 I.*C 5**
n a; :
- =3 E. t. t. ,
- B I ==s- og W
- "IW.5 Itts
. 6 s Sgt . 2:35 0'
.= -- ::g* *I*..g 3 agEE.
-=w 55
.$af
.. a = = **
s W..=W . .. --W. . ,
33*
- sg 55't 2: '
t Ig-3.g 3e."s.t.** 2.: 82W~
- - W WW W
saw watWE me >cw M8 wSu eek W3 3 JWas as en w w as wwg4 wWemwwwase m e. Ewet &
- m RE&ptqwaws >W mSWm m>wW st a mW M*50 Q4
> 4 sEE awa OMWh mWw we e d WWJW a WW Wa Ed m3 M wans.a EHWJCS WhT
> mW m .m32W
- WA Su 3
WW e w &>4 MWW Wm l W P. *2 g -
W&WESbMMSW gg m EWWW M t .. MJ WEMSE3 e >WWo EP
@ > ks&W WWWSM Me E> WW 3 > > w ( W 2 Og
-m E
m E w
MkESIP3WWW
=
3>WSW W = w a e
= [v* a r e o WM d d> m ee EA
'e S M O W W 6 kJ w M WE W- & > MJ4EmWWW > e> udEO ww
$ 4 ESSMShk3Em u WE WWWW E E >
W WD24 05 EWES m-43 4 .WW P M %
w W E@Sk m- W tew SOM W s .. ww22 HQ W W S >
EWWWWJ GEW g > J WEWW MX M M>>& W4M E y g h4Em MM 8 E > > WW244 >WW3 e e a su E J w>
W W N E WWWEWWEWWW m > W M 4 EM 9 W d W WWW WWE3WW W E 3 W Q EM 8W = > 34W5h4W Sm W c ut 2 WEE OM C J 4 W P4JPOS&-RW m u o m344 W>
eaeeeoeeeeeeeeeoeeeeeeeeeeeeeeeeeeeeeeeoeee**
OWNMTM@>WSOWNM4M4kEPOmNM@M4>S@ OW NM4M@hO@ OWNM4 MMMMMMMMMMd f4@f44W4 (MemMMMmemm 444444@@@@N W>NN m,wn,,,,w,,.wwww,,,,pww.,--,--m
~., . . . - . _ . . . - . _ . . . . - . . - - . . . - . - . - . - . - . - . - _ . . . . . - -
~'
I y
k UN1780$TAfts NUCLEAR REGULATORY COMMISSION f
~~ ~
\.,*)
WASMlltefew. D. e. 30005 September 21,1989 [ j 4 _._ ,
Decket No. 50-251 MEMORANDUM PORT T.14 frier 8. SHans P. McMan J. Sniesek F. Congst A. Thaeani F. Nireglia. A3T J. Ree C. McCracken J. Portlow ADP C trines C. Haughnsy D.CrutchfIeld,A08P l. teger H. 8. C14rten, 500 .
- 8. Varga G. Lainas Operations Center
- 4. Holahan M. Viepilio F. Sillespie C. Rossi 8. D. .iew W. Seteman -
J. Richardson E. Butcher L. Reyes, R!!
- 7. Cox THRU: Hartert N. Serkow, Director Prodect Directorate II.t .
Div5sion of Reactor Projects 41/1 FROM - Gordon E. Edison, Sr. Project Manager Protect Directorate 11 2 ' ,
Div9ston of Reactor Pro.iects - t/!!
SUBJtCT: DAILY HIGHLIGHT
' Turkey point Unit 4 1949 Unit 4 was manually scrammed because of a large primary /
l De Septester secondart l m15,ismatch, which resulted from autosatic closure of a tudine sto ead i
valve. The turbine step valve closed on low EHC eil pressure, which was a i result of oil leaking from a cracted weld in the EHC cil line. The rod control system began to insert rods autcastically but stopped after only 4 steps of intertion.
The operators tried to manually insert rods with'the control system but were l unsucesseful. Therefore the reactor was anvally tripped. he rod' control system failure is known In the industry as " urgent failure", which sosutines occurs cogparater in Westinghouse whose voltage signa plants,l had drifted out of range.and in this instance wa the safety function of the separate reactor trip system. A manual safety injection was initiated per procedure when pressurizar level drooped to 125.
However, ne injection took place because RCS pressure dropped only to 1780 psi.
I' while the SI shutoff head is 1600 psi. The "C" steam generator experienced some overfeed to about 855 (narrow range) because sne solenoid-controlled MFW rem:1ating valve did not close; this was caused by a sticking solenoid valve, which was later discovered to have natallic shavings caught in it. The SG hi.h1 level signal resulted in "C' MFW isolation valve c osure, per design.
The RCS cooled about SI'F due to the SG overfeed.
The SI signal started both EDGs. There was a small oil leak in an instrument line on one EDGs this was easily repaired and probably would not have prevented operation of the E06 if needed. A standby FW pump was started because NFW puse restart was temporarily preventen by the high SG 1evel signal. A charging
-2 l
soeed as . which unex
! pump (40) levelisrose controlled by pressuriser one trippes off onlevel low oil press,ure. pectedly About to minutes we after-
- the event the speesters tried to restart a MFW pump. However. a manual valve-would not open in the pressure equalisation line across the Mnl ditehstge j valve, and the discharge valve aster burned out.
The event incluesd several egA1pasnt failuress hooever, the operaters appear to ~
! have performed well. The operators coenmated that the E0ps worked eell. No safety system fa11eres occurred. Some public interest has been notes because of i
- a. failure in the red control system. It is important to note'that this was not an ATWS event,'and the reacter trip system performed por, design.
The licensee has investigated the event, determined the rest causes of the failure and is repairing the-equipment. Restart is expected by Septester 21 The resident inspectors are following the licensee's activities closely.
I l
(( Q .
' 6ercen E. Edison, Sr. Predest Manager Project alrectorste !!.t Division of Reacter Prefects . t/II l est PO's ,
0 l
l l
1
. e ..
i g
TORKEY POINT UNIT 4 MANUAL REACTOR TRIP & MANUAL SAFETY INJECTiot SEPTEMBER 15, 1989 .
004S T.o. REPORTS oL LEAN ON H.P. TUR$1NE, FIRE PROTECTION AND l
S. c. MLPATRION NOTFIED.
1 0120 INSPECn0N COVER REMOVED FROM LEFT STOP V4VE 0180 LOSIN A 1/2-1 GPM LEAK PROM ALito STOP OL PIPING. ,
01:0 CPERATIONS SUPERVISOR NOTIMED .
D 0140 CPsRAtl0NS SUPERINTENDENT NOTFIED. i
!. 0818 DISCUSSED REPAIR OPfl0NS WITN MECNANICAL MAINTENANCE l.E. FURMANITE OR WELD REPAIR. .
0220 3RD ROC ColeAENCES NOURLY INSPECTIONS OF OL LEA STOP'OL PRESSURE.
0427 LEFT TURSINE STOP VALVE CLOSEQ RESULTING IN SEC0 L TRANSIENT (IGR. ORAIN PPS TRIP, LOSS OF ELEC. LOAD), RODS BEGAN STEPPNG IN IN AUTO AND TNEN FALED, MANUAL R00 00NfR06 480 FALED.
0425 MANUAL Rx TRIP, CODE SAFETIES CYCLED.
MANN SAFETY INJECTION AND PHASE A CONT. ISCL., PRI LEVEL 0430 AT 135 AND DECREASING QUE TO C00LDOWN FROM FC L ("C" S/0 FEEDREG) FALURE TO CLOSE, (AUTC FEEDWATER 1806. FROM S.I.).
0431 AUTC FEEDWATER ISCL. FROM Hi-HI LEVEL IN "C" s/0.
l L. - - ... .. _ . _ .._._ _ _ _ _ _ _ _
w i
= l TORKEY POINT UNIT 4 MANUAL .
SEPTEMBER REACTOR 15, 1989 TRIP
- w 1 1
044e sWETY INJECnON REStf. ,
044s SECONDARY RMIATION VERFIED NORIM., STA VDtFIES i STATUS TREES NORMAL WITH EXCEPfl0N O i
0800 Nf6 REPORTS CL LEAK ON "A" EDO, DIRtofED T.O. TO SEC OlEStk. 080LAllED DIESEL 005 ENTERED T.S. 3.0 4 "B" CNAR0 LNG PUMP 003. '
0618 "B" E00 SHUT DOWN AND IN ETANDWY. - .
0880 "B" FREDPUMP 17tFPED UPON START.
0558 "A" FEEDPuMP srARfte.
0553 "A" PEEDPUMP STOPPED 00E To Ol5 CHARGE MO STARTED "B" STAND 5Y S/0 FEEDPVWP, PLACING 0618 ..
0721 NOTFED NR000 0F $10NFICANT EVENT.
"A" E TEST COMPLETE, sAr, oEcLARED SACK IN SERV 1105 g-y-we+p9-ow**-*y-e-W7'*e'p ww-W-'vww#'g-w g-w s wn g.q gy e pa,.M-Ww wmyd .w me+ w-mym t en. m wseep w-e me.v w ewe e epe
- m. e -..
,. 3-4
'- . . pi
\ ' P.e su teese, June Benh.R IMes4nt :
f EE MSG 1 1989 J
I.
L-89-325 ,
I 4
U. S. Nuclear Regulatory Commission Document control Desk
-Attn j
Washington, D. C. 20555 v.
Gentlemen:
~4
.; Re: Turkey Point Units 3 and 4
- Docket Nos. 50-250 and 50-251 Reply.to Notice of Violation Insnaction Renort 89-27 L ' i g. '. .
l t Florida Power. . & Light Company (FPL) has reviewed the subject inspection ' report and pursuant to 10 CFR 2.201 the response is attached.
L Very truly yours,
[- ,
p
< i C. o ody Senior Vice President - Nuclear Acti I
!' COW /JRH/cm Attachment cc: Stewart D. Ebneter, Regional Administrator, Region II, USNRC ,
Senior Resident Inspector, USNRC, Turkey Point Plant ?
l f
8909120388 890901 -
PDR Q
ADOCK 05000250 FDC (l
__ ..___. _.. ___._...__._El1 URBAN A REG. DOCS.}!BRARY. ,, , i[
q LL" t
6
- ^
/ .
ATTACEMENT e
1 l
-REs. Turkey Point Units 3 and 4 Docket Numbers 50-250 and 50-251 -
NRC Inspection Report 89-27
)u l FINDING A TS 6.8.1 requires. that written procedures and administrative policies ihall be l
. established, implemented and maintained that. neet or enseed the requirements and reeoamendations of Appendix A of USNRC Regulatory Guide 1.33 and Seetions 5.1 and 5.3 of- ANSI N18.7-1972. Administrative Procedure 0-ADM-209, Equipment Tagging and Labeling, provides the responsibilities, precautions, limitations -
and instructional guidance for establishing sad maintaining an seenrate, com - <
plate-and effective plant tagging program. .j contrary to the above, engraved label pistes were replaeed on the Unit 3 Safe-ty Injection Block Switch without following the requirements of Administrative Procedure 0-ADN-209, resulting in two separate safeguard attuations within's 24-hour period. .
RESPONSE &
- 1. FPL concurs with the finding.
- 2. The cause for this finding was personnel error by non-licensed utility personnel. The label on the Safety injection Block Switeh had been re-eently replaced with a label which contained more detailed information.
Both the person responsible for validating the label and the person who installed the label for the Safety Injection Block Switch failed to ade-quately validate all the information sontained on the new label. The new label installed had the " Blocked" and " Unblocked" switch positions re-versed. This resulted in the switch being placed unknowingly in the
" Unblocked" position instead of the " Blocked" position. With the switch in the "Unbloeked" position, when the manual block buttons were released, an SI signal was produced.
An unclear drawing was the reason the insecurate label was not identified following the first SI setuation. The 1&C technician was required by the Plant Work Order for this activity to verify that the switch had proper continuity in the block, neutral, and unblock positions. 7 hen he performed this step, confusing information on drawing 5610-N-430-171, Sheet 5, " Units 3 an 4 Safeguards Systes," lead the technician to believer that the switch was responding sorrectly. This resulted in the insecurate label not being 1
_4 s
a i
L identified. Two switch contact blocks which showed signs of physical damage '
L '
. were considered to be the eause of the first 81 setuation.
l
! . 3. Corrective steps which have been taken and the results achieved includet -
r -
L a. The Unit 3 Safety Injeetion Bloek Switch has been relabeled to s j eorrectly identify switch positions.
l b. The Safety Injection Block Switch labels in the Simulator and in '
the Unit 4 Control Roos have been verified to be correct.
L 4. Correetive steps which will be taken to avoid further violations ineludes
- s. The individual responsible for validating the tag, and the individ-ual responsible for plaeing the tag were eeunseled. This counseling ,
stressed the importance of verifying the information contained on tags before they are installed. ,
- b. Administrative Procedure 0-ADM-209 has been revised to require in- t dependent verifiestion by a Renator Control Operator of the seeuracy of information on new tags being installed in the Control Room. '
I
- e. Drawing 5610-N-430-171, Sheet 5 has been revised to remove eonfusion related to the switch nomenclature orientation.
- 5. Date when full soeplianee will be sehieved
- a. Aetion item 3.a was soupleted on June 23, 1989. -
- b. Aetion itea 3.b was eospleted on June 23, 1989.
- c. Action item 4.a was completed on June 23, 1989.
- d. Action item 4.b was completed on July 7, 1989. ,
- e. Action item 4.c was completed on August 15, 1989.
FINDING B 10 CFR 50, Appendix B, Criterion III, as implemented by the approved Florida Power and Light Company Topical Quality Assurance Report (FPLTQAR) 1-76A, Revision II, Topical Quality Requirement (TQR) 3.0, Revision 7, requires that measures be established to assure that appliesble regulatory requirements and the design basis are correetly translated into specifications, drawings, pro-eedures, and instruations.
Contrary to the above, the required 2.0 second opening time specified for the Pressurizer Power Operated Relief Valve (PORV) in the Overpressure Mitigating System (OMS) Safety Evaluation Report dated Marah 14, 1980, was not incorpor-ated into the licensee's Inservice Testing Program. Instead, a non-conserva-tive acceptance criteria of 15.0 seconds was used. This resulted in the Unit 3 and 4 PORVs being unable to maintain Resetor Coolant System (RCS) pressure 2
l 0 &
below the 10 CFR. 50, Appendix G limits, had the most limiting design basis I
transient oceurred. This eondition existed on several oeessions from May 1984 to June 1988, as exhibited by a review of PORY stroke timing records.
l l- RESPONSE 5
]
l
- 1. FPL concurs with the finding. l 1
- 2. The eause for this finding.was an inadequate design process. The process '
did not verify that the design basis opening time of 2.0 seconds for the PORVs could be met by the PORVs installed at Turkey Point, nor did the process assure that the proper seeeptanee eriteria was incorporated into t'..e Plant's affected documents.
.. 1
- 3. Corrective steps which have bee,n taken and the results achieved includes j
- a. Westinghouse has performed an evaluation of the ineressed PORV stroke times against eseh of. three overpressure events (inadvertent start I of two charging pumps with a loss of letdown, spurious start of one - !
safety injection pump, and inadvertent starting of a RCP with a
- I temperature differential between the secondary system and the RCg -
of 50 degrees P). The mass injection pressure transient of a spur-ious start of a single safety injeetion pump has been determined to be the most limiting pressure transient event. The final results showed that the PORVs eould be tested up to 3.45 seeonde and still prevent the most limiting pressure transient from exceeding 10CPR50, Appendix'G limits.
Por the case of two charging pumps starting with a loss of letdown and of inadvertent starting of a RCP with a. temperature differential between the secondary system and the RCS of 20 degrees P-(Turkey Point operating procedures specify 10 degrees P), the Westinghouse evaluation demonstrated that PORY opening stroke times would have to exeeed 10.0 seconds before the limits of 10CPR50, Appendix G would ,
be approached. I
- b. Plant Change /Modifiention (PC/M)88-535 has been issued to ineresse the size of the Unit 4 PORY instrument air and nitrogen backup supply line tubing. This PC/M has been implemented and was demon-strated to be effective in deereasing the FORY opening time through performance of Preoperational Procedure 0800.216 "Pressuriser PORV Nitrogen Baekup and Timing." This procedure requires an opening time of 1.65 to 3.45 seconde and a closing time of 1.0 to 2.0 seconda using both instrument air and nitrogen backup supplies.
- e. PC/M 88-427 has been issued to ineresse the size of the Unit 3 PORV instrument air supply line tubing as a temporary measure to decrease the PORY opening stroke time. This PC/M has been implemented and was demonstrated to be effective through performance of Startup Field Procedure STP-13. "Startup Test Control - Interia Department-al Testing." Permanent modifications to the PORV instrument air and nitrogen baekup supply line tubing will be implemented on the Unit 3 3
8 @
PORVs prior to restart from the next refueling outage. Compensatory i
I measures are in plaes as a condition of NRC Diseretionary Enforcement ;
'to allow eontinued Unit 3 croretion with PORY opening stroke times of less than or equal to 10.0 seconde until these permanent modifiestions l are completed. .;
- d. Operating Procedure 0P 0209.1, " Valve Exereising Procedure," provides instructions for the periodia exercising of Safety Class 1, 2, and 3 valves for which euereising is required by the Valve Test Progree portion of the Turkey Point Inservice Testing Program. This pro- ,
eedure has been revised to ensure the Unit 4 PORVs meet an opening ;
stroke time of 3.45.
- e. OP 0209.1 has been revised to ensure the Unit 3 PORVs meet an open- )
ing stroke time of*1ess than or equal to 10.0 seconds. OF,0209.1 ;
will be revised to specify an opening stroke time of 3.45 seconde t for the Unit 3 PORVs upon eempletion. of long ters sorteetive modi-fiestions during the next refueltag' outage. 1
- f. Operations Surveillanee Procedure 4-OSP-041.4, " Overpressure Miti-gating System Nitrogen Baekup Leak ant, . Functional Test," has been .
revised to ensure the Unit 4 PORVs moeu an opening stroke time of 3.45 seconds using the nitrogen backup supply.
- g. Procedure 3-0SP-041.4 has been revised to ensure the Unit 3 PORVs meet an opening stroke time of less than or equal to 10.0 seconds using the nitrogen beekup supply. 3-03P-041.4 will be revised to specify an opening stroke time of 3.45 seconde for the Unit 3 PORVs i using the nitrogen beekup supply upon soupletion of long ters modi-
' f,testions during the next refueling outage.
- 4. Corrective steps which will be taken to avoid further violations includes
- a. Administrative Procedure (AP) 0103.18, "Paeility Operating License Amendments and/or Changes," has been revised to require the Nualear Engineering Department personnel to doeunent the review of proposed license amendments and provide a response to the Regulation and Compliance Group.
- b. Nualear Engineering Quality Instruction (QI) 3.11, "JPN Leview of Technical Specification Amendments," has been issued which requires the review of teehnical specifiettion amendments for impact on eng-insering design documents.
- 5. Date when full eospliance will be achieved:
- a. Action item 3.a was completed on March 2, 1989.
- b. Aetion ites 3.b was completed on March 2, 1989.
- e. Action ites 3.e will be complete prior to startup from the next Unit 3 refueling outage which is currently scheduled for May 31, 1990.
- d. Action item 3.d wau completed on February 24, 1989.
4 . l i
i
r a.
j
... l (Np !
- u ,
%)) :- , j
- f. !
L e. Aetion ites 3.e will be complete prior to startup f ree the mest Ustt 3 !
refueling outage which is eurtently eeheduled for gay 31, 1990. !
- f. Aetion sten 3.f was cespleted on May 2,1989.
l
- g. Aeties ites 3 3 will be eenplete prior to startup from the seat Ustt 3 refueltas outage which is currently seheduled for May 31, 1990. ;
i
- h. Aetion ites 4.a use eoopleted on Novenher 28, 1988. !
j t. Aetion ite. 4.h ... e..,1.ted is neee.her 1,... ;
I
' i 1 .
l t
'! i i i
- l 1
l- t i ,
j i lI .
e n
8 l
1 j i 1
i
+
i
.i 6
- c J I 1
1 i
1 1
3
. e. Aetion ites 3.e will be eosplete prior to startup f ree the nest Unit 3 s j .
refueling outage whiah is eurtently eeheduled for May 31, 1990.
! f. Aetion ites 3.f was completed on May 2,1989, f 3 Aetion itee 3 3 will be complete prior to startup free the mest Unit 3 (
, refueling outage which is eurtently seheduled for May 31, 1990. l t r
- h. Aetion ites 4.s wee toepleted os November 28, 1984. 6 j ...
- 1. Aetion ites 4.h wee eoepleted in Deeesber 1944. .
1 a i f I !
t i .
l 4
e l l 1 !
I t
I i
f .
i i
l
(
3 l
l l
(
l 1
l e
fr i .
c i UNITED STAf tl 0F AMERICA NUCLEAR RtlVLATORY COMM!st!ON i
In the Matter of I !
l !
FLORIDA POWER AND L18HT COMPeWY I Docket No.(el 50-250/251-OLA-4 i l
i (Turkey Point Plant, Unit Nos. 3 6 4) I i !
I CERTIFICATE OF SERVICE i
! hereby certify that copies of the foregoing NEAP RELEVANT INFCRMATICN... l have been served upon the f ollowing persons by U.S. sail, first clase, sucept !
as otherwise noted and in accordance with the requirements of 10 CFR Sec. 2.712. :
i Atomic Safety and Licensing Appeal Adelnistrative Judge Board B. Paul Cotter, Jr., Chairman U.S. Nuclear Regulatory Consission Atenic Safety and Licensing 90 erd
- Washington, DC 20555 U.S. Nuclear Regulatory Consission .
Washfngton, DC 20555 t i
Administrative Judge Administrative Judge Ilonn 0 Bright Jerry .[
Harbour i Atoste tafety and Licensing Board Atomic Safety and Licensing Board ;
U.S. Nuclear Regulatory Cocaission U.S. Nuclear Regulatory Coseission l Washington, DC 20555 Washington, DC 20555 Janice E. Moore, tsautre Harold F Reis, Esquire !
OHice of the General Counsel Attorney for FF6L !
U.S. Nuclear Regulatory Consission Newman & Holtsinger, P.C. !
Washington, DC 20555 1615 L 8treet. N.W., tutto 1000 Washington, DC 20036 :
Lorton Director Jostte Center for Nuclear Responsibility "
7210 Red Road, #200 i Miami, FL 33143 Dated at Rockville, Md. this ,
23 day of October 1989 j
Office of the Secretary of the Cosaission l -
l l
l
.-. . . .. -- - - - __ - - - ._ - -