ML20076E968
| ML20076E968 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/15/1992 |
| From: | Diazrobainas AFFILIATION NOT ASSIGNED |
| To: | Murley T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17349A900 | List: |
| References | |
| 2.206, NUDOCS 9211240306 | |
| Download: ML20076E968 (5) | |
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- N U5NhC 5832 SE Riverboat Erive Stuart, Florida 3499793 JUN -9 P4 :16 (407) 288-2867 October 15, 1992 Er. Thomas E. Murley Eirector of Nuclear Res.ctor Regulations Nuclear Regulatory Commission Washington, D.C. 20555 Lear Er. Murley
.i By means of this letter and its sueuorting attachment' I am formally requesting. that the Florida Power & Light Turkey Point nuclear units not be allowed to start-uo, per the rights and criteria defined in 10CFR2.206 of the code of federal regulations until an adequate set of answers or modifications raswer the objections and concerns defined in the attachment.
I have lived most of my life in Lade County, and my immediate family resides there today.
I am a citizen of the United States and a Florida resident, and my concerns have the documented backing of hundreds of South Floridians that have signed a petition for Senator Bob Graham to initiate a congressional investigation of these matters.
Sincerely,
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Regino R. Liaz-Robainas nages VIA FAX and US Mail 7,l l'2.4 0 3 D S EDo - 008205 ns e l F J L J - #d
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- e 10CFR2.206 on Turkey Point Nuclear Units.
10/15/92 1)- On 8/24/92, the day when Hurricane Andrew attacked South Florida, the NRC transcripts of events at Turkey Point includes i
the following discussion:
" Licensee noted that this Black Start Diesel which can be 1
used as backup if EDG's fail is inoperable at this time due to a lot of oil sorrounding the Diesel following an oil tank i
rupture...A. lot of grass is in the intake structure and licensee has to clean the strains every hour to trevent them from clogging up (supplies cooling water to EDG's)
The croposed interim Fire Protection system for Unit 4 defined by JNP-PIN-SEMJ-92-034 Rev. O dated 9/23/92 uses screen wash pumos which are, by its own description, "normally used to j
-elaanecollected debris off the intake structures' travelling screens" for fire-protection functions.
Given the documented vulnerability of these systems, the proposed modification reduces the margin of safety for both EDG's required during loss of offsite power and the Fire Protection functions: The former by the nonconservative abolition of l
EDG component cooling functions, and the latter by depending on l
unreliable, non-safety related sources as a prime means of fire crotection.
2)- Then Central Receiving and Health Physics buildings were destroyed during the hurricane.
Temporary Diesel pumps used to guarantee the availability of Fire Protection water are housed at the Central Receiving building.
The demonstrated vulnerability of this location combined with the intended, interim deDendence on this source as a redundant means of fire Drotection reduce the margin of safety.
3)- Critical communication and evacuation mechanisms were completely unavailable dQring hurricane Andrew for a significant period of time during which the units were still in hot shutdown er requiringetheioperation of:. critical cooling equipment without offsite power.
The burden of proof lies in demonstrating that this absense of safety will no longer occur during future events.
4)- On 8/25/92 FPL Management violated Technical Specification 3.4.9 3 and used " lack of lighting in Containment & support eersonnel on site" as excuses for this dangerous reduction in the margin of safety.
The susceptibility of the old, embritteled Turkey Point reactor vessels has been established and has been an area of concern to previous NRC administrations.
The failure to cerform license-required surveillances in the absense of alternate technical specification mandated venting of the Reactor Coolant Syr em constitutes a serious reduction of the margin of Safety.
I. is not clear what the NRC nosition is with regards i
s.
m
te 10CFR2.206 on Turkey Point Nuclear Units.
RER 10/15/92 to arbitrary and subjective imolementation by FPL Management of required technical specifications and LCO's during crises.
If the Technical Soecifications are wrong, they must be revised and clant configuration must be made to comply. Other-wise, the technical soecifications must be adhered to.
These issues must be resolved prior to another imprudent unit start-In addition, the Liesel loading profile must be reviewed uo.
such that it assures sufficient lighting for all areas inside containment, or outside, requiring surveillance during emergencies to orovide for Nuclear-safety or quality-related purposes.
And the availability of enough workers to do the necessary work on site, and support work offsite must be re-evaluated in the light of the massive lay-offfs that FPL Mangement recently conducted.
Has the NRC conducted such a review.
If so, what are the conclusions and bases for those conclusions?
Moreover, the reliability of the Overoressure Mitigation System (OMS) as a whole must be re-evaluated given the documented weaknesses in surveillance, setuoint program, and comoonent reliability. An honest Failure Modes and Ef fects analysis must be performed prior to start-up, with the I
consequent modification to plant configuration, to reliably prevent or mitigate an accident of unpredictable magnitudes if a forthright analysis is incompatible with the economics of reconstruction, the nuclear units must remain shut down, and safer, renewable energy structures must be built to reolace them. On October 5 the oms was erroneously actdated, increasing the probability of dangerous thermal shock to the reactor vessel and its piping thru the added risk of a spurious safety injection.
Last week, once again, the effect of the haste to start up the unit with insufficient workers under overworked and rushed conditions led to the accident of a worker, operating a crane, falling inside radioactive water in the Reactor cavity.
monitored radiation / contamination / exposure data from 8/24 until today.
Has there been any radioactive release, or any kind of venting that may have resulted in such release? Or, does the NRC not have enough reliably recorded data, dse in some cases to equipment problems, to make a determination ?
These questions must be answered clearly orior to any contemplated, prudent startup.
6)-The proposed interim Fire Protection system for Unit 4 violates Aopendix R technical soecificatioms such as 3 7 8.1 which constrain limiting conditions for operation (LCO's).
The
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- 10CFR2.206 on Turkey Point nuclear units.
RDR 10/15/92 interim Raw Water Fire Protection system consists of an unreliable and usuedo-redundancy: On the one hand, a RWT-2 crinoled by lack of automatic level control or indication and requiring manual oceration and local only monitoring to maintain urocer tank level, a questionable proposition at best during hurricanes or other events couuled to a newly ourchased electric fire pumo of unclear snecifications and crocurement Drocess, hurr.iedly replacing the original pump which is in turn alighed, but not in a fully restored manner, to the Fire Protection header.
On the other hand, three temporary diesel pumps, for which no licensing credit is taken due, cerhaps, to vulnerability of location, unassured power supplies and a history of braker coordination problems, paralleled with the screen wash tumps discussed in (1).
The latter have a very vulnerable 6" hose connection to the main header manual hose streams which restricts flows in the neighborhood of 500 rum, a nonconservative reduction from the crevious NRC declared standard of 750 com.
In a related concern, why are FPL Management Safety Evaluations being used in ulace of Engineering Packages, complete with drawing, instructions, survaillance and functional test requirements, procurement documentation, and failure modes &
effects analyses, to imolement radically altered Dlant configurations that are in contradiction, or at best tenuous conformance to Plant technical suefications and design bases?
7)- Why is FPL not being required to request a License Amendment, or as a minimum, involve the NRC in the review of unreviewed safety questions, as required by the code of federal regulations?
Why are Safety Evaluations being used, instead, to short-circuit the process of reviewing unanalyzed interim plant configurations, trior to startup? Why are the mitigation functions not being addressed by evaluations such as the Interim Fire Protection Safety Evaluation issued by FPL? Why, in such evaluations, are not specific surveillance requirements, functional testing, etc. not specified for equipment whose nature and confiruration has changed to perform quality or nuclear-safety related functions?
Are there other such cases which bring into question the margin of safety of our people?
This pattern represents a violation of 10CFR50 59 requirements.
8)- The nerformance of Turkey Point Unit 4 in the period ranging from Sectember 29 until today raises serious concerns about the ethics and pridence of current FPL Management which must be answered prior to any future startups.
j In an irresnonsible haste to start the unit, and after claiming in the press that it did not immediatly need the power it would provide, FPL Management failed to perform critical start-up
5 t-4 10CFR2.206 on Turkey Point nuclear units.
RDR 10/15/92 surveillance tests and procedures on the Reactor Coolant system, and in the Feedwater equipment needed to ascertain adequate levels of water in the Steam Generators leading to serious difficulties in cooling down the primary system after the inevitable manual or automatic trip that resulted from the the loss of feedwater.
This ocurred while the unit was significatly past critical, and reinforces our worries regarding management irresponsibility discussed in item #4.
For these reasons, and on the weight of my professional judgment as a former Senior Engineer and Lead Engineer at FPL, and on my educational qualifications with a Master of Science in Electrical Engineering, and~on the regulatory bases definednis 100ER Part 2.206, I urge the Nuclear Regulatory Commission to crevent FPL Management from starting either Turkey Point nuclear unit until the above issues have been properly resolved. I have a community interest in this matter as I have resided in Dade county for most of my life, and members of my immediate family still reside here, r
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Regino R. Liaz-Robainas
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