ML20137Q121
| ML20137Q121 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 01/24/1986 |
| From: | Woody C FLORIDA POWER & LIGHT CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| RTR-REGGD-01.033, RTR-REGGD-1.033 L-86-31, NUDOCS 8602060024 | |
| Download: ML20137Q121 (4) | |
Text
Wfl)/D P.O. BOX 029100 MI AMI, F L 33102 sQ c
Fi ORID A PO'."!ER & LIGH T COMPANY
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JAN 2 4 10!0 L-86-31 Dr. 3. Nelson Grace Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street, N.W., Suite 2900 Atlanta, Georgia 30303
Dear Dr. Grace:
Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Inspection Report 250-85-24 and 251-85-24 A revised response to the subject inspection report is attached. These revisions were the subject of discussions with members of the Region Il staff.
There is no proprietary information in the report.
Very truly yours,
{fge/Wb C.O. Woody l
Group Vice resident Nuclear Energy Department COW /PLP/mg Attachment I
cc: - Harold F. Reis, Esquire l
l 8602060024 960124 PDR ADOCK 05000250 PDR 0
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l-PEOPLE.. SERVING PEOPLE MOl l
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ATTACHMENT Re: Turkey Point Units 3 and 4 Docket No. 50-250, 50-251 IE Inspection Report 85-250-24 and 85-251-24 FINDING 1:
Technical Specification (TS) 3.5, Instrumentation, delineates the condi-tions of the instrumentation and safety circuits necessary to ensure reactor safety.
Table 3.5-2, Engineered Safety Features Actuation, Item number 1.5, requires the high steam flow in two of three steam lines with the low average temperature safety injection (SI) circuit to be opera-tional when the reactor is not in cold shutdown.
Note 2 of Table 3.5-2 states that this safety injection signal may be manually bypassed when cooling down the reactor and the average temperature is below 543 degrees F.
Contrary to the above, on May 30, 1985, following a Unit 4 reactor trip, the high steam flow in two of three steam lines with low average tempera-ture safety injection circuit was intentionally made unavailable by use of the SI block switch.
The SI signal was manually blocked when average coolant temperature was above 543 degrees F.
No reactor cooldown was in progress.
The safety ci rcuit remained blocked for approximately one hour.
RESP 0 HSE:
1)
FPL concurs with the finding.
2)
The reason for the finding was operator judgment during an off-normal condition (loss of a vital instrument bus) and a coincident failed instrument channel (Tave).
The judgment was based on con-firmed plant parameters outside the failures and the desire to mini-mize an undue thallenge to the safeguards system as a result of a spurious signal being generated by an instrument failure.
3)
Operating Procedures (0Ps) 0205.1, " Unit Shutdown - Full Load to Hot Shutdown Condition", and 0205.2, " Reactor Shutdown - Hot Shutdown to Cold Shutdown Condition", have been reviewed and revised to empha-size the Technical Specification (TS) requirement of maintaining the safety injection signal in an unblocked condition when the reactor coolant systeh (RCS) temperature is greater than 543 degrees Fahren-heit or the RCS pressure is greater than 2000 psig regardless of plant conditions.
4)
A training brief was issued to emphasize the procedure changes in l
Item "J.
5) a)
Full compliance for Item 3
above was achieved by l
August 31, 1985.
b)
Full compliance for Item 4
above was achieved by l
September 6, 1985.
O s
IE Inspection Report 250-85-24 and 251-85-24 Page 2 FINDING 2:
TS 6.8.1 requires that written procedures and administrativa policies be established, implemented and maintained that meet or exceed the require-ments and recommendations of section 5.1 and 5.3 of ANSI N18.7-1972 and Appendix A of USNRC Regulatory Guide 1.33.
Appendix A of USNRC Regulatory Guide 1.33, Section 8, Item (1)K, recom-mends that surveillance procedures be written covering control rod opera-bility and scram time tests.
Operating Procedure (0P) 1604.8, dated April 16, 1984, entitled CRDM/RPI ' Stepping and Drop Time Test, provides instructions for performing the rod control cluster stepping test, the rod drop time test and the rod position indication system calibration.
Figure 1 of OP 1604.8 identifies the proper way to perform the rod drop time measurements.
Contrary to the above, on June 25, 1985, OP 1604.8 was not properly implemented, in that rod drop time measurements for shutdown bank A were calculated in a manner contrary to that identified in Figure 1 of the procedure.
This resulted in the recording of erroneous rod drop travel times for shutdown bank A.
RESPONSE
1)
FPL concurs with the finding.
2)
The reason for the finding was failure to comply with the Appendix R requirements of OP 1604.8.
3)
The rod drop times for shutdown bank A were immediately recalcula-ted.
This increased the rod drop times by less than 0.1 seconds.
The average rod drop time of 1.335 seconds remained well below the Technical Specification 3.2.3 limit.
4)
St rict procedural compliance was re-emphasized to the responsible people upon identification of the problem, 5)
Full compliance for Items 3
and 4
above was achieved by June 26, 1985.
FINDING 3:
TS 4.1, Operational Safety Review, requires that equipment and sampling tests shall be conducted as specified in Table 4.1-2.
Item 10 of Table 4.1-2 requires that accumulator boron concentration he sampled prior to hestup above 200 degrees F.
Contrary to the above, on June 22, 1985, the linit 3 primary coolant system was heated above 200 degrees F without prior performance of the accumulator boron concentration analysis.
~
IE Inspection Report 250-85-24 and 251-85-24 Page 3
RESPONSE
1)
FPL concurs with the finding.
2)
At the time of the incident, the accumulators were drained and pre-parations were being made for a reactor coolant system heatup to greater than 200 degrees Fahrenheit.
A conflict in sampling criteria vs. equipment availability criteria was misinterpreted thus al'4 owi ng an on-the-spot change (OTSC) to be made to Operating Procedure (0P) 0202.1, " Reactor Startup - Cold Shutdown to Hot Shut-down Conditions", that moved the accumulator sampling to a later step in the procedure.
Another factor contributing to this misira-terpretation was the Overpressure Mitigating System (OMS) Technical Specification which does not allow opening of motor operated valve (M0V)-869 'with the -reactor coolant system temperature below 380 degrees Fahrenheit.
M0V-869 is opened when filling the accumu-lators.
3)
The OTSC was cancelled in order to re-establish the TS requirement back into the procedure at the proper sequence.
4) a)
The TS upgrade project and associated changes directed at reduced conflicts and improved action statements should aid in preventing recurrence of this type of incident.
Completion of this action is presently covered under the Performance Enhance-ment Program schedules and controls, b)
Administrative Procedures 0-ADM-100, " Procedure Preparation, Review, and Approval", and 0109.3, "On The Spot Changes to Procedures", will be revised to provida improved guidance
+0' the individuals responsible for preparing procedure changes an I on-the-spot (OTSCs) for FSAR and Technical Specification reviews.
A Ouality Improvement Team has evaluated the prepara-tion of OTSCs and has prepared guidelines for the determination of whether a proposed 0TSC constitutes a change of intent t?
a procedure.
These guidelines have been issued for trial imple-mentation, and the final guidelines and associated administra-tive process selected by the OIP Team will be incorporated into appropriate plant procedures.
If the intent is not being changed, the OTSC will be processed as usual.
Should the proposed 0TSC involve a change in the intent, the revision will not be allowed and will require processing as a permanent procedule change.
These permanent procedure changes will receive the appropriate reviews for FSAR and Technical Specifi-cation applicability.
5) a)
Full compliance for Item 3 above was achieved by iluly 2,1985.
b)
Full compliance for Item 4b above was achieved by January 16, 1986.