ML20138J319

Requests That If Commission Reviews Decision of Presiding Officer,Question 63 Should Also Be Reviewed

ML20138J319
Person / Time
Site:	Turkey Point, 05520726
Issue date:	04/23/1997
From:	Tetrick R AFFILIATION NOT ASSIGNED
To:	NRC
References
CON-#297-18266 SP, NUDOCS 9705080157
Download: ML20138J319 (12)

Text

. . _ . _ _ . _ - . . _ _ _ . _ _ _ _ __ _._ _ _ _ _ . _ ..

.jZ(o S To

United States of America 00CKETE'D Nuclear Regulatory Commission ggg l i .

Subject:

Commission's Review of the Presiding Officers Decision in the matter of Ralph L. Tetrick.

I Docket No. 55-20726-SP 0FFICE OF SECRETARY 00CKETlHG & SERVICE i BRANCH j I, Ralph L Tetrick respectfully request that if the Commission reviews the decision of the Presiding i i Officer that they also review the decision on question #63.

The Staff states that "immediate" action is required under the stated conditions of question #63, because personnel would quickly be exposed to high levels of radiation due to the loss of water. The Staff also

conte,ds that two annunciators sounding together (le. H-1/1 SFP LOW LEVEL and G-9/5 CNTMT SUMP Hi-LEML) is enough corroboration to act immediately to prevent injury to the health of plant employees i without , egard to actual conditions.

l 3-ONOP-033.2 states: With an irradiated assembly full up in the manipulation crane and maximum ,

refueling cavity seal leakage, the refueling bridge radiation levels will reach 10 rem /hr in about 22 -

minates (see attached procedure).

At Turkey Point there are two Spent Fuel Pool level Indications and five sump level Indications in the control room. I contend that the 10 to 20 seconds it takes to verify the alarm would not expose personnel inside containment to high levels of radiation, also, this brief period of time to verify the alarms is preferable to causing panic and possible hard to personnel evacuating containment ifjhe alarm is  ;

invalid. N '

With regard to the above, I respectfully request the presiding Office to reverse his decision on question

1. 63, I am also including a letter written by Brian J. Stamp, Acting Operations Supervisor at Turkey Point Nuclear Facility regarding question number 63.

Sincerely, x

Ralph L Tetrick ,

i enc.

1 9705080157 970423 PDR C

ADOCK 05000250 PDR j>U3 o

i y = = = - -

L Florida Power & Light Company i

l r. . .

, Turkey Point Nuclear Plant 4 s j Unit 3 i ,

i 1 a. i t ,

1 vi /, )

! w 3 j e

i i c2 i  :. : .i-i 1 i

t. 1 l

3<

t . 1.

t a

0

!  : A: i  %

{ .1. . [

j I 3-ONOP-033.2 M...i; i e s i:. t i .O&

i i

Ss,

=

a i, A

V:.?:0 l I i

\ t

Title:

Refueling Cavity Seal Failure 1

Safety Related Procedure i Responsible Department: Operations  ;

'93-149 Reviewed by PNSC: ,

t- Approved by Plant GeneralManager: 6/24/93  ;

I Periodic Review Due: 4/20/96 '

R T55 87-0377P, 88-2210, 89- 1021, 90-2205, 91- 1565P, 91-0561 T R TSs 92 1251P, 92- 1032P, 92 1358P, 93-0930P PCIM 89-332,92-031

• /RSE/bsm/rvcib J

. . Proceowre No.: Frocsoure ritie: pag, g 3 ONOP-033.2 Refucling Cavity Se21 Failuro *'8/5U33 l

i LIST OF EFFECTIVE PAGES 8

i

} Revision j P_aage Date

! 1 06/24/93

2 06/24/93

! 3 10/21/92 4 06/24/93 l

i 5 10/21/92 6 10/21/92

{ 7 10/21/92 8 10/21/92 ,

)

! 9 10/21/92 2

10 10/21/92 l 11 10/21/92 4

4 4

J 1

1 On ,

• /RSE/bsm/rucib

.- - - , ,- - . . ~ - . - _ - . . . - . - - - . . . _ . . . . . . . . - - - . . - - . . . . . - ~ - . . - . . . . _ - ~ _ ~ . . . . .

. Proced ure ido.; Procscure Title; Pa gg,-

i .

. 3 Approvat Date.

Refueling Cavity Ssal Failurs 10/21/92 1 3.ONOP.033.2l -

i i

i TABLE OF CONTENTS Section Page a i

1.0 PURPOSE ........................................ 4 2.0 SYMPTOMS ....................................... 4 l

3.0 AUTOMATIC ACTIONS .............................. 5 1

l 4.0 IMMEDIATE ACTIONS ............................... 5

5.0 ,S U B S E Q U E NT A CTIO N S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-

6.0 REFERENCES

/ RECORDS REQUIRED /

COMMITMENT DOCUMENTS ......................... 11 l

1 l

l .

3 I .

i l>

l .

4 E

I 9'

9

• /RSE'bsm/rs/rs .

proceours No.; proczowre Titie: Page-

, . , 4 3 ONOP 033.2 Rsfusling Cavity Smel Failurs ' 5TUO3 4

1.0 PURPOSE j 1.1 This procedure provides instructions for protecting plant personnel and j assuring that public health and safety is not jeopardized in the event of a j - _ Reactor to Refueling Cavity seal failure. [ Commitment - Step 6.3.1) 1.2' Irradiated fuel shall not be placed in the RCC change out baskets until an engineering evaluation is completed. Therefore, t2is procedure does not address an irradiated fuel bundle in the RCC change out baskets.

l I 2.0 SYMPTOMS j 2.1 Annunciators l ,

2.1.1 Annunciator H-1/1, SFP LO LEVEL, alarmed i 2.1.2 Annunciator G-9/5, CNTMT SUMP HI LEVEL, alarmed

! 2.1.3 Annunciator I-4/6, CNTMT SUMP HI LEVEL, alarmed -

i 2.1.4 Annunciator X-4/1, ARMS HI RADIATION, alarmed 4

! 1. Channel R-2, Unit 3 Containment - operating floor level, El,58 ft

2. Channel R-7, Unit 3 Spent Fuel Building - transfer canal area, El 58 ft i i 3. Channel R-19, Spent Fuel Pit Exhaust Duct t

! 4. Channel R-21, Unit 3 Spent Fuel Pit - north wall 4

2.1.5 Annunciator, H-1/4, PRMS HI RADIATION, alarmed 2.1.6 Annunciator H-1/5, CHRMS HI RADIATION, alarmed l 4

! 2.1.7 Annunciator I-7/3, RX VESSEL DRAINDOWN LO EO LEVEL l 2.2 Indications

2.2.1 Increase in local dose rate monitors.

2.2.2 Decreasing refueling cavity and spent fuel pit levels as observed

' locally.

4 2.2.3 Increase in Containment Sump Water Level Monitcrs, LI-3-6308A l and B .

2.2.4 Increase in Containment Water Level Monitors, LI-3-6309 A and B i

2.2.5 Containment Radiation Monitor R 3-12 increasing or alarmed.

4 1

5 i */RSE/bsm/rs/ctb i

i I

- . . - . ~. - , __ _ . - . _ _ , -

. Pro (Ecure NO . ProCSdste Tit:3 Page Approval Date 3-ONOP 033.2 Refueling Cavity Ss21 Fcitura 10/21/92 3.0 AUTOMATIC ACTIONS 1

3.1 Possible containment ventilation isolation due to high containment radiation levels.

l 3.2. Possible Control Room ventilation isolation due to high containment l radiation levels.

. 4.0 IMMEDIATE ACTIONS 4.1 Sound containment evacuation alarm.

5.0 SUBSEQUENT ACTIONS

! C AUTION S i

e With an irradiated assembly full up on the manipulator crane and maximum refueling cavity seal leakage, the refueling bridge radiation levels will reach 10

. Remlbrin about 22 minutes. -

• As reactor internals are exposed, airborne contamination levels in containment

{ willincrease.

5.1 Refueling Operator (s) in Containment 5.1.1 WHEN informed by H.P. that any of the following occurs, THEN exit the containment building immediately:

1. Area radiation levels exceed 10 Rem /hr ,

1 OR

2. Airborne contamination levels exceed 1000 times pre-event level OR l

3. Cumulative dose exceeds 10 Rem whole body or 50 Rem to the thyroid.

,._. ._._._._._._._._. ._. ._._._._._._._._._._.3

. NOTE .

I I

Steps S. I.2 and S.1.3 should be performed at the same time.

l

-- i._._._._._._._._._._._._._._._._._._._._._._._.;l 5.1.2 LF F an irradiated fuel assembly is in the fuel transfer car, THEN lay assembly down AND transfer assembly to the Spent Fuel Pool.

• RSEtesm/rs'rs

.-_-_.....m.. .._.__--m

. . Procecure No ProCec6re Title. Pegg.

Approva Date, 3

3 ONOP 033.2 Rofusling Ca*>ity Saal Fciture 10/21/92 m

l I

5.1.3 IF an irradiated fuel assembly is latched on the manipulator crane, j TI4EN perform the following:

I'

1. Fully insert assembly in the core AND leave assembly latched.

j - . .

2. .IfF assembly can NOT be inserted into the core, THEN move

assembly to the upender AND transfer assembly to the spent fuel

,! building.

! 5.1.4 WHEN allirradiated fuel assemblies are in the core O R in the spent fuel building, THEN perform the following:

1. Move the fuel transfer car to the spent fuel building.

2. Direct refueling operator in the spent fuel building to close SFP j Transfer Tube Gate Valve,3-12-031.

5.1.5 IF the upper or lower internal assemblies are being removed from or Installed into the reactor vessel TH E N either-

1. Install the upper or lower internal assembly into the reactor vessel ifit is located on the reactor vessel guide studs.

91

2. Place the upper or lower internal assembly in a safe condition.

5.1.6 Inflate the inflatable cavity seal by;

1. Open the instrument air supply valve to the inflatable cavity seal and pressurize the seal to 30 to 35 PSIG.

2. Exit the containment building  !

5.2 Refueling Operator (s)in Soent Fuel Building 5.2.1 WHEN informed by H.P. that any of the following occurs, THEN exit <

the spent fuel buildmgimmediately:

1. Area radiation levels exceed 10 Rem /hr QR

2. Airborne contamination levels exceed 1000 times pre-event level QR .

3. Cumulative dose exceeds 10 Rem whole body or 50 Rem to the thyroid.

, * /RSE/bsrn/rsirs

P'O Od wr t NO . ProCecor e Titie. Page Approvai Date.

l 3 ONOP 033.2 Refueling Cavity Ssel Failurs 10/21/92 1

i 5.2.2 IF an irradiated fuel assembly is latched to the spend fuel pit bridge

.; crane, TH E N insert assembly in a fuel rack.

C AUTION If more than one irradiated fuel assembly must be removed from containment, 't i

least one of the assemblies shall-be transferred to a fuel rack within the first 22 minutes of the event.

5.2.3 IF more than one irradiated fuel assembly must be removed from containment, THEN move one assembly from the transfer car to a fuel rack.

g._._._._._._._._._._._ g.,_._._._._._._._._._._.)

I I

- One irradiated fuel assembly may be left in the transfer car provided that the opender .

I remainsin the fulldown position. I l._._....._..,....._._._._._.._._.._._..J 5.2.4 WHEN all irradiated fuel assemblies are in the core or in the spent fuel building, TH EN perform the following:

1. Verify the fuel transfer car is in the spent fuel building.

2. Verify the fuel transfer car is in the down position.

3. Close SFP Transfer Tube Gate Valve,3-12-031.

5.3 Control Room Operator 5.3.1 Direct Health Physics to perform the following:

1. Limit access to containment

2. Limit access to spent fuel building .

3. Monitor radiation levels in containment and spent fuel building

4. Monitor containment for airborne contamination

5. Monitor cumulative whole body AND thyroid doses for operators in containment AND spent fuel building.

5.3.2 Isolate containment as follows:

1. Manually initiate containmentisolation phase A.

2. Verify containment isolation phase A valve white lights on VPB are all bright.

3. Verify Unit 3 containment purge exhaust and supply fans are off.

4. Verify Unit 4 containment purge exhaust and supply fans are off.

• ,RSE/bsmirs ts

. - -. . . _ . . - ~ . - . - - .-~ ..~ -. . - - _ . = = _ _ . - ... . . . - . . . -

Procgours No.; P'oc50wre Ltie: Pigs Approval Date .

3 ONOP 033.2 Rtifusling Cavity Sect Failura 10/21/92 L ._.

i 1

5.3.2 (Cont'd) i 5. Verify all Containment Pur Isolation Valves are closed. ge Supply AND Exhaust l

- ~

a. POV-3 2600 (outside containment)

b. POV-3-2601 (inside containment)

c. POV-3-2602 (outside containment) i 4

d. POV-3-2603 (inside containment)

6. IF any Containment Purge Supply AND Exhaust Isolation

< V~alve is NOT closed,TH sN behindVPB, pull fuse for any i open purge valve.

i'

a. XEP for POV-3-2600 l b. XLAG for POV-3-2601 ,

c. XEQ for POV-3-2602

d. XLAH for POV-3-2603

7. Verify Containment Instrument Air Bleed Isolation Valves are closec .

a. CV-3-2819

b. CV-3-2826

8. Verify all normal containment coolers are tripped AND associated outlet dampers are closed.

9. Verify containment sump pumps are tripped.  :

10. Verify control building ventilation is in emerg'ency recirculation mode using ONOP-10308.1, Control Building Heating Ventilation and Air Conditioning System (HVAC) 5.3.3 Close allinner AND outer containment access hatches. l 5.3.4 Stop SFP cooling pumps.

5.3.5 Shutdown all non-essential electrical equipment in the containment lowerlevels. .

5.3.6 IJ_least at one emergency contr.inment filter fan.any em e/R$[/bsm/rs/r5

- . _ _ . - - _ _ _ _ . - .--._m._m._._._m . - - . . ~ . . _ . . . . _ . . . . . _ . . . . - _ . . _ . _ - . _ . _ _ . - - . . _ . . . . - . . . _ ~ . _ . . ~ . _ . .

• . irOCeCurt No . PROC % Cure Ttt@ Page Approval Datt.

3 ONOP 033.2 Refueling Cavity Ssal Felluro 10/21/92 i

5.3.7 Maintain RHR system operation:

1. Verify RHR pump motor amps stable AND less than 38 amps l l

2. Verify RHR flow on FI-3-605 between 3000 and 3750 gpm

3. Verify annunciator H 6/2, RHR HX HI/LO FLOW, clear

. 5.3.8 Restore s >ent fuel pit level to normal using 3-OP-033, SPENT FUEL i PIT COOLING SYSTEM.

1 5.3.9 Maintain spent fuel pit boron concentration greater than 1950 ppm as follows:

1

1. Direct Health Physics to monitor exposure for personnel entering the spent fuel pit building.

2. Direct Chemistry Department to sample spent fuel pit for boron  ;

concentration. .

3. Borate spent fuel pit as necessary to maintain spent fuel pit boron l concentration greater than 1950 ppm.

5.3.10 Direct Nuclear Plant Supervisor to perform the following: J

1. Check for applicability to conditions listed in EPIP-20101,.

DUTIES OF EMERGENCY COORDINATOR.

2. Check for~ applicability to conditions listed in AP-0103.12, NOTIFICATION OF SIGNIFICANT EVENTS TO NRC.

3. Check for ap"slicability to conditions listed in AP 0103.6, EVALUATIOb AND REPOP"TNG OFIN-HOUSE EVENTS.

4. Verify applicable Technical Spect...ation Limiting Conditions for Operauon are satisfied. .

5.3.11 WHEN spent fuel pit level has been restored to between 56 ft 10 inches and 57 ft 2 inches, THEN perform the following:

1. Stop makeup to spent fuel pit l l

2. Startup the Spent Fuel Pit Cooling System l

l

• /R$E!bsm/rs/rs

-.. _- - . - _ , .-. . -. _ _ ~ . . . .- . - -

Proccoure No . Proc $ cure Titic: page ,

' - 10 ,

Approvai Oa te 3 ONOP-033.2 Refueling Cavity Saal Failura 10/21/92

! I j

I NOTE I 2

l l

. When refueling cavity level and RCS level are at the top of the reactor vessel flange, .

1 l Draon Down Level. LIS-3-6421 and 6423, should indica te approximately 60 percent. l L._._._._._._._._._._._._._._._._._._._._._._._.]

i 5.3.12 WHEN refueling cavity level drops to the top of the reactor vessel

flange, THES perform the following

4 l 1. Verify containment sump level stops increasing.

i' 2. IF RCS level continues to decrease below the top of the reactor Essel flange, THEN add makeup to the RCS using charging pumps as necessary to maintain RCS water level at the reactor j vessel flange. ,

. I i .

l 5.3.13 _ W HEN plant conditions are stable AND radiation levels permit, .

TH EN initiate repairs to the refueling cavity seal.

• l l 5.3.14 Go to appropriate plant procedure as determined by Nuclear Plant

Supervisor.

e a

4 a

f 4

i

}4 6

• /R$E tsm/rurs

. . Procedure No.. Procecure Titte; Sage.

ADDroval Oate .

3.ONOP 033.2 Refueling Cavity Seal Failure 10/21/92

6.0 REFERENCES

/ RECORDS REQUIRED / COMMITMENT DOCUMENTS 6.1 References

. - 6.1.1 Technical Specifications, Section 3/4.9 Refuel Operations 6.1.2 FSAR

1. Section 9.5, Fuel Handling System

2. Section 11.2, Radiation Protections

3. Appendix 14E, Spent Fuel Storage Facility Modifications Safety )

Analysis Report i 6.1.3 Civil Drawing,5610-C-562, Rev 3 6.1.4 General Arrangement, 21774-1, General Arrangement of Fuel Transfer System .

6.1.5 Operating Procedures

1. ONOP-10308.1, Control Building Heating Ventilation and Air Conditioning System (HVAC)

2. 3-OP-033, Spent Fuel Pit Cooling 6.1.6 IE Bulletin 84-03, Refueling Cavity Water Seal.

6.1.7 FPL Letter JPE-PTP0-84-1546, Re: REA TPN 84-64 (Response to IE bulletin,84-03, Refueling Cavity Water Seal).

6.1.8 NRC Exit Meeting Minutes Dated 4/19/85

Subject:

Refueling Activities. IE Bulletin 84-03.

6.1.9 INPO SOER 85-1 (4 and 5), Reactor Cavity Seal Failure 6.1.10 FPL Letter JPN-PTN-90-2609, Re: RE A TPN-90-272 6.2 Records Reauired 6.2.1 None 6.3 .Qommitment Documents 6.3.1 NRC Inspection Report 89-053, March 14,1990 END OF TEXT FINAL PAGE

• /RSE/bsm/rs/rs t

l I

l To: Peter B. Block, Presiding Officer Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission i Washington, DC 20555 i

Subject:

NRC Staffs' motion for reconsideration in the matter of Ralph L. Tetrick.

1 It is expected that the Licensed Operators at Turkey Point verify plant conditions when one or more annunciators are received in the control room prior to taking corrective actions. -

In the case of Question #63, I fully expect the Operators to verify the decrease in the Spent Fuel Pool level and the increase in the Containment Sump level by the indicators located within the surveillance area of the control room. This action would only take seconds and could preclude erroneously sounding the containment evacuation alarm. During refueling outages, there are numerous jobs going on simultaneously inside the containment.

Requiring all personnel to evacuate the area unnecessarily could pose a larger safety hazard than would the increased radiation levels at the refueling stations for those few seconds. In addition, the Training Departments question bank has been revised concerning the correct answer to Question #63.

hn LbY B'rian/J . Stamp '

Acting Operations Supervisor Turkey Point Operations Department e

N C

l0Ud[ .