ML17342A441

Responds to Violations Noted in Insp Repts 50-250/85-44 & 50-251/85-44.Corrective Actions:Step 8.35 of Operating Procedure 0202.1 Revised to Require That Accumulators Filled & Pressurized Prior to Exceeding 1,000 Psig

ML17342A441
Person / Time
Site:	Turkey Point
Issue date:	03/24/1986
From:	Woody C FLORIDA POWER & LIGHT CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
L-86-128, NUDOCS 8604080107
Download: ML17342A441 (8)

See also: IR 05000250/1985044

Text

p2: O3 P.O.BOX 029100 MIAMI, FL 33102~M 6 gyAlliy irse<x~FLORIDA POWER&LIGHT COMPANY gg 2 4 1888 L-86-128 Dr.3.Nelson Grace Regional Administrator, Region II U.S.Nuclear Regulatory

Commission

101 Marietta Street N.W., Suite 2900 Atlanta, GA 30303 Dear Dr.Grace: Re: Turkey Point Units 3 2 0 Docket Nos.50-250 and 50-251 Ins ection Re or 8-Florida Power R Light has reviewed the subject inspection

report and a response is at tached.There is no proprietary

information

in the report.Very truly yours, C.O.Woo Group Vi President Nuclear Energy Department

COW/3A:dee

Attachment

cc: Harold F.Reis PNS-LI-86-128

8604080i07

860324 PDR*DaCK 05000250 8 PDRi~o j PEOPLE...SERVING PEOPLE

1+P,

ATTACHMENT

Re: Turkey Point Units 3 and 4 Docket No.50-250, 50-251 IE Ins ection Re ort 250-85-44 5 251-85-44 FINDING 1: Technical Specification (TS)6.8.1 requires that written procedures

and administrative

policies be established, implemented

and maintained

that meet or exceed the requirements

and recommendations

of sections 5.1 and 5.3 of ANSI N18.7-1972

and Appendix A of USNRC Regulatory

Guide 1.33.FINDING l.a: Appendix A of USNRC Regulatory

Guide 1.33 recommends

that written proce-dures be established

covering the startup, operation and shutdown of the emergency core cooling system (ECCS).The cold leg accumulators

consti-tute a portion of the emergency core cooling system.The Final Safety Analysis Report (FSAR)does not consider the conse-quences of a loss of coolant accident (LOCA)when the cold leg accumu-lators are unavailable.

Operating Procedure (OP)0202.1, Reactor Startup-Cold Condition to Hot Standby Condition, recommends, but does not require, that the cold leg accumul ators be pl aced in service prior to exceeding 1000 pounds per square inch (psi)reactor coolant system pressure.Contrary to the above, OP 0202.1 was not adequate, in that it allowed the units to be operated at full temperature

and pressure without the cold leg accumulators

in service, that is, to be operated in an unanalyzed

configuration

without regard for the possibility

that an accident of a different type than any previously

identified

in the FSAR could occur.Between June 23 and 26, 1985, the Unit 3 reactor was operated at full temperature

and pressure (hot standby condition)

while all three accumu-lators were empty and depressurized.

On several additional

occasions, the licensee has failed to maintain the required level and pressure in the accumulators

while the units were in hot standby.

I'

Re: IE Ins ction Re rt 250-85-00 R 251-85-00 Page 2 RESPONSE: 1)FPL concurs with the finding.2)OP 0202.1 did not require that the accumulators

be placed into service prior to exceeding 1000 psi in the reactor coolant system (RCS).When the operators reached this step and experienced

difficulty

in placing the accumulators

in service, they consulted both Technical Specifications (TS)and the Final Safety Analysis Report (FSAR)for additional

guidance.In order to fill the accumulators, MOV-+-869 is required to be open.TS 3.15 requires MOV-+-869 to be closed and its breaker racked out whenever the RCS temperature

is less than or equal to 380 degrees Fahrenheit.

TS 3.0.1.a requires the accumulators

to be operable before taking a reactor critical except for low power physics testing.TS 3A.l.b provides an action statement for loss of one accumulator

for a reactor at power that requires a unit to be placed back in service within the specified times.The FSAR does not describe the requirement

to have the accumulators

in service prior to exceeding 1000 psi in the RCS.Since no requirements

could be found to have the accumulators

in service prior to exceeding 1000 psi, the unit heat up was continued with the accumulators

out of service.3)In accordance

with guidance from the Office of Nuclear Reactor Regulation, step 8.35 of OP 0'202.1 has been revised to require that the accumulators

be filled and pressurized

prior to exceeding 1000 psig.0)FPL is currently developing

a revision to the existing Technical Specifications

to improve the format, content and overall margin of safety.This revision includes adoption of the Westinghouse

Standardized

Technical Specification

format.Completion

of this action is presently covered under the Performance

Enhancement

Program (PEP)schedules and controls.5)Full compliance

for Item 3 above was achieved by 3anuary 21, 1986.

~~~E~/II'4

Re,: IE Ins ection Re ort 250-85-44 5 251-85-44 Page 3 FINDING 1.b: ANSI N18.7-1972, section 5.3.(3), Post-Maintenance

Checkout and Return to Service, requires that instructions

shall be included in maintenance

procedures

for returning equipment to its normal operating status.It further states that operations

personnel shall place the equipment in service and verify and document its functional

acceptability.

Special attention shall be given to restoration

of normal conditions, such as removal of signals used in maintenance

or testing, and to systems that can be defeated by leaving valves or breakers mispositioned.

Contrary to the above, during the performance

of maintenance

repai rs on the"B" emergency diesel generator (EDG)day tank level switch (LS 1561B), using maintenance

work orders 63-8224 and 69-4437, instructions

were not included or referenced

in the work orders regarding restoration

of valves to their normal positions.

Consequently, on December 10, 1985, two level switches, located adjacent to the work area, were not returned to service because their isolation valves were inadvertently

left shut.This disabled both the remote day tank low level alarm and the automatic start capability

of the"B" fuel oil transfer pump.RESPONSE: 1)FPL concurs with the finding.2)The guidance available to plant personnel did not provide sufficient

instructions

for restoration

of components

that had been manipulated

within the equipment clearance boundary.3)Upon identification

of this discrepancy, the two level switches were promptly returned to service.4)Administrative

Procedure (AP)0103.4, In-Plant Equipment Clearance Orders, has been revised to require that prior to releasing a clear-ance the components

within the clearance boundary will be aligned in accordance

with the applicable

plant procedure for the required mode of operation.

5)Full compliance

for Item 4 above was achieved on March ll, 1986.