ML20207L846

Ack Receipt of 861008 & 1119 Responses to Violation Noted in Insp Repts 50-250/86-33 & 50-251/86-33.Encl Assessment of Violation Example E.2 Concluded Powering of RHR Components Occurred as Stated.Resubmittal of Response Requested

ML20207L846
Person / Time
Site:	Turkey Point
Issue date:	01/07/1987
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Woody C FLORIDA POWER & LIGHT CO.
References
NUDOCS 8701120364
Download: ML20207L846 (4)

See also: IR 05000250/1986033

Text

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F'

, jAN O 71987

F]orida Power and Light Company

LATTN: Mr. C. O. Woody

Group Vice President

Nuclear Energy Department

P. O. Box 14000

Juno Beach, FL 33408

Gentlemen:

SUBJECT: NRC INSPECTION REPORT NOS. 50-250/86-33 AND 50-251/86-33

Thank you for your responses dated October 8 and November 19, 1986, to our Notice

of Violation issued September 3,1986, concerning activities conducted at your

Turkey Point facility.

We have evaluated your response to the violation example E.2 and concluded, for

the reasons presented in the enclosure to this letter, that the example of the

violation occurred as stated in the Notice of Violation. Therefore, in accordance

with 10 CFR 2.201 please resubmit your response to the Notice of Violation

example E.2,

We appreciate your cooperation in this matter.

Sincerely,

(Original by by M. L. Ernst)

J. Nelson Grace

Regional Administrator

Enclosure:

Staff Assessment

cc w/ encl:

C. M. Wethy, Vice President

Turkey Point Nuclear Plant

$r J. Baker, Plant Manager

Turkey Point Nuclear Plant

L< W. Bladow, Plant QA Superintendent

F Arias, Jr., Regulatory and Compliance

Supervisor

be,c w/ encl:

lHRC Resident Inspector

Document Control Desk

State of Florida

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ENCLOSURE

STAFF ASSESSMENT OF LICENSEE RESPONSE

INSPECTION REPORT 86-33

Restatement of the Violation Example E.2

Technical Specification 6.8.1 requires that written procedures and administrative

- policies be established, implemented and maintained that meet or exceed the

requirements and recommendations of Appendix A of USNRC Regulatory Guide 1.33.

Appendix A of USNRC Regulatory Guide 1.33 specifies that procedures be established

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describing operation of the shutdown cooling system.

AP 0103.32, Reactor Cold Shutdown Conditions, Revision dated June 3,1986,

requires, in section 4.10, that the components of at least one Residual Heat

Removal (RHR) loop be capable of being powered from an operable Emergency Diesel

Generator (EDG).

Contrary to the above, between July 20 - 25, 1986, the components of at least one -

RHR loop were not capable of being powered from an operable EDG.

This is a Severity Level IV violation (Supplement I) applicable to Unit 4 only.

- Suninary of Licensee's Response

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Technical Specification (TS) 3.4.1.e requires that at least two coolant loops

shall be operable one of which shall be in operation whenever the reactor coolant

system (RCS) average temperature is less than 350 degrees Fahrenheit. TS 1.23

provides the definition of a coolant loop which includes both residual heat

removal (RHR) loops and the three reactor coolant loops. AP 0103.32 also has the ,

TS definition of a coolant loop included. Step 4.10 was included to ensure

personnel did not-take credit for the operability of a RHR pump if an emergency

power supply was not available. The step was not intended to require a RHR loop

to be operable at all times. While the 4B RHR loop was in operation at this

time, no credit was taken for its operability to meet TS requirements. During

this event, the operable coolant loops to meet TS requirements were the A and B

reactor coolant loops. A failure of the coupling on the A reactor coolant pump

oil lift pump resulted in the loss of the A reactor coolant loop and an entry

into the limiting condition for operation for TS 3.4.1.e for approximately 31/2

hours while repairs were completed.

Therefore it is FPL's position that step 4.10 was included to clarify the

operability requirements for a RHR loop and not specifically require a loop to be

, operable. To further clarify FPL's position, AP 0103.32 was revised on

!' September 18, 1986, to clarify the operability requirements for RHR loop.

This change requires that for each operable RHR loop its associated' EDG is

capable of energizing its associated 4160 volt bus.

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1 Enclosure

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-NRC Evaluation

The NRC does not take issue with the Turkey Point Plant definition of a reactor

coolant loop as stated in either TS or AP 0103.32. Each of the following is

defined as being a Coolant Loop:

1. Reactor Coolant Loop A and its associated reactor coolant pump and steam ,

generator with secondary side level greater than or equal to 10%.

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! 2. Reactor Coolant Loop B and its associated reactor coolant pump and steam

! generator with secondary side level greater than or equal to 10%.

3. Reactor Coolant Loop C and its associated reactor coolant pump and steam

generator with secondary side level greater than or equal to 10%.

4. Residual Heat Removal loop A 'and its associated residual heat removal pump

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and heat exchanger.

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5. Residual Heat Removal Loop B and its associated residual heat removal pump

and heat exchanger.

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The staff acknowledges that TS 3.4.1.e requires that at least two of these

coolant loops shall be operable, one of which shall be in operation, whenever the

reactor coolant system average temperature is less than 350 F. Consequently, the

staff agrees that the Turkey Point TSs do not require RHR cooling to be operable

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-- when average coolant temperature is less than 350 F. Upon review of AP 0103.32,

l it is apparent that the requirements for RHR loop operability- specified in

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AP 0103.32 are more restrictive than those imposed by TS. However, TS 6.8.1 requires

that administrative procedures such as AP 0103.32 be established and implemented.

i No exemption exists allowing deviations from approved procedures even when those

procedures may be more restrictive than TS. The staff has reviewed the requirements

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of AP 0103.32 and concludes that AP 0103.32 specifically requires at least one

RHR cooling loop to be operable when the reactor is in cold shutdown. This

conclusion is based on the following facts:

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a. Step 8.1 of AP 0103.32 requires that the system alignments of Table 1

l be performed when the plant is in cold shutdown. Table 1 requires at

l least one RHR pump breaker to be closed. The RHR system design is such

j- that if a RHR pump breaker is closed the pump will be operating; -

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b. Table 1 of AP 0103.32 requires at least one Intake Cooling Water (ICW)

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pump breaker and one Component Cooling Water (CCW) pump breaker to be

closed. The ICW and CCW system electrical designs are such that

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closing these breakers will cause the pumps to be operating. The ICW ,

and CCW systems function in cold shutdown to provide a method of heat l

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removal from the RHR system;

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Enclosure

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c. Section 8.17 specifies parameters which should be maintained within l

their indicating limits. Step 8.17.21 specifies that RHR outlet

temperature should be maintained between 70* and 190 F. Step 8.17.22

specifies that RHR flow to the reactor should be maintained between

t 3000 and 5000 gpm. Meaningful RHR temperature and flow indications can

only be measured with an RHR pump operating; and

d. Section 4.12 specifies that one. RHR loop may be taken out of service

provided at least one reactor coolant loop is operable. The removal of

the second RHR loop from service is not addressed.

The violation at issue resulted subsequent to an NRC determination that

section 4.10 of AP 0103.32 was not properly implemented, in that no EDG was

capable of supplying power to the components of at least one RHR loop.

FPL's postion, as specified in the response to the violation is that

section 4.10 was included to clarify the operability requirements for a

RHR loop and not specifically require a loop to be operable. The NRC staff

~ concurs with the determination that section 4.10 does not, in and of itself,

require an RHR loop to be operable. That requirement is specified in

Table 1 and sections 8.17 and 4.12 of AP 0103.32. .

Conclusion

The staff has evaluated the intent of section 4.10 in light of the requirement to

have at least one RHR loop operable except as specified in section 8.12 and has

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concluded that a literal interpretation is appropriate. Consequently, the staff

has also concluded that between July 20 - 25, 1986, multiple sections of procedure ~

AP 0103.32 required an RHR loop to be operable. As required, the licensee did

maintain at least one RHR loop in operation during the dates in question.

However, the components of the operable loop were not capable of being powered

from an EDG and thus the intent of section 4.10 was not met. The example of the

failure to follow the instructions of AP 0103.32 is of minor safety significance

in that the plant was maintained, as required, in a cold shutdown condition.

However, had offsite power been lost, no RHR loop would have been operable and

the ability of the plant to remain in cold shutdown would have been doubtful.

The NRC recognizes that Turkey Point TS are plant specific and in many cases may

be less conservative than Standard TS. FPL has acknowledged these shortcomings

and in an attempt to bring TS up to industry standards recently submitted a major

TS revision to the NRC for review. This revision includes specific requirements

to maintain at least one RHR loop operable, including emergency power, in cold

shutdown.

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