IR 05000250/1978019
| ML17338A294 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/12/1978 |
| From: | Blake J, Conlon T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17338A292 | List: |
| References | |
| 50-250-78-19, 50-251-78-19, NUDOCS 7811240033 | |
| Download: ML17338A294 (16) | |
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~O UNITEO STATES NUCLEAR REGULATORY COMMISSION REGION Il 101 MARIETTASTREET, N.W.
ATLANTA,GE ORGIA 30303 Report Nos.:
50-250/78-19 and 50-251/78-19 Docket Nos.:
50-250 and 50-251 License Nos.:
C/C Licensee:
Florida Power and Light Company P. 0. Box 529100 Miami, Florida 33152 Facility Name:
Turkey Point Power Station Inspection at:
Homestead, Florida Inspection conducted:
August 28-31, 1978 Inspector:
J.
Blake Reviewed bP-W T. E. Conlon, Chief Engineering Construction Section No.
Reactor Construction and Engineering Suppport Branch ate Ins ection Summar Ins ection on Au ust 28-31 1978 (Re ort Nos. 50-250/78-19 and 251/78-19)
Areas Ins ected:
Routine unannounced inspection of inservice inspection activities Unit 4); Inservice inspection Records (Unit 3); Maintenance and Modification Melding and NDE Activities and Program; This inspection involved 27 inspector-hours on site by one NRC inspector.
Results:
There were no items of noncompliance or deviations identified during this inspectio R:.>.8~'
RII Report Nos. 50-250/78-19 and 50-251/78-19 DETAILS I Prepared yo tz-wg J. J. Blake, Metallurgi 1 Engineer Da e
Engineering Support Section No.
Reactor Construction and Engineering Support Branch Reviewed Dates of Inspection:
August 28-31, 1978
T. E.
onion, Chief Engineering Support Section No.
Reactor Construction and Engineering Support Branch 1.
Persons Contacted a.
Florida Power and Li ht (FPM,)
H. E. Yeager, Plant Manager
"R. J.
Spooner, QA Office-R. E. Tucker, QA-G. Gotch, Power Resources Staff
-"G. V. Papalexiou, Power Resources Staff-J.
A. Olsonoski, QC Compliance Engineer-J.
K. Hays, Plant Superintendant, Nuclear
"P. J. White, Maintenance Superintendent
"J. F. O'rien, Construction, Senior QC Supervisor S. Jackson, Construction QC Supervisor P. E. Bannister, Maintenance Welding Supervisor b.
Contractor Or anizations (1)
Southwest Research Institute (SwRI)
R.
LE Niemeyer, Team Leader H. Diaz, QA Representative (2)
Bechtel Power Co oration (Bechtel)
K. Hampton, Lead Melding Engineer J. Collins, Assistant Lead Welding Engineer (3)
Mestin house Electric Co oration (Westin house)
J.
Samimos, Coordinator
- Denotes those participating in the exit intervie RII Report Nos. 50-250/78-19 and 50-251/78-19 I-2 2.
Licensee Actions on Previous Ins ection Findin There were no previous inspection findings reviewed during this inspection.
3.
Unresolved Items There were no unresolved items identified as a result of this inspection.
4 ~
Plant Chan e/Modification (Units 3 and 4)
The inspector reviewed the Plant Change/Modification (PC/M) for the addition of hydraulic accumulators to the suction and discharge of the Charging Pumps, PC/M No. 77-44.
The purpose of this PC/M is to attenuate the vibration in the suction and discharge piping of of the Charging Pumps and acoustically decouple the piping from the pumps.
The work is being done by Bechtel in conjunction with FP&L construction.
The piping is being fabricated in accordance with ANSI B31.1 (1977 Edition); The discharge accumulators will be accordance with ASME B&PV Code,Section III, Class 2 (1977 Edition),
and the suction accumulators will be in accordance with ASME B&PU Code,Section III, Class 2 (1977 Edition including Summer 1977 Addenda).
The inspector observed welding operations in the shop area and reviewed the FP&L construction and Bechtel programs for the controls of these operations.
There were no items of noncompliance or deviations in this area of the inspection.
5-Plant Work Orders The inspector reviewed the operations involved with the replacement of three valves in the steam supply system for the auxiliary feedwater pumps.
The valves were MOU 1403, 1404 and 1405 and were being replaced due to steam leaks.
The work orders required replacement of the exisiting valves with identical valves except the replacement valves would have the stellite seats seal welded in to prevent steam cuts around the seat.
ht the time of this inspection the replacement valves had been seal welded and inspected and were being prepared for installatio RII Report Nos. 50-250/78-19 and 50-251/78-19 I-3 The inspector reviewed, the documentation for the work that had been done and visually inspected the seal welds for workmanship.
There were no items of noncompliance or deviations in this area of inspection.
6.
Inservice Ins ection Observation of Steam Generator Edd Current Testin Unit 4 At the time of this inspection the Mestinghouse inspection group had completed the Eddy Current Program for this outage and were in the process of plugging tubes.
The Eddy Current Program for this outage consisted of:
Reg.
Guide 1.83 inspection and hot and cold leg tube gauging for all three genera-tors; and rows 2-5, columns 1-92, 100KHZ test of unplugged tubes in generator C.
The results of the inspections indicated the need to plug the following number of tubes.
86 Tubes (ll ET Indications; 75 Gauging Program)
28 Tubes (All 28 Gauging Program)
62 Tubes (9 ET Indications; 53 Gauging Program)
There were no items of noncompliance or deviations in this area of inspection.
7.
Inservice Ins ection - Data Review and Evaluation (Unit 3)
The inspector reviewed the final report for the 1977 Inservice Examina-tion at Turkey Point Unit 3 which had been submitted by SwRI.
This 1977 inspection was conducted in accordance with the 1970 Edition of ASME BEZV Code Section XI, with Minter 1970 Addenda, and Reg.
Guide 1.14, Reactor Coolant Pump Flywheel Integrity.
The report was reviewed for compliance with the referenced code and Reg.
Guide requirements.
There were no items of noncompliance or deviations in this area of inspectio RII Report Nos. 50-250/78-19 and 50-251/78-19 I-4
~
Inservice Ins ection - Review of Pro ram and Procedures (Unit 4)
The inspector reviewed the Unit 4 longterm Inservice Examination Plan for Class ), 2, and 3 components and systems and the Project Plan for the 1978 Inservice Inspection.
The review included the following Southwest Research Institute Procedures:
IX-FE-103-1 Weld Joint Identification Marking on Nuclear Power Plant Piping.
IX-FE-104-1 Measuring and Recording Search Unit Location and Maximum Signal Amplitude Data During Ultrasonic Weld Examinations.
X-FE-101-0 X1VFE-102-1 On Site Not Records Control.
Examination Area Marking During the Turkey Point 4 Inservice Examination.
SwRI-NDT-200-1, Rev.
Liquid Penetrant Examination Color Contrast Method.
SwRI-NDT-300-1, Rev.
SwRI-NDT-600-3, Rev.
Magnetic Particle Inspection Procedures.
Manual Ultrasonic Examination of Pressure Piping Weld'wRI-NDT-600-30, Rev.8 Ultrasonic Examination of Pressure Retaining Welds in Ausenitic Regenera-tive Heat Exchangers.
SwRI-NDT-800-36, Rev.
Manual Ultrasonic Examination of Thin Wall Piping Welds.
SwRI-NDT-900-1, Rev.
Procedure for Visual Examination of Nuclear Reactor Components by Direct or Remote Viewing.
SwRI"NDT-900-4, Rev.
Visual Examination of Support Members and Structures for Piping, Valves and Pumps by Director or Remote Viewin RII Report Nos. 50-250/78<<19 and 50-251/78-19 I-5 There were no items of noncompliance or deviations in this area of inspection.
9.
Inservice Ins ection - Observation or Work and Work Activities (Unit 4)
The inspector observed the calibration of ultrasonic equipment prior to inspection and then observed ultrasonic inspections on Weld No.
on line 12" -RC-19 and Weld No.
1 on line 10" -RC-63.
The inspector reviewed the data sheets and the analysis of ultrasonic indications (data plots) for the two welds mentioned above and a
number of other welds.
The inspector reviewed the documentation for the QA surveillance activity by SwRI QA representative.
There were no items of noncompliance or deviations in this area of inspection.
10.
Exit Interview The inspector met with licensee and contractor representatives (denoted in paragraph 1) at the conclusion of the inspection.
The inspector summarized the scope and findings of the inspection.
There was no discussion of the finding !
h)EHORANDUN FOR:
J,. T. Sutherland, Chief, FFHS Branch, Region II FROM:
L. B. Higginbotham, Assistant Director, FFHSI SUBJECT:
'
ACCESS CONTROL TO HIGH RADIATION AREAS - TURKEY POINT (AITS F22oeeH3)
In your memo of December 19, 1978, you requested Headquarters revie~ of a citation made for conditions at Turkey Point and the licensee's wiitten objection to the citation.
This is in response to your request.
Specifically, the citation was against the technical specification that requires each High Radiation Area in which the intensity of radiation is greater than 1,000 mrem/hr to be provided with locked doors.
The citation identified the regenerative heat exchangers and reactor cavity filters, which were both within containment, as creating high radiation areas.
The reactor was shut down at this time and the containment door was unlocked and open to provide access.
The licensee responded that they did not believe the conditions cited constituted an item of noncompliance.
They stated that the reactor con-tainment was identified as a High Radiation Area>,, was maintained locked except during periods when access was required, and personnel access was controlled in accordance with 10 CFR 20,203(c)(2)(iii) when the door was not locked.
Qe Additional information was obtained from review of the inspection report, correspondence between the licensee and the Region, and discussions with one of the inspectors.
It was determined that the reactor containment was posted as a High fbidiation Area; a security guard was positioned near the containment air lock for recording dosimeter number and readings upon entry and exit of individuals into and out of containment; and the two components within containment were harrtcaded and posted as High Radiation
+-/
Areas.
~!a Interpretation of present HRC regulations and Standard Technical Specifi-cation (STS) requirements is that a licensee may establish controls (i.e., r/$ ~
locked doors, access control, 'and posting) at locations beyond the immediate boundaries of the pertinent radiation fields to take advantage of natural or existing barriers..
This means that one locked door, or one orrlc~
~1ON SURNAMd&
DATd&
ACT:
L. J.
unningham
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Based on our evaluation of the situation at Turkey Point, we do not support the Region IS citation.,"The licensee is permitted to select the containment access door for locking fn order to meet the technfca'l specification which requires locked doors for High Radiation Areas (~ 1,000 mr/hv); and the licensee fs permitted to select the containment afr lock as the point at which positive access control to a High Radiation Area is established.
Since the inspection report does not document facts to show that these conditions were not being met, a citatfon for noncompliance is not appropriate.
Although the Region appears to have had some concerns about the adequacy of the positive control exercised over personnel access to and activities within containment, this aspect, was not adequately developed and the specific citation did not reflect this concern.
In light of the licensee's positive response concerning the control of radiation exposure to their workers and the corrective action which will be taken, we see no benefit in pursuing the adequacy of the licensee's access control at this time.
Having recognized that there is a need to clarify some aspects of'he STS requirements, FFt1SI has already initiated discussion with other groups Gs a preliminary effort to obtain a change to the STS.
p Leo B. Higginbotham Assistant Director, FFNSI cc:
G. H. Smith, RI A. B. Davis, RIII G.
D. Brown, RIY H. E, Book, RV ORRICC~
SVRNAMCW DATC~
LJ unningham:
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control po)nt where pos)Ave control over personnel entry fs exercised o@y be utf'lized to establish control over mu1tfple High Radiation Areas.
Although the regu'lations refer to "each" High Radiation Area, they do not preclude the implementation of controls, over a broader area. that encompasses one or more High Radiation Areas.
1te recognize that there are-limitations to the appl)cat)on of th)s "broad area control" concept; however, these limitations are rather subject)ve and must be evaluated fn terms of the degree of'access control necessary in light of the magnitude of radfatio'n. fields, access)bil)ty to the radiation fields and other administrative 'or physical controls ut)1)zed oithfn the "broader area."
Foi example, ill the case of a sma11 room eh~le I contains components that create several discrete High Rad)at)ori Areas, barricading and posting at the entrance may be adequate without individually posting and.barricading each component; in the case of a large area wh)ch includes several ind)vidual High Radiation Areas, separate barricading and posting of the individual High Rad)atiqn Areas may be necessary to prov)de adequate personnel protection even though the total area fs posted and controlled as a ll)gh Radiation Area.
t Under the current STS there are no provisions which substitute for 20.203(c)(2)(iif).
Therefore, when entry fs necessary the control specified in 20,203(c)(2)(f)i) must be imposed.
However, the positive control required for 20.203(c){2){))f) is not defihed.
Since the STS does spell out specific controls for High Radiatfon Areas ().e, posting, barricading, RNP, and instrument), these controls can be used as a reasonable guide for the
"positive "control" which must be )mplemented in addition to providing access control which serves as a substitute for'he locked door.
For situation where a reactor containment structure fs designated as a High Radiation Area (~1,000 mr/hr), access control may be establ)shed at the access hatch for periods when personnel entries are necessary.
The degree of access control may vary based on how and where the other contro'ls are )mplemented.
For example, ff the individual High Rad)ation Areas ()1,000 mr/hr) within conta)nment are readily recognizable (e.g., posted and barr)caited),
less stringent access control is required at the hatch than if the')Wd)v)dual High Radiation Areas are not posted and barricaded.
Also, if personnel are like'ly to enter radfatfnn fields of 100 to 1,000 mr/hr while in contafment, the requirement for providing individuals with a monitoring device which continuously indicates dose rate (newer versions of the STS may allow an integrating/alarm device or monitoring prov)ded by an )nd)vidual qualified in radiation protection procedures)
must be imposed at the access hatch.
I OFFICE~
SVRHAMEW DATE~
NRC FORM 318 (9-76) NRCM 0240 Q U, 8, oovERHMEHT pRIHTINo oF psoms se78 eme earn
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MEMORANDUM FOR:
J.
H.
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W.
ATLANTA,GEORGIA 30303 SSINS:
50-250 Ogo 19 19'l8 Sniezek, Director, FFMSI, IE:H(}
PROM:
SUBJECT:
J. T. Sutherland, Chief, PFMSB, RII ACCESS CONTROL TO HIGH RADIATION AREAS-TURKEY POINT (AITS P2-2048-H3)
A recent inspection at Turkey Point resulted in an item of noncompliance for failure to lock access points to areas inside reactor containment where radiation levels exceeded 1000 mRem/hr.
The licensee's written response to the item stated that the conditions cited did not constitute an item of noncompliance since access to the containment was controlled.
This control was limited to a security guard stationed at the containment air lock. It is our opinion that the stationing of a guard at the containment air lock does not constitute the positive control over each entry required by 10 CFR 20.203-(c)(2)(iii).
We request that you review our findings and advise us of your conclusions concerning this and similar items of noncompliance.
J. T. Sutherland, Chief Fuel Facility and Materials Safety Branch Contact:
A. F. Gibson 245-5542 Enclosures:
1.
Inspection Report Nos. 50-250/78-21 and 50-251/78-,21 2.
Licensee letter dated December 1,
1978 3.
Region II letter dated December 19.',
1978 4.
Technical Specification 6.13 5.
Memo dated March 23, 1976
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