IR 05000250/1978027
| ML17338A428 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 11/30/1978 |
| From: | Elrod S, Robert Lewis, Verdery E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17338A422 | List: |
| References | |
| 50-250-78-27, 50-251-78-27, NUDOCS 7901170444 | |
| Download: ML17338A428 (12) | |
Text
APPENDIX A NOTICE OF VIOLATION Florida Power and Light Company License Nos.
DPR-31 DPR-41 Based on the results of the NRC inspection conducted on November 6-10, 1978, it appears that certain of your activities were not conducted in full compli-ance with NRC requirements as indicated below.
These items have been catego-rized as described in our correspondence to you dated December 31, 1974.
A.
Criterion V of Appendix B to
CFR 50 requires, in part, that activities affecting quality shall be prescribed by documented instructions, proce-dures or drawings.
Appendix D of the NRC approved FPRL Quality Assurance Report, commits to Regulatory Guide 1.39 (1972) and ANSI 45.2.3 (1973) in the area of plant general housekeeping and fire hazard control.
Quality Procedure 2.8 specifies that measures shall be established and imple-mented to provide cleaning and cleanness control practices at the nuclear power plant.
Contrary to the above, as of November 9, 1978, a procedure had not been developed that implemented the general housekeeping requirements.
This item is an infraction.
B.
Criterion X of Appendix B to
CFR 50, as implemented by FPRL Topical Quality Assurance Report TQR 10.0, requires, in part, that a program for inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with documented instructions, procedures and drawings.
Quality Procedure QP 10.3 specifies that plant activities requiring periodic QC surveillance shall include cleanliness and housekeeping practices.
Contrary to the above, as of November 9, 1978, the licensee could pro-duce no evidence of completed periodic QC surveillances of cleanliness and housekeeping practices.
This item is an infractio ~p h
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RII Rpt. Nos. 50-250/78-27 and 50-251/78-27 DETAILS I Prepared by:
E
. Verdery, React Inspector R actor Projects Sec ion No.
Reactor Operations and Nuclear Support Branch fj3uz Da e
Dates of Inspection:
November 6-9, 1978 Reviewed by: E.C.
R.
C. Lewis, Chief Reactor Projects Section No.
Reactor Operations and Nuclear Support Branch Date 1.
Persons Contacted Florida Power and Li ht Com an H. E. Yaeger, Plant Manager-J.
K. Hays, Plant Superintendent, Nuclear-J.
E. Moore, Operations Superintendent, Nuclear
- V. B. Wager, Operations Supervisor, Nuclear
-"P. J. White, Maintenance Superintendent-D.
W. Jones, equality Control Supervisor-R. J.
Spooner, equality Assurance Operations-W. R. Williams, Assistant Superintendent, Electrical Maintenance-T. P. Mendieta, IRC Department Supervisor-K. E. Beatty, Training Supervisor-T. A. Finn, Nuclear Plant Supervisor
- J.
M. Puckett, Assistant H.P. Supervisor-H. F. Story, Corporate H.P.,
General Office-G. D. Whittier, Licensing Engineer, General Office
- J. R. Pendland, Licensing Engineer, General Office The inspectors contacted several operators and technical support personnel not listed.
-Denotes those attending the exit interview.
2.
Licensin Action on Previous Ins ection Findin s (Open)
Infraction (250/78-02-02, 251/78-02-02):
Failure to establish and implement adequate administrative practices for logs of plant operation.
The inspector reviewed the licensee's revision to AP 0123.1,
RII Rpt. Nos. 50-250/78"27 and 50-251/78-27 I-2 Maintaining Operating Logs and Records, dated May 2, 1978.
Based upon the discussion detailed in paragraph 6,
the corrective action taken by the licensee is not considered adequate to prevent recurrence.
(Closed)
Deficiency (250/78-12-01, 251/78-12-01):
Failure to document proper approval of plant work orders (PWO).
The inspector reviewed several recently completed PWO's which had been performed on both units and verified that the Nuclear Supervisor's signature block had been properly filled in.
(Closed)
Deficiency (250/78-12-02, 251/78-12-02):
Failure to document operational release of PWO's.
The inspector reviewed the licensee's corrective action to this item which included the issuance of a letter by the plant manager to all department heads and supervisors (PTP-(}C-78-106, dated October 2, 1978) instructing them as to the proper method to document the release of safety related equipment by the operations personnel.
Additionally, the inspector reviewed the rev'ision to AP 0190.19, Control of Safety Related Maintenance, dated November 7, 1978, which will formally implement these requirements.
The inspector also reviewed several recently completed PWO's and verified that opera-tional release for those maintenance activities had been properly documented.
3.
New Unresolved Items None identified.
4.
Exit Interview The inspector met with licensee representatives (denoted in paragraph 1)
at the conclusion of the inspection on November 9, 1978.
The scope and findings of the inspection were summarized.
During the exit interview the senior licensee representative was informed that four unresolved items were identified during the inspection.
Subsequent to the inspection on November 20, 1978, the inspector telephoned the licensee and informed him that three of the unresolved items were determined to be items of noncompliance and one was downgraded to an open item.
Licensee Management indicated that some monitoring of plant housekeeping had been documented; however, it was not part of a programmed gC surveillance activity.
5.
Housekee in and Cleanliness Control a.
The inspectors reviewed the facility housekeeping program to verify that the requirements in the FPL TAHAR had been implemented.
equality Procedure 2.8, Cleanliness Control Methods, the references require-
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RII Rpt. Nos. 50-250/78-27
'nd 50-251/78-27 I-3 ments in Reg Guide 1.39 (1972)
and ANSI 45.2.3 (1973)
and states in part that" measures shall be established and implemented to provide cleaning and cleanness control practices at the nuclear power plant.
This shall include removal of combustible material and debris and assurance that adequate fire prevention and protection measures are in effect.
Discussion with licensee personnel and a
review of existing plant procedures indicated that no formal program for plant housekeeping existed as of November 9, 1978.
The current unwritten policy is that personnel will pick up after themselves and that Maintenance personnel will restore areas disturbed by them prior to completing their work.
Some specific procedures have cleanliness hold points; however, these generally address only safety related system cleanliness and not general housekeeping or removal of combustible materials.
The most significant discrepancy noted in the licensee's program was the lack of designated respon-sibilities as to which department or individuals were responsible for maintaining the housekeeping in a particular plant area.
Failure to formally implement a general housekeeping program is considered to be an infraction (250/78-27-01, 251/78-27-01).
b.
The FPL Quality Assurance Manual QP 10.3 Inspection and Surveillance of Maintenance Activities, Operations and Fuel Handling, paragraph 5.5 specifies required periodic QC surveillance of cleanliness and housekeeping.
The inspectors requested the licensee to provide them with the completed surveillance sheets covering this area.
As of the date the inspection was completed, the licensee was not able to produce any evidence that these surveillances had taken place.
Failure to conduct QC surveillance in accordance with the stated requirements is considered to be an infraction (250/78-27-02, 251/78"27-02).
6.
Plant 0 erations - General The inspectors reviewed general plant operations of both units including an examination of selected operating logs, special orders, jumper and clearance logs and equipment out-of-service logs for the period September 13, 1978, through November 6, 1978:
This inspection was made to determine compliance with Technical Specifications, Regulations and licensee procedures.
a.
Recorder Charts AP 0123.1, Maintaining Operating Iogs and Records, paragraph 8.5, subparagraph 2 requires that recorder charts have the lead pen set at the correct time at least once per day.
At 6:30 p.m. on November 7, 1978, the following examples were observed by the inspector and recorded to demonstrate that recorder charts are not being set to the correct time:
RII Rpt. Nos. 50-250/78-27 and 50-251/78-27 I-4 Recorder Number Function Recorder Time 334 336 337 338 333 328 Insertion Limit 6 Rod Postion, Bank A Insertion Limit 6 Rod Positon, Bank C
Insertion Limit S Rod Position, Bank D Steam generator, A, B, C Wide Range Level Selected Loop bT, Overtemperature bT Setpoint, Overpower hT Set Point Power Range Channels 364 (Upper)
9:30 p.m.
10:15 p.m.
10:25 p.m.
5 November ll:10 p.m.
1:05 p.m.
8:40 p.m.
b.
Lo Content and Reviews Numerous discrepancies in the content and review of reactor plant logs were noted.
Most could be traced to the lack of a definitive log-keeping program which defines what logs are quality records, how they are to be maintained, and when and by whom they are to be reviewed and signed.
The examples listed below indicate that this problem is pervasive and in need of significant attention:
(1)
AP0123.1, paragraph 8.3 states that all spaces on Log Sheets must be completed or explained by an entry in the blank space.
Examples of missing entries are:
NCCO Data Log Unit 4, ll/02/78 Diesel B Meter Start Up Transformer Electrical Output Per Shift Boric Acid Integrator Primary Water Integrator NCCO Data I.og Unit 4, 11/01/78 Electrical Output Per Shift Boric Acid Integrator Primary Water Integrator Peak Shift Operator's Signature Turbine Operator Log Unit 4, 11/Ol/78 Sevsral Missed Entries Auxiliary Building Log Units 364, 11/06/78 Missing Entries on Sheets-1, 2,
and
Turbine Operator Log Unit 4, ll/06/78 Several Missing Entries Intake Log Peak Shift Operator's Signature
RII Rpt. Nos. 50"250/78-27 and 50-251/78-27 I-5 (2)
AP 0123.1, paragraph 8.2.2 states that Reactor Coolant Boron Concentration (RCS Cb),
Tavg, Pressure, Power Level, and Rod Position shall be entered in the Nuclear iControl8 Center Operator's Log when the power level is steady at
amps in the intermediate range on startup.
Examples of missing entries are:
6:54 p.m.
9:37 a.m.
7:48 p.m.
October 14, 1978 Boron Concentration October 6, 1978 No Entry October 13, 1978 Boron Concentration (3)
AP 0123.1, Paragraph 8.3.2, explains the relationship between the Nuclear Plant Supervisor's (NPS)
I.og and the Nuclear Control Center Operator's (NCCO) Log.
Basically the NCCO Log reports events; the NPS Log explains and amplifies, e.g.,
causes of events, corrective actions to repair, etc.
Examples of data missing from the NPS Log are listed below:
(a)
On 9/23/78, 3B2 Circ Water Pump motor operated valve tripped
- breaker could not be rese't (NCCO Log).
No mention of this was made in the NPS's Log.
(b)
On 10/5/78, Unit 3 RCS leak rate was greater than lgpm and ABC charging pump vents were found open.
The NPS Log did not explain the circumstances or corrective action.
(4)
Paragraph 8.2 of AP 0103.2 entitled "Duties and Responsibilities of Operators on Shift", requires that the oncoming shift read applicable watch station logs through the last entry and initial the log accordingly.
The records do not reflect that the Nuclear Watch Engineers have not consistently done this.
Examples of failure to initial the log are listed below:
(a)
NPS Log - Shift 1, September 13, 15, 19, 26, 29, October 3, 10, 17, 24, and 28.
(b)
NPS Log - Shift 4, October 16, 19-25, October 30 - November
and 7.
(c)
NCCO Log - Shift 3, September 30, October 1, 4-9, 12-18, and 23-28.
(5)
The Nuclear Control Center Operator's (NCCO)
Data Log has a
review block on sheet (1) for the midnight shift Nuclear Plant Supervisor to indicate review of the preceeding day's entries.
In addition to the missing entries shown in paragraph (1)
above, the log has not been routinely signed or initialed
RII Rpt.
Nos. 50-250/78-27 and 50-251/78-27 I-6 indicating that it had been reviewed.
A sampling obtained from Document Control indicated that for November
and 2,
1978, neither Unit 3 nor Unit 4 NCCO Data Logs were initialed.
c.
E ui ment Out-Of-Service Lo Paragraph 8.2 of AP 0103.2, requires oncoming shift Nuclear Control Center Operators to review the Equipment Out-of-Service (EOOS)
Logs to determine the status of equipment under their cognizance.
Main-tenance of this log is not addressed in any nuclear "plant admin-istrative procedure.
At 6:00 p.m.
on November 6, 1978, only three outstanding items were listed in the EOOS Log, yet fourteen (14)
work clearances stamped as Nuclear Safety Related were outstanding.
The licensee was previously cited for failure to establish and implement adequate administrative policies to assure that logs of plant operations are sufficient to reconstruct significant events (IE Inspection Report 50-250/78-02 and 50-251/78-02).
In response to that item of noncompliance the licensee stated that many other types of records were available at the plant which would document the information and data the inspector thought was missing.
A follow-up of the licensee's response conducted during this inspection and documented in paragraph 6.a-c reveal that this information is not readily available and that the quality of the
.logs and operational records in general are not maintained or adequately reviewed.
Therefore, the inspector concludes that noncompliance cited in Inspection Report Nos. 50-250/78-02 and 50-251/78-02 did occur as stated and the information noted above is further evidence that the licnesee's log and operational record-keeping program does not meet regulatory requirements.
In response to the inspector's concern regarding log-keeping and setting of recorder strip charts, the licensee issued a Special Instruction addressing the proper entries in the NCCO's log and the requirement to properly annotate and set the strip charts on a daily basis.
This noncompliance remains open and will be followed up following receipt of the licensee's response (250/78-02-02, 251/78-02-02).
7.
Re ortable Events Follow-U The following reportable events were reviewed to ascertain that:
(1)
reporting requirements of Technical Sepcification 6.9.2 were met; (2)
corrective action was taken as required by Appendix B to
CFR Part 50; (3)
the event was reviewed and evaluated; and
RII Rpt. Nos. 50-250/78-27 and 50-251/78-27 I-7 (4)
the facility was operated within the requirements of
CFR 50.59 and the Technical Specification subsequent to the event.
a
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50-251/78-06, "Pressurizer Relief Tank Rupture Risk (PRT) Failure".
The inspector verified that the corrective action specified in this report had been completed during the most recent Unit 4 refueling outage.
The rupture disc was replaced and the PRT drain valve repaired.
This closes open item 251/78-12-09.
b.
50-251/78-09, "Failure of 20 Hydraulic Snubbers".
c.
50-251/78-10,
"Spent Fuel Pit Cooling Pump Failure".
d.
50-251/78-11,
"MSIV Solenoid Valve Failure".
e.
50-250/78-14,
"Steam Line Flow Comparator Failure".
8.
Plant Tour The inspectors toured various areas of the facility to observe operations and activities in progress, to inspect the general state of cleanliness, housekeeping, adherence to fire protection rules, to check the position of selected valves and breakers, to check proper administration of the equipment clearance order system, and to review with operators the status of various annunciators which were activated.
The inspectors noted that the housekeeping in selected areas, e.g.,
the entrance to the waste Holdup Tank Room, had deteriorated.
This was discussed at the exit interview.
Additionally, this situation led the inspectors to inquire about the QC surveillance being performed in accordance with'R 10.3., discussed in paragraph 5.b.
As part of the tour, the inspectors reviewed the condition of cable tray ebs. 3FDT 10 and 3FCT 40 in the Waste Holdup Tank area 4 ft elevation immediately beneath the floor drain from the 10 ft. elevation.
This problem was first identified in IE Report 50-250/78-26 and 50-251/78-26.
These cables were coated with boric acid precipitates which have been collecting on top of the cables for some time.
The licensee had attempted to shield the cable from the leakage using metal shielding and poly sheeting.
This temporary protection has not been effective.
The licensee indicated that current plans were to repair the leaking drain during the Unit 3 refueling outage scheduled for late December 1979.
The inspector requested that the licensee take more prompt action to remove the boric acid crystals from the cable trays'nd improve the temporary methods being used to divert the leakage.
The licensee agreed to expedite his corrective actio ~
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RII Rpt. Nos. 50-250/78-27 and 50-251/78-27 I-8 i
These cables supply safety-related equipment and as such are rated for a boric acid environment for accident conditions; however, it is not known whether these cables can be continuously exposed to that type of environ-ment over long periods of time without some insulation breakdown.
Also, the cable trays are experiencing some deterioration from the prolonged exposure to the boric acid.
This item will remain open (250/78-27-03 and 251/78-27-03).
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