IR 05000250/1981017
| ML17341A607 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 09/02/1981 |
| From: | Evans C, Hosey C, Wray J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17341A601 | List: |
| References | |
| 50-250-81-17, 50-251-81-17, NUDOCS 8111130501 | |
| Download: ML17341A607 (51) | |
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UNITED STATES UCLEAR REGULATORY COMMISSIO
REGION II
101 MARIETTAST., N.W., SUITE 3100 ATLANTA,GEORGIA 30303 Report Nos. 50-250/81-17 and 50-251/81-17 Licensee:
Florida Power and Light Company 9250 West Flagler Street Miami, FL 33101 Facility Name:
Turkey Point 3 and 4 Docket Nos. 50-250 and 50-251 License Nos.
DPR-31 and DPR-41 Inspection at Turkey o'
site near Homestead, Florida Inspectors:
J.
R. Wray C. D.
E an te ign d
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Date Sig ed Accompanying Personnel D. Stamey Approved by:
C. M.
H se Acting ection Chief ate Sig ed Engineering Inspecti n Branch Engineering and Tech ical Inspection Division SUMMARY Inspection on August 17-21, 1981 Areas Inspected This routine, unannounced inspection involved 99 inspector-hours onsite in the areas of health physics appraisal follow-up and review of the health physics program for the Steam Generator Replacement, project including training, organization and qualifications, instrumentation, exposure control and surveys.
Results Of the two areas inspected, no violations or deviations were identified in one area; one violation was found in one area ( Failure to post notices for workers Severity Level VI).
8iiii3050i 8iii03 PDR ADOCK 05000250 PDR
REPORT DETAILS 1.
Persons Contacted Licensee Employees
'H. E. Yaeger, Site Manager
"J. K. Hayes, Plant Manager Nuclear
- J. E. Moore, Operations Superintendent - Nuclear J.
L. Danek, Corporate Health Physics R. Spooner, Corporate Quality Assurance
- P. W. Hughes, Health Physics Supervisor
- S. M. Feith, Quality Assurance Operations
- D. W. Jones, Quality Control Supervisor
~T. S. Peck, Health Physics Administrative Supervisor J.
R. Bates, Health Physics Operations Supervisor
~R. Brown, Health Physics Operations Supervisor
~J.
H. Hopkins, Health Physics
- F. Marder, Health Physics
- D. Cooper, Health Physics NRC Resident Inspector
- W. C. Marsh, Resident Inspector
- Attended exit interview Exit Interview The inspection scope and findings were summarized on August 21, 1981 with those persons indicated in paragraph 1 above.
The Site Manager acknowledged the apparent violation.
The inspector stated that the documents specified in 10 CFR 19. 11 or a notice statin'g where these documents could be reviewed should be posted as a
minimum at each entrance to the Radiation Control Area.
In response to an inspector's question regarding Nuclear Power Plant Staff work hours ( IE Circular 80-02)
and its effect on the health physics department, the Site Manager stated that the suggestions in the circular are applied to the operations staff and not health physics personnel.
Nonetheless, it was his belief that an adequate health physics staff exists to preclude deteriorated health physics coverage due to excessive work hours.
3.
Licensee Action on Previous Inspection Findings (Closed)
Deviation (81-12-01)
Containment Purge Exhaust Filters.
The inspector reviewed the license's response dated July 31, 1981 (FP and L
letter L-81-331) and by visual inspection verified the containment Purge
Exhaust filters had been replaced.
In addition, the inspector verified that a
routine preventive maintenance and surveillance program has been established.
Unresolved Items, Unresolved items were not identified during this inspection.
Licensee Action on Previous Inspector Follow-up Items (Closed)
(77-CI-14)
Separation of Contaminated Mater Systems from Non-Contaminated Plant systems.
The inspector reviewed records and verified that the circular was reviwed by appropriate site personnel to ensure that contaminated water systems were separated from non-contaminated plant systems.
(Closed)
(78-BU-08) Radiation Levels From Fuel Element Transfer Tubes.
The inspector reviewed records, inspected the area in the unit 3 containment building in the vicinity of the transfer tube and verified the radiological surveys and controls required by the bulletin have been taken.
(Closed)
(78-CI-03)
Packaging Greater Than Type A (}uantities of Low Specific Activity Radioactive Naterial for Transport.
The inspector examined records, reviewed procedures for shipment of radioactive materials, discussed with the licensee representatives the plant program for radwaste shipments and verified that Type A quantities of LSA radioactive material is shipped in the appropriate package.
(Closed)
(80-BU-03)
Loss of charcoal from standard type II, 2 inch, tray absorber cells.
The inspector examined the licensee's response to this bulletin and verified that charcoal has not been lost and the plant's equipment is such that no charcoal is expected to be lost from the absorber cells.
(Closed)
(80-BU-10) Contamination of nonradioactive system and resulting potential for unmonitored, uncontrolled release of radioactivity to environment.
The inspector examined the review of potentially unmonitored and uncontrolled release points conducted by the licensee in response to the bulletin, noted the routine, periodic sampling program established for the release pathways of concern, and had no further comments.
(Closed)
(80-CI-14) Radioactive contamination of plant demineralized water system system and resultant internal contamination of personnel.
The inspector examined records indicating that appropriate site personnel reviewed the circular and verified that appropriate actions were taken.
(Closed)
(80-17-08)
Review of contents of training program.
The inspector reviewed a letter indicating that a written report of the effectiveness of the plant's general employee health physics red badge training course would
be completed on September 18, 1981, by the Manager, Organization Development and Training (Corporate)
who had conducted the evaluation on June 30 and July 1, 1981.
Licensee representatives stated that improvements have already been initiated.
The inspector had some addition comments concerning detailed technical issues ( see paragraph 6a).
This item is closed for record purposes.
(Closed)
(80-17-11)
Record System for Bullard Type Air Filters.
The inspector examined data sheets indicating that an inspection and record systm has been established for Bullard filters.
(Closed)
(80-17-26)
Methyl Iodine Testing.for Charcoal Samples From Emergency Ventilation Systems.
The inspector reviewed the licensee's response to this item indicating the effectiveness of the elemental iodine test conducted in accordance with ANSI N510-1975 and plant procedures on the plant'
containment building recycle emergency filter units.
The inspector examined records of filter efficency tests and had no further questions.
(Closed)
(80-17-28)
Hard piping of portable demin system.
The inspector discussed the licensee's liquid radwaste processing system.
Licensee representatives stated that approval has been obtained to provide hard piping for the portable demineralization system.
In addition, the inspector reviewed a letter indicating that work will begin on eliminating the contract portable liquid process system while using inhouse demineralizers.
A long range study will be conducted concerning upgrading the on-site liquid radwaste system.
(Closed)
(80-17.-31) Activity estimation for new compactor.
The inspector examined a letter establishing the licensee's methodology for estimating activity in the CGR compactor, discussed the incorporation of this method into a procedure and had no further questions.
(Closed)
(80-17-34)
Reverification of high calibration point on instrumentation calibrator.
The inspector verified that the source in question is not used for instrument calibrations.
In addition, the inspector verified that the licensee has obtained a condenser R-meter with which they can perform the needed source calibration test if required in the future.
(Closed)
(80-17-37)
Functional checks of instrumentation.
The inspector reviewed changes to HP-13, Portable Survey Instruments and examined a jig to be used for functional checks of instruments when they are issued to workers.
The inspector stated that instruments continuously used by health physics personnel should also be functional checked at least daily.
The inspector had no further comments.
(Closed)(80-17-38)
Changes to procedures.
The inspector reviewed changes to HP-13, Portable Survey Instruments, and HP-60, Respiratory Protection Manual, and verified that the recommended changes have been made.
(Closed)(81-12-02)
Instrumentation for compactor HEPA filter.
The inspector examined the installed differential pressure gauge on the CGR compactor HEPA filtration unit and had no further questions or comments.
(Closed)(81-12-03)
Air flow out of Unit 3 equipment hatch.
During tours of the Unit 3 containment building, the inspector verified that air flow in through the equipment hatch has been established.
A licensee representative stated that the containment building supply had been converted to an additional purge exhaust path thereby requiring air to be supplied to the containment building only through the open personnel, emergency and equipment hatchs.
In addition, the startup procedures will be changed to ensure equal supply and exhaust when the containment building purge is rated down to 30 percent..
6.
Steam Generator Replacement Project (SGRP)
(a)
Organization, gualifications and Training.
The inspector reviewed the organization of the health physics department a'nd the effect that SGRP has had upon it.
Addit,ional contract health physics tecnicians have been brought in to provide adequate job coverage.
Individual jobs are covered by contract personnel and report to licensee shift foremen.
The inspector found no problems with the reporting chai r of technicians assigned to SGRP but questioned the licensee'
capability to satisfy the recommendation of IE circular 80-02 with regard to maximum staff work hours.
Licensee representatives stated that in their opinion IE circular 80-02 applied only to control room operating personnel and not to health physics technicians and supervisory employees.
Nontheless, the licensee stated that care will be taken to ensure that the quality of the plant's radiation protection program will not be compromised due to overwork.
The inspector reviewed resumes and qualifications of contract health physics employees technicians.
Health physics personnel in responsible positions appear to meet the requirements specified in ANSI 18. 1-1971 Junior technicians are used for decontamination activities, outside radioactive material handling activities and dose control work.
All junior technicians report directly to a senior lead technician who has passed written and oral tests and been approved by a three man examination based on plant procedures and specific health physics problems.
An inspector attended the two-day general employee health physics red badge training course on August 18 and 19, 1981.
The course covers
CFR 19,
CFR 20, the health physics manu'al and plant procedures.
The inspector was aware that the program was undergoing certain changes as a result of an audit conducted by the corporate office (see 80-17-08 paragraph 5).
In addition, the inspector suggested the following changes be made:
(1) obtain a more relevant film to replace
A is for Atom, (2) increase emphasis on radwaste reduction, (3) improve instructions on wearing and removal of protective clothing, and (4)
include discussion of
CFR 19. 11.
The inspector also attended the licensee's respiratory protection training and had no comment.
During tours of the plant, the inspectors determined that workers entering the radiation control area (RCA)
through the Nuclear Maintenance building were not able to review
CFR 19,
CFR 20, the license, or the operating procedures; nor was a
notice posted describing these documents and stating where these items may be examined.
In addition, on July 17, 1981, a Notice of Violation was issued concerning a radiological incident and was not posted within two days of receipt.
Further, on July 22, 1981, an order to suspend use of a fuel element transfer cash NFS-4 was issued and was not posted as of this inspection.
The inspector informed licensee management that the above instances are three examples of failure to comply with the requirements of 10 CFR 19.11 (81-17-01).
Surveys and Instrumentation The inspectors selectively examined records of radiation contamination, and air surveys performed since June 15, 1981.
It appeared that an adequate number of surveys have been taken.
Survey results indicate that most areas of the containment building have been decontaminated and maintained at less than 1000 dpm/100 sq.
cm. Air sample results indicate no air problems although local air activity is anticipated when cutting of the steam generators begins.
The inspector reviewed the health physics isotopic analysis (GELI)
system recently turned over to the department on June 21, 1981.
The inspectors asked the licensee to compare analysis capabilities for an air sample between the established chemistry system and the health physic department's equipment.
Results of the comparison check indicate that improvements must be made to the.health physics system prior to use for the SGRP.
The inspector recommended that the requirements of Regulatory Guide 4. 15 with regard to the establishment of an approval quality assurance program and calibration/source records.
In addition, the inspector suggested that additional people be trained to operate the unit and improve the technical knowledge of the persons responsible for review of the system's results.
The inspector stated that this item will be examined during future inspections (81-17-02).
Exposure Control The inspector reviewed the exposure control program established for the SGRP.
The computerized program is operational and appears to provide positive access control into the RCA.
Workers entering =the RCA through the Nuclear Maintenance building have their TLO and RWP number entered
into the computer by health physics technicians who authorize issuance of a pocket dosimeter and entrance into the RCA based upon the computer response.
Personnel restrictions are programmed into the computer by supervisory personnel for reasons including approaching a dose limit.
Upon exit of the RCA, a health physics techician reads the workers'ocket dosimeter and enters this dose under the workers'LO and RWP number.
In this manner as up to the minute dose history can be maintained by workers and RWP.
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Florida Poorer and Light Company MWPLK@cogx, ATTN:
Dr. R. E. Uhrig, Yice President, Advanced Systems and Technology P.O.
Box 529100 Miami, FL 33152 Gentlemen:
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Subject:
Inspection Rpport Nos.
-250/81-16 a d 50-251/81-16 Thank you for your letter of August 17, 1981, informing us of steps you have taken to correct the violations concerning activities under NRC Operating License Nos.
DPR-31 and DPR-41 brought to your attention in our letter of July 17, 1981.
Me vill examine your corrective actions and plans during subsequent inspections.
He appreciate your cooperation With us.
Sincerely, Ass Paul J. Kellogg, Chief Reactor Projects Branch
Division of Resident and Reactor Project Inspection cc:
J.
K. Hays, Plant Manager bcc:
NRC Resident Inspector Document Management Branch State of Florida gyral RII:
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SURNAME 8/~(81..
OATE NRC FORM 318 (10.80) NRCM 0240
'OFFICtAL RECORD COPY
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FLORIDAPOWER & LIGHTCOMPANY August 17, 1981 L-81-358 Mr. James P. O'Reilly, Director, Region II Office of Inspection and En'forcement U. S. Nuclear Regulatory Commission 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303
Dear Mr. O'Reilly:
Re:
Turkey Point Units
8 4 Docket Nos.
50-250, 50-251 IE Ins ection Re ort 81-16 Florida Power
& Light Company has reviewed the subject inspection report and a response is attached.,
There is no proprietary information in the report.
Very tr ly yours, Robert E. Uhrig Vice President Advanced Systems 5 Technology REU/PLP/ras cc:
Harold F. Reis, Esquire IS>09095't> P PEOPLE... SERVING PEOPLE
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Re:
Turkey Point Units 3 and
Docket Nos. 50-250, 50-251 IE Inspection Re ort 81-16 ATTACHMENTS FINDING A:
Technical Specification 6.8.1.
requires that written procedures be implemented.
Administrative procedure 11550. 1, "Health Physics Procedure HP-1" requires that a Radiation Work Permit or direct Health Physics coverage be provided for work on equipment contaminated in excess of 10,000 dpm/100 cm".
Contrary to the above, neither direct coverage nor a Radiation Work Permit was provided for removal of the Unit 3 liquid release line which was internally contaminated to 20,000 dpm/100 cm for about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> on June 3, 1981.
RESPONSE A:
(A-1)
FPL concurs with the finding.
(A-2)
(A-3)
(A-4)
This incident happened due to construction shift relief and Health Physics'elief occurring when a portion of Unit 3 liquid release line was being moved.
The HP technician left the area before being relieved.
As corrective action, a Radiation Work permit was issued to cover the work required.
As corrective action to avoid further problems, the Health Physics Shift Supervisor reinstructed the KP Technician involved concerning our requirements whenever direct coverage is provided and also the importance of maintaining proper surveillance of the assigned work area.
(A-5)
Full compliance was achieved July 31, 1981.
FINDING B:
CFR 50, Appendix B, Criterion V
and the accepted gA Progr am Technical gual ity Requirement 5. 0 requires that activities affecting qual ity be prescribed by documented procedures and shall be accomplished in ac'cordance with these procedures.
Administrative Procedure 0190.72, Receipt Inspection, Identification and Control of Nuclear Safety-Related and Fire Protection parts, Materials and Components, requires issuance and attachment of guality Control (gC) tags to acceptable controlled material until installation in the plant system.
Contrary 'o the above, A.P.
0190.72 was not followed in that during the inspection period the information on qC tags attached to several items including 3/4 inch T-78 globe valves and Pacific Scientific Company mechanical snubbers was irtaomp1efe and erroneous.
This lack of information disabled the traceabil.ity system of the items to purchase order, receipt and procurement documents.
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Turkey Point Units 3 and
Docket Nos. 50-250, 50-251 IE Ins ection Re ort 81-16 Page
RESPONSE B:
(B-1)
FPL concurs with the finding.
We have not been able to determine the reason for the discrepancies on the tags.
The material had almost certainly been properly tagged at time of receipt as evidenced by receipt inspection reports with all required information noted.
.Tags may have been lost or prematurely removed, but this was impossible to verify.
As corrective action all material with defective gC tags was removed from the gC Storage Area.
(B-4)
As corrective action in order to avoid further problems, the Plant Manager
-
Nuclear issued a. letter directing plant personnel to properly handle gC tags.
(B-5)
Full compliance was achieved by August 4, 1981.
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STAT" OF FLORXDA
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being first duly sworn, deposes and says:
'I That he is Executive Vice President
~of Florida Power
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Light Company, the 1 censee herein; That he has executed the foregoing document; that. the state-ments made in this said document are true and correct to the best. of his knowledge, information, and belief, and that he is authorized to execute the document on behalf of said E. A. Adomat Sub cr.'bed and sworn to before me this I,I,-'d. y of r is fj rNQ".tArZ.PUBLXCr i and for the County of Dade, State of Florida Notary pubac, State of Florida at large My Commission Expires October 30, 1983 Ny commission expires:
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JUL 1 7 1981 Florida Power and Li~ht Company ATTN:
Dr.
R.
E. Uhrsg, Vice President Advanced Systems and Technology P.
O. Box 529100 Miami, FL 33152 Gentlemen:
Subject:
Repor t Nos-250/81-16 nd 50-251/81-16 This refers to the routine inspection conducted by Mr. A. J. Ignatonis of this office on May 26 June 25, 1981, of activities authorized by NRC Operating License Nos.
DPR-31 and DPR-41 for the Turkey Point facility.
Our preliminary findings were discussed with Mr. J.
K. Hays, Plant Manager, at the conclusion of the inspection.
Areas examined during the inspection and our findings are discussed in the enclosed inspection report.
Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspectors.
I During the inspection, it was found that certain activities under your license appear to violate NRC requirements.
These items and references to pertinent requirements are listed in the Notice of Violation enclosed herewith as Appendix A.
Elements to be included in your response are delineated in Appendix A.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed report wi 11 be placed in the NRC's Public Document, Room.
'f the report contains any information that you believe to be exempt from disclosure under
CFR 9 '(a)(4), it is necessary that you:
(a) notify this office by telephone within ten days from the date of this letter of your intention to file a request for withholding; and (b) submit within twenty-five days from the date of this letter a written application to this office to withhold such information. If your receipt of this letter has been delayed such that less than seven days are available for your review, please notify this office promptly so that a
new due date may be established.
Consistent with section 2.790(b)(1);
such application must be accompanied by an affidavit executed by the owner of the information which identifies the document or part thereof sought to be withheld, and a full statement of the reasons on the basis of which it is claimed that the information should be withheld from public
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disclosure.
This section further requires the statement to address with specificity the considerations listed in
CFR 2.790(b)(4).
The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear from you in this regard within the specified periods noted above, the report will be placed in the Public Document Room.
Should you have any questions concerning this letter, we will be glad to discuss them with you.
Sincerely, Wd'rKin Paul J. Kellogg, Acting Chief Project Branch 2, Division of Resident and Reactor Project Inspection
Enclosures:
1.
Appendix A, Notice of Violation 2.
Inspection Report Nos. 50-250/81-16 and 50-251/81-16
REGION I I 101 MARIETTAST., N.W., SUITE 3100 ATLANTA,GEORGIA 30303 Report Nos.
50-250/81-16 and 50-251/81-16 Licensee:
Florida Power and Light Company 9250 West Flagler Street fliami, FL 33101 Facility Name:
Turkey Point Docket Nos.
50-250 and 50-251 License Nos.
DPR-31 and DPR-41 Inspection at Turkey Point site near Homestead, Florida Inspectors:
A. J. Ignat nis, S
i r Resident Inspector D te igned W.
C.
I rsh, eside Inspector Approved by:
H.
C.
Dance, Section C ief, Division of Resident and Reactor Project Inspection SUMMARY Inspection on May 26 - June 25, 1981 Areas Inspected Da e gned
/vY Da e Si ned This routine inspection involved 188 resident inspector-hours on site in the areas of (1) followup on IE Bulletins; (2) followup on licensee event reports (3)
licensee's program review of receipt, storage, and handling of safety-related items; (4) post implementation review of NUREG-0737 items; (5) use of two-way communication radios in Safeguards Equipment rooms; (6) verification of action taken in response to grder concerning primary coolant system pressure isolation valves; (7) followup on containment venting and purging operations; (8) plant operations; and (9) plant tours.
Results Of the nine areas inspected, no violations or deviations were identified in seven-areas; two violations were found in two areas (Violation - failure to follow administrative procedure on receipt, storage and handling of safety-related equipment - paragraph 7; Violation - failure to implement provisions of procedure
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regarding issuance of a Radiation Work Permit - paragraph 13.)
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DETAILS 1.
Persons Contacted Licensee Employees H.
E.
"J.
K.
- J
- D. W.
- J P
- D. W.
B. A.
V. B.
J.
C.
- R. E.
- S.
M.
- J J
Yaeger, Site Manager Hays, Plant Manager - Nuclear Moore, Operations Superintendent
- Nuclear Hasse, Technical Department Supervisor Lawman, I&C Department Supervisor Jones, QC Supervisor Abrisham, Systems Test Engineer Wager, Operations Supervisor Galaguero, Licensing Engineer Tucker, QA Engineer Feith, QA Supervisor Sullivan, QC Mechanical Engineer Other licensee employees contacted included construction craftsmen, technicians, operators, security force members, and office personnel.
- Attended exit interview 2.
Exit Interview
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The inspection scope and findings were summarized on June 26, 1981, with those persons indicated in Paragraph 1 above.
The Plant Manager acknow-
'ledged the stated violations.
3.
Licensee Action on Previous Inspection Findings Not inspected.
4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
Followup on IE Bulletins The following Bulletins were reviewed to determine whether they had been received and reviewed by appropriate management; responses, where necessary, were accurate and complete; and that, if required, action was taken and was complete and appropriate.
a.
(Closed)
IEB 81-02, Failure of gate type valves to Close Against Differential Pressure.
Licensee confirmed in his response that Turkey Point had been correctly omitted from the bulletin list of plants that had obtained W-EMD or BW-NVD valves (L-81-204 dated May 14, 1981).
The inspector verified that the PORV block valves are made by Velan, and
I
spot checked the plant valve index for the subject valve types with negative results.
b.
(Closed)
IEB 81-03, Flow blockage of Cooling Water to Safety System Components by Corbicula SP. (Asiatic Clam)
and Hytilus SP.
(Mussel).
The licensee noted in his response (L-81-231 dated May 28, 1981) that the Asiatic Clam is primarily a fresh water cresture and not suited to the salt water cooling system at Turkey Point.
The licensee further noted that the Mytilus cannot exist in prolonged exposures to temperatures greater than about 66'F.
It is unlikely that the cooling canals at Turkey Point cool down to that temperature more than a few days each winter.
Summer canal temperatures range 95'-105'F.
The inspector has observed various heat exchangers throughout the plant during routine cleaning and has not observed clam or mussel fouling of any type.
6.
Licensee Event Report (LER) Followup The following LER's were reviewed and closed.
The inspector verified that reporting requirements had been met, causes had been identified, corrective actions appeared appropriate, generic applicability had been considered, arid the LER forms were complete.
Additionally, for those reports identified by asterisk, a more detailed review was performed to verify that the licensee had reviewed the event, corrective action had been taken, no unreviewed safety questions were involved, and violations of regulations or Technical Specification conditions had been identified.
- 250-81-09 Incomplete Tripping of All Bistables Associated with N-43 Channel 250-81-10 250-81-11
- 251-81-07
"3A" Component Cooling Water Pump Breaker in Trip Mode Non-intact Electrical Penetration Fire Barriers Component Cooling Water Leakage at Inlet of Excess Letdown Keat Exchanger With regard to LER 250-81-09, procedural inadequacy was the cause of not having all bistables associated with N-43 power range channel while performing low power physics testing.
Operating Procedure 0204.3 was revised as corrective action.
The inspector reviewed the revision and had no further questions.
With regard to LER 251-81-07, Component Cooling Water leakage at the inlet of the excess letdown heat exchanger and its subsequent isolation would not have affected operability status of the safety-related function of the Component Cooling Water System.
O.
Receipt, Storage, and Handling of Safety-Related Items
'On June 24 and 25, 1981, the inspector inspected the licensee's storage facilities for parts, materials, and components which included a tour of the new storage building, the ISC component storage locker, and Mechanical Maintenance gC component storage area.
The inspector verified that the controlled materials (requiring traceability) were stored in a segregated manner from non-quality items; parts or material requiring receipt inspection and those that have already been inspected were tagged accordingly; and, that the stores personnel maintained a proper material receiving inspection log.
During the tour, the inspector selected eight safety-related items attached with gC tags for the purpose of ascertaining traceability of the item to its appropriate records including purchase order, certification record, receipt record, and issue record.
The specific items selected were:
a.
Wide-range containment with level transmitters, Construction Work Order Number C-88B.
b.
Subcooled Margin Monitor RTDs, Construction Work Order Numbers C-97 and C-98.
c.
Two 1-inch Stainless Steel Globe Valves, and one 14-inch Stop Check Valve, Construction Work Order Number C-95.
d.
Blind Flange for 1-inch pipe, rated 150 lbs., Construction Work Order Number C-95.
e.
Insert, 1-inch by 3/4 inch Stainless Steel, rated 3,000 lbs.
Construction Work Order Number C-95.
f.
Three Pacific Scientific Company (PSC) mechanical snubbers, Purchase Order 65255-28204.
g.
Rear bracket for the PSC mechanical snubbers, Purchase Order 65255-08588P.
h.
Two 3/4-inch T-78 Globe Valves.
For the items inspected above, the inspector verified traceability of six items.
Items (f) and (h) were untraceable.
The information presented on the gC tags attached to items (f) and (h) was found to be incomplete and erroneous.
Licensee Administrative Procedure 0190.72, Receipt Inspection, Identifi-cation, and Control of Nuclear Safety-Related and Fire Protection Parts Materials, and Components, requires tagging of controlled material using Form 5521 (gC Tag)
once receipt inspection activities have been completed and the controlled materials have been found to be acceptable.
Furthermore, the gC tag is there for the purpose of retaining traceability data back to
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lf the purchase order by batch, lot, or serial number and remain attached to the controlled material until installation in the plant system.
The gC tags attached to item (h) two 3/4-inch T-78 Globe Valves provided no purchase order number, nor date received, date issued, and gC inspectors initials.
The gC tags attached to item (f) -- the PSC mechanical snubbers provided an untraceable purchase order number.
It appears that 'personnel responsible in tagging the controlled materials have been careless in completing the information required on the gC tags.
The information required to be filled in on the gC Tag appears to be self-evident and needs no additional instructions.
Therefore, A.P. 0190.72 was not followed.
This constitutes a violation of 10 CFR 50, Appendix 8, Criterion V and the accepted licensee gA Program Technical guality Requirement Number 5 in that the instructions provided in 0190.71 were not followed.
(250/81-16-02 and 251/81-16-02)
Post Implementation Review of NUREG-0737 Items During this reporting period, the inspectors completed followup inspections of three TMI related requirements.
Those requirements were stated in NUREG-0737:
Item I.A.1.3 Shift Manning:
Part 1 of this requirement for the control of overtime for operating staff was found to be acceptable.
The licensee, responded to the NRC's overtime restrictions in their letter December 26, 1980, to the Director of Division of LIcensing.
The licensee took exception to imposing overtime restrictions for plant personnel other than licensed operators who perform safety-related functions.
The NRC does not have specific overtime criteria for non licensed personnel.
Licensee conformance and exceptions to the interim criteria are discussed below.
The required implementation dates for having an administrative procedure on limited overtime was November 1, 1980.
The licensee has complied with these dates.
The licensee Administrative Procedure 0103.2 defines overtime restrictions for licensed operators and delineates the four main overtime restrictions which are in agreement with NUREG-0737 requirements.
We have reviewed the licensee's overtime restrictions and its compliance with NRC requirments stated in the NUREG-0737 document.
As already mentioned earlier the licensee took exception to imposing overtime restrictions on personnel other than licensed operators who perform safety functions.
Our acceptance of this licensee position is based on our finding that while we do not have a written policy on overtime restrictions on unlicensed personnel"there is a general agreement between the NRC and the licensee on working hous criteria applied to licensed operators.
With regard to the requirement of having a reactor operator periodically relieved of primary duties at the control board when working in excess of 8 continuous hours, no written agreement is provided in the licensee's procedure.
However, with the number of RO's currently assigned this in the control room this requirement is easily achieveable and is actually
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performed in the control room.
Furthermore the licensee has agreed to add this requirement to the Administrative Procedure.
The overtime restriction on RO's and SRO's when working more than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> on other duties than normal shift assignment in the control room, and then not being able to return to their regular shift duty in the control room without at least a
12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> break preceding such an assignment is not specified in the Administrative Procedure.
However, a letter has been issued to the Tur key Point Units 3 and 4 reactor operation personnel including licensed and unlicensed operators from the Operations Supervisor.
The letter informed them that they may work in maintenance (all other departments)
on their second day of rest and there shall be at least
hours between the time the operator stops 'work in maintenance and the time he is 'scheduled to report back to work on his operating schedule.
Implementation of this letter meets the requirement.
Item I.C.5 Procedures for Feedback of Operating Experience to Plant Staff:
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21,1999, Turkey Point is defined by the Corporate Power Resources Department instruction 3148,
"Feedback of operating Experience to Plant Staff" and Turkey Point Administrative Procedure 0103.5,
"Operating Experience Feedback".
These procedures establish a Program Administrative on the
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corporate staff who is in overall charge of the program.
The guality Assurance department conducts periodic audits, to assure the feedback functions are working effectively.
The inspectors review established that of the seven requirements for a program of feedback of operational staff, four were. deemed to have been fully met, and three were found to be deficient in some aspects of the
'dministrative controls required.
The licensee (Plant 't1anager)
committed to strengthen the administrative controls by modifying Administrative
.Procedure 0103.5 by September 1, 1981, as follows:
a.
.Hodify paragraph 3'.2.2 to state that procedural changes, plant modifications, etc. resulting from action on feedback information will'e accomplished using the plant's existing administrative procedures as appropriate to the individual circumstance.
b.
tlodify paragraph'.2.2.
1 to explain what action shall be taken for priority items and the steps necessary to ensure affected personnel are informed and understand the item.
c.
Establish within the procedure specific administrative direction to the Technical Department Supervisor for the routing of feedback information
. to the plant staff for action and/or information.
Establish within the procedure the form and administrative mechanics of the staff log.
I These items will be reviewed on a subsequent inspection.
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Item I.C.6 Procedures for Verifying Correct Performance of Operating Activities:
Of the five requirements for verification of operating activities, the licensee fully met three.
Administrative Procedure 0103.1, Implant and Equipment Clearance orders, provided the details and authority that addressed requirements 1,
2 and 4.
Two of the requirements (numbers three and five) had not been fully implemented.
The licensee committed by August 31, 1981 to strengthen his administrative controls in these areas of independent verification by letter L-81-248 dated June 12, 1981 (250, 251/81-'16-04).
9.
Use of Hand-held Communication Radios'n Safeguards Equipment Rooms The inspector conducted. an informal survey to determine licensee's position on the use of hand-held radio transceivers and the susceptability of any safety-related equipment to radio frequency electromagnetic interference. It was determined that many; such radios are used continually on site.
The licensee has an informal rule that no such radio may be keyed in the rear vicinity of the protection or safeguard panels in the control room.
Low power (2 watt) radios may otherwise be used anywhere on site.
High power (5 watt) radios may be used anywhere on site except for the control room, cable spreading room, and static inverter room.
The high power radios are known to cause spurious process radiation monitor alarms when keyed in the control room; additionally, it is suspected that they may have been responsible for a spurious reactor'trip several years ago.
Order for License t1odification Concerning Primary Coolant System Pressure Isolation Valves An NRC Order was issued on April 20, 1981, requiring the licensee to implement revised Technical Specifications pertaining to periodic sur-Veillance of reactor coolant pressure isolation valves.
The. inspector has verified that the actions required by this Order have been satisfactorily completed and that the results of the tests and inspections were suitably documented by the licensee.
Records show that within the past 12 months preceding the date of the Order, the licensee performed leakage testing on the affected valves required by the Order.
Testing of Unit 3 Reactor Coolant System (RCS) check valves was performed last on April 16, 1981, per licensee Operating Procedure 1004.5, Reactor Coolant Pressure Isolation Valve Leakage Testing.
Unit 4 RCS check valves were tested last on January 10, 1981, per Temporary Procedure 991.
The RCS pressure isolation valves tested in both units per the two specified procedures were the same as those delineated in the revised Technical Specifications attached to the Order.
The acceptance criteria used for maximum allowable leakage was consistent with that required by the Order.
All valves tested have met"the"acceptance'criteria."
The frequency of testing, test conditions, and acceptable leakage rates are within the guidance given in Section 2.2 of the Franklin Research Technical Evaluation Report which was attached to the Order.
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Based on the revie4 of licensee's documentation, the inspector concluded that an acceptable leak rate test on the required RCS,check valves had been performed, O.P.
1004.5 incorporates all the requirements of the Order, and that the revised Technical Specifications attached to the Order had been implemented in a timely manner.
Containment Venting and Purging The inspector verified the licensee's implementation of the interim commitments on containment purging and venting during reactor operations.
The licensee's commitment of limited purging of both unit containments to a maximum of 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> per year and at a limited valve opening up to 50 degrees maximum has been accepted by NRC.
Subsequently, the containment purge valve manufacturer, the Henry Pratt Company, had determined that the 48-'inch and 54-inch valve disc openings should be limited to 35 and 30 degrees, respectively.
The licensee implemented these modifications on Unit 3 in October 1980, and on Unit 4 in January 1981.
To limit purge valve opening the modification consisted of an air supply adjustment.
Furthermore, the 48-inch valves were adjusted to limit disc opening to 33 degrees instead of 35 degrees.
This was done in order to balance the inlet and outlet containment purge air flows.
The licensee plans to incorporate additional modifications which include installation of mechanical stops for the purge valves.
The inspector also reviewed the number of hours that both units have undergone containment purging operations within the past two years.
Cumulative hours of purging for the time frame of July 1, 1979 to June 30, 1980 'and July 1, 1980 to June 12, 1981, were approximately 49 hours5.671296e-4 days <br />0.0136 hours <br />8.101852e-5 weeks <br />1.86445e-5 months <br /> and
hours, respectively.
The number of hours of containment purging and venting used are well within the limits of the licensee's commitment.
It should be noted during the prolonged outage of Unit 3, while the fuel has been removed, in order to maintain negative pressure in the containment the purge valves have been and will be maintained in an open position.
Plant Operations The inspector kept informed on a daily basis of the overall plant status and any significant safety matters related to plant operations.
Discussions were held with plant management and various members of the operations staff on a regular basis.
Selected portions of daily operating logs and operating data sheets were reveiwed daily during the report period.
The inspector conducted various plant tours and made frequent visits to the control room.
Observations included witnessing wor k activities in progress, status of operating and standby safety systems, confirming valve positions, instrument readings, and recording, annunciator alarms, housekeeping, radiation area controls, and vital area controls.
Informal discussions were held with operators and other personnel on work activities in progress and status of safety-related equipment or systems.
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On June 10, 1981, the inspector observed portions of spent resin transfer operations to a shielded shipping cask.
The spent resin transfer was performed per Operating Procedure 5333.1, Waste Disposal System-Transferring Spent Resin Storage Tank to Shielded Shipping Cask.
The inspector verified that the procedure was followed, operations were performed by qualified personnel, Health Physics coverage'as provided, and that system restoration was correctly accomplished following completion of the operation.
No violations were identified within the areas inspected.
During the time frame of June 8 through June 10, 1981, the inspector observed maintenance activities on Unit 4 "A" Intake Cooling Water Pump motor removal and replacement.
The inspector verified that the Plant Work Orders originating from the Electrical and Mechanical Maintanance depart-ments were properly prepared and the maintenance procedures were used.
The following procedures were applied:
(1) Maintenance Procedure 0707.27, 4160 Volt Motor Grounding and Tesing with use of Manufacturer's Ground and Test Device; (2) Maintenance Procedure 3407.4, Intake Cooling Water Pump Motor-
~ -Overhaul and Maintenance; and (3) Administrative PPocedure 0190.28, Mechanical Test Control (Post Maintenance).
The latter procedure provides-instruction in ensuring that the pump undergoes an Inlervice Inspection test upon completion of maintenance.
Ho violations were identified within the areas inspected.
Plant Tours During a tour of the facility about 0700, June 3, 1981, the inspector noted that the liquid release line to the Unit 3 discharge structure had been partially removed.
One end of the line had been sealed with a welded plate.
The other end of the line was open, unbagged, and unposted.
The inspector brought the condition of the internally contaminated liquid release line to the attention of the health physics supervisor who immediately assigned a
health physics technician to provide direct coverage of the balance of the work in removing the remainder of the line to ensure that proper health physics procedures were used to remove and account for the rest of the piping.
The, licensee was able to account for all of the piping which had been previously removed, cut up in sections, and stored inside the Radio-logically Controlled Area.
A swipe of the inside surface of the open end of the pipe read 20,000 dpm.
Licensee operating procedure 11550.1,
"Health Physics Procedure HP-1" requires that either a Radiation Work Permit or direct coverage by a health physics technician be provided for work on equipment contaminated in excess of 10,000 dpm/100 cm2 or work assignments which have the potential for increasing surface contamination levels to exceed 10,000 dpm/100cm2.
Direct coverage had been assigned for the liquid release line removal; however, a
difference in the shift relief times for health physics and construction personnel produces a two hour gap when no health physics technician was present.
The gap in health physics coverage appears to have been the direct result of inadequacy of health physics supervisor shift turnover procedures to note direct coverage assignments due to the lack of a Radiation Work Permit.
This incident constitutes a violation of Technical Specification
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6.8.1 in that the provisions of operating procedure 11550.1 were not implemented (250/81-16-01).
On June 5, 1981, the inspector performed a complete walkdown of the Auxiliary Feedwater System used for Units 3 and 4.
This included verifi-cation of correct valve position, proper alignment of power supply and breakers that must actuate upon initiation signal, valves are locked as appropriate, and that auxiliary equipment such as the Nitrogen system was in an operable condition.
No violations were identified within the areas inspected.
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