IR 05000250/1982020
| ML20058C730 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/26/1982 |
| From: | Hardin A, Landis K, Vogtlowell R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20058C601 | List:
|
| References | |
| 50-250-82-20, 50-251-82-20, NUDOCS 8207260432 | |
| Download: ML20058C730 (6) | |
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NUCLEAR REGULATORY COMMISSION n $ E REGION 11 g[ 101 MARIETTA ST., N.W., SUITE 3100 o, ATLANTA, GEORGIA 30303
Report flos. 50-250/82-20 and 50-251/82-20 Licensee: Florida Power & Light Company 9250 West Flagler Street fliami, FL 33101 Facility flame: Turkey Point 3 and 4 Docket Nos. 50-250 and 50-251 License Nos. DPR-31 and DPR-41 Inspection at Turkey Foin site near Homestead, Florida o / Inspectors: [X k.
w c/w M,m 4///d#2 R. J. Vogt-Lowell () Date Signed h ( f m (l w du V////27-K. D. Landis g Date Signed Accompanying Personnel: J. Agles Approved by: [[ //2t/86 w A. K. Hardin, Acting Section Chief, Division of Date Signed Project and Resident Programs SUf1 MARY Inspection on February 26 - April 2,1982 Areas Inspected This routine, announced inspection involved 157 resident inspector-hours on site in the areas of Emergency Plant Exercise; Licensee Event Report followup; Plant Operations; Surveillance Test Observation; Plant tours.
Results Of the five areas inspected, no violations or deviations were identified in four areas; one violation was found in one area (Violation - Failure to implement and maintain procedures - paragraph 7).
8207260432 820714 PDR ADOCK 05000250 G PDR __
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. . . . DETAILS 1.
Persons Contacted Licensee Employees H. E. Yaeger, Site Manager
- J. K. Hays, Plant Ibnager Nuclear
- J. P. !!endieta, Maintenance Superintendent Nuclear
- D. W. Haase, Operations Superintendent - Nuclear J. P. Lowman, Assistant Superintendent !!echanical thintenance - Nuclear W. R. Williams, Assistant Superintendent Electrical ttaintenance - Nuclear
- J. W. Kappes, Instrumentation and Control Supervisor V. B. Wager, Operations Supervisor K. E. Beatty, Training Supervisor P. W. Hughes, Health Physics Supervisor
- D. W. Jones, Quality Control Supervisor K. N. York, Document Control Supervisor J. A. Labarraque, Technical Department Supervisor J. C. Balaguero, Licensing Engineer W. Coutier, Construction QA Engineer Other licensee employees contacted included operators, mechanics, and security force members.
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on April 7,1982, with those persons indicated in paragraph 1 above.
The inspector maintained frequent unprogrammed discussions and communications with the Plant ihnager during the inspection report period.
3.
Licensee Action on Previous Inspection Findings Not inspected.
4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
Emergency Plant Exercise The inspector participated in the Emergency Plan exercise conducted at the plant on thrch 15 and 16,1982.
The purpose of the exercise was to test and evaluate the overall emergency response capability of FPL and coordination with offsite emergency response groups.
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The inspector's involvement took place primarily in the Technical Support Center.
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, and 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, a.
251-82-01, "D" flotor Control Center b.
- 251-82-02, Refueling Water Storage Tank Overflow.
The inspector reviewed, in depth, the circumstances surrounding the !! arch 17,1982 overflow of the Unit 4 Refueling Water Storage Tank.
The results of this review are presented in section 7 of this report.
c.
251-82-03, Component Cooling Water System Supports.
7.
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 reviewed during the report period. The inspector conducted various plant tours and made frequent visits to the control room.
Obser-vations included witnessing work activities in progress, status of operating an standby safety systems, confirming valve positions, instrument readings and recordings, 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 the status of safety-related equipment or systems.
The inspector conducted a detailed investigation of the circumstances surrounding an unplanned spill of primary grade water that took place on !! arch 17,1982 at approximately 8:20 p.m.
The Unit 3 refueling cavity level was being lowered in order for maintenance to perfonn work on the reactor vessel head guide studs. The level was being lowered in accordance with operating procedure 0.P.16125.1, " Draining the Refueling Cavity Using the Residual Heat Removal System". When.a report was received that #4 Refueling Water Storage Tank (RWST) was overflowing, the operator took action to secure the RHR pump; and shut valves M0V-3-864A and 864B plus MOV-3-863A and 863B.
The #4 RWST appeared to be slightly pressurized and continued to overflow and the operator reopened MOV-3-864A and 864B thereby allowing #4 RWST to flow back to #3 RWST at which time #4 RWST stopped overflowing. The -- - - - -.- - _ _ _ _ _ _ _ _ _ _ _ _ -- )
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overflow spilled 11,000 gallons of water onto the ground representing an estimated total of 120 millicuries of radioactivity.
The inspector's review of the procedure being followed disclosed a procedural inadequacy which largely contributed to the unplanned unmonitored spill. This inadequacy of OP 16125.1 relates to the failure to address the position of the high head safety injection (HHSI) pump suction cross connect valves 870A and 870B in the prescribed valve lineup for draining the refueling cavity. As a result of the omission, the #3 refueling cavity water was afforded an unintentional flow path to the Unit 4 RWST in addition to the desired flowpath to the #3 RUST.
Valves 870A and 870B had been opened earlier in order to provide suction for all four HHSI pumps from the
- 4 RWST since the #3 RWST had been drained down to flood the Unit 3 refueling cavity. Had OP 16125.1 required closing 870A and 870B prior to draining down the #3 refueling cavity, the overflow through the #4 RWST would have been averted.
The inspector's review of the incident revealed additional contributory aspects releated to the malfunctioning of the #4 RWST level alann system at the time of the spill.
This alann system had undergone a modification whose description and implementing procedure and controls is addressed in Plant Change /ttodification (PC/f t) 80-101.
The issuance of the modification was the installation of a new level switch which would provide a low level alann to prevent exceeding the technical specification level and to provide a high level alann to prevent RWST overflow.
The inspector's review of PC/ft 80-101 revealed several examples of failure to comply with the administrative controls governing PC/ils. These controls are described in A.P.190.15, " Plant Projects - Approval, Implementation and Regulatory Requirements".
The following comprises a description of the specific examples of failure to comply with A.P.190.15: Procedure Requirement: (1) Step 5.3.2 of AP 190.15 requires that marked up drawings, special test, implementation and acceptance procedures be submitted to the plant Technical Department within 20 working days after PC/t1 work completion.
(2) Step 5.3.3 requires " written modification of PC/M work completion" to the Technical Department PC/M coordinator within 5 working days after completion date.
(3) Step 8.2.4 requires that the entire PC/l1 package for each completed PC/it be forwarded to the Technical Department PC/M Coordinator "within 60 days of completion of the hardware changes authorized by the PC/ft".
Inspector Findings: As of itarch 31, 1982, the requirements of the above referenced steps had not been met. The PC/i1 package was still in the custody of the construction department even through the work was completed and the PC/ft signed off as implemented on December 7,1981.
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It should be noted that procedurally it is the notification to the Technical Department of the completion of a PC/M that, in part, triggers the training of the plant licensed operators on the particular aspects of a PC/M. As a result of this lack of notification, the training on the new level switches had not been done at the conclusion of the inspection report period. The inspector noted a general unawareness (among various members of the operations department) of the fact that the RWST high level and low level control-room annunicators were now receiving their signal from the level switches installed under PC/M 80-101.
In the inspector's judgement, earlier awareness of this relationship, would have increased the probability that ~ the discrepancies in the annunicator alarms found during the investigation conducted by the licensee subsequent to the overflow would have been detected and corrected prior to !brch 17, 1982 thus possibly averting the spill.
Procedural Requirement: ' Step 5.4 of A.P.190.15 states, "PTP supporting departments are responsible to ensure that plant modifications, operations, testing and affected procedures, required byaoproved PC/Ms are executed, completed and updated according to procedure requirements in their area of responsibilities".
Inspector Findings" i The following procedures in effect at the time of the overflow on March 17, 1982, had not been updated and/or distributed to reflect the modifications completed December 7,1981 under PC/M 80-101.
a.
ONOP 0208.9, " Annunciator List - Annunicator Panel G - Hiscellaneous".
b.
MP 14007.20, "RWST Instrumentation Calibration".
It should be noted that subsequent to the overflow, the control room annunciator windows corresponding to the RWST high and low level alarms were found reversed to the configuration supposedly achieved by PC/M 80-101 with the added fact that the card associated with the low level alarm was found to be incorrectly wired.
If the correct configuration and card is assured to have existed at the time the PC/M was canpleted one can only conclude that an unauthorized alteration was responsible for the as found, post overflow, configuration.
The licensee has committed to incorporate administrative controls that would identify the individuals organizations authorized to make changes on the annunicators panel's by hay 31, 1982.
Procedural Requirement: Step 8.3.3 of A.P.190.15 requires in part that a " Functional Test and Acceptance Procedure" be generated that complies with the functional acceptance criteria included in the " originator implementation guidelines" discussed in step 8.3.1 of AP 190.15.
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Inspector Findings: fio such procedure was developed and consequently the licensee was unable to provide definitive evidence that the system installed under PC/ft 80-101 was ever shown to have satisfactorily perfomed its design function prior to the 11 arch 17,1982 overflow.
The above describes discrepancies are contrary to the requirements of Technical Specifications 6.8.1 which states in part, " Written procedures and administrative policies shall be established, implemented and maintained..."; and as such constitutes a violation (50-251/82-20-01).
8.
Surveillance Test Observation On April 1,1982 the inspectors observed portions of the performance of 11.P.
12307.3, " Quarterly Calibration of the lluclear Power Range Instrumentation".
The work was being performed under PWO (Plant Work Order) 7121. The inspector ascertained that the following objectives were being met: testing was scheduled in accordance with technical specification requirements, procedures were being followed, testing was perfomed by qualified personnel, LCOs were being met, and system restoration was correctly accomplished following testing.
On March 18, 1982, the inspector observed performarice of P.T. 4304.1, " Emergency Diesel Generator - Periodic Test Load on 4Ky Bus".
The inspector verified the following aspects of this surveillance test: the procedure conformed to technical specification requiremer,ts; proper licensee review; test instrumentation was calibrated; removal of the system from service; conduct of the surveillance test; restoration of the system to service; review of the test data for accuracy and completeness; confirmation that surveillance test documentation was reviewed and test discrepancies were rectified; test results satisfied technical specification requirements; testing was done by qualified personnel; and the surveillance schedule for this test was met.
fio violations or deviations were identified within the areas inspected.
9.
Plant Tours
Various plant tours were conducted by the inspectors. Attention was focused on the operability of safety-related equipment in the following areas: cable spreading room; inverter and battery room; motor generator set and battery rooms; Rod Control Equipment Rooms; switchgear rooms; Diesel Generators Rooms and Day Tank rooms; Auxiliary Building.
! fio violations were identified within the areas inspected.
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