IR 05000250/1986044

Insp Repts 50-250/86-44 & 50-251/86-44 on 861117-21. Violations Noted:Failure to Evaluate Valve Mods for Unreviewed Safety Questions & Failure to Follow Pipe Support Procedures

ML20210E249
Person / Time
Site:	Turkey Point
Issue date:	01/06/1987
From:	Blake J, Kleinsorge W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20210E205	List: IR 05000250/1986044 ML20210E198 ML20210E238
References
50-250-86-44, 50-251-86-44, NUDOCS 8702100259
Download: ML20210E249 (10)

Text

a hrac o UNITED STATES g,[ ~ ,g NUCLEAR RE2ULATORY COMMISSl:N

-'

O o REGION il 0 -r 101 MARIETT A STREET, N.W., SUITE 2900

• *

o ATLANTA GEORGIA 30323

%...../

.. -

Report Nos.: 50-250/86-44 and 50-251/86-44 Licensee: Florida Power and Light Company 9250 West Flagler Street Miami, FL 33102 Docket Nos.: 50-250 and 50-251 License Nos.: DPR-31 and DPR-41 Facility Name: Turkey Point 3 and 4 Inspection Co u e! o ember 17-2 986 Inspector: -

7 4+/+ a1 $, M8d Wf,ff dihsorge Date Signed Approved by: . . AW t /!d 7 J. J. BlaTe, Section Chief /J Date Signed Engineering Branch Division of Reactor Safety SUMMARY Scope: This routine unannounced inspection was conducted in the areas of licensee actions on previous enforcement matters (92701B)(927028), housekeeping (54834B), material identification and control (429028) material control (429408),

inservice inspection (ISI) - review of program (73051) and inspector followup item Results: No deviations were identified. Two violations were identified -

" Failure to Evaluate Valve Modifications for Unreviewed Safety Questions" paragraph 3a and " Failure to Follow Pipe Support Procedures" - paragraph 3 ,

021

.

REPORT DETAILS Persons Contacted Licensee Employees C. T. Baker, Plant Manager

• J. W. Kappes, Acting Plant Manager

• M. J. Crisler, Quality Control (QC) Supervisor

• J. Arias, Jr., Regulatory Compliance Supervisor B. A. Abrishami, System Performance Supervisor

• E. L. Anderson, PNS ISI Specialist

• H. E. Hartman, ISI Coordinator

• R. Hart, Licensing Engineer I

Other licensee employees contacted included engineers, technicians, and office personne Other Organizations

• D. E. Boger, Factory Mutual ANII NRC Resident Inspectors

• D. R. Brewer

• K W. Van Dyne

• Attended exit interview Exit Interview The inspection scope and findings were summarized on November 21, 1986, with those persons indicated in paragraph 1 above. The inspector described

the areas inspected and discussed in detail the inspection findings listed below. No dissenting comments were received from the license (0 pen) Violation 50-251/86-44-01

" Failure To Evaluate Valve Modifications for Unreviewed Safety Questions - paragraph 3 (0 pen) Violation 50-250, 251/86-44-02: " Failure To Follow Pipe Support Procedure" - paragraph 3 (0 pen) Inspector Followup Item 50-250 251/86-44-03: " Relief Request Status"

- paragraph 6a(1)

(0 pen) Inspector Followup Item 50-250, 251/86-44-04: " Repair and Replace-ment Programs" - paragraph 6d.

i

.

(0 pen) Inspector Followup Item 50-250, 251/86-44-05: "Off-Site Storage Controls" - paragraph 6 The licensee did not identify as proprietary any of the materials provioed to or reviewed by the inspectors during this inspectio . Licensee Action on Previous Enforcement Matters (Closed) Unresolved Item 50-251/84-03-02: " Throttling of RHR Discharge Stop Valves" This matter concerned the throttling of RHR discharge stop valve No. 4-872. It was discovered that valve 4-872 was throttled in March 1978 and subsequently unthrottled in April 1984. During inspection 251/84-03, it could not be determined whether the changes to valve 4-872 (throttling and the subsequent unthrottling) were evaluated to determine whether those changes involve unreviewed safety question The licensee informed the inspector that they had determined that the changes to valve 4-872 were not evaluated for unreviewed safety questions. As no evaluation was made, there were no records kept or report made. The above is contrary to Title 10, Code of Federal Regulations Part 50.59 (10 CFR 50.59) which requires that changes to a facility be evaluated to determine whether those changes involve unreviewed safety questions, that records of those evaluations be kept, and that a report be made to the NRC at least annually, containing a description of those changes including a summary of the safety evalua-tion. Clearly, the failure to evaluate, record and report the changes to valve 4-872 is a violation of 10 CFR 50.5 The licensee augmented its earlier response to this unresolved issue (letter L-85-301 to Dr. J. Nelson Grace, Regional . Administrator, Region II, dated August 5,1985) with additional oral and written

information to show that the plant was not in an unsafe condition when j valve 4-872 was throttled or not throttled. RHR pump runout can be limited by either throttling valves 4-754A and B (as directed in

! current procedures) while valve 4-872 is wide open or by throttling i valve 4-872 alone. Sufficient water pressure (110 psig) for the

'

long-term recirculation cooling phase, after a LOCA, could also be provided by the high-head safety injection system without depending on the low-head (RHR) header. The inspector accepts these evaluations as l

fulfilling the intent of Section 50.59 of 10 CFR 5 This matter is clearly a Violation ;f 10 CFR 50.59, therefore, this matter will be closed as an Unresolved Item and Violation 50-251/86-44-01: " Failure to Evaluate Valve Modifications for Unreviewed Safety Questions."

i

_ _

- , _ , _ -

-

.

b. (0 pen) Violation 50-251/86-06-02: " Failure to Provide Appropriate Acceptance Criteria for Inservice Testing Procedure" The licensee denied this violation stating in their May 29, 1986 response:

"FPL does not concur with the finding for the following reasons:

1) It is FPL's position that paragraph IWP-3111 requires a new set (or sets) of reference values be determined after a pump has been replace However, after completion of repairs or routine servicing of a pump, which may have affected a pump reference value (or sets of values), paragraph IWP-3111 requires that either the previous set (or sets) of referenced values shall be reconfirmed, or a new set (or sets) shall be determined by an inservice test run prior to, or within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> after the

,

pump is returned to servic The acceptance criteria for reconfirming the previous set (or sets) of reference values is provided in Table IWP 3100- ) Subsection IWP " Inservice Testing of Pump in Nuclear Power Plants" is based in part on statistical techniques for the analysis of test data. Table IWP-3100-2 " Allowable Ranges of Test Quantities" provides ranges of inservice test quantities in relation to reference value Vibration amplitude has four (4) ranges of Test Quantity specified, depending on the reference vibration amplitude value. Accordingly, a change in pump vibration amplitude from 1.5 mil to 0.5 mil in the range 0.5 to 2.0 mil is not by itself statistically signifi-l cant and did not require a change in reference value.

! Furthermore, statistical analysis of No. 4B containment spray pump inservice test results from 1977 to date show that a l

test quantity of 0.5 mil is within one standard deviation of I the median value for vibration amplitude for this pump and is well within the vendor recommended value."

The NRC in their acknowledgement letter of July 1, 1986 stated:

"The violation described in our letter pertained to an apparent l

failure to provide adequate acceptance criteria for inservice

'

testir.g of containment spray pump 4B as required by the ASME Boiler and Pressure Vessel Code Section XI paragraph IWP-3111. We

will examine the basis for your denial of acceptance criteria discrepancies in a subsequent inspection."

i

,

"

.

The inspector discussed the above with the licensee, who explained their statistical evaluation process that was used to evaluate the adequacy of the existing pump quantity vibration amplitude acceptance criteria. . The . licensee stated _that this evaluation process is undocumented, nor is there any evidence of that evaluatio As the result of further discussions, it appears that the likely root cause of-the problem that resulted in this violation is as. follows: the FP&L program for determining the need for new Pump Test Quantity Reference Values (TQRV) is designed for TQRV that have high-limit and low limit acceptance values. (All the Test Quantities of table IWP-3100-2 except for vibration amplitude) Therefore when a test quantity becomes lower, it moves further from the high limit acceptance value_and closer to the low limit acceptance value.' If the process continues the pump must be tested more frequently or repaired. At this point, by code, the same TQRVs may be reconfirmed or new TQRVs may be established by tes In the case of the test quantity " vibration amplitude," there is no low limit acceptance value by code, only a high limit. valve. Therefor when vibration amplitude becomes lower, as the result of repair or service, it moves further from the high limit but not closer to a low limit because there' is no low limit. -This further distance from the high limit (the only limit) makes the high limit acceptance criteria less conservative. In the case at hand, the reduction in conservatism is by a factor of thre The licensee stated that they would document their policy for how, when and under what circumstances pump test quantity reference values would be established, reestablished or confirmed. They further stated that this policy would be available for NRC review by mid January 198 Pending NRC Review of. that policy and the vibration history of that pump, this matter will be held in abeyanc c. (Closed) Unresolved Item 50-250, 251/86-31-02: " Pipe Support Removal and Reinstallation Authorization."

'

During the inspection documented in report 50-250/86-31, the inspectors

noted a safety related pipe support, (identified with a white paper tag i marked 622AH2) that was not made up (support was attached to the pipe

but not attached to the overhead.) This pipe, a portion of the

component cooling water system, was identified as piece 6 on Drawing

,

5610-FSK-621-A-R3. At the time of that inspection it could not be i determined whether the support disassembly had been authorized, and

whether provisions had been made to assure reinstallation and inspec-

' tion of the same. The licensee indicated that they would look further in to this matter.

! Subsequently the licensee determined that pipe support (later I

positively identified as) 622A H-2 was removed without the authoriza-tion of a Plant Work Order (PWO). The above is contrary to FP&L j Maintenance Procedure 0734, dated February 26, 1986, " Safety Related i-

- . . . . - _ _ _ _ ._ _ _ _

. _ _ _ _ _ _- _ ._. _ _ _ . _

,

.

i

, Supports / Restraints Removal and Replacement" which requires safety -

related pipe supports be removed and replaced in accordance with safety

.related PW ,

'

The above is .in violation of Technical Specification'(TS) 6.8.1 that requires written procedures and administrative policies be established,

, implemented and maintained that meet or exceed the requirements and

.

-

recommendations for Sections 5.1 and 5.3 of ANSI N18.7-1972 and Appendix A of USNRC Regulatory Guide 1.33. This matter will be closed as an unresolved item and opened as Violation 50-250, 251/86-44-02:

" Failure to Follow Pipe Support Procedure." ,

Within the areas examined no violations or deviations were identified i except as noted in paragraph nos. 3a and 3 . Unresolved Items

. Unresolved items were not identified during this inspection.

, Independent Inspection Effort Housekeeping (548348), Material Identification and Control (429028) and i Material Control (429408)

The inspector conducted a general inspection of the protected area to

observe activities such as housekeeping, material ide'ntification and i control; material control, and storag Within the areas examined no violations or deviations were identified.

i Inservice Inspection (ISI) - Review of Program (73051)

'

The inspector reviewed procedures,-interviewed licensee / contractor personnel

,

and reviewed records to determine whether the licensee's program pertaining

to ISI is complete and in conformance with regulatory requirements and the i licensee's commitments, as indicated belo Unit 3, which commenced L commercial operation on December 4,1972, is in the first period of the

second ten year ISI interval (February 22, 1984 - to February 22, 1994).

! Unit 4 which commenced commercial operation on September 7.1973, is in l- the first period of the second ten year ISI interval (April 15, 1984 To April 15, 1994). The applicable code for ISI, for both units is ASME Boiler and Pressure Vessel (ASME B&PV)- Code Section XI 1980 edition with addenda through the Winter of 1981(80W81).

)

'

! ISI is being performed by Florida Power and Light (FP&L) Company under the

!

!

umbrella of the FP&L QA Program, with the exception of automated examina-

< tions of the reactor vessel which are to be performed by Southwest Research Institute (SwRI) under the umbrella of the SwRI QA Program.

l t

l i

~ . _ , , _ - _ _ _- _ -- - - - . ~ . _ _ _ . . _ . - - . _ _ _ _ _ - - ~ . _ _ _ - _ - _ _ - . - _ _ . -

-

.

.

a. Program Approval The inspector interviewed personnel and reviewed documents indicated below to determine whether requirements were met in the following areas: ISI program, including examinations and tests, is in conform-ance with relevant ASME Code Section XI editions and addenda, and Code cases proposed for use as part of the plan; services of an Authorized Nuclear Inservice Inspector (ANII) have been procured and the ISI plan has been reviewed by the ANII in accordance with Article IWA-2120 of the ASME Code; and the ISI plan has been reviewed by the licensee's site nuclear safety review connittee, or equivalent licensee review and approval has been documente With regard to the inspection above the inspector noted the following:

(1) The licensee informed the inspector of the following: 15 requests for relief from code requirements have been submitted to the Commission for consideration. Of the 15 requests submitted for relief from code requirements, one (Relief No. 4) was withdrawn from consideration, three (Relief Request Nos. 2, 6 and 7) are still pending NRC action, the remaining eleven relief requests have been approved. The licensee was unable to provide documented evidence that relief request no. 5 was approved by the Commissio In addition, the status of relief requests indicated in the relief request summary in both ISI Second Ten Year Plans is not consistent with the status stated by the license Therefore pending the NRC's review of the licensee's resolution of relief request, status this matter will be identified as inspector followup item 50-250,251/86-44-03: Relief Request Status."

(2) The licensee is committed to ASME B&PV Code Section XI 80W81 the requirement to have the ANII review the ISI plan did not become a requirement of ASME B&PV Code Section XI until the 1983 editio However the ANII did review the Unit 4 ISI Plan on November 25, 1985 and as evidenced by his log. The ANII stated that he had reviewed the Unit 3 ISI Plan, but he has no documented evidence to substantiate the sam b. Program Organization The inspector reviewed the licensee and ISI contractor's QA programs to verify the following: procedures for the maintenance of required ISI records; QA review includes assurance that plans and procedures have been reviewed by appropriate personnel and meet regulatory require-ments; procedures are established for the corrective action of conditions adverse to quality as detected during examination, including provisions to preclude repetition of such adverse conditions; audits or surveillance of ISI activities are conducted by qualified QA personnel to verify compliance with the ISI program; and procedures are

,

established to effectively oversee contractor activities concerned with l

ISI/ PS .- _ ._, _

_ - -

. . . . . __ _ _ ._- _ _ _

- .- .

_

7 r

J c.- Repair Program ,

The inspector reviewed the licensee's administrative and: maintenance-procedures indicated,below to verify that the requirements of Article

'

i IWA-4000 of the ASME Code, and NRC supplementary requirements, are '

included or reference Replacement-Program

,

The inspector reviewed the licensee's administrative and maintenance procedures indicated below to verify that requirements of Article- '

IWA-7000 of the ASME Code, and NRC supplementary requirements - are included or reference With regard to the inspections described in paragraphs 6c and d above

~

the inspector noted that the licensee does not have a uniform program for repairs or replacements. To determine whether repairs and replacements had been accomplished documented and reported consistent -

with the applicable : code requirements the inspector reviewed records

.

i for the below listed repairs / replacement Identification Repair / Replacement

! CWO-DI-1675/NCR 174-86 Repair i CWO-01-1675/NCR 154-86 Repair .

'

PWO-0589/NCR 86-126 Repai '

PWO-0224 Replacement PWO-1402 Replacement CWO-D1-1674/NCR 252-86 Replacement

- The inspector discussed the above with the licensee who indicated that

a unified repair and replacement- program is in preparation. Pending NRC review of that approved program this matter will be identified as inspector followup item 50-250, 251/86-44-04: " Repair and Replacement

Prog rams. "

! Records l

The inspector reviewed procedures and records indicated below to determine whether provisions for the maintenance and retention of records, including inspection, examination, test reports, repair and

'

replacement, QA, and NDE records have been established in the ISI program.

,

With regard to the inspection above the licensee informed the inspector that nonfilmable records (Radiographs, UT and ET strip charts, etc.)

,

are stored off site at a FP&L corporate storage facility. At the time

' of this inspection the procedures for the storage and preservation of l those records were not available for NRC revie Pending NRC review '

l this matter will be identified as inspector follow up item 50-250, 251/86-44-05: "Off Site Storage Controls " .

[

i

i i

+

vmr,cwe . . ~ -- ---.,m4wi,m -.m,,.-r%-,, mm- ,----,. ~ -r.. , , - - - . . ~ , . - - . . . ,-,-...--------.~w,r-

.

8 Qualification of Personnel The inspector review procedures indicated below to determine whether the ISI program specifies personnel qualification requirements consistent with the ASME Code, plant Technical Specifications (TS), and other applicable document g. Reporting Requirements The inspector reviewed procedures indicated below to determine whether

.

the licensee's ISI program includes the ASME Code and plant TS require-ments for submittal of written reports of ISI results, repairs, and replacement h. Relief Requests The inspector reviewed procedures indicated below to determine whether the licensee's program contains guidance regarding the identification and processing of requests for relief from ASME Code requirements. The inspector conducted an ISI data review as indicated below to determine whether the bases for the relief requested are valid and accurat Relief Request N Subject Status 2 Reactor Vessel Safe-End Welds Pending 3 Regenerative Heat Exchanger Welds Approved Documents Reviewed Document Document Identification Title FP&L-PNS-CIS-QI2.14, " Nuclear Energy Manual for ASME Section Rev. 1 XI Inservice Inspection of Nuclear Power Plant Components" FP&L-CIS-PTP-85-300, " Inservice Inspection Second 10-Year Rev. 3/26/85 Inspection Plan" (Unit 3)

+

FP&L-MCI-PTP-85-400, " Inservice Inspection Second 10-year Rev. 1/16/86 Inspection Plan" (Unit 4)

FP&L-QP-214 Rev. O " Implementation of ASME XI" FP&L " Project Turkey Point " Document Control Master Matrix" i

, _

-. --

.

- - - . - . - . - - - . . . , . - _ _ _ . , . - _ - . _ . -

.

Document Document Identification Title FP&L-AP-0190.14 " Quality Assurance Assurance Records" Rev. October 16, 1985 FP&L-QP2.4, " Preparation and Revision of Quality Rev. 6 Instructions" FP&L-QP2.9, " Qualification of QA Audit, QC Rev. 6 Inspection and Construction Test Personnel" FP&L-QP18.1, " Performance of Quality Assurance Rev. 12 Audits" FP&L-QI18QAD3, " Scheduling of Quality Assurance Rev. 7 Department Audit Activities" Within the areas examined no violations or deviations were identifie . Inspector Followup Items (0 pen) Item 50-250,251/86-31-03: "Gulfalloy Supplied Materials."

The inspector discussed the status of the implementation of the program for the determination of serviceability of Gulfalloy supplied materials with the licensee. The licensee indicated to date that 90% of the piping, 94% of the fittings,100% of the tubing, 78% of the structural shapes, 32% of the structural plate and 88% of the bolting materials had been accepted as of November 20, 1986. The remaining materials representing 17% of the total Gulfalloy supplied materials are still being dispositioned. This item remains ope Within the areas examined no violations or deviations were identified.