IR 05000250/1990019
| ML17348A436 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 07/12/1990 |
| From: | Jape F, Matt Thomas, Wright R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17348A434 | List: |
| References | |
| 50-250-90-19, 50-251-90-19, NUDOCS 9007260143 | |
| Download: ML17348A436 (17) | |
Text
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('w iI p*yW UiVITEDSTATES NUCLEAR REGULATORY COMMISSION REGION I I 101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 f
Report Nos.:
50-250/90-19 and 50-251/90-19 Licensee:
Florida Power and Light Company 9250 West Flagler Street Miami, FL 33102 Docket Nos.:
50-250 and 50-251 Facility Name:
Turkey Point 3 and
License Nos.:
DPR-31 and DPR-41 Inspection Inspector:
Inspector:
Conducted:
June 18-22, 1990 d.
C rig t homas ate Signed C)
ate igned Approved by:
ect>on ref guality Performance Section Operations Branch Division of Reactor Safety Date Signed SUMMARY Scope:
This routine, unannounced inspection was conducted in the areas of design control, engineering support functions, commercial grade procurement, and licensee action on previous inspection findings.
Results:
The plant design engineering authority is preparing and implementing design changes and modifications in accordance with their TS, FSAR,
CFR 50.59 requirements, and their site approved control procedures.
These design changes and modifications appear to be both technically and administratively acceptable.
Plant support provided by engineering was adequate as demonstrated by effective engineering involvement and management of the REA and NCR programs.
System Engineering program weaknesses previously identified in the last SALP report have been appropriately addressed and corrected by the plant to the point where these same deficient areas may now be considered a strength.
The licensee appears to recognize that procurement is an engineering function and has developed a
CGI procurement program comparable to EPRI NP-5652 guidelines.
Overall performance of engineering and technical support provide assurance that technical issues are being resolved in a quality manner.
In the areas inspected, violations or deviations were not identified.
5'007260143 9007(:=:
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REPORT DETAILS Persons Contacted Licensee Employees
- J J.
E.
S.
K.
J.
- K.
R.
- D
- M
- V M.
- M
- J
- J
- L M.
J.
- D
- K
- W.
M.
R.
- K F.
Donis, Operations Support Supervisor, Technical Department Ellis, Systems Engineer, Technical Department Finnigan, Lead Engineer, Procurement Franzone, Project Engineer, JPNS Frehafer, Engineer, JPNS Haas, Lead Engineer, Procurement Harris, Site Vice President Hawkes, gC NCR Coordinator Herrin, Compliance Engineer Huba, Site Lead Engineer, JPNS Kaminskas, Operations Superintendent King, Engineer, JPNS Lacal, Configuration Group Supervisor, Technical Department Mack, IST Coordinator, System Performance Mowbray, Project Engineer, Procurement Supervisor, JPNS Pearce, Plant Manager Pearce, Electrical and l8C Engineer, JPNS Porter, Project Engineer, REAs, JPNS Powell, Licensing Superintendent Remington, Systems Performance Supervisor Skelley, Site Engineering Supervisor, JPNS Slawinski, Technical Staff Developer, Nuclear Training Tierney, Licensing Records Technican Van Oeveren, Nuclear Energy Supervisor, Procurement, JPN Varona, Lead Electrical and I8C Engineer, JPNS Other licensee employees contacted during this inspection included craftsmen, engineers, technicians, and administrative personnel.
NRC Resident Inspectors
- R. Butcher, Senior Resident Inspector T. McElhinney, Resident Inspector
- G. Schnebli, Resident Inspector
~Attended exit interview Acronyms and initialisms used throughout this report are listed in the last paragrap.
Design, Design Changes, and Modifications (37700)
The inspectors reviewed the PC/Ms listed below to. determine the adequacy of the safety evaluations performed to meet
CFR 50.59 requirements; verify that the design changes were prepared and installed in accordance with licensee requirements, industry codes and standards; verify that the PC/Ms were reviewed and approved in accordance with TS and administrative controls; verify the applicable plant operating documents (drawings, plant procedures, FSAR, TS etc.)
were revised to reflect the subject design changes; and modification acceptance criteria and post maintenance/
modification testing requirements were specified.
a ~
PC/N 86-181, SI Pump Minimum Flow Recirculation Line Valve Actuator Replacement, Revision 2.
This modification replaced the air operator with motor operators on isolation valves 3-865A and 3-865B for the safety injection pump minimum flow recirculation line.
The'alve operators were replaced to. eliminate a potential single failure concern.
The NOV control circuit incorporated the use of a separate control power "on-off" switch in addition to the normal valve control switch.
The control power switch is used to isolate the NOY control circuit from control power whenever the valve is not being operated.
This method of MOV control circuit isolation enables the NOV to accomodate an electrical short single failure.
b.
PC/M 89-560, Material Change on RD-11 Radiation Detector Bottom Shield Mounting Bolts.
This PC/M was processed as a
DEEP in response to action item 2 of NCR 89-0376.
This DEEP justifies the material substitution of 300 series stainless steel bolts for cadmium plated carbon steel bolts used in mounting the subject radiation monitoring base shield block.
The maintenance of the RD-11 monitor was hindered by the original cadmium plated mounting bolts which tended to seize and shear off due to galvanic action between the lead and carbon steel even though they were protected with cadmium plating.
The new 300 series stainless steel bolts are of the same dimensions and the material is a more galvanic action resistant'teel.
The 'above PC/N evaluation established design equivalence and conformance to the original design bases and verified that there is neither an unreviewed safety question nor TS change involved in this modification pursuant to 10 CFR 50.59.
co PC/N 90-207, Auxiliary Feedwater Nitrogen Backup System Valve Replacement, Revision 0.
This PC/N was processed as a
DEEP and provided the documentation and evaluation for the replacement of valves 40-3-260 through 40-3-271.
During installation of another PC/M it was discovered that the valves had damaged threaded end connections.
The valves provide the. path for the instrument air supply.to the auxiliary feedwater system flow control valve d.
PC/M 90-247, Replacement of Unit 3 Reactor Vesse'l 0-Ring Seals.
During heat up of the Unit 3 reactor, the high temperature alarm signal was detected in the reactor vessel flange leak detection system originating at the inner, metallic 0-ring seal.
No leakage was detected across the outer 0-ring which is oriented concentrically to the inner 0-ring.
To eliminate the leakage and enhance sealing capacity, the licensee replaced existing silver-plated, stainless steel (Type 304) 0-rings with silver-plated Inconel 718 O-rings.
The higher yield strength of 'he Inconel 718 material provides improved recovery; that is, the seal will tolerate'ncreased flange rotation and separation without leakage.
In addition, since the Inconel 0-ring has a higher strength which requires additional force to compress the O-ring, the increased load compresses the silver cladding, which helps the 0-ring to seal over local imperfections in the seating surfaces.
The 0-rings are fastened in place with spring clips which required slight modification to provide sufficient fastening of the replacement 0-rings.
The mechanical and chemical properties of the Inconel 718 material are compatible with the reactor coolant system, and the material represents an equivalent replacement for the previously used 304 stainless steel rings.
3.
Plant Engineering and Technical Support The inspectors reviewed several activities which give an indication of plant support provided by the Technical Department and the Site Engineering Department.
These activities included system engineering, commerical grade procurement, NRCs, and REAs.
a
~
System Engineering The inspectors reviewed the system engineering group to assess its involvement in plant activities.
System engineering is part of the Operations Support Section within the plant Technical Department.
The system engineer program was identified as a weakness during the last SALP period.
The reasons identified for the weakness were minimal system design training, frequent changes in responsibility for assigned systems, and insufficient physical walkdowns of systems.
Additionally, it was noted that the responsibilities for system engineers were not formally documented, resulting in undefined performance objectives.
The license has taken actions to address the weaknesses identified in the SALP concerning the system engineer program.
The licensee has issued administrative procedure O-ADM-501, Duties and Responsi-bilities of System Engineers, Revision date November 9, 1989.
This procedure outlines the areas of responsibilities assigned to system engineers and establishes basic functions to be performed by system engineers that are necessary to improve system performance and reliabilit Some of the duties and responsibilities performed by system engineers for their assigned systems include, but are not limited to: root cause analysis; operability assessments when required; system configuration verification which includes performing and documenting monthly system walkdowns; review/approve REAs; monitor and trend system performance; provide support to other departments; etc.
In addition to detailing the duties and responsibilities of system engineers, the licensee has developed a training and qualification program designed to provide the system engineers with a comprehensive knowledge of their assigned systems.
The system engineers received training on
CFR 50.59 Safety Evaluations; system reliability; root cause analysis; system integration; configuration control; self study modules consisting of system description and design; etc.
Following completion of the training, the system engineers were certified by an oral board that tested their knowledge on assigned systems.
The inspectors reviewed the system engineer training records and held discussions with licensee training personnel.
At the time of this inspection all of the incumbent system engineers had completed the training requirements committed to by the licensee.
Several of the system engineers were receiving makeup training because they did not successfully complete all of the training requirements.
Licensee personnel stated that in addition to receiving the initial training and certification, system engineers will receive continuing education training provided by the technical staff and licensed operator continuing education programs.
The inspectors determined that the system engineering group is actively involved in plant activities and providing support to other plant departments.
Development and implementation of programs to address the weakness identified during the last SALP period have yielded positive results and are positive indications of the licensee's efforts to improve the overall quality of training provided to system engineers, and thereby improve the quality of engineering support provided to the plant.
Site Engineering The inspectors reviewed activities performed by the Juno-Plant Nuclear Site Engineering Department (JPNS).
JPNS is the site design engineering authority.
Activities reviewed included JPNS involvement in commercial grade procurement; evaluation and resolution of NCRs; and interface with the plant Technical Department during the handling and resolution of REA Commercial Grade Procurement (38703)
This inspection was conducted to determine the progress of industry implementation of current CG procurement initiatives and to provide feedback on its progress.
The inspector conducted discussions with the Site Engineering Supervisor, the JPN Procurement Nuclear Energy Supervisor, the Site Procurement Project Engineering Supervisor, and the lead procurement engineers concerning current procurement engineering organizational structure, practices, responsibilities and procedural controls.
Cursory review of the below listed current applicable Nuclear Engineering Quality Instructions and discussions with the above mentioned personnel, disclosed Turkey Point appears to have established a
CG dedication program comparable to EPRI NP-5652 guidelines, and has been implementing the subject program since January 1,
1990.
JPN-QI JPN-QI JPN-QI JPN-QI 8.2, Rev
Suppl. 8.2.1.
Suppl. 8.2.2.
8.3, Rev
JPN-QI 8.0, Rev 0 JPN-QI 8.1, Rev
Rev 0 Rev
JPN Involvement In Procurement Control Technical Evaluation of Replacement Items Dedication of CGIs CGI Dedication Acceptance Methods CGI Dedication Examples Item Equivalency Evaluation Implementation of the CGI program was not inspected since the NRC staff is deferring programmatic inspections of licensee CG procurement and dedication programs until May 1991.
This allows utilities sufficient time to understand and implement guidance being developed by the industry for, meeting the existing procurement quality requirements of
CFR 50, Appendix B.
The JPN Procurement Nuclear Energy Supervisor also discussed FPSLs'hilosophy that supports the acceptability of CGIs bought prior to January 1,
1990, and have either been installed in the plant or are currently stored in the warehouse.
The inspector examined the backlog of open spare parts technical evaluation requests.
Although the total number of open technical evaluation requests has increased since April 1, 1989, (587) to June 1,
1990, (726), procurement engineering has done a good job reducing the older (greater than 6 months)
vintage requests.
Currently, only 3 percent, or 22 out of the 726 backlog are older than six months, whereas approximately 132 out of 587 formerly exceeded this time frame.
Licensee management attributes the increase in technical evaluation backlog numbers to the normal cyclic nature of plant outages.
Within the area no violations or deviations were identifie e (2)
(3)
Nonconformance Reports (NCR)
In addition to the above PC/Ns examined, the inspectors reviewed open NCRs to determine the current backlog, and examined the following selected NCRs for completeness, accuracy, technical adequacy, assessment for operability and
CFR 50.59 screenings:
NCRs 87-0013, 87-0040, 87-0271, 88-0087, 89-0189, 89-0376, 89-0379, 90-0106, 90-0140, 90-0151 As of June 1, 1990, a total of 230 NCRs remain open.
Performance indicators show that Engineering has made continuing progress in reducing its NCR backlog which was approximately double the current backlog one year ago.
Site Engineering has made a
conscientious effort to reduce the NCR backlog through improved communications with plant and construction gC personnel and improved maintenance/construction interface.
No problems were identified with the above NCRs examined.
Request for Engineering Assistance (REA)
The inspectors reviewed the REA process.
When this area was reviewed during the previous SALP period, it was found that REAs were being submitted to JPNS without the benefit of a
screening or prioritization process.
Licensee personnel stated at that time, that the lack of a prioritization process resulted in a backlog of REAs in JPNS.
Subsequent to that inspection (Report 50-250, 251/89-20),
licensee personnel have implemented a
screening and prioritization process for REAs.
The screening and prioritization are performed by the plant Technical Department.
System engineers perform operability reviews of applicable REAs before they are prioritized.
After being prioritized, the REAs are sent to JPNS for resolution.
The inspectors determined that actions implemented by the licensee in this area have resulted in better management and handling of REAs by the Technical Department and JPNS.
The inspectors reviewed selected REAs to verify that applicable REAs received operability reviews.
While reviewing the REAs, the following two REAs resulted in additional discussions with JPHS personnel concerning their resolution.
(a)
REA TPN-89-614, Safety Injection Block/Unblock Switch This REA was submitted to JPNS after Westinghouse informed FPL by a letter dated October 26, 1989, of a
potential single failure design deficiency associated with the control room SI block switche e (b)
The design deficiency involved the use of a single manual SI block/unblock switch (Westinghouse Type OT-2 switch)
for both trains of SI.
A postulated failure of the SI block switch could result in a loss of some automatic SI actuations.
The licensee evaluated this concern and determined that it was applicable to Turkey Point.
FPL reported this concern to the NRC via LER 89-018 dated January ll, 1990.
In the LER response, FPL committed to installing separate SI block switches for each train.
The licensee did not address potential generic implications during their evaluation and resolution of this concern.
REA TPN-90-405, Westinghouse OT-2 Switch Operability Assessment This REA was issued to address additional switches identified by W.
Westinghouse informed FPL by a letter dated Nay 8, 1990, that the same postulated design deficiency identified for the SI block/unblock switch may be a generic concern for all safety related OT-2 switches used as a single switch in redundant circuits at Turkey Point.
JPNS performed a review of approximately 225 uses of the OT-2 switch at Turkey Point and found eight potentially affected switches.
The eight switches were reviewed further and JPNS found that two functions, in addition to the SI block/unblock switches, are affected.
The two affected switches are CS reset and feedwater isolation reset.
The licensee notified the NRC of the concern with CS on June 13, 1990.
During review of the safety evaluation and response to this REA the inspectors discussed several questions with licensee personnel.
The questions involved corrective actions for the affected switches; whether the eight potentially affected switches had been physically inspected to determine if they were wired in accordance with applicable drawings; and the safety evaluation results for'the feedwater isolation reset switch.
Licensee personnel stated that the short term corrective actions for the CS reset switch included physically inspect-ing the switches after they were last actuated during surveillance testing to verify that the switches were still operational, and changing applicable surveillance procedures to require inspection of the switches after they have been actuated for surveillance testing.
At the time of this inspection, the CS reset switches had been physically inspected and verified to be operational.
The applicable surveillance procedures were in the process of being revise Licensee personnel stated that the final corrective actions to resolve the CS reset switch concern were still being reviewed at the time of this inspection.
Licensee personnel further stated that in addition to the approximately 225 OT-2 switches already reviewed, long term corrective actions include, but are not limited to, reviewing switches other than OT-2 to determine if any were wired for redundant train use; and to analyze the effects of the switches'ailure modes to determine the potential impact on plant safety.
With regard to verifying the wiring of the eight potentially affected switches, licensee personnel stated that only the two affected switches (CS reset and feedwater isolation reset)
had been physically inspected to verify that they were wired in accordance with applicable drawings.
The wiring for the other six switches had been determined by reviewing the applicable drawings.
After the question was raised by the inspectors, the licensee physically inspected the six switches and verified that they were wired in accordance with applicable drawings.
While reviewing the response to REA TPN-90-405 and the section of the safety evaluation which addressed the feedwater isolation reset swit'ch, the inspectors questioned whether the analysis performed by W considered conditions that are specific to Turkey Point.
JPNS personnel stated that the safety evaluation would be reviewed again to verify that the conclusions and results bounded the analysis in the Turkey Point FSAR.
The inspectors questioned what corrective actions were planned for the feedwater isolation reset switch.
Licensee personnel stated that even though it was concluded that the failure of a reset pushbutton would not result in the loss of the protective function associated with feedwater isolation, corrective actions will be taken to address the wiring concern associated with the switch.
Licensee personnel further stated that the feedwater isolation reset switch will be discussed in the LER along with the containment spray reset switch.
No violations or deviations were identified in the areas inspecte Action on Previous Inspection Findings (92702)
(Closed)
VIO 250, 251 /89-203-01 (UNR 89-203-15),
Component Cooling Water System Operating Procedures.
The licensee's response dated March 28, 1990, was considered acceptable by Region II.
The inspector.verified that the subject procedures were revised to reflect correct valve positions and that missing valves were added to applicable procedures as specified.
The inspector examined objective evidence to ascertain that a design verification of procedures for selected systems versus applicable T-E drawings had been performed; that emergency hoses and hose couplings in the charging pump room required to be staged to support off-normal operations were replaced; and Operations Surveillance Procedure 3/4-OSP-300.2 was revised to require monthly verification of the acceptablity of these hoses and equipment.
Objective evidence of training given in procedural and drawing revisions and training in technical reviews was evident for appropriate personnel.
The inspector concluded that the licensee had determined the full extent of the violation, taken action to correct the condition and prevent recurrence of similar problems.
The corrective actions stated in the licensee's response have been implemented.
Exit Interview The inspection scope and results were summarized on June 22, 1990, with those persons indicated in paragraph 1.
The inspectors described the areas inspected and discussed in detail the inspection results.
Proprietary information is not contained in this report.
Dissenting comments were not received from the licensee.
Acr onyms and Initialisms CG CGI CS DEEP EPRI FPL FSAR JPN JPNS LER MOV NCR PC/M QC REA SALP SI TPN TS W
Commercial Grade Commercial Grade Item Containment Spray Design Equivalent Engineering Package Electric Power Research Institute
Florida Power and Light Final Safety Analysis Report Juno Plant Nuclear Engineering Juno Plant Nuclear Engineering - Site Licensee Event Report Motor Operated Valve Nonconformance Report Plant Changes and Modifications Quality Control Request for Engineering Assis'tance Systematic Assessment of Licensee Performance Safety Injection Turkey Point Nuclear Technical Specifications Westinghouse Electric Corporation
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