IR 05000250/1991033

Insp Repts 50-250/91-33 & 50-251/91-33 on 910819-23.No Violations Noted.Major Areas Inspected:Training & Surveillance Testing for Upgrade of Emergency Power Sys & Followup of Previously Identified Items

ML20138F959
Person / Time
Site:	Turkey Point
Issue date:	08/29/1991
From:	Crlenjak R, Mellen L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20138F946	List: IR 05000250/1991033 ML20138F941
References
50-250-91-33, 50-251-91-33, NUDOCS 9610180129
Download: ML20138F959 (10)

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e rato UNITED STATES

'o NUCLEAR REGULATORY COMMISSION

[ o REGION 11

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g j 101 MARIETTA STREET, *

2 ATLANTA. GEORGI A 30323

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Report Nos.: 50-250/91-33 and 50-251/91-33

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Licensee: Florida Power and Light Company

9250 West Flagler Street

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Miami, FL 33102

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Docket Nos.: 50-250 and 50-251 License Nos. : DPR-31 and DPK-41 Facility Name: Turkey Point 3 and 4

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Inspection Conducted: August 19 - August 23, 1991

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Inspector: 3r- %&

L1 Mellen, Team Leader g/2eh t Date Signed

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l Team Member:

] L. King

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Accompanying Personnel: '

. L trum Approved by: (, .

! k. C/l'enJfd1E, Chif Datd Sig:ied i Operational Programs Section i

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Division of Reactor Safety '

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SUMMARY

. Scope:

i i This was a routine unannounced inspection in the areas of training and surveillance testing for the upgrade of the emergency power _

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system and follow-up of previously identified item Its purpose was to evaluate the licensee's performance in ,aplementing and i establishing a training program and to evaluate the development of the required surveillance program related to the upgrade of the

] emergency power syste ; Results:

l The NRC team found that the licensee had progressed in the areas of

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training and surveillance testing for the upgrade of the emergency l power syste The licensee had completed the integration of the l emergency power upgrade into the emergency operating procedure 9610180129 910903 *

PDR ADOCK 05000250 G PDR r

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accident mitigation strateg The sample of Emergency Operating Procedures and Off-normal Procedures reviewed indicated that the

' licensee had successfully incorporated comments from previous

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Emergency Operating Procedure inspections. The progress by the end

of this inspection was acceptabl An additional inspection will be conducted in late 1992 to review the completed program.

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REPORT DETAILS

. Persons Contacted

• Bladow, Quality Manager

• Gadow, Contract Engineer

* Hale, Engineering Project Manager

• Hollinger, Operations Training Supervisor i Knorr, Regulation and Compliance Supervisor

• Pearce, Plant Manager

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• lunkett, Vice President Nuclear

! * Powell, Licensing Support

! * Rose, Design Control Supervisor j Simon, Contract Engineer l * Sisk, Reactor Licensing Engineer i

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Other licensee employees contacted included instructors,

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engineers, mechanics, technicians, operators, and office personnel.

l NRC Representatives

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• Butcher, Senior Resident Inspector J

• Crlenjak, Operational Programa Section Chief a )

* Attended Exit Interview

l* Review of Emergency Operating Procedure Changes for the Emergency Power Upgrade j i

The inspectors reviewed Emergency Operating Procedures that i were affected by the emergency power upgrade. The Emergency Operating Procedures adequately incorporated the redesigned I power distribution system into the Emergency Operating Procedure accident mitigation strateg The Emergency Operating Procedures reviewed were well organized and followed the Westinghouse owners group guidelines for operations. The inspectors identified several minor discrepancie However, .

the procedures reviewed were technically adequate and the comments from previous inspections were appropriately dispositione A single concern identified the actions taken to verify containment integrity following a phase A or phase B isolation. The intent of the following steps was to ensure an adequate level of containment integrity following a phase A or phase B containment isolatio The instructions were inconsistent between Emergency Operating Procedures and between the actions taken following a phase A and phase B isolatio Some examples are as follows:

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d 2 EOP-E-0, Reactor Trip or Safety Injection, Dated 08/01/91

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Step 6b RNO If any cc stainment isolation Phase A valve is NOT closed, THEN manually close valv If valves can NOT be manually closed, THEN locally close

valve Step 14a RNO 2) Verify containment isolation

, phase B - ACTUATED l 3) Verify containment isolation phase B valve white lights on VPB -

All BRIGHT

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4) IF any containment isolation valve is NOT closed, THEN manually close valve (s).

l ECA-0.0, Loss of All AC Power, Dated 4/19/90 i

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Step 29b RNO The same as EOP-E-0 Step 6b RNO

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Step 31 RNO Verify containment isolation

phase B actuated.- IF containment isolation phase B NOT actuated, THEN manually actuate.

{ Verify containment isolation phase B valve white lights on VPB -

l All BRIGH If any containment isolation Phase B valve is NOT

closed, THEN manually close valv If valves can NOT be manually

closed, THEN locally close valves.

< EOP-FR-H.1, Response to Loss of Secondary Heat Sink, dated 08/01/91 1 Step 16 RNO The same as EO?-8-0 Step 6b RNO -

None of the steps completely accomplished the required task.

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The inspectors interviewed selected operators and instructors to determine how the verification of phase A and phase B isolation would be accomplishe If the manual isolation of the valves failed the operators would evaluate the effected

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penetrations and isolate the valve inside containment only if i other isolation methods failed. The licensee stated that the

procedures would be revised to reflect the actual isolation

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methodolog s i The sanple of Emergency Operating Procedures reviewed

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} indicated that the licensee was aggressively pursuing the

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resolution of previously identified Emergency Operating

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Procedure deficiencie The completed procedures will be l reviewed in late 1992 and is identified as part of inspector

, followup item 250,251/91-33-01: Review of Emergency Operating Procedures and Off-normal Operating Procedures after the 1992 j revision cycle is completed.

l Review of Off-normal Operating Procedure Changes for the

Emergency Power Upgrade

The inspectors reviewed Off-normal Operating Procedures for.

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Loss of Offsite Power and its subsequent restoratio The

Off-normal Operating Procedures reviewed adequately 1 incorporated the redesigned power distribution system. The j inspectors identified minor discrepancies.

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The sample of Off-normal Operating Procedures reviewed indicated that the licensee was aggressively pursuing the

. resolution of previously identified Emergency Operating

] Procedure deficiencie The completed procedures will be

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reviewed in late 1992 and is identified as part of inspector

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followup item 250,251/91-33-01: Review of Emergency Operating Procedures and Off-normal Operating Procedures after the 1992

revision cycle is completed.

l Review of 0-ONOP-105 Control Room Evacuation

The inspectors reviewed the portions of 0-ONOP-105 that I

specifically concerned the restoration of power following a i

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control room evacuation. The specific sections reviewed were:

' Enclosure 2, Transferring 3A 4KV Bus to Offsite

. Power.

The inspectors compared the breaker numbers with

the drawings and reviewed the sequence of power 1 isolation and its subsequent connection to offsite l powe The procedural steps were logical and l j accomplished the Cesired .onnection to offsite - i j power expeditiousl Th> t inspectors did not l l identify any diccrepancies.

l The inspectors reached the same conclusions for:

I 1) Enclosure 3, Transferring 3B 4KV Bus to Offsite l Powe .

2) Enclosure 4, Transferring 4A 4KV Bus to Offsite i Powe ; 3) Enclosure 5, Transferring 4B 4KV Bus to Offsite i Power.

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! Enclosure 6, Component KW Load Rating Char ~

The inspectors compared drawings 5613-E-6, ,

Emergency Diesel - Generator 3A Load List, Sheet 2, i 5613-E-6, Revision 3; Emergency Diesel - Generator

) 3B Load List, Sheet 2, Revision 3; 5614-E-6, Emergency Diesel - Generator 4A Load List, Sheet 1,

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Revision 3; and 5614-E-6, Emergency Diesel -

Generator 4B Load List, Sheet 2, Revision 3 with the information provided in this enclosur The j information in this enclosure was also compared to i similar information contained in E0P- The information provided from the three sources was

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identical and appeared adequat . Training and Qualification Effectiveness (41500)

The inLpectors completed the review of training and qualification effectiveness that was started in Inspection Report 250,251/91-2 The inspectors interviewed selected i operations personnel to determine the effectiveness of the training for the emergency power upgrad The operations j personnel interviewed had received training on the i modifications and subsequent procedure change The i procedures that were incomplete during the 250,251/91-20 i.

inspection had been completed and successfully incorporated into the training program.

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i Surveillance Testing and Calibration Control (61725)

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The inspectors completed the review of surveillance testing

and calibration control that was started in Inspection Report

, 250,251/91-20. The inspectors examined the procedures for the j

scheduling of surveillances associated with the emergency power upgrade:

, ADM-215 Plant Surveillance Tracking Program dated

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i 8/19/91

' OSP-20 Schedule of Plant Checks and .

Surveillance dated 8/19/91

1 The procedures contained detailed instructions on the duties

and responsibilities of all individuals involved in the

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scheduling and performance of surveillance The review indicated that all surveillances associated with the emergency power upgrade had been include The inspectors interviewed

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the individual responsible for coordinating and administering the new computer system for scheduling surveillanc No problems were identified.

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• Human Factors Review

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The inspectors conducted a human factors review of Emergency Operating Procedures and Off-normal Operating Procedures using 0-ADM-101, Procedure Writer's Guide dated 8/15/91 and 0-ADM-211, Emergency and Off-Normal Operating Procedure Usage guide dated 8/15/91. Additionally, the inspectors performed a human factors walkdown of 3-ONOP-004.2 and 3-ONOP-00 The inspectors concluded that the procedures were well written, consistent, legible, and followed the Procedure Writer's Guide. The equipment identified in the procedures, such as breakers, were legibly labeled with the same nomenclature as in the procedures and easily accessibl Information on access to vital areas is contained in Inspection Report 250,251/91-3 The associated tools and

, equipment needed to perform the procedures, such as fuse

pullers, were easily accessible, and in good conditio It was also found that operator input was incorporated into the procedure For example, the breaker stripping order listed on Attachment 1 of 3-ONOP-004.2 reflected the order in which the breakers were found on the panels in the control room.

The following minor discrepancies were identified during a

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table top procedure review:

The Procedure Writer's Guide stated that procedure writers should avoid using the words decreasing and increasing in the procedure However, the two words are used a number of times in toe procedures reviewe Examples included, Steps 1, 23, 26, 33, and 43 in 3-EOP-E The other procedures reviewed had similar

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findings. The licensee stated that they would evaluate-

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the useage of decreasir.g and increasing and either change the Writer's Guide or the affected procedures.

I The verbs / terms Stabili'ee, Intact, Tie, Stripping, and Uncontrolled were used in procedures but were not defined in the Procedure Writer's Guide or the Emergency and Off-

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Normal Operating Procedure Usage guid .

CVI " Containment Ventilation Isolation" was used in

, procedures but was n% in ADM 0103.37, Standardization of

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Acronyms and Abbreviations dated 7/16/9 Step 7c.3) in 3-EOP-E-0 RNO stated "Use a setpoint of 100

, gallons per minute for required Auxiliary Feedwater flow j instead of the 390 gallons per minute specified in subsequent steps and procedures. " Step 21a.1) RNO states

" verify total Auxiliary Feedwater flow greater than 390

! gallons per minute." The 300 gallons per minute change

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was required when both units were using Auxiliary i

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Feedwate There was not a note or caution before Step 21a.1) to tell the operator to continue to use the 303

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gallons per minute setpoint or to stop using the 300

gallons per minute setpoint and to begin using the 390

gallons per minute setpoint. Additionally, there was no i

method for ensuring that the 300 gallons per minute would i be used in lieu of 390 gallons per minute after procedure transitio The terms " Cranking Diesels" and " Black Start Diesels" both refer to the same system in the procedares reviewed.

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j In Step 17 in 3-ONOP-004. 4 both terms are use The 1 licensee stated that they would evaluate the nomenclature i

and provide a consistent reference to the diesels.

' The table of contents for 0-ONOP-105 did not have the correct page numbers for most of the Enclosures and Attachments.

j The following minor discrepancies were identified during the

walkdowns of 3-ONOP-004.2 and 3-ONOP-004.3:

Procedure 0-ONOP-023.2 was missing from the local 3A l diesel startup station.

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Most of the gauges in the control room were banded / color l coded to indicate operating limits. However, the ammeter i on the Black Start Diesel tie line does not have any indicator to help the operator know when the amperage is approaching 0.63 kiloamp The value of 0.63 kiloamps

! could not be clearly identified on the indicator.

i l The unit 3 and unit 4 A, B, C, and D and the unit 3 and i

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unit 4 cross-tie ammeters were not labeled.

h Actions on Previously Identified Items

. (Closed) Inspector Followup Item 50-250,251/89-53-02: 1

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Three particularly weak Off-normal Operating Procedures  ! and overall weakness in off-normal Procedure . j

The inspectors reviewed a se_ected sample of Off-normal

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Operating Procedures and determined that the licensee was I addressing the concerns identified in the Emergency l j Operating Procedure revie The Off-normal Operating '

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Procedures reviewed were adequate and the balance of the I

. Off-normal Operating Procedures will be reviewed in late i

1992 and is identified as part of inspector followup item l l 250,251/91-33-01: Review of Emergency Operating 1

Procedures and Off-normal Operating Procedures after the j 1992 revision cycle is complete l l

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i (Closed) Inspector Followup Item 50-250,251/89-53-05:

Emergency Operating Procedure technical and human factors l

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deficiencies.

l The inspectors reviewed a selected sample of Emergency i

Operating Procedures for technical and human factors

, deficiencies and determined that the licensee was

addressing the concerns identified in the Emergency

Operating Procedure revie The Emergency Operating

Procedures reviewed were adequate and the balance of the

Emergency Operating Procedures will be reviewed in late I

' 1992 and is identified as part of inspector followup item

~250,251/91-33-01: Review of Emergency Operating l Procedures and Off-normal Operating Procedures after the l 1992 revision cycle is completed.

I i (Closed) Inspector Followup Item 50-250,251/89-53-06:

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Emergency Operating Procedure Writer's Guide deficiencies.

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The inspectors reviewed a selected sample of Emergency

' Operating Procedures for Writer's Guide deficiencies and determined that the licensee was addressing the concerns

identified in the Emergency Operating Procedure review.

l The Emergency Operating Procedures impleientation of the i

Writer's Guide reviewed were adequate and the balance of

the Emergency Operating Procedures will be* reviewed for l compliance with the Writer's Guide in late 1992 and is

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identified as part of inspector followup item 250,251/91-33-01: Review of Emergency Operating Procedures and

Off-normal Operating Procedures after the 1992 revision

! cycle is completed.

i i (Closed) Inspector Followup Item 50-250,251/89-53-07:

} Emergency Operating Procedure nomenclature and labeling deficiencies.

The inspectors reviewed a selected sample of Emergency

Operating Procedures for nomenclature -and labeling i deficiencies and determined that the licensee was .

addressing the concerns identified in the Et gency

Operating Procedure review. There were still a few minor j labeling deficiencies identifie The balance of the Emergency Operating Procedures will be reviewed for compliance with the nomenclature and labeling j requirements. Nomenclature and labeling will be reviewed

in late 1992 and is identified as part of inspector i followup item 250,251/91-33-01: Review of Emergency

Operating Procedures and Off-normal Operating Procedures after the 1992 revision cycle is completed.

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8 9.- Exit Interview

~ The inspection scope and findings were summarized on August

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23, 1991, with those persons indicated in paragraph 1. The NRC described the areas inspected and discussed in detail the

inspection findings. No proprietary material is contained in l this repor No dissenting comments were received from the

licensee.

Item Number Status Deacriotio Paragraph

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250,251/91-33-01 Open Inspector Followup Item -

Review of Emergency operating Procedures and i

off-normal Operating Procedures after the 1992

revision cycle is complete I 250,251/89-53-02 Closed Inspector Followup Item -

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^ Three particularly- weak off-normal operating j Procedures and overall weakness in off-normal

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Procedures.

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250,251/89-53-05 Closed Inspector Followup Item -

Emergency Operating

Procedure technical and human factors

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deficiencies.

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250,251/89-53-06 Closed Inspector Followup Item -

Emergency Operating Procedure Writer's Guide deficiencie ,251/89-53-07 Closed Inspector Followup Item -

Emergency Operating .

Procedure nomenclature and 1abe1ing

deficiencies.

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