IR 05000250/1998011
| ML17354B212 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 12/09/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17354B211 | List: |
| References | |
| 50-250-98-11, 50-251-98-11, NUDOCS 9812230320 | |
| Download: ML17354B212 (36) | |
Text
U.S. NUCLEAR REGULATORYCOMMISSION
REGION II
Docket Nos:
50-251, 50-251 License Nos:
50-250/98-11, 50-251/98-11 Licensee:
Florida Power and Light Company Facility:
Turkey Point Nuclear Plant, Units 3 & 4 Location:
9760 S. W. 344 Street Florida City, FL 33035 Dates:
October 4 - November 14, 1998 Inspectors:
M. Sykes, Acting Senior Resident Inspector R. Reyes, Resident Inspector D. Forbes, Regional Inspector (Sections R1.1, R1.2, R5, R8.1, and R8.2)
S. Rudisail, Regional Inspector (Section E2.2)
Approved by:
L. Wert, Chief Reactor Projects Branch 3 Division of Reactor Projects 98i2230320 98i209 PDR ADOCK 05000250
PDR Enclosure
EXECUTIVE SUMMARY Turkey Point Nuclear Plant, Units 3 & 4 NRC Inspection Report 50-250/98-11, 50-251/98-11 This integrated inspection included aspects of licensee operations, maintenance, engineering, and plant support.
The report covers a 6-week period of resident inspection. In addition, the report includes the results of announced inspection by a regional Health Physics inspector.
~Oerations The licensee's overall planning, preparation, and execution of Unit 3 refueling outage activities were good. A non-cited licensee identified and corrected violation was issued involving one instance of personnel error and failure to comply with fuel handling procedures.
Thorough testing was professionally conducted to ensure reliable safety system performance.
Discrepancies identified as a result of surveillance activities were corrected.
(Section 01.2)
The Florida Power and Light Company Nuclear Review Board meeting was conducted in accordance with regulatory requirements and provided an independent review of the Nuclear activities at Turkey Point. (Section 07.1)
Maintenance Maintenance and surveillance activities were performed in a quality manner.
Procedures were in place and were adhered to by qualified maintenance personnel.
Interface between maintenance and operations personnel was good. Applicable FME controls, M&TEcontrols, PMT requirements, and QC hold points were properly accomplished.
(Section M1.1)
The licensee appropriately controlled equipment and material in the Unit 3 containment building following refueling activities to minimize potential adverse effects on emergency core cooling systems during postulated design basis accidents.
(Section IVI2.1)
Encni~eeiing After initial repairs on a leaking EDG radiator, post maintenance testing identified additional leaking tubes.
Engineering's initial extent of condition did not identify the full extent of the problem.
Subsequently, with technical assistance from radiator repair specialists, the radiator damage was appropriately assessed and repaired.
(Section E1.1)
The Unit 3 RCP oil collection system design modification installation was performed well and the design modification package was thorough.
(Section E2.1)
The licensee's implementation of modifications PC/M 96;092, Unit 3 CCW Head Tank Addition and PC/M 97-003, Unit 3 Thermal Overpressurization of Isolated Piping Modification, was conducted in accordance with the approved modification plans. The modification packages were thorough and the safety evaluations were adequate.
(Section E2.2)
The Unit 3 modifications associated with the diesel fuel oil transfer pump system, main turbine control valve servo motor test valve, and the motor operated valves 744A and 7448 equalization line were appropriately performed and the modification packages were well planned and documented.
Additionally, lessons learned from a previous modification were appropriately addressed and prevented similar issues from recurring.
Engineering and maintenance support during these modifications was a strength.
(Section E2.3)
The licensee was effectively maintaining controls for personnel monitoring, controls of radioactive material, radiological postings, radiation area controls, and high radiation area controls as required by 10 CFR Part 20. (Section R1.1)
The licensee was maintaining programs for controlling exposures ALARAand continued to be effective in controlling overall collective dose.
Allpersonnel radiation exposures during 1998 to date were below regulatory limits. (Section R1.2)
Health physics had detailed procedures describing the requirements for posting and de-posting contaminated zones. Health physics technicians exhibited a good questioning attitude prior to posting a new contaminated zone in the dry storage warehouse.
Housekeeping in the dry storage warehouse was good.
(Section R1.3)
Contractor health physics technicians employed for the Unit 3 outage met the training qualification requirements of technical specification 6.3.1.
(Section R5.1)
'
Re ort Details Summa of Plant Status Refueling outage activities were completed on Unit 3 during the inspection period and the unit returned to full power on November 2.
Unit 4 operated at or near full power during the inspection period and has been on-line since October 14, 1997.
I. 0 erations Conduct of Operations 01.1 General Comments 71707 Using Inspection Procedure 71707, the inspectors conducted frequent reviews of ongoing plant operations.
Specific events and noteworthy observations are detailed in the sections below.
01.2 Refuelin Outa e Activities Ins ection Sco e 37551 71707 62707 and 71750 The inspectors monitored the licensee performance during the scheduled Unit 3 refueling outage.
Observations of core alterations, safety-related equipment maintenance and testing, and control room activities were conducted.
Observations and Findin s Core Alterations On October 4, 1998, during fuel handling activities in the spent fuel storage building, once burned fuel assembly HH31 was inadvertently moved approximately 18 inches from its storage location. Fuel handling operators moved the the spent fuel pit bridge crane horizontally two storage cell locations with the hoist and handling tool in the down position after placing assembly HH31 in its storage location. This action was not in accordance with the controlling procedure.
The operators then recognized that the hoist was in the down position and decided to raise the hoist. After approximately 18 inches of travel, the operators noted unusual loading and halted the upward hoist movement.
The operators then took actions to lower the hoist to its previous position.
Subsequently, the bridge crane was moved to the original vertical position over assembly HH31 and the hoist was successfully raised.
The fuel handling operators notified station management of the incident.
Licensee management responded promptly to this event by initiating an evaluation of the fuel handling tool to inspect for physical damage prior to continuing the core unload.
Because of the potential for fuel assembly damage, visual inspections of the fuel assembly were performed with specific emphasis on the top nozzle, top spacer grid, and fuel rod alignment in the top grid. No physical distortions of the fuel handling tool or the fuel assembly were identified. Since this fuel assembly was scheduled for reuse in a rod
control cluster assembly (RCCA) location, drag tests were also performed using a burnable poison rod assembly (BPRA) with 16 thimble plugs and an RCCA. The tests indicated that the incident did not affect the assembly the joints below the top nozzle.
Drag testing results also met established acceptance criteria.
The licensee also identified several proposed corrective actions to address the human performance aspect of the incident. These actions were identified in Condition Report (CR) 98-1444 and included removal of the Senior Reactor Operator and Bridge Crane Operator from fuel handling responsibilities for the duration of the refueling outage for failing to immediately stop all fuel handling activities after identification of a problem.
The failure to cease fuel handling activities after identification of a problem was not consistent with management expectations.
The licensee is also evaluating procedural improvements as additional corrective actions.
The inspectors discussed this event and the proposed corrective actions with station management and confirmed that the actions associated with the inspection of the fuel handling tool would be. completed prior to continuation of core unload and the assembly would be visually inspected and evaluated prior to core reload.
The inspectors also reviewed the results of the licensee's investigation and concluded that the licensee adequately addressed the potential for damage to the fuel assembly and handling tool.
The failure to follow.the established procedural sequence during core unload was identified as a violation of regulatory requirements; however, this non-repetitive, licensee-identified and corrected violation is being treated as a Non-cited violation consistent with Section VII.B.1 of the NRC Enforcement policy. This is identified as NCV 50-250, 251/98-11-01: Failure to Follow Spent'Fuel Pit Bridge Crane Operation Procedure.
As,a follow-up to this event, the inspectors monitored core alterations including core reload, reinstallation of reactor upper internals, and control rod drive latching. The inspectors noted good communications and attention to detail during core alterations.
Appropriate communication between control room and fuel handling crews was maintained and equipment performance was good.
Radiation protection controls were adhered to and radiation protection technicians were attentive to ongoing maintenance activities within their assigned area of responsibility.
Diesel Generator Maintenance On October 3, 1998 during routine top deck inspections of the 3B Emergency Diesel Generator (EDG), the licensee identified a crack on a valve spring retainer seat.
Although the cracked retainer seat had not affected diesel generator operability, the.
licensee recognized the potential safety implications and replaced the retainer seat and sent the damaged component to the FP&L metallurgical laboratory for examination.
On October 8, 1998, during top deck inspection of the 3A EDG, the licensee identified a second cracked valve spring retainer seat and sent the damaged component to the diesel vendor for independent metallurgical analysis.
The licensee's preliminary metallurgical examination results indicated that the cause for the EDG 3B retainer seat failure was quench cracking from original manufacture followed by overload failure in
core material during operation.
The licensee has not completed the final report and is awaiting the results of the vendor analysis of the 3A EDG retainer seat.
Because of the concerns regarding the reliability of the spring seat material, the licensee chose to perform a complete replacement of all 3A and 3B EDG valve spring retainer seats.
The seats were replaced and EDG post-maintenance testing was completed.
No additional cracked valves seats have been identified.
The inspectors noted that the licensee's surveillance procedures were effective in identifying the degraded components on the 3A and 3B EDGs which could have adversely affected EDG operability if not corrected.
The inspectors also monitored licensee replacement of the 3B EDG governor actuator and booster pump. The replacement was enacted to correct intermittent DC power system grounds normally experienced during diesel generator surveillance testing. After replacement of the governor actuator, the licensee disassembled the original actuator and identified insulation damaged wire associated with the shutdown solenoid as the cause for the intermittent DC grounds.
The licensee also determined during subsequent testing that the replacement booster pump output was significantly less than the original and not sufficient to achieve reliable fuel rack positioning. The original booster pump was reinstalled and the 3B EDG was subsequently tested and performed satisfactorily.
The replacement pump was sent back to the vendor for problem identification and repair The licensee's systematic approach to identifying the root cause for the intermittent DC system grounds was excellent and subsequent testing of the 3B EDG was comprehensive regarding the identification of potential operability concerns.
ESF Testin The inspectors witnessed portions of the Unit 3 ESF testing from the control room and equipment areas following refueling outage activities and prior to Unit 3. restart to confirm that the licensee appropriately tested attributes of station equipment that may have been affected by outage maintenance activities. The test was performed to 1)
demonstrate EDG starting, load shedding, and emergency load sequencing in response to manually initiated Safety Injection (SI) and Blackout signals and 2) ensure correct movement of valves in response to the manually initiated Sl and Blackout signals.
Control room instrumentation response to changes in equipment status was adequate.
The inspectors also noted that few corrective work requests were generated as a result of test deficiencies.
The inspectors reviewed the test procedures and noted that the procedures had sufficient detail to provide guidance to personnel performing the test.
Coordination between Operations, Maintenance and Engineering was good. The inspectors observed routine information briefs throughout the performance of the test.
Unit 4 operating staff members had been briefed on expected equipment realignment during testing and ensured that shared equipment was not adversely impacted and remained available throughout the test evolution. Additional licensed operator support was utilized to minimize the impact on the normal operating crews during testing.
Routine maintenance and testing activities were minimized on Unit 4 during Unit 3 ESF testin e'
Following completion of the ESF testing, the inspectors also witnessed portions of the licensee's dilution to criticality. The inspectors noted good communication between operating crews.
Station management provided continuous control room coverage.
Conclusions The licensee's overall planning, preparation, and execution of=Unit 3 refueling outage activities were good. A non-cited licensee identified and corrected violation was issued involving one instance of personnel error and failure to comply with fuel handling procedures.
Thorough testing was professionally conducted to ensure reliable safety system performance.
Discrepancies identified as a result of surveillance activities were corrected.
Operational Status of Facilities and Equipment 02.1 General Plant Tours 71707 The inspectors performed general plant tours as described in Procedure 71707 throughout the inspection period. Areas included the emergency diesel generator rooms, auxiliary building, security truck gates, dry storage warehouse, Unit 3 outage work control center, and the Unit 3 containment.
Equipment operability, material condition, and housekeeping were acceptable.
Several minor discrepancies were brought to the licensee's attention and were corrected. Good organization and planning was noted throughout the observed licensee activities.
Operations Organization and Administration 06.1 Mana ement Chan e 71707 During the inspection period Mr. Terry Jones was named Turkey Point Operations Manager. Mr. Jones had been Acting Operations Manager since July 1998.
Prior to that assignment, Mr. Jones served as Turkey Point Operations Supervisor.
Mr. Wendell Prevatt was selected to succeed Mr. Jones as Tukey Point Operations Supervisor.
Previously, Mr. Prevatt was a Nuclear Plant Supervisor.
The inspectors verified that the American Nuclear Standards institute qualifications were met.
Quality Assurance in Operations 07.1 Com an Nuclear Review Board 40500 On October 20, 1998, Company Nuclear Review Board (CNRB) meeting No. 458 was held at Turkey Point. The inspectors attended the meeting and verified it was conducted in accordance with Technical Specification 6.5.2. Management representatives from St. Lucie also participated at the meeting.
The meeting agenda included reviews of significant condition reports, licensee event reports, QA program status, CNRB early warning indicators, NRC inspection reports, a Plant Managers report, and a proposed change to the Technical Specifications relating to the general maintenance leader qualifications. The CNRB board members exhibited good safety focus throughout the meeting in addressing potential issues.
The inspectors later
verified that the board members and alternate voting members met the qualification requirements as described in Technical Specifications.
The inspector concluded that CNRB meeting was conducted in accordance with regulatory requirements and provided an independent review of the nuclear activities at Turkey Point.
, II. Maintenance M1 Conduct of Maintenance M1.1 General Comments Ins ection Sco e 62707 and 61726 The inspectors observed maintenance and surveillance activities for selected components to evaluate the effectiveness of the licensee's maintenance program for equipment important to safety.
b.
Observations and Findin s During observations, the inspectors evaluated procedure use, assignment and performance of Quality Control (QC) hold points, foreign material exclusion (FME)
controls, measuring and test equipment (M&TE)controls, post-maintenance testing (PMT) and qualification of maintenance personnel.
The applicable revisions of procedures were in place and were conscientiously followed by qualified maintenance personnel.
Personnel had procedure or work order requirements clarified before proceeding with the activity. Maintenance supervision was closely involved with monitoring in-process maintenance work. Good interface between maintenance and operations personnel was observed.
Applicable FME controls, MSTE controls, PMT requirements, and QC hold points were properly accomplished.
The inspectors also observed that work activities were properly documented and problems encountered during the performance of the work activities were appropriately resolved.
c.
Conclusions Maintenance and surveillance activities were performed in a professional, manner.
Procedures were in place and were adhered to by qualified maintenance personnel.
Interface between maintenance and operations personnel was good. Applicable FME controls, MME controls, PMT requirements, and QC hold points were properly accomplished.
Maintenance and Material Condition of Facilities and Equipment M2.1 Containment Closeout Ins ection a.
Ins ection Sco e 71707 62707 and 71750 The inspectors conducted tours of containment areas to verify removal of maintenance and test equipment prior to Unit 3 restar Observations and Findin s With the reactor coolant system at operating pressure, the inspectors verified that accessible portions of selected safety-related systems and components were properly aligned and the areas were free of loose materials that could potentially impact plant operations during the recirculation phase of emergency core cooling system operation.
The inspectors noted that equipment was properly aligned.
Spare components staged in the containment building had been secured and evaluated to have no potential adverse impacts on vital equipment during normal and accident conditions. The inspectors noted minor maintenance activities in progress and confirmed that accountability measures were being used to track plant personnel and tools entering the containment building.
Conclusions The licensee appropriately controlled equipment and material in the Unit 3 containment building following refueling activities to minimize potential adverse effects on emergency core cooling system during postulated design basis accidents.
III. Engineering Conduct of Engineering Emer enc Diesel Generator Radiator Leaka e
Ins ection Sco e 37551 The inspector followed the corrective actions and maintenance repair activities of the 3A emergency diesel generator {EDG) radiator after tube leaks were identified during testing.
Observations and Findin s During testing of the 3A EDG, the licensee identified a leak in the diesel radiator. The cooling system is a wet/dry closed loop system that uses a water base solution, with added chromates, as the cooling fluid. The fluid heat is transferred to the environment by forced air convection utilizing a fan. Engineering reviewed various repair methods and decided to repair the radiator using in-house resources.
lt was believed that only one tube was defective. A repair procedure was written and the leaking tube was repaired.
The repair consisted of crimping both ends of the leaking tube and injecting an elastomer sealant in between.
A post maintenance test was performed which consisted of an EDG maintenance run to increase the radiator fluid level, temperature, and pressure to its normal operating limits. The licensee did not perform a static test of the radiator to-determine if additional repair was warranted.
However, during the post maintenance tests (PMT), additional leaking tubes were identified. The EDG was then stopped.
After subsequent static pressure testing of the tubes, the licensee identified six additional tubes requiring repair. The licensee consulted the EDG radiator manufacturer and obtained assistance from a local radiator repair facility. The decision
to limitthe scope of the initial engine'ering review of the radiator leak lengthened the EDG outage and inoperability.
The inspectors observed the static pressure testing and discussed proposed solder repairs, and the post maintenance tests with Engineering and Quality Assurance.
Additionally, the inspectors reviewed interim disposition ff3 to condition report 98-1561 which addressed this issue.
Each of the tubes was soldered closed.
As described in the condition report, long term corrective actions include replacing the radiator during the next Unit 3 refueling outage.
The root cause of the leaking tubes was still under investigation. The licensee stated however, that the most probable root cause of the damaged tubes was mechanical damage to the outside diameter of the tubes during recent maintenance activities performed near the EDG radiator.
C.
Conclusions After initial repairs on a leaking EDG radiator, post'maintenance testing identified additional leaking tubes.
Engineering's initial extent of condition did not identify the full extent of the problem. Subsequently, with technical assistance from radiator repair specialists, the radiator damage was appropriately assessed and repaired.
E2
~
E2.1 a.
Engineering Support of Facilities and Equipment RCP Oil Collection S stem Desi n Modification & S are RCP Vent Screen Installation PC/M No.97-046 Ins ection Sco e 71707 71750 and 62707 The inspectors reviewed installation of an improved oil collection system to ensure compliance with 10 CFR 50 Appendix R, Fire Protection Program for Nuclear Power Facilities.
b.
Observations and Findin s The inspectors reviewed engineering evaluations and observed installation of drip pans and associated piping to meet requirements specified in 10 CFR 50 Appendix R for oil collection systems for reactor coolant pumps (RCPs). The modification was necessary to ensure collection of RCP inventory from pressurized and unpressurized leakage sites of the RCP lube oil system thereby preventing oil fire migration in the containment building. The modification was necessary because of differences between the original RCP motors and the spare motor installed during this outage.
The spare motor oil inventory was determined to be approximately 275 gallons versus the original motor inventory of 200 gallons. The modification to the oil collection system was completed for Unit 3 but was not scheduled for Unit 4 since the current RCP oil collection system for Unit 4 is adequately designed and sufficient to capture the inventory (approximately 200 gallons) of the installed Unit 4 RCPs.
The inspectors observed installation of the seismically designed oil drip pans constructed of welded stainless steel sheet metal situated underneath potential drip locations and bolted to the existing RCP motor casings in accordance with approved
modification instructions.
Stainless steel drain pipes were also provided to direct any potential oil leakage to the main drain header and finally to the oil collection tank.
c.
Conclusion The Unit 3 RCP oil collection system design modification installation was performed well and the design modification package was thorough.
E2.2 Licensee Evaluation and Im lementation of NRC Generic Letter 96-06 Commitments a.
Ins ection Sco e 37551 The inspectors reviewed licensee modifications implemented to assure equipment operability and containment integrity during design basis accident conditions outlined in NRC Generic Letter (GL) 96-06. Specifically, the inspectors observed and evaluated licensee actions to preclude 1) the hydrodynamic effects of water hammer, 2) two-phase flow conditions, and 3) thermally induced over pressurization of water-filled piping sections within containment during postulated design basis accidents.
b.
Observations and Findin s The inspectors reviewed licensee documentation and evaluated the installation and operation of the component cooling water (CCW) system following design modifications.
The modifications addressed'he potential for thermally induced steam voiding in the containment air coolers supplied by the component cooling water system as identified in NRC Generic Letter 96-06. Design modification PC/IVI 96-092, Unit 3 CCW Head Tank Addition, increased CCW system static pressure by the addition of a static head tank at an elevation sufficient to prevent the air coolers from reaching saturation conditions during a design basis event.
The inspectors inspected portions of the modification and noted CCW system static pressure was increased approximately 29 psi. The inspectors also noted that CCW system surge capability was reduced when compared to the original available surge tank volume. The licensee maintained a 240 gallon operating range for system inventory which was equivalent to the original operating band of the CCW surge tank.
Additionally, the inspectors reviewed modification PC/M 97-003, Thermal Over Pressurization of Isolated Piping and the safety evaluation for this design change.
This modification was developed to address the concern of GL 96-06 related to the potential for thermal overpressurization of isolated water filled piping such as piping between containment isolation valves.
Engineering Evaluation PTN-ENG-SEMS-97-005 was completed to identify sections of piping where thermal Over pressurization potential existed.
The modification included the installation of six thermal relief valves and the modification of the failure position of valves CV 850A through 850F on the Safety Injection (Sl) Test Line. The failure position was modified to fail open from fail close.
The scope of the modification also included removal of obsolete test connections, installation of a new test connection for the Sl Test Line, and installation of an isolation valve and test connection on the discharge piping inside containmen c.
Conclusions The licensee's implementation of modifications PC/M 96-092, Unit 3 CCW Head Tank Addition and PC/M 97-003, Unit 3 Thermal Over pressurization of Isolated Piping Modification, was conducted in accordance with the approved modification plans. The modification packages were thorough and the safety evaluations were adequate.
E2.3 Diesel Fuel Oil Transfer Pum S stem Main Turbine Control Valve Servo Motor Test Valve and Motor 0 crated Valves 744A and 744B E ualization Line Modifications.
a.
Ins ection Sco e 37551 71750 and 62707 The inspectors reviewed and followed modification implementation activities on three modifications that were implemented during the Unit 3 refueling outage.
Maintenance and testing observations included activities during deep backshift.
b.
Observations and Findin s Diesel Fuel Oil Transfer Pum S stem PC/M 98-028 The diesel fuel oil transfer pump system is utilized to transfer fuel oil from the Unit 3 diesel fuel oil storage tank to either of the two emergency diesel generator (EDG) day tanks. The licensee had identified corrosion on the suction and discharge piping in the area where the piping entered the ground and, as part of the long term corrective actions, planned to abandon the underground piping and replace it with above ground piping. The modification replaced the underground pipe and also added two new isolation valves to allow isolation between the A and B EDG fuel oil transfer pumps to support system maintnenance.
The inspector verified that the licensee had appropriately documented these changes and that appropriate safety reviews had been performed.
Additionally, the licensee had provided in the modification package a contingency plan to ensure the TS limits would
'ot be exceeded during implementation, Although implementation logistics changed due to.delays associated with hurricane Georges, the modification was successfully implemented within technical specification (TS) allowed outage times for the Unit 3 EDGs. This modification is not planned for Unit 4 because the fuel oil transfer pump system is of a different design and does not include any underground piping.
Main Turbine Control Valve Servo Motor Test Valve PC/M 98-032 Operations had experienced several difficulties, which included power surges, during turbine stop valve testing.
Engineering had concluded that the servo motor test valves were sticking and were not reliable. This modification removed the servo motor test valves and installed a pressure control valve. However, the basic method and procedure of testing the turbine stop valves did not change.
Test procedures require main turbine stop valve testing on a quarterly basis.
Each stop valve is tested to ensure the valve fullycloses.
The licensee had experienced several difficulties during the steam header transition process during this testing.
Power surges
due to unreliable and sticking servo motor test valves were being experienced during the test, increasing the risk of a turbine and reactor trip. During the last stop valve testing, the licensee had to decrease power to approximately 20 percent to minimize the power surges.
This modification removes the left side servo motor test valves and installs a single pressure control valve (PCV) to the left side. The PCV hydraulically controls both left side servo motor control valves simultaneously.
The hydraulics portion of this modification tested satisfactory.
Several minor issues developed relating to the electrical circuitry design.
There had been some miscommunications with the electrical circuitry vendor and consequently engineering concluded that some control card components were underrated for the specific application. These issues were resolved and subsequently the electrical circuitry of the modification tested satisfactory.
The licensee plans to perform the same modification on Unit 4 during the next refueling outage.
MOV3-744A and 744B E ualizin Line Installation PC/M 98-016 This modification was performed on two residual heat removal (RHR) system 10-inch motor operated valves (MOV), MOV 3-744A and 744B.
MOV744NB are normally closed and are also required to open on low head safety injection. The modification installs a pressure equalizing line to prevent hydraulic locking of the valves.
This modification was performed inside containment.
The inspectors noted that health physics controls and fire watch personnel were appropriately utilized throughout the implementation of this modification. No significant issues developed during the implementation of this modification. The inspector noted that the same modification had been implemented on Unit 4 during the last refueling outage.
During that implementation, the licensee encountered several issues.
However, the issues and lessons learned from the Unit 4 modification had been addressed during the preparation of the Unit 3 modification package.
The inspector noted the modification package contained contingency plans in the event of similar issues developing, and that the valve packing procedures effectively incorporated the lessons learned from the Unit 4 modification.
The licensee implemented and tested all three modifications satisfactorily.
Minor issues were encountered through the implementation of the modifications. However, good engineering and maintenance support provided for expeditious and safety-conscious recovery plans. The inspectors noted continuous engineering field coverage and maintenance supervision throughout the implementation of all three modifications.
In general, the modification packages were weil written and contained good technical
'valuations and the safety reviews were thorough.
The inspectors reviewed specific portions of the modification packages with the responsible system and design engineers, and with engineering management.
The inspectors reviewed selected plant work orders, the maintenance and test procedures used, and also discussed the design and implementation work with the field engineers and field supervisors.
Additionally, the inspectors reviewed and discussed specific details of the work in progress with the mechanics and welders performing the jobs.
The mechanics and welders were very well versed with their portions of the job Selected prints, procedures, FSAR, and training briefs describing changes to systems and the implications to plant Operations were independently reviewed and verified to be correct. Through additional discussions with control room operators, the inspectors verified the operators were well versed with the Operations aspects of the plant modifications. Compliance with Technical Specifications action statements associated with equipment out of service due to maintenance and testing during the modification implementations were independently verified.
C.
Conclusions The Unit 3 modifications associated with the diesel fuel oil transfer pump system, main turbine control valve servo motor test valve, and the motor operated valves 744A and 744B equalization line were appropriately performed and the modification packages were well planned and documented.
Additionally, lessons learned from a previous modification were appropriately addressed and prevented similar issues from recurring.
Engineering and maintenance support during these modifications was a strength.
IV. Plant Su ort Radiological Protection and Chemistry Controls R1.1
~ 'our of Radiolo ical Protected Areas Ins ection Sco e 83750 The inspectors reviewed implementation of selected elements of the licensee's radiation protection program as required by 10 Code of Federal Regulations (CFR)
Parts 20.1201, 1501, 1502, 1601, 1703, 1802, 1902, and 1904. The review included observation of radiological protection activities including control of radioactive material, radiological surveys/postings, and radiation area/high radiation area controls.
b.
Observations and Findin s During tours of the Turbine Building, Units 3 and 4 Reactor Buildings, AuxiliaryBuilding, Radioactive Waste (Radwaste) Building, and storage and handling facilities, the inspectors reviewed survey data and observed activities in progress.
The licensee had effectively posted areas where radioactive material was stored and observed radioactive material was labeled as required.
During tours the inspectors also observed that Locked High Radiation Areas were locked and controlled as required by licensee procedures.
Radiological surveys reviewed were well documented and observed areas were posted consistent with the survey documentation.
Calibrations for "in use" direct radiation and air sampler instrumentation were current for those instruments observed.
During the facilitytours, overall radiological housekeeping was observed to be good.
The inspectors reviewed selected Radiation Work Permits (RWPs) for adequacy of the radiation protection requirements based on work scope, location, and conditions.
For the RWPs reviewed, the inspector noted that appropriate protective clothing and dosimetry were required.
During tours of the plant, the inspectors observed the adherence of plant workers to the RWP requirements. The inspectors determined,
l2 P
based on interviews, that RWPs were understood by workers prior to entering the Radiation Control Area (RCA).
The inspectors reviewed licensee condition reports involving control of two radioactive material items that had been recovered from outside of the RCA. The inspectors discussed the corrective actions with licensee management.
Corrective actions were appropriate.
Based on records reviewed, as of October 5, 1998, approximately 29 Personnel Contamination Events (PCEs), defined as contamination levels greater than 1000 disintegrations per minute, had occurred during 1998. This number of PCEs included both particles and dispersed contamination events for clothing and skin contaminations.
The inspectors noted overall efforts during 1998 to reduce personnel contaminations had been effective. The licensee was maintaining contaminated square footage at approximately 2.69 percent of the total RCA during outage periods and less than 1.0 percent during normal non-outage periods.
Conclusions
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R1.2 a.
The licensee was effectively maintaining controls for personnel monitoring, controls of radioactive material, radiological postings, radiation area controls, and high radiation area controls as required by 10 CFR Part 20.
Occu ational Radiation Ex osure Control Pro ram Iris ection Sco e 83750 The inspectors reviewed the licensee's implementation of 10 CFR 20.1101(b) which requires that the licensee shall use, to the extent practicable, procedures and engineering controls based upon sound radiation protection principles to achieve occupational doses and doses to members of the public that are As Low As Reasonably Achievable (ALARA).
b.
Observations and Findin s The inspectors review of the licensee's ALARAprogram determined the licensee had established a Unit 3 outage goal of 146.7 person-rem which was below the last Unit 3 outage of 163.729 person-rem.
At the time of the inspection on October 5, 1998, the licensee was tracking approximately 46.176 person-rem for the Unit 3 outage which was on target with daily projections.
Total site exposure for 1998 was approximately 64.054 person-rem compared to a 1998 total site exposure goal of approximately 185 person-rem. The licensee had tracked and trended outage exposures for purposes of future outage preplanning and it was determined that exposures continue to trend downward based on ALARAinitiatives. The inspectors observed a briefing for performing maintenance on flux mapping equipment and determined that it was interactive between the workers and ALARAplanners.
The briefing appropriately focused on dose reduction efforts and contamination control practices.
The inspectors also observed good radiological controls during steam generator maintenance.
The inspectors determined the licensee was maintaining programs for controlling exposures ALARAand continued
to be effective in controlling an overall collective dose.
Allpersonnel radiation exposures during 1998 to date were below regulatory limits.
The inspectors reviewed and discussed the licensee's efforts during the Unit 3 shutdown in regards to the chemical crudburst performed to reduce primary system dose rates.
The licensee had improved upon chemistry tracking and trending techniques during the shutdown crudburst to improve shutdown analyses.
Conclusions Based on records reviews, discussions with licensee personnel, and observations, the inspectors determined the licensee was maintaining programs for controlling exposures ALARAand continued to be effective in controlling an overall collective dose.
All personnel radiation exposures during 1998 to date were below regulatory limits.
R1.3 D
Stora e Warehouse aO Ins ection Sco e 71750 J'he inspectors reviewed the licensee's health physics procedures and controls used when posting and de-posting a contaminated zone (c-zone) in the dry storage warehouse.
Findin s and Observations During a plant walk down, the inspectors entered the dry storage warehouse (DSW)
which is located inside the radiologically controlled area. The inspectors noted that a c-zone had been set up near one of the truck entrances into the warehouse.
The inspectors found that rain water had entered and collected on the ground throughout the c-zone.
Although an adjacent sliding metal door was completely closed, the ground level in the DSW was slightly lower than outside the warehouse, and rain water from the outside entered and collected on the warehouse ground floor. The inspectors communicated these observations to licensee management.
Health Physics (HP) expeditiously addressed this issue and performed contamination surveys and found that the water in the c-zone had not spread any contamination.
In addition, the inspectors found that subsequently another c-zone had been set up near the same metal door. The area had been posted to segregate bags of waste based on the potential that the bags being segregated may have a hole, whereby a potential for radioactive contamination could exist. The floor was covered with herculite in the posted area to prevent contamination from getting on the concrete.
The inspectors discussed with the licensee the practice of establishing a c-zone near a door where rainwater could enter and subsequently risking the spread of contamination beyond the posted boundary.
The licensee agreed this is not a good work practice and additional precautions should be taken to avoid rainwater from entering posted contaminated area The inspectors reviewed the licensee's HP station procedures describing the requirements for setting up a c-zone and the related HP controls in the DSW. The inspectors reviewed procedure O-HPS-020, Radiation Surveys, O-HPS-021, Surface Contamination Surveys, and O-HPS-022, Airborne Contamination Surveys.'he licensee had documented surveys to comply with 10CFR 20.2103.
Also, the licensee had performed sampling to ensure average concentrations of radioactive material released in gaseous and liquid effluents at the boundary of an unrestricted area did not exceed the values specified in Table 2 of appendix B to 10CFR Part 20. The inspectors reviewed recent c-zone postings in the dry storage warehouse and determined that the c-zones had been posted as required by the licensee's procedures.
The inspectors confirmed that the rain water in the posted contaminated area had been cleaned up and surveys had been performed after the cleanup and after disestablishing the c-zone.
The survey results showed the area was not contaminated at the time the water was discovered or at the time the area was disestablished as a posted contaminated area.
Similarly for the subsequent c-zone that had been posted, the inspector reviewed the licensee's documentation and found that all procedures had been complied with in posting and de-posting the c-zone.
The inspectors interviewed two HP technicians, one FPL employee and an outage contractor, relating to the posting of two recent c-zones in the dry storage warehouse.
The technicians were knowledgeable of the HP requirements for posting and de-posting c-zones.
Also, the technicians exhibited a good questioning attitude relating to the reasons for posting of new c-zones.
The inspectors performed several walkdowns throughout the inspection period in the dry storage warehouse and noted that house keeping in the DSW was good and that the stored items were neatly kept and well organized.
Conclusions An inspector identified issue relating to rain water found in the area of a posted contamination zone was expeditiously addressed by the licensee. Since the area was not actually contaminated, the rain intrusion had no consequences.
Health Physics had detailed procedures describing the requirements for posting and de-posting, contaminated zones. Health physics technicians exhibited a good questioning attitude prior to posting a new contaminated zone in the dry storage warehouse.
Housekeeping in the dry storage warehouse was good.
Staff Training and Qualification in Radiation Protection and Chemistry Health Ph sics Contractor Qualifications Ins ection Sco e 83750 The inspectors verified the qualifications of contractor radiation protection technicians to determine if all qualification requirements were in accordance with Technical Specification (T.S.) 6.3.1. Technical Specification 6.3.1 requires each member of the unit staff meet or exceed the minimum qualifications of American National Standards Institute (ANSI) N18.1-1971 for comparable positions, except for the Health Physics
0'
Superintendent, who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.
b.
Observations and Findin s The inspectors verified through a review of qualification records that health physics contractor technicians employed for the Unit 3 outage met the T.S. 6.3.1 training qualification requirements for having a minimum of two years of working experience in that specialty.
During tours the inspectors observed contractor technicians perform surveys in accordance with licensee procedures.
Conclusions Contractor health physics technicians employed for the Unit 3 outage met the training qualification requirements of technical specification 6.3.1.
R8 Miscellaneous Radiation Protection and Chemistry issues {83750)
R8.1 Closed VIO 50-250 251/97-006-02:
Failure to control licensed b roduct material and make ade uate contamination surve s. The inspectors reviewed and verified corrective actions for VlO 50-250, 251/97-006-02.
Based on completion of licensee actions, this item is closed.
R8.2 Closed VIO 50-250 251/97-010-05:
Failure to control licensed b roduct material released from the radiation control area.
The inspectors reviewed and verified corrective actions for VIO 50-250, 251/97-010-05.
Based on completion of licensee actions, this item is closed.
V. Mana ement Meetin s and Other Areas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on November 25, 1998. The licensee acknowledged the findings presented.
The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary.
No proprietary information was identifie PARTIALLIST OF PERSONS CONTACTED Licensee T. Abbatiello, Quality Assurance Manager G. Hollinger, Licensing Manager R. Hovey, Site Vice-President D. Jernigan, Plant General Manager T. Jones, Acting Operations Manager J. Kirkpatrick, Protection Services Manager R. Kundalkar, Vice President, Engineering and Licensing M. Lacal, Training Manager C. Mowrey, Licensing Specialist M. Pearce, Maintenance Manager R. Rose, Work Control Manager
'. Skelley, Plant Engineering Manager E. Thompson, Site Engineering Manager D. Tomaszewski, Systems Engineering Manager J. Trejo, Health Physics/Chemistry Supervisor G. Warriner, Quality Surveillance Supervisor Other licensee employees contacted included office, operations, engineering, maintenance, chemistry/radiation, and corporate personnel.
j INSPECTION PROCEDURES USED IP 37551:
IP 40500:
IP 61726:
IP 62707:
IP 71707:
IP 71 750:
IP 83750:
Onsite Engineering Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems Surveillance Observations Maintenance Observations Plant Operations Plant Support Activities Occupational Radiation Exposure
ITEMS OPENED and CLOSED
~Oened 50-250, 251/98-11-01 Closed NCV Failure to Follow Fuel Handling Procedure (Section 01.2).
50-250, 251/98-11-01 50-250, 250/97-'006-02 50-250, 251-97-010-05 NCV Failure to Follow Fuel Handling Procedure (Section 01.2).
VIO Failure to Control Licensed Byproducts Material and Make Adequate Contamination Surveys (Section R8.1).
VIO Failure to Control Licensed Byproducts Material Released from the Radiation Control Area (Section R8.2).