L-86-389, Responds to 860812 Confirmatory Order & Notice of Violation. Corrective Actions Implemented in Areas of Design Control, 10CFR50.59 Evaluations,Tech Spec Compliance,Procedural Controls,Control of Maint Activities & Timeliness
| ML20210T515 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/01/1986 |
| From: | Woody C FLORIDA POWER & LIGHT CO. |
| To: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| EA-86-020, EA-86-20, L-86-389, NUDOCS 8610090050 | |
| Download: ML20210T515 (31) | |
Text
_ _ _ _ _ _ _ _ _ _ _
P. o. Bon 14000, Juno BE ACH, F L 33408 l P'O DCS FLomDA POWER & LIGHT COMPANY
. OCTOBER 0 1 1986 L-86-389 Mr. James M. Taylor, Director Office of Inspection and Enforcement United States Nuclear Regulatory Commission Washington, D. C. 20555 Re: Turkey Point Units Nos. 3 and 4 Docket Nos. 50-250 and 50-251 EA-86-20
Dear Mr. Taylor:
In accordance with 10 CFR 2.201, this response is submitted to your letter of August 12, 1986, transmitting a Confirmatory Order and Notice of Violation (NOV), with respect to our Turkey Point facilities.
We have carefully examined the NOV and as a result of our review of the issues involved, we do not believe it appropriate to contest the NOV. Therefore, our check in full payment of the assessed penalty is enclosed.
As I advised you in my letter of September 3,1986, requesting on extension of time to file this response, we wished to review the NOV carefully to assure ourselves that the corrective actions properly addressed the basic issue (s) underlying each matter.
Accordingly, in Appendix 1, we have described the programmatic improvements in place or planned, together with their associated schedules in each of the six besic creas identified in the Notice of Violation:
(1) Design Control (2 50.59 Evo!uotions (3) Technical Specification Compliance (4) Procedural Controls (5) Control of Maintenance Activities, and (6) Timeliness of Corrective Action.
I believe you will find in reviewing Appendix ! that the corrective actions completed or planned, not only address the violations, but are designed to ensure effective management control by addressing their underlying causes. Because the oing beyond the specific violations, we plan to corrective actions are extensive, g(ILS), where oppropriate, so that both the NRC's use on Integrated Living Schedule staff and FPL's management con carefully monitor FPL's progress and make such adjustments os may be necessary to assure that appropriate priorities are assigned to each task. */
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FPL has initiated discussions with the NRC Staff regarding formal chption of an ILS by license amendment.
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PEOPLE.. SERVING PEOPLE
Mr. James M. Taylor, Director L-86-389 Page two The specific examples cited in each of the six oreas are discussed in Appendix 11.
Specific corrective measures to meet those identified deficiencies are also included in the some ottochment together with references to documents previously filed with the NRC.
This response and its associated programs have been carefully reviewed by FPL management; the necessary resources have been allocated to the effort and represent a commitment on the part of FPL management to its successful completion. We believe that the first task of management is to assure quality in every aspect of FPL's operations and this is reflected in a corporate-wide commitment to a Quality improvement Program (QlP) in which FPL's Nuclear Energy Department has played a lead role.
These concepts, adopted from techniques utilitzed in Japanese industry, emphasize the use of dato analysis to assign priorities, determine root causes of problems and formulate corrective actions. We believe that implementation of the GIP program at Turkey Point will assist in the' improvement in significant performance indicators, including reduced equipment failures and unplanned challenges to protective systems.
We believe th'ot Turkey Point, as reflected in the recent SALP report, has been headed in a positive direction for the post year. The impetus provided by the Safety System Functional inspection has, as noted in your letter of August 12, 1986, caused further improvements to be mode. We plan to work with the NRC to achieve our mutual goal of ensuring the margin of safety in the operation of Turkey Point is maintained. Accordingly, we would welcome your comments and suggestions, if any, on any aspect of the programs set forth in this response.
Very truly yours, Yl2 C.O.W Group e President Nuclear Energy COW /gp Enclosure Attochments (2)
Mr. Victor Stello, Executive Director for Operations, USNRC cc:
Dr. J. Nelson Grace, Regional Administrator, Region ll, USNRC
i Re: Turkey Point Unit Nos. 3 and 4 Docket Nos. 50-250 and 50-251 EA-86-20 APPENDIX l Basic Violations and Programmatic Corrective Actions 1.
Desian Control i
A.
Summary of NRC Finding:
Design changes were not subjected to j
oppropriate design control measures.
For example, system modifications were not always oppropriately translated into operating procedures, drawings, system descriptions, and design basis documents.
Quality standards were not always translated into procedures and
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drawings. Calculation assumptions and design inputs were not always appropriately documented.
Violations in this area were identified primarily in the Safety System Functional Inspection (SSFI) of the auxillory feedwater system (AFW) at Turkey Point.
B.
Underlyina Cause: As a matter of background, the Turkey Point units were designed and constructed at a time when many current standards did not exist or were interpreted differently.
Regulatory changes during the 1970's, especially offer the TMI accident, required significant additions and modifications to nuclear plant systems. In addition to i
these modifications, the Turkey Point units replaced all six steam generator tube sheets and tubes, rebuilt the steam generators moisture separators and installed two full flow condensate polishing systems.
This volume of work overstressed FPL's resources. The consequence of this condition was on inconsistency between the as-built modifications, j
drawings, procedures and personnel training.
C.
Programmatic Corrective Action: FPL is applying the lessons learned from the AFW 55FI to its conduct of a comprehensive review of select systems chosen on the basis of the importance of their role in safely shutting down the reactor or mitigating design basis accidents. Phase I of this effort has been completed, as previously discussed in FPL Letter i
L-86-112, dated March 19, 1986. Phase ll is under way. The select systems covered by the program will be systematically analyzed. */ As described in our letter, L-86-112, dated March 19, 1986, the work for each system includes:
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(1)
Establishing design criteria to be used in preparing the system design basis (e.g., single failure criterion, redundancy, electrical separation);
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Consistent with the requirements and schedule relief provisions of the order 3
accompanying the NOV, the milestones for the select systems review are i
expected to be incorporated in the Integrated Living Schedule (ILS) in occordance with their respective priorities and FPL's resources.
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(2)
Assembling current design and performance information on each system from the FSAR, Plant Data Book, Tech Specs and other sources; (3)
Reviewing each system against opplicable regulatory requirements; (4)
Reviewing as-built system design drawings and other documents to assure consistency between the documents and the system design basis; (5)
Reviewing calculations and engineering studies to verify that the system design bases are adequately supported by engineering calculations and/or analyses; (6)
Performing independent design verification of the selected system designs; and (7)
Performing walkdowns as necessary to confirm that system configuration is consistent with the established design basis.
This program will facilitate design modification evaluations and analyses of existing systems by establishing a readily accessible basis against which future modifications con be evoluoted.
It will also support the configuration control program.
The process of making changes to the plant will also be subject to more formal controls than in the post. Under a new program, o Standard Engineering Design Package is required for plant modifications, incorporating written instructions for the use of a Safety and Regulatory Reference Guide, o Functional Design Reference Guide and a Design Verification Reference Guide. The use of these guides will help to ensure that assumptions and inputs are adequately identified, correctly selected and properly incorporated into the design documentation. Each Standard Engineering Design Package includes a listing of drawings and a checklist for other documents that require revision as a result of the modification. This also helps to ensure maintenance of on accurate "as-built" plant design record.
The Institute of Nuclear Power Operations (INPO) has requested permission to incorporate FPL's Standard Engineering Design Package for nuclear plants into its document of industry " good practices."
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These new controls are reflected in a manual entitled " Standard Engineering Design Package for Nuclear Plants." Use of the manual will help to avoid the possibility of inadvertently affecting unmodified portions of a system being changed or related systems.
Under the manual, the review cycle for each plant modification involves prior meetings among Operations, Training, Technical and other affected l
departments to identify affected plant procedures and the need for new or modified procedures.
Administrative controls require that such l
procedures are written or chcnged as necessary and assign specific responsbilities for accomplishing these tasks. Furthermore, a Design Integration Review Team of engineers currently reviews plant 2
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modification designs developed by either FPL or contractor engineering organizations.
Reorganization of the engineering function and the increased staffing of both the engineering and technical organizations at Turkey Point have enhanced the effectiveness of the design control program. In early 1986 o Site Engineering Manager was oppointed, who reports directly to the Turkey Point Site Vice President.
To resolve and incorporate the changes made to the units over 100 engineers and technical support staff were assigned to the Turkey Point site on a temporary basis.
These organizational and staffing improvements have enabled the engineering organization to respond more effectively to requests for engineering assistance by having a dedicated Turkey Point site engineering group. The number of system engineers in the Technical Department has more than doubled with the addition of seven engineers, thereby reducing the number of systems assigned to each engineer and increasing the level of attention to design control with respect to each individual plant system.
D.
Date When Full Compliance Will Be Achieved: The draft report of the design basis reconstitution for the original scope of the Select System Review Program has been prepared. Af ter review and verification activities are complete, required modifications will be subsequently scheduled for implementation to take maximum advantage of the opportunities afforded by normal refueling outages, where appropriate, and will be reflected in the integrated Living Schedule.
The entire program, including further verification steps and walkdowns, should be completed by the end of the next Unit 4 refueling outage or in accordance with the ILS if issued as part of the license amendment process. The manual for the Standard Engineering Design Package has been issued and is currently in use for plant modifications.
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II.
50.59 Evaluations A.
Summary of NRC Findings:
Safety evaluations of plant design modifications were not always adequately conducted and the need for the evaluation of some plant modifications pursuant to 10 CFR 50.59 was not always recognized.
B.
Underlying Cause: Modifications performed in the mid 1970's were evaluated in accordance with the existing industry standards for 50.59 evaluations. The current industry standards for these 50.59 evaluations call for more formal and rigorous evaluations. This concern arises out of the fact that, as one of the nation's older nuclear plants, Turkey Point has been subject to an unusually large number of modifications.
Inadequacies in the coordination of some temporary or permanent modifications have contributed to o failure, at times, to recognize the need for, and conduct of, odequate 10 CFR 50.59 evaluations. These problems have been extensively addressed since the SSFl.
C.
Programmatic Corrective Action: The improved visibility of the site engineering organization and the increased engineering staffing levels described in Appendix 1, Sections I and VI, have enabled site engineering to conduct more rigorous, timely and controlled evaluations of permanent and temporary plant modifications during this year.
In addition, the increased staffing and organization controls are intended to avoid the possibility of making inadequately reviewed modifications.
The mere presence of this increased engineering staff will, we believe, also help to sensitize others to the procedures which must be followed in connection with modifications.
In generating a Standard Engineering Design Package for plant modifications, engineers use a Safety and Regulatory Reference Guide and a Functional Design Reference Guide to help avoid the possibility of overlooking any relevant off-normal operating condition.
The FPL Power Plant Engineering Department must concur with each Standard Engineering Design Package that is generated for a plant modification.
Additional control of temporary system alterations has been achieved through a site procedure revision requiring the Shift Technical Advisor to determine the necessity for on Engineering review under 10 CFR 50.59.
l Training of technical personnel and management attention to the I
implementation of the new and more formal plant modification process will ensure that necessary safety evoluotions are identified and conducted in a timely manner.
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D.
Date When Full Compliance Will Be Achieved: Corrective actions have been completed, except for the upgraded procedure for plant modifications which is currently under review and tentatively scheduled for issuance in October 1986.
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Ill.
Technical Specification Compliance A.
Summary of NRC Findina: Instances were identified in which there were inadvertent noncompliances with Limiting Conditions for Operation (LCO). In each case, there was a failure to recognize that certain plant equipment required for service pursuant to plant technical specifications was inoperable.
B.
Underlyina Cause: The difficulty experienced is attributable, in part, to: (1) inadequate procedures for identifying equipment taken out of service for inspection or repairs; (2) inadequate engineering review of non-conforming conditions; and (3) complexities and/or - lack of definition in the present technical specifications which are being updated and improved.
C.
Proarammatic Corrective Action:
With respect to inadequacies in procedures for identifying inoperable systems, procedures have been modified and implemented for issuing the clearances required to safely remove equipment from service for inspection or repair. The previous procedures provided for a process that grouped clearances for common systems with those for. Unit 3. These procedures have been modified to separate clearance control for common systems from that for Unit 3 and Unit 4.
A more aggressive approach to maintenance activities discussed in item V below will reduce the tendency, noted in the most recent SALP report on Turkey Point, "to operate around maintenance problems" by "on the spot changes" or compensating actions.
The expansion of the site engineering organization discussed in Section I of this response, the QA corrective action program discussed in Section VI and site engineering procedures now being implemented should also assist by providing more consistent, formal and timely engineering review of non-conforming conditions.
An additional feature instituted this past year is that the Turkey Point Regulation and Compliance Group is available to provide guidance to the operating staff on issues of Technical Specification Compliance.
The System Operability Reviews are completed, which provides the component level requirements associated with system operability. This extensive program provides a major resource to assist the plant departments in making operability determinations, which will in turn positively offect Technical Specification compliance.
Finally, as the Commission is aware, FPL has just submitted to the NRC a comprehensive revision of the technical specifications for Turkey Point making them more compatible with those used on newer plants.
This extensive effort has been described by the NRC Staff in the most recent SALP report for Turkey Point as being of " greater magnitude and scope than any similar initiatives at other utilities."
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Date When Corrective Action Will Be Complete: The foregoing changes have been completed, although further enlargement of the on-site engineering staff is contemplated.
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f IV.
Procedural Control n
A.
Summary of NRC Findina: As a result of the SSFl and a Region it 4
follow-up inspection, concerns were identified with respect to the odequacy of procedures and their controls, including the technical review of procedures prior to their release and dissemination.
B.
Underlying Cause: As one of the notion's older generation of nuclear j
plants, Turkey Point's procedures were revised and supplemented on on "os needed" basis over the years. They were not necessarily prepared by skilled, professional technical writers. -
C.
Proarommatic Corrective Action: As the Commission is aware, FPL, as port of its PEP program, has included a Procedures Upgrade Program (PUP) entailing the revision and writing of procedures in the areas of odministration, normal and emergency operations, os well as surveillance and maintenance.
The PUP is largely based on INPO i
guidance and good practices. This upgrading process hos been described to the NRC in previous communications.
i The PUP effort is being performed by contract technical writers under the supervision of FPL. Heavy emphasis is being placed on human factors to assure that procedures are " user friendly." The entire effort is governed by a writer's guide and a set of PUP procedures. The program was initiated over two years ago.
4 To ensure that procedures are understandable and consistent, a standard format is utilized and technical writers will frequently talk with people i
who are responsible for implementing procedures and observe operations l
In the field.
Drafts of procedures are reviewed by the offected departments; their comments are resolved and a revised draft may be l
circulated once more (particularly in the case of a major revision) to ensure that the resolution of comments has been satisfactory.
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Procedures are reviewed (including a formal 50.59 review by engineering as necessary) by QC personnel, by the affected departments, by QA personnel as oppropriate, and by the Plant Nuclear Safety Committee. New or revised procedures must be approved by the Plant Manager before being issued and distributed to users. As noted in the NRC's most recent SALP report on Turkey Point "the pre-l implementation review process is extensive and includes input from j
knowledgable staff members."
l The PUP - Document Control interfoce has been substantially upgraded j
over the past year.
A process exists, for example to ensure that l
revisions to procedures are accompanied by necessary transition documents and concellation letters. The details of the PUP - Document Control interface are addressed in Appendix ll,Section IV.B.
Compliance is clearly facilitated by having uniformly written, clear 3
l procedures to which personnel are trained. In recognition of the need to l
upgrade training materials to reflect the current and future procedure revisions, the Training Department has increased staffing requirements from 35 to 58 personnel with 45 of the 58 positions filled and i
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1 implemented a computerized training mateiiols data base.
These changes will improve configuration control of training materials including system descriptions.
FPL's management is most sensitive to the fact that, os noted in the recent SALP report and the instant NOV, instances of inattention to procedures have occurred.
The - Company has taken very severe administrative personnel actions in such instances and will continue to do so. Even more important is the instillation of oppropriate attitudes in this respect, and we believe the PUP program hos had a marked influence on personnel at Turkey Point.
Both operations and maintenance personnel are reluctant to act without proper procedural guidance and, as noted in the recent SALP report, the PUP program has had the effect of " reducing misinterpretations and personnel errors."
D.
Date When Full Compliance Will Be Achieved: The schedule milestones are set forth more completely in the Performance Enhancement Program.
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V.
Control of Maintenance Activities A.
Summary of NRC Finding: Various maintenance activities, including operability testing, were not always conducted in accordance with vendor requirements, procedures or documented instructions, and maintenance failed, in some instances, to promptly identify, correct and document significat conditions adverse to quality.
B.
Underlying Cause: Mointenance procedures, including those for both preventive maintenance and post-maintenance activities, required improvement, in add' tion, inadequacies in the documented system design basis and plant change packages resulted in a failure in some instances to specify rA:essary post-maintenance testing requirements.
C.
Programmatic Corrective Action:
The maintenance organization is currently undertoking a number of programs to enhance the effectiveness of maintenance activities. Programmatic improvements include: organization changes, increases in staffing, development of maintenance procedures, development of a formalized preventive maintenance program, incorporation of post-maintenance requirements into procedures, training in the areas of mechanical, electrical and I & C maintenance, and implementation of a computerized work order system.
A preventive maintenance section has been formed within the maintenance organization as the fourth functional area, joining mechanical, electrical and I & C. In addition, a permanent engineering staff of six engineers has been assigned to the maintenance organization to assist in field analysis of root causes.
Maintenance procedures are being revised and numerous new procedures are being written, porticularly in the preventive and post-mointenance arcos.
These will improve the level of control over maintenance activities and enable the maintenance organization to incorporate the INPO Guidelines on Maintenance.
The Analytical Based Preventive Maintenance Program (ABPM) is being developed to improve equipment reliability. The ABPM entails input from both industry and plant historical data, and research and analysis by Plant Senior Maintenance Discipline Supervisors. Innovative features of the program include consideration of predictive monitoring, plant oging effects, operability requirements such as possible LCO considerations, and equipment qualification requirements. The ABPM program is currently under development, and upon completion, plant operating equipment will be covered and a significant number of new procedures will have been generated. As an additional control on the preventive maintenance procedures, they will be reviewed by the Plant Nuclear Safety Committee.
FPL has developed a new criteria document that provides generic guidance for post-maintenance testing requirements on mechanical, electrical and I & C equipment. Based cn this generic guidance, 8
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existing procedures are being revised and new procedures generated as necessary to incorporate post-mointenance requirements into applicable maintenance procedures.
When the decision was made in August, 1984 to obtain INPO occreditation, maintenance training was moved from the maintenance organization to the site trotning department.
A training program, potterned on the INPO guidelines, has been established with the goal of enhancing training for each of the maintenance personnel. This training
' program along with the issuance of the new and revised procedures, particularly in the areas of preventive maintenance and post-rraintenance actions, will enable maintenance personnel to effectively implement the new programs.
A new Nuclear Job Planning System (NJPS) has been established to provide computerized planning control of Plant Work Order (PWO) issuance and tracking through the NJPS.
This file will enable the maintenance organization to track the history of individual items to identify precursors to malfunction and failure more effectively.
In addition, several odditional job planners have been added to the NJPS to improve the timeliness of PWO issuances.
D.
Date When Full Compliance Will Be Achieved: Organizational and staffing changes to improve the preventive maintenance and root cause analysis functions have already been implemented.
The other programmatic corrective actions described above and their schedules are incorporated in the Performance Enhancement Prograin.
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VI.
Timeliness of Corrective Action A.
Summary of NRC Finding: Although FPL has shown great initiative in identifying potential safety problems, corrective actions have not always been implemented in a timely and comprehensive way.
B.
Underlyino Cause: This concern is largely the result of limited lines communications between the Turkey Point site end the Juno Beach-based engineering organization, os well as the need for more on-site engineering support.
Historically, certain non-conformance reports (NCRs) could not be dispositioned on-site; likewise, requests for engineering assistance (REAs) had to be transmitted to, and processed by, the Juno Beach engineering organization.
C.
Programmatic Corrective Action: There has been a significant increase in the on-site engineering force at Turkey Point. The Site Engineering function now reports directly to the Site Vice President. The increased presence and visibility of the on-site engineering function has allowed NCRs and REAs to be dispositioned more promptly without the attendant communciations difficulties created by distance between the site and the corporate engineering group at Juno Beach.
To address the concern of satisfying operability requirements while identified deficiencies are being evoluoted, a proposed site engineering procedure is being finalized.
This procedure will formolize the requirements and responsibilities associated with determining the impact on operability and reporting of deficiencies. As part of this process, safety evoluotions by the Power Plant Engineering are initiated when appropriate.
The duties of the Technical Department system engineers are also discussed in a new site engineering procedure, which is in the final stage of review. These individuals will be considered the plant experts for their assigned systems, and would be expected to stay current on outstanding deficiencies being reviewed so that external evoluotions are not postponed without regard for safety significance.
The corrective action program is audited by the site OA organization which is accountable for assuring implementation of the program in accordance with applicable procedures.
As noted below, unless dispnsitioned within 10 days, NCRs generated by QC and Requests for Corrective Action (RCA) are entered on a computerized commitment tracking system (CTRAC). Beginning in July,1985, the frequency of OA oudits of the corrective action program (in part using the CTRAC system) is now done quarterly, instead of semi-annually.
The OA organization is now trending the performance of the corrective action program and reporting those trends on a quarterly basis. In addition, the new Performance Monitoring Group within the QA organization is more deeply involved in on-going activities of the Plant Staff and thus, provides more effective real-time monitoring of those activities including corrective actions.
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Other procedures developed by the site OC organizction within the post year require that NCRs and RCAs be resolved within 10 days or, if not, that they be entered on the CTRAC system with an q$ roved schedule for corrective action.
If the corrective action connot be completed in accordonce with the schedule, on extension may be requested in writing to the UA Superintendent. The OA Superintendent may grant only one extension up to thirty days. Subsequent requests con only be opproved by th=
Director of QA.
These changes have contributed to o more effective, operationally focused cor rective action program which con be monitored on essentially a real-time basis and regularly audited to assure proper implementation.
D.
Date When Full Compliance Will Be Achieved: The corrective actions described above are now implemented.
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i APPENDIX ll j
Specific Violations and Corrective Actions I.
Design Control A.
l.
Item I.A.I involves the failure to modify on Off-Normal Operating Procedure (ONOP) to reflect a change in the Upgraded Auxiliary Feedwater System which had been made in 1983.
Reasons for the Violation: There was inadequate coordination between the Power Plant Engineering and Nuclear Energy Departments to ensure updating of procedures to reflect plant changes and modifications.
Corrective Action and Date When Full Compliance Will Be Achieved:
The procedure in question, ONOP 0208.11, Annunciator List-Ponel l-Station Service, was changed to clarify immediate operator actions in the event of this alarm. It was approved by the Plant Nuclear Safety Committee (PNSC) on October 29, 1985. Further, EOP's have been revised to require operators to shif t flow control volves to manual from automatic control within 3 minutes of AFW actuation.
Plant Change / Modifications (PC/Ms)85-130 (Unit 3) and 85-131 (Unit 4), AFW Discharge Flow Control Volves Upgrades have been implernented.
These modifications replace the existing AFW valve trims with trims sized for operation at the revised setpoint and to limit flow through a stuck open valve. The trim change improves the volve performance and reduces valve oscillations.
Reduction of volve oscillations will reduce bcekup nitrogen supply consumption. Limiting AFW flow through a stuck open volve ensures adequate feedwater flow is available to the operating stecm generators and will prevent overpressurization of the containment building if the volve sticks open concurrent with a steomline break.
As noted in Appendix I, new procedures and programs have been initiated to ensure that PC/Ms are appropriately incorporated in operating procedures. Prior to initiation of the PC/M design activity, Power Plant Engineering and Nuclear Energy schedule on operability review meeting. This review ensures that Engineering is provided with the necessary system operating information.
This inter-department coordination will ensure that the pertinent plant procedures are identified, reviewed and modified to reflect the new system configuration.
Administrative Procedure AP 0190.15 (7/24/86) ' Plant Changes and Modifications" requires the Nuclear Stortup Department to verify with the Plant Operation Supervisor that new procedures are written and old procedures are modified where appropriate. Administrative Procedures AP 0109.1 (6/5/86) " Preparation, Revision and Approval of Procedures" and 0-ADM-100 (6/13/86) " Procedure Preparation, Review and Approval" identify specific responsbilities for preparing and reviewing procedures and procedure changes to ensure that information is complete and correct.
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2.
Item I.A.2 involves a deficiency in on Emergency Operating Procedure (EOP) which required on action (shutting volves) to be taken from the control room, but this action would have been overridden in certain operational situations.
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Reason for the Violation: The procedure EOP 20003 " Steam Generator
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l Tube Rupture" was not reviewed in a systematic fashion to ensure that inconsistencies between the system design and the procedure were i
identified and corrected. As a result, the procedure failed to reflect a design feature which would have prevented the operators from isolating i
the AFW steam supply from the offected steam generator under certain j
operating conditions, as required by the procedure.
Furthermore, operators were not trained to utilize alternate means to achieve the necessary isolation.
I Corrective Action and Date When Full Compliance Will Be Achieved:
All operators received the necessary training during the fall of 1985.
An on the spot change (OTSC) to EOP 20003 was made during the some period, reflecting the alternate means of isolating the AFW from o faulted steam generator.
In addition, as noted in Appendix 1,Section I, the AFW system, as well os the other systems subject to the Design Basis Reconstitution Program, is being reviewed to ensure consistency between the design l
I basis and other documents, such as procedures. The vastly expanded training program will indoctrinate Turkey Point personnel with respect 1
to these new or updated procedures.
I As in the case of I.A.I., new controls have been established to ensure that design inputs are correctly translated into operating procedures.
I 3.
The example illustrates an inconsistency between a procedure
'c (7300.2), which allowed 15 minutes without operator action, and the AFW system description and design bases, which allowed only 10 minutes without operator action.
Reasons for the Violation:
Procedure 7300.2 "AFW System Flow Control Valves Instrument Air / Nitrogen Bockup System Operation," was i
not systematically reviewed to ensure consistency among the design basis, the system description, and associated training materials.
1 Because of the inadequate operator training and incorrect procedural information avalloble, the team locked assurance that oppropriate operator oction would be token in the event of a low nitrogen pressure j
annunciator alarm following a loss of instrument cir.
Corrective Action and Date When Full Compliance Will be Achieved:
Procedure 7300.2 was revised as part of PC/M 80-117. The revision reflected the nitrogen system being split into two independent trains and provided operator guidance in the event of a low pressure alarm.
The nitrogen setpoint has been changed to allow operator action to restore additional nitrogen supplies.
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The programmatic corrective actions described in the response to I.A.2.
will also help to ensure that the system design basis is correctly reflected in procedures and training materials.
4.
The AFW system description indicated that 286 GPM of AFW flow he delivered to each unit within three minutes with only one oumo 7
available. However, the EOP's did not ensure that control room personnel would balonce flows as required within the allowed time.
Reasons for the Violation: The procedures EOP 20004 (Loss of Offstie Power) and 20007 (Loss of All A.C. Power) failed to provide the information reflected in the system description with respect to the need to balance AFW flow with only one pump available.
Corrective Action and Date When Full Compliance Will be Achieved: A revision to Emergency Operating Procedure 20004, dated December 26, 1985, and Emergency Operating Procedure 20007 provides guidance to assure the required AFW flow is provided in the event of a two unit trip.
The Emergency Operating Procedures (EOPs) have been rewritten to incorporate the recommendations of the Westinghouse Emergency Response Guidelines (ERGS). The generic ERGS have been reviewed and opproved by the NRC. This was done in response to Supplement I to NUREG 0737, item 1.C.I.
Other programmatic corrective actions described in the response to I.A.2 ore intended to prevent similar recurrences.
5.
Procedure O-ONOP-103, " Control Room inaccessibility," did not odequately cover local centrol of AFW Train 2 even though the design is such, that local control is required in certain specified conditions.
Reasons for the Violation: The procedure O-ONOP-103 had not been 4
j systematically reviewed to ensure that it addressed a design basis requirement to provide local control of the AFW pumps.
Corrective Action and Date When Full Compliance Will Be Achieved:
4 Procedure 0-ONOP-103 has been revised as follows:
1.
Prior to taking any operator actions at Train I of the AFW System, the operator is directed to check the AFW flow gauces to determine train operability and report the findings to the Plant Supervisor - Nuclear.
2.
A PC/M has been completed to make the instrument air isolation valves for Train 2 of the AFW System easier to operate. A procedure change has been made to incorporate the PC/M information into the procedure.
i 3.
Instructions and setpoints have been incorporated to provide guidance to the operator on how to obtain proper flow to the steam generators utilizing a single AFW pump.
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4.
Instructions have been incorporated to address balancing of the AFW System flow to provide the necessary flow rate to each unit in the event only one pump is operable concurrent with a dual unit trip and both units requiring auxiliary feedwater.
5.
Instructions and setpoints have been incorporated to provide J
instructions to the operator for locally resetting and restarting a l
tripped AFW pump.
ONOP's are among the procedures that will be revised and upgraded as necessary in the PUP to ensure consistency with the system design basis, as described in Appendix 1,Section IV. Other programmatic corrective actions described in the response to I.A.2 are intended to prevent similar recurrences.
B.
l.
A change was made to certain pressure control volve setpoints, but it was not reflected on the appropriate P&lD.
Reasons for the Violation: Due to on administrative oversight, the change was not incorporated on the referenced drawing.
Corrective Action and Date When Full Compliance Will Be Achieved:
Revision 17 of Drawing 5610 M-339 and Revision 8 of the associated instrument index sheet 5610-M-Jll Sht.155 have been issued to reflect the current setpoint of 80 psig.
See Appendix 1, Section i for a description of programmatic corrective actions that are intended to prevent similar recurrences.
The Standard Engineering Design Package requires a listing of those drawings requiring update in order to maintain the as-built plant record. Administrative Procedure AP 0190.15 (7/24/86) " Plant Changes and Modifications" identifies responsibility for initiating drawing inclusion (new drawings) and revisions (old drawings).
C.
l.
Item I.C.l involves a failure to incorporate nitrogen back-up system equipment in the oppropriate Quality Instruction (JPE-OI-2.13 A), although it was safety related.
Accordingly, for maintenance purposes, it was not being treated as safety related.
Reasons for the Violation: This violation is attributable to failure to adequately reflect design changes in a current Q-List.
Corrective Action and Date When Full Compliance Will Be Achieved:
Power Plant Engineering has developed Quality Instructions (Qls) which define the requirements for modifications to and updating of the Turkey Point 0-List. These instructions require that o 0-List impact review be performed for all Turkey Point Plant Changes / Modifications (PC/Ms).
They further provide the engineer with specific guidance on the mechanics of preparing changes to the computerized 0-List Data Base.
15
FPL has updated the 0-List to the now-current document. Power Plant Engineering will maintain the G-List as a "living document" for future PC/M's generated for Turkey Point. This will be done through the use of the Standard Engineering Design Package described in Appendix 1,Section I. which includes on "Affected Document Checklist" to clearly identify those documents such as the G-List requiring revision.
Additionally, the PC/M package cover sheet clearly provides the appropriate quality classification of the change or modification.
2.
Certain switches were not designed or considered safety related although EOPs required operator action upon receipt of signals (nitrogen low pressure alarm) activated by those switches.
Reasons for the Violation:
Design modifications for the Auxiliary Feedwater System utilized the pressure switches and annunciation system installed under the original plant construction, which were neither designed nor maintained as nuclear safety-related. As a result, FPL believed that the separation criteria for these components were not changed from the original design basis of the plant.
Corrective Action and Date When Full Compliance Will Be Achieved:
FPL has since determined that this system will be redesigned as part of the Auxiliary Feedwater System upgrade which involves the addition and relocation of the Auxiliary Feedwater Nitrogen Stations. This redesign will consist of the installation of new qualified pressure switches, indicators and wiring thereto. A pressure switch at each station will be alarmed in the Control Room with a trouble light and will be of a safety grade design. PC/M 85-176 (Unit 4), nitrogen station additions and relocation, has implemented these changes on Unit 4, by means of a partial tornover. PC/M 85-175 for Unit 3 is scheduled to be completed during the next Unit 3 refueling outage.
Applicable programmatic corrective action entails the use of the Standard Engineering Design Package described in Appendix 1,Section I, which includes on "Affected Document Checklist" to clearly identify those documents such as the Q-List requiring revision. Additionally, the PC/M package cover sheet clearly provides the oppropriate quality classification of the change or modification.
D.
Items I.D.I to I.D.4 all involve on inconsistency between system descriptions and the system design bases.
l.
The AFW System Description indicated that an air signal was supplied to a differential pressure controller to maintain a certoic pump discharge
- pressure, but this design feature was disconnected. (l.D.1) 2.
The AFW System Description provided that check valves would open automatically when instrument air pressure dropped below 55 psig. As a result of a plant modification, however, the valves were set to open at 80 psig. (l.D.2) 16
3.
Operator oction described in the AFW System Description uiciated the single failure criterion and was inappropriate for the current system configuration. (l.D.3) 4.
The AFW System Description did not define either the length of time the AFW system could operate without operator action or the operating limits on the available nitrogen supply. U.U.4 Reasons for the Violations:
The program in place for review and updating of system descriptions to reflect plant changes or modifications on a current basis was not sufficiently systematic and comprehensive. In addition, augmentation of the training was necessary to accomplish the necessary review and updating.
Corrective Action and Date When Full Compliance Will Be Achieved:
Discrepancies between the AFW System description and the design basis have been corrected. Although this specific item oddresses a system description prepared on a one-time basis, FPL has implemented a systematic and comprehensive program for review and updating of the system descriptions used for training purposes. A total of 61 System Descriptions required review and updating. Priorities were established for the updating program. 52 of 61 System Descriptions have already been updated. The remaining 9 will be complete by November I,1986.
The Training Department has instituted a Training Information Management System (TRIMS) to ensure maintenance of configurorion control of training materials, including System Descriptions, such that they reflect future plant changes or modifications. The TRIMS program identifies the specific training materials that must be updated, using a system of change indicators such as PC/Ms, procedure changes, Technical Specification changes and user feedback.
The Standard Engineering Design Package review cycle described in Appendix 1,Section I, also provides for interfaces with the Training Department.
E.
Design changes were made which entailed on increase in the nitrogen consumption rate. This had the effect of invalidating the design for the nitrogen back-up system which was set to allow 15 minutes for operator action to restore the nitrogen supply.
Reasons for the Violation: FPL's response to inspection Report 85-40, URI 85-40-22 noted certain factual differences from NRC's description of the problem. However, it is clear that on appropriate procedure for testing the system following its modification would have identified the increase in the nitrogen consumption rate or the need for additional flow control volve trim.
Corrective Action and Date When Full Compliance Will Be Achieved: A procedure to dynamically test the nitrogen back-up system was prepared and issued. This test will identify any detrimental effects on nitrogen consumption created by modificatons to the AFW system. As ste.d in I.A.1, additional volve trims have been added which reduce nitrogen consumption.
17
The Standard Engineering Design Package and AP 0190 15 formalize controls and reviews of design changes in order to avoid inadvertently offecting unmodified portions of the system or related systems.
F.
Item 1.F involves inadequate compliance with a Quality Instruction in liiui 'ussumpilons und design inputs used in cclcv!ctions for cstcb!!shing the low level alarm setpoint in the condensate storage tank were not adequately documented.
Reasons for the Violation: Applicable instructions did not provide a sufficient requirement for documenting caMulational assumptions.
Corrective Action and Date When Full Compliance Will Be Achieved:
As to the specific calculation, FPL was able to confirm that the results of the original calculation were correct.
However, the underlying assumption was inadequately documented.
Quality Instructions have been revised to provide enhanced controls for documentaton of calculational ossumptions and inputs for both internal and contractor-developed calculations.
The Standard Engineering Design Package includes instruction to document methods, assumptions 3
and results so that a competent engineer could at a later date independently verify the results. The Design Verification Reference Guide now being employed in verifying (independent review) the design inputs, design process and results provides guidance that the assumptions and inputs be adequately identified, correctly selected and properly incorporated.
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II.
50.59 Evaluations A.
Item II.A involves on inadequate safety evaluation of a plant change (PC/M 80-117) in that the safety evoluotion did not analyze the operation of the system under the lowest' steam operating conditions.
Heosons - for the Violation: FPL believed that the maximum steam pressure in the AFW system was the bounding case for the range of i
system operaton for the purpose of the safety evoluotion performed.
i Therefore, no 50.59 evoluotion was performed for the lowest steam operating condition. In addition, the safety evaluation was performed by a vendor organizaton and was not independently reviewed by FPL.
Corrective Action and Date When Full Compliance Will Be Achieved: in response to NRC concerns, a confirmatory analysis has been performed at the lowest steam operating conditions (at the time the RHR System is put _ into operation) which has confirmed previous engineering l
judgement. This analysis is documented in Calculation MO8-462-02, dated October i1,1985.
The analysis demonstrated and confirmed odequate steam supply to the Auxiliary Feedwater pump turbines in the event of a complete failure of the steam vent line.
FPL instructions for assuring the proper review of plant changes or modifications are also being updated.
Standard Engineering Design Package preparation employs a Sofety and Regulatory Reference Guide and a Functional Design Reference Guide to ensure that oppropriate occident scenarios are addressed. The Design Verification Reference Guide (independent review) also provides guidance for requesting the Engineering Technical Licensing Section concurrence with the package.
AP 0190.15 requires the Turkey Point Technical Department to independently review PC/Ms and the Plant Nuclect Safety Committee (PNSC) to independently review PC/Ms for unreviewed safety questions.
B.
Item II.B involves on inadequate safety evoluotion for Temporary System Alterations (TSAs) in that the safety evoluotion did not consider the mechanical reliability of the AFW system being operated under o constant speed condition.
Reasons for the Violation: A safety evaluation was conducted for these TSAs in accordance with AP 0103.3.
However, the mechanical reliability of the pumps operating at a speed within the previously j
onalyzed operating range was not addressed. Reviews of TSAs were not adequately formalized nor was provision made for review at the necessary technical level.
Corrective Action and Date When Full Compliance Will Be Achieved:
To enhance management control of TSA evoluotions, the procedure (0-
.l ADM-503) has now been changed so that TSAs for equipment in service will be reviewed by the PNSC prior to installation.
i in addition, 0 ADM-503, " Control and Use of Temporcry System Alterations," was revised to incorporate a determination on the part of the Shif t Technical Advisor as to the necessity for on Engineering -
review under 10 CFR 50.59.
l 19 i
C.
In order to perform certain work, the Turkey Point units were placed in a configuration that required the diesel generator (EDG) loads to remain below 2750 kw.
An oppropriate 50.59 evoluotion was conducted of operatons under these conditions in support of the JCO. Subsequently, the configuration was changed to add additional loads to the EDG withour o further 50.59 evaivaiion.
Reasons for the Violation: Flont personnel relied upon a procedure, 3(4)-OP-006, "480 Volt Switchgear System to support PCM 83-155 (Appendix R Modifications)," which did not have a caution that cross-tie breakers should be rocked out and tagged to prevent a cross-tie which could overload the EDG. However, the Operations Department had taken on additional conservative measure, not required by the EDG loading evoluotion, JPE-l 59, Revision I, of de-energizing the 4D normal containment cooler (powered from the 48 480 volt load center) and taking it out of service on a clearance. In addition, with Unit 4 in cold shutdown, certain engineered safety feature equipment (not required for Unit 3 operation) was also taken out of service to prevent operation. Therefore, it was felt that the EDG loading limits would not be exceeded.
Corrective Action and Date When Full Compliance Will Be Achieved: A safety evoluotion of the April 14, 1986 alignment of the 48 loads and their offect on total EDG loading was performed by our Engineering Department.
The results of this evoluotion indicated that the conservative measure taken by the Operations Department resulted in on octual reduction of design basis occident EDG loading by 43 KW during the time the 48 load center was cross-tied to the 4A load center. Therefore, the evoluotion concluded that the loading on the EDGs would not have exceeded the limits specified in the EDG loading evoluotion, JPE-L-86-59, Revision 1. 3(4)-OP-006 has been revised to incorporate o caution in the infrequent operatons section of the procedure that states that unless both units are in a cold shutdown, the 480 volt load center cross-tie breakers shall be rocked out and tagged in accordance with AP 0103.4, "in-Plant Equipment Clearance Orders."
These breakers may be closed only in accordance with Technical Specifications, a safety evoluotion, or as directed by the Technical Support Center Staff when octivated under the emergency plan. After this incident, clearance togs were placed on the 480 volt tie breakers to preclude recurrence. A letter was issued to Plant Supervisors-Nuclear, emphasizing that no electrical system cross connects between trains con be made without first discussing the new clignment with the Engineering Department.
The programmatic corrective actions described in Appendix 1, Section 11 address the underlying cause of this event. Those changes highlight employee indoctrination and the use of the Change Review Team, Plant Review Board and Plant Nuclear Safety Committee, to review modifications to plant systems and components in a more formal manner.
l 20 w
i 4
111.
Technical Specification Compliance A.
An LCO was exceeded when certain steam supply check volves were l
found inoperable upon examination by radiographic techniques.
Reason.s for the Violation: The results of the radiographs indicated that I
the steam supply volves were unacceptable due to bent guide studs. At that time Engineering judgement concluded that no operability concern existed. Based on this, the volves were not declared inoperable.
Corrective Action and Date When Full Compliance Will Be Achieved:
Corrective actions for the finding were described in LER 250-06-001 transmitted to the NRC via FPL letter L-86-54 dated February 14, 1986. The following updates to those corrective actions are provided.
1 Plant Change / Modification (PC/M)86-009, Auxiliary Feedwater Steam Supply Valve Replacement, was completed for Unit 4 during the recently completed refueling outage. This PC/M replaced the existing motor operated solid wedge gate volves with a motor operated globe volves, installed tilting disc check volves both upstream and i
downstream of these motor operated globe valves, removed the existing downstream stop check volves, and converted the existing upstream stop check volves into manually operated globe volves. PC/M 86-011 will perform the same modifications for Unit 3 during the 1987 refueling outage for that unit.
Programmatic corrective actions include the improvement of i
procedures for identifying inoperable systems and clearances required l
to safely remove equipment from service for inspection and repair. In addition, the expansion of The site engineering organization and the enhanced QA corrective action program described in Appendix 1,Section VI, ensure a more consistent, formal, and timely review of non-conforming conditions.
1 B.
Unit 3 was taken critical for power operations offer a shif t turnover with three safety injection pumps operable; the Tech Specs require that four pumps are operable in these circumstances.
Reasons for the Violatiot-: Due to a personnel oversight during the review of the Unit 4 clearances, a Unit 4 safety injection pump was declared back in service although its discharge valves were closed. A temporary lif t of the pump's breaker was approved, but the valves were never released, because it was assumed they would be opened prior to criticality.
Corrective Action and Date When Full Comptionce Will Be Achieved:
The need to follow through on tasks and to conduct proper shift turnovers was re-emphasized to the operators. The operators were alerted to the difficulties associated with assuming on action will be taken, without following up to ensure it was actually done.
4 4
. m.
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The clearance procedure, AP0103.4, was completely revised, providing a streamlined, more user-friendly process for writing and handling clearances. As a result of this revision, there are now three clearance books -- one for each Unit, os before, and a third for common equipment, to ease the reviewing process.
Additionally, clearance numbers are now listed in the equipment out of service book, as per the i
iotest revisions to AF0iG3.4 und AP0iG3.2.
a l
22
IV.
Procedural Controls A.
l.
Item IV.A.I involves on inadequacy in the maintenance instructions in that they did not assure that safety-related instrumentation was properly aligned under certain conditions.
Reasons for the Vioiorion: The applicable instruciions, 0-SMi-G37.I, were insufficiently detailed for purposes of the particular maintenance activity.
Corrective Action and Date When Full Compliance Will Be Achieved:
Procedure 0-ADM-031 (Independent Verification) dated July 12, 1985, Step 5.3.1 requires independent verification of the removal and return to service of components controlled by equipment clearance orders.
Procedure 0-ADM-107 dated October 25,1985 (Writer's Guide for Maintenance Procedures), Step 5.8.4.C give directions for independent verification for preparing maintenance procedures. As port of the PEP maintenance activities, maintenance and surveillance procedures are being revised to incorporate instrument alignment independent verifications.
As noted in Appendix 1,Section IV, FPL has on extensive Procedure Upgrade Program (PUP) in place to revise and upgrade procedures, including maintenance procedures, on a plant wide basis.
2.
Item IV.A.2 involves several instances in which the Plant Nuclear Safety Committee failed to review certain TSAs within the time required by the procedure.
Reasons for the Violation: Administrative controls did not identify a single point of responsibility for assuring timely PNSC reviews of TSAs.
Corrective Action and Date When Full Compliance Will Be Achieved:
Shif t Technical Advisors (STAS) now have the responsibility for assuring that TSAs are prepared and evaluated properly (including 50.59 considerations). O-ADM-503 was revised to clarify the responsibility-for timely review of TSAs by the PNSC. The revision also enhances the i
adminstrative documentation and controls associated with TSAs. This coordination of the TSA preparation, evoluotion and review through a single point of contact provides assurance that TSAs are processed promptly.
l B.
Item IV.B involves a failure to ensure that a safety-related procedure (relating to the condensate storage tank) was approved for release by f
authorized personnel and appropriately distributed in occordance with established procedures.
l Reasons for the Violation: This problem occurred due to the complexity of the specific change.
In this case several procedures were being l
issued to replace one old procedure. Because one of the replacement procedures was undergoing review by a different section of the plant staff, the old procedure was inadvertently canceled before the l
replacement procedures were of ficially issued.
l 23 l
Corrective Action and Date When Full Compliance Will Be Achieved:
The principal corrective action is the establishment of a PUP-Document Control interface to handle the need to have fast and reliable transmittal of new procedures and associated documentation from PUP to Document Control so that Document Control con distribute the pivceddi=5 tc,63cis throughout the plc..t.
The interface is primarily one dedicated writer who hand corries material from PUP to Document Control on on as needed basis (usually daily or more often).
New procedures and procedure changes are assigned a unique number by PUP for tracking purposes. A tracking system has been set up to ensure that the procedures and documents offected by a new procedure are transmitted to Document Control as a package. This helps ensure that the correct documents / procedures are revised as required.
24
V.
Control of Maintenance Activities A.
I.
Item V.A involves a failure to perform prescribed monthly surveillance tests on batteries os required by technical specifications.
Reasons for the Violation: Vendor maintenance requirements were not incorporated in Plant Operating Procedure 9604.1.
Corrective Action and Date When Full Compliance Will Be Achieved:
Plant Operating Procedure 9604.1, dated December 4,1985 was revised to require specific gravity correction for electrolyte temperature and luel. This procedure was also revised to contain acceptance criteria for the specific gravity readings.
This procedure change had been planned prior to the inspection, but had not been completed.
On a programmatic level, the Standard Engineering Design Package os described in Appendix 1,Section I, provides guidelines and detailed references to startup testing procedures, vendor maintenance requirements, and periodic testing requirements os recommended by the equipment vendors, required by Technical Specifications or desired by the engineer.
2.
Item V.A.2 involves failure to perform odequate battery load tests as requirea by Tech Specs.
Reasons for the Violation: FPL considers that the one-half hour battery service test is adequate to demonstrate that the battery is capable of performing its intended safety function. This is based on the assurance described in the bases for the Technical Specification that, considering any single failure, battery charging current should be supplied in one-half hour or less.
Corrective Action and Date When Full Compliance Will Be Achieved:
This requirement will be reviewed through the Select System Review and the schedules associated with that effort will apply.
B.
1.
It was noted on on NCR that a search was required for three missing volve parts; the parts were not found and no documented basis was generated to establish the operability of the system when the units were returned to service.
Reasons for the Violation:
The main contributor to this item was inadequate procedural guidance in the area of documentation required prior to unit restart or exiting LCOs. In particular, this relates to NCR dispositions that offect equipment and/or system operability.
Correction Action and Date When Full Compliance Will Be Achieved:
New and more extensive controls have been implemented to assure both prompt resolution of NCRs and that the NCR hos been resolved before nonforming equipment that has previously been declared out of service is returned to service.
25 i
Procedure AP 0190.12, "Non-Conforming
- Material, Ports or Components" has been revised to require satisfactory NCR disposition for a nonconforming part or component that has been declared out of service prior to. returning the port or component to service. The GC department is responsible for ensuring satisfactory NCR resolution. In i
uddition, c OC Hold Point wi!! be cdded to PWOs requiring NCR disposition prior to returning the offected component to service.
2.
Personnel were aware of a potential condition in which a single valve for each unit could isolate two redundant condensate storage tank level transmitters. There was, however, failure to implement adequate procedural controls to ensure that these volves would be controlled in the open position.
Reasons for the Violation: The design basis for the addition of the redundant condensate storage tank level indication, installed under PC/M 80-77, was based on the connection to the tank being a possive portion of the system which allowed the redundant monitors to be on o common top. This approach was considered oc eptable at the time 1
because o single possive failure of this line or the isolation volve is not o design basis for Turkey Point.
Corrective Action and Date When Full Compliance Will Be Achieved:
The design modification process has been substantially improved since the time this modification was implemented in recognition of the need to coordinate changes in the. plant with operations and maintenace personnel, os described in Appendix 1, Sections I and ll. The program for the review of proposed plant modifications has recently been enhanced to ensure that the effects on operating documents, procedures and administrative controls are accommodated in the design prior to approval of the PC/M by the Plant Nuclear Safety Committee (PNSC).
Engineering personnel are also currently on distribution for the plant operating procedures. This provides the design engineer with a better insight into the octual operation of the system and the potential impact of modifications of the system.
Also, utilization of the Standard Engineering Design Package provides more rigorous controls on the PC/M evaluation process.
j 3.a.
Item V.B.3.o identifies failures to implement procedural j
requirements for documentation of post-maintenance testing in I & C and electrical safety-related plant work-orders (PWOs).
Also o procedure for post-maintenance testing addressed only
~
mechanical maintenance with no provision for post-maintenance testing associated with I & C and electrical PWOs.
Reasons for the Violation:
Maintenance procedures were not sufficiently formalized to ensure adequate post-maintenance testing and related documentation.
Corrective Ac.. and Date When Full Compliance Will Be Achieved:
1 AP 0190.28, 'Pos't Maintenance Test Control" guidance, was revised to cover I & C and elec. ical maintenance activities, as well as mechanical momtenance.
The Post Maintenance Guidance Document, issued in 26
.. -. -. ~. - -
l September 1985, has been incorporated into AP 0190.28 for criterio guidelines in establishing post maintenance testing on applicable maintenance procedures and PWOs.
3.b.
Item V.B.3.b involves failure to identify root causes of equipment failures on a large number of safety-related PWOs.
Reasons for the Violation: There were some inadequacies in the system for identifying, tracking, and evoluoting root causes of equipment failures.
Corrective Action and Date 'Nhen Full Compliance Will Be Achieved:
Journeymen, Supervisors and GEMS personnel have been directed to ensure that the " Analysis of the Cause or Reason" section of PWOs is completed. As stated in Inspection Report 85-40 (Page 4) "the inspector reviewed 15 safety related PWOs completed since the SSF inspection and noted that all 15 had the root cause section completed as required."
As noted in Appendix 1,Section V, the NJPS program has been vastly expanded. The Nuclear Job Planning System (NJPS), the development of which has been underway since the inception of PEP, requires on identical section to be completed on the CRT screen. These actions have enhanced root cause identification and appropriate corrective action implementation. NJPS automatically catalogs system equipment history. A total of six field engineers have been added to the three maintenance disciplines to enhance corrective actions offer root cause identifications. The inspection report also credited the Turkey Point Event Response Team (ERT) for its copobility to identify root cause of failures which should " subsequently reduce the repetitive failures that have occurred at the Turkey Point Plant."
Finally, the inspection report recognizes that "the automated PWO program which will provide trending information, the auto noted PM program, and the performance based maintenance training program, should also contribute to a reduction in repetitive equipment failures on a long-term basis." (IR 85-40, Page 4) l l
i 27
VI.
Timeliness of Corrective Action A.
Item VI.A involves a failure to take prompt and adequate corrective action offer it was determined that CCW flow through RHR heat exchangers appeared to be below that assumed for accident analysis purposes. CCW volves were repositioned from 30% to full open, but this was do..c veithout evc!uction er testing of the cdequacy of the Unw ta other components served by the CCW system.
Reasons for the Violation: In this specific instance, it had been a long-standing practice at Turkey Point to operate with the CCW discharge isolation volves for the RHR heat exchangers in a throttled position.
Therefore, Unit 3 was not shutdown immediately upon receipt of the safety system review results indicating a potential inadequate flow.
A preliminary evaluation was conducted to reposition the volves that addressed increased flow to the RHR heat exchangers and pump runout concerns. However, due to on oversight, the evoluotion did not address the effects of the change in CCW flow to other components. This was a preliminary evoluotion only and additional reviews and testing were done before the evoluotion was completed.
Corrective Action and Date When Full Compliance Will Be Achieved:
The corrective actions which specifically address this example are described in Turkey Point Unit 3 LER 250-86-009.
Programmatic corrective actions to prevent similar recurrences are described in Appendix 1,Section VI. In porticular, the augmented site engineering organization will provide more timely resolution and tracking of outstanding engineering evaluations.
B.
Item VI.B involves on extended delay in evaluating the safety significance of the failure of on intake Cooling Water (ICW) volve to close on loss of power and/or its control air supply.
After the evoluotion was performed, no analysis was done of ICW system operability or LCO compliance until questioned by Region II.
Reasons for the Violation: A request for a 10 CFR Part 21 evaluation was considered adequate and a separate operability evaluation or Part 50.59 evaluation was not conducted. Procedures did not always ensure that the safety significance of plant-identified deficiencies and the resulting impact on plant operability were reviewed in a timely fashion, in addition, procedures in place did not always provide for adequate tracking of engineering evaluations to ensure their timely completion.
Corrective Action and Date When Full Compliance Will Be Achieved:
The corrective actions which specifically address this example are described in Turkey Point Unit 3 LER-250-86-008 and FPL's response, L-86-21I dated May 16,1986, to inspection Report 250-86-10 and 251-86-10.
In addition, programmatic corrective actions are intended to prevent similar recurrences as described in Appendix I,Section VI.
New 28 i
~
corrective action program controls ensure that on operability review is performed in a timely manner and then additiona: evaluations ate performed as identified.
C.
Although a piping installation error in the Unit 4 Component Cooling Wcter (CCW) tre!.:s fer the common Unit 3/4 hinh hand <nfaty in,iaction system (SI) was identified in 1980, it was not corrected, but instead, the Unit 3 CCW trains to the Si pump coolers were used exclusively. Under certain conditions, the Si pumps on at least two occasions were susceptible to single failure induced inoperability.
Reasons for the Violation: Procedures did not always ensure that the safety significance of identified plant deficiencies and the resulting impact on plant operability were reviewed in a timely fashion.
In addition, procedures in place did not always provide for adequate tracking of engineering evaluations to ensure their timely completion.
Corrective Action and Date When Full Compliance Will Be Achieved:
Procedural controls have been implemented to ensure CCW train redundancy, depending upon system olignment, with one unit in cold shutdown and one unit at power operations. During the Unit 4 refueling outage a piping modification was made to correct the reverse flow condition.
In addition, as noted in Appendix 1, Section 11, engineers are now required to generate a Standard Engineering Design Package for plant modifications.
In doing so, they utilize a Safety and Regulatory Reference Guide and a Functional Design Reference Guide to help to avoid the possibility of overlooking any relevant off-normal operating condition. Furthermore, new instructions under development provide detailed guidance to angineers conducting 10 CFR 50.59 evaluations.
I 29
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