ML17222A797

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Insp Repts 50-335/89-10 & 50-389/89-10 on 890312-0410. Violations Noted & Unresolved Items Identified.Major Areas Inspected:Tech Spec Compliance,Overall Plant Operations,Qa Practices,Site Security & Radiation Control
ML17222A797
Person / Time
Site: Saint Lucie  
Issue date: 05/10/1989
From: Crlenjak R, Elrod S, Michael Scott
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML17222A794 List:
References
50-335-89-10, 50-389-89-10, NUDOCS 8905190175
Download: ML17222A797 (18)


See also: IR 05000335/1989010

Text

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UN IT E0 STATES

'UCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W.

ATLANTA,GEORGIA 30323

Report Nos:

50-335/89-10

and 50-389/89-10

Licensee:

Florida Power 5 Li'ght Company

9250 West Flagler Street

Miami,

FL

33102

Docket Nos.:

50-335

and 50-389

Facility Name:

St.

Lucie

1

and

2

License Nos.:

DPR-67

and

NPF-16

Inspection

Conducted:

March

12

April 10,

1989

Inspector

. A. Elrod, Senior Resident

Inspector

. A.

ot

, Resident

Inspector

Approved

y:

Crlenjak

tion

C

f

ivision of Reactor

Projects

Date Signed

-) >la-(

Date Signed

l~S

at

Signed

SUMMARY

Scope:

This

inspection

involved

on site activities

in the

areas

of

TS

compliance,

overall

plant operations,

quality assurance

practices,

station

and corporate

management

practices,

corrective

and preventive

maintenance,

site security, radiation control,

and surveillance.

Results:

One violation was identified for failure to

use

the proper torque

pattern

when installing

the

Unit 2 containment

maintenance

hatch,

paragraph

6 (VIO 389/89-10-01)

Five unresolved

items" were identified:

2.

The staff was

unaware

of

GE SAL 188. 1 (HFA relays)

since

1986,

paragraph

6 (URI 335,389/89-10-02).

Validity of the

LTOP accident

analysis,

paragraph

9

(URI 335,

389/89-10-03).

3.

Applicability of

GDC 57 to the

SG

blowdown piping in light of

valve

bonnet

gasket

leakage

to

containment,

paragraph

10

(URI 335, 389/89"10-04).

4.

Operability

requirements

for

Containment

Coolers,

paragraph

3

(URI 335, 389/89-10-05).

Unresolved

Items are matters

about which more information is required

to determine

whether

they are acceptable

or may involve violations or

deviations.

EI905i90l75 S905iP

PDR

ADOCK 05000335

9

PDC

5.

Sealing

requirements

for

Class

1E

valve

solenoids

in

containment,

paragraph

3 (URI 335, 389/89-10-06).

This inspection

disclosed

no particular

widepsread

weaknesses

but did

identify

a concern

in the closeout

of the Unit 2

containment

prior to

entering

mode

4.

The majority of the areas

reviewed,

as they related to

the

Unit 2

outage,

showed

an

adequate

understanding

of

goals

and

processes.

The

level

of work detail

in the finalizing af the Unit 2

containment,

discussed

in section

3, displayed

a potential

lack of resolve

and

a lack of site inspection effort necessary

to clear work items for

positive work package

closure.

The violation identified by this inspection

was believed to be

an isolated

case.

As the

procedure

upgrade

program

proceeds,

the

inspectors

will

continue to routinely monitor procedure

adherence.

REPORT

DETAILS

Persons

Contacted

Licensee

Employees

K.

G.

  • J

J.

S.

H.

4'C

D.

  • R.

R.

W.

  • J

p.

C.

L.

"N.

B.

R.

AD

  • R

R

~

D.

W.

  • C

E.

C.

Harris, St.

Lucie Site Vice President

Boissy, Plant Manager

Barrow, Operations

Superintendent

Barrow, Fire Prevent Coordinator

Brain, Independent

Safety Evaluation

Group

Buchanan,

Health Physics

Supervisor

Burton, Operations

Supervisor

Culpepper,

Site Juno Engineering

Manager

Dawson,

Maintenance

Superintendent

Frechette,

Chemistry Supervisor

Hagar,

Nuclear Plant Supervisor

Harper,

QA Supervisor

Isaacs,

Nuclear Plant Supervisor

Leppla,

ICC Supervisor

Libby, Outage Supervisor

McLaughlin, Plant Licensing Supervisor

Rogers,

Electrical Maintenance

Supervisor

Roos, Quality Control Supervisor

Sculthorpe,

Reliability and Support Supervi

Sipos,

Service

Manager

Stewart,

Lead System

Engineer

Storke,

Outage Supervisor

Weller, Nuclear Plant Supervisor

West, Technical Staff Supervisor

White, Security Supervisor

Wilson, Mechanical

Maintenance

Supervisor

Wunderlich,

Reactor

Engineering

Supervisor

Wood, Nuclear Plant Supervisor

sor

Ot

me

her

licensee

employees

contacted

included

technicians,

operators,

chanics,

security force. members

and office personnel.

"Attended exit interview

Acronyms, abbreviations

and initialisms used in this report are listed in

the last paragraph.

Plant Status

Unit I began

and ended the inspection

period at power.

The unit ended

the

inspection

period in day

200 of power operation

since its return from an

outage.

During the

period,

the unit

had

two

blowdown valve

repairs,'imited

emergency diesel

maintenance,

and

CEA reed switch repairs.

Unit

2

began

the

inspection

period

in

day

68 of

a

maintenance

and

refueling outage that began

on February

1,

1989.

Restart

was anticipated

to begin

towards

the

end of the week of April 10.

During the inspection

period,

the unit had

an inadvertent

CIS actuation

(see

section

10 of this

report).

Plant Tours (Units

1 and 2) (71707)

The inspectors

conducted

plant tours periodically during the inspection

interval to verify that monitoring equipment

was

recording

as required,

equipment

was properly tagged,

operations

personnel

were

aware of plant

conditions,

and plant housekeeping

efforts were adequate.

The inspectors

also

determined

that

appropriate

radiation

controls

were

properly

established,

critical clean

areas

were being controlled in accordance

with

procedures,

excess

equipment

or

material

was

stored

properly

and

combustible materials

and debris

were disposed

of expeditiously.

During

tours,

the inspectors

looked for the existence

of unusual

fluid leaks,

piping vibrations,

pipe

hanger

and

seismic

restraint

settings,

various

valve

and breaker positions,

equipment caution

and danger tags,

component

positions,

adequacy

of fire fighting equipment,

and instrument calibration

dates.

Some tours

were

conducted

on backshifts.

The frequency of plant

tours

and control

room visits by site management

was noted to be adequate.

The

inspectors

routinely

conducted

partial

walkdowns

of

ECCS

systems.

Valve positions,

breaker/switch

lineups

and

equipment

conditions

were

randomly verified both locally and in the control

room.

As

a part of preparing for Unit 2 startup,

the licensee

conducted

valve

lineups

and walk downs of their HPSI

and

LPSI systems.

The valve lineups

were in accordance

with OP 2-0410020,

Rev 13,

LPSI/HPSI Normal Operation.

The inspector

observed

a portion of the

HPSI

system

valve lineup in the

RCB.

The operators

carried

a

copy of the

procedure

that identified the

valves

by number

and valve function description.

They utilized the valve

number

and valve type to confirm the valve's identity.

The valve

number

was

on

a tag connected

to the valve

by

a length of wire.

The inspector

verified that

a

number of the valves

checked

where consistent

with the

information on applicable

system drawings.

The valve lineup observed

went

per. procedure.

Independent verification of the lineup

was to occur at

a

later

time

using

the

same

procedure

but

by different operators.

The

inspector

had

no further questions

concerning

the validity of this valve

lineup.

During the

above

valve

lineup,

the

operators

utilized neither

piping

diagrams

nor

hand carried valve locator information to assist

them.

When

a valve could not

be located,

the operators

would call the control

room

requesting

assistance.

Valve location information

has

been

compiled

in

tabular form and was provided

when requested,

but efficiencies in control

room operations

and reduction of radiation

exposure

could apparently

be

gained

by preview of the information.

The

inspectors

walked

down portions

of SIT piping,

HPSI piping,

LPSI

piping,

and the charging piping inside the Unit 2

RCB at the

2A2

RCS loop,

where

these

piping

runs join or connect.

The applicable

drawing

was

Ebasco

drawing 2998-G-078,

sheets

110,

131,

and

132.

Work was continuing

in the area

as the outage

neared

completions

The charging line was still

unlagged

where it joined the

RCS.

The

remainder

of the piping run

had

been

relagged

or was still covered with lagging.

The charging line

had

been

examined

under

the licensee's

ISI program.

Prior to Unit

2 entering

Mode 4, several

tours of the

RCB were conducted

to evaluate

licensee

readiness

for heatup.

Several

minor discrepancies

were found and reported to the site management.

Several

more significant

items were observed.

They are discussed

below:

Sample

line tubing for several

SITs

was

found bent significantly.

The hot leg sample line, within the containment

penetration

boundary,

was bent

and

had obviously been

stepped

on.

None

had

been identified

by the licensee

and evaluated for stress

or operability.

These

have

subsequently

been evaluated.

The hot leg

sample

line valve solenoid inside containment

was loose

on the valve body.

This has

subsequently

been repaired.

The

inside-containment

electrical

penetration

covers

were

missing

many

fasteners.

Several

nearby

pieces

of cable

tray

cover

and

associated

fasteners

were

missing.

These

have

subsequently

been

repaired or completed.

The dogged

doors to the four containment

coolers

had

some or all dogs

unengaged,

yet had

been aligned for operation

and were running.

The

fans were not requi red by TS at the time.

The licensee

was informed

of the

unengaged

dogs.

This issue

is

URI 335,389/89-10-05

pending

licensee

evaluation

and

NRC review of the Unit

1 cooler configuration

and accident

performance.

The

power

leads

to Class

lE solenoid

valves

I-FSE-26-20,23,24

etc.

inside

containment

were unsealed

between

the solenoid valves

and the

Conax conduit seals.

The valves are

used to sample

containment air.

Plant

drawing

2998-B-271,

Sheet

11,

Rev

2 .required

that

they

be

sealed.

The

Rev

1 drawing,

in effect

when 'the unit was licensed,

specified 'ater'egarding

the sealing

requirements.

The licensee

has

subsequently

sealed

the

power leads.

This issue

is

URI 335,-

389/89-10-06

pending

licensee

evaluation

and

NRC

review of the

sealing

requirements

for these

valve solenoids.

4.

Plant Operations

Review (Units

1 and 2) (71707)

The inspectors,

periodically reviewed shift logs

and operations

records,

including

data

sheets,

instrument

traces,

and

records

of

equipment

malfunctions.

This review included control

room logs and auxiliary logs,

operating

orders,

standing

order s,

jumper

logs

and

equipment

tagout

records.

The

inspector s

routinely

observed

operator

alertness

and

demeanor

during plant tours.

During routine

operations,

control

room

staffing,

control

room

access

and

operator

performance

and

response

actions

were

observed

and

evaluated.

The

inspectors

conducted

random

off-hours inspections

to assure

that operations

and security

remained

at

an acceptable

level.

Shift turnovers

were

observed

to verify that they

were conducted

in accordance

with approved

licensee

procedures.

Control

room annunciator

status

was verified.

The

inspector

performed

general

reviews of the Unit

2

EDG tag out for

maintenance

and postmaintenance

electrical

tag outs.

With the

lA1 water box discussed

in paragraph

6 below returned to service,

the

inspector

observed

control

room operations

during

power ascension.

The inspector

observed

no problems with the power ascension.

The inspector

observed

the Unit 2

SDC system during mid-nozzle operation,

which was initiated after refueling

and landing the reactor vessel

head.

The operators

had

manned

both the local

and

control

room

nozzle

level

indications.

Certain operations

personnel

had been to an

INPO seminar

on

mid-nozzle operations

which apparently contributed to the site

operators'acility

in this area.

Smooth operation

in this

mode

was

observed

over

portions

of

a

three

day

period.

During this

period,

the

operators

reported

some blockage of a flow indication instrument line.

The blockage

was easily flushed from the line.

At all times observed

by the inspector,

the licensee

maintained

a watchstander

at

a temporary reactor water level

indicator inside the

RCB.

By March 30,

1989,

the licensee

had filled the Unit 2

RCS and prepared

to

remove

gases still trapped

in the

RCS

from the filling process.

The

applicable

procedure

was

OP 2-0120020,

Rev

27, Filling and Venting the

RCS.

The inspector

observed

operation

of the

RCPs

as

they were

used to

force or

sweep

the

gas

pockets

or voids in the

RCS

toward

system

high

points.

The four RCPs were alternately

run for brief periods.

When each

was

st'opped,

the

RCS high point vents

were

opened

and

then

closed

when

indication of pure fluid was

observed.

Procedure

OP 2-0120020

had

been

recently

revised

and

was

unclear

on

several

points;

three

temporary

changes

were required to make the instructions compatible (the last being

TC 2-89-154) with the desired intent.

The site was using the

SDCS relief

valves for RCS

LTOP.

During the performance

of the five second

pump runs,

one of the reliefs inadvertently lifted with no

harm to the

equipment.

The operators

reduced

RCS pressure

to reseat

the relief valve

and

then

resumed testing.

Technical Specification

Compliance (Units

1 and 2) (71707)

The inspectors

verified compliance with selected "TS

LCOs. This included

the

review of selected

surveillance

test results.

These verifications

were

accomplished

by direct observation

of monitoring instrumentation,

valve

positions,

switch

positions,

and

review of completed

logs

and

records.

The

licensee's

compliance

with

LCO action

statements

was

reviewed

on

selected

occurrences

as

they

happened.

The

inspectors

verified that plant procedures

involved were

adequate,

complete,

and

the

correct revision.

Instrumentation

and recorder

traces

were

observed

for

abnormalities.

Naintenance

Observation

(62703)

Station

maintenance

activities involving selected

safety-related

systems

and

components

were

observed/reviewed

to

ascertain

that

they

were

conducted

in

accordance

with requirements.

The

following items

were

considered

during this

review;

limiting conditions for operations

were

met, activities were accomplished

using

approved

procedures,

functional

tests

and/or calibrations

were performed prior to returning components

or

systems

to service;

quality control

records

were maintained;

activities

were

accomplished

by qualified personnel;

parts

and materials

used

were

properly

certified;

and

radiological

controls

were

implemented

as

required.

Work requests

were reviewed to determine

status of outstanding

jobs

and to assure

the priority was assigned

to safety-related

equipment.

The inspectors

observed

portions of the following maintenance activities:

This inspection

included

follow-up of instances

reported at another site

where

some Century Series

(nuclear safety grade)

HFA relays would bind and

fail to close if the four screws

in the

back that hold the coil to the

case

were

loosened

then retightened

after

shaking

the relay.

This would

simulate

the effects

of vibration or earthquake.

The site staff

had

procedures

for inspection

and testing of HFA relays

but was

not familiar

with this condition.

The first spare relay tested failed.

The site staff

consulted with the vendor

and found that the condition was discussed

in GE

SAL 188. 1,

HFA Armature Binding, dated

November

14,

1986, which could not

be found on site but was obtained.

The target date

range for the

SAL was

January,

1983 through October,

1986.

Licensee

inspection

found

109

HFA

relays in stores,

of which about

48 were Century Series.

Fifty six of the

109

showed target

date

codes

and

were all inspected.

Ten (nine Century

Series)

of the

56 failed

and

were

removed

from stores.

Failed

relays

seemed

to

have

been

received

in groups rather

than

scattered

throughout

the. inventory.

The remaining

53 relays in stores with date

codes

outside

the

. target

range

were

sampled

by

shipment

and

type, if a

shipment

contained

more than

one type.

None failed.

All Unit-2 installed

safety-

related

and control

room relays were inspected

by the licensee for target

date

codes - one was found. It passed

the inspection.

The plant staff's

response

to the inspector's

information was prompt and

thorough.

The plant staff plans

to inspect

Unit

1 installed relays

for

this condition during the

next

shutdown.

This appears

to be

reasonable

because

relays

are

routinely tested

upon installation

and during major

plant outages,

and

no failures in service

due to this condition have

been

identified.

Since the time of Generic Letter 83-28,

Salem

ATWS Event,

licensees

should

have

had

a program for capturing

and resolving

vendor information.

This

SAL was also

discussed

in

IN 88-14,

Potential

Problems

With Electrical

Relays.

That the site staff was

unaware of this

SAL until informed by the

inspector

is identified as

URI 335,389/89-10-02

pending further review by

the licensee

and the

NRC.

When silicone

and

lead levels

became

elevated

in the

1B

EDG engine oil

samples,

a contractor

was

engaged

to change

the oil and filters.

The

EOG

engines

(two diesel

engines drive one generator),

which had been recently

overhauled

during

an outage

ending in January

1989,

were completing their

break-in

period with this oil

change.

The

50ppm

lead

levels,

which

prompted

the oil

change

were

considered

to

be

from expected

bearing

break-in wear (the vendor

recommends

changing oil at 75ppm).

The silicone

was

thought

to

be

from

a

sealant

used

on gasket

seating

surfaces

and

thought

not to

cause

a

problem with engine

operation.

The

inspector

monitored the change

out and

examined

the three

sieve

screens

that filter

each engine's oil.

No problems

were identified.

An

inquiry

concerning

oil

around

the

(non-safety-related)

1A

main

condensate

pump

seal

and motor flange lip revealed

that the maintenance

department

was closely monitoring the

1A main condensate

pump motor, which

was losing approximately five pints of oil per week from a lower bearing

seal

(the reservoir for the bearing

holds thirty gallons of oil).

The loss

rate

had

been reported

as constant

over the previous

several

weeks.

The

site

had not had this type leak before

so the electrical

maintenance

group

had ordered

vendor drawings of the bearing

seal

area

in anticipation of

work.

A contractor normally overhauls

these

large motors during outages.

The licensee's

activities appeared

to be appropriate

and the inspector

had

no further questions

concerning this

pump motor.

On March 27,

1989,

Unit

1 reduced

power due to clogging of the condenser

tube sheets

by marine growth, with has

occurred routinely

and requires

a

power

reduction

for cleaning.

The

inspector

observed

part of the

1Al

waterbox tube sheet cleaning.

The

condenser

has

four

subcompartments,

or

waterboxes,

that

can

be

separately

taken out of operation for this cleaning.

The condenser

tubes

are protected

by plastic traps,

cylindric closed

screens,

which insert

into

each

tube

and

protrude

out into the

waterbox.

The traps

deter

organic growth from growing into the tubes.

Since

the relatively recent

advent of the traps,

cleaning

had consisted of pulling and

hand cleaning

the

traps

and

then

mechanically

raking

the

tube

sheet;

the

average

'leaning time with this method

was 8 to

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per waterbox.

Maintenance

personnel

had

opened

the

waterbox

when

a

load dispatcher

requested

that the unit be returned

to power to support

emergent

power

needs.

To

expedite

cleaning

and

closure,

maintenance

utilized

a

mechanic's

suggestion

to

use

a

small

pressure

washer to clean

the tube

sheet.

The

crew

cleaned

for approximately

forty minutes.

With the

pressure

washer,

the debris

around

and covering

the traps

was literally

blown off the

tube

sheet

and

traps.

Condenser

efficiency returned

to

nearly normal after the limited cleaning.

The licensee

has

subsequently

cleaned

all

of

the

Unit

1

condenser

waterbox

tube

sheets

with this

pressure

washing technique with an average

cleaning

time of four hours

per

waterbox.

During the return to power from the waterbox cleaning discussed

above,

the

inspector

observed

IKC department

personnel

replacing

a module

in the

B

channel

cabinet of the Unit

1

RPS.

The channel

had developed

problems

in

the high power trip portion of its circuitry during the previous

evening.

The operators

were extremely careful

during the power ascension

to check

the

operation

of

the

other

three

system

channels.

The

technicians

returned later that evening

and

replaced

other modules in the channel

to

finally remedy the problem.

The, inspector

reviewed

the plant work order

associated

with the work and found

no problems.

The installing of the Unit 2 containment

maintenance

hatch

and torquing of

the twelve mounting bolts

was

observed

.

Maintenance

procedure

M-0311,

Rev

5,

was

the

applicable

procedure.

The bolts

were

lubricated

as

specified.

The

procedure

specified

a

standard

x-pattern

for

torque

application

in two pa'sses,

with the intermediate

and final torque values

specified.

Maintenance

procedure

M-0039,

Threaded

Fasteners

of Closure

Connections

on

Pressure

Boundaries

and Structural

Steel,

defines

the

standard

x-pattern.

The personnel

installing the hatch actually

made

two

passes

at each

torque value but did not use the standard

x-pattern for any

pass.

One bolt was totally missed during the intermediate

torque setting.

TS 6.8. 1

requires

that

procedures

listed

in

Regulatory

Guide

1.33,

Appendix

A, shall

be

followed.

Appendix

A,

paragraph

9.a.,

includes

maintenance

that can affect the

performance

of safety-related

equipment.

Paragraph

3.f.

includes

procedures

for maintaining

integrity of the

containment

system.

-Failure

to

follow procedure

M-0311

is

a

violation

of

TS 6.8. 1.

335,389/89-10"01

Review of Nonroutine Events

Reported

by the Licensee (Units

1 and 2)

Non-routine plant events

were

reviewed for potential

generic

impact,

to

detect

trends,

and

to

determine

whether

corrective

actions

appeared

appropriate.

Events which were reported

immediately were also rev'ewed

as

they occurred

to determine

that

TS were being

met

and that the

public

health

and safety were of upmost consideration.

There

were

two security-related

LERs

that

were

reviewed

by regional

personnel.

The results will be found in IR 335,389/89-11

as

one violation

with two examples.

On March 21,

1989,

Unit

2

had

a

CIS actuation

while the unit was

in

a

refuel.ing outage.

With one of four containment radiation

channels

having

no output

and

being

troubleshot,

and

a

second

channel

being

disabled

(tripped) for maintenance,

an operator

pressed

the source

check pushbutton

for

the

channel

being

trouble

shot.

The

operator

believed

that

the

tripped channel

was bypassed

instead of tripped.

The operator

was trying

to get

some reaction out of the channel - he did.

The trip setpoints for

all of the

channels

had

been

reduced

to

90

mrem/hour

for the

outage

instead

of the higher

normal

set point of 10 Rem/hour.

The source

check

signal

exceeded

the

lowered trip setpoint

and tripped the

channel.

Two

out of four channels

being tripped properly initiated the

CIS.

The

CIS

actuation

then

properly initiated

an

EDG start.

Once

the

operator

realized

that

the

CIS

was

actuated,

he

reset

the trip

and

restored

effected

equipment to the desired state.

The running

EDG tripped

on indicated high crank case

pressure

coincident

with the reset

of the

CIS actuation

discussed

above.

The

EDG high crank

case

pressure

trip is

locked

out during safety-related

operation

and

reinitiates

upon reset

of the

safeguard

system actuation,

in this case,

the

CIS actuation.

The high pressure

indication

came

from oil splashing

on

a weakened

sensor in'he

crank case.

The

EDG had not yet received

a

planned modification to prevent extraneous oil splashing

from causing

EDG

trips.

The modification,

a

splash

guard

in front of the

sensor,

was

installed along with a

new sensor

shortly after the

EDG trip.

While attempting

to complete

a surveillance

on the

2A EDG a thrust pillow

block bearing

assembly failed on

a radiator cooling fan.

This occurred

on

April 6,

1989, after outage

repairs

which were not bearing-related

had

been

completed.

On Unit 2, there are

two diesels

per generator with two

belt-driven cooling

fans that cool

one radiator

per diesel.

The failed

bearing

took the thrust of one of the

fans for 56 minutes of a one hour

test prior to the

inner

race failing from undetermined

causes.

The

licensee

has committed to submit

a special

report

on the valid failure and

determine

potential

10

CFR part

21 reportabi lity.

The failed race

had

what appeared

to

be

an existing crack that

suddenly

propagated

farther

causing

a loss of the

race

and thrust loading.

The fan

moved into the

shroud

at

the

radiator.

The

fan. rubbing

on

the

shroud

alerted

the

operations staff to the problem.

The licensee

has initiated an inspection

of other bearings

on this

EDG

and

the

second

EDG serving

the unit; the

Unit

1

EDGs are of a different design.

The inspectors will follow up

on

this event,

which had

become

the critical path for the unit returning from

the outage.

Physical

Protection (Units

1 and 2) (71707)

The

inspectors

verified by observation

during routine activities that

security

program

plans

were

being

implemented

as

evidenced

by: proper

display of picture

badges,

searching

of packages

and

personnel

at

the

plant entrance,

and vital area portals

b'eing locked and alarmed.

9

~

Surveillance

Observations

(61726)

The

inspectors

verifiecl that

various

plant

operations

complied with

selected

TS

requirements.

Typical

of

these

were

confirmation

of

TS

compliance for reactor

coolant chemistry,

refueling water tank conditions,

containment

pressure,

control

room ventilation

and

AC and

OC electrical

sources.

The inspectors verified that testing

was performed

in accordance

with adequate

procedures,

test instruventation

was calibrated,

LCOs were

met,

removal

and restoration of the affected

components

were accomplished

properly, test results

met requirements

and

were

reviewed

by personnel

other

than

the individual directing

the test,

and that

any deficiencies

identified during

the testing

were

properly

reviewed

and

resolved

by

appropriate

management

personnel.

The following surveillance

tests

were

observed

The

performance

of the local

leak rate test of the Unit

2 containment

maintenance

hatch

was witnessed.

The procedure

was

OP

1300051,

Rev 3,

Local

Leak

Rate Testing.

The test

was

performed

smoothly

and

the

hatch

seal did not leak.

The inspector

had

no further questions.

The performance

of the Unit

1

AFW flow channel

check

was observed.

The

governing

procedure

was

IKC procedure

1-1400064F,

Rev 4, Installed

Plant

Instrumentation

Calibration (Flow), Appendix 'B', tab

6.

The inspector

observed

the check at the flow transmitter.

The site technician

used

the

appropriate

test

equipment

and

performed

the

procedure

correctly.

The

procedure

had specified neither the deflection

range for maximum flow nor

a tolerance

for that range.

This did not agree with a proposed

change

to

the

channel

check criteria

which

was

in

a

procedure

revision

to

an

administrative

procedure titled Schedule

of Periodic Tests,

Checks,

and

Calibrations.

The technician

had

independently

pulled

the

range

and

tolerance

information

from another

document

and written them

on his copy

of tab

6 of the procedure.

When asked. about

the the

range

and tolerance

absence

in the applicable

procedure,

the

inspector

was told that

the

procedure

was being

changed.

The inspector verified that this was,

in

fact,

occurring.

The

low pressure

side

isolation

valve

on

instrument

+T-09-2C was found to be leaking slightly; the leakage did not invalidate

the test.

The technician

took action to submit

a

PWO to repair

the valve.

~

The, inspector

had

no further questions

on this test.

Part of a periodic test

on the MSIVs was observed.

The procedure

involved

was

OP

1-0810050,

Rev 8,

Main

Steam

Valves

Periodic

Test,

part

8. 1,

Part-Stroke

Test of MSIV.

This

segment

of the test

was

performed with

Unit

1 at power.

The procedure

operates

the valves through approximately

5/8 of an

inch of travel.

The test

was

performed

per

procedure.

The

valves

were

returned

to their normal

operating

position.

The inspector

had

no further questions

on this test.

IN 89-32, Surveillance Testing of Low Temperature

Overpressure

Protection

Systems,

dated

March 23,

1989, arrived

on site prior to Unit 2 requiring

the indicated

valves for LTOP.

Initial licensee

evaluation

of. the

IN

'0

found that

more

consideration

was

necessary.

After reevaluation,

the

licensee

wrote

a

new

LTOP test titled "Test Method D" of Data Sheet

10 in

AP 2-0010125A.

During performance

of the test at

a test

pressure

less

than

the

LTOP

set

point,

the

Unit

2

valves

opened fully in about

2

seconds.

The

accident

analysis

of April,

1986,

page

21,

states

the

assumption

that the valves

would

pop

open

instantaneously

to their full

flow position.

The licensee

was

requested

to confirm that the accident

analysis

assumptions

are valid and actually bounc'he

system

response.

The validity of the

accident

analysis

is

URI 335,389/89-10-03

pending

licensee

completion of the evaluation

and

subsequent

NRC review.

10.

Outage

(71707)

The inspector

observed

the following overhaul activity during the ongoing

Unit 2 outage:

Licensee

performance

of portions

of the fuel bundle

and

CEA location

and

orientation verification,

as

a part of their refueling activities,

was

reviewed.

The fuel shuffle

had

been

completed

and work activities

were

moving

toward

reactor

vessel

closure.

With site

gC

present

and

independently

recording the data

on procedure

data

pages,

the operations

group

and reactor. engineering

personnel

video taped

the serial

numbers,

location,

and orientation of the components.

The personnel

involved with

the verification rode

the refueling bridge,

from which the underwater

TV

camera

was

suspended

and

operated.

The operation

was

conducted

in

a

methodical

and orderly fashion.

Visibility was excellent

and the data

recorded

while the inspectors

were present

agreed

with the

inspectors'bservations.

Clean

up and close

up activities within the containment

were observed just

prior to vessel

head installation. This included work controls for various

jobs that were active during this period.

Most jobs appeared

to be worked

through

from start to completion.

The job sites

were cleared

of debris

and

the

systems

were

closed.

The

exception-

was

the

electrical

yenetrations

and other items indicated in report section

3.

Clean

up

and

removal of scaffolding was orderly and accomplished

in a safe

manner with

little risk to adjacent

equipment.

With the

lower core

internals

in

place,

hydrolazing activities were observed

around the reactor vessel

area

and in the vessel

stud holes.

The areas

were

vacuumed

(except

under

the

reactor

vessel

stud

hole cleanliness

covers)

prior to

and after

the

hydrolazing.

During the

outage,

a

C&D Power

System

Inc. battery

was

replaced

in

a

nonsafety-related

application

on Unit 2..

Problems with the type

LC-33

batteries

are

discussed

in

IN 89-17,

Contamination

and

Degradation

of

Safety-Related

Battery Cells, of February

22,

1989.

Two of the cells of

the

battery

being

replaced

exhibited

copper

transfer

(contamination)

problems

discussed

in the notice.

The site continues to run surveillance

on this battery

as well

as

the safety related batteries.

The inspector

was

informed

that,

although

the

battery

was

being

replaced,

the

replacement

schedule was'eing

very conservative

in that tests

indicated

thai the replaced battery

had substantial

power reserve.

The installation of the high pressure

turbine generator cover/throttle

and

control valve housing

was observed

by the inspector.

Three valves in the

four

valve

group

had

been

replaced

during this

outage.

The

seating

surface

of the

cover

had

been

modified this

outage

by

the

turbine

contractor to facilitate repair of steam

leakage

between

the cover

and its

mating lower half.

Turbine blading

had also

been replaced.

The movement

and seating of the cover went well with no incidents.

This outage,

the site staff overhauled

the

2A containment

spray

pump for

the first time.

Some short time after the postoverhaul

surveillance

test

had

been

completed, it was

noted that the mechanical

seal

had developed

some static

head

mechanical

seal

leakage.

The mechanical

seal

had

been

replaced during the original overhaul of the

pump. It was decided

to open

the

pump again.

The inspector

was present for the removal of the

pump

and

motor

combination.

The

applicable

procedure

was

general

maintenance

procedure

2-M-0045,

Rev

0,

Oisassembly/Reassembly

of Containment

Spray

Pump.

The procedure

contained

several

weaknesses

which did not apparently

cause

actual

work problems this time:

The procedure

was

not

as radiologically ALARA conscious

as it could

have

been.

Procedures

that support

work preparation

outside of the

radiological

work area,

rather

than

in the

area,

are desirable.

Though the health physics staff had anticipated

higher radiation

and

contamination

levels than

found

upon

pump/system

entry,

the working

procedure text did not call out the various fastener

sizes

such that

the mechanics

could prestage

tools.

The mechanics

were measuring

the

fasteners

on the

pump to determine

what wrenches to use.

Oue to the

low radiation levels

found around the

pump at that time, this

posed

no particular problems.

The procedure text allowed prying on the stationary

side of the seal,

which

was

a

quote

from the

applicable

vendor

manual.

Literal

adherence

could

result

in

seal

damage.

The

pump did

pass

its

subsequent

surveillance test.

The root cause

of the

seal

leakage

was not available

by the

end of the

inspection

period.

Site personnel

have taken

notes

on the work evolution

and procedural

anoma1ies

and

have planned

a post-work debrief.

Plant staff 'preparation

for the integrated

leakrate test

was

reviewed.

One of the

steps

taken

was to replace

a leaking metal

gasket

in

a steam

generator

blowdown valve with. a

rubber

gasket

for the test - without

accounting for the leakage

path that

had existed.

This was based

on

FSAR

sections

6.2.4.2,

System

Oesign,

and 6.2.4.4,

Tests

and Inspections,

which

12

classify

these

penetrations

as

meeting

GDC 57,

Closed

System Isolation

Valves.

GDC 57 discusses

lines that penetrate

the containment

vessel

that

are neither part of the

RCPB nor connected directly to the containment

atmosphere.

A leaking valve bonnet gasket

connects

the

system directly to

the containment

atmosphere.

It is not clear whether or not this condition

was considered

by the

NRC in formulating acceptable

tests.

This issue is URI 350,389/89-10-04

pending further

NRC review.

11.

Licensee Action on Previous

Enforcement Natters

Not addressed

during this inspection

period.

12.

Exit Interview (30703)

The inspection

scope

and findings were

summarized

on April 10,

1989 with

those

persons

indicated in paragraph

1 above.

The inspector described

the

areas

inspected

and discussed

in detail

the

inspection

findings listed

below.

The licensee

did not identify as proprietary

any of the material

provided

to

or

reviewed

by

the

inspector

during

this

inspection.

Dissenting

comments

were not received

from the licensee.

Item Number

Status

Descri tion and Reference

389/89-10"01

open

VIO - Failure to follow maintenance

procedures,

paragraph

6.

335,389/89-10-02

open

335,389/89-10-03

open

335,389/89-10-04

open

335,389/89-10-05

open

335,389/89-10-06

open

h

13.

Acronyms and Abbreviations

URI - Site staff unaware of GE SAL

188. 1 (HFA relays)

since

1986,

paragraph

6.

URI - Validity of the

LTOP accident

analysis,

paragraph

9.

URI - Applicability of GDC 57 if

gaskets

on

SG blowdown valves leak,

paragraph

10.

URI - Operability requirements

for

Containment Coolers,

paragraph

3.

URI - Sealing

requirements

for

Class

1E solenoids

in containment,

paragraph

3.

AC

Alternating Current

AFW

Auxiliary Feed Mater (system)

ALARA

As

Low as Reasonably

Achievable (radiation exposure)

ATWS

Anticipated Transient Without Scram

13

CEA

CFR

CIS

DC

ECCS

EDG

FSAR

GDC

HPSI

FPL

IFI

IN

I&C

INPO

IR

ISI

LTOP

LCO

LER

LPSI

MFIV

MSIV

NRC'pm

PWO

QA

QC

RCB

RCP

RCPB

RCS

Rev

SDC

SDCS

SG

-SIT

TS

URI

VIO

, Appendix A)

(system)

Control

Element Assembly

Code of Federal

Regulations

Containment Isolation System

Direct Current

Emergency

Core Cooling System

Emergency

Diesel

Generator

Final Safety Analysis Report

General

Design Criteria (from 10CFR 50

High Pressure

Safety Injection (system)

The Florida Power

and Light Company

NRC Inspector

Follow-up Item

NRC Information Notice

Instrumentation

and Control

Institute for Nuclear

Power Operations

I'nspection

Report

(NRC)

InService Inspection

(program)

Low Temperature

Overpressure

Protection

TS Limiting Condition for Operation

Licensee

Event Report

Low Pressure

Safety Injection (system)

Main Feed Isolation Valve

Main Steam Isolation Valve

Nuclear Regulatory

Commission

Part(s)

per Million

Pl ant Work Order

Quality Assurance

Quality Control

Reactor

Containment Building

Reactor Coolant

Pump

Reactor Coolant Pressure

Boundary

Reactor Coolant System

Revision

Shut

Down Cooling

Shut

Down Cooling System

Steam Generator

Safety Injection Tank

Technical Specification(s)

NRC Unresolved

Item

Violation (of NRC requirements)