ML17338A288

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Responds to NRC Ltr Re Violations Noted in Inspec Repts#50- 250/77-28 & #50-251/77-28.Corrective actions:2 Thermowells & 2 Couplings Were Replaced & Welds Liquid Penetrant Tested
ML17338A288
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 10/31/1978
From: Robert E. Uhrig
FLORIDA POWER & LIGHT CO.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 7811210188
Download: ML17338A288 (29)


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FLORIDA POWER 5 LIGHT COMPANY October 31, 1978 L-78-348 go ~

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Mr. James P. O'Reilly, Director, Region II Office of Inspection and Enforcement U. S. Nuclear Regulatory Comission 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

Re: RI I: MVS 50-250/77-28 50-251/77-28 The purpose of this letter is to conclude our reporting of Boron Injection Tank inspection results at Turkey Point Units 3 and 4.

Examinations:

l. Visual inspections of interior-PTP-4 November 2, 1977 PTP-3 December 15, 1977 PTP-4 August 25, 1978 These internal inspections showed the tanks to be free of defects.
2. Liquid Penetrant Examination on the inside of the 6 inch outlet nozzle-to-pipe weld PTP-3 December 29, 1977 PTP-4 August 31, 1978 No relevant indications were detected on Unit 3. On Unit 4, 17 relevant round indications were found on the first test.

The area was polished and re-examined, and no relevarit indi cations were found.

~R On both units the original 2 thermowells and 2 couplings were removed and sent to our NSSS vendor for analysis. Their report showed the parts to be sensitized.

5 ~ <3.84' James P. O'Reilly, Director, Region II e Two Replacement parts were installed on the following dates.

PTP-3 January 26, 1978 PTP-4 March 3, 1978 All welds, i.e. thermowells-to-couplings (shop weld) and couplings-to-'pipe nozzle (field weld) were liquid penetrant= tested after the root and final passes. Wo relevant indications were detected.

This completes all inspection and reporting activities for both Units 3 and 4.

No new activities are planned.

Very truly yours, ert E. Uhri g e President REU/NS/cpc cc: Robert Lowenstei n, Esquire

14 AE00, UNITED STATES (4~P,8

~4 0 NUCLEAR REGULATORY COMMISSION Cy REGION II 0

lq 3 230 PEACHTREE STREET, N.W. SUITE 818 lO

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ATLANTA,GEORGIA 30303 JAtI 8 7 1978

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In Reply Refer To:

RII:MVS 50-250/77-28 50-251/77-28 Florida Power and Light Company Attn: Dr. R. E. Uhrig, Vice President of Nuclear and General Engineering P. O. Box 013100 9250 West Flagler Street Miami, Florida 33101 Gentlemen:

Thank you for your letter of January 17, 1978, informing us of steps you have taken to correct the deviation concerning activities under NRC Operating License Nos. DPR-31 and DPR-41 brought to your attention in our letter of December 21, 1977. We will examine your corrective actions and plans during subsequent inspections.

We appreciate your cooperation with us.

Sincerely, F. ong, Chic

~

~ .

Reactor Operations and Nuclear Support Branch cc: Mr. H. E. Yaeger, Plant Manager Turkey Point Plant P. O. Box 013100 'I 9250 West Flagler Street Miami, Florida 33101

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.CgI)Y FLORIOA POWER 8 LIGHT COIYiPANY January 17, 1978 L-78-18 0

Mr. James P. O'Reilly, Director, Region Office of Inspection and Enforcement II U. S. Nuclear Regulatory Commission 230 Peachtree Street, N. N., Suite 1217 Atlanta, GA 30303

Dear Mr. O'Reilly:

Re: RII:MVS, 50-250/77-28 50-251/77-28 Florida Power & Light Company has reviewed the subject inspection port and a response is attached.

There is no proprietary information in the report.

Very truly yours, R. E. Uhrig Vice President REU/MAS/lah Attachment cc: Robert Lowenstein, Esquire

ATTACHMENT Re: RII:MVS 50-250/77-28 50-251/77-28 F~indin PSAR Table 6.2-5 states that the boron injection tanks are constructed of austenitic stainless steel.

Contrary to these specifications the boron injection tanks at Turkey Point Units 3 and 4 are constructed of carbon steel lined internally by 5/32 inch stainless steel.

~Res onse Both boron injection tanks (BITs) at Turkey Point are nstructed with stainless steel clad (roll bonded pe 304L) on carbon steel. The housings on the thermo-

.wells are 100% stainless steel (Type 304). As a result of boron injection tank anomalies at another utility, the Turkey Point tanks have been evaluated to verify their continued operational integrity. The following inspections have been performed:

UNIT 4 A visual inspection of the inside of the Unit 4 BIT has been performed. The inside of the tank was specifically examined for blistering. Also examined were the tank seam welds, the inside weld on the Schedule 80 pipe housing the thermowell, and the weld making the transition from the inner diameter (I.D.) of the tank to the manway. The examinations showed the tank to be internally free of pitting, blistering, and weld corrosion.

A liquid penetrant test has been performed. The two thermowell couplings and the fillet welds joining the couplings to the tubes were examined.

The examinations showed no abnormalities.

UNIT 3 A visual inspection of the inside of the Unit 3 BIT has been performed. The inspection areas were the same as for the Unit 4 inspections, and the con-clusions were also the same.

In lieu of a thermowell liquid penetrant test, the two thermowell couplings have been radiographed.

The radiographs of both thermowells showed that, although the two pipe nipples connected by the coupling were bottomed out, against the coupling shoulder, the units had good integrity.

A liquid penetrant test of the weld on the I.D.

of the outlet nozzle was performed. No abnor-malities were detected.

Two stainless steel (Type 304) couplings, one with a pipe nozzle (Type 304) and one without, were removed from the Unit 3 BIT for destructive meta-llurgical. analysis by our NSSS vendor. The couplings were secCioned and their metallurgical structures were evaluated for susceptibility to intergranular attack (as determined by ASTN Specification A262-75, Practice A, oxalic acid test). The tests showed no indication of intergranular corrosion attack.

The tentative plan for the Unit 4 BIT is to (1) visually inspect. the inside of the tank again, (2) remove one thermowell coupling for destructive metallurgical analysis, and (3) perform a liquid penetrant test of the weld on the I.D. of the outlet nozzle. This additional work is planned for the next Unit 4 refueling outage (scheduled for midsummer 1978).

The results will be forwarded to the Regi'on II Office of Inspection and Enforcement. within 30 days of the end of the outage.

As described above, all boron injection tank inspections to date have verified tank integrity. The additional inspections planned for Unit 4 are expected to provide further verification. Therefore, based on the information we have at this time, we have concluded that the existing tanks are in compliance with the intent of the FSAR which is to provide a source of borated water for injection into the RCS under specific c itions. The Plant Nuclear Safety Committee and t Company Nuclear Review Board will review this item for concurrence with the final disposition.

The deviation in question apparently occurred during construction of Turkey Point Units 3 and 4. Since then, the administrative control of plant modifications has been considerably upgraded. The present controls should act to prevent recurrence of such deviations.

~P,S aaCI UNITED STATES 0 NUCLEAR REGULATORY COMMISSION lu c REGION II 230 PEACHTREE STREET, N.W. SUITE 1217 ATLANTA,GEORGIA 30303 kg**4 DFc s '77 In Reply Refer To:

RII:MVS 50-250/77-28 50-251/77-28 Florida Power and Light Company Attn: Dr. R. E. Uhrig, Vice President of Nuclear and General Engineering P. 0. Box 013100 9250 West Flagler Street Miami, Florida 33101 Gentlemen:

This refers to the inspection conducted by Mr. M. V. Sinkule of this office on November 28 December 2, 1977, of activities authorized by NRC Operating License Nos. DPR-31 and DPR-41 for the Turkey Point 3 and 4 facilities, and to the discussion of our findings held with Mr. H. E. Yaeger at the conclusion of the inspection.

Areas examined during the inspection and our findings are discussed in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.

We have examined actions you have taken with regard to previously reported unresolved items. The status of these items is discussed in the enclosed report.

One new unresolved item resulted from this inspection and is discussed in the enclosed report. This item will be examined during subsequent inspections.

During the inspection it was found that certain activities under your license appear to deviate from commitments to the Commission and have safety significance. This item is identified in the Notice of Deviation enclosed herewith as Appendix A. Please provide us in writing within 20 days of your receipt of this letter your comments including a description of corrective actions that have been or will be taken, corrective actions which will be taken to avoid further deviations, and the date corrective actions were or will be completed.

Florida Power and Light Co.

In accordance with Section 2.790 of the NRC's "Rules of Practice,"

Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. If this report contains any information that you (or your contractor) believe to be proprietary, it is necessary that you make a written application within 20 days to this office to withhold such information from public disclosure. Any such application must include a full statement of the reasons on the basis of which it is claimed that the information is proprietary, and should be prepared so that proprietary information identified in the application is contained in a separate part of the document. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.

Should you have any questions concerning this letter, we will be glad to discuss them with you.

~

Sincerely, g.c.

J. Long, Chief Reactor Operations and Nuclear Support Branch

Enclosures:

l. Appendix A, Notice of Deviation
2. RII Inspection Rpt. Nos.

50-250/77-28 and 50-251/77-28 cc w/encl:

Mr. H. E. Yaeger, Plant Manager Turkey Point Plant P. 0. Box 013100 9250 West Flagler Street Miami, Florida 33101

APPENDIX A NOTICE OF DEVIATION Florida Power and Light Company License Nos. DPR-31 DPR-41 Based on the results of the NRC inspection conducted on November 28 December 2, 1977, certain of your activi,ties appear to deviate for your commitments to the Commission.

FSAR Table 6.2-5 states that the boron injection tanks are constructed of austhenitic stainless steel.

Contrary to these specifications the boron injection tanks at Turkey Point Units 3 and 4 are constructed of carbon steel lined internally by 5/32 inch stainless steel.

"<cu UNITED STATES 0 NUCLEAR REGULATORY COMMISSION REGION II 230 PEACHTREE STREET, N.W. SUITE 1217 ATLANTA,GEORGIA 30303

+ +**+

Report Nos.: 50-250/77-28 and 50-251/77-28 Docket Nos.: 50-250 and 50-251 License Nos.: DPR-31 and DPR-41 Licensee: Florida Power and Light Company P. 0. Box 013100 9250 West Flagler Street Miami, Florida 33101 Facility Name: Turkey Point Units 3 and 4 Inspection at: Turkey Point Site, Florida City, Florida Inspection conducted: November 28 December 2, 1977 Inspector: M. V. Sinkule Reviewed by: . C.

R. C. Lewis, Chief Date Reactor Projects Section No. 2 Reactor Operations and Nuclear Support Branch Ins ection Summar Ins ection on November 28-December 2 1977 Re ort No.

50-250/77-28 and 50-251/77-28 Areas Ins ected: Routine, unannounced inspection of plant operations; preparation for refueling; Technical Specification requirements; unresolved items; and reportable events. The inspection involved 36 inspector hours on site by one NRC inspector.

Results: In the five areas inspected, no items of noncompliance or deviations were identified in four areas. One apparent deviation was identified in one area involving the boron injection tanks not being constructed of material specified in the FSAR (paragraph 6) (77-28-01).

RII Rpt. Nos. 50-250/77-28 and 50-251/77-28 DETAILS I Prepared by: . . mnkc~ iw c-0 N7 M. V. Sinkule, Reactor Inspector ate Reactor Projects Section No. 2 Reactor Operations and Nuclear Support Branch Dates of Inspection: November 28 December 2, 1977 Reviewed by:

R. C.

. C>

Lewis, Chief

/P~/77 Date Reactor Projects Section No. 2 Reactor Operations and Nuclear Support Branch All items pertain to both Turkey Point 3 and 4 unless otherwise specifically designated.

1. Persons Contacted

~H. E. Yaeger, Plant Manager

)I J ~ K. Hays, Plant Superintendent, Nuclear

  • J. E. Moore, Superintendent, Nuclear Operations
  • D. W. Jones, QC Supervisor J. P. Mendieta, I and C Supervisor J. S. Wade, Chemistry Supervisor

~R. J. Spooner, QA Supervisor

  • A. E. Siebe, Assistant Manager of QA, Operations
  • W, B. Wager, Operations Supervisor, Nuclear
  • T A. Finn, Plant Supervisor, Nuclear
  • C. J. Baker, Plant Supervisor, Nuclear
  • K. E. Beatty, Training Supervisor
  • J. Hardy, Plant Engineer
  • p. J. White, Plant Superintendent, Maintenance
  • R. J. Acosta, Power Resources Specialist (GO)
  • R. Li, Power Resources Engineer (GO)
  • N. Ranek, Nuclear Licensing Engineer (GO)

Two (2) Control Center Operators The inspector contacted several operators and technical support personnel not specifically listed.

  • Denotes those attending the exit interview on December 2, 1977.

R II Rpt. Nos. 50-250/77-28 and 50-251/77-28 I-2

2. Licensee Action on Previous Ins ection Findin s Unresolved Items (0 en)(77-26-01 Ins ection of Boron In ection Tanks)

Inspections of boron injection tanks (BIT) were initiated as a result of a thermowell failure at another facility. The licensee committed to visually inspecting Unit 3 BIT internals and conducting radiography of the thermowell connectors of both Unit 3 and Unit 4 BIT's.

(paragraph 6)

3. New Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. An unresolved item disclosed in this inspection is discussed in Paragraph 10.b.

4, Exit Interview

'I The results of the inspection were discussed with H. E. Yaeger, Plant Manager, and members of his staff (denoted in paragraph 1) on December 2, 1977.

5. Entrance Interview and Plant Status The inspector conducted an interview with plant management on November 28, 1977, and plant status, status of outstanding items and operating problems were discussed. Unit 3 had been shutdown on November 24, 1977, as scheduled for the purposes of refueling, inservice inspections, and maintenance. The outage is expected to last fifty-eight (58) days. Unit 4 operated at full power during the inspection except for reduced power operation on December 1, 1977, to repair a condenser tube leak.. The plant manager stated that no exposures in excess of the Regulatory requirements had been received by personnel at the facility. No items of noncompliance were identified.
6. Boron In ection Tank Ins ections IE Report 50-250/77-26 and 50-251/77-26 identified an unresolved item concerning inspections of the Units 3 and 4 boron injection tanks and thermowells. The inspector reviewed FPL and Westinghouse visual inspection reports which indicated that the Unit 4 tank was satisfactory. The licensee stated during the exit interview that the visual inspections will be performed on Unit 3 during this refueling outage and that the thermowell connectors on both units will be radiographed to insure integrity. Unit 3 will be accomplished this outage and Unit 4 will be performed during the next extended outage. This item will remain unresolved pending completion of these inspections (77-26-01).

RII Rpt. Nos. 50-250/77-28 and 50-251/77-28 I-3 A review of the FSAR Table 6.2-5 indicates that the boron injection tanks are constructed of austenitic stainless steel when in fact the tanks are constructed of carbon steel lined with 5/32 inch stainless steel. Therefore, it appears that the construction of the tank is in deviation with the FSAR (77-28-01). In addition, a review of the Technical Specifications indicates that no requirements have been established for periodic inspections of these tanks.

7. Plant 0 erations
a. Letters of Instruction The inspector reviewed operating memorandum and letters of instructions pertaining to plant operations to determine whether the instructions were in conformance with the Technical Specifications and regulatory requirements. No items of noncompliance were identified; however, the inspector commented during the exit interview that the letters of instructions appear to be outdated, in that some of these items have been included in operating procedures. Licensee representatives stated that Administrative Procedure, 0109.1, dated August 31, 1977, has been revised concerning the issuance of letters of instruction and that responsibility has been assigned to review the outstanding letters to determine applicability. The inspector verified that this item had been placed on the FPL outstanding items list and had no further questions.
b. Re ortin Re uirements The inspector reviewed the plant supervisor's logs for October 1977, to determine whether reporting requirements specified in Technical Specification 6.9.2 have been met. No items of noncompliance were identified.
8. Pre aration for Refuelin (Unit 3)

The inspector reviewed operating procedures to verify that approved procedures were available for new fuel receipt and inspection; fuel transfer and core verification; recycled fuel inspections; fuel sipping operations; and core and fuel bundle reconstitution. The details associated with the review are described below:

a0 New Fuel Recei t and Ins ection Operating Procedure 16009.2, "Site Removal of New Fuel Assemblies from Shipping Containers and Handling of Shipping Containers,"

was reviewed to verify that provisions have been provided for

~

~ RII Rpt. Nos. 50-250/77-28 and 50-251/77-28 I-4 the inspection of new fuel assemblies. Forty (40) new assemblies had been received on site and discussions indicated that ten (10) assemblies had been inspected and no problems had been identified. A review of two inspection reports which contained inspection results for four assemblies, dated November 16, 1977, did not identify any discrepancies.

b. Rec cled Fuel Ins ections The licensee representatives stated that no plans are currently being made by FPL to conduct complete visual inspections of recycled fuel assemblies. This decision is based on the fact that the primary system activities have been relatively low during the preceeding cycle. The inspector reviewed a sample of E determinations for October 1977, which indicates that primary system activity was approximately 1-2 percent of that allowed by the Technical Specifications.

No plans were being made for fuel sipping operations for the same reason. Licensee representatives stated that Westinghouse was planning on conducting a video tape inspection of sixteen (16) of the assemblies removed during this cycle. No items of noncompliance were identified.

C ~ Fuel Transfer and Core Verification The inspector reviewed:

(1) Operating Procedure 1407.21, "Refueling Activities Check List" (2) "Refueling Limiting Conditions for Operation Check List".

(3) Operating Procedure 16002.6, "Preparations and Precautions for Refueling Fuel Shuffle".

to ascertain that provisions have been established to ensure that the requirements of the Technical Specifications are met during the refueling process. No items of noncompliance were identified.

The licensee had not completed approval of Operating Procedure 16002.5 "Refueling Core Shuffle". This procedure is scheduled to be approved prior to the refueling operations which are currently scheduled to begin December 20, 1977. This item will be reviewed during a future inspection (77-28-03);

R22 Rpt. Nos. 50-250/77-28 and 50-251/77-28 I-5

9. Limitin Conditions for 0 eration Safet Limits and Limitin Safet S stem Settin s The inspector reviewed operating records, surveillance records, and performed visual observations and discussions with licensee personnel to ascertain compliance with or that procedures require adherence to various Technical Specification requirements as described below:
a. Reactivit Control S stems Operating Procedures (OP) 1008.6, "Operation Outside of the Axial Flux Target Band"; and OP 12308.2, "Power Range Nuclear Instrumentation Verification of Upper, Lower, and Channel Deviation Alarms" were reviewed to determine that procedures provide for the detection of axial and radial tilts. The inspector verified that the conditions of Technical Specifications i

3.2.6.c, d, e, f, g, h, were being met on Unit 4 on November 29, visual observation of recording instrumentation, 1977, by target value determinations, data sheets, and completed OP 12308.2.

No items of noncompliance were identified.

b. Reactor Coolant S stem The inspector verified that the conditions of Technical Specifications 2.1.2, 2.1.4, 2.2 and 2.3 were being met by review of the following records and by visual observation on November 29, 1977.

(1) OP 1207.1, "Pressurizer Safety Valve Repair and Setting";

Unit 3 December 6, 1976; Unit 4 June 3, 1977.

(2) OP 14007.14, "Pressurizer Pressure Instrumentation Calibration";

Unit 3 November 23, 1976; Unit 4 June 8, 1977.

(3) OP 202.1, "Reactor Startup, Cold Shutdown to Power Operation" No items of noncompliance were identified.

c ~ Plant and Electrical Power S stems The inspector verified that the conditions of Technical Specifications 3.7.1.a, b, and e were being met by visual observation of the 480 and 4160 volt switchgear panels on November 29, 1977, and by review of minimum equipment lists for October 1977. No items of noncompliance were identified.

C RII Rpt. Nos. 50-250/77-28 and 50-251/77-28 I-6

d. Emer enc Core Coolin S stems The inspector verified that the conditions of Technical Specification 3.4.l.a.3, 7 were met by visual observation of Unit 4 instrumentation on November 29, 1977, and by review of the following records:

(1) OP 14007.25, "Accumulator Pressure Instrumentation Calibration,"

dated June 6, 1977, Unit 4.

(2) OP 14007.24, "Accumulator Level Instrumentation Calibration,"

dated May 9, 1977, Unit 4.

(3) OP 103.5, "Locked Valve List"; Unit 3, October 23, 1977; Unit 4, November 29, 1977.

(4) Sample of Nuclear Control Center Operators data sheets for October 1977, Units 3 and 4.

No items of noncompliance were identified.

e. Containment S stems (1) The inspector verified that the conditions of Technical Specification 3.3.1 were being met by discussions with licensee personnel and review of the following documentation:

(a) OP 13531.1, "Leak Test of Equipment Hatch"; Unit 3 January 13, 1977; Unit 4 November 9, 1977.

(b) OP 13514.1, "Leak Test of Personnel and Emergency Access Hatches"; Unit 3 July 27, 1977; Unit 4 July 26, 1977.

(c) OP 16004.1, "Leak Test of the Fuel Transfer Tube";

Unit 3, January 12, 1977; Unit 4, July 22, 1977.

(d) OP 103.5, "Locked Valve List"; Unit 3, October 22, 1977; Unit 4, November 29, 1977.

(2) The inspector verified that conditions of Technical Specification 3.4.3.a were being met by visual observation and review of the following records:

(a) Minimum Equipment Lists for October 1977. Units 3, 4.

(b) OP 4704.1, "Operability Test of the Emergency Containment Filter System", dated November 7, 1977. Unit 3.

No items of noncompliance were identified.

RII Rpt. Nos'. 50-250/77-28 and 50-251/77-28 I-7

f. Instrument S stems The inspector verified that the conditions of Technical Specification Table 3.5-1 Items 2,5,6,7,8 were being met by visual observation on November 29, 1977, of Unit 4 and a review of a sample of the minimum instrumentation lists for October 1977. No items of noncompliance were identified.
10. Re ortable Events The inspector reviewed two reportable events to ascertain that:

(1) reporting requirements of Technical Specification 6.9.2 were met; (2) corrective action was taken as required by Appendix B to 10 CFR 50; (3) the event was reviewed and evaluated; and (4) the facility was operated within the requirements of 10 CFR 50.59 and the Technical Specifications subsequent to the event.

a~ Re ortable Event 251/77-10 (Unit 4)

This event involved the inoperability of a component cooling system heat exchanger which had been taken out of service for maintenance for 28"minutes longer than the time allowed by Technical Specification 3.4.4.b.2. The inspector conducted interviews with licensee personnel and reviewed the following records:

(1) Plant Nuclear Safety Committee minutes dated October 14, 1977.

(2) Plant Work Order dated September 26, 1977.

(3) Plant Supervisors Log, Nuclear Control Center Log and Equipment Status Log for October 1, 1977.

The event was not reported to Region II within the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as required; however, licensee identified this fact and took appropriate corrective action. The inspector discussed the reporting requirements with licensee personnel and had no further questions.

b. Re ortable Event 251/77-12 (Unit 4)

This event involved the blockage of the boric acid flow path between the boric acid tanks and the reactor coolant system on October 24, 1977. The inspector interviewed licensee personnel and reviewed operating records as follows:

RII Rpt. Nos. 50-250/77-28 and 50-251/77-28 I-8 (1) Plant Supervisors Log, Nuclear Control Center Operators Log, and the Nuclear Operators Log for October 24, 1977.

(2) Plant Nuclear Safety Committee Minutes Date not recorded.

(3) Pressurizer Pressure Recorder Chart for October 24, 1977.

(4) Reactor Power Chart for October 24, 1977.

(5) Plant Work Order dated October 24, 1977.

The inspectors review of the event indicated that: (1) operating records and the event evaluation did not contain all of the information which preceeded identification of the event; and (2) the emergency borate line was not tested for approximately twelve (12) hours after it was determined that a boric acid flow path was not available through the blender. Discussions with licensee personnel indicated that they were aware of the slow identification of the blockage because of a failure of heat tracing circuit in another part of the system. Licensee representatives also acknowledged that it would have been prudent to test the emergency borate sooner than they did.

Licensee representatives confirmed that their review of the event had come up with the same conclusions and that a meeting was held with the personnel involved to ensure that similar situations would be identified in a more timely manner in the future. During the exit interview the licensee committed to (1) reviewing the operating record which led up to this event and upgrading the records as appropriate, (2) reviewing the administrative procedures relative to licensee events and making appropriate changes to ensure that events are adequately identified, evaluated, corrected and documented. This item is unresolved (77-28-02).

c~ Re ortable Events 251/77-11 and 251/77-13 (Unit 4)

The inspector performed an in-office review of the two subject reportable occurrences and has no further questions.

d. Re ortable Occurrence Re ort 251/76-06 The subject reportable occurrence report, which involved failure of a 4160 volt breaker, stated that a supplemental report will be issued concerning the results of a breaker reliability study and the recommended corrective actions. The licensee stated during the exit interview that the supplemental report will be submitted by December 30, 1977.

RII Rpt. Nos. 50-250/77-28 and 50-251/77-28 I-9 ll. Containment Emer enc Filter S stem (CEFS) (Unit 3)

RII Inspection Report 50-250/77-26 identified an outstanding item concerning the testing of absorber spray valves on November 7, 1977. This item was discussed with FPL personnel who stated that testing of the valves was inadvertently added to the monthly operability tests of the CEFS during recent procedure revisions to OP 4701.1 to include the requirements of 10 CFR 50.55(a)(g). A review of the Technical Specifications indicate that there are no requirements to test the valves and review of the 10 CFR 50.55(a)(g) program submitted to the NRC indicate that an exception has been requested for not testing the valves on the basis that the valves are not designed to be tested. Valve actuation is not possible unless pressure is present on the valve to supply the driving force required to open or close the valve. The inspector had no further questions concerning this matter at this time.

12. Metal Im act Monitorin S stem FPL notified Region II by telephone on September 19, 1977, concerning a problem with the Unit 4 metal impact monitoring system as required by The Order for Modification of License dated August 2, 1977. A written report concerning the event was submitted to the NRC on September 30, 1977. The inspector reviewed the corrective action prescribed in the letter by visual observation of the recording equipment in the control room and review of Operating Procedure 1003.2 dated November 6, 1977, and has no further questions.
13. Plant Tour The inspector conducted a tour of the control room on December 2, 1977. No items of noncompliance were identified.

P. O. BOX 013100, MIAMI, FL 33101 J

I FLORIDA POWER & LIGHT COMPANY January 3, 1978 L-78-3

,+gal gS/

Mr. James P. O'Reilly, Director, Region Office of .Insp'ection and Enforcement II U. S. Nuclear Regulatory Commission 230 Peachtree Street, N. W., Suite 1217 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

Re: RII:EHV 50-250/77-27 50-251/77-27 Florida Power & Light Company has reviewed the subject inspection ort. There is no proprietary information in the report.

Very truly yours,

/

//"

Robert E. Uhrig Vice President.

REU/MAS/lah cc: Robert Lowenstein,. Esquire

~qO.~ R ~00,

")::;"

t UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II ig 230 PEACHTREE STREET, N.W. SUITE 1217 ATLANTA,GEORGIA 30303

~O Dt.C I4 1977

+a*++

In Reply Refer To:

RII:EHV 50-250/77-27 50-251/77-27 Florida Power and Light Company Attn: Dr. R. E. Uhrig, Vice President of Nuclear and General Engineering P. 0. Box 013100 9250 West Flagler Street Miami, Florida 33101 Gentlemen:

This refers to the inspection conducted by Mr. E. H. Verdery of this office on November 21-23, 1977, of activities authorized by NRC Operating License Nos. DPR-31 and DPR-41 for the Turkey Point Units 3 and 4 facilities, and to the discussion of our findings held with Mr. H. E. Yaeger at the conclusion of the inspection.

Areas examined during the inspection and our findings are discussed in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.

Within the scope of this inspection, no items of noncompliance were disclosed.

One new unresolved item resulted from this inspection and is discussed in the enclosed report. This item will be examined during subsequent inspections.

In accordance with Section 2.790 of the NRC's "Rules of Practice",

Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. If this report contains any information that you (or your contractor) believe to be proprietary, it is necessary that you make a written application within 20 days to this office to withhold such information from public disclosure. Any such application must include a full statement of the reasons on the basis of which it is claimed that the information is proprietary, and should be prepared so that proprietary information identified in the application is contai

Florida Power and Light Co.

in a separate part of the document. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.

Should you have any questions concerning this letter, we will be glad to discuss them with you.

Sincerely,

~ . Long, Chi

~

Reactor Operations and Nuclear Support Branch

Enclosure:

RII Inspection Report Nos.

50-250/77-27 and 50-251/77-27 cc w/encl: Mr. K. N. Harris, Plant Manager St. Lucie Plant P. 0. Box 128 Ft. Pierce, Florida 33450 Mr. Nat Weems, Assistant QA Manager P. 0. Box 128 Ft. Pierce, Florida 33450

UN I T E D STATES LEAR REGULATORY COMMISSION REGION II 230 PEACHTREE STREET, N.W. SUITE 1217 ATLANTA,GEORGIA 30303 Report Nose 1 50-250/77-27 and 50-251/77-27 Docket Nose1 50-250 an'd 50-251 License Nos.: DPR-31 and DPR-41 Licensee: Florida Power and Light Company 9250 West Flagler Street P. 0. Box 013100 Miami, Florida 33101 Facility Name: Turkey Point Units 3 and 4 Inspection at: Turkey Point Site, Homestead, Florida

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Inspection conducted: November 21-23, 1977 Inspector: E. H. Verdery Reviewed by C. E. Alderson, Acting ief Date Nuclear Support Section No. 2 Reactor Operations and Nuclear Support Branch Ins ection Summar Ins ection on November 21-23 1977: (Re ort Nos. 50-250/77-27 and 50-251/77-27)

Areas Ins ected: Routine unannounced inspection of facility design changes and modifications on Unit Nos. 3 and 4. Specific areas examined included design change and modification evaluation procedures, implementation and acceptance tests; revisions to operating procedures; and maintenance of records. The inspection involved 20 inspector-hours on site by one NRC inspector.

Results: In the areas inspected, no items of noncompliance or deviations were identified.

RII Rpt. Nos. 50-250/77-27 and 50-251/77-27 DETAILS I Prepared by:

E. H. Verdery, Reactor Inspector Date Nuclear Support Section No. 2 Reactor Operations and Nuclear Support Branch Dates of Inspection: November 21-23, 1977 Reviewed by~ C. E. Alderson, Acting Chief Nuclear Support Section No. 2 Reactor Operations and,Nuclear Support Branch

1. Persons Contacted Florida Power and Li ht Com an
  • H. E. Yaeger, Plant Manager
  • D. W. Jones, Quality Assurance Supervisor
  • J. E. Moore, Operations Supervisor
  • P. J. White, Maintenance Supervisor R. H. Reinhardt, Quality Control Engineer L. C. Huenniger, Shift Supervisor
  • Denotes those present at the exit interview.

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2. Licensee Action on Previous Ins ection Findin s Not inspected.
3. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance or deviations. An unresolved item disclosed during the inspection is discussed in paragraph 6.
4. Exit Interview The inspection scope and findings were discussed with the licensee's representative listed in paragraph 1 at the conclusion of the inspection on November 23, 1977.

RII Rpt. Nos. 50-250/77-27 and 50-251/77-27 I-2 Desi n Chan es and Modifications The inspector reviewed nine completed modification packages. Of these, four were applicable to Unit No. 3, three were applicable to Unit No. 4 and two were applicable to both units.

During this review, the inspector verified that these design changes had been: reviewed in accordance with the licensee's approved quality assurance plan; evaluated in accordance with 10 CFR 50.59; conducted in accordance with the Technical Specifications and designated quality assurance procedures; implemented with formal approved procedures; and acceptance tested to demonstrate compliance with applicable Technical Specifications. Additionally, the inspector verified that appropriate operating procedures and system drawings had been revised for the selected design changes.

No items of noncompliance or deviations were identified.

6. Timeliness of Review of Documentation of Cora leted Modifications The inspector observed that the licensee has numerous modification packages outstanding for which the work has been accomplished but the documentation has not been reviewed. Some of these modifications had been completed for more than ten months. The licensee has revised AP0190.15, Plant Changes and Modifications (PC/M) as of February 28, 1977, but no PC/M's had as yet been completed using this new procedure. As revised, this procedure should provide more effective control of PC/M implementation, documentation and review; however, the continuing delays in review of supporting documentation may not be corrected by a new procedure alone.

Unresolved Item 77-27-01: The adequacy of the management controls for plant changes and modifications is designated an unresolved item pending further review.

7. Sco e of Modification Im lementation The inspector noted that the licensee also has several incomplete PC/M's which have been outstanding for an excessive period of time.

In many cases, some modification work is completed on one unit or system but the complete modification package cannot be closed because it was written to accomplish the same work on both units or several systems. The net result of this method of implementation is that some portion of a PC/M will remain outstanding indefinitely.

Consequently, final review and approval of the PC/M is delayed

RII Rpt. Nos. 50-250/77-27 and 50-251/77-27 1-3 indefinitely after some safety-related components or systems have been modified. The inspector stated that the licensee should seriously consider reducing the scope of future PC/M's such that they can be accomplished, documented and reviewed on a shorter time schedule. This item has been identified in a previous inspection report (76-10).

P. O. X 013100, MIAMI, FL 33101 t \C i'*

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p i.l FLORIOA PGWER 8 LIGHT COMPANY December 21, 1977 L-77-389 Mr. James P. O'Reilly, Director, Region Office of Inspection and Enforcement II U. S. Nuclear Regulatory Commission 230 Peachtree Street, N.W., Suite 1217 Atlanta, GA 30303

Dear Mr. O'Reilly:

Re: RII:MVS 50-250/77-26 50-251/77-26 Florida Power & Light Company has reviewed the subject inspection eport. There is no proprietary information in the report.

Very truly yours, Robert E. Uhrig Vice President REU/MAS/lah cc: Robert Lowenstein, Esquire