ML17342A362

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Insp Repts 50-250/85-42 & 50-251/85-42 on 851112-1209. Violation Noted:Failure to Meet Requirements of Tech Spec 6.8.1 Re Written Procedures for Operation of Nuclear Instrument & Feedwater Sys
ML17342A362
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 01/03/1986
From: Brewer D, Elrod S, Peebles T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML17342A360 List:
References
50-250-85-42, 50-251-85-42, NUDOCS 8601130186
Download: ML17342A362 (15)


See also: IR 05000250/1985042

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UNITEDSTATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W.

ATLANTA,GEORGIA 30323

Report Nos.:

50-250/85-42

and 50-251/85-42

Licensee:

Florida Power

and Light Company

9250 West Flagler Street

Miami, Florida 33102

Docket Nos.:

50-250

and 50-251

License Nos.:

DPR-31 and

DPR-41

Facility Name:

Turkey Point 3 and 4

Inspection

Conducted:

Novem

r 12

December

9,

1985

Inspects~:~T.

A. Peebles,

Se ior Resident

Inspector

5

+D.

R. Brewer, Resident

Inspector

Accompanying Personnel:

L. Watson

t

Approved by:

S ep

n A. Elrod, Section Chief

Division of Reactor Projects

3

3 lail

Date

igned

'2I I9R

Date

S gned

Dat

Signed

SUMMARY

Scope:

This routine,

unannounced

inspection entailed

169 direct inspection

hours

at the site, including 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of backshift inspection,

in the areas

of licensee

action

on previous inspection findings, annual

and monthly surveillance,

mainten-

ance

observations

and reviews,

operationil

safety,

engineered

safety features

walkdown, independent

inspection,

and plant events.

Results:

Violation - Failure to meet the requirements

of Technical Specification

(TS) 6. 8. 1.

'

860i130186

860207

PDR

ADOCK 05000250

9

PDR

REPORT DETAILS

Persons

Contacted

Licensee

Employees

Contacted

C.

C

A'D

T.

J.

J.

B.

D.

D.

"R.

R.

AJ

0.

R.

E.

V.

R.

R.

p.

W.

J.

J.

L.

AR

A'R

W.

J.

D.

G.

T.

G.

M. Wethy, Vice President - Turkey Point

J.

Baker, Acting Vice President - Turkey Point,

T. Young, Acting Plant Manager - Nuclear

D. Grandage,

Operations

Superintendent

- Nuclear

A. Finn, Operations

Supervisor

Crockford, Assistant Operations

Supervisor

Webb, Operations/Maintenance

Coordinator

L. Jones,

Technical

Department Supervisor

A. Abrishami, Inservice Test (IST) Supervisor

Tomaszewski,

Plant Engineering Supervisor

A. Chancy,

Corporate

Licensing

Arias, Regulation

and Compliance Supervisor

L. Teuteberg,

Regulation

and Compliance

Engineer

Hart, Regulation

and Compliance

Engineer

W. Kappes,

Maintenance

Superintendent

- Nuclear

E. Suero, Electrical Maintenance

Supervisor

A. Longtemps,

Mechanical

Maintenance

Supervisor

F.

Hayes,

Instrument

and Control (IC) Maintenance

Su

A. Kaminskas,

Reactor

Engineering Supervisor

G.

Mende,

Reactor

Engineer

E. Garrett,

Plant Security Supervisor

W. Hughes,

Health Physics Supervisor

C. Miller, Training Supervisor

M. Donis, Site Engineering Supervisor

M. Mowbray', Site Mechanical

Engineer

C. Huenniger,

Start-up Superintendent

H. Reinhardt,

Acting Quality Control

(QC) Supervisor

J. Acosta, Quality Assurance

(QA) Superintendent

Bladow, Quality Assurance

Supervisor

A. Labarraque,

Performance

Enhancement

Program

(PEP)

W. Hasse,

Safety Engineering

Group Chairman

M. Vaux, Safety Engineering

Group Engineer

C. Grozan,

Licensing Engineer

Traczyk, Fire Protection

Department

0. Kelly, Maintenance/Technical

Training Supervisor

pervisor

Manager

Other

licensee

employees

contacted

included

construction

craftsmen,

engineers,

technicians,

operators,

mechanics,

electricians

and security

force members.

~Attended exit interview

2.

Exit Interview

The

inspection

scope

and

findings

were

summarized

during

management

interviews held throughout

the reporting period with the Plant Manager-

Nuclear and selected

members of his staff.

An exit meeting

was

conducted

on

December

13,

1985.

The areas

requiring

management

attention

were reviewed.

One violation was identified:

Failure to meet the requirements

of TS 6.8. 1 in that procedures

were

not properly implemented for removing

a nuclear instrument

from service

and for completing

prerequisites

for starting

a

steam

generator

feedwater

pump (paragraph

7) (250/85-42-01).

The licensee

did not identify as proprietary any of the materials

provided

to or reviewed

by the

inspectors

during this inspection.

The licensee

acknowledged

the findings without dissenting

comments.

3.

Licensee Action on Previous

Inspection Findings

(92702)

a ~

Performance

Enhancement

Program

(PEP)

The licensee

has

decided

to augment

the existing

PEP to place addi-

tional

emphasis

on

maintenance

and

design

control

areas.

A more

detailed

discussion

of the augmentation

plan is contained in licensee

letter

L-85-439,

of

December

6,

1985,

written in response

to the

findings of Inspection

Report 250,251/85-32.

The principal

program

elements

identified for augmentation

in the maintenance

area

concern

=

maintenance

procedures

(including post-maintenance

testing

and indepen-

dent verification), controls

over plant work orders

(PWOs), training

and experience

of maintenance

personnel,

and

development

of improved

predictive maintenance

techniques.

The program elements

identified in

the design

control

area

concern

enhanced

vendor surveillance,

recon-

stitution of safety

system

design

bases,

standard

engineering

package

implementation,

and formulation of a integrated

design review team.

A

partial itemization of the augmentation

plan is as follows:

The

PEP will incorporate

formal post-maintenance

testing criteria

into

PWO and maintenance

procedures

to improve the level of detail

associated

with corrective

and preventive maintenance.

The

PEP will incorporate

a program to expedite

the reduction of

the IC

PWO backlog.

This includes

extended

work hours, contractor

support

and staffing increases.

The

PEP will incorporate

maintenance

training

on

automated

maintenarice

tracking systems,

work controls

and post-maintenance

testing.

b.

Previously Identified Items

(Closed)

Inspector

Fol 1owup

Item (IFI) 250,

251/85-24-06

- Review

Adequacy

of Engineering

Evaluation for Emergency

Diesel

Generator

Operability.

The engineering

reviews associated

with the

emergency

diesel

generator

hot engine

alarm

have

been evaluated

and found to be

adequate.

Graphs

for engine inlet

and outlet coolant temperatures

indicate

that

the

diesel

generator

was

not operated

outside

the

recommended

temperature

band.

Maintenance

program

improvements

are in

progress

which are

intended

to increase

awareness

of alarm conditions

and minimize the time required to initiate repairs.

(Closed) Violation 250,

251/85-02-03 - Failure to Obtain

gC Approval

Prior to Beginning Maintenance

on Safety-Related

Equipment.

Numerous

maintenance

work orders

have

been

reviewed

between

January

and December

1985.

The failure to obtain

the

required

gC approvals

prior to

beginning

the

work has

not

been

a recurring

problem

and is

not

considered

programmatic.

The licensee's

response

to the Notice of

Violation (L-85-130) was reviewed

and found to be adequate.

(Closed)

IFI 250/84-39-04

and 251/84-40-03

- Degraded

Communications

Between

the Control

Room

and Diesel

Room.

The flashing light circuit

for the

emergency

diesel

generator

telephone

has

generally

been

adequately

maintained

during the past year.

Increased

emphasis

has

been

placed

on maintaining the circuit to facilitate communications.

Additional communication

enhancements

are

being installed

as part of

the alternate

shutdown

panel

modification.

The

licensee

has

also

improved

the reliability of the

loudspeaker

system

in the

diesel

generator

room.

Communications

capabilities

between

the control

room

and the diesel

generator

room appear to be satisfactory.

(Closed)

IFI 250/84-35-05

and

251/84-36-05

- Reactor

Trip Bypass

Breakers

Susceptible

to Inadvertent

Local Operation.

The reactor trip

bypass

breaker

pushbuttons

have

been protected

from accidental jarring

and operation

by a plastic cover.

The cover is held in place

by tape.

During the past year the breakers

have not been inadvertently operated

and therefore the plastic covers

appear to be adequate.

(Closed)

IFI 250/84-34-09

and

251/84-35-09

- Operator

Headsets

for

Surveillance.

Headsets

have

been

obtained

and

are

being utilized

during the performance of surveillances.

For high noise areas,

such

as

the auxiliary feedwater

(AFM) room, the headsets

have

been successfuly

used

while connected

to

hand

held radios.

In the control

room,

headsets

have

been

used during engineered

safety feature surveillance

procedures.

The headsets

have

improved the ease of communication.

t

4.

Unresolved

Items

No unresolved

items were identified during this inspection.

5.

~

G.

Monthly and Annual Surveillance Observation

(61726/61700)

The inspectors

observed

TS-required surveillance testing

and verified the

following:

that the test procedure

conformed to the requirements

of the TS,

that testing

was performed in accordance

with adequate

procedures,

that test

instrumentation

was calibrated,

that limiting conditions for operation

(LCOs) were met, that test results

met acceptance

criteria requirements

and

were

reviewed

by personnel

other than the individual directing the test,

that

deficiencies

were

identified,

as

appropriate,

and

were

properly

reviewed

and resolved

by management

personnel

and that

system restoration

was

adequate.

For completed

tests,

the inspector verified that testing

frequencies

were met and tests

were performed

by qualified individuals.

The inspectors

witnessed/reviewed

portions of the following test activities:

Unit 4 reactor trip breaker testing in accordance

with IE Bulletin 85-02

Units 3 and

4 control

room inaccessibility walk-through

Unit 4 periodic flux map

Units 3 and 4 accumulator valve 883R throttle setting verification

Within this area,

no violations or deviations

were identified.

Maintenance

Observations

(62703/62700)

Station maintenance activities

on safety-related

systems

and components

were

observed

and reviewed to ascertain

that they were

conducted in accordance

with approved

procedures,

regulatory guides,

industry

codes

and

standards

and in conformance with TS.

The following items

were

considered

during this review,

as

appropriate:

that

LCOs were

met while components

or systems

were removed

from service;

that approvals

were obtained prior to initiating work; that activities were

accomplished

using

approved

procedures

and were inspected

as applicable;

that procedures

used

were

adequate

to control the activity; that trouble-

shooting activities were controlled and repair records accurately reflected

what took place; that functional tests

and/or calibrations

were performed

prior to returning

components

or systems

to service;

that

gC records

were

maintained;

that activities were accomplished

by qualified personnel;

that

parts

and materials

used were properly certified; that radiological controls

were properly implemented; that

gC hold points were established

and observed

where required; that fire prevention controls were implemented;

that outside

co~Praetor

force activities

were controlled in accordance

with the approved

gA program;

and that housekeeping

was actively pursued.

The following maintenance activities were observed

and/or reviewed:

Units 3 and 4 motor operated

valve grease

replacement

AFW manual isolation valve repairs

Motor operated

valve environmental qualification inspections

Accumulator fill line inspection

and valve 883R isolation

AFM pump governor oil evaluation

Within this area,

no violations or deviations

were identified.

Operational

Safety Verification (71707)

The inspectors

observed

control

room operations,

reviewed applicable logs,

conducted

discussions

with control

room operators,

observed shift turnovers

and confirmed operability of instrumentation.

The inspectors verified the

operability of selected

emergency

systems,

verified that maintenance

work

orders

had

been

submitted

as required

and that follow-up and prioritization

of work was

accomplished.

The inspectors

reviewed tagout records, verified

compliance

with

TS

LCOs

and verified the return to service of affected

components.

By observation

and direct interviews, verification

was

made that

the

physical security plan was being implemented.

Plant housekeeping/cleanliness

conditions

and implementation of radiological

controls were observed.

Tours of the intake structure

and diesel,

auxiliary, control

and turbine

buildings

were

conducted

to observe

plant equipment conditions

including

potential fire hazards, fluid leaks

and excessive

vibrations.

The

inspectors

walked

down accessible

portions of the following safety-

related

systems

on Unit

3

and

Unit 4 to verify operability

and proper

valve/switch alignment:

Emergency Diesel Generators

Component Cooling Water

4160 volt and 480 volt Switchgear

Nuclear Instrumentation

Drawers

Refueling Mater Storage

High Head Safety Injection

Control

Room Vertical Panels

Standby feedwater

System

On

November

30,

1985, during a shutdown of the Unit 3 reactor,

source

range

nuclear

instrument

N-32 failed to automatically

energize

as reactor

power

entered

the

source

range.

The

instrument

was

taken out of service

by

removing the

two instrument

power

supply

fuses.

The

fuses

were

then

reinstalled

to determine

whether or not improved, fuse contact would restore

the

instrument

power.

The

instrument

did energize

and the

power surge

resulted

in a false

high source

range flux signal spike which exceeded

the

instrument's trip setpoint,

actuated

the reactor

protection

system

and

opened

the

reactor

trip breakers.

All control

rods

had previously

been

fully inserted.

'I

)

~

An independent

review of this event

was conducted

by the resident inspector.

It was

determined

that the source

range nuclear instrument

was

removed from

service

in

a manner contrary to the requirements

of Off-Normal Operating

Procedure

(ONOP)

12108,

Source

Range

Nuclear Instrumentation

Malfunction,

dated

August 22,

1984.

ONOP 12108 requires

(section 5.2.1) that

a failed

instrument

be taken

out of service

by placing the level trip switch in the

bypass

position.

This prevents

the failed instrument from supplying

a trip

signal

to the

reactor

protection

system

and,

consequently,

prevents

the

expected

signal

spike, that occurs

upon initial instrument energization,

from tripping the reactor.

On December

4,

1985,

during

a heatup of the Unit 3 reactor,

the

AFW system

automatically initiated,

as required,

on loss of the running main feedwater

pump.

The

3B main feedwater

pump tripped on low suction pressure

due to its

manually operated

suction valve being closed.

The

pump

ran for approxi-

mately fifteen seconds

before tripping; during that time the logic circuit

was

completed for an

AFW pump start

on loss of the operating

main feedwater

pump.

The

AFW system performed

as required.

Operating

Procedure

3-0P-074,

Steam

Generator

Feedwater

Pump,

dated

September ll, 1985,

requires

(section

5. l. 1) that the condensate

system

be

aligned

for

normal

operation

in

accordance

with procedure

3-0P-073,

Condensate

System,

as

an initial condition prior to starting

a

steam

generator

feedwater

pump.

It was determined that the control

room operator

thought that

procedure

3-OP-073

was

completed

when actually it was only

partially completed.

Consequently,

the

3B feedwater

pump was started with

its suction valve shut.

The events

of November

30 and December 4, 1985, constitute failures to meet

the requirements

of TS 6.8. 1, which requires that written procedures

and

administrative policies

be established,

implemented

and maintained that meet.

or exceed

the

requirements

and

recommendations

of sections

5.1 and 5.3 of

ANSI N18.7-1972

and Appendix

A of USNRC Regulatory Guide 1.33.

Appendix

A of USNRC Regulatory Guide 1.33

recommends

that written procedures

be established

covering operation of the nuclear

instrument

system

and the

feedwater

system.

The failure to properly implement procedures

relative to

the nuclear

instrument

and

main feedwater

systems

are

two examples

which

comprise Violation 250/85-42-01.

This violation applies to Unit 3 only.

Several

additional

discrepancies

were

noted relative to monitoring control

room equipment status:

a.

On December

5,

1985,

a

PWO tag

(048504)

was

observed

next to Unit 3

protection

bistable

FC

474 for one of three

steam line high flow

channels.

The tag indicated that the bistable circuit was placed out-

of-service

on

December

4,

1985.

The bistable

was not in the tripped

position

as

would normally

be the

case for a failure.

The on-shift

~ ~

b.

reactor

operator

was

not

aware that the tag existed

and could not

immediately identify whether

the bistable

was out-of-service

or not.

No entry

had

been

made in the

Equipment Out-of-Service

Log.

Conse-

quently, although the control

room operator

suspected

that the bistable

had

been

repaired,

there

was

no

record of the maintenance

action

available in the control

room.

An IC supervisor

was contacted

and

he

confirmed that the bistable

had

been repaired

on the preceding shift.

The control

room operator

did not receive

any information about the

corrective action during his turnover prior to coming on shift and

he

had not noticed the tag during the normal performance of his duties.

On December

9, 1985,

a reactor protection

system status light for power

above the permissive

(P-10) setpoint

was observed to be extinguished

on

Unit 3.

The reactor

operator

was not aware of the discrepancy until

informed by the inspector.

A check revealed that the light bulbs for

the indicator had burned out.

C.

On

December

9,

1985,

the Unit 4 control

rod

speed

indicator

was

observed

to indicate

40 instead

of the required

72 steps

per minute.

The reactor

operator

was not aware of the discrepancy

and could not

explain the

abnormal

indication.

It was subsequently

deter'mined that

the indicator

was stuck at the

40 steps

per minute position and when

freed it returned to the actual setpoint of 72 steps

per minute.

The inspector

discussed

these

occurrences

with the Operations

Superin-

tendent.

In each

case,

prompt investigation

and correction of the

discrepancy

was

accomplished.

The inspector

expressed

concern that

control

room

awareness

was

not receiving

the

emphasis

required to

identify equipment

discrepancies

at their inception.

The Operations

Department

continues

to emphasize

the

need for diligent monitoring of

all control

room indications.

8.

Engineered

Safety Features

Walkdown (71710)

The inspector verified operability of the emergency

diesel

generator

system,

which is

common .to Units

3

and

4 by performing a complete

walkdown of the

accessible

portion of the

system.

The following specifics

were

reviewed

and/or observed

as appropriate:

a ~

b.

C.

that the licensee's

system lineup procedures

matched plant drawings

and

the as-built configuration;

that the equipment conditions

were satisfactory

and

items that might

degrade

performance

were identified and evaluated

(e.g.

hangers

and

supports

were operable,

housekeeping

was adequate,

etc.);

that instrumentation

was properly valved-in

and functioning and that

calibration dates

were not exceeded;

d.

that

valves

were in their proper

positions,

breaker

alignment

was

correct,

power

was available,

and

valves

were

locked/lockwired

as

required;

e.

local

and

remote position indication

was

compared

and

remote instru-

mentation

was functional;

and

breakers

and

instrumentation

cabinets

were

inspected

to verify that

they were free of damage

and interference.

Within this area,

no violations or deviations

were identified.

9.

Independent

Inspection

During the report period the inspectors

routinely attended

meetings

with

licensee

management

and monitored shift turnovers

between shift supervisors,

shift

foremen

and

licensed

operators.

These 'meetings

included daily

discussions

of plant operating

and testing activities as well as discussions

of significant problems

or incidents.

As a result,

the inspectors

reviewed

potential

problem

areas

to independently

assess

their importance to safety,

the

adequacy

of proposed

solutions,

any improvements

or progress,

and the

adequacy

of corrective actions.

The inspector's

reviews of these matters

were not limited to the defined inspection

program.

Independent

inspection

efforts weye conducted

in the following areas:

AFW system proposed

Technical Specifications

Maintenance

management

controls

Accumulator fill line support requirements

Environmental qualification of motor operated

valises

AFW system

improvement plans

Nuclear instrument operability requirements

Standby feedwater

system

proposed

Technical Specifications

Review of Turkey Point TS upgrade

program

Periodically,

the

inspectors

attended

the daily morning planning meeting

which is conducted

by the Plant Supervisor - Nuclear.

Within this area,

no violations or deviations

werq identified.

10.

Plant Events

(93702)

An independent

review was conducted of the following events.

On

November

29,

1985, the licensee

reported that portions of the Unit 3 and

Unit 4 accumulator fill lines

were not seismically qualified.

The lines

supply water

from the refueling water storage

tank to the accumulators

through the safety injection pumps

and associated

hot leg injection piping.

The safety injection hot leg piping is classified

as

3 inch diameter,

class

B, safety-related,

and seismically

supported.

The accumulator fill lines

are

shown

on drawings

as

1 inch diameter,

nonsafety-related,

class

D piping.

The class

D pipe is not required to

be seismically supported but is manu-

factured from the

same material

as the class

B pipe.

Nonseismically

supported

pipe

is

normally

separated

from seismically

supported

pipe

by at least

one closed isolation valve.

This prevents

the

failure of the nonseismically

supported

pipe from creating

an

unexpected

flowpath that

could divert water from its intended destination.

It was

determined

by the licensee that isolation valves

3-883R and 4-883R had been

maintained

in the normally-open position for many years.

Consequently,

a

failure of the accumulator fill line for either unit could have resulted in

an unanticipated

flow diversion path during post-accident

hot leg injection.

The valves

were shut on November 26,

1985.

Subsequently,

a safety analysis

was performed

which justifies operating with the valves throttled open to

allow a

maximum of 50 gallons per minute flow which would permit the remote

filling of the accumulators

from the control

room.

The

licensee

is evaluating

the safety

significance

of this event.

An

independent

evaluation is being conducted

by the

NRC staff.

On November

30,

1985,

a personnel

error resulted

in the actuation of the

Unit 3 reactor protection

system

when

a source

range nuclear instrument

was

taken

out of service

in a manner inconsistent

with approved

procedures.

This event is discussed

in detail in paragraph

7 of this report.

On December 4, 1985,

a personnel

error resulted in the actuation of the Unit

3 auxiliary feedwater

system

when the

3B main feedwater

pump tripped

due to

an

improper

valve alignment.

This event is, also

discussed

in detail

in

paragraph

7 of this report.

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