ML17342A701
| ML17342A701 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 09/03/1986 |
| From: | Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17342A700 | List: |
| References | |
| 50-250-86-33, 50-251-86-33, NUDOCS 8609120083 | |
| Download: ML17342A701 (10) | |
Text
ENCLOSURE 1
NOTICE OF VIOLATION Florida Power and Light Company Turkey Point Units 3 and 4
Docket Nos.
50-250 and 50-251 License Nos.
DPR-31 and DPR-41 During the Nuclear Regulatory Commission (NRC) inspection conducted on June 9 August 4, 1986, violations of NRC requirements were identified.
The violations involved the failure to establish an adequate procedure, failure to promptly identify and 'correct conditions adverse to quality, failure to maintain an accurate logic drawing, failure to follow procedures and failure to adequately maintain the radiological emergency plan.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
Appendix C (1986),
the violations are listed below:
A.
Technical Specification 6.8. 1 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.
ANSI N18.7-1972, Section
- 5. 1', states that maintenance that can affect the performance of safety-related equipment shall be properly preplanned and performed in accordance with written procedures and documented instructions appropriate to the circumstances.
Contrary to the
- above, on June 27,
- 1986, an adequate maintenance procedure was not established, in that Plant Work Order (PWO) 63-6582 failed to address all appropriate precautions necessary to calibrate steam break protection circuitry.
Consequently, the circuitry being tested was not properly removed from service and subsequent testing resulted in a Unit 3 reactor trip.
This is a Severity Level IV violation (Supplement I) applicable to Unit 3 only.
B.
10 CFR 50, Appendix B, Criterion XVI, as implemented by FPL Topical Quality Assurance Report (FPLTQAR-1-76A) Revision 8, TQR 16.0, Revision 4, Corrective Action, requires, in part, that measures be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
FPL Quality Assurance Manual, Quality Procedure
- 16. 1, Revision 8, delineates requirements for assuring that conditions adverse to quality are corrected.
Procedure O-ADM-913, revision dated May 23, 1986, entitled Corrective Action for Conditions Adverse to Quality, itemizes the mechanisms by which
-'onditions adverse to quality are promptly identified, tracked and corrected.
8b09120083 Sb0'902 PDR ADOCK 05000250,'
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Florida Power and Light Company Turkey Point Units 3 and 4
2 'ocket Nos.
50-250 and 50-251 License Nos.
DPR-31 and DPR-41 Off-Normal Operating Procedure (ONOP) 0208. 14, Deviation or Failure of Reactor Protection and Safety-Related Hagan Instrumentation
- Channels, revision dated September 4,
1985 states, in section 3.2, that bistables for a failed channel shall be placed in the tripped position within 30 minutes of the failure determination.
Contrary to the
- above, on July 1 and July 18,
- 1986, the licensee failed to take adequate measures to assure that conditions adverse to quality were promptly identified and corrected, in that:
1.
On July 1, 1986, Unit 3 pressure transmitter (PT) 495 failed for twenty seconds resulting in a
steam generator water level transient which required prompt operator action to preclude a reactor trip.
PT 495 was of unknown quality and its failure resulted in the potent'ial loss of redundancy for steam flow input to the reactor protective system.
The failure mechanism and its potential for recurrence were not known.
The required actions of ONOP 0208. 14 were not implemented.
Root cause evaluation and troubleshooting were not pursued until requested by the NRC on July 3, 1986.
2.
On July 18,
- 1986, during electrical bus sequencer
- testing, normal control room lighting was inadvertently lost.
One of two trains of emergency lighting had been removed from service for modification.
The remaining train unexpectedly fai.led to energize, resulting in a loss of
,all control room lighting.
The failure mechani sm was not known.
Normal control room lighting was restored within several minutes.
- However, the licensee failed to evaluate the potential for additional losses of all control room lighting and did not attempt to restore the failed emergency lighting train to service.
Consequently, the control room remained susceptible to a loss of all lighting for over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
This is a Severity Level IV violation (Supplement I) applicable to Unit 3 only.
C.
Technical Specification 6.8. 1 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.
states that procedures should be established for the operation of plant fire protection equipment.
Contrary to the
- above, adequate procedures did not exist to control deluge system valve line-ups, including pressure switch isolation valves.
As a
- result, on June 16,
- 1986, the pressure switches associated with the deluge systems for the Units 3 and 4 component cooling water pump rooms and the A
and B emergency diesel generators were discovered to be isolated, preventing control room and local area deluge actuation alarms from functioning.
This is a Severity Level IV violation (Supplement I).
/'
Florida Power and Light Company.
Turkey Point Units 3 and 4
3 Docket Nos.
50-250 and 50-251 License Nos.
10 CFR 50, Appendix B, Criterion VI, as implemented by FPL Topical Quality Assurance Report (FPLTQAR-1-'76A)
Revi sion 8,
TQR 6.0, Document
- Control, requires, in part, that the distribution of controlled documents such as drawings which provide guidance, specifications or requirements affecting the quality of nuclear safety-related structures, systems and components, shall be controlled and that Quality Procedures shall delineate the control measures for drawings, including direction for the review of adequacy.
E.
FPL Qual ity Assurance
- Manual, Qual ity Procedure
- 6. 6, Revi sion 1,
delineates requiremen'ts for maintaining the drawing update program and assuring that drawings reflect the as-constructed configuration of the safety-related system.
Administrative Procedure (AP) 0103. 10, Using and Updating Plant
- Drawings, dated March 3,
- 1983, implements the above requirements and specifies that drawings shall be verified to ensure proper adequacy.
Contrary to the above, as of July 2,
- 1986, drawing 5610-T-D-18B, Revision 1, entitled "Steam Break Protection" was not accurate, in that each of three steam generator pressure transmitters were shown as supplying density compensation inputs to other than the correct steam flow modules.
Consequently, the logic diagram did not accurately reflect the as-built design of the system.
This is a Severity Level V violation (Supplement I)
Technical Specification 6.8. 1 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 specifies that.
procedures be established describing operation of the shutdown cooling system.
ANSI N18. 7-1972, section 5.3. 5, requires that permi ssi on to release equipment for maintenance be granted by operating personnel.
The equipment shall be made safe to work on.
Measures shall provide for the protection of workers and equipment, and strict control measures shall be enforced.
AP 0103.4, In-Plant Equipment Clearance
- Orders, revision dated May 13,
- 1985, implements ANSI N18.7-1972, and states, in section 5.3.5 and 3.4.1, that a
clearance shall exist on a system when a component, equipment or system is isolated and is properly tagged with a danger tag to ensure protection of personnel and equipment.
Section 3.4.3 of the AP 0103.4 requires indepen-dent verification to be completed where applicable per O-ADM-031, Indepen-dent Verification.
Procedure 0-ADM-031 revision dated July 12, 1985
- requires, in section 5.2. 1, that independent verification be performed on the fire protection system.
f,
Florida Power and Light Company Turkey Point Units 3 and 4
4 Docket Nos.
50-250 and 50-251 License Nos.
DPR-31 and DPR-41 AP 0103.32, Reactor Cold Shutdown Conditions, Revision dated June 3,
- 1986, requires, in section
- 4. 10, that the components of at least one Residual Heat Removal (RHR) loop be capable of being powered from an operable Emergency Diesel Generator (EDG).
1.
Contrary to the above, on July 10,
- 1986, an adequate clearance was not properly established on the fire suppression water system prior to commencing weld repairs on C component cooling water channel head in the affected area.
Additionally, independent verification for removing the fire suppression water system from service was not'ccomplished prior to commencing maintenance work in the affected area.
2.
Contrary to the above, between July 20 25 1986, the components of at least one RHR loop were not capable of being powered from an operable EDG.
This is a Severity Level IV violation (Supplement I) applicable to Unit 4 only.
F.
10 CFR 50.54 (q) states that a licensee authorized to operate a nuclear power reactor shall follow and maintain in effect emergency plans which meet, the standards and requirements of 10 CFR 50.47(b) and 10 CFR 50, Appendix E.
Turkey Point Plant Radiological Emergency
- Plan, Revision 15, implements 10 CFR 50.47(b) and 10 CFR 50, Appendix E.
Section 4.6 of the Turkey Point Plant Radiological Emergency Plan states that the public address system provides for the transmission of warning and instructions in the event of an emergency.
Section 5.2.2 specifies that the plant public address system will be used to announce emergency evacuation orders and states that the announcement of an emergency situation to all on-site individuals can be accomplished in less than 15 minutes.
Contrary to the
- above, prior to August 4,
- 1986, the Turkey Point Plant
.Radiological Emergency Plan was not adequately maintained in that:
1.
The public address system was not installed in the nuclear administra-tion building.
This precluded on-site individuals from being able to hear emergency evacuation orders.
Compensatory personnel notification measures were not established.
On July 16,
- 1986, the site evacuation alarm was inadvertently sounded.
The alarm and subsequent explanatory announcements were not be heard in the nuclear administrative building.
2.
Between July and September
- 1985, the public address system was not installed in the health physics building.
On two occasions, in September
- 1985, health physics personnel assigned to the site fire brigade failed to respond to fire drills because they could not hear the public address system announcements.
3.
Some general area public address system loudspeakers have not been maintained in an operable condition.
As a result, on June 20,
- 1986, two of five fire brigade members failed to respond to a fire drill because they could not hear the fire horn and the fire announcement.
Florida Power and Light Company Turkey Point Units 3 and 4
5 Docket Nos.
50-250 and 50-251 License Nos.
The public address system is not audible in several on-site high noise
- areas, including auxiliary feedwater, containment spray and safety injection pump rooms at times when this equipment is operating.
Compensatory
- measures, such as flashing light systems or administrative notification systems have not been established as required by Inspec-tion and Enforcement Bulletin 79-18, Audibility Problems Encountered on Evacuation of Personnel From High-Noise Areas.
Consequently, the ability to announce an emergency situation to personnel in these areas has not been established.
This is a Severity Level IV violation (Supplement YIII).
Pursuant to the provisions of 10 CFR 2.201, Florida Power and Light Company is hereby required to submit to this Office within 30 days of the date of the letter transmitting this Notice a written statement or explanation in reply including (for each violation):
(1) admission or denial of the violation, (2) the reasons for the violation if admitted, (3) the corrective steps which have been taken and the results
- achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved.
Mhere good cause is shown, consideration will be given to extending the response time.
FOR THE NUCLEAR REGULATORY COMMISSION Roger D. Walker, Director Division of Reactor Projects Dated y,t Atlanta, Geqrgia thi<pday of ~gQs19 5>
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