ML17342A794
| ML17342A794 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 07/21/1987 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Woody C FLORIDA POWER & LIGHT CO. |
| Shared Package | |
| ML17342A795 | List: |
| References | |
| EA-87-097, EA-87-97, NUDOCS 8707290031 | |
| Download: ML17342A794 (8) | |
See also: IR 05000250/1987014
Text
JUL21 1987
Docket Nos.
50-250,
50-251
License
Nos.
EA 87-97
,Florida Power
and Light Company
4TTN:
Mr.
C. 0.
Woody
Group Vice President
Nuclear Energy Department
P.
0.
Box 14000
Juno
Beach,
FL
33408
Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED
IMPOSITION OF CIVIL PENALTY
(NRC INSPECTION
REPORT
NOS.
50-250/87-14
AND 50-251/87-14;
AND NRC AUGMENTED INSPECTION TEAM REPORT
NO 50-251/87-16)
This refers to the
NRC inspection
conducted
March
9 through April 27,
1987,
and
the
NRC Augmented Inspection
Team (AIT) review of the Unit 4 Instrumentation
Port Column leakage
conducted
March 19 through
May 5, 1987, at the Turkey Point
Nuclear Plant, Units 3 and 4, Homestead,
Details of these
inspections
were provided to you by letters
dated
May 21,
1987 and
May 15, 1987, respect-
ively, and indicated significant NRC-identified failures to comply with NRC
requirements.
The violations associated
with the above inspections
were
discussed
at an enforcement
conference
held on June 5, 1987, at the Region II
Office, Atlanta,-Georgia.
Violation I.A described in the enclosed
Notice of Violation and Proposed
Imposition of Civil Penalty addresses
the failure to adequately
evaluate
and
correct
a reactor coolant leak from a Unit 4 instrument port column fitting
that was identified during a licensee
inspection
conducted
on August'0,
1986.
FPLL management
chose to authorize operation for a six-month period,
based
on
an engineering safety evaluation which was hastily reviewed
and subsequently
determined to not have appropriately
assessed
the probable corrosive effects
of boric acid residue
on ferritic steel
reactor
components.
This resulted in
the substantial
corrosion of some reactor
vessel
head closure
components.
Further,
on October 24, 1986,
FP8L had
an opportunity to repair the Conoseal
fitting when the reactor
was shut
down for another
reason.
Your preliminary
inspection
showed that the reactor coolant leak remained
and boric acid was
accumulating
on and around the vessel
head area.
However, the boric acid was
cleaned
up by maintenance
personnel prior to an inspection
by Engineering.
This
Engineering inspection failed to consider the poteritial for widespread effects
of leakage
in the head area
beyond the readily accessible,
visible areas.
FP8L
management
continued to rely on the ini'tial faulty safety evaluation
and
determination that the situation
was acceptable
for continued operations.
Management
decisions
were
made with lack of adequate
information concerning
the scope of the potential
problem.
The plant was allowed to start
up in
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ADOCK 05000250
9
JUL 2 p eggy
Florida Power and Light Company
- 2
August 1986,
and to restart in October 1986,
even though information regarding
the effects of boric acid leaks
was documented
in several
previous
NRC and
INPO Notices.
While the actual
corrosion
damage
found in April 1987 did not cause
components
to be operated
beyond design conditions or limits, continued operation in this
leakage
environment could have posed
an unwarranted
degradation
of an important
barrier to the potential release
of fission products to the environment.
There-
fore, this violation is considered significant because it illustrates the fail-
ure of licensee
management
and the operating staff to fully comprehend
and deal
with the adverse effects of plant operations in this mode.
Violation I.B in the enclosed
Notice involves the failure to ensure that the
required prerequisites
and approvals
were met prior to commencing
core alter'ation
activities.
In this regard, activities
commenced
by maintenance
personnel
to
remove the upper core support structure without (1) 'notifying the control
room
and establishing direct communications,
(2) having the containment ventilation
isolation system operable,
and (3) being directly supervised
by a licensed
Senior Reactor Operator.
Had the control
room not responded
properly to a
radiation alarm in containment,
the removal of the upper core support structure
would have
been
completed.
It is unlikely that fuel movement
and
damage
would
have occurred which released
airb'orne activity.
Nevertheless,
we are concerned
that these failures are indicative of a lack of appreciation for controls of
licensed activity and communications
by the Maintenance staff to assure
other
organizations
are
aware of maintenance activities.
While the action by Operations
personnel
was commendable,
those of the Maintenance staff, were unacceptable.
To emphasize
again the
need for FPKL to improve the control of operations
and
the management
decisionmaking'process,
including communications
between major
plant staffs -at the Turkey Point Nuclear Plant, I have
been authorized,
after
consultation with the Director, Office of Enforcement,
and the Deputy Executive
Director,for Regional
Operations,
to issue the enclosed
Proposed
Imposition of Civil Penalty in the amount of One Hundred Thousand
Dollars ($100,000) for the violation described in the enclosed
Notice.
In
accordance
with the "General
Statement, of Policy and Procedure for NRC Enforce-
ment Actions", 10 CFR Part 2, Appendix
C (1987) (Enforcement Policy), the
violations described
in the enclosed
Notice have each
been categorized
in the
aggregate-
as'
Severity Level III problem.
The base
value of a civil penalty
for a Severity Level III problem is $50,000.
The escalation
and mitigation
factors .in the Enforcement Policy were considered.
The base civil penalty
amount
has
been increased
by 100 percent
because
of the lack of prompt correct-
ive action to the leakage situation which was
compounded
by the failure of.FP8L
management
to utilize available information of prior occurrences
relating to
the effects of boron leakage at other facilities.
There was also
a lack of an
effective management
and safety committee review of the safety evaluation.
Furthermore,
escalation
was warranted in consideration
of the poor prior
performance in the area of reactor operations
and maintenance
at Turkey Point
as evidenced
by the Category
3 ratings in the last two Systematic
Assessment
of
Licensee
Performance
(SALP) Reports,
and the number
and scope of violations in
th'ese
areas
over the past
two years.
The remaining violations in the enclosed
Notice of Violation have
been deter-
mined to be of a lesser
safety significance
and are categorized
as Severity
Level IV violations.
These
involved (a) the use of inadequate
procedures
for
the installation of reactor vessel
head
Conoseal
shims which existed from 1972
through 1985,
and the improper fabrication of Conoseal
shims during the 1984
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Florida Power and Light Company
-3-
JUL 21 1987
'
Unit 4 refueling outage,
and (b) the inadequate
procedure for calculation of
reactor
coolant system
leakage
due to use of a correction factor which was
not conservative with respect to temperature
rise.
During the Enforcement
Conference,
discussions
also included activities
relating to- the failure to control wiring of diesel
generator
sequencers.
On
March 27, 1987, with Units'3 and 4 in Mode 6, licensee
personnel
were
performing periodic testing to verify the operability and correct calibration,
of several
of the "B" Emergency Diesel Generator
(EDG) protection relays.
During this testing,
a wiring error was discovered
and promptly corrected with
corrective action documented
in 'a NonConformance
Report.
With this particular
problem identified, licensee
personnel
pursued other areas
where similar wiring
errors could have occurred.
To your credit,'ou also inspected
other work
performed
under this work oeder which revealed
two other wiring errors which
would have affected the operation of the
3B containment
spray
pump
and the
automatic start of Unit 4B and
4C intake cooling water pumps.
We have reviewed
this matter, and determined that it represents
a Severity Level IV violation.
Pursuant to the provisions of 10 CFR Part 2, Appendix C, since the violation was
licensee-identified,
was promptly corrected,
and could not reasonably
be expec-
ted to have
been prevented
by the licensee's
corrective action for a previous
violation,
a Notice of Violation is not being issued for this item.
You are required to respond to this letter
and should follow the instructions
specified in the enclosed
Notice. when preparing your response.
In your
response,
you should document the specific actions
taken
and any
additional'ctions
you plan to prevent recurrence.
In preparing your response,
you should
give particular attention to explain those actions to be taken to'improve the
communication
between your maintenance,
engineering,
and operations staffs.
Atter reviewing your response
to this Notice, including your proposed corrective
actions
and the results of future inspections,
the
NRC will determine
whether
further
NRC enforcement action is necessary
to ensure
compliance with NRC regu-
latory requirements.
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 its enclosure
will be placed in the
NRC Public Document
Room.
The responses
directed
by this letter and the enclosed
Notice are not subject
to the clearance
procedures
of the Office of Management
and Budget
as required
by the Paperwork Reduction Act of 1980, Public
Law No.96-511.
Sincerely,
DMHAL'lGhED BY
f'UM~"
GRNP'nclosure:
Notice of Violation and Proposed
Imposition of Civil Penalty
cc w/encl:
(See
page 4)
J.
Nelson Grace
Regional Administrator
0'
Florida Power and Light Company
- 4
cc w/encl:
LF.
M. Wethy, Vice President
Turkey Point Nuclear Plant
~ J.
Baker, Plant Manager
Turkey Point Nuclear Plant
+
W. Bladow, Plant
gA Superintendent
Q. Aria's, Jr.,
Regulatory
and Compliance
Supervisor
JUL 2
1. 1987
11l26
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