ML17342A854
| ML17342A854 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point |
| Issue date: | 08/07/1987 |
| From: | Brewer D, Macdonald J, Vandyne K, Wilson B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17342A852 | List: |
| References | |
| 50-250-87-33, 50-251-87-33, NUDOCS 8708170477 | |
| Download: ML17342A854 (36) | |
See also: IR 05000250/1987033
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323
Report Nos.:
50-250/87-33
and 50-251/87-33
Licensee:
Florida Power and Light Company
9250 West Flagler Street
Miami, FL
33102
Docket Nos.:
50-250
and 50-251
Facility Name:
Turkey Point
3 and
4
License Nos.:
Inspection
Conducted:
June
22
July 20,
1987
Inspector:
D.
R. Brewer, Senior Resident
Insp ctor
K.
W.
Van
yne,
Resident
Inspector
~7 c
'j
J.
. Macdonald,
Resident
Inspector
Approved by:
m
,
c 'W~
/,I
Bru'
Wilson, Section Chief
Di ision of Reactor Projects
Da
e Signed
Da e
igned
gD
Da
e
igned
< 7/F7
Date Signed
SUMMARY
Scope:
This routine,
unannounced
inspection entailed direct inspection at the
site,
including backshift
inspection,
in the
areas
of annual
and
monthly
surveillance,
maintenance
observations
and reviews,
engineered
safety features,
operational
safety, plant events,
and plant procedures.
Results:
Four
violations
were
identified:
Failure
to
meet
Technical
Specification
3. 18
requirements
. for operability of the auxiliary feedwater
system
(paragraph
10);
Failure to promptly evaluate
the significance of an
system
steam leak (paragraph
11); Failure to'eet Technical
Specification
requirements
for reducing
reactor
protection trip settings
(paragraph
10);
and
the failure to'stablish
an
adequate
fire protection
procedure
(paragraph
10).
8708170477
870807
ADOCK 05000~50
6
REPORT DETAILS
Persons
Contacted
Lic
C.
o'C
O'
D.
tcT
J.
- D
J.
R.
D.
J.
- W.
R.
E.
AJ
R.
AJ
R.
"W.
V.
p.
AG
J.
- W
- F
- G
ensee
Employees
M. Wethy, Yice President
J.
Baker, Plant Manager-Nuclear
H. Southworth,
Maintenance
Superintendent
A. Chancy, Site Engineering
Manager
(SEM)
D. Grandage,
Operations
Superintendent
AD Finn, Training Supervisor
Webb, Operations - Maintenance
Coordinator
H. Taylor, Operations
System
Enhancement
Coordinator
W. Kappes,
Performance
Enhancement
Coordinator
A. Longtemps,
Mechanical
Maintenance
Department Supervisor
Tomasewski,
Instrument
and Control (IC) Department
Supervisor
C. Strong, Electrical Department Supervisor
Bladow, Quality Assurance
(QA) Superintendent
E.
Lee, Quality Control Inspector
F.
Hayes, Quality Control
(QC) Supervisor
A. Labar raque,
Technical
Department Supervisor
G. Mende, Operations
Supervisor
Arias, Regulation
and Compliance Supervisor
Hart, Regulation
and Compliance Engineer
C. Miller, Senior Technical Advisor
Kaminskas,
Reactor Engineering Supervisor
W. Hughes,
Health Physics Supervisor
Solomon,
Regulation
and Compliance
Engineer
Donis, Engineering
Department Supervisor
Pike, Safety Engineering
Group Engineer
Irizarry, Administrative Supervisor
B. Wager,
Licensing Engineer
Marsh,
Reactor
Engineer
Other
licensee
employees
contacted
included
construction
craftsmen,
engineers,
technicians,
operators,
mechanics,
and electricians.
NRC Personnel
"H. 0. Christensen,
Project Engineer
- Attended exit interview on July 20,
1987.
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
2
on July 20,
1987.
The areas
requiring management
attention
were reviewed.
The licensee
acknowledged
the findings without exception.
No proprietary
information was provided to the inspectors
during the reporting period.
Four violations were identified:
Failure to meet Technical Specification
3. 18 requirements for operability
of the auxiliary feedwater
system (paragraph
10, 251/87-33-01).
Failure to meet the requirements
of 10 CFR 50, Appendix B, Criterion XVI,
in that the significance of an auxiliary feedwater
system
steam
leak was
not promptly evaluated
(paragraph
11, 251/87-33-02).
Failure to meet Technical Specification
requirements for reducing reactor
protection trip settings
(paragraph
10, 251/87-33-03).
Failure to meet the requirements
of Technical Specification 6.8. 1, in that
fire protection procedure
O-OP-016.1
was not adequate
(paragraph
10,
250,
251/87-33-04).
Summary of Plant Operations
Unit
3 has
remained
in mode 5, cold shutdown,
since entering
a refueling
outage
on
March 6,
1987.
The Unit
3
Engineered
Safeguards
Integrated
Test,
3-0SP-203,
was successfully
completed
on July
5 after first being
attempted
on June
30,
1987.
The initial test
was unsatisfactory
because
the
A emergency diesel
generator
(EDG) did not start.
The diesel
governor
was adjusted,
correcting the problem and the
EDG was returned
to service
on July 4,
1987.
On July
14
two of four
conoseals
(Northwest
and
Southeast)
were found to be leaking.
Repairs
were completed
on July 19.
However,
during post maintenance
testing,
three
thermocouple
connections
were observed to be leaking at the threaded
connections
above three of the
four conoseals.
Repairs
are in progress.
On March 13,
1987 excessive
Unit 4 conoseal
leakage
was identified.
The
Unit 4 reactor
was placed in cold shutdown while repairs
were implemented.
Subsequently,
additional operability issues
were identified and evaluated
by the licensee
and the
NRC.
These
issues
were the subject of a
May 5
meeting
between
members
of the
NRC
and
licensee
staffs.
The
issues
discussed
included:
Augmented Inspection
Team (AIT) findings;
EDG wiring
discrepancies;
sequencer
testing;
Raychem environmentally qualified splice
replacements;
and
post
accident
recirculation
swapover
changes.
In
a
July 3,
1987 letter to the licensee,
the
NRC specified that there
remained
no outstanding
issues
preventing the restart of the Turkey Point Units.
The
Unit
4 reactor
was
restarted
on July 7,
1987.
Power
operation
continued until July
15
when
a condenser
tube
leak caused
unacceptably
high level of steam generator
and conductivity.
The reactor
was
shutdown
on July
17
due to
an out of service Auxiliary Feedwater
(AFW)
train.
Condenser
and
AFW repairs
were
completed
and
the
reactor
was
restarted
on July 20,
1987.
J
Unresolved
Items
Unresolved
items are matters
about which more information is required to
determine
whether
they
are
acceptable
or
may
involve violations
of
requirements
or deviations
from commitments.
No unresolved
items were
identified during this inspection period.
Follow-up on Items
on Noncompliance
(92702)
A review
was
conducted
of the following noncompliances
to assure
that
corrective actions
were adequately
implemented
'and resulted in conformance
with regulatory
requirements.
Verification of corrective
action
was
achieved
through record reviews, observation
and discussions
with licensee
personnel.
Licensee
correspondence
was
evaluated
to
ensure
that
the
responses
were timely and that corrective actions
were implemented within
the time periods specified in the reply.
(Closed) Violation 250,251/85-30-03,
Failure to meet
requirements
of TS 6.5. 1.6,
Temporary
System Alteration Not Reviewed
by the Plant Nuclear
Safety
Committee
(PNSC) Prior to Implementation.
Corrective action for
this violation,
as
stated
in the licensee's
March 14,
1986
response,
included significant changes
to O-ADM-503, Control
and
Use of Temporary
System Alterations
and
the
issuance
of Training Brief 106.
Corrective
action appeared
adequate
and
was verified to
be in place.
This item is
closed.
(Closed)
Violation
250,
251/86-05-01,
Failure
to
follow Procedure
AP 0103.4,
In-Plant
Equipment
Clearance
Order.
The
licensee
had
re-emphasized
the
importance
of adherence
to procedural
requirements
and
issued
a letter, to all Operations
Department
Personnel
from the Plant
Manager
Nuclear,
dated
February 4,
1986,
emphasizing
the importance of
clearance
procedures.
This item is closed.
(Closed)
Violation 250,
251/85-26-03,
Failure to establish
measures
to
assure
conditions
adverse
to
quality
were
promptly identified
and
corrected,
in that, water was not prevented
from entering
the instrument
air
system.
The
licensee
has
implemented
shiftly
surveillance
requirements
in procedure
3/4-0SP-201.3,
[Nuclear
Plant
Operator]
Daily Logs.
Additionally, operation
and maintenance
department
personnel
were instructed to identify instances
where
particular
problem continue
to recur.
This item is closed.
(Closed) Violation 250,
251/85-26-01,
Four examples
of failure to comply
with procedures
when conducting auxiliary feedwater
system
maintenance.
The individuals involved in the violation examples
were counseled
on the
importance
of
procedure
compliance.
Additionally,
the
following
procedures
were
revised
to correct
noted
deficiencies;
ONOP 0208.1,
Shutdown
Resulting
from Reactor
Trip or Turbine Trip and
AP 0190.19,
Control
of Maintenance
on Safety
Related
and Quality Related
Ststems.
Maintenance
personnel
received
instructions
on
the
requirements
of
AP 0190. 19
and
Administrative- Procedure
O-ADM-701,
Plant
Work Orders
Preparation.
This item is closed.
(Closed) Violation 250,
85-24-02,
Failure to properly
implement control
rod drop time measurements
as required
by OP 1604.8.
The rod drop
times'ere
recalculated
by the licensee
and
the individuals
involved in the
non-compliance
were
counselled
on
procedural
compliance.
This item is
closed.
(Closed)
Violation 250/85-26-02,
Failure
to
comply with
in
performing
a
temporary
change
to
procedure
3-OSP-075. 1,
Auxiliary
(AFW)
Train
1
Operability
Verification
and
procedure
3-0SP-075.2,
Train
2
Operability
Verification.
The
licensee
re-performed
the
surveillance
procedures
in
their
entirety
and
instructions
in the night order
log were
issued
to increase
personnel
awareness
of the necessity
to complete
surveillance
procedures
or obtain
an approved
procedure
change.
This item is closed.
(Closed) Violation 250,
251/85-30-04,
Failure to identify the root cause
of AFW pump overspeed trips.
The maintenance
department
reviewed the root
cause
section
of
procedure
O-ADM-701,
Plant
Work Order
Preparation.
Additionally, the
licensee
has
established
an
event
response
team to
review and determine root causes
to problems.
This item is closed.
(Closed)
Violation 250/85-42-01,
Two
examples
of failure to follow
procedures;
one concerning
source
range
nuclear instrumentation,
and the
other concerns
the
condensate
system.
The individuals involved received
counselling,
a reminder to follow procedures
was placed in the night order
log and the two examples
resulted in LERs which were trained
on during the
1985-1986
Cycle
V operator
requalification class.
Additionally, procedure
3/4-0P-073,
Condensate
System,
was revised to require plant clearances
for
pump motor breakers.
This item is closed.
(Closed) Violation 250, 251/85-23-01,
Failure to meet the requirements
of
10 CFR 50 '9 in the
use
of the
spent
fuel
pool
(SFP)
cooling
system
contrary to the
FSAR.
The
licensee
has
revised
procedures
O-ADM-100,
Procedures
Preparation,
Review
and
Approval;
AP-0109. 1,
Preparation,
Revision, Approval,
and
Use of Procedures;
AP-0109.3,
On The Spot Changes
to Procedures;
and AP-0109.6,
Temporary
Procedures,
to provide
improved
guidance
to individuals
responsible
for preparing
procedure
changes.
These
revisions
included
guidance
on
conducting
and
Technical
Specification, reviews.
A special
NRC inspection
was
conducted
(Report
250,
251/87-24)
to
evaluate
engineering
procedures
and
controls for
engineering
evaluations.
This inspection
concluded that the licensee
had
adequate
controls for conducting
safety evaluations.
Additionally, the
licensee
is
taking
long
term
corrective
actions
in
the
area
of
reviews
as
a result of Enforcement, Action 86-20.
This item
is closed.
(Closed) Violation 250, 251/84-09-05,
Failure to adequately
review design
changes
on safety-related
electrical
busses.
The licensee
stated that the
design
changes
were not performed
due to being classified
as
non-nuclear
safety related
design
changes.
Procedure
AP 0190. 15,
Plant
Changes
and
Modifications (PC/M), was revised to require all
PC/Ms be reviewed
by the
Plants
Nuclear Safety Committee.
This item is closed.
(Closed)
Other
251/83-39-01,
Failure
to
maintain
adequate
procedure
specifying reporting requirements.
Procedure
AP 0103. 12, Notification of
- Significant Events to NRC, dated April 14,
1987
, appears
adequate
in the
reporting requirements for reactor trips.
This item is closed.
(Closed)
Other
251/83-39-03,
Failure to implement
procedure
following a
The licensee
has
implemented
new procedure
3/4-0NOP-059.3,
Nuclear
Instrumentation
Malfunction,
dated
January
23,
1987,
which
requires
the operator
to confirm shutdown
margin
when both
source
range
channels
are malfunctioned.
This item is closed.
(Closed)
Violation
251/83-39-06,
Failure
to
follow procedure
when
conducting
a reactor
startup.
Procedure
3/4-0NOP-028,
Reactor
Control
System Malfunction, contains
guidance
on determining
when
a control rod is
misaligned.
This item is closed.
(Closed)
Violation
251/83-39-08,
Failure
to
implement
off-normal
procedures
for
a failed Pressurizer
Power
Operated
Relief
Stop
Valve.
Procedure
ONOP-1208. 1, Pressurizer
Power Operated Relief System - (Reliefs
and MOV's) Malfunction, dated July 24,
1986, provides adequate
guidance
to operators
on what to do for a failed stop valve.
This item is closed.
(Closed) Violation 251/83-39-09,
Failure to process field procedure
changes.
The
licensee
has
stressed
procedure
verbatim
compliance
policy,
additionally
these
requirements
are
in AP-0103.2,
Responsibilities
of
Operators
and Shift Technicians
on Shift and Maintenance
of Operations
Logs and Records,
This item is closed.
(Closed)
Violation 251/83-39-11,
Failure
to
implement
procedures
when
conducting
system periodic test.
The plant management
issued
circulars
to all
plant
personnel
stressing
procedural
compliance.
Procedure
AP-0103.2
was revised to require procedural
verbatim compliance.
This item is closed.
(Closed)
Violation 251/83-39-12,
Failure of on shift operators
to take
action to investigate
problems.
The licensee
restressed
the importance of
responding to problems
and taking corrective action by the operators,
this
was placed in the night order log.
This item is closed.
(Closed)
Viol'ation 250/86-17-01,
The
cont~ol
room operator
failed to
properly
implement
the unit startup
procedures.
The Plant
Manager
Nuclear
re-issued
a letter
to all
nuclear
plant
personnel
on
the
importance
of
verbatim
procedural
compliance.
New
procedures,
3/4-GOP-301,
Hot Standby to Power Operation
and 3/4-GOP-503,
Cold Shutdown
to Hot Standby,
have
been
implemented with improved guidance.
This item
is closed.
(Closed) Violation 251/83-38-01,
Both Unit 4 Containment
spray
pumps were
during power operations.
This
was
cause
by having the
manual
stop valves inadvertently closed.
The licensee
took the following
corrective actions.
The operations
management
held
meeting
to discuss
.
incident;
the valves in question
were placed
under Administrative Control
as
locked
open
valves
in procedure
O-ADN-205, Administrative Control of
Valve,
Locks and Switches;
the labels
and locks for these
valves
have
been,
color coded to help prevent wrong unit/wrong train events.
This item is
closed.
(Closed)
Violation
250,251/83-38-02,
Failure
to notify the
NRC
on
10 CFR 50.72 events.
The operations
personnel
received
instructions
on
reporting requirements.
This item is closed.
(Closed)
Violation
250,251/84-04-02,
the
licensee
failed to
provide
adequate
procedures
or
to
control
the
operations
of safety
related
equipment.
These failures resulted
in a
breakdown
in management
control
of plant operations.
The procedural
deficiencies
noted in this violation
have
been
corrected.
Additionally,
the
licensee
- implemented
the
Performance
Enhancement
Program
(PEP)
to
improve
overall
plant
performance.
This program is on-going
and its progress is being tracked
by the
NRC.
This item is closed.
(Closed)
Violation 250/84-29-03
and
251/84-30-04,
The
PNSC
did
not
adequately
review facility operations
in that potential
safety hazards
in
the Intake Cooling Water System,
Component
Cooling Water System,
Emergency
Containment
Coolers,
1.20 Volt AC Vital Bus Inverters
and remote
shutdown
instrumentation
were not detected.
The deficiencies
not in the violation
have
been
corrected
and the procedures
have
been
revised.
The licensee
has
implemented
a program for improved operation.
This item is closed.
(Closed) Violation 250,
251/82-24-02,
Failure of personnel
to follow the
requirement
of a Radiation
Work Permit
(RWP)
on protective clothing.
The
individual involved were counselled.'dditionally,
the licensee
requires
all personnel
entering
the radiation controlled
area to read
and
sign
a
log stating that they understood
the requirements
of the
RWP.
This item
is closed.
(Closed)
Violation
250,251/86-25-01,
Failure
to
properly
implement
OP-1004.2,
Reactor
Protection
System - Periodic Testing,
and
OP-4304. 1,
EDG - Periodic
Test.
The operators
involved were
counselled
on the
importance'of procedural
adherence.
Procedure
OP-1004.2
has
been replaced
by
3/4-OSP-049. 1,
Reactor
Protection
System
Logic Test
and
Procedure
OP 4304. 1 has
been
replaced
by 0-OSP-023. 1, Diesel
Generator
Operability
Test.
The deficiencies
noted in the old procedures
have
been corrected.
This item is closed.
(Closed)
Violation 250,251/85-13-01,
Failure to implement
procedures
in
the area of contaminant exclusion, radiation work permit requirements
and
housekeeping.
Procedures
HP-3207.2,
Residual
Heat
Removal
Pump
Disassembly
and
Repair,
and
Procedure
Reactor
Vessel
STUD
Tensioner
Operators,
have
been
revised to include contaminant
exclusion
requirements.
The
individuals
involved
in the
and
housekeeping
non-compliances
were counselled
and specific training developed to address
each of these
problems.
This item is closed.
(Closed)
Violation 250,251/85-02-1,
Diesel
Generator
exceeded
voltage
limit during full load rejection testing.
The
NRC staff reviewed this
concern
and determined that
a short duration voltage transient
was not of
concern
as
long as the
EDG voltage stabilized at or below the limiting
voltage.
The licensee
has
submitted
a
TS change
to. limit the transient
time to two seconds
following the load rejection.
This item is closed.
It should
be
noted that twelve of the
above violations that are closed-
involved failur'es to implement and/or follow procedures.
The licensee's
corrective action
in the past
has primarily
been counselling,
procedure
changes,
and
issuance
of reminder letters
concerning
the
importance of
verbatim compliance with procedures.
The
NRC continues
to
be concerned
over
the
licensee's
program
to correct this continuing
problem.
These
violations in this report
have
been
closed
since there is
no practical
reason
to further track
these
individual
examples.
The
Performance
Enhancement
Program
has
included
several
projects
specifically
aimed
toward
the
improvement
of and
compliance
with procedures
(Project
2,
Operations
Enhancement
and Project 5, Procedures).
The
NRC will continue
to closely monitor the licensee's
progress
in the implementation of these
programs.
Followup
on
Unresolved
Items
(URIs),
Inspector
Followup
Items (IFIs),
Inspection
and,Enforcement
Information Notices (IENs), IE Bulletins (IEBs)
(information only), IE Circulars (IECs),
and
NRC Requests
(92701).
A review was conducted of the following items to assure that the licensee
completed
adequate
applicability reviews,
made appropriate
distributions
and if required,
implemented
adequate
and timely corrective actions.
(Closed)
URI 250,
251/85-03-02,
Throttling of
RHR Discharge
Stop Valves,
This
item
was
changed
into
a violation in
inspection
report
250,
251/86-44.
This item is closed.
(Closed)
IFI 250,251/85-06-05.
Maintenance
attention
needed
for chronic
problems
with
the
area
radiation
monitoring
system
(ARMS).
From
January
1986 to August 1986,
four contract
18C technicians
were
employed
full time to mai'ntain
the
ARMS and process
radiation monitoring
(PRM)
Systems.
From September
1986, to the present,
two
18C technicians
have
been
assigned
to these
systems
on a full time basis.
Using the
same
technicians
to perform maintenance
on these
systems
enabled
them to become
more experienced
with the
equipment,
improved the quality of maintenance
and contributed to increased
system reliability.
The licensee
plans
to=
replace
the existing
system
in the future
on
a priority derived through
the Integrated
Schedule
process.
S
(Closed)
URI 250, 251/85-20-04,
Licensee
personnel
may not be adequately
familiar with
some technical
specifications
(TS).
This unresolved
Item
addresses
a
concern
for the failure to
comply with
TS
Surveillance
requirements
and for removal
of mechanical
without performing
evaluations
required
by TS 3. 13.3 as identified in the following LERs:
LER 250-85"01
LER 250-85-08
LER 250"85-09
LER 250-85-11
These
LERs were previously addressed
and closed in Inspection
Report 250,
251/86-39.
Additionally,
missed
TS
Surveillance
requirements
were
addressed
as
a violation (250,251/86-39-02)
and
subsequently
closed
in
Inspection
Report 250, 251/87-10.
This item is closed.
(Closed)
IFI 250,251/85-06-06.
Develop
a
procedure
for operating
the
spent fuel pool
(SFP)
leakage detection
system.
This IFI was resolved
by
revising OP-0204.2.
Subsequently,
the daily requirement to check for SFP
leakage
was incorporated into O-OSP-201.2,
SNPO Daily Logs.
This item is
closed.
(Closed)
250,
251/85-20-03.
Evaluate
the advisability of blocking
safety injection while maintaining
hot standby
conditions.
The licensee
has
modified 3-GOP-305,
Hot Standby to Cold Shutdown
Procedure,
to more
clearly define the conditions which must be satisfied to place the safety
injection
block switch in the
block position.
These
conditions
were
verified to be in conformance with current
TS requirements.
This item is
closed.
(Closed)
IFI
250,251/85-24-08.
Improve
procedural
guidance
for
containment evaluation
alarm and high flux at shutdown
alarm.
Additional
guidance for setting
and maintaining at least
one alarm channel
in service
for the containment
evacuation
alarm and the high flux at
shutdown
alarm
is specified in 3/4-0SP-059.6.
This item is closed.
(Closed)
IFI 250,251/85-24-05.
Determine
adequacy
of
procedures
for
making temporary
changes
per
TS 6.8'.
AP 0109.7, Responsibilities
of the
Procedure
Upgrade
Program
Group,
and
AP 0109.3,
On the
Spot
Changes
to
Procedures,
were
reviewed
and determined
to adequately
comply with the
review and approval
requirements
of TS 6.8.3.
This item is closed.
(Closed)
URI 250,251/85-26-06.
Evaluate advisability of rescaling interim
power
range
currents.
OP
0204.5,
Nuclear
Design
Check
Tests
During
Startup
Sequence
After
Refueling,
specifies
performing
a
Nuclear
Instrumentation
System
(NIS) 'detector
mini-calibration
per
OP-12304.9
prior to exceeding
50K power.
The data
obtained
are not required to be
used
for resetting
NIS
voltages
and
currents.
However, if tilt
calculations (per
ONOP 12308.2)
exceed
TS limits and flux map data is not
used
to prove that
an actual tilt condition
does
not exist,
then
the
requirements
of
TS
3'.6
(h)
and 3.2.6 (i) will be
implemented,
as
applicable.
This item is closed.
(Closed)
IFI 250,251/85-30-02,
Determine if new equipment
is promptly
added to calibration program.
Administrative Procedure
(AP) 0190.15
step
3.4. 14, requires
a meeting
coordinated
by the Engineering
Department
to
review PC/Ms for operability and maintainability.
Step 5.8.4 requires the
PC/M
coordinator
to
implement
the
required
maintenance/calibration
schedule
in
the
General
Equipment
Management
program.
This
item is
closed.
(Closed)
IFI 250,251/84-09-04,
Failure to implement
an adequate
post trip
reviews.
AP-0103. 16, Duties
and Responsibilities
of the Shift Technical
Advisor, Dated March 10,
1987, Appendix B, contains
adequate
guidance for
performing
a post trip review.
Additionally, the trip review requires the
Plant Manager - Nuclear to give permission for unit restart.
This item is
closed.
(Closed)
Deviation
250/84-04-07,
Failure to fully implement
TMI item
I.C.6,
Independent
Verification.
Procedure
O-ADM-031,
Independent
Verification dated
June
25,
1987,
provides
plant policy
and detailed
direction
on the implementation of independent 'verification requirements.
This item is closed.
(Closed)
IFI
250/84-26-01,
Reactor
,coolant
system
(RCS)
leak
rate
calculation
did
not
address
temperature
and
pressurizer
level.
Procedure
3/4-OSP-041. 1,
Leak Rate Calculation,
dated
May 29,
1987,
has
been revised to include
RCS temperature
and pressurizer
level.
This
item is closed.
(Closed) IFI 250, 251/80-06-03,
Residual
heat
removal
system
(RHR) suction
isolation
valves
MOV 750
and
751
are
not
environmentally
qualified.
Additionally, the
licensee
has
not prioritized the
RHR recirculation
switchover sequence.
The
MOVs 750 and 751 are
considered
environmentally
qualified (EQ) and are listed on the licensee's
EQ list.
The licensee
has
a
new
emergency
operating
procedure
Transfer
to
Cold
Leg
Recirculation,
which prioritizes the
RHR switchover
sequence.
This item
is closed.
(Closed)
IFI 250,
251/80-06-04,
Provide
adequate
training for management
personnel
in the area
of accident
analysis.
The licensee
has
conducted
training in the area of Mitigating Core
Damage,
which is TMI item II.B.4,
this item was closed
in inspection
report
250,
251/81-33.
This item is
closed.
(Closed)
IFI 250/84-18-03,
Review the adequacy
of the piping and supports
associated
with the containment
instrument air lines for both units.
The
licensee
completed
an
evaluation
dated
August 16,
1985
and
noted that
seismic
boundary
anchors
were
needed
to meet the current
standards
to
isolate the safety related portions of the piping from non-safety related
portions.
The licensee
has
completed
the installation of these
anchors,
Unit
3
on
May 29,
1987
and Unit 4
on February
15,
1986.
This
item is
closed.
10=
(Closed)
Switch Electrical
By Pass Circuit for
Safeguard
Service
Valve Motors.
This circular required
the licensee
to
verify that all valves
important to safety
which have
the torque switch
bypass circuits installed
do in fact have these circuits and to establish
controls
to
assure
that
switch
bypass
circuits
are
not
inadvertently
removed.
This circular is administratively
closed
and the
completion
of the circular's
requirements
will be tracked
under
the
response
Motor-Operated
Valve
Common
Mode Failure
During Plant Transients
Due to Improper Switch Settings.
This item is
closed.
(Closed) IFI 250/84-39-05
and 251/84-40-04,
The adequacy
of IEC plant work
order documentation
and procedural
guidance.
The licensee
has implemented
new procedures
that provide guidance.
These
procedures
are
O-GMI-102. 1,
Troubleshooting
and
Repair Guidelines,
and
O-ADM-701, Plant
Work Order
Preparation.
This item is closed.
(Closed) IFI 250, 251/84-09-02,
Failure to take prompt corrective actions.
The action taken
by the licensee for violation 250, 251/84-04-02,
and the
implementation
of the
PEP
program
should
provide
adequate
guidance
on
taking prompt corrective actions.
This item is closed.
(Closed)
IFI 250,
251/84-04-03,
Corrective action for Leeds
and Northrup
Speedomax
chart recorders.
The licensee
has
implemented
controlled plant
work order (84-30,
84-31) to replace
the records capillary
system with
disposable
marker s.
This item is closed.
(Closed)
IFI 250,
251/84-09-06,
Review of AFW and Air/Nitrogen System.
The licensee
completed
a review of the
AFW system,
letter dated
May 15,
1984,
Subject
Auxiliary
System
Improvement
Project.
Additionally, the
AFW system
was included in the licensees
PEP p~ogram
and
the phase II select
system review.
This item is closed.
(Closed)
250,
251/86-25-06,
Determine
the
basis
for
allowing
maintenance
activities which can affect the performance of safety-related
equipment to begin without requiring that the maintenance
be preplanned
or
performed
in accordance
with written procedure.
Procedure
AP-0190. 19,
Control of Maintenance
on Safety
Related
and guality Related
Systems,
requires
a
PWO
be initiated for all
maintenance
work and that
work
performed
for
emergency
situations
be
thoroughly
documented
by the
journeyman.
This item is closed.
(Closed) IFI 250, 251/85-02-06,
Research,
document
and then set the torque
switch and limit switch setting for all motor operated
valves.
This item
will
be
administratively
closed
and
action
tracked
under
Motor-Operated
Valve
Common
Mode Failure
During Plant Transients
Due to
Improper Switch Setting.
This item is closed.
(Closed)
URI 251/86-06-03,
Evaluate the probable
cause of the misalignment
of the
4B
containment
spray
pump.
On July 16,
1986,
the
licensee
completed
an
evaluation
of the misaligned
containment
spray
pump
and
determined
the following.
The
4B containment
spray
pump shaft failed as
a
result of not verifying pump rotation
and not performing
a realignment
prior to conducting
surveillance
testing.
The
misalignment
may
have
resulted
due to improper installation
on
a pipe elbow that
had
minimum
wall thickness.
Procedure
MP 4207.2,
Containment
Spray
Pump
Disassembly,
Repair
and Assembly,
was revised to include
hand rotation of the
pump and
alignment
of
pump to motor prior to running
the
pump.
This
item is
closed.
Onsite
Followup
and In-Office Review of Written
Reports
Of Nonroutine
Events
(92700/92712)
0
The
Licensee
Event
Reports
(LERs)
discussed
below were
reviewed
and
closed.
The Inspectors verified that reporting requirements
had been
met,
root
cause
analysis
was
performed,
corrective
actions
appeared
appropriate,
and generic applicability had been considered.
Additionally,
the
Inspectors
verified that
the
licensee
had
reviewed
each
event,
corrective actions
were implemented,
responsibility for corrective actions
not fully completed
was clearly
assigned,
safety
questions
had
been
evaluated
and resolved,
and violations of regulations or TS conditions
had
been identified,
(Closed)
LERs
250/84-19
and
250/84-20,
TS-RCS
Leakage.
These
two
LERs
were generated
as
a result of excessive
RCS leakage that caused
two Unit 3
shutdowns.
The root cause of the events
was failed gland flanges
on seven
3/4
inch
Rockwell-Edwards
stop
valves.
The flanges
were replaced
with
steel
strong
backs
via
PC/M 84-129.
Technical
correspondence
PTN-Tech-87-182,
to the maintenance
department
specifies
maximum vendor
values for the flange bolts to prevent
overtorquing
which would
to intergranular
stress
corrosion cracking'ERs
250/84-19
and
250/84-20
are closed.
(.Closed)
Appendix
R Safe
Shutdown
Review.
This
LER was
generated
by the
licensee
to
make
advanced
notification to the
NRC of
preliminary results
of the Unit
3 Appendix
R safe
shutdown
review.
The
Region II Appendix
R inspection findings are documented
in IE Report 250,
251/86-09.
LER 250/85-25 is closed.
(Closed)
LOCA Analysis
Discrepancy.
This
LER
was
a
voluntary report
made
by the licensee to advise the
NRC of a discrepancy
between
(W)
LOCA analysis
and the Turkey Point
FSAR.
The
W
analysis
assumes
the failure of one of the four High Head Safety Injection
(HHSI) pumps,
the
FSAR assu'mes
the failure of two HHSI pumps.
A W safety
evaluation
reported that the
Emergency
Core Cooling System
(ECCSQ safety
criteria
as
stated
in
would not
be
impacted
by the
scenario of two failed HHSI pumps.
LER 250/85-33 is closed.
(Closed)
Engineered
Safety
Feature
(ESF) Actuation-Safety
Injection.
On
February 7,
1985,
following
a Unit
4 trip,
a
spurious
safety
injection
signal
was
generated
in the
system.
No safety
12
injection flow was delivered
to the
RCS.
All equipment
actuated
and
functioned
as designed.
The root cause of the event was
a blown fuse
on
a
flow comparator
(FC-485) of the
(SG) coincident with an
electrical
spike in the circuitry of a flow comparator
(FC-475) of the A
SG.
The blown fuse
was
replaced
and instrument calibration
checks
were
performed
on A SG flow instrumentation.
LER 251/85-05 is closed.
(Closed)
TS-Containment
Spray
Pump (CSP).
On February
18,
1985, with Unit 4 at
100% power, the
4A CSP was declared
The
4A
480V power supply breaker closing springs were discharged
and the
closing spring charging motor was turned off.
The
pump beaker
could not
have
closed
in response
to
a start signal.
It was
presumed
that this
condition
had existed
since
the last operability surveillance
test
was
performed
on
February
6,
1985.
Power
was
immediately
restored
to the
closing
springs
and
an operability test
was
performed
on
the
pump.
Operations
personnel
were
briefed
on
the
significance
of the
event.
LER 251/85-07 is closed.
(Closed)
TS-EDG.
On April 25,
1985, with Unit 4 at
100%
power,
the
A
was
taken
out of service
for periodic
maintenance
coincident with the
3B 4160V bus being out of service.
This rendered
the
3A,
4A and
3B high
head
safety injection
pumps
which is in
noncompliance
with TS.
Upon recognition of this
event,
the
A
was
tested
and returned to service.
Operations
personnel
were briefed
on the
importance
of ensuring
the operability of opposite
train
equipment
prior to electively
removing
an
from service.
is
closed.
(Closed)
TS Heat Tracing.
On June
23,
1985, with Unit 4 at
27% power,
two channels
(8A 5 8B) of critical heat tracing
on the boric
acid
pump suction lines were declared
out of service.
TS allow only one
channel
to be inoperable.
A plant shutdown
was implemented
as required
by
TS 3.0. 1.
The root
cause
of the failed
channels
was
a
short circuit
created
when
excess
heat tracing wiring from circuit 9 contacted circuit
8.
Both circuit 8 channels
were
repaired
and
returned
to
service.
Circuit
9
was
shortened
to
prevent it from contacting
circuit 8.
LER 251/85-18 is closed.
(Closed)
LERs
251/84-09
and 251/85-20,
TS-Containment Integrity.
These
LERs were
generated
as
a result of events
in which Operations
personnel
didn't fully appreciate
the
TS
requirements
for containment
integrity.
Later
similar events
led to
issuance
of violation 251/86-41-01.
The
corrective
actions
to this violation,
as
stated
in
the
licensee's
response,
address
the corrective actions of the
LERs.
LERs 251/84-09
and
251/85-20 are closed.
(Closed)
On
November 29,
1985,
the Engineering
Department
notified Turkey Point that portions of the accumulato~ fill line were not
seismically installed.
PC/Ms 86-80 and 86-004,
Unit 3 and
Makeup
Header - Seismic. Upgrade,
have
been
completed
by the
Nuclear
Startup
Department
and turned over to Operations.
This item is closed.
13
(Closed)
On
March 29,
1986,
the
4A Intake Cooling Water
( ICW)
Pump
Was
Inadvertently
Started.
The
actuation
was
due
to
a
construction
worker physically disturbing
the relay.
The construction
worker received
instructions
to
use
caution
when working in the vicinity
of safeguards
equipment.
This item is closed.
(Closed)
On October 23,
1985, the
3A Residual
Heat
Removal
(RHR)
Pump
was declared
out of service
due to failure to meet
the
seal
leakage
acceptance
criteria during
an operability test.
The
licensee
repaired
the pump's mechanical
seal
and conducted
This item is closed.
(Closed)
On
November
11,
1985,
Unit 3 subcritical
reactor
trip occurred
as
a result of manually re-inserting nuclear instrumentation
system
channel
N-32 instrument
power fuses while attempting to energize
the channel.
The licensee
repaired the voltage
power supply
and replaced
a
capacitor
in
the
channel
pre-amplifier.
Additionall'y,
all
post-maintenance
testing
was
satisfactorily
completed.
This
item is
closed,
(Closed)
On
December
4,
1985,
AFW initiated
due to
an
improper
alignment
of the
condensate
system.
The
licensee
properly
aligned the condensate
system,
the operators
involved were
counselled
on
the
need
for clear
and
concise
inter shift turnovers
and
procedure
3/4-0P-073,
Condensate
System,
was revised to require
a plant clearance
for the
Steam
Generator
pump motor breaker
when the condensate
system
was
aligned
in the recirculation
cleanup
mode.
This
item is
closed'Closed)
On June
12,
1986,
the
3A and
3C charging
pumps
were out of service,
exceeding
TS requirements.
The
3C pump was repaired
and
retested
satisfactory.
The
3A
pump
cracked
weld was repaired
and
satisfactorily
placed
back
into
service.
Additionally, the
licensee
developed
a
PC/M to replace
the
pump packing with longer life packing.
This item is closed.
(Closed)
On April 10,
1986, it was determined that
a flow
reversal
condition existed
concerning
the
component
cooling water
(CCW)
supply to high head safety .injection (HHSI) pumps
seal
and thrust bearing
coolers.
The
licensee
has
completed
PC/M
83-008,
to correct
piping
misrouting.
This item is closed.
(Closed)
On August 9,
1986, the Unit 4 Auxiliary Feedwater
System
was
actuated
during
a
system test
due to personnel
error.
The
operator
received
counselling
concerning
his
actions.
This
item is
closed.
(Closed)
On
September
6,
1986, while Unit 4 was at
38K
power,
a reactor trip occurred
due
to
a
4C
steam
generator
isolation circuity failure.
The failed circuity,
a light socket,
was
replaced
and the other sockets for Unit 4 were inspected.
The turbine
14
trip solenoid
was replaced
and procedure
3/4-0SP-089,
Main Turbine Valves
Operability Test,
was revised to test the turbine trip solenoids.
This
item is closed.
(Closed)
Unit 4, Shutdown
on September
16,
1986,
due to Rod
Position Indication (RPI)
System
Malfunction.
The failed line voltage
regulator
was replaced.
The licensee
developed
a preventative
maintenance
procedure,
0-PME-028. 1,
RPI Inverter Maintenance.
This item is closed.
The following LERs were reviewed
and closed
based
on an in-office review.
The
inspectors
verified that reporting
requirements
had
been
met, root
cause
analysis
was performed, corrective actions
appeared
appropriate,
and
generic applicability
had
been
considered.
In addition,
each
LER was
reviewed for 'and
determined
not
to
require
further
onsite
inspector
followup.
Reactor Protection Actuation Reactor Trip
Engineered
Safety Features
Actuation - Turbine Runback
Monthly and Annual Surveillance
Observation
(61726/61700)
The
inspectors
observed
TS required surveillance
testing
and verified:
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
( LCO) 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 inspectors
verified that testing
frequencies
were met and tests
were performed
by qualified individuals.
The
inspectors
witnessed/reviewed
portions
of
the
following test
activities:
Unit 3 Engineered
Safeguards
Integrated Test,
3-OSP-203
Auxiliary Feedwater Train
1 Operability Verification, 4-OSP-075.
1
Nuclear Plant Operator
Logsheets,
4-0SP-201.3
System
Flowpath Verification, 4-0SP-075.5
Safety Injection
Pumps Inservice Test,
O-OSP-062.2
No violations or deviations
were identified within the areas
inspected.
Maintenance
Observations
(62703/62700)
Station
maintenance
activities of 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.
15
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
proce'dures
used
were
adequate
to control the activity;
that
troubleshooting
activities
were
controlled
and
repair
records
accurately
reflected
the maintenance
performed; that functional testing
and/or
calibrations
were
performed
prior to
returning
components
or
systems to service; that
QC records
were maintained; that activities were
accomplished
by qualified personnel;
.that parts
and materials
used
were
properly certified; that radiol,ogical controls were properly
implemented;
that
QC hold points were established
and
observed
where required;
that
fire prevention controls
were
implemented;
that outside contractor
force
activities were controlled in accordance
with the'pproved
QA program;
and
that housekeeping
was actively pursued.
The following maintenance activities were observed
and/or reviewed:
Intake Cooling Water
Pump Motor - Overhaul
and Maintenance,
MP 3407.6
Pump
C Steam
Leak Repair,
PWO 69-2507
Pump
C Trip
and
Throttle
Valve
Repair,
PWO
69"5668
A Skid 'Tank Leak Repair,
PWO 300812
Emergency Diesel
Generator
A Governor Troubleshooting
Steam Trap ST-53 Drip Leg Drain Valve Repair,
PWO 019
No violations or deviations
were identified within the areas
inspected.
However, violation 251/87-33-02 discussed
in paragraph ll appears
to have
resulted
due
to
maintenance
personnel
failing to
inform appropriate
managers that
a suspected
valve packing leak was observed to originate at
a degraded
weld in the train
system.
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 followup
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.
Additionally, 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 also 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.
16
The
inspectors
walked
down accessible
portions of the following safety
related
systems to verify operability and proper valve/switch alignment:
A and
Control
Room Vertical Panels
and Safeguards
Racks
Intake Cooling Water Structure
4160 Volt Buses
and 480 Volt Load and Motor Control Centers
Fire Protection
Deluge Valves
a.
Technical
Specification
Requirements
Not
Implemented
For Reactor
Protection Setpoint Reductions
On
July 12,
1987,
dur ing
routine
backshi ft
inspection
at
approximately 7:00 p.m., while the Unit 4 reactor
was at
76 percent
power,
the inspector
determined
that that the licensee
was
not in
compliance with TS 3.2.6.(i).
This specification
requires,
in part,
that
when the Quadrant
Power Tilt Ratio
(QPTR)
exceeds
two percent
for
24
hours
and
the
reactor
hot
channel
factors
have
not
been
determined
to be acceptable,
then reactor protection
setpoints for
Over-Power
Differential
Temperature
(OPDT)
and
Over-Temperature
Differential Temperature
(OTDT) shall
be reduced.
QPRT is a measure
of radial
power differences existing in the upper and lower quadrants
of the
reactor
core
as
measured
by the
four excore
power
range
nuclear instruments
(PRNIs).
The licensee
took immediate
action to verify that the hot channel
factors
were acceptable
by performing
and evaluating
a Unit 4 flux
map
using
moveable
incore
detectors.
Subsequent
evaluation,
completed
on July 13,
1987 at approximately
1:50 a.m., verified that
the hot channel
factors were acceptable.
This alleviated the need to
reduce
the
OPDT and
OTDT setpoints.
The incore detectors
indicated
that the quadrant
power ratios did not exceed
two percent.
The
are,
by design,
below
50 percent
reactor
power.
Standard
TS
and the licensee's
interim
TS address
QPTR in terms of compensatory
actions only when reactor
power exceeds
50 percent.
During initial reactor
startup
following refueling and
PRNI detector
replacements,
QPTR calculations
are
likely to
be
erroneous
until
the
can
be
calibrated.
Consequently,
by
administrative
procedure,
the licensee
performs flux maps prior to
exceeding
50 percent
power to allow interim calibration of each
PRNI.
Calibration of the
PRNI at
50 percent
power
causes
the
(as
calculated
using the excore
PRNIs) to closely agree with the quadrant
power ratios measured
during the flux mapping.
The licensee
performed
two flux maps at 50 percent
power
on July 8,
1987,
because
the detector for PRNI N-41 had been replaced during
a
recently concluded
outage.
One
map indicated
a
QPTR of 2 '
percent
for the
lower core with peaking factors
which would have
precluded
reactor operation at
100 percent
power.
This flux map was
suspected
17
of containing
erroneous
data
due to maintenance
problems
which had
been
experienced
with the
moveable
detector
drive
mechanisms.
A
second
flux
map
indicated
no
greater
than
2
percent.
Additionally, the results of this second
map compared favorably with
similar maps performed prior to the outage.
Calibration data derived
from the flux maps
was
not installed
in the
because
one
instrument,
N-44, was out of service.
Taking
a second
instrument out
of service for calibration would result,
by design,
in
a reactor
trip.
Since
calculated
gPTR
was
less
than
two
percent,
power
escalation
was'uthorized
by the
Reactor
Engineering
Supervisor.
Power
was
slowly increased
between
July 10-11.
QPTR calculations
performed in the morning
and
evening
on July 10 were less
than
two
percent.
However,
a
gPTR calculation
which was
begun
on July 10 at
ll:50 p.m.
and completed
on July ll at 12:Ol a.m. indicated
an
upper
detector tilt of 2.84 percent.
The increase
in gPTR with increasing
power was not expected
and was
not clearly understood.
Consequently,
when the
Reactor
Engineering
Supervisor
was
contacted
at
home
and
informed of the
change,
he
recommended
that reactor
power be maintained
below full power by two
percent
for each
1 percent
of
gPTR.
This action
implemented
the
requirements
of
TS 3.2.6.(h).
gPTR
was calculated
numerous
times
between
the early morning
on Saturday July ll and the early evening
on July 12,
a
period
of approximately
43
hours.
All results
indicated that the
gPTR was greater
than two percent.
Additionally,
the magnitude of the tilt appeared
to change.
By July ll at 7:50 a.m.
it had increased
to 5.2 percent.
It then decreased
to 2.0 percent
on
July
12 at ll:30 a.m.
and began to increase
reaching
2.4 percent at
7:05 p.m.
on July 12.
Discussion with members of the Operations staff on July 12 revealed
a
lack of concern for the indicated condition.
Several
reasons
were
presented
as to why the condition was not
a concerns
These
included:
(1)
a belief that
the flux
maps
performed
on July 8
adequately
verified that the indicated
gPTR was not real; (2)
a perception that
the
gPTR was relatively stable;
(3)
a belief that the high ratio was
caused
by the inability to install corrected calibration currents in
the
because
instrument
N-44
was
out of service;
and (4)
a
belief that
the
safety
significance
of the
indicated
problem
was
diminished since reactor
power
had
been
maintained
below the limits
specified
in
TS 3.2.6.(h).
Additionally, the Operations
staff did
not appear
to
be
aware of the requirements
to reduce
the
OPDT and
OTDT setpoints
as specified in TS 3.2.6.(i).
Discussions
with
an
NRC core physics
inspector
confirmed that the
above reasonings,
evaluated singularly and in unison, did not provide
an engineering
basis
upon which to verify that the indicated
gPTR
condition
was not real.
Such
a verification would generally
have
been
accomplished
through the performance of additional flux maps at
the power level
and control rod position that existed
when the
gPTR
exceeded
two percent.
The licensee
declined to perform additional
18
flux maps
even though the reactor
had been
increased
from 50 percent
to
90 percent
power
and
had suffered
a small turbine
runback since
the last flux maps
were taken.
This option is authorized
by TS
as
long
as all appropriate
compensatory
power reductions
and reactor
protective setpoint reductions
are
implemented.
This failure to
implement
the
requirements
of
TS 3.6.2.(i) is
a
violation.
This violation applies to Unit 4 only (251/87-33-03).
Licensee
Determined
That
(AFW) System
Was
On July 15,
1987, with the Unit 4 reactor at
100 percent
power, the
licensee
determined that the Unit 4 AFW system
was inoperable
because
both trains of safety-related
nitrogen for the automatic flow control
valves
were
isolated.
The
discrepancy
was
discovered
during
a
routine inspection
by
a Turbine
Operator
tasked
with logging the
status
of the
system
on
a periodic (4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) basis.
The
discrepancy
was
immediately
reported
to the
Operations
Department
staff
and the erroneously
closed
valves
were
opened,
returning the
system
to
service.
"Procedure
4-0P-065.2,
and
Main
Steam
Isolation
Valve
Gas
Supply
System,
revision dated
June
18,
1987,
was expeditiously performed to verify that all valves
were in the correct position.
The discrepancy
received the highest levels of management
attention,
including the establishment
of a
human
performance
review
team
to'nvestigate
and identify the root cause
of the valve misalignments.
It was determined that valves which were required to be
open
had been
closed earlier
on July 15,
1987 by a Turbine Operator.
The operator
had
previously
been
assigned
for
an
extended
period of time to
Unit 3, which was in
an
extended
refueling outage.
The
AFW system
was not required
by
TS to
be
on Unit 3
because
of the
shutdown
status
of the
reactor.
Apparently the
operator
was
not
aware that
a June
1987 revision to procedure
4-0P-065.2
required
3
nitrogen bottles
per train
be in service,
as
opposed
to
one bottle
which
had
previously
been
acceptable.
During
his
1:00 a.m.
inspection of the nitrogen bottles
he noticed that three bottles were
in service
instead
of one.
Believing this to be
a discrepancy,
he
realigned
the bottles with out the
use of the
approved
procedure.
This caused all bottles to be isolated, either by the valve on top of
the bottle or the in-line isolation valve further down stream being
closed.
This valve realignment
was
performed for both
trains,
rendering both inoperable.
The perceived
discrepancy
was not reported to the Operations staff by
the Turbine Operator.
No quality record was created to document
the
realignment.
Logs taken
on the nitrogen
system status at 5:00 a.m.,
9:00 a.m.,
and 1:00 p.m.
documented
(erroneously)
that
1 bottle
was
in service
per train.
The 5:00 p.m.
log reading
indicated that
no
bottles
were
in service
but this
fact
was
not
brought
to
the
19
attention
of supervisory personnel.
The Turbine Operator taking the
9:00 p.m.
log readings identified the discrepancy.
TS 3. 18 requires that the
when the reactor is heated
above
350 degrees.
One train is allowed to be out of service for 72
hours.
Two trains
are
not allowed to
be
simultaneously
out of
service.
The
Turkey
Point
system
design
basis
document,
developed
under the
Performance
Enhancement
Program,
specifies that
the
AFW system
shall
be capable of automatic operation
upon loss of
instrument air for
a period of
two
hours
without
any
required
operator
action
outside
the control
room.
The
AFW flow control
valves
normally use
the non-safety
related,
non-seismic
instrument
air
system
for automatic
valve positioning.
The
instrument air
system
can not,
because
of its unqualified
nature,
be
assumed
to
exist for post accident
AFW operation.
The nitrogen
system,
although
it is often
referred
to
as
a
backup
system,
is required
to
be
to
support
post
accident
AFW system operation.
For this
reason,
the
system,
like
the
system,
is
both
safety-related
and seismically installed.
During the 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> that the nitrogen trains were out of service the
instrument air system
remained in service
and operated
normally. If
instrument
air
pressure
had
become
excessively
low,
existing
administrative
procedures
require that the reactor
be shutdown.
The failure to implement the requirements
of TS 3. 18,for AFW system
operation is
a violation which applies to Unit 4 only (251/87-33-01).
Inadequate
Procedure
For Deluge Fire Systems,
Repeat Violation
On July 14,
1987,
the inspectors
performed
a walkdown of the fire
suppression
systems
for the Unit 3
and
4
component
cooling water
(CCW) pump rooms.
One Unit 3 deluge valve,10-837,
was not correctly
aligned in that
a pressure
switch was isolated.
This discrepancy
did
not prevent
the deluge
valve from operating
but it did prevent the
activation
of the control
room
and
local
area
actuation
alarms.
Since the pressure
switch was isolated,
the 'activation of the deluge
station
would not
be received at the control
room
and local
alarm
panels.
Indication of fire protection
system actuation
would be only
by
secondary
means
such
as
low fire main
pressure
or fire
pump
initiation.
The ability
to
remotely
verify flow through
the
appropriate
deluge station would be lost.
This discrepancy
is
a
repeat
of
a similar problem
described
in
Inspection
Report
250,
251/86-33 dated
September
3,
1986.
Violation
250,251/86-33-03
was
issued
because
adequate
procedures
for the
control
of the
deluge
valves
did
not exist,
contrary
to
the
requirements
of TS 6.8.1.
The licensee
responded
to the Notice of
Violation
on
October 3,
1986
in
PTN-TECH-86-743.
The
proposed
corrective action was to revise
procedure
0-OP-016. 1, entitled Fire
Protection
Water System,
to incorporate
deluge
system valve lineups.
20
Procedure
0-OP-016. 1 was revised
on
December 9,
1986 to include the
auxiliary
support
valves
necessary
to properly align the
deluge
system,
However, for each deluge
system,
the isolation valve for the
alarm
pressure
switch
was
omitted
from
the
lineup
sheets.
Consequently,
the procedure
remained
inadequate
because
the pressure
switches
for the
alarm stations
remain
isolated
when
the
deluge
systems
are returned to service.
TS 6.8. 1 requires that written procedures
and administrative policies
be
established
that
meet
or
exceed
the
requirements
and
recommendations
of Appendix
A of USNRC Regulatory
Guide 1.33.
Regulatory
Guide 1.33,
Appendix A, states
that procedures
should
be
established
for the operation of plant fire protection
equipment.
The fai lure to have
an
adequate
procedure for the alignment of fire
protection deluge
systems is
a repeat of violation 250,
251/86-33-03
(250, 251/87-33-04).
11.
Engineered
Safety Features
Walkdown (71710)
To verify system operability the inspectors
performed
a complete walkdown
of all accessible
equipment
of the Unit
(AFW)
system.
One train of steam to the
AFW pumps
was found to be degraded
as
described
below.
This matter was immediately brought to the attention of
the
licensee
and
NRC
Region II management.
The licensee
declared
the
train inoperable
and
implemented
the
shutdown
requirements
of TS 3.0.1.
Unit 3 remained in cold shutdown
(mode 5) during the inspection period and
consequently its Engineered
Safety
Features
were not required to
be in
service.
The following criteria
were
used,
as appropriate,
during the
walkdown:
a.
System
lineup
procedures
matched
plant
drawings
and
the as-built
configuration.
b.
Equipment conditions
were satisfactory
and
items that might degrade
performance
were identified and evaluated
(e.g.
hangers
and supports
were operable,
housekeeping
was adequate).
c.
Instrumentation
was
properly valved
in
and functioning
and that
calibration dates
were not exceeded.
d.
Valves were in proper position, breaker alignment was correct,
power
was available,
and valves were locked/lockwired as required.
Local
and
remote
position
indication
was
compared
and
remote
instrumentation
was functional.
f.
Breakers
and instrumentation
cabinets
were
inspected
to verify that
they were free of damage
and interference.
21
A walkdown of the Unit 4 portion of the
AFW system
was performed
between
July
17 and July 20,
1987.-
On July 17, plant parameters
were
steady
and
no
demand for AFW system
operation
existed.
The reactor
was critical at
less
than
1 percent
power and the turbine generator
had been
removed from
service
due to apparent
condenser
tube leakage.
On July
17
the
inspector
observed
a pinhole
leak in the
steam
supply
piping which supplies
turbine driven
AFW pumps
A and
C.
The
leak
was
located
on
a
two inch diameter
pipe that branches
from the four inch
diameter train
1 steam line.
The two inch pipe supplies
steam trap
53 and
system
low point drain
AFSS 43.
The leak was located adjacent to AFSS 43.
Additionally, the
2 inch diameter pipe was heavily corroded.
The licensee
determined that
a maintenance
concern
had been identified on
July 11,
1987,
when plant personnel
reported
seeing
small
amounts of water
drop
from the vicinity of drain
valve
AFSS
43.
This resulted
in the
issuance
of a deficiency tag
and Plant Work Order
(PWO) which stated that
either
AFSS
43
had
a valve
stem
packing
leak or the
steam
pipe
was
leaking,
A definitive evaluation
of the source of the leak could not be
made
because
the area of concern
was obscured
by insulating lagging.
The
PWO
was
erroneously
classified
as
Non-Nuclear Safety
Related
(NNS)
and
therefore
did not receive
high priority.
Troubleshooting
did not begin
until the morning of July 14,
1987,
when the
was
removed
and
a
Journeyman
confirmed the existence
of the corroded
pipe
and the pinhole
leak.
Between
July 14-17,
a
weld repair
plan
was
developed
by the
Mechanical
Maintenance
Department.
No evaluation of the
extent of the
degradation
was performed
and
of the Train
1
steam
supply
was
performed.
The
steam
remained
in service
and
aligned
for
automatic
operation.
The
PWO
remained
classified
as
non-safety related.
In the early
afternoon
on July 17,
the
inspector
requested
that the
licensee
evaluate
the extent of the pipe corrosion
and its effect on
system operability.
The licensee
determined that the piping was actually
safety
related
and
a
Non-Conformance
Report
(NCR)
was
issued
to the
Engineering
Department for evaluation.
At approximately 4:30 p.m. it was
determined that,
based
on the extensive visible corrosion
and the observed
pipe leak, the integrity of the
steam line was
suspect
and could not be
assured
without further testing.
A specific concern existed that the weld
joint at which the pinhole leak originated
was of unknown quality and that
pipe wall thinning in excess
of allowed tolerances
could
have resulted
from the observed corrosion.
The licensee
determined
that the train
1
steam line was
and
that sufficient evidence
of the inoperable
condition
had
been
obtained
during the July
14 pipe inspection
and
was
not effectively evaluated.
Consequently,
the licensee
determined
that
AFW train
1
had
been
out of
service in excess
of the
72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Limiting Condition for Operation
(LCO)
allowed by TS 3. 18 for single train operation.
22
TS 3.0. 1 requires,
in part, that when
an
LCO is not met then the reactor
shall
be
placed
in hot
standby
(mode
3) within six hours.
Licensee
interviews with the Journeyman
revealed that
he started
work on July 14 at
7:00 a.m. but his recollection
was that
he did not remove the lagging and
expose
the
source
and nature of the leak until approximately ll:00 a.m..
Consequently,
the licensee
determined
that the
72
hour
LCO expired
at
11:00 a.m.
on July
17
and
mode
3 was required at 5:00 p.m.
At 5:12 p.m.
on July 17,
1987 the Unit 4 reactor
was placed
in hot standby
and plans
were
implemented
to bring the unit to cold shutdown
(mode 5) as required
by additional portions of TS 3.0. 1.
This
event
is of concern
because
the
licensee
identified
a condition
adverse
to quality
and initially failed to
recognize it
as
such.
Maintenance
troubleshooting
and repairs
were
erroneously
identified
as
non-safety
related.
This
resulted
in
a
three
day delay
before
the
potential
through wall pipe leak postulated
in the
PRO
was investigated
(July 11-14).
An appreciation for the potential of train failure through
weld degradation
and/or pipe wall thinning was not shown
by the Mechanical
Maintenance
Oepartment
subsequent
to the July
14 inspection.
10 CFR 50, Appendix B, Criterion XVI, as
implemented
by Florida Power and
Light Topical Quality Assurance
Report
FPLTQAR 1-76A, Revision
10,
and
TQR
16.0,
Revision
5, entitled 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.
Quality
Assurance
Manual,
Quality
Procedure
16. 1,
Revision
8,
delineates
requirements
for assuring
that conditions
adverse
to quality
are promptly corrected.
The failure to promptly identify and correct
a condition
adverse
to
quality
is
a
violation.
This
violation
applies
only
to
Unit
4
(251/87-33-02).
Plant Events (93702)
The following plant events
were reviewed to determine facility status
and
the
need for further
followup action.
Plant
parameters
were evaluated
during transient
response.
The significance of the event
was evaluated
along with the
performance
of the
appropriate
safety
systems
and
the
actions
taken
by the
licensee.
The
inspectors
verified that required
notifications were
made to the
NRC.
Evaluations
were performed relative
to the
need for additional
NRC response
to the event.
Additionally, the
following issues
were
examined,
as
appropriate:
details
regarding
the
cause
of the event;
event chronology; safety
system performance;
licensee
compliance
with approved
procedures;
radiological
consequences,
if any;
and proposed corrective actions.
The licensee
plans to issue
LERs on each
event within 30 days following the date of occurrence.
23
On July 1,
1987, while Unit 3 was in cold shutdown,
Unit 3 underwent
a
safety injection automatic initiation from
a
containment
high pressure
signal. Electrical
department
technicians
required
a
hose
connection
to
test penetration
canisters
on Unit 4.
To accomplish this they borrowed
an
IKC pressure
regulator
from Unit
3 being utilized in preparation
for
initiating a containment
high pressure
signal for safeguards
testing.
The
high pressure
supply
was manipulated
to verify valve closure.
This caused
a high containment
pressure
signal.
On July 5,
1987,
while Unit
3
was
in cold
shutdown, the
D-MCC [Motor
Control
Center]
was deliberately
de-energized
during Unit 3 Integrated
Safeguards
testing.
D-MCC supplies
power to the
4A emergency
containment
cooler
fan and'ssociated
CCW valves.
On loss of power, these
associated
CCW valves failed open
as designed,
causing
Unit 4
CCW flow to increase
which
lowered
pressure.
This
caused
the
4B
pump automatic
start
on low pressure
signals
On July 15,
1987,
due to
an incorrect valve alignment,
while Unit 4 was
operating at 1004 power, train
1 and
2 AFW backup Nitrogen was unavailable
for approximately
20
hours.
This
issue
is
discussed
in detail
in
paragraph
10.
The licensee
promptly returned the system to operation
when
the problem was discovered.
On July 17,
1987,
Unit 4 was placed in hot shutdown 'due to
a leak on
train
1
steam
supply line.
Licensee
personnel
determined that the leak,
which was very small,
existed
due to
a degraded
weld in the
AFW system
train
1 steam
Since repairs
were not initiated within the allowed
72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />
LCO specified in Technical Specification 3. 18, the licensee
placed
Unit 4 in mode
3 and subsequently,
mode 4,
as required
by TS 3.0. 1.
This
issue is discussed
in detail in paragraph
11.
Summary of International
Atomic Energy Agency (IAEA) Activities
In fulfillment of the
Safeguards
Agreement
between
the United States
and
the
IAEA, the
IAEA selected,
on July 19,
1985,
Turkey Point Unit 4 for
participation in its international
safeguards
inspection
program.
A major
portion of this program requires
the continuous surveillance of the fuel
inventory
through
camera
monitoring
and
seal
wire
placement.
The
surveillance
program
ensures
that
the
fuel
inventory
does
not
change
between
physical audits.
The inspectors
verified, during routine tours of the Unit 4 Spent
Fuel
Pool
(SFP)
and the accessible
portions of the containment building, that
seal
wires were in place
and intact
and that surveillance
cameras
were
Seal
wires are
placed
by
IAEA inspectors
on the containment
equipment
access
hatch,
the missile shields
and the reactor
vessel
head
seismic restraints.
Only the
seal
wires
on the equipment
hatch
can
be
observed
from outside the containment building.
The containment
building
is not normally entered during power operation.
Two surveillance
cameras
are installed
in the Unit 4
SFP.
The
area
is
always
accessible
through locked and alarmed doors.
Two
IAEA inspectors,
accompanied
by an
NRC representative,
visited the
site
on July 16,
1987.
Work performed
included
changing
the film in the
two Unit 4 spent
fuel pool monitoring cameras,
placing seal wires on the
Unit 4 equipment hatch,
and reviewing fuel inventory records.
By mutual
IAEA, NRC and licensee
agreement,
seal wires were not placed
on the Unit 4
missile
shields
because
neutron
dose
rates
near
the reactor
head
are
prohibitively high while the reactor is critical.
These
seals will be
installed during
a subsequent visit when the reactor is subcritical.
Plant Procedures
(42700)
A review
was
performe'd
of selected
plant
procedures
to verify, that
overall plant procedures
are in accordance
with regulatory requirements,.
that procedure
changes
are
made
in accordance
with TS requirements
and
that procedures
are adequate.
Numerous
procedures,
including administrative
procedures
(ADM), emergency
operating
procedures
(EOP),
off-normal
operating
procedures
(ONOP),
operating
procedures(OP),
and surveillance
procedures
(OSP) were reviewed
to verify that appropriate
reviews
and approvals
were
performed prior to
issuance.
It
was
determined
that
an
effective
procedure
review
and
approval
program exists
and is being
implemented
in
a
manner
consistent
with
TS
requirements.
These
requirements
include
review of proposed
procedures
by the Plant Nuclear Safety
Committee
(PNSC)
and approval
by
the Plant Manager-Nuclear.
Of the
40 procedures
selected
at random, all
had been
reviewed
by the
PNSC and approved
by the Plant Manager-Nuclear.
A'eview
was
performed
to verify that
procedure
changes
were
made to
reflect
TS changes
and license
revisions.
TS
amendment
numbers
118 and
112,
for Units
3
and
4 respectively,
established
Standby
Systems,
which
requires
two
standby
pumps
to
be
available with 60,000 gallons of water in the demineralized
water storage
tank.
The
licensee
implemented,
on
October
14,
1986,
procedure
0-OP-074. 1, to provide standby
feedwater operating instructions
and valve
alignment
guidance.
Additionally, surveillance
procedure
O-OSP-074.3,
Standby
Steam
Generator
Pumps
Availability Test,
has
been
developed
to implement the surveillance
requirements
specified in TS 4.21
for the
system.
Procedure
0-OSP-200. 1,
Schedule
of Plant'hecks
and
Surveillances,
revision
dated
July 17,
1987,
implements
the
monthly
requirement
to perform
O-OSP-074.3.
Procedures
also
existed
for the
verification of demineralized
water
storage
tank
level
(each shift,
OP-0204.2)
and testing
the
standby
pumps
using
the
cranking
diesels
(each refueling outage,
O-OSP-074.4).
Also reviewed were
TS Amendment
numbers
124 and 118.
This change required
that condensate
storage
tank level
be verified to contain at least
185,000
gallons of water twice
a day.
This requirement is verified in procedure
3-OSP-201. 1.
The volume check is performed
each shift,
exceeding
the
12
hour TS surveillance periodicity.
0
25
Temporary
procedure
changes
are
governed
by the requirements
of TS 8.3.
Temporary
changes
to pr'ocedures
may be
made provided that:
the intent of
the original
procedure
is
not altered;
the
change
is
approved
by two
members of the plant management staff, at least
one of whom holds
a Senior
Operators
License,
on the unit affected;
and the
change
is documented,
reviewed
by the
PNSC
and
approved
by the
Plant
Manager-Nuclear
within
fourteen
days
of
implementation.
The
requirements
of
are
implemented
by Administrative
Procedure
0109.3,
entitled
On
the
Spot
Changes
(OTSC) to Procedures,
revision dated
June
18,
1987.
The procedure
effectively implements
Specific requirements
exist specifying
that
changes
be evaluated
against
eighteen criteria to determine
whether
the change
must receive prior PNSC review before issuance.
The guidelines
include consideration
as to whether
a proposed
change:
modifies
a
TS or
FSAR requirement;
decreases
personnel
safety;
changes
the
design
of
a
safety
related
component
or
system;
changes
the
Emergency
Plan;
or
involves
a
less
conservative
method
of
performing
an
activity.
Affirmative answers
to these
and other
similar questions
result in the
change
being reviewed
by the
PNSC prior to incorporation.
This method of
review
appears
to effectively
prevent
changes
of intent
from being
implemented via temporary changes.
The
OTSC
logbook
was
reviewed
to verify that
temporary
changes
were
'pproved
as required
by
Approximately 50
OTSCs were reviewed.
No discrepancies
were
identified with respect
to
required
approval
signatures,
license
qualifications
or
time
constraints.
Various
procedures
were selected
at random from the control
room procedure files.
Those
procedures
having
OTSCs
were
clearly
marked.
Copies
of the
applicable
OTSCs were readily available.
An examination
of the plant working file for procedures
resulted
in
no
identifiable
out of date
procedures,
However, it was
determined
that
approved
temporary
changes
to procedures
(OTSCs) are not available
in the
working file.
The sole
record of these
temporary
changes
is located in
the control
room.
Consequently,
personnel
who take
a procedure
from the
working file, located
in the Nuclear Administration Building (NAB), have
no indication
as
to whether
a
temporary
change
has
been
made
to the
procedure
.
The possibility exists that
an outdated version'f
a procedure
could be used
by supervisory
personnel
in the
NAB during the performance
of their duties.
This
has
not posed
a problem for operating
personnel
= because
they use copies of procedures
supplied
by the Shift Administrative
Technician
from the control
room file.
Significant procedural
improvements
have
been realized during the past two
years
due
to the
Procedure
Upgrade
Program
(PUP).
This 'program
uses
qualified technical writers to develop
enhancements
in procedure
content
and format.
Several
hundred
procedures
have
been
rewritten to
improve
their
effectiveness.
Additional
procedures
are
being
developed
to
implement the preventative
maintenance
program
and to implement additional
surveillances
which will be required
when the custom
TS are
superseded
by
upgraded,
standardized
TS.
0
26
The quality of the plant procedures
can
be attributed to the
PUP which has
maintained
high
standards
for procedure
content,
format
and
review.
Writers guides
have
been
issued
to standardize
the developmental
process
in the areas of administration
and operations
(O-ADM-101), health physics
(O-ADM-106),
maintenance
(O-ADM-107),
off-normal
(O-ADM-108),
and
emergency
(0-ADM-109) procedures.
The plant staff has
been
intimately
.
involved in the review of proposed
procedure upgrades'his
has, for the
most
part,
prevented
the
issuance
of procedures
which
can
not
be
effectively implemented
due to field conditions.
Specific procedures
have
been
reviewed
and evaluated
during routine
and
reactive
NRC inspections
between
January
and July 1987.
As indicated in
the
respective
reports,
procedural
discrepancies
have
been
identified.
However, these
appear to be individual, isolated procedural
oversights
and
are
not indicative of
a
programmatic
weakness.
Numerous
older
plant
procedures
have not yet been revised
by the
PUP.
Discrepancies
which are
identified in these
procedures
are
handled
on
a real-time basis
through
use
of OTSCs.
The plant's policy of verbatim compliance
has generally
precluded
"working around"
procedural
inadequacies
and typically results
in a halt to procedural
implementation until the discrepancy is corrected.