ML17342B026

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Insp Repts 50-250/87-43 & 50-251/87-43 on 870921-1019. Violation & One Unresolved Item Noted.Major Areas Inspected: Backshift Insp in Areas of Annual & Monthly Surveillance, Maint Observations & Reviews,Esfs & Operational Safety
ML17342B026
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 11/04/1987
From: Brewer D, Macdonald J, Mcelhinney T, Wilson B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML17342B024 List:
References
50-250-87-43, 50-251-87-43, NUDOCS 8711190285
Download: ML17342B026 (25)


See also: IR 05000250/1987043

Text

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UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W.

ATLANTA,GEORGIA 30323

Report Nos.:

50-250/87-43

and 50-251/87-43

Licensee:

Florida Power

and Light Company

9250 West Flagler Street

Miami, FL

33102

'ocket

Nos.:

50-250

and 50-251

Facility Name: Turkey Point

3 and

4

License Nos.:

DPR-31

and

DPR-41

Inspection

Conducted:

September

21 - October

19,

1987

Inspectors:

.

R.

rewer,

Senior

Residen

nspector

B. Macdonal

, Resident

Insp

tor

d

,

F.

Mc

hinney,

Resident

Inspec

~ "--."

ruce Wilson, Section Chief

Division of Reactor Projects

/~ V.S'7

Da

e Signed

II 9 f3

Date Signed

ii 4/I'9

Date Signed

zt F77

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,

and plant events.

Results:

One violation and

one unresolved

item were identified.

87iii90285 87iii2

PDR

ADOCN 05000250

G

PDR

0

II ~

REPORT

DETAILS

Persons

Contacted

Licensee

Employees

C.

A'

D.

D.

T.

J.

D.

4'J

R.

0.

J.

R.

E.

AG

"R.

O'D

AJ

R.

J.

"R.

W.

p.

AG

4'J

AD

D.

S.

A.

AC

4'B

"R.

S.

Odom, Vice President

J.

Baker, Plant Manager-Nuclear

H. Southworth,

Maintenance

Superintendent

A. Chancy, Site Engineering

Manager

(SEM)

0. Grandage,

Operations

Superintendent

A. Finn, Training Supervisor

D. 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

( I&C) Department

Supervisor

C. Strong, Electrical

Department Supervisor

W. Bladow, Quality Assurance

(QA) Superintendent

E.

Lee, Quality Control Inspector

F. Hayes, Quality Control

(QC) Supervisor

A. Warriner,

QC Operations

Supervisor

J. Earl,

QC Supervisor

W. Haase,

SEG Chairman

A. Labarraque,

Technical

Department

Supervisor

G. Mende, Operations

Supervisor

Arias, Regulation

and Compliance

Supervisor

D. Hart, Regulation

and Compliance

Engineer

C. Miller, Senior Technical Advisor

A. Kaminskas,

Reactor

Engineering

Supervisor

W. Hughes,

Health Physics

Supervisor

Solomon,

Regulation

and Compliance

Engineer

Donis, .Engineering

Department

Supervisor

E. Meils, .Chemistry Supervisor

W. Jones,

Procedure

Upgrade

Program Supervisor

D. Ferrell, Licensing Engineer

G. Abbott, Startup Administrative Coordinator

D. Kelly, Mainteance

and Specialized

Traaining Supervisor

Blaschke,

QA/QC Coordinator,

Stores

Sontag,

INPO Coordinator

Other

licensee

employees

contacted

included

'construction

craftsmen,

engineers,

technicians,

operators,

mechanics,

and electricians.

"Attended exit interview on October

19,

1987.

2.

Exit Interview

The

inspection

scope

and

findings

were

summarized

during

management

interviews

held throughout

the reporting period with the Plant Manager

Nuclear

and selected

members of his staff.

An exit meeting

was conducted

on

October

19,

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.

One violation was identified:

Three

examples

of failure

to

meet

the

requirements

of

Technical Specification (TS) 6.8. 1, in that off normal operating

procedures

were not

properly

implemented

when

a nuclear

instrument

was

removed

from service

and

troubleshooting

was

performed

on

a critical

heat

tracing circuit

thermostat

and

an administrative

procedure

was

not properly implemented,

in that

a

val.ve

was

not properly controlled

locked

open

(paragraph

9)

(250, 251/87-43"01) .

Unresolved

Items (URI)

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.

One

unresolved

item is

identified in this report.

Review the

health

physics,

maintenance

and

operational

procedures

for

regulatory

compliance

with

regard

to

the

September

30,

1987

Process

Radiation

Monitor

System

(PRMS) R-ll

alarm

and

resultant

automatic

containment

and control

room ventilation isolation

(paragraph

8)

(250,

251/87"43-02).

Followup on Items of 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"'Tmplemen'ted within

the time periods specified in the reply.

(Closed) Violation 251/79-12-01.

Failure to declare

the pressurizer

level

channels

inoperable

when

their

indication

was

out

of

tolerance.

OP-0204.2,

Periodic Tests,

Checks

and Operating

Evolutions,

require

the

Reactor

Operator

perform the periodic

checks

on pressurizer

level

every

shift.

Additionally,

the

procedure

requires

that

a test

should

be

repeated

for verification of the condition

and

a Plant work order written

if a periodic test,

check or evolution does

not meet acceptance

criteria.

Violation 251/79-12-01 is closed.

(Cl osed)

Yiol ati on

250,

251/85-13-06.

Fai 1 ur e

to

imp 1 ement

the

requirements

of

10 CFR 50.55a.(g),

Inservice

Inspection

requirements

for

Intake Cooling Water(ICW)

system.

Plant Change/Modification

(PC/M) 85-38

wa's performed to inspect,

clean

and repair the above

ground

ICW piping and

PC/M 85-151

was

performed

on sections

of internal

ICW piping.

Procedure

OP-0206.6,

ASME Section

XI Pressure

Tests

for Quality

Group A,

B

and

C

systems/components,

was

revised

to

insure

detailed

review of pressure

boundaries,

complete

walkdowns

and verification of test

boundaries

are

performed.

Violation 250, 251/85-13-06 is closed.

(Closed)

Violation 251/84-36-03.

Failure to maintain facility operating

records

as

required

by TS.

On October

31,

1984,

during

performance

of

'P

1009. 1,

Estimated

Critical Conditions

(ECC)

the

licensee

failed to

maintain

a copy zf

a

completed

work sheet.

OP 1009.1,

revision

dated

October

11,

1984,

Section 7.1

specified

that completed

ECC work sheets

were quality records

and therefore

must

be retained.

OP 1009. 1, revision

dated

March ll, 1987, Sections

7. 1 and 7. 1.1 more specifically states

the

requirement

to retain

and maintain

ECC work sheets

in accordance

with QA

records

requirements.

Violation 251/84-36-03 is closed.

(Closed) Violation 250,

251/85-13-05.

Failure

to verify the operability

of opposite train safety related

equipment prior to elective

removal of an

Emergency

Diesel

Generator

(EDG)

from service.

On April 25,

1985

the

A EDG was

removed

from service for preventive

maintenance

when

the

3B

safety

injection

pump

was

unavailable.

AP 0103.4,

In-Plant

Equipment

Clearance

Orders,

was revised August 28,

1985, to ensure that prior to the

removal

of an

EDG from service that the opposite train Engineered

Safety

Feature

(ESF)

equipment

and its

emergency

power

is verified to

be

available.

Labels

were affixed to the

EDG control

panels

re-enforcing

this requirement.

Violation 250, 251/85-13-05 is closed.

(Closed) Violation 251/85-30-05.

Inadequate

Temporary

System

Alteration

(TSA)

procedure

al lowed

loss

of

containment

integrity.

A non-Plant

Nuclear Safety

Committee

(PNSC)

approved

and

an

inadequate

TSA procedure

caused

Unit 4

containment

integrity to

be

lost

between

June

26

and

August 8,

1985,

in that the

4C

SG blowdown isolation valve CV-4-6275C was

not operable.

An inappropriate

TSA resulted

in the inability of the valve

to close

on

a phase

A containment isolation signal.

Procedure

O-ADM-503,

Control

and

Use of Temporary

System Alterations,

was revised

and approved

by the

PNSC

on

January

14,

1986.

Training Brief

106

was

issued

with

letter

PTN-TRNG-86-033 to explain the

procedure

changes

and to reenforce

the

need

to adhere

to the instruction to ensure

regulatory

compliance.

Violation 251/85-30-05 is closed.

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)

(Closed)

URI 251/78-12-04.

Inadequacy

of procedures

to include

a method

for obtaining

permission

from operations

to

work

on

safety-related

equipment.

Administrative

Procedure

0190. 19,

Control of Maintenance

on

Safety Related

and Quality Related

Systems,

revision dated August 4,

1987,

contains

the

requirements

and

methods

for

obtaining

permission

from

operations.

URI 251/78-12-04 is closed.

(Closed)

URI 250,251/85-13-08,

testing of Auxiliary Feed Water

(AFW) check

valves.

ASME

Secti on XI

code,

par agraph

IWV-35226,

Normally

Closed

Valves,

states

in part:

valves

that

are

normally closed

during plant

operation

and

whose

function

is

to

open

on

reversal

of

pressure

differential shall

be tested

by proving that the disk moves promptly from

the

seat

when

the closing differential pressure

is

removed

and flow is

initiated.

This is verified by visual

or electrical

observation.

AFW

check

valves

140,240,

340,

AFP0-9,

AFPD-ll and

AFPO-13

are

tested

in

accordance

with ASME Section II requirements.

Additionally the

AFW pump casings

and discharge

lines

are

inspected

by

touch

every shift to detect

back

leakage.

URI

250,

251/85-13-08

is

closed.

(Cl osed)

URI

251/86-35-01.

Missed

TS

survei

1 1 ances.

Violation

250,

251/86-39-02

was "issued

as

a result of the

programmatic

weakness

in the

identification and scheduling

of TS required

surveillance,

as

documented

in URI 251/86-35-01.

Corrective actions

were

reviewed

and the violation

was

closed

in inspection

report

250,

251/87-10.

URI 251/86-35-01

is

closed.

II

(Closed)

IFI 251/84-18-01.

Steam

dumps to condenser

did not

arm

due

to

wiring error.

The cause of the wiring error

was

covered

in Inter-office

Correspondence

dated

June

13,

1984,

and

appears

to

be

due to confusion

with the

lead

arrangement

at its terminal

block. "IFI 251/84-18-01

is

closed.

(Closed)

IFI 251/84-29-04,

concerning

the Safety

Engineering

Group

(SEG)

review of

emergency

containment

cooler

(ECC)

control

valve

actuator

relocation.

The

licensee

concluded

in

correspondence

SEG 87-12,

dated

February

17,

1987, that the

ECC control valve actuators

as installed

by

PC/M 83-123/124

are seismically supported.

The actuators

were modified by

PC/M 85-137/138 to allow manual

operation

to comply with Appendix

R safe

shutdown analysis.

The requests

to relocate

the actuators,

REA 85-33,

was

cancelled.

IFI 251/84-29-04 is closed.

Onsite

Followup

and

In-Office Review of Written

Reports

Of Nonroutine

Events

(92700/92712)

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)

LER 250/85-26.

A

Boric

Acid

Storage

Tank

(BAST)

Boron

Concentration

Exceeded

Technical

Specification

(TS)

Limits.

On

September ll,

1985,

with Unit 3

operating

at

100

power,

the

boron

concentration

in the

A BAST, which was aligned to Unit 3,

was 22,800 parts

per million (ppm).

TS 3.6.c.3 requires

boron concentration

to

be

between

20,000

and

22,500

ppm.

The licensees'orrective

actions

were

reviewed

and

found acceptable.

The revision to

TS 3.6.c.3

to include

an

action

statement

which would provide

a reasonable

amount of time to correct the

boron concentration

was not

made at this time.

The licensee

is in the

process of revising all of the

TS to the'Standard

TS format.

The upgraded

Turkey Point

TS will include

an action:statement

with

a specified

time

allowance prior to exceeding

TS requirements.

LER 250/85-26 is closed.

(Closed)

LER 250/86-30.

Reactor Trip and Safety Injection Actuation

Due

to Personnel

Error.

On June

27,

1986, with Unit 3 at

100% power

a reactor

trip and safety injection actuation

occurred.

The cause of the event

was

due to Instrumentation

and Control (IKC) personnel

performing sections

of

Operating

Procedure

(OP)

14004. 1,

"Steam Generator

Protection

Channels

Periodic Test",

on Channel III, without verifying that Channel III was not

the

controlling

channel.

As

a

result

of this

incident,

violation

250/86-33-01

was issued

on September

3,

1986.

Corrective actions for this

LER will be

tracked

by followup of the violation.

LER 250/86-30

is

closed.

(Closed)

LER 251/87-07.

Excessive

leakage

during leak rate test of the

Personnel

Hatch.

A local

leak rate

performed

March 10,

1987,

on

the

Unit 4 Personnel

Hatch.

The

leakage

rate

measured,

150,000 cc/min,

was

greater

than

the

9.6

La

acceptance

criteria of 45,000 cc/min.

A unit

shutdown

was

commenced.

The

excessive

leakage

rate

was

caused

by

a

malfunctioning

linkage

mechanism

in the

equalizing

valve

on

the inner

door.

The

valve

and

linkage

were

replaced

and

the

personnel

hatch

penetration

was retested satisfactorily.

LER 251/87-07 is closed.

(Closed)

LER 251/87-08.

Core Alterations

Performed

Without Containment

Integrity.

On April 9,

1987,

maintenance

initiated the lift of the Unit 4

upper

internals

without prior notification to

the control

room.

The

containment

purge

valves

had

been

jumpered

open

defeating

their

containment

isolation

function.

Violation 251/87-14-02

was

issued

as

a

result,

and was eventually included in Enforcement Action':"

EA 87-97.

The

corrective

actions

to

this

event will

be

tracked

via

violation

251/87" 14-02.

LER 251/87-08 is closed.

(Closed)

LER 251/87-10.

EDG Automatic Start

due

to personnel

error.

On

May 22,

1987,

the

B

EDG experienced

an auto-start

when

an electrician

failed to properly follow procedures

when performing testing

on the

4160

Volt bus

undervoltage

protection circuit.

Violation 251/87-22-01

was

issued

as

a result.

Corrective actions

to this event will be tracked via

violation 251/87-22-01.

LER 251/87-10 is closed.

(Closed)

LER 251/87-12.

Automatic Start of the

4B Component

Cooling Water

(CCW)

pump during

safeguards

testing

on Unit 3.

On July 5,

1987,

the

Unit 3

ESF Integrated test,

3-0SP-203,

was performed.

The

D Motor Control

Center

(MCC)

was

de-energized

by procedure.

The

D MCC

powers

the

4A

J

0,

emergency

containment

cooler

and

fan

and

associated

CCW valves.

The

valves

are

designed

to fail open.

When the valves

opened

CCW flow was

increased

and

pressure

decreased.

The

decreased

CCW

pressure

was

sufficient to cause

an auto-start

of the

4B

CCW pump,

also

as

designed.

The

LER

was

submited

because,

although

all

equipment

functioned-

as

designed,

procedure

3"OSP-203 did not anticipate

or recognize

that

a

CCW

pump would auto-start.

LER 251/87-12 is closed.

(Closed)

LER 251/87-14,

AFW train inoperable

due to

steam

supply piping

leak.

On July 14,

1987,

a small through wall steam line leak was observed

on the Unit 4 train I AFW steam

supply.

The condition went unevaluated

through July 17,

1987,

when it was

brought

to the attention

of upper

licensee

management.

Violation 251/87-33-02

was

issued

for failure to

promptly identify and correct conditions

adverse

to safety.

Corrective

actions

to this

event will be tracked via violation 251/87-33-02.

LER 251/87-14 is closed.

(Closed)

LER 251/87-17.

Isolation of AFW nitrogen

backup

system

due to

personnel

error.

On July 15,

1987,

a Turbine Operator

(TO) improperly and

contrary to procedure

re-aligned

the

AFW nitrogen

backup

system for both

trains

on Unit 4,

such that

the

system

was inoperable.

The condition

existed

for approximately

17

hours

until

another

TO

recognized

the

misalignment

and properly restored it.

Violatiion 251/87-33-01

was issued

as

a result

and was included in EA:87-85.

The corrective actions to this

event

wi 1 l

be

tracked

vi a violation

251/87-33-01.

LER 251/87-17

i s

closed.

(Closed)

LER 251/87-18.

Operation

in excess

of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with greater

than

a

2% Quadrant

Power Tilt Ratio

(QPTR).

On July 9-10,

1987,

Unit 4

nuclear

instrument

N-41 indicated

a

QPTR greater

than

2% power for in

excess

of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without any

TS action statement

requirements

being met.

Violation 251/87-33-03

was issued

as

a result.

The corrective actions to

this event will be tracked

via violation 251/87-33-03.

LER 251/87-18 is

closed.

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:

3/4-0SP-041.1,

Reactor Coolant System

(RCS)

Leak Rate Calculation

3/4-0SP-019.2,

ICW System

Flowpath Verification

3-0SP-046.3,

CVCS-Boration

Systems

Flowpath Verification

3/4-OSP-075. 1,

AFW Train

1 Operability Verification

3/4-OSP-0?5.2,

AFW Train

2 Operability Verification

3/4-0SP-075.3,

AFW Nitrogen Backup System

LowPressure

Alarm Setpoint

And Leakrate Verification

4-0SP-089,

Main Turbine Valves Operability Test

No violations or deviations

were identified within the areas

inspected.

8.

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.

The following items

were considered

during this review,

as appropriate:

that approvals

were. obtained prior to initiating work; that activities

were

accomplished

using

approved

procedures

and

were

inspected

as

applicable;

that procedures

used

were

adequate

to control

the activity;

that

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

(}C records

were maintained; that activities were

accomplished

by qualified personnel;

that parts

and materials

used

were

properly certified; that radiological controls were properly

implemented;

that

gC hold points

were established

and

observed

where required;

that

fire prevention controls

were

implemented;

that outside

contractor

force

activities were controlled in accordance

with the approved

gA program;

and

that housekeeping

was actively pursued.

a.

Reactor Coolant

Pump

(RCP)

3B High Vibration Troubleshooting.

During the Unit 3 refueling outage

in January

1984, vibration

problems

were noted

on the

3B

RCP

and traced

to

a

bowed

pump shaft

below the

pump

and

motor coupling.

To compensate

for the

damaged

shaft,

a tapered

shim was installed between

the coupling halves'he

3B

RCP was scheduled

to be replaced during the

1987 Unit 3 refueling

outage but was not because

vendor support could not be provided.

The

motor

had

been

uncoupled

in anticipation of replacement.

The motor

and

pump were recoupled without equipment

changeout.

High vibrations

were

experienced

again

on

the

3B

RCP

during

unit restart.

On

September

25,

1987

the

licensee

decided

to bring Unit 3 to

Cold

Shutdown,

due to high vibrations

on the

3B RCP,

a leaking pressurizer

spray

valve,

and

seal

table

leaks.

Upon

investigation

of the

possible

cause

of high vibration,

maintenance

personnel

found that

the

tapered

shim

used

to

compensate

for

the

bowed

shaft

was

improperly installed.

The

shim is divided into

two

wedge

shaped

halves,

each

with

a

taper

from

0.061 inches

to

0.050 inches.

Apparently

as the maintenance

personnel

were recoupling the

pump to

the motor,

one half of the

shim was inadvertently reversed

such that

the effect of the

wedge

was

negated.

Each half of the

shim

has

a

locating

notch

in it.

One half has

a single notch

while the other

half has

a double

notch.

The licensee

attributed

the

cause

of the

improperly placed

shim to personnel

error.

The maintenance

personnel

used

a micrometer to verify shim thickness

before installation

but failed to verify proper: orientation after

installation

by notch location.

The licensee

indicated that this is

the first time this type of incident

has

occurred

with the

shim.

Because

The

3B

RCP motor

was scheduled

to have

been

replaced

and

shim

usage

is

unique

to

the

3B RCP,

the

licensee

did

not write

an

instruction

or

procedure

for

shim reinstallation

prior to this

incident.

Although the licensee

does

not plan to uncouple

the motor

and

pump prior to motor replacement

during the next refueling outage,

procedure

CMM-41. 1, Reactor Coolant

Pump Uncoupling and Coupling, is

currently

under

revision

to include

special

instructions

for the

3B

RCP shim installation.

This item will be closely monitored by the

resident

inspectors

during future inspections.

ESF Actuation Caused

By An Ongoing Maintenance Activity.

On September

30,

1987,

PRMS Channel

R-11 alarmed initiating a Unit 3

containment

and control

room ventilation isolation.

The isolation

occurred

when

R-11

detected

increased

activity in the auxiliary

building

caused

when

mechanical

maintenance

transported

a

highly

contaminated,

unshielded

reactor coolant

pump

seal

water injection

filter from the

Unit

3 charging

pump

room through

the auxiliary

building to the rad waste building.

The 3F220B seal

water injection

filter had just, been replaced

by mechanical

maintenance.

Maintenance

procedure

0-PMM-047. 10,

CVCS [chemical

and volume control

system]

and

Letdown

Systems

Fluid

Filters

Replacement,

revision

dated

December

23,

1986 provided instruction.

The work was performed

under

plant work order

(PWO) //2277/63.

The health physics

requirements

for

the

replacement

and

transportation

of the filter were detailed

in

RWPs 87-2314-A

and

2318 respectively.

The filter was

replaced

in

accordance

with the procedure,

but the control

room was not notified

prior to maintenance

personnel

transporting

the fi,lter from the work

area

as

required

in

Section

6.2

of

0-PMM-047. 10.

Further

FPL

correspondence

dated

June

17,

1985, to the health physics

operations

supervision

from the

Health

Physics

Operations

Supervisor,

stated

that all liquid processing filters such

as

the

seal

water injection

filters that

are

greater

than

25

roentgen

per

hour

(R/Hr),

on

contact,

shall

be transported

via the

shielded transfer cart.

The

seal

water injection filter transported,

unshielded,

on September

30,

1987

was

40R/Hr

on contact.

It is

recognized

that

an

approved

procedure

and

a supervisory directive were not followed.

Due to the

time required

to review all pertinent

maintenance,

operational

and

health

physics

procedures

and regulations

for applicability to this

event, it will be identified as

URI 250, 251/87-43-02.

The

licensee

has

taken

corrective

actions.

Health

Physics

instruction

HPI-8,

Removal

and

Transportation

of

Used

CVCS Fluid

Filters,

revi sion

dated

October 8,

1987,

directs

that

the

HP

Operations

Supervisor

or his assistant

must

be notified prior to

activating

the

RWP,

the

shielded cart will be

used

in all filter

replacements

and will be carried

by

a fork lift, if available,

and

the normal travel path or an alternate

path will be verified prior to

the start of the evolution.

No violations or deviations

were identified.

9.

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 operabil.ity 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.

By observation

and direct

interviews,

verification

was

made

that

the

physical security plan was being

implemented.

Plant

housekeeping/cleanliness

conditions

and

implementation

of

radiological controls were observed.

Tour s of the intake structure

and diesel, auxiliary, control

and turbine

buildings were conducted

to observe

plant

equipment

conditions

including

potential fire hazards,

fluid leaks

and excessive

vibrations.

The

inspectors

walked

down accessible

portions of the following safety

related

systems

to verify operability and proper valve/switch alignment:

A and

B Emergency Diesel Generators

Auxiliary Feedwater

Control

Room Vertical Panels

and Safeguards

Racks

Intake Cooling Water Structure

4160 Volt Buses

and

480 Volt Load and Motor Control Centers

Component

Cooling Water

Main Steam Isolation Valve Control

Unit 4 Feedwater

Boric Acid Storage

Tanks

'a

~

Heat Tracing Circuitry Troubleshooting

On September

28,

1987 with Unit 4 in Mode I at

100~o power,

the Heat

Tracing

Trouble

alarm

annunciated..

The

Unit 4

Reactor

Control

Operator

(RCO)

referred

to

Off

Normal

Operating

Procedure

(ONOP)

O-ONOP-048,

Off-Normal

Critical

Heat

Tracing

System

A

0

10

Temperature,

revision dated

June

26,

1985.

A Nuclear Operator

(NO)

was

dispatched

to

determine

which

heat

tracing circuit

had

an

off-normal temperature.

Critical heat tracing circuit number

8 was

found to be reading

191F,

which is above the alarm setpoint of 190F.

The

NO reported

that the

heat tracing thermostat

for circuit 8 was

set at 200F.

Under the direct'upervision of the Unit 4

RCO, the

NO

set

the

thermostat

to

190F without

the

use

of the'equired

electrical

maintenance

procedure

2507. 1,

Maintenance

Heat

Tracing

Circuits.

The

Unit 4

RCO

then

recirculated

the

boric acid

tank to

cool

the line

in order

to clear

the

alarmed

annunciator.

Although these

actions

were sufficient to clear

the

annunciator,

O-ONOP-048,

step 3.2.5 directs

the

RCO to submit

a

PWO

to have Electrical

Mai.ntenance

check the heat tracing

thermostat if

no degraded

insulation or abnormal

system

operation

is discovered.

Failure to follow the instruction of 0-ONOP-048 is

example

one of

violation 251/87-43-01.

Discussions

with Electrical Maintenance

personnel

indicate that this

heat tracing circuit is of the Chemelex self-regulating

type.

As the

temperature

increases

along the length of the circuit, the resistance

also increases

which will limit the current flow, thus

reducing

the

heat

up rate.

The thermostats

are

used

as

a backup with this type of

circuitry.

Electrical

Maintenance

has

a

detailed

procedure,

Maintenance

Procedure

2507. 1,

Maintenance

Heat

Tracing

Circuits,

which outlines the steps for troubleshooting this type of circuit.

b.

Nuclear Instrument Declared

Out Of Service

On October 2,

1987 with Unit 4 in Mode

1 at

100% power, nuclear

power

range

instrument

N-44

had

a

Rod

Drop

alarm

which

appeared

to

be

spurious.

Operations

personnel

declared

N-44 out of

service

in

accordance

with 4-0NOP-059.3.

The Unit 4

RCO completed

the procedure

and

continued

with other duties.

An

NRC inspector

reviewing

the

event discovered that step 5.3. l.a(4), which directs the operator to

transfer

the Comparator

Channel

Defeat switch to the failed channel,

had

not

been

performed,

The transfer

of the

Comparator

Channel

Defeat

switch allows

the operator-'to

'cl'ear

the

channel

deviation

alarm

and

be able to receive

the

alarm for a flux deviation

on the

remaining three

power

range

channels.

The Plant Supervisor

Nuclear

(PSN)

was

immediately notified of the discrepancy

and

the

step

was

successfully

performed

by the

RCO.

Failure to follow the instruction

of 4-0NOP-059.3 is example

two of violation 250, 251/87-43-01.

c.

Valve Lock Found Incorrectly Attached

On

October 3,

1987,

during

a routine

plant tour,

the

inspectors

noticed that the

A BAST recirculation

isolation valve,

344,

was not

locked

as required

by procedure

O-ADM-205, Administrative Control of

Valves,

Locks,

and

Switches,

revision

dated

August ll,

1987.

The

valve

was open,

as required,

and the lock was engaged.

However, the

lock wire

was

not properly

threaded

through

the

valve

handwheel

and-valve

around

the process

pipe.

Consequently,

the valve could be

closed

while

the

lock

remained

engaged.

The

licensee

promptly

corrected

the discrepancy.

Failure to implement the instruction of 0-ADN-205 is example three of

violation (250, 251/87-43-01).

Operation

Of The

Waste

Gas

System

In An Alignment Not Addressed

In

The

FSAR

Numerous auxiliary building evacuations

have

occurred

from 1978 to

1986,

during

VCT gas

space

purge evolutions.

In 1986 there

were

53

auxiliary building evacuations,

42 of which occurred

during

VCT

purges.

In

1978 the

gas

strippers

appear

to have

been

taken out of

service.

Their associated

power

panel

was also de-energized

which

left the waste

gas vent header

to the gas strippers isolation valves,

CV-4A and CV-4B, open in their failure

mode position.

Initially it

was

believed

that

the

gas

strippers

were

gas tight,

making

the

position of CV-4A and

CV-4B irrelevent.

During ensuing

VCT purges

many auxiliary building evacuations

occurred

due to high airborne

contamination.

The licensee

believed the high airborne contamination

levels were

due to high backpressure

in the existing waste

gas

system

flowpath causing

leakage

from various

system

components

.

OP-2132. 1

(now OP-047. 1),

VCT Gas

Space

Concentration

Control,

was revised to

allow the vent header

to discharge directly to the

CVCS holdup tanks

by opening

normally closed

valve

4627,

the vent header to cover gas

cross-connect'isolation

valve.

This reduced

system

backpressure

and

helped

reduce

airborne

contamination'f

the

auxiliary building.

However, this specific

VCT purge alignment

was not addressed

by the

FSAR.

Plant

Quality

Assurance

(QA)

observed

this

condition

and

generated

a

Corrective

Action

Request

(CAR),

via

correspondence

QAO-PTN-87-598,

dated

October

3,

1986.

A series

of

QA prompted

responses

and

requests

for additional

clarifications,

ultimately

'eading

to

an

Engineering

Safety

Evaluation,

followed

and

are

documented

below.

October 20,

1986,

October

24,

1986,

November 7,

1986,

January

21,

1987,

July 9,

1987,

July 31,

1987,

Gas Releases

PTN-PMN-86-430,

Response

to

CAR

QAO-PTN-86-660,

Response

to

CAR; Additional

Information Requested

PTN-Tech-86-854,

Response

to

QA

Nemo

QAO-PTN-86-660

JPE-PTP0-87-108,

Turkey

Point

Unit 3

Operability

and

Substantial

Safety

Hazards

Evaluation

for the

Radwaste

Gas

System;

REA-TPN-86-140,

File:

TPN-86-140,

Oue

June

26,

1987

QAO-PTN-87-588,

Overdue

Commitment

Operability

Review

and

Substantial

Safety

Hazards

Evaluation

for

the

Radwaste

Gas

System

JPE-PTP0-87-1632,

Request

for

extension

until

October 2,

1987

to

complete;

REA TPN-86-140, File:

TPN-86-140-2

12

July 31,

1987,

October 8,

1987,

October

14,

1987,

October

14,

1987,

JQA-87-133,

Extension

Granted

QAO-PTN-87-857,

CAR-QA0-86-598,

Overdue

Committment

QAO-PTN-87-868,

Request

for Extension

CAR

JPE-PTP0-87-2097,

Turkey Point Units

3

8

4

Maste

Gas

System Evaluation,

REA TPN-86-140,

File:

TPN 86-140-2

The evaluation,

JPE-PTP0-87-2097,

concluded that

a substantial

safety

hazard

as

defined

in

10 CFR 21 did not exist.

However, it

was

determined

that the

performance

of

a

VCT purge with valve 4627 open

such that the flowpath would be directly to

the

holdup

tanks,

as

opposed

to

the

waste

decay

tanks,

is outside

the

design

basis

flowpath

as described

in the

FSAR.

OP-047. 1

was

revised April 9,

1987,

to

ensure

that

valve

4627 is controlled

closed

during

VCT

purges

which meets

the

FSAR design

basis.

The auxiliary building

airborne

contaminator

problem

was

resolved

by maintaining

the

gas

stripper isolation valves,

CY-4A and CV-4B, closed.

10.

Engineered

Safety

Features

Mal kdown (71710)

The inspectors

performed

an inspection designed

to verify the operability

of the

Emergency

Oiesel

Generators

and Auxiliary Equipment

by performing

a

complete

walkdown of al 1

accessible

equipment.

The

following criteria

were used,

as appropriate,

during the walkdown:

I

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.

4f.

Local

and

remote

position

indication

was

compared

and

remote

instrumentation

was functional.

Breakers

and

instrumentation

cabinets

were

inspected

to verify that

they were free of damage

and interference.

The

Inspectors

reviewed

procedure

O-OSP-023.6,

Oiesel

Generator

System

Flowpath

Verification,

revision

dated

June

2,

. 1987,

and

drawings

5610-T-E4536,

sheets

1 and

2 revision

11.

Conditions that were noted

and brought to the attention of licensee

include:

13

A EDG

A minor fuel oil leak at the skid tank drain valve 041A connection.

The leak

has existed

since th A EDG overhaul

and skid tank cleaning

performed during the

1987 Unit 3 refueling outage.

A drip pan

is

placed

under

the

connection.

Approximately

one to two gallons of

fuel oil appears

to have collected.

Plant Work Order

(PWO) ¹316006,

dated October 23,

1987,

was issued.

This is considered

a rework

PWO,

in that the connection

had

been

previously

tightened

to stop'he

leakage.

PWO ¹307541,

no

date,

remained

hung

for day

tank to skid tank

solenoid

valve

SV-3522.

This

PWO was

worked

and the condition

was

repaired

on August 19,

1987.

The

PWO has

since

been

removed.

B

EDG

Instrument

Air

valve

CV-4-2046

had

a

slight

packing

leak.

PWO ¹316005,

dated October

23,

1987,

was issued.

A slight fuel oil leak,

between

the

fuel

metering

valve

and the

return

to

the

skid tank.

PWO ¹WA871421325,

dated April 22,

1987,

identified the leak.

Red

and

orange

marks

(as described

by

an information tag) to aid

operators

in identifying kilowatt (KW) limits were missing from the

local

KW meter.

Common

The

pressure

gauges

on

the air receivers

for both

EDGs

are

non

qualified.

The

gauges

on the

D receivers

(PI 3668A and 36688) were

removed

and replaced

by plugs via TSA 3-87-23-8-2,

dated

February

12,

1987.

The

gauges

on

the

A receivers

(PI 3667A

and

3667B)

are

controlled closed,

except

to take

log readings,

by clearance

order

0-87-2-15,

dated

February

12,

1987.

The

inspectors

observed

the

valves to be closed

as required.

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.

On April 10,

1987,

the

Commission

issued

Amendment

117 to the Facility Operating

Licence

No.

DPR-41 for 'the Turkey

Point Plant,

Unit 4.

The

amendment

adds

License

Condition 3.J

regarding

implementation of the

IAEA Safeguards

program for Unit 4.

14

The

NRC 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

operable.

Seal

wires are

placed

by

IAEA inspectors

on the

containment

, equipment

access

hatch

and the reactor

vessel

head

seismic restraints, if

accessible.

Only the

seal

wires

on the

equipment

hatch can'e

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

SFP

area

is always

accessible

through

locked

and alarmed doors.

The

GAEA is scheduled

to perform

a fuel inventory in the Unit 4

SFP

on

November 22,

1987.

12.

Plant Events

(93702)

The following plant events

were reviewed to determine facility status

and

the

need for further followup

actions

'lant

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.

On

September

30,

1987, with'nit.-3 in Mode 5, Unit 3

PRMS channels R-ll,

R17A and

B and

R-19 and Unit 4

PRMS channel

178 alarmed

causing

a Unit 3

containment

and control

room ventilation isolation.

The

PRMS

channels

alarmed

when mechanical

maintenance

was transporting

an unshielded highly

contaminated

reactor

coolant

pump

seal

injection filter through

the

auxiliary building.

This event is discussed

further in paragraph

8,

On October

12,

1987,

a hurricane warning was issued for Dade County.

The

licensee

declared

an

unusual

event

and

made

the required notifications.

Unit 4

commenced

a

normal

shutdown

from 100:o'ower.

Hurricane

Floyd

passed

by Turkey Point at approximately 8:00 p.

m.

The highest sustained

wind speeds

were

less

than

40

MPH and the highest

wind gusts'ere

less

than

60 MPH.

No injuries or damages

were reported.

On October

12,

1987, with Unit 4 in Mode 3,

an automatic

containment

and

control

room ventilation isolation

occurred.

PRMS Channel

R-11

spiked

high initiating the

actuation.

The

cause

of the

event

was

that

the

sampling

paper

had

reached

the

end of its

spool

causing

one

section of

paper

to

be held stationary

at the

sample point, allowing particulate to

accumulate.

When

the

sampling

paper

was

rewound

R-11

detected

the

15

. accumulation

of particles

and

alarmed.

The containment

atmosphere

was

sampled

and

an

RCS leakage

rate calculation

was performed.

On October

15,

1987 the licensee

made

a significant event notification as

a result of operating

the

common waste

gas

system

in a configuration not

analysed

in the

FSAR.

This event is discussed

further in paragraph

9.