ML17345A289
| ML17345A289 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 06/29/1988 |
| From: | Brewer D, Crlenjak R, Mcelhinney T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17345A288 | List: |
| References | |
| 50-250-88-11, 50-251-88-11, NUDOCS 8807260336 | |
| Download: ML17345A289 (32) | |
See also: IR 05000250/1988011
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323
Report Nos.:
50-250/88-11
and 50-251/88-11
Licensee:
Florida Power and Light Company
9250 West Flagl er Street
Miami, FL
'33102
Docket Nos.:
50-250
and
50.-251
Facility Name:
Turkey Point
3 and
4
License
No s.:
and
DP R-41
0
Inspection
Conducted'.
April 25,
1988 through June
3,
1988
Inspectors:
D.
R. Brewer, Senior Resident
I
pector
T.
F. McElh'qney, Resident
Inspe tor
r
G.
A
chne li, Resident
Inspector
Approved by:
V.
C len
, Secti
n Chief
Division o
Reactor Projects
Date
igned
Date Signed
6
D te Signed
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, facility modifica-
tions, plant physical
security
and plant events.
0
Results:
One
violation
of
TS 6.8. 1
was
identified.
Failure
to follow
procedure,
in that Diesel
Fuels Oil Tank suction valve 003 was found
locked closed
when required to be locked open,
(50-250,251/88-11-02)
(paragraph
6).
One
Unresolved
Item
was
identified,
Evaluate
licensee's
method of testing
check valves to meet the requirements
of
ASME Boile~
and
Pressure
Vessel
Code,
Section
XI, (50-250,251/88-
11-01)
(paragraph
3).
One Inspector
Followup Item was identified,
Resolution of the differences
in documentation
associated
with the
Intake
Cooling
Water
assembly's
materials,
(50-250,251/88-
11-03) (paragraph
9).
SB072*0336 880707
ADOCK 05000250
6
PNU'
REPORT DETAILS
Persons
Contacted
Licensee
Employees
F
AJ
T
J
D
J
- R.
R.
"R.
S.
- J
AE
AG
~R.
J.
Dager,
Vice President
S.
Odom, Site Vice President
E. Cross,
Plant Manager-Nuclear
J.
Baker, Plant Manager-Nuclear
(Acting)
W. Pearce,
Operations
Superintendent
H. Southworth,
Technical
Department
Supervisor
W. Kappes,
Maintenance
Superintendent
A. Finn, Training Supervisor
D. Webb, Operations - Maintenance
Coordinator
Tomaszewski,
Instrument
and Control
(18C) Department
Supervisor
C. Strong,
Mechanical
Maintenance
Department
Supervisor
W. Bladow, Quality Assurance
(QA) Superintendent
J. Earl, Quality Control
(QC) Supervisor
A. Abrishami,
System
Performance
Supervisor
.G.
Mende, Operations
Supervisor
Arias, Regulation
and Compliance Supervisor
D. Hart, Licensing Engineer
Salamon,
Regulation
and Compliance
Engineer
Hale, Engineering Project Supervisor
Abbatiello,
QA Performance
Monitoring Supervisor
D. Evans,
Document Control Supervisor
A. Suarez,'echnical
Department
Engineer
M. Smith, Services
Manager-Nuclear
L. Fritchley, Assistant Training Supervisor
Other licensee
employees
contacted
included construction
craftsmen,
engineers,
technicians,
operators,
mechanics,
and electricians.
"Attended exit interview on June 8,
1988.
Note:
An alphabetical
tabulation of acronyms
used in this report is
listed in paragraph
12.
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
was
identified in this report;
"Evaluate
licensee's
method of testing
check
valves to meet
the requirements
of ASME Code,
Section
XI" (URI 250,251/
88-11-Ol)(paragraph
3) .
3.
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, testing
was performed in accordance
with adequate
procedures,
that test instrumen-
tation
was calibrated,
Limiting Conditions for Operation
( LCO) were met,
test results
met acceptance
criteria requirements
and
were
reviewed
by
personnel
other than
th'e "individual 'directing the test, deficiencies
were
identified,
as appropriate,
and were. properly
reviewed
and
resolved
by
management
and
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:
4-0SP-041.18
3-OSP-049.
1
O-OSP-023.1
O-OSP-022.5
3" PMI-071.1,
2,3,4
Pressure
Boundry Check Valves
Leak Test,
Reactor Protection
System
Logic Test,
"A" Diesel Generator Operability Test,
Emergency Diesel
Generators
Starting Air Valves
Operability Test,
and
Level Protection
Instrumentation
Channel Calibration.
On
May 25,
1988,
while operating
in mode 3, the licensee
declared Unit 4
Reactor
Coolant
System
(RCS)
pressure
boundary
isolation
check
valves
4-876
A,
B
and
C out of service
because
leakage
tests
performed
as
required
by
TS
3. 16 indicated
the potential for leakage 'greater
than 5.0
gallons
per
minute
(gpm).
On
two
occasions,
surveillance
procedure
4-OSP-041. 18,
entitled
Pressure
Boundary
Check
Valves
Leak Test,
revision dated
May 12,
1988,
had
been
unsuccessfully
implemented.
The
observed
discrepancy
included
an inability to establish
a differential
pressure
(dp) across
the check valve seating
surface.
This condition
was
thought to be indicative of a leaking valve.
The decision to declare
the
valves
out of service
was
made
by the Plant Supervisor-Nuclear
and
was
conservative.
After six hours;
a cooldown
was initiated in accordance
with TS 3. 16.4.
Since this shutdown
was required
by the
TS,
a Notice of
Unusual
Event was
made
as required
by 10 CFR 50.72(b)( 1)(i)(A).
Three explanations
existed for the
observed inability to establish
a
dp
across
the check valves.
- A check valve could
be
damaged,
could
be stuck
open or the valve design could require
a significant drop
in
upstream
pressure
to terminate
leakage
by firmly compressing
the
seating
surfaces.
The. licensee
staff
favored
the latter possibility
because
procedure
4-OSP-041. 18
had
previously
been
implemented
without
incident
but
had
recently
been
rewritten
to
use
a
slower
method
of
upstream
depressurization.
The initial
use
of the rewritten
procedure
failed to establish
a differential pressure.-
Consequently,
the procedure
twas
revised to utilize
a larger depressurization'rain
path.
However,
prior to
implementing
the
revised
procedure it was
noted
that
a
dp
developed
across
the valve,
apparently
without the
use
of
any depres-
surization
technique.
Leak tightness
checks
were successfully
completed
and
the unit was
returned
to
power
on
May 28,
1988.
The satisfactory
leakage
rates verified that
no check valve seat
was damaged.
The licensee
did not 'evaluate
how the 'check valves
became firmly seated.
Consequently,
the
NRC inspectors
questioned
whether
the observed
phenomenon
was due to
valve design
or valve binding.
On June
7,
1988,
valve vendor
represen-
tatives
confirmed
that
seat
dp
design
could
have
precluded
initial
attempts to establish
dp across
the valves.
On that date,
the
power level
of the
reactor
precluded
additional
testing
to determine
whether valve
binding
had existed.
Clearly,
any binding that
may
have
occurred
must
have
been
minor because
the valves
were
observed
to seat without overt
operator
action.
Nevertheless,
the
inspectors
conducted
a
review of
previous
check valve stroke tests
to verify that valve binding was not
a
significant concern.
4-876 A,
B and
C are required to be tested
in accordance
with
the American Society of Mechanical
Engineers
(ASME) Boiler and
Pressure
Vessel
Code,
Section XI, Division 1, Subsection
IWV, 1980, Edition through
Winter
1981 Addenda;
IWV-3520, Tests for Check Valves.
The code requires
that
be exercised
at least
every
three
months,
except
as
provided
by IWV-3522, Exercising Procedure.
IWV-3522 specifies,
in part,
that:
shall
be exercised
to the position required to fulfill
their function unless
such operation
is not practical
during plant
operation.
If only limited operation
is practical,
during plant
operation
the check valve shall
be part-stroke
exercised
during plant
operation
and full-stroke exercised
during cold
shutdown.
Valves
that cannot bemxercised
during plant operation
shall
be specifically
identified by the
Owner
and shall
be full-stroke exercised
during
cold shutdowns,
Full-stroke exerci sing during cold shutdowns
for all
valves not full-stroke exercised
during plant operation
shall
be
on
a
frequency
determined
by the intervals
between
shutdowns
as follows:
for intervals
of three
months
or
longer,
exercise
during
each
shutdown;
for -intervals
of
less
than
three
months,
full-stroke
exercise
is not required
unless
three
months
have
passed
since
the
last
shutdown axercise.
Additionally, for normally closed
such
as 4-876 A,
B and
C,
IWY-3522 specifies,
in part, that:
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
away
from the
seat
when
the closing pressure
di-fferential'is
removed
and flow through
the valve is. initiated, or when
a mechanical
opening force is applied
to the disk.
Confirmation that the disk moves
away
from the
seat
shall
be by visual observation,
by electrical
signal initiated by
a
position indicating device,
by observation of substantially
free flow
through the valve
as indicated
by appropriate
pressure
indications in
the
system,
or by other positive means.
This test:may
be
made with
or without flow through the va'lve.
4-876A,
B and
C are tested
in accordance
with Appendix
B of
Operating
Procedure
(OP)
0209. 1, entitled
Valve Exercising
Procedure,
revision dated
Nay 19,
1988.
An Inservice
Test
(IST) relief request
has
been filed with the
Commission,
in accordance
with
to
require valve testing during cold
shutdown
conditions
rather
than during
normal
operations
The valves
can
not
be tested
during
normal
operation
because
the
Residual
Heat
Removal
(RHR)
pumps
do not develop sufficient
discharge
head
to establish
a flow path
through
the valves at elevated
primary pressure.
The test
procedure
directs
the full flow from two
RHR pumps through the
check
valves.
Valve
4-876A is isolated
from 4-876B
and
C
such that
approximately
5000
gpm pass
through
the valve.
The piping configuration
is
such that valves
4-876B
and
C can
not
be isolated
from each
other.
Consequently,
valves
4-876B
and
C
are
tested
simultaneously
and
about
5000
gpm is
assumed
to
pass
through
the
two
valves.
However,
the
licensee's
procedure
does
not verify how the total
flow is split.
Since
all
5000
gpm
passes
easily
through
a single valve,
the test
does
not
demonstrate
that
both
valves
4-876B
and
C
are
unobstructed.
This
deficiency
appears
to violate
code
requirements
in that
valves
4-876B
and
C can
not
be determined
to have
been full-stroke tested
during the
performance
of Appendix
B of
OP
0209. 1.
There is
no confirmation that
both .check valve disks
move promptly
away
from their
seats
when flow is
initiated.
A brief review of plant procedures
and piping confagurations
has
revealed
that this deficiency applies
to Units 3 and
4. It appears
that
check
valves
3/4-8760
and
E,
located
in the alternate
low head
injection line,
may be susceptible
to the
same lack of definitive testing.
Also check valves 3/4-874A and B, located in the hot leg injection lines,
are incompletely tested
based
on existing procedures.
The licensee
has
not previously
sought
a relief request relative to this
testing
problem.
Consequently, it appears
that the Section
XI- code test
requirements
have
not
been
adequately
implemented.
The
licensee
is
evaluating
the effect of these
discrepancies
on
the
operating
units.
Preliminary
evaluations,
performed
by
the
Mestinghouse
Corporation,
indicate that the licensee's
test
methods
for valves
876A,
B and
C are
sufficient to
guarantee
that
adequate
flow will reach
the
core
for
accident
mitigation
purposes.
However,
the
number
and location of all
valves
which
are
not definitively full-stroke
tested
have
not
been
determined.
Consequently,
this issue will be identified as
URI 250,251/
88-11-01,
pending additional
licensee
research
and
NRC followup evalua-
tion.
No violations or deviations
were identified in the areas
inspected.
4.
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:
LCOs
were
met while
components
or
systems
were
removed
from service;
approvals
were obtained prior to initiating work; activities
were
accom-
plished
using
approved
procedures
and
were
inspected
as
applicable;
procedures
used
were
adequate
to control
the activity; troubleshooting
activities
were controlled
and repair records
accurately
reflected
the
maintenance
performed;
functional
testing
and/or
calibrations 'ere
performed prior to returning
components
or systems
to service;
gC records
were maintained; activities
were accomplished
by qualified personnel;
that
parts
and materials
used
were
proper ly certified; radiological
controls
were
properly'mplemented;
that
gC
hold
points
were
established
and
observed
where
required;
fire prevention
controls
were
implemented;
outside contractor force activities were controlled in accordance
with the
approved
gA program;
and housekeeping
was actively pursued.
The
inspectors
witnessed/reviewed
portions of the following maintenance
activities in progress:
Installation of the Amertap
System for Unit 4 Intake Cooling Mater/
Component Cooling Water
( ICW/CCW) Heat Exchangers,
Repair/Modification of Unit 4 Containment
Purge Valves,
Repairs to
ICW Pump
Troubleshooting
MOV-4-750 Failure to Open,
Troubleshooting
MOV-4-865 Failure to Operate,
and
Troubleshooting Unit 3 R-11 Spurious Isolation Signals,
and
Containment
Purge Valve Stroke Testing.
On
May 9,
1988, with Unit 4 in Mode 5,
the outboard
containment
purge
exhaust
valve (POV-2602)
was stroke tested
in accordance
with
OP 0209. 1,
entitled
Valve Exercising
Procedure.
Appendix
B of this procedure lists
the valves that are tested during cooldown and/or cold shutdown.
POV-2602
stroke test requires that the valve be verified to close within 5 seconds.
4
The stroke
time recorded
on
May 9,
1988,
was
6.93
seconds.
Plant
Mork
Request
MA880509195444
was -issued
and
troubleshooting
Has
commenced.
Troubleshooting
included lubricating the actuator
shaft
and valve
stem,
and rebuilding the actuator.
The post maintenance
stroke times were also
unsatisfactory.
On
May 13,
1988,
the licensee
formed
an
Event
Response
Team
(ERT
no.88-008)
to investigate
the
problem.
Based
on, the data
obtained through research
and analysis,
the
ERT was able to formulate root
causes.
The primary root 'cause -identifi'ed'as 'that there
was insufficient
capacity to vent the POV-4-2602 actuator.
Contributing to this condition
was
the
implementation
of Plant
Change/Modifications
(PC/M)
to
the
actuator
and instrument air lines over the past eight years.
These
changes
are listed below:
PC/M 79-129,
dated
January
28,
1980,
added air regulators
to
limit valve opening to 50 degrees.
PC/M 81-07, dated
March 4,
1982,
removed the air regulators
and
added
mechanical
hardstops
to further limit supply valves to 33
degrees
and the exhaust
valves to 30 degrees
open.
PC/M 87-406,
dated
December
21,
1987,
changed
on
POV-4-2690
and POV-4-2602 which involved a change
from 1/2 inch
. carbon
steel
piping to
1/2
inch thick-walled tubing for the
instrument air lines.
This reduced
the internal diameter of the
exhaust line.
The altered
stroke of the actuator
and the unregulated
supply of instru-
ment air contributed to the slower closing times.
A -review of the Unit 3
and
4 containment
purge exhaust
valves closure
time history revealed
the
following:
Valve
Avera
e Closure
Time
POV-3"2602
POV-3-2603
POV-4"2602
POV"4"2603
4.58
seconds
3.46
seconds
4.40
seconds
4.54
seconds
In order to decrease
the stroke
times
on the Unit 4 exhaust
valves,
the
licensee
implemented
PC/M 88-158.
The
PC/M increased
the
size
of the
tubing
from 1/2 inch to
1 inch
on the vent side of the solenoid valves.
The 1/2 inch check valves in the air line were replaced with
1 inch check
valves.
Also the existing needle
valves in the instrument air system were
relocated
upstream of the solenoid valves to limit valve
opening
rate to
no greater
than
3 inches
per
second.
The solenoid valve tubing arrange-
ment,
was
changed
to allow simultaneous
venting of the
The licensee
had
noted
a concern with the previous series
arrangement.
A failure
of
the
upstream
solenoid
could
prevent
the
downstream
solenoid
from venting properly,
thus. preve'nting
the
purge
exhaust
valve
from closing. " The-'new parallel
'-venting
path
allows
the
purge
valve to
be closed
in less
than
5 seconds
with the failure of one
solenoid.
During the
ERT investigation,
a concern
was rai sed with the
method =of testing
the
purge
valves.
The licensee
discovered
that the
stroke times varied depending
on
how long the operator
kept the valve open
prior to initiating closure.
The licensee 'test results,
on
POV-4-2602,
were as follows:
Wait Duration
Closure
Time
2 second
15 second
20 second
5 minute
>5 minute
3.32
seconds
4.89
seconds
5. 10 seconds
5. 15 seconds
5. 16 seconds
. The licensee
determined that there
was
a high probability that the valves
could exceed their maximum closure
times due to the inconsistencies
in the
test
method.
Therefore,
on
May 16,
1988,
the Unit 3 containment
purge
valves
were
de-energized
and
declared
out of service.
The
licensee
determined that the test results for all air operated
valves
may have
been
affected
by time sensitive test methods.
All Unit 4 containment integrity
valves
were
subsequently
tested
satisfactorily utilizing a three
minute
pre-test
condition wait period.
The three
minute period
was conserva-
tively established
by the licensee
based
on test
data
collected.
The
Unit 3 containment integrity valves'losure
time histories
were reviewed
to verify there
were
no valves close to their maximum stroke time.
There
was
evidence
of
slow closure
time for
CV-3-519A (Primary
. Water
to
Pressurizer
Relief
Tank
and
Reactor
Coolant
Pumps),
therefore,
the
licensee
stroke
tested this valve waiting three
minutes
in the pre-test
position.
This test
was satisfactory.
The remaining Unit
3 valves
were
not tested
as
the unit is at
100xo power.
In order to ensure full air
pressure
is applied
to the actuator
prior to stroking
in the
closed
position,
the licensee
made
a revi sion to
OP 0209. 1 to have the operator
wait three minutes before closing any air operated
valve.
No violations or deviations
were identified in the areas
inspected.
5.
Engineered
Safety Features
Walkdown (71710)
The inspectors
performed
an inspection
designed
to verify the operability
of the Unit 3 and
4 Emergency
Diesel Generators.
This was accomplished
by
performing
a complete
walkdown of all accessible
equipment.
The following
criteria were used,
as appropriate,
during this inspection:
b.
System
lineup procedures
match plant drawings
and
as built configu-
ration.
Housekeeping
was
adequate
and appropriate
levels of cleanliness
are
being maintained.
8
c.
Valves in the
system
are correctly installed
and do not exhibit signs
~
of gross
packing leakage,
bent
stems,
missing
handwheels
or improper
labeling.
d.
Hangers
and supports
are
made
up properly and aligned correctly.
e.
Valves in the flow paths
are in correct position
as required
by the
applicable
procedures
with power
avai lable,
and valves
were locked/
lock wired as required.
f.
Local
and
remote position indications were compared
and remote instru-
mentation
was functional.
g.
Major system
components
are properly labeled.
The inspectors
reviewed
the following documents
during the course of the
inspection:
O-OP-023,
Emergency
Diesel
Generator
Operating
Procedure;
Operating
Diagram for Diesel
Generators
"A" and "B", S610-T-E-4S36,
sheets
1
and
2
t
No violations or deviations
were identified within the areas
inspected.
6.
Operational
Safety Verification (71707)
The inspectors
observed
control
room operations,
reviewed applicable
logs,
conducted
discussions
with control
room operators,
observed shift turn-
overs
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,
veri Red compliance with TS
LCOs
and verified the return
to service of affected
components.
Plant
housekeeping/cleanliness
conditions
and
implementation
of radio-
logical controls were observed.
Tours of the intake structure
and diesel, auxiliary, control
and turbine
buildings
were
conducted
to observe
plant
equipment conditions including
potential fire hazards,
fluid leaks
and excessive
vibrations.
The
inspectors
walked
down accessible
portions of the following safety
related
systems
to verify operability
and proper valve/switch alignment:
A and
B Emergency
Diesel Generators
Control
Room Vertical Panels
and Safeguards
Racks
Intake Cooling Mater Structure
4160 Volt Buses
and
480 Volt Load and Motor Control Centers
Unit 3 and
Platforms
Unit 3 and
4 Condensate
Storage
Tank'Area
Area
Unit 3 and
4 Main Steam Platforms
Control of Technical Specification
Books
On
May 1,
1988,
the" plant 'staff
made
a partial distribution of
TS
amendment
number 130/124.
The
TS change
increased
the
amount of time
a
Component
Cooling Mater
(CCW) heat
exchanger
could remain
out of
service
The
Amendment
was
sent
to
only
about
half
of
the
individuals maintaining controlled copies of the
TS books.
Normally,
the
change
wouTd
have
been
simultaneously
issued
to all holders of
controlled
TS.
A partial
site distribution
was
made
to expedite
incorporation
of the
new requirements.
The site distribution
was
to
be
promptly followed by
a
corporate
office initiated complete
distribution.
The partial distribution
included
essential
watch-
station
personnel
such
as Control
Room Operators,
Nuclear Operators,
Turbine
Operators
and
the Shift Technical
Advisor.
Some
support
groups,
such
as the Technical
and guality Assurance
Departments,
were
not issued
the Amendment.
Partial
distribution
of the
Amendment
created
the potential
for
confusion
in that
not all
controlled
TS contained
identical
system requirements.
This concern
was discussed
with senior licensee
Supervisors
who specified that the distribution of TS changes
would
always
be complete for future Amendments.
Change
130/124
was
issued
to all holders of controlled
TS on
May 6,
1988.
On
May 5,
1988,
during
a page verification of selected
TS books, it
was
determined
that controlled
copy
number
17,
assigned
to
the
Nuclear Operator's
workstation,
was not up to date.
Several
changes
had been
added to the book without subsequent
removal
of the
super-
seded
pages.
Some of the
superseded
pages
were quite old.
Addi-
tionally,
many sections
were
not in numerical
order
and
some
pages
were missing
from the book.
These
discrepancies
were
brought
to
the attention
of the
Plant
Supervisor-Nuclear
and corrective
action
was initiated.
The Opera-
tions
Department
maintains
four additional
controlled
copies of the
TS.
These
were audited
by the licensee
and additional
discrepancies
were identified and corrected.
However,
even
though all Operations
Department
TS books
had discrepancies,
no audit
was initiated for
'ooks
held by other Departments.
In early
June,
NRC inspectors
audited
two additional
controlled
copies
of TS.
No discrepancies
were identified
in the
book held
by the
IKC Department.
Numerous
discrepancies,
similar
to
those
mentioned
above,
were identified in controlled
copy
number
57,
held
by the Mechanical
Maintenance
Department.
10
The
need for
a comprehensive
assessment
of the status of controlled
books,
such
as the
TS and the
Updated
Final Safety'nalysis
Report,
was discussed
at the exit meeting.
The licensee
committed to develop
a program to ensure
that controlled copies
of important plant books
are
periodically verified against
the current list of effective
pages.
b.
Diesel
Fuel Oil System Misalignment '
On
May 31,
1988,
during the
performance
of
OP 4304.4,
Diesel
Oil
Transfer
System
Periodic
Test
of
Pumps,
test
personnel
noted
inadequate
discharge
pressure
on "A" diesel
fue1 oil transfer
pump.
An operator
checked
the valve line-up for this test
and
$ound the
main diesel oil suction valve,70-003,
locked closed.
This valve is
normally locked
open.
The operator
immediately notified the control
room and the valve was repositioned
and locked in the
open position.
The licensee
then
made'a
significant event notification per
This event is further discussed
in
paragraph
9.
The following chronology
documents
those
occasions
when plant
personnel'recently
performed tests
and alignments
of the
fuel oil
system.
05/22/88
1715
0-ADM-205 (Administrative Control of Valves,
Locks,
and
Switches)
completed,
valve
70-003
verified locked open.
05/24/88
0106
0-0SP-023.6
(Diesel Generator
System
Flowpath
Verification)
completed
satisfactorily,
valve
70-003 verified locked open.
05/24/88
0308
05/28/88
0308
0-OSP-023.
1 (Diesel Generator Operability Test)
completed satisfactorily
on "A" EDG.
O-OSP-022.6
(Diesel
Fuel Oil Storage
Tank
Accumulated
Water
Removal)
completed
satis-
factorilyy.
05/29/88
1700
NC-103 (Diesel
Fuel Oil Inventory, Receiving
Shipments
and
Periodic
Sampling)
Step
8.3.4
(Main Diesel
Storage
T'ank) sampling completed.
05/31/88
1445
.
Valve 70-003 discovered
locked closed.
Discussions
were conducted with the individuals performing the above
evolutions
and it was determined
that the valve
was
locked closed
upon completion of the the diesel oil periodic
sampling
on
May 29,
1988,
at
1700.
A chemistry'echnician
stated
that
prior
to
performing
the
sampling
of the diesel
fuel oil storage
tank,
he
11
reviewed Nuclear Chemistry procedure
NC-103 and found it difficult to
understand.
He then'equested
another technician'o* help him sample
the tank.
During the sampling evolution,
a copy of the procedure
was
not taken
to the
sample
location.
The
sampling
procedure,
section
8.3 '
of NC-103, directs that the
sample valve 70-004
be unlocked
and
opened
to obtain
the
required
sample,
then to close
and lock the
sample
valve.
These
steps
were
accomplished
by
the
technician
requested 'to help in the evolution.
The other" technician
thought
he
also
needed
to
open
the
main
suction
valve
(70-003)
to obtain
a
sample.
The valve is clearly labeled
as
a locked
open
valve.
He
unlocked
and thought
he opened
the
70-003
valve
and
upon completion
of sampling, fully closed
and locked the valve.
Positioning of valve
70-003 is not required or addressed
by NC-103.
Due to the fact that
the technician
thought
he initially needed
to open
valve
70-003 to
obtain his
sample
and that
he obtained valve movement
when attempting
to open the valve,
the Chemistry
and Operations
Supervisors
conducted
further interviews with the
individual.
His recollection
of the
event
was that
he
was
unable
to recall
the initial valve position
either by stem position or the
number of turns
taken
to operate
the
valve.
He indicated that
some degree of motion in the
open direction
was obtained,
maybe 3-5 turns.
However,
he was not sure.
The valve,
when properly positioned
should
be off the backseat with some motion
in the
open direction available,
about
1/2 to
1-1/2 turns.
Full
closure of this valve requires
about
14 full turns
on the handwheel.
Based
on the discussion
above,
the licensee
concluded that the 70-003
valve
was already
open
when the technician
thought
he opened it and
that the initial movement of the valve
he obtained
was
due to the
number of turns the valve was off the back seat.
The configuration of the Diesel
Fuel Oil Supply System at the site is
as follows:
Each diesel
engine
has its own 4000 gallon day tank separated
by
a concrete
wall from the tank of the other
engine.
Each
tank
gravity feeds
through
a solenoid valve to its associated
diesel
generator
skid mounted
(275 gallon) fuel tank.
is provided with
a
manual
bypass
valve
and associated
piping.
This
arrangement
provides alternative capability to fill each
skid tank should
the
solenoid
close
due to loss
of power or
valve malfunction.
The two da'y tanks are'upplied
by one
common
storage
tank having
a capacity of 64,000 gallons.
This tank has
sufficient storage
capacity
to permit
one diesel
generator
set
to operate
at the
"168 Hour Rating" for 7 or more
days.
An
alternate fill connection
to
each
Diesel
Oil Day Tank suitable
for tie-in from a mobile tank unit is provided.
Alternate fill
lines provide
an alternate fill path
should
the
normal
supply
via the Diesel Oil Transfer
Pumps
become
unavailable.
Transfer
12
of fuel oil from the storage
tank to the day tanks to maintain
level is accompli-shed-automatically
by one'of two electric motor
driven
transfer
pumps.
The
70-003
valve
i s
in the
common
suction line from the
common storage
tank to the
two day tanks
via their
respective
transfer.
pumps.
As
noted,
there
are
alternate
means to provide
a supply of fuel oil to the diesels.
The consequences
of having the
70-'003 valve shut would be that
when
the
day tank level
dropped
and automatically
started
the
respective
transfer
pump
to refill the
day
tank
from
the
storage
tank,
no transfer of fuel oil would take
place,
as
the
suction valve was shut.
The licensee
estimated
that the diesels
would run about 8-10 hours with only the 4000 gallon day tank as
a supply.
Identification of the
lowering day tank level would
be possible after the receipt of a low level alarm.
Thus, there
would have
been
time to determine
the problem and correct it or
provide another
means
to supply fuel to the engine.
However,
this
would require
operator
action rather
than
the automatic
initiation
as
designed.
The
licensee
is
evaluating if the
diesel oil transfer
pumps would have
been
damaged
while running
with the suction
val.ve closed.
Nuclear
Chemistry
Procedure
NC-103, entitled
Diesel
Fuel
Oil
Inventory,
Receiving
Shipments
and Periodic
Sampling,
revision
dated April 14,
1988, directs in section 8.3:4, that only 70-004
valve be operated
to obtain
a sample.
Contrary
to
the
above,
on
May 29,
1988,
valve
70-003
was
closed
during the
performance
of this procedure.
The failure
to follow procedure
NC-103 is
a violation (250,251/88-11-02).
7.
Medical
Emergency Drill
The
licensee
conducted
a
medical
emergency drill on
May
24,
1988,
to
demonstrate
the
effectiveness
of
recently
implemented
training
and
equipment
enhancements
identified as
weaknesses
during the
NRC Emergency
Response
Facilities
Appraisal,
February
22-25,
1988,
(IR 50-250,251/
88-01).
The drill simulated
a
contaminated
injured
man in the Radiation
Waste
Building.
Upon discovery',
the
proper notifications
were
made
and
the
victim was attended to.
Communications
between
responsible
personnel
were
good,
as were contamination controls to prevent
the
spread
of contamina-
tion outside
established
boundaries.
The victim's injuries were-promptly
assessed
and treated.
No deficiencies
requiring
long-term
corrective
actions
were identified.
Minor deficiencies
identified
were
discussed
with drill participants
and resolved at
a critique following the drill.
8.
Physical
Secur ity
(71881)
Station security activities were
observed
during this inspection
period
to. ascertain
that
they
were
conducted
in compliance with the
approved
Physical
Security Plan
(PSP).
13
The fol lowing attr ibutes
were
considered
during
these
observation,
as
appropriate: 'he'inimum
number af
armed -guards
is
on 'site for each
shift;
search
equipment
such
as
x-ray
machines,
metal
detectors
and
explosives
detectors
are
operational;
the
Protected
Area
(PA)
bar rier
is well maintained
and is not compromised
by erosion,
opening in the fence
or walls, or proximity of vehicles
or other objects that could
be
used
to scale
the barrier; illumination in the
PA is adequate
to allow patrol-
ling guards
to observe
th'e
area 'at night and permit the
use of closed
circuit monitors
by alarm station operators;
the vital area
(VA) barriers
are
well maintained;
persons
granted
access
to the site
are
badged
to
indicate whether
they
have
unescorted
or escorted
access
authorization;
there
are
no obstructions
in the isolation
zone that could conceal
an
individual attempting
an unauthorized
entry or interfere with the detec-
tion/assessment
system;
and
when
search
equipment
or alarm
systems
are
or when there is
a breach of the
PA or
VA barrier,
the licen-
see
implements appropriate
compensatory
measures.
No violations or deviations
were identified within the areas
inspected.
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
r elative
to the
need for additional
NRC response
to the event.
Additionally, the
following issues.
were
examined,
as
appropriate:
details'egarding
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 Apri 1 27,
1988,
at
0927,
with Unit 3 at
100% power,
the
3A Intake
Cooling Water
( ICW) pump was stopped
and declared
out of service
(OOS) due
to
a discharge
pressure
piping failure.
The
3A
ICW pump receives
its emergency
power
from the
A Emergency
Diesel Generator
(EDG) and the
3B
and
3C
ICW pumps receive their emergency
power from the
B
EDG, which was
for scheduled
preventive
maintenance.
When
the
3A
ICW
pump
was
declared
OOS, the
3B and
3C
ICW pumps
became technically
OOS in accordance
with TS 3.0.5,
even though they continued to operate.
With more than
one
ICW pump
OOS, the unit entered
TS 3.0. 1.
At 1045
on April 27,
1988,
the
B
EOG was returned
to service
thus
the
3B and
3C
ICW pumps
also
became
The unit then exited
TS 3.0. 1,
and entered
TS 3.4.5.b.2,
which
permits
one
ICW pump to
be
OOS for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The pressure
gauge piping
was repaired
and the
3A
ICW
pump
was
returned
to service
at
1209
on
April 27,
1988.
The unit exited
TS 3.4.b.2
at that time.
The
cause of
14
the
failure
of
the
3A
ICW
pump
discharge
pressure
piping
was
corrosion of the coupling which attaches
the pressure
piping to the
ICM discharge
pipe.
The corrosion
was
due to
a leak
and
the
use of
a
steel
instead
of
a stainless
steel
The initial inspec-
tion into the reason
carbon steel fittings existed in
a
sea
water
system
indicated that the fittings in question
should
have
been
constructed
of
stainless
steel.
This is identified in the licensee's
original specifi-
cations,
5610-M-50,
a'nd
the
current
specifications,
5177-PS-ll,
for
fittings in the
Intake
Cooling
Mater
System.
However,
the
licensee
recently provided the inspector
a copy of NCR 86-112,
dated
March 5,
1986,
requesting
information on the proper valve, fitting, and piping arrange-
ment for the discharge
pressure
on the
ICW pumps.
Attachment
D to
the
NCR includes
a diagram of the subject
assembly
and allows for
the
use of carbon
steel fittings in certain applications for these
assemblies.
Based
on
the differences
in the
documentation
associated
with the
assemblies,
this item will be addressed
in the next report
after further information
has
been
obtained.
This is identified
as IFI
50-250,251/88-11-03.
On April 28,
1988, Unit 4 was shut
down due to
a noted increase
in
RCS leak
rate.
The increased
leak rate
was identified as
coming from pressurizer
spray valve
455B
and
was approximately
3. 15 gallons
per minute.
The
TS
limit is
10 gallons per minute.
Subsequent
investigation
revealed that the
bellows internal
to the valve
had failed and was replaced.
The unit was
returned to power on May 28,
1988,
upon completion of various maintenance
items.
On
May 6,
1988, at 0225,
the licensee
declared
an Unusual
Event due to a
security
guard reportedly
being
shot at while
on routine patrol
in the
owner controlled
area.
The
FBI and Metro-Dade
Police
were called in to
assist
with the
investigation
and
the
licensee
terminated
the
Unusual
Event at 1047 that
same day.
The security guard later recanted
his story
that
he
was
shot at by one of three
intruders
in the
owner controlled
area.
He stated that
upon being confronted
by the individuals,
he shot at
their feet to scare
them away.
He then
shot at his
own truck and in the
trees
and fabricated
a story.
He was fearful of losing his job because
he
didn't follow company
procedures
relative to the
use of his weapon.
The
security guard
has
subsequently
resigned
from duty.
No
LER is required to
document this event.
On
May 13,
1988,
the licensee
made'
notification of a significant event
to the
NRC.
During the
design
basis
reconstitution
review of the
System,
the
licensee
identified
a
situation
where
insufficient
Net
Positive
Suction
Head
(NPSH) for the
RHR,
CS and
HHSI pumps could occur.
Valve 3/4-887
was being maintained
in the 30o'ocked
open position.
This
valve provides
a flowpath from the
RHR pump discharge. to the
CS and
pumps during the
post-LOCA recirculation
from the containment
sump.
Plant
engineering
department
determined that insufficient
NPSH would not result
if valve 3/4-887
was being maintained
open
such that the flow through the
valve would be equal to or greater
than
3750
gpm.
The licensee
indicated
that this valve was being maintained
30% since pre-operational
testing but
15
could not obtajn
a positive correlation
between
the valve position
as
a
result of the pre-operational
testing
and the previous
30io valve posi tion.
The valve was locked to 100 percent
open
upon identification of this concern.
Further
investigation
by
the
licensee
revealed
that insufficient
would not result with the valve 30:.'pen.
On
May 25,
1988,
the licensee
made
a notification of a significant event
to the
NRC.
With Unit 4 in Mode 3, 'testing 'of pressure
boundary isolation
valves
4-876 A, B, and
C indicated
a possible
leakage
problem.
The plant
entered
an
LCO in accordance
with TS 3. 16 and
commenced
a unit cooldown at
0915.
The valves were subsequently
retested
and declared
back in service
at 2330
on May 25,
1988. This item is discussed
further in paragraph
3.
On May 28,
1988, during routine verification of the Unit 3
PRMS R-11 high
level trip setpoint,
actuation
of the relay for containment
and control
room ventilation isolation occurred.
The actuation
was generated
when the
"High Level
Setpoint"
pushbutton
was
depressed
to verify the setpoint.
The instrument
drawer
was declared
out of service
and
a work order
was
generated
to 'troubleshoot
the
problem.
The
failure
could
not
be
duplicated
during troubleshooting
in the
shop
by
I&C technicians.
The
drawer
was returned for "indication only" at the request
of operations
department,
on
May 29,
1988,
in order
to monitor containment activity
levels
due to
a
suspected
Pump
(RCP) seal
problem
on
3A.
On
May 30,
1988,
the
drawer
caused
the
same isolation
signal
when
depressing
the
pushbutton
to verify the setpoint.
The drawer
was
then
replaced
with
a
new
drawer
on
June
2,
1988.
The old
drawer will be
shipped to the vendor to determine
the cause of the spurious trip signals.
On May 31,
1988, during the performance
of OP 4304.4,
Diesel Oil transfer
System Periodic Test of Pumps,
test
personnel
noted
inadequate
discharge
pressure
on "A" diesel
fuel oil transfer
pump.
An operator
checked
the
valve line-up for this test
and found the main diesel .oil suction valve,70-003,
locked closed.
This valve is normally locked open.
The operator
immediately notified the control
room and
the valve
was repositioned
and
locked in the
open position.
The licensee
then
made
a significant event
notification
per
This
event
is further
discussed
in paragraph
6.
Onsite
Followup and In-Office Review 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
appro-
priate,
and generic applicability had
been considered.
Additionally, the
inspectors
verified that the licensee
had reviewed
each event, corrective
t
16
actions
were
implemented,
responsibility for corrective actions not fully
completed
was clearly assigned,
safety'uestions
had
been
evaluated
and
resolved,
and
violations
of regulations
or
TS
conditions
had
been
identified.
(Closed)
LER 251/87-23, entitled Process
Radiation Monitor Trends
High Due
to
Jammed
Paper
Drive Causing
Control
Room Ventilation
and
Containment
Vent Isolation.
The licensee
replaced
the paper
and readjusted
the paper
drive tension.
The paper drive units were subsequently
overhauled
and, at
present,
new drive units
are
on order from the vendor.
closed.
(Closed)
LER 250/87-03, entitled Reactor Trip During Load Reduction
Oue to
Low Pressurizer
Pressure.
The unit trip occurred
during
a rapid load
reduction that
was being
performed
due to
a turbine plant cooling water
leak in the main generator exciter
and the resultant
ground.
The trip was
caused
by an excessive
cooldown due to emergency boration during the load
reduction.
The licensee
implemented
a
new procedure
to provide instruc-
tions for
a rapid load reduction
(3/4-ONOP-100)
and included
a simulator
scenario
in the operator training program.
LER 250/87-03 is closed.
11.
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 June 8,
1988.
The areas
requiring management, attention
were
reviewed.
No proprietary
information
was
provided
to the
inspectors
during
the
reporting period.
Unresolved
Item 50-250,251/88-11-01,
Evaluate
licensee's
method of
testing
check
valves
to
meet
the requirements
of ASME Boiler and
Pressure
Vessel
Code,
Section XI.
Violation 50-250,251/88-11-02,
Failure to follow procedure,
in that
the diesel
fuel oil tank suction
valve
003
was
found locked closed
when required to be locked open.
Inspector
Followup
Item
50-250,251/88-11-03,
Resolution
of
the
differences
in documentation
associated
with th'e intake cooling water
assembly materials.
12.
Acronyms and Abbreviations
a.m.
ANSI
Administrative
ante meridiem
American National
Standards
Institute
Administrative Procedures
'
17
CFR
dp
ERT
gpm
I &C
IFI
LCO
LER
LIV
NRC
ONOP
OP
OTSC
PC/M
p.m.
PNSC
RCO
TS
American Society of Mechanical
Engineers
Component
Cooling Mater
Code of Federal
Regulations
Containment
Spray
Differential Pressure
Emergency
Diesel Generator
Emergency Notification System
Event Response
Team
Federal
Bureau of Investigation
Florida Power 5 Light
Final Safety Analysis Report
Gallons
Per Minut'e
High Head Safety Injection
Instrumentation
and Control
Intake Cooling Mater
Inspector
Followup Item
Inservice Test
Limiting Condition for Operation
Licensee
Event Report
Licensee Identified Violation
Loss of Coolant Accident
Moter Operated
Valve
Maintenance
Procedure
Non-conformance
Report
Net Positive Suction
Head
Nuclear Regulatory
Commission
Off Normal Operating
Procedure
Out of Service
Operating
Procedure
On The Spot Change
Protected
Area
Plant Change/Modification
post meridiem
Plant Nuclear Safety Committee
Plant Supervisor
Nuclear
Physical
Security Plan
Quality Assurance
Quality Control
Reactor Control Operator
Pump
Reactor
Coolant System
Residual
Heat
Removal
Senior Reactor
Operator
Technical Specification
Temporary
System Alternative
Unresolved
Item
Vital Area