ML17345A588
| ML17345A588 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 12/08/1988 |
| From: | Belisle G, Russell Gibbs, Jury K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17345A586 | List: |
| References | |
| 50-250-88-34, 50-251-88-34, NUDOCS 8812200167 | |
| Download: ML17345A588 (14) | |
See also: IR 05000250/1988034
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTAST., N.W.
ATLANTA,GEORGIA 30323
\\
Report
Nose I
50-250/88-34
and 50-251/88-34
Licensee:
" Florida Power and Light Company
9250 West Flagler Street
Miami,
FL
33102
Docket
Nose I
50-250
and 50-251
Facility Name:
Turkey Point
3 and
4
License
Nos e I
and
Inspection
Conducted:
October
31 - November 4,
1988
Inspector: ZM IC.
K. Jury, Reactor
I
pector
Inspector:
. Gibbs,
eactor
Inspector
/
Approved 8y:," /
>'t --~/
G. =A. Belisle, Chief
gual ity Programs
Secti on
Division of Reactor Safety
t
Soigne
r~Js se
Date Signed
Date Signed
'UMMARY
Scope:
Results:
This routine,
announced
inspection
was conducted
in the area of
modifications
and design control.
Within the areas
inspected
one violation and
one inspector follow-up
item were identified as follows:
Violation:
Failure
to follow procedure
for maintaining
identification of reactor plant components,
paragraph
3.
Inspector
Follow-up Item:
Inconsistent
practices
concerning
record retention for completed
design
packages,
paragraph
2.a.
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REPORT DETAILS
Persons
Contacted
Licensee
Employees
- E
- J
A.
- A.
- g
- M.
- F
D.
- J
- R.
S.
T.
- K.
- S
P.
- J
- E
- R.
- [
- F
E.
D.
F.
K.
Anderson,
Inservice Inspection
Engineer
Arias Jr., Site Regulatory
and Compliance Supervisor
Arredondo, Site Purchasing
Supervisor
Atkisson,
Juno Plant Nuclear, Site Nuclear Eng'ineer
Bladow, equality Assurance
Superintendent
Blew, Inservice Inspection Coordinator
Carr, Nondestructive
Examination Supervisor
Clark, Tagging Coordinator
Cross,'lant
Manager
Earl, guality Control Supervisor
Ferrell, Regulatory
and Compliance,
Corporate
Gilmore, Juno Plant Nuclear, Site Nuclear Engineer
Gross,
Regu')atory
and Compliance
Engineer
Hale, Engineering
Manager
Higgins, Juno Plant Nuclear, Site Project Engineer
Kappes,
Maintenance
Superintendent
Lyons, Regulatory
and Compliance
Engineer
Mende, Operations
Supervisor
Pearce,
Operations
Superintendent
Southworth, Technical
Supervisor
Suarez,
Configuration Control Supervisor
Tomaszewski,
18C Department
Head
Yarona,
Juno Plant Nuclear,
Lead Electrical/IRC Engineer
York, gA Records
Coordinator, Technical
Department
Other
licensee-
employees
contacted
during this
inspection
included
craftsmen,
engineers,
operators,
mechanics,
technicians,
and
administrative
personnel.
NRC Resident
Inspectors
- R. Butcher
G. Schnebli
- T. McElhinney
- Attended exit interview
Desi gn, Design
Changes,
and Modifications.
This inspection
was
conducted
in the area
o'f design control
and modifica-
tions.
This inspection consisted
of reviewing completed
design
packages,
reviewing
the
modification
engineering
backlog,
and
evaluating
the licensee's
efforts to prioritize and
reduce
the
number of items in
the backlog.
Specific areas
inspected
and conclusions
from the. inspection
are disussed
in the following paragraphs.
a
~
PCM 86-104 - AFWP "A" Impeller Replacement
This
design
change
addressed
replacing
the
"A"
AFWP impeller
assembly
with
a
spare
assembly.
The replacement
impeller
vanes
were underfiled
before installation to achieve
a
minimum of 4 or
5 percent
head, increase
in pump performance,
as the replaced
impeller
was not capable of meeting
design
head.
This modification had been
performed earlier
on
the
"C"
AFWP with increased
performance
to
design specifications.
The
10 CFR 50.59 safety evaluation,
implemen-
ting
PWOs,
vendor correspondence,
compatibility evaluation,
receipt
~ inspection
reports,
and appli'cable
post modification testing
data
were reviewed.
Technical
adequacy of the package
was evident;
however,
a problem
was identified concerning
package
completeness.
During
review of the microfilmed modification- package,
Procedure
O-PMM-075.6,
Pump Rotating
Element
Removal
and
Replacement,
which
was
the
procedure
which
implemented
the
work
performed,
Surveillance
Procedure
3-0SP-075.6,
Train I
Inservice Test,
and Special
Test 86-22,
Pump-
Performance
Test,
both of which implemented
post modification testing
requirements
for
PCM 86-104,
were not included in the package.
Upon
research
by the licensee
these
procedures
and test
were located i n
various plant record filing systems.
This in itself is not a problem;
however,
Turkey Point Units
3 and
4 TS, Section
6. 10,
Record Retention,
states
the records
and
drawing
changes
reflecting facility design
modification made to systems
and equipment shall
be retained for the
duration of the Facility Operating
License.
However,
records of
principa1 maintenance activities, inspections,
repair,
and rep'1acement
of principal activities, are only required to be kept for five years.
Since the implementing procedure,
special test,
and testing procedure
were
not included
as part of the
PCM,
and
were filed 'under their
respective
document
types,
they are only required to be retained for
five years,
whereas
they are lifetime records
as
required
by TS.
The
licensee
currently
keeps all records
with five year retention
'equirements
and
does
not discard
them
as
the
TS al'lows;
however,
the potential for destruction of these
records exists.
The inspector
requested
the licensee
to review
a
sample of
PCMs to determine if
this
example
of dis iointed
PCM records
exists
in other
packages.
Until
the
licensee
evaluates
this
issue,
this
descrepancy
is
identified as
IFI (IFI) 250, 251/88-34-02.
All records
identified
above
were
reviewed
and .found to adequately
document
PCM 86-104 implementation'and
testing.
No other deficiencies
were identified and the
PCM effectively increased
AFWP "A"'erformance
to design specifications.
Plant
Change
Modification
Modification to Component
Cooling Water System.
This
accomplished
modifying the original
CCW, system
piping
supports
on Unit 3 to improve system
performance
during
a -postulated
failure of the
RCP thermal barriers.
The change modified ten supports,
added six additional
supports,
removed three supports,
and performed
maintenance
on eight supports.
Additionally, Globe Valve 3-626A was
replaced
and evaluations
were
made of the containment
pipe support foundations,
and
RCP nozzles.
The supports
were classified
as
safety related,
seismic,
class
B
C of ASME Section XI.
The
inspector
reviewed the -following attributes of the
PCM:
t
(1)
The
10 CFR 50.59 Safety evaluation
was reviewed for technical
adequacy.'2)
The
process
sheet for the
and
Construction
Work Order
D1-2123
was reviewed for completeness
and applicable signatures.
(3) '
sample
of hanger
inspection
reports,
weld travelers,
traveler
weld material
requisitions -, hanger,YT
3 structural
integrity inspection
reports,
and construction
QC Deficiency
Reports,
were reviewed for completeness,
applicable
signatures,'nd
technical
adequacy.
(4)
Traceability of a selected
sample of installed materials to the
Purchase
Orders
and receipt inspection
records for the material
was verified.
(5)
A sample
of purchase
orders,
receipt inspection
records,
and
vendor Certificates of Compliance
were reviewed for inclusion of
technical
and regulatory requirements.
The structural materials
used
in this
PCM were
purchased
as
FPSL Quality Level QL-2,
commercial
grade.
Material
purchased
in this manner is receipt
inspected,
which consists
of
a review of the required
vendor
documentation
and
an inspection of material for damage;
however,
the purchase
order does
not invoke
on the vendor,
nor
does it require
the vendor to have
a
QA program
meeting
10 CFR 50, Appendix
B requirements.
The
FPSL dedication
program
for these materials
consisted
of conducting vendor audits which
primarily verify that the vendor maintains material
traceabi lity
and
has
a
sound basis for vendor Certificates of Compliance.
(6)
Vendors
supplying
material
to the
purchase
odrders
in b.5
above,,
were verified to be on'he
approved
FPSL
Vendors List
for commercial
grade
procurements.
It was
noted during the review of this
PCN, that several
types of
records
were
not filed with the
completed
PCN package.
Several
purchase
orders
and receipt
inspection
records
were filed in the
package
whereas
others
were not.
The Construction
Work Order
and
the associated
documentation
were also
not filed in the
package.
Review of the licensee's
records
retention
requirements
identified
that different records
are required
to
be maintained for different
lengths
of time.
Therefore,
the possibility exists
that records
associated
with design
changes
may
be discarded.
This example of
the
potential
problem
noted
in this
PCN is
combined
with the
examples
discussed
in paragraph
2.
a.
and will be reviewed during
future inspections.
This is identified as
another
example of IFI
250, 251/88-34-02.
c ~
Engineering
Backlog
PCNs at
Turkey Point are primarily developed
as
a result of site
issued
REAs.
Due to the fact that
REAs constitute the major portion
of the engineering
workload,
a review of the
REA process
and the
REA
backlog identified over eight hundred
outstanding
REAs.
Engineering
appears
to have
adequate
control over the backlog.
This conclusion
is
based
on
several
facts.
A large
percentage
of the
backlog
consists
of drawing updates.
This area
has recently
been
addressed
by
FP&L management
by funding
a project specifically designed
to
concentrate
in the
drawing
update
area.
At the
time of this
inspection,
a priority order for the
drawing revisions
was
under
developement.
The remaining
REAs were also prioritized for completion
which should
ensure
correction of the
items most important to plant
safety.
The highest priority was focused
on closing'REAs which were
outage related.
The non-outage
related
REAs are to be worked in the
order of priority after the current outage is completed.
Discussion
with licensee
personnel
and review of approximately
20 outstanding
REAs concluded that there were
no operability concerns
in the backlog.
The majority of the
REAs fall into the categories
of plant improve-
ments,
drawing
changes,
material
substitutions,
and
engineering
studies.
Naj or modifications
to
be
developed
by the
corporate
office were prioritized
and
placed
in the
integrated
schedule.
Review of the current
REA Administrative Procedure,
0190.84,
REA-
Preparation,
Review
and Approval, dated
October 4,
1988 also
noted
that there were provisions for determining
TS involved REAs.
3.
Reactor Plant
Component Identification (Tagging)
During this inspection
a cursory
walkdown of the Unit 3
and Unit 4
Pump
rooms
was
conducted.
The inspectors
identified several
concerns
which were
immediately brought to the attention of licensee
management.
The concerns
noted
were as follows:
a
~
. The face plate
on temperature
TI-4-663C (Unit 4) was broken
and
there
was
no calibration sticker indicating the
was currently
calibrated.
b.
The temperature
next to root valve 4-50-446
(gauge TI-4-1417)
in Unit 4
ha'd
no component
identification 'lable
and .no calibration
sticker attached.
c.
The
face plate
on the temperature
next to root valve
4-50-445
TI-4-1415) in Unit 4 was missing,
the
had
no
component identification,
and
no calibration sticker attached.
d.
e.
No calibration sticker
was attached
to pressure
indicator PI-4-644A
in Unit 4.
The 16-inch
on the discharge
side of .CCW
Pump
"C" in
Unit 4 was not identified.
f.
The sixteen
inch handwheel
operated
valve
on the suction side of the
"B" CCW,pump in Unit 3 was not identified.
g.
The 16-inch
on the discharge
side of the "A" CCW pump in
Unit 3 was not identified.
The
pumps
and
heat
exchangers
had
not
been re-identified
by
stenciling following painting in Unit 3..
Note:
[A significant amount
of maintenance
was
being
performed in the Unit 4
pump
room and the
Unit 3
pump
room had just been
completely repainted
due to the fact
that both units were in outages].
Further investigation of these
concerns
by the inspectors
and the licensee
resulted
in the following conclusions
and corrective actions:
(1)
Work requests
were
issued
by the licensee
to correct
the
face
plate
problem
noted
on
TI-4-663C
and
TI-4-1415
(Reference
WA881102135801
and WA880591159).
(2)
The licensee
does
not use calibration stickers.
The inspector
reviewed
the calibration recall
records for the subject
and
no deficiencies
were identified.
(3)
The component identification (tagging)
concern
was investigated
by the inspectors
and the licensee.
The following problem areas
were noted:
(a)
Interviews with the operations/maintenance
Tagging Coordinator
and
two assistant
operators
in training,
who routinely
accomplish
system
walkdowns for component identification,
determined that:
Personnel
were
not
using
ETI tags
to temporarily
identify
unidentified
components
until
metal
identification
tags
were installed
as
required
by
paragraph
5.2.1
of
O-ADN-209,
Equipment
Tagging,
dated
June
14,
1988.
The operations/maintenance
Tagging Coordinator
was not
assuring that metal
tags
were installed
on unidentified
components within twenty four hours of notification as
required
by Enclosure
{5) of this
same
procedure.
(b)
The
licensee
conducted
independent
partial
walkdowns of
several
plant systems
to determine
the extent of the
com-
ponent identification concern.
These
walkdowns identified
7 unidentified components
out of 279 items
checked
on the
Unit 3
CCW system
and
69 unidentified
components= of 248
items checked
on the
TPCW system.
As
a result of the above,
the inspectors
concluded
that the
component
identification
(tagging)
area
did
not
meet
established
procedural
requirements.
Licensee
actions
in this area,
both completed
and planned,
are
documented
in Plant
Managers
Memo PTN-PMN-88-637,
dated
November 7,
1988, which was tele-faxed to Region II on November 7, 1988.
The deficien-
cies
discussed
above
concerning
the component identification tagging area
are collectively identified as violation 250, 251/88-34-01.
4.
Exit Interview
I
The inspection
scope
and results
were summarized
on November 4, 1988, with
those
persons
indicated
in paragraph
1.
The inspectors
described
the
areas
inspected
and
discussed
in detai
1
the
inspection
results listed
below.
Proprietary information is not contained
in this report.
Dissenting
comments
were not received
from the licensee.
5.
and Initialisms
AFWP-
ASME-
CFR
FP&L-
I FI
PWO
REA
TPCW-
TS
Pump
American Society of Mechanical
Engineers
Component
Cooling Water
Code of Federal
Regulations
Equipment
Temporary Identification
Florida Power and Light
Inspector
Followup Item
Plant
Change Modification
Plant Work Order
Quality Control
Request for Engineering Assistance
Pump
Turbine Plant Cooling Water
Technical Specifications
Visual Testing
I