ML17345A625
| ML17345A625 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 12/30/1988 |
| From: | Conlon T, Ward D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17345A623 | List: |
| References | |
| 50-250-88-37, 50-251-88-37, NUDOCS 8901130058 | |
| Download: ML17345A625 (26) | |
See also: IR 05000250/1988037
Text
p'A Rico
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGiON II
101 MARIETTAST., N.ssV.
ATLANTA,GEORGIA 30323
Report Nos.:
50-250/88-37
and 50-251/88-37
Licensee:
Florida Power
and Light Company
9250 West Flagler Street
Miami,
FL
33102
Docket Nos.:
50-250
and 50-251
License Nos.:
and
Facility Name:
Turkey Point
3 and
4
Inspection
Conducted:
November
28
December
Inspector:
D.
C.
Ward
Approved by:
T.
E. Conlon, Chief
Plant
Systems
Section
Engineering
Branch
Division of Reactor Safety
2,
1988 and
December
19,
1988
/>rgc'8
Date Signed
Date
igned
SUMMARY
Scope:
This routine,
unannounced
inspection
was
conducted
in the
areas
of
fire protection/prevention
and
a review of the licensee's
actions to
meet
the
separation
requirements.
of
Appendix
R,
Section III.G. in the Turkey Point Unit 3 and Unit 4 Containments
and
the requirements
of 10 CFR 50, Appendix
R,Section III.O.
Results:
Several
minor
weaknesses
were
identified
in
the
area
of the-
implementation
of the Fire Protection
Program.
These
weaknesses
are
summarized
below:
There is
an apparent
misunderstanding
on the part of the Fire
Protection
Group
regarding
the training requirements
for fire
brigade
members. 'lant
procedures
specifically
call
for
members
to attend
training
every
three
months.
However,
the
Fire Protection
Group staff had interpreted this requirement
to
mean
quarterly
training
which
resulted
in
several
brigade
members
not receiving their required training within the three
month interval.
In addition,
the
procedural
requirements
to
disqualify ineligible members
from duty were not implemented.
The licensee
did not appear
responsive
to
NRC initiatives during
this inspection.
Specifically, the issue
regarding
the adequacy
of the seismic design of the Reactor
Coolant
Pump
PQIQ
jDOC
L 90l Os3
- >OllSOOgg .,
g
K osO002~0
i
collection
systems
was identified very early in the inspection.
However,
the licensee
did not to provide
a detailed
update
of
the actions
bei~n
taken to address
the inspectors
concerns until
late in the inspection.
The
licensee's
method
of ensuring all reportable
items
are
included
in '
special
report
as
required
by
Technical
Specifications
(TS)
was
not
adequate.
This resulted
in
one
reportable fire bar rier breach
not being
included in a special
report.
The licensee's
review of the circumstances
behind the unresolved
item
identified
in this report
regarding
the
rubber
hose
installed
on
the
Unit 3
Reactor
Coolant
Pump
(RCP)
lube
oil
collection
system
may identify some major weaknesses
in the area of plant design
changes,
maintenance,
and
review of potentially
reportable
items
which wi 11
be evaluated
at
a later date.
Within the areas
inspected,
the following violations were identified:
Assignment
Of
Ineligible
Members
To
Fire
Brigade
Duty,
Paragraph
2.d.(2).
Failure
To Report Fi're Barrier Breach
As Required
By Technical
Specifications,
Paragraph
2.e.(1)
(Not Cited).
In addition the following unresolved
item was identified:
Installation
Of Rubber
Hose
On Unit 3 Reactor
Coolant
Pump "A"
Lube Oil Collection System,
Paragraph
3.b.
Persons
Contacted
Licensee
Employees
- J...Arias., Jr.,
Supervi sor,
Regulatory
Compliance
- K. Arnold, Fire Protection
- P. Banaszak,
Nuclear
Engineering,
Site
- J. Cross,
Plant Manager
- H. Dager,
Vice President
- R. Earl, Supervisor,
equality Control
"C. Fisher,
Mechanical
Engineering,
Juno
Beach
"T. Grozan,
Licensing
"S. Hale, Engineering
Manager
"J. Hutchinson,
Plant Support,
Juno
Beach
- J. Odon, Site Vice President
- L. Pearce,
Superintendent,
Operations
~G.
Salaman,
Compliance
Engineer
- G. Smith, Services
Manager
"G. Tracz
k
Actin
Su ervisor
Fire Protection
Y
~
g
P
)
Other
licensee
employees
contacted
during
this
inspection
included
craftsmen,
engineers,
operators,
mechanics,
security
force
members,
technicians,
and administrative
personnel.
Other Organizations
J. Creighon-
"E. Oesterle-
D. Perrine
- D. Stanley
Bechtel
Power Corporation
Bechtel
Power Corporation
Diamond Corporation
Bechtel
Power Corporation
NRC Resident
Inspector
R. Butcher
- Attended exit interview
Fire Protection/Prevention
Program
(64704)
a.
Fire Prevention/Administrative
Control Procedures
The inspector
reviewed
the following Fire Prevention/Administrative
Procedures:
Procedure
No. Date
Title
15500 .(.10/4/88)
0-ADM-016. 2 (1/19/88)
O-ADM-016.3 (3/22/88)
EP 20107
(12/9/86)
Fire Protection
Program
Fire Brigade
Program
Fire Protection
Impairment
Fire/Explosive
Emergencies
Based
on this review, it appears
that the above procedures
meet the
NRC
guidelines
of the
document
entitled,
"Nuclear
Plant
Fire
Protection
Functional 'esponsibilities,
Administrative Controls,
and
guality Assurance,"
dated
June
1977.
The
inspector
also
reviewed
the
implementation
of the
procedural
requirements
outlined
in
O-ADM-016.2,
Fire
Brigade
Program.
This
review identified
a
number of discrepancies
which are
discussed
in
Paragraph
2.d.(2) of this report.
b.
Fire Protection Surveillance
Procedures
The
inspector
reviewed
the
following
Fire
Protection
System
Surveillance
Procedures:
Procedure
No. Date
Title
MP 15537.3 (1/28/77)
0-OSP" 016. 22 (8/15/88)
O-SMM-016.1 (3/17/88)
0-SMM-016. 6 (9/14/88)
4-SMM-016. 2/1/28/88
Surveillance
of Penetration
Open
Head
Spray/Spr inkler
3
Year Air Flow Test
Surveillance
Program
Fire
Suppression
System
Annual Flush
Fire Door Inspection
Spray/Sprinkler
System
Inspection
The
above
surveillance
procedures
were
reviewed to determine if the
various
test
outlines
and
inspection
instructions
adequately
implement the surveillance
requi rements
of the plant'
Fire Protec-
tion Technical
Specifications
(TS).
In addition,
these
procedures
were
reviewed to determine if the inspection
and test instructions
followed
general
industry fire
protection
practices,
NRC fire
protection
program guidelines
and the guidelines of the National Fire
Protection Association
(NFPA) Fire
Codes.
Based
on this review, it
appears
that the
above
procedures
are satisfactory,
except
Procedure
No. 0"SMM-016.6.
Procedure
No. 0-SMM-016. 6 is implemented to satisfy the annual
visual
n o~sre
doors required
by TS 4.15.
However,
in reviewing
this procedure,
the inspector
found that the
procedure
calls for an
inspection of the latch
and door closure,
but does
not specifically
require
the
door
surface
to
be
inspected
and
documented.
The
inspector
found
by review of
a
sample
of the surveillance
results
from this
procedure
that
damage
to
the
door
surface
was
being
identified
even
though
not specifically required
by the procedure.
In addition,
during the plant tour,
the inspector
did not find any
-fire doors
which were significantly degraded.
Therefore,
this is
identified as
Inspector
Followup Item 50-250,
251/88-37-01,
Revise
Fire
Door Surveillance
Procedure
To 'Document
Visual
Inspection
of
Door Surface.
The
inspector
also
noted
that
Procedure
No.
did not
identify all of the fire protection barriers
installed to meet the
requirements
This issue
had
been previously
identified by the licensee
and
a procedure
revi sion is in progress.
During
a recent surveillance
required
by TS, this procedure
could not
be
used
and
interim Test
Requests
(TR) were
used
to perform the
required
surveillance.
The
upgraded
procedure
will
be
reviewed
during
a future inspection.
c.
Fire Protection
System Surveillance
Inspections
and Tests
The inspector
reviewed the following surveillance
inspection
and test
records for the dates
indicated:
Procedure
No.
MP 15537.3
"MP 15537.3
TR 280-87
TR 011-88
TR 028-88
TR 034-88
TR 038"88
TR 039-88
TR 054"88
TR 002-88
O-OSP-016.22
0-SMM-016. 1
0-SMM-016. 6
Results
Reviewed
6/11/87,
1/28/85
3/02/88
2/26/88
4/19/88
3/02/88
3/17/88
4/19/88
4/19/88
3/01/88
7/29/88
9/30/85,
9/26/88,
1/19/87
4/1/88
3/14/87, 8/16/87,
3/17/88, 9/8/88
- MP 15537.3
conducted
under special
TRs listed.
The surveillance
test
records
data
and testing frequency associated
with the
above fire protection
system
surveillance
test/inspections
were found to be satisfactory with regard to meeting the requirements
of the plant's Fire Protection
TS.
In addition,
the
inspector
reviewed Test
Procedure
(TP)
507,
Fire
Main
Post
Indicator
Valve
(PIV)
Leak
Test.
This
procedure
was
generated
in response
to
a Notice of Deviation issued
in the Resident
Inspectors
Report
No. 88-36.
The test procedure
requires
the flushing of
the fire loop and the leak testing of each
PIV to ensure
leakage
was
within
an
allowable
range.
This
procedure
appears
adequate
to
address
the concerns
outlined in the resident
inspectors
report.
The
inspector also witnessed
portions of the test being conducted
and did
not
note
any discrepancies.
The test
appeared
very effective
in
reducing the amount of leakage
through
some
PIVs.
Leakage at one
prior to the test
appeared
to be in excess
of 100 Gallons
Per Minute
(GPM); however,
following the flushing of the line leakage
from this
PIV was reduced to 2 GPM.
The licensee
intends
to incorporate this
TP into a permanent
plant procedure
which will be conducted
annually.
d.
Fire Brigade
(1)
Organi zati on
The total station fire brigade
is
composed of approximately
57
personnel
from the
operations,
chemi stry
and
health
physics
staff,.
The
on duty shift fire brigade leader is normally one of
the
licensed
operators.
The
inspector
reviewed
the
on duty
shifts for the
following dates
and verified that sufficient
qualified fire brigade
personnel
were
on
duty
to
meet
the
provisions of the plant's
TS.
June
1988
July 1988
The
review resulted
in the inspector
identifying
a
number of
cases
where ineligible personnel
were
assigned
brigade
duty.
This issue
is further discussed
in Paragraph
2.d.(2).
No other
discrepancies
were noted.
(2)
Training
The inspector
reviewed the training and drill records for three
brigade
leaders
and twelve brigade
members for the period fourth
quarter
1987 through third quarter
1988.
The inspector
found that of the fifteen brigade
members
who'
training
records
were
reviewed,
four
members
had
missed
a
required
three
month training
session
for
second
quarter
of
1988.
Per
procedure
O-ADM-016.2,
Section 5.3. 1,
a
brigade
member
who misses
the required
three
month training is to
be
removed
from active status
on the Fire Brigade Assignment
Sheet.
However,
these
four members
were not removed
from active status.
i
Consequently,
the
inspector
identified
twenty
shifts
in
uly 1988 where at least
one of these
four ineligible members
was
assigned
to fire brigade
duty.
In addi~~o~hese-four
members
who missed
the required training,
three
other
members
training
was
not
conducted
within the
three
month interval
required
by procedure.
This is identified
as Violation Item
50-250,
251/88-37-02,
Assignment
Of Ineligible Members
To Fire
Brigade
Duty.
The remaining brigade
members
had attended
the
required training and participated
in the required fire brigade
drills.
(3)
Fire Brigade Drill
During this inspection,
the inspector
witnessed
an
unannounced
fire brigade drill.
The drill fire scenario
was
an electrical
fire in
the
Unit 4
4160
Volt
switchgear
room
which
was
apparently
caused
by an electrical fault.
Five fire
brigade
members
responded
to
the
pending
fire
emergency.
Four
brigade
members
assembled
outside
the
switchgear
room in full protective firefighting turnout clothing
and
self
contained
breathing
apparatus.
The fifth brigade
member
was unable to locate protective clothing in his size.
An
initial size-up
of the fire condition
was
made
by the fire
brigade
leader
and one 1-1/2 inch fire attack
hose line and two
portable fire extinguishers
were
advanced
into room.
The fire
attack
hose line
as
placed in service
on the fire and the fire
was placed
under control in
15 minutes.
In addition,
the fire
brigade initiated fire victim search
and rescue,
smoke control,
and water control operations.
With the
exception
of
one
brigade
member
not
being
able
to
obtain
protective
clothing
in
his
size,
the fire brigade
utilized proper manual firefighting methods
and
reacted
to the
fire drill scenario
in an effective and efficient manner.
The licensee
is in the
process
of upgrading
the fire brigade
equipment
lockers outside
the Radiation
Control
Area
(RCA) to
include
additional
gear
in
a wider variety of sizes.
This
should eliminate
the
problem of members
not having protective
clothing in the correct sizes.
Plant Tour and Inspection of Fire Protection
Equipment
Permanent
Plant Fire Protection
Features
A plant tour was
made
by the inspector.
During the plant tour,
the following safe
shutdown
related
plant
areas
and
their
related fire protection features
were inspected:
Emergency
Diesel Generator
Building
Unit 3 Auxiliary Feedwater
Pumper@.
Unit 3 Component
Coolant Water
Pump Area
Unit 3 Charging
Pump Area
Unit 4 Component
Cooling Water
Pump Area
Unit 4 Charging
Pump
Room
The inspector
found that the fire protection features
in these
plant
areas
were
inservice
or for those
features
compensatory
measures
were in place in accordance
with TS.
The
inspector
also
randomly
selected
a
Fire
Protection
Impairment
( FPI) tag to insure that it had been
reported to the
NRC in accordance
with TS.
FPI
1766 was issued
on July 1,
1988
due to
a breach of fire barrier
45F in the Unit 4 Charging
Pump
Room.
Per
TS 3. 14.5.b.2,
when
is not
returned
to functional
status
within
7 days,
a report to the
Commission
must
be
made.
However,
when the licensee
reviewed
their special'report
issued
at the
end of July 1988, this
FPI
had
not
been
reported.
In
response
to this
finding,
the
licensee
immediately
conducted
a complete
review of all FPI's
outstanding
to determine if any others
had
not
been
reported.
This review found
no other discrepancies.
Also, the licensee
implemented
a
new method of generating
the
computer
data
base
reports to insure
a similar violation would not occur.
Finally,
the
licensee
began
processing
a Special
Report for FPI
1766.
This is identified as
a Violation Item, Failure to Report Fire
Barrier Breach
As Required
By Technical Specification:
However,
since this violation
meets
the criteria of
the
Enforcement
Policy outline
in
Appendix C,
Section
V, this
violation is not being cited.
The plant tour also verified .the licensee's
implementation
of
the fire prevention
administrative
procedures.
The control of
combustibles
and flammable materials,
liquids and gases,
and the
general
housekeeping
were
found to
be very good in the
areas
inspected.
One
welding
operation
was
observed
in the
Unit 4
Component
Cooling Water
Pump Area,
An approved
"Hot Work" permit had
been
issued for each of the welding operations
and the wA'k practices
met the requirements
of the licensee's
fire prevention control
procedures.
Appendix
R Fire Protection
Features
The
inspector
visually
inspected
the
fire
rated
raceway
fire
barriers
required
for
compliance
with
Appendix
R,
Section III.G.2 in the following plant areas:
Room
Unit 4 Charging
Pump
Room
~Racewa
s
B4H1314
g4H1317
B4H1362
BPB1872
BPB4832
Unit 2 Charging
Pump
Room
B3H1318
B3H1319
B3H1323
B3H1374
~
BPB3863
BPB3921
Based
on the inspector
observations
of the
above
raceway fire
barrier
enclosures, it appears
that the
one
hour fire barrier
integrity associated
with the fire barrier assemblies
was
being
properly maintained
in a satisfactory condition.
The
inspector
made
a
walkdown
of the
Appendix
R related
automatic sprinkler protection in the. following plant areas:
Unit 3 Component
Cooling Water
Pump Area
Unit 4 Component Cooling Water
Pump Area
Based
on this
walkdown,
the
inspector
determined
that
the
sprinkler protection
provided for the
areas
identified
above
provided sufficient protection with respect
t'o controlling
an
exposure fire.
The
following
eight-hour
emergency
lighting
units
were
inspected:
Unit No.
Location
EL 046"18
EL 073-30
EL 074-30
EL 083"60
Unit 4 Charging
Pump
Room
Cable Spreading
Room
Cable Spreading
Room
Cable Spreading
Room
These units were in service,
lamps properly aligned
and appeared
to be properly maintained.
Compliance With 10 CFR 50, Appendix
R,Section III.G and III.O.
(64100)
requires
Turkey Point Units
3
and
4 to
comply with the
requirements
of III.G, III.J. and III.O of 10 CFR 50, Appendix
R.
Power and Light (FP&L) was granted
a scheduler
exemption
from the schedule
requirements
outlined in
and is not required to
be in total
compliance with Appendix
R until the
end of the present Unit 4 outage.
In
't ~ K,,. 'lY,~
Crl sa r+'r mse
rse . Asar, ~are pit;
e
pr>>, rw~+.rsm
r,
se t+0 lr, s >
mh r, m
e
re ., ~
'I
'r",
~ '
ts s~~t
Cl
preparation
for
an
upcoming
team
inspection
to verify compliance with
Appendix
R,
an
inspection
was
made
of
the f
q
pro'tection
features
installed in the Unit 3 and Unit 4 containments
to meet
the requirements
of Section III.G.d, e,
and f of Appendix
R and the
Reactor
Coolant
Pump
(RCP)
lube oil collection
system installed to meet
the
requirements
of
Section IIIeO of Appendix
R.
a.
III.G Separation
The
cable
routings
for circuits
associated
with postfire
safe
shutdown
equipment
in the Unit 3
and Unit 4 containments
were
not
available at the time of this inspection.
The licensee
is in the
process
of accumulating
this
information for the
Appendix
R
Team
inspection following the Unit 4 outage.
Therefore,
the inspector
was
only able to verify the physical location of radiant energy shields,
fire retardant
and fire detection
system installed
in the
containments.
The adequacy of cable separation
was not reviewed.
The inspector verified that each radiant
emergency
shield designated
on the following drawings
was installed:
~Racewa
s
Unit 3:
5610-E-100/85-118-Rev.
0
5610-E-101/85-118-Rev.
0
5610-E-101/83-150-Rev.
1
5610-E-100/83-150-Rev.
1
3C1331*
3C1332"
3C1155
3C1165
3C1173
PB3719
PB3720
3C094A**
3C094B**
3C1182*"
3C225
3C1333
TB3885
Unit 4:
5610-E-110/83-149-Rev.
2
5610-E-108/83-149-Rev.
2
5610-E-107/83-149-Rev.
3
5610-E-110/83-149-Rev.
2
- 4C192
4C226
4C247
4C645
4C1336
4C1337
4C192
e
"Radiant
Energy
Shield
no
longer
required
per
Change
Request
Note
(CRN) E-5518
""Radiant
Energy
Shield,no
longer
required
per
approved
exemption
request
(Exemption
Q. 1 of Section
9.6A of the Turkey Point
FSAR).
Radient
energy
shields
were provided
on all of the
above
raceways
which are required to be protected.
In addition,
the
inspector
examined
the
Flamastic fire retardant
coating applied to cables
in cable trays outside the secondary
shield
wall.
This material is applied to safe
shutdown cables
to provide
a
radiant energy shield
and prevent the propagation
of fire across
the
cables.
Also the Flamastic coating is part of the justification for
exemptions
from the separation
requirements
of Appendix
R granted
by
the
NRC
(Sections
4.P.2.and
4.g.2
of
the
Turkey
Point
Section
9.6.A).
The Flamastic
was
found degraded
in many locations
due to work conducted
during
the Unit 3
and
Unit 4 outages.
The
licensee's
fire protection staff stated
that this
item
had
been
previously identified
and
a
was
being
issued
to
ensure
the
flamastic
was reapplied
as required
by the
FSAR.
The results of this
TR will be reviewed during
a future inspection.
The inspector
also
reviewed
the
smoke
detector.
installation in the
electrical
area
of the Unit 3
and Unit 4 containment.
The cables
in cable trays represent
the primary in-situ combustibles
in this area.
The detectors
are installed directly over these
cable
trays.
In addition,
the licensee
has provided
smoke collectors
over
each detector.
The placement 'of these detectors
appeared
adequate
to
detect
a fire originating in the cable trays.
Based
on this
inspection,
the installation
of the
radiant
energy
shields, fire retardant
and fire detection
system
appeared
adequate
except
as noted above.
The cable routings for postfire safe
shutdown circuits inside
the Unit 3 and Unit 4 containments will be
reviewed during the forthcoming Appendix
R Team Inspection.
b,
Compliance With III.O
Section III.O requires
each
RCP to be equipped with an oil collection
system if the'ontainment
is not inerted during
normal
operations.
The system is required to be designed,
engineered,
and installed
such
that failure will not
lead to fire during
normal
or design
basis
accident
conditions,
and that
the
system will withstand
a
safe
shutdown
All
leakage
from potential
pressurized
and
unpressurized
leakage
sites
is to
be collected
and
drained
to
a
vented
closed
container
that
can
hold the entire
lube oi 1
system
inventory.
The
tank
vent
requires
a
flame
arrestor if the
flash-point characteristics
of the oil presents
the
hazard
of fire
flash-back.
10
The
inspector
reviewed
the plant
change
and modification
(PC/Ms)
acka
es issued to i
s~ta
1 the lube oil co'llecti'on systems
in Unit
and Unit 4,
PC/Ms 80-05
and 80-08, respectively.
These
PC/Ms called
for the
systems
to
be designed
to seismic
Category I standards
and
called for a system able to contain the entire inventory of lube oil
from one
RCP.
Oil collection drip pans
were provided at the lube oil
cooler, oil lift pump enclosure
and lower bearing
on each
pump.
The
lubricating oil used in the
pumps
has
a flash point of 450'F and the
collection tank is located
away from ignition sources
and postfire
safe
shutdown
equipment.
Therefore,
a flame arrestor is not provided =.==-=
on the tank.
The
system consists
of the oil collection
pans
which
are
hard
pipe
through
1-1/2 inch pipe to the colTection
tank
and
several
pipe supports.
The
NRC granted
an
exemption
from the
requirements
of Appendix
R
Section III.O to
FP&L by letter,
dated
March 27,
1984
based
on
an
FP&L submittal
dated
May 12,
1983.
The exemption allows the
RCP lube
oil collection
systems
at Turkey Point to be designed
to handle the
inventory from only one
RCP for each unit rather than from all three
as required
by Appendix
R,Section III.O.
The inspector
conducted
a walkdown of the
systems
and found
a discrepancy
in the as-built system for the Unit 3
"A"RCP.
The original
PC/M 88-05 called for the
system
to
be
hard
piped from the
pan to the oil collection tank.
However,
in the field
a
rubber
hose
was installed
between
the
hard
pipe
and
each oil
collection
pan.
Subsequent
to this
finding,
the
inspector
was
informed
by licensee
management
that this
hose
was
not seismically
qualified as required.
The licensee
was
unable
to determine
how or
when the
hose
had been installed
by the
end of this inspection.
In addition to the
above
discrepancy,
the inspector
found that the
RCP oil collection
system
on the Unit 4
was being upgraded
under
PC/M 86-130 during this outage
and that
a similar plant
change
for
Unit 3,
PC/M 86-127,
was
planned
for Unit 3.
A review of
PC/M
packages86-130
and
86-127
revealed
that they were the result of a
May 14,
1985 letter
from Bechtel
Power
Corporation
(BPC) to
which:questioned
the seismic design of the Unit 3 and Unit 4
RCP lube
oil collection
systems.
Specifically,
the letter
stated
that
the
connection
of the
pipe to the oil collection
pans
do not provide
adequate
restraint
and
the letter
stated
that
the
pipe
routings
between
the oil collection
pans
and the first seismic
support
have
been
modified since
PC/Ms 80-05
and
80-08
had
been
implemented
and
these modifications
have not been seismically analyzed.
PC/Ms86-130
and
86-127 call for seismically
qualified flexible
hoses
to
be
installed between
the drip pans
and
system piping and the addition of
a number of pipe supports.
In their
May 12,
1983 letter requesting
an
exemption
from the requirements
of Appendix
R,Section III.O FP&L
states
"The lube oil collection
system is seismically
designed
and
will remain functional during
a seismic event".
FP&L to date
has not
requested
an
exemption
from
the
requirements
of
Appendix
R
Cl
Section III.O, that the
system
be seismically
designed
nor
has
a schedular
exemption
been
applied
for from the
schedule
re uirements of 10 CFII 5+48~~egards
to these
systems.
Based
on the discrepancies
noted above,
the inspector
requested
that
FP8 L provide documentation that the original design
under
PC/Ms 80-05
and
80-08
were
adequate
from
a
Seismic
Category I
stand
point,
determine
how and
when the
rubber
hose
was installed
on the Unit 3
"A" RCP,
and identify what action
was taken
on the
BPC letter which
called'nto question
the original design of the
systems
in 1985.
The licensee
was
unable
to furnish any of the requested
information
prior to
the
end of the
inspection.
Therefore,
during
the exit
interview, this item has
been classified
as
an apparent violation.
On
December
19,
1988,
the inspector
contacted
Gabe
Salaman
of the
licensee's
Regulatory
Compliance
Depar'tment
by telephone
and
was
informed that
an evaluation of the as-built configuration of the
lube oil collection
systems
had
been
completed.
This evaluation
proved that the original seismic design
of the
systems
was
adequate
and that through testing
of the rubber
hose installed
on the Unit 3
system, this system
was also determined
to be adequate
and would have
remained
functional following a seismic
event.
This evaluation
was
completed
on December
9,
1988
and was documented
in a letter from BPC
to
FPKL on that date.
The licensee's
representative
stated further
that they have still not determined
to date
how and
when the rubber
hose
was installed
on the Unit 3 "A" RCP.
Therefore,
based
on this
additional
information, the apparent
violation has
been
deleted
and
an Unresolved
Item 50-250/88-37-03,
Installation of Rubber
Hose
On
Unit 3 Reactor
Coolant
Pump "A" Lube Oil Collection System,
has
been
opened
to
followup
on
the licensee's
investigation
and corrective
actions
in regards
to the installation of the
rubber
hose
in the
Unit 3
RCP lube oil collection system.
Based
on the information above,
the
RCP lube oil collection systems
installed
in
Turkey
Point
Unit
3
and
Unit 4
appear
to
be
in
compliance with the requirements
of
Appendix
R, Section
III. 0 and the
NRC
SER issued
by letter dated
March 27,
1984 granting
the
licensee's
an
exemption
from the requirements
of Section?II.G
of Appendix
R.
4.
Exit Interview
The inspection
scope
and results
were
summarized
on December
2,
1988, with
those
persons
indicated in paragraph
1.
The inspector 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.
12
Item Number
Descri tion and Reference
50"250, 251/88-37-01
IFI
Revise
Fire
Door Surveillance
Procedure
To Document Visual Inspection
Of Door Surface,
Paragraph
2.b
50-250,
251/88-37-02
Not Cited
Violation
Assignment
Of Ineligible
Members
To
Fire
Brigade
Duty,
Paragraph
2.d(2)
Violation
Failure
To
Report
Fire
Barrier Breech
As Required
By Technical
Specifications,
Paragraph
2.e.(1)
50-250/88-37-03
URI Installation of Rubber
Hose
On
Unit 3 Reactor
Coolant
Pump "A" Lube Oil
Collection System
The unresolved
item listed above replaced
an apparent violation identified
in the exit interview
on
December
2,
1988.
This item was identified to
'he
licensee
in a telephone
conversation
subsequent
to the inspection with
a licensee
employee
(See
Paragraph
3.b).