ML17347A709
| ML17347A709 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 03/18/1988 |
| From: | Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17347A708 | List: |
| References | |
| 50-250-87-54, 50-251-87-54, NUDOCS 8803250292 | |
| Download: ML17347A709 (5) | |
Text
ENCLOSURE 1
NOTICE OF VIOLATION Florida Power and Light Company Turkey Point Units 3 and 4
Docket Nos.
50-250, 50-251 License Nos.
DPR-31, DPR-41 Dur'ing the Nuclear Regulatory Commission (NRC) inspection conducted on December 28, 1987 January 18,
- 1988, violations of NRC requirements were identified.
The violations involved: failure to maintain adequate design control in the preparation of Plant Change Modifications (PCMs) for the Auxiliary Feedwater (AFW) Backup Nitrogen System, four examples; and failure to meet the requirements of Technical Specification (TS) 6.8. 1, four examples; misalignment of the AFW Backup Nitrogen System; failure of a fire watch to remain continuously alert; performing maintenance without documented instructions or drawings appropriate for the circumstances; and failure to incorporate an On The Spot Change (OTSC) to a
procedure within required timeframes.
In accordance with "General Statement of Policy and Procedure for NRC Enforcement Action," 10 CFR Part 2, Appendix C (1987),
the violations are listed below.
e A.
10 CFR 50, Appendix B, Criterion III, as implemented by the approved Florida Power and Light Company Topical Quality Assurance Report (FPLTQAR) 1-76A, Revision 10, Topical Quality Requirement (TQR) 3.0, Revision 5,
requires that design changes be subject to design control measures commensurate with those applied to the original design and that these design control measures assure that applicable regulatory requirements and the design basis are correctly translated into specifications,
- drawings, procedures and instructions.
FPLTQAR 1-76A, Appendix C, Revision 7
specifically
- commits, with exceptions not relevant
- here, to American National Standards Institute (ANSI) N45.2. 11-1974, Quality Assurance Requirements for the Design of Nuclear Power Plants, and to Regulatory Guide 1.64, Revision 2, Quality Assurance Requirements for the Design of Nuclear Power
- Plants, which endorses ANSI N45.2. 11-1974.
ANSI N45.2. 11-1974 specifies that design activities be prescribed and accompli shed in accordance with procedures of a type sufficient to assure that applicable design inputs are correctly translated into specifications,
- drawings, procedures, or instructions'esign changes must be justified and subjected to control measures commensurate with those applied to the original design.
Contrary to the above, in January
- 1988, inspections identified that design inputs contained in Plant Change Modifications (PCMs)85-175 and 85-176,
'ad not been correctly translated into operating procedures and the system description, as demonstrated by the examples below.
1.
Units 3 and 4 Operations Surveillance Procedures (OSP) 3/4-0SP-075.3,'oth entitled AFW Nitrogen Backup System Low Pressure Alarm Setpoint 8303250292 8303i8 PDR ADOCK 05000250 O
Florida Power and Light Company 2
Turkey Point Units 3 and 4
Docket Nos.
50-250, 50-251 License Nos.
and Leakrate Verification, Revisions dated November 5,
- 1987, were not revised to include appropriate maximum acceptance criteria for AFW System nitrogen consumption.
Consequently, the procedures allowed consumption rates that, if present, would have failed to meet the design basis requirement for 2
hours of system operation without operator action outside the control room.
Units 3
and 4
procedures 3/4-0SP-075.6, both entitled Auxiliary Feedwater Train 1 Backup Nitrogen Test, Revisions dated December 17,
- 1987, and Unit 3
and 4
procedures 3/4-0SP-075.7, both entitled Auxiliary Feedwater Train 2
Backup Nitrogen Test, Revisions dated December 17,
- 1987, were revised to include incorrect and excessively high acceptance criteria for AFW System nitrogen consumption.
Consequently, the procedures allowed consumption rates that, if
- present, would have failed to meet the design basis requirement for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of system operation without operator action outside the control room.
Off'Normal Operating Procedure (ONOP) 0208. 11, Annunciator Test Panel I, Station Service, Revision dated September 10, 1987, specified that upon receipt of a
low pressure
- alarm, each of 5 nitrogen bottle outlet pressure gauges should be placed in service by opening their root valves.
This was contrary to design requirements specified in PCMs85-175 and 85-176, which specified that the local pressure indicators are not seismically qualified and will be normally isolated from the system.
The AFW System Description (SD)
- 117, Revision dated December 10,
- 1987, and the plant Precautions, Limitations and Setpoints
- Document, Revision 29, dated December 15,
- 1987, indicated that the low nitrogen alarm setpoint pressure was 1350 psig.
- However, changes made during the implementation of PCMs85-175 and PCMs85-176 modified the setpoint to 650 psig.
Additionally, SD 117 was not updated to reflect extended AFW operation without required operator action outside the control room subsequent to receipt of the low nitrogen pressure alarm.
SD 117 specified that only 10 minutes existed during which to provide additional
- nitrogen, a
condition that existed
- before, but not after, the implementation of the PCMs.
Thi s is a Severity Level IV violation (Supplement I).
B.
TS 6.8~requires that wt itten procedures and administrative policies shall be'established, implemented and maintained that meet or exceed the requirements and recommendations of Appendix A of USNRC Regulatory Guide 1.33 and Section
- 5. 1 and 5.3 of ANSI N18.-7-1972.
Regulatory Guide 1.33, Appendix A, Item 8 specifies that surveillance procedures should be developed for the AFW System.
Section
- 5. 1.2 of ANSI N18.7-1972 specifies that procedures shall be followed.
Florida Power and Light Company 3
TurKey Point Units 3 and 4
Docket Nos.
50-250, 50-251 License Nos.
DPR-31, OPR-41 Surveillance Procedure 4-0SP-075.3, entitled AFM Nitrogen Backup System Low Pressure Alarm Setpoint and Leakrate Verification, Revision dated November 5,
- 1987, requires, in Step 7.2.20 that a
nitrogen bottle be placed in service.
This bottle is one of three bottles required to be aligned to the system.
Administrative Procedure O-ADM-031, entitled Independent Verification, Revision dated February 10,
- 1987, specifies, in section 5.2. 1.4 that independent verification of valve positions shall be applied to the Auxiliary Feedwater system.
Section 5.2.2.7 requires that independent verification be performed for manipulations which restore component normal alignment following surveillance testing.
Contrary to the
- above, on January 6,
- 1988, procedures 3/4-0SP-075.3 failed to establish administrative requirements to independently verfity AFW nitrogen valve positions, which resulted in a failure to implement step 7.2.20 of procedure 4-0SP-75.3 in that a valve was not opened as required.
Consequently, only two of three nitrogen bottles were restored to their normal alignment following surveillance testing.
Regulatory Guide 1.33, Appendix A, Item 6.v specifies that procedures should be developed for combating emergencies and other significant events such as plant fires.
Administrative Procedure (AP)
- 15500, entitled Fire Protection
- Program, Revision dated December 8,
- 1987, section 9.4. 1, requires in part that backup suppression be established as compensatory action during fire protection impairment of automatic fire suppression systems such as the halon system.
Section 9.5.3 specifies, in part, that the posting of continuous firewatch is an acceptable compensatory action when the halon system is impaired.
Temporary Procedure
- 347, entitled DC Equipment and Inverter Rooms Supplemental Cooling Monitoring and Standby Condition, Revision dated June 25,
- 1987, section
- 5. 1. 1, requires that any time door 108A-1 is maintained
- open, a
continuous firewatch shall be established to close the door (108A-1) within 60 seconds of sounding of the Halon Activation Alarm.
Contrary to the above, on January 12,
- 1988, the continuous fire watch posted at fire door 108A-1 to compensate for an impaired halon system was found asleep.
Consequently, the effectiveness of the halon system might not have been re-established (through door closure) wi+hin-the required 60 second time interval.
ANSI N18.7-1972, Section
- 5. 1.6. 1 requires that maintenance that can affect the performance of safety-related equipment shall be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances which conform to applicable
- codes, standards, specifications 'nd criteria.
Florida Power and Light Company 4
Turkey Point Units 3 and 4
Docket Nos.
50-250, 50-251 License Nos.
DPR-31, DPR-41 Contrary to the above, on January 13,
- 1988, maintenance was performed on the Unit 3 rod control system without documented instructions or drawings appropriate to the circumstances.
Fuses were removed from the system without a complete understanding of what circuitry the fuses supplied.
Consequently, portions of the rod control circuitry for 3 rods were de-energized while only one rod was thought to be affected.
During a
Unit 3 reactor shutdown,,this unexpectedly resulted in multiple rods dropping into the core, requiring a manual reactor trip.
4.
AP 0109.3, Revision dated August 6,
- 1987, entitled On The Spot Changes
[OTSC] To Procedures, specifies, in section 5.9.2 that:
Licensed Operations personnel are responsible for handwriting the text of approved OTSCs into EOPs
[Emergency Operating Procedures],
EPs (Emergency Procedures],
and ONOPs [Off Normal Operating Procedure] within eight hours of approval.
Contrary to the above, on January 10,
- 1988, OTSC 5676 was approved to ONOP 0208. 11, an annunciator response procedure, and as of January 13, 1988, it had not been entered into the ONOP.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Florida Power and Light Company is hereby required to submit to this office within 30 days of the date of the letter transmitting this Notice a written statement or explanation in reply including (for each violation):
(1) admission or denial of the violation, (2)'he reason for the violation if admitted, (3) the corrective steps which have been taken and the results
- achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved.
Where good cause is shown, consideration will be given to extending the response time.
FOR THE NUCLEAR REGULATORY COMMISSION Lui s A. Reyes, Director Division of Reactor Projects Dated at Atlanta, Georgia this 18th day of March, 1988 R