ML17347B258

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Insp Repts 50-250/89-27 & 50-251/89-27 on 890527-0630. Violations Noted.Major Areas Inspected:Monthly Surveillance & Maint Observations,Esf Walkdowns,Operational Safety,Plant Events & Unit 3 Startup from Outage
ML17347B258
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 07/28/1989
From: Butcher R, Crlenjak R, Mcelhinney T, Schnebli G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML17347B256 List:
References
50-250-89-27, 50-251-89-27, NUDOCS 8908180037
Download: ML17347B258 (36)


See also: IR 05000250/1989027

Text

~p,S RECy

(4

Pp

Cy

0O

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTAST., N.W.

ATLANTAIGEORGIA 30323

Report Nos.:

50-250/89-27

and 50-251/89-27

Licensee:

Florida

Power

and Light Company

9250 West Flagler Street

Miami,

FL

33102

Docket Nos.:

50-250

and 50-251

Facility Name:

Turkey Point

3 and

4

License Nos.:

DPR-31

and

DPR-41

Inspection

Conducte

ay

- June

30,

1989

Inspec

~c.P

R.

C.

che

,

nio

Resident

Inspector

T.

F.

Mc

n

y,

eside

Inspector

G. A.

S

bli, Reside

Inspector

Approved by:

R.

.

C

enjak,

S

ion Chi

Division of Reactor Projects

7- Zc-

-89'ate

Signed

7'- zc A

Date Signed

7- zc

-Zci'ate

Signed

te

gned

SUMMARY

Scope:

This routine resident

inspector

inspection entailed direct inspection at the

site

in the

areas

of monthly surveillance

observations,

monthly maintenance

observations,

engineered

safety features

walkdowns, operational

safety,

plant

events,

Unit

3 startup

from an

outage,

Unit 4 startup

from refueling,

and

installation

and testing of modifications.

Results;

Both Units

3 and

4 were taken critical and put on line during this inspection

period.

Also, Unit 4

was

taken off line,

due to

a

TPCW leak wetting the

generator

exciter,

and

then

returned

to

power.

All manipulations

were

accomplished

in

a deliberate

and controlled

manner.

Operations

exhibited

a

professional

attitude in controlling the operation of the plant.

Two violations were identified:

PORV opening

time exceeded

the

OMS safety evaluation limit of 2 seconds.

(Paragraph

2)

8908i 80037 890803

PDR

ADOCK 05000250

8

PNU

Installation of an erroneous

label

p'1ate

on the Unit 3 safety injection

bl ock switch.

(Para'gr aph 9)

One non-cited violation was identified which involved failure to identify an

outstanding

clearance

affecting auxiliary" feedwater flow to the

C

steam

generator.

(Paragraph

2)

One

Inspector

Followup

Item was identified regarding

minor procedural

and

drawing discrepancies.

(Paragraph

8)

REPORT

DETAILS

Persons

Contacted

Licensee

Employees

J.

W Anderson, guality Assurance

Supervisor

J. Arias, Assistant

to,. Plant Manager

  • L. W. Bladow, Plant guality Assurance

Superintendent

  • J.

E. Cross,

Plant Manager-Nuclear

  • T. A. Dillard, Maintenance

Manager

  • R. J. Earl, guality Control Supervisor

T. A. Finn, Training Supervisor

S. T. Hale, Engineering Project Supervisor

  • K. N. Harris, Vice President
  • D. W. Herrin, Regulatory

Compliance

Engineer

  • J. P. Hendrickson,

Reactor

Engineer

  • R. J. Gianfrencesco,

Maintenance

Superintendent

V. A. Kaminskas,

Technical

Department Supervisor

J.

A. Labarraque,,

Senior Technical Advisor

  • E. Lyons, Acting Regulatory

and Compliance Supervisor

  • F. G. Mahler, Services

Manager

R.

G.

Mende, Operations

Supervisor

  • L. W. Pearce,

Operations

Superintendent

J.

C. Strong,

Mechanical

Department Supervisor

J.

D. Webb, Operations - Maintenance

Coordinator

  • A. J. Zielonka, Site Engineering

Group Supervisor

Other

licensee

employees

contacted

included

construction

craftsman,

engineers,

technicians,

operators,

mechanics,

and electricians.

  • Attended exit interview on June

30,

1989

Note:

An Alphabetical Tabulation of acronyms

used in this report is

listed in paragraph

13.

Actions on Previous

Inspection

Findings

(92702)

A review

was

conducted

of the following noncompliances

to assure

that

corrective actions

were adequately

implemented

and resulted

in conformance

with regulatory

requirements.

Verification of corrective

action

was

achieved

through record reviews, observation

and discussions

with licensee

personnel.

Licensee

correspondence

was

evaluated

to ensure

that

the

responses

were timely and that corrective actions

were implemented within

the time periods specified in the reply.

(Closed)

URI

50-250,251/87-44-02,

Review

Revisions

to

AP 0103.2

as

Required

by

NRC and the Licensee's.MOS

Program.

The required

changes

were

made to the subject

procedure

and the requirements

of the

MOS program have

been lifted after

NRC review.

This item is closed.

(Closed)

URI 50-250,251/88-26-01,

Review Licensee's

Evaluation of the

Effect of

PORV Opening

Time on the Operability of the

OMS During Previous

Shutdowns;

The licensee

issued

a safety evaluation,

JPN-PTN-SEMJ-88-076,

revision 1,

on February

17,

1989, which analyzed

the

PORV maximum stroke

times.

This evaluation

concluded that with a tested

stroke time less

than

or equal

to 3.45 seconds,

one

PORV can safely mitigate the most limiting

pressure

transient.

A review of the licensee's

IST Program for the

PORVs

revealed

that the opening stroke times

exceeded

the 3.45

second limit on

numerous

occasions.

Therefore, if the plant experienced

the most limiting

pressure

transient

and

the

PORV opening

times

were greater

than

3.45

seconds,

the

10 CFR 50,

Appendix

G limits would

have

been

exceeded.

10 CFR 50,

Appendix

8, Criterion III, as

implemented

by the

approved

Florida Power and Light Company Topical Quality Assurance

Report

(FPLTQAR)

1-76A,

Revision

11, Topical Quality Requirement

(TQR) 3.0,

Revision 7,

requires that measures

be established

to assure

that applicable regulatory

requirements

and

the

design

basis

are

correctly

translated

into

specifications,

drawings,

procedures,

and instructions.

Contrary to the above,

the 2.0 second

PORV opening

time specified in the

Overpressure

Mitigating System,

Safety Evaluation

Report dated

March 14,

1980,

was

not incorporated

into the licensee's

IST Program.

Instead,

a

non-conservative

acceptance

criteria of 15.0 seconds

was used.

This could

have resulted

in the Unit 3 and

4

PORVs being unable to mitigate the most

limiting design

basis

transient

for

low

temperature

overpressure

protection,

had this transient

occurred.

This condition

existed

on

several

occasions

from

May 1984

through

June

1988.

This

item is

identified

as

Violation 50-250,251/89-27-01.

Therefore,

URI 50-250,

251/88-26-01

is closed.

(Closed)

URI 50-250,251/89-24-04,

Determine

the

Cause

of Inadequate

Clearance

Control during

AFW Testing.

With Unit 3 in Mode

5 and Unit 4 'in Mode 2, the licensee

declared

the Unit

4 Train

1

AFW out-of-service.

The licensee

had determined that instrument

air supply check valves

(4-40-813

and 815) for flow control valves

(FCV)

4-2817

and

4-2818,

respectively,

were

backleaking.

Technical Specification 3.18 specifies

that in Modes 1,

2 or 3, with one of the two

required

independent

AFW trains inoperable,

either restore

the inoperable

train to an operable status'within

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />,

or place the affected unit(s)

in at least

hot standby within the next six hours

and in hot shutdown

within the following six hours.

Since Unit 4 was in Mode 2, it entered

the

TS 72-hour Action Statement.

The licensee

repaired

the valves

and

commenced

testing later that night.

The test

was

completed;

however,

FCV 4-2818 did not pass

the test.

I&C worked on the valve and

on May 22,

1989, the Unit 4 Train

1

AFW operability test

was performed again.

During

the test,

operators

noted that the

C Steam Generator

was not receiving

AFW

flow.

The operators

secured

from the test.

Investigation of this event revealed

that stop valve (4-20-341) to steam

generator

C

from the

AFW

pump

was

closed

under

clearance

order

4-89-05-149,

thus

preventing

the

C steam

generator

from receiving

feed

flow during the

performance

of surveillance

procedure

4-0SP-075.1,'AFW

Train

1 Operability Verification.

Review by the licensee

revealed

that

the Train

1

AFW control valve 4-2818

was listed in the

Equipment

Out of

Service

Log sheet.

Also another

clearance

existed at this time for the

Train

1

AFW flow control valve filters and

instrument air check valves

(clearance

number 4-89-05-154).

When the operators

were verifying proper

AFW system

alignment prior to testing, this clearance

was lifted.

How-

ever,

the operators

did not identify the other

remaining

clearance

on

Train 1'FW.

The test

was

subsequently

performed sucessfully

and

AFW

train

1

was

returned

to serv'ice

prior to the expiration of the 72-hour

Action Statement.

3.

The root

cause

was attributed to personnel

error

and is considered

an

isolated event.

The licensee

counseled

the operator regarding

the circum-

stances

of this event.

TS 6.8. 1 requires

that written procedures

and

administrative

policies shall

be established,

implemented

and maintained

that meet or exceed

the requirements

and recommendations

of Section

5. 1 of

ANSI

N18. 7-1972.

ANSI

N18. 7-1972,

Sec tion

5.1. 2,

speci fi es

that

procedures

shall

be followed.

Surveillance

Procedure

4-OSP-075. 1,

AFW

Train

1 Operability Verification, dated

March

29,

1989,

Section

3.2,

required

that

the

AFW system

be aligned

in normal

standby

service

per

Operating

Procedure

4-0P-075, Auxiliary Feedwater

System.

Attachment

1

to

Operation

Procedure

4-0P-075,

dated

March 24,

1989,

requires

that

valve

4-20-341

be

locked

open for normal

AFW system

operation.

Contrary to the above,

valve 4-20-341

was found closed during

the

performance

of 4-OSP-075.

1 on

May 22,

1989, which prevented

AFW flow

to the

C steam

generator.

However, this violation is not being cited

because

criteria specified

in Section

V.A of the

NRC Enforcement

Policy

were satisfied.

This

item is identified

as

Non-Cited Violatiop

(NCV)

50-250,251/89-27-02.

Followup on Inspector

Followup Items (92701).

(Closed)

IFI 50-250,251/89-24-05,

Resolution of the Failure. of MOV-4-751.

This item is discussed

in detail in paragraph.6.a.

This item is closed.

4.'nsite

Followup

and In-Office Review of Written Reports

of Nonroutine

Events

and

10 CFR Part 21 reviews

(92700/90712/90713).

The Licensee

Event

Reports

(LERs)

and

10 CFR Part 21 Reports

discussed

below were

reviewed

and closed.

The inspectors

verified that reporting

requirements

had

been

met, root cause

analysis

was performed,

corrective

actions

appeared

appropriate,

and

generic

applicability

had

been

considered.

Additionally, the inspectors

verified that the licensee

had

reviewed

each

event,

corrective actions

were

implemented,

responsibility

for corrective actions

not fully completed

was clearly assigned,

safety

questions

had

been

evaluated

and resolved,

and violations of regulations

or

TS conditions

had

been identified.

When applicable,

the criteria of

10 CFR 2, Appendix C, were applied.

(Closed)

LER 50-250/86-41,

RHR

Pumps

Not in Operation

as

Required

by

Techni ca 1

Speci ficati ons.

The

inspectors

revi ewed

the

compl eted

corrective actions

and found them acceptable.

This item is closed.

(Closed)

LER 50-250/87-23,

Safety Injection

and

Reactor Trip due to

a

Failed

High Steam

Flow Instrument.

The corrective actions

taken,

as

a

result of this event,

were reviewed

and found to be adequate.

This item

is closed.

(Ref. Inspection

Report 50-250/87-39)

(Closed)

LER 50-250/87-33,

Reactor

Trip During Controlled

Shutdown

When

Source

Range

High Neutron

Flux Trip Unblocked.

The inspectors

reviewed

the completed corrective actions

and found them acceptable.

This item is

closed.

(Ref. Inspection

Report 50-250/87-51)

(Closed)

LER 50-250/88-09,

guality Assurance

Discovered

Missed Technical

Specification

Surveillances

for Station Battery Pilot Cell

Rotation

and

EDG

Fuel Oil Sampling Analysis.

The inspectors

reviewed

the

completed

corrective actions for these

items

and found

them acceptable.

This item

is closed.

(Closed)

LER 50-250/88-22,

Diesel

Generators

Inoperable

Due to Planned

Maintenance

and

Fuel Filter Flow Restriction.

The inspectors

opened

Inspector

Followup Item 50-250/88-30-01

to track the licensee's

corrective

actions.

This item is closed.

(Closed)

LER 50-251/87-13,

Failure of the

480 Volt Undervoltage

Relay.

The corrective actions required,

as

a result of the failure, were reviewed

and found to be adequate.

This item is closed.

(Closed)

LER 50-251/87-'6,

Failure of 4A ICW Pump Causing

Auto Start of 4C

ICW Pump.

The corrective actions

taken,

as

a result of the failure, were

reviewed

and found to be adequate.

This item is closed.

(Closed)

LER 50-251/87-26,

Auto Start of 4B

CCW Pump when Returning

4C

CCW

Pump to Service.

The corrective actions required, for this event,

were

reviewed

and found to be adequate.

This item is closed.

(Closed)

LER 50-251/87-27,

Failure to Estimate

Steam

Generator

Blowdown

Flow Rate.

The corrective actions specified in this

LER were reviewed

and

found to be adequate.

This item is closed.

(Closed)

P2185-01,

" Potential

Problem

with

Pipe

Clamps

during

Installation.

Licensee

review of the subject

pipe clamps identified and

determined

that

they

were

purchased

for the

St.

Lucie Plant

and

no

purchase

orders for Turkey Point could be located.

However, the licensee

stated

that current

ISI

procedures

regarding

visual

examination

were

sufficient to detect this problem and discrepancies

would be corrected,

as

required.

This item is closed.

Monthly Surveillance

Observations

(61726)

The

inspectors

observed

TS required surveillance

testing

and verified,

that the test

procedures

conformed to the requirements

of the TS, testing

was performed'n

accordance

with these

procedures,

and that the test

instrumentation

required to perform the tests

was calibrated.

In addition,

the

inspectors

verified that

the test results

met acceptance

criteria

requirements,

were

properly

reviewed

by

personnel

other

than

those

directing

the test,

deficiencies

identified were properly reviewed

and

resolved

by management

personnel

and that system restoration

was adequate.

For completed tests,

the inspectors verified that testing frequencies

were

met and tests

were performed

by qualified individuals.

The

inspectors

witnessed/reviewed

portions

of

the

following test

activities:

0-0SP-16.26,

Electric Driven Fire

Pump Operability Test.

O-NCZP-030,

Component

Cooling Water Sampling.

4-0SP-200.3,

Section 7.2,

Main Turbine Trips Test.

4-OSP-089. 1, Turbine Generator

Overspeed

Trip Test.

O-OSP-062.2,

3B Safety Injection

Pump Inservice Test.

3-0SP-075.2,

Auxiliary Feedwater

Train

2 Operability

Verification.

OP-4004.2,

Safeguard

Relay Rack Train A,

B - Periodic Test

on

Unit 4.

3-SMI-071.5,

Steam Generator

Protection

Set III (gR-18) Analog

Channel

Test.

0-OSP-023. 1, Diesel

Generator Operability Test.

On June

24,

1989,

the operators

performed 3-0SP-075.2,

to test the Unit 3

AFW System Train 2.

- The

B and

C AFW pumps are normally aligned for Train

2 Service.

The

B

AFW pump was tested satisfactorily,

however, during the

C

pump test,

the governor oil level

was low in the sightglass.

Further

investigation

revealed

an oil leak existed

at

a governor

housing

plug.

The

C

AFW pump was declared

OOS due to the oil leak.

Unit 3 was in Mode

2

at the time

and

was

preparing

to

go

on line.

Technical

Specification

3. 18, Auxiliary Feedwater

System

requires

that

two trains of

AFW be

operable

while in Modes 1,,

2 or 3.

This section

also allows the third

AFW pump to be

00S for 30 days

and that

TS 3.0.4 is not applicable to the

third

pump (i.e.,

Unit

3

could

change

modes

with the third

pump

inoperable).

Since

the

A and

B

pumps

were aligned to train

1

and

2,

respectively,

the provisions of TS 3. 18 were met.

Unit 3 was

placed

on

line later

that

day.

The

C AFW

pump

was

repaired

and

tested

satisfactorily

on June

27,

1989,

which

ended= the Limiting Condition for

Operation

(LCO).

0

Most of the surveillances

witnessed

during this inspection

period

were

conducted

to support

the Units

3

and

4 startups.

The inspectors

noted

that test

personnel

performed

the tests

in

a controlled,

deliberate

manner.

The tests

were completed without major discrepancies,

and minor

discrepancies

were adequately

resolved

in accordance

with administrative

controls.

No violations or deviations

were identified in the areas

inspected.

6.

Monthly Maintenance

Observations

(62703)

Station

maintenance

activities

on safety related

systems

and

components

were

observed

and

reviewed

to ascertain

that

they were

conducted

in

accordance

with approved

procedures,

regulatory guides,

industry codes

and

standards,

and in conformance with 'TS.

The following items

were considered

during this review,

as appropriate:

That

LCOs were met while components

or systems

were removed

from service;

=

approvals

were

obtained

prior to initiating work; activities

were

accomplished

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

were

performed prior to returning

components

or'ystems

to service;

gC records

were maintained;

activities

were

accomplished

by qualified personnel;

parts

and materials

used

were properly certified; radiological controls

were properly

implemented;

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 that housekeeping

was actively pursued.

The

inspectors

witnessed/reviewed

portions of the following maintenance

activities in progress:

Troubleshooting

Cranking Diesel

No. 2.

Would not synchronize

on

line.

Repair

of MOV-3-750,

MOV-3-751,

MOV-4-750

and

MOV-4-751 to

eliminate pressure

binding.

(See discussion

below).

Repair of CV-3-2821 for excessive

seat

leakage.

Repair of Unit 4 Flux Mapper Assemblies.

Repair of Unit 4 High Pressure

Turbine Cylinder Heating

Steam

Leak.

Replacement

of 3A RHR Pump Mechanical

Seal.

The modifications to MOV-750 and

751

on Units

3 and

4 were previously

discussed

in Inspection

Report

50-250,251/89-24

and identified

as

IFI

89-24-05.

The

licensee

performed

testing

on

the Unit 4 valves

and

determined that. the binding of the valves

was

caused

by pressure

trapped

between

the

discs

of the

valve.

The testing

was

accomplished

by

increasing

the pressure

between

the valve discs using

a test

pump and then

performing

MOVATS testing

on the actuator

which showed that

as

pressure

was

increased

between

the discs,

the pull out torque

or thrust

also

increased.

This

phenomenon

was previously discussed

in

INPO

SOER 84-07

which

was

evaluated

by the licensee

and

EBASCO in several

letters

and

documents

(JPE-PTP0-87-836,

PTP-87-120,

JPE-PTPO-87-1521

and

REA-TPN-85-39) in mid 1987.

The correspondence

identified the valves

in

the plant,

that could

be subjected

to thermal

or pressure

binding

and

provided

several

methods

to correct

the

problem, if required.

The

licensee

concluded,

in JPE-PTP0-87-1521,

that the identified valves did

not present

an operability concern.

Their conclusion is based

on existing

plant

procedures

that demonstrate

valve operability

by periodic cycling

and

a lack of reported failures

due to thermal or pressure

binding.

Since

this fai lure

was directly attributed

to pressure

binding,

the licensee

implemented

PC/M 89-373 for Unit 4 and

PC/M 89-375 for Unit 3.

These

PC/Ms installed

bonnet equalizing

lines

from the bonnets

of MOV-750 and

751 for both units

through

the existing

packing leak-off lines to

a

connection

upstream of the subject valve.

This would allow any pressure

trapped

between

the discs

to

be vented to the upstream

side of the valve

and thus eliminate the effects of pressure

binding.

Testing

was conducted

after installation .of the

PC/Ms

which verified the modification did

eliminate

the

pressure

binding effect experienced

in these

valves.

The

licensee

also

evaluated

the other valves identified

as

a result of the

SOER

and

determined

that

due

to lack of failure history

and

valve

application

that

no further corrective action

was required at present.

The

residents

discussed

this

issue

with the

Region

and

due

to the

potential

generic

application

the

Region is currently considering

the

issuance

of an Information Notice.

The licensee notified the industry of

the failure

and

cause

via Operating

Plant

Experience

Report,

OE 3376,

dated

June 2,

1989.

No violations or deviations

were identified in the areas

inspected.

Operational

Safety Verification (71707)

The inspectors

observed

control

room operations,

reviewed applicable logs,

conducted

discussions

with control

room

operators,

observed

shift

turnovers

and confirmed operability of instrumentation.

The inspectors

verified the 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,

verified compliance with TS

LCOs

and verified the return

to service of affected

components.

In addition,

by observation

and direct interviews, the inspectors verified

that the physical security plan was being implemented.

Plant

housekeeping

and implementation

of radiological controls were'lso

observed.

The inspectors

found the cleanliness

conditions in the plant

and the implementation of radiological controls to be satisfactory.

Tours of the intake structure

and diesel, auxiliary, control

and turbine

buildings

were

conducted

by the

inspectors

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 Water Structure

'160

Volt Buses

and

480 Volt Load and Motor Control Centers

Unit 3 and

4 Feedwater

Platforms

Unit 3 and

4 Condensate

Storage

Tank Area

Auxiliary Feedwater

Area

Unit 3 and

4 Main Steam Platforms

Auxiliary Building

The inspectors

also

reviewed

the licensee's

administrative

program for

ensuring

that

a

licensed

operator

that fails

his

requalification

examination

is

removed

from licensed

duties.

Administrative Procedure

0301,

Licensed

Operator

Requalification

Program,

provides

for the

administrative

controls in this area.

Step 8.4.2.2.

requires

that

any

individual that fails

the requalification

examination

be

placed

in

a

remedial training program until the responsible

supervisors

are satisfied

that

the

individual

is

again

proficient.

Proficiency

shall

be

demonstrated

by passing

another

examination.

When an individual fails the

examination,

the Training Department

sends

a memorandum to the Operations

Supervisor

informing

him that

the

individual failed to

complete

the

requalification requirements

and is to be relieved of all licensed duties

effective immediately.

At this time the individual is removed

from the

watch bill and is not allowed to assume

the watch until requalification

requirements

have

been

successfully

met.

When the individual is again

deemed proficient the Training'epartment

sends

another

memorandum to the

'Operations

Supervisor

informing him that the individual

may again

assume

licensed duties.

At this time the individual is placed

back

on the watch

bill.

In this inspection

the inspectors

reviewed

AP 0301,

memorandum

removing

and

reinstating

individuals,

and

held

discussions

with

responsible

Training

and Operations

Department

personnel.

In the past,

the

inspectors

have

personally

witnessed

the

removal

of

a

licensed

individual

from licensed

duties

due to failure of 'a requalification

examination.

~

No violations or deviations

were identified in the areas

inspected.

Installation

and Testing of Modifications (37828)

a 0

The

inspectors

reviewed

PC/M 88-535,

Pressurizer

PORY Air a'nd

Nitrogen Supply Tubing Enhancement,

Revision 4, Supplement

3.

Recent

PORV stroke

time measurements

had revealed

that opening times, for

both instrument air and nitrogen

sources,

were

not within the

two

second

opening

time requirement

stated

in the

OMS design analysis.

This

issue

was

discussed

in Inspection

Report

88-26

and is being

followed up as Violation 50-250,251/89-27-01

as noted in paragraph

2

of .this report.

The inspectors

observed

the installation of various

components

and

determined

that

proper

preoperational

testing

was

performed.

The

preoperational

test procedures

were reviewed for proper setpoints

and

to insure that test results

met the test criteria.

The modification

package

and

procedures

were controlled

in accordance

with licensee

administrative

procedures.

Drawings

were

updated

to reflect the

modification except

as noted:

4-0P-041.2,

Pressurizer

Operation,

dated

5/10/89,

attachment

2,

page

4 of 4, lists

4-40-240

and

4-40-250 nitrogen cylinder

isolation

valves

as

open.

Drawing

5610-M-339,

Auxiliary

Feedwater,

MSIV and

Pressurizer

PORY Nitrogen

Backup

Supply

Systems,

Revision 39,

does

not show the noted valves.

4-0SP-041.4,

Overpressure

Mitigating System Nitrogen Backup Leak

and Functional Test,

dated 5/2/89, refers to valves

4-40-240

and

4-40-250.

These

valves,

as

noted

above,

are

not

shown

on

drawing 5610-M-339.

b.

The

inspectors

reviewed

PC/M 88-245,

Main

Steam

Isolation

Valve

(MSIV) Air Accumulator

System,

revision dated October

13,

1988.

The

purpose

of this modification

was to provide safety

related air

accumulators

capable

of closing

each

MSIV in five seconds

or less.

This modification ensured

that the

MSIV can

be maintained

closed for

one

hour before operator

action outside

the control

room would

be

required.

The inspectors

witnessed

various

stages

of installation

and testing

to verify that the appropriate

work controls

were

being followed.

The following preoperational

tests

were witnessed/reviewed

by the

inspectors:

POP

0800.212,

Unit 4

MSIV Air Accumulator

Backup

System

Cold

Test.

POP

0800.213,

Unit 4

MSIV Air Accumulator

Backup

System

Hot

Test.

The inspectors

performed

a walkdown of the

system

using appropriate

drawings

and procedures

to verify that:

Major system

components

were properly labeled.

10

Instrumentation

was properly installed, functional,

and process

parameter

values

normal.

Valves in the

system

were aligned in the correct position for

normal operation.

Drawings

and

procedures

reflected

the

proper

system

configuration.

The documentation

reviewed included:

4-0P-072,,Main

Steam

System,

dated April 28.

1989.

4-0P-013,

Instrument Air System,

dated April 6,

1989.

Drawing

5610-M-735,

MSIV Air Operator

and Air Accumulator

Back-up System

POV-4-2604,2605,2606,

Unit 4, Revision 0.

Drawing

5610-T.-E-4061,

Sheet

5,

MSIV Air Operator

and Air

Accumulator Back-up System.POV-4-2604,

2605,

2606,

Revision 0.

The inspectors

noted the following discrepancy:

4-0P-013,

Attachment

1,

page

58,

had the operator verify the

position of valve 4-40-2166,

Instrument Air to MSIY POV-4-2604,

2605,

and

2606 Isolation,

two times.

One time to verify the

valve to

be

open,

the other to verify the valve closed.

The

normal

system alignment required the valve to be open.

c.

The inspectors

reviewed

the Unit 4 High'ensity

Spent

Fuel

Rack

Project,

as outlined in Procedure

No. FPL-0113-P-l,

Revision

1.

The

following procedures

were reviewed:

FPL-0113-P-l,

Rev.

1

Project

Administrative

Procedure

for

High Density

Spent

Fuel

Rack Project

(HDSFRP).

FPL-0113-P-2,

Rev.

1

Rack removal for HDSFRP.

FPL-0113-P-4,

Rev.

1

Hydrolasing for HDSFRP.

FPL-0113-P-5,

Rev.

1

Underwater

Vacuuming for

HDSFRP.

FPL-0113-P-7,

Rev.

1

Drag Test for HDSFRP.

FPL-0113-P-8,

Rev.

1

Housekeeping

Procedure for HDSFRP.

Topics for possible

enhancements

to the

procedures

were discussed

wi,th appropriate

licensing personnel.

t

11

The inspectors

observed

various

rack manipulations

both outside

and

inside the Spent

Fuel Building.

On June

19,

1989, while the licensee

was

attempting

to lower old rack

No. 3, to the ground,

the nylon

strap rigging failed and the rack dropped

a small distance

to the

ground.

Personnel

in the

area

immediately

secured

the operation,

sealed

the

area off and took prompt actions

to survey the area for

any possible

contamination.

There

was

no contamination,

or injuries

due to the

dropped

rack.

The licensee

immediately

began

a lessons

learned

review and

by the

end of the week were ready to make their

recommendations

to management

to preclude similar incidents.

During

the inspectors

observations,

various incidents of lack of attention

to detail

were

noted to the licensee.

The licensee

took positive

steps

to prevent recurrence.

By the end of June

23,

1989,

old rack

No.

3 was

boxed

and

on

a flat bed truck ready for shipment.

Old rack

No.

4 was

moved into old rack No.

3 position in the Spent

Fuel Pool,

ready to be hydrolased

and removed.

New rack No.

4 has

been

Dry Drag

tested

and the rigging installed,

ready to

be put in the pool.

The

inspectors

also

reviewed

various

Daily Project Status

Reports,

as

required

by Project Administrative Procedure,

FPL-0113-P-1.

Correction of the

noted discrepancies

in items

8a.

and

b.

above

by the

licensee will be followed as Inspector

Followup Item 50-250,251/89-27-03.

No violations or deviations

were identified.

9.

Followup on Onsite

Events

(93702)

The following plant events

were reviewed to determine facility status

and

the

need for further followup action.

Plant parameters

were evaluated

and

the significance of the event

was evaluated

along with the performance

of

the appropriate

safety

systems

and the actions

taken

by the licensee.

The

inspectors

verified that required notifications

were

made

to the

NRC.

Evaluations

were

performed

relative

to the

need for additional

NRC

response

to the event.

Additionally, the following issues

were examined,

as

appropriate:

details

regarding

the

cause

of the

event;

event

chronology;

safety

system

performance;

licensee

compliance with approved

procedures;

radiological

consequences,

if any;

and

proposed

corrective

actions.

On June

12,

1989, with Unit 3 in Mode 5,

RCS

leakage

was

noted during

system fill and vent.

Investigation

by the licensee

revealed

RVS-200,

Reactor

Coolant Vent System drain valve,

was approximately

one half turn

open.

This valve was required to be closed during the fill and vent.

The

valve had

a hose attached

which ran to

a floor drain.

The. floor drain

had

overflowed.

The valve

was

closed

and the fill and vent

was completed.

The

licensee

could not determine

how the valve

was

opened.

The site

guality Assurance

Performance

Monitoring Section

reviewed the incident and

issued

a

summary

on

June

20,

1989,

(gAO-PTN-89-993).

The corrective

actions

for this event

were to change

the fi11

and vent

procedures

to

include verification of valve

RYS-200 to be closed if it is not used

as

a

vent path.

Also,

a verification of blank flanges

and caps

was being

added

12

to post alignment checks.

This step

was already in the process

of being

incorporated

at the time'f this event.

This

was part of corrective

actions

to

a similar event for Unit

4

on

March 9,

1989.

This event

.resulted

in

a Violation 50-250,251/89-12-03.

This item is still open

and

the completed corrective actions will be reviewed to determine if they are

adequate

to prevent recurrence.

On June

16,

1989, at

11: 15 a.m., with Unit 3 in Mode 5; PRMS rack 66 was

de-energized

causing

process

radiation

monitors

R-11

and

R-12 to trip

resulting

in

Containment

Isolation

on Unit

3

and

the

Control

Room

Ventilation System to automatically shif't to the Recirculation

Mode.

All

equipment

functioned

as

required

and

the licensee

notified the

NRC in

accordance

with

10 CFR 50.72(b)(2)(ii).

The

event

occurred

when

ILC

personnel

were troubleshooting

the pressurizer

safety

valve acoustical

monitoring circuitry using

an oscilloscope.

The oscilloscope

was plugged

into

a vital

AC outlet in the bottom of rack

67 and

when the

scope

was

turned

on it caused

breaker

3P08-19 to trip which de-energized

R-Il and

R-12.

The licensee

is taking the following actions to prevent recurrence;

( 1) clearly identify, by labeling, all vital AC power feeds

and electrical

receptacles;

(2) install protective

covers

over the vital

AC receptacles

(3) require

personnel

to obtain

permission

from control

room personnel

prior to

using

unidentified

power

feeds

and electrical

receptacles;

(4) determine if the electrical

loading

on the breaker

is close to its

trip setpoint

as

the oscilloscope

only

draws

about

two

amps

and

was

checked to be functioning properly.

On

June

16,

1989, at 9:49 p.m., with Unit

3 in

Mode 5,

an inadvertent

Train "B" safeguards

actuation

occurred while re-energizing

the safeguards

relay

racks

after

maintenance

in

accordance

with

3-ONOP-049.

All

equipment

functioned

as

expected

and

was verified using

3-EOP-E.O.

The

licensee notified the

NRC of the event

as required

10 CFR 50.72(b)(2)(ii ).

Initial troubleshooting

indicated

the pushbutton for relay 3SIB-2, manual

safety injection block pushbutton,

failed to remain inserted

which caused

the actuation

when the pushbutton

was released.

The

ISC Department

found

a

cracked

wafer in the contact

block which

was

replaced.

On

June

17,

1989, at 4: 13 p.m.,

the

same

event occurred while re-energizing

the Train

"A" safeguards

relay racks.

Again, all equipment

functioned

as expected

and

the

NRC

was notified.

Licensee

investigation

into the occurrence

indicated

the

SI

Block Switch

was mislabeled

in that the "Block" and

"Unblock" positions were reversed.

The licensee

obtained

a picture of the

switch and the general

area of that portion of the control

room panel that

clearly

shows

the

switch labeling opposite

to that at present.

The

picture

was

made in March of 1989 by simulator personnel

for training and

simulator validation use,

which indicated

the labeling

had

been

changed

between

March

and

June of this year.

The licensee's

investigation into

the

issue

identified that the

person installing the

new label

did not

verify that the switch positions

were the

same

as the positions

on the

label

to

be

removed.

TS 6.8.1

requires

that written 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 Sections

5. 1 and 5.3 of ANSI N18.7-1972.

13

O-ADM-209, Equipment

Tagging

and Labeling, provides the responsibilities,

precautions,

limitations

and instructional

guidance for establishing

and

maintaining

an accurate,

complete

and effective plant tagging

program.

Contrary to the above,

engraved

label

plates

were replaced

on the Unit 3

Safety

Injection

Block

Switch without following the

requirements

of

O-ADM-209, resulting in two separate

safeguard

actuations within a

24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

period.

This is identified as Violation 50-250,251/89-27-04.

On June

17,

1989, with Unit 4 at approximately

30% power, the

RCO received

a

Generator

Field

Brush

Contact

Failure/Ground

annunciator

alarm.

Inspection of the generator exciter revealed

a Turbine Plant Cooling- Water,

(TPCW) leak.

The leak

was located

on

a copper tubing drain line from the

exciter

D air cooler.

The

operators

commenced

a

load reduction at

5:32 a.m.

and

took

the unit off line at

5:52 a.m..

The

licensee

determined

that the tubing failure was

due to the tube vibrating against

the clamps.

The defective tubing was replaced

and

a protective sleeve

was

installed to protect the tube.

The Unit 3 exciter cooler drain lines are

stainless

steel,

therefore,

they

are

less

susceptible

to this failure

mode.

The

licensee

plans

to replace

the

copper tubing with stainless

steel

during

an outage of sufficient duration.

The licensee

dried and

megger

tested

the exciter.

Unit 4 was returned to service

on June

18,

1989.

10.

Followup on Licensee

Employee

Concerns

(RII-88-A-0066)

The

inspectors-

reviewed

the following licensee

employee

concerns

which

resulted

from

NRC interviews.

The concerns

are described

below with their

disposition.

a

~

A

concern

was

raised

involving configuration

of electrical

penetration

cannisters.

Each cannister

has

a nitrogen fill line

which is provided to maint'ain the cannister

from 15 to 19 psig.

The

cannisters

are

pressurized

with nitrogen

to verify cannister

integrity for the

LLRT and the ILRT, and also to maintain

a moisture

free environment.

On June ll, 1986,

NCR 86-293

was written.

The

problem described

was that the

gauges

used

to monitor the cannister

nitrogen pressure

did not appear

on any prints or on the g-list.

The

NCR disposition

stated

that the

gauges

could

be

used

as is.

The

cannisters

are

checked

by the Electrical

Maintenance

Department

during quarterly preventive

maintenance

per

MI 51003

and

51004 for

Units

3 and 4, respectively.

If the pressure

is found less

than

15

psig,

the Technical

Department

is notified to implement repair

and

perform

a

LLRT. The

gauges

are not calibrated

since

the pressure

is

checked

during the

LLRT with calibrated

gauges.

The

NCR also stated

that

the cannisters

are

provided with an isolation valve located

between

the cannister

and pressure

gauge.

This valve is maintained

closed except

when monitoring nitrogen pressures.

The inspectors

walked

down electrical

penetrations

for Units

3 and

4

using

drawing

5610-E-54A-1,

sheet

1, revision

1.

The inspectors

noted that the drawing did not match

the field installation in that

14

the

gauge

isolation valve

was

not included

on the drawing.

The

inspectors

brought this discrepancy

to the Engineering

Department's

attention.

The licensee

subsequently

performed

a

walkdown which

generated

NCR 89-0237,

on

June

12,

1989.

Another discrepancy

was

identified in that the drawing specified pressure

gauges

have

a range

of 0-100 psig.

The installed

gauges

have

a range of 0-30 psig.

This

item is being adequately

addressed

by., the licensee.

A concern

was raised

involving excessive

AC

hum in NIMS.

This item

was submitted

to the licensees

ECP

on March 30,

1989.

The

NIMS was

installed in May 1984

and

June

1985 for Units

4 and

3 respectively..

Shortly after installing both Units,

NIMS developed

a 120 Hertz noise

contamination.

The systems

were still operable

and could detect

a

2

foot-pound

impact at

3 feet

as originally designed.

The

vendor

suggested

that the noise

contamination

could

be

removed

by lifting

the shield connection of any noisy channel

in the control

room NIMS

rack,

In

October

1986,

a

REA

was

generated

to

address

the

noise

contamination

in both units.

The

REA recognized

that the noise

was

caused

by shield connections

being grounded

on both the control

room

and containment

side of the system.

In August

1987,

the Unit 3 loop ground

was

removed

permanently

by

lifting the shielded

connections

in the containment

and relanding the

control

room connections.

In March 1989,

the

NIMS vendor performed

a system operability check

and

a

system calibration

on Unit 4.

The vendor also

reviewed

the

licensee's

NIMS procedures

to insure

that

the

system

was

being

operated

and maintained

to conform with the original design.

The

Unit 4 loop ground

was

removed

in April of

1989

by lifting the

containment

connections

and

by

relanding

the

control

room

connections.

Subsequent

investigations

revealed

cracked

glass

insulators

on the

accelerometers.

This condition

caused

a ground in the containment

and with the control

room side

grounded,

noise

was still present.

Therefore,

the containment

side will be grounded

and the control

room

connections will be lifted to remove the ground loop.

The incorporation of vendor

recommendations

into plant procedures

and

the

elimination of noise

contamination

should

ensure

reliable

operation

of the

NIMS.

This

concern

was

adequately

addressed

according to

ADM -002,

Employee

Concerns

Reporting

System

Program.

A concern

was raised

that the

PAHMS did not work properly.

This

concern

was submitted to the licensee's

ECP

on March 30,

1989.

The

licensee

formed

a task

team in November

1988 to address

the numerous

LCO hours

due to

PAHMS inoperability.

Discussions

with the equipment

vendor

have

led to corrections

and clarifications

to

OP 0204.2,

15

d.

Periodic

Tests,

Checks,

and

Operating

Evolutions.

The licensee

expects

these corrections'o

reduce

the

number of out of service

hours

on

PAKMS.

Additionally, I&C and the task

team are monitoring

the

performance

of

PAHMS and further corrective

actions will be

initiated, if necessary.

The inspectors

found that this

item was

addressed

satisfactorily by ADM 002.

A concern

was

raised

that

the

PASS did not work properly.

This

concern

was submitted to the licensee's

ECP

on March 30,

1989.

The

licensee

responded

that

since

the

PASS

was

installed

in

1980,

numerous

design

and operational

problems

have

been encountered.

One

by one,

the problems

have

and continue to be corrected.

The chloride

analyzer is the last non-functional

analyzer.

The licensee

plans to

issue

a design

package

which will replace

the chloride analyzer

in

1989.

In the meantime,

the

sample

cask is available for offsite

reactor

coolant chloride analysis.

However,

PASS reliability is

still being evaluated.

Items targeted for further evaluation

include

the oxygen analyzer,

hydrogen analyzer,

flow instruments

and tempera-

ture instruments.

The

PASS is considered

operational

in accordance

with

NRC

requirements.

The

PASS modifications

and

operational

testing is

an ongoing

NRC concern

which is discussed

in Inspection

Report

50-250,251/88-29.

The inspectors, found that this

employee

concern

was addressed

in accordance

with ADM-002.

e.

A concern

was raised that

due to deficient procedures

and drawings,

availability of the

Halon Fire Suppression

System

was questionable.

This concern

was submitted

to the licensee's

ECP

on March 30,

1989.

The trip energy

source for the release

valves is provided

by

a pair

of nitrogen bottles.

Adequate

nitrogen

pressure

is monitored

by

pressure

switches

mounted

on

each bottle.

These

pressure

switches

are calibrated

by the vendor..

One of the problems

noted

was that

during

nitrogen

bottle

replacement

the

pressure

switch

is

decalibrated.

The licensee

determined,

by checking bottle pressures,

that

an operability problem did not exist.

However,

a

REA is being

developed

to resolve

the calibration concern.

The inspectors

found

that

this

employee

concern

was

addressed

by the

licensee

in

accordance

with ADM-002.

A concern

was raised

involving inadequate

reactor trip relay timing

tests.

This

concern

was

submitted

to the licensee's

ECP

and

adequately

addressed

in accordance

with ADM-002.

This concern

was

also

discussed

in

NRC Inspection

Report 50-250,254/89-06,

paragraph

5.

ll.

Generic Letter 88-17 (TI 2515/101)

This TI addresses

the licensee's

short-term

program entitled "Expeditious

Actions" for the

Loss of Decay

Heat

Removal

issue

discussed

in Generic Letter 88-17.

The licensee

responded

to the

NRC recommended

expeditious

actions

in letter

L-88-559

dated

January

3,

1989.

The

licensee

implemented

the

recommendations

of the

Generic

Letter

in

procedure

16

3/4-0P-041.9,

Reduced

Inventory Operations,

which provides instruct'ional

'uidance

for operation of the unit when

RCS level is lower than three feet

below the reactor

vessel

flange with irradiated fuel in the vessel.

The

review of this TI, to assure

the licensee

actions

to prevent

and, if

necessary,

respond

to loss of decay

heat

removal

during operations

with

the

RCS partially drained,

consisted of the following:

a

~

General

b.

The

licensee

completed its response

to the expeditious

actions

in

licensee

letter L-88-559,

dated

January

3,

1989.

The

inspectors

reviewed the subject

response

for implementation

by discussions

with

responsible

licensee

personnel

in operations

and training, review of

the implementing procedure

(3/4-0P-041.9)

and referenced

procedures,

and

a visual

inspection

of the

components

or systems

required for

this

mode of operation.

Training

Turkey Point currently provides training

on

RCS midloop operations

and

recovery

from loss of

RHR for licensed

operators.

Training

topics

presented

since

the fourth quarter of 1988 were

the Diablo

Canyon event,

related

events,

lessons

learned,

the implications of

the

event

and

loss

of

RHR off normal

procedure.

In addition,

licensed operators

received simulator training concerning

loss of RHR

flow at midnozzle

operation.

Prior to operating

in

a

reduced

inventory condition,

Turkey Point will provide training on operation

in a reduced

inventory condition with irradiated fuel in the reactor

vessel.

Procedure

3/4-0P-41.9

requires

that operating

shifts

be

briefed prior to and

as part of shift turnover when operating

the

RCS

in

a reduced

inventory condition.

This briefing shall

include what

equipment,

indications,

and actions

are required to monitor

RCS

and

RHR parameters

during reduced

inventory operation

and recovery from

loss of

RHR.

Available sources

of

RCS

makeup water shall

also

be

discussed.

The inspectors

reviewed

the training briefs discussing

RCS Mid-Loop Operations,

the Diablo Canyon event,

related industry

events

and

the

simulator

training

program for loss

of

RHR

Flow/Cooling.

Procedure

3/4-0P-041.9

contains

prerequisites

for

conducting shift briefings

and

documentation

of attendance

and

content

of the briefing prior to entering

a

reduced

inventory

condition.

c ~

Containment

Closure

Procedure

3/4-0P-041.9

contains

the

requirements

for containment

closure to be established

prior to entering

a reduced

RCS inventory

condition.

Certain

exceptions

are

allowed

by step

3. 16.4 provided

the following requirements

of step 4. 13 are met.

(1)

Containment

closure is not necessary if the Reactor

Vessel

and

surrounding

pool contain

no irradiated fuel.

17

(2)

Containment

penetrations,

including the

equipment

hatch,

may

remain

open

provided closure

is

assured

within two hours of

initial loss of Decay Heat Removal.

(3) If openings totaling greater

than

one

square

inch exist in the

cold legs,

reactor

coolant

pump

connections

to the cold leg

water

space,

or crossover

pipes

of, the

RCS,

then

containment

closure

must be. reasonably

assured

within 30 minutes of initial

loss of Decay Heat Removal.

(4) If a vent path is provided

by removal of the pressurizer

manway.

or

a

S/G

manway,

then

the

30 minute

time requirement

may

be

increased

to two hours.

(5)

Containment

closure activities are to

be initiated upon loss of

RHR for greater

than five minutes

per 3/4-0NOP-050,

Loss of RHR.

(6)

Once containment closure activities are initiated due to loss of

Decay Heat

Removal,

they may not be terminated until controlled

and stable

Decay Heat

Removal

has

been restored

and the

RCS has

been returned to

a controlled

and stable condition.

d.

Temperature

Indication

The existing core exit thermocouples

meet this requirement

when the

reactor

vessel

head

is located

on top of'he reactor

vessel.

the

core exit thermocouples

do not currently provide

an alarm function,

however,

Turkey Point will evaluate

the feasibility of providing this

function.

If an alarm function is not available,

two independent

channels

will

be

monitored

and

recorded

every

15 minutes

when

operating

in

a reduced

inventory condition.

If an alarm function is

available,

two independent

channels will be monitored

and recorded

every

hour

by

an operator

in the control

room while operating

in a

reduced

RCS inventory condition.

The inspectors verified that these

requirements

are

included

in the licensee's

procedure

3/4-0P-041.9,

steps

3.11,

3.17,

4.14,

4.15,

5.2.2.2,

and

Attachment

2 require

logging of the temperatures.

e.

RCS Water Level Indication

Turkey Point currently

has

two methods of RCS level indication.

One

is

a

pressure

transmitter

which provides

level indication to the

control

room.

The other is

a tygon hose located inside containment,

and vented to the pressurizer.

Both indicators

are connected

to the

RCS at the "A" loop intermediate

leg drain.

FPL's engineering

group

has

developed

a correlation

graph

between

indicated intermediate

leg

level

and

actual

hot leg level for use

during

reduced

inventory

conditions.

When in

a

reduced

RCS inventory condition,

the level

transmitter will be monitored

and

recorded

every

15 minutes until

alarm functions

can

be provided.

When alarm functions are provided,

the level transmitter will be monitored

and recorded

every hour.

The

18

licensee will monitor the tygon

hose

and record

the level every

15

minutes

when 'RCS is'in

a reduced

inventory condition.

The operator

monitoring the

tygon

hose will be in communication with and report

each reading'to

the control

room.

These

requirements

are included in

the licensee's

operating

procedure

3/4-0P-041.9,

steps

3. 12,

3. 13.

4.2,

4.10,

4.14,

4.15,

5.1.1.4,

5.1.2.3,

5.2.2.1,

5.2.2.2,

and

Attachment 2, which requires

logging of level indications.

RCS Perturbations

Procedure

3/4-0P-041.9 "includes

a

'general

precaution

in step

4.12

that states:

"When

RCS water level is lower than three feet below the .Reactor

Vessel

Flange, all activities

which

may cause

perturbation of

the

RCS water level including the manipulation of systems

that

maintain the

RCS in a stable condition should

be prohibited."

In addition,

Enclosure

1

to

the

procedure

provides

a list of

activities that are

undesirable

during reduced

inventory conditions

as

they

may cause

RCS perturbation.

Step

5. 1.2.8 of the procedure

requires verification that

these activities

are

not in progress

or

will not cause

perturbations

prior to reducing

RCS inventory.

RCS Inventory

As

a prerequisite

to entering

a

reduced

RCS inventory condition,

procedure

3/4-0P-041.9

requires

that at least

one

high pressure

safety injection

pump is available

and capable of taking suction from

the

RWST

and

providing injection to the

hot

and cold legs.

In

addition,

the procedure

requires

that two charging

pumps

are avail-

able

and

capable

of taking

suction

from the

RWST

and

providing

injection to the

RCS.

Guidance for operation of these

systems

during

loss

of

RHR

are

contained

in existing

off-normal

procedure,

3/4-0NOP-050,

Loss of RHR.

Hot Leg Flow Paths

At this time,

Turkey Point

does

not

use

nozzle

dams.

However,

procedure

3/4-0P-041.9

requires that

a vent path

be provided whenever

an opening of one square

inch or greater exists in the cold leg, the

RCPs or the intermediate

leg.

Until further analysis

is performed,

this vent will consist

of either the pressurizer

manway,

a

steam

generator

hot leg manway or a steam generator

cold leg manway.

These

requirements

are contained

in procedure

steps

4.16 and 4.17.

Loop Stop Valves

Loop stop valves

are not installed in the

RCS loops at Turkey Point

Units

3 and 4.

19

The inspectors

consider

the licensee's

response

to the Generic Letter and

the implementation of the response

in training, equipment,

and procedures

to be adequate

and satisfy the requirements

of the TI.

This TI is closed.

No violations or deviations

were identified in the areas

inspected.

12.

Exit Interview (30703)

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

30,

1989.

The areas

requiring management

attention were reviewed.

No proprietary

information

was

provided

to the

inspectors

during the

reporting period.

The inspectors

had the following findings:

Item Number

Descri tion and Reference

50-250,251/89-27-01

50-250,251/89-27-02

50-250,251/89-27-03

50-250,251/89-27-04

13.

Acronyms

and Abbreviations

Violation -

PORV opening

time exceeded

the

OMS safety evaluation limits of 2 seconds,

Paragraph

2

Non-Cited Violation - Failure

to identify

outstanding

clearance

affecting

the

auxiliary feedwater

flow to the

C

steam

generator,

Paragraph

2

IFI - Correction of minor procedural

and

drawing discrepancies,

Paragraph

8

Violation - Installation of erroneous

label

plates

on the Unit 3 safety injection block

switch, Paragraph

9

AC

ADM

AFW

ANSI

AP

ASME

CCW

CCTY

CFR

CS

DP

ECP

EDG

ENS

ERT

Alternating Current

Administrative

Auxiliary Feedwater

American National

Standards

Institute

Administrative Procedures

American Society of Mechanical

Engineers

Component Cooling Water

Closed Circuit Television

Code of Federal

Regulations

Containment

Spray

Differential Pressure

Employee

Concerns

Program

Emergency

Diesel

Generator

Emergency Notification System

Event Response

Team

20

FPL

FPLTQR

FSAR

HDSFRP

HHSI

ICW

IEB

IFI

ILRT

IST

LCO

LER

LIV

LLRT

LOCA

MI

MIMS

MOVATS

MSIV

MP

NCR

NPSH

NRC

OMS

ONOP

00S

OP

OTSC

PA

PAHMS

PASS

PC/M

PNSC

PORV

PSN

PSP

QA

QC

REA

RCO

RCP

RCS

RHR

RWST

SRO

T AVG

TQR

TS

TSA

URI

Florida

Power

& Light

Florida

Power

8 Light Topical Quality Assurance

Report

Final Safety Analysis Report

High Density Spent

Fuel

Rack Project

High Head Safety Injection

Intake Cooling Water

Inspection

and Enforcement Bulletin

Inspector

Followup Item

Integrated

Leak Rate Test

Inservice Testing

Limiting Condition for Operation

Licensee

Event Report

Licensee Identified Violation

Local

Leak Rate Test

Loss of Coolant Accident

Maintenance

Instruction

Metal

Impact Monitoring System

Motor Operated

Valve Analysis

and Test

System

Main Steam Isolation Valve

Maintenance

Procedure

Non-conformance

Report

Net Positive Suction

Head

Nuclear Regulatory

Commission

Overpressure

Mitigating System

'ff Normal Operating

Procedure

Out of Service

Operating

Procedure

On the Spot

Change

Protected

Area

Post Accident Hydrogen Monitoring System

Post Accident Sampling

System

Plant Change/Modification

Plant Nuclear Safety Committee

Power Operated Relief Valve

Plant Supervisor Nuclear

Physical

Security Procedures

Quality Assurance

Quality Control

Request for Engineering Assistance

Reactor Control Operator

Reactor Coolant

Pump

Reactor Coolant

System

Residual

Heat

Removal

Refueling Water Storage

Tank

Senior Reactor Operator

Average Reactor Coolant Temperature

Topical Quality Requirement

Technical Specification

Temporary System Alteration

Unresolved

Item