ML17348B233
| ML17348B233 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/18/1991 |
| From: | Peebles T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17348B231 | List: |
| References | |
| 50-250-91-38, 50-251-91-38, NUDOCS 9111200219 | |
| Download: ML17348B233 (41) | |
See also: IR 05000250/1991038
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323
U. S.
NUCLEAR REGULATORY COMMISSION
REGION II
OPERATIONAL READINESS ASSESSMENT
TEAM (ORAT)
INSPECTION
1
Report Nos.:
50-250/91-38
and 50-251/91-38
Licensee:
Florida Power
and Light Company
9250 West Flagler Street
Hiami,
FL
33102
4
Docket Nos.:
50-250/91-38
and 50-251/91-38
License
Nos:
and
Facility Name:
Turkey Point
3 and
4
Inspection
Conducted:
September
9-13,
1991
Inspector:
T. A. Peebles,
Team Leader
Date Signed
Accompanying Personnel:
R. Auluck,
NRR Project
Manager
H. Ernstes,
Operator
Licensing Examiner
G. Galletti,
Human Factors
Engineer
R. Moore, Reactor
Inspector
G. Schnebli,
Resident
Inspector
H. Scott,
Resi'dent
Inspector
D. Thompson,
Security Inspector
Approved by:
A.
. Gibson, Director
Date Signed
" Division of Reactor Safety
91
1 3 r"'00~'
C7 9 ) 3 0 ) 8
ri DQCI( 05000'?lia
0
E'D;-<
EXECUTIVE SUMMARY
The
objective
of the
inspection
was
to
determine
the
licensee's
overall
. operational
readiness
following the recent
outage,
including whether
the
new
equipment
had
been
integrated
into overall plant operations.
The outage
was
intended to separate
the two units'lectrical
busses
and to add two emergency
diesel
generators.
The following were the major items
added =-or replaced
on both units:
-Emergency
Bus
Load (safeguards)
Sequencer;
-Anticipated Transient
Without Scram
(ATWS) Mitigating System Actuation
Circuitry (AHSAC);
-RTD bypass
removal
and instrumentation
upgrade
(Eagle 21);
-Battery chargers
3Al, 3A2,4A1,4A2,3B1,
3B2,
4B1,
and 4B2;
-Spare battery
D5Z and spare
charger
D51;
-480 Volt Motor Control Centers,
3K, 3L, 3H,
4D, 4J,
4K, 4L,
and
4H;
-480 Volt Load Centers
3H and
4H;
-4160 switch gear
3D and
4D (swing buses
and transfer switches);
-Emergency diesel
generators
(EDG)
4A and
4B;
and
EDG 3A and
3B upgrade.
During the outage period, Turkey Point had numerous other inspections.
The team
independently
assessed
the
operability
and
usability
of the
major
system
modifications,
the
procedural
changes,
and
the
newly
implemented
Technical
Specifications.
This included
an assessment
of the operators'eadiness
for the
startup
and their familiarity with the
new equipment'nd
procedures.
Management's
involvement and oversight of the outage
was readily apparent.
The
thoroughness
of the major system tests
and the lack of discrepancies
found during
the tests
are attributable to this attention.
The team findings in the area of
major modifications were minor and,
due to the complexity of the outage,
many
management
cross-checks
were
implemented
and were the reason for the excellent
progress
toward the quality and timely completion of the outage.
Deficiencies
were
corrected
prior to
system
turnover
to operations.
This
required tracking all deficiencies
to closure.
Identification and tracking of
all outstanding
items for each
system provided plant management
with detailed
status information and maintained accountability for resolution of deficiencies.
The
team
found
an
inadequately
implemented
design
change.
The
inadequate
implementation of the initial design intent was not detected
during the design
process
due primarily to
inadequate
independent
review
and
inadequate
post
modification testing.
The operating procedures
developed to implement the back-
up cooling water flow to the charging
pumps would have misdirected the operator.
Therefore,
the back-up function would not have performed properly.
System
engineers
reviewed all
5500
open Plant
Work Orders to determine if the
work
was
required
to
be
accomplished
prior to turning
over
the
system
to
Operations
Department.
The disposition
was agreed
upon by both Maintenance
and
Operations.
The team reviewed the open
PWOs for the Safety Injection, Residual
Heat
Removal,
and
Component
Cooling Water
systems
and
agreed with their final
disposition.
Executive
Summary
2
Approximately 310 Plant Change/Hodifications
were planned to be accomplished
and
22 of these
were cancelled.
The team reviewed the deleted
PC/Hs and agreed that
they did not impact plant safety.
Eleven of the cancelled
PC/Hs were replaced
by 14 other
PC/Hs that the licensee
considered
to be more important.
Shift manning. was found to have experienced
personnel
in the shift supervision
positions
but
22 of 24 of the control
board operators
comprising the current
crews were licensed for less than
a year with few actual plant start ups and shut
downs.
Operations
management
required experienced
operators in the proximity of
control board operations
at all times,
and personally provided oversight in the
control
room.
The Normal and Off-normal operating procedures
were in general
agreement with the
writer's guide.
Some
procedures
were
walked
down with operations
staff
and
particular emphasis
was placed
on reviewing the modifications to the Unit 3 and
Unit 4 Emergency Diesel Generator controls.
The team found that the procedures
were adequately detailed
and the operations staff was capable of performing the
activities described
in the procedures.
Inspectors
observed
the fill and
vent of the Unit
3 Reactor
Coolant
System.
Operators did a good job in monitoring plant conditions
and keeping the evolution
coordinator
and shift supervision
informed of the plant status.
A sample of valve lineup attachments
associated
with Safety Injection, Component
Cooling Water and Emergency Diesel Generators
were reviewed and walked down.
The
team
found system configurations
consistent
with the documented
valve lineups
except 'for
a
few minor labelling discrepancies
and
a broken valve handwheel.
Control of locked valves
was adequate
with a few problems noted.
The team reviewed the incorporation of new Technical Specification requirements
into operation,
calibration
and
surveillance
procedures.
Additionally, the
mechanisms
which identify and track TS operability requirements for Hode change
and
routine
operating
conditions
were
reviewed.
The
team
found
good
incorporation of the
new TS.and
good oversight of changing plant conditions.
The security facilities and staff were found capable of supporting the restart
of Units
3 and 4, with minimal'mpact
on operations.
Simulation of the
new electrical
systems
and
the
sequencer
soft
and
hardware
(switches,
indicator, etc.)
have
been installed
and trained
on in the control
room simulator by the operators
that will perform the upcoming Unit 3 startup.
Electrical maintenance
personnel
were trained
on the
new equipment with the aid
of actual
equipment
installed
at
the training
center.
The
use
of actual
equipment in the training process
was
a positive point in the inspection.
In summary,
the
team determined
that the outage
was accomplished
in
a quality
manner,
and the plant
was staffed
by competent
personnel
who were capable
of
starting-up
and operating
the plant safely.
However; the team identified that
one design
change
was not properly implemented
such that the intended function
would not have
been
performed,
Executive
Summary
TABLE OF
CONTENTS
~Pa
e
1.0
INSPECTION
SCOPE
AND OBJECTIVES.................'..........
1
2.0
FACILITY MANAGEMENT ASSESSMENT.............................1
2. 1.
Review of the
Company
Nuclear
Review
Board
(CNRB)
Assessment
of
Turkey Point Operational
Readiness
2.2.
Review of management efforts for proper prioritization of activities
to assure
completion of required
items
on schedule
3.0
CONFIGURATION CONTROL MANAGEMENT .....
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3. 1
Review of control of new equipment
by operations
3.1
~ 1
PC/H Control
3. 1.2
Walkdown of New Equipment
3. 1.3
New Equipment Drawings
and Procedures
3.2
Review of changeover
of preoperational
deficiencies
to plant work
orders
3.3
Minor Plant
Change Modification (PC/H)
Package
Reviews
3.4
Review Backlog of PWOs for Effect on Operational
Readiness
3,4. 1
Review of PC/Ms which had not been
accomplished.
3.5
Drawing Control for new equipment in Control
Room and
4,
OPERATIONS..........................
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5.
4.1
Shift Manning
4.2
Review of Operating
Procedures
and
Human Factor Walkdown
4.3
Review of Major Operations Activities
4.4
Independently
performed
system walkdowns/Line
up Verifications
4.5
Balance of Plant maintenance
to prevent inadvertent transients
TECHNICAL SPECIFICATIONS (TS) ADHERENCE........... ~...........12
5, 1
New TS requirements
Incorporated
in Operating
Procedures
5.2
Specific
TS Operability Procedure
Review
5.3
Tracking Plant Activities
Equipment
Out of Service Controls
Limiting Conditions for Operation
(LCO)'racking
Tracking Haintenance
and Surveillance Activities
6.
SECURITY
6.1
Hanagement
Support
6.2
Security
Program
Plans
16
6.3
Protected
and Vital Area Access Control of Personnel,
Packages,
and
Vehicles
6.4
Alarm Station
and Communications
6.5
Security Training and gualification
6.6
Vital Areas
7.
ENGINEERING AND TECHNICAL SUPPORT..........................19
7. 1
Operator
and Technical Training
7.2
Temporary Alterations/Hodifications Control
7.3
Human Factors
Review of Control
Room and Local Control
Panel
Changes
7,4
EOP Follow-up Inspection (Inspection Report No.50-250
& 50-251/91-33)
7.4
System Pre-Operability Checklist Process
8.
EXIT HEETING t
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APPENDIX A - ABBREVIATIONS AND ACRONYHS
APPENDIX 8
PROCEDURES
REVIEWED
APPENDIX
C -
DRAWINGS REVIEWED
APPENDIX D - EXIT ATTENDANCE
INSPECTION
SCOPE
AND OBJECTIVES
The ORAT assessed
overall plant readiness for startup with respect to: the major
system modifications,
procedural
changes,
and the newly implemented
Technical
Specifications.
The team also assessed
the operators'eadiness
for the startup
and their familiarity with the
new equipment
and procedures.
This special,
announced
inspection
was conducted
in the areas of management
of
outage
activities,
configuration
control
management,
operations,
Technical
Specification
adherence,
security,
engineering
and technical
support.
Within
these areas,
the inspection consisted of selected examinations of newly installed
equipment,
review
and
walkdown of procedures,
inter views with personnel
and
observation of activities in progress.
2.
FACILITY HANAGEHENT ASSESSHENT
e
2. 1
Review of the Company Nuclear Review Board
(CNRB) Assessment
of Turkey Point
Operational
Readiness
In Hay of 1991, the President of the Nuc'lear Division of FP&L gave
a charter to
the
CNRB.
The charter
was,
in addition to the Nuclear Plant Hanager's
overall
responsibility to assure
the plant is ready for restart, for the
CNRB to review
and approve the overall plant re-start program and provide oversight activities.
A review of the activities 'of the
CNRB and its individual members'ite visits
showed that the overview function was, fulfilled.
A discussion
with the
CNRB
Chairman
and
a review of appropriate
minutes of CNRB meetings
showed that the
review and approval of the plant re-start
program were also achieved.
The team found that this oversight of outage
completion
and readiness
for re-
start
was
an important contributer to the re-start
program
and its success.
2.2
Review of management
efforts for proper prioritization of activities to
assure
completion of required
items
on schedule
The team attended
several of the planning meetings that the licensee periodically
held
and reviewed the multilayered oversight for work planning
and completion.
These
programs
are detailed later in this report.
During the outage planning,
the
licensee
determined
that,
due
to
the
complexity of the
outage,
many
management
cross-checks
were required
and assured their implemention.
The team
concluded that this oversight
was the reason for the excellent progress
toward
the quality and timely completion of the outage.
3.
CONFIGURATION CONTROL HANAGEHENT
3. 1
Review of control of new equipment
by operations
3.1.1.
PC/H Control
The
System
Acceptance
Turnover
(SAT) group
was
led
by the Technical
Support
Department
and provided closeout of the dual unit outage
PC/Hs.
The
SAT staff
had dropped
from 28 people
down to eight
as
the outage
was
coming to
an
end.
This staff was supported
by other groups in the closure effort particularly plant
gC, engineering,
document control, startup test,
and construction.
Documents reviewed, that provided control to assure
PC/H implementation to closure
during the outage
were:
gI 3-PTN-1
Design Control, revision date 6/25/91
0-ADM-708
Maintenance Department
PC/H Guidelines, revision date 10/27/87
TS 3. 1
Design
Change
Verification
and
Document
Turnover,
revision
date
1/31/91
The team conducted
interviews
and reviewed records with PC/H closeout
personnel
in the SAT group, engineering,
and plant gC.
These interviews demonstrated
that
the
licensee
had:
a
functioning-
close'out
methodology;
controlled
records/documentation
that
supported
their
closeout
system;
and
completed
packages
to support the installed
systems
and components.
The
SAT group
and others
involved in the
PC/H closure
system
had
been
given
enough
independence
and authority
by- licensee
management
to insure
a proper
product,
The team reviewed the final closure documentation
package for PC/H
90-071,
Load
Center
and Switchgear
Rooms Chilled Water Air Con'ditioning System.
This system
supplied cooling for the safety-related
load centers'ooms
and was powered from
vital bussing.
Members of the
SAT group discussed
the package
in detail
and
supplied support documents for the review.
During package closure, construction,
engineering,
gC,
and
startup
documents
were
compared
to
separate
listing
documents (e.g., drawings,
PC/H revisions,
Design change Notices,
Change Request
Notices,
Nonconformance
Reports, etc.) that were maintained in document control
as
the official quality
assurance
records
during
package
installation
and
testing.
The package
was complete
and the paper trail which supported
the
PC/M
package
closure
was plain.
No violations or deviations
were identified.
3. 1.2.
Walkdowns of New Equipment
The
new
equipment
was
mainly installed
and
complete.
At the
time of the
inspection,
Unit 3
had
gone
from Node
6 to Mode 5.
Operations
had filled the
primary system
on Unit 3 and was making preparation for Mode 4.
Unit 4 was still
defueled.
New equipment
was in the following states:
The sequencer,
AMSAC, and most of the motor control centers
and electrical
busing were complete;
RTD loop calibration with the vendor present
was ongoing;
The spare
battery
and charger
were being tested
by startup
and were not
needed for either unit power operation (turnover completion was scheduled
for September
19,
1991);
and
=
The
were
complete
except for minor segments
of six
PC/Hs
(87-257,
258,
263,
264,
265,
and
266) that were in process
to be closed out.
The
EDG addition was supported
by 27 dual outage
PC/Ms and was the largest single
work package.
The Unit 3 EDGs had also been modified during the outage receiving
upgrades
such
as air start
enhancements
and idle start
panels.
Much of the
electrical modification testing was observed
by the
NRC as indicated in previous
Inspection Reports, (e.g., 50-250,251/91-22).
The licensee stated that all minor
diesel
work (e.g.,
fireproofing addition)
to complete
the
packages
would
be
accomplished prior to entry into Mode 4.
Operations
walked systems
down during the. turnover process,
when performing the
valve lineups prior to returning the system to normal.
The
PSN is required to
verify for each
SATS that all system; valves, switches,
and breakers
are aligned
in accordance
with the appropriate
operating
procedures
and that the equipment
is operable
as defined in TS or the system/component
is entered
the
EOOS log.
Deficiencies identified during performance of the valve lineups were documented
in the remarks section of the procedure
and
PWO's were generated,
as required.
The system engineers
performed
a walkdown of their assigned
system to identify
deficiencies.
These
walkdowns were documented
on
a check list which was
a part
of the
System
Readiness
for Restart
System
book.
This checklist
included:
deficiencies
identified
and corrective
actions
taken;
missing
or mislabeled
equipment tags;
drawing discrepancies;
and equipment that was
OOS.
The licensee
performed
system
readiness
tests for a number of primary and
systems prior to returning the system to normal service.
Special test procedures
were written to perform selected
portions of OSPs to run pumps,
cycle valves,
etc.,
in order to find major problems prior to returning the system to service.
This program identified several
problems with pumps
and valves before they were
needed,
which allowed early repair
and prevented
additional delays.
The team performed
walkdowns with system engineers
and/or operations
personnel
of selected
new equipment.
The majority of the system engineers
had participated
in the startup testing of portions of the new equipment under their supervision.
The
non-licensed
operators
who
would control
the
equipment
and
line-up the
equipment during normal operation did participate in the initial testing of the
equipment
and had training on the equipment.
All licensee
personnel
involved in
the walkdowns displayed
a working understanding of the systems
and modifications
that 'had
been
performed.
During the walkdowns,
the construction
was complete,
functional,
and in good working order.
The support drawings for the equipment
which
had
been
generated
from the
PC/Ms or altered
during the
PC/M process
matched
the
equipment
and
agreed
with existing
system
conditions
with
few
exceptions.
During team / licensee jointly performed detailed
system walkdowns of piping on
the 3A and
4A
EDG air start
and lube oil piping,
some minor discrepancies
were
noted.
Overall, the systems
matched the lineup instructions.
Air start system
discrepancies
found during the walkdown were
as follows:
3A
gage
isolation
valve
(3-70-441A)
appeared
on the
valve lineup
procedure,
but was not on the print;
3A EDG two way manifold valves
(two valves in one valve body/block) 3-70-
303A, 317A, 419A, 420A were identified by only a valve tag for their globe
valve instrumentation
isolation side
and not the vent valve side;
valves 3-70-314A (3A EDG), 3-70-537A (4A EDG) and 3-70-538A (4A EDG) were
not the=valve type specified'on
the piping drawing.
The first discrepancy
noted
above
was generated
during
a intermediate
drawing
.revision that inadvertently
removed
the valve from the drawing.
The operator
performing the lineup had no problem locating the actual valve.
With the second
discrepancy,
the operator
was faced with the problem of deciding which of the
valves in the common body or block was the isolation valve.
He reasoned
out the
correct
valve
but future manipulations
could
be
questionable
and
a
missed
manipulation
could vent the line, which at the most,
could cause
an erroneous
alarm.-
With the third discrepancy,
the Unit 4
had indicated
a
ball type valve on his bill of materials while the installed valve was
a globe.
The Unit
3 portion of the third discrepancy
occurred
as
a drawing error in
translating
the bill of materials to the drawing.
The licensee
evaluated
the
above
discrepancies
and
took immediate corrective
actions.
For the first discrepancy,
the
441A valve
was
reinstated
to the
appli,cable
drawing,
For the
second
discrepancy,
the applicable
drawing
was
modified to use
a manifold valve symbol
instead of a single globe valve symbol
on all four valves;
operations
had
each
valve
handle
tagged
separately
for
identification purposes.
For the third discrepancy, after the licensee performed
a more detail
walkdown of the air start
systems
to insure there were'no other
types of valves in error, the applicable
drawings
were changed to indicate the
proper type.
The team reviewed the corrective actions
(CRN-H-5442 and
DCR-TPH-
91-389) prior to the
end of the inspection.
Due to the minor nature of the
discrepancies
and
the
immediate
corrective
actions
taken,
no additional
NRC
action
was warranted,
as allowed under the
No violations or deviations
were identified.
3. 1.3
New Equipment Drawings
and Procedures
In preparing
for the
use
of the
new equipment,
the
licensee
has
added
new
procedures
and
drawings
to
the
document
control
system.
The
drawings
in
particular have had many changes
due to the many PC/Hs involved and the multiple
revisions to the PC/Hs.
At the point in time of the inspection,
only some minor
changes
were expected
to the critical plant drawings
used to operate
the plant.
All changes
were to be completed prior to Hode
4 operation.
To determine
the state
of control
over the
drawing
program,
the
team
cross
checked
the drawings
a number of ways.
As noted elsewhere
in this report, the
plant drawings
were
used
in plant walkdowns to ensure correlation
between
the
drawings
and the actual
systems.
A comparison
was
made between the PC/H content
and the actual drawing revision.
Then
a comparison
was made between the drawing
targeted for distribution and those in the plant.
Except for some minor points,
the program
was intact.
The team obtained copies of the
POD section from the 27 dual outage
PC/Hs for the
EDGs.
This section details, the revision level
and the drawing impacted
by the
PC/Hs.
Those
drawings stated
to
be
"POD 1" were to
be issued
to support
the
e
plant prior to startup.
From this population of critical drawings,
a comparison
was
made
between
the
drawing
indicated
PC/Hs
and
those
located
in document
control.
The
PC/Hs
and drawings
sampled
are
as follows:
drawing
sheet
Revision
PC/H
drawing type
5610-T-E-4536
1
22
5610-T-E-4536
3
6
5614-H-736
1
1
5614-H-736
2
1
5610-E-0855
C3
284
- piping and instrumentation
diagram
87-263
86-155
87-263
87-263
91-071
P&ID*
P&ID
breaker list
A
comparison
was
made
between
document
control
records
regarding
drawing
distribution.
From the population
sampled,
the correct revision for drawings
required to be in the control
room and Technical
Support Center
(TSC) were found
as listed in Appendix C.
Also, drawings for new equipment
were checked
in the
control
room 'and the
TSC with good results.
The
licensee
stated
that
the
drawing
system
is
changing
further.
Per
a
relatively new Architect/Engineer contract with Stone
and Webster, all Piping and
.Instrument Diagrams
(P&ID) would be redrawn under
a common numbering system.
The
new
drawings
would rid
the
existing
drawings
of
an
existing
problem
of
e
conflicting symbology
caused
by the
use of at least
three different drawing
developers
in the past.
Additionally, the
new drawings would combine three to
'our existing drawing types
such that the
new drawings would show Environmental
gualification requirements,
code boundaries,
etc.
Approximately 40 percent of
the
P&ID drawings
were stated
to
have
been
changed
and
were existing in the
drawing control system.
Redrawing completion was scheduled for the end of 1991.
The change
should not impact the current startup.
Support
drawings
(other
than
"POD
1" critical drawings)
were
not evaluated.
These were being handled
on a expeditious
schedule with a scheme of required due
.dates
up to 180 days.
"POD 1" drawings would be turned around in one day at the
plant site.
The team
was
shown graphical
presentations
of the backlog of the
lower priority drawings that
showed
the
backlog
close
to
be
being
completed
within schedule.
e
Procedures
for the
new equipment
have
been
issued to support the startup.
These
new
procedures
were
generated
as
a part of the
PC/H process
with specific
signoffs
by the affected
departments.
These
procedures
will change
as
more
information and experience presents itself but the procedures
were largely intact
for the startup.
Reviewed
procedures
are listed in Appendix
8 and they were
found to be complete
and
no problems
were identified.
No violations or deviations
were identified,
3.2
Review of changeover
of preoperational
deficiencies
to plant work orders
Although
in
the
past it
was
common
policy
for
the
licensee
to
convert
preoperation deficiencies
to their normal
PWO system,
the current philosophy is
to correct all deficiencies prior to unit startup,
Regional
based
and resident
0
inspectors witnessed
numerous preoperational
tests throughout the current outage
and
observed
that all deficiencies
identified during the testing
phase
were
corrected.
Test
deficiencies
were
documented
on
a
TER for the
specific
preoperational
test
procedure
being
performed.
The.
then
provided
a
disposition to correct the deficiency and determine the appropriate retest.
The
retest normally required the reperformance of applicable portions of the original
test procedure or in some instances
required the performance of a new procedure
written
-for
the
specific
deficiency.
Deficiencies
identified
after
preo'perational
tes,'ting
and turnover to operations
department for returning the
system/component
to service
would
be identified
by the licensee's
normal
PWO
process
and corrected
under this system.
In order to ensure all deficiencies, identified during the outage were documented
and closed out, the licensee established
'a System Readiness
for Restart
Program.
This program identified approximately
50 systems,
per unit which included all
nuclear plant systems
and those
secondary
systems
considered
by the licensee
as
important to safety
and plant reliability.
The systems
were assigned their own
unique
notebook
which was sub-divided into about
30 subtopics
which included:
open clearances,
surveillance to be performed,
equipment listed in the
EOOS log,
PH,'s
to
be
accomplished,
outstanding
PWOs,
PHT required,
training,
system
lineups,
PC/H's open,
system walkdowns, NCR's, etc.
open items identified in each
subtopic were listed on a master
punch list by system, responsibility,
due date,
and the Node the item must
be cleared
by.
Closure of the open items was'racked
at the daily meetings to ensure all required items were corrected or accomplished
prior to allowing
a Hode change.
For example,
there
were over 800
punch list
items that were required to be completed prior to entering Hode 6.
The books and
punch list for each
system were reviewed
and signed for by each department
head
and approved
by the
PNSC and Plant Hanager.
The team considered this extensive
effort to identify all outstanding
items for a specific system to be beneficial,
in that it provided plant management
with a detailed status of each
system.
It
should be noted this program which was established for the outage
was in addition
to the licensee's
normal
process
for ensuring all required
work was
complete
prior to restart.
No violations or deviations
were" identified.
3.3
Hinor Plant
Change Hodification (PC/H)
Package
Reviews
The team accomplished
a detailed review of PC/H 91-064 which was developed
and
implemented
under
the
Hinor Engineering
Package
program.
The
program
provides guidance for developing minor design changes.
The selected
PC/H was to
the charging
pump reduction
speed drive system.
The charging
pumps are positive
displacement
pumps with variable
speed
control
achieved
through the hydraulic
coupler.
The purpose of the hydraulic oil cooler is to maintain the hydra'ulic
coupling oil within its operating
range.
The
reviewed
PC/H's intent
was to
provide
an alternate
source
of cooling water to the
A and
C charging
pumps'ydraulic
coupling oil coolers (its
normal
cooling water
source
is
CCW)
and
prevent overheating of the oil in the hydraulic coupling should
CCW be lost.
The
B charging
pump for both Units received
a similar modification in 1976.
Design deficiencies identified in this PC/H by the team demonstrated
deficiencies
in
the
program.
Primarily,
these
deficiencies
were
related
to
the
independent
review and post modification testing
aspects
of the design
change
process
as applied to minor design changes.,The
package appropriately addressed
hardware
installation
and
procurement.
The
package
did not provide
adequate
calculation, analysis, testing or procedural
guidance to demonstrate that service
water could supply adequate
cooling for the hydraulic oil which was the design
intent of the modification.
Additionally, piping design. pressures
given in the
documentation
indicated the
CCW piping would experience
pressures
greater
than
design
when the service water supply was provided.
These deficiencies
were not
identified by the independent
reviews.
Although the hardware
was appropriately modified, the incorporation of design
information into the appli,cable operating procedures
was incorrect, resulting in
establishment
of inadequate
flow for the service
water through
the coolers.
Additionally, the parameters
monitored,
by procedure, direction, would not have
alerted the operators if the oil temperature
was approaching limiting conditions.
The procedure directed the operator to adjust the inlet service water valve to
the heat
exchanger
to prevent overflow of the, floor drain to which the outlet
flow was directed.
Due to the flow restriction provided by the drain screen this
would
have
been
considerably
less
than full service
water flow or normal
flow.
This flow condition was not tested
or analyzed to determine if adequate
cooling was provided.
The procedure,
ONOP-030, Malfunction of CCW, directed the operator to monitor the
temperature of the service water outlet flow from the cooler.
No instrumentation
was installed for measuring this temperature.
The procedure stated
a 150 degree
F
upper limit.
During
the
modification
walkdown
the
operator
stated
the
temperature
would be verified by operator tactile sensitivity; i.e., finger in
. the flowstream.
Due to the variable
and unspecified
flow rate this would not
provide
a reliable verification that the oil was not exceeding its temperature
limits even if operator tactile sensitivity was accurate to 150 degrees
F.
The
design
change
package
did state
the oil inlet temperature
to the cooler should
be monitored
however this information was not incorporated
into the applicable
procedures.
Existing
instrumentation
was
available
to
measure
oil inlet
temperature.
The above design deficiencies
challenge the effectiveness
of this design
change
to
accomplish its intent.
The
design
review process
and
post modification
testing, if adequately
performed,
are
mechanisms
which should
have identified
these
deficiencies
or
verified
the
design
intent
was
achieved
by
the
modification.
The failure of the
HEP design
change
process
to provide adequate
design control is identified as violation 91-38-01.
The service water back-up cooling capability provided
by this modification was
taken credit for in improving the licensee's
PRA for preventing
core
damage
in
specified
accident
scenarios.
The modification specifically reduced
the core
melt probability for the unmitigated
RCP Seal
LOCA scenario
where
CCW is assumed
to fail.
Either
CCW or charging flow is required to maintain
RCP seal
cooling
and
CCW is required for continued operation of the charging
pumps
and the High
and
Low
Head
Safety
Injection
Pumps.
Therefore,
to
prevent
unacceptable
consequences
from loss of CCW,
an alternate
source of cooling to the charging
pumps
was developed.
The short-term operability impact of this specific
PC/H deficiency is minimal
'because
the
added
service
water cooling is
a
back-up
function.
A similar
capability on the
B charging
pumps, installed since
1976,
has
never
been
used.
The primary importance of this issue is the design
change
process
programmatic
deficiency
demonstrated.
The licensee's
corrective
action
discussed
in the
following
paragraph
addresses
the
potential
operability
impact
of
other
modifications
accomplished
under
the
HEP program.
The
HEP program at Turkey
Point was initiated in March,
1991;
91
had
been issued
as of September
12,
1991.
I
Upon
notification of this
finding,
the
licensee
initiated
the
following
corrective actions'hich
were to be completed prior to entering
Mode 4:
2
~
All
dual
unit
outage
will
be
reviewed
to
ensure
post
modification testing
and procedural
interfaces
are satisfactory.
The
HEP process
at Turkey Point
was modified to:
1) include Site
Engineering
Manager
sign-off
of
the
MEP
package
prior
to
implementation,
and
2) include
a joint pre-implementation
walkdown
with the
design
engineer,
system
engineer
and
appropriate
plant
operations
and maintenance
personnel.
3.
All site engineering
personnel will be trained
on the changes to the
HEP process.
4.
The
PNSC will be "resensitized" to the need for a thorough review of
post modification testing
requirements
on all
design
changes it
reviews.
The licensee further prohibited use of the
HEP process
at Turkey Point until the
above
items are completed.
3.4
Review backlog of PWOs for effect
on Operational
Readiness
As previously stated,
outstanding
PWO's
are identified
as
a subtopic
in the
System
Readiness
for Restart
Books.
For this portion of the
program,
the
licensee
reviewed all open
PWOs for each
system
and included
a printout of each
one
in this
section
of
the
book.
This
required
reviewing
a
total
of
approximately
5500
PWOs.
The
respective
system
engineer
reviewed
the
PWOs
associated
with his system
and determined if the work described
in the
PWO was
required
to
be
accomplished
prior to turning
over
the
system
to Operations
Department.
The
system
engineer's
disposition for each
PWO was
reviewed
and
agreed
upon
by both Maintenance
and Operation
Departments,
If the work was
required to be accomplished prior to turnover it was
added to the master
punch
list and assigned
a Mode to be completed by.
The team reviewed the open
PWOs for
the SI,
RHR,
and
CCW systems,
and
agreed with the final disposition for those
PWOs 'determined
as not required prior to system turnover.
The team considered
the licensee's
review of the
open
PWOs to be comprehensive
as it included all
open
PWOs
and not just trouble
and
breakdown
PWOs.
0
3.4. 1
Review of PC/Hs which had not been
accomplished.
For this
DUO approximately
310
PC/Hs were planned to be accomplished
and
22 of
these
were canceled.
In order for the licensee
to delete
an activity that was
initially planned for the outage, it had to
be
recommended
by the applicable
Department
Head,'echnical'epartment
Supervisor,
Outage
Manager,
Operations
Superintendent,
and Plant Manager,
and approved
by the Site Vice President.
The
recommendations
and approval
are documented
on Attachment
3 of O-ADH-003, Outage
Management.
The team reviewed
the
22
PC/Hs that were deleted
and
agreed that
they 'did not
impact plant safety.
The
canceled
PC/Hs
ranged
from modifying
components
for system
enhancement
to installing removable
hand rails at the
containment
equipment hatch area.
Eleven of the canceled
PC/Hs were replaced
by
14 other
PC/Hs that
the
licensee,
considered
to
be
more
important
than
the
original
PC/H.
For example,
PC/Hs90-301,
304,
and
305,
to modify
11 pipe
supports,
were traded to procure, install, and test the Hydrogen Recombiner.
In
addition, the canceled modifications were added
as candidates for either the "Top
20" or "Top 30" lists.
These lists were recently implemented
by the licensee to
control the number of modifications being installed in the plant.
In order for
a
modification
to
be
installed it
must
be
listed
on
the
"Top
20 List"
(modifications scheduled for the next outage) or the "Top 30 List" (modifications
that
can
be accomplished
on-the-line or during short notice outages).
For
a
modification to be added to the lists there must be room for it or a modification
currently on the list must be canceled
and the new modification added.
The team
considered
this
an
excellent
method
of controlling
the
number
of
changes
occurring in the plant at any one time.
No violations or deviations
were identified.
, 4.
OPERATIONS
4. 1 Shift Manning
Shift manning
was found to have experienced
personnel
in the shift supervision
positions
but
22 of 24 of the control
board operators
comprising the current
crews were licensed for less than
a year with few actual plant start ups and shut
downs.
Through discussions
with Operations
management, it was agreed that there
would be experienced
operators
in the proximity of control
board operations
at
all times.
These
experienced
operators fill the positions of PSN,
APSN,
and
Watch
Engineer.
Operations
management
personally
provided oversight
in the
control
room.
No violations or deviations
were identified.
4.2
Review of Operating
Procedures
and
Human Factors
Walkdown
The team reviewed
a sample of the
OPs
and
ONOPs to ensure that the procedures
adequately
incorporated
human factors considerations
and that the Turkey Point
operations staff clearly understood
and could use the procedures
as written.
The
review consisted of: (1)
a review of the procedure writer'-guide ADM-101; (2)
comparison of the procedures
against the administrative guidelines for procedural
development;
and
(3) plant
walkdowns of selected
procedures
with operations
e
10
staff.
The procedures
reviewed are listed in Appendix
B to this report.
k
The team reviewed the licensee's
procedures writer's guide
(ADM-101) to ensure
that it adequately
addressed
the
previous
concerns
identified
during
the
Emergency Operating Procedures
Inspection (IR 50-250/89-53)
and incorporated the
human
factors
principles
as
described
in
"Guidelines
for
the
Preparation
of Emergency Operating
Procedures."
The licensee
has incorporated
revisions to the procedure writer's guide in response to the inspection findings.
Most significantly, the writer's guide
has
been
expanded
to include all
OPs,
ONOPs,
and
EOPs.
This is
a good practice
and should help to ensure
consistency
and standardization
in the preparation
and formatting of procedures.
The procedures
reviewed
(Appendix B) generally
agreed with the requirements
of
the writer's guide.
Several
of the
OPs
contained
minor deviations
from the
writer's guide with regard to the format 'and terminology for transition steps,
referencing
and branching steps,
and the use of highlighting.
These deviations
reflect
a lack of verification of the procedures
against the procedure writer'
guide.
The licensee
was appraised of these
concerns
and will continue to review
the procedures
to ensure
consistency
with the writer's guide.
A sample of the procedures
reviewed
were walked
down with operations staff to
determine the adequacy of the procedures,
and to ensure that appropriate controls
and indications were presented.
Particular emphasis
was placed
on reviewing the
modifications to the Unit 3 and Unit 4
EDG controls.
The team found that the
procedures
were
adequately
detailed
and the operations staff were
capable
of,
performing the activities described in the procedures.
In general,
the equipment
nomenclature
used
in the
procedures
matched
the
label identification
on the
equipment.
In those
cases
where labelling discrepancies
were identified, the
licensee
took
the
appropriate
administrative
actions
to
correct
the
discrepancies.
No violations or deviations
were identified.
4.3 Review of major operations activities
Unit 3 Containment
was not yet ready for closeout during this inspection period.
Inspectors
observed
from the control
room,
the fill and vent of the
Reactor
Coolant System.
An off-shift operator
served
as coordinator of the evolution.
He
was
responsible
for the fill and
vent leaving
the
APSN free to monitor
operations of the entire plant.
The coordinator
gave the pre-brief concerning
the
evolution
to
the
shift
during
the
shift
turnover.
There
were
no
discrepancies
observed
during
the
evolution.
Operators
did
a
good job in
monitoring plant
conditions
and
keeping
the
evolution coordinator
and
APSN
informed of the plant status.
During the fill of the Reactor
Coolant
System,
a conservative
value for boron
concenti ation of the water used for make-up to the Volume Control Tank was used
to ensure that
no dilution occurred while filling the Reactor
Coolant System.
No violations or deviations.
were identified,
0
4.4
Independently
performed
system walkdowns/Line
up Verifications
Com onent Coolin
Water
s stem
and
Emer enc
Diesel
Generators
A sample of valve lineup attachments
associated
with the Component Cooling Water
system
and
Emergency
Diesel
Generators
was
reviewed
to verify that
system
configurations
were consistent
with the documented
lineups
and to ensure that
there
was
adequate
control of locked valves.
The
team
found that the
system
configurations
were consistent
with the documented
valve lineups.
A few minor
labelling discrepancies
and
a
broken
valve
handwheel
were identified.
The
licensee
implemented
the appropriate
administrative
actions
to correct
these
discrepancies.
Control of locked valves was generally adequate with some exceptions
noted on the
Component Cooling Water system.
Inspectors
walked down selected
Enclosures
and
Attachments of OSP-205,
"Control of Locked Valves".
All valves were found locked
in their proper position.
This
procedure
calls for color coding of safety
related valves
so that
a color coded
key will open all the locks of that color.
There were three valves
on Unit three
CCW heat exchangers=that
had blue locks,
which are Unit 4 locks.
The facility subsequently
changed these locks to conform
with the procedure,
It should be noted that the check list includes checking the
color of the lock.
Enclosure
2 of the procedure
had omitted one page of valves
during the last revision.
The facility issued
a
new revision to the procedure
that included the correct
pages.
The team also identified several
discrepancies
between the plant system drawings
and the
new plant equipment,
A detailed discussion
of these
discrepancies
is
presented
in paragraphs
3. 1.
Safet
In 'ection
The
team conducted
a system
walkdown of the
system to ensure
proper valve
alignment,
This was accomplished utilizing 3-0P-062, Operating Procedure for the
Safety
Injection
System,
and. 5610-T-E-4510,
sheet
1
and
2,
Rev.
106,
dated
September
6,
1991, Operating
Diagram Unit 3 and
4 Safety Injection and Residual
Neat
Removal
Systems
Inside
and Outside
Containment.
The
team verified the
following;
all valves, in the
system
were in the correct position with power
available
and valves
locked if required;
valves
in the
system
were correctly
installed and did not exhibit signs of gross packing leakage,
bent stems, missing
hand
wheels,
or
improper
labeling;
system
lineup
procedures
matched
plant
drawings
and as-built configuration; local
and
remote position indication
was
compared
and functional;
and
system
components
were properly labeled.
Several
minor
discrepancies
were
identified
and
brought
to
the
attention
of the
Operations
Supervisor for correction.
In addition, the team reviewed the valve
lineups performed
by the licensee
on the
AFW,
CCW, and
RHR systems.
All lineups
reviewed
were found to be satisfactory with deficiencies
noted in the remarks
section
,of the
applicable
procedures.
Deficiencies
requiring
re'pair
were
identified w'ith the respective
PWO number listed,
No violations or deviations
were identified.
12
4.5
Balance of Plant
(BOP) maintenance
to prevent inadvertent transients
The
team
reviewed
and
discussed
with the licensee their efforts
and
actions
concerning their preventative
maintenance
programs with the secondary
systems
during the outage.
It was determined that the licensee
had taken major action
to ensure the secondary
systems
are functioning to support
a long term run after
re-start.
In support of Unit 83, the licensee
completed the following:
High pressure
turbine overhaul
(5 year inspection);
Generator
Rotor Rewind/Stator
Inspection/Repair;
Cross-under
Piping Ultrasonic Inspection/Repair
Program;
Turbine Control Valve Inspection/Overhaul
Condenser
Hotwell Inspection/Repair
Program
Extraction
Steam
Expansion Joint Inspection/Repair
Turbine Plant Cooling Water Heat Exchanger
Retubing
Feed
Pump Motor Upgrade
Feed
Pump Exhaust
Fan Modification
Condenser
Water
Box 100 percent
ECT Program
Replace
Atmospheric
Dump Valves
Moisture Separator
Reheaters
A<B<C<0 Inspect/Repair
on Shellside/Tubeside
Over haul all Turbine Oil Pumps
Relief Valve Testing/Overhaul
Program
Program
Actuator and Valve Overhaul
Program
Replace
Condenser
Water Box Expansion Joint
Turbine Generator
High Pressure
Oil Flush
and Cleanup
Condensate
Pump Overhaul/Motor
Intake Traveling Screen
Overhaul
Circulating Water
Pump Overhaul
(5 year plan)
5.
Technical
S ecification
TS
Adherence
5. 1
New TS requirements
Incorporated
in Operating
Procedures
The team reviewed the incorporation of the
new TS requirements
into operations,
calibration and surveillance procedures.
Additionally, the licensee's
mechanisms
which identify and track TS operability requirements for Node change
and routine
operating conditions
were reviewed.
A sample
of requirements
was
selected
from the
new
TS for verification of
appropriate
implementation in procedures,
The sample focussed
on criteria which
were
new or changed
from the previous
TS.
The general
areas
included
and
reactor
trip
setpoints,
fire
protection,
equipment
and
battery
surveillances.
5,2
Specific Technical Specification Operability Procedure
Review
1.
TS
3. 1.2.3 - Charging
pumps operability,
Reviewed
operating
procedure
4
-
-
047,
"Charging
Pump/Valves
13
Inservice Test" for consistency
with the applicability and surveillance
requirements
from the
TS including action statements.
Comments:
Acceptable
TS 4.8. 1. 1.2.b.
Fuel transfer
pump operability.
Reviewed
procedures
3-0SP-022.4,
"EDG Fuel
Oil Transfer
Pump
and
Valve
Inservice Test",
and 3-OSP-023. 1,",DG Operability Test" for operability of
fuel transfer
pump to 'start
automatically
and transfer
fuel
from the
storage
system to the day tank.
Comments:
Acceptable
TS 4.8. 1. 1.2.d
Removal
of accumulated
water
from fuel oil storage
tanks.
Reviewed procedure
O-OSP-022.6,
"Diesel Fuel oil storage
tank accumulated
water removal" for consistency with the
TS requirements
and also reviewed
the results of the surveillance
completed
in Hay. 1991.
Comments:
Acceptable.
TS 4.8. 1. 1.2.c
Removal
of accumulated
water
from the
day
and skid-
mounted fuel tanks (Unit 4 tank only)
Reviewed
procedure
0-OSP-022-6
for
compliance
with
the
surveillance
requirements.
Comments:
Acceptable.
TS 4.8. 1. 1.2.i.(1) - Draining and cleaning of fuel oil storage
tank.
Reviewed procedure
O-PHA-022.6 "Diesel oil storage tank cleaning"
and the
results of the cleaning
performed during 1987.
Comments:
Acceptable
TS 4.8.2. l.a.(3) - D.
C. Battery
and Charger Surveillance.
Reviewed
procedure
O-SHE-003.7
"
125
VOLT
DC startup
Battery
Weekly
Haintenance" for consistency
with the
TS surveillance
requirements.
Comments:
Procedure
and
TS were not updated to reflect the
new proposed
requirements
issued
on August 26,
1991.
Florida Power
and Light Company
indicated that their documents
are in the
process
of being
updated
and
will be completed
by September
13,
1991.
TS 4.8.2. I.a(1)
Table 4.8.2 Battery surveillance
requirements.
Reviewed
procedure
O-SHE-003.7
for
compliance
with
the
pilot cell
verification
and rotation
schedule
requirements
including reference
to
8.
9
R.G.
1. 129 and
IEEE recommendations.
Comments:
Acceptable
TS 4.7.2.a - Component
Cooling Water System.
Reviewed procedures
O-ADH-513," Duties
and responsibilities of the STA",
and
3-0SP-019-4,"
Component
Cooling
Water
Heat
Exchanger
Performance
Monitoring" for consistency
with the surveillance
requirements.'omments:
Acceptable
TS 4.7..2.b(2)
CCW heat
exchanger
performance test.
Reviewed
procedure
3-0SP-030.6,
"Component
Cooling Water Heat
exchanger
performance test".
Comments:
New surveillance requirements
were issued
as part of a license
amendment
dated
August
26,
1991.
As of September
12,
1991,
procedures
were not updated
to reflect the
new requirements,
nor were the
TS pages
changed,
FPKL indicated that the changes
were in the process
and will be
completed
by September
13,
1991.
~
~
~
~
10.
TS 4.7.9. I.c Fire Rated Assemblies
Reviewed procedure
0-SHE-0163.
seal inspection"
for
compliance
with
the
surveillance
requirements
and
Appendix
R
requirements.
Reviewed the last surveillance
performed in June
1991.
Comments:
Acceptable.
TS 4.7.8. 1. I.d - Fire Water
and Distribution System
Reviewed procedure
O-SMM-016.1, "Fire suppression
system annual flush" for
compliance with the TS surveillance requirement
and also reviewed the test
performed in February
1991.
Comments:
Acceptable.
12.
TS 4.7.8. 1. l.g - Fire Protection
System
Reviewed Procedure
O-OSP-016029,
"Fire Hain three year Hydraulic gradient
flow test" for compliance
with
TS surveillance
requirements
and
also
serviced
the results of the tests
performed in 1989.
Comments:
Acceptable.
A few exceptions
were
noted
above,
but were corrected
immediately.
The
team
concluded
the
new
TS
had
been
appropriately
incorporated
into
operation,
calibration
and surveillance
procedures.
No violations or deviations
were identified.
5.3
Tracking Plant Activities
15
- Equipment
Out of Service Controls
- Limiting Conditions for Operation
(LCO) Tracking
- Tracking Maintenance
and Surveillance Activities
The licensee's
mechanism for identifying and tracking
Mode change operability
requirements
encompassed
a computer data
base
and the software to generate
TS
surveillance
requirement
schedules
and reports.
This data
base
and software
accomplished
the tasks which were previously performed manually.
The new system
was being
used to identify and track
Mode change
requirements
for the current
Mode
5 to 4 transition.
The
computer
data
base,
which
was
established
during the'resent
outage,
identified all TS surveillance requirements, their Mode application, performance-
,
. responsibility, frequency,
and other pertinent .data for tracking and performance.
The team reviewed the
Mode change report generated
by the software
program for
the current plant conditions to verify applicable
requirements
from the
TS for
Mode
4 had
been identified.
No discrepancies
were identified by the team.
A
Mode change report for Mode
2 was similarly reviewed to verify, by sample, that
appropriate
TS requirements
were identified by the system for entry into Mode
2
from Mode 3.
No discrepancies
were identified.
Based
on this sample,
the team
concluded the licensee's
mechanism for identification of Mode change requirements
was adequate.
The Mode change report
was tracked in the control
room by the Plant Supervisor
Nuclear.
This document
was initialed and dated for each surveillance
as it was
completed.
Discussions
with
the
on-shift
demonstrated
the staff
was
knowledgeable
of the
process
and
current
status
of outstanding
surveillance
requirements.
The operating procedure for Mode change,
3-GOP-503,
Cold Shutdown
to
Hot
Standby,
dated
August
30,
1991,
contained
verification
sign-offs
referencing completion of the Mode change report.
Based
on this review, the team
concluded
the
licensee's
mechanism
for tracking
performance
of
Hode
change
requirements
was adequate.
The team additionally reviewed the application of the new computer based
process
to routine
TS surveillance activity.
A daily task
sheet
is generated
which
identifies
TS surveillances
due within a current
7 day window.
This information
is carried
in the
Plan
of the
Day which receives
daily
management
review.
Surveillance requirements
entering the grace period or separately listed in the
POD for increased
management
attention.
Responsibility
for administrative
control of the surveillance tracking program were
assigned
and
personnel
were
knowledgeable
of their duties
and responsibilities.
Equipment out of service
documentation
was
routed
through
the
surveillance
coordinator,
facilitating
verification that
appropriate
TS operability requirements
were
met prior to
declaring the equipment operable.
The team reviewed the
PODs during the week and
verified the currently iidentified surveillances
applicable
in this 'Mode were
being tracked.
Based
on this review,
the
team
concluded that the licensee's
mechanism for identification and tracking of routine TS surveillance requirements
was adequate.
No violations or deviations
were identified.
16
6.
~Securit
Through observation,
testing,
review of documentation,
and evaluation of the
licensee's
organization
and staffing, security plan,
access
control function,
alarm response,
communications,
and training, it was determined that the security
function was capable of supporting the restart of Units
3 and 4.
6. 1
Management
Support
Review of the security program functions and observation of security operational
activities revealed that the program
was effectively managed
and that -security
resources
were
being utilized in
an efficient
manner.
The security
force
provided
by Security
Bureau,
Incorporated,
consisted
of approximately
270
personnel
assigned
to
two shifts
that
provide
security
protection
for the
facility on
a 24-hour basis.
The contract security force includes
a supervisor
and administrative
elements
to support the security shift operations.
Based
on observation
and discussion with security personnel
during the course of
the inspection, it appeared that the security organization
was adequately
managed
and that communication
between plant management
and the contract security force
was sufficient to ensure
the maintenance
of good working relations,
morale,
and
motivation of the security force.
Support of the security
program
by senior
plant management
was evident.
6.2
Security
Program
Plans
Review of current
security
plans
and
discussions
with security
management
determined
that
security
operational
activities
were
being
performed
in
accordance
with the
provisions
of Revision
0 to the
Turkey
Point
Physical
Security Plan,
placed in effect
on July 1,
1991.
The licensee
had established
implementing procedures for use by the security force to facilitate adherence
and
compliance
with the
security
plan
commitments.
Review
confirmed
that
the
security
plan
and
implementing
procedures
were current
and
provided
adequate
guidance for security force implementation of regulatory requirements.
Although
the central/secondary
alarm station
(CAS/SAS)
procedures
were
developed,
the
licensee
continues
to update
the
CAS/SAS procedures
as the total alarm systems
are integrated.
e
17
6.3
Protected
and
Vital
Area
Access
Control
of Personnel,
Packages,
and
Vehicles
Observation
of personnel,
package,
and vehicle
access
control activities
at
personnel
access portals
and vehicle gates revealed that positive access
control
procedures
have been established
to provide control of access
into the protected
and vital
areas.
Personnel
are
issued
security
badges
wh'.ch
includes
an
electronic
key card
and
are
searched
either
by processing
through
metal
and
explosive detection
equipment or
a hands-on
search
by security personnel
prior
to being granted
access
into the protected
area.
Access into the protected
area
is
accomplished
by
passage
through
electronically
controlled
turnstiles.
Security
personnel
positioned
within bullet-resistant
enclosures
have
the
capability of locking
down the turnstiles
to preclude
entry to the protected
area.
access
to vital areas
is controlled by key card
and intrusion detection
equipment.
Security personnel
provide response to attempted unauthorized entry.
All hand-carried
items are
scanned
by X-ray equipment prior to access
into the
protected
area.
guestionable
items are hand-searched.
Routine vehicle access
into the protected
area is accomplished
at
a vehicle gate
located
on the south side of the site.
Vehicles entering the protected
area are
enclosed
within a vehicle
entrapment
area
where
they are
searched
and
access
authorization verified prior to entry.
Observation of vehicle access
and search
activity during the period of the inspection did not identify any discrepancies
or deficiencies
in the control of vehicle access.
6.4
Alarm Station
and Communications
Observation
of routine security
operational
activities
in the
Central
Alarm
Station/Secondary
Alarm Station
(CAS/SAS) during regular
and non-regular
hours
confirmed
that
the
alarm
station
was
equipped
with
appropriate
alarm,
surveillance,
and communications capability in accordance with commitments of the
approved
Physical
Security Plan.
The alarm station
was continuously
manned
by
trained
and experienced
operators
and was independent
and diverse to the extent
that
no single act could remove the security force's capability of calling for
assistance
or otherwise
responding
to
a threat.
There
were
no
operational'ctivities
observed
in the
CAS that
would interface
with the
execution
of
assessment
and response
functions.
The alarm station demonstrated
the ability
to communicate with all security personnel
assigned to armed response
duties
and
fixed posts.
On
September
10,
1991,
the
team
discussed
with the
licensee
and
contractor
personnel
the status
of the computer
and its capability to support the site's
alarm system,
All personnel
present
indicated that they believed that:
1,
As
of this
date,
the
computer
system
would
support
the
site
exterior/interior alarm system,
2.
Other than those
zones
and vital doors
which are not operational,
the intrusion alarm system would cause
an alarm when
a zone or door
alarm was generated.
18
3
There were
no concerns that when all alarm points are tied in, that
the
computer
would overload
or not
be
capable
of functioning
as-
designed.
The
system
cannot
be altered
without the
knowledge of other site
personnel.
6.5
Security Training and gualification
Discussion
with
security
management
and
observation
of
personnel
during
,performance
of their duties,
confirmed
that
the
security
force
had fully
implemented
and
was
in
compliance
with
provisions
of
the
Training
and
gualification
Plan'.
The training
program
is
administered
by
a proprietary
training
supervisor,
assisted
by contractor
training
personnel.
Based
on
observation
of security
operational
activities
and
discussion
with several
members
of the
security
force, it appeared
that
personnel
were
adequately
trained,
motivated,
and capable of providing an acceptable
level of protection
for the power plant facility and vital resources.
6.6
Vital Areas
In addition to the above areas,
the team observed
the licensee's
security force
efforts
on September
11,
1991, to search,
test,
and secure
the protection aids
to support the vital equipment required for Node 4.
The vitalization began at 0800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br />,
and concluded at approximately
1645 hours0.019 days <br />0.457 hours <br />0.00272 weeks <br />6.259225e-4 months <br />.
At the conclusion of the efforts on September
11, 1991,
one compensatory
post was
established
due to door equipment
problems,
and one other compensatory
post was
established
because
of
a barrier
opening
that
exceeded
the
96
square
inch
criteria.
The auxiliary building was vitalized on September
12,
1991,, or prior
to Mode 4.
It was noted that the licensee
decided
not to 'search existing high
radiation
areas
prior to vitalization of the auxiliary building to preclude
exposing security personnel
to radiation.
No violations or deviations
were identified.
7.
ENGINEERING AND TECHNICAL SUPPORT
7. 1
Operator
and Technical Training
The
inspectors
interviewed
training
department
management
to
determine
the
licensee's
program for incorporating
system
and
procedure
changes
into the
licensed
operator requalification
and initial training programs.
Changes
to a
particular
system
were
found to
have
been effectively reviewed for training
requirements.
Changes
requiring
additional
training. were
included
in the
training program.
This included shift training, requalification training
and
initial training.
Procedure
changes
are analyzed
by the training department
to determine training
requirements,
Those changes that are of a minor nature are incorporated into the
required reading list.
The current initial class
was found to be up to date
on
the required reading list.
19
As a subset of the new equipment walkdown, the team observed training tools that
had
been
set
up
by the
licensee
on
the
new
equipment.
The following was
observed.
The training staff
had
a working
sequencer
installed
in the training
building that had been utilized in actual training of Instrumentation
and
Control
and operations
personnel.
The training staff had installed
a partially working panel of the Unit 4
EDG start
control
panel
in
the. training
building.
The
electrical
maintenance
staff
had
trained
on
the
unit
and will requalify
on it
periodically.
The licensee
stated
that within the next year,
a
small
diesel
which was already
on site would be hooked
up to the Unit 4 training
EDG control
cabinet
in the training building to
more closely
simulate
actual
operation.
It is noted that the Un'it 3 and Unit 4 control panels
were similar but not identical.
Recognizing this, the operations staff
had
relied
on .in-plant
EDG training of its
licensed
and
nonlicensed
operators,
During the course of startup testing,
the Unit 4 diesels
were
started
35- times
and
the Unit
3 diesels
were started
in excess
of
25
times.
The Unit 4
have
been operated
over 300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br />
each.
Additionally in the training building, the training staff has installed
new breakers of the
same type as those recently installed in the new load
center positions
and motor controller positions.
These
have
been
used for
plant staff familiarization.
For the
new dual unit
RTD instrument modifications,
the control cabinet
has
been installed in the control
room simulator.
The operators
normally
disable/re-enable
bistables
in .their protection
equipment
as required.
The
bistables
have
not
been
available
for installation
in
the
simulator rack but this was intended.
Simulation
of the
new electrical
systems
and
the
sequencer
soft
and
hardware (switches, indicator, etc.)
have been installed and trained
on in
, the control
room simulator by the operators that will perform the upcoming
Unit 3 startup.
In summary,
the team considered that the use of actual
equipment in the training
process
was
a positive point in the inspection,
No violations or deviations
were identified.
7,2
Temporary Alterations/Modifications Control
Inspectors
reviewed the log of Temporary
System Alterations
(TSA) and found it
maintained in accordance with 0-ADM-503. All TSAs for the required
Mode changes
had
been
completed,
Efforts were being reasonably
made to review and minimize
the number of TSAs.
No violations or deviations
were identified.
is
20
7.3
Human Factors
Review of Control
Room and Local Control
Panel
Changes
The team reviewed the control
room and local control panel revisions associated
with the Emergency
Power System
(EPS)
Enhancement
Project.
The review consisted
of:
(1)
an
evaluation
of
the
documentation
supporting
the
control
panel
modifications;
(2) review of the modifications through plant
and control
room
walkdowns of the affected
panels with operations staff;
and
(3) review of the
resolutions to the
human engineering discrepancies
(HEDs) identified during the
design process.
The
team
reviewed
the
licensee's
documentation
(Appendix
8)
supporting
the
control panel modifications to ensure the design process
adequately incorporated
human factors
engineering
principles described
in NUREG-0700,
"Guidelines for
Control
Room Design Reviews."
The. team-found that the licensee
had implemented
an adequate
process to: identify important operator actions associated
with .the
EPS,
identify controls
and
indications
necessary
for
those
actions,
and
incorporate
accepted
human factors principles into the'esign
of the control
panel modifications.
The
team
reviewed
the control
room
and local
control
panel
modifications to
ensure that the operations staff recognized
and understood the modifications,
and
to ensure that the appropriate
controls
and indications necessary
for operator
activities had been incorporated into the modifications.
The team found that the
operations staff recognized
and understood
the modifications,
and were capable
of performing the activities associated
with the affected control panels.
The
team
found that
indications
and
controls
were
adequate
for performing
the
required activities.
The team reviewed the resolutions to the HEDs identified during the control panel
design
and validation process.
In most
cases
the licensee
has
incorporated
adequate
design modifications to resolve the HEDs identified, and had adequately
documented
the resolutions.
However, the licensee did not adequately
address
the
one major control panel
HED identified during the performance validation process
(PA-SEI-EPS.02,
Discrepancy ¹I) related
to distinguishing
between
the diesel
"emergency start"
and "rapid start" controls.
The team reviewed the discrepancy
with the licensee,
and
the licensee
initiated the appropriate
administrative
controls to resolve
the
concern.
In 'addition,
resolutions
to several
minor
discrepancies
identified
in the validation
report
(PA-SEI-EPS.02)
were
not
documented.
The licensee
stated
that they will document
the resolutions for
these
minor discrepancies.
No violations or deviations
were identified.
7.4
EOP Follow-up Inspection
(Inspection
Report
No. 50-250
5 50-251/91-33)
The team
ass'essed
the licensee's
corrective actions
associated
with the
human
factors findings from the Emergency Operating Procedures
follow-up Inspection (IR
No. 50-250
5. 50-251/91-33),
dated
September
3,
1991.
The licensee
implemented
~
~
~
procedural
revisions
and
control
panel
modifications
in
response
to
the
inspection
report
findings.
The
team
found
that
the
licensee
adequately
C
21
addressed
the minor discrepancies
identified in Section
7 of IR No. 50-250
8 50-
251/91-33,
these
items are therefore
considered
closed.
With regard to the inspection team finding related to the actions taken to verify
containment integrity following a phase
A or phase
B isolation (IR 50-250 850-
251/91-33,
Section
2),
the
licensee
is
incorporating
additional
procedural
guidance into the
EOPs to help ensure
appropriate
operator actions to allow for
local or manual isolation of the affected containment penetrations.
This is more
consistent
with actual. isolation
methodology.
The
team
finds
the
proposed
actions to be adequate.
No violations or deviations
were identified.
8.
EXIT MEETING
On September
13,
1991,
the team conducted
an exit meeting at the Turkey Point
site.
The licensee
and
NRC personnel
attending
this meeting
are listed in
Appendix D.
The licensee did not provide any materials identified as proprietary
to the team.
During the exit, the team summarized
the scope
and findings of the
inspection.
There were no dissenting
comments from the licensee of the findings.
APPENDIX A
ABBREVIATIONS AND ACRONYHS
ADM
CNRB
DUO
ONOP
OP
PC/H
PH
PHT
PNSC
PWO
SATS
Administrative Procedure
Assistant
Plant Supervisor
Nuclear
Balance of Plant
Component
Cooling Water
Company Nuclear Review Board
Dual Unit Outage
Emergency
Core Cooling System(s)
Emergency Diesel
Generator
Equipment out of Service
Emergency Operating
Procedure
Florida Power 5 Light
Minor Engineering
Package
Nonconformance
Reports
Out of Service
Off Normal Operating
Procedure
Operating
Procedure
Operations
Surveillance
Procedures
Plant Change/Modification
Preventive
Maintenance
Post Maintenance
Testing
Plant Nuclear Safety Committee
Plant Operation
Document
Plant Supervisor
Nuclear
Plant Work Order
Residual
Heat
Removal
System Acceptance
Turnover group
System Acceptance
Turnover Sheet
Safety Injection
Test Exception Report
References
for Para ra
h 3.1
APPENDIX
B
PROCEDURES
REVIEWED
Procedures
for the new equipment
have been issued to support the startup.
Aside
from the
EDG surveillance
procedures
(OP-023),
the sequencer
tests
(OSP-24.2),
and procedures specifically mentioned other places in this report, the following
procedures
were sampled for completeness
and not content:
0-PME-003. 1,
DC Load Center Undervoltage
Relay Maintenance,
9/8/88
3-OP-005',
4160
Buses A,B, and
D, 8/27/91
4-0P-005,
4160
Buses
A, B,
and
D, 8/27/91,
0-OP-003. 1,
125 Vital
DC System,
8/30/91
3-0P-023,
Emergency Diesel
Generator,
8/16/91
4-0P-023,
8/16/91
O-OP-024,
Emergency
Bus
Load Sequencer,
8/16/91
O-OSP-024.2,
Emergency
Bus
Load Sequencer
Manual Test,
8/16/91
0-PMI-024. 1,
Emergency
Bus
Load Sequencer
18 Month Maintenance,
8/22/91
MI 59-010,
AMSAC Cabinet Calibration
and Test Instruction,
2/4/91
3-OP-49. 1,
ATWS Mitigating System Actuation Circuitry (AMSAC),6/26/91
4-OP-49. 1,
ATWS Mitigating System Actuation Circuitry (AMSAC), 6/26/91
The above
procedures
were complete
and
no problems
were identified.
References
for Para
ra
h 4.2
0-ADM-101
O-OP-003.4
0-OP-24
3-OP-023
3-ONOP-004
3-ONOP-030
3-OP-030
4-OP-050
4-GOP-301
4-OP-023
~ 2
Procedure Writer's Guide
Auxiliary 120 Volt AC System
Emergency
Bus
Load Sequencer
Emergency Diesel
Generators
Loss of 3A 4KV Bus
Component
Cooling Water Malfunction
Component
Cooling Water System
Residual
Heat
Removal
System
Hot Standby to Power Operation
Emergency Diesel
Generators
8/06/91
8/30/91
8/16/91
8/16/91
7/09/91
6/19/91
7/09/91
8/19/91
8/09/91
8/16/91
References
for
ara ra
h 7.3
0-ADM-006
PTN-90-0381
PA-ESI-EPS. 01
PA-ES I-EPS. 02
FL0-53-20.5006
Human Factors
Review Program,
3/07/91
Turkey Point - Unit
3
8
4
Enhancement
Project
Nuclear
Safety Related Transmittal of Minutes of Meeting, 4/04/90
Enhancement
Project
Human
Factors
Engineering
Review,
Preliminary Review, Revision 0, 8/31/90
Enhancement
Project
Human
Factors
Engineering
Review,
Performance
Validation Final Report,
Revision 0, 6/30/91
Enhancement
Project
Human
Factors
Engineering
Package,
Revision 2, 8/06/91
APPENDIX C
DRAWINGS REVIEWED
A
comparison
was
made
between
document
control
records
regarding
drawing
distribution.
The team obtained
copies of the following:
controlled document status file (line number listings) - this was the
gA
record total population of "POD 1" drawings;
immediate distribution
acknowledgement list - this listed
the
drawing
distributed
to various departments/locations
which
was
a subset
of the
above;and,
W
drawing index control
system,
operation
and logic diagrams,
5610-T-D-l,
revision
27 - this was the index for drawing deemed critical to the plant
that is found in the control
room and listed
a subset of drawings from the
immediate distribution list.
The population
sampled
was
as follows:
drawing
sheet
revision
component
5610-E-0855
5610-E-0855
5610-T-E-1591
5610-T-E-4501
5610-T-Li
5610-T-Li
5610-T-Li
5610-T-Li
5613-T-Li
5613-T-Li
5614-T-L i
5614-T-Li
B2
196
1
1
9C1
9Dll
12A
33A
33B
33A
33B
284
285
9
97
2
1
20
12
0
Unit 3
0
Unit 3
0
Unit 4
0
Unit 4
breaker list
II
electrical distribution
system
sequencer
ANSAC
Except
as
noted
below,
drawings for ne'w equipment
were
checked
in the control
room
and the
TSC with good results.
The
above listed drawings
also
had the
appropriate
revisions.
The list four drawings listed above were for the AHSAC.
These drawings were not
filed chronologically in the control room and in the TSC due to the fact that the
index drawing 5610-T-D-1
had not but updated
to reflect these
new drawings in
their expected order.
Additionally, there was misfiling error between
two of the
control room binders of drawings regarding these
same
ANSAC drawings.
The filing
clerks
wee uncertain
as to where to file the
new 5613
and
5614 series
drawings.
Additionally, the old telemand transfer drawing (5610-T-Li 28A and 29A) that was
replaced
by the
new sequencer
and
new
EDGs equipment
and drawings
were still
listed in the index drawing.
After finding the swapped
sheet drawings for ANSAC
as
a quick check, operations did a audit of their control room drawings per their
e
distribution list with no negative results,
Appendix
C
The above mentioned discrepancies
were considered
minor in light of the massive
changes that have occurred to the drawing files.
By September
27,
1991,
Design
Change
Request
TPH-91-221 will provide disposition for drawing 5610-T-D-l, the
drawing index, that will either declassify,
remove, or reorganize the drawing as
agreed to by engineering
and operations.
APPENDIX
D
EXIT ATTENDANCE
Licensee .Employees
at Exit on September
13,
1991
T.
L.
T.
R.
G.
S.
D.f.
D.
R.
A.
S.
D.
D.
J.
D.
R.
J.
H.
J.
J.
V.
f. Plunkett,
Vice President
W. Pearce,
Plant Manager
Abbatliello, Supervisor
gA
E.
Rose,
Design Control Supervisor
E. Hollinger, Operator Training Supervisor
Salamon,
License Supervisor
Sisk,
Reactor Licensing Engineer
R. Timmons, Security Superintend
J. Davis, Security
L. Teuteberg,
JPN
T. Zielonka, Technical
Department Supervisor
T. Hale, Plant Engineering
Manager
C. Poteralski,
Manager,
Nuclear fuel
W. Haase,
ISEG Chairman
D. Lindsey,
HP Supervisor
R. Powell, License Superintend
J. Earl,
gC Superintend
E. Crockford, Operations
Support Supervisor-
B. Wayland,
Maintenance
Supervisor
Arias, Jr. Technical Advisor to Vice President
D. Webb,
Planning
8
Sch
A. Kaminskas,
OPS Superintendent
NRC Representatives
at Exit
S.
J.
T.
K.
H.
R.
G.
R.
Rubin, RII
Hilhoan, RII, Deputy Regional Administrator
Peebles,
RII
Landis, RII
Ernstes,
RII
Butcher,
Senior Resident
Inspector
.
A. Schnebli,
Resident
Inspector
Auluck,
G. Galletti,
L.
R. Moore, RII
Trocine,
Resident
Inspector
Scott,
Resident
Inspector
L.
H.
0