ML17349A268

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Insp Repts 50-250/92-10 & 50-251/92-10 on 920404-0501. Violations Noted.Major Areas Inspected:Monthly Surveillance Observations,Monthly Maint Observations,Engineered Safety Features Walkdowns Operational Safety & Plant Mods & Events
ML17349A268
Person / Time
Site: Turkey Point  
Issue date: 05/29/1992
From: Butcher R, Schnebli G, Trocine L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML17349A266 List:
References
50-250-92-10, 50-251-92-10, NUDOCS 9206150056
Download: ML17349A268 (22)


See also: IR 05000250/1992010

Text

1

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W., SUITE 2900

ATLANTA,GEORGIA 30323

Report Nos.:

'50-250/92-10

and 50-251/92-10

Licensee:

Florida Power

and Light Company

9250 West Flagler Street

Miami, 'FL 33102

Docket Nos.:

50-250

and 50-251

License Nos.:

DPR -31 and

DPR -41

Facility Name:

Turkey Point Units

3 and

4

Inspection

Conducted:

Apri 1

4

rough

May 1,

1992

Inspectors:

C. Butch r,

enior Resident

Inspector

Dat

Sig ed

A. Schneb

, Resi

t Inspector

Dat

S'gn

d

Trocine,

Res dent Inspector

t

Accompanying Personnel:

RE

P. Schin, Project Engineer

M. N.

er,

Region II Inspector

Dat

Sign

d

Approved by:

K.

D.

and

,'hief

Reactor Projects

Section

2B

Division of Reactor Projects

Dat

Sig ed

SUMMARY

Scope:

This routine resident

inspector

inspection

involved direct inspection

at the

site in the .areas

of monthly surveillance

observations,

monthly

maintenance

observations,

engineered

safety features

walkdowns,

operational

safety,

plant

modifications

and plant events.

Results:

Within the

scope

of this

inspection,

the

inspectors

determined

that

the

licensee

continued to demonstrate

satisfactory

performance

to ensure

safe plant

operations.

The inspectors identified two violations,

one non-cited viola'tion,

and

one weakness

as noted below.

e

50-250,251/92-10-01,

Violation - Failure to follow a procedure resulting in the

removal of a Unit 4,

Channel

A, refueling water

storage tank level transmitter

q20b

oCK 05ppp25

15005b 920529

pDR

IIII

pDR

9

from service

during the calibration of

a Onit 3,

Channel

B, refueling water

storage

tank level transmitter (paragraph

5).

'0-250,251/92-10-02,

Non-Cited Violation - Failure to test diesel

fuel oil for

sulfur or content

per

the test

method specified

in Technical

Specification'.6.1.1.2.e

(paragraph 9.a).

50-250,251/92-10-03,

Violation - Failure to follow procedures for changing out

the

nitrogen

backup bottle. for the

3A

and

3B main

steam

isolation valves

(paragraph

9.d).

Weakness

Incomplete description

in the Final Safety Analysis

Report of the

functions of the main

steam isolation valve nitrogen/accumulator

backup

system

(paragraph

9.d).

REPORT DETAILS

Persons

Contacted

Licensee

Employees

T. V.

R. J.

R. j.

K. N.

E.

F.

R.

G.

D.

E.

H.

H.

V. A

J.

E.

R.

S.

J.

D.

J.

T.

G.

L.

L.

W.

M. 0.

T.

F.

D.

R.

R.

N.

F.

R.

M. B.

J.

D.

E. J.

Abbatiello, Site Quality Manager

Earl, Quality Assurance

Supervisor

Gianfrencesco,

Support Services

Supervisor

Harris, Senior Vice President

Nuclear Operations

Hayes,. I 8

C Maintenance

Supervisor

Hei sterman,

Mechanical

Maintentance

Supervisor

Jernigan,

Technical

Manager

Johnson,

Operations

Supervisor

Kaminskas,

Operations

Manager

Knorr, Regulatory

Compliance Analyst

Kundalkar, Engineering

Manager

Lindsay, Health Physicist Supervisor

Luke, Engineering

Manager

Marsh,

Reactor

Engineering Supervisor

Pearce,

Plant General

Manager

Pearce,

Electrical Maintenance

Super visor

Plunkett, Site Vice President

Powell, Service

Manager

Steinke,

Chemistry Supervisor

Timmons, Security Supervisor

Wayland,

Maintenance

Manager

Webb,

Outage

Manager (Acting)

Weinkam, Licensing Manager

Other

licensee

employees

contacted

included

construction

craftsman,

engineers,

technicians,

operators,

mechanics,

and electricians.

NRC Resident

Inspectors

RE

C. Butcher,

Senior Resident Inspector

G. A. Schnebli,

Resident

Inspector

L. Trocine, Resident

Inspector

Additional

NRC Inspectors

R.

P. Schin, Project Engineer

M. N. Miller, Region II Inspector

" Attended exit interview on

May 1,

1992

Attended exit interview on April 24,

1992

Note:

An alphabetical

tabulation of acronyms

used in this report is listed

in the last paragraph

in this report.

~,

Plant Status

~Un4t

Unit At the beginning of this reporting period, Unit 3 was operating at 87

percent

power in order to extend the unit run time until the beginning of

the

August

24,

1992, refueling outage.

Unit 3

had

been

on line since

February

5,

1992.

The following evolutions

occurred

on this unit during thi s

assessment

period:

On April 9,

1992, at 5:30 a.m.,

a load reduction to 50 percent

power

was

commenced

to facilitate

the

cleaning

of the

3A

TPCW

heat

exchanger

and of all four waterboxes.

(Refer to paragraph

9.b for

additional information.)

On April 9, -1992, at approximately 6:30 a.m., Unit 3 reached

50 per-

cent power,

On April 10,

1992, at 12:55 a.m.,

power ascension

was

commenced.

On April 10,

1992,

at 4:05, a.m.,

Unit 3 reactor

power

reached

87

percent,

and

reduced

power

operations

at this

power

level

was

recommenced.

On

April 27,

1992, at 9:33 a.m.,

a power reduction

was initiated due

to an increase

in the

3C

RCP

number

1

seal

leak rate.

Unit 3 trip

breakers

were

opened

at

10:33

a.m.

(Refer to paragraph

9.g for

additional information.)

Unit 4

At the beginning of this reporting period,

Unit 4 was operating

at

100

percent

powe~

and

had

been

on line since

March 28,

1992.

The following

evolutions occurred

on this unit during this assessment

period:

On Apri'l 28,

1992, at 4:00 a.m., Unit 4 reactor

power was reduced to

approximately'7

percent

for reactor

engineering flux maps (axial

offsets).

On April 28,

1992, at 6:45 p.m.,

reactor

power

was returned to 100

percent.

3.

Onsite

Followup

and

In-Office Review of Written Reports

of Nonroutine

Events

and

10 CFR Part 21 Reviews (90712/90713/92700)

The

Licensee

Event Report discussed

below was

reviewed.

The inspectors

verified that reporting requirements

had been met, root cause

analysis

was

performed,

corrective

actions

appear ed

appropriate,

and

generic

applicability had

been

considered.

Additionally, the inspectors verified

the licensee

had reviewed the event, corrective actions were

implemented,

responsibility for corrective

actions

not fully completed

was clearly

I

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 Part 2, Appendix C, were applied.

(Closed)

LER 50-250/90-12,

A Postulated

Failure of a Single Manual

Reset

Pushbutton

Could Render Both Trains of Containment

Spray Inoperable:

On June

13,

1990,

the licensee notified the

NRC of a significant event in

accordance

with 10 CFR 50.72

concerning

a potential

single failure of

Westinghouse

OT-2 switches

used

in various safety-related

systems.

This

issue

was previously discussed

in

LER 50-250/89-18,

which was closed in IR

50-250,251/90-40.

LER 50-250/89-18 identified a problem with Westinghouse

OT-2 switch at Turkey Point similar to that discovered

at other utilities

but

failed

to

examine

the

problem

generically.

Subsequently,

LER

50-250/90-12

was

issued

identifying other safety-related

applications

of

the Westinghouse

OT-2 switch..

This issue

was also previously discussed

in

IRs

50-250,251/90-18

,and

50-250,251/90-19.

The

licensee'

corrective

actions

were reviewed

and found to be adequate.

This,LER is closed.

4.

Monthly Surveillance

Observations

(61726)

The inspectors

observed TS-required surveillance testing

and verified that

the test procedures

conformed to the requirements

of the TSs; testing

was

performed

in accordance

with adequate

procedures;

test instrumentation

was

calibrated; limiting conditions for operation

were met; test results

met

acceptance

criteria requirements

and were reviewed

by personnel, other than

the

individual directing

the test;

deficiencies

were

identified,

as

appropriate,

and

were

propel ly

reviewed

and

resolved

by

management

personnel;

and

system restoration

was adequate.

For completed tests,

the

inspectors verified testing frequencies

were met and tests

were performed

by qualified individuals.

The

inspectors

witnessed/reviewed

portions

of

the

following test

activities:

4-SMI-071.5,

Steam Generator

Protection

Set III (QR-18)

Analog Channel

Test,

and

4-OSP-059. 10, Determination of Quadrant

Power Tilt Ratio.

The inspectors

determined that the

above testing activities were performed

in a satisfactory

manner

and met the requirements

of the TSs.

Violations

. or deviations were not identified.

5.

Monthly Maintenance

Observations

(62703)

Station

maintenance

activities of safety-related

systems

and

components

were observed

and reviewed to ascertain

they were conducted in accordance

with approved procedures,

regulatory guides,

industry codes

and standards,

and in conformance with the TSs.

The following items

were considered

during this review,

as appropriate:

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 systems

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 housekeeping

was actively pursued.

The

inspectors

witnessed/reviewed

portions of the following maintenance

activities in progress:

troubleshooting

and repair of the

3B

ICW pump discharge

check valve

failure,

troubleshooting

the Unit

3

RPI circuitry to determine

cause of,a

runback (see

paragraph 9.e),

and

troubleshooting

and

replacement

of the

RCP

No.

1

seal

due

to

increased

leakage.

At 1:35

p.m.

on April 2,

1992, the Unit 4

RCO received

an

RWST low level

alarm

and discovered that the

RWST level indicator (LI-4-6583A) had failed

low.

A 7-day

LCO was entered

per

TS

3 ',3.3,

Table 3.3-5 Item 20.

Upon

investigation, it was discovered

that the Unit 4,

Channel

A,

RWST level

transmitter

had

been valved out by I&C personnel

during the performance of

a

calibration

of

the

Unit

3,

Channel

B,

RWST

level

transmitter

(LT-3-6583B).

The Unit 4,

Channel

A,

RWST level transmitter

was valved

back in.

Aft'er a channel

check with the Unit 4,

Channel

B,

RWST level

transmitter,

the

Channel

A level indicator

was returned to service.

The

7-day

LCO was exited at 1:45 p.m.

on the

same day.

The licensee

attributed this event to

a lack of attention to detail

and

the failure of

an

IEC technician

to follow procedure.

The technician

involved was counselled

by the

18

C Maintenance

Supervisor,

and

a Nuclear

Problem

Report

(92-045)

was generated.

The

Human Performance

Enhancement

System

Coordinator

was

also

requested

to review this incident.

As

a

result of this review,

the licensee

plans to incorporate

the use of self

checking

'(stop,

locate,

touch,

verify,

anticipate,

manipulate,

and

observe)

into

the

IEC

Maintenance

Initial

and

Continuing

Training

programs.

The inspectors will follow up

on this action

during future

inspections.

TS 6.8. 1 requires that written procedures

be established,

implemented,

and

maintained covering the activities referenced

in Appendix A of Regulatory

Guide

1.33, Revision 2, February

1978.

Paragraph 8.b(l) of this Appendix

recommends

that

implementing

procedures

be written for each calibration

listed

in the

TSs.

Item ff of this paragraph specifies

procedures

for

water

storage

tank level

instrument calibrations.

Procedure

3PMI-062. 1,

Refueling Water Storage

Tank Level Instrumentation

Channels

LT-3-6583A/B

Calibration satisfies

the calibration

requiremeats

of TS 4.3.3.3,

Table

4.3-4,

Item 20,

RWST, and provides the instructions

and the necessary

data

to ensure

proper calibration and functional testing of the process

control

instrumentation

associated

with the

RWST level indicating

system.

This

procedure

was not followed in that during the calibration of the Unit 3,

Channel

B,

RWST level transmitter

on April 2,

1992; the Unit 4, Channel

A,

RWST level transmitter

was

removed

from service

instead

of the Unit 3,

, Channel

B,

RWST level transmitter.

This failure to follow a procedure

constitutes

a violation and will be

tracked

as

VIO 50-250,251/92-10-01,

fai 1ur e

. to

fol 1 ow

a

procedure

resulting

in the

removal

of a Unit 4,

Channel

A

RWST level transmi,tter

from service during the calibration of the Unit 3,

Channel

B,

RWST level

transmitter.

For those

maintenance activities observed,

the inspectors

determined that

the activities were conducted

in a satisfactory

manner

and that the work

was

properly

performed

in

accordance

with

approved

maintenance

work

orders.

One violation was identified.

Engineered

Safety Features

Walkdown (71710)

The inspectors

performed

an inspection

designed

to verify the status

of

the

4B EDG. This was accomplished

by performing

a complete

walkdown of all

accessible

equipment

and

by utilizing procedure

4-0SP-023.1,

Diesel

Generator Operability Test,

and drawings

5614-M-736,

Sheet

1,

EDG 4A 8

B

PEI Diesel

Oil

8 Service Air P81

Diagram;

5614-M-736,

Sheet

3,

EDG

4B

Diesel Oil, Lube Oil, Cooling 5 Air Systems

P81 Diagram;

5614-M-736,

Sheet

4,

EDG Air Dryer Skid

45235A

& B;

and

5620-T-E-4530,

Sheet

2,

Water

Treatment

Plant Demineralizer Section.

The following criteria were used,

as appropriate,

during this inspection:

systems

lineup

procedures

matched

plant

drawings

and

as-built

configuration;

housekeeping

was adequate,

and appropriate

levels of cleanliness

were

being maintained,

valves

in the

system

were correctly installed

and did not exhibit

signs of gross

packing 'leakage,

bent

stems,

missing

handwheels,

or

improper, labeling;

hangers

and supports

were

made

up properly and aligned correctly;

valves in the flow paths

were in correct position

as required

by the

applicable

procedures

with

power

. available,

and

valves

were

locked/lock wired as required;

local

and

remote

position

indication

was

compared,

and

remote

instrumentaion

was functional;

and

major system

components

were properly labeled.

Some minor drawing and labeling discrepancies

were noted

and were brought

to the atttention

of the

system

engineer

for correction,

Violations or

deviations

were not identified.

7.

Plant Modifications (37828)

The

inspectors

observed

the installation of cathodic protection

in

CCW

heat

exchanger

3B.

This

was

done

per

PC/M 92-014,

under

work request

number

WA920319142431.

The

PC/M,

work order,

and

actual

work were

reviewed in process

and as completed.

This PC/M directed the installation

of four

aluminum

anode

bars in the

ICW side of each

end of the

CCW heat

exchanger.

Each bar

was to be bolted to two two-inch square

blocks of

90/10

cupro-nickel'hich

in turn

were

to

be

welded

to

the

90/10

cupro-nickel

shell of the heat

exchanger.

The

purpose

was to eliminate

galvanic =corrosion of the

aluminum bronze

tubes that

had been occurring.

The inspectors

noted

no deficiencies

in the work or in the records.

8.

Operational

Safety Verification (71707)

The inspectors

observed control

room operations,

reviewed applicable logs,

conducted

discussions

with control

room

operators,

observed

shift

turnovers,

and monitored instrumentation.

The inspectors

verified proper

-valve/switch alignment of selected

emergency

systems,

verified maintenance

work orders

had

been

submitted

as

required,

and verified 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.

By observation

and direct interviews, verification

was

made

that

the

physical

security

plan

was

being

implemented.

The

implementation

of

radiological

controls

and plant housekeeping/cleanliness

conditions

were

also observed.

Tours of the intake structure

and diesel, auxiliary, control,

and turbine

buildings were

conducted

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/structures

to verify proper valve/switch alignment:

A and

B emergency diesel

generators,

control

room vertical panels

and safeguards

racks,

intake cooling water structure,

4160-volt buses

and 480-volt load and motor control centers,

Unit 3 and

4 feedwater platforms,

Unit 3 and

4 condensate

storage

tank

area,'uxiliary

feedwater

area,

auxiliary building.

Ouring tours

of the auxiliary building, the inspectors

identified

the

following minor

discrepancies,

which

were

promptly

corrected

by

the

licensee:

In the

4A

RHR

pump room, the inspectors

found the

B sump

pump motor

ground wire not connected to the motor.

There were

tw'o sump

pumps in

the room,

and the

A sump

pump

'looked to be fn good condition with its

motor ground wire attached.

These

sump

pumps were not classified

as

safety-related

but were support

equipment for the

RHR pump.

When the

inspectors

informed

the

NPS of this

condition,

he

promptly

had

maintenance

personnel

check the

pump and initiated

a work request to

have the ground wire connected.

Within two days,

the ground wire was

connected to the

pump motor.

b.

In the Unit 4 pipe

and valve

room,

the inspectors

observed

a loose

piece of heavy metal

on the floor adjacent

to and touching

the

RCS

letdown radiation monitor.

The piece of metal

was located

so that it

could have

been

bumped or tripped over and

knocked into the radiation

monitor. It looked almost like a support for the radiation monitor,

except

that it was

not bolted to the floor or fastened

to the

radiation

monitor.

The

inspectors

informed 'he

NPS

about

this

condition,

and

he prompt'ly had the loose piece of metal

removed.

The

licensee

routinely

performs

QA/QC audits/surveillances

of activities

required

under its

QA program

and

as

requested

by management.

To assess

the

effectiveness

of these

licensee'udits,

the inspectors

examined

the

status,

scope,

and findings of the following audit reports:

Audit Number

Number of

Findincis

T

e of Audit

QAO"PTN-92-007

QAO-PTN-92-009

TS 3/4.6,

Containment

Systems.

Reactivity Control,

Power

Oistribution

Limits, and Specia'l

Test

Exceptions.

0

QAO-PTN"92-011

RCS, Safety Limits and

Limiting Safety

System

'ettings,

Safety

Limit

Violations.

QAO-PTN"92"013

QAO-PTN"92-014

TS 6.5. 1,

PNSC

March Performance

Monitoring Audit

QAO-PTN"92-017

QAO-PTN-92-018

TS 3/4.7.6,

Snubbers

Training and

Qualification

No additional

NRC followup actions will be taken

on the findings referenced

above

because

they were identified by the licensee's

QA program

audits

and

corrective actions

have either been

completed or are currently underway.

Plant

management

has also

been

made

aware of these

issues.

. As

a result of routine plant tours

and various operational

observations,

the

inspectors

determined

that

the general

plant

and

system material

conditions

were satisfactorily maintained,

the plant security

program

was effective,

and

t

the overall performance of plant operations

was good.

Violations or deviations

were not identified.

9.

Plant Events

(93702)

The following plant events

were reviewed to determine facility status

and

the

need

for further followup action.

Plant

parameters

were

evaluated

during transient

response.

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

'o the

need for additional

NRC response

to the event.

Additionally, the

following i ssues

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.

a

~

On January

23,

1992,

the licensee

received

a fuel oil shipment for

their

EDGS.

TS 4.8. 1.1.2.e requires that the licensee verify within

30 days of obtaining

a

sample of the

new fuel oil that the other

properties

(those

not required prior to addition to the storage

tank)

specified in Table I of ASTM-D975-81 are

met

when tested

in accord-

ance with ASTM-D975-81 except that the analysis for sulfur

may

be

performed

in

accordance

with

ASTM-D129,

ASTM-D1552-79,

or

ASTM-D2622-82.

This analysis

was completed

on January

30,

1992,

and

showed the fuel oil was acceptable.

On April 3,

1992,

during

a

QA

audit, it was

found that the subcontractor

had

used

ASTM-D-4294 for

the fuel oil

sample

analysis for sulfur.

Investigation

showed that

ASTM-D975 had been revised to reflect that sulfur test

methods

D129,

D1552,

D2622

and

D4294

can

also

be

used

for al l

grades

and

the

subcontractor

had

used

the latest version.

On April 14,

1992,

the

licensee

retested

the

EDG fuel oil using ASTM-D129. The results

were

satisfactory (sulfur content less than 0.50K) and correlated with the

~

previous test results.

The vendor was instructed to use only the

TS

approved

methods

as listed

on the purchase

order for future fuel oil

tests.

The failure to test

the

EDG fuel oil for sulfur content

as required

by

TS 4.8. 1. 1.2.e is

a violation.

- However, this violation will not

be subject to enforcement

action

because

the licensee's

efforts in

identifying and correcting the violation meet the criteria specified

in Section

V.G. of the

Enforcement

Policy.

This violation will be

~

tracked

as

NCV 50-250,251/92-10-02,

failure to test diesel

fuel oil

for sulfur content per the test method specified in TS 4.8. 1. 1.2.e.

b.

At 5:30

a.m.

on April 9,

1992,

a

load

reduction

on Unit

3

was

commenced

in order to facilitate the cleaning of the

3A

TPCW heat

exchanger

and all four condenser

waterboxes.

Unit

3

reached

50

percent

power at approximately

6:30

a.m.

on the

same

day,

and power

ascension

was

commenced at 12:55 a.m.

on the following day.

The

87

percent

power level

was re-attained

at 4:05 a.m.

on April 10,

1992,

and reduced

power operations

at this power level

was

recommenced.

C.

At 1:55 p.m.,

on April 17,

1992, the licensee notified the

NRC of a

Significant

Event

in accordance

with

AP

0103.12,

Notification of

Events to the

NRC, and

10 CFR 50.72(b)(1)(ii)(B), In a Condition that

is Outside the Design Basis of the Plant.

After review of IN 91-75,

Status

Head

Corrections

Not

Included

in

Pressure

Transmitter

Calibration Procedures,

and associated

pressurizer

pressure

setpoints

for Turkey Point Units 3 and 4, the license

determined

that the

low

pressurizer

pressure

reactor trip setpoint

was

not adjusted

for

static

head

as

part

of

a

channel

calibration

procedure.

After

adjusting for static

head correction

and accounting for the allowable

margin within 'the current

TSs

, the licensee

confirmed that the plant

is presently operating

in accordance

with the current

TSs which were

implemented

on August 26,

1991.

However,

under

the

TSs in effect

prior to August

26,

1991,

the

licensee

determined

that

the

low

pressurizer

pressure trip setpoint

(if adjusted for static

head

and

assuming

the worst case

instrument error) could have resulted in the

plant operating in a condition outside the design basis of the plant.

This condition

was

documented

in

LER 50-250/92-003,

Operation

With

Improper Pressurizer

Pressure

Transmitter

Calibration,

dated April

22,

1992.

According

to this

LER,

the effect of

a static

head

correction

on the low pressurizer

pressure trip setpoint is currently

under

evaluation,

The

licensee

is

also

conducting

an engineering

analysis

to determine if the safety analysis limit for pressurizer

pressure

of 1790 psig was exceeded

and plans to document the results

of this analysis

in

a

supplement

to the

LER by June

1,

1992.

The

10

inspectors will review the

issue

upon

issuance

of the

supplemental

LER.

d.

At approximately

6:00

a.m.

on April 20,

1992, with Unit 3 operating

at approximately

87% of rated power,

a turbine operator

replaced

the

backup nitrogen supply compressed

gas bottles

on the

A and

B MSIVs on

Unit

3 without the

use of

a procedure.

Each

MSIV has

two backup

nitrogen

supply bottles.

One is normally in service

and

one

in

standby,

isolated

from the

header.

Prior to replacing

a nitrogen

bottle, the

standby bottle

should

be placed

in service

and the

low

pressure

bottle

should

be isolated

from the header.

During nitrogen

bottle replacement

on this day, both bottles for the

A MSIV were left

isolated

and both bottles for the

B MSIV were also left isolated.

The

A and

8 MSIVs were considered

inoperable.

At 8:30

a.m. that

same

day, the Unit 3 turbine operator,

as part of

the next normal log taking in accordance

with Operations

Surveillance

Procedure

3-0SP-201.3,

NPO

Daily

Logs,

discovered

the

valve

misaligments

and notified the

NPS.

At 8:43 a.m.,

the

backup nitrogen supply system lineup was restored

in accordance

with 3-0SP-072.2,

MSIV N2 Backup Periodic Test.

The licensee

took the following corrective actions:

The

A and

B MSIVs were returned

to service

in accordance

with

procedures

as

soon

as the valve misalignment

was identified.

The following safety-related

systems

for both Units

3 and

4 were

walked down by the system engineers

or operations

personnel

for

alignment verification in accordance

with the appropriate

system

alignment verification procedures:

Intake Cooling Water

Component

Cooling Water

Boric Acid System

, Post Accident Containment

Vent System

Containment

Spray

Auxiliary Feedwater

High Head Safety Injection

Residual

Heat

Removal

System

.124 Volt Vital DC

Startup Transformer

On-site

AC Distribution

Post-accident

Hydrogen Monitoring System

No other incorrect valve or breaker alignments

were found.

.The turbine operator

and his supervisor

were disciplined.

11

Each operations

crew,

including both licensed

and non-licensed

operators,

met 'with plant

upper

management

to reinforce

the

necessity

and

requirement

to

use

procedures

with

verbatim

compliance

on safety-related

systems

when performing

even

the

most

routine

operation.

The details

of this

event

were

the

focus of these

meetings.

The activities of the non-licensed

operator during the mid-shift

of April 20,

1992,

were

reviewed.

No other

anomalies

were

noted.

An independent

Human

Performance

Evaluation

System

review is

being

performe'd

and will be

complete

by April 30,

1992,

to

ensure that all

human factors

causes

are evaluated.

Technical Specification (TS) 6.8. 1 requires

written

procedures

be

established,

implemenmted,

and

maintained

covering

the activities

recommended

in Appendix

A of Regulatory

Guide

1.33,

Revision

2,

February

1978,

and Sections

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

Para-

graph

3

of

Regulatory

Guide

1.33,

Appendix

A

recommends

the

establishment

of written procedures

for operation

of safety-related

systems.

Section

5. 1.2 of ANSI N18.7-1972

requires

that procedures

be followed.

Procedure

0-AD

M -201,

Upgrade

Operations

Usage,

paragraph

5.1,

Procedural

Adherence Policy, states

in part that procedures

shall

be

present

during

performance

of tasks

for which verification is

documented

by initial or signature.

Procedure

3-OP

072,

Main Steam

System,

paragraphs'.

1

and 7.2, define

the

steps

required to place

the

MSIV backup nitrogen bottles in service and/or in standby.

These

steps require initials for the operator

and

second verification.

However,

on

April

20,

1992,

'

turbine

operator

replaced

the

in-service

Unit

3

A and

B MSIV backup nitrogen bottles with full

bottles

without following the

procedure

and without the

required

second verification.

This resulted

in the misalignment of valves

and

isolation of the safety-related

nitrogen

backup

systems

for the

3A

and

3B MSIVS.

The nitrogen

backup

systems

for the

3A,and

3B MSIVs

remained

isolated for about

2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />

and

43 minutes while Unit 3 was

operating

in Mode 1.

The failure to follow procedures

for changing out the nitrogen backup

bottles for the

3A 'and

3B MSIVs is

a violation and will be tracked

as

VIO 50-250,251/92-10-03,

failure" to follow procedures

for changing

out the nitrogren backup bottles for the

3A and

3B MSIVS.

While reviewing the Turkey Point

FSAR following this event, it was

noted that the

FSAR does

not adequately

describe

the purpose of the

backup nitrogen supply.

Paragraph

10.2.2(b) of the

FSAR states'hat

a supplemental

nitrogen supply (for Unit 3) and air accumulators (for

Unit 4) are provided to maintain the

MSIVs closed for one

hour should

12

instrument

air

be

unavailable.

However,

FPL's

Component

Design

Requirements

Document

(Document

No.

5610-072-DB-002,

Rev.

A)

references

a

change

to the

MSIVs (documented

in

LER 50-250/85-20-01

dated

May 7.,

1986) that added the nitrogen/accumulator

backup to the

instrument air system .to ensure

the MSIVs would close

under

low steam

flow conditions

and could maintain

the

MSIVs closed

for

one

hour

should

instrument air be unavailable.

The

update

to the

FSAR was

inadequate

in that it does

not accurately reflect the reason for the

instrument air backup

system.

The inspectors

consider the incomplete

updating of the

FSAR

a weakness.

On April 23,

1992,

at

8:53

a.m.,

with Unit

3 at

87% power,

two

momentary

RPI

rod

bottom

signals

were

received

causing

momentary

turbine runbacks,

The

RCO for the unit noted annunciators

B 9/3 (Rod

Deviation)

and

B 7/1

(RPI

Rod Bottom Runback)

alarming indicating

a

dropped

rod turbine

runback.

The plant computer printout indicated

that the first signal

was

a 40 msec duration

and that the

second

was

a 470

msec duration

causing

turbine

and reactor

power to drop

from

87% to 86.5%.

The licensee

verified that no'ontrol

rods dropped,

and

no

rod

bottom lights

were

seen.

There

were

no

rod position

indi,cation

changes

from previous

readings,

and

no rod motion was in

progress

at the time of the event.

All plant conditions were stable

before

and after the runback.

The runback selector

switch was placed

in the

NIS position

versus

the

normal

RPI position after the event

until

the

cause

could

be

determined.

The

licensee

is currently

troubleshooting

the

RPI circuitry which will be

followed by the

inspectot s.

At 2: 10 p.m.,

on April 24,

1992,

lockout relay

186G for the

4B

EDG

was inadvertently

contacted

in panel

4Cl2B.

This resulted

in the

lockout relay tripping and locking out,

and this in turn rendered

the

4B

EDG out"of-service for reasons

other than preplanned

preventative

maintenance.

The lockout relay

was reset

in less

than

30

seconds.

The licensee

entered

action statement

b of TS 3.8. 1. 1 which required

the

demonstration

of operability of the

startup

transformers

and

their associated

circuits per

TS 4.8. l.l. l.a within

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and every

8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter,

the demonstration

of operability of the remaining

required

EDGs per

TS 4.8. 1. 1.2.a.4 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,

and the restor-

ation of the

inoperable

EDG to operable

status

within

72

hours.

Attachments

1 and

2 (the Unit 3 and

4 Startup

Transformer

Breaker

Alignments) of procedure

0-OSP205. 1, Startup Transformer s and Onsite

A.C.

Power Distribution Verification, were

commenced at 2:27 p.m.

and

were

completed

at

3:00

p.m.

Procedure

4-0SP-023.3,

Equipment

Operability Verification with an

Emergency,

Diesel

Generator

inoper-

able,

was

commenced at 2:50 p.m.,

and Attachments

1 and

3

(EDG 4A and

3A and Supported

Equipment Operability Verifications) of procedure

4-0SP-0-23,3

were completed at 3:30 p.m.

The

4B

EDG was returned to

service

at

9:20

p.m.,

and

the

startup

transformers

and

their

associated

circuits

were

verified to

be -operable

per

procedure

0-OSP-205.

1 at 9:38 p.m.

Operability testing of the

4A and

3A

EDGs

was

completed

at

12:45

a.m.

and

4:00

a.m.,

respectively,

on the

13

fol 1 owing

day.

At

4: 10

a.m.

on

April

25,

1992,

procedure

4-0SP-023.3,

Section

6.2,

Emergency

Diesel

Generator

4E Inoperable,

was reviewed,

and all required actions

were .completed.

g.

On April 27,

1992, with Unit 3 operating at

87% power, the unit was

taken "off. line due to increased

seal

leakage

from the

No.

1 seal

on

" the

3C

RCP.

Beginning

on April 25,

1992,

an upward trend in the

No.

1 seal leakoff rate

had been

observed

and

was being monitored

by the

licensee.

At 9:33 a.m.

on April 27,

1992,

the

leakage

exceeded

the

administrative

limit of

5

gpm,

and

the

licensee

initiated

a

controlled

shutdown

of the unit to replace

the

seal.

The

unit

entered

Mode

5 at

1:55

p.m.

on April 28,

1992,

and the licensee is

currently disassembling

the seal to determine

the failure mechanism.

The

resident

inspectors

were

present

in the control

room for the

shutdown which was well controlled and without event.

The residents

will monitor the licensee's

corrective

maintenance

of the

3C

RCP seal

assembly.

10.

Load Sequencer- Followup (92701)

Paragraph

6 of IR 50-250,251/92-02,

dated

February

11,

1992, discusses

the

following sequencer

problems'.

On December

10,

1991, the

4A sequencer

was

found not functioning in the auto-self-test

mode

as it should

have

been.

As

a result of this condition,

the licensee

shut

down Unit 4.

Safety

evaluation

JPN-PTN-SEN-91-099,

dated

December

10,

1991,

was

performed to

evaluate

the effects of taking the

sequencers

out of the auto-self-test

mode.

LER 91-007-00,

dated January

7,

1992,

was issued in accordance

with

Technical

Specification

Table

3.3.2.

The root

cause

.of the

sequencer

problem was identified as

a failure of a portion of the output relay card

used for the auto-self-testing.

A sticking (welded) relay contact which

should

have

been

closed

for only 0.2

seconds

during auto-self-testing

remained

closed.

This relay contact

simulated

a valid input signal during

auto-test,

but by remaining

closed

( sticking), it appeared

to be valid

input signal thus causing

the sequencer

failure problem.,

The inspector

reviewed the root cause

evaluation

and the corrective action

program

proposed

by the

licensee.

The root

cause

evaluation

included

examining

data

from inrush

current tests

run

on the output relay card

contacts.

These tests

indicated

the

inrush current

through the contacts

to the cables'apacitance

exceeded

the contacts

rating.

In addition,

these

output

relays

were

being

operated

in

the auto-self-test

mode

approximately

every three minutes.

This was over 20,000 relay operations

per

month in the test

mode.

To correct

these

conditions,

the licensee

plans

to install

current

limiting resistors

in series

with the relay

contacts.

These resistors

would limit the current well below the rating

of the contacts.

In addition, another

set of relay contacts

from a manual

test or an auto-self-test

relay would also

be in series

with the output

relay contacts.

These additional contacts

(much higher rating) would open

when

the

sequencer

was

not in the test

mode.

Therefore,

under

this

arrangement,

the current limiting resistor

should prevent

and the

second

set of higher rated contacts

would mitigate

a failure of an output relay

~

E ~

~

if it should occur,

The licensee

also stated

the auto'-self testing would

be decreased

to once

an hour for each step.

The inspector

considered

these

actions

appropriate.

However, the inspector stated that the programmable

controllers

used

in the

sequencers

have

a

20-year

history of being

extremely reliable.

Since

the

programmable

controllers

already

have

a

built in factory auto test, additional continuous

auto testing

appears

to

be

redundant.

Overall,

the

inspector

considered

the

sequencers

quite

satisfactory.

The failure was with the relay associated

with continuous

auto-self-test

mode.

Meetings

(71707)

A meeting

was held at the

NRC Region II Office in Atlanta,

GA,

on April 3,

1992,

in order to discuss

the status

of issues

involving the

new

load

sequencers

and

instrument

setpoints.

Representatives

from the licensee

management

and

from the

NRC Region II staff

were

in attendance.

This

meeting

'was

considered

to

be beneficial

and

provided

a better

under-

standing of these

issues.

e

A second

meeting

was held at the

FPL Corporate Office in Juno

Beach,

FL,

on April

14,

1992,

in

order to discuss

current

engineering

issues.

Representatives

from the licensee's

management

and engineering

staff as

well

as

representatives

from both

the St.

Lucie

and

Turkey Point

NRC

Resident

Inspector

Offices

were

in

attendance.

This

meeting

was

considered

to be beneficial

and provided

a better understanding

of the

PRA

applications

at Turkey Point,

the

status

of the

PRA at

St.

Lucie,

engineering

standards

and specifications,

the status

of the Turkey Point

reactor

vessel,

and the Passport

computer

system.

12.

Exit Interview (30703)

The

inspection

scope

and

findings

were

summarized

during

management

interviews

held

throughout

the reporting period with the Plant

General

Manager

and selected

members of his staff.

An exit meeting

was

conducted

on

May l,

1992.

The areas

requiring management

attention were reviewed,

The licensee

did not identify as proprietary

any of the materials

provided

to

or reviewed

by the

inspectors

during this

inspection.

Dissenting

comments

were

not received

from the

licensee.

The

inspectors

had

the

following findings

Item Number

Descri tion and Reference

50"250,251/92-10-01

VIO - Failure to follow a procedure

resulting in the

removal

of

a Unit 4,

Channel

A,

RWST level transmitter

from

service

during

the

calibration

of

a

Unit 3,'hannel

B,

RWST level trans-

mitter (paragraph

5).

50"250,251/92"10-02

NCV - Failure to test diesel

fuel oil

15

50-250,251/92-10-03

for sulfur content per the test method

specified

in

TS 4.8. 1.1.2.e

(paragraph

'.a).

VIO - Failure to follow procedures

for

changing

out

the

nitrogen

backup

bottles

for

the

3A

and

3B

MSIVs

.

(paragraph

9.d).

Weakness

- Incomplete description

in the

FSAR of the functions of the MSIV

nitrogen/accumulator

backup

system

(paragraph

9.d).

13.

Acronyms and Abbreviations

AOM

ANSI

ASTM

CCW

EOG

FPL

FSAR

GPM

IKC

ICW

.

IN

IR

LCO

LER

LT

MSEC

MSIV

N2

NIS

NCV

,

NPO

'PS

NRC

OP

OSP

PC/M

PMI

PNSC

PRA

PTN

gA

QC

RCO

RCP

RCS

RHR

Administrative

American National Standards

Insti

American Society for Testing

and

Component

Cooling Water

Emergency

Diesel Generator

Florida Power 5 Light

Final Safety Analysis Report

Gallons

Per Minute

Instrumentation

and Control

Intake Cooling Water

Information Notice

Inspection

Report

Limiting Condition for Operation

Licensee

Event Report

Level Transmitter

Millisecond

Main Steam Isolation Valve

Nitrogen

Nuclear Instrumentation

System

Non-Cited Violation

Nuclear Plant Operator

Nuclear Plant Supervisor

Nuclear Regulatory

Commission

Operating

Procedure

Operations

Surveillance

Procedure

Plant Change/Modification

Preventative

Maintenance - 18C

Plant Nuclear Safety Committee

Probabi listic Risk Assessment

Plant Turkey Nuclear

equality Assurance

equality Control

Reactor Control Operator

Reactor Coolant

Pump

Reactor Coolant System

Residual

Heat

Removal

tute

Materials

16

RPI

RWST

TPCW

TS

VIO

Rod Position Indication

'efueling Water Storage

Tank

Turbine Plant Cooling Water

Technical Specification

Violati on