IR 05000250/1994016
| ML17352A770 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 08/09/1994 |
| From: | Casto C, Wiseman G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17352A769 | List: |
| References | |
| 50-250-94-16, 50-251-94-16, NUDOCS 9408190083 | |
| Download: ML17352A770 (31) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W., SUITE 2900 ATLANTA,GEORGIA 30323-0199
+a*++
Report Nos.:
50-250/94-16 and 50-251/94-16 Licensee:
Florida Power and Light Company 9250 West Flagler Street Hiami, FL 33102 Docket Nos.:
50-250 and 50-251 Facility Name:
Turkey Point 3 and
Inspection Conducted:
July ll - 15, 1994 License Nos.:
G.
Wiseman Date Signed Accompanying Inspectors W. Hiller R. Schin Approved by:
~ ).
C ~
sto, Chief Test Programs Section Engineering Branch Division of Reactor Safety D t Signed SUMMARY Scope:
This routine, announced inspection was conducted in the areas of design changes and plant modifications, and engineering and technical support activities (IP 37550).
Results:
In the areas inspected, violations or deviations were not identified.
Plant Change/Modification Packages (PC/Hs) reviewed were technically adequate with sufficiently detailed
CFR 50.59 safety evaluations.
Completed modifications were adequately implemented.
Clear installation instructions were provided for the design changes.
Adequate Post Modification Test (PHT) requirements were specified.
System engineers were directly involved in the review and conduct of the PHTs.
9408i90083 940809 PDR ADOCK 05000250
Strong interface teamwork and communications were observed between site and corporate engineering personnel during the in-process interdepartmental reviews and site Plant Nuclear Safety Committee (PNSC)
approval of design changes.
The licensee had adequate controls to ensure that applicable design documents are updated in a timely manner to reflect the as-built plant.
The Design Change (PC/M) Packages were sufficiently documented to verify closure including drawing and procedure revisions; and, FSAR and vendor manual updates.
NRC Report 94-06 identified that computer system equipment database (TEDB) updates had not been consistently implemented for PC/Ms.
NRC follow-up indicated that this was an isolated case which occurred during changeover to a new Item Equivalency Evaluation (IEE)
process.
The current process includes verification of TEDB inputs.
Drawing changes reviewed were clear and accurate.
Overall drawing quality had improved due to conversion of additional drawings to the Computer Aided Drawing (CADD) system and extensive system configuration walk downs by Engineering and Operations personnel.
Organization and staffing levels for Engineering have remained stable and were adequate to perform the assigned duties and responsibilities.
Contractor A/E assistance in design development had been reduced.
Training certification for engineering personnel assigned to the Technical Department (system engineers)
was considered adequate.
Training for onsite Engineering personnel was approximately 25%
completed for the ll week plant system technical training course.
System engineers demonstrated a strong knowledge of their assigned systems during walk-downs with the NRC inspectors.
The various engineering groups provided strong and timely support to maintenance and operations for day-to-day activities and emergent issues.
The,licensee's predictive/preventative maintenance programs, supported by engineering personnel, were effective in identifying and correcting potentially degraded components.
Management initiatives were addressing the area of backlog reduction
,
for:
Plant Work Orders (PWOs), Corrective Maintenance (CM) Work Orders, Procurement Engineering Issues, and Request for Engineering Assistance (REAs).
The licensee was meeting their goals for reducing backlogs.
The various engineering groups were involved in the identification and resolution of problems in the support of reliable plant operation.
Engineering responses to Condition Reports (CRs) were timely with reasonably detailed and descriptive evaluation Quality assurance (QA) audits and performance monitoring of engineering activities were effective in identifying several areas for improvement in the engineering groups.
Corrective actions in response to QA audits and assessments were being addressed.
Engineering's self assessment activities were a positive indication of management's ongoing efforts to improve engineering performance.
Benchmark goals established for the Production Engineering Group (PEG)
"Engineering Report Card" were challenging and motivating.
The
"Engineering Report Card" results indicated consistent achievement of expected goal,
Persons Contacted Licensee Employees REPORT DETAILS C. Bible, Site Manager, Engineering
- S. Brain, Project Engineer, Production Engineering Group D. Culpepper, Chief, Engineering Assurance B. Dunn, Lead Mechanical Engineer, Engineering
- R. Earl, Supervisor, guality Assurance J. Ferrare, Lead Engineer, TEDB Enhancement Project K. Frehafer, Licensing Engineer, Engineering
- V. Kaminskas, Services Manager J. Knorr, Licensing Specialist G. Kuhn, Procurement Engineering Supervisor
- R. Kundalkar, Engineering Manager
- H. Lacal, Supervisor, Plant Change Control V. Laudato, Fire Protection Supervisor
- C. Mowerey, Licensing Specialist
- L. Pearce, Plant General Manager
- D. Powell, Manager, Technical Department J.
Reed, Supervisor, Document Control R. Renuart, Manager, Configuration Management
- E. Thompson, Project Engineer, Engineering
- E. Weinkam, Licensing Manager Other licensee employees contacted during this inspection included engineers, operators, technicians, and administrative personnel.
Other NRC Employees T. Johnson, Senior Resident Inspector
- B. Desai, Resident Inspector L. Trocine, Resident Inspector
- Attended exit interview 2.
Acronyms and initialisms used throughout this report are listed in the last paragraph.
Design Changes and Plant Modifications (37550)
a ~
Procedures Review The inspectors reviewed selected plant procedures and quality instructions (01) relative to design changes and modifications to determine the adequacy of the controls governing the design change process.
The following procedures were reviewed:
O-ADM-510, Requests For Engineering Assistance (REA), December 18, 1993 gI 3-PTN-1, Design Control, December 29, 1993
JPN gI 2.8, Total Equipment Data Base (TEDB), Revision
JPN gI 3. 1, Design Control, Revision
JPN gI 3. 1-3, Engineering Package (EP),
Revision
JPN gI 3. 14, Minor Engineering Package (MEP), Revision
JPN gI 8.3, Item Equivalency Evaluations (IEE), Revision
The inspectors concluded from reviewing the above documentation that adequate controls were in place to ensure effective implementation of design changes.
Review of Completed PC/Hs The inspectors reviewed recently completed PC/Hs listed below to:
(1) determine the adequacy of the safety evaluation screening and the
CFR 50.59 safety evaluations; (2) verify that the modifications were reviewed and approved in accordance with TS and applicable administrative controls; (3) verify that supporting calculations were properly performed, documented, and approved; (4) verify the modifications were installed and had proper signoffs; (5) verify that applicable design bases were included and affected documents (drawings, TEDB, plant procedures, etc.)
were revised; (6) verify that the modifications were properly turned over to operations; and (7) verify that both installation testing and post modification test requirements were specified and that adequate testing was performed.
The following recently completed plant modifications and related calculations were examined:
PC/H 93-82 EC-208, Rev.l PC/M 93-165 PC/H 93-182 PC/H 93-184/185 Replacement of ASCO DC Relays Associated with the 3A/3B EDGs and the 3A/3B 4160-Volt AC Switchgear Calculation of Minimum DC Voltages at EDGs 3A and 3B Control Panels Conversion of ICW Pumps to Self Lubrication Replacement of Westinghouse BFD Relays in the Unit.3 RPS MOV Actuator Motor Replacement and Removal of Valve Actuator Hotor Brakes Selected plant documentation associated with each PC/H was reviewed to verify that the changes were incorporated into the latest revision of the documents.
The inspectors reviewed affected instrument set point index drawings, vendor manuals,
TEDB, fire brigade prefire plans and procedures, fire protection Safe Shutdown Analysis (SSA),
and FSAR tables and figures, to determine if the applicable documents had been updated to accurately reflect the modifications.
An initial NRC review of PC/Hs 93-82 and 93-182 had been accomplished during the Unit 3 outage in Hay 1994 and documented in inspection report 50-250,251/94-10.
No. deficiencies were noted during both that review or this one.
The PC/Hs were technically adequate and had sufficiently detailed
CFR 50.59 safety evaluations.
Completed modifications were considered adequately implemented.
Clear installation instructions were provided for the design changes.
Adequate PHT requirements were specified.
The PC/H packages were sufficiently documented to verify closure, including drawing and procedure revisions and FSAR and vendor manual updates.
The inspectors reviewed selected drawings and TEDB items and found that they had been properly updated for these PC/Hs.
Drawings were installed on the Computer Aided Design Drawing (CADD) system and were clear and accurate.
The inspectors also noted that system engineers were directly involved in the modification review, implementation, and PHTs.
The inspectors performed field inspections for some of the modifications and verified that the PC/Hs were installed in accordance with the technical requirements specified in the applicable PC/H packages and procedures.
Specifically, during this inspection, the inspectors observed the field installation and reviewed related work documents for PC/H 93-165, related to the conversion of the Intake Cooling Water (ICW) Pumps to self lubrication.
This modification was being installed on ICW pump 4B.
The inspectors found the modification installation to be well controlled and documented.
Follow-up of Previously Identified Weakness NRC Inspection Report 50-250,251/94-06, Section 2, described the results of a recent NRC inspection of design changes and plant modifications.
That inspection identified an example of a weakness in implementation of PC/Hs, where plant drawings and the TEDB were not properly updated for PC/H 93-168 (which modified feedwater heater 6A and 6B thermal relief valves).
Follow-up during this inspection found that to be an isolated case that occurred during a licensee changeover to a new IEE process.
The inspectors verified that the current process included verification of TEDB 'inputs and adequate controls to ensure that design documents are updated in a timely manner to reflect the as-built plant.
The licensee conducted an assessment of their document update and closeout process in Hay 1994.
The inspectors reviewed the licensee's final report of that assessment and discussed it with licensee engineers.
The assessment focused on how well
modification-related changes were reflected in as-built documentation, including drawings and the PassPort computerized TEDB.
The assessment identified some improvement recommendations in the licensee's process.
It also identified one change package, DCR-431, that had not updated the TEDB.
DCR-431 updated the breaker list and single line drawings as a result of EDG modifications, but failed to update the TEDB.,
As a result, the licensee's assessment noted 12 errors in the TEDB.
To correct this deficiency, engineering was to review the impact on TEDB for changes made in DCR-431 by July 30, 1994.
The inspector concluded that the licensee's assessment was timely and beneficial.
Plant Nuclear Safety Committee (PNSC)
Review of Proposed PC/Hs The inspectors observed the licensee review and discussion of a proposed PC/N at a
PNSC meeting:
PC/M 93-108 Instrument Air System Compressor Upgrade The inspectors found that PNSC members asked many good questions about the proposed modification and its associated safety evaluation.
The committee and engineers demonstrated detailed knowledge of plant design, plant operation, and appropriate safety considerations.
Also, strong interface teamwork and communications were observed between site and corporate engineering personnel during interdepartmental reviews and site PNSC approval of design changes.
Plant Drawing/Configuration Control Near the end of 1992, the licensee had issued new computer-generated piping and instrumentation drawings.
These CADD drawings represented a notable improvement in quality and legibility.
During the first half of 1993, the licensee performed extensive system walkdowns by engineering and operations to further upgrade the accuracy of these drawings.
The licensee stated that they, converted many other drawings to CADD during 1993 and the first half of 1994, including all isometric and hangar drawings, most electrical wiring diagrams, and some instrument loop drawings.
Approximately 15,000 drawings out of approximately 40,000 total drawings have been converted to CADD.
Inspector review of samples of these drawings found them clear and accurate.
The licensee plans to put CADD drawings, the FSAR, and DBDs on their computer wide area network system in 1995.
(Engineering and licensing (Is were put on the system in. June 1994.)
With these design references on the computer network, engineers (both on site and at corporate headquarters),
operators, and maintenance
personnel will be able to view controlled copies of drawings, the FSAR, DBDs, etc.
on their computers and locally print copies of selected portions of them.
The TEDB has been on the licensee's PassPort wide area network computer system since 1990.
The licensee recently completed a
TEDB enhancement project that added about 115,000 bits of reference information to the computerized TEDB.
This project included reviewing plant drawings, procedures, and vendor manuals then adding these references to each component Identification (ID)
in the TEDB (plant Operating Drawings (POD) level drawings were previously in the TEDB).
Benefits of this database enhancement will be improved efficiency in maintenance, engineering, procurement, and operations.
Also, availability of this database will improve the chances of people having all applicable references for an equipment application.
The inspectors observed a licensee demonstration of the computerized TEDB and noted that, for selected component IDs, the above references were included in the TEDB.
Engineering and Technical Support Activities (37550)
a
~
Organization, Staffing, and Training The inspectors reviewed the licensee's organization and staffing to determine whether the engineering organization was adequately staffed to provide effective engineering support to the plant.
Engineering and technical support were provided by both onsite and corporate organizations.
The engineering support functions performed by the Technical Department and the Engineering Department of the Turkey Point Nuclear Division Engineering and Licensing were examined during this inspection.
(I)
Engineering Division The inspectors reviewed guality Instruction ENG-gI 6.0, Nuclear Engineering Organization, which described the engineering organization, including a description of reporting relationships, accountability of the department and functional activities.
The Turkey Point Engineering Department was under the supervision of the Vice President Nuclear Engineering and Licensing located in the FP&L office at Juno, FL.
This department was composed of the Production Engineering (PEG),
Cost/Scheduling, Site Engineering, Special Projects Engineering, and Procurement Engineering groups.
All of these groups are under the supervision of an engineering manager who is assigned to the Turkey Point plant site.
The PEG and Cost/Scheduling groups were located in Juno and the remaining groups were located on site.
Normally, the engineering manager worked four days per week on site and
one day per week in the Juno Office.
Bi-weekly meetings are conducted on site for key on-site and off-site engineering supervisors and managers to coordinate and manage the engineering program at Turkey Point.
The Engineering Department organization includes three supervisors, three lead engineers, 27 degreed engineers, and nine technicians on-site.
At the off-site Juno office there are two supervisors, four lead engineers, 26 degreed engineers and 11 technicians.
In recent years, a significant reduction had been made in the use of outside contractors (A/E firms) to develop modification packages, engineering evaluations, and other support activities at Turkey Point.
From 1991 to June 1994 the percent of total engineering department manhours charged by contractor workers has been reduced from 65,to 3.5 percent.
As of June 1994 FPKL engineering employees performed 96.5 percent of the engineering work and support activities at Turkey Point.
The licensee informed the inspectors that the FP&L engineering staff will continue to perform practically all of the engineering support activities.
The PEG was responsible for the preparation of most of the major and some of the minor plant modification/design change packages, complex design studies and analysis, safety evaluation reports, amendments to the Technical Specifications, revisions to FSAR and design basis documents, and configuration updates to "As Built" drawings and other construction and installation documents.
The Site Engineering Group was responsible for providing the day-to-day engineering support to operations and other groups.
These duties and responsibilities include the preparation of most minor design changes, operability assessments, temporary system alteration evaluations, safety/engineering evaluations, review of changes to procedures, and the revision or updating of critical flow and one-line plant operating drawings.
The Special Project Engineering Group's responsibilities include the facilitation of the interface and support between maintenance and engineering, support of outage activities, and the planning, coordinating and managing of special projects and initiatives.
Examples of some recent special projects include the thermal power upgrade,'reventive maintenance optimization, enhancement of the total equipment data base, coordination of the maintenance specifications, development of the implementation plan for the maintenance rule, and coordination of the service water
operational performance self assessment inspection.
Details on some of these special project initiatives are discussed in Section 3.d of this report.
The Procurement Engineering Group was formed in 1990 to provided technical support for the control of procurement activities.
The goal of this group was to assure that the correct item was used in the appropriate application for plant modifications and maintenance activities and that the item was available at the right time and at the least cost.
Some of the significant achievements of this group are discussed in Section 3.(c) of this report.
Component/System Engineers The inspectors reviewed Procedure O-ADM-501, Duties and Responsibilities of System Engineers (4/30/92),
and Technical Department Instructions TDI-SE-005, Component and System Walk-downs (1/11/93),
and TDI-SE-007, Post Modification Testing (12/13/93).
These document describe the duties and responsibilities and some of work activities of the system engineers.
Component and system engineering support to operations and other plant groups is provided by the Technical Group which is under the supervision of the Technical Manager who reports to the Plant General Manager.
The Technical group was composed of seven sections:
Reactor Engineering, System Performance, Electrical and IKC Engineering, NSSS Engineering, BOP Engineering, Component Specialist, and Shift Technical Advisors.
A total of seven supervisors,
degreed engineers, and 16 technicians were assigned to this group.
The duties and responsibilities of the system and component engineers include:
establishing and maintaining system performance standards; monitoring, trending and evaluating system performance; determining root cause of system performance degradation; evaluating corrective maintenance performed on the system; and coordinating and monitoring system modifications and post modification testing on their assigned systems.
Various predictive maintenance diagnostic monitoring techniques and analysis are performed by this group.
These activities are discussed in Section 3.b of this report.
The inspectors interviewed several of the system engineers to assess their knowledge of their assigned systems.
A walk-down inspection was performed of the diesel generators and safety injection systems with the system engineers assigned to these systems.
Overall, the system engineers demonstrated a strong knowledge of their assigned system Training and gualification The inspectors reviewed Procedure O-ADH-304, Technical Training Program for Technical Staff, and the departmental training program entitled Engineering Support Training Program.
These documents described the training program for the engineering and technical staff at Turkey Point.
The specified training included an Engineering Support Training course which consisted of approximately ll weeks of training in the areas of administrative topics, power plant fundamentals, nuclear plant primary and secondary systems, electrical systems, integrated plant operations, and simulator training.
Additional job specific training was provided as required.
Continuing training was provided in the areas of industry events, plant changes, plant systems, plant requested subjects and other items as needed to ensure that all of the technical staff remained proficient in the skills and knowledge required to provide technical and engineering support to the plant.
In addition to the above training, all of the system and component engineers must complete a comprehensive self study program on their assigned systems and pass an oral examination to demonstrate that have a detailed knowledge of the system prior to being certified on the system.
The inspectors reviewed the training records for the engineers assigned to the Technical Department and the Engineering Department and noted that a number of the engineers assigned to the Engineering Department had not received the Engineering Support Training.
The licensee indicated that all of the system and component engineers had completed the Engineering Support Training or equivalent training but only approximately 25 percent of the engineers assigned to the Engineering Department had completed this course.
Currently, engineers assigned to the Engineering Department, both on site and off site at the Juno Office, receive core training in 10CRF50.59 Safety Evaluations, configuration management, ALARA, and reliability overview.
Specific discipline training, i.e.
pumps and valves, station batteries, seismic analysis, fire protection, etc. is also provided.
However, the licensee's goal.is to have all of the engineers assigned to the Turkey Point Project meet the training specified by the site procedures for engineering and technical support personnel or to have equivalent qualifications.
Until this goal is met, the licensee indicated that the Engineering Department is staffed with a sufficient number of well qualified personnel to provide acceptable supervision, coordination, oversight and approval of the engineering support provided to the sit Based on this review, the inspectors concluded that the staffing levels and training and qualifications of the technical staff within the various departments were adequate to effectively accomplish the required engineering support for the plant.
Predictive Maintenance Program Procedure O-ADM-519, Predictive Maintenance Program (1/11/94),
was reviewed by the inspectors.
This procedure describes the duties and responsibilities for the plant staff assigned to perform the predictive maintenance program at Turkey Point.
The predictive maintenance activities at Turkey Point include vibration monitoring, lube oil sampling and analysis, infrared thermography and motor current signature analysis.
These monitoring techniques are performed by the System Engineers and Predictive Maintenance Specialist assigned to the Technical Department.
The inspectors reviewed TDI-TECH-007, Infrared Thermography Program (DRAFT), and TDI-TECH-008, Vibration Monitoring Program Description (1/31/94).
These instructions, although one was a
draft procedure, provided a good description of the thermography and vibration monitoring programs.
The licensee indicated that instruction TDI-TECH-007 was to be revised to conform to current site format requirements by late summer 1994.
The inspectors interviewed the Predictive Maintenance Specialist who performed most of the infrared thermography and vibration studies and noted that the individual had a strong knowledge of these monitoring techniques and activities.
Since the thermography analysis are performed by a well qualified individual, the inspectors considered that the temporary use of this draft instruction by the predictive maintenance specialist was not a serious discrepancy.
The inspectors noted several incidents in which the predictive maintenance activities identified potential equipment discrepancies which were corrected prior to major equipment damage.
Refer to paragraph 3.d for details.
Engineering Backlogs The inspectors reviewed the status of engineering backlogs to determine if sufficient engineering resources and management attention had been focused on this area to prevent the buildup of a large engineering work backlog.
It was noted that the licensee had implemented a number of effective programs which had eliminated or reduced previous engineering backlogs.
The licensee's actions towards reduction of engineering backlogs for the following areas were reviewed during this inspection:
'1)
Request for Engineering Assistance (REA)
The inspectors reviewed Procedure O-ADM-510, Request for Engineering Assistance, which provided instructions for the
preparation, prioritizing, tracking, reviewing, and processing of REAs.
This procedure required a cost estimate and a benefit analysis for each proposed REA to justify completion of the REA.
The Plant Review Board reviewed REAs and only those that could be justified were approved.
To minimize the engineering involvement in repetitive minor plant maintenance problems, the licensee developed a number of maintenance specification procedures, entitled Re-Use Specifications.
These specifications, covered a number of items in the civil, electrical and mechanical areas associated with generic problems involving rigging attachments, tubing supports, lighting replacements, bolting, valves, etc.
These specifications provided engineering standard details which were included with engineering documents used by the site engineering staff to minimize drafting and reduce calculation time.
The licensee's REA review and prioritization procedures in conjunction with the Re-Use Specifications has resulted in a signification reduction in the number of REAs awaiting engineering involvement.
The number of open REAs had been reduced from a total of 761 in January 1992 to 463 in January 1993 and to 177 in June 1994.
The current goal for open REAs was 150.
The licensee planed to meet this goal by late 1994.
Corrective Maintenance The number of corrective maintenance items requiring engineering evaluations or assessments was reduced from 767 in December 1990 to 435 in December 1992, 331 in December 1993, and 268 in June 1994.
The target goal number of open corrective maintenance items requiring engineering assistance was reduced from 550 in December 1992 to 350 in December 1993.
The licensee indicated the target number for these open items was to be lowered once again since the current open items are less than the existing target number.
The licensee contributed this reduction to improved plant performance and the ability of maintenance to utilize the Re-Use Specifications to resolve a large number of problems without need of submitting an REA.
Plant Work Orders (PWO)
In early 1993, the licensee formed a task force to determine the reasons for the backlog of open work orders waiting engineering assistance.
By use of the prioritization process of procedure 0-ADM-510 and maintenance's use of the Re-Use Specifications, the backlog of open work orders waiting for engineering resolution has been reduced from 81 in 1993 to 63 in June 1994.
All of the open work requests
(4)
were issued in 1993 or 1994, except for PWO 92031436.
This PWO,involved the replacement or rechroming of the actuator for Containment Purge Air Return Valve POV-3-2602.
The licensee advised the inspectors that IRC Naintenance Engineering was investigating this item to determine if the requested action would achieve the desired results.
The licensee's initial investigations indicated that rechroming the actuator shaft of this valve would not improve the stroke time results.
This conclusion will be evaluated and confirmed by the licensee's valve component specialist prior to the PWO being cancelled.
Procurement Engineering The Procurement Engineering Section was organized in 1990 to reduce the large backlog of purchase requests requiring an engineering evaluation for resolution.
The licensee advised the inspectors that in 1990 a staff of approximately
contractors was assigned the task of resolving procurement problems through some form of an engineering evaluation.
In 1990 there was an average monthly backlog of over 1200 items awaiting an evaluation.
A backlog of over 300 items were classified as obsolete.
The new Procurement Engineering Section was staffed in 1990 with licensee employees who had greatly reduced the backlog.
As of July 1994, a total of 8 FP&L employees were performing the engineering evaluation task.
This work force had reduced the monthly backlog from over 1200 items to approximately 60 items per month.
The number of obsolete items had been reduced from over 300 items to approximately 10 items per month.
Yet, the average time to resolve discrepancies had been reduced from 12 weeks to approximately 3 weeks without the appreciable use of overtime.
During the recent refueling outage, only a total of 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of Procurement Engineering Section overtime was required to support the outage activities.
This backlog reduction can be attributed to upgrades in the procurement evaluation, commercial grade dedication, and item equivalency evaluation procedures.
However, the development of electronic means for documenting, routing, approving, storing and retrieving of technical procurement control information by means of the licensee's computer system was a positive factor in the ability to reduce this backlog.
Problem Identification and Resolution The process used by the licensee to identify and track routine plant problems was the Condition Report (CR) system.
The inspectors reviewed Procedure O-ADH-518, Condition Reports
(7/5/94),
which described the process, including guidance for the issuance of a CR, responsibilities and accountability of the various departments and closeout activities.
Anyone in the plant could initiate a
CR.
The CR subsequently went to the Nuclear Plant Supervisor and Plant General Manager for determination of immediate reportability and plant operability.
The CR is also assigned to the appropriate plant department for further evaluation and disposition.
CR packages were returned to the Technical Department to be reviewed for completeness, entered into the CR data base and tracked to closure.
The inspectors interviewed engineering personnel and reviewed plant records to evaluate the determination, of plant operability, reportability and involvement of engineering in support of day-to-day plant operations.
The inspectors reviewed the following CR packages:
.
CR No.
Problem Sub'ect 93-018 Reactor Coolant System Leakage Downstream of Unit 3 Pressurizer Spray Valve PCV-3-455A ~
93-057 Motor Control Center MCC 3E Trips on Thermal Overload.93-097 93-788 Increased Vibration and High Lube Oil Iron Content Detected for Unit 3B Feedwater Pump.
Support For a Two-Inch Instrument Air Line to the Unit 3 Hain Steam Dump Valve Pulled Off Wall.94-034 Reactor Protection System Hagan Modules Not Reflected In Vendor Manual.
The inspectors concluded that the CR package documentation supported the licensee's evaluation of operability and reportability with an adequate description of the condition.
In the CR packages assigned to Engineering for evaluation and resolution, the inspectors noted that the responses were timely (closed within 25 days or less) with reasonably detailed and descriptive evaluations.
The inspectors reviewed the CR Status Report to determine the involvement of Engineering in the identification of problems.
The originating individual, not the identifying department, was recorded on each CR, and, no composite record of the identifying department was maintained in the Technical Department data bas However, by identifying the individual originating engineers, it was determined that of the 1773 CRs written in 1993-1994 approximately 290 (16%) were identified by engineering personnel.
The inspectors interviewed engineering personnel and found that'ngineers in the various plant departments were actively involved in the support of plant operations and with the resolution of plant problems.
Some examples included:
(1)
Thermal Power Uprate Project The Engineering Department was coordinating an engineering evaluation by an A/E organization and a
NRC license submittal to re-license Turkey Point Units 3 and 4 from 2200 to 2300 MWT.
This evaluation will require a major re-analysis of the nuclear steam supply systems and power conversion systems.
No major equipment replacements were anticipated but several minor operational adjustments will be required.
This additional generation is being considered as an economic benefit.
The project was in the early stages of implementation with completion proposed for 1997.
(2)
(3)
Maintenance Specifications To help reduce engineering involvement in repetitive minor plant maintenance problems, the licensee in 1989 developed a
number of maintenance specification procedures, entitled Re-Use Specifications.
These specifications continued to be revised and new specifications issued by the Engineering Department as needed.
Since January 1993, 15 new specifications were issued.
As of July 1994, there were a
total of 61 specifications covering a number of items in the civil, electrical and mechanical areas associated with generic problems such as rigging attachments, tubing supports, lighting replacement, bolting, valves, etc.
These specifications provided engineering standard details which were included with engineering documents and were used by the site engineering staff to minimize drafting and reduce calculation time.
These specifications were a factor in the backlog reduction of REAs.
Maintenance Rule Implementation The Engineering Department, with support from Maintenance, Technical and Operation Departments, had collected data and developed a plan to meet the maintenance rule.
The implementation of this plan was in progress and was scheduled to be completed in 199 S
Emergency Diesel Generator Air Compressor After recent repetitive air compressors failures for the Emergency Diesel Generators, an engineering evaluation was performed and a number of problems associated with the air compressors were identified.
These included frequent tripping of the associated circuit breakers to the air compressor motors, overheating of the air compressors due to excessive compressor cycling which caused embrittlement and entrapment of gasket material between piston rings and cylinder walls, and air leaks in the air start piping system.
The following items were performed to resolve these
,
problems:
adjusted air compressor motor circuit breaker settings to reduce the in-rush current; replaced pressure control switch; replaced head gasket with a gasket material with a higher heat resistant rating; replaced air compressor head assembly and parts with corrosion resistant material; identified and sealed starting air system piping leaks; and, replaced air compressor unloader with an unloader that provided consistent operation at the proper pressure rating.
This work was completed during the Unit 3 refueling outage which ended in May 1994 and has resulted in improved reliability, lowered compressor temperature and reduced air leakage.
Flux Happer In early 1993, both units at Turkey Point were threatened by the inability to obtain a valid flux map of the reactor core.
Two Event Response Teams were formed to address the problem and arrive at a, resolution.
The Engineering Division performed an engineering evaluation to determine the root cause of these problems and to develop the appropriate corrective action.
A number of causes were identified.
These included high humidity in the flux mapper drive unit enclosure and cable drive path, a design flaw, and human errors.
A number of modifications and enhancements consisting of moisture reduction measures and improved lubrication for the flux map driver and drive path, and electrical/instrumentation and maintenance enhancements for Unit 3 were completed during the Unit 3 refueling outages in Hay 1994.
Some temporary modifications were made on Unit 4 with the remaining items to be completed during the fall 1994 refueling outage.
No flux mapping system failures had occurred since these corrective actions have been complete (6)
Predictive Maintenance Activities The System Engineers and Predictive Maintenance Specialist using various diagnostic monitoring techniques continued to identify discrepancies and potential problems early in their degradation to permit repairs before major equipment damage occurs.
Thermography analysis examinations had identified a number of potential problems.
The following are some examples of recent findings.
On January 28, 1994, thermal fatigue was identified on a fuse bus clip in 480V HCC 30774.
Also, on this date a loose connection was found on one of the three phase connections for breaker 30727 in 480V HCC 3C.
On January 31, 1994, a poor connection was identified on the south phase east connector on,"T-Switch" 8-G-76.
On March 10, 1994, a small leak was identified through relief valve No. RV-4-203 to the Unit 4 pressurizer relief tank.
Appropriate repairs were initiated after these problems were identified.
Likewise, the vibration monitoring programs had identified a
number of problems before major equipment damage occurred.
During the Unit 3 shutdown for refueling in April 1994, the operators noted an abnormal noise from RHR pump 3A.
Vibration analysis performed on April 9, 1994 indicated the possibility of a bad motor bearing.
The motor was replaced with a spare motor.
Subsequent investigation confirmed that the motor bearing needed to be replaced.
A routine vibration monitoring analysis performed on April 16, 1994 indicated that the pump bearing for Unit 4 Primary Water Makeup Pump 4P16B needed replacement.
The pump was taken out of service and the pump bearing replaced.
Subsequent bearing inspection confirmed that the bearing had required replacement.
Violations or deviations were not identified in the areas inspected.
4, Quality Assurance (QA) Assessment and Oversight The inspectors reviewed QA audits, performance monitoring evaluations, and QA Program design control audits of Turkey Point PEG and Site Engineering's safety related activities conducted by the Nuclear Quality Assurance organization.
The assessments and audits were part of the overall QA Program at Turkey Point.
The inspectors reviewed results of the following QA activities that were either completed or in progress:
QAO-PTN-93-007, June 1993, Triennial Fire Protection Audit
QAO-PTN-93-028, November 1993, Performance Monitoring Audit of Events Affecting Operations Resulting From Apparent Human Factors
- gAO-PTN-94-007, Hay 1994, Audit of Fire Protection Program Plant Changes J(S-94-200, June 1994, Performance Honitoring Audit of Protection and Control
gAO-PTN-94-014, July 1994, Performance Honitoring Audit of Design Change Aspects of the Unit 3 Cycle 14 Refueling In addition to reviewing results of the above activities, the inspectors reviewed several Engineering response memorandums to the audit observations and recommendations.
The inspectors found that the gA organization has been heavily involved in independent monitoring'f Engineering activities.
gA audits and performance monitoring of engineering activities were effective in identifying several areas for improvement in the engineering groups.
Several
"Technical Alerts," distributed to discuss outage-related post-modification testing problems identified during performance assessments, have been instrumental in addressing those areas that need improvement.
Corrective actions in response to gA audits and assessments were being addressed.
Another aspect of the license's engineering self assessment effort was the PEG performance assessments for Turkey Point.
These assessments were performed every six months.
Nine specific engineering attributes related to quality, cost, and timeliness were evaluated and an
"Engineering Report Card" issued for each monitored engineering functional group.
As performance improved, higher standards were introduced.
The inspectors considered the benchmark goals established for the PEG design
"Engineering Report Card" both challenging and motivating.
The inspectors reviewed the last report card issued for PEG.
The
"Engineering Report Card" results indicated consistent achievement of expected goals over the most recent six month period.
Engineering's self assessment activities were a positive indication of management's ongoing efforts to improve engineering performance.
The inspectors considered the gA assessment and engineering's self assessment activities to be a strength.
Violations or deviations were not identified in the areas inspected.
(Open)
NRC GENERIC LETTER (GL) 92-08, and GL 86-10, Supplement 1,
THERHO-LAG 330-1 FIRE BARRIERS (64704)
NRC issued GL 92-08 on December 17, 1992 and GL 86-10, Supplement 1,
on Harch 25, 1994.
This correspondence notified licensees of failures of fire endurance tests associated with Thermo-Lag fire barrier systems and requested licensees to take appropriate corrective actions and compensatory measures.
The inspectors reviewed the licensee responses on this issue which indicated that Florida Power and Light Company
(FPKL) will continue to maintain their identified compensatory measures in accordance with plant procedures.
The utility will also continue to review the guidance and testing being provided through an industry program coordinated by the Nuclear Energy Institute (NEI) (formerly NUHARC) to determine the appropriate actions to resolve the issue.
The inspectors observed and photographed eleven (11) Thermo-Lag cable tray, conduit, and junction box enclosure installations.
One conduit installation in an outdoor area, Fire Zone 113, Feedwater Cage, was observed by the NRC inspectors to be weathered and cracked.
The licensee immediately initiated Fire Protection Impairment No.
6245 for the degraded Thermo-Lag condition.
The inspectors considered the compensatory actions established for Turkey Point inoperable fire barrier installations acceptable; however, the Thermo-Lag generic industry issues remain open and will be reviewed during future NRC inspections.
Exit Interview The inspection scope and results were summarized on July 15, 1994 with those persons indicated in paragraph 1.
The inspectors described the areas inspected and discussed in detail the inspection findings.
Proprietary information is not contained in this report.
No dissenting comments were received from the licensee.
Acronyms and Initialisms BOP CADD CFR CH CR DBD DC DCR EDG EP FPLL FSAR GL ICW I&C IEE IP JPN HCC HEP MOV MWT NEI NRC NSSS Balance of Plant Computer Aided Design Drawing Code of Federal Regulations Corrective Maintenance Condition Report Design Basis Document Direct Current Design Change Request Emergency Diesel Generator Engineering Package Florida Power 5 Light Final Safety Analysis Report Generic Letter Intake Cooling Water Instrumentation and Control Item Equivalency Evaluation Inspection Procedure Juno Plant Nuclear Engineering Motor Control Center Minor Engineering Package Motor Operated Valve HegaWatts Thermal Nuclear Energy Institute Nuclear Regulatory Commission Nuclear Steam Supply System
NUMARC PC/M PEG PTN PMT PNSC POD PWO QA QI REA RHR RPS SSA TEDB TDI TS
Nuclear Management and Resources Council Plant Changes or Modifications Production Engineering Group Plant Turkey Point Post Modification Test Plant Nuclear Safety Committee Plant Operating Drawing Plant Work Order Quality Assurance Quality Instruction Request for Engineering Assistance Residual Heat Removal Reactor Protection System Safe Shutdown Analysis Total Equipment Data Base Technical Department Instruction Technical Specifications