ML20129K191
| ML20129K191 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 09/27/1984 |
| From: | Elrod S, Jenison K, Peebles T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20129K167 | List: |
| References | |
| 50-250-84-23, 50-251-84-24, NUDOCS 8507230480 | |
| Download: ML20129K191 (16) | |
See also: IR 05000250/1984023
Text
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_ UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION il
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101 MARIETTA STREET, N.W.
ATLANTA, GEORGI A 30303
%...../
Report Nos.:
50-250/84-23 and 50-251/84-24
Licensee:
Florida Power and Light Company
9250 West Flagler Street
Miami, FL ' 33101
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Docket Nos.:
50-250 and 50-251
License Nos.:
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Facility Name: Turkey Point 3 and 4
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' Inspection Conducted: July 15, 1984 through August 17, 1984
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Inspectors:IW
./rs
41 f f
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T/A.Peples,SeniorRFsidentInspector
ITate/ Signed
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K'M.Jefison,ProjectInspector
Fate / Sighed
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" : Accompanying Personnel.
D. R. Brewer
Approved by:
kN
S~. A. Elrod, Section Chief
04te Signed
Division of Reactor Projects
SUMMARi
Scope:
This routine, unannounced inspection entailed 168 inspector-hours on
site, including 43 hours4.976852e-4 days <br />0.0119 hours <br />7.109788e-5 weeks <br />1.63615e-5 months <br /> on backshift, in the areas of licensee action on
previous inspection findings, Licensee Event Re~ port (LER) followup, annual and
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monthly surveillance, annual and monthly maintenance, operational safety,
Engineered Safety Features walkdown, Plant Events, design changes, calibration,
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independent inspection and exit interviews.
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Results: Of the 15 areas inspected, no violations or deviations were identified
in four areas: four violations were identified in three areas (failure to origi-
nate operating records
paragraph 6; failure to perform an adequate surveillance
test - pz.ragraph 6; failure to follow procedure
paragraph 9, with additional
examples in paragra4'.., 11 and 13; failure to require complete unreviewed safety
question determinations) and two examples of a previous violation were noted in
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two areas (inadequate safety evaluation
paragraph 3; inadequate -curve book
procedure
paragraph 14).
8507230480 841011
ADOCK 05000250
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REPORT DETAILS
1.
Licensee Employees Contacted
- K. N. Harris, Vice President - Turkey Point
C. J. Baker, Plant Manager - Nuclear
- J. P. Mendietta, Service Manager - Nuclear
- D. D. Grandage, Operations Superintendent - Nuclear
R. A. Longtemps, Assistant Superintendent Mechanical Maintenance - Nuclear
W. R. Williams, Assistant Superintendent Electrical Maintenance - Nuclear
- J. W. Kappes, Maintenance Superintendent - Nuclear
E. F. Hayes, Instrumentation and Control Supervisor
T. A. Finn, Operations Supervisor
- W. C. Miller, Training Supervisor
- V. A. Kaminskas, Reactor Engineering Supervisor
J. S. Wade, Chemistry Supervisor
P. W. Hughes, Health Physics Supervisor
M. J. Crisler, Quality Control Supervisor
- J. A. Labarraque, Technical Department Supervisor
- J. Arias, Regulations & Compliance Lead Engineer
- K. Jones, Site QA Superintendent
- D. W. Haase, Chairman Safety Engineering Group
W. Bladow, QA Operations Supervisor
J. E. Moaba, Section Supervisor Licensing
R. E. Garrett, Plant Security Supervisor
G. J. Boissy, PEP Frogram Manager
D. Tomaszewski, Plant Engineering Supervisor
- M. R. Costa, I&C Prod. Supervisor
- F. A. Houtz, QC
Other licensee employees contacted included construction craftsmen,
technicians, operators, mechanics, electricians and security force members.
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized during management inter-
views held throughout the reporting period with the plant manager - nuclear
and selected members of his staff.
An exit meeting was held on August 3,1984, with the persons noted above.
The areas requiring management attention were reviewed, including: failure
to require a complete unreviewed-safety question determination per the
Facility Operating License (250/84-23-01 and 251/84-24-01); failure to
conduct adequate surveillance tests (250/84-23-02 and 251/84-24-02); failure
to originate records as required by the Facility Operating License
(250/84-23-03 and 251/84-24-03); failure of the startup test group to
adequately perform a walk down and turn over a system (250/84-23-04 and
251/84-24-04); an Unresolved Item (URI) concerning how and when the oil vent
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pipe to the bearing on the containment spray pump was replaced URI (250/
84-23-05); and review of construction control of work Inspector Followup
Item (IFI) (250/84-23-06 and 251/84-24-06).
The licensee acknowledged
the findings.
Another exit was held with the plant manager - nuclear on August 17, 1984.
An IFI (250/84-23-07 and 251/84-24-07) concerning the progress of revising
the Inservice Test (IST) program and the submittal of another proposed
Technical Specification (TS) was discussed.
The licensee acknowledged the
commitment. The 10 CFR 21 Report on non-vital power to the safety related
pressure switches on the RWST line is considered to identify another example
of previous Severity Level III violation for inadequate safety evaluation
(250/84-09-10).
3.
Licensee Action on Previous Enforcement Matters
a.
On July 17, 1984, the licensee notified the NRC of a 10 CFR 21 report
which they had received from their architect engineer.
The control
circuitry for safety-related pressure controllers PC-600 and PC-601 is
powered from a single non-vital source.
These controllers are to
protect the Refueling Water Storage Tank (RWST) line from overpressure
during cooled-down operations. Loss of power to this circuit would not
allow the suction and discharge valves to the Residual Heat Removal
pumps to be opened from the control room.
The failure of a single
component (power from the non-vital bus) coincident with a loss of
coolant accident would not allow the recirculation phase of safety
injection to operate. The cause of the deficiency is that these relays
and the control circuitry were not identified as safety related. This
is another example of failure to properly identify equipment as safety
related, and therefore, a failure to adequately review items for
effects on safety as stated in report 250,251/84-09 and is an example
of that violation (250/84-09-10 and 251/84-09-10).
The licensee's immediate corrective actions of changing procedures to
provide guivance to operators to override these relays were reviewed
and were adequate.
The licensee intends to provide proper separate
power sources to these relays.
b.
Monthly Update of Performance Enhancement Program (PEP)
The inspector reviewed the PEP to determine if commitments were being
met. The program to upgrade the facility TS to standard TS is in the
preliminary scoping stage and has yet to be funded or staffed and
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therefore, is progressing slowly.
In addition, a definitive schedule
has yet to be set for this program. Other aspects of the PEP appear to
be progressing according to schedule.
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4.
Unrcsolved Items *
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An unresolved item is identified in paragraph 7.
5.
Licensee Event Report Followup
The following LER's were reviewed and closed. The inspector verified that
reporting requirements had been met, causes had been identified, corrective
actions appeared appropriate, generic applicability had been considered, and
the LER forms were complete. A more detailed review was performed to verify
that the licensee had reviewed the event, corrective action had been taken,
no unreviewed safety questions were involved, and violations of regulations
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or TS conditions had been identified.
(0 pen) LER 251/84-15. On July 16,1984, the 4A high head safety injection
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pump started spuriously.
The licensee's investigation showed that it was
probably started by construction electricians working near the 4160 VAC
switchgear. However, no one would admit to having bumped the switch.
The
licensee - decided that the event was not reportable.
The next day, the
inspector reviewed the decision and contacted the region for an interpreta-
tion. It was determined that the event should have been reported per 10 CFR 50.72(b)(2)(ii) as it was an actuation of an Engineered Safety Feature. The
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licensee was notified of the interpretation and reported the event. Further
followup concerning control of construction activities will be conducted
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under this LER.
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(Closed) LER 251/84-16. On June 24, 1984, manual initiation of the three
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auxiliary feedwater pumps during a transient occurred.
At 8:15 a.m. , a
rapid load reduction was being accomplished on Unit 4 as- turbine oil
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problems had caused control valves to close and the hotwell level was
decreasing due to a divert valve failing to open.
The shift supervisor
ordered the manual start of the auxiliary feedwater pumps to alleviate the low
hotwell level until the divert valve could be reset. The licensee deter-
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mined on July 24, 1984, that the event was not reportable as the pumps were
not required to function as they were only started in a precautionary
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manner.
However, NRC Region II interpreted the event to be reportable as
the pumps were started during a transient condition which was not preplanned
and the pumps were fulfilling their role as an Engineered Safety Feature.
The licensee was informed on August 2,1984, of the region's interpretation
and reported the event.
This event and the LER are considered closed.
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determine whether it is acceptable or may involve a violation or deviation.
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(Closed) LER 250/84-21. On July 14, 1984, a reactor trip occurred on Unit 3
while the unit was shutdown with the shutdown control rods withdrawn. The
instrument technician working on Nuclear Source Range Instrument NI-32
caused a loss of control power to relays which resulted in a reactor trip.
The inspector witnessed and later reviewed the event and has no further
questions. This event and the LER are closed.
No violations or deviations were identified.
6.
Monthly and Annual Surveillance Observation (61726/61700)
The inspectors observed TS required surveillance testing and verified that
testing was performed in accordance with adequate procedures; that test
instrumentation was calibrated; that limiting conditions for operation (LCO)
were met; that test results met acceptance criteria and were reviewed by
personnel other than the individual directing the test; that deficiencies
were documented and that any deficiencies identified during the testing were
properly reviewed and resolved by appropriate management personnel; and that
system restoration was adequate.
For completed tests, the inspector
verified that testing frequencies were met and tests were performed by
qualified individuals.
The inspector witnessed / reviewed portions of the
following test activities:
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Engineered Safety Features Logic Periodic Test
Containment Spray Pump Periodic Test (OP 3204.1)
Residual Heat Removal (RHR) System Periodic Test (OP 4004.1)
High Head Safety Injection (HHSI) System Periodic Test (OP 4104.1)
Auxiliary Feedwater System Periodic Test (OP 7304.1)
Intake Cooling Water System Periodic Test (OP 3404.2)
Emergency Diesel Generator Periodic Test (OP 4304.1)
a.
While witnessing the testing of
"A" Emergency Diesel Generator per OP
4304.1 on July 26, 1984, the inspector noticed that out of specifica-
tion readings were being taken on one of the cylinder exhaust
temperatures. The reading for cylinder No. 2 was 120F and the other
cylinder temperatures in service were reading 790 - 880F.
The
acceptance criteria allowed no greater than 1100 and a deviation
between cylinders of less than 200; however, the acceptance criteria
did not give instructions as to action to be taken if a reading was not
within tolerance. Also, the Data and Record Sheets did not have spaces
to identify the performer of the test and the reviewer of the test and
did not have information required as to disposition of deficiencies.
The Facili ty Operating Licenses (DPR-31 and DPR-41)Section III.D
requires that the licensee shall originate and maintain operating
records in accordance with TS.
TS 6.10.1.d requires records of
surveillance activities required by TS be kept for five years.
These
data sheets are also Quality Assurance records as defined by 10 CFR 50,
Appendix B,
Criterion XVII which requires that records affecting
quality shall include the results of tests and that test records shall
identify the data recorders, the acceptabil.ity and the action taken in
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connection with any deficiencies. The FP&L QA topical section 17.2,
Revision 0, and Quality Procedure 17.1, Revision 11 implements these
10 CFR 50, Appendix B requirements. This is a violation (250/84-23-03
and 251/84-24-03) of the operating license as the records were not
originated,
b.
On July 27, 1984, the procedures for RHR and HHSI pump testing (OP
4004.1 and OP 4104.1) were reviewed for adequacy of compliance against
The intent of the TS is to verify that the subject systems
will respond promptly and perform their design functions. Both of the
pumps have mechanical seals with seal water pumped to a seal water heat
exchanger which is cooled by component cooling water. The seals have a
manufacturer's design maximum leak rate. TS 4.5.2.a requires that the
pumps be started monthly; that they sthrt and reach their required head
and that the instruments and visual observations indicate proper
functioning; and that the test be run for fifteen minutes. Neither of
the procedures verified that the seals, seal water system or component
cooling water system was meeting design functions during the fifteen
minute run by either visual or instrument observations. Therefore,
this is a violation (250/84-23-02 and 251/84-24-02) as the surveillance
tests were inadequate.
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The licensee was informed of the finding on July 27, 1984.
On
August 1,1984, the RHR pumps were tested and the precedure was not
corrected.
The licensee was again notified of the discrepancy on
August 3,1984, at a formal exit, and agreed to correct the problems
with the surveillance tests as it was apparent that the tests were for
ASME Section XI, IST compliance and not TS operability compliance.
The other pump operability surveillance tests have similar discrep-
ancies and have not been adequate.
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7.
Monthly and Refueling Maintenance Observation (62703)
Station maintenance activities of safety-related systems and components were
observed / reviewed to ascertain that they were conducted in accordance with
approved procedures, regulatory guides, industry codes and standards, and in
conformance with TSs.
The following items were considered during this review: LCO were met while
components or systems were removed for service; approvals were obtained
prior to initiating the work; activities were accomplished using appraved
procedures and were- inspected as applicable; functional testing and/or
calibrations were performed prior to returning components or systems to
service; quality control records were maintained; activities were accom-
plished by qualified personnel; parts and materials used were properly
certified; radiological controls wcre implemented; and fire prevention
controls were implemented.
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The following maintenance activities were observed / reviewed:
Replacement of holddowns for packing gland followers on Unit 4.
Charging pump 38 piston valve replacement.
Replacement of air lines to CV-4-2907, component cooling outlet valve
from 4C Emergency Containment cooler.
3A Containment Spray Pump bearing oil vent replacement.
Safety Injection Pump 3B motor rotor overhaul.
a.
The broken air lines on CV-4-2907, which were found on July 24, 1984,
by an auxiliary building operator, caused the valve to fail in the
" unsafe" closed position. The licensee's investigation indicated that
construction crews in the area were the contributing factor.
Construction Work Permits (CWP) are reviewed and signed by the shift
supervisor with the intent of providing guidance to construction
personnel as to critical equipment in the area of work. Many of the
CWP's are not specific enough to allow the shift supervisor to do an
adequate review,
e.g., " cable pulling to be conducted throughout the
auxiliary building." The licensee is reviewing the CWP program. This
will be followed as IFI (250/84-23-06 and 251/84-24-06).
b.
On August 1,
1984, the 3A containment spray pump was taken out of
service as the constant level oiler fell off during the pump run.
Subsequent investigation conducted by the licensee showed that a one
half inch pipe vent, on top of the bearing housing, did not have a vent
hole and running the pumps built up pressure which caused the cooler to
be forced from its mounting. How and when the vent pipe was replaced
is under investigation and the potential for the pump to have been out
of service for an extended period of time is considered an URI pending
NRC review of investigation results URI (250/84-23-05).
c.
Following the repair of 3A high head safety injection pump motor rotor
reported in report 250/84-22, the licensee shipped the 3B high head
safety injection pump motor rotor to Westinghouse for evaluation as
there was some indication of vibration. Westinghouse did not find any
significant problems. After reconditioning, the rotor was shipped back
and reinstalled.
The other two rotors (4A and 4B) are not to be
shipped out as no abnormal vibrations have been seen. The motors are
on a scheduled five year preventive maintenance program and vibration
readings will continue to be taken and are expected to identify any
significant deterioration in motor performance.
No violations or deviations were identified.
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8.
Operation and Safety Verification (71707)
The inspectors observed control room operations, reviewed applicable logs,
conducted discussions with control room operators, observed shift turnovers,
and confirmed operability of instrumentation.
The inspectors verified the
operability of selected emergency systems, reviewed tagout records, verified
compliance with TS LCO and verified return to service of affected
components.
The inspectors by observation and direct interviews verified that the
physical security plan was being implemented in accordance with the station
security plan.
The ir.;pectors verified that maintenance work orders had been submitted as
required and that followup and prioritization of work was on going.
The inspectors observed plant housekeeping / cleanliness conditions and
verified implementation of radiation protection control.
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Tours of the spent fuel pit pumps rooms, auxiliary, control, diesel, 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 on Unit 3 and 4 to verify operability and proper valve
alignment:
Containment Spray System
Auxiliary Feedwater System
a.
The Unit 3 safety injection accumulators have been requiring increasing
attention to keep their levels within specifications as leakage has
increased. The licensee is pursuing corrective action.
b.
The Unit 4 'C' Pressurizer Safety valve is leaking at about the same
rate as it has been since the start-up in April. The STA has been
closely monitoring the leakage for any increase. Parts to rebuild the
valve with are on-site and will be installed if leakage begins to
increase or during a cold shutdown of sufficient duration.
c.
During a tour of the Unit 3 Spent Fuel Pit Pump Room, a boric acid leak
onto the spent fuel pit pump controller box was reported to the
licensee for correction.
d.
On August 14, 1984, Unit 4 power was reduced to 50% to lessen a
possible transient that might occur while a broken lead was replaced on
the B main feedwater pump control switch located on the control room
. panel.
The wire was found broken at the lug while other maintenance
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was being performed. The broken circuit would have partially affected
the B auxiliary feedwater initiation logic. The wire was repositioned
and the unit returned to 100% power.
No violations or deviations were identified.
9.
Design Changes and Modifications (37700)
On July 27, 1984, a review was made of design changes (PC/M) 81-29 and 81-30
(Units 3 and 4) for the installation of bypass switches around the lockout
circuitry for the B backup pressurizer heaters.
The breaker for these
heaters is located in the D 480 Vac load center for each unit. The lockout
circuitry is energized as a load shedding feature during an undervoltage
event and the installation of the keyed bypass switch in the back of the
load center allows these heaters to be re-energized. The inspector found
that the circuits have been operable since the last refueling, which on
Unit 3 was January 1984, and Unit 4 was May 1984.
Neither switch was
labeled as to function and the Unit 4 switch did not have an' indication
plate so that its position could be determined. The drawing for the opera-
tion logic of the circuit 5610-TL-1 Sheet 23 still had the notation that
this was for Unit 3 only, even though, Revision 8 was issued specifically to
incorporate that PC/M for Unit 4.
The start-up test group had respon-
sibility for the walkdown of the system to identify discrepancies and to
have the operating drawing updated.
These requirements are stated in AP
0103.17 - Systems / Equipment Acceptance / Turnover to Plant Staff. This is a
violation (250/84-23-04 and 251/84-24-04) for failure to follow procedures
as required by TS 6.8.1.
10.
Independent Inspection Effort (92706)
a.
Tne inspectors routinely attended meetings with licensee management and
shift turnovers between shift supervisors, shift foremen and licensed
operators during the reporting period. These meetings and discussions
provided a daily status of plant operating and testing activities in
progress as well as discussion of significant problems or incidents.
As a result of discussions with the licensee management, the following
items are to be actively pursued by the licensee: the shift supervisor
is to be responsible for knowing the qualifications of his shift
personnel; the operations supervisor (or superintendent) is to be
responsible to assure operations personnel training is current; and
training briefs will require a separate sign off.
b.
The Inservice Test (IST) Program was reviewed as to the appropriate
scope for pump testing.
Discussions with licensee personnel and with
NRR reviewers led to the agreement that the charging pumps and boric
acid transfer pumps were required for an orderly shutdown and cooldown
of the plant and therefore should be a part of the IST program as
required by 10 CFR 50.55a(g). On July 27, 1984, the Vice-President -
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Turkey Point and the Plant Manager - Nuclear agreed to include the
charging-pumps, boric acid transfer pumps and spent fuel pit pumps into
the IST program and to change the IST TS submittal of April 2, 1984, to
reflect the change. However, on August 22, 1984, no responsibility or
time table'for action had been initiated.~
The IST TS submittal of April 2,1984 has several discrepancies, two
are briefly listed below.
The entire submittal will be further
reviewed:
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(1) The letter states that in the submittal they are adopting the
wording of the Standard Technical Specifications; however, this is
not done.
(2) The margin of safety assured by the current surveillance testing
requirements would be reduced as the requirement to assure the
support systems are operable during the testing is being deleted.
The IST program will be reviewed as IFI (250/84-2-07 and 251/84-24-07).
c.
A review of evaluations for unreviewed safety question determinations
per 10 CFR 50.59 was conducted. The requirement for this evaluation is
in the facility operating licenses (DPR-32 and DPR-41) section III. 10 CFR 50.59(2) discusses that the evaluation for an unreviewed safety
question determination be made against evaluations previously made in
the Final Safety Analysis Report (FSAR).
Discussions with licensee
personnel revealed that they believed that only those items addressed
in the Chapter 14 Accident Analysis chapter of the FSAR were of
significance in evaluations for unreviewed safety question's and that
other chapters discussed back up equipment which did not require the
same level of review. A review showed that the following licensee's
procedures stated management acceptance of this concept as the
procedures only required a review be made against Chapter 14 of the
.FSAR:
Administrative Procedure 0109.1 page 14 - Preparation, Revision and
Approval of Procedures - Procedure Change Safety Evaluation
Administrative Procedure 0103.3 page 15 - Control and Use of Temporary
System Alterations - Safetu F. valuation
Administrative Procedure 0190.2a, page 34 - Plant Projects - Approvals,
implementation
and
Regulatory Requirements - Appendix A
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Suggested Format for Safety Evaluations.
Therefore, this is a violation (250/84-23-01 and 251/84-24-01) of the
facility operating license as the evaluations were not required to be made
as stated in the license.
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Calibration (65700)
References:
NUREG CR 1369 Evaluation of Maintenance Test and
Calibration Procedures in Nuclear Power Plants
ANSI N45.2.4 1972
AP 0190.9 Control of Measuring and Test Equipment
a.
The following maintenance, test and calibration procedures were
evaluated for conformance with the above references.
The review
included calibration frequency, acceptance criteria, maintenance of
procedure revisions, review and approval of procedures, deviated
procedures, return-to-service of out-of-calibration equipment, and
primary standard control:
A-1-I
PWO 8714-TIC 627
PWO 8734
A-2-I
PWO 8715-TIC 625
PWO 8363
A-3-I
PWO 8727
PWO 8230
A-4-I
PWO 8493
MP14007.13
PWO 815B
MP14007.14
PWO 8230
Revision control on some procedures was found to be inadequate in that
pen and ink changes had been made to controlled copies of certain
procedures without management approval.
b.
Records for selected gages, instruments and measuring and test equip-
ment used to determine compliance with TS vere examined to determine if
the equipment was calibrated against certified equipment having a known
valid relationship to nationally recognized standards.
The following
equipment was examined:
Heise gage"
803
General Radio Meg Chm Meter 803
Heise gage
1004
Techtronix 5A21N
Fluke meter
81000A 1000-1
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Fluke meter
81000A 1000-4
Ashcroft Gage 1,500 psig
Fluke meter
81000A 103-3
Ashcroft Gage 10,000 psig 4227
Fluke meter
81000A 103-5
Ashcroft Gage 10,000 psig 4228
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Fluke meter
81000A 103-6
Ametek pump 704-5
Techtronix X-Y module 553
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Several discrepancies were noted during this review of calibration and
test equipment:
Tecktronix
5A2IN
PTP509
Invalid calibration
sticker affixed to the
amplifier.
Ashcroft
0-1500 psig
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No calibration sticker and
no PTP control number
assigned.
No current
calibration data avail-
able.
Ashcroft
0-10,000 psig PTP4227
No calibration sticker
affixed.
No current
calibration data avail-
able.
Ashcroft
0-10,000 psig PTP4228
No calibration sticker
affixed. No current
calibration data avail-
able.
This item was used on
Ametek Pump
704-5
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PWO 8067 on 5/31.
It was
overdue for calibration on
5/23 and not recalibrated
until 6/14.
Tektronix
X-Y output
PTP553
No calibration sticker
module
affixed to the module.
Ametek 93cg
0-15 psig
PTP178
This equipment was out of
Ametek 93cg
0-15 psig
PTP 179
service without the proper
Ametec 93cg
0-15 psig
PTP 180
identification tag
affixed.
The above discrepancies collectively constitute a failure to comply
with AP 0190.0 - Control of Measuring and Test Equipment and will be
considered a further example of violation (250,251/84-24, 23-04).
These
discrepancies will be reviewed as IFI (250,251/84-24, 23-08).
c.
In addition the master calibration schedule, calibration stickers
affixed to equipment and individual completed procedures were compared.
~Several examples were identified in which the data listed on the
different documents did not agree.
This appears to be a clerical
problem in nature, and plant management has committed to review this
area.
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d.
The calibration of gages which are used by tne licensee only for local
indication was reviewed.
It was discovered that local gages are not
calibrated on a routine schedule unless they are a part of a remote
indication calibration loop. In addition these gages are not used for
operability determination or IST by the licensee. This item will be
reviewed as IFI (250,251/84-24, 23-09).
12.
Engineered Safety Features Walkdown (71710)
The inspector verified the operability of the Units 3 and 4 Safety Injection
(SI) system on August 2,
1984, by performing a partial walkdown of the
accessible portions of the system. The following specific attributes were
reviewed / observed as appropriate:
that the licensee's system lineup pro-
cedures match plant drawings and the as-built configuration; that equip-
ment conditions and items that might degrade performance (hangers and
supports are operable, housekeeping, etc.) were identified; with assistance
from licensee personnel that the interior of the breakers and electrical or
instrumentation cabinets were inspected for debris, loose material, jumpers,
evidence of rodents, etc.;,that instrumentation was properly valved in and
functioning and calibration dates were appropriate; and that valves were in
proper position, power was available and valves were locked as appropriate;
and local and remote position indication was compared.
Valves and piping flow paths were verified to be built in accordance with
plant drawings 5610-TE-4510 Revision 29, 5610-TE-4512 Revision 12, and
5610-TE-4501 Revision 34. During the inspect'on of the area, no violations
or deviations were identified, however, various discrepancies were noted:
a.
Numerous valves in the SI system have no valve identification tags,
although the valves have been numbered on applicable drawings. This is
an example of inadequate equipment identification which is being
addressed by the PEP.
b.
In both Units 3 and 4 boric acid injection tank (BIT) areas, boric acid
residue from valve leakage was readily apparent. Several large valves
showed signs of long-term minor leakage with boric acid build up and
valve stud corrosion.
c.
The licensee was informed that the seal water lines, including vent
valves, and safety injection side of the seal water heat exchangers do
not appear on drawings.
13.
Refueling Water Storage Tank (RWST) Level Indication
References
Operating Procedure (0P) 16.122
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Operating Procedure (0P) 0204.2
Drawing 5610-C-18-393
RG-7-3-80
Tank Book drawing figure 5 - RWST
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OP 0204.2 States that an operator should " read pressure, convert to gallons
and record 'the Refueling Water Storage Tank head pressure and check against
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tank level indicators LI *-6583A and LI *-6583B TS (4.1-1(15)) Head Pressure
(PSI) = Test Gauge Pressure (PSI) + Correction Factor (PSI). Level (GALS.)
= Head. Pressure (PSI) X 16620 gallons / PSI. A minimum of 320,000 gallons is
required by.TS 3.4.1.a.1.
The correction factor is given on the engraved
name plate mounted next to the gauge. Check this name plate each time, as
this correction factor may have changed."
When inspected, the local Ashcroft test gauge pressure correction factor was
not mounted next to the gauge plate. It was however, attached to a plastic
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tape attached to a calculator which was used by the reactor operator to
calculate RWST level. Several operators, when questioned on August 1, 1984,
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indicated that the correction factor used was not verified prior to each
calculation in accordance with OP0204.2. This is a violation and will be
considered as a further example of violation (250,251/84-24, 23-04).
This
item will be reviewed as IFI (250,251/84-24, 23-10).
In addition, there appeared to be a 10 inch discrepancy between the data
used to install Magnetrol LS-3-1584A under PCM-80-100, and drawing
5610-C-18-393.
This discrepancy was later attributed to an error in the
data used to calculate figure five - Refueling Water Storage Tank, in the
Unit 3 control room curve book. This level switch is the TS low level alarm
which is used to backup control room level indication LI-3-6583B.
In
addition drawing 5610-C-18-393 (AG 7-3-80) was not updated after the
addition of the Magnetrol level switch. This is a 'tiolation and will be
considered as a further example of violation (250,251/84-24, 23-04). This
item will be reviewed as inspector followup item IFI (250,251/84-24, 23-11).
The local ashcroft meter had several items of concern associated with it.
The meter face vibrated severely and when held still oscillated two tenths
of a pound. It was mounted to a sample line which leaked. When the gage
was held the reading varied three tenths of ' a pound depending on the
pressure used to steady the gage. Because this reading was multiplied by a
factor of 16620 (which could institute significant error) to calculate RWST
level and was the gauge used to calibrate the Magnetrol LS-3-1584A TS alarm
the calculational method was reviewed.
The method seemed to be sound
although water density as a function of temperature or Boron concentration
was not addressed.
The licensee placed a newly calibrated Bailey level
indication in parallel with the Ashroft gage and the indicated level was
4000 gallons above the level calculated using the Ashcroft gage.
The
inspector had no further concerns with respect to the use of the Ashcroft
gage.
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14. Control Room Tank / Curve Book
The control room curve book was reviewed and compared the control room
indications in order to the verity certain TS limits. During the review the
reactor operator on Unit 4 was observed using a table entitled " Allowable
Flux Difference vs. Percent of Reactor Power."
This table was not an
official part of the curve / tank book however, the information included in
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the table appeared to be consistent with a flux vs. power curve in the
curve / tank book.
This table was not controlled and was not listed on the
index nor did it appear in any other control copy.
This is a further
example of violation (250,251/84-24, 23-04), and will be reviewed as
IFI (250,251/84-24, 23-11).
15.
Independent Inspection - Annunciated Control Room Alarms
A review of control room annunciated alarms was conducted with the following
concerns noted:
a.
The Unit 3 reactor coolant pump (RCP) thermal barrier cooling water
high temperature annunciator was alarmed. Maintenance work was being
conducted on the heat exchanger of one train of component cooling water
(CCW) which supplies cooling to the RCP. The licensee stated that one
train of CCW is not sufficient to meet normal cooling requirements
'during the summer months as a result of high canal intake water
temperatures. The review of special allowances for the failure of one
train of CCW is identified as IFI (250,251/84-24, 23-13).
b.
Unit 4 had a high pressure relief tank temperature alarm. This is a
repeat of an item identified in inspection report (250,251/84-06).
Indications of long term corrective actions mentioned in the February,
1984 report are still not evident. In order to comply with OP 1300.1
almost continuous purges of the tank are required. The licensee stated
that an evaluation of this problem was in process. Licensee corrective
action will be reviewed as IFI (250,251/84-24, 23-14).
c.
The Units 3 and 4 containment high Hydrogen monitor alarm was
annunciated in the control room and after review it was determined that
it was permanently alarmed as a result of system lineup. The monitor
is part of the Post Accident Monitoring system and alarms as a result
of one or more of the below situations:
(i)
Low calibration bottle gas pressure
(ii) Low sample gas flow
(iii) Low temperature
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(iv) Heat tracing failure
In this instance, the monitor alarm is the result of low sample gas
flow because the sample gas flow is isolated during normal operations
in order to maintain containment integrity, Diagram 5610-T-E-4534 and
control schematic K-111-01430 were reviewed.
This item is identified
as a possible human factor and/or design concern and the licensee has
agreed to review possible changes to eliminate the continuously alarmed
There were no violations or deviations identified in this section.
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16.
Procedure Upgrade Program (PUP)
The PUP portion Turkey Point Performance Enhancement Program (PEP) was
reviewed.
The following approved procedures were reviewed for content,
detail, and compliance with INP0 or other industry standards:
ADM-101
Writers guide for Administrative and Norma; Operations
Procedures
ADM-100
Procedure Preparation, Review and Approval
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Two preliminary procedures (Residual Heat Removal System OP-050 and Intake
Cooling Water OP-019) were reviewed and compared to the PDG procedure status
report of August 1, 1984. These documents appeared to be clear and well
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written and will be reviewed further.
The schedule / personnel requirements .of the PUP were also reviewed.
The
OP schedule and personnel availability appear to be well matched and should
meet the overall schedule committed to by the licensee. The maintenance
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procedure upgrade portion of the PUP appears to be under staffed with
respect to two issues.
The first issue that appears to be a possible
impediment to the accomplishment of the committed to schedule is the support
of "real time" or intermediate procedure changes. The intermediate changes
have monopolized the available maintenance procedure staff time and no
significant preventive action has been taken by the licensee to effectively
deal with the sharp increase in "real time" procedure change requirements.
This item will be reviewed as IFI (250,251/84-24, 23-15).
This item was
discussed with both the PUP project manager and the resident Vice President
Turkey Point Nuclear Plant, who committed to evaluate the situation.
The
second issue that appears to be a possible impediment to the accomplishment
of both the operations and maintenance procedure upgrading / rewriting efforts
is the implementation training resources available. Presently, there is an
inadequate number of staff available to raview and write updated training
material to support the procedure implementation schedule.
In addition,
there doesn't appear to be any integration of training requirements into the
overall PUP. This item was also discussed with the .UP project manager and
the Vice President, Turkey Point Nuclear Plant who committed to also evaluate
training requirements.
No violations or deviations were identified in this area.
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