ML20140D060
| ML20140D060 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 01/30/1986 |
| From: | Grimsley D NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Weiss E HARMON & WEISS |
| Shared Package | |
| ML20140D066 | List: |
| References | |
| FOIA-85-729 NUDOCS 8603250569 | |
| Download: ML20140D060 (2) | |
Text
/ %>, UNITED STATES (OPono
'. $ 1., NUCLEAR REGULATORY COMMISSION h ij WASHINGTON, D. C. 20655 e
% ,# JAN 80 O Ellyn R. Weiss, Esquire Harmon, Weiss & Jordan 2001 S Street, W, Suite 430 IN RESPONSE REFER Washington, DC 20009 TO F0IA-85-729
Dear Ms. Weiss:
This is the final response to your letter dated October 31, 1985, in which you requested, pursuant to the Freedom of Information Act (F0IA), copies of the NRC inspection report and related records regarding the evaluation of the auxiliary feedwater system at Turkey Point Units 3 and 4 Copies of the documents listed on the enclosed Appendix H are being placed in the NRC Public Document Room (PDR) in PDR folder F01A-85-729 under your name.
A portion of the document listed on Appendix I has been deleted in order to withhold names and other identifying information. Because disclosure of this information would constitute a clearly unwarranted invasion of personal privacy, it is being withheld from public disclosure pursuant to Exemption (6) of the F0IA (5 U.S.C. 552(b)(6)) and'10 CFR 9.5(a)(6) of the Commission's regulations. A copy of the releasable portion of the document is being placed in PDR folder F01A-85-729.
Pursuant to 10 CFR 9.9 of the Commission's regulations, it has been determined that the information withheld is exempt from production or disclosure, and that its production or disclosure is contrary to the public interest. The persons responsible for this denial are the undersigned and Mr. James M.
Taylor, Director, Office of Inspection and Enforcement.
This denial may be appealed to the Commission's Executive Director for Operations within 30 days from the receipt of this letter. As provided in 10 CFR 9.11, any such appeal must be in writing, addressed to the Executive Director for Operations, U.S. Nuclear Regulatory Commission, Washington, DC 20555, and should clearly state on the envelope and in the letter that it is an " Appeal from an Initial FOIA Decision."
Sincerely, 4=- 2%
Donnie H. Grimsley, Director Division of Rules and Records Office of Administration
Enclosures:
As stated 8603250569 860130 PDR FOIA PDR l WEISS85-729
)
k Re: F01A-85-729 APPENDIX I
- 1. 8/1985 - Turkey Point Overtime Summary 9
HARMON, WEISS Oc JORDAN 2001 S STREET N.W.
SUITE 430 WASHINGTON, D.G. cooos Gall McGREEVY H ARMON TELEPHONE ELLYN R. WEISS (202)328 3500 WILLI AM S. JORDAN, til DIANE CURRAN DEAN R. TOUSLEY October 31, 1985 Mr. Joseph Felton, Director FREtAxw 0F INFOW* If0N Division of Rules and Records AC" PE7 "EI Office of Administration [O1Q-g$ [y U.S. Nuclear Regulatory Commission Washington, D.C. 20555 h //- -b RE: FREEDOM OF INFORMATION ACT REQUEST
Dear Mr. Felton,
Pursuant to the federal Freedom of Information Act, I hereby request a copy of each of the following:
- l. NRC's recent " system evaluation" of the auxiliary feedwater system at Turkey Point Units 3 and 4. This evaluation is more fully described in the attached article which appeared in the October 29, 1985 issue of "Inside NRC".
- 2. All related documents including but not limited to reports, memoranda, notes, drafts prepared by NRC staff and/or contractors in connection with this system evaluation.
- 3. All documents prepared by Florida Power and Light and/or its contractors, . employees or agents in connection with this system evaluation or in response to the evaluation.
Your response within ten days will be appreciated. ,
Very truly yours,
?[ y(;~L\
r 1 'l i l;v(3 _-l+.,
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Ellyn R. Weiss ENC.
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- Inside NR.C An exclusive report on the U.S. Nuclear Reg ulatory Commission M
WL 7. N. 22 - htnher 29,1985 gPROTESTS NRC REVIEWS OF INPO-ACCREDITED TRAINING PROGRAMS The Institute of Nuclear Power Operanons (INPO) is asking NRC Executive Director for Opera-tions Wilham Dircks to stop the NRC staff from checkmg on utility trainmg programs after INPO has accredited them. INPO President Zack Pate has also wntten the NRC commissioners asking their help Ln reinmg in the statT. The staff activines, Pate said. "are impeding or underminmg INPO efforts?
-- The NRC commissioners agreed last year not to pass new trammg rules for two years so INPO could prove that voluntary utthty etTorts to meet INPO accreditation standards produced superior re-suhs The commissioners said, however, that the statT would momtor the situanon (INRC,1 April,13)
In Ju!), INPO and NRC signed a coordmation plan. Pate wrote: "INPO has cooperated fully with the NRC in this area and recogmzes the NRC's need to monitor traimng pregress " But some recent NRC act ons, he said, "are not m keepmg with the...coordmation plan?
Pate complained of staff actions in three areas. First, he said, the staff has distributed Nureg/CR-4344, " Instructional Skills Evaluation in Nuclear Industry Traimng " The document duphcates maten-al m two INPO documents but contams some different recommendations, he said, addmg "NRC issu-ance of documents that duphcate INPO traimng-related documents is specifically precluded by the coordmation plan?
Second, without consuhing INPO NRC's Office of Nuclear Reactor Regulation (NRR) an-nounced it will ccnduct " post-accreditation reviews of(INPO) accredited traimng programs usmg new-ly developed enteria " Pate wrote. "Supenmposing these reviews on the accreditauon process and the performance-onented inspections conducted by I&E (NRC Office of Inspecuon & Enforcement) and C (Contmurion pere 4)
FIRST NRC ' SYSTEM EVALUATION' SLAMS TURKEY POINT MAINTENANCE The first of NRC's new system evaluations, on the auxihary feedwater (AFW) system at Flonda Power & Light Co.'s (FP&L) Turkey Pomt-3 and -4, has resulted in a report harshly entical of FP&Us mamtenance, traimng, modificanon design and testmg, and quahty assurance at the plant. Ac-cordmg to the report, a special NRC inspecuon team assessing the operational readmess of the AI'W system found modifications made without analysis of their safety impacts, operators untrained in the system's pecubannes, design flaws that could lead to uncontrolled radiation releases m a steam genera-tor tube rupture or total h>ss of AFW flow control valves, a maintenance backlog that kept control room mstruments out of service for months, and a maintenance training program suspended since March 1984 while the trammg department prepared programs to meet Institute of Nuclear Power Op-erauons (INPO) accreditation requirements.
The inspection is the first of at least three system evaluations that the NRC staff plans to perform while developing new performance-based regulatory critena. The other plants hase not been named.
The shift is occurring as the NRC staff takes a tougher regulatory Ime after a series of plant mishaps blamed on poor plant management (INRC,14 Oct.,1). Besides forcing management attention to what NRC perceives as lingering mamtenance problems at Turkey Pomt (INRC,30 Sept.,1), the statT will be using the inspection findmgs to develop new methods to get s'abstantial changes at poorly managed plants.
For the mspection, NRC called m design and engmeenng experts from NRC headquarters and Region 11 and NRC contractors. They started with the AFW system as desenbed in the operating li-cense and then traced modifications, kioking for design control, maintenance and surveillance quality, operstmg procedures, and adequacy of testing, especially after modifications or mamtenance. In his let-t INSIDE THIS ISSUE Commissioners reject CPA t. EQ deadline change - p5 NRC staff urges tougher safety goal plan -plI Rancho Seco restart timing in doubt -p5 ACRS members critware Indian Point ruhng -Pt 3 hatts Bar weldmg issues resurfacmg - p6 (nmanche Peak paine esempison challerved - pl 3 Anteirug pohty snagged on enforcement -p7 Aswlstane inshts on applymg backf at rule -pl$
Hesearch reorsents to ski plant operations - p9 htcal year 1985 fines charted - pl 5-20
.e e-
- . .s ter accompanying the inspection report, James Taylor, director of the Office of Inspection & Enforce-ment (IE), said 10 fmdings could result in enforcement action.
i FP&L has not yet responded formally to the report, according to spokeswoman Stacy Shaw, but the utility has protested several findings, in the exit interview and in a subsequent letter (INRC,14 Oct.,19). Taylor noted that man:gement began a " performance enhancement program" after receiving low ratings on the last SALP (systematic assessment oflicensee performance) report, but said, "The in-spection team noted that performance in the functional areas of mamtenance, surveillance testing; and design changes and modifications has not markedly improved." Taylor said he understood the utihty "took t rompt action...to address the team's safety concerns," adding NRC will follow up.
Specific findings from the report included:
-The safety grade backup air system for the non-safety grade instrument air system, ntal to keeping AFW flow control valves (and the system) operating, had never been functionally tested though it had been "substantially modified." A test showed operators had only six to seven minutes. in-stead of 15 to 20 minutes, to valve in new mtrogen bottles to the backup system in the worst case. Re.
sponse would have been hampered by an incorrect annunciator response procedure, and the annuncia-tor alarm set-point was halved without a safety evaluation. "The team concluded that the weaknesses
! identified...could have all contributed to a significant nsk of a kiss of AFW flow."
-The AFW system is shared by Turkey Point-3 and -4, and its design basis requires that one j pump be able to remove decay heat from both units. Ilowever, operators must anure the correct din-sion of flow between the units. Operators were not trained in the situation and the;i procedures did not 1
cmer it.
l -The AFW turbine steam supply isolation vahes could not be shut from the control room if an
! AFW actuation signal was present. Operators had no training to recognize the signal's overnde of con-trol room switches "The team concluded that the lack of operator awareness that the steam tiowpaths
{ in question could not be isolated remotely from the control room could have resulted in an unnecessary j and potentially sigmficant radioactive release to the environment following a steam generator tube rup-t u re.*
- Programmatic weaknessess" were found in maintenance, includmg "the consistent failure to evaluate the root cause of equipment malfunctions and to trend these failures to provide input to the
{
j preventive maintenance program," though key parts of the AFW system had experienced recurrent component failures.
(
- Formal classroom training sessions for maintenance technicians had been disconunued m Au-4 gust 1984. Licensee management stated that maintenance training had been discontinued to dedicate i
traimng resources to developing training matenals required to support INPO accreditation of the mam-tenance training program....A very hmited amount of on the job training and vendor supphed training had been conducted smce the decision to discontinue classroom training ,
- Over half of the I&C (instrument & control) technicians that conduct surveillance tests (15 of 27 at the time of the inspection) had an average ofless than 6.5 months of experience at Turkey Point.
The electncal and mechanical maintenance groups have also recently experienced high turnover rates among their technicians."
- Management controls did not exist to ensure that safety related maintenance activities were performed by-qualified personnel.... Maintenance procedures generally lacked detail. Complex safety re-lated maintenance activities were often considered to be within the scope of the ' skill of the trade
- and i therefore not requiring procedures.... Post maintenance testing requirements were typically not included as part of electrical and I&C plant work orders (PWOs)."
--The apparent result was "a large backlog of safety related PWOs throughout both units."
Steam jet air ejector process radiation monitors had been out of service about six months, the unit 4 containment sump high level annunciator had been out since Decernher 1984 and two of four post-acci-j dent sump level monitors out since February, and several area radiation monitors on both units were i
out of service for greater than six months. Iloth units had leaking power operated relief valves (porvs) and unit 4's block valves also leaked, resulting in elevated temperatures in the common discharge pipe downstream of the pressunzer safety relief valves. As a result of the last, all three unit 4 control room annunciators continuously showed alarms, impairing operators' ability to recognize relief valve failures.
- Dunng a system walkdown, the drain hnes on the turbme casings and the exhaust silencers I were noted to be hot. Water was flowing from the drains on the A and C turbines The steam supply ,
, isolation valves for the A and C turbmes were leaking and allowing steam to reach the turbines even i
! though the valves were closed....The awociated steam supply valves on umt 4 also appeared to be lea.
king....The Il turbme did not appear to have any leakage from its steam supply valves....No current 2
1.NSIDI N.R.C. - October 28.1985
. _ . . _ ___.____._.m., ._._, _ , _ _ _ _ _ _ _ . _ . _ . . _ _ _ . . - _ , _ . . _ - . _ _
e
,,t
' PWOs were noted on the leaking steun supply valves." l
- -Seismic qualification "was not being properly maintained," with control air lines not proper y anchored and a temporary scafTolding erected above all four instrument racks for both units' AF flow transmitters so that a collapse could have failed all AFW.
- Programmatic
" weaknesses" were found in the design change process. "He engineering group (i~ often did not provide post. modification testing requirements.... Modifications were installed without detailed design analysis.... Design bases for safety related tystems were difficult to retrieve." The tea found the utility " frequently base (d) design changes on engineering judgment that the new design w bounded by the original design analysis. Documentation justifying the engineenng judgment typ did not exist."
-At least partially as a result, "Four of six AFW steam supply isolation valve motor operators f were changed from AC to DC motors without adequate design analysis. Motor oserload protection the new DC motors was not properly sized. Further, the new power cables were not properly sized to ensure adequate operating voltage for the motor operators in the event of a loss of off-site powe hcensee had not performed any cab'c sizmg calculations to support this design change?
-Potentiak for common mode fadures were introduced by design changes. Common relays and hmit switches were put mto redundant Train A and B flow control circuits and design of mtrogen backup systems could fail redundant control room annunciator circuits.
-Safety related station batteries were modified but no calculations were done to show the new
' ones could meet the design basis and plant procedures and technical specifications were not changed recogmze the new battertes' different requ rements.
- Excessive
" reliance was placed on operator action instead of design features to ensure the prop-er functioning of the AFW system."
- A" review of the corporate and site quality assurance (QA) auditing activities revealed that these audits. as implemented, neither had identified nor were capable of identifying quality concerns of a technical and operational nature" like those NRC found. "Both the corporate vendor audit and the plant audit programs were designed to assure that QA programs met NRC requirements and licen comrmtments from a programmatic basis only....(which) meant that FP&L management was not re-ceiving important feedback on the quality of activities affecting the safe operation of the plant."
Several industry sources said FP&L was objecting to some of the report's conclusions and pressing
( to have them changed. hey said industry groups are concerned about the apparent new mihtancy in the NRC staff and will try to get the NRC commissioners or (nendly members of Congress to inter-vene.
In developmg performance indicators, NRC is also conducting special maintenance program re-siews at seven plants. William Russell of the Office of Nuclear Reactor Regulation said NRC is ahead in developing performance indicators in the maintenance area since staffers have already been' visiting plants to determine where industry initiatives are working and where NRC action is needed (INRC,19 Aug.,1). Turkey Point is also on that list, with a review scheduled for later this year, along with Caro-Ima Power & Light Co.'s Brunswick and Arkansas Power & Light Co.*s Arkansas Nuclear One. Pro-gram reviews have already been done at Northeast Utilities' Millstone, To cdo Edison Co.'s Davis-Besse, Sacramento Municipal Utihty District's Rancho Seco, and Wisconsin Public Service Corp?s Kewaunee.
Region 11 Administrator Nelson Grace noted INPO and the Nuclear Utility Management & Ilu-man Resources Committee (Numarc) want NRC to stay out of managemen* areas and said he agreed NRC should not be managing plants. But, he said,"We can and must touch on those areas, to the ex-tent that all of our (inspection) fmdings must be laid at the doorstep of top management....The buck stops there."-Margaret L Ryan and Eric Lindeman. Washington MERITS OF USER FEE SCHEME TO BE RESOLVED BY HOUSE-SENATE CONFERENCE The merits of a proposed scheme by which NRC would be required to collect user fees to offset 50% ofits authorized budget will be battled out by llouse and Senate conferees when a budget confer-ence begins meeting this week. The llouse was expected to approve by the end oflast week its version of the budget reconcihation bill, which includes the user fee scheme. Since the proposal is not included in the Senate version of the bill, it will first he considered by that body in conference.
The conference is expected to continue for at least a week, so it is uncertain when the user fee
{ provmon will be conudered. In the meantime. industry lobbyists are working to kill the provnion, questiomng the basis for setting budget recovery at 50% Fightmg in the industry's corner is Rep. Dan
' Rostenkowski(D Ill.), chairman of the llouse Ways & Means Committee, who argued before the Rules Committee that the user fee is really a tax and so must he considered by hn committee first. The
! 3 IN51DE N.R.C. - Octotter 28,1985
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TURKEY P0thT NECHAhlCAL DESIGN EXIT PRESEhTAT10h identification of Inspection Scope 45 portion of the inspection concentrated on the adequacy of design and the design control process with respect to modifications performed on the Auxiliary Feedsater System. I examined portions of the design associated sith PC/V 80-77 and 80-117.
Inspection Observations t
The team identified three concerns with respect to the design adequacy; of Auxiliary Feedsater S> stem.
l The team has a significant concern that excessive reliance is placed upon operator action instead of design features to ensure the proper f unctioning of the Auxiliary Feedsater System.j/$pecifically, the team is concerned that immediate operator action may be required upon initiation of the Auxiliary Feedsater System follosing a loss of main feedsater and
' reactor trip sith a concommitant loss of the non safety-related instrument air supply. Although the Auxiliary Feedsater System is designed to automatically initiate. design calculations do not exist which demonstrate that the system sell continue to run for a period of time without immediate operator action. Upon auxiliary feedsater initiation the fios control valses are automatically controlled to pass 125 gpm of feedsater to maintain the steam generators as a heat sink: however, upon loss of air these valves are designed to fail shut. To prevent this from occurring the fios control valves are provided eith a safety-related source of bottled nitrogen to restore the source of motive and control power. In reviewing the design of the nitrogen system the team made the foliosing observations:
s
t o Design analysis dio not exist to document the setpoint selection for pressure ssitches used to alert the operator that ten minutes of nitrogen 1-remains before loss of motive and control pressure t i . e. . closure of fios
}
control valves and loss of ait feedsater).
o Design criteria does not exist to define how long the auxiliary feedsater system has to operate sithout operator action. Consequently. no I,
.\
'l guidance was provided to establish operating limits on available nitrogen supply before reaching the los levei setpoint.
o Electrical and instrumentation and control equipment associated sith the
[1 nitrogen system sere not scentifica as safety related in FP&L's Q-List. As
, a consequence, pressure ssitches used to alert the controi room operator of los nitrogen pressure and the need for immediate operator action to valve in another nitrogen cylinder sere not being treated as safety related by the site Instrumentation and Control Department.
I o Engineering did not provide post modification testing requirements to confirm the adequacy of the installation to design bases.
The team is also concerned that other design features place a significant burden on the operator in addition to the restoration of control and motive poser to the flos controlvalves.JThesystem design description and design ~
- bases for the Auxiliary Feedsater System requires that 286 spe be supplied to both units in the event of a tso unit trip and that some single active v
M failures sill require operator action from the control room sithin three minutes to assure correct fios distribution to each unit. The auxiliary feedsater is arranged into tso trains and any one train is required by design criceria to supply both units. Consequently, train 2, containing one auxiliary feedsater pump, is required to supply both units. Because the fios control valves are preset to supply 125 sps and the auxiliary feedsater pump is limited to approximately 600 spa, operator action sill be
required to balance ilos betseen units.
- 2. The team also has a significant concern eith the adequacy of design features to protect the turbine pumps from steam leaking past the steam admission valves. Although not identified in the system design description and design bases document for the Auxiliary Feedsater System. steam vent valves are provided to vent steam shale the system is not operating., The valves are signaled to close on increasing steam pressure t i . e. . increasing steam pressure indicates auxiliary feedsater system pressures and close 4
i l
upon decreasing pressure to vent the steam lines between the steam adduission valves and the auxiliary feedsater pump turbines. steam
'l vent valves are outside of the seismic boundary and are treated as l'
7 non safety related. The team believes the valves serve a safety-related i function of assuring tnat steam leakage pass the steam admission valves f,
// I does not cause condensate to accumulate such that the capacities of the ,
turoine casing and exhaust drains are exceeded. The team is concerned that excessive condensate accumulation can cause common mode failure of the I l
auxiisary feedsater pumps to overspeed. in reviesing this design feature f
\
the team made the foliosing observations. -
\
t
\
Ao Designanalysisdoesnotexisttodocumenttheconsequenceoffailureof(
the vent valves to shut and the ability of the auxiliary feedsater pump to kf supply sufficient feedsater fios at reduced steam generator pressures to reach the point of residual heat removal system operation.
\
o Design analysis does not exist to document the setpoint selection for
\
b pressure ssitches used to control the operation of solenoid operated steam )
vent valves. The setpoint was verified to be at 150 psig shich sill permit ;
[ the valve to open automatically before the cooldosa has been transferred to f the residual heat removal system. .
p
- 3. In reviesing the design activity associated sith safety related
LO l i
1
,e condensate storage tank, it was found that operator error to close a manual isolation valve can cause an undetected common mode failure of the s
a redundant level indication.
hith respect to design change process, the team observed instances of control design activites and those that reflect adversely. The team found that the cesign calculations are not controlled by FP&L as living design documents and are filed shen perf ormed wi th the modification package. The team sas informed that design inputs are maintained such that, if required.
calculations can be performed to recreate the calculation. The team found g that design criteria documents do not exist and that design bases are in many instances difficult to determine. This condition is further
//
s6 complicateo by the controls Bechtel maintains over calculations performed The team found that Bechtel has a set of original project I by Bechtel.
design calculations shich are used for reference purposes but not updated.
For current design activities. Bechtel maintains design calculations and upcates those calculations as plant modifications are assigned to their des i gn respor.s i bi l i ty by FP&L. As a consequence. it is difficult for a Bechtel or FP&L engineer to knos sere applicable design analyses are to be found. As a consequence the team observed a lack of attention '.a documenting assumptions, justification for their use, and confirmation that the assumptions sere accurate after the design had proceeded. Likesise.
the team found that the source of input data sas not consistently design documents but the FSAR or uncontrolled Plant Data Boots. As an example of this condition. FP&L engineer performed a calculation to establish the setpoint for the los level alarm on the Condensate Storage Tank and did not identify all of the assumption and design inputs used to perform the calculation. The team found no evidence in the calculation that the preparer considered the NPSH required to maintain AFL pump operation.
Instead of preparing a design analysis or requesting information from Y1 P Bechtel, it appears that the preparer assumed that the minimum NPSH sould I be below the instrument tap. It as also unclear at this time that the f
preparer of the calculation knes the elevation of the instrument tap, because a design document does not currently exist identifying that dimension. The team confirmed that the design is not deficient: hosever, a control design process sas not used.
The team also found instances ehere modifications are installed without For example, in the 1981 through 1984 timeframe
(
) Trigoruousoesignanalysis.
the nitrogen system sas required to supply three additional auxiliary
/ feedsater fios control valves, the existing bottles sere divided into 6$ f, trains. ano the actuators on the existing operators changed. Instead of perfor' ming a design analysis sith the techntcal detail and quality controls consistent sith that expected of a calculation performed in early 1980's.
the design modification sas installed based upon inspection of a original project calculation performed in 1972 and engineering judgement that the i nes design sas bounded by the original calculation. It is not clear to the team that the calculation is bounding and documentation justifying the engineering judgement does not exist.
As stated previously the design basis for a given system is difficult to determine. The team viens the development of the Auxiliary Feedsater h System Description and Design Basis document as a positive effort shich should be considered for application to all safety related systems at Turkey Point 3&4.
- 2. L
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f) df trende n,these failures to provide input into the preventive maintenanc prograrg r n ' L.-- - - --:c-- - =. The Plant Work Order (PWO) form is used to document the performance of maintenance and a section of this form is provided to describe the cause or reason for the trouble found. A review of completed PWO forms revealed that the cause of the associated equipment failure was described in very few cases.
Interviews with maintenance supervisory personnel revealed that the cause of equipment failures and the consideration of the recurrent nature of failures are tracked informall by relying upon the memory of maintenance
~ S
,I suprevisors.j,The %
nyuiqiwy hi tory records were not being kept up to j
I Iateintheelectricalandmechanicalareas.
A adrWa review of the maintenance history records for the auxiliary feedwater (AFW) system, which included PW0s and Licensee Event Reports (LERs), revealed a number of component failures of a recurrent nature.
These included seven separate examples, since January 1984, of the failure of an air-operated AFW flow control valve to properly function l due to water or foreign material in the supply air, s
L3 In 1983, on two separate occasions, two of the six auxliary feed steam supply motor operated valves (MOVs) failed to open because of carbon build-up on the motor operator limit switches. A search of the -
maintenance records for the remaining four auxiliary feed sQm supply MOVs revealed that, despite the recent failures mentioned above,4109 m # OV A od 3-140 had been electrically cleaned and inspected since October 1981 had not been electrically cleaned and inspected since and[{l0 1979. Sever d additionab weaknesses-associatef with maintenance on MOVs g lscussed in aba c ution 2._
- 2. A review of the maintenance activities performed on MOVs revealed weaknesses with training for the repair of these valves. Interviews with supervisory maintenance personnel revealed that no training has been i conducted in either the mechanical or electrical areas on the repair of g MOVs with the exception of undocumented, on-the-job training and pre-maintenance briefings. A mock-up of a Limitorque valve operator was
~
available in the training department offices but apparently had not been used to train maintenance personnel.
- 3. Of 54emad6 seat concern was the W:t -- ;'-' uncertainty on the part of mechanical maintenance personnel of the type of grease used in MOV gearboxes. This is considered a problem for two reasons. First, the mixing of different types of grease in the gearbox could cause hardening
/ or separating of the lubricant. The potential for this exists at Turkey ,
Point because their preventive maintenance instructions for Limitorque gearboxes specify the use of Texaco Marfac and these same Limitorques are i
l known to have been supplied with either Exxon Nebula EPO or EPI or Sun 50 1
1
M
, g ... J m ._ r i , m - n--4 "
EP lubricants. Sr-dy the only Limitorque lubricant that meets tne environmental qualification requirements of 10 CFR 50.49 at Turkey Point is Exxon Nebula EPO or EPI. -
w The licensee had previously identified the problems discussed above
,. regarding Limitorque lubrication. A program to address these concerns is
- underway and scheduled for completion by December 1986. The progress of w-]
this effort will be tracked by the NRC Region II Office (50-250/85-XX-XX, 50-251-XX-XX). :
Although several of the previous observations may indicate a general
/
weakness regarding MOV maintenance, the licensee has recent1p(aken some positive' steps to improve F)V reliability. Temporary (rating Procedure 166 was issued in May 1985 and provides detaileb nstructions for trouble-shooting and repai} of MOVs, including 11pt witches, torque switches, and post-maintenance testing. This piocedure provides specific torque
~ ~
/
switch settings for safety-related motor generated valves and the require-ment that, during maintena'Ece, oper torque switch setting be verified
.- x by an electrical , quality control inspector. Discussions with management
,/ N representative's revealed that the licensee is'iq the process of purchasing some rpratively new and innovative MOV test equip n d ,tJH W they intend tV ilize this aquipment to improve the reliability of 'their MOVs.
,/
d Y A review of calibrati)n i
1 r. nw records revealed that the low pressure alarms for
=
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the AFW nitrogen sN' system are not routinely calibrated.8 A search of calibration records with the assistance of an Instrument and Control
(! sri surervisor revealed that the last available records of the l
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d M calibration of S 2322 aInd PS 232pwere dated June 14, 1978. In addition, no procedure was available for the calibration of these alarms. The apparent failure to periodically calibrate these instruments L ,
,M and provide a procedure for this purpose was discussed with't$e licensee M/ l ,
m and will remain unresolved pending followup by the NRC Region II Office (250/85-XX-XX,251/85-XX-XX).
T K. The control and documentation of post-maintenance testing was found to be weak. In many cases, neither the instructions outlining appropriate post-maintenance testing nor the results of the testing performed were Y/
- documented on the Plant Work Order. This was particularly evident for t
f inu_d-i I&C and electrJa1-related maintenance activities.MtL Ce4t cf Administrative
~
P&AwSSaw a</hEJus,"
Procedure (AP) 0190.28,Post Maintenance Test Control," was specifie the PWO in most cases,fE.;!.' ;-
- --J :: n ! --et^d e'-t;. 2:J. This procedure describes much of the testing considered adequate to return
'h/j /, mechanical systems to operability and provides a fonn to document the '
test results which is then attached to the PWO.
The apparent failure to provide adequate instructions for post-maintenace testing on the PWO appears to be contrary to AP 0190.19 " Conduct of Maintenance on Nuclear Safety Related and Fire Protection Systems," was discussed with the licensee, and will remain unresolved pending followup
{
bytheNRCRegionIIbffice(250/85-XX-XX,251/85-XX-XX).
I, 'd. A weakness was noted in the program to ensure that instruments are properly returned to service following maintenance or calibration while i
N the plant is operating. The licensee had a program for providing general assurance that instruments inside and outside the containment are properly aligned when the plant is returning to operation from an outage condition. The procedures describing the instruments to be ecked, 0-SMI-059.1 and 0-SMI-059.2, were generally adequate, providing a place for first and second check verification for each applicable instrument.
Inteviews with I&C supervisory personnel revealed that these procedures would normally be used only to verify instrument alignment at the end of an outage condition.
Instrument 11ne-ups were not required by the
$)h licensee to be independently verified following maintenance or calibration when the plant is in an operating status. Of additional t consideration in this issue is the fact that44 of 34 I&C maintenance ".
technicians at the time of this inspection had less than one year experience at Turkey Point.
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TURKEY POINT - OPERATIONAL READINESS INSPECTION OF AUXILIARY FEEDWATER SYSTEM BY IE AUGUST 26 - SEPTEMBER 13, 1985 (J. CALLAN, IE)
PROBLEM - INSPECTION IDENTIFIED SIGNIFICANT TRAINING, PROCEDURAL, TESTING, MAINTENANCE, AND DESIGN CHANGE <
PROBLEMS AFFECTING THE AFW SYSTEM SAFETY SIGNIFICANCE DEGRADED OPERATOR ABILITY TO ISOLATE STEAM FROM THE AFFECTED STEAM GEN.ERATOR IN THE EVENT OF A STEAM GENERATOR TUBE LEAK DEGRADED AFW OPERATION DUE TO LOSS OF BACKUP N
2 SUPPLY TO AIR-OPERATED AFW FLOW CONTROL VALVES POTENTIAL FOR DEGRADATION OF OTHER SAFETY SYSTEMS DI ~~ "'"urefrANT PROGRAMMATIC WEAKNESSES IN M HANGE/ MODIFICATION PROGRAM, A [ MODIFICATION TESTING
[ 7 )N IN THE EVENT OF A TWO-UNIT
. JC DISCUSSION DESIGN CHANGE PROCESS WEAK. LACK OF DESIGN DOCUMENTS, SUPERFICIAL SAFETY EVALUATIONS, POOR POST-MODIFICATION TESTING Ah
3 MAINTENANCE PROGRAM WEAK; P!GH TURNOVER, LACK OF DETAIL IN PROCEDURES, LACK OF TRAINING, AND WEAK MANAGEMENT CONTROLS OPERATOR TRAINING AND E0PS DID NOT RECOGPIZE THAT STEAM TO AFW PUMP TURBINES COULD NOT BE ISOLATED FROM CONTROL ROOM IN THE EVENT OF A STEAM GENERATOR TUBE RUPTURE OPERATOR TRAINING AND E0PS PROVIDED MISLEADING AND INSUFFICIENT INFORMATION TO ENSURE ADEQUACY OF N 2 SUPPLY TO AFW FCVS N
2 BACKUP SYSTEM HAD NEVER BEEN ADEQUATELY TESTED FOLLOWUP LICENSEE COMMITTED TO TAKE IMMEDIATE CORRECTIVE ACTION FOR MOST TRAINING AND PROCEDURAL WEAKNESS AFFECTING AFW IE., REGION 11, AND NRR ARE IDENTIFYING APPROPPIATE LONG-TERM CORRECTIVE ACTIONS l