ML20207N096
| ML20207N096 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 01/09/1987 |
| From: | Woody C FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| L-87-14, NUDOCS 8701130457 | |
| Download: ML20207N096 (8) | |
Text
P. o. BOX 14000, Juno BEACH, FL 33408-0420 y
$!!y JNIJARY_.00 1987 L-87-14 10CFR2.201 1
U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555 Gentlemen:
Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Inspection Report 86-39 Florida Power & Light has reviewed the subject inspection report and a response is attached. The submittal date for this response was revised with the concurrence of the Region 11 Staff.
Should there be any questions on this information, please contact us.
Very truly yours, M
- 0. Woody roup Vice President Nuclear Energy COW /PLP/gp Attachment cc:
J. Nelson Grace, Region 11, USNRC USNRC Senior Resident inspector, Turkey Point Plant Harold F. Reis, Esquire Nt $CN 87 1 So ff o
i
"'""8'"""'
PLP1/02I/l
ATTACHMENT Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Inspection Report 86-39 FINDING A Technical Specification (TS) 6.8.1 requires that written procedures and administrative policy be established that meet or exceed the requirements and recornmendations of sections 5.1 and 5.3 of ANSI N18.7-1972 and Appendix A of USNRC Regulatory Guide 1.33.
1)
Appendix A of USNRC Regulatory Guide 1.33 requires procedures for the proper operation of safety related systems such as the control rod drive system, nuclear instrumentation systemn and the reactor control and protection system.
Temporary Operating Procedure (TOP) 233, Functional Test of PC/M 84-209 Power Mismatch Modification and PC/M 84-211 Turbine Runback Modification, revision dated January 10, 1986, specifies required testing to be performed subsequent to the installation of the modifications. Step 4.11 of TOP 203 specifies that the procedure con be implemented with the Unit 4 reactor in cold shutdown. Step 8.5 specifies that reactor power be simulated to be above 10% power. Step 8.29 requires the closure of the reactor trip breakers to allow certain control rods to be raised off the core bottom.
Contrary to the above, TOP 233 was not an adequate procedure, in that it could not be performed during cold shutdown conditions. Performance of Steps 8.5 and 8.29 would result in on unplanned actuation of the reactor protection system due to the automatic reopening of the reactor trip breakers. Thus the control rods could not be raised off the core bottom and the procedure could not fulfill its intended function.
This deficiency resulted in an unanticipated actuation of the Unit 4 reactor protective system on August 5,1986.
2)
Appendix A of USNRC Regulatory Guide 1.33 requires that procedures be developed to implement a plant fire protection program.
ANSI N18.7-1972, Section 5.3.5, requires, in part, that permission to release equipment for maintenance be granted by responsible operating personnel.
Prior to granting permission, such operating personnel shall verify that the equipment or system con be released, and if so, how long it will be out of service.
The granting of permission by the operations group shall be documented. Equipment and systems in a controlled status shall be clearly identified. Strict control measures for such equipment shall be enforced.
Contrary to the above, on six separate occasions between June 4 and June 26,1986, fire doors were propped open, rendering them out of service as effective fire barriers. The removal of the otherwise operable fire doors from service was neither controlled nor authorized and the doors remained out of service for an unknown period of time. No plant procedure existed specifying the method by which fire doors should be controlled.
PLPl/021/2
RESPONSE
FINDING A.I I)
FPL concurs with the finding.
2)
TOP 233 did not assure that all relevant plant conditions were taken into consideration during the performance of the procedure. Specifically, the procedure did not ensure that the At Power Trip signals were clear or bypassed prior to simulating 70% power. Previously, testing per TOP 233 was successfully completed on Unit 3 while it was in hot shutdown, with the turbine latched up. When turbine first stoge pressure above 70% power was simulated on Unit 3, the P-7 permissive was enabled, however, no trip signal resulted as no trip conditions were present.
While the test was being performed on Unit 4, multiple trip signals were present due to the cold shutdown plant conditions, and the reactor trip breakers opened. The cause of the inadequacy of procedure TOP 233 was personnel oversight during the preparation of the procedure, in that the procedure did not address the appropriate unit conditions.
3)
Following the subcritical reactor trip, procedure TOP 233 was reviewed step by step to assure that all relevant plant conditions were token into consideration. As a result of this review, steps were added to ensure that all trip signals which may be octuated by the procedure were cleared or bypassed prior to simulation of reactor power level above 10% Appropriate steps to ensure proper system restoration prior to unit operation were also added. The procedure was successfully performed.
l 4)
The Procedure Upgrade Program (PUP) is currently revising and developing procedures in the areas of administration, normal and emergency operations, as well as surveillance and maintenance. The PUP is largely based on INPO guidance and good practice.
The PUP is part of the Performance Enhancement Program at Turkey Point.
5)
Full compliance for item 3 above was achieved by September 4,1986.
2 FINDING A.2 l}
FPL concurs with the finding.
2)
The cause of fire doors being out of service, without each door having been specifically identified as not being in service, was the plant's understanding that the program for the control of fire doors was in full compliance, even though each disabled fire door was not specifically identified as such to the operations group. At the time the disabled fire doors were discovered, the plant was in the midst of performing modifications in accordance with Appendix R requirements. Due to the number of components not meeting Appendix R requirements, and as part of the schedular exemptions from the 10 CFR 50.48 defined schedules granted to the plant, the NRC and the plant agreed that reasonable interim compensatory measures for fire protection would be provided.
The compensatory measures consist of roving fire watches, which enter each area where compensatory measures are required, every 20 minutes. The fire watches identify any indicotton of fire, smoke or 4
burning odor, and immediately notify the control room. As the disabled fire PLPl/02)/3
doors were in areas covered by the roving fire watches, and as other components and fire barriers which may not have met Appendix R requirements could also have been situated in the some fire zones, the plant felt that the roving fire watches adequately addressed the necessary concerns.
3)
New procedures for the control of fire doors and the breaching of fire rated assemblies and barriers have been prepared. Plant personnel have been reminded of the importance of keeping fire doors and barriers functional.
4)
As part of the upgrade of the plant fire protection features, fire doors have been pointed red, and signs requiring closure have been placed on them.
Plant Management has issued directives requiring action when a non-functional or open fired door is found.
5)
Full compliance for items 3 and 4 above was achieved by October I,1986.
FINDING B:
10 CFR 50, Appendix B, Criterion XVI, os implemented by FPL Topical Quality Assurance Report (FPL-NGA-100A) Revision 8, TOR 16.0, Revision 4, Corrective Action, requires, in port, that measures be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
FPL Quality Assurance Manual, Quality Procedure 16.1, Revision 8, delineates requirements for assuring that conditions adverse to quality are corrected.
Procedure 0-ADM-913, revision dated May 23, 1986, entitled Corrective Action for Conditions Adverse to Quality, itemizes the mechanisms by which conditions adverse to quality are promptly identified, tracked, and corrected.
Contrary to the above, the licensee failed to maintain on effective program for the correction of conditions adverse to quality in that:
1)
Corrective actions, implemented in 1985 when four TS surveillances were not performed within their required periodicities, failed to prevent, between January and June 1986, nine additional surveillances from being performed at periodicities longer than those allowed by TS; and 2)
Corrective actions, taken in September 1985 and June 1986 subsequent to the issuance of separate audit fingings which specified that Administrative Procedure (AP) 0103.36, Control of Operator Aids and Temporary Information Tags, was not being correctly implemented, were inef fective, in that they did not result in the correct implementation of the procedural requirements. Consequently, an NRC audit conducted in September 1986, identified additional similar discreponcles associated with the administration of the procedure.
PLPI/021/4
RESPONSE: :
FINDING B.I l}
FPL concurs with the finding.
2)
A review of the missed surveillances has identified a number of contributing factors:
A) Several surveillances were missed because they were imposed as a result of license omendments, and due to personnel oversight, the need for odditional procedures to implement the amendments was not realized.
B) Two surveillances were missed because of reliance on a non-conservative computer generated projection of activities.
C) One surveillance wc,s missed because of problems of coordination between groups.
D) One survelliance was missed because the hardware design did not permit performance of the surveillance.
3)
Plant Management, having recognized that administrative controls to schedule and perform Technical Specification surveillances were not fully effective, undertook a comprehensive effort to eliminate missed surveillances. This effort was initiated in 1985, and was fully in place in May,1986. Some of the missed surveillances were discovered as a result of setting up programs to eliminate the missed surveillances. The following steps have been taken to assure timely performance of Technical Specificotton required surveillances:
A) Administrative Procedure 0190.16, " Scheduling and Surveillance of Periodic Tests and Checks Required by Technical Specifications", has been revised to provide a matrix of all Technical Specification required surveillances.
B) The FPL regulatory commitment tracking program (CTRAC) has been used since the first quarter of 1985 to assure implementation of new or revised techncial specification requirements.
C) Procedure 0-OSP-200.l, " Schedule of Plant Checks and Surveillances",
has been written and implemented. This procedure provides a schedule for the performance of all Technical Specification required surveillances, and centralizes the responsblilty for scheduling the performance of all TS required surveillances in Operations.
D) Procedure 0-OSP-200.2, " Plant Startup Surveillances", has been written and implemented. This procedure provides a method for assuring that Technical Specification surveillances are performed prior to each mode change. This procedure is designed to be used in conjunction with 0-OSP-200. l.
j PLPl/021/S
E) The Procedure Upgrade Project (PUP) has been in place since March 1984. Picnt Management has directed PUP to review all procedure change requests involving TS items in order to assure that all procedures affected by a TS required surveillance are properly revised.
4)
The Operations Maintenance Coordinator (or his delegate) has been assigned the task of monitoring the TS surveillance schedules of 0-OSP-200.1 on a daily basis.
He is to notify each responsible supervisor of any missed surveillances which were to be performed by that supervisor's group. A Surveillance Technician has been assigned the task of tracking TS required surveillances. The Technicion is to keep track of the date each surveillance is due, the date it is actually performed, and if it is not performed prior to the grace period, the Technician is to notify Operations and the responsible group that the surveillance is late.
5)
Full compliance for item 3 above was achieved by December 23,1986.
RESPONSE B.2 l}
FPL concurs with the finding.
2)
The reason for the finding was that the responsbility for the performance of the audits and reviews was not vested in the proper party.
3)
Procedure AP 103.36 was revised to change the responalbility for the audits and reviews to the Operations System Enhancement Coordinator (OSEC).
4)
The OSEC is responsible for directing a monthly audit of the Operator Aid and Temporary Tag Index.
5)
Full compliance for item 3 above was achieved by October 21,1986.
FINDING C Technical Specification (TS) 6.8.1 requires that written procedures and administrative policies be established that meet or exceed the requirements and recommendations of Sections 5.1 and 5.3 of ANSI N18.7-1972 and Appendix A of USNRC Regulatory Guide 1.33.
Appendix A of USNRC Regulatory Guide 1.33 states that procedures should be established specifying:
(1) outhorities and responsbilities for safe reactor operation; and (2) operation of the main steam system.
1)
Administrative Procedure 0103.2, Responsibilities of Operators and Shif t Technicians on Shif t and Maintenance of Operating Logs and Records, revision dated July 29, 1986, requires, in Section 5.4.2, that the Reactor Control Operator (RCO) shall report all significant plant changes, unsafe operating trends or unsafe conditions to on on-shif t Senior Reactor Operator (SRO). Section 5.4.3 of AP 0103.2 requires that the RCO maintain direct sensory perception of, and access to, Unit status and safety system monitoring and controls.
PLPI/021/6
l Contrary to the above, on August 9,1986, during a plant heotup, a Unit 4 RCO failed to adequately monitor steam generator water level, allowing the level in the 4C steam generator to decrease to the low-low olarm setpoint and the condition was not reported to on SRO. This personnel error resulted in the automatic octuation of the Auxiliary Feedwater System, as per system logic design, on low-low steam generator level.
2)
Procedure 4-0P-065.2, Auxiliary Feedwater (AFW) and Main Steam isolation Valve (MSIV) Backup Nitrogen Gas Supply System, revision dated August 12, 1986, requires, in ottachment 2, that MSIV nitorgen station header isolation valves 4-5202, 4-5237 and 4-5272 be closed during normal system olignment. The volves had lost been verified to be closed on August 21, 1986, as required by On-The-Spot-Change (OTSC) 4468 to 4-OP-065.2.
Contrary to the above, on September 25,1986, the valves were found to be open.
RESPONSE C.I I
FPL concurs with the finding.
2)
The failure to adequately monitor steam generator level was due to personnel error.
3)
The operator was counseled concerning awareness of his actions and the seriousness of this error.
4)
Operations management discussed operator attentiveness in shif t meetings and briefings during the month of October. The plant training program will also address operator ottentiveness during the next operator requalification cycle.
5)
Full compilance for item 3 obove was achieved by October 31,1986.
RESPONSE C.2 l}
FPL concurs with the finding.
2)
This discrepancy was discovered shortly offer the system was placed in service.
The reason for the incorrectly positioned volves was, most probably, failure to return the system to proper alignment following system testing.
l 3)
Upon discovery, the volves were positioned correctly, in compliance with 4-OP-065.2, MSIV and Auxiliary Feedwater Backup Nitrogen Supply System.
l The rest of the system was wall <ed down to assure system alignment and operability. The system pressure was noted to be satisfactory.
I i
[
PLPI/021/7
4)
Procedure 4-OSP-072.2, "MSIV Nitrogen Backup Periodic Test" is now in place to perform o monthly surveillance of the system. This procedure requires the operator to note the "os-lef t" volve line-up. This will ensure proper volve line-up.
S)
Full compliance for items 3 and 4 above was achieved by September 26, I986.
i PLPl/021/8