ML20211H471
| ML20211H471 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 02/20/1987 |
| From: | Woody C FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| L-87-74, NUDOCS 8702260186 | |
| Download: ML20211H471 (7) | |
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P. O. box 14000, JUNO BEACH, FL 334C3-0420
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L-87-74 FEBRUARY 2 0 1987 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:
Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Inspection Report 86-45 Florida Power & Light Company has reviewed the subject inspection report and a response is attached.
There is no proprietary information in the report.
Very truly yours, A 0 ))Ur
. O. Woody Group Vice President Nuclear Energy Department l-COW /RG/gp Attachment i
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cc:
J. Nelson Croce, Regional Administrator, Region 11, USNRC Senior Resident inspector, USNRC, Turkey Point Plant l
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PDR Il RG3/032 l an FPL Group company f
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ATDOMINE 1E: IUR EY POINTIMEIS 3 Ato 4 D03Er 10. 50-250, 50-251 IE IIEPBCTI(N EERRE 250-06-45 & 251-46-45 FDODC A:
Technical Specification (IS) 6.8.1 requires that written procedures and administrative policies be established that meet or exceed the requirements and remnwndations of sections 5.1 and 5.3 of ANSI N18.7-1972 and Appendix A of USM C Regulatory Wide 1.33.
FDODC A.1 ANSI N18.7-1972, section 5.1.5. specifies that procedures shall be provided for control of g ip=ne, as necessary, to nmintain reactor and personnel safety and to avoid unauthorized operation of equipment. Section 5.1.2 of ANSI N18.7-1972 specifies that procedures shall be followed.
Administrative Procedure (AP) 0103.11, entitled Housekeeping, revision dated Novenber 13, 1980, specifies in section 8.3.2.4 that scaffolding should be carefully planned ard mordinated with the Plant S@ervisor-Nuclear to ensure that scaffolding is not erected sinultaneously over redundant paps /cmponents in a system in order to provide operability of at least one train of equipment under any forereeable ciremstance.
Contrary to the above, on November 13, 1986, scaffoldirg was observed to inve been erected over both redmdant trains of the Unit 4 Auxiliary Feedeter (AW) system. The scaffolding was above the train 1 AW flow control valves and the train 2 AFW flow orifices and their associated piping and valves. Additionally, two large boards were stored above Unit 4 train 1 AW steam supply notor operated valve (MN) 4-1404, creating an unnecessary seismic hazard.
RES10NSE:
1)
FPI,Econcurs with the finding.
2)
Ilr scaffolding above the Unit 4 AW trains was erected under request SR 634/10-31-86 which when installed was inadvertently placed over both trains of the Unit 4 AW system.
No scaffolding request could be found for placirg the two boards above MDV-4-1404.
3)
'Ihe scaffolding above the Unit 4 AW trains was modified and the two (2) boards above KN-4-1404 were recoved on November 18, 1986. 'Ihe scaffolding was subsequently renoved on December 3, 1986.
t 4)
A) A noetirs; ms held with the scaffolding superintendent to review the scaffolding
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requirenents and stress the inportance of verbati2n empliance, lie in turn will continue to stress this inportance to the responsible craftsmen.
B) Adninistrative site procedure (ASP) ASP-29, Control of Construction Scaffolding, will be l
reviewtd and revised as necessary to ensure that ASP-29 confons to the requirenunts of adninistrative procedure (AIM) 0-ARI-012, Scaffold Control.
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C) In addition Omstruction (kality Control personnel will be requested to periodically walk down selected areas of the plant to verify compliance on a random basis.
5)
Full canplian for item 4 above will be achieved by March 31,1987 FDGIIC A.2:
W NRC Regulatory Gilde 1.33 specifies that procedures should be developed for the operation of the AW system. Plant drawing 5610-T-E-4062, Sheet 3, Revision 44, specifies, in note 2, that flexible hoses are to be connected between'the AN system and the Backup Service Water system during emergencies or extended periods of AW ptmp recirculation operation.
Contrary to the above, prior to November 14, 1986, no procedure existed describing the proper method by which to supply Backtp Service Water to the AW pump turbine lubricating oil coolers. Additionally, to criteria existed specifying appropriate occasions for the use of the Backup Service Water System as an emergency coolirg water source for the AW pinp turbine lubricating oil coolers.
RESIDEE:
1)
FPL concurs with the finding.
2)
The reason for the finding was that while operating procedure (CP) 04P-012, Service Water Operating Procedure, does address some of the required valve lineups for the backup service water to the AW ptap turbine lubricating oil coolers, the procedure does not provide adequate guidance on Mw and when to place the system in service.
3)
A) Engineerirg has been requested to evaluate the Backup Service Water to the AW plup turbine lubricating oil coolers to review the system to assist in determining the requirements for the system and developing the tmidance to be uM11ml. Upon receipt of this guidance, appropriate procedure / document changes will be made.
B) Training reports describirg the procedure change (s) identified in item 3.a above will be issued in accordance with administrative procedure (AP) 0301, Licensed Operator
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Requalification Program.
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FPL has initiated Phase 11 of the Selected Safety System Review as described in FPL letters Ir66-ll2 ed Ir66-197. The Phase 11 Assessment Program will include reconstitution l
of the system design bases, detailed inspections including walkdowns of the systems, uuuvud=:nsive reviews by the Safety Engineering Group, and assessment of the Configuration Control Program. The systens being reviewed include the Auxiliary Feedwater system. The conpletion of this project is under the schedules and controls of the confirmatory order for this project.
5)
Full compliance for item 3 above is scheduled to be achieved by March 31,1967.
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FIlODE A.3:
Section 5.1.2 of ANS1 N18.7-1972 specifies that procedures shall be followed. Operating Procedure (OP) 0-GM)12, entitled Service Water Operating Procedure, revision 4, dated August 26, 1986, specifies that valves70-102 and 70-103, service eter supplies to AFW punp oil coolers A and B, are required to be open. Valve AFW-009, service water supply valve to the C AFW puup oil cooler in required to be closed.
Contrary to the above, m Novuter 14, 1986, valves70-102, 70-103 and AFW 009 were found not to be in their required positions.
RES10 EE:
1)
FPL concurs with the finding.
2)
The reason for the finiing ms personnel error in that the aforenentioned valves were not pla d in the position required by 04F-012.
3)
The three valves were innediately returned to their correct positions as presently required by pro dure and as shown on print 5610-T-E-4075 and 4062 sheet 3. Therefore canpliance with (HIM)12 ms achieved the same day as the discrepant condition was discovered.
4)
An entry will be inade in the night order book to have this event discussed with the operating crews on shift to re-enghasize the inportance of ensuring that valve lineups are properly canpleted.
5)
A) Full coupliance for itan 3 above was achieved by Novenber 15, 1986.
B) Eb11 compliance for itan 4 above will be achieved by March 1,1%7.
FDODO A.4:
USNRC Regulatory nMa 1.33, Appendix A, Itan 9.a indicates that maintenance that can affect the perfonnance of safety-related equipnent should be properly preplanned and performed in accordance with written procedures, docuumted instructions, or drawings appropriate to the circumstances.
0-mI-102, revisira dated January 16, 1986, entitled Troubleshooting and Repair Cbidelines, requires, in section 9.11, that Ibwer Range k. lear Instrument fuses be removed from the channel under test to allow the renoval of test equipment following the calibration of Power Range Nuclear Instrumentation dropped rod circuitry.
l Contrary to the above, on Decenber 2,1%6, with Unit 3 operating at 100% reactor power, during restoration of calibration of Power Range channel N-41 dropped rod circuitry arri while N-41 ms still renoved frun service, unintenance personnel inadvertently renoved the instrtment fuses for channel N-42. This resulted in operation with less than the mininun mnber of redmdant channels operable.
IESRNIE:
1)
FPL concurs with the finding.
2)
The reason for the finding was personnel error in that the incorrect fuse was pulled while restoring channel N-41 to service.
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3)
He fuse for channel N-42 was installed to restore operability. Troubleshooting was coupleted on power range channel N-41 and it was retumed to service.
- 4) The Instnanentation & Control shop was briefed on the nature and importance of the incident. The individual involved was counseled on the significance of this event and the consequences of his actions. A linnan Performance Evaluation was conducted which identified that the work area needs to be clearly defined when working on adjacent protection channels.
The rpm-mdations of this study will be inplemented.
5)
A) Full conpliance for iten 3 above was achieved on Decater 2,1986.
B) Full coupliance for iten 4 above will be achieved by April 15, 1987.
FDDIlO B:
10 GR 50, Appendix B, Criterion XVI, as implenented by FPL Topical Quality Assurance Report FPilQAR 1-76A, Revision 9, and IQR 16.0, Revision 5, entitled Corrective Action, requires, in part, that neasures be established to assure that conditions adverse to quality, such as failures, malfunctiom, deficiencies, deviations, defective unterial and equipment, and nonconformances are promptly identified and corrected.
FPL Quality Assurance Mamal, Quality Procedure M.1, Revision 8, delineates requirenents for assuring that conditions adverse to quality are corrected.
1)
Contrary to the above, after determining on October 23, 1986 that two support hangers on the Unit 4 charging line were not properly assenbled, the limnsee failed to take tinely corrective action in that the safety significance was not evaluated until November 18, 1986.
Between October 23 and Novenber 18, 1986 no analysis was done regarding charging system operability or IS limiting condition for operation conpliance.
2)
Contrary to the above, after detennining on October 27,1%6 that both the A md B Faergency Diesel Generator (EDG) starting air receivers were improperly bolted to the floor, the licensee failed to take timely corrective action in that the safety significanoe of the mndition was not evaluated until November 26, 1986. Between October 23 and Novenber 25, 1986 no analysis was done regarding EDG operability or IS limiting condition for operation coupliance.
IESRNE:
.1)
FPL concurs with the finding.
2)
The procedures associated with tinely processing of nonconformance reports (NCRs) did not specifically constrain operability evaluation completion time franes.
3)
A functionality analysis for finding b.1 above was empleted on November 21, 1986 which detennined that the piping was functional under the criteria of IE Bulletin 79-14, Seismic Analyses For As-Bulit Safety Related Piping Systens. An evaluation of the condition identified in firrling b.2 was ongoing during this tine period and subsequently completed on November 26, 1986 that provided a justification for contimed operation which stated that the air receivers could be considered operable for the three (3) week estimated repair period, due to the unlikely probability of a setsmic event.
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4)
On Decenber 4,1986, Fagineering procedure (EP) 2.3, Processing of Nmconformance Reports, was adopted which specifies a maxinun of three (3) working days for perfonning operability assessment of N Gs. In actual practice, NGs are tracked on a daily basis. hse NQs judged to require nore inmifate attention are given the appropriate priority. In this regard, a recent survey stows that, for more thcn half the NQs received by Power Plant Engineering, reviews for operability concerns are conpleted within one day.
- 5) Full cmpliance for item 4 above was achieved on De mber 4, 1986.
FDODE C:
Technical Specification (1S) 3.3.3 requires that the containment isolation valves for Base A containnent isolation, Phase B contaiment isolation and contalment ventilation isolation shall be operable with the isolation tines of each power operated or automatic v < ve within the limits established for testing in accordance with Section XI of A9E Boiler al Pressure Vessel code and applicable Addenda as required by 10 GR 50.55a(g), except where specific written relief has been granted by tie Comnission pursuant to 1-CFR 50.55a(g)(6)(1).
Applicable in nodes 1, 2, 3 and 4.
With one or note of the isolation valve (s) specified above inoperable, naintain at least one isolation valve ope able in each affected pera.cration that is open and:
a)
Restore the inopcrable valve (s) to operable status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or b)
Isolate each affected penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one deactivated altamatic containnent isolation valve secured in the isolation position, or c)
Isolate each affected penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one closed marual containment isolation valve or blind flange, or d)
Be in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold stutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Cmtrary to the abon, the licensee failed to comply with the requirenents of the IIDs of IS 3.3.3 during two recent containment isolation valve failures. On September 26, 1986, and October 6,1986, a Unit 4 steam generator blowdown isolation valve and its associated blowdown isolation byp ss valve failed closed, rendering the valves inoperable. These valves are autanatic Phase A contaiment isolation valves. Iliring both event the on shift operators failed to isolate the affected penetration within four (4) tours, as required by IS 3.3.3.B or 3.3.3.C.
RESR NSE:
1)
FPL concurs with the finding.
2) 1he root cause was personnel error. The Technical Specification requirement to renove power from a faulty isolation valve within 4 tours was not fully understood by shift personnel.
3)
A) Q1 shift personnel responsible for unking detenninations of equipmmt operability requirenents were instructed via a letter from the Operations Supervisor to contact off-shift managenent so that team work can be sployed in situations nimilar to those in tre finiing.
Training brief 185 was issued to address this finiing and the applicable TS (3.3.3) as well as the actions that should have occurred.
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B) The guidance provided to the operators to identify contairinent isolation valves was revised to include the contairment isolation valves required to be operable by is 3.3.3 on Jamary 23, 1987.
4) nt las initiated t hse 11 of the Selected Safety System Review as described in F R letters Ir66-112 sid Ir66-197. The Phase II Assessnent Program will include reconstitution of the system design bases, detailed inspections including walkdowns of the systens, unvelmssive reviews by the Safety Ergineering Group, and assessment of the Configuration Control Program. The systems being reviewed include the Contairunent Systems and a subset of -
this system is containnent isolation. This completion of this project is under the schedules and controls of the confirmatory order for this project.
5)
Full coupliance for item 3 above was achieved by Jamary 23, 1987.
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