ML20214J869

Forwards 860812 Confirmatory Order,Insp Repts 50-250/86-11 & 50-251/86-11 on 860131,Insp Repts 50-250/86-26 & 50-251/86-26 on 860108 & 0217-0515 & Notice of Violation & Proposed Imposition of Civil Penalty

ML20214J869
Person / Time
Site:	Turkey Point
Issue date:	08/12/1986
From:	Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Woody C FLORIDA POWER & LIGHT CO.
Shared Package
ML20214J871	List: IR 05000250/1986011 IR 05000250/1986026 ML20214J869 ML20214J878 ML20214J882
References
EA-86-020, EA-86-20, NUDOCS 8608150201
Download: ML20214J869 (4)

See also: IR 05000250/1986011

Text

S Al

,%(o' g UNITED STATES

E o NUCLEAR REGULATORY COMMISSION

h  : WASHINGTON, D. C. 20555 h b[

\...../ AUG 1212-

Florida Power and Light Company

ATTN: Mr. C. O. Woody

Group Vice President

Nuclear Energy Department

P. 0. Box 14000

Juno Beach, FL 33408

Gentlemen:

SUBJECT: CONFIRMATORY ORDER AND NOTICE OF VIOLATION AND PROPOSED IMPOSITION

OF CIVIL PENALTIES: EA 86-20 (REFERENCE: INSPECTION REPORTS

50-250/85-32 AND E0-251/85-32, 50-250/85-40 AND 50-251/85-40,

50-250/86-02 AND 50-251/82-02, 50-250/85-11 AND 50-251/86-11,

60-250/86-26 AND 50-251/86-26)

A Safety System Functional Inspection (SSFI) was conducted by the Office of

Inspection and Enfo, cement (IE) during the periods August 26-30 and September

9-13, 1985, and a followup inspection was conducted by Region II during the

periods November 4-8 and 18-22, 1985 of activities at the Turkey Point Nuclear

Plant, Units 3 and 4 authorized by NRC Operating License Nos. DPR-31 and DPR-41.

Other inspections were also conducted by Region II during the period January 6-10

and February 17 - May 15, 1986. The focus of some of these inspections was the

auxiliary feedwater system (AFW) and the supporting back-up nitrogen system. As

a result of these inspections, failures to comply with NRC regulatory require-

ments were identified. Accordingly, Enforcement Conferences to discuss these

matters were held in the NRC Region II Office on January 8 and 31, 1986 and at

the Turkey Point site on May 9, 1986.

Item I of the enclosed Notice of Violation and Proposed Imposition of Civil

Penalties (N0V) involves significant weaknesses identified in your design control

program. These violations indicate that you had not exercised adequate control

to ensure that changes required as a result of system modifications were

appropriately translated into operating procedures, drawings, system descriptions

and design basis documents. Most of these violations affected the AFW and

back-up nitrogen systems. The NRC stoff considers these violations significant

because operability of the back-up nitrogen system is essential to ensure that

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the AFW can perform its intended function upon the loss of the non-safety grade

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instrument air system. The weaknesses identified in your program could lead to

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degradation or complete loss of the safety functions of 'these systems.

Item II of the enclosed NOV involves the failure to satisfy the requirements of

10 CFR 50.59. In several cases, adequate safety evaluations were not perfomed

for the effects of: (1) changes made which could have led to AFW steam supply

vent failure at low steam pressure conditions; (2) temporary system alterations

CERTIFIED MAIL

i RETURN RECEIPT REQUESTED

8608150201 860612

l

PDR ADOCK 05000250 /7

O PDR f

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Florida Power and Light Company 2

pertaining to the removal of the AFW governor speed control system; and

(3) temporarily adding loads to an engineered safety features electrical bus

which could have overloaded the emergency diesel generator supplying that bus.

These examples are considered significant because of the repetitive weaknesses

demonstrated in this area including three previous escalated enforcement actions

involving 10 CFR 50.59 review deficiencies. It is apparent that the previous

corrective actions you had taken in this area were not adequate.

Item III of the enclosed NOV involves two significant violations of Technical

Specification (TS) Limiting Conditions for Operation (LC0). On January 2, 1986,

radiography personnel identified three AFW steam supply stop check valves as  ;

unacceptable per the acceptance criteria of Test Request 001-86. These valves j

were then inoperable and the system should have been declared inoperable. The

operability of the valves was not adequately evaluated and an LC0 was not i

entered as required by Technical Specification (TS) 3.8.5. On January 7, 1986, ]

an NRC inspector questioned the operability of the valves. At that time, the

valves were acknowledged to be inoperable and Unit 3 was then shut down and

Unit 4 was placed in a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO as required by TS 3.8.5. Unit 4 was

subsequently shut down on January 10, 1986. This violation is considered

particularly significant in that all functions of the valves should have been

questioned when the problem was initially identified on January 2,1986. It

was not until January 7,1986 that your engineering organization evaluated the

radiographic report and determined that the disc guide studs were bent or broken.

The second technical specification violation occurred when on February 12, 1986,

the Unit 3 reactor was taken critical with only three safety injection pumps

operable instead of four as required by TS 3.4.1.4.

Item IV in the enclosed NOV identifies weaknesses in your procedural control

program. These violations involve failures to establish or implement adequate

procedures, and to properly control the revision and distribution of . safety-

related procedures. These examples indicated that your procedural control

program was not fully effective.

Item V of the enclosed NOV involves the failure to conduct adequate load

capacity testing and monthly surveillance tests of safety-related batteries as l

required and the failure to conduct adequate preoperational load capacity tests

of these same batteries. This violation is significant because surveillance

and preoperational testing did not demonstrate the operability of the batteries

as required by TS 3.7. In addition, examples of weaknesses involving your

corrective action program were identified in the performance of your maintenance

activities. This is significant as previous problems were also identified in

this area.

Item VI of the enclosed NOV involves failures to take prompt and comprehensive

corrective actions once deficiencies were identified by you and the NRC.

Inadequate corrective actions were taken with regard to: (1) the adjustment

of cooling water flow to heat exchangers due to low flow problems without an

evaluation of the resulting change in flow to other components also served by the

cooling water system; (2) the potential for an intake cooling water valve not to

close as intended on a loss of power or control air which was identified in

November 1984 but was not properly evaluated until February 14, 1986 at the

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Florida Power and Light Company 3

urging of the NRC; and (3) the misinstallation of component cooling water (CCW)

piping for the Unit 4 safety injection pump coolers which caused these coolers to

be dependent on the Unit 3 CCW trains. Adequate safety evaluations and

administrative controls were not established to assure that the Unit 3 CCW system

operated with sufficient redundancy when Unit 4 was operating and Unit 3 was shut

down. As a result of these failures to perform adequate evaluations and to take

adequate corrective actions in response to identified deficiencies, systems did

not satisfy their design requirements under certain conditions. These examples

indicate that although you have shown great initiative in identifying potential

safety problems, you must demonstrate the same degree of initiative in evaluating

and correcting problems once they are identified.

After consultation with the Commission, I have decided to issue the enclosed

Notice of Violation and Proposed Imposition of Civil Penalties in the amount of

Three Hundred Thousand Dollars ($300,000) for the violations described in the

enclosed Notice. The six violations have been categorized as Severity Level III

violations or problems in accordance with the NRC Enforcement Policy,10 CFR

Part 2, Appendix C (1986). The base civil penalty for each Severity Level III

violation is $50,000. Escalation of the penalty on the basis of your prior 1

poor performance was considered. However, the NRC recognizes that you have

initiated extensive actions to examine all safety systems and to identify and

correct problems at Turkey Point. Indeed, some of the violations cited in this

package were identified as a result of these actions. The NRC is encouraged by

the programs you have recently instituted and believes these measures are

necessary to improve operations at the Turkey Point facilities. Therefore, the

staff has decided not to escalate the penalty. We are concerned by the numbers

of violations identified and we consider this civil penalty enforcement action

important to emphasize the significance of these violations and to emphasize the

need for you to continue to improve your management controls in all phases of

the operation of the Turkey Point facility. Thus, no mitigation of the penalty

has been proposed.

The Phase II Assessment Program you have developed is to be implemented in

conjunction with the Turkey Point Derformance Enhancement Program. This program

will examine other safety-related systems to determine whether problems exist

in these systems that are similar to those identified in the AFW system.

Because we believe that your commitments to this program are significant and

must be fully and effectively implemented, we are issuing the enclosed Confirmatory

Order confirming your commitment to implement the extensive corrective actions to

which you have committed. The Order confirms your commitment to schedule the

actions set forth in your Phase II Assessment Program (FP&L letter L-86-112 and

L-86-197) and to submit regular progress reports to the NRC to ensure that these

actions are implemented expeditiously.

You are required to respond to the enclosed Notice ar.d you should follow the

instructions specified therein when preparing your response. Your response

should specifically address the corrective actions taken or planned with regard

to the violations described in the enclosed Notice. In your response, appropriate

reference to previous submittals is acceptable.

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Florida Power and Light Company 4

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," Part 2,

Title 10, Code of Federal Regulations, a copy of this letter and the enclosure

will be placed in the NRC's Public Document Room.

The response directed by this letter and accompanying Notice is not subject to

the clearance procedures of the Office of Management and Budget as required by

the Paperwork Reduction Act of 1980, PL 96-511.

Sincerely,

y - - /

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J es M. Taylo Director

ffice of Ins ection and Enforcement

Enclosures:

1. Confirmatory Order

2. Notice of '<iolation and Proposed

Imposition of Civil Penalties

cc w/encls.:

C. M. Wethy, Vice President

C. J. Baker, Plant Manager

L. W. Bladow, Plant

QA Superintendent

J. Arias, Jr. , Regulatory

and Compliance Supervisor

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