ML20214J869
| 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: |
| References | |
| EA-86-020, EA-86-20, NUDOCS 8608150201 | |
| Download: ML20214J869 (4) | |
See also: IR 05000250/1986011
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D. C. 20555
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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
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.
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Item II of the enclosed NOV involves the failure to satisfy the requirements of
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
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RETURN RECEIPT REQUESTED
8608150201 860612
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ADOCK 05000250
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Florida Power and Light Company
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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
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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
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entered as required by Technical Specification (TS) 3.8.5.
On January 7, 1986,
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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.
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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
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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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
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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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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,
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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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