ML033020375

IR 05000250-03-004 & 05000251-03-004, on 06/29/03 - 09/27/03, Turkey Point Nuclear Plant, Units 3 & 4

ML033020375
Person / Time
Site:	Turkey Point   (DPR-031, DPR-041)
Issue date:	10/27/2003
From:	Joel Munday NRC/RGN-II/DRP/RPB3
To:	Stall J Florida Power & Light Co
References
IR-03-004
Download: ML033020375 (24)

See also: IR 05000250/2003004

Text

October 27, 2003

Florida Power & Light Company

ATTN: Mr. J. A. Stall

Senior Vice President of Nuclear Operations

PO Box 14000

Juno Beach, FL 33408-0420

SUBJECT:

TURKEY POINT NUCLEAR PLANT - INTEGRATED INSPECTION REPORT

05000250/2003004 AND 05000251/2003004

Dear Mr. Stall:

On September 27, 2003, the US Nuclear Regulatory Commission (NRC) completed an inspection

at your Turkey Point Units 3 and 4. The enclosed integrated inspection report documents the

inspection findings which were discussed on October 3, 2003, with Mr. T. Jones and other

members of your staff.

The inspection examined activities conducted under your license as they relate to safety and

compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed

personnel.

Based on the results of this inspection, there was one self-revealing finding of very low safety

significance (Green). The finding was determined to involve a violation of NRC requirements.

However, because of the very low safety significance and because the violation was entered into

your corrective action program, the NRC is treating this violation as non-cited violation (NCV)

consistent with Section VI.A of the NRC Enforcement Policy. Additionally, a licensee-identified

violation which was determined to be of very low safety significance is listed in Section 4OA7 of

this report. If you contest the non-cited violation in this report, you should provide a response,

within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with

copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United

States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior

Resident Inspector at the Turkey Point facility.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its

enclosure will be available electronically for public inspection in the NRC Public Document Room

or from the Publicly Available Records (PARS) component of the NRCs document system

FPL

2

(ADAMS). Adams is accessible from the NRC Web site at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Joel T. Munday, Chief

Reactor Projects Branch 3

Division of Reactor Projects

Docket Nos. 50-250, 50-251

License Nos. DPR-31, DPR-41

Enclosure: Inspection Report 05000250/2003004 and 05000251/2003004

w/Attachment: Supplemental Information

cc w/encl: (See page 3)

FP&L

3

cc w/encl:

T. O. Jones

Site Vice President

Turkey Point Nuclear Plant

Florida Power and Light Company

Electronic Mail Distribution

Walter Parker

Licensing Manager

Turkey Point Nuclear Plant

Florida Power and Light Company

Electronic Mail Distribution

Michael O. Pearce

Plant General Manager

Turkey Point Nuclear Plant

Florida Power and Light Company

Electronic Mail Distribution

Don Mothena, Manager

Nuclear Plant Support Services

Florida Power & Light Company

Electronic Mail Distribution

Rajiv S. Kundalkar

Vice President - Nuclear Engineering

Florida Power & Light Company

Electronic Mail Distribution

M. S. Ross, Attorney

Florida Power & Light Company

Electronic Mail Distribution

Linda Tudor

Document Control Supervisor

Florida Power & Light Company

Electronic Mail Distribution

Attorney General

Department of Legal Affairs

The Capitol

Tallahassee, FL 32304

William A. Passetti

Bureau of Radiation Control

Department of Health

Electronic Mail Distribution

County Manager

Metropolitan Dade County

Electronic Mail Distribution

Craig Fugate, Director

Division of Emergency Preparedness

Department of Community Affairs

Electronic Mail Distribution

Curtis Ivy

City Manager of Homestead

Electronic Mail Distribution

Distribution w/encl: (See page 4)

FP&L

4

Distribution w/encl:

E. Brown, NRR

RIDSNRRDIPMLIPB

PUBLIC

OFFICE

DRP/RII

DRP/RII

DRP/RII

DRP/RII

SIGNATURE

sn

kc (for)

kg

jh

NAME

SNinh:vyg

CPatterson

KGreenBates

JHanna

DATE

10/22/2003

10/24/2003

1024/2003

10/24/2003

E-MAIL COPY?

YES

NO YES

NO YES

NO YES

NO YES

NO YES

NO YES

NO

PUBLIC DOCUMENT

YES

NO

OFFICIAL RECORD COPY DOCUMENT NAME: C:\\ORPCheckout\\FileNET\\ML033020375.wpd

Enclosure

U.S. NUCLEAR REGULATORY COMMISSION

REGION II

Docket Nos:

50-250, 50-251

License Nos:

DPR-31, DPR-41

Report Nos:

05000250/2003004 and 05000251/2003004

Licensee:

Florida Power & Light Company

Facility:

Turkey Point Nuclear Plant, Units 3 & 4

Location:

9760 S. W. 344th Street

Florida City, FL 33035

Dates:

June 29, 2003 - September 27, 2003

Inspectors:

C. Patterson, Senior Resident Inspector

J. Hanna, Acting Senior Resident Inspector

K. Green-Bates, Resident Inspector

S. Ninh, Senior Project Engineer

Approved by:

Joel T. Munday, Chief

Reactor Projects Branch 3

Division of Reactor Projects

SUMMARY OF FINDINGS

IR 05000250/2003-004, 05000251/2003-004; 06/29/2003 - 09/27/20003; Turkey Point Nuclear

Power Plant, Unit 3 & 4; Event Followup.

The report covered a three month period of inspection by resident inspectors. One Green non-

cited violation was identified. The significance of the finding is indicated by its color (Green,

White, Yellow, Red) using IMC 0609, Significance Determination Process (SDP). Findings for

which the SDP does not apply may be Green or be assigned a severity level after NRC

management review. The NRCs program for overseeing the safe operation of commercial

nuclear power reactors is described in NUREG-1649, Reactor Overnight Process, Revision 3,

dated July 2000.

A.

Inspector Identified and Self-Revealing Findings

Cornerstone: Mitigating Systems

Green. A self-revealing finding was identified concerning a failure to comply with

10 CFR 50, Appendix B, Criterion V, Instruction, Procedures, and Drawings.

Licensee drawings and instructions used to research Clearance Zone 28-01 relay

tagouts were not sufficient to assure that the design basis Engineering Safety

Feature Actuation Signal (ESFAS) function of these components was protected.

As a result, a plant configuration was established which rendered the automatic

start of all AFW pumps on a Low-Low Steam Generator Level signal unavailable

while U3 was in Operational Mode 3.

This finding is greater than minor since it affected the Mitigating System

Cornerstone objective for Equipment Availability and had an actual safety impact

of rendering the automatic start of all AFW pumps on a Low-Low Steam

Generator Level signal unavailable while in Operational Mode 3. This finding was

reviewed using the Significance Determination Process and was determined to be

of very low safety significance because for the two applicable design basis

accidents requiring this signal, alternative methods would have started the AFW

pumps and the system would have been able to perform its safety function.

(Section 4OA3.1)

B.

Licensee Identified Violations

A violation of very low safety significance, which was identified by the licensee, has been

reviewed by the inspectors. Corrective actions taken or planned by the licensee have

been entered into the corrective action program. The violation and corrective action

tracking number are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status:

Unit 3 operated at full power during most of the inspection period. On August 15, 2003, Unit 3

reduced power to 20% due to temperature control problems associated with the cooling of the

main turbine generator exciter. The two turbine plant cooling water heat exchangers were

cleaned and the unit returned to full power on August 17, 2003.

Unit 4 operated at full power during most of the inspection period. On August 1, 2003, Unit 4

reduced power to 30% due to temperature control problems associated with cooling of the main

turbine generator exciter. The two turbine plant cooling water heat exchangers were cleaned

and the unit returned to full power on August 4, 2003. The unit started power coastdown on

September 21, 2003, in preparation for a refueling outage and was at 94% at the close of the

inspection period.

1.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity (Reactor-R),

Emergency Preparedness (EP)

1R01

Adverse Weather Protection

a.

Inspection Scope

In September, due to the proximity of Hurricane Isabel to the site, the inspectors

performed a walkdown of the site and reviewed the licensees preparations for hurricane

high winds/rain and implementation of 0-OSP-102.1 Flood Protection Stoplog Inspection;

EPIP-20106 Natural Emergencies; and 0-ONOP-103.3 Severe Weather Preparations, to

verify that those preparations limited the risk of weather related initiating events, ensured

accessibility to accident mitigation system equipment, and adequately protected accident

mitigation systems from adverse weather effects. The inspectors also reviewed the

condition of selected flood mitigation structures and components and verified that

corrective actions were taken at the appropriate thresholds within a time schedule which

met the local onset of hurricane season. Where licensee identified deficiencies were

observed, the inspectors verified that the deficiencies were properly entered into the

corrective action program and timely resolution was being pursued.

b.

Findings

No findings of significance were identified.

1R04

Equipment Alignment

a.

Inspection Scope

Partial Equipment Walkdowns

The inspectors conducted four partial alignment verifications of the safety related

systems listed below during the inspection period to review the operability of required

2

redundant trains or backup systems while the other trains were inoperable or out of

service. These inspections included reviews of plant lineup procedures, operating

procedures, and piping and instrumentation drawings which were compared with

observed equipment configurations to identify any discrepancies that could affect

operability of the redundant train or backup system. The inspectors reviewed the

following systems:

3B Intake Cooling Water (ICW) header while the 3A ICW header was out of

service for cleaning the 3A ICW/(Component Cooling Water) CCW basket

strainer

Unit 4 (Auxiliary Feedwater) AFW Train 1 while AFW Train 2 was out of service

for operability testing

Unit 4A, 3A and 3B (Emergency Diesel Generators) EDGs while the Unit 4B EDG

was declared inoperable due to testing

Unit 4 AFW Pump A Train 1 while Train 2 AFW Pumps B and C were out of

service

b.

Findings

No findings of significance were identified.

1R05

Fire Protection

a.

Inspection Scope

The inspectors toured the following eight plant areas to evaluate conditions related to

control of transient combustibles and ignition sources, the material condition and

operational status of fire protection systems, and selected fire barriers used to prevent

fire damage or fire propagation. The inspectors reviewed these activities against

provisions in the licensees Off Normal Operating Procedure, 0-ONOP-016.8, Response

to a Fire/Smoke Detection System Alarm, 0-SME-091.1, Fire and Smoke Detection

System Annual Test, 0-ADM-016, Fire Protection Plan, and 10 CFR Part 50, Appendix R.

The following areas were inspected:

Unit 4B 4160 Switchgear Room (Fire Zone 67)

Unit 4A 4160 Switchgear Room (Fire Zone 68)

Unit 4 Auxiliary Transformer Area (Fire Zone 82)

Unit 3 Auxiliary Transformer Area (Fire Zone 87)

Unit 3 and Unit 4 Auxiliary Feedwater Pump Area (Fire Zone 84)

Unit 3 and Unit 4 Pipe and Valve Room Fire Zone 35)

Unit 3 and Unit 4 Auxiliary Building Hallway (Fire Zone 58)

Unit 3 and Unit 4 AFW Pump Area (Fire Zone 84)

b.

Findings

No findings of significance were identified.

3

1R06

Flood Protection Measures

a.

Inspection Scope

The inspectors reviewed Turkey Point Final Safety Analysis Report Sections 1.6 and 1.3,

as well as the procedures and other flood mitigation documents listed below, which

depicted design flood levels and protection for areas containing risk and safety-related

equipment to determine consistency with design requirements and identify areas that

may be affected by internal flooding.

Drawing No. JPN-PTN-SECJ-90-057; Drains Subject to BackFlow Inside Flood

Protection Barrier Network

Bechtel Power Corporation No. SFB-3274; Turkey Point Units 3 & 4 Engineering

Guideline for Internal Flood Protection.

Turkey Point Units 3 & 4 Design No. 5610-000-DB-001 Sect VIII; Internal

Flooding Criteria

Turkey Point Units 3 & 4 Design No. 5610-000-DB-001 Sect IX; External Flooding

Criteria

Procedure No. EPIP-20106, Natural Emergencies

Procedure No. 0-OSP-102.1, Flood Protection Stoplog Inspection

A general site walkdown was conducted, with a specific walkdown of the risk significant

Unit 3 and Unit 4 Load Center rooms to ensure that flood protection measures were in

accordance with design specifications. Specific attributes that were checked included

structural integrity, flood platform heights for safety equipment, the sealing of the

switchgear room penetrations, and unobstructed floor drains. Equipment used for flood

mitigation, such as switchgear room sump pumps, sump system level alarms and

external drains, were reviewed for operability and/or structural integrity. Potential

flooding sources were examined to verify proper maintenance.

A review of outstanding maintenance work orders and related condition reports was

performed to verify that deficiencies did not significantly affect the Unit 3 and Unit 4 load

center room flood mitigating functions. The inspectors discussed with engineering and

maintenance management equipment issues to verify that identified problems were being

appropriately resolved in a timely fashion.

b.

Findings

No findings of significance were identified.

1R07

Heat Sink Performance

a.

Inspection Scope

The CCW system at Turkey Point is a safety-related high risk significant system. The

inspectors reviewed the Unit 3 and Unit 4 CCW heat exchanger (HX) thermal

performance testing results that were conducted in the month of July 2003, to verify that

the CCW HXs were capable of removing the basis accident heat load as required. The

inspectors also reviewed Technical Specification (TS) 3/4.7.2, Final Safety Analysis

4

Report (FSAR) Section 9, PTN-BFJI-95-003, Effect of Instrumentation Uncertainty on

Allowable ICW Temperature Calculation, Revision 1, and Calculation No.

PTN-BFJM-96-004, Revised CCW HX Operability Curves for Thermal Uprate, to ensure

that test acceptance criteria, number of plugged tubes, instrument errors, and frequency

of surveillance or testing were appropriately accounted for and included in the licensees

procedures 3/4 OSP-030,4, Component Cooling Water Heat Exchanger Performance

Test and 3/4 OSP-019.4, Component Cooling Water Heat Exchanger Performance

Monitoring.

b.

Findings

No findings of significance were identified.

1R11

Licensed Operator Requalification

a.

Inspection Scope

On July 23, 2003, the inspectors observed and assessed licensed operator actions on a

simulator scenario for a main steam isolation valve failing closed and a steam leak inside

containment that also involved the failure of critical safety equipment. The licensee used

Simulator Practice Scenario 008 Team Training, Attachments 5, 11 and 58. The

inspectors specifically evaluated the following attributes related to operating crew

performance:

Clarity and formality of communication

Ability to take timely action to safely control the unit

Prioritization, interpretation, and verification of alarms

Correct use and implementation of Emergency Operating Procedures and

Emergency Plan Implementing Procedures

Control board operation and manipulation, including high-risk operator actions

Oversight and direction provided by Operations supervision, including ability to

identify and implement appropriate TS actions, regulatory reporting requirements,

and emergency plan actions and notifications

Effectiveness of the post training critique

b.

Findings

No findings of significance were identified.

1R12

Maintenance Effectiveness

a.

Inspection Scope

The inspectors reviewed the following two equipment problems and associated Condition

Reports (CRs) to verify the licensees maintenance efforts met the requirements of 10

CFR 50.65 (Requirements for Monitoring the Effectiveness of Maintenance at Nuclear

Power Plants) and Administrative Procedure ADM-728. The inspectors efforts focused

on maintenance rule scoping, characterization of the failed components, risk significance,

determination of a(1) classification, corrective actions, and the appropriateness of

5

established performance goals and monitoring criteria. The inspectors also attended

applicable expert panel meetings, interviewed responsible engineers, and observed

some of the corrective maintenance activities. Furthermore, the inspectors verified

whether equipment problems were being identified at the appropriate level and entered

into the corrective action program.

CR 03-1525

Unit 3 Steam Jet Air Ejector Found Flooded With Water

CR 03-1560

Inverter & Battery Room Air Conditioning Unit Grounded

b.

Findings

No findings of significance were identified.

1R13

Maintenance Risk Assessments and Emergent Work Control

a.

Inspection Scope

The inspectors reviewed the following seven emergent items, as described in the

referenced CRs or work orders (WOs). The inspectors verified that the emergent work

activities were adequately planned and controlled, as described in 0-ADM-068, Work

Week Management and O-ADM-225, On Line Risk Assessment and Management. The

inspectors verified that, as appropriate, contingencies were in place to reduce risk,

minimize time spent in increased risk configurations, and avoid initiating events. The

following items were reviewed:

CR 03-1528

Gauge Calibration

CR 03-1624

Boric Acid on High Head Safety Injection

CR 03-1647

3A Load Center Undervoltage Relay Failure

CR 03-2249

Demineralized Water Storage Tank - Water on Top of

Bladder

CR 03-1563

3C CCW Inservice Test (IST) - CCW Not Receiving a Valid

Auto Start Signal

CR 03-1331

Unit-3 Backup Pressurizer Heaters Continuously Energized

CR 03-2174

AFW Lube Oil Pump Footvalve Failure

b.

Findings

No findings of significance were identified.

1R14

Personnel Performance During Non-routine Plant Evolutions and Events

a.

Inspection Scope

For the non-routine events described below, the inspectors reviewed operator logs, plant

computer data, and strip charts to determine what occurred and how the operators

responded, and to verify that the response was in accordance with plant procedures:

6

On July 14, 2003, Unit 3 3A load center under voltage relay 327H/3A2 did not

reset during the performance of surveillance test 3-OSP-006.2, U3 480 Volt

Switchgear Undervoltage Test. Unit 3 made a brief planned entry into TS 3.0.3

for the troubleshooting of the load center under voltage relay 327H/3A2. The

licensee determined that the 3A2 switch did not work properly and needed to be

replaced. The switch remained jumpered while waiting for the replacement. The

switch was repaired on September 17, 2003. (CR 03-1647 & CR 03-1648)

On July 14, 2003, during the performance of a Unit 3 3B Charging pump

Equipment Clearance Order 3-03-07-027 of the system train, steps were

performed out of sequence. (CR 03-1705, 03-1708, 03-1710, 03-2021)

b.

Findings

No findings of significance were identified.

1R15

Operability Evaluations

a.

Inspection Scope

The inspectors reviewed the following six operability determinations to ensure that TS

operability was properly supported and the system, structure or component remained

available to perform its safety function with no unrecognized increase in risk. The

inspectors reviewed the UFSAR, applicable supporting documents and procedures, and

interviewed plant personnel to assess the adequacy of the interim CR disposition.

CR 03-1441

Turbine Plant Cooling Water Isolation Valve

CR 03-1597

4A Emergency Containment Cooler

PTN-ENG-SENS-03-009

Control Room Habiltability

CR 03-1847

Failure of Control Room Damper, D-2

CR 03-0895, Sup. 1

4A EDG Fuse Clips

CR 03-2306

3A EDG Wrong Oil Added

b.

Findings

No findings of significance were identified.

1R19

Post Maintenance Testing

a.

Inspection Scope

For the following four post maintenance tests listed below, the inspectors reviewed the

test procedures and either witnessed the testing and/or reviewed test records to

determine whether the scope of testing adequately verified that the work performed was

correctly completed and demonstrated that the affected equipment was functional and

operable. The inspectors verified that the requirements of procedure 0-ADM-737, Post

Maintenance Testing, were incorporated into test requirements. The inspectors reviewed

the following list of tests:

7

WO 33002399

Fire Pump Casing Vent

4-OSP-023.1

Diesel Generator Operability Test

WO 33015160-8

B AFW Lube Oil Pump

WO 33014567-5

A AFW Lube Oil Pump

b.

Findings

No findings of significance were identified.

1R20

Refueling and Outage Activities

a.

Inspection Scope

The inspectors reviewed the outage plans and contingency plans for the Unit 4 refueling

outage, scheduled for October 6 - 26, 2003, to confirm that the licensee had

appropriately considered risk, industry experience, and previous site-specific problems in

developing and implementing a plan that assured maintenance of defense-in-depth. The

inspectors also observed portions of the planned outage activities listed below.

Outage Risk

Prior to the start of the refueling outage the inspectors reviewed the outage risk

assessment with the licensee. The outage risk status or color and plant evolutions

during the outage were reviewed. The risk assessment was planned according to plant

procedure, O-ADM-051, Outage Risk Management. The inspectors reviewed that the

outage unit risk as described in the plan was consistent with the outage work orders on

file.

Refueling Activities

The inspectors observed new fuel pool load activities in the control room and spent fuel

pool areas. Core load activities were observed and activities verified in accordance with

procedure 4-OP-038.5, Refueling Pre-Shuffle in Spent Fuel Pit.

In addition, the nuclear fuel supplier informed the licensee of an issue involving a

nonconformance associated with the top and bottom nozzles of some fuel assemblies.

The inspectors observed the licensee inspect the nozzles on the new fuel assemblies

and verified that CRs were generated as appropriate.

b.

Findings

No findings of significance were identified.

1R22

Surveillance Testing

a.

Inspection Scope

The inspectors reviewed the following five surveillance tests to verify that the tests met

the TS, the Updated Final Safety Analysis Report (UFSAR), and licensee procedure

8

requirements and demonstrated the systems were capable of performing their intended

safety functions and their operational readiness.

3-OSP-030.4, Component Cooling Water Heat Exchanger Performance Test

4-OSP-030.4, Component Cooling Water Heat Exchanger Performance Test

3-OSP- 023.2, 3A EDG 24 Hour Full Load Test and Load Rejection

3-OSP-030.1, 3C Component Cooling Water IST

4-OSP-075.2, B AFW Operability Test

b.

Findings

No findings of significance were identified.

1R23

Temporary Plant Modifications

a.

Inspection Scope

The inspectors reviewed the following two active temporary modifications to verify that

risk significant items did not adversely affect the operation of a system that was altered.

The inspectors reviewed plant procedure 0-ADM-503, Control and Use of Temporary

System Alterations (TSA), to verify that the modifications were controlled as required by

procedure. In addition, the inspectors toured plant areas and specifically looked for any

temporary modifications that might not be identified to ensure that all issues were

recognized. The following active temporary modifications were reviewed:

U4 AFW Nitrogen Backup Cage - Trip Sensitive Equipment Protection

Modification

TSA 3-03-006-022 Troubleshooting Modifications for 3A 480 Volt Undervoltage

Circuit

b.

Findings

No findings of significance were identified.

Cornerstone: Emergency Preparedness (EP)

1EP6

Drill Evaluation

a.

Inspection Scope

On August 19, 2003, the inspectors observed an operating crew in the simulator during

the 3rd quarter EP drill of the site emergency response organization. During this drill the

inspectors assessed operator actions in the control room simulator to verify whether

emergency classification, notification, and protective action recommendations were made

in accordance with implementing procedures. Additionally, the inspectors evaluated the

adequacy of the post drill critiques conducted in the simulator.

9

b.

Findings

No findings of significance were identified.

4.

OTHER ACTIVITIES

4OA1 Performance Indicator (PI) Verification

a.

Inspection Scope

The inspectors sampled licensee submittals for the two performance indicators (PIs)

listed below for the period from third quarter 2002 through second quarter 2003. To

verify the accuracy of the PI data reported during that period, PI definitions and guidance

contained in NEI 99-02, Regulatory Assessment Indicator Guideline, Rev. 2, were used

to verify the basis in reporting for each data element.

Reactor Safety Cornerstone

Safety System Unavailability - High Pressure Injection System

Safety System Unavailability - Emergency AC Power System

The inspector reviewed a selection of licensee event reports (LERs), portions of Unit 3

and Unit 4 operator log entries, daily morning reports (including the daily CR

descriptions), the monthly operating reports, and PI data sheets to verify that the licensee

had adequately identified the number of unavailable hours that occurred during the

previous four quarters. These unavailable hours were compared to the number reported

for the PI during the current quarter. In addition, the inspectors also interviewed licensee

personnel associated with the PI data collection, evaluation, and distribution.

b.

Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

a. Inspection Scope

The inspectors selected the following CRs for detailed review and discussion with the

licensee. These CRs were examined to verify whether problem identification was timely,

complete and accurate; safety concerns were properly classified and prioritized for

resolution; technical issues were evaluated and dispositioned to address operability and

reportability; root cause or apparent cause determinations were sufficiently thorough;

extent of condition, generic implications, common causes, and previous history were

adequately considered; and appropriate corrective actions (short and long-term) were

implemented or planned in a manner consistent with safety and TS compliance. The

inspectors evaluated the CRs against the requirements of the licensees corrective action

program as delineated in Administrative Procedures ADM-518, Condition Reports, ADM-

059, Root Cause Analysis, and 10 CFR 50, Appendix B.

10

CR 03-1331

U3 Pressurizer Back-up Heaters and Millstone OE

CR 03-1847

Control Room Emergency Intake Duct Flow Balancing

b.

Findings

No findings of significance were identified.

4OA3 Event Follow-up

.1

(Closed) Licensee Event Report (LER) 05000250/2003-005-00, Disabling Both Auxiliary

Feedwater Trains Inadvertently During Mode 3

Introduction: A self revealing Green NCV was identified for failure to comply with 10 CFR 50, Appendix B, Criterion V, Instruction, Procedures, and Drawings. Licensee

drawings and documents used to develop Clearance Zone 28-01 relay tagouts were not

sufficient to assure that the design basis ESFAS function of these components was

protected. As a result, a plant configuration was established which rendered the

automatic start of all AFW pumps on a Low-Low Steam Generator Level signal

unavailable while Unit 3 was in Operational Mode 3.

Description: On March 1, 2003, Unit 3 was in Operational Mode 4 (Hot Standby) during

a planned shutdown for Refueling Outage (RFO) Cycle 20. During the shutdown, when

steam generators were drained to below the 10% AFW initiation setpoint, the AFW

Steam Supply MOVs failed to open as required. The licensees analyses concluded that

the cause of the failure was the reactor protection and engineered safety features

actuation system (ESFAS) relays for both trains of AFW had been inadvertently disabled.

Equipment tagout of Clearance Zone 28-01 performed earlier in the day to isolate

equipment, had caused two breakers (3D23-08 and 3D01-40) to be opened.

Subsequent investigation into plant design basis, identified that opening these two

breakers disabled both channels of AFW automatic actuation logic and relays and

therefore impacted operation of the AFW system on a Unit 3 Low-Low Steam Generator

(SG) Level signal. The licensee did not realize that plant documents used to develop the

AFW clearance were inadequate until the valves failed to open.

Analysis: This finding is greater than minor since it affected the Mitigating System

Cornerstone objective for Equipment Availability and had an actual safety impact of

rendering the automatic start of all AFW pumps on a Low-Low Steam Generator Level

signal unavailable while in Operational Mode 3. The finding was assessed using the

Significance Determination Process for Reactor Inspection Findings, Phase 2 worksheets

for the applicable initiating event likelihood; the exposure time for this condition was less

than 3 days; and the following plant conditions and assumptions were made.

1.

For a Loss of Normal Feedwater design basis accident, annunciator response

procedure 3-ARP-097.CR and emergency operating procedure 3-EOP-E-0

instruct the operator to verify AFW pumps are started and if not, manually start

them. The inspectors found that there was ample time for the operator to perform

this action, given the fact that the unit had already been shutdown for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

11

2.

For a Loss of all Non-Emergency AC Power design basis accident, automatic

actuation of the AFW pumps would still have occurred on a bus stripping signal.

This finding was determined to be of very low safety significance (Green).

Enforcement: 10 CFR 50, Appendix B, Criterion V, Instruction, Procedures, and

Drawings, states in part that measures shall be established to assure that applicable

regulatory requirements and the design basis are correctly translated into specifications,

drawings, procedures, and instructions. Contrary to this, plant drawing 5613-M-430-

146, Sheet 12 A, Rev.4, Reactor Protection System Control Circuits Train A and

document 5610-E-855, Rev. 490, AC/DC Breaker List, did not adequately reflect the

ESFAS design function. As a result, on March 1, 2003, while in Mode 3, when these

documents were used to develop a clearance of the AFW system, the automatic start

feature of AFW on a Unit 3 Low-Low Steam Generators Level signal was defeated and

rendered all AFW pumps inoperable. Because this self revealing failure for a mitigating

system was determined to be of very low safety significance and has been entered into

the corrective action program (CR 03-0406, 03-2802) this violation is being treated as a

non-cited violation (NCV) consistent with Section VI.A of the NRC Enforcement Policy,

NUREG-1600: NCV 05000250/2003004-01, Failure to Maintain Design Documentation

to Prevent Inadvertent Loss of Both Trains of AFW Automatic Actuation Logic and

Relays. This LER is closed.

.2

(Closed) Licensee Event Report (LER) 05000251/2003-001-00: Channel Failure of the

Qualified Safety Parameter Display System

On April 10, 2003, the 4A Core Exit Thermocouple Subcooling Margin Monitor of the

Qualified Safety Parameter Display System (QSPDS) was not responding during the

power reduction. The licensee identified that some inputs to the 4A Channel of the

QSPDS had stopped responding to actual plant conditions since March 22, 2003. These

inputs were inoperable for more than 18 days which exceeded the 7 days TS Action

Statements 31 and 37 of Accident Monitoring TS 3.3.3.3 for inoperability of the 4A

In-Core Thermocouples, and the Reactor Vessel Level Monitoring System. The licensee

determined the apparent cause of the failure was a sticking input relay on one of the

thermocouple input board on Chassis number 2 of the 4A QSPDS. Corrective actions

included increased monitoring and trending of QSPDS. This finding is greater than minor

because it affected the Reactor Safety Mitigating System cornerstone objective in that

operators may rely on equipment availability and reliability to respond to initiating events

to prevent undesirable consequences during the accidents. The issue was considered

to have very low safety significance because the remaining independent and redundant

channel was operable to provide indication to operators in the control room. This event

did not involve a performance issue and was not assessed through the SDP but was

reviewed by NRC management. This licensee-identified issue involved a violation of TS 3.3.3.3 Action Statements 31 and 37. The enforcement aspects of the violation are

discussed in Section 4OA7. This LER is closed.

12

.3

(Closed) Licensee Event Report (LER) 05000250/2003-006-00: Technical Specification

Required Shutdown Due to Inoperable Containment Isolation Valve.

On April 28, 2003, with Unit 3 in Mode 1 at 100 percent power, the licensee entered TS 3.6.4, Containment Isolation Valves, Action Statement D, which required that the unit be

in at least Hot Standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Cold Shutdown within the following 30

hours. This TS was entered in order to effect repairs to an inoperable containment

isolation valve, CV-3-200B, which had excessive leakage. The licensees apparent

cause of the excessive leakage was attributed to wear on the valve stems, cages and

plugs due to a lack of a defined preventative maintenance program of the letdown

isolation valves. Corrective actions included the repair of CV-3-200A, B, C letdown

isolation valves and revision of the preventative maintenance program to improve the

reliability of these components. The inspectors noted that the licensees failure to

perform an as found leak Type C test prior to adjusting the frame cap screws on

CV-3-200B was in violation of plant procedure 0-ADM-531, Containment Leakage Rate

Testing Program and Administrative TS 6.8.4.h, the containment leakage rate testing

requirements. Also, step 5.8.7.2 of 0-ADM-531 procedure states that if as found testing

is not performed, then the component shall be tested at a frequency of at least once per

30 months. A review of the performance of the isolation valves since startup from the

previous refueling outage did not provide any evidence that containment leakage rate

limits required by TS 3.6.1.2 were exceeded prior to the unit shutdown on April 28, 2003.

Therefore, this finding constitutes a violation of minor significance that is not subject to

enforcement action in accordance with Section IV of the NRCs Enforcement Policy. The

licensee documented this violation CR 03-1014. This LER is closed.

.4

(Closed) LER 05000250/2003-008-00: Manual Reactor Trip to Repair Shutdown Bank B

Rod Control System Logic Failure

On May 20, 2003, a controlled shutdown of Unit 3 was conducted due to a failure in the

rod control system. Operator performance was previously discussed in NRC Inspection

Report 250,251/2003-03, Section 1R14. The required Technical Specification (TS) for an

inoperable shutdown control rod bank was followed and there was no violation of TS.

The failure was determined to be due to a degraded connector in a control circuit card.

Several corrective actions were taken including correcting the specific card failure and

scheduling an inspection of all the card connectors with the vendor during the next

refueling outage for both units. This LER is closed.

4OA6 Meetings, including Exit

Exit Meeting Summary

On October 3, 2003, the resident inspectors presented the inspection results to Mr. T.

Jones and other members of his staff, who acknowledged the findings. The inspectors

confirmed that proprietary information was not provided or examined during the

inspection.

13

4OA7 Licensee Identified Violations

The following violation of very low significance (Green) was identified by the licensee and

is a violation of NRC requirements which meet the criteria of Section VI of the NRC

Enforcement Policy, NUREG-1600, for disposition as a non-cited violation (NCV).

Action Statement 31 of TS 3.3.3.3, applicable to In-core Thermocouples, states that if the

number of OPERABLE channels is less than the Total Number of Channels, either

restore the inoperable channel to OPERABLE status within 7 days or 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 />. Action Statement 37 of TS 3.3.3.3, applicable to the

Reactor Vessel Level Monitoring System, states that if the number of OPERABLE

channels is one less than the total than the Total Number of Channels, either restore the

inoperable channel to OPERABLE status within 7 days or, if repairs are not feasible

without shutting down, prepare and submit a Special Report to the NRC within 30 days

following the event. On April 10, 2003, the 4A Channel of In-Core Thermocouples and

Reactor Vessel Level Monitoring System had been inoperable for more than18 days and

exceeded the 7 days TS Action Statements 31 and 37 of TS 3.3.3.3. This violation was

identified in licensees corrective action program as CR-03-0909. This finding is only of

very low safety significance because the remaining independent and redundant channel

was operable to provide indication to operators in the control room.

Attachment

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel:

M. Cornel, Training Manager

M. Chambers, AFW System Engineer

T. Jones, Site Vice-President

M. Lacal, Operations Manager

T. Miller, Maintenance Manager

M. Moore, Performance Improvement Manager

S. Wisler, Health Physics Supervisor

W. Parker, Licensing Manager

M. Pearce, Plant General Manager

W. Prevatt, Work Control Manager

G. Warriner, Quality Assurance Manager

A. Zielonka, Site Engineering Manager

NRC personnel:

K. Green-Bates, Resident Inspector

J. Hanna, Acting Senior Resident Inspector

J. Munday, Branch Chief

S. Ninh, Project Engineer

C. Patterson, Senior Resident Inspector

LIST OF ITEMS OPENED AND CLOSED

Opened and Closed

05000250/2003004-01

NCV

Failure to Maintain Design

Documentation to Prevent

Inadvertent Loss of Both Trains of

AFW Automatic Actuation Logic and

Relays(Section 4OA3.1)

Closed

05000250/2003-005-00

LER

Disabling Both Auxiliary Feedwater

Trains Inadvertently During Mode 3

(Section 4OA3.1)

2

05000251/2003-001-00

LER

Channel Failure of the Qualified

Safety Parameter Display System

(Section 4OA3.2)

05000250/2003-006-00

LER

Technical Specifications Required

Shutdown Due to Inoperable

Containment Isolation Valve (Section

4OA3.3)

05000250/2003-008-00

LER

Manual Reactor Trip to Repair

Shutdown Bank B Rod Control

System Logic Failure (Section

4OA3.4)