IR 05000250/2002005

IR 05000250-02-005 and IR 05000251-02-005, Inspection on 08-23-02, Turkey Point Nuclear Plant. Non-Cited Violations Noted

ML022670387
Person / Time
Site:	Turkey Point
Issue date:	09/20/2002
From:	Wert L Division of Reactor Safety II
To:	Stall J Florida Power & Light Co
References
IR-02-005
Download: ML022670387 (21)

Text

ber 20, 2002

SUBJECT:

TURKEY POINT NUCLEAR PLANT- NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 50-250/02-05 AND 50-251/02-05

Dear Mr. Stall:

On August 23, 2002, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Turkey Point Nuclear Plant. The enclosed report documents the inspection findings, which were discussed on August 23, 2002, with Ms. M. Lacal and other members of your staff.

This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities and interviews with personnel.

On the basis of the sample selected for review, the inspectors concluded that, in general, problems were properly identified, evaluated, and corrected. One green finding was identified associated with ineffective corrective actions to prevent recurrence of significant conditions adverse to quality. Previous corrective actions have not been effective in preventing recurring functional failures of charging pumps and important electrical breakers. These are risk significant components. This finding was determined to be a violation of NRC requirements.

However, because of its very low safety significance and since it has been entered into your corrective action program, the NRC is treating the finding as a noncited violation in accordance with Section VI.A.1 of the NRCs Enforcement Policy. If you deny this noncited violation, you should provide a response with the basis of your denial, within 30 days of the date of this inspection report, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Center, Washington DC 20555-0001, with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at the Turkey Point Nuclear Plant.

In addition, several examples of minor problems were identified regarding incomplete documentation of the apparent cause or associated corrective actions in condition report records. Also, the Plant Nuclear Safety Committee was not consistently conducting reviews of Technical Specification violations documented in NRC inspection reports. A number of mispositioned events documented by the licensee were assigned a significance level lower than

FP&L 2 that recommended in the program procedure. Overall, the inspectors noted that issues regarding human performance problems, including mispositioned events, were entered into the condition report system with a low threshold and were receiving high levels of management attention.

In accordance with 10 CFR 2.790 of the NRCs "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 control system (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/

Leonard D. Wert, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket Nos. 50-250, 50-251 License Nos. DPR-31, DPR-41

Enclosure:

Inspection Report 50-250/02-05, 50-251/02-05 w/Attachment - Supplemental Information

REGION II==

Docket Nos: 50-250, 50-251 License Nos: DPR-31, DPR-41 Report Nos: 50-250/02-05, 50-251/02-05 Licensee: Florida Power & Light Company (FPL)

Facility: Turkey Point Nuclear Plant, Units 3 & 4 Location: 9760 S. W. 344th Street Florida City, FL 33035 Dates: August 5 - 9 and August 19 - 23, 2002 Inspectors: T. M. Ross, Senior Resident Inspector, Saint Lucie Nuclear Plant (Lead Inspector)

J. R. Reyes, Resident Inspector, Turkey Point Nuclear Plant J. J. Lenahan, Senior Reactor Inspector, Division of Reactor Safety, Region II Approved by: L. Wert, Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS IR 05000250-02-05, IR 05000251-02-05; Florida Power and Light; on August 5-23, 2002; Turkey Point Units 3 and 4; biennial baseline inspection of the identification and resolution of problems. A violation was identified in the area of corrective action effectiveness.

The inspection was conducted by a senior resident inspector, the Turkey Point resident inspector, and a regional senior reactor inspector. One green finding of very low safety significance was identified during this inspection and was classified as a noncited violation. The finding was evaluated using the significance determination process (SDP). The significance of most findings is indicated by their 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 Oversight Process, Revision 3, dated July 2000.

Identification and Resolution of Problems Overall, the licensees corrective action program (CAP) was effective at prioritizing, evaluating and resolving conditions adverse to quality. The licensee was particularly effective at identifying problems with a low threshold and entering them into the CAP. One finding was identified involving corrective actions that were not fully effective in preventing repetitive failures of charging pumps and important electrical breakers. Several negative observations were also identified during the inspection. Some Condition Report records did not contain documentation to fully support disposition of the issues in that apparent causes or corrective actions were not adequately described. The significance level of some condition reports was not in accordance with licensee program guidance. Also, the Plant Nuclear Safety Review Committee was not consistently reviewing Technical Specification violations documented in NRC inspection reports.

Operating experience information, including NRC generic communications, was routinely reviewed for applicability in a timely manner and effectively utilized. Root cause analyses were usually comprehensive and in-depth, and apparent cause determinations were sufficiently rigorous. Overall, audits and self-assessments were sufficiently critical and thorough; licensee identified findings, weaknesses, areas of improvement, or recommendations were consistently tracked to resolution. For almost all problems, appropriate corrective actions were developed and implemented in a timely manner commensurate with the safety significance. A safety conscious work environment was evident at Turkey Point where employees felt free to raise safety concerns.

Cornerstone: Mitigating Systems Green: A noncited violation of 10 CFR 50, Appendix B, Criterion XVI was identified for ineffective corrective actions to prevent recurring charging pump and vital electrical breaker functional failures. These failures constituted repetitive significant conditions adverse to quality.

This finding was considered more than minor due to the safety significance of the affected systems and because actual loss of component safety functions occurred. The charging pump controller failures, and the failure of the 3A component cooling water pump breaker were determined to be of very low safety

significance by the significance determination process because the failures did not reduce the number of available pumps to below that required for each of the involved systems to perform their safety function. (Section 4OA2.c).

Report Details 4. OTHER ACTIVITIES (OA)

4OA2 Problem Identification and Resolution a. Effectiveness of Problem Identification (1) Inspection Scope The inspectors reviewed licensee corrective action program (CAP) activities documented since March 1, 2001, which corresponds with the completion of the last NRC team inspection (see inspection report (IR) 50-250, 251/2001-03). A complete list of the documents reviewed by the inspectors is included in the attachment to this report.

The inspectors review also included issues documented in prior NRC inspection reports and Licensee Event Reports regarding Turkey Point. Problem identification and resolution (PI&R) effectiveness since March 1, 2001, until the present, was also discussed with the resident inspectors who routinely observed PI&R activities as part of the NRC baseline inspection program.

The inspectors screened and reviewed numerous condition reports (CRs) associated with the seven cornerstones of safety to determine if problems were being properly identified and entered into the licensees CAP for evaluation and resolution. The inspectors also reviewed CRs which had been canceled to determine if the reasons for cancellation were appropriate and adequately documented.

The inspectors also reviewed numerous work orders (WO) that were written to address specific equipment problems for highly risk significant systems such as auxiliary feedwater (AFW), component cooling water (CCW), station batteries, and emergency diesel generators (EDG). In addition, the recent quarterly maintenance rule performance summary reports of Units 3 and 4 were reviewed for selected high risk significant structures, systems, and components (SSC) such as Safety Injection, 4 Kilovolt Switchgear (A, B and D buses), and the Chemical Volume and Control System (CVCS).

The inspectors reviewed the Unit 3 and Unit 4 operator logs for the months of January and February, 2002; outstanding main control room (MCR) deficiency tags, operator work around log, and the Maintenance Rule a(1) log to verify whether plant equipment problems and control room deficiencies were being identified and entered into the CAP.

The inspectors also monitored control room operations and performed MCR board walk downs on Unit 3 and Unit 4 to verify whether problems with control room equipment have been entered into the CAP.

The inspectors conducted general tours of plant areas containing equipment important to safety. The inspectors also performed more thorough walk downs of Unit 3 and 4 SSCs of high risk significance, which included the high head safety injection pumps; charging pumps; CCW pumps and heat exchangers; and AFW. These tours and walkdowns were conducted to ascertain whether the licensee had appropriately identified and entered into their CAP any existing equipment problems and deficient conditions. In addition, the inspectors interviewed various engineers, maintenance personnel, plant operators (licensed and nonlicensed), and supervisors to determine if

the corrective action system was being used to identify and properly disposition problems.

The inspectors reviewed industry operating experience, including NRC Information Notices (IN), NRC Regulatory Issue Summaries (RIS), NRC daily event reports, 10 CFR Part 21 reports, vendor reports and bulletins, and INPO documents, that were issued since March 21, 2001, to determine if they had been appropriately evaluated for applicability and whether problems identified through these reviews were entered into the licensees CAP.

The inspectors also reviewed several Quality Assurance (QA) audits, QA quality reports, and licensee self-assessments, to determine if the findings were consistent with those identified by the NRC and to verify that licensee identified findings, weaknesses, and recommendations were being entered into the CAP. The inspectors also met with the onsite Speakout (employee concerns program (ECP)) investigator and reviewed the types of issues addressed by Speakout to verify whether any conditions adverse to quality identified by the ECP process were properly included as part of the CAP. The inspectors reviewed selected Speakout resolution reports to determine if concerns were being properly reviewed and entered into the CAP, as applicable.

(2) Issues and Findings No findings of significance were identified. The inspectors determined that the licensee was very effective at identifying problems at a low threshold and entering them into the CAP. Operating experience, including NRC generic communications, was routinely reviewed for applicability in a timely manner, and if appropriate, entered into the CAP.

Audits and self-assessments were sufficiently critical and thorough. Findings, weaknesses, areas of improvement, or recommendations were consistently entered into the CAP as CRs or plant manager action items (PMAIs).

b. Prioritization and Evaluation of Issues (1) Inspection Scope The inspectors screened or reviewed approximately 145 CRs, plus associated supplements, out of nearly 3500 CRs initiated since March 1, 2001. Although numerous CRs were selected from across all cornerstones, including Emergency Planning, Safeguards, and Radiation Protection, the inspectors focused on the top five risk significant mitigating systems (i.e., CVCS, HHSI, CCW, AFW, and EDG). The licensees CAP requires all CRs to be assigned a significance level commensurate with its level of safety/risk significance in accordance with 0-ADM-518, Condition Reports.

Significance level 1 problems are the most safety significant and require a formal root cause analysis; level 2 problems require an apparent cause determination; and, level 3 problems are correction only. Condition reports were specifically selected by the inspectors from each significance level and reviewed to determine if the appropriate significance (i.e., priority) was assigned, root or apparent cause determined, and corrective actions developed to effectively resolve the identified problem. These CRs were also reviewed to assess whether they properly characterized identified problems, and adequately addressed operability, reportability, extent of condition, repeatability,

generic implications, and impact upon Maintenance Rule performance criteria.

The inspectors attended several daily Condition Report Oversight Group (CROG)

meetings, and morning management meetings, to determine the level of management attention and oversight given to issues entered into and being processed through the CAP.

(2) Issues and Findings In general, the licensees CAP was effective at prioritizing, evaluating and resolving conditions adverse to quality. Root cause analyses were usually comprehensive, thorough and detailed, and apparent cause determinations were sufficiently rigorous.

For almost all identified problems, the licensees CAP ensured timely disposition commensurate with safety and risk significance. However, the inspectors did identify two negative observations.

One negative observation was identified regarding inadequate documentation to support CR and PMAI closure. The inspectors found several CRs lacked the documentation to stand alone, when it came to describing the apparent cause and corrective actions taken to ensure adequate resolution of the identified problem. However, after further review, the licensee was able to confirm that the problems had been adequately dispositioned and provided supplemental documentation. Specific examples related to this observation are described below:

• CR 02-1094 did not contain sufficient documentation to justify continued operability of the turbine-driven AFW pumps at a higher lube oil pressure than specified by the vendor and original system design. Through interviews with the system engineer and engineering management, the inspectors determined that the licensee had also considered the past operating history of the AFW pumps and turbines as an integral part of justifying continued operability but had not documented this information. The licensee wrote a CR supplement to address this issue.

• CR 01-1404, 1404S1,1643, 1643S1, 1643S2, and 1691 described issues regarding CCW heat exchanger anodes that had separated from their mountings and clogged several tubes. Casual factors and corrective actions had not been fully documented in the CR records. The licensee wrote a supplement to condition report 01-1691 to clarify the resolution of all the CRs relating to this issue.

• CR 01-0277 was initiated when the 4B safety injection pump failed to start during a surveillance test. Operations reported that breaker 4AB12 would not close. It was concluded that this failure was a Maintenance Preventable Functional Failure on the High Head SI system and the 4KV system. The inspectors noted that this MPFF was counted towards 4 KV breakers and not the HHSI system. The available documentation did not justify this decision but interviews with the system engineer provided additional information supporting the decision. The licensee wrote a supplement to the CR to document an appropriate technical justification. In addition, the PMAI (01-03-086) closure for corrective action #1 of this CR did not document whether the system engineer had actually followed through and conducted an additional investigation to obtain information from other utilities and the vendor, and

to incorporate appropriate changes to the 4KV breakers. The licensee wrote another supplement to the CR to address this issue.

• CR 01-2255 was initiated to address a greater than expected thermal performance degradation of the 4A CCW heat exchanger due to fouling that resulted in declaring the heat exchanger inoperable and removing it from service for cleaning. It was subsequently determined that elevated canal temperatures accelerated the rate of fouling from calcium carbonate scaling. As part of the corrective actions to prevent recurrence, specific changes to the surveillance procedure were proposed.

However, the inspector found that the procedure was not revised in the manner described in the CR. Apparently, a decision had been made to revise the procedure in a different manner. The licensee wrote a supplement to the CR to address this issue.

• CR 02-0068 addressed the licensees discovery during post maintenance testing that certain critical electrical leads in the newly refurbished 4B Charging pump breaker had been inadvertently rolled by the vendor. However, the CR did not fully document the vendors investigation, cause determination, extent of condition, and corrective actions. The licensee has since reviewed the vendors actions and supplemented this CR.

A second negative observation was identified regarding the assigned significance level of several CRs. The CRs listed below were assigned a significance level inconsistent with the guidance of ADM-518.

• CR 01-2153 was initiated to address the incorrect assembly of the reactor head control rod drive mechanism cooling shroud. This CR was assigned a significance level 3 but should have been a significance level 2 according to ADM-518 recommendations because it was a nonconformance. However, the corrective actions appeared appropriate to resolve the identified deficiencies.

• CR 02-1039 was initiated to address the sheared control air tubing for the 4B charging pump. The CR was assigned a significance level 2, but because this was a considered a repetitive failure of equipment important to plant safety it should have been assigned significance level 1 in accordance with ADM-518 guidance. No root cause analysis or corrective action effectiveness review was performed. CR 02-1650 was initiated to address this issue (see noncited violation in the next section).

• Numerous CRs involving repetitive maintenance (e.g., CR 01-1278, 01-2031, 02-1107) and mispositioned events (e.g., 01-1020, 01-1133, 01-1637, 02-0617,CR 02-0727, and 02-0856) were assigned significance level 3 but should have been significance level 2 according to ADM-518 guidance. Even though the specific problems associated with the CRs were corrected, the documented actions did not sufficiently address preventing recurrence. CR 02-1651 was initiated to review the implementation of the ADM-518 guidance, particularly for mispositioned events.

c. Effectiveness of Corrective Actions (1) Inspection Scope

The inspectors reviewed numerous CRs of various significance levels to determine if the licensee had developed appropriate corrective actions consistent with the apparent/root cause. The inspectors also independently verified many of the corrective actions to confirm whether they had been implemented as described and in a manner commensurate with their safety significance. And where appropriate, the inspectors evaluated the effectiveness of the corrective actions taken to address the extent of conditions, generic implications, and to prevent recurrence.

The inspectors also specifically reviewed and verified the corrective actions taken to resolve six noncited violations issued since the last PI&R inspection.

The inspectors reviewed the 1st Quarter 2002 Turkey Point Plant Health Report, and Operations CAP rollup, used to trend and assess the licensees effectiveness in resolving significant equipment problems and human performance issues. Where applicable, the inspectors reviewed the Maintenance Rule evaluations and resultant corrective actions relating to functional failures, maintenance preventable functional failures, and the classification of SSCs into and out of a(1) status. Additionally, the inspectors interviewed responsible personnel and management directly involved with these aspects (e.g., Health Report, CAP Rollup, Maintenance Rule) of the licensees CAP.

The inspectors examined the existing backlogs of PMAI, WO, and RTS items that were generated to track CR-related corrective actions. The inspectors also verified selected PMAI, WO, and RTS items that had been closed, to verify whether corrective actions were completed as described by the CR, and in a timely manner as scheduled.

Additionally, the inspectors performed plant walk downs; reviewed applicable procedure revisions, drawing changes, training records, and other documents; and conducted interviews to verify whether corrective actions were actually implemented as described by the applicable CRs.

(2) Issues and Findings Overall, the inspectors concluded that the licensees corrective actions were appropriately developed to correct the identified problem, and were verified to be implemented in a timely manner commensurate with the safety significance of the problem. With very few exceptions, the corrective actions directly addressed the apparent/root cause, and effectively prevented recurrence for significant conditions adverse to quality. However, the inspectors identified a noncited violation involving ineffective corrective actions and a negative observation regarding the Plant Nuclear Safety Review Committee (PNSC).

The inspectors identified a Green finding related to ineffective corrective actions. This finding involved a violation of 10 CFR 50, Appendix B for ineffective corrective actions to prevent recurring charging pump and vital 4KV breaker functional failures. These components involve risk significant systems.

On July 23, 2001, the licensee initiated a Level 1 CR (01-1432) to investigate the large number of material deficiencies and functional failures associated with safety-related 4KV breakers during the past two years. As recently as February 2001, the 4B HHSI

pump and 4C Intake Cooling Water pump had failed to start due to breaker installation induced problems. A multi-disciplined team was assembled to conduct the investigation.

Although the team subsequently concluded the root cause was equipment age, the team also determined there were several contributing causes such as breaker-to-cubicle interface/fit problems, inconsistent levels of expertise by the journeymen, and inadequate periodic inspections and post-maintenance testing/exercising. The team recognized that these issues, combined with an increased number of breaker exchanges being performed as a consequence of the ongoing accelerated breaker overhaul program, could contribute to additional breaker performance problems.

However, the licensees team did not propose any additional specific corrective actions to address these contributing causes, but rather they relied upon the sufficiency of previous CR corrective actions. Even though CR 01-1432 was a Level 1 CR, it failed to develop comprehensive corrective actions to address all known causes, and did not establish an review plan to ensure corrective actions were effective. This CR was closed out September 19, 2001.

On August 6, 2002, the 3A CCW pump failed to start (i.e., breaker 3AA12 would not close). The licensees investigation (CR 02-1544) subsequently determined that the breakers positive interlock roller (PIR) was improperly set in the cubicle, thereby preventing the breaker from closing. This critical interlock between the cubicle and the breaker was not properly adjusted for the fully racked in position when the 3AA12 breaker was swapped with a refurbished breaker on August 2, 2002. The causes for the failure appear to include a lack of knowledge concerning the critical dimensions of the PIR position by the journeymen, inadequate procedures, and cubicle-to-breaker fit differences between the swapped breakers. CR 02-1544 was classified as a potential repeat condition and assigned as a significance level 1. The 3A CCW pump was considered inoperable for slightly more than four days and was determined to be reportable by the licensee pursuant to 10 CFR 50.73.

On May 12, 2002, the 4B charging pump speed control copper air tubing was discovered to be sheared completely. The licensee initiated a significance level 2 CR (02-1039) and concluded the cause was cyclic fatigue. The licensee also concluded this was a functional failure, since they were uncertain whether the charging pump would have been able to achieve the required maximum speed during accident conditions with a broken actuator supply tubing. As part of the generic implications review, the licensee recognized that there have been several other failures associated with the charging pump copper control air tubing during the past 18 months. Two of these other failures included - CR 02-0113, 3A charging pump speed control copper air tubing failure due to cyclic fatigue; and, CR 01-0388, 4A charging pump speed control copper tubing leak due to a hole caused by rubbing. Concurrent to, and preceding, these events the licensee has also experienced numerous charging pump speed controller problems (e.g., CR 02-1055,01-547, 00-1495) that have resulted in functional failures. However, despite the number of failures and their similarities the licensee did not initiate a level 1 CR (see section 4OA2.b) for the most recent 4B charging pump failure. Consequently, no root cause analysis was performed and no effectiveness review plan was established.

Corrective actions to date by the licensee have not been effective in preventing recurring charging pump and vital 4KV breaker functional failures. This issue is

considered more than minor due to the risk significance of the affected systems and the actual loss of component safety function. Both the charging pumps and vital 4KV breakers involve the reactor safety mitigating systems cornerstone and the objective of ensuring availability of mitigating system equipment was affected. Using the Significance Determination Process (SDP) this issue was determined to have very low safety significance (Green). The charging pump failures screened as Green according to Phase 1 of the SDP and the recent 3A CCW pump breaker failure was also determined to be Green according to Phase 2 of the SDP. The charging pump and CCW pump failures were of very low significance because there were three redundant pumps in both systems and the failure did not reduce the number of available pumps to below that required for the systems to accomplish their safety functions. Additionally, another pump was available in both instances for recovery of train operability.

10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires in part, that for significant conditions adverse to quality, measures shall be taken to assure the cause of the condition is determined and corrective actions implemented to preclude repetition.

The licensees failure to develop and implement effective corrective actions to prevent repetitive functional failures of the charging pumps and vital 4KV breakers is considered a violation of Criterion XVI. This violation was characterized by the SDP as having very low safety significance (i.e., Green finding) and is being treated as a noncited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy. Two CRs (02-1650 and 1652) were initiated by the licensee to address the ineffectiveness of past corrective actions regarding recurring charging pump and vital 4 KV breaker failures.

This finding is identified as NCV 50-250, 251/2002-05-01, Ineffective Corrective Actions To Prevent Recurring Charging Pump and 4KV Breaker Failures.

The inspectors determined that the PNSC was not consistently reviewing violations of Technical Specifications (TS) documented in NRC inspection reports. Although the PNSC reviewed the CRs associated with the identified violations of TS, the committee had not reviewed the TS violations once they were issued in NRC inspection reports.

Section 12 of the updated Final Safety Analysis Report indicates that the PNSC evaluates all violations of TS and recommends actions to prevent recurrence. To address this issue, the licensee initiated CR 02-1597. Examples are described below:

• CR 01-1883 was initiated to investigate whether a nonlicensed operator (NLO) had falsely completed his daily operator rounds. Subsequently, NCV 50-250, 251/02-02-01 was written for violation of TS 6.8, Procedures And Programs. This NCV was not reviewed by the PNSC. A CR supplement was issued to provide additional documentation related to generic implications.

• CR 01-0516 was initiated to address three potential TS noncompliances identified by the NRC. The CR was reviewed by the PNSC on January 30, 2001. The NRC issued NCV 50-251/00-06-01, Failure to Meet TS Time Requirement for QPTR Calculations, on April 30, 2001. The PNSC did not review the NCV. The inspectors concluded that CR 01-0516 did not address the Event Review Teams (ERT) failure to identify the multiple TS noncompliances during the post-trip review. The licensee subsequently initiated a proposed revision of the post-trip review procedure to address this oversight by the ERT and post-trip review process.

• CR 01-2081 was initiated to address an inoperable boration flow path identified by the NRC. The CR was reviewed by the PNSC on December 12, 2001. The NRC issued NCV 50-250/01-06-01, Inoperable Boration Flow Path, on January 25, 2002.

The PNSC did not review the NCV.

d. Assessment of Safety Conscious Work Environment (1) Inspection Scope The inspectors interviewed numerous plant employees, supervisors and managers to assess whether a safety conscious work environment existed at Turkey Point. The inspectors also reviewed the results of licensee QA audits, quality reports, self-assessments, Operations CAP rollup, Health Report and CRs, especially those regarding the CAP, to determine whether any issues were identified that would indicate employees might be reluctant to raise safety concerns. Furthermore, the inspectors reviewed selected issues addressed in the Speakout program which provides an alternate method than the CAP for employees to raise safety concerns and remain anonymous.

(2) Issues and Findings No findings were identified. The inspectors determined that licensee employees were familiar with the CAP and Speakout program, and were not reluctant to raise safety issues.

4OA6 Management Meetings Exit Meeting Summary The inspectors presented the detailed inspection results in a pre-exit debriefing with Mr.

J. McElwain, Site Vice President, and other members of his staff on August 22, 2002.

An exit meeting with M. Lacal, Operations Manager, and A. Zielonka, Engineering Manager was held on August 23, 2002 at the conclusion of the inspection. No proprietary information is included in this report.

Supplemental Information PARTIAL LIST OF PERSONS CONTACTED Licensee R. Earl, Corrective Action Group Supervisor M. Lacal, Operations Manager R. Leckey, Speakout Supervisor D. Lowens, Quality Assurance Manager E. Lyons, Engineering Supervisor J. McElwain, Site Vice President W. Parker, Licensing Manager K. Remmington, Maintenance Rule Program Administrator B. Stamp, Operations Supervisor

G. Warner, Acting Quality Assurance Manager A. Zielonka, Engineering Manager Other licensee employees contacted included Operations, QA, Engineering, Maintenance, Corrective Action, and Chemistry/Radiation Protection personnel.

NRC C. Patterson, Senior Resident Inspector, Turkey Point Nuclear Plant L. Wert, Chief, Reactor Projects Branch 3, Division of Reactor Projects, Region II ITEMS OPENED AND CLOSED 50-250, 251/02-05-01 NCV Ineffective Corrective Actions To Prevent Recurring Charging Pump and 4KV Breaker Failures (Section 4OA2.c)

LIST OF DOCUMENTS REVIEWED Procedures:

0-ADM-002, Nuclear Safety Speakout Program 0-ADM-005, Control Of Onsite Services 0-ADM-054, PMAI Corrective Action Tracking Program 0-ADM-102, On The Spot Changes To Procedures 0-ADM-310, Contractor And Temporary Employee Training 0-ADM-515, Operating Experience Feedback (OEF) Program 0-ADM-518, Condition Reports 0-ADM-710, Control Of Preventative Maintenance 0-ADM-728, Maintenance Rule Implementation 0-GMI-102.1, Troubleshooting and Repair Guidelines 0-GMM-102.5, Freeze Seal Application 0-PMI-025.1, Control Room HVAC Flow Switch Calibration 0-PMM-030.1, Component Cooling Water Heat Exchanger Cleaning 0-PMM-030.2, Component Cooling Water Pump Oil Change 0-PMM-075.6, Auxiliary Feedwater Pump Rotating Element Removal and Replacement 0-PMM-075.8, Auxiliary Feedwater Pump Oil Change Nuclear Policy NP-800, Nuclear Safety Speakout Program 3-ONOP-028.3, Dropped RCC 0-OP-025, Control Room Ventilation System 3-OSP-019.4, Component Cooling Water HX Performance Monitoring 4-OSP-019.4, Component Cooling Water HX Performance Monitoring 0-OSP-025.1, Control Room Emergency Ventilation System Operability Test 0-OSP-025.2, Control Room Emergency Ventilation System Filter Performance Test 4-OSP-075.2, AFW Train 2 Operability Verification 0-OSP-200.5, Miscellaneous Test, Checks, and Operating Evolutions 4-OSP-201.1, RCO Daily Logs 3-OSP-201.1, RCO Daily Logs QI 1-PTN-4, PNSC Organization and Operation QI 16-PTN-1, Corrective Action QI 16 QAD 4, Corrective Actions QI 18 QAD 13, Performance of Quality Audits Noncited Violations CR 01-0516 NCV 50-251/00-06-01, Failure to Meet Technical Specification Time Requirement for Quadrant Power Tilt Ratio Calculations CR 01-1197 NCV 50-250, 251/01-05-01, Control Room Emergency Ventilation System Inoperable Due To Mispositioned Damper Attachment

CR 01-1503 NCV 50-250/01-05-02, Both Trains of AFW Rendered Inoperable by a Single Event CR 00-2164 NCV 50-251/01-04-01, Inadequate Training Verification of Contract Personnel Working on Safety-related Motor Operated Valves CR 01-2081 NCV 50-250/01-06-01, Failure to Meet TS Requirements for Boration Injection Flow Path CR 01-1883 NCV 50-250, 251/02-02-01, Operator Rounds Inadequately Performed Plant Nuclear Safety Committee Meeting Minutes:

October 10,2000 January 30, 2001 July 30, 2001 July 31, 2001 September 04, 2001 October 09, 2001 December 12, 2001 Maintenance Rule Expert Panel Meeting Minutes:

January 25, 2001 February 15, 2002 April 04, 2002 April 17, 2002 April 19, 2002 April 30, 2002 May 2, 2002 July 23, 2002 Maintenance Rule SSC Performance Indicator Summary Reports 4.16 KV Switchgear (Unit 3 and 4) 1st and 2nd Quarter 2002 CVCS (Unit 3 and 4) 1st and 2nd Quarter 2002 Safety Injection (Unit 3 and 4) 1st Quarter 2002 EDG (Unit 3 and 4) 1st Quarter 2002 AFW (Unit 3 and 4) 1st Quarter 2002 Operating Experience CR 01-0840 NRC Information Notice (IN) 2001-02, Summary of Fitness for Duty Program Performance for Calendar Years 1998 and 1999 CR 01-2352 IN 2001-14, Problems with Incorrectly Installed Swing-Check Valves CR 02-0123 IN 2002-04, Wire Degradation at Breaker Cubicle Door Hinges CR 02-0204 IN 2002-07, Use of Sodium Hypochlorite for Cleaning Diesel Fuel Oil Supply Tanks CR 02-0840 IN 2002-12, Submerged Safety -Related Electrical Cables CR 02-0841 IN 2002-14, Ensuring A Capability to Evacuate Individuals, including Members of the Public, from the Owner-Controlled Area

CR 01-1117 NRC Regulatory Issue Summary (RIS) 2001-12, Non-conservatism in Pressurized Water Reactor Spent Fuel Pool Reactivity Equivalency Calculations CR 02-0347 NRC Generic Safety Issue (GSI) 191, Assessment of Debris Accumulation on PWR Sump Performance CR 01-0690 INPO SER 2-01, Emergency Diesel Generator Failure from Inadequate Performance Monitoring and Inadequate Response CR 02-0842 Westinghouse NSAL 02-008, Incomplete Rod Cluster Control Assembly (RCCA) Insertion in the Dashpot CR 01-2216 10 CFR 21 Report (Part 21), Switch Lock Concern for Model 288A &

289A Indicating Switches CR 01-1650 Part 21, Woodward Electronic Controllers with Electrolytic Capacitors CR 02-0615 Part 21, Model # SS84 Rotary Ball Valves - Fisher Controls Seat Leakage CR 01-0970 Part 21, Wiring Configuration of the Power Cable for the Hydrogen Recombiner CR 02-0006 Part 21, OE12679 Switch Supplied by Magnetrol Does not Conform to Westinghouse Drawing Specifications CR 02-0711 Part 21, Dresser-Rand Terry Turbine CR 02-0185 Part 21, ASCO Limit Switches Failed to Operate Correctly CR 01-1665 Surry LER 280-01-001, Emergency Diesel Generator Inoperable as a Result of Silver in Lubricating Oil CR01-2292 Industry (DOE) Issue, Rigging Failure at Brookhaven National Laboratory Condition Reports (including Supplements, as applicable):

00-1388 00-1495 00-2090 00-2091 00-2092 00-2093 00-2094 00-2164 00-2346 01-0277 01-0388 01-0415 01-0493 01-0516 01-0546 01-0547 01-0608 01-0617 01-0690 01-0783 01-0785 01-0838 01-0840 01-0856 01-0885 01-0893 01-0899 01-0951 01-0970 01-0971 01-1020 01-1029 01-1042 01-1068 01-1091 01-1098 01-1117 01-1128 01-1133 01-1158 01-1197 01-1220 01-1235 01-1236 01-1278 01-1311 01-1388 01-1404 01-1419 01-1432 01-1442 01-1444 01-1451 01-1462 01-1481 01-1503 01-1528 01-1596 01-1625 01-1634 01-1636 01-1643 01-1650 01-1665 01-1691 01-1760 01-1798 01-1883 01-1935 01-1967 01-1977 01-1995 01-1996 01-2006 01-2011 01-2024 01-2029 01-2031 01-2037 01-2075 01-2081 01-2083 01-2084 01-2101 01-2153 01-2216 01-2229 01-2248 01-2255 01-2292 01-2310 01-2323 01-2352 01-2391 01-2423 01-2441 01-2465 02-0006 02-0051 02-0068 02-0095 02-0113 02-0123 02-0185 02-0247 02-0305 02-0320 02-0335 02-0340 02-0347 02-0378 02-0390 02-0461 02-0470 02-0476 02-0496 02-0498 02-0540 02-0555 02-0566 02-0615 02-0617 02-0673 02-0711 02-0727 02-0763 02-0840 02-0841 02-0842 02-0888 02-0893 02-0899 02-0995 02-1002 02-1039 02-1053 02-1055 02-1065 02-1094 02-1107 02-1138 02-1166 02-1177 02-1487 02-1481 02-1544

Canceled Condition Reports:

01-0507 01-0598 01-0608 01-0663 01-0876 01-0902 01-0903 01-0904 01-0905 01-0906 01-0907 01-0908 01-0909 01-1050 01-1051 01-1553 01-1696 01-1713 01-1763 01-1789 01-1793 01-1816 01-1825 01-1830 Plant Work Orders:

30021568 30021705 30023029 31000250 31000578 31011751 31011753 31011755 31011758 31011760 31011762 31011763 31022039 31012925 32008499 32009675 32010298 32010298 32010572 32010849 32010957 32010958 32010976 32010977 32011548 32011549 32011550 32011551 32011643 32011816 32012563 32013846 32013847 Quality Assurance Audits, Quality Reports (QR), and Quarterly Reports QAM-PTN-00-007 Corrective Action QAO-PTN-00-010 Maintenance Functional Area Audit QAO-PTN-01-006 Site Engineering Functional Area Audit QAO-PTN-01-008 Triennial Fire Protection Audit QAO-PTN-02-001 Security Functional Area Audit QAO-PTN-02-002 Emergency Preparedness Program QR 01-0089 Contractor Training and Qualification QR 01-0119 Foreign Materials Exclusion Controls During Unit 3 Cycle 19 Outage QR 01-0127 Control of Motor Operated Valve Maintenance and Testing QR 02-0099 Self Assessment/Corrective Action Effectiveness For Mispositioned Components QA Quarterly Report First Quarter 2002 QA Quarterly Report Second Quarter 2002 Self-Assessments Maint 01-03 M&TE Program Maint 01-04 Maintenance Department Corrective Action Program Assessment Chem 01-01 Chemistry Technician Analytical and Surveillance Techniques and Procedures HP 01-01 Health Physics Eng 01-01 Engineering Design Control WC 01-01 Work Scheduling Process CAG 02-01 Corrective Action Program 1st Quarter 2002 Turkey Point Health Report CAP Rollup Operations