ML20212H965

Notice of Violation from Insp on 861103-1215

ML20212H965
Person / Time
Site:	Turkey Point
Issue date:	01/16/1987
From:	Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20212H925	List: IR 05000250/1986045 ML20212H921 ML20212H965
References
50-250-86-45, 50-251-86-45, NUDOCS 8701280062
Download: ML20212H965 (4)

Text

• a ENCLOSURE 1 NOTICE OF VIOLATION Florida Power and Light Company Docket Nos. 50-250 and 50-251 Turkey Point Units 3 and 4 License Nos. DPR-31 and DPR-41 During the Nuclear Regulatory Commission (NRC) inspection conducted on November 3 - December 15, 1986, violations of NRC requirements were identified.

The violations involved the failure to establish and implement adequate proce-dures, the failure to take adequate corrective action for a condition adverse to quality, and the failure to meet valve isolation requirements for two failed containment isolation valves:

A. TS 6.8.1 requires that written procedures and administrative policies shall be established, implemented and maintained that meet or exceed the require-ments of section 5.1 and 5.3 of ANSI N18.7-1972 and Appendix A of USNRC Regulatory Guide 1.33.

1. ANSI N18.7-1972, section 5.1.5 specifies that procedures shall be provided for control of equipment, as necessary, to maintain reactor and personnel safety and to avoid unauthorized operation of equipment.

Section 5.1.2 of ANSI N18.7-1972 specifies that procedures shall be followed.

Administrative Procedure (AP) 0103.11, entitled Housekeeping, revision dated November 13, 1986, specifies in section 8.3.2.4 that scaffolding should be carefully planned and coordinated with the Plant Supervisor-Nuclear to ensure that scaffolding is not erected simultaneously over redundant pumps / components in a system in order to provide operability of at least one train of equipment under any foreseeable circumstance.

Contrary to the above, on November 13, 1986, scaffolding was observed to have been erected over both redundant trains of the Unit 4 Auxiliary Feedwater (AFW) system. The scaffolding was above the train 1 AFW flow control valves and the train 2 AFW flow orifices and their associated piping and valves. Additionally, two large boards were stored above Unit 4 train 1 AFW steam supply motor operated valve (MOV) 4-1404, creating an unnecessary seismic hazard.

2. USNRC Regulatory Guide 1.33 specifies that procedures should be developed for the operation of the AFW system. Plant drawing 5610 T-E-4062, Sheet 3, Revision 44, specifies, in note 2, that flexible hoses are to be connected between the AFW system and the Backup Service Water system during emergencies or extended periods of AFW pump recirculation operation.

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Florida Power and Light Company 2 Docket Nos. 50-250 and 50-251 Turkey Point Units 3 and 4 License Nos. DPR-31 and DPR-41 Contrary to the above, prior to November 14, 1986, no procedure existed describing the proper method by which to supply Backup Service Water to the AFW pump turbine lubricating oil coolers. Additionally, no criteria existed specifying appropriate occasions for the use of the Backup Service Water System as an emergency cooling water source for the AFW pump turbine lubricating oil coolers.

3. Section 5.1.2 of ANSI N18.7-1972 specifies that procedures shall be followed. Operating Procedure (0P) 0-0P-012, entitled Service Water Operating Procedure, revision 4, dated August 26, 1986, specifies that valves70-102 and 70-103, service water supplies to AFW pump oil coolers A and B, are required to be open. Valve AFWU-009, service water supply valve to the C AFW pump oil cooler is required to be closed.

Contrary to the above, on November 14, 1986, valves70-102, 70-103 and AFWU 009 were found not to be in their required positions.

4. USNRC Regulatory Guide 1.33, Appendix A, Item 9.a indicates that maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.

0-GMI-102.1, revision dated January 16, 1986, entitled Troubleshooting and Repair Guidelines, requires, in section 9.11, that Power Range Nuclear Instrument fuses be removed from the channel under test to allow the removal of test equipment following the calibration of Power Range Nuclear Instrumentation dropped rod circuitry.

Contrary to the above, on December 2,1986, with Unit 3 operating at 100% reactor power, during restoration of calibration of Power Range channel N-41 dropped rod circuitry and while N-41 was still removed from service, maintenance personnel inadvertently removed the instru-ment fuses for channel N-42. This resulted in operation with less than the minimum number of redundant channels operable.

This is a Severity Level IV violation (Supplement I).

B. 10 CFR 50, Appendix B, Criterion XVI, as implemented by Florida Power and Light Topical Quality Assurance Report FPLTQAR 1-76A, Revision 9, and TQR 16.0, Revision 5, entitled Corrective Action, requires, in part, that measures be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified, tracked and corrected.

JAN 161967 Florida Power and Light Company 3 Docket Nos. 50-250 and 50-251 Turkey Point Units 3 and 4 License Nos. DPR-3.1 and DPR-41 FPL Quality Assurance Manual, Quality Procedure 16.1, Revision 8, delineates requirements for assuring that conditions adverse to quality are promptly corrected.

1. Contrary to the above, after determining on October 23, 1986 that two support hangers on the Unit 4 charging line were not properly assembled, the licensee failed to take timely corrective action in that the safety significance was not evaluated until November 18, 1986.

Between October 23 and November 18, 1986 no analysis was done regarding, charging system operability or TS limiting condition for operation compliance.

2. Contrary to the above, after determining on October 27, 1986 that both the A and B Emergency Diesel Generator (EDG) starting air receivers were improperly bolted to the floor, the licensee failed to take timely.

corrective action in that the safety significance of the condition was not evaluated until November 26, 1986. Between October 23 and November 25, 1986 analyses performed relative to the seismic qualifica-tion of the air receiver floor bolts failed to provide positive indication of acceptability. Preliminary, conservative calculations performed by the site engineering staff indicated that two of the eight receivers might not withstand the safe shutdown earthquake. Between October 23 and November 25, 1986 no analysis was done regarding EDG operability or TS limiting condition for operation compliance.

This is is a Severity Level IV violation (Supplement I).

C. Technical Specification (TS) 3.3.3 requires that the containment isolation valves for Phase A containment isolation, Phase B containment isolation and containment ventilation isolation shall be operable with the isolation times of each power operated or automatic valve within the limits established for testing in accordance with Section XI of ASME Boiler and Pressure Vessel code and applicable Addenda as required by 10 CFR 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(1). Applicable in modes 1, 2, 3 and 4.

With one or more of the isolation valve (s) specified above inoperable, maintain at least one isolation valve operable in each affected penetration that is open and:

a) Restore the inoperable valve (s) to operable status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or b) Isolate each affected penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one deactivated automatic containment isolation valve secured in the isolation position, or

Florida Power and Light Company 4 Docket Nos. 50-250 and 50-251 Turkey Point Units 3 and 4 License Nos. OPR-31 and DPR-41 c) Isolate each affected penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one closed manual containment isolation valve or blind flange, or d) Be in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Contrary to the above, the licensee failed to comply with the requirements of the LCOs of TS 3.3.3 during two recent containment isolation valve failures. On September 26, 1986, and October 6, 1986, a Unit 4 steam generator blowdown isolation valve and its associated blowdown isolation bypass valve failed closed, rendering the valves inoperable. These valves are automatic Phase A containment isolation valves. During both events the on shift operators failed to isolate the affected penetration within four (4) hours, as required by TS 3.3.3.B or 3.3.3.C.

This is is a Severity Level V violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Florida Power and Light Company is hereby required to submit to this Office within 30 days of the date of the letter transmitting this Notice a written statement or explanation in reply including (for each violation): (1) admission or denial of the violation, (2) the reason for the violation if admitted, (3) the corrective steps which have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.

FOR THE NUCLEA EGUI ORY COMMISSION

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uis A. Reyes, t g Director Division of Re c r Projects Dated at Atlanta, Georgia this16 day of January, 1987 w