Insp Repts 50-250/89-45 & 50-251/89-45 On 890930-1027 .

0above 340 degrees F and stabilized levels in the YCT,, RCS pressurizer,The licensee determined that at the timePRT,, RCDT, and containment sump.the surveillances were missed, Reactor Power level and load changes wereperforming the surveillance until aThe licensee, in respons'e to thisevent, developed a modified method for calculating RCS leakage due to aplant transient (i.e., xenon, startup, etc.). As soon as possible afterthe unit is in a stabilized condition the licensee procedures requirethat a full length calculation be performed. The inspector reviewedProcedures 3-OSP-041. 1 and 4-OSP-041. 1, Reactor Coolant System Leak RateCalculation, dated June 19; 1989, and verified the licensee hadincorporated provision in the procedures to calculate RCS leakage duringplant transients. This item is closed.occurring.Theoperatorsstabilized condition5.wasdelayedreached.Nonthly Surveillance Observations(61726)observed TS required surveillance testing and verified:conformed to the requirements of the TS, testing wasperformed in accordance with adequate procedures, test instrumentation wascalibrated, limiting 'conditions for operation were met, test results metacceptance criteria requirements and were reviewed by personnel other thanthe individual directing the test, deficiencies were identified, asappropriate, and .were properly reviewed and resolved by managementpersonnel and system restoration was adequate.For completed tests, theinspectors verified testing frequencies were met and tests were performedTheThebyTheinspectorstest procedurequalified /reviewed12308.2OP1604.OP4004.21portionsof the following testPower Range Nuclear Instrumentation VerificationUpper, Lower, and Channel'Deviation AlarmsFull LengthRodCluster Controls - Periodic ExerciseSafeguard, Relay Rack, Train A,violations or deviationsEngineered Safety Featureswereofidentified in the8Periodic Testareasinspected.Walkdown (71710)to verify theResidual Heat Removal System. Thiscomplete walkdown of all accessiblewas accomplished byThe following procedures and drawings were used by theequipment.4-0SP-050.4, Residual Heat Removal System Flowpathinspectors:Verification While in Residual Heat Removal Cooldown Operation, datedJune 16, 1988; 3-OSP-202. 1, Safety Injection/Residual Heat RemovalFlowpath Verification; Drawing 5610-T-E4510, sheet 1, revision 87.Theinspectorsperformedoperability of the Unitsaninspection designed3 and 4performing a

0

efollowing criteria were used,inspection:Thelineup proceduresconfiguration.appropriate,plant drawingsduring thisbuilta.Systemsb.Housekeeping was adequateare being maintained.c.Valves in the system are correctly installed and do not exhibitsigns of gross packing leakage, bent stems, missing handwheelsor improper labeling.d.Hangers and supports are made upe.Valves in the flow paths are in correct position as required bythe applicable procedures with power available and valves werelocked/lock wiredf.easg.matchandappropriate levels'of cleanlinessproperlywasindicationfunctional.aligned correctly.wascomparedremoteandhlajor system components are properly labeled.inspectors noted the following discrepancieslicensee's management attention:TheUnitandrequired.asLocal and remote positioninstrumentationand asto theand brought these33A RHR Heat Exchanger- leaking at flange, boric acid buildup,corroding nutsValve 3-862A - leaking greaseValve 3-942P - drawing shows capped connection, no cap wasValve 3-8873B RHR pumpValve 3-938Binstalled- leaking, plastic bag wrapped around valve, no PWOto correct this leak- two flanged pipe connections off pump, not shownon drawing- vent off of seal water has a hose connection toRHR roo'm sumpValve 3-766B - drain from pump hasa hoseconnection toRHRroomsumpValve 3-761F - drawing shows capped connection, flange wasinstalled in fieldValve 3-944t - no cap installed as shown on drawingValve 3-899F - tag says normally open, drawing shows normallyclosedValve 3-759A - ladder leaning against valve, valve was baggeddueto leak,PWOwritten 1988verify position,Valve 3-771E - valve bagged, couldn'twritten1988PWO

eGeneralHousekeeping was poor, ladders and scaffolding in pumprooms, bags full of rags laying on the floor.and heat exchangerProtective clothing barrels leaning against flow transmitter3-605 (RHR flow to RCS).Unit4-RHR Pumpand Heat Exchanger RoomsRestricting Orifice 4-RO-1468 - no labelValve 4-942R - leaking, no PW0 writtenValve 4-899D - leaking, no PWO writtenValve 4-771B - drawing shows flange, flange was missingValves 4-771C/D - leaking arid bagged, no PWOs writtenValves 4-755A/8 - hose connection to RHR room sumpValve 4-944N - drawing shows this test connection on Units 3 and4, not installed on Unit 4Valve 4-766F - ball valve connected to drain line, not ondrawingValve 4-7568 - leaking, no PWOValve 4-766E - missing labelValve 4-899E - drawing shows valve on Unit 3, Unit 4 also hasthis valveandthis area, PC barrels were overflowingfloor near the barrels; scaffoldingladders laying in rooms; tools laying on the floor behindtheA RHRHousekeepingwithCommonsome(UnitsSump pumpinspectorscontainment.poor inbags3 and4)valves not labeledleakoff lines notshown on drawingalso noted two discrepanciesValve 4-RV-200 - hadclearance.onheat exchanger.Valve packinqThewasplasticahose connectioninside the Unit4to floor drain withoutatrash bag was hung on the Nitrogen bottles used for theOverpressure Mitigating System with the system inservice. Duringthese walkdowns the inspectors noted five hose connections fromdifferent valves. AP 0103.4, In-Plant Equipment ClearanceOrders, dated August 15, 1989, Section 4.4 requires thatclearance tags be installed near drain or vent hoses MaintenanceDepartment intends to install. When the clearance is released,the hoses shall be aligned or verified aligned for the requiredmode of system operation in accordance with applicable plantA

procedures.Contrary to the above, hoses were installed onvalves 3-938B, 3-7668, 4-755A, 4-755B and 4-RV-200 without anThis is a violation andequipment clearance.will be trackedas the second example of Violation 50-250,251/89-45-01.itTheresolution of the other discrepanciesFol 1 owup I tern- 50-250,251/89-45-02.willtrackedbeasInspectorhad performed walkdowns of the Unit 3 and 4 RHR pumprooms on August 25, 1989, and August 31, 1989,respectively. These walkdowns identified numerous discrepancies, some ofwhich were also identified by the inspectors.The Management walkdownsLicensee managementand heat exchangerare part of the licensee'splans to upgrade the material condition of theplant. The Unit 3 and Unit 4 RHR pump and heat exchanger rooms aretentatively scheduled for material condition upgrade completion inNovember 1989 and November 1990, respectively.This is a positiveinitiative;however,the inspectorsexpressedto licenseemanagementrelative to the timeliness of correcting some of the noteddeficiencies.The inspectors'alk'downstook place approximately onemonth after the licensee's and many of the same conditions persisted.Management indicated that the timeliness for corrective actions is stillconcernsbeing addressed.Monthly Maintenance Observations(62703)Station maintenance activities of safety related systems and componentswere observed and reviewed to ascertain that they were conducted inaccordance with approved procedures, regulatory guides, industry codes andstandards, and in conformance with TS.following i tems were considered during this review, as appropriate:were met while components or systems were removed from service;approvals were obtained prior to initiating work; activities wereaccomplished using approved procedures and were inspected as applicable;procedures used were adequate to control the activity; troubleshootingactivities were controlled and repair records accurately reflected themaintenance peiformed; functional testing and/or calibrations wereperformed prior to returning components or systems to service; gC recordsTheLCOswere maintained;activitieswere accomplishedbyqualified personnel;materials used were properly certified; radiological controlswere properly implemented; gC hold points were established and observedoutsidewhere required; fire prevention controls were implementedcontractor force activities were controlled in accordance with thepartsandapproved gA program; and housekeepinginspectors witnessed/reviewedactivities in progress:TheTroubleshooting UnitRepair of Unit44wasactively pursued.portions of the following maintenanceTurbine Stop ValvesSpent Fuel Pool CoolingPump

0ReplacementRepair ofof Unit3B SteamRepair of UnitNo8.3violations or deviations4 N-42Nuclear Instrumentation DetectorGenerator FeedPumpCondenser Tube Leakswereidentified in theareasinspected.Operational Safety Verification (71707)inspectors observed control room operations, reviewed applicable logs,discussions with control room operators, observed shiftturnovers and confirmed operability of instrumentation.The inspectorsverified the operability of selected emergency systems, verified thatmaintenance work orders had beeri submitted as required arid that followupand prioritization of work was accomplished.The inspectors reviewedtagout records, verified compliance with TS LCOs and verified the returnto service of affected components.Theconductedobservation and direct interviews, verificationphysical security plan was being implemented.ByPlant housekeeping/cleanlinessconditionsradiological controls were observed.aridwasmadethat theimplementationofof the intake structure and diesel, auxiliary, control and turbinebuildings were conducted to observe plant equipment conditions includingpotential fir e hazards, fluid leaks and excessive vibrations.Toursinspectors walked down accessiblerelated systems to verify operabilityTheportions of the following safetyvalve/switch alignment:and properEmergency Diesel GeneratorsControl Room Vertical Panels and Safeguards RacksIntake Cooling Water Structure4160 Volt Buses and 480 Volt Load and Motor Control CentersUnit 3,and 4 Feedwater PlatformsA and BUnit 3 and 4 Condensate Storage Tank AreaAuxiliary Feedwater AreaUnit 3 and 4 Main Steam PlatformsAuxiliary BuildingA.Generic Concern RegardingPressure Deviation.PressurizerSafety Valve (PSY)NS-PL-RCSL-89-396 was issued by WestinghouseeSetto address the concernof setting the pressurizer safety valves using a different media thanwhat the valve is used for. Westinghouse tested Crosby 6M safetyThe valves were set at 2485 psig using 300 degrees F water,valves.

then they were tested using steam.The setpoint was found to be 4Xto 8l lower using the steam. The concern would exist when the valvesare set to 2485 psig /- 15 using steam then installed in the systemwith a hot or cold loop seal. With the valve body temperature lowerthan when the setpoint was tested, the setpoint could drift to ahigher value. Mith the higher setpoint, the nominal 2500 psig /- 1%value used in the FSAR accident analyses might be exceeded.Areview was performed of the test and sctpoint methods used at TurkeyPoint Units 3 and 4 for these valves. It was found that the Pressurizer Safety Valves 3/4-551A, B, and C (Crosby style HB-BK, 4K 2/6)are tested and set using 3/4-CMM-041.1 and 3/4-SMM-041.1 Theseprocedures test and set the relief pressure at 2460 psig to 2510psig (2485 psig /- 1%) using a cold (ambient, 100 degrees F)water/nitrogen mixture. The testing is performed on site duringrefueling outages.Based on the cold setting of the pressurizersafety valves,is concluded that Turkey Point Units 3 and 4 donot have an operability nor a safety concern as identified inNS-PL-RCSL-89-396.By setting the valves in a low temperatureenvironment and installing them in a high temperature environment,the drift of the setpoint would be down or lower. This is theconservative direction and does not present a potential of exceedingthe FSAR Accident Analysis values.itB.Theinspectors performedareview of the following Operator Aids andTemporary Information tags to verify they were being controlled inaccordance with AP 0103.36, Control of Operator Aids and TemporaryInformation Tags, Dated March 10, 1987.Operator Aids0-89-049 -3B NormalContainment Coolerovercurrent or breakerposition contact viceNCR submitted.0-89-052 -3BChargingPumposcillations.tripanwillnot annunciatedischarge pressure and flowneeded.onlyUseifTemporary Information TagsT-89-232 - A Standby Steam Generator FeedwaterPumpoi 1Pumpoi 1sightglass incorrect.T-89-233 -BStandby Steam Generator Feedwatersightglass incorrect.T-89-242 - Unit3 Annunciator E-4/5.replaced.onto the use of aovercurrent alarm contact.dueSensing element to be

0

10T-89-244 - Unit 4 Annunciator E-4/5. Replacepressure rs performedverify theywere beinga review of the following Caution tags tocontrolled in accordance 'with AP 0103.41,Caution Tag Clearance 9-410-12-89-5NoD.Thedifferential dated December 11, 1986:3-2906, prevent changing mechanical stop position3-2907, prevent changing mechanical stop position4-2907, prevent. changing mechanical stop positionCV 4-2908, prevent changing mechanicalstop positionValve 4-50-402, throttle to control TPCW andGenerator temperatures within specifications.CVCVCVdi'screpanci es werei denti fi ed.reviewed the following equipment clearance orders towere being controlled in accordance with AP 0103.4,Equipment Clearance Orders, dated August 15, 1989:inspectorsverify theyIn-Plant3-89-10-434-89-10-233-89-10-211540, Condensate Storage Tank Make Up.2201, ICW Discharge Isolation After TPCW HeatExchanger.Valves 3-11-018,019, Instrument Air Bleed Line DrainCVCVTrap.inspectors noted a concern to operations management regardingclearance 3-89-10-21. This clearance was issued to open normally closedThese valvesvalves 3-11-018 and 019 to help reduce containment pressure.are on a drain line from the instrument air bleed line. The instrumentair bleeds are normally kept open durinq plant operation to reducecontai'nment pressure.This line connects to he containment purge exhaustline and discharges .to the plant vent. The valves opened under theclearance are located in the Unit 3 pipe and valve room in the AuxiliaryBuilding. A hose was connected to the pipe and routed to a floor drain.Therefore, the containment atmosphere was also being vented to the Unit 3pipe and valve room. This release path was being monitored since the.Auxiliary Building exhaust fans discharge to the plant vent. However, thePlantinspectors determined this practice could be an ALARA concern.high activity releases were topersonnel exposures could be increasedoccur. The licensee was reviewing this concern and the Inspectors willfollowup on their results. This item will be'tracked as Inspector FollowupItem 50-250,251/89-45-03.TheifNoviolations or deviationswereidentified in. theareasinspected.

11Plant Events (93702)following plant events were reviewed to determine facility status andfor further followup action. Plant parameters were evaluatedThe significance of the event.was evaluatedduring transient response.along with the performance of the appropriate safety systems and theactions taken by the licensee.The inspectors verified that requirednotifications were made to the NRC.'valua ions were performed relativeto the need, for additional NRC response to the event. Additionally, thefollowing issues were examined, as appropriate: Details regarding thecause of the event; event chronology; safety system performance; licenseecompliance with approved procedures; radiological consequences,any;and proposed corrective actions.The.the .needifSeptember 27, 1989 at 9:30 a.m., an individual in the OperationsSupport Group reported finding one of the two wide range containment waterOnlevel indicators (LI-4-6309A) for Unit 4 de-energized. This condition wasreported to the Plant Supervisor - Nuclear and LI-4-6309A wasre-e»ergized. At 10:50 a.m.,was noted that LI-4-6309A did not displaythe proper ERDADS response following re-energization.A Plant Work Orderwas initiated to correct this condition.Maintenance personnel observedthat the cable from LI-4-6309A to its associated receiver was damaged atOne of the two cable wires at the receiverthe receiver connection.Onconnection was found to be disconnected at the solder point.LI-4-6309Areturnedtoservice.September 28, 1989,wasSubsequent to theidentification that the A loop of wide range containment water levelindication was de-energized, a fourteen day ERDADS printout was reviewedwhich revealed that LI-4-6309A had been de-energized from at leastTechnical Specification 3.5,September 14 throuoh September 28, 1989.Table 3.5-5, Item 9, Containment Water Level (Wide Range), requires atotal of two channels and a minimum of one channel to be operable. If twochannels are not available, Action Statement 1, applies. Action Statementthe number of operable1 of TS Table 3.5-5, requires a unit shutdownaccident monitoring instrumentation channels is less than the total numberof channels shown in Table 3.5-5 for seven days. The inspectorsdetermined that. the licensee's planned and completed corrective actions toThese actions include:prevent recurrence are adequate.(1) Bump coverswill be placed on the containment penetration rooms to. prevent thereceiver's form being inadvertently, de-energized; (2) an On The Spot Changewas issued to Surveillance procedure, 0-OSP-200. 1, Schedule of PlantChecks and Surveillances, to add a periodic check that verifies thecofltainment water level indication loops are energized; (3) An investigation of other accident monitorino instrumentation as presented in Tables7.5-1 and 7.5-2 of the Final Safety Analysis Report will be performed.Those loops of indication which do not have control room indication ofbeing energized and continually indicate a zero reading during normaloperation will be identified. Corrective Actions similar to those takenin Corrective Action Number (2) will be initiated as appropriate. Thisitif

12licensee identified violation is not being cited because the criteriaspecified in Section V.G. 1 of the NRC Enforcement Policy were satisfied.This itemwillbetrackedas NCV50-250,251/89-45-04.October 6, 1989, with Unit 4 in Mode 2, the CCW system engineer foundCCW headercross-tie valve (4-835H) open. This valve was beingcontrolled by clearance 4-89-09-137 which required the valve be closed. ANuclear Operator was instructed to place the valve in the requiredposition. The CCW headers wer e split due to heavy loadover thepiping in support of the ongoing Unit 4 Spent Fuel rerack work. Thelicensee reviewed the heavy loadrecords which indicated no lifts hadoccurred with the headers not split. Therefore, the mispositioning ofthis valve did not effect CCW system operability. Discussions withoperations personnel indicated that the cause of the valve beingmispositioned was inadequate independent verification. This valve ischain operated and the operator aligning the valve, pulled the chain theThe operator performing the independent verificationwrong direction.'pulled the chain in the same direction to confirm the valve position.ADM-031, Independent Verification, dated September 21, 1989, Section 5. 1.6requires that independent verification should be accomplished by using twoOntheliftslift-for valve 'alignments.These methods included visual inspection ofpositions or post indication. Verificationcould also be performed *by use of process parameters such as flow,pressure, temperature or level indication. Contrary to the above themethodsposition indicators,,stemoperators performing independent verification did not use two methods forverifying the position of valve 4-835H. This resulted in the valve beingleft in the open position when clearance 4-89-09-137 required the valve tobe closed.,The inspectors appl'ied the criteria for Licensee IdentifiedViolations set forth in 10 CFR 2, Appendix C, Section G. 1. Theinspectors noted that the system engineer's identification of the valvemispositioning was commendable

(4 p,q RE0Ir P0 cs cs O * UNITEDSTATES NUCLEAR REGULATORYCOMMISSION REGION II 101 MARIETTASTREET, N.W. ATLANTA,GEORGIA 30323 RePort Noser 50-250/89-45 and 50-251/89-,45 Licerisee: Florida Power and Light Company 9250 West Flagler Street Miami, FL 33102 Docket Nos.: 50-250 and '50-251 License Nose