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UNITED STATESNUCLEAR REGULATORY COMMISSION

REGION II101 MARIETTASTREET, N.W., SUITE 2900

ATLANTA,GEORGIA 30323-0199

+a*++

Report Nos.: 50-250/94-16 and 50-251/94-16

Licensee: Florida Power and Light Company9250 West Flagler StreetHi ami, FL 33102

Docket Nos.: 50-250 and 50-251

Facility Name: Turkey Point 3 and 4

Inspection Conducted: July ll - 15, 1994

License Nos.: DPR-31 and DPR-41

Inspectors:G. Wiseman Date Signed

Accompanying Inspectors W. HillerR. Schin

Approved by:~ ).

C ~ sto, ChiefTest Programs SectionEngineering BranchDivision of Reactor Safety

D t Signed

SUMMARY

Scope:

This routine, announced inspection was conducted in the areas of designchanges and plant modifications, and engineering and technical supportactivities (IP 37550).

Results:

In the areas inspected, violations or deviations were not identified.

Plant Change/Modification Packages (PC/Hs) reviewed were technicallyadequate with sufficiently detailed 10 CFR 50.59 safety evaluations.Completed modifications were adequately implemented. Clear installationinstructions were provided for the design changes. Adequate PostModification Test (PHT) requirements were specified. System engineerswere directly involved in the review and conduct of the PHTs.

9408i90083 940809PDR ADOCK 050002508 PDR

Strong interface teamwork and communications were observed between siteand corporate engineering personnel during the in-processinterdepartmental reviews and site Plant Nuclear Safety Committee (PNSC)approval of design changes.

The licensee had adequate controls to ensure that applicable designdocuments are updated in a timely manner to reflect the as-built plant.

The Design Change (PC/M) Packages were sufficiently documented to verifyclosure including drawing and procedure revisions; and, FSAR and vendormanual updates. NRC Report 94-06 identified that computer systemequipment database (TEDB) updates had not been consistently implementedfor PC/Ms. NRC follow-up indicated that this was an isolated case whichoccurred during changeover to a new Item Equivalency Evaluation (IEE)process. The current process includes verification of TEDB inputs.

Drawing changes reviewed were clear and accurate. Overall drawingquality had improved due to conversion of additional drawings to theComputer Aided Drawing (CADD) system and extensive system configurationwalk downs by Engineering and Operations personnel.

Organization and staffing levels for Engineering have remained stableand were adequate to perform the assigned duties and responsibilities.Contractor A/E assistance in design development had been reduced.

Training certification for engineering personnel assigned to theTechnical Department (system engineers) was considered adequate.Training for onsite Engineering personnel was approximately 25%completed for the ll week plant system technical training course.

System engineers demonstrated a strong knowledge of their assignedsystems during walk-downs with the NRC inspectors.

The various engineering groups provided strong and timely support tomaintenance and operations for day-to-day activities and emergentissues.

The,licensee's predictive/preventative maintenance programs, supportedby engineering personnel, were effective in identifying and correctingpotentially degraded components.

Management initiatives were addressing the area of backlog reduction ,

for: Plant Work Orders (PWOs), Corrective Maintenance (CM) Work Orders,Procurement Engineering Issues, and Request for Engineering Assistance(REAs). The licensee was meeting their goals for reducing backlogs.

The various engineering groups were involved in the identification andresolution of problems in the support of reliable plant operation.

Engineering responses to Condition Reports (CRs) were timely withreasonably detailed and descriptive evaluations.

Quality assurance (QA) audits and performance monitoring of engineeringactivities were effective in identifying several areas for improvementin the engineering groups. Corrective actions in response to QA auditsand assessments were being addressed.

Engineering's self assessment activities were a positive indication ofmanagement's ongoing efforts to improve engineering performance.Benchmark goals established for the Production Engineering Group (PEG)"Engineering Report Card" were challenging and motivating. The"Engineering Report Card" results indicated consistent achievement ofexpected goals.

, Persons Contacted

Licensee Employees

REPORT DETAILS

C. Bible, Site Manager, Engineering*S. Brain, Project Engineer, Production Engineering Group

D. Culpepper, Chief, Engineering AssuranceB. Dunn, Lead Mechanical Engineer, Engineering

*R. Earl, Supervisor, guality AssuranceJ. Ferrare, Lead Engineer, TEDB Enhancement ProjectK. Frehafer, Licensing Engineer, Engineering

*V. Kaminskas, Services ManagerJ. Knorr, Licensing SpecialistG. Kuhn, Procurement Engineering Supervisor

*R. Kundalkar, Engineering Manager*H. Lacal, Supervisor, Plant Change Control

V. Laudato, Fire Protection Supervisor*C. Mowerey, Licensing Specialist*L. Pearce, Plant General Manager*D. Powell, Manager, Technical DepartmentJ. Reed, Supervisor, Document ControlR. Renuart, Manager, Configuration Management

*E. Thompson, Project Engineer, Engineering*E. Weinkam, Licensing Manager

Other licensee employees contacted during this inspection includedengineers, operators, technicians, and administrative personnel.

Other NRC Employees

T. Johnson, Senior Resident Inspector*B. Desai, Resident Inspector

L. Trocine, Resident Inspector

*Attended exit interview

2.

Acronyms and initialisms used throughout this report are listed in thelast paragraph.

Design Changes and Plant Modifications (37550)

a ~ Procedures Review

The inspectors reviewed selected plant procedures and qualityinstructions (01) relative to design changes and modifications todetermine the adequacy of the controls governing the design changeprocess. The following procedures were reviewed:

O-ADM-510, Requests For Engineering Assistance (REA), December 18,1993

gI 3-PTN-1, Design Control, December 29, 1993

JPN gI 2.8, Total Equipment Data Base (TEDB), Revision 3

JPN gI 3. 1, Design Control, Revision 21

JPN gI 3. 1-3, Engineering Package (EP), Revision 8

JPN gI 3. 14, Minor Engineering Package (MEP), Revision 3

JPN gI 8.3, Item Equivalency Evaluations (IEE), Revision 4

The inspectors concluded from reviewing the above documentationthat adequate controls were in place to ensure effectiveimplementation of design changes.

Review of Completed PC/Hs

The inspectors reviewed recently completed PC/Hs listed below to:(1) determine the adequacy of the safety evaluation screening andthe 10 CFR 50.59 safety evaluations; (2) verify that themodifications were reviewed and approved in accordance with TS andapplicable administrative controls; (3) verify that supportingcalculations were properly performed, documented, and approved;(4) verify the modifications were installed and had propersignoffs; (5) verify that applicable design bases were includedand affected documents (drawings, TEDB, plant procedures, etc.)were revised; (6) verify that the modifications were properlyturned over to operations; and (7) verify that both installationtesting and post modification test requirements were specified andthat adequate testing was performed. The following recentlycompleted plant modifications and related calculations wereexamined:

PC/H 93-82

EC-208, Rev.l

PC/M 93-165

PC/H 93-182

PC/H 93-184/185

Replacement of ASCO DC Relays Associatedwith the 3A/3B EDGs and the 3A/3B 4160-Volt AC Switchgear

Calculation of Minimum DC Voltages at EDGs3A and 3B Control Panels

Conversion of ICW Pumps to SelfLubrication

Replacement of Westinghouse BFD Relays inthe Unit.3 RPS

MOV Actuator Motor Replacement and Removalof Valve Actuator Hotor Brakes

Selected plant documentation associated with each PC/H wasreviewed to verify that the changes were incorporated into thelatest revision of the documents. The inspectors reviewedaffected instrument set point index drawings, vendor manuals,

TEDB, fire brigade prefire plans and procedures, fire protectionSafe Shutdown Analysis (SSA), and FSAR tables and figures, todetermine if the applicable documents had been updated toaccurately reflect the modifications.

An initial NRC review of PC/Hs 93-82 and 93-182 had beenaccomplished during the Unit 3 outage in Hay 1994 and documentedin inspection report 50-250,251/94-10. No. deficiencies were notedduring both that review or this one. The PC/Hs were technicallyadequate and had sufficiently detailed 10 CFR 50.59 safetyevaluations. Completed modifications were considered adequatelyimplemented. Clear installation instructions were provided forthe design changes. Adequate PHT requirements were specified.The PC/H packages were sufficiently documented to verify closure,including drawing and procedure revisions and FSAR and vendormanual updates. The inspectors reviewed selected drawings andTEDB items and found that they had been properly updated for thesePC/Hs. Drawings were installed on the Computer Aided DesignDrawing (CADD) system and were clear and accurate. The inspectorsalso noted that system engineers were directly involved in themodification review, implementation, and PHTs.

The inspectors performed field inspections for some of themodifications and verified that the PC/Hs were installed inaccordance with the technical requirements specified in theapplicable PC/H packages and procedures. Specifically, duringthis inspection, the inspectors observed the field installationand reviewed related work documents for PC/H 93-165, related tothe conversion of the Intake Cooling Water (ICW) Pumps to selflubrication. This modification was being installed on ICW pump4B. The inspectors found the modification installation to be wellcontrolled and documented.

Follow-up of Previously Identified Weakness

NRC Inspection Report 50-250,251/94-06, Section 2, described theresults of a recent NRC inspection of design changes and plantmodifications. That inspection identified an example of aweakness in implementation of PC/Hs, where plant drawings and theTEDB were not properly updated for PC/H 93-168 (which modifiedfeedwater heater 6A and 6B thermal relief valves). Follow-upduring this inspection found that to be an isolated case thatoccurred during a licensee changeover to a new IEE process. Theinspectors verified that the current process included verificationof TEDB 'inputs and adequate controls to ensure that designdocuments are updated in a timely manner to reflect the as-builtplant.

The licensee conducted an assessment of their document update andcloseout process in Hay 1994. The inspectors reviewed thelicensee's final report of that assessment and discussed it withlicensee engineers. The assessment focused on how well

modification-related changes were reflected in as-builtdocumentation, including drawings and the PassPort computerizedTEDB. The assessment identified some improvement recommendationsin the licensee's process. It also identified one change package,DCR-431, that had not updated the TEDB. DCR-431 updated thebreaker list and single line drawings as a result of EDG

modifications, but failed to update the TEDB., As a result, thelicensee's assessment noted 12 errors in the TEDB. To correctthis deficiency, engineering was to review the impact on TEDB forchanges made in DCR-431 by July 30, 1994. The inspector concludedthat the licensee's assessment was timely and beneficial.

Plant Nuclear Safety Committee (PNSC) Review of Proposed PC/Hs

The inspectors observed the licensee review and discussion of aproposed PC/N at a PNSC meeting:

PC/M 93-108 Instrument Air System Compressor Upgrade

The inspectors found that PNSC members asked many good questionsabout the proposed modification and its associated safetyevaluation. The committee and engineers demonstrated detailedknowledge of plant design, plant operation, and appropriate safetyconsiderations. Also, strong interface teamwork andcommunications were observed between site and corporateengineering personnel during interdepartmental reviews and sitePNSC approval of design changes.

Plant Drawing/Configuration Control

Near the end of 1992, the licensee had issued new computer-generated piping and instrumentation drawings. These CADDdrawings represented a notable improvement in quality andlegibility. During the first half of 1993, the licensee performedextensive system walkdowns by engineering and operations tofurther upgrade the accuracy of these drawings.

The licensee stated that they, converted many other drawings toCADD during 1993 and the first half of 1994, including allisometric and hangar drawings, most electrical wiring diagrams,and some instrument loop drawings. Approximately 15,000 drawingsout of approximately 40,000 total drawings have been converted toCADD. Inspector review of samples of these drawings found themclear and accurate.

The licensee plans to put CADD drawings, the FSAR, and DBDs ontheir computer wide area network system in 1995. (Engineering andlicensing (Is were put on the system in. June 1994.) With thesedesign references on the computer network, engineers (both on siteand at corporate headquarters), operators, and maintenance

personnel will be able to view controlled copies of drawings, theFSAR, DBDs, etc. on their computers and locally print copies ofselected portions of them.

The TEDB has been on the licensee's PassPort wide area networkcomputer system since 1990. The licensee recently completed aTEDB enhancement project that added about 115,000 bits ofreference information to the computerized TEDB. This projectincluded reviewing plant drawings, procedures, and vendor manualsthen adding these references to each component Identification (ID)in the TEDB (plant Operating Drawings (POD) level drawings werepreviously in the TEDB). Benefits of this database enhancementwill be improved efficiency in maintenance, engineering,procurement, and operations. Also, availability of this databasewill improve the chances of people having all applicablereferences for an equipment application. The inspectors observeda licensee demonstration of the computerized TEDB and noted that,for selected component IDs, the above references were included inthe TEDB.

Engineering and Technical Support Activities (37550)

a ~ Organization, Staffing, and Training

The inspectors reviewed the licensee's organization and staffingto determine whether the engineering organization was adequatelystaffed to provide effective engineering support to the plant.Engineering and technical support were provided by both onsite andcorporate organizations. The engineering support functionsperformed by the Technical Department and the EngineeringDepartment of the Turkey Point Nuclear Division Engineering andLicensing were examined during this inspection.

(I) Engineering Division

The inspectors reviewed guality Instruction ENG-gI 6.0,Nuclear Engineering Organization, which described theengineering organization, including a description ofreporting relationships, accountability of the departmentand functional activities.

The Turkey Point Engineering Department was under thesupervision of the Vice President Nuclear Engineering andLicensing located in the FP&L office at Juno, FL. Thisdepartment was composed of the Production Engineering (PEG),Cost/Scheduling, Site Engineering, Special ProjectsEngineering, and Procurement Engineering groups. All ofthese groups are under the supervision of an engineeringmanager who is assigned to the Turkey Point plant site. ThePEG and Cost/Scheduling groups were located in Juno and theremaining groups were located on site. Normally, theengineering manager worked four days per week on site and

one day per week in the Juno Office. Bi-weekly meetings areconducted on site for key on-site and off-site engineeringsupervisors and managers to coordinate and manage theengineering program at Turkey Point.

The Engineering Department organization includes threesupervisors, three lead engineers, 27 degreed engineers, andnine technicians on-site. At the off-site Juno office thereare two supervisors, four lead engineers, 26 degreedengineers and 11 technicians.

In recent years, a significant reduction had been made inthe use of outside contractors (A/E firms) to developmodification packages, engineering evaluations, and othersupport activities at Turkey Point. From 1991 to June 1994the percent of total engineering department manhours chargedby contractor workers has been reduced from 65,to 3.5percent. As of June 1994 FPKL engineering employeesperformed 96.5 percent of the engineering work and supportactivities at Turkey Point. The licensee informed theinspectors that the FP&L engineering staff will continue toperform practically all of the engineering supportactivities.

The PEG was responsible for the preparation of most of themajor and some of the minor plant modification/design changepackages, complex design studies and analysis, safetyevaluation reports, amendments to the TechnicalSpecifications, revisions to FSAR and design basisdocuments, and configuration updates to "As Built" drawingsand other construction and installation documents.

The Site Engineering Group was responsible for providing theday-to-day engineering support to operations and othergroups. These duties and responsibilities include thepreparation of most minor design changes, operabilityassessments, temporary system alteration evaluations,safety/engineering evaluations, review of changes toprocedures, and the revision or updating of critical flowand one-line plant operating drawings.

The Special Project Engineering Group's responsibilitiesinclude the facilitation of the interface and supportbetween maintenance and engineering, support of outageactivities, and the planning, coordinating and managing ofspecial projects and initiatives. Examples of some recentspecial projects include the thermal power

upgrade,'reventivemaintenance optimization, enhancement of thetotal equipment data base, coordination of the maintenancespecifications, development of the implementation plan forthe maintenance rule, and coordination of the service water

operational performance self assessment inspection. Detailson some of these special project initiatives are discussedin Section 3.d of this report.

The Procurement Engineering Group was formed in 1990 toprovided technical support for the control of procurementactivities. The goal of this group was to assure that thecorrect item was used in the appropriate application forplant modifications and maintenance activities and that theitem was available at the right time and at the least cost.Some of the significant achievements of this group arediscussed in Section 3.(c) of this report.

Component/System Engineers

The inspectors reviewed Procedure O-ADM-501, Duties andResponsibilities of System Engineers (4/30/92), andTechnical Department Instructions TDI-SE-005, Component andSystem Walk-downs (1/11/93), and TDI-SE-007, PostModification Testing (12/13/93). These document describethe duties and responsibilities and some of work activitiesof the system engineers.

Component and system engineering support to operations andother plant groups is provided by the Technical Group whichis under the supervision of the Technical Manager whoreports to the Plant General Manager. The Technical groupwas composed of seven sections: Reactor Engineering, SystemPerformance, Electrical and IKC Engineering, NSSSEngineering, BOP Engineering, Component Specialist, andShift Technical Advisors. A total of seven supervisors, 32degreed engineers, and 16 technicians were assigned to thisgroup. The duties and responsibilities of the system andcomponent engineers include: establishing and maintainingsystem performance standards; monitoring, trending andevaluating system performance; determining root cause ofsystem performance degradation; evaluating correctivemaintenance performed on the system; and coordinating andmonitoring system modifications and post modificationtesting on their assigned systems. Various predictivemaintenance diagnostic monitoring techniques and analysisare performed by this group. These activities are discussedin Section 3.b of this report.

The inspectors interviewed several of the system engineersto assess their knowledge of their assigned systems. Awalk-down inspection was performed of the diesel generatorsand safety injection systems with the system engineersassigned to these systems. Overall, the system engineersdemonstrated a strong knowledge of their assigned systems.

Training and gualification

The inspectors reviewed Procedure O-ADH-304, TechnicalTraining Program for Technical Staff, and the departmentaltraining program entitled Engineering Support TrainingProgram. These documents described the training program forthe engineering and technical staff at Turkey Point. Thespecified training included an Engineering Support Trainingcourse which consisted of approximately ll weeks of trainingin the areas of administrative topics, power plantfundamentals, nuclear plant primary and secondary systems,electrical systems, integrated plant operations, andsimulator training. Additional job specific training wasprovided as required. Continuing training was provided inthe areas of industry events, plant changes, plant systems,plant requested subjects and other items as needed to ensurethat all of the technical staff remained proficient in theskills and knowledge required to provide technical andengineering support to the plant.

In addition to the above training, all of the system andcomponent engineers must complete a comprehensive self studyprogram on their assigned systems and pass an oralexamination to demonstrate that have a detailed knowledge ofthe system prior to being certified on the system.

The inspectors reviewed the training records for theengineers assigned to the Technical Department and theEngineering Department and noted that a number of theengineers assigned to the Engineering Department had notreceived the Engineering Support Training. The licenseeindicated that all of the system and component engineers hadcompleted the Engineering Support Training or equivalenttraining but only approximately 25 percent of the engineersassigned to the Engineering Department had completed thiscourse. Currently, engineers assigned to the EngineeringDepartment, both on site and off site at the Juno Office,receive core training in 10CRF50.59 Safety Evaluations,configuration management, ALARA, and reliability overview.Specific discipline training, i.e. pumps and valves, stationbatteries, seismic analysis, fire protection, etc. is alsoprovided. However, the licensee's goal .is to have all ofthe engineers assigned to the Turkey Point Project meet thetraining specified by the site procedures for engineeringand technical support personnel or to have equivalentqualifications. Until this goal is met, the licenseeindicated that the Engineering Department is staffed with asufficient number of well qualified personnel to provideacceptable supervision, coordination, oversight and approvalof the engineering support provided to the site.

Based on this review, the inspectors concluded that the staffinglevels and training and qualifications of the technical staffwithin the various departments were adequate to effectivelyaccomplish the required engineering support for the plant.

Predictive Maintenance Program

Procedure O-ADM-519, Predictive Maintenance Program (1/11/94), wasreviewed by the inspectors. This procedure describes the dutiesand responsibilities for the plant staff assigned to perform thepredictive maintenance program at Turkey Point. The predictivemaintenance activities at Turkey Point include vibrationmonitoring, lube oil sampling and analysis, infrared thermographyand motor current signature analysis. These monitoring techniquesare performed by the System Engineers and Predictive MaintenanceSpecialist assigned to the Technical Department.

The inspectors reviewed TDI-TECH-007, Infrared ThermographyProgram (DRAFT), and TDI-TECH-008, Vibration Monitoring ProgramDescription (1/31/94). These instructions, although one was adraft procedure, provided a good description of the thermographyand vibration monitoring programs. The licensee indicated thatinstruction TDI-TECH-007 was to be revised to conform to currentsite format requirements by late summer 1994. The inspectorsinterviewed the Predictive Maintenance Specialist who performedmost of the infrared thermography and vibration studies and notedthat the individual had a strong knowledge of these monitoringtechniques and activities. Since the thermography analysis areperformed by a well qualified individual, the inspectorsconsidered that the temporary use of this draft instruction by thepredictive maintenance specialist was not a serious discrepancy.

The inspectors noted several incidents in which the predictivemaintenance activities identified potential equipmentdiscrepancies which were corrected prior to major equipmentdamage. Refer to paragraph 3.d for details.

Engineering Backlogs

The inspectors reviewed the status of engineering backlogs todetermine if sufficient engineering resources and managementattention had been focused on this area to prevent the buildup ofa large engineering work backlog. It was noted that the licenseehad implemented a number of effective programs which hadeliminated or reduced previous engineering backlogs. Thelicensee's actions towards reduction of engineering backlogs forthe following areas were reviewed during this inspection:

'1)

Request for Engineering Assistance (REA)

The inspectors reviewed Procedure O-ADM-510, Request forEngineering Assistance, which provided instructions for the

10

preparation, prioritizing, tracking, reviewing, andprocessing of REAs. This procedure required a cost estimateand a benefit analysis for each proposed REA to justifycompletion of the REA. The Plant Review Board reviewed REAsand only those that could be justified were approved.

To minimize the engineering involvement in repetitive minorplant maintenance problems, the licensee developed a numberof maintenance specification procedures, entitled Re-UseSpecifications. These specifications, covered a number ofitems in the civil, electrical and mechanical areasassociated with generic problems involving riggingattachments, tubing supports, lighting replacements,bolting, valves, etc. These specifications providedengineering standard details which were included withengineering documents used by the site engineering staff tominimize drafting and reduce calculation time.

The licensee's REA review and prioritization procedures inconjunction with the Re-Use Specifications has resulted in asignification reduction in the number of REAs awaitingengineering involvement. The number of open REAs had beenreduced from a total of 761 in January 1992 to 463 inJanuary 1993 and to 177 in June 1994. The current goal foropen REAs was 150. The licensee planed to meet this goal bylate 1994.

Corrective Maintenance

The number of corrective maintenance items requiringengineering evaluations or assessments was reduced from 767in December 1990 to 435 in December 1992, 331 in December1993, and 268 in June 1994. The target goal number of opencorrective maintenance items requiring engineeringassistance was reduced from 550 in December 1992 to 350 inDecember 1993. The licensee indicated the target number forthese open items was to be lowered once again since thecurrent open items are less than the existing target number.The licensee contributed this reduction to improved plantperformance and the ability of maintenance to utilize theRe-Use Specifications to resolve a large number of problemswithout need of submitting an REA.

Plant Work Orders (PWO)

In early 1993, the licensee formed a task force to determinethe reasons for the backlog of open work orders waitingengineering assistance. By use of the prioritizationprocess of procedure 0-ADM-510 and maintenance's use of theRe-Use Specifications, the backlog of open work orderswaiting for engineering resolution has been reduced from 81in 1993 to 63 in June 1994. All of the open work requests

(4)

were issued in 1993 or 1994, except for PWO 92031436. ThisPWO,involved the replacement or rechroming of the actuatorfor Containment Purge Air Return Valve POV-3-2602. Thelicensee advised the inspectors that IRC NaintenanceEngineering was investigating this item to determine if therequested action would achieve the desired results. Thelicensee's initial investigations indicated that rechromingthe actuator shaft of this valve would not improve thestroke time results. This conclusion will be evaluated andconfirmed by the licensee's valve component specialist priorto the PWO being cancelled.

Procurement Engineering

The Procurement Engineering Section was organized in 1990 toreduce the large backlog of purchase requests requiring anengineering evaluation for resolution. The licensee advisedthe inspectors that in 1990 a staff of approximately 56contractors was assigned the task of resolving procurementproblems through some form of an engineering evaluation. In1990 there was an average monthly backlog of over 1200 itemsawaiting an evaluation. A backlog of over 300 items wereclassified as obsolete.

The new Procurement Engineering Section was staffed in 1990with licensee employees who had greatly reduced the backlog.As of July 1994, a total of 8 FP&L employees were performingthe engineering evaluation task. This work force hadreduced the monthly backlog from over 1200 items toapproximately 60 items per month. The number of obsoleteitems had been reduced from over 300 items to approximately10 items per month. Yet, the average time to resolvediscrepancies had been reduced from 12 weeks toapproximately 3 weeks without the appreciable use ofovertime. During the recent refueling outage, only a totalof 20 hours of Procurement Engineering Section overtime wasrequired to support the outage activities.

This backlog reduction can be attributed to upgrades in theprocurement evaluation, commercial grade dedication, anditem equivalency evaluation procedures. However, thedevelopment of electronic means for documenting, routing,approving, storing and retrieving of technical procurementcontrol information by means of the licensee's computersystem was a positive factor in the ability to reduce thisbacklog.

Problem Identification and Resolution

The process used by the licensee to identify and track routineplant problems was the Condition Report (CR) system. Theinspectors reviewed Procedure O-ADH-518, Condition Reports

12

(7/5/94), which described the process, including guidance for theissuance of a CR, responsibilities and accountability of thevarious departments and closeout activities. Anyone in the plantcould initiate a CR. The CR subsequently went to the NuclearPlant Supervisor and Plant General Manager for determination ofimmediate reportability and plant operability. The CR is alsoassigned to the appropriate plant department for furtherevaluation and disposition. CR packages were returned to theTechnical Department to be reviewed for completeness, entered intothe CR data base and tracked to closure.

The inspectors interviewed engineering personnel and reviewedplant records to evaluate the determination, of plant operability,reportability and involvement of engineering in support of day-to-day plant operations. The inspectors reviewed the following CR

packages: .

CR No. Problem Sub'ect

93-018 Reactor Coolant System Leakage Downstreamof Unit 3 Pressurizer Spray Valve PCV-3-455A ~

93-057 Motor Control Center MCC 3E Trips onThermal Overload.

93-097

93-788

Increased Vibration and High Lube Oil IronContent Detected for Unit 3B FeedwaterPump.

Support For a Two-Inch Instrument Air Lineto the Unit 3 Hain Steam Dump Valve PulledOff Wall.

94-034 Reactor Protection System Hagan ModulesNot Reflected In Vendor Manual.

The inspectors concluded that the CR package documentationsupported the licensee's evaluation of operability andreportability with an adequate description of the condition. Inthe CR packages assigned to Engineering for evaluation andresolution, the inspectors noted that the responses were timely(closed within 25 days or less) with reasonably detailed anddescriptive evaluations.

The inspectors reviewed the CR Status Report to determine theinvolvement of Engineering in the identification of problems. Theoriginating individual, not the identifying department, wasrecorded on each CR, and, no composite record of the identifyingdepartment was maintained in the Technical Department data base.

13

However, by identifying the individual originating engineers, itwas determined that of the 1773 CRs written in 1993-1994approximately 290 (16%) were identified by engineering personnel.

The inspectors interviewed engineering personnel and foundthat'ngineersin the various plant departments were actively involved

in the support of plant operations and with the resolution ofplant problems. Some examples included:

(1) Thermal Power Uprate Project

The Engineering Department was coordinating an engineeringevaluation by an A/E organization and a NRC licensesubmittal to re-license Turkey Point Units 3 and 4 from 2200to 2300 MWT. This evaluation will require a major re-analysis of the nuclear steam supply systems and powerconversion systems. No major equipment replacements wereanticipated but several minor operational adjustments willbe required. This additional generation is being consideredas an economic benefit. The project was in the early stagesof implementation with completion proposed for 1997.

(2)

(3)

Maintenance Specifications

To help reduce engineering involvement in repetitive minorplant maintenance problems, the licensee in 1989 developed anumber of maintenance specification procedures, entitled Re-Use Specifications. These specifications continued to berevised and new specifications issued by the EngineeringDepartment as needed. Since January 1993, 15 newspecifications were issued. As of July 1994, there were atotal of 61 specifications covering a number of items in thecivil, electrical and mechanical areas associated withgeneric problems such as rigging attachments, tubingsupports, lighting replacement, bolting, valves, etc. Thesespecifications provided engineering standard details whichwere included with engineering documents and were used bythe site engineering staff to minimize drafting and reducecalculation time. These specifications were a factor in thebacklog reduction of REAs.

Maintenance Rule Implementation

The Engineering Department, with support from Maintenance,Technical and Operation Departments, had collected data anddeveloped a plan to meet the maintenance rule. Theimplementation of this plan was in progress and wasscheduled to be completed in 1996.

S

14

Emergency Diesel Generator Air Compressor

After recent repetitive air compressors failures for theEmergency Diesel Generators, an engineering evaluation wasperformed and a number of problems associated with the aircompressors were identified. These included frequenttripping of the associated circuit breakers to the aircompressor motors, overheating of the air compressors due toexcessive compressor cycling which caused embrittlement andentrapment of gasket material between piston rings andcylinder walls, and air leaks in the air start pipingsystem. The following items were performed to resolve these ,problems: adjusted air compressor motor circuit breakersettings to reduce the in-rush current; replaced pressurecontrol switch; replaced head gasket with a gasket materialwith a higher heat resistant rating; replaced air compressorhead assembly and parts with corrosion resistant material;identified and sealed starting air system piping leaks; and,replaced air compressor unloader with an unloader thatprovided consistent operation at the proper pressure rating.This work was completed during the Unit 3 refueling outagewhich ended in May 1994 and has resulted in improvedreliability, lowered compressor temperature and reduced airleakage.

Flux Happer

In early 1993, both units at Turkey Point were threatened bythe inability to obtain a valid flux map of the reactorcore. Two Event Response Teams were formed to address theproblem and arrive at a, resolution. The EngineeringDivision performed an engineering evaluation to determinethe root cause of these problems and to develop theappropriate corrective action. A number of causes wereidentified. These included high humidity in the flux mapperdrive unit enclosure and cable drive path, a design flaw,and human errors. A number of modifications andenhancements consisting of moisture reduction measures andimproved lubrication for the flux map driver and drive path,and electrical/instrumentation and maintenance enhancementsfor Unit 3 were completed during the Unit 3 refuelingoutages in Hay 1994. Some temporary modifications were madeon Unit 4 with the remaining items to be completed duringthe fall 1994 refueling outage. No flux mapping systemfailures had occurred since these corrective actions havebeen completed.

15

(6) Predictive Maintenance Activities

The System Engineers and Predictive Maintenance Specialistusing various diagnostic monitoring techniques continued toidentify discrepancies and potential problems early in theirdegradation to permit repairs before major equipment damageoccurs.

Thermography analysis examinations had identified a numberof potential problems. The following are some examples ofrecent findings. On January 28, 1994, thermal fatigue wasidentified on a fuse bus clip in 480V HCC 30774. Also, onthis date a loose connection was found on one of the threephase connections for breaker 30727 in 480V HCC 3C. OnJanuary 31, 1994, a poor connection was identified on thesouth phase east connector on,"T-Switch" 8-G-76. OnMarch 10, 1994, a small leak was identified through reliefvalve No. RV-4-203 to the Unit 4 pressurizer relief tank.Appropriate repairs were initiated after these problems wereidentified.

Likewise, the vibration monitoring programs had identified anumber of problems before major equipment damage occurred.During the Unit 3 shutdown for refueling in April 1994, theoperators noted an abnormal noise from RHR pump 3A.Vibration analysis performed on April 9, 1994 indicated thepossibility of a bad motor bearing. The motor was replacedwith a spare motor. Subsequent investigation confirmed thatthe motor bearing needed to be replaced. A routinevibration monitoring analysis performed on April 16, 1994indicated that the pump bearing for Unit 4 Primary WaterMakeup Pump 4P16B needed replacement. The pump was takenout of service and the pump bearing replaced. Subsequentbearing inspection confirmed that the bearing had requiredreplacement.

Violations or deviations were not identified in the areas inspected.

4, Quality Assurance (QA) Assessment and Oversight

The inspectors reviewed QA audits, performance monitoring evaluations,and QA Program design control audits of Turkey Point PEG and SiteEngineering's safety related activities conducted by the Nuclear QualityAssurance organization. The assessments and audits were part of theoverall QA Program at Turkey Point. The inspectors reviewed results ofthe following QA activities that were either completed or in progress:

* QAO-PTN-93-007, June 1993, Triennial Fire Protection Audit

* QAO-PTN-93-028, November 1993, Performance Monitoring Audit ofEvents Affecting Operations Resulting From Apparent Human Factors

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* gAO-PTN-94-007, Hay 1994, Audit of Fire Protection Program PlantChanges

J(S-94-200, June 1994, Performance Honitoring Audit of Protectionand Control

* gAO-PTN-94-014, July 1994, Performance Honitoring Audit of DesignChange Aspects of the Unit 3 Cycle 14 Refueling

In addition to reviewing results of the above activities, the inspectorsreviewed several Engineering response memorandums to the auditobservations and recommendations.

The inspectors found that the gA organization has been heavily involvedin independent monitoring'f Engineering activities. gA audits andperformance monitoring of engineering activities were effective inidentifying several areas for improvement in the engineering groups.Several "Technical Alerts," distributed to discuss outage-related post-modification testing problems identified during performance assessments,have been instrumental in addressing those areas that need improvement.Corrective actions in response to gA audits and assessments were beingaddressed.

Another aspect of the license's engineering self assessment effort wasthe PEG performance assessments for Turkey Point. These assessmentswere performed every six months. Nine specific engineering attributesrelated to quality, cost, and timeliness were evaluated and an"Engineering Report Card" issued for each monitored engineeringfunctional group. As performance improved, higher standards wereintroduced. The inspectors considered the benchmark goals establishedfor the PEG design "Engineering Report Card" both challenging andmotivating.

The inspectors reviewed the last report card issued for PEG. The"Engineering Report Card" results indicated consistent achievement ofexpected goals over the most recent six month period. Engineering'sself assessment activities were a positive indication of management'songoing efforts to improve engineering performance. The inspectorsconsidered the gA assessment and engineering's self assessmentactivities to be a strength.

Violations or deviations were not identified in the areas inspected.

(Open) NRC GENERIC LETTER (GL) 92-08, and GL 86-10, Supplement 1,THERHO-LAG 330-1 FIRE BARRIERS (64704)

NRC issued GL 92-08 on December 17, 1992 and GL 86-10, Supplement 1, onHarch 25, 1994. This correspondence notified licensees of failures offire endurance tests associated with Thermo-Lag fire barrier systems andrequested licensees to take appropriate corrective actions andcompensatory measures. The inspectors reviewed the licensee responseson this issue which indicated that Florida Power and Light Company

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(FPKL) will continue to maintain their identified compensatory measuresin accordance with plant procedures. The utility will also continue toreview the guidance and testing being provided through an industryprogram coordinated by the Nuclear Energy Institute (NEI) (formerlyNUHARC) to determine the appropriate actions to resolve the issue.

The inspectors observed and photographed eleven (11) Thermo-Lag cabletray, conduit, and junction box enclosure installations. One conduitinstallation in an outdoor area, Fire Zone 113, Feedwater Cage, wasobserved by the NRC inspectors to be weathered and cracked. Thelicensee immediately initiated Fire Protection Impairment No. 6245 forthe degraded Thermo-Lag condition. The inspectors considered thecompensatory actions established for Turkey Point inoperable firebarrier installations acceptable; however, the Thermo-Lag genericindustry issues remain open and will be reviewed during future NRC

inspections.

Exit Interview

The inspection scope and results were summarized on July 15, 1994 withthose persons indicated in paragraph 1. The inspectors described theareas inspected and discussed in detail the inspection findings.Proprietary information is not contained in this report. No dissentingcomments were received from the licensee.

Acronyms and Initialisms

BOP

CADD

CFRCH

CR

DBD

DC

DCR

EDG

EP

FPLLFSARGLICWI&CIEEIPJPNHCC

HEPMOV

MWT

NEINRC

NSSS

Balance of PlantComputer Aided Design DrawingCode of Federal RegulationsCorrective MaintenanceCondition ReportDesign Basis DocumentDirect CurrentDesign Change RequestEmergency Diesel GeneratorEngineering PackageFlorida Power 5 LightFinal Safety Analysis ReportGeneric LetterIntake Cooling WaterInstrumentation and ControlItem Equivalency EvaluationInspection ProcedureJuno Plant Nuclear EngineeringMotor Control CenterMinor Engineering PackageMotor Operated ValveHegaWatts ThermalNuclear Energy InstituteNuclear Regulatory CommissionNuclear Steam Supply System

NUMARC

PC/MPEG

PTNPMT

PNSCPOD

PWO

QA

QIREARHR

RPSSSATEDBTDITS

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Nuclear Management and Resources CouncilPlant Changes or ModificationsProduction Engineering GroupPlant Turkey PointPost Modification TestPlant Nuclear Safety CommitteePlant Operating DrawingPlant Work OrderQuality AssuranceQuality InstructionRequest for Engineering AssistanceResidual Heat RemovalReactor Protection SystemSafe Shutdown AnalysisTotal Equipment Data BaseTechnical Department InstructionTechnical Specifications