L-84-330, Responds to Violations Noted in Insp Repts 50-250/84-23 & 50-251/84-24.Corrective Actions:Procedures Re Design Changes,Pump Surveillance & Emergency Diesel Generator Surveillance Testing Revised.Personnel Being Retrained

Responds to Violations Noted in Insp Repts 50-250/84-23 & 50-251/84-24.Corrective Actions:Procedures Re Design Changes,Pump Surveillance & Emergency Diesel Generator Surveillance Testing Revised.Personnel Being Retrained

ML20133E305
Person / Time
Site:	Turkey Point
Issue date:	11/21/1984
From:	Williams J FLORIDA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
L-84-330, NUDOCS 8507220471
Download: ML20133E305 (8)

Text

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, FLOHIDA POWER & LIGHT COMPANY 2*Jg f!avenber 21, 1984 L-84-330 Mr. James P. O'Reilly Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101 Marietta Street, N.W., Suite 2900 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Inspection Report 250-84-23 and 251-84-24 Florida Power and Light Company has reviewed the subject inspection report and a response is attached.

The concern discussed in the report cover letter regarding classification of design changes is listed as an additional finding, and a response is provided.

There is no proprietary information in the report.

Ver truly yours, M

J. W. Williams, Jr.

Group Vice President Nuclear Energy Department JWW/JA/PLP/js cc: Harold F. Reis, Esquire PNS-LI-84-411-4 8507220471 841121 PDR ADOCK 05000250 G PDR a mVI PEOPLE, .SEH G PEOPLC L

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. ATTAC MENT Re: Turkey Point Units 3 and 4 Docket No. 50-250, 50-251 IE Inspection Report 250-84-23 and 251-84-24 FINDING 1:

The Facility Operating Licenses, DPR-31 and DPR-41,Section III, state that the license is subject to 10 CFR 50.59. 10 CFR 50.59(1) requires that evalua-tions be conducted to determine if an unreviewed safety question exists prior to a facility change or procedure change being accomplished for any system as described in the FSAR and prior to the conduct of tests described in the FSAR. 10 CFR 50.59(2) requi res that the evaluation be made against evaluations previously done in the safety analysis report.

Contrary to the above, the licensee did not require that evaluations be conducted in accordance with the provisions of 10 CFR 50.59 in that the Administrative Procedures (AP) 0190.15, 0109.1, and 0103.3 covering, respectively, Design Changes, Procedures Changes and Temporary System Alterations did not require that the evaluations be done against the entire safety analysis report but only against the Chapter 14 Accident Analysis.

RESPONSE

1) FPL concurs with the finding.

2) The reason for the finding was that the referenced procedures only referred to FSAR Chapter 14, Accident Analysis, for safety evaluations.

This was a misconception on Tu rkey Point Plant's part in that safety evaluations should require a review of the entire FSAR.

3) The following corrective steps have been taken:

a) Administrative Procedure (AP) 0103.3, " Control and Use of Temporary System Alterations", AP 0109.1, " Preparation, Revision, and Approval of Procedures", AP 0190.15, " Plant Projects -

Approval, Implementation, and Regulatory Requirements", and AP 0190.22,

" Changes, Tests and Experiments", have been reviewed and revised to reflect the fact that the safety evaluations shall be made against evaluations previously done in the FSAR and not just the accident analysis chapter.

b)

Our engineering dep(artment and Modifications has been by PC/Ms) originated requested the planttoand review the Plant Changes contractor used for developing modifications in compliance with IE Bulletin 79-14

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to ensure that the safety evaluations that were performed for these PC/Ms were based on evaluations previously done in the FSAR and not just the accident analysis chapter of the FSAR.

c) A further investigation revealed that PC/Ms originated by our Engineering Department in fact include safety evaluations which are based on evaluations previously done in the FSAR.

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4 Re *IE' Inspection Report 250-84-23 and 251-84-24

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4) No further corrective actions are deemed necessary.

5) Full compliance for Item 3.a was achieved on August 2,1984 Full compliance for Item 3.b will be achieved by December 31, 1985.

FIlWING 2:

Technical Specification (TS) 4.5.2.a requires that the Residual Heat Removal (RHR) and High Head Safety Injection (HHSI) pumps be started monthly, that they start and reach the required head, and that the instruments and visual observations indicate proper functioning during the test.

Contrary to the above, the pump surveillance tests, OP 4004.1 and OP 4104.1, did not verify by the instruments and visual observations that the pumps were properly functioning, in that, neither procedure verified that the seals, seal water system, or component cooling water system met design function during the test. Therefore, on August 1-2, 1984, the tests on RHR pumps on both units conducted per OP 4004.1 and the tests on the HHSI pumps conducted per OP 4104.1 during July 1984, were inadequate.

RESPONSE

1) FPL concurs with the finding.

. 2) The subject pump tests were conducted using approved plant procedures.

These procedures, however, only included the parameters required by the PTP ASME Section XI Inservice Testing Program.

3) Operating Procedure (0P) 4004.1, " Containment Spray Pumps -

Periodi c Test", and Operating Procedure .(0P) 4104.1, "High Head Safety Injection System - Periodic Test", have been revised to include verification that the seals and seal water system meet design function during the test and the tests are now being conducted in accordance with the revised procedures. The component cooling water system to RHR and HHSI pumps is continuously monitored by audible and visual alarms in the Control Room.

Malfunctions or deviations from required conditions are controlled by 0P 0208.10, " Annunciator List - Panel H - Safety Injection and Auxiliary".

4) FPL has implemented a Program for Improved Operation that was described in our letter L-84-265 dated September 28, 1984 Part of this program will include a review of the FSAR and Technical Specifications to ensure that systems, components, and instruments that require testing for operability have adequate test and acceptance criteria.

5) Full compliance was achieved on September 7, 1984

s Rei IE I"spection Report 250-84-23 and 251-84-24 P, age 3-t FI MING 3:

The Facility Operating Licenses, DPR-31 and DPR-41,Section III.D, require that the licensee snall originate facility operating records in accordance with the Technical Specifications (TS ) . Technical Specification 6.10.1.d requires that records of surveillance activities required by the TS be kept for five years. 10 CFR 50, Appendix B, Criterion XVII requires that records affecting quality shall include the results of tests and that test records shall identify the data recorder, the reviewer, the acceptability and the action taken in connection with any deficiencies. The FP&L Quality Assurance Topical Section 17.2.1, Revision 0, and Quality Procedure 17.1, Revision 11 implements these 10 CFR 50, Appendix B requirements.

Contrary to the above, the data originated as a facility operating record of the required TS surveillance test performed on July 26, 1984, on the "A" Emergency Diesel per OP 4304.1 did not have the information required to qualify it as a record as required by the above, in that, the Data and Record Sheets did not require the identity of the data recorder nor the acceptability and the action taken in connection with any deficiency.

RESPONSE

1) FPL concurs with the finding.

2) The reason for the finding was that the procedure did not adequately address the criteria necessary for Quality Assurance requirements.

3) Operating Procedure (0P) 4304.1, " Emergency Diesel Generator - Periodic Test Load on 4 KV Bus", has been reviewed against Quality Assurance record retention requirements and has been revised to identify the data recorder, to define acceptance criteria and identify the steps for correcting any deficiencies detected while conducting the test.

4) a) The Quality Assurance Department is conducting a comprehensive review of records to determine record retention requirements as part of our Program for Improved Oper . tion as described in our letter L-84-265 dated September 28, 1984.

b) Our Procedure Upgrade Group is reviewing every procedure they develop for compliance with Quality Assurance record requirements.

5) Full compliance was achieved on August 22, 1984 FINDING 4:

Technical Specification 6.8.1 requires that written procedures and administra-tive policies shall be established, implemented, and maintained.

FI E ING 4.a:

Administrative Procedure 0103.17 establishes the procedure for systems or  !

equipment acceptance and turnover to the plant staff. It charges the startup l test group with the responsibility for the walkdown of the system to identify discrepancies and to have the operating drawings updated.

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Re: lY Inspection Report 250-84-23 r nd 251-84-24

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. . l Contrary to the above, AP 0103.17 was not implemented in January through May 1984 during the turnover of the Pressurizer Heater Circuit Modification, PC/M 81-29 and 81-30, in that, the discrepancy of the bypass switches not being labeled was not identified and the operating drawing change to incorporate PC/M 81-30 was not accomplished.

RESPONSE

1) a) , FPL concurs with part of the finding. FPL concurs that the operating drawing change to incorporate PC/M 81-30 was not fully accomplished.

b) FPL denies the discrepancy of the Pressurizer Heater bypass switches not being labeled.

2) a) The reason for the finding was personnel oversight in that drawing 5610-T-L1, Sheet 23, Revision 8, that was issued to incorporate PC/M 81-30 for Unit 4, did not delete the notation that the Pressurizer Keylock Switch only applied to Unit 3.

b) FPL denies part of the finding because discussions with Start-up personnel confirmed that the walkdown of PC/M 81-30 had been performed

• on May 23, 1984, and the label was found on the switch at that time.

The label described the PC/M required (Normal - Emergency) settings and it was installed as such.

In response to the NRC Inspector's concerns regarding the information contained on the labels, as an interim solution, temporary labels were installed on the switches to indicate their function, while ordering permanent labels to be installed upon receipt.

3) The Drawing Update Group revised drawing 5610-T-L1, Sheet 23, to delete the note that referred to Unit 3 only, thus including Unit 4

4) This event will be discussed with Drawing Update personnel at Turkey Point to reemphasize the requirements for updating drawings adequately upon completion of PC/Ms and the significance of complying with this requirements.

5) Full compliance was achieved on July 27, 1984 FINDING 4.b:

Administrative Procedure 0190.9 establishes the procedure for the control of measuring and test equipment. It requires that equipment be calibrated on a routine schedule, identifieu with proper calibration data affixed, and segregated and not used if out of service.

. Contrary to the above, several examples of equipment with incorrect or no calibration stickers were identified. Several Ashcroft gauges had no current calibration data available in addition, they were not segregated from calibrated equipment. One Ametek pump was used outside of its calibrated period of acceptability.

RedEIspectionReport 250-84-23 and 251-84-24

• Pag) 5

RESPONSE

1) a) FPL concurs that several Ashcroft gauges had no current calibration data and were not segregated from calibrated equipment.

b) FPL denies that an Ametek pump was used outside of its calibration period.

2) a) The reason for the finding was that the Ashcroft gauges were new, had no tag numbers attached yet and still had clamps attached to their pointers. These gauges were never intended to be used for calibration purposes, b) FPL denies part of the finding because Ametek pressure pumps do not require calibration and as such are not part of the Instrument and Control calibration program. Our position on this issue has been discussed with the Turkey Point NRC Resident Inspector.

3) The new gauges have been removed from the calibrated gauge storage drawer and all new, untagged and uncalibrated gauges will be properly segregated from calibrated equipment.

4) Instrument and Control maintenance instruction, " Adding New Measuring &

Testing Equipment", will be revised to include steps requiring segregation of new equipment. Administrative Procedure (AP) 0190.9, " Control of Measuring and Test Equipment", will be revised to clearly distinguish between equipment requiring calibration and equipment which does not.

5 Full compliance will be achieved by January 2,1985 FINDING 4.c:

Operating Procedure (0P) 0204.2 requires an operator to read Refueling Water Storage Tank (RWST) pressure, convert to gallons and record the RWST head pressure and check against tank level indicators LI-3-6583A and B. OP 0204.2 also requires that a name plate with an engraved correction factor be mounted next to the gauge.

Contrary to the above, the calculated RWST level was not compared with level indications LI-3-6583A and B and .they were out of service on Unit 3 and no facilities for additional level indications were made. In addition, there was no engraved correction factor attached to the local Ashcroft gauge.

RESPONSE

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1) FPL concurs with the finding.  !

2) The reason for the finding was that a PC/M to modify the RWST level infonnation in the control room was in the process of implementation. In addition, the original local tags containing the correction factor had deteriorated due to j weather conditions and had been removed or lost. The Reactor Control Operator (RCO) had instructions in the control room for the required correction factor to be used when calculating RWST levels based on RWST head pressure However, because no physical changes had been made to the local pressure gauge, it was not felt necessary for the correction factor to be verified prior to each calculation.

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o. Re$IEInspectionReport 250-84-23 and 251-84-24

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3) PC/M 83-33,34 " Addition of Refueling Water Storage Tank (RWST) Indication,"

placed two fully qualified and redundant P.WST level indicators with alarms in the control room. . This PC/M removed the local RWST pressure gauge, so the requirement in OP0204.2 to calculate RWST level based on RWST head pressure has been removed. Administrative contols have been added to the OP0204.2 to correct any discrepancies discovered in the two redundant RWST level indicators in the control room.

4) Adherence to procedural requirements has been the subject of several staff meetings and is the main topic in a new training program for all nuclear personnel as described in our letter L-84-275 dated October 3, 1984, Program for Improved Operation.

5) Full compliance was achieved on November 2,1984.

FlfeING:

On July 17, 1984, the licensee notified the NRC of a 10 CFR 21 report which they ,had received from their archite-t engineer. The control circuitry for safety-related pressure controllers PC-600 and PC-601 is powered from a single non-vital source. These controllers are to protect the Refueling Water Storage Tank (RWST) line from overpressure during cooled-down operations.

Loss of power to this circuit would not allow the suction and discharge valves to the Residual Heat Removal pumps to be opened from the control room. The failure of a single component (power from the non-vital bus) coincident with a loss of coolant accident would not allow the recirculation phase of safety injection to operate. The cause of the deficiency is that these relays and the control circuitry were not identified as safety related. This is another example of failure to properly identify equipment as safety related, and therefore, a failure to adequatley review items for ef fects on safety as stated in report 250,251/84-09 and is an example of that violation (250/84 10 and 251/84-09-10).

In your response to the previous violation, the stated cause was that design changes (PCM's) were incorrectly identified as non-nuclear safety related and consequently did not receive the appropriate review. Please address the ,

specific corrective actions taken, or to be taken, to assure that PCM's both l previously evaluated and to be evaluated are correctly classified. j

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' Re:,IE Inspection Report 250-84-23 and 251-84-24 t

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RESPONSE

1) FPL denies the finding.

2)' FPL denies the finding because the control ci rcuitry for pressure controllers PC-600 and PC-601 was part of the original design of the plant l and that design provided power for both relays from the same non-vital i

source. This is a design deficiency and not another example of an incorrectly classified PC/M. This deficiency was processed under the provisions of 10 CFR Part 21 and our QA requirements, and was reported to the NRC under 10 CFR 50.72 and 50.73 A PC/M (84-132, Unit 3 and 84-133, l ' Unit 4), classified as nuclear safety-related, has been developed to provide separate and redundant Class 1E feeds to each control relay to correct this desigr. deficiency as described in Licensee Event Report (LER) l 250-84-018.

In addition, to address your concerns on PC/M classification the following actions have been or will be taken:

a) Our Engineering Department has been requested to review PC/Ms from 1980 on, classified as non-Nuclear Safety and non-Nuclear Safety Related - QA/QC required to verify their classifications. An outside consultant has been contracted to develop a procedure describing PC/M classification. Following proper reviews and approvals, the consultant will use this procedure in reviewing the aforementioned PC/Ms.

b) This review is expected to be completed by December 31, 1985.

c) The resulcs of this review will be forwarded to our Engineering Department which in turn will make recommendations, if necessary, to promptly disposition any discrepancies discovered.

d) The guidelines of the newly developed procedure will he evaluated

! , and, if necessary, changes will be made to our procedures or i policies to ensure proper classification of PC/Ms regardless of l point of generation.

e) Administrative controls are now in effect that require the Plant Nuclear Safety Committee to review PC/Ms regardless of thei r classification.

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