L-88-192, Responds to NRC Ltr Re Violations Noted in Insp Repts 50-250/87-54 & 50-251/87-54.Corrective Actions:Gauges to Be in Svc During Off Normal/Emergency Condition Instead of Being Isolated & Procedure Onop 0208.11 Revised
| ML17345A124 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/25/1988 |
| From: | Conway W FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| L-88-192, NUDOCS 8805030073 | |
| Download: ML17345A124 (7) | |
Text
REQULATORY INFORMATION D ISTR IBUTION SYSTEM
( R IDS )
ACCESSION NBR FACIL: 50-250 50-251 AUTH. NAME CONl4AY> W. F.
RECIP. NAME 8805030073 DOC. DATE: 88/04/25 NOTARIZED:
NO DOC f(ET
~'
Turkey Point Plant.
Unit 3> Florida Pacer and Light C
05000250 Turkey Point Plant>
Unit 4> Florida Power and Light C
05000251 AUTHOR AFFILIATION Flori da Power ic Light Co.
REC IP IENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC ltr re violations noted in Insp Repts 50-250/87-54
~ 50-251/87-54. Corrective actions:gauge-to be in svc during off normal/emergency condition instead of being isolated D~ Procedure ONOP 0208. 11 revised.
DISTRIBUTION CODE:
IEOID COPIES'ECEIVED: LTR
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TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response i~tOTES:
REC IP IENT ID CODE/NAME PD2-2 PD COPIES LTTR ENCL 1
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AEOD NRR MOR ISSEAU> D NRR/DLPG/GAB 10 NRR/DREP/EPB 10 NRR/DR I8 DIR 9A MAN> J 02 RQN2 FILE 01 DEDRO NRR/DLPG/PEB 11 NRR/DOEA DIR 11 NRR/DREP/RPB 10 NRR/PMAS/ILRB12 OQC 15-8-18 RES/DRPS DIR 1
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LTTR 22 ENCL 22
APRIL' 5
1988 L-88-192 U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D.
C.
20555 Gentlemen:
Re:
Turkey Point Units 3 and 4
Docket Nos.
50-250 and 50-251 Reply to Notice of Violation Ins ection Re ort 87-54 Florida Power Light Company has reviewed the subject inspection report and a response to Finding A.3 is attached.
Our response to the remaining findings was submitted April 18/
1988.
Very truly yours, Acting Group Vice President Nuclear Energy WFC/SDF/gp Attachment cc:
Dr. J.
Nelson Grace, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant SDF/026. IR 8805030073 880425 PDR ADQCK 05000250 G
i i
ATTACHMENT RE:
TURKEY POINT UNITS 3 AND 4 DOCKET NO. 50-250, 50-251 IE INSPECTION REPORT 250-87-54
& 251-87-54 FINDING A:
10 CFR 50, Appendix B, Criterion III, as implemented by the approved Florida Power and Light Company Topical Quality Assurance Report (FPLTQAR) 1-76A, Revision 10, Topical Quality Requirement (TQR) 3.0, Revision 5,, requires that the design changes be subject to design control measures commensurate with those applied to the original design and that these design control measures assure that applicable regulatory requirements and the design basis are correctly translated into specifications,
- drawings, procedures, and instructions.
FPLTQAR 1-76A, Appendix C, Revision 7 specifically commits, with exceptions not relevant here, to American National Standards Institute (ANSI) N45.2.11-1974, Quality Assurance Requirements for the Design of Nuclear Power Plants, and to Regulatory Guide 1.64, Revision 2, Quality Assurance Requirements for the Design of Nuclear Power Plants, which endorses ANSI N45.2.11-1974.
ANSI N45.2.11-1974 specifies that design activities be prescribed and accomplished in accordance with procedures of a type sufficient to assure that applicable design inputs are correctly translated into specifications,
- drawings, procedures, or instructions.
Design changes must be justified and subjected to control measures commensurate with those applied to the original design.
Contrary to the above, in January 1988, inspections identified that the design inputs contained in Plant Change Modifications (PCMs)85-175 and 85-176, had not been correctly translated into operating procedures and the system description, as demonstrated by the examples below.
FINDING A.3:
Off Normal Operating Procedure (ONOP) 0208.11, Annunciator Test Panel I, Station
- Service, Revision dated September 10, 1987, specified that upon receipt of a low pressure
- alarm, each of 5 nitrogen bottle outlet pressure gauges should be placed in service by opening their root valves.
This was contrary to design requirements specified in PCMs85-175 and 85-176, which specified that the local pressure indicators are not seismically qualified and will be normally isolated from the system.
RESPONSE
1)
'PL concurs with the finding.
2)
When ONOP 0208.11 was revised after implementation of PC/M 85-175 and 85-176, it was determined that it was more important.. to have the gauges in service during an off normal/emergency condition than to have them isolated.
This was based on a review of PC/M 85-175 and 85-176 which stated that the "local pressure indicators be ~normall isolated from the system."
Since ONOP-0208.11 delineates off-normal conditions, it was determined
i
that it was essential to provide the operators with the AFW backup nitrogen pressure information.
3)
Procedure ONOP 0208.11 was revised upon identification of the concern to leave the non-seismic gauges isolated during off-normal conditions.
4) a) Since this time the non-seismic gauges have been removed and seismic gauges were installed by PC/Ms88-044 and 88-045, AFW Nitrogen Backup
- System, Pressure Indicator Replacement.
b)
An investigation will be conducted of this event to determine root cause and provide appropriate corrective actions.
This investigation will be reviewed and corrective actions taken as required.
5) a) Full compliance for item 3 above was achieved by January 27, 1988.
b) Full compliance for item 4.a above was achieved by March 28, 1988.
c) Full compliance for item 4.b above will be achieved by May 27, 1988.
C