L-90-362, Responds to Violations Noted in Insp Repts 50-250/90-30 & 50-251/90-30 Re Changes to Master Calibr Sheet.Corrective Actions:Maint Instruction 102.114 Revised
| ML17348A611 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/16/1990 |
| From: | Goldberg J FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| L-90-362, NUDOCS 9010260109 | |
| Download: ML17348A611 (10) | |
Text
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ESSXON NBR:9010260109 DOC.DATE: 90/10/16 NOTARIZED: NO DOCKET CIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C 05000251 AUTH.NAME AUTHOR AFFXLIATION GOLDBERG,J.H.
Florida Power 6 Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch- (Document Control Desk)
SUBJECT:
Responds to violations noted in Insp Repts 50-250/90-30 50-251/90-30 re changes to master calibr sheet.
DISTRIBUTION CODE:
XE01D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Xnsp Rept/Notice of Vio ation esponse NOTES:
RECIPIENT ID CODE/NAME PD2-2 PD INTERNAL: AEOD AEOD/TPAD NRR MORISSEAU,D NRR/DLPQ/LPEB10 NRR/DRIS/DIR NRR/PMAS/XLRB12 O~E-gG~ZL 02 RNAL'RC PDR COPIES LTTR ENCL
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1 RECIPIENT XD CODE/NAME EDISON,G AEOD/DEIIB DEDRO NRR SHANKMAN,S NRR/DREP/PEPB9 D NRR/DST/DXR SE2 NUDOCS-ABSTRACT
,OGC/HDS2 RGN2 FILE 01 NSXC COPXES LTTR ENCL 1
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'1 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE lVASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION t
LISTS FOR DOCUMENTS YOU DON'T NEED!
AL NUMBER OF COPXES REQUIRED:
LTTR 20 ENCL 20 t
P.O. Box 14000, Juno Beach, FL 33408-0420
't APL OCTOBER 1 6 1990 L-90-362 10 CFR 2.201 U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D.
C.
20555
'1 Gentlemen:'Re:
Turkey Point Units 3 and 4
Docket Nos.
50-250 and 50-251 Reply to Notice of Violation NRC Ins ection Re ort 90-30 Florida Power
& Light Company has reviewed the subject inspection report and pursuant to 10 CFR 2.201 the response is attached.
Very truly yours,
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~yak'.
H. Goldberg President Nuclear Division JHG/SAV/lef Attachment cc:
Stewart D. Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant t
901026010501016 PDR ADGCK 050002.:0 PDC an apl Group company
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'Il
p1
e ATTACHMENT REPLY TO A NOTICE OF VIOLATION RE:
Turkey Point Units 3 and 4
Docket Number 50-250 and 50-251 NRC Inspection Report 90-030 FINDlNG TS 6,.8.1 requires that written procedures and administrative policies shall be established, implemented, and maintained that meet or exceed the requirements and recommendations of Appendix A'f USNRC Regulatory Guide 1.33 and Sections 5.1 and 5.3 of ANSI N18.7-1972.
Section 5.1 of ANSI N18.7-1972 requires that administrative policies be provided to control the issuance of documents, including changes, that prescribe activities affecting safety-related structures,
- systems, or components.
Contrary to the above, administrative policies were not established to control changes to the master instrument calibration data sheet for Unit 4 CCW pump automatic start pressure
- switch, PC-4-611, in that procedures did not address changes to the instrument calibration data sheets.
In January, 1988, the required and actual setpoints for PC-3-611 and PC-4-611 were changed from 75.0
+ 1.5 psig to 60.0 + 1.5 psig but the related instrument calibration data sheets were not changed.
Subsequently, PC-4-611 was moved and then improperly calibrated to 75.0
+ 1.5 psig using the instrument calibration data sheets.
As a result, on July 26, 1990, the Unit 4A CCW pump improperly automatically started due to pressure switch PC-4-611 being set at the wrong value.
RESPONSE
TO THE FINDING FPL concurs with the finding.
2.
Instrument calibration data sheets were developed to augment Plant Work Orders (PWOs) for those instruments under the control of I C Maintenance.
Instrument calibration data sheets specify a setpoint and require that the as-found and
.as-left setpoint be documented.
During initial development, setpoints contained in design documents were incorporated into the instrument calibration data sheets.
Although not proceduralized, a policy had been developed for revising instrument calibration data sheets.
An individual within I
& C Maintenance was assigned the responsibility for revising instrument calibration data sheets and for ensuring the affected instrument(s) is calibrated to the new setpoint.
e When the setpoint for PC-*-611 was changed to 60.0 +/- 1.5 psig, this individual failed to revise the affected instrument calibration data sheet.
Additionally, the instrument calibration data sheet was not attached to the Plant Work Orders (PWOs) used to change the setpoint of PC-3-611 and PC-4-611 to 60.0 +/- 1.5 psig.
Only the setpoint change document was attached to the PWOs.
3.
'The written violation stated that the 4A CCW pump, improperly automatically started due to pressure switch PC-4-611 being set at the wrong value.
FPL would like to clarify that automatic starting of a
CCW pump upon CCW pump discharge header pressure reaching the low pressure setpoint is a proper system reaction.
This violation and the following corrective steps, with the exception of Corrective Step 3.c, were discussed in Licensee Event Report 50-251/90-007.
Corrective steps which have been taken and the results achieved include:
a.
The instrument calibration data sheet for PC-3-611 and PC-4-611 was revised to specify a low pressure setpoint of 60.0 psig +/- 1.5 psig.
b.
PC-3-611 and PC-4-611 were calibrated to 60.0 psig +/-
1.5 psig.
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c.
This event was discussed during an I & C Maintenance shop meeting.
Corrective steps which have been taken to avoid further violations include:
a
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Maintenance Instruction 102. 114, "Maintenance Instruction On The Spot Change (MICHANGE) Preparation, Review and Approval Form," has been'evised to include provisions for changing instrument calibration data sheets based on information contained in a
Plant Change/Modification (PC/M).
b.
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& C Maintenance instrument setpoint changes which were made through Administrative Procedure 0140.2, "Precautions, Limitations, and Setpoint Changes,"
and issued PC/Ms were verified.
No discrepancies were found.
c ~
Administrative Procedure O-ADM-701, "Plant Work Order Preparation,"
has been revised to require instrument calibration data sheets to be verified and attached to PWOs that involve instrument calibrations or calibration checks.
The date when full compliance was achieved:
a
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b.
c ~
Item 3.a was completed on July 27, 1990.
Item 3.b was completed on July 27, 1990.
Item 3.c was completed on August 3, 1990.
d.
Item 4.a was completed on August 2, 1990.
e.
Item 4.b Item 4.c was completed on was completed on September 2S, 1990.
August 9,
1990.
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