L-92-339, Responds to NRC Ltr Re Violations Noted in Insp Insp Repts 50-250/92-24 & 50-251/92-24.Corrective Actions:Licensee Procedure Will Be Written for Installation of RTDs That Will Include Data Transmittal for Updating Protection Parameters
| ML17349A558 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 12/21/1992 |
| From: | Goldberg J FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| L-92-339, NUDOCS 9212280093 | |
| Download: ML17349A558 (10) | |
Text
ACCELERATED DOCUMENT DISTRIBUTIONSYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9212280093 DOC.DATE: 92/12/21 NOTARIZED: NO DOCKET ACIL: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 AFFILIATION GOLDBERGJ.H.
Florida Power
& Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC ltr re violations noted in insp insp repts 50-250/92-24
& 50-251/92-24.Corrective actions:licensee procedure will be written for installation of RTDs that will include data transmittal for updating protection parameters.
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TITLE: General (50 Dkt)-Insp Rept/Notice of Vi lation Response R
D NOTES:NRR RAGHAVAN,L NRR RAGHAVAN,L RECIPIENT ID CODE/NAME PD2-2 PD INTERNAL: AEOD AEOD/DSP/TPAB DEDRO NRR/DLPQ/LHFBPT NRR/DOEA/OEAB NRR/PMAS/ILPB NUDOCS-ABSTRACT OGC/HDS3 RGN2 FILE 01 EXTERNAL EG&G/BRYCE z J ~ H ~
NSIC NOTES:
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1 RECIPIENT ID CODE/NAME AULUCK,R AEOD/DEIB AEOD/TTC NRR MORISSEAU,D NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NRR/PMAS/ILRB12 REG FILE 02 NRC PDR COPIES LTTR ENCL 1
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D NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACI'HEDOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
D TOTAL NUMBER OF COPIES REQUIRED:
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P.O. Box 14000, Juno Beach, FL 33408-0420 DEC 2 1 1992 L-92-339 10 CFR 2.201 U.
S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D. C.
20555 Gentlemen:
Re:
Turkey Point Units 3 and 4
Docket No. 50-250 and 50-251 Reply to Notice of Violation NRC Ins ection Re ort 92-24 Florida Power and Light Company has reviewed the subject inspection report
- and, pursuant to 10 CFR 2.201, the required response is attached.
t If there are any questions, please contact us.
Very truly yours, H. Goldberg
)
President Nuclear Division JHG/OIH/oh Attachment cc:
Stewart D. Ebneter, Regional Administrator, Region II, USNRC Ross C. Butcher, Senior Resident Inspector,
- USNRC, Turkey Point Nuclear Plant
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9212280093 92i22i PDR ADOCK 05000250 PDR an FPL Group company
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Attachment to L-92-339 Page 1
, ATTACHMENT REPLY TO A NOTICE OP VIOLATION RE:
Turkey Point Units 3 and 4
Docket Nos.
50-250 and 50-251 NRC Inspection Report 92-24 FINDING:
Technical Specification 6.8.1 requires that written procedures be established, implemented, and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Section 9 of Appendix A of Regulatory Guide 1.33 recommends procedures for performing maintenance.
Administrative Procedure 0190.19, Control of Maintenance and Construction Work on Safety Related and Quality Related
- Systems, paragraph 3.2.1, states that work activities which can affect the performance of safety related and quality related equipment shall be appropriately preplanned and shall be performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
Procedure O-GMI-102.26, Alteration of Eagle 21 Protection System Parameters, Section 6.6, Protection Set III Parameter
- Update, on page 38, requires that the field supervisor verify that the correct parameters were updated and the correct values for parameters were entered.
Contrary to the above, on September 19, 1992, incorrect scaling constants for the channel III resistance temperature detectors were entered into the Eagle 21 protection system and were improperly verified as correct by the field supervisor.
This is a Severity Level IV violation (Category 1).
Attachment to L-92-339 Page 2
RESPONSE
TO FINDING 2.
Company concurs with the finding.
Cause of the violation:
The Resistance Temperature Detector (RTD) has three constants which are used to relate resistance to temperature.
These constants come from a data sheet supplied by Westinghouse which relates the RTD serial number to its respective constants.
The Westinghouse procedure for replacing the RTD required a data sheet which related tag number to serial number.
The error of interchanging the RTD constants resulted from not having the data from the Westinghouse procedure for replacing the RTD when the parameters were updated.
The data was verbally transmitted and not verified against the Westinghouse procedure.
This error was caused by the lack of attention to detail by the journeyman and the field supervisor.
3.
Corrective steps which have been taken and the results achieved:
a.
The Turkey Point journeyman and field supervisor involved were counseled in accordance with Nuclear Division policy.
b.
A Plant Work Order was issued to correct the RTD temperature constants.
The work was completed on 9/19/92.
c ~
Procedure O-GMI-102.26 was revised to add independent verification for adequacy of the documents to be used for system parameter
- update, and to clarify supervisor signature blocks and step numbers.
In addition, a formal transmittal sheet for RTD parameters is required.
The procedure was revised on 11/5/92.
d.
Procedures 3/4-PMI-059.8, 3/4-PMI-059.9, and 3/4-PMI-059.10 were revised to obtain information necessary for a periodic review of all the protection system parameters.
The procedures were revised on 11/5/92.
4.
The corrective steps to be taken to avoid further violations:
a ~
The procedure used for RTD replacement was a Westinghouse procedure.
An FPL procedure will be written for installation of RTDs.
This procedure will include data transmittal forms for use in updating the protection system parameters..
The FPL procedure will be completed by 1/15/93.
5.
The date when full compliance was achieved:
Full compliance was achieved on 9/19/92 with the correction of the RTD T-Cold temperature constants.
I,
~
Attachment to L-92-339 Page 3
6.
Other information:
Interchanging the RTD constants had no effect on the T-Cold signal used for protection and safeguards signals because the constants swapped were for two RTDs measuring the same temperature.
In this case, the two T-Colds for Loop C are averaged internally to develop the protection T-Cold signal.
Calculations have shown that this average signal from two RTDs, with their constants
- swapped, is the same as the temperature input to the RTDs.
Therefore, this interchange of RTD constants had no effect on nuclear safety.