ML17223A452

Responds to Violations Noted in Insp Repts 50-335/89-27 & 50-389/89-27.Corrective Actions:Step Documentation for Rev 3 to Cen 152 Emergency Operating Procedures Will Be Completed by Dec 1990

ML17223A452
Person / Time
Site:	Saint Lucie
Issue date:	01/05/1990
From:	Goldberg J FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-82-33, L-90-7, NUDOCS 9001120278
Download: ML17223A452 (5)

Text

ACCELERATED DISTjUBUTION DEMONSTPATION SYSTEM

]I REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9001120278 DOC.DATE: 90/01/05 NOTARIZED: NO DOCKET FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power & Light Co. 05000335 50-389 St. Lucie Plant, Unit 2, Florida Power & Light Co. 05000389 AUTH. NAME AUTHOR AFFILIATION GOLDBERG,J.H. Florida Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to violations noted in Insp Repts 50-335/89-27 &

50-389/89-27.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Vi&o ation Response NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 PD 1 1 NORRIS,J 1 .

1 INTERNAL: ACRS 2 2 AEOD 1 1 AEOD/DEIIB 1 1 AEOD/TPAD 1 1 DEDRO 1 1 NRR SHANKMAN,S 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA DIR 11 1 1 NRR/DREP/PEPB9D 1 1 NRR/DREP/PRPB11 2 2 NRR/DRIS/DIR 1 1 NRR/DST/DIR 8E2 1 1 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 OS~ - N,J 1 1 OGC/HDS2 1 1 02 1 1 RES MORISSEAU,D 1 .

1 GN2 FILE OI 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER'OF..COPIES REQUIRED: LTTR 26 ENCL 26

. P.O. Box 14000, Juno Beach, FL 33408.0420 JANUAf5 P 5 $ 990 L-90-7 10 CFR 2.201 U. S., Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:

Re: St. Lucie Units 1 and 2

~

Docket Nos. 50-335 and 50-389

~

Reply to a Notice of Violation

~ ~ ~

Ins ection Re ort 89-27 Florida Power & Light Company'FPL) has reviewed the subject inspection report and pursuant to 10 CFR 2.201 the response is attached.

cl g,gi~~e, .

J. H. Goldberg Executive Vice President JHG/GRM/rh Attachment cc: Stewart D. Ebneter, Regional Administrator, Region Senior Resident Inspector, USNRC, St. Lucie Plant II, USNRC

. Re: St. Lucie Units 1 and 2 Dockets Nos. 50-335 and 50-389 Reply to a Notice of Violation Ins ection Re ort 89-27 Violation 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires that measures shall be established to assure that significant conditions adverse to quality, such as deficiencies, deviations, and nonconformances are promptly identified and corrected, and that such measures include action to preclude repetition. NRC Generic Letter 82-33 requires that licensees develop and implement improved EOPs using an NRC approved procedures genera/ion package. By letter dated April 15, 1983, the licensee committed to implement this EOP improvement program. St. Lucie procedure QI 5-PR/PSL-6 Requirements for Development and Revision of Emergency Operating Procedures (Procedures Generation Package), Revision 0, dated April 10, 1987, requires that safety significant EOP deviations from the latest NRC approved revision to CEN-152, Combustion Engineering Emergency Procedure Guidelines, will be documented and reviewed by the technical staff prior to final approval of the EOPs. NRC Notice of Deviation (NOD) 389/88-08-01, dated August 28, 1988, stated that the licensee failed to provide the technical basis or justification for significant EOP differences from CEN-152. In a September 22, 1988, response to the NOD, the licensee stated that discrepancies identified in the NOD would be corrected at the next revision to the EOPs, scheduled for June, 1989, and that these corrective actions would include backup information giving details for EOP deviations from CEN-152.

Contrary to the above, the licensee failed to document justifications for safety significant EOP deviations from CEN-152, Revision 3, and to review them by the technical staff prior to final approval and use of the revised EOPs in September, 1989.

R~ee once Florida Power & Light Company (FPL) concurs with the violation.

2. The EOP justifications were not adequately documented because the personnel involved in the EOP revision process did not properly assess the importance of documenting the deviations from CEN-152 prior to issuing the EOPs. A technical review was conducted during the EOP revision process and this information was scheduled for incorporation into step documentation after the review and approval of the EOPs.

3 ~ The step documentation was in progress at the time of the November 1989 inspection. This process is ongoing.

4 ~ With the exception of revision 1 of EOP-15, future revisions of the EOPs will have step documentation complete prior,to revision review and approval. Revision 1 of EOP-15 incorporates human factor and implemention clarification corrections and is scheduled to be issued prior to January 15, 1990. The step documentation for this revision will be prepared subsequent to approval. This approach was discussed with the NRC staff at a meeting held on December 22, 1989.

5. Step documentation for CEN 152 (Rev. 3) EOP revisions will be completed by December 1990.

IFI 50-335 389-89-27-02 Develop St. Lucie PSTG for EOPs, paragraph 2.

"The inspection team indicated to the Licensee that a PSTG was required which could be maintained and used effectively for the development and revision of the EOPs. Such a PSTG is described in

. NUREG-0800, Standard Review Plan, Rev 0, in Appendix A, paragraph 3.0. The licensee committed to consider developing a new PSTG (including a setpoint document). The detailed description of this PSTG and its projected completion date is to be addressed by the licensee in their response to this inspection report. Resolution of this item was identified as IFI 50-335, 389/89-27-02.

~Res ense As described in FPL letter L-88-462 dated October 20, 1988, FPL believes the step documentation sheet with backup information is an acceptable Plant Specific Technical Guideline (PSTG).

As discussed in FPL's response to the NOV 50-335/389-89-27-01, the PSTG for CEN 152 (Rev. 3) will be complete by December, 1990.

Plant guidelines will be prepared which will establish the criteria for changing the applicable steps of the EOPs by December 1990.

This would allow for editorial corrections with minimum effort and require engineering review where substantial safety concerns exist.