ML17341A437

Responds to NRC 810218 Ltr Re Violations Noted in IE Insp Rept 50-250/81-01.Corrective Actions:Surveillance Area Redefined,Permanent Red Colored Floor Tiles Installed & Changes Made to Administrative Procedure 0103.2

ML17341A437
Person / Time
Site:	Turkey Point
Issue date:	04/20/1981
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML17341A438	List: ML17341A437
References
L-81-174, NUDOCS 8108180286
Download: ML17341A437 (9)

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ATLANTA, GEORGIA o>>

0 FLORIDA POWER & LIGHT COMPANY April 20, 1981 L-81 -174 Hr . Victor Stello, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Hr. Stello:

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Re: Turkey Point Unit 3 Docket No. 50-250 M

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)I I 10 CFR 2.201 Response to Notice of Violation dated Februar 18, 1981 The attachment to this letter contains Florida Power 6 Light Company's reply to your letter and Notice of Violation of February 18, 1981 as required by 10 CFR 2.201. Our reply pursuant to 10 CFR 2.205 has been prov d d separately as requested.

Very trul yours, Robert E. Uhrig Vice President Advanced Systems and TectIno'logy REU/RAK/rnbd Attachment cc: I~Ir. J.P. O'Reilly, Region II Harold F. Reis, Esquire 810818028b 0500025'0 PQR,'EOPLE...

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'e: Turkey Point Uni Docket Ho. 50-250

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10 CFR 2.201 Response to Notice of Violation dated e February 18, 1981 Page 1 ATTACHMENT

~Findin:

10 CFR 50.54(k) states that an operator or senior operator licensed pursuant to Part 55 of this chapter shall be present at the controls at all times during operation of the facility. 'echnical Specification 6.8.1 requires that written procedures and administrative policies be established, implemented and maintained that meet or exceed the requi rements and recommendations of Section

5. 1 and 5.3 of ANSI N18.7-1972, Appendix "A" of USHRC Regulatory Guide 1.33; this includes plant operating procedures. Plant Operating Procedure 0103.2, Responsibilities of Operators- On-Shift and Maintenance of Operating Logs and Records, states in Section 5.3.3 that the Nuclear Control Center Operator (NCCO) shall have an unobstructed view of and access to the control panels, including instrumentation displays and alarms. He shall not leave the Surveillance Area (Figure 1) for any non-emergency reason without obtaining a qualified relief. Section 5.3.4 states that a single operator shall not assume the HCCO responsibility for both units at the same time unless so directed and such action is in compliance wi th Technical Specification 6.2.2 or is necessitated by emergency conditions.

e Contrary to the above, at about 11:45 a.m. on January 29, 1981, the HRC Resident Inspector observed Turkey Point Unit 3 operating at full power without an operator present at the controls. The assigned Unit 3 operator was in a room behind the Unit 4 instrument panels which precluded visually monitoring the Unit 3 reactor conditions. The room, although open to the control room, is outside the surveillance area specified in Plant Operating Procedure 0103.2. A qualified relief had not been obtained and an operator leaving the surveillance area was not necessitated by an emergency condition, nor was the Unit 4 operator directed to assume HCCO responsibilities for both units.

~Res ense:

1. (1-1) FPL concurs with the finding, however, as discussed in our reply pursuant to 10 CFR 2.205, we take exception to the severity level classification.

The reason for the violation was that the Nuclear Control Center Operator (NCCO) did not adhere to the procedural requirement to obtain a relief prior to leaving the surveillance area.

As corrective action:

(1) The surveillance area has been re-defined and permanent red colored floor tiles have been installed to outline the

. surveillance area boundary.

P, Re: Turkey Point'Unit Docket Ho. 50-250 10 CFR 2.201 Response to Notice of Violation dated February 18, 1981 Page 2 (2) Changes have been made to Administrative Procedure 0103.2, .

Responsibilities of Operators On-Shift and Maintenance of Operating Logs and Records, which redefined the proper procedure which must be taken by the NCCO in order to leave the surveillance area. The third NCCO on shift is now required to normally stay in the surveillance area and to verbally notify and obtain acknowledgment from each operator with unit responsibility prior to leaving the surveillance area.

(3) A name display system has been implemented that positively identifies the operator who has unit responsibility. In order to transfer unit responsibility from one operator to another, the name display must be changed by the oncoming operator as part of his turnover acknowledgement.

(4) All operators have been instructed in wri'ting of their responsibilities.

(5) Plant management has begun a program of random visits to the Control Room at unannounced intervals. During these e visits, the management will verify that the licensed operators are conti nui ng to perform thei r duties in a professional manner.

(1-4) He will also take the following long and short term corrective actions to avoid similar problems in the future.

Short term:

The surveillance area boundaries will be redefined by April 30,- 1981 to fully meet the intent of Regulatory guide 1.114 as discussed at the management meeting with IKE personnel.

FP8L Management will conduct meetings with Licensed (2) by May 31, 1981 to emphasize the importance of

'perators this issue, to provide guidance on compliance with the Regulatory Guide, and to discuss management enforcement actions that will be taken should further deficiencies occur.

(3) Movable rope or chain barriers will be placed at appropriate openings to the surveillance'area boundaries by May 15, 1981 to give a more physical means of identifying the surveillance area and to limit access to this area by non licensed personnel .

(4) Plant management will conduct meetings with Licensed Operators to discuss Operator concerns, management policies, and Operator safety responsibilities.

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Re: Turkey Point Unit Docket No. 50-250 10 CFR 2.201 Response to Notice of Violation dated February 18, 1981 Page 3 Long term:

(1) A human factors engineering study of the Control Room layout will be conducted by January 1, 1982.

(2) The Nuclear Match Engineer's office will be modified by January.l, 1982 to allow him to see the control panels while in his office.

(3) Other physical changes will be made to permanently re-locate such items as water fountains, chart lockers, bookcases and coffee pots in short term item 1, above.

This will be accomplished by January 1, 1982.

Immediate corrective action was taken on January 29, 1981, in response to the violation. Additional corrective action, described in 1-3 above, was taken between January 30, 1981 and February 13, 1981. Additional short and long term cor-rective action to enhance compliance will be completed by the dates provided with each item in 1-4 above.

STATE OF FLORlDA )

) ss.

COUNTY OF DADE )

Robert E. Uhrig, being first duly sworn, deposes and says:

I That he is a Vice President of Florida Power & Light Company,

'the. Lic nsee herein; That he has executed the foregoing document; that the state-ments made in this said document are true and correct to the

'best of his knowledge, information, and belief, and that he is authorized to execute the document on behalf of said Licensee.

t Robert E. Uhrig Subscribed and sworn to before me this 9-C'ay of NOTARY PUBLIC, and for the county of Dade, State 'of Florida Ho,erg Pub'.i", 8!s'o ol i.>.i;:a;.t Lnpo Pgy COmmiSSiOn eXPireS = 'ond d '.hru 'A= "...".ri'.

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