ML17347B587

Responds to Violations Noted in Insp Repts 50-250/89-48 & 50-251/89-48.Corrective Action:Cited Drawing Discrepancies Corrected & Memo Reemphasizing Procedure as Being Method for Documenting Drawing Discrepancies Issued to Personnel

ML17347B587
Person / Time
Site:	Turkey Point
Issue date:	02/27/1990
From:	Goldberg J FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9003090083
Download: ML17347B587 (5)

Text

ACCELERATED DISTIGBUTION DEMONSTjRATION SYSH2M REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

CCESSION NBR:9003090083 DOC.DATE: 90/02/27 NOTARIZED: NO DOCKET FACIL: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 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 50-250/89-48 &

50-251/89-48.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Vio ation Response NOTES RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 PD 1 1 EDISON,G 1 1 INTERNAL: AEOD 1 1 AEOD/DEIIB 1 1 AEOD/TPAD 1 '. 1 DEDRO 1 1 NRR SHANKMAN,S 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA DIR 11 1 1 NRR/DREP/PEPB9 D 1 1 NRR/DREP/PRPBll 2 2 NRR/DRIS/DIR 1 1 NRR/DST/DIR 8E2 1 1 NRR/PMAS/ILRB12 1 1 NUDOCS-A STRACT 1 1 OGC/HDS2 1 1 F L 02 1 1 RES MORISSEAU,D 1 1 FILE 01 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASIZt CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXI'. 20079) TO ELMINATEYOUR NAME FROM DISTRIBUTION LIS1S FOR DOCUMENTS YOU DON'T NEEDI OTAL NUMBER OF COPIES REQUIRED: LTTR 23 ENCL 23

P.O Box14000,Juno Beach,FL 33408 0420 L-90-81 10 CFR 2.201 fE8RUARY. 2 7 ]ggg U. S. Nuclear Regulatory Commission Attention: 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 89-48 Florida Power & Light Company has reviewed the subject inspection report and pursuant to 10 CFR 2.201 the response is attached.

Very truly yours, J. H. Goldberg Executive Vice President Nuclear Energy JHG/GRM/slh Attachment cc: Stewart D. Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant F00305'00c'3 PDF ~DOCK 050002.'= 0 9 pnt,.

/(p(

an FPh Group comrr,.r,

ATTACHMENT RE: Turkey Point Units 3 and 4 Docket Numbers 50-250 and 50-251 NRC Inspection Report 89-48 FINDING 10 CFR 50, Appendix B, Criterion V and the licensee's accepted Quality Assurance Program, FPL TQAR 1-76A, Section 5 require that activities affecting quality shall be prescribed by appropriate drawings.

Contrary to the above, two drawings, Operating Diagrams 5610-T-E-4501, Sheet 1, and 4510, Sheet 2, contained errors identified by NRC inspectors. These specific errors were promptly corrected and the licensee agreed to perform a further review to identify and correct any similar drawing errors.

RESPONSE

1 ~ FPL concurs with the finding.

2 ~ The Plant Operating Drawings (T-E series) were maintained by the Training Department and used as operator training documents until approximately 1979. At that time, the responsibility for maintaining the Plant Operating Drawings was transferred to the Engineering Department. A limited scope as built walkdown of the Plant Operating Drawings was initially performed during the turnover process; however, the drawing discrepancies noted by the NRC inspectors were not identified at that time. Use of the two subject Plant Operating Drawings since 1979 has not resulted in identification of the noted discrepancies by utility personnel. A discussion of the cited discrepancies is provided below.

a ~ Drawing 5610-T-E-4501, Sheet 1, depicted the Residual Heat Removal (RHR) System hot leg suction line coming from the Reactor Coolant System (RCS) Loop C hot leg for both Units. This is correct for Unit 3, however, the RHR System hot leg suction line comes from the RCS Loop A hot leg for Unit 4. This discrepancy existed at the time the drawing was turned over to the Engineering Department in 1979. The associated Piping and Instrument Drawing (P&ID) correctly identifies the RHR hot leg suction line coming from RCS Loop C for Unit.3 and, by note, describes the RHR hot leg suction line coming from RCS Loop A for Unit 4. The cause for the continued existence of the drawing discrepancy was that the discrepant condition was not recognized by utility personnel.

b. Drawing 5610-T-E-4510, Sheet 2, correctly identified the RHR System hot leg suction line as coming from RCS Loop C for Unit 3 and from RCS Loop A for Unit 4 within the flow arrows but had the direction of one flow arrow incorrectly drawn. Additionally, both of the flow arrows incorrectly referenced drawing 4510 instead of drawing 4501. The cause for the drawing discrepancies was an oversight by individuals responsible for drawing upgrades.

System walkdown guidelines for System Engineers were issued in June 1989. The drawing discrepancies noted by the NRC inspectors were on that part of the RHR System located inside the containment buildings. System walkdowns inside containment buildings would normally be performed during refueling outages. Neither Unit 3 nor Unit 4 entered a refueling outage between June 1989 and November 17, 1989. System walkdowns performed on systems outside the containment buildings since June 1989 have proven effective in identifying drawing discrepancies and initiating corrective actions.

3. Corrective steps which have been taken and the results achieved include:

a. The cited drawing discrepancies were corrected.

b. A memorandum was issued to Operations personnel re-emphasizing Administrative Procedure O-ADM-510, "Request for Engineering Assistance," as being the method for documenting drawing discrepancies.

4 ~ Corrective steps which will be taken to avoid further violations include:

System walkdown guidelines for System Engineers have been further revised to clarify that system walkdowns include the entire system (i.e., accessible portions of the system inside and/or outside the containment building).

5. The date when full compliance was achieved:

a. Item 3.a was completed by November 17, 1989.

b. Item 3.b was completed on February 14, 1990.

c. Item 4 was completed on February 20, 1990.

'