ML17348A180

Responds to NRC 900314 Ltr Re Violations Noted in Insp Repts 50-250/89-53 & 50-251/89-53.Corrective Actions:Existing Administrative Procedures Revised & New Procedures Developed to Provide Detailed Mgt Controls

ML17348A180
Person / Time
Site:	Turkey Point
Issue date:	04/11/1990
From:	Harris K FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-90-136, NUDOCS 9004230002
Download: ML17348A180 (9)

Text

. AC CELEBRATED D1F>TMBUTlON DEMON STRXTION SYSTEM REGULATORY INFOR'4QTION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9004230002 DOC.DATE: 90/04/11 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 TH.NAME AUTHOR AFFILIATION RIS,K.N. Florida Power 8 Light Co.

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

SUBJECT:

Responds 50-250/89-53 to NRC 900314 ltr re violations noted in Insp 50-251/89-53.Corrective actions:

Repts DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR i ENCL TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response

~ SIZE: 5 NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 PD 1 1 EDISONiG 1 1 INTERNAL: AEOD 1 1 AEOD/DEIIB 1 1 AEOD/TPAD 1 1 DEDRO 1 1 NRR SHANKMANiS NRR/DOEA DIR NRR/DRIS/DIR ll 1 1

1 1

1 1

NRR/DLPQ/LPEB10 NRR/DREP/PEPB9D NRR/DST/DZR 8E2 1

1 1

1 1

1 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 OE DI 1 1 OGC/HDS2 1 1 RES/DSR/HFB/HFS

~~a 1 1

1 1

1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 NCtZE K) ALL "RZDS" KKIPIENZS RQCN LISTS HER DOCUMENIS YOU DCNIT NEED!

~

PIZASE HELP US V3 REDUCE WASTE! COMPACT 'IHE DOCUMENZ CGNGRL DESK Pl-37 (EXT. 20079) ZO 1KZMZNLTB NAME HKH DISTiGEOTICS TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 22

P.O. Box14000, Juno Beach, FL 33408-0420 APR 11 1990 L-90-136 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:

RE: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 NRC Inspection Report 89-053 NRC Inspection Report 50-250, 251/89-053 was issued on March 14, 1990 and provided the results of the Emergency Operating Procedure (EOP) audit conducted at the Turkey Point Nuclear Plant site on January 22 to February 2, 1990. The subject NRC Inspection Report requested that a response be provided by April 13, 1990 clearly defining FPL's plans for corrective action on the inspection findings contained therein. The requested information is provided in the enclosed attachment.

Additionally, a verbal commitment documented in Paragraph 3 of the subject NRC Inspection Report stated that the Shift Technical Advisors (STAs) would be given a key to Document Control and additional training in accessing document control records. During those periods that the plant has entered an Emergency Operating Procedure (EOP), the STA is required to remain in the Control Room to provide Operations support. Therefore, alternate methods of addressing the NRC concern of Document Control access are being evaluated (i.e., use of the Shift Technician).

Should there be any questions on the above or attached information, please contact us.

Very truly yours, K. N Harris Vice resident Turkey Point Plant Nuclear KNH/JEC/DRP/DWH/rat attachment cc: Stewart D. Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant voooasooop FDR. ADOCa 9ooafi OSOaOaSO r~uf 8 PNU an Fpl. GrouP cornPan'f

ATTACHMENT RE: Turkey Point Units 3 and 4 Docket Numbers 50-250 and 50-251 NRC Inspection Report 89-053 ITEM 1 Provide a statement of intended corrective actions, including schedules, for the application of management controls to the maintenance of Emergency Operating Pro-cedures (EOPs) and Off-Normal Operating Procedures (ONOPs).

RESPONSE TO ITEM 1 Intended corrective actions and scheduled completion dates are as follows:

Action Date Revise existing administrative procedures and develop 03/01/91 new administrative procedures, as necessary, to pro-vide detailed management controls which will:

A. Clearly define interdepartmental duties and re-sponsibilities related to the maintenance of EOPs and ONOPs.

B. Provide a specific list of documents which make up the Plant Specific'Technical Guidelines (PSTGs).

C. Provide administrative controls necessary to en-sure that PSTG documents are updated as procedure changes are made.

D. Provide special administrative controls for the EOP and ONOP review and approval process. These controls will address the need for verification, validation and engineering evaluation; as well as training requirements associated with each EOP and ONOP change.

E. Eliminate conflicting guidance pertaining to EOP and ONOP development, revision, verification, validation, periodic review, and approval.

ITEM 2 Provide intended corrective actions, including schedules, for the revision of ONOPs for cavity seal failure.

RESPONSE TO ITEM 2 Intended corrective actions and scheduled completion dates are as follows:

Action Date An engineering analysis will be performed to support 11/30/90 the event mitigation strategy for refueling cavity seal failure. The results of this engineering analysis will be used to revise or replace procedures 3/4-ONOP-033.2, "Refueling Cavity Seal Failure." The discrepant conditions noted in Section V.23 of Appendix B to the subject NRC Inspection Report will be resolved during the procedure upgrade. The above actions will be com-pleted by the scheduled completion date.

ITEM 3 Provide intended corrective actions, including schedules, for the revision of ONOPs for intake cooling water malfunctions.

e RESPONSE TO ITEM 3 Intended corrective actions and scheduled completion dates are as follows:

Action Date Develop one new ONOP to address intake cooling water 11/30/90 failure scenarios currently addressed in ONOP 3408.1, "Intake Cooling Water - Malfunction," and ONOP 3408.2, "Intake Cooling Water - Failure of System," then can-cel ONOP'.3408.1 and ONOP 3408.2. The discrepant con-ditions noted in Sections V.50 and V.51 of Appendix B to the subject NRC Inspection Report will be resolved during the procedure upgrade. The above'ctions will be completed by the scheduled completion date.

ITEM 4 Provide the date by which the review and corrective action will be complete. for the findin'gs identified in the subject NRC Inspection Report.

RESPONSE TO ITEM 4 Intended .corrective actions and the scheduled completion dates are as follows:

e

Action Date FX 53-01: Lack of restrictions on EOP entry points.

This finding will be addressed during de- 03/01/91 velopment of the detailed management con-trols outlined in Item above.

1 IFI 53-02: Three particularly weak ONOPs and overall weakness in ONOPs.

The,ONOPs for refueling cavity seal failure 11/30/90 will be upgraded as outlined in Item 2 above.

The ONOPs for intake cooling water malfunct- 11/30/90 ions will be upgraded as outlined in Item 3 above.

ONOP 0208.15, "Annunciator - General," will 11/30/90 be revised or replaced to resolve the dis-crepant conditions noted in Section V.42 of Appendix B to the subject NRC Inspection Report.

The overall weaknesses in ONOPs will be 12/31/92 addressed through actions taken to resolve IFX 53-05, IFX 53-06, and XFI 53-07. The completion date is an estimated date which is subject to change.

IFI 53-03: Weakness in EOP placekeeping.

This finding will be addressed during de- 03/01/91 velopment of the detailed management con-trols outlined in Item above.

1 IFI 53-04: EOP VIV open items from PGP SER.

This item will be addressed during develop- 03/01/91 ment of'he detailed management controls outlined in Item 1 above.

IFI 53-05: EOP technical and human factors deficiencies.

The discrepant conditions identified against 11/01/91 EOPs in Appendix B to the subject NRC In-spection Report will be resolved. The com-pletion date is an estimated date which is subject to change.

The discrepant conditions identified against 12/31/92 ONOPs in Appendix B to the subject NRC In-spection report will be resolved as part of an ongoing procedure upgrade milestone. Up-

grade priority will address ONOPs referenced by EOPs first. The remaining ONOPs will be addressed as determined by plant need. The completion date is an estimated date which is subject to change.

IFI 53-06: EOP writer's guide deficiencies.

The discrepant conditions identified against 11/01/91 EOPs in Appendix C to the subject NRC In-spection Report will be resolved. The com-pletion date is an estimated date which is subject to change.

The discrepant conditions identified against 12/31/92 ONOPs in Appendix C to the subject NRC In-spection Report will be resolved as part of an ongoing procedure upgrade milestone. Up-grade priority will address ONOPs referenced by EOPs first. The remaining ONOPs will be addressed as determined by plant need. The completion date is an estimated date which is subject to change.

The discrepant conditions identified against 03/01/91 the EOP Writer's Guide and the ONOP Writer' Guide in Appendix C to the subject NRC In-spection Report will be addressed during de-velopment of the detailed management controls outlined in Item 1 above.

IFI 53-07: EOP nomenclature'and labeling deficiencies.

The discrepant"conditions identified against 11/01/91 EOPs in Appendix D to the subject NRC In-spection Report will be resolved. The com-pletion date is an estimated date which 'is subject to change..

The discrepant conditions identified against 12/31/92 ONOPs in Appendix D to the subject NRC In-spection Report will be resolved as part of.

an ongoing procedure upgrade milestone. Up-grade priority will address ONOPs referenced by EOPs first. The remaining ONOPs will be addressed as'determined by plant need. The completion date is an estimated date which .

is subject to change.

/

IFI 53-08: Management control of ONOPs and EOPs.

II This finding is addressed in Item 1 above. 03/01/91 1