ML17348A822
| ML17348A822 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 01/17/1991 |
| From: | Goldberg J FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| L-91-23, NUDOCS 9101220473 | |
| Download: ML17348A822 (10) | |
Text
,l REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ESSION NBR:9101220473 DOC.DATE: 91/01/17 NOTARIZED:
NO CIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 50--251 Turkey Point Plant, Unit 4,. Florida Power and Light C AUTH.NAME AUTHOR AFFILIATION GOLDBERG,J.H.'lorida Power
& Light, Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET 05000250 05000251
SUBJECT:
Responds to violations noted in Insp Repts,50-250/90-40 50-251/90-04.Corrective actions:task group formed to procure
& implement computerized surveillance scheduling program procedures revised to monitor RCS pressure indicators.
DISTRIBUTION CODE:
IEOID COPIES RECEIVED:LTR ENCL g SIZE:
TITLE: General (50 Dkt)-Insp'Rept/Notice of Vio ation Response NOTES:
RECIPIENT ID CODE/NAME'D2-2PD INTERNAL: AEOD AEOD/TPAB NRR MORISSEAUiD NRR/DLPQ/LPEB10 NRR/DREP/PEPB9D NRR/DST/DIR. SE2 NUDOCS-ABSTRACT OGC/HDS2 RGN2 FILE 01 EXTERNAL EG&G/BRYCE E J
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1 RECIPIENT ID CODE/NAME AULUCK,R AEOD/DEIIB DEDRO NRR SHANKMAN,S NRR/DOEA/OEAB NRR/DRIS/DIR NRR/PMAS/ILRB12 OQ~Q EG FILE 02 NRC PDR
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1 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TQ REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOiil Pl-37 (EXT. 20079) TO ELliXIINATEYOUR NAii<E FROiil DISTRIBUTION LISTS FOR DOCUb,lENTS YOU DON'T NEED!
TAL NUMBER OF COPIES REQUIRED:
LTTR 22 ENCL 22
P.O, Box 140u., ~ono Boa~4, FL 3340o-0420
'e Pf-'>r..
JANUARY 1 7 j99 i L-91-23 10 CFR 2.201 U.
S. Nuclear Regulatory Commission
- Attn:
Document Control Desk Washington, D.
C.
20555
'IGentlemen:
Re:
Turkey Point Units 3 and 4
Docket No. 50-250 and 50-251 Reply to Notice of Violation NRC Ins ection Re ort 90-40 t
Florida Power and Light Company has reviewed the subject inspection report and pursuant to 10 CFR 2.201, the required response is attached.
Very truly yours, J.
H. Goldberg~
President Nuclear Division JHG/DPS/ds Attachment cc:
Stewart D. Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Nuclear Plant 9i0i22047 'i0i17 PDR ADOCK 050002
<0
~ Q PDR tg
ATTACHMENT REPLY TO NOTICES OF VIOLATION RE,:
Turkey Point Units' and 4
Docket'os.
50-250 and 50-251 NRC Inspection Report 90-40 FINDING A Technical Specification (TS) 4.15.4.a.1 requires the fire protection hose stations in the vicinity of safety-related equipment to be visually inspected on a monthly interval.
TS 4.0.1 allows the scheduled interval to be adjusted, plus or minus 25
- percent, to accommodate normal test schedules.
Contrary to the
- above, the allotted time interval to perform TS surveillance 4.15.4.a.l was exceeded in that between October 4,
- 1990, and On November 13, 1990, this monthly surveillance was not accomplished.
This exceeded the TS required time including the additional 25 percent allowed by TS 4.0.1.
RESPONSE
TO FXNDING A 1 ~
FPL concurs with the finding.
2
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The cause for exceeding the maximum allowed TS interval between Fire Hose Station surveillances was inadequate administrative controls of the surveillances.
If surveillances are performed on the date scheduled by procedure 0-OSP-200.1,,
the surveillances will, be performed within maximum time intervals allowed by TS. If a surveillance is to be performed later than the scheduled
- date, Control Room personnel identify this condition during their daily review of procedure O-OSP-200.1 scheduling sheets.
They then track the surveillance to completion and ensure that it is completed within the allowable time frame.
However, if a surveillance is performed earlier than scheduled by procedure G-OSP-200.1, no guidance for controls existed at the time of this event to ensure that the maximum time interval allowed by TS is not exceeded for a subsequent surveillance test.
3
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Corrective steps which have been taken and the results achieved include:
This event and applicable corrective actions were reported in Licensee Event Report (LER) 50-250/90-022-0, submitted to the NRC on December 12, 1990.
These corrective actions included the following:
a.
Appendix A to procedure MP 15537.5 was satisfactorily completed on November 13, 1990.
All fire hose stations were found to be operable.
b.
The TS surveillance planner responsible for procedure MP 15537.5 was counselled.
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c.
A memorandum has been issued to. plant departmental supervisors responsible for the performance of surveillances identified in procedure O-OSP-200..1.
The requirement for performing TS surveillances within the maximum time interval allowed by TS was re-emphasized.
Corrective steps which will be taken to avoid further violations include:
5.
On January 14,
- 1991, the Turkey Point Site Vice President formed a Task Force to procure and implement a, computerized surveillance scheduling program.
This program willbe used to implement a new centralized accountability for the performance of required surveillances.
The centralized accountability and the computerized surveillance scheduling program are scheduled to be implemented during the current dual unit outage.
Date when full compliance was achieved:
The late surveillance reported in this NOV was completed satisfactorily on November 13, 1990.
FINDING B Technical Specification 6.8..1 requires that written procedures and administrative policies be established, implemented, and maintained in accordance with the requirements and recommendations of Appendix A of Regulatory Guide 1.33.
Appendix A of Regulatory Guide 1.33, Revision 2, dated February,
- 1978, recommends that written procedures be established for typical.
safety-related activities carried out during the operation of nuclear power plants.
Section 1.
b of this Appendix suggests administrative procedures which include authorities and responsibilities for safe operation and shutdown, and Section 2.j of this Appendix recommends general plant operating procedures for plant operation from Hot Standby to Cold Shutdown.
Paragraph 5.1.6 of procedure O-ADM-200,
'Conduct of Operations,'equires all on-shift Operations personnel to be aware of and'esponsible for the plant status at all times.
Paragraph 5.11 of procedure 4-GOP-305,
'Hot Standby to Cold
- Shutdown, requires that pressurizer pressure be maintained within
the range of 325 to 375 psi for the establishment and verification of Overpressure Mitigation System operation.
Contrary to the
- above, on November 26, 1990, while preparing to place the Overpressure Mitigation System into service during the Unit.4
- shutdown, an operator failed to adequately monitor plant status and to maintain pressure within the required range in that pressurizer pressure reached the power operated relief valve (PORV) liftsetpoint of 415 psi and PORV 4-455C inadvertently opened.
RESPONSE
TO FINDING B FPL concurs with the finding.
2
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3.
This event was caused by cognitive personnel error, in that a licensed plant operator failed to maintain RCS pressure within the limits of 325 psig and 375 psig as required by procedure 4-GOP-305, "Hot Standby to Cold Shutdown."
Corrective steps which have been taken and 'the results achieved include:
Upon receipt of, the Overpressure Mitigation System high pressure alert and Overpressure Mitigation System control alarms, the operator immediately reduced pressure manually to.
approximately 350 psig.
The operator responsible for maintaining RCS pressure within the required range during this event has been counseled by Operations management for failure to closely monitor for pressure changes whenever pressurizer spray is changed.
4 ~
Correct'ive steps which will be taken and the results achieved include:
Procedures 3/4-GOP-305 will be revised to caution the operators to closely monitor all RCS pressure indicators to ensure that the proper pressure range is maintained.
A caution will also be added to remind the operators of the small margin between the required pressure range and the PORV liftsetpoint.
The procedure revisions will be completed prior to re-establishing RCS
- integrity during the dual unit outage currently in progress.
RCS integrity is scheduled to be re-established in Unit 3
on September 12,
- 1991, and Unit 4
on
'October 15, 1991.
Date when full~compliance was achieved:
RCS pressure was immediately restored to within the required range up'on receipt of the alarms mentioned above.
5.