ML17354A411

Provides Response to RAI to 10CFR50.54(f) Re Adequacy & Availability of Design Basis Info

ML17354A411
Person / Time
Site:	Turkey Point
Issue date:	02/12/1997
From:	Plunkett T FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-97-26, NUDOCS 9702180360
Download: ML17354A411 (157)

Text

CATEGORY j.

REGULRTQI~ INFQRM((TIQN DIBTRIBUTIQN LITEM (RIDE)

SUBJECT:

Provides response to RAI to 10CFR5.54(f) re adequacy availability of design basis info.

DISTRIBUTION CODE:

A074D COPIES RECEIVED:LTR ENCL SIZE TITLE: Responses to 50.54(f)

Req. for Design Basis Info NOTES:

COPIES COPIES LTTR ENCL LTTR ENCL 1

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1 RECIPIENT ID CODE/NAME CROTEAU,R RECIPIENT ID CODE/NAME PD2-3 PD ACCESSION NBR:9702180360 DOC.DATE: 97/02/12 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 PLUNKETT,T.F.

Florida Power S Light Co.

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

INTERNA PDR 2/THOMASFK EXTERNAL: NRC PDR 1

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1 NRR/DRPM/PGEB 1

1 NOTE TO ALL NRIDSN RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE!

CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN SD-5(EXT. 415-2083)

TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED:

LTTR 8

ENCL

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Florida Power 5 Light Company, P.O. Box 14000, Juno Beach, FL 33408-0420 2/12/97 L-97-26 10 CFR 50.4 10 CFR 50. 54 (f)

U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 RE:

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Request for Information Pursuant to 10 CFR 50.54(f) Regarding Adequacy and The purpose of this letter is to provide the information requested from Florida Power and Light Company (FPL) in NRC letter, (J. M. Taylor to J. L. Broadhead) dated October 9, 1996. Your letter requested information that would provide the NRC with "added confidence" and reasonable assurance that our plants are being operated and maintained within their design bases and that any

. deviations identified are reconciled in a timely manner.

FPL's response was requested within 120 days ofreceiving your letter, i.e., by February 13, 1997.

The current engineering design, configuration control, and corrective action processes are discussed in the Enclosure.

These are active processes that are under continuous change and improvement based on operating experience, the corrective action program, and changing regulatory guidance or interpretations.

The enclosed information forms the basis for our conclusion that plant design bases requirements have been and willcontinue to be translated into operating, maintenance, and testing procedures.

FPL also concludes that system, structure, component configuration, and performance are consistent with the plant design bases, and that Turkey Point has an adequate process for the identification and correction ofidentified deviations. The overall effectiveness ofour current processes and programs provides reasonable assurance that the configuration ofTurkey Point Units 3 and 4 is consistent with the plant design bases.

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Turkey Point Units 1 and 2 Docket Nos. 50-250 and 50-251 L-97-26 Page 2 The Enclosure contains new regulatory commitments which are located in the response to NRC request [fj. In summary, FPL is planning to perform a graded FSAR review over the next 2 years to further address the accuracy ofinformation it contains. This review willcommence following completion of the NEI review effort scheduled forApril 1997.

The enclosed information is provided pursuant to the requirements of Section 182a of the Atomic Energy Act of 1954, as amended, and 10 CFR 50.54(f). The required oath or affirmation affidavit executed by my Engineering Vice President, is attached.

Please contact us should you have any questions on the enclosed information.

Very truly yours, T. F. Plunkett President Nuclear Division TFP/JEK Enclosure cc:

Director, Office ofNuclear Reactor Regulation, USNRC Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant

Turkey Point Units 1 and 2 Docket Nos. 50-250 and 50-251 L-97-26 Page 3 STATE OF FLORIDA

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COUNTYOF PALMBEACH

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Ss.

R. S. Kundalkar being first duly sworn, deposes and says:

That he is Vice President; Engineering, Nuclear Division, ofFlorida Power &Light Company, the Licensee herein; That he has executed this document; that he has read the contents of the attached Enclosure and, in reliance on the processes discussed in the Enclosure and independent oversight of its accuracy, hereby affirms that the statements made in this 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.

R. S. Kundalkar STATE OF FLORIDA COUNTY O ulm Sworn to and subscribed before me this~ day of Ekt'~t, f9' by R. S. Kundalkar, who is personally known to me.

Name ofNot ublic - State of rida

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ROBERTA S. ECONOMY

=a. $ :a! MYCQANSSlON f CC283823 GPIES tune 1, 1997 eONQ iNUTnnY FAiMINJRACE, ue.

Print, type or stamp Commissioned Name ofNotary Public

Turkey Point Units 3 &

4'ocket Nos. 250 and 251 L-97-26 EncIosure Page.l Response to NRC 10 CFR 5094(f) Information Request Adequacy and Availability-ofDesign Bases Information

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 2 Table of Contents 1.0 Introduction...

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NRC Request [a]

"Description of engineering design and configuration control processes, including those that implement 10. CFR 50.59, 10 CFR 50.71(e), and Appendix B to 10 CFR Part 50."................

NRC Request [b]

"Rationale for concluding that design bases requirements, are translated into operating, maintenance, and testing procedures."........

27 NRC Request'[c]

"Rationale for concluding that system, structure, and component configuration and performance are consistent with.the design bases.".. 39 NRC Request [d]

"Processes for identification ofproblems and implementation ofcorrective actions, including actions to determine the extent ofproblems, action to prevent recurrence and'reporting to NRC."......................

54 NRC Request [e]

"The overall effectiveness ofyour current processes and programs in concluding that the configuration. ofyour plant(s) is consistent with,the design bases."

. 64 NRC Request [f]

"Supplemental request forinformation on design review/reconstitution P

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.72 Appendix B - QA Audits, Findings and Corrective Actions.......................

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Turkey Point Units 3 &,4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 3 1.0 Introduction By letter dated October 9, 1996, the Nuclear Regulatory Commission (NRC) requested information to provide the added confidence and assurance that the Florida Power and Light Company's (FPL) nuclear units,'St. Lucie Units 1 and 2 and Turkey Point Units 3.and 4, are operated and maintained within the design bases and that any deviations are reconciled in a timely manner.

The purpose of this enclosure is to provide the specific information requested by the NRC forTurkey Point Units 3 and 4. Although the engineering design and configuration control processes are similar for the St. Lucie and'urkey Point units, their licensing and design bases are different and certain activities associated with maintaining the design bases are plant specific.

Therefore, the requested information for the St. Lucie units. is provided in separate correspondence.

2.0 Response Preparation Upon receipt of the October 9, 1996, request for information, a Management Oversight Committee was appointed to direct the preparation of the response to the NRC. Their first task was the appointment of a multi-discipline working committee to prepare the response.

The committee was composed ofpersonnel from Engineering, Operations, Maintenance,:Quality Assurance, Process Consol, Training, and Licensing. Turkey Point and St Lucie had teams of approximately the same composition. Initialplanning for the response was completed by a combination ofpersonnel from both sites. Afterthe initialidentification of the subject material needed, tasks were assigned to each member of the working group to write detailed responses to the requests and'provide documentation to.the working committee for compilation and verification for the draft report. The majority of the tasks involved the review ofhistorical documents that describe processes and results ofFSAR reviews and DBD development.

Quality Assurance (QA) audits of those efforts, as well as the processes controlling configuration and design control, also were reviewed. 'The response was then finalized and a review process was conducted.

This response was reviewed by knowledgeable management personnel with expertise in the areas discussed in the response.

As discussed above, extensive work has already been done in the area ofFSAR reviews and DBD development.

Continued updates of those documents and the processes controlling change at Turkey Point also have been put in place. An initiative suggested by Nuclear Energy Institute (NEI 96-05, "Guidelines for Assessing Programs forMaintaining the Licensing Basis,") to review the processes for translation of the licensing bases into the various plant documentation is under way.

3.0 Summary of Conclusions FPL has reviewed previous audits, inspections, self-assessments and vertical slice review activities, current engineering design and configuration control processes, plant configuration and performance documentation, and problem identification/corrective action programs at Turkey Point. Based on these reviews, FPL concludes, with reasonable assurance, that the design. bases for Turkey Point are adequate; that the design bases and as-built plant conditions have been

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'Ihrkcy Point Units 3 8t,4 Docket Nos. 250 and 251 I 97-26 Enclosure Page 4 maintained consistent through effective engineering processes; and that the plant corrective action programs adequately identify,and correct exceptions to this conclusion in a timely manner.

Engineering processes and procedures ensure that the as-built plant is accurately reflected in the plant design bases and that plant changes do not erode or compromise safety margins ofrisk-significant systems.

In-depth vertical slice reviews ofactual design basis documentation and its use in plant modifications, procedures, and operation during the late 1980s and early 1990s provide an integrated positive conclusion about the engineering process effectiveness in maintaining the Turkey Point design bases.

FPL is committed to maintaining the integrity of the plant design as licensed, and to plant operations consistent with that license. As such, FPL has learned that the best way to demonstrate conformance with design bases, is through in-depth reviews, and timely correction of identified nonconformances or inconsistencies.

Improved engineering processes result from findings ofreviews of the plant structures, systems and components, and their associated operations, maintenance and testing procedures.

Previous practice which includes responsive actions to deficiencies, in-addition to recently performed'programs and evaluations, provide reasonable assurance that the Turkey Point design bases are adequate and that the plant is configured and operated in accordance with its design.

Exceptions to this conclusion are addressed promptly once they have been identified. In addition, reviews are in process or willbe initiated which willfurther assess, the design documentation at Turkey Point and the programs and processes which control configuration of the facilityin relation to its design bases.

The details of these programs are further outlined herein.

4.0 Historical Background The original Turkey Point Final Safety Analysis Report (FSAR) was submitted to the Atomic Energy Commission (AEC) in the late 1960s. Revisions to the FSAR were submitted throughout the licensing process and continued until after the original AEC Safety Evaluation was issued in March 1972, such that significant original licensing issues were resolved. Similarly, the FPL Topical Quality Assurance Report (TQAR) was originally submitted in the late 1970s, with revisions followingperiodically as prescribed by the regulations.

Subsequently, 10'CFR 50.71(e) was revised in 1980 to require the periodic update of the FSAR.

As part of the update effort, FPL reviewed plant design changes and licensing correspondence for the intervening period from 1973 to 1980 to capture changes to the FSAR. The Updated FSAR (FSAR) was initiallyissued in July 1982, with subsequent updates occurring annually. until 1992.

Since 1992 the periodic updates. have occurred within six months after each Unit4 outage.

These updates were performed primarily by an Architect Engineer (A/E) until 1991 when updating was taken over by FPL.

During the design and construction phase ofTurkey Point, FPL performed project management functions, while the A/E performed the engineering and modification control functions, including original design and'modifications. Following plant upgrades in response to NUREG 0737, a review of the engineering design process,-along with the configuration management process, indicated that the interfaces between the A/E and the plant were not as robust as they were during

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 5 the construction phase and needed to be revised. This was confirmed by an NRC Safety System Functional Inspection (SSFI) of the Turkey Point AuxiliaryFeedwater (AFW) system performed in 1985, where the NRC found violations of the configuration management process.

FPL committed to a Performance Enhancement Program which revised many of the processes as described below.

In the early to mid-1980s, a number ofevents occurred which provided indications that control over the plant's design bases wa's not being maintained in a completely effective manner. In early 1984, several plant trips occurred that were attributed to design changes associated with the AuxiliaryPower Upgrade Project. In mid-1985, the first NRC Safety System. Functional Inspection (SSFI) noted numerous concerns with the design basis of the AFW system at Turkey Point. In late 1985 and early 1986, issues with Emergency Diesel Generator (EDG) Loading were reported by FPL. Significant corrective actions were initiated to correct this situation, including the implementation ofthe Emergency Power System (EPS) enhancement project. This project installed'wo additional emergency diesel generators and associated circuitry.

Based upon inspections in the early 1980s, the NRC reached the conclusion that FPL had not given sufficient management attention to ensuring adherence to regulatory requirements for surveillances, testing, maintenance and operating activities. FPL developed the Performance Enhancement Program (PEP) to address those issues, and additional programs to improve many Turkey Point processes such as a review of the plant against the FSAR. In the later phases of the PEP, an assessment program was instituted to include design bases reconstitution, detailed audits including system walkdowns, comprehensive reviews by the Safety Engineering Group, and assessment of the configuration control program. In addition, a Select System Review (SSR), a design bases rev'iew and in some cases a reconstitution, was conducted on selected systems in the middle 1980s by the Safety Engineering Group (SEG).

In 1989, FPL began to assume the A/E design functions. Engineers were placed in A/E offices to train and work hand-in-hand with the A/E design engineers.

By late 1990, FPL engineering was performing design, production engineering, and design modification functions, with the exception ofmajor projects.

In 1991, the restart from the EPS project included a detailed restart evaluation of the facilityprior to returning the units to power. This restart evaluation was a detailed review of the configuration control process for the EPS portion of the facility.

To respond to the concerns about design bases control, in the late 1980s, FPL implemented extensive improvements in plant. processes and design. bases documentation.

Starting in 1984, FPL engineering implemented an enhanced Engineering Package (EP) process that required, for important facilitychanges, that the appropriate design bases information. be reconstituted to assure an acceptable design change.

Starting in 1985 and continuing until 1989, FPL implemented a design bases reconstitution program for"selected safety related and non-safety related systems at Turkey Point. The output of this process was the issuance of the Turkey Point Design Basis Documents (DBDs) in 1989. The DBDs have since been periodically updated on approximately the same frequency as the FSAR.

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 6 Since 1989, FPL has made improvements to the overall FSAR updating process to enhance its accuracy ofupdating. Each engineering design change or stand-alone evaluation is required to address the impact on the FSAR as part of the engineering change process and include proposed changes to the FSAR with the issuance of each design change package, as applicable. This process provides a comprehensive mechanism for inserting change information into the FSAR and into the DBDs.

During the later stages of the PEP, an extension ofthe SSR included a systematic design investigation which provided a risk based method for setting priorities for the resolution of technical concerns that resulted from the design bases reconstitution project. The concerns were addressed commensurate with the safety significance and associated risk of the particular item.

This program was considered a strength by an.NRC inspection team (NIR 89-203).

During the fallof 1986, FPL requested changes to'the Technical Specifications to make them consistent with the standard Technical Specifications for Westinghouse facilities. The revised Technical Specifications were approved in 1990 with implementation occurring in August of 1991. This.complete revision ofthe Technical'Specifications resulted in an established baseline of recent NRC review of the Turkey Point Technical-Specifications.

In 1991, a configuration management manual was issued which described the on-site design and configuration control responsibilities as well as process requirements for plant design, interfaces, reviews and approvals.

Implementing engineering and'administrative Quality Instructions were developed which represent a complete and definitive set of design and configuration control procedures.

More recent programs such as the Containment Structure Re-analysis, the Emergency Power System upgrade and the Thermal Power Uprate have provided an adequate and,available design bases for systems, structures and components as well as their associated operating, maintenance, and testing procedures.

Due to the evolutionary nature of each of the processes discussed in this response, the descriptions ofthe processes are a snapshot in time. Each of the processes is subject to controlled change consistent with Turkey Point procedures.

5.0 Commitments Turkey Point willcomplete its assessment of the plant processes using the approach outlined in NEI 96-05, "Guidelines'.for Assessing. Programs for Monitoring.the Licensing Basis," which will address programmatic and non-programmatic FSAR changes and assess, four risk significant systems described in the FSAR. Following completion ofthe "NEI"initiative, FPL intends to perform an additional detailed review ofportions ofthe FSAR over a two year period to'identify and correct documentation. discrepancies. Ifthe need is identified as a result of these reviews, a Safety System Functional Assessment willbe completed on an appropriate system or group of systems.

The details of the Turkey Point commitments are included in section [fJ,ofthe Enclosure.

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 7

[a]

"Description of,engineering, design and configuration control processes, including those. that implement 10 CFR 5089, 10 CFR 50.71(e), and Appendix 8 to 10 CFR Part 50."

The followingoutline provides the organization of.the response to request [a].

1.0 Configuration Management Overview 2.0 Detailed Descriptions ofEngineering Design and Configuration Control Processes 2.1 Engineering Design Control Processes 2.2 Configuration Control Processes 3.0 Implementation of 10 CFR 50.59 3'.1 3.2 3.3 3.4 Unreviewed Safety Question Determination Process 10 CFR 50.59 Screening and Evaluation Process The 10 CFR 50.59 Safety Evaluation Non 10 CFR 50.59 Activities 4.0 Engineering Design and Configuration Control Process Training 4.1 Engineering Support Personnel (ESP) Training and Qualification 4.2 Shift Technical Advisor (STA) Training Program 4.3 Nuclear Plant Supervisor (NPS) Training Program 4.4 PNSC Training Program 5.0 10 CFR 50.71(e) Implementation'Process 5.1 FSAR Updates 5.2 Design Basis Document Updates 6.0 10.CFR 50, Appendix B Implementation Process Turkey Point recognizes that maintaining current and accessible design documentation is important to ensure that; (1) the plant physical and functional characteristics are maintained and are consistent with the design bases as required by NRC regulation, (2) systems, structures, and components can, perform their intended functions, and (3) the plant is operated in a manner consistent with the design bases.

Thi's is accomplished, through the Turkey Point Configuration Management (CM),processes, which encompass engineering design and configuration control.

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Turkey Point Units 3 8c 4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 8 1.0 Configuration Management Overview The CM is comprised ofprocesses that are used to control the plant design bases, design, design changes, physical configuration, operations, maintenance, testing, procurement, installation, training and documentation.

The CM program ensures that, throughout the lifeof the plant the foHowing occur:

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Design'bases are identified, documented and maintained.

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Approved design documents accurately reflect and implement the design bases.

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Plant physical structures, systems, components, (SSCs), and process control computer software conform to the approved design requirements.

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Plant physical and functional characteristics are accurately reflected in plant documents.

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Plant conditions conform to the requirements included in the design bases, procedures and other approved documents which are used to control the operation of the plant.

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Changes to the design or physical plant are optimized through an integrated management review, process with established approval criteria to miriimize changes to the design or physical plant.

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Changes to the design are approved, planned, budgeted and scheduled for all phases of the change from design through implementation and document update.

8 Consistency is maintained between design bases, design documents, hardware, software, and plant procedures.

Turkey Point activities which affect the CM goals listed above are controlled by engineering design and configuration control processes.

These processes ensure that the plant design, as-built condition, and operation remain in conformance with the original plant design bases and subsequent licensing commitments.

2.0 Detailed Descriptions ofEngineering Design and Configuration Control Processes 2.1 2.1.1 Engineering Design Control Processes General Description The processes whereby the design.and design bases are maintained and controlled include all plant departments.

The engineering design control processes are controlled under FPL Engineering Quality Instructions'(ENG:QIs).-ENG.QIs are designed in a hierarchical fashion with reference to interfacing instructions. The overall governing ENG.QI for the engineering design control processes is ENG QI 1.0, Design Control. This instruction leads the engineer/designer/user to other governing instructions for maintaining and controlling the plant license, design bases, as-builtdesign documentation,.and operations, maintenance and testing procedures.

e Determination of the appropriate process vehicle to initiate a design change requires the understanding of the scope ofthe proposed change.

The design change process is divided into Plant Change/Modifications (PC/Ms) and Non-Plant. Change/Modifications (Non-PC/Ms).

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-'26.Enclosure Page 9 The PC/M process is further subdivided into major and minor changes.

Major design changes to the plant are controlled under ENG QI 1.1, Engineering Package (EP) and are implemented using the complete PC/M EP process to perform modifications which constitute a change to the facility (physical and/or documentation), requiring a 10 CFR 50;59 safety evaluation.

EPs usually contain detailed implementation and testing information for complex and involved design changes.

Minordesign changes to the plant are controlled under ENG QI 1.2, MinorEngineering Package (MEP) and are implemented using the process to perform minor-modifications which constitute a change to the facility(physical or documentation).but which do not require a 10 CFR 50.59 safety evaluation. MEPs include 10 CFR 50.59 screening to document that a 10 CFR 50.59.safety evaluation is not required.

The Non-PC/M process is used forDrawing Change Requests (DCRs), Item Equivalency Evaluations (IEEs), Non Nuclear Safety (NNS) MinorScope Changes (MSC),, and Maintenance Specifications.

This process is also used for Temporary System Alterations (TSAs), design document updates, minor repairs, and maintenance activities.

2.1.2 Plant Change/Modification.(PC/M) Process For PC/Ms, the engineering design. change control process includes:

Design. Change Initiation Design Change Package Preparation Design Implementation Documentation Updates 2.1.2.1 Design.'Change Initiation A change to the plant design may become, necessary for a number ofreasons, such as new or changing regulatory requirements, equipment reliabilityproblems, obsolete equipment, or operational improvements.

The need for a change can be identified by any, employee at the plant.

When a change'to the plant design is proposed, itmust first be justified by the appropriate, plant department before engineering:may be requested to evaluate the change.

0 A plant modification is usually proposed by using the Request forEngineering Assistance (REA) process.

The REA process, O-ADM-510, Request forEngineering Assistance, can be initiated by any member of the plant staff requiring assistance from Engineering to resolve plant problems, conduct engineering studies, reconcile. discrepancies, and.update design documentation.

This process provides the rough scope, the purpose, the budget, the cost and benefit, the implementing organization, the design/safety significance, and the relative priorityfor a project candidate.

REAs are processed using one oftwo paths: Real-Time Support (RTS) review group for easily implemented projects, and Project Review Board (PRB) management review group for larger or construction intensive projects. Following the issuance of an REA, Engineering performs a scope, schedule and cost estimate for a suggested project, including the evaluation of design options. Ifvarious options are possible, plant input is solicited in order that issues ofcost, simplicity, maintainability usability,.etc. may be factored into the evaluation for the preferred

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Turkey Point Units 3 k4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 10 option. This,initialinformation is used by the RTS or PRB review groups to justify final approval forEngineering to prepare a design package and for the implementor to complete procurement and implementation activities. The review groups are composed ofplant management or their designees who review and approve projects,. authorizing the use of engineering resources both for estimating and designing activities. The review includes consideration of the number ofdesign changes planned for outage and non-outage work period, so that work scope can be scheduled and managed properly. Ifapproved, the REA is forwarded to Engineering for design change package preparation.

2.1.2.2 Design Change Package Preparation The design engineers prepare design changes in accordance with the licensing, design basis, design standards, and configuration management requirements governed by ENG QI 1.0, Design Control, and ENG QI 1.1, Engineering'Package-(EP).

These. procedures. are approved under the QA 10 CFR 50 Appendix B program. Personnel who prepare design changes are appropriately trained and experienced.

The basic steps in the design change process include:

a.

The design engi'neer(s) conducts research and interfaces with the design change sponsor(s) to obtain a fullunderstanding of the design change justification, scope, licensing/design impact, interdiscipline design requirements, affected engineering/operations documentation, etc.

Applicable Operating Experience Feedback (OEF) (lessons learned from other utilities) can be retrieved and factored into designs or design modifications. Engineers stay current with FPL and nuclear industry operating, experience related to engineering activities. NRC Bulletins, Information Notices, other regulatory requirements, internal FPL correspondence related to nuclear design experience,.experience reports received from manufacturers and other industry sources are circulated appropriately. In the development ofa design document, the followingcomputerized information retrieval services are currently available and may'be used to obtain data related to design or

,safety analysis input: OEF,program (FPL), Nuclear Plant Reliability-Data System (INPO) Technical Library Database (INPO), Nuclear Network (INPO), LER database (INPO), NRC Index (INPO), and SERCH/REGIS (Bechtel Database).

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The design engineer(s) identifies and assembles the design inputs that must be considered in preparing. the design or design. change.

Design input is defined as the set ofcriteria, parameters, bases or other information upon which detailed final'design is based.

Design changes are based upon existing design bases documentation.

Design inputs are identified from the followingsources:

FSAR/Technical Specifications

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Turkey Point Units 3 &,4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 11

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Bases Documents (calculations,.diagrams, drawings, design specifications, analyses, studies, vendor documents, DBDs, etc.)

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Condition Reports The design organization performs design integration activities to ensure that all new designs/design changes are consistent with the base plant design, and that consideration is given to related design and design changes in progress.

The design integration activities include a review ofinformation sources such as TSA logs, and abandoned equipment logs. To aid the design integration, electronic information sources which are part of the PassPort database (FPL's computerized. management information system) are also available.

These include the PC/M Index, Calculation Index, Engineering Evaluation Index, and Total Equipment Data Base. This review provides assurance that no other modifications which are in progress can affect the modi6cation package which is being prepared. Alimitis imposed by management on the. number ofmodifications that are processed at the same time.in order to minimize integration difficulties.

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The design engineer(s) performs the detailed design change and prepares 10 CFR 50.59 screening-and/or safety evaluations.

The PC/M defines the scope of the modification and activities associated with the change.

The safety evaluation is a major part of the EP and is required to demonstrate that the provisions of 10 CFR 50.59 safety evaluation are met when performing a design modification. The requirements of 10 CFR 50.59.are a subset of the overall safety evaluation objectives. The safety evaluation addresses the overall safety aspects of the modification including description and purpose of the change, analysis ofeffects on safety, failure modes and effects analysis, effects on Technical-Specifications, Unreviewed Safety Question (USQ) determination, and plant restrictions.

The detailed design effort includes walkdowns of affected systems and components to verify their field configuration and their consistency with plant design drawings.

Design change packages undergo interdisciplinary reviews, i'.e., conceptual, detailed, and final, involving engi'neering and plant. personnel.

When the proposed design is substantially complete, a draft design change package is issued so that input can be solicited'from the appropriate department or group such as Operations, Maintenance, the System and Component Engineers, Health Physics, Plant Change Control (PCC),

etc. The early and final review processes ensure that the design change is understood and meets the design basis, design and operations requirements.

They also ensure that the impact of the design change is reflected in the appropriate plant design documents and procedures, and that the final product willbe acceptable upon. turnover to the

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 I 97-26 Enclosure Page 12 plant. Afterincorporating interdepartmental comments, the design change package is finalized by Engineering.

d; The design engineer(s) and other affected site organizations identify and assemble the documentation affected by.the design or design change for inclusion in the P/CM package.

Documentation is updated and maintained to reflect the "as-built" status of the plant. Responsibility forupdating each type ofdocumentation is assigned to the appropriate department, functional group, or organization.

The. affected design PC/M documents are tracked in FPL's PassPort database to aid in design integration. The types of documents that may be affected include:

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Indices The final design change package is approved and issued by Engineering management and is processed by the plant for.implementation and document control.

2.1.2.3 Design Implementation 0

The design change package is then submitted to PCC. The approved design change package is routed to affected'plant departments for.review and preparation. forimplementation.

The appropriate discipline identifies training requirements and any functional tests required to be performed followingthe modification. The implementing departments prepare work documents, i.e., Plant Work Orders (PWO), which provide step by step instructions forimplementing the design change.

Each affected department identifies revisions to programs, processes, and documents required as a result of the design change.

These revisions are made in accordance with plant procedures ensuring. that.plant'SSCs.are installed and.operated in accordance with established design requirements and plant documentation.

PCC submits the PC/M package to the Plant Nuclear Safety Committee (PNSC), a multi-discipline senior member group, forreview and recommendation to the Plant General'Manager (PGM) for approval. Upon approval by the PGM, the design change may be implemented.

The Company Nuclear Review Board (CNRB) also provides an independent review ofthe design modifications to verify that the change did not constitute a USQ. Both the PNSC and the CNRB reviews constitute Technical Specification requirements for Turkey Point.

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'Dopey Point Units 3 &,4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 13 2.1.2.3.1 Changes to PC/M After a PC/M has been issued forimplementation and prior to final closure, a minor technical change or a documentation change to the PC/M is evaluated. for disposition via the Change Request Notification (CRN) process.

The engineering design organization reviews and resolves CRNs. Ifthe change to the PC/M affects the safety evaluation, design criteria or original PC/M intent, then the PC/M'is revised and the revisions to the PC/M receive the same review as the original PC/M. A special PC/M which is issued periodically and titled "MinorDrawing Enhancements", is used to make administrative changes to design documents.

Each change is processed as a CRN to the PC/M.

2.1.2.3.2 PC/M Closure The Plant Change Control'(PCC) department is the plant organization specifically tasked to supervise processes affecting configuration management and to ensure that the plant design and configuration are maintained accurately.

The implementing department provides the implementing:documents'to PCC as a turnover package.

Formal verification ofcompletion by PCC entails verifying the completeness ofopen items from the implementing department, satisfactory completion ofPC/M requirements including implementation instructions, tests and inspections, and compliance to governing procedures.

2.1.2.4 Documentation Updates Drawings required by Operations for the safe operation ofthe plant are defined by Turkey Point and Engineering procedures as'Plant Operating Diagrams (POD). As part of the PC/M closure process, these drawings and affected plant operating procedures are updated and placed in the Control Room prior to Operations department accepting the modification. The remaining documentation is updated in accordance with approved procedures that define a required timeframe within which the update:process must be completed.

2.1.3',

Non-PC/M Process Non-PC/M processes allow. administrative document updates and equivalent replacements (but not design changes).

The non-PC/M processes, including document updates and.equivalent item replacements are intended. for changes that are outside of the scope of 10 CFR 50.59, but a screening is conducted to ensure the change does not require a 10 CFR 50.59 safety evaluation or Technical Specification change.

The non-PC/M process controls temporary system alterations, equivalent replacements, minor-scope changes, drawing change requests, and design document updates.

These activities are controlled under Engineering and Plant procedures.

e The Temporary System Alterations (TSA) process, O-ADM-503, Control and Use ofTemporary System Alterations, maintains plant and design configuration control for non permanent changes to plant SSCs; while ensuring the applicable technical and administrative reviews and approvals are obtained. The TSA process ensures that personnel are aware of temporary plant configuration and.that TSAs made to.plant equipment do not.unacceptably degrade the original design'intent.

To maintain plant configuration control, the affected drawings are required to be redlined.to

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 14 reflect the temporary plant configuration. These redlined drawings are made available in the Control Rooms, the Work Control Center, Technical Support Center and the Operations Support Center within one day ofthe TSA implementation.

The Item Equivalency Evaluation (IEE) process is used to perform equivalent item replacements requiring implementation that is within the bounds of. a maintenance activity. An IEE is required ifa replacement item is not a like-for-like(identical) replacement for the original item. IEEs determine and document the acceptability of non-identical replacement. items by evaluating form, fitand function. Implementation of the replacement item must fall into the maintenance arena (no modifications or construction), ifnot, the appropriate design change vehicle is required to replace or augment the IEEs.

The Drawing Change Request (DCR) process is used to perform administrative changes to design documents for which there is an approved basis (no physical change or design change).

Typical uses ofDCRs are administrative changes to controlled documents, changes in controlled documents substantiated by IEEs, reflection of as-found conditions in controlled. documents substantiated by a verified Nonconformance Report (NCR) or Condition Report (CR) disposition.

The Non-Nuclear Safety (NNS) Minor Scope Changes (MSC) process is used to perform minor NNS changes in support of maintenance activities (which have a technical relationship or interface with the plant), but do not affect critical piping welds, PODs or plant operating procedures.

A MSC is a change to a plant configuration that is evaluated as equivalent in form, fitand function.

Changes performed under this process constitute maintenance activities and are not considered to be modifications to the plant. The CR process is the mechanism used to initiate MSCs.

Certain engineering specifications referred to as "Re-use", provide generic guidance, instructions and details which can be used as applicable, to process, fabricate, install,-inspect and/or perform maintenance, e.g., replacement/refurbishment, during routine maintenance activities. These engineering specifications are supported by 10 CFR 50.59 safety evaluations ifdetermined to be required. Each specification identifies what activities it addresses.

The appropriate specifications can be invoked within plant documents e.g., PWOs, forroutine maintenance activities. Ifplant Maintenance determines during the implementation of a PWO that the maintenance activity may not'be covered by the engineering specification, an engineering review is required. A Maintenance Request Authorization (MRA)form is used by the PWO implementor to request an engineering review. A Request for Specification Clarification or Change Sheet which is similar to an MRAmay also be used. Engineering screens and reviews the MRAand either approves or disapproves the change requested'by the MRA. Ifthe MRAis disapproved, the design change process is entered, e.g., an REA.may be issued.

2.1.4 Types ofEvaluations When design changes are desired/required the safety evaluation process. is required to demonstrate that safety is maintained in the modification process by preserving the licensing bases. 'There are different types ofevaluations performed by engineering and other qualified personnel for different aspects ofplant support.

These include general evaluations (studies, feasibility assessments, submittal), operability assessment, nonconformance assessment and

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 I 97-26 Enclosure Page 15 resolution, condition assessment and resolution, proposed license amendments (10 CFR 50.90),

probabilistic safety assessment, etc.

2.1.4.1 Stand-Alone Evaluations Stand-alone evaluations are used for meeting 10 CFR 50.59 requirements in which no hardware change is involved, thus an EP may not be required. The stand-alone safety evaluations include a concise description of the proposed change, why the change is necessary, the effect on plant operation and safety, any changes in design or operating practices or philosophy, any restrictions on plant operations, whether a USQ exists or Technical Specification change is involved. The evaluation also describes the licensing requirements including the information normally contained in the design section of an EP and the actions required including short term and long term actions by the plant and/or engineering departments.

The affected documents are identified and the appropriate change package is attached to the evaluation, including a list of applicable documents used in preparation of the evaluation.

These evaluations are submitted to the PNSC for review and recommendation for approval by the PGM. Any action items listed in the evaluation are tracked using the Plant Management Action Item Process (PMAI)process.

2.'2 Configuration Control Processes

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2.2.1 General Description The confi uration control roces g

p ses integrate all plant activities. These processes accomplish the CM process objectives described in Section 1.0 above by defining and documenting the requirements for maintaining the plant's configuration (design, physical plant, and procedures) consistent with the plant design bases.

The governing procedures for these processes are Engineering and Plant'QIs and other applicable plant procedures some ofwhich are listed below:

ENG QI 1.0 ENG QI 1'.1 ENG QI 1.2 ENG QI 1.3 ENG QI 1.4 ENG QI 2.0 ENG QI 2.1 ENG QI 2.4 ENG QI 2.5 ENG QI 3.0 ENG QI 3.1 ENG QI 3.2 ENG QI 3.3'NG QI 3.4 ENG QI 3.5 ENG QI 3.6 Design Control Engineering Package (EP)

MinorEngineering Package (MEP)

Drawing Change Requests (DCR)

Change Request Notices (CRN)

Engineering Evaluations 10 CFR 50.59 Screening/Evaluation Non-Conformance Reports (NCR)

Condition Reports Quality Assurance Records Controlled Document Distribution Drawing Control Vendor Technical Manual Control FSAR Updating Design Basis Document (DBD) Updating Total Equipment Data Base (TEDB)

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 I 97-26 Enclosure Page 16 ENG QI 4.2 ENG QI 6.7 QI 3-PTN-1 QI 4-PTN-1'I 6-PTN-1 0-ADM-059 0-ADM-054 0- ADM-100 0- ADM-102 0-ADM-212 0-ADM-507 0-ADM-515 0-ADM-518 0-ADM-701 0-ADM-737 Procurement Engineering Control FSAR Reviews Design Control Procurement Control Document Control Root Cause Evaluation PMAICorrective Action Tracking Program Preparation, Revision, Review, Approval and use ofProcedures On the Spot Changes to Procedures In Plant Equipment Clearance Orders Processing Safety Evaluations Operating Experience Feedback Condition Reports Control OfPlant Work Orders Post Maintenance Testing 2.2.2 Integration of Configuration Control Processes Configuration Control processes establish the authorities and responsibilities for integrating plant activities which could'affect the, plant configuration. They ensure that the integrity of the design bases is maintained by requiring changes that may impact. the design bases are reviewed by the proper organization.

These changes include physical changes to the plant that may originate through the modification process, or daily operational and maintenance tasks. The design bases, in turn, must be accurately reflected in the engineering, licensing, operating, maintenance; testing, training, and quality assurance documents for the plant with consistency maintained:between these documents in a timely manner.

2.2.2.1 Design, Physical, and Operational Plant Configuration Change Processes The design, change PC/M package preparation activities are performed by Engineering and must account for,affected design and administrative documents.

Design integration reviews are performed to ensure that "open" plant changes in progress do not conflictor compete with the intended new design change.

Relational databases to track change documents and other design integration tools facilitate this design integration review are available. Walkdowns are performed to validate the design change packages against field conditions and in progress design integration activities. As-building of affected documents is automatically triggered. upon completion of a design change package within the relational document control databases.

Part of the design change activities is the procurement control process that provides a mechanism to purchase initialparts and services for PC/Ms, and subsequent stock replacement parts, and a mechanism to ensure only appropriate parts are'bought and made available for plant use.

Plant work is controlled and documented with the'Plant Work Order ( PWO) process.

This process is a mechanism to provide the administrative requirements and work controls for plant work activities on. Safety Related (SR), Quality. Related (QR), and'NNS SSCs, The PWO is the primary implementing, document forPC/Ms. PWOs become the plant's historical'work records.

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 I 97-26 Enclosure Page 17 When work is complete, the information provided in the PWOs is entered into FPL',s PassPort database foreasy retrieval.

Changes to the plant's operational configuration that are not controlled by procedures, are controlled and documented with the clearance process,.O-ADM-212, In Plant Equipment Clearance Orders. This process tracks electronically the removal and restoration ofequipment out of service. The clearance process provides administrative controls that allow for the. isolation ofcomponents for maintenance activities, or for the safety ofplant personnel and equipment.

Each clearance is checked against Technical Specification requirements, and risk significance prior to the issuance of the clearance.

Multiplereviews and checks are performed to ensure that the components are isolated and restored correctly to operable status.

Design changes are required to,be reviewed by interfacing organization personnel knowledgeable in plant processes and configuration, and by system engineers knowledgeable about the affected

'SSCs.

Operations, maintenance and testing personnel perform interface reviews forPNSC affected procedures.

A final review by the Plant Nuclear Safety Committee is performed for safety impacts..

During implementation, any necessary field changes must first be documented and approved by Engineering, via the CRN process before they are implemented.

Post-modification testing requirements are part of the design change package and test results become part of the design change permanent records.

Implementation documents such as temporary procedures, test results, etc., are submitted to PCC for review as an Implementation Turnover package (ITOP).

This package is then used to prepare a System Acceptance and Turnover Sheet (SATS) prior to turnover of the modified equipment/system to Operations.

This system acceptance and turnover process which is used as part of the final design change implementation, requires mandatory approval from all affected plant departments.

High.priority affected documents (operating procedures, PODs, logic diagrams, etc.) receive first priorityfor update upon notification of design change implementation completion. These documents must be updated and available as part of the final system acceptance and turnover (SATS); Training is conducted on design changes and operations procedures,.usually prior to final system acceptance.

2.2.2.2 Procedure. Change Process 0

This,process provides a mechanism.to make procedure changes in a controlled manner.

Procedure changes may,.be either. permanent or temporary.. Procedures and changes to the procedures require as a minimum a 10 CFR'50.59 screening to determine ifthe change is consistent with the FSAR, Technical Specifications or whether a USQ exists. Ifa 10 CFR'50.59 safety evaluation is.prepared for changes to a procedure, the changes are reviewed-by the PNSC.

Procedures required'to be reviewed by Technical. Specification are reviewed by the PNSC.'ew procedures are validated'prior to.use and revised procedures may be validated ifthe change is extensive in nature.

2.2.'2;3 Document Control Process

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Pago 18 The document control process governs the preparation, issuance, and revision ofdocuments such as instructions, procedures, and drawings which describe activities affecting quality. Document control processes ensure that documents including changes, are reviewed, approved forrelease by authorized personnel, and distributed to the responsible individuals/organizations for implementation and use as appropriate.

Databases that identify the most recent approved revision of documents are maintained.

Controls that prevent the inadvertent use ofobsolete or superseded documents are provided. Document control process responsibilities include identifying, storing,

,updating, and retrieving appropriate documents throughout the lifeof the plant. The FSAR and DBD updating processes are described in section 5.1 and 5.2, respectively which addresses the implementation process for 10 CFR 50.71(e) requirements.

2.2.2.4 Quality Assurance Records Records are maintained to provide documentary evidence of the performance ofactivities affecting quality including design activities. Turkey Point QA records are maintained at the Corporate Records Center in Riviera Beach, Florida. Working,copies are available at the site.

2.2.3 Discrepancy Documentation and Commitment Tracking Processes 2.2.3.1 Condition Report (CR) Process The CR process allows plant staff to document, evaluate, analyze and correct conditions of concern.

CRs are initiated for nonconformances and other events or conditions that may appear to be adverse to the safe and orderly conduct ofplant operations.

The CR process is not intended to replace or duplicate the functions ofother Turkey Point programs which provide for identification, disposition and trending ofadverse conditions, e.g., PWOs, REAs. The CR originator delivers the CR to the Nuclear Plant Supervisor (NPS). The NPS reviews each CR for operability and reportability concerns, logs it and forwards it to the PGM. The PGM screens each CR and assigns the investigating group responsible for the investigation, analysis and determination ofcorrective actions ifrequired. The Condition Report Oversight Group (CROG) reviews daily the CRs generated in order to verifyreportability, outage significance, and classification ofcondition. The dispositioning Department Head determines ifthe root cause is adequately identified and ifthe corrective actions are adequate to prevent recurrence.

Closing a CR requires that the PGM accepts satisfactorily completed evaluations. Ifthe corrective actions are not completed within the designated time frame, the remaining open items are transferred to Plant Management Action Item (PMAI)or other tracking system.

2.2;3.2 Nonconformance-Report (NCR) Process The NCR is considered as a subset of the CR process which provides a means for capturing potential or real concerns with respect to the plant, and allows for their correction using other existing and integral plant processes, e.g., the PC/M process, PWO. Nonconformances have historically been addressed using an NCR. The NCR provides a mechanism for documenting the identification of a nonconformance, getting appropriate reviews, and resolving the nonconformance or taking corrective actions. This process is used to collect data for future improvements. Itis a mechanism used by plant members to document nonconforming conditions,

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 19 and itallows engineering personnel an opportunity to critique the design. Engineering evaluates, the NCR.and provides an appropriate disposition (i.e, corrective action, ifany) to the NCR for implementation. An NCR's relatively narrow scope does not provide the flexibilityto address various conditions'that might exist in the plant.

2.2.3.3 Plant'Management Action Item (PMAI)Process The PMAIprocess provides a method for controlling and scheduling corrective actions to meet internal commitments'and ensures followup and closure oflong term corrective actions generated by the CR process.

The PMAIis a tracking system which follows the corrective actions to completion and gives the items visibilitywithin the plant organization.

2.2.3.4 Commitment Tracking Process A commitment tracking process is in place to provide a method ofidentifying and tracking commitments.

Sources of commitments include Licensee Event Reports, Notice ofViolation responses, NRC requirements, INPO or internal audit findings, and NRC safety evaluation reports. The major objective of the process is to assure completion of the commitments in a timely manner.

3.0 Implementation of 10 CFR 50.59 The 10 CFR 50.59',safety evaluation provides assurance that the documented information used and understood by the NRC, as a'basis for licensing the facility,remains valid'in lightof the proposed changes.

FPL uses NSAC 125 as guidance for conduct of safety evaluations and 10 CFR 50.59 screens.

When proposed design changes are desired or required, the 10 CFR 50.59 process determines if the change requires a revision to Technical Specifications or ifthe change constitutes an USQ.

3.1 Unreviewed Safety Question Determination Process Changes to the facility,procedures described in the FSAR, or a test or an experiment not described'in the FSAR are screened for the need to determine ifa USQ exists. This section discusses the definitions of a change, the 10. CFR 50.59 screening process, and the preparation of a formal safety evaluation in accordance with 10 CFR 50.59.

3.1.1 Change to the. Facility Changes to the facilityinclude additions or deletions of SSCs described in the FSAR, modifications which affect design function or method ofperforming a function of a SSC, and temporary modifications.

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Turkey Point Units 3 8h 4 Docket Nos. 250 and 251 L-.97-26 Enclosure Page 20 3.1.2 Change to the Procedures FPL revises procedures as described in the FSAR without prior NRC approval provided the change does not involve a Technical Specification change or a USQ. Procedures:that may require a 10 CFR 50.59 safety evaluation are those that are outlined, summarized or completely described in the FSAR.

3.1.3 Tests and.Experiments Tests and experiments that require a 10 CFR 50.59 safety evaluation are those that are not discussed in the FSAR, but are within the scope of the FSAR, i.e., tests and experiments which could degrade the margins of safety during normal operations, anticipated transients, or that could degrade the adequacy of SSCs to prevent accidents or mitigate accident conditions.

10 CFR

.50.59 safety evaluations are also required for changes to tests or experiments described in the FSAR.

3.2 10 CFR 50.59 Screening and Evaluation Process An evaluation of.a change to the facilityfor,10 CFR 50.59 applicability is made for changes at Turkey Point. This evaluation is referred to as a 10 CFR 50.59 screening.

Therefore,.formal safety evaluations are limited to those changes that fall within the scope and the intent of the 10 CFR 50.59 rule. The applicable procedures to the design change process contain guidance on screening criteria. The followingcriteria are used in screening activities for 10 CFR 50.59 applicability:

1.

Does the change represent a change to the facilityas described in the'FSAR?

2.

Does the change represent a change to procedures as described in the FSAR?

3.

Is the change associated with a test or experiment not described in the FSAR?

4.

Could-the change affect Nuclear safety in a way not previously-evaluated in the FSAR'?

5.

Does the change require a change to the Technical Specifications?

Apositive response to any ofquestions 1 - 4 requires a formal 10 CFR 50.59 safety evaluation. A positive response to question 5 requires a license amendment in accordance with 10 CFR 50.90 prior to change implementation..Furthermore, a design change which requires a change to the Technical Specifications requires NRC review and approval of a license amendment. prior to implementing the change.

3.3 The 10 CFR 50.59 Safety Evaluation For the purpose of a safety evaluation the 10 CFR 50.59 criteria have been expanded into seven questions for clarity:

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Pago 21 Does. the proposed activity increase the probability of occurrence of an accident previously evaluated in the SAR?

Does the proposed activity increase the consequences of.an accident previously evaluated in the SAR?

3.

Does the proposed activity increase the probability ofoccurrence. of a malfunction of equipment important to safety previously evaluated in the SAR?

4.

Does the proposed activity increase the consequence of a malfunction ofequipment important to safety previously evaluated in the SAR?

5.

Does the proposed activity create the possibility of an accident of a different type. that any previously evaluated in the SAR?

Does the proposed activity create the possibility ofdifferent type ofmalfunction of equipment important to'safety than previously evaluated in'the SAR?

7.

Does the proposed activity reduce the margin of safety as defined'in the basis for any Technical Specifications.

Based upon the answers to these questions, a determination is made ifa USQ exists or a Technical Specification change is required. Ifeither exists, NRC review and approval of a license amendment is obtained prior to the change being implemented.

The primary participants in the 10 CFR 50.59 safety evaluation:preparation are as follows:

ao Aproperly trained and qualified preparer develops an understanding of the design bases ofthe plant and applicable regulatory requirements, and is familiar with the concepts and terminology of the 50.59 process.

The design change under consideration typically falls within the preparer's field ofexpertise.

b.

A properly trained and qualified reviewer that has not been participating in the preparation ofthe 50.59 evaluation verifies the acceptability of the safety evaluation.

C.

The PNSC is composed ofmanagers (or designees) representing the functional'an:as of the plant and provides a multi-discipline review of the safety evaluations in accordance with.10 CFR 50.59 guidelines and concurs with the determination that an USQ.does not exist and no Technical Specification change is required.

d.

An offsite safety review board, the CNRB, composed ofofficers, managers, or specialist in design, operations, safety analysis or related activities with extensive nuclear plant expertise is responsible for the review of evaluations prepared according to 10.CFR 50.59 guidelines; The purpose of the review is to confirm the change did not constitute a USQ and no Technical Specification change is requhed.

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 22 e.

Quality Assurance performs periodic audits oforganizations involved in the 10 CFR 50.59 evaluation-process.

Auditresults are documented and reviewed by management having responsibility in the specific areas audited, Corrective actions are documented and followaudits are then performed.

The 10 CFR 50.59 safety. evaluation process is applied to potential design, physical plant and procedural changes. that may impact the plant license, design bases or the FSAR. However, there are changes to the plant which are not governed by the 10 CFR 50.59 requirements and are managed under Turkey Point procedures.

These are referred to as non-10 CFR 50.59 activities as discussed below.

3.4 Non 10 CFR 5059 Activities Plant activities, controlled under. various administrative, engineering, operations and maintenance procedures, which are not normaHy.considered design activities, but which could possibly affect the design bases are screened for 10 CFR 50.59 applicability. Each procedure controlling these activities contains'a requirement to perform a 10 CFR 50.59 screening.

These screenings are performed by qualified personnel trained on the 10 CFR 50.59 requirements.

4.0 Engineering Design and Configuration Control Process Training

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'The training associated with engineering and design configuration and control processes that implement 10 CFR 50.59, 10 CFR 50.71(e), and. Appendix B to 10 CFR Part 50 includes:

4.1 Engineering Support Personnel (ESP) Training and Qualification Initialindoctrination training for engineering support includes a basic review of the plant QIs and procedures'associated with the configuration control process, the plant modification process, the use ofa 10 CFR 50.59 safety evaluation to modify the plant or identify an unreviewed safety question.

Each of the reviews is part of the initialindoctrination training section of the Institute for Nuclear Power Operations (INPO) accredited ESP Training Program for all new Engineering Support Personnel.

The ESP Qualification Guides provide individual qualification requirements.

These qualification requirements are based on an evaluation ofthe individual's education, previous. experience and technical training. The training required for each individual is specified by the department supervisor.

4.2 Shift Technical Advisor (STA)Training Program The STA.is responsible for reviewing CRs for safety issues and procedure changes for applicability to the requirements of 10 CFR 50.59. STAs,are trained on the requirements of 10 e

CFR 50.59 and the requirements of the CR process.

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0 Nuclear Plant Supervisor (NPS) Training Program Turkey Point Units 3 &,4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 23 The NPS training program contains specific lessons on plant modifications, setpoint change responsibility and applying design basis to operations.

4,4 PNSC Training Program A lesson on 10 CFR 50.59 requirements is presented as part ofthe PNSC initialand requalification training. Itis designed to introduce PNSC members and alternates to their responsibilities as related to PNSC review ofprocedure and design changes.

5.0 10 CFR 50.71(e) Implementation Process The engineering design and configuration control processes described in the response to this request detail the activities that ensure the accuracy of the changes which are made to the FSAR.

5.1 FSAR Updates The Turkey Point FSAR, which was originally submitted to the Atomic.Energy Commission (AEC), as part of the operating license application; is maintained and updated in accordance'with the requirements of 10 CFR 50.71(e)(3)(i). Turkey Point Units 3 and 4 share a common FSAR with the update amendment schedule based on the Unit 4 refueling outage.

Amendments reflect FSAR changes up to a maximum of 6 months prior to the date offiling. Special FSAR amendments may.be submitted to the NRC more frequently than the minimum required by 10 CFR 50.71(e)

The primary responsibility for implementation of the FSAR updating process resides within the Turkey Point Engineering Department.

ENG QI 3.4, FSAR Updating, provides the instructions for updating the FSAR in accordance with 10 CFR 50.71(e).

FSAR amendments consider the followingcategories of items implemented; revised, or identified'ince the last amendment:

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Changes made in the facility/procedures as described in the FSAR

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Safety analyses performed i'n support oflicense amendments

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Safety evaluations performed per 10 CFR 50.59

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Safety evaluations performed at the request of the NRC

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New or modified.NRC.requirements

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Changes made to drawings contained in the FSAR

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Commitments made in FPL to NRC correspondence

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Corrections to the FSAR

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Changes to design bases or design criteria identified in the FSAR

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Changes to quality, procedural; test, inspection, or other criteria cited in the FSAR

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Abandoned equipment noted in the FSAR

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 I 97-26 Enclosure Page 24 Engineering design changes are procedurally required to address the impact on the FSAR as part ofthe engineering design change process, and to include proposed changes to the FSAR with the issuance ofeach design change package, as applicable. This process provides a comprehensive mechanism for capturing changes to the FSAR and for their incorporation into the design bases.

Changes to the facilitymay affect the FSAR descriptions and associated accident analyses; Engineering design outputs, e.g., EPs, Stand-Alone Safety Evaluations, which impact the FSAR include an FSAR Change Package (FCP) as an attachment to the document.

FCPs are reviewed, and ifadequate, are incorporated into the next amendment of the FSAR followingthe implementation of the change.

Plant design changes implemented during the update period and all 10 CFR 50.59 safety evaluations are reviewed forimpact on the FSAR. When a change is proposed, the organization initiating the change determines whether the change willresult in the revision of any documents.

Changes to licensing documents can result from design changes, as-found conditions, evaluations, procedure revisions, and NRC requirements.

FPL responses to NRC Information requests, IE Bulletins/Circulars/Information Notices, FPL correspondence to and from the NRC, etc. may affect the FSAR. Incoming and outgoing NRC correspondence is reviewed for impact on the FSAR. Ifan individual determines that an FSAR change is required, an FCP is prepared along with any necessary supporting evaluations.

The intent of the NRC correspondence review is to identify and document NRC requirements that impact the design, operation, or maintenance of the facility,regardless of the level ofdetail associated with the requirement.

Commitments in NRC correspondence to implement physical changes to the facilityare not incorporated into the next FSAR revision. Physical changes are only incorporated after implementation and turnover for use.

Stand-alone safety evaluations that require FSAR changes have an FCP attached.

Engineering reviews stand-alone safety evaluations forwarded by other departments and/or contractors for potential FSAR impact. FCPs are developed as necessary.

The FSAR user comment form, which is proceduralized, permits the FSAR user to identify actual or perceived discrepancies in the content or accuracy of the FSAR. FSAR user comments concerning the content of the FSAR are forwarded to Engineering forreview and incorporation into the FSAR. The FSAR user comment is reviewed to determine ifenough information is provided. In order to be processed for inclusion in an FSAR amendment, the user comment must meet one ofthe followingcriteria:

1) Editorial, such that back-up documentation is not required.

2) Providing sufficient bases, e.g., safety evaluation, PC/M reference, or equivalency justification to show that the desired change has been evaluated and/or analyzed.

Ifthe criteria stated above is not met, the deficiencies are documented on the user comment form and returned to the originator. Ifthe user comment is adequate, it is forwarded to the cognizant discipline forreview and disposition.

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Docket Nos. 250 and 251 I 97-26 Enclosure Page 25 A completed FSAR amendment is reviewed for accuracy and completeness by the appropriate plant departments prior to submittal to the NRC.

5.2 Design Basis Document Updates The Design Basis Documents (DBD) forTurkey Point are updated in accordance with ENG QI 3.5, Design Basis Document (DBD)Updating. The primary responsibility for implementation of the DBD updating, process resides within the Engineering department.

DBD updates consider the followingcategories ofitems implemented, revised, or identified since the last revision:

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Changes to design bases or design criteria identified in the DBDs

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Changes made in the systems/components described in the DBDs

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Safety evaluations performed per 10 CFR 50.59

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Safety evaluations performed in support oflicense amendments

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Safety evaluations performed'at-the request of the NRC

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New or modified NRC requirements

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Commitments made in FPL to NRC correspondence

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Changes made to figures contained in the DBDs

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Corrections to the DBDs Changes to the facilitymay affect the DBD descriptions.

These changes may result from design changes issued by Engineering, Contractors, or other Turkey Point departments.

Engineering design outputs, e.g., EPs, MEPs, DCRs, evaluations, which impact the DBDs include a DBD Change Package (DCP) as an attachment to the document. The level ofdetail and format provided in DBD updates are consistent with the level ofdetail and format contained in the original DBDs.

The review ofNRC/FPL correspondence and stand-alone safety evaluations for impact on the DBD is the same as the method used to review the FSAR updates discussed in Section 5.1. DBD user comment forms are proceduralized and used similar to FSAR user comment forms (see Section 5.1) to identify actual or perceived discrepancies in content or accuracy of the DBDs.

Prior to issuing a DBD update, a review of the revised DBD is coordinated with plant personnel, Nuclear Fuels and other applicable departments.

6.0 10 CFR 50, Appendix B Implementation Process The FPL Quality Assurance (QA) Program is described in the FPL Topical QA Report (TQAR) and is structured to be in compliance with the requirements of Appendix B to 10 CFR Part 50.

0 The TQAR delineates the QA Program requirements and summarizes the FPL approach to activities related to materials, parts, components, systems and services included in the QA Program. The TQAR states that a QA Program be established for design related activities. More specifically, the TQAR provides the general guidance that-the design control program must ensure that the design is defined, controlled and verified, that applicable design inputs are specified and

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Turkey Point Units 3 &4

'Docket Nos. 250 and 251 L-97-26 Enclosure Pago 26 correctly translated into design output documents; that design interfaces are identified and controlled; that design adequacy is'verified.by persons other than those who designed the item; and that design changes, including field changes, are governed by control measures commensurate with those applied to the original design.

The general design requirements described in the TQAR are implemented through QIs. For each applicable criterion in 10 CFR 50, Appendix B, there is a corresponding Engineering and Plant QI or series. of QIs that comply with the criterion in Appendix B.

The design records are developed to provide evidence that the design process and design verification were performed in accordance with the requirements ofTurkey Point's QA Program.

QIs are developed as required by each. of the implementing departments that describe the measures to be used to implement the quality assurance requirements.

QIs describe actions and responsibilities to be performed',within a.department or organization and address the requirements ofthe appropriate TQAR requirements.

QA performs periodic audits of the configuration control processes.

The FPL TQAR requires that audits be regularly scheduled for on-going activities, and the scope ofthose audits include the preparation, review, approval and control of the SAR, designs, specifications, procurement documents, instructions, procedures, and drawings. QIs require a biennial functi'onal area audit of design and configuration control to be performed by QA organization. Design control is also audited during audits ofother functional, areas such as fire protection, fuels, refueling operations, environmental protection, and protection and control. Activityaudits ofspecific design and configuration control issues may be performed at any time. In.addition, reviews of safety related and non safety related SSCs have been performed as part ofaudits and technical reviews. Also, Turkey.Point procedures require that procedures and instructions (including those related to design and configuration control) be reviewed by QA for compliance with the TQAR, and other applicable industry standards and requirements.

TQR 18.0, "Audits," requires that QA AuditFindings be issued to the responsible management of the audited organization, who are required to correct the deficiencies identified in the audit report and take actions to prevent their recurrence.

The, status ofcorrective actions are tracked by QA until the corrective actions have been accomplished and verified.

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Turkey Point Units 3 4 4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 27

[b]

"Rationale for concluding that design bases requirements are translated into operating, maintenance, and testing procedures."

The discussion ofthe rationale. forconcluding that design bases requirements are translated into operating, maintenance, and testing'procedures follows this outline.

1.0 Introduction 2.0 Turkey Point Programs Affecting Design Bases 2.1 Performance, Enhancement Program (PEP) 2.1.1 Procedure Upgrade Program (PUP),(PEP Project 3) 2.1.2 Configuration Control Program (PEP Project 4) 2.1.3 Upgrade, ofthe Turkey Point Technical Specifications (PEP Project 10) 2.2 Design Basis Reconstitution Program 2.2.1 Design Basis Document Development 2.2.2 Design Basis Document Use and Maintenance 3.0 Recent Design Related Projects 3.1 3.2 3.3 3.4 3.5 3.6 Emergency Power System Upgrade Project (EPS)

Upgrade of the Turkey Point Technical Specifications (PEP Project 10)

Containment Isolation Design Basis Setpoint Verification Thermal Power Uprate Emergency Operating Procedure Simulator Verification 4.0 Functional Review'and Verification ofDesign Basis Translation into Procedures 4.1 4.2 4.3 4.4 4.5 Turkey Point Select System Review Turkey Point SWSOPA Quality..Assurance. (QA) Audits Third Party Reviews NRC Inspections 5.0 Conclusion

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Introduction Turkey, Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 28 The rationale for concludi'ng that the Turkey Point design basis requirements are translated into plant. procedures is based upon the. following:

1. 'The design, procedures and plant modifications have been under procedural control since initial operation to assure that changes to the procedures, the design or to the FSAR are consistent.

Procedural control has been further enhanced during the 1990s to resolve issues discovered during the 1980s.

2.

The procedures were verified to be consistent with the plant design, the as-built plant and the FSAR as part ofpreparations forinitialoperation. The original design documents, the FSAR, and the Technical Specifications were used for initialsystem startup and testing. The design, construction and licensing review process and.results from inspections and audits confirmed that the plant was built, began operation, and was controlled by,procedures that reflected the plant as described in the FSAR and the design bases.

3.

The design basis reconstitution resulted in design basis information and'details being incorporated into the.plant's operating procedures.

The design basis document has been in place and maintained since the verification was conducted in the late 1980s.

4.

Quality.Assurance audits and NRC inspections continue to review the processes

for, maintaining procedural consistency and their level ofeffectiveness.

A detailed review of.the Revised Technical Specifications which documented the implementing procedures for operations, maintenance, and testing has been incorporated into. a matrix. The original verification of the matrix and the subsequent procedural control of the matrix ensures the incorporation ofTechnical Specifications requirements are reflected in the procedures.

The Procedure Upgrade Program (PUP) resulted in a complete rewrite ofmost Turkey Point procedures enhancing technical accuracy and availability of current design related information.

The FSAR is a document which describes the plant, its site, and how it functions. It is not intended'as a compilation of.the complete design bases forTurkey Point. The FSAR was produced as part of the original plant design process and received Atomic Energy Commission (AEC) review and approval. Technical Specifications (originally part ofthe FSAR) were developed in conjunction. with.the.AEC review, and identified functional requirements, controlling parameters, surveillance and testing requirements that are significant to the safe operation of.the plant.

Licensing and design reviews conducted in conjunction with the initial startup and testing ofthe plant, confirmed that the plant, as described in the FSAR, was appropriately translated into the original procedures.

Since initialstartup, there have been numerous audits and inspections by Quality Assurance, third parties and NRC which reviewed the agreement between the plant, as modified, and the procedures in use at the time of the reviews. These inspections and audits show

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 I 97-26 Enclosure Page 29 that the configuration control process has incorporated design basis changes resulting from plant modifications into the procedures.

A Performance Enhancement Program (PEP) included a procedure upgrade program, and a design basis reconstitution program as well as the other programs discussed below, further supports the rationale that the design basis requirements are translated into the operating, maintenance, and testing procedures.

Projects have recently been implemented at Turkey Point which have served to verify that the configuration control process has been effective in maintaining the procedures.

The Emergency Power Systems (EPS) project modified the emergency electrical distribution system at Turkey Point and the procedures controlling that system. The revised Technical Specifications resulted in a review and in many cases a rewrite of plant surveillance procedures.

An FSAR self-assessment and operational review was conducted in 1995 and 1996, to identify inconsistencies between the plant operation and design and'the description in the FSAR. The Thermal Power Uprate project resulted in a reanalysis. ofmost of the accidents assumed in the FSAR and a subsequent reflection of the changes into the plant's procedures.

2.0 Turkey Point Programs Affecting Design Bases The followingprojects support the rationale that the procedures reflect the design, bases.

The PEP resulted in a design reconstitution for selected systems which, during the Procedure Upgrade Program (PUP), was incorporated into approved plant procedures as appropriate.

Another part of the PEP enhanced the configuration management by procedurally controlling many ofthe processes.

The-total revision of the Technical Specifications and the correlation of the procedures with the revised Technical Specifications during the pre-implementation phase ensured that procedures were in place to implement the revised Technical Specifications.

The projects discussed below further enhance our conclusion that the Turkey Point design bases is current and that the procedures reflect those design bases by virtue of the processes described in the response to request [a] above.

Performance Enhancement Program (PEP)

As a result ofvarious NRC inspections and an NRC Safety System Functional Inspection (SSI) of the AuxiliaryFeedwater System, the NRC reached the conclusion that FPL had not given sufficient management attention to ensuring adherence to regulatory requirements for testing, surveillances, maintenance, and operating activities at Turkey Point. Turkey Point developed the PEP to not only address the NRC concerns but to additionally consider the improvements of many diverse Turkey Point controlling.processes.

The. NRC issued Confirmatory Order EA 84-55, subsequently superseded by EA 86-20, requiring FPL to proceed with the PEP. In addition to a review of the plant against the FSAR, the followingPEP projects were initiated which upgraded the configuration control processes:

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Project 3 - Turkey Point Procedure Upgrade Program (PUP).

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Project 4 - Turkey Point configuration control program.

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Project 10 - Implementation of Revised Technical Specifications.

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 30 2.1.1 Procedure Upgrade Program (PUP) (PEP Project 3)

PEP Project 3 was the Turkey Point PUP project developed to improve the existing procedures and to implement a more human factors oriented procedure format. Structured revision controls were implemented to assure technical accuracy with respect to system design bases and to assure compliance with Technical Specifications, technical standards, and NRC regulations.

The updated controls and processes have continued to focus on procedure accuracy and usefulness.

That focus provides assurance that the design basis is translated into Turkey Point procedures.

2.1.2 Configuration Control Program (PEP Project 4)

PEP Project 4 was designated to enhance the Turkey Point configuration control processes.

The objective of this project was to implement a process to better manage the Plant Change and Modification (PC/M) process and control how procedures are changed to reflect the changes made in the plant. 'Thereby, the PC/M process has aided in the incorporation and control of design and document changes including assuring. the transfer of design information into.the appropriate procedures.

2.1.3 Upgrade ofthe Turkey Point Technical Specifications (PEP Project 10)

During the fallof 1986, FPL applied for a change to the Technical Specifications which upgraded the Technical Specifications to what was the current standard for the Technical Specifications. for Westinghouse facilities. A detailed review and verification process for this PEP project resulted in approval ofthe new Technical Specifications and implementati'on in August of 1991. For more detail see section 3.2 of the response to this request.

2.2 Design Basis Reconstitution Program In the middle 1980s, the PEP program was instituted-to enhance the design bases to include a design basis reconstitution for the most important safety related and non-safety related systems.

The program resulted in the development of the Design Basis Documents (DBDs) for selected systems and other'licensing basis information. The objective of the DBD program was to satisfy commitments made to the NRC regarding Turkey Point configuration control and to provide a collation of.the Turkey Point design basis information and a standard, well-defined, and controlled interpretation ofthe design bases for selected systems and licensing issues forTurkey Point.

2.2.1 Design Basis Document. Development A total of 18 systems, plus selected licensing issues, were selected for.reconstitution ofdesign bases.

FPL retained'Bechtel and Westinghouse to prepare the documents, and assigned scope based on their original plant design responsibility. The design basis document details and initial preparation responsibilities are listed in the response.to request [c], section 2.4.1.

As a result ofperforming the DBD reconstitution, several procedure problems were identified.

Two prominent items included discovery:of procedures that allowed too much time without safety

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Turkey Point Units 3 k,4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 31 injection flow during switchover to cold leg recirculation. Also, the DBD reconstitution found improper testing of.the steam generator low-lowlevel auto start relays for the Auxiliary Feedwater pumps. The only corrections needed were revisions to the procedures.

These procedures changes were made in accordance with the procedure revision process.

The design basis reconstitution effort also discovered the residual heat removal (RHR) recirculation line was not designed to assure adequate flowfor each of two pumps. This potential inadequate flowcoupled with a single failure of the other operating RHR train could potentially have resulted a in complete loss ofRHR pump capability. The recirculation flowpath for the RHR pumps was an original design of the plant. Plant modifications, procedure changes and training were completed to resolve this discrepancy.

2.2.2 Design Basis Document Use and Maintenance The design basis document provides a means for facilitating,the search and retrieval of source documents.

The document explains each system design and provides a definition ofbases for the design, component design constraints, and design features for addressing selected licensing issues.

The DBDs also provide a useful tool for design engineering to support plant modifications and operability evaluations.

Maintenance of the DBDs is performed withinFPL's Engineering Department and is upheld as vital to assuring design and configuration control ofthe plants. The DBDs have enhanced the ability ofpersonnel responsible for the transfer ofdesign basis information into the procedures at Turkey Point, and to ensure the accuracy of the information in those procedures.

Both the FSAR and the'DBDs are essential in the design and design modification processes, since they provide a valid source of design basis information for translation into,procedures; The DBDs are updated with approximately the same frequency as the FSAR.

3.0 Recent Design Related Projects Each of the followingprojects reconstituted design basis information. The procedures that

,controlled the systems involved were revised to reflect the system and design changes.

The processes described in response to request [a] ensured that the design characteristics were translated into the procedures.

3.1 Emergency Power System Upgrade Project (EPS) 0 In late 1985 and early 1986,.issues-with Emergency Diesel Generator (EDG) loading were reported by FPL (LER 250/85-042) and significant corrective actions commenced to correct this situation,,including ultimately the implementation of the EPS enhancement project. The EPS project included the review and establishment of the design basis for the new emergency electrical distribution system and the installation of the new emergency diesel generators.

The project established a new design'baseline for these systems.

Procedures were substantially revised to reflect the new system and its configuration.

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'Ibrkcy Point Units 3 R,4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 32 3.2 Upgrade ofthe Turkey Point Technical Specifications (PEP Project 10)

During the fallof 1986, FPL applied for a change to the Technical Specifications which upgraded the Technical Specifications to what was the current standard for the Technical Specifications for Westinghouse facilities. A detailed review and verification process for this PEP project resulted in approval of the revised Technical Specifications and implementation in August of 1991. Prior to the transition from the original Technical Specifications to our current Technical Specifications, a line by line review was performed by licensing, operations and maintenance personnel, and a matrix was developed, and proceduralized (0-ADM-218) to document how the specifications were implemented in the plant procedures.

The Technical Specification implementing procedure matrix development process identified areas that required procedure development to address new specifications. In areas where duplication existed in procedures, the matrix identified areas allowing the deletion ofredundant procedures.

Additionally, the matrix facilitates the identification ofprocedures in need ofrevision as the Technical Specifications are revised.

Containment Isolation Design Basis I

In 1989, FPL identified discrepancies between the existing design basis documentation and the FSAR description of the features ofeach containment penetration.

The description of the configuration ofeach of the penetrations and the valves which comprise the containment isolation function was documented.

This penetration'by penetration review effort was successful in reconciling the penetration configurations, DBD and FSAR, and revisions to the implementing procedures for operation, maintenance and testing of these penetrations.

3.4 Setpoint Verification From 1991 to 1993, FPL performed an instrument setpoint review for the Turkey Point plant to document the current setpoints. This program incorporated the instrument setpoint change process. into the configuration control processes and documented or recalculated instrument setpoints.

Prior to this effort, instrument setpoint changes were governed by a separate procedural process.

In order to place these instrument setpoints under engineering control, in the configuration management process, an instrument setpoint list was prepared.

The setpoint list contains both process units and the calibration units. In addition, any special maintenance requirements are noted. This'list is a controlled engineering drawing that consolidates instrument setpoints (both safety related and non-safety related), with their vital performance characteristics and reference documentation into one document.

This setpoint effort provides a basis,to conclude that the current plant setpoints are translated into plant documents and that the design bases for these setpoints are available.

3;5 Thermal Power Uprate In December of 1995, FPL provided'analyses to the NRC justifying an increased thermal power rating forTurkey Point Units 3 and 4 from 2200 Megawatts thermal to 2300 Megawatts thermal.

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 33 This resulted in numerous changes to the plant's design bases.

The majority of the potential accidents discussed in Section 14 of the FSAR were reanalyzed.

Major sections of the FSAR were revised and willbe distributed in the near term. The DBD has also been revised. Technical Specification changes were approved by the NRC and implemented in the fallof 1996.

To implement the power uprate in 1996, many procedures were revised and instrument setpoints were changed to reflect the new design numbers.

3.6 Emergency Operating Procedure Simulator Verification The plant reference simulator is a major contributor in the validation of the Turkey Point Emergency Operating Procedures (EOPs). This validation process is used to fine tune EOP revisions. The Training Department assists th'e Operations Department in validation of procedures by use during the simulator portion ofLicensed Operator Continuing Training. The draft procedures are provided to'Training by the Operations Department and the,-feed back from the crews in the simulator is forwarded to the Operations Department for consideration for inclusion into the procedures.

In early 1996, Engineering completed an electronic text search and review of the DBDs to verify that design information contained within the DBDs which identified the requirement foroperating procedure controls had been correctly translated in plant procedures.

Each identified procedural requirement was researched to identify the specific plant procedures that had been written or revised to contain the required information. In each reviewed case, the requirement to include design information in the appropriate procedure was met. This review provided reasonable assurance that this type of design information had been correctly incorporated into plant procedures including the EOPs.

4.0 Functional Review and Verification ofDesign Basis Translation into Procedures 4.1 Turkey Point Select System Review During the late 1980s, the Safety Engineering Group (SEG)was involved in the select system review which was conducted on mitigating and support systems.

The mission of the SEG group was to discover, assess and report conditions ofnuclear safety significance including procedures, and to make recommendations for action to the cognizant disciplines, departments, or organizations.

Recommendations resulting from these reviews included emphasis on accountabilities and management self-assessment.

The SEG function is now met by QA and other Turkey Point nuclear organizations.

4.2 Turkey Point SWSOPA A Service Water System Operational Performance Self-assessment (SWSOPA) was initiated by FPL at Turkey Point in 1995. This assessment identified two design basis related issues as Unresolved Assessment'Questions'(UAQ).

Both issues related to the level ofavailable documentation dealing with the initialplant design.

Some procedures were enhanced and a new off-normal operating procedure was generated to better deal with influxofgrass from the cooling

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 34 canal system. The level ofdocumentation was considered to be typical for a plant licensed in the early 1970's. Well documented design features provided additional assurances that actual design deficiencies did not exist. Each of the UAQs was resolved.

The self-assessment final report was provided to the'NRC in July of 1995, and a follow-up NRC inspection is currently scheduled for early February, 1997.

A conclusion of the self-'assessment was that the Intake Cooling Water (ICW)'and Component Cooling Water (CCW) operating, alarm response, off-normal, and emergency procedures were adequate in maintaining the system configuration and function.

4.3 Quality Assurance (QA) Audits 4.3.1 Engineering Design Audits QA has conducted audits of.procedures on a regular basis; The subject ofmany of the audits is the review of engineering design packages and how they control procedure changes.

For example, an audit of'a system includes a review of the recent significant modifications performed on the'system,.how the modification affects procedures, and how those procedure changes are controlled.

The rationale for concluding that design bases requirements are translated into operating, maintenance, and testing procedures is based upon multiple system reviews conducted by the QA Department since 1988.

As part ofsystem reviews. by QA, the applicable FSAR sections, and'if available, the DBDs were reviewed. The associated maintenance, operating, and test procedures and their records were also reviewed. Use of the procedures are often checked on a real time basis.

Based upon these reviews, by and large, the procedures were found to be compatible. with their FSAR/DBD descriptions and were also found functionally. able.to be implemented.

Several findings were documented and/or CRs were issued as a result of audits with respect to translating design bases into procedures.

They were considered minor in nature and did not affect the conclusions regarding strengths.

Some of the examples included seismic boundaries indicated on drawings in the wrong location, FSAR setpoint note wording misleading, and FSAR wording stilldescribing the operation of abandoned equipment.

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Turkey Point Units 3 &4 Docket Nos. 250 and 251

.L-97-26 Enclosure Page 35 Each of these deficiencies has been resolved. An abandoned equipment. program is methodically removing the equipment form service using the PC/M process. described in the response to request [a] above.

For details of these and other QA audits see Appendix B.

4.4 Third Party Reviews 4.4.1 Revised Technical Specification Review A review was completed in 1991, by an independent contractor. of the Technical Specifications surveillance requirements versus the implemented surveillance procedures.

No substantive issues were found.

4.4.2 EPS Procedure Revisions and Reviews During the EPS project, a contractor was designated to revise procedures being changed for the electrical modifications being made to the plant. The results of these revisions, the plant review of the revisions, and the many NRC inspections provide assurance that the transfer of the design information into the procedures was adequate.

During 1987 and 1988, an effort was undertaken to update and/or create detailed maintenance procedures for.plant equipment at Turkey Point Units 3 and 4 that are required to be environmentally qualified per 10 CFR 50.49. This effort encompassed over 284 pieces of equipment and 81 procedures.

The intent of this effort was to ascertain whether existing FPL procedures and programs were properly maintaining the EQ equipment in the correct condition.

This verification effort was conducted in two phases.

The first phase was a detailed document review to establish the required installed condition for each type ofequipment on. the EQ List. This effort included the review ofmanufacturers'endor Manuals, Environmental Qualification Document Packages, FPL Maintenance Procedures, Vendor Technical Publications, NRC Notices and Letters, and NRC EQ Inspection Reports. As a result, the required installed configuration was determined.

The required physical characteristics were captured on a field walkdown checklist which was used'to verify the installed condition for each type of equipment. The review identified errors and inconsistencies among the various documents and procedures.

These. items were forwarded to the responsible departments at Turkey Point and corrective actions were completed.

The second phase of the program is discussed in. section 4.2.1 of the response to request [c]. This phase was a comprehensive walkdown to check each piece ofequipment against the requirements t

identified in the first phase.

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0 4.5 NRC Inspections Turkey Point Units 3 &,4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 36 The followinglist is not used as a primary source for providing rationale for concluding that design bases requirements are translated into operating, maintenance, and testing procedures.

The list ofNRC inspections in the area ofdesign are provided here as a reference for docketed information on this subject.

4.5.1 EOP Simulator Verification NRC inspection report NIR 89-53 included an NRC evaluation of selected EOPs on the simulator. Some weaknesses in the process ofmaking transitions from one procedure to another during simulator training sessions were identified. Turkey Point has procedurally corrected these weaknesses.

Overall, no violations or deviations were found.

4.5.2 DBD Inspection Results The depth, breadth:and quality of the DBD was noted by the design validation inspection team (NIR 89-203). Some weaknesses were noted in the area of the breadth ofverification of the DBD and in errors found in the Component Design Requirements Documents (CDR) which are part of the DBD documentation.

Some weaknesses were also found in some system procedures.

The DBD documentation was enhanced as part of the final drafts of the DBD and procedures were revised to reflect the NRC noted weaknesses.

4;5.3 Turkey Point Design Basis Validation Inspection (Configuration Control Program, PEP 4, Inspection)

NIR 89-203, documents the NRC inspection conducted at Turkey Point which used the Safety System Functional Inspection (SSFI) format on three systems to review the implementation of the PEP actions.

The, focus of. this portion of the inspection was on PEP Project 4 (Configuration Control Program). The inspection was conducted by performing SSFIs on reactor protection, component cooling and electrical distribution systems.

The inspection team identified a number of concerns (some of which involved operating procedure documentation ofvalve lineups) which were resolved and closed in a later inspection report and several strengths which were attributed to the PEP.

The strengths identified in the area ofplant modifications found that the more recent PC/Ms sampled were of generally high quality. The PC/Ms sampled were ofa population that were generated after the implementation. of the changes made by the PEP. The weaknesses were technical errors in some of the PC/Ms generated by Architect Engineers (A/E's). This was attributed to a lack ofsufficient FPL technical oversight. The technical oversight ofvendors has been strengthened since that inspection especially in the area ofvalidation and verification.

I 4.5.4 NRC PEP Inspection Results The overall PEP was closed by the NRC as part of the closure ofNRC Confirmatory Order EA 86-20, on August 13, 1992. The NRC cited improved equipment reliability,effective quality and

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 37 safety assessment, and successful completion of and recovery from the dual-unit.EPS modification project. The restart from the EPS project included a detailed restart evaluation ofthe facility prior, to returning the units to'power. This detailed evaluation. of the configuration control process for;the facilityincluded the translation ofdesign requirements into the plant procedures.

The i'nspection aided in reaffirming that the design bases are reflected in the Turkey Point procedures.

4;5.5 SWSOPA NRC Inspections An NRC inspection-(NIR 95-08) of the SWSOPA was conducted in March,,1995 during. the third week of the initialfour-week inspection. This NRC inspection resulted. in comments on the conduct of. the self-assessment, and an extension of-the self-assessment period to include CCW, but did not result in the identification ofany procedure related violations or deviations. The FPL SWQPI Self-assessment final report was provided to the NRC in July of 1995, and a follow-.up NRC inspection is currently scheduled forearly February, 1997.

4;5.6 ISI/IST Inspection History NRC'inspection report 94-11, discussed an unresolved'item dealing with an incorrect inservice inspection (ISI) of branch line connections to the reactor coolant system.

The incorrect inspection ofthe branch line connection was discovered during a refueling outage by an ISI technician.

Procedures. controlling that test originally written,by the A/E were revised and the inservice inspection was conducted correctly during the followingrefueling outage.

NRC.inspection report 94-08, documents an NRC inspection in the areas ofISI and flow accelerated corrosion. The inspector determined'that nondestructive test examiners conducted conservative exams in accordance with appropriate test procedures and that nondestructive

. examination procedures were good.

NRC inspection report.94-07, in part, covered the inservice testing (IST) program of main, steam safety valves. The inspection findings included a procedural deficiency which did'not direct personnel'to use.the. CR.process to resolve an issue such as a safety valve found to have failed ASME Section XIcriteria. The inspector also noted that. the procedures did not require the recording of a satisfactory or unsatisfactory test result. The procedures were revised to include

.the requirement to file a CR upon a Section XIfailure and include the requirement to document the test result as satisfactory or unsatisfactory.

4;5.'7'ntegrated:Inspection Reports Two ofthe NRC inspections conducted during 1996 resulted in verification by the i'nvolved inspectors that, in those areas inspected, the FSAR wording,was consistent with'the observed plant practices and procedures (NIR 96-01 and 96-03). However, some minor inconsistencies were found during, the NRC.inspection as documented in NIR96-04. These inconsistencies have either been resolved in the October 1996 update of the FSAR.or willbe included in the next regularly scheduled update.

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Turkey Point Units 3 8t, 4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 38 5.0 Conclusion There is adequate rationale for concluding with reasonable assurance that the operations, maintenance, and testing procedures at Turkey Point are consistent with the design and that discrepancies between design documents, the FSAR, procedures and the plant are.not significant with respect to safety based upon the facts that:

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The verification at initiallicensing of the plant, FSAR and the design are consistent.

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The processes in place assure that consistency is maintained.

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Various recent major modifications have aided in establishing a reconstituted bases for many plant systems and the translation of those bases into the procedures.

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The various audits, inspections, and self-assessments have verified consistency of design with the plant and its translation into the procedures.

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Processes have been and are in place for identification, evaluation and correction of discrepancies:between the design and the plant procedures.

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Turkey Point Units 3 k,4 Docket Nos. 250 and 251 L-97-26 Enclosure Pago 39

[c] "Rationale for concluding that system, structure, and component configuration and performance are consistent with the design bases."

The followingoutline provides the general organization of the response to the request.

1.0 Introduction 2.0 Design Basis Programs 2.1 2.2 2.3 2.4 2.5 2.6 Process Improvement Programs Design Basis Reconstitution Program Containment Isolation Documentation Containment Structural Analysis Motor Operated Valves (MOVs) GL 89-10 Surveillances 3.0 Recent Design Related Projects e

3.1 3,2 3.3 3.4 Setpoint Program Emergency Power System (EPS)

Revised Technical Specifications (RTS)

Thermal Power Uprate 4.0 Turkey Point Walkdowns 4.1 4.2 4,3 4.4 4.5 4.6 4.7 Programmatic Walkdowns Special Walkdowns Quality Assurance Audits/I'echnical Reviews Third Party Reviews Service Water System Operational Self-assessment (SWSOPA)

Select System Review NRC Inspections 5.0 Conclusion

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Turkey Point Units 3 Ec 4 Docket Nos. 250 and 251 L-97-26 Enclosure Pago 40 1.0 Introduction The rationale for concluding that the Turkey Point system, structure, and component (SSC) configuration and performance is consistent with the design bases is based on the following:

1.

The plant configuration was verified to be consistent with the plant design information and the FSAR as part ofpreparations for initialoperation. The original design documents,.the FSAR, and the Technical Specifications were used for initialsystem startup and testing. The design, construction and licensing review process and results from inspections and audits confirmed that the plant was built and began operation in the configuration that reflected the plant as described in the FSAR and the design bases.

2.

The design, plant configuration and plant modifications have been under procedural control since initialoperation to assure that changes to and operation. of the plant are consistent with the design and the FSAR. As a result the identification for the need for increased management attention ofconfiguration control processes, the PEP, discussed. in the response to request [b], was implemented to enhance those processes.

3.

Routine audits, inspections and vertical slice reviews have continued to confirm that the processes for maintaining consistency of both configuration and performance are effective.

4, Quality Assurance audits and NRC inspections followthe level of effectiveness of the processes formaintaining SSC consistency.

The original design process produced'design documents such as drawings, specifications, evaluations, and analyses. necessary to support construction, testing, operation and initiallicensing of the plant. The design documents produced by this process were used as the bases for system startup and acceptance testing. The design and construction review process included various inspections, audits and documentation requirements to assure consistency between SSC construction and design.

The FSAR was produced as part of the original plant:design process.and submitted to the Atomic Energy Commission (AEC) forreview and approval. The FSAR includes sufficient descriptions ofthe plant's design and procedures to document compliance with regulatory requirements and regulatory guidance. AEC review of the original FSAR resulted in numerous amendments prior to plant operation to document. plant. configuration. Technical Specifications were developed in conjunction with the AEC.review, and identifies functional requirements, controlling parameters and surveillance and testing requirements that are significant to the safe operation of the plant.

APerformance Enhancement Program (PEP), which included a design basis reconstitution program as well'as other programs discussed below, supports the rationale that system, structure, and component configuration and performance are consistent with the design bases.

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 41 A number of-major projects have recently been implemented at Turkey Point which also have served to provide reasonable assurance that the configuration control process has been effective in maintaining the plant configuration in accordance with its design bases.

The Emergency Power Systems (EPS) program modified the emergency electrical distribution system at Turkey Point.

The revised Technical Specifications resulted in a review and in many cases a rewrite of many of the plant surveillance procedures to assure the operation of the facilityin accordance with its design. The'Thermal Power Uprate project resulted in a reanalysis ofmost of the accidents assumed in the FSAR and a subsequent reflection ofthe changes into the plant's configuration and operation.

In addition, since initialstartup, there have been numerous audits and inspections by QA, NRC and third parties which have reviewed the agreement between the plant configuration, as modified, and the design bases. at the time of the reviews. These inspections and audits have provided reasonable assurance that the configuration control process has'incorporated design basis changes into the plant configuration and its operation.

2.0 Design Basis Programs The followingprojects support the rationale that the plant configuration and operation reflect the design bases.

The PEP resulted in,a design reconstitution for selected systems which reflected the as-built plant and its design basis. Another part of the PEP enhanced the configuration control program by procedural control of.many of the plant modification processes.

The total revision of the Technical Specifications and the correlation of the procedures with the new Technical Specifications during the preimplementation.phase, ensured that procedures were in place to assure correct operation ofTurkey Point in accordance with the new Technical Specifications.

The additional projects discussed below further. enhance our conclusion that the Turkey Point design bases are current and that the configuration of the plant and its operation reflect that design bases.

The plant configuration and the operation in accordance with the design is maintained by,the configuration control processes described in the response to request [a] above.

2.1 Process Improvement Programs 2.1.1 Performance Enhancement Program As a result ofvarious inspections'and a Safety System Functional Inspection (SSFI) of the AuxiliaryFeedwater System which occurred during the mid 1980s, the NRC reached the conclusion that FPL'ad not given sufficient management attention to ensuring adherence.to regulatory requirements for testing, surveillances, maintenance, and operating activities. FPL developed the PEP to not only address those issues but also additional programs to improve many Turkey Point processes.

The NRC issued Confirmatory Order EA 84-55 subsequently superseded by EA 86-20, requiring FPL to proceed with the PEP. Areview of the plant's configuration against the FSAR and the projects outlined below were beneficial to the processes which ensure the translation ofthe design basis into the SSCs.

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Turkey Point Units 3 k. 4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 42

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Project 4 - Turkey Point configuration control program.

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Project 10 - Implementation of the Revised Technical Specifications As part of a later phase of the PEP, an assessment program was instituted to include design basis reconstitution of selected safety related and non-safety related systems and an assessment of the Configuration Control Program. Detailed inspections including system walkdowns, comprehensive reviews, and a Select System Review, were conducted on thirteen systems in the middle 1980s by the Safety Engineering Group (SEG).

2.1.2 Configuration Control Program (PEP Project 4)

PEP Project 4 was designed to enhance the Turkey Point configuration control program, The objective. of this project was to implement a process to better manage the Plant Change and Modification (PC/M) process thereby preventing negative impact on plant safety or control.

Changes to the configuration control process, and the implementation of the formal Engineering Package (EP) process, resulted in improvements to the design modification controls. The changes to the SSC design requirements are captured as part ofthe design change package.

Responsible technical personnel review the impact of the design modifications on the SSC and take appropriate. actions to update the configuration baseline.

This process ensures that the performance requirements for the SSC reflect design changes made in a PC/M.

2.1.3 Implementation of the Revised Technical Specifications (PEP Project 10 )

The revised Technical Specifications upgraded the Technical Specifications to what was the current standard for Westinghouse facilities. A detailed review and verification process for this PEP project resulted in approval of the new Technical Specifications and their implementation in August of 1991. For further details on the Revised Technical Specifications see section 3.3 of the response to this request.

2.2 Design Basis Reconstitution Program In the middle 1980s, a PEP assessment program was instituted to enhance the design basis program to include a design basis reconstitution for selected systems.

The product of this program was a Design Basis Document (DBD) for the selected systems and other licensing basis information.

The DBDs have enhanced access-to the design basis information and assures that personnel responsible for the modification ofTurkey Point SSCs have correct design basis information available for their use. This applies to both the modification of the SSC and the ultimate performance parameters ofthe SSC.

2.'2.'1 Design Basis Document (DBD) Development Design basis documentation to support the Turkey Point configuration existed prior to the development of the DBD. However the information was not always readily retrievable and in

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 43 certain cases the information was not'sufficient to provide a complete. logic trail to explain the configuration. The use and application of the information depended on case by case interpretation. The design basis reconstitution program consisted ofestablishing from existing source documents the design requirements for the SSCs.

A total of 18 systems, plus selected licensing issues, were chosen for the reconstitution ofdesign bases.

Bechtel (B) and Westinghouse (W) prepared the DBDs. The design basis documents and initialpreparation responsibilities are listed below:

AuxiliaryFeedwater System (B)

Chemical and Volume Control System (W)

Component Cooling Water System (W)

Containment Isolation Features(B)

Containment Spray System (W)

Emergency AC Power (B)

Instrument AirSystem (B)

Intake Cooling Water System (B)

Area Radiation Monitoring System (B)

Process Radiation Monitoring System (B)

Reactor Protection System (W)

Residual Heat Removal System (W)

Safety Injection System (W)

VitalAC/DC'System (B)

Emergency Containment Coolers (B)

Emergency Containment Filters (B)

Main Steam Isolation Valve Assemblies (B)

Normal Containment Coolers (B)

Selected Licensing Issues (B)

The design basis documents. were prepared and,issued under the auspices of the FPL QA Program. Each document had a preparer, verifier and approval from the respective organization project team. The design basis documents for systems addressed the system scope; basic and performance functions, safety. classifications, external influences and interfaces, configuration development history, licensing commitments, and calculation summaries.

The selected licensing issues addressed design history and design basis. positions.

Each specific design basis is presented.

To the extent possible, the design basis is a direct quote from the source document. If.further, clarification is needed, a second paragraph (distinguished, from,the design basis quote) is included to provide an interpretation.

There were some cases where a design basis was clearly needed to explain a particular'function or design constraint, but no,documented evidence was found. In such cases, a design. basis has'been developed'and "assigned" to the design basis document.

Development ofdesign bases required particular care to assure that current design codes, standards and practices were not being presumed.

The development basis has included related documents and existing plant conditions

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 44 as supporting evidence, and coordination with "vintage" design engineers where practical to assure a proper perspective.

Engineering is the primary, user of the DBD for 10 CFR 50.59 safety evaluations, and modifications. However, other personnel also use the DBD, particularly for evaluating components out-of-service, system or component operability and proposed changes in methods of plant operation. Before issuing the DBD as a final document, each was issued for trial-use, during which period the various departments provided review, assessment of usefulness and comments on content.

The design basis reconstitution program resulted in establishing SSC configuration and performance requirements which are reflected in the configuration documentation.

The maintenance ofthe DBDs to a current status is controlled by the processes described in the response to request [a] above.

The DBD review process identified some reportable conditions. In May of 1987, the design basis reconstitution process found a discrepancy in design flowrates for,the containment spray pumps.

The system piping resistance was such that pump runout flowwould exist. The flowrestricting orifices assumed'in the calculation were not installed. in the field nor were they found on the system documentation.

Both, units were shut down at the time of the discovery and the flow oriflices were installed.

The design basis reconstitution effort also discovered the residual heat removal (RHR) recirculation line was not designed to assure adequate flowfor each oftwo pumps. This potential deficiency coupled with a single failure ofthe other operating RHR train could have potentially resulted in a complete loss ofRHR pump capability. The recirculation flowpath for the RHR pumps was an original design ofthe plant. Plant modifications were. completed on both units to correct the configuration discrepancy.

2.2.2 Turkey Point DBD Program Comparison to NUMARC90-12 NUMARC90-12, Design Basis Program Guidelines, was issued after the Turkey Point design basis reconstitution program was under way. It is evident from review ofNUMARC90-12,, and from NRC input during NRC inspection NIR 89-203, that the Turkey Point program substantially followed the NUMARC90-12 guidelines and recommendations.

Therefore, the Turkey Point program'is generally consistent with the overall guidelines as well as many ofthe specific recommendations and applications.

Most of the Turkey Point plant-specific design basis information is contained in calculations, the FSAR, specifications and correspondence.

This information is available in microfilmrecords. As such, this information was reviewed and collated to support design basis document preparation for the selected systems and issues.

Turkey Point has prepared design basis documents the most. important selected systems, but not all plant systems.

The initialreason was that one of the systems, auxiliary feedwater, was the focus of Safety System Functional Inspection (SSFI) in 1985. Issues raised during that SSFI lead

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 45 to considering intake cooling water and other selected systems with high maintenance histories and functional problems having potentially significant consequences in terms of nuclear safety.

However, further consideration of the system scope confirmed that design basis documents included those systems with the highest risk significance.

Design basis information is readily available for use while developing new or revised procedures and fordesign modifications to plant structure, system and component modifications. The design basis documents were developed on a programmatic basis, and facilitate design and operability evaluations for systems and components having high safety risk significance. For lower-risk systems, more research and evaluation effort is required to reconstitute design basis information and is handled on a case-by-case basis. The procedures governing plant changes or modifications, calculations, evaluations, nonconformances and condition reports assure that the appropriate levels ofdocumentation and verification are performed, such as the reconstitution of the design basis ifnecessary.

2.3 Containment Isolation Documentation In 1989, FPL identified'discrepancies between the design basis documentation and the FSAR description of the features ofeach containment penetration. A substantial effort was made to define the configuration of each ofthe penetrations and the valves which comprise the containment isolation function. This effort was successful in defining the penetration configurations and effective in establishing the configuration baseline and assuring the consistency between the design basis and the documentation ofthat basis within the FSAR and the DBD.

2.4 Containment Structural Analysis In 1993, Turkey Point reanalyzed the containment structure and applied to the NRC for a license amendment to revised the licenced design basis pressure for the containment.

This amendment (approved by the NRC in 1994) required the translation of many of the design basis numbers into documents affected by the change using the processes described in the response to request [a].

2.5 Motor Operated Valves (MOVs) GL 89-10 In response to Generic Letter 89-10, FPL developed a Motor Operated Valve (MOV)program.

FPL identified 111 valves at Turkey Point that were included in the program. Design basis reviews were completed in the followingareas:

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Differential pressure determination

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Voltage drop calculations.

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Thermal overload heater sizing

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MOVsizing and switch settings Turkey Point addressed the design basis differential pressure forboth the open and closed valve direction to determine the maximum expected differential pressure foreach MOV. Fluid medium, temperature, and flowwere specified for the design basis condition and were included in the review to help determine the design basis differential pressure.

Turkey Point reviewed the FSAR,

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Turkey Point Units 3 &,4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 46 DBDs, plant normal, off-normal and emergency operating procedures, plant drawings, system descriptions, the computer data base containing design information, plant MOVwalkdown data, and environmental qualification document packages to ensure that the maximum expected differential pressure was accurate.

Each of the issues were addressed to the same detail as differential pressure.

In each case the configuration was found acceptable or the installed configuration was changed to meet the design criteria for each MOVin the program.

This process resulted in the establishment of a documented design basis for each of the valves in the program. The FSAR or DBDs were revised'to capture this new valve design basis information.

2.6 Surveillances Surveillance testing provides a means to verify the operability of systems and components and ensure variables are-within specified design and licensing bases limits. Surveillance requirements are obtained from Technical Specifications, ASME Boiler and Pressure Vessel Code,Section XI Pump and Valve program, Inservice Inspection gSI)/Inservice Testing. (IST) requirements, and other criteria specified by management.

Processes are in place to assure failed or missed surveillances are appropriately evaluated for reportability and corrective actions are implemented ifnecessary.

These processes are discussed'in the responses to requests [a] and [d].

Just prior to the transition from the original Technical Specifications to the current Technical Specifications, a line by line review was performed by licensing, operations and maintenance personnel and a matrix was developed and proceduralized to.show each specification was procedurally implemented.

This review and matrix were used to ensure that procedures were in place to address each item of the Technical Specifications and that the equipment required to be tested under each surveillance requirement was tested as required.

3.0 Recent Design Related Projects Each of the followingprojects reconstituted design basis information as part of the project. The configuration of systems involved were reviewed to ensure that each system reflected the design bases and was operated in accordance with its design basis.

The. processes described in response to request [a] ensure that the translation of those design characteristics into the plant systems and their operation is accomplished in accordance with their design.

3.1 Setpoint Program The details of this program are described in the response to question [b]. The setpoint documents were developed with the intent to document the setpoint basis for determining correct system or component performance.

The setpoint program provides a basis for the conclusion that the current plant setpoints are correctly translated into plant procedures, available for review by engineers planning modifications to the facilityand therefore correctly reflected in the PC/M packages.

The effort assures that the setpoints used in maintenance and operations functional tests incorporate the correct values and are documented properly for each SSC.

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 47 3.2 Emergency Power System (EPS)

In late 1985 and early 1986, issues with Emergency Diesel Generator (EDG) loading were reported by FPL and significant corrective actions commenced to correct this situation, including ultimately the implementation of the EPS enhancement project. Significant FPL resources were expended reconstituting and redesigning portions of the plant's electrical distribution system. The project was completed in 1991 at the end of a dual unit outage.

The restart from the EPS project included a restart evaluation of the facilityprior to returning the units to power. The project included a detailed evaluation ofthe configuration. baseline of the. emergency electrical distribution system for the facilityensuring that the new designs and system requirements had been correctly

,reflected in the new installation and its documentation.

3.3 Revised Technical Specifications (RTS)

During the fallof 1986, FPL applied for a change to the Technical Specifications which upgraded the specifications to what was at the time an adaptation of the current standard for the Technical Specifications forWestinghouse facilities. A detailed review and verification process for this PEP project resulted in approval ofthe new Technical Specifications and implementation in August of 1991.

During the process ofdeveloping the justification for the changes to the Technical Specifications, a number of analyses were performed which reestablished the basis forvarious Technical Specification requirements on plant systems, structures and components.

See the response to request [b] above for the discussion of the development of a Technical Specification surveillance matrix to assure the Technical Specification required testing and surveillances are completed on the SSCs of the plant. These new surveillances enhanced the ability ofTurkey Point to assure the operation of the SSCs involved is in accordance with their performance requirements 3.4 Thermal Power Uprate In December of 1995, FPL provided analyses to the NRC to justify an increased thermal power rating for Turkey Point Units 3 and 4 from 2200 Megawatts thermal to 2300 Megawatts thermal.

This resulted in numerous changes to the plant's design bases.

This amendment request included an engineering evaluation to justify the proposed changes.

The majority of the potential accidents discussed in Section 14 of the FSAR were reanalyzed.

Major sections ofthe FSAR were revised and willbe distributed in the near.,term.

The.DBDs are. being revised. Technical Specification changes were approved by the NRC in mid 1996, and implemented in the fallof 1996.

To implement the thermal. power uprate in 1996, some minor modifications were implemented such as increasing the size of the tail pipes on the main steam safety valves. Additionally, component cooling'water system as well as containment integrity analyses were completed for this evolution. This extensive analyses work has provided an opportunity for Turkey Point to reestablish a baseline for many ofthe analyses which appear in Section 14 ofthe FSAR.

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Turkey Point Units 3 &,4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 48 4.0 Turkey Point Walkdowns, Walkdowns are an integral part of the continual identification of SSC conformance with the design bases of the-plant. Most ofTurkey Point walkdowns are programmatic, however some special walkdowns have been required by generic NRC correspondence.

4.1'rogrammatic Walkdowns The programmatic walkdowns include those accomplished during normal operation of the facility, scheduled audits ofthe facility.by QA, system walkdowns by each system engineer, walkdowns of systems or components during maintenance planning or testing, and walkdowns performed by plant management.

4.1.1 Operator Rounds Operator. rounds are conducted to ensure that systems'are operating as expected.

During these rounds, data are collected which document the status ofvarious parameters which reflect the operation of the monitored equipment. By evaluation of the data, both on a point by point basis as well as evaluations oftrends, Turkey Point can determine ifthe equipment is operating in accordance with the design bases.

Operator rounds at Turkey Point are computer aided to provide the operator with more specific plant information. The real time information capability afforded by the computerized log keeping, aids in ensuring, the accurate reflection of the design bases in plant operations.

4.1.2 Quality Assurance Walkdowns QA performs system walkdowns under two.plans, during a periodic safety related flowpath verification, and as part of system audits and reviews. For the walkdowns, both the applicable operating procedure(s) and drawing(s) are used to verifyvalve and breaker alignment.,

The scheduling of the walkdowns is determined by the QA Supervisor.

Presently, the frequency for the safety related flowpath verification walkdowns is monthly. System reviews are performed with the objective ofcovering a mixture of safety related, quality related, and non-.safety related systems every few years with most of the reviews on the safety related systems.. The walkdowns during system reviews have been on-going for about eight years.

These walkdowns have been supplemented by the periodic safety related flowpath verifications for about the past two years.

Although these QA walkdowns have, identified minor.deviations, the conclusion, is that good configuration and'design control was being maintained.

4.1.3 System Engineer Walkdowns System engineers and,component engineers are required to perform walkdowns oftheir systems ori a regular basis. Direction for walkdowns are provided by procedure.

Engineering Department instructions for component and system walkdowns provide specific details on how to perform walkdowns. The procedure applies to 46 systems.

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 49 Turkey Point has recently categorized systems based upon risk significance in accordance with the maintenance rule. These systems require the generation ofa monthly walkdown report. Allother systems require a quarterly report. The procedures require specific inspections to monitor changes that affect piping degradation on mechanical systems (flowaccelerated corrosion) and specific inspections that may be needed on some electrical systems.

As-a result of seismic considerations, a walkdown ofeach system for structural degradation and degradation of environmental coatings is required. Each quarter the system engineer is instructed to have one of the followingindividuals join the walkdown; system engineer supervisor, civilengineer, maintenance department supervision or operations department supervision. Ifinconsistencies are found they are typically documented by use of the CR process.

4.1.4 Management Walkdowns Turkey Point has instituted, as part ofthe culture of the plant, a number ofmanagement walkdowns. The Plant General Manager periodically designates a specific area, system or set of components to be walked down by the upper. management of the plant. Additionally, the material condition of the facilityis monitored by cleanliness tours conducted by management personnel bimonthly. Offhours tours are conducted at random by upper management once each month.

Most of these walkdowns are documented and condition reports or other corrective actions are implemented and tracked to completion by the Plant Manager Action Item (PMAI)system.

4.2 Special Walkdowns 4.2.1 Environmental Qualification (EQ) Walkdowns During the late 1980's the second phase forEQ was composed ofwalkdowns performed for verification of the environmental qualification ofvarious equipment in the plant in accordance with 10 CFR 50.49. One output of the review was the determination of the required installed configuration. The required physical characteristics were captured on a field walkdown checklist which was used to verify the installed condition for each type ofequipment. Unit4 walkdowns identified numerous deficiencies, many ofthem common to several components.

The Unit 3 walkdown resulted in similar findings and provided reasonable assurance that there were no other generic discrepancies.

The EQ equipment discrepancies identified during the walkdowns were documented on discrepant field condition reports. Engineering resolutions were provided on NCRs and repairs made where necessary.

Reinspection of the equipment was performed by FPL QA personnel and'a member of the EQ walkdown team to ensure satisfactory resolution of configuration or performance deficiencies.

See section 4.4.3 in the response to request [b] for a detailed discussion ofthe. first-phase of.the EQ component analysis.

4.2.2 Bulletin 79-14 Walkdowns In.response to IE Bulletin 79-14, Turkey Point implemented a program to reassess the piping support systems for large bore safety-related systems.

As an extension to the project, walkdowns were performed forimportant safety-related small bore piping systems to confirm the acceptability of support system'design and installation. Some discrepancies were identified'and resolved by calculation or hardware modification.

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e 4.3 Quality Assurance Audits/Technical Reviews

~key Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 50 QA has conducted performance monitoring audits of systems and components on a regular basis.

The subject ofmany of the audits is the review of engineering design packages and how they control SSC changes.

For example, an audit of a system includes a review of the recent significant modifications performed on the system and how the modification configuration and performance characteristics are controlled.

The additional reviews conducted by QA enhance the rationale for concluding that SSC configuration and performance are consistent with the design bases.

Multiple QA system reviews

.have been conducted since 1988. For administrative efficiency QA now performs technical reviews of system and components on a regular basis and reports the results to management by Quality Reports.

0 As part of the system reviews, the FSAR applicable sections and DBDs, ifapplicable, were reviewed.

Systems were walked down using drawings and procedures to ensure the fidelityofthe systems.

Clearances and temporary system alterations in effect were reviewed to ensure design bases were not adversely affected. Additional strengths that facilitate walkdowns are the good system labeling ofequipment and identification tags on valves.

Several findings/CRs or comments were documented in reports and audits with respect to maintaining design bases ofSSCs. They were considered minor in nature and did not affect conclusions regarding strengths.

Some examples are:

One report identified that a seismic anchor for the boric acid supply piping had been removed without prior evaluation ofits seismic affect. The anchor removed was from a boron injection tank recirculation pump that was awaiting formal abandonment.

A condition report was written by the system engineer.

An evaluation determined that no operability concern existed.

An audit found that the capability to operate the gas analyzer sample valve for the pressurizer relief tank was not indicated on the system drawings or in the.FSAR.

Engineering has since revised system drawings and the FSAR to reflect this function.

An electrical drawing for the containment spray reset buttons was found to be incorrect. A switch replacement could have resulted in an incorrect wiring configuration. A drawing change was made.

For details of these and other QA audits see Appendix B.

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'Ibrkey Point Units 3 R 4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 51 4.4'hird Party Reviews An audit was conducted in 1991 by an independent contractor of the Turkey Point compliance with Reg Guide 1.97. Some inconsistencies were found. APC/M was issued to resolve those inconsistencies.

4.5 Service Water System Operational Self-assessment (SWSOPA)

A SWSOPA was initiated by FPL at Turkey Point in 1995. Details of this assessment and its findings are discussed in the response to question [b]. The use of the SWSOPA temporary instruction aided FPL in assuring that, the ICW system at Turkey Point was being operated and was performing in,accordance with the design bases.

4.6 Select System Review The select system review was conducted in the middle 1980s by the Safety Engineering Group (SEG). These systems were categorized'as mitigation systems and support systems.

Thirteen of the systems included in the design basis reconstitution program were'included in this program with the followingfour elements being implemented.

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Reconstitution ofdesign basis

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Comprehensive review by SEG

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Plant walkdowns

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Configuration management program review An expansion of the SSR was a systematic design investigation. This was considered a strength by an NRC inspection team. The'systematic design investigation provided a risk based method for setting priorities for the resolution of technical concerns which resulted from the DBD reconstitution project. The concerns found during the investigation were dealt with in an order which reflected the safety significance and risk ofeach of the items. The conclusions reached by the SSR were that the systems were being operated in accordance with,their design basis.

4.7 NRC'Inspections Both FPL and NRC have performed "vertical slice" audits of systems to confirm the adequacy and'ompleteness ofdesign basis information related to Turkey Point. These audits include, but are not limited to; the auxiliary feedwater SSFI'by NRC, NRC audit of the Design Basis Program, multiple inspections during the.EPS upgrade, and.the SWSOPA in process inspection by NRC; The followinglist includes examples ofNRC inspections in the area of design which support the conclusion that design bases requirements are translated into operating, maintenance, and testing procedures.

4.7.1 AuxiliaryFeed Water SSFI The earliest of these audits was the NRC SSFI of the AFW system conducted in 1985 by the NRC. This audit clearly identified'concerns related to how,design basis information was

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Pago 52 maintained and focused on understanding design bases.

Corrective actions from this audit were sweeping in nature and impacted every area ofplant operations.

Specific concerns related to AFW design were addressed, corrected, and incorporated into the DBDs. This SSFI lead.to the implementation ofthe PEP.

4.7.2 Motor Operated Valves (MOVs)

NRC inspection reports 92-08 and 93-25 document the Phase I and H inspections conducted by the NRC on Generic Letter 89-10 issues.

The concerns identified were'that acceptance criteria needed to be enhanced in the testing procedures.

Documentation to support MOVbrake operation during degraded voltage needed to be upgraded.

Turkey Point needed to evaluate load sensitive behavior margins for dynamically tested MOVs and to provide guidelines to account for torque switch repeatability and other uncertainties in the calculations.

Each of these concerns was addressed and resolved.

The NRC also noted a number of strengths in the program some of which were; prioritization was given to high DP/low margin MOVs for aggressive differential pressure testing; performance of multiple differential testing was done to justify extrapolation methodology; pressure transducers were used. both up and down stream to capture time dependent pressure variation. These program strengths aid in ensuring that the design basis for each of the MOVs is reflected in the installed configuration.

An additional NRC inspection in this area is tentatively scheduled for the spring of 1997.

4.7.3 DBD Inspection The Turkey Point Design Basis Validation Inspection (NRC NIR 89-203) was performed as a series of SSFIs on the Reactor Protection System (RPS), the Component Cooling Water (CCW) system, and on the Electrical Distribution System (EDS). In general, the NRC cited the depth, breadth, and quality of the system DBDs, finding them useful and well researched.

On the other hand, the depth ofverification ofthe DBDs was identified as a concern, the component level DBDs were found to have errors, and the. correctness of certain calculations was questioned.

FPL corrected the identified information deficiencies in the component DBDs, enhanced the verification of the component DBDs, and instituted improvements in the calculation process, including retrieval and indexing ofTurkey Point and vendor calculations in PassPort.

See the discussion in the response to request [b] section 2.2.1, for more details on the PassPort system.

4.7.4 EPS Inspections Because Turkey Point has implemented the Emergency Power System (EPS) Enhancement Project, significant NRC and FPL resources have been expended reconstituting and redesigning portions of the plant's electrical distribution system. Again, based on the significant number of inspections performed as part of this project, FPL demonstrated that an Electrical Distribution System Functional Inspection (EDSFI) had essentially been completed at Turkey Point. The NRC did not conduct a specific EDSFI at Turkey Point.

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'Ibrkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 53 4.7.5 SPVSOPA In-process Inspection A SWSOPA was.initiated by FPL in 1995 and an in-process NRC inspection was conducted during the self-assessment.

The inspection team found that the depth and scope of the self-assessment was lacking in some areas.

As a result FPL extended the length ofthe self-assessment to envelope the required scope and depth.

The self-assessment report was issued in mid 1995. The self-assessment concluded that the ICW and CCW meet their thermal and hydraulic performance requirements.

The design change process adequately maintains the design basis and drawings reflect the as-constructed configuration. Single failure analyses demonstrate that no credible active component failure would prevent the systems from performing their design function. Afollow-up NRC inspection is scheduled forTurkey Point in early February 1997.

5.0 Conclusion There is adequate'rationale for concluding with reasonable assurance that the systems,.structures and components are consistent with the design and that discrepancies between design documents, the FSAR and procedures and the plant are not significant with respect,to safety, based upon following:

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The verification at initiallicensing that the plant, FSAR and the design are consistent.

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The processes in place assure the maintenance of that consistency.

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Various recent major modifications have aided in.establishing a reconstituted bases for configuration and performance requirements on many plant systems.

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The various audits and inspections have verified consistency ofdesign and the plant.

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Processes have been and are in place for identification, evaluation and correction of discrepancies between the design and the plant systems, structures and components.

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 54

[d]

"Processes for identification ofproblems and implementation of corrective actions, including actions to determine the extent of problems, action to prevent recurrence and reporting to NRC."

The followingoutline provides the organization of the response to request [d]:

1.0 Introduction - Background 2.0 Problem Identification Processes 2.1 2.2 2.3 2.4 2.5 2.6 Operator Rounds Walkdowns Operating Experience Feedback (OEF) /Generic Implications Management Self-assessment Quality Assurance (QA) AuditPrograms Nuclear Safety Speakout (SPEAKOUT) 3.0 Corrective Action Programs 3.1 Historical Discussion 3.2 Quality Instructions (QIs) 3.3 Condition Reporting (CR) System 3.4 Event Response Teams 3.5 Commitment and Corrective Actions Tracking (CTRAC) Systems 3.6 Change Request Notices (CRN) 3;7 Nonconformances (NCRs) 3;8 10 CFR Part 21/Significant Safety Hazard Evaluations 3.9 Operability Determination 3.10 10 CFR 50.72 and 50.73 Reportability Determination 3.11'orrective Action Program Training 4.0 NRCffurkey Point Interfaces

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Turkey Point Units 3 A 4 Docket Nos. 250 and 251 L-97-26 Enclosure Pago 55 1.0 Introduction - Background The Plant General Manager is responsible for the overall implementation ofthe programs described in this response.

Operations personnel are responsible for operating the plant in accordance with the design bases, Technical Specifications and the applicable regulations.

Along with a questioning attitude exhibited by plant personnel and the identification of issues during routine work, Turkey Point has many programs which are designed to identify issues needing resolution. Examples which are discussed in this response are, operator rounds, programmatic and special walkdowns, Operating Experience Feedback, management self-assessments, the QA program, the Condition Report process, and Nuclear Safety Speakout.

Conditions found may be documented by any employee, permanent or temporary, on a Condition Report (CR). Afterreview by the Nuclear Plant Supervisor and the Plant General Manager, the CR program is administered by the Engineering organization. The corrective actions identified in the resolution to each CR are tracked by personnel reporting to the Plant General Manager.

Root causes are typically determined by Engineering personnel with the aid ofcognizant personnel from the Maintenance, Operations, Health Physics, Chemistry, Reactor Engineering or other disciplines as required.

If.any operability or reportability issues arise that must be resolved in a short time defined by the Technical Specifications, or Federal Code, the Nuclear Plant Supervisor and the on shift operations staff are authorized and required to make those determinations and followthe applicable procedures to resolution. For those conditions which are ofa nature which allow or require more detailed evaluation, the Engineering staff aids in the determination ofoperability and the Licensing staff aids in the determination ofreportability.

2.0 2.1 Problem Identification Processes Operator Rounds Operator rounds are required by procedure.

The procedure in some cases implements the requirements ofTechnical Specifications and is a reflection of management expectations for the operator to keep abreast of the operation of the equipment in the plant.

Operator rounds use a computerized data logger to provide the operator with more plant specific information. This information is useful, in documenting plantstatus and.is more user friendly than the previous hard copy logs. The computer provides the operator with minimum and maximum values associated'with equipment performance.

It-also has Technical Specification information, trending capabilities, and does not allow the operator to exit the program until the rounds have been completed. The availability ofthe information in the computerized data set simplifies the identification ofan abnormal condition and provides a more efficient means for supervisor review.

The plant procedures provide a broad scope of the requirements, and specific departmental instructions were developed to govern the aspects of each watch station. Satisfactory completion of a set ofrounds on a particular watch station in accordance with these instructions (under the

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Turkey Point Units 3 A4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 56 surveillance of a supervisor) is a requirement ofqualifying on a watch station. The instructions are periodically used as a monitoring tool by management to insure that the rounds are performed in accordance with their expectations.

The rounds help to identify and correct conditions prior to them becoming problems. Plant work orders are generated for any deficiencies, condition reports are generated for anything outside the work order process.

2.2 Walkdowns System engineers and component engineers are required to perform walkdowns of their systems on a regular basis. Directions for walkdowns are provided by procedure.

Engineering Department instructions are in place forwalkdowns of.components and systems.

See section 4.0 in the response to question [c] for more details on programmatic and special walkdowns. Ifnon-conforming conditions are found, the CR system may be used to document the condition and provide a platform for the correction of the condition.

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Operating Experience Feedback (OEF) /Generic Implications Industry events and reports are reviewed and processed based on applicability.to Turkey Point in accordance with administrative procedures.

Industry events and.reports are reviewed by the OEF coordinator and processed based on potential generic applicability to Turkey Point in accordance with administrative procedure 0-ADM-515. Industry event reports screened by the OEF Coordinator include:

NRC Generic Letters (GLs)

NRC Information Notices (INs)

NRC Daily Event Reports NRC Press Releases (PRs)

INPO Significant Operating Experience Reports (SOERs)

INPO Significant Event Reports INPO Significant Event Notifications (SENs)

INPO Significant by Others reports (SOs)

INPO Operations and Maintenance Reminders (OgcMRs),

INPO Operating Experience reports (OEs)

Westinghouse, General Electric and Combustion Engineering Vendor and Technical Reports Operating experience items which merit analysis, specific actions or a thorough, documented plant review or response, are processed. as.CRs.

Implementation of the.CR process ensures that a thorough evaluation and analysis of the event or report is made and that the plant's response (if applicable) adequately addresses the concerns. Ifan. update to the plant's design'bases documents are required in response to the operating event, itwillbe identified and implemented through. the CR process using the appropriate engineering processes.

Problems identified in house and through the OEF program are compared to the processes used'in the plant. procedures.

Where identified enhancements, or changes would benefit the plant or mitigate the consequences of an event, procedure/process changes are made as necessary.

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Turkey Point Units 3 &,4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 57 the OEF goals, when providing industry information to plant personnel, is to aid in the maintenance of the procedures, such that the potential'for the. introduction of a step which could initiate an event is minimized during'the development or change process of'a procedure.

The OEF program is just one of several programs that provides a measure ofhow well the lessons learned are incorporated from both the experience of others and ourselves.

Another,program is the use of,the simulator to validate selected procedures such as Emergency Operating Procedures (described in section 3.6 ofresponse [b]). This validation helps to ensure that problems have not been written into the procedures and allows for the testing ofideas ifitis believed that there is a better way to perform a task.

In-house events are screened for inclusion in the OEF program by review ofplant CRs.

Violations which have been cited at other licensees are reviewed on a periodic basis for applicability to Turkey Point. Contractors that have compiled docketed.'information and internal:

as well as generic communications from the NRC have been retained by FPL. This body-of information is available in an electronically searchable format, and aids in the timely review of information potentially applicable to Turkey Point. Recent access-via the Internet has.made these documents in many cases available to FPL on the same day as released to the industry by the NRC.

2.4 Management Self-assessment t

Turkey Point departments have a series of formal'and informal programs which provide for self-assessment.

The-self-assessment processes used at Turkey Point include:

Post Outage Assessments Post Trip Reviews OffHours Tours Training Observations PWO Feedback Forms Cleanliness Walkdowns Plant Manager's Walkdown Event Response Teams Condition Report System Trending Quarterly Trend Analysis Each of these processes provide the. opportunity to.identify procedure, design or configuration issues in need ofresolution.

2.5 Quality Assurance (QA') Audit Programs The QA organization at Turkey Point is an independent organization reporting through an offsite Director directly to the President of the Nuclear Division. QA has a program of audits which are required by procedure and they also conduct audits at the request of the CNRB and upper Nuclear Division management.

Many of the CNRB requested audits are required by Technical

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 58 Specifications. The findings and recommended corrective actions are documented by the generation of a CR for each item, as well as in the QA audit files. (Also see discussion in the response to request [a], section 6.0, on the Topical Quality Assurance Report (TQAR) Section 18.0 requirements for audits.)

2.6 Nuclear Safety Speakout (SPEAKOUT)

The SPEAKOUT program is a separate reporting process for identification ofconcerns which may be used by personnel wishing to remain anonymous or used as a method which does not require the normal chain of command reporting, process.

This program is designed to maintain anonymity while'seeking causes and corrective actions for the identified issues. A designated committee reviews SPEAKOUT issues for thoroughness ofinvestigation, documentation and corrective actions.

Summary reports on each issue are returned to the identifying individual for their information.

3.0 Corrective Action Programs 3.1'istorical Discussion The TQAR for Turkey Point is the top tier document (approved by the NRC) which defines the QA program. The TQAR is written such that the numbering and topic ofeach section matches that of 10 CFR 50, Appendix B. The basic requirements for corrective action processes are described in the followingTopical Quality Reports (TQRs):

This TQR requires that measures be established to control nonconforming items to prevent them from being installed or used.

These measures also are required to provide for the disposition of the nonconforming conditions.

This TQR requires that measures be established..to ensure that conditions adverse to quality are promptly identified and corrected. Additionally,ifthe condition is significant, the cause is determined, and actions are taken to prevent recurrence,.and results are reported to appropriate managers..

This TQR requires the conduct ofa comprehensive system ofplanned and period audits of the quality assurance program and to determine the effectiveness of the program. Auditresults are reviewed by the audited management and subsequently by the Company Nuclear Review Board.

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0 3.2 Quality Instructions Turkey Point Units 3 4, 4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 59 The Engineering QIs implement the requirements of the TQAR. The overall method and process for addressing corrective action, as required by Criterion XVIof 10 CFR 50 Appendix B has historically been controlled by plant management, with engineering providing,input into the decision process when needed.

However, Turkey Point has always maintained a process for dealing with internally identified concerns.

Traditionally, issues are to be brought up through management, up to and including the President Nuclear Division. This process is progressive, and the individual may continue up this chain ifsatisfactory action is not taken on, an individual concern. This process is supplemented by the Nuclear Safety SPEAKOUT program which provides:a mechanism for anonymously identifying concerns.

See section 2.6 of this response for further details on SPEAKOUT.

3.3

'Condition Reporting (CR) System Prior to 1992, Turkey Point had many problem reporting and resolution systems in place. They were in:most cases. department or process dependent.

In 1992, most were consolidated into the CR process.

The CR process is controlled by an administrative procedure (ADM-518, Condition Reports).

The process is now designed for use throughout the Nuclear Division, although each plant has its own implementing. procedure.

The system is also designed to have a very low threshold for use by anyone working in the Nuclear Division. Issues such as a plant trip, a design basis question, or a non-compliance with a procedure which controls paper flow, each receive attention in the CR process.

This allows tracking and trending oflow level as well as high level issues to aid plant management to set priorities on issues as they arise. The CR:process is used to initiate operability determinations, root cause determinations, license amendment application preparation, and reportability determination among others. Reportability can include the 10 CFR 50.72,,10 CFR 50.73, 10 CFR 21, or 10 CFR 20 as well as other reporting requirements.

Corrective actions which are generated by the CR,process are tracked in a Plant Manager Action Item (PMAI)tracking system. This is a plant specific. tracking system which follows the corrective actions to completion and gives the items visibilitywithin the organization.

3.4 Event Response Teams An Event Response Team (ERT) program provides for a fast acting group ofknowledgeable plant personnel to investigate. the. root cause. of.plant, events. such as, automatic reactor trips, unplanned unit shutdowns, and recurring maintenance/repair issues.

Significant equipment problems can also be the subject ofinvestigations by an ERT. The ERT process is defined'in plant procedure'0-ADM-011', "Event Response Team (ERT) Organization." An ERT'may be requested by the Nuclear Plant Supervisor (NPS) or any other member of the Nuclear Management Team. The Engineering Manager appoints an ERT leader and concurs with the selection of team members.

In cases where an ERT is formed, a CR is initiated.

Team meetings are held'as often as necessary until the ERT accomplishes the following tasks:

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Determination of the root cause of the event.

Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 60

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Determination of short term countermeasures.

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Determination of countermeasures to prevent recurrence of the event.

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Identification ofpossible generic problems that may cause similar events, and development of action plans to address them.

The ERT uses tools such as event time lines, drawings, cause and effect diagrams, failure modes and effect analysis, possible root cause evaluation matrices, system operators, vendors applications experts, system engineers, and component specialists to aid in the determination of root cause. A formal plant procedure, O-ADM-059, "Root Cause Analysis," is also in place to provide detailed guidance in determination ofroot cause.

This procedure provides for use of the followingproven root cause techniques:

task analysis, change analysis, barrier analysis, event time line and causal factor charting, causal factors category listing, cause and effect analysis, and fault tree analysis. A formal procedure, O-ADM-511, "Post Trip Review," is in place to provide a systematic method for ensuring the proper functioning of safety-related and other important equipment during-a reactor trip. The post trip review is used as input to the ERT and provides management with the necessary information to determine when the plant can be safely restarted.

Event Response Team recommendations and countermeasures are documented and tracked using the CR system.

3.5 Commitment and Corrective Actions Tracking (CTRAC) Systems 0

In 1984 Turkey Point began tracking commitments made to the NRC. The tracking goal is to not miss'the completion date for any commitment. Performance Enhancement Program (PEP) Project 7 was implemented to enhance the effectiveness oflicensing activities and to.improve the coordination and control ofNRC related projects. The commitment tracking system was implemented as part of the project to ensure meeting each NRC commitment made by FPL for Turkey Point. This tracking system continues to provide the process for closing. each commitment item, such as those made within an application for a License Amendment, an exemption request, a response to a notice ofviolation, a corrective action within a Licensee Event Report, or other commitment made to the NRC on the docket. Many, offthe docket agreements can also be found referenced in this tracking system. A the large number ofcorrective action commitments were made during the implementation of the PEP in the mid to late 1980s. As a result, a "livingschedule"..(Integrated Schedule) was created and was required by inclusion in the Turkey Point Operating License until the end date listed in the license, December, 1991. This schedule allowed a reallocation ofresources as each new commitment was added to the schedule.

The commitment tracking system today is more detailed but essentially the same in function as that generated as part ofProject 7.

An additional feature of the system is'to make available a search tool which can ascertain ifa particular issue is in fact a commitment and its originating document.

Procedures often have

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 61 commitment'references in the introductory sections of the procedure and in many cases in.the body of the procedure next to the step which.implements the commitment.

3.6 Change Request Notices (CRN)

When an engineering design package is issued, there is always'a potential that'some field condition or minor,change may be required after the package is issued.

The engineering procedures permit a design package to either,go through.a formal.revision or to have.a CRN issued to resolve. the minor change.

The CRN is a method under which,minor changes are made to an issued engineering design but, where the change requested does not affect the design or safety analysis generated by the original engineering package.

A CRN may also be initiated for a design package by any individual and provides a mechanism forformally correcting minor potential problems with an issued design.

3.7 Nonconformances (NCRs)

The NCR process was administered'by the Quality Control Department until 1993, at which time, it was made part ofthe Condition Report (CR) process which is now administered by.the Engineering Department.

The historical NCR as part of the CR process provides a means for controlling the disposition of nonconforming items reported during receipt inspection or field inspection of SSCs where Engineering is required.to evaluate and resolve the nonconformance.

Nonconforming items that are acceptable by virtue of existing design documentation do not require Engineering evaluation and are corrected by a Plant Work Order or Relay Work Order.

3.8 10 CFR Part.21/Significant Safety Hazard Evaluations One mechanism for evaluating design. or equipment problems is through the 10 CFR 21 reporting process.

When first instituted in 1977, Part 21 was used extensively to address design and equipment. issues identified both internally and by external vendors.

10 CFR 21 evaluations have almost exclusively been performed by engineering personnel ifthe design or equipment is found to have been provided to FPL. These evaluations provided a means for FPL to evaluate,and address specific issues from either external or internal sources and to document required corrective actions and reporting to NRC. Subsequent changes in this rule and the promulgation:of 10 CFR 50.72 and 50.73 are such that evaluations are now primarily performed with "operability" criteria as the focus rather than against substantial safety hazards criteria. Operability is incorporated within the condition reporting. process and.is more restrictive than 10 CFR 21.

10 CFR 21 evaluations'are performed for equipment received by the warehouse, but:not yet installed in the power plant to evaluate if.a substantial safety hazard exists. The reporting criteria of 10 CFR 50.72 and 50.73 and their use willbe discussed in section 3.10.

3.'9 Operability Determination Recommended guidance, considerations, and methodology for performing assessments of operabili'ty on non-conforming or degraded'conditions that are commonly evaluated'by Nuclear

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Pago 62 Engineering are proceduralized in a QI. The QI is based on the information contained in NRC Generic Letter 91-18, "Information to Licensees Regarding Two NRC Inspection. Manual Sections on Resolution ofDegraded and Nonconforming Conditions and'on Operability."

The followingaspects ofoperability determination are discussed in the QI:

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Operability vs. fullqualification

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Operability vs. single failure

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Operability and the use of manual action vs. automatic action

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Operability and the use ofprobabilistic safety assessment

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Operability vs. environmental qualification

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Technical specification operability vs. ASME Section XIoperative criteria

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Operability'vs. piping and,pipe support requirements

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Operability vs. flaw evaluation

~:Operability vs. operational leakage (Generic Letter 90-'05)

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Operability vs..structural requirements r

In addition, a design/operability reference guide is in the Engineering QIs to provide additional guidance on operability considerations as well as design, safety, quality, and regulatory considerations which may facilitate development of thorough design inputs/analyses and operability assessments.

The guidance'is intended,to.be.a check list to ensure that applicable considerations are not omitted during a design or operability assessment activity.

Training for operability determination as discussed in-Generic Letter 91'-18 was added to the lesson plan forinitialand requalification training for Plant Nuclear Safety Committee (PNSC) personnel.

The training for identification ofproblems and'implementation ofcorrective actions is discussed in section 3.11 on Corrective Action Program Training below.

3.10 10 CFR 50.72 and 50.73 Reportability Determination CRs are the entry point for issues of a condition ofnonconformance or non-compliance at Turkey Point. Each CR is reviewed by,the Nuclear Plant Supervisor for 10 CFR 50.72 reportability in accordance with administrative procedure O-ADM-115, "NotificationofPlant Events." Afterthe determination is made that the condition is not reportable under 10 CFR 50.72 then the CR will next be reviewed'for 10 CFR 50.73 reportability by the Licensing Department. Ifthe initial information on the'CR did not lead to the conclusion that a condition was reportable.but further information raises that potential, the new facts about the condition are relayed to the Licensing Department for.further evaluation.

3.11 Corrective Action Program Training Training on identification ofproblems and implementation ofcorrective actions includes the

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The Engineering Support Personnel (ESP) Training Plan includes initialtraining on the Corrective Action Program which is a,basic review of the plant procedures associated with the corrective

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Turkey Point Units 3 A4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 63 actions program including the CR process. Itis part of the InitialIndoctrination training section of the INPO accredited Engineering Support Personnel (ESP) Training Program. The Problem Identification and Correction (PIC),process is covered in a three day class which includes topics such as, defining the problem, determining root cause and the development of appropriate corrective actions. The PIC process training is offered to appropriate management and engineering personnel.

The CR process is a subject ofthe General Employee Training Program presented to plant employees and contractors on an annual basis. Additionally, the opportunity to provide information directly to the NRC in accordance with the provisions ofForm 3 is a subject of this training.

NotificationofPlant Events is a lesson plan which is used for the training of licensed operators which includes the requirements of 10 CFR 50.72.

4.0 NRC/Turkey Point Interfaces FPL has a policy that requires open and'candid communications with NRC personnel.

To that end, the followingcommunications are maintained. Daily conversations are held with the resident Inspectors at the plant by many staff-members on site. Weekly meetings are typically scheduled between the Plant General Manager, Licensing Manager and the residents.

Frequent communications are made with the NRC project manager for Turkey Point. A regulatory liaison office is maintained in Washington D.C. to allow expedited face to face communications with the NRC staff for any issue which may arise.

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Turkey Point Units 3 k4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 64

-[e] "The overall effectiveness ofyour current processes and programs in concluding that the configuration ofyour plant(s) is consistent with the design bases."

An outline of the organization of the response to this request follows:

1.0 Introduction 2.0 Program Reviews Which Lead to Design Basis Verification 2.1 2.2 2.3 2.4 2.5 IEB 79-14, Small Bore Walkdown Program Revised Technical Specification Project Emergency Power System Enhancement Containment Structural Re-analysis Thermal Power Uprate Project 3.0 FPL Vertical'Slice Audits and Conclusions 3.1 3;2 3.3 Emergency Power System Service Water System Operational Performance Self-assessment (SWSOPA)

Quality Assurance Audit Conclusions 4.0 NRC Safety System Functional Inspections (SSFIs) 5.0 Overall Conclusion

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Turkey Point Units 3 &4 Docket Nos. 250 and &1 I 97-26 Enclosure Page 65 Introduction FPL, with reasonable assurance, is confident that the. current processes and programs are effective in ensuring that the Turkey Point has understood and documented design bases and that the design and'configuration are consistent with those design bases based upon the following:

The initialplant verification process, continued configuration control processes, and audits and inspections verify consistency between plant design and dependent information. In addition, previously performed design basis documentation efforts and design basis verification efforts such as. vertical slice audits and related reviews represent a baseline that establishes the consistency between the plant, plant procedures,,and the design bases.

The NEI 96-05, "Guidelines, for Assessing Programs for Maintaining.the Licensing Basis,"assessment has thus far provided-positive results. No significant programmatic breakdowns were identified, thereby-providing reasonable assurance that structure, system, component configuration, procedures, and performance are consistent with;the design bases.

(Refer to section [fJ for a detailed discussion of the NEI-96-05 assessment.)

2.

The plant design change process ensures the compatibility of,the plant physical and functional characteristics with the design bases and plant documentation.

Changes are evaluated and reviewed to fully.determine the impact of each change on other systems, and documents the evaluations to ensure adherence to established requirements.

(Refer to the response to request [a] for a detailed discussion of the design change process.)

3.

The process ofidentifying and determining reportability offound conditions and resolving those conditions includes the Condition Report program, the review ofpotential defects and non compliance, the Nuclear Safety SPEAKOUT program, the QA audit and engineering:reviews,of the CRs. For cases where problems were and are identified, appropriate root cause analyses and corrective actions were and are implemented. If minor discrepancies are found in licensing documents, the condition reporting or other proceduralized processes willbe used to resolve them.

2.0 Program Reviews Which Lead to Design Basis Verification Numerous activities have been performed by FPL at Turkey Point that verify the plant design basis requirements are correctly implemented in the plant and in procedures.

2.1 IEB 79-14, Small Bore Walkdown Program In response to IE Bulletin 79-14, Turkey Point implemented a major program to reassess the piping support systems for large bore safety-related systems.

As an extension to the project, walkdowns were. performed ofimportant safety-related small bore piping systems to confirm the acceptability of support system design and installation

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 66 2.2 Revised Technical Specification Project Turkey Point implemented a project to go,from custom Technical Specifications to an adaptation of the Revised Standard Technical Specifications in effect at the time, which was the form approved by NRC prior to the current Improved Standard Technical Specifications.

This required the review and reassessment ofeach plant Technical Specification and involved years ofwork between FPL and NRC to develop a new acceptable Technical Specifications.

2.3 Emergency Power System Enhancement Two new emergency diesel generators and a spare safety related battery were installed at Turkey Point in.1990-1991 along with a significant modification of the plant emergency electrical distribution system.

Aspects ofthis major design change from design to implementation were reviewed and evaluated by NRC in both their SER for this project and in numerous plant inspections.

Design basis type calculations were either revised or recreated, including an EDG.

Dynamic Load Study, short circuit/voltage drop calculations, battery sizing, and breaker coordination.

2.4'ontainment Structural.Re-analysis A detailed analysis for the Turkey Point containment building was recreated'to confirm the acceptability ofthis structure.

2.5 Thermal Power Uprate Project The Thermal'Power Uprate project involved the review and reevaluation ofmany safety-related system at Turkey Point. Numerous calculations were recreated including those for.the containmentresponse analysis.

Accident transients werereanalyzed.

Offsitedosecalculations were reperformed.

Thermal hydraulic analyses for the Component Cooling Water (CCW) system were performed. Tank sizing calculations were reperformed.

Safety-related setpoint calculations were reperformed, and control system transients were reanalyzed.

3;0 FPL Vertical Slice Audits and Conclusions Both FPL and NRC have performed'"vertical slice" audits of systems to confirm the adequacy,and completeness ofdesign basis information related to Turkey Point. These audits include, but are not limited to, the auxiliary feedwater SSFI by NRC, NRC audit ofthe Design Basis Program,.

FPL preparation for an. Electrical Distribution Safety. Functional. Inspection (EDSFI), and the service water system operational performance self-assessment awaiting. final closeout inspection by.the NRC.

3.1 Emergency Power, System Because FPL had'implemented the Emergency'Power System (EPS) Enhancement Project, significant'FPL resources had been expended reconstituting and'redesigning the plant's electrical

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 67 distribution system.

Based on the significant number ofinspections performed by the NRC during the EPS.project, the NRC did not conduct an EDSFI at Turkey.Point.

3.2 Service Water System. Operational Performance Self-assessment (SWSOPA)

An SWSOPA was initiated by FPL at Turkey Point in 1995. This self-assessment was approved by the NRC in lieu ofan NRC conducted,SWSOPI followingstaff review ofFPL's self-assessment.

The level ofdocumentation found for the intake cooling water system was considered to be typical for a plant licensed in the early 1970s. Well documented design features provided additional assurances that actual design deficiencies did not exist.

The conclusions reached were that two design related issues which reflected upon current design basis maintenance practices were minor and related to initialplant design. Additionally, the SWSOPA examined current intake cooling water design basis maintenance.

The self-assessment concluded operating, alarm response, off-normal, and emergency operating procedures for these systems were adequate i'n maintaining the system configuration and function. The design change process reviewed during this assessment was found to adequately maintain the design basis and drawings which reflect the as-constructed configuration.

0 An NRC.oversight inspection of the self-assessment was conducted in March, 1995 during the third week ofthe'initial four-week self-assessment.

This inspection resulted in comments on the conduct ofthe self-assessment, but did not result in technical issues.

The self-assessment final report was provided to the NRC in July of 1995, and a follow-up inspection is currently scheduled for early February, 1997..

3.3 Quality Assurance (QA) Audit Conclusions Several QA reports from the beginning of 1993 to September 1996 have been reviewed. These reports included the latest (June 1995) programmatic audit of engineering activities, performance monitoring reports on systems/components, and two 1996 Quality Reports on system reviews..

Based upon these reviews, there is reasonable, assurance that the accuracy of the FSAR and its design basis are being maintained, and that implementing procedures maintain their fidelityto the FSAR. Some findings/comments regarding the FSAR were contained in the reports, but were relatively minor in nature and do not affect the acceptability of the conclusion.

4.0 NRC Safety System Functional Inspections (SSFIs)

The firstof these audits was the NRC SSFI of the Auxiliary,Feedwater (AFW) system conducted in 1985 by the NRC. This audit clearly identified concerns related,to the way design. basis information was maintained and focused on understanding design, bases.

Corrective actions from this audit were sweeping in nature and impacted every area ofplant operations including; training, maintenance controls, testing, maintenance'backlogs, QA auditing and design control. This audit resulted in FPL's decision to implement a Design Basis Reconstitution Program.

Specific concerns related'to AFW design were addressed; corrected,'nd incorporated into,the Design Basis Documents (DBDs). Programmatic improvement efforts became part ofFPL's Performance Enhancement Program (PEP).

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Turkey Point Units 3 k4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 68 The NRC Turkey Point Design Basis Validation Inspection (NIR 89-203) was performed to review the adequacy ofFPL's Design Basis program implemented on 18 selected safety and non-safety systems at Turkey Point. This inspection was conducted as-a SSFI on the Reactor Protection System (RPS), the Component Cooling Water (CCW) system, and on the Electrical Distribution System (EDS). In general, the NRC was impressed by the depth, breadth, and quality ofthe system DBDs, finding them useful and well researched.

On the other hand, the depth. ofverification was identified as a concern, the component level DBDs were found to have errors, and the correctness ofcertain calculations was questioned.

To correct these identified weaknesses, FPL corrected information deficiencies in the component DBDs, enhanced the verification of the component DBDs, and instituted improvements in the calculation payess, including retrieval and indexing ofFPL and vendor calculations in the computerized data. base PassPort.

5.0 Overall Conclusion While the earliest of these audits and inspections identified concerns with the control of design bases information, the programs and projects e.g., the DBD development, instituted by FPL, provided a strong framework to correct the identified deficiencies. Later audits by the NRC and self-assessments by FPL show a major improvement in the control and maintenance of design bases at Turkey Point. These processes have clearly shown that Turkey Point is in control ofits design basis information and is maintaining itin an acceptable manner. Major improvements in configuration control through improved access to design documents, redrawing ofimportant plant drawings,.walkdowns ofimportant mechanical and electrical systems, etc., ensure that design information and its control are significantly improved.

The focus ofmore recent FPL management activities has been to reduce the quantity or number ofchanges occurring at its nuclear units such that the impact on the design bases is reduced.

Backlogs of design changes and required maintenance have been reduced, resulting in improved control of the plant's configuration.

Based upon information presented in this section, as well as in the FPL response to requests [a]

thru [d] of this enclosure, FPL has concluded that the control processes provide reasonable assurance and confidence that the plant is'being operated and maintained within its design bases.

The validityof these configuration control processes are confirmed by continued safe plant operation, self-initiated evaluations, and NRC assessments ofplant performance.

Additionally, the events, inspections, audits and programs discussed above provide the basis to conclude that with reasonable assurance, the design basis information is adequate and available. The corrective action program assures that problems or.concerns which are identified are tracked, evaluated and corrective actions implemented to resolve the concern. The above described processes assure that the design bases are maintained.

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 69

[f] "Supplemental request for information on, design review/reconstitution programs."

The followingoutline provides the organization for the response to this additional information request.

1.0 Nuclear Energy Institute 96-05 Initiative 2.0 FSAR Reviews and Self-Assessments 3.0 Design Basis Reconstitution 4.0 Commitment Details

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Turkey Point Units 3 A 4 Docket Nos. %0 and 251 L-97-26 Enclosure Page 70 1.0 Nuclear. Energy Institute (NEP 96-05 Initiative In response to NRC Information Notice 96-17,,"Reactor Operation Inconsistent with the'Updated Final Safety Analysis Report," dated March 18, 1996, NEI 96-05, "Guidelines for Assessing Programs for Maintaining the Licensing Basis," was issued.

Turkey Point is currently proceeding with the review effort proposed by NEI, which willaddress programmatic and non-programmatic FSAR changes and assess the accuracy of two safety and two non-safety risk significant systems described in the FSAR. Following completion of the "NEI"effort, itis FPL's intention to perform an additional review of.sections ofthe FSAR over a two year period to correct any existing documentation discrepancies.

See details in section 4.0 below. Additionally,FPL engineering is conducting a review ofthe 10 CFR 50.59 screening process at Turkey Point in an effort to.provide more stringent and more consistent controls on this important input to the change process at the plant.

2.0 FSAR Reviews and Self-assessments In response to the events that occurred at Northeast Utilities'illstone plant, Turkey Point engineering conducted a self-assessment of.the FSAR in March and:April of 1996. This review was conducted by a team of.senior FPL staff from.Engineering and Quality Assurance and encompassed about three quarters of the Turkey Point FSAR. In that review, 96 comments and/or questions were generated.

These comments were broken down into four categories:

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67 Required no change or the change was already in progress

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24 -

Were administrative or very minor

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5 Required the FSAR to'be updated to reflect the approved design or procedure

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.Required a plant or procedure change The general conclusion ofthis effort is that the important design bases information is correctly documented in the FSAR, but that some specific details were found to be inaccurate.

The majority of items identified related to equipment that had been abandoned in place, but that the FSAR had not been appropriately updated.

FPL has and is continuing to implement a program to address and deal with the issue of abandoned plant equipment.

Documented discrepancies have been resolved and incorporated into the FSAR.

In addition to, but separate from the self-assessment effort, an operational review of the FSAR was conducted by senior operations and training staff related to operational statements in the FSAR. This review, completed. in,1996,.identified 45,discrepancies and/or questions related to the FSAR which can be broken. down as follows:

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21 -

Required no change or change was in progress

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16 -

Requiied an administrative or minor wording change

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8 Required the FSAR to be updated to reflect an approved design or procedure

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'0 Required a plant or procedure change h

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 71 The results of this review are similar to that identified during the FSAR self-assessment process.

Changes identified by this review process have been incorporated into the FSAR.

3.0 Design Basis Reconstitution A design basis reconstitution was completed at Turkey Point on a selected number of systems and licensing basis information. See the discussion on DBD in the Turkey Point response to request

[c].

4.0 Commitment Details The design bases and design bases information are adequately maintained and retrievable. FSAR reviews performed to date provide reasonable assurance that design basis information is correctly documented, however, some specific details within the FSAR were found to have discrepancies.

FPL is planning to perform a graded FSAR review over the next 2 years to further address the accuracy ofinformation it contains. This review willbe focused on sections of the FSAR that have not recently:seen significant updates as a result of other design basis projects e.g., Thermal Uprate and EPS have revised/updated selected portions of the FSAR for agreement with plant operating and maintenance practices.

Select validation ofdata willbe performed on information contained within the sections reviewed. This review willcommence followingcompletion ofthe NEI review effort scheduled forApril 1997. Ifthe need is identified as a result of these reviews, a Safety System Functional Assessment willbe completed on an appropriate system or group of systems.

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Turkey Point Units 3'&4 Docket Nos. 250 and 251 I 97-26 Enclosure Page 72 Appendix A Partial List ofAcronyms A/E AFW BIT CM CNRB CR CRN CIRAC

'DBD DCR EDG EDS

'EDSFI ENG QI EOP EQ ERT ESP ESFAS FCP FPL FSAR GL ICW INPO ISI ITOP LER MEP MOV NCR NEI Architect/Engineer AuxiliaryFeedwater Boric Acid Injection Tank Configuration Management Company Nuclear Review Board Condition Report Change Request Notice Commitment Tracking Design Basis Document Drawing Change Request Emergency Dicscl Generator Electrical Distribution System Electrical Distribution System Functional Inspection

Engineering Quality Instruction Emergency Operating Procedure Engineering Package Equipment Qualification Event Response Team Engineering Support Personnel Emergency Safety Feature Actuation System FSAR Change Package Florida Power and LightCompany Final Safety Analysis Rcport NRC Generic Letters Intake Cooling Water, Item Equivalency Evaluation NRC Information Notices Institute OfNuclear Power Operations Inservice Inspection Implcmcntor Turnover Package Licensee Event Reports MinorEngineering Package Motor-Opcratcd Valve Non-Conformance Rcport Nuclear Energy Institute NNS Non-PC/M NPS NRC OEF PC/M PEG PEP PMAI PMT PNSC POD PRA PRB PWO QA QI RCS REA SAR SEN SER SO SOER SSFI SSC SSH SWSOPI SWSOPA TEDB TQAR TSA UFSAR Non-Nuclear Safety Non-Plant Change/Modification Nuclear Plant Supervisor Nuclear Regulatory Commission Operating Experience Fccdback Plant Change/Modification Production Engineering Group Performance Enhancement Program Plant Manager Action Item Post-Maintenance Testing Plant Nuclear Safety Committee Plant Operating Drawings Probabilistic Risk Asscssmcnt Plant Review Board Plant Work Order Quality Assurance Quality Instruction Reactor Coolant System Request forEngineering Assistance Safety Analysis Report Significant Event Notification Safety Evaluation Rcport Significant by Others Report Significant Operating Expericncc Rcport Safety System Functional Inspection System, Structure &Component Significant Safety Hazard Service Water System Operational Performance Inspection Scrvicc.Water System Operational Performance Self-assessment Total Equipment Data Base Topical Quality Assurance Rcport Temporary System Alteration Updated Final Safety Analysis Rcport

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Turkey Point Units 3 &4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 73 Appendix B QA Audits,-Findings and Corrective Actions Several Findings were documented and/or Condition Reports were issued'as a result of audits with respect to translating design basis into procedures.

They were considered minor in'nature and did not affect conclusions regarding strengths.

They were, as follows:

Audit QAO-PTN-96-002 - PMON ¹1, Post Accident Sampling System 33 found that a note on drawing 5613/5614-M-3036, Sh. 1, that prescribed that in case offailure of the normal flowpath-to PASS, valve PASS-3/4-010 was to be opened. But this note had not been incorporated into procedures.

Engineering'has removed the note.

identified a drawing inconsistency regarding seismic boundary classification of the normal sample coolers. Dwg. 5610-M-3094, Sh. 1, indicates by flags that the PASS cooler is seismic. But drawing 5613/5614-M-3036, Sh. 1, do not have similar flag designators for the normal coolers. Engineering has revised the drawings to show flag designators.

QR9~22 identified seismic boundary inconsistency between Post Accident Containment Ventilation (PACV) system drawings 5613/5614-M-3094, Sh. 1, and FSAR Appendix 5, and section 9.12.1.2. Engineering evaluated same and has revised the drawings and made minor wording changes to the FSAR to indicate that, the PACV, piping may be seismically installed; 2.

Audit QAO-PTN-95-018 - PMON ¹2, Pressurizer Relief System QR95-~ raised a concern. that the wording ofFSAR section 4.3 was misleading regarding the OMS setpoint because it indicated that the OMS varies the setpoint of the PORV as RCS temperature varies. But, operating procedures effectively eliminate this variable. Engineering's evaluation explained that the description was a design feature. Engineering agreed to submit a clarification to the FSAR, and has revised same.

'QR9~115 identified a quality group transition boundary error on Unit 3 power operated reliefvalves..'Boundary flags were on.the inlet versus the outlet. Dwg.

5613-M-3041, Sh. 2, has been revised.

3.

Audit QAO-PTN-95-014 - PMON ¹1, Containment Spray. System Q~M523 found that the. alignment of all four high head safety injection pumps to a single refueling water storage tank, e.g., during refueling, had not been evaluated.

Engineering performed an evaluation and determined that the alignment was acceptable.

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Turkey Point Units 3 k,4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 74

4. Audit QAO-PTN-95-008 - PMON¹1, Waste Disposal System - Gaseous

- FSAR description indicated that gaseous monitoring was shown on a drawing, including the CO7 gas analyzer panel, but this panel's hydrogen and oxygen analyzers have been inoperable for years. Technical Department evaluated the finding and made plans to abandon the equipment formally. The system engineers reviewed the FSAR sections for their systems, but found no additional discrepancies.

g~~23Q found that the normal valve position for the pressurizer relief tank to gas analyzer sample valve prescribed by a chemistry pmcedure was in conflict with those shown by the FSAR description and'system drawings. The procedure was in error and has.been revised.

5.

QAO-PTN-94-020 - PMON ¹1, Nuclear Instrumentation Review Bg<QngJ. - Reactor trip setpoints changed in a procedure without.processing. an authorization of.the procedural'change For main steam safety valve testing, a safety evaluation had been reviewed and approved for prescribing reactor. trip setpoint values. However, nobody had changed the implementation procedure to reflect these setpoints.

Technicians installed the new setpoints and only referred to the safety. evaluation's file number as the reason.

I&C's and maintenance planning practices were reviewed and have been revised to prevent this.

Audit QAO-PTN-93-006 - PMON ¹4, Waste'Disposal System - Liquid

'The report recommended that the FSAR description of boron recycle be annotated to explain that the system is no longer in use. The report also recommended upgrading the procedure format and content quality.

Since this audit, the abandoned equipment program has been developed and PC/Ms written'to delete the FSAR section on boron recycle. Also, the procedures have been changed to the upgrade format. The procedure willbe reviewed by QA during the next review ofthis system.

(This audit/review should be complete by the end of 1996 or early 1997).

Several Findings/Condition Reports or comments were documented in,reports'and audits with respect to maintaining design basis with respect to SSCs. They were considered minor in nature and did not affect conclusions regarding strengths.

They were, as follows:

7.

Audit QAO-PTN-96-005 - PMON ¹4, CVCS This report identified that a seismic anchor for the boric acid supply piping had:been removed without prior evaluation ofits seismic affect. The anchor removed was for a BITrecirculation pump that was awaiting formal abandonment.

A condition report

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Turkey Point Units 3 k 4 Docket Nos. 250 and 251 L-97-26 Enclosure Page 75 was written by the system engineer.

An evaluation determined that no operability concern existed.

8. Audit QAO-PTN-95-015 - PMON ¹2, RPS and ESFAS A conditon report found that of the three portable fans required to be stored in the Cable Spreading Room by procedure, only one was there. Supplemental cooling of the DC Equipment/Inverter rooms using these portable fans and their storage is described in the FSAR. The Operations resolution to ensure fans are properly stored, was to add a check to the Nuclear Plant Operator logsheet.

(This CR was unrelated to RPS and ESFAS but was included under PMON ¹2 because the condition was identified while in the cable spreading room observing an RPS'test).

9. Audit QAO-PTN-95-008 - PMON ¹1, WDS-Gaseous A condition report found that the capability to operate the Gas Analyzer sample valve from the Pressurizer ReliefTank was not indicated on the system drawings or in the FSAR. Engineering has since revised system drawings to reflect this function.

10.

Audit QAO-PTN-94-016 - PMON ¹6, Configuration Control ofDrawing for Containment Spray Reset Pushbutton A drawing for the system was found to be incorrect. A switch replacement could have resulted in an incorrect wiringconfiguration. A drawing change request was issued to correct the drawing.

11.

Audit QAO-PTN-94-003 - PMON ¹10, Unit 3 EDGs A condition report found that the Unit 3 Emergency Diesel Generators Day Tank's level switches which are within a seismic boundary had been procured without any seismic requirement being specified. Engineering evaluated the switches and determined that they would remain functional after a seismic event. Corrective actions included update ofthe equipment data base to add seismic requirements for these switches.

12.

Audit QAO-PTN-93-028 - PMON ¹1, Spent Fuel Cooling,'System A condition report. found that high radiation area:gates-had been installed without design authorization. 'The gates had been attached to supports for a Spent Fuel Cooling system filter, and also impinged on the Component Cooling Water piping.

Engineering evaluated the condition and determined that it was acceptable. Adrawing change was made to document the condition.

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