ML17354A426

Forwards Response to NRC Ltr Re Violations Noted in Insp Repts 50-250/96-13 & 50-251/96-13 on 961117-1231.Corrective actions:non-licensed Operator Involved in Event Was Counseled on Need for Compliance to Procedures

ML17354A426
Person / Time
Site:	Turkey Point
Issue date:	02/28/1997
From:	Plunkett T FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-97-043, L-97-43, NUDOCS 9703110177
Download: ML17354A426 (9)

Text

CATEGORY 1 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

$ -ACCESSION NBR:9703110177 DOC.DATE:

~ 97/02/28 NOTARIZED: NO DOCKET IL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 50-251 Turkey Point Plant, Unit 4, Florida Light

~

Power and C 05000251 AUTH. NAME AUTHOR AFFILIATION PLUNKETT,T.F. Florida Power & Light Co.

RECIP.NAME 'ECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Forwards response to NRC ltr re violations noted in insp repts 50-250/96-13 a 50-251/96-13 on 961117-1231.Corrective actions:non-licensed operator involved in event was counseled on need for compliance to procedures.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-3 PD 1 1 CROTEAU,R 1 1 INTERNAL: AEOD/SPD/RAB 1 1 1 1 DEDRO 1 1 FILE CENTER 1 1

'RR/DISP/PIPB 1 ' NRR DRCH HH B 1 1 NRR/DRPM/PECB 1 1 NRR/DRPM/PERB 1 1 NUDOCS-ABSTRACT 1 1 OE DIR 1 1 OGC/HDS3 1 1 RGN2 FILE 01 1 1

• E ERNAL: LITCO BRYCEiJ H 1 1 NOAC 1 1 NRC PDR 1 1 NUDOCS FULLTEXT 1 1 t NOTE TO ALL "RIDS" RECiPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN 5D-5(EXT. 415-2083) TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL 'NUMBER OF COPIES REQUIRED: LTTR 18 ENCL 18

Florida Power 5 Light Company, P.O. Box 14000, Juno Beach, FL 33408-0420 FEB 28 1997 L-97.-043 10 CFR 2.201 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. CD 20555 Re: Turkey Point Units 3 S 4 Docket Nos. 50-250/251 Reply to Notice of Violation NRC Ins ection Re ort 96-13 Florida Power & Light Company has reviewed the subject inspection report and, pursuant to 10 CFR 2.201, the required response is attached.

If there are any questions, please contact us.

Very truly yours,

~ g7~Pg~

T. F. Plunkett President Nuclear Division CLM Attachment cc: Luis A. Reyes, Regional Administrator, Region II, USNRC T. P. Johnson, Senior Resident Inspector, USNRC, Turkey Point Plant h

97031'L0177 970228 PDR ADOCK 05000250 8 PDR IIIIIIIlIIllllMIHlmlElmlIil3I3JII an FPL Group company

e Attachment to L-97-043 Page 1, REPLY TO NOTICE OP VIOLATION RE: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 NRC Inspection Report 96-13 FINDING "During an NRC inspection conducted on November 17 to December 31, 1996, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG 1600, the violation is listed below:

Technical Specification 6.8.1 requires that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, t February 1978.

Item 7.a of Regulatory Guide 1.33, .Revision 2, February 1978, Appendix A, recommends the use of procedures for activities involving the liquid radwaste disposal system.

Procedure O-OP-061.12 Waste Disposal System-Waste Monitor Tank (WMT) and Demineralizer Operation, section 5.1, Recirculation and Sampling of the WMTs, requires the non-licensed operator to independently verify the valve lineup prior to WMT recirculation per the appropriate procedure attachment.

Contrary to the above, on December 17, 1996, the non-licensed operator failed to adequately implement section 5 ' of procedure O-OP-061.12, as the valve lineup independent verification was not performed as documented on the appropriate procedure document.

Subsequently, during B WMT recirculation, an overflow and spill of the A WMT occurred.

This is a Severity Level IV violation (Supplement I)."

e' Attachmen't to L-97-043 Page 2 RESPONSE TO FINDING Florida Power 6 Light Company (FPL) concurs with the finding.

Reason for the violation:

The recirculation of the Waste Monitor Tanks (WMT) for sampling is a routine evolution that is controlled by procedure O-OP-061.12, Waste Disposal System-Waste Monitor Tanks and Demineralizer Operation. On December 17, 1996, the C WMT was aligned and placed on recirculation for sampling. During this process the B WMT overflowed to the Radwaste Building floor. The most probable cause of this event was a valve misalignment (the misalignment could not be verified) that allowed a transfer of water from the C WMT to the B WMT, when the C WMT was placed on recirculation. The valve misalignment was not found prior to starting the recirculation of C WMT because the Non-licensed Operator performing the task failed to comply with the independent verification requirements of procedure O-OP-061.12. The procedure requires an independent verification of the valve lineup prior to starting a pump for a recirculation.

The overflow of the A WMT that occurred on February 26, 1996, was due to a valve being left open, instead of closed as required by O-OP-061.12, when recirculation of the A WMT for sampling was terminated. Due to this misaligned valve, water was inadvertently transferred to the A WMT when the B WMT's contents were being transferred to the A monitor tank (different-than the A WMT). The cause of this event was that the Non-licensed Operator failed to complete the requirements of O-OP-061.12 when the recirculation of the A WMT was completed. When the February 96 event occurred, procedure O-OP-061.12 did not require independent verification for WMT valve manipulations. The addition of the independent verification requirement was a corrective action for this earlier event.

The overflow of A WMT on February 26, 1996, was due to the Non-licensed Operator not completing the requirements of O-OP-061.12.

When the A WMT recirculation was completed, leaving a normally closed valve open, independent verification of the valve position was not required. The December overflow of the B WMT was due to a most probably mispositioned valve where the Non-licensed Operator failed to comply with the independent verific'ation requirements established as a barrier to prevent a WMT overflow recurrence.

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

The Non-licensed Operator involved in this event was counseled on the need for compliance to procedures, management's expectations on the conduct of tasks, and the professional manner required for work in a nuclear power plant.

0 Attachment to L-97-043 Page 3 A root cause analysis of the tank overflow event was performed.

Seven possible scenarios were analyzed. Four were eliminated based primarily on satisfactory tank recirculations before and after the spill; the remaining three all required valve mispositions/repositions to accommodate the known facts of the event.

On-shift supervision has been instructed to observe'volutions involving the movement of radioactive waste water for a two month duration to ensure there are no further procedural compliance concerns or procedure discrepancies. Identified concerns are forwarded to the Operations Supervisor for resolution.

4. Corrective actions which will be taken to prevent further violations:

The Operations Supervisor discussed the details of this event and corrective actions with the on-shift Non-13.censed Operators.

The Non-licensed Operator involved in this has been permanently reassigned to a position out of the Nuclear Operations Department.

As part of the on-shift supervision's observation of radwaste movements, procedure O-OP-061.12 is being reviewed to determine if further enhancements would be beneficial.

A radwaste control panel remote alarm has been installed in the Unit 3 6 4 Control Room. Prior to its installation, Operations personnel had been instructed that an Operator be continuously stationed in the area of the WMTs during radioactive waste water transfers or WMT recirculation.

5. The date when full compliance was or will be achieved:

Full compliance was achieved on December 17, 1996, with the completion of the valve alignment check by Operations Management, and completion of the required sections of O-OP-061.12.