ML20004F968

Forwards Response to NRC 810218 Ltr & Notice of Violation Re 810129 Failure to Have Operator Present at Controls During Full Power Operation

ML20004F968
Person / Time
Site:	Turkey Point
Issue date:	04/20/1981
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML17340A841	List: ML20004F966 ML20004F968
References
FOIA-81-110 L-81-174, NUDOCS 8106260360
Download: ML20004F968 (5)

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g FLORIDA .'OWER & LIGHT COMPANY April 20,1981 L-81 -l 74 Mr. Victor Stello, Director Office of Inspection'and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Stello:

Re: Turkey Point Unit 3 Docket No. 50-250 10 CFR 2.201 Response to Notice of Violation dated February 18, 1981 The attachment to this letter contains Florida Power & Light Company's reply to your letter and Notice of Violation of February 18, 1981 as required by 10 CFR 2.201. Our reply pursuant to 10 CFR 2.205 has been provided separately as requested.

Very truly yours, W

bert E. Uhrig Vice President Advanced Systems and Technology

-REU/RAX/mbd Attachment cc: Mr. J.P. O'Reilly, Region II Harold F. Reis, Esquire e

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8106260300

- Re: Turkey Point Unit 3  ;

.'- .,' Docket No. 50-250 ,

10 CFR 2.201 Response to '

Notice of. Violation dated Februa ry 18, 1981 Page 1 ATTACHMENT Finding:

10 CFR 50.54(k) states that an operator or senior operator li_cen' ed pursuant.

to Part 55 of this chapter shall be present at the controls at all times during operation of the facility. Technical Specification 6.8.1 requires that -

written procedures and administrative policies be established, implemented and maintained that meet or exceed the requirements and recommendations of Section 5.1 and 5.3 of ANSI N18.7-1972, Appendix "A" of USNRC Regulatory Guide 1.33; this includes plant operating procedures. Plant Operating Procedure 0103.2, Responsibilities of Operators On-Shift and Maintenance.of Operating Logs and Records, states in Section 5.3.3 that the Nuclear Control Center Operator (NCCO) shall have an unobstructed view of and access to the control panels, including' instrumentation displays and alanns. He shall not leave the Surveillance Area (Figure 1) for any non-emergency reason without obtaining a qualified relief. Section 5.3.4 states that a single operator shall not assume the NCCO responsibility for both units at the same time unless so directed and such action is in compliance with Technical Specification 6.2.2 or is necessitated by emergency conditions.

Contrary to the above, at about 11:45 a.m. on January 29, 1981, the NRC Resident Inspector observed Turkey Point Unit 3 operating at full power without an operator present at the controls. The assigned Unit 3 operator was in a room behind the Unit 4 instrument panels which precluded visually monitoring the Unit 3 reactor conditions. The roan, although open to the control room, is outside the surveillance area specified in Plant Operating Procedure 0103.2. A qualified relief had not been obtained and an operator leaving the surveillance area was not necessitated by an emergency condition, nor was the Unit 4 operator directed to assume NCC0 responsibilities for both units.

Response

1. - (1-1) FPL concurs with the finding, however, as discussed in our reply pursuant to 10 CFR 2.205, we take exception to the severity level classificatio,n.

(1-2) The reason for the violation was that the Nuclear Control Center Operator (NCCO) did not adhere to the procedural requirement to obtain a relief prior to leaving the surveillance area.

(1-3) As corrective action:

(1) The surveillance area has been re-defined and pennanent red colored floor tiles have been installed to outline the -

surveillance area boundary.

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Re:

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Tur ey Point Unit-3

. - ~. Docket No.50-25C 110 CFR 2.201 Response to Notice of< Violation dated ,

February 18, 1981 Page 2 b

(2) Changes have been made to Administrative Prtcedure 0103.2,

- Responsibiliti'es of Operators On-Shift and Maintenance of Operating Logs and Records, which redefined the proper

- procedure which must be taken by the NCC0 in order to leave the ~ surveillance area. The~ third NCC0 on shift is now required to normally stay in the. surveillance area and to

. verbally notify and obtain acknowledgment from each operator with unit responsibility prior to leaving the surveillance area.

(3) A name display system'has been implemented that-positively identifies _the operator who has unit responsibility. In order'to transfer unit responsibility from one operator to another, the name display must be changed by_ the oncoming i operator as part of his turnover acknowledgement.

(4) All operators have been instructed in writing of their responsibilities.

(5) Plant management has begun a program of random visits to the Control Room at unannounced intervals. During these visits,'the management will verify that the licensed operators are continuing to perform their duties in a professional manner.

(1-4) We will also take the following long and short term corrective actions to avoid similar problems in the future.

Short term:

(1) The surveillance area boundaries will be redefined by April 30, 1981 to fully meet the intent of Regulatory guide 1.114 as discussed at the management meeting with I&E personnel.

l (2) FP&L Management will conduct meetings with Licensed

! Operators by May 31, 1981 to emphasize the importance of this issue, to provide guidance on compliance with the Regulatory Guide, and to discuss management enforcement actions that will be taken should further deficiencies occur.

i (3) Movable rope or chain barriers will be placed at j appropr. fate openings to the surveillance area boundaries by

- May 15,1981 to give a more physical means of identifying the surveillance area and to limit access to this area by non licensed personnel . -

(4) Plant management will conduct meetings with Licensed Operators to discuss Operator concerns, management policies, and Operator safety responsibilities.

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• - Re: -

Turkey. Point Unit 3

.- ,. . - Docket 'No. 50-250 10 CFR 2.201 Response to Notice of Violation dated

' February 18, 1981 Page 3 Lcng term:

, (1) A human factors engineering study of the Control Room layout will be conducted by January 1,1982.

(2) The Nuclear Watch Engineer's office will be modified by January 1,1982 to allow him to see the control panels while in his office.

(3) Other physical changes will be made to permanently re-locate such items as water fountains, chart lockers, bookcases and coffee pots in short term item 1, above.

This will be accomplished by January 1,1982.

(1-5) Immediate corrective action was taken on January 29, 1981, in response to the violation. Additional corrective action, described in 1-3 above, was taken between January 30, 1981 and February 13, 1981. Additional short and long term cor-rective action to enhance compliance will be completed by the dates provided with each item in 1-4 above.

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. STATE OF FLORIDA

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COUNTY'OF DADE' ')-

4 Robert E.

Uhrig, being first duly sworit, deposes'and says:

thelLicensee herein;That he-'is a Vice President of Florida Power & ,

.' -That.he~has executed the foregoing document; that the state--

'best of;his knowledge,ments made in this said document are true and is authorized . to execute the ' document on ' behalf of saidinform Licensee.

/

Robert E. Uhrig [

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i. Subscribed and sworn to before me this

~ > o day of &c.42_flL , 19p L. -

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. NOTARY PUBLIC, i[andforthecountyofDade, State of Florida pr.::.ry FWi:. Cta.: c' T %J at L ::;e t M.y cc.wnu:- E,: n .r.:.c 23. r-c3 p My commission expires:. Ev.:.ec t . w ra. c.z:d Ex: .o I.7,.y I

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