ML20084H071
| ML20084H071 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 01/27/1984 |
| From: | Williams J FLORIDA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20084H057 | List: |
| References | |
| L-84-21, NUDOCS 8405070438 | |
| Download: ML20084H071 (4) | |
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FLORIDA POWER & LIGHT COMPANY January 27, 1984 L-84-21 Mr. Janes P. O'Reilly Regional Administrator, Region II U. S. Nuclear Regul atory Commission 101 Marietta Street NW, Suite 2900 At1 ant a, Georgi a 30303
Dear Mr. O'Reilly:
Re:
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Inspection Report 83-32 Florida Power & Light Company has reviewed the subject inspection report and a response is attached.
There is no proprietary information in the report.
Very tr ly yours, J. W. Willi ams, Jr.
Vice President Nuclear Energy Department JWW/PLP/js Att achment cc:
Harold F. Reis, Esquire PNS-LI-84-36 8405070438 840302 PDR ADOCK 05000250 G
PDR PEOPLE.. SERVING PEOPLE u__
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ATTACIMENT RE: TURKEY POINT UNITS 3 AND 4 DOCKET N05. 50-250, 50-251 IE INSPECTION REPORT 83-32 FIlOING A:
Technical Specification 6.0.1 requires in part that written procedures be established and implemented.
Contrary to the above, Operating Procedure (0P) 1001.1, dated May 20, 1983, Filling and Venting the Reactor Coolant System (RCS), was not properly implemented in that:
(1) The fill of the RCS on August 17,1983, from 40% pressurizer level (wide range indication) to an indication of off-scale high was performed prior to the confirmation of a proper alignment and test of the Overpressure Mitigating System as required by Steps 8.3.1 through 8.3.3 and 8.7.
(2) Procedurally the only recognized method of water addition to the RCS was via a single charging pump on slow speed. The fill of the RCS as described in the paragraph above was performed with a primary water transfer pump without using OP 1001.1.
(3)
Steps of OP 1001.1 were being marked not applicable (N/A) without the shift supervisor's authorization as required.
RESPONSE
1.
FPL concurs with the finding.
2.
The reason for this finding was that the shift personnel did not fully comply with the procedure.
l 3.
As corrective action the RCS fill was iramedi ately terminated and the operating shift was counseled on adherence to all procedures. The fill I
and vent procedure was discussed and it was explained that certain steps, marked with an asterisk, could be marked N/A for a partial fill and that all other steps shall be complied with.
4.
This finding was a topic during a Operations Department Supervisor's staff meeting. Adherence to procedures has also been reemphasized in plant management meetings and in management meetings with plant personnel and corporate managers.
5.
Full compli ance was achieved on September 30, 1983.
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ATTACM4ENT RE: TURKEY POINT UNITS 3 AND 4 DOCKET N05. 50-250, 50-251 IE INSPECTION REPORT 83-32 l
FINDING 8:
Technical Specification 6.8.1 requires that written procedures be established and maintained.
Contrary to the above, on August 18, 1983, Administrative Procedures (AP) 0103.5, Administrative Control of Valves, Locks and Switches, dated April 17, 1983, and Operating Procedure 0202.1, Reactor Startup - Cold Condition to Hot Shutdown Conditions, dated May 12, 1983, were found to have not been maintained to reflect the configuration of the Emergency Containn.ent Filter System as modified by Plant Change /Mcdification 80-096.
RESPONSE
1.
FPL concurs with the finding.
2.
The reason for the finding is that our startup turnover program was i n adequ ate. The reason, corrective action, and full compliance date will be fully discussed in our response to Inspection Report 250/83-41 and 251/83-40.
FINDING C:
Technical Specification 6.8.1, and paragraph 5.1.6.1 of ANSI N18.7-1972 as implemented by plant AP 0190.19, Control of Maintenance on Nuclear Safety-Rel ated and Fire Protection Systens, require that maintenance which can affect the performance of nuclear safety-related equipment be appropri ately prepl anned.
In support of the preplanning FPL Topical Quality Assurance Report, TQR 4.0 and Quality Procedure (QP) 4.1, Rev.13, Control of Requisitions and the issuance of Purchase Order for Spare Parts, Replacenent Items and Services, requires, in Step 5.1.1, that the originator of a requisition include information such that the iten requested is describcd in enough detail that it is clear what is desired. Additionally, step 5.8 requires the item description to be in sufficient detail to allow a nonnal Stores Department inspection to be satisfactory tc assure that the item meets the requirements of the original equipment and the needs of the plant.
Contrary to the above, the preplanning for the work described in plant work orders PWO-2053 and 2054 was inadequate in that it f ailed to include in the work package, a plant maintenance instruction, entitled Packing Val.ves Using Grafoil Dieformed Packing, which contains specific directions on the installation of anti-extrusion rings with an accompanying di agran depicting the relative position of the rings with respect to the actual grafoil p acki ng. Additionally, the " requisition on purchasing agent" (RPA) number 575-7102, for packing of motor operated valves MOV-535 and MOV-536, f ailed to provide enough detail in the description of the packing.
Consequently, maintenance was performed on two valves using the wrong packing.
Al fACMENT RE: TURKEY POINT UNITS 3 AND 4 DOCKET N05. 50-250, 50-251 IE INSPECTION REPORT 83-32
RESPONSE
1.
FPL concurs with the finding.
2.
The work package did not include the rnaintenance instruction because the individual compiling the packace wasn't aware of the instruction. The RPA didn't provide enough detail because the packing had previously been bought from a vendor who knew what packing was being ordered, but then the order was given to a new vendor.
3.
As corrective action, the apprcpriate packing was obtained and installed in the valves.
In addition, all packages of grafoil packing in Stores were inspected ar.J restored so that all packages now contain the proper packing rings.
4.
In order to prevent recurrence, all appropri ate mechanical inaintenance personnel were trained in the proper packing of valves using grafoil packing and the hardcard for the packing was rewritten to include sufficient detail.
5.
Full compliance was achieved prior to January 26, 1984.
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