ML20101H977
| ML20101H977 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 03/19/1984 |
| From: | Williams J FLORIDA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20101H919 | List: |
| References | |
| L-84-75, NUDOCS 8412280392 | |
| Download: ML20101H977 (3) | |
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FLORIDA POWER & LIGHT COMPANY March 19,1984 L 75 Mr. Janes P. O'Reilly Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101 Madetta Street NW, Suite 2900 Atlanta, Georgi a 30303
Dear Mr. O'Reilly:
Re: Tarkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Inspection Report 83-41/40 Florida Power & Light Company has reviewed the subject inspection report and a response is attached.
The actions taken to improve the effectiveness of our progran are fully described in our letter dated February 17, 1984, which included the Turkey Point Performance Enhancement Progran.
There is no proprietary information in the report.
Very truly yours, WW L J. W. Willi ans, Jr.
Vice President Nuclear Energy Department JWW/PLP/js Attachment '
cc: Harold F. Reis, Esquire PNS-LI-84-98 B412290392 840406 PDR ADOCK 05000250 0
PDR PEOPLE... $ERVING PEOPLE
o ATTACWlENT RE:
TURKEY POINT UNITS 3 & 4 DOCKET WS. 54 250, 50-251 INSPECTION REPORT 83-41/40 FINING I:
. Technical Specification (TS) 6.8.1 requires th6t written procedures and administrative policies shall be established and implemented in safety related systems. Maintenance Procedure (MP) 12207.1, Intennedi ate Range Nuclear Instrumentation Compensating Voltage Adjustment, requires that shutdown rods be on the core bottom prior to instrument maintenance commencenent.
Contrary to the above, on Decenber 4,1983, instrument maintenance in accordance with MP 12207.1 was commenced while shutdown rod banks "A" and "B" were not on the core bottom.
RESPONSE
1.
FPL concurs with the finding.
2.
The finding occurred because the procedure was not properly followed.
3.&4.
As corrective action, MP 12207.1 was revised adding a precaution to wait 20 minutes after shutdown prior to commencing the procedure and deleting the requirement that shutdown rods be on the core bottom.
5.
Full compliance was achieved prior to January 15, 1984.
FI NING II:
Technical Specification (TS) 6.8.1 requires that written procedures and administrative policies shall be established, implemented and maintained for safety related systems.
The licensee f ailed to comply with TS 6.8.1 in the area of turnover and testing of the plant change / modification on several occasions.
Separate occasions and procedural requirements are discussed in "a" through "c", listed below:
- a.. Licensee Administrative Proedure 0103.10 Updating and Using P1 ant i
Drawing, Section 3.2.1 requires the Technical Department to provide interim drawings to reflect recent changes to systems.
Contrary to the above, interim drawings were not provided for the Safety i
Injection Test Recirculation (SITR) systen, the Containment Spray Test Recirculation (CSTR) system, and the Under-Voltage Sub-Systen (UVS) for ESF buses.
b.
Licensee Administrative Procedure 0190.15, Pl ant Projects - Approval, l
Implementation and Regulatory Requirements, requires training / operating drawings be provided the Start-up Organization at the time of system I
accept ance.
l
I C:ntrary to tha (1:ve, training /oparating drawings were nst prcvided th2
' Start-up Organization at the time of system acceptance for the SITR system, CSTR system and the UVS for ESF buses.
c.
Licensee Administrative Procedure 0103.17, System / Equi pment, Acceptance / Turnover to Nuclear Plant Staff,' requires a complete as-built package submittal from the Construction Department at the time of acceptance.
Contrary to the above, a complete as-built package was not provided for modifications to the SITR system, CSTR system and the UVS for ESF buses.
RESPONSE
1.
FPL concurs with this finding and finding B of Inspection Report 83-32 which was similar in nature. Our response to this finding of Inspection Report 83-32 had been delayed in order to respond to the similar findings together.
3 2.
The finding occurred because of inadequate implementation of the progran for startup and testing following hardware modifications.
3.
As corrective action, the drawings and as-built information were provided.
4.
In order to prevent recurrence, the Start-up Program is being upgraded to include the seven features noted in the inspection report.
5.
Full compliance will be achieved by April 2,1984 when the upgraded startup program will be in effect.
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