ML20127F966
| ML20127F966 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 03/18/1985 |
| From: | Williams J FLORIDA POWER & LIGHT CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20127F861 | List: |
| References | |
| L-85-114, NUDOCS 8505200619 | |
| Download: ML20127F966 (3) | |
Text
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FLORIDA POWER & LfGHT COMPANY 35 mR21 P 1 r 56 MAR 1 0 1985 L-85-114 Or. J. Nelson Grace Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101-Marietta Street NW, Suite 2900 Atlanta, Georgia 30323
Dear Dr. Grace:
Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Inspection Report 250-84-41 and 251-84-42 Florida Power & Light Company has reviewed the subject inspection report and a response is attached.
There is no proprietary infonnation in the report.
//// /
J. W. Williams, Jr.
Group Vice President Nuclear Energy JWW/JA/ms
' Attachment cc: Harold F. Reis, Esquire G
PEOPLE... SEf4VING PEOPLE
ATTACimENT Re: Turtey Point Units 3 and 4 Docket No. 50-250, 50-251 IE Inspection Report 250-84-41 and 251-84-42 FINDING 1:
10CFR 50 Appendix B, Criterion XII, and the licensee accepted QA Program (FPL-NQA-100A), Revision 7) collectively require that measures be established to assure that tools, gages, instruments, and other measuring and test devices are controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits.
Contrary to the above, measures have not been adequately established in that the calibration status of numerous instruments were unknown.
Adequate measures have not been provided as indicated by the following examples:
a.
AP 0190.9, Control of Measuring and Test Equipment, paragraph 8.5, does not delineate controls applicable to the removal of instruments f rom service that are past due calibration or are found to exceed required calibration tolerances.
This procedure only delineates controls applicable to removing instruments from service that cannot be repaired and recalibrated.
b.
Maintenance Procedure 0731, the implementing procedure for calibration of measuring and test equipment in the Mechanical Maintenance Department, does not address removing instruments f rom service when no longer in calibration.
RESPONSE
1)
FPL concurs with the finding.
2)
The reason for the finding was inadequate procedural guidance in that:
a)
Administrative Procedure (AP) 0190.9 did not delineate controls for the removal of measuring and test instrumentation from service which are past due calibration or are found to exceed required calibration tolerances.
b)
Maintenance Procedure (MP) 0731 does not address the removal of measuring and test instrumentation from service when no longer within required calibration tolerances.
IE Inspection R port 250-84-41. 251-84-42 Page 2 3)
AP 0190.9 was revised and approved for use to specifically delineate controls for the removal of instrumentation from service.
The following additional requirements have been added to Section 8.5.1:
a)
As Found data shall be taken (where it is possible to take this data).
b)
The calibration sticker shall be removed.
c)
A REJECTED sticker shall then be affixed to the instrument.
The REJECTED sticker will contain the following information:
(1)
Instrument Identification Number (2)
Date of Rejection i
(3)
Reason for Rejection (4)
Person Rejecting the Instrument d)
The words " Removed from service" shall be entered in the Use Log I
with the date.
A procedure change request was initiated on March 1,1985 to MP 0731 to address the removal of instruments from service when no longer in calibration.
4)
MP 0731 will be revised, consistent with Section 8.5.1 of AP 0190.9, to incorporate those same requirements identified in Item 3 above into a new Section 9.7.1.
Additional Sections 9.7.2 and 9.7.3 will be added to delineate. controls when instrumentation cannot be repaired /recalibrated i
and document retention requirements for instrumentation permanently removed from service.
5) a)
Full compliance was achieved on December 19, 1984 with those revisions to AP 0190.9 identified in Item 3 above.
i b)
Full compliance will be achieved by May 1,1985 with the issuance of a revision to 0731 to incorporate those requirements identified in Item 4 above.
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