ML20128M405
| ML20128M405 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 06/25/1985 |
| From: | Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Williams J FLORIDA POWER & LIGHT CO. |
| References | |
| NUDOCS 8507110704 | |
| Download: ML20128M405 (4) | |
See also: IR 05000250/1984023
Text
okl
-
,
.
JUN 251985
Florida Power and Light Company
ATTN: Mr. J. W. Williams, Jr.
Group Vice President
Nuclear Energy Department
P. O. Box 14000
Juno Beach, FL 33408
Gentlemen:
SUBJECT: REPORT NOS. 50-250/84-23 AND 50-251/84-24
Thank you for your response of November 21, 1984, to our Notice of Violation
issued on October 11, 1984, concerning activities conducted at your Turkey Point
facility.
We have evaluated your response to Violations 1, 2, 3 and 4.c and
found that it meets the requirements of 10 CFR 2.201.
We will examine the
implementation of your corrective actions during future inspections.
A careful review of the basis for your denial of portions of Violation 4,
subsections 4.a and 4.b., and your denial of the additional example of Violation
250/84-09-10 and 251/84-09-10 has been conducted.
With respect to subsection 4.b, we agree with your position concerning one of the
several examples (Ametek pump) as described in the enclosure to this letter.
Though the item is no longer considered to be an example of Violation 4.b, the
storage of uncalibrated equipment in the same location as calibrated equipment,
along with related aspects of the maintenance program, is designated as an
Unresolved Item (250/84-23-08 and ?.51/84-24-08) pending further NRC inspection.
With respect to the additional example of a previously cited Violation
(250/84-09-10 and 251/84-09-10), we agree with your position that this is an
original design deficiency.
Please provide a supplemental response addressing
what review is being done or has been done to assure that similar design
deficiencies have not occurred in the routing of power to miscellaneous relay
rack equipment which may require safety-related power sources.
This subject is
identified as an Inspector Followup Item (250/84-23-09 and 251/84-24-09).
With respect to subsection 4.a of Violation 4, we have concluded, for reasons
presented in the enclosure to this letter, that the violation occurred as stated
in the Notice of Violation.
Therefore, in accordance with 10 CFR 2.201(a),
please submit to this office within 30 days of the date of this letter a written
statement that, for subsection 4.a of Violation 4, describes the corrective steps
which have been taken and the results achieved, the corrective steps which will
be taken to avoid further violations, and the date when full compliance will be
-achieved.
8507110704 850625
ADOCK 05000250
G
,j
--
JUN 251985
-
.
Florida Power and Light Company
2
We appreciate your cooperation in this matter.
Sincerely,
Original Signed by
Roger D. Walker
Roger D. Walker, Director
Division of Reactor Projects
Enclosure:
Staff Evaluation of I.icensee Response
dated November 21, 1984
cc w/ enc 1:
C. M. Wethy, Vice President
Turkev "oint Nuclear Plant
C. J
r, Plant Manager
TL,
oint Nuclear Plant
R. J. . ssta, Plant QA Superintendent
bec w/ enc 1:
NRC Resident Inspector
Document Control Desk
State of Florida
RII -
RII
RII
RII
RII.
h
Qly
c
v
G LFck:dr
frS
d
VBrownlee
CUpr ght
GJenk ns
3
6/ )/85
6/g85
6/Jo/85
6
85
6/7l/85
3
l
!
, _ _ _
.-
- _ . _ _
. . - .
.
.
-
-
_
-
em
,
.
JUN 2519es
ENCLOSURE
STAFF EVALUATION OF LICENSEE
RESPONSE DATED NOVEMBER 21, 1984
Staff Evaluation of the Partial Denial of Violation 4.b.
The licensee made the following statement in the partial denial:
"FPL denies
part of the finding because Ametek pressure pumps do not require calibration and
as such are not part of the Instrument and Control Calibration Program."
,
~
After additional inspection in this area, we agree that the pump is not on a
l
calibration schedule but is on a preventive maintenance schedule and that it was
used beyond the maintenance expiration date.
This item has been deleted as an
example to subsection 4.b of Violation 4.
The storage of uncalibrated equipment
1
in the same location as calibrated equipment is designated as an Unresolved Item
(250/84-23-08 and 251/84-24-08) pending further NRC inspection.
Additionally,
j
further inspection will be conducted into the preventive maintenance program and
,
will be addressed in future inspection reports.
t
Staff Evaluation of the Denial of an Additional Example of Previous Violation
'
250, 251/84-09-10
'
The licensee made the following statement in the denial:
"FPL denies the finding
because the control circuitry for pressure controllers PC-600 and PC-601 was part
i
of the original design of the plant and that design provided power for both
relays from the same non-vital source.
This is a design deficiency and not
another example of an incorrectly classified PC/M [ Plant Change / Modification].
This deficiency was processed under the provisions of 10 CFR Part 21 and our QA
requirements, and was reported to the NRC under 10 CFR 50.72 and 50.73. A PC/M
.
(84-132, Unit 3 and 83-133, Unit 4), classified as nuclear safety-related, has
been developed to provide separate and redundant Class 1E feeds to each control
relay to correct this design deficiency as described in Licensee Event Report
(LER) 250-84-018."
This item was an example of a previous violation which addressed classifying
design changes as non-safety-related when they were safety-related.
It was
maintained that the 10 CFR 21 report on pressure controllers PC-600 and PC-601
addressed an original design deficiency.
We concur in that determination;
however, the licensee should provide a supplemental response addressing what
review is being done or has been done to assure that similar design deficiencies
have not occurred in the routing of power to miscellaneous relay rack equipment
which may require safety-related power sources.
Staff Evaluation of the Partial Denial of Violation 4.a
The licensee made the following statement in the partial denial: "FPL denies the
j
discrepancy of the pressurizer heater bypass switches not being labeled.
denies part of the finding because discussions with start-up personnel confirmed
that the walkdown of PC/M 81-30 had been performed on May 23, 1984, and the label
!
_-
.
-
_ _ _ , _ _ _ _ _
_ _.. ___ _ ___,__
_ _
. _ . _ _ , _ _ _ _ _
_ _ _ . _ _ _ _ . . _ .
_
_
_
__
JUN 251985
,
Enclosure
2
1
was found on the switch at that time.
The label described the PC/M required
(Normal - Emergency) settings and it was installed as such."
Response 2.b to subsection 4.a of Violation 4 implies that start-up personnel
accompiished what procedure AP 0103.17 intended when on May 23, 1984, they
confirmed that the pressurizer heater lockout bypass switch position label
(Normal - Emergency) was installed on Unit 4 as PC/M 81-30 required.
The
response does not address PC/M 81-29, which is for Unit 3, but does state that
.
when the lack of information on the labels was identified by the NRC inspector
'
that temporary lables were installed to indicate the function of the switches.
Prior to this, the Unit 3 switches had no labels or visible identification at
all.
Inherent in the labeling process are the requirements to adequately identify the
component to a drawing and/or a procedure. There are two effective requirements
to which the FPL quality assurance program (FPL-NQA-100A) has committed.
The
first is that a component's identity be maintained from receipt to installation
and be in accordance with drawings, equipment lists, specifications and
established procedures (Regulatory Guide (R.G.) 1.116 and ANSI N45.2.8,
Section 3.2, Identification, and Section 5, Installed Systems Inspection and
Test).
These requirements must be met by appropriate tags / labels adequate to
relate to purchase specifications and operating drawings and procedures.
The
second requirement is that a continuing program of inspection be conducted of
activities affecting safety to verify (conformance with applicable documented
instructions, procedures and drawings
R.G 1.28 and ANSI N45.2, Section 2).
This, in turn, requires that the operating staff be provided sufficient component
identification labeling to comply with the applicable documents.
We conclude that labels to identify the components were not specified by either
PC/M (81-29 or 81-30), and that start-up personnel who were charged with the
responsibility for the walkdown of the system to identify discrepancies did not
initiate corrective action for the inadequate switch labeling.
We have evaluated the licensee's response to Violation 4.a, and found that it
does not meet the requirements of 10 CFR 2.201.
Therefore, the licensee should
respond to the original violation and submit a supplemental response to this
violation addressing:
(1) why the design change review process did not correct
the inadequate labeling discrepancy; and (2) what controls are in place to assure
that components are properly labeled or otherwise identified such that each
component can be properly operated and readily traced to drawings and procedures.
References:
R.G. 1.116-1976 (modifies ANSI N45.2.8-1975)
QA Requirements for Installation and Testing of
Mechnical Equipment and Systems
R.G. 1.28-1972 (modifies ANSI N45.2-1971)
QA Program Requirements.