L-2024-076, Reply to Notice of Violation; NOV 05000250, 05000251/2024010-05
| ML24150A242 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 05/29/2024 |
| From: | Rasmus P Florida Power & Light Co |
| To: | NRC/RGN-II, Document Control Desk |
| References | |
| L-2024-076, IR 2024010 | |
| Download: ML24150A242 (1) | |
Text
L-2024-076 Attachment Page 1 of 2 RESPONSE TO NOTIFICATION OF VIOLATION FLORIDA POWER & LIGHT COMPANY TURKEY POINT NUCLEAR GENERATING STATION, UNITS 3 AND 4 Notice of Violation (NOV) 05000250,05000251/2024010-05 Title 10 CFR 50 Appendix B, to 10 CFR Part 50, Criterion XVI, Corrective Action, requires, in part, that measures be established to assure conditions adverse to quality are promptly identified and corrected.
Contrary to the above, since 2005, the licensee identified a condition adverse to quality associated with the lack of MCCB testing, but failed to implement measures to assure that the testing deficiencies were corrected in a prompt manner. Specifically, the site failed to restore compliance within a reasonable period of time after a 2013 corrective action violation to ensure that molded case circuit breakers were adequately tested.
Response
- 1. The reason for the violation The NRC identified a slow pace in the testing of molded case circuit breakers (MCCBs).
This was originally identified in 2005 and then a Green non-cited violation (NCV) was received in 2013 for the timeliness of testing.
The cause was determined to be inadequate scheduling of preventive maintenance (PM) activities for testing or replacing breakers. Based on review, a contributing cause was a 2015 revision to OM-AA-04, Plant Readiness for Operations, that removed a scheduling flag for regulatory related work activities, which in turn allowed for work scope removal without understanding the reasons for the work order.
- 2. The corrective steps that have been taken and the results achieved The Notice of Violation (NOV) was entered into the Turkey Point corrective action program.
An assignment was created to determine and apply work order attributes for ensuring 125 VDC and 120 VAC breaker PM work orders are included as OM-AA-04 restart readiness items for each outage. Another assignment was created to revise OM-AA-04, adding the attributes back into the procedure. This procedure revision adds a barrier to properly tag work orders for regulatory PM tasks to ensure that they are not inadvertently removed from the scope of the outage.
- 3. The corrective steps that will be taken A collaborative effort between Outage Work Management, the Work Scheduling Group, Maintenance, Operations and Engineering is underway to schedule MCCB testing or replacement during appropriate outage windows. This assignment is expected to be complete on 8/30/24. A revision to OM-AA-04 is expected to be completed by 10/30/24.
L-2024-076 Attachment Page 2 of 2
- 4. The date when full compliance will be achieved Preventive maintenance activities for MCCBs breakers are being scheduled into future refueling outages. The program will continue until the entire population of breakers is brought into full compliance. For Unit 4, the date is the end of 2031 and for Unit 3, the date is the end of 2032.