ML17346A867

Responds to NRC 841227 Ltr Re Violations Noted in Insp Repts 50-250/84-35 & 50-251/84-36.Corrective Actions:Listed Procedures Upgraded by Additions of Columns to Record as-found Data & Operating Procedure OP 7304.1 Updated

ML17346A867
Person / Time
Site:	Turkey Point
Issue date:	01/28/1985
From:	Williams J FLORIDA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML17346A866	List: ML17346A865 ML17346A867 ML17346A868 ML17346A869 ML17346A872
References
L-85-48, NUDOCS 8503040123
Download: ML17346A867 (4)

See also: IR 05000250/1984035

Text

~~SS FEB 4 pip.~:$8~FLORIDA POWER 5 LIGHT COMPANY.January.28, 1985 L-85-48 Mr.James P.O'Reilly Regi onal Administrator, Regi on I I U.S.Nuclear Regulatory

COIIIIission

101 Marietta Street N.W., Suite 2900 Atlanta, Georgia 30303'Dear Mr.O'Reilly: Re:-Turkey Point Units 3 and 4 Docket Nos.50-250 and 50-251 Ins ection Re ort 250-84-35 5 251-84-36 I~~*'lorida Power and Light Company has reviewed the subject inspection

report"and a response is attached.Th'ere is no proprietary

information

in the report.Very truly yours,)J.W.Williams, Jr.Group Vice President Nuclear'nergy

Department

JWW/JA/ms/Kl

Attachment

cc: Harold F.Reis, Esquire-8503040123

850219 PDR ADOCK 05000250'Q.PDR PEOPLE...SERVING PEOPLE

Rg: Turkey Point Units 3 and 4'ocket No.50-250, 50-251 IE Ins ection Re ort 84-250-35 and 84-251-36~~OP 14004.1"Steam Generator Protection

Channels" OP 14004.2"Reactor Coolant Flow Protection

Channels-Periodic~Test" FINDING 1: 10 CFR 50 Appendix B, Criterion XI,"Test Control", states, in part,'that test results shall be documented

and evaluated to assure that test requirements

have been satisfied.

~.Licensee guality Assurance Topical guality Requirement

11, Section 11.2.3, Revision 1, and equality Procedure 11.4, Revision 4, implement these.requirements.

Contrary to the above, test results obtained during the performance

of Operating Procedure (OP)14004;2,"Reactor Coolant Flow Protection

Channels-'eriodic Test", performed on November 14, 1984, and OP 14004.4,"Pressurizer

Pressure and Mater Level Protection

Channels-Periodic Tests:, performed on November 15, 1984, were not documented

or evaluated, in that protection

bistable trip data was not recorded and consequently.did not receive supervisory

review or analysis.The failure to record astable trip data is a prograomati

c oversight which has resulted in the completion

of several additional

periodic tests without a specific evaluation

of the test results.RESPONSE: 1)FPL concurs with the finding..2), The normally expected values with acceptance

criteria are printed in the procedure.

Evaluation

is done after the procedure is completed to ensure that hl l the steps.wef e executed.'ut-of-tolerance

settings are documented

in the gA Record Section.The procedures

did not require documenting

the"as-read" data.3)The fo11owing procedures

are being upgraded by the additions of columns to record the as-found" data.OP 14004.3 OP 14004.4"TPVG and DELTA-T Protection

Channels-Periodic Test" 2 t 1"Pressurizer

Pressure and Mater Level Protection

Channels-Periodic Test" OP 1804.1"Axial FTuux.Pod:Deviation

and.Rod Position Indication

System Honthly Test"

Re: IE Ins ection Re ort 250-84-35 and 251-84-36 Page 2 4)The Procedures

Upgrade Program is chartered to.rewrite

Turkey Point Plant.~procedures.

One of the improvements

to procedures

is the addition of columns for"as-found" data and"as-left" data.The FPL approved"Writers Guide for Maintenance

Procedures", O-ADH-107,'assures that when maintenance

'procedures

are updated or new procedures

are written, they are reviewed for including appropriate"as-found" and:"as-left" data.~5)Full compliance

for item 3 above will be achieved by Harch 15,'1985.FINDING 2: Technical Specification (TS)4.10.1 requires periodic testing of the auxiliary feedwater (AFW)pumps to verify the ability of the system to respond properly when needed.~-'"~~.~~0.'T TS 4.10.2 requires that AFW discharge valves be tested during AFW pump tests.~~TS 4.10.4 states that AFM tests shall be considered

satisfactorily

if control panel indication

and visual observation'of

the equipment demonstrate

that all coayonents

have operated properly.Contrary to the above, the licensee did not perform the required visual obser-vations necessary to verify that the AFM flow control discharge valves would operate as designed.These.valves should open'utomatically

in response to the o'pening of any steam supply valve, modulate as necessary to maintain.flow.and shut automatically

when all the steam supply, valves are shut.Additionally, the licensee failed to perform post test lineups on the AFW flow'ontrol valves and failed to'independently

verify the position of these valves.'\~~RESPONSE:~.1).FPL concurs with the finding.r 2)'he procedure was inadequate

because it assumed that when the steam supply valve closed that the interlock would close the associated

auxiliary feedwater control valve as designed.3).Operating Procedure, OP 7304.1,"Auxiliary

Feedwater System-Periodic Test" is upgraded to verify that the interlocks

on the steam supply HOY operates the flow control valve open and closed: per design..The procedure has been upgraded to include verification

and independent

verification

of final flow control'valve

alignment and pos'ition.

C