ML17341A437

Responds to NRC 810218 Ltr Re Violations Noted in IE Insp Rept 50-250/81-01.Corrective Actions:Surveillance Area Redefined,Permanent Red Colored Floor Tiles Installed & Changes Made to Administrative Procedure 0103.2

ML17341A437
Person / Time
Site:	Turkey Point
Issue date:	04/20/1981
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML17341A438	List: ML17341A437
References
L-81-174, NUDOCS 8108180286
Download: ML17341A437 (9)

See also: IR 05000250/1981001

Text

!~~)~'c 0 USNRO REOlox:: ATLANTA, GEORGIA+y(IAq~o>>FLORIDA POWER&LIGHT COMPANY April 20, 1981 L-81-174 Hr.Victor Stello, Director Office of Inspection

and Enforcement

U.S.Nuclear Regulatory

Commission

Washington, D.C.20555 Dear Hr.Stello: Re: Turkey Point Unit 3 Docket No.50-250 10 CFR 2.201 Response to Notice of Violation dated Februar 18, 1981 PUG171983Ž-M I,HXQARiggATCel

~.IIOgg f/~)I I The attachment

to this letter contains Florida Power 6 Light Company's reply to your letter and Notice of Violation of February 18, 1981 as required by 10 CFR 2.201.Our reply pursuant to 10 CFR 2.205 has been prov d d separately

as requested.

Very trul yours, Robert E.Uhrig Vice President Advanced Systems and TectIno'logy

REU/RAK/rnbd

Attachment

cc: I~Ir.J.P.O'Reilly, Region II Harold F.Reis, Esquire 810818028b

81042%0, PDR ADOCK 0500025'0'PQR,'EOPLE...

SERVING PEOPLE

II I a+~!i II'0 it s/-\~p r I

e II (~'e: Turkey Point Uni Docket Ho.50-250~10 CFR 2.201 Response to Notice of Violation dated February 18, 1981 Page 1 ATTACHMENT

e~Findin: 10 CFR 50.54(k)states that an operator or senior operator licensed pursuant to Part 55 of this chapter shall be present at the controls at all times during operation of the facility.'echnical Specification

6.8.1 requires that written procedures

and administrative

policies be established, implemented

and maintained

that meet or exceed the requi rements and recommendations

of Section 5.1 and 5.3 of ANSI N18.7-1972, Appendix"A" of USHRC Regulatory

Guide 1.33;this includes plant operating procedures.

Plant Operating Procedure 0103.2, Responsibilities

of Operators-

On-Shift and Maintenance

of Operating Logs and Records, states in Section 5.3.3 that the Nuclear Control Center Operator (NCCO)shall have an unobstructed

view of and access to the control panels, including instrumentation

displays and alarms.He shall not leave the Surveillance

Area (Figure 1)for any non-emergency

reason without obtaining a qualified relief.Section 5.3.4 states that a single operator shall not assume the HCCO responsibility

for both units at the same time unless so directed and such action is in compliance

wi th Technical Specification 6.2.2 or is necessitated

by emergency conditions.

Contrary to the above, at about 11:45 a.m.on January 29, 1981, the HRC Resident Inspector observed Turkey Point Unit 3 operating at full power without an operator present at the controls.The assigned Unit 3 operator was in a room behind the Unit 4 instrument

panels which precluded visually monitoring

the Unit 3 reactor conditions.

The room, although open to the control room, is outside the surveillance

area specified in Plant Operating Procedure 0103.2.A qualified relief had not been obtained and an operator leaving the surveillance

area was not necessitated

by an emergency condition, nor was the Unit 4 operator directed to assume HCCO responsibilities

for both units.~Res ense: 1.(1-1)FPL concurs with the finding, however, as discussed in our reply pursuant to 10 CFR 2.205, we take exception to the severity level classification.

The reason for the violation was that the Nuclear Control Center Operator (NCCO)did not adhere to the procedural

requirement

to obtain a relief prior to leaving the surveillance

area.As corrective

action: (1)The surveillance

area has been re-defined

and permanent red colored floor tiles have been installed to outline the.surveillance

area boundary.

P,

Re: Turkey Point'Unit

Docket Ho.50-250 10 CFR 2.201 Response to Notice of Violation dated February 18, 1981 Page 2 (2)Changes have been made to Administrative

Procedure 0103.2,.Responsibilities

of Operators On-Shift and Maintenance

of Operating Logs and Records, which redefined the proper procedure which must be taken by the NCCO in order to leave the surveillance

area.The third NCCO on shift is now required to normally stay in the surveillance

area and to verbally notify and obtain acknowledgment

from each operator with unit responsibility

prior to leaving the surveillance

area.e (3)(4)(5)A name display system has been implemented

that positively

identifies

the operator who has unit responsibility.

In order to transfer unit responsibility

from one operator to another, the name display must be changed by the oncoming operator as part of his turnover acknowledgement.

All operators have been instructed

in wri'ting of their responsibilities.

Plant management

has begun a program of random visits to the Control Room at unannounced

intervals.

During these visits, the management

will verify that the licensed operators are conti nui ng to perform thei r duties in a professional

manner.(1-4)He will also take the following long and short term corrective

actions to avoid similar problems in the future.Short term: The surveillance

area boundaries

will be redefined by April 30,-1981 to fully meet the intent of Regulatory

guide 1.114 as discussed at the management

meeting with IKE personnel.

(2)*FP8L Management

will conduct meetings with Licensed'perators by May 31, 1981 to emphasize the importance

of this issue, to provide guidance on compliance

with the Regulatory

Guide, and to discuss management

enforcement

actions that will be taken should further deficiencies

occur.(3)(4)Movable rope or chain barriers will be placed at appropriate

openings to the surveillance'area

boundaries

by May 15, 1981 to give a more physical means of identifying

the surveillance

area and to limit access to this area by non licensed personnel.Plant management

will conduct meetings with Licensed Operators to discuss Operator concerns, management

policies, and Operator safety responsibilities.

.1~

Re: Turkey Point Unit Docket No.50-250 10 CFR 2.201 Response to Notice of Violation dated February 18, 1981 Page 3 Long term: (1)A human factors engineering

study of the Control Room layout will be conducted by January 1, 1982.(2)The Nuclear Match Engineer's

offi ce will be modified by January.l, 1982 to allow him to see the control panels while in his office.(3)Other physical changes will be made to permanently

re-locate such items as water fountains, chart lockers, bookcases and coffee pots in short term item 1, above.This will be accomplished

by January 1, 1982.Immediate corrective

action was taken on January 29, 1981, in response to the violation.

Additional

corrective

action, described in 1-3 above, was taken between January 30, 1981 and February 13, 1981.Additional

short and long term cor-rective action to enhance compliance

will be completed by the dates provided with each item in 1-4 above.

STATE OF FLORlDA))COUNTY OF DADE)ss.Robert E.Uhrig, being first duly sworn, deposes and says: I That he is a Vice President of Florida Power&Light Company,'the.Lic nsee herein;That he has executed the foregoing document;that the state-ments made in this said document are true and correct to the'best of his knowledge, information, and belief, and that he is authorized

to execute the document on behalf of said Licensee.t Robert E.Uhrig Subscribed

and sworn to before me this 9-C'ay of NOTARY PUBLIC, and for the county of Dade, State'of Florida Ho,erg Pub'.i", 8!s'o ol i.>.i;:a;.t

Lnpo Pgy COmmiSSiOn

eXPireS='ond d'.hru'A="...".ri'.

%~,~.z~