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: ML17346A867
References
L-85-48, NUDOCS 8503040123
Download: ML17346A867 (4)

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.

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