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See also: [[followed by::IR 05000250/1984035]]


=Text=
=Text=
{{#Wiki_filter:~~SS FEB 4 pip.~:$8~FLORIDA POWER 5 LIGHT COMPANY.January.28, 1985 L-85-48 Mr.James P.O'Reilly Regi onal Administrator, Regi on I I U.S.Nuclear Regulatory
{{#Wiki_filter:SS FEB                            FLORIDA POWER 5 LIGHT COMPANY.
COIIIIission
                    ~ ~
101 Marietta Street N.W., Suite 2900 Atlanta, Georgia 30303'Dear Mr.O'Reilly: Re:-Turkey Point Units 3 and 4 Docket Nos.50-250 and 50-251 Ins ection Re ort 250-84-35 5 251-84-36 I~~*'lorida Power and Light Company has reviewed the subject inspection
4   pip.:$~ 8       ~
report"and a response is attached.Th'ere is no proprietary
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
information
 
in the report.Very truly yours,)J.W.Williams, Jr.Group Vice President Nuclear'nergy
==Dear Mr. O'Reilly:==
Department
 
JWW/JA/ms/Kl
Re:   -
Attachment
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
cc: Harold F.Reis, Esquire-8503040123
                                                      ~ ~
850219 PDR ADOCK 05000250'Q.PDR PEOPLE...SERVING PEOPLE  
* '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.
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
Very   truly yours,
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
J. W. Williams, Jr.
and evaluated to assure that test requirements
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
have been satisfied.
 
~.Licensee guality Assurance Topical guality Requirement
Rg:   Turkey Point Units 3 and 4
11, Section 11.2.3, Revision 1, and equality Procedure 11.4, Revision 4, implement these.requirements.
              'ocket     No. 50-250, 50-251 IE Ins ection Re ort 84-250-35 and 84-251-36 FINDING 1:
Contrary to the above, test results obtained during the performance
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.
of Operating Procedure (OP)14004;2,"Reactor Coolant Flow Protection
~
Channels-'eriodic Test", performed on November 14, 1984, and OP 14004.4,"Pressurizer
    . Licensee guality Assurance Topical guality Requirement 11, Section 11.2.3, Revision 1, and equality Procedure 11.4, Revision 4, implement these                               .
Pressure and Mater Level Protection
requirements.
Channels-Periodic Tests:, performed on November 15, 1984, were not documented
Contrary to the above, test results obtained during the performance of Operating Procedure (OP) 14004;2, "Reactor Coolant Flow Protection Channels Test", performed on November 14, 1984, and OP 14004.4, "Pressurizer         -'eriodic 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
or evaluated, in that protection
~
bistable trip data was not recorded and consequently.did not receive supervisory
  ~    additional periodic tests without a specific evaluation of the test results.
review or analysis.The failure to record astable trip data is a prograomati
 
c oversight which has resulted in the completion
===RESPONSE===
of several additional
: 1)     FPL concurs with the   finding.
periodic tests without a specific evaluation
      . 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.
of the test results.RESPONSE: 1)FPL concurs with the finding..2), The normally expected values with acceptance
: 3)     The fo11owing procedures       are being upgraded by the additions of columns to record the as-found" data.
criteria are printed in the procedure.
OP 14004.1        "Steam Generator    Protection Channels" OP  14004.2      "Reactor    Coolant  Flow Protection  Channels  - Periodic
Evaluation
                              ~
is done after the procedure is completed to ensure that hl l the steps.wef e executed.'ut-of-tolerance
Test" OP 14004.3        "TPVG and DELTA-T     Protection Channels - Periodic Test" 2 t             1 OP  14004.4        "Pressurizer Pressure     and Mater Level Protection Channels
settings are documented
                                  - Periodic Test" OP   1804. 1       "Axial   FTuux. Pod:Deviation   and. Rod Position   Indication System Honthly Test"
in the gA Record Section.The procedures
 
did not require documenting
Re:       IE Ins ection Re       ort 250-84-35         and 251-84-36 Page 2
the"as-read" data.3)The fo11owing procedures
: 4)     The Procedures       Upgrade Program is chartered to.rewrite Turkey Point Plant .         ~
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
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.
Channels-Periodic Test" 2 t 1"Pressurizer
    ~
Pressure and Mater Level Protection
: 5)     Full compliance for item             3 above   will be achieved by Harch 15, '1985.
Channels-Periodic Test" OP 1804.1"Axial FTuux.Pod:Deviation
FINDING 2:
and.Rod Position Indication
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.               ~ -'"~ .
System Honthly Test"  
                                          ~       ~ ~0.'
Re: IE Ins ection Re ort 250-84-35 and 251-84-36 Page 2 4)The Procedures
T TS 4.10.2 requires that AFW discharge valves be tested during AFW pump tests.
Upgrade Program is chartered to.rewrite
                          ~   ~
Turkey Point Plant.~procedures.
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.
One of the improvements
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 .
to procedures
and shut       automatically when all the steam supply, valves are shut.
is the addition of columns for"as-found" data and"as-left" data.The FPL approved"Writers Guide for Maintenance
Additionally, the licensee failed to perform post test lineups on the AFW flow
Procedures", O-ADH-107,'assures that when maintenance
    'ontrol valves and failed to 'independently verify the position of these valves.
'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
===RESPONSE===
satisfactorily
~
if control panel indication
  . 1) .
and visual observation'of
FPL concurs with the         finding.
the equipment demonstrate
: 2)   'he   procedure was inadequate because                 it             r assumed that when the steam supply   valve     closed     that     the   interlock   would close the associated auxiliary   feedwater       control     valve as designed.
that all coayonents
: 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.
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
C}}
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
}}

Latest revision as of 23:14, 3 February 2020

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  NextEra Energy icon.png
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:
References
L-85-48, NUDOCS 8503040123
Download: ML17346A867 (4)
v • d • e


Text

SS FEB FLORIDA POWER 5 LIGHT COMPANY.

~ ~

4 pip.:$~ 8 ~

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 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 Test", performed on November 14, 1984, and OP 14004.4, "Pressurizer -'eriodic 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 14004.1 "Steam Generator Protection Channels" OP 14004.2 "Reactor Coolant Flow Protection Channels - Periodic

~

Test" OP 14004.3 "TPVG and DELTA-T Protection Channels - Periodic Test" 2 t 1 OP 14004.4 "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.

2) 'he procedure was inadequate because it r 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

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