ML17223A452: Difference between revisions

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See also: [[followed by::IR 05000335/1989027]]


=Text=
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{{#Wiki_filter:]I ACCELERATED
{{#Wiki_filter:]I ACCELERATED DISTjUBUTION DEMONSTPATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)ACCESSION NBR:9001120278 DOC.DATE: 90/01/05 NOTARIZED:
DISTjUBUTION
NO FACIL:50-335 St.Lucie Plant, Unit 1, Florida Power&Light Co.50-389 St.Lucie Plant, Unit 2, Florida Power&Light Co.AUTH.NAME AUTHOR AFFILIATION GOLDBERG,J.H.
DEMONSTPATION
Florida Power&Light Co.RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SYSTEM REGULATORY
 
INFORMATION
==SUBJECT:==
DISTRIBUTION
Responds to violations noted in Insp Repts 50-335/89-27
SYSTEM (RIDS)ACCESSION NBR:9001120278
DOC.DATE: 90/01/05 NOTARIZED:
NO FACIL:50-335
St.Lucie Plant, Unit 1, Florida Power&Light Co.50-389 St.Lucie Plant, Unit 2, Florida Power&Light Co.AUTH.NAME AUTHOR AFFILIATION
GOLDBERG,J.H.
Florida Power&Light Co.RECIP.NAME
RECIPIENT AFFILIATION
Document Control Branch (Document Control Desk)SUBJECT: Responds to violations
noted in Insp Repts 50-335/89-27
&50-389/89-27.
&50-389/89-27.
DISTRIBUTION
DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice of Vi&o ation Response NOTES: DOCKET 05000335 05000389 RECIPIENT ID CODE/NAME PD2-2 PD INTERNAL: ACRS AEOD/DEIIB DEDRO NRR/DLPQ/LPEB10 NRR/DREP/PEPB9D NRR/DRIS/DIR NRR/PMAS/ILRB12 OS~-N,J 02 GN2 FILE OI EXTERNAL: LPDR NSIC COPIES LTTR ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME NORRIS,J AEOD AEOD/TPAD NRR SHANKMAN,S NRR/DOEA DIR 11 NRR/DREP/PRPB11 NRR/DST/DIR 8E2 NUDOCS-ABSTRACT OGC/HDS2 RES MORISSEAU,D NRC PDR COPIES LTTR ENCL 1.1 1 1 1 1 1 1 1 1 2 2 1 1 1 1 1 1 1.1 1 1 NOTE TO ALL"RIDS" RECIPIENTS:
CODE: IE01D COPIES RECEIVED:LTR
PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER'OF..COPIES REQUIRED: LTTR 26 ENCL 26  
ENCL SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice
.P.O.Box 14000, Juno Beach, FL 33408.0420 JANUAf5 P 5$990 L-90-7 10 CFR 2.201 U.S., Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.20555 Gentlemen:
of Vi&o ation Response NOTES: DOCKET 05000335 05000389 RECIPIENT ID CODE/NAME PD2-2 PD INTERNAL: ACRS AEOD/DEIIB
Re: St.Lucie Units 1 and 2~~~~~Docket Nos.50-335 and 50-389 Reply to a Notice of Violation Ins ection Re ort 89-27 Florida Power&Light Company'FPL) has reviewed the subject inspection report and pursuant to 10 CFR 2.201 the response is attached.cl g,gi~~e,.J.H.Goldberg Executive Vice President JHG/GRM/rh Attachment cc: Stewart D.Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St.Lucie Plant  
DEDRO NRR/DLPQ/LPEB10
.Re: St.Lucie Units 1 and 2 Dockets Nos.50-335 and 50-389 Reply to a Notice of Violation Ins ection Re ort 89-27 Violation 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires that measures shall be established to assure that significant conditions adverse to quality, such as deficiencies, deviations, and nonconformances are promptly identified and corrected, and that such measures include action to preclude repetition.
NRR/DREP/PEPB9D
NRC Generic Letter 82-33 requires that licensees develop and implement improved EOPs using an NRC approved procedures genera/ion package.By letter dated April 15, 1983, the licensee committed to implement this EOP improvement program.St.Lucie procedure QI 5-PR/PSL-6 Requirements for Development and Revision of Emergency Operating Procedures (Procedures Generation Package), Revision 0, dated April 10, 1987, requires that safety significant EOP deviations from the latest NRC approved revision to CEN-152, Combustion Engineering Emergency Procedure Guidelines, will be documented and reviewed by the technical staff prior to final approval of the EOPs.NRC Notice of Deviation (NOD)389/88-08-01, dated August 28, 1988, stated that the licensee failed to provide the technical basis or justification for significant EOP differences from CEN-152.In a September 22, 1988, response to the NOD, the licensee stated that discrepancies identified in the NOD would be corrected at the next revision to the EOPs, scheduled for June, 1989, and that these corrective actions would include backup information giving details for EOP deviations from CEN-152.Contrary to the above, the licensee failed to document justifications for safety significant EOP deviations from CEN-152, Revision 3, and to review them by the technical staff prior to final approval and use of the revised EOPs in September, 1989.R~ee once Florida Power&Light Company (FPL)concurs with the violation.
NRR/DRIS/DIR
2.The EOP justifications were not adequately documented because the personnel involved in the EOP revision process did not properly assess the importance of documenting the deviations from CEN-152 prior to issuing the EOPs.A technical review was conducted during the EOP revision process and this information was scheduled for incorporation into step documentation after the review and approval of the EOPs.3~4~5.The step documentation was in progress at the time of the November 1989 inspection.
NRR/PMAS/ILRB12
This process is ongoing.With the exception of revision 1 of EOP-15, future revisions of the EOPs will have step documentation complete prior,to revision review and approval.Revision 1 of EOP-15 incorporates human factor and implemention clarification corrections and is scheduled to be issued prior to January 15, 1990.The step documentation for this revision will be prepared subsequent to approval.This approach was discussed with the NRC staff at a meeting held on December 22, 1989.Step documentation for CEN 152 (Rev.3)EOP revisions will be completed by December 1990.
OS~-N,J 02 GN2 FILE OI EXTERNAL: LPDR NSIC COPIES LTTR ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME NORRIS,J AEOD AEOD/TPAD NRR SHANKMAN,S
IFI 50-335 389-89-27-02 Develop St.Lucie PSTG for EOPs, paragraph 2."The inspection team indicated to the Licensee that a PSTG was required which could be maintained and used effectively for the development and revision of the EOPs.Such a PSTG is described in.NUREG-0800, Standard Review Plan, Rev 0, in Appendix A, paragraph 3.0.The licensee committed to consider developing a new PSTG (including a setpoint document).
NRR/DOEA DIR 11 NRR/DREP/PRPB11
The detailed description of this PSTG and its projected completion date is to be addressed by the licensee in their response to this inspection report.Resolution of this item was identified as IFI 50-335, 389/89-27-02.
NRR/DST/DIR
~Res ense As described in FPL letter L-88-462 dated October 20, 1988, FPL believes the step documentation sheet with backup information is an acceptable Plant Specific Technical Guideline (PSTG).As discussed in FPL's response to the NOV 50-335/389-89-27-01, the PSTG for CEN 152 (Rev.3)will be complete by December, 1990.Plant guidelines will be prepared which will establish the criteria for changing the applicable steps of the EOPs by December 1990.This would allow for editorial corrections with minimum effort and require engineering review where substantial safety concerns exist.}}
8E2 NUDOCS-ABSTRACT
OGC/HDS2 RES MORISSEAU,D
NRC PDR COPIES LTTR ENCL 1.1 1 1 1 1 1 1 1 1 2 2 1 1 1 1 1 1 1.1 1 1 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISTRIBUTION
LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER'OF..COPIES
REQUIRED: LTTR 26 ENCL 26  
.P.O.Box 14000, Juno Beach, FL 33408.0420
JANUAf5 P 5$990 L-90-7 10 CFR 2.201 U.S., Nuclear Regulatory
Commission
Attn: Document Control Desk Washington, D.C.20555 Gentlemen:
Re: St.Lucie Units 1 and 2~~~~~Docket Nos.50-335 and 50-389 Reply to a Notice of Violation Ins ection Re ort 89-27 Florida Power&Light Company'FPL)
has reviewed the subject inspection
report and pursuant to 10 CFR 2.201 the response is attached.cl g,gi~~e,.J.H.Goldberg Executive Vice President JHG/GRM/rh
Attachment
cc: Stewart D.Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St.Lucie Plant  
.Re: St.Lucie Units 1 and 2 Dockets Nos.50-335 and 50-389 Reply to a Notice of Violation Ins ection Re ort 89-27 Violation 10 CFR 50, Appendix B, Criterion XVI, Corrective
Action, requires that measures shall be established
to assure that significant
conditions
adverse to quality, such as deficiencies, deviations, and nonconformances
are promptly identified
and corrected, and that such measures include action to preclude repetition.
NRC Generic Letter 82-33 requires that licensees develop and implement improved EOPs using an NRC approved procedures
genera/ion
package.By letter dated April 15, 1983, the licensee committed to implement this EOP improvement
program.St.Lucie procedure QI 5-PR/PSL-6
Requirements
for Development
and Revision of Emergency Operating Procedures (Procedures
Generation
Package), Revision 0, dated April 10, 1987, requires that safety significant
EOP deviations
from the latest NRC approved revision to CEN-152, Combustion
Engineering
Emergency Procedure Guidelines, will be documented
and reviewed by the technical staff prior to final approval of the EOPs.NRC Notice of Deviation (NOD)389/88-08-01, dated August 28, 1988, stated that the licensee failed to provide the technical basis or justification
for significant
EOP differences
from CEN-152.In a September 22, 1988, response to the NOD, the licensee stated that discrepancies
identified
in the NOD would be corrected at the next revision to the EOPs, scheduled for June, 1989, and that these corrective
actions would include backup information
giving details for EOP deviations
from CEN-152.Contrary to the above, the licensee failed to document justifications
for safety significant
EOP deviations
from CEN-152, Revision 3, and to review them by the technical staff prior to final approval and use of the revised EOPs in September, 1989.R~ee once Florida Power&Light Company (FPL)concurs with the violation.  
2.The EOP justifications
were not adequately
documented
because the personnel involved in the EOP revision process did not properly assess the importance
of documenting
the deviations
from CEN-152 prior to issuing the EOPs.A technical review was conducted during the EOP revision process and this information
was scheduled for incorporation
into step documentation
after the review and approval of the EOPs.3~4~5.The step documentation
was in progress at the time of the November 1989 inspection.
This process is ongoing.With the exception of revision 1 of EOP-15, future revisions of the EOPs will have step documentation
complete prior,to revision review and approval.Revision 1 of EOP-15 incorporates
human factor and implemention
clarification
corrections
and is scheduled to be issued prior to January 15, 1990.The step documentation
for this revision will be prepared subsequent
to approval.This approach was discussed with the NRC staff at a meeting held on December 22, 1989.Step documentation
for CEN 152 (Rev.3)EOP revisions will be completed by December 1990.  
IFI 50-335 389-89-27-02
Develop St.Lucie PSTG for EOPs, paragraph 2."The inspection
team indicated to the Licensee that a PSTG was required which could be maintained
and used effectively
for the development
and revision of the EOPs.Such a PSTG is described in.NUREG-0800, Standard Review Plan, Rev 0, in Appendix A, paragraph 3.0.The licensee committed to consider developing
a new PSTG (including
a setpoint document).
The detailed description
of this PSTG and its projected completion
date is to be addressed by the licensee in their response to this inspection
report.Resolution
of this item was identified
as IFI 50-335, 389/89-27-02.
~Res ense As described in FPL letter L-88-462 dated October 20, 1988, FPL believes the step documentation
sheet with backup information
is an acceptable
Plant Specific Technical Guideline (PSTG).As discussed in FPL's response to the NOV 50-335/389-89-27-01, the PSTG for CEN 152 (Rev.3)will be complete by December, 1990.Plant guidelines
will be prepared which will establish the criteria for changing the applicable
steps of the EOPs by December 1990.This would allow for editorial corrections
with minimum effort and require engineering
review where substantial
safety concerns exist.
}}

Revision as of 16:16, 17 August 2019

Responds to Violations Noted in Insp Repts 50-335/89-27 & 50-389/89-27.Corrective Actions:Step Documentation for Rev 3 to Cen 152 Emergency Operating Procedures Will Be Completed by Dec 1990
ML17223A452
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 01/05/1990
From: Goldberg J
FLORIDA POWER & LIGHT CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-82-33, L-90-7, NUDOCS 9001120278
Download: ML17223A452 (5)


Text

]I ACCELERATED DISTjUBUTION DEMONSTPATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)ACCESSION NBR:9001120278 DOC.DATE: 90/01/05 NOTARIZED:

NO FACIL:50-335 St.Lucie Plant, Unit 1, Florida Power&Light Co.50-389 St.Lucie Plant, Unit 2, Florida Power&Light Co.AUTH.NAME AUTHOR AFFILIATION GOLDBERG,J.H.

Florida Power&Light Co.RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to violations noted in Insp Repts 50-335/89-27

&50-389/89-27.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice of Vi&o ation Response NOTES: DOCKET 05000335 05000389 RECIPIENT ID CODE/NAME PD2-2 PD INTERNAL: ACRS AEOD/DEIIB DEDRO NRR/DLPQ/LPEB10 NRR/DREP/PEPB9D NRR/DRIS/DIR NRR/PMAS/ILRB12 OS~-N,J 02 GN2 FILE OI EXTERNAL: LPDR NSIC COPIES LTTR ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME NORRIS,J AEOD AEOD/TPAD NRR SHANKMAN,S NRR/DOEA DIR 11 NRR/DREP/PRPB11 NRR/DST/DIR 8E2 NUDOCS-ABSTRACT OGC/HDS2 RES MORISSEAU,D NRC PDR COPIES LTTR ENCL 1.1 1 1 1 1 1 1 1 1 2 2 1 1 1 1 1 1 1.1 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER'OF..COPIES REQUIRED: LTTR 26 ENCL 26

.P.O.Box 14000, Juno Beach, FL 33408.0420 JANUAf5 P 5$990 L-90-7 10 CFR 2.201 U.S., Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.20555 Gentlemen:

Re: St.Lucie Units 1 and 2~~~~~Docket Nos.50-335 and 50-389 Reply to a Notice of Violation Ins ection Re ort 89-27 Florida Power&Light Company'FPL) has reviewed the subject inspection report and pursuant to 10 CFR 2.201 the response is attached.cl g,gi~~e,.J.H.Goldberg Executive Vice President JHG/GRM/rh Attachment cc: Stewart D.Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St.Lucie Plant

.Re: St.Lucie Units 1 and 2 Dockets Nos.50-335 and 50-389 Reply to a Notice of Violation Ins ection Re ort 89-27 Violation 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires that measures shall be established to assure that significant conditions adverse to quality, such as deficiencies, deviations, and nonconformances are promptly identified and corrected, and that such measures include action to preclude repetition.

NRC Generic Letter 82-33 requires that licensees develop and implement improved EOPs using an NRC approved procedures genera/ion package.By letter dated April 15, 1983, the licensee committed to implement this EOP improvement program.St.Lucie procedure QI 5-PR/PSL-6 Requirements for Development and Revision of Emergency Operating Procedures (Procedures Generation Package), Revision 0, dated April 10, 1987, requires that safety significant EOP deviations from the latest NRC approved revision to CEN-152, Combustion Engineering Emergency Procedure Guidelines, will be documented and reviewed by the technical staff prior to final approval of the EOPs.NRC Notice of Deviation (NOD)389/88-08-01, dated August 28, 1988, stated that the licensee failed to provide the technical basis or justification for significant EOP differences from CEN-152.In a September 22, 1988, response to the NOD, the licensee stated that discrepancies identified in the NOD would be corrected at the next revision to the EOPs, scheduled for June, 1989, and that these corrective actions would include backup information giving details for EOP deviations from CEN-152.Contrary to the above, the licensee failed to document justifications for safety significant EOP deviations from CEN-152, Revision 3, and to review them by the technical staff prior to final approval and use of the revised EOPs in September, 1989.R~ee once Florida Power&Light Company (FPL)concurs with the violation.

2.The EOP justifications were not adequately documented because the personnel involved in the EOP revision process did not properly assess the importance of documenting the deviations from CEN-152 prior to issuing the EOPs.A technical review was conducted during the EOP revision process and this information was scheduled for incorporation into step documentation after the review and approval of the EOPs.3~4~5.The step documentation was in progress at the time of the November 1989 inspection.

This process is ongoing.With the exception of revision 1 of EOP-15, future revisions of the EOPs will have step documentation complete prior,to revision review and approval.Revision 1 of EOP-15 incorporates human factor and implemention clarification corrections and is scheduled to be issued prior to January 15, 1990.The step documentation for this revision will be prepared subsequent to approval.This approach was discussed with the NRC staff at a meeting held on December 22, 1989.Step documentation for CEN 152 (Rev.3)EOP revisions will be completed by December 1990.

IFI 50-335 389-89-27-02 Develop St.Lucie PSTG for EOPs, paragraph 2."The inspection team indicated to the Licensee that a PSTG was required which could be maintained and used effectively for the development and revision of the EOPs.Such a PSTG is described in.NUREG-0800, Standard Review Plan, Rev 0, in Appendix A, paragraph 3.0.The licensee committed to consider developing a new PSTG (including a setpoint document).

The detailed description of this PSTG and its projected completion date is to be addressed by the licensee in their response to this inspection report.Resolution of this item was identified as IFI 50-335, 389/89-27-02.

~Res ense As described in FPL letter L-88-462 dated October 20, 1988, FPL believes the step documentation sheet with backup information is an acceptable Plant Specific Technical Guideline (PSTG).As discussed in FPL's response to the NOV 50-335/389-89-27-01, the PSTG for CEN 152 (Rev.3)will be complete by December, 1990.Plant guidelines will be prepared which will establish the criteria for changing the applicable steps of the EOPs by December 1990.This would allow for editorial corrections with minimum effort and require engineering review where substantial safety concerns exist.