ML17348B278

Responds to Violations Noted in Insp Repts 50-250/91-37 & 50-251/91-37.Corrective Actions:Plant Change/Mod Installed in Current Cavity Seal Ring Holddown Clamps & Procedure Re Removal of Reactor Cavity Seal Ring Revised

ML17348B278
Person / Time
Site:	Turkey Point
Issue date:	11/22/1991
From:	GOLDBERG J H FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-91-318, NUDOCS 9112100162
Download: ML17348B278 (9)

See also: IR 05000250/1991037

Text

a<<e)r,mar,u ulSlMBUTION

DEMONSTRATION

SYSTEM R EGULATORY INFORMATION

DXSTRIBUTXON

SYSTEM (RIDS)SSION NBR:9112100162

DOC.DATE: 91/11/22 NOTARIZED-'O

DOCKET FACIL:50-250

Turkey Point Plant, Unit 3, Florida Power and Light C.05000250 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C 05000251 AUTH.NAME AUTHOR AFFXLIATION

GOLDBERG,J.M.

Florida Power&Light Co.RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)SUBJECT: Responds to violations

noted in Insp Repts 50-250/91-37

&50-251/91-37.Corrective

actions:plant

change/mod

installed in current cavity seal ring holddown clamps&procedure re removal of reactor cavity seal ring revised.DISTRIBUTION

CODE: IEOID COPIES RECEIVED: LTR ENCL 3 SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice

of Vio ation Response NOTES: INTERNAL: RECIPIENT ID CODE/NAME PD2-2 PD AEOD AEOD/DSP/TPAB

NRR HARBUCK, C.NRR/DLPQ/LHFBPT

NRR/DOEA/OEAB

NRR/DST/DIR

SE2 NUDOCS-ABSTRACT

OGC/HDS3 RGN2 FILE'1 COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1, 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME AULUCK,R AEOD/DEIIB

DEDRO NRR MORISSEAU,D

NRR/DLPQ/LPEB10

NRR/DREP/PEPB9H

NRR/PMAS/I

LRB12 OE+DR--: REG-"-BILE

~0 COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 D EXTERNAL: EG&G/BRYCE, J.H.NSIC 1 1 1 1 NRC PDR D NOTE TO ALL"RIDS" RECIPIENTS:

D D 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'UMBER

OF COPIES REQUIRED: LTTR 22 ENCL 22

P.O.Box 14000, Juno Boach, FL 33408 0420<<NOV 2 2 1992 L-91-318.10 CFR 2.201 U.S.Nuclear Regulatory

Commission

Attn: Document Control Desk Washington, D.C.20555 Gentlemen:

Re: A Turkey Point Unit 3 and Unit 4 Docket Nos.50-250 and 50-251 Reply to Notice of Violation NRC Ins ection Re ort 91-37 e Florida Power and Light Company has reviewed the subject inspection

report and pursuant to 10 CFR 2.201, the required response is attached.Very truly yours, Qi J.H.Goldberg President Nuclear Division TFP/CLM/cm

Attachment

cc: Stewart D.Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant"" f.0(316ŽF'DR ADOC)>>0 911122 Q~a000250 PDR (!,i,'U an FPL Group company

0'

-e ATTACHMENT

REPLY TO A NOTICE OF VIOLATION RE: Turkey Point Units 3 and 4 Docket Number 50-250 and 50-251 NRC Inspection

Report 91-37 FINDING Technical Specification (TS)6.8.1 requires written procedures

be established, implemented, and maintained

covering the activities

recommended

in Appendix A of Regulatory

Guide 1.33, Revision 2, February 1978, and Sections 5.1 and 5.3 of ANSI N18.7-1972.Section 5.1.2 of ANSI N18.7-1972 requires that procedures

be followed.O-GME-043.6, Reactor Vessel Cavity Seal Ring Installation, step 6.4.7, requires the installation

of the 24 compression

arms in their proper location.Step 6.4.7.1 states to ensure that the beveled end of the compression

arm is resting on the seal ring.e Contrary to the above, on December 22, 1990, 2 of the 24 compression

arms were not installed in their proper position on the seal ring.In addition, this deficient condition existed for an eight-month

period.RESPONSE TO FINDING.1.FPL concurs with the finding, with the following clarification:

the correct procedure number is O-GMM-043.6.

2.Plant Change/Modification (PC/M)86-014 installed the current cavity seal ring hold down clamps.During the initial installation

by Construction

in 1987, Nonconformance

Report (NCR)C-0241-87 was issued to document misalignment

between five compression

blocks and compression

arms.The NCR disposition

required installation

of temporary blocks at four locations and"accept as is" at one location.Corrective

action also required that the appropriate

procedure contain a hold point to verify removal of the temporary blocks following refueling.

However, installation

and removal of the temporary blocks were documented

as part of the NCR.

Prior to the next refueling in 1990, Discrepant

Field Condition DFC 90-0025 was initiated by Construction

to address the same misalignments.

An evaluation

was performed by Engineering (JPN-PTN-SEMS-90-031, NCR N-90-0049)

which required each misaligned

block to be inspected, and an attempt made to" provide"full line of contact" between each compression

block and compression

arm.Where full contact could not be made, temporary blocks were to be installed.

The NCR required a procedure revision to verify removal of the temporary blocks.Process Sheet 90-081 was revised.Work was performed by Construction.

The first time Mechanical

Maintenance

installed the cavity seal rings was at the beginning of the Dual Unit Outage just completed.

Mechanical

Maintenance

installed the seal rings in accordance

with procedure O-GMM-043.6, Reactor Cavity Seal Ring Installation.

Step 6.4.7.1 stated,"Ensure beveled end of compression

arm is resting on the seal ring." No drawing was included in the procedure to indicate the proper configuration

of the seal ring hold down clamp design, showing the compression

arm resting on the compression

block.The procedure did not specify the requirement

to have the compression

arms in full contact with the compression

blocks, nor did it allow the use of temporary blocks.The seal rings were installed with ,each compression

arm resting on a compression

block or on the seal ring plate.Cause of Event: The immediate cause of the event was an inadequate

procedure, in that the procedure did not sufficiently

specify the arm/block alignment requirements.

The cause of the inadequate

procedure was inadequate

incorporation

of PC/M design information

as evaluated and modified in the two previous NCRs, and in safety evaluation

JPN-PTN-SEMS-90-031.

A major contributing

factor was that two separate Quality Control (QC)organizations

existed, with different applications

of the term"procedure." Plant QC typically considered

only Maintenance

Procedures

as work documents, while Construction

QC normally restricted

their view of procedures

to Process Sheets.An.additional

contributing

factor was that the NCRs and the safety evaluation

did not clearly identify corrective

actions.The NCRs and the safety evaluation

justified the use of the temporary compression

blocks to obtain a full line of contact with the compression

arms.The safety evaluation

authorized

the future use of the temporary compression

blocks, provided the requirements

of the disposition

of NCR N-90-0049 were followed.One of those requirements

was that,"the procedure shall be revised to contain a hold point which verifies the removal of any temporary compression

blocks..." Since the NCR had been generated by Construction, only the Construction

Process Sheet was revised.The plant Maintenance

Procedure was not specifically

addressed.

e When installed by Maintenance, any misalignment

of the clamps was considered

not to be a problem since each compression

arm was in contact with the seal ring plate or compression

block (both are parts of the seal ring), and post-maintenance

testing was satisfactory.

It was also apparent that the misalignment

was a result of the original installation, and assumed to be acceptable.

Maintenance

personnel were not aware of past NCRs addressing

misalignment.

3.Corrective

steps which have been taken and the results achieved: a~b.Procedure O-GMM-043.6

has been revis'ed to provide directions

for the installation

of temporary blocks where"full line of contact" is not achieved between the compression

arm and block, and to include a sketch showing proper compression

arm/block contact.Procedure O-GMM-043.3, Removal of Reactor Cavity Seal Ring, has been revised to include verification

by a Quality'Control

Inspector that any temporary blocks have been removed.c~d.e.g, The compression

arms and blocks on the Unit 4 reactor cavity seal ring were inspected for"full contact." All compression

arms were found to be in full contact with the compression

blocks.Engineering

performed a walkdown and an evaluation

of the existing=condition, and determined

the condition to be acceptable

for the reasons listed in the body of the inspection

report (Ref: NCR N-91-0803).

The guidelines

for dispositioning

NCRs, found in ZPN-QI 15.1-3, have been upgraded.Completion

of JPN Form f65 identifies

the Final Engineering

Output Documents required to close the NCR.In this particular

case, the earlier NCR dispositions

would have been classified

either as"Use Alternate Design," or as"Use As Is," and one of five possible output documents would have been required.Prior to the recently completed dual unit outage, three separate NCR systems existed;one for Construction, one for Procurement, and one for the plant.As a result,"Construction" NCRs typically received Construction-

oriented dispositions.

The three systems have now been combined, as have the QC organizations.

'll NCR dispositions

are now reviewed by the same QC organization.

All engineering

safety evaluations

are required to specify all required actions in a dedicated section of the evaluation.

The evaluation

format containing

the"Actions Required" section existed in 1989, but its use was made mandatory in March of 1991.

4.Corrective

actions which will be taken to avoid further violations

include: a.Engineering

will issue a PC/M to update design documents to allow continued use of the moveable compression

blocks.5.The date when full compliance

was achieved: Full compliance

was achieved on August 30, 1991, when the Unit 3 reactor cavity seal ring was removed in accordance

with procedure O-GMM-043.3, Removal of Reactor Cavity Seal Ring.In addition, corrective

actions were or will be completed as follows: a 0 Item 3.a above was completed when the procedure revision was approved by the Plant Nuclear Safety Committee, and signed by the Plant Manager-Nuclear on September 3, 1991'.Item 3.b above was completed when the procedure revision was approved by the Plant Nuclear Safety Committee, and signed by the Plant Manager-Nuclear on September 24, 1991.Ci Item 3.c above was completed on September 23, 1991.d.NCR N-91-0803 was closed (Item 3.d), on September 23, 1991.e.g, JPN-QI 15.1-3 was revised in August, 1990 (after NCR N-90-0049 had been closed).The three NCR systems were integrated

on October 19, 1990.(Ref: QCQI 15.1)JPN-QI 3:9, mandating the dedicated section for action required, on safety evaluations, was revised in March, 1991.The PC/M described in Item 4.a above will be issued by March 31, 1992.

yJ