ML17347B587

Responds to Violations Noted in Insp Repts 50-250/89-48 & 50-251/89-48.Corrective Action:Cited Drawing Discrepancies Corrected & Memo Reemphasizing Procedure as Being Method for Documenting Drawing Discrepancies Issued to Personnel

ML17347B587
Person / Time
Site:	Turkey Point
Issue date:	02/27/1990
From:	GOLDBERG J H FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9003090083
Download: ML17347B587 (5)

See also: IR 05000250/1989048

Text

ACCELERATED

DISTIGBUTION

DEMONSTjRATION

SYSH2M REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)CCESSION NBR:9003090083

DOC.DATE: 90/02/27 NOTARIZED:

NO 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 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 50-250/89-48

&50-251/89-48.

DISTRIBUTION

CODE: IE01D COPIES RECEIVED:LTR

ENCL SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice

of Vio ation Response NOTES RECIPIENT ID CODE/NAME PD2-2 PD INTERNAL: AEOD AEOD/TPAD NRR SHANKMAN,S

NRR/DOEA DIR 11 NRR/DREP/PRPBll

NRR/DST/DIR

8E2 NUDOCS-A STRACT F L 02 FILE 01 EXTERNAL: LPDR NSIC COPIES LTTR ENCL 1 1 1 1 1.1 1'1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME EDISON,G AEOD/DEIIB

DEDRO NRR/DLPQ/LPEB10

NRR/DREP/PEPB9

D NRR/DRIS/DIR

NRR/PMAS/ILRB12

OGC/HDS2 RES MORISSEAU,D

NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASIZt CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXI'.20079)TO ELMINATE YOUR NAME FROM DISTRIBUTION

LIS1S FOR DOCUMENTS YOU DON'T NEEDI OTAL NUMBER OF COPIES REQUIRED: LTTR 23 ENCL 23

P.O Box14000,Juno

Beach,FL 33408 0420 L-90-81 10 CFR 2.201 fE8RUARY.2 7]ggg U.S.Nuclear Regulatory

Commission

Attention:

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

Re: Turkey Point Units 3 and 4 Docket Nos.50-250 and 50-251 Reply to Notice of Violation Ins ection Re ort 89-48 Florida Power&Light Company has reviewed the subject inspection

report and pursuant to 10 CFR 2.201 the response is attached.Very truly yours, J.H.Goldberg Executive Vice President Nuclear Energy JHG/GRM/slh

Attachment

cc: Stewart D.Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant F00305'00c'3

PDF~DOCK 050002.'=0 9 pnt,./(p(an FPh Group comrr,.r,

ATTACHMENT

RE: Turkey Point Units 3 and 4 Docket Numbers 50-250 and 50-251 NRC Inspection

Report 89-48 FINDING 10 CFR 50, Appendix B, Criterion V and the licensee's

accepted Quality Assurance Program, FPL TQAR 1-76A, Section 5 require that activities

affecting quality shall be prescribed

by appropriate

drawings.Contrary to the above, two drawings, Operating Diagrams 5610-T-E-4501, Sheet 1, and 4510, Sheet 2, contained errors identified

by NRC inspectors.

These specific errors were promptly corrected and the licensee agreed to perform a further review to identify and correct any similar drawing errors.RESPONSE 1~2~FPL concurs with the finding.The Plant Operating Drawings (T-E series)were maintained

by the Training Department

and used as operator training documents until approximately

1979.At that time, the responsibility

for maintaining

the Plant Operating Drawings was transferred

to the Engineering

Department.

A limited scope as built walkdown of the Plant Operating Drawings was initially performed during the turnover process;however, the drawing discrepancies

noted by the NRC inspectors

were not identified

at that time.Use of the two subject Plant Operating Drawings since 1979 has not resulted in identification

of the noted discrepancies

by utility personnel.

A discussion

of the cited discrepancies

is provided below.a~Drawing 5610-T-E-4501, Sheet 1, depicted the Residual Heat Removal (RHR)System hot leg suction line coming from the Reactor Coolant System (RCS)Loop C hot leg for both Units.This is correct for Unit 3, however, the RHR System hot leg suction line comes from the RCS Loop A hot leg for Unit 4.This discrepancy

existed at the time the drawing was turned over to the Engineering

Department

in 1979.The associated

Piping and Instrument

Drawing (P&ID)correctly identifies

the RHR hot leg suction line coming from RCS Loop C for Unit.3 and, by note, describes the RHR hot leg suction line coming from RCS Loop A for Unit 4.The cause for the continued existence of the drawing discrepancy

was that the discrepant

condition was not recognized

by utility personnel.

b.Drawing 5610-T-E-4510, Sheet 2, correctly identified

the RHR System hot leg suction line as coming from RCS Loop C for Unit 3 and from RCS Loop A for Unit 4 within the flow arrows but had the direction of one flow arrow incorrectly

drawn.Additionally, both of the flow arrows incorrectly

referenced

drawing 4510 instead of drawing 4501.The cause for the drawing discrepancies

was an oversight by individuals

responsible

for drawing upgrades.System walkdown guidelines

for System Engineers were issued in June 1989.The drawing discrepancies

noted by the NRC inspectors

were on that part of the RHR System located inside the containment

buildings.

System walkdowns inside containment

buildings would normally be performed during refueling outages.Neither Unit 3 nor Unit 4 entered a refueling outage between June 1989 and November 17, 1989.System walkdowns performed on systems outside the containment

buildings since June 1989 have proven effective in identifying

drawing discrepancies

and initiating

corrective

actions.3.Corrective

steps which have been taken and the results achieved include: a.The cited drawing discrepancies

were corrected.

b.A memorandum

was issued to Operations

personnel re-emphasizing

Administrative

Procedure O-ADM-510,"Request for Engineering

Assistance," as being the method for documenting

drawing discrepancies.

4~Corrective

steps which will be taken to avoid further violations

include: 5.System walkdown guidelines

for System Engineers have been further revised to clarify that system walkdowns include the entire system (i.e., accessible

portions of the system inside and/or outside the containment

building).

The date when full compliance

was achieved: a.Item 3.a was completed by November 17, 1989.b.Item 3.b was completed on February 14, 1990.c.Item 4 was completed on February 20, 1990.

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