ML17347B316

Responds to Violations Noted in Insp Repts 50-250/89-27 & 50-251/89-27.Corrective Actions:Administrative Procedure 0-ADM-209 Revised to Require Independent Verification by Reactor Control Operator of Accuracy of Info on New Tags

ML17347B316
Person / Time
Site:	Turkey Point
Issue date:	09/01/1989
From:	WOODY C O FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-89-325, NUDOCS 8909120388
Download: ML17347B316 (13)

See also: IR 05000250/1989027

Text

AC CElZ RATED Dl STPJBUTJ ON DEMON STRATlON SYSTEM REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)CESSION NBR:8909120388

DOC.DATE: 89/09/01 NOTARIZED:

NO FACIL:50-250

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

WOODY,C.O.

Florida Power&Light Co.RECIP.NAME

RECIPIENT AFFILIATION

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

noted in Insp Repts 50-250/89-27

&50-251/89-27.

DISTRIBUTION

CODE: IEOID COPIES RECEIVED:LTR

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

of Vio ation Response NOTES: DOCKET 05000250 05000251 RECIPIENT ID CODE/NAME PD2-2 PD INTERNAL: AEOD AEOD/TPAD LOIS, ERASMIA NRR/DEST DIR NRR/DOEA DIR 1 1 NRR/DREP/RPB

10 NUDOCS-ABSTRACT

OGC/HDS2 RES MORI SSEAU I D EXTERNAL: LPDR NSIC COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 2 2 1'1 1 1 1 1 1'1 1 RECIPIENT ID CODE/NAME EDISON,G AEOD/DEIIB

DEDRO NRR SHANKMAN,S

NRR/DLPQ/PEB

NRR/DREP/EPB

10 NRR/PMAS/I

LRB12 OE IZ RMAN, J G FIL 02 H2~ILE 01 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 1 1 R h NOIR'IO ALL'RING" RECZEKZÃIS'LEASE

HELP US IO REDUCE RASTE.'MIRCT

'IHE DOCGMERZ CGNZROL DESK, RXN Pl-37 (EXT.20079)KO iKZMINATR KX3R NAME PKH DISTBIHUTICN

LISTS FOR DO(XIMEHIS

VXJ MN'T NEEDt TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24-D S

Cl

P.O.Bc,x 14000, Juno Beach, FL 33408.0420

SEPTEMBER 1 1989 L-89-325 10 CFR 2.201 U.S.Nuclear Regulatory

Commission

Attn: 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 89-27 Florida Power&Light Company (FPL)has reviewed the subject inspection

report and pursuant to 10 CFR 2.201 the response is attached.Very truly yours, pe~~~C.O.oody Acti Senior Vice President-Nuclear COW/JRH/cm

Attachment

cc: Stewart D.Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant 8 F05'1203C<3 (y0y01 PDR ADOCK 0 F0002'50 9 PDC w~gg(I<an FPL Group company

ATTACHMENT

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

Report 89-27 FINDING A TS 6.8.1 requires that written procedures

and administrative

policies shall be established, implemented

and maintained

that meet or exceed the requirements

and recommendations

of Appendix A of USNRC Regulatory

Guide 1.33 and Sections 5.1 and 5.3 of ANSI N18.7-1972.

Administrative

Procedure O-ADM-209, Equipment Tagging and Labeling, provides the responsibilities, precautions, limitations

and instructional

guidance for establishing

and maintaining

an accurate, com-plete and effective plant tagging program.Contrary to the above, engraved label plates were replaced on the Unit 3 Safe-ty In)ection Block Switch without following the requirements

of Administrative

Procedure O-ADM-209, resulting in two separate safeguard actuations

within a 24-hour period.RESPONSE A 1.FPL concurs with the finding.2.The cause for this finding was personnel error by non-licensed

utility personnel'he

label on the Safety In)ection Block Switch had been re-cently replaced with a label which contained more detailed information.

Both the person responsible

for validating

the label and the person who installed the label for the Safety Injection Block Switch failed to ade-quately validate all the information

contained on the new label.The new label installed had the"Blocked" and"Unblocked" switch positions re-versed.This resulted in the switch being placed unknowingly

in the"Unblocked" position instead of the"Blocked" position.With the switch in the"Unblocked" position, when the manual block buttons were released, an SI signal was produced.An unclear drawing was the reason the inaccurate

label was not identified

following the first SI actuation.

The I&C technician

was required by the Plant Work Order for this activity to verify that the switch had proper continuity

in the block, neutral, and unblock positions.

When he performed this step, confusing information

on drawing 5610-M-430-171, Sheet 5,"Units 3 an 4 Safeguards

System," lead the technician

to believe that the switch was responding

correctly.

This resulted in the inaccurate

label not being

identified.

Two switch contact blocks which showed signs of physical damage were considered

to be the cause of the first SI actuation.

Corrective

steps which have been taken and the results achieved include: a.b~The Unit 3 Safety In)ection Block Switch has been relabeled to correctly identify switch positions.

The Safety In)ection Block Switch labels in the Simulator and in the Unit 4 Control Room have been verified to be correct.4.Corrective

steps which will be taken to, avoid further violations

include: a~The individual

responsible

for validating

the tag, and the individ-ual responsible

for placing the tag were counseled.

This counseling

stressed the importance

of verifying the information

contained on tags before they are installed.b.Administrative

Procedure 0-ADM-209 has been revised to require in-dependent verification

by a Reactor Control Operator of the accuracy of information

on new tags being installed in the Control Room.c.Drawing 5610-M-430-171, Sheet 5 has been revised to remove confusion related to the switch nomenclature

orientation.

5.Date when full compliance

will be achieved: a.Action item 3.a,was completed on June 23, 1989.b.Action item 3.b was completed on June 23, 1989.c.Action item 4.a was completed on June 23, 1989.d.Action item 4.b was completed on July 7, 1989.e.Action item 4.c was completed on August 15, 1989.FINDIHG B 10 CFR 50, Appendix B, Criterion III, as implemented

by the approved Florida Power and Light Company Topical Quality Assurance Report (FPLTQAR)1-76A, Revision II, Topical Quality Requirement (TQR)3.0, Revision 7, requires that measures be established

to assure that applicable

regulatory

requirements

and the design basis are correctly translated

into specifications, drawings, pro-cedures, and instructions.

Contrary to the above, the required 2.0 second opening time specified for the Pressurizer

Power Operated Relief Valve (PORV)in the Overpressure

Mitigating

System (OMS)Safety Evaluation

Report dated March 14, 1980, was not incorpor-ated into the licensee s Inservice Testing Program.Instead, a non-conserva-

tive acceptance

criteria of 15.0 seconds was used.This resulted in the Unit 3 and 4 PORVs being unable to maintain Reactor Coolant System (RCS)pressure

b elow the 10 CFR 50, Appendix G limits, had the most limiting design basis transient occurred.This condition existed on several occasions from May 1984 to June 1988, as exhibited by a review of PORV stroke timing records.RESPONSE B 1.FPL concurs with the finding.2.The cause for this finding was an inadequate

design process The process did not verify that the design basis opening time of 2.0 seconds for the PORVs could be met by the PORVs installed at Turkey Point, nor did the process assure that the proper acceptance

criteria was incorporated

into the Plant s affected documents;

3.Corrective

steps which have been taken and the results achieved include: a~Westinghouse

has performed an evaluation

of the increased PORV stroke times against each of three overpressure

events (inadvertent

start of two charging pumps with a loss of letdown, spurious start of one safety in)ection pump, and inadvertent

starting of a RCP with a temperature

differential

between the secondary system and the RCS of 50 degrees F).The mass in)ection pressure transient of a spur-ious start of a single safety in)ection pump has been determined

to be the most limiting pressure transient event.The final results showed that the PORVs could be tested up to 3.45 seconds and still prevent the most limiting pressure transient from exceeding 10CFR50, Appendix G limits.For the case of two charging pumps starting with a loss of letdown and of inadvertent

starting of a RCP with a temperature

differential

between the secondary system and the RCS of 20 degrees F (Turkey Point operating procedures

specify 10 degrees F), the Westinghouse

evaluation

demonstrated

that PORV opening stroke times would have to exceed 10.0 seconds before the limits of 10CFR50, Appendix G would be approached

.b.Plant Change/Modification (PC/M)88-535 has been issued to increase the size of the Unit 4 PORV instrument

air and nitrogen backup supply line tubing.This PC/M has been implemented

and was demon-strated to be effective in decreasing

the PORV opening time through performance

of Preoperational

Procedure 0800.216,"Pressurizer

PORV Nitrogen Backup and Timing." This procedure requires an opening time of 1.65 to 3.45 seconds and a closing time of 1.0 to 2.0 seconds using both instrument

air and nitrogen backup supplies.C~PC/M 88-427 has been issued to increase the size of the Unit 3 PORV instrument

air supply line tubing as a temporary measure to decrease the PORV opening stroke time.This PC/M has been implemented

and was demonstrated

to be effective through.performance

of Startup Field Procedure SFP-13,"Startup Test Control-Interim Department-

al Testing." Permanent modifications

to the PORV instrument

air and nitrogen backup supply line tubing will be implemented

on the Unit 3

PORVs prior to restart from the next refueling outage.Compensatory

measures are in place as a condition of NRC Discretionary

Enforcement

to allow continued Unit 3 operation with PORV opening stroke times of less than or equal to 10.0 seconds until these permanent modifications

are completed.

Operating Procedure OP 0209 F 1,"Valve Exercising

Procedure," provides instructions

for the periodic exercising

of Safety Class 1, 2, and 3 valves for which exercising

is required by the Valve Test Program portion of the Turkey Point Inservice Testing Program.This pro-cedure has been revised to ensure the Unit 4 PORVs meet an opening stroke time of 3.45.e.OP 0209.1 has been revised to ensure the Unit 3 PORVs meet an open-ing stroke time of less than or equal to 10.0 seconds.OP 0209.1 will be revised to specify an opening stroke time of 3.45 seconds for the Unit 3 PORVs upon completion

of long term corrective

modi-fications during the next refueling outage.Operations

Surveillance

Procedure 4-0SP-041.4,"Overpressure

Miti-gating System Nitrogen Backup Leak and Functional

Test," has been revised to ensure the Unit 4 PORVs meet an opening stroke time of 3.45 seconds using the nitrogen backup supply.g~Procedure 3-0SP-041.4

has been revised to ensure the Unit 3 PORVs meet an opening stroke time of less than or equal to 10.0 seconds using the nitrogen backup supply.3-0SP-041.4

will be revised to specify an opening stroke time of 3.45 seconds for the Unit 3 PORVs using the nitrogen backup supply upon completion

of long term modi-fications during the next refueling outage.4.Corrective

steps which will be taken to avoid further violations

include: a~Administrative

Procedure (AP)0103 18'acility

Operating License Amendments

and/or Changes," has been revised to require the Nuclear Engineering

Department

personnel to document the review of proposed license amendments

and provide a response to the Regulation

and Compliance

Group.b~Nuclear Engineering

Quality Instruction (QI)3.11,"JPN Review of Technical Specification

Amendments," has been issued which requires the review of technical specification

amendments

for impact on eng-ineering design documents.

5.Date when full compliance

will be achieved: a~Action item 3.a was completed on March 2, 1989.b~Action item 3.b was completed on March 2, 1989.c~Action item 3.c will be complete prior to startup from the next Unit 3 refueling outage which is currently scheduled for May 31, 1990.d.Action item 3.d was completed on February 24, 1989~

e.Action item 3.e will be complete prior to startup from the next Unit 3 refueling outage which is currently scheduled for May 31, 1990.f.Action item 3.f was completed on May 2, 1989.g.Action item 3.g will be complete prior to startup from the next Unit 3 refueling outage which is currently scheduled for May 31, 1990.h.Action item 4.a was completed on November 28, 1988.i.Action item 4.b was completed in December 1988.