ML17341A897

Responds to NRC Ltr Re Violation Noted in IE Insp Repts 50-250/80-38 & 50-251/80-37.Corrective Actions:Nonlicensed Operator Training Procedure Will Be Revised & Issued by 820226

ML17341A897
Person / Time
Site:	Turkey Point
Issue date:	01/28/1982
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML17341A896	List: ML17341A897
References
L-82-32, NUDOCS 8202220266
Download: ML17341A897 (30)

See also: IR 05000250/1980038

Text

USHRQ REQ/Qg e~'>t L ADYTA'LOR~], 82FE8 2~8~g'.O.BOX 529100 MIAMI, F L 33152 yQlllg 8-i cA FLORIDA POWER 8 LIGHT COMPANY January 28, 1982 L-82-32 Mr.James P.O'Reilly Regional Administrator, Region II U.S.Nuclear Regulatory

Commission

101 Marietta Street, Suite 3100'tlanta, Georgia 30303 Dear Mr.O'Reilly: Re: Turkey Point Units 3 8 4 Docket Nos.50-250, 50-251 IE Inspection

Report 80-38/37 Florida Power 5 Light responded to IE Inspection

Report 80-38/37 in our letter (L-81-127)

dated March 25, 1981.In that report, Finding A concerned the maintenance

of training records for nuclear turbine operators.

We responded that as future corrective

action we would review existing non-licensed

operator training procedures

and make revisions as necessary.

Our letter said that full compliance

would be achieved by January 1, 1982.The review of the non-licensed

operator training program and procedures

has been completed, but the procedure revision, although prepared in draIt form has not received final review prior to being issued.The procedure revision, which is essentially

an upgrade of the training program, has been substantially

incorporated

into the program.However, in order to be in full compliance, we have determined

that the revised procedure shouId be reviewed, issued and fully implemented.

Our current plans are to complete the non-licensed

operator training procedure revision and then to issue the procedure by February 26, 1982.Very truly yours, ob t E.Uhrig Vice President Advanced Systems 8 Technology

REU/PLP/cab

Attachment

cc: Harold F.Reis, Esquire , 8202220266

8202i0 i" PDR.-ADQCK

05000250..."~" PDR""~1~4~>>.~PFOPLF...SERVING PEOPLE

l v 4 t u s~4ii i~II~t M

P aaq Reou c<C~~4~o'~c Cl o>>>>*a~UNITED STATES NUCLEAR REGULATORY

COMMISSION

REGION II 101 MARIETTA ST., N.W., SUITE 3100 ATLANTA, G EORGIA 30303 P,PR 0 9!981 Florida Power and Light Company ATTI'I: R.E.Uhrig, Vice President Advanced Systems and Technology

P.0.Box 529100 Miami, FL 33152 Gentlemen:

Subject: Inspection

Report 50-250/80-38

and 50-251/80-37

Thank you for your letter of March 25, 1981, informing us of steps you have taken to correct the violations

concerning

activities

under NRC License IIos.DPR-31 and DPR-41 brought to y'our attention in our letter of February 27, 1981.We will examine your corrective

actions and plans during subsequent

inspections.

We appreciate

your cooperation

with us.Sincerely, gC;R.C.ewis, Acting Director Division of Resident and Reactor project Inspection

cc: H.E.Yaeger, Plant Manager

~~March 25, 1981 L-81-127 Mr'.James P.O'Reil ly, Director, Region II Office of Inspection

and Enforcement

U.S.Nuclear Regulatory

Commission

101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 Dear Mr.O'Reilly: Re: RII: 50-250/80-38

50-251/80-37

Florida Power 8 Light Company has reviewed the subject inspection

report and a response is attached.There is no proprietary

information

in the report.Very yours,~~~Robert E.Uhrig Vice President Advanced Systems 8 Technology

REU/JEM/r'as

Attachment

cc: Harold F.Reis, Esquire

DRAFT RESPONSE TO USNRC IE INSPECTION

REPORT 80-38/80-37

Findin A: Technical Specification 6.4.1 requires that a retraining

and replacement

training program for the facility staff be maintained

under the direction of the training supervisor

to meet or exceed the requirements

and recommendations

of Section 5.5, ANSI N18.1-1971.

Section 5.5 of ANSI N18.1 1971 requires that a means be provided in the training programs for appropriate

evaluation

of its effectiveness.

Contrary to the above, the Training Supervisor

failed to implement an existing administrative

procedure on the training and retraining

program of nuclear operators and nuclear turbine operators in that the nuclear turbine operator on-the-job (on-shift)

training records for trainee evaluation

purposes were not maintained

as required by AP 0303.Res onse A: (A-1)FPL concurs with the finding.The reasons for the findings are: (1)Turnover of nuclear turbine operators has been significant

during this past year.(2)The training staff had been undermanned

to handle the amount of training necessitated

by the turnover.As corrective

action, the size of the training stafr has been increased to properly support the effort required in the non-licensed operator area.The training program for nuclear turbine operators was reinitiated

in January of this year and will continue in order to insure this training will be conducted as required by Administrative

Procedure 0303, Nuclear Operator and Nuclear Turbine Operator Training and Retraining

Program.As corrective

action in order to avoid further problems, (1)Review of the existing non-licensed

operator training procedures

will be conducted and the procedures

revised if necessary to more clearly define our policies on replacement

training and retraining

of non-licensed

operators, and (2)the Quality Control Department

will periodically

check the progress of the non-licensed

operator training program.Full compliance

will be achieved by January 1, 1982.

Techn ical Sepcification

6.8.1 requires that written procedures

and adm.nistrative

policies be established, implemented, and maintained

that meet or exceed the requirements

of Section 5.1 and 5.3 of ANSI N18.7-1972

and Appendix"A" of USNRC Regulatory

Guide 1.33.Contrary to the above, the Nuclear Plant Supervisor

failed to implement an existing administrative

procedure on the control of valves, locks and switches in that on December 4, 1980,'the onshift nuclear plant supervisor

failed to enter into the locked valve deviation log of Administrative

Procedure 0103.5 the change in status of valves MOV-3-863A

and B,"RHR.Heat Exchanger to RWST or Alternate LHSI" which had undergone'a periodi.c valve exercise test in accordance

with Operating Procedure 0209.1.Valves MOV-3-863A

and B with their associated

circuit breakers are included in the valve, lock and switch list of AP 0103.5 and the status of these valves is required to be under administrative

control.Res onse B: FPL concurs with the finding.The reason for the violation was that the Nuclear Plant Supervisor

assumed that the requirement

to log deviations

of valve positions did not apply if the repositioning

was covered by another procedure.

As corrective

action a procedure change that was reviewed and approved by the Plant Nuclear Safety Committee on March 19, 1981, to Administrative

Procedure 0103.5 clarifies that when a deviation from normal line up occurs, it will be logged in the deviation log, unless it is covered by an approved plant procedure and/or equipment clearance order.As corrective

action in order to review our pump and valve test these procedures

cause a valve operated they also require it position and relocked.avoid further problems, we will procedures

to ensure that when on the locked valve list to be to be returned to its normal Full compliance

will be achieved by March 31, 1981.

V

STATE OF FLORXDA))COUNTY OF DADE)ss Robert E.Uhrig, being first duly sworn, deposes and says: That he is a Vice President of Florida Power&Light Company, the Licensee herein;That he has executed the foregoing document;that the state-ments made in this said document are true and correct to the best of his knowledge, information, and belief, and that he is authorized

to execute the document on behalf of said Licensee.Robert E.Uhrig Subscribed

and sworn to before me this day of 19 F~NOTARY PUBLT.C in and for the county of Dade, State of Florida~)Ny commission

expires:

J yS~EOII+O~Cy A n t'I UNITED STATES NUCLEAR REGULATORY

COMMISSION

REGION I I 101 MARIETTA ST., N.W., SUITE 3100 ATLANTA, GEORGIA 30303 FE8 27 ass~Florida Power and Light Company ATTN: R.E.Uhrig, Vice President P.0.Box 529100 Miami, FL 33152 Gentlemen:

Subject Report Nos.50-250/80-38

and 50-251/80-37

This refers to the routine inspection

conducted by A.J.Igantonis.

and W.C.Marsh of this office on December 1-31, 1980, of activities

authorized

by NRC Operating I,icense Nos.DPR-31 and DPR-41 for the Turkey Point facility.Our preliminary

findings were discussed with J.K.Hays at the conclusion

of the inspection.

Areas examined during the inspection

and our findings are discussed in the enclosed inspection

report.Within these areas, the inspection

consisted of selective examinations

of procedures

and representative

records, interviews

with personnel, and observations

by the inspectors.

During the inspection, it was found that certain activities

under your license appear to violate NRC requirements.

These items and references

to pertinent requirements

are listed in the Notice of Violation enclosed herewith as Appendix A.Elements to be included in your response are delineated

in Appendix A.We have examined actions you have taken with regard to previously

identified

enforcement

matters.These are discussed in the enclosed inspection

report.In accordance

with Section 2.790 of the NRC"Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection

report will be placed in the NRC Public Document Room.If this report contains any information

that you believe to be proprietary, it is necessary that you make a written application

within 20 days to this office to withhold such infor" mation from public disclosure.

Any such application

must include the basis for claiming that the information

is proprietary

and the proprietary

information

should be contained in a separate part of the document.If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.

FEH 27~sst Florida Power and Light Company-2-Should you have any questions concerning

this letter, we will be glad to discuss them with you.Sincerely, E.c.R.C.ewis, Acting Chief Reactor Operations

and Nuclear Support Branch Enclosures:

1.Appendix A, Notice of Violation 2.Inspection

Report Nos.50-250/80-38

and 50-251/80>>37

cc w/encl: H.E.Yaeger, Plant Manager

0 APPENDIX A NOTICE OF VIOLATION Florida Power and Light Company Turkey Point Units 3 6 4 Docket Nos.50-250 8 50-251 License Nos.DPR-31 S DPR-41 As a result of the inspection

conducted on December 1-31, 1980, and in accordance

with the Interim Enforcement

Policy, 45 FR 66754 (October 7, 1980), the following violations

were identified.

A.Technical Specification 6.4.1 requires that a retraining

and replacement

training program for the facile;ty staff be maintained

under the direction of the training supervisor

to meet or exceed the requirements

and recom-mendations

of Section 5.5, ANSI N18.1-1971.

Section 5.5 of ANSI N18.1 1971 requires that a means be provided in the training programs for appropriate

evaluation

of its effectiveness.

Contrary to the above, the Training Supervisor

failed to implement an existing administrative

procedure on the training and retraining

program of nuclear operators and nuclear turbine operators in that the nuclear turbine operator on-the-job (on-shift)

training records for trainee evaluation

.purposes were not maintained

as required by A.P.0303.This is a Severity Level V Violation (Supplement

I.E.).B.-Technical Specification

6.8.1 requires that written procedures

and administrative

policies be established, implemented, and maintained

that meet or exceed the requirements

of Section 5.1 and 5.3 of ANSI N18.7-1972

and Appendix"A" of USNRC Regulatory

Guide 1.33.Contrary to the above, the Nuclear Plant Supervisors

failed to implement an existing administrative

procedure on the control of valves, locks and switches in that on December 4, 1980, the onshift nuclear plant supervisor

failed to enter into the locked valve deviation log of administrative

procedure 0103.5 the change in status of valves MOV-3-863ASB,"RHR Heat Exchanger to RUST or Alternate LHSI"which had undergone a periodic valve exercise test in accordance

with operating procedure 02.09.1.Valves MOV-3-863AM

with their associated

circuit breakers are included in the valve, lock and switch list of A.P.0103.5

and the status of these valves is required to be under administrative

control.This is a Severity Ievel VI Violation (Supplement

I.F.)applicable

to Unit 3 only.Pursuant to the provisions

of 10 CFR 2.201, Florida Power and Light Company is hereby required to submit to this office within twenty>>five

days of the date of this Notice, a written statement or explanation

in reply, including:

(1)admission or denial of the alleged violations;

(2)the reasons for the violations

if

admitted;(3)the corrective

steps which have been taken and the results achieved;(4)corrective

steps which will be taken to avoid further violations;

and (5)the date when full compliance

will be achieved.Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation.

Date: FEB 27)98)

~g RK0Iy~o ee~i I e 0 0 I rye y ee+~~0~"~UNITED STATES NUCLEAR'REGULATORY

COMMISSION

REGION II 101 MARIETTA ST., N.W., SUITE 3100 ATLANTA, GEORGIA 30303 Report Nos.50-250/80-38

and 50-251/80-37

Licensee: Florida Power&Light Company 9250 West Flagler Street Miami, FL 33101 Facility Name: Turkey Point Oocket Nos.50-250 and 50-251 License Nos.OPR-31 and OPR-41 I'nspection

at Turkey Point site near Homestead, Florida Inspector:

A.J.nat s Oate igned Accompanying

Personnel.:

M.C.Marsh Approved by: C'.Julia, Acting Section Chief, RONS Branch SUMMARY z/z.7 8/Oate Signed Inspection

on Oecember 1-31, 1980 Areas Inspected This routine inspection

involved 111 resident inspection

hours on site.Ouring this reporting period Unit 4 continued to be in a shutdown condition for the scheduled refueling outage which included time spent for the preparation

of the periodic Integrated

Leak Rate Testing, replacement

of feedwater heaters and main steam reheater tube bundles, and other scheduled inspection

and maintenance

'ctivities

of primary system components.

The areas of inspection

were: (1)licensee event report followup;(2)followup of previous inspection

findings;(3)surveillance

test observations;

(4)plant operations

including the review of the Nuclear Turbine operator training program;(5)witness of Unit 4 pressurizer

safety valve bench testing;and (6)plant tours.Results Of the six areas inspected, no items of identified

in five, areas;two aparent items area (Violation

-failure to fully comply Technical Specifications

-paragon aph 8;administrative

procedure-paragraph 8).noncompliance

or deviations

were of noncompliance

were found in one with paragraph 6.4.1 of the plant violation-failure to follow

DETAILS Persons Contacted Licensee Employees H.E.Yaeger, Site Manager"J.K.Hays, Plant Manager-Nuclear*J.E.Moore, Operations

Superintendent

-Nuclear D.W.Haase, Technical Department

Supervisor

V.B.Wager, Operations

Supervisor

J.Wade, Chemistry Supervisor

G.G.Jones, Nuclear Plant Supervisor

J.E.Crockford, Nuclear Plant Supervisor

C.A.Coker, Nuclear Plant Supervisor

T.A.Finn, Nuclear Plant Supervisor

L.C.Huenniger, Nuclear Plant Supervisor

J.L.Whitehead, Nuclear Plant Supervisor

D.C.Bradford, Refueling Coordinator

W.A.Klein, Licensing Engineer B.Abrishami, Systems Test Engineer"J.P.Mendietta, Maintenance

Superintendent"D.W.Jones, gC Supervisor"R.L.Caleman, Training Instructions

Supervisor

Other licensee employees contacted included operators, craftsmen, technicians, security personnel, gC personnel, and engineering

personnel."Attended monthly exit interview Monthly Exit Interview An interview was conducted on January 8, 1981 with plant management

personnel.

The inspector summarized

the scope and findings for the month of December inspection

activities

to the persons indicated in paragraph 1.The plant manager acknowledged

the stated violation on the lack of documentation

for the Nuclear Turbine Operator training program and agreed to take corrective

action.The item on failure to follow administrative

procedure 103.5,"Administrative

control of Valves, Locks and Switches" was reported by the inspector during the interview as a deviation.

However, following review of this item, the inspector determined

this to be a violation.

This change was reported to the plant manager prior to the publication

of this'eport.Licensee Action on Previous Inspection

Findings (Closed)Infraction

(50"250/80-16-01, 50-251/80-14-01)

Failure to track implementation

of corrective

action to noncompliance

79-31-01.The inspector reviewed the licensee's

corrective

action and had no further questions.

(Closed)Oeviation (50-250/80-16-02, 50-251/80-14-02)

Failure to establish a maintenance

instruction

on Select-A-Torq

by date committed in response to 79-31-01.The inspector reviewed the procedure issued Apri 1 25, 1980 and had nb further questions.(Cl osed)Inspector Fol 1 owup Item (50-250/80-16-04, 50-251/80-14-04), Licensee to modify procedures.to reduce chance of safeguards

actuations.

The inspector reviewed operating Procedure 0205.2"Hot shutdown to cold shutdown condition" and noted that information

regarding blockage of the high steam line differential

pressure signal prior to reducing steam generator pressure below 500 psig had been included in a caution statement after step 8.8, and had no further questions.

Followup on Previous Unresolved

Items Not reviewed during this inspection

report period.New Unresolved

Items No new unresolved

items were identified

during this inspection

report period.Licensee Event Report Followup Our ing this inspection

report period, the following Licensee Event Reports were followed up: 1.250-80-21,T.S.

4.1 Seismograph

Inoperative

2.250-80-23 T.S.4.1 Hissed EST Level Surveillance

The events were reviewed to assure the accuracy and completeness

of the report and the appropriateness

and efficiency

of corrective

actions taken.The inspector verified that the seismograph

was repaired and returned to service.No violations

or deviations

were identified

within the areas inspected.

Surveillance

Test Observations

Portions of the monthly surveillance

testing on three safety-related

system components

were witnessed by the inspector.

These were the component cooling water system 4A pump, the Unit 3 containment

spray pumps, and the Auxiliary Feedwater System pump.The tests were performed in accordance

to the following procedures:

(1)Operating procedure 3104.1,"Component

Cooling water system-periodic test of pumps";(2)operating procedure 4004.1,"Containment

Spray Pumps-Periodic Test;and (3)operating procedure

7304.1,"Auxiliary

Feedwater System-Periodic Test".Performance

dates for the above test activities

were December 2, 1980, and December 8, 1980.The following inspection

items were verified: a.Testing is scheduled in accordance

with technical specification

requirements.

b.~Procedures

are being followed.c.Testing is by qualified personnel.

d.LCOs are being met.e.System restoration

is correctly accomplished

following testing.'o

violations

or deviations

were identified

for the areas inspected above.Plant Operations

The inspector kept informed on a daily basis of the overall plant status and any significant

safety matters related to plant operations.

Discussions

were held with plant management

and various members of the operations

staff on a regular basis.Selected portions of daily operating logs and operating data sheets were reviewed on at least a weekly basis during the report'period.The inspector conducted various plant tour'nd made frequent visits to the control room.Observations

included witnessing

work activities

in progress, status of operating and standby safety systems, confirming

valve positions, ,instrument

readings and recordings, annunciator

alarms, housekeeping, radiation area controls, and vital area controls.During the conduct of routine plant tours inspections

the inspector observed on December 16, 1980 that the motor control circuit breake~, 3-0726 for motor operated valve MOV-3-863A, (RHR heat exchanger to refueling water storage tank (RWST)or altenate LHSI)was not in the required condition.

The breaker was found to be in an open position as it should be, but it was not locked.The licensee administrative

procedure 0103.5,"Administrative

Control of Valves, Locks and Switches" requires the circuit breaker 3-0726 be locked open with the valve closed (item 18.b of the valve lock and switch list).This finding was brought to the Nuclear Plant Supervisor's

attention, and was subsequently

corrected by having the circuit breaker locked open.It appears that the lock may have been inadvertently

left open following completion

of the valve exercise test performed on valve MOV-3-863A

on December 4, 1980.But this supposition

could not be substantiated

because per operating procedure 0202.1,"Reactor Startup-Cold Condition to Hot Shutdown Condition", step 8.20 which requires verification

of valves MOV-863 A&B closed and their associated

breakers locked open had been initiated.

This step of the procedure had been accomplished

some time between

Oecember 4 and 6, 1980.However, it is evident that the administrative

procedure A.P.0103.5 was not followed in that testing performed on valve MOV-3-863A

as well as MOV-3-863B

per O.P.0209.1,"Valve Exercising

Procedure" should have required the supervisor

to enter the valve position change in the locked valve deviation log of the subject administrative

procedure.

The record shows that no such entry had been made during the month of Oecember, 1980.This is, contrary to the requirements

of the procedure and constitutes

a violation.

(50-250/80-38-01)

Informal discussions

were held with operators and other personnel on work activities

in progress and status of safety-related

equipment or systems.The inspectors

questions were satisfactorily

answered.A review of the licensee's

training program for unlicensed

personnel, specifically

oriented towards the Nuclear Turbine Operators (NTO)'and nuclear operators (NO)was conducted by the inspectors'nformal

discussions

were held with the licensee training department

instructions

supervisor, the operations

superintendent, and the NTOs.This included the review of NTO personnel training records.Based on the review, it was the inspectors

understanding

that the NTOs are considered

to be fully qualified operators once they have completed the training program per the licensee administrative

procedure A.P.0303,"Nuclear Operator and Nuclea~Turbine Operator Training and Retraining

Program".The training program consists of classroom work (off-shift), in-the-field

walk thr'ough of all equipment that the NOs and NTOs are responsible

for, and on-the"job

training (on-shift).

Based on the information

provided to the inspector the training records show'that five out of ten NTOs did not complete the training program in accordance

to the requirements

of A.P.303.The inspector has concluded that the licensee lacked adequate documentation

for the NTO trainees in order to show that they have satisfactorily

completed their training.This finding results in a violation, for the licensee failed to follow plant Administrative

procedures

A.P.303.In paragraph 5.1 of A.P.303 the following statement is made: "The Training Supervisor

shall arrange for the Nuclear Operator or Nuclear Turbine Operator Trainee to be placed on shift to work with a regular shift operator on all phases of operations.

On-shift check off guide sheets will be furnished to cover on-shift training and will be used to help evaluate each trainee, and the progress achieved shall be evaluated by the'raining

Supervisor".

This step of the procedure was not'ollowed

in that the licensee was not able to provide NTO records covering on-shift training with check off guide sheets used for trainee evaluation

and progress achieved.Furthermore, paragraph 6.4.1 of the Technical Specifications

states that a retraining

and replacement

training program for the facility staff shall be maintained

under the direction of the Training Supervisor

and shall meet or exceed the requirements

and recommendations

of Section 5.5, ANS1 N18.1-1971 and Appendix A to 10 CFR Part 55.Per Section 5.5 of ANSI 18.1-1971 the licensee should provide means in the training programs for appropriate

evaluation

of its effectiveness.

Contrary to the above the licensee failed to maintain on-the-job

training evaluation

records for the NTOs.Failure of

o the Training Supervisor

to implement the requirements

of A.P.303 constitutes

a violation of Technical Specification 6.4.1.(250/80-38"02, 251/80-37-01)

Prior to and during the exit interview in the discussions

held with the Training Supervisor

the inspector was informed that classroom training for the NTOs will start early January, 1981 and that all the NTOs will be scheduled to complete their training by the end of 1981.The results of this training will be reviewed during a future inspection.(Inspector

Fol 1 owup Item 250/80-38-03, 251/80-37-02)

.'or Unit 4 the inspector observed a portion of the pressurizer

safety valve bench testing performed during each refueling shutdown.Specifically,"pop" tests and seat leakage testing were witnessed on valves 4-551B and 4-551A, respectively.

Also, the inspector performed walkdowns of the containment

spray and high head safety injection systems to verify their operability

for Units 3 and 4 outside containment.

No violations

or deviations

were identified

within the areas inspected.

h 9.Plant Tours Ouring the Unit 3 steam generator inspection

and tube plugging outage (November 26 through Oecember 6, 1980)the licensee had also inspected and modified pipe supports for the Safety Injection and Residual Heat Removal Systems lines located inside the containment.

The pipe supports were structurally

reinforced

based on the results of analyses performed by the Architect Engineering

firm in accordance

with IE Bulletin 79-14,"Seismic Analyses for As Built Safety Related Piping Systems".Just prior to heatup of Unit 3, on Oecember 4, 1980 the inspector performed a walkthrough

inspection

inside the containment

with licensee personnel and visually inspected all of the piping support modifications.

No discrepancies

were observed.