L-84-353, Responds to NRC Re Violations Noted in Insp Repts 50-250/84-25 & 50-251/84-26.Corrective Actions:New Training Video Tape Prepared to Address Requirements of Administrative Procedure 0306

Responds to NRC Re Violations Noted in Insp Repts 50-250/84-25 & 50-251/84-26.Corrective Actions:New Training Video Tape Prepared to Address Requirements of Administrative Procedure 0306

ML20113B085
Person / Time
Site:	Turkey Point, 05000000
Issue date:	11/28/1984
From:	Williams J FLORIDA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20113B077	List: L-84-353, Responds to NRC Re Violations Noted in Insp Repts 50-250/84-25 & 50-251/84-26.Corrective Actions:New Training Video Tape Prepared to Address Requirements of Administrative Procedure 0306
References
RTR-NUREG-0737, RTR-NUREG-737 L-84-353, NUDOCS 8501210312
Download: ML20113B085 (4)

Text

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, , t. CA FLORIDA POWER & LIGHT COMPANY

.3 el:56

?!ovember 28, 1984 L 353 Mr. James P. O'Reilly Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Inspection Report 250-84-25 and 251-84-26 Florida Power and Light Company has reviewed the subject inspection report and a response is attached.

There is no proprietary information in the report.

Very truly yours, J. W. Williams, Jr.

Group Vice President Nuclear Energy Department JWW/JA/ms/K26 Attachment cc: Harold F. Reis, Esquire 85012103{2 g gj250 PDR ADOC PDR G

PEOPLE. . SERVING PEOPLE

ATTACimENT Re: Turkey Point Units 3 and 4 l Docket No. 50-250, 50-251 IE Inspection Report 84-250-25 and 84-251-26

)

I FINDING 1-l 10 CFR 50, Appendix B, Criterion V requires activities affecting quality to be prescribed by documented procedures and to be accomplished in accordance with these procedures.

Turkey Point Administrative Procedure 0306 requires employees entering the plant protected area to attend the General Employee Orientation consisting of a security orientation, 0A/0C presentation, general plant orientation, emergency alarms and responses, and listening to an audio tape identifying plant emergency alarms.

Contrary to the above, employees receiving blue badges are only given a general employee handbook and required to listen to an audio tape identifying emergency alarms and responses.

RESPONSE

1) FPL concurs with the finding.

2) The reason for the finding was inadequate implementation of Administrative Procedure (AP) 0306, " General Employee Training and Retraining".

- 3) A new trair.ing video tape was prepared to addrats the requirements of AP 0306 including a security orientation, 0A/0C presentation, general plant orientation, and emergency alarms and responses. This tape was shown to blue badge status personnel as a requirement to comply _with AP 0306.

4) All new plant personnel receiving blue badge status and blue badge personnel attending biennial requalification will be shown the above mentioned tape in accordance with AP 0306.

5) Full compliance was achieved on November 6,1984 FIlWING 2:

10 CFR 50, Appendix B, Criterion V requires activities affecting quality to be prescribed by documented procedures and to be accomplished in accordance with these procedures.

~

Turkey Point Administrative' Procedure 0307 requires 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of on-the-job training prior to qualification for and assumption of shift technical advisor on-shift duties.

Contrary to' the above, the past two shif t technical advisor training cycles allotted only 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> and 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />, respectively, to on-the-job training prior to qualification for and assumption of shift technical advisor on-shift duties.

k-

R2: IE Inspecticn Repnrt 250-84-25 and 251-84-26 Page 2

RESPONSE

1) FPL concurs with the finding.

2)

The reason for the finding was inadequate implementation of qualification requirements for the shif t technical shift as described in AP 0307 advisors (STAS) prior to going on 3)

Turkey Point Plant has re-evaluated the STA qualifications and has found that individuals involved in the past two STA training cycles that are performing STA duties, have accumulated at experience. least 170 hours0.00197 days <br />0.0472 hours <br />2.810847e-4 weeks <br />6.4685e-5 months <br /> of on shift evolutions as witnessing: This experience includes, apart from normal duties, such a) reactor startups b) load changes at power c) normal and off-normal conditions.

As a result of this evaluation, FPL feels that these individuals presently addition, meet the qualifications for STAS as described in AP 0307 In they have accumulated at least t rainin g. 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of simulator Training Reactor Additionally, the STAS have received training at a Nuclear and classroom included: training. This classroom training a) basic reactor theory b) neutron kinetics c) principles of BF3 and ion chamber detectors d) subcritical multiplication e) interlock and reactor protection systems f) g) overview of control and reactor protection logics emergency and off-normal procedures h) technical specifications i) hot channel factors i

J) control rod worth l k) departure from nucleate boiling ratio (DNBR)

1) modtrator temperature coefficient (MTC) m) unresolved safety questions.

4)

To preclude recurrence, the following actions will be taken:

a)

AP 0307 will be reviewed and changes will be made as necessary to complyinwith 2,1981 response the commitments made in FPL letter L-81-1, dated January to NUREG-0737.

b)

As a part of this procedure change, a sign-off sheet will be included detailing training. the requirements to be completed by the STA during This completed sign-off sheet will require review and approval by plant management prior to the STA assuming shift responsibilities.

5)

Full compliance for item (4) above will be achieved by December 21, 1984

{ .

o Re: IE Inspection R pirt 250-84-25 and 251-84-26 Page 3 NOTICE OF DEVIATION:

Florida Power and Li ght Company letter L-81-1, dated January 2, 1981, in response to NUREG-0737, states that 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of simulator training will be given to shift technical advisor candidates, unless the individual can demonstrate adequate knowledge in this area.

Contrary to the above, three personnel were utilized as shift technical advisors without demonstrating adequate knowledge or possessing previous operating experience and prior to receiving simulator training.

RESPONSE

1) FPL concurs with the deviation.

2) The reason for the deviation was inadequate implementation of commitments made under FPL letter L-81-1 in response to NUREG-0737, in that our procedure AP 0307 did not require 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of simulator training as a prerequisite for STA candidates.

3) Turkey Point Plant has re-evaluated the STA qualifications and found that STAS, including the 3 individuals in question, have accumulated at least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of simulator training. Additionally, the STAS received training at a Nuclear Training Reactor and classroom training. This classroom training included:

a) basic reactor theory b) neutron kinetics c) principles of BF3 and ion chamber detectors d) subcritical multiplication e) interlock and reactor protection systems f) overview of control and reactor protection logics g) emergency and off-normal procedures h) technical specifications

1) hot channel factors j) control rod worth k) departure from nucleate boiling ratio .(DNBR)

1) moderator temperature coefficient (MTC) m) unresolved safety questions.

4) To preclude recurrence, the following actions will be taken:

a AP 0307 will be reviewed and changes will be made as necessary to comply with the commitments made in FPL letter L-81-1, dated January 2, 1981, in response to NUREG-0737 b) As a part of the procedure change, criteria will be included to detail simulator training or related experience as a prerequisite to assuming shift responsibilities. Also a sign-off sheet will be included detailing the requirements to be completed by the STA during trai ni ng. This comoleted sign-off will require review and approval by plant management prior to the STA assuming shift responsibilities.

5) Full' compliance for item (4) above will be achieved by December 21, 1984

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