L-88-384, Responds to Violations Noted in Insp Repts 50-250/88-11 & 50-251/88-11.Corrective Actions:Chemistry Dept Training Program Revised to Include Addl Instruction on Procedure Usage
| ML17345A351 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 09/02/1988 |
| From: | Conway W FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| L-88-384, NUDOCS 8809070460 | |
| Download: ML17345A351 (6) | |
Text
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CCESSXON NBR:8809070460 DOC.DATE: 88/09/02 NOTARIZED: NO; DOCKET CIL: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 CONWAY,W.F.
Florida Power
& Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Forwards response to Insp Repts 50-250/88-11
& 50-251/88-11
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:
RECIPIENT ID CODE/NAME PD2-2 PD INTERNAL: AEOD NRR MORISSEAUgD NRR/DLPQ/QAB 10 NRR/DREP/EPB 10 NRR/DRIS DIR 9A NUDOCS-ABSTRACT OGC/HDS2 RES/DSIR DEPY RNAL: LPDR NSIC COPIES LTTR ENCL 1
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1 RECIPIENT ID CODE/NAME EDISON,G DEDRO NRR/DLPQ/PEB 11 NRR/DOEA DIR 11 NRR/DREP/RPB 10 NRR/PMAS/ILRB12 RMAN,J REG FILE 02 G
FXLE 01 NRC PDR COPIES LTTR ENCL 2
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LTTR 23 ENCL 23
P. O. BOX 14000, JUNO BEACH, FL 33408 0420 SEPTEMBER 2
1988 L-88-384 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 88-11 Florida Power Light Company has reviewed the subject inspection report and a response is attached.
Very truly yours, W. F.
way Senior Vice President Nuclear WFC/SDF/gp Attachment cc:
Dr. J. Nelson Grace, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant SDF.IR 8809070460 880902 PDR ADOCK 05000250 8
pNU
(
an FPL Group company
ATTACHMENT RE:
TURKEY POINT UNITS 3 AND 4 DOCKET NO. 50-250, 50-251 IE INSPECTION REPORT 250-88-11
& 251-88-11 FINDING:
Technical Specification administrative policies exceed the requirements N18.7-1972 and Appendix (TS) 6.8.1 requires that written procedures and be established, implemented and maintained that meet or and recommendations of sections 5;1 and 5.3 of ANSI A of USNRC Regulatory Guide 1.33.
ANSI N18.7-1972, section 5.1.2 requires that procedures shall be followed.
Appendix A of Regulatory Guide 1.33, section 8.q., requires that specific procedures for surveillances of the Emergency Diesel Generators should be written.
Nuclear Chemistry Procedure NC-103, entitled Diesel Fuel Oil Inventory, Receiving Shipments and Periodic Sampling, revision dated April 14,
- 1988, section 8.3.4, outlines instructions for sampling the Diesel Fuel Oil Tank (through the transfer line).
These instructions include opening valve 004 to obtain the diesel fuel oil sample and then reclosing and locking this valve after filling the sample container.
Contrary to the above, on May 29, 1988, after obtaining a sample from the Diesel Fuel Oil Tank, a chemistry technician locked closed valve 003, the suction valve for the Fuel Oil Transfer Pumps.
Closure of valve 003 caused both Emergency Diesel Generators to be outside the design basis as described in the Final Safety Analysis Report (FSAR).
FSAR, Section 8.2.3, states that transfer of fuel oil from the storage tank to the day tanks to maintain level is accomplished automatically.
With valve 003 closed, manual operator action would be required to restore the day tank fuel oil level.
RESPONSE
1)
FPL concurs with the finding.
2)
The cause of the violation was personnel error in that the Chemistry Technician performed a valve manipulation not required by procedure.
In addition, Chemistry Department Supervision did not provide adequate guidance and controls which in turn allowed the Chemistry Technician to misalign valve 70-003.
The following factors contributed to this violation:
The procedure was reviewed prior to performing the work, but was not taken into the field while performing the work.
The procedure in use did not require signoff or verification of valve manipulations.
Chemistry Supervision did not completely understand and enforce the application of work controls.
Chemistry Supervision did not ensure the Technician was knowledgeable to
perform this task.
The valve locking system did not provide the desired level of error prevention.
The same key could be used to unlock both the sample valve (70-004) and valve 70-003.
The consequences of closing valve 70-003 were not understood by the Technician due to the Technician s level of system knowledge.
3) a) Valve 70-003 was locked open and the operability of the diesel oil transfer system was verified by testing.
b) Safety related system walkdowns were performed to verify proper alignment.
c) The Technician involved was disciplined.
d) The responsibility for ensuring that Chemistry Technicians are qualified for the tasks they perform has been re-emphasized to the Chemistry Supervisors A
matrix of Technician qualification versus tasks has been developed to ensure that the Technicians are qualified for the tasks they perform.
e)
The Chemistry Supervisor conducted a training session with the Chemistry Technicians emphasizing procedural compliance.
f) Procedure 0-ADM-650 "Chemistry Department Policy Procedure" was issued detailing requirements for Chemistry Department procedural compliance.
g) The Training Department issued Information Bulletin 88-02 to plant personnel.
This bulletin details the administrative requirements for work controls and procedural compliance.
Tests were given to selected individuals to determine the effectiveness of the training bulletin.
The results from this testing were evaluated, and indicate that further training on work controls is required for first line supervisors.
h) The Chemistry Department training program was revised to include additional instruction on procedure usage.
4) a) Chemistry procedures that require manipulations of safety related valves will be reviewed and revised to require signoffs, or signoff and independent verification, as necessary.
b) Valves which are essential to safety related flow pa'ths and are required to be locked in position will have their locks changed so that only Operations personnel wi.ll be able to manipulate the valves.
c) The Chemistry Department training program will be revised to provide instruction on selected valve types, valve position determination and valve identification.
d) Training on work controls will be implemented in New Employee Training and General Employee Training (GET).
e) Work control training will be incorporated into continuing training programs for plant staff.
f) System training will be incorporated into continuing training programs for Chemistry Technicians.
g) Training on work controls will be provided to first line supervisors per 3g above.
5)
Full Compliance for item 3 above was achieved by August 31, 1988.
Full compliance for items 4a, 4b and 4c above will be achieved by December 31, 1988.
Full compliance for item 4d above will be achieved by September 3,
1988.
Full compliance for item 4e above will be achieved by December 15, 1988.
Full compliance for item 4f above will be achieved by September 27,1988.
Full compliance for item 4g above will be provided by September 30, 1988.