L-92-244, Forwards Response to Violations Noted in Insp Rept 50-389/92-11.Corrective Actions:Work Completed to Reinstall Seismic Clamp Under Plant Work Order 92041291 on 920710 & Change to Nuclear Plan Work Orders Completed

Forwards Response to Violations Noted in Insp Rept 50-389/92-11.Corrective Actions:Work Completed to Reinstall Seismic Clamp Under Plant Work Order 92041291 on 920710 & Change to Nuclear Plan Work Orders Completed

ML17227A590
Person / Time
Site:	Saint Lucie
Issue date:	09/09/1992
From:	Goldberg J FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-92-244, NUDOCS 9209180164
Download: ML17227A590 (4)

Text

DOCKET ¹ 05000389

SUBJECT:

Forwards response

.to violations noted in Insp Rept 50-389/92-11.Corrective actions:work completed to reinstall seismic clamp under Plant Work Order 92041291 on 920710 Il change to nuclear plan work orders completed..

DISTRIBUTION CODE:

IE01D COPIES RECEIVED:LTR ENCL A SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:

~CCEr.Em~TED DrSTalamlow DErvrOXSTB.<Trav SUSIE~~

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

SSION NBR:9209180164 DOC.DATE: 92/09/09 NOTARIZED: NO IL:50;389 St.

Luci'e Plant, Unit 2, Fl'orida Power a Light Co..

UTH.N%>IE AUTHOR AFFILIATION GOLDBERG,J.H.

Florida Power a Light Co.

REOIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

R RECIPIENT ID CODE/NAME PD2-2 PD INTERNAL: ACRS AEOD/DEIB AEOD/TTC NRR MORISSEAUgD NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NUDOCS-ABSTRACT OGC/HDS3 RGN2 FILE 01 EXTERNAL: EG&G/BRYCEIJ.H.

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RECIPIENT ID CODE/NAME NORRISiJ AEOD AEOD/DSP/TPAB DEDRO NRR/DLPQ/LHFBPT NRR/DOEA/OEAB NRR/PMAS/ILRB12 OE D

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A NOTE TO ALL RIDS RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK.

ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED:

LTTR 24 ENCL 24

P.O. Box 128; Ft. Pierce, Fi 34954-0128 PPt SEP -9 1992 L-92-244 10 CFR 2.201 U. S. Nuclear Regulatory. Commission Attn:

Document Control Desk Washington, D., C.

20555 Re:

St. Lucie Unit 2 Docket No. 50-389 Reply to Notice. of Violation Ins ection Re ort 92-11

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Florida Power and Light Company (FPL) has reviewed the subject inspection report and pursuant to 10 CFR 2.201 the response to the notice of violation is attached.

Very truly yours,

.4E~

J.

H. Goldberg President Nuclear Division

'JHG/JWH/kw Attachment cc: Stewart D. Ebneter, Regional Administrator, USNRC Region II Senior Resident Inspector, USNRC, St. Lucie Plant DAS/PSL 5768-92 9209180164 920'PO'P PDR ADOCK 0500038'7 9

PDR an FPL Group company

g St. Lucie Unit 2 Docket No. 50-389 Reply to Notice of Violation Ins ection Re ort 92-11 VIOLATION:

Unit 2 Technical Specification (TS) 6.8.l.a requires that written procedures shall be established, implemented and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Appendix A, paragraph 9.a, includes maintenance that can affect the performance of safety-related equipment.

This requirement is implemented in part by procedure AP 0010432, Rev"'60, Nuclear Plant Work Orders, paragraph 8.10, which requires that all work be completed within the scope of the work document.

Contrary to the above, during a Unit 2 tour on July 10, 1992, the NRC inspector observed that a large seismic support under safety-related MV-21-4B, the Train "B" Motor Operated Valve for the seal water supply header, was not attached to the safety-related conduit serving MV-21-4B, thus was not performing its safety function.

The conduit had not been reattached to this seismic support following the temporary removal of both to facilitate completion of plant change 273-290D, Monel Substitution for Aluminum Bronze, during the recent refueling outage.

The licensee should have known from the work control and inspection processes that the conduit was not attached as designed.

The licensee subsequently reviewed the as-found condition for operability since the licensee had recently changed the Unit 2

operating mode several times with this seismic support disassembled.

Subsequent licensee stress analysis found that both the electrical conduit and MV-21-4B had actually been operable as found in spite of the conduit not being attached to the support.

I Re:..St.

Lucie Unit 2 Docket No. 50-389 Reply to Notice of Violation Ins ection Re ort 92-11

RESPONSE

1 ~

The reason for the violation was lack of procedural guidance in AP 0010432 "Nuclear Plant Work Orders."

This procedure lacked guidance to planners concerning work order planning on seismic structures in the maintenance area.

A contributing factor 'was personnel error on the part of maintenance workers and supervision.

The maintenance workers and supervision were not sensitive to the importance of certain components necessary for meeting seismic requirements.

2.

Corrective Ste s Taken and Results Achieved A)

Work was completed to reinstall the seismic clamp under plant work order 92041291 on July 10, 1992.

Corrective Ste s to Avoid Further Violations A)

A change to AP 0010432 "Nuclear Plant Work Orders" has been completed.

This procedure now requires all planners to identify those components required to maintain equipment within the required seismic configuration on the work order utilizing appropriate drawings.

The work order will also list those components that must be reinstalled to return the equipment to proper seismic configuration.

Furthermore, the signature block responsibility on PWO signoff has been revised to include the responsible person to check for reinstallation of the listed seismic components.

B)

Training of

Planners, Supervisors,

Foremen, and Journeymen in all maintenance disciplines will be completed by September 30, 1992.

This training will stress the importance of components necessary for meeting seismic requirements and the new requirements contained in AP 0010432 "Nuclear Plant Work Orders" 4.

Full compliance was achieved

-on July 10,

1992, upon the'ompletion of the corrective action in paragraph

'2.

Training of Planners, Supervisors,

Foremen, and Journeymen in all maintenance di'sciplines willbe completed by September 30, 1992.