ML17221A551

Responds to Violations Noted in Insp Repts 50-335/87-21 & 50-389/87-20.Corrective actions:in-core Instrumentation Straightened & Acceptance Criteria Met Prior to Head Reassembly.Alignment Method Procedure Will Be Revised

ML17221A551
Person / Time
Site:	Saint Lucie
Issue date:	12/16/1987
From:	Woody C FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
L-87-514, NUDOCS 8712230053
Download: ML17221A551 (6)

Text

a REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR 8712230053 DOC. DATE: 87/12/16 NOTARIZED: NO DOCKET FAC IL: 50-335 St. Lucie Planti Unit 1> Florida Power 8c Light Co. 05000335 50-389 St. Lucie Planti Unit 2I Florida Power 8c Light Co. 05000389 AUTH. NAME AUTHOR AFFILIATION WOODY'. O. Florida Power h Light Co.

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

SUBJECT:

Responds to violations noted in Insp Repts 50-335/87-21 5 50-389/87-20. Correc tive actions: in-core instrumentation straightened 8c acceptance criteria met prior to head reassembly. Alignment method procedure will be revised.

DISTRIBUTION CODE: IEQID COPIES RECEIVED: LTR J ENCL ( SIZE:

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

REC IP IENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 PD 1 TOUR IGNYI E 2 2 INTERNAL: AEOD 1 1 DEDRO 1 1 NRR MOR ISSE*UI D 1 NRR/DLPG/PEB 1 NRR/DOEA DIR 1 1 NRR/DREP/EPB 1 1 NRR/DREP/RPB 2 2 NRR/DRIS DIR 1 NRR /P MAS/ I LR B 1 1 OE LIEBERMANIJ 1 1 OGC/HDS2 1 1 1 RES DEPY GI 1 1 RGN2 FILE 01 1 EXTERNAL: LPDR 1 1 NRC PDR NSIC 1 1 TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL 21

P. O. BOX 14000, JUNO BEACH, FL 3340B-0420 DECEMBER 1 6 1987 L-87-514 10 CFR 2.201 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:

Re: St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Ins ection Re ort 335 87-21 and 389 87-20 Florida Power & Light Company has reviewed the subject inspection report, and pursuant to the provision of 10 CFR 2.201 the response is attached.

There is no proprietary information in this report.

Very truly yours, Pc'P~

C. O. dy Execute e Vice President COW/GRM/gp Attachment cc:. Dr. J. Nelson Grace, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St. Lucie Plant 87i 2230053 87i216 PDR ADOCK 05000335 8 PDR GRM/005 'R an FPL Group company

ATTACHMENT VIOLATIONA Units 1 and 2 Technical Specifications (TS) 6.8.l.a., states that written procedures shall be established, implemented, and maintained covering the activities referenced below: Applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978.

Regulatory Guide 1.33, Revision 2, February 1978, Appendix "A", states in part, that recovery from reactor trip, operation at hot standby, power operation and process monitoring, and re fueling and core alterations are considered general plant operating procedures which should be covered by writte procedures.

Contrary to the above, On October 24, 1987, procedure 2-M-0036, Reactor Vessel Maintenance Sequence of Operations, was not properly implemented in that while performing a lift of the Unit 2 in-core instrumentation (ICI) plate, utilizing the polar crane, a load cell was not utilized as reauired by the procedure. This resulted in excessive lifting force being applied by the crane, resulting in deformation of the ICI plate.

RESPONSE

1. Florida Power and Light Company concurs with the violation.

2. Failure to use the Procedure was the cause for the violation. The foreman involved had previously performed the above task on Unit 1 and believed he understood how to properly perform the job. He was unaware of the potential damage to be sustained when lifting the ICI plate.

3. The ICI plate was straightened and all acceptance criteria were met prior to head reassembly. The individuals involved were counseled on the need for use of procedures and procedural compliance.

4. Training will be altered to cover the details of this violation and proper methods for cribbing the ICI plate.

5. Personnel training will be complete prior to the Unit 1 refueling outage.

ATTACHMENT(continued)

VIOLATION A

2. On October 28, 1987, procedure 1-0700020, Condensate and Feedwater, was not properly implemented in that awhile electrically realigning the Unit 1 operating condensate pumps, the turbine operator, after .removing the 1B pump from the electric lineup, inadvertently stopped the only remaining operating condensate pump which resulted in a loss of feedwater and a subsequent Unit 1 reactor trip from 20Fo power.

Additionally, the procedure was not properly established in that, after completing the electrical realignment, the procedure did not specify how to disengage the protective interlock which is activated during the realignment evolution. This contributed to the confusion which resulted in the inadvertent trip of the condensate pump and subsequent reactor trip.

RESPONSE

1. Florida Po~er and Light Company concurs with the violation.

2. An inadequate procedure was the'ause for the violation.

3. A critique of the trip was held with all personnel involved in the reactor trip.

4. The procedure will be revised to reflect the proper alignment method which should prevent recurrence. A temporary change to procedure is in effect as an interim measure until the revised procedure is issued.

S. The revised procedure should be issued by January 31, 1988.

ATTACHMENT(continued)

RE; ST. LUCIE PLANT - UNIT 2 DOCKET NO. 50"389 IE INSPECTION REPORT 389-87-20 FINDING B:

Unit 2 Operating License NPF-16, item 2.C.10, Non-Safety Related Loads on Emergency Power Sources (Section 8A.2, SER, SSER 3), and 11, Containment Electrical Penetrations (Section 8.4.3, SSER 3), require:

1. Prior to startup follo~ing the first refueling outage, the Licensee shall implement the design modifications to disconnect four-kilovolt loads on detection of a safety injection signal and provide two isolation devices in series for those non-safety electrical loads that are not disconnected by a safety injection signal or a loss of offsite po~er, and

2. Prior to startup following the first refueling outage, the Licensee shall complete the design modifications to provide independent primary and backup fault protection for each electrical conductor penetrating containment.

Contrary to the above, Unit 2 Licensee commitments were not fully implemented, in that, at least eight electrical conductors, which penetrate the Unit 2 containment, were identified as not having the required two isolation devices in series and/or independent primary and backup protection modifications completed prior to startup after the first refueling outage.

RESPONSE

1. FPL concurs with the finding.

2. The cause of this finding appears to be an incorrect engineering assumption by the engineers working on these particular circuits.

The most logical explanation, looking at the circuits identified, seems to indicate an incorrect engineering assumption that a circuit that is not normally in use (i.e. a passive load), such as receptacles, or

, cranes/hoists/elevators which do not operate when the unit is at power, would not require modifications to conform to Regulatory Guide 1.63. The circuits that were modified were done after the plant was in operation and were implemented via PC/M 015-2S3. The individuals who prepared and verified this document appear to have made a conscious decision that these circuits should be excluded from the design modification.

ATTACHMENT(continued)

3. As documented in the NRC's Notice of Violation, FPL immediately took short term corrective action to rectify the situation and revie~

all circuits for compliance to Regulatory Guide 1.63. As circuits were identified, FPL opened the breakers thereby bringing the circuits into conformance with RG 1.63. FPL also took the initiative to investigate all circuits for conformance to Regulatory Guide 1.75.

In addition, FPL immediately investigated the situation for potential reportability to the NRC under 10CFR21. Included in FPL's report, were the recommended actions for disposition of these nonconformances, as well as a safety evaluation substantiating these recommendations.

All circuits that were found to be in nonconformance had the circuit breakers opened, removing power, thereby bringing these circuits into conformance with the recommendations in the safety evaluation and the recommendations of Regulatory Guides 1.63 and 1.75.

4, The responsible engineers have been consulted to advise them of this violation. To ensure that they follow the commitments FPL has made with respect to Regulatory Guides 1.63 and 1.75, the Regulatory Guides'ecommendation have been re-iterated.

In addition, since the development of PC/M 015-283, FPL has developed a new methodology for preparation of Engineering Packages (PC/M's).

FPL now institutes a standard engineering package format which requires more extensive reviews.

Therefore, as a result of the consultation with the engineers which highlighted the importance and recommendations of Regulatory Guide 1.63 and 1.75, combined with the new standard engineering package, which requires more documentation and more indepth reviews, this situation of nonconformances to RG 1.63 and 1.75 will not repeat itsel f.

5. Full compliance was made by de-energizing the circuits in accordance with the safety evaluation issued on September 21, 1987.