ML17223A436

Responds to Violations Noted in Insp Repts 50-335/89-23 & 50-389/89-23.Corrective actions:resin-fill Funnels Removed, Gasketed Flanges Installed & Metal Trench Covers Replaced

ML17223A436
Person / Time
Site:	Saint Lucie
Issue date:	12/13/1989
From:	Goldberg J FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-89-440, NUDOCS 8912200314
Download: ML17223A436 (8)

Text

gCCELZRATED KFZR1BUTIO> DEMONSTRATIO> ~ST~M REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

NBR:8912200314 DOC.DATE: 89/12/13 NOTARIZED: NO DOCKET FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power & Light Co. 05000335 50-389 St. Lucie Plant, Unit 2, Florida Power & Light Co. 05000389 UTH.NAME AUTHOR AFFILIATION OLDBERG,J.H. Florida Power & Light Co.

1'CCESSION RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to violations noted during insp of Licenses DPR-57

& NPF-16.

DISTRIBUTION CODE: IEOID COPIES RECEIVED:LTR j ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation esponse NOTES: g(g$

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 PD 1 NORRIS,J 1 1 INTERNAL: ACRS 2 2 AEOD 1 1 AEOD/DEIIB 1 1 AEOD/TPAD 1 1 DEDRO 1 1 NRR SHANKMAN,S 1 1 NRR/DET/DZR 8H3 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA DIR 11 1 1 NRR/DREP/PEPB9D 1 1 NRR/DREP/PRPB11 2 ~ 2 NRR/DRIS/DIR 1 1 NRR/DST/DIR SE2 1 1 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT OGC/HDS2 RES MORZSSEAUPD 1

1 1

1 1

1 0

REG FIL RGN2 FILE

'2 RMAN, J 01 1

1 1

1 1

1 EXTERNAL: LPDR NRC PDR 1 1 NSIC D

TOTAL."NUMBER OF,CGPZES. REQUIRED: LTTR 27 ENCL 27

f P.O. Box 14000, Juno Beach, FL 33408 0420 APL L-89-440 10CFR 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 Inspection Report. 89-23 Re 1 to a Notice of Violation

'I Florida Power & Light Company has reviewed the subject inspection report, and pursuant to the provisions of 10 CFR 2.201, the response is attached. Based on a discussion with NRC Region Staff the response date was revised to December 13, 1989.

II Very I truly yours, J'J>~

J. H. Goldberg Executive Vice President JHG/JRH/rh Attachment cc: Stewart D. Ebneter, Regional Administrator, Region Senior Resident Inspector, USNRC, St. Lucie Plant II, USNRC 8p122003i4 8~1~>3 C5000335 PDR ADOCK G PNU

L-89-440 Attachment VIOLATION A.

Unit 1 Technical Specification 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 7.a., recommends procedures for the liquid radioactive waste system including "demineralizing". Appendix "A" paragraph 3.n., recommends procedures for the chemical and volume control system, which contains some of the ion exchangers addressed in the subject procedure. These were implemented in-part on site by operating procedure OP 1-0520020, Radioactive Resin Replacement, which provided instructions for resin replacement on various ion exchangers, including the 1D waste ion exchanger.

Contrary to the above, on August 20, 1989, the licensee failed to implement the above procedure. The procedure was signed as being complete for. the 1D waste ion exchanger; however, the resin fill funnel was left installed on the resin isolation valve flange and exposed to the weather until fill September 8, 1989, when The fill it was discovered by an NRC inspector.

isolation valve, which was a potential unmonitored radioactive release point, is located in a shallow trench on the auxiliary building roof. This fill station, as shown by diagrams in the Final Safety Analyses Report, would normally be sealed after resin filling by a bolted and gasketed blank flange and would also be protected by a bolted metal trench cover.

Subsequent procedure review showed that the procedure was also inadequately established.

funnel installation/removal; It blank did not adequately address flange removal, temporary storage, or reinstallation; stowage instructions for the potentially contaminated funnel; management control of departmental nor did it provide adequate interfaces during the process.

RESPONSE A:

1~ Florida Power & Light concurs with the violation.

2 ~ The cause of the violation was personnel error and inadequate procedure. The procedure being implemented did not provide the specific actions to be accomplished when resin replacement was complete.

3 ~ The resin installed fillthe and funnels were removed, gasketed flanges metal trench covers were replaced.

4 ~ Operating Procedures 1-0520020 and 2-0520020 will be revised to'rovide the interdepartmental controls for the installation and removal of the resin blank flanges.

fill funnels and

5. Corrective actions are scheduled to be completed by February 1, 1990.

L-89-440 Attachment Pg 2 VIOLATION B:

Units 1 and 2 TS 6.8.1a require 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 procedures for maintenance of safety-related equipment. This requirement was implemented in part by procedures 1-M-0018 and 2 M 0018) Mechanical Maintenance Safety-Related Preventive Maintenance (PM). Program, that implemented PM requirements on the strainers for the bearing lubricating water for the Unit 1 and 2 intake cooling water (ICW) pumps.

Contrary to the above, the subject procedures were inadequately established in that they did not provide appropriate inspection guidance concerning self-cleaning strainers and y-type strainers in the bearing lubricating water systems for the ICW pumps. The procedures did not provide strainer inspection acceptance criteria, service limits, or repair specifications. The lack of inspection guidance allowed a change in strainer mesh size to go unquestioned and excessive deterioration of self-cleaning strainers to be unrecognized. The change in strainer mesh size was a major contributor to lA ICW pump bearing failures caused by y-type strainer blockage.

RESPONSE

B'lorida Power & Light concurs with the violation.

2 ~ The cause of the violation was an inadequate procedure.

The inspection acceptance .criteria, service limits, and spare parts information were not provided in'the ICW pump bearing lubricating water system preventative maintenance activities. (PM file numbers 153, 154, 155, and 156 for Unit 1 and PM file numbers 00501, 00502, 00503, and 00504 for Unit 2). These activities are specified in the Mechanical Maintenance Safety-Related Preventive, Maintenance Program Procedures (1-M-0018 and 2-M-0018).

3 ~ The preventative maintenance (PM) activities for the ICW pump bearing lubricating water system specified in procedures 1-M-0018 and 2-M-0018 have been'evised to provide the inspection acceptance criteria, repair guidelines and spare parts information.

L-89-440 Attachment Pg 3 4 The maintenance department will review a representative sample of other PMs in procedures 1-M-0018 and 2-M-0018 to determine if'he inspection acceptance criteria, and spare parts information are repair guidelines included. . Based on. the results of this review the corrective actions specified in item ,3 above will be expanded to include additional PM activities as warranted. This review is scheduled to be completed by January 31, 1990.

5. Item 3 above was completed on October 30, 1989.

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