ML17223B224

Responds to NRC Ltr Re Violations Noted in Insp Rept 50-389/91-11.Corrective Actions:Mgt Expectations Re Existing Valve Verification Policy Restated to Operations Staff.Civil Payment to Be Transmitted by Electronic Transfer

ML17223B224
Person / Time
Site:	Saint Lucie
Issue date:	07/11/1991
From:	Goldberg J FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
EA-91-062, EA-91-62, NUDOCS 9107190029
Download: ML17223B224 (7)

Text

ACCELERATED DISTRIBUTION DEMONSTPATION SYSTEM

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rj REGULATORY INFORMATION DISTRIBUTION SYSTEM (RXDS)

ESSXON NBR:9107190029 DOC.DATE: 91/07/11 NOTARIZED: YES FACIL:50-389 St. Lucie Plant, Unit 2, Florida Power

& Light Co.

AUTH.NAME AUTHOR AFFILIATION GOLDBERG,J.H.

Florida Power

& Light Co.

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

DOCKET 05000389

SUBJECT:

Responds to NRC ltr re violations noted in Insp Rept 50-389/91-11.Corrective actions:mgt expectations re existing valve verification policy restated to operations staff. Civil payment to be transmitted by electronic transfer.

DISTRIBUTION CODE: IEOID COPIES RECEIVED:LTR i

ENCL j SIZE:

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

INTERNAL:

RECIPIENT ID CODE/NAME PD2-2 PD ACRS AEOD/DEIIB DEDRO NRR SHANKMAN,S NRR/DOEA/OEAB NRR/DST/DIR 8E2 NRR/PMAS/ILRB12 OE DIRLE~

COPIES LTTR ENCL 1

1 2

2 1

1 1

1 1

1 1

1 1

1 1

1 1

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1 RECIPIENT ID CODE/NAME NORRIS,J AEOD AEOD/TPAB NRR MORISSEAU,D NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NRR/OTSB 11E22 NUDOCS-ABSTRACT OGC/HDS3 RGN2 FILE 01 COPXES LTTR ENCL 1

1 1

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EXTERNAL: EG&G/BRYCE,J.H.

NSXC 1

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1 NRC PDR 1

1 D

NOTE TO ALL"RIDS" RECIPIENTS:

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PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

AL NUMBER OF COPIES REQUIRED:

LTTR 24 ENCL 24

P.O. Box14000, Juno Beach, FL 33408-0420 NL1 l Nl L-91-193 10 CFR 2.201 Director, Office of Enforcement U. S. Nuclear Regulatory Commission Attn:

Document Control Desk Washington, D.C.

20555

Dear Sir:

Re:

St. Lucie Unit 2 Docket No. 50-389 Inspection Report 91-11 Re l to Notice of Violation EA 91-062 Florida Power and Light Company (FPL) has reviewed the subject notice of violation.

Pursuant to the provisions of 10 CFR 2.201 and Section 182 of the Atomic Energy Act of 1954, as

amended, the reply to the notice of violation is attached.

FPL will pay the civil penalty by electronic transfer.

This payment will be confirmed under separate cover.

Very truly yours, J.

H. Goldberg President Nuclear Division JHG JWH kw Attachment cc: Stewart D. Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St. Lucie Plant DAS/PSL N465-91 Pj.07$ 9O029'107il PDR ADOCK 0000389 Qi POR an FPL Group company peal

St. Lucie Unit 2 Docket No. 50-389 Inspection Report 91-11 Re l to Notice of Violation STATE OF FLORIDA

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COUNTY OF PALM BEACH

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J.

H. Goldberg being first duly sworn, deposes and says:

That he is President, Nuclear Division of Florida Power

& Light

Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information and belief, and that he is authorized to execute the document on behalf of said Licensee.

J.

H. Goldbe Subscribed and sworn to before me this l(

day of z.s 9'/.

NOTARY PUBLIC, in and fo t e County of Palm Beach, State of Flora a

4'otery Public, State of Fforida My Commission Expires June 1, 1993 COmmiSSion eXpireS Bonded shw Troy fain ~ Inivanco rnc.

St. Lucie Unit 2 Docket No. 50-389 Inspection Report 91-11 Re 1

to Notice of Violation VIOLATION:

Unit 2

Technical Specification 3.6.2.1, Containment Spray

System, requires that, in Modes 1,

2, and 3,

two independent containment spray systems be OPERABLE.

Further, this Technical Specification requires that each spray system flow path from the containment sump shall be via an OPERABLE shut down cooling heat exchanger.

If one containment spray system is inoperable, it must be restored within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the unit must be in hot standby within six hours.

Unit 2 Technical Specification definition 1.19 defines a system, subsystem,

train, component, or device as being OPERABLE or having OPERABILITY when it is capable of performing its specified function(s) and when all necessary attendant instrumentation,

controls, electrical

power, cooling or seal

water, lubrication, or other auxiliary equipment that are required for the system, subsystem,

train, component or device to perform its function(s) are also capable of performing their related support function(s).

Contrary to the

above, with Unit 2 operating Mode 1, the 2A containment spray system was not OPERABLE from about November 29, 1990, when manual component cooling water valve 2-SB-14365, servicing the 2A shutdown cooling heat exchanger, was locked closed vice locked open, until April 26, 1991.

The 2A shutdown cooling heat exchanger was not OPERABLE with the manual component cooling water outlet valve closed as it would not cool recirculation flow from the containment sump with no cooling water flow.

The 2A containment spray system was not OPERABLE with an inoperable shutdown cooling heat exchanger.

RESPONSE

1.

Florida Power and Light Company concurs with the violation.

2.

The reasons for the violation were:

a)

Cognitive personnel error by a non-licensed operator which led to the closure of valve 2-SB-14365.

b)

Operators relied on visual verification methods to check locked valves instead of using the established valve verification policy.

c)

Management follow-up of the existing valve verification policy implementation was insufficient.

St. Lucie Unit 2 Docket Nos.

50-389 Inspection Report 91-11 Re l to Notice of Violation d)

Valve 2-SB-14365 position indicator had a faulty position indicator design which caused the position indicator to be inoperable.

3.

Valve 2-SB-14365 was immediately opened and the CCW outlet valve on the other train was verified and found open.. In

addition, a hands-on verification of 409 safety related valves for Units 1 and 2 was conducted.

No discrepancies were discovered.

4.

The corrective actions taken to prevent recurrence were:

a)

Management expectations regarding the existing valve verification policy were restated to the Operations staff by the President Nuclear Division.

b)

A discipline policy concerning procedural non-compliance has been issued by the President, Nuclear Division.

c)

Joint Quality Control/Operations surveillances of the Weekly Valve Status Check (Administrative Procedure AP

0010125A, Data Sheet

36) are being performed.

These surveillances have uncovered no discrepancies as of this date.

d)

A valve indicator enhancement to all applicable Pratt valves on Units 1 and 2 has been completed.

5.

All corrective actions have been completed.