ML17229A062

Responds to NRC 960927 Ltr Re Violations Noted in Insp Repts 50-335/96-11 & 50-389/96-11.Changes Were Made to Applicable Plant Preventive Maintenance & Surveillance Testing Procedures to Discontinue Practice of Lubricating

ML17229A062
Person / Time
Site:	Saint Lucie
Issue date:	09/27/1996
From:	Plunkett T FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
EA-96-260, L-96-234, NUDOCS 9610080101
Download: ML17229A062 (6)

Text

DA. L K(iUKY J.

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9610080101 DOC.DATE:

~ 96/09/27 NOTARIZED: NO DOCKET FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power a Li'ght Co. 05000335 50-389 St. Lucie Plant, Unit 2, Florida Power & Iight Co. 05000389 AUTH. NAME AUTHOR AFFILIATION PLUNKETT,T.F.~ Florida

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Power a Light Co.

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

SUBJECT:

Responds 50-335/96-11 to NRC 960927 ltr re 6 50-389/96-11.Changes violations noted in insp repts were made to applicable plant preventive maintenance & surveillance testing procedures to discontinue practice of lubricating.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES: G RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-3 PD 1 1 WIENSgL. 1 1 INTERNAL: ACRS 2 2 AEOD/SPD/RAB 1 1 AEOD/TTC 1 1 DEDRO 1 1 TER 1 1 NRR/DISP/PIPB 1 1 B 1 1 NRR/DRPM/PECB 1 1 NRR/DRPM/PERB 1 1 NUDOCS-ABSTRACT 1 1 OE DIR 1 1 OGC/HDS3 1 1 RGN2 FILE 01 1 1 D

EXTERNAL: LITCO BRYCE,J H 1 1 NOAC 1 1 NRC PDR 1 ~

1 0 C,

U E

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 19

Florida Power & Light Company, P.O. Box 14000, Juno Beach, FL 33408-0420 SEP 27 3998 L-96-234 10 CFR 2.201 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Re: St. Lucie Units 1 and 2 Docket No. 50-335 and 50-389 Reply to a Notice of Violation Ins ection Re ort 96-11 EA 96-260 Florida Power and Light Company 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, T. F. Plunkett President Nuclear Division TFP/JAS/EJW Attachment cc: Stewart D. Ebneter, Regional Administrator, USNRC Region II Senior Resident Inspector, USNRC, St. Lucie Plant V

9'6i0080iOI, 960927 PDR ADQCK 05000335 8 PDR an FPL Group company

L-96-234 Attachment Re I to a Notice of Violation Violation Citation During an NRC inspection conducted on July 7 through August 3, 1996, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," (60 FR 34381; June 30, 1995), the violation is.

listed below:

A. 10 CFR 50, Appendix B, Criterion XI, requires, in part, that a test program shall be established to assure that all testing required to demonstrate that systems and components will perform satisfactorily in service is identified and performed in accordance with written test procedures. Test- procedures shall include provisions for assuring that the test is performed under suitable environmental conditions.

Contrary to the above, Administrative Procedures, AP-1-0010125A, revision 39, for Unit 1 and AP-2-0010125A, revision 43, for Unit 2, did not ensure that the procedures were performed under suitable environmental conditions. Specifically, the two aforementioned procedures directed that valves 1-FCV-07-1A, 1-FCV-07-1B, 2-FCV-07-1A,'nd 2-FCV-07-1B be lubricated prior to being tested. This practice negated the ability to assess the operational readiness of the valves.

This is a Severity Level IV violation (Supplement I).

Violation Res onse

1. FPL concurs with the violation

2. Reason for the Violation The root cause of the violation was incorrect procedural direction to plant personnel in the sequencing of preventive maintenance and surveillance testing. Specifically, post-preventive maintenance surveillance testing did not permit the proper assessment of the as-found condition of the valves. The following were contributing factors to the violation: 1) There was a lack of understanding and appreciation by plant personnel that the practice of pre-lubrication resulted in the valves being surveilled under other than suitable, or "as found," conditions; and, 2) There were inadequate management controls in the maintenance planning and scheduling processes to assure that the sequencing of maintenance and testing activities was appropriate for these valves.

L-96-234 Attachment Re I to a Notice of Violation

3. CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED Changes were made to the applicable plant preventive maintenance and surveillance testing procedures to discontinue the practice of lubricating the valves prior to surveillance testing. The procedural changes require that lubrication not be performed if the surveillance test has not been performed. This action was completed by December 7, 1995.

4. CORRECTIVE STEPS TO AVOID FURTHER VIOLATIONS A. St. Lucie Plant problem reports (STARs 951063 and 960127) were written to review other plant preventive maintenance procedures to determine if similar preconditioning procedural allowances existed elsewhere. Components associated with the 1C and 2C Auxiliary Feedwater pumps, St. Lucie Unit 2 emergency core cooling system (ECCS) ventilation dampers, and St. Lucie Unit 1 control room ventilation dampers, were identified as potentially being subject to surveillance test preconditioning. Changes were made to these components'reventive maintenance procedures to prohibit this practice prior to surveillance testing. This action was completed on March 25, 1996.

B. The St. Lucie Plant General Manager has issued a memorandum, dated September 18, 1996, to the Operations Supervisor, Engineering Manager, and Work Controls Group Manager stating that preconditioning a component prior to performing a surveillance test violates the Federal regulations and is an unacceptable practice. The managers were instructed to be aware of the violation and alert for other conditions and tests which may result in preconditioning components. In addition, precautions related to component preconditioning will be incorporated into appropriate St. Lucie Plant Operating and Maintenance Procedures. This action will be completed by October 25, 1996.

St. Lucie Plant has recently implemented a 13 week rolling maintenance program. In this program, preventive maintenance, surveillance, and testing are planned weeks in advance of the activity. An important feature of this program is the up-front review and coordination of all maintenance prior to work being authorized via the Plan of the Day (POD). This pre-planning according to applicable guidance will ensure that the improper sequencing of work is not performed since the only authorized plant work is that accomplished in

L-96-234 i Attachment Re I to a Notice of Violation accordance with the POD, with the exception of unplanned Limiting Condition for Operation (LCO) ACTION statement entries requiring immediate attention.

Full compliance was achieved on December 7, 1995, with the completion of item 3, above.

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