ML17338A229
| ML17338A229 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 09/18/1978 |
| From: | Robert E. Uhrig FLORIDA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML17338A228 | List: |
| References | |
| L-78-316, NUDOCS 7810240071 | |
| Download: ML17338A229 (5) | |
Text
September 18, 1978 L-78-303 Mr. James P. O'Reilly, Director, Region III Office of Inspection and Enforcement U.
S. Nuclear Regulatory Commission 101 Marietta Street, Suite 3100
Dear Mr. O'Reilly:
Re:
RII:EHV 50-250/78-12 50-251/78-12 Florida Power
& Light Company has reviewed the subject inspection report and a response is attached.
There is no proprietary information in the report.
er~Muly yours,
.-..-, +- /i,.
Robert.
E. Uhrig Vice President REU/MAS/dlh Attachment cc: Robert Lowenstein, Equire
-1 8 (o~goo l(
ATTACHMENT Re:
RII:EHV 50-250/78-12 50-251/78-12 Findinq A
Technical Specifications, Section 6.8.1 requires that written procedures and administrative policies be established, imple-mented and maintained that meet or exceed the requirements and recommendations of Section
- 5. 1 and 5.3 of ANSI 18.7-1972 nd Appendix "A" to,Regulatory Guide 1.33.
Section 8.1.2 of Administrative Procedure 0190.19 (Control of Maintenance on Nuclear Safety Related Systems) requires that the Assistant Superintendent Nuclear Maintenance, Electrical Maintenance, I&C Supervisor or their designees will approve the Plant Work Order (PWO} in the Nuclear Supervisor approval signature block.
Contrary to the above, during the period of September 2,
1976 to May 17, 1978 seven Plant Work Orders (PWO Nos.
- 0336, 1657,
- 1745, 2319,
- 2372, 7542, 7746) were missing the Nuclear Supervisor signature.
~Ree once R
The procedure refe. enced in the Finding was approved on October 18, 1977.
The previous version of the procedure, which was app.ovec'.
on August 6, 1975, did not require the Nuclear Super-visor block to be signed off.
Four of the PWOs listed were daterior to October 18, 1977.
Specificallv, PWO 0336 was date<i June 24,
- 1977, PWO 1657 was dated March 22,
- 1977, PWO 2745 (1 istc<! in the inspection report as 1745) was dated January 13,
- 1977, anc'.
PWO 2372 was dated July 8, 1976.
For these PWOs the lac), of a signature does not constitute noncompliance
- because, at the tine they were wri tten, there was no requirement to sign the '.nuclear Supervisor block.
Thc. pur!>ose of the signature requirement is to ensure that proper cont.rois are ap;>lie<) to nuclear safety related work.
T'>~ three remaini n<; Pt'Os 1 istc c! in the Fine! in<; were reviewe<'.
from that stand)>oint..
I t. was founc! that each one had the
".':ucl ear Sa fe ty Rel a t e<! - Yes" block and the approp'riatc Rac! i a-tion York Permi t block checkec!,
and that procedures were 1 is to,!
when the, werc rc<)uirc <! to do the work.
This inc!icates that the rc.view, which shoulc! have been documented by a signature in the !'uclear Su)>crvisor block, was per formec!.
- Thus, we have oncl u<)c.<? tha t the. Finding does not. represc nt a failure to
>er form t.hc PWO revi cw, but. represents a failure to document the rivic w.
Supervisory personnel from each of the four maintenance departments onsite (Electrical, Instrument and Control, Primary Mechanical, and Secondary Mechanical) have initiated internal action to ensure that all PlJO's are signed in the Nuclear Super-visor block as required by procedure.
This action provides reasonable assurance that the Finding will not recur.
Based on the steps taken to prevent recurrence, compliance was achieved on September 13, 1978.
Findinq B
Criterion II of Appendix B to 10 CFR 50 states that the quality assurance program shall provide control over activ-ities affecting quality of the identified structures systems and components to an extent consistent with their importance to safety.
Appendix C to the FP&L Topical Quality Assurance R
o t states that that the Quality Assurance Program is committed to ANSI N18.7-1972.
Section 5.3.5 of ANSI N18.7-19 72 states that permission to release equipment or systems for maintenance shall be granted by responsible operating per-sonnel and that the granting of the permission by the Operations Group shall be documented.
Contrary to the above, documentation could not be provided for the period of March 14, 1977, to June 5,
1978, that showed that six Plant Work Orders (PWO Nos.
- 0453, 1623,
- 2204, 2375,
- 7541, 7849) had received the operational release as required.
Resoonse B
As discussed in the inspection report, the standard metho<!
or documenting operations release of equipment or systems for maintenance is by operations approval of the equipment clearance order used to take the equipment or system out of service.
The intent of the clearance program has been to ensure that sources of energy are properly isolated so that. they will not be hazards to personnel and equipment when maintenance is beinc per ormed.
?)ence, the clearance program does not require issuin<:
a clearance to perform maintenance when that maintenance would not s
personnel or equipment to a potentially hazardous
- enerc, i zed i inc.
- source, such as live electrical circuits or, pressurize p'p'n the case where a clearance is not issued for a maintenance activi ty, there.is now no formal i zed mechanism of documen ing operations approval of the maintenance activity.
In such cases, establ ished informal verba1 communications between the main-tenance and opera ions departments has been used to ensure that operations department.
ai>proval is granted prior to star:ing maintena..ce work, but this ap?>rova]
has not been documente.?
xn 11 In order to imi>lement a formal mechanism to mec t in all cas< s, the requirement, to docum< nt o?>< rations approval in a cas~ s, a i>rocram change wi11 have t.o
?><
made.
I t. is not present.?y known what:
form this chang<
wi11 take, nor when the chan<;e can b
implemented.
By Octob< r 31, 1978 we intend to provide an e
1 im >lementation date for what< vc r c)>an<?as ar<
neede,.
to ac corn;>liance.
Technical Specification (TS) Section 6.8.1 require:s that written procedures be established, implemented an('; maintai no
'hat meet or exceed the requirements and recommendation Sections 5.1 and 5.3 of ANSI N18.7-1972.
Sc:ction 5.8 of Administrative Procedure (AP) 0103', In P>>n<
Equipment Clearance Order, requires in part that all clc;arancc;s on nuclear safety-related systems or equipment listed in
.TS 3.0 shall be given proper review before issuance by the Nuclear 4'atch Engineer or Nuclear Plant Supervisor and a
Licensed Senior Reactor Operator.
Their approvals are to bc; indicated by use of a stamp labeled "Nuclear Safety Pelate Contrary to the above, during the period of:4arch 8,
- 1978, to June 26,
- 1978, four clearances on nuclear sa fety re!a c'.:
equipment (Unit 3 Clearance No. 6-102, Unit 4 Clear.-;aces-Nos.
3-27, 6-5 and 6-59) were not properly approved or marked to indicate that they were nuclear safety-relate'.
Response
>o '1c1p prevent recurrence of this F'inc! in;:, Opera'.i n.:
0204. 2, "Sc'>ec!ulc'.
Periodic Tests,
- Checks, Cal ibra:fons Operating Evolutions," will be revisec!
to re(,.uire the
." c.
Plant Supervisor to review, on a daily basis, the clearanc
". itten du: in<: th.; rcv'ous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> perio(! to ver.'-.,
c~.-",
with thc Ac!;..inistrative Procec!ure 0103.4 proc c
~en s.or clc a: ance
- review, stam!>inc~,
an::
s a..:> si(:n-o::
- p. occ c! urc chan:(
wi 1 1 bc reviewec! by the Fl an;
.':uc.'ea."
Co.-."; ".:((>> !.",Acti>!>cr 15, 1978.
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