ML17347A911
| ML17347A911 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 01/17/1989 |
| From: | Conway W FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| L-89-19, NUDOCS 8901260054 | |
| Download: ML17347A911 (4) | |
Text
J~(CCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS) j SION NBR:8901260054 DOC.DATE: 89/01/17 NOTARIZED: NO DOCKET iL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C,05000251 AUTH.NAME AUTHOR AFFILIATION CONWAY,W.F.
Florida Power
& Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
I
SUBJECT:
Responds to violations noted in Insp Repts 50-250/88-34 50-251/88-34.
DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR'NCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES RECIPIENT ID CODE/NAME PD2-.2 PD INTERNAL: AEOD DEDRO NRR/DEST DIR NRR/DLPQ/QAB 10 NRR/DREP/EPB 10 NRR/DRIS DIR 9A NUDOCS-ABSTRACT OGC/HDS2.
RGN2 FILE 01 EXTERNAL: LPDR NSIC COPIES LTTR ENCL 1
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RECIPIENT ID CODE/NAME EDISON,G AEOD/DEIIB NRR SHANKMAN,S NRR/DLPQ/PEB 11 NRR/DOEA DIR 11 NRR/DREP/RPB 10 NRR/PMAS/ILRB12 ERMANIJ GFL02 NRC PDR RESL MARTIN,D COPIES LTTR ENCL 1
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NOTE 'IO ALL RIDS" PLEASE HELP US 'XO REDUCE HASTE!
CONZACT 'LHE DOCUMEPZ COZEL DESK ROOM Pl-37 (EZZ. 20079)
TO. EIZMZNATE KNJR NAME FBGH DISTlKBUTIGN LISTS POR DOCGMZRZS KNJ DOIN'T NEEDs TOTAL NUMBER OF COPIES REQUIRED:'LTTR 24 ENCL 24
P.O. Box14000, Juno Beach, FL 33408-0420 JANUARY 1 7 1989 L-89-19 U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D.
C.
20555 Gentlemen:
Re:
Turkey Point Units 3 and 4
Docket Nos.
50-250 and 50-251 Reply to Notice of.Violation Ins ection Re ort 88-34 Florida Power
& Li'ght Company has 'reviewed the subject inspection report and a response is attached.
Very truly yours, W. F.
Conw y'enior Vice President Nuclear WFC/RHF/gp Attachment cc:
Malcolm L. Ernst, Acting Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant Pg0g~g00~4 Sc]0i17 pgp ggoCK 05000250 O
ATTACHMENT RE:
TURKEY POINT UNITS 3 AND 4 DOCKET NOS ~ 50-250 AND 50-251 IE INSPECTION REPORT 250-88-34
& 251-88-34 FINDING 10 CFR 50, Appendix 3, Criterion V, and the licensee s accepted Quality Assurance Program FPL TQAR 1-76A, Rev.
11 of May 10, 1988, paragraph 5.1 in part state:
"Activities affecting quality shall be prescribed by documented instructions, procedures or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings...."
Florida Power and Light Administrative Procedure O-ADM-209, Equipment Tagging, dated June 14, 1988, provides the instructional guidance for establishing and maintaining an accurate,
- complete, and effective plant equipment identification program.
Paragraph 5.2.1 of this procedure requires that unidentified equipment shall be temporarily identified by use of an Equipment Temporary Identification (ETI) Tag.
Additionally, Enclosure (5) of this procedure requires that the Operations/Maintenance Coordinator shall have the unidentified equipment tagged with a metal tag and shall order a permanent fiberglass tag within.24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of notification of the problem.
ontrary to the above, Procedure 0-ADM-209 requirements were not adhered to, in
- that, on November 1,
- 1988, NRC inspectors identified several Component Cooling Water System components which were not identified and further investigation determined that operations personnel were not utilizing ETI tags for temporary, identification, nor were they tagging equipment with metal tags within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
RESPONSE
1)
Florida Power and Light accepts the violation.
2)
The reason for the violation was an inadequate procedure, in that 0-ADM-209 imposed requirements which were not practicable based on the overall status of implementation of the equipment tagging program.
The construction and maintenance work controls required to implement the equipment tagging program were not adequate and the increased burden on the operations program led to inability to implement the procedure requirements.
Procedure 0-ADM-209 was intended to assure maintenance of equipment identifying tags, however it was being used to implement the installation of equipment
- tags, as well as maintain existing tags.
A contributing cause was personnel error in that the personnel responsible for implementing the program were aware of the procedure weaknesses and did not initiate changes to correct the procedure and/or practices.
3)
The corrective steps which have been taken and the results achieved are:
a)
Procedure 0-ADM-209 was reviewed to identify areas which need revision to assure the requirements can be implemented as described.
Several areas of potential improvement have been identified, and a revision to the procedure has been submitted for review and approval.
b)
Work control programs which govern activities onsite were reviewed to identify activities which significantly impact the maintenance of the overall equipment identification tagging program.
These programs are being revised or otherwise modified to address the implementation of the program.
c)
The individual responsible for the implementation of the operations equipment tagg'ing program has been counseled regarding the importance of implementing procedures as written, or obtaining resolution of requirements which are not practicable.
4)
The corrective steps which will be taken to avoid future violations are:
a)
The revisions to procedure 0-ADM-209 will be implemented following review and approval of the procedure changes.
b)
The training materials for new and continuing employee training programs are being reviewed to assure that the appropriate awareness of the equipment tagging program is included.
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c)
Modifications az'e being 'made to the construction aqd maintenance work control. programs to improve the implementation of the equipment tagging program and assure proper tag maintenance.
5)
The date when full compliance will be achieved:
a)
The revision to 0-ADM-209 will be completed by January 31, 1989.
b)
The review of the training program to assure inclusion of the equipment tagging awareness training materials will be completed by February 28, 1989.
c)
Modifications to site work control programs will be completed by February 28, 1989.