ML17347B080

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Notice of Violation from Insp on 881128-1216.Violations Noted:Longstanding Deficiencies in Equipment Identification Not Promptly Corrected,Absence of Adequate Procedural Requirements & Failure to Comply W/Procedure Requirements
ML17347B080
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 03/04/1989
From: Gibson A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML17347B078 List:
References
50-250-88-32, 50-251-88-32, NUDOCS 8904180141
Download: ML17347B080 (8)


Text

ENCLOSURE 1

NOTICE OF VIOLATION Flori da Power and Light Company Turkey Point Docket Nos. 50-250 and 50-251 License Nos.

DPR-31 and DPR-41 During the Nuclear Regulatory Coranission (NRC) inspection conducted on November 28 - December 16, 1988, violations of NRC requirements were identi-fied.

In accordance,with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"

10 CFR Part 2, Appendix C (1989), the violations are listed below:

A.

10 CFR 50, Appendix B, Criterion XVI, and the licensee's accepted guality Assurance

Program, FPL TAHAR 1-76A, Section
16. 1, require that deficiencies be promptly corrected; Contrary to the
above, longstanding deficiencies in equipment 'identifi-cation have not been promptly corrected.

Th'e licensee has acknowledged equipment identification deficiencies and has had a

program in place for their correction for several years.

.Such a program was refer red to in the 1987 Systematic Assessment of Licensee Performance and in the Turkey Point Performance Enhancement

Program, Project 2, Task 4

(reference September 30, 1987 letter from Florida Power and Light Company to the NRC).

As evidence of failure of prompt correction, in December 1988 the following identification labeling deficiencies were identified as a result of NRC inspection:

(1)

Unit 2 Residual Heat Removal suction isolation valves from the Reactor Coolant cold leg were observed with the following identifi-cation deficiencies:

Valve ink marked 750, but identification tagged 751 Valve ink marked 751 with no identification tag (ink-marked numbers were correct;

however, the acceptable method for identification is by tagging.)

(2)

An unlabeled pressure indicator (PI) was mistakenly assumed to be PI 1545 (Emergency Containment Cooler CCW Outlet Pressure) by a planner

and, as result a deficient condition for.PI 1545 was not recogni,zed and corrected when initially reported.

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

B.

10 CFR 50, Appendix B, Criterion V, and the licensee's approved guality Assurance

Program, FPL TAHAR 1-76A, Section 5, require that activi ties affecting quality shall be prescribed by and accomplished in accordance with appropriate instructions or procedures.

Technical Specification (TS) 6.4. 1 requires a

program for periodic retraining of Health Physics svoocsaiOi aso4oe PDR ADOCK 05000250 6

PNU

Florida Power and Light Company Turkey Point 2

Docket Nos.

50-250 and 50-251 License Nos.

DPR-31 and DPR-41 technicians.

TS 6.8. 1, through reference to Regulatory Guide 1.33, requires procedures for breathing air quality testing be established and implemented.

Contrary to the

above, the licensee did not have adequate procedural requirements or did not comply with requirements from procedures in the following examples:

(1)

A work order issued to repair pressure indicator 1545 (Emergency Containment Cooler.CCW Outlet Pressure),

which was reading off scale

high, was coded out (cancelled) without referring the condition back to the originator as required by'rocedure O-ADM-701.

(2)

During November and December 1988 data entry technicians were not incl'uding all of the journeyman 's work o'rder wor k write-up entries in the work order computerized data base as required by Procedure-O-ADM-701.

(3)

A procedure for diesel generator maintenance contained erroneous requirements.

Procedure O-PMM-022.3 (10/24/88) was deficient in that it, contained requirements regarding chromate water which were no longer applicable, as well as major modifications (power pack

assembly, cylinder liner installation and measurement, cylinder head installation, and lube cooler) which will not be required for several subsequent 18 month intervals.

(4)

There were no procedural requirements for periodic retraining of contract Health Physics technicians and said retraining was not being per formed.

(5)

Breathing air quality testing was not procedurally addressed..

/

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

C.

10 CFR 50, Appendix B, Criterion V, and the licensee's approved guality Assurance

Program, FPL TAHAR 1-76A, Section 5, require that activities affecting quality be accomplished in accordance with the documented requi rements of the applicable procedures and instructions.

Contrary to the

above, receipt inspection's prescribed and documented on Receipt Inspection Reports (RIRs) R87-7772 and R86-3842 were not performed as required by the RIRs.

A reinspection of the parts included on these

Florida Power and Light Company Turkey Point 3

Docket Nos.

50-250 and 50-251 License Nos.

DPR-31 and DPR RIRs, which was conducted at NRC request on 12/16/88, found that cleanliness and physical condition was not acceptable though the inspecti'on record indicated that they were.

Unacceptable results from reinspection were documented in= General Inspection Report G-88-159.

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

D.

10 CFR 50, Appendix B, Criterion XVII, and the licensee's approved guality Assurance

Program, FPL TAHAR 1-76A, Section 17, require storage of quality assurance records to assure they are protected from deterioration and are readily retrievable.

Contrary to the above, the following examples of quality assurance records were not stored such that they would be protected from deterioration or would be readily retrievable in accordance with licensee requirements:

(1)

Temperature and humidity daily records for the Class B storage warehouse were not. maintained as gA records as required by Corporate gA Manual Procedures gP 13.1 and

17. 1 (2)

Procedure, O-HPA-003, Control of Health Physics Records revision dated July 5,

1988, section
5. 1.5 requires completed quality assurance records be turned over to the health physics records custodian to file in an approved guality Assurance cabinet for storage until the records are stored in the plant quality assurance record storage area.

During the week ended December 2,

1988, it was found that qualifi-cation records for contract Health Physics personnel were not stored in an approved cabinet, filed by a health physics records custodian, or readily retrievable.

Further, these health physics quality.

assurance records had not 'bee'n transmitted to the plant quality assurance

. record storage area.

They had been stored by several individuals at various locations.

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

Pursuant to the provisions of 10 CFR 2.201, Florida Power and Light Company is

~ hereby required to submit a written statement or explanation to the Nuclear Regulatory Commission, ATTN:

Document Control

Desk, Washington, DC
20555, with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector, Turkey Point, within 30 days of the date of the letter transmitting this Notice.

This reply should be clearly marked as a "Reply to a Notice of Violation" and should include [for each violationj:

(I) admission or denial of the violation, (2) the reason for the violation if admitted, (3) the corrective steps which have been taken and the results

achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved.

Where good cause is

shown, consideration will be given to extending the response time.

If an adequate

Florida Power and Light Company 4

Turkey Point Docket Nos.

50-250 and 50-251 License Nos.

DPR-31 and DPR-41 reply is not received within the time specified in. this Notice, an order may be issued to show cause why.the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.

FOR THE NUCLEAR EGULATORY COMMISSION Albert F. Gibson, Director Division of Reactor Safety Dated at Atlanta, Georgia this ~

day of March 1989

NRC MAINTENANCE INSPECTION OF TURKEY POINT UNITS 3 5 4 INSPECTION REPORT NOS. 50-250,251/88-32 ON-SITE INSPECTION, DATES ll/28/88 - 12/2/88 and 12/12/88 - 12/16/88 EXIT MEETING 1/12/89