ML17347B436

Responds to Violations Noted in Insp Repts 50-250/89-43 & 50-251/89-43.Corrective Actions:Supervisors & Chiefs in Electrical Dept Instructed to Clearly Communicate Job Scope & Clearance Requirements to Control Room Personnel

ML17347B436
Person / Time
Site:	Turkey Point
Issue date:	11/22/1989
From:	Goldberg J FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-89-423, NUDOCS 8912050052
Download: ML17347B436 (9)

Text

ACCELERATED DISTBXBUTION DEMONSTPJ!!,TION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

CESSION NBR:8912050052 DOC.DATE: 89/11/22 NOTARIZED: NO DOCKET g FACIL: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 GOLDBERG,J.H. Florida Power & Light Co.

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

SUBJECT:

Responds to violations noted in Insp Repts 50-250/89-43 &

50-251/89-43.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR 1 ENCL 1 SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 PD 1 1 EDISON,G 1 1 INTERNAL: AEOD AEOD/DEIIB 1 1 AEOD/TPAD DEDRO 1 1 NRR SHANKMAN,S NRR/DEST DIR 1 1 NRR/DLPQ/PEB NRR/DOEA DIR 11 1 1 NRR/DREP/EPB 10 NRR/DREP/RPB 10 2 2 NRR/DRIS/DIR I NRR/PMAS/ LRB1 2 1 1 NUDOCS-ABSTRACT 0 B N,J 1 1 OGC/HDS2 EG FILE 02 1 1 RES MORISSEAUiD RGN2 FILE 01 1 1 EXTERNAL: LPDR NRC PDR 1 1 NSIC NOTE TO ALL "RIDS" RECIPIENTS:

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

TAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24

II P.O. Box 14000, Juno Beach, FL 33408-0420 I=PL NOVEMBER 2 2 1989 L-89-423 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 89-43 Florida Power 6 Light Company (FPL) has reviewed the subject e inspection report and pursuant to 10 attached.

CFR 2.201 the response is Very truly yours, t

r

~i -l~(4j.'.g J. H. Goldberg Executive Vice President JGH/JRH/rh Attachment cc: Stewart D. Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant

~go f

0 ATTACHMENT RE: Turkey Point Units 3 and 4 Docket Numbers 50-250 and 50-251 NRC Inspection Report 89-43 FINDING TS 6.8.1 requires. that written procedures and administrative. policies shall be established, implemented and maintained that meet or exceed the requirements and recommendations of Appendix A of USNRC Regulatory Guide 1.33 and Sections 5.1 and 5.3 of ANSI N18.7-1972.

NRC Regulatory Guide 1.33, Appendix A, item 1, specifies that procedures should be written for equipment c'ontrol .

Section 5.1.2 of ANSI N18.7-1972 requires that procedures be followed.

Administrative Procedure 0103.4, In-Plant Equipment Clearance Orders, dated July 27, 1989, specified that In-Plant Equipment Clearance Orders shall be re-quired for the safety and protection of plant personnel and equipment.

Contrary to the above, clearance number 4-89-09-069 was inadequate on September 20, 1989, in that MOV-4-1420 was not fully isolated. This allowed the line to remain pressurized which caused the valve stem to be ejected resulting in ser-ious injury to a plant electrician.

RESPONSE

1. FPL concurs with the finding.

2. The reason for the violation was inadequate training for the task at hand .

When the job scope on Motor Operated Valve (MOV)-4-1420 expanded from re-placing the motor operator to replacing the actuator stem drive sleeve lock-nut., clearance requirements were not re-evaluated by Electrical Department personnel. It was assumed that because the initial clearance identified the sub)ect valve as being "isolated" the system pressure had been relieved .

The Electrical Maintenance Department had received valve actuator training approximately 18 months prior to the accident. The Chief Electricians had the mechanical section of the training but remembered precautions concern-ing system pressure only after the accident occurred. In addition, the Chief Electrician and electrical crew had no practical experience in work-ing with piping systems.

3. Corrective steps which have been taken and the results achieved include:

a. The accounts of this event were described in Plant Safety Meetings.

The root cause and contributing causes for the accident were discuss-ed in detail.

b. Supervisors and Chiefs within the Electrical Department have been in-structed to clearly communicate their job scope and clearance require-ments to Control Room personnel. Additionally, the need to re-evalu-ate clearance requirements each time a job scope changes and the need for strict adherence to the requirement for a clearance walkdown prior to the commencement of maintenance activities has been re-emphasized.

This was achieved through discussions at shop meetings and by memoran-dum to Electrical Department personnel.

C ~ General Maintenance Elect'rical (GME) procedures O-GME-0102.9, "Motor Operated Valve Operator, Inspection and Overhaul (SMB-OOO)," and 0-GME-0102.10, "Motor Operated Valve Operator, Inspection and Overhaul (SMB-00 and SMB-500)" have been converted from General Maintenance Mechani-cal (GMM) procedures and approved by the Plant Manager-Nuclear. A Pre-caution has been added to these procedures which states, "Do not remove stem nut locknut or upper bearing housing if a thrust load is on the actuator or if the valve is under pressure and not fully open, as per-sonnel injury may result. Once the stem nut locknut is removed, stem movement can occur. Stem blocking should be used when removing stem nut locknut and shall be used when it cannot be verified that the pipe is drained and vented ." In addition, a Caution has been added which states, "Do not remove locking nut with unit under load or with valve under pressure. Stem blocking should be used and shall be used when i

it c annot b e v erified that t he p p e is drained and vented.

e 4. Corrective steps which a ~

will be taken to avoid further violations include:

Procedure O-GMM-0102.8, "Motor Operated Valve Operator, Inspection and Overhaul (SMB-0 through SMB-4)," will be converted to a GME procedure after it has been revised to include Precaution and Caution statements similar to those added to procedures O-GME-0102.9 and O-GME-0102.10.

b. Electrical Department personnel assigned to work on valve actuators will receive training that, as a minimum, will include the following:

Methods to render a pressurized valve actuator safe for disassem-bly.

Methods for testing to verify that a valve actuator has been made safe to work.

Examples of a generic clearance needed to repair a valve under both pressurized and depressurized conditions.

Detailed discussion of Safe Work Practice Rules regarding clear-ance testing to verify and ensure a proper clearance'ntil this training is completed, Mechanical Maintenance personnel will support Electrical Maintenance personnel during valve actuator

maintenance, as necessary.

5. The date when full compliance will be achieved:

a ~ Item 3.a was completed on November 1, 1989.

b. Item 3.b was completed on October 5, 1989.

c~ Item 3.c was completed on November 9, 1989.

d ~ Item 4.a will be complete by February 15, 1990.

e. Item 4.b will be complete by February 15, 1990.

~