View source for L-90-392, Responds to Violations Noted in Insp Repts 50-335/90-23 & 50-389/90-23.Corrective Actions:Instructions Reviewed W/Maint Personnel to Ensure Compliance & Work Control Procedure Revised

{{Adams
| number = ML20062F997
| issue date = 11/21/1990
| title = Responds to Violations Noted in Insp Repts 50-335/90-23 & 50-389/90-23.Corrective Actions:Instructions Reviewed W/Maint Personnel to Ensure Compliance & Work Control Procedure Revised
| author name = Goldberg J
| author affiliation = FLORIDA POWER &amp; LIGHT CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000335, 05000389
| license number = 
| contact person = 
| document report number = L-90-392, NUDOCS 9011280316
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 4
}}

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P.O. 8:n 1400W,Jeno Beach, FL 3MOS-W20 EE November 21, 1990 L-90-392 10 CFR 2.201
              \/ . S . Nuclear Regulatory Commission Attn:      Document Control Desk Washington, D. C. 20555 Gentlemen Ret    St. Lucie Unit Nos. 1 and 2 Docket Nos. 50-335 & 50-389 Response to Notice of Violation InsDection ReDort 90-23
                                                                                                              )
Florida Power and Light company has reviewed the subject inspection                           '
report and, pursuant to 10 CFR 2.201, the response is attached.
Very truly yours, Y*               %
J. H. Goldberg President Nuclear Division JHG/GRM/kw Attachmeat cc:   Stewar". D. Ebneter, Regional Administrator, USNRC Region II Senior P,esident Inspector, USNRC, St. Lucie Plant DAS/PSL #280 p
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o, ATTACKMENT
    ,                          RESPONSE TO NOTICE OF VIOLATION FINDINGt                                                              I l
10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, as implemented by approved FPL Topical Quality Assurance Report TQAR 1-76A Rev. 15, TQR 5.0, Instructions, Procedures, and Drawings, and further implemented by TQAR Appendix C commitment to ANSI N18-7, 1976, paragraph 5.2.7, Maintenance and Modifications, require that maintenance or modifications which may effect functioning of safety-related structures, systems, or components shall be performed in a manner to ensure quality at least equivalent to that specified in original design bases and requirements,      materials     specifications,    and    inspection requirements.
10 CFR 50, Appendix B, Criterion VIII, Identification and Control of Materials, Parts and Components, as implemented by approved FPL Topical   Quality    Assurance   Report  1-76A,  Rev   15,  TQR  8.0, Identification and Control of Materials, Parts, and Components, requires that measures be designed to provent the use of incorrect materials, parts or components.       This is further implemented on site by procedure QI-PR/PSL-8.1, Rev 11, Identification Control of Materials, Parts, and Components.
Contrary to the above, in the two safety-related repair examples cited below, the licensee failed to control material and ensure quality at least equivalent to that specified in original design bases and requirements, materials specifications, and inspection requirements in that:
: 1. The equipment manual for the Reactor Protection System channel "C"  cabinet failed to specify approved replacement wire
)                material. As a result, on August 21, 1990, non-authorizp.
wire material was installed in the Unit 2 cabinet during the replacement of the reactor coolant pump mode selector switch.
The licensee did not establish qualification by other means.
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: 2. On August 24,1990, a non-authorized sealant was used on a 1A Component Cooling Water (CCW) pump shaf t mechanical seal leak.
The unapproved sealant was applied to the joint after an "O" ring at the seal retaining collar was compressed, causing a minor leak at the collar-to-pump casing joint.         "O" ring replacement sculd have required partial pump disassembly.
In each instance, subsequent engineering evaluation was requested after repair completion and NRC inquiry.           These evaluations concluded that the repairs were acceptable, but this was not known at the time of the repair. The CCW system was in operation during the evaluation but the RPS channel remained out of service until authorized material was obtained and installed.
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                            . ATTACHMENT                                                                                I Page 2 of 3 RESPONSE:                                                                                 *
: 1. Florida Power and Light Company                          (FPL)   concurs with the violation.                                                                          ,
: 2. The reason for the violation was personnel error coupled with inadequate procedure.
: 3. The following actions were taken to correct the specific items of noncompliance:
: a. The improper wire was replaced with vendor recommended wire.
: b. The sealant used on the component Cooling Water Pump was evaluated by FPL Engineering and determined to be acceptable for use.
: 4. The   following            corrective         act. ions   have   been  or will  be implemented:
: a. Interim Measures:
Until the procedure changes can be made and training conducted               the    following       interim    measures  will  be
!                                        implemented:
(1)   The Maintenance Superintendent has issued a letter describing the requirements for material control.
All parts or material used in safety-related component repairs will be verified to conform to i
requiremente (i.e. . Technical Manuals, drawings, i
procedures,. procurement specifications, or stores material identification sheets) .                      If material can not be verified work will be stopped until a written               F.tgineering disposition is received.
(2)   These              instructions .will         be   reviewed  with  all Maintenance Personnel tg ensure compliance.
: b. Program Corrections:
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(1)   The work control procedure will be revised to
!                                              provide the detail to properly implement the plant quality instructions.
(2)   Our programs to control chemicals and consumable materials                will     be     reviewed and revised as necessary.
(3)   Training . vill be held for all Maintenance Personnel on the revised material control procedures.

ATTACHMENT Page 3 of 3                                                           '
: 5. Ccrrective action status.
: a. Corrective actions 3.a. and 3.b. were completed before the end of the inspection period.
: b. Corrective action 4.a. will be complete by November 30, 1990.
: c. Corrective action 4.b. (1) will be completed by December
* 31, 1990,
: d. Corrective Action 4.b. (2) will be complete by January 31, ;
1991.
: e. Corrective Action 4.b.(3) will be complete by February 28, 1990.
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