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)

See also: IR 05000250/1989043

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 INTERNAL: RECIPIENT ID CODE/NAME PD2-2 PD AEOD AEOD/T PAD NRR SHANKMAN,S

NRR/DLPQ/PEB

NRR/DREP/EPB

10 NRR/DRIS/DIR

NUDOCS-ABSTRACT

OGC/HDS2 RES MORISSEAUiD

COPIES LTTR ENCL 1 1 RECIPIENT ID CODE/NAME EDISON,G AEOD/DEIIB

DEDRO NRR/DEST DIR NRR/DOEA DIR 11 NRR/DREP/RPB

10 NRR/PMAS/I LRB 1 2 0 B N,J EG FILE 02 RGN2 FILE 01 COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 2 2 1 1 1 1 1 1 1 1 EXTERNAL: LPDR NSIC NRC PDR 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.20079)TO ELIMINATE YOUR 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 CFR 2.201 the response is attached.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.

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 it annot e erified that he i e C~e c b v t p p is drained and vented.4.Corrective

steps which will be taken to avoid further violations

include: a~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

5.The a~maintenance, as necessary.

date when full compliance

will be achieved: Item 3.a was completed on November 1, 1989.b.c~d~e.Item 3.b was completed on October 5, 1989.Item 3.c was completed on November 9, 1989.Item 4.a will be complete by February 15, 1990.Item 4.b will be complete by February 15, 1990.

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