ML17212B253

Ack Receipt of IE Insp Rept 50-335/81-22 on 810811-0910.No Proprietary Info.Corrective Actions:New Fuel & Spent Fuel Storage Areas Cleaned & Procedure for Receipt & Handling of New Fuel Revised to Ref Crane Checkout Practice

ML17212B253
Person / Time
Site:	Saint Lucie
Issue date:	11/16/1981
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML17212B252	List: IR 05000335/1981022 ML17212B253
References
L-81-479, NUDOCS 8112230316
Download: ML17212B253 (8)

Text

USNRc REGIQt;I:.

Al'!ANTA, GEOI-l"" P.O.BOX 529100 MIAMI, F L 33152 gild+Ct e+FLORIDA POWER&LIGHT COMPANY November 16, 1981 L-81-479 Mr.James P.O'Reilly, Director, Region II Office of Inspection and Enforcement U.S.Nuclear Regulatory Commission 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303

Reference:

St.Lucie Unit 1 Docket No.50-335 IE Inspection Report 81-22 Florida Power&Light Company has reviewed the subject inspection report and a response is attached.There is no proprietary information in the report.Very truly yours, Robert E.Uhrig Vice President Advanced Systems&Technology REU/PLP/pat Attachment CC: Harold F.Reis, Esquire 8ii2>3 3 P5PPP335 t b 8ii215 I PDR ADOCK PD~R Q'8 PEOPLE...SERVING PEOPLE.,-

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Re: St.Luci e Uni t 1 Docket No.50-335.Inspection Report 81-22 A.Fi ndi ng ATTACHMENT 1.Operating Procedure 1610020, Rev.6, Receipt and Handling of New Fuel, requires in paragraph 4.10 that"Prior to unloading the shipping containers, the new fuel and spent fuel storage areas shall be clean and any dirt producing operations shall be"stopped".

On August 20, 1981, new fuel was being unloaded and stored in vertical racks on the new fuel storage floor (42 ft level).The area was not clean.Debris included many small wooden chips, rubber bands, several pieces of plastic, and masking tape.Response a.FPL concur s with the finding.b.This problem was caused by per sonnel oversight.

c.As corrective action the area was cleaned.d.To prevent further problems, the item was discussed with personnel invol ved.e.Ful 1 compliance was achieved prior to resumption of fuel receipt.Finding 2.Operating Procedure 1630028, Rev.0, New Fuel Handling l;rane Operation, requires in paragraph 7.2 that prior to refueling or any fuel handling evolution involving the new fuel handling crane, section 8.1.1 throu'gh 8.4.4 shall be completed.

Section 8.1 includes the acceptance criteria for pr e-operational checkout.The new tuel handling crane had not been checked out in accordance with OP 1630028 prior to use on September 9, 1981.The procedure was over-looked.

A contributing factor was that'P 1610020 referred to in paragraph A.l above did not inc'lude OP 1630028 as a pre-requisite.

Response a.FPL concurs with the finding.b.The problem was caused by personnel oversight.

c.As corrective action the check-out of the crane was conducted in accordance with the correct procedure.

d.The"Receipt and Handling of New Fuel" procedure has been revised to reference the crane checkout procedure.

e.Full compliance'as achieved September'25, 1981.

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~~Finding 3.Operating'Procedure 0010122, Rev.2, In-plant Equipment Clearance Orders requires a clearance when inadvertent operation of equipment could create a hazard to personnel or equipment.

Switches and valves are positioned and tagged prior to a clearance being granted.Clearances are granted by the'latch Engineer.On September 9, 1981, a person isolated the discharge pressure Gage from an operating, safety-related Auxiliary Feed pump wi th a single valve isolation and commenced removing the gage with no clearance or other apparent permission from the Nuclear>latch Engineer.At the time, the pump discharge pressure was over 1000 psig and the pump was being used to feed the steam generators for reactor decay heat removal.Response a.FPL concurs with the finding.b.This problem was caused by personnel oversight.

c.No immediate action was taken.The job was complete before action could be taken.d.The personnel involved were instructed to follow appropriate procedures.

B.e.Full compliance was achieved on September 10, 1981.Finding 10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality shall be prescribed and accomplished in accordance with documented instruction or procedures appropriate to the circumstances and shall include appropriate acceptance criteria.Florida Power and Light Company guality Procedure 11.2, Test Control-Operation, Section 5.3.1, states that retesti ng procedures shall include a documented functional check of the equipment operability.

Contrary to the above, a test procedure was neither written nor performed to confirm satisfactory operation of the Emergency Notification System (ENS)telephone upon completion of plant change modification 112-80.Uue to an error in hookup, the ENS was powered from a non-vital bus so that power would have been lost duri ng a station blackout.Response'a~FPL does not concur with this finding for the following reasons: 1.The criteria-cited in the finding is 10 CFR 50, Appendix B.Criterion V.This cr iteria is applicable to those systems and items which are safety related as determined and defined in the FPL guality Assurance Manual.This installation was determined as not safety related and not affecting the safety of the nuclear plant.Having made that determination, Appendix B to 10 CFR 50 is not applicable with regard to testing.

2.Activities for installation and testing are required to be commensurate with its importance to safety.FPL does not consider the ENS to have any plant safety significance.

3.It should also be noted that FPL letter L-80-288 dated 9/2/80 stated that such testing would not be conducted following the plant change;FPL was not notified that this was not satisfactory.

4.The ENS circuit has been properly connected such that it will be powered from the Emergency Power Sources with a loss of offsite power.FPL intended to and did test this function during the 1981 refueling outage as part of the loss of off-site power test as requested by the NRC in their letter requiring emergency power for the ENS.

STATE OF FLOHl:DA))COUNTY OF DADE)st Robert E.Uhrig, being first duly sworn, deposes and says: That he is Vice President of Florida Power Light Company, the herein;That he has executed the foregoing document;that the state-ments made in this said document are true and correct to the best of his knowledge, information, and belief, and that he is authorized to execute the document on behalf of said Robert E.Uhrig Subscr'bed and sworn to before me th's day of 19+/;MOORY,PUBLIC,>-,, Sta'te of Florida and for the County of Dade, P b!'c State of Fiorida at Largo 0 r 30 1983 Qy Comrrrhsiort Expiraa Octobor pires th Ma rd Bo d'Agency e'