ML17223A529

Responds to Violations Noted in Insp Repts 50-335/89-29 & 50-389/89-29.Corrective Actions:Util Shifted Responsibility for All Limitorque Maint to One Dept & Counseled Personnel in Adherence to Procedures

ML17223A529
Person / Time
Site:	Saint Lucie
Issue date:	02/22/1990
From:	Goldberg J FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-90-71, NUDOCS 9003020142
Download: ML17223A529 (6)

Text

AO;ELBRATED DISTRIBUTION DEMONS'.TION SYSTEM

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REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

CESSION NBR: 9003020142 DOC. DATE: 90/02/22 NOTARIZED: NO DOCKET FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power

~ & Light Co.

~ 05000335 50-389 St. Lucie Plant, Unit 2, Florida Power & Light Co. 05000389 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 Rept 50-335/89-29 &

50-389/89-29.*

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

TITLE: General (50 Dkt)-Insp Rept/Notice of Vi ation Response NOTES:

RECIPXENT

COPIES RECIPIENT COPXES XD CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2'-2 PD 1 1 NORRXS,J 1 1 D.

RNAL: ACRS 2 2 AEOD 1 1 AEOD/DEIIB 1 1 AEOD/TPAD 1 1 DEDRO 1 1 NRR SHANKMAN,S 1 1 NRR/DLPQ/LPEB10 '1 1 NRR/DOEA DIR 11, 1 1 NRR/DREP/PEPB9D 1 1 NRR/DREP/PRPB11 2 2 NRR/DRIS/DXR 1 1 NRR/DST/DIR 8E2 1 1 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 BB (J 1 1 OGC/HDS2 1 1 REG F L 02 1 1 RES MORISSEAUiD 1 1 RGN FXLE 01 1 1 EXTERNAL: LPDR 1 NRC PDR NSIC 1 1

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NOTE TO ALL "RIDS" RECIPIENIS:

PLEASE HELP US TO REDUCE WASTETH CONTACI'HE.DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISIRIBUTION LISIS FOR DOCUMENTS YOU DON'T NEEDI TOTAL NUMBER OF COPIES REQUIRED: LTTR 26 ENCL 26

'P.O. Box14000,Juno Beach,FL 33408.0420 PPt FEBRUII 2 2 QgsO L-90-71 10 CFR 2.201 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:

Re: St. Lucie Units 1 and 2

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Docket Nos. 50-335 and 50-389

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Inspection Report 89-29 Res onse to Notice of Violation

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Florida Power & Light Company has reviewed the subject inspection report, and pursuant to the provisions of 10 CFR 2.201, the response is attached.

Very truly yours, J. H. Goldberg Executive Vice President Nuclear Energy JHG/GRM/slh Attachment cc: Stewart D. Ebneter, Regional Administrator, USNRC Region Senior Resident Inspector, USNRC, St. Lucie Plant II 900g0~0142 900'222 0-<<) ~003+@

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ATTACHMENT RESPONSE TO NOTICE OF VIOLATION VIOLATION Title 10 Code of Federal Regulations, Part 50, Appendix B Criterion V requires, in part, that, activities affecting quality shall be prescribed by documented instructions or procedures of a type appropriate to the circumstances. Instructions, and procedures shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Florida Power and Light procedure PR/PSL-1, Revision 13, "Control of Purchased Material, Equipment,

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and Services," paragraph 5.10. requires the St. Lucie Plant Site

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Coordinator to, approve material used on safety related work

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performed by contractors to ensure proper quality level, and to

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provide adequate supervision of the work. Florida Power and Light

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Administrative Procedure No. 0010432, Revision 39, "Nuclear Plant Work Orders," paragraph 8.6 requires, in part, "When parts or materials are used, attach all ROS forms and/or QC tags to the NPWO package....."

Contrary to the above, the following was found as listed below:

Unit 2 Limitorque actuators MV-09-09, and MV-09-10 failed to operate as designed when called upon to do so September 23, 1989, following a manual reactor trip and the subsequent receipt of an Auxiliary Feedwater Actuation System (AFAS) signal. Valves MV-09-09 and MV-09-10 are at the discharge of the Unit 2 motor driven auxiliary feedwater pumps, 2a and 2b, respectively.

0 MV-09-09 failed to operate as designed because of severe galling between the upper stem and stem nut, due to inadequate lubrication. The valve went full-open following receipt of the AFAS signal, however, operators could not close the valve remotely or locally. General Maintenance Procedure Number 2-M-00180, revision 5 PM File 10500 covers the 18 month inspection and lubrication of Limitorque actuators. Valve stem lubrication is covered in section 4.8 of the procedure, and the instructions are to "Clean the valve stem with kerosene and rags; apply a coat of anti seize lubricant."

These instructions are inadequate because they do not ensure an even coating of lubricant will be applied to the entire valve stem, including the portion of the valve stem in contact with the actuator stem nut.

t ATTACHMENT Page 2 of 2 0 MV-09-10 failed to operate as designed due to a worn limit switch pinion drive gear. The result was the valve could only move in the closed direction, after initially being o'pened by the AFAS signal. The root cause was due to the installation of an unauthorized handwheel cover gasket which was 0.116"

.thick, resulting in improper meshing of the limit switch pinion and drive sleeve bevel gears. The proper gasket thickness should- have been 0.015". The licensee was unable to determine when -the unauthorized gasket was installed, or account for the use of the gasket material it was cut from, in violation of the requirements to account for material not and parts used on safety related work. The licensee did provide adequate and complete work procedures for proper Limitorque disassembly/assembly, and the vendor technical manuals in use at the time were not updated. The most recent vendor technical manual for Limitorque actuators, SMBI-82C was available in 1982. The SMBI-82C technical manual contains instructions for determining the proper thickness of the handwheel cover gasket; the SMBI-170, issued in 1979, and in use during the time the unauthorized handwheel gasket was installed (between 1984 and 1989) did not contain instructions for determining proper handwheel gasket thickness.

RESPONSE TO VIOLATION; Florida Power 6 Light concurs with the violation.

2. -The reason for the violation was lack of detail in "Limitorque" maintenance procedures and failure to follow procedures.

3. Florida Power & Light has shifted responsibility for all "Limitorque" maintenance to one department at the St. Lucie Plant and counselled personnel in adherence to procedures.

A technical review of all contractor implemented "Plant Work Orders" was performed.

'aintenance 4 ~ instructions for all "Limitorque" actuated valves have been written or revised to incorporate manufacturers instructions and industry guidelines. Technical support engineers perform a technical, review of contractor related "Plant Work Orders" to, ensure compliance to design specifications.

Compliance has been achieved as of February 16, 1990.