ML17347B266

Responds to Violations Noted in Insp Repts 50-250/89-24 & 50-251/89-24.Corrective Actions:New Backfit Const Procedure Developed to Improve Control of Process Sheets & Installation Lists for Lifted Leads

ML17347B266
Person / Time
Site:	Turkey Point
Issue date:	08/14/1989
From:	Woody C FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-89-283, NUDOCS 8908220220
Download: ML17347B266 (10)

Text

REGULATORY'NFORMATION DISTRIBUTION SYSTEM (RIDS)

-A ION NBR: 8908220220 DOC DATE: 89/08/14

~ NOTARIZED: NO DOCKET I L: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

'XUTH'Ã2QIE . AUTHOR AFFILIATION

=-=MOODY,.C.O. Florida Power & Light Co.

gtECIP.NAME RECIPIENT AFFILIATION Document Contro1 Branch (Document Control Desk)

';SUBJECT.: Responds

~~, 'NOTES:

50-251/89-24 to violations noted in Insp Repts 50-250/89-24

".ZE01D

'".DZSTRZEDTZON:":CODE:

• COPIES RECEZVED;LTR" (50 .Dkt)-Insp Rept/Notice of Vio ation". Response; ENCL j ':~SZEE-'ITLE:=.General RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL h PD2-2 PD 1 1 EDISON,G 1 1 INTERNAL AE0D 1 1 AEOD/DEIIB 1 1 AEOD/TPAD 1 1 DEDRO 1 1 LOIS, ERASMIA 1 1 NRR SHANKMAN,S 1 1 NRR/DEST DIR 1 1 NRR/DLPQ/PEB 1 1 NRR/DOEA DIR 11 1 1 NRR/DREP/EPB 10 1 1 NRR/DREP/RPB 10 2 2 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 0 ERMAN, J 1 1 OGC/HDS2 1 1 G ILE 02 1 1 RES MORISSEAU,D 1 1 RG PZLE 01 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24

P.O. Box14000, Juno Beach, FL 33408-0420 Ig555II 14 )989.

L-89-283 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 89-24 Florida Power E Light Company (FPL) has reviewed the subject

~

inspection report and pursuant to 10 CFR 2.201 the response is

~ ~

attached.

Very truly yours, C. O. Woody Senior Vice President

'cting Nuclear COW/JRH/cm Attachment '

cc: Stewart D. Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant

) qQ 8 9QPq2~+()QgC

~

pDI ICY l.) pQ I.P.

an FPL Group company ~go I

5~

.'>RE:,. Turkey-Point Units. 3 and 4

. '..Docket Numbers 50-250 and 50-251 NRC Inspection Report 89-24

. TS '6'.8.1 requires'"that.written procedures and"administrative policies shall

"; .~<<be~established, implemented and maintained that meet or exceed the require-

ments and recommendations of Appendix A of USNRC Regulatory.;Guide 1~33 and Sections 5.1 and 5.3 of ANSI N18.7-1972.

O-GME-102.1, Troubleshooting and. Repair Guidelines, step 3.1 requires that a PWO shall have been issued prior to commencing work and step 6.2.7 requires that all lifted leads be documented and independently verified. Steps 6.2.9 and 6.3.8 require all lifted leads be reconnected and independently verified.

O-ADM-715, Maintenance Procedure Usage, steps 5.5.2 and 5.5.3; provide in-structions for independent verification of lifting and relanding leads.

Contrary~ to the above, licensee personnel failed to follow procedure 4-PMI-028'3 by proceeding. to Section. 6.4 of the procedure, prior to completing Section 6.3, resulting in an inadvertent drop of Rod M-8 on May 7, 1989.

2. Contrary to the above, leads to the turbine stop valve limit switches were lifted without adequate controls which resulted in a reactor trip during surveillance testing on. May 5, 1989 .

RESPONSE

Exam le (1)

1. FPL concurs with the finding.

2. The reason for this example was inadequate communications between test .

personnel in the Control Room and at Motor Control Center B (MCC B).

Test personnel in the Control Room h<d the responsibility for ensuring that test personnel at MCC B were supporting the performance of procedure 4-PMI-028.3, "RPI Hot Calibration, CRDM Stepping Test, and Rod Drop Test." However, test personnel at MCC B believed Section 6.3 was com-plete and advanced to Section 6.4 without direction from the Control Room test personnel. This condition resulted in the moveable coil fuse

for rod M-8 being'emoved while the CRDM Stepping Test was being perform-ed on rod H-12 which led to the unexpected drop of rod M-8.

0 Corrective steps which have .been taken and'.,the results achieved include:

a) I6C test personnel. performing."-4-PMI-028 '3 were made aware of the

.miscommunications'.problem andswere cautioned to be, more. attentive

--* "..~.':,; to precise communications.

Procedures 3/4-PMI-028.3, "RPI Hot Calibration, CRDM Stepping Test, and Rod Drop Test," have been changed by adding a Caution Statement to Section 6.3 which states, "Ensure all CRDMs to be stepping tested are completed .prior to proceeding to.Section 6.4."

'4 ""The corrective steps'.which willAe taken to avoid further violations

." include:

A general communications policy statement will be placed in Mainten-ance Instruction MI-700, "Conduct of Maintenance," to formalize and standardize maintenance communications.

Date when full compliance will be achieved:

a) Action item 3.a was completed on May 7, 1989.

b) Action item 3 b was completed on June 20, 1989.

c) Action item 4 will be completed by August 31, 1989.

1. FPL concurs with the finding.

2. Failure to comply with Procedures O-GME-102.1, "Troubleshooting and Repair Guidelines.," and 0-ADM-715', "Maintenance Procedure Usage," were cited by the NRC as being the cause for Example 2. Since the turbine stop valve limit. switches were* under. the control of Backfit Construction, these procedures were not applicable to those components during this event.

The reason for this example was inadequate administrative controls. Through personnel interviews, FPL believes that work activities on the turbine stop valve limit switch terminal boxes were performed in the November 1988 time frame. The procedure governing the work being performed on the turbine stop valve limit switches at the time the limit switch leads were lifted was Back-fit Construction procedure ASP-2, "Preparation of Site Procedures/Process Sheets." This procedure did not require the lifting of these leads to be documented.

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

Although the lifted lead condition was identified in May 1989, a new Backfit Construction procedure was developed to improve control of

Process Sheets and Installation Lists in early 1989. This new pro-cedure, ASP-34, "Preparation of Process Sheets and Installation Lists,"

was issued on January 23', 1989 and superceded that part of ASP-2 addressing Process Sheets. This procedure describes the requirements

.for the .control and documentation of Backfit Construction work act-

': ivities "and is applicable 'to all Safety Classifications of work per-formed by Backfit.,Construction -at'urkey Point Units=3 and 4.

.'Subsequent -to -the issuance of ASP-34, an enhancement was made to specify that Process Sheets or Installation Lists are required for maintenance work that is not directly implemented on a Plant Work

, . Order (PWO) or in accordance with an approved ASP.

"~"4 ." The corrective steps which will be be .taken .to avoid further violations include:

No further corrective actions are deemed necessary.

Date when full compliance will be achieved:

Action item 3 was completed on August 3, 1989.

p