ML17342B088

Responds to Violations Noted in Insp Repts 50-250/87-46 & 50-251/87-46.Corrective Actions:Valve Removed,Evaluation Performed to Determine Valve Function & Procedure AP 0103.34, Component Labeling & Tagging Revised

ML17342B088
Person / Time
Site:	Turkey Point
Issue date:	01/19/1988
From:	Woody C FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
L-88-27, NUDOCS 8801260110
Download: ML17342B088 (4)

Text

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR: 8801260110 DQC. DATE: 88/Oi /1'7 NOTARIZED:

NO DOCKET ¹ FACIL: 50-250 Turkey Point Plant, Unit 3i Florida Power and Light C

05000250 50-251 Turkey Point Planti Unit 4'i Florida Poeer and Light C

05000251 AUTH. NAME AUTHOR AFFILIATION l4OODYI C. O.

Florida Poujer Cc Light Co.

REC IP ~ NAME RECIPlENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to violations noted in IE Insp Repts 50-250/87-46 Sc 50-251/87-46. Corrective actions: Valve removedi evaluation performedi Procedure AP 0103. 34 revised 5 time tag installed.

DISTRIBUTION CODE:

IEQID COPIES RECEIVED: LTR I

ENCL J SIZE:

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

RECIPIENT ID CODE/NAME PD2-2 PD INTERNAL:

AEOD NRR MQRISSEAUiD NRR/DOEA DIR NRR/DREP/RPB NRR/PMAS/ ILRB OGC/HDS2 RES/DRPS DIR TERNAL:

LPDR NSIC CQP IES LTTR ENCL 1

1 1

1 1

1 1

2 2

1 1

1 1

1 1

1 1

1 RECIPIENT ID CODE/NAME Mc DONALD, D DEDRO NRR/DLPG/PEB NRR/DREP/EPB NRR/DRIS DIR OE DOBERMAN>J x

RGN2 FILE 01 NRC PDR COPIES LTTR ENCL 2

2 1

1 1

1 1

1 1

1 1

1 1

1 1

TOTAL NUMBER OF COPIES REQUIRED:

LTTR 21 ENCL 21

P. O. BOX 14000, JUNO BEACH, FL 33408.0420 3ANUAfE 1 9 1980 L-88-27 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 Ins ection Re ort 87-46 Florida Power Light Company has reviewed the subject inspection report and a response is attached.

Very truly yours, C.

O.

Wo Executive Vice President COW/SDF/gp Attachment cc:

Dr. J. Nelson Grace, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant SDF/IR.004 gp(

an FPL Group company

ATTACHMENT

~

~

RE:

TURKEY POINT UNITS 3 AND 4 DOCKET NO ~ 50-250, 50-251 IE INSPECTION REPORT 250-87-46

& 251-87-46 FINDING A:

Technical Specification 6.8.1 requires that written procedures shall be established and implemented for activities recommended in Appendix A of Regulatory Guide 1.33.

Appendix A, recommends, in part, that procedures for the operation of safety related systems should be established'perations Procedure 4-0P-64, entitled Safety Injection Accumulators, revision dated September 22, 1987, requires, in Attachment 2 that the manual isolation vent valve 4-937 be in the open position.

Contrary to the above, on October 25, 1987, valve 4-937 was found not to be in the open position.

RESPONSE

A:

2)

The reason for the violation is most probably the combination of two personnel errors'erformance of procedure 4-OP-064 is required prior to entry into mode 2.

This procedure verifies proper valve position for valve 4-937.

Procedure 4-OP-064 was last performed on June 28, 1987, prior to unit 4

criticality on July 8, and verified that valve 4-937 was open.

No work which required valve 4-937 to be in the closed position was performed between the performance of 4-OP-064 on June 28 and October 25, 1987.

A probable contributor to the event was a component ID tag which was attached to this valve.

The tag improperly identified the valve as being normally closed.

The incorrect tag was installed in April 1986.

The tagging program has implemented significant enhancements since that time.

The likely reason for the closure of valve 4-937 was that the valve operator was inadvertantly stepped on.

The valve is a globe valve with a quarter-turn required to fully close it.

The conclusion that the valve was stepped on was based on the fact that the valve operator was bent such that it could not fully opened.

3) 4)

Valve 4-937 was immediately opened.

a)

Valve 4-937 was removed.

An evaluation was performed to determine the function of the valve.

The evaluation determined that no credit is taken for this valve for venting the accumulators'

~ ~

b)

Procedure AP 0103

~ 34

~ "ComPonent Labeling and Tagging"

~

was revised on February 24 1987

~

The revised Procedure assures that the information on the tags is accurate by requiring the following:

Prior to tags being ordered, the applicable

drawings, procedures, and other reference materials are reviewed to establish the accuracy of the information which is to be printed on the tag.

At the time the tag is installed, the above verification is performed independently by the tag installer.

Any identified discrepancies are required to be evaluated and resolved at this time.

In an effort to further enhance the plant tagging program, procedure ADM-209, "Equipment Tagging" revised and replaced procedure AP 0103.34 on December 4,

1987.

c)

A letter addressing the need for care to assure that valve position is not changed accidentally will be issued to plant personnel.

5) a) Full compliance for item 3 above was achieved by October 25, 1987.

b) Full compliance for item 4a above was achieved by November 13, 1987.

c) Full compliance for item 4b above was achieved by February 24, 1987.

d) Full compliance for item 4c above will be achieved by February 15, 1988.