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)

See also: IR 05000250/1989024

Text

REGULATORY'NFORMATION

DISTRIBUTION

SYSTEM (RIDS)-A ION NBR: 8908220220

DOC DATE: 89/08/14 NOTARIZED:

NO~~L:50-250 Turkey.Point Plant, Unit 3, Florida Power and Light C 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C'XUTH'Ã2QIE

.AUTHOR AFFILIATION

=-=MOODY,.C.O.

Florida Power&Light Co.gtECIP.NAME

RECIPIENT AFFILIATION

Document Contro1 Branch (Document Control Desk)';SUBJECT.:

Responds to violations

noted in Insp Repts 50-250/89-24

&50-251/89-24

'".DZSTRZEDTZON:":CODE:

".ZE01D*COPIES RECEZVED;LTR" ENCL j':~SZEE-'ITLE:=.General

(50.Dkt)-Insp

Rept/Notice

of Vio ation".Response;~~,'NOTES: DOCKET I 05000250 05000251 RECIPIENT ID CODE/NAME PD2-2 PD INTERNAL AE0D AEOD/TPAD LOIS, ERASMIA NRR/DEST DIR NRR/DOEA DIR 11 NRR/DREP/RPB

10 NUDOCS-ABSTRACT

OGC/HDS2 RES MORISSEAU,D

EXTERNAL: LPDR NSIC COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 2 2 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME EDISON,G AEOD/DEIIB

DEDRO NRR SHANKMAN,S

NRR/DLPQ/PEB

NRR/DREP/EPB

10 NRR/PMAS/ILRB12

0 ERMAN, J G ILE 02 RG PZLE 01 NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 h 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'cting Senior Vice President-Nuclear COW/JRH/cm

Attachment

'cc: Stewart D.Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant 9QPq2~+()QgC

pQ)qQ 8~pDI ICY l.)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.

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