ML17347B266: Difference between revisions

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See also: [[followed by::IR 05000250/1989024]]


=Text=
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{{#Wiki_filter:REGULATORY'NFORMATION
{{#Wiki_filter:REGULATORY'NFORMATION DISTRIBUTION SYSTEM (RIDS)-A ION NBR: 8908220220 DOC DATE: 89/08/14 NOTARIZED:
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
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
.AUTHOR AFFILIATION
=-=MOODY,.C.O.
=-=MOODY,.C.O.
Florida Power&Light Co.gtECIP.NAME
Florida Power&Light Co.gtECIP.NAME RECIPIENT AFFILIATION Document Contro1 Branch (Document Control Desk)';SUBJECT.:
RECIPIENT AFFILIATION
Responds to violations noted in Insp Repts 50-250/89-24
Document Contro1 Branch (Document Control Desk)';SUBJECT.:
Responds to violations
noted in Insp Repts 50-250/89-24
&50-251/89-24
&50-251/89-24
'".DZSTRZEDTZON:":CODE:
'".DZSTRZEDTZON:":CODE:
".ZE01D*COPIES RECEZVED;LTR" ENCL j':~SZEE-'ITLE:=.General
".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  
(50.Dkt)-Insp
 
Rept/Notice
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:
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
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
10 NUDOCS-ABSTRACT
'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~  
OGC/HDS2 RES MORISSEAU,D
.'>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.
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
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.
DEDRO NRR SHANKMAN,S
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.
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  
This condition resulted in the moveable coil fuse  
 
for rod M-8 being'emoved
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.
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
performing."-4-PMI-028
'3 were made aware of the:.miscommunications'.problem
'3 were made aware of the:.miscommunications'.problem andswere cautioned to be, more.attentive--*"..~.':,;to precise communications.
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
Procedures
." include: A general communications policy statement will be placed in Mainten-ance Instruction MI-700,"Conduct of Maintenance," to formalize and standardize maintenance communications.
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
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.
to.Section
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  
6.4."'4''""The corrective
 
steps'.which
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
willAe taken to avoid further violations
'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.
." include: A general communications
Date when full compliance will be achieved: Action item 3 was completed on August 3, 1989.
policy statement will be placed in Mainten-ance Instruction
p}}
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
}}

Revision as of 07:28, 17 August 2019

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  NextEra Energy icon.png
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~~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.

p