ML17348A177

Responds to Violations Noted in Insp Repts 50-250/90-04 & 50-251/90-04.Corrective Actions:Individuals Counseled Re Adherence to Clearance tag-out &/Or Tag Removal Procedures & Event Discussed W/Personnel During Shift Crew Meetings

ML17348A177
Person / Time
Site:	Turkey Point
Issue date:	04/13/1990
From:	GOLDBERG J H FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-90-134, NUDOCS 9004200416
Download: ML17348A177 (5)

See also: IR 05000250/1990004

Text

>C;CE1ZRATED

'3)lSTR1BUTION

DEMOYSTRA'Ho.i

SYSTEM REGUL'ATORY:INFORMATION

DISTRIBUTION

SYSTEM (RIDS)" ACCESS3:ON

NBR:9004'200416

DOC.DATE: 90/04/1'3 NOTARIZED:

NO DOCKET ACIL:50-250

Turkey-.Point'Plant, Unit 3, Florida Power and Light C 05000250 50-251 Turkey:.Point

'Plant., Unit 4, F1orida Power and Light C 05000251 UTH.NAME-'AUTHOR AFFILIATION

GOLDBERG,J:H.

florida Power 6 Light Co.RECIP.NAME

~CIPIENT AFFILIATION

Document Control Branch (Document Control Desk)SUBJECT.Response Wo violations

noted during Znsp Repts 50-250/90-04

6.50-253./$

0-04 Corrective

actions noted.DISTRIBUTION

CODE: IE01'D COPIES RECEIVED:LTR

(ENCL\SIZE: TITLE: General (50 J)kt)-Insp

Rept/Notice

of Violation Response NOTES:-RECIPIENT

'ID CODE/NAME PD2-2 PD INTERNAL: AEOD AEOD/TPAD NRR SHANKMANgS

NRR/DOEA DIR 11 NRR/DRZS/DIR

NRR/PMAS/ZLRB1Z

OE D EG FTL 02 R FILE 01 EXTERNAL: LPDR NSIC 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 1 1 RECIPIENT ID CODE/NAME EDZSONiG AEOD/DEZIB

DEDRO NRR/DLPQ/LPEB10

NRR/DREP/PEPB9D

NRR/DST/DIR

8E2 NUDOCS-ABSTRACT

OGC/HDS2 RES/DSR/HFB/HFS

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 R NOXE'ZO ALLRIDS" RECIPZERIS:

PIZASE HELP US 10 REDUCE HASTE)CORI'ACZ'ZHE

DOCUMERl'XWGK)L

DESK RDCH Pl-37 (EXI'.20079)K)EIZKQQZS MAR NICHE FKH DIB!HGEtUTICN

LISTS FOR DOCUMEMI'S

YOU DCÃ~T NEED)D S TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 22

P.O.Box 14000, Juno Beach, FL 33408 0420 0 jQQJQ g g 199(L-90-134 10 CFR 2.201 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 90-04 Florida Power&Light Company has reviewed the subject inspection

report and pursuant to 10 CFR 2.201 the response is attached.Very truly ours, J.H.Goldberg Executive Vice President Nuclear Energy JHG/GRM/sh

Attachment

cc: Stewart D.Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant 9004200426

900423 PDR ADOCK 05000280 9 PNU an FPL Group company

ATTACHMENT

• RE::Turkey.Point

Units 3 and 4 Docket Numbers 50-250 and 50-251'RC Inspection

Report 90-004 FINDING TS 6.8 1 requires that written procedures

and administrative

policies.shall be established, implemented

and maintained

that meet or exceed the requirements

and recommendations

of Appendix A of USNRC Regulatory

Guide 1.33 and Sections 5.1 of ANSI N18.7-1972.-

Section 5.1.2 of ANSI N18.7-1972

requires that procedures

be followed..

Operating Procedure 4-0P-013, Instrument

Air System, dated December 15, 1989, Section 3.0, Prerequisites, required that all instruments

and control devices be in service for the instrument.

air system operation with no clearances

that could affect system operability.

This is verified by reviewing the clearance log.Contrary to the above, on February 4, 1990, a senior nuclear plant operator returned the Unit 4 instrument

air dryer to service per 4-OP-013 without verifying system clearances.

This resulted in the Unit 4 instrument

air supply being isolated.The control room operators were required to reduce the load to prevent a reactor trip until the instrument

air was restored.RESPONSE FPL concurs with the finding.2.The Unit 4 instrument

air, supply was inadvertently

isolated due to personnel error.A Senior Nuclear Plant Operator (SNPO)was instructed

to place the Unit 4 instrument

air dryer in service.The SNPO obtained a copy of Operations

Procedure 4-OP-013,"Instrument

Air System," and the clearance order (4-90-02-008)

issued to remove the Unit 4 instrument

air dryer from service.The SNPO assumed that the clearance order followed the procedural

sequence for restoring the Unit 4 instrument

air dryer to service.Based on this, the SNPO commenced performance

of Section 7.5 of 4-OP-013 while simultaneously

removing tags identified

on the clearance order.Upon closure of the Unit 3 instrument

air cross-tie isolation valve to Unit 4 (3-IAS-012), instrument

air to Unit 4 was lost.The SNPO did not adhere to the prerequisites

of 4-OP-013 which require that all instruments

and control devices be in service for Instrument

Air System operation.

This prerequisite

requires that clearances

be lifted before using the procedure.

'The SNPO did not adhere to the clearance executor responsibi1ities

defined.in Administrative

Procedure AP 0103..4,,"In-Plant Clearance Orders." The clearance executor is responsible

for following the clearance tag-out and/or Wag removal in the order given.If any step cannot be executed exactly in the order given, he shall request clarification

from the originator

of the order or Plant Supervisor-Nuclear

before proceeding.

Clearance Order 4-90-02-008

was correctly prepared.The last step in the clearance order required%he Unit 4 instrument

air dryer to be placed in service in accordance

with Section 7.5 of 4-OP-013.Had the SNPO followed the clearance order, this event would not have occurred.3~Corrective

steps which have been taken and the results achieved include: a~b.The Operations

Superintendent

held a meeting with the individuals

involved in this event to determine the cause for inadvertently

isolating the Unit 4 instrument

air supply.During this meeting, the involved individuals

were counseled on their performance, the need to thoroughly

understand

the task being assigned, and the importance

of following procedural

requirements.

The Operations

Superintendent

discussed this event with operations

personnel during shift crew meetings.Shift cre'w meetings provide a forum for Turkey Point management

team personnel to interface with operations

personnel and discuss problems affecting plant operations.

4~Corrective

steps which have or will be taken to avoid further violations

include: a.A Human Performance

Evaluation

System (HPES)representative

is currently evaluating

this event for possible enhancements

to prevent event recurrence.

b.Operations

management

will review the HPES Study recommendations

to determine what further actions, if any, need to be taken to prevent event recurrence.

5.The date when full compliance

was or will be achieved: a~b.C~d.Item 3.a was completed on February 7, 1990.Item 3.b was completed on March 20, 1990.Item 4.a will be completed by April 16, 1990.Item 4.b will be completed by April 27, 1990.