L-91-334, Responds to Violations Noted in Insp Repts 50-250/91-19 & 50-251/91-19.Corrective Actions:Const Svcs Procedure ASP-30, Application of Protective Coatings Will Be Revised to Include Plant Maint Coating Spec
| ML17223B377 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 12/16/1991 |
| From: | Goldberg J FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| L-91-334, NUDOCS 9112260030 | |
| Download: ML17223B377 (4) | |
Text
ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ESSION NBR:9112260030 DOC.DATE: 91/12/16 NOTARIZED: NO CIL:50-335 St. Lucie Plant, Unit 1, Florida Power
& Light Co.
50-389 St. Lucie Plant, Unit 2, Florida Power
& Light Co..
AUTH.NAME AUTHOR AFFILIATION GOLDBERG,J.H.,
Florida Power
& Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch '(Document Control Desk)
DOCKET ¹ 05000335 05000389
SUBJECT:
Responds to violations noted in Insp Repts 50-250/91-19 50-251/91-19.Corrective actions:Const Svcs Procedure ASP-30, "Application of Protective Coatings" will be revised to.
include plant maint. coating spec.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED LTR ENCL SIZE TITLE: General (50 Dkt)-Insp Rept/Notice of VioTation R sponse NOTES:
D RECIPIENT ID CODE/NAME PD2-2 PD INTERNAL: ACRS AEOD/DEIIB DEDRO NRR MORISSEAU,D NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NRR/PMAS/ILRB12 0
EG F L 02 EXTERNAL EG&G/BRYCE 1 J ~ H ~
NSIC COPIES LTTR ENCL 1
1 2
2 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 RECIPIENT ID CODE/NAME NORRIS,J AEOD AEOD/DSP/TPAB NRR HARBUCKg C ~
NRR/DLPQ/LHFBPT NRR/DOEA/OEAB NRR/DST/DIR 8E2 NUDOCS-ABSTRACT OGC/HDS3 RGN2 FILE 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 D
D D
NOTE TO ALL"RIDS" RECIPIENTS:
D D
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TAL NUMBER OF COPIES REQUIRED:
LTTR 24 ENCL 24
P.O. Box14000, Juno Beach, FL 33400-0420 DEC 1 6 199)
S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D. C.
20555 Gentlemen:
Re:
St; Lucie Unit Nos.
1 and 2
Docket Nos.
50-335
& 50-389
Response
to Notice of Violation Ins ection Re ort 91-19 Florida Power and Light Company has reviewed the subject inspection
~
~
report and pursuant to 10 CFR 2.201 the response is attached.
Very truly yours, t
President Nuclear Division JHG/JWH/kw Attachment cc: Stewart D. Ebneter, Regional Administrator, USNRC Region II Senior Resident Inspector, USNRC, St. Lucie Plant DAS/PSL 582-91 0
'r'1i2260030 91i216 PDR r-"rGOCK O.i000335 Ag M PDFl an FPL Group company
~pc /
I/ g
ATTACHMENT
RESPONSE
TO NOTICE OF VIOLATION NDING0 Unit 1 Technical Specification (TS) 6.8.1.a required that written procedures shall be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1;33, Revision 2,
February 1978.
Appendix A, paragraph 9.a, included maintenance that can affect the performance of safety-related equipment.
Procedure QI 5-PR/PSL-l, Rev 46, Preparation,
- Revision, Review/Approval of Procedures, section 5.8, implemented TS 6.8.1 and required that procedures be strictly adhered to.
Procedure CN-2.27, Rev 1, Furnishing and Application of Service Level II and Balance-of-Plant Maintenance
- Coatings, required that while painting or
- coating, adjacent equipment such as emergency diesels and support equipment shall be protected.
The procedure further detailed the types of equipment and possible means of protection.
Contrary to the above, on September 24, 1991, the 2A EDG room and equipment contained therein was found unprotected during a floor painting preparation activity.
The still-in-service EDG and support equipment was dusted with paint and concrete material removed by mechanical abrasion
- tools, with itional material and debris still on the floor.
The situation could have n
aggravated had the EDG and the attached radiator cooling fans tomatically started.
The resulting wind would have blown dust and debris into critical locations on or in the equipment.
RESPONSE
1 ~
The reason for the violation was personnel error coupled with an inadequate procedure.
2 3 ~
e The work was immediately stopped and the area cleaned up.
The painting supervisor, painting
- foreman, and painters were given additional instruction on the requirements of CN-2.27 (Service Level II and Balance of Plant Maintenance Coatings Specification).
A 'pre-work checklist which implements the equipment protective requirements of CN-2.27 has been developed.
The checklist includes:
1)
Noting the pre-work condition of the area,
- 2) List of the equipment, valves, etc. that have to be protected,
- 3) Sign-offs by the FPL and contractor supervisors.
A temporary change to Construction Services procedure ASP-30 "Application of Protective Coatings" has been developed to include the pre-work checklist.
This temporary change has been implemented.'onstruction Services procedure ASP-30 "Application of Protective Coatings" will be revised to include the requirements of CN-2.27 and the pre-work checklist.
The plant procedure for cleanliness control will be reviewed and enhanced as necessary.
Construction services procedure ASP-30 will be revised by January 15, 1992
'heplant cleanliness control procedure will be reviewed and enhanced as necessary by January 31, 1992.
Full compliance will be achieved on January 31, 1992.
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