L-90-271, Responds to NRC Ltr Re Violations Noted in Insp Repts 50-335/90-09 & 50-389/90-09.Corrective Actions:Procedural Expectation Re Hanging & Removal of Deficiency Tags Will Be Reemphasized to Personnel Generating Work Orders

Responds to NRC Ltr Re Violations Noted in Insp Repts 50-335/90-09 & 50-389/90-09.Corrective Actions:Procedural Expectation Re Hanging & Removal of Deficiency Tags Will Be Reemphasized to Personnel Generating Work Orders

ML20055G763
Person / Time
Site:	Saint Lucie
Issue date:	07/20/1990
From:	Goldberg J FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-90-271, NUDOCS 9007240149
Download: ML20055G763 (3)

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4  : P.o. Box 14000, Juno Beach,FL 33408 0420 PPL JULY 2 01990 L-90-271 1

10 CFR 2.201 U.!S. Nuclear Regulatory Commission Attn: Document Control' Desk

,, Washington, D. C. 20555 Gentlemen:

Re: St. Lucie Units 1 and.2

' Docket Nos. 50-335 and 50-389 Inspection Report 90-09 Response'to Notice of Violation Florida Power & Light Company -(FPL) has reviewed th? subject inspection report, and' pursuant to the provisions of 10 CFR '.2'J1, the response is-attached.

Very truly 'yours,

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J. . G- dberg Y, [4 President Nuclear Division JHG/JF./1g Attachment cc: Stewart D. Ebneter, Regional Administrator, Region II, USHRC Senior Resident Inspector, USNRC, St. Lucie Plant 2

9007240i49 900720 >

PDR ADOCK 05000335 .

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Re:' S't'..Lucie Units land 2

= Dockett Nos. LO-335 and 50-389 Inspection Report'.90-09 Response to Notice of Violation  ;

VIOLATION:

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-Unit 1 and Unit 2_ Technical Spsifications, section 6.8.1, state .

in part that written procedures shall be established, implemented 1

and maintained. Administrative Procedure (AP)_ No. 0010432, Revision ' d 41, Nuclear Plant - Work Orders _(NPW0s) requires the following l

(including._butnotlimited.to):

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-1. Section 8.1: requires a deficiency tag to be hung if the NPWO l is identifying a. deficient plant condition.

1' _-Contrary to Section 8.1, on May 10, 1990, there were six' b t-2' control room deficiency tags which were not hanging. as required.

These tags were associated with the following control _ room'NPW0s: i 5588, 7956,. 3094, 7662, 7483, 6073. Additionally. on May ~8 .

1990, .there. were nine deficiency tags. which were not hung on ,

the Unit 2 Emergency Diesel Generators - (EDGs) as required. The-respective - EDG NPW0s .were: 3060, 7253,. 5658 7489,. 3107, 5065, i and three others (NPWO numbers were not available. - Work Request numbers XA 891016122630, XA ' 900321162206, and XA 900502033049, respectively).

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2. Section .8.6.9. requires that after work . completion, the Journeyman / Technician removes. the portion of: the deficiency tag used to ' identify or associate the defect with the NPW0. - ,

Additionally, this section = requires _ attaching the ' deficiency. '

tag-to the NPW0'after_ work completion.

u Contrary - to section' 8.6.9. , there were four- NPWO deficiency tags E hung on the EDGs subsequent to work completion and NPWO~ closure  ;

or cancellation. These deficiency tags were 43110 (PWO '7512),

4 = 43788 - (PHO 7819), and: 32711 (PW0 E 7622) and 32268 - (PWO number unavailable). These deficiency tags were not . attached- to the o respective NPWO after compir '. ion - as required. Additionally,

, on .May - 10, 1990, there were ~ nine Unit-2 control room _ deficiency lE tags which were not attached to the respective NPWO as required, e These deficiency -tags were: C43500, C32252, C32295, C40190, L- C43411, C43456, C43457 C43504, and C43700.

RESPONSE (ITEM 1)

~1. Florida- Power & Light concurs with the violation.

2. The reasor for the violation is procedure non-compliance.

L 3. The missing deficiency . tags on the reference NPW0s have been 'l L hung on the applicable components. '

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RESPONSE'(ITEM 1) Continued.

4. -To prevent recurrence, procedural expectation regarding= the' hanging '

and ' removal- of _ deficiency tags will be re-emphasized. tot the i persor nel ~ generating NPW0s. In addition, the deficiencyE tags

assigned' to- the control- room will - be . checked - monthly and l discrepancies corrected.

5. ' Corrective - action is expected to be complete by ~ September 1, 1990.

RESPONSE (ITEM 2)

-1. Florida Power & Light concurs with the violation.

2 .- The reason for' the - violation is procedure non-compliance and-inadequate procedural instructions.

3. The - deficiency tags left on the equipment ,af ter comp 1'e tion or -

cancellation, have been removed.

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4. To prevent recurrence - procedural _ expectations regardin', the  ;

removal .of deficiency tags following completion or canculation of. NPW0s - and. the attachment of these tags to the NPWO will = be re-emphasized to the personnel closing :NPW0s. In addition. i AP 0010432 . Nuclear Flaat Work Orders, will be revised to include instructions regarding the cancellation of a NPWO. '

5. Corrective action is expected to be complete by October 1, 1990.

It should be noted that the deficiency tag system does not govern the potential operation - of defective equipment as described in Paragraph c.2 on' page 10. Our clearance system and equip:nent out

'of service log govern. the -operability of -plant equipment. The deficiency tag system wa's established as an aid to ensure duplicate -

NPW0s were not written on the same piece __ of deficient; equipment.

The deficiency tag ' system was never intended to function -as an equipment status _ system.

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