IR 05000335/1979006
| ML19270H096 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 04/03/1979 |
| From: | Cantrell F, Webster E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19270H083 | List: |
| References | |
| 50-335-79-06, 50-335-79-6, NUDOCS 7906230013 | |
| Download: ML19270H096 (7) | |
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Report No.-
50-335/79-06
' Licensee:
Florida Power and Light Company Facility Name:
St. Lucie Unit 1 Dotket No.
50-335 License No..
DPR-67 Inspection at St. Lucie Site
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Inspector-
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Djite Signed E. 11. Web s t e r
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Approved by:
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S. Chnt r' ell, Ac t ing Sect ivn Chi ef, RONSB STSDL\\RY Inspection on February 12-16, 1979 Areas Inspected This routine unannounced inspection involved 33 inspector-hours onsite in the areas of licensee event reports, Facility Review oroup activities, IE Bulletin, and Circulars, c on t a inmen t puree controls, design changes and modifications, and non-routine event reporting program-Results of the six areas inspected, no apparent items of noncompliac e or deviations were identified is five areas; two apparent itens of noncompliance wert found in one area (infrat ion - failure to c om;il e t e a written safety evaluation of a modification to a system described in the FRAR - paragraph 4a; infraction-failure to rev w and approve a maintenance retest procedure - paragraph 95),
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DETAILS 1.
Persons Contacted Licensee Employees
- C.
M. Wethy, Plant Manager
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- J.
H. Barrow, Operations Superintendent C. A. Wells, Operations Supervisor
- A.
J. Collier, Instrument Control Supervisor
- R.
R. Jennings, Technical Department Supervisor L. W. Pearce, Plant Supervisor, Nuclear
- N.
C. Roos, QC Engineer D. J. St. John, Plant Supervisor, II F. J. Frechette, Acting Chemistry Supervisor
- A.
W.
Barley, QA Engineer
- H.
F. Buchanan, Health Physics Supervisor Other licensee employees contacted included technicians, and operators.
- Attended exit interview.
2.
Exit Interview The inspection scope and findings were summarized on February 16, 1979 with those persons indicated in Paragraph I above.
The two items of noncompliance discussed in paragraph 9.a. and b. were acknowledged by licensee management.
The licensee stated that action to locate neces-sary documentation, discussed in paragraph 9.c. as an unresolved item, was in progress.
3.
Licensee Action on Previous Inspection Findings (Closed) Unresolved Items (335/78-23-01):
L'censee evaluation of environ-mental qua1ifications of electrical components inside con t a inme it.
The inspector provided a co; y of IE Bullet in 79-01 " Environmental Qualif i-cation of Class IE Equipment" dated February 8, 1979 to licensee manage-ment.
Since this bulletin requires response by mid-June, 1979 to the same action request as in IE Circular 78-08, this unresolved item and a related open item (335/79-01-04) are closed.
The issue shall remain open administratively, by the IE Bulletin tracking system and shall be reviewed by the.nspector in future inspections.
I'nresolved Items l'nresolved items are a matter about which more information is required to determine whether they are acceptable or may involve noncompliance or deviations. One new unresolved item identified during this inspection is discussed in paragraph 9c.
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5.
Plant Status At the time of this inspection, St. Lucie Unit I was operating at 100%
rated power.
6.
Containment Purge Controls
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A letter f rom NRR to FP&L dated November 29, 1978, requested information concerning bypass circuitry for containment purge systems and an evalu-ation of containment purge operations.
In letters dated January 5, and February 1, 1979 FP&L responded to all questions and committed to complete an evaluation of the purge valves operation for specific analyzed accidents by August 1, 1979.
The inspector verified the controls detailed in the licensees letters.
1978 gas release records indicated containment purge operations for only 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br />.
All but two purges were conducted just prior to maintenance outages.
The licensee appears to have adequate control of purging operations and appears to minimize containment purging as much as possible.
The inspector had no further questions in this area.
7.
Facility Review Group (FRG) Activities Review The inspector reviewed the licensees Administrative Procedure (AP)
0010520 and FRG minutes to verify that the onsite safety committee reviewed activities and documents as prescribed in Technical Specifications, met at required frequency, and that membership for specific meetings was appropriate for the material covered.
The inspector reviewed FRG minutes from December 1, 1978 to January 30, 1979.
In the minutes for the 14 meetings, involved membership listings indicated more than two designated alternate members present on four occasions.
Since this appeared to be in noncompliance with Technical Spec if ication (T.S.) 6.5.1.3, the inspector interviewed three FRG members and two designated alternate members to assess the method of approval by the FRG.
Licensee personnel confirmed that FRG approval of procedures unanimous agreement, making the use of extra alternate members have no impact on the intent of the T.S.
in deciding technical issues.
The inspector confirmed that a minimum of three members were present at each FRG meeting, regardless of the number of alternates and that all alternates 1isted were designated in writing.
Licensee personnel committed to changing Ap 0010520 to reflect the approval procedure presently in use This area remains open pending review of the revised procedure (335/79-06-01).
No items of noncompliance or deviations were identified.
8.
Review of Licensee Event Reports a.
Nritten Report Review The following thirty-day LERs were reviewed in-office to determine whether reporting requirements had beto met, the report assessed the event and identifled the cause, and corrective action was appropriate.
Except as indicated, the inspector had no further questions:
(1)
LER 78-11, Supplement dated August 8, 1978 reported the cause 2247 058
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of the broken in-core instrument thimbles found April 15, 1978.
(2)
LER 78-16, dated June 9, 1978.
An open item (335/78-17-03)
was initiated pending licensee request for a T.S. change to Table 2.2-1.
The licensee requested that change by letter to NRR dated January 8, 1979.
(3)
LER 78-44, dated December 20, 1978, concerning inoperabilitt of valve MV-07-1B.
(4)
LER 78-46, dated January 5, 1979 concerned a control element assembly (CEA) drop.
Due to the frequency of CEA drops, the inspector will review the system used by the licensee to report problems that may be generic to Combustion Engineering (CE) systems, to assure followup by CE (335/79-06-02).
b.
Written Report Review and Followup Onsite In addition to performing a report review as defined in a.
above, site followup was performed for these LERs to determine whether the corrective action specified had been taken, the 1icensee had reviewed the event, whether it involved an unreviewed safety question or violation of regulations or whether a corrected LER was submitted, if required:
(1)
LER 78-10, dated July 14, 1978 reported one channel of stea--
generator low pressure measurement failing due to a faulty power supply.
As discussed in IE inspection report 335/78-15, the licensee has approved a design change, desienat ed PC 'M 413-78, to replace the power supplies durinn the upconing refueling outage.
The inspector will verify completion of PC/M 413-78 (335/79-06-03).
(2)
LER 78-30, dated September 8, 1978 reported failure to cor"lete required chemistry analysis following a plant trip.
Th.
a inspector verified administrative controls exist to preclude recurrence.
The inspector had no further questions in thi:
area.
(3)
LER 78-41, dated November 17, 1978 reported inadvertent int er-ruption of shutdown cooling due to improper clearance renm al.
The inspector completed the review initially reported in 11 inspection report 335/79-01, by reviewing Operating Procedure (OP) 0010122, revision 6, and the subject clearaaec order number 10-171 dated October 28 1978.
The inspector verified the revised procedure was adequate to preclude recurrence No items of noncompllance or deviations were identified.
9.
Design Changes and Modifications 2247 059
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The inspector reviewed the design change / modification areas to verify that changes were made and documented in accordance with 10 CFR 50.59, reviewed and approved in accordance with T.S. and QA/OC controls, and conducted using formal, approved procedures.
For the seven changes selected, the inspector verified that documentary evidence was available onsite to support their conformance to design change requirements. Design inputs,
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encompassing codes, standards, regulatory requirements, and design bases were verified.
The test and acceptance criteria stipulated in the design change procedures were reviewed as to their status and adequacy.
The final modified equipment performance was reviewed and approved indicating their conformance to Technical Specifications.
Additionally, operating procedures and as-built drawings affected by the selected design changes were reviewed to verify their up-to-date revision status.
The specific changes reviewed were:
a.
PC/M 446-78 and associated Plant Work Order (PWO) 7437 dated March 16, 1978. The change to the Thermal Margin / Low Pressure (TM/LP) pretrip (alarm) setpoint from 100 PSI above the trip setpoint to 50 PSI above completed on November 2, 1978.
the TM/LP trip setpoint was The TM/LP pretrip function is described in the Final Safety Analysis Report (FSAR) sect ion 7.2.1.2(g) and the pretrip setpoint of 100 psi above the trip setpoint listed in the FSAR table on page 7.2-13.
The safety evaluation required by 10 CFR 50.59(b) was completed on September 20, 1978, but did not specifically address the three bases specified in 10 CFR 50.59(a)(2) to be used to determine whether the change represented an unreviewed safety question.
The assumption used that the TM/LP pretrip function serves only for an alarm, appeared to make this evaluation complete.
However, VSAR section 7.2.1.2(g) on page 7.2-14b details that the TM/LP pretrip also functions to cause a CEA withdrawal prohibit as well as an alarm.
This control function was not analyzed as required bv 10 CFR 50.59 nor was a written evaluation documented. This is in noncompliance with 10 CFR 50.59 (335/78-06-04).
b.
PC/M 359-78 and associated PWO 7178 dated December 2, 1977, This modification during a CEA block circuit test panel to the existing cabinet wiring was completed November 8, 1978. The change package reviewed by the FRG did not include the PWO nor the attached retest procedure consisted of 11 steps involving step-by-step operation of the new switch, removing leads and checking safety-related indica-tions.
Technice.1 Specification 6.8.2 requires the FRG approve applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, November 1972.
Regulatorv Guide 1.33 section I.1 lists "mainten-ance that can affect the performance of safety-related equipment..."
The lack of approval of t he retest procedure to PC/M 359-78 repre-sents noncompliance with T.S. 6.8.2 (335/79-06-05).
PC/M 493-78 and associated PWO 0931 dated November 7, 1978.
This c.
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-5-modification to a safety injection tank (SIT) brace was completed on November 9, 1078.
The inspector noted that this modification was completed during a plant outage five days prior to FRG approval, on November 14, 1978.
Licensee management could not explain this occurrence, but felt it was exceptional to insure the modification did not extend the shutdown.
The inspector noted that the main-
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tenance did not affect operability of the SIT while the plant was in Mode 5 and that the FRG approval occurred prior to changing plant modes, alleviating the safety concern in this case.
However, the inspector will review other modifications to assure that no other examples exist indicating loss of modification program control (335/79-06-06)
Further review by the inspector revealed the absence of QA documen-tation of the plate material used in this change.
The PWO required 5/8 inch plate material A 515 material specified as grade 70, class III be used for the brace flanges, but the licensee was unable to find the documentation of the material used.
This item will remain unresolved pending review of the documentation of these plates (335/79-06-07).
d.
PC/M 314-77 dated October 14, 1977. This change required a Technical Specification change which has been forwarded to the Company Nuclear Review Board (CNRB) for approval.
The inspector had no further questions in this area.
PC/M 421-78 dated April 30, 1978.
The inspector had no comments in e.
this area.
f.
PC/M NNS 475-78 dated September 1, 1978.
The inspector had no comments in this area.
g.
PC/M NNS 410-78 and associated PWO 6908 dated April 4, 1978.
This change did not effect safety related equipment and was checked only to verify licensees modification program controls.
The inspector had no further questions in this area.
The inspector noted from the above reviews that documentation on the PC/M forms of completion of appropriate drawing and procedure changes, training and CNRB review was often three months or more behind completion of the change activity.
The inspector shall review a larger sampling of changes to determine the extent of this problem in future inspections (335/79-06-08).
10.
IE Bulletin 78-01, Retainers for Contact Arms on CP-120 Relays The subject bulletin was discussed in IE Report 335/78-09 and left open pending licensee action to replace the Celcon retainers in the subject contact arms.
The inspector reviewed the licensees documentation in this area and verif led the replacement retainers are on hand and that PW0s, number 4187 through 4195, are written to conduct the work during 2247 061
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the upcoming refueling outage.
The inspector shall followup on completion of these PW0s in future inspections (335/79-06-09).
11.
TE Circulars and Notices a.
IE Circulars The inspector verified licensee receipt of the following IE Circulars, distribution to appropriate supervisors, review for applicability and action taken or proposed:
(1)
IEC 78-18, UL Fire Test dated November 6, 1978.
This circular was issued for information only and was routed accordingly to appropriate fire protection engineering personnel.
(2)
IEC 79-02 Failure of 120 Volt AC Power Supplies dated January 16, 1979.
This circular was routed and assigned for review by in future March 1979, the inspector will followup in this area inspections wher the review results and proposed action, if any, are available.
b.
IE Notices SRC Inf ormat ion Notices are a new communications mean whereby NRC provides early notification of a possibly significant matter to licensees.
The inspector verified that the licensee has received and distributed the following notices:
(1)
IE5 79-01 Bergen-Paterson Hydraulic Shock and Sway Arrestors dated February 2,
1979.
(2)
IES 79-03 Limitorque Valve Geared Limit Switch Lubricant dated February 9, 1979.
12.
Non-routine Ev en t Reporting Program The inspector reviewed Administrative Procedure 0010721, "SRC Required Non-Routine Reports" and discussed non-ro *ine event reporting functions with Licensee management.
The !icensee appear-to have adequate admin-review and evaluation of operations and istrative controls for prompt maintenance oriented events.
The inspector will review corrective and ad.inistrative controls on vendor bulletins in future action controls m
inspections.
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