IR 05000335/1986013
| ML20214S263 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie, 05000000 |
| Issue date: | 12/01/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20214S164 | List: |
| References | |
| FOIA-86-791 50-335-86-13, 50-389-86-12, NUDOCS 8612080234 | |
| Download: ML20214S263 (41) | |
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ENCLOSURE 2 i SALP BOARD REPORT i
- U. S. NUCLEAR REGULATORY COMMISSION t
REGION II
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NUMBERS 50-335/86-13 and 50-389/86-12
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FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNITS 1 AND 2
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NOVEMBER 1, 1984 THROUGH APRIL 30, 1986
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1. Introduction The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate liwnsee performance based upon this informa-tio The SALP program is supplemental to normal regulatory processes used to determine compliance with NRC rules and regulations. The SALP program is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to licensee management to promote quality and safety of plant construction and operatio An NRC SALP Board, composed of the staff members listed below, met on July 15, 1986, to review the collection of performance observations and data to assess licensee performance in accordance with guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance." A summary of the guidance and evaluation criteria is provided in Section II of this repor This report is the SALP Board's assessment of the licensee's safety performance at St. Lucie Units 1 and 2 for the period November 1, 1984, through April 30, 198 SALP Board for St. Lucie Units 1 and 2:
L. A. Reyes, Acting Director, Division of Reactor Projects (DRP), RII (Chairman)
J. P. Stohr, Director, Division of Radiation Safety and Safeguards, RII V. W. Panciera, Acting Director, Division of Reactor Safety, RII D. M. Verrelli, Chief, Reactor Projects Branch 2, DRP, RII
, A. C. Thadani, Director, PWR Project Directorate #8, Division of PWR Licensing-B, NRR
E. Tourigny, Senior Project Manager - St. Lucie, PWR Project Directorate #8, NRR R. V. Celenjak, Senior Resident Inspector, St. Lucie, DRP, RII i
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Attendees at SALP Board Meeting: *
S. A..Elrod, Chief, Reactor Projects Section 2C (RP2C), ORP, RII K. D. Landis, Chief, Technical Support Staff (TSS) ORP, RII T. C. MacArthur, Radiation Specialist, TSS, DRP, RII 0. R. Brewer, Senior Resident-Inspector, Turkey Point, DRP, RII S. Guenther, Project Engineer, RP2C, DRP, RII H. E. Bibb, Resident Inspector, St. Lucie, DRP, RII J. Rausch, Reactor Engineer, TSS, DRP, RII 0. Sells, Senior Project Manager, PWR Project Directorate #8, NRR
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II. Criteria Licensee performance is assessed in selected functional areas depending on whether the facility has been in the construction, preoperational, or operating phase during the SALP review period. Each functional area represents an area which is normally significant to nuclear safety and the environment and which is a normal programmatic area. Some functional areas may not be assessed because of little or no licensee activity or lack of meaningful NRC observations. Special areas may be added to highlight significant observation One or more of the following evaluation criteria was used to assess each functional area; however, the SALP Board is not limited to these criteria and others may have been used where appropriat Management involvement in assuring quality Approach to the resolution of technical issues from a safety standpoint Responsiveness to NRC initiatives Enforcement history Operational and construction events (including response to, analysis of, and corrective actions for) Staffing (including management) Training and qualification effectiveness Based upon the SALP Board assessment, each functional area evaluated is classified into one of three performance categorie The definitions of these performance categories are:
Category 1: Reduced NRC attention may be appropriat Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or construction quality is being achieve Categor3 2: NRC attention should be maintained at normal level Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that satisfactory performance with respect to operational safety or construction cuality is being achieve Category 3: Both NRC and licensee attention should be increase Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used such that minimally satisfactory performance with respect to operational safety or construction quality is being achieve The functional area being evaluated may have some attributes that would place the evaluation in Category l, and others that would place it in either Category 2 or 3. The final rating for each functional area is a composite of the attributes tempered with the judgement of NRC management as to the significance of individual item . .- . - . - - - - -- _ _ .- _ - - . - . .
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The SALP Board may also include an appraisal of the performance trend of a
} functional area. This performance trend will only be used when both a i
- definite trend of performance within the evaluation period is discernible
, and the Board believes that continuation of the. trend may result in a change j of performance level. The trend, if used, is defined as:
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Improving: Licensee performance was determined to be improving near the
- close of the assessment period.
! Declining: Licensee performance was determined to be declining near the
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close of the assessment perio j III. Summary of Results
)! Overall Facility Evaluation
St. Lucie continues to be a well-managed site, with a technically j competent and professional staf Major strengths were identified in
the areas of plant operations, maintenance, surveillance', licensing j activities, and trainin No major weaknesses were identified.
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Management involvement at all levels has contributed to the high level of plant performance during this assessment period. One weakness was j noted to recur in both the Radiological Controls and Surveillance
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analyses, in that plant procedures were not always adequata to maintain the level of program performance during changes in staff experience l levels.
i The performance categories for the current and previous SALP periods in
, each functional area are as follows:
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July 1, 1983 - November 1, 1984 -
j Functional Area October 31, 1984 April 30, 1986 j Plant Operations 1 1
{ Radiological Controls 1 2
j Maintenance 1 1 l
- Surveillan
- e 1 1 I
Fire Protection 2 2
[ e j Emergency Preparedness 1 2
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Security and Safeguards 1 2
i Outages Not Rated 2 i
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Quality Programs and 2 2 Administrative Controls Affecting Quality Licensing Activities 1 1 Training and Qualification Not Rated 1 Effectiveness I Performance Analysis Plant Operations Analysis During the evaluation period, inspections were performed by the resident and regional inspection staff Management involvement in daily operating activities continued at a high level and was augmented by the licensee's development of a new management position titled Site Vice Presiden This strengthened the local control of engineering and purchasing activities and enabled a more coordinated response to site need The position was filled on March 1, 1985, by a strong manager who had previous experience as the St. Lucie Plant Manager during start up and as the Site Vice President at another nuclear sit Plant generation performance for both units continued to be well above average. Unit I was the lead plant in the western world for-the second year in a row, having an annual load factor in excess of 100 percent for the period from September 1984 to September 1985. It is not unusual for a plant to have a load factor in excess of 100 percent for short periods of time, however, this marked the first time a nuclear power plant had ever recorded an annual load factor in excess of 100 percent. This was possible due to the continued high power operation of Unit I and the lower than predicted temperatures of the circulating water taken directly from the Atlantic Ocea Plant operations continued to be conducted in a professional manner with operators exhibiting a high degree of operating proficienc In general, the licensee's performance in the areas of procedural compliance and adequacy over the last SALP period and for most of this period was good to excellent. However, there have been some violations which indicate a slight decline in this are Violations (c) and (e) listed below, coupled with a similar l
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violation (a) in the Outage analysis, could be indicative of a programmatic weaknes These violations prompted additional licensee management attention to ensure the adequacy of procedures and procedure updates and the institution of measures to ensure that a major programmatic problem does not develop. A site Procedures Department has been established to implement a procedure review program. Administrative procedures have been developed to control the preparation, review, revision and approval of the upgraded procedures and to provide guidelines for the writing of procedure Emergency procedures have been rewritten utilizing the appropriate guide Off-normal and annunciator response procedures were being upgraded at the end of the SALP period. All operating procedures have been scheduled for upgrading after the completion of the off-normal procedures. The upgrading process includes detailed operating and multi-discipline reviews, Facility Review Group (FRG) review and Plant Manager approval. Several changes have also been incorporated into the design control process to ensure that potential problems dealing with procedure updates, as they relate to Plant Changes /
Modifications (PC/Ms), are adequately addresse A special inspection was conducted to assess the licensee's t compliance with Generic Letter 83-28, Required Actions Based on Generic Implications of Salem ATWS Events. Several deficiencies
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were identified in the post-trip review procedure implementation, indicating a possible lack of supervisory involvement in the post-trip review process. The licensee had identified several other deficiencies and had revised the procedure to improve its effectiveness. The revised procedure, if properly implemented,
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should resolve the program deficiencie For Unit 1, there were three reactor trips and there were three
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actuations of the engineered safety features (ESF); two of the trips were at power levels greater than 85 percen Unit l's reactor trip frequency of 0.26/1000 hours of operation compares very favorably to the current national average frequency of 1.1
. trips /1000 hours of operatio (See Section V.J for a further discussion of reactor trips.)
For Unit 2, there were sixteen reactor trips, six of whish were at power levels greater than 85 percent; there were six ESF actuations. Unit 2's reactor trip frequency of 1.54/1000 hours of
- operation was higher than the current n!.lonal average frequency.
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Both units had an availability factor of over 78 percent with Unit l's over 86 percent. As discussed earlier , Unit l's annual load factor was in excess of 100 percent for the period from September 1984 to September 198 . .
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Management's responsiveness to NRC and other initiatives was expeditious and thorough. The previous SALP noted weaknesses associated with the adequacy of information reported in Licensee Event Reports (LERs). Af ter consulting with NRC Headquarters and NRC Region II, the licensee successfully altered its methods of presenting information in LERs. Since implementing these changes early in this SALP period, LER descriptions and cause analyses have shown dramatic improvement. Events at St. Lucie are generally reported within the required time period following the occurrence. There were 43 LERs submitted during the evaluation period for both unit Near the end of this evaluation period (April 28,1986), a brief (one day) strike by the iron workers' union caused a shortage of plant operations persennel because some operators would not cross the picket line. Licensee management took prompt, positive action to assure adequate staffing of critical position The licensee has maintained a clean and efficient plant. During the period, added emphasis has been placed on plant cleanliness and a repainting program was initiated to improve plant preservation and appearance. Plant tour observations have consistently found housekeeping to be above average, even during periods of high outage-related activity. Housekeeping has been excellent during the latter part of the SALP perio Conduct of operations in the control room was generally excellen Plant management is quite sensitive to control room demeanor and quick to correct lapse The NRC's questions were always addressed in a prompt and courteous manner. Observations have shown that shift turnovers were adequate, with the relieving shift being properly briefed with information which could impact plant safety. Operators could almost always respond to inquiries about annunciators, plant or system status and lineups. Procedures for various annunciator responses and Technical Specification requirements for LCOs were consistently followed. The control rooms were always adequately staffed with an appropriate mix of talent and experienc The senior operators, Nuclear Plant Supervisors (NPSs) and their assistant ANPSs, are given an appropriate level of responsibility within the FPL structure, which, when combined with their experience, results in certain operational issues and management decisions being made at somewhat lower levels than normally encountered. This has had a positive effect on operator morale and has improved management efficiency -
in operations. Another contributor to management efficiency has been the use of the morning meeting, which is chaired by the NP Plant status for both units is reviewed, and planned evolutions and new problems are discussed. Additional meetings are then scheduled to address, in greater detail, particular problems and
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their solution Because all departments participate in these morning meetings, which are conducted by Operations, there is an atmosphere within the plant organization of supporting the plant's operation. This has resulted in other departments, such as Maintenance, being more readily available to respond to and support the needs of the Operations Departmen Five violations were identified:
! Severity Level IV violation for an inoperable containment isolation valve. (335/85-07) Severity Level IV violation for failure to properly align the instrument air supply to a main feedwater regulating valve after testin (389/85-10) . Severity Level IV violation for failure to adequately establish plant procedures which reflect the operating
! characteristics of the main steam isolation valve air supply solenoid valve logic control circui (389/85-20) Severity Level IV violation for failure to maintain two operable shutdown cooling loops during cold shutdown operations with the reactor coolant loops not fille (335/85-36) Severity Level V violation for an inadequate procedure update after a plant modificatio (389/85-17) Conclusion Category: 1 Trend: Declining Board Recommendations The board noted that Unit I was a superior performer and met the criteria for a Category I rating, however, Unit 2's performance was determined to fit the Category 2 rating. Based on the strong management involvement, an overall rating of I was deemed appropriat * Radiological Controls Analysis During the evaluation period, routine radiological controls inspections were performed by the regional and resident inspection i staff The regional staff also performed a routine secondary
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chemistry inspection, a special inspection involving a potential overexposure incident, and a confirmatory measureidents inspection using.the NRC Region II mobile laborator The licensee's health physics staffing level appeared adequate to support routine operations. - Additional contract health physics t
technicians were utilized to supplement the permanent staff during refueling outages. Health physics staff turnover was low during ,
the evaluation period. The licensee maintained a small technical staff on-site, with much of the health physics technical expertise i in dosimetry processing, solid radioactive waste classification and audits residing in the corporate health physics group. The audit program was, due to corporate office concerns, under review by the licensee at the end of the assessment perio During 1985, the licensee developed a formal training and qualification program for health physics technician The licensee has submitted the program to the Institute of Nuclear Power Operations and anticipates that accreditation 'will be achieved in the fall of 1986.
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The licensee submitted the required _ effluent and radiological
environmental reports. There were no unplanned radioactive liquid i or gaseous releases during 1985. Releases, while higher than regional averages for gaseous effluents, _were within the j prescribed limits of the Technical Specifications. 60,340 curies 1 (C1) of fission and activation gases and 0.98 Ci of iodine-131
- were discharged to the atmosphere in gaseous effluents from both units in 1985. The 1985 Region II averages for a two unit site (based on 12 operating PWRs) were .5260 Ci and 0.023 C1, respectively. Liquid effluents contained 5.5 Ci of mixed fission and activation products and 650 Ci of tritium. The 1985 Region II averages were 1.3 Ci and 780 C1, respectively.
' Of f-site doses calculated for_ liquid and gaseous effluents were
' within 10 CFR Part 20 and 10 CFR Part 50, Appendix I guideline For 1985 releases, the maximum calculated doses to a member of the public were 0.4 mrem from liquid effluents and 2 mrad combined gamma and beta dose from gaseous effluents. These calculated doses represented 8 percent of the 10 CFR Part 50 Appendix I" limits for liquid releases and 7 percert of the limits for gaseous release The consistently high gaseous effluent releases over a period of
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several years were caused by a higher than expected rate of fuel cladding perforation in both units. In 1985 and at present, most of the gaseous radioactivity has been from Unit 1. The licensee
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has utilized the Unit 1 gaseous waste decay tanks to full capacity and has been able to achieve holdup times on the order of 21 to 28
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days in an effort to employ available design features to minimize releases. It was also noted that the licensee has a formal leak reduction program which enabled the detection of leakage problems with the waste gas decay tank syste A deviation from the -Final Safety Analysis Report (FSAR) design criteria / objectives was identified during the evaluation perio Several reactor auxiliary building (RAB) doors were blocked open and the RAB ventilation system was improperly aligned, allowing unfiltered air to flow out of the RAB. The flow of air from areas of high potential radioactivity to ones of low potential radioactivity was possibl The corrective action taken by the licensee was effective in preventing a recurrenc The licensee's post accident sampling systems (PASS) were .
evaluated during the SALP period. Since the PASS installations in Units 1 and 2 were supplied by different vendors, the plant operators are required to be separately trained and qualified for each installation. The evaluation found the PASS installations operable for both units, and training and procedures were determined to be adequat A special NRC inspection reviewed the circumstances surrounding an inadvertent personnel exposure while conducting sludge lancing operations in a Unit I steam generator. It disclosed a weakness in the licensee's radiation protection program, in that informal memoranda and the experience level of the health physics technicians, rather than approved procedures, were relied upon to specify radiological protection requirements for maintenance activities which had high exposure potential. This dependency was, in large part, responsible for a Severity level III violation involving an overexposure to the upper arm of the whole body of a worker performing those sludge lancing operations. The licensee denied this violation, however, on July 11, 1986, the NRC rejected the bases for the licensee's denia Both the on-site and the corporate health physics staffs were involved in the resolution of the technical issues surrounding the overexposure incident. investigation and assessment was deficient in that it failed to adequately address the placement of dosimetry on the arm and the dose gradient in the steam generator handhol The respiratory protection and Radiat ftn Work Permit programs appeared adequate; however, one proposed violation was identified in that respiratory protection equipment issuance records were not addressed procedurally as requi ed by regulations, and consequently, none were maintained. This proposed violation was issued after the end of the SALP period and has not yet been responded to by the license , _ --. - - . _ - .
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Collective personnel exposure during 1985 was approximately 637 man-rem per reactor, which was somewhat above average (425 man-rem) for U.S. pressurized water reactors (PWRs), but is not considered significant in light of the extensive outage activity during the period. The projected collective dose for the facility in 1986 is approximately 300 man-rem per reacto From October 20 to December 31, 1985, 461 skin and clothing contamination events occurred. The number of skin and clothing contamination events was noted to decrease to 64 between January 1 and April 17, 198 Tracking of contamination control program ef fectiveness was begun by the licensee during the evaluation period. On February 1, 1986, the licensee had 46,565 square feet, or 35 percent of the radiation controlled area of the plant, controlled as contaminated. On March 31, 1986, the area controlled as contaminated increased to 51,042, or 38 percent of the plan It is too early to judge the effectiveness of the licensee's program for reducing the plant's contaminated are During 1985, the licensee disposed of 14,590 cubic feet of solid radioactive waste containing 796 curies of activity per uni This represented a significant decrease when compared to the 1984 figure of 21,625 cubic feet, which was unusually large due to the disposal of the Unit I reactor thermal shiel Packaging and preparation of radioactive material for transport off site was generally adequate. However, two apparent violations of Department of Transportation (00T) regulations were identifie The licensee failed to package radioactive material in a strong, tight container and the radiation levels on the external surfaces of two packages in a shipment exceeded the regulatory limi These violations may have been caused, in part, by a temporary reduction in health physics staff experience level brought about by personnel reassignments. The second violation was determined to be a Severity Level III violation, however, no civil penalty was assessed. These proposed violations were issued after the end of the SALP period and have not yet been responded to by the license The quality control program for radiological measurements met the general guidance of NRC Regulatory Guide 4.15. Some procedural deficiencies were identified however, in that detailed intralaboratory and interlaboratory crosscheck implementing procedures were not formalized. The results of the 1984 and 1985 NRC spiked sample crosscheck program for iron-55 were in disagreement. Generally, enforcement action is considered af ter three consecutive sample crosscheck disagreement Measurement discrepancies were also noted in various liquid media for
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manganese-54 and iodine-13 In the spiked particulate fi.lter, cobalt 57 was in disagreement, and all nuclides for the filter geometry exhibited a consistently high bia These results demonstrated the need for increased management involvement in the radiological measurements quality control program, to ensure th validity of measurements for quantifying' plant effluent Both units operated in a very stable manner during the evaluation period, enabling the control of secondary chemistry to a standard
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higher than the guidelines recommended - by the Steam Generator Owners Group. Implementation of an aggressive water chemistry program was a noted strengt The licensee was actively attempting to resolve an air ejector design problem which caused
, the concentration of air in the condenser hotwell to remain higher than desired, a'
One violation and one deviation were identified: Severity Level III violation for failure to establish radiological control procedures for steam generator work and failure to perform adequate- surveys (evaluations) of individual exposure such that one worker received an overexposure of the whole bod (335/86-01) Deviation from FSAR design criteria / objectives in that RAB doors were blocked ope (389/86-01)
Three additional proposed violations were identified during the SALP period. These violations were not issued until after the end of the SALP period and the licensee has not yet responded to the citation Proposed Severity Level IV violation for inadequate procedures addressing the maintenance of respiratory protection equipment issuance records. (335/86-09)
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Proposed Severity Level III (with no civil penalty) violation for failure to maintain radwaste shipment external radiation
levels within limits. (335/86-09)
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Proposed Severity Level IV violation for failure to package
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(335/86-09) Conclusion Category: 2
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. . Board Recommendations The Board noted a decrease in the effectiveness of the licensee's program for the transportation of radioactive material, which may
'have been caused, in part, by personnel changes which reduced the experience level of the health physics staff and by the lack of detail in transportation procedures. The licensee should give increased attention to this area, and the NRC should increase its inspection activit C. Maintenance Analysis '
During the evaluation period, inspections were performed by the resident and regional inspection staff Licensee management continued to seek improvements in the maintenance program, and emphasized adherence to procedural and regulatory requirements. This resulted in a decrease .in the number of violations identified during the SALP period. The excellent Unit 1 performance record since completing the repairs to the core support barrel and removing the thermal shield is another indication of the quality of maintenance activitie Maintenance staffing and training were adequat The plant work order (pWO) backlog at St. Lucie appears to be under control. The licensee subscribes to the Institute of
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Nuclear Power Operations guideline that no more than 50 percent of the outstanding PW0s be greater than three months ol In comformance with that guideline, the number of PW0s more than three months delinquent was noted to drop significantl The licensee's routine maintenance program utilizes a number of techniques to monitor equipment performance and analyze failure The program uses vibration analyses on mechanical equipment, infrared analyses on electrical equipment, oil analyses on selected components (e.g. , emergency diesel generators), and the Motor Operated Valve Analysis and Testing System (M0 VATS) to determine - the operability of motor operated valve These techniques have enabled the licensee to detect degrading trends in equipment performance and effect repairs before f ailures occu Management responsiveness to NRC initiatives remained at the previously established high levels discussed in the last SALP report and was evidenced by the continuation of the operating experience feedback progra Additionally, the licensee, on its ;
own initiative, has established a Quality Improvement Program
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(QlP) which encourages the direct involvement of craftsmen and technicians in achieving, maintaining and improving quality. The parti.ipation of these wurking level individuals has had a positive effect because they can make inputs to management and observe improvements brought about by their effort Maintenance activities involving the reactor coolant pump oil seals and anti-reverse rotation devices (ARRD) were also reviewe The degradation of these components were quickly identified and proper corrective action was promptly initiated. Site management readily committed to formal reports to the NRC as investigation and assessment results were compile A special inspection to assess the licensee's compliance with Generic Letter 83-28 raised concerns regarding the preparation, review, approval, and implementation of reactor trip breaker maintenance procedure The licensee's proposed corrective measures for these concerns were judged to be adequate. The licensee's programs for reactor trip system post-maintenance testing and equipment classification were found to meet the requirements of the Generic Lette No violations were identified during the assessment perio . Conclusion Category: 1 Board Recommendations .
The board noted that the Category I rating was based on a limited inspection effort which failed to reveal any significant deficiencie D. Surveillance Analysis During the evaluation period, inspections were performed by the resident, regional and headquarters inspection staff The regional staff performed inspections of the surveillance testing, calibration control and snubber surveillance programs, and the headquarters staff performed a special #hvironmental qualification program inspectio The surveillance testing programs appeared effective. Technical Specification surveillances were almost always completed in a timely manne No instances of u'.ing out-of-date surveillance procedures were identified during the evaluation perio Management involvement in staffing and training for operational surveillances continued to be adequat . .
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Though surveillance scheduling and implementing procedures were generally effective, four cases of missed surveillances, which occurred near the end of the evaluation period, indicated a program weakness in the scheduling of plant surveillances during the reassignment of plant personnel. The licensee identified these cases and has vigorously implemented measures to correct the missed surveillance problem. Plant Quality Control (QC) audited the departments responsible for conducting surveillances to ensure that an adequate and timely method or verifying the completion of surveillances existed within the responsible departments. This review determined that three of the nine departments involved in the performance of TS surveillances lacked scheduling procedures and two lacked an individual directly responsible to oversee or review the conduct of surveillances. The licensee has implemented three new scheduling procedures, and the two deficient procedures have been revised to include sign-offs for internal, departmental reviews. While the results cannot be judged at this time, it is expected that this added visibility and the delineation of responsibility will improve the conduct of surveillance testin A special inspection to assess the licensee's compliance with Generic Letter (GL) 83-28 found that trip system reliability testing met the intent of the GL. The licensee's trending program for critical reactor trip breaker parameters was found not to include all the parameters recommended by NRR, and their response to a request from NRR for more information on their trending program was not timel The calibration program was effective in maintaining current instrument calibrations. Problems were identified, however, in that gauges required for inservice inspection (ISI) calibrations were not included in the calibration program and the ISI vibration monitoring program was inconsistent. The remaining areas of this program appeared effectiv Snubber surveillance program planning was evident in the well-defined and written procedures. Policies were adequately stated and understood, and reviews were timely, thorough and technically soun Records of snubber inspection results were complete, legible and readily retrievable on a personal computer syste The resolution of problems encountered during snubber surveillance insoections (functional test failures) were conservative, timely, technically sound and thoroug Staffing, training and qualification of personnel involved in snubber surveillance were adequat A special inspection determined that the licensee had implemented a program to establish and maintain the environmental qualifica-tion of equipment within the scope of 10 CFR 50.49. Although there were some potential problem areas in procurement and
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maintenance, there were no findings affecting the safe operation
of the plan The findings were typical of findings during similar inspections at other Region II facilities.
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Two violations were identified: Severity Level IV violation for missed surveillances (four examples). (86-07/06) Severity Level IV violation for failure to correct battery
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specific gravity for electrolyte leve (85-08) Conclusion '
! Category: 1 Trend: Declining
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Board Recommendations The Board expressed a concern regarding the decrease in surveillance program effectiveness during a period of personnel transitio The same problem was noted to have occured in the
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radioactive waste transportation program and indicates a need for increased management oversight during future staf f change Fire Protection Analysis
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Durtig this assessment period, inspections of the licensee's
] routine fire protection and prevention program were conducted by i the regional and resident inspection staffs. In addition, a special Unit 2 inspection was conducted by the regional staff to assess the status of the licensee's implementation of the requirements of 10 CFR 50, Appendix The licensee's routine fire protection and fire prevention program was found to be satisfactory. The licensee has issued procedures
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for the administrative control of fire hazards within the plan Froni a fire protection standpoint, housekeeping and control of flammable materials were satisfactory. The -fire protection
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' extinguishing systems, detection systfms, fire barriers and
, barrier penetrations were found to be in service.
- Procedures for the surveillance inspection, ~ testing and main-tenance of the plant's fire protection systems and equipment
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, features have been satisfactorily tested and maintained.
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The licensee has also established procedures governing the organization and training of the fire protection staff and the fire brigade. The fire brigade training program was well defined and fully implemente The training and drills for the fire brigade members met the frequency specified by the licensee's procedures and the NRC's guideline The licensee has established an on site fire brigade training l facility, which presently consists of flammable liquid burn pits l utilized for portable fire extinguisher and small fire attack hose line training operation It is the licensee's intent to expand this facility in the future to include structural power plant firefighting and self-contained breathing apparatus training operation Fire protection staffing was adequate to accomplish the goals of the licensee's program. The fire protection staf f positions are i identified, and authorities and responsibilities are clearly j define The personnel assigned to these positions are well
qualified for their assigned dutie The organization and i staffing of the plant fire brigade met NRC guideline The inspectors reviewed the annual fire protection / prevention audit, the 24 month QA fire protection program audit by off-site organizations and the triennial audit by an outside fire l
protection organization required by the Technical Specifications.
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Tht se audits were conducted within the specified frequency and appeared to cover all the essential elements of the fire protection progra The licensee had implemented appropriate corrective actions for discrepancies identified by these audit During a routine inspection, the licensee's QA staff found that an l hourly fire watch required by the Technical Specifications had not
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been performed for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> during the bargaining unit walkout on April 28, 1986. The incident was reported as required, and the applicable procedures were revised to preclude recurrenc In preparation for the special Appendix R inspection the licensee identified, analyzed, and reported the Appendix R,Section III.G l discrepancies as required by Unit 2 operating license condition 2.c.1 In these reports the licensee stated that the require-l ments of Appendix R,Section III.G.2, had not been met in the Unit 2, Train "B" switchgear room and cable loft. The NRC l
l reviewed these reports and determined that the licensee-identified Appendix R discrepancies were significant with respect maintaining
' one train of safe shutdown capability free from fire damage. The licensee's compensatory actions and approach to resolving these discrepancies were, however, found to be satisfactor ._ _. . _ . - . _ _ _ _ . - - - _ _ _ ._ _ _ . _ _ _ _ ._.__ . _ _ _
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- In addition, the NRC's Appendix R ' inspection found that the
'
licensee's alternative shutdown procedure for fire in either the control room or the cable spreading room was in error. The two
'
- - procedural errors could have affected the safe implementation of
!
alternative shutdown capabilities on Unit 2. The licensee 'also failed to fully implement the control / cable spreading room
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alternative shutdown procedure required by license condition 2.C.13. The licensee demonstrated a clear understanding of the
, Appendix R alternative shutdown procedure issues, and their i approach to resolving these issues was technically sound,- timely
) and responsive to NRC requirement i l In general, management involvement and control in assuring quality
) in the routine fire protection program was adequate as evidenced i by the issuance and implementation of fire protection procedures
- that met the NRC's requirements and guidelines. The licensee's ;
- approach to the resolution of routine technical fire protection j issues indicated a clear understanding of the issues, and was i practically always technically sound and timely. Responsiveness j to NRC initiatives was technically sound and thorough in almost i d
all cases. In addition, violations against the routine fire
, protection and prevention program are rar j Three Appendix R related violations were identified:
] Severity Level III violation for failure to provide adequate j fire protection features for a safe shutdown system necessary j to achieve and maintain hot standby. (389/85-06)
- Severity Level IV violation for procedure errors which could
] affect the safe implementation of alternative shutdown j capabilitie (389/85-06)
i i Severity Level IV violation for failure to fully implement
] Appendix R. as required by license condition 2.c.1 ; (389/85-06)
i j Conclusion
j Category: 2 i Trend: Improving i e i 3. Board Recommendations
) No changes in the NRC's inspection resources are recommended.
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. Analysis During the assessment period inspections were performed by the regional and resident inspection staff This included one routine inspection and the observation of two annual emergency preparedness exercise The routine inspection found that the essential elements for emergency response were adequately implemente Walk-throughs
- conducted with plant staff members assigned positions of responsibility in an emergency showed that they were able to l recognize emergency action levels, correctly classify events, l develop correct protective action recommendations, and that they l were knowledgeable of off site notification method A l communication system that would allow prompt notifications and l communications to off-site agencies was in place and operabl The public information program appeared to provide necessary
'
information to the public in the form of brochures and through speaking engagements. An adequate system for shif t staf fing and l augmentation was provided through a duty officer / roster syste Walk-throughs of dose projection and assessment problems '
demonstrated the licensee's ability to promptly obtain acceptable l results, t
Although no violations, deviations, or significant negative findings were identified during the routine inspection, the licensee's demonstration of its ability to adequately implement i the emergency plan and procedures during the annual emergency l exercises showed a basic flaw in command and control. The 1985 l emergency exercise identified procedural conflicts in that the
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Emergency Plan and implementing procedures would not allow the Emergency Coor61nator to delegate the responsibility for emergency declaration, off-site notifications, protective action recommendations, and radiological dose assessment, while other documents permitted such delegation. The licensee was informed that these inconsistencies in the assignment of responsibility could potentially lead to corrfusion, duplication of ef fort, or non-performance of certain function The licensee did not correct this potential problem after the 1985 exercise.
<
The 1986 emergency exercise confirmed that these inconsistencies l remained. This resulted in actual fragmentation of command and control and contributed to the following problems:
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a failure to notify the NRC Operations Center of the General Emergency classification; i
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less than full involvement of the Technical Support Center (TSC) staff in accident mitigation;
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poor information flow to the Recovery Manager, including a delay of 45 minutes in informing the Recovery Manager that the : ore was uncovered; and
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a delay in the flow of information to the Emergency Operations Facility (EOF).
- . These difficulties developed during an exercise with a scenario
- that was not particularly taxing. The licensee acknowledged these j findings during the NRC critique following the exercise. During i subsequent discussions, the licensee's corporate emergency j planning staff proposed corrective actions, including procedural i revisions and special emphasis on communications training, which, j if properly implemented, should resolve the exercise problems.
j No violations were identified during the assessment perio . Conclusion i
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Category: 2 j Board Recommendations
l Additional licensee management attention is necessary to ensure l that the problems associated with the delegation of authority are
- resolved and do not recur during future exercise *
)t G. Security and Safeguards
! Analysis
!
j Inspections during this evaluation period were performed by the
- resident and regional inspection staffs.
l There was evidence of management involvement and control of the
! security program. Managerial interest and response to security-1 related issues and problems were generally technically sound and j consistent, demonstrating the existence of policies and procedures for control of security related activities.
y!
1 The licensee's security organization consists of a security management function and a contract guard force, i
! The security staff manning and performance capability is i considered adequate to implement the physical protection program l as committed to in the Physical, Security Plan despite a slightly i
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higher than normal turnover rate. The training and qualification of the guard force to perform routine security as defined in the training and qualification plan is also judged to be adequate.
l The contract guard force training officer is also utilized in a l compliance verification role.
.
Two apparent violations demonstrated the need for more security l awareness on the part of the technical and operational staff One violation, involving the failure to control access to vital equipment was initially identified by the NRC during the SALP period. AS a corrective action for this violation the licensee initiated a survey to revalidate all identified vital equipmen This survey, which was in progress at the end of the SALP evaluation period, led to the discovery of two instances in which equipment identified as vital in the Physical Security Plan was not enclosed within a vital area. This resulted in an additional apparent violatio The licensee's failure to detect these violations resulted from a lack of communication between the plant
, operating staff and security personnel, and inadequate procedures and training of security force members to recognize and respond
'
area barrier degradations.
t appropriately to vital These violations could have been avoided with better interfacing and cross-training between security and non security organization Both violations are under consideration for escalated enforcement actio Safeguards event reports were timely and accurate and adequately addressed appropriate corrective actions, the implementation of which account for the absence of repetitive incident Changes to the Physical Security Plan were submitted within the time frames specified in 10 CFR 50.54(p), and the licensee was responsive to NRC Region !! comments on those Plan revision The licensee's independent security program quality assurtnce auditors are permanently assigned unescorted vital area access and are aware of security requirements while conducting other audit : One violation was identified:
l Severity Level IV violation for failure to secure an unattended vehicl (85-01)
2. Conclusion Category: 2 l
3. Board Recommendations No changes in the NRC's inspection resources are recommended, l
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! H. Outages
) Analysis i
, During this evaluation period routine inspections were performed i by the resident and regional inspection staffs. Refueling was
- performed on both units. The regional inspection effort focused
,
on Unit I refueling activities and reviews of the licensee's
inservice inspection (ISI), inservice test (IST) and measuring and l
test equipment (M&TE) programs. Routine inspections ' by the
' resident inspectors addressed the areas of preparation for refueling, receipt and handling of new fuel, Unit I core support barrel inspection, steam generator eddy current testing, in-core instrument replacement, reactor cavity seal ring design and testing and refueling activities. All activities appeared to be j well manage !
Ouring this evaluation period, licensee management has continued to focus attention on preventive measures and planning in-an effort to anticipate occurrences. For example, the licensee is t
- continually planning for unscheduled shutdowns and outage A ;
- current list of action items requiring a made of operation other
than power operation is maintained, work packages are prepared and I parts are ordered in advance.
j When forced into an unplanned shutdown, there is little time wasted in planning and scheduling i this contingency work. This allows a clearer focus on correction ',
of the cause of the forced shutdown and minimizes the facility's i backlog of " shutdown items." Plant safety and reliability are j enhanced and the length of scheduled outages is shortened, i
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The licensee has been very successful in planning and implementing i j scheduled outages. Outages have usually been completed within a '
i few days of the schedule. Even when unexpected problems have
j occurred the licensee has demonstrated the necessary flexibility
'
to make schedule changes and still complete the outage within a reasonable time span. This was particularly apparent during the Unit 1 outage in the fall of 1985 when problems were encountered i in lif ting the upper guide structure. The licensee took actions
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to minimize the incidents impact on the critical path of the l outag <
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The Unit I core support barrel inspection revealed no degradation j in the repairs implemented during the p&vious refueling outage, j Fif teen damaged Unit 1 fuel pins were removed and replaced with j solid, unfueled pin Additional fuel failures have been
experienced since the unit was restarted in December 1985 and I indicate a possible inadequacy in the licensee's failure analysis, l
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The licensee did not se' arch for debris in the lower f'uel assembly grids until af ter the damaged pins were removed. This may have obscured any indications of potential debris-induced fretting in that are The licensee should implement a more detailed and disciplined search for fuel failure mechanisms during the next refueling outag While removing the Unit 1 core internals upper guide structure (UGS) in preparation for defueling, one of three lif ting rig attachments gave wa This placed the UGS and lif ting rig in a tilted position suspended about eight feet above the irradiated l
fuel. The licensee declared an unusual event in accordance with
! plant emergency procedures. It is believed that this failure was I caused by inadequate thread engagement on one of the three bolts which attaches the lif ting rig to the UGS. The bolt was assumed to be fully engaged when the torque limit specified in the procedure was reache The procedure was inadequate (see
! violation (a)) in that no independent verification method was l required to ensure that the bolt was not cross-threaded or otherwise bound, thereby creating a false seating indication.
l Management involvement was evident in the prompt and ef ficient l mobilization and direction of appropriate resources in designing,
! manufacturing, testing and employing a temporary lif ting rig for removing the UG These actons were taken in a timely manner to ensure that a potentially hazardous situation was corrected without unnecessary delay, while at all times maintaining controls l to ensure that an already tenuous situation did not degrade further and cause additional damag A regional inspector witnessed Unit 1 defueling activities from the control room, refueling floor and spent fuel pool area, and found that defueling was performed in accordance with the controlling procedur ,
Management involvement in refueling activities continued to be strong and effective, both during routine operations and during the unusual event described above. Total team refueling meetings were held twice daily and were effective in maintaining control of critical path refueling activities. Staffing during refueling met I
or exceeded the Technical Specification requirements. The one-day l strike on April 28, 1986, had little or no impact on the Unit 2 l refueling progress because of prompt management control and l
placement of personnel. Unit 2 completed its second refueling outage and returned to power on June 4, 198 Violation (c) involved a failure to install safety-related battery racks in accordance with approved drawings. This was considered to represent an isolated instance of inadequate drawing references in the Plant Change / Modification package and not a breakdown of the design change program.
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Licensee management involvement in 1'nservice inspection (ISI) and inservice testing (IST) activities appeared to be adequate and decision making was at a level that assured adequate management
, review. The ISI manual and implementing procedures continued to be upgraded by site and corporate management thereby improving
'
control of the ISI progra Because of a change in organization, the ISI Coordinator now reports to the Technical Department rather than the Maintenance Department. The effect of this change on the ISI organization has
- , not yet been evaluate Key positions within the organization were identified, and authorities and responsibilities were define The ISI manual now defines responsibilities for ISI work.
i The licensee's ISI/IST program reviews were timely, thorough and technically soun Records were complete, well maintained and available.
l A training program for all personnel involved in ISI was defined
'
and implemente One minor IST procedural violation (d) was identified during the evaluation period. The violation was not repetitive and is not indicative of a programmatic breakdown.
l l The regional inspection of the M&TE program found it to be adequate overal Some inconsistencies in documentation were noted and a violation was identified for a failure to control the environmental conditions in the calibration laborator Four violations were identified: Caverity Level IV' violation for inadequate procedure for removal of the upper guide structur (335/85-29) Severity Level IV violation for failure to provide adequate measures for e1vironmental conditions for calibration of M&T (85-16) Severity Level IV violation for failure to install safety-related batteries in accordance with applicable drawing *
(85-08) Severity Level V violation for failure to enter pump test status in control room " Pump and Valve Summary" boo (85-04)
_ _ _ _ - - _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ __
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. Conclusion f Category: 2 Board Recommendations ,
t No change in the NRC's inspection resources are recommende I I. Quality Programs and Administrative Controls Affecting Quality f i Analysis .
?
During this evaluation period, inspections were performed by the l resident and regional inspection staffs. The following areas were >
reviewed by the regional inspection staff: quality assurance (QA)
program review, audits, records, document control, QA/ quality control (QC) administration, 'of f-site support staff, and off-site review committee (Company Nuclear Review Board).
The licensee has instituted a Commitment to Excellence Program !
(CEP) which was a spin-off of the Performance Enhancement Program ;
at Turkey Poin The CEP included the following QA/QC '
enhancements:
-
increase QA staf f size (four additional positions to be - -
filled).
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increased QA personnel training,
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increased QA technical expertise (one recently hired QA i employee was a licensed operator),
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improved communication between QA and site personnel,
,- trend analysis and reporting, f
performance monitoring to address plant systems / hardware and
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real time operating activitie expanded QA and QC surveillance programs, and !
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QA audits to assure that CEP commitments are being me !
A number of QA implementing procedures have also been rewritten to :
more accurately reflect program requirements. Site personnel '
appeared knowledgeable about these program enhancement The implementation, scope, and findings of QA audits were found to be adequate. A problem was identified which reflected that audits of surveillance activities were not performed to the depth
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necessary to assure calibration activities were betng properly ,
performe This appeared to be an isolated example. Records and !
document control programs were assessed as adequate. The QA/QC administration was determined to be adequate. Closecut and corrective actions for NRC identified violations was timely, ;
The special inspection to assess compliance with GL 83-28 found licensee management to be actively involved in assuring quality j and to be reasonably responsive to NRC initiatives regarding i
reactor trip system operation, maintenance, testing, and reliabilit Management involvement was evident in the development, review, ano, in most cases, timely submittal of responses required by the GL, The off-site support staff program met existing regulatory requirements. The training of personnel appeared adequate to ensure technical competenc Interface between off-site and on-site staff appeared adequate. Greater efficiency in providing support services was achieved by assigning of f-site organizational staff to the site. The off-site review committee was adequate in fulfilling the function of the committee charte No violations were identified during the appraisal perio . Conclusion Category: 2 Board Recommendations
.
No changes in the NRC's inspection resources are recommende J. Licensing Activities Analysis During the SALP evaluation period, the licensee continued to show significant management overview in the area of licensing
!
activitie The licensee consistently balances the desire to l maintain or improve plant productivity with the need to protect i
the health and safety of the public. The majority of the l licensing actions completed during the SALP period were resolved by the licensing group. In the few insttnces where matters needed to be referred to upper management, the managers involved proved to be well-informed and helpful in resolving question Upper
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management has also become deeply involved in improving the quality of the work done at the plant by actively participating'in the development of a quality improvement program.. The licensee s management has continued to pursue a program that is aimed at
- improving and increasing the technical capability of the staff, l
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The licensee's submittals are most of ten timely and of high qualit In particular, the licensee's treatment of the no signiaficant hazards standards of 10 CFR 50.92 have shown a steady and marked improvement during the reporting perio There were some instances during the period when submittals were not made in a timely manner. This occurred most frequently on requests for action on items required for restart after refueling outages. The licensee needs to improve their performance in this area. The licensee also needs to improve in areas where
,
information or action is required on matters that do not have an immediate impact on plant operation. In particular, such areas include nonpriority items that are part of requirements generated by operating experience, Generic Letters, Information Notices, et The need for changes in the diesel generator Technical Specifications is a prime exampl With few exceptions, the technical content of submittals made in support of, or in response to licensee or NRC initiated actions is complete and thorough. Where additional information has been needed, it has been of a clarifying nature, for the most part, and l In many cases handled by phone with a confirmatory follow-up
! letter. Few, if any, licensee responses to NRC requests for additional information require subsequent question The licensee continues to maintain a significant technical capability in almost all engineering and scientific disciplines necessary to resolve items of concern to the NR During the
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report period, the licensee has expanded the staff at the plant site as well as the main office in Miami and the subsidiary office in Juno Beach. The licensee has also utilized the services of i nuclear support groups to assist in the resolution of technical l
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problems or to utilize both new and proven techniques that will enhance the operation and safety of the plan During this period, t9e licensee has decided to consolidate the majority of its nuclear engineering support staff into a single office complex in Juno Beac This consolidation should improve the support capability provided to the St. Lucie plant, particularly in the reduction in response time required to resolve technical issue Licensee management supported a number of NRC initiatives, most notably a site visit dealing with a residual heat removal generic issue. During the period, the licensee worked with the NRC in resolving a number of multi-plant and THI items. In each case, the licensee carefully evaluated the action in question and provided meaningful input to the NRC staff. Where differences of opinion havo occurred, the licensee has negotiated changes in requirements to insure that the results (Technical Specifications, for example) reflest the plant desig __ __ _ _ _ _ _ _
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The licensing group holds informal training sessions on topics of current and future interes The group also participates in corporate wide training programs such as, " Supervisor Training for Quality". The training program, measured by results, has been very effective during this rating period and is about to be evaluated by INPO for program accreditatio . Conclusion
.
Category: 1 1 Board Recommendations No changes in the NRC's inspection resources are recommende K. Training and Qualification Effectiveness Analysis No formal inspections of the St. Lucie training program were conducted during this SALP perio Routine inspections by the regional staf f did, however, touch on training of personnel in several specific areas, including health physics, fire brigade, security, ISI technicians, quality assurance staff, maintenance, and licensing. These inspections did not note any deficiencies in the areas reviewe Two sets of replacement operator licensing exams were administere Four of five senior reactor operator (SRO)
candidates and five of five reactor operator (RO) candidates l passed the oral and written examinations administered in February - March 1985. The oral and written examinations administered in December 1985 resulted in six of seven SR0 candidates and ten of ten RO candidates passing. The SRO and RO l
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passing rates of 83*. and 100*., respectively, were above the industry average, and provide evidence of management's involvement in the training process and in the screening of prospective license examination candidate Six new Shif t Technical Advisors (STAS) were qualified during the evaluation period, and there are presently four new STAS in the qualification progra ,
) A training simulator has been ordered and is scheduled to be
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installed by late 1986 in a new training facility which is
! currently under construction at the site.
No violations were identified during the appraisal perio . Conclusion Category: 1 l
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! Board Recommendations No changes in the NRC's inspection resources are recommended, i V. Supporting Data and Summaries l Licensee Activities
!
{ The scope of major outage work at St. Lucie was as follows:
l l
Unit 1 i 10/20/85 - 12/25/85 Scheduled refueling / maintenance, inspection of '
j core support barrel l
Unit 2
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j 10/12/84 - 11/19/84 Scheduled refueling / maintenance J 11/21/84 - 11/29/84 Turbine bearing problems
12/19/84 - 12/27/84 Condenser air leak
! 08/08/85 - 09/07/85 RCP seals, high vibration & oil leaks j
i 09/09/85 and 09/22/85 04/05/86 - 06/04/86 Scheduled refueling / maintenance
, Inspection Activities i
i The routine inspection program was performed during this period, with
] special inspections conductea to augment the program as follows:
)
J February 25 - March 5,1985, in the areas of liquid and gaseous radwaste management, environmental programs, and evaluation of NUREG-0737, Item II.B.3, Post-Accident Sampling System (PASS).
- February 25 - March 1,1985, in the areas of fire protection and the licensee's actions regarding the implementation of the i
requirements of 10 CFR 50, Appendix R, Sections III.G, II ! III.L and II ! July 8-12, 1985, concerning FPL's response to Generic Letter l 83-28, Required Actions Based on General Implications of Salem 3 Anticipated Transient Without Scram (ATWS)' Events. Areas <
inspected included: post-trip reviews, equipment classification, L vendor interface and manual controls, post-maintenance testing, i and reactor trip system reliabilit . August 19-21, 1985, on-site and in the General Office in the areas I
' of emergency preparedness, emergency response facilities, NRC response team coordination, and NRC hurricane response equipment, ;
coordination and procedure :
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_ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _
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, January 8-9, 1986, in reaction to a potential whole body radiation i
exposure in excess of 10 CFR 20 limits.
- . January 21-22, 1986, to follow-up on previously identified j findings in the area of fire protectio . March 31 - April 4,1986, in the area of equipment environmental qualification Licensing Activities l The basis for this appraisal was the licensee's performance in support i
of licensing actions that were completed during the current rating
- period. These actions consisted of amendment requests, exemption requests, responses to Generic Letters, TMI items and other actions, as l shown belo , Licensing Activities Completed During the SALP Period
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License Condition Compliance Concerning Heavy Loads (S j Lucie 2)
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Purge and Vent Valve Operability (St. Lucie 1)
1
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Environmental Qualification of Electrical Equipment (S ; Lucie 1)
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EXXON Nuclear Creep Collapse Methodology (St. Lucie 1)
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Control of Heavy Loads, Phase I (St. Lucie 1)
( -
Axial Growth of Fuel Rods (St. Lucie 2)
2 -
PASS Core Damage Assessment Procedure (St. Lucie 2)
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Control of Heavy Loads, Phase I (St. Lucie 2)
, -
Underground Cable Insulation (St. Lucie 1)
}
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Safety Parameter Display System (St. Lucie 1 & 2)
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Inadequate Core Cooling Instrumenta, tion (St. Lucie 1 & 2)
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NUREG-0737, Generic Letter (GL) 83-37 (St. Lucie 1 & 2)
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Code Error in EXXON Analysis (St. Lucie 1)
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LOCA Outline, Compliance with 10 CFR 50.46 (St. Lucie 1-& 2)
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Masonry Wal) Design (St. Lucie 1)
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Control of Heavy Loads, Phase II (St. Lucie 1 & 2)
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GL 83-28, Items 3.1.3 and 3.2.3 (St. Lucie 1 & 2)
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Use of Instrumented Inspection Technique (St. Lucie 1)
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ASME Code Update (St. Lucie 1 & 2),10 year Inspection
!
Interval (St. Lucie 1)
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Steam Generators GL 85-02 (St. Lucie 1 & 2)
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GL 83-28, Items 3.1.1, 3.2.1, 3.2.2, 4.1 and 4.5.1 (St. Lucie
- 1 & 2)
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GL 83-28, Item 1.1 (St. Lucie 1 & 2)
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15 Percent Steam Generator Tube Plugging (St. Lucie 1)
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GL 83-28, Item 1.2 (St. Lucie 1 & 2) '
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GL 83-28, Item 3.1.2 (St. Lucie .1 & 2) ,
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CE Large Break LOCA Analysis (St. Lucie 2)
- 2. NRR - Licensee Meetings
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November 9, 1984 Cycle 2 Reload
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June 4, 1985 Core Support Barrel _ Inspection Plan
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July 10, 1985 LOCA Error
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September 11, 1985 Cycle 7 Reload i
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September 24, 1985 Instrument Inspection Technique l -
September 26, 1985 Security System
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October 22, 1985 Rod Swap and Cycle 7 Technical
] Specifications
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October 30, 1985 LOCA Error (follow-up to July 10)
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December 18, 1985 Security System
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December 19, 1985 Detailed Control Room Design Review 1,
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February 4,1986 CSB Inspection Results i
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3. NRR Site Visits
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November 1-2, 1984 Cycle 2 Outage Activities, St. Lucie 2
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November 12-14, 1984 Cycle 2 Startup Testing and Plant Activities, St. Lucie 1 and 2
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December 10-13, 1984 Visit Concerning Generic Issue A-45
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February 25-28, 1985 Fire Protection Audit
.
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April 10-15, 1985 Site Visit Concerning Cycle 7 Planning, St. Lucie 1
-
June 19-20, 1985 Meeting with Region II to Discuss Licensing Actions
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October 6-11, 1985 Pilot Audit of St. Lucie SPDS
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November 17-22, 1985 Core Support Barrel Inspection and Cycle 7 Activities, St. Lucie 1
-
January 20-25, 1986 Appendix R and Generic Issue A-45 Reviews
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March 4-6, 1986 Security System
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April 20-23, 1986 Cycle 3 Outage Activities, St. Lucie 2, 4. Commission Briefings
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None 5. Schedule Extensions Granted
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None 6. Reliefs Granted
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April 2, 1985 IST of Pumps and Valves, St. Lucie 1
,
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January 13, 1986 IST of Pumps and Valves, St. Lucie 2 7. Exemptions Granted
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February 21, 1985 10 CFR 50 Appendix R - Fire Protection, St. Lucie 1
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' ' License Amendments Issued i St. Lucie 1
- -
' December 6,1985 License Amendment 69 - Changes required
'
by 10 CFR 50.72 and 50.73 and miscellaneous changes in definitions and administrative controls
-
December 12, 1985 License Amendment 70 - Change to linear heat generation rate LCO from a constant value to an axially dependent limit
-
January 15, 1986 License Amendment 71 - Allos. continued operation at rated ther power for a specific time following a dropped control assembly
! -
January 15, 1986 License Amendment 72 - Adds auxiliary
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feedwater actuation system instrumen-tation to the Technical Specifications St. Lucie 2
-
November 9, 1984 License Amendment 8 - Technical Specifi-cation changes associated with Cycle 2
-
March 1, 1985 License Amendment 9 - Allowed power increase from 2560 MWt to 2700 MWt
,
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March 15, 1985 License Amendment 10 - Changed valve tag
- numbers in continuous purge and
- station air system
-
October 17, 1985 License Amendment 11 - Modified surveil-
- lance requirements with regard to t reconnection of pressurizer heaters to
'
their respective buses ,
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November 14, 1985 License Amendment 12 - Limits the use of i the 8-inch containment purge system
-
December 6, 1985 License Amendment 13 - Changes required by 10 CFR 50.72 and 50.73 and miscel-laneous changes in definitions and ;
administrative controls
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April 28, 1986 License Amendment 14 - Changes to
, moderator temperature coefficient to 3 provide more operating flexibility and
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remove restrictive operational require- ,
ments above 70 percent power l
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. Emergency Technical Specifications Issued
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None 1 Orders Issued , .
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June 27, 1985 Order Modifying license confirming additional licensee commitments on emergency response capability
.(Supplement 1 to NUREG-0737)
1 Status of Licensing Backlog At the conclusion of the SALP period, the licensing backlog consisted of the following items:
St. Lucie 1 TMI Related 9 MPA 11 Plant Specific 7 St. Lucie 2 TMI Related 6 MPA 10 Plant Specific 16 Investigations and Allegation Review No significant investigations were conducted during this evaluation perio Escalated Enforcement Actions A Severity Level III (Supplement I) violation was issued on May 22, 1985, for failure to provide fire protection features to ensure that Unit 2 systems necessary to achieve and maintain hot shutdown conditions are maintained free from fire damage. A civil penalty was not imposed because FPL discovered the problem, reported it promptly, and took decisive action to preclude its recurrence, e A Severity Level III (Supplement IV) violation was issued on April 24, 1986, for failures to establish radiological control procedures for steam generator work and to perform adequate individual exposure evaluations during that work. A civil penalty was not imposed because of FPL's good prior performance in the area of concer .. .
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. One order was issued as noted in paragraph V.C.1 Licensee Conferences Held During Appraisal Period January 22, 1985 -
Management meeting in preparation for the 10 CFR 50 Appendix.R inspection March 28, 1985 -
Enforcement Conference regarding 10 CFR 50, Appendix R violations and inoperable containment isolation valves February 26, 1986 - Enforcement Conference to discuss a potential overexposure during steam generator sludge lancing Confirmation of Action Letters CAL 50-335/85-01 was issued on September 4,1985, to document the NRC's concurrence with FPL's commitment to administratively restrict the Linear Heat Generation Rate to 14.0 kw/ft for the remainder of Cycle 6 for St. Lucie Unit Licensee Event Report Analysis During the assessment period, 15 LERs for Unit I and 21 LERs for Unit 2 were analyzed by the NRC staff to determine cause. The distribution of these events was as follows:
Number of LERs Cause Unit 1 Unit 2 Component Failure 2 9 Design 2 -
Construction, Fabrication, Installation 2 1 Personnel
- Operating Activity 2 3
- Maintenance Activity 3 4
- Test / Calibration Activity 3 2
- Other Activity *-
Othe TOTAL 15 21 i
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I. Enforcement Activity Unit Summary FUNCTIONAL AREA NO. OF DEVIATIONS AND VIOLATIONS IN EACH SEVERITY LEVEL 0 V IV III II I UNIT NO. 1/2 1/2 1/2 1/2 1/2 1/2 Plant Operations 0/1 2/2 Radiological Controls (*) 0/1 1/0 Maintenance Surveillance 2/2 Fire Protection 0/2 0/1 Emergency Preparedness Security 1/1 Outages 1/1 3/2 Quality Programs and Administrative Controls Affecting Quality Licensing Activities Training Total 0/1 1/2 8/9 1/1 Facil.ity Summary FUNCTIONAL AREA NO. OF DEVIATIONS AND VIOLATIONS IN EACH SEVERITY LEVEL D V IV III II I Plant Operations 1 4 Radiological Controls (*) 1 1 Maintenance Surveillance 2 Fire Protection 2 1 Emergency Preparedness Security 1 Outages 1 3 Quality Programs and Administrative Controls Affecting Quality Licensing Activities Training Total 1 2 12 2 (*) Additional apparent violations' were issued after the end of the SALP period as discussed in the Radiological Controls analysi .
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. Three unplanned reactor trips and two manual shutdowns occurred during this evaluation period for Unit 1. Unit 2 sustained 16 unplanned trips and seven manual shutdowns. The unplanned trips are listed belo . Unit 1 December 19, 1984 - The reactor tripped from 100 percent power on a low steam generator (SG) water level signal. The
"B" diesel generator breaker was being racked out for inspection when a failed relay actuated the breaker's closing spring, closing the breaker and thereby motorizing the generato The ensuing electrical system realignment resulted in the loss of a main feedwater pump and the low SG level. The faulty relay was repaired prior to restarting the plan ' March 7, 1985 - The reactor tripped as a result of a suspected operator error while performing a routine reactor protection system logic matrix test. All systems functioned normally and the plant was returned to service in about seven hours. The trip was subsequently found to have resulted from a faulty matrix relay trip select switch (see next
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paragraph). February 6,1986 - The reactor tripped from full power while operations personnel were performing the monthly reactor protection system logic matrix test. The trip was caused by a faulty matrix relay trip select switch. The switch was replaced and the logic matrix test was successfully completed prior to restart of the uni . Unit 2 November 19, 1984 - The reactor was manually tripped from 20 percent power while conducting a plant startup. A condensate pump failure caused, a loss of a 4160 volt bus with numerous associated alarms and indications and the operator judged it prudent to manually trip the reactor. All systems functioned normally and the reactor was promptly restarted while the condensate pump was inspected and repaire _ November 19, 1984 - While conducting a recovery from the previous trip, a second reactor trip occurred because of a spurious high startup rate (SUR) spike. A 1.0 decade per minute (DPM) SUR was being maintained when a noise spike briefly increased the SUR above the 2.49 DPM trip setpoin The operators were subsequently cautioned to maintain the SUR at or below 0.5 DP i l
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c. November 21, 1984 - The reactor tripped from 68 ' percent power because of a turbine trip caused by a loss of main generator excitatio The generator field was lost as the result of a failed pedestal bearing on the generator's excite All systems functioned normally and the unit was returned to service after completion of exciter repair d. November 29, 1984 - The reactor tripped on a S3 low water level signal caused by a closure of the "B" main steam isolation valves (MSIVs). The MSIVs had received an isolation signal because of a blown fuse on the "A" safeguards chanae e. December 18, 1984 - The reactor tripped from'50 percent power on a SG low water level signal after an "A" main feedwater pump (MFP) trip on low suction pressure resulted in a total loss of feedwater flo The MFP trip was caused by improperly venting the "B" condensate pump while placing it l in service. Attempts to restart the "A" MFP before reaching the low SG level trip were unsuccessful. The "B" MFP, which was not operating at the time, started automatically but its
! ! solation valve breaker tripped on overcurrent before the valve stroked ope f. December 19, 1984 - The reactor. tripped from about 25 percent power as the result of a turbine trip on low condenser vacuum. A power reduction from 50 percent had been initiated to repair a cracked condensate pump recirculation line, but the line separated and vacuum was lost before repairs could be effecte The ensuing outage was extended to repair reactor coolant pump seals and safety injection valve g. April 8, 1985 - The reactor tripped from about 10 percent power while conducting a startup from a SG maintenance outage. Improper operator control of feedwater flow caused a SG low water level trip. All systems functioned normally and the unit was promptly restarted, h. April 8, 1985 - The reactor tripped from 15 percent power while conducting a recovery startup from the trip discussed above. Operating air to a main feedwater regulating valve (MFRV) was improperly aligned after performing-post-maintenance testing on the valve, causing the valve to fail open when placed in service. SG level increased to the main turbine trip setpoint, which, in turn, tripped .the reactor. A citation was issued for the failure to properly realign the system after testin _
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i. April 17, 1985 - The reactor was manually tripped from 99 percent power to prevent the loss of secondary system water inventory through open moisture separator reheater (MSR)
atmospheric relief valve An electrical spike, which occurred during maintenance on the digital electro-hydraulic (DEH) control system, somehow (unexplained) caused a spurious closure of all four turbine intercept valves (IV) thereby causing the MSR relief valves to open. The unit was restarted with the stipulation that future nonroutine DEH maintenance not be permitted at power. The IV closure feature has since been removed from the DEH circuitry for both St. Lucie unit j. April 17, 1985 - The reactor tripped from 20 percent power when improper manual control of SG water level during the recovery from the trip discussed in the previous paragraph resulted in a steam generator high water level turbine trip, which, in turn, tripped the reacto k. July 18, 1985 - The reactor tripped during performance of a ground isolation procedure at 100 percent power. An error in the operating procedure for DC ground isolation directed the operators to remove the fuses for the MSIV closure logic circuitry causing the "A" MSIV to close and the reactor to trip on asymmetric SG pressure. A citation was issued for failure to adequately establish and maintain the Unit 2 OC ground isolation procedur . August 8,1985 - The reactor tripped from full power when an incorrectly sized fuse in an electrical supply to the engineered safeguards actuation cabinet blew. This initiated a main steam isolation signal and a reactor trip on low SG water level. The reactor coolant pump seals were damaged during the transient because a containment isolation had interrupted component cooling water flow to the seals. The damaged seals were replaced during the ensuing outag m. September 9, 1985 - The reactor was manually tripped from full power when high vibrations occurred on reactor coolant pump (RCP) 2A2. RCP shaf t vibration had damaged internal components on the motor lower oil reservoir. The oil seal had previously failed on August 22 while attempting to recover from the pump seal repair *butage; additional damage was incurred during a minor oil fire on August 24. Repairs had been completed and the unit was returned to service on September 7, only to suffer recurrent RCP high vibrations on September 9. The oil seals and reservoirs were subsequently modified as recommended by the vendor to prevent recurrenc :
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41 January 7, 1986 - The reactor was manually tripped from full power when a turbine cooling water (TCW) leak developed in the main generator exciter housin The TCW leak was repaired and the init was restarted, January 7,1986 - The reactor tripped from 12. percent power
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while conducting a recovery from the previous trip described above. A power spike to above 15 percent occurred while synchronizing the turbine to the grid, causing the local power density reactor trip circuitry to automatically enable and trip the reacto Plant operating procedures were modified to caution operators to remain at low power until the axial shape index is favorable for power escalatio Janua ry 11, 1986 - The reactor was tripped from full power when an operator, who was conducting the weekly turbine overspeed trip mechanism test, erroneously operated the-
" Trip" lever instead of the " Test" lever; the turbine trip, in turn, caused the reactor tri The operator was counselled concerning his inattention to detail and the i
" Trip" lever was painted red to distinguish it from the
" Test" leve .
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