IR 05000335/1990027
| ML17223B062 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 12/27/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17223B061 | List: |
| References | |
| 50-335-90-27, 50-389-90-27, NUDOCS 9101230046 | |
| Download: ML17223B062 (29) | |
Text
ENCLOSURE INITIAL SALP BOARD REPORT
.
U. S.
NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NUMBER 50-335/90-27 AND 50-389/90-27 FLORIDA POWER AND LIGHT ST LUCIE UNITS 1 AND 2 MAY 1, 1989 - OCTOBER 31, 1990 qgpi23004b 90>~73 PDR ADOCK 05000335
I I
I
'I I
t
SUMMARY OF RESULTS During the assessment period, St.
Lucie continued to demonstrate overa'll superior performance.
Improvements were noted in the areas of Security and Radiological Controls.
A decline in performance was noted in the Maintenance/Surveillance area.
There has been considerable improvement in the area of Security.
Management has taken measures to improve security force motivation and
attrition rates.
Hardware improvements were also apparent, including an upgraded canal perimeter intrusion detection system and resolution of the canal underwater detection system issue.
Additionally, the licensee has taken action to resolve all concerns associated with the Regulatory Effectiveness Review.
As a result of these improvements, the need for compensatory measures has been reduced.
The Radiological Controls area has 'also shown notable improvement.
The licensee has taken aggressive action to reduce contaminated floor space.
Additionally, procedures for documenting and correcting program deficiencies have also improved.
In the Operations area, although it was rated a category I, a weakening performance was noted during the first half of the assessment period.
The licensee has taken effective actions to correct problems identified during the early part of this period.
By the latter part of the assessment period, Operations was performing at the excellent level noted in previous SALP assessments.
A decline in performance was noted in the Maintenance/Surveillance area.
Special NRC team inspections conducted during the period identified weaknesses within the maintenance program, particularly in the areas of work planning and maintenance procedures.
There were examples of equipment failures due to poor maintenance and/or lack of proper/
recoomended planned maintenance.
There were also examples of plant modifications being implemented by maintenance personnel without design approval or controls.
By the end of the assessment period, the licensee had taken appropriate measures to correct identified weaknesses and improve overall maintenance performance.
Overall, superior performance continues with no changes in the SALP ratings over the previous assessment period in the areas of Emergency Preparedness, Engineering/Technical Support, and Safety Assessment/
guality Verification.
All areas remain strong because of the licensee's ceanitment to excellence and dedication to self-identification and prompt correction of problems.
Facilit Performance Sugar Functional Area Rating Last Rating This Period Period Plant Operations (Operations 5 Fire Protection)
Radiological Controls Maintenance/Surveillance Emergency Preparedness Security Engineering/Technical Support (Engineering, Training 8 Outages)
Safety Assessment/
guality Verification (guality Programs 5 Licensing)
2 Improving
1
1
III. CRITERIA The evaluation criteria which were used, as applicable, to assess each functional area are described in detail in NRC Manual Chapter 0516.
This chapter is in the Public Document Room files.
Therefore, these criteria are not.repeated here, but will be discussed at the public meeting held with the licensee's management on January 11, 1991.
IV.
PERFORMANCE ANALYSIS II
~P1
l. ~Anal sls This functional area addresses the performance of activities directly related to operating the units, as well as fire protection.
These activities were observed during routine and special inspections throughout the assessment period.
St.
Lucie continued to demonstrate generally excellent day-to-day performance in plant operations, with few operational problems.
Management involvement in daily activities continued at the high level of the previous three assessment periods.
Effective staffing and procedure adherence have continued.
The process for scheduling of routine operational activities, the ownership of that process by the senior operators on shift, and the daily detailed quality control
.(gC) reviews have continued to be implemented effectively.
During the first half of this assessment period, some weaknesses in operational performance were noted.
Imprecise operation of the feedwater control system during startup resulted in three automatic plant trips.
One of these resulted from an inadequate procedure, one from a failure to follow a procedure sequence, and one from a missed communication while placing the turbine on line.
Additionally, during operator requalification exams early in the assessment period, deficiencies were noted in the operators'bility to use emergency operating procedure (EOP)
15, Functional Recovery.
EOP-15 is designed to assist the operators in mitigating unrecognized or multiple events. 'n response to these weaknesses, the licensee initiated corrective actions as described below.
A special operational safety team inspection (OSTI) was conducted at the end of a major outage during the middle of the assessment period.
In general, the team found that plant operations were well managed.
Monitoring of critical system parameters for adverse trends was noted as a strength.
However, the team also identified some weaknesses.
Unit 2 operators were desensitized to the high numbers of alarms, equipient tagged out of service, and instruments. reading in the warning range in the control room.
There were examples of operators being unaware of equipment status, and not being able to promptly deteraine the correct status from the Nuclear Job Planning System.
Operators were slow to acknowledge or reset annunciators during a
Unit I reactor startup observed by the inspection team.
Ouring other NRC-observed startups, operator response to annunciators or unexpected equipment behavior was noted to be timely and proper.
Prior to the OSTI and in response to the third feedwater control trip, a
number of licensee initiatives were undertaken to enhance operator awareness during plant manipulations and emergency response.
These initiatives, although not'ully successful at the time of the OSTI, resulted in substantial improvements by the end of the assessment period.
In addition to upgrading several operating procedures, licensee initiatives included:
maintaining an experienced independent supervisory senior reactor operator (SRO) in the control room in an advisory capacity during plant startup, shutdown, and power changes; stationing an SRO reactivity manager during reactor start-up; operator simulator practice prior to start-up; EOP improvements; and expanded EOP simulator practice for operators.
These initiatives and the licensee's construction and use of a site-specific simulator reduced operational personnel errors to a
low level by the end of the period, Late in the period, the ability of operators to effectively use EOP-15 was demonstrated during requalification examinations.
During several events, excellent operator responses were demonstrated.
Two manual reactor trips during the assessment per iod were prompted by an unisolable turbine hydraulic control fluid leak and by dropped control element assemblies (CEA).
Operator responses during these events were positive and professional.
A turbine runback was terminated and stabilized by proper operator, response without a plant trip.
guick analysis and response to a spurious letdown isolation during solid plant pressure control prevented the lifting of relief valves or the exceeding of procedural limits.
Operator performance during startups, power changes, and shutdowns was effective.
Control during reactor coolant system (RCS) reduced inventory conditions, as when installing steam generator (SG) dams,
'as also effective.
Operators often reinforced training by involving trainees in hands-on control during plant startups, shutdowns, and fuel movement.
Operator performance of major tests and surveillances was well planned; briefed, and executed.
On-shift and supervisory operators were instrumental in the successful conduct of a check valve slam reduction program and.in successful troubleshooting of heater drain pumps and associated valves.
Operator participation in the development of improved procedures for placing reactor coolant pump shaft seal stages in ser vice resulted in a reduction of premature'seal failures.
An inspection of the fire protection program was conducted during the assessment period.
Areas inspected included procedures, test results, training and staffing, equipment, and qual ity assurance (gA)
audits.
The performance of the fire brigade during an unannounced drill was also observed.
All areas were found to be excellent and no deficiencies were identified.
Fire brigade response to an actual
warehouse fire was observed to be prompt, professional, and effective.
Housekeeping was above average, excellent for a plant having many systems and components located outside and exposed to the elements.
Occasional examples of marginal housekeeping and control of transient combustibles occurred in scattered plant areas.
The weekly inspection by management started last assessment period, with its required corrective action list, continued to be effective.
A new management initiative produced significant strides in the material condition and minor discrepancy areas during the last half of the assessment period.
Assignment of a full-time supervisor and crew'to address material condition and minor. discrepancies produced positive results.
Five violations were cited in the Plant Operations area during this assessment period.
2. Performance Ratin Category:
3. Recommendations None B. Radiolo ical Controls l. ~Anal sls This functional area addresses activities related to radiological controls, radioactive waste management, environmental monitoring, water chemistry, and transportation of radioactive materials.
These activities were evaluated during routine and special inspections conducted throughout the assessment period.
The radiation protection program continued to be effective in controlling personnel exposures to radioactive materials and protecting the health and safety of the workers.
The licensee had no internal or external radiation exposures greater than regulatory limits during the assessment period.
Licensee audits of radiological protection program activities were more thorough than those performed during the previous assessment period.
The audit findings were substantive and identified deficiencies were corrected in a timely manner.
The procedures for documenting and correcting radiological protection program deficiencies were also improved.
Criteria for implementing the radiological protection corrective action program were expanded to increase their use and monitor additional radiation protection program trends.
However, expanded use of the corrective action procedure had not yet been effectively implemented.
in that it was
limited primarily to personnel'ontamination events with minimal documentation of, the corrective actions.
management support for the radiation protection program was demonstrated during the assessment period by the allocation of sufficient resources to significantly reduce the amount of radioactive material stored on-site and the purchase and use of remote monitoring equipment.
The number of personnel contaminations decreased during the 1989 por tion of the assessment period, but increased in 1990.
This increase was due primarily to the unusually high number of outage days during the period.
The licensee had planned for 95 outage days with both units refueling in 1990, but had 170 outage days due to outage extensions and unplanned outages.
The increased work activity also caused the collective personnel doses to rise in the 1990 period.
1989 1990 Collective Personnel Exposure (Person-Rem per Unit)
284 350 Personnel Contaminations 116 183 The 1990 increases in person-rem per unit and personnel contaminations did not indicate a decrease in the effectiveness of the personnel dose and contamination control programs.
Even with unplanned work activities, the collective personnel dose for 1990 was near the licensee's original dose goal.
The licensee implemented several dose reduction initiatives that were designed to improve their ability to identify, control, and reduce collective personnel dose.
Examples of applied As Low As Reasonably Achievable (ALARA) activities included:
underwater repair of a reactor coolant pump and underwater cleaning of the reactor head sealing surface, both reported to have saved considerable collective personnel exposures; use of guality Improvement Teams to reduce collective exposure by determination of source term reduction techniques and improved maintenance efficiency; and use of remote monitoring equipment.
A controlled shutdown reactor water cleanup procedure was performed whenever possible to remove radioactive contamination from the primary system.
The licensee continued to maintain contaminated floor space at a low level.
During the assessment period, the licensee was able to reduce the area contaminated from 8,000 - 10,000 square feet in 1988 to approximately 5,000 square feet in 1989 and 1990.
The licensee has included approximately 106,000 square feet in their contamination control program.
Contamination levels in the Unit 2 containment during the fall, 1990, refueling outage were low enough to allow access with minimal protective clothing for some activities.
Other radiation protection program and procedure improvements included:
guidance for determining curie content of various shipping
containers, improved document controls and reviews for radiation protection quality assurance records, qualification review and instructor training for vendor-supplied health physics general employee trainers, implementation of a task qualification program for vendor dosimetry technicians, and improved procedures for controlling access and work activities in high radiation areas.
The licensee's radiation protection staffing levels, including health physics (HP),
radwaste, and transportation, were sufficient to support routine and most outage operations.
The licensee made limited use of contract HP technicians to.supplement the permanent staff during outages.
The staff's experience level was good and there were no staff turnovers during the assessment period.
The overall quality, technical capabilities, and experience level of the HP staff and the program for reviewing and qualifying vendor HP personnel continued to be program strengths.
The licensee contracted radiation protection general employee (GET)
trainers to support the site's training program and improved the qualifications of those trainers with a training qualification program.
The training programs for general employee radiation protection (GET) and for HP technicians continued to be adequate and well defined.
Primary and secondary coolant chemistry was generally maintained within specified limits; when outside of limits, it was returned to within limits in a timely manner.
8oric acid chemistry control had been initiated in the Unit 1 secondary system subsequent to the most recent refueling outage in order to inhibit steam generator tube cracking near the tube sheet.
The Post Accident Sampling System (PASS)
for Unit I was out of service for a significant period of time from January through August, 1990.
The system was operationally tested and calibrated at the end of August and has been fully operational since then.
Unit 2 PASS was fully operational with the exception of dissolved hydrogen and oxygen analyses.
These parameters were obtained through grab sampling and laboratory analysis.
Management evaluation and control of effluent and chemistry programs were demonstrated through comprehensive gA audit and surveillance programs.
Liquid and gaseous effluent releases were within Technical Specification and 10 CFR 50, Appendix I, limits.
Two violations were cited in the Radiological Controls area during the assessment period.
2. Performance Rating Category:
3. Recommendations None
C. Maintenance/Surveil lance l. ~Anal sis Routine and special inspections during this assessment period were conducted to evaluate maintenance and surveillance activities, observe equipment condition, and provide an overview of the maintenance program.
A maintenance team inspection (MTI) was performed early in the assessment period.
It was directed toward evaluation of equipment conditions, maintenance control procedures, and the overall maintenance program; observation of in-process maintenance activities; and review of equipment histories and records.
The HTI concluded that the licensee had developed and implemented a
good maintenance program, although numerous program weaknesses were identified.
Strengths were noted in the areas of maintenance staffing, training, and qualification.
With the exception of the mechanical maintenance planning group, the maintenance organization was well staffed.
Maintenance craft and supervisory personnel were knowledgeable, had an enthusiastic attitude, and worked with management toward improving the maintenance program.
The maintenance management focus was to find problems and fix them prior to equipment failures.
The turnover rate among maintenance personnel was low and maintenance work was accomplished without excessive overtime.
There was good interface and communication between the maintenance staff and other organizations.
The maintenance training and qualification program was strong, except as noted below.
This program was accredited by INPO and was specifically designed to meet the continuing need for personnel to perform specialized plant maintenance tasks.
Training facilities were good.
Weaknesses were identified in the areas of maintenance work planning and maintenance procedures.
For example, preventive maintenance procedures were weak and instructions on some plant work orders were incorrect or incomplete.
The NRC staff attributed a cause of these problems to understaffing in the mechanical maintenance planning group.
Also, work planners had no formal training program.
In addition, procedures covering repair of major equipment were lacking; resulting in planners being required to research vendor manuals when planning repair tasks.
Vendor recottmendations had not been incorporated into some planned maintenance (PM) procedures.
Examples of PM procedures that failed to incorporate vendor recomendations were those for the new instrument air compressors, torque wrench calibration, the turbine driven auxiliary feedwater (AFW) pump, and the intake cooling water (ICW) deep draft pumps.
During a post-trip restart of Unit 2. the 2C AFW pump tripped and would not restart while cold.
A root cause of
this AFW pump failure to start was that the PM procedure had not implemented the vendor requirements for the governor PM.
Inadequate PM on the ICW deep draft pumps contributed to degradation of those pumps.
Vendor requirements were also not incorporated in those PM procedures.
In addition-to inadequate PM procedures, other deficiencies identified in preventive maintenance included lack of a program for testing molded case circuit breakers (MCCB).
A forced plant outage (manual trip) occurred early in the assessment period due to failure of an MCCB in a control element assembly power supply.
After that event, the licensee conducted extensive testing and replacement of the related vendor's circuit breakers, and identified a potentially generic problem.
During this assessment period, the licensee has added a technical support section in the maintenance group to reduce the workload of the maintenance planners.
The licensee has also taken action to evaluate all mechanical PM proce-dures and revise them as necessary to comply with appropriate vendor requirements.
In general, plant condition and housekeeping were good, with the exception of many minor deficiencies which had not been identified by the licensee.
The minor deficiencies included leaking valves; nuts with less than full thread engagement; missing fasteners on equipment, components, and panels; corrosion and coating deficiencies on various pieces of equipment and/or supports; missing equipment identification tags; and miscellaneous items loose in electrical equipment cabinets.
A violation was identified concerning missing protective covers on var ious environmentally qualified (Eg)
electrical control components.
The equipment deficiency tagging process included errors.
Some tags were missing from equipment that had deficiencies, and others were still hanging after repair work had been completed.
Also, the work order tracking system was not promptly updated to reflect work status, making it difficult for operators and maintenance personnel to determine the status of work in progress.
Several examples of plant modifications being implemented by maintenance personnel without design approval were identified.
These included plugging the Unit 1 component cooling water (CCW) heat exchanger tubes with rubber instead of the metal plugs specified by the vendor, changing the strainer size in the ICW pump cooling water which jeopardized pump operation,.
stowing the containment hatch bridge using restraints not in accordance with drawing requirements, and using incorrect pressure transmitter mounting brackets in some applications.
Five examples of use of unauthorized or incorrect materials while performing maintenance activities were identified in two cited violations.
Plant operations were affected by maintenance personnel errors.
A plant trip occurred as a result of a maintenance personnel error during reactor protection system maintenance.
A forced Unit 2 outage occurred as a result of a leaking pressurizer code safety valve mounting flange.
This leak was attributed to inadequate bolting practices while installing the flang Inadequacies were identified in the licensee's management of contractors.
This was primarily due to a
lack of technical oversight of contractor activities.
A violation was cited for failure of a contractor to follow procedures in valve maintenance.
A forced shutdown occurred during plant startup due to this inadequate contractor valve maintenance.
Other examples of lack of technical oversight of mechanical contractor maintenance included poor motor operated valve (HOV) overhaul on various systems and lack of adequate dust control during paint removal and painting preparation in various spaces.
Dust had to be vacuumed'rom inside the charging pump motors.
However, once these problems were identified, the licensee was aggressive in addressing them and resolving the concerns with increased management attention.
The routine Technical Specifications (TS)
surveillance program implementation was, for the most part, well done.
In particular, the programs for operations, chemistry, snubbers, in-service inspection, and pump and valve testing were well implemented.
Three routine TS surveillances were missed during the assessment period, each by a
different group.
Two were attributed to personnel error and one to procedural error.
The missed surveillances represented minimal safety significance and licensee corrective actions were comprehensive.
However, some examples were noted where documentation of surveillance activity was deficient.
Inappropriate data was recorded during surveillances on auxiliary feed pumps and emergency diesel generators, and technical reviews had not identified the problems.
A number of control room instruments were identified with incorrectly marked normal operating bands or readings that differed from other channels of similar instrumentation.
These instrument deficiencies could affect operator response to various events.
During the assessment period, the licensee took strong corrective actions in response to identified deficiencies in the following areas:
preventive maintenance, contractor performance, configuration design and material control, MOV repair, valve repacking, and attention to detail.
Corrective actions included clearer assignments of responsibility, personnel training, and improved procedures.
A number of engineers were hired to enhance the maintenance shop activities.
By the end of the period, improvements in these areas were noted by NRC inspectors.
Licensee control of scheduled major modifications and repairs during the assessment period was effective.
For example, the complex 1Al reactor coolant pump repair was particularly well coordinated and performed.
Other examples included:
the Unit 1 AFM pump overhauls, the Unit I high pressure safety injection (HPSI)
pump overhaul, the anticipated transient without scram (ATMS) modifications on both units, and refurbishment of CCW platform hangars on both units.
Licensee efforts toward improved control of equipment degradation, including exter ior corrosion and minor equipment deficiencies, were also noteworthy.
Increased licensee inspection and revised
assignment of plant area responsibilities contributed to improvements in material conditioh by the end of the assessment period.
Ten violations were cited in the Haintenance/Surveillance area during this assessment period.
R. ~Pf R
Category:
3. Receanendations None 0.
Emer enc Pre aredness l. ~Anal sis This functional area includes evaluation of activities related to the Emergency Plan (EP)
and implementing procedures, support and training of onsite and offsite emergency response organizations, and licensee performance during emergency exercises and actual events.
During the assessment period, one routine inspection and two annual exercise inspections were conducted.
One exercise included full participation, with state and local government involvement; the other was a small scale off-hours limited participation exercise.
The licensee provided excellent management support to the Emergency Preparedness program and sufficient staffing for response to an emergency.
Corporate management continued to demonstrate strong comaitment and support through direct involvement in the annual exercises and associated critiques.
Sufficient staffing levels for responding to an emergency were demonstrated during both emergency exercises.
An overall program strength was noted concerning the high level of knowledge and low personnel turnover in the emergency response organization.
The licensee continued to take initiatives regarding emergency preparedness issues, as demonstrated by prompt implementation of corrective actions in response to self-identified emergency preparedness exercise critique items as well as to inspection findings.
A licensee-identified deficiency involving differences between the Emergency Plan Implementing Procedure (EPIP)
classification table and the EP classification table was noted.
The differences resulted from a licensee change to the EPIP table that had not yet been, incorporated into the EP.
The differences were such that the same off-normal conditions could result in an event being declared per the EPIP table and not the EP classification table.
The emergency response facilities, which included the Operations Support Center (OSC), Technical Support Center (TSC),
and Emergency
Operations Facility (EOF), were maintained in an acceptable state of readiness.
During the two exercises, performance of emergency response personnel was observed to be superior.
The licensee demonstrated the capability to effectively assess, control, and mitigate postulated casualties presented to emergency response personnel during the emergency exercises.
All event classifications were timely and procedurally correct.
Initial and followup notifications to offsite agencies were timely.
Emergency response personnel training,
,including annual training, was completed in accordance with the EP.
Malkthroughs with selected EOF personnel demonstrated that they were fully aware of their responsibilities.
A detailed review of the St.
Lucie dose assessment program during the exercises found that corrective actions and improvements in response to a previous generic dose assessment finding at Turkey Point were implemented.
Exercise critiques were comprehensive and detailed.
The emergency preparedness program was independently audited by the licensee's gA organization.
The comprehensive audit emphasized emergency equipment and inventory documents.
No findings were identified.
gA comnents on the exercises were included as evaluation comments at the critiques.
During the assessment period, two EP changes were submitted for review.
Although Revision 19 changes were primarily administrative, Revision 20 changes involved a significant rewrite of the Emergency Action Levels (EALs).
The rewrite responded to the self-identified deficiencies described above and also reworded the EALs for enhanced clarity and ease of use.
Changes to the EP were timely and acceptable.
Four classifiable events, all Notifications of Unusual Events, occurred during this assessment period.
Review of the event reports found that classifications were correct and notifications were timely.
No violations were cited and no exercise weaknesses were identified in the Emergency Preparedness area dur ing this period.
2. Performance Ratin Category:
3. Recommendations None
E. Securit and Safe uards 1.
~Anal sls This functional area addresses security activities related to protection of plant vital systems and equipment, as evaluated during inspections and observations during the assessment period.
During this assessment period, the licensee implemented and managed a
superior security program.
Program oversight was provided by aggressive and knowledgeable security management.
The staffing level for the contract security force was appropriate.
Security force members were well motivated, knowledgeable, and capable in the performance of their duties.
An improvement during this SALP period in motivation and a
reduced security force attrition rate were attributed to management's institution of fixed day and night shifts and a promotion board using uniform standards.
Although the previous training program was effective, the recent conversion of the training specialist from a contract to a
permanent employee position has improved the functioning of the training staff in making recoomendations for program modifications and improvements.
Plant management continued to demonstrate an awareness of and a
strong supportive attitude toward physical protection requirements.
This was evidenced by support for and involvement in security tactical drills.
Contingency tactical drills appeared realistic and were conducted frequently to ensure that each shift was involved in a drill.
Additionally, the licensee had purchased a low-power laser engagement system which provided for more realistic exercises.
Significant improvements have been made in security system hardware components.,
The perimeter intrusion detection system at the discharge canal was upgraded with standard microwave to, enhance its reliability and performance.
The existing surveillance and assessment equipment was modified to improve its effectiveness.
A major accomplishment was the resolution of a long-standing issue concerning the underwater detection system.
The licensee proposed to replace the troublesome existing system with one of proven technology.
The installation of the new system is progressing on schedule for completion by February 28, 1991.
Another significant accomplishment was the completion of all actions necessary to resolve concerns identified during the Regulatory Effectiveness Review conducted the previous assessment period.
As a result of these improvements, compensatory measures have been reduced.
The licensee has provided the security force with effective procedures.
Security Plan changes were submitted on a timely basis.
Records were complete, well maintained, and readily available.
The licensee continued to log and report, as appropriate, physical security events in accordance with 10 CFR 73.71.
Licensee audits of the security program have been helpful in identifying deficiencies and providing recooeendations for improvements.
Although not inspected during this assessment period,
the licensee established a Fitness-For-Duty program, managed by the corporate security
'function, with an on-site supervisor who is responsible for the site program.
No violations were cited in the Security and Safeguards area during this assessment period.
2. Performance Ratin Category:
I 3. Recomnendations:
None F.
En ineerin /Technical Su ort 1.
~Anal sis This functional area addresses those activities associated with the design of plant modifications; engineering and technical support for operations, maintenance, testing and surveillance, outages, and procurement; and licensed operator training as reviewed during routine and special inspections conducted during the assessment period.
Effective engineering support of the plant staff was demonstrated in several performance areas.
Involvement in the plant deficiency reporting program was timely and adequate.
Technical support for the maintenance organization was good during the assessment period.
Engineers were permanently assigned to the maintenance organization.
Technical support for routine plant activities was demonstrated by ownership of several surveillance programs, including:
containment penetration leak rate, pump and valve, in-service inspection, and snubber programs.
As a result of involvement in surveillance activity, engineering identified a long-standing setpoint discrepancy related to Unit
degraded grid undervoltage relays.
Design engineering effectively addressed St. Lucie applications of 8ulletin 88-04 regarding potential safety-related pump loss.
A program was initiated to render vendor manuals more user-friendly for the plant staff.
Outage support was demonstrated by completion of 98 percent of Unit 2 outage scheduled design change packages 60 days before outage start.
Engineering root cause evaluation and corrective action activity was effective.
Root cause evaluation of equipment failures included the Unit I reactor building overhead crane, low pressure safety injection (LPSI) suction valve, Unit I reactor coolant pump, and Unit
Auxiliary Feed System HOV actuators.
Corrective action was timely and adequate for NRC-identified deficiencies related to the mounting design of compressed gas cylinders and design documentation of instrumentation mounting configurations.
In response to repetitive problems with the Control Element Drive Mechanism Control System (CEDHCS),
an engineer was specifically dedicated to resolve the issu Control of the design change program was adequate.
Modifications were appropriately developed and implemented in most cases.
Post modification testing was effective.
The modifications to improve reliability of the waste gas system demonstrated effective design change activity.
There were several exceptions that involved maintenance or construction personnel making unauthorized and uncontrolled modifications.
Examples included:
ICW pump suction strainer modifications, compressed gas cylinder installations, improper mounting of instrumentation and class lE equipment, improper mounting of hydrogen sampling system contairment isolation valves, and installation of improper nuts and gaskets on the 1A ICW pump.
These examples indicate insufficient engineering support in the maintenance work planning process.
The licensee has taken corrective actions to resolve this problem, including the assignment of engineers to the maintenance department.
Engineering demonstrated an internal self-assessment capability.
Activities included periodic performance reviews of architect/
engineer and other vendor engineering services, audits of engineering packages, and a calculation quality monitoring program.
As a result of self-assessment activities, a methodology was developed to more effectively process minor design change activity.
An independent contractor was used to assess FPL's coomercial grade procurement program.
Technical and engineering support of licensing activities was of high quality throughout the evaluation period.
This was evidenced by well-prepared documentation and sound engineering judgement reflected in the proposed solutions to the various technical issues.
The licensed operator initial and requalification training programs were effective, as demonstrated by examination results.
Initial examinations were administered to 5 SROs, with 4 passing, and to one RO who also passed.
The requalification program was rated satisfactory, based on an 85 percent pass rate.
Seven of 10 SROs,
of
reactor operators (ROs),
and 4 of
crews passed requalification examinations.
Minor weaknesses were identified in the requalification examination performance related to informal communications and selected EOP usage.
No deficiencies were identified in simulator performance.
No violations were cited in the Engineering/Technical Support area during this evaluation period.
2. Performance Ratin Category:
3. Recomnendations None
G. Safet Assessment/ ualit Verification l. ~Anal sis The assessment of this functional area is based on a review of licensee implementation of safety policies; activities related to license amendments, exemptions, and relief requests; responses to Generic Letters, Bulletins, and Information Notices; resolution of safety issues; reviews of plant modifications made under
CFR 50.59; safety review comnittee activities; and use of feedback from self-assessment programs and activities.
These activities were reviewed during routine and special inspections and communications during the assessment period.
The licensee's senior management has continued to be involved in monitoring and assessing plant performance and operations.
Involvement included daily control room visits; presence during field activities such as plant startup, major maintenance, and tests; weekly material inspections; and monthly evaluation of performance indicators against site goals.
Hanagement also increased their personal involvement in certifying containment conditions after outages and in setting the tone for aggressive corrective actions.
Ouring this assessment per iod, gA and over sight functions were strong
- identifying many worthwhile findings.
The licensee's quality program identified and initiated corrective actions on over
significant findings, as well as a
number of lesser concerns.
The findings included licensee self-identification of approximately
violations of NRC requirements.
The quality activities producing these findings included routine audits, performance monitoring of a wide spectrum of operational and maintenance activities, review of NRC violations on a national basis, vertical slice audits, and audits of the corrective action program.
Additionally, previously strong programs, such as cmmitment audits and routine gC audits of control room activities, continued.
The employee concern program was upgraded in April, 1990, and renamed the Speakout Program.
The corporate Speakout manager was located in the Juno Beach o'ffice, repor ting directly to the Vice President, Nuclear Assurance.
The St.
Lucie Speakout supervisor answers directly to the corporate manager.
A special team inspection of the Speakout Program found that it was effective in identifying and resolving employee safety concerns, had strong management support, and was a significant improvement over the earlier program.
The licensee's dedication and comitment to conservative plant operation were demonstrated when Unit 1 developed a small leak from the primary-to-secondary side through one of the SG tubes.
Even though the leak was well below the TS limit, the licensee shut down the plant and entered a refueling outage approximately three weeks ahead of schedule.
However, in one case concerning a generically identified potential for a
safety significant control element assembly failure mode, the licensee was slow in addressing the issu Corrective actions for NRC findings were generally technically adequate.
This was'videnced by the correction of technical and human factors deficiencies identified during a previous emergency operating procedures inspection.
One exception was a failure to take adequate corrective action for a previously identified deviation.
This involved the failure to document justifications for EOP step deviations from the NRC-approved plant specific guidelines, and fai lure to perform a technical'eview of step deviations prior to implementation of the EOPs.
Improvements were made in the procedures for performing safety evaluations required by
CFR 50.59 and in the program for root cause analysis.
FPL adopted EPRI guidelines for
CFR 50.59 evaluations, issued a
new guidance document, and trained site engineers in its use.
An NRC audit of 10 CFR 50.59 reviews found improvement in documentation quality.
Also, Licensee Event Reports continued to be of high quality.
They were thorough, detailed, generally well written, and easy to understand.
In most cases, the root cause of the event was clearly identified and the corrective actions were thorough.
A number of license amendment requests were made as a result of the NRC's ongoing Technical Specification Improvement Program including:
pressure/temperature curves, steam generator low level setpoints for Unit 1, diesel generator specifications, axial shape index for Unit 1, boric acid concentration reduction, and a number of administrative updates.
Other major accomplishments were completion of the licensing documentation for modifications to comply with the ATWS rule and documentation of the status of resolved Generic Safety Issue and Unresolved Safety Issue implementation.
The licensing documents from FPL were typically of high quality, demonstrating a
thorough understanding of technical issues and a
conservative approach to safety.
The submittals rarely required clarification and were always timely.
When extensions of due dates were needed, requests for them were also timely.
The No Significant Hazards Evaluations accompanying amendment requests were complete and well prepared.
Licensing activities exhibited evidence of assignment of appropriate p'riorities, adequate management review, and full management support.
The licensing staff maintained excellent lines of cooeunication with the NRC.
Reviews of the activities of the Independent Safety Engineering Group (ISEG) indicated that a number of ISEG findings had not been resolved and there was not an aggressive program to address these findings.
In addition, audit reports were not issued in a timely manner.
The licensee implemented corrective actions to improve performance in this area.
The Facility Review Group (FRG)
was very active at the site.
Reviews of safety issues by the FRG were excellent.
Minor
weaknesses were noted in the administration of the program, including lack of a formal cooeent resolution method and lack of detail in meeting minutes.
One violation was cited in the Safety Assessment/guality Verification area during this period.
2. Performance Ratin Category:
3. Reconeendations Hone V.
SUPPORTING DATA A. Licensee Activities Unit 1 began and ended the assessment period in an operational mode.
The unit was shut down for a refueling outage from January 22 to April 23, 1990.
A number of shutdowns occurred before and after that outage due to equipment and maintenance problems, including a major reactor coolant pump repair.
For the period, Unit 1 experienced a relatively high availabi lity of about 66%, considering the refueling and reactor coolant pump outages.
Unit 2 began the assessment period in an operational mode.
A number of shutdowns were caused by equipment failures and operational problems.
It was shut down on September 30 for a refueling outage, which extended through the end of the period.
Unit 2 experienced a high availability of about 91% during the period.
B. Direct Inspection and Review Activities During the assessment period, 38 routine, 3 special, and no reactive inspections were performed at St. Lucie by the NRC staff.
The special inspections included:
Haintenance Team Inspection Emergency Operating Procedures. Inspection followup Operational Safety Team Inspection C. Escalated Enforcement Actions l. Orders 2. Civil Penalties None
D. Licensee Conferences Held During Appraisal Period Hay ll, 1989 Meeting held at NRC headquarters to discuss licensee's steam generator tube plugging September 6,
1989 September 13, 1989 November 1, 1989 November 8, 1989 December 6, 1989 December 22, 1989 February 28, 1990 July 11, 1990 August 30, 1990 September 20, 1990 September 24, 1990 Meeting held at NRC headquarters to discuss modification of the CE-1 critical heat flux correlation Meeting held at NRC headquarters to discuss safeguar ds issues Meeting held at NRC headquarters to discuss Regulatory Guide 1.99, Rev. 2, methods for calculation of irradiation damage function Meeting held at NRC headquarters to discuss potential pressurizer heater sleeve cracking problem Meeting held at NRC headquarters to discuss probabilistic risk analyses Meeting held at NRC RII office to discuss emergency operating procedure EOP-15 Meeting held at NRC headquarters to discuss safeguards issues Meeting held at NRC headquarters to discuss probabilistic risk assessments Meeting held at NRC headquarters to discuss station blackout requirements Meeting held at NRC headquarters to discuss the licensee's TS amendment request for increased resistance temperature detector (RTD) delay time Meeting held at RII office to discuss the licensee's assessment of their performance E. Confirmation of Action Letters None F. Reactor Trips and Unplanned Shutdowns Unit 1 experienced three unplanned reactor trips and six unplanned manual shutdowns during this evaluation period.
Unit 2 experienced three unplanned reactor trips and four unplanned manual shutdowns
during the period.
The unplanned trips and manual shutdowns are listed below.
1. Unit
Reactor Trips July 17, 1989:
The unit automatically tripped on low steam generator level from 15% power during restart from an outage.
The unit was restarted early the following day.
September 13, 1989:
The unit automatically tripped due to maintenance activities on the reactor protection system and was down for 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />.
Hay 24, 1990:
The unit was manually tripped in response to a turbine hydraulic control fluid leak on the number three governor valve and was down for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for repairs.
Unplanned Reactor Shutdowns June 28, 1989:
The unit was manually shut down for 19 days for steam generator tube plug repair and replacement.
Oecember 27, 1989:
The unit was manually shut down for 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> to repair a leaking one-inch drain off the lA main steam. line.
January 22, 1990:
The unit was manually shut down to repair a tube leak in the 1B steam generator.
The unit remained down to start the scheduled refueling outage early.
May 3, 1990:
The unit was manually shut down for 5 days to repair power operated relief valve block valves.
July 2, 1990:
The unit was manually shut down for 36 days to repair a leaking reactor coolant pump seal.
August 7, 1990:
The unit was manually shut down for 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> due to a reactor coolant pump heat exchanger control valve malfunction.
2. Unit 2 Reactor Trips June 27, 1989:
The unit automatically tripped on high steam generator level and was down for 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />.
September 23, 1989:
The unit was manually tripped due to five control rods dropping, and was down for 4 days.
January 14, 1990:
Ouring a return to full power, the unit automatically tripped due to operator error.
The unit remained down for 39 hours4.513889e-4 days <br />0.0108 hours <br />6.448413e-5 weeks <br />1.48395e-5 months <br /> to repair the 2C auxiliary feedwater governor valv Unplanned Shutdowns June 26, 1989:
The unit was -manually shut down for 27 hours3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br /> to repair a reactor coolant pump oil level transmitter.
January 4,
1990:
The unit was manually shut down for 10 days for minor leak repairs of two valves in the pressurizer cubicle area.
August 11, 1990:
The unit was manually shut down for 6 days to repair vibration in the number nine turbine bearing.
August 20, 1990:
The unit was manually shut down for ll days to repair vibration in the number nine turbine bearing.
G. Review of Licensee Event Reports During the assessment period, a total of 24 LERs were analyzed.
The distribution of these events by cause, as determined by the NRC staff, is as follows:
Cause Component Failure Design Construction, Fabrication, or Installation Unit 1 or Coneon Unit 2 Personnel Error
- Operating Activity
- Maintenance Activity
- Test/Calibration Activity
- Other Other ota Note 1:
lith regard to the area of "Personnel Error," the NRC considers lack of procedures, inadequate procedures, and erroneous procedures to be classified as personnel error.
Note 2:
The "Other" category is comprised of LERs where there was a
spurious signal or a totally unknown cause.
Note 3:
One additional LER was voluntary and not considered in this report.
Note 4:
The above information was derived from a review of LERs performed by the NRC staff and may not completely coincide with the licensee's cause assignment H. Licensing Activities During the assessment period, the staff completed 66 licensing actions, while 43 new actions were opened.
Twelve of the closed actions were license amendments and two were exemptions from 10 CFR Part 20.
I. Enforcement Activity Functional Area o.
o evsations an so at ons n
Each Severity Level Dev.
V IV III II I
Unit 1/Unit2 P ant Operations Radiological Controls Maintenance/Surveillance Emergency Preparedness Security Engineering/Technical Support Safety Assessment/equality Verification 4/3 2/0 8/9 0/0 0/0 0/0 N
L
1 OVERALL TOTALS 18