IR 05000335/1992006

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SALP Repts 50-335/92-06 & 50-389/92-06 Covering 901101 to 920502.Category 1 Rating Assigned in Areas of Plant Operations,Radiological Controls,Emergency Preparedness, Security & Engineering/Technical Support
ML17227A482
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 06/12/1992
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML17227A480 List:
References
50-335-92-06, 50-335-92-6, 50-389-92-06, 50-389-92-6, NUDOCS 9207010289
Download: ML17227A482 (36)


Text

EN L

RE INITIALSALP BOARD REPORT U. S. NUCLEAR REGULATORY COMMISSION

REGION II

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NUMBER 50-335/92-06 AND 50-389/92-06 FLORIDA POWER AND LIGHT ST LUCIE UNITS 1 AND 2 NOVEMBER 1, 1990 - MAY2, 1992 92070102B9 920hi2 PDR ADOCK 05000335

P 'AQ

~NN OF CONT NT

~pa e

I.

INTRODUCTION...............................................

,1 II. SUMMARY OF RESULTS........................................,

III. CRITERIA..........-........................................

IV. PERFORMANCE ANALYSIS A.

B.

C.

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E.

F.

G.

Plant Operations......................

Radiological Controls.................

Maintenance/Surveillance..............

Emergency Preparedness................

Security..............................

Engineering/Technical Support.........

Safety Assessment/guality Verification

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V. SUPPORTING DATA A.

B.

C.

D.

E.

F.

G.

H.I.

Licensee Activities...................

Direct Inspection and Review Activities Escalated Enforcement Actions....,....

Licensee Conferences..................

Confirmation of Action Letters........

Reactor Trips.........................

Review of Licensee Event Reports......

Licens>ng Activities..................

Enforcement Activity..................

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INTROOUCTION The Systematic Assessment of Licensee Performance (SALP) program is an integrated Nuclear Regulatory Commission (NRC) staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance on the basis of this information.

The SALP program is supplemental to normal regulatory processes used to ensure compliance with NRC rules and regulations.

It is intended to be sufficiently diagnostic to provide a rational basis for allocation of NRC resources'nd to provide meaningful feedback to the licensee's management regarding the NRC assessment of their facility's performance in each functional area.

An NRC SALP Board, composed of the staff members listed below, met on Hay 28, 1992, to review the observations and data on performance, and to assess licensee performance in accordance with Chapter NRC-0156,

"Systematic Assessment of Licensee Performance."

This report is the NRC's assessment of the licensee's safety performance at St.

Lucie Units 1 and 2 for the period November 1,

1990, through Hay

, 2, 1992.

The SALP Board for St. Lucie was composed of:

J.

P. Stohr, Director, Division of Radiation Safety and Safeguards (DRSS),

Region II (RII) (Chairman)

A. F. Gibson, Director, Division of Reactor Safety (DRS), RII J.

R. Johnson, Deputy Director, Division of Reactor Projects (DRP), RII M. V. Sinkule, Chief, Reactor Projects Branch 2, DRP, RII S. A. Elrod, Senior Resident Inspector, St. Lucie, DRP, RII H. N. Berkow, Director, Project Directorate II-2, Office of Nuclear Reactor Regulation (NRR)

J.

A. Norris, Senior Project Manager, St. Lucie, Project Directorate II-2, NRR Attendees at SALP Board Meeting:

K. D. Landis, Chief, Project Section 2B, DRP, RII J.

P. Potter, Chief, Facilities Radiation Protection Section (FRP),

ORSS, RII T. Decker, Chief, Radiological Effluents and Chemistry Section (REC),

ORSS, RII W. H. Rankin, Chief, Emergency Preparedness Section (EP),

DRSS, RII R.

P. Schin, Project Engineer, Project Section 2B, ORP, RII M. A..Scott,.Resident Inspector, St. Lucie, ORP, RII R.

B. Shortridge, Senior Radiation Specialist, FRP, ORSS, RII R.

P. Carrion, Radiation Specialist, REC, DRSS, RII F.

N. Wright, Senior Radiation Specialist, EP, DRSS, RII W. J. Tobin, Physical Se'curity Specialist, Safeguards Section, DRSS, RII

.

G.

R.

Wiseman, Reactor Inspector, Test Programs Section, DRS, RII

'

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SUMMARY OF RESULTS During this 18-month assessment period, St. Lucie continued to demonstrate overall superior performance.

Improvements in the areas of Maintenance/Surveillance, Plant Operations, and Engineering/Technical Support enabled Unit 2 to be operated continuously in a safe manner for 502 days.

St. Lucie continued to demonstrate excellent day-to-day performance in the Plant Operations area with minimal operational errors.

Strong management attention to corrective action, personnel performance, training, improved pre-job planning, and enhanced supervisory oversight during infrequently performed evolutions helped plant operations to excel.

Continued improvement was noted in the area of Radiological Controls.

As Low As Reasonably Achievable (ALARA) initiatives remained a program strength which contributed to effective control of overall dose exposure.

Significant improvements were made in both procedures and hardware for controlling external and internal exposure, access to high and very high radiation areas, and contamination control.

Aggressive programs for dose reduction and radwaste volume reduction were maintained.

Improvements were noted in the area of Maintenance/

Surveillance, especially in maintenance quality, reduced personnel errors, work procedures, training, planning,.interface with other organizations, and in reducing equipment failures.

The overall material condition of the pl'ant was noticeably improved and was quite good.

The Emergency Preparedness program was maintained at a high level of proficiency and readiness as demonstrated by management support, staffing commitment, improvement initiatives, and good facilities and equipment.

Strengths were observed in the two evaluated emergency exercises and there were no identified weaknesses.

Continued implementation and management of a superior Security program was observed and supported-by numerous program improvements such as the Security Force Upgrade Program, completion of the Intake Canal Intrusion Detection System, and improved access control.

The Engineering/Technical Support area was characterized by improvements in design control and integration, erosion/corrosion monitoring and reduction, enhanced equi'pment reliability, defect trending for steam generator tubes, exceptional correction of Electrical Distribution System deficiencies, and timely problem identification and resolution.

Performance in the Safety Assessment/guality Verification area continued at a high level.

Management involvement was very effective in monitoring and assessing plant operational performance and outage activities, following technical or safety issues, evaluating industry experience, quality assurance audits, thorough self-assessments, good root cause analysis, thorough corrective actions, and high quality licensing

submittals.

Overall, superior performance continued, as exemplified by the high rating in all SALP functional areas.

All areas remained strong because of the licensee's continued commitment to excellence, reduction of opportunities for error, and dedication to self-identification and prompt correction of problems.

This was facilitated by a strong management team and a well qualified, experienced staff.

Facilit Performance Summar

A Rating Last Rating This Period Period

. Plant Operations (Operations S. Fire Protection)

Radiological Controls Haintenance/Surveillance Emergency Preparedness Security Engineering/Technical, Support Safety Assessment/

equality Verification I

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III. CRITERIA The evaluation criteria which were used, as applicable, to assess each functional area are described in detail in NRC Hanual Chapter 0516.

This chapter is in the'ublic Document Room.

Therefore, these criteria are not repeated here, but will be presented in detail at the public meeting to be held with licensee management.

IV. PERFORMANCE ANALYSIS A. Plant 0 erations I. ~na1 sis I

This functional area addresses control and performance of activities directly related to operating the unit, as well as fire protection.

St. Lucie continued to demonstrate excellent day-to-day performance in plant operations, with minimal operational problems.

Hanagement involvement in daily activities continued at the high level exhibited during the gast four assessment periods.

One exception, early in the SALP period, involved improper valve lineup verification which resulted in a failure to maintain operability of the Unit 2 Containment Spray (CS) System.

Strong management corrective action and increased focus, on personnel performance helped operational performance to excel throughout the remainder of the perio The operator error weakness that was apparent in the first half of the last evaluation period was not apparent during this period.

Operations efforts effectively reduced trip's and off-normal conditions.

= During the previous SALP period, there were six unplanned trips and ten unplanned shutdowns between the two units.

This SALP period showed a significant improvement, with three unplanned trips and one unplanned shutdown.

The reduction in

. personnel errors allowed Unit 2 to be operated continuously and safely for 502 days after startup from refueling, almost the entire SALP period, before shutting down for the next'refueling.

Unit I had several minor events early in the evaluation period, but has operated without a major transient since startup from refueling in December of 1991.

Careful operation was used to minimize operator errors.

An additional supervisory Senior Reactor Operator (SRO)

was assigned in the control room during unit startup, shutdown, and major power changes.

Also, an SRO was stationed in the control room as reactivity monitor during reactor startup.

Procedures and operator awareness continued to improve.

Log books were routinely legible, accurate, and reflected plant status.

Shift turnover in the control rooms improved because of management emphasis, especially when an infrequently performed activity was imminent.

In summary, the operations staff took the initiative to reduce the likelihood of operational problems throughout the evaluation period.

This, combined with day-to-day management and staff attention, produced exemplary plant operation.

Nevertheless, some events did occur due to operator errors.

For example, an inadequate valve alignment and verification caused a required locked open Component Cooling Water (CCW) valve to be inadvertently locked closed.

That resulted in a loss of CCW to the 2A shutdown cooling heat exchanger and inoperability of the CS system.

Weekly valve position verifications conducted by non-licensed operators failed to detect the mispositioned valve for five months.

In another instance, a non-licensed operator improperly paralleled Control Element Assembly Motor Generator (CEA MG) sets, causing scram breakers to open on overcurrent and a resultant reactor trip.

Licensee responses to these operational events were well considered and positive, producing excellent policy, procedure, and equipment changes.

Formal interface processes were used to minimize operational problems caused by other activities, sucli as maintenance.

The operations group improved pre-job planning, formal pre-evolution briefings, and the Sensitive Systems Program work review process during this period.

They continued the effective process for scheduling routine operational activities, emphasized senior operator ownership of that scheduling process, and continued the daily detailed quality control review.

Equipment failures were reduced by coordinated scheduling of maintenance and by enhanced preventive maintenance.

For example, the maintenance retest was combined with the surveillance test, thereby reducing duplication of effort and the opportunity for undesired events.

Experienced non-

licensed operators were designated as area specialists focusing on troublesome support systems such as the liquid and gaseous waste systems, the water plant, and the hypochlorite system.

These systems now operate better, with expedited'roblem resolution.

Operators'ggressive pursuit of proper actions and controlled operation of plant components generally prompted similar performance from other groups.

However, there were still a few,examples of poor control of equipment, when three radiation monitors and an Engineered Safety Feature (ESF) actuation channel were inappropriately out of service when required to be in service.

These examples were identified and promptly corrected by the licensee.

Throughout the assessment period, the operations staff exhibited excellent management and supervisory oversight and technical control of operational processes.

Control room drawings and procedures were routinely updated by the clerical staff.

Drawings in use were observed to be accurate.

Management attention was focused on minimizing entries into and time in Technical Specification (TS)

Limiting Conditions of Operation (LCOs).

The licensee made plant changes to reduce nuisance alarms in the control rooms.

Lighted annunciators were reduced to about six per unit.

Operations management and staff actively participated in efforts to improve operating procedures.

Examples include the development of shutdown cooling controls beyond those requested by Generic Letter 88-17, the operations manager being personally involved in a dry run of emergency containment closure prior to entering a Unit 1 reduced inventory condition, and making further improvements in the reduced Reactor Coolant System (RCS) inventory control procedures.

The controlling procedures were rewritten, used to train personnel, and were successfully used during two refueling outages.

8etween outages, the procedures and associated operator training were expanded and made highly interactive to further improve their effectiveness.

Although there have been some minor RCS nozzle dam seal leaks, no operational problems occurred while at reduced inventory.

Operators recognized some operational problems, aggressively addressed them, and prevented potential events from occurring.

Examples are:

during a Unit 1 refueling, loss of containment integrity was recognized by an SRO; a small Unit 1 letdown leak was identified at a boundary valve after the hanging of clearance tags; a Unit 2 hot leg injection check valve leak was quickly identified and resolved; and Emergency Core Cooling System (ECCS)

sump level changes were promptly identified as caused by an open (though checked closed) drain valve on a reactor drain tank pump being returned to service.

Control Room operators also demonstrated alertness and proper responses to operational events.

During problems with the Unit 1 heater drain pumps, operators realized the condition and tripped the reactor prior to safety system challenges occurring.

When a Unit 2 main circulating pump failed, operators

took prompt actions and closely monitored reactor and secondary plant parameters to ensure unit safety.

Operator actions were excellent during a Unit I reactor trip caused by a maintenance personnel error.

Each of these events was well controlled.

Operators were observed to use Emergency Operating Procedures with rigor and familiarity.

Subsequent corrective actions were very thorough.

Operations management has been effective in filling licensed and non-licensed operator positions to maximize staffing levels and assure proper qualifications of personnel on shift.

They have implemented improved formal processes for selection of SROs and Shift Supervisors.

Current staffing is six positions (entry level auxiliary operators)

short of the full 144 staff complement - with 12 new non-licensed operators and 2 new licensed operators in training classes.

Hoth licensed and non-1'icensed operator staffing is sufficient for six-shift rotation (up from five during the last

.

SALP period) with the exception of the auxiliary operator position.

Operator experience level remained high, as the turnover rate of all operating personnel was very low.

The licensee routinely evaluated plant problems with regard to possible labeling improvements.

Although the majority of plant equipment has been labeled, the licensee's plant labeling pr'oject continued to find and label additional items that should be so identified.

These included potential plant trip sources, and items or areas requiring the Sensitive Systems Program process.

A temporary tagging process and procedure was developed to positively identify new valves.

The quality of operator training was evidenced by the excellent operator performance throughout the assessment period.

Trainees received detailed on-the-job training from operators using actual drawings and procedures.

During an operational performance inspection of the Intake Cooling Mater (ICM) system, a number of both licensed and non-licensed operators were found to be extremely knowledgeable when interviewed concerning responses to routine and off-normal events and details of system operation.

Some discrepancies were identified in operator training material, which indicated a program weakness in maintaining the material current.

Fortunately, this training material weakness did not appear to affect operator performance because of the extensive on-the-job training.

Fire protection at the plant continued to be excellent during this evaluation period.

The licensee demonstrated a solid program through participation in numerous fire drills, vigorous pursuit of flammable materials control, and maintenance of plant material condition.

Dedication to continued fire protection program improvement was demonstrated by the start of construction of a "burn house" for fire training to simulate plant situations.

During the assessment period, problems were found with a late compensatory fire

watch and a lack of control of combustibles in a crew box.

These were isolated instances for which effective corrective action was taken.

2.

During the SALP period, there were two violations cited in the Plant Operations area.

erformance Ratin 3.

Category:

I ecommendations None B. Radiolo ical Controls

~nal sis This functional area addresses activities directly related to radiological controls and primary/secondary chemistry control.

The radiation protection program continued to be effective in controlling personnel exposure to radioactive materials (ALARA) and protecting the health and safety of plant personnel and the public.

The licensee maintained an experienced, qualified staff in radiation protection through effective training and a low turnover rate.

A sufficient number of licensee and contractor ANSI-qualified health physics (HP) technicians were available to cover radiological operations in both outage and non-outage periods.

Through management support for advanced technician training, the licensee had nine HP technicians certified by the National Registry of Radiation Protection Technicians.

Significant improvements were made in techniques for controlling external exposure.

The licensee purchased and implemented telemetry with electronic digital alarming dosimeters and air sampling devices, which enabled them to remotely monitor and control the radiation and airborne exposure of 64 people at one time.

By use of a computer, the time required to issue radiation work permits was reduced.

Also, the licensee videotaped areas and components to support pre-job briefings.

Closed circuit television cameras were provided to monitor jobs in progress and to videotape jobs for use in future tr aining.

To improve the control of high radiation areas, the licensee developed new procedures and implemented flashing red warning signs.

In addition, locking hardware was improved on ladders and manways leading to very high radiation areas.

Collective dose in the previous assessment period was 415 person-rem per unit with 199 outage days, compared to 274 person-rem per unit this assessment period with Ill outage days.

The slight increase in

collective dose per outage day this period was attributed to the increase-in steam generator maintenance and reactor coolant pump work during the.assessment period. 'he licensee effectively maintained an aggressive program of dose reduction.

For example, during refueling, reactor cavity water filtration was maintained inside the reactor cavity and filters were changed out under water.

Also, roughing filters were used in the reactor cavity drain to prevent highly radioactive material from getting into plant piping systems.

The program to control contamination at its source has been

. aggressively supported by plant management.

The licensee documented 226 personnel contamination events (PCEs)

in the previous assessment period with approximately 5,500 square feet (ft') of the 106,000 fthm radiologically controlled area (RCA) maintained as contaminated.

Through heightened worker awareness and an aggressive decontamination program, the number of PCEs in this assessment period was reduced to 107 and the contaminated portion of the RCA was reduced to approximately 3,850 ft.

The licensee's respiratory protection program was satisfactory.

There were no uptakes during this period that required evaluation.

During this assessment period, the licensee changed the procedure for identifying/documenting radiological performance deficiencies to use lower thresholds 'for deficiencies.

This has resulted in improved use of the system.

Hanagement evaluation and control of effluent and chemistry programs were demonstrated through comprehensive Quality Assurance (QA) audit and surveillance programs during this assessment period.

For the current SALP period, St. Lucie liquid and gaseous effluent releases showed no significant changes from the previous period and were well within limits,(TS,

CFR 20, and

CFR 50).

One unplanned release (although it was monitored)

was identified in the reporting period.

It occurred when the outlet valve of a Gas Decay Tank (GDT) was not fully seated, allowing part of its contents to be released, while the contents of another GDT were being released per the generated release permit.

The mixed release was monitored in its entirety, and no limits were exceeded.

A new meteorological tower was erected which incorporated upgraded instrumentation and other unique features.

These features included a lightning.suppression system to minimize lightning damage and a

hoist system to allow the three instrument platforms to be lowered for maintenance and/or calibration instead of requiring a technician to climb up the tower to the instrumentation.

Post-Accident Sampling System (PASS) availability was a problem during the previous assessment period, but was impro'ved during this assessment period.

Except for the dissolved hydrogen analyzers, PASS availability exceeded ninety percent during this assessment

period; Replacement of the old unreliable hydrogen analyzers with newer models continued during this period.

Alternate hydrogen sampling capability was available during the entire period.

The licensee has established a good radiochemical analysis program.

The confirmatory measurement comparison results showed good agreement between the licensee and the NRC mobile lab.

Primary and secondary coolant chemistry was maintained well within specified limits, with one exception.

While hydrolasing the Unit

reactor vessel flange, an estimated 1000 gallons of potable water (instead of the required demineralized water)

was introduced into the refueling cavity, resulting in a measured chloride concentration of 226 ppb.

This exceeded the TS limit of 150 ppb.

An engineering evaluation was done to analyze the chloride effects on the nuclear fuel assemblies and on the remainder of the RCS wetted surfaces (those exposed to reactor coolant)

and concluded that no degradation to RCS integrity or fuel assemblies resulted from this event due to the relatively low chloride concentrations, low system temperature, and its short'duration.

This event is further discussed in the Maintenance/Surveillance section under management of contractors.

A chemistry problem contributed to contaminated fuel oil entering the fuel storage tanks of the Emergency Diesel Generators (EDGs).

Although the fuel oil delivery trucks and fuel storage tanks had been sampled and tested at the specified times, the test methodology was not transcribed correctly from the ASTM standard to the licensee's test procedure, resulting in an incorrect reagent being specified.

The procedure consistently y'ielded total particulate concentrations less than the actual value.

The incorrect analysis contributed to three of the four EDGs being technically declared inoperable due to high total particulate content in their fuel storage tanks.

However, the EDG fuel filters maintained practical EDG availability.

The licensee's response in evaluating and correcting this problem was effective after confirmation of the unsatisfactory condition.

The Radiological Environmental Monitoring Program was conducted in accordance with TS requirements and supplemental sampling and analyses were performed.

Review of environmental data revealed no unusual offsite radiation levels as measured by the indicator instruments and samples.

The licensee had previously initiated a Volume Reduction Program to reduce radioactive waste'generated for burial.

A steady reduction in the volume has been experienced since the program's inception, enabling the licensee to reduce its volume buried from 11,221 cubic feet in 1989 to 6,432 cubic feet in 1991.

One violation was cited in the area of Radiological Controls during this assessment perio. Performance Ratin 3.

Category:

I Recoreaendations None C.

aintenance Surveillance

~nal sis This functional area addresses activities related to equipment condition, maintenance, testing, and surveillance.

In addition to routine inspections, three special inspections were conducted:

an Electrical Distribution System Functional Inspection, a Service Water Inspection, and a Hotor Operated Valve Inspection.

During this assessment period, the licensee made significant strides in improving maintenance quality, reducing personnel errors, improving the interfaces between maintenance and other organizations, and reducing equipment failures.

These efforts included:

improved organization and resources, such as permanent assignment of more field engineers to the various shops; more stringent maintenance control policies and processes; better coordinated maintenance and engineering efforts to reduce failure probability; and improvements to equipment physical condition.

A recurring management theme has been to ensure that observed problems and failures are corrected such that they do not recur.

These efforts contributed to improvements in plant performance.

Reactor trips were reduced from six during the previous SALP period to three in this period.

One of the three was caused by a maintenance personnel error in managing a lifted lead in a tight work area while

'removing a malfunctioning steam generator level instrument.

This event was pivotal in accelerating the development of the Sensitive Systems Program.

Unplanned shutdowns were reduced from ten during the last SALP period to one during this SALP period.

The licensee recognized that effective administrative control measures were needed to reduce the probability of certain events due to existing equipment or instrument configurations.

The new Sensitive Systems Program was improved following the Unit I trip caused by a maintenance personnel error.

The maintenance staff adopted this new program, which included maintenance staff pre-job preparation and management review of critical evolutions prior to commencing the maintenance activity.

During the last evaluation period, a weakness was identified in maintenance procedures.

Since then, the overall quality of maintenance work procedures has improved.

Preventive maintenance (PH) procedures have grown significantly in number and have been improved by maintenance engineering review.

Thirty-five new major

e

equipment overhaul procedures were issued or are in the review process.

Haintenance procedures in the areas of service water and motor operated valves were licensee strengths.

However, two instances were noted during this period where procedure quality contributed to work problems:

Hain Steam Safety Valve setpoint adjustment and Hain Feedwater Isolation Valve nitrogen addition.

A weakness in mechanical maintenance planning and quality of work orders was noted during the last SALP period.

Better procedural guidance for work planning, combined with the improved maintenance procedures, contributed to improved planner efficiency, production, and morale during this assessment period.

Maintenance planners subsequently provided more complete work instructions, resulting in a notable reduction in problems with plant work orders.

In addition, a contractor has beg'un to formulate improved planner training, which is scheduled to begin during the next SALP period.

During the last evaluation period, several cases of maintenance personnel making unauthorized modifications to the plant were identified.

Hanagement attention to this problem, improvements in maintenance procedures and work orders, and additional field engineers resulted in unauthorized modifications being almost eliminated during this assessment period.

One exception was a

containment pressure sensing line that was disabled by being capped inside the containment building.

This cap caused one of the four channels of containment pressure input to the Reactor Protection System and the Engineered Safety Features Actuation System to be inoperable.

The condition existed for over 18 months without being discovered by the licensee.

The licensee was unable to determine how the improper cap was installed, but did find that there had been no related maintenance work authorization.

Although improvement was made in the quality of maintenance work, there were several examples of lack of adherence to work control procedures.

Starting work without getting prior SRO permission resulted in a loss of containment integrity during refueling.

Flammable materials were left unattended in the cable spreading room.

Other instances of not following work control procedures included use of unapproved procedures for preventive maintenance of the 2C Auxiliary Feedwater (AFM) Pump governor, use of improper thread sealant in safety-related applications, failure to restore the 1B ICM missile shield after maintenance, failure to change a

plant work order post-maintenance test of the 2B EDG field control circuits, and repairing an electrical breaker latching relay without an approved procedure.

Host of these examples were licensee identified, and "all were prom'ptly corrected with no significant safety consequences.

Hany maintenance strengths were noted during this assessment period.

The electrical distribution system (EDS) was well maintained, as demonstrated by the excellent material condition of the electrical cabinets and equipment.

A comprehensive program for the

maintenance, testing, and calibration of EDS equipment and switchgear had been established.

The preventive maintenance performed to detect failed molded case circuit breakers was especially noteworthy.

Preventive maintenance and diagnostic programs such as thermography and motor vibration trending were detecting equipment problems in time for early repair.

Hany equipment problems were identified as a result of planned maintenance activity, and these often resulted in equipment modifications or upgraded planned maintenance requirements.

Examples were the implementation of a required overhaul schedule for circuit breakers based on a nine-year age cycle rather than operating cycles and the replacement of critical parts in safety-related inverters and battery chargers.

The overall material condition of the plant was noticeably improved and was very good.

A material condition supervisor and staff were assigned.

They immediately corrected many small degradations and identified major ones for more extensive correction.

The maintenance department, in conjunction with the engineering division

'nd corporate office, aggressively pursued outdoor environmental corrosion problems.

The licensee developed a new plant maintenance coating specification to enhance the coatings program and reduce outdoor structure corrosion.

As a result, corrosion problems have decreased.

The maintenance training program continued to be strong.

Training facilities and programs in the'area of motor operated valves were good.

Haintenance training materials in the area of service water were thorough and of high quality.

Also, the training program was well presented and comprehensive.

Maintenance staffing was stable and adequate.

Haintenance personnel were knowledgeable of procedures and equipment.

Observed maintenance activities were appropriately performed.

During the previous evaluation period, a weakness was identified in the licensee's management of contractors.

The licensee changed the responsibility for oversight of maintenance contractors from a separate

"contract administration". group to the maintenance discipline involved.

They also started evaluating the skills of individuals prior to commencing work.

While contractor performance improved greatly during this assessment period, contractor interfaces were not always well controlled.

One instance involved failure to control surface preparation for painting, leaving large amounts of loose dust in the room which could have adversely affected. an operable emergency diesel.generator.

In another instance, a contractor hydrolased an open reactor vessel flange seating surface using potable water, resulting in high RCS chlorides.

Both events jeopardized equipment condition, required licensee resources to clean up and analyze, and could have caused operational problems if they had been undetected.

Additionally, contractors sheared the 2C AFW pump lubricating oil line during a

scaffolding installation and sheared the 2A main feedwater

2.

regulating valve air line during another scaffolding installation.

Neither occurrence initiated a plant transient or exceeded an LCO.

The licensee subsequently revised procedures to require that such safety-related equipment be declared inoperable during the installation of scaffolding.

Licensee response and corrective actions were positive.

Surveillance procedures were performed well during this assessment period, and multiple observations of proper surveillances were documented by the NRC.

The licensee identified two isolated cases of missed surveillances regarding radiation monitors.

In response to erosion found during in-service inspections (ISI), the licensee upgraded a significant amount of carbon, steel high pressure turbine pipe and valves to chrome molybdenum steel.

To increase the availability of equipment, preventive maintenance was generally scheduled in conjunction with periodic surveillances, with the surveillance including a retest for the preventive maintenance action.

Two in-service testing (IST) program weakness are described in the Engineering/Technical Support section.

During this period, there were six violations cited in the area of Haintenance/Surveillance.

Performance Ratin 3.

Category:

I Recommendations None D.

Emer enc Pre aredness

~aal sis This area includes activities related to the Emergency Plan; support for and training of emergency response organizations, both on and offsite; as well as licensee performance during two evaluated emergency exercises.

There were no actual emergency events.

During the assessment period, the licensee continued to maintain a

strong emergency response organization capable of providing sufficient protective measures to ensure public health and safety in the event of an emergency.

Hanagement's support for and involvement in the emergency preparedness program was evident in the licensee's staffing commitment, resulting in an effective base of expertise at

=

both corporate and site levels.

Staffing at both the station and corporate levels was sufficient and members of the emergency response program demonstrated a high.level of proficiency.

During the 1992 NRC-observed exercise, alternates replaced key emergency response personnel throughout the organization.

The alternates performed well, indicating good organizational planning, training,

and depth.

Licensee initiatives during the assessment

'period to further improve their emergency response program included:

continued periodic exercises,'all-outs, table-top exercises, and numerous health phys,ics drills.

Additionally, on-site meteorological monitoring capabilities were improved by the installation and operation of a new meteorological tower and instrumentation system, establishment of a new alternative off-site assembly area, improvements in plant emergency kit inventories, improved quality assurance checklists for emergency preparedness program audits, and establishment of a 24-hour manned site first aid station.

Hanagement and staff were also effective in addressing routine and exercise inspection findings'nd issues through the use of corrective action programs and issue

,tracking systems.

The licensee conducted two full emergency response facility exercises during the assessment period in addition to the two evaluated exercises.

During the NRC-observed exercises, the licensee demonstrated the ability to staff and promptly activate the on-site emergency organization in a timely manner, identify initiating conditions, determine Emergency Action Level 'parameters, and correctly classify the emergency throughout the exercise.

The licensee also demonstrated the ability to make proper protective action recommendations and effectively implement the Emergency Plan.

Other strengths observed during the exercises included:

effective communications within the onsite emergency organization and with State and local authorities, excellent emergency medical response, and good assessment and mitigation of plant damage.

Areas identified during the assessment period with potential for improvement included emergency response facility activation timeliness, off-hours augmentation drills, control and management of Operations Support Center emergency repair teams, and timeliness of radiological release dose projections.

During the 1991 full-scale exercise with ingestion pathway, the NRC participated with both base

.and site teams.

The licensee effectively integrated and coordinated with NRC personnel when the latter arrived in the emergency response facilities.

Overall, the licensee's performance during the exercises demonstrated a capability to protect the public health and safety in the event of a radiological emergency.

The licensee maintained its emergency response facilities and equipment in a good state of readiness during the assessment period.

The Emergency Operations Facility located near the boundary of the ten-mile Emergency Preparedness Zone was spacious, with ample equipment and seating for the numerous government agency representatives who respond there.

The. licensee's emergency preparedness audit program was effective.

Identified deficiencies were followed up in a timely manner.

The licensee submitted one Emergency Plan revision during the assessment period.

NRC review disclosed several deficiencies in the

2.

submittal.

The licensee promptly submitted a revised version.

During the assessment period, the licensee experienced no conditions which warranted an emergency declaration.

No Emergency Preparedness exercise weaknesses or violations were identified during the assessment period.

Performance Ratin 3.

Category:

I Recommendations None E. ~Securit

~Anal sis This functional area addresses security activities related to protection of vital plant systems and equipment and the Fitness-for-Duty Program.

During the assessment period, the licensee implemented and managed a

superior security program.

Security management at both the site and corporate level was competent, experienced, and highly visible in the program activities.

Support was indicated by the implementation of numerous program improvements.

Examples of these improvements included a Security Force Upgrade Program, completion of the Intake Canal Intrusion Detection System, and improved access control with a new badging system and new search equipment.

The licensee-initiated Security Force Upgrade Program resulted in the following improvements:

training and equipping the security force with new rifles and semiautomatic pistols; improved employee benefits; new uniforms; and lights and PA system installed at the firing range.

A National Riflemen's Association Rifle Instructors School was conducted adjacent to the plant and a Tactical Response Training instructor completed a Special Response Team training course.

These initiatives contributed to increased security force professionalism.

They were also effective in reducing the security staff turnover rate during this assessment period as compared to the last assessment period.

The security force was professionally and effectively staffed, equipped, and trained to perform its assigned duties.

The security training staff was dedicated, knowledgeable, and motivated.

Through effective management support and intense. plant training, the licensee significantly reduced the number of unsecured door events (by 75 per cent) during the last half of this rating perio \\ ~

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The licensee finally completed the nine-year project to establish a

protected area intrusion detection system in the intake canal.

The installation of this intrusion detection device resulted in the elimination of three long-term compensatory posts.

During this SALP period, the licensee improved the access control system.

For example, the licensee purchased a new digital picture badge camera system.

This digital picture badge system stores all necessary access information and individual pictures within the system's computer.

This data can be electronically transferred to the licensee's other facilities.

This new system enhanced the licensee's access control capabilities and eliminated annual visits for repicturing.

The licensee purchased new metal/explosive detectors and new step wedges to improve X-ray equipment testing at the protected area access portals.

They also replaced all the old handheld metal detectors with new units.

Other areas of the licensee's security program were effectively operated during this period.

For example, the licensee replaced th'

discharge canal protected area barrier with a new one of improved design (fabric, poles, razor ribbon).

Alarm stations and associated communication equipment were operated by capable and knowledgeable personnel.

Security equipment was tested and maintained acceptably.

There was one instance when the licensee did not maintain adequate illumination on a portion of the protected area perimeter.

The licensee also identified and corrected an instance of an unsecured safeguards container.

The licensee's Fitness-for-Duty Program was effective in obtaining drug-free workplaces while balancing the rights and privacy of the workforce.

It met the objectives of 10 CFR Part 26.

The licensee submitted six Physical Security, one Contingency, and six Training and gualification Plan revisions during this period.

These revisions were consistent with 10 CFR 50.54(p), timely, and adequately coordinated with NRC.

The licensee's staff coordinating plan revisions and technical specification changes was knowledgeable of regulatory requirements.

I One violation was cited in the Security area during this assessme'nt period.

Performance Ratin 3.

Category:

Recommendations:

None

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F.

En ineerin Technical Su ort

~Aa a'I s I s

This functional area addresses activities associated with the design of plant modifications; engineering; and technical support for operations, maintenance, and licensed operator training.

In addition to routine inspections, three special inspections were conducted:

an Electrical Distribution System Functional Inspection (EDSFI),

a Service Mater Inspection, and a Motor Operated Valve Inspection.

The licensee demonstrated both responsive and conservative engineering/technical support (ETS) for St. Lucie.

Overall engineering and technical support were excellent.

During the assessment period, the licensee began engineering evaluations and implementation of plant material upgrades and modifications to address. external erosion/corrosion (E/C), caused primarily by salt water and boric acid.

Inspections were expanded to bound suspected E/C problems and included inspections for boric acid leaks, which exceeded the program required by NRC Generic Letter 88-05.

At the component and system level, plant materials have been subject to degradation from the salt-laden atmosphere associated with the site's coastal environment.

Issues addressed during this period included the corrosion of the carbon steel feet of the ICM strainers upstream of the CCW heat exchangers; salt water attack on outdoor electrical conduit and on reinforcement bar in concrete pedestal supports for safety-related pumps and other components; chloride attack in the steam trestle area on insulated piping; and the ocean intake structure refurbishment project.

Engineering also provided the design. for modifications to replace aluminum bronze ICW pump lubricating water piping with Honel.

These efforts have been thorough and well documented.

Engineering and contractor work control at the ocean intake structure refurbishment project was effective and involved concrete engineering which was state of the art.

Engineering personnel understood their role in the project, were well versed in project details, and routinely visited the work site.

The project proceeded smoothly and within schedule.

Engineering involvement was aggressive and extensive for the plant piping systems internal erosion/corrosion (E/C) program, to address reductions in pipe wall thickness.

Engineering was upgrading the method for E/C monitoring by incorporating operational and as-built piping data into computer programs for prediction of piping and components potentially susceptible to internal E/C.

Hodifications of the ICW pumps to self-lubricating models continued, with the conversion of all Unit I pumps during this period.

The modification had been successfully tried on one Unit 2 ICW pump and has now been applied to four of the six ICW pumps.

The design

change also included standardization of pump shaft dimensions and shaft section interchange capability.

This modification provided a

long-term plant reliability improvement and eliminated the existing troublesome salt water lubrication system which required constant maintenance.

The welding and ISI programs were effective during this assessment period.

The licensee's engineering management involvement was demonstrated in the monitoring of ISI work, especially in the area of eddy current testing the steam generator tubes.

Considerable

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management involvement was evident in the analysis of eddy current test results.

Also noteworthy was the licensee's defect trending program for steam generator tubes, used to predict the best time for steam generator replacement.

Technical support activities for welding and non-destructive examination (NDE) have been excellent.

FPL's commitment to safety and excellence was demonstrated by the use of enhanced stainless steel piping weld examination techniques that assure full coverage and defect detection.

One problem identified in the area, concerning inadequate radiograph film identification, appeared to be an isolated event.

An NRC team inspection of the ICW system concluded that the system as designed, operated, and maintained was capable of performing its safety function if called upon to do so.

Overall system performance was good; however, some IST program weaknesses were identified.

Test procedures for ICW train operability did not adequately test the spare (C)

pump and its actuation circuitry.

In two cases, the IST program for ICW valves was not implemented as documented in the NRC-approved program.

FPL corporate engineers were assigned to onsite plant organizations in support of outage activities, and continuous corporate and site engineering supervisory coverage was provided for valve repairs conducted by contractor personnel.

The valve repairs went well.

The motor-operated valve testing and surveillance program, in the early stages of implementation, was satisfactory and adequately addressed most of the recommendations of Generic Letter 89-10.

Strengths were noted in the program relative to refresher training that included a Job Performance Measure Examination completed prior to each refueling outage, and positive efforts in addressing recent industry concerns regarding the capabilities of previously-used diagnostic testing equipment.

Nevertheless, the NRC identified several issues.

These issues primarily involved the implementation schedule for program completion and the omission of recommended differential pressure and flow testing from the valve program.

In response, the licensee is implementing a schedular change for program completion and the testing of all valves in the program where practicable.

During this SALP period, engineering design controls provided for plant activities were gener ally effective.

The design process was

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detailed and functional.

Design change documentation was readily retrievable and the technical staff demonstrated a sound knowledge of the design process.

The various engineering organizations providing technical support were adequately staffed.

The licensee's engineering organizations actively increased in-house design responsibility during this period.

Corporate engineering's design integration program was adequate for ensuring that applicable information was available to engineers involved in performing design activities.

Detailed procedures addressing design integration and engineering standards were available to engineers for accomplishing their tasks.

A Procurement Engineering group was established to strengthen implementation of material and equipment procurement controls.

Engineering provided timely support during emergent plant equipment problem identification and resolution.

Unit I had a water hammer event that required evaluation and modification of broken feedwater ring retaining U-bolts in the IB steam generator.

A Unit 2 AFM pump bearing wear problem, a circulation water pump shaft failure problem, and large electric motor failures were well supported by both the corporate and site engineering staffs.

At the end of the assessment period, an emergency diesel generator failure revealed a

potentially generic issue, involving the under-frequency relay, that-was handled effectively by site engineering.

The licensee had performed an exceptional evaluation of the Electrical Distribution Systems (EDS) and corrected deficiencies before the arrival of the NRC EDSFI Team.

A series of self-audits of the EDS was conducted by the licensee in anticipation of the planned EDSFI.

Significant resources of over 13,000 man-hours were expended during these audits.

As a result, the licensee identified

,and corrected issues that would have otherwise been identified by the NRC.

The EDSFI team identified some minor issues in the areas of sharing of the startup transformers, DC motor-operated valve power cable sizing, emergency diesel generator building ventilation, protective relay setting drawings, fuse control, and relay calibration procedures.

The FPL self-assessment efforts reflected positive actions toward further self-improvement.

Throughout the assessment period, routine technical support for maintenance.and operations activities was demonstrated by the plant engineering staff.

As discussed in the Haintenance section, a

direct interface with the maintenance activity was provided by the electrical maintenance technical support group for performance,

.planning, and oversight of EDS maintenance activities.

Engineering has assisted or, taken the lead on:

drawing correction efforts, supporting core physics evaluations for the low leakage fuel, and establishing a process to transform vendor manuals to a more user-friendly format for craft use.

Interface and working relationships between ETS and plant organizations were well defined and established.

Effective

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communications were demonstrated on interfacing issues such as modifications and root cause analysis.

However, reviews indicated that the ETS organization had not aggressively pursued potentially safety-significant recommendations which had been made by the Independent Safety Engineering Group ( ISEG).

As an example, the ISEG had identified a potential problem concerning operability of containment cooling system ventilation dampers.

These dampers are required'o operate during post-LOCA conditions.

The ISEG had recommended that an operability determination be made to determine the dampers'tatus.

This was put on "hold" for a period exceeding two years, and was only recently resolved as a result of NRC involvement.

2.

An effective licensed operator training program was demonstrated by a 100 per cent pass rate on two initial examinations and a 92 per cent pass rate on a requalification examination.

Additionally, there was a

100 per cent pass rate for the Generic Fundamentals Examination, noted as a significant improvement from the previous SALP period.

High quality examination material was provided by the licensee for use during the requalification examinations, as evidenced by the low number of changes required.

Job Performance Heasures (JPHs)

were clearly written and covered a broad range of tasks.

Written examination questions were pertinent and well phrased.

The licensee conducted thorough pre-reviews of NRC initial written examinations, as evidenced by the low number of post-examination comments.

The licensee utilized a state-of-the-art plant simulator capable of reliably simulating a wide range of accident conditions.

Simulator scenarios sufficiently covered the scope and depth of the Emergency Operating Procedures.

The licensee's instructors effectively evaluated the candidates'erformance.

The simulator was effectively used as a training tool as evidenced by the high pass rate on the initial and requalification examinations.

Within this assessment period, two violations were cited in the Engineering/Technical Support area.

Performance Ratin 3.

Category:

ecommendations None

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G. Safet Assessment ualit Verification

~nal sis This functional area addresses licensee implementation of safety policies; 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 committee activities; and use of feedback from self-assessment programs and activities.

Management involvement and control to assure safety and quality in plant operations were evident throughout the assessment.

period.

The licensee's senior site management continued to be readily accessible and routinely involved in monitoring and assessing plant performance, operations, and technical or safety issues.

Involvement included daily control room visits; presence during infrequently performed field activities such as plant shutdown, major maintenance, or special tests; daily discussions with corporate and Turkey Point management; and weekly management walkdowns of the plant areas.

During outage periods, senior management made frequent tours of the containment building and other radiation work areas.

Corporate management received detailed

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written reports on significant site problems.

In addition, the lines of communication were always open between licensee management and the NRC staff.

The licensee's approach to safe plant operations during this assessment period continued to be conservative.

One example was the voluntary delay of the Unit I post-outage startup until repairs to a

shield building door seal were completed.

The licensee's response to personnel errors and equipment failures generated'any good root cause determinations and thorough corrective actions.

Examples include:

the Sensitive Systems Program, in response to a reactor trip caused by a maintenance personnel error; the control element assembly motor generator set synchronizing modification, in response to a reactor trip caused by an operations personnel error; correction of a cap and gasket design and installation problem that allowed moisture entry into outdoor solenoid valves, in response to a main steam isolation valve failure to close; correction of an electrical breaker relay latch manufacturing problem, in response to multiple Engineered Safety Features equipment failures'o start during Loss of Offsite Power

, surveillance.testing; zorrection of Unit I EDG vibration problems, in response to EDG cooling fan idler shaft failures; and innovative state-of-the-art motor rewinding with licensee quality control;- in response to failures of 4160 volt outdoor motors on ICW and CCW pumps.

These examples demonstrate the licensee's typical approach toward identifying and effectively correcting the root cause of problem r

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The licensee generally responded well to industry experience, NRC Information Notices, self-assessment and audit findings, and NRC findings.

Evaluations and corrective actions were usually very thorough.

An example was the response to industry information that silica could leach from boraflex material that was installed in the Unit I high-density fuel storage racks.

The licensee found and corrected high silica levels in the Spent Fuel Pool and the Refueling Mater Tank, and prevented high silica levels from entering the RCS.

In response to the NRC, the licensee.completed Anticipated Transient Mithout Scram (ATWS) and Station Blackout modifications and implemented a control room "dark board."

One exception to the licensee's good responsiveness was with the ISEG, for which observed weaknesses had not been corrected during the previous SALP period.

Early in this assessment period, the NRC observed similar poor performance, with lack of an aggressive program to address ISEG findings.

A subsequent NRC review found increased corporate and site managerial attention to ISEG activities and output, and a

clearly-demonstrated improvement in overall ISEG performance.

gA audits and other oversight review group activities were effective.

gA audits generated many worthwhile findings.

'The Facility Review Group conducted efficient TS-required reviews.

The Corporate Nuclear Review Board (CNRB) members had solid educational backgrounds and experience, and reviewed material prior to meetings.

The CNRB performed detailed reviews in a professional manner.

The CNRB was noted to be a significant asset to the licensee's self-assessment capability.

The licensee conducted self-assessments

"or vertical slice audits in the areas of electrical distribution, service water, motor operated valve testing, production engineering, architect/engineer performance, main steam and feedwater systems, and the reactor protection system.

NRC special inspections in the first three of these areas found that, in general, weaknesses had been identified by the licensee and were in a corrective action program.

In the service water area, the NRC found that the licensee's gA, root cause, and corrective action programs were adequate but that the NRC had identified some findings that the licensee's audits and assessments had missed.

In th6 area of electrical distribution, the NRC found that the licensee's self-assessments identified most of the problems and were a positive factor in self-improvement.

An inspection of the Speakout Program found that it continued to be effective in identifying and resolving employee safety concerns and had strong management support.

The licensing department was adequately staffed with experienced, competent, and well-qualified individuals with-many years of St.

Lucie plant experience.

The licensing staff was always cooperative and responsive.

They made frequent visits to NRC headquarters to discuss licensing issues.

The licensee's emphasis on personal involvement and responsibility enhanced the overall performance in

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the licensing area.

The licensee almost always submitted high quality licensing material, demonstrating a thorough understanding of the technical issues involved and a conservative approach'o safety.

Submittals were almost always timely and the No Significant Hazards Evaluations accompanying license amendment requests were almost always complete and well prepared.

One exception was a request for a license amendment to change the moderator temperature coefficient surveillance frequency, which contained a weak technical basis and was denied.

The licensee's staff was effective in anticipating and identifying potential problems related to TS or other regulatory requirements, that may require NRC licensing actions, and in notifying the NRC promptly so that problem resolution could be obtained on other than an emergency basis.

The absence of emergency TS changes during this assessment period was, at least in part, attributable to the licensee's effort.

The licensee implemented improved procedures for reviewing plant changes pursuant to 10 CFR 50.59, based on Electric Power Research Institute guidelines contained in NSAC/125.

Harked improvement was noted in the newly completed safety evaluations.

However, a recent fuel reload. analysis missed a required'TS change relating to the maximum weight of uranium per fuel rod.

Licensee Event Reports (LERs)'ontinued to be of high quality.

They adequately described all major aspects of events, including component failures that contributed to the event and significant corrective actions taken or planned to prevent recurrence.

The root cause was clearly identified in most cases.

The LERs were thorough, detailed, generally well written, and easy to understand.

No violations were cited in the Safety Assessment/guality Verification area during this assessment period.

2. Performance Ratin Category:

3.8 dt's None V.

SUPPORTING DATA A. Licensee Activities Unit 1 began and ended this assessment period at power.

The unit operated at power with the exception of one refu'cling outage, from October 18 to December 22, 1991, and with the exception of two planned shutdowns for CEA testing, two scrams due to personnel error, and one

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scram due to non-safety equipment malfunction.

Unit 2 began this period in a refueling outage and started up on December 3,

1990.

During power escalation, main turbine vibrations forced a brief shutdown.

On December 5, the unit restarted and remained on line for 502 days until it was shut down on April.20, 1992, to begin a scheduled two-month refueling outage.

Some noteworthy management personnel changes occurred during this assessment period:

the corporate Nuclear Operations Vice President

'etired, the Construction Services Site Manager retired, and the chairman of the Corporate Nuclear Review Board changed.

B. Direct Ins ection and Review Activities During the assessment period, 36 routine and 3 special inspections were performed at St.

Lucie by the NRC staff.

The special inspections were:

Electrical Distribution System Functional Inspection Motor Operated Valve Inspection Service Water Inspection C. Escalated Enforcement Actions 1. Orders None 2. Civil Penalties One:

$37,500 Civil Penalty for failure to maintain OPERABILITY of the Unit 2 Containment Spray System D. Licensee Conferences Held Durin A

raisal Period February 22, 1991-April 10, 1991 Hay 30, 1991 September 10, 1991-September 20, 1991-November 6, 1991 Meeting held at RII office to discuss engineering initiatives.

Meeting held at NRC headquarters to discuss Station Blackout Rule implementation.

'i Enforcement conference held at RII office to discuss Containment Spray System inoperability.

Heeting held at,NRC headquarters to discuss various licensing issues.

Meeting held at NRC headquarters to discuss status of licensing issues.

Heeting held at NRC headquarters to discuss licensing issues, FPL organizational changes,

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1992

and Unit 1 outage activities.

Meeting held at RII office to discuss St.-Lucie organization, outage, and current initiatives.

Meeting held at RII office to discuss FPL engineering initiatives.

January 16, 1992

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Heeting held at NRC headquarters to discuss active lic'ensing actions and service water.

January 29, 1992

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Meeting held at NRC headquarters to discuss active licensing issues.

February 6,

1992

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. Heeting held at RI I office to discuss the licehsee's assess'ment of their performance.

February 27, 1992 -

Meeting held at NRC headquarters to discuss current licensing issues.

February 27, 1992 -

Heeting held at NRC headquarters to discuss equipment seismic qualification. per Generic Letter 87-02.

April 17, 1992

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Meeting held at NRC headquarters to discuss active licensing actions.

E. Confirmation of Action Letters None F.

eactor Tri s and Un armed Shutdowns Unit 1 experienced three unplanned reactor trips during this evaluation period.

Unit 2 experienced one unplanned manual shutdown during the period.

The unplanned trips and shutdowns are listed below.

Reactor Trips:

Hay 6, 1991:

Unit 1 was manually tripped in response to a feedwater heater drain pump trip and subsequent feedwater pump trip.

Unit 1 was down for 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />.

July 1, 1991:

Unit 1 automatically tripped due to the loss of a steam

,generator.feedwater..regulator controller caused by maintenance personnel error.

Unit 1 remained down for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> due to control rod position indication problems and turbine control valve problems.

September 18, 1991:

Unit 1 automatically tripped due to scram breakers opening on overcurrent caused by operator error while paralleling CEA drive motor generator sets.

Unit 1 remained down for 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> due to Hydrogen analyzer problem ~

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Unplanned Reactor Shutdowns:

December 4,

1990:

Unit 2 was manually shut down for 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> due to vibration in the f6 main turbine bearing during startup from a refueling outage.

G. Review of Licensee Event Re orts For the assessment period, a total of 20 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 or Commo Personnel Error

- Operating Activity

- Maintenance Activity

- Test/Calibration Activity

- Other Other ota Note 1:

With 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:

In addition to the above, one voluntary LER was submitted, which involved a fabrication defect.

Note 3:

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 assignments.

H. Licensin Activities

,During the assessment period, the staff closed 49 licensing actions, while 31 new ones were opened.

Twenty-four of the closed actions were amendments and the remainder were multi-plant and other regulatory actions, including NRC Bulletins and Generic Letter I. Enforcement Activit Functional Area o.

o ev>atlons an

>o at>ons

>n Each Severity Level Dev.

V IV III II I

Unit I/Unit2 ant peratsons Radiological Controls.

Maintenance/Surveillance Emergency Preparedness Security Engineering/Technical Support Safety Assessment/equality

'Verification

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I/I 3/4 0/0 I/I 2/2 0/0

8/8 0/

Net total (each VIO counted once)

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