IR 05000335/1993025
| ML17228A382 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 11/30/1993 |
| From: | Casto C, Wiseman G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17228A381 | List: |
| References | |
| 50-335-93-25, 50-389-93-25, NUDOCS 9312140096 | |
| Download: ML17228A382 (14) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W., SUITE 2900 ATLANTA,GEORGIA 30323-0199 gp,S REgy (4
,.z,:=-'**yW Report No.:
50-335, 389/93-25 Licensee:
Florida Power and Light Company ATTN: Hr. J.
H. Goldberg President
- Nuclear Division P. 0.
Box 1400 Juno Beach, FL 33408-0420 Docket Nos.:
50-335 and 50-389 Facility Name:
St. Lucie Inspection Conducted:
November 1-5, 1993 License Nos.:
G.
Wiseman
/
Bo Date Signed Accompanying Inspectors:
H. Thomas H. Whitener
Approved by:
C. Casto, C
ef Test Programs Section Engineering Branch Division of Reactor Safety
/y-u-5s Date Signe SUMMARY Scope:
This routine, announced inspection was conducted in the areas of design changes and plant modifications, engineering and technical support activities, and follow-up on previously identified inspection findings.
Results:
In the'reas inspected, violations or deviations were not identified.
The licensee had demonstrated the use of an adequate prioritization process for identifying and implementing plant modifications.
The overall quality and technical content of the Plant Change/Hodifications (PCHs)
packages reviewed was adequate and sufficiently documented to verify closure.
The 50.59 safety evaluations provided sufficient discussion and justification to comply with regulatory requirements.
The licensee has implemented a control process which should reduce and maintain the PCM backlog at an acceptable level.
Examples of management initiatives to address PCH backlog reduction included the creation of a backlog reduction team and an outage directive for PCH closure.
Timely 931214009h 931201 PDR ADOCK 05000335
and effective engineering and technical support were being provided to the plant.
The predictive maintenance program has successfully identified impending equipment failure in time to allow controlled maintenance and prevent on-line failure.
This program is considered a positive aspect, in support of plant maintenance and operation.
The licensee's self assessment activities were a positive example of management's ongoing efforts to identify areas that n'eed improvement.
The "Technical Alerts" distributed to discuss post-modification testing and departmental interface problems have been instrumental in addressing those areas that need improvement.
The gA assessment and oversight activities were considered to be a strength.
One inspector follow-up item was identified relating to the operability of a motor operated valve during the period July 20 to October 19, 1993 - paragraph 3 e l.
Persons Contacted REPORT DETAILS Licensee Employees
- W. Bladow, Manager, Site Quality W. Bohlke, Vice President, Nuclear Engineering and Licensing J.
Brady, Supervisor, Maintenance Engineering J.
Connor, Supervisor, Test and Code Group R. Costis, Supervisor, Configuration, Control D. Culpepper, Chief, Engineering Assurance
- J. Dyer, Supervisor, Quality Control
- J. Fulford, Supervisor, Site Project Engineering B. Griner, Supervisor, Site Electrical Engineering
- J. Holt, Licensing Engineer
- J. Hosmer, Project Manager, Engineering J.
Laduca, Mechanical Engineer J.
Manso, Mechanical Engineer
- L. HcLaughlin, Manager, Licensing-K. Hohindro, Manager, Production Engineering
- C. O'Farrill, Project Engineer
- T. Oswald, Supervisor, Document Control H. Paduano, Manager, Licensing and Special Project
- L. Rogers, Supervisor, Instrumentation and Controls
- D. Sager, Vice President, Plant St. Lucie
- J. Scarola, Manager, Nuclear Operations
- D. Stewart, Supervisor, System Engineering
- S. Valdes, Supervisor, Design Control
- C. Wasik, Site Lead Licensing Engineer
- D. West, Technical Manager
- J. West, Supervisor, Nuclear Operations D. Wolf, Site Supervising Engineer Other licensee employees contacted included engineers, QA/QC personnel, craftsmen, operators, and administrative personnel.
NRC Personnel
- S. Elrod, Senior Resident Inspector
- H. Hiller, Resident Inspector
- N. Stinson, NRC Intern
+Attended exit meeting Acronyms and initialisms used throughout this report are listed in the last paragrap Design Changes and Plant Modifications (37700)
'a ~
Plant Modifications to Improve Reactor Safety The inspectors reviewed the licensee's initiatives to identify and implement plant modifications to improve reactor safety.
Documentation reviewed included the Plant Change/Modification (PCH) Tracking Control Log, dated October 29, 1993, which covered the Unit
1992 refuel outage and other PCHs completed since January 1993; and, the Nuclear Engineering Unit 2 1994 Outage Schedule.
The inspectors reviewed the listed documentation and concluded that the licensee had demonstrated the use of an adequate prioritization process for identifying and implementing plant modifications.
b.
Planning, Development, and Implementation of Plant Modifications The inspectors reviewed the PCH packages listed below to determine the adequacy of evaluations to meet
CFR 50.59 requirements; verify that the PCHs were reviewed and approved in accordance with TS and applicable administrative controls; verify the subject modifications were installed (for those that could be physically inspected)
in accordance with the PCH package and other applicable design documents; verify that applicable plant operating and design documents (drawings, plant procedures, FSAR, TS, etc.)
were revised to reflect the subject modifications; verify that the-modifications were reviewed and incorporated into the operations training program as applicable; and verify that post modification test requirements were specified and adequate testing was performed.
PCH 123-193, ECCS Room Ventilation System Differential Pressure (DP) Instrumentation High Alarm Setpoint Change to Minimize the Potential for Spurious Alarm During Testing.
PCH 055-193, Addition of Electrical Interlock. Auto-Stop of the Reactor Auxiliary Building Hain Exhaust Fans on a Safety Injection Actuation Signal to Assist in Maintaining Adequate DP.
PCH 176-191M, Emergency Diesel Generator Air Start Solenoid Valve Coil Replacement to Eliminate Push-on Spade Lug Connections.
PCH 004-192M, Emergency Diesel Generator Air Start Receiver Tank Drain Valve Replacement.
PCH 294-192M, Emergency Diesel Generator lA and 1B Radiator Cooling Fan Drive Replacement.
(The licensee's implementation of this PCM is discussed in NRC Inspection
0
The inspectors concluded from reviewing the above PCH'ackages that the overall quality and technical content were adequate and sufficiently documented to verify closure.
The 50.59 safety evaluations provided sufficient discussion and justification to comply with regulatory requirements.
I Engineering PCH Backlog The inspectors reviewed trending plots of PCHs to determine if.
plant modifications are maintained at manageable levels and
,processed in a timely manner.
While the trend was somewhat cyclic, reflecting outage schedules, the overall trend has shown a
reduction since April of 1993.
In 1992 the number of active PCHs ranged from about 250 to 350.
As of April 1993 the number reached 329.
In April 1993 the licensee implemented a backlog reduction program which has several aspects.
As of the Unit
1993 refueling outage, the site vice president established a policy that all outage modifications would be complete at mode four.
This means no PCHs were added'o the backlog as a result of incomplete updating'f design change paper.
The licensee also formed a Backlog Review Group to review and disposition backlogged PCHs.
Since the formation of this group in April 1993,,the number of active PCHs has been reduced from 329 in April to 190 in October 1993 (
a 43 percent reduction).
The inspectors reviewed summary data on the disposition of a sample'of 101 open PCHs.
Of the 101 PCHs, 33 were completed and closed,
remain active, seven were of the As-Fail Classification (i.e, relates to the generic replacement of a particular component with an alternate component as it fails ).
Ebasco has been contracted to resolve this type of PCM.
Thirty nine PCHs have been.
cancelled.
The inspectors reviewed PCMs 137-81 and 296-183 to
,determine if the basis for cancellation was acceptable.
PCH 137-
"
81 contained an adequate description of the basis for cancellation.
PCH 296-183 did not contain a description of the basis for cancellation.
However, based on a review of the design package the inspectors concluded that cancellation of PCH 296-183 did not adversely affect plant reliability or safety.
A final aspect of the licensee's program that contributes indirectly to backlog reduction is the rigorous control of PCHs to be engineered and issued.
A Request for Engineering Assistance (REA) is the method for requesting design engineering to develop a
design change.
The REAs are prioritized and screened at several levels of management review.
As a result PCHs which are considered nice-to-have but not necessary for reliable, safe plant operation and do not meet the budget restraints are not engineered.
This conserves engineering resources and prevents development of PCHs which would become back logged due to low priority and budget restraint The inspectors concluded that the licensee has implemented a
control process which should reduce and maintain the PCH backlog at an acceptable level.
Engineering and Technical Support Activities The inspectors reviewed activities performed by the various engineering and technical support departments in an effort to assess the effectiveness of the support being provided to the plant.
The inspectors concluded -that timely and effective support was being provided.
a
~
b.
Organization and Staffing Engineering and technical support are provided by both site and corporate organizations.
The inspectors reviewed site support activities provided by Site Engineering (design),
the Technical Department (which includes system engineering),
and the Maintenance Department (which includes the Mechanical Maintenance Engineering Group (HMEG)).
The corporate and site engineering organizations, under the Vice President Engineering and Licensing, were recently reorganized and streamlined in September 1993.
The duties and responsibilities of the above departments are described in various site and corporate administrative procedures.
In general, the staffing levels appeared to be adequate to provide support to the plant.
However, the inspectors noted that recent staffing level changes in system engineering has resulted in excessive workloads for some system engineers.
The inspectors discussed the staffing with licensee management who indicated that the two individuals who transferred from system engineering to other plant groups will be replaced in January 1994.
Support The inspectors interviewed licensee personnel, reviewed records, and observed plant activities to evaluate the engineering involvement and technical support of day-to-day plant operations.
An example of timely engineering and technical support observed by the inspectors involved efforts following a manual reactor trip of Unit 2 on November 2, 1993, due to a high hydrogen gas'emperature for the main generator.
After the operators tripped the unit, the system engineering supervisor and the system engineer for the turbine systems assisted maintenance and operations personnel in efforts to determine the cause of the hydrogen gas temperature increase.
Site and 'corporate engineering personnel and 'the turbine vendor also assisted in this effort.
These effoi ts included verifying proper operation of temperature control valve TCV 13-28 and its associated controller, verifying proper operation of other TCVs in the turbine cooling water (TCW) and component cooling water systems, and verifying that the increased
hydrogen temperature would not adversely affect the main generator.
The cause for the increase in the main generator hydrogen gas temperature was determined to be the automatic opening of the TCW temperature control valve TCV 13-28, TCW Temperature Control Valve for the Turbine Lube Oil Coolers.
The opening of TCV 13-28 caused TCW flow to be reduced to the hydrogen coolers.
The coordinated efforts and cooperation of the groups resulted in operations commencing the restart of Unit 2 during the evening of November 2, 1993.
This item is discussed further in NRC inspection report 50-335, 389/93-23.
Another example of timely engineering support was demonstrated in the development and implementation of PCH 137-293M for the replacement of an engineered safeguards Lambda power supply in
'nit 2.
Site Engineering was contacted to determine if an alternate power supply could be used.
Engineering identified a
replacement power supply and provided a design to allow its use in the safeguards cabinet within one day.
Other examples of engineering and technical support included the following:
Prioritizing and implementing actions to resolve operator work-arounds.
The work-arounds were identified by operations at the request of engineering.
Development of the Haintenance Specification Program by engineering to enable maintenance to more efficiently perform routine repetitive maintenance activities.
Guidance was issued to ensure that plant design basis is maintained.
Implementation of a leak repair surveillance program by the MHEG.
Implementation of the safety related small diameter (2-inch and under) valve generic replacement program.
A valve team was formed which consisted of Site Engineering, Mechanical Maintenance, Purchasing, and Stores.
Anchor Darling was selected as the standard replacement valve.
PCH 282-192H
'and PCH 009-293M for Unit 1 and Unit 2 respectively, were issued to cover installation of the standard replacement valves on an as-needed basis.
The inspectors concluded that timely and effective engineering and technical support were being provided to the plant.
In addition to the above examples of engineering support the inspectors reviewed a sample of Nonconformance Reports (NCRs) to evaluate engineering involvement in plant problems.
Nonconformance Reports are one method of identifying plant problems
for design engineering review to determine operability and problem resolution.
To evaluate the adequacy of the operability
.
assessments and problem resolutions, the inspector reviewed the following:
NCR No.
1-716 1-723 1-803 2-500 2-513 2-507 2-534 2-537 2-536 Problem Sub 'ect I
Incorrect wiring and penetration designation.
1C ICW pump performance degraded.
Support in the plant not shown on plant drawings.
Secondary check valve V3525 for HPSI Hot Leg Injection degraded and leaking.
2B ICW pump performance degraded.
Leakage past the seat of the 2A HPSI pump recirculation check valve V3102.
Deviation in configuration of TCW pump casing vents and plant drawing.
2B ICW pump motor lower guide housing for bearing is oversized and thrust block bearing journal is undersized.
SG 2A.to AFW pump turbine Hotor Operated Valve (HOV) HV-08-13 stalled during surveillance test.
The inspectors concluded that operability assessments and proposed problem resolutions were adequate with the possible exception of NCR 2-536 which is related to the high thrust for disk pull out for HOV HV-08-13.
During a surveillance test on HV-08-13 on July 20, 1993, the HOV apparently stalled on the opening stroke (valve safety function).
With the use of VOTES diagnostic equipment, an unacceptably high unseating load (10,902 lbs.
uncorrected)
was obtained during a subsequent Full Flow Differential Pressure tests (FFDP).
Five additional FFDP tests were performed on July 21, and additional testing in August, September, and October 1993.
By refining design calculations using actual test data and imposing a limit on the number of allowable cycles for the Limitorque actuator, the licensee had concluded that the HOV was operable until a test on October 19, 1993 resulted in an unacceptable disk pull out thrust of 14,241 lbs. (uncorrected).
At this time, the licensee changed the control logic to terminate valve closu're from Torque Switch Trip (TST) to the limit switch to reduce the wedging force from inertial loads.
Under this condition the, HOV has exhibited consistent unseating thrust (nominal 4000 lbs) well within
C.
acceptable limits for both the valve and actuator in eleven subsequent tests.
The inspectors considered the HOV to be operable in the as-left condition.
However, the operability of the HOV during the period July 20 to October 19, 1993 is still under NRC review.
This matter is identified for further review in the Generic Letter 89-10 program Phase II inspection as IFI 50-389/93-25-01, Review operability of Unit 2 HOV HV-08-13 during the period July 20 to October 19, 1993.
Implementation of Predictive Maintenance Techniques The licensee has a well established Predictive Maintenance Department (PHD) staffed with experienced personnel.
This group has been actively engaged in monitoring, trending, and analyzing plant equipment performance through diagnostic techniques.
The techniques included vibration data trending and analysis; oil sample ferrography and physical analysis; and, thermography (thermal imaging).
Through this predictive maintenance program the licensee has successfully identified impending equipment failure.
Early detection of equipment degradation allows time for developing a
corrective action'lan, procuring spare parts, scheduling equipment out of service at appropriate plant conditions, and effecting equipment repair before on-line failure which could potentially result in a plant transient or challenge to the safety systems.
The inspectors reviewed the results of five case histories and concluded that the diagnostic analysis and bearing failure analysis had been effective in identification of failure root cause to support appropriate maintenance to prevent recurrence and identification of degrading equipment to-allow controlled maintenance and prevent on-line failure.
The inspectors considered this program a positive aspect in support of plant
.maintenance and operation.
Quality Assurance (QA) Assessment and Oversight The inspectors reviewed QA audits, performance evaluations, and Quality Assurance Program design control audits of St. Lucie Production Engineeri'ng Group (PEG)
and Site Engineering's safety related activities conducted by the Nuclear Quality Assurance organization.
The assessments and audits were part of the overall Quality Assurance Program at St. Lucie.
The inspectors reviewed results of the following Quality Assurance activities that were either completed or in progress:
QAS-JPN-91-8, April 1992, Audit of Juno Nuclear Engineering and Pr'oduction Engineering Group PSL QAS-JPN-92-3, February 1993, Quality Assurance Audit of Nuclear Engineering
gAS-JPN-93-1, July 1993, Audit of Nonconformance and Corrective Action
gAS-JPN-93-3, October 1993, Audit of St.
Lucie Design Control Including Production Engineering Group and PRA In addition to reviewing results of the above activities, the inspectors reviewed several Engineering response memorandums to the audit observations and recommendations.
The inspectors found that the guality Assurance organization has been heavily involved in assessing Engineering activities.
This included detailed reviews of the plant Commercial Grade Dedication, Hotor Operated Valve (HOV), and Environmental gualification (Eg) Programs.
guality Assurance has been aggressive in identifying areas that need'improvement.
Corrective actions in response to Nuclear Engineering audits are being implemented.
Another aspect of the license's self assessment effort is the PEG and contractors performance assessments for St. Lucie.
These assessments are performed every six months.
Nine specific engineering attributes are evaluated and a "report card" is issued.
The inspectors reviewed the last report card issued for PEG.
The report card showed that the overall performance trend of PEG showed improvement over the most recent six month period.
Several
"Technical Alerts" distributed to discuss post-modi.fication testing and departmental interface problems identified during performance assessments have been instrumental in addressing those areas that need improvement.
The inspectors considered the gA assessment and oversight activities to be a strength.
Violations or deviations were not identified in the areas inspected.
Li a
~
b.
censee Actions on Previous Inspection Findings (92701)
(Open)
Unresolved Item 50-335, 389/93-01-01,'oncerning two check valves (V-8372, V-8373)
added to the main steam system by PCH 541-191, and two check valves (V-7269, V-7270) in the containment spray system that were not tested in accordance with ASHE Section XI requirements.
This item was unresolved pending the NRC's review of the licensee's requests for relief from the ASHE Section XI requirements..
The licensee modified Relief Request VR-22 and submitted it to the NRC in a letter dated April 19, 1993, to address the containment spray valves.
The NRC approved this relief request in a letter to the licensee dated September 17, 1993.
L'icensee personnel indicated that Relief.
Request VR-41 for the main steam system check valves was under review by the NRC.
This Unresolved Item will remain open pending the NRC's review of Relief Request VR-41.
Although not identified with an NRC tracking number, there were several other weaknesses identified in the licensee's Inservice Testing (IST) program during 'NRC inspection 50-335, 389/93-0 During followup by the inspectors, licensee
'personnel indicated that actions have. been taken to address the.weaknesses identified.
These actions included the following:
Task team formed to review and upgrade the St. Lucie Section XI IST program implementation.
Additional personnel and resources have been assigned to the Technical Staff Test and Code Department.
Completed an upgrade of the Basis Documents for both Unit
and Unit 2.
Reviewed the Total Equipment Data Base to identify all Class 1, 2, and 3 pumps and valves.
Submitted second Ten-Year Interval Pump and Valve Program
'or Unit 2.
Revised the Unit 2 IST procedures.
Revision of the Unit 1 IST procedures in progress.
Revision to Unit
Pump and Valve Program in progress.
The inspectors. made note of the above actions taken by the licensee 'and will review these actions in greater depth during a
future inspection.
Exit Interview The inspection scope and results were summarized on November 5, 1993, with those persons indicated in paragraph 1.
The inspectors described the areas inspected and discussed in detail the inspection findings.
One IFI (50-389/93-25-01)
was identified concerning the operability of Unit 2 HOV NV-08-13 in the period July 20 to October 19, 1993.
Proprietary information is not contained in this report.
Dissenting comments were not received from the licensee.
Acronyms and Initial i sms AFW ASHE CFR DP ECCS EQ FFDP FSAR HPSI ICW IFI Auxiliary Feedwater American Society of Mechanical Engineers Code of Federal Regulations Differential Pressure Emergency Core Cooling System Environmental Qualification Full Flow Differential Pressure Final Safety Analysis Report High Pressure Safety 'Injection Intake Cooling Water Inspector Followup Item
~
HHEG NCR NRC PCH PEG PHD PSL PRA-QA QC REA SG TCV TCW TS TST Inservice Test Motor Operated Valve Mechanical Maintenance Engineering Group Nonconformance Report Nuclear Regulatory Commission Plant Change/Modification Production Engineering Group Predictive Maintenance Department Plant St.
Lucie Probilistic Risk Assessment Quality Assurance Quality Control Request for Engineering Assistance Steam Generator Temperature Control Valve Turbine Cooling Water Technical Specifications Torque Switch Trip