IR 05000335/1995015
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- Date:
10/28/96 7:26am'
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Subject:
St. Lucie IR 96-15 Attached is St. Lucie IR 96-15 (September / October)
SUBJECT:
NRC. INTEGRATED INSPECTION REPORT 50 335/96-15, 50-389/96-15
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AND NOTICE OF VIOLATION,
Dear Mr. Plunkett:
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On October 12. 1996, the NRC completed an inspection at your St. Lucie 1 and 2 reactor facilities. The enclosed report presents the results of.that inspection.
Based on the results of this inspection, the NRC.has determined that violations of NRC
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requirements occurred. The violations are of concern because they indicate that procedural
adherence issues continue to challenge the facility. Of particular note was the case of the Unit 1 containment airborne radiation monitor, which had been incorrectly' aligned while'
l being returned to service as a result of an individual.who did not employ a procedure, in this event'.. the control room had been incorrectly informed that the component in question
was operable when it was not, resulting in.it being declared operable before an independent verification could have identified the problem. We note that this event shares a root cause
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with a similar event in February of this year, when another individual similarly misaligned
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'the same component by not employing a procedure for the same activity. While we are
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encouraged that'this most recent occurrence was promptly identified by non-licensed
operators (as opposed to the February event), indicating that you have been successful in l
heightening awareness to off normal indications, we nonetheless view this as a repeat
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violation.
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Repetitive violations are addressed in the NRC's " Statement of Policy and Procedure for NRC l
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Enforcement Actions," (Enforcement Policy) NUREG 1600,Section IV.B. The Enforcement Policy allows the severity level of a violation to be increased if the violation can be considered repetitive. For example, a Severity Level IV violation could be increased to
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Severity Level 111 with the attending escalated enforcement action. However, in this case,
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we have decided not to increase the severity level of this violation based on your corrective actions to this event your ongoing efforts to reinforce a culture of procedural compliance at your facility, and your overall satisfactory performance in this area.
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.These' violations are cited in the enclosed Notice of Violation. and the circumstances
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surrounding the violations are described in detail in the enclosed report. Please note that
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you are required to respond to this letter and should follow' the instructions specified in the enclosed Notice when preparing your response, The NRC will use your response in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
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In accordance with 10 CFR 2.790 of the NRC's'" Rules of Practice.", a copy of this letter and Lits enclosures will be placed in the NRC Public Document Room (PDR).
Sincerely, j
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Kerry D. Landis, Chief
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Reactor Projects Branch 3 Division of Reactor Projects Docket Nos. 50 335, 50-389 License Nos. DPR-67, NPF-16 Encidsures: Notice of Violation Inspection Report.50-335/96 15 50-389/96-15
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cc w/ encl: (See page 2)
NOTE: ADO CC & BCC LISTS
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Florida Power & Light Company Docket No, 50-335
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St Lucie 1 License No. DPR-67
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During an NRC inspection conducted from September 7 through October 12, 1996,
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violations of NRC requirements were identified.
In accordance with the'" General Statement of Policy and Procedure.for NRC Enforcement Actions " (60 FR 34381: June 30, 1995), the violations are listed below:
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. Technical Specification 6.8.1.a requires that written procedures be j
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established, implemented, and maintained covering.the activities recommended in Appendix A of Regulatory Guide 1.33. Revision 2, February, -1978. Appendix A.~ paragraph 8.a includes procedures to ensure that tools, gauges, instruments. controls, and other measuring and test devices are properly
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controlled. Procedure 01 12-PR/PSL-2, Revision 22. "C'ontrol And Calibration
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Of Measuring And Test Equipment (M&TE) " Section 5.3.4.A states, in part that
each item of M&TE shall have a log sheet filled out to identify each activity
.where the instrument was used.
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Contrary to the above,~on June 26, 1996, Measuring and Test Equipment item-PSL-865, was used to perform maintenance in accordance with Work Order j
95031787 without identifying the activity where the instrument was used on the log sheet.
This is a Severity Level IV violation (Supplement I).
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Technical Specification 6.8.1.a requires that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33. Revision 2. February, 1978. Appendix A paragraph 1.d includes administrative procedures for procedural adherence.
Procedure 01 5-PR/PSL-1, Revision 73. " Preparation, Revision, Review / Approval Of Procedures," section 5.14.1 requires verbatim compliance to procedures by all personnel. In addition, step 5.14.4.A.3 requires.that procedures
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containing tasks which must be performed in a specified sequence and/or which
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verification is documented by initial or signature must be present and referred to directly during the performance of the activity.
' Contrary to'the above, on September 14, 19'96, a health physics technician.
performing a grab sample of the Unit 1 containment failed to have Procedure HPP 22 Revision 4. " Air Sampling". Appendix A, in hand, while. it was.being.
performed.. As a result, step 7.21 of this procedure was not performed which rendered the containment radiation monitor inoperable,
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This is a Severity Level IV violation (Supplement I),
Pursuani!to'theprovisionsof10CFR2.201,theFloridaPower&LightCompanyis
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hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident
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Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation:
(1) the reason for the violation, or, if contested, the basis for disputing the violation. (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate r'eply is not received within the time specified in this Notice, an order or a Demand for Informatio,n may be issued as to why the license should not be modified, suspended., or revoked, or why such other action as may be proper should not be taken. Where good cause is shown,
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consideration will be given 'to extending the response time.
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Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without reduction.
If personal privacy or proprietary information is 'necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information.
If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for l
withholding confidential commercial or financial information).
If safeguards i
information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.]
Notices of Violation are not to be signed; only dated.
Dated at Atlanta. Georgia this day of
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a U.S. NUCLEAR REGULATORY COMMISSION
REGION II
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Docket Nos: 50-335, 50-389 License Nos: DPR 67, NPF-16 j
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Report No:
50-335/96-15, 50-389/96 15 Licensee:
Florida Power & Light Co.
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Facility:
St. Lucie Nuclear Plant Units 1 8.2 l
Location:
9250 West Flagler Street Miami, FL 33102
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Dates: September 7 - October 12, 1996 Inspectors:
M. Mille,r, Senior Resident Inspector J. Munday, Resident Inspector
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D. Lanyi, Resident Inspector G. Hopper, Reactor Inspector, paragraphs 01.2. 05.1.
Approved by: 1(. Landis, Chief, Reactor Projects Branch 3 Division.of Reactor Projects
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EXECUTIVE SUMMARY St. Lucie Nuclear Plant. Units 1 & 2 NRC Inspection Report 50-335/96-15, 50-389/96-15 This integrated inspection included aspects of licensee operations, engineedng.
maintenance, and plant support. The report covers a 5-week period of resident inspection.
Doerations Control room watchstanding practices were satisfactory. Watchstanders
maintained a professional environment and were attentive to plant parameters and conditions (paragraph 01.2).
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Equipment areas were generally clean, valves were properly positioned and
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labelled, and support equipment was acceptable (paragraph 02,.1).
Emergency Diesel Generator surveillance testing was accomplished
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satisfactorily. Additionally, the inspector found the use of Real Time Training Coaches indicated innovative and proactive Training Department involvement in plant activities The use of a post-evolution debrief of operators was viewed as an excellent practice for operational improvement (paragraph 04.1).
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A failure to adequately ensure that required reading was performed by
operators was identified. The corrective actions taken were satisfactory (paragraph 05.1).
A major site reorganization was implemented which aligned all site engineering
functions under the licensee's Engineerin'g organization (paragraph 06).
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Poor labeling led to a failure to bypass the correct Engineering Safety
Features steam generator water level channel after the channel had been declared inoperable, leading to a failure to satisfy Technical Specifications (paragraph 08.1).
Maintenance
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The licensee has made progress in the identification and reduction of
maintenance backlogs as a result of improved scheduling, management attention, and'the use of the minor maintenance process. Win Team activities were reviewed and were found to be appropriately defined. ' Work Request cancellations reviewed during the period were found to have been performed appropriately (paragraph M3.1).
Ouality Control effectively identified weaknesses in the Measuring and Test
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Equipment (M&TE) program. Once the problems were. identified, corrective actions were implemented (paragraph M7.1).
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The NRC identified a violation of M&TE program requirements involving a meter
which had not been logged against a work activity for which it had been employed (paragraph M8.1).
Enoineerina An inspection of the Unit I containment airborne radiation monitor indicated a
general lack of design basis documentation for this system.
In addition, five examples of failure to update the Updated Final Safety Analysis Report were identified (paragraph E3.1).
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Plant Sucoort
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An event, involving r mispo'sitioned valve that rendered the Unit 1 containment
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airborne radiation monitor inoperable, occurred during the inspection period.
The event was the result of an individual who did not have a procedure in hand and follow it as required, and a violation resulted. This is a repeat violation (paragraph R1.1).
A review of the c'ontrols applied to the release of oily wastewater from the
Radiation Controlled Area was performed (pa'ragraph R1.2).
An Unresolved Item, involving a fa1 lure to properly secure the Unit 1 Post
Accident Sampling System following a test, was closed (paragraph R8.1).
Protected area barriers were found to be in good condition, the isolation
zones well lit. and the appropriate compensatory guard postings in place (paragraph S2).
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' Report Details
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Summary of Plant Status
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Unit 1 entered the inspection period at approximately 60 percent power due to.the i
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removal of'the-1B main transformer from service. On September 14. the unit was taken
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-to Mode 2 to allow for the reconnection of the 18 main transformer. On September 15.
i the unit was placed on line and the unit remained at reduced power due to secondary chemistry concerns until September 16. when full power conditions were achieved. The unit then remained at essentially full power for the balance of the period.
Unit 2 entered the inspection period at 100 percent power. On September 23.~the unit i
was downpowered to approximately 85 percent for turbine valve testing and waterbox inspections. The unit returned to full power on September 25 and remained at
essentially full power for the balance of the inspection period.
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I. Operations
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Conduct of Operations
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01.1 General Canments (71707)
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Using Inspection Procedure 71707, the inspectors conducted frequent reviews of ongoing plant operations.
In general, the conduct of operations was professional and safety-conscious:. specific events and noteworthy observations are detailed in the sections below.
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While touring the Unit 2 control room on October 1. the inspector noted that the 28 High Pressure Safety Injection (HPSI) pump discharge pressure was
indicating approximately 880 psig. The inspector questioned control room operators on the indication and found that no operator could explain the
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indication. Upon reviewing strip chart recorder output and control room logs, the inspector determined that the pressure indication was the result of a 2B HPSI pump run made a week prior to the observation (pressure trapped between check valves). The inspector concluded that the lack of operator knowledge of the source of the pr' essure indicated poor attention to detail during board
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walkdowns and a lack of sensitivity to the potential for intersystem Loss of Coolant Accident (LOCA).
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01.2 Control Room Observation (71715)
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Inspection Scope The inspector monitored, control room and plant activities during the week of September 9, 1996. Particular attention was given to special or non-routine evolutions in progress, communications and procedural compliance.
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Observations and' Findings
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d The inspector noted that the control room environments for both units were quiet and professional. The operators' conformed to the requirements of the
Conduct of 00erations procedure. Operators were attentive to plant parameters
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and conditions and followed procedures as required by plant policy.
Communications between crew members were also satisfactory, The inspector
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-noted that one_ licensed Senior Reactor Operator (SRO) was directing and supervising the operation of Unit 2 as the Assistant Nuclear _ Plant Supervisor
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(ANPS) trainee. Another SRO was the a6tual watcb3tander noted on the' logs.
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When this SR0 was out of the control-room, the trainee.was in charge. The '
.1 inspector noted that the chronological logs for the shift did not indicate
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that the trainee had held the command and control function. While this did
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not violate any log keeping requirements, the practice does not emphasize the j
need for accountability. The licensee took immediate corrective action and
issued a bulletin in the night orders to correct the discrepancy.
The inspector al.so observed administrative' practices while'in the control room and was concerned that some unnecessary administrative burden may detract from
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the _ control room supervisors ability to monitor plant operations. In the past large numbers of procedure Temporary Changes (TCs) had been processed through the' control rooms via the Nuclear Plant Supervisor (NPS). The inspector reviewcd the TC process and found one TC to an I&C maintenance. procedure which t
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marked as a " Procedural Improvement" rather than " Technically Incorrect."
- Upon close scrutiny, the inspector determined that the procedural errors were quite obvious. These errors could have been discovered and corrected prior to-
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issuance of the procedure rather than relying on the control room staff to review and approve changs resulting from on-the-job validation. While the licensee's administrative procedures allow the m e of TCs to effect procedural changes under some conditions without the Facility Review Group's (FRG) prior
approval, the control room supervi. sors primary function is to monitor and supervise the safe operation of tne plant..
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Conclusion
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Control room watchstanding practices were satisfactory. Watchstanders maintained a professional environment and were attentive to plant parameters and conditions.
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Operational Status'of Facilities and Equipment 02.1 Enoineered Safety Feature System Walkdowns (71707)
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Inspection Scope-The inspector performed a walkdown of the accessible portions of the Unit 1 and 2. Component Cooling Water (CCW) systems and the Unit 1 Low Pressure Safety Injection _(LPSI) system,
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Findings
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- In performing these walkdowns, the inspector verified the proper installation f
of hangers and supports: the adequacy of housekeeping: correct valve positions
-and conditions; proper labelling; and expected instrument indications. A step
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ladder was identified 'in the 1A LPSI pump room. A tag was affixed which
' stated that the ladder had been put in place on June 6, 1996 to facilitate an i
inspection of a welded joint. The licensee was informed and removed the
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i ladder from the area.
The following drawing discrepancies were noted:
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8770-G-083. Sheet 1. Revision 44. " Flow Diagram Component Cooling System" (Unit 1) indicated the following instruments were installed: PX
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14-1A. PX 14-2A, TE 14-1A, PX 14-18. PX 14-2B, and TE 14-1B. The
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instruments were.not installed as depicted on the drawing.
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2998 G-083, Sheet 1. Revision 32. " Flow Diagram Component Cooling (2)-
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System" (Unit 2) did not indicate that valves SB14169 and SB14439 were to be LOCKED CLOSED. The valves were in fact LOCKED CLOSED in accordance with Administrative Procedure 2-0010123. Revission 75.
" Administrative Control of Vales. Locks and Switches."
l The licensee was informed and initiated Plant Management Action Item (PMAI)
l 96-10182 to investigate and correct as necessary.
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Conclusions
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The inspector concluded that the equipment areas were generally clean, valves j
were properly positioned and labelled, and support equipment was acceptable.
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The license ~e took the appropriate action with regard to the. step ladder once identi fied.
-04 Operator Knowledge and Performance j
04.1 2A Emeroency Diesel Generator Surveillance Testina (61726)
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Scope The inspector observed portions of a surveillance test of the 2A Emergency
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Diesel Generator (EDG) conducted on October 9.
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Findings
i The inspector.noted that. operators were performing their activities in
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accordance with Procedure OP 2-2200050A. Revision 24. "2A Emergency Diesel j
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Generator Periodic Test and General Operating Instructions."- During the surveillance,- the inspector noted that EDG cooling water expansi'on tank level l
. indicated high (above the upper mark on a sight glass). -The inspector also
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noted a placard which stated that the level'should be between the upper and j
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lower marks during' hot and cold, running and idle conditions. The inspector
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. questioned the' licensee as to the applicability df the placard and was '
informed that the placard was in error and that it would be removed and
replaced with a correct placard which allowed for expansion of EDG coolant.
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The inspector also noted that a Real Time Training Coach (RTTC) was covering the' activity. The RTTC was a relatively new development in the training area
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in which instructors are assigned to the field to observe and coach personnel
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in maintenance, engineering and operations..The inspector discussed the
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'part of the Training Department.
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Following the surveillance, the inspector witnessed a post-evolution
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debriefing of.the operators involved. The activity was facilitated by the ANPS and was attended by the RTTC. The activity solicited comments from j
l operators on how the activity could be improved. and resulted in several positive contributions from the Non-Licensed Operators (NL0s) performing the evolution. The inspector found tflis practice to be an excellent method for
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continuous improvement of Operations' practices.
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Conclusion
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i The inspector concluded that the subject surve11' lance test had been I
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accomplished satisfact'rily. Additionally.'the inspector found the use of-o I
RTTCs to be innovative and proactive Training involvement in plant activities.
The use of post-evolution debriefings was viewed as an excellent practice'for operational improvement.
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Operator Training and. Qualification
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05.1 Trainino Bulletins (71001)
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Inspection Scope The Inspector reviewed the Training Bulletins (tbs) that were in the control
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room during the control room observations. The tbs constitute part of the on-shift training requirements of the licensed operator'requalification
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program.
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Observations and Findings
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- The inspector;found three tbs which had not been reviewed by all, operators by j
the required due dates.. 0ne TB. "Standdown Package for Tempo.rary Changes'."
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was due to be completed by July 5, 1996. Another TB containing Revision 71 to'
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the " Conduct of Operations Procedure" had a due date of July 6. 1995. 'This TB had been signed off;as.having been reviewed by an operator as late as
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September 12.-1996. -The procedure contained in the.TB had been revised 14
. times since the issuance of the TB. Yet another TB on the " Work It Now
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Program" had a due date of August'5, 1995, and had been reviewed by an
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operator as late as September 10. 1996: These T8s contained outdated material that could be mistaken for current guidance. Procedure AP 0005720. " Licensed Operator Requalification Program." required that each NPS/ANPS ensures that each member of the crew reviews Training Bulletins and completes any other on shift training requirements including the necessary documentation.
It further states that each licensee understands the content of on-shift training and associated documents and properly documents the training. St. Lucie Training Department Guideline No. TG-005 " Processing and Distribution of Training Bulletins." contains specific requirements for monitoring all outstanding tbs. Specifically, bulletins found to be incomplete will be monitored and every 15 days past the requested review completion date, the Training Section Supervisor will be notified of the delinquency. The inspector concluded that the requirements and intent of these procedures had not been met and was concerned that important emergent training information was not being assimilated by the operators. The inspector noted that.the licensee identified the non-compliance regarding the tbs in Condition Report 96-618 dated May 2. 1996. The licensee also instituted a RTTC Program in August which is described in Procedure OI 1-PR/PSL-10. " Training Organization." This program in part provides real time on-shift training on the most important issues such as industry /in-house events. The licensee also revised Procedure-0005720 (Revision 40). This procedure now contains new requirements concerning tbs and invokes a policy of removing an operator's access authorization for failure to complete the required reading by a specified date.
In addition, all old tbs were removed from the control room.
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Conclusion The inspector determined that the licensee had not complied with the requirements of procedures 0005720 and TG-005, constituting a violation of Technical Specification 6.8.1.a.
The corrective actions taken were
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satisfactory. The inspector determined that the implementation of a RTTC Program was an effective tool to rapidly disseminats important training information to the operators. This licensee-identiffed and corrected violation is being treated as a Non-cit'd Violation, consistent with Section e
VII.B.1 of the NRC Enforcement Policy (NCV 335.389/96-15-01. " Failure to implement Training Bulletins in Accordance with Requalification Program Procedure").
Operations Organization and Administration (71707)
On September 10 the licensee implemented a major site reorganization.
Notable in the reorganization were the placement of all site engineering j
organizations under the Site Engineering Manager (who reports directly to the
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Vice President. Engineering, in Juno Beach).
Included in this group were
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Reactor Engineering. Shift Technical Advisors ~ (STAS).. Systems Engineering, ind System Performance Engineering (re'sponsible for ISI and IST).
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Reporting to A. Stall. Site Vice President are:
J. Scarola. Plant General Manager j
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D. Fadden. Services Manger
E. Weinkam. Licensing Manager
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G. Boissy, Materials Manager
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R. Heroux, Business Systems Manager
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R. Sipos. Steam Generator Replacement Project Manager
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Reporting to the Plant General Manager are:
J. Marchese, Maintenance Manager
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H. Johnson. Operations Manager
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C. Wood. Acting Work Control Manager
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Reporting to the D. Denver Site Engineering Manager, are:
R. Church. Administrative Supervisor
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R. Gil. Plant Engineering Manager e
J. Fulford, Operations Support Engineering Supervisor
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K. Mohindroo, Project Engineer /FSAR
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M. Snyder Project Engineer / Maintenance Rule
J. West. System Engineering Manager
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Inciuded in this reorganization was the augmentation of the System Engineering and Plant Engineering organizations, accomplished through transferral of staff
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The inspector noted that the licensee had reviewed and updated plant Quality
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Instructions (Ols) to reflect the new organization and to specify organizational responsibilities under the new organization.,A training bulletin was developed highlighting the changes. The inspector. concluded that the licensee had appropriately implemented the changes made during this reorganization.
Miscellaneous Operations Issues 08.1 Inadvertent BvDassina of the Wrona Unit 1 Enaineerina Safeauards Features Actuation System (ESFAS) Sianal (71707)
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Scope On September 18, 1996 the licensee received indicatioris of a bistable problem associated with ESFAS cabinet channel "0" Investigation identified that the
"B" Steam Generator (SG) Pressure Main Steam Isolation Signal (MSIS) in that channel had failed. Operations determined that the failed bistable could be
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bypassed in accordance with the Unit 1 technical specifications. However.
Operations mistakenly bypassed the channel
"D" "A" SG Pressure MSIS. This condition was discovered by Maintenance personnel approximately 11.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />
after the mistake occurred.
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Findings I
Once identified. the licensee realigned the' system appropriatelp. The
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~0perating crew associated with.the event conducted a crew self assessment to j
' identify strengths and weaknesses which led to the event. The assessment
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identified that poor labelling of the bypass switches and keys and a lack of questioning attitude led to the wrong ESFAS bistable being bypassed. In addition, it was noted that an independent verification was performed but '
failed to identify the mistake.
The inspector. examined the affected components imediately after the problem was identified and noted that the labelling was extremely confusing. For example, the physical layout of the panel resulted in modules from one bistable being aligned with the' bypass switches of a different bistable.
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.addition, the bypass switches were identified as Unit 2 rather than Unit 1.
The inspector reviewed Procedure AP 1-0010123. Revision 102. " Administrative Control Of Valves, Locks. And Switches," and verified that, although the Operator obtained the wrong key to bypass the bistable, it was obtained in accordance with the procedure. The procedure contained no guidance or verification to ensure that the key requested was actually the key needed to perform the required function.
A log identifying each key and its function was included as an Attachment in'
the procedure, however, it was only used to audit the key lockers. After the deficiencies'were corrected, the inspector verif.ied the labelling to be much
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improved.
In addition, a night order was issued which highlighted the problem and requested a more questioning approach to activities by the Operations personnel. This night order was discussed by the Nuclear Plant Supervisors
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with personnel associated with their shift.
Technical Specification 3.3.2.1 states, in part. that the ESFAS
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l instrumentation channels and bypasses shown in Table 3.3-3 shall be operable.
Table 3.3-3 item 4.b states, that the total number of channels for the MSIS
' function actuated due to SG Pressure Low, is four per SG. Action statement i
9.a for this Table states, in part, with the number of_ operable channels one
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less than the total number of channels, operation may proceed provided the inoperable channel is placed in either the bypassed or tripped condi. tion l
within one hour. The ESFAS channel
"D" "B" SG Pressure MSIS was inoperable for approximately 11.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> on September 9 and 10 and was not bypassed or
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placed in a tripped condition. 'This licensee identified and corrbeted violation is being treated as a Non-Cited Violation consistent with'Section
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VII.B.1 of the NRC Enforcement Policy and is identified as NCV.
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50 335/96-15-02. " Inadvertent Bypassing of the Wrong ESFAS Signal."
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Conclusions _
~ The inspectors concluded that exceptionally poor labelling led to the Noncited Violation (NCV) identified above. While generally it would be expected that an independent verification would have identified th_is problem sooner, the combination of poor labelling and procedural guidance was such that this was
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ineffective. Once identified, the system was appropriately aligned and the-Llabelling corrected.
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08.2 ' (Closed) IFI 50-335 & 50-389/94-300-01: Procedures 00 Not Provide Information
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On Securina Reactor Coolant Pumos (RCPs) Before The Reactor Coolant System
-Temoerature Decreases Below 500 F (92901)
a.
Inspection Scope
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The licensee's Emergency Operating Procedures (E0Ps) did not provide explicit
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instructions to operators.to ensure that one Reactor Coolant Pump was secured
prior to the Reactor Coolant System (RCS) temperature decreasing below 500 F.
During simulator scenarios, operators were observed to. secure one RCP only
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when they got to specific procedural guidance. This occurred after RCS-temperature decreased below 500 F on three out of four occasions.
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b.
Observations and Findings
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The inspector noted that Procedure E0P-01, " Standard Post Trip Actions " now contains guidance which should ensure that one RCP is secured prior to the RCS
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reaching 500 F.
This guidance is encountered early in the procedure for any reactor trip and should enable the operators to secure an RCP when required.
c.
Conclusion The inspector concluded that the EOP procedural guidance was satisfactory.
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II. Maintenance M3 Maintenance Procedures and Documentation M3.1 Control of Maintenance Backloos (62703)
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a.
Scope
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The inspector r,eviewed controls for maintenance activities and the monitoring of maintenance backlogs.
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b.
Findings The inspector noted that the licensee, as a part of morning management-meetings, has. adopted a. practice of reporting on' maintenance and other
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backlogs. With respect to maintenance backlogs reductions have been realized due to a combination of improved scheduling and an increase in the use of Work h
it Now (WIN) teams; which perform minor maintenance activities outside of the
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scope of standard maintenance planning and control processes.
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-The-inspector reviewed controls applied to' WIN team activities. Procedure
ADM-80.01. Revision 2,." Control of Minor Maintenance Activities." was
developed which defined the scope and type of work which could be performed
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under the process. The inspector found that the work activities defined in
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Appendix A of the procedure'(e.g. packing adjustments on valves not subject to testing) were appropriate to work outside the traditional work control process..The inspector reviewed the WIN team open requests database, and found that minor maintenance activities were appropriately tracked, and that activities wnich were found to be outside of the-scope of the minor
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maintenance program were appropriately closed to Work Requests (WRs) under the formal maintenance control process. Each item was found to have been reviewed
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by an SR0 for applicability to minor maintenance.
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The inspector reviewed the licensee's progress on minor maintenance activities since April and found that, as of October 7. 753 individual activities had been worked under the minor maintenance program. Of those. 24 had been closed
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out;to work requests.. indicating both a high level.of accuracy in identifying
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candidate activities for minor maintenance and sensitivity in the screening
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process for ' items which did not belong in minor maintenance.
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The inspector also reviewed the processing of canceled WRs to ensure that reductions in maintenance backlogs were not realized due to wholesale l
cancellations of requested work. A sample of WRs canceled since June was
. reviewed. The inspector found that WR cancellations were performed appropriately, with most cancellations involving adding the given activities
to a previously planned Plant Work Order (PWO) (as opposed to' creating a
. separate PWO) or by referencing an identical WR/PWO combination which performed the same activity. The inspector reviewed PW0s referenced in WR cancellations and found that the requested work activities were incorporated appropr-iately.
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The inspector reviewed the licensee's weekly plant indicators for October 8.
In it. the licensee tracked a number of key indicators of plant performance.
The indicators were discussed at morning management meetings.
In the area of maintenance backlogs. the inspector noted that the licensee was tracking (among other things) the number of open PW0s. PWO age. control room instruments out-of-service, number of PWO awaiting parts. _ Trends generally reflected reductions in both the number of open PW0s and the age of PW0s. The
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inspector found that management attention to backlogs had increased and that i
the tracking mechanisms employed, and the discussions surrounding the indicators, were effective in. producing reductions in backlogs.
c.
Conclusions
The inspector concluded.that the licensee has made progress in the
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identification and reduction of maintenance backlogs as a result of improved i
scheduling, management attention, and the use of the minor maintenance
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process. Win Team activities were reviewed and were found to be appropriately defined. Work Request cancellations reviewed during the period were found to have been performed appropriately.
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M7-Quality Assurance in Maintenance Activities O
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M7.1 M&TE Noncomoliances identified. By Ouality Control (OC) Deoartment (62703)
a.
Scope The inspectors reviewed Quality Control activities associated with an inspection of M&TE administrative controls.
b.
Findings
During a monthly surveillance of calibration activities. OC identified three areas of noncompliance with Procedure 01 12-PR/PSL-2 Revision 22. " Control And Calibration Of Measuring And Test Equipment (M&TE)."
1.
Section 5.3.1.A required a calibration sticker to be attached to each M&TE item. Contrary to this. item E-586 was identified in the general population without a calibration sticker affixed.
2.
Section 5.3.2 required that the M&TE storage area have sufficient
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separation between the ready-to-use equipment (calibrated and restricted use) and other equipment (rejected) to preclude inadvertent use.
Contrary to this, item E-593 had a Reject sticker affixed to it but was not segregated to preclude use.
In addition, items E-647. E-253. and E-648/15 were out of calibration but were also stored in the general population ready for use.
3.
Section 5.3.2.C required that the M&TE storage areas shall be maintained by a designated individual responsible for logging in and out all M&TE.
In the absence of this individual, the storage areas shall be locked with access and logging controlled by the responsible supervisor.
Contrary to this, the OC inspector observed three electricians and one I&C technician access the facility to obtain M&TE.
In addition, the QC inspector-identified through interviews that other non-supervisory personnel had access to the M&TE facility.
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Condition Report (CR) 96-2203 was initiated to document these discrepancies.
When the problem was identified, the not-ready-to-use M&TE items were
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segregated from the ready-to-use items. Additionally, the Maintenance Manager changed the locks on the M&TE storage area doors and restricted access to Chiefs. Foremen, and Supervisors only. A memo was sent to all maintenance personnel addressing the requirements of 0112-R/PSL-2 and stressing procedural adherence. This licensee identified and corrected violation is being treated as a Non-Cited Violation consistent with Section VII.B.1 of the NRC Enforcement Policy and is identified as NCV 50-335.389/96-15 03. " Quality Control Identification of M&TE Issues "
c.
Conclusions Quality Control effectively identified weaknesses in the M&TE program as id'entified in the NCV documented ab'ove. Once the problems were identified.
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corrective actions were implemented.
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M8 Hiscellaneous Maintenance Issues
M8.1 (Closed) Unresolved Item 50-335/96-14-02-Control Of M&TE (92902)
This item was open pending review of additional information related to the use of.M&TE during maintenance on the Unit 1 linear power range detector #9. The l
licensee replaced this detector in accordance with Work Order 95031787 Testing of the detector was conducted in accordance with I&C Procedure-l 1200062. Revision 5. " Uncompensated Ion Chamber Acceptance Test." The Work
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Order indicated that the ohmmeter used to obtain the p6st-installation resistance readings of the detector was a Biddle model BM-10. M&TE item PSL-865. These readings were obtained on June 26. 1996.
The inspector reviewed the ' sage log for this meter on that date and noted u
that it had not been logged out for maintenance associated with this Work Order. The licensee investigated and determined that meter.PSL-865 had been l
. logged out for another maintenance activity and was simply " borrowed" to obtain the measurements required.by Work Order 95031787. However, when this
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activity was complete. the maintenance w6rkers failed to identify this use of
the meter on the usage log. The inspector reviewed the usage log and verified that meter PSL-865 had been logged out on June 25 for another maintenance activity and logged back in on June 27, 1996.
Procedure 01 12-PR/PSL-2 Revision 21. " Control And Calibration Of Measuring And Test Equipment (M&TE)," Section 4.2.4. states. in part, that borrowing of M&TE in the field is not an acceptable practice.
In addition. Section 5.3.4.A requires. in part, that each item of M&TE shall have a log sheet filled out to identify each activity where the ' instrument was used. Failure to log maintenance associated with Work Order 95031787 on the usage log for meter PSL 865 is a violation of this procedure and is being identified as'VIO 335/96-15-04. " Failure to Control M&TE."
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III. Enaineerina E3 Engineering Procedures and Documentation
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E3.1 Containment Atmosoheric Rcdiation Monitor Desian Basis Documents (37551)
a.
Scope
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During this report period the inspectors performed an inspection of the Unit 1 Containment Atmo' spheric Radiation Monitoring system.
b, Findings
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During a Unit 1 Containment Radiation Monitor system wal,kdown, the inspector
observed the sample flow rate to be approximately 2.2 scfm. Further
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inspection determined that the normal flow rate was 3.5 scfm. The inspector asked the licensee if the monitor's radiation alarm setpoints were affected by the reduced flow rate.. The licensee provided CR 96 1983. which documented the low flow condition, and an operability assessment which concluded that the system was operable with a flow. rate of less than 3.0 scfm. However, the licensee was unable to produce calculations or Other documentation which
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' determined what the alarm setpoints should be or how they were to be established. The li,censee stated that the setpoints were established, using engineering judgement, at twice the normal background radiation' level with the reactor at power for the Alert alarm, and three times the normal background radiation level for the High alarm. The inspector reviewed the applicable sections of the Updated Final Safety Analysis Report (UFSAR) and noted that it
made no mention of alarm setpoints on this monitor.
i In response to the inspectors questions, the licensee generated an action plan
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i to develop the design basis documents and calculations for the system.
In addition. CR 96-2228 was initiated to review the applicable UFSAR sections and make appropriate revisions as necessary. Pending review of this data, this
item will be tracked as URI 335, 389/96-15-05. " Inadequate Design Basis j
Documentation."
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Additionally, the inspector noted the following Unit 1 UFSAR discrepancies:
UFSAR section 5.2.4.6 states that the rate of change in indication of the various leak detection parameters provides the necessary information
.to identify and' estimate reactor coolant i;ystem leakage rates for a 1.0 gpm leak. Table 5.2-11 lists the amount.of' time for a 1 gpm leak to be detected as evidenced by a 10 percent deviation in the normal readings.
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The inspector observed the Containment Radiation Particulate and Gaseous meters channels 31 and 32. respectively, to deviate by more than 10
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percent normally, without a 1 gpm leak. The licensee is investigating
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the basis for this method of leak detection.
UFSAR section 5.2.4.5.b.1 states that the level detector which measures leakage fl6w through the containment sump weir is non-seismic. The detector is in fact seismically qualified. This section also states that the recorder wil.l.have a full scale range.of 0 to 11 gpm. The-recorder. FR-07-03, in fact has a range of 0 to 12 gpm.
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.UFSAR section.5.2.4.5.b 2 stated that the Containment Atmosphere.
Radiation Monitoring System took isokinetic samples of air from the
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containment cooling system ductwork. Section 12.2.4.1 stated that the sample nozzles were designed such that the sampling velocity was the same as that in the ventilation system so that preferential particulate selection did not-occur. Through discussions with the licensee, the i
inspector determined that the system flow rate was greater than the sample flow rate. 'Therefore the system was not isokinetic but rather subisokinetic.
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.UFSAR Table 5.2-11. item (1) referenced Figure 5.2-36.
This figure did
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not. exist Item (2) stated that the instrument range for the quench tank water level was 0 to'48 inches. The instrument. LIA-1116. actually'
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. indicated from 0 to 100 percent.
Item (3) stated that Safety Injection
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Tank water level instruments ranged from 0 to 336 inches. The
. instruments. LIA-3311. 3321. 3331. and 3341, actually indicated from'0 to 100 percent in the plant. Also, item (3) indicated that the Safety Injection Tank pressure instruments ranged from 0 to 250 psig. The instruments'. PIA-3311.' 3321. 3331. and 3341. actually indicated from 0 t
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to 300 psig in the plant.
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UFSAR section 12.2.4.1 stated that the sample flow was regulated and indicated by independent mass flow meters. While the flow was indicated by independent mass flow meters. it war not regulated. The system flow
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was' dependent only on the capability of'the pump.
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These discrepancies will be tracked as additional examples of failure to update the UFSAR identified as URI 50-335.389/96-04-09. " Failure to Update
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UFSAR."
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Conclusions
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Results of this inspection indicated a general lack of design basis documentation for this system. Because the licensee has initiated action to verify system operability and determine design basis, this issue will be i
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tracked as an unresolved Item (URI).
In addition, five additional examples of failure to. update the UFSAR were. identified.
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IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls
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R1.1 Unit 1 Containment Radiation Monitor Out Of Service Due To Miscositioned Valve
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(71750)
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Scoph a.
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On September 14. 1996, the Unit 1 containment radiation monitor was removed from service to allow Health Physics (HP) personnel to ob'.'ain a grab sample.
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Upon completion of this. activity, a system valve was not properly realigned
'and resulted in the. system being inoperable. The' condition was identified by
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the' Unit 1 Senior Nuclear. Plant. Operator (SNPO) and was subsequently corrected.
- b.
-. Findings (
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The grab sample was obtained in accordance with Procedure HPP-22. Revision 4?
" Air Sampling " Appendix A..After the sa7ple was..obtained. the HP technician reported to the Unit 1 Control Room that the monitor had been realigned.for-l
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e normal operation. Operations subsequently declared the monitor back in service. Approximately two hours and fifteen minutes after.the system was removed from service, the Unit 1 SNP0 noted that the system flow rate was low.
indicating approximately 0.15 scfm. Normal system flow was approximately 3.5 scfm. The control room was notified and HP personnel were dispatched to verify the system valve lineup. Upon review of the lineup.'it was identified that sample valve #3 was CLOSED instead of FULL OPEN as required. The valve was subsequently opened and system flow returned to the normal value of 3.5 scfm. CR 96-2232 was initiated to document this event and develop corrective action.
The licensee's investigation determined that sample vaTve #3 had not been realigned as required after obtaining the sample.
In addition, the lic.ensee discovered that the HP technician performing this task did'not have the proccdure'in hand while obtaining the sample. The licensee's corrective actions included properly realigning the system upon discovery of the problem and subsequent disciplinary action against the involved individual.
The inspector reviewed the CR and HPP-22 and concluded the procedure was adequate to perform the evolution..
In addition. the inspector verified through discussior)s with Training department personnel and records review that adequate training had been provided to Health Physics personnel in the area of procedural usage and compliance. Discussions with the involved personnel i
confirmed the licensee's findings with regard to the individual not having a procedure in hand during this evolution.
l Procedure 01 5-PR/PSL-1. Revision 73, " Preparation. Revision. Review / Approval
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Of Procedures." section 5.14.1 requires verbatim compliance to procedures by all personnel. In addition, step 5.14.4.A.3 requires that procedures containing tasks which must be performed in a specified sequence and/or which verification is documented by initial or signature must be present and referred to directly during the performance of the activity.. ailure to have F
Procedure HPP-22. Revision 4. " Air Sampling." Appendix A in hand, while it was bsing performed on September 14, 1996 is a violation of Procedure 01 5-PR/PSL'-1 and is identified as VIO 50-335/96-15-06. " Failure of HP to Have Procedure In Hand During Realignment of Unit 1 Containment Radiation Monitor."
This violation is a repeat occurrence of VIO 50-335/96-04-01. " Failure To Follow Procedures Lead to Unit 1 Containment PIG Inoperability."
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c.
Conclusions The inspector coricluded that because the involved individual did not have a procedure in hand and follow it as required the violation as stat'd above e
occurred. This is'a repeat violation. Good attention to detail was noted on the part of the SNP0 who identified the subject condition.
R1.1 ' Oil Catchment Boxes Within the Radiation Control Area (RCA) (71707)
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a.
. Inspection Scope
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The inspector toured the RCA and reviewed the method used to release oil catchment box liquid from the RCA. The oil catchment boxes are underground tanks which hold runoff liquid from the diesel generator buildings. The
majority of the liquid in these tanks is water.
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Observations and Findings
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The inspector noted that liquid pumped from the Unit 1 Emergency Diesel Generator oil catchment box was stored in 55 gallon drums located 6n a flatbed truck. This liquid had not yet been tested or released from the RCA. The inspector became aware of a previous incident described in Condition Report No. 96-2199 where on August 2. 1996. liquid from the Unit 2 EDG oil catchment box had been released from the RCA prior to ensuring that the liquid activity level was'less than the environmental. release limits. The inspector inquired as to the status of the present batch of drums and was told that they were awaiting testing. The inspector, reviewed the maintenance procedure governing the oil separating box inspections. Procedure M-0018 and noted that chemistry.
- had the assigned responsibility to test the samples from the oil catchment boxes. The inspector interviewed the Health Physics Manager and inquired as to the adequacy of using the hot chemistry lab for the testing. He indicated that the correct method for testing the liquids was to.use the low background GELI detector located in the training building. This detector had been out of service for many month's resulting in a backlog of liquids to be sampled and released. The licensee generated a' Procedure Change Request for Procedu,re M-0018 Appendix A. "011 Separating Box Inspection." The procedural changes assigned responsibility for the testing of the liquid to Health Physics and specified the sampling techniques and specific requirements that must be met prior to release of the liquid from the RCA. The inspector toured the RCA and
. located the ten 55 gallon drums associated with the August 2. 1996 incident in the dry storage building along with numerous other 55 gallon drums which were awaiting testing. The ten drums containing the Unit 2 EDG catchment box liquid were marked with contamination stickers indicating detectable activity levels.
c.
Conclusion The inspector was satisfied that the revised procedure was adequate to ensure that unmonitored release of 55 gallon drums _would not occur and had no safety concerns.regarding the revised sampling process. This issue will remain open as.an Unresolved Item. URI 50-335.389/96-15-07. " Contaminated 55 Gallon Drums
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Improperly Removed from RCA." pending further inspection efforts concerning the incident.which. occurred on August 2. 1996.
- R8 Miscellaneous RP&C Issues
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R8.1 (Closed) Unresolved Item 50-335/96-14-03i Failure' To Procerly Alion The Unit
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1 Containment Radiation Monitor (92901)'
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This issue involved the failure to properly realign the containment radiation monitor following a functional test of the Post Accident Sampling System
.(PASS) control panel.
Issues surrounding this event invol.ved general procedure usage as well as the quality. of the procedure being used'by the chemistry technicians at the time-of the event. The failure to properly realign the-system resulted in the inoperability of trie Unit 1 containment radiation monitor, which shared a return line to containment with the PASS system and which was isolated when the PASS system was tested..A SNPO identified a low flow condition in the monitor, indicating good attention to'
detail while performing tours.
The procedure being used at the time of the event was Chemistry Procedure 1-C-112. Revision 16. " Operation And Calibration Of The Milton Roy Post Accident Sampling System." With regard to the quality of this procedure. the
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inspector concluded that while it was poorly written. the procedure did
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contain all the necessary actions to accomplish its purpose. Severai steps in the procedure contained multiple actions-including the step that was inappropriately performed. The' licensee submitted a procedure change request
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.to format the procedure consistent with the other Chemistry Procedures and to limi't the actions of individual steps to one.
- i Regarding the technician's use of the proced'ure, the inspector concluded that
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the individual had the procedure in hand while performing the evolution and was signing steps off as they were completed. Approximately two hours after completing the PASS panel test. the low flow condition with the containment
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radiation monitor was identified by an operator anu was subsequently corrected. Followup investigation by the licensee concluded that the technician failed to deenergize the PASS panel upon completion of the i
functional test. Failure to deenergize the PASS panel was a violation of'
Chemistry Procedure 1-C-112, step.8.1.33. This licensee identified and
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corrected violation is being treated as a'Non-Cited Violation' consistent with Section VII.B.1 of the NRC Enforcement Policy and is identified as NCV 50-335/96-15-08. " Failure to Follow Procedure During PASS Operatton."
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S2 Status of Security Facilities and Equipment (71750)
a.
Scope-On October 10. 1996, the inspector walked down the protected area barriers.
In performing these walkdowns. the inspector verified the fence fabric had no unintentional openings, was not degraded, and was not eroded at the base:.
isolation zones were free of objects and well illuminated; and compensatory
. guard postings were in place as necessary.
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Findings
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The inspector found no discrepancies with the protected area barriers,
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c; Conclusions
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The' protected area barriers were in good condition, the isolation zones well
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-lit, and the appropriate compensatory guard postings in place.
V. Manaoement Meetinas and Other Areas-
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XI.
Exit Meeting Summary o
The inspectors presented the inspection results to members of licensee management at
' the conclusion of inspections on September 13 and Octooer 18. The licensee
' acknowledged the findings presented.
~ The inspectors asked the licensee whether.any materials examined during the.
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' inspection should be considered proprietary. No proprietary information was
identified.
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PARTIAL LIST OF PERSONS CONTACTED
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Licensee'-
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- W.B1adow. S.ite Quality' Manager.
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--H. Buchanan. Health Physics Supervisor l-D, Fadden. Site Services Manager
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- R; Dawson. Business Manager
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O. Denver. Site Engineering Manager
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i D. Faulkner. Chemistry Supervisor
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.. Fulford.' Operations Support Engineering Manager
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-J. Holt. Information Services Supervisor.
H. Johnson. Operations Manager l
l J. M1rchece. Maintenance Manager
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L C. Marple. Operations Supervisor
. C. 0*Farrel. Reactor Engineering Supervisor
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'A. Pawley, instrument and Control Maintenance Supervisor j
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J. Scarola. St. :Lucie Plant General Manager
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'A. Stall. Site Vice President
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E. Weinkam. Licensing Manager l
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C. Wood. Acting Work Control Manager
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We White. Security Supervisor Other licensee' employees contacted included office, operations. engineering, l
maintenance, chemistry / radiation.-and corporate personnel.
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INSPECTION PROCEDURES USED t
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~l IP'37551:-
Onsite Engineering
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- IP 61726i
' Surveillance Observations ilP 62703:
- Maintenance Observations i
IP 71001i
. Licensed Operator Requalification Program Evaluation
IP 71707i Plant Operations i
IP 71715:
Sustained Control Room and Plant' Observation
-IP:71750:
' Plant Support Activities IP 92901:
Followup - Plant Operations i
IP.92902;.
Followup - Maintenance-
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l ITEMS OPENED. CLOSED AND DISCUSSED
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50 335/96-15 04 VIO
" Failure to Control M&TE" e
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' 50-335.389/96-15-05 0RI
" Inadequate Design Basis Documentation"
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50-335/96 15-06
'VIO
" Failure of HP to Have Procedure'In Hand During
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-Realignment of Unit 1 Containment Radiation Monitor"
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i 50-335.389/96-15-07 URI
" Contaminated 55 Gallon Drums Improperly Removed
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From RCA"'
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Closed l
50-335.389/96-15 01 NCV
" Failure to Implement Training Bulletins in Accordance with Requalification Program Procedure"
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50-335/96-15-02
.NCV
" Inadvertent Bypassing of the Wrong ESFAS Signal"
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50-335.389/96 15-03 NCV
" Quality Control' Identification of M&TE Issues"
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f>0-335/96-15-08 NCV Failure to Follow. Procedure During, PASS Operation"
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50-335.389/94-300-01 IFI
" Procedures Do Not Provide Information On Securing
RCPs Before The Reactor Coolant System Temperature i
Decreases Below 500 F "
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50-335/96-14-02'
" Control of M&TE" i
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..50-335/96-14 03
.URI
" Failure To Properly Align The Unit 1 Containment
Radiation Monitor" j
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= Discussed ~
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.50-335.389/96-04-09 URI.
" Failure to Update UFSAR" i
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LIST OF ACRONYMS USED
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'ADM Administrative Procedure
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ANPS Assistant Nuclear Plant Supervisor _.
ATTN Attention
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CCW-Component Cooling Water CFR Code of Federal Regulations-
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CR Condition Report
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DPR'
Demonstration Power Reactor (A type of operating license)
EDG -
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E0P'
Emergency Operating. Procedure l
ESFAS-Engineered Safety Feature Actuation System l
FPL'
The Florida Power & Light-Company l
FR Federal Regulation
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