IR 05000335/1997016
| ML20217G287 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 03/25/1998 |
| From: | Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Plunkett T FLORIDA POWER & LIGHT CO. |
| Shared Package | |
| ML20217G293 | List: |
| References | |
| 50-335-97-16, 50-389-97-16, EA-98-009, EA-98-9, NUDOCS 9804020269 | |
| Download: ML20217G287 (7) | |
Text
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY -
$88.000 (NRC SPECIAL INSPECTION REPORT NOS. 50-335/97-16.
50-389/97-16)
Dear Mr. Plunkett:
This refers to the inspection conducted on November 3. 1997, through January 9. 1998, at the St. Lucie facility.
The results of the inspection were formally transmitted to you by letter dated January 23. 1998. An open.
3redecisional enforcement conference was conducted in the Region II office on ebruary 13. 1998, with you and members of your staff to discuss the apparent violations, the root causes, and corrective actions to preclude recurrence. A list of conference attendees, co)ies of the Nuclear Regulatory Commission's (NRC's) slides, and Florida and
)ower Light Company's (FP&L) presentation materials are enclosed.
In addition, a video 3 resented by FP&L at the predecisional enforcement conference is availa)le in the NRC Region II office.
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Based on the information developed during the inspection and the information that you provided during the conference, the NRC las determined that two violations of NRC requirements occurred.
The violations are cited in the enclosed Notice of Violation, and the circumstances surrounding them are described in detail in the subject ins)ection report.
Violation A involves the failure to ensure that the design ] asis was correctly translated into specifications, drawings, procedures, and instructions.
Specifically, in 1993 you revised the Unit 1 Refueling Water Tank (RWT) instrument loop and bistable calculation to establish a new setpoint for the RWT level instruments and bistables.
This new setpoint was not correctly translated into instrument calibration procedures.
This resulted in a Recirculation Actuation Signal (RAS) bistable setpoint of 36 inches indicated level, instead of 48 inches indicated level as required by Technical Specifications (TSs).
Violation B. a direct result of the incorrect RWT setpoint, is associated with the failure to comply with two TSs.
TS 3.3.2.1 requires that the trip setpoint for the Containment Sump Recirculation actuation signal be set at 48 inches above the RWT bottom.
Because the tri) setpoint for the RAS was set at 36 inches instead of 48 inches above t1e RWT bottom, you failed to comply with this TS for the period of April 1993 until December 1997.
TS 3.5.2 requires that two independent Emergency Core Cooling System (ECCS) subsystems be operable with 9004020269 980325
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each comprised of an independent operable flow nath capable of taking suction from the RWT on a safety injection signal and automatically transferring suction to the containment sump on an RAS.
The incorrect setpoint would cause ECCS pump air entrainment under certain design basis accident scenarios.
Given the air entrainment into the ECCS pumps you did not have reasonable assurance that the ECCS systems would remain operable under all postulated accident scenarios.
Therefore, the NRC considers that the ECCS systems were inoperable, and thus you failed to comply with TS 3.5.2.
The analysis performed by your staff and that of your contractor, as referenced in Licensee Event Report 50-335/97-011. supports this conclusion.
The root cause of the violations was a failure to follow setpoint program and Engineering Quality Instructions which resulted in a failure to properly revise the RWT level bistable calibration procedure.
Although there was not an actual safety consequence of the incorrect RWT set)oint as safety systems were not called upon to function, this issue is risc significant and has potential safety consequences.
The design basis of your facility requires that durirg certain loss of coolant accidents (LOCAs).
ECCS subsystems must be capable of automatically transferring suction to the containment sump upon receipt of an RAS.
Because of the incorrect trip setpoint of the RWT level instrument bistables automatic transfer of the ECCS pumps' suction source from the RWT to the containment sump under certain conditions would cause an open channel flow condition.
This condition could cause damage to the ECCS pumps because of air entrainment, absent operator intervention to manually initiate transfer to the containment sump prior to the open channel condition.
Systems affected by this condition include the high pressure safety injection system. the low pressure safety injection system, and the containment spray system, which are designed to prevent or mitigate serious safety events.
Damage to these systems because of air entrainment would prevent them from performing their intended safety function.
The NRC recognizes that your Emergency Operating Procedures require monitoring of the RWT level. and direct operators to manually transfer the ECCS pump suction source from the RWT to the containment sump, if necessary.
However.
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the design basis of the plant calls for automatic transfer of the ECCS suction source.
In such a case, your analysis as described in Licensee Event Report 50-335/97-011 and as presented during the enforcement conference. concluded that there was a substantial increase in the core damage frequency (i.e..
based on your calculations, you estimated the core damage frequency increased by a factor of two to 5.5E-5).
This further confirms the significance of these violations.
For these reasons. these violations represent a very significant regulatory concern.
Therefore. Violations A and B have been classified in the aggregate in accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy).
NUREG-1600, as a Severity Level II problem.
In accordance with the Enforcement Policy. a base civil penalty in the amount of 588.000 is considered for a Severity Level II problem.
Because your facility has been the subject of escalated enforcement actions within the last
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.3 two years'. the NRCl considered whether credit'was warranted for Identification and Corrective Action in accordance with the civil penalty assessment process in Section VI.B 2. of the Enforcement Policy. ' This issue was -identified-
> because of critical, questioning attitudes by operations and engineering-
. personnel.
During replacement of the RWT level circuitry bistable cards in October 1997, a main control room operator initially questioned a difference
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in.the safeguards cabinet RWT level meter reading when compared-to the meter
. reading prior to replacement. After notifying engineering personnel, the system engineer reviewed this anomaly and. in addition, conducted a thorough review of-the RWT level circuitry which led to the identification of the incorrect RAS set)oint.
In addition, your corrective actions were comprehensive.
S1 ort-term corrective actions included verification that the
' issue was limited to only the Unit 1 RWT level RAS setpoint, formation of an.
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event response team which identified the root cause and contributing causes, revision of Engineering Quality Instructions to clarify requirements regarding transmittal of design information to the plant and use of engineering hold
points for critical design aspects revision and cross-referencing of bistable calibration procedures. and re-emphasis of management expectations'on design transmittal requirements. You also conducted an unannounced simulator exercise with a minimum control room staff to gain a high level of confidence that operators would manually. initiate a transfer of the ECCS pump suction source to the containment sump prior to pump damage given a failure of an automatic transfer to the sump.
Finally. you initiated a comprehensive engineering program implementation review to verify that the root and contributing causes which led to this setpoint error were not translated into dther engineering programs. As of the date of the predecisional enforcement conference, reviews for many programs have been completed. with other program reviews in 3roaress and planned. Thus, based on the above. the NRC has concluded tlat credit is warranted for Identification and Corrective Action.
Notwithstanding credit for Identification and Corrective Action. the NRC considers the exercise of discretion to propose a civil ]enalty for problems categorized at Severity Level I or II in accordance witi Section VII.A.1 of the Enforcement Policy.
In this case, the violations resulted in a
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significant increase in risk over the more than four year period in which the conditions' existed.
In addition. the violations are not associated with old design issues in that they were caused by engineering performance deficiencies in the 1990's.
Moreover, better quality assurance of engineering activities at the time of the setpoint change could have ]revented the violation altogether.
Therefore, after consultation wit 1 the Director, Office of
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Enforcement. and the Deputy Executive Director for Regulatory Effectiveness. I have been authorized to exercise discretion to propose a base civil penalty of I A Severity Level Ill problem was issued on December 11. 1997., associated with the failure to maintain two trains of containment cooling operable as required by Technical Specifications (EA 97 501). A Notice of Violation (NOV) and Proposed Imposition of Civil Penalty in the amount
- of $100.000 was issued on January 10. 1997 for violations of the plant security access control
- program.- the emergency preparedness program and requirements for nuclear instrumentation (EAs96-458. -464, and -457). A Severity level Ill violation was issued on September 19. 1996, associated with the failure to comply with 10 CFR 50.59 (EA 96 326). An NOV and Proposed Imposition of' Civil Penalty in the amount of $50,000 was issued on March 28. 1996. for multiple
Lviolations associated with a dilution event (EA 96-040).
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- 588.000 in this case.
This penalty is intended to emphasize the importance of effective engineering activities and associated quality assurance commensurate with the core damage risk.
If not for the questioning attitudes displayed by your staff and, in particular. the aforementioned licensed operator and system engineer, which led to the identification of the setpoint error, a more substantial civil penalty would have been proposed.
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.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice." a copy of this letter, its enclosures, and your response will be placed in the NRC Public Document Room (PDR).
Sincerely, orignial signed by L. Reyes Luis A. Reyes Regional Administrator Docket Nos.
50-335, 50-389 License Nos.
1.
List of Attendees 3.
NRC Slides 4.
Licensee Material
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FP&L-
cc w/encls:
J. A. Stall Site.Vice President St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach. FL 34957 H. N. Paduano, Manager Licensing and Special Programs Florida Power and Light Company P. O. Box 14000 Juno Beach. FL 33408-0420 J. Scarola
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Plant General Manager St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, FL 34957 E. J. Weinkam
' Licensing Manager St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach. FL 34957 M. S. Ross. Attorney Florida Power & Light P. O. Box 14000 Juno Beach. FL 33408-0420 John T. Butler. Esq.
Steel. Hector and Davis 4000 Southeast Financial Center Miami. FL 33131-2398
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Bill Passetti Office of Radiation Control De)artment of Health and Rehabilitative Services 1317 Winewood Boulevard Tallahassee. FL 32399-0700 a
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cc w/encls:
Director Division of Emergency Preparedness
. Department of Community Affairs 2740 Centerview Drive Tallahassee. FL 32399-2100 County Administrator St. Lucie County 2300 Virginia Avenue Ft. Pierce. FL 34982
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