IR 05000335/1999005
| ML17241A484 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 09/20/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17241A483 | List: |
| References | |
| 50-335-99-05, 50-389-99-05, NUDOCS 9910080205 | |
| Download: ML17241A484 (17) | |
Text
{{#Wiki_filter:U.S. NUCLEAR REGULATORYCOMMISSION
REGION II
Docket Nos: 50-335, 50-389 License Nos: DPR-67, NPF-16 Report Nos: 50-335/99-05, 50-389/99-05 Licensee: Florida Power 8 Light Company Facility: St. Lucie Nuclear Plant, Units 1 8 2 Location: 6351 South Ocean Drive Jensen Beach, FL 34957 Dates: July 11 - August 21, 1999 Inspectors: T. Ross, Senior Resident Inspector D. Lanyi, Resident Inspector G. Warnick, Resident Inspector J. Lenahan, Regional Inspector (Section M.4) Approved by: A. Boland, Acting Chief Reactor Projects Branch 3 Division of Reactor Projects 9910080205 990920 PDR ADOCK 05000335
PDR Enclosure
EXECUTIVE SUMMARY St. Lucie Nuclear Plant, Units 1 8 2 NRC Inspection Report Nos. 50-335/99-05, 50-389/99-05 This integrated inspection included aspects of licensee operations, engineering, maintenance, and plant support.
The report covers a six-week period of resident inspection, and an in-office review by a regional inspector.
~oerations ~ A non-cited violation was identified for several procedural adherence errors associated with reactor protection system logic matrix testing, one of which caused two pairs of trip circuit breakers to be open at the same time. However, since both pairs of breakers were supplied by the same motor generator all control element assemblies remained energized.
The operating crew supervision overseeing the test failed to adequately control and resolve difficulties encountered while performing the test. (Section 01.2) New fuel receipt, inspection, and transfer activities were conducted in accordance with procedural requirements.
Required records and logs were maintained during all fuel inspections and transfers.
Operators performing the activities were knowledgeable and the level of supervision provided for these efforts was appropriate.
(Section 01.3) Nonconservative decision-making, schedule pressures, insufficient questioning attitude, and inadequate implementation of the corrective action process contributed to the inadvertent heat-up of the reactor coolant system during Unit 2 Cycle 11 mid-loop operation.
A non-cited violation was identified for inadequate identification and correction of degraded shutdown cooling system performance. (Section 07.1) Licensee evaluations, root cause analysis, Quality Assurance audit, and self-assessment efforts to address the Unit 2 shutdown cooling system event last outage were comprehensive, thorough, and self-critical. The resulting corrective actions appropriately targeted identified causes, complemented each other well, and appeared to be effective.
(Section 07.1) Maintenance ~ Observed maintenance and surveillance activities were performed consistent with established work control processes.
Risk assessments were performed prior to emergency diesel generator and start-up transformer maintenance outages to ensure there were no significant increase in risk. Also, unavailability time during these critical maintenance activities was managed appropriately.
(Section M1.1) ~ A non-cited violation was identified for the failure to maintain adequate procedures for conducting engineering safeguards actuation functional testing.
Due to the longstanding procedure errors, both safety injection actuation systems have been blocked simultaneously for short periods during monthly surveillance testing, which is a condition prohibited by Technical Specifications. (Section M8.1) ~En ineerin ~ Reactivity Management Event summaries provided specific insights of recent events from a reactor engineering perspective and were a useful tool in succinctly
communicating the scope and impact of reactivity management events to management.
(Section E1.1) Recent failures associated with the control room air conditioning system were appropriately evaluated with respect to the Maintenance Rule. The licensee's monitoring and tracking through the use of system performance windows has led to increased reliability of several systems that are important to safety. (Section E2.1 and E2.2) Health Physics response to a contamination event was in accordance with licensee procedure and exhibited appropriate radiological control practices.
(Section R4.1) Walkdown of the protected area fence found it in good condition, and isolation zones were free of obstructions.
(Section S2.1)
Re ort Details Summa of Plant Status'oth units operated continuously at essentially full power for the entire report period.
01.1 Conduct of Operations General Comments (71707) 01.2 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.
Reactor Protection S stem Lo ic Matrix Testin S {I>> d Il{{ On August 9, 1999, Operations performed a routine surveillance of the Unit 1 reactor protection system'logic matrix. During the performance of the testing, several personnel errors occurred, one of which resulted in the opening of two sets of trip circuit breakers at the same time. The inspector reviewed the applicable procedure and discussed the event with Operations supervision and other personnel involved.
Observations and Findin s Operating Procedure OP 1-1400059, Reactor Protection System - Periodic Logic Matrix Test, prescribed the requirements for conducting logic matrix testing.
Discussions with licensee personnel indicated that the pre-evolution briefing addressed the precautions, limitations, and contingencies related to the procedure.
Personnel conducting the testing were advised how to back out of the procedure ifconditions warranted.
This was a first time evolution for the Assistant Nuclear Plant Supervisor (ANPS), and the Nuclear Plant Supervisor (NPS) was present to provide general oversight.
The first testing error occurred while performing Section 8.2 of the procedure, Verification of Matrix Hold Coils and Bistable Trip Unit Test Coil. This portion of the test required that the operator rotate the matrix relay trip select switch sequentially through each of its eight positions and verify that proper light indication occurred each time. However, on one occasion, the operator inadvertently turned the select switch too far, going past the next position. The NPS discontinued the surveillance and discussed the incident. The apparent cause was identified by the licensee as a sticking switch coupled with an operator's previously injured finger.
During this test, the operator is required to hold down a pushbutton to maintain the hold relays energized for the matrix ladder being tested.
While holding the pushbutton, the operator rotates the trip selector switch. This releases only those bistable trip relays that have operating contacts in the logic matrix being tested.
During the evolution, the operator stated that he was experiencing thumb pain due to holding down the pushbutton.
The second error occurred during the conduct of the end of Section 8.2, which directs the operator to return the channel trip selector switch to the neutral position and then release the pushbutton.
However, in this case, the operator released the pushbutton and then turned the selector switch. There was no consequence to the error
in that under normal circumstances, just releasing the pushbutton should not have any effect on the plant. Again, the testing was stopped, and the crew discussed the importance of ensuring that the selector switch is placed in a neutral position prior to releasing the pushbutton.
The final error occurred while performing Section 8.3 of the procedure, Two-out-of-four Logic Matrix Test.
This portion of the surveillance required the operators to insert a test signal which causes a set of two trip circuit breakers to open.
The procedure included a caution to the operators to ensure that the breakers were shut after performing each matrix test, and the operators stated that they remembered discussing this precaution prior to the test.
However, after performing the testing for opening trip circuit breakers 3 and 6, the ANPS, who was responsible for reading the procedure, inadvertently omitted Step 8.3.7 which required closing these trip circuit breakers.
The next matrix test was performed, and trip circuit breakers 4 and 8 were opened, as procedurally required.
The operator at the control board promptly noted that both pairs of circuit breakers powered from a single motor generator were open.
The surveillance was stopped. The circuit breakers were closed, and the crew conducted a self-critique. A different operator was assigned to continue the test, and the surveillance,was subsequently completed without further incident.
Technical Specification 6.8.1.a requires that the procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, including Section 4.y (reactor protection system), be established, implemented, and maintained.
Contrary to this requirement, as described above, during the performance of Unit 1 logic matrix testing operators failed to properly implement procedural requirements. This Severity Level IV violation is being treated as a non-cited violation (NCV), consistent with Appendix C of the NRC Enforcement Policy, and is identified as NCV 50-335/99-05-01, Failure to Properly Perform Logic Matrix Testing. This violation is addressed in the licensee's corrective action program as Condition Report 99-1390.
Based on a review of this event and discussions with the involved personnel, the inspector made several observations.
The procedure had not been significantly changed in the recent past.
It is routinely performed on a monthly basis, generally, without incident. For this test, the ANPS stated that he had directly observed the discomfort being experienced by the operator responsible for holding down the pushbutton, and consequently felt pressure to complete the procedure quickly which likely contributed to missing the step for closing circuit breakers 3 and 7. The inspector noted that the ANPS, failed to take corrective action (e.g., replace the operator) when he first identified that the operator was suffering pain due to performing the procedure.
The consequences from the failures to followprocedure were minimal; however, had both pairs of trip circuit breakers not been supplied by the same motor generator, half of the control element assemblies would have dropped into the core.
At the end of the report period, the ANPS was conducting a performance review of the testing events to determine additional corrective actions to prevent recurrence of similar problem Conclusions A non-cited violation was identified for several procedural adherence errors associated with reactor protection system logic matrix testing, one of which caused two pairs of trip circuit breakers to be open at the same time. However, since both pairs of breakers were supplied by the same motor generator all control element assemblies remained energized.
The operating crew supervision overseeing the test failed to adequately control and resolve difficulties encountered while performing the test.
New Fuel Transfer And Recei t Ins ection (60705 and 71707) The inspectors observed the receipt of new fuel for the upcoming Unit 1 refueling outage as well as the transfer of the fuel to the new fuel storage racks and the spent fuel pool.
Additionally, the inspectors monitored receipt inspections of the new fuel conducted by a fuel vendor representative and a reactor engineer.
The evolution of receipt and storage of the new fuel was scheduled to occur over a two month period.
During these activities, operators used Operating Procedure 0-1610020, Receipt and Handling of New Fuel and Control Element Assemblies.
The operators were thoroughly knowledgeable with the procedure and adhered to it accordingly. Appropriate records and logs were maintained during fuel inspections and transfers, and the level of supervision was also appropriate.
During this inspection period, the inspector did not identify any issues regarding the fuel receipt, inspection, or transfer activities.
Operational Status of Facilities and Equipment General Plant Tours (71707) Frequent plant tours were conducted by the inspectors to examine the physical condition of plant equipment and to verify that safety systems were properly maintained and aligned.
Overall material condition was good.
Several, minor equipment and housekeeping problems were identified and referred to the licensee for resolution. The licensee either immediately corrected these items or placed them in their corrective action program for resolution.
En ineered Safet Feature S stem Walkdowns (71707) The inspectors walked down accessible portions of the following Engineered Safety Feature systems: Condensate Storage Tank - Unit 1 Auxiliary Feedwater - Unit 1 Intake Cooling Water - Unit 1 Shield Building Ventilation System - Unit 2 Shield Building Ventilation System - Unit 1 Equipment operability, material condition, and housekeeping were acceptable in all cases.
Several minor discrepancies were brought to the licensee's attention and corrected.
The inspectors identified no substantive concerns as a result of these walkdown O3 03.1
Operations Procedures and Documentation Review of E ui ment Clearance Orders (71707) On July 29, 1999, the inspector performed a review of all Unit 2 equipment clearance orders that had been in effect for greater than 30 days.
Administrative Procedure ADM-09.04, In-Plant Equipment Clearance Orders, was reviewed and referenced by the inspector to verify that the clearance order audits were being performed as required.
Additionally, a walkdown of selected equipment clearance orders verified that required tags were present and in appropriate condition. Several minor deficiencies were identified and have been addressed through the licensee's corrective action program.
07.1 Quality Assurance In Operations Unit 2 Shutdown Coolin S stem Problem Identification and Resolution a.
71777 The inspector reviewed the closed out condition reports (CR), the root cause analysis, and Quality Assurance audit that addressed numerous problems with the Unit 2 shutdown cooling system (SDCS) experienced during the Unit 2 Cycle 11 (SL2-11) refueling outage.
The inspector also reviewed the results of two separate licensee self-assessments conducted by corporate management and an onsite management team.
Responsible managers and plant personnel who were directly responsible for investigating, resolving and assessing the problems related to degraded SDCS performance and inadequate system evaluations were interviewed.
Observations and Findin s As described in Section 01.3 of NRC Inspection Report (IR) 50-335, 389/98-11, dated ,January 12, 1999, the licensee entered mid-loop conditions for Unit 2 on November 11, 1998, with a degraded SDCS that resulted in an unexpected heat up of the reactor coolant system (RCS). The root cause was determined to be excessive bypass control valve, FCV-3301 and 3306, seat leakage which adversely affected SDCS heat exchanger performance.
Plant personnel failed to recognize the impact this degraded condition would have on decay heat removal capability during mid-loop operations.
Section 01.3 of IR 50-335, 389/98-11 also described licensee actions and inspector efforts in response to the incident. A number of CRs were generated to address the difficulties operators experienced in their attempts to establish stable mid-loop conditions and the problems that arose due to degraded SDCS performance.
As described in IR 98-11, the inspectors reviewed the interim disposition of these CRs, including operability and reportability concerns, and monitored recovery actions to establish safe mid-loop operation and refueling outage conditions for Unit 2.
Following the SL2-11 refueling outage, the corporate office initiated a special review of several events that occurred during the outage, which included the SDCS event.
The investigation was completed, and the NRC was briefed on the results on March 21, 1999. One of the actions which resulted from the corporate review was for the onsite management team to conduct a comprehensive self-assessment of the SDCS even During the later part of February 1999, responsible senior onsite managers formed a self-assessment team along with the Plant General Manager from Turkey Point. This team conducted a broad, high level assessment of the conditions and circumstances leading to, and resulting in, the inadequate performance of the SDCS during the mid-loop evolution. Generic implications were also considered, in particular, corporate management's concern regarding the conservatism of plant decision-making and planning processes for managing shutdown risk. The team presented their conclusions and proposed corrective actions to the Nuclear Division President on March 23, 1999, and a summary report was issued on March 26, 1999.
On February 12, 1999, the Quality Assurance organization issued a report of their functional area audit of the Nuclear Fuels, Refueling Operations, and Special Nuclear Material Controls programs conducted during SL2-11. This audit report had only one finding that stated, "During the SL2-11 refueling outage, the functional integrity of shutdown cooling was repeatedly threatened by adverse conditions that should have been avoided."
In response to the audit finding, the licensee initiated CR 99-0216.
Condition Report 98-1749 was closed out and approved on December 30, 1998. This CR was used to consolidate the multiple CRs generated during SL2-11 to address mid-loop and SDCS related problems.
When it was completed, it provided a thorough, detailed analysis of the SDCS event and recommended numerous specific and generic actions.
As part of these corrective actions, Supplement 1 to CR 98-1749 was initiated to better document a formal root cause analysis of the event and to consolidate all associated corrective. actions from the previous CRs, Quality Assurance Audit, and management self-assessment.
Condition Report 98-1749-1, Root Cause Analysis of SL2-11 Refueling Outage Shutdown Cooling Event, was completed and issued on April 19, 1999. The inspector reviewed this report, and verified the status of corrective actions, particularly those applicable to Unit 1. At the end of this inspection period, the licensee had not completed all of the corrective actions required to support the Unit 1 refueling outage (SL1-16); however, they were scheduled for completion prior to unit shutdown on September 13, 1999.
In summary, the licensee identified the following principal causes and lessons learned regarding the Unit 2 shutdown cooling event: 1) No operability determination was performed to address the excessive seat leakage through FCV-3301 identified in 1995, and the licensee failed to work the valve prior to shutting down for SL2-11; 2) Material condition and health of the SDCS was not questioned or reviewed despite known bypass valve leakage, particularly given the decision to move up the schedule for mid-loop operation which greatly increased the decay heat load and reduced the time to boil; 3) Operability of the SDCS for SL2'-11 was not challenged during system warm-up and reduced inventory conditions even after system parameters demonstrated significantly degraded performance; 4) Inadequate compensatory measures and contingencies were established to fully, comply with Nuclear Division policy on "Shutdown Risk;"
5) Pre-outage safety evaluation and risk assessment processes did not adequately address several important aspects such as single train failure and RCS pressurization following loss of shutdown cooling; and 6) Schedule pressures on the organization resulted in the failure to use industry standards for ensuring an adequate vent path, and taking credit for reflux boiling to prevent RCS pressurization.
The inspector concluded that these, and other less significant causes pnd lessons learned identified by the licensee, were the result of an very thorough, self-critical multi-disciplined and multi-level effort to examine all relevant information and address the circumstances and implications surrounding the Unit 2 shutdown cooling event of November 1998. The numerous corrective actions appropriately targeted identified causes, complemented each other, and appeared to be effective.
Overall, the licensee's evaluations, root cause analysis, Quality Assurance audit and self-assessment efforts were comprehensive and thorough.
However, the inspector concluded that a violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, occurred.
Specifically, the licensee failed to adequately identify and correct a significant 'condition adverse to quality regarding the Unit 2 SDCS.
On two separate occasions, the licensee had an opportunity to recognize and resolve demonstrated evidence of degraded SDCS performance and failed to adequately do so.
First, a plant work order was written in 1989 regarding excessive SDCS bypass valve leakage of FCV-3301 which was not worked and subsequently canceled.
Another work order was initiated in November 1995 to rebuild the valve due to leak test results of greater than 900 gallons per minute (gpm), but this work order was not completed and remained outstanding at the time of SL2-11. Second, on November 9, 1998, Operations and Engineering personnel observed 833 gpm and 1233 gpm seat leakage through both bypass valves FCV-3301 and 3306, respectively, during initial system warmup.
However, they did not utilize the corrective action process to address the condition and assess the ability of the SDCS to remove decay heat.
This Severity Level IVviolation is being treated as a non-cited violation (NCV), consistent with Appendix C of the NRC Enforcement Policy, and is identified as NCV 50-335/99-05-02, Inadequate Corrective Actions To Resolve Degraded Shutdown Cooling System Performance.
This issue is addressed in the licensee's corrective action program as referenced above.
Conclusion Nonconservative decision-making, schedule pressures, insufficient questioning attitude, and inadequate implementation of the corrective action process contributed to the inadvertent heat-up of the reactor coolant systeni during Unit 2 Cycle 11 mid-loop operation. A non-cited violation was identified for inadequate identification and correction of degraded shutdown cooling system performance.
The licensee's evaluations, root cause analysis, Quality Assurance audit, and self-assessment efforts to address the Unit 2 shutdown cooling system event last outage were comprehensive, thorough, and self-critical. The resulting corrective actions appropriately targeted identified causes, complemented each other well, and appeared to be effectiv II. Maintenance M1 Conduct of Maintenance M1.1 Maintenance Work Order and Surveillance Observations a.
Ins ection Sco e (61726 and 62707) The inspectors observed portions of the following maintenance and surveillance activities, including Plant Work Orders (PWO), Operations Procedures (OP), and Operations Support Procedures (OSP): OP 2-2200050B OP 0-1400058 PWO.99011462 OP 1-0700050 PWO 99014091 PWO 98023466 OP 2-0110050 1-OSP-24.01 Multiple PWOs Multiple PWOs 2B Emergency Diesel Generator Periodic Test Seismic Instrumentation Periodic Check Fuel Handling Building Radiation Monitor Calibration Auxiliary Feedwater Periodic Test 2C Charging Pump Discharge Safety Relief Valve Replacement Control Element Assembly 2 Indication Restoration Control Element Assembly Periodic Exercise Reactor AuxiliaryBuilding Fluid Systems Periodic Leak Test 1A Emergency Diesel Generator Maintenance Outage Startup Transformer Maintenance Outage b.
Observations Findin s and Conclusions The ins o observ pect rs ed that work was performed consistent with the established work control processes.
Maintenance supervision and Engineering were closely involved in the work activities. Briefings conducted prior to the initiation of work activities were satisfactorily completed in accordance with Operations procedural guidance.
The tasks were performed by knowledgeable workers who actively used applicable work packages and procedures.
The inspectors observed that work activities were properly documented.
Additionally, issues encountered during the performance of the maintenance and surveillance activities were appropriately resolved.
Risk assessments performed prior to the emergency diesel generator and startup transformer critical online maintenance outages were also reviewed.
No significant increase in risk occurred as a result of these maintenance activities, and unavailability time was managed appropriately.
M4 Maintenance Procedures and Documentation M4.1 Reactor Su ort Coolin S stem Flow Ad'ustments a.
Ins ection Sco e (62707) The inspectors reviewed the licensee's evaluation and corrective actions associated with Condition Report 98-155 b.
Observations and Findin s Condition Report 98-1556 was initiated to review and disposition identified issues relating to operation of the reactor support cooling system (RSCS).
The licensee's review determined that adjustments had been made to RSCS flow switches and dampers without adequate written guidelines or adequate procedural instructions.
Ad'ments were made to clear low fiow alarms in both Units 1 and 2. The RSCS had been tested and adjusted during startup testing to assure that the system was p ope y jus n r rl b I ced and met the design flow requirements.
The licensee determined, based on a a ance CS review of temperature data, that the adjustments/maintenance performed on the RS did not degrade system performance.
Corrective actions initiated by the licensee to address this issue and to control future maintenance work on the system were as follows: The maintenance work history performed on the dampers in the RSCS was reviewed.
This review determined that this work did not impact the initial flow balancing performed on this system.
The heating, ventilation, and air conditioning ductwork drawings for the RSCS were reviewed to verify adequate flow monitoring locations existed.
Drawings and procedures were revised to clarify setpoint information specified in plant procedures to reflect current plant practices.
The safety classification of the instrumentation was also clarified.
Based on the review, the inspector concluded that performance of adjustments to the RSCS flow switches without adequate written guidelines or adequate instructions was a violation of the requirements of 10 CFR 50, Appendix B, Criterion V. However, the inspector concurred with the licensee's assessment that the adjustments did not degrade RSCS system performance.
Therefore, this failure constitutes a violation of minor significance and is not subject to formal enforcement action.
c.
Conclusions A minor violation was identified regarding the performance of adjustments to the RSCS without adequate written guidelines or adequate instructions.
This problem was adequately addressed by the licensee's corrective action program.
Operation of the RSCS was not affected.
INIscellaneous INaintenance Issues M8.1 Closed LER 50-335 389/1999-002: Both Trains of Safety Injection Actuation Blocked During Surveillance Due to Procedure Error. (92902) This Licensee Event Report (LER) documented longstanding procedural errors for both units. The procedures directed licensee personnel to momentarily block both trains of safety injection (Sl) actuations while performing monthly functional tests.
Technical Specification Table 3.3-3, Section 1.d required two channels of the SI actuation system, to be operable in Modes 1 through 4. Action statement 12 stated, in part, that with the'umber of channels one less than the total number of channels, restore the inoperable
channel to operable status."
There were no applicable Technical Specifications associated with both channels being inoperable.
Therefore, operation with both channels blocked was prohibited, and the provisions of Technical Specification 3.0.3 apply. This required the plant to be in hot standby within one hour.
The licensee and the inspector reviewed several years of logs, and a definitive determination as to whether both channels were ever blocked for greater than one hour could not be made.
However, based upon current practices, the Sl actuation should never have been blocked for more than a few minutes at a time. Therefore, no instances in which the action time of Technical Specification 3.0.3 was exceeded were identified.
Criterion V of Appendix B to 10 CFR 50 requires, in part, that activities affecting quality shall be prescribed by procedures of a type appropriate to the circumstances.
Contrary to this requirement, Procedures 1-IMP-69.02 and 2-IMP-69.02, "Engineered Safeguards Actuation System Monthly Functional Test," were not appropriate to the circumstances in that they contained errors held over from the original pre-operational test procedures which resulted in simultaneously blocking both Sl actuation system signals.
This Severity Level IVviolation is being treated as a non-cited violation, consistent with Appendix C of the NRC Enforcement Policy, and is identified as NCV 50-335, 389/ 99-05-03, Procedural Error Caused Both Trains of Safety Injection Actuation to be Blocked. The licensee developed extensive corrective actions documented in the LER and tracked in Condition Report 99-0596.
This LER is closed.
III. En ineerin Conduct of Engineering'eactivit Mana ement Event Reviews The licensee's reactivity management program requires review of any incident that could have caused or resulted in an unplanned reactivity change.
Five reactivity management events (RME) were recently reviewed by reactor engineering as part of this program.
All five events occurred on Unit 2 between May and June.
The inspector reviewed the RME ., summaries originated by the site Reactor Engineering group for all five events.
These summaries concisely addressed all relevant information, which included plant conditions, event description, event cause(s), and immediate and long term corrective actions.
Although each of these events had been previously addressed as part of the CR process, the RME summaries provided insights and corrective actions tailored from a reactor engineering perspective.
The inspector concluded that the summaries appeared to be a useful tool for succinctly communicating the scope and impact of RMEs to plant management and other personnel.
E2 E2.1 Engineering Support of Facilities and Equipment Control Room AirConditionin - Maintenance Rule Im lementation (62707) On July 10, 1999, the Unit 1 control room air conditioner ACC-3C was identified by the licensee as failing its surveillance and not capable of cooling the control room envelope as required.
The control room air conditioners were considered as a non-risk significant; heating and ventilation system in the licensee's Maintenance Rule program; thus only requiring the use of plant level performance criteria. However, Engineering had also
assigned a performance criteria of less than or equal to two maintenance preventable functional failures per train for the control room air conditioning systems.
The inspector reviewed the previous 18 months of work requests for all six (three per unit) air conditioners for Maintenance Rule compliance.
Unit 1 ACC-3A and Unit 2 ACC-3C required significantly more corrective maintenance than the other air conditioning units. The licensee had determined that most of the failures did not cause a train of the system to be inoperable.
Upon discussion of each failure with the system engineer, the inspector concurred with the assessments.
The inspector concluded that the system appropriately remained in (a)(2) status, and was being adequately monitored in accordance with the Maintenance Rule program.
S stem Performance Window Review (37551 and 40500) The inspector observed the licensee's periodic review of system performance for the second quarter 1999.
In general, the licensee continued to make progress towards improving plant system performance.
For those systems with unacceptable or marginal performance, the licensee has developed reasonable corrective action plans with defined goals.
This monitoring and tracking mechanism has led to increased reliability of several systems that are important to safety.
Miscellaneous Engineering Issues Year 2000 Y2K Readiness of Health Ph sics Information S stem (Tl 2515/141) The inspector conducted a review of Y2K documentation associated with the recently installed health physics administrative computer system using Temporary Instruction (Tl) 2515/141, Review of Y2K Readiness of Computer Systems at Nuclear Power Plants.
Documents reviewed included the Software Verification and Validation Plan and the Software Certificate of Compliance for Y2K Operation.
Tests performed and software certifications were adequate to demonstrate the licensee's determination that the Health Physics Information System is Y2K compliant.
Closed LER 50-389/1999-004 and 50-389/1 999-004-01: As Found Cycle 10 Pressurizer Safety Valve Setpoints Outside Technical Specification Limits. (92903) This LER reported that all three pressurizer safety valves exceeded their Technical Specification setpoints after removal from the plant during the Unit 2 Cycle 11 refueling outage.
Technical Specification 3.4.2.1 required that the pressurizer safety valves liftat 2500 psia plus or minus one percent.
As determined through testing by an offsite vendor, all the valves removed from Unit 2 lifted at greater than one percent above the setpoint, one of which lifted greater than three percent above the setpoint.
The American Society of Mechanical Engineering code required the licensee to perform a cause determination and to implement corrective action when a tested pressurizer safety relief valve exceeded the liffsetpoint by greater than three percent.
The inspector reviewed the licensee's cause determination and safety implications and concluded that the licensee's findings as stated in the LER were reasonable.
This LER is close IV. Plant Su ort R4 Staff Knowledge and Performance in Radiation Protection and Chemistry R4.1 Health Ph sics Performance (71750) The inspectors observed health physics response to an individual who alarmed the portal monitor at the exit of the radiologically controlled area, including decontamination efforts and evaluation of the areas where the individual could have been contaminated.
Afterthe individual alarmed the exit portal monitor, he was moved to a decontamination area.
The health physics technician {HPT) performed a methodical frisk of the contaminated area and identified slight contamination of the individual's shoe of approximately 500 counts per minute.
Using proper radiological techniques, the HPT successfully decontaminated the area.
Following decontamination, the inspector observed that the HPT performed area contamination surveys to verify that the individual had not spread any contamination.
Additionally, the plant areas where the individual had been were wiped down to minimize the possibility for further spread of contamination.
Overall, the inspector concluded that the HPT followed the procedural requirements for handling a contaminated individual and exhibited appropriate radiological work practices.
S2 Status of Security Facilities and Equipment S2.1 Protected Area Fence Walkdown (71750) The inspector performed a routine walkdown of the protected area security fence.
The areas observed were found to be in good condition and free of openings in excess of regulatory guidelines.
Isolationzoneswerefreeofobstructions.
Lighting levelswere adequate.
V. Ilana ement Meetin s X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on August 31, 1999. The licensee acknowledged the findings presented.
The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary.
No proprietary information was identiTied.
PARTIALLIST OF PERSONS CONTACTED Licensee M. Allen, former Operations Manager C. Bible, Site Engineering Manager G. Bird, Protection Services Manager W. Bladow, Maintenance Manager R. De La Espriella, Quality Assurance Manager D. Fadden, Training Manager W. Gufdemond, Operations Manager C. Ladd, Operations Supervisor
A. Stall, St. Lucie Plant Vice President E. Weinkam, Licensing Manager R. West, St. Lucie Plant General Manager
, Other licensee employees contacted included office, operations, engineering, maintenance, chemistry/radiation, and corporate personnel.
INSPECTION PROCEDURES USED IP 37551: IP 40500: IP 60705: IP 61726: IP 62707: IP 71707: IP 71750: IP 81700: IP 92901: IP 92902: IP 92903: TI 2515/141 Onsite Engineering Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems Preparations for Refueling Surveillance Observations Maintenance Observations Plant Operations Plant Support Activities Physical Security Program for Power Reactors Followup - Operations " Followup - Maintenance Followup - Engineering Review of Y2K Readiness of Computer Systems at Nuclear Power Plants ITEIIS OPENED AN CLOSED ~Oened 50-335/1999-05-01 50-389/1 999-05-02 NCV Failure to Properly Perform Logic Matrix Testing (Section 01.2) NCV Inadequate Corrective Actions To Resolve Degraded Shutdown Cooling System Performance (Section 07.1) 50-335,389/1999-05-03 NCV Procedural Error Caused Both Trains of Safety Injection Actuation to be Blocked (Section M8.1) Closed 50-335,389/1 999-002 50-389/1999-004 50-389/1 999-004-01 50-335/1999-05-01 LER Both Trains of Safety Injection Actuation Blocked During Surveillance Due to Procedure Error (Section M8.1) LER As Found Cycle 10 Pressurizer Safety Valve Setpoints Outside Technical Specification Limits (Section E8.2) LER As Found Cycle 10 Pressurizer Safety Valve Setpoints Outside Technical Specification Limits (Section E8.2) NCV Failure to Properly Perform Logic Matrix Testing (Section 01.2)
NCV Inadequate Corrective Actions To Resolve Degraded Shutdown Cooling System Performance (Section 07.1) 50-335,389/1 999-05-03 NCV Procedural Error Caused Both Trains of Safety Injection Actuation to be Blocked (Section M8.1) }}