IR 05000335/2010006
| ML101100013 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 04/19/2010 |
| From: | Hopper G Reactor Projects Branch 7 |
| To: | Nazar M Florida Power & Light Co |
| References | |
| IR-10-006 | |
| Download: ML101100013 (20) | |
Text
April 19, 2010
SUBJECT:
ST. LUCIE NUCLEAR PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000335/2010006 AND 05000389/2010006
Dear Mr. Nazar:
On March 19, 2010, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your St. Lucie Nuclear Plant Units 1 and 2. The enclosed report documents the inspection results which were discussed on March 19, 2010, with Mr. R. Anderson and other members of your staff.
The inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, compliance with the Commissions rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of plant equipment and activities, and interviews with personnel.
The team concluded that problems were properly identified, evaluated, and resolved within your corrective action program. Prior to our inspection, your self-assessment team found some examples of minor problems associated with identification of plant issues, problem evaluation, and implementation of corrective actions. Our inspectors found similar minor problems which are discussed in the attached report. There was one green finding identified during this inspection for the failure to promptly correct a known condition adverse to quality. This finding was determined to be a violation of NRC requirements. However, because of its very low safety significance and because it has been entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you wish to contest this non-cited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-001; with copies to the Regional Administrator Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior Resident Inspector at the St. Lucie Nuclear Plant.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response, if any, will be available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
George T. Hopper, Chief
Reactor Projects Branch 7
Division of Reactor Projects
Docket Nos.: 50-335, 50-389 License Nos.: DPR-67, NPF-16
Enclosure:
Inspection Report 05000335/2010006, 05000389/2010006
w/Attachment: Supplemental Information
REGION II==
Docket Nos:
50-335, 50-389
License Nos:
Report No:
05000335/2010006, 05000389/2010006
Licensee:
Florida Power & Light Company (FP&L)
Facility:
St. Lucie Nuclear Plant, Units 1 & 2
Location:
6351 South Ocean Drive Jensen Beach, FL 34957
Dates:
March 1 to 19, 2010
Inspectors:
J. Stewart, Senior Resident Inspector, Turkey Point, Team Leader
T. Hoeg, Senior Resident Inspector, St. Lucie
R. Taylor, Senior Project Inspector M. King, Senior Project Inspector
J. Hamman, Project Engineer
Approved by:
George T. Hopper, Chief Reactor Projects Branch 7 Division of Reactor Projects
Enclosure
SUMMARY OF FINDINGS
IR 05000335/2010006, 05000389/2010006; 03/01/2010 - 03/19/2010; St. Lucie Nuclear Plant,
Units 1 and 2; biennial inspection of the identification and resolution of problems.
The inspection was conducted by two senior resident inspectors, two senior project inspectors, and one project engineer. One Green NRC identified finding was identified. The significance of most findings is indicated by its color (Green, White, Yellow, Red) using the Significance Determination Process in Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). The cross-cutting aspect was determined using IMC 0305, Operating Reactor Assessment Program. Findings for which the Significance Determination Process does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in 2NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
Identification and Resolution of Problems
The team concluded that, in general, problems were properly identified, evaluated, prioritized, and corrected. The threshold for initiating condition reports (CRs) was appropriately low, as evidenced by the types of problems identified and the number of CRs entered annually into the Corrective Action Program (CAP). Employees were encouraged by management to initiate CRs. However, several examples of problems related to CAP administration were identified by the team, including minor equipment issues that had not been identified by the licensee and entered into the corrective action program, a few minor examples of corrective actions closed where the specified action had not been completed, and some minor problems with sustainability of corrective actions to prevent recurrence (CAPRs). When identified, the licensee entered these issues into the CAP. In the weeks prior to the inspection, a licensee self-assessment team found similar minor issues with CAP administration and had entered these items into the CAP. Corrective actions were planned but not fully implemented in the licensee identified cases, and an assessment of the sustainability of the corrective actions could not be accomplished.
The team found problems with deferral of preventive maintenance on risk significant equipment, including the intake cooling water check valves. The team found examples of deferral of critical preventive maintenance activities that were not based on engineering evaluation, but rather scheduling concerns or management discretion. However, there was no evidence that failures had occurred because of deferred maintenance. The licensee had identified deferred maintenance as a problem in 2009 and had undertaken comprehensive evaluation and actions to remedy the problem. These activities were in progress and the timetable to correct deficient conditions was appropriate.
The team determined that, overall, audits and self-assessments were adequate in identifying deficiencies and areas for improvement in the CAP, and in most cases, appropriate corrective actions were developed to address the issues identified. Operating experience usage was found to be generally acceptable and integrated into the licensees processes for performing and managing work and plant operations.
Based on discussions and interviews conducted with plant employees from various departments, the inspectors determined that personnel felt free to raise safety concerns to management and use the CAP to resolve those concerns. However, internal surveys of work and safety culture issues identified a declining trend in worker satisfaction in 2008, and actions have been initiated to improve the work and safety culture environments throughout the corporation.
NRC Identified Findings
Cornerstone: Mitigating Systems
- Green.
The NRC identified a Green Non-cited Violation of 10 CFR 50, Appendix B,
Criterion XVI, Corrective Action, for the licensees failure to promptly correct a condition adverse to quality that being degraded check valves on the intake cooling water system affecting both units. The failure to implement corrective actions after identifying that the valves were degraded in an inspection in 2005 resulted in a reduction in system reliability and a burden to plant operators. The issue was documented in the corrective action program as CR 2010-7380, and the license intends to replace the check valves at the next availability.
The finding was more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems Cornerstone in that it adversely affected the reliability of the intake cooling system to respond to initiating events to prevent undesirable consequences. The finding was screened using Manual Chapter 0609.04,
"Phase 1 - Initial Screening and Characterization of Findings," and was determined to have a very low safety significance (Green) because the system remained operable and capable of meeting its design function with no loss of safety function of any train of intake cooling water. The cross-cutting aspect of H.3(b) was applicable because the licensee did not plan work activities to support long term equipment reliability to limit operator workarounds and reliance on manual actions. (4OA2)
Licensee Identified Violations
None
REPORT DETAILS
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
a.
Assessment of the Corrective Action Program (CAP)
- (1) Inspection Scope
The inspectors reviewed the licensees CAP procedures which described the administrative process for initiating and resolving problems using condition reports (CRs). To verify that problems were being properly identified, the inspectors toured plant areas, including the main control rooms and accompanied operations personnel on routine daily rounds to verify that issues were identified and documented in the CAP.
Daily plant status reports were reviewed and plant issues were checked for appropriate documentation in CAP. A sampling of work orders and surveillance tests since 2008 was checked to assure that identified problems were documented and resolved in the CAP. Further, the inspectors verified that issues were appropriately characterized, and screened in accordance with the significance of the issue. The inspectors included a detailed review of selected CRs associated with two risk-significant systems: Auxiliary Feedwater (AFW), and Cooling Water (ICW, CCW). In these systems and in other selected cases, a review of issues as far back as 5 years or more was done. The inspectors conducted plant walkdowns of equipment associated with selected systems to look for any deficiencies that had not been previously entered into the CAP. System health reports, condition reports, engineering walkdown reports and interviews with personnel were done to assess effectiveness of problem resolution. Also work order and corrective action backlogs were checked to assess if risk significant issues were being promptly addressed. Where possible, the inspectors independently verified that the corrective actions were implemented as intended. The inspectors also reviewed selected common causes and generic concerns associated with root cause evaluations to determine if they had been appropriately addressed. To help ensure that samples were reviewed across all cornerstones of safety, the team selected a representative number of CRs that were identified and assigned to the major plant departments, including operations, maintenance, engineering, emergency preparedness, health physics, and security. These CRs were reviewed to assess each departments threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions.
The inspection included a detailed review and evaluation of 12 CAP reports associated with significant conditions adverse to quality (screened as significance level 1 by the licensee and requiring root cause evaluation). The inspectors reviewed these evaluations using the guidance in licensee procedure PSL-01.06, Root Cause Evaluation Handbook, Revision 7. The inspectors assessed if the licensee had adequately determined the cause(s) of identified problems and had adequately addressed operability, reportability, common cause, generic concerns, extent-of-condition, and extent-of-cause. The use of operating experience (OE) in assessing significant conditions was evaluated. The review also assessed if the licensee had appropriately identified and prioritized corrective actions to prevent recurrence.
Control room walkdowns were also performed to assess the main control room (MCR)deficiency list and to ascertain if deficiencies were being tracked to resolution. A sample of operator workarounds and operator burden screenings were reviewed and the inspectors verified compensatory measures for deficient equipment were being implemented in the field.
The inspectors completed a critical review of the St. Lucie Nuclear Plant Identification and Resolution of Problems Self-Assessment Report, SA 2009-34387, February 8-12, 2010. This review included a status check of selected issues identified as a result of the assessment.
The team reviewed selected industry operating experience items, including NRC generic communications and Part 21 reports, to verify that they had been appropriately evaluated for applicability or used in licensee activities and that issues identified through these reviews had been entered into the CAP.
Documents critically reviewed are listed in the Attachment.
- (2) Assessment
Identification of Issues
The team determined that the licensee was effective in identifying problems and that plant staff had a low threshold for entering issues into the CAP. This conclusion was based on observation of daily summaries of issues documented in the CAP during the inspection and in discussion with management on the expectation that employees initiate CRs for any reason. Site management was actively involved in the CAP and focused appropriate attention on significant plant issues. The inspectors observed that trending was generally effective in monitoring equipment performance.
The licensee had planned a self-assessment of the CAP for April 2009. The assessment was done the week of February 8, 2010 and documented as Station Assessment SA 2009-34387. The assessment identified 34 discrepancies which were documented in the CAP by the licensees team. The problems included prioritization of some lower significance condition reports, causal analysis gaps with extent of condition, corrective actions weaknesses including resolution of Corrective Actions to Prevent Recurrence (CAPRs), poorly developed closure of CAP items, and an increasing open action inventory. Many of the licensee identified issues remained open at the time of this NRC inspection although many actions had been taken to correct the problems.
During plant walkdowns and on tours with plant operators the NRC inspectors identified several minor issues that were not previously identified by operators or system engineers during routine rounds and system walkdowns. Examples included a fire door with a sticking latch, externally induced corrosion on a fuel storage tank and on some auxiliary feedwater piping, and several minor housekeeping issues. The corrosion issues were subsequently evaluated by the licensee and determined not to have a current adverse impact on reliability of equipment. The fire door latch was corrected by maintenance within hours.
Prioritization and Evaluation of Issues
The inspectors concluded that problems were prioritized and evaluated in accordance with the licensees CAP procedures as described in the PI-AA-204, Condition Identification and Screening Process. Each CR was assigned a priority level using station procedures.
Equipment problems were documented as work requests, then in work orders and the station had initiated action to reduce the work backlog based on risk significance. The inspectors found that a large number of system health reports had not been documented in the fourth quarter of 2009 and because these reports listed equipment deficiencies along with risk information, prioritizing problems for repair was being done in some cases without up-to-date health report input.
The team determined that station personnel had conducted root cause and apparent cause analyses in compliance with the licensees CAP procedures and assigned cause determinations were appropriate, considering the significance of the issues being evaluated. A variety of formal causal-analysis techniques were used depending on the type and complexity of the issue consistent with PSL-01.06, Root Cause Evaluation Handbook, Revision 7.
The team determined that, generally, the licensee had performed evaluations that were technically accurate and of sufficient depth. The team further determined that operability, reportability, and degraded or non-conforming condition determinations had been completed consistent with the guidance contained in the licensees Nuclear Administrative Procedure (NAP) 204, Condition Reporting. The use of operating experience was appropriate and obvious in cause evaluations.
Effectiveness of Corrective Actions
The inspectors determined that, in general, corrective actions were commensurate with the safety significance of the issues and were appropriately implemented. During the inspection, a problem with externally induced cracking in emergency diesel generator 2B air receivers was appropriately addressed and corrected within the Technical Specification Limiting Condition for Operation window, demonstrating that the corrective action process could be effectively implemented for risk significant deficiencies (CR 2010-5305). However during review of prior NRC inspection issues, some examples of conditions adverse to quality that were recurring had been identified signaling that corrective actions were not effective in all cases (See NRC Inspection Report 50-335,389/2009-003). The inspectors also found a number of minor examples where corrective actions taken did not match those described in the CAP. A number of examples were found where corrective actions were specified in the problem evaluation portion of CAP documentation, but not listed in the actions portion in CAP. These documentation discrepancies were considered minor.
- (3) Findings
i.
Failure to Promptly Correct a Condition Adverse to Quality Associated with Intake Cooling Water System Pump Discharge Check Valves
Introduction:
The NRC identified a Green Non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to promptly correct a condition adverse to quality by failing to implement corrective actions for deficient discharge check valves on the Unit 1 A and B, and Unit 2 C, intake cooling water pumps.
Description:
In 2002, discharge check valves were replaced on all intake cooling water pump discharge headers. At the time, a preventive maintenance activity to replace the check valves to assure reliability and functionality was specified with a three year frequency, due in 2005. However, the replacement preventive maintenance was not done. In a 2005 internal piping inspection, the licensee identified damage to the check valve rubber lining and a corrective action to replace or rebuild the valve internals was specified (CR 2005-1121). The licensees corrective action program specified that due dates for corrective actions be based on risk and that extension to due dates be technically justified. The corrective actions were closed, although not completed and neither a technical justification to extend the due date nor a risk assessment of continued operation was documented. Although Unit 1 A and B check valves were replaced in 2008, Unit 2 A and B, and Unit 1 C were not replaced and were again deferred in 2008 without technical justification. When operations personnel noted the 2A ICW pump rotating backwards, indicating check valve reverse leakage, an operator workaround was created to isolate the pump using the manual isolation valve on the header to support in-service testing.
The inspectors evaluated the licensees operability evaluation of the ICW headers given the reverse check valve leakage and found the analysis reasonable. The inspectors concluded the headers remained operable, able to support their design function, but degraded.
Analysis:
The failure promptly implement corrective actions for degraded check valves after a 2005 inspection revealed that the valves were degraded was a performance deficiency. The performance deficiency was more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems Cornerstone in that it adversely affected the reliability of the intake cooling system to respond to initiating events by allowing reverse flow to the idle intake cooling water pumps. The finding was screened using Manual Chapter 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," and was determined to have a very low safety significance (Green) because the system remained operable and capable of meeting its design function and there was no loss of safety function of any train of intake cooling water.
This finding is not potentially risk-significant due to external events.
The finding was assigned a cross-cutting aspect in the Human Performance, Work Control component because the licensee did not coordinate work activities consistent with nuclear safety to assure long term equipment reliability by limiting operator workarounds and reliance on manual actions associated with degraded check valves on the intake cooling pump discharge headers. (H.3.(b)).
Enforcement:
10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures be established to assure that conditions adverse to quality, such as deficiencies, are promptly corrected. Contrary to this, as of March 19, 2010, a condition adverse to quality, degradation of intake cooling water system pump discharge check valves, identified in 2005, was not promptly corrected such that a manual action in an operator workaround was required to complete in-service testing of the headers. No technical justification for the due date extension was documented in the CR record.
When identified to the licensee, Condition Report 2010-7380 was written and the license intends to replace the check valves at the next availability. Because the finding was determined to be of very low safety significance and has been entered into the licensees CAP as CR 2010-7380, this violation is being treated as an NCV consistent with Section VI.A of the Enforcement Policy: NCV 05000335, 389/2010-006-01, Failure to promptly correct a condition adverse to quality associated with degraded intake cooling water pump discharge check valves.
b. Assessment of the Use of Operating Experience (OE)
- (1) Inspection Scope
The team examined the licensees use of industry operating experience to assess the effectiveness of how external and internal operating experience data was used to prevent similar or recurring problems at the plant. In addition, the team selected operating experience documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, and plant internal operating experience items), which had been issued since 2008 to verify whether the licensee had appropriately evaluated each notification for applicability to the St. Lucie plant, and whether issues identified through these reviews were entered into the CAP. The inspectors checked if operating experience was appropriately incorporated into cause evaluations and integrated into plant operations through pre-job briefs and operations activities. Documents reviewed are listed in the Attachment.
- (2) Assessment
Based on observations of activities and interviews with station personnel and a review of documentation related to operating experience issues, the team determined that the licensee was effective in screening operating experience for applicability to the plant.
OE issues requiring action (e.g. Part 21 reports) were entered into the CAP for evaluation, tracking, and closure. In addition, operating experience was included in apparent cause and root cause evaluations in accordance with licensee procedures. OE was evident in plant operations activities, such as pre-job briefings and turnover meetings.
Findings
No findings of significance were identified.
c.
Assessment of Self-Assessments and Audits
- (1) Inspection Scope
The team reviewed the licensees audit and self-assessment reports, including those which focused on problem identification and resolution, to assess if the licensee was identifying problems at an appropriately low threshold and to verify that problems identified through those activities were entered into the CAP and prioritized for resolution in accordance with licensee procedures. The team verified that recommendations from self-assessments reviewed had been entered into the CAP, evaluated, and verified that actions had been completed consistent with those evaluations.
- (2) Assessment
The team determined that the scopes of assessments and audits were technically sound and appropriate. Self-assessments were generally detailed and critical. Condition reports were created to document the results and associated recommendations from the final reports. The team also determined that the licensee had adequately prioritized self-assessment and audit issues entered into the CAP.
The team reviewed an Emergency Preparedness Area St. Lucie Daily Quality Summary (DQS) report, dated October 3, 2008, and a Maintenance Area St. Lucie Daily Quarterly Summary (DQS) report, dated October 2, 2008. In both cases there were minor examples of actions for lower tiered issues that had been closed in the CAP, but had not been completed at the time of this inspection. The licensee documented these issues in condition reports and the inspectors verified that the specified actions had minimal impact on plant risk.
The inspectors recognized that the site experienced difficulty with certain elements of the CAP program as evidenced by the number of issues identified in the FPL self-assessment of the CAP, and some additional examples of issues identified by the inspectors. These issues included actions where the completed action did not match the corrective action listed in the CAP, or incomplete actions where the CAP action had been closed to another process or list or not appropriately tracked to closure. Each example was assessed as minor with regard to risk, although the number of similar issues was of concern. The stations decision to conduct the CAP self-assessment which identified performance problems was a good initiative for launching performance improvement. Also, a newly created CAP Health Index and related Departmental Corrective Action Program Health Report, created in February 2010, revealed a large proportion of areas requiring management attention, such as Average Time for Evaluation Completion, Number of Due Date Changes, and Average Age of Open Actions. The inspectors were told by station managers that the site was committed to reducing the backlog of open actions and addressing the problems raised in their self-assessment.
- (3) Findings
No findings of significance were identified.
d. Assessment of Safety Conscious Work Environment
- (1) Inspection Scope
The inspectors assessed the stations safety conscious work environment (SCWE)through review of the stations Employee Concern Program (ECP), discussions with coordinators of the ECP, interviews with personnel from various station departments, and reviews of station performance indicators. The inspectors checked the status of FPLs evaluation and actions related to improving the corporate safety culture, including upgrades to the Employee Concerns Program.
- (2) Assessment
The inspectors found that individuals remained aware of the processes available to raise safety issues and that no reluctance to raise safety concerns was identified.
Improvements to the employee concerns program and initiatives to improve the FPL safety culture were proceeding.
The inspectors found that FPL had implemented a comprehensive corporate plan to improve the Safety Conscious Work Environment at its facilities, including St. Lucie. A station survey was administered in 2007 to assess the work environment at FPL, including St. Lucie. The survey was administered again in September 2008 using many of the same questions to identify changes in the environment for personnel to raise issues through various channels as well as individual work satisfaction. At St. Lucie, a decline in some areas was identified such as, increasing frustration of the staff with their ability to drive repair of some plant issues. An action plan was initiated in June 2009 to improve the ability of the station to manage work and work related issues, including the ability of personnel to raise objections to management. In late 2009, FPL initiated a comprehensive plan to improve its corporate safety culture, starting with a comprehensive root cause evaluation of safety culture issues identified in corporate surveys. From this evaluation, a number of actions were initiated to improve corporate culture, including formalizing the management of employee concerns, taking actions to address the industrial safety work order backlog at PSL, improving management oversight of station backlogs and management oversight of preventive maintenance change requests, initiating a review of nuclear safety culture issues by the corporate nuclear review board, benchmarking SCWE at other facilities, and planning for effectiveness reviews. The inspectors verified that actions planned were being implemented on schedule, including training of senior managers on SCWE management and initiation of the management review of safety culture issues on a routine basis.
The inspectors found, through interviews with site workers, that they were willing to raise nuclear safety concerns, had initiated a CAP items, and had been involved in the safety culture surveys. Interview discussions also revealed that plant workers were knowledgeable of the various available methods for raising nuclear safety concerns.
Furthermore, the workers communicated recent improvement in station supervisions support of the workers raising issues. None of the workers indicated that their co-workers or they had been retaliated against for raising safety concerns.
The inspectors met with the newly appointed station ECP coordinator and the ECP manager. The ECP coordinator indicated activities that would facilitate more awareness and understanding of the ECP including introducing the program with onsite staff and contractor groups at departmental meetings. Furthermore, the ECP office had been recently relocated within the plant protected area and procedures had been developed for uptake of concerns and management of concern resolution. The new process required closeout of the concern with the concerned individual, typically in a face to face meeting.
Findings
No findings of significance were identified.
4OA6 Meetings, Including Exit
On March 19, the inspectors provided the results of the inspection to Mr. R. Anderson and other members of the site staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection.
ATTACHMENT: SUPPPLEMENTAL INFORMATION
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- R. Anderson, Site Vice President
- D. Calabrese, Radiation Protection Manager
- D. Cecchert, Licensing Engineer
- A. Day, Chemistry Manager
- S. Duston, Training Manager
- R. Filipez, Project Engineering Manager
- M. Haskin, Maintenance Manager
- D. Huey, Work Control Manager
- B. Hughes, Plant General Manager
- E. Katzman, Licensing Manager
- R. Lingler, Operations Manager
- J. Owens, Assistant Operations Manager
- C. Patterson, ECP Coordinator
- M. Seidler, Security
- M. Snyder, Quality Assurance Manager
- B. Vogel, Chemistry
- M. Willis, Work Control
- D. Willson, Inspection Facilitator
NRC
- S. Sanchez, RI St. Lucie
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
- 05000335&389/2010-006-01 NCV
Failure to promptly correct a condition
adverse to quality associated with degraded
intake cooling water pump discharge check
valves.