IR 05000335/2006008

IR 05000335-06-008 and IR 05000389-06-008; Florida Power & Light Company (Fpl); 08/07-25/2006; St Lucie Nuclear Plant, Unit 1 & 2

ML062770011
Person / Time
Site:	Saint Lucie, Susquehanna
Issue date:	10/03/2006
From:	Joel Munday NRC/RGN-II/DRP/RPB3
To:	Stall J Florida Power & Light Co
References
IR-06-008
Download: ML062770011 (20)

Text

ber 3, 2006

SUBJECT:

ST LUCIE NUCLEAR PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 050000335/2006008 AND 05000389/2006008

Dear Mr. Stall:

On August 25, 2006, the U. S. Nuclear Regulatory Commission (NRC) completed a team inspection at your St. Lucie Nuclear Plant, Units 1 and 2. The enclosed inspection report documents the inspection findings, which were discussed on August 25, 2006, with Mr. Gordon Johnston and other members of your staff during an exit meeting.

This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.

On the basis of the sample selected for review, there were no findings of significance identified during this inspection. The inspectors concluded that problems were properly identified, evaluated, and resolved within the problem identification and resolution programs (PI&R).

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system

FP&L 2 (ADAMS). ADAMS is accessible from the NRC Web-site at http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Joel T. Munday, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket Nos. 50-335 and 50-389 License Nos. DPR-67 and NPF-16

Enclosure:

Inspection Report 05000335/2006008 and 05000389/2006008 w/Attachment: Supplemental Information

REGION II==

Docket Nos.: 05000335, 05000389 License Nos.: DPR-67 and NPF-16 Report Nos.: 05000335/2006008 and 05000389/2006008 Licensee: Florida Power & Light Company (FPL)

Facility: St Lucie Nuclear Plant, Units 1 & 2 Dates: August 7-25, 2006 Inspectors: S. J. Vias, Senior Reactor Inspector, Lead Inspector S. Stewart, Senior Resident Inspector, Turkey Point S. Sanchez, Resident Inspector, St Lucie D. Eskins, Resident Inspector, LaSalle J. Wallo, Senior Security Inspector O. DeMiranda, Senior Allegation Coordinator Approved by: Joel Munday, Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000335/2006008 and 05000389/2006008; on August 7-25, 2006; St. Lucie Nuclear Plant,

Units 1 & 2; biennial baseline inspection of the identification and resolution of problems.

The inspection was conducted by two Senior Reactor Inspectors, one Senior Resident Inspector, two Resident Inspectors, and one Allegation Coordinator.

Identification and Resolution of Problems The inspectors identified that the licensee was effective at identifying problems and entering them into the corrective action program. The licensees effectiveness at problem identification was evidenced by the relatively few deficiencies identified by external organizations (including the NRC) that had not been previously identified by the licensee, during the review period. The licensee effectively used risk in prioritizing the extent to which individual problems would be evaluated and in establishing schedules for implementing corrective actions. Corrective actions, when specified, were generally implemented in a timely manner. Operating experience usage was also found to be effective. Self assessment results adequately identified problems. The inspectors identified a number of weaknesses that are detailed in the report in various aspects within the corrective action process.

On the basis of the samples selected for review, the inspectors concluded that, 1) in general problems were properly identified, evaluated, and corrected within your problem identification and resolution program, 2) the processes and procedures of your corrective action program were generally effective; thresholds for identifying issues were appropriately low, and in most cases, corrective actions were adequate to address conditions adverse to quality, and 3) on the basis of interviews conducted during this inspection, workers at the site felt free to input safety findings into the corrective action program.

A. Inspector Identified Findings None

Licensee Identified Violations

None

REPORT DETAILS

4OA2 Identification and Resolution of Problems

The inspectors based the following conclusions, in part, on issues that were identified in the assessment period, which ranged from March 1, 2004 (the last biennial problem identification and resolution inspection) to the end of the inspection on August 25, 2006.

In addition, the inspectors reviewed problems for selected systems identified outside the planned assessment period whose significance might be age dependent.

a. Assessment of the Corrective Action Program Effectiveness

(1) Inspection Scope The inspectors reviewed the licensees corrective action program (CAP) procedures which described the administrative process for initiating and resolving problems through the use of condition reports (CRs). The inspectors reviewed selected CRs, and attended meetings where CRs were screened for significance, to determine if the licensee was identifying, accurately characterizing, and entering problems into the corrective action process at an appropriate threshold.

The inspectors reviewed condition reports of varying severity levels and from most site departments. The inspectors also conducted a detailed review of CRs for four risk significant systems. These systems were selected based on equipment performance history, Maintenance Rule (MR) considerations, and risk significance insights from the licensees probabilistic safety assessment. The systems reviewed were Intake Cooling Water (ICW), Emergency Diesel Generators (EDG) including the starting air and fuel oil systems, Reactor Protection System (RPS), and Component Cooling Water (CCW).

The inspectors reviewed the maintenance history and selected completed Work Orders (WOs) for the four systems and reviewed associated system health reports. Additional CRs were selected associated with MR evaluations and problems previously identified by the NRC. The inspectors also reviewed NRC inspection results of CRs documented in NRC reports over the previous two years. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP. In addition to the two year review, in accordance with the inspection procedure, a five year review was performed for the selected systems for issues the inspectors determined to be age dependant.

The inspectors reviewed licensee event reports, condition reports, selected licensee effectiveness reviews, work requests, and work orders tied to condition reports, along with the inspections discussed in this report, to verify that the licensee had implemented timely and appropriate corrective actions to address significant problems. The inspectors verified that the corrective actions were properly documented, assigned, and tracked to completion. The review was also to verify the adequacy of corrective actions to address equipment deficiencies and MR functional failures of risk significant plant safety systems.

The inspectors also conducted plant walkdowns of equipment associated with the four selected systems to assess the material condition and to look for any deficiencies that had not been previously entered into the CAP. Control Room walkdowns were performed by the inspectors to verify the main control room (MCR) deficiency list and to ascertain whether deficiencies were entered into the CAP.

The inspectors attended various plant meetings to observe management oversight functions of the corrective action process. These included morning meetings, Condition Report Oversight Group (CROG) meetings, Corrective Action Program Coordinator (CAPCO) meetings and Work Request Review meetings (per CR 2006-23991). The inspectors also held discussions with various personnel to evaluate their threshold for identifying issues and entering them into the CAP.

(2) Assessment Effectiveness of Problem Identification The inspectors determined that the licensee was generally effective at identifying problems and entering them into their CAP. The threshold for initiating CRs was low and employees were encouraged by management to initiate CRs. As a result, the inspectors observed that there was an increasing trend in the number of CRs generated over the last few years. However, this has placed an increased demand on the staff to provide timely and quality reviews and evaluations. This has also challenged the organizations ability to prioritize and evaluate CR issues in a timely manner, which oftentimes exceeded the evaluation completion time periods.

During the system walkdowns by the inspectors, very few conditions adverse to quality were identified by the inspectors not previously documented by the licensee. However, during a walkdown of the Unit 2 EDG rooms, inspectors identified ladders that had not been seismically evaluated as required by licensee procedures for safety related and seismic class 1 areas (CR 2006-23014). Though these areas were frequently walked down by operations staff, this issue was not identified by licensee personnel. This was considered a weakness in the area of problem identification relative to seismic storage requirements. The licensee initiated a CR documenting this concern.

During a review of a March 2005 maintenance event (CR 2005-07449), the inspectors noted that a related issue involving aspects of the security program, was not adequately identified in the licensees corrective action program. Based on a subsequent review of this issue by the licensee, an additional condition report (CR 2006-22869) was issued which documents the issue and corrective actions taken to prevent recurrence. This inadequate review is considered a weakness in the area of problem identification, however, additional inspection is needed. Pending completion of additional inspection, this issue will be identified as URI 05000335, 389/2006008-01, Inadequate Review of Condition Report Concerning Security Issues.

Although the CAP program procedures suggested that senior management attend various CAP-related meetings, including the CAPCO and PWO screening meetings, the inspectors noted this to be rare. The licensee acknowledged this concern.

Effectiveness of Prioritization and Evaluation of Issues The inspectors determined that the licensee was generally effective at problem prioritization and evaluation. Most evaluations were technically adequate and of appropriate depth. Among the documents reviewed, the inspectors identified no issues with the licensees operability or reportability evaluations. In most cases, the licensee appropriately considered risk in prioritizing or evaluating issues. However, several weaknesses in this area were identified as discussed below.

The inspectors concluded that CAP-related meetings were well attended and participating members appeared to be prepared. Assignment of significance level and investigation types to CRs appeared to be in accordance with CAP procedures and guidance. In general, there was good discussion and interaction among the group members that the inspectors observed with the proper focus on reactor safety. In some cases the CR investigation type was changed from what was originally presented by the CAPCO screening meeting quorum to what was decided upon by the CROG.

The inspectors also observed several work request (WR) review meetings and determined that WRs were not receiving the same level of review as condition reports (CR 2006-23991). Specifically, all department representatives required per procedure MPG-001, Work Order Planning, to attend this meeting were not present and all WRs generated were not reviewed. Additionally, the WR review packages did not always establish a clear linkage to an associated CR, when written, and a formal review process was not always followed. Because the Plant Work Order (PWO) system was part of the CAP, this represented a weakness in problem identification in the area of WR review.

Inspectors identified several issues related to the licensees evaluation of repetitive failures of emergency diesel generator (EDG) air start motors. In February of 2006, a Root Cause Evaluation (RCE) determined that the failure interval for these motors was between eighteen and twenty-four months. In June of 2006, an additional failure occurred after approximately five months and though a RCE was initially proposed to evaluate this failure, it was later downgraded to an Apparent Cause Evaluation (ACE).

The underestimation of the air start failure rate in RCE 2006-2748 and the decision not to perform a new RCE when additional failures occurred demonstrated a weakness in the CAPs evaluation of the air start motors failure mechanism. However, because the issue did not impact EDG operability and the licensee has taken interim corrective action to detect additional failures, the licensees overall corrective actions appeared adequate to prevent the failure of the EDG air start system function.

CR 2006-17321 documented an issue where a CR (2006-17271) was changed without the originators consent or knowledge. The change involved the acting PID manager amending the brief description wording to augment future trending and/or searches, and subsequently failed to inform the CR originator in a timely manner. Evaluation of CR 2006-17321 identified a programmatic deficiency whereby CR text could be changed without a documented record of the change. However, it was noted that the administrative rights to change the text of a CR exists only within the Performance Improvement Department (PID). The human performance evaluation performed as part of this CR determined that the issue involved a human error associated with communication. Additionally, the inspectors noted two separate issues during the review of CR 2006-17321. First, the human performance evaluation was conducted and approved by the same individual. Second, the issue was referred to Speakout for evaluation, however, it was two months before Speakout actually opened a case.

Although these are not violations of the CAP procedures, the inspectors considered them to be weaknesses.

The team noted many instances in which work orders associated with corrective actions or deficiency tags had been deferred. However, no failures or issues associated with the deferment of corrective actions were identified.

The inspectors review of CRs associated with the ICW and CCW Systems revealed a couple possible trends, not any of which resulted in a significant concern. However, after reviewing System Health Reports, interviewing the cognizant system engineer, and walking down the systems, the Unit 2 ICW system continues to display material condition degradation. This was evident in the System Health Report where the material condition attribute is coded red (unacceptable material condition), along with the system Structures also coded red. Attachment 3 to the System Health Report for Unit 2 ICW indicates several SSCs within the ICW system continually being rescheduled and sometimes completely dropping out of the schedule. CR 2004-5294, dated July 7, 2004, documents an NRC concern regarding the material condition of the Unit 2 ICW pump enclosure. CR 2004-7280, dated August 27, 2004, identifies an ineffective corrective action from CR 2004-5294. The CAs did not address the housekeeping or the degraded material condition aspect of the CR, instead only stated that Engineering would monitor the degraded condition. This CR (2004-07280) was deleted for some unknown reason, thereby forgoing any corrective action(s) for addressing the Unit 2 ICW pump enclosure material condition. This is considered a weakness in the areas of prioritization and evaluation of issues and corrective action effectiveness.

Effectiveness of Corrective Action The inspectors found that corrective actions developed and implemented for problems were timely and effective, and commensurate with the safety significance of the issues.

Generally, the corrective actions directly addressed the cause and effectively prevented recurrence for significant conditions adverse to quality. However, the inspectors noted that the number of CRs being submitted had increased from previous years.

(3) Findings and Observations The inspectors determined that overall, corrective actions were effective in correcting problems which resulted in generally good material condition and operating performance of the systems reviewed. The inspectors noted that somewhat frequent problems with the reactor protection system were typically caused by age related degradation and were being adequately managed to prevent functional failures or more significant problems. The inspectors also observed a number of minor plant deficiencies on secondary systems where corrective action had been delayed, as indicated by numerous deficiency tags. Scaffolding that remained in the intake cooling water pump area had been left in place to deal with repeated problems with secondary systems in this area. Although a number of work orders had due date extensions, the inspectors found no problems of significance that had occurred due to incomplete or extended corrective actions.

b.

Assessment of the Use of Operating Experience

(1) Inspection Scope The inspectors conducted a review of the licensee's Operating Experience (OE)program to verify actions were completed in accordance with licensee procedure NAP-414, Operating Experience Program. The inspectors reviewed a sampling of the items the licensee had submitted for OE to verify the information accurately reflected the events, were appropriately evaluated, and documented in their CAP. The inspectors also focused on NRC generic communications and OE items associated with the four systems selected for a detailed review to verify issues were appropriately evaluated for applicability and whether issues identified through these reviews were entered into the CAP.

(2) Assessment In general, OE items were adequately identified, evaluated, and utilized, however, several weaknesses were identified. During a review of OE screening, inspectors noted that the training organization conducted its own OE screening apart from the station OE coordinator. Also, no screening records were maintained for OE that was considered not applicable to the station and OE that was dispositioned as applicable prior to the year 2004 may not be contained within the licensees current OE database system. This represented a weakness in problem identification in the area of OE review.

In the area of OE evaluation, inspectors noted that OE evaluations are normally screened as 4/D and non-CAQ. In some examples, this low priority has led to repeated delays in evaluating the applicability of OE. For example, NRC Information Notice 2005-23 which involved vibration induced failures of butterfly valves was entered into the CAP as CR 2005-22485 in August of 2005. The evaluation of this item was deferred multiple times due to resource limitations with the latest due date for completion being November 2006. The routine assignment of low priority to OE evaluations for which the potential plant implications are unknown is a weakness in the CAPs evaluation of issues.

(3) Findings and Observations No findings of significance were identified. The stations OE program had several identified weaknesses which the licensee plans to address with upgrades to the OE program. Improvements being considered include the creation of a corporate level OE screening program and the inclusion of an OE module in the SITRIS CAP tracking database.

c.

Assessment of the Self-Assessment and Audits

(1) Inspection Scope The inspectors reviewed licensee quality assurance audits, quality assurance quality reports, and department self-assessments including those which focused on problem identification and resolution to verify that findings were entered into the CAP and to verify that these findings were consistent with the NRCs assessment of the licensees CAP.

(2) Assessment The inspectors reviewed licensee event reports, condition reports, selected licensee effectiveness reviews, work requests, and work orders tied to condition reports, along with the inspections discussed in this report, to verify that the licensee had implemented timely and appropriate corrective actions to address significant problems. The inspectors verified that the corrective actions were properly documented, assigned, and tracked to completion. The review was also to verify the adequacy of corrective actions to address equipment deficiencies and MR functional failures of risk significant plant safety systems.

(3) Findings and Observations Department self-assessments and QA audits were self-critical and effective in identifying areas for improvement that were entered into the CAP where appropriate.

d.

Assessment of Safety-Conscious Work Environment

(1) Inspection Scope The inspectors randomly interviewed approximately 40 on-site workers, focusing on their knowledge of the problem identification process (corrective action program, Speakout)at St Lucie. Interviewees were questioned on their understanding and their willingness to initiate condition reports or raise safety concerns. Discussions with plant staff were conducted to develop a general sense of the safety-conscious work environment at the site. The inspectors looked for indications of conditions that would cause employees to be reluctant to raise safety concerns.

Additionally the inspectors reviewed thirty-one closed Speakout files for completeness, adequacy of the investigation conducted, file documentation, responsiveness to the concerned individuals and responses to recommended corrective actions by station management and for employees to raise concerns and remain anonymous. The inspectors also interviewed the Speakout site representative, the Speakout supervisor and the Director Quality Assurance to glean their awareness of any areas needing additional attention in light of the increased NRC allegations at St Lucie. The inspection included verification that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate.

(2) Assessment and Observations In general, the inspectors determined that the Safety Conscious Work Environment appeared to be adequate where most people felt free to raise issues without fear of retaliation. The investigations conducted by Speakout were thorough, complete and the recommended corrective actions were appropriately focused to address the actions needed to resolve the individual concerns.

The inspectors noted that the number of NRC allegations received was high when compared to the number of Speakout concerns received. When coupled with information obtained during the site interviews the inspectors noted some reluctance by several organizations to bring issues to Speakout. Some interviewed commented that they did not feel issues got resolved in a timely manner, or in some cases at all, and therefore they were reluctant to use the Speakout program. Others commented that Speakout was not readily accessible and there was not enough management emphasis on the program. Others interviewed were unaware that the program existed. However, all interviewed indicated they would raise their concern through some process.

Inspectors noted several concerns with the implementation of the licensees anonymous kiosk CR submission program. Many of the staff interviewed were unfamiliar with the existence or use of the kiosks and some were concerned that the location of the kiosks allowed observation by management. Additionally, the CROGs occasional practice of determining that a CR was not intended to be anonymous and attempting to identify the author for more information was determined to have a potential chilling effect on the use of this system. The inspectors also noted that the practice of publically posting the count of Anonymous CRs in an effort to drive down the number of such CRs may also discourage the use of this method of raising concerns. In response, the licensee agreed to stop posting anonymous CR charts and to stop pursuing anonymous kiosk CR identifications.

(3) Findings and Observations There were two Speakout files that contained evidence that a condition report (CR) was not written as described in NSS-1, 6.1.1.1. In one case, Speakout recommended corrective actions that included the Security Force attend refresher training on changes that have occurred to the Security Force Instructions (SFIs) and the Plant Security Plan (PSP). A condition report should have been initiated to formalize that there existed a misunderstanding of the PSP. This matter being handled without a condition report circumvented the corrective action process. A second example involved a CR that was initiated but the scope of the CR only described identifying areas for improvement rather than the failure to follow security procedures. Because of the low significance of these two issues, both were considered to be minor.

The inspectors conducted a review of Speakout files for any potential safeguards information (SGI) that may have been inadvertently included in the files. Even though no SGI was discovered, Speakout does not have a program or procedure in place to preclude SGI from inadvertently being included in Speakout files. The licensee acknowledged that a procedure should be in place that delineates the process for assuring that safeguards information does not inadvertently get added to Speakout files.

4OA6 Management Meetings

On August 25, 2004, the inspectors presented the inspection results to Mr. Gordon Johnston and other members of his staff who acknowledged the findings. The inspectors confirmed that proprietary information was not provided or examined during the inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

R. Acosta, Director Nuclear Assurance

R. Bailey, Security Analyst

D. Bonthron, FPL Corp. Access Authorization Manager

R. Boskey, STL Access Authorization Supervisor

M. Danford, Corrective Action Program Supervisor

B. Jacques, Security Manager

G. Johnston, Site Vice President

R. Lecky, Supervisor Speakout

A. Scales, Plant Engineering Manager

M. Seidler, STL Security Operations Supervisor

NRC personnel

D. Jones, Acting Senior Resident Inspector, St. Lucie

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000335, 389/2006008-01 URI Inadequate Review of Condition Report Concerning Security Issues

Closed

None

Discussed

None