IR 05000730/2009016

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Notice of Violation from Insp on 950730-0916.Violation Noted:On 950802,during Cooldown of Unit 1,valid Block Permissive Annunciators Were Received But Operators Failed to Establish Required MSIS Blocks
ML17228B323
Person / Time
Site: Saint Lucie, 05000730 NextEra Energy icon.png
Issue date: 10/16/1995
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML17228B322 List:
References
50-335-95-15, NUDOCS 9511140314
Download: ML17228B323 (5)


Text

NOTICE OF VIOLATION Florida Power

& Light Company St.

Lucie

Docket No.

50-335 License No.

DPR-67 During an NRC inspection conducted on July 30 through September 16, 1995, violations of NRC requirements were identified.

In accordance with the

"General Statement of Policy and Procedure for NRC Enforcement Actions,"

(NUREG-1600), the violations are listed below:

A.

Technical Specification 6.8. I.a requires that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Rev.

2, February 1978..

Appendix A, paragraph 1.d includes administrative procedures for procedural adherence.

Procedure gI 5-PR/PSL-I, Rev.

62, "Preparation, Revision, Review/Approval of Procedures,"

Section 5. 13.2, states that all procedures shall be strictly adhered to.

OP 1-0030127, Rev 68, "Reactor Plant Cooldown Hot Standby to Cold Shutdown," required, in part, that operators block Main Steam Isolation System (MSIS) actuation when block permissive annunciations were received.

ONOP 1-0030131, Rev 60, "Plant Annunciator Summary," required that, upon valid receipt of annunciators 0-18 and 9-20, operators immediately block MSIS channels A and B, respectively.

Contrary to the above, on August 2, 1995, during a cooldown of St. Lucie Unit 1, valid block permissive annunciators were received, however, operators failed to establish the required MSIS blocks, resulting in A and B channel MSIS actuations.

This is a Severity Level IV violation (Supplement I).

B.

Technical Specification 6.8, l.a requires that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Rev.

2, February 1978.

.Appendix A, paragraph 1.d includes administrative procedures for procedural adherence.

Procedure gI 5-PR/PSL-1, Rev.

62, "Preparation, Revision, Review/Approval of Procedures,"

Section 5. 13,.2, states that all procedures shall be strictly adhered to.

Contrary to the above, procedures were not adhered to strictly in the following examples:

1.

OP 1-0120020, Rev 72, "Filling and Venting the RCS," precaution 4.2, required that Reactor Coolant System (RCS) venting, described in the procedure, not be attempted if RCS temperature was above 200'F.

On August 2, 1995, Reactor Coolant Pump (RCP)

seal venting, performed in an attempt to correct. seal package le'akage in the lA2 RCP in accordance with Appendix E of the subject 'procedure, was performed while RCS temperature was approximately 370'F.

As a

result, design temperatures of RCP seal components were approached or exceeded.

95iii40314 95iOih PDR ADOCK 05000335

PDR

2.

OP 1-0120020, Rev 72, "Filling and Venting the RCS," Appendix E,

"Restaging Reactor Coolant Pump Seals,"

required the use of RCP seal injection while restaging was attempted.

On August 2, 1995, restaging of the 1A2 RCP seal package was attempted without seal injection aligned to the seal package.

As a result, design temperatures of RCP seal components were approached or exceeded.

This C.

This D.

This is a Severity Level IV violation (Supplement I).

Technical Specification 6.8. 1 '

requires that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Rev.

2, February 1978.

Appendix A, paragraph 1.d includes administrative procedures for procedural adherence.

Procedure gI 5-PR/PSL-1, Rev.

62, "Preparation, Revision, Review/Approval of Procedures,"

Section 5. 13.2, states that all procedures shall be strictly adhered to.

AP 1-0010123, Rev 99, "Administrative Controls of Valves, Locks, and Switches,"

step 8. 1.6, required, in part, that all valve position deviations be documented in the Valve Switch Deviation Log.

Contrary to the above, on or about August 1,

1995, HCV-25-1 through

were repositioned and left in the closed position without the required entries being made in the Valve Switch Deviation Log.

The valves'ositions complicated a loss of RCS inventory.

is a Severity Level IV violation (Supplement I).

Technical Specification 6.8. I.a requires that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Rev.

2, February 1978.

Appendix A, paragraph 1.d includes administrative procedures for procedural adherence.

Procedure gI 5-PR/PSL-1, Rev.

62, "Preparation, Revision, Review/Approval of Procedures,"

Section 5. 13.2, states that all procedures shall be strictly adhered to.

OP 1-0410022, Rev 22,

"Shutdown Cooling," step 8.3.7, required that V3652, the B Shutdown Cooling (SDC) hot leg suction isolation valve, be locked open while placing the B

SDC loop in service.

Contrary to the above, on August 29, a control room operator failed to place V3652 in a locked open condition while placing the B

SDC loop in service.

As a result, the 1B Low Pressure Safety'njection Pump was operated with its suction line isolated.

is a Severity Level IV violation (Supplement I),

Technical Specification 6.8. 1. a requires that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Rev.

2, February

~

J

0

This This 1978.

Appendix A, paragraph 1.d includes administrative procedures for procedural adherence.

Procedure QI 5-PR/PSL-I, Rev.

62, "Preparation, Revision, Review/Approval of Procedures,"

Section 5. 13.2, states that all procedures shall be strictly adhered to.

QI 16-PR/PSL-2, Rev.

1, "St. Lucie Action Report (STAR) Program,"

required that STARs be initiated for Quality Assurance audit findings and independent technical review recommendations.

Contrary to the above, a

STAR was not generated when a Quality Assurance review of an inadvertent Unit 1 containment spraydown, documented in interoffice correspondence JQQ-95-143, identified the practice of pre-lubricating FCV-07-1A, Containment Spray header A flow control valve, when performing valve stroke time testing.

is a Severity Level IV violation (Supplement I).

Technical Specification 6.8. l.a required that written, procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Rev, 2, February 1978.

Appendix A, paragraph 1.d includes administrative procedures for procedural adherence, Procedure QI 5-PR/PSL-1, Rev.

62, "Preparation, Revision, Review/Approval of Procedures,"

Section 5. 13', stated that all procedures shall be strictly adhered to.

ADH-08.02, Rev 7,

"Conduct of Haintenance,"

Appendix 5, step 5, required that procedures be present during work and that individual steps be initialed once performed.

Contrary to the above, inspection of work in progress revealed that individual steps were not initialed once performed upon completion for work conducted in accordance with Plant Change/Hodification 11-195.

is a Severity Level IV violation (Supplement I).

G.

CFR 50 Appendix B, Criterion V,

" Instructions, Procedures, and

'rawings," requires, in part, that activities affecting quality shall be prescribed by documented procedures of a type'ppropriate to the circumstances.

This Contrary to the above, on August 18, 1995, venting of the Low Pressure Safety Injection (LPSI) System was conducted in accordance with a procedure which was inappropriate to the circumstances, Specifically, OP 1-0420060, Rev.

0, "Venting of the Emergency Core Cooling and Containment Spray Systems,"

did not require a verification that the portions of the system being vented were hydraulically isolated from adjacent systems and flowpaths.

As a result of this failure to establish proper initial conditions, water driven by the 1A LPSI pump was inadvertently directed to the A Train Containment Spray header, resulting in a spraydown of the Unit 1 Reactor Containment Building.

is a Severity Level IV violation (Supplement I):

Pursuant to the provisions of 10 CFR 2.201, the Florida Power

& Light Company is hereby required to submit a written statement or explanation to the U.S.

Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, D.C.

20555, with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).

This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation:

(1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.

Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response.

If an adequate reply is not received within the time specified in this Notice, an order or a

Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken.

Where good cause is shown, consideration will be given to extending the response time.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not iriclude any personal privacy, proprietary, or safeguards in'formation so that it can be placed in the PDR without reduction.

However, if you find it necessary to include such information, you should clearly indicate the specific 'information that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.

Dated at Atlanta, Georgia this 16th day of October 1995