L-97-291, Forwards Response to Violations Noted in Insp Repts 50-335/97-11 & 50-389/97-11.Corrective Actions:Individuals Causing Violation Issued Written Warning in Accordance W/St Lucie Plant Policy

Forwards Response to Violations Noted in Insp Repts 50-335/97-11 & 50-389/97-11.Corrective Actions:Individuals Causing Violation Issued Written Warning in Accordance W/St Lucie Plant Policy

ML17229A551
Person / Time
Site:	Saint Lucie
Issue date:	12/10/1997
From:	Plunkett T FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-335-97-11, 50-389-97-11, GL-89-10, L-97-291, NUDOCS 9712160234
Download: ML17229A551 (18)

Text

CATEGORY j.

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9712160234 DOC.DATE: 97/12/10 NOTARIZED: NO

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FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power 6 Light Co.

50-389 St. Lucie Plant, Unit 2, Florida Power

& Light Co.

AUTH.NAME AUTHOR AFFILIATION PLUNKETT,T.F.

Florida Power

&: Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Forwards response to violations noted in insp repts 50-335/97-11 E 50-389/97-11.Corrcetive actions:individuals causing violation issued written warning in accordance w/St Lucie plant policy.

DISTRIBUTION CODE:

IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General-(50 Dkt)-Insp Rept/Notice of Violation Response NOTES:

DOCKET ¹ 05000335 05000389 E

RECIPIENT ID CODE/NAME PD2-3 PD INTERNAL: ACRS FILE CE R

RCH HHFB NRR/DRPM/PERB OE DIR RGN2 FILE 01 EXTERNAL: LITCO BRYCE,J H NRC PDR COPIES LTTR ENCL 1

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E N-NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)

ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED:

LTTR 20 ENCL 20

Florida Power 5 Light Company,6351 S. Ocean Drive, Jensen Beach, FL 34957 December 10, 1997 L-97-291 10 CFR $2.201 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Re:

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Reply to a Notice ofViolation NRC Inte rated Ins ection Re ort 97-11

~A II Florida Power and Light Company (FPL) has reviewed the subject Notice ofViolation and, pursuant to 10 CFR $2.201, the response to the violations is attached.

I The violations ofthe Technical Specification limits on overtime and the missed Quality Control hold points indicate that the plant's efforts to assure procedural compliance need to continue to focus on personal accountability. The process improvements that have been made to reduce the potential for such violations in the future willbe effective since FPL willcontinue to require procedural compliance and to emphasize personal accountability.

Plant process improvements (i.e., Condition Reports and Plant Management Action Items) will ensure that violations similar to the missed Generic Letter 89-10 program requirements should not recur. Action items are highly visible to the plant's management through these processes, both from the perspective ofthe pending action item and its due date.

St. Lucie management recognizes design bases documents, such as the Total Equipment Data Base (TEDB), should reflect the latest information. In line with this philosophy, St. Lucie has scheduled a TEDB update project that willcommence in 1998. As for other design bases documents, discrepancies identified are corrected when found.

In a telephone conversion with Kerry Landis, Region IIBranch Chief, on December 10, 1997, FPL was granted an extension for the response to violation D, Systems Approach to Training.

The response to violation D willbe provided on or before December 23, 1997.

PDR ADOCK 050003 an FPL Group conlpany i> \\J v ~f llllllllllllllllllllllllllllllllllllllll

L-97-291 Page 2 Please contact us with questions on the enclosed violation responses.

Very truly yours, Thomas F. Plunkett President Nuclear Division TFP/JAS/EJW Attachment

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Regional Administrator, USNRC, Region II Senior Resident Inspector, USNRC, St. Lucie Plant

L-97-291 Attachment P~ae t Violation A Section 6.2.2.f ofTechnical Specifications states, in part, that "Administrative procedures shall be developed and implemented to limitthe working hours ofunit staffwho perform safety-related functions." Furthermore, the Technical Specification requires that "An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period, all excluding shift turnover time."

Contrary to the above, the licensee failed to limitthe working hours ofunit staff who perform safety-related functions as evidenced by the following; On September 29, a Non-Licensed Operator worked 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> in a 48-hour period, which exceeded the requirement for working no more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48-hour period.

On September 19, a Senior Reactor Operator worked 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> in a 48-hour period, which exceeded the requirement for working no more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48-hour period.

This is a repeat Severity Level IVviolation (Supplement I).

R~ea on e 1.

FPL concurs with the violation.

2.

REASON FOR VIOLATION The cause ofboth ofthe occurrences ofviolating the Technical Specification overtime limits by unit staff who perform safety-related functions was cognitive personnel error on the part ofthe Non-Licensed Operator and the Senior Reactor Operator.

In the September 29, 1997, event, the Non-Licensed Operator was offered, and accepted, overtime for four hour periods in excess ofhis regularly scheduled shift. In so doing, he worked 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period. When FPL determined that the Non-Licensed Operator had exceeded the overtime limits, he was relieved ofhis watchstanding duties by FPL shift management and sent home.

In the September 19, 1997, event, the Senior Reactor Operator had not kept track ofhis total hours worked. He traded shifts with another operator and, in so doing, violated the prohibition on working more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period.

L-97-291 Attachment

~Pa e2 3.

CORRECTIVE STEPS TAKENANDTHE RESULTS ACHIEVED A.

B In the case ofthe September 29, 1997, violation, the Non-Licensed Operator was found to be in violation ofthe Technical Specification limits on overtime while on shift. The operator was relieved ofhis watchstanding responsibilities by FPL shift management and sent home. In the case ofthe September 19; 1997, violation by the Senior Reactor Operator, the violation was identified afier the operator had been relieved ofhis watchstanding responsibilities.

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'hese two occurrences were identified by FPL personnel and, in accordance with plant procedures, Condition Reports were written to document the events, determine root cause, and identify and track to completion corrective actions.

C.

The individuals causing this violation were issued a written warning in accordance with St. Lucie Plant policy.

CORRECTIVE STEPS TO AVOIDFURTHER VIOLATIONS A.

FPL has revised Operations Department Policy Number 403 to include a checklist to be used by Licensed and Non-Licensed Operators prior to accepting a shift trade or working overtime beyond their regularly scheduled shift. The intent ofthe checklist is to ensure that the Technical Specification limits on overtime are not exceeded. The checklist includes provisions for:

1)

The operator to personally review his or her work schedule for the seven days prior to, and seven days after, the change in scheduled shift work.

2)

Personal verification, including an aftirming signature by the operator, that the Technical Specification limits on overtime willnot be exceeded as a result ofthe shift trade or unscheduled overtime.

3)

Review ofthe checklist, and an af5rming signature, by on-shift management (i.e., the Nuclear Plant Supervisor, Assistant Nuclear Plant Supervisor, or Nuclear Watch Engineer).

4)

Retention ofthe checklist for 3 months by the Operations Department Administrative Assistant.

B.

Meetings were held with Operations Department personnel to describe the circumstances which resulted in the exceedance ofthe Technical Specification I

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L-97-291 Attachment

~Pa e3 overtime limits and review the changes made to, and new requirements of, Operations Department Policy Number 403.

C.

A computerized work hours tracking system has been developed and is being tested on a trial basis. This program uses a spread sheet and conservatively alerts the user to potential Technical Specification overtime limits violations when hours worked and hours planned to be worked are entered in the database.

The computerized work hours tracking system willbe finalized, implemented, and used by Health Physics, Chemistry, and Key Mainteriance Personnel by January 15, 1998.

D.

FPL willimplement a checklist for use by Health Physics, Chemistry, and Key Maintenance Personnel similar to the checklist found in Operations Department Policy Number 403, discussed in corrective action 4.A., above. Implementation willbe completed by January 15, 1998.

Full compliance was achieved on September 29, 1997, when the Non-Licensed Operator was relieved ofhis watchstanding responsibilities, as discussed in response 3.A., above.

L-97-291 Attachment

~Pa e4 Violation B 10 CFR 50, Appendix B, Criterion X, requires "Aprogram for inspection ofactivities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity. Such inspections shall be performed by individuals other than those who performed the activity being inspected."

The licensee's Topical Quality Assurance Report implements this requirement in Section 10.2.5 stating "Mandatory hold points shall be identified in process documents when witnessing and inspecting must be performed and signed-offby the responsible personnel before work can proceed."

Procedure QI-2-PR/PSL-1, Revision 15, "Quality Assurance Program," Section 4.3 stated "Quality Control (QC) holdpoints are mandatory requirements, or are requested by supervision.

A QC holdpoint shall not be bypassed."

Contrary to the above, on August 11 and again on August 13, the licensee failed to perform the QC inspections during QC holdpoints as required by Procedure QI-2-PR/PSL-1 during reassembly ofthe SB 37-2, the Ultimate Heat Sink Valve.

This is a Severity Level IVviolation (Supplement I).

Resly~ne 1.

FPL concurs with the violation.

2.

REASON FOR VIOLATION The reason for the violation was failure to followprocedure by non-licensed utilitypersonnel.

Causal factors which contributed to the above violation are:

Mul i leNuclearPI n W rk Order W

were s o iated with the'o

- 1&C Maintenance was working on the actuator, Mechanical Maintenance was performing the disassembly, inspection, repair, and reassembly ofthe valve, and Maintenance Services was assigned the removal and re-installation ofthe valve. During the course ofthe work activities, the scope ofthe Maintenance Services NPWO was changed on four occasions, including the addition ofperforming a torque followingvalve installation. The scope change for final torque, and the torque recheck, should have been part ofthe Mechanical Maintenance NPWO, not the Maintenance Services NPWO.

L-97-291 Attachment P~ee 5 Non-standard w rkorder racticeinaccom lishin NPWOactivities-Mechanical Maintenance was performing work under a Maintenance Services (MS) NPWO. A scope change to the MS NPWO had been'made providing instructions for final torque ofthe valve following installation. However, after the re-installation ofthe valve, Mechanical Maintenance was assigned the responsibility to perform the final torque and retorque of the valve, instead ofthe original task-assignee, MS. A new NPWO should have been written, or a scope change made to the Mechanical Maintenance NPWO.

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Inade uateinter-disci linecommunications fchan in 'NPW workassi nment

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-Wh M i 'Mi e d*p kyrie pd'he retorque on the valve, it was not communicated to the day shift Mechanical Maintenance journeymen that the final torque had been completed by the midnight shift as a result ofa scope change to the MS NPWO and that Mechanical Maintenance was now working to the MS NPWO. The Mechanical Maintenance journeymen continued to work to the Mechanical Maintenance NPWO. The Maintenance foreman directed the journeymen to retorque the valve per the torque value provided in the drawing which was included as part ofthe Mechanical Maintenance NPWO, but which did not include a Quality Control (QC) hold point.

Inade uate 'ob turnover - The final torque was performed by the midnight shift Mechanical Maintenance crew to the requirements ofthe scope change to the MS NPWO and procedural requirements. The final torque was witnessed by QC as required by the procedure. Upon completion ofthe final torque, the midnight shift Mechanical Maintenance crew left the job site to attend a mandatory safety meeting and there was no turnover at the job site. Later, the oncoming day shift crew was told by the Maintenance foreman to retorque the fasteners to the specified torque value. The day shift crew was not informed that QC had witnessed the final torque or that the retorque was being performed in accordance with a scope change to the NPWO and that QC was to observe the retorque.

Inade uate ost-'o review - A timely review ofthe work package by the Maintenance foreman, Maintenance supervisor, or QC would have revealed that the retorque had not been witnessed by QC. Since the ultimate heat sink intake well in which the valve is located was not flooded immediately, there existed a window ofopportunity for the retorque to be conducted a second time and witnessed by QC.

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L-97-291 Attachment

~Pap 6 The post-job review also revealed that a second QC hold point had been missed. Prior to the installation ofthe valve, a cleanliness inspection should have been conducted, as is required for piping sizes greater than 2 inches. This hold point had been discussed prior to the performance ofthe task and determined to not be required. However, the QC hold point was not subsequently deleted from the NPWO.

CORRECTIVE STEPS TAKENANDTHE RESULTS ACHIEVED A.

FPL determined that the flnal torque had been witnessed and so documented by Quality Control.-Since the retorque was adequately documented in the journeyman's work report, there is reasonable assurance ofa satisfactory retorque.

B.

An investigation was conducted to verify that no movement was detected on any ofthe flange bolts during the retorque. This was determined by interviews conducted with the journeymen and foreman involved in the job.

C.

Two stand down meetings were held with supervisors, foreman, journeymen, Quality Control inspectors and planners involved with the maintenance.

The meetings were led by the Maintenance department head and identified the problems and process breakdowns which occurred, how to handle jobs involving multiple disciplines, communications, and responsibilities.

CORRECTIVE STEPS TO AVOIDFURTHER VIOLATIONS A.

Allplanning for Maintenance Services willbe incorporated into the plant work control organization.

This willprovide a single planning organization for all maintenance activities. This willbe completed by January 31, 1998.

B.

FPL willdevelop a Maintenance Department turnover checklist to be required to be used and signed by the responsible maintenance supervisor/foreman/chief during the turnover ofincomplete jobs to assure that criticaljob attributes and requirements are camed over from shift to shift. This corrective action willbe completed by January 31, 1998.

I C.

FPL willdevelop and implement a post-job checklist which willbe included with NPWOs to be used as a reference by the foreman and supervisor prior to close out ofthe NPWO. The checklist willbe used to address and verify, or disposition, the sign-oFof required QC hold points, or QC hold points deemed as "not applicable." This corrective action willbe completed by January 31, 1998.

L-97-291 Attachment

~Pa e7 5.

Full compliance was achieved on November 2, 1997, when it was concluded that the retorque was adequately documented in the journeyman's work report and that there was reasonable assurance ofthe completion ofa satisfactory retorque.

L-97-291 Attachment

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~Violation r

10 CFR 50 Appendix B, Criterion III,requires measures be established which assure that applicable regulatory requirements and the design basis for safety-related components and systems are correctly translated into specifications, drawings, procedures, and instructions.

Contrary to the above, as ofSeptember 25, 1997, the licensee's measures did not assure that applicable regulatory requirements and the design basis would be correctly translated into specifications, drawings, procedures, and instructions, in that:

(1)

As described in Condition Report 97-1733, the results ofdesign basis testing ofmotor-operated valves had not been incorporated into the affected design documents.

(2)

As described in Condition Report 97-1658, the data base which provided the setpoints for design basis operation ofmotor-operated valves had not been updated to reflect revised requirements from calculations and evaluations.

This is a Severity Level IVviolation (Supplement I).

Routes onse 1.

FPL concurs with the violation.

2.

REASON FOR VIOLATION The cause ofthis violation was failure to track feedback within the GL 89-10 program.

The present day St. Lucie corrective action tracking system (the Condition Report (CR) and Plant Management Action Item (PMAI)systems) did not exist at the time the GL 89-10 program was completed.

Weaknesses associated with the previous problem identification and corrective action process (STAR) were recognized by St. Lucie management.

In early 1996, STARs were converted into the CR and PMAIsystems.

The original methods available to track feedback to the GL 89-10 program were not as rigorous and formal as the present day PMAI system, and required actions were not adequately tracked during implementation ofthe MOVprogram.

During Generic Letter (GL) 89-10 self-assessment activities in 1997, utilitypersonnel determined that the initialMotor Operated Valve (MOV)Program followup items were not being implemented in a timely manner.

When the GL 89-10 program was established, a summary was developed for each MOVincluded in the GL 89-10 program scope.

These summaries include a description ofthe specific valve, valve safety significance, justification for valve performance and a discussion ofvalve design margins.

However, selected summaries included follow-up actions that were to be completed.

For example, ifa specific valve was tested under differential pressure conditions and the required thrust obtained from the test exceeded that originally calculated, the

L-97-291 Attachment

~Pa e9 affected calculations and other affected engineering documents were to be updated to include the increased thrust.

Generic Letter 89-10 program requirements and improvements identified during self assessments are now tracked in the plant's corrective action tracking system, the Plant Management Actions Items (PMAI)system.

Furthermore, the Condition Report system willresolve any discrepancies between actual field conditions and Generic Letter 89-10 program documentation identified during MOVtesting.

3.

CORRECTIVE STEPS TAKENANDTHE RESULTS 'ACHIEVED FPL revised evaluations and standards to update the St. Lucie Plant Generic Letter 89-10 program to make it current for program requirements. The following revisions were completed:

1)

Engineering Evaluation JPN-PSL-SEMP-94-027, "MotorOperated Gate, Globe, and Butterfly Valve Grouping for MOVDynamic Test Reduction Program," and Engineering Evaluation JPN-PSL-SEMP-95-024, "Motor Opera"ed Gate, Globe, and Butterfly Valve Grouping for MOVDynamic Test Reduction Program," revised the Valve Factor grouping criteria, and justifications for selected torque and thrust requirements for St. Lucie Units 1 and 2, respectively, to include considerations for pressure class, fluid temperature, fluid medium, and valve size.

2) 3)

Engineering Evaluation JPN-PSL-SEMP-91-030, 'NRC Generic Letter 89-10 Program Description," for St. Lucie Units 1 and 2 and Engineering Evaluation PSL-ENG-97-018, "Periodic Verification ofDesign Basis Capability ofSafety Related Motor Operated Valves for NRC Generic Letter 96-05," was revised to include dynamic testing ofa sample ofmotor operated balanced disk globe valves.

Engineering Standard No. STD-M-003, "Engineering Guidelines for Sizing and Evaluation ofLimitorque Motor Operators" was revised to provide specific reference to Appendix AofEPRI MOVPerformance Prediction Program Globe Valve Model Report for determination ofthe valve flow orifice (D,).

4)

Engineering Evaluation JPN-PSL-SEMP-91-030, 'NRC Generic Letter 89-10 Program Description," was revised to require the use ofthe latest EPRI MOVPerformance Prediction Program methodology for linear extrapolation ofdynamic test data. This was revised to document the acceptability ofthe previously performed linear extrapolations ofdynamic

L-97-291 Attachment

~Pa e 10 test data with regard to this criteria in the appropriate engineering evaluation ofdiagnostic test results.

5)

Engineering Evaluation PSL-ENG-97-018, "Periodic Verification of Design Basis Capability ofSafety Related Motor Operated Valves for NRC Generic Letter 96-05" was revised to address the change in stem lubricant from FELPRO N-5000 to Mobil 28 and its effect on Stem Friction Coefficient and Load Sensitive Behavior.

6)

Engineering Evaluation PSL-ENG-97-018, "Periodic Verification of Design Basis Capability ofSafety Related Motor Operated Valves for NRC Generic Letter 96-05" was revised to identify a 10% goal for Age Related Degradation.

4.

CORRECTIVE STEPS TO AVOIDFURTHER VIOLATIONS FPL willrevise appropriate calculations and GL 89-10 engineering evaluations to incorporate the latest design information ( e.g., single valves, load sensitive behavior, feedback oftest data, stem friction coefficients =0.2, etc.). This corrective action willalso include incorporation ofthe Phase 2 EPRI Performance Prediction Program results including the Safety Evaluation provisions and long term plans where the EPRI model is used as best available data: Total Equipment Data Base (TEDB) update willalso be performed as a result ofthe calculation and document revisions.

The calculation and evaluation revisions and TEDB update willbe completed by March 31, 1998.

Full compliance willachieved by March 31, 1998, when the calculation and evaluation revisions and TEDB update are completed, as discussed in item 4A., above.