ML17216A546
| ML17216A546 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 05/01/1986 |
| From: | Tourigny E Office of Nuclear Reactor Regulation |
| To: | Miraglia F, Russell W, Speis T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17216A545 | List: |
| References | |
| NUDOCS 8605190345 | |
| Download: ML17216A546 (18) | |
Text
~
. ~ 'S REgy
~4 Docket Nos.
50-335 and 50-389 May 1, 1986
~:.,
UNITEDSTATES NUCLEAR REGULATORY COMMISSION WASKINGTON,D. C. 20555 MEMORANDUM FOR:
THRU:
FROM:
SUBJECT:
Frank J. Miraglia, Director Division of PWR Licensing-B William T. Russell, Director Division of Human Technology Themis P. Speis, Director Division of Safety Review and Oversight Dennis Crutchfield, Assistant Director for Technical Support Division of PWR Licensing-8 Ashok C. Thadani, Director PWR Project Directorate 88 Division of PWR Licensing-B Edmond G. Tourigny, Project Manager PWR Project Directorate 88 Division of PWR Licensing-B DRAFT NRR SALP INPUT FOR ST.
LUCIE PLANT, UNIT NOS.
1 8
2 Enclosed is a draft of the NRR input to the SALP review for the St.
Lucie Plant.
The draft report is based partly upon input from selected staff personnel who have substantial contact and involvement with the St.
Lucie Plant licensing material.
Please review the draft evaluation and provide any comments you feel appropriate.
All comments received by May 9, 1986 will be considered in the final report.
Your comments may be provided verbally due to the short turn-around time.
Please note that the licensee overall evaluation for "Licensing Activities" is a Category 1.
~~z~~
Edmond G. Tour gny, Project Manager PWR Project Directorate III8 Division of PWR Licensing-B
Enclosure:
As stated ab05190345 Sb0512 PDR IIIIDOCK 05000335 6
~
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a'
Enclosure 1
Detailed Review - Licensin Activities Facility Name:
Licensee:
Evaluation Period:
NRR Project Managers:
I.
INTRODUCTION St.
Lucie Plant, Unit Nos.
1 and 2
Florida Power 8 Light Company, et al.
November 1,
1984 through April 30, 1986 D. Sells/E.
Tourigny This report represents the results of an evaluation of the licensee in the functional area of "Licensing Activities." It is intended to provide NRR's input to the SALP review process as described in NRR Office Letter No.
44 dated January 3, 1984, and NRC Manual Chapter 0516.
II.
SUMMARY
OF RESULTS NRC Manual Chapter 0516 specifies that each functional area evaluated will be assigned a performance Category (Category 1, 2 or 3) based on a composite of a number of attributes.
The performance of Florida Power 8 Light Company, in the functional area of "Licensing Activities", is rated Category 1.
III.
CRITERIA The evaluation criteria used in this assessment are given in NRC Manual Chapter 0516 Appendix, Table 1, Evaluation Criteria with Attributes for Assessment of Licensee Performance.
IV.
METMODOLOGY This evaluation represents the integrated inputs of the Project Manager (PM) and those technical reviewers who expended significant amounts of effort on St.
Lucie Plant, Unit Nos.
1 and 2 licensing actions during the current rating period.
Using the guidelines of NRC Manual Chapter
- 0516, the PM and each reviewer applied specific evaluations to the relevant licensee performance
- criteria, as delineated in Chapter
- 0516, and assigned an overall rating Category (3., 2, or 3) to each criterion.
The reviewers included this information as part of each Safety Evaluation prepared for the St.
Lucie Plant.
The PM, after reviewing inputs of the technical reviewers, combined this information with his own assessment of the licensee performance
- and, using appropriate weighting factors, arrived at a composite rating for the licensee.
This rating also reflected the comments of the NRR Senior Executive assigned to the St.
Lucie Plant SALP assessment.
A written evaluation was then prepared by the PM and circulated to NRR management for comments.
, r l
The basis for this appraisal was the licensee's performance in support of licensing actions that were completed during the current rating period.
These actions consisted of amendment
- requests, exemption requests, responses to generic letters, TMI items, and other actions, as shown in Table 1 below and in Enclosure 2.
Table 1
Licensin Activities Com leted Durin the SALP Period See Enclosure 2 for Amendments,
- Reliefs, Exemptions Issue License condition concerning heavy loads (St.
Lucie 2)
Purge and Vent Valve Operability (St.
Lucie 1)
Environmental qualification of Electrical Equipment (St.
Lucie 1)
EXXON Nuclear Creep Collapse Methodology (St.
Lucie 1)
Control of Heavy Loads, Phase I (St.
Lucie 1)
Axial Growth of Fuel Rods (St.
Lucie 2)
PASS Core Damage Assessment Procedure (St.
Lucie 2)
Control of'eavy Loads, Phase I (St.
Lucie 2)
Underground Cable Insulation (St.
Lucie 1)
Safety Parameter Display System (St.
Lucie 1 & 2)
Inadequate Core Cooling Instrumentation (St.
Lucie 1 & 2)
NUREG-0737, Generic Letter 83-37 (St.
Lucie 1 & 2)
Code Error in EXXON Analysis (St.
Lucie 1)
LOCA Outline, Compliance with 10 CFR 50.46 (St.
Lucie 1 8 2)
Masonry Wall Design (St.
Lucie 1)
Control of Heavy Loads, Phase II (St.
Lucie 1 & 2)
GL 83-28, Items
- 3. 1.3 and 3.2.3 (St.
Lucie 1 & 2)
Use of Instrumental Inspection Technique (St, Lucie 1)
ASME Code Update (St.
Lucie 1 & 2), 10-yr Inspection Interval (St.
Lucie 1)
Com letion Date 11/09/84 11/09/84 11/15/84 02/19/85 03/04/85 03/05/85 03/08/85 04/02/85 05/08/85 06/11/85 06/20/85 06/21/85 06/25/85 06/26/85 06/26/85 06/28/85 10/25/85 11/08/85 11/20/85
Table 1 (continued)
Licensin Activities Com leted Dur in the SALP Period See nclosure 2 for Amendments, Re sefs, Exemptions Issue Steam Generators GL 85-02 (St. Lucie 1 8 2)
Com letion Date 12/11/85 GL 83-28, Items 3.2.1, 3.2.2, 4.1 and 4.5.1 (St.
Lucie 1 8 2) 12/17/85 GL 83-28, Item 1.1 (St.
Lucie 1 8 2) 15K Steam Generator Tube Plugging (St.
Lucie 1)
GL 83-28, Item 1.2 (St.
Lucie 1 8 2)
GL 83-28, Item 3. 1.2 (St.
Lucie 1 8 2) 12/D/85 03/27/86 03/28/86 04/03/86 V.
ASSESSMENT OF PERFORMANCE ATTRIBUTES The licensee's performance evaluation is based on a consideration of the seven criteria specified in NRC Manual Chapter 0516.
These are:
Management Involvement and Control in Assuring equality Approach to Resolution of Technical Issues from a Safety Standpoint Responsiveness to NRC Initiatives Enforcement History Reporting and Analysis of Operational Events Staffing (Including Management)
Training and qualification Effectiveness In addition to the above, Housekeeping and Control Room Behavior is discussed.
A summary of the SALP ratings in each area is shown in Table 2 below.
Table 2 Summar of SALP Ratin s
Criterion Management Involvement and Control in Assuring equality Approach to Resolution of Technical Issues Responsiveness to NRC Initiatives
~Ratin
Table 2 (continued}
Summar of SALP Ratin s
Criterion
~Ratin Enforcement History Operational Events Staffing Training Housekeeping and Control Room Behavior Composite Rating
'I A.
Mana ement Involvement and Control in Assurin ualit During the SALP evaluation period, the licensee continued to show good management overview in the area of licensing activities.
The licensee consistently balances the licensee's desire to maintain or improve plant productivity with the need to protect the health and safety of the public.
The majority of the licensing actions completed during the SALP period were resolved by the licensing group.
This is accomplished by closely coordinating the technical efforts of three groups that are at three different locations.
In the few instances where matters needed to be referred to upper management, the individuals involved proved to be well informed and helpful in resolving questions.
This has become more significant since the establishment of the position of Site Vice President.
As a result, upper management is more involved in resolving problems, but also much better informed of conditions that need their attention.
In particular, the site vice president played an important role in resolving problems associated with a reactor coolant pump on St.
Lucie 2 and a lifting rig problem that occurred during the cycle 7
refueling outage on St.
Lucie l.
Upper management has also become deeply involved in improving the quality of the wor k done at the Plant by actively participating in the development of a quality improvement program.
During this period, errors were found in the codes that were used in the core physics analysis of both units.
The licensee's management took aggressive action to ensure the health and safety of the public by placing conservative limits on plant operations unti 1 these errors were cleared up.
The licensee's management has continued to pursue a program that is aimed at improving and increasing the technical capability of the staff.
The licensee's submittals are most often timely and of high quality.
In particular, the licensee's treatment of the no significant hazards standards of 10 CFR 50.92, have shown a steady and marked improvement during the reporting period.
There were several instances during the period when submittals were not made in a timely manner.
This occurred most frequently on requests for NRC action on items required for restart after refueling outages.
The licensee needs to improve his performance in this area.
The licensee also needs to improve in areas where information or action is required on matters that do not have an immediate impact on plant operation.
In particular, such areas include non-priority items that are part of requirements generated by operating experience, generic letters, information notices, etc.
The need for changes in the Diesel Generator technical specifications is a prime example.
During the period, the licensee management supported a number of NRC initiatives.
Most notable was the support provided for a visit dealing with the residual heat removal generic issue.
In another area dealing with the operation of the
- SPDS, the licensee supported a visit to the site that resulted in an unsatisfactory conclusion.
Because of delays in the licensee's response to the SPDS audit results, management at all levels have been brought to bear on this problem and a response is scheduled to be presented to the NRC early in the next report period.
Based upon the uniform and consistent performance of the St.
Lucie licensing group and the willingness of a knowledgeable upper management to get involved, as
- needed, a
SALP rating of Category 1 is assigned to this criterion.
B.
A roach to Resolution of Technical Issues from a Safet Stand oint The licensee continues to maintain a significant technical capability in almost all engineering and scientific disciplines necessary to resolve items of concern to the NRC and the licensee.
During the report period the licensee has expanded his staff at the Plant site as well as in the support staff located at the main office in Miami and subs'idiary office in Juno Beach.
In addition, the licensee continues to utilize the services of Combustion Engineering and EKKON Nuclear for accident analysis support.
The licensee has also utilized the ser vices of other nuclear support groups to assist in the resolution of technical problems or to utilize new and proven techniques that will enhance the operation and safety of the Plant.
They are currently asking for a review of analytical models so that they can use them to conduct in-house analyses for both of the licensee's nuclear sites.
During this period, the licensee has decided to consolidate the majority of its nuclear engineering support staff into a single office complex in Juno Beach.
This consolidation should improve the support capability provided to the St.
Lucie Plant, particularly in the reduction in response time required to resolve technical issues.
The licensee's extensive and improving technical capability is reflected in the submittals made in support of or in response to licensee or NRC initiated actions.
With few exceptions, the technical content of these submittals is complete and thorough.
Where additional information has been needed, it has been of a clarifying nature for the most part and in many cases handled by phone with a follow-up letter to confirm the verbal conversation.
Few, if any, licensee responses to NRC requests for additional information require subsequent questions.
Based upon the licensee's extensive technical capability and effective use of this resource, a
SALP rating of Category 1 is assigned to this criterion.
C.
Res onsiveness to NRC Initiatives The licensee continues to respond promptly to all NRC staff initiatives.
During the period, the licensee worked with the NRC in resolving a number of multiplant and Tt1I items.
In each
- case, the licensee carefully evaluated the action in question and provided meaningful input to the NRC staff.
Particularly noteworthy is the support provided for Generic Issue A-45, Residual Heat Removal.
Where differences of opinion have occur red, the licensee has negotiated changes in requirements to insure that the results (Technical Specifications, for example) reflect the Plant design.
This has been true in several cases that are nearing completion; i.e., diesel generator surveillance, control room design and fire protection.
Based upon the willingness of the licensee to resolve conflicts in an orderly manner and a willingness to accept the results of these negotiated positions, a
SALP rating of Category 1 is assigned to this criterion.
D.
Enforcement Histor During the SALP period, one enforcement action was taken and several actions have been initiated that will likely lead to some form of enforcement.
While conducting inspections for the Appendix R audit, the licensee found that the A 8 B trains could be made inoperable by a fire in one of the switch gear rooms.
This was reported to the NRC and led to a Level III violation without civil penalty.
During the Unit 1 refueling outage, a calculated overdose occurred during sludge lancing operations.
One conference has been held on this subject and another is scheduled to occur early in the new report period.
Severity level for this infraction, if any, is still to be determined, During a routine inspection at the site, the SRI found that unauthorized access to a vital area was possible through an open equipment and piping trench.
This will be the subject of possible future enforcement action.
Based on the fact that St.
Lucie has had a very good record in the past, this trend in the current reporting period is a cause for concern and a
SALP rating of Category 2 is assigned to this Criterion.
E.
Re ortin and Anal sis of 0 erational Events During the report period for this SALP evaluation the St.
Lucie Plant reported a total of 26 non-security events to the NRC Operations Center as required by 10 CFR 50.72.
One event was site related due to coastal flooding because of a storm and high rainfall.
Of the remaining 25 events, six were related to Unit 1 and 19 were related to Unit 2.
For Unit 1, two of the six events were reactor scrams and both were at power levels greater that 85/,
and there were two actuations of the ESF.
Unit 1's reactor trip frequency of 0. 19/1000 hours of oper ation compares very favorably to the current national average frequency of 1. 1 trips/1000 hours of operation.
One of. the Unit 1 events was the subject of an operating reactor events briefing.
This involved the failure of the reactor internals lifting rig.
Mhile removing the upper internals guide structure on November 5, 1985, one of three bolts connecting the structure to the lifting rig failed with the structure still over the core.
f For Unit 2, 10 of the 19 events were reactor scrams of which six were at a power level greater than 85K, and there were seven actuations of Engineered Safety Features (ESF).
Six of the 19 events were declared as an unusual
- event, and two events placed the licensee into limiting conditions for operation (LCO} action statements.
Unit 2's reactor trip frequency of 0.961/1000 hours operation compares favorably to the current national average frequency of 1. 1 trips/1000 hours of operation.
One of Unit 2's events was the subject of further review and the subject of an operating reactor events briefing.
This involved an oil seal failure on Reactor Coolant Pump (RCP) 2A2.
The oil leak resulted in a small fire on August 24, 1985.
There were 12 Licensee Events Reports (LER) submitted in 1985 and four to date in 1986 for both units.
Both units had an availability factor of over 80X with Unit 1's over 86K.
Events at St.
Lucie are generally reported within the required time period following the occurrence.
The reports provided adequate information describing the event and cause, if known, at that time.
Based on the above observations, a SALP rating of, Category 2 is assigned to this criterion.
If a rating were to be given to each Unit, then a
SALP rating of Category 1 would be appropriate for Unit 1 and Category 2 for Unit 2.
F.
~Staffin (Including Nanagement)
The licensing group consists of two elements.
The newest element is the group that was established at the site during this period.
It consists of three degreed engineers and one technician.
This increased level of staffing in the licensing area has improved the responsiveness to NRC requests.
It has also increased the speed with which plant specific information can be obtained.
The older group, located in Juno Beach about 45 miles from the site, consists of one manager and five engineers, all of whom are degreed.
One of the engineers spends full time on the St.
Lucie Plant project.
This part of the licensing group also supports the licensing activities of Turkey Point.
There is a relatively low and slow turn-over rate in this group and its excellence at coordinating the inputs from three separate offices has resulted in a successful licensing program.
Submittals are generally time1y, complete and of high quality.
A very high degree of cooperation with the NRC staff is exhibited by this group.
Based on the licensing group's performance, a
SALP rating of Category 1
is given to this criterion.
G.
Trainin and uglification Effectiveness The licensing group holds informal training sessions on topics of current and future interest.
The group also participates in corporate-wide training programs such as, "Supervisor Training for equality".
The training program, measured by results, has been very effective during this rating period and is about to receive INPO accreditation.
A training course for all shifts was attended at the Combustion Engineering facility in Windsor, Connecticut.
A training simulator has been ordered and is scheduled to be installed by late 1986 in a new training facility being built, just north of the current administration building, at the site.
Based on this continued improvement, a
SALP rating of Category 1 is assigned to this criterion.
H.
Housekee in and Control Room Behavior The licensee has maintained a clean and efficient plant.
During the period, added emphasis has been placed on plant cleanliness and a repainting program was initiated to improve the overall appearance of the plant.
Policing of the plant has been excellent as observed during plant tours.
Even during periods of high outage related activity, the Plant housekeeping has been excellent.
The licensee maintains a very professional atmosphere in the control room.
During a number of observations, the control room was clean and quiet with no unnecessary personn'el present.
Even during outages, the unit undergoing maintenance has maintained a high standard of housekeeping and professionalism.
The personal conduct of the operating staff and shift crews has always been observed to be professional and helpful.
V Based on the continued high state of housekeeping and professionalism exhibited at the Plant, a
SALP rating of Category 1 is assigned to this area of management interest.
VI.
Conclusion The licensee's licensing activi ties are conducted by a well staffed and well trained group resulting in an overall efficient operation.
Management overview is obvious in that the licensing group is, for the most part, well integrated into other plant activities and licensing activities reflect a uniform approach.
Upper management becomes directly involved in licensing actions when necessary to assist in resolving potential deadlocks.
The licensee is to be commended for the diligent way in which multiplant (generic) and TMI Action Items are resolved and the willingness of the licensee to compromise when necessary to achieve agreement with NRC positions.
Direct plant observations during the SALP period indicate that the plant is well maintained and the operating personnel are professional in appearance and demeanor.
The licensee's greatest strengths appear to be in the following areas:
Responsiveness to NRC Initiatives - The licensee's willingness to hold productive discussions with the NRC staff has resulted in the resolution of a significant number of multiplant action items and TNI action items.
Management Involvement and Control in Assuring equality The licensee's submittals are of high quality with a noticeable improvement in the manner in which the licensee addresses the "no significant hazards considerations" criteria of 10 CFR 50.92.
Staffing - The licensee's continued effort to upgrade the experience, capability and effectiveness of the licensing group and the supporting administrative and technical personnel required to operate a good facility.
The following areas need additional attention:
Approach to Resolution of Technical Issues - The licensee needs to be more responsive in the resolution of actions that are
- needed, but have no direct bearing on operation or health and safety of the public.
Enforcement History - The licensee needs to put additional emphasis on assuring that plant personnel are knowledgeable of regulations and that they operate the Plant within the requirements of the regulations.
Based upon the evaluation of the above criteria, an overall SALP rating of Category
- j. for the area of "Licensing Activities" is assigned.
LUCIE PLANT UNIT NQS.
1 AND 2 ADS M
Enclosure 2
1.
NRR-LICENSEE MEETINGS November 9, 1984 June 4, 1985 July 10, 1985 September ll, 1985 September 24, 1985 September 26, 1985 October 22, 1985 October 30, 1985 December 18, 1985 December 19, 1985 February 4, 1986 2.
NRR SITE VISITS November 1, 1984 to November 2, 1984 November 12, 1984 to November 14, 1984 December 10, 1984 to December 13, 1984 February 25, 1985 to February 28, 1985 April 10, 1985 to April 15, 1985 June 19, 1985 to June 20, 1985 October 6, 1985 to October ll, 1985 Cycle 2 Reload Core Support Barrel Inspection Plan LOCA Error Cycle 7 Reload Instrument Inspection Technique Security System Rod Swap and.Cycle 7 Technical Specifications LOCA Error (follow-up to July 10)
Security System DCRDR CSB Inspection Results Cycle 2 outage activities, St.
Lucie 2 Cycle 2 startup testing and plant activities, St.
Lucie 1 and 2.
Visit concerning Generic Issue A-45 Fire Protection Audit Site visit concerning Cycle 7 planning, St.
Lucie 1 Meeting with Region II to discuss licensing actions Pilot audit of St.
Lucie SPDS
November 17, 1985 to November 22, 1985 January 20, 1986 to January 25, 1986 March 4, 1986 to Narch 6, 1986 April 20, 1986 to April 23, 1986 3.
COMMISSION BRIEFINGS None "2"
Core support barrel inspection and Cycle 7 activities, St.
Lucie 1 Appendix R and Generic Issue A-45 reviews Underwater detection system testing Cycle 3 outage activities, St.
Lucie 2 4.
SCHEDULAR EXTENSIONS GRANTED None 5.
RELIEFS GRANTED April 2, 1985 January 13, 1986 6.
EXEMPTIONS GRANTED February 21, 1985 IST of Pumps and Valves, St.
Lucie 1 IST of Pumps and Valves, St.
Lucie 2 Appendix R to 10 CFR Part 50 - Fire Protection, St.
Lucie 1 7.
LICENSE AMENDMENTS ISSUED St.
Lucie 1 December 6,
1985 December 10, 1985 January 15, 1986 January 15, 1986 License Amendment 69 - Changes required by 10 CFR 50.72 and 50.73 and miscellaneous changes in definitions and administrative controls License Amendment 70 - Change to linear heat generation rate LCO from a constant value to an axially dependent limit License Amendment 71 - Allows continued operation at rated thermal power for a specific time following a dropped control assembly License Amendment 72 - Adds Auxiliary Feedwater Actuation System instrumentation to the Technical Specifications
St.
Lucie 2 November 9,
1984 March 1, 1985 March 15, 1985 October 17, 1985 November 14, 1985 December 6,
1985 April 28, 1986 1
License Amendment 8 - Techni cal Speci ficati on changes associated with Cycle 2
License Amendment 9 - Allowed power increase from 2560 HMt to 2700 MMt License Amendment 10 - Changed valve tag numbers in continuous purge and station air system License Amendment ll - Modified surveillance requirements with regard to reconnection of pressurizer heaters to their respective buses License Amendment 12 - Limits the use of the 8-inch containment purge system License Amendment 13 - Changes required by 10 CFR 50.72 and 50.73 and miscellaneous changes in definitions and administrative controls License Amendment 14 - Changes the moderator temperature coefficient to provide more operating flexibilityand remove restrictive operational requirements above 70K power 8.
EMERGENCY TECHNICAL SPECIFICATIONS ISSUED None 9.
ORDERS ISSUED June 27, 1985 Order Modifying license confirming additional licensee commitments on emergency response capability (Supplement 1 to NUREG-0737) 10.
Status of Licensin Backlo At the conclusion of the SALP period, the licensing backlog consisted of the following items:
St.
Lucie 1 TMI Related MPA Plant Specific St.
Lucie 2 9ll 7
TMI Related MPA Plant Specific 6
10 16
I
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4