ML17223A228
| ML17223A228 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 04/30/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17223A227 | List: |
| References | |
| 50-335-89-13, 50-389-89-13, NUDOCS 8907210065 | |
| Download: ML17223A228 (16) | |
See also: IR 05000335/1989013
Text
ENCLOSURE
INTERIM SALP
BOARD REPORT
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMATIC ASSESSMENT
OF LICENSEE
PERFORMANCE
INSPECTION
REPORT
NUMBER
50-.335,
389/89-13
FLORIDA POWER
AND LIGHT COMPANY
ST.
LUCIE UNITS
1
AND 2
NOVEMBER 1,
1987 " APRIL 30,
1989
890721006'~07j0
A110CK 0 000335
9
I.
INTRODUCTION
The
Systematic
Assessment
of Licensee
Performance
(SALP) program is
an
integrated
NRC staff effort to collect available observations
and data
on
a periodic basis
and to evaluate
licensee
performance
on the basis of this
information.
The
program is supplemental'o
normal regulatory processes
used to ensure
compliance with NRC rules
and regulations.
It is intended
to
be sufficiently diagnostic
to provide
a rational basis for allocation
of
NRC resources
and to provide
meaningful
feedback
to the
licensee's
management
regarding
the
NRC'
assessment
of their facility'
performance
in each functional area.
,
An
NRC
SALP Board,
composed
of the staff
members
listed below,
met
on
June
26,
1989, to review the observations
and data on,performance,
and to
assess
licensee
performance
in
accordance
with
Chapter
"Systematic
Assessment
of
Licensee
Performance."
The
guidance
and
evaluation criteria
are
summarized
in Section III of this report.
The
Board's
findings
and
recommendations
were
forwarded to the
NRC Regional
Administrator for approval
and
issuance'his
report is the
NRC's assessment
of the licensee's
safety performance
at
St.
Lucie Units
1
and
2, for the
period
November
1,
1987
through
April 30,
1989.
The
SALP Board for St.
Lucie was
composed of:
C.
W. Hehl, Deputy Director, Division of Reactor Projects
(DRP),
Region II (RII) (Chairman)
A.
F. Gibson, Director, Division of, Reactor Safety,
(ORS), RII
W.
E. Cline, Chief, Nuclear Materials Safety
and Safeguards
Branch,
RII
M. V. Sinkule, Chief, Reactor Projects
Branch 2,
ORP, RII
H.
N. Berkow, Director, Project Directorate II-2, Office of Nuclear
Reactor Regulation
(NRR)
S.
A. Elrod, Senior Resident
Inspector,
St. Lucie,
ORP, RII
J.
Norris, Project Manager,
Project Directorate II-2, NRR
Attendees
at
SALP Board Meeting:
R.
V. Crlenjak, Chief, Project Section
28,
ORP, RII
W.
K. Poertner,
Project Engineer,
Project Section
2B,
ORP, RII
S.
J . Vias, Project Engineer,
Project Section
2B,
DRP, RII
M. A. Scott,
Resident
Inspector,
St.
Lucie,
ORP, RII
K.
O. Landis, Chief, Technical
Support Staff,
ORP, RII
A.
Licensee Activities
During this
SALP period, Unit
1 was
on line for a total of 496 days
with a unit capacity factor of 91. 1 I, and Unit 2 was
on line for 434
days with a capacity factor of 78.5 X.
The forced outage
rates
were
1.06 I and
1.35
X
for Units
1
and
2
r espectively.
The operating
history during this assessment
period is described
below.
June
20-24
and July 11-15,
1988;
This special
inspection
was
conducted
in the area of quality assurance
effectiveness.
September
12-16,
1988; This special
inspection
was conducted
in
the
area
of
Environmental
gualification
(Eg)
of electrical
equipment.
January
23-27,
1989; This special
team inspection
was conducted
to verify conformance
to Regulatory
Guide 1.97,
Instrumentation
for Light-Water-Cooled Nuclear
Power Plants to Assess
Plant
and
Environs Conditions During and Following an Accident.
February
21 - March 3,
1989; This special
inspection
involved a
site visit by the
NRC
NDE van.
February
27
March 3,
1989;
This special
team
inspection
was
conducted
in the area of Eg of electrical
equipment.
March 13-17,
1989; This special
inspection
was conducted
in the
area of design, control.
II.
SUMMARY OF RESULTS
St. Lucie continues
to perform as
one of the top sites in the region.
This is evident
by the consistent
FPL staff enthusiasm'nd
effort
shown at St. Lucie.
No major weaknesses
were identified.
The staff is encouraged,
by the positive
steps
taken to reduce the,
number of plant trips during this evaluation period.
As discussed
in
the Plant Operations
section of this report, this effort reduced
the
number
of plant trips during this evaluation
period
to five
as
compared
to fourteen trips during the previous evaluation period.
Improvement
was also noted in the area of radiological controls with
substantial
reductions
realized
in
personnel
contaminations,
personnel
exposures,
as well
as gaseous
and liquid effluent releases.
The
ALARA program
and radiological control efforts during the period
have
been effective and current trends indicate continued
improvement
is likely.
Functional
Area
Rating Last
Rating This
Period
Period
Trend
Plant Operations
(Operations
& Fire Protection)
Radiological
Controls
Maintenance/Surveillance
Emergency
Preparedness
Security
Engineering/Technical
Support
(Engineering,
Training
8 Outages)
1/NR
2
1/1
1
2
NR/1/1
Improving.
reasonably
allocated
so that good plant and personnel
performance
',:
being achieved.
NRC attention
may be maintained at normal levels.
3.
~Cate or
3.
Licensee
management
attention to arid involvement in the
performance
of nuclear
safety
or
safeguards
activities
are
not
sufficient.
The licensee's
performance
does
not significantly exceed
that
needed
to
meet
minimal
regulatory
requirements.
Licensee
resources
appear
to
be
strained
or
not effectively
used.
NRC
attention
should
be increased
above
normal levels.
The
SALP Board
may also
'nclude
an appraisal
of the performance
trend of a
functional
area.
This performance
trend will only be
used
when both
a
definite trend of performance within the evaluation period is discernible
and the
Board believes
that continuation of the trend
may result in
a
change of performance
level.
The trend, if used,
is defined as:
~lm rovin
Licensee
performance
was determined
to be
improving near the
close of the assessment
period.
~Declihin:
Licensee
performance
was determined
to be declining near the
close of the
assessment
period
and the licensee
had not taken meaningful
steps to address
this patterns
IV.
PERFORMANCE ANALYSIS
A.
PLANT OPERATIONS
l.
A~nal sis
During
this
assessment
period
routine
inspections
and
evaluations
of
plant
operations
were
performed
by
the
resident
and regional
inspection staffs.
Management
involvement
in daily activities
continued
at
the
high levels
discussed
in the
previous
two
SALP evaluations.
The site
Vice President
continued
to
be
highly visible
in
daily coordination
and
policy activities
and
to
vigorously
support
various
site
coordination
and
planning
meetings
and
guality
Improvement
Team
activities.
He
also
projected
a
continuing
insistence
on
coordination,
communication,
and
early
identification
and
resolution
of. potential
problems.
The
nuclear
Plant
Manager
continued
his proactive
leadership
and
monitoring
role
concerning
operational
activities,
the
implementation
of policy,
and
the
implementation
of
the
guality in Daily Work program.
Control
room
operations
continued
to
be
conducted
in
an
excellent
manner.
Staffing,
professional
demeanor,
knowledge
of plant
status,
and
procedure
adherence
have all
been
positive.
The
licensee
had,
some
years
ago,
developed
a
relatively
simple
process
for
control
of
routine
operational
activities
and
activities
required
by
the
Technical
Specifications
(TS).
This
process
was
based
on
an
use
revg ew
Thi s
1 nvol vement
sophisticated
quality
techniques
is
considered
a
program
h.
Mana ement
also
implemented,
via
a
new
procedure
addressing
unit reliability,
a policy encourag
g
p
ura in
the
lant
opera
ors
o
t
t
severely
restrict
the
simultaneous
conduct
of
ave
a
activities
a
't'hat
would either
be trip sensitive
or
h
potential
detrimental
effect
on
plant
operations.
The
new
procedure
did not
replace
earlier
administrative
procedures
concerning
process
ng
ing
of
control
documents,
but
rather'ocused
on
management
control.
For
troubleshooting
or
lifting
ea
s,
n
1
d
it included detailed prior review for effects
b.
th
i dividual
requesting
to troubleshoot
or
e
r lift leads,
department
head
review
and
concurrence
that
the
wwork
was
essential
at
that
particular
time,
detailed
independent
f
ff ts
and
Operations
Supervisor
concurrence.
r
b
For
manipulation
of
switches,
valves
or
breakers
y
t
ersonnel
it required
Nuclear
Plant
Supervisor
or Assistant
review
of
the
proposed
action
for
mpact
br iefing of the control
room operators,
.and the authority to
ritten
procedure:
With
regard
to
unusual
d
I -h
E
t
occurrences
or
near
misses, it requ re
an
n-
o
Summary
be
prepare
an
d
and
that
work stop until
an
assessment
could
be
ma
e
y
d
b
the
Operations
Supervisor.
The
procedure
for
an
suppor
ng
m
d
ti
anagement
emphasis
have
been
in effect
or
approximately
10
months
and
appear
to 'have
had
a
dramatic
effect in reducing challenges
to safety
systems,
Lapses
in
a
en
o
tt
tion to detail
by the
operating
staff
were
ulted
in
i
en i ie
'd t'f'
during
the
evaluation
period
and
resu
violations
being
issued.
Several
examples
p
tt
tion
to
detail
were
also
identified
late
in
the
evaluation
period
by
NRC
inspectors.
This
included
final
c'lose-out
o
e
n'
the
Unit
2
containment
prior
to
mode
change
e
ion -term
ft
th
scheduled
1989
refueling
- outage
and
the
g-
operation
of
containment
coolers
in
both
units
ith the
cooler'oors
not tightly closed.
.Both
lapses
were
promptly
addressed
by
the
licensee
upon
identification
by
the
inspectors.
0 'his
evaluation
period
one
Severity
Level
III
uring
onin
of
a
vio a ion
w
1 t's
issued
involving the
improper positi
'
switch
which
caused
the
bypassing
of
letdow
own
isolation
t ti
a
d
safety
injection
actuation
signals
to
a
containment
isolation
valve,
which would
have
p
automatic
closure.
No
imposition
of civil
penalty
was
assessed.
An
Emergency
Operating
Procedure
(EOP)
Team
inspection
conc
u
e
a
1
d d
that
the
were
adequate
for
use
by
well
s
were
identified
in
trained
operators.
However,
weaknesses
w
t e
areas
o
h
f
technical
adequacy
of
procedures,
human
factors,
and
training.
The
licensee
has
p
s
im lemented
a
program to resolve
the identified weaknesses.
The
licensee
has
experienced
a
reduct'."n
in the
number of
personnel
contamination
events
during
the
assessment
period.
During
1987,
the
licensee's
annual
goal
for
personnel
contamination
was
250 events.
Due
to
outage
work
on
both
units
and
the
lowering
of
the
personnel
contamination
threshold,
from
5000
dpm/100cm~
to
1000
dpm/100cm~,
. the
licensee
had
606
personnel
contaminations
that year.
During
1988,
the
licensee's
personnel
contamination
goal
was
set at
,400
and
the
licensee
met their
goal
objectives
with
315
contaminations,
cutting
the
previcus
years
total
by
approximately
50%.
With
increased
management
emphasis
the
licensee
lowered
the
1989
goal for personnel
contaminations
to
272.
However,
upon
completion
of the Unit
2
outage
in
April 1989,
with
only
62
personnel
contaminations',
management
reduced
the
1989
goal
to
90.
The
licensee
also
improved its
personnel
contamination
monitoring
program with
the installation of whole
body monitors at
the
RCA exits
in
1988.
The
licensee
credits
the
activity of
the
quality
improvement
team
formed
in
1986,
and
strong
management
emphasis
on
reducing
personnel
contaminations,
as
key
factors
in
their
successful
trend
of
reduced
personnel
contaminations.
The
licensee
technician
and
general
employee
radiation
protection
training
programs
were
adequate.
The
licensee's
technician
training
programs
are
accredited
by the Institute
for
Nuclear
Power
Operations
( INPO).
During
the
salp
period,
NRC inspectors
determined
that
the
licensee
utilized
vendor
personnel
to
provide
general
employee
radiation
protection
training
to radiation
workers.
The
licensee
was
not qualifying the
vendor
instructors
to the
approved
instructor
qualification
program.
In
January
1989,
the
licensee
committed
to
provide
formal
training
programs,
similar
to
those
approved
by
INPO,
for all
contractor
trainers providing general
employee training.
Management
attention
in the area,of
keeping
exposures
as
low
as
reasonably
achievable
(ALARA)
was
increased.
During
1987,
the licensee
had
set
a person-rem
goal
of
982
for the
site,
and
actual
exposure
for
1987
was
896,
or
448
person-rem
per Unit, which
was slightly above
the
national
average
for
pressurized
water
reactors
(PWRs)
at
390
person-rem
per unit.
During
1988,
the
licensee's
exposure
goal
was
609 person-rem
and
the actual
exposure
for the year
was
569
or
285
person-rem
per unit.
Through
the
end
of
March 1989,
the
licensee's
site
exposure
was
288 person
rem..
The 'icensee
had
completed
most
of
the
refueling
work
by
that
date
and
was
on
schedule
to
stay within the
station
1989
person-rem
goal
of
514.
The
licensee
has
formed
a
quality
improvement
team
to
look
at
other
personnel
exposures
to
see if
non-outage
exposures
can
be
further
reduced.
13
numerous
radioactive
storage
".eas,
disposing
of radioactive
waste
where
possible,
and
has
ensured
that radioactive
waste
containers
are properly labeled
and controlled.
Three violations were identified in this area.
2.
Performance
Ratin
Category:
2 Improving
3.
Recommendations
Significant
improvement
was
noted
during
the
assessment
period
in the
area
of radiological controls with substantial
reductions
realized
in
personnel
contaminations,
personnel
exposures,
as
well
as
gaseous
and liquid effluent releases.
The
ALARA program
and
radiological
control
efforts
during
the
period
have
been
effective
and current
trends
indicate
continued
improvement is likely.
C.
MAINTENANCE/SURVEILLANCE
~Anal
ala
Evaluation
of this functional
area
was
based
on
the results
of routine
inspections
performed
by the
resident
inspectors,
routine
inspections
by
regional
inspectors,
and
special
inspections
in
the
area
of Environmental
gualification
(Eg)
of Electrical
Equipment,
a guality
Assurance
Effectiveness
(gAE) inspection
and
a site visit by the
NOE van.
Licensee
management
has
continued
to maintain
overall
good
performance
in the
maintenance
and
surveillance
areas
during
the
assessment
period.
With
few exceptions,
administrative
and
work
procedures
used
to
control
maintenance
and
surveillance
activities
were
consistent
with
Code,
regulatory requirements
and licensee
commitments.
Management
has
been
effective
through
the
guality
Improvement
Program
((}IP) in
focusing
actions
required
to
correct
the
pattern
of
equipment
failures
and
design
deficiencies
that
had
led
to
challenges
to
safety
systems
and plant trips during previous
SALP periods.
As
a
result
of design
changes
developed
to
a
new
design
charging
pump
packing,
the
number
of charging
pump
repacks
per
year decreased
from 43 in
1984 to eight to
1987
and this
positive
trend
continues.
Likewise
the
number
of reactor
coolant
pump
(RCP)
seal
change-outs
has
been
reduced
significantly during this
period
due to extended
lifetime of
the
seals,
resulting
from
implementation
of modifications
recommended
by
the
gIP
team
investigating
seal
failure
history.
15
procedure.
Local
leak rate test
personnel
were well qualified
for their job functions
and were knowledgeable
of procedural
and
regulatory
requirements.
Staffing
level s
in thi s
area
was
adequate
for the activity.
The licensee's
program for obtaining
Pressurizer
SRV setpoint,
utilizing air
as
the test
medium,
while meeting
the present
regulatory requirements,
did not comply with the latest industry
standards
contained
in
ANSI/ASME OM-1-1981,
Requirements
for
Inservice
Testing
of
Nuclear
power
Plant
Pressure
Relief
Devices,
which requires that
a correlation
between
steam
and air
be established.
Although the licensee
has not been
required
to
incorporate
OM-1-1981 into the
SRV setpoint test
program, it
will be
a requirement
in the future
and early incorporation of
OM-1-1981 would result
in a significant improvement.
Strengths
identified in the pressurizer
SRV setpoint test
program involved
actions
planned to determine
the cause of excessive
pressurizer
SRV seat
leakage
and
a
new policy to obtain
as-found
setpoints
values.
Post-refueling
and
power
escalation
testing activities
were
reviewed for the Unit
1 - Cycle
9 and Unit 2 - Cycle
4 refueling
outages
for this period.
The procedure
for initial criticality
following refueling
was
found to
be
sound
in principle,
but
requiring
improvement
in
implementation
in
confirming
operability
of
neutron
monitors,
plotting
inverse
multiplication,
and
establishing
a
criterion
for securing
dilution.
The zero
power physics test
program
was
found to
be
basically
sound,
but needing
improvement
in calibration of the
reactivity of rod worth measurements.
Three violations
and
one deviation were identified in this area.
2.
Performance
Ratin
3.
Category:
1
Recommendations
None
D.
EMERGENCY- PREPAREDNESS
A~nal ala
The
inspections
conducted
during this
assessment
period
by
Resident
and
Regional
inspectors
included
an emergency
response
exercise
and
two routine
emergency
preparedress
inspections.
Two Emergency
Plan revisions
were submitted
by the licensee for
NRC review.
During this
SALP period, the lic ansee
continued
to
demonstrate
the
capabi.lity
to fully implement
the critical
aspects
of emergency
preparedness
during simulated
and
actual
emergency
events.
17
One violat'.on; as identified but not issued
in this area.
2.
Performance
Ratin
Category:
1
3.
Board Comments
None
E.
SECURITY ANO SAFEGUARDS
A~nal sfs
The Physical
Security functional area evaluates
and assesses
the
adequacy
of
the
security
program
to
provide protection
for
station vital systems
and equipment.
To determine
the
adequacy
of the protection provided, specific attention
was given to the
identification
and
resolution
of
technical
issues,
responsiveness
to
NRC
initiatives,
enforcement
history,
staffing,
effectiveness
of training
and qualification.
The
scope
of this
assessment
includes all
licensee
activities
associated
with access
control, physical barriers,
detection
and
assessment,
armed
response,
alarm
stations,
power
supply,
communications,
and compensatory
measures
for degraded
security
systems
and
equipment.
This evaluation is based
on routine
and
reactive
inspections
conducted
by the
NRC in this
and related
functional areas.
Authority
and
responsibilities
associated
with the
security
organization
were clearly delineated
and,
in general,
appeared
to
be
effective.
The
site's
contract
security
force
is
adequately
staffed
and appropriately trained
and
equipped.
The
facility Guard Training and gualification Plan is implemented
on
a continuing basis
at all levels of the security organization
using the onsite training staff.
The
licensee
has
provided
the
security
force with adequate
procedures.
Security
plan
changes,
with
one
exception,
have
been
submitted
on
a
timely basis
and
licensee
records
are
complete
and adequately
maintained with the exception of the two
instances
noted during this evaluation
period.
The, licensee's
Safeguards
Event
Reports
have
been
submitted
promptly
and
complete.
The
licensee's
independent
security
program
audit
covered
various aspects
of the site security program.
The auditors
were
thorough
and
knowledgeable
of security program requirements
and
commitments.
Long standing
issues
relating to .intrusion detection capability
for
some
segments
of
the
protected
area
perimeter
remain
unresolved,
resulting
in
extensive
and
extended
use
of
19
t"chnical
support provided
for operation,
maintenance,
testing
and
surveillance,
operator
training,
procurement,
and
configuration control.
This evaluation is based
on routine
and
special
inspections
conducted
by
the
NRC in this
area
and
related functional areas.
Performance
in this functional
area
has
been
good during this
assessment
period.
Oevelopment
and
implementation
of plant
modifications
have
been
thorough
and
well
documented.
The
'engineering
staff
demonstrated
a
sound
knowledge
of
environmental
qualification
(EQ)
issues
and
implementation
of
this program
has
been effective.
The use of Quality Improvement
Program
(QIP)
teams
has
provided
a technical
focus
on plant
problems
resulting
in
improved
plant
reliability.
The
engineering staff support of onsite activity has
been effective
and. response
to
NRC initiatives
has
been
good.
Improved staff
performance
could
be achieved
in
10
CFR
50.59
evaluations
of
lifted leads
and jumpers,
generic
communications
and operator
training.
Oevelopment
and
implementation
of modifications
and
design
changes
have
been
thorough
and technically
sound.
Management
was actively involved in assuring quality design output.
Onsite
and offsite
engineering
staffs
were
knowledgeable
of plant
systems
and current configurations
and the interface
between
the
engineering
groups
was
effective.
Although
different
engineering
groups utilize different 'procedures
to accompli sh
10
CFR 50.59 evaluations,
the evaluations
were adequate,
indicating
a
basic
understanding
of this
evaluation's
purpose.
Staff
performance
of these
evaluations
however,
did not consistently
include temporary modifications associated
with lifted leads
and
jumpers.
Performance
of independent
calculations
to confirm
vendor work provided additional
as'surance
of quality engineering
activity.
The
engineering
staff
was
knowledgeable
of
issues
and
responsive
to
NRC
inquires
. during
EQ 'inspections
performed
during this assessment
period.
Implementation of the
EQ program
at
St.
Lucie
has
been
gener ally
adequate.
NRC identified
weaknesses
related
to tracking of
EQ maintenance
and
motor
operated
valve
(MOV) heater circuits resulted in timely correc-
tive action.
This prompt corrective action
and
the employment
of independent
contractors
to review the site
program
was
indicative
of
management
involvement
in the
program
and
resolution of technical
issues.
The
technical
staff'
utilization
of QIP
teams
to
focus
on
specific
plant
problems
has
resulted
in
enhanced
plant
reliability.
The Critical
Systems
Monitoring
program,
previ-
ously discussed
in the Plant Operations
section of this report,
is
a predictive
tool
which provides
early identification of
.
trends
which could potentially result
in plant trips or
LCO
conditions.
The actions
from the
operator
errors
study
have
21
management
meeting
held
on January
11,
1989 at the St.
Lucie
site.
Two replacement
operator
licensing
examinations
were adminis-
tered
during this
assessment
period.
The first
exam
was
administered
to
5
SRO and
15 RO,candidates.
The second
exam was
administered
to the three
RO candidates
failing the
simulator
portion of the initial exam.
The operator
candidates
failing
examinations
during this assessment
period failed on the simula-
tor portion of the
exam,
indicating
a
need to improve training
on cont) ol board manipulations.
No violations were identified fn this area.
2.
Performance
Ratin
Category:
1
3.
Recommendations
None
G.
SAFETY ASSESSMENT/
UALITY VERIFICATION
~Anal sl s
In general,
management
involvement
and control to assure quality
were
evident
throughout
the
assessment
period.
The
company's
commitment
to
achieving
and
maintaining
high
standards
of
performance
is evidenced
by maintaining the Vice-President
level
management
representation
at the St.
Lucie site.
The management
personnel
at the site
and at the corporate offices are readily
accessible
and willing to involve themselves
in technical
and
safety issues.
The lines of communication
are
always
open.
To
assure
quality,
the
licensee
is
continuing
the Quality
Improvement
Program (QIP).
The results of meetings with the
NRC
staff to review
the
status
of active
licensing
issues
held
approximately
every
six
weeks
are
used
by
the
licensee
to
improve
the
QIP's
effectiveness
in the
licensing
area.
The
previously instituted computerized
system of tracking licensing
commitments
is used efficiently and results
in timely responses
and
maintaining
of
schedules.
A monthly
status
report
is
printed out for management
information.
The licensee
is committed to maintain
excellence
fn individual
performance
with
emphasis
on
personal
involvement
and
responsibility
for
plant
operations.
This
approach
has
demonstrably
proved
successful
in
the
overall
licensee
performance.
The
licensee
program to ensure
quality was
good
with respect
to identification and correction of problems,
This
was
demonstrated
by the effectiveness
of the
nonconformance
reporting program.
Identified nonconformances
were reviewed for
23
Program
was
superior
and
that,
the
accident
and
analysis
could justify 'the
change.
The staff could not agree
with the
licensee
and
denied
the
application
request.
On
another
occasion,
during review of the request
to transfer Unit
I spent
fuel to Unit 2,
the staff found
one of the
proposed
casks for fuel transfer
unacceptable
for >ts intended
use.
In
almost all
cases
the
licensee
has
been
cooperative
and
responsive
to
NRC initiatives.
For
example,
in
response
to
the license'equested
and
was
granted
changes
in Sections
3.0 and 4.0 of the St.
Lucie TS.
Simil.-.-ly,
the deletion
of organizational
charts
from the Administra;ive
Controls
section
of the
TS
was
requested
in response
to staff
initiative.
Another
example
was
the
request
relating to the
maximum control element
assembly
drop time.
This submittal for
Unit
2
was
made
in
response
to
Information
Notice 88-.47.
However,
the
licensee
was
slow in responding
to
some
of the
requirements
of
the
rule.
The
licensee
delayed
implementation
of the modifications, waiting for the staff to
approve
the
design
concept
even
though
pre-approval
of the
design
by
the
staff
was
not
required.
The
licensee
had
previously requested
and
was granted
a schedular
exemption
from
the
ATWS Rule.
After being
infor'med
by the staff that another
schedular
exemption
was not likely to be granted,
and facing the
possibility of being in violation of the
ATWS Rule, the licensee
took positive
steps
to implement
the modifications during the
1990 refueling outages.
The
licensee
maintains
more
than
adequate
staff to
support
licensing activities.
All individuals are technically competent
and well trained'.
The
licensee
maintains
adequate
technical
resources
at
the
St.
Lucie
site
and
at its
Juno
Beach
headquarters.
In addition,
as
may
be
required,
the
licensee
draws
on
the
technical
assets
of the St,
Lucie
vendor,
consultants
and architect/engineer.
Such cooperative effort has
produced
good results
on
sound
resol,ution of technical
issues
from
a safety
standpoint.
The
increased
fuel
enrichment
for
fuel
sto'rage
in the
new fuel racks for Unit I exemplifies
such
joint technical effort.
From the submittal it was
obvious that
the licensee
performed
a
QA review of the documents
before they
were
presented
to
NRC.
Additional examples
of such technical
cooperation
were the
two separate
requests
for Unit I and Unit 2
relating
to the
Boric Acid Makeup
System
(BAMS).
In
these
requests
the licensee
proposed
to lower boric acid concentration
in the
BAMS in order to eliminate
heat
tracing
requirements.
Although most of the original technical
work was
performed
by
CE,
the licensee
did
an
independent
check of CE's work before
requesting
the change.
The licensee
stays
abreast
of industry experien~e
and approaches
to plant safety issues
and stays
informed of. programs,
problems
and
resolutions
at
other
plants
by participating
in major
industry groups
and by membership
in the owners groups.
e
25
B.
Mana ement Meetin
s
November 24,
1987
-
Site visit and tour by Commissioner
Rogers
January
26,
1988
-
SALP meeting with licensee
at St.
Lucie
site
May 26,
1988
Enforcement
conference
to discuss failure
to
meet
the
requirements
of
Technical Specification 3.6.3 for operable
containment
isolation valves.
September
6,
1988
Enforcement
conference
to discuss
failure
to
control
access
to
a vital 'area
and
failure to report the violation within one
hour.
October
12,
1988
Meeting in NRC headquarters
to discuss
licensing actions
January ll, 1989
-
Meeting at the St.
Lucie site to
discuss
key Emergency Operating
Procedures
(EOP)
C..:
Confirmation of Action Letters
None
D.
Review of Licensee
Event
Re orts
LERs
During the evaluation
period,
18
LERs for Units
1
and
2 were
ana-
lyzed.
The distribution of the events
by cause,
as determined
by the
NRC staff,
was
as follows:
Cause
Total
Component
Design
Construction,
fabrication
or installation
Personnel:
- operating activity
- maintenance activity
- Test/calibration activity
- Other
Other
7
4
1
0
2
18
27
d.
On September
20,
1988,
the reactor tripped from 10(C power
on low steam generator
level
due to the inadvertent closure
of -a
main
regulating
valve.
Personnel
were
working -on the 'B'team, generator
feed regulating
system
in an effort to minimize water level swings.
2.
Unit 2
a.
On
November
25,
1987,
the reactor tripped
from
50% power
durinc
physics testing following a refueling outage
due to
a
generator
lockout
and
The
generator
lockout
was
caused
by
the
failure of
the
g9
turbine
generator
bearing.
H.
Effluent Release'Summar
a
~
Liquid Releases
Activity Released
by Year (Curies)
1986
1987 '988
1.
Fission
and Activation
4.96
E+00
9.96
E-01
5.23 E-Ol
Products
2.
5.56
E+00
6.76
E+02
5.50
E+02
. b.
Gaseous
Releases
1.
Fission
and Activation
4.33
E+04
1.48
E+04
1
~ 06
E+04
Products
2.
and
3. 11 E"01
9.46 E"02
3.48 E"02
Particulates