ML17228B475

Forwards Response to NRC 960318 Ltr Re Violations Noted in Insp Repts 50-335/96-01 & 50-389/96-01.Corrective Actions: 1B EDG Periodic Test & General Operating Instructions,Rev 22 Was Reviewed by Frg & Approved by Plant General Manager

ML17228B475
Person / Time
Site:	Saint Lucie
Issue date:	04/23/1996
From:	Plunkett T FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-96-91, NUDOCS 9604300105
Download: ML17228B475 (8)

Text

CATEGORY 1 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION MBR:9604300105 DOC.DATE: 96/04/23 ACIL:50-335 St. Lucie Plant, Unit 1, Florida Power s Light Co.

NOTARIZED: NO DOCKET I 05000335 50-389 St. Lucie Plant, Unit 2, Florida Power 6 Light Co. 05000389 AUTH. NAME AUTHOR AFFILIATION PLUNKETT,T.F. Florida Power a Light Co.

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

SUBJECT:

Forwards response to NRC 960318 ltr re violations noted in insp repts 50-335/96-01 & 50-389/96-01.Corrective actions:

1B EDG Periodic Test 6 General Operating Instructions,Rev 22 was reviewed by FRG & approved by Plant General Manager.

DISTRIBUTION CODE: ZEOID COPIES RECEIVED:LTR 1 ENCL I SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 PD 1 1 NORRIS,J 1 1 INTERNAL: ACRS 2 2 AEOD/SPD/RAB 1 1 AEOD/TTC 1 1 DEDRO 1 1

~~FILE CEN~TER~ 1 1 NRR/DISP/PIPB 1 1

~NRR/DRCH7HHFB 1 1 NRR/DRPM/PECB 1 1 NRR/DRPM/PERB 1 1 NUDOCS-ABSTRACT 1 1 OE DIR 1 1 OGC/HDS3 1 1 RGN2 FILE 01 1 1 D

EXTERNAL LITCO BRYCEF J H 1 1 NOAC 1 1 NRC PDR 1 1 N

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE CONTACT THE DOCUMENT CONTROL DESKS ROOM OWFN SD-5(EXT. 415-2083) TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 19

Florida Power & Light Company, P.O. Box 14000, Juno Beach, FL 33408-0420 APR 23 $ 996 L-96-91 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 of Violation Ins ection Re ort No. 96-01 Florida Power and Ught Company (FPL) has reviewed the subject inspection report and, pursuant to 10 CFR 2.201, the response to the notice of violation is attached.

NRC Inspection Report No. 96-01 was dated March 18, 1996. FPL received the inspection report on March 26, 1996. The inspection report required a response within 30 days of March 18, 1996 (i.e., by April 17, 1996). The delayed receipt of the inspection report by FPL was discussed between K. D. Landis of the NRC and E. J.

Weinkam of FPL on March 29, 1996. As a result of the delay in receipt by FPL of the ihspection report, FPL's response herein attached, and as agreed to by the NRC staff in a conversation on April 12, 1996, is being submitted within 30 days of receipt of the inspection report by FPL.

Very truly yours, T. F. Plunkett President Nuclear Division TFP/WHB/EJW Attachment cc: Stewart D. Ebneter, Regional Administrator, USNRC Region II Senior Resident Inspector, USNRC, St. Lucie Plant

~- vI 3OOO23 9604300105 05000335 ir60423 PDR ADOCK 8 PDR an FPL Group company

L-96-91 Attachment VIOIATION:

Technical Specification 6.8.3 provides that temporary changes to procedures required by Technical Specification 6.8.1 may be made, without prior review by the Facility Review Group (FRG) or approval by the Plant General Manager, provided that the intent of the original procedure is not altered.

Contrary to the above, the licensee made temporary changes to procedures required by Technical Specification 6.8.1, without prior review by the FRG or approval by the Plant General Manager, that altered the intent of the original procedures. Examples include:

Temporary Change (TC) 1-95-569 of October 30, 1995, revised OP 2200050A, 1A emergency diesel generator (EDG) Periodic Test and General Operating Instructions, Rev. 22. The TC revised surveillance test acceptance criteria for load variations. Changing the 1A EDG surveillance test acceptance criteria altered the intent of the original procedure.

2. TC 1-95-570 of October 30, 1995, revised OP-1-2200050B, 1B EDG Periodic Test and General Operating Instructions, Rev. 22. The TC revised surveillance test acceptance criteria for load variations. Changing the 1B EDG surveillance test acceptance criteria altered the intent of the original procedure.

3. TC 1-95-589 of November 11, 1995, revised OP-1-0540020, Boron Recovery System Line-up, Rev. 14. The TC added a new two and one-fourth page long step by step procedure for transferring radioactive borated water from a Unit 1 hold-up tank to a Unit 2 hold-up tank.

Adding a detailed and complex procedure for transferring radioactive water altered the intent of the original procedure.

4. TC 1-95-592 of November 12, 1995, revised AP-1-0010125, Schedule of Periodic Tests, Checks, and Calibrations, Rev. 103. The TC eliminated the requirement for a dedicated auxiliary operator to open the 2B EDG fuel oil transfer manual isolation valve in the event of a Unit 2 reactor trip.

This requirement had been placed in the procedure as a manual action in place of automatic Engineered Safeguards Feature action, to open a manual valve that had been closed because of an underground fuel oil pipe leak. The use of this manual action had been closely reviewed by licensee and NRC management. Deletion of the dedicated auxiliary operator from the procedure altered the intent of the original procedure.

This is a Severity Level IV Violation (Supplement 1).

L-96-91 Attachment 4

FPL RESPONSE:

1. CONCURRENCE AND REASON FOR THE VIOIATION FPL concurs with the violation.

The cause of the violation was that the St. Lucie Plant procedure which provided guidance on evaluating proposed procedural changes as "temporary changes" did not provide sufficient guidance on what would, or would not, constitute "no change in intent." The violation cause is discussed further below.

Back round St. Lucie Units 1 and 2 Technical Specification 6.8.1 state, in part, that:

Written procedures shall be established, implemented and maintained covering the activities referenced below:

a. The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978, and those required for implementing the requirements of NUREG 0737.

Technical SpeciTication 6,8.2 states, in part, that:

Each procedure of Specification 6.8.1a. through i. above, and changes thereto, shall be reviewed by the FRG and shall be approved by the Plant General Manager prior to implementation...

Technical Specification 6.8.3 states:

Temporary changes to procedures of Specification 6.8.1a. through i.

above may be made provided:

a. The intent of the original procedure is not altered.

b. The change is approved by two members of the plant management staff, at least one of whom holds a Senior Reactor Operator's License on the Unit affected.

C. The change is documented, reviewed by the FRG, and approved by the Plant General Manager within 14 days of implementation.

L-96-91 Attachment Technical Specification 6.8.3 was implemented at St. Lucie Plant by A'dministrative Procedure (AP) No. 0010148, "Temporary Changes to Procedures." Revision 2 to AP 0010148, Figure 2, page 2 of 2, states that:

A change of intent to a procedure exists if it:

Changes the purpose of the document.

2. Decreases the margin of safety.

Discussion Regulatory guidance concerning change in intent" has been published in the NRC Inspection Manual. NRC Inspection Manual, Inspection Procedure 42700, Procedures," dated November 15, 1995, states that "...temporary 'Plant procedure changes cannot change the intent of the basic procedure. A "change in intent" means changing what is accomplished by the basic procedure or changing the method by which it is accomplished has safety significance."

St. Lucie Plant procedural requirements in revision 2 to AP 0010148 parallel NRC Inspection Manual guidance on temporary procedures in that: 1) the temporary change could not "change the purpose of the document" (thus paralleling the NRC's guidance that the temporary change "cannot change the intent of the basic procedure."); and, 2) temporary changes to procedures cannot decrease the margin of safety (paralleling the NRC's Inspection Manual guidance related to the safety significance of the change). FPL has concluded that more detailed guidance for what typically would, or would not, constitute .

"no change in intent" for temporary changes to procedures is required.

CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED The examples cited in the Notice of Violation were incorrectly characterized by the two members of plant staff as constituting "no change in intent." The subject procedural changes should have received FRG review and approval by the Plant General Manager prior to implementation, in accordance with Specification 6.8.2. In accordance with Technical Specification 6.8.3, the subject procedure changes received FRG review, and Plant General as follows:

Managel'pproval TC 1-95-569 of October 30, 1995, which revised OP-1-2200050A, 1A EDG Periodic Test and General Operating Instructions, Rev. 22, was reviewed by the FRG and approved by the Plant General Manager on November 1, 1995.

2. TC 1-95-570 of October 30, 1995, which revised OP-1-2200050B, 1B EDG Periodic Test and General Operating Instructions, Rev. 22, was

l L-96-91 Attachment reviewed by the FRG and approved by the Plant General Manager on November 1, 1995.

3. TC 1-95-589 of November 11, 1995, which revised AP-1-0540020, Boron Recovery System Line-up, 'Rev. 14, was reviewed by the FRG and approved by the Plant. General Manager on November 16, 1995.

4. TC 1-95-592 of November 12, 1995, which revised AP-1-0010125, Schedule of Periodic Tests, Checks, and Calibrations, Rev. 103, was reviewed by the FRG and approved by the Plant General Manager on November 12, 1995.

Following review of the temporary changes by the FRG, and approval by the Plant General Manager, the subject procedural changes were properly approved for implementation.

3. CORRECTIVE STEPS TO AVOID FURTHER VIOLATIONS A. A benchmarking study was conducted on how other nuclear sites address temporary procedure change of intent.

B. As a result of the benchmarking study, Administrative Procedure 0010148 "Temporary Changes to Procedures" has been revised to clarify, for the reviewers, what changes and revisions to procedures may be considered as changing the intent of the procedure. With respect to "no change in intent" TCs, AP No. 0010148 now states:

TC CHANGE OF INTENT GUIDELINES AND PRIOR APPROVAL REQUIREMENTS A change of intent to a procedure exists if the answer to ANY question below is YES.

1. Does this change modify or delete a set point?

2. Does this change modify or delete acceptance criteria?

3. Does this change delete QC or HP hold points?

4. Does this change remove a requirement for Independent Verification?

5. Does this change revise the stated purpose of the procedure?

6. Does this change revise the initial conditions that must be satisfied prior to performing the Instruction section of a procedure?

L-96-91 Attachment 0

7. Does this change revise specific actions which result in a less conservative method of performing the task'P 4, Full compliance was achieved by November 16, 1995, upon review of the subject temporary changes by the,FRG and approval by the Plant General Manager.