ML17229A051
| ML17229A051 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 09/11/1996 |
| From: | Landis K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Plunkett T FLORIDA POWER & LIGHT CO. |
| References | |
| EA-96-236, EA-96-249, NUDOCS 9609270264 | |
| Download: ML17229A051 (52) | |
Text
CATEGORY REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9609270264 DOC.DATE: 96/09/ll NOTARIZED: NO FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power s Light Co.
50-389 St. Lucie Plant, Unit 2, Florida Power
& Light Co.
AUTH.NAME AUTHOR AFFILIATION LANDIS,K.D.
Region 2 (Post 820201)
RECIP.NAME RECIPIENT AFFILIATION PLUNKETT,T.F.
Florida Power
& Light Co.
DOCKET ¹ 05000335 05000389
SUBJECT:
Summarizes predecisional enforcement conference on 960819 in in Atlanta,GA re apparent violations concerning SEs 6 design control requirements. List of conference attendees,NRC presentation handouts a
FPL handouts encl.
DISTRIBUTION CODE:
IE45D COPIES RECEIVED:LTR j ENCL SIZE:
TITLE: Summary of Significant Meeting with Licensee (P rt 50)
NOTES:
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1 1
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1 RECIPIENT ID CODE/NAME WI E CENTjl OGC ROED RGN2 FILE 01 NRC PDR COPIES LTTR ENCL 1
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1 1
1 NOTE
~O ALI >>RIDS" RECIPIENTS:
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CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN 5D-5(EXT. 415-2083)
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LTTR 10 ENCL 10
Sept:ember 11, 1996 EA 96-236 and EA 96-249 Florida Power and Light Company ATTN:
Hr. T. F. Plunkett President
- Nuclear Division P. 0.
Box 14000 Juno
- Beach, FL 33408-0420 SUBJECT'EETING
SUMMARY
- PREDECISIONAL ENFORCEMENT CONFERENCE ST.
LUCIE -
DOCKET NOS 50-335 AND 50-389 Gentlemen:
This refers to the predecisional enforcement conference on August 19,
- 1996, at the Region II office in Atlanta, Georgia.
The purpose of this meeting was to discuss apparent violations of 10 CFR 50.59, relating to safety evaluations, and 10 CFR 50 Appendix 8, Criterion III, relating to design control, requirements.
The meeting was beneficial toward answering the questions provided by our letter dated July 26, 1996.
Enclosed is a List of Conference Attendees, the NRC's presentation
- material, and Florida Power and Light Company's handouts.
The results of the NRC's deliberations regarding the apparent violations, discussed at the predecisional enforcement conference, will be forwarded to you by separate correspondence.
In accordance with Section 2.790 of the NRC's "Rules of Practice, "Part 2, Title 10 Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Room.
Should you have any questions concerning this letter, please contact us.
Sincerely, Orig signed by Kerry D. Landis EA 96-236 and EA 249 Docket Nos.
50-335, 50-389 License Nos.
Enclosures:
1.
List of Attendees 2.
Predecisonal Enforcement Conference Agenda 3.
FPL Presentation Kerry D. Landis, Chief Reactor Projects Branch 3
Division of Reactor Projects 960'9270264 960'Pli PDR ADOCK 05000335 8
PDR OFFICIAL COPY
~C$5
FP&L cc w/encls:
J.
A. Stall, Site Vice President St.
Lucie Nuclear Plant P. 0.
Box 128 Ft. Pierce, FL 34954-0128 H.
N.
- Paduano, Manager Licensing and Special Programs Florida Power and Light Company P. 0.
Box 14000 Juno
- Beach, FL 33408-0420 J. Scarola, Plant General Manager St.
Lucie Nuclear Plant P. 0.
Box 128 Ft. Pierce, FL 34954-0128 E. J.
Weinkam, Plant Licensing Manager St.
Lucie Nuclear Plant P. 0.
Box 128 Ft. Pierce, FL 34954-0218 J.
R,
- Newman, Esq.
- Morgan, Lewis
& Bockius 1800 M Street, NW Washington, D.
C.
20036 John T. Butler, Esq.
- Steel, Hector and Davis 4000 Southeast Financial Center
- Miami, FL 33131-2398 Bill Passetti Office of Radiation Control Department of Health and Rehabilitative Services 1317 Winewood Boulevard Tallahassee, FL 32399-0700 Jack Shreve, Public Counsel Office of the Public Counsel c/o The Florida Legislature 111 West Madison Avenue, Room 812 Tallahassee, FL 32399-1400 Joe Myers, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, FL 32399-2100 cc w/encls:
Continued see page 3
FPKL Thomas R.
L. Kindred County Administrator St.
Lucie County 2300 Virginia Avenue Ft. Pierce, FL 34982 Charles B. Brinkman Washington Nuclear Operations ABB Combustion Engineering, Inc.
12300 Twinbrook Parkway, Suite 3300 Rockville, HD 20852 Distribution w encls:
K. Landis, RII J.
Lieberman, OE LE Wiens, NRR B. Crowley, RII G. Hallstrom, RII PUBLIC NRC Resident Inspector U.S. Nuclear Regulatory Comm.
7585 South Highway A1A Jensen
- Beach, FL 34957-2010 SIGNATURE ELea BU<yo NAME 09 /
.'/ 96 09////96 DATE 09 /
/96 09 /
/96 09 /
/96 YES NO YES NO COPY /
YES NO YES NO YES NO OFFICIAL RECORD COPY OOCUMENT NAME:
G: XSTLUCIE'IMEETINGNSLMETSUM.819 09 /
/96 YES NO
ATTENDEES Licensee T. Plunkett, President, Nuclear Division W. Bohlke, Vice President, Engineering A. Stall, Site Vice President, St.
Lucie J. Holt, Information Services Supervisor E.
- Benken, Licensing Engine'er" NRC
'L. Reyes, Deputy Regional Administrator, Region II (RII)
J.
- Jaudon, Acting Deputy Director, Division of Reactor Projects (DRP), RII A. Gibson, Director, Division of Reactor Safety (DRS), RII B. Uryc, Director, Enforcement and Investigation Coordination Staff (EICS),
RII C. Casto, Chief, Engineering
- Evans, Regional
- Counsel, RII H. Hiller, Senior Resident Inspector, St. Lucie, DRP, RII (Via Phone)
E.
Lea, Project Engineer, Reactor Projects Branch 3, DRP, RII H. Satorus, OE, Hg, (Via Phone)
L. Wiens, Senior Project Hanager, Reactor Projects II/2, NRR J.
York, Reactor Inspector, RII A. Boland, Enforcement Specialist, Enforcement and Investigations Coordination Staff
NRC SPECIAL INSPECTION REPORT NOS. 50-335/96-12, 50-3S9/96-12 PRK-DECISIONALENFORCEMENT CONFERENCE AUGUST 19, 1996 ATLANTA,GA FLORIDAPOWER 4 LIGHTCOMPANY ST. LUCIEPLANT
~
INVESTIGATIONOF PROPOSED 10 CFR50.59 VIOLATIONS CONTROL ELEMENTDRIVEMECHANISMCONTROL SYSTEM ENCLOSURE TEMPORARY FIRE PUMP LOADCELL SETPOINT CHANGE DIESEL FUEL OILSUPPLY VALVE
~
INVESTIGATIONOF CONFIGURATIONMANAGEMENTDEFICIENCIES
~
SUMMARY
~
CLOSING REMARKS
FAILURETO PERFORM A 50.59 SAFETY EVALUATIONFOR CEDMCS ENCLOSURE PRIOR TO OR SUBSEQUENT TO ITS INSTALLATION
~
FABRICATEDPRIOR TO OCTOBER, 1982 CEDM PRE-OP TESTING
~
PLANTLICENSE ISSUED APRIL 6, 1983
~
NON-SAFETY STRUCTURE FOR NON-SAFETY EQUIPMENT
~
EVALUATEDBY ARCHITECT/ENGINEERFOR INTERACTIONS
~
ENCLOSURE HAS NOT BEEN MODIFIEDSINCE FABRICATION
~
CHANGE PREDATES PLANTLICENSE; 50.59 DIDNOT APPLY
~
10 CFR 50.71(e) REQUIRES UFSAR UPDATE TO CAPTURE CHANGES
~
REG. GUIDE 1.70 DEFINES UFSAR FORMATAND CONTENT
~
DESIGNS MUST COMPLY WITHPLANTDESIGN REQUIREMENTS
{e.g., SEISMIC INTERACTION)
L STANDARDFORMATAND CONTENT OF SAFETY ANALYSISREPORTS (Emphasis Added) 9.4.3 Auxiliaryand Radwaste Area Ventilation System 9.4.3.1 Design Bases i
Include requirements for meeting the single-failure criterion, seismic design criteria, requirements for the manual or automatic actuation of system components or isolation dampers, ambient temperature limits, preferred direction of airflowfrom areas oflow potential radioactivity to areas of high potential radioactivity, differential pressures to be maintained and
- measured, requirements for the monitoring of normal and abnormal radiation levels, and requirements for the treatment of exhaust air. Details of the means for protection of system vents or louvers from missiles should be provided.
~
ENCLOSURE INSTALLEDPRE-LICENSE AS A TEMPORARY STRUCTURE
~
ENCLOSURE WAS NEVER MADEINTO A PERMANENT MODIFICATION NOR WERE DRAWINGS UPDATED
~
PERMANENT MODIFICATIONNOT GIVENPRIORITY
~
50.59 EVALUATIONPERFORMED NO UNREVIEWED SAFETY QUESTION
~
MINORMODIFICATiONSMADE
~
DRAWINGS WILLBE UPDATED
~
50.59 EVALUATIONWAS NOT REQUIRED ATTIMEOF INSTALLATION
~
NO OPPORTUNITIES FOR 50.59 EVALUATIONPOST-CONSTRUCTION SINCE NO MODS DONE
~
INCLUSIONIN UFSAR NOT REQUIRED PER REG. GUIDE 1.70
~
CURRENT PROCESSES (e.g., MODIFICATION,TEMPORARY ALTERATION)
WOULD REQUIRE 50.59 CONSIDERATION
~
TEMPORARY ENCLOSURE SHOULD HAVEBEEN MADEPERMANENT
~
ENGINEERING EVALUATIONFOR PAST OPERABILITYAGREED KITH INITIALARCHITECT/ENGINEEREVALUATIONNO IMPACTTO PLANT SAFETY
INSTALLATIONOF A TEMPORARY FIRE PUMP RESULTED IN A CHANGE TO THE PLANTAS DESCRIBED IN THE UFSAR WITHOUTA 50.59
~
UFSAR DRAWINGSHOWS CONNECTION FOR PORTABLE PUMP
~
UFSAR TEXT DESCRIBES TEMPORARY PUMP CONNECTION TO CITYWATER STORAGE TANKDRAINLINE
APPE~NDIX 9.5A, FIRE PROTECTION PROGRAM REPORT EXCERPT FROM SECTION 3.1.1:
"Aflanged connection is provided from the CWST drain line to allow connection to a portable fire pump to assist the fire protection system ifrequired."
(cont'd)
\\
~
TEMPORARY PUMP SUCTION WAS INSTALLEDATLOCATIONNOTED IN UFSAR FIGURE
~
FIRE PROTECTION PLAN (AP 1800022) ALLOWS PUMP OUT OF SERVICE UP TO 37 DAYS
~
PROCEDURE "LCO"INCORPORATES FORMER TECH SPEC LCO (TECH SPEC AMENDMENT115; 6/11/92)
~
FIRE PUMP WAS OUT OF SERVICE FOR 19 DAYS
~
NO COMPENSATORY ACTIONS REQUIRED
~
TEMPORARY PUMP NOT FULLCAPACITY
~
PLANTQUALITYINSTRUCTIONS REQUIRE PROCEDURES FOR FIRE PROTECTION
~
TEMPORARY SYSTEM ALTERATIONPROCEDURE IS TO BE USED FOR INSTALLATIONOF TEMPORARYEQUIPMENT NOT ADDRESSED BY EXISTING PROCEDURES
~
THE ACTIVITYWAS A LONG STANDINGPRACTICE THE TEMPORARY SYSTEM ALTERATIONPROCEDURE WAS NOT USED
~
INSTALLATIONOF TEMPORARY PUMP WAS NOT PROCEDURALIZED
~
ENGINEERING TO DETERMINEMINIMUMFIRE WATER CAPACITY ANDTO PROVIDE EVALUATIONFOR USE OF A TEMPORARY PUMP
~
FIRE PROTECTION TO REVISE ADMINISTRATIVEPROCEDURE BASED ON ENGINEERING INPUT
USE OF THE TEMPORARY PUMP SHOULD HAVEBEEN IMPLEMENTED VIAPLANTPROCEDURE OR TEMPORARY SYSTEM ALTERATION; BOTH REQUIRE A 50.59 SCREEN 50.59 SCREEN WOULD HAVECONCLUDED 50.59 EVALUATIONWAS NOT REQUIRED
~
THE OPERABLE FIRE PUMP WOULDHAVEBEEN CAPABLE OF MITIGATINGA FIRE
FAILURETO PERFORM A 50.59 SAFETY EVALUATIONFOR CHANGE TO SETPOINTS DESCRIBED IN UFSAR
~
TWO PROCEDURES REVISED TO UPDATE OVERLOAD 0, UNDERLOAD SETPOINTS FOR REFUELING AND SPENT FUEL HANDLINGMACHINES
~
ENGINEERING PREPARED EVALUATIONWHICHPROVIDED NEW SETPOINTS IN SUPPORT OF PROCEDURE CHANGES (NO 50.59)
~
UFSAR DESCRIBES INTERLOCKS WITHRESPECT TO LOADVALUES; EXAMPLE:
"...interlock limits the maximum upliftload to ten percent above load."
(cont'd) 4/29/96 5/08/96 5/12/96 EVALUATIONREV. 0 ISSUED EVALUATIONREV. I ISSUED (EDITORIALCHANGES)
PROCEDURE CHANGE SCREENED AS NOT REQUIRING 50.59 PROCEDURES FRG APPROVED WITHOUT50.59 LETTER OF INSTRUCTION SCREENED AS REQUIRING 50.59; EVALUATIONIS REFERENCED ON SCREENING FORM FRG REJECTS LOI Ec EVALUATIONBECAUSE 50.59 MISSING 5/12/96 (1400)
EVALUATIONREV. 2 FRG APPROVED (ADDED 50.59) 5/12/96 (1700)
FUEL MOVEMENTCOMMENCED
~
ENGINEERING QUALITYINSTRUCTIONS REQUIRE 50.59 FOR A "CHANGETO THE FACILITY..."
~
50.59 SCREENING REQUIRES DETERMINATIONIF UFSAR IS AFFECTED
. BY THE CHANGE
~
FUELS ENGINEERS DIDNOT IMPLEMENTPROCEDURAL REQUIREMENTS
~
INDIVIDUALSCREENING PROCEDURE CHANGE FOR 50.59 DID NOT IDENTIFYALLAPPLICABLEUFSAR TEXT
~
TECHNICALALERTISSUED
~
SUPPLEMENTALTRAININGFOR FUELS ENGINEERS
~
REVIEW OF OTHER FUEL GROUP EVALUATIONS-NO FINDINGS
~
50.59 SHOULD HAVEBEEN PROVIDED WITHPROCEDURE CHANGES 2 BARRIERS FAILED-DESIGN 4 PROCEDURE 50.59 SCREENING PROBLEM WAS SELF-IDENTIFIEDPRIOR TO FUEL MOVEMENT
~
NO SAFETY SIGNIFICANCE
~
SETPOINTS WERE TECHNICALLYEVALUATED
~
NO UNREVIEWEDSAFETY QUESTION
~
FUEL MOVEMENTDIDNOT START UNTILAFTER 50.59 ISSUED
REPOSITIONING OF AN EMERGENCY DIESEL GENERATOR FUEL SUPPLY VALVECONSTITUTED AN UNREVIEWEDSAFETY QUESTION UNDERGROUND LEAKBETWEEN THE TRANSFER PUMP AND DIESEL DAYTANKSREQUIRED ACTION
~
EVALUATIONISSUED (7/6/95) TO ALLOWISOLATIONOF THE NORMALLYOPEN FUEL LINETO STOP THE LEAK
~
EVALUATIONREQUIRED COMPENSATORY MEASURES
(cont'd)
~
ADEQUATETIMETO IMPLEMENTMANUALACTION:
DAYTANKCAPACITY= 126 MIN TRANSFER PUMP STARTS AT 40 MIN MANUALACTION REQUIRED WITHIN20 MINBY PROCEDURE
~
EVALUATIONIDENTIFIEDPOTENTIALFAILUREMODES
(cont'd)
~
EVALUATIONWAS PREPARED CONSISTENT WITHFPL PROCEDURES AND NSAC-125 EXCERPT FROM NSAC -125 (Emphasis Added):
Changes that result in a change from one frequency class to a more frequent class are examples of changes that increase the probability ofoccurrence.
However, this is not to say that changes within a category may not result in an increase in the probability of occurrence of an accident ifthere is a clearly discernable increase or trend.
Compensating effects such as changes in administrative controls may be used to offset an increase or trend in the probability of accidents of moderate frequency.
Normally, the determination of a probability increase is based upon a qualitative assessment using engineering evaluations consistent with the original SAR analysis assumptions.
This is not to say that ifa plant specific probability calculation can be used to evaluate a change in a quantitative sense, it should not be used.
However, it should be emphasized that PRAs are just one of the tools for evaluating safety and their use is not needed to perform 10CFR50.59 evaluations.
Licensees should utilize reasonable engineering practices, engineering judgement, and PRA techniques, as appropriate, in determining whether the probability of occurrence of an event increases as a result of implementing a proposed change.
A large body of knowledge has been developed in the area of event frequency and risk significant sequences through plant specific and generic studies.
Licensees should draw on this knowledge where applicable in determining what constitutes an increase in the probability of occurrence of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report.
C h n n
20
(cont'd)
~
USE OF MANUALACTIONWAS CONSISTENT WITHGENERIC LETTER 91-18 (OPERABILITY)
EXCERPT FROM GL 91-18 (Emphasis Added):
6.7 Use of Manual Action in Place of Automatic Action ua a
i
. The physical differences to be considered include, but are not limited to, the ability to recognize input signals for action, ready access to or recognition of setpoints, design nuances that may complicate subsequent manual operation such as auto-reset, repositioning on temperature or pressure, timing required for automatic action, etc., minimum manning requirements, and emergency operation procedures written for the automatic mode of operation.
c
~
~
c The assignment of a dedicated operator for manual action is not acceptable without written procedures and a fullconsideration ofall pertinent differences.
~l
~
0
~
~
e
... Nevertheless, this is expected to be a temporary condition until the automatic action can be promptly corrected in accordance with 10 CFR Part 50, Appendix B, Criterion XVI,Corrective Action.
21
~
EVALUATIONSARE TO BE PREPARED IN ACCORDANCE WITH ENG PROCEDURES AND 50.59 GUIDANCEDOCUMENT
~
GUIDANCEDOCUMENTWAS CONSISTENT WITHNSAC-125 INTERPRETATIONWHICHDIFFERS FROM THE NRC POSITION ON "INCREASE IN PROBABILITY" 22
~
REVISED ENGINEERING'S 50.59 GUIDANCEDOCUMENT EXCERPT:
Note:
Any.* qualitative or quantified increase in probability regardless of magnitude must be considered an increase in probability for the purposes of 10CFR50.59.
However, compensating effects (including compensatory actions) such as changes in administrative controls are acceptable in offsetting uncertainties and increases in the probability of occurrence or consequences of an accident previously evaluated in the SAR or reductions in a margin of safety, provided the potential increases or reductions in margin are negligible.
Additionally, a change that would result in a slight increase in the probability of an initiating event for an accident would not be an increase in probability under 10CFR50.59 provided the probability of occurrence of some other event(s) in the same sequence is concomitantly decreased and there is no adverse effect on other plant-.specific accident sequences.
This statement is in effect pending final resolution of this issue between the NRC and NEI.
Previous guidance in NSAC 125 had stated that small increases in probability that did not demonstrate a trend towards increasing consequences could be considered as not constituting an increase in consequences pursuant to 10CFR50.59.
(cont'd)
~
ISSUED TECH ALERTTO ALLENGINEERS (3/6/96):
TECHNICALALERT-50.59 EVALUATIONS When perl'orming 10CFR50.59 evaluations, any quan(ilicd incrcasc in Ihe probability of occurrcncc of accidents, or any quantified increase in thc probabilityofoccurrence of malfunction ofequipmcnt important to safety, must be considcrcd an unrcvicwed safety question. Additionally, credit for operator action in place ofautomatic action, or credit for operator rcalignmcnt of a system to perform its intcndcd function, when that realignment is not normally required, must reccivc management review.
Asafety evaluation was issued which calculated a small increase in probability ofoccurrcncc of a malfunction ofequipment important to safety using probabalistic safety assessmcnt tcchniqucs.
Credit for operator action was taken to compensate for this increase, although this compensation did not quantitatively climinatc the incrcasc in probability. Thc evaluation concluded that the evaluated condition was permitted by 50.59.
The NRC subsequently questioned this conclusion, and is further rcvicwing the evaluation.
%he Nuclear Engineering Department document "Guidance for Performing 10CFR50.59 Safety Evaluations" includes notes on page 15 which discuss small changes in thc prohahility ofoccurrence ofaccidents. It is not intended that quantified increases in the probability ofoccurrence of accidents, or occurrence ofmalfunction ofequipment important to safety, be allowed under 50.59. Additionally, taking credit for operator action to compensate for incrcascs in thc probability ofoccurrence of accidents, or occurrence ofmalfunction ofcquipmcnt is a dclicatc undertaking. For this reason, credit for operator action in place ofautomatic action, or credit for operator rcalignmcnt ofa system to perform its intended function, when that realignment is not normally required, must receive management review.
hCUQHS Engineering personnel involved in Ihc review of plant and procedure changes must consider quantified increases in accident occurrcncc probability, or equipment important to safety malfunction probability, an unrcvicwcd safety question for which prior NRC approval is required.
'nic Nuclear Enginccring Department document "Guidance for Performing 10CFR50.59 Safety Evaluations" willbe revised in thc 2nd quarter of 1996 to further address the topic of this Technical Alert.
"Guidance for Performing 10CFR50.59 Safety Evaluations," Rcv. 0, 10/89 24
~
CURRENT NRC INTERPRETATIONANDINDUSTRYGUIDANCEDIFFER ON THIS ISSUE
~
NO SAFETY SIGNIFICANCE
~
CORE DAMAGEFREQUENCY CHANGE (3%
~
CONSIDERABLETIMEAVAILABLEFOR OPERATOR ACTION 25
SUMMER
~
NO PROGRAMMATIC50.59 BREAKDOWN:
CEDMCS ENCLOSURE
- PRIOR TO LICENSE TEMPORARY FIRE PUMP - FAILURETO FOLLOW PROCEDURES WHICH WOULDHAVEREQUIRED 50.59 SCREENING (WOULD SCREEN OUT)
LOADCELL SETPOINTS
- 50.59 SHOULD HAVEBEEN WRITTEN; SELF IDENTIFIED DG FUEL SUPPLY VALVE-EVALUATIONDONE IN ACCORDANCE WITH PROCEDURES ANDINDUSTRY GUIDANCE 26
(cont'd)
~
EMPHASIS HAS BEEN PLACED ON THE IMPORTANCE OF 50.59 AND THE UFSAR:
50.59 REVIEWER CERTIFICATIONESTABLISHED 50.59 TRAININGOF STAs COMPLETED DURING REQUAL FORMALIZINGTRAININGMODULETO QUALIFY50.59 SCREENERS IMPROVED 50.59 SCREENING REQUIREMENTS FOR PROCEDURES QI 5-1, [PLANTPROCEDURES j AP 0010124, TEMPORARY SYSTEM ALTERATIONS AP 0010148, TEMPORARY CHANGES TO PROCEDURES ALL50.59 EVALUATIONSMUST BE PREPARED BY ENGINEERING REVISION TO 50.59 GUIDANCEDOCUMENT TRAININGOF FUELS PERSONNEL TECHNICALALERTISSUED TO FUELS PERSONNEL UFSAR REVIEW PROJECT
~
NO SAFETY SIGNIFICANCE 27
FIVE EXAMPLES OF CONFIGURATIONCONTROL ISSUES INVOLVEA FAILURETO UPDATE DRAWINGS ANDPROCEDURES 3 ANNUNCIATORRESPONSE
SUMMARY
ERRORS
~
1 ERROR RELOAD MODIFICATIONPRE-IMPLEMENTATION REQUIREMENTS
~
1 DRAWINGUPDATE ERROR 28
(cont'd)
THREE ERRORS IN ANNUNCIATORRESPONSE PROCEDURE (UNIT2) 1.
PROCEDURE NOT REVISED TO REFLECT NEW SETPOINT VALUE HYDRAZINETANKLOW LEVELALARM (CONTAINMENTSPRAY)
MOD CHANGED SETPOINT FROM 35.5" TO 36.7" TO GAINMARGIN TO TECH SPEC LIMIT PROCEDURE ERROR IS IN CONSERVATIVEDIRECTION 2.
PROCEDURE NOT REVISED TO DELETE OPERATOR ACTION INTAKECOOLING WATERPUMPS'UBE WATER SYSTEM MODIFICATION MOD ELIMINATEDNEED FOR CERTAIN OPERATOR ACTIONS 29
(cont'd) 3.
PROCEDURE NOT REVISED TO REFI.ECT ANNUNCIATORDELETION MOD DELETED ATMOSPHERIC DUMP VALVE"MANUAL" INDICATION(INDICATES"MANUAL"CONTROL)
RELAYCONTACTS REMOVED BYMOD - ANNUNCIATORWOULD NOT ALARM NOT AN OPERATIONALPROBLEM 30
(cont'd)
RELOAD MODIFICATIONPRE-IMPLEMENTATIONERROR
~
MOD FOR FULLCORE OFF-LOAD / FUEL RELOAD
~
MOD PACKAGE CONTAINEDPREREQUISITES TO BE IMPLEMENTED PRIOR TO FULLCORE OFF-LOAD
~
PLANT PROCEDURE WAS NOT REVISED TO INCLUDEPREREQUISITES
~
OFF-LOAD COMMENCEDWITHOUTVERIFYINGPREREQUISITES
~
ERROR SUBSEQUENTLY IDENTIFIEDBY QUALITYASSURANCE
~
CORE OFF-LOAD STOPPED UNTILPROCEDURE CHANGED (7 ASSEMBLIES MOVED)
(cont'd)
DRAWINGUPDATE ERROR MOD REMOVED LUBEWATER VALVESANDPIPING FOR INTAKE COOLING WATER SYSTEM
~
DRAWINGWAS NOT REVISED TO REFI.ECT DELETIONS 32
(cont'd)
~
EXAMPLES SPAN THE TIMEPERIOD FROM 1992 1996
~
CONFIG CONTROL PROCESS RELIED ON PERSONNEL STRENGTHS-NOT RIGOROUSLY PROCEDURALIZED
~
THE LARGE NUMBER OF MODIFICATIONPACKAGES CHALLENGED THE PROCESS ANDRESULTED IN A LARGE "OPEN ITEMS"LIST
~
PERIOD OF GREATEST VULNERABILITYBEGAN AUGUST 1995
~
DESIGN CHANGES MUST BE ACCURATELYTRANSLATEDINTO PROCEDURES ANDDRAWINGS 33
~
CONFIG CONTROL PROCESS RELIED TOO HEAVILYON INDIVIDUALS INSTEAD OF PROCESS
~
CONFIG CONTROL PROCESS OVERWHELMEDBYLARGE NUMBER OF MODIFICATIONPACKAGES
~
SYSTEMS WERE RETURNED TO SERVICE PRIOR TO ALLREQUIRED CONFIG MANAGEMENTCHANGES BEING IMPLEMENTED 34
~
QI 3PR/PSL-I "DESIGN CONTROL" WAS REVISED TO ENSURE THAT SYSTEMS ARE NOT RETURNED TO SERVICE UNTILREQUIRED DOCUMENTATIONIS UPDATED
~
THE PROCESS FOR MODIFICATIONCLOSE OUT WAS FORMALIZED ANDMANAGEMENTEXPECTATIONS EMPHASIZED
~
THE NUMBER OF MODIFICATIONSPROCESSED IS BEING REDUCED BY IMPLEMENTATIONOF TOP 20/30 LIST
~
MODIFICATIONRELATED OPEN ITEMS AFFECTING PLANT OPERATIONS OF SAFETY SYSTEMS HAVEBEEN CLOSED
(cont'd)
REVIEWS CONDUCTED FOR THE PERIOD OF GREATEST PROCESS VULNERABILITY(AUGUST 1995 TO MAY1996)
~
VERTICALSLICE OF PSA RISK SIGNIFICANTSYSTEMS (HIGH PRESS.
INJECTION, EMERGENCY POWER & COMPONENT COOLING WATER)
WAS CONDUCTED TO VALIDATESIGNIFICANTFLOW DIAGRAMSAND PROCEDURE REQUIREMENTS
~
SUMMARY
UPGRADE
~
ASSIGNED A DEDICATEDSUPERVISOR AND STAFF TO MODIFICATION CLOSEOUT PROCESS
~
STANDARDIZINGUP-FRONT MODIFICATIONREVIEW PROCESS TO EXPLICITLYIDENTIFYAFFECTED PROCEDURES
~
SYSTEM ENGINEERS WILLHAVEOWNERSHIP OF CONFIGURATION
FOR lNFORMhTION0 Y
Oes V~~~l-4~
lb@ document is eA ootitraied. Before uee very Inkx1netion~ h con~ed doaxnent.
Ql 3-PR/PSL-1 Revision 40 May, 1996 Page 1 of 38 FLORIDA POWER 6 LIGHTCOMPANY NUCLEAR ENERGY DEPARTMENT ST. LUCIE PLANT
1.0 APPROVAL
DESIGN CONTROL Reviewed by Plant Nuclear Safety Committee Approved by K. N. Hams Plant General Manager 7/25 1974 7/31 1974 Revision 40 Reviewed by F R G Approved by J. Scarola
2.0 PURPOSE
Phnt General Manager 5/16 1996 5/16 19~6 2.1 Provide control of plant changes and modifications ensuring phnt structures, systems and components are installed and maintained in accordance with applicable design specifications and documerrts.
2.2 Ensure plant changes and modifications comply with:
1.
10 CFR 50.59 Domestic Licensing of Production and Utilization Facilities-Changes, Tests and Experiments.
2.
SQM 3.0 Design Control S
OPS DATE DOCT PROCEDURE DOCN OI-3-1 sYs COMP COMPLETED rTM 40
Ql ~R/PSL-1 Revision 40 May, 1996 Page 35 of 38 ATTACHMENT4 SYSTEM ACCEPTANCE/TURNOVER HEET (Page 1 of 2)
PC/M No.
Revision Supplement Unit(s): Q 1
Cl 2 Cl Conxnon SATS: 0 Par5aI Cl Complete Tine:
Page 1 of Implemented by:
Discipline:
Cl EI ctncaI Cl Mechanicai Cl lac Cl Mtunt. Protects Cl Sy. Protection Cl Other Cl Mode Deferred Testing is required in Mode Cl This SATS is a partial turnover.
Work remaining includes the following:
PC/M COORDINATORS:
Allprocedures for my dep;utment which are required for turnover are complete and/or procedure changes for my department which are not reqtIred for turnover are Dsted below.
YES N/A DATE:
Cl Cl Security:
Cl Cl Chemurgy; Cl Cl.
F~ Pmtecborc Cl Cl Heath physcs.
Cl Cl Rant Maintenance:
D Cl Emergency Preparedness:
PROCEDURE NO.
DATE REQUIRED CR OR PMAI NO.
SYSTEM ENGINEER OR OPS SUPPORT TESTING:
System functional testing has been sa5sfactorly completed and aII test documents used have been transmitted to CM. (N/A iftest has been mode deferred for this SATS).
The updated PODs for which the SATS is being issued adequately support the design change.
Q Q
All Department procedures required for turnover are compiete and/or SCE Department procedures not required for turnover are listed above.
System Engineer or OST:
Date:~
Page 7 of 59 ST. LUCIE PLANT ADMINISTRATIVEPROCEDURE NO. 0005745, REVISION 13 REQUEST FOR ENGINEERING ASSISTANCE REA
3.0 SCOPE
(continued) 3 4 (continued) 25, Sponsoring Department Head - the sponsoring department head is the manager or supervisor of the department in which the sponsor works.
26.
Top 20 Prioritized Plant MODs List - list of modifications approved by the MRB for work during upcoming refueling outages.
There willbe a Top 20 List for each unit. Any Top 20 modification which is not implemented within one refueling cycle will be canceled and deleted from the list unless determined othenvise by MRB.
27.
Top 30 Prioritized Plant MODs List - list of modifications approved by the MRB for work during nonwutage or Short Notice Outage (SNO). Any Top 30 modification which is not implemented within 52 weeks will be canceled and deleted from the list unless determined otherwise by MRB.
4.0 PRECAUTIONS & LIMITS:
4.1 All applicable sections and portions of the REA form should be filled out as per this procedure in order to insure proper evaluation and subsequent action.
5.0 RESPONSIBILITIES
5.1 Services Manager Responsible for REA program.
2.
If REA is considered a Minor Modification, authorizes the following types of REAs for implementation, without obtaining MRB review and approval:
A.
RTS REAs for Minor Modifications B.
Fast Track REAs C.
Document changes and other issues not dispositioned as major or outage modifications.
PCM OPEN ITEMLOOKBACK Rcviewed DB ill PCM Data Base Identified PCM Shown Active Oi'/OpenItems Reviewed And Processed PCMs Which Had Been Itnplcmented Si~ August 95 Prepared List OfPotential Discrepancies Initiated Open item Review / Closeout For PCMs Rcviscd Processed Procedure Changes As IdentiTied / Submitted Reconciled DMS With DB III Data Base Submitted Closed PCMs To Vault Updated PCM Open Item Piles Begin Review OfARPa 40
VERTICALSLICE REVIEW - FINDINGS SOME SETPOINTS WERE FOUND TO BE INCONSISTENT BETWEEN TEDB ANDTHE ANNUNCIATOR
SUMMARY
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SEVERAL SETPOINT VALUES ANDINSTRUMENTRANGES LISTED IN THE FSAR APPEAR TO BE INCONSISTENT WITHOTHER PLANT DRAWINGS
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INA FEW EXAMPLES, THE TOTALEQUIPMENT DATABASE (TEDB)
WAS NOT UPDATED OR EQUIPMENT REMOVED AS NOTED BYTHE CHANGE PACKAGE
VERTICALSLICE REVIEW - FINDINGS (cont'd)
FLOW DIAGRAMSDO NOT REFLECT CURRENT VALVELOCKING PRACTICES DEPICTED IN OPERATING PROCEDURES. VALVELOCKING ANDEQUIPMENT TAGGING OF INSTRUMENTISOLATIONVALVESIS NOT CONSISTENT WITHTHE FLOW DIAGRAMS
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LINEANDVALVEORDER/TAKEOFF POINTS ON THE FLOW DIAGRAMS ARE SOMETIMES INCONSISTENT WITHTHE FIELD
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NO ITEMS OF SAFETY SIGNIFICANCEWERE NOTED AND CONDITION REPORTS WERE GENERATED FOR CORRECTIVE ACTIONANDFURTHER REVIEW 42
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. =1000 CONTROL ROOM ANNUNCIATORSPER UNIT
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NEW FORMAT
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SETPOINT VERIFICATION
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REVIEW OF OPERATOR ACTIONS FOR CONSISTENCY
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UPGRADED REFERENCES COMPLETED =10% OF CONTROL ROOM ANNUNCIATORS (PENDING FINALREVIEW)
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UPDATE ANNUNCIATORRESPONSE
SUMMARY
AS REQUIRED; NOT QUARTERLY 43
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THE SYSTEM ENGINEER WILL:
HAVEOWNERSHIP OF THE SYSTEM
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UNDERSTAND SYSTEM OPERATION
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CONDUCT INITIALANDSUBSEQUENT SYSTEM WALKDOWNS
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ENSURE AGREEMENT WITHPLANTDRAWINGS
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ENSURE AGREEMENT WITHPLANTPROCEDURES
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ENSURE AGREEMENT WITHTHE UFSAR
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BE COGNIZANTOF ALLMODIFICATIONS 45
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CONFIGURATIONCONTROL PROCESS REQUIRED ENHANCEMENTS IN ORDER TO MEET MANAGEMENTEXPECTATIONS
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NO SAFETY SIGNIFICANTITEMS HAVEBEEN IDENTIFIEDIN THE REVIEWS CONDUCTED TO DATE
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PROCESS HAS BEEN STRENGTHENED ANDMORE FORMALIZED
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BASED UPON LOOK BACKREVIEWS, NO SAFETY SIGNIFICANTITEMS HAVEBEEN IDENTIFIED 47