ML17229A054
| ML17229A054 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 09/19/1996 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Plunkett T FLORIDA POWER & LIGHT CO. |
| Shared Package | |
| ML17229A055 | List: |
| References | |
| NUDOCS 9610030009 | |
| Download: ML17229A054 (8) | |
See also: IR 05000335/1996012
Text
CATEGORY 2
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CCESSION NBR:9610030009
DOC.DATE: 96/09/19
NOTARIZED: NO
ACIL:50-335 St. Lucie Plant, Unit 1, Florida Power
& Light Co.
50-389 St. Lucie Plant, Unit 2, Florida Power
&. Light Co.
AUTH.NAME
AUTHOR AFFILIATION
EBNETER,S.D.
Region
2 (Post
820201)
RECIP.NAME
RECIPIENT AFFILIATION
PLUNKETT,T.F.
Florida Power
& Light CO.
SUBJECT: Forwards insp repts
50-335/96-12
& 50-389/96-12
on 960712
&
notice of violation. Failure to recognize
an unreviewed
safety question related to implementation of valve lineup
change
to
EDG fuel oil transfer
sys.
DISTRIBUTION CODE:
ZEOID
COPIES
RECEIVED:LTR
I
ENCL
[
SIZE: 5 N
TITLE: General
(50 Dkt)-Insp Rept/Notice of Violation Response
NOTES:
DOCKET I
05000335
05000389
RECIPIENT
ID CODE/NAME
PD2-3
INTERNAL: ACRS
ER
NRR/DRPM/PERB
OE DIR
RGN2
FILE
01
EXTERNAL: LITCO BRYCE,J
H
NRC
COPIES
LTTR ENCL
1
1
2
2
1
1
1
1
1
1
1
1
1
'1
1
1
1
1
1
1
RECIPIENT
ID CODE/NAME
WIENS,L.
AEOD/SPD/RAB
DEDRO
NRR/DISP/PIPB
NRR/DRPM/PECB
NUDOCS-ABSTRACT
OGC/HDS3
NOAC
COPIES
LTTR ENCL
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
0
D
0
E
NOTE TO ALL "RIDS" RECIP1ENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS
OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL
DESK
(DCD)
ON EXTENSION 415-2083
TOTAL NUMBER OF COPIES
REQUIRED:
LTTR
19
ENCL
19
Seotemoer
i9.
1996
EA 96-236 and
EA 96-249
Florida Power
& Light Comoany
ATTN:
Hr. T.
F. Piunkett
President
-
Juclear Division
Post Office Box :4000
Juno Beach.
Floriaa
33408-0420
SUBJ. '::
NOTICE
F '/IOLATiON (NRC Special
Tnspection
Repor t Nos.
50 335 and
Dear "ir. P1'unkett:
- his refers to :.".e
nsoection
c.mo!eted
on
uly :".
996. at
- our St
faci',i y
The :nsoection
inc,'uaea
a review of se!ectea
aspects
of youl
confIguration manaaement
ana l0 CFR 50.59 safetv =valuation proarams.
The
result,s of our
- ns"ecticn were sent to you by letter aated Julv 26.
1996.
."',cse
.
reaec.s.c."ai
en orc men. conference:vas
=:nauctea
In the Region II
orfice on Augus-.
.
996.
.vith vou and
memoers cf your staff :o discuss
the
-ooarent vioiat'."ns.
- he ~cot causes.
and your ccrroc.-:ve actions to preclude
r;cir;ence. ,'--=r summariz;.".g
- .".e ccnference
- .as
=-ent .o 'ou by letter
datea
September
.
996.
Based
on the infor~ation developed
during the insoection
and
.he information
you provided dur.."." the conference.
'he
NRC has cetermined that violations of
NRC requirements
occurred.
The violations are cited '
the
nclosed Notice of
= d -",e
';. c
.,s ances
=-.rr"unc;",.a
- .".em are ".escribed 'n
'V
4 A V
~
a
w Il
ws
~
zetai,
n the:.0;=-:::nsoe t.:n
."=- or"..
The violation in Part
I of the Notice involves your failure to recognize
an
i nreviewed safety "uestion related to tt e imoiementation of a valve lineuo
chanae to the Emergency Diesel Generator
(EDG) iuei oil transfer
system.
Specifically.
- n
~iy 1995. the licensee
implemented
a change to the
2B
system to permit closing of a manual isolation va!ve from the Diesel
Fuel
011
Storaae
Tank to the aay tanks in order to minimize fuel oil around leakage
between the two :anvs.
4s part of the chanae.
". e licensee
instituted,
-- ministrative - a=-.res
".,ciuairg =edicat;:cn c- : .".on-:icense
operator
and
proceaural
revisions to assure
timely opening of the valve following an
start.
Although
=- safety evaluation performed to evaluate this change
-"nc..'ded -hat :-= =robaoi'!itv :;
oss of the
""=" emergency
"us
ncreased
y
- ix .-ercent.
- t
=-. 'neousiv concii aea that no increase
in the
rooabi lity of a
"cmporent .aiiur
- .as created.
.n addit;on.
- he
".RC:".as acne:uaed
that
I vo
new --ilure moaes
- .ere .:ntroaucea
by the cnange: ,') ootential .ailure of the
~peratol
to u!il<-.ate t4e -uei oil '-;,ne ana (",'=-ilure cf the manual
96i0030009 9609i9
ADOCK 05000335
8
Florida Power
8 Light Company
-2-
isolation valve to open.
Therefore.
both the possibility for a malfunction of
a type different than any evaluated
previously in the Updated Final Safety
Analysis Report
(UFSAR) was introduced.
and the probability of a failure of a
component
important to safety was increased,
representing
a valid unreviewed
safety question.
At the conference.
you stated that
a safety evaluation
was prepared
for this
change consistent with Florida
Power
and Light Company procedures
and industry
guidance
(NSAC-125).
However.
NRC's position with respect to an "increase in
probability" differs.
Although the
NRC recognizes
in this case that the
increase
in probability of component fai lure was small,
a normally passive
component
was
made active and
an absolute
increase
in probability was
realized.
Notwithstanding the small probability increase.
the violation in
Part I of the Notice is of significant regulatory concern
because
a change
was
made to the
EDG system resulting in the emergence of an unreviewed safety
question for which a license
amendment
and
NRC approval
was not sought.
Further,
such failures to comply with the requirements of 10 CFR 50.59
resulted in facility operations
which depart
from the licensing and or design
bases
described in the
Therefore.
the violation in Part I of the
Notice is classified in accordance with the "General
Statement of Policy and
Procedures
for
NRC Enforcement Actions" (Enforcement Policy),
as
a
Severity Level III violation.
In accordance
with the Enforcement Policy,
a base civil penalty in the amount
of $50,000 is considered for a Severity Level III violation.
Because
your
facility has
been the subject of escalated
enforcement
actions within the last
two years'
the
NRC considered
whether credit was warranted
for
Identification and Corrective Action in accordance
with the civil penalty
assessment
process
described
in Section VI.B.2 of the Enforcement Policy.
In
this case,
the
NRC concluded that it is not appropriate to give credit for
Identification because
the violation was discovered
by the
NRC.
With regard
to consideration for Corrective Action, at the conference
you stated that your
actions related to the violation in Part I of the Notice included revision of
engineering safety evaluation guidance to clarify the definition of an
increase
in probability
and issuance of a technical alert to all engineers
regarding this issue.
Further,
although not directly related.to this
violation, additional
emphasis
has
been placed
on the importance of 10 CFR 50.59 and the
Your recent actions in this regard include:
(1)
10 CFR 50.59 reviewer certification; (2) additional
10 CFR 50.59 training for
designated staff: (3)
10 CFR 50.59 procedural
enhancements;
and (4)
implementation of the
UFSAR Review Project.
Based
on the above.
the
NRC
determined that credit was warranted for Corrective Action. resulting in the
base civil penalty.
A Severity Level III problem and proposed civil penalty of
$50.000 were issued
on
Narch 28.
1996
(EA 96-040) related to a reactor coolant system boron dilution event.
A Severity
Level III violation and proposed civil penalty were issued
on November
13.
1995
(EA 95-180)
related to inoperable
power operated relief valves.
Florida Power
8 Light Company
-3-
As
a result of these considerations,
a civil penalty of $50,000 would normally
be warranted for this Severity Level III violation.
However,
i'n this case,
you did perform
a 50.59 evaluation
and promptly thereafter
communicated with
the
NRC staff and discussed
your plans to reposition the fuel oil transfer
isolation valve,
as well as your preparatory
and compensatory
measures
to
minimize the potential for system failure.
Accordingly. under the
circumstance of this case,
a civil penalty is not warranted.
I have been
authorized,
after consultation with the Director. Office of Enforcement.
and
the Deputy Executive Director for Nuclear Reactor Regulation,
Regional
Operations
and Research,
to exercise
in accordance
with the guidance set forth in Section VII.B.6 of the Enforcement Policy,
and
not propose
a civil penalty in this case.
Violations A and
B described
in Part II of the Notice have been categorized
at
Severity Level
IV.
The violations involve four instances
where you failed to
effectively incorporate design
changes
into plant operating procedures
or
drawings.
These violations were
NRC identified and are of concern
because of
the potential for misleading operators
and the similarity of the violations to
response
procedure deficiencies identified during previous
inspections.
The fifth apparent
example of the configuration management
violation discussed
at the conference
involved your failure to incorporate
roperly the spent fuel pool heat load calculation into operational
procedure
imitations prior to initiating core off-load.
For this issue,
the
NRC has
decided to exercise discretion
and characterize
the violation as non-cited
(NCV 50-335/96-12-01)
in accordance
with Section VII.B.1 of the Enforcement
Policy.
Specifically. you identified the violation and promptly instituted
appropriate corrective action.
NRC has concluded that no violation occurred with respect to the three
additional
apparent fai lures to comply with 10 CFR 50.59 addressed
in the
subject inspection report and discussed
at the conference.
Specifically,
(1) the Unit 2 Control Element Drive Mechanism Control System Enclosure
was
not required to be included in the
~
and installation and subsequent
modifications did not require
10 CFR 50.59 safety evaluations;
(2) the
configuration of a temporary fire pump placed in stand-by during the 1996
Unit 1 refueling outage did not requi re
a
10 CFR 50.59 evaluation in that the
configuration was
as described in the
UFSAR (i.e.
~ the discharge
valve was
closed
and the
pump was isolated
from the system):
and (3) the failure to
perform
a
10 CFR 50.59 safety evaluation to change the setpoints
and
procedures
for operating the fuel hoist was identified and corrected
by you
prior to actual
fuel movement.
This letter closes
any further
NRC action
on
these matters.
You are required to respond to this letter and should follow the instructions
specified in the enclosed
Notice when preparing your response.
In your
response,
you should document the specific actions taken
and any additional
actions you plan to prevent recurrence.
After reviewing your response
to this
Notice, including your proposed corrective actions
and the results of future
inspections.
the
NRC will determine whether further
NRC enforcement
action is
necessary
to ensure
compliance with NRC regulatory requirements.
Florida Power
5 Light Company
4
In accordance
with 10 CFR 2.790 of the NRC's "Rules of Practice,"
a copy of
this letter, its enclosure,
and your
response will be placed in the
NRC Public
Document
Room (PDR).
To the extent possible.
your response
should not include
any personal
privacy, proprietary.
or safeguards
information so that it can be
placed in the
PDR without redaction.
Sincerely.
Docket Nos. 50-335.
50-389
License
Nos.
Enclosure:
cc w/encl:
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
cc w/encl: (Cont'd on Page
5)
J'tewart D. Ebneter
Regional Administrator
Florida Power
II Light Company
cc w/encl (Cont'd):
J.
R.
Newman,
Esq.
Morgan.
Lewis
8 Bockius
1800
M Street.
NW
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
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
Rockvi lie.
20852