ML17229A132

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Insp Repts 50-335/96-15 & 50-389/96-15 on 960907-1012. Violations Noted.Major Areas Inspected:Operations, Engineering,Maintenance & Plant Support
ML17229A132
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 10/12/1996
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML17229A130 List:
References
50-335-96-15, 50-389-96-15, NUDOCS 9611150333
Download: ML17229A132 (23)


See also: IR 05000335/1996015

Text

o

U.S.

NUCLEAR REGULATORY COHHISSION

REGION II

Docket Nos: 50-335,

50-389

License

Nos:

DPR-67,

NPF-16

Report

No:

50-335/96-15,

50-389/96-15

Licensee:

Florida Power

8 Light Co.

Facility:

St. Lucie Nuclear Plant.

Units

1

8

2

Location:

9250 West Flagler Street

Hiami,

FL 33102

Dates:

September

7 - October 12,

1996

Inspectors:

H. Hiller, Senior Resident

Inspector

J.

Hunday,

Resident

Inspector

D. Lanyi, Resident

Inspector

G. Hopper,

Reactor

Inspector,

paragraphs

01.2,

05. 1.

R1. 2

Approved by:

K. Landis, Chief, Reactor Projects

Branch

3

Division of Reactor Projects

96iii50333 96ii06

PDR

ADQCK 05000335

6

PDR

EXECUTIVE SUMMARY

St. Lucie Nuclear Plant, Units

1

8

2

NRC Inspection Report 50-335/96-15,

50-389/96-15

This integrated

inspection included aspects of'icensee

operations,

engineer-

ing, maintenance,

and plant support.

The report covers

a 5-week period of

resident inspection.

~oerati ons

~

Control

room watchstanding

practices

were satisfactory.

Watchstanders

maintained

a professional

envi ronment

and were attentive to plant

parameters

and conditions

(paragraph 01.2).

~

Equipment areas

were generally clean,

valves were properly positioned

and labelled.

and support equipment

was acceptable

(paragraph

02. 1).

~

Emergency Diesel Generator surveillance testing

was accomplished

satisfactorily.

Additionally, the inspector

found the use of Real

Time

Training Coaches

indicated innovative and proactive Training Department

involvement in plant activities.

The use of a post-evolution debrief of

operators

was viewed as

an excellent practice for operational

improvement

(paragraph

04. 1).

A failure to adequately

ensure that required reading

was performed

by

operators

was identified.

The corrective actions taken were

satisfactory

(paragraph

05. 1).

~

A major site reorganization

was implemented which aligned all site

engineering functions under the licensee's

Engineering organization

(paragraph

06).

~

Poor labeling led to a failure to bypass the correct Engineering Safety

Features

steam generator

water level channel after the channel

had been

declared

inoperable,

leading to a failure to satisfy Technical

Specifications

(paragraph

08. 1).

Maintenance

~

The licensee

has

made progress

in the identification and reduction of

maintenance

backlogs

as

a result of improved scheduling,

management

attention,

and the use of the minor maintenance

process.

Work It Now

(WIN) team activities were reviewed

and were found to be appropriately

defined.

Work Request cancellations

reviewed during the period were

found to have been performed appropriately

(paragraph

M3. 1).

~

Quality Control effectively identified weaknesses

in the Measuring

and

Test Equipment

(M&TE) program.

Once the problems were identified,

corrective actions were implemented

(paragraph

M7.1).

2

~

The

NRC identified

a violation of %TE program requirements

involving a

meter which had not been

logged against

a work activity for which it had

been

employed

(paragraph

M8. 1).

En ineerin

~

An inspection of'he Unit 1 containment airborne radiation monitor

indicated

a general

lack of design basis

documentation for this system.

In addition, five examples of failure to update the Updated Final Safety

Analysis Report were identified (paragraph

E3. 1).

Plant

Su

ort

An event,

involving a mispositioned valve that rendered

the Unit 1

containment

ai rborne radiation monitor inoperable,

occurred during the

inspection period.

The event

was the result of an individual who did

not have

a procedure in hand

and follow it as required,

and

a violation

resulted.

This is

a repeat violation (paragraph

Rl. 1).

A review of the controls applied to the release of oily wastewater

from

the Radiation Controlled Area was performed

(paragraph

R1.2).

An Unresolved

Item, involving a failure to properly secure the Unit 1

Post Accident Sampling System following a test.

was closed

(paragraph

R8.1).

Protected

area barriers were found to be in good condition, the

isolation zones well lit. and the appropriate

compensatory

guard

postings in place (paragr aph S2).

Summar

of Plant Status

Re ort Details

Unit 1 entered the inspection period at approximately

60 percent

power due to

the removal of the

1B main transformer

from service.

On September

14, the

unit was taken to Node 2 to allow for the reconnection of the

1B main

transformer.

On September

15, the unit was placed

on line and the unit

remained at reduced

power due to secondary

chemistry concerns

unti 1 September

16,

when full power conditions were achieved.

The unit then remained at

essentially full power for the balance of the period.

Unit 2 e'ntered the inspection period at 100 percent

power.

On September

23,

the unit was downpowered to approximately

85 percent for turbine valve testing

and waterbox inspections.

The unit returned to full power on September

25 and

remained at es'sentially full power for the balance of the inspection period.

I. 0 erations

01

Conduct of Operations

01.1

General

Comments

71707

Using Inspection

Procedure

71707, the inspectors

conducted

frequent

reviews of ongoing plant operations.

In general,

the conduct of opera-

tions was professional

and safety-conscious;

specific events

and

noteworthy observations

are detailed in the sections

below.

While touring the Unit 2 control

room on October

1, the inspector

noted

that the

2B High Pressure

Safety Injection (HPSI)

pump discharge

pressure

was indicating approximately

880 psig.

The inspector

questioned

control

room operators

on the indication and found that no

operator could explain the indication.

Upon reviewing strip chart

recorder output and control

room logs, the inspector determined that the

pressure

indication was the result of a

2B HPSI

pump run made

a week

prior to the observation

(pressure

trapped

between

check valves).

The

inspector

concluded that the lack of operator

knowledge of the source of

the pressure

indicated

poor attention to detail during board walkdowns

and

a lack of sensitivity to the potential

for intersystem

Loss of

Coolant Accident

(LOCA).

01. 2

Control

Room Observati on

71715

Inspection

Scope

The inspector monitored control

room and plant activities during the

week of September

9,

1996.

Particular attention

was given to special

or

non-routine evolutions in progress,

communications

and procedural

compliance.

Observations

and Findings

The inspector

noted that the control

room environments

for both units

were quiet and professional.

The operators

conformed to the

02

02.1

requirements

of the Conduct -of Operations

procedure.

Operators

were

attentive to plant parameters

and conditions

and followed procedures

as

required

by p'tant policy.

Communications

between

crew members

were also

satisfactory.

The inspector

noted that one licensed Senior Reactor

Operator

(SRO)

was di recting

and supervising the operation of Unit 2 as

the Assistant

Nuclear Plant Supervisor

(ANPS) trainee.

Another

SRO was

the actual

watchstander

noted

on the logs.

When this

SRO was out of the

control

room, the trainee

was in charge.

The inspector noted that the

chronological

logs for the shift did not indicate that the trainee

had

held the

command

and control function.

While this did not violate any

log keeping requi rements,

the practice

does not emphasize

the need for

accountability.

The licensee

took immediate corrective action

and

issued

a bulletin in the night orders to correct the discrepancy.

The inspector also observed administrative practices while in the

control

room and was concerned that

some unnecessary

administrative

burden

may detract

from the control

room supervisors ability to monitor

plant operations.

In the past large numbers of procedure

Temporary

Changes

(TCs)

had been processed

through the control

rooms via the

Nuclear

Plant Supervisor

(NPS).

The inspector

reviewed the

TC process

and found one

TC to an

I&C maintenance

procedure which contained

steps

that were technically incorrect.

The TC was prepared

and marked

as

a

"Procedural

Improvement" rather than "Technically Incorrect."

Upon

close scrutiny, the inspector determined that the procedural

errors were

quite obvious.

These errors could have been discovered

and corrected

prior to issuance of the procedure rather than relying on the control

room staff to review and approve

changes

resulting from on-the-job

validation.

While the licensee's

administrative procedures

allow the

use of TCs to effect procedural

changes

under

some conditions without

the Facility Review Group's

(FRG) prior approval,

the control

room

supervisors

primary function is to monitor and supervise

the safe

operation of the

plant.'onclusion

Control

room watchstanding

practices

were satisfactory.

Watchstanders

maintained

a professional

environment

and were attentive to plant

parameters

and conditions.

Operational

Status of Facilities and Equipment

En ineered Safet

Feature

S stem Walkdowns

71707

Inspection

Scope

The inspector performed

a walkdown of the accessible

portions of the

Unit 1 and

2 Component Cooling Water

(CCW) systems

and the Unit 1 Low

Pressure

Safety Injection (LPSI) system.

,

04

04.1

Findings

In performing these

walkdowns, the inspector verified the proper

installation of hangers

and supports;

the adequacy of housekeeping;

correct valve positions

and conditions;

proper labelling;

and expected

instrument indications.

A step ladder was identified in the

1A LPSI

pump room.

A tag was affixed which stated that the ladder

had been put

in place

on June

6,

1996, to facilitate an inspection of a welded joint.

The licensee

was informed and

removed the ladder

from the area.

The following drawing discrepancies

were noted:

(1)

8770-G-083,

Sheet

1, Revision 44,

"Flow Diagram Component Cooling

System" (Unit 1) indicated the following instruments

were

installed:

PX 14-1A,

PX 14-2A,

TE 14-1A,

PX 14-1B,

PX 14-2B,

and

TE 14-1B.

The instruments

were not installed

as depicted

on the

drawing.

(2)

2998-G-083,

Sheet

1, Revision 32.

"Flow Diagram Component Cooling

System" (Unit 2) did not indicate that valves

SB14169

and SB14439

were to be

LOCKED CLOSED.

The valves were in fact

LOCKED CLOSED

in accordance

with Administrative Procedure

2-0010123,

Revision

75, "Administrative Control of Vales,

Locks and Switches."

The licensee

was informed and initiated Plant Management Action Item

(PMAI) 96-10182 to investigate

and correct

as necessary.

Conclusions

The inspector

concluded that the equipment

areas

were generally clean,

valves were properly positioned

and labelled,

and support equipment

was

acceptable.

The licensee

took the appropriate action with regard to the

step ladder once identified.

Operator

Knowledge and Performance

2A Emer enc

Diesel Generator

Surveillance Testin

61726

Scope

The inspector

observed portions of a surveillance test of the

2A

Emergency Diesel Generator

(EDG) conducted

on October 9.

Findings

The inspector noted that operators

were performing their activities in

accordance

with Procedure

OP 2-2200050A,

Revision 24,

"2A Emergency

Diesel Generator

Periodic Test

and General

Operating Instructions."

During the surveillance,

the inspector

noted that

EDG cooling water

expansion

tank level indicated high.(above the upper mark on

a sight

glass).

The inspector also noted

a placard which stated that the level

should

be between the upper

and lower marks during hot and cold, running

05

05.1

and idle conditions.

The inspector

questioned

the licensee

as to the

applicability of the placard

and was informed that the placard

was in

error and that it would be removed

and replaced with a correct placard

which allowed for expansion of EDG coolant.

The inspector

also noted that

a Real

Time Training Coach

(RTTC) was

covering the activity.

The

RTTC was

a relatively new development in the

training area in which instructors

are assigned to the field to observe

and coach personnel

in maintenance,

engineering

and operations.

The

inspector discussed

the program with the

RTTC and found the practice

innovative and proactive

on the part of the Training Department.

Following the surveillance,

the. inspector witnessed

a post-evolution

debriefing of the operators

involved.

The activity was facilitated by

the

ANPS and was attended

by the

RTTC.

The activity solicited comments

from operators

on how the activity could be improved,

and resulted in

several

positive contributions

from the Non-Licensed Operators

(NLOs)

performing the evolution.

The inspector

found this practice to be an

excellent

method for continuous

improvement of Operations'ractices.

Conclusion

The inspector concluded that the subject surveillance test

had been

accomplished satisfactori ly.

Additionally, the inspector

found the use

of RTTCs to be innovative and proactive Training involvement in plant

activities.

The use of post-evolution debriefings

was viewed as

an

excellent practice for operational

improvement.

Operator

Training and Qualification

Tr ainin

Bulletins

71001

Inspection

Scope

The inspector

reviewed the Training Bulletins (TBs) that were in the

control

room during the control

room observations.

The TBs constitute

part of the on-shift training requirements

of the licensed operator

requalification program.

b.

Observations

and Findings

The inspector

found three

TBs which had not been

reviewed by all

operators

by the required

due dates.

One TB.

"Standdown

Package

for

Temporary Changes,"

was due to be completed

by July 5,

1996.

Another TB

containing Revision

71 to the "Conduct of Operations

Procedure"

had

a

due date of July 6,

1995.

This TB had been signed off as having been

reviewed by an operator

as late as September

12,

1996.

The procedure

contained in the TB had been revised

14 times since the issuance of the

TB.

Yet another

TB on the

"Work It Now Program"

had

a due date of

August 5.

1995,

and had been

reviewed

by an operator

as late as

September

10,

1996.

These

TBs contained outdated material that could be

mistaken for current guidance.

Procedure

AP 0005720,

"Licensed Operator

06

Requalification Program," required that each

NPS/ANPS ensures

that each

member of the crew reviews

TBs and completes

any other on-shift training

requirements

including the necessary

documentation.

It further states

that each licensed operator

understands

the content of on-shift training

and associated

documents

and properly documents

the training.

St. Lucie

Training Department Guideline

No. TG-005,

"Processing

and Distribution

of Training Bulletins," contains specific requirements

for monitoring

all outstanding

TBs.

Specifically, bulletins found to be incomplete

will be monitored

and every 15 days past the requested

review completion

date,

the Training Section Supervisor will be notified of the

delinquency.

The inspector

concluded that the requirements

and intent

of these

procedures

had not been

met and was concerned that important

emergent training information was not being assimi lated by the

operators.

The inspector

noted that the licensee identified the non-

compliance regarding the TBs in Condition Report 96-618 dated

May 2,

1996.

The licensee

also instituted

a

RTTC Program in August which is

described

in Procedure

QI 1-PR/PSL-10,

"Training Organization."

This

program in part provides real time on-shift training on the most

important issues

such

as industry/in-house

events.

The licensee also

revised

Procedure

0005720

(Revision 40).

This procedure

now contains

new requi rements

concerning

TBs and invokes

a policy of removing an

operator's

access

authorization for fai lure to complete the requi red

reading

by a specified date.

In addition, all old TBs were removed from

the control

room.

Conclusion

The inspector

determined that the licensee

had not complied with the

requirements

of procedures

0005720

and TG-005, constituting

a violation

of Technical Specification 6.8. l.a.

The corrective actions taken were

satisfactory.

The inspector determined that the implementation of a

RTTC Program was

an effective tool to rapidly disseminate

important

training information to the operators.

This licensee-identified

and

corrected violation was treated

as

a Non-cited Violation, consistent

with Section VII.B.1 of the

NRC Enforcement Policy and was identified as

NCV 335,389/96-15-01,

"Failure to Implement Training Bulletins in

Accordance with Requalification

Program Procedure."

Operations

Organization

and Administration (71707)

On September

10, the licensee

implemented

a major site reorganization.

Notable in the reorganization

were the placement of all site engineering

organizations

under the Site Engineering

Hanager

(who reports directly

to the Vice President.

Engineering,

in Juno Beach).

Included in this

group were Reactor Engineering, Shift Technical Advisors (STAs),

Systems

Engineering,

and System

Performance

Engineering

(responsible

for ISI and

IST).

Reporting to A. Stall, Site Vice President

are:

~

J. Scarola,

Plant General

Hanager

~

D. Fadden,

Services

Hanger

~

E. Weinkam, Licensing Hanager

08

08.1

~

G. Boissy, Materials Manager

~

R. Heroux,

Business

Systems

Manager

~

R. Sipos,

Steam Generator

Replacement

Project Manager

Reporting to the Plant General

Manager are:

~

J.

Marchese,

Maintenance

Manager

~

H. Johnson,

Operations

Manager

~

C.

Wood, Acting Work Control Manager

Reporting to the

D. Denver, Site Engineering

Manager,

are:

~'.

Church, Administrative Supervisor

~

R.

Gi 1, Plant Engineering

Manager

~

J. Fulford, Operations

Support Engineering Supervisor

~

K. Nohindroo, Project

Engineer/FSAR

~

H. Snyder,

Project Engineer/Maintenance

Rule

~

J.

West,

System Engineering

Manager

Included in this reorganization

was the augmentation of the System

Engineering

and Plant Engineering organizations,

accomplished

through

transferral of staff from Juno Beach.

The inspector

noted that the licensee

had reviewed

and updated plant

Quality Instructions

(QIs) to reflect the new organization

and to

specify organizational

responsibilities

under

the new organization.

A

training bulletin was developed highlighting the changes.

The inspector

concluded that the licensee

had appropriately

implemented the changes

made during this reorganization.

Miscellaneous

Operations

Issues

Inadvertent

B

assin

of the Wron

Unit 1

En ineerin

Safe uards

Features

Actuation

S stem

ESFAS

Si nal

71707

Scope

On September

18,

1996, the licensee

received indications of a bistable

problem associated

with ESFAS cabinet

channel

"D".

Investigation

identified that the "B" Steam Generator

(SG) Pressure

Main Steam

Isolation Signal

(NSIS) in that channel

had failed.

Operations

personnel

determined that the failed bistable could be bypassed

in

accordance

with the Unit

1 technical specifications.

However

.

Operations

personnel

mistakenly bypassed

the channel

"D" "A" SG Pressure

NSIS.

This condition was discovered

by Maintenance

personnel

approximately 11.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after the mistake occurred.

Findings

Once identified, the licensee

realigned the system appropriately.

The

Operating

crew associated

with the event conducted

a crew self

assessment

to identify strengths

and weaknesses

which led to the event.

The assessment

identified that poor labelling of the bypass

switches

and

keys

and

a lack of questioning attitude led to the wrong

ESFAS bistable

being bypassed.

In addition, it was noted that an independent

verification was performed but failed to identify the mistake.

The inspector

examined the affected

components

immediately after the

problem was identified and noted that the labelling was extremely

confusing.

For

example,

the physical layout of the panel

resulted in

modules

from one bistable being aligned with the bypass

switches of a

different bistable.

In addition, the bypass

switches were identified as

Unit 2 rather than Unit 1.

The inspector

reviewed Procedure

AP 1-

0010123,

Revision 102, "Administrative Control Of Valves,

Locks,

And

Sw'itches,"

and verified that,

although the operator obtained the wrong

key to bypass

the bistable, it was obtained in accordance

with the

procedure.

The procedure

contained

no guidance

or verification to

ensure that the key requested

was actually the key needed to perform the

required function.

A log identifying each

key and its function was included

as

an

Attachment in the procedure,

however, it was only used to audit the key

lockers.

After the deficiencies

were corrected,

the inspector verified

the labelling to be much improved.

In addition,

a night order was

issued which highlighted the problem and requested

a more questioning

approach to activities by the Operations

personnel.

This night order

was discussed

by the Nuclear Plant Supervisors with personnel

associated

with their shift.

Technical Specification 3.3.2. 1 states,

in part, that the

ESFAS

instrumentation

channels

and bypasses

shown in Table 3.3-3 shall

be

operable.

Table 3.3-3 item 4.b states,

that the total

number of

channels for the MSIS function actuated

due to

SG Pressure

Low, is four

per

SG.

Action statement

9.a for this Table states,

in part, with the

number of operable

channels

one less than the total

number of channels,

operation

may proceed provided the inoperable

channel is placed in

either the bypassed

or tripped condition within one hour.

The

ESFAS

channel

"D" "B" SG Pressure

MSIS was inoperable for approximately 11.5

hours

on September

9 and

10 and was not bypassed

or placed in a tripped

condition.

This licensee identified and corrected violation was treated

as

a Non-Cited Violation consistent with Section VII.B.1 of the

NRC

Enforcement Policy and was identified as

NCV 50-335/96-15-02,

"Inadvertent Bypassing of the Wrong

ESFAS Signal."

Conclusions

The inspectors

concluded that exceptionally poor labelling led to the

Non-Cited Violation (NCV) identified above.

While generally it would be

expected that

an independent verification would have identified this

problem sooner,

the combination of poor labelling and procedural

guidance

was such that this was ineffective.

Once identified. the

system

was appropriately aligned

and the labelling corrected.

08.2

M3. 1

8

Closed

IFI 50-335

& 50-389/94-300-01:

Procedures

Do Not Provide

Information On Securin

Reactor Coolant

Pum s

RCPs

Before The Reactor

Coolant

S stem

Tem erature

Decreases

Below 500'F

92901

Inspection

Scope

The licensee's

Emergency Operating

Procedures

(EOPs) did not provide

explicit instructions to operators to ensure that one Reactor Coolant

Pump was secured prior to the Reactor Coolant System

(RCS) temperature

decreasing

below 500

F.

During simulator scenarios,

operators

were

observed to secure

one

RCP only when they got to specific procedural

guidance.

This occurred after

RCS temperature

decreased

below 500'

on

three out of four occasions.

Observations

and Findings

The inspector

noted that Procedure

EOP-01,

"Standard

Post Trip Actions."

now contains

guidance which should ensure that one

RCP is secured prior

to the

RCS reaching

500

F.

This guidance is encountered

early in the

procedure for any reactor trip and should enable the operators to secure

an

RCP when required.

Conclusion

The inspector concluded that the

EOP procedural

guidance

was

satisfactory.

II. Maintenance

Maintenance

Procedures

and Documentation

Control of Maintenance

Backlo s

62703

Scope

The inspector

reviewed controls for maintenance activities and the

monitoring of maintenance

backlogs.

Findings

The inspector noted that the licensee,

as

a part of morning management

meetings,

has adopted

a practice of reporting

on maintenance

and other

backlogs.

With respect to maintenance

backlogs,

reductions

have been

realized

due to a combination of improved scheduling

and an increase in

the use of Work it Now (WIN) teams,

which perform minor maintenance

activities outside of the scope of standard

maintenance

planning

and

control processes.

The inspector

reviewed controls applied to WIN team activities.

Procedure

ADM-80.01, Revision 2, "Control of Minor Maintenance

Activities." was developed

which defined the scope

and type of work

which could be performed

under the process.

The inspector

found that

the work activities defined in Appendix A of the procedure

(e.g.

packing

adjustments

on valves not subject to testing) were appropriate to work

outside the traditional work control process.

The inspector

reviewed

the WIN team open requests

database.

and found that minor maintenance

activities were appropriately tracked,

and that activities which were

found to be outside oi'he scope of the minor maintenance

program were

appropriately closed to Work Requests

(WRs) under the formal maintenance

control process.

fach item was found to have been

reviewed by an

SRO

for applicability to minor maintenance.

The inspector

reviewed the licensee's

progress

on minor maintenance

activities since April and found that,

as of October 7,

753 individual

activities had been worked under

the minor maintenance

program.

Of

those,

24 had been closed out to work requests,

indicating both

a high

level of accuracy in identifying candidate activities for minor

maintenance

and sensitivity in the screening

process for items which did

not belong in minor maintenance.

The inspector also reviewed the processing of canceled

WRs to ensure

that reductions in maintenance

backlogs

were not realized

due to

wholesale cancellations of requested

work.

A sample of WRs canceled

since June

was reviewed.

The inspector

found that

WR cancellations

were

performed appropriately, with most cancellations

involving adding the

given activities to a previously planned Plant Work Order

(PWO) (as

opposed to creating

a separate

PWO) or by referencing

an identical

WR/PWO combination which performed the same activity.

The inspector

reviewed

PWOs referenced

in WR cancellations

and found that the

requested

work activities were incorporated appropriately.

The inspector

reviewed the licensee's

weekly plant indicators for

October 8.

In it, the licensee tracked

a number of key indicators of

plant performance.

The indicators were discussed

at morning management

meetings.

In the area of maintenance

backlogs,

the inspector noted that

the licensee

was tracking

(among other things) the number of open

PWOs,

PWO age,

control

room instruments out-of-service,

number of PWO awaiting

parts.

Trends generally reflected reductions in both the number of open

PWOs and the age of PWOs.

The inspector

found that management

attention

to backlogs

had increased

and that the tracking mechanisms

employed.

and

the discussions

surrounding the indicators,

were effective in producing

reductions in backlogs.

c.

Conclusions

The'nspector

concluded that the licensee

has

made progress

in the

identification and reduction of maintenance

backlogs

as

a result of

improved scheduling,

management

attention,

and the use of the minor

maintenance

process.

Win team activities were review'ed

and were found

to be appropriately defined.

Work Request cancellations

reviewed during

the period were found to have been performed appropriately.

10

H7

Quality Assurance in Maintenance Activities

M7. 1

M&TE Noncom liances Identified

B

ualit

Control

C

De artment

62703

a.

Scope

The inspectors

reviewed Quality Control activities associated

with an

inspection of H8TE administrative controls.

b.

Fi'ndings

During a monthly surveillance of calibration activities,

QC identified

three areas of noncompliance with Procedure

QI 12-PR/PSL-2.

Revision 22,

"Control And Calibration Of Measuring

And Test Equipment

(H8TE)."

Section 5.3. 1.A required

a calibration sticker to be attached to

each

M&TE item.

Contrary to this, item E-586 was identified in

the general

population without

a calibration sticker affixed.

II

Section 5.3.2 required that the

M&TE storage

area

have sufficient

separation

between the ready-to-use

equipment (calibrated

and

restricted

use)

and other

equipment (rejected) to preclude

inadvertent

use.

Contrary to this,

item E-593 had

a Reject

sticker affixed to it but was not segregated

to preclude

use.

In

addition,

items E-647.

E-253,

and E-648/15 were out of calibration

but were also stored in the general

population ready for use.

Section 5.3.2.C requi red that the

H&TE storage

areas

shall

be

maintained

by a designated

individual responsible for logging in

and out all H&TE.

In the absence of this individual, the storage

areas

shall

be locked with access

and logging controlled by the

responsible

supervisor.

Contrary to this, the

QC inspector

observed three electricians

and one

I&C technician

access

the

taci lity to obtain

H&TE.

In addition, the

QC inspector identified

through interviews that other non-supervisory

personnel

had access

to the

M&TE facility.

Condition Report

(CR) 96-2203 was initiated to document these

discrepancies.

When the problem was identified, the not-ready-to-use

H8TE items were segregated

from the ready-to-use

items.

Additionally,

the Maintenance

Manager

changed the locks on the

H&TE storage

area

doors

and restricted

access

to Chiefs,

Foremen,

and Supervisors

only.

A memo

was sent to all maintenance

personnel

addressing

the requi rements of QI

12-R/PSL-2

and stressing

procedural

adherence.

This licensee identified

and corrected violation was treated

as

a Non-Cited Violation consistent

with Section VII.B.1 of the

NRC Enforcement Policy arid was identified as

NCV 50-335.389/96-15-03,

"Quality Control Identification of H&TE

Issues."

,

H8.1

Conclusions

Ouality Control effectively identified weaknesses

in the

H&TE program as

identified in the

NCV documented

above.

Once the problems were

identified, corrective actions

were implemented.

Miscellaneous

Haintenance

Issues

Closed

Unresolved

Item 50-335/96-14-02:

Control Of H&TE

92902

This item was open pending review of additional information related to

the use of H&TE during maintenance

on the Unit 1 linear power range

detector g9.

The licensee

replaced this detector in accordance

with

Work Order 95031787.

Testing of the detector

was conducted in

accordance

with I&C Procedure

1200062,

Revision 5,

"Uncompensated

Ion

Chamber Acceptance Test."

The Work Order indicated that the ohmmeter

used to obtain the post-installation

resistance

readings of the detector

was

a Biddle model

BH-10,

H&TE item PSL-865.

These readings

were

obtained

on June

26.

1996.

The inspector

reviewed the usage

log for this meter

on that date

and

noted that it had not been

logged out for maintenance

associated

with

this Work Order.

The licensee

investigated

and determined that meter

PSL-865

had been

logged out for another maintenance activity and was

simply "borrowed" to obtain the measurements

requi red by Work Order 95031787.

However,

when this activity was complete,

the maintenance

workers failed to identify this use of the meter

on the usage log.

The

inspector

reviewed the usage

log and verified that meter

PSL-865 had

been

logged out on June

25 for another

maintenance activity and logged

back in on June

27,

1996.

Procedure

QI 12-PR/PSL-2,

Revision 21, "Control And Calibration Of

Measuring

And Test Equipment

(M&TE)." Section 4.2.4, states,

in part,

that borrowing of M&TE in the field is not an acceptable

practice.

In

addition, Section 5.3.4.A requires,

in part, that each item of METE

shall

have

a log sheet filled out to identify each activity where the

instrument

was used.

Failure to log maintenance

associated

with Work Order 95031787

on the usage

log for meter

PSL-865 was

a violation of

this procedure

and was identified as

VIO 335/96-15-04,

"Failure to

Control

M&TE."

III. En ineerin

E3

E3.1

Engineering Procedures

and Documentation

Containment

Atmos heric Radiation Monitor Desi

n Basis

Documents

37551

Scope

During this report period, the inspectors

performed

an inspection of the

Unit 1 Containment Atmospheric Radiation Monitoring system.

b.

Findings

12

During a Unit 1 Containment Radiation Monitor system walkdown, the

inspector

observed the sample flow rate to be approximately 2.2 scfm.

Further inspection determined that the normal flow rate was 3.5 scfm.

The inspector

asked the licensee if the monitor's radiation alarm

setpoints

were affected by the reduced flow rate.

The licensee

provided

CR 96-1983,

which documented

the low flow condition,

and

an operability

assessment

which concluded that the system

was operable with a flow rate

of less than 3.0 scfm.

However, the licensee

was unable to produce

calculations

or other documentation

which determined

what the alarm

setpoints

should

be or how they were to be established.

The licensee

stated that the setpoints

were established,

using engineering

judgement,

at twice the normal

background radiation level with the reactor at power

for the Alert alarm,

and three times the normal background radiation

level for the High alarm.

The inspector

reviewed the applicable

sections of the Updated Final Saf'ety Analysis Report

(UFSAR) and noted

that it made

no mention of alarm setpoints

on this monitor.

In response to the inspectors

questions,

the licensee

generated

an

action plan to develop the design basis

documents

and calculations for

the system.

In addition,

CR 96-2228

was initiated to review the

applicable

UFSAR sections

and

make appropriate revisions

as necessary.

Pending review of this data, this item is being tracked

as

URI 335,

389/96-15-05,

"Inadequate

Design Basis Documentation."

Additionally, the inspector noted the following Unit 1

UFSAR

discrepancies:

\\

~

UFSAR section 5.2.4.6 states that the rate of change in indication

of the various leak detection

parameters

provides the necessary

information to identify and estimate reactor coolant system

leakage rates for

a 1.0

gpm leak.

Table 5.2-11 lists the amount

of time for a

1 gpm leak to be detected

as evidenced

by a 10

percent deviation in the normal readings.

The inspector

observed

the Containment Radiation Particulate

and Gaseous

meters

channels

31 and 32, respectively,

to deviate

by more than

10 percent

normally, without a

1 gpm leak.

The licensee is investigating the

basis for this method of leak detection.

~

UFSAR section 5.2.4.5.b.l states that the level detector

which

measures

leakage flow through the containment

sump weir is non-

seismic.

The detector

is in fact seismically qualified.

This

section also states that the recorder will have

a full scale

range

of 0 to 11 gpm.

The recorder,

FR-07-03, in fact has

a range of 0

to 12 gpm.

~

UFSAR section 5.2.4.5.b.2 stated that the Containment

Atmosphere

Radiation Monitoring System took isokinetic samples of air from

the containment cooling system ductwork.

Section 12.2.4. 1 stated

that the sample nozzles

were designed

such that the sampling

13

velocity was the

same

as that in the ventilation system

so that

preferential particulate selection did not occur.

Through

discussions

with the licensee,

the inspector

determined that the

system flow rate was greater than the sample flow rate.

Therefore

the system

was not isokinetic but rather subisokinetic.

~

UFSAR Table 5.2-11.

item (1) referenced

Figure 5.2-36.

This

figure did not exist.

Item (2) stated that the instrument

range

for the quench tank water level was

0 to 48 inches.

The

instrument,

LIA-1116. actually indicated from 0 to 100 percent.

Item (3) stated that Safety Injection Tank water level instruments

ranged

from 0 to 336 inches.

The instruments,

LIA-3311, 3321,

3331.

and 3341, actually indicated from 0 to 100 percent in the

plant.

Also. item (3) indicated that the Safety Injection Tank

pressure

instruments

ranged

from 0 to 250 psig.

The instruments,

PIA-3311,

3321.

3331.

and 3341, actually indicated

from 0 to 300

psig in the plant.

~

UFSAR section 12.2.4. 1 stated that the sample flow was regulated

and indicated

by independent

mass flow meters.

While the flow was

indicated

by independent

mass flow meters. it was not regulated.

The system flow was dependent

only on the capability of the pump.

These discrepancies

are being tracked

as additional

examples of failure

to update the

UFSAR identified as

URI 50-335,389/96-04-09.

"Failure to

Update

UFSAR."

c.

Conclusions

Results of this inspection indicated

a general

lack of design basis

documentation

for this system.

Because the licensee

has initiated

action to verify system operability and determine design basis, this

issue will be tracked

as

an Unresolved

Item (URI).

In addition, five

additional

examples of failure to update the

UFSAR were identified.

IV. Plant

Su

ort

R1

Radiological Protection

and Chemistry

(RPEC) Controls

R1. 1

Unit

1 Containment Radiation Monitor Out Of Service

Due To Mis ositioned

Valve

71750

Scope

On September

14,

1996, the Unit 1 containment radiation monitor was

removed from service to allow Health Physics

(HP) personnel

to obtain

a

grab sample.

Upon completion of this activity,

a system valve was not

properly realigned

and resulted in the system being inoperable.

The

condition was identified by the Unit 1 Senior Nuclear

Plant Operator

(SNPO)

and was subsequently

corrected.

14

Findings

The grab sample

was obtained in accordance

with Procedure

HPP-22,

Revision 4, "Air Sampling," Appendix A.

After the sample

was obtained,

the

HP technician reported to the Unit 1 Control

Room that the monitor

had been realigned for normal operation.

Operations

subsequently

declared the monitor back in service.

Approximately two hours

and

fifteen minutes after the system

was

removed from service,

the Unit 1

SNPO noted that the system flow rate was low, indicating approximately

0. 15 scfm.

Normal system flow was approximately 3.5 scfm.

The control

room was notified and

HP personnel

were dispatched to verify the system

valve lineup.

Upon review of the lineup, it was identified that sample

valve P3 was

CLOSED instead of FULL OPEN as required.

The valve was

subsequently

opened

and system flow returned to the normal value of 3.5

scfm.

CR 96-2232 was initiated to document this event

and develop

corrective action.

The licensee's

investigation determined that sample valve g3 had not

been realigned

as required after obtaining the sample.

In addition, the

licensee

discovered that the

HP technician performing this task did not

have the procedure in hand while obtaining the sample.

The licensee's

corrective actions included properly realigning the system

upon

discovery of the problem and subsequent

disciplinary action against the

involved individual.

The inspector

reviewed the

CR and HPP-22

and concluded the procedure

was

adequate to perform the evolution.

In addition, the inspector verified

through discussions

with Training department

personnel

and records

review that adequate training had been provided to Health Physics

personnel

in the area of procedural

usage

and compliance.

Discussions

with the involved personnel

confirmed the licensee's

findings with

regard to the individual not having

a procedure in hand during this

evolution.

Procedure

QI 5-PR/PSL-1.

Revision 73, "Preparation,

Revision,

Review/Approval Of Procedures,"

section

5. 14. 1 requires

verbatim

compliance to procedures

by all personnel.

In addition, step 5. 14.4.A.3

requi res that procedures

containing tasks which must be performed in a

specified

sequence

and/or which verification is documented

by initial or

signature

must be present

and referred to directly during the

performance of the activity.

Failure to have Procedure

HPP-22,

Revision

4, "Air Sampling," Appendix A, in hand, while it was being performed

on

September

14,

1996,

was

a violation of'rocedure

QI 5-PR/PSL-1

and was

identified as

VIO 50-335/96-15-06.

"Failure of HP to Have Procedure

In

Hand During Realignment of Unit 1 Containment Radiation Monitor."

This

violation was

a repeat

occurrence of VIO 50-335/96-04-01,

"Failure To

Follow Procedures

Lead to Unit 1 Containment

PIG Inoperability."

Conclusions

The inspector concluded that because

the involved individual did not

have

a procedure in hand

and follow it as required the violation as

15

stated

above occurred.

This was

a repeat violation.

Good attention to

detail

was noted

on the part of the

SNPO who identified the subject

condition.

Oil Catchment

Boxes Within the Radiation Control Area

RCA

71707

Inspection

Scope

The inspector toured the

RCA and reviewed the method

used to release oil

catchment

box liquid from the

RCA.

The oil catchment

boxes are

underground

tanks which hold runoff liquid from the diesel

generator

buildings.

The majority of the liquid in these tanks is water.

Observations

and Findings

The inspector noted that liquid pumped from the Unit 1 Emergency Diesel

Generator oil catchment

box was stored in 55 gallon drums .located

on

a

flatbed truck.

This liquid had not yet been tested

or released

from the

RCA.

The inspector

became

aware of a previous incident described

in

Condition Report

No. 96-2199 where

on August 2,

1996, liquid from the

Unit 2

EDG oil catchment

box had been released

from the

RCA prior to

ensuring that the liquid activity level was less than the environmental

release limits.

The inspector inquired as to the status of the present

batch of drums

and was told that they were awaiting testing.

The

inspector

reviewed the maintenance

procedure

governing the oil

separating

box inspections,

Procedure

H-0018 and noted that chemistry

had the assigned

responsibility to test the samples

from the oil

catchment

boxes.

The inspector inter viewed the Health Physics

Hanager

and inqui red as to the adequacy of using the hot chemistry lab for the

testing.

He indicated that the correct method for testing the liquids

was to use the low background

GELI detector

located in the training

building.

This detector

had been out of service f'r many months

resulting in a backlog of liquids to be sampled

and released.

The

licensee

generated

a Procedure

Change

Request

for Procedure

H-0018

Appendix A, "Oil Separating

Box Inspection."

The procedural

changes

assigned

responsibility for the testing of the liquid to Health Physics

and specified the sampling techniques

and specific requi rements that

must be met prior to release of the liquid from the

RCA.

The inspector

toured the

RCA and located the ten 55 gallon drums associated

with the

August 2,

1996 incident in the dry storage building along with numerous

other 55 gallon drums which were awaiting testing.

The ten drums

containing the Unit 2

EDG catchment

box liquid were marked with

contamination stickers indicating detectable activity levels.

Conclusion

The inspector

was satisfied that the revised procedur'e

was adequate to

ensure that unmonitor6d release of 55 gallon drums would not occur and

had no safety concerns

regarding the revised sampling process.

This

i

R8

R8.1

S2

16

issue will remain open

as

an Unresolved

Item,

URI 50-335.389/96-15-07.

"Contaminated

55 Gallon Drums. Improperly Removed

From RCA," pending

further inspection efforts concerning the incident which occurred

on

August 2,

1996.

Miscellaneous

RP&C Issues

Closed

Unresolved .Item 50-335/96-14-03:

Failure To Pro erl

Ali n The

Unit 1 Containment Radiation Monitor

92901

This issue involved the failure to properly realign the containment

radiation monitor following a functional test of the Post Accident

Sampling System

(PASS) control panel.

Issues

surrounding this event

involved general

procedure

usage

as well as the quality of'he procedure

being used

by the chemistry technicians

at the time of the event.

The

failure to properly'ealign the system resulted in the inoperability of

the Unit 1 containment radiation monitor, which shared

a return line to

containment with the

PASS system

and which was isolated

when the

PASS

system

was tested.

A SNPO identified a low flow condition in the

monitor, indicating good attention to detail while performing tours.

The procedure

being used at the time of the event was Chemistry

Procedure

1-C-112,

Revision 16.

"Operation And Calibration Of The Milton

Roy Post Accident Sampling System."

With regard to the quality of this

procedure.

the inspector concluded that while it was poor ly written, the

procedure did contain all the necessary

actions to accomplish its

purpose.

Several

steps in the procedure

contained multiple actions

including the step that was inappropriately performed.

The licensee

submitted

a procedure

change

request to format the procedure consistent

with the other Chemistry Procedures

and to limit the actions of

individual steps to

one.'egarding

the technician's

use of the procedure,

the inspector concluded

that the individual had the procedure in hand while performing the

evolution and was signing steps off as they were completed.

Approximately two hours after completing the

PASS panel test.

the low

flow condition with the containment radiation monitor was identified by

an operator

and was subsequently

corrected.

Followup investigation

by

the licensee

concluded that the technician failed to deenergize

the

PASS

panel

upon completion of the functional test.

Failure to deenergize

the

PASS panel

was

a violation of Chemistry Procedure

1-C-112, step 8. 1.33.

This licensee identified and corrected violation was treated

as

a Non-

Cited Violation consistent with Section VII.B.1 of the

NRC Enforcement

Policy and was identified as

NCV 50-335/96-15-08,

"Failure to Follow

Procedure

During

PASS Operation."

Status of Security Facilities and Equipment

(71750)

Scope

On October

10,

1996. the inspector walked down the protected

area

barriers.

In performing these

walkdowns. the inspector verified the

17

fence fabric had no unintentional

openings,

was not degraded,

and was

not eroded at the base;

isolation zones

were free of objects

and well

illuminated;

and compensatory

guard postings

were in place

as necessary.

b.

Findings

The inspector

found no discrepancies

with the protected

area barriers.

c.

Conclusions

The protected

area barriers

were in good condition, the isolation zones

well lit, and the appropriate

compensatory

guard postings in place.

V. Hang ement Heetin

s and Other

Areas

Xl

Exit Heeting

Summar y

The inspectors

presented

the inspection results to members of licensee

management

at the conclusion of inspections

on September

13 and October

18.

The licensee

acknowledged the findings presented.

The inspectors

asked the licensee

whether any materials

examined during the

inspection should

be considered

proprietary.

No proprietary information was

identified.

PARTIAL LIST OF

PERSONS

CONTACTED

Licensee

W. Bladow, Site Quality Manager

H. Buchanan,

Health Physics Supervisor

D. Fadden,

Site Services

Manager

R.

Dawson,

Business

Manager

D. Denver, Site Engineering

Manager

D. Faulkner,

Chemistry Supervisor

P. Fulford, Operations

Support Engineering

Manager

J. Holt. Information Services

Supervisor

H. Johnson,

Operations

Manager

J.

Harchese.

Maintenance

Manager

C. Marple, Operations

Super visor

C. O'Farrel.

Reactor

Engineering Supervisor

A. Pawley,

Instrument

and Control Maintenance Supervisor

J. Scarola,

St. Lucie Plant General

Manager

A. Stall, Site Vice President

E.

Weinkam, Licensing Manager

C.

Wood, Acting Work Control Manager

W. White. Security Supervisor

Other licensee

employees

contacted

included office, operations,

engineering,

maintenance,

chemistry/radiation,

and corporate personnel.

i

IP 37551:

IP 61726:

IP 62703:

IP 71001:

IP 71707:

IP 71715:

IP 71750:

IP 92901:

IP 92902:

O~ened

INSPECTION

PROCEDURES

USED

Onsite Engineering

Surveillance Observations

Maintenance

Observations

Licensed Operator Requalification

Program Evaluation

Plant Operations

Sustained

Control

Room and Plant Observation

Plant Support Activities

Followup - Plant Operations

Followup - Maintenance

ITEMS OPENED,

CLOSED,

AND DISCUSSED

50-335/96-15-04

50-335,389/96-15-05

50-335/96-15-06

50-335,389/96-15-07

Closed

50-335,389/96-15-01

50-335/96-15-02

50-335,389/96-15-03

50-335/96-15-08

50-335,389/94-300-01

50-335/96-14-02

50-335/96-14-03

VIO

"Failure to Control

M&TE"

URI

"Inadequate

Design Basis Documentation"

VIO

"Failure of HP to Have Procedure

In Hand During

Realignment of Unit 1 Containment Radiation

Monitor"

URI

"Contaminated

55 Gallon Drums Improperly Removed

From RCA"

NCV

"Failure to Implement Training Bulletins in

Accordance with Requalification

Program

Procedure"

NCV

"Inadvertent Bypassing of the Wrong

ESFAS

Signal"

NCV

"Quality Control Identification of M&TE Issues"

NCV

"Failure to Follow Procedure

During PASS

Operation"

IFI

"Procedures

Do Not Provide Information On

Securing

RCPs Before The Reactor Coolant System

Temperature

Decreases

Below 500'F

"

URI

"Control of M&TE"

URI

"Failure To Properly Align The Unit 1

Containment Radiation Monitor"

Discussed

19

50-335,389/96-04-09

URI

"Failure to Update

UFSAR"

LIST OF ACRONYMS USED

ADM

ANPS

ATTN

CCW

CFR

CR

DPR

EDG

EOP

ESFAS

FPL

FR

FR

FRG

FSAR

HPP

HPSI

IFI

rsr

IST

LOCA

LPSI

METE

MSIS

NCV

NLO

No.

NPF

NPS

NRC

PASS

PDR

PIG

PMAI

Psig

PSL

PWO

QC

QI

RCA

RCP

RCS

Administrative Procedure

Assistant

Nuclear Plant Supervisor

Attention

Component Cooling Water

Code of Federal

Regulations

Condition Report

Demonstration

Power Reactor

(A type of operating license)

Emergency

Diesel Generator

Emergency Operating

Procedure

Engineered

Safety Feature Actuation System

The Florida Power

8 Light Company

Federal

Regulation

Flow Recorder

Facility Review Group

Final Safety Analysis Report

Health Physics

Procedure

High Pressure

Safety Injection (system)

[NRC] Inspector Followup Item

[NRC] Inspection Report

InService Inspection

(program)

InService Testing

(program)

Loss of Coolant Accident

Low Pressure

Safety Injection (system)

Measuring

8 Test Equipment

Main Steam Isolation Signal

NonCited Violation (of NRC requirements)

Non-Licensed Operator

Number

Nuclear Production Facility (a type of operating license)

Nuclear Plant Supervisor

Nuclear Regulatory

Commission

Post Accident Sampling System

NRC Public Document

Room

Particulate-Iodine-Noble

Gas Monitor

Plant Management Action Item

Pounds

per square

inch (gage)

Plant St. Lucie

Plant

Work Order

Quality Control

Quality Instruction

Radiation Control Area

Reactor Coolant'Pump

Reactor

Coolant System

Region II - Atlanta, Georgia

(NRC)

Real

Time Training Coach

Standard

Cubic Foot/Feet

Per Minute

SG

SNPO

SRO

St.

STA

TB

TC

UFSAR

URI

VIO

WIN

WR 20

Steam Generator

Senior

Nuclear Plant Lunlicensedj Operator

Senior Reactor [licensedj Operator

Saint

Shift Technical Advisor

Training Bulletin

Temporary

Change

Updated Final Safety Analysis Report

[NRCj Unresolved

Item

Violation (of NRC requirements)

Work It Now Team

Work Request