ML17229A132
| ML17229A132 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie |
| 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:
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
ADQCK 05000335
6
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
water level channel after the channel
had been
declared
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
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
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
(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,
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
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
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
instrumentation
channels
and bypasses
shown in Table 3.3-3 shall
be
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
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
Pum s
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
"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
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
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
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
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
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
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
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
"Failure to Control
M&TE"
"Inadequate
Design Basis Documentation"
"Failure of HP to Have Procedure
In Hand During
Realignment of Unit 1 Containment Radiation
Monitor"
"Contaminated
55 Gallon Drums Improperly Removed
From RCA"
"Failure to Implement Training Bulletins in
Accordance with Requalification
Program
Procedure"
"Inadvertent Bypassing of the Wrong
Signal"
"Quality Control Identification of M&TE Issues"
"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
"
"Control of M&TE"
"Failure To Properly Align The Unit 1
Containment Radiation Monitor"
Discussed
19
50-335,389/96-04-09
"Failure to Update
LIST OF ACRONYMS USED
ADM
ANPS
ATTN
CFR
CR
FR
FR
FRG
HPP
IFI
rsr
METE
No.
NPF
NRC
PIG
PMAI
Psig
PSL
PWO
QI
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
SNPO
St.
WIN
Senior
Nuclear Plant Lunlicensedj Operator
Senior Reactor [licensedj Operator
Saint
Training Bulletin
Temporary
Change
Updated Final Safety Analysis Report
[NRCj Unresolved
Item
Violation (of NRC requirements)
Work It Now Team
Work Request