ML17229A211

Responds to NRC 961223 Ltr Re Violations Noted in Insp Rept 50-335/96-17.Corrective Actions:Fpl Has Adopted Policy of Verbatim Compliance with Procedural Instructions at St Lucie Plant

ML17229A211
Person / Time
Site:	Saint Lucie
Issue date:	01/28/1997
From:	Plunkett T FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-97-016, L-97-16, NUDOCS 9702030207
Download: ML17229A211 (13)

Text

CATEGORY 1 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9702030207 DOC.DATE: 97/01/28 NOTARIZED: NO DOCKET I ACIL:50-335 St. Lucie Plant, Unit 1, Florida Power & Light Co. 05000335 AUTEUR.NAME AUTHOR AFFILIATION LUNKETT,T.F. Florida Power 6 Light Co.

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

SUBJECT:

Responds to NRC 961223 ltr re violations noted in insp rept 50-335/96-17.Corrective actions:FPL has adopted policy of verbatim compliance with procedural instructions at St Lucie plant.

DISTRIBUTION CODE: ZEOZD COPIES RECEIVED:LTR i ENCL t SIZE: l0 TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response E

NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-3 PD 1 1 WIENS,L. 1 1 INTERNAL: ACRS 2 2 AEOD/SPD/RAB 1 1 1 1 DEDRO 1 1 1 1 NRR/DISP/PIPB 1 1 1 1 NRR/DRPM/PECB 1 1 NRR/DRPM/PERB 1 1 NUDOCS-ABSTRACT 1 1 OE DIR 1 1 OGC/HDS3 1 1 RGN2 FILE 01 1 1 TERNAL: LITCO BRYCEPJ H 1 1 NOAC 1 1 D NRC PDR 1 1 N

N OTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN SD-5(EXT. 4l5-2083) TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 19

r.<

Florida Powers Light Company, i.u. Box128, Fort Pierce. FL34954-0120 January 28, 1997

@PL L-9716 10 CFR 2.201 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Re: St. Lucie Unit 1 Docket No. 50-335 Reply to a Notice of Violation Florida Power and Light Company has reviewed the subject Notice of Violation and, pursuant to 10 CFR 2.201, the responses to the violations are attached.

The subject inspection report was dated December 23, 1996, with a response to the Notice of Violation required within 30 days of that date, i.e., by January 22, 1997. FPL received Integrated Inspection Report No. 96-17 on December 30, 1996. The seven day delay in the receipt of the inspection report and Notice of Violation by FPL was discussed with Caudle A.

Julian (USNRC/Region IQ and Edward Weinkam (FPL) on January 9, 1997. In accordance with the response relief discussed in the Notice of Violation, Mr. Julian granted an extension to the required response date.

Very truly yours, T. F. Plunkett President Nuclear Division TFP/JAS/EJW Attachment cc: Regional Administrator, USNRC, Region II Senior Resident Inspector, USNRC, St. Lucie Plant 9702030207 970%28 PDR ADOCK 05000335 8 PDR an FPL Group company

L-97416 Attachment Technical Specification 6.8.1.a, requires that written procedures shall be established, implemented and maintained covering the activities recommended in appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A, paragraph 7 of RG 1.33 requires procedures for calibration of area, process, portable and airborne radiation monitors.

I&C Procedure No 1-1220053, "Calibration of the Control Room Outside Air Intake Monitors," Rev 2, dated September 15, 1994, provides instructions for calibrating the control room outside air intake radiation monitors.

Step 7.1 of I&C Procedure no 1-1220053, states a completed copy of this procedure shall be maintained in the plant files in accordance with QI 17-PR/PSL-1, "Quality Assurance Records."

Step 7.2 states a copy of the assay report for the radiation check sources and data sheets associated with this procedure should be retained and included as a calibration package upon completion.

if Step 9.3.10, of I&C Procedure No 1-1220053, required, in part, that the high if voltage is adjusted more than 50 volts, or a new detector is installed or monitor cannot be adjusted to within J 10% tolerance go to step 9.4 New Calibration.

Step 9.4, of I&C Procedure No 1-1220053, described the process for performing a primary calibration and required, in part, the performance of a high voltage plateau for determining operating voltage for the detector. The procedure also required the introduction of known radioactive gas in various activity levels to develop an efficiency curve in pCi/cc vs cpm for the new detector. At least 4 points were required on the graph.

Contrary to the above, on April 11, 1995, the licensee replaced the detector for the Unit 1 RE-26-47 Control Room Outside Air Intake Monitor and failed to adequately perform the primary calibration in accordance with I&C Procedure No 1-1220053, in that; the licensee failed to develop an efficiency curve with at least four calibration points of known quantities of radioactive material as required by step 9.4 of the procedure; and the licensee failed to maintain calibration documentation as required by steps 7.1 and 7.2 of procedure.

'-97-016 turb ~s nt

>nlv " a k~tirp n 'E n(ntinn This is a Severity Level IV violation (Supplement IV) applicable to Unit 1 only.

1. FPL concurs with the violation.

2.

The cause of the violation was personnel error on the part of a utility Instrument and Control (1&C) Technician who failed to strictly adhere to an approved plant procedure (1-1220053) requiring the performance and documentation of a primary calibration of the Control Room Outside Air Intake Radiation Monitor (RE-26-47). The technician did not demonstrate a thorough awareness of the importance and the specific requirements related to the implementation of the calibration procedure.

A. Since the time of this violation (April 1995) FPL has adopted a policy of verbatim compliance with procedural instructions at St. Lucie Plant. The policy applies to all plant personnel and is currently incorporated in the St. Lucie Plant Quality Instructions.

B. The Control Room Outside Air Intake Monitor (RE-26-47) was removed from service on January 6, 1997, pending the performance of a primary calibration of the instrument, and a redundant channel (RE-26-46) was selected for use.

C. A primary calibration was performed using revised I&C Procedure 1-1220053, and a functional test was completed for Control Room Outside Air Intake Monitor RE-26-47. The monitor was returned to service on January 21, 1997.

4.

A. The current site philosophy regarding verbatim compliance and procedural adherence was reinforced to the I&C personnel involved in this event, which actually occurred in April 1995.

B. Since the time of this violation (April 1995) FPL has implemented several key actions to improve personnel performance, including procedure adherence, at St. Lucie Plant. These actions have included increased management oversight,

L-97-016 Attachment reinforcement of management expectations at the supervisory level, and development of guidelines for assessing and improving employee performance.

FPL is continuing to reinforce high standards of personal accountability, including procedural adherence, to plant personnel at St. Lucie.

C. This violation will be incorporated into the events training program materials for St. Lucie maintenance personnel to reinforce the expectation for verbatim procedure compliance and the importance of maintaining documentation as required by procedures. This action will be completed by March 31, 1997.

5. Full Compliance was achieved on January 21, 1997, with the completion of Item 3C, above.

Technical Specification 6.8.1.a, requires that written procedures shall be established, implemented and maintained covering the activities recommended in appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A, paragraph 7 of RG 1.33 requires procedures for calibration of area, process, portable and airborne radiation monitors.

ISAAC Procedure No 1-1220053, "Calibration of the Control Room Outside Air Intake Monitors," Rev 2, dated September 15, 1994, provides instructions for calibrating the control room outside air intake radiation monitors.

Contrary to the above, the procedure for calibrating the control room outside air intake radiation monitors was inadequate, in that, on April 11, 1995, the procedure did not provide sufficient guidance for the documentation of instrument calibration. The calibration records necessary to provide sufficient documentation to demonstrate that a primary calibration had been performed were not clearly specified by the procedure.

This is a Severity Level IV violation (Supplement IV) applicable to Unit 1 only.

1 ~ FPL concurs with the violation.

I 97-016 Attachment 2.

The cause of the violation was personnel error, in that sufficient guidance regarding required documentation records was not incorporated during the original development of Prouxiure 1-1220053, "Calibration of the Control Room Outside Air Intake Monitors," which was written in 1989. Specifically, high voltage and primary curve plots were not properly identified as records which were required to be maintained following the performance of a primary calibration on this instrumentation.

3.

A. I&C Procedure 1-1220053, "Calibration of the Control Room Outside Air Intake Monitor's" was revised to more clearly specify the requirements for maintaining sufficient documentation as a record when a primary calibration has been performed. The procedure change was approved on January 10, 1997.

B. The Control Room Outside Air Intake Monitor (RE-26-47) was removed from service on January 6, 1997, and a redundant channel (RE-26-46) was selected for use. A primary calibration was subsequently performed using revised I&C procedure 1-1220053 and the monitor was returned to service January 21, 1997.

4.

A. FPL has identified several additional procedures for review which are currently being used by I&C to calibrate and functionally test radiation monitoring instrumentation. These procedures will be reviewed to ensure that proper guidance is included to describe the documentation required to be maintained as a quality record. This action will be completed by February 28, 1997.

B. Recent self assessment activities performed by FPL have identified that procedural improvements are necessary to improve the level of detail provided in plant procedures. FPL has initiated actions to address the weaknesses which were identified by the above self assessment and to ensure that current procedure upgrade initiatives are adequately supported, staffed and directed.

5. Full compliance was achieved January 10, 1997, with the completion of Item 3A, above.

L-97-016 Attachment 5lialatioiij Technical Specification 6.3.1 states each member of the unit staff shall meet or exceed the minimum qualifications of ANSI/ANS-3.1-1978.

Technical Specification 6.4.1 states a retraining and replacement training program for the unit staff shall be maintained under the direction of the Training Manager and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSUANS-3.1 1978 and 10 CFR Part 55 and the supplemental requirement specified in Sections A and C of Enclosure 1 of the March 28, 1980 NRC letter to all licensees, and shall include familiarization with relevant industry operational experience.

Licensee procedure QI 2-PR/PSL-2, "Indoctrination and Training of St Lucie Plant Personnel," revision 23, dated October 23, 1996, states the instruction shall apply but not be limited to training in several general areas, including 6.0 Job Specific Technical Training.

Section 4.1, states the Training Manager shall be responsible to the Plant General Manager for the establishment and coordination of training activities as required by St.

Lucie Plant Technical Specifications, Section 6.4 and as required to meet regulatory

'equirements.

Section 4.3.2 states that department heads shall be responsible for approving department personnel qualification standards, appropriate for the duties to be performed.

Section 4.3.3 states that Department Heads shall ensure that personnel performing activities affecting quality receive departmental training commensurate with the work performed prior to performing those activities or are performing those activities under the supervision of a trained individual until the required training is complete.

Contrary to the above, on July 1, 1996, licensee personnel assigned I&C personnel the responsibilities to calibrate Unit 1 plant radiation monitoring instrumentation utilized to perform certain plant process controls, radiological monitoring and continuous effluent monitoring functions that were not fully trained and qualified to perform those functions in accordance with the licensee s training program.

This is a Severity Level IV violation (Supplement IV) applicable to Unit 1 only,

L-97-016 Attachment

1. FPL concurs with the violation.

2.

The cause of this violation was the ineffective transfer of accountability for the Unit 1 radiation monitoring instrumentation from Chemistry and Health Physics Departments to the I&C Department prior to ensuring that the affected I&C personnel had completed all appropriate training qualifications. Training for the subject I&C personnel had been scheduled to be implemented and was postponed by the I&C system supervisor due to work priorities. A subsequent verification was not made by I&C supervision to verify that personnel had been fully trained prior to receiving responsibility for the above instrumentation.

A. A revised schedule was implemented for the completion of the specific training and qualification required for I&C personnel responsible for performing radiation monitor calibration and testing. The above training for these personnel will be completed by March 31, 1997, following a review of the associated I&C procedures.

B. A supervisor's meeting was held by the I&C Department head to address and emphasize the requirements for obtaining prior department head approval of changes to scheduled training and ensuring that all personnel are properly and currently trained to perform the tasks which they are assigned. I&C personnel performing radiation monitoring calibrations, and functional checks were required to work under additional supervisory oversight pending the completion of the appropriate qualification training.

C. Appropriate Training personnel were counseled on the importance of informing management when training or qualification requirements are not being adequately met.

4.

A. The required training and qualification of I&C personnel responsible for performing calibration and testing of radiation monitoring instrumentation will

L-97-016 Attachment be completed by March 31, 1997. Additional supervisory oversight is being provided until the above training has been completed.

B. St. Lucie Training Department implemented a program in which the managers of each department are informed, on a weekly basis, of training which is scheduled for their personnel. As part of this process, weekly attendance is presented to the department managers, who are notified of any individuals who have not attended the scheduled training.

C. The St. Lucie Maintenance Manager required that department heads review and concur with any changes to scheduled training and ensure that personnel in their departments are fully qualified to perform the tasks which they have been assigned.

D. Training Department guidelines and administrative requirements will be enhanced to require that qualification training be completed for individuals who are performing new tasks, and to better define the responsibility for ensuring that training is achieved prior to the transfer of task accountability. This action will be completed by March 31, 1997.

E. A recent FPL self-assessment initiative recognized that the transfer of responsibilities at St. Lucie was not always properly evaluated prior to implementing site organizational changes. FPL has since initiated action to address the weaknesses identified in the "Change Management" process at St.

Lucie and ensure that the impact of future organizational change is properly assessed, so that the definition of responsibilities, adequate training, and resources are in place prior to implementing such changes,

5. Full compliance will be achieved by March 31, 1997, with the completion of the training described in Item 4A, above.

Technical Specification 6,8.1.a requires that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February, 1978. Appendix A, paragraph l.d includes administrative procedures for procedural adherence. 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.

0 L-97-016 Attachment Operating Surveillance Procedure 64.01, Revision 16, "Reactor Engineering Periodic Tests, Checks and Calibrations," Appendix 7, "Reactivity Deviation From Design,"

required that reactivity deviation results be documented in the Unit 1 Plant Physics Curve Book, Figure B.3, "Reactivity Deviation Log," upon completion of the determination of reactivity defect.

Contrary to the above, the reactivity deviation calculation performed on October 8, 1996, was not documented in the Unit 1 Plant Physics Curve Book. This resulted in operators using an incorrect reactivity deviation in two Shutdown Margin Verifications performed on October 31 and November 1, 1996.

This is a Severity Level IV violation (Supplement I) applicable to Unit 1 only.

Bespot&

1. FPL concurs with the violation.

2.

The cause of the violation was personnel error on the part of Reactor Engineering personnel who failed to update the Unit 1 Plant Physics Curve Book in accordance with procedural requirements following performance of a monthly surveillance. The procedure violation occurred when the Plant Physics Curve Book was not immediately updated with the current data after the reactivity deviation value was calculated as required by Operating Surveillance Procedure (OSP) 64.01. The Reactor Engineer performing the surveillance failed to execute proper follow-up and verify that the data was properly recorded in the Plant Physics Curve Book prior to closing the corresponding surveillance procedure.

3.

A. A Condition Report (CR) was written on November 5, 1996, to evaluate the cause of the event and to determine the appropriate corrective actions.

B. The Unit 1 Control Room plant physics data was updated to reflect the current value for reactivity deviation, in accordance with procedure, following discovery of the above condition on November 5, 1996.

C. A review of the Plant Physics Curve Books for both St. Lucie Units 1 and 2

I 97-016 Attachment BepLy tomHoticeafYialatian was performed to ensure that no additional missing data existed. No other missing data was identified during the review.

4, A. Reactor Engineering performed a self assessment of the process in place for updating information in the Plant Physics Curve Books. As a result of this assessment, a detailed verification checklist was developed for use in performing the Plant Physics Curve Book updates.

B. The Reactor Engineering Schedule of Periodic Tests and Reports, AP-0010127, was revised to require that a weekly review of the Plant Physics Curve Book be performed to verify that reactor physics data contained in the book are current.

C. A meeting was held with the responsible Reactor Engineering personnel, the President of the Nuclear Division and the Vice President of Nuclear Engineering to discuss this event and the expectations of FPL management with regard to personnel performance.

D. The personnel involved in the failure to properly update the reactivity deviation information received appropriate disciplinary action in accordance with FPL policy.

5. Full compliance was achieved on November 5, 1996, with the completion of Item 3B, above.