ML17229A511

Forwards Response to Violations Noted in Insp Repts 50-335/97-10 & 50-389/97-10.Corrective Actions:All Sixteen Identified Errors Reviewed & Determined Not to Represent Operability Concerns

ML17229A511
Person / Time
Site:	Saint Lucie
Issue date:	11/03/1997
From:	Plunkett T FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-335-97-10, 50-389-97-10, L-97-274, NUDOCS 9711100088
Download: ML17229A511 (14)

Text

CATEGORY 1 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9711100088 DOC.DATE: 97/11/03 NOTARIZED: NO DOCKET ¹ FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power & Light Co. 05000335

,.5g-.'589 St. Lucie Plant, Unit 2, Florida Power & Light Co. 05000389 UTH.NAME AUTHOR AFFILIATION PLUNKETT,T.F. Florida Power & Light Co.

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

SUBJECT:

Forwards response to violations noted in insp repts 50-335/97-10 & 50-389/97-10.Corrective actions:all sixteen identified errors reviewed & determined not to represent operability concerns.

T' DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR . ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Vio ation Response l

NOTES:

RECIPIENT COPIES RECIPIENT COPIES

'ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL 0 PD2-3 PD 1 1 WIENS,L. 1 1 INTERNAL: ACRS 2 2 AEOD/SPD/RAB 1 1 AEO C 1 1 DEDRO 1 1 LE CE 1 1 NRR/DISP/PIPB 1 1

/DRC /fiHFB 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 EXTERNAL LITCO BRYCE I J H 1 1 NOAC 1 1 D

NRC PDR 1 1 NUDOCS FULLTEXT 1 1 U'

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER Or COPIES REQUIRED: LTTR 20 ENCL 20

'l Florida Power 8c Light Company,6351 S. Ocean Orive. Jensen Beach, FL34957 L-97-274 November 3, 1997 10 CFR $ 2.201 APL U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Re: St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Reply to a Notice of Violation NR In e ratedIns ecti nRe ort97-10 Florida Power and Light Company (FPL) has reviewed the subject Notice of Violation and, pursuant to 10 CFR $ 2.201, the response to the violation is attached.

'y FPL letter L-97-180, subject, "Voluntary Initiative to Review Final Safety Analysis Reports,"

dated July 11, 1997, FPL committed to conduct a graded review of the St. Lucie Updated Final Safety Analysis Reports (UFSARs). As stated in the letter, the UFSAR review effort and resources are being expended in those areas of greatest safety'significance. The review scope includes examination of relevant system documentation and walkdowns of system critical characteristics. FPL also committed to evaluate the outcome of the UFSAR review and, as necessary, expand the scope of the UFSAR review.

As for the UFSAR discrepancies cited in this Inspection Report, FPL reviewed all identified errors and determined the issues did not represent operability concerns. FPL implemented improvements in the UFSAR update process that will minimize the potential for future UFSAR discrepancies of the type cited in this violation. A UFSAR style guide has been developed to UFSAR change packages. Personnel developing facility changes (e.g., plant 'tandardize modifications or procedure changes) have access to search tools that were developed to facilitate locating relevant UFSAR information. These search tools ensure that accurate 10 CFR 50.59 screenings are performed, and that required UFSAR change packages are developed.

Please contact us with questions on the enclosed violation response.

Very truly yours, Thomas F. Plunkett r~L I President I Nuclear Division TFP/JAS/EJW cir711100088 971103 Attachment PDR ADOCK 05000335 6 PDR cc: Regional Administrator, USNRC, Region II Senior Resident Inspector, USNRC, St. Lucie Plant llllllllllllllllllllllllllllllllllllllll an FPL Group company

0 I L-97-274 Attachment P~ae 1

~il ~in 10 CFR 50.71(e) requires that each person licensed to operate a nuclear power plant, update, periodically, the final safety analysis report to assure that the information included in the document contains the latest material developed.

Contrary to the above, as of September 6, 1997, the licensee failed to update the Updated Final Safety Analysis Reports (UFSAR) for St. Lucie Units 1 and 2 such that the information included in the documents did not contain the latest material developed as evidenced by the following examples of UFSAR discrepancies:

1. Unit 1 NaOH concentration listed in Unit 1 UFSAR Table 6.2-22 was incorrect.

2. Unit 1 UFSAR Table 7.3-2 incorrectly designated MV-21-2 in the A ICW train rather than the B ICW train.

3.. Unit 1 UFSAR Figure 9.2-1a was not revised following modifications to the intake cooling water lube oil coolers performed under PC/M 341-192.

4. Unit 1 UFSAR Table 7.4-1 was not revised to delete lubricating water pressure switches removed by modification.

5. Unit 1 UFSAR figures 7.4-9, 10, and 11 were not revised to remove annunciator E-15 logic which was spared out.

6. Unit 2 UFSAR Table 7.3-2 incorrectly designated MV-21-2 in the A ICW train rather than the B ICW train.

UFSAR Table 4.2-1 and UFSAR Section 4.2.3.2.3(b)(1) contained inconsistent information on control element assembly (CEA) speed and drop times.

t

8. Installed Unit 2 fire extinguishers were not of the type specified by Unit 2 UFSAR Table 9.5A-8D..

9. Unit 2 UFSAR Table 7.5-3 for windows LA-9 and LB-9 showed incorrect actuation devices.

10. Unit 2 UFSAR Table 7.5-3 incorrectly indicated that windows LA-4 and LB-4, "Lube Water Supply Strainers High Differential Pressure", were safety related.

11. Unit 1 UFSAR Section 5.2.4.5.b.1 incorrectly stated that the level detector which measured leakage flow through the containment sump weir was non-seismic.

J i L-97-274 Attachment P~a 2

12. Unit 1 UFSAR Section 5.2.4.5.b.2 incorrectly stated that the Containment Atmosphere Radiation Monitoring System took isokinetic samples of air from the containment cooling system.

13. Unit 1 UFSAR Table 5.2-11, Reactor Coolant Leak Detection Sensitivity, contained inconsistent information on "Average Rate of Change" and the "Time for Scale to Move" and instrument ranges.

14. Unit 1 UFSAR Section 12.2.4.1 incorrectly stated that containment atmosphere sample flow was regulated and indicated by independent mass flow meters.

15. The battery load profile shown in Unit 1 UFSAR Table 8.3-5 was incorrect.

16. UFSAR Table 9.2-5, Operating Flow Rates and Calculated Heat Loads for Auxiliary Equipment Cooled by Component Cooling Water, was not changed to reflect a 1993 accident reanalysis affecting these parameters.

This is a Severity Level IV violation (Supplement I).

R~g~ng FPL concurs with the violation. However, as explained below, FPL determined that examples 3, 8, and 16 cited in this violation do not constitute UFSAR errors.

REASON FOR VIOLATION The cited UFSAR update deficiencies represent a diverse group of discrepancies identified from the UFSARs for both units. The sixteen identified errors stem from a variety of individual causes. Based on our review of the specific examples, the errors were grouped into the following categories: (i) editoriaVtypographical corrections (examples 2, 6, 9, 15);

(ii) errors present in the original UFSAR (examples 11, 14); (iii) instances where plant operations have evolved away from that anticipated in the original design and described in the FSAR (example 12, 13); (iv) changes made under 10CFR50.59 and 10CFR50.92 which were not incorporated into the UFSAR (examples 1, 4, 5, 7, 10).

Examples 3, 8 and 16 are not UFSAR errors and consequently do not fall into any of the above categories. Example 3 states that Figure 9.2-1a in the Unit 1 UFSAR was not updated to reflect Plant Change/Modification (PC/M) 341-192. This figure is a duplication of controlled drawing 8770-G-082 Sheet 2 and the UFSAR amendment used the most recent revision. At the time of the UFSAR figure update, the controlled drawing had not been as-built to reflect (PC/M) 341-192. Note that the timing of controlled

~ L-97-274 Attachment P~ae 3 drawing revisions is no longer a concern since UFSAR Amendment 15 (1/97) removed all figures based on controlled drawings. The figures have been replaced by a reference to the controlled plant drawing.

Example 8 is a discrepancy between the physical plant and the UFSAR description in the UFSAR was correct. The discrepancy was resolved by restoring the plant to 'hich the UFSAR described condition.

Example 16 states that the values in Table 9.2-5 were not updated to reflect the 1993 reanalysis of the post accident containment conditions. In fact, this table was updated in Amendment 9 (10/94) to contain the following note: "These values reflect original procurement values. Refer to Ref. 27 in Section 6.2." Reference 27 in Section 6.2 is the 1993 containment reanalysis.

The principal causes for each of the four error categories are identified below:

i T o ra hical/E it rialErr r xam les2 6 9 15 The editoriaVtypographical changes are primarily the result of human error and a lack of

'attention to detail. The cited examples have no impact on nuclear safety or plant operation.

ii ErrorsinOri inalFSAR xam les 11 14 These errors were made as a result of original preparation of the UFSAR and were not identified in subsequent updates of the UFSAR. The historical cause of the original errors in the UFSAR cannot be definitively determined and is not relevant to current processes.

The update process does not [nor is it required to by 10CFR50.71(e)] include a validation of unmodified'sections of the UFSAR. Additionally, because of the relatively low safety significance of the examples, they have not undergon'e scrutiny by other processes.

iii Chan es in erational Practices xam les 12 13 Examples 12 and 13 are the result of changes over time in the operation of plant equipment that were not recognized as impacting the UFSAR. Both of the cited examples are associated with operation of the containment Particulate, Iodine, and Gas (PIG) monitors which are used for identification of Reactor Coolant System (RCS) leakage. The original UFSAR descriptions assumed operation with a relatively high RCS activity. Over time the use of debris resistant fuel and other improvements (e.g., foreign material exclusion programs) have significantly reduced the actual RCS activity levels. Changes to the operation for the PIG monitors was a consequence of these improvements, however, because of a lack of awareness and sensitivity to the UFSAR descriptions these differences

L-97-274 Attachment P~ae 4 failed to be identified as UFSAR changes.

50 59 457 0 Examples 1 and 7 are the result of a failure to update the UFSAR to reflect changes made to the Technical Specifications pursuant to 10CFR50.92. Examples 4, 5, and 10 are the result of a failure to update the UFSAR to reflect changes made via PC/M packages for the installation of cooling lines on the intake cooling water pumps for both units.

3. CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED All sixteen identified errors were reviewed and determined not to represent operability concerns. Examples 3, 8 and 16 are not update errors and do not require a change to the UFSAR. However, to address example 8, fire extinguishers were added to bring the plant into conformance with the UFSAR descriptions. a A. UFSAR changes were implemented during the last Unit 1 amendment (Amendment 15) to correct examples 2, 4, and 5.

B.. Examples 1, 7, 11, 12, 13, 14, and 15 will be corrected in Amendment 16 to the Unit 1 UFSAR. Amendment 16 to the Unit 1 UFSAR is currently scheduled for July 1998.

C. Examples 6, 9, and 10 will be corrected in the next Unit 2 UFSAR amendment (Amendment 11). Amendment 11 to the Unit 2 UFSAR will be submitted in December 1997.

ORRECTIVE STEPS TO AVOID FURTHER VIOLATIONS By FPL letter L-97-180, subject, "Voluntar'y Initiative to Review Final Safety Analysis Reports," dated July 11, 1997, FPL committed to conduct a graded review of the St.

Lucie Updated Final Safety Analysis Reports (UFSARs). As stated in the letter, the UFSAR review eFort and resources are being expended in those areas of greatest safety significance. The review scope includes examination of relevant system documentation and'walkdowns of system critical characteristics. FPL also committed to evaluate the outcome of the UFSAR review and, as necessary, expand the scope of the UFSAR review.

a Two additional FSAR review projects have been undertaken to identify and correct errors in the UFSAR. The first of these projects was a comprehensive review of the UFSAR

~ L-97-274

• Attachment

~Pa e5 against plant operating procedures by a multi discipline task team which commenced in 1996. This review resulted in both procedure and UFSAR changes as appropriate to reconcile identified conflicts between plant operation and the UFSAR descriptions of these activities. This review is complete and all associated UFSAR corrections are scheduled for resolution by February 1999. Secondly, an ongoing review of the fire protection descriptions in the UFSAR is being conducted as a part of the preparation for the spring 1998 Fire Protection Functional Inspection (FPFI).

The following corrective actions were established to prevent recurrence of UFSAR errors:

A. A new style guide has been developed which is undergoing trial use during the current Unit 2 amendment preparation. The style guide provides standards for format and content of UFSAR changes, which should minimize typographical and editorial errors in UFSAR updated packages. These types of errors are associated with a lack of attention to detail in UFSAR amendments. Recent Industry and NRC emphasis related to the Millstone UFSAR issues has greatly heightened the awareness of the need for management and accuracy of the UFSAR update process.

Standardized training has been developed for personnel who perform 10 CFR 50.59 screening activities. Awareness has improved at all levels of the organization with respect to the potential for changes in operating practices to potentially impact the UFSAR descriptions. Plant administrative procedures also now require that all 10CFR50.59 safety evaluations be performed by trained individuals in the Engineering department.

C. The UFSAR update process has been upgraded with more detailed procedural guidance to ensure that all UFSAR change sources are reviewed. New search tools are being utilized which facilitate locating potential UFSAR impacts and increase the accuracy of UFSAR change packages as they are being developed.

These search tools also facilitate checking by the UFSAR update group during preparation of the UFSAR amendments.

5. Full compliance will be achieved with the completion of Amendment 16 to the Unit 1 UFSAR.