ML17229A561

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Discusses Insp Repts 50-335/97-15 & 50-389/97-15 on 971008- 30 & Forwards Notice of Violation Re Failure to Maintain Two Trains of Containment Cooling Operable as Required by TS 3.6.2.1
ML17229A561
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 12/11/1997
From: Jerrica Johnson
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Plunkett T
FLORIDA POWER & LIGHT CO.
Shared Package
ML17229A562 List:
References
50-335-97-15, 50-389-97-15, EA-97-501, NUDOCS 9712300250
Download: ML17229A561 (8)


See also: IR 05000335/1997015

Text

December

11,

1997

EA 97-501

Florida Power

(t Light Company

ATTN: Hr. T. F. Plunkett

President

- Nuclear Division

P. 0.

Box 14000

Juno Beach,

Florida

33408-0420

SUBJECT:

NOTICE OF VIOLATION

(NRC SPECIAL INSPECTION REPORT

NOS. 50-335/97-15,

50-389/97-15)

Dear

Hr. Plunkett:

This refers to the special

inspection conducted

on October

8

- October 30,

1997, at your St. Lucie facility.

The purpose of the inspection

was to review

deficiencies identified in the surveillance

and operation of the Unit 2

containment cooler fans.

Specifically, Florida Power

8 Light Company

(FP&L)

identified,

on October 8,

1997, that in slow speed, i.e., the configuration

during emergency operation,

the 2-HVS-1D containment cooler fan would. rotate

in the reverse direction causing the fan to be unable to fulfillits safety

function.

FPEL later concluded that monthly surveillance tests of the Unit 2

fans

had not been conducted with the fan in slow speed.

The results of the

inspection were sent to you by letter dated

November 6, 1997.

An open,

predecisional

enforcement

conference

was conducted in the Region II office on

December

3,

1997, with member s of your staff, to discuss the violations, the

root causes,

and your corrective actions to preclude recurrence.

A list of

conference

attendees

and copies of the Nuclear

Regulatory Commission's

(NRC)

and FP8L's presentation

materials

are enclosed.

Based

on the information developed during the inspection

and the information

that was provided during the conference,

the

NRC has determined that

violations of NRC requirements

occurred.

The violations are cited in the

enclosed

Notice of Violation (Notice),

and the circumstances

surrounding them

are described in detail in the subject inspection report.

The violations

included:

(1) the failure to maintain two trains of containment cooling

operable

as required by Technical Specification (TS) 3.6.2.1;

(2) the failure

to follow the procedure for a post maintenance test

(PHT) of'ontainment

cooler

fan 2-HVS-1D; and,

(3) the failure to assure that appropriate testing

was identified and performed to'emonstrate

that the Unit 2 containment

cooler

fans would perform satisfactorily while operating in the emergency

configuration, i.e., the slow speed.

The root causes of the violations were

(1) poor communication while performing

a

PHT of the containment cooler fan

resulting in operation of the fan twice in fast speed rather

than once in both

slow and fast speeds

as required by the

PHT procedure,

and (2)

a lack of

oversight or attention to detail

when the surveillance procedure

was

originally written.

97i2300250 97i2ii

PDR

ADOCK 05000335

8

PDR

IIIIIIII///(/////////////((//////////(/

7

FP&L

The

NRC commends the questioning attitude of the Assistant Nuclear Plant

Supervisor

(ANPS) who identified that the containment cooler fans were not

being periodically tested in the configuration that they would operate in

following a safety injection actuation signal.

You should continue to

encourage similar sensitivity to potential

long-term testing deficiencies.

The

NRC recognizes that the potential safety consequence

of the fan

inoperability was low due to the diversity of the containment cooling system.

However, operation of the plant in a condition outside the design basis of the

plant and in violation of the TSs for approximately five months is

a

significant regulatory concern.

The

NRC is particularly concerned that the

monthly surveillance test designed to determine oper'ability of the fans

had

failed, since plant licensing, to incorporate

a critical test requirement.

In

addition, if not for the inquisitiveness of the ANPS, the equipment could have

remained inoperable for

a longer'eriod of time.

The normal

methods of

detecting

and preventing errors from disabling safety-related

equipment

failed.

Specifically, both

PHT and surveillance testing, failed to identify

that the fan was inoperable.

Therefore,

the violations have been categorized

in the aggregate

in accordance

with the "General

Statement of'olicy and

Procedures

for NRC Enforcement Actions" (Enforcement Policy),

NUREG-1600,

as

a

Severity Level III problem.

In accordance

with the Enforcement Policy,

a base civil penalty in the amount

of'55,000 is considered for a Severity Level III problem.

Because

your

facility has

been the subject of escalated

enforcement

actions within the last

two years,'he

NRC considered

whether credit was warranted for Identification

and Corrective Action in accordance

with the civil penalty assessment

process

described in Section VI.B.2 of the Enforcement Policy.

NRC determiried that

credit was warranted for Identification because

your staff identified the

violations.

With regard to the factor of Corrective Action, you formed

a team

to review the event,

determine the root causes,

and develop corrective

actions.

Your long term corrective actions included:

(1) modifying the

surveillance

procedure to test the fans in slow speed;

(2) reviewing other

surveillance tests

against

Updated Final Safety Analysis Report

(UFSAR)

accident

modes of operation;

(3) reviewing the tracking of annunciators

during

safeguards

testing;

(4) training Haintenance

and Operations

personnel

to

reinforce three part communication;

(5) adding clarification for testing

motors with multiple windings to the

PHT procedure;

(6) adding guidance in the

50.59 screening

pr'ocedure to ensure that the reviewer'onsiders

the intent of

the TSs as well as

UFSAR requirements

when revising procedures;

and,

(7) conducting

a vendor

assessment

of the significance of the inoperable fan

cooler.

Based

on the above,

the

NRC determined that credit was warranted f'r

the factor of Corrective Action.

'

Notice of Violation (NOV) and Proposed

Imposition of Civil Penalty in the amount of

$ 100,000

was issued

on January

10.

1997 for violations of the plant security access

control

program, the emergency

preparedness

program,

and requirements for nuclear instrumentation

(EAs96-458 '464,

and -457).

A Severity Level III violation was issued

on September

19,

1996.

associated

with the failure to comply with 10 CFR 50.59

(EA 96-326).

An NOV and Proposed

Imposition of Civil Penalty in the amount of $50,000

was issued

on March 28,

1996, for multiple

violations associated

with a dilution event

(EA 96-040).

An NOV and Proposed

Imposition of Civil

Penalty in the amount of $50,000

was issued

on November 13.

1995, related to inoperable

power

operated relief valves

(EA 95-180).

FP&L

Therefore,

to encourage

prompt identification and comprehensive

correction of

violations, I have been authorized,

after consultation with the Director,

Office of Enforcement,

not to propose

a civil penalty in this case.

However,

significant violations in the future could result in a civil penalty.

You are required to respond to this letter

and should follow the instructions

specified in the enclosed

Notice when preparing your response.

The

NRC will

use your response,

in part, to determine whether further enforcement

action is

necessary

to ensure

compliance with regulatory requirements.

In accordance

with 10 CFR 2.790 of the NRC's "Rules of Practice,"

a copy of

this letter, its enclosures,

and your response will be placed in the

NRC

Public Document

Room (PDR).

Sincerely,

Original Signed by

J.

R.

Johnson

Docket Nos.

50-335,

50-389

License

Nos

~

DPR-67,

NPF-16

Luis A. Reyes

Regional Administrator

Enclosures:

1.

Notice of Violation

2.

NRC Presentation

Haterials

3.

FP&L Presentation

Haterials

4 ~

List of Attendees

cc w/encls:

J.

A. Stall

Site Vice President

St. Lucie Nuclear Plant

6351 South

Ocean Drive

Jensen

Beach,

FL

34957

H.

N. Paduano,

Hanager

Licensing and Special

Programs

Florida Power and Light Company

P. 0.

Box 14000

Juno Beach,

FL

33408-0420

J. Scarola

Plant General

Hanager

St. Lucie Nuclear Plant

6351 South Ocean Drive

Jensen

Beach,

FL

34957

cc w/encls cont'd:

See

page 4

FP8L

cc w/encls cont'd:

E. J.

Weinkam

Licensing Manager

St. Lucie Nuclear

Plant

6351 South

Ocean Drive

Jensen

Beach,

FL

34957

H. S. Ross,

Attorney

Florida Power

8 Light

P. 0.

Box 14000

Juno Beach,

FL

33408-0420

John T. Butler,

Esq.

Steel,

Hector and Davis

4000 Southeast

Financial

Center

Hiami,

FL

33131-2398

Director

Office of Radiation Control

Department of Health and

Rehabilitative Services

1317 Winewood Boulevard

Tallahassee,

FL

32399-0700

Director

Division of Emergency

Preparedness

Department of Community Affairs

2740 Centerview Drive

Tallahassee,

FL

32399-2100

County Administrator

St. Lucie County

2300 Virginia Avenue

Ft. Pierce,

FL

34982

FP8L

Distribution w/encl

1:

PUBLIC

LJCallan,

EDO

HThompson,

DEDR

AThadani,

DEDE

LTrocine,

OEDO

LChandler,

OGC

JGoldberg,

OGC

RZimmerman,

NRR

EJulian,

SECY

BKeeling,

CA

Enforcement Coordinators

RI, RIII, RIV

JLieberman,

OE

OE:EA File (BSummers)

(2

TReis,

OE

EHayden,

OPA

GCaputo,

OI

TMartin, AEOD

HBell, OIG

FHebdon,

NRR

LWiens,

NRR

CEvans,

RII

ABoland, RII

JJohnson,

RII

JJaudon,

RII

Klandis, RII (IFS Action

HWhitener, RII

JMoorman, RII

KClark, RII

RTrojanowski, RII

LWatson, RII

BCrowley, RII

GHopper, RII

letterhead)

Required)

NRC Resident

Inspector

U.S. Nuclear Regulatory

Comm.

7585 South Highway A1A

Jensen

Beach,

FL

34957-2010

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