ML17229A563
| ML17229A563 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 12/11/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17229A562 | List: |
| References | |
| 50-389-97-15, EA-97-501, NUDOCS 9712300256 | |
| Download: ML17229A563 (43) | |
Text
NOTICE OF VIOLATION Florida Power and Light Company St. Lucie Nuclear Plant Unit 2 Docket Nos. 50-389 License Nos.
NPF-16 EA 97-501 During an NRC inspection conducted on October 8
- October 30, 1997. violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
A.
Technical Specification 3.6.2. 1 states that two containment spray trains and two containment cooling trains shall be OPERABLE.
Contrary to the above, between Hay 16 and October 8, 1997, while operating in Modes 1, 2 and 3, one Unit 2 containment cooling train was inoperabl e.
(01013)
B.
10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented procedures of a type appropriate to the circumstances and shall be accomplished in accordance with those procedures.
Maintenance Procedure (HP) 2-0950173, Revision 9, "The Overhaul of Containment Fan Cooler Motors 2HVS-lA, 1B, 1C, 1D (EQ Motors)",
Section 9.9, implements the post maintenance checks of the containment fan cooler motors after maintenance.
HP 2-0950173 requires the fan to be started in slow and fast speed to verify proper blade rotation in each speed.
Contrary to the above.
on Hay 16, 1997, the licensee failed to perform Section 9.9 of Maintenance Procedure 2-0950173 properly in that containment fan cooler 2-HVS-1D was not started in slow speed and proper blade rotation was not verified.
(01023)
C.
10 CFR 50, Appendix B, Criterion XI, Test Control, requires, in part, that a test program shall be established to assure that all testing required to demonstrate that components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in the applicable design documents.
Final Safety Analysis Report Section 6.2.2.2.2 states that the fan coolers operate at a reduced flow of 39,600 cubic feet per minute each, with low speed motor operation during accident operation.
Normal Operating Procedure, NOP-2-2000020, Revision 2, "Containment Cooling System Operation",
which implements monthly surveillance testing of the containment fan coolers, requires that each cooling train fan 97i2300256 97i2ii PDR ADQCK 05000335 8
PDR Enclosure 1
P~
unit be started from the control room and verified that each unit operates for at least 15 minutes, at least once per 31 days.
Contrary to the above, as of October 6, 1997, the licensee failed to assure that all testing required to demonstrate that components will perform satisfactorily in service, in accordance with the requirements and acceptance limits contained in the applicable design documents, was identified and performed.
Specifically, NOP-2-2000020, did not require the containment cooler fans to be tested in slow speed, which is the alignment required during emergency operation.
This procedural inadequacy had existed since initial plant operation.
(01033)
These violations represent a Severity Level III problem.
(Supplement I)
Pursuant to the provisions of 10 CFR 2.201, Florida Power 5 Light Company is hereby required to submit a written statement or explanation to the U.S.
Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C.
20555 with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector at the St. Lucie facility, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation:
(1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results
- achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.
Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response.
If an adequate reply is not received within the time specified in this Notice.
an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken.
Where good cause is shown, consideration will be given to extending the response time.
Under the authority of Section 182 of the Act, 42 U.S.C.
2232, this response shall be submitted under oath or affirmation.
Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction.
If personal privacy or proprietary information is necessary to provide an acceptable
- response, then please provide a bracketed copy of your response that identifies the information that should be protected and a
redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable
- response, please provide the level of protection described in 10 CFR 73.21.
Dated at Atlanta, GA this 11th day of December 1997
PREDECISIONAL ENFORCEMENT CONFERENCE AGENDA ST. LUCIE NUCLEAR PLANT DECEMBER 3, 1997; 10:00 A.M.
NRC REGION II OFFICE, ATLANTA,GEORGIA OPENING REMARKS AND INTRODUCTIONS B. Mallett, Acting Deputy Regional Administrator NRC ENFORCEMENT POLICY A. Boland, Director Enforcement and Investigation Coordination Staff
SUMMARY
OF THE ISSUES B. Mallett, Acting Deputy Regional Administrator STATEMENT OF CONCERNS / APPARENT VIOLATIONS J. Johnson, Director Division of Reactor Projects LICENSEE PRESENTATION BREAK / NRC CAUCUS NRC FOLLOWUP QUESTIONS CLOSING REMARKS B. Mallett, Acting Deputy Regional Administrator Enclosure 2
ISSUE TO BE DISCUSSED Technical Specification 3.6.2.1 requires that two containment cooling trains be operable in Modes 1, 2, and 3.
From May 22, to October 9, 1997, one train of containment cooling was inoperable while the plant was in Mode 1, 2, and 3.
The apparent violation discussed in this predecisional enforcement conference are subject to further review and subject to change prior to any resulting enforcement decision.
ISSUE TO BE DISCUSSED 10 CFR 50, Appendix 8, Criterion V, "instructions, Procedures, and Drawings," requires, in part, that activities affecting quality be performed in accordance with procedures appropriate to the circumstances and that the procedures include appropriate quantitative or qualitative criteria for determining that activities have been satisfactorily accomplished.
On May 16, 1997, Maintenance Procedure 2-0950173, Revision 9, "The Overhaul of Containment Cooler fan Motors 2HVS-1A, 1B, 1C, and 1D" was inadequate in that it failed to require verification of proper rotation of the cooling fan motors.
The apparent violation discussed in this predecisional enforcement conference are subject to further review and subject to change prior to any resulting enforcement
- declslon,
ISSUE TO BE DISCUSSED 10 CFR 50, Appendix B, Criterion XI, "Test Control,"
- requires, in part, that a test program shall be established to assure that all testing required to demonstrate that structures,
- systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.
The licensee failed to properly test the containment cooling fans to demonstrate operable conditions as required by Technical Specification 4.6.2.1.1.a.
Normal Operating Procedure NOP-2-2000020, Revision 2, "Containment Cooling System Operation," used to satisfy the Technical Specification surveillance requirement did not require testing the fan motor 2-HVS-1D in its emergency alignment.
The apparent violation discussed in this predecisional enforcement conference are subject to further review and subject to change prior to any resulting enforcement decision.
yG ItleV~
NRC inspection Report No. 50-389197-15 Pre-Decisional Enforcement Conference December 3, 1997 Atlanta, Ga.
Agenda Opening Remarks J. A. Stall, Vice President, St. Lucie Plant Discussion C. R. Bible, Engineering Manager, St. Lucie Plant W. Korte, Electrical Maintenance Supervisor, St. Lucie Plant Closing Remarks J. A. Stall, Vice President, St. Lucie Plant
Questioning Attitude Results in Self Identification
. Issues TS Surveillance Procedure Inadequacies Motor Rotation Test issues Opportunities For Discovery Strong Corrective Actions TS Surveillance Procedure Changes PMT Enhancements Safeguards Enhancements.
Generic Implications Reviewed Low Safety Significance
Design Bases ENGINEERED SAFETY FEATURES (ESF)
SAFETY INJECTION SYSTEM 4 Safety Injection Tan'ks 2 High Pressure Safely Injection Pumps 2 Low Pressure Safety Injection Pumps PRIMARYCONTAINMENT COOLING SYSTEM 4 Containmenl Cooling Fans 2 Containmenl Spray Pumps SECONDARY COOLING SYSTEM 2 Component Cooling Water Pumps 2 Intake Cooling Water Pumps 2.CCW/ICW Meal Exchangers CONTAINMENTCOOLING SYSTEM (CCS) 4 Cooling Fans 8 CooIing Coils 4 Flow Switches 4 Gravity Dampers 8 Relief Dampers Associated Ductwork CONTAINMENTSPRAY SYSTEM (CSS) 2 Containment Spray Pumps Associaled Piping I Ring Headers Refueling Water Tank Containment Su<np NORMALOPERATION Three Coolers in Fasl Speed to Mainlain Conlainmenl Temperature
<= 120 Degrees POST-ACCIDENT AllCoolers in Slow Speed to Mainlai Conlain<nenl Prcssure and Tcn<perature Requirements
Containment Cooling System Overview Provide Diverse Containment Cooling Method Four Fan Cooler Units Common Ring Header Dual Speed Fans
+ Normal Operation - Three Coolers in Fast Speed to Maintain Containment Temperature
+ Accident Operation - All Coolers Run in Slow Speed on SIAS to Account For Increased Air Density Design Bases Single Failure Results in Two Operable Coolers
TS Surveillance Issue Raised IladeS<
SRO Questioned Surveillance Existing Surveillance Method - Test l'die Fan in Fast Speed During Weekly Rotation
+ Did Not Consider Dual Speed Fans
+ Slow Speed Operation Tested During Safeguards 31 Day TS Surveillance Requirement
+ "Starting each cooling train fan unit from the control room and verifying that each unit operates for at least fifteen minutes."
TS Surveillance Issue
+ TS Does Not Specify Fan Speed During Surveillance
+ Surveillance Procedure Did Not Specify Fan Speed Condition Report initiated
ie N"~lc~~r CP)
Investigation Engineering CR Disposition Concluded That Existing Surveillance Method Inadequate Surveillance Intent of TS Surveillance is to VerifyAll Functions Important to Safety
+ Safety Related Post-Accident Slow Speed Operation
+ Quality Related Fast Speed Operation For TS Containment Temperature Requirements UFSAR Does Not Explicitly Discuss Surveillance
Discovery Timeline 10/4/97 Xa4XkJ4WW 10/6/97 10/7/97 10/8/97 10/9/97 CR Initiated
-Midnight Saturday Monday Morning Ops Management Directs Slow Speed Testing ID Fan Cooler Low Flow Alarm 7 Day ACTION Statement Entered ERT Formed X4~
l Troubleshooting Continues Data Acquisition 1A and 1D Fan Cooler Low Flow Alarms 72 Hour ACTION Statement Entered
, Containment Entry Made 1D Fan Cooler Reverse Slow Speed Operation 1D Fan Cooler Slow Speed Motor Winding Leads Rolled PMT for 1D Fan Cooler Includes AirFlow Measurements 1A Fan Cooler Instrumentation Problem Corrected 1A and -1 D Fan Coolers BIS TS ACTION Statements Exited
~g~ 8 ltCjga Fan Cooler 1D Motor Replacement Fan Cooler 5D Reverse Slow Speed Motor Rotation Error Made During 1997 Refueling Outage Scheduled Motor Replacement Motor Rotation Check Error
+ Procedure Adequate to Ensure Correct Rotation
+ Human Error Resulted In Improper Execution of Procedure
~ No Local Indication
~ Test Relied on Verbal Communication Between Containment And Control Room 31 Day TS Surveillance Issue
+ Slow Speed Operation Not Verified
3 Phase Motors Clockwise Rotation A
Rotation Determined By Phase Relationships A Then B Then C Counter-Clockwise Rotation A
B Vendor Motor Markings Not Useful For Rotation C
B A
Field Routed Three Phase Power Cables C
B A
10
0
Page 20 Gf 23
"-.0 0ETAILE0 PROCEDURE:
(contfnuedj ST. Lucl>> UNt-,2 AZ -'~
~lAil<I <<ANCE PROCES.URE NO. 2ZS=G173 REVISlON g "
RHAUL O< CON: AtNMENTFAil COOL R ~tOTORS 2HVS-1A 1a.
I C. 10 (=0 MOTORSl NF(O 9.C Fcs', installation Che f<
CALI I lON Use e I'emc cafe to pfave.
t ciiy ln)UIj when Yefi yi c pf cef an rotation If1 Cuc i.
1.,".e!ease clcaranc for tes:.
2.
Fequest c"ntrol rooM to:,'ari tihe I Gtcr "r. l in slow speed.
)
Recuest c fit ol fQGMi to stco the fal I c'to(.
Altcw the an I Gtof to c=-accelerate almost to a complete stop beitore rotation vef'IIcation.
4.
Vef'pi that blade rctatlGn:3 coun',e~loc'raise as view'ed ~>>OM the intake/fan hand.
Inii. k~
Date
) /
(( ( 57 Reruest c"ntrol room to s!all ille motcr in fast sI~ced ainid ver'y counter Iockwise rcIation.
6.
Recuest control roon.to 'iop the motor and r~cs',ablish the c!earance.
7.
inform cont ol room wl er. maintenance is cof pleted but tes,ng is required.
8.
Clean up ail wo6: areas asscciat d with r,".Gtor over'ul.
9.
Crew supervisor shall rev' the Oata Sh""'.s to d%ef if motor is r ady for luIih r testing.
Cc.-,pi=-i=-d by ~~~
0K'"
1
- ".evie r>>~ by Da, '2 l(
.i.proved by Cfe"r Supelvlsor oa:= -
'l i I'1
Safeguards Testing Initial Conditions Fan Cooler 1D Out of Service Pending Completion of Flow Switch Post Maintenance Test Motor Available For Actuation Test Safeguards Results Fan Cooler 1D ESFAS Actuation Verified Fan Cooler 1D Low Flow Alarm Not Documented as Safeguards Test Deficiency Weak Documentation of System Functional Status During Safeguards
~o Ht!C(q 199? Unit 2 Outage Timeline Inadequat Psocedure 31 Day Fan Cooler TS Susvelllance PMT Requirement:
Motor Rotation Ghee'k in Both Speeds ESFAS Actuation
- Vesllied, Fan Cooler OOS Human Error Fan Coolers B, C, And D
Placed In OOS Log ID Flow Swilch Removed iD Molos Removed 1D Replacement Motor Installed 10 Flow Switch Reinslalled 10 Motor Rotation Check Peslosmed Saleguards Perlormed Delermlned 10 Flow Switch Installed Incorrectly All Fan Coolers Removed From OOS Log 4/14/97
~
5/I/97 5/4/97 5/9/97 g
5/I 0/97 5/16/97 5/19/97
~~~KhJ'/21/97 5/21/9?
Fan Cooler Out of Service Because PMT Requirements Not Completed
Corrective Actions Procedure Changes TS Surveillance Procedure Revised to Meet TS Intent
+ Concurrent Test of All Four Coolers in Slow Speed
+ Includes Verification of Fast Speed Operation Fan Cooler Motor Overhaul Procedure Enhanced
+ Addendum For Ops In Control Room to Improve Communications
+ Fan Cooler Fast and Slow Speed Functional Check Safeguards Procedure Enhanced to Improve Documentation of Alarm Dispositions Use of Three VVay (.ommunications Incorporated In Continuing Training
Generic Implications No Programmatic Post Maintenance Test Issues Unit 1 Containment Fan Coolers Other Dual Winding Motors Component Types Subject to Technical Specifications Reviewed Most Components Subject to 181/IST, Industry Surveillance Standards, etc.
HVAC Surveillance Procedures Unique
+ No Underlying Test Program/Requirements
+ Pre-Op. Baseline Determined HVAC Surveillance Procedures Susceptible to Not Meeting TS Intent
~ g H(ICJg.
v 5~
Generic Implications Actions Taken HVAC TS Surveillance Implementing Procedures Review Complete
+ Minor Unit 2 Control Room HVAC 18 Month Surveillance Inadequacy Identified On Going Actions Periodic Procedure Review Program
+ All Procedures in Scope
+ Qualified Independent Review For Procedures That Implement TS Surveillances
~ c, 8uc/e Unit 2 Control Room Surveillance Issue 18 Month Control Room Pressurization Test Verify Each Train Capable of Maintaining 1/8 Inch Water Gage Surveillance Procedure Simultaneously Closed Both Trains of Kitchen And Bathroom Exhaust Dampers Negligible Effect on Control Room Pressurization Capability LER In Progress Kitchen Exhaust From Control Room A
Train B
Train To Atmosphere Toilet Exhaust From Control Room
Safety Significance g<$
'OCA Sensitivity Studies Conducted Nlith-One Inoperable Fan Cooler No Effect on Remaining Fan Cooler
+ Reverse Fan Operation Closes Associated Gravity Damper Impact on MSLB Bounded By LOCA Analysis Containment Pressure
Response
+ Small Pressure Increase of 0.5 psig
+ Significant Margin to Both Containment ILRT and Design Pressures Containment Temperature and EQ Response
+ Minor Temperature Increase
+ Existing EQ Profile Bounding
~
~
~o HtK'/gs Safety Significance PSA Insights VVith Failure Probability of One Cooler Set "True" Change in Core Damage Frequency (CDF) -1E-7/yr Change in Large Early Release Fraction (LERF) < 1E-8/yr Overall Change to CDF And LERF Insignificant Defense In Depth Maintained No Impact to Health and Safety of Public
P
Summary Self Identified Deficient 31 Day Technical Specification Surveillance Procedure PMT Process Sound Strong Corrective Actions Low Safety Significance
5 St. Lucie Plant Unit 2 Containment Fan C'ooler 2-HVS-1D Elevation Views 70'-O'ADIUS RING HEADER 63'-O'ADIUS 110'-0" Q60X60 105'-0
~52X50 RD2 jj56 X 56
~ + 75 X 44 BLOW OUT PANEL 92'-0'D2 82'-0 TRANSITION 2 -HVS-1D FAN C356X56 FLOW SWITCH FS.25-2D GRAVITYDAMPER Of45'LENUM 2D2 COOLING COIL o o~o 76'-0'8'-3'7'-5'6'-5'3'-9'1'-6 56'-6'D1 COOLING COIL O
O 47 O gO 45 O4O45 ooo.oo 45 ooo 45 SIDE ELEVATIONVIEW o
45'-0 EL o{5 ooo o og{5o o{4 ohio oo O O O. O O 45. O,O O 45 O O O. O O.45 O FRONT ELEVATIONVIEW (DISCE75770STd.FZ RIJ
C
LIST OF PREDECISIONAL ENFORCEMENT CONFERENCE ATIENDEES December 3
1997 Florida Power
& Li ht Com an FP&L J. Stall, Site Vice President, St. Lucie R. Kundalkar, Vice President, Engineering, FP&L E. Weinkam, Licensing Manager, St. Lucie H. Moran, System Performance Supervisor, St. Lucie C. Bible, Engineering
- Manager, St. Lucie R. Weller, Operations
- Hanager, St. Lucie WE Korte, Electrical Maintenance Supervisor, FP8L C. Guey, Supervisor, Reliability and Risk Assessment, FP8L NRC B. Hallett, Acting Deputy"Regional Administrator, Region II (RII)
J. Johnson, Director, Division of Reactor Projects (DRP), RII J. Jaudon, Director, Division of Reactor Safety (DRS), RII A. Boland, Director, Enforcement and Investigations Coordination Staff (EICS)
~ RII C. Evans, Regional
- Counsel, RII K. Landis, Chief, Reactor Projects Branch 3, DRP, RII J.
Munday, Acting Senior Resident Inspector,
- Robinson, DRP, RII
~L. Weins, Project Manager, Office of Nuclear Reactor Regulation L. Watson, Enforcement Specialist, EICS, RII S. Rudisail, Project Engineer, DRP, RII
- By phone Enclosure 4
4P
/
4 I1'