ML17229A766

This was

completed with the following revision of the

At that time TS

4. 11.2.5. 1 had

a note stating if continuous monitoring of GDTs was

unavailable,

grab samples in accordance

with a table was allowed.

This

table was

no longer found in TS, but had been

moved to the

Approximately one year later.

an administrative

change to TS was

made

that eliminated the note.

Therefore.

whenever both 0

analyzers

in a

unit were unavailable.

the licensee

was unable to meek their TS

survei 1 1 ance requirements.

Second,

Unit 1 had been in this condition at least

once earlier, in

April.

The licensee

had been isolating the gas analyzers

in 'an attempt

at finding the gas leaks.

The licensee

was continuing to research

historical records for other examples.

Third,

up until about a'year

and

a half ago. the licensee did not routinely use their

GDTs.

Standard

~

rocedure

was to vent directly to the stack.

Although not prohibited by

S. this practice

was determined to be undesirable

because it could

result in higher radioactive release

rates.

The licensee

determined that

a TS amendment

was required to return the

TS to its original intent and started processing

the request.

Meanwhile, they have acknowledged that if both 0, analyzers

become out

of service

on

a unit, they would have to vent directly to the stack to

avoid violating the current

TS requirement.

Additionally, the

licensee'as

working on restoring both Unit 2 0, analyzers.

This non-repetitive,

licensee identified and corrected violation is being treated

.as

a Non-

Cited Violation. consistent with Section VII.B of the

NRC Enforcement

Policy,

and is identified as

NCV 50-335,389/98-06-02,

"Failure to

Fulfill a Technical Specification Surveillance

Requirement to

Continuously Monitor Oxygen Concentration in the Gas

Decay Tank."

c.

Conclusions

An inspector

walkdown of the Unit 1 waste

gas

system identified only

minor discrepancies

which were addressed

by the licensee.

An NCV was

identified because of a licensee-identified

non-compliance with the TS

4. 11.2.5. 1 requirement.

This TS for both units had previously been

revised

and administrative errors

made

as part of the revision resulted

in the specification being inadequate.

At the close of the report

period the licensee

was in the process of submitting another

TS

amendment

request.

02:2

Shield Bui ldin

Ventilation

S stem Walkdown

Unit 1

Ins ection Sco

e

71707

The inspector performed

a walkdown of accessible

portions of the Shield

Building Ventilation System.

Additionally, the inspector

reviewed

recent surveillance

records

documenting the testing of the filter train

and the associated

results.

Observations

and Findin s

The inspector

reviewed Section 6.3.2 of the Updated Final Safety

Analysis Report

(UFSAR) and compared it with Technical Specification

(TS), Section 3/4.6.6, to verify adequacy.

Drawing 8770-G-879,

Sheet

2,

was used to perform the system walkdown.

Also, Procedure

1-NOP-25.01,

Revision 0, "Shield Building Ventilation Operation"

was reviewed by the

inspector to verify the system line up.

The inspector noted

a minor discrepancy

regarding the procedural

requirement for the position of FCV-25-13.

Procedure

1-NOP-25.01,

Rev.

0, required that the valve be in the position of NORM/OPEN.

However,

the switch, position on the control panel

was

a "spring return to the mid

position".

This mid position on the switch had no inscription which

could potentially lead to operator confusion.

The inspector

informed

the system engineer of the discrepancy for evaluation.

The inspector

reviewed surveillance

records for the testing of the

shield building ventilation filtering system.

The frequency of test

performance

and the results obtained

met the

TS requirements.

Conclusions

Equipment operability. material conditions,

housekeeping,

and

surveillance

records

were acceptable.

05

05.1

Re uired Postin

s

71707

The inspector verified that all information required

by 10 CFR 19.11

was

posted.

The licensee controlled the required postings with procedure

AP-0010721

NRC Required

Non-Routine Notifications and Reports,"

Revision 38.

The procedure

required

NRC Form 3 and four appendices

from

the procedure

be posted in five areas.

The inspector verified that all

areas

were posted

and that the posted information met all requirements

of Part 19.

The licensee

met all posting requirements of 10 CFR 19.11.

Oper ator Training and Qualification

On-shi ft Tr ainin

of Reactor

0 erator Trainees

Ins ection Sco

e

71707

During this report period the inspector

reviewed the licensee's

on-shift

training program for the reactor operator trainees.

The inspector

reviewed Administrative Procedure

0005721,

Revision 17. "Reactor Control

Operator Training and Qualification", several

On The Job Training (OJT)

guides,

discussed

the program. with several

trainees

and witnessed

training during Control

Element Assembly

(CEA) testing.

Observations

and Findin s

During this report period the inspector often noted that the reactor

operator trainees

on shift were not working in the control

room, but

rather

were studying elsewhere.

The inspector

discussed this with many

of the tr ainees

and concluded that during the time spent on-shift many

. requirements

had to be completed.

OJT guides.

consisting of knowledge

requirements

(questions

and answers),

activities requirements

(locating

equipment

or reading drawings),

and practical

requi rements

(performing

or simulating actual

equipment manipulations)

were to be completed while

on shift.

Nany of the trainees

were spending

a great deal of time

studying procedures

and reviewing plant material related to these guides

outside of the control

room rather than completing the guides

under the

di rection of licensed operators while in the control

room.

The

inspector

noted

on several

occasions. critical activities were completed

without affording the trainees

the opportunity to get involved.

One

example occurred

on Unit 1 when the plant computer

became

inoperable.

Licensed operators

had to perform troubleshooting

on the system,

but did

so without the added benefit of trainee

involvement.

The inspector

reviewed the operator logs to determine

when the trainees actually stood

watch in the control

room and noted that often their names

would not

appear in the logs.

The inspector

reviewed Procedure

AP 0005721,

Revision 17, "Reactor

Control Operator Training And Qualification," and noted that step 8.1.4

stated

"a minimum of 13 weeks

(65 days) shall

be completed

as

an extra

person

on shift in training for the

RCO position.

This training should

include all phases of day-to-day operations activities and shall

be

completed

under

the direct supervision of licensed personnel."

The

07

07.1

07.2

9

inspector verified this to be consistent with existing

NRC regulatory

guidance.

The inspector

expressed

the concern with both Operations

management

and Training personnel

that these

requirements

might not be

getting satisfied.

The licensee stated that the on-shift portion of the

training was intended to be conducted with a trainee standing watch

under the guidance of a licensed operator in each unit's control

room

each shift.

The other trainees

were to witness,

perform or simulate

various activities in the control

room as described

in the G3T guides or

as plant conditions allowed.

Although review of procedures,

drawings

and other technical

manuals

was expected to occur outside the control

room on occasion,

the trainees

were meant to spend the majority of their

time interacting with licensed operators

and their mentor.

The licensee

reiterated

these expectations

with the trainees

and their mentors.

Toward the end of the report period the inspector

noted

much improvement

in the on-shift training.

On April 29, the inspector witnessed trainees

performing

CEA testing.

This is discussed

in section

08. 1 of this

report.

Conclusions

The inspector concluded that reactor operator

trainees

were not spending,

an appropriate

amount of time performing control

room duties

under the

'irection of a licensed operator.

Discussion with the licensee training

staf'f and management

indicated that the reactor operator on-shift

training program was not being implemented

as designed.

The licensee

took action to ensure the required

amount of OJT was provided.

Quality Assurance in Operations

General

Comments

40500

Using inspection procedure

40500 'Effectiveness

of Licensee Controls"

in Identifying, Resolving,

and Preventing

Problems,

an inspection

was

conducted of the licensee's

corrective action program,

operating

experience

review, self-assessments

and quality assurance

(QA). and on-

site/off-site safety review committees.

Generally,

favorable trends

were noted in site activities.

Problem identification was effective.

On-site/off-site safety review committees

provided effective safety

oversight.

However, the corrective action program lacked focus

on

correction of problems.

Several

examples of recent Condition Reports

(CRs) in 1998 indicated that timely corrective action for a 1997

licensee

QA audit concerning corrective action was not effective.

This

was identified as

a corrective action violation.

P

Trendin

Pro

ram

Ins ection Sco

e

40500

The inspector

reviewed the effectiveness

of licensee trend

identification and response.

10

Observations

and Findin s

A list of CRs was reviewed by the inspector.

The

CRs identified

deficiencies in several

areas

including:

procedural

adequacy,

control

and adherence

clearances

fire protection

design drawings

emergency

response

organizational staffing

The use of initiation codes for the analysis of trends

allowed the

licensee to tabulate trends in some areas of human performance

and

equipment related events.

Review of the quarterly trend reports for

1997 indicated adequate identification of trends for that quarter,

and

the trends were consistent with the inspector's

findings.

The inspector

noted that the resolution of significant negative trends identified in

previous reports were not consistently

reviewed in subsequent

reports.

Therefore,

the 'effectiveness

of actions taken

was not evident.

Likewise, the inspector

noted that action items initiated at the request

of management

were not consistently

reviewed

and updated.

The second

quarter trend report indicated that the results

were not presented to

management.

The licensee stated that the issuance of the trend reports

for several

quarters in 1997 had not been timely and that management

had

not always

been briefed on the results.

One trend report was issued

approximately six months after the end of the quarter.

The licensee

related that

a self-assessment

was underway to assist in improving the

effectiveness

of the program.

Discussions with the licensee

revealed that the identification of

repetitive issues

would reside in the trending program as

a result of a

pending

change in the corrective action program.

However, the licensee

indicated that the administration of the trending program was not

covered

by any procedural

guidance.

The inspectors

concluded that

without procedural

guidance the trending program

may lack consistency

and 'become less effective.

Conclusion

The quarterly trend reports adequately identified site trends.

The

effectiveness

of these reports

was diminished by the lateness

of report

issuance

and communication to site supervision.

There was

a lack of

procedural

guidance for trending nonconforming issues.

Problem Identification and Characterization

Ins ection Sco

e

40500

The inspector

reviewed

CRs for adequacy of problem identification and

"

proper characterization

in accordance

with the guidance provided in

Administrative Procedure

AP-0006130.

Revision 12, "Condition Reports."

11

b.

Observations

and Findin s

The inspector

reviewed

CRs and Plant Manager Action Items

(PMAIs)

~

initiated from March 1997 to present.

The inspector determined that the

CR initiation threshold

was sufficient to assure

adequate identification

of nonconforming conditions.

Depending

on the source.

the condition may

be entered into the

CR program or PMAI database.

Certain items.

such

as

the need for procedural

revisions

and

UFSAR discrepancies

changes,

could

bypass the

CR process

and be entered directly as

a PMAI.

The licensee's

program established

characterization

and set the duration

for problem analysis of the issues

based

on severity level

and analysis

technique.

The severity level

was primarily based

on reportability and

operability.

For items requiring reportability or operability

assessments,

a 3-day level was assigned.

Reportability assessments

without operability concerns

were, assigned

a 10-day level.

Issues that

did not require either

an operability or reportabi lity assessment

were

assigned

a 30-day level.

'A fourth level designated

as other, included

any condition that did not meet the 3-day or 10-day criteria but

requi red resolution in less than 30 days.

Typically, the "Other" group

consisted of items that were causing

Node escalation

holds.

The

analysis techniques

used were essentially either

an "investigate

and

correct" or some form of a root cause analysis.

The inspector

reviewed the characterization

of selected

CRs.

The

inspector noted that many repetitive issues

were not assigned

root cause

evaluations.

Examples of these

are as follows:

CR 98-178 repeated

CR 97-383

CR 98-112 repeated

CR 96-2531

, CR 97-2301

was canceled

due to corrective actions

proposed for CR

97-2287

CR 97-1229 repeated

CRs 97-1091

and 97-395

These are discussed

in more detail in paragraph

07.6.

According to AP-0006130,

a

CR could be closed without completion of the

proposed corrective actions.

The proposed corrective actions were

entered into the

PMAI tracking program.

Control

and scheduling of PMAIs

were performed in accordance

with Administrative Procedure

AP-0006129.

Revision 7,

"PMAI Corrective Action Tracking Program."

The PMAIs

prioritization was based

on the

PNAI completion dates.

Most PMAI due

dates

were provided

by. the implementor.

Procedure

changes

or cr'eations

were not assigned

a due date but were requi red to be completed within 16

months with a priority for completion based

on the type of procedure

change.

Deficiencies related to the timely implementation of procedure

in Section 07.6.

The licensee

had several

different ways that

a

CR and the resultant actions could be classified.

The inspector

concluded that the actual significance of issues

could not

be easily determined

using the licensee's

method of characterizing all

issues

as Severity Levels requiring resolution in either

3 days,

10 days

or 30 days.

For example,

CR 98-'0029 documented that the security entry

12

gates did not always

open after the hand reader identified a person.

Occasionally,

the person

needed to reperform the entry procedure.

CR

98-0053 documented

a leaking Safety Injection Tank drain or fill valve

causing the Refueling Water Tank return header

and the Hot Leg Injection

return header

to pressurize.

Both of these

CRs were identified as

30

day severity levels.

Unless there

was

an operability or'reportability

concern

a 30 day Severity Level was assigned.

The inspector

reviewed the problem analysis for more than

100

CRs and

noted that the quality of the analyses

varied.

Among CRs

requi ring

root cause analysis,

those

CRs prepared

by individuals who had received

some form of root cause training were generally of better quality.

The

condition descriptions

for the

CRs reviewed were complete

and the cause

identified was supported

by facts gathered

during the investigation.

Conclusion

Problem identification was determined to be effective.

However,

repetitive issues

were not consistently

assigned

root cause evaluations.

The Severity Level designation

did not necessarily

indicate the actual

significance of the

CR.

Although the

PMAI process

was designed to

assign

due dates

based

on significance,

the inability to differentiate

significance

between

CRs hindered this process.

The inspector

considered this

a weakness- in prioritizing corrective actions for

identified problems.

Ade uac

of Corrective Action Pro

ram

Ins ection Sco

e

40500

The inspector

reviewed the most recent Quality Assurance

(QA) audits of

the,licensee's

Corrective Action Program

(CAP).

The inspector verified

that the scope

was adequate,

the investigation

was appropriate,

and the

conclusions

were well founded.

Additionally, the inspector

reviewed

seventeen

selected,

safety-significant Significant Condition Reports

(SCRs) for proper administration,

adequacy of analysis

and root cause

evaluations.

and appropriateness

of corrective actions.

Observations

and Findin s

The licensee's

QA organization

completed their audit QSL-CA-96-20,

"Corrective Action Functional Audit" on February

14,

1997.

The audit

identified eight findings that

QA stated indicated

a continuing weakness

in the corrective action program.

Overall. the inspector

found the

audit to be well performed.

The findings were documented with

substantiating

facts,

and the scope of the audit was appropriate.

The

weaknesses

identified by QA were limiting the effectiveness

of the CAP.

Section 07.6 discusses

further details of these findings and the

licensee's

attempt to correct these deficiencies.

The primary method of problem identification was the

CR.

As defined in

Administrative Procedure

AP-0006130.

Revision 12, "Condition .Reports,"

13

the program allowed any person working within the Florida

Power

8 Light

(FPL) Nuclear program to identify any problem or potential

problem to

the company, for resolution.

A subset of the

CR system

was the

SCR

system.

An SCR would be issued in response to a more serious condition

that would require

a higher level of management's

attention (for example

off-site notifications,

Emergency

Plan Activations, Technical

Specification required shutdowns, etc.).

The events that would require

an

SCR were defined in both AP-0006130

and ADM-17.02. Revision 13,

"Significant Condition Report Summaries."

The inspector

reviewed

17 safety significant SCRs.

The inspector

had

the following observations:

~

All SCRs reviewed

had been appropriately assigned

SCR status

as

defined by the licensee's'procedures.

~

The Root Cause

Evaluations for these

17

SCRs were assigned

according to Appendix 2 of AP-0006130.

~

Level'

Root Cause Analyses were well performed, well documented,

and appeared to identify all appropriate root and contributing

causes.

~

Overall.

Level

2 Root Cause Analyses were significantly less

formal.

The inspector

had difficulty in ascertaining if all root

causes

had been identified with a Level

2 Root Cause Analysis.

A

Level

2 Root Cause did not differ significantly from an

"Investigate

and Correct" analysis.

The licensee stated that they

had identified this and stopped

performing Level

2 Analyses.

~

All corrective

actions identified in SCRs were either completed or

properly tracked

by a PMAI;

~

All corrective actions

assigned

were appropriate, for the

identified root causes.

Also, the inspector

reviewed the licensee's

system to identify and

correct operator

workarounds.

The licensee actively tracked all

'orkarounds

via the

PMAI system.

At the time of the report the licensee

had seven

open items, all of which had been evaluated to correct.

Five

had work scheduled in the near future.

Periodically, the licensee

asked

the operators to reevaluate their job tasks

and determine if a

workaround might exist.

c.

Conclusions

The SCRs reviewed by the inspectors

were appropriately dispositioned.

The inspectors

noted

good Level

1 Root Cause Analyses

performed

by the

licensee's staff.

Lower grade evaluations

were noted to be mixed in

their quality.

Corrective actions

were appropriate for the identified

root causes

and the actions

were either completed

or transferred to

PMAIs before closing out the packages.

Additionally, the inspector

14

07.5

found the Operator

Workaround process effective in identifying and

correcting these deficiencies.

0 eratin

Ex erience

Pro ram

Ins ection Sco

e

40500

The inspector

reviewed the licensee's

Operating

Experience

Program,

and

evaluated the program's. effectiveness

in receiving, evaluating.

and

dispersing

information for use in the plant.

Observations

and Findin s

The inspector

reviewed the procedure

ADN-17.03. Revision 11, "Operating

Experience

Feedback" to determine the licensee's

requirements

for the

program.

The inspector

found the procedure to be general

in nature,

but

all requirements

were being met by the program.

.The inspector

reviewed the information that the Operating Experience

Administrator was putting into the corrective action program and found

that it was timely and usually beneficial.

The administrator

used the

personnel

resources

in the plant effectively to determine the

applicabi lity to the faci lity.

The inspector

noted that. typically, the

administrator

accessed

Part

21 notifications,

Information Notices.

Generic Letters

and industry information within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of issuance.

The information was processed

and filtered for usefulness

in a timely

manner.

In February

1997,

QA identified

a backlog of items from

December

1994 to Hay 1996 that had not been reviewed for applicability

or distributed to the plant.

This backlog had been worked off.

The inspector

reviewed

a sampling of the information forwarded to the

lant.

Generally, the appropriate divisions were given the information.

he division supervision further filtered the information and passed it

on to the worker level.

The workers felt that most of the information

was useful,

however, they also believed that there might be more

beneficial information available.

The workers interviewed believed that

the information reached

them in a timely fashion.

The inspectors

also

noted

a significant population of CR responses

included Operating

Experience information in them.

. Conclusions

The Operating

Experience

Program

was effective.

Information distributed

to the plant was generally timely and useful.

The backlog identified by

QA in 1997 had been worked off.

15

Self-Assessment

Ins ection Sco

e

40500

The inspector

reviewed the licensee's

selt-assessment

activities

including the site

QA assessment

activities.

Observations

and Findin s

Self-Assessment

A self-assessment

program was started at the site about two years

ago.

Administrative Procedure

ADH-11.05. Revision 0. "Self-Assessment

Procedure,"

provided the guidance for the self-assessment

program..

This

program required that each department

perform

a quarterly self-

assessment.

The inspector

reviewed the tracking and assessment

system

used

by the

program owner for self-assessments.

Nore recent self-assessments

were

assigned

a grade from zero to 100.

Each of the quarterly grades

was

tracked

by department.

The quality monitoring of the self-assessment

was self-critical.

Noteworthy was the review of a third quarter self-

assessment

done for fire protection which was given

a grade of only 20.

The assessment

was limited in that it only looked at emergency lighting

and did not assign corrective

action for the findings.

The inspector

concluded that this program was effective in providing feedback

on the

quality of the selt-assessments.

The inspector noted that the self-assessment

procedure did not require

an annual or periodic site-wide self-assessment.

The last site-wide

assessment

was performed in 1996.

No further site-wide assessment

was

planned at the time of the inspection.

~iit

A

The inspector

reviewed

an audit conducted

by QA of the site corrective

action program.

This audit started in October

1996 and was completed in

February

1997.

The inspector

reviewed the audit,

QSL-CA-96-20.

and

responses

to the audit.

This audit identified eight significant

noncompliances

with corrective action procedures.

The audit also

discussed

that stronger support of the corrective action mechanisms

must

be provided by the plant management

team at all levels.

The audit findings were:

CR reportabi lity review practices

were deficient in that failure

to identify two reportable conditions occurred.

Corrective Action processes

did not properly address

actions to

prevent recurrence of conditions adverse to quality.

16

Nonconformances

were not being evaluated

and classified

consistently in CRs.

h

A procedural

noncompliance

resulted in deficient review and

approval practices for corrective action documents

in a

significant number of cases.

~

A procedural

noncompliance

resulted in improperly validated

software being used to control

mode restriction items

on PHAIs

~

A lack of "attention to detail" resulted in corrective action

records containing insufficient detail to recreate

the actions

taken.

~

An ineffective management

of conditions

adverse to quality

resulted in delayed evaluations.

disposition,

and implementation

of corrective actions.

~

An effective Operating

Experience

Feedback

(OEF) Program

had not

been

implemented at St. Lucie.

This was

an effective

QA audit identifying substantive

issues with the

licensee's

corrective action program (CAP)., It should

be noted that

improvements to the

OEF Program were observed

and are discussed

in

section 07.5. of this report.

The inspector

also reviewed the

QA quarterly reports.

These reports

provided self-critical assessm'ents

and wer e used

as the basis

for the

site performance

windows report.

The windows report was

a one page.

color-coded display of the various departments'erformance

for several

quarters.

The

QA audits

and quarterly assessments

provided effective

self-critical reviews of plant activities.

However, during the review of many recent

CRs (1998), the inspector

found that the corrective actions for the previous

QA audit of the

corrective action program were not effective.

Correction of problems

was not timely and similar problems

found in the past

QA audit were

still occurring.

The corrective action program lacked focus

on timely

correction. and preventing repetition of previous problems.

Accordingly.

this was identified as

a violation of 10 CFR 50 Appendix B, Criterion

XVI, Corrective Action.

This violation was identified as

VIO 50-

335,389/98-06-03.

"Corrective Action Program

Lacks Focus

on Correction

of Problems",

and contained three examples.

Quality Assurance

documented in CR 98-0635 that

PMAIs issued

as

CAP

corrective actions for 29 procedure revisions

had been

open since

1996.

Further investigation

by the inspectors identified fifteen of the

Condition Reports

as potentially affecting the operation of safety-

related equipment.

Nine of those

CRs were determined .to be more than

"human factors" upgrades

and would add to the substance

of the

procedure.

These nine

CRs

(CR 96-1065,

96-1341.

96-1789,

96-1792,

96-

1865,

96-2065,

96-2189,

96-2311,

and 96-2768)

each

had at least

one

e

17

procedure

change related

PMAI outstanding.

The inspectors

reviewed,

in

detail, six of the nine

CRs (96-1065,

96-1789,

96-1792.

96-2065.

96-

2311,

and 96-2768),

and noted several

items of interest.

~

Every

PMAI issued in response to these

CRs was originally assigned

a due date before September

30,

1997.

Most were assigned

due

dates

before January

31,

1997.

The PMAIs were transferred to the

Procedures

Group in mid January

1997.

~

When transferred to the Procedures

Group, all of the

PMAIs were

. given

a priority of either

1 or 2.

These priorities superceded

the due dates.

However, the assigned priorities indicated that

the licensee did not believe that these

were the lowest level

priority procedure

changes.

~

One

CR (96-1792)

was dispositioned with a recommended

procedure

change to prevent

a loss of charging

and letdown during

maintenance.

Another

CR (96-2768)

was dispositioned with a

recommended

procedure

change to address

aligning the control

room

ventilation system following an auto start,

as described in the

The existing procedure did not agree with the

conditions adverse to quality

As of

the end of the report period, the changes

were still pending

issuance.

Criterion XVI of Appendix

B 'to 10 CFR 50 requi res the licensee to have

measures

"established to assure

.

. are

promptly identified and corrected."

On January

17,

1997,

Revision

5 of

procedure,

AP-0006129,

"PMAI Corrective Action Tracking Program."

added

a requirement for closure of all procedure

change related

PMAIs within

16-months.

Although the 16-month requirement to close

a procedure

was

not in place

when the subject

PMAIs were issued,

the licensee did not

properly track these corrective actions

and ensure

implementation

was

completed in a timely manner.

This is the first example of VIO 50-

335,389/98-06-03.

Quality Report 97-2271

and related

CR 98-0043 identified multiple CRs

with unsatisfactory

responses.

The

QA audit of 29

CRs found five CRs

inadequately dispositioned,

in that the corrective actions were not

adequate to correct the conditions.

This sampling of CRs indicated that

about one-sixth of CRs audited were unsatisfactory.

These issues

were

similar to a 1997 finding in QA Audit QSL-CA-.96-20 that was documented

in CR 97-282.

Although each of the individual

CRs were eventually

adequately dispositioned,

the licensee

had not yet fully address'ed

the

root causes

for the inadequate

dispositions.

The licensee

had failed to

ensure that

a significant condition adverse to quality (multiple

assignments

of inadequate

corrective actions to CRs)

was adeguately

corrected.

This is identified as the second

example of VIO 50-

335,389/98-06-03.

Additionally, Root Cause evaluations

were not -performed

as requi red by

site procedure.

Step 8.5.5 of AP-0006130,

stated that

a Root Cause

Analysis was requi red for those significant events listed in Appendix 6

18

of the same procedure.

Appendix 6 listed,

among other items,

inadequate

10 CFR 50.59 reviews/evaluations/screens.

QA Audit QSL-CA-96-20

identified multiple instances

of improperly assigned

problem analyses.

including examples

involving inadequate

50.59 reviews

and repetitive

equipment fai lures.

which were not investigated with a root cause

analysis

as required

by the licensee's

procedure.

The licensee's

response to the audit finding stated that Appendix 6 was provided as

guidance

and adherence

was not

a requirement.

It further stated that

a

certain

amount of human judgement

was involved in the assignment of an

evaluation level.

Since the audit,

QA identified in CR 98-043

a

condition in which a

10 CFR 50.59 screening

had not been performed

as.

required

by site procedures.

Likewise. the inspectors

i,dentified that

CR 98-0346 was written because

a Temporary System Alteration was

installed without a 10 CFR 50.59 screening.

Both .CR 98-043 and

CR 98-

0346 were not investigated with a root cause analysis

as required

by AP-

-0006130.

However,

NRC review of these

CRs verified that

a full 10 CFR 50.59 safety evaluation

was not required in either case.

Also.

NRC

regulations

do not require

a

10 CFR 50.59 screening.

Therefore,

the

inspectors

concluded that the lack of 50.59 screenings

in these

instances

was of minor significance

and is not subject to enforcement

action.

Additionally, the inspectors identified an example of a repeat

problem

concerning periodic procedure

reviews.

CR 96-2531 identified that 65

procedures

did not receive

a periodic review as required by QI-5-PSL-1,

Revision 7, "Preparation,

Revision, Review/Approval.0f Procedures".

and

Technical Specification 6.8.2.

CR 98-0112 again identified that

183

procedures

had not been reviewed

as required.

Appendix 6 of AP-0006130

required

a root cause evaluation to be performed for QA program

breakdowns,

such

as failure to follow verbatim compliance with

procedures.

Although this condition represented

a repetitive problem

resulting in a failure to implement the Quality Instruction,

a Root

Cause evaluation

was not identified as necessary

and was not performed.

The inspectors

concluded that these

examples

represented

multiple

failures by the licensee to perform Root Cause evaluations

as requi red

by the site procedure.

This is identified as the third example of the

VIO 50-335,389/98-06-03.

c.

Conclusions

The site self-assessment

program conducted quarterly and department

audits were of mixed quality.

Self-critical monitoring of these

assessments

was driving improvements in the process.

The site

QA audits

and quarterly reports provided self-critical reviews of plant

activities.

However. corrective actions for a

QA audit of Corrective

Action Program were not effective.

Recent

CRs dealing with

unsatisfactory

and untimely corrective actions were identified.

These

issues

were identified as

a corrective action violation.

19

On-Si te/Off-Si te

Commi ttees

Ins ection Sco

e

40500

The inspector

reviewed the on-site safety committee

and off-site

committee activities that were available during the period.

Observations

and Findin s

Off-Site

The inspector

reviewed the functions of the Company Nuclear

Review Board

(CNRB).

The requirements for the

CNRB are specified in TS 6.5.2.

The

inspector

reviewed the meeting minutes for meetings

440-451 covering the

time period of January

21,

1997. to January

29,

1998.

Each of the

meeting minutes indicated the members

and alternate

members

present.

Compliance with TS requirements for attendance

was verified.

The inspector

verified that required items were reviewed such

as safety

evaluations,

TS changes,

violations, Licensee

Event Reports

(LERs).

and

minutes of the Facility Review Group (FRG).

No deficiencies or problems

with TS compliance were identified.

Heeting

number

448 conducted

November 25,

1997,

addressed

the site plant

manager's

report and

a review of plant performance for 1997.

This

report reviewed

a 1996 site-wide self-assessment.

Weaknesses

were

identified and

a list of indicators tracked to determine the

.

effectiveness

of corrective actions for the weaknesses

was presented.

The inspector

reviewed this report and noted

an overall positive

improvement in plant performance.

This was evident by a declining trend

in the number of overdue

CRs, control

room instruments out-of-service,

reduction of backlogs,

and other items tracked.

The inspector

noted

a unique system termed the "ear ly warning

indicators."

The early warning system

was

a set of 25 indicators

used

as precursor indications of future plant performance.

These indicators

were monitored to enable early detection of negative

performance

so that

corrective actions

may be taken prior to experiencing

a significant

decline in plant performance.

The inspector noted that the overall

trend for the site was positive except for overtime hours.

This was

previously identified

a repeat

problem and an

NRC violation.

From the meeting minutes of the

CNRB, it was apparent that the reviews

conducted

were rigorous, challenging,

and conformed to TS requirements.

The use of early warning indicators

was

an enhancement

to the safety

review process.

On-Site

The inspector attended

an

FRG meeting

on April 14,

1998.

This meeting

focused

on the TS requi rement for FRG to review procedure revisions.

Thirty items were reviewed.and

one item was not approved.

The inspector

08

08.1

20

observed excellent

feedback to the sponsor of one procedure revision for

the quality of the 50.59 screening

review.

The inspector

reviewed compliance with the TS 6.5. 1 concerning the

requirements

for Facility Review Group

(FRG).

The quorum membership,

member disciplines,

meeting frequency,

and responsibilities

were

reviewed

and no problems

were identified.

FRG meeting minutes were

promptly available after the meeting.

The inspector

reviewed

FRG

minutes for meeting

number

98-088 held on April 14,

1998,

and

a follow-

up meeting,

number

98-090,

conducted April 15,

1998.

The follow-up

meeting

was held to approve

a change to the administrative procedure

AP-

0006130,

"Condition Reports," to transfer responsibility for CR review

and closure to line managers.

This change also deleted the requirement

to review CRs for repeat conditions.

This was done to provide

consistency

between the

FPL sites at the direction of senior management.

The inspector also reviewed recent guidance dated April 7,

1998.

entitled "Conduct of the FRG."

This guidance

reduced the

FRG membership

from 40 to 19 members in order to achieve consistency.

Also. noteworthy

guidance

was that each item presented

to FRG had

a sponsor.

The

FRG

chairman,

members,

and sponsor 's responsibilities

were specified

on

a

chart in the

FRG room.

This guidance

was seen

as enhancements

to the

process.

Conclusions

The off-site/on-site safety review groups provided an effective

oversight of TS required activities.

The use by the

CNRB of early

warning indicators

was

an innovative'approach

to detecting plant

problems.

Recent

changes

made to the

FRG meetings

were enhancements

to

their review process.

Hiscellaneous

Operations

Issues

Control

Element Assembl

CEA

Periodic Exercise

Ins ection Sco

e

61726

The inspector

observed portions of the performance of Procedure

OP 1-

0110050,

Revision 35, "Control Element Assembly Periodic Exercise."

Observations

and Findin s

On April 29, the inspector witnessed the Unit 1 Control

Room operators

exer cise seven

CEAs in accordance

with the aforementioned

procedure.

CEA movement

was actually performed by operators

in license training.

The activity was directed

by a licensed operator

and was overseen

by the

Assistant

Nuclear Plant Supervisor.

k

The inspector noted good use of three-part

communication

by the

participants.

The control

room was quiet with other activities kept to

a minimum during the surveillance.

The ANPS was noted to have provided

21

advice to the trainee

based

on personal

experience.

Overall control of

the evolution was considered to be excellent.

The inspector verified the procedure

was the proper revision and was

being adhered to.

Conclusions

The inspector considered

the operator performance of a surveillance

of

control element

assemblies

to be excellent.

The control

room was quiet

with little other activities or traffic.

Oversight of operators

in

training during this evolution was also excellent.

Conduct of Haintenance

II. Maintenance

Work Order Plannin

and Control Of Troubleshootin

Ourin

Maintenance

Ins ection Sco

e

62707

The inspector

reviewed

numerous

Work Orders

(WOs), focussing

on the

quality of planning. to verify that maintenance

troubleshooting

activities were being properly controlled and documented.

Additionally.

the associated

procedures

were also reviewed.

Observations

and Findin s

The inspector

reviewed the licensee's

procedure for the processing,

planning,

and working of WOs, ADN-0010432. Revision 18, "Control Of

Plant Work Orders."

In addition, the inspector

reviewed the licensee's

procedure for the control of maintenance

troubleshooting activities,

GMP-21 'evision 2, "Troubleshooting Process."

The inspector

randomly selected

eight

18C

WOs to review the level

and

adequacy of planning.

The inspector noted that seven of the

contained

a step to troubleshoot

and repair the associated

equipment.

The seven

WOs were;

9800495901,

9702586501,

9702112501,

9702619801,

9800347601,

9800499301

and 9702325101.

However,

none of the

contained the required troubleshooting

documents

requi red by GMP-21.

The approved planning of the

WOs would typically state

1) Investigate

the reported

problem.

2) Repair/Replace

as necessary

the affected

components.

3) If required, troubleshoot/repair

associated

components

as

directed

by supervision

using

GMP-21 and vendor technical

manuals

as

reference

as necessary.

The inspector

reviewed

GMP-21 and noted that it required

a formal step-

by-step troubleshooting

plan be developed,

however.

none of the

reviewed contained that documentation.

The inspector discussed this

issue with Maintenance

supervisors

who stated that

GMP-21 was not

actually used.

The step

was written into WOs as

a contingency to be

22

used if necessary.

The

WOs had been completed

as skill of the craft and

did not requi re the use of the documents

described in the

GNP.

The

licensee

provided several

examples of troubleshooting

WOs and the

inspector verified the appropriate

documents

were included in the

package.

The inspector concluded that GNP-21 was

an excellent tool in developing

work instructions for troubleshooting

equipment

problems.

The procedure

requi red

a logical sequence

of thought

and observation prior to actually

commencing work. It also provided for an adequate

amount of review and

oversight during the process.

One

WO reviewed

by the inspector,

9800499301,

written to rebuild the

plant vent stack sample

pumps,

contained only minimal instruction.

The

planning stated to remove the pumps from the skid and refurbish,

sending

it out to the vendor for rebuild if necessary.

Although the pumps were

safety-related,

the

WO contained

no guidance

on how to perform the

actual

refurbishment.

The inspector discussed this with the licensee

who stated that the planning was misleading.

The pumps did not get

refurbished,

but actually were replaced.

The

WO controlling this

activity was used to replace these

pumps

on

a regular basis

as part of a

,

preventive maintenance activity.

The practice of refurbishing the pumps

was discontinued

and the

WO was never revised.

The licensee

revised the

WO to more accurately reflect the maintenance activity.

The inspector

reviewed ADN-0010432, Revision 18, "Control Of Plant Work

Orders."

Step 7.3.2.0,

stated that "if a work task requires direction

beneath

the level of detail that is available with specific procedure or

technical

manual

guidance,

the work may be performed at the di rection of

and with direct oversight by the Maintenance Supervisor

(having

appropriate technical

assistance

when necessary)....."

Two restrictions

associated

with this step were:

1) Stay within the scope of the

WO or

'rite a scope

change,

and 2) Use GNP-21 when performing troubleshooting

activities.

The inspector discussed, the meaning of this step with

various maintenance

workers and supervision.

.A large percentage

of

workers interpreted this step

as providing authorization for work to be

conducted without a procedure

provided oversight

was provided by a

supervisor

.

The inspector noted that to do so would bypass the various

reviews necessary

to ensure the activity could be safely accomplished.

Additionally, work on equipment

such

as safety related,

seismic,

or fire

protection required

procedures

that had been reviewed by the Facility

Review Group.

The inspector

discussed this issue with Haintenance

supervision

who

stated that the intent of the step

was to limit the work accomplished

at

the direction of the supervisor to minor maintenance

or skill of,the

craft activities.

The licensee

revised the step in Revision

20 of the

procedure.

The inspector

concluded that

a large portion of ISC work, by its very

nature,

involved troubleshooting.

It was

a routine practice to plan

a Foreign Material Exclusion

with a heavy reliance

on skill of the craft and supervisory oversight.

23

WOs were written to include

a step to allow troubleshooting, if needed.

However, the inspector

found few examples

where it was used.

The

troubleshooting activities were generally determined

by the maintenance

worker in the field and his supervisor

as the job progressed

and were

considered skill of the craft.

In the cases that were considered

beyond

skill of the craft, written instructions

were provided.

The inspector

did not identify any examples of work which had been performed

inappropriately.

Conclusions

The inspector concluded that the licensee's

method of WO planning was

adequate.

but placed

a heavy reliance

on the skill of the maintenance

worker and supervisory oversight.

The inspector did not identify

examples

where this reliance resulted in inadequate

work.

In addition,

the inspector

concluded that GAP-21 provided

an excellent tool

developing work instructions

and controlling troubleshooting of

equipment

problems.

En ineered

Safe uards

Rela

Test

Unit 2

Ins ection Sco

e

62707

The inspector

observed portions of OP 2-0400053,

Revision 27.

"Engineered

Safeguards

Relay Test."

Discussions

were held with

maintenance

workers, control

room operators,

and supervisors.

Observations

and Findin s

The inspector

observed the preparation

and set-up for the performance of

Safety Injection Actuation Signal,

Containment Isolation Actuation

Signal,

and Containment

Spray Actuation System

Channel

A, Group

2

testing.

The inspector

reviewed the procedure in use by the maintenance

workers

and found it to be the correct procedure

and the current

revision.

The knowledge level of the operations

personnel

and

technicians with regard to the procedures

was verified by the inspector

through questioning

and found to be good.

While the

I&C technicians

were performing

a dry run to verify and label

all terminal

board test points,

a discrepancy

was found in the

procedure.

The technicians

found the discrepancy

as

'a result of the'ry

run while .comparing the terminal

board wiring with the drawings

and

procedure.

The procedure,

a first time use procedure,

incorrectly

identified

a terminal board test point location.

The licensee

backed

out of the procedure

so that

a temporary change

(TC) could be made to

the procedure prior to continuing with that portion of testing.

The

inspector

observed

the. performance of the restoration

and verification

steps

by operations

personnel

and found it to be performed properly.

While observing the test.

the inspector identified a void in the fire

barrier on the control

room floor inside the east

"SA" safeguards

0

M2

H2.1

24

E

cabinet.

The inspector could not see if the void extended

completely

through the floor.

This void was brought to the attention of the

licensee.

A fire breach permit was initiated and

CR 98-0723 generated.

The licensee will determine the extent of degradation of the fire

barrier during the next outage of sufficient duration to de-energize

the

cabinet.

Conclusions

The experience

and thoroughness

of the maintenance

and operations

personnel

helped identify a procedural error involving the testing of

safety components.

The inspector

concluded that the correct actions

were taken when the error

was identified.

The actions that were taken

were properly performed.

Maintenance

and Material Condition of Facilities and Equipment

4

Safet

Maintenance

Ins ection Sco

e

62707

The inspector

reviewed the maintenance

history of multiple safety-

related recorders for the time period July 1,

1997 through April 30,

1998.

The inspector

reviewed the records for common failures and

problems, timely repai rs,

and documentation of work.

Observations

and Findin s

The inspector

reviewed greater than

100 safety-related

work orders for

control

room chart recorders.

The vast majority of these

work orders

were preventive maintenance

(PH) items

as prescribed

by the various

recorder's

Technical

Manuals

and as described

by the applicable

18C

rocedure.

Any recorder that provided an indication required

by

echnical, Specifications

(TS) was clearly identified within the work

scope

as being

a

TS required instrument.

For example,

Work Order 98007109,

which would perform the midpoint calibration check for the

Auxiliary Feedwater

Flow Indication, identified this

PH as partially

satisfying

TS 3.3.3.6.

The inspector identified no problems with the

PH

documentation.

The inspect'or also reviewed approximately twenty work orders identified

as "Trouble and Breakdown."

Nearly all these

work orders

were performed

to correct

a recorder failing to advance,

a recorder

spiking,

a recorder

indication fai ling to change.

or a recorder fai ling to ink.

The

inspector identified no clear,

recurring problems with any individual

recorders.

Parts

were available for recorder

repair within a few weeks.

However, several

maintenance

workers

and work control personnel

did note

that the age of the recorders

was making parts

replacement

more

difficult with time.

The inspector did note that.

on average.

the licensee

would fix the

safety-related

recorders

four to six weeks after

a problem was

25

identified.

Conversations

between

personnel

in Work Control

and the

inspector

suggested

that this was expected.

The licensee

has

adopted

a

thirteen-week

maintenance

schedule.

Administrative Procedure

ADM-

0010432.

Revision 18, "Control of Plant Work Orders"

ranked work based

on the plant's

needs.

Emergency

Work was classified

as work that must

be started

immediately.

Examples of this type of work were the

following:

TS 3.0.3 related fai lures

Unidentified steam or through wall leaks

Unplanned unit load threats

Potential for major equipment

damage

Degrading equipment condition with the potential for

significant consequences

The next level of significance included work that should

be started

within two weeks.

This category included the following:

~

A severe threat to personnel

safety

~

An actual

load limit greater than one megawatt

~

Event Response

Team support

~

TS Limiting Conditions for Operation with a unit shutdown in

less than

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or

NRC notification

~

Control

Room nuisance

alarms

~ 'lant General

Manager Directive

The third level of work would be performed

between

two and seven

weeks.

Examples of this type of work included:

~

A worsening condition affecting component operability

~

Equipment

needed

regardless

of system work week

~

A condition adverse to Maintenance

Rule availability impact

~

Drip pockets

~

Control

Room deficiency tags

All other work would be scheduled after seven

weeks.

The inspector

discussed

these procedural

requirements

with Work Controls

personnel

and questioned

the advisability of delaying work on safety-

The licensee

asserted

that this plan met all

regulatory requi rements,

allowed proper prioritization of work. and

allowed efficient use of thei r maintenance

workers.

c.

Conclusions

The inspector concluded the safety-related

recorder

maintenance

program

was able to maintain the equipment operable despite the aging of the

recorders.

Finding replacement

parts for these

recorders

has not yet

impacted the program.

The licensee

was following their program to

schedule repair of non-functioning recorders.

26

Miscellaneous

Maintenance

Issues

Closed

VIO 50-389/97-05-01

"Fai lure To Control Forei

n Material

Enterin

and Exitin

The Unit 2 Containment-

92902

This violation occurred

as

a result of not controlling the Unit 2

containment

as

(FNE) area

as required

by

procedure.

An inspection identified incomplete logs of equipment taken

into and out of containment.

As a result of the violation the licensee

completely revised the controlling procedure,

QI 13-PR/PSL-2,

"Foreign

Material Control, Housekeeping

And Cleanliness

Control Methods."

The

inspector

reviewed Revision 35 of that procedure

and noted

much more

stringent controls of foreign material.

In addition, the licensee

developed

pamphlets

which describe the process,

posted signs throughout

the plant to serve

as reminders

about the program,

and provided training

to personnel

that might be involved with FNE (i.e. maintenance

workers,

utility men and operators).

The licensee

also revised HPP-l, "Radiation Work Permits."

Form 1.4,

'hich

is used to control containment entries in Modes 1, 2,

3 and 4 when

no work is to be performed.

The inspector verified the change

had been

incorporated into the current revision,

Revision 11.

In addition, the

licensee prohibited the use of the unit restart

open items list as

a

method for controlling FNE in the containment.

The inspector

reviewed

AP 0010728,

Revision 23, "Unit Restar't

Readiness,"

and verified that

this change

had been

made.

The inspector considered

these actions

adequate to prevent recurrence.

This violation is closed.

Conduct of Engineering

III. En ineerin

Generic Letter

GL 89-10

Safet

Valve Testin

and Surveillance

Pro ram

Im lementation

Ins ection Sco

e

Tem orar

Instruction 2515-109

The objectives of this inspection were to review:

1) the licensee's

response to

NRC Integrated

Inspection

Report (IR) 50-335,389/97-11,

and 2) the Motor Operated

Valve (NOV) program implemented in response to

GL 89-10.

The inspection

was conducted through reviews of documentation

and interviews with licensee

personnel.

Observations

and Findin s

Guidance for the

NOV program was documented in Florida Power and Light

(FPL) Procedure

JPN-PSL-SENP-91-030,

"St. Lucie Plant Units

1

8

2

NRC Generic Letter 89-10 Program Description," Revision 6, dated October 22,

1997.

Specific engineering

documents

contained the justifications for

J

0

27

MOV program assumptions.

These included justifications for valve

factors,

load sensitive behavior,

and stem friction coefficient

assumptions.

Inspection

Report 97-11 and the licensee's letter (Letter L-97-258)

dated October

10,

1997, identified 13 issues

and the associated

corrective actions

needed to resolve the Nuclear

Regulatory

Commission

(NRC)'s concerns with the

GL 89-10

NOV program.

The following sections

discuss

these

13 issues.

(1)

Weak Valve Factor Justifications:

IR 97-11 identified several

weak

valve factor justifications.

In its October

10,

1997 letter, the

licensee

committed to take the following specific actions to

resolve these

concerns.

~

Closed

Grou in

Criteria - The licensee's

grouping criteria

had not considered

a valve's American Nuclear Standards

Institute pressure

class or the system's fluid temperature.

The

inspectors

reviewed JPN-PSL-SENP-94-027.

"St. Lucie Unit 1-

Motor Operated

Gate.

Globe,

and Butterfly Valve Grouping for NOV

Dynamic Test Reduction

Program," Revision 5, dated

March 30,

1998 and JPN-PSL-SEMP-95-024,

"St. Lucie Unit 2 - Motor Operated

Gate.

Globe.

and Butterfly Valve Grouping f'r MOV Dynamic Test

Reduction Program," Revision 3, dated

March 30.

1998.

The

procedures

had been revised to include the above criteria and to

regroup the

NOV valve population.

This item is closed.

~

Closed

Inade uate 0 en Valve Factor Data for Valves 1-V3206

1-V3207

1-V3452

1-V3456

and 1-V3457

- The original valve

factor justification for this group did not include open dynamic

test data to address

performance in the open safety function

di rection.

The inspectors

reviewed the dynamic tests of valves

in this group which were reanalyzed

using Electric Power

Research

Institute (EPRI)'s extrapolation criteria and concluded

three tests

had adequate

disc loading levels to provide reliable

open valve factor information which was used to justify the

valve factors

used

by this group.

This item is closed.

~

Closed

Low Differential Pressure

Test Conditions for Valves 1-

MV-08-1A/B - These valves were originally tested at very low

differential pressures

relative to a design-basis

differential

pressure of 1015 psid.

The licensee recently retested

these

valves

and was able to obtain significantly higher differential

pressure

conditions.

The inspectors

reviewed the test results

which demonstrated

that the valves were flow-over-the-seat

globe

valves

and were self-closing in their safety function direction.

This item is closed.

~

Closed

Address

Unwed in

for Valves 'MV-09-9

'NV-09-10

MV-09-11

and ~r-MV-09-12 - These

WKN balanced-plug

globe valves

had not been analyzed to determine whether significant. unwedging

loads could exist under design-basis

conditions.

Several

near

28

'design-basis

dynamic test results

were reviewed by the

inspectors

and no unwedging concerns

were observed.

Dynamic

testing of this valve design will continue

as part of the long-

term

NOV program.

This item is closed.

~

0 en

Inade uate Close Valve Factor s for Valves 2-NV-08-12/13-

The licensee

was unable to perform meaningful

dynamic tests

on

these

4 inch Anchor/Darling double-disc"gate

valves in the close

direction.

To justify the applied valve factors,

the licensee

compared

EPRI Performance

Prediction Methodology

(PPN) flow

isolation model results to the results obtained

from the

industry standard

equation using

a 0.50 valve factor.

This

comparison

found that the industry standard

method bounded the

PPH results

and was used

as the basis for continued

use of a

0.50 valve factor .

The inspectors

observed that these Auxiliary Feedwater

(AFW)

Pump Steam Supply valves

have

a design-basis

function to close

under high-energy line beak conditions.

Therefore,

some

additional

stem thrust,

beyond flow isolation, is necessary

to

ensure that these

valves continue to meet thei r safety function

under all.plant conditions.

A new

PPN calculation

was performed that

assumed

the worst-case

lower wedge orientation,

so that

a bounding prediction could be

established.

The current torque switch settings

were found to

be approximately

midway between the current

minimum required

thrust

and the worst-case

PPM prediction for full disc wedging.

This provided confidence that the valves would reliably perform

thei r safety function at their cur rent settings.

Further, the

licensee will increase

actuator capability during the upcoming

Unit 2 outage.

The licensee

issued Plant Manager Action Item

(PNAI) PN 98-04-072 to revise program documents

and thrust

calculations to establish

a minimum thrust requirement that

ensures

adequate

mechanical

wedging of the valve discs

under

design-basis

conditions.

~

Closed

Inade uate Close Valve Factor

for Valves 2-V3481 arid 2-

V3651 - The licensee

reviewed the design-basis

conditions for

these

valves

and determined that they were not closed under

differential pressure

conditions.

Therefore.

the close valve

factor

does not affect the close thrust requirements

for these

valves.

The inspectors

agreed with this determination.

'This

item is closed.

~

0 en

Inade uate Close

Mar in for Valves 2-HV-08-1A/B - Unit

2's Hain Steam Isolation Valves

(MSIV) bypass

valves were found

to have inadequate

actuator capability to meet their close

safety function and were declared

inoperable.

The licensee

de-

energized

these valves in their close safety function position.

PMAI PM97-10-113

and modification package

PC/H 98014 had been

issued to implement actions to increase

the margin for these

29

valves.

Further, the valves will be reversed to change the flow

direction across

the valve plug.

These modifications were

scheduled to be implemented during the Fall

1998 Unit 2

refueling outage.

~

Closed

Justif

Safet

Function for Valve 2-MV-08-3 - AFW

Turbine Tri

Throttle Valve - The licensee

reviewed the safety

function for valve 2-MV-08-3 to ensure that it was correctly

classified

as not having an open safety function.

Condition

Report

(CR) 98-0457

documented the licensee's

review of the

Final Safety Analysis Report

and the emergency operating

procedures.

This review determined that 2-MV-08-3 is maintained

in its open safety position and is,not relied upon to re-open

after

a turbine overspeed trip because

the accident analysis

relies

on the 2 motor-driven

AFM pumps.

Additionally,

Operations

personnel

confirmed that this understanding

was

consistent with plant operating procedures.

This item is

closed.

~

Closed

Inade uate Close

Mar in for Valves 2-V3550

2-V3551

and 2-V3536 - Globe valves 2-V3550,

2-V3551,

and 2-V3536 were

found to have inadequate

actuator capability to meet their close

safety function.

The licensee

revised 2-V3536's thrust

calculation to take credit for its flow-over -the-seat

design

which assists

closure of the valve.

This removed

any capability

concerns

for this valve.

Further review of the design-basis

requirements

for valves

2-V3550 and 2-V3551 identified that

these valves

do not have

a close safety function.

This item is

closed.

(2)

Closed

Periodic Verification Plan Did Not Address

D namic Te tin

of Globe Valves:

The licensee's

periodic verification program was

described

in PSL-ENG-SEMS-97-018,

"Periodic Verification of Design

Basis Capability of Safety Related

Motor Operated

Valves for NRC Generic Letter 96-05", Revision 3, dated -April 9,

1998.

. Inspection Report 97-11 identified that dynamic testing of globe

valves

was specifically excluded.

In its October

10,

1997 letter

.

the licensee

committed to revise the program to include dynamic

testing of a sample of balanced disc globe valves.

The inspectors

verified that these

changes

were implemented.

However, the

inspectors

noted that the licensee did not intend to dynamically

test

any unbalanced

globe valves.

The licensee's

decision

was

based

on

a preliminary assessment,

as part of the Joint Owners

Group

(JOG) program on

MOV periodic verification. that unbalanced

globe valves were not susceptible to degradation

mechanisms.

The

inspectors

indicated that the

JOG is now including some unbalanced

globe valves in their test program to validate this assumption.

In

response,

the licensee

revised

PSL-ENG-SEMS-97-018 to include

a

review of the JOG's

unbalanced

globe valve testing

and to reassess

the need to perform continued testing of unbalanced

globe valves,

if necessary.

This item is closed.

T

30

(3)

(4)

(5)

(6)

(7)

Closed

Globe Valve Calculations

Did Not Use Correct Disc Area

The inspectors

reviewed Mechanical

Standard,

STD-H-003,

"Engineering Guidelines for Sizing

8 Evaluation of Limitorque Motor

Operators,"

Revision 3, dated 10/31/97.

which had been revised to

rovide guidance

on determining if globe valves were guide or seat

ased for PPH calculations.

Additionally, the inspectors

reviewed

PSL-1FJH-91-019.

Revision 12,

and PSL-2FJM-91-048,

Revision 12,

which had been revised to identify which globe valves were guide

based.

This item is closed.

Closed

D namic Testin

Data Extra olation Guidance

Needs

~Udatin:

The licensee's

justification for linear extrapolation of

dynamic test data did not include EPRI's latest

recommendations

for

identifying the disk loads that were necessary to ensure that test

results

were reliable for extrapolation.

Licensee

personnel

had

revised

JPN-PSL-SEMP-91-030

and their linear extrapolation

justification to include.EPRI's extrapolation criteria.

A review

of previous extrapolations

using this guidance

found that all

existing dynamic test conditions were adequate.

This item is

closed.

Closed

Condition

Re ort 97-1732

Does Not Address

Load Sensitive

Behavior in the 0 en Direction:

Condition Report

(CR) 97-1732

determined that the original 10.5 percent

load sensitive behavior

margin was non-conservative.

Analysis of in-plant data using

methods

determined that

a, 22.5 percent

margin was appropriate.

However,

CR-97-1732 did not specify

a margin'or the open

direction.

To resolve this issue,

the licensee

revised the open

setup calculations to include the 22.5 percent margin.

CR 97-1734,

Supplement

1, addressed

the revised margins

and identified 3 valves

that required further review (1-V2514, 2-V3663,

and 2-V3665).

These valves were found acceptable

based

on valve-specific dynamic

test data.

This item is closed.

Closed

Revisions

Needed to Address Effects of Stem Lubricant

Chan

e on Stem Friction Coefficient and

Load Sensitive

Behavior

The licensee recently changed the standard

stem lubricant from

FelPro

N5000 to Mobil 28 which may have different performance

characteristics,

The licensee will monitor for stem friction

coefficient and load sensitive

behavior

performance

changes

as part

of the long term

MOV program.

Load sensitive behavior

and stem

friction coefficient justifications will be revised to reflect the

new test data,

as necessary.

This item is closed.

Closed

No Mar in Identified for

A e Related

De radation:

The

licensee

had not identified

a margin for valve degradations.

PSL-

ENG-97-018,

"Periodic Verification of'esign Basis Capability of

Safety Related Motor Operated

Valves for NRC Generic Letter 96-05,"

Revision 2, dated 4/3/98,

was revised to include

a minimum 10

percent thrust margin goal.

The licensee

also

had identified 48

MOVs that will be modified over the next three outage cycles to

attain this margin goal.

This item is closed.

31

(8) 'losed

MOV Calculations

Need to Be

U dated to Incor orate the

Latest

Desi

n Information: The inspector

reviewed PSL-lFJH-91-017.

Revision 12; PSL-2FJN-91-048,

Revision 12;

F-MECH-CALC-018,

Revision 3;

and L-MECH-CALC-017, Revision 4.

These procedures'ad

been revised to address

non-conservative

valve factors,

load

sensitive behavior,

and include

PPH results for non-testable

valves.

This item is closed.

(9)

Lon

Term Plans

Where

PPH is Considered

"Best Available Data:"

Engineering

Report JPN-PSL-SENS-96-070,

"Evaluation of EPRI

HOV

Performance

Prediction

Program Results,-

NPR Report 1759," Revision

3. dated

March 30,

1998, describes

how the

PPN is applied to MOVs

and identifies several

cases

where the conditions for model

application were not met.

These results

were considered to be

"best available data."

In its October

10,

1997 letter, the

licensee

committed to develop plans to resolve

each of these

cases.

The licensee's

actions to implement these

plans are discussed

below.

~

0 en

Nona

licable Guide and Seat Material Combination-

EPRI's

PPH was not validated for valves that use Deloro on the

guide and disc seating surfaces.

Valve 1-V3480 (10 inch Velan

gate valve) uses .this material.

A contractor study showing

Deloro and Stellite 6 .as haying similar friction characteristics

was used

as

an interim justification.

Further

. the

JOG program

test plan includes at least

one valve that has Deloro internal

surfaces.

The licensee

issued

PMAI PH98-04-071 to monitor the

JOG and other industry testing

and to compare this information

to

PPN predictions

as

a long-term resolution of this issue.

~

Closed

Nona

licable Butterfl

Valve Bearin

Material-

Butterfly valves

~g-NV-07-ZA/B, 2-NV-'14-3, and Z-HV-14-4 were

identified to use

a nylatron bearing material that was not

included

as part of the

PPH validation program.

The licensee

reviewed existing dynamic tests for valves

1-HV-07-2A/B using

EPRI methods to measure

the bearing friction coefficient.

This

testing resulted in a bounding coefficient of friction of 0.,26.

For conservatism,

a coefficient of 0.35 was used

by the

PPN

prediction.

In-plant investigations

found that valves 2-NV-07-

2A/B have bronze bearings.

Therefore,

the

PPH predictions are

directly applicable to these valves.

.The bearing material

concern

was resolved for valves

2-NV-14-3 and 2-MV-14-'4 as they

have'no safety function in either di rection and were removed

from the

GL 89-10 program.

This item is closed.

~

0 en

Com ressible

Flow Globe Valves

- The licensee

applied

PPM

results to the HSIV bypass

valves

(2-NV-08-1A/B) which are globe

valves that operate

under steam

(compressible

flow) conditions.

Engineering

Report JPN-PSL-SEHS-96-070

noted that the

PPN is not

validated for globe valves that are in compressible

flow

applications.

The licensee

issued

PMAI PH97-10-133

and

modification P/CN 98014 to modify these

valves to increase their

32

(10)

margin dur ing the Fall

1998 Unit 2 refueling outage.

Further,

dynamic tests will be performed to establish

design-basis

settings.

~

0 en

Inverted Valve Guides

- Valves 1-HV-15-1 and 1-MV-18-1

use

an inverted guide design.

where the guide rai 1 is part of

the valve disc which rides in a slot in the valve body.

The

PPM

was not validated for valves with this design.

A contractor

study was used to justify use of the

PPH as "best available

data."

This study modified the guide offset dimensions

used

by

the

PPH and determined that disc tilting and nonpredictable

behavior

was not

a concern for these valves.

Engineering

Report

JPN-PSL-SEMS-96-070

stated that industry test

programs would be

monitored

and

new information would be incorporated

as it

becomes available.

The licensee

issued

PMAI PH98-04-71 to

communicate with industry sources

and other licensees to

identify existing

or future testing of this valve design.

Closed

Non redictable

Behavior

- The

PPH results for valves 1-

MV-09-7/8 originally determined that these

valves would be

nonpredictable

due to disc tilting and the sharp disc, seat

ring, and guide edges

assumed

by the

PPH.

These valves were

subsequently

opened,

and the seat

and guide edges

were verified

to be rounded in accordance

with EPRI's criteria.

Revised

PPH

calculations

resulted in a predictable thrust requirement

and

resolved this

PPH applicability issue.

This item is closed.

~

0 en

Valves Sizes

Lar er than

18 Inches

- The licensee

had

applied

PPM results to several

20 inch gate valves

(1-MV-09-1.

1-MV-09-2. 1-HV-09-7. and 1-HV-09-8).

The

NRC safety evaluation

(dated

Harch 15,

1996)

on the