ML17241A496
| ML17241A496 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 10/13/1999 |
| From: | Wert L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Plunkett T FLORIDA POWER & LIGHT CO. |
| References | |
| NUDOCS 9910250100 | |
| Download: ML17241A496 (37) | |
Text
October 13, 1999 Florida Power and Light Company ATTN:
Mr. T. F. Plunkett President - Nuclear Division P. O. Box 14000 Juno Beach, FL 33408-0420
SUBJECT:
MID-CYCLEPLANT PERFORMANCE REVIEW (PPR) - ST. LUCIE NUCLEAR PLANT On September 30, 1999, the NRC staff completed the mid-cycle Plant Performance Review (PPR) of St. Lucie Nuclear Plant. The staff conducted these reviews for all operating nuclear power plants to integrate performance information and to plan for inspection activities at your facility over the next 5 months.
The focus of this performance review was to identify changes in performance over the past six months, and to allocate inspection resources accordingly.
Based on this review, we.did not identify any new areas that warranted more than the core inspection program over the next five months.
It is still our intention, however, to continue our previously planned regional initiative inspection of open items associated with fire protection.
issues.
Enclosure 1 contains a historical listing of plant issues, referred to as the Plant Issues Matrix (PIM), that were considered during this PPR process to arrive at an integrated review of licensee performance trends.
The PIM includes items summarized from inspection reports or other docketed correspondence between the NRC and Florida Power and Light Company from October 1, 1998, to September 30, 1999. As noted above, greater emphasis was placed on those issues identified in the past 6 months during this performance review. The NRC does not attempt to document all aspects of licensee programs and performance that may be functioning appropriately.
Rather, the NRC only documents issues that the NRC believes warrant management attention or represent noteworthy aspects of performance.
In addition, the PPR may also have considered some predecisional and draft material that does not appear in the attached PIM, including observations from events and inspections that had occurred since the last NRC inspection report was issued, but had not yet received full review and consideration.
Once this predecisional material is finalized it will be placed in the PDR as part of normal issuance of NRC inspection reports and other correspondence.
This letter advises you of our plans for future inspection activities at your facility so that you will have an opportunity to prepare for these inspections and to provide us with feedback on any planned inspections that may conflict with your plant activities. Enclosure 2 details our inspection plan through March 2000 to coincide with the scheduled implementation of the revised reactor oversight process in April2000. The rationale or basis for each inspection outside the core inspection program is discussed above so that you are aware of the reason for emphasis in these program areas.
Routine resident inspections are not listed due to their ongoing and continuous nature.
99i0250i00 99101S PDR ADQCK 050003S5 G
FPL Ifcircumstances arise which cause us to change this inspection plan, we willcontact you to discuss the change as soon as possible.
Please contact me at 404/562-4540 with any questions you'may have.
(Original signed by L. Wert)
Leonard D. Wert, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket Nos. 50-335, 50-389 License Nos. DPR-67, NPF-16
Enclosures:
1.
Plant Issues Matrix 2.
Inspection Plan cc w/encls:
FPL cc w/encl:
J. A. Stall Vice President St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, FL 34957 R. G. West Plant General Manager St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, FL 34957 E. J. Weinkam Licensing Manager St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, FL 34957 John Gianfrancesco, Manager Administrative Support 8 Special Projects Florida Power 8 Light Company P. O. Box 14000 Juno Beach, FL 33408-0420 Mark Dryden Administrative Support 8 Special Projects Florida Power & Light Company P. O. Box 14000 Juno Beach, FL 33408-0420 Rajiv S. Kundalkar Vice President - Nuclear Engineering Florida Power 8 Light Company P. O. Box 14000 Juno Beach, FL 33408-0420 M. S. Ross, Attorney Florida Power 8 Light Company P. O. Box 14000 Juno Beach, FL 33408-0420 WilliamA. Passetti Bureau of Radiation Control Department of Health and Rehabilitative Services 2020 Capital Circle SE Bine PC21 Tallahassee, FL 32399-1 741 Joe Myers, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, FL 32399-2100 J. Kammel Radiological Emergency Planning Administrator Department of Public Safety 6000 SE Tower Drive Stuart, FL 34997 Douglas Anderson County Administrator St. Lucie County 2300 Virginia Avenue Ft. Pierce, FL 34982
FPL Distribution w/encls:
S. Collins, NRR J. Zwolinski, NRR W. Dean, NRR W. Gleaves, NRR C. Thomas, NRR G. Tracy, EDO J. Borchardt, OE L; Wert, Rll S. Rudisail, Rll PUBLIC NRC Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 6090 Jensen Beach, FL 34957-2010
- (See previous concurrence)
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FPL Distribution w/encls:
S. Collins, NRR J. Zwolinski, NRR W. Dean, NRR T. Boyce, NRR W. Gleaves, NRR C. Thomas, NRR G. Tracj/, /DO~
J&ieberITTan, OE L. Wert, Rll S. Rudisail, Rll PUBLIC NRC Resident Inspector U.S. Nuclear Regulatory Comm'ion P. O. Box 6090 Jensen Beach, FL 34957-2 0
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Page:
1of20 10/1 3/1999 06:24:18 IR Report 3 Region II ST LUCIE United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Date Source Functional Area Template ID Type Codes Item Title Item Description 08/21/1999 1999005-01 Pri: OPS Licensee NCV Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: 1A Sec: 3A Ter:
Procedural adherence issues A non-cited violation was identified for several procedural adherence errors associated with reactor protection system logic matrix testing, one ofwhich caused two pairs of trip circuit breakers to be open at the same time.
However, since both pairs of breakers were supplied by the same motor generator all control element assemblies remained energized.
The operating crew supervision overseeing the test failed to adequately control and resolve difficulties encountered while performing the test. (Section 01.2) 08/21/1999 1999005 Prl: pps Sec: ENG Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 NRC POS Pri: 2B Sec: 4B Ter: 3B New fuel receipt, inspection, and transfer activities New fuel receipt, inspection, and transfer activities were conducted in accordance with procedural requirements.
Required records and logs were maintained during all fuel inspections and transfers.
Operators performing the activities were knowledgeable and the level of supervision provided for these efforts was appropriate.
(Section 01.3) 08/21/1999 1999005 Prl: ppS Sec: OTHER Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 NRC POS Pri: SB Sec:
Ter:
Licensee evaluations of Unit 2 shutdown cooling system issues Licensee evaluations, root cause analysis, Quality Assurance audit, and self-assessment efforts to address the Unit 2 shutdown cooling system event last outage were comprehensive, thorough, and self-critical. The resulting corrective actions appropriately targeted identified causes, complemented each other well, and appeared to be effective. (Section 07.1) 08/21/1999 1999005-02 Prl: ppS Sec: ENG Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 NRC NCV Pri: SC Sec: 3A Ter: SA Inadvertent heat-up during mid-loop conditions Nonconseivative decision-making, schedule pressures, insufficient questioning attitude, and inadequate implementation of the corrective action process contributed to the inadvertent heat-up of the reactor coolant system during Unit 2 Cyde 11 mid-loop operation. A non-cited violation was identified for inadequate identification and correction of degraded shutdown cooling system performance. (Section 07.1) 07/10/1999 1999004 Pri: OPS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 NRC NEG Pri: 1A Sec: 3A Tef: 3B Operations decision making during startup Operations decision making was not conservative as evidenced by proceeding with a main turbine test during reactor startup and maintaining the Unit 2 reactor in a suspended startup condition (i.e., shutdown and regulating groups withdrawn) for an extended period. (Section 01.4) 07/10/1999 1999004 Pri: ppS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 NRC NEG Pri: 1B Sec: 3A Tef: 3B Inadequate supervisory actions involving restoration of MSIV The Assistant Nuclear Plant Supervisor failed to demonstrate sufficient caution and attention to'detail in supervising main steam isolation valve restoration and recovery activities. Both the Event Response Team and root cause analysis failed to recognize and/or adequately address certain aspects of the event.
(Section 01.3)
Enclosure 1
Item Type (Compliance,Followup,other), From 10/01/1998 To 09/30/1999
Page:
2 of 20 10/13/1999 06:24:18 IR Report 3 Region II ST LUCIE Date Source Functional Area United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Template Item Title ID Type Codes Item Description 07/10/1999 1999004 Pri: ppS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 NRC POS Pri: 1A Sec: 3C Ter: 3A Crew briefings.for Unit 2 restart Crew briefings conducted by Operations supervision included appropriate guidance and clarified management expectations for Unit 2 restart. Operators successfully performed the reactor startup in a cautious manner, closely following procedures and input from Reactor Engineering.
Supervisory oversight was effective throughout the evolution. (Section 01.5) 07/1O/1999 1999OO4 Prl: ppS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 NRC POS Pri:18 Sec: 3A Ter: 2A Operator actions in response to two control element assembly drop events Operator actions in response to two control element assembly drop events were conservative and consistent with established off-normal and emergency operating procedures.
Plant systems functioned as designed, with only a few minor equipment problems.
(Section 01.2) 07/10/1999 1999004 Pri: ppS NRC ppS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: 5A Sec: 58 Ter: 5C Post-trip review for manual trip The post-trip review,for the control element assembly related manual trip was complete and thorough. The Facility Review Group decision to approve startup was based on a reasonable assurance that the causes of the event were sufficiently understood and appropriate corrective actions were taken.
(Section 01.2) 07/10/1999 199900441 Pri: OPS Licensee NCV Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: 18 Failure To Properly Release The 28 MSIVClearance Order Sec: 3A Improper release of an equipment dearance order for the Unit 2 main steam isolation valves by Operations caused the 28 main steam isolation valve to unexpectedly open resulting in an inadvertent cooldown of the reactor coolant Ter: 38, system and actuation of the reactor protection system.
This failure to followprocedure was identified as a nonmted violation. (Section 01.3) 07/10/1999 199900442 Prl: ppS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST, LUCIE 2 NRC NCV Pri: 18 Sec: 3A Ter.
Failure To Follow MSIVRestoration Procedure Operator efforts to reclose the 28 main steam isolation valve, following the cooldown event, using the normal restoration procedure were hindered when a procedural step was inadvertently missed.
This failure to follow procedure was identiTied as a non-cited violation. (Section 01.3) 07/10/1999 1999004-03 Prl: OPS Ucensee NCV Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: 18 Failure to FollowTurbine Trip Procedure Sec: 3A A nonsked violation was identified for the failure to folio'wprocedures and reset the fifteen percent main feedwater bypass valves following a post-maintenance test turbine related trip which resulted in a steam generator overfeed Ter: 38 condition and inadvertent reactor coolant system cooldown. (Section 01.4).
Item Type (Compliance,Followup,Other), From 10/01/1998 To 09/30/1999
Page:
3 of 20 10/13/1 999 06:24:18 IR Report 3 Region II ST LUCIE United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Date Source Functional Template Area ID Type Codes Item Title Item Description Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 05/29/1999 1999003 Pri: OPS NRC NEG Pri: 3A Sec:
Sec: 5A Ter: 5B Questioning attitude of control room operators Two examples were identified in which control room operators did not apply a questioning attitude or properly pursue resolution of important equipment operability issues (Section 01.1).
05/29/1999 1999003 Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: OPS Sec: OTHER NRC POS Pri: 3C Sec: 5C Ter:
Site management actions to improve the utilization of the corrective action program Senior site management initiated actions to improve the utiTization of the corrective action program. These actions addressed recent findings that some work groups were not using Condition Reports to address problems'(Section 07.1).
04/17/1999 1999002 Pri: OPS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE2 NRC POS Pri: 1A Sec: 3A Ter: 3C Execution of Unit 2 shutdown due to emergent issue Operations personnel and plant equipment performed well during the Unit 2 shutdown required 6y Technical Specification 3.0.3 and during the subsequent power ascension.
Management decisions were conservative and clearly communicated to the operating crews. Crew turnover and briefings were accomplished in a professional and informative manner.
Strong control room supervision was observed.
(Section 01.2)
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 04/17/1999 199900241 Pri: OPS NRC NCV Prl: 3A Sec: ENG Sec: 4A Tef: 4B Safety Evaluation not performed for valve position changes A Non-Cited Violation was identified for failing to perform written safety evaluations to determine ifchanges to the positions of containment isolation valves described in the Updated Final Safety Analysis Report involved unreviewed safety questions.
(Section 03.1) 03/19/1999 1999009 Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Prl: OPS Sec: OTHER NRC WK Pri: 3B Sec: 1C Ter. 5C Licensee's training program self assessment The licensee's training program assessment identified a number of implementation weaknesses in the Systems Approach to Training (SAT) for the operator licensing training program.
The license's initial correctiva actions may have been too narrowly focussed and did not address all of the underlying weaknesses in the implementation of the SAT process.
These weaknesses along with additional NRC identified examples, directly contributed to the poor pass rate on the December 1998 initial operator licensing examination.
03/06/1999 1999001 Pri: OPS NRC POS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Prl: 5C Sec: 5B Ter. 5A Corrective action process improvements The licensee established several actions to improve the corrective action process.
Previous problems with the Plant Manager's Action Item program have been corrected.
Detailed reviews by the licensee continue to identify minor problems with proposed corrective actions. The licensee initiated corrective actions to address the identified issues (Section 08.1).
Item Type (CompIiance,Followup,Other), From 10/01/1998 To 09/30/1999
Page:
4 of 20 10/13/1999 15:56:21 IR Report 3 Region II ST LUCIE United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Date Source Functional Area Template ID Type Codes Item Title Item Description 03/06/1999 1999001-01 Pri: OPS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 NRC NCV Pri: 1A Sec: 3A Ter: 5C Inadequate Corrective Actions Improper communications between Operations, Engineering, and Chemistry and a lack of attention to detail resulted in incomplete corrective actions associated with a containment isolation valve. Although a CR was initiated to address the condition adverse to quality, corrective actions were not fullyimplemented. A nonsked violation was identified (Section 02.4).
03/06/1999 1999001 Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Prl: OPS Sec: ENG NRC NEG Prl: 3A Sec: 3B Ter: 1A Human performance errors and procedural deficiencies Several human performance errors and procedural deficiencies were identified following a routine emergency diesel generator (EDG) surveillance test.
Dunng the test, the 1A EDG was unintentionally overloaded when a control room indication failed to operate properly. Operator decision making was not conservative.
Operators and Engineering personnel lacked knowledge of EDG load ratings. Engineering and Operations conducted a thorough investigation of the event.
Detailed inspections were completed to verify EDG operability. The human performance and procedural deficiencies were effectively corrected as evidenced during subsequent EDG tests (Section M1.3).
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 03/06/1999 1999001 Prl: OPS NRC POS Prl: 2B Sec: ENG Sec: 3A Ter: 2A Condition ofshield building ventilation system Shield building ventilation system operability and configuration were appropriate to support plant operations.
The system component engineer was knowledgeable of system operation and status.
Material condition and housekeeping of the system were acceptable (Section 02.3).
03/06/1999 1999001 02 Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: OPS Sec: MAINT NRC NCV Prl: 3A Sec: 2A Ter: 2B Scaffolding Construction Discrepancies In general, scaffolds observed by the inspector were well constructed and properly restrained to prevent damage to safety-related electrical equipment from planned work or a seismic event.
However, the inspector did identify a nonwted violation involving several instances of improperly constructed scaffolds over safety-related electrical equipment.
Procedural requirements were not met.(Section M1.5).
01/23/1999 1998012 Prl: OPS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 NRC NEG Prl: 1A Sec: 3A Tel". 5A Performance of Non-licensed Operators Although the Non-licensed Operators performed their duties in a manner consistent with the Conduct of Operations procedure, they were not meeting the expectations of Operations Management regarding identification of minor equipment deficiencies.
(Section 04.1) 01/23/1999 199801241 Pri: OPS ucensee NCV Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Prl: 1A Sec: 3A Ter:
Containment Isolation Signal Bistable Bypassed in Excess of TS Action Statement The licensee identified that TS limits for bypassing Containment Isolation Signal bistables had been exceeded.
A Non-Cited Violationwas identified. The Licensee Event Report met the requirements of 10 CFR 50.73 and correctly characterized the event. Allcorrective actions were completed satisfactorily.
(Section 08.1)
Item Type (Compliance,Followup,Other), From 10/01/1998 To 09/30/1999
Page:
5 of 20 10/13/1999 06:24:18 IR Report 3 Region II ST LUCIE Date Source Functional Area United States Nuclear Regulatory Commission PLANT ISSuE MATRIX
. By Primary Functional Area Template Item Title ID Type Codes Item DescriPtion Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 01/23/1999 1998012 Pri: OPS NRC POS Prl: 1A Equipment Clearance Orders Sec: MAINT Sec: 3A Equipment Clearance Orders were properly prepared, authorized, and implemented.
(Section 02A)
Ter:
01/23/1999 1998012 Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE2 Prl: OPS Sec: MAINT NRC POS Prl:2A Hydrogenanalyzersandrecombinera Sec:
The hydrogen analyzers and recombiners were in an operable condition as identified through the review of documents, inspection of accessible system components, and interviews with responsible individuals. The material Ter:
condition and housekeeping of these systems were also acceptable.
(Section 02.3) 12/12/1998 1998011 Prl: OPS NRC POS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: 1A Sec: 3C Ter: 3A Power reduction, shutdown, and cooldown for the planned refueling outage The power reduction, shutdown, and cooldown for the planned refueling outage were professionally conducted.
Supervisors ensured that the control room was maintained quiet. The operators were attentive and knowledgeable of their tasks.
Consistent use of three part communications and strong teamwork were observed (Section 01.2).
12/12/1998 1998011 Pri: OPS NRC POS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE2 Pri: 1A Sec: 3C Ter. 3A Conduct of reactor startup The reactor startup was well conducted.
Supervision maintained quiet conditions in the control room, and a professional attitude was exhibited throughout the cnticai evolutions.
Reactor Engineering interacted frequently with the Reactivity hJanager and the Reactor Control Operator.
Reactivity manipulations were properly controlled and the expected response was verified by the operator. (Section 01.5) 12/12/1998 1998011 Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 P~: OPS Sec: FNG NRC POS Prl: 1B Sec: 2A Ter: 5B Immediate response to shutdown cooling valve leakage Shutdown cooling operations were impacted by seat leakage of the shutdown cooling heat exchanger bypass valves.
Operators were attentive to plant conditions and expeditiously identified the reactor coolant system heatup as shutdown cooling flowwas decreased during reduced inventory conditions. Recovery actions were appropriately conservative and procedures were adequate.
Analyses of the incident were thorough.
The final resoluhon adequately addressed all technical and administrative issues (Section 01.3).
12/12/1998 1998011 Prl: OPS NRC POS Sec: MAINT Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: 2A Sec: 3C Ter: 2B Condition of containment prior to restart Prior to restart, the inspectors conducted comprehensive tours of Systems, Structures, and Components inside Unit 2 containment.
Overall, the containment was dear and dean.
The Structures, Systems, and Components appeared to be good condition (Section 02.3).
Item Type (Compliance,Foliowup,Other), From 10/01/1998 To 09/30/1999
Page:
6 of 20 10/13/1999 06:24:18 IR Report 3 Region II ST LUCIE United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Date Source Functional Area Template ID Type Codes Item Title Item Description 12/12/1998 1998011 Pri: OPS Sec: MAINT Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 NRC STR Pri: 1A Sec: 3A Ter: 2B Overall conduct of operations The overall conduct of operations was professional and safety-conscious.
Operations control of outage activities was strong (Sections 01.1 - 01.5).
10/31/1998 1998010 Pri: OpS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 NRC MISC Pri: 5C Sec: 1A Ter. 2B Corrective actions for clearance issues The licensee has implemented extensive corrective actions to prevent recurrence of past clearance-related problems.
Equipment clearance orders were being processed in accordance with program requirements and management expectations.
The Clearance Center was at first reconfigured, and then incorporated into the One Stop Shop, to provide a controlled environment conducive to generating quality. Responsible personnel were knowledgeable and sensitive to the critical impertance of an effective clearance process for ensuring personnel, equipment and nuclear safety (Section 08.2).
10/31/1998 1998010 Pri: OpS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 NRC POS Pri: 1A Sec: 3A Ter.
Execution of Infrequent Evolution An infrequent evolution to shift main feedwater flowcontrol from the 1B main feed regulating valve to the bypass valves to allow for online repairs was well controlled and accomplished without incident. Operating crew preparation, brlefling, and performance were exemplary (Section 01.2).
10/31/1998 1998010 Pri: OPS Sec: MAINT Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 NRC POS pri: 1A Sec: 3A Ter: 2A Alignment of safety-related systems Safety-related systems were properly aligned, induding valve and breaker positions, and maintained consistent with applicable drawings, procedures, and Technical Specifications.
Equipment operability, material condition, and housekeeping were acceptable (Sections 02.2).
08/21/1999 1999005 Pri: MAINT NRC POS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 08/21/1999 1999005 Pri: MAINT
. NRC POS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: 2A Sec: 4B Ter:
Pri: 2B Sec: 3A Ter: 3B Evaluation of control room air conditioning system failures Recent failures associated with the control room air conditioning system were appropriately evaluated with respect to the Maintenance Rule. The licensee's monitoring and tracking through the use of system performance windows has led to increased reliability of several systems that are important to safety. (Section E2.1 and E2.2)
Conduct of maintenance and surveillance activities Observed maintenance and surveillance activities were performed consistent with established work control processes.
Risk assessments were performed prior to emergency diesel generator and start-up transformer maintenance outages to ensure there were no significant increase in risk. Also, unavailability time during these critical maintenance activities was managed appropriately.
(Section M1.1)
Item Type (Compliance,Followup,Other), From 10/01/1998 To 09/30/1 999
Page:
7 of 20 10/13/1999 06:24:18 IR Report 3 Region II ST LUCIE United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Date Source Functional Area Template ID Type Codes Item Title Item Description 08/21/1999 199900543 Pri: MAINT Licensee NCV Sec: ENG Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE2 Prl: 2B Sec: 4C Ter:
Inadequate procedures for functional testing of Sl system A nonmted violation was identified for the failure to maintain adequate procedures for conducting engineering safeguards actuation furictional testing.
Due to the longstanding procedure errors, both safety injection actuation systems have been blocked simultaneously for short periods during monthly surveillance testing, which is a condition prohibited by Technical Specifications. (Section M8.1) 07/10/1999 1999004 Pri: MAINT NRC POS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: 2B, Conduct of surveillance activities Sec: 3A Surveillance activities were appropriately planned, performed and coordinated with the control room. The Emergency Diesel Generator 1A surveillance and the Unit 1 Moderator Temperature Coefficient test were well briefed and executed. (Sections M1.1 ~ M1.2, and M1.3) 07/10/1999 199900444 Pri: MAINT NRC NCV Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: 2B Sec: 3A Ter:
Failure to Control Work Scope Per Administrative Procedure Control ofwork activities during control element drive mechanism control system repairs was not accomplished in accordance with the scope change requirements of the licensee's administrative procedure. A non-cited violation was identified. (Section M4.2) 05/29/1999 1999003 Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: MAINT Sec:
NRC POS Pri: 2B Sec: 3B Tef: 4B Overall resolution of Intake Cooling Water pump shaft corrosion problems The licensee's overall resolution of Intake Cooling Water pump shaft corrosion problems was effectiv. While initial efforts to investigate the pump shaft failure were not aggressive, once the shaft corrosion was identified, the licensee's actions were reasonable and prudent.
Mechanical maintenance activities were conducted according to wdtten work instructions by skilled personnel.
Maintenance supervision provided active oversight and direction of the work.
Engineering support of the work activities, resolution of emergent problems, and root cause investigation was effective. (Section M1.2).
05/29/1999 199900341 Pri: MAINT NRC NCV Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE2 Pri: 2B Sec: 3C Tel".
Inadequate Foreign Material Accountability Controls For The Spent Fuel Pool Areas Foreign material exclusion controls in the spent fuel pool areas were effective for routine day-tray entries.
However, long term accountability and control of items left in the areas were not adequate.
A non-cited violation was identified regarding inadequate procedural guidance for these aspects of foreign material exclusion controls (Section M2.1)
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE2 05/29/1999 1999003 Pri: MAINT NRC POS Pri: 3A Sec: OPS Sec: 2B Ter: 5A Conduct of AuxiliaryFeedwater system relay test Operations and Instrumentation and Controls personnel properly performed an AuxiliaryFeedwater Actuation System relay test using 'effective pre-job briefings, three part communications, and peer checking.
Attention to detail by the involved technicians resulted in a test procedure error being identified and corrected (Section M4.1).
Item Type (Compliance,Foliowup,Other), From 10/01/1998 To 09/30/1999
Page:
8 of 20 10/13/1999 06:24:18 IR Report 3.
Region II ST LUCIE United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Date Source Functional Area Template ID Type Codes Item Title Item Description 04/17/1999 1999002 Pri: MAINT NRC POS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE2 04/17/1999 199900242 Pri: MAINT Licensee NCV Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: 3A Sec: 2B Ter: 3B Pri: 3A Sec: 2B Ter: 5A Application of lessons teamed Application of lessons learned and effective teamwork during the planning, preparation, and implementation ofwork, resulted in successful repairs of emergency core cooling system header leaks while minimizing the out of service time of important safety systems. (Section M1.2)
Missed Steam Generator U-Tube Inspection A Nonited Violation was identified for failure to complete the required steam generator tube inspections during the Unit 2 Cycle 11 refueling outage.
This condition was identified and reported by the licensee in Licensee Event Report (LER) 50-389/98%08@Or (Some tubes not inspected due to software encoding errors related to use of remote positioning device) (Section M8.1) 04/17/1999 1999002 Pri: MAINT Sec: ENG Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE2 NRC POS Pri: 3A Sec: 2B Ter: 4B Surveillance testing of sodium hydroxide tank vacuum breaker check valves Surveillance testing of the Unit 1 sodium hydroxide tank vacuum breaker check valves was conducted in a methodical, step-by-step manner.
The test engineer immediately notified the control room and wrote a three4ay condition report when one of the check valves failed to open.
Compensatory measures to restore operability were prompt and effective. Engineering dispositions of the applicable condition reports were thorough and comprehensive.
(Section M1.3) 03/06/1999 1999001 Pri: MAINT NRC NEG Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 03/06/1999 1999001 Pri: MAINT NRC POS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE2 03/06/1999 1999001 Pri: MAINT NRC POS Sec: ENG Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: 2B Sec: 3A Ter:
Pri: 5A Sec: 3A Tel". 3B Pri: 4B Sec: 5A Ter: 5C Contingency preparations for failure of the emergency cooling canal discharge valves Contingency preparations for mitigating a potential failure of the emergency cooling canal discharge valves during routine surveillance testing were not fullyimplemented.
Transfer of responsibility for installation of ultimate heat sink stop logs from Maintenance Services to the Mechanical Maintenance department had not been well executed (Section M1.2).
Troubleshooting efforts for a failed containment isolation valve Troubleshooting efforts for a failed containment isolation valve were successful once Instrumentation and Control supervision became involved, helping the crew focus on problem identification, Clearances were observed to provide the necessary safety boundary for completion of the work. Replacement and post maintenance testing of the valve were successfully completed by skillfuland knowledgeable maintenance personnel (Section M1.4).
Quarterly system health review meeting The quarterly system health review meeting between management, engineering, and maintenance relative to equipment status and the status of corrective actions for equipment problems was effective (Section M1.6).
Item Type (Compliance,Followup,Other), From 10/01/1998 To 09/30/1999
Page:
9 of 20 10/13/1999 06:24:18 IR Report 3 Region II ST LUCIE Date Source Functional Area United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Template Item Title ID Type Codes Item Description 03/06/1999 1999001 Prl: MAINT NRC POS Sec: OPS Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE2 Pri: 2B Sec: 3A Ter. 3B Maintenance and surveillance activities Observed maintenance and surveillance activities were performed in a quality manner and documentation was appropriate.
Procedures were in place and were being conscientiously followed by knowledgeable and qualified maintenance personnel. Interface between maintenance and operations personnel was good (Sections M1.1 and M1.6).
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 01/23/1999 1998012 Pri: MAINT NRC POS Pri: 3A Performance of maintenance and surveillance activities Sec:
Sec: 2B Maintenance and surveillance activities were performed well, with good documentation.
Procedures were in place and being followed by qualified and knowledgeable maintenance and testing personneL Good coordination between Ter: 3C operations, maintenance, and engineering was observed.
(Section M1.1) 01/23/1999 1998012 Pri: MAINT NRC POS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: 4B Sec: 4C Ter:
GL 96-05 Program The licensee was in the process of establishing a program with the intent of meeting GL 96-05, "Periodic Verification of Design-Basis Capability of Safety-Related Motor4perated Valves."
The licensee's Iong-term motor operated valves dynamic test plan for continued dynamic testing on a rotating ~cte basis was considered a positive aspect of the licensee's GL 96-05 program.
(Section M1.2)
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 01/23/'l999 199801242 Pri: MAINT Licensee NCV Pri: 5A Inoperable Shutdown Cooling Flow Indication On Hot Shutdown Panel Sec:
Sec: 3A The licensee identified that a shutdown cooling flowindicator on the alternate shutdown panel had been inoperable in excess ofTechnical Specification limits. Corrective actions were adequately implemented and addressed the root Ter: 3B cause of the incident. A Non-Cited Violation (NCV) was identified.
(Section M8.1)
'1/23/1999 1998012 Dockets Discussed:
OS000335 ST LUCIE 1 05000389 ST LUCIE 2 Prl: MAINT Sec: ENG NRC NEG Prl: 3A Communications during troubleshooting Sec: 1A Operations and maintenance did not adequately communicate during the troubleshooting of a problem with the B hot leg injection valve (V3523). Operations considered the valve operable and believed the issue was only an Ter 4B indication problem. Subsequent investigation revealed V3523 was actually experiencing mechanical difficulties.
Engineering performed a detailed analysis of the issue and provided sound recommendations to restore confidence in the continued operation of the system.
Additionally, the licensee's operability and repoitability assessments were thorough.
(Section E2.1)
Dockets Discussed:
05000335 ST LUCIE 1.
05000389 ST LUCIE 2 12/12/1998 1998011 Pri: MAINT NRC POS Pri: 2B Quality Assurance Audit Sec:
Sec: SA Quality Assurance Audit QSL-ISI-97-14 was detailed, well performed, and contained meaningful findings.
Appropriate corrective actions were taken for adverse audit findings. (Section M1.8)
Ter: SB Item Type (Compliance',Followup,Other)
~ From 10/01/1998 To 09/30/1 999
Page:
10 of 20 10/13/1999 06:24:18 IR Report 3 Region II ST LUCIE United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Date Source Functional Area Template ID Type Codes Item Title Item Description Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 12/12/1998 1998011 Pri: MAINT NRC STR Pri: 2B Sec:
Sec: 4C Ter: 3B Inservice inspection activities Inservice inspection activities were performed in accordance with requirements with strong licensee direction and oversight of contract personnel.
Overall, the licensee's Inseivice Inspection program was considered to be a strength.
(Section M1.8)
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 12/12/1998 1998011 Pri: MAINT NRC STR Pri: 3A Sec:
Sec: 2B Ter: 3B Maintenance outage activities Maintenance outage activities were conducted professionally.
Procedural compliance, worker knowledge, and pre-job briefings were strong.
Coordination between different work groups and supervision of testing activities were effective. (Sections M1.1 - M1.7)
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 12/12/1998 1998011 Pri: MAINT NRC POS Prl: 2B Sec: ENG Sec: 3B Ter. 4C Flow accelerated corrosion program Adetailed flowaccelerated corrosion program was in place and was being implemented in accordance with procedural requirements by knowledgeable licensee personneL (Section M1.9).
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 12/12/1998 1998011 Prl: MAINT NRC STR Prl: 5A Sec: OPS Sec: 5B Ter:
Quality Control inspections, surveillances, and spot checks conducted during outage Quality Control inspections, surveillances, and spot checks conducted during the refueling outage were proactive and included insightful observations (Section 07.2).
10/31/1998 1998010 Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: MAINT Sec:
NRC POS Pri: 3A Sec: 2B Ter. 3C Critical Maintenance Management (CMM)evolutions ln general, Critical Maintenance Management (CMM)evolutions were well planned and executed.
Maintenance pre-job briefs were thorough, focused on safety, and took advantage of prior operating experience events.
Operations, maintenance and engineering personnel worked together well to successfully accomplish CMM adivities.
Supervisory and/or engineering personnel provided consistent oversight and support.
Maintenance activities were conducted in accordance with applicable instructions and procedures, and appropriately documented (Sections M1.2 and 1.3).
10/31/1998 1998010 Pri: MAINT Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 NRC POS Pri: 3B Sec: 3C Ter. 3A Maintenance and surveillance testing activities Maintenance and surveillance testing activities were performed in accordance with work instructions, procedures, and applicable dearance controls. Work performed during these activities was accomplished by knowledgeable and expenenced personnel who exhibited familiaritywith their specific tasks.
The work package or procedure was routinely present and in active use at the work site. Maintenance supervision and site engineering staff were dosely involved with the maintenance work. Good interface between maintenance and operations personnel was observed, particularly during the feedwater maintenance evolutions.
Work activities were properly documented and problems were appropriately resolved (Section M1.1).
Item Type (Compliance,Followup,Other), From 10/01/1998 To 09/30/1999
Page:
11 of 20 10/13/1999 06:24:18 IR Report 3 Region II ST LUCIE Date Source Functional Area United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Template Item Title ID Type Codes Item Description Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 08/21/1999 1999005 Pri: ENG NRC POS Pri: 5A Reactivity Management Event summaries Sec:
Sec: 5B Reactivity Management Event summaries provided specific insights of recent events from a reactor engineering perspective and were a useful tool in succinctly communicating the scope and impact of reactivity management Ter: 4B events to management.
(Section E1.1)
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 07/10/1999 1999004 Pri: FNG NRC POS Pri: 4A Containment radiation monitoring systems Sec:
Sec: 4B Containment radiation monitoring systems were determined to meet original design and were sufficient to meet the intent of Regulatory Guide 1.45.
(Section E8.2)
Ter:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 07/10/1999 19S9004 Pri: ENG NRC POS Pri: 4C Year 2000 readiness Sec:
Sec: 4A The Year 2000 inspection was completed in accordance with Temporary Instruction 2515/141.
Overall, the Year 2000 project was 100 percent complete for Category 1 and 2 items and contingency planning, and 85 percent Ter: 5B complete for Category 3 items. (Section E8.4) 07/10/1999 1999004 Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Prl: ENG Sec:
NRC POS Pri: 4C Sec: 5B Ter. 5C Initial root cause evaluations and corrective actions for control element assembly events Initial root cause evaluations and corrective actions for the control element assembly events were sufficient to support restart of Unit 2, and the final root cause determination and associated corrective actions were appropriate.
The cause of the dropping of assembly No. 40 was two separate ground faults that created a phase to phase to ground fault. The cause of the dropping of the assemblies in subgroup No. 21 was misalignment of the power switch compartment during troubleshooting activities. (Section E2.1) 07/10/1999 1999004 Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: ENG Sec:
NRC POS Prl: 5B Sec: 3C Ter. 4B Event Response Team (ERT) and root cause analysis activities Event Response Team (ERT) and root cause analysis activities for the two control element assembly drop events and other issues associated with the control element drive mechanism control system were conducted in a thorough and comprehensive manner.
Management involvement and oversight was evident throughout. Adetailed self-assessment of ERT performance was very selfwritical and identified many signiTicant lessons learned.
(Sections E1.1 and E2.1)
Dockets Discussed:
05000335 ST LUCIE 1
-05000389 ST LUCIE 2 07/10/1999 199S004-05 Pri: ENG NRC EEI Pri: 4A Apparent violation for failure to establish environmental qualification Sec:
Sec: 4C An apparent violation was identified regarding the failure to establish environmental qualification, in accordance with 10 CFR 50.49, for electrical equipment located in the Unit 1 steam trestle area.
(Section E8.3)
Ter.
Item Type (Compliance,Followup,Other), From 10/01/1998 To 09/30/1999
Page:
12 of 20 10/13/1 999 06:24:18 IR Report 3 Region II ST LUCIE United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Date 05/29/1999 1999003 Pri: ENG Sec:
Dockets Discussed:
05000389 ST LUCIE 2 Licensee NOED Pri: 4A Sec:5B Ter. 5C Functional Template Source
~
Area ID Type Codes Item Title Item Description Errors In the analysis of a main steam line break In containment The licensee identified several errors in the analysis of a main steam line break in containment. A re-analysis, using more appropriate assumptions, indicated that Unit 1 containment pressure could exceed the value specified in the Updated Final Safety Analysis Report and Technical Specification bases.
The licensee completed an evaluation which concluded that the Unit 1 containment was operable and continued operability was justified per the guidance of Generic Letter 91-18. The licensee's immediate corrective actions were comprehensive and additional actions are planned (Section E8.2).
05/29/1999 1999003 Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pi'I: ENG Sec: MAINT NRC NEG Pri: 4C Sec: 4B Ter: 5C Implementing action ofTechnical Specification 6.8.4.a(i)
Program requirements for implementing Technical Specification 6.8.4.a(i) regarding preventive maintenance and visual inspection of potential highly radioactive primary coolant leaks outside containment were not well defined.
Other existing plant processes were adequately minimizing leakage.
Engineering conducted a thorough review of the issue and developed corrective actions for providing additional controls to ensure leakage limits were maintained within the safety analysis assumptions (Section E3.1).
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 04/17/1999 1999002 Pri: ENG NRC POS Pri: 3A Sec:
Sec: 4C Ter: 5A Root Cause Team for the 2B Qualified Safety Parameter Display System The Root Cause Team assembled to coordinate troubleshooting and repair activities for the 2B Qualified Safety Parameter Display System used good teamwork to systematically determine the root cause of the equipment failure.
Communications were effective between team members.
(Section E2.1) 03/06/1999 1999001 Pri: ENG NRC Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 POS Pii: 4B Sec: 4C Ter: 5C Accuracy of Unit 1 feedwater flowindications Engineering support and written evaluations to address questions involvinq the accuracy of Unit 1 feedwater flow indications were comprehensive and technically sound.
Management decisions throughout the investigation were conservative.
Facility Review Group involvement was evident (Section E1.1).
01/23/1999 199801243 Pri: ENG Licensee NCV Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: 2B Sec:
Ter.
Control Room Outside AirIntake Radiation MonitorTrip Point Set Greater than TS Limit The licensee identified procedural deficiencies associated with the control room outside air intake radiation monitors.
Technical Specification requirements for actuation set points and testing were not met. Two Non-Cited Violations were identified. Corrective actions were appropriate and the Licensee Event Report met all reporting requirements.
(Section E8.2)
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE2 01/23/1999 1998012-04 Pri: ENG l.icensee NCV Pri:
Sec:
Sec:
Ter:
Failure to Adequately Test the Actuation Logic for the Control Room Emergency Cleanup System Failure to adequately test all portions of the actuation logic for the CROAI radiation monitors is a violation of TechnicalSpecification Table4.3-3. Thiswasa non-repetitive, licensee identified andcorrectedviolation.
Item Type (Compliance,Followup,Other), From 10/01/1998 To 09/30/1999
Page:
13 of 20 10/13/1999 06:24:18 IR Report 3 Region II ST LUCIE Date Source Functional Area United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Template Item Title ID Type Codes Item Description 12/12/1998 1998011%1 Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Prl: ENG Sec: MAINT NRC VIOIV Pri: 5C Inadequate Corrective Actions Taken To Restore Unit 2 Containment Sumps To Design Requirements Sec: 5A Insufficiently comprehensive inspections during the 1997 Unit 2 refueling outage resulted in a failure to promptly identify and correct conditions adverse to quality. Aviolation was identified.
The inadequate corrective actions Ter. 2B resulted in inaccurate information being provided to the NRC in that the sump was not restored to design requirements as was indicated.
Initial inspections conducted this refueling outage were not adequate.
After additional discrepancies were identified by NRC inspectors and licensee personnel, licensee management recognized that a detailed inspection of the sump was necessary.
The licensee consequently identified that the corrective actions had not been adequate.
Thorough corrective actions were subsequently completed and a detailed report was submitted.
(Section E8.2) 10/31/1998 1998010 Pri: ENG Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 NRC POS Pri: 4B Sec: 4C Ter: 4A Pre-planning for Plant Change/Modification Plant Change/Modification (PC/M) 976431, Generic Letter 96%6 Thermal Pressurization Relief Valves had good pre-planning.
The package was detailed and complete, induding the justification for the modification, and post-installation testing requirements.
Pipe stress calculations were dear and accurate.
Allassumptions and references were dearly stated (Section E1.1).
10/31/1998 1998010-02 Pri: ENG Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Licensee NCV Pri: 4C Failure to Adequately Test ESFAS Relays Sec: 4B TS 4.3.2.1 required that all ESFAS subgroup relays not specifically exempted in FSAR table 7.3-9a shall be tested semi-annually.
The licensee failed to test these two relays at this interval from initial staitup until June 30, 1997.
Ter: 2B 08/21/1999 1999005 Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: PLTSUP Sec:
NRC POS Pri: 1C Health Physics response to a contamination event Sec:
Health Physics response to a contamination event was in accordance with licensee procedure and exhibited appropriate radiological control practices.
(Section R4.1)
Ter:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 07/10/1999 1999004 Pri: PLTSUP NRC POS Pri: 1C Radioactive effluent releases Sec:
Sec:Radioactive eNuent releases and resultant doses were maintained within Technical Specifications, 10 CFR Part 20, Offsite Dose Calculation Manual limits, and the design objectives ofAppendix I to 10 CFR Part 50.
(Section R3.1)
Ter:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 07/10/1999 1999004 Pri: PLTSUP NRC POS Pi'i: 1C Occupational worker doses for calendar year 1998 and year-to-date 1999 Sec:
Sec:
Occupational worker doses were within regulatory limits for CY98 and YTD99. ALARAprogram implementation was conducted in accordance with approved procedures, and YTD99 cumulative exposure results met established goals.
Ter:
(Section R1.2)
Item Type (Compliance,Foilowup,Other), From 10/01/1998 To 09/30/1999
Page:
14 of 20 10/13/1 999 06:24:18 IR Report 3 Region II ST LUCIE Date Source Functional Area United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Template Item Title ID Type Codes Item Description Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 07/10/1999 1999004 Pri: PLTSUP NRC POS Pri: 1C Overall radiological controls Sec:
Sec: 3A Radiological controls were maintained and implemented in accordance with the Updated Final Safety Analysis Report, Technical Specifications, and 10 CFR Part 20 requirements.
Disposal of high level radwaste from the Unit 1 Ter: 2B spent fuel pool was particularly well controlled. (Sections R1.1 and 07/10/1999 1999004 Pri: PLTSUP NRC POS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: 1C Sec: 5A Ter: 5C Audit program activities for the radiation protection and effluen program areas Audit program activities were implemented effectively for the radiation protection and effluent program areas.
In general, follow up actions for issues identified in Condition Reports associated with radiation protection or effluen program activities were appropriate and completed in a timely manner.
(Section R7.1) 05/29/1999 1999003 Prl: PLTSUP NRC POS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: 1C Security officers served as roving Fire Protection Program watches Sec: 3A Security officers completing Fire Protection Program requirements for roving fire watches as part of their dedicated patrols were knowledgeable of their fire watch responsibilities.
The fire watch tours were routinely being T<<: 3B accomplished more frequently than specified by regulatory requirements (Section S1.1).
04/17/1999 1999002 Prl: PLTSUP NRC POS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: 1C Sec: 3A Ter.
Annual emergency preparedness exercise scenario The annual emergency preparedness exercise scenario was well crafted and challenged the emergency response organization.
Communications and coordination between the emergency response facilities were effective.
Licensee declarations of progressively higher emergency action level classifications were consistent with implementing procedures and the simulated deterioration of plant conditions.
(Section P1.1) 04/17/1999 1999002 Pri: PLTSUP NRC POS Pri: 1C Routine radiological surveys
'4 Sec:
Sec: 3B Routine radiological surveys were completed by knowledgeable technicians using efficient and conservative methods.
(Section R4.1)
Ter. 3A Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE2 Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE2 04/16/1999 1999010 Prl: PLTSUP NRC MISC Pri: 1C Changes to the Physical Security Plan Sec:
Sec:
Changes to the Physical Security Plan submitted by the licensee were generally satisfactory.
The inspectors identified that the licensee failed to submit a revision to the Physical Security Plan when the response station was no Ter:
longer utilized (Section S3.1).
Item Type (Compliance,Followup,Other), From 10/01/1998 To 09/30/1999
Page:
15 of20, 10/13/1999 06:24:18 IR Report 3 Region II ST LUCIE Date Source Functional Area United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Template Item Title ID Type Codes Item Description 04/16/1999 1999010 Pri: PLTSUP NRC NEG Pri: 1C Security officer continuous communication Sec:
Sec:
Two examples were identified in which officers, for a brief period of time, did not maintain the capability for continuous communication with an individual in the Central or Secondary Alarm Station (Section S1.3).
Ter:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE2 04/16/1999 1999010 Pri: PLTSUP NRC NEG Pri: 3A Low number of Condition RePorts generated by Security Sec:
Sec:
Security generated a tower number of Condition Reports than actual problems that had been identified and corrected (Section S7.4).
Ter:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 04/16/1999 1999010-02 Prl: PLTSUP NRC NCV Pri: 1C Failure to Detect Test Explosive Device
'ec:
Sec: 3A One Non-Cited Violation of regulatory requirements was identified when the inspectors bypassed one of the explosive detectors with a test source due to configuration of the metal and explosive detectors (Section S.2.2).
Ter.
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 04/16/1999 199901043 Prl: PLTSUP NRC NCV Pri: 3A Security Shift Specialist Duties Interfere with Abilityto Direct in Emergencies Sec:
Sec: 1C One Non4 ited Violation was identified in that, in some instances, duties ofthe Security Shift Specialist were not being performed as required in the Physical Security Plan (Section S6.2).
Ter.
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: 1C Inadequate fire protection procedure Sec:
A Severity Level IIIViolation was identified for an inadequate fire protection procedure that intended to implement the alternative shutdown capability In the event of a main control room evaculation.
Procedures did not ensure Ter:
habitability of hot shutdown control panel room under certain conditions.
EEI 50-335, 389/99-1444 was closed.
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 03/31/1999 1998014-11 Pri: pLTSUp Licensee NCV Pri: 1C Failure to install a one hour rated fire barrier for charging pump 1A Sec:
Sec:
A Non-Cited Violation was identified for failure to install a one hour rated fire barrier for charging pump.1 A.
T<<EEI 50-335, 389/98-1445 was dosed.
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 t
03/31/1999 1998014-10 Pri: PLTSUP Licensee VIOIII Sec:
Item Type (Compliance,Foliowup,Other), From 10/01/1998 To 09/30/1999
Page:
16 of 20 10/13/1999 06:24:18 IR Report 3 Region II ST LUCIE Date Source Functional Area United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Template Item Tiue ID Type Codes Item Description 03/31/1999 1998014-12 Pri: PLTSUP NRC NCV Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 03/06/1999 1999001 Pri: PLTSUP NRC NEG Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 03/06/1999 1999001 Pri: PLTSUP NRC NEG Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE2 03/06/1999 1999001 Pri: PLTSUP NRC POS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: 1C Sec:
Ter:.
Prl:1C Sec: 2A Ter:
Pri: 2B Sec: 3A Ter:
Pri: 1C Sec: 2A Ter:
Failure to limitfire damage for 1A low pressure safety Injection pump A Non-Cited Violation was identified for failure to limitfire damage so that one train of a system (in this case, the train A shutdown cooling equipment, including the low pressure safety injection 1A pump) was free from fire damage as required by Section III.G.1 ofAppendix R to 10 CFR 50.
EEI 50-335, 389/98-14-06 was dosed.
Poor radiological practice A poor radiological practice resulting in decreased effectiveness of labels, contamination controls, and As Low As Reasonably Achievable program implementation was identified associated with the Unit 1 drumming facility locked-high radiation area.
(Section R1.1)
Counting room gammawpectroscopy Quality Control activities Counting room gamma-spectroscopy Quality Control activities and inter-laboratory analyses were implemented appropriately and no negative trends were identified. The addition of standard deviation to the observed value of a quality control spiked sample in order to meet acceptance criteria was identified as a poor practice (Section R7.1).
Low-level radioactive waste storage areas The licensee continued to consolidate low-level radioactive waste storage areas and reduce quantities of solid radioactive waste stored onsite.
Excluding the Unit 1 drumming facility, selected radiological control area locations were uncluttered.
Area postings, container labels, and radiological controls were maintained in accordance with regulatory requirements (Section R1.1).
03/06/1999 1999001 Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: PLTSUP Sec:
NRC POS Pri: 1C Sec: 2B Ter:
Radiation Monitor System (RMS) detector and electronic calibrations Radiation Monitor System (RMS) detector and electronic calibrations were conducted at required frequencies and met established acceptance criteria. The Unit 2 emergency core cooling system particulate sample line installation contained 90 degree bends immediately preceding the sample filterhousing. This configuration is not recommended and could adversely affect sample accuracy.
In general, RMS equipment and sample lines were installed in accordance with the Updated Final Safety Analysis Report, configuration control diagrams, and acceptable industry practices (Section R1.2).
Dockets Discussed:
, 05000335 ST LUCIE 1 05000389 ST LUCIE 2 03/06/1999 1999001%3 Pri: PLTSUP Licensee NCV Pri: 1C HP Technician Exceeded TS Overtime Limits Sec:
Sec: 3A The licensee identified that a Health Physics technician exceeded Technical Specification overtime limits by working 29 hours3.356481e-4 days <br />0.00806 hours <br />4.794974e-5 weeks <br />1.10345e-5 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period. A nonmted violation was issued (Section R6.1)
Ter:
Item Type (Compliance,Followup,Other),
From 10/01/1998 To 09/30/1999
Page:
17 of 20 10/13/1999 06:24:18 IR Report 3 Region II ST LUCIE Date Source Functional Area United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Template Item Title ID Type Codes Item Description 01/23/1999 1998012 Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE2 Prl: PLTSUP Sec:
NRC POS Pri: 1C Sec:
Ter:
Alarm stations and communication systems Alarm stations and communication systems were effective and adequate to meet regulatory requirements and commitments of the licensee's Physical Security Plan.
Compensatory measures observed and reviewed through documentation were appropriate and within the Physical Security Plan requirements.
Security officers were appropriately trained and qualified.
(Sections S1.2, S2.3, and S5.1)
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 01/23/1999 1998012 Pri: PLTSUp NRC pOS Pri: 1C Testing and maintenance program for physical protection related equipment Sec:
Sec: ZB The licensee had implemented a testing and maintenance program that ensured that the physical protection related equipment and security related devices were properly installed, tested, and maintained.
(Section S2.2)
Ter.
01/23/1999 1998012 Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: PLTSUP Sec:
NRC POS Pri: 1C Sec: 3A Ter:
Daily primary coolant sampling Correct procedures were followed by the chemistry technician to collect a Unit 2 daily primary coolant sample and conduct analyses.
The Unit 2 Hot Laboratory and equipment conditions were observed to be adequate for the performance of the work. The technician used appropriate methods to prevent unnecessary exposure and spread of contamination.
Analysis results were properly reviewed, compared against trend data, and documented.
(Section R4.1) 12/12/1998 1998011 Pri: pLTSUP NRC POS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE2 12/12/1998 1998011 Pri: PLTSUP NRC POS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: 1C Sec: 3A Ter:
Pri: 1C Sec: 3A Ter': 3B Personnel radiation exposure during the Unit 2 Refueling Outage The licensee was properly monitoring and controlling personnel radiation exposure during the Unit 2 Refueling Outage and posting area radiological conditions in accordance with 10 CFR Part 20. The licensee had implemented an effective shutdown chemistry control plan and closely monitored primary coolant chemistry during the shutdown for the Unit 2 Refueling Outage.
(Section R1.2)
Health Physics technicians performance Health Physics technicians observed by the inspectors were aware of plant status and provided good coverage for the work forwhich they were responsible, ensuring that personnel exposure was controlled in accordance with the licensee's ALARA(As Low As Reasonably Achievable) program. (Sections R1.1 and R4.1)
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 11/06/1998 1998014-01 Pri: pLTSUP NRC VIOIV Pri:
Failure to Follow Combustible Control Procedures Sec:
Sec:
Aviolation of procedural requirements was identified for not managing the use and temporaiy storage of transient combustibles in safety-related areas. (Section F8.2).
Ter.
Item Type (Compliance,Followup,Other), From 10/01/1998 To 09/30/1999
Page:
18of20 10/13/1999 06:24:18 IR Report 3 Region II ST LUCIE Date Source Functional Area United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Template Item Title ID Type Codes Item Description Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 1998014<3 pri: PLTSUP NRC NCV Pri:
Failure to Conduct Timely Corrective Action for identified Post-Fire Safe<hutdown Procedural Deficiencies.
Sec:
Sec:
A nonmted violation was identified for the failure to conduct. timely corrective action for identified post-fire safe-shutdown procedures. (Section F8.7)
Ter.
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE2 11/06/1998 1998014-02 Pri: PLTSUP NRC VIOIV Pri:
Failure to Maintain the Fire Fighting Strategies Sec:
Sec:
Aviolation was identified for failure to maintain the fire fighting strategies to reflect the requirements of the approved Fire Protection Program and 10 CFR Part 50, Appendix R. (Section F8.4).
Ter:
11/06/1998 199801447 Pri: PLTSUP NRC EEI Pri:
Sec:
Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Ter:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Ter:
11/06/1998 199801448 Pri: PLTSUP NRC NCV Sec:
Sec:
Ter.
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE2 11/06/1998 1998014%9 Pri: pLTSUp NRC NCV Pri:
Sec:
Sec:
Failure to Implement and Maintain in Effect Provisions of the NRC Approved Fire Protection Program An apparent violation was identified for failure to implement and maintain in effect the provisions of the NRC approved Fire Protection Program and Appendix R, Sections III.G.1.a and III.L.7. This issue involved the licensee's analysis and method of protection for fire-induced spurious equipment operations. (Section F8.8.d).
Failure to Provide Emergency Lighting and Post-Fire Safe Shutdown Communications A non4ted violation was identified for the failure to provide emergency lighting and post-fire safe-shutdown communications that meet the requirements of the NRC approved Fire Protection Program and Appendix R Section III.J. This issue involved the lack of emergency lighting and cummunications to support post-fire safe shutdown procedural operator manual actions.
(Section F8.8.h)
Failure to Implement and Maintain in Effect Provisions of the NRC Approved Fire Protection Program A non-cited violation was identified for failure to implement and maintain in effect the provisions of the NRC approved Fire Protection Program for fire hose stations.
This issue involved the design and testing requirements of the licensee's standpipe and fire hose system.
(Section F8.9) 10/31/1998 1998010 Prl: pLTSUP NRC POS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 Pri: 1C Sec: 3A Ter:
Implementation of site security plan requirements Security and plant personnel performed their responsibilities in a manner consistent with site security plan requirements.
Overall ~ security facilities and equipment were operating well and maintained in a condition to ensure physical protection of the plant (Sections S1.1 and S2.1).
Item Type (Compliance,Followup,Other), From 10/01/1998 To 09/30/1999
Page:
19 of 20 10/13/1999 06:24:18 IR Report 3 Region II ST LUCIE Date Source Functional Area United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Template Item Title ID Type Codes Item Description 10/31/1998 1998010 Prl: PLTSUP NRC POS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE 2 10/31/1998 1998010 Prl: PLTSUP NRC POS Sec:
Dockets Discussed:
05000335 ST LUCIE 1 05000389 ST LUCIE2 Prl:1C Sec: 3B Ter:
Pri: 3A Sec: 3B Ter:
Emergency planning drill using Severe Accident Management Guidelines The licensee's first emergency planning drillof their newly developed Severe Accident Management Guidelines (SAMG) was a useful training experience for the emergency response organization.
Recommendations were properly reviewed, clarifying details were requested, corrections made as necessary, and proper authorization was granted to implement them (Section P1.1).
Control of the Unit 2 spent resin transfer activities by Health Physics Overall coordination and control of the Unit 2 spent resin transfer activities by Health Physics (HP) were very effective and exhibited a high degree of attention to all details of this evolution. Numerous radiological precautions were taken during the preparation phase to prevent inadvertent spills and limitpersonnel exposures.
Personnel from HP and Operations organizations worked closely together to ensure a successful transfer (Section R1.1).
Item Type (Compliance,Followup,Other), From 10/01/1998 To 09/30/1999
Page:
20 of 20 10/13/1999 06:24:18 IR Report 3 United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Legend Type Codes:
Template Codes:
Functional Areas:
BU Bulletin CDR Construction DEV Deviation EEI Escalated Enforcement Item IFI Inspector follow-up item LER Licensee Event Report LIC Ucensing Issue MISC Miscellaneous MV MinorViolation NCV NonCited Violation NEG Negative NOED Notice of Enforcement Discretion NON Notice of Non-Conformance OTHR Other P21 Part21 POS Positive SGI Safeguard Event Report STR Strength URI Unresolved item VIO Violation
'K Weakness 1A Normal Operations 1B Operations During Transients 1C Programs and Processes 2A Equipment Condition 2B Programs and Processes 3A Work Performance 3B KSA 3C Work Environment 4A Design 4B Engineering Support 4C Programs and Processes 5A Identification 5B Analysis SC Resolution ID Codes:
NRC NRC Self Self-Revealed Licensee Licensee OPS MAINT ENG PLTSUP OTHER MISC Operations Maintenance Engineering Plant Support Other Miscellaneous EEls are apparent violations of NRC Requirements that are being considered for escalated enforcement action in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Action"(Enforcement Policy), NUREG-1600. However, the NRC has not reached its final enforcement decision on the issues identified by the EEls and the PIM entries may be modified when the final decisions are made.
URls are unresolved items about which more information is required to determine whether the issue in question is an acceptable item, a deviation, a nonconformance, or a violation. A URI may also be a potential violation that is not likelyto be considered for escalated enforcement action. However, the NRC has not reached its final conclusions on the issues, and the PIM entries may be modified when the final conclusions are made.
Item Type (Compliance,Followup,Other), From 10/01/1998 To 09/30/1999
ST. LUCIE INSPECTION PLAN OCTOBER 1, 1999 THROUGH MARCH 31, 2000 INSPECTION PROCEDURE/
TEMPORARY INSTRUCTION PROGRAM DIRECTIVE-NUREG-1021 TITLE/PROGRAMAREA OPERATOR - INITIAL EXAM-PREPARATION INITIALEXAM NUMBER OF INSPECTORS OPERATIONS PLANNED INSPECTION DATES 1/2000 2/2000 TYPE OF INSPECTION-COMMENTS INITIALEXAM IP 71001 OPERATOR-REQUALIFICATIONS 11/1999 CORE INSPECTION PROGRAM IP 40500 CORRECTIVE ACTION PROGRAM 1/2000 CORE INSPECTION PROGRAM
INSPECTION PROCEDURE/
=
TEMPORARY INSTRUCTION NONE TITLE/PROGRAMAREA NUMBER OF INSPECTORS MAINTENANCE PLANNED INSPECTION DATES TYPE OF INSPECTION-COMMENTS ENGINEERING IP 92904 ENGINEERING-FOLLOW-UP FIRE PROTECTION 12/1999 REGIONAL INITIATIVE-TO CLOSE OPEN ITEMS IP 37001/37550 ENGINEERING AND 50.59 INSPECTIONS 2/2000 (2 Weeks)
CORE INSPECTION PROGRAM
INSPECTION PROCEDURE/
TEMPORARY.
INSTRUCTION
'ITLE/PROGRAMAREA NUMBER OF INSPECTORS PLANNED INSPECTION DATES TYPE OF INSPECTION-C,OMMENTS IP 84750 RADIOACTIVEWASTE TREATMENT,AND EFFLUENT AND ENVIRONMENTAL MONITORING PLANT SUPPORT 11/1999 CORE INSPECTION PROGRAM IP 86750 SOLID RADIOACTIVE WASTE MANAGEMENT AND TRANSPORTATION OF RADIOACTIVE MATERIALS IP 83750 OCCUPATIONAL RADIATIONEXPOSURE 2/2000 CORE INSPECTION PROGRAM IP 84750 RADIOACTIVEWASTE TREATMENT,AND EFFLUENT AND ENVIRONMENTAL MONITORING
INSPECTION PROCEDURE/
TEMPORARY INSTRUCTION IP 82701 TITLE/PROGRAMAREA OPERATIONAL STATUS OF THE EMERGENCY PREPAREDNESS NUMBER OF INSPECTORS PLANNED INSPECTION DATES 11/1 999 TYPE OF INSPECTION-COMMENTS CORE INSPECTION PROGRAM
Distri92.txt Distribution Sheet Ju('flfi Priority: Normal From: Linda Eusebio Action Recipients:
W Gleaves Copies:
1 Not Found Internal Recipients:
NRR/DIPM/EPHP
,IRO D Hagan Not Found Not Found Not Found External Recipients:
NRC PDR NOAC Not Found Not Found Total Copies:
Item:
ADAMS Document Library:
ML ADAMS"HQNTAD01 ID: 993140163
Subject:
ACTIVATION AND OPERATION OF THE OPERATIONAL SUPPORT CENTER Body:
Docket:
- 05000335, Notes:
N/A Docket:
- 05000389, Notes:
N/A Page 1
~~,
a- ~
gA/~8489 FPL
Title:
Mrf ST. LUCIE PLANT EMERGENCY PLAN IMPLEMENTINGPROCEDURE SAFETY RELATED Procedure No.
EPIP-05 Current Rev. No.
3 Effective Date:
03/09/99 ACTIVATIONAND OPERATION OF THE OPERATIONAL SUPPORT CENTER Responsible Department:
Revision Summary TRAINING Revision 3 - Added OSC Information Services Rep position and responsibilities to procedure and added editorial changes.
(J. R. Walker, 3/2/99)
PSL OO OO PROCEDURE PRODUCTION Revision FRG Review Date 12/1 5/97 Revision FRG Review Date 3/2/99 Approved By J. Scarola Plant General Manager Approved By R. G. West Plant General Manager Approval Date 12/1 5/97 Approval Date 3/2/99 S
OPS DATE DOCT PROCEDURE DOCH EPIP-05 sYs COMP COMPLETED ITM 3
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