ML17309A831
| ML17309A831 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 03/28/1996 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Plunkett T FLORIDA POWER & LIGHT CO. |
| Shared Package | |
| ML17228B446 | List: |
| References | |
| EA-96-040, EA-96-40, NUDOCS 9604090108 | |
| Download: ML17309A831 (5) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSlON REGION II 101 MARIETTASTREET, N,W., SUITE 2900 ATLANTA,GEORGIA 303234199 March 28, 1996 EA 96-040 Florida Power and Light Company ATTN:
Mr. T. F. Plunkett President - Nuclear Division P. 0.
Box 14000 Juno Beach, Florida 33408-0420
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY-
$50,000 (NRC Inspection Report No. 50-335/96-03 and 50-389/96-03)
Dear Mr. Plunkett:
This refers to the special followup inspection at the St. Lucie facility conducted on January 26-30 and February 8, 1996, with regard to a Unit 1
overdilution event which occurred on January 22, 1996.
The results of our inspection were sent to you by letter dated February 22, 1996.
A closed predecisional enfo1'cement conference was conducted in the Region II office on March 8, 1996, with members of your staff (including the licensed operators involved in the event) to discuss the apparent violations, the root causes, and your corrective actions to preclude recurrence.
A sumary of the conference was sent to you by letter dated March 13, 1996.
Based on the information developed during the inspection and the information that you provided during the conference, the NRC has determined that violations of NRC requirements occurred.
These violations are cited in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) and the circumstances surrounding them are described in detail in the subject inspection report.
Violation A, described in the enclosed Notice, involved a
serious lapse of attention to control room activities by a licensed operator.
The operator failed to follow procedures for reactor coolant system boron dilution and failed to monitor a planned dilution evolution requiring the addition of between 25 and 40 gallons of primary makeup water which should have taken less than a minute to perform.
This resulted in an unplanned reactivity addition in that the operator failed to stop the addition of primary makeup water until approximately 400 gallons were added.
In addition, the operator and other crew members conducted an inadequate watch turnover.
During the event, the temporary relief operator at the controls and the senior reactor operator were unaware that a boron dilution was in progress.
The event also demonstrated operator performance problems in that:
(1) the method routinely used by St. Lucie operators to dilute the reactor coolant system was not authorized by procedure; (2) the method used was not as described in the Updated Final Safety Analysis Report (UFSAR); (3) operators routinely performed the dilution procedure from memory when the dilution procedure was designated by administrative requirements as one requiring referral to the written procedure; and (4) operators failed to give prompt verbal notification 9604090i08 960328 PDR ADQCK 05000335 8
FPL to the Operations Supervisor of the unplanned reactivity change that had occurred.
As a result of these operator errors, 100 percent reactor power was exceeded on January 22, 1996.
Violation B involved inadequate design control in that the method stated in the UFSAR for adding demineralized water and boric acid to the reactor coolant system was not appropriately translated into plant operating procedures.
This condition has existed since plant licensing in January 1976 and during the periodic reviews of this procedure required by Technical Specification 6.8.2, you failed to identify the.discrepancy.
The root cause of this violation was the failure to implement a comprehensive review of procedural requirements against the operational methods described in the UFSAR.
Violation C involved a change that was made to the Unit 1 operating procedure for reactor coolant system boron dilution on January 23, 1996, that again differed from the method stated in the UFSAR, without performing a required safety evaluation.
The UFSAR states that boron dilution must be conducted in automatic and described a flow path into the volume control tank.
- However, under a temporary change to the operating procedure, instructions were added for dilution in manual mode with a flowpath directly to the suction of the charging pumps.
The temporary change allowed the addition of positive reactivity faster than the method described in the UFSAR and without an automatic shutoff.
The temporary change was implemented on January 23,
- 1996, without a written safety evaluation providing a basis fot this change.
The root cause of Vi'olation C was a weakness in the screening process for 10 CFR 50.59 safety evaluations of procedural changes.
The safe operation of your nuclear facility requires strict attention to plant operating conditions particularly when reactivity changes are in progress.
The actual safety consequences of this event were low because the operator recognized his error and the crew took prompt actions to restore plant parameters.
Consequently, 100 percent power level was exceeded for only a short period of time.
- However, the event is of significant regulatory concern due to the poor performance practices exhibited by your licensed operating staff and the inadequate control and evaluation of operating procedure requirements before and after the event.
In addition, the NRC is concerned that management failed to set clear standards regarding operator attentiveness, watch station turnovers, and oversight of control room activities and protocol.
Other weaknesses were identified with regard to operating experience
- feedback, instrumentation and alarm settings, and management guidance on maintaining operating parameters close to Technical Specification limits.
Therefore, these violations are classified in the aggregate in accordance with the "General Statement of policy and procedure for NRC Enforcement Actions" (Enforcement Policy),
NUREG-1600, as a Severity Level III problem.
In accordance with the Enforcement Policy, a base civil penalty in the amount of $50,000 is considered for a Severity Level III problem.
Because your facility has been the subject of escalated enforcement actions within the last
FPL 2 years,'he NRC considered whether credit was warranted for Identificatfon and Corrective Action in accordance with the civil penalty assessment'process in Section VI.B.2 of the Enforcement Policy.
In this case, the NRC has concluded that it would not be appropriate to give credit for Identification because the violations were identified as a result of an event and there were prior opportunities to identify and correct the deficiencies.
We are also concerned that your operating experience program failed to ensure that adequate corrective action was taken when you wer e advised of a similar overdilution event at Florida Power and Light Company's Turkey Point facility.
With regard to consideration for Corrective Action, your immediate corrective actions included restoring. plant parameters and conducting an investigation of the event.
Your planned long-term corrective actions were comprehensive and
- included, in part: (I) corrective actions to address management issues and clarify management expectations for operating crew performance; (2) revisions of appropriate procedures and policies for reactor coolant system dilution; (3) comprehensive review of compliance with the UFSAR; (4) changes to. the 10 CFR 50.59 screening process; and (5) counseling and training plant staff.
The NRC determined that credit was warranted for the factor of Corrective Action, and that a base civil penalty is appropriate.
Therefore, to emphasize the importance of control over operational activities affecting safe plant operations and in consideration of your previous escalated enforcement
- actions, I have been authorized, after consultation with the Director, Office of Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) in the base amount of
$50,000 for the Severity Level III problem.
You are required to respond.to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.
In your
- response, you should document the specific actions taken and any additional actions you plan to prevent recurrence.
After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice,"
a copy of this letter, its enclosure, and your response will be placed in the NRC Public Document Room (POR).
To the extent possible, your response should not include Severity Level III problem with a proposed civil penalty of $50,000 was issued on November 13, 1995 (EA 95-180), for inoperability of the low temperature overpressure protection feature due to PORV failure.
FPL any personal privacy, proprietary, or safeguards information so that.it can be placed in the POR without redaction.
Sincerely, Docket No. 50-335 License No.
OPR-67 ewart
. Ebneter Regional Administrator
Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty cc w/encl:
(See Next Page)
FPL cc w/encl:
B. Bohlke Vice President St. Lucie Nuclear Plant P.
O.
Box 128 Ft. Pierce, FL 34954-0128 H. N. Paduano, Manager Licensing and Special Programs Florida Power and Light Company P.
O.
Box 14000 Juno
- Beach, FL 33408-0420 J. Scarola Plant General Manager St.
Lucie Nuclear Plant P.
O.
Box 128 Ft. Pierce, FL 34954-0128 E.
Weinkam Plant Licensing Manager St.
Lucie Nuclear Plant P. 0.
Box 128 Ft. Pierce, FL 34954-0218 J.
R.
- Newman, Esq.
- Morgan, Lewis 8 Bockius 1800 H Street, NW Washington, D.
C.
20036 John T. Butler, Esq.
- Steel, Hector and Davis 4000 Southeast Financial Center
- Hiami, FL 33131-2398 Bill Passetti Office of Radiation Control Department of Health and Rehabilitative Services 1317 Winewood Boulevard Tallahassee, FL 32399-0700 Jack Shr eve Public Counsel Office of the Public Counsel c/o The Florida Legislature.-
lll West Madison Avenue, Room 812 Tallahassee, FL 32399-1400 Joe Hyers, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, FL 32399-2100 Thomas R. L. Kindred County Administrator St. Lucie County 2300 Virginia Avenue Ft. Pierce, FL 34982 Charles B. Brinkman Washington Nuclear Operations ABB Combustion Engineering, Inc.
12300 Twinbrook Parkway, Suite 3300 Rockville, MD 20852