ML17309A887

Forwards Schedule for Completion of Corrective Actions Planned for Ifis & Ufis in Response to NRC Insp Repts 50-335/96-201 & 50-389/96-201

ML17309A887
Person / Time
Site:	Saint Lucie
Issue date:	05/27/1997
From:	Stall J FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-335-96-201, 50-389-96-201, L-97-139, NUDOCS 9706030192
Download: ML17309A887 (14)

Text

~ cATEGoRY 10 (RIDS)

REGULATORY INFORMATION DISTRIBUTION SYSTEM CCESSION NBR:9706030192 DOC.DATE: 97/05/27 NOTARIZED: NO DOCKET g ACIL:50-335 St. Lucie Plant, Unit 1, Florida Power & Light Co. 05000335 50-389 St. Lucie Plant, Unit 2, Florida Power & Light Co. 05000389 AUTH. NAME AUTHOR AFFILIATION STALLiJ.A. Florida Power & Light Co.

RECIP. NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Forwards schedule for completion of corrective actions for IFIs & URIs noted in insp repts 50-335/96-201 &50-389/96-201 on 961118-970110.

DISTRZSUTION CODE: TEOID COPIES RECEIVED:LTR TITLE:,General (50 Dkt)-Insp Rept/Notice 1 ENCL of Violation g SIZE:

Response

E NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-3 PD 1 1 WIENSIL. 1 1 INTERNAL: ACRS 2 2 AEOD/SPD/RAB 1 1 AEOD TTC 1 1 DEDRO 1 1 Y CENTE 1 1 NRR/DISP/PIPB 1 1 HHFB 1 1 NRR/DRPM/PECB 1 1 NRR/DRPM/PERB 1 1 NUDOCS-ABSTRACT 1 1 OE DIR 1 1 OGC/HDS3 1 1 RGN2 FILE 01 1 1 EXTERNAL: LITCO BRYCEEJ H 1 1 NOAC 1 1 D NRC PDR 1 1 NUDOCS FULLTF 7 1 1 0

U M

E N

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 20 ENCL 20

Florida Power & Light Company, 6501 South Ocean Drive, Jensen Beach, FL 34957 May 27, 1997 L-97-139 10 CFR 50.4 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 RE: St. Lucie Units 1 and 2 Docket Nos. 50-335/389

Reference:

NRC Inspection Report Nos. 50-335/96-201 and 50-389/96-201 From November 18, 1996 through January 10, 1997, the NRC performed a design inspection of the St. Lucie Unit 1 Auxiliary Feed Water (AFW) system and the St. Lucie Unit 2 Component Cooling Water (CCW) system. The purpose of the inspection was to evaluate the capability of the inspected systems to perform their required design basis functions, to adhere to the design and licensing basis, and to conform to the UFSAR. The inspection results were documented in the above reference.

Included in attachment 1 to the inspection report is a listing of inspector follow-up and unresolved items. In response to the NRC report, attached is the schedule for completion of the corrective actions planned for the IFIs and URIs. I Please contact us if there are any questions about this submittal.

Very truly yours, J. A. Stall Vice President St. Lucie Plant JAS/KWF cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St. Lucie Plant Robert M. Gallo, Special Inspection Branch, NRR 9706030192 970527 PDR ADOCK 05000335 8 PDR ilLiliIlllIlill)iilIlllllllklllIll an FPL Group company

0 L-97-139 Attachment Page 1 AE AUDIT IFI/URI COMPLETION SCHEDULE/STATUS IFI 50-335/96-201-01 Condensate Storage Tank (CST) Volume Requirements Status: 1. The CST volume requirements will be reviewed and the calculations revised as necessary. The current-U1 and 2 CST Technical Specification volume requirements will be reviewed, based on the calculations, and a Proposed License Amendment (PLA),

5, 1997.

if required, will be submitted by December 2 ~ The UFSAR and Design Bases Document (DBD) change packages will be developed to reflect the new calculations and assumptions by January 31, 1998.

3. The Plant procedures and Emergency Operating Procedures (EOPs) will be reviewed and revised to reflect the new calculations by April 30, 1998.

IFI 50-335/96-201-02 Calculations and Indication for Auxiliary Feed Water (AFW) Flow Status: All calculations and required modifications will be completed by the end of the Fall Unit 1 Cycle 15 Refueling outage.

IFI 50-335/96-201-03 AFW Crosstie Net Positive Suction Head Available (NPSHA) Calculation Status: The calculation to document the exact NPSHA for the Ul AFW pumps when taking suction from the U1 and U2 CST will be completed by September 30, 1997.

IFI 50-335/96-201-04 Calculation Revision for AFW Piping Supports Status: 1. The containment check valve testing procedure (1-0700050, Rev. 60) was revised to include testing of AFW check valves every outage. This activity's complete.

2. The review of the AFW system piping and supports will be completed by February 28, 1998.

L-97-139 Attachment Page 2 URI 50-335/96-201-05 Environmental Qualification (EQ) of Woodward Governor Controls

Background:

The Terry Turbine Governor Control panel is located in the turbine pump area underneath the main steam and feedwater trestle. EQ Documentation Package (Doc Pack) 1000 discusses a feedwater or main steam high energy break in this area. This break would make the area a harsh environment as defined in 10 CFR 50.49 and would require that the equipment be qualified for its operating environment by either testing or analysis. The A/E inspection team determined that 10 CFR 50.49 requires environmental qualification of the Terry Turbine Governor Control.

Response: The licensing basis for the EQ qualification requirements of the Terry Turbine Governor Control was researched and documented in Condition Report (CR) 97-0046. The Main Steam and Auxiliary Feedwater Systems were evaluated as part of IE Bulletin 79-01B. In the FPL response dated September 30, 1981, FPL stated that the steam trestle was an outdoor area and that when consideration was made of the postulated MSLB and the size of the equipment vent relief area compared with the compartment volume to the conclusion that the pressure it spike would lead would be dissipated almost immediately. The resultant air temperature spike would be of very short duration such that the equipment would not in effect experience a harsh environment. The Franklin Research Center, as contractor for the NRC to review the 79-01B EQ files, agreed with FPL and indicated in their Technical Evaluation Report dated Feb 28, 1983 that the equipment in the steam trestle area was in a "mild" environment and outside the scope of IEB 79-01B. The NRC provided their concurrence in the Safety Evaluation for Environmental Qualification of Safety-Related Electrical Equipment dated April 21, 1983.

Status: This item is complete.

IFI 50-335/96-201-06 Full Flow Testing of AFW Crosstie Status: '. The Unit 2 to Unit 1 CST cross connect valves will be included in the ASME Section XI test program and procedures by June 30, 1997.

L-97-139 Attachment Page 3 2 ~ A full flow test of the CST cross tie will be performed during the Unit 1 Cycle 15 refueling outage.

URI 50-335/96-201-07 Lack of Testing and Operating Procedures for DC Breaker Crossties

Background:

FPL identified an issue concerning a lack of procedures and testing for switching DC control power to the turbine driven AFW pump during the UFSAR accuracy review. Operating procedures had not been written to perform a transfer of DC control power, as necessary to isolate a failed DC bus or battery. Additionally, the undervoltage trip feature of the four circuit breakers used to complete the transfer of DC power had never been tested. Therefore, the team felt that FPL failed to establish operating and testing procedures as necessary to ensure the operability of the DC bus tie breakers in accordance with 10 CFR 50, Appendix B, Criterion XI.

Response: FPL concurs that the above problem statement is essentially correct. However, this condition was self-identified by FPL as part of the UFSAR accuracy review. Corrective actions were planned and are being implemented in accordance with CRs 96-2825 and 96-2507, and LER 96-016.

Status: A rotating PM schedule to monitor molded case circuit breakers for age related degradation was established and this item is complete.

2 ~ The 4 Unit 2 DC tie breakers were tested, and 104 of the safety related DC molded case circuit breakers were tested during the Unit 2 Cycle 10 refueling outage. This item is complete.

3. EOPs 1-EOP-02, 1-EOP-06, and 1-EOP-15 will be revised to include directions for performing DC bus realignments by June 30, 1997.

4 ~ Surveillance/maintenance schedules for the Unit 1 and 2 DC cross tie breakers will be developed by September 15, 1997.

5. The 4 Unit 1 DC tie breakers will be tested during the Unit 1 Cycle 15 refueling outage.

L-97-139 Attachment Page 4 URI 50-335/96-201-08 Inadequate Troubleshooting Documentation

Background:

The first test of the undervoltage trip feature of the four circuit breakers used to complete the transfer of DC power failed. The original test procedure written for operations to perform the test was well written and received an appropriate level of review. Upon failure of the breaker to function during the test, additional, testing and troubleshooting were not performed by procedure, but rather, by scope changes to the original plant work order. Therefore, the team felt that FPL failed to ensure appropriate procedures were used for activities affecting quality in accordance with 10 CFR 50, Appendix B, Criterion V, and also failed to perform testing by written procedures in accordance with 10 CFR 50, Appendix B, Criterion XI.

Response: The original plant work order's scope was changed to allow troubleshooting of the undervoltage device with the breaker installed, vice removed, from the switchgear. The troubleshooting and testing performed by the plant work order was well within the skill of the craft. Close supervision was provided during all phases of the plant work order. All applicable testing requirements (for example purpose, requirements, acceptance criteria, etc.) were addressed within the scope change, even though the strict terminology and format of a formal test procedure were not used.

However, a potential weakness was identified in that the troubleshooting instructions could have contained more detail to ensure consistent troubleshooting from shift to shift.

The disposition to CR 96-2825 documents that the added scope change was within the skill of the craft, and close supervision was provided that reduced the need for greater detail within the plant work order. Therefore, the troubleshooting performed under the work order would not be considered a "step by step" procedure as defined in ADM-0010432, and Facility Review Group (FRG) review and Plant General Manager (PGM) approval was not necessary.

However, enhancements to the testing process were made as a result of the review of the work order.

A training brief was developed to strengthen expectations for personnel involved in preparing

C, L-97-139 Attachment Page 5 procedural and documentation requirements for testing performed under the FPL Quality Assurance (QA) program.

Status: This item is considered complete.

IFI 50-335/96-201-09 Lack of Tracking for Unidirectional Drift Status: FPL reviewed the setpoint program and determined that the Engineering Standard IC-3.17, "Instrument Setpoint Methodology for Nuclear Power Plants," meets the intent of ISA 67.04-1982, "Setpoints for Nuclear Safety-Related Instrumentation used in Nuclear Power Plants,"

which is referenced as useful guidance in NRC IN 89-68.

Therefore, as documented in CR 97-0037, FPL concludes that. no further action is required for this issue.

IFI 50-335/96-201-10 Lack of Loop Accuracy Calculations for Indication Only Instruments Status: Analyses to validate the acceptability of loop accuracies for instruments that are used for indication only will be performed by April 30, 1998.

URI 50-335/96-201-11 Lack of 50.59 Evaluation for Installation of Motor Operated Valve (MOV) Covers

Background:

The team observed that canvas covers had been tied over the top of the AFW pump discharge motor operated valves. The concern was that the covers or rope could potentially become entangled in the stem of the valves and compromise the FPL did not have a documented formal valves'peration.

engineering evaluation for the covers, nor was a specific installation procedure used.

Response: The MOV protective covers were installed as part of the Generic Letter (GL) 89-10 program. The covers were installed in an effort to protect the MOVs from rain water intrusion to minimize corrosion. In a letter from the NRC to FPL dated June 7, 1994, the NRC documented their approval of the installation of the MOV protective cover, or "hats," as referred to in the letter.

However, no specific 50.59 screening or

L-97-139 Attachment Page 6 engineering evaluation was performed for the original installation. The design of the covers, and attachment points, precluded any possible adverse interactions between the covers and the MOVs. Installation of the MOV covers was considered to be within the skill of the craft such that no specific installation procedure was required. The MOV covers and installation were screened from"50.59 as documented in CR 96-2870.

The MOV covers were subsequently removed from the MOVs due to their age and condition. Re-installation of new covers, if desired, will require prior Engineering approval.

Status This item is considered complete.

IFI 50-335/96-201-12 Lack of Maintenance Procedure for Changing Panel Filters Status: A maintenance procedure will be developed to inspect/change out the hot shutdown panel filters by July 31, 1997.

IFI 50-389/96-201-01 Component Cooling Water (CCW)

Performance Curves Status: The revised CCW analysis, stated in the report to be completed by March 31, 1997 is not done at this time.

The analysis will be performed and new performance curves developed by June 30, 1997.

IFI 50-389/96-201-02 Operations Night Orders for Using CCW Performance Curves Status: The new CCW performance curves will be incorporated into the appropriate operating procedures by August 29, 1997.

IFI 50-389/96-201-03 Lack of Calculations for CCW Radiation Monitor Setpoints Status: Setpoint calculations for CCW radiation monitors will be performed by March 31, 1998.

URI 50-389/96-201-04 Failure to Take Appropriate Corrective

L-97-139 Attachment Page 7 Actions for Degraded Pen Recorder

Background:

The 2A Emergency Diesel Generator (EDG) tripped on reverse power during a surveillance. A sticking EDG KW paper chart recorder pen, along with the inexperience of the trainee RCO, contributed to the trip. The team believed the failure to document and take appropriate corrective actions for the sticking pen recorder lead to mis-operation of'he diesel.

Response: CR 97-0030 documents the assessment of the effect of the reverse power trip on the EDG. The EDG was not damaged as a result of the protective reverse power trip.

Status: The sticking pen recorder was repaired and this item is considered complete.

URI 50-335&389/96-201-01 Failure to Update UFSAR as Required by 10CFR50.71(e)

Background:

UFSAR Figure 8.3-14 not representative of the battery load profile and UE'SAR Fi are 9.2.5 not changed to reflect the 1993 accident analysis (108 F maximum CCW temperature).

Response: An FSAR Change Package will be developed by 8/31/98 and UFSAR Figure 8.3-14 revised and incorporated in the subsequent U1 FSAR amendment 16 update.

An FSAR Change Package will be developed by 7/31/98 and UFSAR Figure 9.2.5 revised and incorporated in the subsequent U2 FSAR amendment 11 update.