ML20136E454

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Forwards Answers to RA Questions Re Plant Self Assessment
ML20136E454
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 10/24/1996
From: Mark Miller
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Landis K, Son Ninh
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML17229A261 List: ... further results
References
FOIA-96-485 NUDOCS 9703130213
Download: ML20136E454 (4)
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' From: . Mark Miller ,6

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To: KDL, SON K_ LAN O /6, E[ .

Date: 10/24/96 9:28am

Subject:

Answers to RA questions on St. Lucie Self Assessment -

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' Responses to RA Questions Regarding St. Lucie Self-Assessment -i c -

1 L Specific Answers

a. Is the assessment correct? j r Yes. The assessment addresses areas which we have identified formally as problems (corrective actions, programs / processes / procedures), areas which we i have discussed informally (complacency, change management, communications), i t and areas we have not identified (training, self-assessment, accountability).

5 b. Did the NRC identify via inspections and/or SALP any indicators that sho.uld  !

j- have prompted us to potential problems? -

i Yes. The NRC began to have concems about St. Lucie's performance as early as  !

! Spring / Summer 1994, when an increase in the number of reactor trips (6 in 6  :

i months) was noted. In April,1994, the Site Integration Matrix was developed to  ;

attempt to identify the problems at St. Lucie. In June 1994, St. Lucie was  !

! removed from the NRC list of good performers. The following assessments were j made: e f = Plant Status Report, June 1994 l i-Reactor trips not seen as related, but additional attention to the adequacy  !

) of procedures was recommended. Weakness in review cited. Weaknesses l in corrective actions discussed. Operations was assessed as continuing to , l be strong. Other functional area discussions indicated strong performance.

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3 Plant Status Report, August 1994 i i

Fundamentally the same assessment as June,1994, although potential  !

problems in vendor technical manuals noted in the maintenan:e area.

l Plant Status Report /TPPR, October 1994

PSR concluded that performance remained strong in all functional areas, .

4 however, SRI notes for the TPPR indicating a difficulty in identifying  ;

common causes for deficiencies identified through inspection. SRI's  !

assessment was that some complacency existed, management standards ,  !

were not firmly set and communicated, and too many people (in EPL) l didn't believe that a real problem existed. .

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a Plant Status Report /PPR, March 1995 g ,

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, Sharp decrease in the number of reactor trips cited. . Weaknesses pointed l

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I p i k out in annunciator response procedures, corrective actions, logkeeping, I

and some aspects of FRG activities (reviews), however, Ops rated as

- strong overall. Some maintenance weaknesses were identified (VTMs, .

- IVs, welding), but, overall, maintenance was seen as superior. Other functional areas were seen as continuing at superior levels.

  • August,1995 q l

Regional personnel perform a root cause analysis for indications of . j organizational and programmatic deficiencies, based on SIM data for 12  ;

months. The predominant root cause for events observed at the plant was  ;

insufficient detail and scope in site programs and procedures. Deficiencies j were noted in job skills, work practices, decisionmaking, interface among i organizations, and unclear organizational responsibility and  ;

. accountability. These weakness areas conform well to the l licensee-identified limiting weaknesses in training, accountability, programs / processes / procedures, and communications management. '

i Plant Status Report /PPR, September 1995 ,

Increase in personnel errors noted in Operations, including failures to l follow procedure, inattention to detail, and. failures to maintain awareness  ;

of equipment status. Overall, Operations' performance was seen as having declined. Maintenance performance.was similarly seen as having declined, with procedural quality and adherence and attention to detail l

cited as problem areas. Engineering and Plant. Support were seen as j continuing to perform strongly. '

A review ofinspection report findings from 1992-93 indicates that, primarily in  ;

the areas of equipment reliability and procedural adherence, problems existed. A cursory review indicates that opportunities for enforcement may have been missed in some cases. However, the SALP report covering the period indicates that only minor problems (operator attention-to-detail and maintenan' ce procedure adherence) were identified and does not categorize problems into specific areas in a manner sufficient to conclude that declines in performance levels were  !

occurring.

c. . Did we pursue any of the indicators? If yes, how? If no, why not? .

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Prior to August,1995, when significant plant events (e.g. containment spraydown, RCP seal failure) indicated a clear decline in performance, no specific inspection efforts were targeted at - I perceived weaknesses outside of the core inspection effort. A review ofInspection Reports from mid-1994 through the end of 1995 indicate that the only departures from the core inspection .

program were for allegation-related issues.

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.o Miller's. Assessment (Opinion)

-'Ihe failure of the NRC to act more proactively in applying inspection effort to St. Lucie i stemmed from several factors:  :

  • A long history of superior performance leading to reduced inspection effort and a ,

subsequent reduction in the number of findmgs

  • A failure to act on the negative findings which were developed, as they tended to be masked by a large number of positive findings  :

A failure to take advantage of the opinions of DRS and other visiting inspectors who,  !

overwhelmingly, felt the plant was overrated j

  • A lack of a clear discriminator as to when negative findings warrant amplification over a larger number of positive findings.

Additionally, the plant is now undergoing what has been described in several documents in that, )

with added inspection effort come more findings and more enforcement which tends to appear as j a decline in performance when, in fact, conditions which had persisted for some time are only now being realized. The percived decline then invites additional inspection, which turns up more l problems, and the cycle repeats.

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