ML20137M177

Audit Rept QSL-PM-96-02, Monthly Performance Monitoring Audit, Feb 1996

ML20137M177
Person / Time
Site:	Saint Lucie
Issue date:	04/02/1996
From:	Panessa L, Voorhees J FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML20137M095	List: ML20137M089 ML20137M161 ML20137M177 ML20137M204 ML20137M212 ML20137M224 ML20137M250 ML20137M266 ML20137M358 ML20137M416 ML20137M495 ML20137M532 ML20137M541 ML20137M711 ML20137M763 ML20137M803 ML20137M907 ML20137P297 ML20137P306 ML20137P338 ML20137P343 ML20137P355 ML20137P365 ML20137P417
References
FOIA-96-485 QSL-PM-96-02, QSL-PM-96-2, NUDOCS 9704080026
Download: ML20137M177 (24)

Text

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FPL Nuclear Division Fl:PL, Quality Assurance Audit Report' ,

MONTHLY PERFORMANCE MONITORING AUDIT QSL-PM-96-02 February,1996 .  !

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4 Audit Team:

J. J. Walls L. L. Panessa B. J. Lowerv L. J. Bearror 4

S. Sanders L' W. Bladow QA PSL 9704080026 970401 1 PDR FOIA ix, BINDER 96-485 PDR

QUALITY ASSURANCE DEPARTMENT AUDIT REPORT DISTRIBUTION. y z , iq:r (, 4 i

AUDIT REPORT: OSL-PM-96-02 g 49%

PLANT / DEPARTMENT: St. Lucie Plant l NUMBER OF FINDINGS: Two

• CNRB Standard Distribution R. J. Acosta - JNA'JB T. F. Plunkett - JEX JB W.11. Bohlke - VP/PSL T. V. Abbatiello - JNA PTN D.~ A. Sager - JNA/JB L. W. Bladow - JNA PSL R. J. liovey - VP/PTN R. A. Symes - JNA/JB G. J. Boissy - JPN/JB D. A. Culpepper - JPN/JB Dr. K. R. Craig - JPN/JB QAD Files w/ Checklist & Audit Plan Cheryl Robinson - JNA/JB H. N. Paduano - JPN/JB IIcalth Physics & Chemistrv Related Audits Dr. W. R. Corcoran (CNRB) .\lanager Nuclear Health Physics: Chemistry D. B. Niiller (CNRB) Emereenev Prenaredness Related Audits i

.\tanauer - Nuclear Emercenev Preparedness j

• CNRB Files: K. E. Gutowski l Nuclear Trainine Related Au11113 Audit Snecific Distribution .\lanager Nuclear Training

.\l, Niiller - NRC.'PSL-1 Plant Specific Security Audits  ;

E. Weinkam 5ecurity Supervisor J. West l Services Ntanager j P. Fulford C. .\larple Fire Protection Audits 11.Iluchanan S. .\tartin. Risk N1anagement

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• Only distribution outside the plant for Security Audits containing Safeguards information.  !

%gh 3/12/96

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1 s Inter-Office Correspondence l

JQQ-96-047 l

To: J. Scarola Dr.te: April 2.1996  ;

1 From: L. W. Bladow Department: JNA'PSL I I

Subject:

Quality Assurance Audit OSL-PM-96-02 Attached is the summary of Performance Monitoring activities completed during February.1996 to assess the implementation of the Quality Assurance Program at St. Lucie.

The following findings are documented in this report and hase been discussed with appropriate personnel and exited with PSL Plant Management.

Findine 1: A comparison of plant operating data. AP 0010134 Appendix "A" documentation and the STA Database indicated several deficiencies regarding the program for tracking of Component Cycles and Transient events.

Findinn 2: Several discrepancies were identified regarding strict adherence to plant procedural guideline requirements.

Condition Reports (CRs) have been generated for the above findings. In accordance with the FPL l Quality Assurance Program. please ensure that the CRs which address these findings are responded to within 30 days of origination. As noted in AP 0006130. responses to CRs resulting from QA audit findings must include the following:

1. The results of review and investigation of the findings including identification of the probable root causeccausal factors.

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2. Results of your examination of potential weaknesses in departmental self-assessment programs which may has e impeded self identitication of the problem.

1 A determination of the generic impact of the finding. i.e.. w hether it extends to other areas. ;

systems. drawings. procedures. etc. or u hether it is isolated to those examples cited in the audited report.

'. Actions taken or planned to correct the findings identified and to prevent recurrence of the deliciency. Corrective actions should address the causal factors and enhancements to the audited t,iepartment's self-assessment program.

5. Date when full corrective action was or will be achieved.

JQQ 96-047 ,

April 2.1996 i

Pagel 1

6, Identification of the individual (s). responsible for.th'e corrective action. . '

'For those corrective actions which cannot be completed within 90 days from the audit report *

. transmittal. the response shall (1) include an explanation why the action cannot be completed within ,

90 days and G) include both the cognizant Vice President (or Director where the Director is a direct  !

report of the President - Suclear Division) and the Vice President Nuclear Assurance on distribution. '

, An evaluation .should be made of the Dndings identified in this audit to determine reportability.  ;

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.We sincerely appreciate the cooperation we received from your staff during the course of the audit.

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Please contact me at extension 7111 or the respective QA contact ifyou have any questions.

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/tb&_,4,f  !

L. W. Bladow i

.. Quality Manacer - PSL

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s Attachment Copies to: Dist. Attached '

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L AUDIT REPORT QSL-PM-96-02 FPL Page 2 of 21 Audit Location: St. Lucie Plant Date of Audin February /N! arch 1996 Executive Summarv: Performance .\lonitoring summaries for evaluations completed during February and early .\ larch 1996 are included in this report. Included are reviews of the following subiects:

Daily reviews of the conduct of operations were conducted. Control room demeanor was observed to be professional. Turnovers observed were thorough and in accordance with current expectations. A reactor shutdown.

unit trip and reactor startup were observed. Compliance to operating and emergency operating procedures was good. Several items with regard to procedural non-compliance were identified during the month.

Additional reviews included implementation of the Freeze Protection Program during periods of cold weather. evaluatien of Emergency Preparedness. controls of Health Physics department computer software.

control of Temporary Changes to N1aintenance procedures. welding repair to Unit i ECCS piping and Technical Specitication resiews.

Strengths Compliance to operating and emergency operating procedures during Unit I reactor shutdown. reactor trip.

PSL site implementation of the Emergency Plan during the annual exercise.

Findings Finding i discusses programmatic and performance issues regarding the program for evaluating and tracking component cycle and transient limits to ensure compliance with St. Lucie I echnical Specifications a See Pg.1 L.

OFPL AUDIT REPORT

' QSL-PM-96-02 l, age 3 of 21

. Finding 2 discusses several instances of procedural non-compliance discovered while reviewing operating activities (See Pg.16). -

Weaknesses

. Failure to perform adequate self assessment and corrective action on potential performance and procedural desciencies which contributed to reactivity dit:ferences between estimated and actual critical conditions during reactor startup (See Pg.6).

. , One additional STAR was issued to llP documenting minor discrepancies in implementation of computer software controls (See Pg D.

Based on the activities and objective evidence examined. it uas determined that the requirements of the QA program and technical specifications are adequately addresse'd by procedures and that implementation of those procedures is effective. The Findings noted in this report identify specific areas where improvement is required to achieve additional program effectiveness.

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AUDIT REPORT FPL QSL-PS1-96-02 Page 4 of 21 Operations:

P310N 96-014 was conducted to determine whether St. Lucie Plant has etTectively implemented programs to ensure compliance with selected PSL Technical Specifications. Technical Specifications selected for examination during this audit included those in Sections 5.0 -Design Features".

Examples include:

Component Cycles & Transient Limits

-Design Features of the Site and Containment The audit results were obtained from a combination of procedure and documentation review and interviews. A review of the annual beach survey and annual mangrove survey showed that the site continues to meet the original design provisions contained in Section 2.4.2.2 of the FUSAR . A review of design drawings showed that the site Exclusion Area. Low Population Zone.

\leteorological Tower Location and Containment Vessel and Shield building meet the original' Jesign prosisions.

A comparison of plant operating data. AP0010134 Appendix "A" documentation and the STA Database indicated several deficiencies regarding the progr. for tracking of Component Cycles and Transient events: .

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.\. Esents documemed by Uperations hase not been esaluated in a timely manner.

B. The responsibilities of all personnel involved in the process for documenting.

evaluating and tracking these e + are not clearly defined by procedure.

C RCS leak tests equal to or greater than normal operating pressure are not being recorded and tracked. I D. Cumulative event totals are not periodically documented. The software program for tracking and totaling these events is not controlled in accordance uith the Ql-2 requirements for limited scope software. i l

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Ihese issues are documented in Finding =1. .\Jditional information regarding the circumstances currounding this preHem is prosided in the Finding.

It should be noted that uhile the accuraev of the cumulatis e totals for certain events in the trackinu

' database is indeterminate at this time. the Tech Spee allowable numbers of cycles are sufficiently l

high that current estimated numbers are well below Technical Specitication limits. i Example - 200 1 R,C.S. leak tests with pressure _2:35 p3ig)

Perfonnance .\1onitor: S. Sanders  !

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O 3: P L AUDIT REPORT QS L-P.\1-96-02 l, age s of 21 PMON 96-015 was conducted to obsen e and document the Operations Department's compliance with Administrative Procedure AP-0010120 " Conduct of Operations" and other various Plant procedures during the month of Februarv. Control Room tours were made on a regular basis. Day.

\ lid and peak shift tours were completed in order to observe shift turnoser meetmgs between on-coming and off-going Operator shifts. Each tour found a terv professional atmosphere being maintained by the control room staff present. Workers entering the control room in need of varying assistance from the statYuere dealt with in a businesslike. expeditious manner. furnovers observed.

both at the end of shift and short term. were conducted as required by procedure.

, Control room procedures-in-use completed paperwork and s arious control room iogs were reviewed Junng each tour. In general logs and other required records were well maintained. I he tollowing discrepancies were found and brought to the attention of the assigned l' nit ANPS:

1. Unit 1 Data Sheets li and 18. surveillance runs for 1B and 1C ICW pumps c'ompleted on the mid shift 2 26 96 did not have the test '

results of the surveillances checked off as acceptable, alert. or required action u hen reviewed by QA. At the time this documentation was . signed o!Y as complete by the RCO and the ANPS involved in the surveillance runs.

I hese individuals were informed of the oversight and the paperwork was corrected.

2. Unit : Data Sheet 37. Loose Parts .\1onitor Daily Check. and Data Sheet 31. Fire Door l Surveillance, had not been initialed and dated as having their revision s entied prior t.o use I as required by v16-l. The on- shift ANPS veritied the Data Sheets to be the correct revision and passed on to the .\ lid -shift who originally generated the Data Sheet. the need for attention to 01 requirements. Subsequent reviews of the daily paperwork hase found no additional problems m this area.

( In : 12 46 l' nit cross tie valves for station air were opened and logged in each unit's valve.

switch desiation logs. A walk down of these valves resealed that the i nit 2 vaive. \'18717.

iid not has e a deviation tag attached to it as required by AP 2-00101:3. paragraph 8.1.6.b.

I he l' nit ASPS uas informed and a tag was installed.

Collectn ely these. ana ses eral other instances et procedural non-compiiance cocumented in this

eron were determmed to constitute a failure to meet management expectanons m this area and are documented in 1:inding =2.

Fhe : 23 on l' nit t )ne reactor shutdown and >ubseauent manual tnp were obsen ea. Fhis shutdown sa3 conducted as a resuit of GA :20 being in a dropped and unrecos erable conaition. Compliance

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AUDIT REPORT QSL-PM-96-02 FPL Page 6 of 21 to applicable plant procedures. including Administrative. Operating, Off-Normal Operating, and Emergency Operating Procedure as well as Unit One Technical Specifications was noted. The Unit One reactor startup from Mode 3 to criticality completed on mid shift 2/24/96 was also observed.

This startup was conducted per Operating Procedure 1-0010122 . This procedure was strictly adhered to. During the early stages of the reactor stanup, routine inverse count rate ratio plots revealed that the calculated critical boron concentration was in erTor and that criticality would not be reached at the calculated boron concentration. The error was conservative. The reactor startup was stopped at this point. Investigation by Reactor Engineering indicated that the error was the result of asing power defect and xenon worth values based on the 30% power conditions existing at the time of the previous reactor trip, The ECC Calculation worksheet was recalculated using the most recent steady state equilibrium value for these parameters and the reactor startup was completed successfully.

t he OP l-0030122 " Reactor Stanup" Appendix C ECC calculations are prepared by a reactor operator, checked by reactor engineering. reviewed by a reactivity manager and approved by the ANPS or NPS. This calculation was performed several times during the above time frame in anticipation of the reactor startup on Unit 1.

Reactor Engineering has a Departmental Guideline entitled " Reactivity N1anagement Program" which requires completion of an "ECC Accuracy Review Sheet" for the purpose of self assessing the accuracy of ECC calculations and other physics information provided to Operations. The ECC Accuracy Review Sheet for the subject startup provided a critique of only the final ECC Calculation.

not any of the original calculations containing the errors and upon which the reactor startup was imtiated. ~1 he documented difference between the estimated critical conditions on the "ECC Activity Retiew Sheet" and the actual critical conditions was 121.06 PCN1. Discussion with RE personnel indicate that the difference in the instance that the startup was originally halted uas approximately 251 PCN1 The Reactivity Analysis sheet contains no comments regarding the initial errors in the ECC calculation. The only ECC Calculation Worksheet that is retained as a QA record is the final corrected s ersion.

Discussion with RE personnel indicate that the Appendix C ECC Calculation Worksheet could be enhanced to more clearly specify the need to use the last steady state equilibrium s alues for power defect and xenon wonh. The procedure currently contains a space for conditions prior to shutdown

\t _ 'n Power" In the subject case this uas recorded as 30,*o power. the condition just prior to the l' nit I trip. however this was not an equilibrium condition. Resiew of presions recent ECC Accurae) Review Sheets indicates that this type of error has occurred before. Subsequent to these discussions with QA. STAR %0436 was initiated by RE to investigate anJ suggest procedural enhancements and additional training as appropriate regarding these issues.

o AUDIT llEPOllT QSL-P.\l-96-02 1:PL Page 7 of 21 Failure to capture. document and analyze the errors identitled on the original ECC calculations represents a missed opportunity to improve personnel performance and enhance the procedures used for predicting criticality during a reactor startup.

i >n 128 96. a pre-evolution brieting conducted by the Operations .\ tanager was observed. This brieting was done prior to Pre-Op 2-1-4002S1 " Placing The Leadmg EJge Flow Meter iLEFM) into i )peration For Digital Data Processing (DDPS) Calonmetric input" being performed. Elements of ittachment 1. Checklist For The Conduct of Infrequently Performed Tests or Esolutions. were adequately cos ered during this briefing.

'ertormance Momtor: L Bearror P\lON 96-004 was initiated to es aiuate the computer software control program established by the ilealth Physics department to ensure compliance with SQM-2.9 and QI 2-PR/PSL-3. both entitled

" Control of Computer Softwaref This evaluation included interviews with cognizant personnel and the review of documentation packages. access controls. change controls. and software classification.

'iennicant e:Yort has been expended within llealth Physics regarding the deselopment of the

.iocumentation and s eritication s alidation packages. Each package ineiudes a test run incorporating snown mputs and outputs which are sentied via manual calculations. Master copies of the user handbooks and manuals are tiled in document control with copies available for personnel operating he sy stems. Software identified in the control program is restricted via password and lock and key rom the general population. unh access granted to a ilmited number ofindividuals. The master enware tiles and data backups are stored in a lockable disk organizer along with software and data l iies not associated with this program. The sottuare controi program ielineates that measures be aken td pres ent inadsertent damage and provide for the phy sical separauon of backup and data

-iles.

sd iitional redeu o' software control aetnities found the ilP computer software index to be neomplete in tnat it does not melude seseralinformanonal items specuied by 9te software control rocedures. fhe m'iex should be redesigned to include the above items and indicate the existence.

na locanon or backup ana data tiles.

Aas noted that the documentauon rackages ter programs TD\l:!" ana "\ll f E .!!d not inciude

' copy of the source coae pnntout. In this connection it is also noted that only the run time

. eeutarle is ownea by i'Pl. and that both rograms F base reen' testea extensneiy agamst known j

.at.t. ut documentauon rackages snould contam a cot er letter

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\ EDIT REPORT b QSL-P.\l-96-02 Page 8 of 21 authorizing the use of the software cad approval of the documentation package. The forms included in QI 2-PR/PSL-3 may be used for the tracking s critication and approval process. STAR =960389 was initiated by QA to address the above issues and track the corrective actions taken.

Performance .\lonitor: B. Low ery

\lainten m P\lON 95-076 was imtiated to determine whether St. Lucie Plant has effectively implemented a reeze Protection Program. fhis evaiuation was conducted utilizing the NRC Inspecuon .\lanual. ,

'rocedure 71714 enutled " Cold Weather Preparauons" and St Lucie procedure .\P0005753.

in preparauon tbr this activity. the responses to the I&E Bulletin 70-24 " Frozen Lines" was reviewed Ibr each unit. l\ comparison of the submittal to the NRC and the site procedure was reviewed ihr implementation of prior commitments. The pcocedure was then reviewed against the inspection Guidance of the NRC Inspection Procedure. Field walkdowns were conducted to check insulation on specified equipment. Implementation of cold weather protection measures were a aluated during ses erai recent periods of cold weather.

I he resuit or this es aiuation indicates that the cold weather preparations (.\P 0005753 Rev.14) are adequately addressed within approved site procedures. Checklists for participating departments outline the measures required of each depanment. Due to the subtropical climate of the site, the equipment is stayed Ibr installation upon notitication from the System Dispatcher. Some procedure

.ompliance i3 sues were obsers ed during the observanon of procedure implementauon. Two STARS sere urmen auring inis Performance .\lomtoring actisity. STAR 960128 was written to obtain orrectis e acuon for not completing Data Sheet 3 i List of Temporary Hoses tbr Fire .\ lain freeze

'rotecooru or .\P 0005 53 as required. ST.\R 0 60326 was written because not ail of the instruments

!isted in AP 0005753 were pros ided with a protective source of heat as specified in the procedure.

< ollectis el> these. and eu"4 other m>tances of procedural non-compliance documented in this enon were detemimea to u itute a failure to meet management expectations m this area and are meumented in i inding =2

\ hh me escevuon3 .: me 'T.\Rs urttten. ..no We nems documented m imding =2 it was sietermmed that the commitments for freeze protection at St. Lucie were being adequately mPlemented.

. onductea by r Watis and ! 3earror

Of:PL

\ EDIT REPORT QSL-P.\1-96-02 I, age 9 of 21 P.\lON 96-009 was initiated to evaluate the Maintenance Group's process for control and update of temporary changes to applicable maintenance procedures within the controlled document sets assigned to the .\laintenance Group. Controlled Procedure sets =J2 NSB) and =49 (SSB). were sampled for selected issued TC's. This review was conducted to serify that the current active TC's are properly filed with their appropriate procedure and that inactise FC's are removed when incorporated by an approved procedure resision. The FC logs for both units were reueued to obtain

he listing of active TC's and recently closed out TC's for 1946. Beth of the controlled procedure sets were found to be un to date and in conformance with the document control requirements.

Performance Monitor: 1. Panessa PMON 96-016 was mitiated to monitor and evaluate the repair activity of through wall leakage of Unit 1ECCS piping. STAR 960294 was generated to document the discovery of a weld area leakage on line 1-24-CS-3. PC M 031-196 detailed the necessary action to accomplish the repair and l restore the piping to an acceptable operatmg status. SPWO 61/6678 was the tield document established to implement the repair activity. This PWO was used as the focal point between the s T.\R correctis e action and the PC N1 details to etfect the repair. Time constramts of a 7: hour LCO necessitated a e,ntinuous work esolution with substantial in Process work controls and corresponding inspection activity.

Various aspects of the work activity were monitored to assure compliance with applicable I procedures and conformance to NPWO approved instructions. These actisities included work l controls, cleanliness controls material controls. Special process controls and associated veriti canon l actions. I he planmng. nuerlace and supervisory insobement u nh the work es olution resulted in

-occessful accomplishment of the engineered repair and restoration of the liCCS piping. 1 l

l'pon completion of the repair activities the PC M documentation package including the QC inspeenon reports were reviewed ti3r accuracy and completeness. There are 'O separate QC j inspeenon activities coeumented on weld inspection checklists or mspection ret, orts. Of these. 29 ]

esiubit documentation deliciencies that retleet inattention to procedural detads. Many of these jeliciencies result from implementation of the new computer generated welding inspection checklists. No inspeenon report could be ! bund documenting one in-process UC inspection signed

>ti on a weid traseier m QC. fhe PC M package currently a.ssembieu ana resieued for linai dosure o marginal as a stand alone document. In this connection it is noted that aithough numerous errors were detected. :es ieu of the mdisiduai items indicated that there b no concern with regards I o salets ugnificance er quality of the work performed. fhe documentation eeticiencies were  !

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0 0 FPL AUDIT REPORT QSL-PNI-96-02 Page 10 of 21

• summarized in PSL Quality Department self-assessment report JQQ 96-043. Corrective action is currently being pursued by QC supervision and the Site Quality Nianager.

. Performance Nfonitor: L. Panessa

.Sen ices /Encineerine:

PSION 96-001 was conducted to evaluate Emergency Preparedness through observation of the ,

annual drill and exercise. The observations were made at the simulator. Technical Support Center. l Operations Support Center. Site Assembly Area and the tield radiation monitoring team. The drill )

controller briefing. scenario walk through, and drill critique were also attended. Compliance to Emergency Plan implementing Procedures was verified to be satisfactory in all areas observed.

Proper statring and personnel were available to meet the duties and organizational requirements of the TSC and OSC as outlined in the Emergency plan.  !

The activation checklist for these two centers was observed being completed and it was noted to be j the latest revision. The equipment listed in the tables of the On-site Support Centers EPIP 3100032E was found to be available and in use during the drill and exercise. This observation included controlled procedure:. drawings..and technical manuals. llealth Physics instruments in use were s critied to be in calibration.

Personnel demonstrated familiarity with the use of procedures. plant monitoring systems used in accident identitication and assessment. and good overall management of the accident. Event classilication was performed in accordance with plant procedures that contained acceptable emergency classification and action level schemes.

The critiques were attended and it was noted that the items noted by the QA auditors were also self identuied by the drill participants.

Plant records were reticued to determine that Emergency inventory veritications are being performed on a monthly basis in accordance with IIP 90 " Emergency Equipment" Completed attachments to this procedure were reviewed for the past , sear. These records included inventories after drills and exercises. The insentory resiews were found to be satisfactory.

Based on the activities and objectis e es idence audited. it was determined that the requirements of the St. Lucie Emergency Plan were adequately addressed by procedures and the implementation of those procedures was effectis e.

Performed by: J Walls and D. N!acArthur t PTN QA )

t G. b AUDIT REPORT QS L-PM-96-02 Page 11 of 21 Summarv ofIndeoendent Technical Review (ITR) Activities This information is provided in accordance with T.S. 6.5.2.11.d. It is current for February 29.1996.

L Summary:

No ITRs were completed issued during February. Additionally. no items which narrant CNRB attention were identitied from Independent Technical Reviews in progress.

11. The following ITRs are in progress:

e 196-008 "PSL Emergency Diesel Generator .\taintenance Program"

• F)6-00 / Assessment of the Operating Experience Feedback iOEF) Program. and its implementation at PSL"

• 196-006 "Resiew of the February 22.1996 Dropped Control Element Assembly. Unusual Event. and Manual Reactor Trip at PSL Unit 1"

• 1 % o05 "1995 STAR Program Review"

• 195 024 " Initial Criticality Evolution Following the PSL2 1995 Refueling Outage"

• 105-021 " Review ofINPO Significant Operating Experience Report t SOER) 45-I and Assessment of Foreign Material Exclusion Program and Practices During the 1995 PSL Unit 2 Refueling Outage" e 105-012 " Review of NUREG CR-6144. Evaluation of Ses ere Accidents during Low Power and Shutdown Operations at Surrey Unit l'"

• !05-020 ' Assess the Adequacy of Operator Logs and Associated Log Keeping"

• 105-01: "Resieu of NUREG CR-6144. Evaluation of Sesere Accidents during Low Power and Shutdown Operanons at Surre> Unit U" e 145-o10 "Resiew of Plant Frip due to Personnel Error During I urbine Trip Test on PSL-l"iLER 334 05-00.4

s AUDIT REPORT QSL-PM-96-02 FPL Page 12 of 21 Finding No.1 Criteria: Unit 1/2 Technical Specification 5.9 (5.7 Unit 2)

Specification 5.9.1 15.7.1) "The components identified in Table 5.91 (5.7-1) are designed and shall be maintained within the cyclic or transient limits of Table 5.9-1 i 5.7-1 L" AP 0010134 Rev 12 " Component Cycles and Transients" Para. 8.1,8.2,8.3 Paragraph 81 If an event listed in Appendix A occurs. a copy of Appendix A shall be completed and forwarded to the Shift Technical Advisor.

Paragranh 8.2 Copies of Appendix A received by the Shift Technical Advisor shall be evaluated to determine if the event requires notilication and/or record retention in accordance with Technical Specifications 6.10.2.f Paragranh 8.3  !

Aller review, the material collected in Step 8.2 above shall be forwarded to the j l.icensing department for record retention. l QI 2-PR/PSL-3 Rev 3 " Control of Computer Software" j Scope Section ,

Paragraph 3.1.3 l Support of plant license requirements when used to document compliance with regulatory requirements .

Paragranh 5.13.1 I.imited Scope Computer Software is classified as computer sotiware that is written and I used to support such activities as engineering calculations, simple data manipulations. )

formulae applications and data control in a localized application..

Finding: A comparison of plant operating data. AP0010134 Appendix "A" documentation and the STA Database indicates ses cral deficiencies regarding the program for j tracking of Component Cy cles and Transient es ents: l T. I T ents documented by Operations has e not been es aluated in a timelv manner.

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@ ACDIT REPORT O SI,-P M-96-02 Page 13 of 21 Finding No.1 (continued)

B. The responsibilities of all personnel involved in the process for documenting.

evaluating and tracking these events is not clearly defined by procedure.

C. RCS leak tests equal to or greater thar. normal operating pressure are not being recorded and tracked. .

D. Cumulatis e es ent totals are not periodically documented. The software program for tracking and totaling these events is not controlled in accordance with the QI-

requirements for limited scope sof tware.

Discussion: Ai 1' nit 1 Operating Data iRCO Logi was resiewed from o I C+5 to 21.96 for plant cycles and transients required to be tracked by AP 0010134. " Component Cycles and Transients.' ihamples of six specitic esents requiring tracking were selected. A review of the STA Database .and completed Appendix "A" data sheets forwarded to the vault revealed that u hile these events had been identitied

- on Appendix A as required. several identitied events had not been evaluated and tracked according to the requirements of AP 0010134. At the time of the audit eix of Appendix A data sheets had not yet been evaluated by the STAS for a detemlination of the need for inclusion into the component cy cle and transient database. Many of these data sheets documemed multiple events requiring evaluation and potential recording. Several of these data sheets had also not been signed by the ANPS'NPS.

None of the listed occurrences are currently entered into the computer program being used to track cycles and transients. In discussions with the STA group there was apparently not any one person accountable f or the database on Cy cles and Transients as there had been in the pa>t. and there was some confusion on w ho had the actual responsibility for data input.

10 \P0010134 Rev i1: Component C)cies and Transients. Para 8.3. require that the material collected shall be forwarded to the VC denartment for record retention. l~hi3 paragrapn has been revised in Resision 12 to state ' After reuen. the material coileeted in Step 8.2 abose shall be forwarded to the

een>ing depanment for record retenuon. :n all ses en cases documented abos e the Appendix "A" was forwarded to Licensing prior to being forwarded to the Jault. In sis of the sesen eases these documents were reueued by Licensing.

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ACDIT REPORT QS L-P.TI-96-02 FPI~" Page 14 of 21 Finding No.1 (continued) initialed. and forwarded on to the records vault without the evaluation.

signatures. and tracking omissions being identitied.

Licensing's role in this process is not defined unhin AP0010134 and is not understood by licensing personnel.

C) Technical Specification Table 5.9-1 requires tracking of RCS 1.eak tests equal to or . greater than :35 psig. The implementing procedure. AP 0010134.

Component Cycles and Transients. requires tracking of only RCS leak tests greater than ::50 psia. .not equal to or greater as required by the Tech Specs.

RCS Leak Tests are perfmmed during all outages in which RCS integrity is broken in accordance with OP ':- 0120022 "RCS Leak Test." These tests are performed at approximately normal operating temperatures and pressures. According to the literal statement in TS Table 5.9-l. several of these tests require recording and tracking as leak tests at pressures equal  ;

to 2235 psig. The STA database used to track cycle and transient events currently contains only one occurrence of an RCS leak test uith pressure equal to or greater than 2250 psia for PSL-I and four occurrences for PSL-

2. A review of RCO Logs and Inservice Pressure test records identified severai events meeting the leak test criteria of Technical Specification .

Table 5.9-1 for tests greater than 2235 psig which have not been i Joeumented. evaluated, or tracked on Appendix "A" AP 0010134.

Component Cy eles and Transients. Esamples include:

Ii 1-I PT-07 12 20'1991 Logged pressure of 2255 psia

2) 1 -I PT-0-' 05 27 1043 Logged pressure of 2250 psia

3) 1-IPT-07 11 28 1904 I ogged pressure of 2265 psia 4i 1 -I PT-o 1 12 20 1085 Logged pressure of 2295 psig Di Cumulative esent totals for eyeles and transients identitled in the fechnicai 4peenications are not documented or reriodically summanred in any report

.;ound m die secords s ault. in ent totals are maintained by a macro sotiware program unhin the database that the STA uses to track esents. The rehability 4 the esent totals is onl> a.s reliable as the accuracy of imruted data, and the

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@FPL .\UDIT REPORT QSL-PM-96-02

" age 15 of 21 Finding No.1 (continued) accuracy of the macro end program to count all occurrences. The program has several functions that . ..ow for data entry. correction. deletion. reports. and searching the database. This program t.ses simple data manipulations to record and count the cumulative events defined in the Technical Specification and is the only cumulative record which demonstrates compliance with the T.S.

requirements. Although the program can print out cumulative totals for each unit and Cy cle and Transient Tech Spec Limit. the program has a fault that will not allow for the printing of all individual recorded events. This database is not i controlled in accordance with QI :-PR'PSL-3. Parauraph 5.13. Limited Scope l Computer Software. j li should be noted that while the accuracy of the cumulatise totals for certain  ;

events in the tracking database is indeterminate at this time. the Tech Spec allowable number of cycles is sufficiently high as to not represent a Technical Specification compliance concern, t Examples - 200 RCS leak tests with pressure ,

2235 psig)

Recommendation: Your response must address the findine above. The followine recommendations are offered for y our consideration. l 1i Revise Admir:strative Procedure No. 0010134. " Component Cyclec and Transients" to show responsibilities of each department identified in the l

low path of documentation. Identify the responsibilities of the STA in maintainine the cumulatise totals of Cs eles and Transients. ,

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) Re'. ise Administrative Procedure No. 0010134. " Component Cycles and fransients" to retlect the actual requirements for recording leak tests at pressures equal to or greater than 2:35 psig. Review the technical basis for tracking leak tests at the Normal Operating Pressure and submit a rn ision to the Technical Specifications if uarranted.

i Resise .\P00lol34 to reuuire that an annuai -ummary report et

.umulatise component c)cies and transients be Frerated. res iewed and nubmitted to the vault as a VA record.

l AUDIT REPORT I 1

FPL QSL PM-96-02 1 l

Page 16 of 21 l

Finding No.1 (continued) l l

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4) Revise all PSL Pressure Test Procedures to prompt an evaluation of conducted tests in accordance with Administrative Procedure No. l 0010134. " Component Cycles and Transients" to ensure tracking when required.  !

5) Review PSL operating data to ensure the current accuracy of cumulative evele and transient totals. .

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6) Review the STA database on Component Cveles and Transients to ensure compliance with the software control requirements of QI 2-PR/PSL-3 Rev 3 " Control of Computer Software /

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@FPL AUDIT REPORT QSL-PM-96-02 Page 17 of 21 Finding No. 2 Criteria: PSL 1/2 Technical Specification 6.8.1

" Written procedures shall be established, implemented and maintained covering the activities reference below:

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e. Surveillance and test activities of safety-related equipment" QI 5 - PR/PSL - 1 Preparation, Revision. Review / Approval Of Procedures.

Paragrarsh 5.13.1

'A strict adherence to procedural / guideline requirements - Verbatim Compliance - is the policy expected and required of all St. Lucie Plant personnel."

Finding: Several discrepancies were identified regarding strict adherence to plant procedural / guideline requirements.

Discussion: A review of in use and completed plant procedures and plant conditions during PNtON's05-076 and 96-015 revealed live examples of failure to comply with plant procedures. Ihe following discrepancies were identified.

1. Unit i Data Sheets 17 and 18. surveillance runs for IB and IC ICW pumps, completed on the mid shift 2/26,96 did not have the results of the surveillance test checked off as Acceptable. Alert, or Required Action w hen reviewed by QA.

.\t the time of the QA review, this documentation had been signed off as complete by the RCO and ANPS imolved with the surveillance runs. These indisiduals were infonned of the oversight and the paperwork was corrected.

2. Unit : Data Sheet 37. " Loose Parts N!onitor Daily Check". and Data Sheet 31.

"I ire Door Surveillance" had not been initialed and dated as having the necessary revision verification prior to use as required by QI 6-PR/PSL-l.

Following this discovery by QA. the on-shift ANPS s eritied the Data Sheet: to be of the correct revision and had passed on to the mid-shift. who originally j generated the Data Sheets. the need for attention to Q1 requirements. l Subsequent resiews of the daily paperwork has e found no additional problems l in this area.  ;

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\UDIT REPORT QS L-P.\1-96-02 FPL Page 18 of 21 Finding Number 2 (Continued) ,

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3. On 2J12 96 Unit cross-tie valves for station air were opened and logged in the valve and switch deviation log for each unit. A walk down of these valves revealed that the Unit 2 valve. VI 8717. did not have a deviation tag attached as required by AP :-00101:3. paragraph 8.1.6.b. The Unit ANPS was informed and a tag was installed on the vaise.

4. During the implementation of AP 0005753. Data Sheet 3. which documents the installation of temporary drain hoses. was not tilled out as required by the procedure. STAR %012S was uritten by OA to address this procedural non-compilance. I 1

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5. .\P 00057f 3. Checklist :0. states. " Install heat tape or other method oflocal air i beaung on.the followine instruments for each unit" and provides a list of instruments. A walkdown of the listed instruments revealed that not all ir.struments had been addressed. Some instruments had been indicated as "not applicable" on the completed checklist. STAR 9603:6 was written by QA to address this procedural non-compliance.

Fhe 31 AR's uniten as a resua of items 4 and 5 hase reen answered and I procedure changes generated to improve the " Severe Weather Preparations" procedure.

Tiie mstances listed above collectnelv mdicate that : rroblem exists uitn implementanon of riant crocedures m an .erbaum compiiance ' manner. .

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Recoillmendation; j 1

l 1 his tinding must be responded to in the manner desenbed in the coser letter. The l

t'ollow mg recommendauon is of ferea for S our consideration. l aie action as neessary to emorce me P! ant General \lanaueri espectations ar s errattm compliance 'ulth ratuirentents containea in riant procedures.

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@FPL AUDIT REPORT QSL.PM-96-02 Page 19 of 21 Audit

Participants:

Name Denartment/G roun PMON No.

R. Walker Training ol ,

C. Burton Services 01 J. West Services 15 W. Green SCE 15

11. Buchanan 11ealth Physics 04 D. Mercer liealth Physics 04 K. Wood Information Services 09 A. Molenda instrument & Control 09 J. Ilarmon Information Services 16 N. West Information Services 16 l

D. Jacobs Maintenance 16 l

E. Benkin Licensing 16 G. Schnebli Quality Control 16 T. Dwy er Quality Control 16 j K. Crosby Quality Control 16 l A. Pawley Instrument & Control 76 R. Toscano Maintenance 76 K. Korth Operations 14-li Lyons Operations 14

s. Nierrill Operaiions 14 S. Las elle Licensing 14 C. O'Farrill Reactor Engineering 15 B. Parks Reactor Engineering 15 W. Mead Reactor Engineering 15 l R. Klein Reactor Enginecring 15 l R. Teller Operations 15 1

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AUDIT REPORT ,

p QSL-PM-96-02 Page 20 0f 21 4

Pre-Audit' Notification:

Location: St. Lucie Plant Date: February 1.1996 Post-Audit Conference:

Location: St. Lucie Plant Date: NIarch 29.1996 Summary of Post-Audit Conference:

The results of the audit were discussed with personnel in attendance it was agreed that the findings i were valid and that correctise action would be taken. I 1

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l J. Scarola. C. O'Farrill. W. Bladow. J. Voorhees. L. Bearror. D. Lowens 1 ocation of Audit: .

1 St. Lucie Plant i

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O b AUDIT REPORT QSL-PM-96-02 Page 21 of 21 l Accomnanvine Auditors: J. Walls. B. Lowery, L. Beatror. S. Sanders  !

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Auditor: s ~.h '

L. L. Panessa Date Quality Assurance - PSL

, lleviewed by:

/ffevwJ FW2 H/2/%

J. T. Voorhees Date QA Supervisor - PSL j e

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