Text

Rev 31 to St Lucie Plant Radiological Emergency Plan
	ML20137P440
Person / Time
Site:	Saint Lucie
Issue date:	09/13/1996
From:	; FLORIDA POWER & LIGHT CO.
To:	;
Shared Package
ML20137P228	List: ML20137P226; ML20137P236; ML20137P391; ML20137P440; ML20137P509; ML20137P533; ML20137P565; ML20137P589; ML20137P595; ML20137P609; ML20137P624; ML20137P631; ML20137P647; ML20137P675; ML20137P686; ML20137P700; ML20137P714; ML20137P719;
References
	FOIA-96-485 NUDOCS 9704090249
	Download: ML20137P440 (150)
	v • d • e

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i ST. LUCIE PLANT

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RADIOLOGICAL EMERGENCY PLAN REVISION 31 4

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i Approved by:

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Date 9 / /3 / f/

President, Nuclear Division 9704d90249 970407 PDR FOIA BINDER 96-485 PDR

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ORGANIZATION. FACILITInct AND SUPPORT SERVICES (continued)'

1 2.4. 2.

Technical Support Center (TSC)

The company maintains an on-site Technical Support Center to provide the Control Room with in-depth diagnostic and engineering assistance l

without adding to congestion within the Control Room. - The.TSC interfaces with the EOF regarding those diagnostic and engineering i

decisions. This assistance can help determine the operational decisions that veould be appropriate to best control and mitigate the consw of the emergency. The TSC is located adjacent to the Unit 1 Control Room.

i Activation of the Technical Support Center will be initiated by the Emergency Coordinator in the event of an Alert, Site Area Emergency or General Emergency. Arrangements have been made to staff the TSC in a timely manner.

I The Technical Support Center contains pertinent records and drawings.

The Technical Support Center has an emergency communications network similar to the Control Rooms. The TSC also has the NRC FTS Emergency Telecommunications System. See section 4.6 for a more detailed description of the FTS system.

I 3.

Operational Support Center (OSC) i The company maintains an on-site Operational Support Center (OSC) to serve as an assembly point for auxiliary operators, health physics technicians, maintenance personnel, and other plant personnel available to support the emergency response. Required staff will be assigried to

]

appropriate activities by the Emergency Coordinator or bla/her designee.

Equipment that can be used by personnel dispatched from the OSC is stored in the Service Building. Table 2-4 indicates the types of material and equipment stored there.

Activation of the OSC will be initiated by the Emergency Coordinator.

The OSC will be activated and in operation for an Alert, Site Area Emergency or General Emergency. Arrangements have been made to staff the OSC in a timely manner.

t The OSC is maintained in the second floor large conference room in the i

North Service Building. Telephone communications are maintained between the OSC and the Technical Support Center.

i EPS:4 2-33 St. L.uce, Rev. 31

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. 2.

ORGANIZATION. FACILITIES. AND SUPPORT SERVICES (continued)

' 2.4 4.

Altemate Operational Support Center-4 in the event that the OSC becomes untenable, the Emergency Coordinator will designate an altemate location.

5.

Emergency Operations Facility (EOF)

The company maintains an Emergency Operations Facility from which evaluation and coordination of FPL activities related to an emergency j

can be carried out and from which FPL can provide information to federal, state, and local authorities.

_l 5

The Emergency Operations Facility is located at the intersection of State Route 712 (Midway Road) and I-95 approximately 101/2 miles west ef the St. Lucie Plant. The EOF has sufficient space to accommodate the Florida Power & Light Company response organization and designated representatives of the federal, state, and local authorities. Altemate temporary locations for the Emergency Operations Facility may be l

designated by the Recovery Manager if a natural disaster or other

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(non-radiological) extemal event significantly affects the operational capability of the facility.

m31 The Emergency Operations Facility has an emergency communications network including but not limited to, Local Govemment Radio (LGR),

commercial telephone lines, Hot Ring Down (HRD) phone, NRC ENS, NRC HPN, NRC counterpart links, ESATCOM, and various Florida I

Power & Light Co. maintained radio systems. Essential, precalculated j

emergency data and pertinent reports and drawirgs are readily av,ailable, j

l Activation of the Emergency Operations Facility is the responsibility of i

the Recovery Manager and is required for a Site Area Emergency or General Emergency. The RM should place the emergency response staff on standby in the facility for an Alert. Arrangements have been made to activate the EOF in a timely manner.

m31 i

6.

Emergency News Center (ENC) r An Emergency News Center (ENC) is provided to allow the news media access to information from the Emergency Operations Facility, i

The Emergency information Manager will designate an individual to supervise the ENC. The ENC is co-located with the EOF (Midway Road /l-95 intersection).

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' EPS:4 '

2-34 St. Lucio, Rev. 31

_... _ _ _ _ - _ ~ _ - _. _ _

7.

MAINTAINING EMERGENCY PREPAREDNESS ~(continued) 7.2 Emergency Response Training jj 1.

Objectives The primary objectives of emergency response training are as follows:

1.

Familiarize appropriate individuals with the Emergency Plan and' related implementing procedures.

2.

Instruct individuals in their specific duties to ensure effective and expeditious action during an emergency.

3.

Periodically present significant changes in the scope or content of the Emergency Plan.

i 4.

Provide refresher training to ensure that ' personnel are familiar with their duties and responsibilities.

5.

Provide the various emergency organization groups with the required training that will ensure an integrated and prompt response to an emergency situation.

2.

Training of On-site Emergency Respnse Organization Personnel Training programs have been established for personnel working at the plant site. The programs include initial indoctrination and subsequent retraining.

_ The training program for members of the on-site emergency response organization will include practical drills, as appropriate and participation in exercises, in which each individual demonstrates an ability to perform assigned emergency functions.

The St. Lucie Plant Training Manager is responsible fcr the conduct and documentation of initial training and annual retraining programs for on-site FPL Emergency Response Organization (ERO) personnel.

l Emergency teams will receive specific training as specified in the following subsections. The Emergency Planning Coordinator is responsible for the content and accuracy of the Emergency Planning Training. Each new employee permanently assigned to work at the St. Lucie Plant shall be given initial orientation training. For employees not assigned specific responsibility or authority under the Emergency Plan or Procedures, such training shall,' at a minimum, provide -

information describing the action to be taken by an individual discovering an emergency condition, the location of assembly areas, the identification of emergency alarms, and the action to be taken upon hearing those alarms.

/R31 EP3:4 :

7-8 St. Lucio. Rev. 31

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MAINTAINING EMERGENCY PREPAREDNESS (continued) 7.2 2.

Training of On-site Emergency Response Organization Personnel

- (continued) i k

i For employees with specific assignments or authonties as members.of

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emernency teams.. initial training and annual retraining programs will be

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provided. Training must be current to be maintained on the site Emergency Team Roster.. The site Emergency Team Roster is updated by the Pmot Training Manager once each calendar month. Securfty maintains training records for members of the Security.

/R31 The following provides a description of the training provided to personnel 4

l filling the indicated positions, 1.

Emergency Coordinator a.

Interpretation of plant and field data and how it relates to emergencies and their classification (i.e. emer0ency action level determination per Chapter 3).

i b.

Prompt and effective notification methods, including the types 1

of communication systems.

c.

Method of activating the Florida Power & Light Company Emergency Response Organization (ERO).

L d.

The methods used for estimating radiation doses and recommending off-site protective actions.

e.

Emergency Plan familiarization f.

Emergency Plan implementing Procedures (EPIPs) familiarization g.

Communications and record-keeping methods h.

Accident assessment and corrective action (licensed operators 4

only).

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. St. Lucis. Rev. 31

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' '"IhD FLORIDA POWER & LIGHT COMPANY r

E PLAN IMPLEMENTING PROCEDURE NO. 310 ST. LUCIE PLANT o

q REVISION 72

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1.0 TITLE

jPROCEOud p DUm ON-SITE EMERGENCY ORGANIZATION AND CALL DIRECTORY 2.0 REVIEW AND APPROVAL:

Reviewed by Facility Review Group 7/25 1975 Approved by K. N. Harris Plant General Manager 7/29 1975 Revision 72 Reviewed by F R G 9/12 1996 Approved by J. Scarola Plant General Manager 9/12 19 96 THIS PROCEDURE HAS BEEN COMPLETELY REWRITTEN, PLEASE READ ENTIRE PROCEDURE BEFORE PROCEEDING.

/R72

3.0 SCOPE

3.1 Purpose This procedure provides instructions and phone numbers necessary to activate the On-Site Emergency Organization (see Figure 1) for shift augmentation in response to an emergency declaration. In the appendices are the names, phone numbers and attemates for company emergency personnel, as well as phone numbers of County, State and Federal agencies, s

OPS DATE DOCT PROCEDURE DOCN 3100023E SYS COMP COMPLETED ITM 72

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ST. LUCIE PLANT F

E-PLAN IMPLEMENTING PROCEDURE NO. 3100023E, REVISION 72 ON-SITE EMERGENCY ORGANIZATION AND CALL DIRECTORY

8.0 INSTRUCTIONS

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8.1 Upon notification by the Emergency Coordinator (EC), tho' on-shift Emergency Response Organization shall assemble and prepare to respond as necessary l

to the emergency.

Upon notification by the EC, the Duty Call Supervisor (DCS),' will initiate staff l

8.2 augmentation in accordance with Figure 3, Staff Augmentation Call Tree. The j

DCS will use the (automated dialing) Emergency Recall System or l

Appendix A, Duty Call Supervisor Call Directory, to notify persons to fill the positions of Recovery Manager; TS eaith Physics Supervi ol, TSC f

Supervisod OSC Supervisor andiSC Security Supervis f

Supervisor Emergency Coordinato,

perations Coordinato 4

Instructions for use of the Emergency Recall System are in the ANPS office in s not used continue with the next step. N 8.3 2

either Control Room, p

r 8.4 The DCS will record the names of persons fillina oositions as well as_the expected times of arrival at the plant on a form similar to Figure 3.

c 8.5 The Recovery Manager shall determine the action to be taken by EOF

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Responders.

l 1.

For an Alert, EOF Responders should be notified and placed in a standby.

status or mobilized to respond to the EOF.

2.

The EOF shall be activated in a Site Area Emergency and/or General 1'

Emergency.

l

/ 8.6 Persons filling the positions of TSC HP Supervisor and TSC Chemistry Supervisor will notify the appropriate number of individuals from their k

respective departments in accordance with Figure 3 (See Appendix B, TSC

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Health Physics Supervisor and TSC Chemistry Supervisor Call Directory).

8.7 The TSC Supervisor (altemate) shall call the necessary persons to establish the minimum staff per Figure 3. He may call additional persons, as necessary i

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(See Appendix C, Technical Support Center Supervisor Call Directory).

t 8.8 The OSC Supervisor (altemate) shall call the necessary persons to establish the minimum staff per Figure 3. He may call additional persons, as necessary l

(see Appendix D, Operational Support Center Supervisor Call Directory).

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III. Documentation of Enforcement Panel / Caucus Consensus i

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Preliminary Severity Level (Prior to Application of any Discretion.

From Part I)

B.

Increase Severity Level based on Aggregation?

C.

Increase Severity Level for Repeat Violations?

(Address requirements of ROI 0903)

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SEVERITY LEVEL SUPPLEEKT/SECTION F.

Re6 Civil Penalty

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Civil Penalty Assessment A.

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Preliminary Severity Level (Prior to Application of my Discretion.

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B.

Identification Credit? YES - NO - N/A 15tC identified?

Licensee identified?

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ISSUE:

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Documentation of Enforcement Panel / Caucus Con A.

Preliminary Severity Level (Prior to Application of any Discrw Fme Part I) __

B.

Increase Scierity Level based on Aggregation?

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Increase Severity Level for W111 fulness?

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SEVERITY LEVEL -

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Recommended Civil Penalty G.

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B.

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Preliminary Severity Level (Prior to Application of my Discretion.

From Part I)

B.

Intvease Severity Level based on. Aggregation?

C.

Increase Severity Level for Repeat Violations?

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SEVERITY LEVEL SUPPLDENT/SECTION F.

Recommended Civil Penalty G.

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EICS ENFORCEMENT WORKSHEET EICS MEETING NOTES AND DOCUMENTATION OF UNDERSTANDING EA M EER:

Ov&V ATTDOEES FACILITY:

9.Lu.ie Set 94-46B SLBJECT:

68 gCAUCUS o PAEL a PEC a OTER a OI BRIEF INSPECTION EIO DATE:

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ENFORCEMENT ACTION WORKSHEET EICS HEETING NOTES AND DOCUMENTATION OF UNDERSTANDING II.

Civil Penalty Assessment A.

First non willful SL III violation in 2 vears/2 insoections? YES or NO Previous escalated cases:

B.

Identification Credit? YES - NO - N/A 15tC identified?

Licensee identified?

Revealed through an event?*

Prior opportunities?

C.

Corrective action credit? YES - ND - N/A Immediate corrective actions:

l Long tern corrective actions to prevent recurrence:

1 D.

Discretion anolied? Yes or No: Reason why.

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Civil Penalty:

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ENFORCBENT ACTION WORKSEET EICS EETING NOTES AW DOCtMMATION OF UWERSTMING NOTE: Complete the following information for each violation ISSUE:

III. Documentation of Enforcement Panel / Caucus Consensus A.

Preliminary Severity Level (Prior to Application of av Discrdion.

From Part I) 8.

Increase Severity Level based on Aggregation?

C.

Increase Severity Level for Repeat Violations?

(Address reqirtrements of HDI 0903) i D.

Increase Severity Level for Willfulness?

E.

SEVERITY LEVEL SUPPLEENT/SECTION F.

Recommanded Civil Penalty G.

Predecisional Enforcement Conference Necessary?

il H.

Revision to Draft NOV Required?

I.

Fonnal Review by OE Required?

J.

gial Action Items / Nessage to Licensee / Comments KKlor-fes

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ENCLOSURE 4

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EICS ENFORCEMENT WORKSHEET EICS MEETING NOTES AND DOCUMENTATION OF UNDERSTANDING

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(To be Completed by ElCS per ROI 0912)

EA NUMBERh kb ~~bb ATTENDEES FACILIT(:

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II.

Civil Penalty Assessment A.

First non willful SL III violation in 2 years /2 insoections? YES or NO Previous escalated cases:

B.

Identification Credit? YES NO N/A NRC identified?

Licensee identified?

Revealed through an event?*

Prior opportunities?

C.

Corrective action credit? YES NO N/A Immediate corrective actions:

Long term corrective actions to prevent recurrence:

D.

Discretion aoolied? Yes or No:

Reason why.

E.

Civil Penaltv:

F.

Recommendation for credecisional enforcement conference:

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ENFG E EMENT ACTION WORKSHEET EICS MEETING NOIU ANO DOCUMENTATION OF UNDERSTANDING (To be Completed by EICS per ROI 0912)

NOTE: Complete the following information for each violation ISSUE:

III. Documentation of Enforcement Panel / Caucus Consensus A.

Preliminary Severity Level (Prior to Application of any Discretion.

From Part I) i B.

Increase Severity Level based on Aggregation?

C.

Increase Severity Level for Repeat Violations?

Udfress requirements of ROI 0903)

D.

Increase Severity Level for W111 fulness?

E.

SEVERITY LEVEL SUPPLEMENT /SECTION F.

Recommended Civil Penalty G.

Predecisional Enforcement Conference Necessary?

H.

Revision to Draft NOV Required?

I.

Formal Review by OE Required?

J.

Special Action Items / Message to Licensee / Comments 5 AlvU At GYosh - YL. WN h I

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@T. L(.u:iG h&

/ST SLBJECT:

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(* VIA TELEPHOE)

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i JL Civil Penalty Assessment YESorh JL First non willful SL III violation in 2 years /2 insoections?

Previous escalated cases:

B.

Identification Credit? YES - NO - N/A EC identified?

Licensee identified?

Revealed through an event?*

Prior opportunities?

C.

Corrective action credit?

NO - N/A Immediate corrective actions:

Long term corrective actions to prevent recurrence:

4

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Yes or h Reason why. bM D.

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Civil Penalty:

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BRRCDENT ACTI(W M EICS DEETIIE HDTES AfD DoctBENATI(BI 0F IAEERSTAfEIP'7 i

INTE: Caglete the' following infomation for each violation ISSLE:

III. Docueentation of Enforcement Panel / Caucus Consensus A.

Preliminary Severity Level (Prior to Application of any otscretion.

From Part I) 8.

Increase Severity Level based on Aggregation?

1 C.

Increase Severity Level for Repeat Violations?

4 (Address regstruments of ADI 0903)

D.

Increase Severity Level for Willfulness?

i.

E.

SEVERITY LEVEL SIPPLDENT/SECTION F.

Recoseended Civil Penalty G.

Predecisional Enforcement Conference Necessary?

H.

Revision to Draft NDV Required?

i I.

Fomal Review by OE Required?

J.

Special Action Items / Nessage to Licensee / Comeents i

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4 uNrrED STATES NUCLEAR REGULATORY COMMISSION f

REesoN li s

ih1 1 with two exampics. 101 MARIETTA STREET, N.w., sulTE 200D ATLANTA, GEORGIA 30350199

\\*****[e 10 CFR 50 Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel i

Reprocessing Plants," Criterion lil requires, in part, that... design control measures shall provide for verifying or checking the adequacy of design, such as the performance of design reviews...The verifying or checking process shall be performed by individeals or groups other than those who performed the original design, but who may be from the same organization.

I FPL Topical Quality Assurance Report, TOR 3.0, revision 11, " Design Control," Section 3.2.4, " Design Verification," stated, in part, " Design control measures shall be established to independently verify design input... Design verification shall be performed by technically qualified individuals or groups other than those who performed the design.

3 Engineering Quality instructions 1.7 " Design input / Verification," rev.1, dated July 5, 1995, states in part, " Design verification is the process whereby a competent individual, who has remained independent of the design process, reviews the design inputs,... and design output to verify design adequacy.

l i

Contrary to the above:

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1.

Design change (PC/M 009-195) was implemented without an independent design verification by a competent individual. Design change PC/M 009-195 to install new Gamma Metrics Nuclear instrumentation drawers was completed by a lead designer and a lead engineer. Contrary to this requirement the first reviewer (a designer) could not be considered as competent because he was not j

an engineer as required by QI 1.7 and the lead engineer as the third reviewer I

could not be considered to have remained independent of this design project.

2.

An adequa,te independent design verification was not conducted for the installation of a new core flux monitoring computer code BEACON. During initial operation of BEACON it was found that the code did not compensate for a core mid-plane offset created by a previous core modification. The engineer who

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prepared the design was not aware of the core mid-plane offset and the t

independent review of the new BEACON code did not identify this omission.

i Violation 2 with two examples 1

Technical Specification 6.8, Procedures and Programs, paragraph 6.8.1 requires in part that written procedures recommended in Appendix A of Regulatory Guide 1.33 revision 2, February 1978, shall be established, implemented...

Administrative Procedure No. 0006130, Condition Reports, revision 4, dated March 22,

' 1996, Paragraph 8.1.1.A states in part that "Any individual who becomes aware of a problem or discrepant condition... should initiate a CR. If doubt exists, a CR form should be initiated" Engineering Quality Instruction (Ql) 3.7, Computer Software Control, revision 1, Section

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/ mee?q'o*g UNITED STATES NUCLEAR REGUI ATORY COMMISSION y

REosoN 11 101 MARIETTA sTME(T, N.W., sufTE 2000 j

ATLANTA, GEORGIA 3312s4199

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/ 5.4. requires that SQA1 software shall be validated and verified (V&V'ed) in accordance with Section 5.6. Section 5.6 states that new software shall be V&V'ed prior to use.

V&V includes the use of test cases to ensure the new software produces correct results.

Item 4 of Section 5.6 states that technical adequacy shall be determined by comparing the test case to results from attemative methods such as functionally equivalent and previously validated software.

Contrary to the above, On July 30,1996, instrument and Control technicians installing a plant Design Change (PC/M 009-15) did not initiate a Condition Report when they became aware of a discrepant condition conceming incorrectly marked cables. They continued to install the modification and an error was made that resulted in cross-wiring of the nuclear instrumentation system.

BEACON was placed into service on Unit 1 without benchmarking against IMPAX, functionally equivalent and previously validated software.

(NOTE TO PANEL: This could be considered another example ofinadequte PMT as identified in EA 95-18f. V&Vis the post-mod acceptance test for software.)

(gn RD 1

4 ENFORCEMENT ACTION WORKSHEET INADEQUATE DESIGN CONTROL PREPARED BY: John W. York DATE: October 28, 1996 NOTE: The Section Chief of the responsible Division is responsible for preparation of this EAW and its distribution to attendees prior to an Enforcement Panel. The section Chief shall also be.

responsible for providing the meeting location and telephone bridge number to attendees via e-mail [ENF.GRP. CFE. OEMAIL. JXL. JRG. sHL, LFD: appropriate RII DRP. DRs; appropriate NRR. NMss].

A Notice of Violation (without *boilerplate") which includes the recommended severity level for the violation is required. Copies of applicable Technical specifications or license conditions cited in the Otice or other reference material needed to evaluate the proposed enforcement action are required to be enclosed.

This Notice has been reviewed by the Branch Chief or Division Director and each violation includes the appropriate level o s i fi,c1 as to how and when the requirement was violated.

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G14rktfure" Facility: St. Lucie Unit (s): 1 and 2 Docket Nos: 50 335, 389 License Nos: DPR 67. NPF 1 Inspection Report No: 96-Inspection Dates: 10/7 11, and 10/15 18, 1996 Lead Inspector: John York 1.

Brief Summary of Inspection Findings:

[Always include a short statement of the regulatory concern / violation. Reference and attach draft NOV. Then, either sumarize the inspection findings in this section or reference and attach sections of the inspection report. Insnectors are encouraged to utilize the Noncompliance Information Checklist provided in Enclosure 4 to ensure that the information gathered to support the violation is complete.)

The licensee replaced some safety related nuclear instrumentation drawers during the Unit 1 Outage.

The drawers were wired backwards because of incorrect drawings.

Part of the root cause identified the lack of a proper independent verification as a potential cause.

This is a violation of 10 CFR 50 Appendix B Criterion III.

In examining the safety aspects of this event, one additional example of inadequate design verification was identified for BEACON on line core performance monitoring system.

In addition to the wiring problem for the drawers. the maintenance group connected the field cables for an NI backwards because the markmgs on the connectors were different than on the previous detectors.

An NOV was written for failure to write a Condition Report (discrepancy report) and resolve this problem prior to installation of the detector.

See attached IR feeder and proposed NOV for details.

PROPOSED ENFORCEMENT ACTION - NOT FOR PUBLIC DISCLOSURE WITHOUT THE APPROVAL OF THE DIRECTOR, OE

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o ENFORCENINT ACTION womasassT t

2.-

Analysis of Root Cause:

Lack of control and procedural adherence.in the licensee's program for preparing and implementing Plant Change / Modifications (PC/Ms).

3.

Basis for Severity Level (Safety Significance): -CInclude example from the

~ supplements, aggregation, repetit1veness, willfulness etc.]

Aggregation of examples and" application of Supplement I, C.7. a breakdown in the control of licensed activities involving two violations that are related that collectively represent a potentially significant lack of attention'toward licensed activities.

The safety significance of reversing the detector inputs to the NIS drawers substantially reduced the safety margin between the TM/LP trip setpoint and the analysis limit even considering the increased TM/LP

. margin to the trip setpoint due to actual core operating conditions.

~

4.

Identify Previces Escalated Action Within 2 Years or 2 Inspections?

. by EA#, supplement. and Identification date.]

[

EA 96-249 - Inadequate 50 59 did not identify US0. 7/12/96 EA 96-040 - Boron 0verdilution Event.. Supplement 1. 1/22/96 EA 95 180 - Inoperable PORVs due to Inadequate PMT. Supplement 1. 8/4/95 5.

-Identification Credit? No

.The miswired NI drawers were identified through an event (the failure to have the system respond properly), i. e. the analysis of the data by Reactor Engineering discovered the miswiring of the NI drawers but the error in the drawing should have been discovered in the design control process.

-The design error associated with BEACON was identified through routine comparisons of actual plant data with predicted data.

This error could have been discovered in the design control process.

Enter date Licensee was aware of issues requiring corrective action:

7/30/96 6.

Corrective Action Credit? Yes Brief summary of corrective actions:

In response to the issue, the licensee adopted corrective actions which included:

e

~For immediate action the licensee prepared a change request-for the' modification package and channels A.C. and D were reconnected and testing was performed to verify proper NI response.

e A root cause/self assessment and training meeting for the Engineering Department emphasizing importance of proper design PROPOSED ENFORCEMENT ACTION - NOT FOR PUBLIC DISCLOSURE WITHOUT THE APPROVAL OF THE DIRECTOR, OE k

4 s

(

ENFORCEMENT ACTION WORKSEEET verification and irportance of questioning attitude.

Tape was produced of this meeting for future engineering training.

I e

Procedures (Engineering Quality Instructions) were revised to (1) require all critical aspects be verified during the PC/M. (2) emphasize that the same level of verification is required for PC/Ms duplicated for the second unit, and-(3) reinforce the verification requirements for safety related drawings.

e Walkdowns will be conducted (linear NIs) to revise any design -

documentation and tagging.

e ASI targets will be established for future trending of ASI during power ascension.

e Require cross-disciplinary reviews of design inputs o

Better documentation of assumptions in core design inputs and codes Explain application of corrective action credit:

Corrective action appears to be of appropriate scope.

7.

Candidate For Discretion? N0 Explain basis for discretion consideration.

Since actual power conditions did not exceed trip setpoints, no escalation is warranted.

Several examples of licensee's declining performance in engineering does not warrant mitigation.

8.

Is A Predecisional Enforcement Conference Necessary? Yes Why:

To determine adequacy of licensee's proposed long-term corrective actions regarding backward looks at modifications performed prior to the Unit 1 outage.

This included discussions of other modifications that may not have been independently verified.

If yes, should OE or 0GC attend?

[ Enter Yes or No):

Should conference be closed?

[ Enter.Yes or No):

9.

Non Routine ' Issues / Additional Information:

PROPOSED ENFORCEMENT ACTION - NOT FOR PUBLIO DISCLOSURE WITHOUT THE APPROVAL OF THE DIRECTOR, OE

ENFORCEMENT ACTION wommsusar-10.

This Action is Consistent With the Following Action (or Enfor' cement Guidance) Previously Issued:

[EICS to pro"ide] [If inconsistent. include:]

Basis for Inconsistency With Previously Issued Actions (Guidance) 11.

Regulatory Message:.

Positive control must be established and maintained over the design process with particular emphasis on properly performing independent design verification.

12.

Recomiwnded Enforcement Action:

SL Ili 13.

This Case Meets the Criteria for a Delegated Case. [EICs - Enter Yes or No]

14.

Should This Action Be Sent to OE For Full Review? [EICs - Enter Yes or No]

If yes why:

15.

Regional Counsel Review [EICs to obtain)

No Legal Objection Dated:

16.

Exempt from Timeliness: (EICs]

Basis for Exemption:

Enforcement Coordinator:

DATE:

PROPOSED ENFORCEMENT ACTION - NOT FOR PUBLIC DISCt.OSURE

' WITHOUT THE APPROVM, OF THE DIRECTOR, OE 2

ENFORCEMENT ACTION WORKSHEET - ISSUES TO CONSIDER FOR DISCRETION j

o Problems categorized at Severity Level I or II.

O Case involves overexposure or release of radiological material in excess of NRC requirements.

]

o Case involves particdlarly poor licensee performance.

j o

Case (may) involve willfulness.

Information should be included to address whether or not the region has had discussions with OI regarding the case, whether or not the matter has been formally referred to 01.

and whether or not 01 intends to initiate an investigation.

A description, as applicable, of the facts and circumstances that address the aspects of negligence, careless disregard, willfulness, and/or management involvement should also be included.

1 a

Current violation is directly repetitive of an earlier violation.

a Excessive duration of a problem resulted in a substantial increase in risk.

o Licensee made a conscious decision to be in noncompliance in order to j

obtain an economic benefit, a

Cases involves the loss of a source.

(Note whether the licensee self-identified and reported the loss to the NRC.)

J a

Licensee's sustained perforn.ance has been particularly good.

o Discretion should be exercised by escalating or mitigating to ensure that the proposed civil senalty reflects the NRC's concern regarding the violation at issue and tlat it conveys the appropriate message to the licensee.

Explain.

PROPOSED ENFORCEMENT ACTION - NOT FOR PUBLIC DISCLOSURE

. WITHOUT THE APPROVAL OF THE DIRECTOR, OE

REFERENCE DOCUMENT CHECKLIST

[]

NRC Inspection Report or other documentation of the case:

NRC Inspection Report Nos.:

[]

Licensee reports:

[-]

Applicable Tech Specs along with bases:

[]

Applicable license conditions

[]

Applicable licensee procedures or extracts

'[ ]

Copy of discrepant licensee documentation referred to in citations such as NRC, inspection record, or test results

[]

Extracts of pertinent FSAR or Updated FSAR sections for citations involving 10 CFR 50,59 or systems operability

[]

Referenced ORDERS or Confirmation of. Action Letters

[]

Current SALP report summary and applicable report sections

[]

SUBJECT:

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PREPARED BY: N'R DATE: 1(Ob96 TIME: (N'2D I.

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Civil Penalty Assessment A.

First non-willful SL III violation in 2 years /2 inspections? YES or l

Previous escalated cases:

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D.

Discretion aoolied? Yes or No-Reason why.

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Civil Penalty:

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Recommendatio.

T oredecisional enforcement conference:

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3 ENFORCEENT ACTION WORKSEET EICS EETING NOTES E DOCUENTATION OF UWERSTEING NOTE: Complete the following infomation for each violation ISSUE:

III. Documentation of Enforcement Panel / Caucus Consensus A.

Preliminary Severity Level (Prior to Application of any Discretion, From Part I)

B.

Increase Severity Level based on Aggregation?

C.

Increase Severity Level for Repeat Violations?

(Address regsirements of ROI 0903)

D.

Increase Severity Level for Willfulness?

E.

SEVERITY LEVEL SUPPLEENT/SECTION 1.d F.

Recommended Civil Penalty G.

Predecisional Enforcement Conference Necessary?

l H.

Revision to Draft NOV Required?_

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Formal Review by OE Required?

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Special Action Items / Nessage to Licensee / Comments i

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l ENFORCEMENT ACTION WORKSHEET EICS MEETING NOTES AND DOCUMENTATION OF UNDERSTANDING II.

Civil Penalty Assessment A.

First non willful $L III violation in 2 'vears/2 insoections? YES or NO Previous escalated cases:

B.

Identification Credit? YES - NO - N/A 15tC identified?

4 Licensee identified?

Revealed through an event?*

Prior opportunities?

C.

Corrective action credit? YES - NO - N/A Immediate corrective actions:

Long tern corrective actions to prevent recurrence:

D.

Discretion anolied? Yes or No:

Reason why.

E.

Civil Penalt'.e:

j F.

w-

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I i

k 1

1

F vA w..

3 ENFORCEENT ACTION WORKSHEET EICS EETING NOTES AE DOClMMfATION OF UWERSTAEING NGTE: Complete the following information for each violation ISSUE:

III. Documentation of Enforcement Panel / Caucus Consensus i

A.

Preliminary Severity Level (Prior to Application of any Discretion.

From Part I)

B.

Increase Severity Level based on Aggregation?

C.

Increase Severity Level for Repeat Violations?

(Address rgirements of ROI 0903) l D.

Increase Severity Level for Willfulness?

E.

SEVERITY LEVEL SUPPLEENT/SECTION F.

Recommended Civil Penalty G.

Predecisional Enforcement Conference Necessary?

H.

Revision to Draft NOV Required?

I.

Fonnal Review by CE Required?

J.

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ENFORCEMENT ACTION WORKSHEET EICS HEETING NOTES AND DOCUMENTATION OF UNDERSTANDING II.

Civil Penalty Assessment A.

First non willful SL III violation in 2 years /2 insoections? YES or NO Previous escalated cases:

B.

Identification Credit? YES NO - N/A MtC identified?

4 Licensee identified?

Revealed through an event?*

l Prior opportunities?

C.

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3 ENFORCDENT ACTION WORKSEET EICS EETING NOTES Als DOCLM3fTATION OF LMIERSTAleING n

NOTE: Complete.the fo110:dr41nformation for each violation-l ISSLE:

III. Documentation of Enforcement Panel / Caucus Consensus A.

Preliminary Severity Level (Prior to Application of my macretion.

From Part I)

B.

Increase Severity Level based on Aggregation?

C.

Increase Severity Level for Repeat Violations?

(Adhess rapirements of HDI 0903) l D.

Increase Severity Level for Willfulness?

E.

SEVERITY LEVEL SUPPIBENT/SECTION F.

Recommended Civil Penalty G.

Predecisional Enforcement Conference Necessary?

H.

Revision to Draft NOV Required?

I.

Formal Review by OE Required?

J.

Special Action Items / Nessage to Licensee / Comeents e

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Civil Penalty Assessment A.
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B.
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3 ENFORCEENT ETION WORKSEET EICS EETING NOTES M DOCUENTKfION OF UWERSTEING NOTE: Complete the following information for each violation ISSUE:
III. Doctamentation of Enforcement Panel / Caucus Consensus A.
Preliminary Severity Level (Prior to Application of any Discretion.
From Part I)
B.
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4 C.
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Recommended Civil Penalty G.
Predecisional Enforcement Conference Necessary?
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Formal Revirm by OE Required?
J.
Special Action Items / Nessage to Licensee / Comments e
1 4 1
I 1
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P:\\ FORMS.DIR\\ENFP M L.FRM / October 11, 1996 9
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Preliminary Severity Level (Prieg to Aplication of any Discretion, From Part I)
IJ-Vfd B.
Increase Severity Level based on Aggregation?
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SEVERITY LEVEL ___ I SUPPLB OIT/SECTION f./,, 9 i
F.
Recmmended Civil Penalty do G.
Predecisional Enforcement Conference Necessary?
NS H.
Revision to Draft NOV Required?
W5 I.
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Special Action Items / Message to Licensee / Comments L
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'El c
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]
EiE. Complete the following information for each.. violation.._
ISSUE:
III. Documentati of Enforcement Panel / Caucus Consensus
~ ~ ~
A.
Preliminary ity Level (Prior to Application of my Discretion.
From Part I) -
\\
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)
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SEVERITY LEVEL SUPPLDENT/SECTION F.
Recommended Civil Penalty G.
Predecisional Enforcement Confere'nce Necessary?
\\
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I.
Formal Review by OE Required?
\\
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Special Action Items / Nessage to Li
/ Comments
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NDTE: Complete the following infomation for each violation ISSIE:
III.
Deartem,
lon of Enforcement Panel / Caucus Consensus I
A.
ndism:ary Severity Level (Prior to Application of my Discretion.
a Gu. /wt I) 1 B.
Increase Severity Level based on Aggregation?
C.
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SEVERITY LEVEL SUPPtBENT/SECTION F.
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Special Action Items / Message to Licensee / Comeents i
I 1
[ % A/
OICN No.
7 QUALITY INSTRUCTION CHANGE NOTICE (QICN)
APPROVAL Chief - Engineering Assurance Date Quality Assurance Dept (as reg'd)
N/A (see ** below)
Date VP - Nuc Engr and Lic (as reg'd)
Date DESCRIPTION OF CHANGE I
This 01CN adds additional Verification & Validation (V&V) guidance to ENG OI 3.1.
" Computer Software Control". Section 5.8 of 013.7 requires that. as a minimum.
V&V for revisions to pre-existing process software be done to the level of the original ecuipment. This 0ICN provides guidance for additional V&V tools that may be usec based on the critical nature of some process software.
BEASON FOR/ INTENT OF CHANGE In December.1995 a failure of a revision to the R-11/R-12 radiation monitor firmware occurred.
013.7 requires that the V&V for revision be done to the original level of equipment as a minimum. Therefore, a rigorous V&V had not been performed on the revision.
This 01CN provides a reference to additional V&V tools that may be used in similar instances.
This QICN does not change the intent of the procedure.
Therefore. 0A j
approval of this 01CN is not required.
SPECIAL INSTRUCTIONS l
1.
Insert this 01CN in front of 01(s) 3.7 ATTACHMENTS Mark-ups of.ENG 01 3.7 Pages 8 and 11 of 14 (2 pages).
l i
i QUALITY INSTRUCTION ENG-Ol 3.7 l
G.
REV.
1(QICN 7) i DATE 4/29/96
]
pp(,
NUCLEAR ENGINEERING C0rlfiER SOFTWARE CONTROL PAGE 8
OF 14 process code, including ladder diagrams. ladder diagrams cross reference, and a detail design description.
The SDD shall be reviewed for adequacy and feasibility (typically part of PC/M review process). The computer software being developed shall receive at least one design review covering the complete design as described in the SDD. The SDD shall be reviewed to ensure that it implements the SRS, and approved. The majority of the SDD may be from pre-existing vendor controlled documentation / spec sheet if it meets the criteria.
4)
V&V shall be performed in accordance with Section 5.6.
5)
User manuals (vendor manuals) shall be obtained or developed as required based on the complexity of the software.
6)
Process software errors or defects shall be screened for potential 10CFR21 applicability / evaluation (see ENG OI 2.2).
7)
Installation of new or revised process software must consider plant operation in all modes, as well as intermediate plant configurations during software installation.
8)
Modifications to process software shall be accomplished using the applicable PC/M process. The 10CFR50.59 considerations shall be addressed as part of the PC/M.
All affected documentation required by Section 6.0 shall be revised as recuired to reflect the software revision.
See Section 5.6 for verification /valication requirements for revised software.
9)
Process software changes that affect control room indication shall be duplicated in the control room simulator software.
5.6 Software Verification & Validation Plan and Report (SVVP and SVVR)
See V&V of newly developed / revised computer software shall be completed plrior to use.
section~5' 8 for'th~e re'quirements applicable to~ pre bkisting software V&V 1s a multi-
~
faceted ~ process that ma9 include product'in-jroces's~'r'eviews.~p'rodUct evaluation and testing. process and product audits, process and algorithm analysis, anomaly detection and resolution, as well as other associated activities. V&V is modeled to follow the guidance of IEEE Std 1012. " Software Verification and Validation Plans" V&V planning must take into consideration such project characteristics as software criticality (including the software classification). safety and reliability requirements, schedule.
resources. customer expectations. etc. Note that critical software as referred to in the standard applies to safety related process and SOA1 software only.
1)
V&V results shall be reviewed by an independent individual other than the developer of the software.
--- l
QUALITY INSTRUCTION ENG-ol 3.7 o
REV.
1(QICN 7)
DATE 4/29/96 F P L.
NUCLEAR ENGINEERING COMPUTER SOFTWARE CONTROL PAGE 11 OF 14 5.8 Pre Existina Software Recuirements Pre-existing non-process computer software is defined as software which was placed into a production environment prior to and not modified since the implementation of FPL's software 0A program (before 1990).
Pre-existing computer software (purchased, developed, or otherwise obtained) which falls under the scope of this procedure shall be eva luated in order to justify continued use. Although the specific requirements for an SRS. SDD. SVVP. and SVVR need not be retrofitted to pre-existing software, periodic validation testing and verification testing for revisions to the software must be performed and controlled in accordance with this procedure. See Section 5.6. Form 136 (or equivalent) shall be prepared for all pre-existing computer software within the scope of this proced.ure, and submitted to NIS for inclusion in the CSI. RsvisToWHto pre-existing
>0Aleveh ;non3 process ^ soft @a~r;s3 hall'mestiths30rrentdeq01FementhMth Revisions to pre-existing process software shall be purchased such that V&V is performed to the level of the original equipment, as a minimum.!!(IHEsonis]fd5Es additionalW8V activitisiinaf!beWrranted basedfoniths crit'icalinature of[thelprocess r
softwarea flEEELStandard(1012ican/be usr&as f aiguidelfor> additional?V&VRtoolsitolbe used in these instancesi 1 Additional assurance of proper; operation can ahlo be obtained byLblack boxLtesting;and/or(siteitestinglof; functions;on; training; equipment:
5.9 Software Confiauration Reauirements Process software configuration is controlled via the PC/M process.
Non-process software configuration control shall be maintained via the CSI in accordance with Section 5.10.
Newly developed, purchased, or revised software shall be identified to NIS via Form 136 (or equivalent).
Additional guidance on software configuration control is provided in lower tier NIS working procedures.
Revisions to software may be required for the following reasons:
discrepancies noted during validation discovery of software errors modifications or revisions in software requirements The following steps are to be followed in performing software revisions:
1)
All software revision / modification to be performed by NIS shall be initiated by an RFS. Details and guidance on the RFS process are provided in lower tier NIS working procedures.
2)
Revisions to computer software shall be verified and processed in
QUALITY INSTRUCTION ENG-Ol 3.7 REV.
1 NUCLEAR ENGINEERING DATE 7/5 95 (effectin) f:PL COWUTER SOFTWRE CONTROL PAGE 1
OF 14 1.0 APPROVAL Approved by:
Date:
2.0 SCOPE This instruction applies to all computer software that falls under the FPL Quality Assurance program.
Specifically, this instruction applies to:
Software which is used to support design, testing, acceptance, or operation of Safety Related or Quality Related items Software which is used to verify compliance with Technical Specifications Software which is used to determine / document compliance with Regulations i 3.0 PURPOSE The purpose of this instruction is to provide requirements and guidance for computer software control, including software develupment, procurement.
verification and validation, maintenance, and configuration management.
4.0 ACCOUNTABILITIES 4.1 The Manager - Nuclear Information Services (NIS) is accountable for:
ensuring implementation of an overall computer software control program (excluding process software) approving the purchase of computer software and related documentation (excluding process software) 4.2 The PSL and PTN Engineering Managers are accountable for ensuring that process software meets the requirements of this procedure.
NOTE: Process software is defined as software which directly controls the functional aspects (actuation / regulating / monitoring) of plant i equipment.
4.3 Managers are accountable for ensuring compliance with this instruction and maintaining adequate interface with NIS and user groups.
4.4 Supervisors are accountable for approving software related activities and documentation as required by this instruction, and ensuring that l
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1 appropriate personnel receive training commensurate with the requirements of this instruction.
4.5 Engineers and Analysts are accountable for complying with the requirements of this instruction for software related activities and documentation.
5.0 INSTRUCTIONS 5.1 Software Control Process Overall software control requires adequate control mechanisms in each of the following phases of the typical software life cycle:
Requirements Phase Design Phase Test Phase Installation and Checkout Phase Operation and Maintenance Phase Retirement Phase All software (excludirg process software) procurement. development, and modification shall be coordinated with Nuclear Information Services (NIS).
Regardless of the nature or application, all non-process software within the scope of this instruction falls under the general responsibility of NIS for screening, approval, access control. integration into existing i networks / platforms, and incorporation into the Computer Software Index (CSI).
Much of the detailed guidance for NIS support and processing is contained in lower tier NIS working procedures.
The following sections provide control requirements and methods to address the software life cycle phases above.
5.2 Software Cateoories The two basic software categories are process and non-process. Process software is software used in an automated process control system designed to actuate, regulate.
and/or monitor plant systems subsystems or components on a real-time basis.
Process software is classified and controlled under the PC/M process (See Section 5.5).
Non-process software is softwar'e used in the performance of calculations, data bases, indices. work flow processes etc.
Non-]rocess software is further broken down into four categories as listed 3elow.
Non-process software requirements are detailed in Section 5.4.
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(1)
Software Ouality Assurance Level 1 (SOA1)
Includes software which provides unique technical capabilities that are unavailable via alternate methods.
Also in'cludes complex databases such as expert systems that alter safety related data without verification. 50A1 software is treated like a " black box" and the output cannot be readily independently verified.
Examples: LOCADOSE. Finite Element Analysis Programs (2)
Software Ouality Assurance Level 2 (SOA2)
Calculational software used as a convenience and time saving tool.
The software results at e oblemble through alternative (but more time consuming) methods.
This software category includes programs that perform simple or complex arithmetic operations and mathematical functions (e.g.,
solving of boolean algebra.
statistical analysis, trigonometric functions). The output /i esults from SOA2 software can be obtained through alternate methods including bounding analysis, and alternate calculation.
Examples: CAFTA. PIPE-FLO (3)
Software Quality Assurance Level 3 (SOA3)
Software used to automate business processes, develop and maintain data bases.
Safety related data contained in a SOA3 data base is not modified by the database software.
Examples: Pas port. Request Processing System (4)
Software Ouality Assurance Level 4 (50A4)
Widely available commercial software used to produce spreadsheets.
data bases, word processing, or to perform arithmetic functions.
Based on widespread usage and acceptance, use of this software is analogous to other software tools such as Fortran. DOS. Basic, etc.
1 Examples: Excel. Access. WP 5.3 General Non Process Software Reauirements 1)
Requests for new computer software shall be prepared using Form 135 (or equivalent) and submitted to NIS.
After NIS processing, the i
requester shall be informed of whether the request was approved or rejected.
Requests for software modification / development shall be prepared using a Request for Service (RFS) and submitted to NIS or via an equivalent on-line system.
Guidance for RFS processing is provided in lower tier NIS working procedures.
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NIS should install PC software on the requestor's/ developer's Local I Area Network (LAN) Server or workstation.
Otherwise. NIS shall distribute a " working" copy of PC software to requestors / developers who shall in turn submit Form 136 to NIS as input to the CSI.
3)
Access to computer software shall be controlled to ensure protection against unauthorized access.
Network / mainframe software control shall include log-on passwords.
Additional guidance on software security is provided in lower tier NIS working procedures.
4)
Technical assistance, for users experiencing software problems / anomalies, can be requested from NIS using Form 138 or equivalent (e.g.. an RFS or Form 135).
5)
Computer software shall be handled under the same Problem Reporting.
Non-Conformance. Corrective Action, and Substantial Safety Hazard requirements as hardware, using the applicable instructions.
6)
All users shall comply with software license agreements related to their specific software. including terms and conditions pertaining to duplication, disclosure, and confidentiality.
7)
Software users shall be trained as necessary on computer software.
l The necessity and extent of training is at the discretion of immediate supervision and department management.
8)
Retirement of computer software from the production environment shall be indicated to NIS via Form 136 (or equivalent).
1 9)
NIS personnel receiving notification from Computer Operations (CPO) of a significant proposed system change shall assess the impact of the change on their application (s) and respond as requested by CPO.
i 10)
All production software and data shall have current backups. When possible. these backups shall be physically separate from the l
production software and data.
11)
Pre-existing software is exempt from certain requirements (see Section 5.8).
I i
12)
A Computer Software Index (CSI) shall be maintained by NIS and include a listing of all software within the scope of this instruction. excluding process software (see Section 5.10).
I 13)
A package which includes all documents applicable to the software shall be assembled and retained as specified in Section 6.0.
14)
User manuals / documentation should specify and describe required data, input, options, limitations, and other key information. Error
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OF 14 messages should be identified with required response actions.
5.4 Non Process Software Develooment/ Purchase / Control Recuirements SQA1 1)
A Software Requirements Specification (SRS) shall be prepared which identifies and describes the function, performance, constraints, attributes, external interfaces, and user documentation requirements of the computer software.
SRS requirements should be caoable of being objectively verified.
The SRS shall be reviewed to ensure _
adgquacy and teasibility.
a_nA__ approved The procurement accuments.if applicable. may constitute the majority of the SRS if they meet the criteria.
2)
A Software Design Description (SDD) shall be prepared which identi fies and describes the functions, components, and subcomponents of the software design.
specific hardware requirements, interfa
s. data sources, and how the SRS requirements will be implemented.
The computer software being developed shall receive at least one ign review covering the complete design as describedintheSDD]. The SDD sh 1 be reviewed to ensure that it implements the SRS, and approved.
The majority of the SDD may be from pre-existing vendor controll documentation / spec sheet if it meets the criteria.
3)
V&V shall be performed in accordance with Section 5.6.
The V&V for purchased SOA1 should be performed by the vendor when feasible.
If the vendor is unable perform the V&V. then it may be performed by FPL.
All discrepancies revealed during validation / verification of the software shall be resolved by the vendor prior to delivery /use of the computer software unless otherwise stated by the procurement documentation.
4)
If possible. SOA1 software should be purchased as PC-1 from a qualified vendor.
If necessary, software which is not developed under an approved nuclear 0A program may be purchased for SOA1 applications as PC-2.
The required validation and verification activities shall be performed in accordance with Section 5.6.
FPL assumes 10CFR21 responsibility for dedicated software.
The vendor shall be required in the purchase order to notify OA of any 3roblems/ errors subsequently revealed in the supplied software.
If t1e software vendor is unable to support error notification. FPL shall perform a documented evaluation to determine the appropriate compensatory measures to be taken.
The evaluation shall consider:
(1) the degree of FPL and industry experience with the software. (2) tha level of testing and benchmarking that the application has and will received. (3) the extent to which the software is being
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OF 14 modified or has been modified. Compensatory measures may include additional benchmarking and testing.
The purchase order shall require the vendor for purchased software to provide User Documentation as required based on the complexity of the software.
5)
Disposition of software error notices shall include a review for potential 10CFR21 applicability / evaluation (see IP 801/803 and ENG OI 2.2).
S082 1)
Requirements 1 through 3 for SOA1 software shall also be required for SOA2 software. However, the documentation of these requirements is not required to be as rigorous as for SOA1 software.
SOA2 software is not considered critical software as described in IEEE Std 1012 and has fewer mandatory aspects to the V&V.
2)
Software error notification, if received, should be reviewed for pc+ential applicability and appropriate action.
However, because the output from SOA2 software used in safety or quality related applications is inde)endently verified, any errors that may be discovered would not 3e capable of resulting in substantial safety hazard.
Therefore part 21 applicability has been generically screened out for SOA2 software.
3)
SOA2 software shall be procured as PC-3 as a minimum. Vendor error notification is not required. but will be reviewed if provided.
SQA3 1)
Requirements 1 through 3 for SOA1 software shall also be required for SOA3 software. However, the documentation of these requirements is not required to be as rigorous as for SOA1 software.
SOA3 software is not considered critical software as described in IEEE Std 1012 and has fewer mandatory aspects to the V&V.
2)
Software error notification, if received, should be reviewed for potential applicability and appropriate action.
However. because the data from SOA3 software is controlled under the QA program and the software does not modify the data. any software errors would not be capable of resulting in substantial safety hazard.
Therefore, part 21 applicability has been generically screened out for SOA3 software 3)
SOA3 software shall be procured as PC-3 as a minimum. Vendor error
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OF 14 notification is not required, but will be reviewed if provided.
10M 1)
The acceptability of 50A4 software is based on unisersal commercial acceptance and extensive use by a large and diverse population.
There are no additional requirements on this software, so long as its use is within the normal intended bounds for the application.
i 2)
SOA4 software is commercially available and should be procured PC-4.
Note: Although software categorized as SOA4 does not require any additional controls under this instruction, the specific usage may fall under another aspect of the FPL OA program.
(a)
For example, spreadsheet applications used in design are subject to the design input and verification requirements of 01 1.7.
(b)
Other applications created using SOA4 software shall be controlled as SOA1, SOA2 or SOA3 software as appropriate.
5.5 Process Software Reauirements Process software shall meet the applicable general requirements of this instruction, as well as the following specific requirements.
I 1)
The implementation of process software shall be considered a PC/M in accordance with the requirements of ENG OI 1.0.
The requirements of this instruction are j.n addition to the requirements of the applicable PC/M process (EP or MEP).
Additional required documentation shall be attached to, or referenced in, the PC/M.
2)
A Software Requirements Specification (SRS) shall be prepared which identifies and describes the function, performance, constraints, attributes, external interfaces, and user manual requirements of the computer software.
SRS requirements should be capable of being objectively verified. The SRS shall be reviewed to ensure adequacy and feasibility, and approved.
The procurement documents.if applicable, may constitute the majority of the SRS if they meet the criteria.
3)
A Software Design Description (SDD) shall be prepared which identifies and describes the functions, components, and subcomponents of the software
design, speci fic hardware requirements, interfaces. data sources, and how the SRS requirements will be implemented.
The SDD shall include Detail Logic Diagrams (DLD) or other documentation as appropriate to the proposed software.
The 500 shall also include the information necessary to represent the translation of the design requirements to the actual
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OF 14 process code, including ladder ' diagrams, ladder diagrams cross reference, and a detail design description.
The SDD shall be reviewed for adequacy and feasibility (ty3ically part of PC/M review process). The computer software being cevelo]ed shall receive at least one design review covering the complete cesign as described in the SDD. The SDD shall be reviewed to ensure that it implements the SRS and approved. The majority of the SDD may be from pre-existing vendor controlled documentation / spec sheet if it meets the criteria.
4)
V&V shall be performed in accordance with Section 5.6.
5)
User manuals (vendor manuals) shall be obtained or developed as required based on the complexity of the software.
6)
Process software errors or defects shall be screened for potential 10CFR21 applicability / evaluation (see ENG OI 2.2).
7)
Installation of new or revised process software must consider plant operation in all modes, as well as intermediate plant configurations 1
during software installation.
8)
Modifications to process software shall be accomplished using the applicable PC/M process.
The 10CFR50.59 considerations shall be addressed as part of the PC/M. All affected documentation required by Section 6.0 shall be revised as required to reflect the software revision. See Section 5.6 for verification / validation requirements for revised software.
9)
Process software changes that affect control room indication shall be duplicated in the control room simulator software.
5.6 Software Verification & Validation Plan and Reoort (SVVP and SVVR)
V&V of newly developed / revised computer software shall be completed prior to use.
V&V is a multi-faceted process that may include product in-process reviews, product evaluation and testing. process and product audits, process and algorithm analysif, anomaly detection and resolution, as well as other associated activities.
V&V is modeled to f6115w the guidance of IEEE Std 1012. " Software Verification and Validation Plans" V&V planning must take into consideration such project characteristics as software criticality (including the software classification), safety and reliability requirements, schedule, resources customer expectations, etc.
Note that critical software as referred to in the standard applies to safety related process and SOA1 software only.
1)
V&V results shall be reviewed by an independent individual other M
than the developer of the software.
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V&V shall include h review of the SRS. and SDD and preparation of a Software Validation and Verification Plan (SVVP). and test procedure (STP), and Software Validation and Verification Report (SVVR): or equivalents: to ensure that all requirements and referenced standards have been satisfied.
3)
The Software Validation and Verification Plan (SVVP) shall describe the methods / tests which will be used to verify the computer software. the method / frequency of periodic follow-up validation, test documentation required, and acceptance criteria (input data vs expected results).
The SVVP shall specify any validation (benchmarking) to be performed on a periodic basis. (Note: Process software is controlled via the plant's maintenance program and appropriate validation is performed to ensure accurate operation of safety related functions.) Validation ensures that the software, operating system, and hardware are collectively working correctly and producing valid results. The frequency of periodic validation (benchmarking) should be determined from the frequency of use of the software, since the purpose of the validation is to ensure accurate operation on a continuing basis.
For example, if a particular program is used once every 6 months, validation could be performed prior to each use.
However, if a program is used 3 times a day, validation prior to each use is clearly not warranted, and a weekly or monthly schedule may be more appropriate.
The determined frequency of validation (based on the above and/or vendor recommendations) shall be specified on Form 136 (or equivalent) and shall be maintained in the CSI for non-process software.
In addition to oeriodic validation, specific validation shall be performed following any significant change in hardware (including configuration of CPU). operating system, or program.
4)
Testing shall be conducted per a Software Test Procedure (STP) or equivalent in a controlled manner such that there is minimal risk of losing data, damaging files, etc. The test scenario and environment shall be functionally equivalent to the working environment to ensure a representative test. The STP shall include a description of the test (s) to be conducted, test methods to be used, documentation to be generated, range of input parameters and their expected output. criteria for acceptance and identification of support software / hardware to be used. The STP shall be included in the SVVP. Testing shall ensure that the software, operating system, and hardware are collectively working correctly and producing valid results.
The results of the testing and associated documentation shall be placed in a SVVR or other QA record documentation.
Testing shall ensure adherence to requirements and ensure that the software produces correct results for the test cases.
To evaluate technical adequacy the test case shall be compared to results from alternative methods such as:
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FPL COMPlJTER SOFTWARE C()NTROL PAGE 10 OF 14 hand calculations functionally equivalent and previously validated software experiment and test results standard problems with known solutions confirmed published data and correlations 5)
The Software Validation and Verification Report (SVVR) shall be preparect to summarize and document validation and verification results.
6)
Separate SVVP and SVVR documents are not required if the requirements are enveloped by a single document.
5.7 10CFR50.59 Reauirements New non-process software or changes to non-process software (purchased or I developed) which fall within the scope of this procedure shall be reviewed i
for 10CFR50.59 applicability. This shall be accomplished by screening the software using the following screening questions.
The determination of this screening shall be specified on Form 136 (or equivalent) and shall be maintained in the CSI. Guidance on 10CFR50.69 Generic Exclusion shall be -
provided in lower tier NIS working Procedures.
Does the new addition of/ change in software represent a change to the facility as described in the SAR?
Does the new addition of/ change in software represent a change to procedures described in the SAR?
i Is the new addition of/ change in software associated with a test or experiment not described in the SAR?
Could the new addition of/ change in software affect nuclear safety in a way not previously evaluated in the SAR?
Does the new addition of/ change in software require a change to the Technical Specifications?
If the answer to any of the above screening questions is "YES". then a 10CFR50.59 evaluation shall be prepared to support the new software addition or software change. If required. the 10CFR50.59 evaluation shall be performed in accordance with ENG OIs 2.0 and 2.1.
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1 NUCLEAR ENGINEERING DATE 7/5/95 (effective) i CO@tTIER SOFTWARE CONTROL PAGE 11 OF 14 5.8 Pre Existina Software Reauirements Pre-existing non-process computer software is defined as software which was placed into a production environment prior to, and not modified since the implementation of FPL's software 0A program (before 1990).
Pre-existing computer software (purchased developed, or otherwise obtained) which falls under the scope of this procedure shall be evaluated in order to justify continued use. Although the specific requirements for an SRS.
SDO, SVVP, and Si/VR need not be retrofitted to pre-existing software, periodic vali6 tic.n testing and verification testing for revisions to the software must be performed and controlled in accordance with this procedure.
See Section 5.6.
Form 136 (or equivalent) shall be prepared for all pre-existing computer software within the scope of this procedure, and submitted to NIS for inclusion in the CSI.
Revisions to pre-existing process software shall be purchased such that V&V is performed to the level of the original equipment, as a minimum.
5.9 Software Confiauration Reauirements Process software configuration is controlled via the PC/M process.
Non-process software configuration control shall be maintained via the CSI in accordance with Section 5.10.
Newly developed, purchased, or revised software shall be identified to NIS via Form 136 (or equivalent).
Additional guidance on software configuration control is provided in lower tier NIS working procedures.
Revisions to software may be required for the following reasons:
discrepancies noted during validation discovery of software errors modifications or revision.s in software requirements The following steps are to be followed in performing software revisions:
1)
All software revision / modification to be performed by NIS shall be initiated by an RFS.
Details and guidance on the RFS process are
]
provided in lower tier NIS working procedures, j
2)
Revisions to computer software shall be verified and processed in accordance with the requirements of this instruction pertaining to newly purchased / developed software (See Sections 5.4 and 5.5).
I 3)
All affected documentation required by Section 6.0 shall be revised as required to reflect the software revision.
All superseded documentation shall be retained and traceable to the specific software revision / version.
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Emergency maintenance of software (limited to loss of functionality or system availability) shall be initiated with NIS personnel, with follow-up documentation requirements defined in lower tier NIS working procedures.
Verbal initiation shall be acceptable for emergency maintenance.
5)
Changes to data required by mathematical modeling applications to perform correctly shall be controlled via an approved Nuclear Quality Assurance Program (Vendor or FPL).
Validation of changes shall be performed in accordance with an SVVP or equivalent (see Section 5.6).
Validations of this nature may be performed as part of the SVVP for the respective software application.
5.10 Comouter Software Index (CSI)
NIS shall maintain and distribute the CSI. which is a compilation of inputs from Forms 135. 136, and all SVVRs.
Non-process software which falls under this instruction shall be listed in the CSI.
Additional guidance on the CSI is provided in lower tier NIS working procedures.
Information contained in the CSI includes:
Software Name Version / Revision Revision Status OAP Applicable Non-process Software Category (SOA1/2/3/4) 1 Program Language Host System Operating System Description Manual Revision Software Developer Custodian User Contact Validation Frequency Validation Date 6.0 RECORDS The following documents (as applicable) shall be submitted to Juno Document Control and retained as OA records in accordance with 01 3.0:
Form 135 Form 136 Software Procurement Documentation Software Requirements Specification (SRS) and review (s)
Software Design Description (SDD) and review (s)
Software Validation and Verification Plan (SVVP)
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I:PL COMPlfTER SOFTWARE CONTROL PAGE 13 OF 14 Software Validation and Verification Report (SVVR)
Testing Procedure / Software Test Plan (STP)
User Manuals 10CFR50.59 Applicability Review 10CFR21 (SSH) Applicability Review Production Release Forms I
Revision Docunentation Software Problem / Error Documentation (Form 138)
Request for Service (RFS)
Training Documentation The documents referred to above should be assembled / stored as an overall package (i.e.,
all documents pertaining to a specific software version should be traceable and preferably filed together).
Note that for process software, documentation required above may be submitted to Site Document Control as an attachment to the PC/M. A copy of Forms 135. 135, 138, and all SVVRs shall also be submitted to NIS.
Archived magnetic media shall be maintained in designated storage facilities to protect against inadvertent damage.
System software shall be used to manage archived magnetic media on the Mainframe.
Master PC software / controlled data diskettes shall be retained in a controlled manner (traceable to the CSI) by NIS.
7.0 REFERENCES
. DEFINITIONS. AND ABBREVIATIONS 7.1 References 1)
NUREG/CR-4640. Handbook of Software Quality Assurance Techniques Applicable to the Nuclear Industry 2)
ANSI /ASME NOA-2a-90. Part 2.7. Quality Assurance Requirements of Computer Software for Nuclear Facility Applications 7.2 Definitions See Glossary l
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FPL COPUTER SOFTWARE C(WTROL PAGE 14 OF 14 7.3 Abbreviations CP0 - Computer Operations CSI - Computer Software Index LAN - Local Area Network NIS - Nuclear Information Services PC/M - Plant Change / Modification PDM - Production Data Modification OAP - Quality Assurance Program RFS - Request for Service SRR - Software Requirements Review SRS - Software Requirements Specification SDD - Software Design Description 4
SDR - Software Design Review STP - Software Test Plan SVVP - Software Validation and Verification Plan SVVR - Software Validation and Verification Report i
l
'_ l APPARENT VIOLATIONS PREDECISIONAL VIOLATION A 10 CFR 73.55(7) requires that licensee's shall establish an access authorization system to limit unescorted access to vital areas during non-emergency conditions to individuals who require access in order to perform their duties.
I The licensee's Physical Security Plan (PSP) Revision 48 dated 2/23/96 states. "Only those individuals with identified need for access and having appropriate authorization shall be granted unescorted Vital Area access."
From July 28. 1996 to September 19, 1996 an individual whose employment terminated on July 28, 1996. had unescorted access to protected and vital areas without appropriate authorization.
In addition, on A.ugust 7: August 9:
and August 15. 1996, that individual entered the protected area and had access to vital areas.
Also, five other individuals had unescorted access to the protected and vital areas after they were terminated from the period of July 27 to September 19.
1996, without appropriate authorization.
However, those individuals did not access the protected or vital areas.
NOTE: The apparent violations discussed in this enforcement conference are subject to further review and are subject to change prior to any resulting enforcement decision.
9
APPARENT VIOLATIC.NS PREDECISIONAL VIOLATION B 10 CFR 73. Appendix G. states that an actual entry of an unauthorized person into a protected area or vital area be reported within one hour of discovery.
10 CFR 73. Appendix G. states that any failure, degradation, or discovered vulnerability in a safeguards system that could have allowed unauthorized or undetected access to a protected area or a vital area had compensatory measures not been established, be recorded within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of discovery in the safeguards event log.
On October 9. 1996, the licensee discovered that an individual had been terminated on July 28, 1996, and had entered the protected area on five different occasions. yet failed to make a report within the one hour timeframe.
In addition, on September 19. 1996, the licensee discovered three individuals who had previously been terminated on July 27. July 28. and August 24.19% that had access to the protected area and failed to report that discovery in the safeguards event log.
NOTE: The apparent violation discussed in this enforcement conference are subject to further review and are subject to change prior to any resulting enforcement decision.
I
APPARENT VIOLATION B PREDECISIONAL As of August 19. 1996. Technical Specification (TS) 6.8.1.e required that l
written procedures be established.1mplemented. and maintained covering Emergency Plan implementation.
(The subject TS was deleted with NRC approval effective August 20, 1996. but these examples of inadequate EPIPs existed in the same form prior to August 20. 1996 as when identified during the inspection.)
Procedures covering Emergency Plan implementation were not adequately established. implemented and maintained with respect to the following aspects of the Emergency Plan:
a.
recovery activities, as discussed conceptually in REP Section 5.4 b.
description and delineation of the licensee's emergency response organization (ERO) and the detailed means for notifying ERO members in an emergency, as discussed generally in REP Section 2.2 c.
relocation of the OSC if reauired by radiological or other adverse conditions during an emergency. as referenced in REP Section 2.4.4 NOTE: The apparent violations discussed in this enforcement conference are subject to further review and are subject to change prior to any resulting enforcement decision.
A
+
b l
l APPARENT VIOLATION C PREDECISIONAL
-10 CFR.50.54(q) requires that nuclear power plant licensees follow and maintain in effect emergency plans which meet the planning standards of 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50.
"The primary cbactives REP Section 7.2.1. " Objectives", stated the following:liarize appropriate of emergency response training are as follows: 1. Fami individuals with Emergency Plan and related implementing procedures.
2.-
Instruct individuals in their specific duties to ensure effective and expeditious action during an emergency.
3. Periodically present significant changes In the scope or content of the Emergency Plan.
4. Provide refresher training to ensure that personnel are familiar with their duties and responsibilities." REP Section 7.2.2. " Training of On-Site Emcrgency_ Response 1
Organization [ERO) Personnel". states. "The training prograia for members of the on-site emergency response organization will include practical drills as 4
. appropriate and participation in exercises, in wMch each individual demonstrates an ability to perform assigned emergency functions... For
. employees with specific assignments or authorities as membert of emeroency Agam. initial training and annual retraining 3rograms will be provided.
Training must be current to be maintained on t1e site Emergency Team Roster."
REP Section 7.3.2 states. "The Plant Training Manager will ensure that on-site Emergency Response Organization _ personnel are informed of relevant changes in the Emergency Plan and Emergency Plan Implementing Procedures [EPIPs]."
a.
In 1994, the licensee failed to provide initial training or annual retraining for 17 positions (approximately 92 individuals) identified as part of the on-site response organization.
In 1995, the licre finled to provide initial training or annual retraining for 8 positions (approxistely 54 individuals) identified as part of the on-site j
response organization.
b.
The licensee's training program failed to include initial training or annual retraining on all procedures required to be implemented by ERO personnel in several identified positions.
Examples:
EPIP 3100027E.
"Re-entry" - Emergency Coordinator. Radiation Team Leader. OSC Supervisor. Re-entry Team Supervisor. Re-entry Team Member. OSC Status Board Keeper, and OSC Dose Recorder.
EPIP 3100026E. " Criteria for and Conduct of Evacuation" - Emergency Coordinator. Assembly Area Supervisor, and TSC Security Supervisor.
EPIP 3100035E. "Off-site Radiation Monitoring" - Radiation Team Leader and ISC Supervisor.
The Plant Training Manager failed to ensure that ERO personnel in several identified positions were informed of relevant changes in procedures.
Example:
EPIP 3100026E. '" Criteria for and Conduct of Evacuations".
. c.
For the calendar year 1995, the licensee failed to remove from the I
emergency response organization two individuals who had not completed t
retraining as required, and whose qualifications had expired in 1994.
The licensee also failed to remove six individuals from the emergency team roster effective October 6.1996, who had not remained qualified to fill response team requir ments as a result of allowing their respirator cualifications to lapse.
.l APPARENT VIOLATIONS PREDECISIONAL VIOLATION A 10 CFR 50. Appendix B. Criterion III. Design Control, requires. in part. that measures be established to ensure that the design basis is correctly transhted into drawings and that design control measures provide for verifying the adequacy of the design by individuals other than those who perfomed the original design.
FPL Topical Quality Assurance Report. TOR 3.0. Revision 11. " Design Control."
Section 3.2.4. " Design Verification." stated in part. " Design control measures shall be established to independently verify design input... Design verification shall be performed by technically qualified individuals or groups other than those who performed the design.~
Ergineering Quality Instructions (01) 1.7. Design Input / Verification. dated July 5,1995, states, in part. that " Design veriffcation is the process whereby a competent individual, who has remained independent of the design process. reviews the design inputs... and aesign output to verify design adequacy. This independent review is provided to minimize the likelihood of design errors in items that are important tr :uclear safety "
1)
On July 30. 1996, it was discovered that a design change (PC/M 009-195) to install new nuclear instrumentation system drawers did not receive an independent design verification by a competent individual independent of the design process.
Design change PC/M 009-195 was completed by a lead designer and a lead engineer.
This design change was independently verified by a second designer who had no special knowledge of the oesign.
The design was then approved by the lead engineer whom was not independent of the design process.
2)
On July 30. 1996, it was discovered that an independent design review Jb was not conuucted for the installation of a new core flux monitoringDu computer code BEACON.
that the code did not compensate for a core mid-plane offset created by a previous core modii'ication.
The engineer who prepared the design wasj not aware of the core mid-plane offset and the lack of an independent /
review of the new BEACON code did not provide the opportunity to
/t laentify this omission.
NOTE: The apparent violations discussed in this enforcement conference are subject to further review and are subject to change prior to any result Pg enforcement decision.
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i 1
-APPARENT DEVIATION PREDECISIONAL Amendment Nos.147 and 86 to the operating licenses for Unit;s 1 and 2.'
j respectively, were approved by the NRC on August 20. 1996, and consisted of-changes to the TS in response to the licensee's application dated-August 16.
i 1995.x Among numerous changes in these amerr:Mients were.the deletion,(for both j
Units 1 and 2) of the previous TS 6.8.1.d'ond TS 6.0.1.e. which formerly i
i specified that " Written procedures shall be established, implemented and maintained". to cover " Security Plan implementation" and " Emergency Plan innlementation". respectively.
In Attachment 2. " Safety Analysis". to the August 15. 1995 application. the licensee stated (in the introduction to the
)
section addressing modifications to TS 6.5.1.6.1. 6.5.1.6.j. 6.8.1.d. and -
6.8.1.e) that the " selected Technical Specifications are being relocated to
.the Emergency Plan or Security Plan as appropriate.
Relocating these requirements to the appropriate plan will ensure the control of future changes are under the requirements of 10 CFR 50.54.10 CFR 73.55 and 10 CFR 73.56."
The NRC's referenced approval of the subject application stated that the
" licensee proposes to relocate these review requirements and their implementing procedures to the St. Lucie Security and Emergency Plans..."
The licensee failed to relocate the requirements formerly found in TS 6.8.1.d and 6.8.1.e to the Security Plan or Emergency Plan as applicable. in accordance with the commitment to the NRC contained in the licensee's application dated August 16. 1995.
r i
1-I NGTE: The apparent' violations discussed in this enforcement conference are subject to further review and are subject to change prior to any l-
.resulting enforcement decision.
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VIOLATION B PREDECISIONAL Technical Specification 6.8. Procedures and Programs. paragraph 6.8.1 requires. in part. that written procedures recomended in Appendix A of Regulatory Guide 1.33 revision 2. February 1978 'shall be established and implemented.
Engineering Quality Instruction (01) 3.7. Computer Software Control. Revision
1. Section 5.4. requires that SOA1 software shall be validated and verified (V&V'ed) in accordance with Section 5.6 of OI 3.7.
Section 5.6 states Jt at-Ai new software shall. be V8V'ed prior to use. The V&V process includes-TfW use of of test cases to ensure the new software produces correct results.
Item 4 of '
I i
Section 5.6 states that technical adequacy shall'be determined by comparing guilf.
the test case to results from alternative methods such as functionally equivalent and previously validated software.
During the Unit 1 Cycle 14 outage. BEACON core monitoring system was placed into service on Unit 1 without any benchmarking against IMPAX. the on-line core performance monitoring code BEACON was replacing.
Instead. BEACON was
. installed on Unit 2 and benchmarked against CECORE. the core monitoring system installed nn Unit 2. which did not require any modifications to accomodate the core midplane offset.
NOTE: The apparent violations discussed in this enforcement conference are subject to further review and are subject to change prior to any resulting enforcement decision.
4 VIOLATION C PREDECISIONAL Technical Specification 6.8. Procedures and Programs. paragraph 6.8.1.
requires in part that written procedures recommended in Appendix A of Regulatory Guide 1.33 revision 2. February 1978. shall be established and implemented.
Administrative Procedure No. 0006130. Condition Reports. Revision 4. dated March 22, 1996. Par. 8.1.1.A states in part that "Any individual who becomes aware of a problem or discrepant condition... should initiate a CR.
If doubt exists a CR form should be initiated" On July 30. 1996. Instrument and Control technicians installing Modification.
PC/M 009-195 did not initiate a Condition Report when they became aware of a discrepant condition when markings for electrical terminal connectors differed from existing cable markings. The failure to resolve the discrepant condition resulted in incorrectly installing two excore nuclear instrumentation system detectors.
d NOTE: The apparent violations discussed in this enforcement conference are subject to further review and are subject to change prior to any resulting enforcement decision.
1 1
l
i 1
ENCLOSURE 4 EICS ENFORCEMENT WORKSHEET EICS MEETING NOTES AND DOCUMENTATION OF UNDERSTANDING (To be Completed by EICS per ROI 0912)
O EA NUMBER:
ATTENDEES
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i PREPARED BY:
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DATE: OlIb9bTIME: [/ lLTD
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.EICS STAFF NOTES:
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2 ENFORCEMENT ACTION WORKSHEET EICS HEETING NOTES AND DOCUMENTATION OF UNDERSTANDING (To be Completed by EICS per ROI 0912)
II.
Civil Penalty Assessment A.
First non willful SL_lII violation in 2 years /2 insoections? YES or NO Previous escalated cases:
B.
Identification Credit? YES NO N/A NRC identified?
Licensee identified?
, Revealed through an event?*
Prior opportunities?
i C.
Corrective action credit? YES NO N/A Immediate corrective actions:
Long term corrective actions to prevent recurrence:
D.
Discretion aoolied? Yes or No:
Reason why.
E.
Civil Penalty:
F.
Recommendation for credecisional enforcement conference:
1 J
1 3
ENFORCEMENT ACTION WORKSHEET EICS MEETING NOTES AND DOCUMENTATION OF UNDERSTANDING (To be Completed by EICS per ROI 0912) i NOTE:
Complete the following information for each violation ISSUE:
III. Documentation of Enforcement Panel / Caucus Consensus A.
Preliminary Severity Level (Prior to Application of any Discretion.
From Part !)
8.
Increase Severity Level based on Aggregation?
C.
Increase Severity Level for Repeat Violations?
(Address requirements of ROI 0903) i D.
Increase Severity Level for Willfulness?
E.
SEVERITY LEVEL SUPPLEMENT /SECTION F.
Recommended Civil Penalty G.
Predecisional Enforcement Conference Necessary?
H.
Revision to Draft NOV Required?
I.
Formal Review by OE Required?
J.
Special Action Items / Message to Licensee / Comments n
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P:\\ENFPANEL.FRM
7 ENFORCEMENT ACTION WORKSHEET PREl.08RICATION OF VALVES PRIOR TO ASNE SECTION XI TESTING PREPARED BY:Joel T. Munday DATE: July 11.1996 NOTE: The section Chief of the responsible Otvisten is responsible for preparation of this EAW and its distributton to attendees prior to an Enforcement Panel. The Section Chtef shall also be responsible for providing the meeting location and telephone bridge number to attendees via e-mail (ENF.GRP, CFE, OEMAIL, JXL, JRE, SHL. LFD; appropriate R!l ORP, DR$; appropriate NRR, NMSS). A Notice of Violation (without "botlerplate") whten includes the recomended severtty level for the violation is reaut ree. Copies of acplicable Technical Spect f tcations or license conditions cited in the Notice or other reference material needed to evaluate the proposed enforcement action are required to be enclosea, e
This Notice has been reviewed by the Branch Chief or Division Director and each violation includes the appropriate level of specificity as to how and when the requirement was violated.
Signature Facility: St. Lucie Unit (s): 1, 2 Docket Nos: 50-335, 50-389 License Nos: DPR-67, NPF-16 Inspection Report No: 50-335,389/96-11 Inspection Dates: July 7 - August 3, 1996 Lead Inspector: Nark Miller 1.
Brief Summary of Inspection Findings:
An NRC inspector identified, through document review, that the Unit 1 containment spray flow control valve,1-FCV-07-1A, was being precanditioned prior to being tested.
Specifically, prior to the performance of the surveillance which verifies proper stroke-time of the valve, lubrication was applied to the valve stem.
Further inspection identified that three other containment spray valves were also prelubricated prior to being stroke-time tested.
The licensee had noted in a QA assessment that this practice was occurring, however, it was not highlighted as significant nor was a STi.R written to document its occurrence.
The QA assessment indicated that there did not appear to be h correlatien between frequency of lubrication and test performance.
However, when informed by the inspector that this practice could result in not obtaining truo as-found data and would not provide reliable trend information, the licensee agreed and revised the appropriate procedures to delete the practice.
Violation 335/95-15-05 was issued documenting the fact that a STAR was not initiated as required by plant procedures.
Corrective actions for this violation included documenting the event in STAR 951048 as well as revising use applicable procedures to remove the practice of
\\
PROPOSED ENFORCEMENT ACTION - NOT FOR PUBLIC DISCLOSURE k
WITHOUT THE APPROVAL OF THE DIRECTOR, OE
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~
_ prelubricating other valves prior to surveillance testing.
In additien,.
STAR 951063 was' written to review other test and surveillance procedures t
to: determine if similar conditions existed elsewhere. One additional valve was identified that might be impacted by this practice and that i
i:
- problem was also corrected. The licensee _ stated, in response to STAR 951063,:that the PMs which lubricated the valves' vere performed along-with the stroke-time surveillance because the surveillance was required as a PMT-following the PM.
By scheduling the PM to be performed prior
- to the surveillance the number of surveillances performed would be reduced.
10 CFR 50, Appendix B, Criterion XI, requires, in part, that' testing required-to demonstrate that systems and components will perform Aatisfactorily in service shall'be performed under suitable.
environmental conditions.
Prelubrication of valves prior to performing f
stroke-time tests violates this requirement.and negates the vailidity of the test in assessing the operational readiness of the valve.
Proposed NOV 10 CFR 50,' Appendix B, Criterion XI, requires,'in part, that~a test program shall be established.to assure that all testing required to demonstrate that systems and components will perform satisfactorily in service is identified and performed in accordance with written test procedures.
Test procedures shall include provisions for assuring that the test is performed under suitable environmental conditions.
Contrary to the above,. Administrative Procedures, AP-1-0010125A, revision 39 for Unit I and AP-2-0010125A, revision 43 for Unit 2, did not ensure that the procedures were performed under suitable environmental conditions.
Specifically, the two aformentioned procedures directed that valves 1-FCV-07-1A,1-FCV-07-18, 2-FCV-07-1A, and 2-FCV-07-1B be lubricated prior to being tested. This i
practice negated the ability to assess the operational' readiness of the valves.
This is a Severity Level IV violation (Supplement I).
l PROPOSED ENFORCEMENT ACTION - NOT FOR PUBUC DISCLOSURE WITHOUT.THE APPROVAL OF THE DIRECTOR, OE 1
t 4
-2.
Analysis cf Root Cause J
It appears that the surveillance procedures were revised in September,1994 to include lubricating the valve:: prior to performance.
The licensee's response to STAR 951063 indicated that this was done as a means of reducing the number of surveillances required to be performed.
The licensee did not consider the effect this practice would have on the validity of the as-found data.
This decision appears to have been a result of poor engineering judgement.
3.
Basis for Severity Level (Safety Significance):
Severity Level IV: Supplement I.D.3 which states, "A failure to meet regulatory requirements that have more than minor safety or environmental significance."
4.
Identify Previous Escalated Action Within 2 Years or 2 Inspections?
EA 96-040, 1/22/96, level III Base CP: Overdilution Event EA 95-180, 8/4/95, Level III Base CP: Inoperable PORVs l
l 5.
Identification Credit? (EnterYesorNo):
No I
f Consider following and discuss if applicable below:
O Licensee-identified 0 Revealed through event O NRC-identified D Mixed identification D Missed opportunities Enter date Licensee was aware of issues requiring corrective action:
September, 1996 when questioned by NRC inspector.
Explain application of identified credit, who and how identified and consideration of missed opportunities:
1 Although identified in a licensee QA assessment report, the licensee did not realize the significance until identified by NRC.
I l
6.
Corrective Action Credit?
[EnterYesorho): Yes Brief summary of corrective actions:
Upon identification that this practice was unacceptable, the applicable procedures were revised to delete the practice.
Other plant systems and procedures were reviewed to determine extent of condition with only one additional case being identified.
This example was also corrected.
PROPOSED ENFORCEMENT ACTION - NOT FOR PUBUC DISCLOSURE WITHOUT THE APPROVAL OF THE DIRECTOR, OE
Explain application of corrcctive action credit:
f Corrective actions were completed quickly and included a generic review of other systems, both by the engineering staff and QA.
7.
Candidate For Discretion? [See attached list]
[EnterYesorho): No.
Explain basis for discretion consideration:
8.
Is A Predecisional Enforcement Conference Necessary?
(EnterYesorNo): No.
Why: There is no additional information needed by the NRC and the licensee has corrected the condition.
If yes, should OE or OGC attend?
[ Enter Yes or No]:
Should conference be closed? [ Enter Yes or No]:
9.
Non-Routine Issues / Additional Information:
10.
This Action is Consistent With the Following Action (or Enforcement Guidance) Previously Issued:
[E!CS to provide) (:f inconsistent. include:]
Basis for Inconsistency With Previously Issued Actions (Guidance) 11.
Regulatory Message:
The licensee needs to consider all impacts that a procedure change could l
have on a system prior to making the change.
Additionally, stress the l
importance of as found trending of equipment performance.
l t
PROPOSED ENFORCEMENT ACTION - NOT FOR PUBLIC DISCLOSURE WITHOUT THE APPROVAL OF THE DIRECTOR, OE
t 12.
Recommended Enforcement Action:
Level IV violation.
13.
This Case Meets the Criteria for a Delegated Case. [E!cs - Enter Yes or No) 14.
Should This Action Be Sent to OE For Full Review? [EICS - Enter Yes or No]
If yes why:
1 15.
Regional Counsel Review (Etc5toobtain]
No Legal Objection Dated:
16.
Exempt from Timeliness: (EICS)
Basis for Exemption:
^
Enforcement Coordinator:
J DATE:
\\
PROPOSED ENFORCEMENT ACTION - NOT FOR PUBLIC DISCLOSURE WITHOUT THE APPROVAL OF THE DIRECTOR, OE
ENFORCENENT ACTION WORKSHEET - ISSUES TO CONSIDER FOR DISCRETION 0
Problems categorized at Severity Level I.or II.
0 Case involves overexposure or release of radiological material in excess of NRC renyirements.
O Case involves particularly poor licensee performance.
O Case (may) involve willfulness.
Information should be included to address whether or not the region has had discussions with OI regarding the case, whether or not the matter has been formally referred to 01, and whether or not OI intends to initiate an investigation. A description, as applicable, of the facts and circumstances that address the aspects of negligence, careless disregard, willfulness, and/or management involvement should also be included.
O Current violation is directly repetitive of an earlier violation.
O Excessive duration of a problem resulted in a substantial increase in risk.
O Licensee made a conscious decision to be in noncompliance in order to obtain an economic benefit.
O Cases involves the loss of a source.
(Note whether the licensee self-identified and reported the loss to the NRC.)
O Licensee's sustained performance has been particularly good.
O Discretion should be exercised by escalating or mitigating to ensure that the proposed civil penalty reflects the NRC's corcern regarding the violation at issue and that it conveys the appropriata message to the licensee.
Explain.
l I
- PROPOSED ENFORCEMENT ACTION - NOT FOR PUBUC DISCLOSURE WITHOUT THE APPROVAL OF THE DIRECTOR, OE
's
~
REFERENCE DOCUMENT CHECKLIST
[X]
NRC Inspection Report or other documentation of the case:
NRC Inspection Report Nos.: 50-335,389/96-11
[X ] Licensee reports: STAR 951048, STAR 951063
[]
Applicable Tech Specs along with bases:
[]
Applicable' license conditions
[X]
Applicable licensee procedures or extracts AP-1-0010125A; AP-2-001012A
[]
Copy of discrepant licensee documentation referred to in citations such as NCR, inspection record, or test results
[]
Extracts of pertinent FSAR or Updated FSAR sections for citations involving 10 CFR 50.59 or systems operability
[]
Referenced ORDERS or Confirmation of Action Letters
[]
Current SALP report summary and applicable report sections
[X]
Other miscellaneous documents (List):
TIA 96-007 - Acceptability of Lubricating Valves Prior to Surveillance Testing PROPOSED ENFORCEMENT ACTLON - NOT FOR PUBUC DISCLOSURE WITHOUT THE APPROVAL OF THE DIRECTOR, OE
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ENCLOSURE 4 y{
EICS ENFORCEMENT WORKSH ET W>
EICS MEETING NOTES AND DOCUMENTATION OF UNDERSTANDING (To be Completed by EICS per ROI 0912) cA NUMBER:
[M-lb ATTENDEES FACILITY: JIawI-g2bdk h,du/Z
SUBJECT:
TTM MMO a PANEL a PEC-a CAUCUS
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a OTHER a OI BRIEF PREPARED BY: b!hd DATE 7 TIME: //n3 I.
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ENFORCEMENT ACTION WORKSHEET EICS HEETING NOTES AND DOCUMENTATION OF UNDERSTANDING (To be Completed by EICs per ROI 0912)
II.
Civil Penalty Assessment A.
First non willful SL III violation in 2 years /2 insoections? YES or NO Previous escalated cases:
B.
Identification Credit? YES NO N/A NRC identified?
Licensee identified?
Revealed through an event?*
d;
\\
Prior opportunities?
C.
Corrective.;ction credit? YE NO N/A Immediate corrective actio Long term corrective etions to prevent recurrence:
D.
Discretion acol ed? Yes or No: Reason why.
E.
Civil Pen tv:
F.
Reco ndation for oredecisional enforcement conference:
l 3
ENFORCEMENT ACTION WORKSHEET EICS MEETING NOTES AND DOCUMENTATION OF UNDERSTANDING (To be Completed by EICS per ROI 0912)
NOTE:
Complete the following information for each violation ISSUE':
III.
Documentation of Enforcement Panel / Caucus Consensus A.
Preliminary Severity Lev to Application of any Discretion.
From Part I) 64 /
V B.
Incre to Severity Level based on Aggregation? ##
C.
Increase Severity Level for Repeat Violations?ge (Address requirements of ROI 0903)
D.
Increase Severity Level for Willfulness?
84 E.
SEVERITY LEVEL 84 /
SUPPLEMENT /SECTION I
F.
Recommended Civil Penalty h
G.
Predecisional Enforcement Conference Necessary?
NM H.
Revision to Draft NOV Required?
4 - M II /
I.
Formal Review by OE Required?
Me J.
$pecial Action Items / Message to I.icensee / Comments AV/dA%m4-do41s JMO NLo Adm w m
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ENFORCEMENT ACTION WORKSHEET Failure to Maintain Overtime Within' Guidelines PREPARED BY: Mark S. Miller DATE: 7/3/96 IIOTE: The section Chief of the reopenelbte Divlelen le rescenalbte for preparation of this EAW end its distributten to attendees prior to en Enforcement Penet. The Section chief shall else be reopenelble for providing the meeting tecetten and telephone bridge nusher to attendose vie e sell (ElIF.GRP, CFE, CEft4IL, 4
JXL, JAG, SalL, LFD; appropriate all DRP, DR8; appropriate 18RR,1stss). A lietice of Violation (uithout "hellerplate") uhleh includes the receemended severity towet for the vietetten le rewired. Copies of applicable Toshniset specificettene er License canditlene sited in the tiotice er other reference estoriet needed to evoluete the,.i, " enforcement action are re wired to be encleoed.
This Notice has been reviewed by the Branch Chief or Division Director and j
aach violation includes the appropriate le e f sp as to how and when the requirement was violated.
51gpture Facility: St. Lucie Unit (s): 1A2 Docket Nos: 50-335, 50-389 License Nos: DPR-67, NPF-16 Inspection Report No: 96-09 Inspection Dates: June 9 - July 6, 1996 Lead Inspector: Mark Miller 1.
Brief Sumusary'of Inspection Findings: A review of overtime over a one month period in'dtcated that 56 individual deviations from TS required overtime guidelines occurred. The deviations were not approved by plant management, as required by TS. The deviations were committed by 5 individuals.
The number of examples of the proposed violation indicates particularly poor performance by the licensee in this area.
PROPOSED ENFORCEMENT ACTION - NOT FOR PUBUC DISCLOSURE WITHOUT THE APPROVAL OF THE DIRECTOR, OE
2.
Analysis of Rest caus3:
Failure, on the part of the individuals involved, to recognize the need for approved deviation requests, failures, on the part of plant management, to conduct effective reviews of overtime usage.
With regard to the differences between gate logs and timesheets, comments were also received indicating that, while management had stated that overtime guidelines should not be exceeded, an unexpressed pressure was perceived to meet outage schedules which led to work performed "off the clock." Additional. comments were received which indicated that all of the parties interviewed were motivated by a desire to see jobs through-to completion, with several stating that their own expectations for their performance factored into decisions to work extra hours.
3.
Basis for Severity Level (Safety Significance):
No operational event or challenge to a safety _ system has been identified as a result of the violation identified. This is proposed as a SL IV violation, Supplement
(
I, D.3, a failure to meet regulatory requirements that have more than minor safety significance.
i 4.
Identify Previous Escalated Action Within 2 Years or 2 Inspections?
EA 96-249 10 CFR 50.59 Deficiencies, Supplement 1, 7/96, (pending)
EA 96-236 Configuration Management Programmatic Breakdown, Supplement 1, 7/96 (pending)
EA 96-040 Boron Overdilution Event, Supplement 1, 1/22/96 EA 95-180 Inoperable PORVs due to Inadequate PMT, Supplement 1, 8/4/95 5.
Identification Credit? No Consider following and discuss if applicable below:-
O Licensee-identified O Revealed through event O NRC-identified O Mixed identification O Missed opportunities Enter date Licensee was aware of issues requiring corrective actions:
6/6/96 1
Explain application of identified credit, who and how identified and consideration of missed opportunities:
The issue of excessive overtime was identified by the licensee's QA organization in an audit conducted for the period of May 9 through 18.
The NRC identified the issue in an audit conducted for the period of May 13 through June 13. The NRC was unaware of the licensee's audit. On June 6, QA discussed the issue with the Plant General Manager (PGM).
Consequently, the Site VP and the PGM stressed personal accountability to their staff at morning meetings. Notwithstanding the licensee's immediate corrective actions, the NRC inspection identified 23 examples l
of unapproved deviations from the overtime guidelines in the time period from June 7 through.13.
While the licensee's QA organization was able to identify cases of excessive overtime, the licensee's program for controlling overtime i
l usage was ineffective in identifying the issue sooner.
By procedure, the licensee's management was to perform monthly reviews of overtime 11 PROPOSED ENFORCEMENT ACTION - NOT FOR PU8UC DISCLOSURE WITHOUT THE APPROVAL OF THE DIRECTOR, OE l
usage. The procedure failed to,specify which managors were responsiblo for the required reviews or how the reviews were to be conducted.
Consequently, opportunities to identify the problem were missed.
6.
Corrective Action Credit? Yes Brief sumusary of corrective actions:
. Site VP and PGM discussed the problem with their staff at morning meetings stressing expectations for personal accountability in i
this area.
PGM issued letter to department heads on June 19 restating guidelines and restressing personal accountability and the possibility for discipline for violation of the policy.
l
'The Site Services Manager proposed a monthly spot check of high overtime users, comparing time sheet totals to gate logs.
1 The site VP explained to site management at a morning meeting, and l
'i later reiterated to the SRI, that it is his expectation that personnel working beyond guidelines receive prior approval, receive direct management oversight to ensure that fatigue does i
not impede the employee's abilities to work safely, and that employees working excessive hours receive a ride home and that someone else drive the employee's car home.
QA has subsequently performed an audit of overtime use in the I&C department (the group showing the most examples of the inspector's violation) and has found no deficiencies, indicating that corrective action has been effective in the short term.
j Explain application of corrective action credit:
The licensee's actions to date appear to have reestablished control over overtime usage.
7.
Candidate For Discretion? [See attached list]
tanterv ormon Explain basis for discretion consideration:
8.
Is A Predecisional Enforcement Conference Necessary? No Why:
Severity of violation does not warrant conference.
Additionally, no new information is predicted to be obtained.
If yes, should OE or OGC attend?
[ Enter Yes or No):
Should conference be closed?
[ Enter Yes or No):
i
{
.9.
Non-Routine Issues / Additional Information:
i PROPOSED ENFORCEMENT ACTION - NOT FOR PU8UC DISCt.OSURE WITHOUT THE APPROVAL OF THE DIRECTOR. OE
l 10.
This Action is Consistent With the Following Action (or Enfarcement l
Guidance) Previously Issued:
mies te pewidei tif inconsistene, includeo Basis for Inconsistency With Previously Issued Actions (Guidance) 11.
Regulatory Message:
A strong commitment to maintaining overtime usage at acceptable levels is necessary to minimize the potential for human error which might 1
result in challenges to safety.
i 12.
Recommended Enforcement Action:
SL IV 13.
This case Meets the criterik for a Delegated case. teses - ant.c v
.c mi i
14.
Should This Action Be Sent to OE For Full Review? cries - enter vm or mi l.
If yes why:
l 15.
Regional Counsel Review trics to bc.ini No Legal Objection Dated:
16.
Exempt from Timeliness: rates)
Basis for Exemption:
Enforcement Coordinator:
DATE:
h PROPOSED ENFORCEMENT ACTION - NOT FOR PUBUC DLSCLOSURE WITHOUT THE APPROVAL OF THE DIRECTOR, OE
ENFORCDIDE ACTION WORKSHEET - IS$UES TO CONSIDER FOR DISCRETION j
i O
Problems categorized at Severity Level I or II.
O Case involves overexposure or release of radiological material in excess of NRC requirements.
l O
Case involves particularly poor licensee performance.
O Case (may) involve willfulness.
Information should be included to,
address whether or not the region has had discussions with OI regarding the case, whether or not the matter has been formally referred to 01, and whether or not 01 intends to initiate an investigation. A description, as applicable, of the facts and circumstances that address q
the aspects of negligence, careless disregard, wi11 fulness, and/or management involvement should also be included.
O current violation is directly repetitive of an earlier violation.
O Excessive duration of a problem resulted in a substantial increase in risk.
t O
Licensee made a conscious decision to be in noncompliance in order to 1
obtain an economic benefit, O
Cases involves the loss of a source.
(Note whether the licensee self-identified and reported the loss to the NRC.)
l D
Licensee's sustained performance has been particularly good.
O Discretion should be exercised by escalating or mitigating to ensure that the proposed civil penalty reflects the NRC's concern regarding the violation at issue and that it conveys the appropriate message to the licensee.
Expl ain.
l 1
2 PROPOSED ENFORCEMENT ACTION - NOT FOR PUBUC DISCLOSURE WITHOUT THE APPROVAL OF THE DIRECTOR, OE
REFERENCE DOCUMENT CHECKLIST
[x]
MRC Inspection Report or other documentation of the case:
NRC Inspection Report Nos.: IR 96-09
[x]
Licensee reports: Quality Assurance Audit QSL-PM-96-08 l
[x]
Applicable Tech Specs along with bases:
[]
Applicable license conditions
[x]
Applicable licensee procedures or extracts AP-0010119 Rev. 14
[x]
Copy of discrepant licensee documentation referred to in citations such as NCR, inspection record, or test results Typical time sheet l
[]
Extracts of pertinent FSAR or Updated FSAR sections for citations involving 10 CFR 50.59 or systems operability f
[]
Referenced ORDERS or Confirmation of Action Letters
[]
Current SALP report summary and applicable report sections
[]
Other miscellaneous documents (List):
PROPOSED ENFORCEMENT ACTION - NOT FOR PUBUC DISCl.OSURE i
WITHOUT THE APPROVAL OF THE DIRECTOR. OE j
l Excerpt From St. Lucie Inspection Report IR 96-09 1
4 e
i B
4 J
d 1
1 4
e t
..m-4
_.... - _ ~-.
08.X Control of Overtime l
-The inspector reviewed the licensee's control'of overtime for the period i
of May 13 through June 13. The inspector obtained gate logs for 26 individuals. The selected individuals were chosen from the licensee's maintenance, engineering, planning, and management organization: based '
i upon their involvement in outage activities and the inspector's understanding of the' activities under their cognizance.
From the results obtained (which demonstrated time spent on site), the inspector reduced the inspection population to five individuals based upon-i indications of excessive hours. The individuals in question included supervisors and engineers with responsibilities for safety-related work.
As acceptance criteria, the inspector reviewed TS 6.2.f, which required that the hours expanded by personnel performing safety-related functions be 11gited, with an objective that personnel work a normal 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months day, 40 hour4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months week while the plant was operating. The TS observed that l
substantial amounts of overtime might be required during extended periods of shutdown for refueling, and established guidelines for these periods. The TS stated"
,..on a temporary basis the following guidelines shall be followed:
a.
An individual should not be permitted to work more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months straight, excluding shift turnover time.
b.
An individual should not be permitted to work more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months in any 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period, nor more than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in any 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months period, nor more than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in any 7-day period, all excluding shift turnover time.
c.
A break of at least 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months should be allowed between work periods, including shift turnover time...
...Any deviations from the above guidelines shall be authorized by the Plant General Manager or his deputy, or higher levels of management, in accordance with established plant procedures and with documentation of the basis for the deviation." The inspector reviewed AP C010119, revision 14
" Overtime Limitations for Plant Personnel," and found that the procedure appropriately implemented the TS requirements.
The inspector found that the licensee deviated from TS guidelines for the control of overtime without the prior (or subsequent) approval from s
e senior plant management. Of the five individuals focused on as a result of gate logs, the following information was obtained from timesheets (violations of the requirements were cited only for excesses of requirements which had not received approval per AP 0010119):
r PROPOSfD ENFORCEMENT ACTION - NOT FOR PUBUC DISCLOSURE s
WITHOUT THE APPROVAL OF THE DIRECTOR. OE t
Individual Violations of 72 Violations of Violations of 16 Hour Requirement 24/48 Hour Hour Requirement Requirement A
3 0
0 B
0 0
0 l
C 5
1 0
D 14 2
0 i
E 16 12 3
Total 38 15 3
The instances identified above, in which TS guidelines were exceeded, and for which the TS-required approvals for the deviations were not obtained, collectively represent a violation (VIO 96-09-XX, " Failure to Control Overtime").
While violations were identified, the inspector also noted that significant differences existed between timesheet records, which divided time between TS and non-TS categories, and gate records, which indicated total time on site.
For the 5 individuals highlighted above, numerous instances of differences between total time on site and timesheet-indicated time on site existed, with differences frequently exceeding one and two hours and, at times, exceeding several hours. The most time spent continuously on site was noted to be approximately 26 hours3.009259e-4 days 0.00722 hours 4.298942e-5 weeks 9.893e-6 months .
The inspector discussed the results above with the affected parties to ascertain the reasons for the excessive use of overtime and for the differences between gate logs and timesheets.
Responses were mixed.
Regarding the heavy use of overtime, several respondents pointed out that the project that they had been working was adversely affected by the loss of several key personnel (one to layoffs, one to death, and one to termination for cause), which reduced the depth of knowledge on the associated job.
Several stated that the diverse activities on both units (due to the outage on Unit 1 and the recent trip of Unit 2) had placed increased demands on their time.
In discussing the method for completing timesheets, the inspector found that a lack of uniformity existed.
Some respondents treated work periods (as described on the timesheet) as any work performed on a given calendar day.
By applying this :pproach, the potential existed for the work hours recorded for a given day to represent a composite value of two work periods if one (or more) of the work periods extended across midnight.
The potential result of j
this type of accounting was that the true length of a work period, as referenced in TS, would not be accurately reflected on timesheets, confounding the ability to maintain an accurate count of daily, 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and 7-day totals.
With regard to not obtaining the appropriate deviation approvals for time worked in excess of the guidelines, several workers stated that they believed that obtaining a deviation provided a blanket authorization for overtime spent 2
on the project for which the deviation applied. The inspector noted t. hat the AP was not specific as to whether a deviation request was required for each PROPOSED ENFORCEMENT ACTION - NOT FOR PUBUC DISCLOSURE WITHOUT THE APPROVAL OF THE DIRECTOR. OE I
l
planned deviation from the guidelin:s cr whsther it applied to ths job which was described on the request. The inspector discussed this issue with the Plant General Manager, who stated that it was his expectation that a deviation request be filed for each planned deviation of the guidelines (the implication being that a series of work periods for which each period led to violations of one or more guidelines should each be documented on separate requests). The inspector had requested any deviation requests associated with the personnel audited for the subject time period.
Two were identified which addressed themselves to 3 of the personnel.
The deviations covered by these deviation requests were not considered in the suimmary table above.
AP 0010119 required that department heads perform a monthly review of assigned overtime to assure that excessive overtime was not assigned.
The inspector questioned the licensee as to how those reviews were executed.....
Independent of this inspection (and unknown by the inspector), the licensee's QA organization performed an audit of overtime usage for the period from May 5 through 18. A population of 100 plant personnel was selected at random for the audit. QA reviewed gate logs for the sample population and applied criteria which assumed a one half hour lunch break and accepted turnover periods to reach the following criteria for determining whether guidelines had been exceeded:
No more than 17.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months in I day.
No more than 27 hours3.125e-4 days 0.0075 hours 4.464286e-5 weeks 1.02735e-5 months in a 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months period No more than 82.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months in a 7 day period An 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months break between work periods.
QA determined that 13% of their population exceeded the criteria at least once and that 8% exceeded the criteria at least twice. QA informed management of their findings in this area on June 6.
As a result, the Site Vice President and the PGM discussed the problem with plant staff at morning meetings to stress expectations for. personal accountability in this area.
On June 19, the PGM issued a letter to department heads restating the overtime guidelines and stressing personal accountability on the issue. The inspector noted that, with respect to immediate corrective actions, 23 examples of unapproved deviations existed in the inspector's sample from June 8 through 13.
As a result of this inspection, the inspector concluded the following:
Overtime usage for the period May 13 through June 13 has exceeded TS
=
guidelines for a number of personnel.
The licensee failed to effectively control overtime as required in AP 0010119, revision 14. " Overtime Limitations for Plant Personnel," in that deviation requests were neither prepared nor approved for the majority of deviations identified.
AP 0010119 was unclear in its expectations, both for when a deviation l
request was required and for who was responsible for reviews of overtime usage (and how it was to be executed).
i PROPOSED ENFORCEMENT ACTION - NOT FOR PUBUC DISCLOSURE i
WITHOUT THE APPROVAL OF THE DIRECTOR, OE 4
' The requirement for monthly reviews of overtime usage, detailed in AP 0010119, was ineffectively implemented.
farsonnel have, at times, worked hours which were not recorded on timesheets i
.4 4
4 l
l PROPOSED ENFORCEMENT ACTION - NOT FOR PUSUC DISCLOSURE WITHOUT THE APPROVAL OF THE DIRECTOR, OE j
PREDECISIONAL l
DRAFT INFORNATION - NOT FOR DISTRIBUTION-L NOTICE OF VIOLATiGN -
Florida Power & Light Company Docket Nos.
50-335 and 50-389-j St. Lucie 1 and 2 License Nos. DPR-67 and NPF-16
[
During an NRC inspection conducted on June 9 through July 6, 1996, violations of NRC requirements were identifi.ed.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," (60 FR 34381; j
June 30, 1995), the violations are listed below:
i A.
Technical Specification 6.2.f, requires that the hours expanded by personnel performing safety-related functions be limited and that during extended periods of shutdown for refueling, the following guidelines be observed:
1 a.
An individual should not be permitted to work more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months straight, excluding shift turnover time.
j b.
An individual should not be permitted to work more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months in any 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period, nor more than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in any 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months period, nor more than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in any 7-day period, all excluding shift turnover time.
The Specification further required that any deviations from the above guidelines be authorized by the Plant General Manager or his deputy, or l
higher levels of management, in accordance with established plant procedures and with documentation of the basis for the deviation. AP 0010119, revision 14, " Overtime Limitations for Plant Personnel,"
implemented this requirement and provided an administrative vehicle for the approval of deviations from the specified guidelines.
i Contrary to the above, during the period from May 13 through June 14, 1996, five individuals who performed safety related functions were found to have contributed to 38 deviations from the 72-hour-in-any-seven-day-period requirement, 15 deviations from the 24-hour-in-any-48-hour requirement, and 3 deviations from the 16-hour-in-any-24-hour-requirement without obtaining authorization from the Plant General Nanager, his deputy, or higher levels of management.
j i
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C:\\ hips t \\B00Seuf \\mmLL\\APf 9NELA.6P tapert printed 9:35 am, Fridsy, Jety 19, 1996 10
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Quality Assurance Audit QSL-PM-96-08
)
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v. _.c..
s....._.
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Inter Office Correspondence 1
JQQ-96-086 To:
J. Scarola Date:
July 8,1996 From:
L. W. Bladow Department:
JNA/PS'L
Subject:
Quality Assurance Audit OSL.PM-96-08 1
Attached is a summary report for QA Perfonnance Monitoring activities completed during May/ June.1996 to assess the irnplementation of the Quality Assurance Progrcm at St. Lucie.
The following three findings are documented in this report and have been discussed with appropnate personnel and exited with PSL Plant Management.
Finding 1:
Inadequate Procedures for Resin Transfer A.
The procedure and methods in use during blowdown building resin transfer did not implement the system operating description for Blowdown Building resin discharge as found in the i
FSAR.
l B.
The procedures used to changcout typically non-radioactive resins do not provide adequate radiological controls when the resins are radioactive.
C.
The procedures in use during a Blowdown Building resin transfer were not being completely follow:d in that several radiological controls were not in place.
Findine 2:
Procedure Non-compliances with Requirements for Control of Breathing Air Stations Contrary to requirements, HP Techs provided bubble hood respiratory protection with air supply pressures that execeded procedure limits. Neither procedure HP-61 or a usable Table 1 of that procedure were available. BA station BB 029 calibration data posted with the machine was not complete. Other stations (BB003 and BB004) were found with expired calibration stickers and incomplete calibration sheets.
Finding 3 Violation of Overtime Guidelines During the period 5 through 1 S May 96,12% of the sampled population exceeded one or more A.
of the overtime guideliner..
B.
Overtime deviation requests are not being filled out and forwarded to the vault as required.
C.
Management reviews of overtime guideline adherence are ineffective.
g,_ p % em a weie hes.osm OH ic,
aa7 e e P 03 Q~
Qj AUDIT REPORT 4-QStrPM-96-08 Page 12 of 28
/
observed to be conducted per established procedural guidelines. Upon satisfactory completion PMT per Data Sheet C, QA monitored the performance of the flow tests of the 2C AFW its valves per Data Sheet D, Activities were accomplished per procedure with satisfactory Performance Monitor: L. Panessa Services /Enrineerint/Other PMON 96-033 was initiated to insure Plant compliance with overtime controls specified in Technical Specifications 6,2.2.f and Administrative Procedure AP0010119, Rev.14. This evaluation was conducted by reviewing security gate log entries and exits from the protected area for a random sampling ofpersonnel currently b.sdged at the St. Lucic site. Selected personnel were drawn from a population of 16 plant departments and eight diff' rce contractor companies all of which have the e
potential to perform safety related work activities. individuals examined were selected using a random numbergenerator.
2 Interviews were conducted with management personnel to examine consistency in understand implementation.of overtime guidelines. Records of overtime deviation requests were reviewed.
Interviews conducted indicate that managers and direct reports are reviewing time sheets eac i
period to ensure compliance with overtime guidelines. In addition, personnel have been instructed I
to report in advance any anticipated overtime that would exceed the guidelines. Management interviews revealed a consistent interpretation of the overtime limits. As currently implernented the overtime policy allows turnover tirr.e of 30 minutes before and after each shift in addition to the maximum limits stated in the technical specifications. This understanding is contained in a 4
maintenance memorandum datcJ 20 April 1992.
Other than this Mechanical Maintenance I
memorandum, other plant wide guidance defining shift turnover time was not located during this audit. Consistent implementation of shift turnover time was not found when time records were reviewed.
The target population contained 1,572 badged personnel. A sample size of 100, 6.4% of the population, was randomly selected. Security gatelogs were obtained for the period,5 through 18 May 96, inclusive. Allowing 30 minutes for a lunch break and applying the previously discussed dormition of shin turnover to the criteria in AP0010119, the following maximum thresholds for allowed hours on site were established:
1.
No more than 17.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months in 24 1.
Nb more than 27 hours3.125e-4 days 0.0075 hours 4.464286e-5 weeks 1.02735e-5 months in 48 1.
No more than 82.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months in 7 days 1.
An 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months break exists between work periods (including snift turnover).
l
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~
Unit 2 Technical Specification 6.2
07-1p-1996 04:55&l
'+. Lucle Reoid:ns OHice
407 461 4622 P.63 i.'.
ag,-18-1996 1183eAM Lucse nr21 dent. Office 4Er7 dei 4622 P.82 ADMINISTRATIVE CONTROLS 6.2 GIRANIZAhloll(Continued)
M11JZall
~
6.2.2 The unit organisation shall be subject to the following:
Each en duty shift shall be composed of.at least the minieme shift i
a.
crew souposition shown in Table 6.2-1.
At least one licensed Reacter Operater shall be in.the control resa b.
when fuel is in the reactor. In addition, while the reacter is in j
MODE 1, 2, 3, or 4, at least one licensed senter Reacter Operator shall be in the control rees.
A health physics techitician# shall be on site when fuel is is the c.
r..cser.
d.
All CORE ALTERATIONS shall be obsened by a licensed operator and supervised by either a licensed Senior Reetter Operater or Senior 4
who has no other concurrent Reactor Operater Limited to Fuel Handling'he SR0 in charge of fuel responsibilities during this operation.
hand 111odirectlysuperviseateithertherefoe,1ingdeckerthenormally l
b111ty spent fuel pool.
I e.
DELETED i
f.
Administrative recedures shall be developed and implemented to i
limit the werkt hours of unit staff who eerfers safety-rel ued i
j functions;.e.., senter reacter operators, reacter operators, health physic sts, auxiliary raters, and key safetenance personnel.
Adequate shift coverage shall asintained without routine heavy vse of evertime. The ective shall be to have operating
(
l Personnel work a normal hour day, 40-hour week while the plant l
1s operating. However, in the event that unfereseen probless-require substantial amounts of evertime to be used, or during extended periods of shutdown for refueling, major maintenance j
or major plant modification, on a temporary basis the following i
guidelines shall be followed:
s l
?
I f.
I i
The health physics technician may be less than the minimes requirement for a period of time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in order to accoseedate unexpected absence, provided temodista action is taken to fill the required posittens.
ST. LUCIE - 451!T 2 6-2 W ns. SS 55
. - -. - - ~ _.
u?-AS. sins 043 5Sc) 5t Lucie iwssesnt Off sco i 407 461 4622 P 04 06-18-1996 11835R1 Lucie Resident OHico
dW7 461 4622 P.53 meistni==iiw enufens
,15dIT STA F (Cont nued)
F i
a.
An individual should not be permitted to work more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months straight, excluding shift turnover time, b.
An individual should not be permitted to work more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months in any 24-hour period, nor eers than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in any 48-hour period, nor more than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in any 7-day period, all excluding shift turnover time.
c.
A break of.at le;st 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months should be allowed between work periods,. including shift tornover time.
the use of overtime Escept during extended shutdown periods d.
should be considered on an ladividual 1Esis and not for the entire staff en a shift.
Any deviation from the above guidelines shall be authorized by the Maat General Manager or his deputy, or higher levels of management, in accordance i
vith established procedures and with documentation of the basis for granting the deviation. Centrols shall be included in the procedures such that individual overtime shall be reviewed monthly by the Plant General Manager or l
his designee to assure that excessive hours have not been assigned. Routine deviation from the above guidelines is not authorized.
l g.
The Operations Supervisor shall hold a senior Reactor Operator License.
i 4
ST. LUCIE - UNIT 2 6-ts Amendment Mo. 39,65 i
d?-12.s,o i/J 5 cran as wc se Aes sornt Ott ace
407 461 4622 T 05 06-1'e-1996 "183941 Lucie Recident Offico 4s7 461 44fE2
?.e4 4
e Page 1 or G
}
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FLORIDA POWER & LIGHT COMPANY ST. LUCIE PLANT I
ADMINISTRATIVE PROCEDURE NO. 0010119 3
REVISION 14
__ PSL
1.0 IIILE
l OVERTIME LIMITATION 8 FOR Pl. ANT PERSONNEL L
i N P400Utm0N 2.0 REVIEW AND APPROVAL:
Reviewed by Facility Review Group 10f3119R
]
Approved by
.L H. herow (for)
Plant General Manager 10/31 19 1 j
l l
Revision 14 Reviewed by F R G H 19,3(,,
I Approved by
c. L aurson Plant General ti -,,+
M 19,36, l
3.0 SCOPE
j 4
3.1 'This procedure prowdee administrative requirements and doournentation requwoments for plant personnel workirg. overtime.on. safety.ranated.tuactions.
FOR INFORMATION ONLY
4.0 PRECAUTIONS
THis ooCeMcNT is Noi comeotuo. serout uss, l
VIRIFY INPotMATION WIT"A A CoMTRo:1ED DoCVMENT..
None noanoApowst AN3UCHT Co.$T.LUClf PLANT DATEYERFIED I
I D#nA43 i.
5.0 ftESPONSIBILITIES
DATEYttWWD f
,I INmAL5 5.1 The Plant General Manager is responsi5ETor ensuring that the use of I
overtime le minimized.
5.2 Each department head is responsible to provide noosssary work schedules without routine heavy use of overtime.
J 5.3 Each department head is responsible to follow these instructions and ensure documentation of the basis for use of overtime exceeding the guidelines.
5.4 The Administrative Depwtment le responsible for maintaining updated copies of the plant roster in each Control Room.
l 8M i
DATE INFORMATION ONLY EN I
(
ITM 14 i
4 SP
)
1 l
i
^
t i
4 St. Lucie Administrative Procedure No. 0010119 h
4
.m.
. e7. sci 422 r.uo nWr-1b 1w96 118depM wc:o mea 1eens Offito der? 461 d622 P.W Page 2 of 6 ST. LUCIE PLANT ADMINISTRATIVE PROCEDURE NO. 0010119, REVISION 14 OVERTIME LIMITATIONS FOR PLANT PERSONNEL 6.0 REEEBEM;ES:
6.1 Tech Spec Section 6.2.2.f 6.2 NUREG 0737 Section I.A.1.3 6.3 Adrrunistra#ve Procedure 0010518, ' Fitness for Duty Call Out and For Cause Teethg.'
6.4 NucieAr Polley NP-306, Overtime.
6.5 St. Lucie Plant Policy, PSL-202, Overtime.
/R14 7.0 RECORDS AND NOTIFICATIONS:
7.1 Completed Overtime Deviatiori Requests shall be maintained in the plant files in acooniance with Ol 17-PR/PSL 1, " Quality Amourance Records'.
F P
i
,l 1
4 iNFORMATiON ONI.Y
. _ _.. ~. _ _. _ _... _. _ _ _ _... _. _ _ _.. _ _ _ _ _ _ ____._-- _______
i.0..5mh W.ovi 4s L.wc ae Aesso:nt Ot+ 1ce 47 41 422 P.07 BEr-10-1996 118deFW1 Luc 1e mesident Off1c3 de7 dei es22 P.es Page 3 of 5 l
ST. LUCIE PLANT ADMINISTRATIV
E. PROCEDURE
NO. 0010119, REVISION 14 OVERTIME LIMITATIONS FOR PLANT PERSONNEL
8.0 INSTRUCTIONS
8.1 Excesolve utilization of overtime le cociGrproductive and is to be avoided.
8.2 De nuoiser plant personnel.in all departments shes be covered bym instructans.
/R14
/R14 MOTE Nucieer DMsion personnel should adhere to these limits. Variations fem these limits can only be authonzod by the Vice President - 9t. Lucie Plant or his designee in accordance with the requirements of Nuclear Policy NP-308.
Overtime.
8.3 Overtime Limit Guidelines:
1.
An individual should not be permitted to work more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months straight, excluding shift tumover time.
2.
An indMdual should not be permitted to work more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months in any 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period, nor more than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in any 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months period, nor more than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in any 7 day period, all excluding ohlft tumover time. An acceptable deviation to this guideline is the STA esven consecutive 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months shift schedule.
3.
A break of at least 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months should be allowed between work periods, including shift tumover time.
4.
Exoopt during extended shutdown penode, the use of overtime should be considered on an indMdual basis and not for the entire staff on a ehlft.
8.4 Deviatione from Overtime Limit Guidelines:
l 1.
Deviation from the overtime guidelinee shall be approved by the Vice Prooident St. Lucie Plant, Plant General Manager, Services 'tr+y.
2.
The senior person on site from their respectivo department shall complete the overtime deviation request (Figure 1) and obtain the necessary 3
approval for personnel speelflamay outlined in section 8.2 of this procedure. AR St. Lucie Plant personnel shall comply with Nuclear Pohoy Guideline NP-306, Overtime, l
l iNFORMATION ONLY e
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ML20137P440

Contents

Text

1.0 TITLE

3.0 SCOPE

8.0 INSTRUCTIONS

SUBJECT:

SUBJECT:

SUBJECT:

SUBJECT:

Deartem,

7.0 REFERENCES

SUBJECT:

Subject:

1.0 IIILE

3.0 SCOPE

4.0 PRECAUTIONS

5.0 ftESPONSIBILITIES

E. PROCEDURE

8.0 INSTRUCTIONS

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ML20137P440

Text

1.0 TITLE

3.0 SCOPE

8.0 INSTRUCTIONS

SUBJECT:

SUBJECT:

SUBJECT:

SUBJECT:

Deartem,

7.0 REFERENCES

SUBJECT:

Subject:

1.0 IIILE

3.0 SCOPE

4.0 PRECAUTIONS

5.0 ftESPONSIBILITIES

E. PROCEDURE

8.0 INSTRUCTIONS

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