Text

FOIA Request for Documents Re Access to twenty-two Listed Files.Also Encl,Case Chronology for RII-95-A-0001 & RII-95-A-0183
	ML20202D837
Person / Time
Site:	Saint Lucie
Issue date:	12/18/1997
From:	Barton E; PORT ST. LUCIE, FL
To:	Pool M; NRC OFFICE OF ADMINISTRATION (ADM)
Shared Package
ML20202D814	List: ML20202D810; ML20202D837; ML20202D884;
References
	FOIA-97-484 NUDOCS 9802180015
	Download: ML20202D837 (6)
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c1501 Pest SL lacio Boulevard, S* he

. Port SL 1mle, P1,34952 i (561) 337 5800 PAX:(56I) 333-3993 The Port St. Lucie News i F0WPAREQUEST Dec.18,1997 Cas0No: ._%2cI --

MeRoc% 22-#

To the ofBee of'.

Ac0cnOth 35md '

Mary JeanPool R32dCf2 - - ~

Freedom ofIn*etastion Act Branch U.S. Nuclear hogulatory Comminion 11545 Rockville, MD 20852-2738 Ms. Pool-Pursuant to Section 119.07 (1) (a), Florida Statutes and the U.S. Freedom ofInformation Act, I am requesting access to certain public records. In reference to our conversation today,'I am requesting fhrther access to these twenty two (22) NRC files:

RII 1994-A-0119

RII-1995-A-0001

RII-1995-A-0033

RII-1995-A-0065

RII-1995-A-0183

RIi-1995-A-0186

RII-1995-A-0199

RII-1995-A-0200

RII-1996-A-0029

RII-1996-A-0035

RII-19%A 0120

RII-1996-A-0122

RII-1996-A-0130

RII-1996-A 0150

RII-1996-A-0175

RII-19%A-0180

RII-1996-A-0192

RII-1996-A-0251

RII-1997-A-0015

RII-1997 A-0027

RII-1997-A-0053

RII-1997-A-0116

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SpecificaDy, we are looking for several portions of these files and will likely not need the entire files. Below are lists ofportions we are requesdng:

The initial allegation

The allegeridWtion sheet

The case chronology

The investigation report

Any documents regarding a conclusion, summary or recommendation for changes If copies are needed, 7he Pcrt St. Lucie News will pay the reasonable costs, as defined by Florida law. Please fax any and all results of the request to (561) 335-3993. If a fax is not posalle, the results may be mailed to the above address.

If you believe you are not required to disclose any or all of the documents in your possession which fhll within the scope of the foregoing request, please be advised of the requirements of Section 119.07 (2) (a), Florida Statutes. This statute provides that, if a person who has custody of 9802180015 980128 FDR FOIA

. ._ BARTON97-484 PDR ,,,,,,,,.w., ...., ,,,.1,,,

e , public record contends that the wd or part ofit is exanpt f! rom insper',n and examination, 6

that person amist state the basis c. an - --den which is believed to be 6 . .icable to the public

' record, including the statutory dtation to an asemption created or affbrded by statute, and, if

'- requested by the person seeking to inspect, examine and copy the record, the custodian of the record must state in writing and with particularity the reasons for his conclusions that the record is exampt.

Pursuant to the foregoing statutory provision, if you believe the records raquested above, or any portions oithose records, are exanpt from inspection, == amination and copying, please provide a written statement desenVmg with particulanty the reasons and the statutory basis for your conclusion.

I Thank you in advance for your prompt attention to this matter. If you have any questions or cacerns, do not hesitate to contact me at (561) 337-5826 or fax to (561) 335-3993.

sinaardy,

/.44f Eric AlanBarton nu Port St. Lucie Nm 4

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January 16, 1996 CASE CHRONOLOGY RII-95-A-0001 PACILITY: ST LUCIE OPENED BY: O..DEM RANDA DATE/ INT!LS ACTIVITY SECTION 1/03/95;ODM NMSS ALLEG REPORT. 1 ALLEG: ARMS ROOM DOOR LEFT OPEN AND UNATTENDED 1/03 /95 ;ODM, ALLEGER IDENTIFICATION SHEET 4 1/03/95;ODM INDEX OF CONCERNS 1 1/05/95;ATB ALLEGATION REVIEW PANEL: DRP RESIDENT PERFORM 2 AN INITIAL CHECK FOR REQUIREMENTS. NMSS WITH LEAD INSPECTION AND CLOSEOUT RESPONSIBILITY. ._

6/04/95;ATB RECE VED CLOSEOUT MEMO FROM NMSS INCLUDING 3 INSPECTION REPORT AND ALLEGATION EVALUATION REPORT. THE EVENT WAS SUBSTANTIATED; HOWEVER, NO VIOLATIONS OF NRC REQUIREMENTS RESULTED.

9/15/95;ATB ATB CONTACTED ALLEGER TO OBTAIN LAST NAME AND 4 ADDRESS. UPDATED ALLEGER IDENTIFICATION SHEET.

9/15/95;ATB ATB REVIEWED CASE FILE. NONE 1/10/96;ATB ATB REVIEWED CASE FOR CLOSURE PROVIDED CLOSURE LETTER TO ALLEGER FOR D/EICS REVIEW.

1/11/96;ATB CLOSEOUT LETTER TO ALLEGER ISSUED. 5 01/16/96;ODM SAC QA AMS AND PROVIDE COPY FOR FILE 5

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Jcnuary 10, 1996 IMDEX OF-CONCERMS =

ISTjLUCIE I

m-RII-95-A-00011 '

NO. _ _

DESCRIPTION LOCATION 1/1 ARMS ROOM DOOR LEFT OPEN AND UNATTENDED Date:01/03/95 ALLEG RPT 4

ACTION: ARP CONDUCTED ON 1/05/95. DRP TO PERFORM AND INITIAL EVALUATION OF THE LICENSEE'S REOUIREMENTS. NMSS TO INSPECT FOR CLOSURE.

CJC,OSURE: ONSITE INSPECTION CONDUCTED ON MARCH 27-31, 1995, AND ._

DOCUMENTED IN IR 50-335, 189/95-05. THE EVENTS DESCRIBED BY THE ALLEGER WERE CONFIRMED; HOWEVER, NO VIOLATION OF.NRC REQUIREMENTS WAS IDENTIFIED. _

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1 July 26, 1996 CASE CHRONOLOGY RII-95-A-0183 FACILITY: ST. LUCIE OPENED BY 0.' DEMIRANDA DATE/ INITIALS ACTIVITY SECTION 11/16/95;ODM EICS ALLEGATION REPORT 1 ALLEG: (1) HEALTH PHYSICS CONCERNS INVOLVING POOR CONTROL OF CONTAMINATED TOOLS, LACK OF TRAINING FOR HEW HIRES, PERSONNEL CONTAMINATION EVENT, (2) LACK OF MANAGEMENT RESPONSE TO CONCERNS AND EFFECTIVENESS OF SPEAKOUT 11/16/95;ODM ALLEGER IDENTIFICATION SHEET ( ANONYMOUS) 4 _

11/16/95;ODM INDEX OF CONCERNS 1 11/17/95;ODM SAC ENTER ALLEGATION IN AMS NONE 12/07/95;ODM ALLEGATION REVIEW DOARD MEETING MINUTES 2 apt DRS INSPT HP ISSUES IN CONCERN #1 WEEK OF FEB 26, 1995. DRS DEVELOP PLAN FOR REVIEWING SPEAK OUT TO INCLUDE A CHILLING EFFECT LETTER.

05/11/96;ODM DRS/FREDRICKSON CLOSURE MEF WITH ATTACHED: 5

1. ALLEGATION EVALUATION REl RT

2. REPORT NO. 96-07 07/16/96;ODM DRS/BARR CLOSURE MEMO WITH ATTACHED: 3

1. ALLEGATION EVALUATION REPORT

2. REPORT NO. 96-04 07/26/96;ODM SAC REVIEW, QA AMS AND FINAL CLOSURE NONE 07/26/96;ODM, CASE CLOSED - OSCAR DEMIRANDA NONE e

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1 July 26, 1996 INDEX OF CONCERNS l

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RII-95LA-0183-NO. DESCRIPTION LOCATION 1/2 HEALTH PHYSICS CONCERNS INVOLVING POOR CONTROL OF Date:11/16/95 CONTAMINATED TOOLS, LACK OF TRAINING FOR HEW HIRES, SAC ALLEG RPT PERSONNEL CONTAMINATION EVENT, ACTION: 12/07/96 ARB - DRS INSFT HP ISSUES IN CONCERN #1 WEEK OF.FEB 26, 1995. DRS DEVELOP PLAN FOR REVIEWING SPEAK OUT TO INCLUDE A CHILLING

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, EFFECT LETTER.

CLOSUBE: In summary, a non-cited violation and a cited violation were identified for failure to properly control contaminated tools. While some of the specific allegations were not substantiated, the CI identified a weakness in the licensee's controls for contaminated tools.

This allegation is closed.

2/2 LACK OF MANAGEMENT RESPONSE TO CONCERNS AND Date:11/16/95 i

EFFECTIVENESS OF SPEAKOUT SAC ALLEG RPT ACTIO_H: 12/07/96 ARB - DRS INSPT HP ISSUES IN CONCERN #1 WEEK OF FEB 26, 1995. DRS DEVELOP PLAN FOR REVIEWING SPEAK OUT TO INCLUDE A CHILLING EFFECT LETTER.

CLOSUR_E : The inspection report eoncluded that overall the NRC team inspection judged the Speakout program to be effective at all three

company locations (Turkey Point, St. Lucie, and the Corporate office in Juno Beach). It concluded that the company's Speakout program was effective in handling and resolving employee safety concerns. The teams review did not' identify any technical issues that had not been adequately resolved, s

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CLOSURE:

APRIL 20, 1995 Florida Power and Light company ATTN: Nr. J. H. Goldberg D/M fliTORI.!A710ti grygM President - Nuclear Division P. O. Box 14000 Juno Beach, FL 33408-0420

SUBJECT:

NkC INSPECTION REPORT NOS. 50-335/95-08 AND Gentlemen:

Narch 27 - 31,1995.This refers to the inspection conducted by W. Tobin of this authorized for your St. Lucie facility.The inspection included a review of activi At the conclusion of the . inspection, enclosed report.the findings were discussed with those members of your staf Areas examined during the inspection are identified in the report.

these areas Within and represen,tative activities in progress. records, interviews with personnel, and Within the scope of the inspection, violations or deviations were not identified.

The material enclosed herewith contains Safeguards by Section 147 of the Atomic Energy Act of 1954, as amended.

material will nel be placed in the Public Document Room. Therefore, the Should you have any questions concerning this letter, please contact us.

Sincerely, '

original signed by charles hosey for:

Douglas M. Collins, Chief Nuclear Materials Safety and Safeguards Branch Division of Radiation Safety and Safeguards Docket Nos. 50-335, 50-389 Licensa Nos. DPR-67, NPF-16

Enclosure:

NRC Inspection Report (Safeguards Information) cc w/ encl: (See page 2) 4

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p* *% USNTeD STATEE

Q'o,, NUCLEAR REGUt.ATORY COMMISSION

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101 MARIETTA STREET. N.W.. SUITI 2500 ATLANTA. GEOAG4A 312D4105 tg oo o . * ,o R: port Nos. 50-335/95-08 and 50-389/95-08 Licensee: Florida Powar and Light Company 9250WestF1tglerStreet Miami, FL 3<,402 Dock'et Nos.: 50-335 and 50-389 License Nos.: DPR-67 and NPF-16 Facility Name: St. Lucie Plant Units 1 and 2 Inspection Conducted: March 27 - 31, 1995 Inspector:

7.kobin Sennor (Safeguaros Inspector 1) ateliff('

Signeo Approvedby:l /s Mg .k 9 D. McEuire, Chief ' Date' 51gneo Safeguards Section Nuclear Materials Safety and Safeguards Branch

. Division of Radiation Safety and Safeguards StMMRY Scope:

This routine, announced inspection was conducted in the areas of the Safeguards Program for Power Reactors, Specifically, the inspector reviewed Alarm Stations and Coassunications; Testing, Maintenance and Compensatory Measures; and Training and Qualification.

R;sults: '

Th;rc were no violations identified. The inspector found Alann Stations and Comununications to be as required. Testing, Maintenance and Compensatory Measures appeared to be appropriate. Training and Qualification was a strength. The firearms range we.s exceptional, and, officers were professional and well versed -on their duties and responsibilities.

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Background

were also partinvestigations, of this recordswhich verification. included psychological evaluation, The inspector visited the firearms range which was equipped with a classroom, lights, moving targets, a stress course and a " Shoot-Don't Shoot" course.

initial qualification. Officers were observed in the conduct of Several events relative to firecres were reviewed:

o On November 19, 1994, a security officer, who was one of the several officers on duty at the North Security Building, was found to be wearing a weapon that did not have an amunition magazine.

with two other magazines of amunition.This officer was equipped A search of the Building and of other areas and patrol routes taken by the officer failed to locate his missing amunition magazine.

The event was logged in the Safeguards Event Log, and a '

Security incident Report was written, E o On December 19, 1994, the Armory located within the East g Security Building, inside the protected area, was unlocked and unattended for approxima Inside this Armory are response weapons,tely two minutes.

body armor and ammunition.

The event was documented in a Security Incident Report.

An inventory accounted for all weapons and equipment. The Armory door is located 'across the uall from officers continuously access to theposted protected inside area. the glass enclosure controlling There is no requirements in the Physical Security Plan, nor implementing Security Procedures, that the Armory be locked when unattended, o

On March 6, 1995, a training weapon (unusable due to the firing pin having been removed) was found to be missing from the Security Response Room inside the protected area.

The weapon had been accounted for earlier in the shift during an inventory.

An extensive search of all relative areas, posts and vehicles did not locate the weapon. The local St. Lucie County Sheriffs Department was notified

- and interviews, using a voice stress analyzer, were initiated with all officers involved with the weapon. A Lieutenant found the weapon in a trash can on March 12 outside securitythe protected area near the door to the contract offices. The event was originally " Red Phone" to the NRC but was downgraded to a Safeguards Event Log item.

o On M h 16, 1995, a five round magazine of 45 caliber amtnition was found inside a oriefcase carried by a licensee supervisor prior to entering the protected area.

A Security Infomation Report was written. Since there was no malevolent intent, there was no Safeguards Event y

UNITEo STATES

[$2 croneo1 NUCLEAR REGULATORY COMMISSION

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9 101 MARIETTA STREET, N.W., SUITE 2900

-; ;j ATLANTA, GEORGIA 30323o190

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MEMORANDUM Fh4: Oscar DeMiranda, Senior Re91onal Allegation Coordinator Enforcement and I vestigation C dination .

-FROM:- Pa T. rgdrit s h ef .

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Reactor Safety SU8 JECT: CLOSE0VT OF All.EGATIONS ST. LUCIE (SPEAK 0UT RELATFD PORTIONS OF ALLEGATION NOS.

RII-A-95-0065, RII-A-95-0154 RII-A-95-0183, RII-A-95-0186)

ANONYMOUS HISCELLANE0VS ALLEGATIONS The scope and circumstances of the Speakout portions of anonymous allegations ~

RII-A-95-0065, RII-A-95-0154, RII-A-95-0183, and RII-A-95-0186 were reviewed by an NRC team inspection conducted on site April 29 - May 3, 1996 (Reference IR 50-335,389/96-07)._ Attachment I to this memo, Allegatien Evaluation Report (AER), contains information about the results of this inspection and review of the allegations. Also included in the AER is the inspector's finding: and conclusions. Attachment 2 contains a copy of the Inspection Report Nos.

50-250,251/96-05 and 50-335,389/96-07.

The allegations were not substantiated. Howe ser, some elements of the statements made by the allegers were-noted in the inspection report as a concern to the NRC and were discussed with the licensee and documented in the subject inspection report. .It is recommended that the Speakout related issues in these case files be closed.

Attachments: 1. Allegation Evaluation Report

2. Inspection Report Nos. 50-250,251/96-05 and 50-335,389/96-07 4

A 7 C ';ilo u f t L/, p .

ALLEGATION EVALVATION REPORT Turkey Point Nuclear Plant St. Lucie Nuclear Plant Juno Beach Corporate Offices Docket Nos. St. Lucie 50-335 cnd 389 Turkey Point 50-250 and 50-251 ANONYMOUS ALLEGATIONS RIl A-95-0065, RII-A-95-0154, RII-A-95-0183 and RII-A-95-0186 ALLEGATION:

Numerous anonymous allegation sent to the NRC Region II Office alleged concerns about the Florida Power & Light Nuclear facilities. The allegations are not specific but alleged the following broad concerns:

e Management gets rid of employees that bring up problems or go to "Speakout" -

e Employees bring up concerns to " safety" and nothing get done e Speakout is a joke, worthless, a coverup program o Within minutes of going to "Speakout" everyone knows e

When NRC talks to workers, NRC needs to do so without management knowing who is being interviewed

Upcoming cutbacks by utility president threatens safety DISCUSSION:

The NRC determined the above subject anonymous allegations did not hwe enough specific details for NRC to do detailed inspections. Further, the :Glagers are anonymous, thereby preventing the NRC from obtaining additional information from the specific alleger. In order for the NRC to address these broad statements, an NRC team inspection (IR 50-250/96-05, 50-251/96-05, 50-335/96-07, and 50-389/96-07) was performed at Turkey Point, St. Lucie, and Juno Beach facilities cn April 22 through May 3, 1996. The inspection evaluated'the adequacy of the Speakout programs at those facilities and included interviews with various on-site disciplines, including utility management and detailed record reviews of site specific allegation closure files. The objective of the inspection was to evaluate the effectiveness of the utilities ability to address safety issues and protect the identify of the concerned employee.

ATTACHEMENT 1

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Conclusion:

The inspection report concluded that overall the NRC team inspection judged Turkey Point, St. Lucie, and the Corporate Office in Juno Beach).the It conclu Speakout program to b the company's Speakout program was effective in handling and resolving employee safety concerns. The teams review did not identify any technical issues that had not been adequately resolved.

1 The team did note that recent staffing reductions and a perceived lack of l employee confidence associated with identity protectior, may have negative !

effects on the program in the future. The team also noted that investigative techniques and methods used by the licensee when investigating specific concerns and making coroctive action recommendations have the potential to inadvertently identify the concerned individual. Additionally, the team noted i

the license 6's feedback policy to the concerned individual lacked specific details on the outcome of the employees concern. This lack of information could lead to tppeehension on the part of the alleger and subsequently result in the alleger concluding that nothing was done about his or her safety issue which could be contrary to the actual corrective actions taken by the -

licensee.

Recent staffing recuttions affected the job status of some employee's that had previously gone to the Speakout program. This potentially led employee's to the conclusion that because they had gone to speakout with a concern that they had be' terminated or gotten rid of.

The term also noted the N solution and closura af employee concerns was not always dom in a timely manner. This also h:. .he potential to incorrectly lead the concerned employee to the conclusion that his concern was not important and not acted upon by the Speakout group. The team found that aithough some of the issues were not resolved in a timely manner, all issues were adequately eventually resolved.

Separate from the team inspection, an NRC review was performed of FP&L employt.e concern file number NSS-PSL-95-044. The employee concern file stated that: " Employee's ge to Speakout, are tagged as troublemakers and laid off.

Program also prevents issues from going to the NRC. This information was received by the licensee in an anonymous letter to J. H. Goldberg (former Nuclear Division President) on October 30, 1995. The licensee had completed this investigation by obtaining from Human Resources a list of FPL/PSL employees who, for whatever reason are no longer employed at PSL f or the years 1992, 1993', 1994', 1990 t.nd to date, 04/01/1996. They then reviewed the list against employee's that had gone to Speatout and expressed a concern (by name) since the Spcakout program was impitmented in March of 1990.

The licensee's review found that from 01/01/1992 to 04/01/1996, 279 FPL employees have exited the PSL site (temporary employee and students employed during the summer were not included in the 279 figure). The records revealed that 25 of the 279 employee's that had left PSL, had at some time expressed a concern to the employee's concern Speakout program. However, none of the 279 ATTACHEMENT 1 w _

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3 had expressed any concern, including their exit interview, that they believed they were terminated because they had previously gone to the Speakout program.

The licensee concluded that no evidence was identified that any employee had been released from employment at PSL because he had expressed a concern to Speakout, further, the licensee concluded from the record review that no employee had made any such statement to the licensee when they left PSL employment. The record file indicates the licensee was unable to substantiate this anonymous statement.

The licensee also reviewed the Speakout files of all employn't (contractors, and temporary employees) who exited the PSL plant since 1990. Approximately 6,000 employee's exited the PSL plant since 1990. The licensees review found that no employee who had exited during this time frame expressed a concern that their termination for any reason, was related to having expressed a concern tt Spe3koJt.

Regarding the statement that the Speakout program prevents issues from going to the NRC, the licensee concluded that all employees who are badged at PSL are apprised of the purpose of the Speakout program in their initial training / orientation to the site. This training is mandatory and a vidno is shown that encourages employees to take safety concerns they may have to their supervisor, the Speakout program, or the NRC. Additionally, an annual refresher /requalification is mandatory for all employees and in the training, the employees are again reminded of the Speakout program and ancouraged to express their concerns to management Speakout or the NRC. The licensee was unable to find any evidence that supports the theory that issues are prevented from going to the NRC.

The NRC inspectors reviewed the licensee's evaluatlon, including a review of the list of employees that left PSL employment since 1990 and found the evaluation provided adequate ,justi'ication to support their conclusion that employees are not being released from the site because they went to the Speakout program and expressed a safety concern. The inspector also concluded that issues are not being prevented from going to the NRC tecause of the Speakout program, However, most issues are being properly resolved by Speakout which necessitates the need for issues coming to the NRC. The inspector concluded the licensee had adequately addressed this anonymous allegation.

The NRCs review of the anonymous allegations concluded that without more specific infonnation, no further review of these concerns are required. The team inspection determined from employee interviews that employee's would use the Speakout program if they had a s:ifety issue that was not adequately resolved by their management, further, the team determined from sample reviews of closure files that safety issues that go to the Speakout program are being adequately resolved. Some concerns were identified in the IR which the licensee should address and correct. The Speakout portion of the anonymous allegations listed above are considered closed.

ATTACHEMENT 1

April 29,1996 l .

Florida Power & Light Company ATTN: T. F. Plunkett President - Nuclehr Division P. O. Box 14000

, Juno Beach, Florida 33408-0420 i

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SUBJECT:

NRC INTEGRATED INSPECTION REPORT N05. 50-335/96-04 AND 50-389/96-04 AND NOTICE OF VIOLATION Gentlemen:

This refers to the inspection conducted on February 18 through March 30, 1996, it the St. Lucie facility. The purpose of the inspection was to dctermine whether activities authorized by the license were conducted safely and in accordance with NRC requirements. At the conclusion of the inspection, the l findings were discussed with those members of your staff identified in the l enclosed report.

Areas examined during the intnection are identified in the report. Within these areas, the inspection consisted of selective examinations of procedures <

and representative records, interviews with personnel, and observation of activities in progress.

Based on the-results of this inspection, the NRC has determined that violations of NRC requirements occurred. The violations are cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding them are described in detail in the subject inspection report. The violations are of concern because they inclicate that personnel performance with respect to procedure compliance and usage and attention to detail persist even after corrective actions had been completed for previous, similar, violations, Particularly illustrative of this point is a violation for failures ass.ciated with the Unit I containment particulate /icdine/gastous radiatisn monitor. The event displayeo particularly poor performance on the part of sev9ral indiviouais and included aspects of failing to access and follow a procedure, compounded by failing to capitalize on multiple opportunities to identify the inoperable component throtsn logtaking. Logtaking weaknesses were further compounded by the fact that ncn-licensed operators taking the logs were electronically prompted that a key parameter associated with the component's operability was unacceptably low. The failure to pursue this condition, with at least six logtaking opportunities, indicates that a lack of a questioning attitude extends to multiple personnel. It is also noted that a failure to employ an approved precedure lead to a condition of Emergency Diesel Generator inoperability (the subject of another violation in the enclosed report).

As documented in the report, we have performed an initial review of the

" Licensee Event Report you submitted for the subject event. While we found your immediate corrective actions appropriate, we question the scope of the actions delineated in your transmittal. Consequently, in your response to the enclosed Notice, please describe what actions you will take to instill, in non-licensed operators, an understanding of the vital role they play in the of7ICIAL COPY

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early detection of off-normal conditions during logtaking and log review.

Additionally, please describe your basis for believing that other cases of inoperability in com>onents have not been overlooked through similar errors and any actions you aave taken (or plan to take which may be rendered inoperable in a similar ma)nner (by non-Operationsto identify t personnel performing routine evolutions for which the control room may not have cognizance). Please plan to discuss the progress of your corrective actions at the next FPL/NRC management meeting scheduled for June 12,19M.

You are required to respond to this letter and should. follow the instructions specified in the enclosed Notice when preparing your response.. In your response, you should document the specific actions takeri Lad any additional actions you plan to 1revent recurrence. Your risponse may reference or include previous docceted ccrres addresses the required response.pondence, if the your After reviewing correspondence response toadequately this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.

( In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice " a copy of this letter, its enclosures, and your response will be placed in the NRC Public Document Room (PDR). To the extent possible, your response should not include any personal privacy, prop,*ietery, or safeguards information so that it can be pl3ced th t1e PDR without reduction.

The responses directed by this letter and the .sr.:losed Notien are not subject to the clearance procedures of the Office of Managenient and Budget as f aquired by +.he PePe.rork Reduction Act of 1980, Pub. L. No.96-511.

Shou'i you have any questions concerning this letter, please contact us.

Sincerely, Orig signed by Kerry D. lx:dds Kerry D. Landis, Chief Reactor Projcets Cranch 2 Division of Re ctor Projects Docket Nos. 50-335, 50-389 License Nos. DPR-67, NPF-16 Enclosures; Notice of Violatica inspection Report ec w/ encl: (See pkge 2) i

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i FP&L 3 ccw/ enc 1:

W. H. Bohlke, Site Vice President l St. Lucie Nuclear Plant '

P. O Box 128 Ft. Pierce, FL 34954-0128 H. N. Paduano, Manager Licensing and Special Programs Florida Power and Light Company .

P. O. Box 14000 -

Juno Beach, FL 33408 0420 f

J. Scarola, Plant General Manager St. Lucie Nuclear Plant P. O. Box 128 Ft. Pierce FL 34954-0128 E. J. Weinkam, Plant Licensing Manager St. Lucie Nuclear Plant P. 0. Box 128 Ft. Pierce, FL 34954-0218 J. R. Newman, Esq.

Morgan, Lewis & Bockius 1800 M Street. NW Washington, D. C. 20036 John T. Butler Esq.

Steel, Hector and Davis 4000 Scutheast Financial Center Miami, FL 33131-2398 Bill Passetti Office of Radiation Control Department of Health and Rehabilitative Services 1317 Winewood Boulevard Tallahassee, FL 32399-0700 Jack Shreve Public Counsel Office of the Public Counsel

, c/o The Florida Legislature 111 West Madison Avenue, Room 812 Tallahassee FL 32399-1400 J9e Myers, Director Division of Emergency Preparedness Departms.nt of Community Affairs 2740 Centerview Drive Tallahastte, FL 32399 2100 cc w/ encl: See page 3

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NOTICE OF VIOLATION Florida Power & Light Company Docket Nos. 50-335 St. Lucie 1 License Nos. OPR-67 During an NRC inspection conducted on February 18 through March 30, 1996, violations of NRC requirements were identified. In accordance with the

" General Statement of Policy and Procedure for NRC Enforcement Actions," (60 FR 34381; June 30. 1995), the violations are listed below: -

1 A. Technical Specification 6.8.1.a requires that written procedures be !

established, implementedt and maintained covering the activities recossended in AppendL 4 e bpulatory Guide 1.33, Rev 2 February, 1978. Appendix A, paray; A 1.t includes administrative procedures for procedural adherence. 41 s-r!!PSL-1, Rev 68, " Preparation, Revision, Review / Approval of Procedures " Section 5.13.1, states that all procedures shall be strictly atihcred to.

Step 7.5.1.R of procedure HPP-22, Rev 2, " Air Sampling," required that valve 3 of the Unit I containment Particulate lodine Gaseous Monitor be returned to the open position following the performance of a containment grab sample.

AP 0010120 Rev 79, " Conduct of Operations, Appendix F, " Log Keeping,"

required, in part, that " Log readings shall be compared to previous readings to detect abnormal trends or conditions and verified to be within the minimum and maximu:n values for that parameter. All log readings outside the min / max values shall be circled with reasons stated for abnormal readings (i.e., 005, NPWO, ISOL, etc)."

Contrary to the above:

1.

On February 22, 1996, a health physics technician performing a grab sample of the Unit I containment failed to return valve 3 to the open position and, es a result, rendered the monitor inoperable.

-2. On February 22, 23. and 24, 1996 Senior Nuclear Plant Operators failed to perform adequate reviews of logs taken in the Unit 1 Reactor. Auxiliary Building, as'the out-of-specification log readings taken on the Unit I containment particulate iodine gaseous monitor were not highlighted and explained. As a result, the Unit I containment Particulate lodine Gaseous monitor remained inoperable and Unit I transitioned from Mode 3 to Mode 2 without satisfying Technical Specification Limiting Condition for Operation 3.4.6.1. The Mode transition was prohibited by Technical Specification 3.0.4.

This is a Severity Level IV violation (Supplement 1).

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8. Technical Specificatior 6.8.1.a requires that written procedures be implemented, and maintained covering the activities established,in recommended Appendix A of Regulatory Guide 1.33. Rev 2, February, 1978. Appendix A, paragraph 1.d includes administrative procedures for procedural adherence. QI 5-PR/PSL-1, Rev 68, " Preparation, Revision, Review / Approval of Procedures," Section 5.13.1, states that all procedures shall be strictly adhered to.

AP 0010120, Rev 80, " Conduct of Operations," Appendix F. " Log Keeping,"

required, in part, that reactivity manipulations be entered 'n the Reactor Controls Operator Chronological Log.

AP 0010120, Rev 80, " Conduct of Operations," Appendix F, " Log Keeping,"

required, in part, that abnormal conditions in turbine-generator auxilitr systems be entered in the Reactor Controls Operator Chronolo ical Log.

Contrary to the above:

1. On March 27, 1996, St. Lucie Unit 1 operators performed two Reactor Coolant System dilutions (reactivity manipulations), which were not entered in the Reactor Controls Operator Chronological Log.

2. On March 27, 1996, hydrogen was added to restore a low pressure condition in the St. Lucie Unit 1 generator and was not entered in the Reactor Controls Operator Chronological Log.

This is a Severity Level IV violation (Supplement I)

C. Technical Specification 6.8.1.a requires that written procedures be established, implemented, and maintained covering the activitiet recommended in Appendix A of Regulatory Guide 1.33 Rev 2, February, 1978. Appendix A, paragraph 1.d includes administrative procedures for procedural adherente. QI 5-PR/PSL-1, Rev 68, " Preparation, Revision, Review / Approval of Procedures," Section 5.13.1, states that all procedures shall be strictly adhered to.

OP l-2200050A, Rev 24 "lA Emergency Diesel Generator Periodic Test and General Operating Instructions," Appendix E required, in part, that the 1A Emergency Diesel Generator Fuel Oil Storage Tank be recirculated by establishing a flow path from the tank, through the transfer pump, and through valves V17207 and V17208 back to the tank.

QI 1-PR/PSL-2 , Rev 26, " Operations Organization," and AP 0010120, Rev 79, " Conduct of Operations," Appendix A, required that Senior Nuclear Plant Operators "... report promptly to the Control Room any equipment or valve manipulations so that the RCO will be aware of the current plant status."

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3 Contrary to the above

1. On January 5, a Senior Nuclear Plant Operator placed the 1A Emergency Diesel Generator Fuel Oil Storage Tank in recirculation by isolating the oischarge of the transfer pus) and allowing the fuel to be recirculated back to the tank via tie pump's minimum flow line. The isolation of the transfer pump's discharge resulted in the Emergency Diesel Generator being inoperable.

2. On Jannry 5, a Senior Plant Nuclear Operator failed to notify the Unit 1 control room of a valve manipulation made to place the 1A Emergency Diesel Generator on recirculation.

This is a Severity Level IV violation (Supplement 1)

D. 10 CFR 50, Appendix B, criterion XI, " Test control," requires in part that a test program be established to assure that all testing required to demonstrate that components will perform satisfactorily in service and that test results be evaluated to assure that test requirements have been satisfied. FPL Topical Quality Assurance Report 11.0, Rev 4, " Test Control,"

step 11.2.3, " Evaluation of Test Results." requires that

... documented test results si'all be evaluated against the predetermined acceptance criteria by a group or individual having appropriate qualifications."

Contrary to the above, on May 22, 1993, the licensee failed to adequately evaluate Unit 1 CEDM coil resistance test results to assure that test requirements were satisfied as specified in PWO 63/0046 for PC/M 133-191. This resulted in not identifying and dispositioning 11 CEDMs coils whose resistance readings did not meet the specified item

11, Acceptance Criteria of Attachmer.t 4, "PC/M Testing Document."

This is a Severity Level IV violation (Supplement 1) i Pursuant to the provisions of 10 CFR 2.201, the Florida Power & Light Company is hereby required to submit a written statement or explanation to the U.S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.

20555, with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).. This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violations, or, if contested, the basis for disputing the violations, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response, if an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

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4 8ecause your response will be placed in the NRC Public Dxument Room (PDR), to the extent pessible, it should not include any personal privacy, sroprietary, or safeguards information so that it can be places in the PDR wittout reduction. However, if you find it necessary to include such infomation, you should clearly indicate the specific infomation that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.

Dated at Atlanta, Geo ia this 29th day of 1996. .

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/ p * % *g. NUCLEAR REGULATDhY COMMISSION f REWON 11 g 191 MAfutTTA aTRET. N.W., Sun 1 NDO ATuMTA, OmnelA 30350188 U.S. NUCLEAR REGULATORY COMISSION REGION !!

Docket Nos: 50-335, 50 389 License Nos: DPR-67, NPF-16 Report No 50-335/96-04,50-389/9604 Licensee: Florida Power & Light Co.

Facility: St. Lucie Nuclear Plant, Units 1 & 2 Location: 9250 West Flagler Street Miami, FL 3?!02 Dates: February 18 March 30,1996 Inspector: Y A U 'N t.

/d H. Miller, Sr. Resid,ent InspecIBr Date Signed Accompanying Inspectors:

5. Sandin, Resident inspector H. Thomas, Reactor Inspector, paragraph H2 F. Wright, Reactor Inspector, paragraphs R1, R3, R5, R6, R7, and R8 R. Chcu, Reac' tor Inspector, paragraphs 1.2.1 through 1.2.4 E. Lea, Project Engineer, paragraphs 04.2, 04.4, M8.2, H8.3, and M8.4

. . J. Coley, Reactor Inspector, paragraphs M1.2.5 through 1.2.10 and M3.2 J. Hoorman, Liceuse Examiner, paragraphs 04.3 Approved by: 29 4 K. Landis, Brartch Chief Date Si'gned Division of Reactor Projects d

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EXECUTIVE

SUMMARY

St. Lucie Nuclear Plant. Units 1 & 2 NRC Inspection Report 50-335/96-04, 50-389/96-04 This integrated inspection included aspects of licensee operations, maintenance, and plant support. The report covers a 6-week period of resident inspectiont in addition, it includes input from regional inspectors in the areas of Maintenance and Plant Support.

Onorations , ,

Operators performed well during a Unit 1 dropped CEA event on February

22. Response to the transient, declaration of an Unusual Event, and a manual reactor trip (inserted when feedwater anomalies were identified) were all timely and appropriate.

On March 4, while a Unit 1 MTC test was being conducted CEA #1 was declared inoperable during installation and removal of test equipment with no Equipment Out-Of-Service Log entry made (NCV 50-335/96-04-08,

" Failure to Log an 005 CEA in the Equipment Out-0f-Service Log").

The return to power of Unit I was complicated by an attempt to synchronize to th'e grid with the main generator disconnects open. An inadequate procedure was the root cause (NCV 50-335/96-04-07,

" Inadequate procedure leads to switchyard misalignment".

Walkdowns of both units' Containment Spray systems resulted in the identification of a number of procedural, drawing and hardware deficiencies. Based on the number of deficiencies identified the inspectors expanded the scope of the detailed walkdowns to include the intake Cooling Water System of both units. At the close of the inspection period the reviews were not complete. The issue will be tracked as an unresolved item (URI 96-04-05, " Configuration Control Management").

Control room observations resulted in the identification of:

a failure to employ a procedure for boric acid addition (an additional example of a previous violation - VIO 96-03-01)

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failures to make required log entries for reactivity manipulations and a main generator hydrogen addition (VIO 96-04-02)

A containment gaseous / particulate / iodine monitor was rendered inoperable due to a failure to follow procedures, combined with a lack of proper follow through on the part of non-licensed operators taking logs (VIO 96-04-01).

An Emergency Diesel Generator was rendered inoperable due to a failure to follow procedures while placing the fuel oil tank on recirculation (VIO 96-04-03).

The requalification program is supporting management expectations for operations and covering timely and important topics.

2 The Unit 1 TS 3.6.2.2.a and the UFSAR Table 6.2-22 is inconsistent with respect to NaOH concentration. Pending further NRC review, failure to update the UFSAR is aa unresolved item (URI 50-335,389/96-04-09, Failure to Update UFSAR).

tiaintenance The procedures used for testing and maintenance on a number of observed maintenance ictivities were adequate to provide the details for the craft to perform maintenance, inspection, and calibration. The crafts were knowledgeable and skillful in doing work. The inspectors were satisfied with the work performed. However, one weakness was observed for a crew not signing and dating the working copy of the ' fork Order in the field prior to physically starting work.

A review of maintenar:ce procedure revision control indicated that the licensee's program contained vulnerabilities which could result in the wrong revision to a given procedure being used in the field. The licensee's corrective actions were satisfactory.

The Lack of a preapproved structured troubleshooting plan for a CEA problem, especially considering the short TS A0T involved, was considered a weakness.

There were weaknesses noted in the licensee's maintenance program relative to the SBCS valves and MFRV.

Reviews of historical data for CEA maintenance revealed that post-modification testing acceptance criteria for Unit 1 CEA power cables were not applied to post-modification test data (VIO 96-04-04).

Closecut of an Unresolved Item concerning poor HP work practices exhibited by maintenance personnel resulted in a non-cited violation for failure to adhere to Radiation Work Permit requirements (NCV 96-04-05)

Enoineering The engineering disposition for a deficiency identified in Unit 1 Boroflex panel length was reviewed and found to be satisfactn P1 ant Support Based on interviews with licensee staff, record reviews, and observations made during tours of licensee facilities; the inspector found the RP program to be adequately managed and internal and external exposure control programs were effectively implemented with all radiation exposures within 10 CFR Part 20 limits. One non-cited violation was identified concerning failure to follow procedures for the control of contaminated tools utilized in the licensee's radiological control area (NCV 96-04-06).

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3 The permanent modifications for cooling Unit 2 Containment Building in 1995 was a positive step in increasing worker efficiency and redec< ng collective outage dose and number of personnel contamination events.

The modification demonstrated managements commitment to worker safety, RP and ALARA.

Unplanned maintenance activities and rework significantly increased outage work in 1995 and was the primary reason the licensee exceeded its 1995 annual collective dose goal of 283 person-ren by approximately 129 person-rom.

This was basically a maintenance and' operations problem adversely impacting the station ALARA program.

44 IV. Plant Suonort R1 Radiological Protection and Chemistry (RP&C) Controls (83750)

Rl.1 External and Internal Exoosure Controls This program area was reviewed to evaluate the adequacy of licensee RP controls for internal and external radiation hazards and to verify individual Subpart C, radiation of 10 CFRdoses did not exceed the dose limits described in Part 20.

Selected elements of the licensee's personnel exposure control program were reviewed. Based on direct observation, review of records and discussions with licensee personnel the inspectors noted the following:

Reviewed RWP's provided adequate RP instructions and controls; Personnel monitoring equipment was utilized appropriately; Locked high radiation areas were properly posted and secured; and

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Process and engineering controls to limit exposures to airborne radioactivity were considered and utilized when possible.

The licensee reported the following maximum doses (Rems) for individuals in calendar year 1995 and 1996 to date:

Year TEDE Skin Extremity Lens-Eye 1995 2.263 2.452 2.452 2.263 1996 0.254 0.258 0.258 0.254 Part 20 Limits:

5.000 50.000 50.000 15.000 Adm. Limits:

Site 2.500 25.000 25.000 7.500 Total 4.500 45.000 45.000 13.500 1996 data through February 26. 1996.

In 1995, the highest individual CDE dose assigned was 287 mrem and the highest CEDE dose assigned was 33 mrem. No individual internal exposures had been identified at the time of the inspection for 1996.

All external and internal exposures were well within the regulatory limits.

The licensee has applied for NVLAP certification of its electronic dosimeter program. The licensee has completed performance testing in

45 categories !!, IV, and VI.b. and passed in categories IV and VI.b. The licensee did not plan to re-test in category !!, an accident category since the licensee did not plan to use the electronic dosimeters as the primary dosimeter for emergency response. The licensee had already receive? its on site review and expected certification of the electronic dosimetry program in 1996. The licensee has been conducting parallel testing of TLDs and electronic dosimeters for approximately two years.

The licensee expets to keep the TLD as the dose of record, at this time. The licent.se planned to continue using TLDs for special monitoring conditions such as high beta dose component fields or neutron fields. The on-going work in obtaining accreditation of the FPL electronic dosimetry program was identified as a good example of the health physics program technical capabilities.

Thrdugh review of licensee procedures and reported dose information, the inspector concluded the licensee was implementing adequate RP controls and monitoring individual occupational radiation exposures in accordance with the requirements and that 11 individual doses reported were within 10 CFR Part 20 limits.

No violations or deviations were identified.

R3 RP&C Procedures and Documentation (83750)

R3.1 Control of Radioactive Materials and Contamination. Surveys and Monitorina This area was reviewed to evaluate the licensee's control of radioactive and contaminated material.

St. Lucie TS 6.8.1 required written procedures be established, implemerited and maintained covering the activities recommended in Appendix A of RG 1.33 Rev 2, dated February 1978. RG 1.33, Appendix A,

_ 1978, required written procedures for contamination control.

The inspector reviewed the licensee's procedures for the control of tools within the licensee's RCA. St Lucie HPP- 41, Rev 1, " Movement of Material and Equipment," dated September 29, 1994, described the licensee's procedures for positive control of materials and equipment located in and leaving the RCA. Section 7.5 of HPP-41 addressed the use of tools and equipment in the RCA. Step 7.5.2 stated " Paint contaminated tools and equipment designated for use in the RCA with purple paint." Step 7.5.3 stated, in part, "Unless otherwise authorized, use only

hose tools that meet the following criteria for fixed and removable radioactivity:

Beta-Gamma < 10 mrem /hr Fixed and

< 1,000 dpm/100 cm2 Removable."

During a tour of the licensee's RCA the inspector noticed maintenance workers working on some equipment in the Hot Tool Room. The inspector

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46 inquired about the workers activities and learned the equipment was not from any contaminated system. While there, the inspector observed several maintenance workers searching for various tools and observed one worker returning tools to the storage cabinets. The worker returning tools reported the tools had not been used. The inspector noted.the Hot Tool Room was a self-serve facility and that there appeared to be little control of materials or tools entering or leaving the room. Many workers left the tool room without the tools they had bean looking for and the inspector noted some of the tool bins were empty.

The inspector made independent radiation and contamination surveys of the items stored there. During the survey the inspector found numarous tools that were not painted with purple paint and 2 tools exceeding the contamination levels for such tools. One tool having approximately 14 mrem /hr beta gamma exceed the fixed beta gamma contamination limit of 10 mrem /hrandanothersetofjac}ingboltshavingcontaminationlevelsof approximately1,500dpm/lp0cm exceeded the removable contamination l

limit of 1,000 dpm/100 cm . The inspector identified the tools to a health physics technician and they were promptly removed from the Hot Tool Room for decontamination. The inspector stated that failure to paint tools utilized in the RCA with purple paint and failure to control tools having radiatien levels in excess of licensee procedure limits appeared to be violations of licensee procedure requirements. The finding constitutes a violation of minor significance and is being treated as a NCV, consistent with Section IV of the NRC Enforcement Policy.

NCV 50-335,389/96-04-06: Viole. tion of TS 6.8.1 requirements for failure to follow contamination control procedures for the control and use of contaminated tools in the RCA.

In order to provide better control of these tools, licensee representatives reported that there would be a worker assigned to the Hot Tool Room for half a day on day shifts and the tool room would be locked at all ether tines.

The inspector clso requested and observed surveys of selected tools in the licensee's Cleen Tool 90nm. No contaminated tools were found during those surveys.

The inspector toured the yard and individual buildings in the p2 and !

noted that there appeared to be more contaminated material stared within the RCA than the inspector had observed at the site on previous RP inspections. The inspector determined that some of the additional material was material that had not been decontaminated following the 1995 outages. The problems with the Hot Tool Room and the amount of contaminated material accumulating around the site appeared to be the relatert to the significant cuts in the numbers of utility workers on site during and following the mo;t recent outages. The inspector reported te licensee management that continued attention was needed to reduce the amount of radioactive material and contaminated material the licensee had stored ir. yard and warehouses, t.icensee representatives

47 l

reported temporary personnel would be hired during the next few months to reduce the backlog of contaminated material.

1 Houdekeeping in the Auxiliary Buildings was generally good. However I process areas such as the decontamination facility and quinnent storage areas such as the one near the Unit 1 personnel access hatc) were )

i cluttered and untidy. No uncontrolled containers of radioactive material or contamination were idsntified.

At the time oT the inspection the licensee reportbd there were only 250 fta of contaminated included 106,063 ft, area in the licensee's decontamination plan, which The plan excluded the containment Buildings and certain process areas such as the decontamination facility. The 250 ft 2 was the lowest level obtained by the licensee in recent years. l The inspector reviewed documentation of selected PCEs and annual PCE ;

trends. The inspector noted that the licensee had approximately 83 "CEs l in 1995 which exceed the goal of 50 PCEs. The number of outage days in 1995, approximately 170, was the primary reason the licensee had exceeded this goal. The licensee actually had fewer PCEs in 1995 than in 1994. The lice.nsee had 95 PCEs in 1994 with 9pproximately 104 outage days. The licensee documanted PCEs at a threshold of 100 cpm above background, measured with a thin window GM detector. The inspector noted the licensee surveyed the walkways in the Auxiliary Buildings daily with large swipes which helped in reducing the number of PCE occurring in clean areas. No r:oncerns with PCEs were identified during the inspection.

The inspector observed several empty drums in the RCA and inquired about the licensee's procedures for releasing empty drums having once contained hazardous material or used oil. The inspector learned that drums containing a hazardous material and radioactive contamination were not released and were stored within the RCA. Fifty-five gallon drum' of hazardous material free of radioactive contamination and exiting the RCA were stored on a special pad on the secondary side of the facility. '

used oil leaving the RCA which could have been exposed to radioactive contamination was sampled and analyzed for uncontrolled release.

The inspector determined that used oil from the site was collected in a holding tank for offsite processing. The inspector also learned that the licensee had processors for separating water from uil which were located on the seccndary side of the facility in the Turbine Buildings.

The separated oil from an oil and water mixture was transferred to the oil holding tank and the separated water was released to the yard drainage system which emptied into evaporation / percolation ponds located within the protected area.

The inspector noted that the east pond was posted with signs displaying a radiation symbol and the words: " Restricted Area Keepout" and

" Radioactive Materials Area." The inspector determined that the east pond had received some contaminated water from a spill in 1977. The ,

inspector learned that in 1992 the licensee had sampled and evaluated

1, 48 the soil from the pond bem and bottom. At that time, detectable radioactive contamination was observed at various depths of 1-6 feet with the activity decreasing with depth. The most significant level of contamination detected was in the first three feet of sediment below the pond with radioactive concentrations of 1.5E-6 micro-C1/g of Cs-117 and 2.4 E-6 micro-C1/g of Co-60. Licensee representatives reported that the water was currently free of measurable contamination. The inspector observed several species of fowl utilizing the pond during the inspection. No concerns with the removal of drums from the primary to 1

secondary side of the facility were identified.

One NCV and no deviations were identified.

R5 staff Training and Qualification in RP&C (83750)

R5.1 Trainina This area was reviewed to verify that site health physics technicians '

were receiving continuing training.

Through interviews with licensee: personnel, review of licensee training documents and training records the inspector determined that the licensee was providing continuing training for health physics technicians. The licensee provided approximately 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months of continuing training for health physics technicians in 1995 and expected to provide approximately that amount in 1996. However, the licensee had not developed a schedule for proposed training. The inspector noted the 1995 training provided was appropriate for continuing health physics technician training. The inspector determined the technicians generally found the quality of the training good and useful for their responsibilities.

No violations or deviations were identified.

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R6 RP&C Organization and Administration (83750)

R6.1 Occupation Radiation Exoosure Control Prooram Chances Changes in the RP program, since.the last inspection, were reviewed to assess their impact on the effective implementation of the RP program.

The. inspection focused on changes in organization, personnel, facilities, equipment, programs, and procedures. The previous RP inspection was conducted during the period of May 30 t1 rough June 2, 1995. With the exception of organizational changes described below the licensee had not made any significant changes in the RP program.

The site health physics department lost several positions in down-sizing activities in February 1996. The number of site senior health physics technicians was reduced from 32 to 30 and 2 health physics supervisor positions were also eliminated. The most significant change in numbers of staff reductions was the decline in decontamination workers from 22 to 12.

49 The rasponsibilities held by the Special Projvet Material Condition Supgrvisor and Instrumentation Supervisor were temporarily transferred to the ALARA Supervisor and the Radioactive Waste Supervisor respectively. The inspector did not identify any concerns with the licensee's changes in organization structure or in the qualifications of personnel receiving new program responsibilities. While the loss of the two supervisors reduced collective staff expertise it did not appear that tae changes would adversely affect the licensee's pro control of radiation exposures and radioactive materials. grams for -

No concerns were identified with the reductions in the number of health physics technicians. The decontamination workers reductions did appear to have a negative impact on the quantity of contaminated material the licensee had stored around the facility (Paragraph R3.1 .

violations of regulatory requirements concerning the con) trol ofHowever, no radioactive material were identified during the inspection.

The organizatit.. chain of command structure from the site Health Physics Supervisor to the Operations Manager to the Plant General Manager had not changed. However, recent changes in personnel were made for the Operations Manager and the Plant General Manager positions.

There were also decreases in the number of vendor personnel supporting site health physics activities in 1995. The number of senior health physics technicians decreased from 69 in 1994 to 51 in 1995. Other decreases from 1994 levels to those in 1995 included: junior health physics technicians from 41 to 18; dosimetry technicians from 16 to 13; and decontamination personnel from 53 to 44. Additional decreases in the numbers of vendor support personnel during outages were not expected in 1996. However, the licensee plinned to britig in the personnel as needed and did not plan to use the personnel throughout the entire outage.

No violations or deviations were identified.

R7 Quality Assurance in RP&C Activities (83750)

R7.1 Audits Audits of RP activities were reviewed to determine the adequacy of the licensee's identification and corrective action programs for deficiencies or weaknesses related to the control of radiation or radioactive material.

The inspector reviewed the licensee's 1995 and 1996 audits of RP program activities. Reviews of RP activities during this period were limited to several performance monitoring activities which the licensee referred to as PHONS. Five PHONS were conducted in the RP area in 1995 and two were on-going during the inspection for 1996. The inspector also reviewed the checklist and auditor notes for each of the 1995 PMONs. One finding requiring corrective actions was identified in the five PHONS and the inspector verified it's corrective actions were proceeding.

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The inspector determined that the licensee was reviewing the RP program and tracking auilt findings for correction. No concerns with the licensee's audit program, findings or corrective actions were identified.

No violations or daviations were identified.

R8 Miscellaneous RP&C !ssues (83750)

R8.1 Maintainitto occunational Ernosures ALARA '

This program area was reviewed to determine the status and effectiveness of Al. ARA program initiatives in reducing collectwe dose for the site.

Areas reviewed included site annual and outage go.ls and objectives, and the collective dose results.

A sumary of recent collective dose and gonis for the site is shown behw.

Collective Personnel E,_xposures (Person-Rem)

Annual Doso I Dutage Dose Actual Goal Title Actual Goal Days 1993 460 477 'J2-SNO 71 -

77 Ul-RF0 387 444 61 Ul-SNO 55 -

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1994 505 600 U2-RF0 168 187 71 ,

Ul-RF0 290 361 33

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1995 412 283 Ul-SNO 18 -

8 Ul-SN0 41 -

80 U2-RF0 311 172 83 1996 7 356 Ul-RF0 - - -

Notes:

The 1996 dose information was measured with electronic dosimeters and was current through February 26.

The 1996 Ul-RF0 outage goals had not been issued.

Unplanned outages, maintenance activities and re-work were the primary reasons the licensee exceeded the 1995 annual collective dose goal of 283 person-rem by approximately 129. person-rem. This was basically a maintenance and operations problem which significantly and adversely

51 impacted the station ALARA program. The duration of the U2 PJO was expected to be 53 days and actually lasted approximately 83 days due to expand 6d work scope and rework. The licensee also had an extended outage on U1 of approximately 80 days. Even with the increased work load, the 1995 annual collective dose was the lowest since 1992 when the licensee had 245 person-rem.

The site collective dose goal for 1996 had just been approved by plant management. The ALARA staff had identified four possible site collective dose goals for management consideration. The goals considered such factors as industry averages and historical performance.

Upper management selected the most challenging one at 356 person-rem.

The licensee had just started a new ALARA Han-Rem Budget program similar to one utilized at Turkey Point. At the time of the inspection the plan had just been approved and little use of the system had been made. The plan assigned a dose budget for each department and the departments were required to complete as igned responsibilities without exceeding their allotted dose budget. An element of the plan permitted departments to borrow dose from one another as needed. The licensee expects the implementation of the process to result in increased involvement of the St. Lucie staff in dose reduction solutions.

The licensee completed a permanent modification on U2 Containment Building in 1995 which provided air conditioning to the building during outages. The licensee planned to make the same modification on 01 during the 1996 RF0 scheduled for Spring 1996. The licensee had found that air conditioning had generally increased worker efficiency and safety and had resulted in fewer PCEs from leaching protective clothing.

The air conditioning modification was an example of licensee management's support for personnel safety, RP and ALARA programs.

The inspector also learned the licensee had started preliminary preparations for a VI SG replacement project scheduled for January in 1998.

Based on direct observation, discussion and review of records the inspector concluded the licensee was utilizing Al ARA techniques and making progress in reducing collective doses for the staff. However, the recent failure to meet 1995 annual collective dose goal indicated additional attention to reduce collective doses during outages was needed.

No violations or deviations were identified.

P4 Staff Knowledge and Performance in EP (71750)

On January 22, at approximately 7:45 p.m., Unit 2 began a downpower from 100 percent to 90 percent in preparation for turbine valve testing.

During the downpower, I&C was changing a FC (Fleld Contact) - 250 power supply .or annunciator housing #1, in the annunciator logic cabinet. At appro.:imately 8:20 p.m., annunciator panels H (Reactor Coolant System),

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A.

Vis! TING INSPECTORS INPUT TO RESIDENT INSPECTION REPORT Plant Inspected: 5t Lucie Units 1 and 2 Report Nos.

50-335/96-09 and 50-389/96 09 Plant support: OccupationalRadiationExposure(83750)

Inspector M/

r. r. wr # t M eranch Chief Co Jncur once: x, g, ,,,,

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B. IV. Plant Suncort R1 Radiological Protection and Chemistry (RP&C) Controls RI.3 Occupational Radiation Internal and External Exposure Control (83750) i

a. Inspection Scone The inspectors reviewed the 1ersonnel exposure records to verify radiation exposures were wit 11n regulatory limits and the licensee was implementing proper internal and external exposure control measures,

b. ObservationsandFinding1 The inspectors found all internal and external personnel exposures were below regulatory limits. Tours of the Radiation Control Areas (RCAs) were made to verify that radiological areas were prcperly posted and controlled. Locked high radiation areas were found properly secured.

The inspectors reviewed select licensee radiation surveys and made independent radiation surveys in those areas to verify radiological conditions were properly identified and posted.

The inspectors observed good use of engineering controls and work processes to control airborne radioactive contamination.

c. Conclusions in general, the licensee appeared to be implementing effective radiological controls to minimize personnel exposures to internal and external radiation sources. No concerns with +ke licensee's internal or external exposure control programs were identified.

Rl.5 Control of Radioactive Materials and Contamination (837501

~

e. Inspection Scope The inspectors reviewed licensee procedures for control of contaminated tools, discussed controls with tool room staff and radiation protection personnel, reviewed licensee radiation surveys of tool rooms, and made independent radiation surveys is, tool rooms.

HP 2,'"Florica Power and Light (FPL) Health Physics Manual," Rev.10, Dated August 24, 1995, described the radiation protection program at FPL's nuclear power plants. The FPL contamination guidelines were summarized in Table 4.2, " Contamination Guidelines."

Tne licensee's contamination limits for materials, tools, equipment and solid waste unconditionally released from the RCA were:

_ = .

_ = =

8 1,000 dpa/100 cm for locse beta and gama contamination and

) 5,000 dps/100 cm8 for fixed beta and gama contamination (direct t

measurement)

The licenseo's contamination limits for tools and equipment used in the RCA were:

8 1,000 dpm/100 cm for loose beta and gamma contamination and 10 mrem /hr for fixed beta and gamma contamination

b. Observations and Findinos The inspectors noted that the licensee had made some positive changes in tool controls since the previous inspection. The inspectors observed the hot tool room located in the Unit 1 Reactor Auxiliary Building (RAB) was manned during the inspection and secured when unattended.

Additionally, the licensee had combined two clean tool rooms located outside the RCA and the licensee was improving tool tracking and inventory capabilities. The licensee was also able to obtain enough temporary tool room personnel to staff tool rooms at all times during I

the .neak outage period.

The licensse planned to reduce the total number of issued tools. A backlog of contaminated tools from previous outages had accumulated in storage locations within the RCA. Staff reductions in decontamination personnel had resulted in decreased tool decontamination efforts and increased levels of contaminated tools in storage.

As permitted by licensee procedures, some tools were designated for use within the RCA and were referred to as hot tools. The hot tools had specific contamination limits which were greater than unconditional release limits. These tools were identifiable with purple paint. The inspectors toured shops and warehouses and examined vehicles and " gang boxes" outside the RCA for hot tools. No hot tools were found outside the RCA. The inspectors also made radiation and contamination surveys in clean and hot tool rooms. No tools exceeding limits for clean or hot tools were identified by the inspectors.

In discussions with tool room personnel, the inspectors found many were unaware of the specific radiation and contamination limits for clean or hot tools. The temporary tool coom personnel were generally less knowledgeable of the tool contamination limits. However, tool room personnel were not responsible for determining contamination levels of tools.

The inspectors reviewed routine and special su*veys of licensee tool rooms. The licensee spent approximately 162 hours0.00188 days 0.045 hours 2.678571e-4 weeks 6.1641e-5 months surveying tools during the period of June 13-16, 1996. The announced radiation protection inspection began June 17, 1996. The licensee also spent another 116 hours0.00134 days 0.0322 hours 1.917989e-4 weeks 4.4138e-5 months surveying tool rooms during the first three days of the inspection (June 17-19,1996). The licensee's survey efforts in

1

, tool rooms during this seven day period were significant and not typical

, of routine monitoring.

1 During the licensee's surveys numerous tools were found outside the RCA having contamination levels in excess of the limits for use in clean

. areas. The licensee also identified numerous tools for use in the RCA having contamination limits in excess of the limits for hot tools.

The licensee's tool room surveys during the period of June 13-19, 1996, identified the following examples where contaminated tools were found-outside'tl. RCA:

On June 18, 1996 HPTs removed 12 M&TE tools from the licensee's cleantoolroomhgvingcontaminationlevelsuptoapproximately 12,500dpm/100cm (250 net counts per minute / probe). j On June 19, 1996 s from the licensee's clean tool room having contaminationHPTsremovedfiveriggings approximately 40,000 to 600,000 dpm/100 cm 8 (8.000 to 120,000 '

4 dpm/ probe).

The licensee's tool room surveys during the period of June 13 19, 1996, identified the following examples where tools were found within the RCA having contamination levels in excess of the licensee's contamination ,

limits for hot tools:

On June 13, 1996 HPTs removed nine tools from a temporary hot tool room having loose contamination levels from approximately 1,000 to 20,000-dpm/100 cm2 .

On June 14, 1996 HPTs removed five wrenches, from the Unit I hot tool room having loose contamination in the range of 1,000 to 4,000 dpm/100 cm'. .

On June 16, 1996, HPTs removed numerous tools from a temporary hot tool room having loose contamination levels from approximately 1,000 to 30,000-dpm/100 cm',

On June 16, 1996, HPTs removed numerous tools (licensee identified as two bags), from the Unit I hot tool room having loose contaminatlon in the range of 1,000 to 120,000 dpm/100 cm'.

In the February- 1996, radiatioli protection pr9 gram ins'pection the inspectors found a few contaminated tools in the hot tool room that were '

slightly above the licensee's limits, in response to the inspector's findings. the licensee secured the hot tool room when unattended for better control. - A Non Cited Violation (NCV) concerning the control of 4 contaminated tools was identified at that time. The licensee identified all of the recent examples of tools having contamination levels in er ess of the licensee's contaminated limits. However, these were additional examples of tools having contamination in excess of i contamination limits previously identified by the inspectors in the February 1996, radiation protection inspection. Corrective measures 4

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i l implemented by the licensee following the NCV were inadequate to prevent the additional violations identified in the recent and extensive tool L _ room surveys. The failure to control contaminated tools in accordance i with licensee procedures is identified as a violation (VIO 50 335/96 09-01, " Failure to Control Contaminated Tools in Accordance i with Licensee Procedures"). The licensee opened a condition report for the purpose of identifying the cause of the contaminated tool violations and to cause appropriate corrective actions.

1 During tours of the licensee's facilities the inspectors found

' houseneeping was generally good. However, numerous drums containing low-level contardnation were still stored in the yard area within the RCA l that were exposed to environmental conditions and could present problems durke severe winds. l

c. C3nclusions While the licensee was making progress in achieving controls for tools in general, the licensee's controls had not been effective in preventing contaminated tools from leaving the RCA or ensuring' tools for use inside the RCA had contamination levels below the licensee s contamination limits.

RI.6 Maintainino Occupational Exposure ALARA (81750)

a. Inspection ScoDe The inspectors reviewed the status of the licensee's collective dose for 1996 and the-implementation of the person-rem budget program,

b. Observations and findinas The inspectors attended an ALARA Review Board meeting held during.the inspection. During the meeting, the inspectors noted the new ALARA dose budget program appeared to have strong management support and to have directly involved site department managers in the dose reduction process. Department managers were accountable for collective doses and required to take corrective actions to minimize collective dose for their departments. Managers were encouraged to utilize the corrective action program to capture succqssful activities into procedures and to document unsuccessful activities for approprute corrective actions.

The collective doses for specific work activities were reviewed with ALARA personnel and the inspector inquired about specific tasks exceeding expected collective dose. The effects of recent staff reductions on site collective dose were also discussed with licensee personnel. Recent staff reductions had resulted in additional temporary and less experience personnel performing.certain activities including shielding, insulation removal and decontamination during outages. It appared that the use of temporary and less experienced personnel could reduce efficiency and therefore increase collective doses. The licensee had not-quantified collective dose differences of experienced versus less experienced laborers for task and the inspector was unable to -

measure the impact = that temporary personnel were having on collective

l dose. However, no significant collective dose problems were identified during the inspector's reviews.

The licensee's 1996 annual collective dose goal of 326 person rem was based on routine Re Fueling Outage (RFO) activities and was one of the' most challenging for the site. However, the work scope expansion for the Unit 1 Steam Generators (SGs) was significant enough to threaten achievement of the 1996 goal. The licensee had approximately 297 person rem through June 19, 1996.

c. Conclusions Management support for the ALARA program was good with increased management involvement in dose reduction activities. The dose budget program has increicsed site participation in reducing collective dose.

Upper managements encouragement to document ALARA successes and failures in the corrective action program indicate understanding and willingness to implement quality control processes in ALARA activities. The unexpected SG work had significantly impacted the licensee's ability to achieve the challenging 1996 collective dose gcals.

R5 Staff Training and Qualification in Radiation Protection und Chemistry (83750)

a. ]Mptf tion Scope Thn inspectors reviewed the qualifications of certain site and vendor HPTs on site for the Unit 1 RFO. Licensee Technical Specificatiors 6.3.1 required that staff exceed the minimum qualification requireaents specified in ANSI /ANS-3.1 1978, "American National Standard for Selection and Training of Nuclear Power Plant Personnel."

b. Qhservations and Findinas The inspectors requested a review of vendor HPT resumes for technicians working in the on going Unit 1 RFO. The inspectors also reviewed the qualifications of all site HPTs having lesr. than five years of experience in FPL radiation protection programs.

The inspectors were able to review experience records for a portion of vendor HPTs hired for the on going RFO. Vendor HPT resumes were reviewed by the licensee to determine experience levels for meeting ANSI qualification requirements,

c. Conclusions The inspectors determined that the licensee had not lowered qualification requirements for site.and vendor HPTs. All site and vendor HPTs qualification records reviewed by the inspectors documented compliance with the app 1 k able qualification requirements. No violations or deviations were identified.

C. Exit Meeting Summary The inspectors presented.the inspection results to members of the ,

licensee management at the conclusion of the inspection on June 21, 1996. The licensee acknowledged the findings presented.

The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

D. PARTIAL LIST OF PERSONS CONTACTED Licensee Buchanan, H., Health Physics Supervisor

McCullers, R., Health Physics Operations. Supervisor 11 %

Miller, M., Senior Resident Inspector

Attended June 21, 1996 Exit Meeting E. INSPECTION PROCEDURES USED IP 83750: Occupational Radiation Exposure F. ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-335, 389/96 09 01 VIO: Failure to Control Contaminated Tools In Accordance With Licensee Procedures.

Closed NA Discussed NA .

G. Conclusion / Assessment Plant Support The radiation protection program was adequately managed and internal and external exposure control programs were effectively implemented with all radiation exposures within 10 CFR Part 20 limits. (Paragraph R1.3)

~ -

m- 7

A Violation, 50-335, 389/96 09 01, was identified concerning failure to follow procedures for the control of contaminated tools.- (Paragraph -

RI.S)

Tours of licensee facilities showed generally good radiological housekeeping and controls. (Paragraph RI.5)

Increased management involvement in Al. ARA efforts were observed during the inspection. (Paragraph RI.6)

I O

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, 4_ ,

/

1. NOTICE OF VIOLATION l Florida Power and Light Company- ' Docket Nos. 50-335, 50-389 St. Lucie 1- Licanse Nos. DPR 67, hPF-16 During an NF.C inspection conducted on June 17 through June 21,14f; violations of NRC requirements were identified. In accordance wi:h me

" General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violation is listed below:

Technical Specification 6.8.1.a requires that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Rev.-2, February, 1978. Appendix A, paragraph 1.d includes administrative procedures for procedural adherence. QI 5 PR/PSL-1,-Rev 68, " Preparation, Revision R& view / Approval of Procedures,"

Section 5.13.li states that all procedures shall be strictly adhered to.

HP-2, Florida Power and Light (FPL) Health Physics Manual, Rey, 10, describes the radiation protection program at FPL's nuclear power plants. The licensee's contamination guidelines are summarized in Table 4.2,

" Contamination Guidelines," of the manual. The following contamination limits are described in Table 4.2.

The licensee's contamination limits for materials, tools, equipment and solid waste unconditionally released from the Radiation Control Area (RCA) are:

2 1,000 dpm/100 cm for loose beta and gamma contamination and 5,000 dpm/100 cm' for fixed beta and gamma contr'ination (direct measurement)

The licensee's contamination limits-for tools and' equipment used in the RCA are:-

2 1,000 dpm/100 cm for loose beta and gamma contamination and 10 mrem /hr for fixed beta and gamma contamination Con a ry to the above:

. 1. - On June 18 and 19, 1996,' licensee HPTs found contaminated tools outside the RCA having contamination levels greater than the unconditional release limits.

On June 18 1996, HPTs remow ' 12 M&TE tools from the clean tool room having contamination 2

levels up to approximately 12,500 dpm/100 cm (250 net counts per minute / probe).

)

I On June 19, 1996, HPTs removed five rigging slings from the licensee's clean tool room having contamination levels from 2

approximately 40,000 to 600,000 dpm/100 cm (8,000 to 120,000 dpc/ probe).

2. On June 13, 14, and 16, 1996, HPTs found tools in the RCA having contamination levels greater than the limits for tools and equipment utilized in the RCA.

On June 13, 1996, HPTs removed nine tools from a temporary hot tool room having loose contamination levels from approximately 1,000 to 20,000 dpm/100 cm'.

On June 14, 1996, H?Ts removed five wrenches from the Unit I hot tool room having loose contamination in the range of 1,000 to 4,000 dpm/100 cm2 .

On June 16, 1996, HPTs removed numerous tuols from a temporary hot tool room having loose contamination in the range of 1,000 to 30,000 dpm/100 cm2 .

On June 16, 1996, HPTs removed numerous (two bags) of tools, from the Unit I hot tool room having loose contamination in the range of 1,000 to 120,000 dpm/100 cm2 ,

This is a Severity Level IV violation (Supplement IV).

Pursuant to the provisions of 10 CFR 2.201, Florida Power and Li

, required to submit a written statement or explanation to the U.$ght is bereby

. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington. 0.C. 20555 with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector at the #acility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the

~ violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the torrective steps that will Le taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within 4

the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper shcald not be taken, Where good cause is shown, consideration will be given to extending the response time.

Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Because your response will be placed in the NRC Public Document room (POR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. However, if you find it necessary to include such information,

-4 , ;-

you should clearly indicate the specific information that you desire not to be placed in the POR.: and previde-the legal basis to support your request for

- withholding the information from the public.

Datsd at.

this day of :1996 m-e-i-

w

+ ,

i LIST OF ACRONYMS USED ALARA As low As Reasonably Achievable !

ANS American Nuclet.r Society i ANSI American National Standard Institute CFR Code Federal Regulations cm Centimeters cpm Counts Per Minute dpm Disintegration Per Minute FPL The Florida Power and Light Company FR Federal Register HP Health Physics-HPT Health Physics Technician IP Inspection Procedure mrem Milli Roentgen Equivalent Man M&TE Measuring and Test Equipment NCV Non-Cited Violation NRC Nuclear Regulatory Commission PSL -Plant St. Lucie QI Quality Instruction RAB Reactor Auxiliary Building RCA Radiation Control Area RF0 Re-Fueling Outage RP&C Radiological Protection and Chemistry SG Steam Generator TS Technical Specification VIO Violation J. Cover Letter Paragraph The contamination control violation described in the enclosed Notice is i similar to a violation described in the Inspection Report 50-335/96-04 and 50-l 389/96-04 sent to you by 'our letter dated April 29, 1996.- Recurring violations are of particular concern because the NRC expects licenseos to learn from their past failures and to take effective corrective actions.

Although NRC does not normally consider monetary civil penalties for Severity Level IV violations, .the Enforcement Policy states that such penalties may be

, imposed for Severity Level ;V violations that are similar to previous

violations for which the licensee did not take effective corrective action.

In this case, we have decided not to hold an enforcement-conference nor to propose a civil penalty because this is the first repeat associated w!th a violation of procedure compliance. 'In your response to the. enclosed Notice, you should document the specific actions taken and any additional actions you plan to prevent recurrence. We will review your response, including your i proposed corrective actions, and the results of future inspections to determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulator., requirements.

ML20202D837

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