ML20137L297

Forwards Matrix Containing Answer to Listed Questions in ,Rev 1

ML20137L297
Person / Time
Site:	Saint Lucie
Issue date:	03/31/1997
From:	Jerrica Johnson, Peebles T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Gibson A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML17354B293	List: IA-46-485, Advises That Changes in Rev 23 to Radiological Emergency Plan for St Lucie,Consistent W/Provisions of 10CFR50.54(q), 10CFR50.47(b),10CFR50 & App E to 10CFR50 IR 05000528/1996009 ML20137K471 ML20137K491 ML20137K574 ML20137K611 ML20137K664 ML20137K745 ML20137K761 ML20137K771 ML20137K803 ML20137K822 ML20137K864 ML20137K929 ML20137K935 ML20137K945 ML20137K966 ML20137K982 ML20137K991 ML20137L003 ML20137L009 ML20137L035 ML20137L055 ML20137L061 ML20137L085 ML20137L098 ML20137L150 ML20137L168 ML20137L209 ML20137L231 ML20137L237 ML20137L252 ML20137L275 ML20137L283 ML20137L297 ML20137L303 ML20137L307 ML20137L314 ML20137L322 ML20137L853 ML20137L880 ML20137L897 ML20137L934 ML20137L948 ML20137L961
References
FOIA-96-485 NUDOCS 9704070194
Download: ML20137L297 (38)

Text

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UNITED STATES e

f #p reso'**k NUCLEAR REGULATORY COMMISSION REGloN li S 101 MARIETTA STREET, N.W., SUITE 2900 j ATLANT/ . GEORGIA 303234199

+,

...../ M4R 3 i W MEMORANDUM FOR: Albert F. Gibson, Director Division of Reactor Safety Jon R. Johnson, Acting Director Division of Reactor Projects l FROM: Thomas A. Peebles, Chief i Operations Branch Division of Reactor Safety  !

SUBJECT:

SIEMENS FUEL QUESTIONS, PER MR.EBNETER MARCH 4, 1994* i I

REVISION 1 Mr. Ebneter had the following four questions in his letter. Curt Rapp compiled the information contained in the enclosed matrix, which is intended to answer the questions. Additionally, comments have been included for Robinson and St. Lucie facilities. <

l

1. Which plants use Seimens fuel in Region II?

2. How long have they been using Seimens?

3. What have these utilities done in the way of QA oversight of the vendors? '

4. What is the extent of problems wg are aware of--(Robinson, Crystal River, Harris, others)?

Thomas A. Peebles Enclos'ure:

Vendor Fuel Matrix  !

I cc w/ enc 1: I C. Rapp, DRS l

(

9 9704070194 970325 PDR FOIA BINDER 96-485 PDR

i f 1 I

ENCLOSURE '

VENDOR FUEL MATRIX Facility Reactor  !

Fuel Problems Oversight Cycle i Type Vendor length l Browns Ferry 1 BWR Browns Ferry 2 BWR  !

GE 18 Browns Ferry 3 BWR GE 18 Brunswick I BWR GE 14-18 Brunswick 2 BWR GE 14-18 Catawba 1 PWR B&W/W going to 24 Catawba 2 PWR B&W/W going to 24 Crystal River PWR B&W 24 Farley 1 PWR W (LIJV5) 20; going to 24 i sley 2 PWR W (LUV5) 20; going to 24 Grand Gulf BWR Seimens One bundle replaced 2 fuel Corporate fuels group 18 (since cycle pins elongated independently checks core i

2) cales On-line core monitoring l would identify problems SRI has not inspected this area l

Harris PWR W/ On-site receipt inspection Fuels group and NAD 18 Seimens-ist found several QA problems observe fabrication process load l Independent review of fuel design Detailed recipit inspection on-site Hatch i BWR GE 18 Hatch 2 lBWR GE 18 hicGuire i PWR B&W. about 18 36 months W

/

losure 2 Facility Reactor Fuel Problems Oversight Cycle Type Vendor length McGuire 2 PWR B&W-about

. 18 36 months W

) North Anna 1 PWR W 18 North Anna 2 PWR W 18 Oconee 1 PWR B&W 18 Oconee 2 PWR B&W 18 Oconee 3 PWR B&W 18 Robinson PWR Seimens Recent refueli,g found 4 Same as Harris several bundles with '

incorrectly located poison rods; resulted in significant core performance problem.

J Miscalculated initial N1 7

calibration constants; i  !

resulted in indicated power 10% below actual.

St. Lucie 1 PWR Seimens-> 5 SRI found grit in fusi Escalated vendor inspections fuel cycles bundle during receipt by QA and fuels group inspection included contractual Seimens failed to verify requirement for Seimens to fuel weights wii TS limits increase self-assessment i

I (1990)

St. Lucie 2 PWR CE Sequoyah 1 PWR W l 18; going to 24 Sequoyah 2 PWR W 18; going to 24 Summer PWR W 18 Surrv 1 PWR lW 18 I

'urry 2 PWR W 18 rkey Point 3 PWR lW 18

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.losure 3 i

I Facility Reactor Fuel Problems Oversight Cycle Type Vendor length Turkey Point 4 PWR W 18 Vogtle 1 PWR W 18 Vogtle 2 PWR W 18 Watts Bar PWR W 18 i

S l

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March 30c 1994 SURVEY FOR B&W OR SIEMENS FUEL USERS f

Facility Reactor Fuel Problems Oversight Cycle Type Vendor length Browns Ferry 1 BWR Browns Ferry 2 BWR GE 18 Browns Ferry 3 BWR GE 18 Brunswick ) BWR GE 14-18 Brunswick 2 BWR GE 14-18 Catawba 1 PWR B&W/W going to 24 Catawba 2 PWR B&W/W going to 24 Crystal River PWR B&W 24 Farley 1 PWR W 20; (LL/V5) going to 24 Farley 2 PWR W 20; (LL/V5) going to 24 Grand Gulf BWR Seimens One bundle Corporate fuels 18 (since replaced-2 fuel group ,

cycle 2) pins elongated independently l checks core cales 1 On-line core monitoring would identify problems SRI has not inspected this  !

area Harris PWR W/ On-site receipt Fuels group and 18 Seimens- inspection found NAD observe 1st load several QA fabrication problems process Independent review of fuel design Detailed recipit i inspection on- l site l Hatch 1 BWR GE 18 0 Hatch 2 BWR GE 18 i i

1 l l Facility Reactor Fuel Problems Oversight Cycle  !

Type Vendor length '

McGuire 1 PWR B&W-18 -

about 36 )

months McGuire 2 PWR B&W-18 about 36 months '

W l

~

North Anna 1 PWR W 18 l1 North Anna 2 PWR W 18 Oconee 1 PWR B&W 18 Oconee 2 PWR B&W 18 Oconee 3 PWR B&W 18 Robinson PWR Seimens Recent refueling Same as Harris found several bundles with incorrectly located poison rods; resulted in significant core performance problem. Also, miscalculated initial NI  :

calibration constants; l'

resulted in i

indicated power I 10% below '

actual.

St. Lucie 1 PWR Seimens- SRI found grit

> 5 fuel in fuel bundle cycles during receipt inspection:

St. Lucie 2 PWR CE Il l

Sequoyah 1 PWR W 18- l; going  ;

, to 24 I i

' 1 Sequoyah 2 PWR W 18;  ! '

going ,

to 24  !

! Summer PWR W 18

)

I Facility Reactor Fuel Problems Oversight Cycle !

Type Vendor length Surry 1 PWR W 18 Surry 2 PWR W 18 l l

Turkey Point 3 PWR W 18 Turkey Point 4 PWR W 18 Vogtle 1 PWR W 18 Vogtle 2 PWR W 18 4

Watts Bar PWR W 18 I l

l l

l l

l 1

l 1

l l

l f

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

Dt S o ry

. t X.X Procurement Engineering Qualification / Certification and

• Experience This portion of the inspection was conducted to evaluate the ,

qualification and experience of personnel currently assigned to the procurement engineering organization at St. Lucie. The organization is currently staffed with a supervisor and ten engineers and technicians, some of which are on temporary assignments. This evaluation was conducted by a review of i certification records and interviews with personnel within the group. Personnel in procurement engineering are required to .-

complete a certification program which is outlined in FPL Standard STD-PE-001, Rev. 4, Nuclear Engineering Standard Procurement Engineering Responsibility. The standard provides for a management i evaluation of personnel experience and training. This  !

certification process evaluates personnel in a blend of areas -

including industry standards (e.g. ASME Code, IEE standards, ANSI and ASTM Standards, EPRI standards, etc), reactor plant systems, .

St. Lucie technical specifications, corporate and site Quality Assurance Instructions, and all of the current guidance regarding the dedication of commercial grade materials. Most of the  ;

certification process is based on a combination of work experience l and self study in these areas. The inspectors determined that all of the personnel currently assigned to the group have technical college degrees except two materials analysts. One of these analysts has a non technical college degree, and extensive nuclear navy and industry experience in procurement engineering. The other individual has an associates degree from a technical school, and extensive industry experience in the procurement engineering l function. All of the individuals in the group have at least three years of experience in procurement engineering at St. Lucie, and other industry experience which establishes an adequate basis for their qualifications. Based on a review of certification records and interviews with these individuals, as well as, the technical review of their work discussed in para RANDY reference the Para on  ;

review of the oackaces, the inspectors concluded that the procurement engineering organization is appropriately staffed with i l

well qualified personnel.

X.X Material Identification, Storage and Control The inspectors conducted an inspection of material storage areas in accordance with the requirements of ANSI N45.???. This inspection included walkthroughs of warehouses 1, G-1 and G-2. The inspection

! included verification of the segregation of acceptable from l unacceptable materials, segregation of safety related materials from non-safety related materials, proper identification (tagging) and traceability, proper use of pipe caps, segregation of stainless steel from other materials, maintenance of cleanliness and

! environmental conditions, etc. In addition, issuance of material i

! from the issue station was observed and materials personnel were j

< interviewed concerning their responsibilities at the time of issue.

l Also, a sample of commercial grade materials dedicated for safety related applications, which required field dedication testing, were

reviewed to verify that the appropriate " dedication testing required" tags (applied to alert maintenance personnel that field testing is required prior to installation) had been applied at the time of receipt inspection and had been maintained during storage.

No deficiencies were observed by the inspectors during the warehouse walkthroughs.

X.X Problem Identification and Resolution RANDY WE NEED AN INTRODUCTORY PARAGRAPH X.X.1 STARS reviewed RANDY X.X.2 Supplier Deviation Notices Supplier Deviation Notices are used at St. Lucie to resolve vendor exceptions to contract / purchase order requirements prior to material shipment. As such, these notices serve as corrective action documents. The inspectors requested the licensee to provide a copy of all SDNs issued in the last two months in order to support a review for appropriateness of corrective actions. The following Supplier Deviation Notices were provided by the licensee and reviewed by the inspectors during the inspection:

SL-95-006-0 SL-95-033-5 SL-95-034-4 SL-95-034-5 SL-95-033-4* SL-95-033-5*

SL-95-027-4*

• Not resolved as of December 8,.1995.

The inspectors review of these SDNs determined that vendor exceptions were being appropriately dispositioned with the exception of SDN SL-95-034-5:

Upon receipt of purchase order 12173, the vendor advised St. Lucie site purchasing that the fuses to be supplied (stock codes 0199809-1 and 0036616-1) did not meet the purchase order requirements for over-current testing as specified, i.e. , testing of a sample of the fuses had determined that the fuses would not break the circuit in the required amount of time when subjected to 200% and 250% of the rated current. SDN SL-95-03 4 - 5 was written on November 21, 1995 to obtain a resolution to this vendor exception. The SDN was resolved on November 25, 1995, allowing the vendor to ship the fuses based on PE evaluations 040129 (for stock code 0036616-1) and 040130 (for stock code 0199809). Review of these evaluations and walkthrough of the material in warehouses 1 and G-2 revealed two problems which were presented to the licensee for resolution:

PE evaluation 040130 concluded that the fuses (stock code 0199809-1) were acceptable for non-safety related application, however, no action was taken to downgrade the material to the

i 5

3 licensee's non-safety Procurement Classification PC-3 or PC-4.

! As a' result,.the fuses were found in a ready for issue status

! in warehouse G-2 tagged with a safety related (PC-1) tag. The j

end use of these fuses was, however, specified as non-safety -

i in the Passport computer program, which would have prevented '

l their use in safety related equipment. The licensee took j action prior to the end of the inspection to downgrade and tag these fuses as PC-3 material. l

! - PE evaluation 040129 concluded that the vendor should ship the l fuses (stock code 0036616-1), and that further engineering l evaluation of the specific safety related application would be

[ required prior to installation in plant equipment. As a ,

j. result, the procurement engineer took action via a computer

[ message to place the fuses "on QC hold" upon receipt.  ;

j Investigation into this material by licensee personnel and the

inspector determined that the fuses had not been placed "on QC I

! hold" as directed by the PE evaluation, but had been received, i

! QC receipt inspected, and made ready for issue as safety  !

related (PC-1) material. Additionally, it was discovered that t j two of the fuses had been drawn, and installed in a non-safety j (main

~

! related application feedwater regulating valve

circuitry). Once this condition was discovered, the licensee j took action to place the fuses in stock "on hold pending PE i evaluation, " and issued STAR 952127 to identify the root cause

! of this problem and to document corrective actions. Further ,

! investigation of this problem by the licensee determined that l l the computer message to place the material "on QC hold" was l

! never transmitted to the QC receipt inspection group due to a

! computer (Passport) programming error. This programming error ,

! was generic to both the Turkey Point site and to the St. Lucie i j site. This error resulted in twenty three additional  ;

i potential problems at St. Lucie and seventeen potential ,

i problems at Turkey Point. The licensee took immediate action  ;

to correct the programming error, and investigate all forty potential problems at both sites. No additional material f deficiencies at either site were caused by this computer i programming error. The failure to follow engineering  :

! instructions to place safety related material "on QC hold" i pending further PE evaluation is identified as another example ,

5 of Violation 50-335,389/95-17, for Failure to Follow

Procedures for Proper Control of Safety Related Materials.

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X.X.3 Receipt Inspection Deficiency Reports l Receipt. I nt:, p c t i o n Deficiency Reports are used at St. Lucie to l resolve dgFi7iencies discovered during receipt inspection of materials by QC inspection. As such, these deficiency reports serve as corrective action documents. The inspectors requested the ,

licensee to provide a copy of all deficiency reports issued in the last two months in order to support a review for appropriateness of  ;

corrective actions. The following deficiency reports were provided by the licensee and reviewed by the inspectors during the inspection

_ .. . _._.___m_. . . - _ . . . - . _. _ . . _ - _ _ _ ._. . _ . . _ _ . ._

.- I j'  !

)

D0030404 D0032240 D0035584 D0034715 .

,' D0034107 D0033907 D0036609 D0037769 I D0036163 D0037771 D0037601 D0037398

} D0037720 D0029153 D0037668 D4348432  ;

i D0031742 D4348411 D4348433 D4348034 '

D0029916 D0031743 D0030389 D0030719

• D0029302 D0029005 D0028011 D0034015 i l D0030715 D0031729 D003874 D003875 I J D003879 D0029922 D0036520 D0034972 ,

i D0032839 D0031626 D0031626A D0037649 i D0029005 D0031605 D0027431 D0029155  !

j The inspectors' review of these deficiency reports did not identify i any ; weaknesses concerning corrective action for deficienciae 8

identified during the receipt inspection process.

i

. X.X Procurement Process '

3 i This inspection included a review of all phases of the material  !

j requisitioning, pre-screening, engineering, procurement, receipt  :

i inspection, identification, storage, and issue control process.

] The inspection included a review of site and corporate procedures i controlling the process, interviews with personnel from i maintenance, pre-screening, procurement engineering, purchasing, i i

warehousing, and QC receipt inspection, as well as, a review of documentation generated from each of these groups. As a result, several general observations were made by the inspectors:  ;

During several of the interviews, the "old" procurement ,

process was discussed. The inspectors learned that in the  !

"old" process, technical changes to the materials catalog l j (which included the ordering data for material purchases) l

could be made by pen and ink annotation on a hard copy of the catalog, without any technical justification being provided for the change. As a result, a concern developed that i unauthorized or unsupported changes in technical requirements j could have occurred. To resolve this concern, the inspectors reviewed a sample of these changes focusing on the technical

justification for the changes. Changes made by the material pre-screeners and procurement engineering were reviewed during

this effort. Changes to the following M&S stock codes were i reviewed by the inspectors

I' 1 570-28480-7 570-03490-8 570-24336-1 570-13137-7 772-74237-0 772-72872-5 579-61445-1 579-05308-5 578-14250-5 578-93550-5 578-92076-1 278-36850-3 579-38918-1 579-63676-5 Review of the changes to these stock codes determined that all  !

of the changes were supported by adequate technical  !

justification, and no unauthorized or unsupported changes had been made. The inspectors' concern is this area was adequately resolved.

I

i I

A relatively detailed review of the capabilities of the computer based Passport system _ was conducted during the  :

inspection. The inspectors concluded that the implementation l

of this system was an overall strength of the licensee's i material procurement and control program. The Passport system provides for easy and direct communication between the various l

material groups, speeds the procurement process, minimizes '

material errors, and allows easy access to technical information on material purchasing, stocking and usage.

During the course of the inspection, the inspectors observed the existence of Bill of Materials (BOMs) for many of.the plant components. These BOMs included a pre-engineered listing of piece parts used in assembly of components, which included the technical description of the part, the safety classification of the part, the stock code assigned, and stocking information. During personnel interviews it was {

learned the development of these BOMs was undertaken some time ago, and BOMs have been developed for approximately 50% of the high use equipment in the plant. The inspectors considered BOM development to be a strength of the licensee's material program, due to the fact that it pre-engineers the piece parts, makes identification of piece parts easier and faster, maintains a minimum amount of high use parts available, and minimizes the chance for unqualified parts being installed in the plant. Efforts in BOM development should be continued and l

supported by plant management.

• • • • • RANDY *****

I REVIEWED THE FOLLOWING ENGINEERING PACKAGES OUT OF THAT LAST BATCH THAT WE ASK FOR-PLEASE MAKE SURE THEY ARE ON,YOUR LIST:

038082 CGD 039626 EVAL PC III-ITEM 040298 EVAL PC III ITEM 038781 EVAL PC IV ITEM i 037931 EVAL PC IV ITEM 040101 EQIV EVAL 038966 EQIV EVAL 038962 EQIV EVAL 038956 EQIV EVAL 038942 EQIV EVAL 038941 EQIV EVAL 038928 EQIV EVAL 038344 EQIV EVAL

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ffz H is l

GIBBS/ TAYLOR l l

10 CFR 50.65 " Requirements for Monitoring the Effectiveness of Maintenance at i Nuclear Power Plants." as described in 10 CFR 50.65 b(1). in part. requires that  !

the scope of the monitoring program shall include safety related structures i systems or components. Additionally. 10 CFR 50.65 (b)(2). in part. requires  !

that the scope of the monitoring program shall include non-safety related structures systems and components that are relied upon to mitigate accidents or transients or are used in plant emergency operating procedures.

Contrary to the above, as of September 16. 1996 the following safety and non-safety related systems structures and components were not included in the licensee's 10 CFR 50.65 monitoring program scope:

Unit I and 2 Main Steam Line Radiation Monitors. RE-26-62. RE-26-63. RE-26-71. RE-26-72. and the Unit 1 Containment Air Radiation Monitors RE 31. and RE-26-32.

The Unit 1 and 2 Post Accident Sampling System (System 55) {

The Licensee's Communications System (System 61) )

The Unit 1 and Unit 2 Service Air System Compressors which are periodically crosstied to the Instrument Air System.

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Administrative Procedure 17.08. Implementation of 10 CFR 50.65. the Maintenance i Rule Administrative Procedure St. Lucle Plant. paragraph 7 . 8 .' Cause Determinations. states that a cause determination shall be performed for a performance criteria not being met.

Contrary to the above, no cause determination was performed when RCS unavailability exceeded the PLPC 1 criteria (Unplanned availability less than or equal to 5% for each unit, last twelve months.) Reference Condition Reports 96-1981 and 96-2037.

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Administrative Procedure 17.08. Implementation of 10 CFR 50.65. the Maintenance Rule Administrative Procedure St, Lucie Plant, paragraph 7.8,4 requires that cause determinations shall consider any generic implications for SSCs other than the one being evaluated.  !

Contrary to the above, the generic implications of the failure of the TCV valves j in the Turbine Control System, which caused a manual reactor trip on June 6. i 1996. were not considered for similar TCV valves in other plant systems. PMAI i 96-09-210 was issued by licensee concerning this problem. '

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A A St. Lucie Plant Systems and Components Engineering Department Guideline SCEG-006.

Rev. O. Guideline for Monitoring Maintenance Effectiveness by Maintenance Rule System Owners, paragraph 7.3. states: "Each responsible system owner shall

' monitor and trend actual SSC performance against the established performance criterla" Contrary to the above, WO 95007753-01 and 95007984-01 performed preventive maintenance on SWGR 2AB-01 and 1AB-01 (the 4.16 KV SB0 crosstie breakers).

respectively, and no unavailability of these breakers was logged against the Unavailability performance criteria in the licensee's Maintenance Rule Quarterly report dated July 9, 1996.

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W0s 95021809-01 and 95023498-01 appear to be MPFFs for the 4.16 KV  !

breakers for the pressurizer heater electrical supply. These failures are not shown in the licensee's Maintenance Rule Quarterly report dated July

9. 1996. This issue is unresolved.

PLPC 2a and PLPC 2b provide different performance criteria for plant level maintenance rule failures with no apparent technical maintenance basis.

Plant level unavailability time should be logged against each system in

, the quarterly report.  !

Program is set up to rely on system owners. To date system owners are not a major part of program implementation. System owners were not involved with the initial review of historical data and as a result there is very 4

little corporate memory in this area. Also performance criteria for some SSCs may need adjustment based on System Owner involvement. l Operator interviewed (1 RO. ISS) were weak.

Monitoring of performance criteria / data gathering is weak l

) -

The plant trip related to starting of the fire pumps remains an unresolved  !

4 item. l Implementation of the Matrix for removal of equipment from service and for logging equipment DOS is weak (based on the two operators interviewed).

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+

goal setting and monitoring of (a)(1) PORVs were appropriate and focussed 4

on the problem.

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TCW system engineer excellent Brian Gaffney (He has only had the position for 2 months).

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5 The following are examples were id1ntified where the licensee failed to implement requirements of the maintenance rule as described in Administrative Procedure 17.08. Implementation of 10 CFR 50.65.

Failure to monitor unavailability and functional failures for certain SSCs. (paragraph 4.4.3) (ex. station blackout bkrs. cvcs, hydrazine pump unit 1. 4.16KV Bkrs)

Failure to perform cause determinations for SSCs which have exceeded plant unavailability performance criteria (paragraph 7.8) (ex. RCS safeties and rx head o-ring)

Failure to initiate a condition . report for a functional failure of a risk significant SSC. (paragraph 7.8) (ex. lA Boric Acid Makeup pump. 7/25/96)

Failure to consider generic implications for temperature control valve failures. (paragraph 7.8.4) l 4

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I RON GIBBS INPUT FOR ST. IR 96-13 04.1 Operator Knowledae or the Maintenance Rule  ;

a. Insoection Scooe (62706)

The inspector interviewed two licensed operaters (one R0 and one SRO) to ,

determine if they understood the general requirements of the maintenance L rule and their particular duties and responsibilities for its t implementation. ]

b. Observations and Findinas 1

Operator knowledge of the rule was very limited and did not indicate an understanding of the purpose of the rule nor any of the details of why the i rule exists. Each of the operators had a very general knowledge of the rule and its implementation at the site, Training on the rule was very l' limited (approximately one hour during requalification) and was focussed mainly on the licensee *s matrix for removal of equipment from service. ,

There was also very limited knowledge on their specific duties and )i responsibilities for implementation of the rule. The matrix was not well understood by either operator: they were not aware of what systems were included under the rule, nor how to determine that information: they did not understand that they were an integral part in the logging of system unavailability for performance monitoring: and neither of them had read l l the procedure for implementation of the rule. )

c. Conclusions l Based on the interview of these two operators, the operations duties and responsibilities for implementation of the maintenance rule was very weak.

M1.1 Scooe of Structures. Systems. and Components Included Within the Rule

a. .Insoection Scooe (62706)

Prior to the onsite inspection, the inspectors reviewed the ST, Lucie l

Final Safety Analysis Re) ort, Licensee Event Reports, the Emergency

! Operating Procedures, prev ous NRC Inspection Reports, the site integrated matrix, and other information provided by the licensee. The team selected an independent sample of structures, systems, and components that the team l believed should be included within the scope of the rule, which was not l classified as such by the licensee. During the onsite portion of the

inspection, the inspectors used this list to determine if the licensee had

! adequately identified the structures systems, and com)onents that should l be included in the scope of the rule in accordance wit 110 CFR 50.65 (b).

' i

b. Observations and Findinas

, The licensee appointed an expert panel to perform several maintenance rule  !

! implementation functions including establishing the scope of the i

! Maintenance Rule. The panel reviewed 106 systems in the plant and l

determined that 72 were in the scope of the rule. In addition, 54 structures were placed within the scope of the rule.  !

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l The inspectors reviewed the licensee's data base and verified that all l required structures, systems, and components were included in the rule j with the exception of the following:

l - The licensee had not included the Post Accident Sampling System in

! the scope of the Maintenance Rule. Further review of this system determined that the system would be used during the performance of l the sites Emergency Operating Procedures to aid in determination of i offsite evacuation. Specific examples of this were found in the Emergency Operating Procedures for a Loss of Coolant Accident (EOP-

03. Revision 14) and Steam Generator Tube Ru)ture (EOP-04. Revision i 12). This is contrary to 10 CFR 50.65. whic1 requires inclusion of '

SSCs that mitigate the consequences of an accident and are included I

in plant E0Ps. The licensee issued Condition Report 96-2278 during the inspection to re-evaluate this system for inclusion in the Maintenance Rule.

- The licensee had not included the site Communications System in the scope of the Maintenance Rule. Further review of this system determined that the system is used to mitigate accidents or transients, and is vital in the proper performance of all Off-Normal and Emergency Operating Procedures. A specific reference to the use

, of the plants Communications System was found in the Station Blackout Crosstie Emergency 03erating Procedure (EOP-99. Revision 17). This is contrary to 10 C R 50. 65, which requires inclusion of SSCs that mitigate the consequences of an accident and are included in plant E0Ps. The licensee issued Condition Report 96-2278 during the inspection to re-evaluate this system for inclusion -in the Maintenance Rule.

- The licensee had not included the Service Air System in the sco)e of the Maintenance Rule. Review of operator logs determined tha; the Service Air System Air compressors on Unit 1 had been crosstie to the Instrument Air System on July 13,1996 in sup3 ort of plant shutdown conditions. The Instrument Air System is neluded under the scope of the rule. Discussion of this issue with licensee personnel determined that it was licensee policy to routinely crosstie the Service Air System Compressors to the Instrument Air System during outage conditions. Further investigation determined that this configuration could affect the operation of the Low  :

Pressure Safety Injection System operating in the shutdown cooling i mode, and therefore, the Service Air System compressors were required to be included in the scope of the rule. This is contrary i to 10 CFR 50.65. which requires inclusion of non-safety related i

systems whose failure could prevent safety related SSCs from i fulfilling their safety function. The licensee issued Condition Report 96-2278 during the inspection to re-evaluate this system for inclusion in the Maintenance Rule.

The inspection team was. aware of a history of problems with radiation monitors, and, as a result, a review of the Radiation Monitoring System for scoping within the Maintenance Rule was conducted, even though the Radiation Monitoring System was included in the rule by the licensee. This review resulted in the

l .

l determination that the Main Steam Radiation Monitors had not been '

included in the scope of the Maintenance Rule. even though both the Main Steam System and the Radiation Monitoring System had been  !

, included in the rule. This deficiency was the result of the lack of '

l specific definition of the boundaries between the two systems. Upon discovery of the deficiency the licensee issued Condition Report 96-

)

2264. Preliminary investigation by the licensee also identified the ,

fact that the Unit 1 Containment Air Radiation Monitors were also l l not included in the scope of the rule. The Main Steam Radiation Monitors are used to mitigate the consequences of an accident and are included in plant E0Ps. A specific example of their use is in the Steam Generator Tube Rupture E0P (E0P-04. Revision 12). This is contrary to 10 CFR 50.65, which requires inclusion of SSCs that i mitigate the consequences of an accident and are included in plant i E0Ps.

c. Conclusions 10 CFR 50.65 (b) establishes the scoping criteria for selection of safety related and non-safety related structures, systems, or components to be  !

included within the Maintenance Rule program. Scoping criteria includes j safety-related structures, systems or components that are relied upon to remain functional during and following design basis events to ensure the j integrity of the reactor coolant pressure boundary, the capability to shut I down the reactor and maintain it in a safe shutdown condition and the capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposure comparable to the 10 CFR part 100 )

guidelines; and non-safety related structures, systems, or components that are relied upon to mitigate accidents or transients or are used in the  :

plant emergency operating procedures, or whose failure could prevent safety-related structures, systems, and components from fulfilling their  !

safety-related function, or whose failure could cause a reactor scram or 1 actuation of a safety-related system. The deficiencies concerning sco)ing discussed above are included as examples of a Violation of t1ese requirements, and are cited as Violation 50-335, 389/96-13-01. Failure to Include Structures. Systems, and Components in the Scope of the Maintenance Rule as Required by 10 CFR 50.65 (b).

1 M1.6 Goal Settina and Monitorino for (a)(1) SSCs I'

a. Insoection Scone Bill, use the Palo Verde boiler plate to describe what we looked at

b. Observations and Findinas l

Unit 1 Power Ooerated Relief Valves (PORVs)

The licensee had experienced two Maintenance Preventable Functional l Failures (MPFFs) on the Unit 1 Pressurizer PORVs in August 1995, which l resulted in the valves being inoperable for a period of nine months l (Reference LER 95-05). As a result of these failures and the PORV l unplanned unavailability associated with these failures, the licensee had l

put the Unit 1 PORVs in a (1) status. The inspector reviewed the

f corrective action for these failures, and the goals and monitoring under the a (1) status, and concluded that the corrective action, goals, and monitoring.were appropriate.

During the review of the PORVs the inspector noted that the plant performance criteria for unit unplanned unavailability had been exceeded due to Reactor Coolant System deficiencies. The licensee was questioned concerning this issue, and it.was determined that a'cause determination for exceeding this criteria had not been performed in accordance with Licensee procedure. ADM 17.08. Revision 7, paragraph 7.8.1.B. Further investigation determined that a condition report (96-2037) had been issued with regard to exceeding this criteria. but had not been resolved. The licensee completed resolution of this condition report during the  !

inspection. The untimely documentation of the cause determination for exceeding the unit unplanned unavailability was considered a weakness in the implementation of the licensee's Maintenance Rule program.

Conclusions i The Maintenance Rule had been' effectively implemented for the Unit 1 3

Pressurizer PORVs. The untimely documentation of the cause determination j for unit unplanned unavailability was considered a weakness.

1 4.16 KV Switchaear and Breakers l

I The licensee had experienced several -repeat Maintenance Preventable  !

i Functional Failures (MPFFs) involving failure of 4.16 KV breakers due to  !

floor tripper and latch switch misadjustments. As a result of these. !

! failures the licensee had put these breakers in the Maintenance Rule a (1) ,

1 category. The inspector reviewed the corrective action for. these 1

failures, and the goals and monitoring under the a (1) status. and i

concluded that the corrective action, goals, and monitoring were

[ appropriate. The inspector also reviewed additional work order data l L concerning performance of these breakers for the period January 1995 to  ;

the beginning of the inspection. This review determined that there were l two additional repeat MPFFs, and a significant number of breaker i

unavailability hours, which had not been identified in the licensee's l

Maintenance Rule Quarterly Report as follows:

I j - Work Orders 95007753-01 and 95007984-01 performed preventive '

t maintenance on the 4.16 KV Station Blackout Crosstie Breakers, and i no unavailability of these breakers was trended against the

! unavailability performance criteria for these breakers in the licensee's Maintenance Rule Quarterly report dated July 9, 1996.

! - W0s 95021809-01 and 95023498-01 reported repetitive maintenance preventable functional failures for the 4.16 KV breakers for the pressurizer heater electrical supply which were not shown in the

' licensee's Maintenance Rule Quarterly report dated July 9,1996.

! This is contrary to licensee procedure ADM 17.08. Revision 7. paragraph s 7.6.4 and 7.11.2. A. which require performance monitoring be accomplished

by tracking specific (SSC Level) and/or Plant Level Performance Criteria i and repetitive maintenance preventable functional failures, and the y

i i

documentation of this information the licensee's Maintenance Rule Quarterly Reports. Failure to track repeat MPFFs and SB0 unavailability I hours against their performance criteria are included as examples of a .

Violation 50-335, 389/96-13-03. Failure to Follow Procedures for Implementation of the Maintenance Rule.

Conclusions .

1 Based on the above, the inspector concluded that implementation of the l Maintenance Rule for 4.16 KV breakers was weak.

M1.7 Preventive Maintenance and Trendina for (a)(2) SSCs ,

a. Insoection Scooe Bill, use the Palo Verde boiler plate to describe what we looked at

b. Observations and Findinas Turbine Coolina Water System The licensee had experienced two failures in the Turbine Cooling Water l (TCW) System on Unit 2, which caused manual reactor trips during the first  ;

six months of 1996. This was below the performance criteria (less than or l equal to two failures causing manual reactor trips within the past twelve  ;

months) established by the licensee in order to keep the system in l Maintenance Rule category a (2). However, the team determined that this t criteria had no technical basis as discussed in paragraph XXX. (Bill - i reference the para on the vio for less than or equal to 2 failures) Even  ;

though the TCW System had been classified as a (2), the system had been  !

reported to management as a system requiring " heightened awareness" in the Maintenance ivle Quarterly Report dated July 9.1996. Review of the TCW failures de. - mined that they were caused by the failure of the same l

temperature antrol valve (TCV-13-15) but the failures were due to two different causes (one failure involving electrical logic and one failure involving disconnect of the operator actuator feedback arm from the valve). The inspector reviewed the work order history for valve TCV-13-15  !

! during the previous twelve months, and no additional failures of the valve were found. In addition the inspector reviewed the corrective action for these two failures. The inspector determined that corrective action was appropriate with the one exception: The corrective action for the actuator arm failure had considered similar valves in the TCW system for both units.-however, it had not considered similar valves in other plant systems. This is contrary to licensee procedure ADM 17.08. Revision 7.

paragraph 7.8.4. which requires that cause determinations for failures shall consider any generic implications for structures, systems and components other than the one being evaluated. The licensee issued Plant Managers Action Item (PMAI) 96-09-210 when advised of this deficiency.

Failure to consider the generic implications of a Maintenance Preventable 3 Functional Failure is included as an example of a Violation 50-335.

! 389/96-13-03. Failure to Follow Procedures for Implementation of the l Maintenance Rule. ,

j Conclusions l

1

l I i

! The inspector concluded that The Maintenance Rule had been adequately j

implemented for the Turbine Cooling Water System. On example of failure  ;

to follow procedure for implementation or the Maintenance Rule was  :

observed. ,

Main Feedwater System i

~

Review of the Main Feedwater System determined that appropriate l performance criteria had been established and monitoring was being  !

accomplished against those criteria. Review of the problems associated l with the system determined that appropriate corrective actions had been ,

taken for failures. Operating experience was being used in system l monitoring. No deficiencies were noted concerning this system. j Conclusions The Maintenance Rule had been effectively implemented for the Main l Feedwater System.  ;

r M2,1 Maintenance and Material Conditions of Facilities and Eauioment l

a. Insoection Scone In the course of verifying the implementation of the Maintenance Rule  !

using inspection procedure 62706, the inspector performed walkdowns to  ;

examine the material condition of the Main Feedwater System and the i Turbine Cooling Water System. i

b. Observations and Findinas The inspector found that the systems inspected appeared to be free of i corrosion; oil leaks; water leaks: trash: and based on external l inspection, well maintained. especially considering the . corrosive i conditions that exist at St. Lucie. ]

c. Conclusions In general, the material condition of systems inspected was satisfactory.

E2.1 Review of UFSAR Commitment.q Bill, use the boiler plate in the Palo Verde inspection I have reviewed the FSAR for my assigned systems Main Feedwater, Turbine Cooling Water, U1 PORVs, and 4.16 KV breakers.

E4.1 Enoineer Knowledae of the Maintenance Rule

a. Insoection Scooe Bill, use Palo Verde boiler plate - I interviewed 1 component engineer who j was well experienced and 4 systems engineers, 2 of which had been recently assigned

b. Observations and Findinos

.- . . --..- -. =- - . . --- - . _ . . .

l

, The licensee had assigned nearly one half of the staff to the systems l l engineering organization within the last month and one half prior to this i inspection. The design of the licensee's program for implementation of the Maintenance Rule is heavily dependent on systems engineers for ,

implementation. As a result, the knowledge and experience of the newly ,

assigned personnel was very limited. One exception to this observation I was made involving the systems engineer for the Turbine Cooling Water System. This individual, in a month and a half, was already familiar with the issues on his assigned system, was in the process of initiating i necessary corrective actions, and was very responsive to concerns raised by the NRC inspector.

c. Conclusions The fact that the licensee assigned systems engineers so late in the process for implementation of the rule is viewed as the major contributing i factor to the deficiencies noted during this inspection. l l

l

)

l l

I I

w 4*.o -

A Hap 10. 1996 Page 1' V

INFORMATION ON EMERGENCY OPERATIONS FACILITIES (EOFs) FOR REGION !! PLANTS g Distance in miles Meets criteria of Real-Time NRC Verification Backup EOF *** Staff 6

EDFlocation(distance from staffing organ. NUllEG-0737. Supp.17 Staffing of R-I Staffing Meets NUREG-0737 Dist.

Q Site in air slies If of fsite) (normal wrkq. hours) location

• Staffino** Demonst raterf? Documented in IRN tocation Critertaf (ml.)

Browns Ferry Chattanooga. TN (105) 0 No Yes (60) Yes 95-32 (Par.10) N/A N/A Brunswicit ,

Onsite 0 Yes No (75) Yes 94-30 (Par. 9) Yes - see NOTE A 12 Catawba Charlotte NC (17) 17 Yes No (75) Yes 96-04 (Par. 9) N/A N/A Crystal River Crystal River. FL (II) Yes Yes (60)

!! Yes 91-08 (Par. 8) N/A N/A Farley Onsite 0 Yes No (75) Yes 94-25 (Par. 9) Yes 16 Ilarris Nearsite (2) 2 Yes No (15) Yes 95 07 (Par. 10) No - see NOTE B 21 llatch Onsite 0 Yes Yes (50) Yes 95-15 (Par. 10) Nn - see NoiE C 21 McGuire Charlotte. NC (15) 15 Yes No (75) Yes 93-21 (Par. 9) N/A N/A North Anna Onsite 0 Yes Yes (50) Yes 94-14 (Par. 9) Nn - see NCIE D 0 Oconee Clemson. SC (9.5) 9.5 No No (75) Yes 94-10 (Par. 9) ft/A N/A Robinson .Onsite O Yes No (75) Yes 95-28 (Par. 10) Yes - se- NOTE E el5 St. Lucie SR 712 et I-95 (10.5) 10.5 Yes Yes (60) Yes 96-02 (Par, 10) N/A N/A sequoyah Chattanooga. TN (18) 0 Yes Yes (60) Yes 94-32 (Par. 9) N/A E/A Sumer Jenkinsville. SC (3) 3 Yes Yes (50) Yes 95-11 (Par. 10) No - see NOIE r 25 Turry Onsite 0 Yes No (90) Yes 95-10 (Par. 10) No - see fMIE D 0 Tukey Point Miaml. FL (26) 26 No Yes (50) Yes 95-07 (Par 9) N/A N/A Vogtle Nearsite (1.5) 1.5 Yes Yes (GO) Yes 95-02 (Par. 9) N/A N/A Vatts Bar Chattanooga,Ill(50) 0 No Yes (60) Yes 95-78 (Par. 10) N/A N/A

• lable I of Supplement I to NUREG-0/37 specifies two options for EOFs: (1) a primary f acility within 10 miles and a backup f acility at 10-20 elles, or (2) a single facility at or beyond 10 miles: If beyond 20 miles, specific Comission approval is required. Enceptions to tiv- Incation critetta w re empilcitly granted by the Comission for Browns ferry. Oconee. Turkey Point. and Vatts Bar.

• • The number listed in parentheses is EOF staffing time In minutes. Table 2 of Supplement I to NUREG-0737 specifies 60 minutes as 'the' goal for ktaf fing an EDF following the event declaration for which staffing is required. In the cases of the f acilities whose EOF staf fing times are 75 or 90 minutes, the NRC has formally evaluated and accepted the licensee *s justification of a " reasonable erception' (as provided for in Supplement 1) to the 60-minute goal.

i

• • • The sites for which "N/A" (not appilcable) is indicated in this column are those not required to have a backup EOF (see the

• fontnote above).

NOTES referenced in this column will be found on the following page.

J

_ _ _ _ . __ -m _. -a- - m..__.._

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

I i 6 May 10,1996 Page 2 l

l INFORMATION ON EOFs FOR REGION !! PLANTS l Notes on Backup EOFs:

NOTE A:

Although the location (Brunswick County Complex in Bolivta, NC) meets the cetterion of 10-20 miles from the plant site. the facility would function only as a temporary meeting place for the EOF staff in theAevent EOF. letter that datedradiological Decemoer conditions 16, 1988 were to prevent personnel from traveling to the onsite from NRC (R. H. Lo, NRR) to the licensee (E. E. Utley) l doctseented the NRC staff's approval of this arrangement, which is delineated in the licensee's Emergency Plan, The approval was largely based upon the high degree of radiological protection provided by the cesign of the primary EOF.

NOTE B:

The location (Center Plaza Building in Raleigh, NC), at 26 miles from the plant site, ceviates only slightly issue.

from the criterion of 10-20 miles, and was not consioered by the NRC to be a significant i The facility would function only as a temporary meeting place for the EOF staff in the event that radiological conditions were to prevent personnel from traveling to the nearsste EOF.- A lttter dated Decemcer 16, 1988 from NRC (R. H. Lo, NRR) to the licensee (E. E. Utley) documented the NRC i staff's approval of this arrangement, which is delineated in the licensee's Emergency Plan. The the primarywas approval ECF.largely based upon the high oegree of radiological protection provided by the design of

[

NOTE C

A memoranoum cated February a. 1993 (re: SECY 93-004) from the Secretary to J. H. Taylor cocumented Conrntssion approval of the licensee's recuest to relocate the cacKuo EOF to its Emergency News Center Complex in Vidalia, GA, 21 miles from the plant site.

NOTE 0: A letter dated January 13, 1984 from NRC (D. G. Eisennut NRR) to the licensee (W. L. Stewart) documented the NRC staff s acceptance of the licensee's use of its corporate EOF in Glen Allen VA as the backup EOF for both North Anna and Surry. The corporate EOF is located 29 and 58 miles' l respectively, from the plant sites, l NOTE E:

! Although the location (National Guard Amory in Darlington, SC) meets the criterion of 10-20 miles from the plant site, the facility would function only as a temporary meeting place for the EOF staff in the event that radiological conditions were to s,.-event personnel from traveling to the onsite EOF. A letter dated Decemoer 16, 1988 from NRC (R. H. Lo, NRR) to the licensee (E. E. Utley) documented the NRC staff's approval of this arrangement, which is delineated in the licensee's Emergency Plan. The approval was largely based upon the high cegree of raotological protection provided by the oesign of the primary EOF, NOTE F:

i A letter cated Hay 9,1964 from NRC (0, 6. Eisenhut, NRR) to the licensee (O. W. Olxon, Jr.)

documented the Conrnission's acceptance of the licensee's use of its corporate office in Columbia, 50 as from thethe location of the backup EOF for the Suniner plant. The corporate office is located 25 miles plant site.

1 l

I l

l 1

t j _ -_- - --

PLANT RANKINGS IN PLANT SUPPORT (HP & EP only)

HEALTH PHYSICS TOP THIRD MIDDLE THIRD LOWER THIRD (ABOVE AVE) (AVERAGE) (BELOW AVE)

BFNP CR3 BRU HAR MCG CAT OCO NA FAR SUM ROB HAT TP SUR SQN VOG WBN STL l

l I

i EMERGENCY PPEPAREDNESS TOP THIRD MIDDLE THIRD LOWER THIRD (ABOVE AVE) (AVERAGE) (BELOW AVE) i 1

BFNP BRU HAT HAR CAT MCG OCO CR3 ROB SUM FAR SQN SUR NA STL l VOG WBN TP MAJOR RATING QRITERIA HEALTH PHYSICS Radiation dose (including 3yr. average) l Alara Program initiatives and results l HP Violations and severity level l Events i

EMERGENCY PREPAREDNESS Response to actual EP events EP exercise findings EP inspection findings / violations EP Plan review issues 4

4

^

i ST. LUCIE PERFORMANCE REVIEW

\

11. Function +f Arrm Assessments

1. Plant Support A.

The last SALP cycle ended 1/6/96. Plant Support was Category 1. The licensee continues to mainta:n a satisfactory level of performanc !

in the area of Plant Support. Some decline in Radiation Protection has been noted due to the loss of control of contaminated tools and exceeding dose goals. Insufficient information is available at this time to assess the Chemistry, Effluent. Waste, Transponation and Emergency Preparedness programs Hurncane preparations for hurncane Bertha were conservative. Overall site secunty has been adequate. Training and Qualification noted as a strength and management observed to be aggressive in pursuing issues, but not aggressive in doing indepth review of events. Implementation of the fire protection program continued to be satisfactory. Fire protection activities were primanly monitored by the resident inspectors dunng the PPR penod. i B. Basis Radiation Protection NCV for failure to control contaminated tools used in RCA (96-04, p 45)

Violation (repeat of above NCV) for numerous examples of failure to control contaminated tools. (96-09. p 25)

Internal and extemal exposures below 10 CFR Part 20 limits. (96-04, p 45 and 96-04, p 23) (1996 dose levels????????)

1995 dose was 412 person-rem. Unplanned maintenance and rework caused 1995 dose goal of 283 person-rem to be exceeded by 129 person-rem. (96-04, p 50)

Rad Techs decreased from 32 to 30 and 2 supervisors lost (96-04, p 48)

Decon staff reduced frorn 22 to 12 persons. Levels of contaminated equipment and matenals increasing (96-04, p 46)

Good radiological housekeeping and controls. (96-09. p 28)

The total area contaminated was at 250 ft'. (96-04, p 47)

Licensee accreditation of the FP&L DADS a good example of Radiation Protection staffs technical capabilities. (96-04, p 44)

Emeroency PreDaredness Conservative actions taken to prepare for Hurricane Bertha (96-11, p 3)

Secunty Failure to report a confirmed tampering event within one hour, which resulted in a violation. l i

Two events in pnor to the above tampenng event were documented as tampered or unauthonzed work, but management failed to notify secunty of these events.

Numerous problems discovered by a QA audit determined the FFD program to be weak.

Fire Protection A backup fire pump was installed to replace an out of service larger fire pump without an engineenng evaluatior' C. Recommended Inspection Effon  !

Inspections Rationale Health Physics (SALP 1 decline - maintain, watch)

Operational HP(83750) 2-inspections with focus on procedure compliance; rework doses Effi/RadWast(84/66750) 3-inspections with focus on accident' process monitor insta3ation & maintenance Tl 133 Rad Waste Combine with 86750 l

1 Emergency Preparedness I

)

EP Prog (82701) 1-Inspection witn focus on Self Assessment results I 1-Reg init. inspection on allegation followup (2 weeks) i Secunty , '

Secunty Prog (B1700) Core insp to review secunty auc.ts. corrective actions, management support and l

effectiveness. and rewew protected area detection equipment Sec. Prg/FFD (81700/81502) One regional instrative to fohowup on tampenng and FFD issues l

I VBS (Tl 2515/132) Inspection of Vehicle Bamer System Tl l l

Fire Protection  ;

None

1 l

i Silnt Lucie inspectlin Activities During The As es:m:nt P;rird 02/01/96 09/30/96 IR 96-01: period 01/07/96 - 02/17/96: issued 03/18/96: IP 71750 l

R:sedent Report, Radiological Protection topics (71750) were reviewed by residents. i IR 96-03; period 01/26/96 - 01/30/96: issued 02/22/96 Special inspection of Over Dilution Event of January 22,1996 i 1

IR 96-04: period 02/18/36 - 03/30/96: issued 04/29/96: IPs 71750 and 83750 I i

Resident Report Emergency Preparedness topics (71750) were reviewed by residents.  !

PS2 Inspection, Radiological Protection (83750) topics were reviewed by Region ll inspector j

IR 96-05: period 04/30/96 - 05/03/96: Issued 05/31/96 i

i S:cunty inspection by Region 11 inspector i IR 96-06: period 03/31/96 05/11/96: issued 06/07/96: IPs 93702 i

R:sident Report. Emergency Preparedness topics (93702) were reviewed by residents

{

IR 96-08: period 05/12/96 - 06/08/96: Issued 07/08/96: IPs 71750 Rxident Report, Radiological Protection topics (71750) were reviewed by residents.

IR 96-09: period 06/09/96 - 07/06/96; issued 08/05/96: IPs 71750 and 83750 R:sident Report, Fire Protection topics (71750) were reviewed by residents.

PS3 Inspection, Radiological Protection (83750) topics were reviewed by Region 11 inspector.

IR 96-11: period 07/07/96 - 08/03/96: issued 08/05/96: IP 71707 R:sident Report, No Plant Support Section in report, preparations for hurricane Bertha (71707) were reviewed by residents.  ;

IR 9612: 07/12/96: issued 08/26/96:

Special 50.59 Inspection St. Lucie Violations 02/01/96 09/30/96 I Dunng the assessment penod three violations were identified.

VIO 96-04-01, Failure to Follow Procedures lead to Unit 1 Containment Particulate-lodine-Noble Gas Monitor in-operability. This violatior resulted in a Technical Specification violation during start-up. (IR 96-04: pages 14-16 paragraph 04 2)

NCV 96-04-05, improper Health Physics Practices, Failure to follow licensee radiation protection procedures. The poor health physics practices identified as an URI in IR 96-01 later resulted in a NCV 96-04-05. (IR 96-04, pages 39 and 40, paragraph M81)

NCV 96-04-06, Failure to Follow Contamination Control Procedures for the Control and Use of Contaminated tools in the RCA. (IR 96-04, pages 45 & 46, paragraph R3.1) l l

l

, _ _ ___ ., _- -= -- -~ - - - -

ST. LUCIE PERFORMANCE REVIEW i II. Functionel Area Ass +ssments

1. Plant Support '

l e

A The fast SALP cy~cle ended 1/6/96. Plant Support was Category 1. The licensee continues to maintain a satisfactory level of performan t in the area of Plant Support. Some decline in Radiation Protection has been noted due to the loss of Control of Contaminated tools and exceeding dose goals. Insufficient information is available at this time to assess the Chemistry, Effluent. Waste, Transportation and Emergency Preparedness programs. Hurncane preparations for hurncane Bertha were conservative. Overall, stte secunty has be adequate.

Training and qualification noted as a strength and management observed to be aggressive in pursuing issues, but not 1

aggressive an doing indepth review of events, implementation of the fire protection program continued to be satisfactory Fire protection I activities were pnmarily monitored by the resident inspectors dunng the PPR penod. I B. Basis Radiation Protection NCV for failure to control contaminated tools used in RCA (96-04, p 45) l Violation (repeat of above NCV) for numerous examples of failure to control contaminated tools. (96-09, p 25) l intemal and external exposures below 10 CFR Part 20 limits. (96-04, p 45 and 96-04, p 23) (1996 dose levels????????)

1995 dose was 412 person-rem. Unplanned maintenance and rework caused 1995 dose goal of 283 person-rerr. to be exceed person-rern. (96-04, p 50)

• Rad Techs decreased from 32 to 30 and 2 supervisors lost (96-04, p 48)

Decon staff reduced from 22 to 12 persons. Levels of contaminated equipment and matenals increasing (96-04, p 46)

Good radiological housekeeping and controls. (96-09, p 28)

The total area contaminated was at 250 ft'. (96-04, p 47)

Licensee accreditation of the FP&L DADS a good example of Radiation Protection staffs technical capabilities. (96-04, p 44)

Emeroency Preparedness Conservative actions taken to prepare for Hurricane Bertha (96-11, p 3)

Secunty Failure to report a confirmed tampenng event within one hour, which resulted in a violation.

Two events in poor to the above tampenng event were documented as tampered or unauthonzed work, but management failed secunty of these events.

Numerous problems discovered by a QA audit determined the FFD program to be weak.

Fire Protection t

A backup fire pump was installed to replace an out of service larger fire pump without an engineenng evaluation.

C. Recommenced Inspection Effort inspections Rationale Health Physics (SALP 1 decline - maintain; watch)

Operational HP(83750) 2-inspections with focus on procedure compliance; rework doses Efft/RadWast(84/86750) l 3-inspections with focus on accident / process monitor snstallat:on & maintenance Ti 133 Rad Waste Comoine with 86750 Emergency Preparedness EP Prog (82701) 1-inspection with focus on Self Assessment results 1-Reg init. inspection on allegation followup (2 weeks) l Secunty Prog (B1700) Core Insp to review secunty audits, corrective actions management support and effectiveness, and review protected area cetection equipment.

! See Prg/FFD (S1700/81502) One reg onal inmatve to followuo on tampenng and FFD issues VBS (Tl 2515/132) Inspection of Vehicle Barner System Tl Fire Protection None

Saint Lucie inspection Activities During The Arsestment P;riod 02/01/96 - 09/30/96 IR 96-01: period 01/07/96 02/17/96: issued 03/18/96; IP 71750 Resident Report, Radiological Protection topics (71750) were reviewed by residents IR 96-03: period 01/26/96 - 01/30/96: issued 02/22/96 Special inspection of Over Dilution Event of January 22,1996

'l'196-04: period 02/18/96 03/30/96: Issued 04/29/96; IPs 71750 and 83750 Resident Report, Emergency Preparedness topics (71750) were reviewed by residents.

PSB Inspection, Radiological Protection (83750) topics were reviewed by Region 11 inspector IR 96-05: period 04/30/96 05/03/96: Issued 05/31/96 Secunty inspection by Region ilinspector l

IR 96-06: period 03/31/96 05/11/96: Issued 06/07/96: IPs 93702 R;sident Report, Emergency Preparedness topics (93702) were reviewed by residents.

IR 96-08: period 05/12/96 - 06/08/96: Issued 07/08/96: IPs 71750 R:sident Report, Radiological Protection topics (71750) were reviewed by residents.

1 I

1R 96-09: period 06/09/96 07/06/96: Issued 08/05/96: IPs 71750 and 83750 l I

RIsident Report, Fire Protection topics (71750) were reviewed by residents.

PS3 Inspection, Radiologicai Protection (83750) topics were reviewed by Region Il inspector.

IR 96-11: period 07/07/96 - 08/03/96: issued 08/05/96: IP 71707 '

RIsident Report, No Plant Support Section in report. pre parations for hurricane Bertha (71707) were reviewed by residents.

IR 9612: 07/12/96 issued 08/26/96:

Special 50.59 Inspection St. Lucie Violations 02/01/96 09/30/96 During the assessment penod three violations were identified.

VIO 96-04-01, Failure to Follow Procedures lead to Unit 1 Containment Particulate-lodine-Noble Gas Monitor in-operability. This violatior resulted in a Technical Specification violation during start-up. (IR 96-04. pages 14-16. paragraph 04.2)

NCV 96-04-05, improper Health Physics Practices, Failure to follow licensee radiation protection procedures. The poor health physics practices identified as an URI in IR 96-01 later resulted in a NCV 96-04-05. (IR 96-04, pages 39 and 40, paragraph M8.1)

NCV 96-04-06. Failure to Follow Contamination Control Procedures for the Control and Use of Contaminated tools in the RCA. (

pages 45 & 46. paragraph R3.1)

ST, LUCIE PERFORMANCE REVIEW '

11.

Functional Arem Assrssments 4

h e/ l$

I g

, 1. P! ant Support kf i

The last SALP cycle ended 1/6/96. Plant Support was Category 1. The licensee continues to maintain a satisfactory lev in the area of Plant Support.

Some dechne in Radiation Protection has been noted due to the loss of control of contaminate d

q j%ng cose goaIs) Insufficient information is available at this time to assess the Chemistry, Effluent, Waste, T i e Emergency adequate. Preparedness programs. Hurncane preparations for humcane Bertha were conservative. Overall, site secu Training and quahfication noted as a strength and management observed to be aggressive in pursuing issues, but not aggressive in doing indepth review of events. Implementation of the fire protection program continued to be satisfactory. Fire p activities were pnmanly monitored by the resident inspectors during the PPR penod. '

s '

B. Basis *Q

)

[7 n Radiation Protection

• U j ' NCV for failure to control contaminated tools used in RCA (96-04, p 45)

Y

{

Violation (repeat of above NCV) for numerous examples of failure to control ontaminated tools. (96-09, p 25) 4 intemat and extemal exposures below 10 CFR Part 20 limits. (96-04, p 45 and 96-04, p 23 l 1995 dose was 412 person-rem. Unplanned maintenance and rework caused 1995 dose goal of 283 person-rem to 4

person-rem. (504, p 50) ,

I 3

8 Rad Techs decreased from 32 to 30 and 2 supervisors lost (96-04, p 48) ~ '

4

_Decon staff reduced from 22 to 12 persons. Levels of contaminated equipment and matenals increasing.(504, p 46)

Good radiological housekeeping and controls. (96-09, p 28)

The total area contaminated was at 250 ft'. (E04, p 47)

Licensee accreditation of the FP&L DADS a good example of Radiation Protection staffs technical capabilities. (504, p 44) i Emeroency Preparedness

• Conservative actions taken to prepare for Hurricane Berthe (511, p 3) g '

f Secunty j Failure to report a confirmed tampenng event within one hour, which resulted in a violation.

~

A 1

} Two events in prior to the above tampenng event were documented as tampered or unauthonzed work, bu t

secunty of these events. na- nt failed to notify Numerous problems discovered by a OA audit determined the FFD program to be weak.

Fire Protection i

! A backup fire pump was installed to replace an out of service larger fire pump without an en eering evaluation bY l C. Recommended inspection Effort "

1 I

1 Inspections Rationale (T l Health Physics i Operational HP(83750)

(SALP 1 dechne - maintain; watch) /'

t 2-inspections with focus on procedure compliance:kviod@

Effi/RadWast(84/86750) 3-inspections with focus on accioent/ process monitor installation & maintenance Tl 133 Rad Waste Combine with 86750

! Emergency Preparedness l EP Prog (82701) 1-inspection with fpeus on Self Assessment results W,p W,

1. Reg init, inspection on allegation followupp _we #,

Secunty Prog (81700) Core insp to review secunty audits, corrective actions, management support and j effectiveness, and review protected area cetection equipment.

Sec. Prg/FFD (B1700/81502) 1 One regional initiative to followuo on tampenng ano FFD issues.

4

, VBS (Tl 2515/132) Inspection of Vehicle Bamer System Tl Fire Protection l

} '

None i

I A

S Int Lucb inspecti:n ActivitiM During Th) Ammment Pcrisd 02/01/96 - 09/30/96 IR 96-01: period 01/07/96 - 02/17/96: Issued 03/18/96: IP 71750 -

• ident Report, Radiological Protection topics (71750) were reviewed by residents.

l

. 96-03 period 01/26/96 - 01/30/96: Issued 02/22/96 Special inspection of Over Dilution Event of January 22,1996 l

IR 96-04: period 02/18/96 - 03/30/96: Issued 04/29/96: IPs 71750 and 83750 Resident Report, Emergency Preparedness topics (71750) were reviewed by residents.

PSB inspection, Radiological Protection (83750) topics were reviewed by Region 11 inspector IR 96-05: period 04/30/96 - 05/03/96: Issued 05/31/96 Security inspection by Region ll Inspector IR 96-06 period 03/31/96 - 05/11/96: issued 06/07/96: IPs 93702 R:sident Report. Emergency Preparedness topics (93702) were reviewed by residents.

IR 96-08: period 05/12/96 - 06/08/96: issued 07/08/96: IPs 71750 RIsident Report, Radiological Protection topics (71750) were reviewed by residents.

IR 96-09: period 0&r09/96 07/06/96: Issued 08/05/96: fps 71750 and 83750 l

RIsident Report, Fire Protection topics (71750) were reviewed by residents.

PSB inspection, Radiological Protection (83750) topics were reviewed by Region ilinspector.

6-11: period 07/07/96 - 08/03/96: Issued 08/05/96: IP 71707 Resident fieport, No Plant Support Section in report, preparations for hurncane Bertha (71707) were rcviewed by residents.  ;

IR 96-12: 07/12/96: issued 08/26/96:

Special 50 59 Inspection St. Lucie Violations 02/01/96 09/30/96 During the assessment period three violations were identified.

VIO 96 04-01, Failure to Follow Procedures lead to Unit 1 Containment Particulate-lodine-Noble Gas Monitor in-operability. This violation resulted in a Technical Specification violation dunng start-up. (IR 96-04, pages 14-16; paragraph 04.2)

NCV 96-04-05, improper Health Physics Practices, Failure to follow licensee radiation protection procedures. The poor health physics practices identified as an URI in (R 96-01 later resulted in a NCV 96-04-05. (IR 96-04, pages 39 and 40, paragraph M8.1)

NCV 96-04-06, Failure to Follow Contamination Control Procedures for the Control and Use of Contaminated tools in the RCA. (IR 96-04 pages 45 8,46; paragraph R3.1) i l

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1

)'

ST. LUCIE SPECIAL INSPECTION TEAM Team Charter A.

4 Develop a chronological sequence of events describing identification of and licensee responses to suspected precursor and known tampering events. (Munday-lead)

B. Evaluate licensee's response to the recent suspected and known '

tampering events to determine if:

- plant components. which have had tampering, have been adequately evaluated and the known degradation has been corrected. (Munday)

- plant safety systems have been sufficiently evaluated for 1 potential tampering to assure they can perform their 1 intended functions. (Munday-lead: Wiems) '

- plant management adequately responded to the suspected i precursor and known tampering events. (Barr) '

! - plant management has implemented adequate interim actions 3 to detect new tampering. (Wiens-lead; Thompson-Sec.)

- plant investigations are sufficiently thorough in i attempting to identify the person (s) responsible for the '

tampering. (Thompson)

- plant systems / components that experienced tampering have

, been maintained consistent with the plant licensing basis including location and personnel access to equipment.

'. (Wiens) 4

- assess whether personnel access to tampered components was in accordance with approved security plan and other

.' regulatory requirements. (Thompson)

C. Issue an unclassified, final report by September 11. 1996. A supplemental report which includes safeguards information may also be issued at the same time.

L D. Inspection team will report to the Director. Division of Reactor Safety. Region II.

d

, Inspection Team Members J

K. P. Barr - Team Leader

. L. A. Wiens J. T. Munday D. H. Thompson 8/16/96

1ST DRAFT DETAILED PLAN  ;

Resident Inspector (Munday)

1. Establish chronology / sequence from operations / maintenance / engineering for events (May 1996 through present>.

2. Determine edequacy of licensee actions taken +.a correct degraded components.

3. For each safety system on each unit determine adequacy of licensee actions to identify additional tampering. Perfori;l independent walkdown evaluations of several important systems for previously unidentified tampering to independently verify licensee's conclusions.

4. Determine adequacy of licensee actions to evaluate system interactions that may relate to the known tampering (eg, some mechanism that would have forced operators to use the shutdown panels).

5. Determine the adequacy of the licensee's evaluation of any synergistic +

effects of known and suspected tampering (eg. relation between SI relief '

valves and SI key switches).

l l

l .

i

1ST DRAFT DETAILED PLAN Security Inspector (Thompson)

1. Establish security chronology / sequence of events (May 196 through present).

2. Determine adequacy of licensee actions taken to investigate / evaluate the known degraded components and tamper mechanisms to identify the responsible person.

3. Determine adequacy of interim actions of security is sufficient to expeditiously detect new tampering.

4. Determine adequacy of the security response to the events of suspected and known tampering. Include immediate responses by management and any compensatory actions implemented.

T. Determine adequacy of criterion used to' decrease security.

I f

l T

E IST DRAFT DETAILED PLAN Project Manager (Wiens) 4

1. Review installed configuration of components in the Remote S/D Panels to determine whether they meet licensing basis.

2. Determine adequacy of iriterim actions of operations, maintenance. and engineering is sufficient to expeditiously detect new tampering.

3. As assigned, for each safety system on each unit, determine adequacy of licensee actions to identify additional tampering. As assigned, perform independent walkdown evaluations of several important systems for previously unidentified tampering to independently verify licensee's conclusions.

i I

i l