ML17228B327

Forwards Response to NRC Ltr Re Violations Noted in Insp Repts 50-335/95-15 & 50-389/95-15.Corrective Actions:Msis Was Blocked & Reset Immediately Following Event on 950802

ML17228B327
Person / Time
Site:	Saint Lucie
Issue date:	11/15/1995
From:	GOLDBERG J H FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-95-306, NUDOCS 9511210113
Download: ML17228B327 (23)

See also: IR 05000335/1995015

Text

RIG RITY 1 ACCELERATED

RIDS PROCESSING), REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)r'ESSION NBR 9511210113

DOC~DATE'5/11/15

NOTARIZED NO FACIL:50-335

St.Lucie Plant, Unit 1, Florida Power&Light Co.50-389 St.Lucie Plant, Unit 2, Florida Power&Light Co.AUTH.NAME AUTHOR AFFILIATION

GOLDBERG,J.H.

Florida Power&'ight Co.RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)SUBJECT: Forwards response to NRC ltr re violations

noted in insp repts 50-335/95-15

&50-389/95-15.Corrective

actions:MSIS

was blocked&reset immediately

following event on 950802.I DISTRIBUTION

CODE: IE01D COPIES RECEIVED:LTR

ENCL SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice

of Violation Response NOTES DOCKET N 05000335 05000389 INTERNAL: RECIPIENT ID CODE/NAME PD2-1 PD ACRS AEOD/SPD/RAB

DEDRO NRR/DISP/PIPB

NRR/DRPM/PECB

OE DIR RGN2 FILE 01 COPIES RECIPIENT LTTR ENCL ID CODE/NAME 1 1 NORRIS,J 2 AEOD/DEIB 1 A'E.1 FILE CENTER 1/'DRC8/H FB 1 NUDOCS-ABSTRACT

1'GC/HDS3 1 COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 EXTERNAL: LITCO BRYCE,J H NRC PDR 1 1 1 1 NOAC 1 1 iNOTE TO ALL RIDS" RECIPIEYTS:

PLEASE HELP US TO REDUCE 4VASTE!CONTACT THE DOCL'!iIEYT

CO."iTROL DESK, ROOiiI Pl-37 (EXT.504-2083)TO ELI iIINATE YOUR NA!iIE FROiI DISTRIBUTIOY.

LISTS FOR DOCL'IiIEi'I'S

5'OU DOi"I'L'LD!TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 19

4 0'

0 Florida Power L Light Company, P.O.Box 14000, Juno Beach, FL 33408 0420 NOV 1 5$995 L-95-306 10 CFR 2.201 U.S.Nuclear Regulatory

Commission

Attn: Document Control Desk Washington, D.C.20555 Re: St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15Florida Power and Light Company (FPL)has reviewed the subject inspection

report and pursuant to 10 CFR 2.201 the response to the notice of violation is attached.Very truly yours, J.H.Goldberg President-Nuclear Division JHG/DAS/EJB

Attachment

cc: Stewart D.Ebneter, Regional Administrator, USNRC Region II Senior Resident Inspector, USNRC, St.Lucie Plant 95ii210i13

'it5iii5 PDR ADOCK 05000335 9 PDR an FPL Group company

FPL RESPONSE TO INSPECTION

REPORT 95-15 SUMMARY NRC Inspection

Report 50-335/389/95-15

considered

St.Lucie Plant performance

during the six (6)week period from July 30, 1995 through September 16, 1995.The violations

below occurred during a relatively

short period of time, as described in the inspection

report, and several of the corrective

actions were instituted

following an analysis of the events, collectively.

The corrective

steps to avoid further violations

were in some cases determined

to be generic following this analysis, and are therefore repeated in a number of the responses.

The Inspection

Report identified

seven (7)violations

which are listed below.Violation A: Failure to Follow Procedures

and Block MSIS Actuation Violation B: Failure to Follow Procedures

During RCP Seal Restaging Violation C: Failure to Follow Procedure and Document Abnormal Valve Position in the Valve, Switch Deviation log Violation D: Failure to Follow Procedures

during Alignment of Shutdown Cooling System Violation E: Failure to Follow Procedure and Document a Deficiency

on Containment

Spray Valve Surveillance

Test Procedure Violation F: Failure to Initial Maintenance

Procedure Steps as Work was Completed Violation G: Failure to Follow Procedures

During Venting of ECCS System Resulted in Containment

Spraydown Additionally, both Florida Power and Light (FPL)and the NRC evaluated plant events to identify common underlying

themes.FPL presented a summary of events to the NRC on August 29, 1995.Weaknesses

identified

in this summary included procedure content and use, as well as management

oversight of eguipment performance.

FPL's Plan to Improve the Operational

Performance

at St.Lucie was developed as a result of the August 29, 1995, meeting and submitted to the NRC on September 15, 1995.To date, FPL has completed the activities

according to the improvement

plan schedule.

S=.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 VIOLATION A: 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.

Procedure QI 5-PR/PSL-1, Rev.62,"Preparation, Revision, Review/Approval

of Procedures," Section 5.13.2, states that all procedures

shall be strictly adhered to.OP 1-0030127, Rev 68,"Reactor Plant Cooldown-Hot Standby to Cold Shutdown," required, in part, that operators block Main Steam Isolation System (MSIS)actuation when block permissive

annunciations

were received.ONOP 1-0030131, Rev 60,"Plant Annunciator

Summary," required that, upon valid receipt of annunciators

Q-18 and Q-20, operators immediately

block channels A and B, respectively.

Contrary to the above, on August 2, 1995, during a cooldown of St.Lucie Unit 1, valid block.permissive

annunciators

were received, however, operators failed to establish the required MSIS blocks, resulting in A and B channel MSIS actuations.

RESPONSE A: REASON FOR VIOLATION The root cause of this violation was cognitive personnel error on the part of a utility licensed operator who failed to block the actuation of the main steam isolation signal (MSIS)in accordance

with the requirements

of the approved plant operating procedure.

2.CORRECTIVE

STEPS TAKEN AND THE RESULTS ACHIEVED A.The main steam isolation signal (MSIS)was blocked and reset immediately

following the event on August 2, 1995.

St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 3.CORRECTXVE

STEPS TO AVOXD FURTHER VXOLATXONS

A.The licensed operator who was involved in the event was counseled on the need to follow procedures

and received discipline

in accordance

with plant'policy.

B.All Operations

Nuclear Plant Supervisors (NPS)held meetings with their crews subsequent

to this event to reiterate FPL's goal for error free performance.

C.This event will be incorporated

into licensed operator requalification

training to emphasize procedural

compliance, proper communication

among the Control Room'team, and the importance

of supervision-in the control room maintaining

an overall awareness, of activities.

This action will be complete by January 1, 1996.D.St.Lucie Plant adopted verbatim compliance

as the only acceptable

means of procedure compliance.

This requirement

has been incorporated

into plant Quality Instruction

QI 5-PR/PSL-1,"Preparation, Revision, Review/Approval

of Procedures'~

" 4.Full compliance

was achieved on August 2, 1995 with the completion

of item 2 above.

St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 VIOLATION B: 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.

Procedure QI 5-PR/PSL-1, Rev.62,"Preparation, Revision, Review/Approval

of Procedures," Section 5.13.2, states that all procedures

shall be strictly adhered to.Contrary to the above, procedures

were not adhered to strictly in the following examples: OP 1-0120020, Rev.72,"Filling and Venting the RCS," precaution

4.2, required that Reactor Coolant System (RCS)venting, described in the procedure, not be attempted if RCS temperature

was above 200'F.On August 2, 1995, Reactor Coolant Pump (RCP)seal venting, performed in an attempt to correct seal package leakage in the 1A2 RCP in accordance

with Appendix E of the subject procedure, was performed while RCS temperature

was approximately

370'F.As a result, design temperatures

of RCP seal components

were approached

or exceeded.2.OP 1-0120020, Rev.72,"Filling and Venting the RCS," Appendix E,"Restaging

Reactor Coolant Pump Seals," required the use of RCP seal injection while restaging was attempted.

On August 2, 1995, restaging of the 1A2 RCP seal package was attempted without seal injection aligned to the seal package.As a result, design temperatures

of RCP seal components

were approached

or exceeded.RESPONSE B: REASON FOR VIOLATION The root cause of this violation was cognitive personnel error on the part of a utility licensed operator who failed to follow an approved plant procedure while performing

a restaging evolution on a Reactor Coolant'Pump (RCP)seal package.The operator did not strictly adhere to the conditions

contained in the procedure which required that RCS temperature

be no greater than 200'F, and that seal injection be in service.

0

St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply'o Notice of Violation Ins ection Re ort 95-15 2.CORRECTXVE

STEPS TAKEN AND THE RESULTS ACHIEVED A.The RCP'estaging evolution was discontinued, and Operations

cooled and depressurized

the Reactor Coolant System (RCS)in accordance

with approved plant procedure to lower RCP seal temperatures

to within the acceptable

range.The 1A2 RCP was secured.B.The damaged 1A2 RCP seal package was replaced prior to returning Unit 1 to operation.

3.CORRECTIVE

STEPS TO AVOID FURTHER VXOLATXONS

A.The licensed operator involved in this event was disciplined

in accordance

with plant policy.B.The procedure appendix which was used for performing

the restaging of the RCPs was deleted and is no longer available for use.C.Plant management

performed an assessment

of the decision making process that led to the restaging of the RCP seal under the existing plant conditions.

Based on this assessment, Plant policy 105,"Plant Operation Beyond the Envelope of Approved Plant Operating Procedures", was revised to require a technical review of procedures

which are being implemented

for the first time or for which plant conditions

are different from those described in the procedures

D.All Operations

Nuclear Plant Supervisors (NPS)held meetings with their crews subsequent

to this event to reiterate FPL's goal for error free performance.

E.St.Lucie Plant adopted verbatim compliance

as the only acceptable

means of procedure compliance.

This requirement

has been incorporated

into plant Quality Instruction

QI 5-PR/PSL-1,"Preparation, Revision, Review/Approval

of Procedures." 4.Full compliance

was achieved on August 2, 1995 with the completion

of item 2A, above.

St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 VIOLATION C: 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.

Procedure QI 5-PR/PSL-1, Rev.62,"Preparation, Revision, Review/Approval

of Procedures," Section 5.13', states that all procedures

shall be strictly adhered to.AP 1-0010123, Rev 99,"Administrative

Controls of Valves, Locks, and Switches," step 8.1.6, required, in part, that all valve position deviations

be documented

in the Valve Switch Deviation Log.Contrary to the above, on or about August 1, 1995, HCV-25-1 through 7 were repositioned

and left in the closed position without the required entries being made in the Valve Switch Deviation Log.The Valves'ositions

complicated

a loss of RCS inventory.

RESPONSE C: REASON FOR VIOLATION The root cause of this violation was cognitive personnel error on the part of utility licensed operators who did not properly document the closed status of the subject valves in the Valve Switch Deviation Log, as required by the approved plant procedure.

2.CORRECTIVE

STEPS TAKEN AND THE RESULTS ACHIEVED The Safeguards

Pump Room Sump Isolation valves, HCV 25-1 through HCV 25-7, were realigned to the open position immediately

following the loss of RCS inventory event on August 10, 1995, when Control Room operators discovered

the closed status of the valves.

St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 3.CORRECTXVE

STEPS TO AVOXD FURTHER VXOLATXONS

A.All Operations

Nuclear Plant Supervisors (NPS)held meetings with their crews subsequent

to this event to reiterate FPL's goal for error free performance.

B.C.D.The plant has adopted verbatim compliance

as the only acceptable

means of procedure compliance.

This requirement

has been incorporated

into plant Quality Instruction

QI 5-PR/PSL-1,"Preparation, Revision, Review/Approval

of Procedures." Management

is conducting

a daily review of Control Room chronological

logs to reinforce the expectation

for detail and completeness.

I Plant administrative

procedures

have been revised to provide for increased reviews by plant staff of the logs controlling

valve repositioning.

Full compliance

was achieved on August 10, 1995, with the completion

of item 2 above.

St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 VIOLATION D: 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.

Procedure QI 5-PR/PSL-1, Rev.62,"Preparation, Revision, Review/Approval

of Procedures," Section 5'3.2, states that all procedures

shall be strictly adhered to.OP 1-0410022, Rev 22,"Shutdown Cooling," step 8.3.7, required that V3652, the B Shutdown Cooling (SDC)hot leg suction isolation valve, be locked open while placing the B SDC loop in service.Contrary to the above, on August 29, a control room operator failed to place V3652 in a locked open condition while placing the B SDC loop in service.As a result, the 1B Low Pressure Safety Injection Pump was operated with its suction line isolated.RESPONSE D: REASON FOR VIOLATION The root cause of this violation was cognitive personnel error on the part of a utility licensed operator who failed to properly verify the alignment of the shutdown cooling (SDC)system flowpath in accordance

with the approved plant procedure, prior to starting the 1B Low Pressure Safety Injection (LPSI)Pump.This resulted in the failure to open the 1B LPSI Pump suction isolation valve.2.CORRECTIVE

STEPS TAKEN AND THE RESULTS ACHIEVED A.The Control Room operators noted the error in valve alignment and the LPSI pump was secured approximately

5 minutes after being started.A subsequent

inspection

determined

that no damage had occurred during the short period of pump operation.

B.The system was realigned in accordance

with the approved procedure and the LPSI pump was restarted.

Subsequent

operation of the LPSI pump was satisfactory.

C.An ASME Section XI code run was performed satisfactorily

on the 1B LPSI Pump and a subsequent

Engineering

assessment

concluded that pump operability

had not been adversely affected.

St.Lucie Units.1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 3.CORRECTIVE

STEPS TO AVOID FURTHER VIOLATIONS

A.The licensed operator involved in this event was disciplined

in accordance

with plant policy.B.Operations

implemented

procedure changes which require the use of a dedicated procedure reader to assist in the implementation

of SDC related evolutions.

C.All Operations

Nuclear Plant Supervisors (NPS)held meetings with their crews subsequent

to this event to reiterate FPL's goal for error free performance.

D.The plant has adopted verbatim compliance

as the only acceptable

means of procedure compliance.

This requirement

has been incorporated

into plant Quality Instruction

QI 5-PR/PSL-1,"Preparation, Revision, Review/Approval

of Procedures." E.This event will be included into licensed operator, requalification

training.This action will be completed by January 1, 1996.4.Full compliance

was achieved on August 29, 1995 with the completion

of item 2A and 2B above.

St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 VIOLATION E: 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.

Procedure QI 5-PR/PSL-1, Rev.62,"Preparation, Revision, Review/Approval

of Procedures," Section 5.13.2, states that all procedures

shall be strictly adhered to.QI 16-PR/PSL-2, Rev.1,"St.Lucie Action Report (STAR)Program," required that STARs be initiated for Quality Assurance audit findings and independent

technical review recommendations'ontrary

to the above, a STAR was not generated when a Quality Assurance review of an inadvertent

Unit 1 containment

spraydown, documented

in interoffice

correspondence

JQQ-95-143, identified

the practice of prelubricating

FCV-07-1A, Containment

Spray header A flow control valve, when performing

valve stroke time testing.RESPONSE E: 1.REASON FOR VIOLATION The root cause of this violation was cognitive personnel error on the part of utility Quality Assurance (QA)personnel.

QA personnel were in the process of conducting

an independent

review focusing on the contributing

factors associated

with a Unit 1 containment

spray down event.The practice of pre-lubricating

Containment

Spray header flow control valve FCV-07-lA prior to surveillance

testing was identified

during this.review, but was not determined

to be a contributing

factor to this event.Recommendations

to correct this deficiency

were therefore not contained in the resulting QA report, nor was a St.Lucie Action Request (STAR)generated in a timely manner.2.=CORRECTIVE

STEPS TAKEN AND THE RESULTS ACHIEVED A.A St.Lucie Action Request (STAR 951048)was generated on September 7, 1995 to document the deficient practice of pre-lubricating

Unit 1 and Unit 2 containment

spray flow control valves prior to surveillance

stroke time testing.B.Temporary changes were issued to plant surveillance

procedures

on September 2, 1995 to remove the practice of'pre-lubricating

valves prior to surveillance

testing.10

St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 3.CORRECTIVE

STEPS TO AVOID FURTHER VIOLATIONS

A.B.C.A meeting was held on September 13, 1995 between the Vice President of Nuclear Assurance and all St.Lucie Quality Assurance and Quality Control personnel.

During this meeting, clear expectations

were provided regarding the threshold for identification

and documentation

of deficiencies

by Quality personnel.

E On October 25, 1995, a second meeting was held between the site Quality Manager and St.Lucie QA personnel.

During this meeting, the requirements

of the Quality Instruction

QI 16-PR/PSL-2,"St.Lucie Action Report (STAR)Program" were reviewed.The responsibility

of QA personnel for timely identification

and documentation

of deficiencies

in accordance

with this procedure was reinforced.

Permanent changes will be made to plant surveillance

procedures

to discontinue

the practice of pre-test lubrication

of the valves prior to surveillance

testing.This action will be completed by December 1, 1995.4.Full compliance

was achieved on September 7, 1995 with the completion

of item 2A above.

St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 VIOLATION F: 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.

Procedure QI 5-PR/PSL-1, Rev.62,"Preparation, Revision, Review/Approval

of Procedures," Section 5.13.2, states that all procedures

shall be strictly adhered to.ADM-08.02, Rev 7,"Conduct of Maintenance," Appendix 5, step 5, required that procedures

be present during work and that individual

steps be initialed once performed.

Contrary to the above, inspection

of work in progress revealed that individual

steps were not initialed once performed upon completion

for work conducted in accordance

with Plant Change/Modification

11-195.RESPONSE F: 1.REASON FOR VIOLATION The root cause of this violation was cognitive personnel error on the part of an Electrical

Department

journeyman

who failed to properly document the completion

of steps while performing

work activities

associated

with the trip solenoids on the 1B Emergency Diesel Generator (EDG).The steps were not initialed as they were being performed, in accordance

with approved plant procedure.

2.CORRECTIVE

STEPS TAKEN AND THE RESULTS ACHIEVED A.The steps of the maintenance

procedure being worked were signed off by the journeyman

immediately

following the completion

of the work on August 31, 1995, and the completed procedure was reviewed by the chief electrician

and Electrical

supervisor.

B.The EDG circuitry was subsequently

tested following completion

of the work on August 31, 1995, and performed satisfactorily.

12

0

St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 3.CORRECTIVE

STEPS TO AVOID FURTHER VIOLATIONS

A.Meetings were held following this event with Electrical

Maintenance

employees to review this incident and emphasize management

expectations

regarding the documentation

of w'ork activities.

B.Supervisors

from each Maintenance

discipline

have conducted meetings with their employees to reinforce the need for strict adherence to the administrative

requirements

related to procedure use.C.The plant has adopted verbatim compliance

as the only acceptable

means of procedure compliance.

This requirement

has been incorporated

into plant Quality Instruction

QI 5-PR/PSL-1,"Preparation, Revision, Review/Approval

of Procedures." 4.Full compliance

was achieved on August 31, 1995 with the completion

of item 2A and 2B above.13

St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 VIOLATION G: 10 CFR 50 Appendix B, Criterion V,"Instructions, Procedures, and Drawings," requires, in part, that activities

affecting quality shall be prescribed

by documented

procedures

of a type appropriate

to the circumstances.

Contrary to the above, on August 18, 1995, venting of the Low Pressure Safety Injection (LPSI)System was conducted in accordance

with a procedure which was inappropriate

to the circumstances.

Specifically, OP 1-0420060, Rev.0,"Venting of the Emergency Core Cooling and Containment

Spray Systems," did not require a verification

that the portions of the system being vented were hydraulically

isolated from adjacent systems and flowpaths.

As a result of this failure to establish proper initial conditions, water driven by the 1A LPSI pump was inadvertently

directed to the A Train Containment

Spray header, resulting in a spraydown of the Unit 1 Reactor Containment

Building.RESPONSE G: REASON FOR VIOLATION The root cause of this violation was procedural

deficiency

in that the ECCS venting procedure, OP 1-0420060, did not state the plant conditions

required to successfully

vent the ECCS but relied upon the RCS heatup procedure to set plant conditions.

Specifically, the venting procedure did not require operators to verify that the proper containment

spray header isolation valves were closed prior to recirculating

the water in the SDC system.A contributing

factor to this event was that the operations

personnel performing

the ECCS venting procedure did not recognize that the existing plant conditions

would result in flow to the'A'ontainment

spray header when flow was aligned through the Shutdown Cooling Heat Exchanger.

A second contributing

factor of this event was that FCV-07-1A was placed in the open position because this valve had failed its ASME stroke time test.Plant management

made the decision to defer the valve repair and position this normally closed valve to its engineered

safeguards

open position in lieu of repairing the valve prior to startup.14

St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 2.CORRECTIVE

STEPS TAKEN AND THE RESULTS ACHIEVED A.Operators secured the 1A LPSI Pump and isolated, the flowpath to the containment

spray header from the LPSI Pump.The Reactor Cavity sump was drained to the Waste Management

System.B~Following the event, all nonessential

work at the site was placed on hold, and Unit 1 was maintained

stable in Mode 3 while senior plant management

conducted meetings with all available site personnel to stress the need for worker vigilance and attention to detail.The need to reduce equipment deficiencies

that impact operations

was also discussed.

C.Unit 1 was cooled down and depressurized

to Mode,5 and an inspection

and decontamination

of containment

was then conducted.

The event was evaluated under an Engineering

evaluation, which resulted in a comprehensive

inspection

of components

inside containment

to ensure future component reliability.

D.Operating procedure, OP 1-0420060,"Venting of the Emergency Core Cooling an'd Containment

Spray System", was revised September 1, 1995 to include the plant conditions

required to be present during venting.3.CORRECTIVE

STEPS TO AVOID FURTHER VIOLATIONS

A.Plant policy 105,"Plant Operation Beyond the Envelope of Approved Plant Operating Procedures", was revised to require a technical review of procedures

which are being implemented

for the first time or for which plant conditions

are different from those described in the procedure.

B.The Maintenance

Department

established

a team composed of plant staff and engineering

personnel, to determine the root cause for the Containment

Spray header isolation valve repeat failures and determine corrective

actions to eliminate this operator workaround.

FCV-07-1A was repaired prior to returning Unit 1 to service.15

St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 C.Existing plant deficiencies

were reviewed by senior plant management.

Additional

deficiencies

which could impact operations

were added to the work scope of the Unit 1 shutdown.These deficiencies

were corrected prior to returning the unit to service.D.Administrative

procedure, AP-0010147,"Assessment

of Abnormal Plant Configurations

or Significant

Material Deficient'Conditions

on Plant Operation", was developed to enhance outage scope review and ensure that equipment deficiencies

are restored in a timely manner.E.St.Lucie management

instituted

a weekly review of appropriate

performance

indicators

and work backlog status, including the age of open items and operator workarounds.

F.All Operations

Nuclear Plant Supervisors (NPS)held meetings with their crews subsequent

to this event to reiterate FPL's goal for erro'r free performance.

G.This event will be incorporated

into licensed operator requalification

training.This action will be complete by January 1, 1996.4.Full compliance

was achieved on August 18, 1995 with the completion

of items 2A, 2C and 2D above.16