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| =Text= | | =Text= |
| {{#Wiki_filter:CATEGORYj.REGULATORY | | {{#Wiki_filter:CATEGORY j.REGULATORY |
| INFORMATION | | INFORMATION |
| DISTRIBUTION | | DISTRIBUTION |
| SYSTEM(RIDS)ACCESSION | | SYSTEM (RIDS)ACCESSION NBR:9902120166 |
| NBR:9902120166 | | DOC.DATE: 99/02/04 NOTARIZED: |
| DOC.DATE: | |
| 99/02/04NOTARIZED: | |
| NO~~~~~~~~~~FACIL:50-389 | | NO~~~~~~~~~~FACIL:50-389 |
| St.LuciePlant,Unit2,FloridaPower6LightCo.AUTH.NAME.AUTHORAFFILIATION | | St.Lucie Plant, Unit 2, Florida Power 6 Light Co.AUTH.NAME.AUTHOR AFFILIATION |
| PLUNKETT,T.F.'lorida | | PLUNKETT,T.F.'lorida |
| PowerSLightCo.RECIP.NAME'ECIPIENT
| | Power S Light Co.RECIP.NAME'ECIPIENT AFFILIATION |
| AFFILIATION | | Records Management |
| RecordsManagement
| | Branch (Document Control Desk)SUBJECT: Forwards response to violations |
| Branch(Document | | noted in insp rept 50-389/98-11.Corrective |
| ControlDesk)SUBJECT:Forwardsresponsetoviolations
| |
| notedininsprept50-389/98-11.Corrective
| |
| actions:addi | | actions:addi |
| procedural | | procedural |
| guidancedeveloped
| | guidance developed for ECCS containment |
| forECCScontainment
| | sump insps for Units 1&2.Mode 1 walkdown of Unit 1 also performed. |
| sumpinspsforUnits1&2.Mode1walkdownofUnit1alsoperformed.
| |
| DISTRIBUTION | | DISTRIBUTION |
| CODE:IE01DCOPIESRECEIVED:LTR | | CODE: IE01D COPIES RECEIVED:LTR |
| ENCLSIZE:TITLE:General(50Dkt)-Insp
| | ENCL SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice |
| Rept/Notice | | of Violation Response DOCKET¹05000389 NOTES: RECIPIENT ID CODE/NAME PD2-3 PD COPIES LTTR ENCL 1 1 RECIPIENT ID CODE/NAME GLEAVES,W COPIES LTTR ENCL 1 1 INTERNAL: ACRS AEOD/TTC CENT NRR/DRPM/PECB |
| ofViolation
| |
| ResponseDOCKET¹05000389NOTES:RECIPIENT
| |
| IDCODE/NAME
| |
| PD2-3PDCOPIESLTTRENCL11RECIPIENT | |
| IDCODE/NAME
| |
| GLEAVES,W | |
| COPIESLTTRENCL11INTERNAL:
| |
| ACRSAEOD/TTCCENTNRR/DRPM/PECB
| |
| NUDOCS-ABSTRACT | | NUDOCS-ABSTRACT |
| OGC/HDS3EXTERNAL: | | OGC/HDS3 EXTERNAL: LITCO BRYCE,J H NRC PDR 2 2 1 1 1 1 1 1 1~1 1 1 1 1 1 1 AEOD/SPD/RAB |
| LITCOBRYCE,JHNRCPDR221111111~1111111AEOD/SPD/RAB
| | DEDRO NRR/DRCH/HOHB |
| DEDRONRR/DRCH/HOHB
| |
| NRR/DRPM/PERB | | NRR/DRPM/PERB |
| OEDIRRGN2FILE01NOACNUDOCSFULLTEXT111111111111YNOTETOALL"RIDS"RECIPIENTS:
| | OE DIR RGN2 FILE 01 NOAC NUDOCS FULLTEXT 1 1 1 1 1 1 1 1 1 1 1 1 Y NOTE TO ALL"RIDS" RECIPIENTS: |
| PLEASEHELPUSTOREDUCEWASTETHTOHAVEYOURNAMEORORGANIZATION
| | PLEASE HELP US TO REDUCE WASTETH TO HAVE YOUR NAME OR ORGANIZATION |
| REMOVEDFROMDISTRIBUTION
| | REMOVED FROM DISTRIBUTION |
| LISTSORREDUCETHENUMBEROFCOPIESRECEIVEDBYYOUORYOURORGANIZATION,
| | LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROZ DESK (DCD)ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 19 |
| CONTACTTHEDOCUMENTCONTROZDESK(DCD)ONEXTENSION
| | Florida Power&Light Company, P.0.Box14000,Juno |
| 415-2083TOTALNUMBEROFCOPIESREQUIRED: | | Beach, FL33408.0420 |
| LTTR19ENCL19
| | February 4, 1999 L-99-028 10 CFR 2.201 U.S.Nuclear Regulatory |
| FloridaPower&LightCompany,P.0.Box14000,Juno
| |
| Beach,FL33408.0420 | |
| February4,1999L-99-02810CFR2.201U.S.NuclearRegulatory
| |
| Commission | | Commission |
| Attn:DocumentControlDeskWashington, | | Attn: Document Control Desk Washington, D.C.20555 Re: St.Lucie Unit 2 Docket No.50-389 Reply to a Notice of Violation NRC Ins ection Re ort 98-11 Florida Power and Light Company (FPL)has reviewed the subject Notice of Violation and, pursuant to 10 CFR$2.201, the response to the violation is attached.As discussed in the violation response, the Unit 2 Spring 1997 refueling outage sump screen repair and disposition |
| D.C.20555Re:St.LucieUnit2DocketNo.50-389ReplytoaNoticeofViolation | |
| NRCInsectionReort98-11FloridaPowerandLightCompany(FPL)hasreviewedthesubjectNoticeofViolation
| |
| and,pursuantto10CFR$2.201,theresponsetotheviolation | |
| isattached.
| |
| Asdiscussed
| |
| intheviolation
| |
| response, | |
| theUnit2Spring1997refueling
| |
| outagesumpscreenrepairanddisposition
| |
| activities | | activities |
| failedtoadequately
| | failed to adequately |
| considerthegenericimplications
| | consider the generic implications |
| oftheidentified
| | of the identified |
| discrepancies. | | discrepancies. |
| St.Luciesitepersonnel | | St.Lucie site personnel are being trained to reinforce the requirements |
| arebeingtrainedtoreinforce
| | of the St.Lucie corrective |
| therequirements
| | action program.Please contact us with questions on the enclosed violation response.Very truly yours, Thomas F.Plunkett President Nuclear Division TFP/JAS/E JW Attachment |
| oftheSt.Luciecorrective
| | cc: Regional Administrator, USNRC, Region II Senior Resident Inspector, USNRC, St.Lucie Plant 9902120i66 |
| actionprogram.Pleasecontactuswithquestions
| | 990204 PDR ADOCK 05000389 P PDR an FPL Group company |
| ontheenclosedviolation
| |
| response. | |
| Verytrulyyours,ThomasF.PlunkettPresident
| |
| NuclearDivisionTFP/JAS/E
| |
| JWAttachment
| |
| cc:RegionalAdministrator, | |
| USNRC,RegionIISeniorResidentInspector, | |
| USNRC,St.LuciePlant9902120i66 | |
| 990204PDRADOCK05000389PPDRanFPLGroupcompany
| |
| | | |
| L-99-028Attachment | | L-99-028 Attachment |
| Page1of5VIOLATION
| | Page 1 of 5 VIOLATION Part 50 of Title 10 of the Code of Federal Regulations |
| Part50ofTitle10oftheCodeofFederalRegulations
| | (10 CFR 50), Appendix B, Criterion XVI requires that measures shall be established |
| (10CFR50),AppendixB,Criterion | | to assure that conditions |
| XVIrequiresthatmeasuresshallbeestablished
| | adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances |
| toassurethatconditions
| | are promptly identified |
| adversetoquality,suchasfailures,
| | and corrected. |
| malfunctions, | | Contrary to the above, as of November 15, 1998, conditions |
| deficiencies, | | adverse to quality were not promptly identified |
| deviations, | | and corrected involving the Unit 2 emergency core cooling systems (ECCS)containment |
| defective | | sump.Specifically, in May 1997, corrective |
| materialandequipment,
| | actions were implemented |
| andnonconformances
| | to address gaps and openings in the ECCS containment |
| arepromptlyidentified
| | sump screens in excess of design requirements |
| andcorrected.
| | described in the Updated Final Safety Analysis Report.However, as evidenced by the identification. |
| Contrarytotheabove,asofNovember15,1998,conditions
| | of approximately |
| adversetoqualitywerenotpromptlyidentified
| | 100 additional |
| andcorrected
| |
| involving | |
| theUnit2emergency
| |
| corecoolingsystems(ECCS)containment
| |
| sump.Specifically, | |
| inMay1997,corrective
| |
| actionswereimplemented
| |
| toaddressgapsandopeningsintheECCScontainment
| |
| sumpscreensinexcessofdesignrequirements
| |
| described | |
| intheUpdatedFinalSafetyAnalysisReport.However,asevidenced
| |
| bytheidentification.
| |
| ofapproximately
| |
| 100additional
| |
| discrepancies | | discrepancies |
| inNovember1998,thecorrective
| | in November 1998, the corrective |
| actionsinMay1997werenoteffective
| | actions in May 1997 were not effective in identifying |
| inidentifying
| | and correcting |
| andcorrecting
| | the deficiencies, and the sump was not restored to design requirements. |
| thedeficiencies,
| | This is a Severity IV Level violation (Supplement |
| andthesumpwasnotrestoredtodesignrequirements.
| | 1).RESPONSE 1.A reement with or Denial o the Violation FPL concurs with the violation. |
| ThisisaSeverityIVLevelviolation
| | Reason for the Violation The failure of the corrective |
| (Supplement | | actions performed in May 1997 to effectively |
| 1).RESPONSE1.AreementwithorDenialotheViolation | | identify and correct deficiencies, and to restore the ECCS containment |
| FPLconcurswiththeviolation.
| | sump to design requirements, is primarily the result of inadequate |
| ReasonfortheViolation
| |
| Thefailureofthecorrective
| |
| actionsperformed
| |
| inMay1997toeffectively
| |
| identifyandcorrectdeficiencies,
| |
| andtorestoretheECCScontainment
| |
| sumptodesignrequirements,
| |
| isprimarily
| |
| theresultofinadequate
| |
| consideration | | consideration |
| ofgenericimplications
| | of generic implications |
| ofthedocumented
| | of the documented |
| deficiencies | | deficiencies (i.e., consideration |
| (i.e.,consideration | | of the potential for deficiencies |
| ofthepotential
| | in all areas of the Unit 2 sump screens).In May 1997, near the end of the Spring 1997 Unit 2 refueling outage (SL2-10), the NRC Resident Inspector noted discrepancies |
| fordeficiencies
| | in the construction |
| inallareasoftheUnit2sumpscreens).
| | of the ECCS containment |
| InMay1997,neartheendoftheSpring1997Unit2refueling
| | sump screen.These discrepancies |
| outage(SL2-10), | | involved gaps between the divider screen and the outer vertical screen, and between the divider screen and the concrete wall.Condition Report 97-1102 was written to document these discrepancies, and Plant Change/Modification (PC/M)97-037 was written for the implementation |
| theNRCResidentInspector
| | of required repairs.FPL performed additional |
| noteddiscrepancies
| |
| intheconstruction
| |
| oftheECCScontainment
| |
| sumpscreen.Thesediscrepancies
| |
| involvedgapsbetweenthedividerscreenandtheouterverticalscreen,andbetweenthedividerscreenandtheconcretewall.Condition
| |
| Report97-1102waswrittentodocumentthesediscrepancies,
| |
| andPlantChange/Modification
| |
| (PC/M)97-037waswrittenfortheimplementation | |
| ofrequiredrepairs.FPLperformed
| |
| additional | |
| inspections | | inspections |
| ofthedividerscreen,andnotedadditional
| | of the divider screen, and noted additional |
| discrepancies. | | discrepancies. |
| Duringtheimplementation
| | During the implementation |
| of | | of |
| L-99-028Attachment | | L-99-028 Attachment |
| Page2of5therequiredrepairs,otherminorgapswerenotedinthedividerscreenandinthehorizontal
| | Page 2 of 5 the required repairs, other minor gaps were noted in the divider screen and in the horizontal |
| screenatthetopofthesump;thesegapswerealsodocumented
| | screen at the top of the sump;these gaps were also documented |
| inCondition
| | in Condition Report 97-1102 and repaired pursuant to PC/M 97-037.During this period, FPL efforts were focused on the repair of the gaps noted at the divider screen and the horizontal |
| Report97-1102andrepairedpursuanttoPC/M97-037.Duringthisperiod,FPLeffortswerefocusedontherepairofthegapsnotedatthedividerscreenandthehorizontal
| | screen.The areas of concern noted by the NRC Resident dealt with gaps between the divider screen and the outer screen, and between the divider screen and the concrete wall (i.e., discrepancies |
| screen.TheareasofconcernnotedbytheNRCResidentdealtwithgapsbetweenthedividerscreenandtheouterscreen,andbetweenthedividerscreenandtheconcretewall(i.e.,discrepancies | | that would allow the passage of debris from one side of the sump to the other side, thus potentially |
| thatwouldallowthepassageofdebrisfromonesideofthesumptotheotherside,thuspotentially
| | affecting both ECCS trains).Additional |
| affecting | |
| bothECCStrains).Additional
| |
| inspections | | inspections |
| performed | | performed by FPL during the SL2-10 refueling outage to address generic concerns for Unit 2 were originally |
| byFPLduringtheSL2-10refueling
| | limited to the divider screen;aAer discrepancies |
| outagetoaddressgenericconcernsforUnit2wereoriginally
| | were observed in the horizontal |
| limitedtothedividerscreen;aAerdiscrepancies
| | screens, the scope of inspections |
| wereobservedinthehorizontal
| | was increased to include the horizontal |
| screens,thescopeofinspections | | screens.A commitment |
| wasincreased
| | was made (and fulfilled) |
| toincludethehorizontal
| | to prepare guidelines |
| screens.Acommitment | | for inspection |
| wasmade(andfulfilled)
| | of the sump screens for both Units 1 and 2 during future outages.However, St.Lucie did not recognize that the scope of generic concerns to be addressed during the SL2-10 outage should have been expanded to include the vertical outer screens, to provide complete assurance (a)that all sump screen deficiencies |
| toprepareguidelines
| | were identified |
| forinspection
| | and corrected and (b)that the design requirements |
| ofthesumpscreensforbothUnits1and2duringfutureoutages.However,St.Luciedidnotrecognize
| | for'the ECCS containment |
| thatthescopeofgenericconcernstobeaddressed
| | sump were satisfied. |
| duringtheSL2-10outageshouldhavebeenexpandedtoincludetheverticalouterscreens,toprovidecompleteassurance
| | The gaps in the divider screen were discovered |
| (a)thatallsumpscreendeficiencies | | during the Spring 1997 Mode 4 containment |
| wereidentified
| | closeout walkdown.The implicit awareness by personnel of the schedule for unit re-start (inherent during refueling outages)was a factor in the.narrow focus of corrective |
| andcorrected
| | action which failed to identify the need for additional |
| and(b)thatthedesignrequirements | |
| for'theECCScontainment | |
| sumpweresatisfied.
| |
| Thegapsinthedividerscreenwerediscovered
| |
| duringtheSpring1997Mode4containment
| |
| closeoutwalkdown.
| |
| Theimplicitawareness
| |
| bypersonnel
| |
| ofthescheduleforunitre-start(inherent
| |
| duringrefueling
| |
| outages)wasafactorinthe.narrowfocusofcorrective | |
| actionwhichfailedtoidentifytheneedforadditional
| |
| inspections | | inspections |
| tobeperformed
| | to be performed to address generic concerns.During the disposition |
| toaddressgenericconcerns.
| | of these discrepancies, generic implications |
| Duringthedisposition
| | for Unit 1 were considered. |
| ofthesediscrepancies,
| | Since the design of the Unit 1 screens has a completely |
| genericimplications
| | different configuration |
| forUnit1wereconsidered.
| | than Unit 2 (with no divider screen), FPL determined |
| SincethedesignoftheUnit1screenshasacompletely
| | that no immediate actions were required for Unit l.A subsequent |
| different | | Mode 1 power entry was performed as described below in corrective |
| configuration | | action 3.b.Detailed inspections |
| thanUnit2(withnodividerscreen),FPLdetermined
| | and repairs of the Unit 1 screens were performed during the, Fall 1997 Unit 1 refueling outage (SL1-15).Based on these facts, FPL has determined |
| thatnoimmediate
| | that the reason for this violation (ineffective |
| actionswererequiredforUnitl.Asubsequent
| |
| Mode1powerentrywasperformed
| |
| asdescribed
| |
| belowincorrective
| |
| action3.b.Detailedinspections
| |
| andrepairsoftheUnit1screenswereperformed
| |
| duringthe,Fall1997Unit1refueling
| |
| outage(SL1-15). | |
| Basedonthesefacts,FPLhasdetermined
| |
| thatthereasonforthisviolation
| |
| (ineffective | |
| corrective | | corrective |
| actions)wasthefactthatinsufficient | | actions)was the fact that insufficient |
| attention | | attention and consideration |
| andconsideration
| | were given to generic concerns (i.e., the potential for discrepancies |
| weregiventogenericconcerns(i.e.,thepotential
| | in the vertical outer screeris and the horizontal |
| fordiscrepancies
| |
| intheverticalouterscreerisandthehorizontal
| |
| screens)subsequent | | screens)subsequent |
| tothediscovery
| | to the discovery of gaps in the divider screen. |
| ofgapsinthedividerscreen.
| | L-99-028 Attachment |
| L-99-028Attachment | | Page 3 of 5 3.Corrective |
| Page3of53.Corrective
| | Ste s Taken and Results Achieved Subsequent |
| StesTakenandResultsAchievedSubsequent
| | to the SL2-10 refueling outage, additional |
| totheSL2-10refueling
| |
| outage,additional | |
| procedural | | procedural |
| guidancewasdeveloped
| | guidance was developed for ECCS containment |
| forECCScontainment
| | sump inspections |
| sumpinspections
| | for Units 1 and 2 to provide specific inspection |
| forUnits1and2toprovidespecificinspection
| |
| requirements | | requirements |
| forgapsinthesumpscreenaswellasforverification
| | for gaps in the sump screen as well as for verification |
| ofsumpareacleanliness.
| | of sump area cleanliness. |
| Theprocedural
| | The procedural |
| guidanceisintendedtoensurethatthephysicalcondition
| | guidance is intended to ensure that the physical condition of the sump screens meets the design requirements. |
| ofthesumpscreensmeetsthedesignrequirements.
| | The required guidance was issued via Maintenance |
| TherequiredguidancewasissuedviaMaintenance
| |
| Surveillance | | Surveillance |
| Procedure | | Procedure MSP-68.01 (" Containment |
| MSP-68.01 | | Sump Inspection")and PSL Nuclear Assurance Quality Control Technique Sheet 10.54 (" Unit 1 and Unit 2 Containment |
| ("Containment | | Sump Inspection").Subsequent |
| SumpInspection"
| | to the SL2-10 refueling outage, a Mode 1 walkdown of Unit 1 was performed to inspect the accessible |
| )andPSLNuclearAssurance | | areas of the Unit 1 ECCS containment |
| QualityControlTechnique
| | sump screens.Only the horizontal |
| Sheet10.54("Unit1andUnit2Containment
| | screen at the top of the sump could be inspected during this walkdown.Eight minor discrepant |
| SumpInspection"
| |
| ).Subsequent | |
| totheSL2-10refueling
| |
| outage,aMode1walkdownofUnit1wasperformed | |
| toinspecttheaccessible
| |
| areasoftheUnit1ECCScontainment
| |
| sumpscreens.Onlythehorizontal
| |
| screenatthetopofthesumpcouldbeinspected
| |
| duringthiswalkdown.
| |
| Eightminordiscrepant
| |
| conditions | | conditions |
| werefound;anengineering
| | were found;an engineering |
| evaluation | | evaluation |
| concluded | | concluded that there were no operability |
| thattherewerenooperability
| | concerns associated |
| concernsassociated
| | with these conditions. |
| withtheseconditions.
| | Two of these discrepancies |
| Twoofthesediscrepancies
| | were repaired immediately. |
| wererepairedimmediately.
| | The remaining six discrepancies |
| Theremaining
| | were repaired during the next Unit 1 refueling outage (SL1-15);see paragraph c, below.These discrepancies, and the evaluation |
| sixdiscrepancies
| | of the as-found condition, were documented |
| wererepairedduringthenextUnit1refueling
| | in Condition Report No.97-1465, Supplement |
| outage(SL1-15);seeparagraph | | 1.C.During the SL1-15 refueling outage (the first outage subsequent |
| c,below.Thesediscrepancies, | | to the issuance of the procedural |
| andtheevaluation
| | guidance discussed in paragraph a, above), the Unit 1 ECCS containment |
| oftheas-foundcondition,
| | sump screens were inspected in detail in accordance |
| weredocumented
| | with MSP-68.01 and Technique Sheet 10.54.No , discrepancies |
| inCondition
| | were observed on the inner screens.Several discrepancies |
| ReportNo.97-1465,Supplement
| | were documented |
| 1.C.DuringtheSL1-15refueling | | with regard to the outer screens and the sump itself.These discrepancies |
| outage(thefirstoutagesubsequent | | were documented |
| totheissuanceoftheprocedural
| | and evaluated in Condition Report No.97-2225 and Plant Management |
| guidancediscussed
| |
| inparagraph
| |
| a,above),theUnit1ECCScontainment | |
| sumpscreenswereinspected
| |
| indetailinaccordance
| |
| withMSP-68.01
| |
| andTechnique
| |
| Sheet10.54.No,discrepancies
| |
| wereobservedontheinnerscreens.Severaldiscrepancies
| |
| weredocumented
| |
| withregardtotheouterscreensandthesumpitself.Thesediscrepancies
| |
| weredocumented
| |
| andevaluated
| |
| inCondition
| |
| ReportNo.97-2225andPlantManagement
| |
| Action-Item | | Action-Item |
| No.97-12-166. | | No.97-12-166. |
| FPLconcluded
| | FPL concluded that there were no outstanding |
| thattherewerenooutstanding
| |
| operability | | operability |
| concernsorreportability
| | concerns or reportability |
| issues.Requiredrepairstothesumpscreenswereperformed | | issues.Required repairs to the sump screens were performed in accordance |
| inaccordance
| | with PC/M 97-058.During the Fall 1998 Unit 2 refueling outage (SL2-11), a detailed,.comprehensive |
| withPC/M97-058.DuringtheFall1998Unit2refueling
| |
| outage(SL2-11), | |
| adetailed,
| |
| .comprehensive | |
| inspection | | inspection |
| oftheUnit2ECCScontainment
| | of the Unit 2 ECCS containment |
| sumpscreenswasperformed
| | sump screens was performed in accordance |
| inaccordance
| | with MSP-68.01 and Technique Sheet 10.54.This was the first Unit 2 outage subsequent |
| withMSP-68.01
| | to the issuance of the detailed procedural |
| andTechnique
| | guidance discussed in paragraph a, above.A total of 101 discrepant |
| Sheet10.54.ThiswasthefirstUnit2outagesubsequent
| | conditions, along with a limited number of inaccessible |
| totheissuanceofthedetailedprocedural
| | areas, were identified |
| guidancediscussed
| | during this inspection. |
| inparagraph
| | These conditions |
| a,above.Atotalof101discrepant | | were documented |
| conditions, | | ~r 0 |
| alongwithalimitednumberofinaccessible
| | L-99-028 Attachment |
| areas,wereidentified | | Page 4 of 5 and evaluated in Condition Report No.98-1766 and 98-1766 (Supplements |
| duringthisinspection.
| | 1 and 2).The sump screen discrepancies |
| Theseconditions
| | which required repair were corrected in accordance |
| weredocumented
| | with PC/M 98-029.All other identified |
| ~r0 | | sump screen discrepancies, including any potential deficiencies |
| L-99-028Attachment | |
| Page4of5andevaluated
| |
| inCondition
| |
| ReportNo.98-1766and98-1766(Supplements
| |
| 1and2).Thesumpscreendiscrepancies
| |
| whichrequiredrepairwerecorrected
| |
| inaccordance
| |
| withPC/M98-029.Allotheridentified
| |
| sumpscreendiscrepancies,
| |
| including | |
| anypotential
| |
| deficiencies | |
| associated | | associated |
| withtheinaccessible
| | with the inaccessible |
| sumpscreenareas,weredispositioned
| | sump screen areas, were dispositioned |
| asanacceptable
| | as an acceptable |
| configuration. | | configuration. |
| FPLconcluded
| | FPL concluded (a)that there were no operability |
| (a)thattherewerenooperability | | concerns associated |
| concernsassociated
| | with the as-found condition (with the unit off line), and (b)that the evaluation |
| withtheas-foundcondition
| | for safety significance |
| (withtheunitoffline),and(b)thattheevaluation | | provided for the discrepancies |
| forsafetysignificance
| |
| providedforthediscrepancies
| |
| discovered | | discovered |
| duringtheSL2-10refueling
| | during the SL2-10 refueling outage bounded the newly discovered |
| outageboundedthenewlydiscovered
| |
| anomalies. | | anomalies. |
| FPLdetermined
| | FPL determined |
| thatthediscrepancies
| | that the discrepancies |
| werereportable
| | were reportable |
| under10CFR50.73as"acondition
| | under 10 CFR 50.73 as"a condition outside the design basis of the plant".FPL issued a revision to LER 50-389/97-02, in which the discrepancies |
| outsidethedesignbasisoftheplant".FPLissuedarevisiontoLER50-389/97-02,
| | were attributed |
| inwhichthediscrepancies
| | to (a)a failure to properly implement the design requirements |
| wereattributed
| | during original construction |
| to(a)afailuretoproperlyimplement | | and (b)inadequate |
| thedesignrequirements
| |
| duringoriginalconstruction
| |
| and(b)inadequate | |
| inspections. | | inspections. |
| 4.Corrective | | 4.Corrective |
| StestoAvoidFutureViolations
| | Ste s to Avoid Future Violations |
| St.LucieUnit2Technical | | St.Lucie Unit 2 Technical Specification |
| Specification | | 4.5.2.e.2 requires a visual inspection |
| 4.5.2.e.2 | | of the containment |
| requiresavisualinspection
| | sump at least once per 18 months for verification |
| ofthecontainment
| | that the screens show no evidence of structural |
| sumpatleastonceper18monthsforverification
| | distress or corrosion. |
| thatthescreensshownoevidenceofstructural
| | A similar inspection |
| distressorcorrosion.
| | is required by Unit 1 Technical Specification |
| Asimilarinspection
| |
| isrequiredbyUnit1Technical
| |
| Specification | |
| 4.5.2.d.2. | | 4.5.2.d.2. |
| Asdiscussed
| | As discussed above, Maintenance |
| above,Maintenance | |
| Surveillance | | Surveillance |
| Procedure | | Procedure MSP-68.01 (" Containment |
| MSP-68.01 | | Sump Inspection")and PSL Nuclear Assurance Quality Control Technique Sheet 10.54 (" Unit 1 and Unit 2 Containment |
| ("Containment | | Sump Inspection")have been issued to provide additional |
| SumpInspection"
| |
| )andPSLNuclearAssurance | |
| QualityControlTechnique
| |
| Sheet10.54("Unit1andUnit2Containment
| |
| SumpInspection"
| |
| )havebeenissuedtoprovideadditional | |
| procedural | | procedural |
| guidanceforECCScontainment
| | guidance for ECCS containment |
| sumpinspections.
| | sump inspections. |
| Thesedocuments
| | These documents provide specific inspection |
| providespecificinspection
| |
| requirements | | requirements |
| forgapsinthesumpscreensaswellasforverification
| | for gaps in the sump screens as well as for verification |
| ofsumpareacleanliness.
| | of sump area cleanliness. |
| Satisfactory | | Satisfactory |
| completion | | completion |
| oftheseprocedures
| | of these procedures |
| willensurethatthephysicalcondition
| | will ensure that the physical condition of the sump screens meets the design requirements. |
| ofthesumpscreensmeetsthedesignrequirements.
| |
| Inspection | | Inspection |
| personnel | | personnel will utilize these documents during future refueling outages to satisfy the Technical Specification |
| willutilizethesedocuments
| |
| duringfuturerefueling
| |
| outagestosatisfytheTechnical
| |
| Specification | |
| requirements. | | requirements. |
| Inordertoprovideassurance
| | In order to provide assurance that the problem noted (inadequate |
| thattheproblemnoted(inadequate
| |
| consideration | | consideration |
| ofgenericconcerns)
| | of generic concerns)will not recur, a Technical Alert addressing |
| willnotrecur,aTechnical
| | this concern has been issued to Engineering |
| Alertaddressing
| | personnel Formalized |
| thisconcernhasbeenissuedtoEngineering
| | training for re-emphasis |
| personnel | | of existing procedural |
| Formalized | | guidance will be provided as part of scheduled Engineering |
| trainingforre-emphasis
| | Support Personnel (ESP)training;this training will be completed by March 26, 1999.In order to provide assurance that future condition reports will not be approved without adequate consideration |
| ofexistingprocedural
| | of generic concerns, a training |
| guidancewillbeprovidedaspartofscheduled
| | L-99-028 Attachment |
| Engineering | | Page 5 of 5 bulletin for re-emphasis |
| SupportPersonnel
| | of existing procedural |
| (ESP)training; | | guidance was issued to St.Lucie management |
| thistrainingwillbecompleted
| | personnel responsible |
| byMarch26,1999.Inordertoprovideassurance
| | for approving Condition Report dispositions. |
| thatfuturecondition
| | d.Future pre-outage |
| reportswillnotbeapprovedwithoutadequateconsideration
| | Employee Communication |
| ofgenericconcerns,
| | meetings will re-emphasize |
| atraining
| |
| L-99-028Attachment | |
| Page5of5bulletinforre-emphasis
| |
| ofexistingprocedural
| |
| guidancewasissuedtoSt.Luciemanagement
| |
| personnel | |
| responsible | |
| forapproving
| |
| Condition | |
| Reportdispositions.
| |
| d.Futurepre-outage | |
| EmployeeCommunication
| |
| meetingswillre-emphasize
| |
| management | | management |
| expectations | | expectations |
| concerning | | concerning |
| theneedtothoroughly
| | the need to thoroughly |
| investigate | | investigate |
| outagediscovery
| | outage discovery items, including the consideration |
| items,including | | of generic implications |
| theconsideration
| | as part of the corrective |
| ofgenericimplications
| | action plan.Date of Full Com liance Full compliance |
| aspartofthecorrective
| | was achieved on December 2, 1998, upon implementation |
| actionplan.DateofFullComlianceFullcompliance
| | of PC/M 98-029 which included modifications |
| wasachievedonDecember2,1998,uponimplementation
| | to the ECCS containment |
| ofPC/M98-029whichincludedmodifications
| | sump screens necessary to meet design requirements. |
| totheECCScontainment
| | This PC/M was completed prior to the Unit 2 startup following the SL2-11 refueling outage. |
| sumpscreensnecessary
| |
| tomeetdesignrequirements.
| |
| ThisPC/Mwascompleted
| |
| priortotheUnit2startupfollowing
| |
| theSL2-11refueling
| |
| outage. | |
| }} | | }} |
|
---|
Category:CORRESPONDENCE-LETTERS
MONTHYEARML17241A5001999-10-21021 October 1999 Forwards Rev 3 to Emergency Response Data Sys (ERDS) Data Point Library for St Lucie Unit 1.Rev Provides Replacement Pages & Follows Format Recommended by NUREG 1394, ERDS Implementation, Rev 1,App C ML17309A9981999-10-19019 October 1999 Forwards Revised Epips,Including Rev 3 to EPIP-10 & Rev 25 to HP-202.EPIP-10 Added Onsite Monitoring Points,Made Administrative Changes & Incorporated New Attachments & HP-202 Added Red Team Survey Points ML20217F6171999-10-0808 October 1999 Forwards Insp Repts 50-335/99-11 & 50-389/99-11 on 990827 & 990907-09.No Violations Identified.Matl Encl Contained Safeguards Info as Defined by 10CFR73.21 & Disclosed to Unauthorized Individuals Prohibited by Section 147 of AEA ML17241A4811999-10-0101 October 1999 Reports Number of Tubes Plugged During Unit 1 Refueling Outage SL1-16,per TS 4.4.5.5.a ML20212M1601999-09-28028 September 1999 Refers to 990908 Engineering Meeting Conducted at NRC Region II to Discuss Engineering Issues at Lucie & Turkey Point Facilities.List of Attendees & Copy of Presentation Handout Encl ML17241A4701999-09-25025 September 1999 Forwards Info Requested by NRC Staff During 990916 Telcon to Complete Staff Review of Request for risk-informed Extension of Action Completion/Aot Specified for Inoperable Train of LPSI Sys at Plant ML17241A4721999-09-24024 September 1999 Forwards Rev 1 to Plant Change/Mod (PCM) 99016 to St Lucie Unit 1,Cycle 16 COLR, IAW TS 6.9.1.11.d.Refueling Overhaul Activities Are Currently in Progress & Reactor Operations for Cycle 16 Are Scheduled to Commence in Oct 1999 ML17241A4681999-09-22022 September 1999 Requests Restriction Be Added to Senior Operator License SOP-21093 for TE Bolander.Nrc Forms 369,encl.Encl Withheld Per 10CFR2.790(a)(6) ML17241A4671999-09-20020 September 1999 Forwards Completed NRC Form 536, Operator Licensing Exam Data, for St Lucie Units 1 & 2,as Requested in Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams. ML17241A4581999-09-13013 September 1999 Forwards Info Requested by NRC Staff During 990630 & 0816 Telcons,To Complete Review of Proposed License Amend for Fuel Reload Process Improvement Program ML17241A4531999-08-31031 August 1999 Informs That No Candidates from St Lucie Plant Will Be Participating in PWR Gfes Being Administered on 991006 ML17241A4521999-08-31031 August 1999 Withdraws Relief Request 16 & Suppl Relief Request 15 with Info Requested During 990526 Telephone Conference Re ISI Insp Plan,Third 10-yr Interval ML17241A4501999-08-26026 August 1999 Informs That FPL Has Reviewed Reactor Vessel Integrity Database,Called RVID2,re Closure of GL 92-01,rev 1,suppl 1. Requested Corrections & Marked Up Pages from Rvid 2 Database Summary Repts That Correspond to Comments,Attached ML17241A4371999-08-13013 August 1999 Forwards fitness-for-duty Program Performance Data for six- Month Period Ending 990630,per 10CFR26.71(d) ML17241A4461999-08-11011 August 1999 Requests That W Rept Entitled, Evaluation of Turbine Missile Ejection Probability Resulting from Extending Test Interval of Interceptor & Reheat Stop Valves at St Lucie Units 1 & 2, Be Withheld from Public Disclosure L-99-171, Forwards Rev 56 to Physical Security Plan.Summary of Changes & Marked Up Copy of Revised Pages Also Encl.Encls Withheld from Public Disclosure Per 10CFR2.790(a)(3)1999-07-29029 July 1999 Forwards Rev 56 to Physical Security Plan.Summary of Changes & Marked Up Copy of Revised Pages Also Encl.Encls Withheld from Public Disclosure Per 10CFR2.790(a)(3) ML17309A9911999-07-26026 July 1999 Forwards Revised EPIPs & Revised Procedures That Implement Emergency Plan as Listed.Procedures Provides Instruction for Operational Support Ctr (OSC) Chemistry Supervisor to Establish Remote Labs at Locations Specified ML17241A4471999-07-22022 July 1999 Requests That Rev 1 to WCAP-14732 & Rev 1,Add 1 to WCAP-14732 Be Withheld from Public Disclosure ML17241A4221999-07-22022 July 1999 Forwards List of Proposed Licensing Actions for St Lucie Units 1 & 2,planned During Fys 2000 & 2001,in Response to Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates. ML17241A4151999-07-22022 July 1999 Forwards Revised Relief Request 25 for Second 10-yr ISI Interval for Unit 2 ML17241A4101999-07-16016 July 1999 Forwards FP&L Supplemental Response to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants ML17309A9881999-07-0707 July 1999 Forwards Rev 5 to EPIP-03, Emergency Response Organization Notification/Staff Augmentation. Rev 5 to EPIP-03 Was Revised to Transfer EP Responsibilities from Training Manager to Protection Svcs Manager ML20209F1541999-07-0606 July 1999 Informs That NRC in Process of Conducting Operational Safeguards Response Evaluations at Nuclear Power Reactors. Plant Chosen for Such Review Scheduled for Wk of 990823-26 ML17241A4011999-06-30030 June 1999 Forwards Info Copy of Florida Wastewater Permit (FL0002208) (Formerly NPDES Permit) Mod,Which Was Issued by Florida Dept of Environ Protection on 990604 ML17241A3971999-06-30030 June 1999 Forwards Suppl Response to GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs, as Requested in 990317 Ltr ML17355A3661999-06-30030 June 1999 Forwards Florida Power & Light Topical QA Rept, Dtd June 1999.Encl I Includes Summary of Changes Made to Topical QA Rept Since 1998 ML17241A3951999-06-29029 June 1999 Provides Response to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants.Gl 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants, Requested Response on Status of Facility Y2K Readiness by 990701.Disclosure Encl ML17241A3731999-06-17017 June 1999 Supplements Relief Requests 4,11 & 13 for Third ten-year ISI Interval with Info Requested During 990526 Telcon.Expedited Review Is Requested by 990730 to Avoid Negatively Impacting Upcoming St Lucie Unit 1 Refueling Outage (SL1-16) ML17241A3641999-06-14014 June 1999 Submits Supplement to Relief Request 24 with Info Requested by Nrc.In Addition Relief Request 24 Is Identical to St Lucie Unit 1 Relief Request 4 for Third ISI Interval Being Supplemented by FPL Ltr L-99-139 ML20195F3871999-06-11011 June 1999 Final Response to FOIA Request for Documents.App a Records Being Withheld in Entirety (Ref FOIA Exemption 5) IA-99-247, Final Response to FOIA Request for Documents.App a Records Being Withheld in Entirety (Ref FOIA Exemption 5)1999-06-11011 June 1999 Final Response to FOIA Request for Documents.App a Records Being Withheld in Entirety (Ref FOIA Exemption 5) L-99-129, Forwards Rev 55 to Physical Security Plan,Summary of Changes & Marked Up Copy of Revised Pages.With Directions for Incorporating Rev Into Plan & Copies of Replacement Pages.Rev Withheld,Per 10CFR2.790(a)(3)1999-06-0909 June 1999 Forwards Rev 55 to Physical Security Plan,Summary of Changes & Marked Up Copy of Revised Pages.With Directions for Incorporating Rev Into Plan & Copies of Replacement Pages.Rev Withheld,Per 10CFR2.790(a)(3) ML17241A3561999-06-0707 June 1999 Forwards Rept Containing Brief Description & Summary of SEs for Changes,Tests & Experiments Which Were Approved for Unit 3 During Period of 970526-981209 ML17241A3601999-06-0707 June 1999 Forwards Correction to Annual Radiological Environ Operating Rept for CY98.Util Has Identified Transcription Error on Last Page of Attachment C of Rept,Results from Interlaboratory Comparison Program 1998 ML20195F3941999-05-27027 May 1999 FOIA Request That Memo from J Calvo to Fl Lebdon Re TIA - St Lucie,Unit 1 Environ Qualification of Woodward Governor Controls Be Placed in PDR ML17241A3461999-05-24024 May 1999 Forwards Revised Relief Request 22 to Clarify Several Areas of Relief.Nrc Action Is Requested to Be Complete by Aug 1999 to Support Planning for Spring 2000 Unit 2 Refueling Outage ML17241A3391999-05-20020 May 1999 Forwards Notification of Change to Small Break LOCA ECCS Evaluation Model Used for St Lucie Unit 1.Anomaly Was Discovered & Corrected That Resulted in Reducing Calculated PCT for Limiting SBLOCA by More than 50 F ML17241A3371999-05-20020 May 1999 Forwards Util Suppl to GL 95-07 Response Re pressure-locking & Thermal Binding of safety-related power-operated Gate Valves,In Response to NRC Second RAI Dtd 990225 ML20207C7531999-05-17017 May 1999 Discusses Issue Identified by FPL in Feb 1998 Involving Potential for Fire to Cause Breach of Rc Sys High/Low Pressure Interface Boundary & NRC Decision for Exercise of Enforcement Discretion ML17241A3301999-05-17017 May 1999 Forwards LER 99-004-00 Re as Found Cycle 10 Psv Setpoints Outside TS Limits,Which Occurred on 990415.Root Cause Determination Not Yet Complete.Suppl to Include Root Cause & Corrective Actions Will Be Submitted ML17309A9821999-05-10010 May 1999 Forwards Rev 36 to St Lucie Emergency Plan, Per 10CFR50.54(q).Executive Summary & Summary of Changes Incorporated by Rev,Encl IR 05000335/19980141999-04-29029 April 1999 Provides Confirmation of NRC Staff Conclusions Re Cited & non-cited Violations in Insp Rept 50-335/98-14 & 50-389/98-14.Utils Position Re Consideration of Multiple Spurious Actuations in Event of Fire,Reiterated ML17241A3221999-04-29029 April 1999 Provides Confirmation of NRC Staff Conclusions Re Cited & non-cited Violations in Insp Rept 50-335/98-14 & 50-389/98-14.Utils Position Re Consideration of Multiple Spurious Actuations in Event of Fire,Reiterated ML17229B1071999-04-28028 April 1999 Forwards 1998 Annual Environ Operating Rept for St Lucie Unit 2. Rept Includes Discussions of 5-inch Barrier Net Maint & Taprogge Condenser Tube Cleaning Sys Ball Loss,As Agreed at First Biennial Sea Turtle Meeting Held on 980120 ML17229B1051999-04-22022 April 1999 Requests That Listed Individuals Be Placed on Official Serve List for Nuclear Matl Safety & Safeguards Info Notices ML17229B1061999-04-21021 April 1999 Notifies NRC of Change in Medical Status of Licensed Operator Pf Farnsworth (Docket 55-21285,license SOP-21094). NRC Form 3996, Medical Exam Certification, Encl.Encl Withheld Per 10CFR2.790(a)(6) ML17309A9851999-04-15015 April 1999 Requests That NRC Review Denial of Appeal from Assessment of Fees Assessed in 981101 Invoice RS0062-99 & Assessment of Fees in Invoice RS0182-99 Which Was Also Denied in 990305 Ltr.Both Invoices Are for Fees Re Inspector GG Warnick ML20205M0431999-04-13013 April 1999 Eighth Partial Response to FOIA Request for Records.App Q & R Records Encl & Being Made Available in PDR ML17229B0951999-04-0808 April 1999 Requests Approval of Encl Revised Relief Request 6,in Response to 990322 Telcon with NRC & 10CFR55.55a(a)(3). Request States That Visual VT-3 Exams Will Be Conducted IAW IWA-2213 & Repairs Will Be IAW Util ASME Section IX Program ML17229B0821999-04-0707 April 1999 Requests Approval of Interim Relief Request 26 Re Repair Requirements for Class 2 ECCS Piping,Per 10CFR50.55a(a)(3) & 50.55a(g)(iii).Alternative Actions Apply Guidance of GLs 91-18 & 90-05 & ASME Code Case N-513.Evaluation,encl 1999-09-28
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML17241A5001999-10-21021 October 1999 Forwards Rev 3 to Emergency Response Data Sys (ERDS) Data Point Library for St Lucie Unit 1.Rev Provides Replacement Pages & Follows Format Recommended by NUREG 1394, ERDS Implementation, Rev 1,App C ML17309A9981999-10-19019 October 1999 Forwards Revised Epips,Including Rev 3 to EPIP-10 & Rev 25 to HP-202.EPIP-10 Added Onsite Monitoring Points,Made Administrative Changes & Incorporated New Attachments & HP-202 Added Red Team Survey Points ML17241A4811999-10-0101 October 1999 Reports Number of Tubes Plugged During Unit 1 Refueling Outage SL1-16,per TS 4.4.5.5.a ML17241A4701999-09-25025 September 1999 Forwards Info Requested by NRC Staff During 990916 Telcon to Complete Staff Review of Request for risk-informed Extension of Action Completion/Aot Specified for Inoperable Train of LPSI Sys at Plant ML17241A4721999-09-24024 September 1999 Forwards Rev 1 to Plant Change/Mod (PCM) 99016 to St Lucie Unit 1,Cycle 16 COLR, IAW TS 6.9.1.11.d.Refueling Overhaul Activities Are Currently in Progress & Reactor Operations for Cycle 16 Are Scheduled to Commence in Oct 1999 ML17241A4681999-09-22022 September 1999 Requests Restriction Be Added to Senior Operator License SOP-21093 for TE Bolander.Nrc Forms 369,encl.Encl Withheld Per 10CFR2.790(a)(6) ML17241A4671999-09-20020 September 1999 Forwards Completed NRC Form 536, Operator Licensing Exam Data, for St Lucie Units 1 & 2,as Requested in Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams. ML17241A4581999-09-13013 September 1999 Forwards Info Requested by NRC Staff During 990630 & 0816 Telcons,To Complete Review of Proposed License Amend for Fuel Reload Process Improvement Program ML17241A4531999-08-31031 August 1999 Informs That No Candidates from St Lucie Plant Will Be Participating in PWR Gfes Being Administered on 991006 ML17241A4521999-08-31031 August 1999 Withdraws Relief Request 16 & Suppl Relief Request 15 with Info Requested During 990526 Telephone Conference Re ISI Insp Plan,Third 10-yr Interval ML17241A4501999-08-26026 August 1999 Informs That FPL Has Reviewed Reactor Vessel Integrity Database,Called RVID2,re Closure of GL 92-01,rev 1,suppl 1. Requested Corrections & Marked Up Pages from Rvid 2 Database Summary Repts That Correspond to Comments,Attached ML17241A4371999-08-13013 August 1999 Forwards fitness-for-duty Program Performance Data for six- Month Period Ending 990630,per 10CFR26.71(d) ML17241A4461999-08-11011 August 1999 Requests That W Rept Entitled, Evaluation of Turbine Missile Ejection Probability Resulting from Extending Test Interval of Interceptor & Reheat Stop Valves at St Lucie Units 1 & 2, Be Withheld from Public Disclosure L-99-171, Forwards Rev 56 to Physical Security Plan.Summary of Changes & Marked Up Copy of Revised Pages Also Encl.Encls Withheld from Public Disclosure Per 10CFR2.790(a)(3)1999-07-29029 July 1999 Forwards Rev 56 to Physical Security Plan.Summary of Changes & Marked Up Copy of Revised Pages Also Encl.Encls Withheld from Public Disclosure Per 10CFR2.790(a)(3) ML17309A9911999-07-26026 July 1999 Forwards Revised EPIPs & Revised Procedures That Implement Emergency Plan as Listed.Procedures Provides Instruction for Operational Support Ctr (OSC) Chemistry Supervisor to Establish Remote Labs at Locations Specified ML17241A4221999-07-22022 July 1999 Forwards List of Proposed Licensing Actions for St Lucie Units 1 & 2,planned During Fys 2000 & 2001,in Response to Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates. ML17241A4471999-07-22022 July 1999 Requests That Rev 1 to WCAP-14732 & Rev 1,Add 1 to WCAP-14732 Be Withheld from Public Disclosure ML17241A4151999-07-22022 July 1999 Forwards Revised Relief Request 25 for Second 10-yr ISI Interval for Unit 2 ML17241A4101999-07-16016 July 1999 Forwards FP&L Supplemental Response to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants ML17309A9881999-07-0707 July 1999 Forwards Rev 5 to EPIP-03, Emergency Response Organization Notification/Staff Augmentation. Rev 5 to EPIP-03 Was Revised to Transfer EP Responsibilities from Training Manager to Protection Svcs Manager ML17241A4011999-06-30030 June 1999 Forwards Info Copy of Florida Wastewater Permit (FL0002208) (Formerly NPDES Permit) Mod,Which Was Issued by Florida Dept of Environ Protection on 990604 ML17241A3971999-06-30030 June 1999 Forwards Suppl Response to GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs, as Requested in 990317 Ltr ML17355A3661999-06-30030 June 1999 Forwards Florida Power & Light Topical QA Rept, Dtd June 1999.Encl I Includes Summary of Changes Made to Topical QA Rept Since 1998 ML17241A3951999-06-29029 June 1999 Provides Response to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants.Gl 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants, Requested Response on Status of Facility Y2K Readiness by 990701.Disclosure Encl ML17241A3731999-06-17017 June 1999 Supplements Relief Requests 4,11 & 13 for Third ten-year ISI Interval with Info Requested During 990526 Telcon.Expedited Review Is Requested by 990730 to Avoid Negatively Impacting Upcoming St Lucie Unit 1 Refueling Outage (SL1-16) ML17241A3641999-06-14014 June 1999 Submits Supplement to Relief Request 24 with Info Requested by Nrc.In Addition Relief Request 24 Is Identical to St Lucie Unit 1 Relief Request 4 for Third ISI Interval Being Supplemented by FPL Ltr L-99-139 L-99-129, Forwards Rev 55 to Physical Security Plan,Summary of Changes & Marked Up Copy of Revised Pages.With Directions for Incorporating Rev Into Plan & Copies of Replacement Pages.Rev Withheld,Per 10CFR2.790(a)(3)1999-06-0909 June 1999 Forwards Rev 55 to Physical Security Plan,Summary of Changes & Marked Up Copy of Revised Pages.With Directions for Incorporating Rev Into Plan & Copies of Replacement Pages.Rev Withheld,Per 10CFR2.790(a)(3) ML17241A3601999-06-0707 June 1999 Forwards Correction to Annual Radiological Environ Operating Rept for CY98.Util Has Identified Transcription Error on Last Page of Attachment C of Rept,Results from Interlaboratory Comparison Program 1998 ML17241A3561999-06-0707 June 1999 Forwards Rept Containing Brief Description & Summary of SEs for Changes,Tests & Experiments Which Were Approved for Unit 3 During Period of 970526-981209 ML20195F3941999-05-27027 May 1999 FOIA Request That Memo from J Calvo to Fl Lebdon Re TIA - St Lucie,Unit 1 Environ Qualification of Woodward Governor Controls Be Placed in PDR ML17241A3461999-05-24024 May 1999 Forwards Revised Relief Request 22 to Clarify Several Areas of Relief.Nrc Action Is Requested to Be Complete by Aug 1999 to Support Planning for Spring 2000 Unit 2 Refueling Outage ML17241A3371999-05-20020 May 1999 Forwards Util Suppl to GL 95-07 Response Re pressure-locking & Thermal Binding of safety-related power-operated Gate Valves,In Response to NRC Second RAI Dtd 990225 ML17241A3391999-05-20020 May 1999 Forwards Notification of Change to Small Break LOCA ECCS Evaluation Model Used for St Lucie Unit 1.Anomaly Was Discovered & Corrected That Resulted in Reducing Calculated PCT for Limiting SBLOCA by More than 50 F ML17241A3301999-05-17017 May 1999 Forwards LER 99-004-00 Re as Found Cycle 10 Psv Setpoints Outside TS Limits,Which Occurred on 990415.Root Cause Determination Not Yet Complete.Suppl to Include Root Cause & Corrective Actions Will Be Submitted ML17309A9821999-05-10010 May 1999 Forwards Rev 36 to St Lucie Emergency Plan, Per 10CFR50.54(q).Executive Summary & Summary of Changes Incorporated by Rev,Encl ML17241A3221999-04-29029 April 1999 Provides Confirmation of NRC Staff Conclusions Re Cited & non-cited Violations in Insp Rept 50-335/98-14 & 50-389/98-14.Utils Position Re Consideration of Multiple Spurious Actuations in Event of Fire,Reiterated IR 05000335/19980141999-04-29029 April 1999 Provides Confirmation of NRC Staff Conclusions Re Cited & non-cited Violations in Insp Rept 50-335/98-14 & 50-389/98-14.Utils Position Re Consideration of Multiple Spurious Actuations in Event of Fire,Reiterated ML17229B1071999-04-28028 April 1999 Forwards 1998 Annual Environ Operating Rept for St Lucie Unit 2. Rept Includes Discussions of 5-inch Barrier Net Maint & Taprogge Condenser Tube Cleaning Sys Ball Loss,As Agreed at First Biennial Sea Turtle Meeting Held on 980120 ML17229B1051999-04-22022 April 1999 Requests That Listed Individuals Be Placed on Official Serve List for Nuclear Matl Safety & Safeguards Info Notices ML17229B1061999-04-21021 April 1999 Notifies NRC of Change in Medical Status of Licensed Operator Pf Farnsworth (Docket 55-21285,license SOP-21094). NRC Form 3996, Medical Exam Certification, Encl.Encl Withheld Per 10CFR2.790(a)(6) ML17309A9851999-04-15015 April 1999 Requests That NRC Review Denial of Appeal from Assessment of Fees Assessed in 981101 Invoice RS0062-99 & Assessment of Fees in Invoice RS0182-99 Which Was Also Denied in 990305 Ltr.Both Invoices Are for Fees Re Inspector GG Warnick ML17229B0951999-04-0808 April 1999 Requests Approval of Encl Revised Relief Request 6,in Response to 990322 Telcon with NRC & 10CFR55.55a(a)(3). Request States That Visual VT-3 Exams Will Be Conducted IAW IWA-2213 & Repairs Will Be IAW Util ASME Section IX Program ML17229B0821999-04-0707 April 1999 Requests Approval of Interim Relief Request 26 Re Repair Requirements for Class 2 ECCS Piping,Per 10CFR50.55a(a)(3) & 50.55a(g)(iii).Alternative Actions Apply Guidance of GLs 91-18 & 90-05 & ASME Code Case N-513.Evaluation,encl ML17229B0851999-04-0505 April 1999 Requests Approval of Encl Relief Request 25 Which Proposes to Use Alternative Requirements of ASME Code Case N-613 in Lieu of Requirements of ASME Section XI Figures IWB-2500-7(a) & IWB-2500-7(b).Action Requested by Aug 1999 ML17309A9791999-03-31031 March 1999 Forwards Revised EPIPs Including Rev 2 to EPIP-00,rev 2 to EPIP-09,rev 2 to EPIP-10 & Rev 10 to HP-207.Summary of Revs Listed ML17309A9761999-03-23023 March 1999 Forwards Revised Epips,Including Rev 4 to EPIP-03, Er Organization Notification/Staff Augmentation, Rev 3 to EPIP-05, Activation & Operation of OSC & Rev 14 to HP-200, HP Emergency Organization. Changes to Epips,Discussed ML17229B0691999-03-19019 March 1999 Transmits TS Pages Requested by NRC for Use in Issuance of Proposed License Amend Re SFP Storage Capacity,Per Soluble Boron Credit ML17229B0721999-03-16016 March 1999 Requests Approval of Enclosed Relief Requests 23 & 24 Re ISI Plan for Second ten-year Interval.Nrc Action Is Requested to Be Complete by Aug 1999 to Support Planning for Spring 2000 Unit 2 Refueling Outage ML17355A2631999-03-12012 March 1999 Forwards FPL Decommissioning Fund Status Repts for St Lucie, Units 1 & 2 & Turkey Point,Units 3 & 4.Rept for St Lucie, Unit 2 Provides Status of Decommissioning Funds for All Three Owners of That Unit ML17229B0481999-03-10010 March 1999 Informs That Util Delivered Matls Requested in Encl 1 of NRC Ltr by Hand on 990308,as Requested by NRC Ltr Dtd 990218 1999-09-25
[Table view] |
See also: IR 05000389/1998011
Text
CATEGORY j.REGULATORY
INFORMATION
DISTRIBUTION
SYSTEM (RIDS)ACCESSION NBR:9902120166
DOC.DATE: 99/02/04 NOTARIZED:
NO~~~~~~~~~~FACIL:50-389
St.Lucie Plant, Unit 2, Florida Power 6 Light Co.AUTH.NAME.AUTHOR AFFILIATION
PLUNKETT,T.F.'lorida
Power S Light Co.RECIP.NAME'ECIPIENT AFFILIATION
Records Management
Branch (Document Control Desk)SUBJECT: Forwards response to violations
noted in insp rept 50-389/98-11.Corrective
actions:addi
procedural
guidance developed for ECCS containment
sump insps for Units 1&2.Mode 1 walkdown of Unit 1 also performed.
DISTRIBUTION
CODE: IE01D COPIES RECEIVED:LTR
ENCL SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice
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Florida Power&Light Company, P.0.Box14000,Juno
Beach, FL33408.0420
February 4, 1999 L-99-028 10 CFR 2.201 U.S.Nuclear Regulatory
Commission
Attn: Document Control Desk Washington, D.C.20555 Re: St.Lucie Unit 2 Docket No.50-389 Reply to a Notice of Violation NRC Ins ection Re ort 98-11 Florida Power and Light Company (FPL)has reviewed the subject Notice of Violation and, pursuant to 10 CFR$2.201, the response to the violation is attached.As discussed in the violation response, the Unit 2 Spring 1997 refueling outage sump screen repair and disposition
activities
failed to adequately
consider the generic implications
of the identified
discrepancies.
St.Lucie site personnel are being trained to reinforce the requirements
of the St.Lucie corrective
action program.Please contact us with questions on the enclosed violation response.Very truly yours, Thomas F.Plunkett President Nuclear Division TFP/JAS/E JW Attachment
cc: Regional Administrator, USNRC, Region II Senior Resident Inspector, USNRC, St.Lucie Plant 9902120i66
990204 PDR ADOCK 05000389 P PDR an FPL Group company
L-99-028 Attachment
Page 1 of 5 VIOLATION Part 50 of Title 10 of the Code of Federal Regulations
(10 CFR 50), Appendix B, Criterion XVI requires that measures shall be established
to assure that conditions
adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances
are promptly identified
and corrected.
Contrary to the above, as of November 15, 1998, conditions
adverse to quality were not promptly identified
and corrected involving the Unit 2 emergency core cooling systems (ECCS)containment
sump.Specifically, in May 1997, corrective
actions were implemented
to address gaps and openings in the ECCS containment
sump screens in excess of design requirements
described in the Updated Final Safety Analysis Report.However, as evidenced by the identification.
of approximately
100 additional
discrepancies
in November 1998, the corrective
actions in May 1997 were not effective in identifying
and correcting
the deficiencies, and the sump was not restored to design requirements.
This is a Severity IV Level violation (Supplement
1).RESPONSE 1.A reement with or Denial o the Violation FPL concurs with the violation.
Reason for the Violation The failure of the corrective
actions performed in May 1997 to effectively
identify and correct deficiencies, and to restore the ECCS containment
sump to design requirements, is primarily the result of inadequate
consideration
of generic implications
of the documented
deficiencies (i.e., consideration
of the potential for deficiencies
in all areas of the Unit 2 sump screens).In May 1997, near the end of the Spring 1997 Unit 2 refueling outage (SL2-10), the NRC Resident Inspector noted discrepancies
in the construction
of the ECCS containment
sump screen.These discrepancies
involved gaps between the divider screen and the outer vertical screen, and between the divider screen and the concrete wall.Condition Report 97-1102 was written to document these discrepancies, and Plant Change/Modification (PC/M)97-037 was written for the implementation
of required repairs.FPL performed additional
inspections
of the divider screen, and noted additional
discrepancies.
During the implementation
of
L-99-028 Attachment
Page 2 of 5 the required repairs, other minor gaps were noted in the divider screen and in the horizontal
screen at the top of the sump;these gaps were also documented
in Condition Report 97-1102 and repaired pursuant to PC/M 97-037.During this period, FPL efforts were focused on the repair of the gaps noted at the divider screen and the horizontal
screen.The areas of concern noted by the NRC Resident dealt with gaps between the divider screen and the outer screen, and between the divider screen and the concrete wall (i.e., discrepancies
that would allow the passage of debris from one side of the sump to the other side, thus potentially
affecting both ECCS trains).Additional
inspections
performed by FPL during the SL2-10 refueling outage to address generic concerns for Unit 2 were originally
limited to the divider screen;aAer discrepancies
were observed in the horizontal
screens, the scope of inspections
was increased to include the horizontal
screens.A commitment
was made (and fulfilled)
to prepare guidelines
for inspection
of the sump screens for both Units 1 and 2 during future outages.However, St.Lucie did not recognize that the scope of generic concerns to be addressed during the SL2-10 outage should have been expanded to include the vertical outer screens, to provide complete assurance (a)that all sump screen deficiencies
were identified
and corrected and (b)that the design requirements
for'the ECCS containment
sump were satisfied.
The gaps in the divider screen were discovered
during the Spring 1997 Mode 4 containment
closeout walkdown.The implicit awareness by personnel of the schedule for unit re-start (inherent during refueling outages)was a factor in the.narrow focus of corrective
action which failed to identify the need for additional
inspections
to be performed to address generic concerns.During the disposition
of these discrepancies, generic implications
for Unit 1 were considered.
Since the design of the Unit 1 screens has a completely
different configuration
than Unit 2 (with no divider screen), FPL determined
that no immediate actions were required for Unit l.A subsequent
Mode 1 power entry was performed as described below in corrective
action 3.b.Detailed inspections
and repairs of the Unit 1 screens were performed during the, Fall 1997 Unit 1 refueling outage (SL1-15).Based on these facts, FPL has determined
that the reason for this violation (ineffective
corrective
actions)was the fact that insufficient
attention and consideration
were given to generic concerns (i.e., the potential for discrepancies
in the vertical outer screeris and the horizontal
screens)subsequent
to the discovery of gaps in the divider screen.
L-99-028 Attachment
Page 3 of 5 3.Corrective
Ste s Taken and Results Achieved Subsequent
to the SL2-10 refueling outage, additional
procedural
guidance was developed for ECCS containment
sump inspections
for Units 1 and 2 to provide specific inspection
requirements
for gaps in the sump screen as well as for verification
of sump area cleanliness.
The procedural
guidance is intended to ensure that the physical condition of the sump screens meets the design requirements.
The required guidance was issued via Maintenance
Surveillance
Procedure MSP-68.01 (" Containment
Sump Inspection")and PSL Nuclear Assurance Quality Control Technique Sheet 10.54 (" Unit 1 and Unit 2 Containment
Sump Inspection").Subsequent
to the SL2-10 refueling outage, a Mode 1 walkdown of Unit 1 was performed to inspect the accessible
areas of the Unit 1 ECCS containment
sump screens.Only the horizontal
screen at the top of the sump could be inspected during this walkdown.Eight minor discrepant
conditions
were found;an engineering
evaluation
concluded that there were no operability
concerns associated
with these conditions.
Two of these discrepancies
were repaired immediately.
The remaining six discrepancies
were repaired during the next Unit 1 refueling outage (SL1-15);see paragraph c, below.These discrepancies, and the evaluation
of the as-found condition, were documented
in Condition Report No.97-1465, Supplement
1.C.During the SL1-15 refueling outage (the first outage subsequent
to the issuance of the procedural
guidance discussed in paragraph a, above), the Unit 1 ECCS containment
sump screens were inspected in detail in accordance
with MSP-68.01 and Technique Sheet 10.54.No , discrepancies
were observed on the inner screens.Several discrepancies
were documented
with regard to the outer screens and the sump itself.These discrepancies
were documented
and evaluated in Condition Report No.97-2225 and Plant Management
Action-Item
No.97-12-166.
FPL concluded that there were no outstanding
operability
concerns or reportability
issues.Required repairs to the sump screens were performed in accordance
with PC/M 97-058.During the Fall 1998 Unit 2 refueling outage (SL2-11), a detailed,.comprehensive
inspection
of the Unit 2 ECCS containment
sump screens was performed in accordance
with MSP-68.01 and Technique Sheet 10.54.This was the first Unit 2 outage subsequent
to the issuance of the detailed procedural
guidance discussed in paragraph a, above.A total of 101 discrepant
conditions, along with a limited number of inaccessible
areas, were identified
during this inspection.
These conditions
were documented
~r 0
L-99-028 Attachment
Page 4 of 5 and evaluated in Condition Report No.98-1766 and 98-1766 (Supplements
1 and 2).The sump screen discrepancies
which required repair were corrected in accordance
with PC/M 98-029.All other identified
sump screen discrepancies, including any potential deficiencies
associated
with the inaccessible
sump screen areas, were dispositioned
as an acceptable
configuration.
FPL concluded (a)that there were no operability
concerns associated
with the as-found condition (with the unit off line), and (b)that the evaluation
for safety significance
provided for the discrepancies
discovered
during the SL2-10 refueling outage bounded the newly discovered
anomalies.
FPL determined
that the discrepancies
were reportable
under 10 CFR 50.73 as"a condition outside the design basis of the plant".FPL issued a revision to LER 50-389/97-02, in which the discrepancies
were attributed
to (a)a failure to properly implement the design requirements
during original construction
and (b)inadequate
inspections.
4.Corrective
Ste s to Avoid Future Violations
St.Lucie Unit 2 Technical Specification
4.5.2.e.2 requires a visual inspection
of the containment
sump at least once per 18 months for verification
that the screens show no evidence of structural
distress or corrosion.
A similar inspection
is required by Unit 1 Technical Specification
4.5.2.d.2.
As discussed above, Maintenance
Surveillance
Procedure MSP-68.01 (" Containment
Sump Inspection")and PSL Nuclear Assurance Quality Control Technique Sheet 10.54 (" Unit 1 and Unit 2 Containment
Sump Inspection")have been issued to provide additional
procedural
guidance for ECCS containment
sump inspections.
These documents provide specific inspection
requirements
for gaps in the sump screens as well as for verification
of sump area cleanliness.
Satisfactory
completion
of these procedures
will ensure that the physical condition of the sump screens meets the design requirements.
Inspection
personnel will utilize these documents during future refueling outages to satisfy the Technical Specification
requirements.
In order to provide assurance that the problem noted (inadequate
consideration
of generic concerns)will not recur, a Technical Alert addressing
this concern has been issued to Engineering
personnel Formalized
training for re-emphasis
of existing procedural
guidance will be provided as part of scheduled Engineering
Support Personnel (ESP)training;this training will be completed by March 26, 1999.In order to provide assurance that future condition reports will not be approved without adequate consideration
of generic concerns, a training
L-99-028 Attachment
Page 5 of 5 bulletin for re-emphasis
of existing procedural
guidance was issued to St.Lucie management
personnel responsible
for approving Condition Report dispositions.
d.Future pre-outage
Employee Communication
meetings will re-emphasize
management
expectations
concerning
the need to thoroughly
investigate
outage discovery items, including the consideration
of generic implications
as part of the corrective
action plan.Date of Full Com liance Full compliance
was achieved on December 2, 1998, upon implementation
of PC/M 98-029 which included modifications
to the ECCS containment
sump screens necessary to meet design requirements.
This PC/M was completed prior to the Unit 2 startup following the SL2-11 refueling outage.