ML17229A211

Responds to NRC 961223 Ltr Re Violations Noted in Insp Rept 50-335/96-17.Corrective Actions:Fpl Has Adopted Policy of Verbatim Compliance with Procedural Instructions at St Lucie Plant

ML17229A211
Person / Time
Site:	Saint Lucie
Issue date:	01/28/1997
From:	PLUNKETT T F FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-97-016, L-97-16, NUDOCS 9702030207
Download: ML17229A211 (13)

See also: IR 05000335/1996017

Text

CATEGORY 1 REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)ACCESSION NBR:9702030207

DOC.DATE: 97/01/28 NOTARIZED:

NO ACIL:50-335

St.Lucie Plant, Unit 1, Florida Power&Light Co.AUTEUR.NAME

AUTHOR AFFILIATION

LUNKETT,T.F.

Florida Power 6 Light Co.RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)SUBJECT: Responds to NRC 961223 ltr re violations

noted in insp rept 50-335/96-17.Corrective

actions:FPL

has adopted policy of verbatim compliance

with procedural

instructions

at St Lucie plant.DISTRIBUTION

CODE: ZEOZD COPIES RECEIVED:LTR

i ENCL t SIZE: l0 TITLE: General (50 Dkt)-Insp Rept/Notice

of Violation Response NOTES: DOCKET I 05000335 E RECIPIENT ID CODE/NAME PD2-3 PD INTERNAL: ACRS NRR/DRPM/PERB

OE DIR RGN2 FILE 01 TERNAL: LITCO BRYCEPJ H NRC PDR COPIES LTTR ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME WIENS,L.AEOD/SPD/RAB

DEDRO NRR/DISP/PIPB

NRR/DRPM/PECB

NUDOCS-ABSTRACT

OGC/HDS3 NOAC COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 D N N OTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN SD-5(EXT.4l5-2083)TO ELIMINATE YOUR NAME FROM DISTRIBUTION

LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 19

r.<

Florida Powers Light Company, i.u.Box128, Fort Pierce.FL34954-0120

@PL January 28, 1997 L-9716 10 CFR 2.201 U.S.Nuclear Regulatory

Commission

Attn: Document Control Desk Washington, D.C.20555 Re: St.Lucie Unit 1 Docket No.50-335 Reply to a Notice of Violation Florida Power and Light Company has reviewed the subject Notice of Violation and, pursuant to 10 CFR 2.201, the responses to the violations

are attached.The subject inspection

report was dated December 23, 1996, with a response to the Notice of Violation required within 30 days of that date, i.e., by January 22, 1997.FPL received Integrated

Inspection

Report No.96-17 on December 30, 1996.The seven day delay in the receipt of the inspection

report and Notice of Violation by FPL was discussed with Caudle A.Julian (USNRC/Region

IQ and Edward Weinkam (FPL)on January 9, 1997.In accordance

with the response relief discussed in the Notice of Violation, Mr.Julian granted an extension to the required response date.Very truly yours, T.F.Plunkett President Nuclear Division TFP/JAS/EJW

Attachment

cc: Regional Administrator, USNRC, Region II Senior Resident Inspector, USNRC, St.Lucie Plant 9702030207

970%28 PDR ADOCK 05000335 8 PDR an FPL Group company

L-97416 Attachment

Technical Specification 6.8.1.a, requires that written procedures

shall be established, implemented

and maintained

covering the activities

recommended

in appendix A of Regulatory

Guide 1.33, Revision 2, February 1978.Appendix A, paragraph 7 of RG 1.33 requires procedures

for calibration

of area, process, portable and airborne radiation monitors.I&C Procedure No 1-1220053,"Calibration

of the Control Room Outside Air Intake Monitors," Rev 2, dated September 15, 1994, provides instructions

for calibrating

the control room outside air intake radiation monitors.Step 7.1 of I&C Procedure no 1-1220053, states a completed copy of this procedure shall be maintained

in the plant files in accordance

with QI 17-PR/PSL-1,"Quality Assurance Records." Step 7.2 states a copy of the assay report for the radiation check sources and data sheets associated

with this procedure should be retained and included as a calibration

package upon completion.

Step 9.3.10, of I&C Procedure No 1-1220053, required, in part, that if the high voltage is adjusted more than 50 volts, or a new detector is installed or if monitor cannot be adjusted to within J 10%tolerance go to step 9.4 New Calibration.

Step 9.4, of I&C Procedure No 1-1220053, described the process for performing

a primary calibration

and required, in part, the performance

of a high voltage plateau for determining

operating voltage for the detector.The procedure also required the introduction

of known radioactive

gas in various activity levels to develop an efficiency

curve in pCi/cc vs cpm for the new detector.At least 4 points were required on the graph.Contrary to the above, on April 11, 1995, the licensee replaced the detector for the Unit 1 RE-26-47 Control Room Outside Air Intake Monitor and failed to adequately

perform the primary calibration

in accordance

with I&C Procedure No 1-1220053, in that;the licensee failed to develop an efficiency

curve with at least four calibration

points of known quantities

of radioactive

material as required by step 9.4 of the procedure;

and the licensee failed to maintain calibration

documentation

as required by steps 7.1 and 7.2 of procedure.

'-97-016 turb~s nt>nlv" a k~tirp n'E n(ntinn This is a Severity Level IV violation (Supplement

IV)applicable

to Unit 1 only.1.FPL concurs with the violation.

2.The cause of the violation was personnel error on the part of a utility Instrument

and Control (1&C)Technician

who failed to strictly adhere to an approved plant procedure (1-1220053)

requiring the performance

and documentation

of a primary calibration

of the Control Room Outside Air Intake Radiation Monitor (RE-26-47).

The technician

did not demonstrate

a thorough awareness of the importance

and the specific requirements

related to the implementation

of the calibration

procedure.

A.Since the time of this violation (April 1995)FPL has adopted a policy of verbatim compliance

with procedural

instructions

at St.Lucie Plant.The policy applies to all plant personnel and is currently incorporated

in the St.Lucie Plant Quality Instructions.

B.The Control Room Outside Air Intake Monitor (RE-26-47)

was removed from service on January 6, 1997, pending the performance

of a primary calibration

of the instrument, and a redundant channel (RE-26-46)

was selected for use.C.A primary calibration

was performed using revised I&C Procedure 1-1220053, and a functional

test was completed for Control Room Outside Air Intake Monitor RE-26-47.The monitor was returned to service on January 21, 1997.4.A.The current site philosophy

regarding verbatim compliance

and procedural

adherence was reinforced

to the I&C personnel involved in this event, which actually occurred in April 1995.B.Since the time of this violation (April 1995)FPL has implemented

several key actions to improve personnel performance, including procedure adherence, at St.Lucie Plant.These actions have included increased management

oversight,

L-97-016 Attachment

reinforcement

of management

expectations

at the supervisory

level, and development

of guidelines

for assessing and improving employee performance.

FPL is continuing

to reinforce high standards of personal accountability, including procedural

adherence, to plant personnel at St.Lucie.C.This violation will be incorporated

into the events training program materials for St.Lucie maintenance

personnel to reinforce the expectation

for verbatim procedure compliance

and the importance

of maintaining

documentation

as required by procedures.

This action will be completed by March 31, 1997.5.Full Compliance

was achieved on January 21, 1997, with the completion

of Item 3C, above.Technical Specification 6.8.1.a, requires that written procedures

shall be established, implemented

and maintained

covering the activities

recommended

in appendix A of Regulatory

Guide 1.33, Revision 2, February 1978.Appendix A, paragraph 7 of RG 1.33 requires procedures

for calibration

of area, process, portable and airborne radiation monitors.ISAAC Procedure No 1-1220053,"Calibration

of the Control Room Outside Air Intake Monitors," Rev 2, dated September 15, 1994, provides instructions

for calibrating

the control room outside air intake radiation monitors.Contrary to the above, the procedure for calibrating

the control room outside air intake radiation monitors was inadequate, in that, on April 11, 1995, the procedure did not provide sufficient

guidance for the documentation

of instrument

calibration.

The calibration

records necessary to provide sufficient

documentation

to demonstrate

that a primary calibration

had been performed were not clearly specified by the procedure.

This is a Severity Level IV violation (Supplement

IV)applicable

to Unit 1 only.1~FPL concurs with the violation.

I 97-016 Attachment

2.The cause of the violation was personnel error, in that sufficient

guidance regarding required documentation

records was not incorporated

during the original development

of Prouxiure 1-1220053,"Calibration

of the Control Room Outside Air Intake Monitors," which was written in 1989.Specifically, high voltage and primary curve plots were not properly identified

as records which were required to be maintained

following the performance

of a primary calibration

on this instrumentation.

3.A.I&C Procedure 1-1220053,"Calibration

of the Control Room Outside Air Intake Monitor's" was revised to more clearly specify the requirements

for maintaining

sufficient

documentation

as a record when a primary calibration

has been performed.

The procedure change was approved on January 10, 1997.B.The Control Room Outside Air Intake Monitor (RE-26-47)

was removed from service on January 6, 1997, and a redundant channel (RE-26-46)

was selected for use.A primary calibration

was subsequently

performed using revised I&C procedure 1-1220053 and the monitor was returned to service January 21, 1997.4.A.FPL has identified

several additional

procedures

for review which are currently being used by I&C to calibrate and functionally

test radiation monitoring

instrumentation.

These procedures

will be reviewed to ensure that proper guidance is included to describe the documentation

required to be maintained

as a quality record.This action will be completed by February 28, 1997.B.Recent self assessment

activities

performed by FPL have identified

that procedural

improvements

are necessary to improve the level of detail provided in plant procedures.

FPL has initiated actions to address the weaknesses

which were identified

by the above self assessment

and to ensure that current procedure upgrade initiatives

are adequately

supported, staffed and directed.5.Full compliance

was achieved January 10, 1997, with the completion

of Item 3A, above.

L-97-016 Attachment

5lialatioiij

Technical Specification 6.3.1 states each member of the unit staff shall meet or exceed the minimum qualifications

of ANSI/ANS-3.1-1978.

Technical Specification 6.4.1 states a retraining

and replacement

training program for the unit staff shall be maintained

under the direction of the Training Manager and shall meet or exceed the requirements

and recommendations

of Section 5.5 of ANSUANS-3.1 1978 and 10 CFR Part 55 and the supplemental

requirement

specified in Sections A and C of Enclosure 1 of the March 28, 1980 NRC letter to all licensees, and shall include familiarization

with relevant industry operational

experience.

Licensee procedure QI 2-PR/PSL-2,"Indoctrination

and Training of St Lucie Plant Personnel," revision 23, dated October 23, 1996, states the instruction

shall apply but not be limited to training in several general areas, including 6.0 Job Specific Technical Training.Section 4.1, states the Training Manager shall be responsible

to the Plant General Manager for the establishment

and coordination

of training activities

as required by St.Lucie Plant Technical Specifications, Section 6.4 and as required to meet regulatory

'equirements.

Section 4.3.2 states that department

heads shall be responsible

for approving department

personnel qualification

standards, appropriate

for the duties to be performed.

Section 4.3.3 states that Department

Heads shall ensure that personnel performing

activities

affecting quality receive departmental

training commensurate

with the work performed prior to performing

those activities

or are performing

those activities

under the supervision

of a trained individual

until the required training is complete.Contrary to the above, on July 1, 1996, licensee personnel assigned I&C personnel the responsibilities

to calibrate Unit 1 plant radiation monitoring

instrumentation

utilized to perform certain plant process controls, radiological

monitoring

and continuous

effluent monitoring

functions that were not fully trained and qualified to perform those functions in accordance

with the licensee s training program.This is a Severity Level IV violation (Supplement

IV)applicable

to Unit 1 only,

L-97-016 Attachment

1.FPL concurs with the violation.

2.The cause of this violation was the ineffective

transfer of accountability

for the Unit 1 radiation monitoring

instrumentation

from Chemistry and Health Physics Departments

to the I&C Department

prior to ensuring that the affected I&C personnel had completed all appropriate

training qualifications.

Training for the subject I&C personnel had been scheduled to be implemented

and was postponed by the I&C system supervisor

due to work priorities.

A subsequent

verification

was not made by I&C supervision

to verify that personnel had been fully trained prior to receiving responsibility

for the above instrumentation.

A.A revised schedule was implemented

for the completion

of the specific training and qualification

required for I&C personnel responsible

for performing

radiation monitor calibration

and testing.The above training for these personnel will be completed by March 31, 1997, following a review of the associated

I&C procedures.

B.A supervisor's

meeting was held by the I&C Department

head to address and emphasize the requirements

for obtaining prior department

head approval of changes to scheduled training and ensuring that all personnel are properly and currently trained to perform the tasks which they are assigned.I&C personnel performing

radiation monitoring

calibrations, and functional

checks were required to work under additional

supervisory

oversight pending the completion

of the appropriate

qualification

training.C.Appropriate

Training personnel were counseled on the importance

of informing management

when training or qualification

requirements

are not being adequately

met.4.A.The required training and qualification

of I&C personnel responsible

for performing

calibration

and testing of radiation monitoring

instrumentation

will

L-97-016 Attachment

be completed by March 31, 1997.Additional

supervisory

oversight is being provided until the above training has been completed.

B.St.Lucie Training Department

implemented

a program in which the managers of each department

are informed, on a weekly basis, of training which is scheduled for their personnel.

As part of this process, weekly attendance

is presented to the department

managers, who are notified of any individuals

who have not attended the scheduled training.C.The St.Lucie Maintenance

Manager required that department

heads review and concur with any changes to scheduled training and ensure that personnel in their departments

are fully qualified to perform the tasks which they have been assigned.D.Training Department

guidelines

and administrative

requirements

will be enhanced to require that qualification

training be completed for individuals

who are performing

new tasks, and to better define the responsibility

for ensuring that training is achieved prior to the transfer of task accountability.

This action will be completed by March 31, 1997.E.A recent FPL self-assessment

initiative

recognized

that the transfer of responsibilities

at St.Lucie was not always properly evaluated prior to implementing

site organizational

changes.FPL has since initiated action to address the weaknesses

identified

in the"Change Management" process at St.Lucie and ensure that the impact of future organizational

change is properly assessed, so that the definition

of responsibilities, adequate training, and resources are in place prior to implementing

such changes, 5.Full compliance

will be achieved by March 31, 1997, with the completion

of the training described in Item 4A, above.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, Revision 2, February, 1978.Appendix A, paragraph l.d includes administrative

procedures

for procedural

adherence.

Procedure QI 5-PR/PSL-1, Revision 73,"Preparation, Revision, Review/Approval

Of Procedures," section 5.14.1 requires verbatim compliance

to procedures

by all personnel.

0 L-97-016 Attachment

Operating Surveillance

Procedure 64.01, Revision 16,"Reactor Engineering

Periodic Tests, Checks and Calibrations," Appendix 7,"Reactivity

Deviation From Design," required that reactivity

deviation results be documented

in the Unit 1 Plant Physics Curve Book, Figure B.3,"Reactivity

Deviation Log," upon completion

of the determination

of reactivity

defect.Contrary to the above, the reactivity

deviation calculation

performed on October 8, 1996, was not documented

in the Unit 1 Plant Physics Curve Book.This resulted in operators using an incorrect reactivity

deviation in two Shutdown Margin Verifications

performed on October 31 and November 1, 1996.This is a Severity Level IV violation (Supplement

I)applicable

to Unit 1 only.Bespot&1.FPL concurs with the violation.

2.The cause of the violation was personnel error on the part of Reactor Engineering

personnel who failed to update the Unit 1 Plant Physics Curve Book in accordance

with procedural

requirements

following performance

of a monthly surveillance.

The procedure violation occurred when the Plant Physics Curve Book was not immediately

updated with the current data after the reactivity

deviation value was calculated

as required by Operating Surveillance

Procedure (OSP)64.01.The Reactor Engineer performing

the surveillance

failed to execute proper follow-up and verify that the data was properly recorded in the Plant Physics Curve Book prior to closing the corresponding

surveillance

procedure.

3.A.A Condition Report (CR)was written on November 5, 1996, to evaluate the cause of the event and to determine the appropriate

corrective

actions.B.The Unit 1 Control Room plant physics data was updated to reflect the current value for reactivity

deviation, in accordance

with procedure, following discovery of the above condition on November 5, 1996.C.A review of the Plant Physics Curve Books for both St.Lucie Units 1 and 2

I 97-016 Attachment

BepLy tomHoticeafYialatian

was performed to ensure that no additional

missing data existed.No other missing data was identified

during the review.4, A.Reactor Engineering

performed a self assessment

of the process in place for updating information

in the Plant Physics Curve Books.As a result of this assessment, a detailed verification

checklist was developed for use in performing

the Plant Physics Curve Book updates.B.The Reactor Engineering

Schedule of Periodic Tests and Reports, AP-0010127, was revised to require that a weekly review of the Plant Physics Curve Book be performed to verify that reactor physics data contained in the book are current.C.A meeting was held with the responsible

Reactor Engineering

personnel, the President of the Nuclear Division and the Vice President of Nuclear Engineering

to discuss this event and the expectations

of FPL management

with regard to personnel performance.

D.The personnel involved in the failure to properly update the reactivity

deviation information

received appropriate

disciplinary

action in accordance

with FPL policy.5.Full compliance

was achieved on November 5, 1996, with the completion

of Item 3B, above.