ML17309A860
| ML17309A860 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 10/21/1996 |
| From: | Plunkett T FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| EA-96-236, EA-96-249, L-96-254, NUDOCS 9610300138 | |
| Download: ML17309A860 (15) | |
Text
CATEGORY 1 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9610300138 DOC.DATE: 96/10/21 NOTARIZED: YES DOCKET FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power 5 Light Co. 05000335 56-389 St. Lucie Plant, Unit 2, Florida Power 6 Light Co. 05000389 AUTH. NAME AUTHOR AFFILIATION PLUNKETT,T.F. Florida Power 6 Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Forwards responds to NRC 961021 ltr re violations noted in 50-389/96-12.Complete review of insp rept 50-335/96-12 a plant change/Mod (PC/M) 341-192 was conducted.
DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt}-Insp Rept/Notice of Violation Response NOTES:
RECIPIENT COPIES RECIPIENT COPIES
-ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-3 PD 1 1 NIENS, L. 1 1 INTERNAL:'CRS R 2 2 AEOD/SPD/RAB 1 1 AEO 1 1 DEDRO 1 1 E CENTER 1 1 NRR/DISP/PIPB 1 1 B 1 1 NRR/DRPM/PECB 1 1 NRR/DRPM/PERB 1 1 NUDOCS-ABSTRACT 1 1 OE DIR 1 1 OGC/HDS3 1 1 RGN2 FILE 01 1 1 EXTERNAL'ITCO BRYCEtJ H 1 1 NOAC 1 1 D
NRC PDR 1 1 NOTE TO ALL <<RIDS" RECIPIENTS PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUK'NT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 19
Florida Power 5 light Company, P.O. Box 14MO, Juno 6each, FL 33408-0420 OCT 2 3 $ 996 L-96-254 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 No. 50-335 and 50-389 Reply to a Notice of Violation NRC S ecial Ins ection Re ort 96-12 EA 96-236 and 96-249 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.
Very truly yours, T. F. Plunkett President Nuclear Division TFP/J AS/EJW Attachment cc: Stewart D. Ebneter, Regional Administrator, USNRC Region II Senior Resident Inspector, USNRC, St. Lucie Plant t-Co{
9hi0300i38 qhi02i 05000335 PDR ADQCK 8 PDR an FPL Group company
STATE OF FLORIDA )
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COUNTY OF PALM BEACH )
J. A. Stall being first duly sworn, deposes and says:
That he is Vice President, St. Lucie Plant, of Florida Power & Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information and belief, and that he is authorized to execute the document on behalf of said Licensee.
J. A. Stall STATE OF FLORIDA COUNTY OF this by
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Sworn to and subscribed before me J. A.
day of Stall, who is personally known
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Name of Not Public - State of Fl
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(Print, type or stamp Commisioned Name of Notary Public)
l L-96-254 .
Attachment Re 1 to a Notice of Violation VIOLATIONI:
10 CFR 50.59, "Changes, Tests and Experiments," provides, in part, that the licensee may make changes in the facility as described in the Safety Analysis Report (SAR) without prior Commission approval, unless the proposed change involves an unreviewed safety question. A proposed change shall be deemed to involve an unreviewed safety question if the probability of occurrence of a malfunction of equipment important to safety previously evaluated in the SAR may be increased, if a possibility for an accident or malfunction of a different type than any evaluated previously in the SAR may be created, or if the margin of safety as defined in the basis for any technical specification is reduced.
Contrary to the above, in July 1995, the licensee made a change to the facility which involved an unreviewed safety question without prior Commission approval.
Specifically, the 2B Emergency Diesel Generator (EDG) fuel oil line was manually isolated to secure a through-wall fuel oil leak. In taking this action, the licensee introduced two new failure modes for the 2B EDG, which both increased the probability of occurrence of a malfunction of the EDG above that previously evaluated in the SAR and the possibility for malfunction of a different type than any evaluated previously in the SAR, resulting in an unreviewed safety question. (01013)
This is a Severity Level III violation (Supplement I)
RESPONSE I:
FPL concurs with the violation.
- 2. REASON FOR THE VIOLATION The cause of the violation was that FPL procedural guidance for performing 10 CFR
$ 50;59 evaluations in place at the time of the violation was not consistent with the NRC's interpretation of the regulation.
The subject evaluation was prepared in accordance with the "Nuclear Engineering Department Guidance for Performing 10 CFR 50.59 Safety Evaluations." The primary basis for this engineering procedure was NSAC-125, "Guidelines for 10 CFR 50.59 Safety Evaluations," which is the generally accepted industry standard on the subject.
In July 1995, both the FPL procedure and NSAC-125 allowed a conclusion of no
L-96-254 .
Attachment Re 1 to a Notice of Violation increase in probability if the increase was determined to be insignificant.
The subject 10 CFR $ 50.59 safety evaluation allowed plant operation with the 2B diesel fuel oil transfer pump discharge isolation valve (normally locked open) in the closed position in order to isolate a leak in the underground portion of the piping.
Compensatory actions were required by the evaluation to ensure the valve would be opened in the event of an EDG start. These compensatory actions were consistent with the guidelines of NRC Generic Letter 91-18, "Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability" for the use of manual action in place of automatic action. As noted in the FPL evaluation, two new failure modes and a slight increase in the probability of a component failure were created. Pursuant to the FPL procedure, the evaluation concluded that this slight increase in probability was insignificant and that no unreviewed safety question existed as a result of the proposed plant configuration.
- 3. CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED The unreviewed safety question identified in NRC Inspection Report 96-12 was associated with the closing of the diesel fuel oil transfer pump discharge isolation valve. Compliance was re-established upon restoring the valve to its normally open position following replacement of the leaking underground piping downstream of the valve. The replacement of the leaking piping, restoration of the valve to the open position, and return of the'2B EDG to OPERABLE status were completed by November 25, 1995.
CORRECTIVE STEPS TO AVOID FURTHER VIOLATIONS FPL Engineering issued a Technical Alert to engineering personnel on March 6, 1996, informing them that when performing 10 CFR $ 50.59 evaluations, any quantified increase in the probability of occurrence of accidents or any quantified increase in the probability of occurrence of a malfunction of equipment important to safety must be considered an unreviewed safety question.
B. Revision 1 to the "Nuclear Engineering Guidance for Performing 10 CFR 50.59 Safety Evaluations" was issued on May 17, 1996. This revision proceduralized the requirement stated in the Technical Alert discussed in 4.A. above.
Attachment Re 1 to a Notice of Violation FPL will evaluate the need for further procedural revisions taking into account the NRC's position documented in TIA 95-013 and the latest industry guidance on performing 10 CFR $ 50.59 evaluations. This action will be completed within three months following the issuance of NRC and industry guidance on performing 10 CFR $ 50.59 evaluations.
Full compliance was achieved by November 25, 1995, with the completion of Item 3 above.
- 6. ~
ADDITIONALINFORMATION While FPL concurs with the violation as cited, it was not until August 19, 1996, that FPL had the benefit of reviewing the NRC memorandum dated July 30, 1996, which responded to a Technical Assistance Request (TIA 95-013). The response to TIA 95-013 illustrates the existing confusion surrounding interpretation of 10 CFR $ 50.59.
The issue of concern deals with the Staff's position on the introduction of new failure modes as they relate to permitted compensatory actions. The NRR response to TIA 95-013 contains a narrower interpretation of the permissible use of administrative controls, specifically compensatory actions, when compared to a previous NRC position. Specifically, NRC Inspection Manual, Part 9900 interim guidance on 10 CFR
$ 50.59, issued in April 1996. Part 9900 (pg. 3, paragraph 4) states that "...the staff has found compensating effects such as changes in administrative controls acceptable in offsetting uncertainties and increases in the probability of occurrence or consequences of an accident previously evaluated in the SAR or reductions in margin of safety, provided the potential increase or reductions in margin are negligible."
On the other hand, the response to TIA 95-013 suggests that compensatory measures can no longer be credited to offset small potential increases in probability. In the case of the FPL 10 CFR $ 50.59 evaluation, a compensatory operator action was used in place of an automatic function. Specifically, the response to the TIA asserts that "an unreviewed safety question exists because the proposed change introduces a new procedure and associated malfunction of a different type (operator error)..." The response to the TIA further asserts that "[I]n general, the introduction of compensatory measures suggests that there is an unreviewed safety question for which compensation is needed, hence, a 50.90 submittal should be prepared by the licensee and evaluated by the staff to determine whether the compensation is adequate." This position conflicts with the position set forth in the April 1996 Part 9900 guidance.
Attachment Re 1 to a Notice of Violation The new position also has implications for the NRC's operability guidance in Generic Letter 91-18, "Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability." Under this guidance, NRC recognizes that substitution of manual action for automatic action may be acceptable under certain circumstances. Additionally, in an NRC letter to Northeast Nuclear Energy Company dated October 21, 1994 (John F.
Stolz to Richard M. Kacich), it is stated that, "[I]fan operability conclusion is made based upon implementing compensatory actions resulting in a change to the facility or procedures as described in the FSAR, an evaluation pursuant to $ 50.59 must be performed..." However, as stated above, the new position taken in the response to the TIA, with regard to compensatory measures, would appear to foreclose the possibility that such a change could be made pursuant to 10 CFR $ 50.59.
The inconsistencies between the positions set forth in the TIA response, NRC Inspection Manual Part 9900 guidance, and docketed correspondence illustrate the current state of confusion regarding the interpretation of 10 CFR $ 50.59. In the response to the TIA, the Staff states that it "...is in the process of better defining what constitutes appropriate use of compensatory measures in 10 CFR 50.59 safety evaluations." Further attesting to the currently evolving state of 10 CFR $ 50.59 interpretation is NRC's "Action Plan for Improvements to 10 CFR $ 50.59 Implementation and Oversight," from James M. Taylor to Chairman Jackson, dated April 15, 1996. The action plan recognizes several issues in need of clarification and that a final paper to the Commission on the action plan is not scheduled for issuance until February 1997.
FPL respectfully requests that, in light of the position on the introduction of new failure modes through manual operator action expressed in the response to the TIA, the Staff resolve, in a timely manner, the differences in interpretation and apparent inconsistencies that exist. The Staffs resolution of these differences will permit FPL and other licensees to properly implement the requirements of 10 CFR $ 50.59 and 10 CFR $ 50.90 in day-to-day plant operations.
Attachment Re I to a Notice of Violation VIOLATIONII A:
10 CFR 50, Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," Criterion IH requires, in part, that measures be established to assure that applicable regulatory requirements and the design basis for safety-related structures, systems, and components are correctly translated into specifications, drawings, procedures, and instructions.
Florida Power and Light Company Topical Quality Assurance Report, TQR 3.0, Revision 11 implements these requirements. Section 3.2, "Design Change Control,"
provides, in part, that design changes shall be reviewed to ensure their implementation is in each case, coordinated with any necessary changes to operating'procedures. In addition, Section 3.2.4, "Design Verification," provides, in part, that design control measures shall be established to verify the design inputs, design process, and that the design inputs are correctly incorporated into the design output.
Contrary to the above, the licensee failed to coordinate design changes with the necessary changes to operating procedures as evidenced by the following examples:
Plant Change/Modification (PC/M) 109-294, "Setpoint Change to the Hydrazine Low Level Alarm (LIS-07-9)," was completed on January 6, 1995, without ensuring that affected Procedure ONOP 2-0030121, "Plant Annunciator Summary," was revised. This resulted in Annunciator S-10, "HYDRAZINETK LEVEL LO," showing an incorrect setpoint of 35.5 inches in the procedure.
PC/M 268-292, "Intake Cooling Water Lube Water Piping Removal and Circulatory Water Lube Water Piping Renovation," was completed on February 14, 1994, without ensuring that affected Procedure ONOP 2-0020131, "Plant Annunciator Summary," was revised. This resulted in the instructions for Annunciator E-16, "CIRC WTR PP LUBE SPLY BACKUP IN SERVICE," incorrectly requiring operators to verify the position of valves MV 21-4A and 4B following a safety injection actuation system signal to ensure they were de-energized and had no control room position indication.
- 3. PC/M 275-290, "Flow Indicator/Switch Low Flow Alarm and Manual Annunciator Deletions," was completed on October 28, 1992, without ensuring that affected Procedure ONOP 2-0030131, "Plant Annunciator
L-96-254-Attachment Re 1 to a Notice of Violation Summary," was revised. This resulted in the instructions for safety-related Annunciators LA-12, "ATM STM DUMP MV-08-18A/18B OVERLOAD/SS ISOL," and LB-12, "ATMSTM DMP MV 19A/19B OVERLOAD/SS ISOL," incorrectly requiring operators to check Auto/Manual switch or switches for the manual position. (02014)
This is a Severity Level IV violation (Supplement I).
RESPONSE II A:
- 1. FPL concurs with the violation.
REASON FOR THE VIOLATION The cause of the violation was an inadequate configuration control process which failed to ensure that procedures and processes affected by plant modifications were identified and updated in a timely manner as required to accurately reflect the modifications made in the plant.
A contributing factor to this violation was that, at the time of implementation of the plant modifications in the examples to the violation, there was a general acceptance by plant management of routine backlogs for open items related to plant modifications.
- 3. CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED The St. Lucie Plant Annunciator Summary Procedure, ONOP 2-0030131, was revised to correct the three discrepancies identified in this violation. This action was completed on July 5, 1996.
CORRECTIVE STEPS TO AVOID FURTHER VIOLATIONS A. A self-assessment of the plant modification front-end review process was conducted, which included benchmarking with FPL's Turkey Point Plant. In addition, a Quality Assurance audit of the design control process was conducted, which supported the results of the self-assessment.
B. St. Lucie Design Control Procedure QI 3-PR/PSL-1 was revised to incorporate a positive check for completion of procedure updates prior to system turnover
L-96-254 Attachment Re I to a Notice of Violation and to ensure updating and tracking of affected procedures prior to restoring a modified system to service. The revised QI 3-PR/PSL-1 process was first implemented at St. Lucie Plant during the Summer 1996 St. Lucie Unit 1 refueling outage. Procedure QI 3-PR/PSL-1 was further revised, post-Unit 1-refueling outage, to incorporate the results of the self-assessment discussed in 4.A, above.
C. The Configuration Management Group at St. Lucie Plant was reorganized and restructured, with the addition of staffing and supervision to support the new plant modification review process and to continue to optimize process control and design/procedure integration.
D. Plant management expectations and requirements for thorough review, processing, and closeout of modification-related action items, and the documentation of these actions prior to restoring a modified system to service, were communicated to plant personnel via Items 4.B. and 4.C., above. The plant's acceptance of backlogged modification-related action items was replaced with an unambiguous requirement to fully process modification documentation to closure prior to declaring restoration of operability.
Full compliance was achieved on July 5, 1996, with the completion of Item 3 above.
VIOLATIONII B:
10 CFR 50, Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," Criterion III requires, in part, that measures be established to assure that applicable regulatory requirements and the design basis for safety-related structures, systems, and components are correctly translated into specifications, drawings, procedures, and instructions.
Florida Power and Light Company Topical Quality Assurance Report, TQR 3.0, Revision 11 implements these requirements. Section 3.2, "Design Change Control,"
provides, in part, that design changes shall be reviewed to ensure their implementation is in each case, coordinated with any necessary changes to operating procedures. In addition, Section 3.2.4, "Design Verification," provides, in part, that design control measures shall be established to verify the design inputs, design process, and that the design inputs are correctly incorporated into the design output.
L-96-254 Attachment Re I to a Notice of Violation Contrary to the above, the licensee failed to assure that the design of the Circulating and Intake Cooling Water System was correctly translated into plant drawings.
Specifically, during implementation of PC/M 341-192, "Intake Cooling Water Lube Water Piping Removal and Circulatory Water Lube Water Piping Renovation," the as-built Drawing No. JPN-341-192-008 was not incorporated into Drawing No. 8770-G-082, "Flow Diagram Circulating and Intake Cooling Water System," Revision 11, Sheet 2, issued May 9, 1995, for PC/M 341-192. This resulted in Drawing No. 8770-G-082 erroneously showing valves 1-FCV-21-3A and 3B and associated piping as still installed. (03014)
This is a Severity Level IV violation (Supplement I).
RESPONSE II B:
- 1. FPL concurs with the violation.
- 2. REASON FOR THE VIOLATION The cause of the violation was cognitive personnel error by utility drawing update personnel who failed to incorporate as-built drawing number JPN-341-192-008 into drawing number 8770-G-082, Revision 11, Sheet 2, which resulted in an inaccurate documentation of design changes made to the plant.
Several additional factors contributed to the event:
A. The drawing update discrepancy noted above was not identified during subsequent independent review by utility personnel'rior to release.
B. For the drawing that was not updated, a discrepancy was observed in the computer based drawing update tracking program in place at the time, regarding the date of transmittal of the subject drawing to document control.
This discrepancy in transmittal date provided a source of confusion regarding actual drawing status at the time of transmittal, and contributed'as a causal factor to the violation.
C. The missed drawing update in this event was associated with a plant modification which was implemented over a long period of time, which also contributed to the event.
Attachment Re 1 to a Notice of Violation D. Accountabilities and responsibilities associated with the Drawing Update checker and verifier roles were informally communicated at the time drawing verification was initially performed.
- 3. CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED Drawing number 8770-G-082, Sheet 2, was revised to incorporate as-built drawing number JPN-341-192-008, which deleted valves 1-FCV-21-3A and 3B. This revision was issued on April 24, 1996.
CORRECTIVE STEPS TO AVOID FURTHER VIOLATIONS A. A complete review of plant change/modification (PC/M) 341-192 was conducted. Three additional drawing errors were discovered and all drawings have been corrected and reissued.
B. This event was reviewed with drawing update personnel to provide training and ensure understanding of the responsibilities, accountabilities, and expectations of personnel involved in the process of drawing update.
To ensure proper updating, and to generically assess the potential for other errors resulting from other causes, a sample of updated drawings from previously implemented PC/Ms is being reviewed. This sample includes drawings exhibiting a potential discrepancy between status transmittal date, as described above, and also drawings associated with PC/Ms which were implemented over an extended period of time. This action will be complete by December 30, 1996.
D. The computer based system used to track drawing updates was converted to a new system in 1996. The new system allows personnel checking drawing updates to print a complete list of all drawing updates required for a given modification. The accountabilities and responsibilities associated with the Drawing Update checker and verifier are better defined in that drawing update personnel are required to use this list when verifying the drawing updates performed by the drafter for a given modification package. The use of this list aids personnel in verifying that all applicable revision requirements for a given drawing have been incorporated.
Full compliance was achieved on April 24, 1996, with the completion of Item 3 above.