L-95-346, Responds to Violations Noted in Insp Rept 50-389/95-21. Corrective Actions:Clearance Order 2-95-11-128 Removed on 951204
| ML17228B372 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 01/04/1996 |
| From: | Goldberg J FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| L-95-346, NUDOCS 9601160011 | |
| Download: ML17228B372 (10) | |
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CA.TEGORY 1 y REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CCESSION NBR:9601160011 DOC.DATE: 96/01/04 NOTARIZED: NO FACIL:50-389 St. Lucie Plant, Unit 2, Florida Power
& Light Co.
AUTH.NAME AUTHOR AFFILIATION GOLDBERG,J.H.
Florida Power 6 Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to violations noted in insp rept 50-389/95-21.
Corrective actions:clearance order 2-95-11-128 removed on 951204.
DISTRIBUTION CODE: IE0lD COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response DOCKET 05000389 RECIPIENT ID CODE/NAME PD2-1 PD INTERNAL: ACRS AEOD/SPD/RAB DEDRO NRR/DISP/PIPB NRR/DRPM/PECB NUDOCS-ABSTRACT OGC/HDS3 XTERNAL LITCO BRYCE g J 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 NORRISiJ AEOD/DEIB AEOD C
~E CENTER NRR DRCH/HHFB NRR/DRPM/PERB OE DIR RGN2 FILE 01 NOAC COPIES LTTR ENCL 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE CONTACT THE DOCUMENT CONTROL DESKi ROOM OWFN SD-5(EXT. 41S-2083)
TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON' NEED!
TOTAL NUMBER OF COPIES REQUIRED: iLTTR 20 ENCL 20
Florida Power 5 Light Company, P.O. Box 14000, Juno Beach, FL 33400-0420 JAN 4
$996 L-95-346 10 CFR 2 '01 U.
S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D.
C.
20555 Re:
St. Lucie Unit 2 Docket No. 50-389 Reply to Notice of Violation Ins ection Re ort 95-21 Florida Power and Light Company (FPL) has reviewed the subject inspection report and pursuant to 10 CFR 2.201 the response to the notice of violation is attached.
In addition to the attached response to the specific violations, FPL is continuing to implement actions to drive cultural changes which will provide sustained performance improvements in the area of operations.
These changes have included additional management oversight designed to bring about a reduction in operator errors and ensure prompt corrective actions.
The self identification of problems by the operating staff is being encouraged by shift supervision and is tracked for analysis of generic problem areas.
This effort, combined with the use of Quality Assurance peer reviews is creating a self-critical culture that is resulting in continuous improvements.
Very truly
- ours, J.
H. Goldberg President Nuclear Division JHG/EJB Attachment cc: Stewart D. Ebneter, Regional Administrator, USNRC Region II Senior Resident Inspector, USNRC, St. Lucie Plant 960ii600ii 960104 PDR ADOCK 05000389 8
PDR IXOXOP an FPL Group company
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4
St. Lucie Unit 2 Docket No. 50-389 Reply to Notice of Violation Ins ection Re ort 95-21 VIOLATIONA:
Technical Specification 6.8 '.a required that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Rev 2, February 1978.
Appendix A, paragraph 1.d includes administrative procedures for procedural adherence.
, Procedure QI 5-PR/PSL-1, Rev 65, "Preparation,
- Revision, Review/Approval of Procedures,"
Section 5.13.2, stated that all procedures shall be strictly adhered to.
Operating Procedure No.
- 0010122, Rev 60, "In-Plant Equipment Clearance Orders", Section 4.16, requires "Assurance that Technical Specification equipment clearances are independently verified per Section 3.4.4".
Sections 5.6.4 and 5.6.5 state that the Reactor Control Operator (RCO):
4.
Is responsible to ensure the Equipment Clearance Order is:
A.
Filled out properly.
B.
Tag sign offs are signed.
C.
Safety related section properly completed.
D.
The independent verification section properly completed or a procedure specified that will provide for independent verification.
5.
Shall also enter Technical Specification and safety related equipment to be taken out of service in the Out-of-Service Log.
Instruction 8.3.7 SAFETY REVIEW requires that the NK.S/ANPS/NWE identify that an IV is required for Technical Specification/UFSAR/Safety Related component or system is affected.
Unit 2 Technical Specification 3.7.1.7 requires operability of the atmospheric dump and associated block valves in Mode 1.
Contrary to the above, on November 11,
- 1995, Equipment Clearance Order 2-95-11-128 was issued requiring no Independent Verification that the 125 VDC power supply breaker to block valve MOV-08-17 for Atmospheric Dump MV-08-19B was in the required position off.
An Out-of-Service Log entry on November 5, identified MV-08-17 as Tech.
Spec.
equipment required prior to Mode 1
as "out on clearance".
St. Lucie Unit 2 Docket No. 50-389 Reply to Notice of Violation Ins ection Re ozt 95-21 RESPONSE A:
1.
REASON FOR VIOLATION FPL concurs with the violation.
The root cause of this violation was cognitive personnel error on the part of a
utility licensed operator who failed to require that an Independent Verification (IV) be performed, in accordance with procedure, for the positioning of the power supply breaker to the Atmospheric Dump Isolation Valve.
2.
CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED A.
Clearance Order 2-95-11-128 was removed on December 4,
1995.
The power supply switch for MV-08-17, Breaker
- 60957, was subsequently restored to its normal position (On) under Equipment Clearance Order 2-95-09-261 on December 6,
1995.
An Independent Verification of the switch restoration was performed at that time.
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CORRECTIVE STEP TO AVOID FURTHER VIOLATIONS A.
Operations Department Senior Reactor Operators (SRO) were counseled in writing of the need for meticulous attention to detail when generating Equipment Clearance Orders.
B.
A cross functional team will be assembled to review the equipment clearance process and provide recommendations for improvement'.
This action will be complete by June 1, 1996.
C.
This event will be incorporated into licensed operator r~qualification training.
This action will be complete by June 30, 1996 Full compliance was achieved on December 6,
1995 with the completion of item 2A, above.
.0
St. Lucie Unit 2 Docket No. 50-389 Reply to Notice of Violation Ins ection Re ort 95-21 VIOLATIONB:
Technical Specification 6.8.1.a required that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Rev 2, February 1978.
Appendix A, paragraph 1.d includes administrative procedures for procedural adherence.
Procedure QI 5-PR/PSL-1, Rev 65, "Preparation,
- Revision, Review/Approval of Procedures,"
Section 5.13.2, stated that all procedures shall be strictly adhered to.
Operating Procedure No.
- 0010122, Rev.
60, "In-Plant Equipment Clearance Orders", defines "A clearance shall exist when:...C) The component used to isolate or disconnect has been tagged in its required position, D) Independent Verification has been completed on those clearances requiring an Independent Verification."
Instruction 8.6.5 states that "All required Independent Verifications shall be performed as per section 3.4.4".
Contrary to the above, on November 20, 1995, V09120 Isolation Valve for AFW Pump 2A to Steam Generator 2A Feedwater Inlet specified on Equipment Clearance Order 2-95-09-062 Tag 513 issued November 17 was found in the Closed instead of required Locked Closed position.
This valve also requires independent verification.
RESPONSE B:
REASON FOR VIOLATION FPL concurs with the violation.
The root cause of this violation was cognitive personnel error on the part of utility non-licensed operators who failed to properly implement the requirements of an Equipment Clearance Order.
2.
CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED A.
On November 20,
- 1995, the Senior Reactor Operator (SRO) on-shift was informed of the discrepancy regarding the locking of V09120.
An operator was dispatched to investigate, and the locking device was properly engaged on the Auxiliary Feedwater (AFW) isolation valve.
St. Lucie Unit 2 Docket No. 50-389 Reply to Notice of Violation Ins ection Re ort 95-21 3.
CORRECTIVE STEPS TO AVOID FURTHER VIOLATIONS A.
The utility non-licensed operator who performed the independent verification on valve V09120 was disciplined in accordance with plant policy.
B.
A Procedural change will be made to Administrative Procedure AP-0010123, "Administrative control of Valves, Locks and Switches",
to strengthen the guidance associated with verifying the locked position of valves.
This action will be complete by January 31, 1996.
C.
This event willbe included into operator requalification training.
This action will be complete by June 30, 1996 4.
Full compliance was achieved on December 11, 1995, with the completion of item 2A, above.
VIOLATION C:
Technical Specification 3.1.2.9 required that boron concentration be verified consistent with shutdown margin in Mode 5 with reactor coolant system level above the hot leg centerline by use of the boronometer or by sampling the reactor coolant system at a
frequency determined by the number of operable charging pumps as shown on Table 3.1-1.
Contrary to the above, Unit 2 entered Mode 5 at 3:10 am on November 27, 1995, which required that the sampling periodicity be increased to every eight hours.
Since the past previous sample was at 1:00 am on October 27, the next sample was due at 9:00 am and every eight hours thereafter.
At 11:45 pm, operators discovered that the sampling had not been accomplished at the required times on the day and peak shift.
Chemistry was notified and the sample was taken and analyzed at 12:00 pm on November 27.
St. Lucie Unit 2 Docket No. 50-389 Reply to Notice of Violation Ins ection Re ort 95-21
RESPONSE
C:
REASON FOR VIOLATION FPL concurs with the violation.
The root cause of this violation was cognitive personnel error by utility licensed operators who did not strictly adhere to the Administrative Procedure (AP 2-0010125) check sheets which delineate the boron sampling surveillance requirements to be performed 'each shift.
During the time that the boron sampling requirements were not met, no Charging Pumps were operable or available for dilution.
This led the operators to believe that sampling requirements had not changed when the Unit entered Mode 5.
2.
CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED A.
A Reactor Coolant System (RCS) sample was taken immediately upon discovery of this event on November 27, 1995.
Boron concentration was found to be consistent with shutdown margin requirements, and no RCS dilution had occurred.
B.
A Data Sheet 30, "Unscheduled Surveillance Tracking Sheet" was initiated to ensure that the correct sampling frequency was being followed.
3.
CORRECTIVE STEPS TO AVOXD FURTHER VIOLATIONS A.
The utility licensed operators involved with this event were disciplined in accordance with plant policy.
B.
St.
Lucie Action Report (STAR) 951546 was initiated to evaluate the current Technical Specification requirements for RCS boron sampling frequencies.
Changes will be submitted as appropriate based upon this evaluation.
This action will be completed by June 1,
1996.
C.
This event will be included into licensed operator requalification training.
This action will be complete by June 30, 1996.
4.
Full compliance was achieved on November 27, 1995 with the completion of item 2A, above.
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