ML17229B004

Forwards Response to Violations Noted in Insp Rept 50-389/98-11.Corrective Actions:Addl Procedural Guidance Developed for ECCS Containment Sump Insps for Units 1 & 2. Mode 1 Walkdown of Unit 1 Also Performed

ML17229B004
Person / Time
Site:	Saint Lucie
Issue date:	02/04/1999
From:	PLUNKETT T F FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-389-98-11, L-99-028, L-99-28, NUDOCS 9902120166
Download: ML17229B004 (9)

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.

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CODE: IE01D COPIES RECEIVED:LTR

ENCL SIZE: TITLE: General (50 Dkt)-Insp 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

NUDOCS-ABSTRACT

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

DEDRO NRR/DRCH/HOHB

NRR/DRPM/PERB

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:

PLEASE HELP US TO REDUCE WASTETH TO HAVE YOUR NAME OR ORGANIZATION

REMOVED FROM DISTRIBUTION

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

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.