ML17228B327
ML17228B327 | |
Person / Time | |
---|---|
Site: | Saint Lucie ![]() |
Issue date: | 11/15/1995 |
From: | GOLDBERG J H FLORIDA POWER & LIGHT CO. |
To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
References | |
L-95-306, NUDOCS 9511210113 | |
Download: ML17228B327 (23) | |
See also: IR 05000335/1995015
Text
RIG RITY 1 ACCELERATED
RIDS PROCESSING), REGULATORY
INFORMATION
DISTRIBUTION
SYSTEM (RIDS)r'ESSION NBR 9511210113
DOC~DATE'5/11/15
NOTARIZED NO FACIL:50-335
St.Lucie Plant, Unit 1, Florida Power&Light Co.50-389 St.Lucie Plant, Unit 2, Florida Power&Light Co.AUTH.NAME AUTHOR AFFILIATION
GOLDBERG,J.H.
Florida Power&'ight Co.RECIP.NAME
RECIPIENT AFFILIATION
Document Control Branch (Document Control Desk)SUBJECT: Forwards response to NRC ltr re violations
noted in insp repts 50-335/95-15
&50-389/95-15.Corrective
actions:MSIS
was blocked&reset immediately
following event on 950802.I DISTRIBUTION
CODE: IE01D COPIES RECEIVED:LTR
ENCL SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice
of Violation Response NOTES DOCKET N 05000335 05000389 INTERNAL: RECIPIENT ID CODE/NAME PD2-1 PD ACRS AEOD/SPD/RAB
DEDRO NRR/DISP/PIPB
NRR/DRPM/PECB
OE DIR RGN2 FILE 01 COPIES RECIPIENT LTTR ENCL ID CODE/NAME 1 1 NORRIS,J 2 AEOD/DEIB 1 A'E.1 FILE CENTER 1/'DRC8/H FB 1 NUDOCS-ABSTRACT
1'GC/HDS3 1 COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 EXTERNAL: LITCO BRYCE,J H NRC PDR 1 1 1 1 NOAC 1 1 iNOTE TO ALL RIDS" RECIPIEYTS:
PLEASE HELP US TO REDUCE 4VASTE!CONTACT THE DOCL'!iIEYT
CO."iTROL DESK, ROOiiI Pl-37 (EXT.504-2083)TO ELI iIINATE YOUR NA!iIE FROiI DISTRIBUTIOY.
LISTS FOR DOCL'IiIEi'I'S
5'OU DOi"I'L'LD!TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 19
4 0'
0 Florida Power L Light Company, P.O.Box 14000, Juno Beach, FL 33408 0420 NOV 1 5$995 L-95-306 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 Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15Florida 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.Very truly yours, J.H.Goldberg President-Nuclear Division JHG/DAS/EJB
Attachment
cc: Stewart D.Ebneter, Regional Administrator, USNRC Region II Senior Resident Inspector, USNRC, St.Lucie Plant 95ii210i13
'it5iii5 PDR ADOCK 05000335 9 PDR an FPL Group company
FPL RESPONSE TO INSPECTION
REPORT 95-15 SUMMARY NRC Inspection
Report 50-335/389/95-15
considered
St.Lucie Plant performance
during the six (6)week period from July 30, 1995 through September 16, 1995.The violations
below occurred during a relatively
short period of time, as described in the inspection
report, and several of the corrective
actions were instituted
following an analysis of the events, collectively.
The corrective
steps to avoid further violations
were in some cases determined
to be generic following this analysis, and are therefore repeated in a number of the responses.
The Inspection
Report identified
seven (7)violations
which are listed below.Violation A: Failure to Follow Procedures
and Block MSIS Actuation Violation B: Failure to Follow Procedures
During RCP Seal Restaging Violation C: Failure to Follow Procedure and Document Abnormal Valve Position in the Valve, Switch Deviation log Violation D: Failure to Follow Procedures
during Alignment of Shutdown Cooling System Violation E: Failure to Follow Procedure and Document a Deficiency
on Containment
Spray Valve Surveillance
Test Procedure Violation F: Failure to Initial Maintenance
Procedure Steps as Work was Completed Violation G: Failure to Follow Procedures
During Venting of ECCS System Resulted in Containment
Spraydown Additionally, both Florida Power and Light (FPL)and the NRC evaluated plant events to identify common underlying
themes.FPL presented a summary of events to the NRC on August 29, 1995.Weaknesses
identified
in this summary included procedure content and use, as well as management
oversight of eguipment performance.
FPL's Plan to Improve the Operational
Performance
at St.Lucie was developed as a result of the August 29, 1995, meeting and submitted to the NRC on September 15, 1995.To date, FPL has completed the activities
according to the improvement
plan schedule.
S=.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 VIOLATION A: 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, Rev.2, February 1978.Appendix A, paragraph 1.d includes administrative
procedures
for procedural
adherence.
Procedure QI 5-PR/PSL-1, Rev.62,"Preparation, Revision, Review/Approval
of Procedures," Section 5.13.2, states that all procedures
shall be strictly adhered to.OP 1-0030127, Rev 68,"Reactor Plant Cooldown-Hot Standby to Cold Shutdown," required, in part, that operators block Main Steam Isolation System (MSIS)actuation when block permissive
annunciations
were received.ONOP 1-0030131, Rev 60,"Plant Annunciator
Summary," required that, upon valid receipt of annunciators
Q-18 and Q-20, operators immediately
block channels A and B, respectively.
Contrary to the above, on August 2, 1995, during a cooldown of St.Lucie Unit 1, valid block.permissive
were received, however, operators failed to establish the required MSIS blocks, resulting in A and B channel MSIS actuations.
RESPONSE A: REASON FOR VIOLATION The root cause of this violation was cognitive personnel error on the part of a utility licensed operator who failed to block the actuation of the main steam isolation signal (MSIS)in accordance
with the requirements
of the approved plant operating procedure.
2.CORRECTIVE
STEPS TAKEN AND THE RESULTS ACHIEVED A.The main steam isolation signal (MSIS)was blocked and reset immediately
following the event on August 2, 1995.
St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 3.CORRECTXVE
STEPS TO AVOXD FURTHER VXOLATXONS
A.The licensed operator who was involved in the event was counseled on the need to follow procedures
and received discipline
in accordance
with plant'policy.
B.All Operations
Nuclear Plant Supervisors (NPS)held meetings with their crews subsequent
to this event to reiterate FPL's goal for error free performance.
C.This event will be incorporated
into licensed operator requalification
training to emphasize procedural
compliance, proper communication
among the Control Room'team, and the importance
of supervision-in the control room maintaining
an overall awareness, of activities.
This action will be complete by January 1, 1996.D.St.Lucie Plant adopted verbatim compliance
as the only acceptable
means of procedure compliance.
This requirement
has been incorporated
into plant Quality Instruction
QI 5-PR/PSL-1,"Preparation, Revision, Review/Approval
of Procedures'~
" 4.Full compliance
was achieved on August 2, 1995 with the completion
of item 2 above.
St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 VIOLATION B: 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, Rev.2, February 1978.Appendix A, paragraph 1..d includes administrative
procedures
for procedural
adherence.
Procedure QI 5-PR/PSL-1, Rev.62,"Preparation, Revision, Review/Approval
of Procedures," Section 5.13.2, states that all procedures
shall be strictly adhered to.Contrary to the above, procedures
were not adhered to strictly in the following examples: OP 1-0120020, Rev.72,"Filling and Venting the RCS," precaution
4.2, required that Reactor Coolant System (RCS)venting, described in the procedure, not be attempted if RCS temperature
was above 200'F.On August 2, 1995, Reactor Coolant Pump (RCP)seal venting, performed in an attempt to correct seal package leakage in the 1A2 RCP in accordance
with Appendix E of the subject procedure, was performed while RCS temperature
was approximately
370'F.As a result, design temperatures
of RCP seal components
were approached
or exceeded.2.OP 1-0120020, Rev.72,"Filling and Venting the RCS," Appendix E,"Restaging
Reactor Coolant Pump Seals," required the use of RCP seal injection while restaging was attempted.
On August 2, 1995, restaging of the 1A2 RCP seal package was attempted without seal injection aligned to the seal package.As a result, design temperatures
of RCP seal components
were approached
or exceeded.RESPONSE B: REASON FOR VIOLATION The root cause of this violation was cognitive personnel error on the part of a utility licensed operator who failed to follow an approved plant procedure while performing
a restaging evolution on a Reactor Coolant'Pump (RCP)seal package.The operator did not strictly adhere to the conditions
contained in the procedure which required that RCS temperature
be no greater than 200'F, and that seal injection be in service.
0
St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply'o Notice of Violation Ins ection Re ort 95-15 2.CORRECTXVE
STEPS TAKEN AND THE RESULTS ACHIEVED A.The RCP'estaging evolution was discontinued, and Operations
cooled and depressurized
the Reactor Coolant System (RCS)in accordance
with approved plant procedure to lower RCP seal temperatures
to within the acceptable
range.The 1A2 RCP was secured.B.The damaged 1A2 RCP seal package was replaced prior to returning Unit 1 to operation.
3.CORRECTIVE
STEPS TO AVOID FURTHER VXOLATXONS
A.The licensed operator involved in this event was disciplined
in accordance
with plant policy.B.The procedure appendix which was used for performing
the restaging of the RCPs was deleted and is no longer available for use.C.Plant management
performed an assessment
of the decision making process that led to the restaging of the RCP seal under the existing plant conditions.
Based on this assessment, Plant policy 105,"Plant Operation Beyond the Envelope of Approved Plant Operating Procedures", was revised to require a technical review of procedures
which are being implemented
for the first time or for which plant conditions
are different from those described in the procedures
D.All Operations
Nuclear Plant Supervisors (NPS)held meetings with their crews subsequent
to this event to reiterate FPL's goal for error free performance.
E.St.Lucie Plant adopted verbatim compliance
as the only acceptable
means of procedure compliance.
This requirement
has been incorporated
into plant Quality Instruction
QI 5-PR/PSL-1,"Preparation, Revision, Review/Approval
of Procedures." 4.Full compliance
was achieved on August 2, 1995 with the completion
of item 2A, above.
St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 VIOLATION C: 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, Rev.2, February 1978.Appendix A, paragraph 1.d includes administrative
procedures
for procedural
adherence.
Procedure QI 5-PR/PSL-1, Rev.62,"Preparation, Revision, Review/Approval
of Procedures," Section 5.13', states that all procedures
shall be strictly adhered to.AP 1-0010123, Rev 99,"Administrative
Controls of Valves, Locks, and Switches," step 8.1.6, required, in part, that all valve position deviations
be documented
in the Valve Switch Deviation Log.Contrary to the above, on or about August 1, 1995, HCV-25-1 through 7 were repositioned
and left in the closed position without the required entries being made in the Valve Switch Deviation Log.The Valves'ositions
complicated
a loss of RCS inventory.
RESPONSE C: REASON FOR VIOLATION The root cause of this violation was cognitive personnel error on the part of utility licensed operators who did not properly document the closed status of the subject valves in the Valve Switch Deviation Log, as required by the approved plant procedure.
2.CORRECTIVE
STEPS TAKEN AND THE RESULTS ACHIEVED The Safeguards
Pump Room Sump Isolation valves, HCV 25-1 through HCV 25-7, were realigned to the open position immediately
following the loss of RCS inventory event on August 10, 1995, when Control Room operators discovered
the closed status of the valves.
St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 3.CORRECTXVE
STEPS TO AVOXD FURTHER VXOLATXONS
A.All Operations
Nuclear Plant Supervisors (NPS)held meetings with their crews subsequent
to this event to reiterate FPL's goal for error free performance.
B.C.D.The plant has adopted verbatim compliance
as the only acceptable
means of procedure compliance.
This requirement
has been incorporated
into plant Quality Instruction
QI 5-PR/PSL-1,"Preparation, Revision, Review/Approval
of Procedures." Management
is conducting
a daily review of Control Room chronological
logs to reinforce the expectation
for detail and completeness.
I Plant administrative
procedures
have been revised to provide for increased reviews by plant staff of the logs controlling
valve repositioning.
Full compliance
was achieved on August 10, 1995, with the completion
of item 2 above.
St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 VIOLATION D: 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, Rev.2, February 1978.Appendix A, paragraph 1.d includes administrative
procedures
for procedural
adherence.
Procedure QI 5-PR/PSL-1, Rev.62,"Preparation, Revision, Review/Approval
of Procedures," Section 5'3.2, states that all procedures
shall be strictly adhered to.OP 1-0410022, Rev 22,"Shutdown Cooling," step 8.3.7, required that V3652, the B Shutdown Cooling (SDC)hot leg suction isolation valve, be locked open while placing the B SDC loop in service.Contrary to the above, on August 29, a control room operator failed to place V3652 in a locked open condition while placing the B SDC loop in service.As a result, the 1B Low Pressure Safety Injection Pump was operated with its suction line isolated.RESPONSE D: REASON FOR VIOLATION The root cause of this violation was cognitive personnel error on the part of a utility licensed operator who failed to properly verify the alignment of the shutdown cooling (SDC)system flowpath in accordance
with the approved plant procedure, prior to starting the 1B Low Pressure Safety Injection (LPSI)Pump.This resulted in the failure to open the 1B LPSI Pump suction isolation valve.2.CORRECTIVE
STEPS TAKEN AND THE RESULTS ACHIEVED A.The Control Room operators noted the error in valve alignment and the LPSI pump was secured approximately
5 minutes after being started.A subsequent
inspection
determined
that no damage had occurred during the short period of pump operation.
B.The system was realigned in accordance
with the approved procedure and the LPSI pump was restarted.
Subsequent
operation of the LPSI pump was satisfactory.
C.An ASME Section XI code run was performed satisfactorily
on the 1B LPSI Pump and a subsequent
Engineering
assessment
concluded that pump operability
had not been adversely affected.
St.Lucie Units.1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 3.CORRECTIVE
STEPS TO AVOID FURTHER VIOLATIONS
A.The licensed operator involved in this event was disciplined
in accordance
with plant policy.B.Operations
implemented
procedure changes which require the use of a dedicated procedure reader to assist in the implementation
of SDC related evolutions.
C.All Operations
Nuclear Plant Supervisors (NPS)held meetings with their crews subsequent
to this event to reiterate FPL's goal for error free performance.
D.The plant has adopted verbatim compliance
as the only acceptable
means of procedure compliance.
This requirement
has been incorporated
into plant Quality Instruction
QI 5-PR/PSL-1,"Preparation, Revision, Review/Approval
of Procedures." E.This event will be included into licensed operator, requalification
training.This action will be completed by January 1, 1996.4.Full compliance
was achieved on August 29, 1995 with the completion
of item 2A and 2B above.
St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 VIOLATION E: 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, Rev.2, February 1978.Appendix A, paragraph 1.d includes administrative
procedures
for procedural
adherence.
Procedure QI 5-PR/PSL-1, Rev.62,"Preparation, Revision, Review/Approval
of Procedures," Section 5.13.2, states that all procedures
shall be strictly adhered to.QI 16-PR/PSL-2, Rev.1,"St.Lucie Action Report (STAR)Program," required that STARs be initiated for Quality Assurance audit findings and independent
technical review recommendations'ontrary
to the above, a STAR was not generated when a Quality Assurance review of an inadvertent
Unit 1 containment
spraydown, documented
in interoffice
correspondence
JQQ-95-143, identified
the practice of prelubricating
FCV-07-1A, Containment
Spray header A flow control valve, when performing
valve stroke time testing.RESPONSE E: 1.REASON FOR VIOLATION The root cause of this violation was cognitive personnel error on the part of utility Quality Assurance (QA)personnel.
QA personnel were in the process of conducting
an independent
review focusing on the contributing
factors associated
with a Unit 1 containment
spray down event.The practice of pre-lubricating
Containment
Spray header flow control valve FCV-07-lA prior to surveillance
testing was identified
during this.review, but was not determined
to be a contributing
factor to this event.Recommendations
to correct this deficiency
were therefore not contained in the resulting QA report, nor was a St.Lucie Action Request (STAR)generated in a timely manner.2.=CORRECTIVE
STEPS TAKEN AND THE RESULTS ACHIEVED A.A St.Lucie Action Request (STAR 951048)was generated on September 7, 1995 to document the deficient practice of pre-lubricating
Unit 1 and Unit 2 containment
spray flow control valves prior to surveillance
stroke time testing.B.Temporary changes were issued to plant surveillance
procedures
on September 2, 1995 to remove the practice of'pre-lubricating
valves prior to surveillance
testing.10
St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 3.CORRECTIVE
STEPS TO AVOID FURTHER VIOLATIONS
A.B.C.A meeting was held on September 13, 1995 between the Vice President of Nuclear Assurance and all St.Lucie Quality Assurance and Quality Control personnel.
During this meeting, clear expectations
were provided regarding the threshold for identification
and documentation
of deficiencies
by Quality personnel.
E On October 25, 1995, a second meeting was held between the site Quality Manager and St.Lucie QA personnel.
During this meeting, the requirements
of the Quality Instruction
QI 16-PR/PSL-2,"St.Lucie Action Report (STAR)Program" were reviewed.The responsibility
of QA personnel for timely identification
and documentation
of deficiencies
in accordance
with this procedure was reinforced.
Permanent changes will be made to plant surveillance
procedures
to discontinue
the practice of pre-test lubrication
of the valves prior to surveillance
testing.This action will be completed by December 1, 1995.4.Full compliance
was achieved on September 7, 1995 with the completion
of item 2A above.
St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 VIOLATION F: 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, Rev.2, February 1978.Appendix A, paragraph 1.d includes administrative
procedures
for procedural
adherence.
Procedure QI 5-PR/PSL-1, Rev.62,"Preparation, Revision, Review/Approval
of Procedures," Section 5.13.2, states that all procedures
shall be strictly adhered to.ADM-08.02, Rev 7,"Conduct of Maintenance," Appendix 5, step 5, required that procedures
be present during work and that individual
steps be initialed once performed.
Contrary to the above, inspection
of work in progress revealed that individual
steps were not initialed once performed upon completion
for work conducted in accordance
with Plant Change/Modification
11-195.RESPONSE F: 1.REASON FOR VIOLATION The root cause of this violation was cognitive personnel error on the part of an Electrical
Department
journeyman
who failed to properly document the completion
of steps while performing
work activities
associated
with the trip solenoids on the 1B Emergency Diesel Generator (EDG).The steps were not initialed as they were being performed, in accordance
with approved plant procedure.
2.CORRECTIVE
STEPS TAKEN AND THE RESULTS ACHIEVED A.The steps of the maintenance
procedure being worked were signed off by the journeyman
immediately
following the completion
of the work on August 31, 1995, and the completed procedure was reviewed by the chief electrician
and Electrical
supervisor.
B.The EDG circuitry was subsequently
tested following completion
of the work on August 31, 1995, and performed satisfactorily.
12
0
St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 3.CORRECTIVE
STEPS TO AVOID FURTHER VIOLATIONS
A.Meetings were held following this event with Electrical
Maintenance
employees to review this incident and emphasize management
expectations
regarding the documentation
of w'ork activities.
B.Supervisors
from each Maintenance
discipline
have conducted meetings with their employees to reinforce the need for strict adherence to the administrative
requirements
related to procedure use.C.The plant has adopted verbatim compliance
as the only acceptable
means of procedure compliance.
This requirement
has been incorporated
into plant Quality Instruction
QI 5-PR/PSL-1,"Preparation, Revision, Review/Approval
of Procedures." 4.Full compliance
was achieved on August 31, 1995 with the completion
of item 2A and 2B above.13
St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 VIOLATION G: 10 CFR 50 Appendix B, Criterion V,"Instructions, Procedures, and Drawings," requires, in part, that activities
affecting quality shall be prescribed
by documented
procedures
of a type appropriate
to the circumstances.
Contrary to the above, on August 18, 1995, venting of the Low Pressure Safety Injection (LPSI)System was conducted in accordance
with a procedure which was inappropriate
to the circumstances.
Specifically, OP 1-0420060, Rev.0,"Venting of the Emergency Core Cooling and Containment
Spray Systems," did not require a verification
that the portions of the system being vented were hydraulically
isolated from adjacent systems and flowpaths.
As a result of this failure to establish proper initial conditions, water driven by the 1A LPSI pump was inadvertently
directed to the A Train Containment
Spray header, resulting in a spraydown of the Unit 1 Reactor Containment
Building.RESPONSE G: REASON FOR VIOLATION The root cause of this violation was procedural
deficiency
in that the ECCS venting procedure, OP 1-0420060, did not state the plant conditions
required to successfully
vent the ECCS but relied upon the RCS heatup procedure to set plant conditions.
Specifically, the venting procedure did not require operators to verify that the proper containment
spray header isolation valves were closed prior to recirculating
the water in the SDC system.A contributing
factor to this event was that the operations
personnel performing
the ECCS venting procedure did not recognize that the existing plant conditions
would result in flow to the'A'ontainment
spray header when flow was aligned through the Shutdown Cooling Heat Exchanger.
A second contributing
factor of this event was that FCV-07-1A was placed in the open position because this valve had failed its ASME stroke time test.Plant management
made the decision to defer the valve repair and position this normally closed valve to its engineered
safeguards
open position in lieu of repairing the valve prior to startup.14
St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 2.CORRECTIVE
STEPS TAKEN AND THE RESULTS ACHIEVED A.Operators secured the 1A LPSI Pump and isolated, the flowpath to the containment
spray header from the LPSI Pump.The Reactor Cavity sump was drained to the Waste Management
System.B~Following the event, all nonessential
work at the site was placed on hold, and Unit 1 was maintained
stable in Mode 3 while senior plant management
conducted meetings with all available site personnel to stress the need for worker vigilance and attention to detail.The need to reduce equipment deficiencies
that impact operations
was also discussed.
C.Unit 1 was cooled down and depressurized
to Mode,5 and an inspection
and decontamination
of containment
was then conducted.
The event was evaluated under an Engineering
evaluation, which resulted in a comprehensive
inspection
of components
inside containment
to ensure future component reliability.
D.Operating procedure, OP 1-0420060,"Venting of the Emergency Core Cooling an'd Containment
Spray System", was revised September 1, 1995 to include the plant conditions
required to be present during venting.3.CORRECTIVE
STEPS TO AVOID FURTHER VIOLATIONS
A.Plant policy 105,"Plant Operation Beyond the Envelope of Approved Plant Operating Procedures", was revised to require a technical review of procedures
which are being implemented
for the first time or for which plant conditions
are different from those described in the procedure.
B.The Maintenance
Department
established
a team composed of plant staff and engineering
personnel, to determine the root cause for the Containment
Spray header isolation valve repeat failures and determine corrective
actions to eliminate this operator workaround.
FCV-07-1A was repaired prior to returning Unit 1 to service.15
St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to Notice of Violation Ins ection Re ort 95-15 C.Existing plant deficiencies
were reviewed by senior plant management.
Additional
deficiencies
which could impact operations
were added to the work scope of the Unit 1 shutdown.These deficiencies
were corrected prior to returning the unit to service.D.Administrative
procedure, AP-0010147,"Assessment
of Abnormal Plant Configurations
or Significant
Material Deficient'Conditions
on Plant Operation", was developed to enhance outage scope review and ensure that equipment deficiencies
are restored in a timely manner.E.St.Lucie management
instituted
a weekly review of appropriate
performance
indicators
and work backlog status, including the age of open items and operator workarounds.
F.All Operations
Nuclear Plant Supervisors (NPS)held meetings with their crews subsequent
to this event to reiterate FPL's goal for erro'r free performance.
G.This event will be incorporated
into licensed operator requalification
training.This action will be complete by January 1, 1996.4.Full compliance
was achieved on August 18, 1995 with the completion
of items 2A, 2C and 2D above.16