EA-97-501 - Saint Lucie 2 (Florida Power & Light Co.)

December 11, 1997

EA 97-501

Florida Power & Light Company
ATTN: Mr. T. F. Plunkett
President - Nuclear Division
P. O. Box 14000
Juno Beach, Florida 33408-0420

SUBJECT: NOTICE OF VIOLATION (NRC SPECIAL INSPECTION REPORT NOS. 50-335/97-15, 50-389/97-15)

Dear Mr. Plunkett:

This refers to the special inspection conducted on October 8 - October 30, 1997, at your St. Lucie facility. The purpose of the inspection was to review deficiencies identified in the surveillance and operation of the Unit 2 containment cooler fans. Specifically, Florida Power & Light Company (FP&L;) identified, on October 8, 1997, that in slow speed, i.e., the configuration during emergency operation, the 2-HVS-1D containment cooler fan would rotate in the reverse direction causing the fan to be unable to fulfill its safety function. FP&L; later concluded that monthly surveillance tests of the Unit 2 fans had not been conducted with the fan in slow speed. The results of the inspection were sent to you by letter dated November 6, 1997. An open, predecisional enforcement conference was conducted in the Region II office on December 3, 1997, with members of your staff, to discuss the violations, the root causes, and your corrective actions to preclude recurrence. A list of conference attendees and copies of the Nuclear Regulatory Commission's (NRC) and FP&L; 's presentation materials are enclosed.

Based on the information developed during the inspection and the information that was provided during the conference, the NRC has determined that violations of NRC requirements occurred. The violations are cited in the enclosed Notice of Violation (Notice), and the circumstances surrounding them are described in detail in the subject inspection report. The violations included: (1) the failure to maintain two trains of containment cooling operable as required by Technical Specification (TS) 3.6.2.1; (2) the failure to follow the procedure for a post maintenance test (PMT) of containment cooler fan 2-HVS-1D; and, (3) the failure to assure that appropriate testing was identified and performed to demonstrate that the Unit 2 containment cooler fans would perform satisfactorily while operating in the emergency configuration, i.e., the slow speed. The root causes of the violations were (1) poor communication while performing a PMT of the containment cooler fan resulting in operation of the fan twice in fast speed rather than once in both slow and fast speeds as required by the PMT procedure, and (2) a lack of oversight or attention to detail when the surveillance procedure was originally written.

The NRC commends the questioning attitude of the Assistant Nuclear Plant Supervisor (ANPS) who identified that the containment cooler fans were not being periodically tested in the configuration that they would operate in following a safety injection actuation signal. You should continue to encourage similar sensitivity to potential long-term testing deficiencies.

The NRC recognizes that the potential safety consequence of the fan inoperability was low due to the diversity of the containment cooling system. However, operation of the plant in a condition outside the design basis of the plant and in violation of the TSs for approximately five months is a significant regulatory concern. The NRC is particularly concerned that the monthly surveillance test designed to determine operability of the fans had failed, since plant licensing, to incorporate a critical test requirement. In addition, if not for the inquisitiveness of the ANPS, the equipment could have remained inoperable for a longer period of time. The normal methods of detecting and preventing errors from disabling safety-related equipment failed. Specifically, both PMT and surveillance testing, failed to identify that the fan was inoperable. Therefore, the violations have been categorized in the aggregate in accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, as a Severity Level III problem.

In accordance with the Enforcement Policy, a base civil penalty in the amount of $55,000 is considered for a Severity Level III problem. Because your facility has been the subject of escalated enforcement actions within the last two years,⁽¹⁾ the NRC considered whether credit was warranted for Identification and Corrective Action in accordance with the civil penalty assessment process described in Section VI.B.2 of the Enforcement Policy. NRC determined that credit was warranted for Identification because your staff identified the violations. With regard to the factor of Corrective Action, you formed a team to review the event, determine the root causes, and develop corrective actions. Your long term corrective actions included: (1) modifying the surveillance procedure to test the fans in slow speed; (2) reviewing other surveillance tests against Updated Final Safety Analysis Report (UFSAR) accident modes of operation; (3) reviewing the tracking of annunciators during safeguards testing; (4) training Maintenance and Operations personnel to reinforce three part communication; (5) adding clarification for testing motors with multiple windings to the PMT procedure; (6) adding guidance in the 50.59 screening procedure to ensure that the reviewer considers the intent of the TSs as well as UFSAR requirements when revising procedures; and, (7) conducting a vendor assessment of the significance of the inoperable fan cooler. Based on the above, the NRC determined that credit was warranted for the factor of Corrective Action.

Therefore, to encourage prompt identification and comprehensive correction of violations, I have been authorized, after consultation with the Director, Office of Enforcement, not to propose a civil penalty in this case. However, significant violations in the future could result in a civil penalty.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response will be placed in the NRC Public Document Room (PDR).

Sincerely, Original Signed by J. R. Johnson for Luis A. Reyes Regional Administrator

Docket Nos. 50-335, 50-389
License Nos. DPR-67, NPF-16

Enclosures:
1. Notice of Violation
2. NRC Presentation Materials
3. FP&L; Presentation Materials
4. List of Attendees

cc w/encls:
J. A. Stall
Site Vice President
St. Lucie Nuclear Plant
6351 South Ocean Drive
Jensen Beach, FL 34957

H. N. Paduano, Manager
Licensing and Special Programs
Florida Power and Light Company
P. O. Box 14000
Juno Beach, FL 33408-0420

J. Scarola
Plant General Manager
St. Lucie Nuclear Plant
6351 South Ocean Drive
Jensen Beach, FL 34957

E. J. Weinkam
Licensing Manager
St. Lucie Nuclear Plant
6351 South Ocean Drive
Jensen Beach, FL 34957

M. S. Ross, Attorney
Florida Power & Light
P. O. Box 14000
Juno Beach, FL 33408-0420

John T. Butler, Esq.
Steel, Hector and Davis
4000 Southeast Financial Center
Miami, FL 33131-2398

Director
Office of Radiation Control
Department of Health and
Rehabilitative Services
1317 Winewood Boulevard
Tallahassee, FL 32399-0700

Director
Division of Emergency Preparedness
Department of Community Affairs
2740 Centerview Drive
Tallahassee, FL 32399-2100

County Administrator
St. Lucie County
2300 Virginia Avenue
Ft. Pierce, FL 34982

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NOTICE OF VIOLATION

Florida Power and Light Company Docket Nos.50-389 St. Lucie Nuclear Plant License Nos.NPF-16 Unit 2 EA 97-501

During an NRC inspection conducted on October 8 - October 30, 1997, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

A. Technical Specification 3.6.2.1 states that two containment spray trains and two containment cooling trains shall be OPERABLE.

Contrary to the above, between May 16 and October 8, 1997, while operating in Modes 1, 2 and 3, one Unit 2 containment cooling train was inoperable. (01013)

B. 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 and shall be accomplished in accordance with those procedures.

Maintenance Procedure (MP) 2-0950173, Revision 9, "The Overhaul of Containment Fan Cooler Motors 2HVS-1A, 1B, 1C, 1D (EQ Motors)", Section 9.9, implements the post maintenance checks of the containment fan cooler motors after maintenance. MP 2-0950173 requires the fan to be started in slow and fast speed to verify proper blade rotation in each speed.

Contrary to the above, on May 16, 1997, the licensee failed to perform Section 9.9 of Maintenance Procedure 2-0950173 properly in that containment fan cooler 2-HVS-1D was not started in slow speed and proper blade rotation was not verified. (01023)

C. 10 CFR 50, Appendix B, Criterion XI, Test Control, requires, in part, that a test program shall be established to assure that all testing required to demonstrate that components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in the applicable design documents.

Final Safety Analysis Report Section 6.2.2.2.2 states that the fan coolers operate at a reduced flow of 39,600 cubic feet per minute each, with low speed motor operation during accident operation.

Normal Operating Procedure, NOP-2-2000020, Revision 2, "Containment Cooling System Operation", which implements monthly surveillance testing of the containment fan coolers, requires that each cooling train fan unit be started from the control room and verified that each unit operates for at least 15 minutes, at least once per 31 days.

Contrary to the above, as of October 6, 1997, the licensee failed to assure that all testing required to demonstrate that components will perform satisfactorily in service, in accordance with the requirements and acceptance limits contained in the applicable design documents, was identified and performed. Specifically, NOP-2-2000020, did not require the containment cooler fans to be tested in slow speed, which is the alignment required during emergency operation. This procedural inadequacy had existed since initial plant operation. (01033)

These violations represent a Severity Level III problem. (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Florida Power & Light Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector at the St. Lucie facility, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Atlanta, GA
this 11th day of December 1997

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^1. A Notice of Violation (NOV) and Proposed Imposition of Civil Penalty in the amount of $100,000 was issued on January 10, 1997 for violations of the plant security access control program, the emergency preparedness program, and requirements for nuclear instrumentation (EAs 96-458, -464, and -457). A Severity Level III violation was issued on September 19, 1996, associated with the failure to comply with 10 CFR 50.59 (EA 96-326). An NOV and Proposed Imposition of Civil Penalty in the amount of $50,000 was issued on March 28, 1996, for multiple violations associated with a dilution event (EA 96-040). An NOV and Proposed Imposition of Civil Penalty in the amount of $50,000 was issued on November 13, 1995, related to inoperable power operated relief valves (EA 95-180).