CATEGORY 1REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9711100088 DOC.DATE: 97/11/03 NOTARIZED: NOFACIL:50-335 St. Lucie Plant, Unit 1, Florida Power & Light Co.

,.5g-.'589 St. Lucie Plant, Unit 2, Florida Power & Light Co.UTH.NAME AUTHOR AFFILIATION

PLUNKETT,T.F. Florida Power & Light Co.RECIP.NAME RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)

SUBJECT: Forwards response to violations noted in insp repts50-335/97-10 & 50-389/97-10.Corrective actions:all sixteenidentified errors reviewed & determined not to representoperability concerns.

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APL

Florida Power 8c Light Company,6351 S. Ocean Orive. Jensen Beach, FL34957

L-97-274November 3, 1997 10 CFR $2.201

U. S. Nuclear Regulatory CommissionAttn: Document Control DeskWashington, D. C. 20555

Re: St. Lucie Units 1 and 2Docket Nos. 50-335 and 50-389

Reply to a Notice ofViolationNR In e ratedIns ecti nRe ort97-10

Florida Power and Light Company (FPL) has reviewed the subject Notice ofViolation and,

pursuant to 10 CFR $2.201, the response to the violation is attached.

'y FPL letter L-97-180, subject, "Voluntary Initiative to Review Final Safety Analysis Reports,"dated July 11, 1997, FPL committed to conduct a graded review of the St. Lucie Updated Final

Safety Analysis Reports (UFSARs). As stated in the letter, the UFSAR review effort and

resources are being expended in those areas ofgreatest safety'significance. The review scopeincludes examination ofrelevant system documentation and walkdowns ofsystem criticalcharacteristics. FPL also committed to evaluate the outcome of the UFSAR review and, as

necessary, expand the scope of the UFSAR review.

As for the UFSAR discrepancies cited in this Inspection Report, FPL reviewed all identified errorsand determined the issues did not represent operability concerns. FPL implementedimprovements in the UFSAR update process that willminimize the potential for future UFSARdiscrepancies of the type cited in this violation. A UFSAR style guide has been developed to

'tandardizeUFSAR change packages. Personnel developing facility changes (e.g., plantmodifications or procedure changes) have access to search tools that were developed to facilitatelocating relevant UFSAR information. These search tools ensure that accurate 10 CFR 50.59screenings are performed, and that required UFSAR change packages are developed.

Please contact us with questions on the enclosed violation response.

Very truly yours,

Thomas F. PlunkettPresidentNuclear Division'lr~L I

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TFP/JAS/EJW

Attachmentcir711100088 971103PDR ADOCK 050003356 PDR

cc: Regional Administrator, USNRC, Region IISenior Resident Inspector, USNRC, St. Lucie Plant

an FPL Group company

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10 CFR 50.71(e) requires that each person licensed to operate a nuclear power plant, update,periodically, the final safety analysis report to assure that the information included in the

document contains the latest material developed.

Contrary to the above, as ofSeptember 6, 1997, the licensee failed to update the Updated Final

Safety Analysis Reports (UFSAR) for St. Lucie Units 1 and 2 such that the information includedin the documents did not contain the latest material developed as evidenced by the followingexamples ofUFSAR discrepancies:

1. Unit 1 NaOH concentration listed in Unit 1 UFSAR Table 6.2-22 was incorrect.

2. Unit 1 UFSAR Table 7.3-2 incorrectly designated MV-21-2 in the A ICW train ratherthan the B ICW train.

3.. Unit 1 UFSAR Figure 9.2-1a was not revised following modifications to the intakecooling water lube oil coolers performed under PC/M 341-192.

4. Unit 1 UFSAR Table 7.4-1 was not revised to delete lubricating water pressure switchesremoved by modification.

5. Unit 1 UFSAR figures 7.4-9, 10, and 11 were not revised to remove annunciator E-15

logic which was spared out.

6. Unit 2 UFSAR Table 7.3-2 incorrectly designated MV-21-2 in the A ICW train ratherthan the B ICW train.

8.

UFSAR Table 4.2-1 and UFSAR Section 4.2.3.2.3(b)(1) contained inconsistentinformation on control element assembly (CEA) speed and drop times.

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Installed Unit 2 fire extinguishers were not of the type specified by Unit 2 UFSAR Table9.5A-8D..

9. Unit 2 UFSAR Table 7.5-3 for windows LA-9 and LB-9 showed incorrect actuationdevices.

10. Unit 2 UFSAR Table 7.5-3 incorrectly indicated that windows LA-4 and LB-4, "Lube

Water Supply Strainers High Differential Pressure", were safety related.

11. Unit 1 UFSAR Section 5.2.4.5.b.1 incorrectly stated that the level detector whichmeasured leakage flow through the containment sump weir was non-seismic.

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12. Unit 1 UFSAR Section 5.2.4.5.b.2 incorrectly stated that the Containment AtmosphereRadiation Monitoring System took isokinetic samples ofair from the containment coolingsystem.

13. Unit 1 UFSAR Table 5.2-11, Reactor Coolant Leak Detection Sensitivity, containedinconsistent information on "Average Rate ofChange" and the "Time for Scale to Move"and instrument ranges.

14. Unit 1 UFSAR Section 12.2.4.1 incorrectly stated that containment atmosphere sampleflowwas regulated and indicated by independent mass flow meters.

15. The battery load profile shown in Unit 1 UFSAR Table 8.3-5 was incorrect.

16. UFSAR Table 9.2-5, Operating Flow Rates and Calculated Heat Loads for AuxiliaryEquipment Cooled by Component Cooling Water, was not changed to reflect a 1993

accident reanalysis affecting these parameters.

This is a Severity Level IVviolation (Supplement I).

R~g~ng

FPL concurs with the violation. However, as explained below, FPL determined thatexamples 3, 8, and 16 cited in this violation do not constitute UFSAR errors.

REASON FOR VIOLATION

The cited UFSAR update deficiencies represent a diverse group ofdiscrepancies identifiedfrom the UFSARs for both units. The sixteen identified errors stem from a variety ofindividual causes. Based on our review of the specific examples, the errors were groupedinto the following categories: (i) editoriaVtypographical corrections (examples 2, 6, 9, 15);(ii) errors present in the original UFSAR (examples 11, 14); (iii) instances where plantoperations have evolved away from that anticipated in the original design and described inthe FSAR (example 12, 13); (iv) changes made under 10CFR50.59 and 10CFR50.92which were not incorporated into the UFSAR (examples 1, 4, 5, 7, 10).

Examples 3, 8 and 16 are not UFSAR errors and consequently do not fall into any of theabove categories. Example 3 states that Figure 9.2-1a in the Unit 1 UFSAR was notupdated to reflect Plant Change/Modification (PC/M) 341-192. This figure is a

duplication ofcontrolled drawing 8770-G-082 Sheet 2 and the UFSAR amendment usedthe most recent revision. At the time of the UFSAR figure update, the controlled drawinghad not been as-built to reflect (PC/M) 341-192. Note that the timing ofcontrolled

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drawing revisions is no longer a concern since UFSAR Amendment 15 (1/97) removed allfigures based on controlled drawings. The figures have been replaced by a reference tothe controlled plant drawing.

Example 8 is a discrepancy between the physical plant and the UFSAR description in'hichthe UFSAR was correct. The discrepancy was resolved by restoring the plant to

the UFSAR described condition.

Example 16 states that the values in Table 9.2-5 were not updated to reflect the 1993

reanalysis of the post accident containment conditions. In fact, this table was updated inAmendment 9 (10/94) to contain the following note: "These values reflect originalprocurement values. Refer to Ref. 27 in Section 6.2." Reference 27 in Section 6.2 is the1993 containment reanalysis.

The principal causes for each of the four error categories are identified below:

i T o ra hical/E it rialErr r xam les2 6 9 15

The editoriaVtypographical changes are primarily the result ofhuman error and a lack of'attention to detail. The cited examples have no impact on nuclear safety or plantoperation.

ii ErrorsinOri inalFSAR xam les 11 14

These errors were made as a result oforiginal preparation of the UFSAR and were notidentified in subsequent updates of the UFSAR. The historical cause of the original errorsin the UFSAR cannot be definitively determined and is not relevant to current processes.The update process does not [nor is it required to by 10CFR50.71(e)] include a validationofunmodified'sections of the UFSAR. Additionally, because of the relatively low safetysignificance of the examples, they have not undergon'e scrutiny by other processes.

iii Chan es in erational Practices xam les 12 13

Examples 12 and 13 are the result ofchanges over time in the operation ofplantequipment that were not recognized as impacting the UFSAR. Both of the cited examplesare associated with operation of the containment Particulate, Iodine, and Gas (PIG)monitors which are used for identification ofReactor Coolant System (RCS) leakage. Theoriginal UFSAR descriptions assumed operation with a relatively high RCS activity. Overtime the use ofdebris resistant fuel and other improvements (e.g., foreign materialexclusion programs) have significantly reduced the actual RCS activity levels. Changes tothe operation for the PIG monitors was a consequence of these improvements, however,because ofa lack ofawareness and sensitivity to the UFSAR descriptions these differences

L-97-274AttachmentP~ae 4

failed to be identified as UFSAR changes.

50 59 457 0

Examples 1 and 7 are the result ofa failure to update the UFSAR to reflect changes made

to the Technical Specifications pursuant to 10CFR50.92. Examples 4, 5, and 10 are the

result ofa failure to update the UFSAR to reflect changes made via PC/M packages forthe installation ofcooling lines on the intake cooling water pumps for both units.

3. CORRECTIVE STEPS TAKENAND THE RESULTS ACHIEVED

Allsixteen identified errors were reviewed and determined not to represent operabilityconcerns. Examples 3, 8 and 16 are not update errors and do not require a change to the

UFSAR. However, to address example 8, fire extinguishers were added to bring the plantinto conformance with the UFSAR descriptions. a

A. UFSAR changes were implemented during the last Unit 1 amendment

(Amendment 15) to correct examples 2, 4, and 5.

B.. Examples 1, 7, 11, 12, 13, 14, and 15 willbe corrected in Amendment 16 to the

Unit 1 UFSAR. Amendment 16 to the Unit 1 UFSAR is currently scheduled forJuly 1998.

C. Examples 6, 9, and 10 willbe corrected in the next Unit 2 UFSAR amendment

(Amendment 11). Amendment 11 to the Unit 2 UFSAR willbe submitted inDecember 1997.

ORRECTIVE STEPS TO AVOIDFURTHER VIOLATIONS

By FPL letter L-97-180, subject, "Voluntar'y Initiative to Review Final Safety AnalysisReports," dated July 11, 1997, FPL committed to conduct a graded review of the St.

Lucie Updated Final Safety Analysis Reports (UFSARs). As stated in the letter, the

UFSAR review eFort and resources are being expended in those areas ofgreatest safety

significance. The review scope includes examination of relevant system documentationand'walkdowns ofsystem critical characteristics. FPL also committed to evaluate the

outcome of the UFSAR review and, as necessary, expand the scope of the UFSARreview.

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Two additional FSAR review projects have been undertaken to identify and correct errorsin the UFSAR. The first of these projects was a comprehensive review of the UFSAR

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against plant operating procedures by a multi discipline task team which commenced in1996. This review resulted in both procedure and UFSAR changes as appropriate toreconcile identified conflicts between plant operation and the UFSAR descriptions oftheseactivities. This review is complete and all associated UFSAR corrections are scheduledfor resolution by February 1999. Secondly, an ongoing review of the fire protectiondescriptions in the UFSAR is being conducted as a part of the preparation for the spring1998 Fire Protection Functional Inspection (FPFI).

The following corrective actions were established to prevent recurrence ofUFSAR errors:

A. A new style guide has been developed which is undergoing trial use during thecurrent Unit 2 amendment preparation. The style guide provides standards forformat and content ofUFSAR changes, which should minimize typographical andeditorial errors in UFSAR updated packages. These types oferrors are associatedwith a lack ofattention to detail in UFSAR amendments. Recent Industry andNRC emphasis related to the Millstone UFSAR issues has greatly heightened theawareness of the need for management and accuracy of the UFSAR updateprocess.

Standardized training has been developed for personnel who perform 10 CFR50.59 screening activities. Awareness has improved at all levels of theorganization with respect to the potential for changes in operating practices topotentially impact the UFSAR descriptions. Plant administrative procedures alsonow require that all 10CFR50.59 safety evaluations be performed by trainedindividuals in the Engineering department.

C. The UFSAR update process has been upgraded with more detailed proceduralguidance to ensure that all UFSAR change sources are reviewed. New searchtools are being utilized which facilitate locating potential UFSAR impacts andincrease the accuracy ofUFSAR change packages as they are being developed.These search tools also facilitate checking by the UFSAR update group duringpreparation of the UFSAR amendments.

5. Full compliance willbe achieved with the completion ofAmendment 16 to the Unit 1

UFSAR.