IR 05000250/1991041
| ML17348B312 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 12/02/1991 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17348B310 | List: |
| References | |
| 50-250-91-41, 50-251-91-41, NUDOCS 9201030024 | |
| Download: ML17348B312 (49) | |
Text
ENCLOSURE INITIAL SALP BOARD REPORT U. S.
NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMATIC ASSESSMENT OF LICENSEE-:PERFORMANCE INSPECTION REPORT NUMBER 50-250,251/91-41 FLORIDA POWER AND LIGHT COMPANY TURKEY POINT UNITS 3 AND 4 AUGUST 1, 1990 - SEPTEMBER 28, 1991 e OiOSOoan 9>>20'DR ADQCK 05000250 G
g I
SUMMARY OF RESULTS This 14-month assessment period for Turkey Point was unusual, in that it included about four months of dual-unit operation and about ten months of dual-unit outage.
During this outage period, extensive plant modifications were accomplished.
An emergency power system enhancement included the addition of two new emergency diesel generators with associated electrical switchgear and cables.
A security upgrade included replacement of most of the security hardware.
In recognition of the extensive outage activities, a separate Outage section has been included in this report.
The area of Plant Operations improved considerably.
Improved plant and
'operator performance resulted in a reduction of reactor trips and forced shutdowns which in turn contributed to a dual-unit run of 102 days.
Effective corrective action programs, increased licensed operator staffing levels, and reduced problems with equipment clearances were also noted.
The Board noted that additional attention is needed to address control of systems shared with the fossil units, such as the electrical switchyard.
Continued improvement was noted in the area of Radiological Controls.
As Low As Reasonably Achievable (ALARA) program strengths contributed to effective control of overall dose 'exposure.
Improvements to laundry facilities contributed to'
reduction in personnel. contamination events (PCEs).
However, weaknesses continued in solid radiological waste storage, processing, and transportation.
Performance in the area of Maintenance also continued to improve.
The material condition of the plant was notably improved.
Also, the timeliness of preventive maintenance was improved and the backlog of corrective maintenance items was reduced.
Areas for further improvement include maintenance overtime, control room deficiencies, and quality of maintenance work.
Considerable improvements were noted in the areas of Security and Emergency Preparedness.
Installation of the major security upgrades and improved security training were noteworthy.
Several Emergency Preparedness strengths were noted during the November, 1990, exercise.
Engineering/Technical Suppor't performance continued to be good.
Noteworthy was the conservative planning for the contingency of a loss of offsite power that occurred during the outage and the timely completion of Plant Change/Modification (PC/M) packages prior to the outage.
Examples of good engineering solutions to equipment problems, effectiveness of the System Engineer Program, and excellent operator training results were also noteworthy.
Engineering areas for improvement include oversight of contractors'ork and control of equipment selection and procurement.
Overall management and control of the outage was extremely effective.
This major outage was completed with very few problems and ahead of schedule.
Planning, scheduling, and work controls were very effectiv Also noteworthy were 'plant configuration controls and testing of equipment.
Performance in the Safety Assessment/guality Verification area continued at a high level.
Management involvement in plant operation and outage activities, quality assurance audits, self assessments, and root cause analysis was very effective.
Facilit Performance Summar Functional Area Plant Operations Radiological Controls Maintenance/Surveillance Emergency Preparedness Security Engineering/Technical Support Outage Safety Assessment/
equality Verification III. PERFORMANCE ANALYSIS
2 Improving
. Improving
2 Improving
NA I
Improving
Improving II 2I Rating Last Period Rating This Period (8/1/89 - 7/31/90)
(8/1/90 - ~9/28/91 A. Plant Operations 1.
~Anal sis This functional area addresses the control room and performance of-activities directly related to operating the units, as well as fire protection.
These activities were reviewed during routine and special inspections conducted throughout the assessment period.
During the early part of this assessment period, both units operated simultaneously for 102 days, which exceeded all previous dual-unit runs.
There was one reactor trip during'his SALP period:
Unit 4 automatically tripped when a condensate pump tripped (due to wetted motor'windings)
and subsequently a feedwater pump tripped (due to a faulty setting of a time delay relay) before a'standby condensate pump could provide makeup.
This was an improvement over the previous SALP periods.
Overall, there were fewer personnel errors during this period than during previous SALP periods.
However, there were instances early in the SALP period that indicated a lack of operator attention to detail.
For example, a component cooling water pump automatically started on low system pressure when one of two operating component cooling water pumps was secured prior to the ful,l closure of a system isolation valve.
Also, an operator failed to properly monitor reactor coolant system pressure during low pressure
operations, resulting.in the inadvertent actuation of a power operated relief valve.
The licensee successfully initiated a number of actions to reduce personnel errors, such as management meetings and training operators to utilize self-checking prior to'performing any action.
Plant events associated with equipment clearances were noted as a
problem during the previous SALP period.
The.licensee revised its clearance program and created a separate outage clearance group prior to the outage, and plant events associated with equipment clearances were substantially reduced during this SALP period.
Prompt and effective operator performance has been noted.
When a
heater drain pump tripped off due to a ground fault, the operators promptly reduced power and stabilized the plant with one heater-drain pump.
Also, during the outage, fuel off-load and reload were handled by Operations personnel.
Fuel movement had been previously performed by contractors.
The fuel movements by operators were handled professionally and without incident.
During restart from the outage, an alert operator was responsible for identifying that inappropriate constants had been entered into the newly installed Reactor Protection System.
The NRC expressed concern during previous SALP periods regarding the use of excessive overtime by Operations staff.
Increased Operations staffing during this assessment period allowed a reduction in overtime and permitted implementing a six-shift rotation in early 1991.
Since January, 1991, Operations maintained its overtime rate at 14%, which was greater than its lOX target but an improvement over previous SALP periods in spite of the demands of the extended dual-unit outage.
Increased staffing also allowed the transfer of experienced operators into Planning arid Scheduling, Emergency Preparedness, and Training (which is now fully staffed by FPL employees).
Two initial operator exams were administered during the assessment period.
In November, 1990, and January, 1991, all 25 Senior Reactor Operator (SRO) candidates successfully passed the examination.
Additionally, four of five applicants passed the NRC. Generic Fundamentals Exam during this SALP period.
During the operator exams, three instances of procedure deficiencies were noted as causing operator difficulties with abnormal conditions.
These included:
Emergency Plan Implementing Procedures regarding event classification, the Off-Normal Operating Procedure for a dropped control rod, and ATWS caused by instrument failures; The licensee responded by revising each of the procedures.
Another large class of operators was in training at the end of the SALP period which, when coupled with the low turnover rate of licensed operators, will continue to improve the overall staffing of operator e
Plant changes made during the outage have been properly integrated into the Emergency Operating Procedures (EOPs'), Off Normal Operating Procedures (ONOPs), surveillance procedures, and control room drawings.
Also, plant and procedural changes had been incorporated into training.
The Operations department implemented'n in-depth plan-of-the-day (POD) meeting during the previous SALP period, and this was combined with the daily outage meeting during the outage.
This meeting was very comprehensive and well controlled such that all disciplines, were involved in planning and defining the next few days'ork objectives and critical path work.
Operations had the necessary control to assign priorities for maintenance activities and ensure that operational concerns were addressed.
The POD effectiveness, defined as the percent of jobs started and worked as scheduled compared to the total number of jobs scheduled, continued to improve and approached the licensee's aggressive goal toward the end of the assessment period.
Shift briefings were held in the control room and were thorough and professional.
Operations explained the shift objectives and discussed with each department its main work activities for the shift.
This permitted Operations and craft personnel to better understand the on-going work activities and objectives.
Management has been active in support of plant operations.
The Operations Supervisor was routinely in the control room, and the Operations Superintendent and the Plant Manager made frequent plant and control room tours.
During the startup period after the outage, a management watch program was initiated which provided management-on-shift overview 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.
Members of the management watch program were required to concur that the units were ready to change modes and to provide daily briefings to,upper management of any concerns or strengths.
An inspection of the licensee's fire watch program and an Appendix R
inspection of changes incorporated during the outage were conducted during this SALP period.
The results indicated that the licensee had an adequate fire protection program.
However, there were some missed survei llances in the fire protection area whi.ch are discussed in the, Maintenance/Surveillance section of this report.
Problems with control of work on shared systems between the fossil and nuclear units were evident during this SALP period.
The fossil units initiated a modification to the shared non-safety related service water system which affected the fire protection system piping and was detected by an operator noting that work was being accomplished without proper controls.
Additionally, an electrical relay asso'ciated with offsite power transformer availability was identified as not having adequate test criteria and was not being properly controlled.
Other interface areas, such as control of access forelectrical switchyard work, have not been permanently addressed,
2.
Two violations were cited in the Operations area during this assessment
.period.
Performance Ratin 3.
Category:
Recommendations The Board noted that additional attention by licensee management is appropriate to permanently address control'f systems shared between the fossil and nuclear units, such as the electrical switchyard.
B. Radiolo ical Controls J
~Anal sis This functional area addresses those activities directly related to radiological controls and primary/secondary chemistry control, as viewed during routine inspections conducted-throughout the assessment period.,
Radiation Protection (RP) organization and staffing were adequate to protect worker health and safety.
Licensee actions to fill a
.&4+jp,:,-:
vacated Health Physics (HP) supervisor position with a qualified individual were timely and maintained continuity for ongoing program activities and initiatives.
gualified Radiation Protection Man (RPN) (ie.,
HP technician) staffing provided sufficient coverage for the outage activities.
Numerous changes to the Chemistry organization were initiated by the licensee to further strengthen management oversite and control.
Although manpower levels remained unchanged, the department was reorganized such that a
new group was established to oversee on-line monitors; a special projects and outage coordinator was appointed to oversee secondary system wet layup and to coordinate during the outage activities; and the supervisor responsible for the chemistry aspects of the water treatment plant also was placed in charge of secondary chemistry.
Improvements in specialized training for personnel were observed during the assessment period.
These improvements, such as detailed mockup training, contributed to increased worker efficiency for expected high person-rem expenditure tasks, including resistance temperature detector (RTD) removal, and steam generator (S/G)
associated activities.
RPM continuing training was comprehensive and effective, and was supplemented by an aggressive schedule of periodic shift and weekly staff briefings.
Briefings stressed areas requiring RP program emphasis, including procedural changes, recent industry events, and items of noncompliance.
Licensee self-identification of RP and chemistry program weaknesses, including quality assurance (gA) audi.ts and radiological incident
reports, continued to be regarded as a program strength; gA auditors were experienced and well trained to review RP activities.
Audits were comprehensive, thorough, and continued to strengthen the HP program.
Licensee-identified issues, included failure to adhere to high radiation area posting; inaccurate radioactive waste shipment radionuclide quantities; lack of survey documentation for bulk material released from the radiologically controlled area (RCA); lack of chemistry acceptance criteria; and improper receipt, control, and storage of radioactive materials outside of the RCA.
Staff and management responsiveness to identified issues and subsequent corrective actions were considered timely and appropriate.
Weaknesses in the respiratory protection and radiological control programs were identified during the review period.
Respiratory protection issues included the failure to follow procedures for full-face respirator issuance and for verification of Grade
quality for station breathing air.
Other weakness were noted for adherence to respiratory protection procedural training frequencies and administrative controls associated with TS required surveillance.
within containment.
Overall, the licensee continued to effectively manage collective dose expenditure during the assessment period.
For the extensive work activities during 1990, including initiation of the dual-unit outage activities in November and routine Unit 3 (U-3-) refueling activities earlier in the year, an annual dose expenditure of 365 person-rem per unit was reported.
For dual-unit outage activities during the period extending from November, 1990, through October, 1991, the licensee reported a total expenditure of approximately 480 person-rem per unit relative to the goal of 650 person-rem per unit, which was an aggressive goal considering the work planned.
Licensee initiatives for the
"As Low As Reasonably Achievable" (ALARA) program were considered program strengths contributing to immediate and long-term reduction of dose expenditure.
The removal of the U-3 and U-4 RTDs, a dose intensive task, was conducted, in part, to decrease long-term dose expenditure.
Completion of this task was an ALARA program success with dose expenditures approxi-mately 60 to 85 percent of the 90 person-rem originally estimated to complete the task.
These were among the lowest values reported for similar tasks within the industry.
Further, a dose expenditure of 13.3 person-rem for 100 percent Eddy Current Testing (ECT) of the U-4 S/G was approximately 50 percent less than dose expenditure for similar ECT activities conducted during a previous outage.
Improved preplanning, increased use of temporary shielding within containment, and improved mockup training were identified initiatives contributing to the reduced dose expenditure.
Continued improvement was noted in the reduction of personnel contamination events (PCEs),
For 1990, 214 PCEs were reported.
However, a significant decrease in PCEs to 90 was noted during the
dual-unit outage from January through September 30, 1991.
This reduction was due to corrective actions for i'dentified laundry facility equipment problems, improved monitoring, decreased acceptable contamination limits for laundered protective clothes (PCs),
and utilization of additional vendor laundry services.
Licensee actions to improve the control/recovery of contaminated floor space continued.
Throughout most of the outage, approximately 11,000 to 14,000 ft~ (9 to 11 percent) of the potentially recoverable floor space, was controlled as contaminated during the outage.
This value represented a significant reduction from the
percent contaminated floor space controlled during previous extended outages.
As a result of extensive valve testing and painting activities during the July through August, 1991, period; approximately 18,000 to 23,000 ft~ was controlled as contaminated.
Following completion of valve testing and painting activities, licensee initiatives for efficient decontamination (for example new floor surface coatings)
resulted in rapid recovery of contaminated floor space.
Weaknesses continued from the previous'SALP period for solid radioactive waste storage, processing, and transportation activities.
Poor practices, such as poor housekeeping and inconsistent labeling, for clean/contaminated.
waste receptacles in the radioactive waste sorting areas were identified.
Violations, including a repeat occurrence, were noted for failure to follow procedures regarding labeling of onsite storage containers.
In addition, an issue regarding failure to maintain a continuously operable emergency response telephone line during transportation of hazardous materials was identified.
2.
A confirmatory measurements evaluation was performed with beta-emitting samples sent to the licensee.
All four analyses were in agreement with the known values.
The liquid and gaseous effluent programs were effective.
Three unplanned liquid releases were identified during this reporting period.
The majority of the unplanned released activity, an estimated 7.74 E-2 curries, resulted from a U-3 transfer canal leak which drained through the caskwash area.
Liquid and gaseous effluent releases were in accordance with requirements, the releases and their associated doses were well within TS limits, and the reported environmental measurements for 1990 were consistent with those of previous years.
Four violations were cited in the Radiological Controls area during the assessment period.
Performance Rating Category:
Trend:
Improving
3. Recommendations None-C. Maintenance/Surveillance
~Anal sis This functional area addresses those activities related to equipment.
condition, maintenance, Technical Specifications surveillance, and equipment testing as viewed during routine and special inspections conducted throughout the assessment period.
The licensee's continued efforts in material upgrade and reliability improvements have shown positive results as evidenced by reduced trip rates and fewer unplanned days off-line.
The licensee continued to improve the material condition of the plant throughout this period.
For example:
over 650 valves were repacked, approximately 80,000 square feet of surface area inside the containments was painted, the No.
3 blackstart diesel generator was overhauled (completing the overhaul of all five blackstart diesel generators),
the Unit 3 and 4 containment spr'ay pump rooms and the water treatment acid tank were cleaned and painted, and extensive maintenance support was provided toward reducing the total amount of contaminated floor space.
" The licensee's program requiring 'formal management walkdowns of the plant, which was implemented during the last period, continues to be an effective method for the identification and resolution of material condition deficiencies.
Follow-up inspections of the areas indicate that deficiencies are being corrected or added to the plant work order system to be corrected as the priority warrants.
The licensee continued with a comprehensive motor-operated valve (MOV) maintenance program.
Accomplishments at the end of this cycle included the overhaul and diagnostic testing of almost all safety-related MOVs in both units.
In addition, most MOV spring packs have been replaced to prevent hydraulic locking and Belleville washer collapse, both of which were identified as potential problems.
The licensee has also replaced the old style two-train limit switches with four-,train limit switches to separate the closed light indication from the open torque switch bypass settings.
The licensee's MOV program has shown notable results over the past several years.
The licensee's MOV failure rate had decreased to 2.65 failures per million component hours at the end of 1990, which was below the industry average of 3. 1.
There were several instances of plant operations being impacted by equipment malfunctions during this assessment period.
Examples included:
failure of 3B and 4A heater drain pump seals, Unit 4 reheat stop valve inadvertent closure, 4B steam generator feed pump thrust bearing failure, and failure of the 4A heater drain pump motor.
Additionally, examples of problems with quality of work were noted diiring this period. Specifically, a reactor trip was caused by
improper setting of Agastat relay in the steam generator feed pump trip circuitry, Unit 3 pressurizer safety valves were installed with improper gaskets, repetit'ive drainage problems existed with the Auxiliary Building floor drains, instrument tubes were damaged when drilling a stuck corio-seal bullet nose, and the Unit 3 reactor vessel stud hole threads were damaged during stud installation.
Improvements continued to be made in the areas of training facilities, staffing levels, and turnover rates throughout this assessment period.
Maintenance training equipment was added, including a complete emergency safeguards sequencer panel, a Unit 4 emergency diesel generator (EDG) control panel, new Brown Boveri 4160 and 480 volt switchgear, reactor vessel head stud tensioners, and new battery chargers.
The end-of-SALP cycle staffing levels for the four maintenance disciplines appeared appropriate.
Although turnover rates in general have shown a downward trend since the last SALP cycle, the loss of Instrumentation and Control Specialists is still a concern.
Toward the end of the SALP cycle, the year to date average overtime for the Maintenance Department was 23K, compared to.
over 27% noted during the last cycle.
The licensee continued efforts to reduce the backlog of plant work orders (PWO).
These efforts resulted in a positive downward trend during the first part of the SALP cycle as the backlog approached the licensee's goal of 700 in December 1990.
Due to the effects of the outage, the PWO backlog increased to almost 1000 in February 1991, but has remained around 700 since April 1991.
The licensee has continued to emphasize reducing the number of control, room deficiency tags and control room instruments out of service.
These indicators showed a downward trend prior to the outage, reaching an all-time low of 44 deficiency tags and 28 instruments out of service.
However, redirection of mai'ntenance efforts during the outage caused the numbers to increase.
The licensee's reliability centered maintenance program, which was established during the last SALP cycle, has completed the analyses for about 15 problem areas to date in an effort to reduce unplanned shutdowns/unplanned days off line and corrective maintenance effort.
In response to the results of the analyses, the licensee is implementing modifications to equipment design, maintenance, and operational practices.
Components analyzed by this group include:
controller hand/auto pushbuttons, reactor head o-rings, power operated relief valves, and steam generato'r feed pumps.
This program, along with the predictive maintenance program, continues to be an effective means of identifying degraded conditions so that corrective maintenance can be accomplished prior to equipment failure.
Several examples of early detection include the use of thermography to properly balance silicon controlled rectifier (SCR)
output in battery chargers, identification of condenser air leaks, and location of hot spots in electrical equipment/switch gear.
Implementation of the preventive maintenance (PM) program continued to improve throughout this assessment period.
The number of overdue
2.
PM items declined from an average about 20 overdue PMs per month to
=
less than 10 per month during this cycle.
However, the ratio of preventive maintenance to corrective maintenance declined from 62:38 to 47:53 during this period, which was below the licensee's goal of 60:40.
The cause for the decline was the increase in corrective maintenance being performed during the outage.
The Inservice Inspection ( ISI) program was very effective in most areas.
ISI activities were performed in an excellent manner by highly qualified personnel.
Management at all levels was involved in assuring quality, as evident by the computer-'based programs initiated by the, licensee and its vendors, and excellent work practices observed.
ISI records documented examinations and discontinuities in a very effective manner.
Evaluations and disposition of findings were effectively analyzed and resolved.
Excellent radiographic technique, good work practices, and sound judgement in disposition of discontinuities were evident.
Early in this assessment period, problems associated with surveillance scheduling and tracking were noted.
The licensee issued four licensee event reports (LERs) between September and December, 1990, regarding failures to perform Technical Specifications required surveillances within the required timeframe.
These missed survei llances resulted from personnel errors, inadequate procedural guidance, and inadequate administrative controls.
Three of these LERs involved missed fire protection surveillances.
In response to these problems, the'icensee performed a management review of problems associated with surveillance scheduling and tracking.
This resulted in the creation of a new computerized surveillance tracking program.
It became the principal source for tracking and scheduling all technical specifications survei llances required to be performed at intervals of weekly or longer.
Other required surveillances continued to be tracked by a manual tracking system.
Several audits were performed to ensure that all required survei llances were captured by the new surveillance tracking programs.
These included an audit by a 'dedicated group of SROs and an audit by an independent contractor.
In addition,. an NRC inspection indicated that all surveillances associated with the emergency power upgrade had been incorporated into the new surveillance program.
The new surveillance tracking procedures were implemented in August 1991.
Four violations were cited in the area of Maintenance/Surveillance during this SALP assessment period.
Performance Ratin 3.
Category:
Trend:
Improving Recommendations None,
D.
Emer enc Pre aredness
~Anal sis This functional area includes activities related to the Emergency Plan and implementing procedures, support and training of onsite and offsite emergency response organizations, and licensee performance during emergency exercises, actual events, and routine inspections.
Overall, the Emergency Preparedness (EP) program received strong management support.
The licensee effectively maintained the basic emergency preparedness.
elements needed to promptly identify, correctly classify, adequately staff, and effectively implement the elements of the Emergency Plan and respective procedures in response to emergency events.
The licensee's emergency preparedness program was generally well organized and managed.
The program was maintained in a state of operational readiness with adequate facilities, equipment, and staff for responding in the event of an emergency.
The licensee conducted an independent audit during the assessment period to review the overall implementation and maintenance of the emergency preparedness (EP) program.
The use of a new EP corrective action item tracking system was effective in ensuring that prompt and appropriate corrective actions were completed to address findings identified during the independent audit, and during inspections, drills and exer cises.
Early in this assessment period, although there were no significant deficiencies, the EP action item tracking system had over 200 items identified for EP program improvement.
The licensee has made good progress toward addressing these items.
The licensee demonstrated the ability to staff the emergency response organization with qualified and well-trained personnel during the November 1990 exercise.
The licensee's performance during the exercise effectively demonstrated the ability to provide for the radiological safety of onsite personnel as well as the public.
The response organization demonstrated ability to effectively implement the Emergency Plan during the exercise including identification and classification of the emergency situation, accident mitigation, effective communications with state and local authorities, effective dose projection and monitoring, and proper protective action recommendations.
The licensee's critique of the exercise was judged to be effective, and the licensee pursued timely corrective actions for all deficiencies identified.
During the exercise, strengths were identified within the l,icensee's emergency response organization and facilities to include:
.
excellent command, control, and technical knowledge of the plant and plant systems; a
new in-plant radio system which provided effective exercise control for Operations personnel and fire team
e
coamunications; and status boards which were'egibly maintained, frequently updated, and with off-normal values highlighted for quick identification.
One issue identified during the exercise concerned the additional training of offsite communicators needed to ensure that any changes made to the state offsite notification form, after authorized for release by the Emergency Coordinator, be brought to the attention of and concurred in by the Emergency Coordinator.
No exercise weaknesses were identified during the 1990 exercise.
During this assessment period the operational readiness of the site Emergency Preparedness program remained high.
No significant findings were identified in the key program elements of the Emergency Plan'nd associated implementing procedures, facilities and equipment, or in overall EP organization and management control.
The licensee initiated an extensive training upgrade to the emergency preparedness lesson plans and instruction modules during this period in order to make all EP training modules more user friendly and task specific.
Readiness to respond in the event of an emergency was further enhanced by several self-initiated augmentation drills as well as numerous -specialized response team
"tabletop" drills.
Several drills involved efforts to improve on site emergency response facility activation timeliness.
Toward the
'nd of the assessment period, the licensee authorized a third full-'ime emergency preparedness staff person 'on site with Operations qualifications to strengthen the overall EP organization.
The transition to a
new EP site supervisor during the period was being achieved effectively without any apparent loss of program effectiveness.
The licensee is undertaking steps to improve activation timeliness at the Emergency Operations. Facility in downtown Miami, Florida in order. to conform to regulatory guidance in this area.
Two emergency declarations were made during the assessment period, both at the Notification of Unusual Event level, and both involving loss of offsite power.
The event classifications were prompt and correct, and offsite authorities were notified in accordance with requirements.
No exercise weaknesses or cited violations were identified during the assessment period.
2. Performance Ratin 3.
Category:
I Recommenda tions None
E. ~Securit l. ~Anal sis This functional area addresses security activities related to protection of plant vital systems and equipment and special nuclear material.
In addi tion, the area addresses the licensee's Fitness for Duty Program.
During this assessment period, the licensee completed approximately 85K of the planned major security upgrades and was ahead of the schedule for completion of all upgrades by December, 1991.
Changes to the security program were extensive and involved an almost complete replacement of-all security hardware, construction of barriers for all vital areas, and a complete rewrite of the security plan.
The Security Department was consolidated into one location in the new nuclear entrance building.
Major segments of the upgrade security system were implemented on July 1, 1991, including:
activation of approximately 50 percent of the reconfigured protected area perimeter, pew central and secondary alarm stations, personnel and vehicle access control facilities, and dedicated emergency security diesel generator and associated uninterruptible power supply equipment.
NRC review found that the security upgrades were successfully resolving long-standing issues.
. FPL has addressed this area aggressively and effectively, resulting in a significant upgrade of the entire security program.
The installation and transition to operational status of major components of the upgraded security system have been accomplished with no identified degradation or adverse impact on security effectiveness to date.
During most of the assessment period, a
majority of the vital areas were devitalized, reducing security force responsibilities.
However, security manning requirements were increased by demands for compensatory measures to support other security program upgrade activities, particularly with regard to
"phase-in". of new system components, and the new plant emergency diesel facility.
The improvement in program effectiveness was demonstrated, in part, by the fact that only one violation of regulatory requirements, which resulted from conflicting interpretation of Technical Specifications and Physical Security Plan requirements, was identified during this assessment period.
A new security contractor assumed responsibility for the security force.
Job enhancements, along with improved working conditions, have resulted in a continuation of the trend of improvement in personnel performance and security program effectiveness, which was noted during the previous assessment period.
Corporate and site senior management have continued to demonstrate commitment and support for completion of the security upgrade.
This was through "hands-on" involvement in program activities, participation in resolution of problems associated with identified deficiencies in system components and functional acceptance criteria, and by providing adequate funding to meet established levels of operational performance and effectiveness.
Evaluation and
testing of the operational components of the upgraded security systems validated the operability and effectiveness of those components relative to compliance with regulatory requirements and Physical Security Plan commitments.
Some procedural and hardware difficulties were encountered during the installation and implementation process, specifically with regard to central and secondary alarm station functional activities relative to assessment and excessive false and nuisance alarms.
However, the problems were promptly addressed and an acceptable level of performance was demonstrated.
No significant deficiencies in the security system were identified during the SALP period.
Continued improvement in training provided to security personnel has been noted during this assessment period, as evidenced by the decline in the number of violations related to personnel performance and the professional attitude of security shift personnel.
The security force has been provided an excellent training facility that has proven beneficial in conducting joint tactical response training with the Dade County Metro Police Department.
The joint training culminated in a large-scale contingency exercise in November, 1990, involving ground and airborne response forces.
Approximately 300 local law enforcement agency personnel participated in the entire exercise which was video-taped for training purposes.
A major strength of the licensee's security program is the continued communications and coordination among site, corporate, and the NRC regarding Security Plan revisions, equipment upgrades, and facility renovations.
2.
The licensee's Fitness For Duty Program (FFD) was effective in meeting the objectives of a drug-free workplace.
Implementation was satisfactory, with several strengths noted,'including the professionalism of the staff, the FFD testing facility, and FFD training.
One violation was cited in the Security area during this assessment period.
Performance Ratin
~ Category:
I 3. Recommendations:
None F.
En ineerin /Technical Su ort A~nal sis This functional area addresses those activities associated with the design of plant modifications; engineering and technical support for operations, maintenance, testing and surveillance, outages, and
procurement; and licensed operator training.
These=activities were viewed during routine and special inspections'hroughout this assessment period.
During this assessment period, the licensee initiated a
number of actions to help improve performance in the engineering and technical support area.
These actions included providing strong support to Maintenance and Operations organizations, improving 'self-assessment programs, and reducing dependency on the architect/engineer contractor. by performing more.of the engineering work in-house.
The plant change/modification (PC/M) post-implementation review process was improved to require that the review must be completed prior to system turnover to plant Operations.
The backlog of PC/Ms awaiting post-implementation review was reduced from" approximately 219 in January 1990 to 98 in May 1991.
Also, Engineering instituted a
program to rate the performance of its major architect / engineers (A/Es) with respect to nine separate attributes.
This evaluation technique appears to have encouraged the A/Es to improve their product and the performance ratings have shown an improvement.
Similar eval,uations have been used to assess the performance of the licensee's Production Engineering Group (PEG), which is the design group that develops PC/Ms.
In addition, a Design Review Board reviews selected PC/Ms originated by PEG to assess technical adequacy and quality of design reviews.
The two major engineering activities during the assessment
.period were the Emergency Power System (EPS)
Enhancement Project and the Security Upgrade Program.
The EPS project included installation of two new diesel generators and their associated'quipment, and the Security Upgrade Program included overhauling the total system with new state-of-the-art equipment.
The engineering effort was extensive, involving about 550,000 manhours. for these two projects alone.
About 97% of all engineering PC/M packages were completed
days or more before the start of the dual-unit outage.
This was a
significant accomplishment considering that there were a large number (over 280) of PC/Ms implemented during this outage.
An example of good engineering performance was demonstrated by the licensee's actions upon discovery of a problem with.the sequencer 3B ASEA/ABB relays.
Prompt and decisive action was taken to test and replace all faulty relays.
The generic aspects of this problem were
.determined and all relays were replaced.
Additional preoperational tests were completed to ensure proper. operation of the relays in each sequencer.
Another example of good performance was the lead shielded cable pre-qualification testing and pull test program.
During this outage, the licensee installed a programmable logic control based load sequencer system.
The procedures implemented by the licensee to control the quality of the system indicated a high level of commitment by the management.
Engineering's actions prior to and during conduct of the outage reflected a conservative management approach.
The engineering group developed preplanned contingency actions for potential events during
-
e
e the EPS actuation.
This included spent fuel pool (SFP) cooling and onsite backup power requirements, such as:
spent fuel pool redundant heat exchanger installation, alternate-cool'ing water fittings added to the component cooling water system piping, and a
trailer mounted diesel generator to provide redundant power supplies.
The licensee's preparation was evide'nt when on Harch 13, 1991, the startup transformer for Unit 4 locked out, resulting in a loss of all vital AC power to Unit 4.
Although the power was restored within two hours, alternative methods of SFP cooling were available, if needed.
The licensee's performance in planning for and handling this event was excellent.
Several plant problems were encountered for which engineering support demonstrated good problem solving capabilities.
The potential deterioration of the intake canal structure was thoroughly explored with an engineering structural rework/enhancement package provided on a timely basis.
The existing intake cooling water system piping was inspected and evaluated for continued ability to meet design requirements.
The resolution and corrective measures required for numerous high pressure turbine erosion/corrosion problems that were found following Unit 3 turbine, disassembly were prompt and thorough.
Also, during a review of the component cooling water (CCW) system, a system engineer noted an operability concern with one header of CCW separated from the remaining system.
With a single active failure, that alignment could prevent the operation of the required two-out-of-three emergency containment coolers.
Engineering appropriately expanded its review of this situation to determine what other safety-related systems might have similar unrecognized discrepancies and assured the issue was appropriately resolved.
During the Unit 3 shutdown, the 3C reactor coolant pump seal exhibited excessive leakoff.
The licensee's investigation and corrective actions were very extensive, including disassembly and inspection of the 3A and 3B reactor coolant pump seals.
The number of outstanding non-conformance reports (NCRs)
has been reduced from 367 in November 1990, (270 open greater than 365 days),
to approximately 58 (13 open greater than 365 days), in October 1991.
Also, the number of corrective maintenance plant work orders awaiting parts has decreased from 170 at the start of the SALP period to 35 at the end of the SALP period.
The number of backlogged Request for Engineering Action (REAs) has continued to decline over the current assessment period.
The licensee attributed the reduction to good communications and the interface between FPL corporate engineering and the onsite Technical Department.
In addition, the Technical Department has improved the method for prioritizing and screening REAs prior to sending them to corporate engineering for resolution.
The System Engineer Program established about two years ago appears to be working well.
The system engineers perform walkdowns of their assigned systems to identify deficiencies.
During the dual-unit outage, system engineers
.pgovided assistance in supporting the performance of 10-year ISI hydrostatic tests, participated in the
Joint Test Group to review the pre-operational test procedures and results and the development of the temporary 'system modifications, and participated in the startup test program for the EDGs and electrical systems and in the restart readiness program.
Seventy percent of the system engineers have completed the certification requirements for system engineer.
The current staffing level of system engineers appears to be adequate based on the present assignment of systems and work load.
Some procedural problems were noted during the period.
The licensee failed to identify proper conditions prior to performing the reliability tests for.the 48 EDG.
A demonstration of hydrogen recombiner operation was attempted using an off-normal procedure instead of a subsequently written test procedure.
Another procedure failed to specify isolation of electronic components during the post-installation megger testing of field installed power cables, resulting in some equipment damage.
Each of these problems was satisfactorily resolved.
Some program problems were noted.
An inconsistency existed in the quality of pipe support calculations; for example, three of six calculations improperly used catalog values for allowable concrete, anchor bolt loads.
A short circuit calculation used a 3.65 MYA typical machine rating instead of the 3.575 MYA actual machine rating.
Another example of. a program problem was the conduit installation procedure which did not provide an acceptance criteria for flatness in conduit bends, and several such bends were noted in the field to be slightly flattened.
An example of an engineering area that needs improvement is the oversight of contractors'ork and support to engineering.
Recently, FPL contracted for the calculation of reactor protection system and engineered safety features setpoint tables using a
proprietary five column setpoint methodology.
The licensee's oversight in the area was weak and relied heavi,ly upon contractor support.
This reliance on the vendor complicated the staff's review and adversely affected the licensee's ability to respond quickly to plant-specific questions.
The additional review resulted in changes to some of the initially proposed values to reflect.the actual as-configured conditions of the plant.
This demonstrated a weakness in FPL's internal review and control of the contractor's wo'rk in this specialized area.
The licensee has had problems in selecting and specifying reliable equipment.
Examples of new equipment installed that required extensive engineering followup to resolve operational problems included area radiation monitoring systems and the new emergency diesel generators'uel oil day tank auto fill system.
Two issues occurred during this period that indicated the licensee's need to improve quality verification that the designed instrumentation parameters and setpoints are properly installed.
These issues were:
1) non-plant specific tuning constants were placed in the Eagle-21 portion of the reactor protection systems and 2)
a wrong trip value was set for an Agastat relay in the feed pump
breaker trip logic, due to inadequate setpoint documentation, which resulted in a reactor trip.
~
Engineering has developed a minor engineering package (MEP) program to provide a more streamlined process for the design and implementation of plant changes that are considered minor.
This program allowed relatively minor engineering changes to be processed faster.
The plant-specific Individual Plant Examination ( IPE) was completed in June, 1991, as scheduled.
The engineering group actively participated in this effort.
As a result, a plant modification that was recommended by the IPE study was completed during this outage.
The modification provided an alternate source'f cooling water to the A and C charging pumps'ydraulic coupling oil coolers.
The B charging pump for both units had been similarly modified in 1976.
This modification significantly reduced the core damage frequency probability for the most dominant sequence in the IPE study.
Over 90 MEPs have been completed this year.
An NRC inspection team review of the MEP relating to the above modification recommended by the IPE study indicated a weakness in the design review and-post-implementation review process.
FPL took immediate action to revise the MEP review procedures and initiate a review of all MEPs.
2.
Two violations were cited in the area of Engineering/Technical Support during this assessment period.
Performance Ratin 3.
Category:
Recommendations None G. Outage Analysis This area includes outage planning, scheduling, configuration control, control of work activities, post-outage testing, and preparations for return of the units to operation.
These activities were observed during routine and special inspections throughout this assessment period.
The dual-unit outage preplanning was exceptionally well done.
FPL and NRC personnel met early in the planning phase to discuss the emergency power systems enhancement project outage.
FPL defined four phases for 'the dual-unit outage and the special precautions that would be taken to assure spent fuel pool cooling.
Projected spent fuel pool heatup rate curves were provided, major electrical lineups for each phase of the outage were provided, and the applicable porti.ons of the revised technical specifications were defined.
By letter',
FPL submitted a list of applicable technical
'pecifications, a list of equipment that would remain functional, and a description of the configuration control program that was to be in 'effect during the outage.
A temporary procedure was issued and used as a basis for configuration control throughout the -outage.
This temporary procedure was exceptionally well done and comprehensive, and it was precisely followed during the outage.
Other temporary procedures were issued prior to the dual-unit outage to provide guidance in the event of a loss of a system or component necessary to meet the specified requirements.
These procedures were well written, comprehensive, and provided several levels of protection.
As described in the previous section of this report,
,these procedures were of benefit during the loss of all vital AC power to Unit 4 in March, 1991.
Scheduling and planning were very effective for an outage of this magnitude.
There were several large emergent work items, such as the Unit 3 high pressure turbine housing rework, the 3C reactor coolant pump seal failure investigation, turbine plant cooling water heat exchanger foundation rework, etc., that were incorporated into the existing outage schedule.
The morning and afternoon plan-of-the-day meetings were used to identify the work schedule for the next few days, resolve work or schedule conflicts, and identify previously unplanned work.
The licensee scheduled the shutdown and fuel offload of Unit 4 prior to starting the shutdown of Unit 3 to reduce the opportunity for activities on one unit to be confused
,with activities on the opposite unit.
Also, Unit 3 fuel load and startup were scheduled to be complete prior to starting fuel load on Unit 4.
The maintenance department made a significant effort in planning for the dual-unit outage.
An outage group was established within the department five months prior to the outage.
This group was tasked with providing work packages, preparing construction work orders, assuring parts availability, and providing input to the schedule for identified maintenance for over 3,500 work packages.
The group contributed to completing the outage slightly ahead of schedule.
In addition, the maintqnance department performed the reactor disassembly and reassembly for both units in lieu of contractors.
The disassembly and defueling for both units were completed within the scheduled time and exposure.
Refueling and reassembly also went according to schedule, with the exception of damage to threads in three reactor vessel stud holes which were subsequently repaired.
The damaged threads were due to inadequate training of maintenance personnel.
Work controls were closely adhered to during the outage.
Work activities had to be scheduled on the plan-of-the-day prior to being worked.
Sensitive work areas were closely controlled.
For example, switchyard access was controlled by the Plant Supervisor - Nuclear as defined by a temporary procedure and regularly scheduled work
could not be performed in the switchyard for 90 days following the Unit 4 defueling.
To ensure that Operations was aware of the plant status during the outage, a temporary procedure was issued that required the Operations staff to be be notified of changes to the plant configuration as changes occurred but also on a weekly basis as a
minimum.
This notification was made by system engineers to the on-shift Plant Supervisor - Nuclear.
A Configuration Control Notification Notebook was kept in the control room and was kept up-to-date by the system engineers, while the on-shift Operations personnel kept abreast of changes incorporated during the outage.
Additionally, there was a Configuration Control Team formed of representatives from all disciplines to review near-term plant changes to ensure all affected groups were aware of upcoming changes and would not be adversely affected..
To ensure that outage modifications were properly incorporated into procedures or drawings and outstanding non-conformance reports were evaluated and closed out, a closeout team was put in place to review all paperwork associated with a PC/M and any outstanding actions (i.e., post-modification testing dependent on a certain mode) were entered on a punch list to ensure completion on a timely basis.'his is a major improvement over past practices which had resulted in the final review of older PC/Ms being accomplished after plant startup.
To eliminate the backlog of older plant changes that are still awaiting review, the closeout team is being retained to go back and review older plant changes for closeout.
'
During the outage, the licensee established a System Readiness for Restart Program to ensure that all identified deficiencies were documented and closed out.
This program identified approximately
systems, including all nuclear systems and those systems important to safety and plant reliability.
The systems were assigned their
'wn unique notebook which included all open items, including surveillance and maintenance activities and their expected completion dates.
This extensive effort was quite beneficial in that it provided plant management with a det'ailed status of each system.
It should be noted that this program, which was established for the outage, was in addition to the licensee's normal process for ensuring that all required work was completed prior to restart.
To identify equipment/system problems early during the recovery phase of the outage, the licensee issued temporary procedures to test specific equipment (i.e.
pumps or valves) or portions of systems to identify, as early as possible, work that would possibly result from equipment sitting idle and/or drained during the outage.
This permitted early scheduling of maintenance on those items showing degradation such that impact on reactor startup would be minimized.
The licensee's post-modification test program was comprehensive and well developed such that the preoperational testing was accomplished
0-
2.
with minimal discrepancies and within the original test schedule.
The integrated engineered safeguards testing 'was extensive.
For example, each sequencer was tested by simulating 24 different accident scenarios.
This testing also included portions of the TS-required surveillance tests which were then repeated with plant procedures prior to placing the equipment into operation.
The new Unit 4 emergency diesel generators and the modified Unit 3 emergency diesel generators were preoperationally tested with only minor discrepancies noted.
One violation was cited in the Outage area during this assessment period.
'erformance Ratin 3.
Category:
Recommendations None H. Safet Assessment/
ualit Verification
~Anal sis This functional area addresses licensee activities related to implementation of safety policies; license amendments, exemptions and relief requests; responses to Generic Letters, Bulletins, and Information Notices; resolution of safety issues, reviews of plant modifications made under
CFR 50.59; safety review committee activities; and use of feedback from self-assessment programs and activities.
These activities were viewed during routine and special inspections and communications throughout the assessment period.
During this period, licensee management became more directly involved in plant operation and status by conducting weekly outage status meetings with attendance by both corporate and site management, by increased management and supervisory presence in the field, and by Corporate Nuclear Review Board (CNRB) members being required to attend Plant Nuclear Safety Committee meetings and tour the facility periodically.
During the outage, the planning and scheduling group was assigned to the Outage Manager to integrate outage and operations concerns.
The CNRB was restructured late in the last SALP period with a designated full-time chairman and Board members reporting to the Vi'ce President of Nuclear Assurance.
The CNRB was enhanced by the addition of two non-licensee members who are members of other utilities'eview boards.
The Board's main function is to provide an independent review of activities related to nuclear safety and advise the President-Nuclear Division of any issues.
The members review gA audit results, NRC violations and licensee responses, Licensee Event Reports (LERs), license amendments, industry events,
and overall performance of the nuclear units in various key areas.
During the. outage-,
the CNRB recognized a lack of oversight with respect to the contractor's determination of setpoints and recommended that engineers be sent to the contractor's facility to further review the setpoint work.
The licensee's gA audit program has continued to be very effective in self-identification of problems.
The program carries out performance-based evaluations which contribute to the faci.lity's overall self-assessment efforts.
The group's'udits are comprehensive, in-depth, and have resulted in several issues of non-compliance with NRC regulations being licensee-identified and promptly corrected.
The gA audit program has been addressed as a
strength following inspections in the chemistry, health physics, operations, and outage areas.
In addition, the plant staff has made a noted improvement in the amount of time an audit finding remains open.
In May of 1990, there were 15 findings open greater than 180 days.
At the end of this SALP period, there were no findings open greater than 180 days, which indicates an improving trend in personnel accountability in correcting issues.
The licensee has made significant improvements in the area of self-assessment.
- In May of 1991, the President of the Nuclear Division tasked the CNRB to review and approve the overall plant restart program and provide oversight of the outage activities in addition to its normal responsibilities, This assisted in developing good teamwork, a higher quality of work; and a more conservative approach to nuclear safety.
The licensee also performed an in-depth self-assessment of the emergency power upgrade installed during the outage.
This audit was conducted by the gA department following the NRC's Safety System Outage Modification Inspection format.
In addition, an outside expert was contracted to provide current industry knowledge and review the audit results.
This assessment identified several weak areas which were corrected, resulting in improved safety and reliability of this major modification.
Additional self-assessments conducted during this cycle included the effectiveness in implementing the site Radiological Emergency Plan, the configuration control program for the outage, the design arid operation of the spent fuel pool cooling systems in place during the outage including the permanent and backup systems, and a simulator certification program assessment.
The licensee performed several in-depth reviews of the revised Technical Specifications (TSs)
issued on August 28, 1990, prior to implementation.
The reviews were conducted to ensure that all problems were identified and procedures were updated to reflect the new requirements.
Several license amendments containing changes to these TSs as a result of system modifications installed during the outage were issued during this period.
The new TSs were fully implemented as Unit 3 entered Mode 6 on August 24, 199 ee
Root cause analysis continued to be an asset throughout this period.
All major problems require an Event Response Team (ERT) to determine root cause and corrective action to be taken.
Safety significant failures of lesser magnitude that do not require an ERT still require a root cause analysis to be performed by the system engineer or other responsible individuals.
The ERTs and root cause analysis reports have identified several areas for improvement in plant procedures and processes.
Some of these include the following:
nonconforming material supplied by the vendor for component cooling water heat exchanger tubes, Unit 3 spent fuel pool transfer canal liner leak, 3C reactor coolant pump seal failure, analysis of reactor coolant system cooldown following reactor trips, and high radiation areas noted during movement of Unit 4 lower reactor internals.
There were two requests for temporary waivers of compliance.
The licensee's actions were justified and necessary; however, the licensee's letter to the NRC for the spent fuel pool keyway gate lift and seal repair contained errors regarding the keyway gate loads.
A second letter was submitted to correct the error.
However, a more thorough review is appropriate for documents regarding items of this nature.
This assessment period included several major licensing review activities, and staff reviews of the critical activities were expedited by the licensee's excellent cooperation throughout the period.
This included staffing of their Bethesda office with competent technical, personnel when warranted to support the reviews.
One major licensing review activity was the EPS enhancement effort.
During the staff's review of these modifications and associated TSs, and during several team inspections and audits, the licensee provided necessary support in a timely manner and the responses to-the NRC questions were of high quality.
This complex project was completed on schedule and. successfully, which reflects the licensee's excellent planning and management.
Another major licensing review activity that has been completed is the replacement of the resistance temperature detector (RTD) bypass manifold system with the dual element RTDs located directly in thei reactor coolant system hot and cold leg piping.
An Eagle-21 temperature averaging system was also installed as part of the RTD bypass system replacement.
Although the licensee was responsive and
~ cooperated fully in providing additional information to NRC staff questions, the flow measurement uncertainty analysis, performed by the contractor, contained inconsistencies and errors which delayed the staff's review considerably.
In the area of communications with NRC headquarters staff, the licensing staff at the site has provided excellent support in all licensing areas and has kept the NRC staff well informed of the status of activities at the site.
The licensee's LERs were well written and were issued in a timely manner.
A survey of the 50.72 reports indicated that the pertinent events were subsequently reported as LER e
In summary, the licensee's approach in safety assessment and quality verification was very successful during the SALP period and management involvement was evident in this functional area.
No violations were cited in the area of Safety Assessment/guality Verification during this assessment period.
2. Performance Ratin
'ategory:
3.
Recommendations None IV.
SUPPORTING DATA A. Licensee Activities During this SALP period, Unit 3 operated, at 100K power until September 1990 when a power reduction was necessary to repair a heater drain pump seal.
Unit 3 then returned to 100K power until shut down on December 12, 1990, for the dual-unit outage.
Unit 4 went on line on August 5, 1990, after having shut down on July 17, 1990 to repair leaking pressurizer spray valves.
During the Unit 4 startup, problems were experienced with the 4A heater drain pump seal and a reheat stop valve.
Unit 4 tripped on August 12, 1990 (see B. below).
Unit 4 returned to power operation on August 14, 1990.
In September 1990, power was reduced on Unit 4 to repair a main feed pump thrust bearing, and in November, 1990, power was reduced to replace a
failed heater drain pump motor.
Unit 4 then operated at 100K power until shut down on November 24, 1990, for the dual-unit outage.
Unit 4 commenced refueling activities after this SALP period.
"
B. Reactor Trips and Unplanned Shutdowns No unplanned reactor trips or unplanned shutdowns were experienced on Unit 3 during this assessment period.
Unit 4 experienced one unplanned reactor trip.
On August 12, 1990, Unit 4 automatically tripped from 100% power when a condensate pump tripped and subsequently the feedwater pump,tripped due to a faulty setting of a time delay relay.
C. Direct Inspection and Review Activities During the assessment period, 54 routine and three special team inspections were pe'rformed at Turkey Point by the NRC staff.
The special inspections included:
Design Verification Inspection Followup Emergency Operating Procedures Inspection followup Appendix R Ins'pection Operational Readiness Assessment
D. Escalated Enforcement Actions None E. Licensee Conferences Held During Appraisal Period November 27, 1990 Meeting held at NRC headquarters to discuss replacement of existing RTDs with thermowell mounted RTDs.
February 29, 1991 March 14, 1991 Meeting held at NRC RII office to discuss engineering excellence.
Meeting held at NRC headquarters to discuss Probabilistic Risk Assessment.
April 24, 1991 June
8 14, 1991 June 20, 1991 June 25, 1991 July 10, 1991 Interface meeting with FPL at Juno to discuss general issues.
Meeting held at NRC headquarters to discuss B&W Owners Group reactor vessel program.
Meeting held at NRC RII office to discuss 1 icensee
'
se1 f-asses sment of performance.
Meeting held at NRC headquarters to discuss status of licensing actions Meeting held at Turkey Point site to discuss dual-unit restart readiness July 18, 1991 August 27, 1991 Meeting held at NRC headquarters to discuss.
status of licensing issues.
Meeting at NRC headquarters to discuss licensee's IPE submittal.
F. Confirmation of Action Letters None G. Licensing Activities During the assessment period, the staff completed two major licensing review activities (emergency power system enhancement and reactor coolant system resistance temperature bypass manifold replacement),
license amendments, two Technical Specification waivers of compliance, and a number of other licensing actions, including responses,to Generic Letters and Bulletin H. Review of Licensee Event Reports During the assessment period;, a total of 19 LERs were analyzed.
The LER distribution, by cause, as determined by the NRC staff; is:
Cause Component Failure Design Construction, Fabrication, or Installation Unit 3 or Common Unit 4
0
0
Personnel Error
- Operating Activity
- Maintenance Activity
'- Test/Calibration Activity
- Other
6
Other ota
Note 1:
With regard to the area of "Pers'onnel Error," the NRC considers lack of procedures, inadequate procedures, and erroneous procedures to be classified as personnel error.
Note 2:
The "Other" category is comprised of LERs where there was a
spurious signal or a totally unknown cause.
Note 3:
Seven LERs were voluntary and not considered in this report Note 4:
The above information was derived from a review of LERs performed by the NRC staff and may not completely coincide with the licensee's cause assignments.
I. Enforcement Activity Functional Area No. of Deviations and Violations in Each Severity Level (Unit 3/4)
Dev.
V IV III II I
Plant Operations
.
Radiological Controls Maintenance/Surveillance Emergency Preparedness Security Engineering/Technical Support Outage Safety Assessment/equality Verification T TALS 2/2 4/4 4/4 0/0 1/1 2/2 1/1.
0/0 14/14
4