IR 05000250/2008008

IR 05000250-08-008 & 05000251-08-008; on 06/09-13/2008 - 06/23-27-2008; Turkey Point Nuclear Plant, Units 3 & 4, NRC Problem Identification and Resolution Inspection Report

ML082120558
Person / Time
Site:	Turkey Point
Issue date:	07/28/2008
From:	Vias S Division Reactor Projects II
To:	Stall J Florida Power & Light Co
References
IR-08-008
Download: ML082120558 (17)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION uly 28, 2008

SUBJECT:

TURKEY POINT NUCLEAR PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000250/2008008 AND 05000251/2008008

Dear Mr. Stall:

On June 27, 2008, the U. S. Nuclear Regulatory Commission (NRC) completed a team inspection at your Turkey Point Nuclear Plant, Units 3 and 4. The enclosed inspection report documents the inspection findings, which were discussed on June 27 and July 23, 2008 with Mr.

M. Kiley and other members of your staff.

The inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of plant equipment and activities, and interviews with personnel.

On the basis of the samples selected for review, there were no findings of significance identified during this inspection. The team concluded that in general, your corrective action program processes and procedures were effective; thresholds for identifying issues were appropriately low; and problems were properly evaluated and corrected within the problem identification and resolution program (PI&R). However, several examples of minor problems were identified where corrective actions have not been entirely effective, or potential adverse trends had not been identified and entered into the Corrective Action Program.

Enclosure

FP&L 2 In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Web-site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Steven J. Vias, Chief Reactor Projects Branch 7 Division of Reactor Projects Docket Nos.: 50-250 and 50-251 License Nos.: DPR-31 and DPR-41

Enclosure:

Inspection Report 05000250/2008008 and 05000251/2008008 w/Attachments: 1. Supplemental Information 2. Turkey Point PI&R Inspection 2008 Information Request

REGION II==

Docket Nos.: 05000250, 05000251 License Nos.: DPR-31, DPR-41 Report Nos.: 05000250/2008008 and 05000251/2008008 Licensee: Florida Power & Light Company (FPL)

Facility: Turkey Point Nuclear Plant, Units 3 & 4 Location: 9760 S. W. 344th Street Florida City, FL 33035 Dates: June 9 - 13, 2008 June 23 - 27, 2008 Inspectors: D. Merzke, Senior Project Engineer, Lead Inspector R. Taylor, Senior Project Inspector D. Mas-Penaranda, Reactor Inspector J. Wallo, Senior Physical Security Inspector M. Barillas, Resident Inspector, Turkey Point K. Ellis, Resident Inspector Development Candidate Approved by: Steven J. Vias, Chief Reactor Projects Branch 7 Division of Reactor Projects Enclosure

SUMMARY

OF ISSUES

IR 05000250/2008-008, 05000251/2008-008; 06/09/2008 - 06/27/2008; Turkey Point Nuclear Plant, Units 3 & 4; Identification and Resolution of Problems.

The inspection was conducted by a senior project engineer, two senior inspectors, one reactor inspector, and one resident inspector. No findings of significance were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Identification and Resolution of Problems Summary The team concluded that in general, problems were properly identified, evaluated, prioritized, and corrected within the licensees corrective action program (CAP). Evaluation of issues was generally comprehensive and technically adequate. Formal root cause evaluations for issues classified as significant adverse conditions were comprehensive and detailed. The team reviewed the licensees corrective action program improvement plan and actions to address evaluation quality, timeliness, and overall CAP effectiveness. The team determined that progress has been made in improving all areas addressed by the improvement plan. Overall, corrective actions developed and implemented for issues were effective in correcting the problems. However, the team identified examples where corrective actions have not been entirely effective, or potential adverse trends had not been identified and entered into the CAP.

The team determined that thresholds for identifying issues were appropriately low. Nuclear Assessment Section audits and departmental self-assessments were effective in identifying issues and directing attention to areas that needed improvement. Licensee identified weaknesses and issues in self-assessments were appropriately entered into the CAP and addressed.

Based on discussions and interviews conducted with plant employees from various departments, the inspectors did not identify any reluctance to report safety concerns.

NRC-Identified and Self-Revealing Findings

No findings of significance were identified.

Licensee-Identified Violations

No findings of significance were identified.

REPORT DETAILS

4OA2 Problem Identification and Resolution

The team based the following conclusions, in part, on issues identified during the period, July 1, 2007 (the last biennial problem identification and resolution inspection) to the end of the inspection on June 27, 2008. In addition, the team reviewed problems for selected systems, which were identified outside this assessment period whose significance may be age-dependent.

a. Assessment of the Corrective Action Program (CAP)

(1) Inspection Scope The inspectors reviewed the licensees corrective action program (CAP) procedures which described the administrative process for initiating and resolving problems primarily through the use of condition reports (CRs). The inspectors reviewed selected CRs, and attended meetings where CRs were screened for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold.

The inspectors selected CRs for review which involved issues covering the seven cornerstones of safety identified in the NRCs Reactor Oversight Process (ROP). The selected samples involved various licensee classified severity levels and site departments. The inspectors also conducted a detailed review of CRs for risk significant systems which were selected based on risk insights from the licensees probabilistic safety assessment and discussions with the Senior Resident Inspector. The systems selected for review were the Auxiliary Feedwater system and Containment Isolation.

The inspectors reviewed CRs, maintenance history, completed work orders (WOs) for the systems, and reviewed associated system health reports. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP. Items reviewed generally covered a two-year period of time; however, in accordance with the inspection procedure, a five-year review was performed for selected systems for age-dependent issues.

The inspectors conducted plant walkdowns of equipment associated with the selected systems to assess the material condition and to look for any deficiencies that had not been entered into the CAP. Control Room walkdowns were also performed to assess the main control room (MCR) deficiency list and to ascertain if deficiencies were entered into the CAP. Operator Workarounds and Operator Burdens screenings were reviewed and the inspectors verified compensatory measures for deficient equipment were being implemented in the field.

The inspectors reviewed CRs, including root and apparent cause evaluations, site and department trend reports, and observed other activities to verify that the licensee appropriately prioritized and evaluated problems in accordance with their risk significance. The inspection was intended to verify that the licensee adequately determined the cause of the problems, including root cause analysis where appropriate, and adequately addressed operability, reportability, common cause, generic concerns, and extent of condition.

The review included the appropriateness of the assigned significance, the timeliness of resolutions, the level of effort in the investigation, and the scope and depth of the causal analysis. The review was also performed to verify that the licensee appropriately identified corrective actions to prevent recurrence and that those actions had been appropriately prioritized.

The inspectors reviewed a sample of selected licensee effectiveness reviews and work orders initiated to resolve CRs to verify the licensee had identified and implemented timely and appropriate corrective actions to address problems. The inspectors verified that the corrective actions were properly assigned, documented, and tracked to ensure completion. The review was also conducted to verify the adequacy of corrective actions to address equipment deficiencies and maintenance rule (MR) functional failures of risk significant plant safety systems.

The inspectors attended various plant meetings to observe management oversight functions of the corrective action process. These included initial screening team (IST)meetings, as well as Management Review Committee (MRC) meetings.

Furthermore, the inspectors verified that issues identified by internal and external operating experience, licensee audits and self-assessments, and the employee concerns program were entered into and dispositioned by the CAP, as appropriate. The team also reviewed corrective action packages related to previously issued enforcement issues and licensee event reports.

Documents reviewed are listed in the Attachment.

(2) Assessment Identification of Issues The team determined that the licensee was generally effective in identifying problems and entering them into the CAP. There was no threshold for entering issues into the CAP and employees were encouraged to initiate CRs for any reason. Trending was generally effective in monitoring equipment performance. However, the team did identify a potential area for improvement in the identification of adverse trends. Procedure 0-ADM-533, CAP Performance Monitoring and Trend Analysis, states that identifying a trend should consider an increase in or undesirable number of events or trend codes over the period of time under analysis. The procedure specifies a new CR should be written when a trend is increasing in significance. The inspection team determined a trend CR was not initiated in accordance with plant procedure 0-ADM-533, for the undesirable performance of FCV-4-6278C, the 4C steam generator blowdown flow control valve, despite its impact on reactivity management, and a history of 15 CRs generated on the performance of the valve since January 2007. Also, CR 2008-20629 was recently written as a result of a site QA audit of the Chemistry department, identifying a weakness in the departments ability to identify and evaluate adverse trends. Additionally, a site QA audit on corrective actions and self-assessments completed in January 2008 stated that emerging negative trends impacting plant performance are not being promptly identified, reported, and corrected.

The team also conducted plant and system walkdowns and identified two deficiencies: a trash can was found in a marked non-combustibles area, and discrepancies were noted between the Control Room Deficiency Log and the actual condition of the control room boards. The licensee initiated condition reports 2008-19636 and 2008-20895 to address these issues.

Prioritization and Evaluation of Issues The team concluded that problems were generally prioritized and evaluated in accordance with the licensees CAP procedures and NRC requirements. Each CR written was assigned a priority level at the Initial Screening Team (IST) meeting, which was chaired by the Plant Improvement Department. Management reviews of CRs conducted by the Management Review Committee (MRC) were thorough, and adequate consideration was given to system or component operability and associated plant risks.

Additionally, feedback from the MRC was communicated to the IST for comments on specific CRs, as well as CRs where the MRC changed the initial priority level. The team found that in the sample of root cause and apparent cause evaluations reviewed, the licensee was generally self-critical and thorough in evaluating the causes of the conditions adverse to quality. The team noted two examples of evaluations that could have been more thorough:

• In CR 2007-32279, the extent of condition for identification of incorrect ASTM bolting material extended only to isophase bus links, where the original deficiency was identified. Consideration should have been given to include other systems and components where specific ASTM bolting material is required to be installed by procedure, and where there may be a possibility of installing the incorrect bolting material due to the inability of workers to identify the proper material.

• In CR 2008-9728, a recommendation to evaluate the 3B Main Steam Isolation Valve backup nitrogen system for leaks due to frequent nitrogen bottle changeouts was listed in the CR description. The concern was not addressed in the evaluation, nor was a corrective action generated to address the concern.

Effectiveness of Corrective Actions The team determined that overall, corrective actions were effective in correcting plant problems, and that most corrective actions implemented by the licensee were appropriate for the severity and risk significance of the problem identified. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence. However, one example was found of inadequate and untimely corrective actions. CR 2005-27299 was written as a result of the failure of a chain operator for valve 3-712B, the Component Cooling Water (CCW) Heat Exchanger 3B Inlet Isolation Valve. A corrective action was identified that all chain operators were to be evaluated and, if required, modified to prevent future failures leading to handwheel/operator falling. On May 21, 2008, the chain operating mechanism for valve 4-50-371, the 4A CCW Inlet Valve, failed. This valve had not been evaluated, nor modified, in accordance with the corrective action. The team determined this was not a violation of NRC regulations in that the original deficiency was not a significant condition adverse to quality, and as such, the licensee was not required to perform an extent of condition review. The licensee entered this issue into their corrective action program as CR 2008-21025. Additionally, the team noted that audits of the Security department conducted in 2006, 2007, and 2008 identified CRs that were closed out without clearly demonstrating that the corrective actions addressed the issues identified.

(3) Findings No findings of significance were identified.

b. Assessment of the Use of Operating Experience

(1) Inspection Scope The team examined licensee programs for reviewing industry operating experience, reviewed the licensees operating experience database, and interviewed the Operating Experience Coordinator, to assess the effectiveness of how external and internal operating experience data was handled at the plant. In addition, the team selected operating experience documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, vendor notifications, and plant internal operating experience items, etc.), which had been issued since July 1, 2007, to verify whether the licensee had appropriately evaluated each notification for applicability to the Turkey Point plant and whether issues identified through these reviews were entered into the CAP. Documents reviewed are listed in the Attachment.

(2) Assessment The team determined that the licensee was effective in screening operating experience for applicability to the plant. The inspectors verified that the licensee had entered those items determined to be applicable into the CAP and taken adequate corrective actions to address the issues. Operating experience was adequately utilized and considered as part of formal root cause evaluations for supporting the development of lessons learned and corrective actions for CAP issues.

(3) Findings No findings of significance were identified.

c. Assessment of Self-Assessments and Audits

(1) Inspection Scope The inspectors reviewed licensee Quality Assurance (QA) audits conducted by the Nuclear Assurance Department, and department self-assessments, including those which focused on problem identification and resolution, to verify that findings were entered into the CAP and to verify that these findings were consistent with the NRCs assessment of the licensees CAP.

(2) Assessment QA audits and departmental self-assessments were effective in identifying issues and directing attention to areas that needed improvement. Licensee identified weaknesses and issues in self-assessments were appropriately entered into the corrective action program and addressed. The team determined that the self-assessments and audits were critical, insightful, and persistent at identifying issues and entering them into the corrective action program. Based on the weaknesses and recommendations identified by the licensee, the team determined the self-assessments were thorough and comprehensive.

(3) Findings No findings of significance were identified.

d. Assessment of Safety-Conscious Work Environment

(1) Inspection Scope The team randomly interviewed 41 on-site workers regarding their knowledge of the corrective action program at Turkey Point and their willingness to write CRs or raise safety concerns. During technical discussions with members of the plant staff, the inspectors conducted interviews to develop a general perspective of the safety-conscious work environment at the site. The interviews were also conducted to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns. The inspectors reviewed the licensees employee concerns program (ECP) and interviewed the ECP manager. Additionally, the inspectors reviewed a sample of completed ECP reports to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate.

(2) Assessment Based on this inspection and the CR reviews, the team determined that licensee management emphasized the need for all employees to identify and report problems using the appropriate methods established within the administrative programs, including the CAP and ECP. These methods were readily accessible to all employees. Based on discussions conducted with a sample of plant employees from various departments, the inspectors determined that employees felt free to raise issues and felt that management encouraged employees to place issues into the CAP for resolution. The inspectors did not identify any reluctance on the part of the licensee staff to report safety concerns.

(3) No findings of significance were identified.

4OA6 Exit Meeting

On June 27 and July 23, 2008, the inspectors presented the inspection results to Mr. M.

Kiley and other members of his staff who acknowledged the results. The inspectors confirmed that proprietary information was not provided or retained following the inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

N. Eggemeyer, Security Manager

W. Jefferson, Site Vice-President

M. Kiley, Plant General Manager

O. Hanek, Licensing Manager

K. OHare, Performance Improvement

R. Flynn, Performance Improvement

M. Downs, Employee Concerns

M. Mowbray, Engineering

M. Coen, Operations

NRC Personnel

S. Vias, Branch Chief, Division of Reactor Projects, Region II

S. Stewart, Senior Resident Inspector, Turkey Point

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

None