IR 05000266/2008001

EOC Annual Assessment Letter (Report 05000266-08-001, 05000301-08-001)

ML080600317
Person / Time
Site:	Point Beach
Issue date:	03/03/2008
From:	Pederson C Division Reactor Projects III
To:	Mccarthy J Florida Power & Light Energy Point Beach
References
IR-08-001
Download: ML080600317 (8)

Text

rch 3, 2008

SUBJECT:

ANNUAL ASSESSMENT LETTER - POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 (05000266/2008001; 05000301/2008001)

Dear Mr. McCarthy:

On February 12, 2008, the NRC staff completed its performance review of Point Beach Nuclear Plant, Units 1 and 2. Our technical staff reviewed performance indicators (PIs) for the most recent quarter and inspection results for the period from January 1 through December 31, 2007.

The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility.

This performance review and enclosed inspection plan do not include security information. A separate letter designated and marked as "Official Use Only - Security Related Information" will include the Security Cornerstone review and resultant inspection plan.

Overall, Point Beach Nuclear Plant, Units 1 and 2, operated in a manner that preserved public health and safety, and fully met all cornerstone objectives. Plant performance for the most recent quarter, as well as for the first three quarters of the assessment cycle, was within the Licensee Response column of the NRCs Action Matrix, based on all inspection findings being classified as having very low safety significance (Green) and all PIs indicating performance at a level requiring no additional NRC oversight (Green). Therefore, we plan to conduct reactor oversight process (ROP) baseline inspections at your facility. Although plant performance was within the Licensee Response column, the significance of increased water in the oil of the outboard bearing of the Unit 2 turbine-driven auxiliary feedwater pump turbine is still under review as part of the Significance Determination Process, which, when finalized, may change our assessment of your plants safety performance.

The staff has continued to identify a substantive cross-cutting issue in the area of human performance. This issue is a continuation of the substantive cross-cutting issue first opened in our Mid-Cycle Assessment letter dated August 31, 2007. At the time of the mid-cycle assessment, you had four findings that were associated with the aspect of not maintaining long-term plant safety (H.2(a)) and six findings that were associated with the aspect of not having complete, accurate, and up-to-date design documentation, procedures, and work packages (H.2(c)). A review of the findings for the current 12-month assessment period indicates that you have not received any additional findings with the aspect of not maintaining long-term plant safety (H.2(a)), for a total in the assessment period of one. Our review also shows that you did have an additional four findings with the same aspect of not having complete, accurate, and up-to-date design documentation, procedures, and work packages (H.2(c)), for a total in the assessment period of nine. Although you have made progress at reducing the number of findings with an associated aspect of not maintaining long-term plant safety (H.2(a)), additional attention to the aspect of not having complete, accurate, and up-to-date design documentation, procedures, and work packages (H.2(c)) is needed. The NRC has a concern with your scope of efforts and progress in addressing the cross-cutting area performance deficiencies and has concluded that the substantive cross-cutting issue in human performance will remain open. It will remain open until the number of findings with the same cross-cutting aspect is reduced or when the NRC gains confidence in the performance of your corrective action program to evaluate and correct problems. Because this end-of-cycle assessment is the second consecutive assessment letter identifying a substantive cross-cutting issue in the human performance area, we request that you discuss your actions to address this issue at the 2007 end-of-cycle meeting. This meeting will be scheduled at a later date.

In the first quarter of 2006, the NRC closed a longstanding substantive cross-cutting issue in the problem identification and resolution (PI&R) area because you had demonstrated sustainable improvement. In 2005 and 2006, you continued to demonstrate sustainability in this area; however, since January 2007, we have noted a declining trend in the PI&R area. For this assessment period, we identified four findings in the PI&R area with the same aspect of appropriate and timely corrective actions (P.1(d)). Three of the four findings were identified in the last two quarters of the assessment period. Also, we have noted that your January 2007 Self-Assessment and your July 2007 Independent Assessment of the corrective action program both identified that continued improvement was needed with apparent cause evaluation quality and timeliness, and with corrective action timeliness. The number of findings exceeded the threshold of three, specified in NRC Inspection Manual Chapter (IMC) 0305, Operating Reactor Assessment Program, dated November 27, 2007, and involved the Initiating Events and Mitigating Systems Cornerstones. Because of the decline in the area of PI&R, the NRC has a concern with your scope of efforts and progress in addressing the cross-cutting area performance deficiencies and has concluded that a substantive cross-cutting issue exists in this area. This substantive cross-cutting issue will remain open until the number of findings with the same cross-cutting aspect is reduced or when the NRC gains confidence in the performance of your corrective action program to evaluate and correct problems.

Additionally, in this assessment period, we evaluated whether a substantive cross-cutting issue existed in the area of safety-conscious work environment (SCWE) using the three criteria in IMC 0305. We determined that the first criterion was met, based on a Confirmatory Order issued on January 3, 2007, (ADAMS Accession Number ML063630336). This Order was issued for an apparent violation identified by the NRC in August 2006 (ADAMS Accession Number ML070100138) that involved a reactor operator who was discriminated against. We also determined that the impact on SCWE was not isolated, thus meeting the second criterion.

However, based on inspections conducted during this assessment period, we do not have a concern with your scope of efforts or progress in addressing the actions contained in the Confirmatory Order. Therefore, the final criterion was not met and we have determined that a substantive cross-cutting issue does not exist in SCWE. We will continue to assess your implementation of the Confirmatory Order actions in the 2008 assessment period.

On January 29, 2007, the staff issued a Severity Level III Notice of Violation (ADAMS Accession Number ML070290711) for the failure in 1983 to update the Final Safety Analysis Report with the results of an evaluation of a hypothetical drop of the reactor vessel head onto the vessel. This failure was identified by NRC inspectors in 2005. No civil penalty was issued with this Notice of Violation because the statute of limitations had been exceeded. This violation was closed in the fourth quarter 2007 integrated inspection report.

The enclosed inspection plan details the inspections, including baseline and other infrequently conducted inspections, less those related to security, scheduled through June 30, 2009. The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature. The inspections in the last nine months of the inspection plan are tentative and may be revised at the mid-cycle review.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System(PARS) component of NRCs document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Michael Kunowski at (630) 829-9618 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

Cynthia D. Pederson, Director Division of Reactor Projects Docket Nos. 50-266; 50-301 License Nos. DPR-24; DPR-27 Enclosure: Point Beach Inspection/Activity Plan DISTRIBUTION:

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