L-2008-059, Supplement to Response to Apparent Violation EA-07-138

Supplement to Response to Apparent Violation EA-07-138

ML080790103
Person / Time
Site:	Turkey Point
Issue date:	03/14/2008
From:	Stall J Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-07-138, L-2008-059
Download: ML080790103 (2)

Text

Florida Power & Light Company, 700 Universe Boulevard, P.O. Box 14000, Juno Beach, FL 33408-0420 FPL 10 CFR 50.4 L-2008-059 March 14, 2008 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Re: Florida Power and Light Company Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Supplement to Response to Apparent Violation EA-07-138

References:

1) NRC Letter to Florida Power & Light Company dated October 30, 2007

2) Florida Power & Light Company Letter L-2008-038 dated February 28, 2008

3) Florida Power & Light Company Letter L-2008-024 dated February 28, 2008 The NRC Region II Office issued a letter (Reference 1) to Florida Power and Light Company (FPL), the licensee for the Turkey Point Nuclear Plant, Units 3 and 4, alleging that there have been several instances where security officers had been inattentive between 2004 and 2006.

FPL's written response to the apparent violation was provided in Reference 2. The purpose of this letter is to supplement the Reference 2 FPL response.

As previously stated in the Reference 2 response, FPL cannot substantiate whether all of the incidents alleged in the apparent violation occurred due to the limited information provided by the NRC in the letter to FPL. FPL reserves the right to revise its position on the apparent violation based on any future opportunity to review Office of Investigations Report No. 2-2006-013.

While FPL cannot determine whether a violation of NRC requirements occurred as alleged in Reference 1, FPL recognizes that problems existed in the Turkey Point Security organization during the period 2004-early 2006. These problems manifested themselves in security officers tampering with security equipment and failures to properly report improper behaviors. FPL performed a root cause evaluation and initiated an extensive number of corrective actions intended to strengthen the overall Security program at Turkey Point. The causes, key corrective actions and results achieved are discussed in FPL's Reply to the Notice of Violation and Proposed Imposition of Civil Penalty in the Reference 3 FPL letter. The Turkey Point Security program improvements establish expectations and standards for security personnel performance.

In FPL's Reference 2 response, FPL offered information via reference to the FPL response to Bulletin 2007-01, "Security Officer Attentiveness." The Bulletin response provided NRC with information regarding administrative programs, managerial programs and controls established to an FPL Group company {/,L' . AU [-

Florida Power and Light Company L-2008-059 Response to Apparent Violation EA-07-138 Supplement Page 2 of 2 prevent, identify and correct security personnel inattentiveness and, especially complicity, and failures to implement the behavioral observation program by personnel among licensee security personnel including security contractors and subcontractors.

The security force personnel who are alleged to have been inattentive and/or complicit to inattentiveness are no longer in the employ of FPL's security contractor at Turkey Point. Two of the six individuals have been denied unescorted access to any FPL facility. The plant access files for the remaining four individuals contain administrative data that would initiate a thorough review if future access is sought at any FPL or FPL Energy nuclear facility. This administrative data is referred to in the Plant Access Data System.

If there are any questions regarding this letter, please contact Mr. Paul Infanger, Turkey Point Licensing Manager, at 305-246-6632.

Very truly yours, J. A. Stall "Oj Senior Vice Pre dent, Nuclear and Chief Nuclear fficer cc: Regio al Administrator, USNRC, Region II Senior Resident Inspector, USNRC, Turkey Point