ML033580027

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Slides of Nuclear Engineering Nrc/Fpl Interface Meeting
ML033580027
Person / Time
Site: Saint Lucie, Turkey Point  NextEra Energy icon.png
Issue date: 12/18/2003
From:
Florida Power & Light Co
To:
Office of Nuclear Reactor Regulation
Shared Package
ML033580014 List:
References
Download: ML033580027 (84)


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1 Nuclear Engineering Nuclear Engineering NRC / FPL Interface Meeting NRC / FPL Interface Meeting December 18, 2003 Region II Atlanta, Georgia

2 Agenda O Opening Remarks R. Kundalkar O Principles & Expectations C. Bible O Engineering Performance B. Hughes /J. Cadogan O Corrective Action J. Garcia O Equipment Reliability J. Cadogan O Breaker Reliability Improvements J. Granger O Life Cycle Management D. Tomaszewski O Materials Management R. Gil O Summary

3 Nuclear Engineering O Nuclear Division Focus Areas

- Nuclear Safety

- Equipment Reliability

- Corrective Action

- Performance Management O License Renewal

4 Nuclear Engineering Organization D. RYBCZYK EXECUTIVE SECRETARY B. HUGHES MANAGER ST. LUCIE SITE ENGINEERING A. ZIELONKA MANAGER TURKEY POINT SITE ENGINEERING P. FREEMAN MANAGER SEABROOK SITE ENGINEERING J. MOABA MANAGER MAJOR PROJECT ENGINEERING GROUP (MPEG) S/G, RX Vessel C. VILLARD MANAGER NUCLEAR FUEL D. TOMASZEWSKI MANAGER LIFE CYCLE MANAGEMENT S. HALE MANAGER SBK UPRATE / MSRs J. GARCIA CHIEF NUCLEAR ENGINEER C. BIBLE MANAGER SPECIAL PROJECTS R. S. KUNDALKAR VICE PRESIDENT NUCLEAR ENGINEERING

5 Principles & Expectations C. Bible

6 Principles and Expectations O Developed Principles and Expectations Document O Trained all engineers on document O Tool to be used during daily work activities

- Communicated

- Emphasized in training

- Utilized on a daily basis

7 Principles and Expectations O Key Attributes

- Nuclear safety is highest priority

- Intolerance for failures of critical equipment

- Repeat failures constitute collective failure of the organization

- Rigorous problem solving

- Own problems until they are completed

- Operationally focused

- Tolerance for minor issues can mask safety problems

- Demonstrate professionalism

8 Engineering Performance St. Lucie / Turkey Point Engineering B. Hughes / J. Cadogan

9 WANO Weighted Overall Performance 75 80 85 90 95 100 1998 1999 2000 2001 2002 2003 PSL1 PSL2 Industry Median 75 80 85 90 95 100 1998 1999 2000 2001 2002 2003 PTN 3 PTN 4 Industry Median St. Lucie Turkey Point PERCENTAGE Data Through 9/03

10 Engineering Department Indicators and Goals (1) All green by NRC criteria (2) FPL criteria more stringent (3) Unit 3 EAC significant improvement Green Red Unit 1 - 0.9 Unit 3 -.9 Unit 2 - 1.9 Unit 4 - 0 Unit 1 - 1.9%

Unit 3 -.6%

Unit 2 - 0.3%

Unit 4 -.4%

C.

Safety System Unavailibility - HPSI (1)(2)

<0.75%

>5%

Unit 1 - 0.4%

Unit 2 - 0.4%

Unit 3 -.2%

Unit 4 -.5%

D.

Safety System Unavailibility -AFW (1)(2)

<1.0%

>6%

Unit 1 - 0.5%

Unit 2 - 0.5%

Unit 3 - 0.3%

Unit 4 - 0.5%

E.

Safety System Unavailibility - RHR (1)(2)

<0.75%

>5%

Unit 1 - 0.7%

Unit 2 - 0.6%

Unit 3 - 0.5%

Unit 4 - 0.4%

F.

NRC Violations due to Engineering

<2

>6 2

1 G.

QA Findings

<2

>6 1

3 Unit 1 - 4.12E-5 Unit 3 - 1.60 E-5 Unit 2 - 2.66E-5 Unit 4 -1.0 E-6 I.

OSHA Recordable Injuries 0

2 1

0 Outage 1%<

Outage 87%>

Non-Outage 52%>

Non-Outage 7%<

K.

Reactivity Events Due to Engineering 0 Major

<4 Minor

>5 Major

> 8 Minor 0 Major 0 Minor 0 Major 0 Minor Turkey Point Actuals Nuclear Safety Focus (Data Through 9/30/03)

St. Lucie Actuals Goals Indicators B.

Safety System Unavailibility - EAC (1)(2)(3)

<1.25%

>5%

H.

Wano FRI 5 E-4

>2.0 E-2 J.

ALARA 10% <Budget

>5% Over Budget Unplanned Scrams Per 7000 Hours A.

<1

>6

11 Engineering Department Indicators and Goals Green Red A.

Condition Reports (Late) 0 Late

>5 Late 0

3 (1)(2)

B.

Condition Report Action Items (PMAI's) 0-75

>125 at YE 267 222 C.

Condition Report Action Items (Late) 0 Late

>11 Late 94 (1) 6 (1)(2)

D.

Self Assessments 1 in 6 mos

<2 per year 2

0 E.

System Walkdowns 90%-100% W/D Complete

<70% W/D Complete 90%

100%

F.

Drawing/VTM/TEDB Changes 0-2 Late 10 Late 0

7 (1)

St. Lucie Actuals Goals Indicators Problem Identification and Correction (Data Through 9/30/03)

Turkey Point Actuals (As of 9/30/03)

(1) No safety significant items late.

(2) Zero overdue by year-end.

12 Engineering Department Indicators and Goals Green Red A.

Engineer Initial Training Not Started Within 12 Months of Hire

<1

>6 0

0 ETP - 100%

ETP - 100%

STA - 100%

STA - 100%

C.

Plant Modification Revisions due to ENG Error 0

5 6 (1) 4 (1)

D.

Procurement Engineering Backlog

( >4 Weeks Old)

<2

>11 0

18 (2)

Turkey Point Actuals Quality of Engineering (Data Through 9/30/03)

St. Lucie Actuals Goals Indicators B.

Training Effectiveness

>90%

<70%

(1) Minor changes only, no package revisions.

(2) Increase due to outage items, presently zero.

13 Engineering Department Indicators and Goals Thermal Performance Indicator

>99.70%

<99.5%

Unit 1 - 99.99%

Unit 2 - 99.99%

Unit 3 - 99.8%

Unit 4 - 99.9%

Refueling Outage Duration

<30 Days

>35 Days Unit 2 49.2 Unit 3 28 Unit 1 - 0.05%

Unit 3 - 1.4%

Unit 2 - 2.49%

Unit 4 - 0.5%

91.14%

99.85%

Forced Loss Rate 18 Month Running Average 0% - 1%

>2.0%

Summer Capacity Factor

>99.8%

<98%

14 Corrective Action J. Garcia

15 Corrective Action O Current Situation O Performance Improvement Initiatives

- Programmatic

- Organization

- Strategic Initiatives O Examples O Conclusions

16 Current Situation O Equipment Failure Corrective Action

- Troubleshooting process problems

- Narrowly focused corrective actions

- Limited extent of condition reviews O Problem Identification and Resolution Improvements In Progress

17 Performance Improvement Initiatives O Programmatic Improvements

- Enhanced troubleshooting procedure O Clear problem statement O Identification of failure modes O Validation of causes O Incorporation of results into the corrective action process

18 Performance Improvement Initiatives

19 Performance Improvement Initiatives

20 Performance Improvement Initiatives O Programmatic Improvements (cont.)

- Significant change to corrective action procedure O Additional guidance for repeat events

- Review past identified occurrences

- Determine why previous corrective actions were not effective

- Determine if the previous evaluations were too narrowly focused

21 Performance Improvement Initiatives O Programmatic Improvements (cont.)

- Expanded guidance for generic implications and extent of condition O Develop a comprehensive list of components or systems that could have the same identified condition O Determine other common characteristics (e.g.,

personnel, procedure, material, vendor, age, location, environment, etc.)

O Identify extent of condition

22 Performance Improvement Initiatives O Programmatic Improvements (cont.)

- Expanded guidance for human performance errors O Development of specific error description O Identification of precursors O Identification of causes

- Individual

- Team

- Organizational

23 Performance Improvement Initiatives O Organizational Initiatives

- Established Performance Improvement Departments

- Created division performance improvement coordinator position O Coordinate industry benchmarking O Standardize fleet approach

- Hiring engineers and adjusting staffing levels O Improve focus on equipment reliability O More proactive approach for equipment health

24 Performance Improvement Initiatives O Strategic Initiatives

- Equipment Reliability

- Breaker Reliability

- Life Cycle Management

25 Instrument Air O Design

- Four Compressors installed; 2 Electric Driven, 2 Diesel Driven

- One Compressor required for plant load O Operational Issues

- Fuel system failures

- Water intrusion

- High temperature trips

- Electrical failure

- Cold weather failures

26 Instrument Air O Applied revised troubleshooting procedure

- Formed multi-discipline team

- Obtained vendor input

- Performed historical review of failures O Extensive corrective actions implemented

- Increased engine idle speed

- Modified logic scheme

- Improved preventive maintenance activities

- Incorporated industry operating experience and vendor input

- Improved post modification and maintenance testing

- Monitoring modifications planned

27 Auxiliary Feedwater O Design

- Two trains

- 3 turbine driven pumps O 1 pump required per train O Additional pump aligned to either train

- Common to both Units O Pump failure due to loss of oil pressure

- Pumps realigned to maintain two train operability O Applied revised troubleshooting procedure

- Formed multi-discipline team

- Obtained vendor input

- Performed historical review of failures

28 Auxiliary Feedwater O Root Cause

- Foot valve did not maintain the main oil pump line full

- Excessive clearances in main oil pump O Corrective Action

- Replaced foot valve

- Reworked the main oil pump

- Installed loop seal in oil line

- Improved post modification and maintenance testing

- Applying corrective actions to other pumps

29 15% Feedwater Bypass Valve Stem Separation O

Background

During start up, after refueling, Unit 2 tripped on low steam generator levels 2 A 15% Bypass Valve was open with no flow Event response team formed O

Root Cause Sheared valve stem caused by high cycle fatigue due to worn piston rings Valve PM program implementation O

Corrective Actions Inspected remaining 15% Bypass Valve stem/plug assemblies Significant extent of condition review performed Increase PM overhaul frequency to 36 months Initiated review of valve PM program

30 Conclusions O Equipment Performance Improvements

- Programmatic

- Organizational

- Strategic initiatives O Starting to See Positive Benefits

- Turkey Point 4KV breaker / cubicle interface

- External corrosion

31 Equipment Reliability J. Cadogan

32 Maintenance Rule and Equipment Reliability O Division level process changes to include

- Maintenance Rule process supports Equipment Reliability

- Integration of System Health Reporting and the Maintenance Rule to drive equipment health

- Significant element of Fleet Equipment Reliability Improvement Plan

System Health Reports

System Health Report Icon System Windows (Point & click)

LINKS TO HISTORICAL HEALTH REPORTS

System Health Report Icon System Windows (Point & click)

LINKS TO HISTORICAL HEALTH REPORTS System Engineer

  • Oversight
  • Leadership
  • Prioritization Plant Health Committee

System Health Report Icon System Windows (Point & click)

LINKS TO HISTORICAL HEALTH REPORTS Work Management (Scheduling and Action)

System Engineer

  • Oversight
  • Leadership
  • Prioritization Plant Health Committee

39 EQUIPMENT RELIABILITY IMPROVEMENTS / SIGNIFICANT PLANNED MAINTENANCE Monday, December 15 Activity Dept Scheduled Start Date Completion Date System Sys Health Comments 3P16B 3B Primary Water makeup pump PMTs MM EL/OP 12/15/03 12/15/03 020 Y A(2)

A G(1)

WTYP (1 )

PMT run @ 07:00 3A EDG Air Compressor Monthly/Quarterly PMs MM 12/15/03 12/16/03 022 W A(2)

Clearance hang @ 04:00 Clr Rel/Test run: @10:00 on 12/16 Alarm Point 26 - Replace UV/IR detectors EM 12/15/03 12/17/03 091 WTYP (7 )

PMAI for CR 02-1815 Circ Lube Water Piping Replacement - MSP-03-047 MM 12/15/03 12/19/03 010 W A(2)

C G(1)

Prep work - Install 12/19 U4 H2 Panel - Instr On-Line 18MO Calibration - Carryover IC 12/09/03 12/18/03 090 DDD 12/14/03 WTYP (7 )

E-16D Inverter/Battery Rm HVAC Bi-monthly PM EL 12/15/03 12/16/03 025 W A(2)

DDD 12/29/03 3P26A/B RHR room B sump work Continuing work MS 12/01/03 12/17/03 050 R A(1)

B W

WTYP (3)

U3/4 Safeguards Relay Rack Train B (STP0607 & STP1079)

OP 12/15/03 12/15/03 063 G A(2)

Start 11:00 U3/4 CTMT Isolation Rack QR51 (STP0609 & STP1081)

OP 12/15/03 12/15/03 063 G A(2)

Start 15:00 3A CTMT Spray Pump Semi-Annual PM MM 12/15/03 12/15/03 068 G A(2)

Clearance hang @ 15:00 Clearance release @ 23:00 133.8 Hrs Remaining P235D Diesel Service Water Pump Controller/Battery PMs EL 12/15/03 12/15/03 012 W A(2)

Clearance hang @ 16:00 Clearance release @ 22:00 96.1 Hrs Remaining

40 Maintenance Rule and Equipment Reliability O Developing organizational roles and responsibilities training to support process O Investigating Maintenance Rule software improvements to provide better integration O Maintenance Rule Program Quarterly Health Report and Indicators O Detailed a(1) action plans

- Reviewed by Expert Panel

- Approved by Plant Health Committee

41 Breaker Reliability Improvements J. Granger

42 Breaker Reliability Improvements O Fleet wide evaluation performed to identify improvement action plan O Reasons for breaker reliability improvement

- 14 functional failures in past 3 years

- Some repeat failures

- 4.16 KV systems in Maintenance Rule a(1) status

- Notice of Enforcement Discretion at St. Lucie

43 3/4 On 11/22/03, St. Lucie Unit 2 required alternate line-up to the 1B startup transformer. Breaker in location 2-20701 relocated to 2-20703, failed to close on first two attempts.

3/4 On 11/25/03, breaker relocated back to 2-20701 and failed to close.

3/4 Outdoor Non-Safety switchgear (2A-4 and 2B-4) flexible floor can cause breaker to trip-free after rack-in due to spurious operation of floor tripper mechanism. Troubleshooting confirmed this as root cause.

Breaker Reliability Improvements

44 Breaker Reliability Improvements St. Lucie 2B-4 Non-Safety Switchgear

45 St. Lucie Westinghouse DHP breaker St. Lucie 4.16 KV switchgear floor tripper Breaker Reliability Improvements

46 O St. Lucie DHP breakers interface with switchgear cubicle

- DHP floor trippers only installed at St. Lucie.

- Flexible floor primary concern with outdoor non-safety switchgear

- No failures of safety related breakers due to floor tripper

- Outdoor switchgear breakers perform no safety function and do not operate in any design basis event Breaker Reliability Improvements

47 Breaker Reliability Improvements O St. Lucie DHP breakers interface with switchgear cubicle (cont.)

- Floor trippers can cause failure to close after breaker is removed and then racked-in

- Breakers do not trip once successfully closed

- Switchgear floor stiffening being evaluated O Potential 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO for bus outage

48 O

Turkey Point 4.16 KV breaker failures due to switchgear interface 4B SI pump failed to close in March 2000 due to Positive Interlock Roller (PIR) adjustment problem on GE Magne-Blast Circuit Breaker Incorrect PIR adjustment caused 3A CCW pump breaker failure to close in August 2002 Accelerated breaker overhauls increased breaker swaps O

Increased potential for interface problems due to unique breaker fit-up requirements Detailed corrective actions completed to prevent re-occurrence:

O Inspections and required adjustments made on switchgear cubicle interface points O Operations and Maintenance procedures revised to address critical checks and tolerances O New procedure with detailed checks and testing for breaker swaps O Training completed for Electrical Maintenance and Engineering personnel.

Further enhancements to standardize switchgear cubicles being performed during bus outages (2 of 4 buses complete)

Four breaker overhauls remaining in 2004 O

Future breaker swaps minimized Breaker Reliability Improvements

49 PIR must be centered in notch of cam plate with 1/16 clearance 52/IS switch striker clearance must be less than 1/32 to ensure actuated (racked-in)

Breaker Reliability Improvements GE Magne-Blast 4.16 KV Breakers PIR design

50 Failures by Voltage Class 8

2 3

1 4 KV 6.9 KV 480 V MCC Failures by Mechanism 11 3

Mech Elec Failures by Manufacturer 2

3 1

5 3

W-DHP GE-Magne AB B HK AB B K-line MCC Breaker Reliability Improvements Functional Failures in Past 3 Years

51 Design Application Maintenance Breaker to swgr cubicle interface Complex mechanical design Number of breaker cycles and rack in/out operations Mechanical forces Improper PM tasks and intervals Inadequate post PM and O/H testing Knowledge of breaker design and operation Lack of PM task acceptance criteria Poor Quality Overhauls Outside vendor Breaker failures and degradation Components Environment Manufacturing defect Infant mortality Age Degradation Mechanical latches and interlock devices Adjustments and lubrication Obsolescence Breaker Reliability Improvements

52 Materials Process Lack of adequate spare breakers Breaker parts not available Acceptance criteria for condition assessment not well defined Breaker swap for PMs and OHs Scheduling and coordination of PMs and OHs Tracking of bkr location and maintenance history Breaker PMs and OHs are complex and require high skill Breaker Program Deficiencies Human Coordination required between all departments No clear program owner and accountability Inadequate Training Insufficient resources Inadequate Procedures Breaker Reliability Improvements

53 Breaker Reliability Improvement Plan Verify procedures address critical interface requirements (complete for GE breakers)

Perform switchgear inspections and maintenance during next outage (3B and 4A complete)

Evaluate basis for PM and overhaul intervals Validate corrective actions implemented for CR 02-1544 Turkey Point Verify procedures address critical interface requirements Validate adequacy of switchgear inspections, scope and interval Verify interface design for DHP replacement breakers Evaluate basis for PM and overhaul intervals Validate corrective actions implemented for CR 01-2681 Switchgear cubicle inspection and maintenance Standardize switchgear cubicles Evaluate increasing PM and overhaul intervals Root cause of functional failures at Turkey Point and St. Lucie Reduce potential for misalignment during breaker install Identify and correct interface deficiencies Verify procedures address critical interface requirements Reduce frequency of breaker rack-in/out St.

Lucie Strategy Fleet Actions Basis - Effect Verify procedures address critical interface requirements Validate adequacy of switchgear inspections, scope and interval Note: No problem currently observed at Seabrook Sea-brook Site Actions Counter-Measure Site Counter-measures: Breaker to Switchgear Interface

54 O Action Plan Summary

- Reliability O Planning St.Lucie 4 KV and 6.9 KV breaker replacement starting in April 2004

- Stiffening outdoor switchgear floor O Complete Turkey Point breaker replacement on C-bus in 2004 O Replace Turkey Point 4 KV GE Magne-Blast breakers prior to next overhaul cycle O Identify and correct switchgear cubicle interface deficiencies O Increase monitoring, inspection, testing of overhauled breakers O Evaluate using Seabrook to perform fleet overhauls of ABB breakers Breaker Reliability Improvements

55 Breaker Reliability Improvements O Action Plan Summary (cont.)

- Program O Assign breaker program owner and team O Consistent program documentation and procedures O Controlled process for tracking breaker status and history

56 O St. Lucie DHP Breaker Replacement Improvements

- Simple operating mechanism with less failure modes

- Less maintenance required at longer intervals O 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> duration, 6 year intervals

- Reduced maintenance minimizes breaker swapping

- Weight of new breakers significantly less O Reduces switchgear interface problems

- Less mechanical forces required to operate breaker O Reduced vibration Breaker Reliability Improvements

57 Breaker Reliability Improvements SF6 Replacement Breaker DHP Breaker

58 Life Cycle Management D. Tomaszewski

59 Life Cycle Management O Program to Effectively Cope with Aging Systems and Components in FPL Nuclear Plants O Near Term Focus is Instrumentation and Control Systems O Replacements of Selected I&C Systems are in process O Improved Data Gathering Capability and Human Factors

60 Life Cycle Management O Standard Platform Approach to System Replacements

- Distributed Control System, Foxboro I/A

- Safety Related Platform, Triconex O Design Includes Redundancy and Diversity

61 Life Cycle Management O St. Lucie Digital Data Processing System Replacement

- Unit 2, In-service since May 2003

- Unit 1, Installation to be completed March 2004 O Three Functions plus Sequence of Events

62 O

Incore Detectors/Linear Heat Rate Monitoring Life Cycle Management

63 O

Incore Detectors/Linear Heat Rate Monitoring Life Cycle Management

64 Life Cycle Management O

Calorimetric Power Determination

65 Life Cycle Management O

Control Element Assembly Pulse Count Position Indication

66 Life Cycle Management O Planned Projects Scheduled Through 2005

- Qualified Safety Parameter Display Systems

- Emergency Response Data Acquisition and Display Systems

- Feedwater and Low Power Feedwater Control Systems

- Turkey Point Auxiliary Feedwater Controls

- Turkey Point Steam Dump Controls

67 Life Cycle Management O St. Lucie Project Plans PROJECT 2003 2004 2005 2006 PSL1 Digital Data Processing System Feedwater Controls Qualified Safety Parameter Display System Emergency Response Data Acquisition and Display Turbine Controls Condensate and Cooling Water Control and Instr.

Turbine Building/ Heater Drains Reactor Protection System PSL 2 Digital Data Processing System Feedwater Controls Qualified Safety Parameter Display System Emergency Response Data Acquisition and Display Turbine Controls Condensate and Cooling Water Control and Instr.

Turbine Building/ Heater Drains Reactor Protection System

68 Life Cycle Management O Turkey Point Project Plans PROJECT 2003 2004 2005 2006 PTN 3 ERDADS Qualified Safety Parameter Display System Auxiliary Feedwater Controls Feedwater Controls and Steam Dump to Atm.

Steam Dump to Condensor Reactor Protection System Reactor Coolant, Chemical and Volume Control Pneumatics/Turbine Building PTN 4 ERDADS Qualified Safety Parameter Display System Auxiliary Feedwater Controls Feedwater Controls and Steam Dump to Atm.

Steam Dump to Condensor

69 Life Cycle Management O Additional Planned LCM Projects PROJECT PSL1 Motor Generator Set Controls Instrument Inverter Replacement Auxiliary Feedwater Governor PSL 2 Acoustic Feedwater Flow Measurement Upgrade Motor Generator Set Controls

70 Materials Management R. Gil

71 Materials Management O Alloy 600 and other materials issues continue to be a focus area O Bottom Mounted Instrumentation (Turkey Point)

- Bare metal visual completed at Turkey Point Unit 4

- No leaks or boric acid accumulation identified

- Timing for UT inspections being evaluated Turkey Point Unit 4 BMI Visual

72 Materials Management O Small Bore Instrument Nozzles (St. Lucie)

- Hot leg and pressurizer bare metal visuals performed each outage

- Replacing on prioritized basis

- Unit 2 hot leg and pressurizer nozzles already replaced O Pressurizer Heater Sleeves (St. Lucie)

- Unit 1 mitigated with nickel plating

- Visual inspections per industry recommendations

- Long term resolution being evaluated

73 Materials Management O Butt Welds (St. Lucie)

- Augmenting ISI with bare metal visuals

- Mitigation options being evaluated O Reactor Head Penetrations

- All four heads volumetrically inspected

- No leaks or wastage identified

- St. Lucie Unit 2 repaired two cracked penetrations

- Plans in place to replace all four heads

74 Materials Management O Steam Generators (St. Lucie Unit 2)

- 361 Tubes Plugged in 01

- 530 Tubes Plugged in 03

- Increased Cracking at Eggcrates (257/482)

- No Ding Indications in 03

- Replacement Planned in 2007 Based on Projections

75 Boric Acid Corrosion Control O Nuclear Policy and station procedures in place O Significant effort applied to identification and resolution of boric acid conditions

- Focused walkdowns

- Emphasis on cleaning and repairs

- Significant effort during recent outages O Successful INPO assessment at St. Lucie

- Strength in cross-functional effort

- Minor enhancements recommended

76 Conclusions O Alloy 600 issues need -

proactive inspections and mitigation / repair actions O FPL is very active In industry groups addressing these issues O All Alloy 600 locations at FPL plants have been identified and plans are in place, or actively being developed, to provide long-term resolution

i FPUFPLE Nuclear Engineering i:

Principles and Expectations

1.

1:

I t April 25,2003 i:

i:

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i i

TAME OF CON-

~

INTRDDUGTKIN..........................................

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SAFETY.............

11.

KNOWLEWE AN EOFTHEDESIGNUID LICENSING BASIS i

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111.

IMOLEMNCE FOR FAELLIRES OFCRITICAL EQUIPMENT.....................

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MRRECnVE ACTIONS...

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a d a h r M I METHODS.........................................................................................

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VI.

RIGORWS APPLICATION OF ENGINEERING PROCEDURES AND IX.

RESULTS ORIENTATION.....................................................................

7

x.

DEMONSTRATE PROFESS~ONWSM...................................................

a XI.

SIILMWOWLEDOEABLE WORKFORCE...........................................

9 XII.

NUCLEAR CODE OF ETHICS...............................................................

10

Introduction The purpose of Nuclear Engineering at FPUFPLE is to ensure safe and reliaMe Bquipment pertormance and io Control and mahtain the configurations of each nuclear facili in accordance with the design and licensing requirements. To achieve a high ievei of perfomanad in thess u @ ~ s, an environment that promotes excellence and professionalism is required. To esiabiish this atmosphere, we must all share and embrace a number of fundamental principles for eng'neering W W.

1.

safety Nuclear SaIety is our highest prior@, and is our most fundamentd mission. Engineering must be ttm *technical a7nscience" of the station.

Engineering must ensure mat:

- The plant is maintained end operated within the design and We do not tolerate failures of equipment that am critical or licensing bases at 811 times. Design margins must be understmi, controlled and properly maintained important to p!ant safety and reliability. We provide in-depth failure analyses and implement actkms sutfiient to prevent any repeat failures.

Equipment prohiems EW pmmptly evaiuateted and resolved.

RPeurrant muiment DmMemS are not tolerated. We Characteristics of excellence in engineering include:

  • Nuclear safely is never cornpromi&

Personnel satetv is never commmised A safely 'wsci;us work Rnvirunment (SCWE) ciearly exlab

  • H i

Muip.ment reliability In1okmic.e of remat ewo:nent fbilures

&%&,xi

&A sup&

Cpwatintn pdonties.

. we do not iive w~tn suspected or ktwwn prohlem condnions wmi tnc, plant. bu: aggressbIely porsue SoiLliOns.

- operationally iaCused Maintenance of plant configuration Continued performance improvement Organlzafonai effectiveness Timely idenliilcation and resdution of technical equipment probiems and engineering issues

- Seek out and share lesshls learned Maintenance of enginwring programs m Accountable, engaged and motivated WOrMoice we are ingaged vanh industry paem through benchmafig and Operathg Expsrifmce.

management and across any organizational boundaries to ensure that actions required to ensure ssfe aperation are We pursue safety issues by takig them to any lewl of

,.*an

~~

~

mtiwl ttwkng is e&&.

. ws take en 8ggW;sive poiranive e.ppfoacn lo the !sentifwtiw, lgpnrting ana resolut,oP 01 concern3 ielaied to ndclas: WfeW or gualiry. This app:Mch wili bc lahm Whoul fear nt reiwissl, nara%smenl or inlim~datlon.

1 hwe are no occeWhle organi'at~onnl i m ~ n l 0 l l l r when it mmes 10 safety. Y O J ~ supervisor. tnsrngw and V.P. are t h w to nssist m removiq imwdmenrs.

Tt)e ~ J W S ~

of mis document is ID esIHb!iSh lh9 Lndamumtll principles.

am rxuec~~tims tor technirai and sv;,neenng wmx at FPuFPL~.

These sIai:oards 00 not repla= any existing procedures 01 rDqblremenlc*; ralhw they ~unstllule a msic ae! of aniludHs and nehaviorn expected lioni everyone in Enyineenng. These standards are Io be cummunicated, nmptmmd in tra'ninp ana practiced on a daily bas13 Wlth,n E.nyineering and wit!, inle,facng O,yan,ra[~on.s. 'lney consliiuLe lhe fundanionla1 conlen and a!mnsphere tor our work

- ?

It.

Knowledge end Malntensnce of the Design and Licensing Basls Engineerlng is the repository of, and cmtcdian for, the piant design basis. This is one of our most fundamental principles. Engineering must:

Understand the design basi8 of the piant and its equipment.

Undwstmd, wntroi and properly maintain design and safety margins.

Communicate mat understanding to others, such as Operations and Maintemnce.

. Maintain and preserve the design basis documentation.

Be continually alee for situations mere ttm plant could be operated, maintained or modified inwnsistent with design basis. including equipment specifications and component limitatihis.

must dedicate owselves to ankmpatiq nnd eliimnatiiig smh cnalonges. Failures of crifi2al quipi!iont wl.i not be tolcratod ' W a t lai!ures miisIti1te a collective failure of tne Engmaeny orgaiiizntion anu are cnecceptable. In the even1 there are failures 01 cdticsl RquIpment. Engnserinp niuaf ensure that CorMiVe actions are SiMiciently robust to prm:ude repent failures Pmgrams: uno oryanuationa ber.ov;ors are to be focused on the przveNon of critical equipment failures. ': hi8 anitude must be inStiUad In tnn :htnKvrg md aniiudm uf Enginrering ana constltuto our 'mna ser RS we apprmch ow lobs. Our equipment rrhabllii program WNi orrly ~c successfJI if fi is oasad on this principle.

In addaim to crilical eqdment. we must bave R low fole:ance *or degraoatian of our nonc:itial equipment and systems. Deqad?stion of any system e3(oo!ishes a pwr working atmosphere.

System pntormnnce monitoring mlist be ;nlemiess ir oraei to idnntlty end correct eqCpnwnt issues before hey s k t giant operaton.

(.

WRh liense renewal, we expect our plants to operate for many years.

we future engineers are not hsmwred by incomplete or poor qualily infonation. We are the trustees forme future engineers. To properly discharge this trust, we must RnSUre the caiculations, drawing, deSign We nottokmte large baoklogss.

bogs down in yeserdaY" basis documents, vendor manuals and other key infonnatim are accurate, upto-datR, useable, and easily accessible.

b r leaks, arCUnds* degded sum equipment and backlogs can mask more seriws safety problems and compromise our sense of ownership and pride.

problams and prevents us from working M tcdafs and tomorrow's chaliengas.

our design &is dwumentatbn cuntMt Such that Only Engineering can fulfill thi6 obligation. There will always be forms We condu* Our with Ifie Of 'rgenCY and pressures at work mat can dislracf us whv we must consider maintenance of the design basis as a most this.

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merits. We win not allow low value work to distract us from resoiution of problems with critical equipment.

fuidamental principle.

N. CormcWe AcUonr

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essential that all Engineering personnel understand that engineers own prublems untii they are completed. It is not acceptable to relinquish ownership of wrrsctive actions. Corrective atiins are to be timely, thorough and provide resoiution of the identified caus@s. Identified caus0s Shall provide sufficient insights into organizational.s!wtifails so that we can root out and correct these issues whioh are usually deep-seated and fundamental. A robust corrective action and sdi-assessment program is essetdiai to conthmi improvement

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V.

Ripows Approach to Problem Solvlng

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P Our approach to problem solving wiK be rigomus and fwmai. The foiiowingl attributes must be adhered to:

a Clear assignments for solving the problem.

Thorough fact finding and data gathering. Personally inspect the situation.

Consunation with ail parties Mth background or past experience in the issue. A muiii-disciplined team may be needed.

CDMUhation with industry operating expsrience, viewing it broadly to determine Station impact.

Intoleriinze for repeat problems.

Draw c~nclusions based on facts and evidence.

- Review results with management and supervision.

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There is always pressure 18 short CUI a disciplined approach to problem solving; particularly during outages or dher time sensitive situations. It is one of our principles that time sensaive situations are when its most important to apply rigomus problem solving.

VI.

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Rigorous Appllcstion of Engineering Pmcauums and MethC45 In addition to those engineering principlss derived from owf formal education, there are several others that are fundamental to our wrk

- 5 Technical work is always done formally in writing. Ai! problem soiving or issue evaluation becDmes part of the station's history and must be avdlabla for future consideration.

All technical decisions impacting piant Sefety and reliability will bt? verified and approved at the appropriate levels. The more urgent, or risk signmcsnt the situation, the greater the need to ensure thorough reviews and approvals.

. In making technical evaluations, the limitations and merbintiss of the atate or information must be wnsidemd and dearh/ documented.

Assumptions made in performing technical evaluetions shall be made explicit so they cnn be independently assessed.

Assumptions made In performing 8 technicai evRIuatm sham be verified by direct lnspeCtwn or t& to t b exlent practical.

When evaluating equipment eondtlons, a personal inspection shall always be performed.

All mmunicatioms of technical information must be clear and formally transmined lnfomal transmittel of technissl infonnaNotion has been the cause of considerable mistmlune in the nuclear industry over the years.

VH.

Strict Compllance with V ~ ~ ~ R I C R I Pmgrsmr and Promiurea Our technicxi programs and procedures are the repository of w r accumu1ated technical knowfedge and of the engineering methods and pmcedures that history has shown to be most effective. Like all Engineering program documents, our programs wntain feelurea that experience has demonstrated to be necessary. Thaw featurns re rot slvfays obvious and the reasons for them onen b m e O

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with time. Experience has shown, howaver. that we proceed at our peril whenever we do not comply with es8blish& engimerinp and plant programs and pmesses. Accordingly. ail Eng~neeing Programs will be rigarously foliowed. As we gain experience, we must also update and improve car program documents 50 that future engineers can avoid w r mistakes.

I WI. Ownership for Engineering Progrems Program ownership consists o! having 6 single point accountabilay for th8 success of a program. Although there may be a numher of individuals involved with prcgram implementation. there can be only one owner. The following is expecled of program ownen:

I. Fuily understands the technical and regulatory basis for the program. Keeps up with industry and regulatoiy deveicpmem so that FPL employs industry best pr8ctkx.s.

2. Ensures mat program.impiementing documents ar@ clear, up-to-date, and wmpiianl with reguiatary requirements and industry best practices.
3. Ensures that interfaces wdth other programs and pmcedures are clear aw3 functional.
4. Ensures that Roles and ResponsibliAies are properly defined and are baing effectively implemented in the Beid.
5. Ensures that suitable training and qualilicatkm prvpms are available for lmpiemsnling individuals.
6. Uses outside peers and INPO assistance.
7. Maintains awareness of industry Operating Experience. and uses QE lo improve program effectivRness.
8. Ensutes that corrective actms are popedy evalualed, implemented, and closed. Places major empasis an th6 effectiveness o! the corrective actim.
9. Ensures management is perkdicaliy apprised of problems with the program and its implementation. It is recognized that some isstme aflecling program impiamentalion are beyond the cuntroi of the program owner; however. visible and persistant highlighting of implementation problems is expected.

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E. Results orlentation The above pnncrpies vffl help us to produc@ high quaiitytechntcal work and mwre mect soIu11ons to problems. They will not, hawever.

produce resuits. Nl engineers must be dedicated to producing results and to baing effedve. Being technically wnect is not enough.

Too often we can be tempted to take a limited view 01 w r engineering jobs. For example:

. We dont just produce designs; we resolve problems and improve plant performance.

We don? just report problems on CRS; wo ensure pmbiems are corrected pennanemly.

We dont simply execute our Engineering Programs; we improve the plant through their implementation.

We dont use organizational obstacles as excuses; we overcome them.

We don? lust do system walk&vms; we manage the health of our systems and Ellsure problems are found and conected before they adversely aHect the plant.

It is essential that each engineer grasp the significance of this principle and embrace it iut~y.

X.

Demonstrat6 P m W o n s l i m Professionalism is a pmitive anribille focused on doing the best job possible..

We are pmfessioneis who take fun responsibility for the quaif and productivity of our work. and have the same expectations of all members of the team.

We demonstrate personal ieademhtp, responsibility, and acwuntaMliIy.

Wa balance the value of teamwurk and synergy w4th ownership and personal responsibility.

- We pstively confront tmm members who ar6 not performing.

We rslate proactively and positively within the plant organization and with exiernai arganizatbns.

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We are committed to impmving quality. reducing costs. and seeking ways to continuously improve.

We are sdf-critical. admit and leam from our mistake§, and RE open to aching lor self-impmvement.

. We build trust in others. and are trustworthy.

We have high personal integrity and ethics.

. we continually improve our own technical competence and interpersonal skills n We learn from the experience of others, and stay current with We take time to proudly celebrate our success@s and the SUCC~SSBS of others.

We understand that our signature on enginewing documents represents adherence to these principles.

the industly; we accept critical input from outsiders.

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. We wdl abide by the FPL Nuclear Division 6ode Of thcs.

XI.

Skilled. Knowledgeable Workforce Training is used as B strategic lod to provide highly skilied and knowledgeable personnel.

WR are expected to be fuUy trainad and cetiiied lo perform our asqimclrt Insks FPL Nuclear Division Code of Ethics k members at FPb's nuclear organlaition, committed to excelknee and protessbrsallsm in the cwrsluet of our actlivitles.

we de hereby endorse the followlng protessional code:

+ We will at all times, regard the safety of the public and our fellow employees as our own personal and moral responsibility.

+ We will efiiciently and effectively utilize our resources to promote cost eflective electrkal power generatkm.

t We will conduct our nuclear activities in a manner which demonsirales commitment and integrity, arw which establishes and maintains a professional environment mnducive to excellencs in performance.

+ We wilt ensure that key personnel. managers, an0 olficers, responsible lor supporting nuclear piant operation. possess the neGBssaT)' knowledge and experience to understand nuclesr ptant sctivities, events and problems.

"__./I h a %(,I. maintam our q~a?kalions.

which doct?mont 0l.r

!eChncaI know8edp.

. we bear responr.bility rot our owc edwaiion. 'rnls itiwdes hoep:ng up mth engineering and piant procedLwo:prucnss ChaPgOB.

we w.ii apply 11-8 systnmatc atwoacli (0 1w'c.W.

. As a learning orgawarioc. we apply nman peiiotmance tonis sucri 83 sell-checking. quftsticPing alBud0 IOV8V). w r cnncking. and t(iree.way CommJn cslion as a means Of continuws improvemonl.

+ We wI 1 avoid com;lacency and establish an environment of cortinJou8 mprovemem. We will mmurage ana a m p t mrstruclive cmaism.

+ We will mmnlit ourselves tu ens:iring that plan1 systoms and colriwnents are reliable and propbdy maintllined We mil protn?

t+e envi~orime~t.

We coirmil to an agpessive and 1 me y approach lo lhe resoI;Itior 01 prob,ems. purwiny tna objec$ve r;f idenhty ng niid mr:e2ti~ mol causes lo improve perlonnance.

+ We will adopt and maintain policies and pra'tces ma: convey an attitwle 01 t ~ u s t. encowaye c#nmu:iicatioti. and foster teamwork among 811 groups that opernto. maintain ana support the i~uclew plants.

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FPUFPLE Engineering Pllndples and Expectations

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