ML17342A801
| ML17342A801 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 07/17/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17342A800 | List: |
| References | |
| 50-250-87-19, 50-251-87-19, NUDOCS 8707290208 | |
| Download: ML17342A801 (63) | |
See also: IR 05000250/1987019
Text
JUL I 7 tgof
ENCLOSURE
BOARD REPORT
U.
S.
NUCLEAR REGULATORY COMiMISSION
RFGION II
SYSTEMATIC ASSESSMiFHT
OF LICEHSEE
PERFORMANCE
IHSPECTION
REPORT
HUMiBER
50-250/87-19
50-251/87-19
FLORIDA PO'i",ER AND LIGHT COMPANY
TURKEY POINT UNITS 3 AND 4
MAY 1,
1986
THROUGH MAY 31,
1987
90~08 670717
ADOCN 05000250
I .
Introduc.i on
The
Systemat'.c
Assessment
of Licensee
Performance
(SALP) program is
an
integrated
NRC staff
e fort to collect available observations
and data
on
a periodic basis
and to-evaluate
licensee
performance
based
upon this
informa ion.
The
program
is
supplemental
to
normal
regulatory
processes
used
to determine
compliance- with
NRC rules
and
regulations.
The
SALP program is intended
to
be sufficiently diagnostic
to provide
a
rational
basis
for allocating
NRC
resources
and
to provide
meaningful
guidance
to licensee
management
to promote quality and
safety of plant
construction
and operation.
An
NRC
SALP Board,
composed
of the staff
members
listed below,
met
on
July 10,
1987, to'eview the collection of performance
observations
and
data
to assess
licensee
performance
in accordance
with guidance
in
NRC
Manual
Ch'apter
0516,
"Systematic
Assessment
of Licensee
Performance."
A
summary of the guidance
and'evaluation criteria is provided in Section II
of this report.
This report is
the
SALP Board's
assessment
of the
licensee's
safety
performance
at Turkey Point Units
3
and
4 for the
period
May 1,
1986,
through
May 31,
1987.
SALP Board for Turkey Point Units
3 and 4:
L. A. Reyes,
(Chairman) Director, Division of Reactor Projects
(DRP), RII
A.
F. Gibson, Director, Division of Reactor Safety
(DRS), RII
J.
P. Stohr, Director, Division of Radiation Safety
and
Safeguards
(DRSS), RII
D.
M. Verrelli, Chief, Reactor Projects
Branch
1,
DRP, RII
L.
S.
Rubenstein,
Director, Project Directorate II-2, Division of
Reactor Projects,
D.
G. McDonald, Project
Manager,
Project Directorate II-2, Division of
Reactor Projects,
D.
R. Brewer, Senior Resident
Inspector,
Turkey Point,
DRP, RII
Attendees
at
SALP Board Meeting:
M. L. Ernst,
Deputy Regional Administrator, RII
B. A. Wilson, Chief, Reactor Projects
Section
1C (RP1C),
DRP, RII
K. D. Landis, Chief, Technical
Support Staff (TSS),
DRP, RII
H. 0. Christensen,
Project Engineer,
RP1C,
DRP, RII
M. A. Scott, Project Engineer,
RP1C,
DRP, RII
K.
Van Dyne, Resident
Inspector,
Turkey Point,
DRP, RII
T.
C. MacArthur, Radiation Specialist,
TSS,
DRP, RII
J. Zeiler, Reactor
Engineer,
TSS,
DRP, RII
,
M.
M. Troskoski,
Regional
Coordinator - RII, .EDO
II.
Cl iteria
Licensee
performance
is assessed
in selected
functional areas
depending
on
whether
the facility has
been -in the
construction,
preoperational,
or
operating
phase
during
the
SALP review period.
Each
functional
area
represents
an area which is normally significant to nuclear safety
and the
environment
and
which is
a
normal
programmatic
area.
Some
functional
areas
may
no
be
assessed
because
of li tie or
no licensee
ac ivity or
lack
of meaningful
NRC observations.
Special
areas
may
be
added
to
highlight significant observations.
One or more of the following evaluation criteria was
used to 'assess
each
functional area;
however,
the
SALP Board is not limited to these criteria
.and others
may have
been
used
where appropriate.
C.
D.
F
G.
Management
involvement in assuring quality
Approach
to
the
resolution
of technical
issues
from
a
safety
standpoint
Responsiveness
to
t<RC initiatives
Enforcement history
Operational
and construction
events (including response
to, analysis
of, and corrective actions for)
St=->fing (including management)
Training and qualification effectiveness
Based
upon
the
SALP Board
assessment,
each
functional
area
evaluated
is
'classified
into one of three
performance
categories.
The definitions of
these
performance
categories
are:
Cateoorv
1:
Reduced
NRC attention
may
be
appropriate.
Licensee
management
attention
and
involvement
are
aggressive
and
oriented
toward nuclear
safe y; licensee
resources
are
ample
and effectively
used
such
that
a
high
level
of
performance
with respect
to
operational
safety or construction quality is being achieved.
~Cate or
2:
NRC attention
should
be
maintained
at
normal
levels.
Licensee
management
attention
and
involvement
are evident
and
are
concerned
with nuclear
safety;
licensee
resources
are
adequate
and
are
reasonably
effective
such
that satisfactory
performance
with
respect
to
operational
safety
or construction
quality is
being
achieved.
~Cate
or
3:
Both
NRC
and
licensee
attention
should
be
increased.
Licensee
management
attention
or
involvement
is
acceptable
and
considers
nuclear
safety,
but
weaknesses
are
evident;
licensee
resources
appear
to
be strained
or not effectively used
such that
minimally satisfactory
performance with respect
to operational
safety
or construction quality is being achieved.
The functional
are
being
evaluated
may
have
some a.tributes
that would
place
the
evaluation
in Category
1,
and others
that would place it in
either Catego".y
2 o.
3.
The final rating for each
functional
area
is
a
composite of the attributes
tempered with the judgement of
NRC management
as to the significance of individual items.
The
SALP Board
may also include
an appraisal
of the performance
trend of a
functioral
area.
This performance
trend will only be
used
when both
a
definite trend
os
performance within the evaluation
period is discernible
and
the
Board believes
that continuation of the trend
may result in
a
change
of performance
level.
The trend, if used,
is defined as:
~lm rovin
Licensee
perrormo-nce
was determined
to
be
improving near the
close of the assessment
period.
Da-lininc:
Licans
e performance
was
de:ermined
to
be declining
near
the
close o':he
assessmant
period.
III. Summary'f Results
A.
Overall Facility Evaluation
The licensee
has
made
some
noteworthy
improvements
in the last year
particularly
plant
operations,
maintenance,
and quality
programs
and administrative
controls affecting quality which all
had
been
identified
as
weaknesses
each of the last
two
SALP. periods.
These
improvements
may have
been at the expense
of management
attention
in
other
areas
such
as security,
where
performance
declined;
training
and
qualification
effectiveness
which
remained
a
weakness;
and
engineering
support,
which
was
included
for the first
time
as
a
functional
area
due
to
identified
deficiencies.
Emergency
preparedness
has
cont',nued
as
a major strength
area.
Since
the
licensee's
Performance
Enhancement
Program
(PEP)
was
implemented
by
a Confirmatory Order
in July 1984,
many significant
events
and
enhancements
have
occurred.
A Safety
System
Functional
Inspection
(SSFI)
was
conducted
in
1985 which resulted
in numerous
violations
and
a
substantial
Civil Penalty.
This resulted
in the
original
PEP
being
expanded
and
then
superseded
by
a
Confirmatory
Order
in
August 1986.
The
licensee
has
implemented
numerous
improvement
programs
and
expended
tremendous
resources
in their
commitment to safe
and reliable operation of the Turkey Point units.
The results of many of these
programs
have
been
evident during this
period.
These
results
have
included
tangible
benefits
in
facilities
such
as
a
new training building,
a
new administration
building,
and
a simulator
and
a maintenance
building that are nearing.
completion.
The
Phase
II Assessment
Program
has
also
provided
positive
results
such
as'hose
described
in Section IV.l,. of this
report.
In
October
1986,
the
licensee
submitted
their
proposed
Technical
Specifications
(TS)
to the,NRC for review
and approval.
These modified standard
TS represent
a significant
improvement
over
JUL I 7
l987
the old custom
TS.
Increased
staffing levels, training and enhanced
procedures
are
all
evidence
of
the
licensee's
commitment,
to
subs.an
ially upgrade
prev ously identified
problem
areas.
There
remains,
however,
some
evidence
of the
need for further management
responsiveness
in certain
areas.
'xamples
of this
include
the
imprudent decision to
s art
up Unit 4 in September
1986 with a
known
leak
on the vessel
head.
This
was
exacerbated
by the decision
to
restart
he unit in October following an inspection of the area which
showed
a substantial
spread of boric acid residues.
In addition,
the
NRC
Augmented
Inspection
Team
(AIT)
in
March
1987 initially
encountered
a management
attitude that appeared
more oriented
toward
a unit restart
rather
than
a comprehensive
analysis of the problem.
It should
be
noted
that
the
licensee's
subsequent
response
was
comprehensive
and
the corrective
actions
were
reviewed prior to the
HRC
concur ring in restart.
The
special
testing
of the
Emergency
Diesel
Generator
(EDG)
load
sequencers
was
another
instance
of
management
involvement
and
support that were initially perceived
to
be lacking but once
the
commitment to resolve
the
issue
was
made,
personnel
performed
in
a
comprehensive
and
technically
competent
manner.
Management
effectiveness
was also
lacking in the level of
awareness
of the
obligatio'ns
associated
with the
containment
and
surveillance
functions of international
safeguards.
The
HRC notes
that
management
attention
to solving the
problems at
Turkey Point is evident in a number of areas
and that this attitude
must continue
to
be successfully
conveyed to the plant personnel
at
all levels.
B.
The performance
categories
for the current
and previous
SALP period
in each functional
area
are
as follows:
Functional
Area
November
1, 1984-
May 1, 1986
7
Plant Operations
Radiological Controls
Maintenance
Surveillance
Fire Protection
Emergency
Preparedness
Security
and Safeguards
Outages
Quality Programs
and Administrative
Controls Affecting Quality
Licensing Activities
Training and Qualification
Effectiveness
Engineering
Support
H/R
Not Rated
"
N/R
2
2
2
2
N/R
1
3
.2
2
2
3
IV.
Performance
Analysis
A.
Plan.
Opera
ions
1.
Analysi s
During -this assessment
period,
inspections
were conducted
by the
residen
and regional
inspec
ion staff.
At the beginning of the
evaluation
period
Unit 3
was
in
commercial
operation
while
Unit 4
remained
shutdown
until
September
1986 while emergency
diesel
generator
loading
modifi'cations
were
being
performed.
Unit 3 continued
operating until early March 1987,
when it was
shutdown
for
refueling
and
maintenance.
Unit 4,
following
restart
in September,
operated
until March
1987 at which time
boric acid deposits
on the reactor
vessel
head
from the leaking
conoseal
were
discovered.
Both units
remained
shutdown
the
remainder of the
SALP period.
Since
the category of Operations
has received
three consecutive
3 ratings,
additional
HRC attention
was
devoted
to thi s
area.
A special
team inspection
was conducted
in February
1987
to specifically assess
plant operations
in addition to routine
and enhanced
',nspections
by the Resident
Inspector staff.
" Operations
has
been
identified
in
the
past
as
having
programmatic
deficiencies
in
a
number
of areas.
Among these
have
been
inadequate
system configuration control,
failure to
follow procedures,
excessive
on-the-spot
changes
to procedures,
inadequate
control
room
and
plant
labeling,
and
missed
surveillance- testing.
The previous
SALP report specifically singled out the licensee's
tendency
for
the
Operations
Department
to
operate
around
maintenance
problems.
Seven
examples
were cited, four of which
resulted
in violations.
During this
SALP period,
there
was
little indication
of this
tendency
and,
in
fact,
plant
management
has
stressed
ihe
concept
of Operations
as
the
"customer"
for
the
support
groups
such
as
Maintenance,
Engineering,
and the Technical
Departments.
The
outage
caused
by the leaking boric acid
from the conoseal
could be construed
to
be "operating
around
a maintenance
problem",
but
was
more
logically attributed
to Engineering
Support
(See
Section IV.L)
and
imprudent
management
decisions.
These
decisions
involved
the startup
of Unit'
in September
1986 with
a
known Reactor
Coolant
System
(.RCS)
leak
on the reactor
vessel
head
and the
restart of the Unit in October after
a short unrelated
outage.
With
regard
to
the
above
identified deficiencies,
both
the
Residents
and
the
team inspection
found that programmatically,
the
operators
have
been
sensitized
to
follow procedures
carefully.
Although nine of the twelve violations that occurred
in
.he Opera.ions
area
were attributed to failure to follow or
properly implement procedures,
the violations were
due p.imarily
to
either
personnel
error
or
incomplete
under standing
of
procedural
intent.
A comprehensive,
independent
verification
program exists
which
has
helped
reduce
personnel
errors.
The
policy of verbatim compliance with procedural
requirements
is
strongly supported
by the operations staff and plant management.
Improvements
in plant
labeling
are
discUssed
later
in this
section.
. One event that occurred at the end of the
SALP period tended to
refute
the
above
comments
with regard to procedural
adherence
and configuration control.
From May 28 until June
3,
1987, with
both units
in
mode
5, nitrogen intrusion into the Boric Acid
system
through
a failed boric acid transfer
pump seal,
caused
'problems with regard to operators
establishing
and maintaining
a
boric acid, flow path to the vessel
in accordance
with approved
procedures.
A special
inspection
was
conducted
in June
1987
and
although
the results
are
preliminary,
there
are
several
violations which are being considered
for escalated
enforcement.
In general,
management
involvement with operations
activities
has
increased
over the past year.
Shift briefings,
performed
by
a licensed
Senior
Reactor
Operator
(SRO),
are
performed after
each
shift
assumes
their duties.
These
briefings
provide
information relative to goals
and objectives for the
subsequent
shift.
As
a result,
general
awareness
of site activities is
enhanced
and complex evolutions are
more smoothly performed.
In December
1986,
the licensee
placed
a third
SRO on each shift
as
assistant
to
the
Plant
. Supervisor-Nuclear
(PSN).
As
a
result,
tours
of the facility by supervisory
personnel
have
increased.
This
has
resulted
in
more
prompt
deficiency
identification, resolu-ior. of problems,
and
increased
liaison
between
operators
and supervisor s.
The additional shift manning
has further reduced
the administrative
requirements
placed
on
the
which
was
begun
when administrative
technicians
were
assigned
to each shift during the last
SALP evaluation period.
The staffing of the Operations
Department,
is adequate
to meet
routine
needs.
The staffing level
has
remained
approximately
constant
at
125 persons.
However,
operator
overtime
has
been
excessive,and
was
found to
exceed
administrative
guidelines.
This
resulted
in
the
issuance
of
a
level
IV violation
as
discussed
in
Section
IV.I
of this
report.
The
increased
overtime workload resulted primarily from poor pass
rates
on
NRC
requalification
examinations
and site activities
accompanying
the 'dual unit outage
which occurred
between
March and June
1987.
JUL 17
195
The
licensee
has
since
resumed
five shift operation
with
a
licensed
shift'complement
of the
PSM (SRO). Assistant
PSH (SRO),
Nuclea
L"atch
Engineer
(SRO),
and
three
Reac.or
Con rol
Operators
(RO,
minimum).
Although additional
and
SROs are
presently
in license preparation
classes,
FPL does
not expect to
realize their design shift complement for another
two years.
The Operations-Maintenance
Coordinator,
a licensed
SRO,
and his
staff
improved
communications
between
the
two departments
and
for the most part, facilitated the operational
readiness
of the
plant.
However,
a proposed violation (e) listed in Section
IV.C
of this report
was partially due to poor communication
between
Operations
and
Maintenance
when
the
core
alterations
were
performed
without
establishing
containment
integrity.
Communications within the Operations
department
was
not evident
during
the
February
1987
team
inspection.
Communications
appeared
casual
and
on
a first name basis,
with operators
rarely
using
any
form of verbal
repeat
feedback.
Operators
indicated
to
HRC
inspectors
that
there
were
concerns
with in-plant
communications
including
radios
and
the
page
system.
Both
communications
systems
are being upgraded.
The violation in the
Emergency
Preparedness
analysis
section
documents
four examples
of disc-.epancies
associated
with the public address
system,
each
of which adversely
affected site communications.
Con rol
room
demeanor
remains
satisfactory
overall
but varies
between shifts.
The relatively small dual unit control
room is
susceptible
to crowding.
During
day shift, the control
room
becomes
busy
and
noisy.
The
requirement
for individuals to
obtain
permission
prior to entering
the control
area
is not
generally enforced.
However, supervisory
personnel
do minimize
visits by nonessential
personnel
during important evolutions
and
during shift turnover.
The clearance
tagging
center
was
moved
outside
the control
room during the latter half of the Unit 3
refueling'utage.
This
change
was
beneficial
in
reducing
personnel
traffic
flow
and
congestion.
The
licensee
is
considering
a permanent
relocation of the tagging center.
Unit 3 was in operation for approximately ten of the
13 months
during
this
period
and
experienced
eight
manual
or
automatic
unplanned
Three of the trips were
due
to personnel
error in the conduct of periodic tests,
while three
others
were
due to problems with the turbine
governor control
oil
system.
The trip rate for Unit 3 is approximately
equal
to the industry
average
for older plants.
Unit 4 was only in
operation
for about
six
months
and
sustained
five manual
or
automatic
unplanned trips.
Four trips were caused
by equipment
malfunction, while the fifth was
due to
a procedural
error.
The
rate
of trips
for Unit 4
was
slightly
above
the
industry
average.
JUL
1 7
]987
The quality of plant procedures
continues
to improve as
more are
rewrit en
and
reissued
through
the
Procedures
Upgrade
Program
(PUP}.
The
PUP
has
been especially effective in improving the
con ent
and
form of approximately eight
hundred
procedures
and
has
reduced,
though not eliminated,
the potential for personnel
error
and
misinterpretation.
The
PUP
continues
to
be well
received
by the plant staff
and is widely recognized
for its
con ribution
to
reliable
plant
operations.
During
this
assessment
period
the
PUP
has
completed
130
surveillance
procedures
in
support
of the
Technical
Specification
upgrade
program.
Since
its
inception
the
PUP
has
responded
to
approximately
5,000
requests
for real
time
support
in the
improvement
of
existing
procedures.
The
large
volume
of
on-the-spot-changes
(OTSCs)
which existed
during the previous
period
has
been
reduced
to
a
manageable
level.
As
procedure quality has
improved there
has
been
less
need for the
operations staff to implement
OTSCs.
Additionally, supervisory
personnel
have
monitored
spot
changes
and
approved
only those
meeting
approved criteria.
An eouipment labeling
and valve tagging
program continues
to be
expanded.
Virtually all safety related
systems
have
had their
alum',num
tags
replaced
with larger,
more legible,
fiberglass,
color coded
tags.
Equipment stenciling effectively identifies
major components,
systems,
rooms
and buildings.
Separation
of
Unit 3 and
4 equipment
is emphasized
by color-coding, with tan
representing
common
equipment.
Control
room
panels
have
been
relabeled
with
clearly
legible
color-coded
power
supply
identification tags.
The labeling
and tagging
program
appears
to have resulted
in tangible benefits
in that licensee
trended
data
shows,
that, except for the
May 2,
1986 Unit 3 Trip,
no
other
personnel
errors
or reactor trips attributed
to
wrong
unit/wrong train events
over this
SALP period.
The
use oi brightly colored
information,
clearance
and
work
order tags allows operators
to more easily assess
the status of
equipment.
Even
minor
deficiencies
in
control
room
instrumentation
receive
work order
deficiency
tags
alerting
operators
to the discrepancy.
'
large
number of the deficiency
tags exist at
any
one time.
The minor deficiencies
may exist
for extended
periods
because
of
more
pressing
maintenance
requirements
on the
Instrument
and Control staff.
Coordinated
efforts between
the Operations
and Maintenance
Departments
have
maintained
the
amount of control
room instrumentation
which is
actually out of service
to acceptable
levels of magnitude
and
duration.
Instrumentation
which is subject to repeated
failures
is discussed
in the maintenance
analysis
section.
Management
has
continued
to
emphasize
the
requirement
for
housekeeping.
Primary
plant
housekeeping
has
continued
the
improving
trend
documented
during
the
previous
assessment
JUL 1P
]987
period.
Cleanliness
remains fully satisfactory
due, primarily,
to partial
cleanup
as
the repair effort progresses,
minimizing
.the
need
for large-scale,
post
maintenance
cleanup.
House-
keeping
prac.ices
are
better
implemented
in
plant
areas
containing safety related
equipment rather than balance
of plant
sys
ems.
As d'.scussed
in the Maintenance
analysis
section,
the
material
condition of the
secondary
systems
is not
as
good
as
prima y systems.
Some
severe
pump and valve leaks
have existed
for
extended
periods
in the
secondary
plant.
Additionally,
unused
hoses,
burned
out lightbulbs,
small
leaks
and
standing
water
are
not
uncommon
secondary
plant
housekeeping
deficiencies.
Activities associated
with the
Performance
Enhancement
Program
(PEP) were closely monitored.
The
PEP,
which was
confirmed
by
an
NRC Order dated July 13,
1984,
is intended
to address
NRC
concerns,
improve regulatory compliance
and 'implement regulatory
corrective action,
and is scheduled
to continue into 1988.
The
PEP
has
resulted
in improvements
in the following areas:
organizational
structure
and personnel,
guality Assurance
(gA)
program,
upgrade of Technical Specifications
(TS), establishment
of safety engineering
groups, allocation of additional
resources
and
upgrade
of facilities,
operation
enhancement,
procedures
upgrade,
improvement of the plant configuration control program,
and
training
and
improvements
in maintenance
management.
A
Program for Improved Operation
(PIO) was added
to the
PEP
by
a
Confirmation
of
Concurrence
letter
on
October
11,
1984,
and
includes
reviewing the Final Safety Analysis
Report
(FSAR) to
assure
plant
operation
within
the
safety
analysis,
identification
and
correction
of
surveillance
program
deficiencies,
and increased
management
awareness
and overview of
operations.
In
9eneral,
the
implementation
of the
PEP/PIO
and
Phase II
Assessment
has
shown
successes
in that
adequate
corporate
attention
and resources
have
been
focused
on identified problem
areas.
Adherence
to
established
schedules
and
regional
briefings
have
been
satisfactory
in
most
areas.
Upper
management's
commitment to excellence
is apparent
not only in
the
Turkey
Point
PEP
but
also
in
other
corporate
quality
improvement
programs.
. Licensee
management
has
continued
to
implement
and to support
PEP'nd
has
expanded
the
program to
include areas
not originally addressed.
The
contribution
of
the
Operations
Group to,overall
plant
operations
has
improved
considerably
within the
past
year.
Initial implementation of the various
upgrade
programs
has
made
noticeable
improvements
to control
room and plant operations
and
the
interface
with other -plant groups,
including Maintenance,
Training,
and Engineering.
10
JUL I V
ISSUE
Twelve violations were identified.
Nine of the twelve were due
to failure
o
follow or properly
implement
procedures
as
discussed
ea. lier.
Violations
e
(example, 1), i,
and
1
are
repetitive violations i ndica .i ng that corrective
action
may not
always
be effective at correcting
the root cause of the problem.
Twelve violations were identified:
c
~
Severity
Level
IV violation for three
examples of failure
to follow procedures
(reactor protection
system 'testing,
emergency diesel
generator
[EDG] valve lineup,
EOG startup
operation).
(86-25)
Severity
Level
IV violation for failure to establish
an
adequate
procedure for the control of several
EDG valves.
(86-25)
Severity
Level
IV violation
(one
example)
in which the
Plant Supervisor
Nuclear misinterpreted
an administrative
procedural
requirement
concerning
plant
work
order
priorities.
(86-25)
Sever i ty
Level
IV vio'. ation
for
not
impl ementing
an
off-normal
procedure
for
a failed
steam
1 ine
pressure
transmitter.
(Unit 3 only, 86-33)
e.
Severity
Level
IV violation for two examples of failure to
follow procedures
(a clearance
procedure
not
implemented,
an
administrative
procedure
not
properly
implemented).
(86-33)
CI
~
Severity
Level
IV violation for two examples of failure to
follow procedures
(steam
generator
level
was
not properly
controlled,
the auxiliary feedwater nitrogen
system
was not
properly aligned).
(86-39)
Severity
Level
IV violation for three
examples of failure
to
follow
procedures
control,
auxiliary
valves
not
aligned,
the
third
example
is
addressed
in the maintenance
section)
and
one
example of a
fai lure
to
establish
a
necessary
auxiliary
procedure.
(86-45)
Severity
Level
IV violation for failure to follow secondary
source
handling procedures.
(Unit 3 only, 87-14)
.
Severity
Level IV violation for failure to follow clearance
tag procedures.
(87-22)
SUL I 7
1997
j.
Severity
Level
V violation for failure to follow procedures,
for containment
spray
system
valve lineup
and
independent
ver"ica.ior,.
(Unit 3 only, 86-31)
Severity
Level
V violation for failure
to
comply with
Technical Specification 3.3.3,
in that
on
two occasions
failed containment
isolation valves
were
not isolated
as
required.
(Unit 4 only, 86-45)
1.
Severity
Level
V violation for fai lure to follow clearance
tag procedures.
(Unit 3 only, 87-06)
2.
Conclusion
Category:
2
Trend:
3.
Board Recommendations
Additional plant
management
effort needs
to
be applied to the
areas
of inadequate
staffing
and
excessive
overtime,
secondary
plant
physical
condit o." control
room congestion,
and
plant
communications.
No change
to inspection
program is recommended.
B.
Radiological Controls
1.
Analysi s
During this assessment
resident
and regional
radiological controls,
ments
using the
Region
the plant chemistry.
period,
inspections
were conducted
by the
inspection
staffs.
Inspections
included
radwaste
controls,
confirmatory measure-
II Mobile Laboratory,
and inspections
of
The
licensee's
health
physics
(HP)
staffing
level
compared
favorably with other utilities
having
a facility of similar
size.
An
adequate
number
of
American
Nuclear
Standards
Institute
(ANSI)
qualified
licensee
technicians
were
available
to
support
routine
operations.
During
outage
operations,
additional
contract
HP technicians
were
used
to
supplement
the permanent
HP staff.
One
strength
noted
in
the
health
.physics
program
was
the
stability of the health
physics staff.
The
low turnover
rate
has resulted
in a more experienced
group of individuals and has
provided
the
time necessary
to
implement
a continuing training
program for the staff.
On the other
hand,
the contributors
to
chemistry
program deficiencies
were staff turnover
and lack of
training.
A new Chemistry
Supervisor
was appointed
at the
end
of the evaluation period.
12
During the
SALP period the licensee
began
upgrading their health
physics
procedures
to
add
more formality to
the
conduct
of.
rou.ine operations.
The
improvement of procedures
along with
the experience
of the health physics staff should contribute.to
improved implementation of the health physics
program.
There
was
also
a
lack
of
formality
in
the
posting
of
instructions
to workers in that
hand written memoranda,
signs,
instructions
and documents
were routinely posted
throughout
the
site to provide guidance
to plant personnel.
It was noted that
in
some
cases,
the
posted
guidance
did not reflect
the
most
current practice.
Management
support
and
involvement
in
matters
related
to
radiation protection
was
adequate.
Health
physics
management
was
involved sufficiently early in outage preparation
to permit
adequate
planning.
The health
physics
supervisor
received
the
support of other plant managers
in implementing
the radiation
protection
program.
Resolution of technical
issues
by the health physics staff was
a
weakness
early
in the
period.
Since
the
reassignment
of
a
technical
staff
member
from corporate
headquarte.
s,
technical
evaluations
have
improved.
However, there are,
on
a continuing
basis,
many techn'ical
evaluations
necessary,
at times more
than
the current professional
staff can complete in a timely manner.
Those technical
evaluations
which
have
been
completed
are
good
as demonstrated
by the licensee's
response
to
NRC initiatives in
the conduct of an alpha radiation
survey program.
The licensee
developed this program in response
to
a violation.
The licensee
has continued to improve the alpha
program
as
more data
has
been
gathered.
The radiological effluent program
was conducted
in an acceptable
manner.
Effluent
releases
for
the
past
th~ee
years
are
summarized
in the
Supporting
Data
and
Summaries
Section
V.K.
The
licensee's
calculated
offsite
doses
for
1986
from
radioactive
effluents
were
1.24
E-02
mrem
gamma
to the whole
body and 9. 13 E-02 mrad beta.
These
values
place
the licensee
well within the limi.ts of 40
CFR 190. 10, e.g.,
25 mrem to the
whole
body
over
any
12 consecutive
months.
There
were
no
significant trends during the
SALP review period.
The
licensee
is currently
working with
a
liquid
radwaste
processing
contractor to improve the efficiency of the portable
demineralizer
system to further reduce
the quantity of effluent.
Some progress
has
been
made with informal leak reduction efforts
to reduce
the quantity of liquid waste to be processed.
'13
JUL I P
]g87
One
unplanned
release
resulted
from
contamination
of
the
demineralized
water
sys.em
by spen.
fuel
pool water.
The root
cause
Gf this
contamination
appeared
to
be
a
check
valve
failure, which allowed contaminated
water in
o the demineralized
water system
and which eventually
led to unmonitored releases
to
unrestricted
areas.
After-the-fact analyses
showed
the releases
had
been within limits.
The
licensee
expended
considerable
resources
to .upgrade
components
in
the
secondary
water
cycle affect,ing
chemistry
control.
As
a result, corrosion within the secondary
system
was
reduced.'s
of the
end of the,SALP
review period,
the plant
improvement
program
had not been
extended
to facilities used
by
the
chemistry staff, i.e.,
sampling
panels
and
laboratories,
although
improvements
within these
areas
are
scheduled
to
be
performed within a few years.
Audits performed
by the corporate
staff of the health
physics
program
have
improved during the
SALP period.
The .site internal
audit
organization
conducted
audits
of the
health
physics
program
using
personnel
that
were
experienced
in the
health
physics
area.
Appropriate
corrective
actions
were
taken
and
documen.ed.
During
.the
evaluation
period,
the
licensee's
radiation
work
permit
and
respiratory
protection
programs
were
found to
be
satisfactory.
Control
of
contamination
and
radioactive
materials within the facility was generally
adequate.
At the
beginning of the
assessment
period in 'Nay
1986,
the
licensee
maintained
41;> of the total
area
regarded
as
the
Radiation
Con rol Area
(RCA) under contaminaton controls.
The
RCA did not
include
the
containments.
in April
1987,
the
area
under
contamination controls
had
been
reduced to approximately 38:.'f
the total
RCA.
During
1986,
the
licensee's
cumulative
exposure
was
445
person-rem
per unit as
measured
by thermoluminescent
dosimeter
(TLD).
Tnis
value
is
above
the
national
average
of
397
person-rem
unit observed
at similar
PWR facilities.
However,
the
number
of person-rem
above
the
national
average
is
not
considered
to
be significant.
The licensee
has
established
a
500 person-rem
goal
per unit as
measured
by pocket ion chamber
(PIC) for 1987.
The total exposure
per unit through
June
1987,
as
measured
by
PIC,
was
660 .person-rem.
This total
included
exposure
received
during
extended
outages
necessitated
by
a
problem
and
Raychem
splice repair work.
The boric
acid repairs
accounted for approximately
170 person-rem
and the
Raychem
splice
work accounted
for approximately
139 person-rem.
It should
be
noted
that
the
licensee
expended
considerable
resources
to support the installation of temporary shielding in
order to further reduce
the
exposure
of workers
performing the
splice repair work.
14
SUL 1P
Ig87
During
1986,
the
licensee
made
25
solid
radioactive
waste
shipments
totalling
11420
cubic
feet
(fthm)
(5710
fthm
per
reactor)
and
con.ai ning
89 curies
of ac.ivity.
This
is
signi,icantly below
he
1986
na ional average
for
PWR facilities
of 9,400
fthm per reactor.
Through April 31,
1987,
the licensee
made
7 solid radioactive
waste
shipments totalling 1194 fi~ (597
ft
per
reactor)
and
containing
approximately
78 curies
of
activity.
Four violations were identified:
a.
Severity
Level
IV violation for failure
to calibrate
air-line pressure
on the breathing air distribution
system
as
required
by
Appendix
A,
Footnote
h
(86-36).
b.
Severity
Level
IV violation f'r failure to conduct
an alpha
radiation
survey
program
and evaluate
the
extent
of the
alpha
hazard
present
as
required
by
(86-36).
c.
Severity Level
IV violation for failure to ensure that each
procedure
and administrative
policy
was
reviewed
by the
Plant Nuclear Safety
Committee
(PNSC) prior to implementa-
tion as required
by Technical Specification 6.8.2 (86-36).
d.
Severity
Level
V violation for failure to post notices of
violation and licensee
responses
to Notices of Violation as
required
by 10 CFR 19. 11 (87-15).
2.
Conclusion
Category:
2
3.
Board Recommendations
No change
in the
NRC's inspection
resources
are
recommended.
C.
Maintenance
l.
Analysis
The major maintenance
deficiencies
noted during the last
evaluation
included
inadequate
training,
failure
to follow
procedures,
high work order backlog,
and
a tendency to postpone
necessary
maintenance
forcing operations
to "operate
around"
problems.
JUL l 7
1987
Durino the evaluation period,
inspec
ions were performed
by the
residen
and regional
s.affs.
Supervisory
involvement
in the
opera
ion cf the maintenance
program
has significantly improved
and is apparen
during daily work activities.
Foremen
and line
supervisors
have
increased
direct
monitoring of maintenance
-asks
resul:ing
in generally
effective
work order
implemen-
tation.
Maintenance
work packages
have consistently
documented
the root cause
of problems,
alleviating
a significant concern
documented
in
the
previous
assessment
period.
Numerous
NRC
inspections
performed
during
this
assessment-
period
have
verified that work packages
are
complete
and work instructions
are adequate.
Maintenance
procedures
are utilized at the work
location
and are appropriate for the work activity.
In February
1987,
selected
review of the licensee's
Plant Work
Order
(PWO) backlog resulted
in the following concerns:
The required review of the computerized
PWO tracking system
does
not appear
to be thorough,
and was not being performed
on
a timely basis.
The
requested
as~istance,
(i.e.
Request
for Technical
Assistance
(RTAs),
Requ st
for
Engineering
Assist
nce
(REAs), Requisition
and Purchasing
Authorization (RPAs)
and
parts
request)
did not receive
the
same priority as
the
requesting
PWO.
A
new
engineering
work
request
system
was
implemented
in
September
1986 to prevent the loss of REAs.
This should aid in
assuring
more timely responses.
However, the
REAs that were
in
the engineering
review process
prior to the
implementation
of
the
new system did not appear
subject to the
improved con rois.
The licensee
has
a
PWO backlog target criterion of having
no
more
than
50 percent
of the corrective
maintenance
PWOs older
than
three
months
which is
based
on
an
INPO guideline.
In
February
1987,
the
Mechanical
and Electrical
Departments
were
very close
to
the
target
indicator
but
the
IEC
Department
appeared
to be about
10 percent
above
the target.
In
the
past,
the
I8C
PWO
backlog
was fairly large,
with
approximately
900
PWOs.
In response
to an
NRC expressed
concern
with this
backlog,
the
licensee
hired eighteen
temporary
I@C
technicians
to aid the permanent
IKC staff in reducing
the
PWO
backlog.
With their
help the
licensee
reduced
the backlog to
approximately
400
PWOs,
at
which
time
the
temporary
ISC
technicians
were
terminated.
A review of the
backlog
trend
curves for all three
maintenance
departments
indicated that the
16
JUL 2r lgs7
P'l'0 backlog
had been increasing.
In addition to the loss of the
temporary
technicians,
other
apparent
reasons
for
this
increasing
trend are:
The
number
of
has
increased
because
the
plant
operating s-aff has experienced
improved response
from the
Maintenance
Department
on correcting identified problems.
As
a result more
PMOs were being generated.
The Maintenance
Department
was
using
improved maintenance
procedures,
which require
more time to perform.
The licensee
has committed to stay within the
INPO guidelines
in
the
number
of outstanding
maintenance
work orders,
and it
appears
that these guidelines
are being met at the present
time.
The total
PYO prioritization
system
as currently
impleme'nted
does
noi
appear
to
adequately
define
appropriate
work
prioritization.
There
appeared
to
be
a conflict between
the
original priorities as assigned
by the author,
the priority as
revised
by the work planners,
and the priority as revised
by the
Operations/Maintenance
Coordinator
and the "hot items list."
The direct, supervision of maintenance
personnel
was noted to be
increased
during this
SALP period
when
compared with the past.
Supervisors
are
now available
to aid in the completion of the
work activity,
and
to
interface
with the
Operations
staff
regarding
work in progress.
Since
there
are
more maintenance
personnel
than
in the past, all overtime is usually
done
on
a
voluntary
basis.
Excessive
overtime
appeared
to
have
contributed
to maintenance
errors
and plant events
in the past.
In general
the philosophy of the Maintenance
Department
appears
to
have
changed greatly over the past
two years.
There is more
attention
paid to the
assembly
of adequate
work packages,
the
specific
needs oi mechanics
arid technicians,
and to maintenance
training.
Management
support
of maintenance.
was readily apparent
in the
areas
of training
and facilities.
Maintenance
training
was
reinstated
in
early
1986
after
accomplishing
the
accreditation
effort with
a
new
performance
based
Continuing
Maintenance
.Training
Program.
'Providing
on-going
performance-based
training
to
maintenance
personnel
is
a
definite
improvement,
and
should
result
in
a
noticeable
performance
improvement.
The
new maintenance
building, which is
under construction,
should further improve the training
program
by providing mechanical,
I&C, and electrical
laboratories
for
hands-on training.
17
JUL
2 c
>gy
The
licensee's
recently
implemented
Preventive
and Predictive
Mainterance
Program
has aided in .he generation
of approximately
40 percen.
more maintenance
procedures
than there
were
18 months
ago.
This is primarily due to the licensee's
effort to provide
an apploved procedure for every task
and their implementation of
the upgraded
program.
These
upgraded
procedures
appear
adequate
in scope
and in cross-reference
material.
Implementation of the
improved procedures
represents
a significant improvement in the
potential
effectiveness
of
the
licensee's
Preventative
Maintenance
(PN)
Program.
The
licensee
is
additionally,
implementing
an Analytical
Based
Preventive
Maintenance
(ABPN)
Program
to
augment
their
PM program.
ABPN includes "oil
and
vibration analysis for pumps
and motors.
The licensee
intends to expand the
scope of the
ABPN program in-
Aear
future
to
include
pipe
wall thickness
monitoring,
infrared
scanning
of
breakers
and
electrical
connections,
'attery
voltage
monitoring,
and
generator/exciter
load
and
voltage testing.,
The program represents
a definite improvement,
and
should
help the
licensee
in identifying equipment
problems
prior to fai lure as well as
reduce
unscheduled
nutages.
Due to
increases
in the
scope
of the
ABPM program, its projected date-
- for full implementat
on is August 1987,
as
specified
in the
Integrated
Schedule.
The
post
maintenance
testing
program
for all,
maintenance
s'ections
on
balance
of plant
equipment
was
implemented
in
Hovember
1986.
The
electrical
and
instrument
and
control
sections
implemented
the
program,
however,
the
mechanical
maintenance
section
did not.
This deficiency
was identified
during
an
HRC inspection
in
February
1987
and
was
promptly
corrected.
Management's
approach to the resolution of technical
issues
has
improved.
Supervisory
involvement in the identification of the
root
causes
of problems
is evident through the
assignment
of
experienced
personnel
as
Event
Response
Team
(ERT) Leaders.
The
ERT is respon5ible for identifying and resolving the root cause
of a system or component deficiency in
a manner that precludes
recurrence.
On at least
ten previous
events
in 1986,
some of
which were reactor trips,'he
ERT succeeded
in ensuring that
an
acceptable
solution was
implemented without recurrence.
The licensee's
favorable results
achieved
through
use of
ERTs
for events
resulting
in plant outages
have
led to
use of the
team
approach
to resolve
equipment deficiencies
which do not
require
plant
shutdowns.
The
procedural
requirements
and
administrative policies to
be followed during
an
ERT were not
clearly
established
except
when
dealing
with
an
outage
initiating
event.
The
licensee
has
recognized
that
this
18
limitation has,
on occasion,
impacted
the effectiveness
of the
team's
response.
An
ERT administrative
procedure
is currently
under development.
Maintenance
related deficiencies
have resulted
in ten critical
and
one subcritical reactor trips.
The maintenance
deficiencies
associated
with
these
trips
were
not
generally
repetitive.
However,
five Unit
were
related
to turbine
generator
problems.
Two of these trips were manually initiated
by Control
Room Operators
when the turbine governor oil control
system
malfunctioned
causing
a
loss
of load.
An additional
reactor trip occurred during post maintenance
testing following
'eplacement
of
a turbine
governor oil impeller
The
replacement
was
necessitated
because
of unstable
governor oil
pressures.
A fourth
occurred
during
turbine
surveillance
testing
when
a technician inadvertently let go of a
trip test
handle.
The likelihood of
a personnel
error of this
sort was increased
because
a failed test valve coupling required
the operator to hold the trip test
handle
in the test position
for an extended
period of time.
The
ERT which addressed
the turbine governor oil problem was not
successful
in precluding recurrence.
A reactor trip occurred in
December
1986.
Significant load swings occurred in January
and
February
and
a reactor t'rip occurred
in March 1987.
The problem
with turbine governor performance
resulted
from poor cleanliness
of the oil- system.
The magnitude of the deficiency was realized
in
March
1987
and
resulted
in Unit 3 entering
a
scheduled
refueling
outage
approximately
one
week early
due to concerns
for turbine reliability.
Turbine control oil, lube oil and seal
oil piping was cleaned
during the outage to correct the problem.
Similar maintenance will be performed
on Unit 4 in a Spring
1988
refueling outage.
Repe itive
maintenance
problems
have
affected
other
safety-
related
systems.
Although
general
system
performance
has
improved,
(AFW) system
malfunctioned
on
numerous
occasions
resulting
in
seven
Licensee
Event
Reports
(LERs)
and
causing
repetitive
reductions
in
load
or plant
cooldowns.
Numerous
initiatives
have
been
implemented
to
improve
AFW system
performance,
including
improved
supplies,
check
valve
replacements,
restoration
of automatic
system
control,
and
flow transmitter
upgrades.
However,
the
reliability of
system
valves
and
flow transmitters,
as
documented
in six LERs,
needs
to improve.
Intake
Cooling
Water
( ICW)
pumps,
check
valves
and
heat,
exchangers
continue
to require extensive
maintenance
resources.
All six
ICW
check
valves
were
replaced
in
January
1987
subsequent
to the identification of. internal
degradation.
An
19
JUL
1 7
198)
improved
valve
design
was installed
to preclude
recurrence.
Hea. exchanger
fouling due to calcium carbonate
buildup required
repetitive
cleanings
and entrance
into limiting conditions for
opera.ion.
An Amertap
system
has recently
been installed
on the
Unit
3 heat
exchangers
to allow cleaning without removing the
heat
exchanger
from
service.
Cleaning
the
Unit
4
heat
exchangers
wi 11
remain
manpower intensive until
a similar system
is installed
on Uni
4 in the Spring
1988 refueling outage.
The
performance
of
the
charging
pumps
continues
to
be
a
maintenance
problem.
On
two occasions
multiple out-of-service
pumps
required
the
plant
to initiate
a
load
reduction
in
preparation for a reactor
shutdown
because
a limiting condition
for
operation
was
exceeded.
The
efforts
of .a
guality
Improvement
Team have
reduced
but not eliminated
t,he problems.
Excessive vibration and reduced
pump flow capacity
have required
the
pumps to be taken out of service.
A plant modification is
planned
to
reduce
vibration.
The
pumps
have
repeatedly
been
susceptible
to air
binding
which
reduces
flow output
to
unacceptable
levels
and requires
venting to restore operability.
The
pumps
are designed
to maintain
60 aallons
per
minute
(gpm)
flow but frequently provide only 45 gpm.
The operability of the Source
Range Nuclear Instruments
remains
a problem
area
as identified in the last
two assessments.
A
program developed
by the
IKC Department
in late
1985 to enhance
'perability
through physical
and procedural
improvements
has not
resulted
in significantly increased reliability.
Consequently,
the
instruments
are
frequently
out of service
during
power
operation
and
a single train may not be available for use during
unplanned
shutdowns.
As
mentioned
in the
previous
assessment,
the
area
radiation
monitoring
system,and
the process
radiation monitoring
system
continue
to have
numerous
channels.
Improvement
in
operability
has
not
been
noted.
Long
term
plans
exist
to
replace
both
systems.
Failures of process
radiation monitors,
particularly
gaseous
and particulate
containment monitors,
have
resulted
in at least
twelve
LERs documenting
the actuation
of
the control
room ventilation isolation
system.
Some of these
actuations
were caused
during maintenance
repairs
on previously
failed
channels.
Inadvertent
system
actuation
during
maintenance
is difficult to avoid due to the design of the power
supplies.
After
numerous
system
actuations,
I&C personnel
developed
a procedure
which greatly reduced
actuations
caused
by
improper maintenance.
Personnel
errors
and procedural
noncompliances
remain
a problem
as indicated in multiple LERs and the repetitive
nature
of the
violations
listed
below.
The
identified
discrepancies
are
20
JUL 1F
198'ymptomatic
of individual rather
than
programmatic
problems.
The
need for individual
a tentiveness
continues
to be stressed
Ly management
and individual technicians
and
foremen
are
held
strictly accountable
for their actions.
A desire to meet plant
expectations
of verbatim compliance
is evident
in the majority
of maintenance
asks.
However,
procedural
noncompliances
have
occurred,
as
indicated
by violations (a)
and (c)
and
proposed
violation (e)
below, during maintenance
evolutions
which were
directly supervised
by experienced
foremen.
This indicates that
verbatim
compliance
is
not yet
ingrained
at all
supervisory
levels
and
represents
a
concern
because
of the
example
that
foremen set for technicians.
Maintenance
liaison with the Operations
Department
has
improved
through the efforts of an Operations/l1aintenance
Coordinator
and
because
frequent
planning
meetings
are
held.
However,
ineffective
communication
has
occasionally
resulted
in
noncompliances.
Violation (a)
documents
an
instance
where
maintenance
personnel
performed calibration procedures
on
steam
break
protection circuitry while the circuit was
not
removed
from service.
Control
Room Operators
were not
aware of which
circuit was
being calibrated.
A reactor trip ensued.
Proposed
violation (e)
documents
multiple
Technical
Specification
violations
which
occurred
because
maintenance
personnel
performed
a core alteration without the
knowledge or consent
of
the
Operations
staff.
This
miscommunication
precluded
the
establishment
of containment integrity when required.
Four violations were identified:
a.
Severity
Level
IV violation for
a maintenance
supervisor
fail'ng to follow procedural
requirements
during
a
steam
generator
protection
channel
periodic test.
(86-30)
b.
Severity
Level
IV violation for
ai lure to establish
an
adequate
maintenance
procedural
precaution
for protection
circuitry calibration resulting in a reactor trip.
(Unit 3
only, 86-33)
Severity
Level IV violation for two examples of failure to
perform required post maintenance
valve testing
(exceeding
requirements
for containment
isolation valves,
not implementing
an administrative
and
operating
procedure).
(Unit 4 only, 86-41)
d..'everity
Level
V violation for removal
of
a pipe
support
without the authorization of a
PWO.
(86-44)
21
The following viola ion is
under
consideration
for escalated
enfo, cemel t a tlon:
e.
Proposed
violation
for
failure
to
meet
containment
integrity requirements
during
(Unit 4
only, 87-14)
2.
Conclusiion
Category:
2
Trend:
3.
Board Recommendation
The in'itial implementation
of the various
maintenance
upgrade
programs
and the resultant
improvements
in training,
procedural
compliance,
work
planning,
root
cause
identification,
Maintenance-Operations
interface,
and
individual
emphasis
on
quality,
appears
to have
improved the Naintenance
contribution
to plant operations.
Additional
management
effort needs
to
be
applied
to
reduce
the
excessive
PWO backlog,
and
to
ensure
that
proper
priorities
are
assigned
to
maintenance
work
I
activities.
It is apparent
that,
based
on past
performance,
more qualified
maintenance
personnel
are required,
especially
in the
IKC area.
This
would also
require
more field supervisors
to maintain
a
suitable ratio between
craftsmen
and supervisors.
No change
in
the
HRC's inspection
resources
is recommended.
D.
Surveillance
1.
Analysi s
During this assessment
period,
reviews of the operational
and
outage
surveillance
testing
programs
were
performed
by
the
resident
and regional
inspection
staffs.
Activities inspected
included
the
surveillance
testing
and
calibration
control
program
and snubber surveillance
program.
The surveillance
program
was deficient at the beginning of the
assessment
period,
in that
some
Technical
Specification
(TS)
required
survei llances
were not identified by the
program
and
therefore
not
performed.
Licensee
Event
Reports
(LERs)
250/86-20,
250/86-27
(5 examples),
and 250/86-29
were generated
through July 8,
1986,
as
a result of the
missed
surveillance
testing.
LERs
250/86-20
and
250/86-29 identified missed fire
protection
pump and
system
component surveillance testing.
JUL 1F
8w'2
L":R 250/86-27 iden.ified-five examples
of missed calibration
and
channel
functionality surveillance
tests.
The
systems
not
tested
within the
TS required
surveillance
period were:
Data
Acquisition
Module
-1 calibration;
Radioactive
waste
liquid
effluent
line
flow rate
monitor
calibration
and
channel
functional test;
Steam
Generator
(SG)
blowdown effluen.
flow
rate monitor channel
functional test
and;
condenser
air ejector
vent.effluent
sys.em
flow rate
measuring
device calibration.
Violation
(a)
below
was
issued
due
to
the
surveillance
programmatic
weaknesses.
The conduct of the surveillance
program
has
improved
substan-
. tially during
the latter portion of the
assessment
period.
Plant
Management
acknowledged
the programmatic
weaknesses
which
resulted
in multiple missed
TS
survei llances
and
subsequent
issuance
of violation (a)
and undertook
an aggressive effort to
eliminate
the deficiencies.
A single
comprehensive
operating
surveillance
procedure
(0-OSP-200. 1)
was
implemented
which
incorporated
all
surveillance,
schedule,
and
departmental
responsibilities.
The
procedure
delineates
.each
surveillance
test, current
TS and
new standard
TS (see
Licensing Activities)
requirement,
applicable
modes
of operation,
responsible
plant
discipline
and .its
schedule
for completion.
Since
issuance
of violation (a)
and
the
implementation
of
0-OSP-200.
1
the
surveillance
program
has
been
highly effective
and
well
controlled.
One
TS surveillance
was not performed
(LER 25/87-13)
as
a result
of personnel
error in the interpretation
of the
applicable
mode for test performance.
Although the surveillance
period was exceeded,
the
new program identified the discrepancy.
guality records
were well maintained,
accessible
and complete.
guality con.rol
reviews of test
procedures
and witnessing
of
test activities was strongly evident.
Surveillance
procedures
were technically
accurate
and provided
sufficient
instruction
to
assure
proper
performance.
The
Procedure
Upgrade
Program
(PUP)
has increased
the quality of the
format
and
content
o'f
surveillance
procedures,
minimizing
personnel
errors
and promoting quality work.
Procedures
for control of the
surveillance
program are
well defined
and explicit.
Decision 'making
was
usually at
a
level
that
ensured
adequate
management
review.
Records
were
complete,
well maintained,
legible
and retrievable.
Staffing
and training and qualifications of personnel
was adequate.
Two Unit 3 reactor trips
occurred
as
a result
of personnel
errors
in the
performance
of surveillance
procedures
and
one
Unit 3 reactor trip occurred
as
the result
of
an
inadequate
23
JUL 1V lg87
surveillance
procedure.
The licensee
took prompt action after
each
rip to determine
he roo
cause of each
even
and
o .ake
corrective actions to prevent recurrence.
One violation was identified:
a.
Severity
Level
IV violation
for
inadequate
corrective
action
on
missed
surveillances
(86-39;
second
part
of
violation is discussed
in the gA section of text.).
The following violation is
under
consideration
for escalated
enforcement
action:
b.
Proposed,
violation for inadequate
leak rate
procedures.
(Unit 4 only, 87-16)
Conclusion
Category:
2
Trend:
3.
Board Recommendations
The
PUP
group
must
continue
to review
and
upgrade
existing
procedures
and write new procedures,
when appropriate,
to ensure
that
surveillance
test
periodicities,
applicable
modes
of
operation,
and all required
components
and
systems
are tested
consistent
with the requirements
of the
upgraded
TS prior to
their approval
and implementation.
Fire Pro-ec
ion
1.
Analysi s
Fire
protection
was
not
inspected
by
NRC
Region II office
personnel
during
this
period.
During
routine
tours,
the
resident
inspector identified two violations in this area which
are indicated below.
Two violations were identified:
a.
Severity
Level
IV violation
for
not
having
adequate
procedures
for controlling deluge
system
valve
line-ups
including pressure
switch isolation valves (86-33).
b.
Severity
Level
V violation for six occasions
of propped
open fire doors.
(86-39; first part of violation is
on
inadequate
Plant
Change/Modification
functional
testing
and is discussed
in the outage
section of t'ext).
2.
Conclusion:
The
lack
of inspection
activity in this
area
orecludes
a
meaningful
assessment
of
licensee
performance.
Category:
N/R
3.
Board Recommendations
None
Emergency
Preparedness
l. 'nalysis
During the assessment
period, inspections
were performed
by the
regional
and
resident
inspection
staffs.
These
included
observation
of
an
annual
emergency
preparedness
exercise
and
a
routine inspection.
One revision to the Radiological
Emergency
Plan
was reviewed.
During the exercise,
the licensee
continued
to. demonstrate
the
capability to promptly identify and correctly classify emergency
events
consistent
with the Radiological
Emergency
Preparedness
Plan
and
implementing
procedures.
Corporate
management
demonstrated
a strong
commitment to maintenance
of an effective
emergency
response
program.
Consistent
with this
commitment,
corporate
management
was
directly
involved
in
the
annual
exercise
and critique.
Personnel
assigned
to
the
Emergency
Response
Organization
were cognizant of their responsibilities,
and
were
adequately
trained
in required
areas
of
emergency
response.
The
Emergency
Response
Organization's
management
and resolution
of the
postulated
accident
during
the
exercise
demonstrated
significantly improved
emergency
preparedness
training.
Prompt
activation
and
management
of the
emergency
response
facilities
was particularly notable.
The transfer of emergency
management
from
the
Technical
Support
Center
(TSC)
to
the
Emergency
Operation
Facility
(EOF)
was
prompt,
decisive,
and
comprehensive.
The
licensee
effectively
used
emergency
action
level
(EAL)
matrices
in promptly identifying and declaring
each
emergency
classification.
Inplant and offsite protective action decisions
were
effectively
implemented
throughout
the
exercise.
Protective action
recommendations
were promptly communicated
to
the State.
State
and local
government representatives
assigned
to
the
,EOF
were
consistently
factored
into
the
offsite
protective
action
decision-making
process.
Consistent
and
effective
communications
with offsite agencies
were maintained
25
JUL 1V
1987
throughout
the
exercise..
Significant
improvement
in
he
licensee's
communications
wi
h its field radiological monitoring
teams
was
observed.
The subject
teams
were frequently updated
regarding
plant status
and
changing
meteorological
parameters.
Effective
interaction
between
licensee
and
State
field
monitoring teams
and reported data
was maintained
throughout the
exercise.
The
one area
which detracted
from the exemplary performance
was
the licensee'
failure, during the
annual
exercise,
to notify
the
State
of the
Site
Area
Emergency within the
assigned
15
minu
e constraint.
The
15 minute notification is required
by
Regula"on
and
'he
licensee's
notification
procedures.
The
licensee
did
make
the proper notification within
25 minutes.
This finding
was
also
identified
by the
licensee
during the
con rolle. /evaluator
cr',tique.
The
licensee
continued
to
be
responsive
to
HRC initiatives regarding correction of weaknesses
and program
improvements identified during routine inspections,
drills,
and
exercises.
The
licensee
continues
to
conduct
detailed critiques
following each
exercise,
and
implements
the
corrective actions reouired.
One violation .was '.dentified by the Senior Resident
Inspector:
Severity
Level
IV violation defining four examples of the
public address
system
as failure to meet
the requirements
of
and 50.47(b) (86-33).
(See
2.
Conclusion
Ca egory:
1
3.
Board Recommendations
Ho change
in the
NRC's inspection
resources
are
recommended.
G.
Security
and Safeguards
1.
'Analysi s
Inspections
were performed
by the resident
and regional staff.
The previous
SALP's analysis
addressed
the licensee's
program to
repair
and maintain'he
aging
security
system's
components.
This program utilized several
full-time employees
to maintain
the
system
and relied
on compensatory
measures.
Currently, the
licensee
has
reduced
the dedicated
maintenance
personnel
to one,
although other plant resources
can
be called upon.
The licensee
continues
to rely heavily
on
compensatory
measures,
some
of
26
JUL
> p
~>87
which have
been
in place
in excess
of two years,
with no
end
date
planned.
The
security
system
computer
continues
to
be
unreliable
with
frequent
down-time,
requiring
addi .ional
ex ensive
compensa.ory
measures.
The
licensee
is currently
having difficulty procuring
spare parts for the system,
which is
approaching
obsolescence.
The licensee
has
long term plans (in
the Integrated
Schedule)
to replace
the security computer
system
but no vendor selection
has
been
made to date.
The
number
and repetitive
nature
of the violations identified
during this period indicated
.a weakness
in the security
program.
These .violations
were
caused
by
a
combination
of inadequate
procedures,
inadequate
compensatory
measures,
and
lack of
management
oversight.
The licensee
does
not
show initiative in
self-identification of problems.
However,
the
licensee
does
show responsiveness
to
NRC initia ives.
1
The security shift supervisors
exhibit
a knowledge of procedures
but
lack training
in regulatory
requirements
and
are
not
familiar with the
basic
documents
detailing
the
licensee's
commizmenis
to the
NRC.
During an inspection,
late in the
period, it was noted that none of the security force supervisors
had
seen
or
had
access
to the Physical
Security
Plan.
During
this rating period the licensee relied
upon the line supervisors
to implement
compensatory
measures
and
communicate
problems
to
plant
management.
This
lack
of
management
oversight
is
evidenced
by the
nume'rous
violations demonstrating
a lack of
attention
to
details.
Violations
identified
involve:
unescorted
visitors;
unbadged
personnel
inside
the
protected
area;
isolation
zone
degradations;
inadequate
compensatory
measures
and procedures;
and inadequate
door hardware.
The repetitive
nature
of the
more
serious
violations dealing
with failure to adequately
control
access
to the protected
and
vital
., areas
indicate
that
the
licensee
implements
.violation-specific corrective
actions
and fails to address
the
root
cause.
This is particularly significant in that
three
Enforcemeni
Conferences
were
held
in
the
Region II offices
during this rating period at which time the licensee
stated that
the security program would be improved.
The
licensee
has
shown
a willingness
to
improve vital
area
barriers
and
has requested
a meeting to address
the topic.
The
response
to this request
has
been deferred,
pending
completion
of NRC Headquarters
review of vital area policy and criteria.
The licensee
has
made personnel
changes
in the positions of Site
Security
Manager
and
Chief
of
Uniformed
Security.
The
incumbents
are working to improve the security program;
however,
this change
came too late in the
SALP rating period to
have
an
impact
on the current analysis.
27
JUL 1V
>887
Eleven
viola ions
were identified during this rating
period.
Two
viol a i ons
represen
ed
by
(a)
below
were
categorized
o"e her
as
Sc veri ty
Level III
problems
and
a
Seventy-Five
T lousand
Dol 1ar Civil Penalty
was i ssued.
Two violations (j and
k) are currently under review for escalated
enforcement action.
I
Eleven violations were identified during this evaluation period:
a.
Severity
Level III violation
for
security
problems
involving security officers sleeping
on post
and inadequate
visitor control/escorting
(87-11) .
b.
Severity
Level
IV violation
for failure
to
provide
protected
area barri er (86-32) .
c.
Seve. ity Level
IV violation for having
inadequate
pathway
from the protected
area
into vital areas
(86-38).
d.
Severity
Level
IV violation for having
inadequate
access
control to vital areas
(86-38).
e.
Severity
Level
IV violation for having inadequate
lighting
at :he protected
area
perimeter (86-38).
f.
Severity
Level
IV violation
for
having
inadequate
compensatory
measures
(86-40).
g.
Severity
Level
IV violation
for failure
to
maintain
protected
area isolation
zone (86-47).
h.
Severity
Level
IV violation for failure to wear security
badge/keycard
(86-47).
i.
Severity Level
V violation for having inadequate
procedures
(86-38).
The
following
two violations
are
under
consideration
for
escalated
enforcement action:
j.
Inadequate
vehicle search
(87-25).
k.
Failure
to
control
personnel
and
equipment -access
to
containment
(87-25).
2.
Conclusion
'ategory:3
Trend:
28
JUl.
g 7
1987
3.
Board Recommendation
The
board
recommends
increased
management
attention
and
commitment in order to effect
necessary
improvements
in this
area.
H.
Outages
1.
Ana lysi s
During
this
evaluation
period,
inspections
of
refueling
activities,
outage
management,
major
plant
modifications,
inservice
inspec-.ion
and test
( ISI/IST) and post-outage
startup
testing
were performed
by the regional
and resident
inspection
staffs.
Unit 4
rema i ned
in col d
shutdown
through
the fi r st
week
in
August
1986,
to
complete
electrical
load
modifications
to
preclude
the
potential
for overloading
the
emergency
diesel
generators
(EDG).
To support
the final implementation
of these
modifications
required
both
units
to
be
in
cold
shutdown
simultaneously.
Unit 3
came off line
on July 15,
1986,
to complete elec'trical
modifica~ions required
to resolve
the
EDG overload evaluation.
The
outage
was
scheduled
for eighteen
days
with electrical
system modifications
and
RHR motor
end bell inspections.
The
electrical
system
modifications
were
completed
and
tested
satisfactorily
and the outage
lasted
nineteen
days.
On July 26,
and July 28,
1986,
the licensee
performed engineered
sa eguards
testing
on Units .3
and
4,
respectively.
Licensee
letter
JPES-PTP-86-1099,
dated July 29,
1986,
documented
that
the test
results
were
acceptable
with regard
to
EDG loading
concerns.
The testing
was per'formed in
a manner
which required
the measurement
of EDG loading values
during
a simulated
large
break
LOCA coincident with a loss of offsite power.
These tests
did
not
involve
Units 3
and
4
simultaneously.
Additional
loading
values
were
obtained
assuming
only
a loss of offsite
power.
Correction factors were applied to the data
as necessary
to account for the .increased
power consumption
some
equipment
would require
. under
actual
accident
conditions.
The
maximum
load that could automatically
load
on
a single operable
EDG was
calculated.
As documented
in letter JPES-PTP-86-1099,
the worst
case
load 'values
were found to remain within those predicted
by
licensee
in Safety Evaluation JPE-L-86-074,
Revision
1, "Safety
Evaluation Turkey Point Units
3 and
4 (PTPN)
Emergency
Diesel
Generator
Load", dated July 1986.
The inspectors
conducted
an
29
JUL I'7 lg87
independen.
review of ihe
surveillance
results
and .concluded
that
.he wors.
case
au+o-connected
loading
during single
operation did not exceed
the 2750 ki iowa+t limit specified in TS 4.8.1.c.8.
in returning
Unit 3 to service
no significant primary system
problems
were
encountered
although
the
secondary
system
experienced
several
problems.
On August 21,
1986,
the unit was
forced to come off the line as
a result of a main condenser
tube
leak apparently
due,
in part, to
a free bolt in the tube bundle.
Also discovered
at this time
was
a hole in the
3B condensate
pump suction piping.
An ongoing
problem exists with
a leaking
condenser
boot seal.
The interim solution
has
been to seal
the
leak with condensate
flow to prevent air
from entering
the
secondary
system.
Unit
4 restart
was
contingent
upon
completion
of electrical
system modifications.
Subsequent
to the
successful
testing of
these
modifications,
simultaneous
unit operation
was concurred
in
by
the
NRC.
Unit 4
encountered
.several
delays
while
a-tempting
unit restart
and/or
while achieving
rated
power.
During rod testing,
multiple control
rod failures resulted
in
the
repair
and/or
replacement
o
control
rod drive mechanism
instrumentation.
On August 2,
1986,
the
4C
steam
supply
check valve (4-383)
required
replacement
due to excessive
seat
leakage.
Unit operation
was further delayed
as
a result of high
vibration in the exciter.
The exciter
was replaced,
but the
vibration
was
later
determined
to
be
caused
by
a
bowed
turbine-generator
rotor.
Additionally,
the
4A
regulating
bypass
valve
(4-FCV-479)
had to
be repaired
due to
difficulty in maintaining
steam
generator
level
at
a
low
feedwa er
flow
ra e.
Throughou'he
startup
period,
he
secondary
system
experienced
chemistry
problems
which required
low power level holds.
On
August 30,
an
leak
was
identified
coming
from the
conoseal
on the reactor vessel
head.
An engineering
evaluation
was
performed
and
approved
which justified operation with the
existing leak.
Unit 4
was
then
started
up
and
achieved
power
operation
in early
September.
A further
discussion
of the
conoseal
leak
is
contained
in
Section
IV.L.,
Engineering
Support.'iolations
of
NRC
reqUirements
were
identified
during
the
extended
Unit 4
refueling
outage.
On
Augu'st
5,
1986,
a
'ubcritical
reactor
trip
occurred
while
performing
post
modification
acceptance
testing
(86-39);
this
violation is
listed in Section
IV.E.
Of particular.
concern
in reviewing the
reactor trip was that
two departments
were performing separate
30
JUL 17
lgsy
tests
without apparent
knowledge of the unit test status.
On
August 9,
1986,
during Unit
4 hea.
up apparent
operator error
resulted
in the automat'.c
actuation
of the
AFIRE'ystem (85-39);
thi s violation is listed in Section IV.A., Plant Operations.,
On October 23,
1986, Unit 4 was
shutdown to locate
and repair
a
suspected
condenser
tube leak.
All steam generator
conductivity
meters
in
the
control
room
had
pegged
high off scale
and
chemical
analysis
verified excessive
conductivity
and chloride
levels
in the condenser
and the
indicative of
gross
tube
leakage.
Unit 4 was
shutdown while
an investigation
commenced
to determine
the root cause
of the condenser
inleakage.
Based
on the chloride concentration
and conductivity levels in
the
secondary
system
the
licensee
calculated
that
there
was
approximately
600
gallons
of circulating
water
inleakage.
Because
of
the
severity
of
the
contamination,
an
extensive
clean
up of the
conden,sate
and feedwater
systems
was
initiated.
This was
hampered
by a shortage
of water meeting
the
quality standards
for the secon'dary
system.
The water treatment
plant onsite
which provides
such
water
was
in service
only
intermittently and resin type ion exchangers
were trucked to the
site to provide adequate
water.
Several
leak detection
methods
>>ere
used
in an attempt to locate the leak, including the
use of
a
helium sniffer,
soaping
of the
water
box
tube
sheet,
and
testing of the hotwell side of the condenser
tubes.
All were
unsuccessful
in determining
the
source
of inleakage.
On October
27,
1986, while Unit 4 was in Mode
3 (hot standby)
in
preparation
for reactor startup,
operating
personnel
discovered
that
the required
post-maintenance
testing for numerous
valves
inside
containment
had
not
been
performed.
The
valves,
primarily
from
the
Program,
included
two
containment
isola.ion
valves,
which
were
subsequently
declared
out
of
service.
The licensee
commenced
an immediate unit cooldown per-
and
made preparations
to test all affected valves.
In
addition
Motor Operated
Valve (MOV)-751, which is in the
pump
suction
line,
required
plant
depressurization
to
less
than
525 psig
for testing
(violation (c)
of Section IV.C.,
Maintenance).
On
March 6,
1987,
after manually tripping the reactor
due to
turbine control oil system
problems,
Unit 3 was brought to cold
shutdown
to
commence
preparations
for the
refueling
outage,
which was
scheduled
approximately
a week later.
One violation
was identified during the Unit 3 refueling outage.
It involved
the
failure
to control
the lifting/handling of regenerative
Secondary
Sources
in a manner to prevent
damage,
which is listed
as violation (h) in Section IV.A., Plant Operations.
31
On
March 11,
1987,
Unit 4 reactor
was
manually
shutdown
as
required
by Technical
Specifications
due
to
a
leak
in
the
containment
personnel
hatch
inner door.
Unit 4 was maintained
in
Mode 3,
Hot Standby,
until March 13, while
r epair s to the
personnel
hatch
door were in progress.
On March 13,
1987,
The
unit was taken to Mode 5, Cold Shutdown, io assess
a
known leak
from
a port instrumentation
column
assembly
(conoseal)
and the
ex ent
of
he
boric
acid
contamination
and
subsequent
surroundino
corrosion
areas.
Subsequently,
an
NRC
Augmented
Inspec
ion
Team (AIT) was. formed
and dispatched
to
the site.
Section IV.L., Engineering
Support,
contains
the details of the
'conoseal
leak and AIT findings..
A violation
identified
during
the
Unit 4
outage
involved
the
performance
of
core
alterations
prior
to establishing
containment
integrity.
This
was
attribu
ed
to
inadequate
procedures
and
poor
communications
between
Maintenance
and
Operations
(see
proposed violation (e) in Section
IV.C).
In
general,
there
is
management
evidence
of planning
and
assignment
of priorities for maintenance
and modifications of
known tasks.
Schedules
have slipped considerably
from original
estima+es
primarily
as
a result
of the
iden+ifica+ion
of
unforeseen
work activity.
Raychem splice
rework was identified
only after both unit outages
had
commenced.
As
a result of the
Unit 4 conoseal
leak, detailed
inspection
of the Unit 3 vessel
head
identified
CRDM seal
housing
leaks
that
also
required
repair.
Leaks
in the
Post Accident Hydrogen Monitoring System
sample line were identified by local leak rate testing
and have
further delayed restart of Unit 4.
Regional
Inspec ors reviewed
he ISI/IST program,
procedures
and
. observed
work activities.
The
staff
found
that
ISI/IST
activities
were
procedurally
well
delineated
for
ISI/IST
personnel.
Training, qualification and certification of ISI/IST
personnel
has contributed to good, adherence
to procedures
with
only
a modest
number of personnel
errors.
Responsiveness
to
NRC
initiative was usually timely; however,
the deviation indicated
below is
an exception
in this area.
Aside from violation (c),
of Section IV.C., Maintenance,
discussed
previously,
the ISI/IST
corrective
action
system
promptly
and consistently
recognized
and
addressed
non-reportable
concerns.
Records
were complete,
well maintained
and available.
In May 1987,
the licensee
developed
and conducted
a special test
of the "cross-talk" capability of the
EDG load sequencers.
This
test
was
deemed
necessary
following the discovery of
EDG wiring
discrepancies
as discussed
in Section IV.L., Engineering
Support.
Subsequent
to
discussions
with
the
Resident
Inspectors
and
regional
management,
the licensee
elected to conduct these tests
32
JUL
1 p
)gal
to ensure all aspects
of the load sequences
abilities to operate
properly for both units had
been adequately
tested.
These tests
involved simula.ing
a
Loss
of Ofisite
Power
(LOOP)
and
then
manually initiating
a
Safety
Injection
(SI)
on
each
unit.
Previous integrated
safeguards
tests did not involve both units
sim ltaneously
and therefore,
with only two EDG'
the ability of
the sequencers
to properly sequence
the safeguards
loads
on the
SI affec.ed
unit
and
shutdown
loads
on the non-affected
unit
(cross-talk)
had never
been completely tested.
These tests
were
conducted
in late
May 1987
and
resulted
in the initial test
being unsuccessful
due to personnel
errors that occurred
during
a
related
preventive
maintenance
test
conducted
the
previous
week.
The licensee's
troubleshooting efforts were effective
and
the
subsequent.
tests
for
each
unit
were
successful.
NRC
inspectors
had
the following reservations
with regard
to the
licensee's
performance
of these tests:
management
involvement
and support were not always evident
both in the development
and conduct of the test.
The licensee's
initial root cause
analysis
was superficial
but subsequent
efforts were comprehensive.
Personnel
errors
that
resulted
in the first test
being
unsuccessful
were
att,ributed
to
deficiencies
in
the
training
and qualification of the electrical
maintenance
personnel
involved.
One deviation
was identified.
,
2
Deviation for failure to submit inservice inspection relief
request
as committed (86-31).
Conclusion
Category:
2
3.
Board Recommendations
No change
in the
NRC's inspection
resources
are
recommended.
Quality Programs
and Administrative Controls Affecting Quality
1.
Analysi s
During the
assessment
period inspections
were
performed
by the
resident
and regional
inspection staff.
33
JUL 1V 1987
For the purposes
of this assessment,
this area is defined
as the
ability of
the
licensee
to identify and correct
heir
own
problems.
It
encompasses
all
plan+
activi+ies,
all
plant
personnel,
as well
as
those
corporate
functions
and
personnel
that provide services
to the plant.
The plant and corporate
staf=
have
responsibi li y for verifying quality.
The rating in
this area
specifically denotes
results
for various
groups
in
achieving
quality
as
well
as
the
QA staff in verifying that
ouality.
A QA effectiveness
inspection
was conducted of licensee
trending
indicators
as
the
basis
for
a
broad
based
assessment
across
various performance
areas.
The premise of the
QA program is to
ensure
safe
and
reliable
plant
operation
and
the
ultimate
effectiveness
of the licensee's
QA program
can
be
measured
by
examining
various
operational
trending
indica ors.
The
inspection
included
reviewing
licensee
corrective
actions
developed
to address
the indicated
problem areas.
The inspection effort was divided into the following areas:
Operations
and Maintenance
Qual;+y Assurance
Quality Con rol and Licensing
Commitments
Design Control
In
the
area
of operations
and
maintenance,
some
short-term
improvements
were
evident
but
long
term
improvements
were
indeterminant.
An activity which
had
produced
verifiable
short-term
improvements
was
the 'establishment
of
the
Event
Response
Team
(ERT).
The
ERT
was apparently
instrumental
in
decreasing
he
number of repeated
or recurrent ouiages.
Large
scope corrective action
programs
were developed to reduce
personnel
errors,
to develop
and implement
an equipment labeling
program
and to develop
a procedures
upgrade
program.
The
1987
policy statement
for
FPRL states
that
40
percent
of reactor
trips at
Turkey Point
were
caused
by personnel
error.
The
equipment
labeling
program
has
shown its effectiveness
to
some
extent
in that
no
wrong
train/wrong -unit
personnel
errors
occurred
after
Nay
1986.
The
procedure
upgrade
program
is
intended
to
provide
"user
friendly" procedures
for safety-
related
systems.
These
improvement
programs
address
the major
identified causes
of personnel
error
and
should
improve
the
long-term performance
in this area..
The general
conclusion of QA effectiveness
in the operations
area
was that
the licensee
can identify and was correcting
problems.
34
JUL 17
>9S7
The maintenance
department
has initiated several
projects
in an
ef for . 'to'mprove
performance
and
increase
plant reliability.
However,
the
license-" trend indicators (corrective
main.enance
backlog,
unplanned
days off line,
and equipment out of service)
used for measuring
the effectiveness
of maintenance
activities
do
no
reflect
convincing
trend
changes
in this
area.
One
improvement
example
was
in
source
range
instrumentation
reliability.
A Quality Improvement
Team reviewing
.the chronic
failure problem identified two mechanisms
of detector failure.
The
licensee
has
initiated
some
other
improvements
in the
Preventative
Maintenance
(PM)
program,
and
the
Nuclear
Job
Planning
System
(NJPS);
they
also
created
positions
for
engineers
dedicated
to root cause
analysis.
These
corrective
actions
have the potential to improve maintenance
performance.
The quality
assurance
department
appeared
to
be
adequately
accomplishing
its
assigned
function
of
identifying
and
correcting
site
problems
based
on
interviews
with
site
personnel,
reviewing audit findings, reviewing audit schedules,
and reviewing corrective action 'requests.
During l986, the licensing group
has significantly increased its
involvement in the review of reportable
events;
consequently,
a
more effective liaison exists
between
licensing
and operations
personnel.
Quality improvement
teams
have
been established
which consist of
'ersonnel
from different departments
addressing
problem areas.
Approximately 25 teams
have
been established,
about
one half of
which
have
completed
a project
resul
ing in various quality
. improvements.
Problems
were
noted
in the
area
of design control.
FPC L, in
their letter
dated
October
I,
1986,
committed
to
develop
corrective
action
plans
to address
identified deficiencies
in
design
control,
evaluations,
and
timelines
of
corrective
action
in
i"esponse
to confirmatory action letter.
Considerable
resources
have
been
expended
in the
process
of
meeting
these
'requirements.
However,
a- review of
selected
elements
of
the
corrective
action
plans
identified
that
weaknesses
still
exist.
Relative
'to
corrective
action
timeliness
for
site
QA identified
problems,
administrative
control's for justifications for operations
evaluations
and
high
backlogs
of drawings
needed
to
be
updated.
Other
elements
of
.the
commitments
made
in the letter
appear
to
be
on
schedule
including
the
site
engineering
staffing
level
and
program
procedures,
the Standard
Engineering
Package
for Nuclear Plants,
and
various
aspects
of the
comprehensive
review effort for
selected
systems.
35
SUL ~'7
>s87
The
QA organi=ation
a- Turkey Point has
been
reorganized
into a
Performance
tionitoring
Section
and
a
Regulatory
Compliance
Section.
The
Performance
Monitoring
Sec
ion
provides
,or
a
significan
increase
in
QA/QC
involvement
in monitoring all
plant activities
through. observation
and
walkdowns
of various
systems
and equipmen
.
The
Regulatory
Compliance
Section
is
responsible
for
the
traditional
QA/QC audit function.- Improvements
in this
area
include
increasing
the
audit
frequency
to
quarterly
and
increasing
the time constraints
associated
with Non Conformance
Reports
(NCRs) to assist
in expediting
response
and corrective
action.
However,
this
group
is
not
involved
in
auditing
Requests
for
Engineering
Assistance
(REAs),
Event
Response
Team
(ERT) activites
and investigations,
and the monitoring of
activities
and
equipment
associated
with the secondary,
balance
of plant area.
The quality control
over
the
procurement
and
issuance
of
replacement
parts
has
been
improved
by
the
licensee.
The
licensee
es~ablished
an
onsite
group
called
the
Purcnase
Document
Review
Team
(PORT)
to
address
excessive
delays
in
procurement.
The licensee
has
also
improved the control over safety-related
spare
parts
in
storage
on site.
Personnel
responsible
for
cataloging
these
parts
have
been
moved
from corporate
to the
site.
In addition, the nuclear stores
have
been
segregated
from
the fossil
stores
to help
ensure
that non-qualified parts
and
equipment
are
not utilized in safety-related
or important to
quality applications.
An
inspection
of
the
corrective
action
program
was
also
conducted
as part of a special
performance
assessment
inspection
oi maintenance activities.
Two violations occurred
during the
SALP period
which
document
fai lures
of the
licensee
to take
timely
adequate
corrective
action.
In
violation
(c)
of
Section
IV.L.,
the
licensee
failed to
take
timely corrective
action for two support
hangers
on the Unit 4 charging line.
A
second
example
involved improperly bolted starting air receivers
on the
A and
B Emergency
Diesel
Generator.
Violation (e) of
Section IV.L. involved the failure of the licensee
to identify
and correct
a deficient condition involving an Intake Cooling
Mater check valve, which exhibited
symptoms of internal
key and
keyway damage.
Plant
personnel
indicated
that
the
responsiveness
of plant
management
has
been
improving
in
many
areas
including work
requests
and
NCRs.
There
were
also positive
indications
of
increased
management
involvement
in daily plant operations,
36
~UL ~r
>s87
including frequen
plan.
and control
room tours
and a.tendance
a
he
morning olant status
mee+inqs.
Manaaement
sensi .ivity
.raining
which is
designed
+o "sensitize"
employees
to
the
corporate
and plant goals,
has
been
implemented for all Turkey
Point personnel.
An important aspect
of this training was that senior
members of
managemen
, including the Plant Manager
and Site Yice President,
were available at each
session
to answer questions.
In general,
it appeared
that
management
attention
to plant operations
and
response
to identified problems
has
been
improving.
A review was performed
on all sections
of the
SALP report in an
attempt
to capture
apparent
strengths
and weaknesses
related to
management
controls affecting quality.
The following are
some
pe.ceived
strengths
in management
controls affecting quality:
Plant
management
stressed
the concept of Operations
as the
"customer" for various plant
support
groups,
reducing
the
previous
tendency
for
Operations
to
operate
around
maintenance
problems.
Plant
management's
emphasis
on
procedural
verbatim
compliance
helped to reduce
personnel
errors.
Management
involvement
with
operations
activities
has
increased.
As
a result,
complex
evolutions
are
more
smoothly performed.
Primary plant housekeeping
has continued to improve in the
wake of increased
management
attention in this area.
Management
has
shown
a
commitment
to excellence
in its
support of the
PEP
and other corporate quality improvement
programs.
Management
involvement
in health
physics
was sufficient
earlv in outage preparation
to permit adequate
planning.
Supervisory
involvement
in
the
maintenance
program
has
significantly improved resulting
in effective
work order
implementation.
Management
support of maintenance
was readily apparent
in
the areas
of training and facilities.
Supervisory
involvement in the identification of the root
ca'uses
of problems
has
improved through the assignment
of
experienced
personnel
as Event
Response
Team leaders.
37
JUL 1'7
1987
Plant
management
has
undertaken
an
aggressive
effort to
eliminate
m'.ssed
TS
survei llances,
resulting
in
conside,able
improvement to this program.
Corporate
management
demonstrated
a strong
commitment to
main-enance
of ar. effect,ive emergency
response
program.
There
has
been
increased
management
involvement in plant
operations,
including frequent plant and control
room tours
and attendance
at morning meetings.
Since
the
last
period,
management
attention
to
licensing initiatives
has
improved
as
demonstrated
by the
reduction of the backlog in licensing actions.
Opera
ional
Experience
Feedback
Training control
has
been
improved
due
to management
attention
to documentation
and
timely disposition
of information.
It was
unsuccessful,
however, with regard to
two events;
the
conoseal
leak
and
the nitrogen intrusion into the boric acid system.
The
following
are
some
perceived
weaknesses
in
management
controls a;fe ting quality:
Secondary
plant
housekeeping
has
been
mediocre
as
management
emphasis
has concentrated
on the primary side.
Plant
management
has
been
previously
unsuccessful
in
assuring
adequate
staffing in the Operations
Department
to
preclude
excessive
overtime.
Specific plans
and
programs
are presently
in place to correct this deficiency.
Management
support
in
the
plant
chemistry
improvement
program
was
not evident with regard
to the timeliness for
upgrading
of
the
chemistry
laboratories
and
sampling
panels.
Management
has
not
been fully successful
in preventing
repetitive maintenance
problems (e.g.
AFW,
ICW and nuclear
instrumentation)
and
in
stemming
an increasing
number of
PWO's.
This increasing
PWO backlog
can also
be viewed as
a
positive
indication
of
maintenance
responsiveness
( see
Section IV.C).
The licensee
has continued to rely heavily
on compensatory
measures
for
the
maintenance
of
the
security
system
computer,
which remains unreliable.
Lack of management
oversight
has contributed
to
numerous
and repetitive violations concerning
the security program.
38
Shor
ages
in the staffing of qualified instructors
has
led
to deficiencies
in the training area.
The
use of contract
instructors
has
had diminished effectiveness
due to their
lack of knowledge of plant specifics.
The existing training
program
and its documentation
has
lacked adequate
management
attention.
Two violations were identified:
a.
Severity
Level
IV violation for failing to have the proper
number of radios
in the Control
Room
as
required
by the
Control
Room Inacessibi lity Off Normal Procedure
(86-37).
b.
Severity
Level
IV violation
for
excessive
Operations
personnel
overtime.
(87-24)
2.
Conclusion
Category:
2
Trend:
3.
Board Recommendations
The
board
recognized
the fact that
licensee
management
has
expended
significant effort to improve performance
in this area.
Licensing Activities
1.
Analysi s
Management
control
and overview in the licensing activity area
continues
to be evident.
The licensee's
management
continues
to
have
freouent
meetings
and discussions
with the
NRC staff to
assure
there is
a
common understanding
of safety
issues
and the
need
for
timely
resolution.
An
example
of
management
involvemen
is demonstrated
by their initiative in proposing
an
amendment
to incorporate
a license
condition for
an integrated
schedule.
The integrated
schedule
concept provides
a methodical
process
to allocate
and balance
resources
between
improvement of
plant performance
and enhancement
of overall plant safety.
There
has
been
an
improvement
in
the
attention
management
provides
to licensing initiatives
and activities
from the last
SALP period
as demonstrated
by the reduction .of the
backlog
in
licensing
actions.,
Although the
level
of attention
given to
licensing
activities
has
improved,
the
resolution
of
some
licensing
issues
is
impacted
due
to the efforts
required
in
other areas
such
as operations,
maintenance
and select
systems
review.
39
JUL 17
)g87
The
- icensee
continues
to
increase
the
technical
staff
supporting
the
Turkey
Point
Plant
both
ir.
the
engineering
offices
and
a+
+he plant site.
The projected
and
agreed
upon
schedules
are
generally
met.
In
most
cases
where
schedul.e
changes
are
necessary
adequate justification is provided.
Some
schedules
have
been slightly delayed
due to resource
cons.raints
resulting
from operational
problems.
In general,
the effects of
the licensee's
consolidation
of the majority of their nuclear
engineering
support
staff
has
resulted
in overall
improvement
and efficiency in the licensing process.
The
licensee's
response
to
NRC initiatives continues
to
be
prompt
and
complete.
During this
SALP period
a total of
30
multi-plant
and
Tt1I related
items
have
been
resolved.
The
licensee
has
taken the initiative of proposing
amendments
to the
Turkey Point licenses
to incorporate
an integrated
schedule
and
to upgrade
the plant specific Technical
Specifications
to the
standard
Technical
Specifications
for Mestinghouse
plants.
It
should
also
be noted that the licensee voluntarily initiated an
administrative Limiting Condition of Operation
on the
emergency
diesel
oenerators
as
an inierim measure
until the staff
com-
pletes
their
review of the
proposed
technical
specification
upgrade
in this area.
The overall staffing to support
licensing activities continues
to
be
more
.han
adequate.
The
increased
diversity
in
the
technical
backgrounds
of the
licensing staff is
an
asset
in
resolution of technical
problems."
The overall coordination of
the licensing activities generally results in prompt and timely
responses,
although the extremely
heavy workload of the on-site
staff
continues
to result
in
scheduler
delays
on
occasion.
Increased
interaction
of the
o f-site
and
on-site
licensing
staff has led to overall
improvement.
The
licensee
has
been
responsive
to
Regional
initiatives to
reduce
the
NRC
backlog
of Outstanding
Items
(closeout
of
violations,
unresolved
items,
etc.).
They
have
prepared
and
submitted
packages
to the inspection staff of those
items
deemed
ready for closeout inspection.
The licensee
continues
to, provide specialized
training to the
licensing staff.
As noted previously,
the diverse
backgrounds
of
the
licensing
staff
have
aided
in prompt resolution
of
licensing activities and providing timely information related to
operational
occurrences.
The
licensing staff provided timely
and detailed
information rel,ating to the recent reactor
coolant
system
leak
on Unit 4.
The licensing staff also participates
in industry initiatives
such
as
the
technical
specification
improvement
program.
40
JVL lp8y
During
the
evaluation
period of
Nay 1,
1986
through
May 31,
1987,
several
situa.ions
occurred at Unit 4 which had
a negative
impact
on the implementa.ion
of in.ernational
safeguards
in the
U.S.
-The
implemen.ing
instrument
for International
Atomic
Energy
Agency
( IAEA) safeguards
at the facility level is the Facility
Attachment
(FA) which contains
detailed
information
as to
how
IAEA safeguards will be performed at the facility.
In Nay 1986,
the
NRC sent the licensee
a copy of the draft IAEA FA for review
and,
in
October
1986,
he
was
provided with
a
copy of the
finalized
FA for informational
purposes.
The
FA was formally
imposed
as
a condi
ion of license
by
NRR on April 10,
1987.
.Although licensee
management
did perform the records
and reports
functions
in
an
adequate
manner,
they
did
not
maintain
an
adequate
level of awareness
of the obligations associated
with
the
containment
and
surveillance
functions
of international
safeguards.
On
several
occasions
continuous
illumination for
surveillance
cameras
was not maintained
in the
spent
fuel
bay.
This reouired
two re-verifications of the spent fuel inventory.
Also,
IAEA seals
designated
to maintain the safeguards
integrity
of 'he
reactor
core
were
broken
on
several
occasions
which
require
re-verification
by
the
IAEA.
During
the
period,
however,
the facility was not required
by the license to fulfill
the
requirements
of the
and
there
was
a difference
in
perception
of the
requirements
between
the licensee,
IAEA, and
the
HRC.
No violations were identified during this period.
. Conclusion
Category:
2
Trend:
3.
Board Recommendations
None
K.
Training and gualification Effectiveness
1."
Analysis
During this
SALP reporting period,
several
routine
and reactive
inspections
were conducted
in the area of training at the Turkey
Point facility.
In addition,
replacement
and requalification
examinations
were
conducted
in
September
and
December
1986.
During the last
SALP period,
major deficiencies
identified in
41
the area of training have included
an inadequate
training staff,
a
lack of
con inuing train'.ng
for ma'ntenance
personnel,
an
nsat,sfactory
Licensed
Operator
Requalifica.ion
Program,
General
Employee
Training
(GET)
deficiencies,
programmatic
deficiencies
in the Required
Reading
and Operational
Experience
Feedback
Programs,
and
Emergency
Operating
Procedure
(EOP)
training deficiencies.
In addition,
an
internal
assessment
conducted
by the licensee
in June
1986 identified
165 specific
training deficiencies.
In the previous
SALP report it was
stated
that
an
inadequate
number of instructors
and training staff have
had
a significant
nega-ive
impact
on training, testing,
and documentation.
The
continuing
maintenance
training
was
discontinued
for
over
a
year
to allow the
small
training staff to
support
the
acc. edita.ion
effort.
Licensed
operator
requalification
was
staffed
by
a
minimal
staff
responsible
for
development,
instruction, testing,
scheduling,
and documentation.
Based
on
their poor performance
on
an
NRC requalification examination
in
February
1986,
the
licensee's
Requalification
Program
was
determined
to
be unsatisfactory.
Numerous
deficiencies
were
also identified in the testing
and documentation
associated
with
'.raining,
and
those
deficiencies
appeared
somewhat
attributable to an inadequate
training staff.
The licensee
has
increased
the
size of the training staff from
35
in April
1986,
to
58
in
February
1987.
Three
program
supervisor positions
have
been established
which report directly
to the Training Superintendent.
The program supervisor positions
for
Operations
and
'thai ntenance
Training were'illed
with
incumbents
from the in-plant organization,
thus
increasing
the
experience
levels within the Training Depar men'anagement.
The
simulator
training staff will consist
of
a
Simulator
Engineer
Coordinator,
who is
a contract individual, four support
specialists,
and two instructors.
The only instructor
assigned
at the time of the February
1987 inspection
was
a supervi sor who
had
been
unsuccessful
on
the
recent
NRC
requalification
examination.
This simulato'r staff does
not appear
adequate
to
supp'ort curriculum development for simulator delivery this year,
or to provide simulator instruction for hot license
and license
requalification training.
While the overall
numbers of training staff have
been
increased,
the licensee
was critically short of qualified instructors for
Licensed
Operator
Requalification Training.
Two of the
three
instructors
assigned
to
requalification
training
were
licensed,
but
had
recently
failed
NRC
requalification
examinations.
Several
other
instructors
who
had failed
NRC
requalification
programs
were
permanently
reassigned
to other
42
JUL 1'7
1987
du.ies.
The
utilization
of
instructors
who
have
failed
requalification
examinations
to prepare
licensed
operators
for
th
same
type of examination
jeopardizes
the effectiveness
of
the
Upgrade
Requalification
Program
and
undermines
student
confidences
As
an interim solution to the instructor shortage,
the licensee
was utilizing contract instructors
in the
Upgrade/
Accelerated
Licensed
Operator
Requalification
Program.
Contract
instructors,
however,
were found to be lacking in plant specific
knowledge.
Utilizing contract instructors to teach
systems
and
integrated
plant
response
without si e-specific
knowledoe
or
training prevents
them from being able to provide plant specific
information.
During most of 1986i
Turl ey Point
embarked
upon
an accelerated
requali fication
training
program.
All'icensed
operators
were
removed
from licensed
duties until they
passed
an
HRC
administered
requalification
examination.
These
examinations
were administered
in April, September,
and
December
of
1986.
The
overall
oass
rate
was
63;;.
The
NRC's criterion
for
evaluating
a facility's requalification
training
program
as
unsatisfactory
is below
60.'o'.
Contributing factors to this lack of performance
appeared
to be
the shortage
of qualified instructors
and instructors
working
excessive
overtime,. the utilization of upgrade
requalification
participants
for in-plant overtime,
and
an apparent
inadequate
evaluation
and identification of the specific
knowledge
areas
requiring
upgrade
training.
An additional, contributing factor
to this relatively
low
pass
rate
was
that
those
licensed
individuals
associated
wi:h
the facility'
training staff
achieved
only
a
14
pass
rate.
If these
individuals
are
extracted
from the overall results,
then
a
75ro
success
rate,
representing
those individuals in Turkey Point's
operations
and
technical
support staffs, is observed.
This indicates that the
accelerated
program
was marginally effective in correcting
noted
deficiencies
and
improving the overall
knowledge
1 vel for the
licensed
operators
in these positions.
The
Operational
Experience
Feedback
and
Required
Reading
Programs
continue
to experience
problems.
Operating
Experience
Feedba'ck
Training control
has
been
improved
due to management
attention
to
documentation
and
timely
disposition
of
info'rmation.
The program,
however,
was apparently
unsuccessful
in responding
to prior information
on the boric acid/conoseal
leak and the nitrogen intrusion into the boric acid system.
43
JUL l7
1981
The
number
of
procedure
revi sions
being
generated
by
the
Procedure
Upgrade
Program.
including
minor
administrative
changes,
had virtually inunda'ed
the
operators
with
a
large
volume
of
material
to
review
and
seriously
impeded
the
effectiveness
of the
required
reading.
In
response
to
NRC
concerns,
the
Required
Reading
Program
had
been
effectively
revised to provide the operators
with a synopsis of significant
procedural
changes
vice
a
de ai led
review of all
procedure
changes.
As
noted
previously
in this
SALP,
the
licensee
has utilized
non-licensed
ins ructors
who
have
not
attended
a
licensed
opera
or training or received site specific training.
An audit
of the records for the current instructor Certification Program
revealed
disorganized
and
incomplete
records with records
such
as
lesson
plans
and instructor in-plant training time missing.
While the licensee
has conducted
an instructor job tasl
analysis
to be used. in their new four phase,
performance-based
instructor
Developement
and Certification Project,
the existing program
and
its documentation
lacked adequate
management
attention.
Early in the
SALP period,
the licensee
conducted
an internal
assessment
o: the Training
D partment.
Thiis licensee-initiated
review
was
very beneficial
in .uncovering
deficiencies
and
potential
problem
areas.
An
NRC
inspection
conducted
in
November
1986 revealed that although the assessment
was thorough
and
comprehensive,
the
licensee
was
slow in taking corrective
action,
especially for
some of the
more serious
deficiencies.
Several
discussions
and meetings
with regional
representatives
resulted
in
accelerated
closeout
of
the
identified
problem
areas.
A tracking
system
is
in
place
for monitoring
the
close-out
of
ac ion items associated
wi
h identified training
deficiencies.
The completion of this activity is instrumental
'in the
success
of the Training Department's
Quality Improvement
PrografA/
Quality
in
Daily
Work
(QIP/QiDW)
programs.
By
November
15,
1986,
nine
items
which were classified
by the
licensee
as regulatory
in -nature
had
been
closed
out,
and
by
January
15,
1987,
35
additional
items
had
been
closed.
Completion of the training audit action
items
is progressing
ahead of the projected
schedule.
Additional
long-term
programs
were
in the
early
stages
of
implementation,
but
should
provide
a positive
impact
on
the
quality of training at the licensee.
These
programs
include the
following:
(1)
Training Assurance
Program
(TAPS)
(2)
Training Information Management
System
(TRIMS)
(3)
INPO Accreditation Effort
JUL 1'7
1987
The
TAPS
program
is charged
with moving the Nuclear Training
Sys.em
from
a reactive
to
a proactive
mode of operation.
The
TRIMS program
involves
a method to identify tracking
needs
by
the review of change-indicators,
and to track both internal
and
external
change
indicators,
documenting
the
use
of
the
systema.ic
approach
to iraining (SAT) process.
As of January
1987,
1,229
items of instructional
materials
had
been
entered
into
he
system.
This
data
base
allows efficient
use
of
available
data
for training
cour ses,
e.g.,
Licensee
Event
Reports
( LERs), Significant Operating
Event Reports
(SOERs),
and
Operating
Event Reports
(OERs) student
feedback.
Due to the
NRC/INPO Memorandum of Understanding
with regard to
training programs,
no violations were issued during this period.
2.
Conclusion
Category:
3
3.
SALP Board Recommendations
Turkey
Point
has
made
limited
improvements
in the
area
of
training
through
increases
in
management
controls,
implementation
of
performance
based
continuing training for
maintenance
personnel,
and preparation
for
IHPO accreditation.
The
licensee
management
has
not,
however,
provided
adequate
attention
to
and
control
over
the
Licensed
Operator
Requalification
Program.
Continued
NRC and licensee
management
attention
in this area is recommended.
L.
Engineering
Support
1.
Analysis
This functional
area
is
included
in this =SALP report
since
licensee
activities
and
HRC
inspections
showed
significant
contributions to many other areas
of licensee
performance.
This
area
was
evaluated
through
routine
and
specific
resident
inspections,
regional
review of Safety Evaluations
(SEs),
and
a
special
inspection
conducted
by the
regional
gA Section
in
May 1987.
The concerns
in the area of Engi'neering
Support were highlighted
in Enforcement
Action 86-20 dated August 12,
1986.
As
a result
of the
SSFI conducted
in 1985, six violations were cited in this
enforcement
action
with
an
accompanying
Civil
Penalty
of
$300,000.
Two of the violations were directly attributable
to
Engineering
Support:
Design
Control
and
inadequate
SEs,
while
engineering
functions directly contributed
to
several
others.
Previous
enforcement
actions
in
1984
and
1985
also
involved
examples of inadequate
and failure to control
PC/Ms.
45
JUL l '7
1987
In
a letter dated October
1,
1986,
FPL responded
to
EA 86-20
and
delineated
numerous
correc ive actions,
completed
or planned,
'.",=-: addressed
each
of the six basic
areas
identified in the
No ice of Violation.
With regard
to the
functional
area
of
Engineering
Support these corrective actions included:
1)
Phase II Select
System Safety
Review
2)
Standard
Engineering
Design
Package
for Controlling Plant
Changes
3)
Reoroanization
of the
engineering
function
and
increased
s-.affing
of
both
the
engineering
and
technical
organizations
at, the plant.
'4)
Traininc
o> technical
personnel
and management
attention to
the
new plant modification process.
The majority of the
Phase II Select
System
Review
has
been
completed
for
the
14
systems.
This
extensive
effort
has
included:
reconstitution
of design
bases,
system
walkdowns,
Safety
Engineering
Group
(SEG)
comprehensive
review
and
an
enhanced
configuration
management
program.
The
implementation
of the effort has
been effective
and
has
required significant
resources.
The
review
effort
has
identified
numerous
deficiencies
in
system
design
to
which
the
Engineering
Departments
have
responded
promptly
and
adequately.
Examples
include;
identification of
emergency
diesel
generator
loading
limitations,
the
absence
of containment
spray
flow limiting
orifices,
the
potential
for safety
injection recirculation
valves to fail in a non-conservative
position,
the potential for
electrical
relays
to prevent proper diesel
operation,
potential
ventilation system failures,
and
the
need
to expedite
the post
accident
recirculation
initiation.
The
Engineering
Departments,
both site
and corporate,
have
responded
to these
deficiencies with careful
analyses
and
sound short term and long
term corrective action proposals.
Electrical modifications were
completed
in August
1986 to preclude
the potential
for diesel
overload.
Containment
Spray flow orifices were installed in May
1987
to preclude
the possibility of
pump
runout.
Emergency
procedures
were revised
to require
post accident recirculation
initiation without
delay.
Temporary
procedures
.have
been
developed
to
supply inverter ventilation in'he
event
of
a
sustained
Modifications
have
been
made
to the Unit 3 Component
Cooling Water heat
exchangers
to allow
continuous
online
cleaning.
The
Unit 3
safety
injection
recirculation valves
have
been modified so that the flow path is
not
susceptible
to
a
single
failure.
Numerous
additional
improvements
are
being
developed
by the engineering
staff for
future implementation.
46
JUL
1 '7
1987
A significant initiative of the engineering
organizations
was
the
developmen
of
a
Standard
Engineering
Design
Packace
to
control
he
manner
in which plant modifications
a. e developed
and
implemented;
By standardizing
the format,
content,
review
process
and
approval
mechanisms
the
licensee
has
reduced
the
potential
for
changes
to
have
adverse
affects
on
the plant.
Included
in the design
package
are
requirements
for procedure
and drawing reviews to ensure
hat modifications
have
been fully
completed prior to system turnover for operation.
The Standard
Engineering
Design
Package
has
been
recognized
by the Institute
for Nuclear
Power Operations
(INPO) as
a good practice worthy of
consideration
for use
by other industry organizations.
The site engineering
function
was
reorganized
in early
1986 to
create
the position of Site Engineering
Manager
and to increase
site
staffing.
In
addition
to
the
Site
Engineering
organization,
there
is
a
functionally
separate
Technical
Department
that
reports
directly to the
Plant
Yianager.
The
staff allowance for this Technical
Department
was also increased
to provide additional
system
engineers.
This
has
reduced
the
qumber of systems
assigned
to each
engineer
and
increased
the
level
of attention
to
design
control
with respect
to
each
individual
plant
system.
Th se
organizational
and staffing
improvements
enabled
the engineering
organizations
to respond to
requests
for assistance
in
a
more effective manner
and allowed
more complex issues
to be pursued
by site rather
than corporate
personnel.
Enhanced
training
of
technical
personnel
and
increased
management
attention
have also
been evident
and are discussed
in
the training and
gA sections
of this report.
'While
many
engineering
problems
have
been
identified,
compensated
for in the
short
term
and
apparently
corrected
programmatically,
some deficiencies
have
been evident.
In March
1987,
an
NRC Augmented Inspection
Team (AIT) began
a review of
the
consequences
of the licensee's
decision to operate
the Unit
4 reactor with a small instrument
seal
(conoseal)
leak which had
been
identified
in
August
1986.
The
Engineering
Department
issued,
on August 30,
1986,
a safety evaluation
which considered
the
leakage
minor, within Technical
Specification limits,
and
recommended
that
the
leaking
conoseal
be
reinspected
in six
months
and
repaired
during
the
next
available
shutdown
of
sufficient length.
The safety evaluation
was
approved
by the
Plant
Nuclear
Safety
Committee
on
August 31,
1986.
Between
August
1986
and
March
1987,
a
large
amount
of boric
acid
accumulated
on the reactor
vessel
head
and resulted
in c'orrosion
damage
to surrounding
equipment
and
components.
Analysis
and
repair resulted
in an extended Unit 4 outage.
JUL 1'7
1987
The AIT determined
that
the engineering
safety evaluation
used
'.o justify reactor operation
was deficient in that it:
was
not
based
on
a detailed
inspection
of the leaking component;
based
corrosion
calculations
on
a
non-conservative
corrosion
rate;
failed
to
evaluate
the effects
of corrosion
on
surrounding
components
and equipmen
- and was performed in
a hurried
manner
without
complete
and
comprehensive
supervisory
review.
In
add',:ion,
the
engineering
inspection
review
of
the
leaking
conoseal,
a month
and
a half after discovery, failed to consider
the
ex ensive
spread
of boric acid residues
on
and
around
the
reactor
vessel
head
area.
Proposed
violation (f) below
was
issued
concerning
this deficient
safety
evaluation.
Also,
a
re iated
violation
(g)
was
proposed
for fai lure
to properly
adhere
to tne drawing accuracy/control
of the conoseal.
The licensee's
program for recovery
from the leakage
even
was
very complehensive.
An hRC review of the licensee's
engineering
analysis of the event,
including safety significance resulted
in
concurrence
in
the
reactor
restart
plan.
However,
some
prompting
as to the level of detail
expected
from the licensee
in its event evaluation
was
necessary
when the AIT arrived
on
site.
Programmatic
improvements
in the area of leak detection,
engineering
analyses,
and corrective actions
have
been developed
and implemented.
Violation (c)
below
documents
two
examples
when
the
safety
significance
of discrepant
conditions
was
not, evaluated
in
a
timely manner.
In each
case,
several
weeks
elapsed
between
the
discovery of the condition
and the initiation of an engineering
review to determine
the
consequences
of the condition.
In the
interim,
the operability of the
equipment
was
not established
because
he
plant
staff
did
not insist
on
an
engineering
assessment
and
the
engineering
staff
was
not
procedurally
required
to
supply operability determination,
either
oral
or
writ~en.
Subsequently,
in early
December
1986,
engineering
procedures
were
approved
and
implemented
which require written
operability
assessments
within three
days of the receipt of
a
nonconformance
report.
This
represented
the first
formal
procedural
guidance
implemented
for
the
Site
Engineering
Department
subsequent
to its establishment
in
February
1986.
Between
February
and December
1986 draft versions of procedures
were circulated but compliance
was left to the discretion of the
individual engineers.
Violation
(e)
below
documents
an
example
where
inadequate
inspection
and analysis
were
performed relative to
an
observed
deficiency
in
a safety related
As
a result,
the
discrepant
condition existed for several
months
before it was
determined
to
be
symptomatic
of undesirable
internal
valve
degradation.
Inspection
of similar
valves
revealed
multiple
48
JlJf 17
1987
examples
of internal
degradation
different in type
and origin
than those previously
known to exist.
All valves
were
replaced
wi.h
an
improved
design
which
reduces
the
potential
for
recurrence.
Violation (b)
was
issued
in
1986
but
is
based
on
a
1984
Unr'esolved
Item concerning
a failure to perform
a
evaluation
on the throttling of an
RHR discharge
valve.
Turkey Point is
considered
by
NRC Region II staff to
have
a
reasonably
effective
program
with
regard
to
environmental
qualification (Eg) aspects.
This
may
be the result of lessons
learned
from
an earlier
inspection
performed
at
FPL's
other
nuclear
site
(St. Lucie).
In
February
1987,
a
special
team
inspection,
by the
IRE Vendor Program
Branch
was performed
Turkey
Point
to
examine
the
licensee's
program
fol
establishing
Eg of electrical
equipment
within the
scope
of
Using enforcement criteria specified
and 86-15 several
potential
Enforcement/Unresolved
Items
and
Open
Items were identified.
An
NRC
Team
inspection
in
February
1987
revealed
that
many
Requests
for
Engineering
Assistance
(REAs)
remained
open
approximately
525 and that these
numbers
were still increasing.
This
was attributable,
in part,
to the increased
confidence
in
Site
Engineering
Office by various
plant
groups,
and
to
the
extensive
plant modifications taking place.
It should
be noted
that
a high percentage
of the
open
REAs were
a year or more old
and
had not been
the object of any action or review.
Several
additional
concerns
with
Engineering
,Support
were
identified
during
tne
period.
Inspector
review
of
JPE"L-85-38,
"Substantial
Safety
Hazards
Evaluation
for
System
Design",
identified
a
potential
operability
problem.
This
SE apparently
au'horizes
the operation
of the plant with
the Intake Cooling Mater (ICW) system outside its design
basis.
Due
to
fouling of the
heat
exchangers
and
elevated
Intake
Cooling Mater temperature
there
are
times
when the
ICM system
may
not or
has
not
been
capable
of performing its
intended
safety function during
a design
basis
accident
and
assuming
a
single
active failure.
The
has
been
forwarded to
NRR for
further
evaluation
and
for possible
generic
considerations
concerning fouling of service water systems.
During
an inspection
conducted
in January
1987
in the
area
of
seismic
analysis
for as-built safety-related
piping,
supp'orts,
etc,
the
inspector
had
several
unresolved
items
(URIs).
These
concerned
the
failure
to
identify
and
to
evaluate
discrepancies
that
could
potentially
have
affected
the
49
JUL I7
1987
operabi
1 i y of
the
Component
Cool ing
'l4ater
(CCl'!)
sys
em.
Although the
have
not yet
been
closed
out,
corrective
ac ion
by
the
licensee
was
only
.aken
after
prompting
by
regional
management.
The
Res dent Inspectors'eport
for March and April 1987 de.ai ls
two
proposed
violations
concerning
electrical
wiring
discrepancies
in
the
Emergency
Diesel
Generator
(EOG)
load
sequencers
and protective
relays.
The latter
discrepancy
was
identified first during routine
surveillance
testing
and
was
attributed to the generation
of an incorrect connection
diagram
developed
as part of a
PC/M package.
Violation (h) was proposed
in
response
to this
problem.
Additional
inspections
were
conducted
by
the
licensee
to determine if any
other wiring
discrepancies,
existed that were related to work performed
under
this
PC/M.
The inspection
revealed
two problem areas
in the
3B
load sequencer.
The root cause
of one wiring error has not yet
been
found while the other cause
was attributed to an incorrect
Process
Sheet.
Proposed violation (i) addresses
this error.
In
response
to
these
various
concerns
over
the
Engineering
Support function,
a special
announced
inspection
was
conducted
in
May i9S7.
Areas
inspected
included engineering
procedures,
controls
for
engineering
evaluations,
and
a
review
and
assessment
of
engineering
evaluations.
In
the
area
of
engineering
procedures,
the inspectors
found that
the licensee
had
established
adequate
engineering
procedures
for
the
performance
of safety evaluations
associated
with
requirements
related to plant modifications, justifications for
continued
operations,
and
controlled
plant
work
orders.
However,
requirements
for the
assessment
of the
effects
of
nonconforming
conditions
on safety-related
equipment
function,
performance,
reliability
and
response
time
had
not
been
explicitly defined.
At the conclusion of the
SALP period, the
licensee
was
in
the
process
of
revising
procedures
that
delineate
the
administrative
controls
for
processing
nonconformance
reports.
Based
on
the
sample
reviewed,
the
licensee
appeared
to
be
performing
an
adequate
job of performing
safety
evaluations
associated
with plant change/modifications,
justifications for
continued
operations,
and controlled
plant
work orders
with
regard to the effect of the change or activity on safety-related
equipment
function,
performance reliability, and response
time.
Most,
safety
evaluations
adequately
addressed
critical
engineering
design
requirements, where applicable
such
as single
failure criteria, separation criteria,
and seismic requirements.
In
a
related
area,
improvement
was
apparent
in
the
site
engineering
organizations disposition of nonconformance
reports
50
Jgg gg
1987
with respect
to roo.
and pos.-modification
sta+'.stica'.
sampling
SALP period which did
cause
analysis,
corrective
action plans,
testing.
This conclusion
was
based
on
a
of nonconiormance
reports
covering thi s
not identify any deficiencies.
ive violations were identified:
Severity
Level
IV violation with four
examples
of
incorrect diesel
generator
drawings
due to incomplete
iield veri iication.
(86-25)
Severity
Level
IV violation for failure to evaluate
valve
modi iications for unreviewed
safety
question.
(86-44)
Severity Level IV viola.ion for failure .o assure
that
conditions adverse
to quality were promptly corrected;
two examples - support
hangers
not properly
assembled
and
emergency
diesel
generator
air receivers
not
properly bolted to the floor.
(86-45)
Severity
Level
V violation for incorrect
steam
break
protection logic drawings.
(86=33)
Severity
Level
V violation ior failure to take prompt
corrective action to identify and correct
damaged
(Unit 4 only, 87-06)
The following four violations are
under consideration
for
escalated
enforcement
actions:
Proposed violation for inadequate
safety evaluation
on
conoseal
boric acid leak.
(Unit 4 only, 87-16)
9.
Proposed
violation
for
insufficient
iniormation
regarding
conoseal
in
procedure
for
the
installation
of
reactor
vessel
head
conoseals.
(Unit 4 only, 87-16)
Proposed
violation for failure to
have
and accurate
connection
.diagram
for safety
related
EDG wiring.
(87-14)
Proposed
violation for failure to maintain
adequate
control of design
changes
affecting the
3B
EOG load
sequencer
.
(87-14)
2.
Conclusion
Category:
51
JUL 17
1S87
3.
Board Recommendation
The
Board
',s
concern
d
hat although
the engineering
support
programs
have
been substantially
improved, there exists
a large
number
of request
for engineering
assistance
over
a year
old
that
remain
open with no action or review.
In addition several
significant examples
of engineering
evaluation
or modifications
have
resulted
in the operation
of the facility with degraded
sa:ety
related
equipment.
Additional
NRC
and
licensee
management
attention
in this area is recommended.
V.
SUPPORTING
DATA AiND SUMMARIES
A.
Licensee Activities
During
he
assessment
period,
Unit 3 was in routine commercial
operations with a refueling
outage
from March ll, 1987,
to the
end of the
SALP period.
Other outages
included those
discussed
under
Item J
Reactor
trips
and
an
outage
to
perform
modifications
required
for
Emergency
Diesel
. Generator
load
considerations
from July 15,
1986
to
August 5,
1987.
The
present
refueling
outage
began
one
week early
due to problems
w'.th the turbine-generator
hydraulic .oil
system
and
has
been
extended
about
two months
due to the
Raychem
splice
issue
and
the cracks
found in the Post Accident Hydrogen Monitoring sample
line:
Unit 4 remained
in
a refueling
outage
at the beginning of the
assessment
period
due
to
overload
concerns
and
modifications.
Commercial
operation
was
conducted
from
September
1986 until March 10,
1987,
when it was
shutdown
due to
a failure of the
personnel
hatch
to meet
con ainment integrity,
and
has
remained
down through the remainder of the
SALP period,
due to discovery of excess
boric acid buildup
on the reactor
vessel
from a conoseal
leak.
Replacement
of Raychem splices
has
also extended this outage.
B.
Inspection Activities
The routine inspection
program
was performed during this period, with
special
inspections, conducted to augment
the program
as follows:
1.
April 28 -
May 2,
1986,
in
the
area
of the
control
and
distribution of electrical
loads
which are
connected
to the
emergency
diesel
generators
in the
event
of
a
design
basis
accident.
2.
June
10
and
August 18,
1986,
involving
physical
security
concerns
observed
by
the
Resident
Inspector
relative
to
protected
are barriers,
gates
and compensatory
measures.
'52
JUl. rV >S87
July 22-26,
1986,
in the
areas
of modifications
in elect. ical
loads
for emergency
diesel
generators
(EDGs)
and
integrated
safeguards
testing
associated
with modifications
and
EOG load
evaluation.
4
5.
September
28-29,
1986,
involved
a review of scaffolding which
provided
a pathway from the protected
area into
a vital area.
november
17-21,
1986,
in the area of training.
'I
January
20-21,
1987,
a review of the circumstances
of a licensee
reported incident of failure to,provide positive access
control
to
a vi al, area
as
a result of a posted security officer being
asleep
on post.-
March 2-6,
1987,
in the area of equipment qualifications.
February
16-21,
1987,
to assess
plant operations
in four major
assessment
areas
which include
maintenance,
operations,
plant
management
controls
and training.
March
19 - May 5,
1987,
an Augmented Inspection
was conducted to
monitor the lic nsee's
response
and to review the circumstances
associated
with
a
problem
identified
by
the
licensee
with
corrosion
caused
by deposits
of crystalline boric acid
on the
reactor vessel
head
and surrounding
areas.
10.
April 28 - May 1,
1987, in the area of followup on worker health
physics
concerns.
May 11-15,
1987,
in the
area
of Engineering
Support
and Safety
Evaluations.
12.
May 18-.29,
1987,
in
the
area
of performance
of
a
loss
of
off-site
power testing
on
both units with
a loss of coolant
accident
on one unit.
C.'icensing
Ac ivities
The
basis
for this
appraisal
was
the
licensee's
performance
in
support
of licensing
actions
that
were either
completed
or
had
a
significant
level
.of activity during
the
rating
period.
These
actions
consisted
of
amendment
requests,
exemption
requests,
responses
to generic
letters,
TMI items,
and
other
actions.
The
numbers of closed licensing actions
can
be
summarized
as follows:
Active actions at beginning of period (6/1/86)
Actions added during. period
Total actions
Completed actions during period
Active actions at end of period (6/31/87)
76
28
104
64
40
53
JUL 1.7
1987
The
64 actions
completed during this
SALP period
can
be divided into
three major cateoories.
The
number of actions
which were
completed
for each category
are:
Plant specific actions
Multi-plant actions
TMI actions
34 completed
16 completed,
14 completed
1.
Licensing Actions Completed
During This
SALP Period
ASME Code
Case
N-416
Item 4. 1 Reactor Trip System
(RTS) Reliability
Item 4.5. 1 -
Item III.A.1.2,
Emergency
Response
Facility
(ERFs)
Item III.A.2.2, Meteorological
Upgrade
TMI Order Modification (July 15,
1985 Order)
Environmental qualification (Eg) - Clarification
Code
Case
N-411
Use at Turkey Point
Item II.K.3.31, Small Break
Load Evaluation
Item I.D. I, Control
Room Design
Review
Emergency
Diesel Generator Reliability
Containment
Purge/Vent
Items
3. 1. 1
and
3. 1.2,
Post
Maintenance
Testing
(RTS Components)
Items 3.2. 1
and 3.2.2,
Post
Maintenance
Testing
(All Other Safety-Related
Components)
Component Cooling Mater Flow Balance
PTS Rule (10 CFR 50.61)
,54
JUL
1 7
1987
2.
HRR-Licensina Yieetin
s
%ubga~t
USI A-44 Station Blackout,
Bethesda
Physical Security,
Bethesda
. Technical Specification
Upgrade,
Bethesda
Integrated
Schedules,
Atlanta
3.
HRR Si
e Visits
Subject
Performance
Enhancement
Program
50.59
Review
R Licensing Activities
Boric Acid Leak Evaluation
SPDS Implementation Audit
4.
Commission Briefin
Hone
Date
9/3/86
9/12/86
11/18/86
2/19/87
Date
5/28-30/86
12/8-10/86
3/20-22/87
3/23-26/87
Subject
Boric Acid Leak Event
6.
Schedular
Extensions
Granted
Subject
50.48 Schedular.
Exemption
Appendix
R
Surveillance
Report
Schedular
Exemption
7.
Reliefs Granted
IST Relief - Spent
Fuel
Pool Cooling
Pumps
IST Relief
ISI Relief - Safe
End Welds
Date
4/10/87
Date
6/9/86
8/25/86
9/18/86
10/9/86
2/13/87
55
JUL 1'7
1987
8.
Exemptions
Granted
one
9
~
License
Amendment
Issued
Amendment
Nos.
Subject
Date
116/110
117/111
118/112
Snubber Technical Specifications
5/6/86
Per
Use of Burnable
Poisons
7/14/86
LCO and Survei1 lance
Non Safety
8/13/86
Standby
System
119/113
120/114
ISI Program - Second
10 Year
Diesel
Generator
Inspections
(Exigent Amend)
10/27/86
11/10/86
121/115
122
Cont~ol
Room Habitability
2/2/87
Extend Surveillance
- Containment
2/12/87
Filter System
(Emergency
Amend)
123/116
Reporting
Requirements
and 50.73
3/6/87
117
IAEA Safeguards
License Condition
4/10/87
D.
Investigation
and Allega.ion Review
No major investigations
were
conducted
at Turkey Point during this
appraisal
period.
E.
Escalated
Enforcement Actions
1.
Civil Penalties
Six Notices of Violations (Severity
Level III, Supplement
I) and Proposed
Imposition of Civil Penalty
(EA-86-20) for
a total of $ 300,000
was issued
on August 12,
1986, for the
following:
1) significant
weaknesses
identified in the
design
control
program;
2)
Failure
to
satisfy
the
requirements
of 10 CFR 50.59;
3) significant violation of
Technical
Specification
(TS)
Limit,ing
Conditions
for
Operations
(LCOs);
4) identified weaknesses
in procedural
control
program;
5) fai lure
to
conduct
adequate
load
capacity
testing
and
monthly
surveillance
tests
of
safety-related
batter ies and;
6) failure to take prompt and
comprehensive
actions
once deficiencies
were identified.
This violation,
although
issued
during
the current
peri.od,
was addressed
in the previous 'SALP analysis.
A Notice of Violation (Severity
Level III, Supplement
I)
and
Proposed
Imposition of Civil Penalty
(EA-86-28) for
$50,000,was
issued
June
25,
1986, for inadequate
testing
and
failing
to
satisfy
an
NRC
order
regarding
the
operability of
a neutron flux detector
system
on Unit 3.
This violation,
although
issued
during
the current
period.
was addressed
in the previous
SALP analysis.
A Notice of Violation (Severity
Level III, Supplement
IV)
,and
Proposed
Imposition of Civil Penalty
(EA-86-38) for
$ 50,000
was
issued
on
April 28,
1986,
for
radiation
exposure
control
problems
associated
with
maintenance
activities
on the Unit 3 traversing
incore probe
system
on
January
8,
1986.
The licensee's
request
for mitigation of
the Severity
Level
and Civil Penalty resulted
in the Civil
Penalty being mitigated
on October
14,
1986 to $25,000
and
the
Severity
Level
remained
unchanged.
This violation,
although
issued
during
the
current
period,
was
addressed
in the previous
SALP analysis.
C
A No ice of Violation (Severity Level III, Supplement III)
and
Proposed
Imposition of Civil Penalty
(EA-87-40) for
$75,000
was
i ssued
April 21,
1987, for physi cal
securi ty
i ssues.
e.
T.
A proposed
violation with an associated
Civil Penalty for
inadequate
Safety
Evaluation
concerning
a
boric
acid
conoseal
leak
on Unit 4.
A proposed
violation with an associated
Civil Penalty for
failure to maintain access control'f a vital area.
Orders
An order
imposing
a civil monetary
penalty
was
issued
on
October
14,
1986;
as discussed
in paragraph
E. l.c above.
An order updating
the
Performance
Enhancement
Program
was
issued
on August 12,
1986, this is in relation to paragraph
E. l.a above.
57
JUg ] g
1S87
F.
Licensee
Conferences
Held During Appraisal
Period
1.
May 9,
1985,
Enforcemen.
Conference
to discuss
Turkey Point
issues
related
to
Component
Cooling Mater
and Intake Cooling
Vater issues.
2.
May 20,
1986,
Management
meeting
to discuss
emergency
diesel
generator
loading.
3.
May 29,
1986,
Management
meeting to discuss
PEP progress.
4.
August 18,
1986,
Enforcement
Conference
to discuss
protected
area
boundary control.
5.
September
11,
1986,
Management
meeting
to discuss
Board
Assessment
and
PEP progress.
6.
September
23,
1986,
Management
meeting
to
discuss
the
construction of the
NRC and
FPL administered
operator
licensing
examinations.
7.
October
1,
1986,
Enforcement
Co'nference
to discuss
vital area
boundary control.
8.
October 29,
1986,
Management
meeting
to discuss
the integrated
,schedule,
general
employee
training
examinations
grading
and
resolution of items
on Region II's outstanding
items list.
9.
December
16,
1986,
Management
meeting
to discuss
corrective
action for training deficiencies.
10.
February
19,
1987,
Management
meeting
to discuss
the
Proposed
License
Amendment
on Integrated
Schedule.
11.
February
23,
1987,
Enforcement
Conference
to discuss
security
issues.
12.
May 14,
1987,
Management
meeting
to discuss
Operator
License
Training.
G.
Confirmation of Action Letters
(CALs)
NONE
58
Jgg
] y
1987
H.
Licensee
Even. Report Analysi s
During the assessmeht
~e.'.od
57
LERs for Units
3 & 4 were analyzed.
The distribution of these
events
by cause,
as determined
by the
NRC
staff,
was
as follows:
Cause
Component Failure
Design
Construction,
Fabrica ion, or
Installation
Personnel:
-,Operating Activity
- Maintenance Activity
- Test/Calibration Activity
- Other
Out of Calibration
Other
Unit 3
Unit 4
Total
5
14
19
5
1
3
6
11
2
TOTAL
31
26
57
I.
Enforcement Activity
UNIT SUMMARY
FUNCTIONAL
NO.
OF DEVIATIONS AND VIOLATIONS IN EACH
AREA
SEVERITY LEVEL
D
V'V
III
II
I
UNIT NO.
-
3/4
3/4
3/4
3/4
3/4
3/4
Plant Operations
Radiological Controls
Maintenance
Surveillance
.Fire Protection
Emergency
Preparedness
Security
Outages
equality
Programs
and
Administrative Controls
Affecting (}uality
Licensing Activities
Training
Engineering
Support
TOTAL
2/1
9/7
1/1
3/3
1/1
2/2
1/1"
1/1
1/1
1/1
1/1
7/7
2/2
1/2
3/3
I/I+
59
><< >q le~!
FACILITY SUMMARY
FUNCTIONAL
AREA
HO.
OF DEVIATIONS AND VIOLATIOHS IH EACH
SEVERITY LEVEL
D
V.
IV
III
II
.
I
Plant Operations
Radiological Controls
Maintenance
Surveillance
Fire Protection
Emergency
Preparedness
Security
Outages
Quality Programs
and
Administrative Controls
Affecting Quality
Licensing Activities
Training
Engineering
Support
TO:A'
9
1
3
1
3
1
1
1
1
7
2
3
(")An additional
apparent
violations
(one
in Maintenance,
four in
Engineering
Support,
one
in Surveillance,
and
one
in Security
and
Safeguards)
was issued after the
end of the
SALP period
as discussed
in the text of this report.
Eigh- unplanned
reactor
rips and
one manual
shutdown occurred during
this evaluation
period for Unit 3.
Unit 4 sustained
five unplanned
trips
and three
manual
shutdowns.
The unplanned trips and
shutdown
are listed below.
1.
Unit 3
a.
May 2,
1986,
the reactor tripped from 100 percent
power due
to operator error while performing the
Reactor
Protection
Periodic Test.
b.
June
27,
1986;
the reactor tripped from'00 percent
and
a
Safety Injection actuation
occurred
due to Instrumentation
and Control personnel
while performing the
Steam
Generator
Protection
Channels
Periodic Test.
August 3,
1986,
the unit was
shutdown
from
1 percent
power
due to train
2 of Auxiliary Feedwater
(AFM) being declared
out of service
on the failure of a ARl flow control valve.
60
gag ] y
1981
August 13,
1986,
the reactor tripped from 53 percent
power
due to spurious
actua.ion
of the Pressur'.zer
Low Pressure
Chanrel
logic.
The actuation
was apparently
caused
by
a
lighting strike.
September
21,
1986,
the reactor
tripped
from
100 percent
power
due to personnel
error while performing
a Secondary
Plant Periodic test.
December
27,
1986,
the reactor
was manually tripped due to
a
loss
of turbine
governor oil
system
pressure
and
a
subsequent
rapid electrical
load decrease.
January
12,
1987,
the reactor tripped during
a rapid load
reduction
due to low pressurizer
pressure.
February
15,
1987,
the reactor tripped from 7 percent
power
due to personnel
error while performing adjustments
on the
turbine governor control oil system.
March 6,
1987,
the
reactor
was manually tripped
from 95
percent
power due to malfunctioning turbine governor.
2.
Unit
August 5,
1986, the reactor tripped from subcritical
power
.
levels
due to
a procedure error while personnel
performed
a
temporary
procedure
to
functionally
test
a
plant
modification
on
the
Turbine
Runback
arid
Power
Mismatch
systems.
August 21,
1986,
the- reactor
was
shutdown
to repair
an
Steam
Supply Valve.
August 23,
1986,
the reactor
was manually tripped from zero
percent
power but critical due to dropped
rods caused
by a
24 volt DC power
supply failure.
September
.6,
1986,
the
reactor
tripped
from
38 percent
power
due
to
a
short
in the light socket
for
the
4C
isolation circuit.
September
16,
1986,
the unit conducted
a shutdown
due to
a
malfunction in the rod position indication system.
October 27,
1986,
the unit conducted
a
shutdown
due
to
missed
Post-Maintenance
testing
of containment
isolation
valves.
61
gUg ] p
1987
o.
November
10,
1986,
the
reactor
tripped
from
100
percent
power due to
flow control valve failing closed.
h.
January
6,
1987, reactor tripped from 100 percent
power,due
to one
channel
of over-power
delta
temperature
and
over
x,emperav.ure
del
a temperature
reactor trip channels
being
tripped
and receiving
a spike in another
channel.
i.
February 7,
1987,
the unit conducted
a
shutdown
to hot
s andby to meet Technical Specification
requirements
due to
a failure of an Intake Cooling Water
Pump shaft coupling.
h,.
Efiluen-
Summary for Turkey Point
1984
1985
1986
Gaseous
Effluents*
Fission
and Activation Gases
Iodine and Particulates
1. 16E+3
3. 11E-2
'.
1. 10E+3
8. 66E+3
4. 19E-3
4. 12E-2
3.85E-2
1.92E-2-
Whole Body Oose
8. 90E+2
Liquid Effluents
Fission
and Activation Products
1.07E+2
9. OOE-1
4. 2E-1
8. 69E+2
5. 17E+2
1. 24E-2
mrem
In curies