ML17345A279
| ML17345A279 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 07/14/1988 |
| From: | Edison G Office of Nuclear Reactor Regulation |
| To: | Lainas G, Varga S Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8807190087 | |
| Download: ML17345A279 (11) | |
Text
July 14< 1988 Docket No. 50-250 and 50-251 MEMORANDUM FOR:
Steven A. Varga, Director Division of Reactor Projects-I/II Gus C. Lainas, Assistant Director for Region II Reactors Division of Reactor Projects-I/II THRU:
Herbert N. Berkow, Director Project Directorate II-2 Division of Reactor Projects-I/II SUBJECT'riginal signed by Gordon E. Edison, Senior Project Manager Project Directorate II-2 Division of Reactor Projects-I/II
Enclosure:
As stated cc:
T. Murley F. hliraglia FROM:
Gordon E. Edison, Senior Project Manager Project Directorate II-2 Division of Reactor Projects-I/II DRAFT NRR SYSTEhlATIC ASSESSMENT OF LICENSEE PERFORhlANCE (SALP)
FOR FLORIDA PONER 8( LIGHT COMPANY'S TURKEY POINT UNITS 3 AND 4 FOR JUNE 1, 1987 THROUGH JUNE 30, 1988 Enclosed is the NRR SALP report for Turkey Point Units 3 and 4 for licensing activities.
This report is based upon direct inputs solicited from selected staff personnel who have had substantial contact and/or involv'ement with Florida Power t/ Light Company's licensing activities for Turkey Point.
Also enclosed is a summary of SALP results for the previous three, rating periods.
Please review the draft evaluation and provide comments you feel appropriate by July 20, 1988.
The SALP Board meeting is scheduled for August 23, 1988.
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Docket Nos.
50-250 and 50-251 FACILITY:
LICENSEE:
EVALUATION PERIOD:
PROJECT MANAGER:
Turkey Point 3 and 4
Florida Power and Light Company June 1, 1987, through June 30, 1988 Gordon E. Edison/Dan HcDonald I.
INTRODUCTION This report contains NRR's input to the SALP evaluation for Turkey Point, Units 3 and 4.
The assessment was conducted according to NRR Office Letter No. 44, Revision 1, dated December 22, 1986. This Office Letter incorporated NRC Manual Chapter 0516, "Systematic Assessment of Licensee Performance."
The report reflects the staff's special inspection of the 10 CFR 50.59 process in December 1987 and a site visit in March 1988 to study the use of upgraded Technical Specifications in the control room.
The report also reflects the staff's review of the Independent Management Appraisal performed by Enercon.
II.
ASSESSMENT OF PERFORMANCE ATTRIBUTES The licensee's performance evaluation is based on consideration of seven attributes.
These are the following:
A.
Management involvement and control in assuring quality B.
Approach to resolution of technical issues from a safety standpoint C.
Responsiveness to NRC initiatives D.
Staffing E.
Enforcement F.
Training and qualification effectiveness G.
Housekeeping A.
Mana ement Involvement and Control in Assurin gualit The licensee management's role in attempting to assure quality in licensing-related activities showed certain weaknesses during the SALP interval, with signs of possible improvement near the end of the period.
An apparent weakness in the licensing organization has been the interface and coordination between headquarters licensing, site licensing, and operations/modifications planning and scheduling.
The lack of unification under strong leadership in the licensing area was also noted by Enercon in their Independent Ma'nagement Appraisal published on April 18, 1988.
There needs to be sufficient communication between these groups to permit advance planning of licensing proposals such as relief requests and technical specifications changes so that they can be processed in an orderly manner.
One example where this did not occur concerned containment
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tendon surveillance.
Although there are several years between tendon survei 1-
- lances, a last-minute proposal surfaced and some FP&L and NRC resources were spent discussing a change in tendon surveillance technical specifications.
This effort was ultimately abandoned because ther e was not enough time to process a
change before the next surveillance.
Another example was relaxation of Technical Specifications (TS) for CCW heat exchangers.
In order to install the Amer tap system on Unit 4, a proposal was made to relax the permissible outage time for one heat exchanger to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
The proposal was made for an emergency amendment.
However, this could not be supported on the basis of 10 CFR 50.91 and instead the proposal was processed by the staff as an exigent amendment.
Better coordination and planning would have foreseen the need for the TS relaxation and avoided the need for an exigent amendment.
Throughout most of the SALP interval there was no apparent mechanism by which the licensee identified, prioritized, scheduled and tracked ongoing and future open licensing actions.
Instead it was the practice to use the NRC-generated list of open licensing actions as a vehicle to monitor status of licensing actions.
This approach was not effective because the licensee's priorities were not apparent, and future licensing actions were not identified.
Near the end of the SALP period, at the NRC Project Manager's recommendation, the licensee created a
new licensing action status report.
This report lists priorities and attempts to identify future actions far enough in advance to permit planning for resources and orderly processing of proposals.
The new status report has the potential to improve the licensing interface between the licensee and NRC provided it is coordinated within the licensee's organization.
Significant improvements can still be made in formatting and layout of the report which will give a better visual perspective of issues, focus on future actions and schedu les, and document the history of key communications on open actions.
The commitment to an Integrated Schedule
( I/S) process indicates a desire to control licensing activities as well as prioritize plant modifications and allocation of resources.
The licensee made a significant effort to develop a
computer-assisted program for integrated scheduling of planned plant modifications.
The licensee's particular I/S proposal was considered to be especially comprehen-sive and well thought-out.
A license amendment was issued incorporating the I/S during this evaluation period, and it is clear the process is being used extensively to control schedules and priorities.
The Integrated Schedule represents a clear improvement to management's control of plant modifications.
B.
A roach to Resolution of Technical Issues from a Safet Standpoint The licensee's approach to resolution of technical issues has been adequate.
A special inspection was held during the week of December 7, 1987 to examine activities in the areas of safety review pursuant to 10 CFR 50.59, and'he on-site and off-site review committees.
Steady improvement in the quality and completeness of 10 CFR 50.59 safety evaluation documentation was observed.
Recent safety evaluations audited during the inspection were sufficiently detailed to demonstrate the logic and bases for determinations regarding poten-tial unreviewed safety questions.
A weakness was identified in that the large volUme of material requiring PNSC review resulted in long and frequent meetings, diverting management from other duties.
Some method of screening the material for PNSC review seemed to be needed.
Several other lesser weaknesses were noted.
A broad technical issue that has existed for some time has been the early vintage technical specifications which were part of the initial operating license of the plant.
Many technical improvements in technical specifications have been developed in the industry and at NRC over the years, and the licensee volunteered several years ago to upgrade their TS to Standard TS.
During this SALP period a significant effort was made by the-Hcensee to resolve technical isssues related to the upgrade and to make many refinements in their original proposal.
The vast majority of the TS changes are in a more conservative safety direction than the original TS, and the licensee is commended for this effort.
Another broad issue that has existed for some time is the reliability of A. C.
electrical power (station blackout).
The licensee's approach to this issue has been to make a very significant commitment in financial'and personnel resources to enchance emergency power supplies by committing to add two new safety-grade diesel generators with associated equipments.
The licensee has increased planning and design work during this SALP period as this effort begins to grow in magnitude.
In a meeting held on March 29, 1988, the licensee proposed relaxing the allowable outage time for CCW heat exchangers and ICW pumps.
The technical basis for the CCW heat exchangers was thoroughly evaluated and well preseAte'if:""'Ttris",permitted rapid technical review and issuance of a license amendment at a "Tater date.
Such was not the case for the ICW pumps.
Even though the ICW" is an important heat removal system and Turkey Point operating experience with the ICW system has shown a number of fai lures, the licensee proposed removal of the TS on the third ICW pump.
Operating experience in the industry and, in particular, at Turkey Point could not support such a relaxation and the req'uest was de'nied.
In another matter regarding the allowable outage time for diesel generators, the licensee made it clear the issue was very important to the plant's operation.
- However, conference calls to resolve the issue were twice postponed by the licensee
- and, when finally held, evidenced inadequate technica'1'preparation to fully address the issue.
The issue remains to be resolved.
C.
Res onsiveness to NRC Initiatives The licensee's responsiveness to NRC licensing initiatives has been very good.
An example was the cooperation with the NRC effort to document historically the completion/implementation status of requirements in the NRC Safety Issue Manage-ment System.
Other examples were the provision of information related'o surveys of reactor vessel support structures, and the use of Bunker Ramo Containment Penetration Assemblies.
The response to requirements of bulletins and generic letters has been timely.
The licensee has volunteered to be the lead plant in the NRC staff's effort to modify generic requirements related to the need for an operations superintendent to hold an SRO license.
The spent fuel pool hearings were completed during this SALP period.
The licensee was especially res'ponsive and expended significant resources to reassure the licensing boards and intervenors that they had taken appropriate design and monitoring measures to provide for safe storage of spent fuel.
D.
~Staffiri The licensee has generally provided appropriate members of their organization at meetings with the staff.
The corporate licensing supervisor has shown good judgement in controlling mieeting attendance and has been very responsive to NRC inquiries.
The headquarters licensing staff includes a former Turkey Point reactor operator, providing a valuable perspective for the group.
The staffing level of the corporate (4 positions) group appears to be the minimum able to keep up with the extra improvement programs underway during the past year in addition to the normal workload.
The site licensing group has been heavily burdened with its role in interpreting technical specifications, evaluating root causes, preparing reports to NRC, and translating operational needs into licensing actions.
The Independent t1anagement Appraisal by Enercon recommended increasing the size of that group.
In res'ponse, the licensee has increased the number of authorized positions from 5 to 9.
E.
Enforcement There was no input specifically directed toward enforcement for the licensing area.
F.
Trainin and (uglification Effectiveness As part of the effort to improve performance in the area of 10 CFR 50.59 reviews, the licensee issued guality Instruction 3.9 on April 20, 1988, entitled "Evalua-tions Performed by Power Plant Engineering."
This (}I is intended to provide guidance to the licensee's staff for conducting 50.59 reviews and preparing reports.
Training on the procedure was provided at the corporate offices and at the Turkey Point and St. Lucie sites.
G. ~k Observations made during a number of plant tours including a special site visit to evaluate the use of two sets of technical specifications in the control room indicated that a number of areas appeared to be maintained well, including the control room, auxiliary building, turbine building and cable spreading room.
Outside areas near the Standby Feedwater Pumps were frequently inspected and were always clean.
In one instance a small unisolable steam leak was observed in a low pressure reheater dr ain line.
The licensee eventually decided to plug this leak.
III. ASSESS>1ENT OF OTHER FUNCTIONAL AREAS While the primary thrust of this evaluation is focused on licensing activities and the rating assignment pertains only to this functional area, some NRR observations relating to the other functional areas are included.
These observations were gained from the plant tours and visits to the plant, by the Project Manager and discussions with NRR staff.
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a Early in the SALP period there were indications of a lack of professionalism'in the control room.
This problem has been addressed by the utility by ma'king operations management changes in the form of a new Operations Superintendent and
a new Plant Manager, and by instituting a Management on Shift program to identify and correct deficiencies in operations and maintenance.
A dress code has been implemented for reactor operators.
A guidance document called "Standards of Professionalism" was prepared for reactor operators.
While the operational performance in the first half of the SALP period was marked by outages, operator errors, operational
- events, and a lack of profes-sionalism in the control room, the performance in the second half was markedly improved.
No reactor trips occurred in the first half of 1988 at either unit.
Operator professionalism was reported in weekly MOS reports to be significantly improved.
Securit and Safeguards The licensee has made significant improvements in the site security organization.
The licensee has reorganized the site security organization, provided new management, separated the day-to-day activities from the upgrade
- projects, and added 5 additional positions to supervise contractor personnel on all shifts.
With the issuance of the Integrated Schedule the licensee allocated resources and established an implementation schedule to complete modifications identified in an earlier Regulatory Effectiveness Review.
The licensee made timely license amendment submittals to address the new require-ments of 10 CFR 50.?3 (Miscellaneous Amendments)
- and, as a result, that issue is now closed.
Trainin and qualification Effectiveness:
A few operators appeared to have difficulty understanding the use of the upgraded TS in the control room as a trial document preparatory to a complete transition to Standard TS.
Better training could have been provided to operators to put the program in perspective and to understand how to use the upgraded TS in relation to the current license TS.
Hear the end of the SALP period, a new plant-specific simulator began operation.
.This represents a major improvement in the training capability of the licensee.
Surveillance:
Throughout the SALP period the licensee made a voluntary effort to add additional surveillances where they were needed, to provide more detailed guidance for performing survei llances, and to eliminate unnecessary surveillances.
This activity took the form of the Technical Specification Improvement Project which is intended to upgrade the plant TS towards Standard TS.
The licensee devoted significant resources to this project and an enhancement in plant safety is occurring because of it.
IV.
SIGNIFICANT OCCURRENCES A.
NRR/Licensing Meetings - The licensee's presentations were generally well structured.
The licensee was generally well prepared for meeting with the NRC staff and generally handled the staff's questions adequately.
A list of NRR/Licensee meetings is shown below:
Date Pur ose June 4, 1987 June 17-18, 1987 June 23, 1987 June 22-23, 1987 Discussion of Emergency A. C. Power Enhancement Discussion of TS Improvement Project
,Discussion of Boraflex in Spent Fuel Pool Racks Discussion of TS Improvement Project August 26-27, 1987 Discussion of TS Improvement Project September 2,
1987 Discussion of FP&L Electrical Transmission System October 20-22, 1987 Discussion of TS Improvement Project December 15-17, 1987 Discussion of TS Improvement Project January 6,
1988 January 28, 1988 Discussion of Schedule for Technical Specification Conversion Project Clarification of Use of Technical Specifications in Control Room February 23-26, 1988 Discussion of Technical Specification Improvement project Harch 15, 1988 Harch 28-31, 1988 Hay 18, 1988 June 2, 1988 Discussion of ICW/CCW TS and Operability of CCW Heat Exchangers Discussion of Technical Specification Improvement Project (Electrical)
Discussion of Improvements to Integrated Schedule Discussion of Seismic Adequacy of Components (Generic Letter 87-02)
B.
Commission Heetin s - None C.
Schedular Extension Granted - None D.
Reliefs Granted June 15, 1987 Harch 28, 1988 Relief request No. 16-relief from visual (UT-2) examination (Unit 3)
Relief request No. 17-relief from visual (UT-2) examination (Unit 3)
E.
Exem tions Granted August 12, 1987 Technical exemption from Appendix R
requirements.
F.
Orders Issued October 19, 1987 Order for independent written appraisal of site and corporate organizations and Notice of Violation and Proposed Imposition of Civil Penalty G.
Emer enc Technical S ecifications Issued None H.
License Amendments Issued Amendment Numbers Unit 3 Unit 4 Descri tion Date 125 119 126 120 127 121 128 122 124 118 Revise the TS for the auxiliary feedwater system and the condensate storage tanks Incorporate TS for reactor vessel level monitoring system Integrated Scheduling Revise the TS for the D.C.
power sources Delete remaining Sections 1.0 and 5.0 of the environmental TS and replace it with an Environmental Protection Plan 06/08/87 07/28/87 11/23/87 04/18/88 04/25/88 129 123 Organizational changes per Generic Letter 88-06 04/28/88 130 124 Revise the TS for the component cooling water system 04/29/88
TURKEY POINT P LA.NT, UNITS 3 AND 4 DOCKET NOS. 50 250/'50 251 SAIP SUMMA.RT PERIOD OVERA.LL 5/ 1/86 5/31/87 SATIS Xi/1/a4 4/30/86 SATIS.
V/1/aS 10/31/84 SATXS.
PLANT OPER.
RADXOL. CONTROX S MAINTENANCE SU RVEXLLANCE FIRE PROTECTION EMERG. PREP.
SECURITY 8c SAI'QDS.
OUTAGES QlJAK. PROGRAMS/
ADMIN. CONTROLS LICENSING TRAXNINGjQUAL.
EFFE CTXVENESS ENGINEERING SUPPORT 2
2 2
2 NR 1
8 2
2 3+
2 3+
2 2
2 2
3+
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3 2+
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2 2
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