ML17345A397
| ML17345A397 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 09/13/1988 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17345A396 | List: |
| References | |
| 50-250-88-15, 50-251-88-15, NUDOCS 8809260148 | |
| Download: ML17345A397 (88) | |
See also: IR 05000250/1988015
Text
ENCLOSURE
BOARD REPORT
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMATIC ASSESSMENT
OF LICENSEE
PERFORMANCE
INSPECTION
REPORT
NUMBER
50-250/88-15
50-251/88-15
FLORIDA POWER
AND LIGHT COMPANY
TURKEY POINT UNITS 3 AND 4
JUNE 1,
1987
THROUGH JUNE 30,
1988
ssom6ocas
Siovis
pDR
ADQOK p500025p
6
PNU
0,
INTRODUCTION
The
Systematic
Assessment
of Licensee
Performance
(SALP) program is
an
integrated
Nuclear
Regulatory
Commission
(NRC) staff effort to collect
. available
observations
and
data
on
a periodic
basis
and
to evaluate
licensee
performance
based
on this information.'he
program is
supplemental
to normal
regulatory
processes
used to determine
compliance
with
NRC rules
and
regulations.
The
program
is
intended
to
be
sufficiently diagnostic
to provide
a rational
basis
for allocating
NRC
resources
and
to provide meaningful
guidance
to licensee
management
in
order to promote quality and safety of plant construction
and operation.
An
NRC
SALP Board,
composed
of the staff
members listed below,
met
on
August 23,
1988, to review the collection of performance
observations
and
data
to assess
licensee
performance
in accordance
with guidance
in
NRC
Manual
Chapter
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
and
management
performance
at
Turkey Point Units
3
and
4 for the
period
June
1,
1987, through June
30,
1988.
SALP Board for Turkey Point Units 3 and 4:
L. A. Reyes,
(Chairman), Director, Division of Reactor Projects
(DRP),
Region II (RII)
A. F. Gibson, Director, Division of Reactor
Safety
(DRS), RII
J.
P. Stohr, Director, Division of Radiation Safety
and Safeguards
(DRSS),
RII
B. A. Wilson, Chief, Reactor Projects
Branch
2 (RPB2),
DRP, RII
H.
N. Berkow, Director, Project Directorate II-2, Division of Reactor
Projects,
Office of Nuclear Reactor
Regulation
(NRR)
G.
E. Edison,
Senior Project Manager,
Turkey Point, Project Directorate
II-2, Division of Reactor Projects,
Attendees at
SALP Board Meeting:
M. L. Ernst,
Deputy Regional Administrator, RII
R.
V. Crlenjak, Chief, Reactor Projects
Section
2B,
RPB2,
DRP, RII
H. 0. Christensen,
Project Engineer,
RPB2,
DRP, RII
R.
C. Butcher, Senior Resident Inspector,
Turkey Point,
DRP, RII
G. A. Schnebli,
Resident
Inspector,
Turkey Point,. DRP, RII
P.
M. Madden,
Reactor Engineer,
Technical
Support Staff (TSS),
DRP, RII
T.
C. MacArthur, Radiation Specialist,
TSS,
DRP, RII
P.
A. Balmain, Reactor Engineer,
TSS,
DRP, RII
CRITERIA
0
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
normally represents
an area which is significant to nuclear safety
and .the
environment
and
which is
a
normal
programmatic
area.
Some
functional
areas
may not
be
assessed
because
of little or
no licensee activity or
because
of
a 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.
A.
B.
C.
D.
E.
F.
G.
Management
involvement in assuring quality
Approach
to
the
resolution
of technical
issues
from
a
safety
standpoint
Responsiveness
to
NRC initiatives
Enforcement history
Operational
and construction
events (including response
to, analysis
of, and corrective actions for)
Staffing (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:
~Cate or
1:
Reduced
NRC attention
may
be appropriate.
Licensee
management
attention
and
involvement
are
aggressive
and oriented
toward nuclear safety;
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
area
being evaluated
may
have
some attributes
that would
place
the
evaluation
in Category
1
and
others
that
would place it in
either Category
2 or 3.
The final rating for each functional
area
is
a
composite
of the attributes
tempered
with the judgment of NRC management
as to the significance of individual items.
The
SALP Board
may also include
an appraisal
of the performance
trend of a
functional
area.
This performance
trend will only be
used
when
both
a
definite trend of performance within the evaluation period is discernable
and
the
Board believes
that continuation of the trend
may result in
a
change of performance
level.
The trend, if used, is defined as:
~Im rovin
Licensee
performance
was determined
to be improving near the
close 'of the assessment
period.
~Declinin
Licensee
performance
was
determined
to
be declining near the
close of the assessment-
period
~
III. SUMMARY OF
RESULTS
A ~
Overa 1 1
Fac i 1 ity Eva 1 uati on
The
licensee
has
continued
to
make
improvements
during this
period.
Although the initial portion of this period
indicated
a
definite
need for improvement,
which resulted
in the
issuance
of
a
Confirmatory
NRC
Order
in
October
1987,
management
attention
to
deficiencies
identified
in
the
Confirmatory
Order
has
produced
results during the latter portion of the rating period.
The licensee
has
made
a series
of personnel
changes
using
people
not previously
assigned
to the Turkey Point facility in order to obtain
a
new look
at the problem areas.
The initiation of several
new programs,
such
as
Management
on Shift,
an in-depth plan of the day, shift briefings,
and
an emphasis
on accountability
and ownership
have
had
an impact
on
reversing
adverse
characteristics
of culture
and climate previously
existing at the plant.
There
has
been
a definite shift in management
philosophy in the conservative
direction to shut
down the plants
or
extend
shutdown periods to allow equipment repairs to be completed to
help
improve unit reliability.
The
security
program continues
to
show
a weakness
as indicated
by the continued
number of violations
which are repetitive in nature.
The
new maintenance
building and the
simulator were completed during the period
and
should
show tangible
benefits in the future.
Corporate
management
has committed to expend
tremendous
resources
at the site to enhance
the
safe
and reliable
operation
of the units.
Throughout
the rating period,
there
have
been
numerous
meetings
between
the licensee
and the
NRC to resolve
issues
over
the licensee's
proposed
Technical
Specifications
(TS),
which were submitted in October of 1986.
These modified standard
TS
will provide
a significant improvement over the old custom TS.
In April
1988,
an
Independent
Management
Appraisal
(IMA) of the
Turkey Point facility was
completed
and
submitted to the
NRC.
The
IMA was
evaluated
by the Office for Analysis
and
Evaluation of
Operational
Data
(AEOD) and
immediately after the
SALP period, this
evaluation
was provided to
FPL.
Initial indications
show that
has
been very responsive
to implementing
the
recommendations
of the
IMA and the
AEOD evaluation.
However,
due to the history of poor
performance
in
a
number
of functional
areas, it is incumbent
upon
FPL and the
NRC to maintain close
management
scrutiny of performance
indicators,
site
organizations
and
effectiveness
of the
various
corrective actions.
B.
Facility Performance
Summary
The performance
categories
for the current
and previous
SALP period
in each functional
area
are
as follows:
Functional
Area
May 1, 1986-
Ma
31
1987
June
1, 1987
June
30
1988
Plant Operations
2
Radiological Controls
2
Maintenance
2
Surveillance
2
- . Fire Protection
N/R
Emergency
Preparedness
1
Securi'ty and Safegurds
3
Outages
2
guality Programs
and Administrative
Controls Affecting equality
2
Licensing Activities
2
Training
and
equal
ificati on
Effectiveness
3
Engineering
Support
3
3 Improving
2
3 Improving
2
2
2
3
2
N/R = Not Rated
IV.
PERFORMANCE ANALYSIS
~
~
A.
Plant Operations
l.
Analysi s
During the first half of this
SALP period, licensee
performance
in the
area
of Operations
was
marginal
as
demonstrated
by
equipment
problems,
plant availability,
number
of escalated
enforcement
actions,
and
number
of special
NRC
inspections.
Recent
management
changes
and
implementation
of
program
improvements
have significantly improved Operations
toward the
end of the
SALP period.
For the last
six
months
of 1987,
Unit 3
had
an availability
factor of less
than
10%.
During the first half of 1988 this
improved to about
71%.
Following the. repairs
to the
conoseal
leak, Unit 4 returned to service in July and
had
an
up and
down
operational
history for the
remainder
of
1987.
Availability
factors for Unit 4 were about
63% for the first half of the
period and
73% for the
second half.
The previous
SALP report
noted
improvements. in the Operations
area,
although
an event that occurred at the
end of the
period,
which resulted
in loss of the required boric acid flow
paths,
was discussed.
A special
NRC inspection
condu'cted
in
June
1987 resulted
in escalated
enforcement
action
and
a civil
penalty (violation b).
In July 1987,
another
event
occurred
resulting
in
a Severity
Level III violation.
This involved
a
turbine operator
who closed
backup nitrogen supply valves to the
System
(AFW).
Then
in
September
1987,
an
unauthorized,
unlicensed
individual
was
allowed to manipulate
the dilution controls of Unit 3 with the reactor at
power.
At
least
four
licensed
operators
observed
the
event
without
intervening.
A
management
observer
reported
the
event
to
several
members
of the plant
management
who hold or have
held
Senior
Reactor
Operator
licenses.
However,
appropriate. action
was not taken. to evaluate
and resolve the circumstances
leading
to the event for over one week.
This event,
along with other observations
made
by the management
observer,
raised
concerns
as
to the
adequacy
of professional
conduct
on shift.
Continuous
NRC control
room observations
were
conducted
in late
September
and early October
1987 to evaluate
'control
room demeanor
and conduct of operations.
In October
1987, voids were detected
in the Unit 4 reactor
head
region with the plant at cold
shutdown.
Evaluation determined
that nitrogen from an accumulator
had entered
the primary system
through
a leaking accumulator isolation valve.
A total of seven
voiding events
occurred
between
October
21 and
November 3,
1987.
Several
of these
were avoidable
had the desired
valve lineups
been
maintained.
A special
NRC inspection
was
conducted
in
November
to
investigate
the
circumstances
surrounding
these
occurrences.
A review of the
Operations
related
violations,
special
NRC
inspections
and
Licensee
Event
Reports
(LERs)
shows
the
preponderance
of these to occur in
1987'.
The
NRC's Office for
Analysis
and Evaluation of Operational
Data
(AEOD) reviewed
65
LERs for the
two Turkey
Point units
over this'ALP period.
Fifty-one
LERs were
submitted
in the last
seven
months of 1987
and
14 were submitted in 1988.
Further analysis
of these
LERs
is later in this section.
Four reactor trips occurred
during this evaluation
period for
Unit 3.
Unit 4 did not trip during this period.
Three of the
trips
were while operating
above
15% power.
Two were
due to
personnel
error
and
one
due
to
equipment
malfunction.
This
represents
an
improvement
over the previous
evaluation
period
and is slightly above
the national
average
for trips per
1000
critical hours for 'plants of this type.
The deficiencies
identified in the
summer
and fall of
1987
resulted
in licensee
generated
corrective actions,
which were
confirmed
by an
NRC Order
(87-85)
issued
on October
19,
1987.
One
confirmatory
item
included
a
commitment
to
conduct
an
Independent
Management
Appraisal
(IMA) to
be
performed
by
a
third party,
qualified,
outside
organization.
The
IMA was
performed
between
December
14,
1987,
and
March 30,
1988,
and
included
interviews,
document
reviews,
surveys
and
direct
observations
at
the
Turkey Point Plant
and the
FPL corporate
offices:
A final report -was
issued
in April 1988.
An
NRC
evaluation
of the
IMA to determine its quality and completeness
7
was
completed
in June
1988.
The licensee'
response
and action
plan to implement the
IMA findings were submitted for NRC review
after the close of the evaluation period.
It was
determined
that. operational
performance
issues
stemmed
from root causes
related to operations
ownership
and leadership,
training
and
implementation
of Technical
Specifications.
Poor
performance
was
caused,
in part,
by past
focus
on near
term
plant availability rather than long term plant reliability and
a
lack of
strong
sense
of plant
ownership
in the
Operations
Department.
Over
the
long
term, this resulted
in operators
using
compensatory
measures
and
backup
methods
to operate
the
plant safely
when
equipment
was
not operating
properly.
These
practices
resulted
in operators
who did not
.ake
a leadership
role in the operation
and maintenance
of the plant.
The
leadership
of the
operators
has
also
inadvertently
been
diluted
through corrective
actions
in
response
to identified
problems.
For
example,
several
incorrect
Technical
Specification interpretations
have
been
documented
over the past
several
years.
In
an effort to prevent
recurrence,
support
groups,
such
as
the Regulatory
Compliance
Group and Operations
Department
Supervisors,
were utilized to confirm the decisions
of the
control
room supervisors.
Over time, this
led to
a
dependence
on outside
help in complying with required actions.
This
problem
has
been
compounded
during
the
upgrade
of the
custom Technical Specifications to
a standardized
format.
The performance
problems which occurred early in the assessment
period were analyzed
by the licensee
and corrective actions
were
implemented.
It was
recognized
that
an
increased
emphasis
on
management
and accountability
was
necessary,
and to thi s end
a
series
of
personnel
changes
were
made
which
spanned
the
assessment
period.
Each
change
was implemented
using personnel
not previously
assigned
to the
Turkey Point facility in
an
effort to obtain fresh insight into problem areas.
A new Site Vice President
was appointed
in August 1987.
Shortly
after his arrival,
a significant initiative was taken to place
a
management
representative
on operating shifts to help identify
deficiencies
in performance.
This
"Management-On-Shift"
(MOS)
program
was
instrumental
in
identifying
areas
needing
improvement.
A
corrective
action
tracking
program
was
established
for identified discrepancies.
The
program
provided
increased
sensitivity
relative
to
plant
material
condition,
planning
and
scheduling,
leadership
and
professionalism,
procedural
compliance
and
inter-departmental
communications.
Subsequent
to the
September
1987 operation
of
the Unit 3 dilution controls by an unauthorized individual, the
program
was
expanded
and
confirmed
by
NRC
Order
. It is
significant that
the
professionalism
questions
raised
by the
dilution
event
were initially identified
by
a
MOS observer
participating
in the then voluntary
enhancement
program.
One
important
initiative
derived
from *analysis
of
the
observations
was
the
development
of
a Plan-of-the-Day
(POD)
document
to
correlate,
schedule
and
manage
daily
plant
activities.
The
POD addresses
'the daily work lists for each
plant
department,
surveillance
schedules,
. chemistry
results,
plant modification schedules,
priority maintenance
item status
and status
of all Technical
Specifications
limiting conditions
for operation.
The
POD is evaluated daily at
a planning meeting
attended
by all plant departments.
The
program
successfully
emphasized
improving the shift
turnover
process.
Shift briefings,
performed
by
a
licensed
Senior
Reactor Operator,
are performed after each shift assumes
its duties.
These
briefings
provide
information relative
to
goals
and
objectives
for
the
subsequent
shift.
They
are
attended
by
all
shift
personnel
including
maintenance
disciplines.
As
a
result
of the
and shift briefing
programs,
general
awareness
of site activities
has
been
enhanced
and complex evolutions
have
been
performed
more smoothly.
In
December
1987,
a
new Operations
Superintendent
joined
the
Turkey Point staff.
This change resulted in improved department
morale, just
as
the
change
in the Site Vice President
resulted
in
improved
site
morale.
Promptly
apparent
was
a
renewed
emphasis
on personal
accountability
and operations
"ownership"
of
the
decision
making
processes
that
impact
equipment
operability.
Additional initiatives included the involvement of
the licensed
Senior
Reactor
Operators
in the
program
to
assist
in
establishing
and
improving their visibility as
managers
of
the
power
block.
Also
a
"Standards
of
Professionalism"
document
was. developed
to clearly define the
responsibilities
of personnel
assigned
to each
licensed
shift
position.
This document,
which was developed with considerable
input
from licensed
operators,
sets
out in clear
terms
new
stringent
standards
of conduct
and performance
against which the
operators will be evaluated.
A new Plant Manager
was appointed late in the assessment
period.
His initial efforts to develop accountability
on the supervisory
level
have
been
well received
and
appear
to
be
succeeding.
Although,
he
has
not
been
in the position
long
enough to have
had
a
clear
impact
on
sustained
performance,
his
renewed
emphasis
on leadership,
professionalism
and
accountability
.have
had
an immediate
impact
on reversing
adverse characteristics
of
culture
and climate, which have existed at the plant.
Operations
has
made
and continues
with efforts to equalize
and
minimize
overtime
for
on
shift
personnel.
Trainees
were
utilized
where
possible
to
perform duties
not
requiring
a
licensed operator.
Although the current staffing level provides
for enough operators
during normal plant operations,
overtime is
routinely utilized during outages,
forced
load reductions,
and
to fill vacancies
during
vacation
periods
or illness.
At
present,
21 operator
and senior
operator trainees
are
scheduled
for
exams
in October
1988.
This
should
aid in reducing
the
amount of overtime presently
required.
In August of 1988,
an
individual will be
assigned
full time to coordinate
advanced
scheduling
and filling of
vacancies.
This
should
aid
in
minimizing excessive
use of overtime
by arranging
in advance for
off-shift personnel
to work vacancies
where possible.
The
NRC Office for Analysis
and Evaluation of Operational
Data
(AEOD) reviewed
65
Licensee
Event
Reports
( LERs) for the
two
Turkey Point units in the
assessment
period
from June
1,
1987,
through
June
30,
1988.
Of the
LERs reviewed, eight were
deemed
to
be significant by AEOD's screening
process.
Four of those
LERs
reported
long-standing
design
deficiencies
that
were
discovered
by the licensee's
selected
safety
system/design
basis
reconstitution
review.
The other four significant events
are
listed
below in violations
a,
b,
and j
and
the
unauthorized
manipulation
of reactor
controls
which
was
included
in the
Confirmatory Order.
The
review of the
preliminary notifications
issued
on
events
which occurred
during
the
SALP period
found that the
licensee
submitted
LERs
which
adequately
addressed
the
reportable
events.
The
LERs adequately
described
the major aspects
of each event,
including component or system fai lures that contributed to the
event
and the significant corrective actions
taken or planned to
prevent recurrence.
The reports
were complete,
well written and
easy
to
understand.
The
root
causes
were
identified
as
appropriate.
Previous
similar
occurrences
were
properly
referenced
in the
LERs
-as applicable.
Violation a described
an event involving operation of the intake
cooling water
(ICM) system
outside
the plant design
basis,
and
was
an
example
where
lack
of
communications
of required
information to supervisory
personnel
was
a contributing factor
to poor performance.
This item was discussed
in the last
report.
Violations c, e, f; i, j, and
m, document
a number of occasions
where
plant
personnel
manipulated
valves without procedural
justification or approval
from supervisory personnel.
The major
areas
of
concern
included
personnel
departing
from approved
procedures,
failing to notify supervisors
of changes
in system
lineups,
the
'loss
of
configuration
control
over
the
safety-related
systems,
and
system
engineers
directing plant
operators'o
perform valve operations
without first obtaining
the proper authorization
from the control
room staff and without
using approved
procedures.
Violation .h,
identifies
a
similar,
though
less
extensive,
misalignment which occurred in January
1988.
On that occasion
a
single nitrogen bottle was inadvertently isolated for the Unit 4
10
system.
Minor
valve
misalignments
also
occurred
once
in
February
and
twice
in
March 1988.
Violation j,
which
occurred
in
June
1988,
resulted
when
a
technician
locked
closed.
a normally
open
valve in the diesel
fuel system,
contrary to procedural
requirements.
These
failures
by
plant
personnel
indicate
a
lack
of
appreciation
for procedural
compliance,
system
configuration
control,
and
receipt
of
appropriate
authorization
for
realignments
from the control
room.
Comprehensive
co~rective
actions
are being implemented.
Thirteen violations were identified:
a.
Severity Level III violation for failure to take corrective
action
to prevent
component
cooling water heat
exchanger
degraded
performance.
(Unit 3 only 87-27)
b.
Severity
Level III violation for failure to establish
or
implement
adequate
procedures
to
assure
configuration
control over the emergency boration
system.
(87-28)
c.
Severity
Level III violation
for failure
to
follow
procedures
which resulted in isolation of the
system.
(87-33).
d.
Severity
Level
IV violation for failure to determine
hot
channel
factors
when quadrant
to average
power tilt ratio
was exceeded.
(Unit 4 only 87-33)
e.
Severity
Level
IV violation
for
fai lure
to
follow
procedures.
Three
examples:
manipulating
heat
tracing
thermostat,
failure to transfer
the
comparator
channel
defeat
switch
on
a power
range
nuclear
instrument,
and
a
boric acid storage
tank valve was not properly locked open.
(87-43)
f.
Severity Level
IV violation for failure to follow procedure
in that
a
manual
isolation valve
was not in its required
position.
(Unit 4 only 87-46)
g.
Severity Level
IV violation for failure to translate
design
inputs
into
correct
operating
procedures
and
system
descriptions.
(87-54)
Severity
Level
IV vi,olation
for failure
to
follow
.
procedures.
Four examples:
was
found asleep,
failure
to
independently
verify
valve
position,
maintenance
performed
on
Unit 3
rod
control
system without documented instructions
and failure to enter
an
o'n the
spot
change
to
a procedure.
(Example
one is
a
fire
protection
violation
and
example
three
is
a
maintenance
violation, 87-54).
11
Severity
Level
IV violation
for failure
to
follow
procedures.
Three
examples:
failure to maintain
a valve
in
an
open
position
as
per
a
clearance
procedure,
no
temporary
system
alteration
for
removed flow indicators,
and
inadequate
surveillance
procedure.
(Example
two is
a
maintenance
violation, 88-02).
-j .
Severity Level IV violation for failure to follow procedure
which resulted in isolation of the diesel
fuel oil system.
(88-11)
k.
Severity Level
V violation for failure to follow procedure.
Two examples:
a locked valve not locked
and
was
found
asleep,
(Example
two is
a fire- protection
violation, 87-35).
1.
Severity Level
V violation for failure to follow procedure,
Two examples:
shift relief turnovers
were not documented
and actions
were not documented
in the Plant Supervisor's
logbook.
(87-51)
m.
Severity
Level
V
violation
for
failure.
to
follow
procedures.
Three
examples:
vent valve
was
mispositioned,
on three
occasions
a boric acid transfer
pump
discharge
pressure
indication
isolation
valve
was
mispositioned
and
an intake cooling water heat
exchanger
inlet isolation valve was not fully opened.
(88-07)
2.
Conclusion
Category:
3
Trend:
Improving
3.
Board Recommendation
During the first half of the
SALP period,
licensee
performance
was marginal
as
demonstrated
by
a
number of Severity
Level III
violations.
Recent
management
changes
have
had
positive
results.
This has
been demonstrated
by a number of conservative
actions to shut
down the plants or keep
them shut
down
so that
equipment
repairs
could
be
completed
to -help
-improve plant
reliability.
This action
has resulted
in an, improved operating
record
at
the
end of the
SALP period.
The
licensee
should
continue to address
the problems with procedural
adherence.
Radiological Controls
l.
Analysi s
During the assessment
period,
inspections
were performed
by. the
resident
and
regional
inspection
staffs.
There
were
four
12
regional
inspections:
two radiation protection
inspections,
a
radiological effluent inspection
and
a chemistry inspection.
The licensee's
health physics
(HP) and radwaste
staffing levels
were appropriate
and compared
well to other utilities having
a
facility of similar size.
During the
assessment
period,
the
staff consisted
of both
permanent
licensee
and
contract
technicians.
The
permanent
staff
was
supplemented
with
corporate staff and contract technicians
during
nonroutine -or
outage
activities.
In general,
foremen
and first line
supervisors
were
knowledgeable
of their authority
and assigned
duties within the radiation protection organization.
Vacancies
existed for an onsite
radwaste
supervisor
and
HP engineer.
The
licensee
was actively recruiting experienced
personnel
to fill
these positions.
As noted during the previous
SALP assessment
period,
a strength
of the radiation protection
program was the
low turnover rate
among the
HP staff positions.
The
knowledge
and experience
level of the site health
physics
staff was
good.
The licensee's
training program for radiation
protection activities
was well
defined
and
applied
to all
staff.
The
licensee's
health
physics
technician
training
program
has
been
accredited
by
INPO.
Improvements
in
the
general
employee
training
(GET)
were
reflected
in
improved
knowledge
of
principles
and
practices
among
a
wide
cross-section
of
workers
interviewed
at
the
site
during
inspections.
Management
support
and
involvement
in
matters
related
to
radiation protection
and radioactive
waste
were
adequate.
The
health physics
supervisor
received
the support of other managers
at the plant in implementing
the radiation protection
program.
During the
assessment
period,
licensee
management
initiated
several
programs
concerned
with identifying
and
resolving
radiation protection
issues
at the facility.
However,
licensee
programs
designed
to
identify,
review,
track
and
resolve
radiation protection
issues
reported in audits,
incident reports
and
employee
concern
were not fully effective.
These
programs
were poorly organized,
did not
have
clear
lines of authority,
and the responsibility of several
quality assurance
groups
was
not clearly defined.
Details regarding the programs
were poorly
documented.
The
effectiveness
of
these
programs
for
identification of radiation protection
issues
at
the facility
was minimal.
The
licensee's
Performance
Monitoring
Section
(PMONS)
has
initiated
a
monitoring
program,
which
augments
the
audit
program.
Typically, activities monitored under
PMONS were of a
discrete
or one-time
nature,
such
as resolution of unresolved
items
or correction of identified
problems.'he
licensee
continued
the
upgrade
of the plant's
radiation
protection
procedures.
The
involvement of site
and
corporate
13
staff in the
procedural
upgrade
and the
comprehensiveness
of
their technical
reviews of procedures
by the site
and corporate
HP staff
were
less
than
adequate.
For
example,
a violation
concerning
inadequate
procedure
guidance for radiation controls
during
removal
and transfer
of reactor
coolant
system
(RCS)
spent filters
was
identified
during
the
assessment
period
despite
the fact that radiation controls for this activity had
been
previously
reviewed
earlier
in
the
assessment
period
following
an
event
which
exposed
workers
to high radiation
levels.
In addition,
procedures
did not require
documentation
of personnel
contaminations,
even in an instance
when extensive
decontamination
of an individual was required.
Licensee
action
in replacing
several
primary components
of the
post
accident
sampling
system
was
timely
and
demonstrated
licensee initiative in problem solving.
The licensee
did not effec.ively address
technical
issues
in the
radiation
protection
area
such
as electronic drifting of the
invivo counter.
The
licensee
did not
develop
complete
and
technically
sound procedures.
These findings,
combined with the
violations identified in the radiation protection
area
during
,the
assesment
period,
indicate
a decline
in what
had
been
in
previous
assessment
periods identified as
a strong,
aggressive
and
technically
sound
radiation
protection
program,
with
effective leadership
from management.
During
the
assessment
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
January
1987,
approximately
27,000
square
feet (ft~) or
38% of
the radiation controlled area
(RCA), excluding containment,
were
controlled
as contaminated.
Although the licensee
had
a goal of
'reducing
the
area
contaminated
by
20% in . 1987,
the
actual
reduction
was less
than
12%.
At the
end of December
1987,
the
licensee
maintained
34% of the
RCA as contaminated.
This is the
largest
percentage
of any Region II facility.
Toward the end of
this assessment
period, the licensee
began
an extensive
upgrade
of the contaminated
control program including decontamination
of
plant
areas,
use of contamination
containments
and preventive
maintenance
of leaking valves.
As of July 15,
1988,
the total
area maintained
as contaminated
was reduced to 12,600 ft~ or
18%
of
the
RCA,
which
is still
greater
than
most
Region II
facilities.
The licensee
reported
437 instances
of personnel
contamination
in
1987,
of
which
186 events
were
identified
as
skin
contamination.
These
numbers
represented
an
increase
relative
to 1986,
when
a total of 257 contamination
events
were reported.
The higher
number of personnel
contaminations
was related to the
unscheduled
outage
work conducted
in 1987.
The total
number of
personnel
contaminations
for
1987
was
above
average
for
Region II PWRs.
The
1987 collective radiation
dose
was
645 person-rem
per unit
which
was
approximately
75io
above
the
national
average
of
368 person-rem
per
PWR.
The increased collective dose for 1987
was attributed to increase
outage activities.
A comparison of
Turkey Point radiation protection attributes
to Region II plant
averages
is listed in section
V.
K.
During this
SALP period,
the chemistry supervisory staff
had
been
reorganized
and administrative
programs
were initiated to
more
effectively
address
qualification
of
personnel
and
chemistry control.
A new training staff and training laboratory
had
been
provided;
however,
the
small
size
of the chemistry
staff continued
to
be
an
impediment to initating the training
program.
Also,
insufficient
personnel
resources
created
an
obstacle
to
upgrading
chemistry
procedures.
In
1984,
the
licensee initiated
a chemistry
improvement
program for upgrading
facilities, equipment
and analyses
for controlling chemistry in
the
secondary
water cycle.
This program
was in line with the
recommended
guidelines
of the
Steam
Generators
Owners
Group
(SGOG)
and
the
Electric
Power
Research
Institute
(EPRI).
Completion of the total
improvement
program
has
been
delayed
because
of assignment
of lower priorities as part of the Turkey
Point
Nuclear
Plant
Integrated
Schedule.
Completion
of the
secondary
chemistry
inline
monitors
is
scheduled
for
November
1991,
and
November
1992,
for
Units 3
and
4,
respectively.
Construction
of
a
new
secondary
chemistry
laboratory is scheduled for March 1992.
The licensee
continued to encounter difficulties in controlling
chemistry
because
of degradation
of condenser
tubes
and problems
associated
with the
equipment
conditions
of the
makeup
water
treatment plant.
Liquid radwaste
processing,
using
a contractor
and
a portable
demineralizer
system,
maintained
excellent
control
over
the
release
of
radioactive
effluents.
The
mixed
fission
and
activation
products
in
liquid
effluents
for
1987,
were
0.75 curies for both units,
which was consistent with previous
years
and less
than the 0.5 curies per unit industry aVerage for
for
1983,
the
last
year for which industry
data
was
avai 1 abl e.
There
were
no significant changes
in the quantities of gaseous
effluent during this
SALP period
from previous
periods.
The
effluent releases
for the past three years
are
summarized
in the
Supporting
Data
and Summaries
Section
V.K.
The licensee's
quality assurance
program for the counting
room
was
adequate.
The
licensee
participated
in
a
quarterly
15
cross-check
program. with
a
vendor
whose
quality
assurance
program was traceable
to the National
Bureau of Standards.
As
part
of
the
NRC's
confirmatory
measurements
program,
the
licensee
analyzed
samples
for
selected
beta-emitting
radionuclides.
The
results
were
in
agreement
for tritium,
and iron-55.
The
maximum
environmental
radiation
doses
attributed to plant
relea'se
were
a
small
fraction of
and
Appendix I limits and criteria.
Maximum total
body dose to
a
hypothetical
individual
from liquid effluents
was calculated to
be 0.0156
mrem per unit, which was
0.524 percent
of the
annual
limit.
Maximum
gamma
air
dose
and
beta
air
dose
to
a
hypothetical
individual from gaseous
releases
were less
than 0.2
percent of the annual limit.
During
1987,
the
volume of solid radioactive
waste
shipped
by
the
licensee
totalled
4,300 cubic
feet
(ft~)
containing
903 curies of activity.
This volume of waste
shipped offsite is
one of the
lowest of any facility in Region -II.
During 1987,
the licensee initiated the
use of a vendo'r to super
compact the
waste prior to shipment for burial.
Increased
decontamination
efforts for equipment
and material
leaving the
RCA, as well as
control of material
being
brought into the
RCA, resulted
in
a
significant
reduction
in radioactive
waste
volume relative to
1986,
when
approximately
11,420 ft~
were
shipped
containing
approximately '89 curies.
Three violations were identified:
a.
Severity
Level IV violation for failure to follow radiation
work permit
(RWP) requirements
(87-36).
b.
C.
Severity
Level
IV violation
for failure
to
properly
complete
a
manifest
for
a
radioactive
waste
shipment
(87-36).
Severity
Level
IV violation (four examples) for failure to
follow and
have adequate
procedures
(87-48).
Conclusion
Category:
2
Board Recommendations
Licensee
management
should
give continued
attention
to:
(1)
addressing
the continuing higher, than average
annual
collective
occupational
doses
and (2) efforts to reduce plant and personnel
contaminations.
In addition, licensee
management
should
assure
that
there
is
an
adequate
level
of
resources
and
support
provided to effectively deal with these
issues.
16
Maintenance
1.
Analysi s
During thi s
a'ssessment
peri od
inspections
were
performed
by
resident
and regional
inspectors.
Several
deficiencies
were
noted in the plant work order
(PWO)
process
during this
SALP period.
These deficiencies
included:
Numerous
items identified with deficiency tags in the field
were
not entered
in the
work control
system.
This is
caused
by the time lag
between
identification
and actual
entry intc the computer.
The indicated
number of
PWOs is artificially lower due to
the method of tracking them.
The unplanned
work orders
are
not entered into the
system until the planner
has completed
,
his portion of the
PWO.
Deficiency
tags
for
items
repaired
were left
on
the
component in the field even after the work was completed.
The
PWO job packages
were
weak in the
areas
of planning,
the
use
of machinery
history,
up to date
drawings
and
procedures,
and root cause
determination.
Assignment
of priorities
was
weak in several'nstances
where the item was not worked
when required.
This caused
inadequate
job
planning
which resulted
in
an
increased
workload
on
the
maintenance
staff.
Also,
priorities
continued
to
be 'changed
as
the
PWO
was
processed.
The
licensee
has
made
several
attempts
to
correct
this
deficiency
however,
the problem continues
to exist.
Late
in the
SALP period,
the licensee
instituted
a
new program
to
address
this
issue.
The
program
involves
more
operations
control
over the
assignment
of
PWO priority
during
a daily meeting
between
the Plant Supervisor
Nuclear
(PSN)
and the operations
coordinator.
The
program
appears
to
be working,
however,
since
implementation
was late in
the
SALP period, it is too early to accurately
assess
its
impact.
There
were
several
instances
where
PWOs
were
cancelled
without the originator's
knowledge or approval.
Normally,
cancellation
was
due
to
not
finding the
problem
as
described
on the
PWO.
This
has
caused
additional
PWOs to
be
generated
by
the
originator until
concerns
were
addressed.
.The
licensee
continues
to
have
a
large
number
of corrective
maintenance
PWOs',
approximately
1,000 at the
end of this
period.
Howeve~, this is
an
improvement
over
the
same
period
17
last year
which
showed
an
average
of about
1,800 corrective
maintenance
-PWOs.
It should
be
noted
that
the
reduction
in
PWO'
was
accomplished
by
better
management
of
available
resources
and not by increasing
the work force.
During previous
SALP periods,
a
reduction
in
PWO's
was also
noted
near
the
end of the period.
This was attributed to
a
temporary
increase
in the work force with contract
personnel.
Upon termination of the temporary help,
the backlog increased.
The
licensee
continues
to strive for maintaining
the total
PWO backlog in accordance
with the
INPO guidelines of having
no
more
than
50 percent of the corrective maintenance
PWOs greater
than three
months old. They normally meet this target criterion.
In order to reduce
the total
PWO backlog to
an acceptable
and
more
manageable
number,
the licensee
has
developed
several
new
programs
late in this
SALP period.
The first involves
a
team
developed
to resolve the la'rge
number of control
room deficiency
tags.
The team,
which was established
May 23,
1988, is center-
ing on repeat control
room deficiencies
to determine
and correct
the root cause.
The initial effort indicates
an
improvement,
a
reduction of about
60 deficiency tags
between
May 23,"
1988 and
June
30,
1988 (from about
255 to 195).
The
second
program
was
initiated
by the Electrical
Department
and has
shown
a dramatic
reduction
in the backlog of ready
to work
PWOs
since starting
the
program
on June
14,
1988.
Backlog
was reduced
from 206 to
about
65 at the end of this rating period
on June
30,
1988.
The
program
included:
discussions
with the
shop
personnel
as to
what constituted
backlog;
a status
board displayed
in the
shop
area listing all ready-to-work
PWOs
and graphs
tracking daily
progress;
and
a separation
of the department's
workforce into
crews being responsible for .their assigned
units (Unit 3, Unit 4
and
common).
Although this
concept
was
implemented
late
in
the
SALP period, initial indications are positive.*
Communications
between
Operations
and
Maintenance
Departments
have greatly improved during this
SALP period and Operations
i s
being treated
more
as
a customer of the Maintenance
Department.
The improvement
was due to a more in-depth Plan-of-the-Day
(POD)
meeting,
and the
POD document
containing:
work scheduled
for
the
current
day; priority items;
LCOs presently
in effect;
surveillances
due
and past due;
and other information pertinent
to daily plant operation.
In addition,
the
oncoming
Plant
Supervisor
Nuclear
(PSN) or Assistant
Plant Supervisor
Nuclear
(APSN) conducts
a briefing for their shift to update
the shift
for work planned
or in progress.
These
briefings
are
also
attended
by supervisors
from the other departments
so that all
departments
are working toward the
same goals.
18
The
licensee's
Analytical
Based
Preventive
Maintenance
(ABPM)
Program,
which was
implemented
during the last
SALP period to
augment
the Preventative
Maintenance
(PM) Program
has
proven to
be
an effective tool for predictive maintenance.
This program
initially started with vibration and oil analysis for pumps
and
motors,
and
was
recently
expanded
to
include
infrared
The thermography
has
been
useful
in identifying
numerous
equipment
problems
throughout
the
plant
prior to
fai lure.
Examples
include:
the
location
and
repair
of
condenser
air
inleakage;
hot
spots
in electrical
equipment
caused
by
loose
electrical
connections
or
overload;
and
identification of valve seat
leakage.
An average
of 50 to
100
components
per month were analyzed
using thermography.
The original
Performance
Enhancement
Program
(PEP)
goal of 560
maintenance
and operations
procedures
was met
on April 1,
1988.
In addition,
the licensee
has
added
103
new. approved
PM proce-
dures
during this
period
and
the're
are
329 left to
complete.
The additional
procedures
are part of the
Enhanced
PEP currently scheduled for completion in May of 1993.
A recent audit in the area of performing
PMs indicated about
300
PMs past
due.
Increased
management
involvement rapidly reduced
the
number to 79 by late June
1988.
However,
continued
manage-
ment attention is required in the area of performing
PMs within
their required
schedule.
Maintenance-related
deficiencies
caused
two manual
and
one
automat,ic trip during this period.
This is
a marked
improvement over the last rating. period which attributed
eleven
reactor trips due to maintenance.
The two manual trips were both
associated
with Unit 3.
One
was initiated
due to
an
equipment
malfunction,
sticking electrical
contacts,
and
the
other
was
related to personnel
error that resulted
in multiple rod drops
during
a
shutdown.
There
were
a large
number of shutdowns
or
forced
power reductions
due to maintenance/engineering
related
deficiencies
(see
the
Outage
section
for
a
more
detailed
discussion
of outages).
The shutdowns
(4 for Unit 3 and
6 for
Unit 4)
and
load
reductions
(2 for Unit 3 and
9 for Unit 4)
were, for the most part,
due to equipment malfunction or failure
which could be attributed to poor design or material condition.
Increased
management
attention
is
needed
for
repetitive
equipment failure, in particular in the balance of plant area.
Examples
include the following.
The
pressurizer
spray
valves
have
caused
three
forced
shutdowns
due
to controller malfunction or
spray
valve
failure.
In addition,
a pressurizer
spray
valve failed
while Unit 3
was
in
Mode 3,
causing
a negative
pressure
which resulted in partial discharge
of a cold leg
accumulator into the
RCS.
19
The
steam
generator
feedwater regulating valve to actuator
has
caused
two
forced
power
reductions
to
facilitate repairs.
The turbine control oil system for Unit 4
has
caused
one
shutdown
and
several
load
reductions.
Unit 3
has
been
relatively free of problems with the oil
system
since
a
major
cleaning
was
accomplished
during
the
last
period.
The
licensee
completed
replacement
of all intake cooling
water
( ICW)
pump
during this period after
a
failure required
a load reduction.
However, the
ICW system
continues
to remain
a large
maintenance
item,
accounting
for increased
time in
LCOs.
Major problems
include
heat
exchanger
fouling caused
by calcium carbonate
buildup
and
strainer
plugging
caused
by marine
growth.
The
Amertap
system
was installed in Unit 4 late in this
SALP period and
should
reduce
the
heat
exchanger
fouling
problems.
Increased
attention
should
be
focused
on the
ICW strainer
problems
and future heat
exchanger
replacement
or retubing.
As mentioned
in previous
assessments,
the
area
radiation
monitor
system
(ARMS)
and
the
process
radiation
monitor
system
(PRMS),
continue
to
have
numerous
problems.
The
PRMS
failures
of
R-11
and
R-12
have
resulted
in
the
initiation of
seven
LERs
due to containment
and control
room ventilation
system
isolations.
The
system
drawers
were replaced
with new upgraded
drawers
during this
period (Unit 3 on November 5,
1987,
and March 24,
1988 for
Unit 4)
and
this
has
resulted
in
improved
system
performance.
However, the series circuit type power supply
for the system,
which has also caused failures,
has yet to
be corrected.
The licensee
currently plans to modify the
power supply in August 1988.
Personnel
errors continue to remain
a problem,
as indicated
by the violations identified't the
end of this section.
The licensee
is improving in this area,
as evidenced
by the
reduced
number of
LERs in the
maintenance
area attributed
to personnel
error, versus
equipment malfunction.
However,
continued
licensee
emphasis
is required
on
the
need for
attention
to
detail
and
individual
accountability
as
indicated
in the following- additional
examples
related to
personnel
error:
Not knowing the effects .of pulling certain
CROM fuses
caused
multiple rod drops
which required
a
manual
Use
'of
steel
gauge fittings in
a
seawater
system
caused
an
ICW pump to be placed out of service
and entrance
into TS 3.0. 1.
20
An improperly installed
RCP shaft
shim contributed to
a uni-t shutdown
during startup
and
increased
outage
time.
A review of the safety
system failures for the units indicated
that they were slightly above
the national
average
for older
plants of this type during this
SALP period.
However, only one
failure could be attributed to
a maintenance
related deficiency,
which concerned
the failure of an
ICW pump coupling previously
di scussed
in this section.
The licensee's
approach
of resolving technical
issu'es
by using
Event
Response
Teams
(ERTs)
has
continued to
be
a useful tool
for identifying and resolving the root cause of a deficiency.
A
total of 23
ERTs
were initiated during this assessment
period,
some of which were for multiple problems.
One
ERT concerning
the multiple failures of the
125
VDC battery chargers identified
an
inadequate
component
provided
by the vendor during circuit
modifications.
This deficiency
was not initially recognized
by
the vendor
and its identification was not only a benefit to the
licensee
but also to the industry.
The
new maintenance
building was
completed
during this assess-
ment period.
This should aid in improving maintenance
trends
by
centrally locating all maintenance
disciplines.
Three violations were identified.
(Two additional
maintenance
related
violation
examples
are
identified in
the
Operations
section):
a.
Severity
Level
IV violation for failure to
report to
management
a pin hole leak
on
an
AFW steam line.
(Unit 4
only, 87-33)
b.
Severity Level
IV violation for improper fuses installed in
the reactor
safeguards
protection circuitry.
(87-39)
c.
Severity
Level
IV violation with two examples:
failure to
perform
a functional test
on
an instrument
loop
and the
improper installation of a check valve.
(87-39)
2.
Conclusion
Category:
3
Trend:
Improving
3.
Board Recommendations
The
Board recognizes
the
improvements
made
in the maintenance
area
but remains
concerned with the significant number of plant
equipment
problems
that
have
not
been
repaired
through
the
corrective
maintenance
program
or are
overdue
for preventive
21
maintenance.
Additional licensee
management
and
NRC attention
in thi s area is recommended.
0.
Surveillance
Analysi s
During the evaluation period, routine reviews of the operational
surveillance
testing
program
were
conducted
by
the
resident
inspector
staff.
Regional
inspectors
reviewed
surveillance
testing
in the
areas
of fire protection,
chemistry,
-and
core
physics testing.
During the last
SALP period, the majority of the missed
survei 1-
lances
were
caused
by
a
poor
surveillance
tracking
program.
The
licensee
corrected
that
problem with
an
improved
manual
tracking
system,
but during this
SALP period
nine
LERs
were
generated
as
a result of survei lian"es.
Personnel
error caused
four missed
survei 1 lances.
These
were in the area of failure to
perform the
scheduled
surveillance.
The other five
LERs were
due to inadequate
procedures,
and resulted
in failed or missed
survei llances.
The violations listed
below
concern
missed
TS
survei llances.
However, the root causes
for each
were different:
violation b
was
due to misinterpretation of the applicable
mode for the test
performance;
violation
a concerned
TS interpretations
and
was
a
result of the licensee's
decision to omit, rather than meet,
the
TS requirement
for sampling
the safety injection accumulators;
violation c
was
due
to operations
personnel
anticipating
the
return
to service
of the
EDG before
the
TS time limit for
testing
the other
EDG expired;
and violation d was
a result of
an inadequate
surveillance tracking program.
The
~ Quality
Control
(QC)
surveillance
gro'ups'eview
of
completed test procedures
and testing activities
was evident by
the low frequency of missed
survei llances.
This is due to the
group surveillance tracking program.
The licensee
has developed
a computerized
surveillance tracking
program,
which is scheduled
to.be
implemented
in July 1988.
The
major benefit
of this
program will
be
to
reduce
manpower
necessary
to track
survei llances.
QC surveillance
personnel
should
be
able
to witness
more test activities
instead
of
reviewing
documentation.
The
surveillance
tracking
program
currently
in
use
will
be
run
in parallel
with the. new
computerized
system until the
end of
1988.
This will ensure
that the
new
system is able to track the survei 1.lances
as well
as the current
system.
The
Procedure
Upgrade
Program
(PUP)
has
continued
to improve
existing
surveillance
procedures
to
increase
the
quality,
content
and to aid in reducing
personnel
errors.
In general,
22
the surveillance
procedures
were technically accurate
and well
written.
Some difficulties resulted,
as
expected,
with the
upgrade
and
generation
of
new
surveillance
procedures.
Personnel
performing
testing
have
encountered
some
minor
difficulties with the
new procedures,
especially
during
the
initial
use.
However,
management's
policy
of
verbatim
compliance to procedures
has helped to avert problems.
When the
procedures
have
been unclear or technically inaccurate,
the test
personnel
have
stopped
the test to
seek
a change/clarification
to the procedure.
Test
personnel
routinely exhibited conservative
approaches
to
'resolving
safety
significant issues
and were
knowledgeable
of
the surveillance
they were performing.
Management
involvement
in assuring
quality
was
evidenced
by the
low occurrence
of
procedural
noncompliance
related
to
surveillance
testing.
Additionally,
the
surveillance
records
were
complete,
well
maintained
and
readily
available
for review.
However,
the
licensees
poor
management
of the
surveillance
schedule
was
reflected
by the routine
use of TS allowed grace
periods.
An
example
of this
was
the
Unit 3
and
4
containment
tendon
surveillance.
This surveillance is performed every
5 years
and
was last performed in early 1982.
The licensee
had not started
the tendon surveillance until May 1988, with the Unit 3 end of
grace period expiring June
30,
1988,
and the Unit 4 end of grace
period expiring July 31,
1988.
The surveillances
were completed
on
time but
the
licensee
utilized
almost
the entire alloted
grace period. If an
unforeseen
problem would have arisen,
the
licensee
would not
have
had sufficient margin to complete
the
surveillance within the allowed
TS time limits.
The most recent post-refueling startup tests
on both units were
satisfactory.
They
were
representative
of good technique
and
attention to detail, which indicate
an understanding
of the test
and
a
sound
and thorough
approach
toward performance
of these
,
required activities'he initial criticality for both
units
showed
a reactivity overshoot.
This could
have
been
avoided
with an improved procedure
and/or
a
more conservative
approach
toward 'restart.
One inspection
on heat tracing records
and procedures
identified
a weakness
concerning
a lack of
. review of surveillance
records
by management.
When brought to the attention
of the l.icensee,
the
data 'was
immediately
checked
by performing
retests
and
verified to be adequate.
Four violations were identified:
a.
Severity
Level
IV violation for failure to 'perform the
boron concentration
analysis for the
4C accumulator (Unit 4
only', 87-35).
23
b.
Severity
Level
V violation for failure to
perform the
monthly surveillance
on Unit
3
spent
fuel pit
exhaust
monitors (Unit 3 only, 87-27).
c.
Severity
Level
V
violation
for failure
to
verify
operability
of the
B emergency
diesel
generator
when
the
A diesel
was out of service (87-35).
d.
Severity
Level
V violation
for failure
to
perform
surveillance test
on electric fire pump (87-42).
Conclusion
Category:
2
Board Recommendations
None
E.
Fire Protection
Analysi s
During this assessment
period, inspections
were conducted
by the
regional
and resident
inspection staff to review the licensee'
implementation of the fire protection
program
and follow up
on
previously identified enforcement
matters.
The
licensee
has
issued
revisions
to
procedures
for the
administrative
control
of fire
- hazards
within
the
plant,
surveillance
and maintenance
of the fire protection
systems
and
equipment,
and
organization
and training of the
plant fire
brigade.
These
procedures
were
reviewed
during
the staff
inspections
and found to meet
NRC requirements
and guidelines.
The
inspectors
also
reviewed
the licensee's
implementation
of
the
fire
prevention
administrative
controls.
General
housekeeping
and control of combustible
and
flammable materials
in safety-related
plant
areas
were
found to
be satisfactory.
The fire extinguishing
systems, fire detection
systems,
and fi, e
barrier
assemblies
protecting plant
systems
required
for safe
shutdown were found to be functional.- In addition, the surveil-
lance
inspections,
tests
and
maintenance
instructions for the
plant fire protection
systems
were found to be satisfactory
and
met the criteria of the plant Technical Specifications.
The fire protection/prevention
annual audit, triennial audit and
audits
conducted
to
verify
implementation
of
Appendix R,
requirements
were
reviewed.
These
audits
were
conducted
within the specified
frequency
and
covered all the
essential
elements of the fire protection program.
These audits
covered procedures,
fire brigade organization
and training,
and
fire protection
systems
and housekeeping.
The audits identified
minor discrepancies.
None of the audit findings were of major
safety
significance.
The
licensee
has
implemented
the
corrective actions for discrepancies
identified by these audits.
During
a
design
basis
review, it
was
determined
that
insufficient
emergency
power
exists
(assuming
worst
case
accident
design basis) to operate air conditioning units in the
battery
charger
rooms.
Consequently,
fire doors
have
been
required to be propped
open for the past year along with the use
of portable
fans, to assure
adequate
ventilation during accident
conditions.
One fire door requires that
be present
to shut the door
under certain circumstances.
Twice
in
the
past
year,
individuals fulfilling this
compensatory
action
have fallen
asleep.
This
haq resulted
in examples
of
violation
h and
k of the Operations
section.
The
management
involvement
and control in assuring
quality in
the
fire
protection
program
was
evident
due
to
the
well
developed,
issued
and implemented fire protection administrative
procedures'he
licensee's
approach
to resolution of technical
fire protection
issues
indicated
an understanding
of issues,
and
was
sound
and timely.
The
responsiveness
to
NRC initiatives
were generally timely and thorough.
When violations did occur,
effective corrective action
was promptly taken.
Fire protection
related
events
and discrepancies
identified by the licensee
were
properly analyzed,
promptly reported,
and effective corrective
actions
were taken.
Staffing
for
the
fire protection
program
is
adequate
to
accomplish the goals within normal work'hours.
The fire protec-
tion staff is identified,
and authorities
and respons'ibi lities
are clearly defined.
Personnel
appear. well qualified for their
assigned
duties.
The organization,and
staffing of the plant
fire brigade
met
NRC guidelines.
The training
and drills for
the
brigade
members
met
the
frequency
specified
by
the
procedures
and
NRC guidelines.
One violation was identified.
Severity
Level
IV violation for inadequate
procedure
for the
control of deluge isolation valve positions (87-33).
2.
Conclusion
Category:
2
3.
Board Recommendations
None
F.
Emergency
Preparedness
Ana lysi s
t
25
During
the
assessment
period,
inspections
were
performed
by
resident
and
regional
inspection
staffs.
These
included
an
annual
emergency
preparedness
inspection,
and
an
emergency
response facilities
(ERF) appraisal.
One revision to the Turkey
Point Radiological
Emergency
Plan
(REP)
was
submitted for
NRC
review.
The
emergency
program
inspection
and
ERF appraisal
disclosed
that the licensee
has
the capability to promptly identify and
correctly classify
emergency
events,
and
implement
the
key
elements
of the
and respective
procedures
in
response
to
emergency
events.
The
annual
radiological
emergency
preparedness
exercise
was
not evaluated
duri ng this assessment
period;
however,
the effectiveness
of the
were evaluated
during the exercise.
No significant findings, other
than
those
discussed
below, were identified during either the appraisal
or
related
interviews
of emergency
response
personnel
regarding
adequacy
of
the
licensee's
emergency
response
program
and
faci 1 ities.
Malkthroughs
with shift
supervisors,
performed
during
the
inspection,
disclosed that the licensee
continued to demonstrate
the
capability
to
promptly identify
and
correctly classify
emergency
events
consistent
with
the
current
and
implementing
procedures.
The shift supervisors
were cognizant
of their authorities
and responsibilities
regarding
accident
assessment
and
protective
action
decision-making,
including
onsite
protective
measures
and
recommendations
appropriate
to
offsite protection.
Additionally,
the
inspection
identified that
the
following
emergency
programmatic
elements
were adequate:
notification and
communications;
shift staffing and augmentation;
emergency
plan
and
implementing
procedures;
emergency
facilities
including
equipment,
instrumentation,
and
supplies;
emergency
response
organization
and
management
control; training;
and
independent
'reviews
and audits.
The
ERF appraisal
performed during this period included detailed
review
and
evaluation
of the
onsite
meteorological
facility,
Control
Room,
Technical
Support
Center
(TSC),
Emergency
Operations
Facility
(EOF),
and all
emergency
equipment
and
supplies,
provided therein.
.The appraisal
disclosed
that
equipment
and
supplies
were
adequate
to
support
response
to
emergency
events.
The emergency
program evaluation
and the
appraisal
also
confirmed
management's
continued
attention
to
maintenance
of an effective
emergency
preparedness
program
and
provision
of
emergency
facilities
required
to
implement
the
program.
The following findings,
were
disclosed
which
could
'esult
in nonconservative
dose
estimates
following an offsite
radioactive release:
(1) failure to
use
required
time-averaged
meteorological
data
( 15
minutes)
defined
in
the
emergency
procedure
addr essing
offsite
dose
calculation
and failure to
26
inform
Control
Room
personnel
of
changes
made
at. the
meteorological
tower
regarding
delta
temperature;
and
(2) failure
to establish
and
implement
a
computer
software
control procedure
to ensure
maintenance
and control of the Class
A Model
Dose Assessment
computer.
Two violations were identified.
a.
Severity
Level
IV violation (two examples)
for failure to
use required time-averaged
(15 minutes) meteorological
data
as
defined
in
the Offsite
Dose
Calculation
Emergency
Procedure,
and for failure to inform Control
Room personnel
and reflect respective
change to Control
Room analog chart
records
of hardware
changes
made to meteorological
tower
equipment
addressing
delta temperature
(88-01).
b.
Severity
Level
IV violation for failure to establish
and
implement
a
computer
software control
procedure
to ensure
maintenance
and control of Class
A Dose Assessment
Computer
Model (88-01).
2.
Conclusion
Category:
2
3.
Board Recommendations
The
SALP rating
should
not
be
construed
as
representing
a
dramatic
reduction
in performance
but is indicative of needed
improvement to reach
the level of excellence
achieved
in the
past.
During the period,
problems
were identified in this area
which
indicated
that
more
aggressive
action
is
needed
in
striving for an excellent
program.
Security
and Safeguards
1.
Analysi s
Inspections
were
performed
by the resident
and regional staff.
Additionally, security
wa.
discussed
with the
NRC during monthly
management
meetings
held onsite.
The licensee
had established
a program to upgrade
the security
systems,
barriers,
and
computer.
This effort is part of the
integrated
schedule
and is currently estimated to be complete in
1992.
The
licensee
had
dedicated
four
employees
to
the
maintenance
of the
system until the
upgrade
can
be completed.
There
has
been
some
progress
in maintenance
late
in the
period.
Recently,
a guard force captain
was detailed to track
maintenance
and related
compliance issues'wo
projects related
to the
upgrade
program
are
near
completion,
the
new Contractor
Entrance
Building and the vehicle
entrapment
and
search
area.
With regard to both of these projects,
a weakness
has
been
shown
27
on the part of the security organization to recognize
regulatory
requirements
and to manage
the program upgrade effectively.
The
Contractor Entrance Building work required
a reconfiguration
of
the protected
area barrier,
alarm and surveillance
systems.
The
licensee failed to implement compensatory
measures
and to timely
submit
the
required
security
plan
change.
This failure to
implement
regulatory
requirements
was
not
recognized
by
the
licensee,
but
was identified by the Senior Resident
Inspector.
'everal
layers
of security
management
had
an opportunity to
recognize
this
problem
and failed to do
so.
Subsequently,
a
failure
in
communications
within
the, Security
Department
precluded
the prompt implementation of compensatory
measures.
Work
on
the
vehicle
entrapment
area
was
initiated without
consideration
of
the
necessary
regulatory
requirements;
compensatory
measures
are
currently
in
place
while
an
engineering
redesign is accomplished
to ensure
conformance
with
the
Physical
Security
Plan.
Late in the
SALP period,
the Site
Security
Superintendent
was
assigned
to oversee
the
upgrade
program.
Weaknesses
in the security program
have continued to prevai
1 in
this
SALP period
as indicated
by the
number of violations.
The
violations
continue
to
be repetitive
in nature,
involving
a
failure of the guard force to implement the security program,
an
inability of security
personnel
and
supervisors
to
recognize
violations and
a lack of management
oversight..
These violations
included escalated
enforcement
in the areas
of access
control,
compensatory
measures,
and
the
control
of
Safeguards
Information.
The
licensee
continues
to
show
a
lack
of
initiative in self-identification
of
problems
but
remains
responsive
to
NRC initiatives.
The
1 icensee'
Security
Department
has
failed
to
take
responsibility for the complete security program
and associated
program
problems
and
solutions.
This
was highlighted
by the
licensee's
inaccurate
responses
to
escalated
enforcement
violations.
Statements
were
made to the inspectors
while onsite
and later in an
enforcement
conference
that were not accurate.
More
inaccurate
statements
were
'sent
to
the
NRC
in
the
licensee's
response
to the violations.
This
necessitated
the
licensee
to submit revised
responses
to Reports
87-38 and 87-47.
The
inaccurate
information
can
be attributed to the security
management failing to verify data,
dates,
and
causes,
prior to
providing the
information to other organizations
within FPKL,
which formulate the formal responses
to the
NRC.
In one
case,
Security Management
stated that
a preventive
maintenance
program
had
been
implemented
when in fact no program was
implemented
and
the
hardware
which
had initially failed was
found to
be in
a
failure mode again.
28
The mindset
appeared
to
be
one of writing a response,
handing
responsibility to another
licensee entity to implement
and then
failing to follow up to
see if the other entity
had
performed
the
work necessary
to
ensure
reliable
operation
of security
equipment.
. Ownership
of
the
security
program
was
poorly
managed.
Although
the
licensee
has
made
extensive
plans
to
upgrade
security
facilities
program
and
systems
and
has
provided
additional training
and manpower resources,
these
measures
have
not yet
been
implemented
or have failed to
be effective.
As
di scussed
previously,
the security force failures
and lack of
regulatory sensitivity at all
levels
of the
security
force,
demohstrate
that
although all
members
of the force
have
been
trained,
the
training
management
of
the
force
has
been
ineffective in ensuring
compliance with regulatory requirements
during most of the
SALP period.
Recently,
licensee
corporate
and plant management
have
begun to
provide
support
to the
security
program.
Monthly management
meetings
between
high level licensee
and
NRC management
include
security
program
issues
on
the
agenda.
The
licensee
has
directed
substantial
resources
to improvement of the
security
program
shown by the upgrade
program
and hiring of new managers.
However,
these efforts
have
had limited improvement during the
current
period.'he
licensee
has
made personnel
changes
in the positions of Site
Security
Superintendent,
Site
Security
Manager
and Assistant
Site Security
Manager
and
had
added
one onshift
FP&L security
supervisor,
with four more scheduled
to be hired.
These
changes
came too late in the
SALP rating period to have
an impact
on the
current analysis.
Seven violations were identified during this rating period.
Severity
Level III violation
for failure
to
maintain
positive
access
control,
six
examples:
fai lure
,to
adequately
control access
to the protected
area; failure to
adequately
control
access
to
the
Unit
4
containment
personnel
hatch; failure to adequately
control
access
to
the Unit 3 containment
equipment hatch; officer sleeping
in
defensive
tower; failure to adequately
control
access
to
the
protected
area;
and
an officer leaving
a vital area
compensatory
post without proper relief.
(87-38)
b.
Severity
Level III violation for failure to recognize,
properly mark and protect Safeguards
Information-.
(87-38)
c.
Severity
Level
IV violation for inadequate
protected
area
lighting.
(87-47)
29
d.
Severity
Level IV violation for inadequate
search of vital
area prior to revitalization.
(87-47)
e.
Severity
Level
IV violation for inadequate
compensatory
measure.
(88-03)
f.
Severity
Level IV'iolation for inadequate
protected
area
barriers.
(88-03)
g.
Severity
Level
IV violation for inadequate vital area
alarm
testing.
(88-03)
Conclusion
Category:
3
3.
Board Recommendations
The licensee
has finally given attention
and
resources
to the
security
area,
but continued
to perform at
a category
3 level
during this
SALP period.
It wi 1 1 take
continued effort by the
licensee
to improve performance.
H.
Outages
Analysis
During this evaluation period, inspections
were conducted
by the
resident
and regional
inspection staff.
At the beginning of the
period,
both Units
3
and
4 were in the
shutdown
mode.
Unit 3
entered
a scheduled
refueling outage
on March 11,
1987.
Unit 4
entered
an
extended
outage
on
March 13,
1987,
to repair
corrosion
caused
by boric acid buildup from
a conoseal
leak
on
the vessel
head.
Both outages
were extended to allow extensive
replacement
of environmentally qualified
(Raychem)
electrical
splices
inside
the
containments.
Additionally,
the
Unit 4
. outage
was
extended
in June. 1987 to allow for replacement
of
defective
piping
in
the
post
accident
monitoring
system.
There were four region based
inspectiohs
performed of activities
defined
as Outage related.
The first arid third inspections
were
primarily to review the licensee's
response
to
NRC open
items
including Bulletin 83-06; the
second inspection
was
a review of
primary coolant
system
pressure
isolation (Event V) valves
and
the
pump and valve inservice test (IST) program
and procedures;
and the fourth inspection involved the status of the licensee's
corrective action in response
to Bulletins 79-02 'and 79-14.
The
inspectors
found that
the
level
of management
awareness
and
initiative varied
from adequate
to excellent
depending
on the
particular issue.
Resolution of technical
issues
also varied in
the
same
areas
depending
on which part of the
company
had the
lead in developing
the resolution (e.g.,
the resolution of the
30
problems
associated
with, material s
supplied
by
GULFALLOY
[Bulletin 83-06j
was
handled
in
an
excellent
manner,
while
resolution
of
issues
involvi'ng
Event
V valves
and
the
program were only average).
Throughout this
assessment
period,
there
were
numerous
forced
outages
due to equipment failure caused
by design or maintenance
deficiencies.
There were
a total of eight non-refueling
outages
for Unit 3 and six for Unit 4 during this period.
When required
to enter
a forced
outage
of significant duration,
the licensee
utilized their
Short
Notice
Outage
Work
(SNOW) list, which
identifies all
maintenance
items
requiring
a
shutdown.
New
maintenance
items identified during power operation that require
a plant shutdown to repair are continuously
added to this list.
During this evaluation
period,
a positive
change
in management
philosophy
was
noted in that the
emphasis
is
no longer being
placed
on meeting
startup
schedules
at the
expense
of
needed
maintenance.
This philosophy change
has
been
observed
since the
fall of 1987.
During subsequent
outages,
a
good
number of the
maintenance
activities
were
being
performed
to
enhance
the
physical
condition of the plant
and
not
because
they
were
requi red to return the unit to service.
This
change
in philosophy
has
produced
a
more reliable plant
during the latter part of the period,
as
noted
by the
improve-
ments
in availability
of the
units.
Several
examples
of
extending
outage
times are discussed
below.
The forced outages
demonstrated
adequate
planning
and scheduling
through
use of the
SNOW list and daily meetings to discuss
work
progress
and critical path issues.
One weakness
in the area
of
personnel
accountability
and responsibility was noted.
This has
resulted
in extending
equipment
down
times
due
to
no single
individual
assuming
responsibility
and following up
on delays.
An example
was the recent installation of the Amertap system
on
Unit 4
ICW/CCW heat
exchanger s.
Some changes
in accountability
and responsibility
'were
noted
late
in the
SALP period,
due
mainly to the
new Plant
Manager's
increased
emphasis
in this
area.
Unit 3 encountered
numerous
material
problems
during the first
part of the period,
which required
forced
shutdowns
to repair
defective
equipment.
In August of 1987, while coming out of the
refueling
outage,
a
leak was identified in the inner reactor
vessel
o-ring seal.
A conservative
management
decision
was
made
to correct
the deficiency,
although
plant operation
was
not
disallowed by Technical Specifications.
The repairs
added about
two weeks
to the
schedule
and
required
reactor
vessel
head
removal.
In
September
1987,
the
unit
experienced
one trip
and
one
shutdown
due to equipment malfunction.
During the outages,
the
31
faulty equipment
was repaired,
which included the reinstallation
of
3B
shim that
was
installed
incorrectly
during
the
previous
outage
due to personnel
error.
Additional events that
occurred
during
the
outage
that
resulted
in
an
extension
included:
repair of
RHR leaks,
motor,
and
pump;
seal
table
leakage
repair;
containment
purge valve repair';
RPI repair;
and
replacement. of
RHR recirculation
lines,
which
was
a generic
concern identified by the licensee.
There
were two short forced outages
in December
1987; the first
to repair
a stuck
open pressurizer
spray valve
due to control
circuit malfunction,
and the
second to repair
a defective relay
in the turbine generator
protection circuitry.
Again
in January
1988 there
were
two forced outages,
one to balance
the
due to excessive
vibration
and the other to
correct
pin engagement
on
CROM connectors.
The latter caused
a
dropped
rod and
an eventual
manual trip due to personnel
error
in removing the
CRDM fuses- for testing
(see violation
h in the
Operation
Section).
While preparing
to return
the
unit to
service
the
licensee
was performing
a leak inspection
of all
accessible
areas
inside the containment
and
found
a
small
leak
in
a
CROM canopy
seal
weld.
The leak inspection
was instituted
by management
as
a result of the conoseal
leak discussed
in the
last
SALP report.
Repair of the canopy
seal
extended
the outage
39
days
and
showed
effective
preplanning
in that
welders
practiced
on
a non-radiated
reactor vessel
head at Westinghouse
headquarters
prior to performing the repair to conserve
man-rem
and provide experience
in this type of repair.
The repair work
was documented
by the licensee
on, video tape
and distributed to
other
plants
in the
industry that
may
experience
this
same
failure, thus providing
a free flow of information throughout
the industry for newly identified problems.
In addition,
the
licensee
installed
a radiation monitoring
system
in the
upper
head
region during this outage
to detect future leaks in this
area.
Two short
outages
were required
in March 1988
and
were
caused
by balance-of-plant
(BOP) failures.
One
was
due
to
failed welds in a moisture separator
reheater
(MSR) baffle plate
and the other
was
due to a condenser
tube rupture.
In the
repair,
the licensee
again
showed conservatism
by inspecting all
other
MSRs and repairing questionable
welds even
though only one
MSR had failed.
Unit 4
also
required
several
forced
outages
throughout this
period
due mainly to
BOP failures.
Two short outages
occurred
in July and
September
of 1987 to repair
a condenser
tube leak
and
a
condenser
vacuum
leak.
In October
1987
the unit was
.
placed
in cold
shutdown
as- a precautionary
measure
due to
a
hurricane
warning.
Several
maintenance
items were accomplished
during this
shutdown
which extended
the outage,. including the
replacement
of the
RHR recirculation line,
several
major valve
and actuator
repairs,
and recovery
from high chlorides
in the
CCW system.
In February
1988,
the unit was in a forced outage
due to
a
common
mode failure of the battery chargers.
An
ERT
32
was initiated to determine
the root cause of the failures.
The
ERT identified that the vendor was supplying replacement circuit
cards with capacitors
that were not suited for this application.
This resulted
in the selection
of replacement
capacitors
that
benefited
others
in the industry using this type of charger
as
well as the licensee.
The unit required
two forced
outages
in April 1988 to repair
a
turbine generator'control
oil leak,
due to a failed weld caused
by
a
vendor
manufacturing
deficiency,
and
to
repair
a
pressurizer
spray valve leak.
During the
outage
to repair the
turbine generator
failed welds,
the licensee
rewelded all the
control oil lines that were susceptible
to this failure,
and not
just the failed weld.
During repair of the pressurizer
spray
valve
leak, 'he
licensee
opted
to
extend
the
outage
to
facilitate partial installation of the
Amertap
system
on
the
ICW/CCW heat
exchangers.
This installation
could
have
been
accomplished
with the
unit
on line,
however
the
licensee
accomplished it during the outage to prevent entering
an
LCO if
performed while at power.
In addition,
a design
deficiency in
the
containment
purge
valve air
supply/discharge
lines
was
identified and corrected.
Conclusion
Category:
2
Board Recommendations
None
I.
Quality Programs
and Administrative Controls Affecting Quality
Analysi s
During the assessment
period,
inspections
were conducted
by the
regional
and resident
inspection staffs
on
a routine basis.
For
the
purposes
of this assessment,
this area
is defined
as the
ability of
the
licensee
to identify and correct their
own
problems.
It
encompasse's
all
plant activities,
all
plant
personnel,
as well
as
those
corporate
functions
and personnel
that provide services
to the plant.
The plant
and
corporate
Quality Ass'urance
(QA) staffs
have responsibility 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 quality.
The plant
QA organization
is divided into two sections.
The
Regulatory
Compliance
Section
and
the
Performance
Monitoring
(PMON) Section.
The Regulatory
Compliance
Section
consists
of
ten auditors
with experience
in various disciplines
such
as
chemistry,
health
physics,
training,
design,
metallurgy,
and
instrumentation
and controls.
This Section is responsible
for
33
performing the traditional
QA audits.
This includes,
but is not
limited to,
audits
of
TS,
QA program,
Emergency
Plan,
plant
procedures
and
verification
of
accuracy
of
licensee
correspondence
to
the
NRC.
An
improvement
in this Section
included
conducting
audits
on "real-time" ,plant
issues.
This
has
helped to identify problems
as they occur,
which results in
more timely resolutions.
Another improvement is the involvement
of
personnel
with the
Event
Response
Teams
(ERT).
personnel
have
been
involved
in
providing
technical
and
regulatory/quality
inputs for various
ERTs including:
failure
of containment
purge valves;
high chloride concentrations
in the
CCW; formation of voids in the Unit 4 reactor vessel
head during
a cold shutdown condition;
4B and
4C
ICW pump failures;
and
backup regulator discrepancies.
The licensee
is also
implementing Vertical Slice Audits (VSA);
VSAs are
intended
to
evaluate
the
operational
readiness
and
design
basis
functionality of
selected
plant
systems.
The
Guidance
Document
was
issued
in March 1988,
and
a
VSA on the
ICW system
was
commenced
in early July 1988.
.The
VSA will be
an
ongoing
program
and the licensee
plans to conduct
VSAs for at least
two
systems
per year.
Audits
by
the
Regulatory
Compliance
group
have
resulted
in
several
LERs
being
issued
by
the
plant
concerning
fire
protection,
diesel
fuel oil sampling
and rotation
of battery
pilot cells.
Another audit identified problems with the control
of non-fuel special
nuclear material
(SNM) prior to issuance
of
Information Notice 88-34, which expressed
similar concerns.
The
PMON
section
currently
consists
of
nine
auditors
that
provide more of a Quality Control
(QC) role by monitoring plant
operation,
maintenance,
and
root
cause
analysis
on technical
issues.
Improvements
in thi s area
include dedicating
an auditor
to
monitor
balance
of
plant
(BOP)
activities.
Events
investigated
thus far include:
Unit 3 condenser
tube failure;
Unit 3 moisture
separator
reheater
(MSR) internals failure; and
the Unit 4 guarded oil
system
leak.
Instituting
a dedicated
auditor will help provide
a quality perspective
in determining
root causes
for
system
problems.
PMON
has
also
provided
support
to operational
enhancements
such
as
the
computerized
clearance
system,
computerized
surveillance tracking program
and
also
the centralized
scheduling
organization.
The
PMON group
activities
have
generated
numerous
findings
including:
operation of the waste
gas
system in an alignment not addressed
in the Final Safety Analysis Report
(FSAR);
and
LERs 250/87-25
and
87-28
which involved
mi ssed
surveillance
of control
rod
positions verification and undocumented
surveillance
of ,coolant
loop operability.
Based
on
the
review of
the
Department
audit
findings,
schedules,. corrective action requests
and other site activities,
it appears
that the
QA Department is conducting timely, thorough
and technically.
sound reviews of site activities.
34
The
Regulation
and
Compliance
Group
(Licensing)
has
provided
effective
support
to plant departments
for interpretations
of
regulations
and
Technical
Specifications.
In addition, thi s
group
has actively participated in the review of the revised
TS
project with
and
has
supported
Region II. personnel
in
resolving
and
closing
approximately
900
open
items.
The
Regulation
and Compliance
Group continues to demonstrate
an open
and effective interface with
NRC inspectors,
which facilitates
the resolution of issues that arise.
The licensee
was able to identify and correct problems relating
to safety
as evidenced
by the following actions:
The
establishment
of
a Management-on-Shift
(MOS) program
which
is
instrumental
in
identifying
areas
needing
improvement.
4
The
issuance
of
a "Standards
of Professionalism"
document
to
clearly
define
the
responsibilities
of
licensed
personnel.
The
management
involvement
in the
reduction
of the
PWO
backlog.
Management's
initiative in reducing control
room
PWOs,
to
facilitate efficient operations.
Management's
policy
on
verbatim
compliance
with plant
procedures
to reduce
personnel
errors.
Event
Response
Teams
identification of root
causes
of
significant plant problems
and determination of appropriate
corrective actions.
The
expansion
of
the
Analytical
Based
Preventive
Maintenance
Program
to
include
new
testing
methods,
resulting
in
the
identification
of
numerous
equipment
problems prior to failure.
Design
Bases
Reconstitution
which identified several
plant
design deficiencies.
The
licensee
exhibited
an
inability to either
identify or
correct
(once
identified)
problems
relating to safety
in the
following areas:
Management's
failure
to
develop
effective
corrective
actions
to
resolve
numerous
AFW backup
system
misalignments.
Failure to adequately
control activities in the operations
area
which
resulted
in
nine
examples
of
procedural
noncompliances.
'I
35
Numerous repetitia'e violations in the security area.
Repeti tive maintenance
pr obl ems,
such as:
def ici ency tags
not entered into the tracking system; priorities not worked
on time or are
changed
during
PWO process;
high preventive
maintenance
backlog;
high amount of rework items
on various
safety-related
systems.
Management's
fai'ture to
assure
adequate
staffing
in the
Operation's
Department: to prevent excessive
overtime.
One violation was identified:
Severity
Level
IV '. violation for failure to take
prompt
corrective
action
l to i have
operators
and
non-licensed
operators
review iand acknowledge training reports.
(87-32)
2.
Conclusion
Category:
2
3.
Board Recommendations
The
Board acknowledges:. signtifiicant action taken
by the licensee
to identify and correct. problems.
Specifically, efforts in the
areas
of design
basis;~reconstitution,
independent
management
appraisal,
and management
changes
have
been effective.
However,
the Board noted that 'these efForts were, in part, in response
to
concerns
expressed
by
~ the.
NRC.
The
Board
encourages
the
licensee
to be more proactive in the future.
J.
Licensing Activities
1.
Analysi s
The
licensee
managements's
role
in attempting
to
assure
quality in
licensing-,related
activities
showed
certain
weaknesses
during. the
SALP period, with signs of possible-
improvement
near..the
nend
of the
period.
An
apparent
weakness
in
the<i licensing
organization
has
been
the
interface
and
coordinathon
between
corporate
licensing,
'ite
licensing,;and
operations/modifications
planning
and
scheduling.
Thei lack
of
unification
under
strong
leadership
in thel licending area
was also noted
by Enercon
in their Independent
Management Appraisal.
There
needs
to
be sufficient communiaption
between
these
groups to permit
advance
planning
of liaensing
proposals
such
as relief
requests
and Technical. Specifications
changes
so that they
can
be processed
i.n
an: orderly
manner.
One
example
where
sufficient
communciation
did
not
exist
concerned
containment
tendon
surveillance'lthough
there
are
several
years
between
tendon
surveillances,
a last-minute
proposal
surfaced
hnd both licensee
and
NRC resources
were
36
spent
discussing
a change
in tendon surveillance
Technical
Specifications.
This effort
was
ultimately
abandoned
because
there
was
not
enough
time to
process
a
change
before
the
next
surveillance..
Another
example
was
relaxation
of
Technical
Specifications-
for
heat
exchangers.
In order
to install
the
Amertap
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 af
and
instead
the
proposal
was
processed
by
the
staff
as
an
exigent
amendment.
Better
coordination
and
planning
would .have
foreseen
the
need for the'S
relaxation
and
avoided
the
need for an exigent
amendment.
Throughout
most of the
SALP period 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
Nanager'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.
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
schedules,
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
comprehensive
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.
The licensee's
approach
to resolution of technical
issues
has
been
adequate.
A special
inspection
was
held during
the
week of December
7, 1987'o
examine activities in the
37
areas
of safety
review pursuant
to
and the
on-site
and off-site review committees.
Steady
improvement
in the quality
and
completeness
of
safety
evaluation
documentation
was
observed'.
Recent
safety
evaluations
audited during the inspection
were sufficiently
detailed
to
demonstrate
the
logic
and
bases
for
determinations
regarding
potential
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'or
PNSC
review seemed
to be needed.
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'icensee
volunteered
several
years
ago to upgrade
their
TS to modified Standard
TS.
During this
SALP period
a significant effort was
made
by the licensee
to resolv'e
technical
issues
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
a'pproach
to this issue
has
been
to
make
a
very significant
commitment
in financial
and
personnel
resources
to enhance
emergency
power supplies
by committing
to
add
two
new
safety-grade
diesel
generators
with
associated
equipment.
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
presented.
This permitted
rapid technical
review and
issuance
of a
license
amendment
at
a later 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 failures,
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
request
was
denied.
At the
end of the
SALP period the
licensee still
has
not proposed
an alternate
TS for the
third ICW pump.
38
In another
matter regarding
the allowable
outage
time for
diesel
generators,
the
licensee
made it clear
that
the
issue
was
important
to
plant
operation.
However,
conference calls to resolve
the issue
were twice postponed
by
the
licensee
and,
when
finally
held,
evidenced
inadequate
technical
preparation
to fully address
the
issue.
The'issue
remains to be resolved.
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
Management
System.
Other
examples
were the
provision of information related
to
surveys
of
reactor
vessel
support
structures,
and
the
use
of Bunker
Ramo
containment
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 rerack
hearings
were completed during
this
SALP period.
The licensee
was especially
responsive
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.
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 meeting
attendance
and
has
been very responsive
to
NRC inqui ries.
The corporate
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
i'n interpreting Technical
Specifications,
evaluating
root
causes,
preparing
reports
to
NRC,
and
translating
operational
needs
into licensing actions.
The Independent
Management
Appraisal
by Enercon
recommended
increasing
the
size
of that
group.
In
response,
the
licensee
has
increased
the
number of authorized positions
from 5 to 9.
As part of the effort to improve performance
in the area of
reviews,
the
licensee
issued
equality
Instruction 3.9
on April 20,
1988, entitled
"Evaluations
Performed
by Power Plant Engineering."
This gI is intended
39
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 site.
Conclusion
Category:
2
Board Recommendations
None
K.
Training and (qualification Effectiveness
Analysi s
Early in the
SALP period, close out inspections
conducted
in the
area
of training indicated that the licensee
has
continued
to
make
improvements.
The licensee
has addressed
inadequacies
and concerns identified
during
the
previous
period
in
the
Licensed
Operator
Requalification
Program
by providing more qualified instructors,
hiring qualified contractor
instructors,
enhancing
instructor
classroom training,
and implementing
an effective tickler system
to ensure
the incorporation of emergent
training
and briefing
m'aterial
into
permanent
lesson
plans.
The licensee
has
also
prohibited Senior
Reactor
Operator
(SRO)
licensed
instructors
who
have failed
NRC requalification
examinations
from 'teaching
licensed operators,
eliminated contract instructors
who were not
commercially
licensed
from the license training programs,
contracted
15 formerly licensed
SRO instructors,
and
implemented
a five week site specific
systems
training course for contract
instructors.
Another
improvement
was
the
development
of
the
Training
Information
Management
System
(TRIMS) which'ensures
that only
qualified personnel
are
assigned
to perform maintenance
tasks.
The
TRIMS program is also
designed
to provide:
configuration
control
of training materials;
management
of
personnel
and
program training records;
maintenance
of examination
questions
and relative statistical
data;
maintenance
of class
data
and
training
program
schedules;
and
maintenances
of the tracking,
documenting,
and updating of training commitments.
The
licensee
has
made
improvements
in the
required
reading
program,
which
provides
operational
" experience
feedback
.
information
to
Operations
personnel
on
a
regular
basis.
Improvements
include
upgrades
in the procedural
controls
over
documentation
and timeliness of operational
experience
feedback
reviews,
and the screening
of revised procedures
to ensure that
only
relevant
information
is
forwarded
to
the
operators.
40
However,
as noted in the
gA section,
a violation was issued
due
to management'
failure to take
prompt corrective
action for
identified deficiencies
pertaining to licensed
and non-licensed
operators
who
h'ad
- assumed
unit
responsibilities
without
completing
the required
reading.
This violation indicates that
improved management
control over the required reading
program is
needed.
On
January
26-28,
1988,
replacement
examinations
were
administered
to
seven
'SRO
candidates
and
one
individual
was
administered
an
SRO retake written examination.
All candidates
passed.
Two.areas of below normal
performance
were noted in the
written examination.
These
areas
were
knowledge
of bypasses
associated
with the manipulator crane interlocks,
and
knowledge
of whole body dose
emergency
exposure limits for various reentry
situations.
No areas
of generic
weakness
were noted during the
oral examinations.
With respect
to the licensed
operator requalification
program,
the
last
requalification
exams
were
administered
in
February
1986.
The results
of these
exams
wer e considered
in
the
previous
SALP report,
which stated
that
the
licensee's
performance
on
the
exams
was
poor
and
the requalification
program
was
unsatisfactory.
In this
current
period,
requalification
examinations
were
not administered at, Turkey
Point
because
the
NRC
has
suspended
its
requalification
activities in the industry.
The licensee's
program will receive
reevaluation
at
a future date,
pending
resumption
of the
NRC
administered requalification examinations.
Other
non-licensed
employee training
was
assessed
during this
period.
As
noted
in
the
Radiological
Controls,
Fire
Protection,
Emergency
Preparedness
and
Engineering
Support
sections of this report, training in these
areas
was
determined
to
be
adequate,
with improvement
noted
in the health
physics
area of the general
employee training program.
In
the
area
of
Survei llances;
the
training
of technica'l
personnel
was satisfactory,
yet the training of personnel
who
specify
and write repair
and retest
procedures
needs attention.
In the Security. and Safeguards
area, it was noted that training
measures
were either
not
implemented,
or
have failed to
be
effective in ensuring
compliance with regulatory
requirements.
It was
noted that
in the
Operations
'area,
some
performance
issues
stemmed
from root causes
related to training.
Six
training
programs
received
accreditation
by
in
December
1987,
resulting
in all ten original training programs
being accredited.
Conclusion
41
Category:
2
Board Recommendations
None
L.
Engineering
Support
Analysi's
The licensee
has successfully
implemented
a number of corrective
actions
to
improve
technical
support.
These
have
included
detailed
reviews of selected
safety
systems,
reconstitution of
system
design
bases,
standardization
of design
packages
for
controlling
changes,
increased
staffing
and training
on
the
plant change
process.
The
design
.basis
reconstitution
effort,
in conjunction with
system
reviews
and walkdowns,
has
been particularly beneficial
in
that
numerous
design
related
deficiencies
have
been
identified and corrected.
The Engineering
Departments
have,
in
all instances,
responded
promptly and adequately
to, identified
problems.
Several
of the problems
were corrected
on
a real time
basis,
although
administrative
justification
for
continued
operation until scheduled
outages
could have
been
pursued.
The
efforts to minimize operating
the
plant
around
problems
has
shown
improvement.
The
licensee
has
been
conducting
repairs
when
required.
Examples
of safety-related
deficiencies
which
were identified
and
addressed
on
a
real
time basis
include;
waste
gas
system
operation
in
an
unevaluated
configuration
(October
1987),,
inappropriate
design
of
the
residual
heat
removal, 'ecirculation
flow
path
(October 1987),
and
post-injection
recirculation
valve
alignment
resulting
in
insufficient net positive
suction
pressure
to safety-related
pumps
(Nay 1988).
Corrective actions
to preclude
recurrence
of boric acid leaks
similar to the
conoseal
leak during the last
SALP period
have
been
implemented,
resulting
in
a vigorous
program to identify
and correct
even minor primary leakage.
This effort resulted in
the identification and correction of small conoseal
leaks
on the
Unit 3 reactor
in July 1987.
Additional sensitivity to primary
leakage
was demonstrated
in August 1987,
when
a decision
was
made
to
remove
the Unit 3 reactor
head to correct
a leaking
inner 0-ring.
Continued plant operations
with this deficiency
could
have
been
justified
had it occurred
during
power
operation.
However,
the licensee's
position
was that quality
precepts
dictated that
a post-refueling
power cycle not begin
with an avoidable deficiency.
During this assessment
period,
reviews were performed to assess
th'e adequacy
of engineering
evaluations.
The
NRC found evidence
of significant improvement in the quality of safety evaluations
42
over
those
performed
during
the
previous
period.'dditionally,
trends
were
identified
which
indicated
that
continued
improvement
would result
as
procedures
and training
continued to be implemented.
In
general,
safety
evaluations
reviewed
were
sufficiently
detailed to demonstrate,
as stand-alone
documents,
the logic and
basis for determinations
regarding
potential
unreviewed
safety
questions.
Safety
evaluations
were
performed
for all plant
modifications,
even
those classified
as non-safety
related,
to
preclude
the possibility of unexpected
adverse
impact
on the
plant.
Detailed
equality Instructions
have
been
developed
and
implemented after completing training to control the methodology
'used
in completing
reviews
and design
equivalent
engineering
packages.
The design
equivalence
program
has
been
particularly effective in verifying that appropriate
component
substitutions
are
selected
when current
equipment is no longer
available.
The procedures
for controlling Temporary
System Alterations are
detailed
and effective.
Evaluations to support the alterations
meet
the
requi rements
of
and
receive
numerous
reviews
including
the
Shift
Technical
Advisor,
Technical
Department
Supervisor,
Plant
Supervisor-Nuclear
and
Plant
Nuclear Safety
Commi.ttee.
The temporary alterations
are audited
quarterly to ensure
.continued validity.
The
level
of detail
included
in
the
safety
evaluations
has
increased
over that
.
existing during the previous
assessment.
Violation i,
in
the
Operations
functional
area,
documents
a
single
isolated
example
of the failure to perform
a required
Temporary
System Alteration evaluation.
Violation a,
in the
Operations
functional
area,
occurred,
in
part,
due to an unacceptable
safety evaluation, performed
on the
intake cooling water.
Although the
problem
was identified in
June
1987, it should
be noted that the deficient evaluation
was
issued
in August 1986.
The
safety
evaluation
allowed brief
system
operation
in
a
mode
which
was
susceptible
to single
failure.
Consequently, it constituted
an
unreviewed
safety
question
which was not recognized
by the Engineering
Department.
Additional
reviews
of safety
evaluations
indicate
that this
problem is not programmatic.
Some
engineering
resolutions
to identified deficiencies
have
been resolved
by administratively controlled compensatory
action
in the short term.
Some significant plant modifications must be
implemented to allow completion of long term fixes.
Plans exist
to install two additional
emergency
diesel 'generators
on site by
late
1991.
This is necessary
to provide a'dditional
margin for
emergency
loads
assuming
the loss of offsite power, failure of a
single diesel
and the initiation of a loss of coolant accident;
Until this upgrade is completed,
the plant must rely on portable
43
instrument air compressors
'to operate
the instrument air system.
The temporary
compressors
have
been in use since
1986
'ong
term compensatory
action
has
been required to ensure that
a
valve with single failure deficiencies
in the
Intake
Cooling
Water
system will shut
under
certain
accident
conditions.
Periodic
valve watches
have
been
required
since
1985.
Unit 3
corrective
action in mid 1987,
included the installation of an
automatic
cleaning
system for the
system
heat
exchangers.
A
similar
system will be
functional
on Unit 4 by October
1988.
However,
the corrective action
has
reduced,
but not alleviated
the
need for the Unit 3 valve watch.
On
one
occasion
in the
spring of 1988, the compensatory
valve watch was found asleep
at
his post.
The
use of non-seismic
pressure
in engineering
designs
has
contributed
to
problems
described
in
the
Operations
functional
area.
For example,
several
non-seismic
were
installed
in
the
auxiliary
(AFW)
backup
system.
Since
the
system
must
meet
seismic
requirements,
the
were
normally
isolated.
Several
system violations occurred
when the gauges
were valved
in contrary
to
procedure.
Violation m,
in
the
Operations
functional area,
documents
three
examples of the plant personnel
opening
a
non-seismic
boric
acid
transfer
pump
discharge
pressure
gauge required to be shut.
Non-seismic
pressure
also exist in other safety related
systems,
which have
had minor
valve misalignments.
Violation g,
listed
in
the
Operations
functional
area,
represents
an
isolated
example
of the failure
to translate
design
input into
operating
procedures
for the
AFW backup
system.
Modifications to the
system
were
performed for Unit 4 in mid 1986,
and Unit 3 in the spring of
1987.
The
engineering
packages
were
essentially
identical.
Calculations
were performed to assure
that the expanded
capacity
allowed
the requisite
duration of
system
operation.
The
bases
for the calculations
were not fully explained in the
engineering
package.
Consequently,
design
basis
usage
rates
were
taken
out of context
and incorporated
in AFW system
surveillance
procedures.
This
resulted
in
surveillance
procedures
with
non-conservative
acceptance
criteria,
which
failed to verify full system operational capabilities.
This
problem
occurred
because
site engineering
personnel
were
not supplied with the original calc'ulations
used
by a contract
organization
in
developing
design
consumption
rates.
A
description
of
the
consumption
rates
contained
in
the
engineering
package
summary
was too vague to supply the proper
context
for their
inclusion
in
surveillance
procedures
as
acceptance
criteria.
The
existence
of this
type of deficiency
was
the result
of
ineffective
use
of
the
licensee's
system
engineers.
The
program,
which is designed
to centralize
knowledge
of system
characteristics
and requirements
in
a single engineer,
has not
resulted
in
the
identification
of
the
kinds
of
concerns
discussed
above.
An additional
example
includes
violation a
listed in the Operations
functional
area.
The system'ngineer
for the intake cooling water
system failed to ensure
that the
heat
exchangers
were cleaned
on
an appropriate
schedule
and in
the correct
sequence.
Additionally, although
a
system existed
requiring detailed analysis of heat
exchanger
efficiencies,
the
engineer failed to realize that design
basis
assumptions
were
'not met.
In part, this problem area existed
because
the
system engineers
did not monitor closely
enough
the
status
of their assigned
systems
through
work order
reviews,
design
change
analyses,
frequent
system walkdowns
and status
evaluations.
,Consequently,
identifiable problems
may not be identified in a timely manner.
For
example,
violation 1,
in the
Operations
functional
area,
documents
that certain
intake cooling water
flow meters
were
removed
from the
system without administrative justification.
Although the
meters
were
absent
for
many
months,
the
system
engineer
did
not
independently
pursue
the
discrepancy
and
therefore
remained
unaware
of the
problem.
Also, the engineer
was
not aware that plant log sheets
allowed
an intake cooling
water
pump
dis'charge
pressure
band
which
was
so
large that
conformance
with design
flow rate
requirements
might not
be
possible.
A new administrative
procedure
was implemented during
this
assessment
period which
requires
the
system
engineer
to
perform regular reviews of system logs and instrumentation,
and
to perform periodic system walkdowns.
These
requirements
should
prevent
some of the problems discussed
above
from occurring.
The
recently
completed
Independent
Management
Appraisal
concluded
that
problems
associated
with the
system
engineering
~
program
included;
lack of
management
follow-up to
assure
effective
system
engineer utilization, lack of clear definition
of system
engineer
responsibilities,
lack of authority to obtain
the
support
needed
to
resolve
problems,
and
inadequate
fulfillment of assigned
responsibilities.
The
system
engineers
spend
a large percentage
of time processing
paperwork instead of
solving system problems.
These
deficiencies
have
resulted
in
an
environment
in which
system
engineers
primarily react to problems.
They do not have
sufficient
time,
nor
are
they
directed
to
prevent
future
problems.
There
is little trending
of
performance
data.
Reliability engineering
has not been achieved
because
potential
system
problems
are not resolved before they occur.
In the spring of 1988,
a
new Technical
Department Supervisor
was
appointed.
A number
of initiatives
are
being
developed
to
45
address
the
above
concerns.
These
include
less
reliance
on
contractor
personnel
to perform
system
engineering
functions,
increased
staffing to reduce
the
number of systems
assigned
to
each
engineer,
increased
training 'nd
increased
supervisory
involvement.
While it is expected
that these
initiatives will
have
a favorable
impact, it is too
soon to determine
whether
they will ultimately be successful.
Two violations were identified:
a.
Severity
Level
IV violation
for failure
to
conduct
modification
testing
as
a
result
of
an
inadequate
procedure.
(87-41)
b.
Severity
Level
IV violation for fai lure to use the proper
material
in intake cooling water system.
(88-14)
2.
Conclusion
Category:
2
3.
Board Recommendations
Although improvement
has
been
noted
in the Engineering
Support
area,
continued
management
attention is warranted.
V.
SUPPORTING
DATA AND SUMMARIES
A.
Licensee Activities
At the start of the assessment
period, Unit 3 was in a refueling and
maintenance
outage
that
started
March 11,
1987.
On
September
12,
1987, the unit returned to power operations;
the extended
outage
was
caused
by repair work on Raychem splices,
diesel
generator
sequencer
wiring checks
and testing,
and
a reactor vessel
0-Ring leak.
Other
outages
included those discussed
under Item J
and the
following non-scheduled
maintenance
outages:
On September
25,
1988,
a
maintenance
outage
occurred
to
investigate
and
repair
high
vibrations
on
a reactor
coolant
pump
and to repair
a pressurizer
spray
valve.
The unit remained
down to repair additional
items
including
a
design
deficiency
with
the
residual
heat
removal
recirculating piping.,
The unit returned to service
on
December
22,
1987.
Additional
maintenance
outages
occurred
from
March
16 to
March 23,
1988,
due to weld repairs
to cracked
moisture
separator
reheater
baffle plates
and
on March 24,
1988, to repair
a condenser
tube
leak.
On
March 30,
1988,
the
unit
returned
to
commercial
operations
and
remained
at
power through the remainder
of the
period.
Unit 4 was in an extended
maintenance
outage at the start of the
period
and did not return to service unti 1 July 8,
1987.
On July 15,
1987,
the unit was
shut
down to repair
a condenser
tube
leak
and
returned to power operations
on July 21,
1987.
On September
6,
1987,
46
the unit was
shut
down for 576 hours0.00667 days <br />0.16 hours <br />9.523809e-4 weeks <br />2.19168e-4 months <br /> to repair
a damaged
drain line
which was
causing
a
condenser
vacuum
problem.
The unit operated
at
power
until
October
12,
1987,
when it
was
shut
down
as
a
precautionary
measure
for
a hurricane
warning.
The unit remained
down until
December
4,
1987,
to repair
a safety injection
pump,
a
leaking
PORV,
and correct
a, design deficiency with the residual
heat
removal
recirculation piping.
On
February 7,
1988,
the unit shut
down
on declaring
two battery charges
out-of-service.
While the unit
was
down,
work was
performed
on
a reactor
coolant
pump
motor
and
control
rod drive mechanism
cables.
The unit returned to service
on
February
24,
1988.
On April 6,
1988,
the unit was shut
down for a 33
hour
period
to repair
a
turbine
control oil
system
leak.
On
April 28,
1988,
the
unit
was
shut
down
to
repair
a
leaking
pressurizer
control
spray
valve
and
remained
down
to
repair
a
containment
purge
isolation
valve.
The
unit
returned
to
power'perations
on
May 28,
1988,
and
remained
at
power
through
the
remainder
of the
SALP period.
B.
Inspection Activities
The routine inspection
program
was performed during this period, with
special
inspections
conducted
to augment
the program
as follows:
1.
June
15-19,
1987,
concerning
of
a series of loss of boric acid
flowpath events,
the status
of licensed
operator training,
and
instructor qualifications.
2.
September
22
October 25,
1987,
in the areas
of unauthorized
dilution event
and resolution of issues
raised
by
a
licensee
personnel.
3.
November 4-6,
1987,
in the area of void formations in the Unit 4
reactor
vessel
upper
head
region
during
cold
shutdown
conditions.
December 7-11,
1987,
in the area
of safety
review activities,
including
determinations
and
safety
review
committee functions.
December
14-16,
1987, in the area of IE Bulletin 83-06.
6.
February 22-25,
1988, in the area of Emergency
Response
Facility
Appraisal.
C.
Licensing Activities
1.
NRR/Licensing Meetings
The
licensee's
presentations
were
generally well'tructured.
The licensee
was generally well prepared
for meetings with the
NRC staff'nd handled
the staff'
questions
adequately.
A list of NRR/Licensee
meetings is
shown below:
Date
Pur ose
June
4,
1987
Discussion of Emergency
A.
C.
Power
Enhancement
June
17-18,
1987
June
23,
1987
Discussion of TS Improvement Project
Discussion of Boraflex in Spent
Fuel
Pool
Racks
June
22-23,
1987
August 26-27,
1987
'September
2,
1987
Discussion of TS Improvement Project
Discussion of TS Improvement Project.
Discussion of FP&L Electrical
Transmission
System
October 20-22,
1987
December
15-17,
1987
January
6,
1988
Discussion of TS Improvement Project
Discussion of TS Improvement Project
Discussion of Schedule for Technical
Specification
Conversion Project
January
28,
1988
Clarification of Use of Technical
Specification in Control
Room
February 23-26,
1988
Discussion of Technical Specification
Improvement Project
March 15,
1988
Discussion of ICW/CCW TS and
Operability of
CCW Heat Exchangers
March 28-31,
1988
Discussion of Technical Specification
Improvement Project (Electrical)
May 18,
1988
Discussion of Improvements to
Integrated
Schedule
June
2,
1988
Discussion of Seismic Adequacy of
Components
I
2.
Commission Meetings - None
3.
Schedular
Extension
Granted
None
4.
Reliefs Granted
48
June
15,
1987
March 28,
1988
S.
Exemptions
Granted
August 12,
1987
Relief
Request
No.
16
Relief
From Visual
(UT-2) Examination (Unit 3)
Relief
Request
No.
17
Relief
From Visual
(UT-2)'Examination (Unit 3)
Technical
Exemption
from
Appendix
R Requirements
6.
Emergency or Exigent Technical Specifications
Issued
Apri 1 29,
1988
Exigent
Technical
Specification
to
the
Component
Cooling Water System.
7.
Discretionary Enforcement
December
31,. 1987
Discretionary
enforcement
granted for
a
24
hour extension
of TS 3.4.5.a
concerning
ICW
pump operation.
January
15,
1988
Discretionary
enforcement
granted
for
TS
Chapter
6,
figure
6.2-2
concerning
the
requirement for the Operation
Superintendent
to hold an
SRO license.
Febr vary 24,
1988
Di scretionary
enforcement
granted for a
24
hour extension
of
TS 3.0. 1
concerning
the
recalibration
of
the
steam
generator
instrument channels.
8.
License
Amendments
Issued
Amendment
Numbers
Unit 3
Unit 4
Descri tion
Date
124
118
Revise the
TS for the auxiliary
06/08/87
system
and the condensate
storage
tanks
125
119
126
120
127
121
128
122
Incorporate
TS for reactor vessel
level monitoring system
Integr ated Scheduling
Revise the
TS for the D.C. power
source
Delete remaining Sections
1.0
and 5.0 of the environmental
TS and replace it with an
Environmental
Protection
Plan
07/28/87
11/23/87
04/18/88
04/25/88
49
129
123
Organization
changes
per Generic
04/28/88
Letter 88-06
130
124
Revise the
TS for the component
cooling water system
04/29/88
D.
Investigation
Review
An investigation
was conducted
on the events
surrounding
the
manipulation of reactor controls
by a non-licensed
person.
E.
Escalated
Enforcement Actions
1.
Civi 1 Penalties
a
~
A Notice of Violation (Severity
Level III, Supplement I),
and
a
Proposed
Imposition of Civil Penalty
(EA 87-97) for
$ 100,000
were
issued
on July 21,
1987,
for failure
to
adequately
evaluate
and correct
a reactor coolant leak and
failure to assure
the required prerequisites
were met prior
to
commencing
This violation, although
issued during the current
SALP period,
was addressed
in the
previous
SALP.
b.
Three Notices of Violation (Severity Level III, Supplement I)
and
a Proposed
Imposition of Civil Penalty
(EA 87-85) for a
total of $225,000 were issued
on October
18,
1987, for the
following:
1) fai lure to adequately
establish
or implement
procedures
to assure
configuration control over the safety-
related
emergency
boration
system; .2) failure to meet the
Technical
Specification
requirement
for
maintaining
auxiliary
system
for Unit 4 operable;
and
3)
operation
of the intake cooling water
system
outside
the
plant
design
basis.
These
violations,
although
issued
during
the
current
SALP period,
were
addressed
in
the
previous
SALP.
c.
Two Notices of Violation (Severity Level III, Supplement III)
and
a Proposed
Imposition of Civil Penalty
(EA 87-98) for a
total of $ 100,000 were issued
on July 28,
1987, for failure
to maintain access
cont'rol
and to conduct
adequate
vehicle
'earch.
The
licensee's
request
for mitigation of the
Severity
Level
and Civil Penalty
resulted
in the Civil
Penalty
being mitigated
on
November 5,
1987,
to
$75,000.
These violations,
although
issued
during the current
period,
were addressed
in the previous
SALP analysis.
d.
Two Notices, of Violation (Severity
Level III, Supplement
III) and
a Proposed
Imposition of Civil Penalty
(EA 87-179)
for $ 150,000 were issued
on February ll, 1988, for failure
to
maintain
positive
access
control (six
examples)
and
fai lure to protect safeguards
information'
4
50
Orders
An
order
imposing
the
licensee's
commitments
to
have
an
independent
review of management
and operational activities,
and
an
assessment
of required
changes
was
issued
on
October
19,
1987.
F.
Licensee
Conferences
Held During Appraisal
Period
June
5,
1987,
Enforcement
Conference
to discuss
the following
issues:
inadequate
protected
and vital
area
access
control;
emergency
diesel
generator
sequencer
wiring errors; failure to
establish
containment
integrity during
and
inadequate
safety evaluation of the conoseal
leakage.
June
24,
1987,
Working
level
discussions
on
Turkey
Point's
Performance
Enhancement
Program
(PEP).
July 29,
1987,
Enforcement
Conference
to di scuss
the loss of
boric acid flowpath and auxiliary feedwater
system inoperability
due to i'solation of the safety-related
nitrogen supply.
July 30,
1987,
quarterly
Performance
Enhancement
Program
management
meeting.
July 30,
1987,
Management
meeting to discuss
SALP assessment.
October 28,
1987,
Enforcement
Conference
to discuss
security
issues.
November
18,
1987,
Management
meeting
to discuss
the initial
independent
audit plan.
November 24,
1987,
Management
meeting to discuss
the Independent
Management
Appraisal
Plan
and
the
Management-on-Shift
Program
(MOS).
10.
December
21,
1987,
Management
meeting to discuss
the Independent
Management
Appraisal,
Management-on-Shift
Program,
category
3
areas,
and
an
Enforcement
Conference
on security
issues.
January
25,
1988,
Management
meeting to discuss
the Independent
Management
Appraisal
Plan, MOS,'nd the Performance
Enhancement
Program status.
12.
March 2,
1988,
Management
meeting
to discuss
the
Independent
Management Appraisal
Plan
and the
MOS Program.
April 21,'988,.
Enforcement
Conference
to di scuss
emergency
preparedness
issues.
II
~ ~
~
51
G.
13.
April 22,
1988,
Management
meeting
to discuss
the
Pr ogram
and
SALP category
3 areas.
14.
June
10,
1988,
Management
meeting
to discuss
the
Independent
Management
Appraisal,
MOS Program
and
Performance
Enhancement
Program status.
Confirmation of Action Letters
(CALs)
CAL 50-250,251/87-01
i ssued
on
October 6,
1987,
requiring that
a
specific reactor
operator
not
assume
his
normal duties without
NRC
approval.
H.
Licensee
Event Report Analysis
During the assessment
period,
51
LERs for Units
3 and
by the
NRC staff.
The distribution of these
events
determined
by the
NRC staff,
was
as follows:
Cause
Unit 3
Unit 4
4 were analyzed
by cause,
as
Total
Component Failure
Design
Construction,
Fabrication,
or Installation
Personnel
Operating Activity
Maintenance Activity
- Test/Calibration Activity
Other
10
8
10
2
Out of Calibration
Other
TOTAL
24
27
51
V
~l
I.
Enforcement Activity
52
UNIT SUMMARY
FUNCTIONAL
AREA
NO.
OF DEVIATIONS AND VIOLATIONS
IN EACH SEVERITY LEVEL
D
V
IV
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
and Safegurads
Outages
Quality Programs
and
Administrative Controls
Affecting Quality
Licensing Activities
Training
Engineering
Support
3/3
3/2
5/7
3/2
3/3
2/3
0/1
1/1
2/2
5/5
2/2
2/2
TOTAL
6/5
21/25
5/4
FACILITY SUMMARY
FUNCTIONAL
AREA
No.
OF DEVIATIONS AND VIOLATIONS IN EACH
SEVERITY LEVEL
IV
III
II
I
Plant Operations
Radiological Co~trois
Maintenance
Sur veil lance
Fire Protection
Emergency
Preparedness
Security
and Safeguards
Outages
Quality Programs
and
Administrative Controls
Affecting Quality
Training and Qualifications
Licensing
'Engineering
Support
Total
6
7
3
3
3
1
1
2
5
2
25
5
53
Four unplanned
reactor trips and three
manual
shutdowns
occurred
during this evaluation
period for Unit 3.
Unit 4 sustained
six
manual
shutdowns.
The unplanned trips and shutdowns
are listed
below.
1.
Unit
September
13,
1987, Safety injection actuated
and the
reactor tripped from five percent
power
due to failed high
steam flow channels
and personnel
errors while performing
a
turbine generator
cverspeed trip test.
September
25,
1987, the unit was manually shut
down from
power operations
due to high vibration on
pump.
C.
Oecember
25,
1987, while attempting
a controlled shutdown,
the reactor tripped from subcritical conditions
when
a
source
range detector,
which had
been
taken out of service
without bypassing its trip signal,
spuriously energized
above its setpoint.
Insufficient procedural
guidance
was
cited as
a primary cause,
with circuitry problems
as
a
contributing cause.
d.
Oecember
29,
1987, the reactor
was manually tripped from
approximately
70:o power due to contact failures in the
turbine overspeed
protection relay and the resultant
loss
of turbine load.
f.
g.
January
13,
1988, the unit experienced
a turbine runback
from 1005 power and
a subsequent
manual reactor 'trip due to
dropped control rod assemblies.
Narch 16,
1988, the unit was shut
down to repair
a weld
crack on moi sture separator
reheator baffle plates.
Harch 24,
1988,
the unit was shut
down from approximately
30% power due to
a condenser
tube leak.
2.
Unit
b.
July 17,
1987,
the unit was shut
down to hot standby to comply
with Technical Specification
requirements
due to a steam
supply
leak in the auxiliary feedwater
system.
September
6,
1987, the unit= was shut down due to losing
vacuum
as
a result of a bearing drain failures
on the main
pump.
~ C
'tl
54
c.
October
12,
1987,
the unit was shut
down as
a precautionary
measure for a hurricane warning.
d.
February 7,
1988, the unit was shut
down from 100K power
due to exceeding
the Technical Specification action state-
ment for inoperable battery chargers.
e.
April 6,
1988,
the unit was shut
down to investigate
and
repair
a leak in the turbine control oil system.
f.
April 28,
1988 the unit was shut
down due to increased
leakage
(3.2
gpm) caused
by a pressurizer
spray valve
bellows rupture.
K.
Radioactive Effluent Releases
(Ci/YR)
Activity Released
(Curies)
1.
Gaseous
Effluents
Fission
and Activation
Gases
and Particulates
1985
3.12
0.015
310
1986
4.65
0.023
593
1987
1.70
0.025
820
2.
Liquid Eff1 vents
Fission
and Activation
Products
0.9
869
0.506
727
0.75
540
3.
Personnel
Contaminations
a.
Turkey Point
b.
Region II PWR Average
4.
Contaminated
Area (ft~)
a.
Turkey Point
b.
Region II
5.
Collective
Dose
(Man-rem)
a.
Turkey Point
b.
Region II PWR Average,
6.
Solid Rad Waste
(fthm)
a.
Turkey Point
b.
Region II PWR Average
437
306
23,821
16,023
645
390
4,300
14,497