ML17346A649
| ML17346A649 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 11/27/1984 |
| From: | Mcdonald D Office of Nuclear Reactor Regulation |
| To: | Bernero R, Eisenhut D, Vollmer R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8412070069 | |
| Download: ML17346A649 (18) | |
Text
Docket Nos.
50-250 and 50-251 MEMORANDUM FOR:
Darrell G. Eisenhut, Director Division of Licensing Robert M. Bernero, Director Division of Systems Integration Richard H. Vollmer, Director Division of Engineering Hugh L. Thompson, Director Division of Human Factor Safety Themis P.
Speis,, Director Division of Safety Technology Distribution NRC PDR Local PDR ORB¹1 Rdg.
Memo file HDenton CParrish DMcDonald 4C4Q THRU:
FROM:
SUBJECT:
Gus C. Lainas, Assistant Director for Operating Reactors, DL Steven A. Varga, Chief Operating Reactors Branch ¹1, DL Daniel McDonald, Project Manager Operating Reactors Branch ¹1, DL DRAFT OF THE NRR INPUT FOR THE SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)
FOR FLORIDA POWER AND LIGHT COMPANY'S (FPL)
TURKEY POINT PLANT 'UNITS 3 AND 4 - JULY 1983 TO OCTOBER 1984 Enclosed is a draft of the NRR input to the SALP review for the Turkey Point Plant Units 3 and 4.
This draft report is based partly upon input solicited from selected staff personnel who have had substantial contact and involvement with FPL licensing material.
Please review the draft evaluation and provide any comments you feel appropriate.
All comments received by December 4, 1984 will be considered in the final report.
Your comments may be provided verbally due to the short turnaround time.
/s/DGMcDonald Daniel G. McDonald,.Project Manager Operating Reactors Branch ¹1 Division of Licensing
Enclosure:
As stated cc w/enclosur H.Dento ORB¹1:
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Docket Nos.
50-250 and 50-251 MEMORANDUM FOR:
THRU:
FROM:
SUBJECT:
UNITEDSTATES NUCLEAR R EGULATORY COMMISSION WASHINGTON, D. C. 20555 November 27, 1984 Darrell G. Eisenhut, Director Division of Licensing Robert M. Bernero, Director Division of Systems Integration Richard H. Vollmer., Director Division of Engineering Hugh L. Thompson, Director Division of Human Factor Safety Themis P. Speis, Director Division of Safety Technology Gus C. Lainas, Assistant Directo for Operating Reactors, DL Steven A. Varga, Chief Operating Reactors Branch
- Intel, DL Daniel McDonald, Project Manager Operating Reactors Branch 81, DL DRAFT OF THE NRR INPUT FOR THE SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)
FOR FLORIDA POWER AND LIGHT COMPANY'S (FPL)
TURKEY POINT PLANT UNITS 3 AND 4 - JULY 1983 TO OCTOBER 1984 Enclosed is a draft of the NRR input to the SALP review for the Turkey Point Plant Units 3 and 4.
This draft report is based partly upon input solicited from selected staff personnel who have had substantial contact and involvement with FPL licensing material..
Please review the draft evaluation and provide any comments you feel appropriate.
All comments received by December 4,
1984 will be considered in the final report.
Your comments may be provided verbally due to the short turnaround time.
.,c Daniel G. McDonald, Project flana er Operating Reactors Branch
//1 Division of Licensing
Enclosure:
As stated cc w/enclosure:
H. Denton
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Docket Nos.
50-250 and 50-251 FACILITY:
LICENSEE:
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 Turkey Point Plant Units 3 and 4
Florida Power and Light Company EVALUATION PERIOD:
July 1, 1983 to October 31, 1984 PROJECT MANAGER:
Daniel G. MicDonald, Jr.
I.
INTRODUCTION This report contains NRR's input to the SALP review for the Turkey Point Plant Units 3 and 4.
The assessment of the licensee's,performance was conducted according to NRR Office Letter No. 44, NRR Inputs to SALP
- Process, dated January 3,
1984.
This Office Letter incorporates NRC Manual Chapter 0516, Systematic Assessment of Licensee Performance.
II.
SUMMARY
NRC Manual Chapter 0516 specifies that each functional area evaluated will be assigned a performance category (Category 1,
2 or 3) based on a
composite of a number of attributes.
The single final rating to be tempered with judgment as to the significance of the industrial elements.
Based on this approach, the performance of Florida Power and Light Company in the functional area - Licensing Activities - is rated Category l.
III. CRITERIA The evaluation criteria used in this assessment are given in NRC Manual Chapter 0516 Appendix, Table 1, Evaluation Criteria with Attributes for Assessment of Licensee Performance.
IV. METHODOLOGY This evaluation represents the integrated inputs of the Operating Reactor Project Manager (ORPM) and those technical reviewers who expended significant amounts of effort on the Turkey Point Plant Units 3 and 4
licensing actions during the current rating period.
Using the guidelines of NRC Manual Chapter 0516, the ORPM and each reviewer applied specific evaluation criteria to the relevant licensee performance attributes, as delineated in Chapter 0516, and assigned an overall rating category (1,
2 or 3) to each attribute..
The reviewers included this information as part of each Safety Evaluation Report transmitted to the Division of Licensing.
The ORPM, after reviewing the inputs of the technical reviewers, combined this information with his own assessment of licensee performance and, using appropriate weighting factors, arrived at a composite rating for the licensee.
This rating also reflected the comments of the NRR Senior
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Executive assigned to the Turkey Point Plant Units 3 and 4 SALP assessment.
A written evaluation was then prepared by the ORPM and circulated to NRR management for comments which, if provided, were incorporated in the final draft.
The basis for this appraisal was the licensee's performance in support of licensing actions that were either completed or had a significant level of activity during the current rating period.
There were a total of 84 active actions at the beginning of the rating period for the Turkey Point Plant.
Actions were added to the multi-plant and plant specific actions for a total of 156 actions by the end of the rating period.
We have closed 96 actions during the rating period and have 60 active actions at the end o7 this rating period.
These actions and a partial list of completions consisting of amendment
- requests, exemption requests, responses to generic letters, TMI
- items, and licensee initiated actions are:
54 Multi-Plant Actions (30 com lete).
Some of the completed actions in t is category are:
Control of Heavy Loads - Phase 1 (C-10)
Appendix I (RETS) Technical Specifications (A-02)
Mechanical Snubber Technical Specifications (B17 and B22)
Environmental gualification of Electrical Equipment (B-60)
Alternate Shutdown - Appendix R (B-41)
Degraded Grid Technical Specifications (B-23)
Pressurized Thermal Shock (B-73)
Vent and Purge Valve Operability (B-25)
NUREG-0737 Technical Specifications
- Generic Letter 82-16 (B-72)
NUREG-0737 Technical Specifications
- Generic Letter 83-37 (B-83) 64 Plant S ecific Actions (48 com leted).
Some of the completed actions in t is category are:
ECCS Single Failure Technical Specifications Fire Protection - Appendix R
Safety System Walkdown Technical Specifications Fuel Design (OFA/WABA) Technical Specifications Operational Limits
(~F H/F~) Technical Specifications
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RHR Emergency Technical Specifications Reactor Vessel Material Data Fuel Enrichment Technical Specifications Electrical Design Changes Safety-Related Snubber Technical Specifications 38 TMI (NUREG-0737) Actions (18 com leted).
Some of the completed actions in t is category are:
I.C. I.2.A Inadequate Core Cooling II.B.3 Post Accident Sampling II.D.3.4 Control Room Habitability II.K.2. 17 Potential Voids in the RCS V.
ASSESSMENT OF PERFORMANCE ATTRIBUTES The licensee's performance evaluation is based on a consideration of four of the seven attributes specified in NRC Manual Chapter 0516.
These are:
-- Management Involvement and Control in Assuring guality
-- Approach to Resolution of Technical Issues from a Safety Standpoint
-- Responsiveness to NRC Initiatives
-- Staffing For the remaining three attributes (enforcement, reportable
- events, and training and qualification effectiveness),
no basis exists for an NRR evaluation for the functional area of Licensing Activities.
A. Mana ement Involvement and Control in Assurin gualit We have noted in our previous assessment, that there has been effective attention and an aggressive effort given by management toward nuclear safety in the licensing area.
The concern perviously identified in the area of requesting amendments under the guidelines of 10 CFR 50.91, as amended, pursuant to Public Law 97-415, has been corrected.,
This is evidenced by the detailed No Significant Hazards Consideration findings provided with requests for amendments.
We have completed 32 of the 34 amendments requested since issuance of the 10 CFR 50.91 guidelines.
Two of the requests have been petitioned and Final No Significant Hazards Consideration determinations were made.
The completion of 96 actions during this evaluation period provides strong evidence of management involvement in the prior planning and'ssignment of priorities.
One goal
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established with the licensee at the beginning of this rating period was to complete the oldest outstanding multi-plant and plant specific actions.
Of the 46 active actions at the beginning of the period, 40 have been closed.
The remaining 6 require action by the NRC staff for final resolution.
An example of specific licensing actions where the licensee's management involvement was evidenced was in the Environmental gualification of Electrical Equipment.
The submittal included well stated, controlled and explicit procedures for the control of equipment qualification activities.
It is also significant that all the electrical equipment important to safety for Unit 4 has been qualified and only 9 switches remain to be ualified for Unit '3.
Detailed Justifications for Continued Operation JCOs) were provided for these 9 switches.
Detailed discussions, at the licensee's
- request, are held with FPL and NRC management to assure that licensing actions are getting the appropriate priority and resources necessary to meet changing safety needs which further demonstrates management involvement and control by the licensee.
On the basis of these observations, a rating of 1 is assigned to this attribute.
B.
A roach to Resolution of Technical Issues from a Safet Stand oint The increased interaction of the licensee, including frequent visits and management discussions/meetings with the NRC staff, have resulted in clear understanding of safety issues and sound technical approaches are taken by the licensee's technical staff toward their resolution.
Conservatism is being exhibited in relation to significant safety issues on a routine basis.
Thoroughness in the approach to the technical issues has been demonstrated by the number and complexity of the licensing actions completed during this period.
Consistently sound technical justification is deviations from staff guidance.
The improved licensee and NRC staff has been beneficial to licensing actions and minimizing the need for provided by the licensee for communications between the both in the processing of additional information.
On the basis of these observations, a rating of I is assigned to this attribute.
C.
Res onsiveness to NRC Initiatives The ini.tial submittals and responses to our requests for information are consistently meeting the projected schedules or a sound justification and a revised schedule are provided.
We have noted that the corporate structure of FPL has a large number of organizational units requiring internal coordination and. a cooperative attitude to achieve timely resoluti'on of safety issues in the licensing area.
A significant improvement has been noted in the licensee's technical staff's attitude in responding to our requests concerning safety'ssues.
We are consistently achieving timely resolutions of safety issues in the licensing area as a
result of this improvement.
II.
We are aware of the extensive efforts and resources currently involved in responding to the NRC requirements relating to TNI, Appendix R, Performance Enhance Program (PEP) Orders and other Commission actions.
Individually, each of the requirements are a subset of the total safety effort.
Over-emphasis or focusing on one specific area could result in the overall safety of the plant being degraded.
Although this has not been a problem for this rating period, we point it out to emphasize the need for establishing relative priorities and the integration of. all safety activities at the plant so that we'ill all have a
common basis for understanding constraints, needs and priorities.
- Thus, any revised schedules or extensive time needed for responding to NRC initiatives will require that a discussion of the priority, impact and integration with all ongoing safety efforts be included in the justification.
On the basis of these observations, a rating of 1 is assigned to this attribute.
D. Enforcement No basis exists for an NRR evaluation of this attribute.
E.
Re ortable Events No basis exists for an NRR evaluation of this attribute.
F. ~Staffin The licensee has increased the licensing staff to assure timely responses and the quality of their submittals in relation to licensing actions.
In addition, the technical staff has increased at the site which enhances the quality and timeliness.of the licensee's submittals.
On the basis of these observations, a rating of 1 is assigned to this attribute.
G. Trainin and ([uglification Effectiveness No basis exists for an NRR evaluation of this attribute.
VI, CONCLUSION A complete performance rating of 1 has been assigned by NRR for the SALP evaluation for the current rating period.
INFORMATION TO BE ADDED TO SECTION V OF THE SALP REPORT "SUPPORTING DATA AND
SUMMARY
1.
NRR/Licensee Meetin s
Masonry Wall Design Review
( IEB 80-11)
Integrated L'iving Schedules Reactor Materials Surveillance Programs Technical Specifications Upgrade Proposed Spent Fuel Pool Expansion Detailed Control Room Design Review 2.
NRR Si,te Visits/Meetin s
Masonry Wall Design
( IEB 80-11)
ALARA Data Gathering Detailed Control Room Design Review Electrical Design Review Inadequate Core Cooling Audit NRR Director Visit and Briefing 3.
Commission Briefin s None 4.
Schedular Extension Granted Appendix R,Section III.A Emergency Preparedness Exercise 5.
Reliefs Granted, None 6.
Exem tions Granted Inservice Inspection Program - Code Upgrade Appendix R, 21 Granted to Sections III.G, III.J and III.O 8/18-.19/83 6/22/84 7/13/84 8/23/84 9/10/84 10/2/84 8/16/83.
2/7-10/84 4/2-6/84 6/5-6/84 8/7-8/84 10/5/84 3/21/84 9/20/84 3/1/84 3/27/84 7.
Licensin Amendments Issued Amendment Numbers Titl e Date 96/90 97/91 98/92 Mechanical Snubber Requirements Safety System Walkdown Fuel Design (OFA/WABA) 10/14/83 10/26/83 12/9/83
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Amendment Numbers
- 99/93 100/94 101/95 102/96 103/97 104/98 105/99 106/100 107/101 108/102
- 109/103 110/104 Title Operational Limits (F~/F~)
Appendix B Deletions ECCS Single Failure Safety Inspection Bypasses Appendix I (RETS)
Degraded Grid Appendix B - 'Groundwater/Env.
Safety-Related Snubber -Tables Control of Heavy Loads Fuel Enrichment NUREG-0737 (GL 83-37)
Date 12/23/83 1/4/84 2/22/84 4/13/84 4/23/84 8/14/84 8/24/84 8/27/84 8/27/84 8/29/84 9/5/84 10/17/84 8.
Emer enc Technical S ecifications Issued Amendment Numbers Title Date 95/89 9.
Orders Issued Maximum Reactor Coolant Activity 8/31/83 Confirmatory Order - Impl'ementation of Supplement 1 'to NUREG 0737 Items Order - Modify Technical specification 3.4.1.b on an Interim Basis 10.
NRR/Licensee
.Mana ement Conferences 2/23/84 3/14/84 No formal conferences, however several discussions were held with licensee management to assure appropriate priority and resources are being expended to meet changing safety needs.
- Request for hearing and.petition for leave to intervene.
Hearing Boards have been established.
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