ML17347B443

Responds to SALP Repts 50-250/89-36 & 50-251/89-36 for Period Jul 1988 - Jul 1989.Strong Mgt Oversight Recognized in SALP Rept Will Be Maintained & Systematically Address Weaknesses Noted

ML17347B443
Person / Time
Site:	Turkey Point
Issue date:	11/21/1989
From:	Goldberg J FLORIDA POWER & LIGHT CO.
To:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
L-89-428, NUDOCS 8912080086
Download: ML17347B443 (10)

Text

AC CELZRLTED DISTRIBUTION DEMONSTRATION SYSI'EM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8912080086 DOC.DATE: 89/ll/21 NOTARIZED: NO . DOCKET SCIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C 05000251 UTH.NAME AUTHOR AFFILIATION GOLDBERG,J.H. Florida Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION EBNETER,S.D. Region 2, Ofc of the Director

SUBJECT:

Responds to SALP Repts 50-250/89-36 & 50-251/89-36 for period Jul 1988 Jul 1989.

DISTRIBUTION CODE: IE40D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: Systematic Assessment of Licensee Performance (SALP) Report NOTES RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 LA 1 0 PD2-2 PD 1 1 h EDISONjG 1 1 INTERNAL: AEOD/DOA 1 1 AEOD/DSP/TPAB 1 1 COMMiSSION 5 5- DEDRO 1 1 NRR SHANKMANiS 1 1 NRR/DLPQ/LHFBll 1 - 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA/OEAB11 1 1

~

NRR/DREP/PEPB9D 1 1 NRR/DREP/PRPB11 1 1' NRR/DRIS/RSGB9D 2 2 NRR/DRIS/RSIB9A 1 NRR/PMAS/ILRB12 1" 1 NUDOCS-ABSTRACT 1 1 OE DIR 1 1 OGC/HDS2 1 1 R'E 1 1 RGN2 FILE 01 1 1 EXTERNAL: L ST LOBBY WARD . 1 1 LPDR 1 1 NRC PDR 1 1 NSIC 1 1 TOTAL NUMBER OF COPIES REQUIRED: LTTR 30 ENCL 29

P.O. Box14000, Juno Beach, FL 33408.0420 tlQVEMBER '2 1 1989 L-'89-428 Mr. Stewart D. Ebneter Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101 Marietta Street, N. W., Suite 2900 Atlanta, GA 30323 Re: Turkey Point'Units 3 and 4 Docket Nos. 50-250 and 50-251 Inspection Report No. 89-36 Response to Systematic Assessment of Licensee Performance

Dear Mr. Ebneter:

Florida Power & Light Company (FPL) has reviewed the NRC Systematic Assessment of Licensee Performance (SALP) Report for Turkey Point covering the period July 1, 1988 to July 31, 1989, and generally agrees with the facts and conclusions in the report. Considerable effort has been devoted to improving performance at the Turkey Point plant, and FPL appreciates the recognition of this fact in the SALP,report.

As I stated at the October 26, 1989, meeting at which the SALP results were discussed, we regard the performance achieved thus far as a beginning; continued improvement will require sustained effort.

We will maintain the strong management oversight recognized in the SALP report and systematically address the weaknesses which were noted. We will keep the NRC apprised of our progress.

The comments on the SALP report in the Attachment highlight areas in which there have been significant measurable improvements since the close of the SALP period.,We will be glad to discuss these comments at your convenience.

\

Very truly yours, J. H. Goldberg Executive Vice President Attachment 0 U. S. Nuclear Regulatory Commission Document Control Desk Dr. Thomas E. Murley, Director, Office of Nuclear Reactor Regulation, USNRC Senior Resident Inspector, USNRC, Turkey Point Nuclear Plant an FPL Group company 8'P l 2080086 891 12l PDR ADDCK 05000250 6 . PNU

ATTACHMENT The October 19, 1989 SALP report for Turkey Point (Inspection Report 89-36) identified specific areas where performance could be improved, and in some cases made recommendations for impr'ovement. In a number of these areas, significant improvement has occurred since the end of the SALP period (July 31, 1989). These improvements include R ADIOL I AL ONTROL umber of Containment Entries While at P wer (p. 12).

The number of containment entries while at power has decreased from a total of 64 in July 1989 (for both units) to 20 in October 1989.

ntaminated Fl or ace (p. 12).

The amount of contaminated floor space has been reduced from 18,149 feet (18.6%) in July 1989 to 15,205 feet (15.6%) as of October 31, 1989.

o Personnel Contamination Event lI There were 384 Personnel Contamination Events (PCEs) during 1988. As of October 31 there were 147 PCEs during 1989. It is expected that the total number of PCEs for 19S9 will be less than half that experienced during 1988.

The cumulative dose for both Turkey Point units was 671 person-rem for 1988 (measured by TLD). As of September 30, the cumulative'dose for 19S9 was 382 person-rem. The projected total 1989 cumulative dose is 454 person-rem, a'decrease of about one-third from the 1988 level.

'Page references are to pages in Inspection Report 89-36

~I AINTENAN E v r im n Turn v r Ra (p.14).

Overtime and Turnover rates in the maintenance disciplines generally have declined since July 1989. Average overtime rates in each discipline during.1989 have been as follows:

~lt uarter ~2nd uarter ~rd uarter Mechanical 46.3% 23.3% 16.7% =-

Electrical 53% 31.7%, 30.0%

I&C 469o 36.3% 26.3%

All Maintenance 469o 30.39o 21.3%

(includes Reliability Group)

Turnover rates have been:

- Jul 1 uu - c rl Mechanical 8.7% 1.1%

Electrical 1.69o 3.39o I&C 4.9% 3.7%

All Maintenance 6.0% 3.1%

(includes Reliability 0 .

Group) rrective M in enance Backl (p 15)

The corrective maintenance backlog has declined from 1056 Plant Work Orders (PWOs) as of July 31, 1989 to 870 PWOs as of October 31, 1989. The backlog had reached a low of 708 on September 15, 1989; the increase since that time is primarily due to PWOs initiated to implement material upgrades.

Control Room Deficienc Ta (p 15)

The number of control room deficiency tags has declined from 95 as of July 31, 1989 to 68 as of November 15, 1989.

S~are Part (p.td).

Significant improvements are evident in performance indicators- related to spare parts Average procurement times have declined from 96.2 days during October 1988 - March 1989 to 79.1 days during April - September 1989 (a decrease of approximately 18%). The number of stores parts below minimum stocking levels has been reduced from 5154 as of May 1, 1989 to 4509 as of October 1, 1989 (a 12.5% reduction). The proportion of procurement requests made on, an "urgent" basis has fallen from an average of 39% during February - May 1989 to 29% during June - September 1989.

ualit of Procedures (pp. 16-17)

The number of Maintenance On-The-Spot-Changes (OTSC's) to procedures has declined substantially in recent months, from an average of 57.2 per month during January - April 1989, to an average of 12.5 during May - October 1989. Higher figures early in the year were in part due to the amount of outage work being performed.

' o Trackin nd Anal i f u frR w rk (p.17)

In September 1989, a rework Maintenance Engineer position was designated for each discipline in the Turkey Point Maintenance Department. In the 1&C and Electrical departments, Engineers have been assigned responsibility for analyzing the root causes of rework items and for recommending corrective action to prevent recurrence. An offer is being tendered to an individual to fill the Mechanical Engineer position. The required administrative processing of this individual should be completed by March 31, 1990., A revision to the Turkey Point root cause analysis procedure (ADM-509) to reflect this change has been issued.

ECURITY o At ntiveness to Dut m ensat r P (p. 20)

Since early May 1989, there have been no identified instances of sleeping or inattentiveness to duty by Turkey Point security personnel. The average number of compensatory post hours worked per month has declined from an average of 1183 hours0.0137 days <br />0.329 hours <br />0.00196 weeks <br />4.501315e-4 months <br /> during October 1988 - March 1989 to an average of 236.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> during April - October 1989.

curit Shift Su ervision L a 1 Ev n Since October 1988, five FPL security shift specialists have provided FPL management supervision of contractor security personnel on each shift. During this time, the number of loggable security events has declined, from an average of 49.3 per month during June through December 1988 to an average of 38.2 per month during January - October of 1989, a 22.5 9o decrease. During July - October, 1989, the average number of loggable security events has been 26.25 per month.

ENGINEER IN TE HNI AL PP RT 0 Desi n - Related ALARA Trainin (p.22)'

On May 1, 1989 two ALARAcoordinators, one for St. Lucie and one for Turkey Point, were assigned within the FPL Nuclear Engineering organization. These coordinators are responsible for the development of ALARA design standards for the FPL Nuclear Engineering organization, and for assuring that ALARA considerations are properly accounted fo'r in'plant design work. In addition, these individuals are developing an ALARA training program for design engineers. This training is scheduled to be implemented during the first quarter of 1990.

v rim ndT rn v rR (p.14).

Overtime and Turnover rates in the maintenance disciplines generally have declined since July 1989. Average overtime rates in each discipline during 1989 have been as follows:

~l~r~ ~n~r'r ~r~i~rr Mechanical 46.3% . 23.396 16.7%

Electrical . 53% '1.7%

30.0%

I&C 46% 36.396 26.3%

All Maintenance 46% 30.396 21.396 (includes Reliability Group)

Turnover rates have been:

Mechanical 1.1%

Electrical 3.396 I&C 3.7%

All Maintenance 3.1%

(includes Reliability Group) rr iv M in n n B kl (p 15)

The corrective maintenance backlog has declined from 1056 Plant Work Orders (PWOs) as of July 31, 1989 to 870 PWOs as of October 31, 1989. The backlog had reached a low of 708 on September 15, 1989; the increase since that time is primarily due to PWOs initiated to implement material upgrades.

nr'IR mD fi i nc T (p 15)

The number of control room deficiency tags has declined from 95 as of July 31, 1989 to 68 as of November 15, 1989.

ah>~rBIQR (P 16)

Significant improvements are evident in performance indicators related to spare parts.

Average procurement times have declined from 96.2 days during October 1988 - March 1989 to 79.1 days during April - September 1989 (a decrease of approximately 18%). The number of stores parts below minimum stocking levels has been reduced from 5154 as of May 1, 1989 to 4509 as of October 1, 1989 (a 12.5% reduction). The proportion of procurement requests made on an "urgent" basis has fallen from an average of 39% during February - May 1989 to 29% during June - September 1989.

li f Pr r (pp. 16-17).

The number of Maintenance On-The-Spot-Changes (OTSC's) to procedures has declined substantially in recent months, from an average of 57.2 per month during January - April 1989, to an average of 12.5 during May - October 1989. Higher figures early in the year were in part due to the amount of outage work being performed.

~

4

'I T 'n n In September 1989, a rework Maintenance Engineer position was designated for each discipline in the Turkey Point Maintenance Department. In the I&C and Electrical departments, Engineers have been assigned responsibility for analyzing the root causes of rework items and for recommending corrective action to prevent recurrence. An offer is being tendered to an individual to fill the Mechanical Engineer position. The required administrative processing of this individual should be completed by March 31, 1990. A revision to the Turkey Point root cause analysis procedure,(ADM-509) to reflect this change has been issued.

!VERITY 0 A niv n D m n r P (p.20)

Since early May 1989, there have been no identified instances of sleeping or inattentiveness to duty by Turkey Point security personnel. The average number of compensatory post hours

'orked per month has declined from an average of 1183 hours0.0137 days <br />0.329 hours <br />0.00196 weeks <br />4.501315e-4 months <br /> during October 1988 - March 1989 to an average of 236.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> during April - October 1989.

ri hif rviinL I Evn Since October 1988, five FPL security shift specialists have provided FPL management supervision of contractor security personnel on each shift. During this time, the number of loggable security events has declined, from an average of 49.3 per month during June through December 1988 to an average of 38.2 per month during January - October of 1989, a 22.5 %

decrease. During July - October, 1989, the average number of loggable security events has been 26.25 per month.

ENGINEERIN TE HNI AL PP RT 0 i n - Rela e ALARA Tr inin (p.22)

On May 1, 1989 two ALARAcoordinators, one for St. Lucie and one for Turkey Point, were assigned within the FPL Nuclear Engineering organization. These coordinators are responsible for the development of ALARA design standards for the FPL Nuclear Engineering organization, and for assuring that ALARA considerations are properly accounted for in plant design work. In addition, these individuals are developing an ALARA training program for'design engineers. This training is scheduled to be implemented during the first quarter of 1990.