ML17347B497

Requests Termination of 860812 Confirmatory Order Re Plant Performance Enhancement Program,Per Section IV of Order. Listing of Remaining Program Tasks & Open Issues Encl

ML17347B497
Person / Time
Site:	Turkey Point
Issue date:	12/21/1989
From:	Goldberg J FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-89-397, NUDOCS 9001050191
Download: ML17347B497 (9)

Text

ACCESSION NBR:9001050191 DOC.DATE: 89/12/21 NOTARIZED: NO DOCKET FACIL: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 AUTH. NAME AUTHOR AFFILIATION GOLDBERG,J.H. Florida Power a Light'o.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Requests termination of 860812 confirmatory order re plant, performance enhancement program.

DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR Submittal: General Distribution NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 LA 1 1 PD2-2 PD 1 1 ..

EDISONiG 5 5 INTERNAL: NRR/DET/ECMB 9H 1 1 NRR/DOEA/OTSBll 1 1 NRR/DST 8E2 1 1 NRR/DST/SELB 8D 1 1 NRR/DST/SICB 7E 1 1 NRR/DST/SRXB 8E 1 1 NUDOCS-ABSTRACT 1 1 OCJLZMB 1 0 OGC/HDS2 1 0 ZG FILE 1 1 RES/DSIR/EIB 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 NOZE K) ALL "RIES" RECIPIENTS:

PLEASE HELP US K) REDUCE HASTE.'XÃI'ACZ 'IHE DOCUMEVZ KNZROL DESK, ROCN Pl-37 (EXT. 20079) %0 EIJMNRES MAR MME HKH DEPIVGBUTIGR LISTS FOR DOCUMENIS YOU DGNiT NEZDt TOTAL NUMBER OF COPIES REQUIRED: LTTR .21 ENCL 19

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P.O. Box 14000, Juno Beach, FL 33408-0420 nEG'EMBER 2 i >989 L-89-397 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:

Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Performance Enhancement Pro ram The Turkey Point Performance Enhancement Program (PEP) was established in early 1984 to address performance issues and to upgrade operations to meet corporate and regulatory requirements.

Additional tasks were added to the program later that year to enhance testing of plant components, and in 1986 to improve design and system configuration control. The program is the subject of a confirmatory order dated August 12, 1986.

The purpose of this report is to request termination of the order in accordance with the provisions of Section IV of the order. It is our judgement that the few remaining tasks can be followed by existing mechanisms and that the, management controls provided by the formal PEP are no longer necessary.' listing of remaining PEP tasks and open issues is provided in Attachment 1 to this letter along with several requests for program modifications (Attachment 2).

Should you have any questions on our request, please contact us.

Very truly yours, J. H. Goldberg Executive Vice President JHG/PLP/gp Attachments cc: Stewart D. Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant

,OL an FPL Group company 900i050i9i S9122i 05000250 PDR ADDCK p pNU

ATTACHMENT 1 STATUS OF REMAINING PEP PROJECT SUBTASKS Sub task Item Status Control S stem 2(Operations) 1.3 Adjust shift compliment. QA audit QA audit "QAS-finding to PEP-88-1" finding provide 6 1 tracks this shifts issue. Scheduled for completion by 12/90 due to testing for Group 4 (Configuration 11.0 Select S stem Review XIII.

Control)

1. Resolution of SEG open items. Review Expected IFI 89-203-01 various SEG Items for work off Completion (NRC Design priority. 6/90 Validation Inspection)

2. Replace RHR 887 Valve/ Expected IFI 89-203-03 Completion IS MOD 519 Unit 3 End of Cycle 12 5/90 IS MOD 565 Unit, 4 End of Cycle 13 10/91

3. Install redundant EDG Air Start Motor, Expected IFI- 89-203-03 IS MOD 576. Completion 10/91

4. Resolve Select System Punchlist. Expected IFI 89-203-04 Completion 6/90

5. Resolution of Design Basis Document Expected IFI 89-203-05 (DBD) verification open items. Completion Involves closing approximately 230 5/91 items resulting from DBD verification effort.

Expected IFI 89-203-06

6. Resolution of Breaker List. IS MOD Completion 1265 1/91

Sub PEP Pro'ect task Item Status Control S stem 4 (Configuration 7. P&ID Walkdowns of ARMs/PRMs/NCCs inside Expected IFI 89-203-07 Control) con't Unit 3 containment. Identify P&ID Completion discrepancies on NCRs. IS Mod 1042 5/90

8. Resolution of P&ID walkdown Expected IFI 89-203-07 discrepancies. Completion 9/90

9. Review Control of Vendor Manuals. Expected IFI 89-203-09 Completion 1/91 10.Upgrade Small Bore Piping to FSAR Expected IFI 89-203-08 Standards. Completion IS MOD 1313 Unit 3, IS MOD 1314 Unit 4 10/9 1

[See Note below]

5(Training) 1.2 Performance based training for Open item from N/A see maintenance journeymen and foremen and NRC Inspection Attachment 2 for chemistry technicians. Report 89-41 request to modify program.

1.3 Performance based training for reactor Open item from N/A see engineering, technical department and NRC Inspection Attachment 2 for quality control. Report 89-41 request to modify program.

Note: Other non-PEP open items from the NRC Design Validation Inspection (Inspection Report 89-203) will be addressed in the FPL response requested by that report.

ATTACHMENT 2 REVIS ION/CLARIFICATION OF PEP PROJECT 5 g SUBTASKS 1 ~ 2 AND 1 ~ 3 AND PEP PROJECT 6 g SUBTASK 9 ~ 1 PROJECT 5 SUBTASK 1.2 PEP Project 5, Training, Subtask 1.2 provides for the development of performance-based training programs for maintenance journeymen and foremen/chiefs. The intent of the commitment was to develop a single training program applicable to both of these groups; however, as worded, the commitment could be interpreted to require separate training programs for each group. FPL has developed a single program applicable to both journeymen and foremen/chiefs, and this program has been accredited by INPO.

Receuest:

FPL requests that the program of performance-based training developed for maintenance journeymen and foremen/chiefs be accepted as satisfying Project 5, Subtask 1.2 and that this subtask be closed.

PROJECT 5 SUBTASK 1.3 PEP Project 5, Training, Subtask 1.3 provided for developing performance-based training for certain reactor engineering, technical department, and quality control personnel.

it Initially, was anticipated that INPO accreditation would be provided for training programs in each of these areas.

However, FPL was subsequently informed that INPO accreditation would be provided only for technical staff and managers and shift technical advisors.

Appropriate personnel from reactor engineering, technical department, and quality control are included within the scope of the INPO-accredited program, but this program does not include all the personnel from these groups that were initially envisioned.

On March 12, 1985, FPL sent a letter to the NRC describing changes to Subtask 2.3 which reflected our understanding of the accredited INPO program and indicated that FPL would use that program. The letter did not make clear that . a corresponding change to subtask 1.3 would be necessary to support that accreditation.

However, since the purpose of Subtask 1.3 is to develop programs meeting the INPO accreditation guidelines, we believe that the program developed, which has been accredited by INPO and which provides training to appropriate personnel within the groups listed in Subtask 1.3, meets the intent of the commitment.

Independent of the PEP, a training program for reactor engineering has been developed and implemented. Furthermore, independent requirements of the PEP Level I, II and III certification for our QC inspectors are provided in plant-procedures, and additional training for QC inspectors is provided on an as needed basis.

Receuest:

FPL requests that the performance-based training program developed and implemented for technical staff and managers and for shift technical advisors be accepted as satisfying Subtask 1.3 and that this item be closed.

PROJECT 6 SUBTASK 9.1 PEP Project 6, Management Action Plan, Subtask 9.1 provides an action in the area of senior management control to continue to conduct Quality Assurance Committee meeting on a semi-annual basis. This subtask was established to meet the program objective to expand corporate management involvement and oversight of the operating plants.

RecCuest:

In order to consolidate oversight activities, FPL requests this task be modified so the oversight function be performed by the Company Nuclear Review Board (CNRB). Because of the senior level of the members on the CNRB, and the current CNRB Technical Specification responsibility for cognizance over QA audits of facility activities, we have determined that an equivalent level of management oversight. will be maintained for this activity by transferring responsibility to the CNRB.

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