ML17348A596
| ML17348A596 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 09/25/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17348A595 | List: |
| References | |
| 50-250-90-26, 50-251-90-26, NUDOCS 9010160219 | |
| Download: ML17348A596 (39) | |
See also: IR 05000250/1990026
Text
ENCLOSURE
INITIAL SALP
BOARD REPORT
U. S.
NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMATIC ASSESSMENT
OF LICENSEE
PERFORMANCE
INSPECTION
REPORT
NUMBER
50-250/90-26
AND 50-251/90-26
FLORIDA POWER
AND LIGHT
TURKEY POINT UNITS 3 AND 4
AUGUST 1,
1989 - JULY 31,
1990
TABLE OF
CONTENTS
~Pa
e
I ~ INTRO DUCT ION
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1
II. SUMMARY OF RESULTS ..........,,...,,...............,...,....
2
I II. CRITERIA ..............................'.................,...
3
IV. PERFORMANCE ANALYSIS
A.
B.
C.
D.
E.
F.
G.
Plant Operations .....................
Radiological Controls ................
Maintenance/Surveillance ...,..........
Emergency
Preparedness ...............
Security
& Safeguards ..............,.
Engineering/Technical
Support ........
Safety Assessment/equality
Verification
3
7
9
13
15
16
20
V. SUPPORTING
DATA
A.
Licensee Activitses ......................,...,
B.
Direct Inspection
and Review Activities ..'.....
C.
Escalated
Enforcement Actions ...........,.....
D.
Licensee
Conferences
Held During Appraisal
Peri
E.
Confirmatiog of Action Letters ................
F.
Reactor Trips ........;..................,....,
G.
Review of Licensee
Event Reports
and
H.
Licensing Activities ..........................
I.
Enforcement Activity ..........................
~
~ 4 ~ ~ ~ ~
od ....
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Reports.
23
23
24
24
24
24
2627,
27
I.
INTRODUCTION
The Systematic
Assessment
of Licensee
Performance
(SALP) program is an
integrated
NRC staff effort to collect available observations
and data
on
a periodic basis
and to evaluate
licensee
performance
on the basis
of
this information.
The program is supplemental
to normal regulatory
processes
used to ensure
compliance with NRC rules
and regulations.
It
is intended to be sufficiently diagnostic to provide
a rational
basis for
allocation of NRC resources
and to provide meaningful
feedback to the
licensee's
management
regarding
the NRC's assessment
of their facility's
performance
in each functional area.
An NRC SALP Board,
composed of the staff members listed below, met on
September
6, 1990, to review the observations
and data
on performance,
and to assess
licensee
performance
in accordance
with Chapter
"Systematic Assessment
of Licensee
Performance."
The guidance
and
evaluation criteria are
summarized
in Section III of this report.
The
Board's findings and recommendations
were forwarded to the
NRC Regional
Administrator for approval
and issuance.
This report is the NRC's assessment
of the licensee's
safety performance
at Turkey Point Units
3 and 4, for the period August 1, 1989,
through
July 31,
1990.
The SALP Board for Turkey Point was
composed of:
L. A. Reyes, Director, Division of Reactor Projects
(DRP), Region II
(RII) (Chairman)
A. F. Gibson, Director, Division of Reactor Safety,
RII
J.
P. Stohr, Director, Division of Radiation Safety
and Safeguards,
RII
M. Y. Sinkule, Chief, Reactor Projects
Branch 2,
DRP, RII
R.
C. Butcher, Senior Resident
Inspector,
Turkey Point,
DRP, RII
H. H. Berkow, Director, Project Directorate II-2, Office of Nuclear
Reactor Regulation
(NRR)
G. Edison, Project Manager, Project Directorate II-2, NRR
Attendees
at
SALP Board Meeting:
R.
Y. Crlenjak, Chief, Project Section
2B,
DRP, RII
R.
P. Schin, Project Engineer,
Project Section
2B,
DRP, RII
K. D. Landis, Chief, Technical
Support Staff,
DRP, RII
II.
SUMMARY OF RESULTS
Turkey Point operated with improved performance
during the assessment.
period.
Management
continued to upgrade
the material condition of
jhst'ystems
and components
which resulted
in improved operating
times
wTK..
fewer failures
due to equipment malfunctions.
Significant improvemfwas
noted in the areas
of Security
and Safety Assessment/guality
Verifia5'an.
Improved performance
was also demonstrated
in the areas of RadiologM
Controls
and Maintenance/Surveillance.
Although there
was
a reduction in
personnel
errors in the Operations
area
over this
SALP period,
an iuxease
occurred
near the end of the period.
Additional attention
should
he
directed to this problem.
There
has
been considerable
improvement in the area of Security.
Gages
in management
made during this
and the prior assessment
period haveTad
to marked
improvement in this area.
Upgrading of the security traiexg
program
and enhanced
security communications capability were other
initiatives which have contributed to the overall
improvement.
ExtmPve
hardware modifications, currently in progress,
are expected
to resuifix
.
an excellent security complex.
The Safety Assessment/guality
Verification area
has also
shown not8h-
improvement.
Your ability and comnitment to determine "root cause"Xs
improved substantially,
to the point that repeat events/failures
wee;
minimized.
The preparation efforts, including self-assessments
con6zt'ed
by Regulatory
Compliance
and guality Assurance,
resulted
in positive
findings by the
NRC in several
team inspections
conducted
during
tha3LLP.
period.
The licensee's self-identification of NRC violations is
considered
a significant indicator of effectiveness
in this area.
'3heach
self-identified case,
prompt and thorough corrective actions
were tkh= hy
the licensee.
For licensing activities, significant improvement in%.
timeliness of submittals
and responses
to
NRC initiatives was notch
8oth the Radiological Controls
and Maintenance/Surveillance
areas
ha8
improved.
The area of Radiological Controls benefited
from the posture
efforts in reducing collective dose expenditure,
contaminated floorsym,
and personnel
contamination
events.
The positive achievements
in th:.
Maintenance/Surveillance
area resulted in improved plant and equipmaf
reliability.
Strengths
in this area
were:
personnel
staffing and nfzed,
turnover rates;
upgrading of the auxiliary building;
PWO backlog
reduction; preventive maintenance
program,
and
a reduction of contr8'toom
deficiency tags.
Although the licensee
has taken measures
to contr@:
rework PWO's, with noted improvements,
additional attention is warmed..
Improvement continues with no changes
in SALP ratings
over the previm
SALP period in the areas of Operations,
Emergency
Preparedness,
and
Engineering/Technical
Support.
Clearly all areas
have benefited bye
licensee's
commitment to improve and to make safe operation
a prio~
making conservative
choices
when necessary.
. Functional
Area
Facil it
Performance
Summar
Rating Last
Period
Rating This
Period
Plant Operations
(Operations
& Fire Protection)
Radiological Controls
Maintenance/Surveillance
Emergency
Preparedness
Security
En ineering/Technical
Support
Engineering, Training
& Outages)
Safety As'sessment/
guality Verification
(guality Programs
& Licensing)
III. CRITERIA
2
2
2
3 Improving
2
2 Improving
2 Improving
2
2 Improving
2
The evaluation criteria which were used,
as applicable, to assess
each
functional area
are described
in detail in NRC Manual Chapter 0516.
This
chapter is in the Public Document
Room files.
Therefore
these criteria
are not repeated
here, but will be presented
in detail at the public
meeting held with the licensee
management
on October 3, 1990.
However,
the
NRC is not limited to these criteria and others
may have
been
used,
where appropriate.
IV.
PERFORNNCE
ANALYSIS
A. ~10
l. ~Anal sis
This functional area
addresses
the control
room and performance of
activities directly related to operating the unit, as well as fire
protection.
These activities were viewed during routine and special
inspections
conducted
throughout the asessment
period.
8oth units have
been shut
down and started
up numerous
times during
the
SALP period.
Changes
in plant modes'and
power levels were
conducted
in a controlled
and professional
manner.
Several
times,
prompt actions
by the operators
stabilized the plants during
transient conditions.
There were two reactor trips on Unit 3 during
the
SALP period.
One was attributed to operator error while conduct-
ing a load reduction associated
with a condenser
tube leak
and the
other trip was associated
with an equipment
pr'oblem.
On Unit 4,
three of 'the four reactor trips resulted
from equipment
problems
and
one trip was attributed to operator error, during testing.
The
equipment
problems that caused
the trips were not repetitive
failures.
During the previous
SALP period,
two reactor trips
occurred, of which one was
due to operator error.
Overall, operator
performance
has
been satisfactory.
Personnel
errors,
inadequate
component labeling,
and improper
clearances
had contributed to
a number of events
during the previous
SALP period.
The licensee
has
taken actions to specifically address
each of the previous
problem areas.
In the area of component
labeling, the licensee
implemented
a program to include independent
verification of labeling
and improve the process
of identifying and
correcting in-plant labeling problems
by utilizing the system
engineers.
There
has
been
a substantial
increase
in labeling since
the previous
SALP.
The licensee's
changes
'in this program have
been
effective.
Ouring this
SALP period, there
has not been
an event
which has
had mislzbeling identified'as
the root cause.
Personnel
errors
were fewer than experienced
during the previous
period; however,
near the end of this
SALP period there were events
that indicated
a lack of attention to detail.
Ouring a four-day
period in May 1990,
one unit entered
mode
3 from mode
4 with a
containment isolation valve pinned
open in lieu of pinned closed
and
with both channels
of the Reactor
Vessel
Level monitoring system
and exceeded
an administrative limit of 380 degrees
F
with both safety injection (SI) system flowpaths locked closed.
Other events
appeared,to
be related to lapses
in the
command function
in the control
room; e.g., in May 1990, Unit 4 was inadvertently
tripped when an operator (with the plant supervisor's
concurrence)
pushed the manual reactor trip buttons in lieu of continuing the
reactor startup
as intended;
and in June,
1990, Unit 3 was
inadvertently tripped when
an operator pulled control rods to control
temperature
and failed to monitor reactor
power, resulting in a
reactor trip at
10K reactor
power.'o
increase
operator attention to detail, Operations
has
increased
its effort to understand
how different events
occur and to implement
corrective actions appropriate
to them.
One of these efforts has
been to conduct weekly open discussions
with the operating
crews
on
the events,
the root causes,
causal
contributors,
and actions'needed
to prevent
a similar occurrence
in the future.
These shift meetings
have helped to identify problem areas
so that they could be acted
on,
and
have provided personnel
with a better understanding
of the events
and management's
expectations
in similar situations.
As a result of
the discussions
and other corrective actions (i.e., procedure
changes,
self-check training,
and discipline) the operational
error
rate has
decreased
when compared to the
same time frame in 1989.
The
licensee
plans to provide additional
simulator training time for
operators
over the next year, including emphasis
on normal
evolutions.
Although the
number of events
associated
with clearance
problems
has
decreased
from the last
SALP period, errors involving clearances
were
associated
with two violations cited in the operations
area
and two
in the maintenance
area.
The licensee
has
performed
a review of
their clearance
process
and
as
a result is making changes.
These
changes
include developing simplified clearance
procedures
and
procedures
on handling equipment out of service,
and modifying the
work control measures.
Currently, these
clearance
program changes
are scheduled
to be in place prior to the November
1990 dual unit
outage.
The licensee
has
had problems with inadequate
implementation of
corrective actions for known problems.
During a design validation
inspection,
several
procedural
and equipment
problems
were
identified.
When the licensee's
completed corrective actions
were
inspected,
several
of the previously identified discrepancies still
existed.
In February,
1990,
a leak occurred in the Unit 3 spent fuel
pool
pump room and due to the floor drains
being partially plugged,
approximately
3 inches of water accumulated
in the spent fuel pool
pump room and the cask
wash area.
The spent fuel pool
pump room
floor drains were being periodically tested
but that testing
had not
been adequate.
The licensee
has since revised their method of floor
drain testing.
During the last
SALP period,
on January
20,
1989, the licensee
concluded
the "Management-On-Shift"
(MOS) program.
However, since
the termination of the
MOS program. and during the early part of the
SALP period, the licensee
continued to utilize non-licensee
observers
that were previously part of the
MOS program to obtain
an independent
assessment
of plant operations.
The independent
observer
coranents
were positive, indicating that operato'rs
displayed
a very positive
attitude toward their jobs
and management;
plant personnel
were
continuing to display
a sense
of pride
and ownership; significant
improvements
in cooperation
between
operations
and other departments
were observed;
overall
improvements
in the material condition of the
Auxiliary Suilding were noted;
and shift technical
advisors
were more
involved in shift activities,
such
as coordination of testing.
The
resident inspectors
have
made similar observations
during their
routine inspection activities.
The Operations
department
has
implemented
an in-depth plan-of-the-day
(POD) meeting,
and shift briefings are thorough
and professional.
Operations
explains the shift objectives
and asks
each
department
(chemistry, mechanical
maintenance,
etc.) their main objectives for
their shift.
Also, Operations
personnel briefly explain the status
of the plant in their area of responsibility.
Plant management,
during this
SALP period,
has taken
a conservative
approach
to plant operations.
The following examples
demonstrate
operational
conservatism:
On December
25,
1989, the licensee
took Unit 3 off line to
replace
corroded electrical
terminal blocks,
even
though the
system
demands
were high and temporary
power interruptions
resulted.
On March 25, 1990,
the licensee
stopped all outage
work on Unit
3 to review and walk down clearances
following an inadvertent
spill of water from the reactor water storage
tank.
In Hay,
1990, the licensee
discovered
a control oil leak
on
a
fitting of the left turbine stop valve.
The fitting could
possibly have
been tightened with the unit on line.
However,
the licensee
conservatively
decided to take the unit off line to
avoid risking a plant transient if the oil line failed during
tightening.
The
NRC had expressed
concern in previous
SALPs regarding the use of
excessive
operations staff overtime.
The overtime use
has
remained
at about the
same level
as in the previous
SALP period
(25 to 30 X)
due to outages
and
an aggressive
labeling program,
but was
substantially
reduced
near the end of the
SALP period.
The recent
qualification of two non-licensed
plant operator training classes
and
the planned staffing increases
from the operator license candidates,
presently in training should help control overtime."
Presently
there
are
52 operator license
candidates
in training, with 29 scheduled
to
take the NRCPtest in the first quarter of 1991.
Turnover rate of
on-shift licensed
operators
has
been
low compared to previous
periods, with 2 of 29 (6.8X) leaving Operations.
An Emergency Operating
Procedure
(EOP) inspection
was conducted
during this period.
The team, concluded that the licensee's
adequately
covered the broad
range of accidents
and equipment
failures necessary for safe
shutdown of the units.
Prior to this
inspection,
the licensee
had initiated self audits of the
and
made extensive
improvements
to the
and the
EOP setpoint
document.
The licensee
committed to take corrective actions for
weaknesses
in Off Normal Operating
Procedures
and other deficiencies
identified by the
team
and by a Design Validation Inspection.
The inspection of the fire protection features, fire detection
systems
and the fire fighting equipment indicated that these features
were in a state of readiness.
Early in this
SALP period there
was
a
team inspection for conformance to 10 CFR 50, Appendix
R requirements
with no violations identified and late in the
SALP period there
was
a
second
inspection in the fire protection area with no findings.
The
team inspection report recognized that the self assessment
audit
conducted
by the licensee's
gA organization, with contractor
assistance,
was comprehensive
and ensured
the licensee that their
Appendix
R modification program
was satisfactory.
Six violations were cited in the Operations
area during this period.
2. ~Pf
2
Category:
2
3. Recomendations
An increase
in personnel
errors occurred during the final quarter of
this
SALP period.
Additional attention
by the licensee is
recomended
to ensure
that the
command function is maintained
and
attention to detail is enforced.
B. Radiolo ical Controls.
l. ~Anal sis
This functional area
addresses
those activities d;rectly related to
radiological controls
and primary/secondary
chemistry control,
as
viewed during routine inspections
conducted
throughout the inspection
period.
Radiation protection organization
and staffing were adequate
to
protect worker health
and safety.
Organizational
and technical
staffing upgrades,
the majority of which were completed early in the
SALP period, included having the
ALARA Supervisor report directly to
the Health Physics
(HP) Technical
Support Supervisor,
and the
addition of a specialist position to the ALARA group.
Also,
a
Training. and Procedure
Coordinator
improved integration of Radiation
Protection
(RP) personnel
training and
enhanced
the ongoing procedure
development
and/or upgrades.
Overall, the
HP staff provided appropriate
coverage for routine
operations
and outage conditions.
During the
HP contractor
technician. strike,
management
properly trained
and utilized licensee
replacement staff to provide adequate
HP coverage for limited outage
activities.
Licensee
audits of RP activities were comprehensive,
thorough,
and
continued to strengthen
the health physics
program.
Two
RP issues
identified by licensee
audits were reviewed.
Significant technical
upgrades within the
RP program resulted
from the timeliness,
depth,
and
scope of the audits;
the significance of identified issues;
and
appropriateness
of corrective actions.
Procedure
and Radiation
Work Permit
(RWP) guidance for radiation
protection activities were technically sound.
Compliance with
established
procedures
was adequate,
with only two isolated
issues
regarding failure to follow procedures
identified.
One was
a
deficiency regarding maintenance
of Special
Nuclear Material
inventory records,
which was corrected imediately.
The other was
a
violation regarding the failure of selected
workers to follow RWP
requirements.
Licensee evaluation of this issue
and corrective
actions
were thorough
and appropriate
to prevent recurrence.
Overall, the licensee
continued to effectively manage
and
reduce
collective dose expenditure.
The facility's three-year
average
annual collective dose continued to decrease
from 475 to 399
person-rem
per reactor
from 1988 to 1989.
For July 31,
1990, the end
of the current
12 month
SALP cycle, the licensee
projected
a
collective dose of approximately 341.5 person-rem
per reactor
as
measured
by thermoluminescent
dosimeter
(TLD).
=This value represents
a decrease
from the previous
13 month
SALP period,
when collective
radiation
dose
was reported
as
430 person-rem
per reactor.
The
effective management
of dose expenditure
was demonstrated
by the
continued overall reduction
even with increased
routine maintenance
activities, which effectively reduced
source
terms.
Also, this
reduction
was achieved in spite of an unexpected
extension of the
Unit 3 outage to correct reactor
head 0-ring leaks
and also
an
unscheduled
outage to repair Unit 4 pressurizer
spray valves.
These
unplanned activities contributed approximately
76 person-rem
per
reactor to the total
TLD exposure
values,
as estimated
from
self-reading dosimetry.
Licensee
actions to reduce
the percentage
of contaminated floor space
within the radiologically controlled area
(RCA) were very effective.
Actions included
an aggressive
decontamination
program
and subsequent
resurfacing of selected
areas/rooms
within the
RCA, and the use of
catch containments
and prioritizing corrective
and preventative
valve
maintenance.
The licensee started
the
SALP period with 17 percent of
the floor space
(20,929
square feet) contaminated.
By November 1,
this was
reduced to 10 percent.
= This percentage
did increase
during
outages,
but was immediately reduced after outages.
As of July 30,
1990, the percentage
of contaminated floor space
during non-outage
conditions
was being maintained at approximately 8,900 square feet
(ft~), 7.5 percent.
A dramatic
improvement
was noted in the reduction of personnel
contamination
events
(PCEs) reported
between
1988 and
1989,
from 384
to approximately
168 respectively,
as
a result of,employee
awareness
and procedural
upgrades.
The licensee
reported
219
PCEs for .the
current evaluation period.
During the
HP contractor strike,
an
unexpected
increase
in the frequency of PCEs
was noted
and determined
to result from decreased
availability of clean laundry for workers.
Additional long-term improvements
including laundry monitoring
equipment
and procedure
upgrades
were being
implemented
to prevent
recurrence.
Solid radioactive
waste storage
and processing
were identified as
program areas
with deficiencies.
A violation was issued for failure
to maintain appropriate
posting
and labeling of a radioactive waste
storage
area.
In addition, problems with completing spent resin
transfer during waste processing
were noted during the review period.
A preliminary licensee
evaluation of the event indicated deficiencies
and concerns
in operations,
ALARA, and administrative
areas.
The
'reliminary evaluation
appeared
thorough
and proposed corrective
actions
adequate .to prevent recurrence.
Hanagement
support continued to be strong through continued
implementation of a management
control
system which helps to ensure
an aggressive
chemistry program.
The completeness
of documentation
of chemistry parameters
provided
a highly visible means of tracking
plant chemistry
and highlighting anomalies.
A confirmatory measurements
evaluation
was performed with beta
samples
sent to the licensee.
All analyses
(4) were in agreement.
The liquid and
gaseous
effluents
programs
were effective.
Only one
unplanned liquid release
was
made during the period.
Less
than
one
microcurie was released,
and
no dose 1'imits were exceeded.
The
licensee
took effective corrective action to prevent recurrence.
Radwaste
processing
had
been
a joint effort shared
between
Operations,
Health Physics,
and Chemistry groups, with Operations
administering
the vendor contracts.
With the appointment of a
Radwaste
Coordinator within the Chemistry Department,
reporting
directly to the Chemistry Supervisor,
Chemistry
assumed
administration of vendor contracts
in the Radwaste
area
and
respons>bility for overall coordination of the program.
The licensee
expects this organization
change to improve control
by focusing
program responsibility on one individual.
Two violations were cited in the Radiological Controls area
during
-this period.
2. Performance
Ratin
Category:
2
Trend:
Improving
3. Recomendations
The Board noted that there
has
been
a significant improvement in
radiological controls during the
SALP period.
The Board, a1so
recognized
that the licensee's
performance, at the end of the
period" was excellent.
After careful deliberation,
the Board
concluded that the appropriate
characterization
of performance
throughout the
SALP period was Category
2 Improving.
C. Maintenance/Surveillance
l. ~Anal sis
Routine
and special
inspections
during this assessment
period were
conducted
to evaluate
equipment condition and maintenance
activities
and to provide an overview of the maintenance
program.
The
NRC performed
a followup inspection to determine
the
effectiveness
of the licensee's
corrective actions for the findings
of the
NRC Maintenance
Team Inspection
(MTI) conducted
in the prior
SALP period.
The licensee. developed
and implemented corrective
actions to address all of the weaknesses
identified by the MTI.
.
Significant improvements
were observed
in all areas.
Management
involvement in implementing the improvements
was evident through
well-stated policies for control of corrective actions,
consistent
evidence of prior planning
and assignment
of priorities, and decision
making at
a level which ensured
adequate
management
review.
Personnel
are accountable
to plant management
for implementing
improvements
and their performance
was actively monitored.
Corporate
management
allocated significant resources
to the improvements
and
supported
plant management
in all their activities.
Improvements
noted included:
increased
and more effective guality Control staff;
10
hiring of permanent staff employees
to replace contract personnel
in
important maintenance
support functions;
development of engineering
support functions, especially
system
and reliability engineering;
ongoing equipment
upgrade
program,
which has
improved plant
and
equipment condition;
and
changes
to planning
and scheduling
activities, which have
reduced
maintenance
delays.
The tracking and scheduling of the surveillances
has
been effective;
no survei llances
exceeded
'the
TS grace period.
During the previous
SALP period weaknesses
were identified in the inservice testing
(IST)
program regarding root cause analysis
and corrective actions
pertaining to testing motor-operated
valves
(MOVs).
The licensee
has
resolved
these
problems.
Root cause
analysis
and corrective action
evaluations of MOV IST failures were timely and 'technically adequate.
Strengths
were identified in the area of leak rate testing pertaining
to trending of valve leakage data,
and testing of additional'pressure
isolation valves not required
by the Technical Specifications
(TS).
The licensee's
IST surveillance
procedures
were technically adequate
and in conformance with TS requirements.
Two instances
were
identified where insufficient briefing of personnel
for low power
physics testing resulted
in portions of tests
not being performed to
expectations.
Inservice test personnel
were knowledgeable of the
surveillances
they were following and routinely followed procedures.
During test performance, it was noted that test personnel
did not
always identify and correct the equipment
nomenclature
errors in test
procedures.
Overall, the licensee
conducted
surveillances
in a safe,
conservative
manner.
Licensee
management
has
made
improvements
in the areas of Maintenance
Department
personnel
staffing, turnover rates,
and overtime reduction
throughout this assessment
period.
Currently the staffing levels for
the four maintenance
disciplines
are consistent
with the licensee's
authorized levels.
Turnover rates
have steadily
improved since the
last SALP.
In addition, during this period,
no
ISC personnel
have
transferred
to the Operations
Department,
which in the past accounted
for the majority of the turnover rate of the
ISC specialists.
Maintenance
Department
management
has
remained stable
throughout this
period.
Over most of the
SALP period, overtime rates
have remained
above the licensee's
goal of 27 percent or less.
However, at the
end
of the
SALP cycle, the overtime rate
had
been
reduced to almost half
of the level experienced
in the first half of this cycle.
The
decrease
was
due to new controls implemented'by
the licensee at the
beginning of 1989, including pre-approval
of overtime by supervisors
and tracking of overtime.
The material condition of the plant has continued to improve during
this period.
In October l989, the licensee
implemented
a material
condition upgrade
plan requiring plant walkdowns
by a management
team.
The team then generates
a list of deficiencies
which are
corrected or tracked to be corrected
when plant conditions allow.
Some noted areas of improvement are:
upgrading of the auxiliary
building, including hallways, Unit 4
RHR pump room,
and Unit 3
charging
pump room; painting and lagging in the turbine plant area;
11
reduction in the total amount of contaminated
floor space;
overhaul
and repacking of a'significant
number of valves; reduction in the
number of control
room green tags;
and
a complete overhaul
and
material
upgrade of the cranking diesels
and switchgear.
The
licensee's
efforts in the material condition upgrade
have resulted
in
improved plant reliability and.availability.
This is evidenced
by
the facility being
on target at
52 days for their "unplanned
days off
line" for 1990.
Late in the last
SALP cycle the licensee
began tracking rework
PWOs
and established
a goal to have less
than
30 rework
PWOs per month by
the end of 1990.
Ouring the first quarter of 1990,
a downward trend
was noted indicating that the goal
was achievable.
However,
an
increase
in rework
PWOs occurred
near the end of the Unit 3 refueling
outage
as
systems
and components
were returned to service.
In an
effort to reduce
rework, the licensee
established
a rework
maintenance
engineer position within each
maintenance
department
discipline.
Their responsibility is to analyze
the cause for repeat
equipment
problems.
The licensee
has
made progress
in the
identification of recurring equipment failures
and provided adequate
corrective action.
For example,
the charging
pump oil pressure trip
switches
caused
numerous
spurious trips due to switch location
and
range.
These
were subsequently
replaced with a
new switch having
a
more appropriate
range
and relocated
to a low vibration area.
Since
these corrective actions
were taken there
have
been
no further
spurious trips due to this switch.
However, continuing rework
problems exist due to poor design,
poor workmanship/maintenance
practices,
and poor vendor supplied
components
and services.
The
charging
pumps
and the Ingersoll-Rand
spent fuel pool cooling
pumps
have
had failures
due to poor design.
Poor workmanship
has
resulted in failures of the feedwater heater
68 outlet valve,
deaerators
for the water storage
tanks,
and pressurizer
spray valves.
Finally, failures
due to poor vendor/contractor
supplied
components/services
include: reactor vessel
head 0-ring;
generator
turbine control wire; residual
heat
removal
pump mechanical
seals;
and atmospheric
steam
dump
valves.
Efforts continue to be directed in Plant Work Order
(PWO) backlog
reduction.
These resulted
in a positive reduction in the backlog
during the first part of the
SALP cycle.
However,
an upward trend
resulted
in about the
same total
as noted in the prior SALP period.
The increase
was
due largely to the
PWOs generated
for the licensee's
systematic material condition upgrade
program,
which was established
in October
1989,
and activities associated
with the Unit 3 refueling
outage.
The licensee
has established
a goal to reduce the backlog to
less
than
700
PWOs.
The licensee
has established
guidelines for
maintaining the percentage
of corrective maintenance
PWOs greater
than
90 days old at less
than
50%.
This target level has
been met
since the beginning of April 1990.
Although the current trend of
PWOs
may a'ppear high, it is
an
improvement
over the backlog noted in
prior SALP reports
and indicates
appropriate
management
involvement
in controlling and reducing
PWO backlog.
12
The licensee's
preventive maintenance
(PN) program continued to
improve throughout this cycle.
Although the
number of corrective
maintenance
(CN) work items
has
increased
due to the Unit 3 outage
and the plant's material
upgrade, program,
the
PN/PN+CN ratio has
shown
an improvinq trend throughout this
SALP period.
The ratio is
currently running at
59%, which is near the current goal of 60%.
The
total number of past
due
PMs which exceeded
their grace period
has
also decreased
during this period,
from 32 to less
than 20.
The
achievement
of this lower number is attributed to the licensee's
policy implemented in the last
SALP period to require management
approval for a
PM to exceed its grace period by 25K.
The licensee's
Analytical Based Predictive Maintenance
(ABPN) program
was
expanded
during this period with additional
personnel
being added
to the thermography
group,
increased capability to perform on-site
ferrography for the oil analysis
program,
and the addition of a new
Reliability Centered
Maintenance
(RCN) group consisting of four
maintenance
analyzers
and
a lead engineer.
The
RCN section selects
components for analysis
based
on impact on plant availability and
reliability. After the analysis is complete,
a package
is issued
recommending
program or equipment
changes
to improve reliability.
The group has
issued
packages
on the pressurizer
spray valves
and
condenser
tub'e cleaning
system
and is currently working on analysis
for the reactor coolant
pumps,
pressurizer
heaters/controls,
and the
control rod drive system.
The
ABPN group has continued to enhance
plant maintenance
throughout this period.
A few examples
include
identification of: air in-leakage
on the Unit 4 condenser;
the
location of coils with above-average
temperatures
in the reacto~
protection relays;
a defective
feed
pump rotor; excessive
vibration
in the
pump;
and high vibration in 3C charging
pump f1ui d drive.
The increased
licensee attention to reduce
the large
number of
control
room deficiency tags
noted in the last
SALP cy'cle resulted in
continued to improvement throughout this assessment
period,
The
total number of deficiency tags
was reduced
by approximately half of
the level at the beginning of the
SALP period.
This is
a significant
reduction
compared to totals
noted in previous years.
The Plan-of-the-Day
(POD) continues
to be
a licensee
strength.
The
Operations
Department
has the necessary
control to assign priorities
for maintenance activities
and ensure that operational
concerns
are
addressed.
The
POD clearly identifies
and prioritizes work to be
accomplished,
support groups required,
clearances
required,
and
applicable Radiation
Work Permits.
During the last
SALP cycle, the
Planning
and Scheduling
Group
began tracking the effectiveness
of the
POD to identify all jobs not worked as scheduled,
along with the
reason for,the delay.
The licensee
has
a current target of 70
percent effectiveness
with a goal of 90 percent
by the end of 1991.
During this
SALP period the total effectiveness
has
averaged
around
80 percent.
13
2.
3.
Two violations were cited in the Maintenance/Surveillance
area
during
this period.
a
~fR
Category:
2
Trend:
Improving
Recomendations
None
D.
Emer enc
Pre aredness
l. ~Anal sis
This functional
area
includes evaluation of activities related to the
implementation of the Emergency
Plan
and procedures,
support
and
training of onsite
and offsite emergency
response
organizations,
and
licensee
performance
during emergency
exercises
and actual
events.
Performance
is also evaluated
in the areas
of and interactions
between onsite
and offsite emergency
response
organizations
during
exercises
and actual
events.
During the
SALP period one routine
inspection
and
one exercise evaluation
were performed.
Two Emergency
Plan changes
were reviewed.
During this period, the licensee
provided
good management
support to
the emergency
preparedness
(EP) program and maintained
adequate
staffing levels for responding to an emergency.
Support to the
program
was evident from both corporate
and site management.
For
example, following the departure
of the site emergency
planning
coordinator,
corporate
management
provided
a corporate
emergency
planner to the site full time until the vacant position could be
filled.
Additionally, an emergency
planning consultant
was provided
to the site for calendar year
1990.
Site support to the program also
involved upgrading the emergency
response
coordinator to a
supervisory level reporting directly to the Operations
Superintendent.
Adequate staffing levels for responding
to an emergency
were also
demonstrated
during the November 30,
1989,
emergency exercise.
Emergency
preparedness
coordination
and support for coordination
was
good,
as reflected
by the detailed exercise
scenario
and effective
control observed
during the annual exercise.
The emergency
preparedness
training was effective,
as demonstrated
during exercise
observations
and inspection walk-throughs, with two noted exceptions.
The first training exception
was that the Emergency Coordinator
(EC)
did not know that the responsibility for emergency classification
remained with the
EC and did not transfer to the
EOF upon its
activation.
During the exercise,
the
EC recomended
rather than
declared
a General
Emergency
(GE) classification to the Recovery
Manager in the
EOF.
Despite this procedural error,
a
classification
and the accompanying. required actions
were
accomplished
in a timely manner.
This exercise
weakness
was
14
corrected
during the period and verified during an inspection
walk-through.
The other exception
was the limited effectiveness
of
the Technical
Support Group
(TSG) in support of the Technical
Support
Center staff during the exercise.
This was
due to a lack of timely
and complete information flow to the
TSG.
The remainder of emergency
comunications within and
among the licensee's
emergency
response
facilities were effective during the exercise.
There were three
emergency declarations,
all Notifications of Unusual
Events
(NOUEs) during the rating period, although
one
on August 23,
1989 was later determined to have
been in error and was withdrawn.
On Oecember
18,
1989,
the licensee
declared
a
NOUE for having failed
on Oecember
1, 1989,
(17 days earlier) to establish fire protection
compensatory
measures
within the one-hour time limit specified
by
Technical Specifications.
The significance of this belated
declaration
was mitigated
by the fact that the applicable
emergency
action level
(EAL) for event classification
was conservative
compared
with NUREG-0654 guidance,
has since
been revised
such that the
occurrence
on December
1,
1989, would not now meet the
EAL for a
HOVE.
On. April 11,
1990,
a hydrogen explosion
and fire in the Unit 2
(fossil plant) turbine generator
was promptly classified
and required
offsite notifications were made.
Management
support to the emergency
preparedness
program was apparent
in the guality Assurance
program
and implementation of corrective
actions.
Both the corporate
and site audits reflected substantive
findings with complete
and timely corrective actions.
The licensee's
self-critique of their emergency
exercise
was detailed
and consistent
with regulatory requirements.
The licensee
continues to maintain adequate facilities and equipment
to respond to an emergency,
including the Technical
Support Center,
the Emergency Operations Facility and communications
equipment.
The
relocated
(OSC) provides
adequate
communication capabilities
and its larger size
was
an improvement
over the previous
OSC facility, as
noted in the annual
exercise.
The licensee
submitted
two revisions to the Turkey Point Plant
Emergency
Plan during this assessment
period.
The substantive
change
was
an extensive rewrite of the EALs.
The changes
were consistent
with existing guidance
and regulatory requirements
in most cases.
In
those
few instances
where the changes
appeared
to degrade
the plan,
the licensee
revised
them so
as not to decrease
the effectiveness
of
the plan.
One exercise
weakness
was identified during the period.
Category:
2
3. Recommendations
Hone
15
E. Securit
and Safe uards
l. ~Anal sis
This functional area
addresses
those se"urity activities related to
protection of plant vital systems
and equipment,
as viewed during
inspections
and observations
during the assessment
period.
Inspection of the security 'program during this assessment
period
confirmed continuing improvement in program effectiveness
and
performance.
The licensee
has
focused considerable attention,
including personnel
and funds, to assure
adequate
and timely
accomplishment of the programed
upgrade.
"State of the art"
equipment
has
been procured,
and improved facilities have
been
designed to house security systems
and components.
Included are
new
protected
and vi.tal area barriers,
intrusion detection
and access
control systems,
high mast security lighting, dual security
computers,
a dedicated
security diesel
generator
and
an Entry Control
Building with an associated
vehicle entrapment
area.
The
new
security hardware
exceeds
basic regulatory requirements.
Installation of the facilities and system
components
is in progress
and is generally
on schedule.
Construction of the Entry Control
Building and installation of high mast lighting has
been
completed.
Cable duct banks
and associated
electrical
terminal facilities are
largely complete.
Barrier foundations
and equipment supporting
structures
are under construction.
,These activities are scheduled
to
be completed
by late
December
1991.
During this assessment
period,
NRC review activities were concluded for the majority of the
site-initiated
changes
to the Turkey Point physical security program.
Two site visits were conducted
by NRC staff, in February
and June,
to
finalize long-standing
issues
related to vital equipment
identification and vital barriers.
The resolution of these
issues
and the anticipated final implementation will significantly improve
the total security program at Turkey Point.
Initiatives to improve personnel
management
and resource utilization
noted in the 'previous
SALP report are continuing
and
a marked
improvement
has
been noted.
Performance
improvement is evidenced
by
the decline in the
number of violations cited from a total of ten in
the previous
SALP period to one in the current assessment
period.
The one violation cited was for a failure to control safeguards
material
by the security force.
In addition, there
was
an event that
involved the failure to maintain control of a visitor by a
contractor.
The improvements
in adherence
to regulatory requirements
and security plan commitments is attributed to senior management
attention,
recruitment of qualified and experienced
security managers
and supervisors
and resulting
enhancement
of morale,
and performance
orientation of security shift personnel.
The current limiting factor
in the overall effectiveness
of the security program is the extensive
use of compensatory
measures
which are necessitated
by deficiencies
and operational
limit'ations of the old security systems
and
facilities now in use,
and the extensive
upgrade efforts ongoing.
nr
16
Considerable
improvement
has
been
made in the security training
ogram
as evidenced
by security shift personnel
performance
and the
reduction in the number of violations.
Improvement is attribute
i
d 'n
part to the assignment
of a proprietary training supervisor
and
increased
emphasis
and involvement by the security contractor
corporate
management.
The extent of improvement in training
effectiveness
was demonstrated
by the performance of personnel
during
response drill scenarios
and the various evaluation
and critique
methods
employed
by security managers
and supervisor s.
The submission of security plan revisions
and temporary
changes
to
accommodate
frequent
changes
resulting from the security program
upgrade activities
have
been timely with few provisions requiring
further discussion,
validation, or change.
The licensee
has established
an improved comounications capability,
both within the security organization
and in communicating reportable
events,
security concerns
and issues,
and other significant items of
interest to the
NRC.
The on-site comunications capability was
enhanced
by the use of a highly reliable radio-telephone
system.
The
capability of the system frequently provided for the receipt of
notification of an event
by Region II directly from the event scene
prior to notification through
normal reporting channels..
guality Assurance
audits of the security program
have
been helpful in
identifying deficiencies
and providing recommendations
for
improvements.
The licensee
has
a well-established
"Fitness
For Duty" program that
is managed
by the corporate security function.
An on-site manager is
responsible for all on-site
and related activities.
Although the
program was not formally inspected
during this assessment
period,
review indicated that the program
was providing adequate
results with
a minimum of problems.
One violation was cited in the Security and Safeguards
area during
this period.
I. ~II
Category:
2
Trend:
Improving
3. Recomendations:
None
F.
En ineerin /Technical
Su
ort
l. ~Anal
s is
The engineering'and
technical
support area
includes all activities
associated
with the design of plant modifications, engineering
and
technical
support for operations,
outages,
maintenance,
testing
and
17
4
survei
1 lance,
procurement,
and licensed
operator training.
These
activities were viewed during routine
and special
inspections
throughout
the assessment
period.
Overall, engineering
and technical
support
has
been effective during
'his
assessment
period with improvements
evident in the System
Engineering
and Licensed Operator Requalification Training
programs.'eficiencies
were identified related to comprehensiveness
of generic
application evaluations',
incorporation of design information into
plant procedures,
and technical
overview of contracted
engineering
services.
Engineering
has
demonstrated
effective technical
support during. this
evaluation period.
Engineering evaluations
to support Appendix
R
technical
issues
'were excellent.
Technical
information was well
maintained
and complete.
Engineering
implementation of R.G. 1.97,
Instrumentation to Assess
Plant
and Environs Conditions During and
Following an Accident, was timely, technically sound,
and thorough.
The root cause
analysis for Telemand
Relay failures
was
comprehensive.
The Operating
Experience
Feedback
(OEF) program
identified
a potential plant operability problem related to
recirculation
sump screens.
Further effective engineering activity
was demonstrated
by the Emergency
Power System
upgrade initiatives
progressing
on schedule
through this evaluation period.
Engineering
, interface with the
NRC on this activity was characterized
by sound
analyses
and timely response
to requests
for further information.
Engineering
involvement in these
issues
demonstrated
an improvement
in comnunications
between corporate
engineer ing and the plant.
Performance
has
been generally adequate
within engineering
program
activities.
Design change control
and implementation
has
been
adequate
overall
and demonstrated
improvements
in some areas.
Design
change
packages
generated
in the previous year have
improved with
respect to screening
and detailed requirements for post- modification
test'equirements.
Engineering
involvement in the Request for
Engineering Assistance
(REA) and Nonconformance
Reporting
(NCR)
programs
has
been effective.
The licensee
has contributed considerable
resources
to the
reconstitution
and verification of Design
Base
Documents
(DBD).
The
NRC Design Validation Inspection
(DVI) conducted
during this
assessment
period reviewed engineering
resource
improvements
resulting from this activity.
The system level
DBDs were well
assembled,
however the associated
Component
Design Requirements
(CDRs) contained
errors which could have infiltrated into the design
process
since the
CORs were approved for use.
The
CDRs were
developed
by a contractor
and
had not been verified by FPAL.
The
scope of the
DBD verification program was too limited in that it did
not address all of the Reactor Protection
System
(RPS) functional
characteristics
and the external
hazards
design
bases.
A positive
aspect of the
DBD activity was the establishment
of a Systematic
Design Investigation
(SDI) program to evaluate
the issues
that arose
during the reconstitution effort.
The SDI program was found
18
extremely beneficial, particularly with respect to its expansion
to
include technical
issues
beyond select
systems
concerns.
Although the
DVI determined that engineering
and technical
support
performance
on issues
and program activities was generally effective,
there were examples of less effective engineering
performance.
A
change
to Component
Cooling Water,(CCW) flow rates
was
made without
verifying adequate
flow rates for all accident conditions.
There
were several
examples of design information not being incorporated
into plant procedures;
e.g.
minimum
CCW flow for Emergency
Containment
Coolers
(ECC),
PORV opening time limits, and
ICW to TPCW
isolation valve test requirements.
Inadequate
technical
overview of contracted
engineering
services
contributed to deficiencies
in design calculations identified by the
NRC DVI inspection.
Calculations
associated
with the
modifications contained errors resulting in the erroneous
evaluation
of heat exchanger
and nozzle loads.
Additionally, pipe and support
calculations
did not account for required load
and stress
aspects.
In a letter dated January
12,
1990, the licensee
provided plans
and
schedules
for corrective actions in response
to the DVI.
The last
corrective action to be implemented,
modification of Unit 4
CCW surge
tank anchorages,
is scheduled
to be completed
by the end of the dual
unit outage in 1991.
There were examples of inadequate
or incomplete generic application
reviews for specific plant issues.
Although the
OEF program
was
proactive in the identification of the recirculation
sump screen
issue,
the engineering applicability review for the operating unit
was not considered until prompted
by the
NRC.
Following
identification of Westinghouse
OT-2 switch deficiencies
on the Safety
Injection System,
the generic applicability review was delayed until
generic implications were raised
by other utilities.
Subsequent
review identified additional plant applications.
Engineering
evaluatio'n of the Fire Protection
Suppression
System operability due
to excessive
system
leakage
did not assess
the impact of excessive
leakage
preventing repairs to the system.
The performance
deficiencies
addressed
in the previous
paragraphs
do not indicate
major programmatic failures;
however they do indicate areas of
engineering
performance requiring increased
attention.
A comprehensive
Drawing Update
Program initiated 'in the previous
assessment
period was effective in reducing the backlog of drawing
changes,
however additional
drawing deficiencies
were identified in
this assessment
period.
The backlog
was reduced
from 28,000
outstanding
changes
in early 1989 to approximately 15,000.
Present
deficiencies
include existing drawings which are sometimes difficult
to read.
Several
NRC inspections
identified inaccurate
drawings
as
a
weakness
including: as-built conditions did not match drawings for
cable routing and piping supports,
Residual
Heat Removal
System
drawings did not accurately reflect Reactor Coolant System interface,
19
and there were
no drawings for the'containment
recirculation
screens.
During the previous
SALP period, weaknesses
were identified in the
procurement of parts
needed for equipment maintenance.
Improvements
were
made during this period,
such as:
parts
issues
being included
in daily
POD meetings,
assignment
of additional
maintenance
and parts
personnel
to identify and expedite parts
needed for the refueling
outage,
supplementing
the engineering staff to reduce
procurement
backlog,
and
use of blanket purchase
orders for routinely used parts.
In addition, the responsibility for materials
management for the
nuclear units
was separated
from the fossil units
and included in the
new nuclear division.
As
a result,
the average
parts reorder time
was
reduced substantially,
from 111.5 days to 76.4 days,
and
engineering
procurement
backlog
was reduced
sharply,
from 740 items
to the current goal of around
200 items.
However, opportunity for
improvement in parts
procurement
remains,
as indicated
by the
increase
in the
number of corrective maintenance
PWOs awaiting parts
from 115 at the start of the
SALP period to 170 at the end of the
period.
r
Technical
support for the Unit 3 outage
was effective.
Outage
management
was upgraded to provide full shift coverage at
a
management
level capable of redirecting resources
to support outage
activities.
Consultants
were contracted
to assist in pre-outage
planning.
Prior to the Unit 3 outage,
Unit 4 entered
an outage to
correct conditions which could result in Unit 4 shutdown during the
Unit 3 refueling outage.
Preparation for the upcoming'ual unit
outage included contracting
personnel
experienced
in nuclear
outage
activities to overview the outage
program.
Additional outage support
actions
were the establishment
of a Plant Nuclear Safety Subcomaittee
to focus
on outage activities,
and
a configuration control
team to
coordinate modification activities.
System Engineering
program
improvements
have contributed to increased
effectiveness
of the system engineering
organization.
Program
improvements initiated included:
formal documentation of
responsibility,
increased
system walkdowns, increase
in staff size,
and
a training program with increased
emphasis
on system design
training.
Examples of improved system engineering
effectiveness
were
demonstrated
by problems identified by system engineers,
including:
CCW system design flow discrepancies,
CCW system misalignment,
and
misposition of a Safety Injection System valve.
NRC inspections
identified an increased
contribution of system engineering to plant
technical
support in the areas of maintenance
and operations.
System
engineers
have contributed to a reduction in LCO hours
by
improvements
in the
CCW system chemical injection system
and
increased availability of the Emergency Diesel Generators.
The licensee
has
taken actions which have resulted in improvements in
the requalification training program.
Improvements
include increased
management
involvement in the requalification training program
and
increased
simulator time for requalification trainees.
Management
20
routinely observes
simulator examinations
and critiques.
Periodic
feedback
sessions
between
management,
operations,
and training
personnel
address
requalification training issues.
Average simulator
time for requalification individuals increased
to greater
than
90
hours versus
an average
of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> in the last
SALP period.
The
licensee
plans to reduce contract training staff by replacement
with
permanent
FPL staff from the licensed
operator class presently in
training.
The effectiveness
of training program
improvements
was demonstrated
by the
1990 requalification examination results.
Four of four ROs
and
10 of 12
passed
requalification examinations.
The
NRC rated
the licensee requalification program
as satisfactory
based
on this
87.5 percent
pass rate.
This program
had
been rated
as
unsatisfactory
since March,
1986.
Other examples of,effective
licensed
operator training activity include
a
100 per cent
pass rate
for 9 SRO upgrade
examination candidates
and
31
NRC Generic
Fundamentals
Examination candidates.
One violation was cited in the Engineering/Technical
Support
area
during this period.
2. Performance
Ratin
Category:
2
3. Recormendations
None
G. Safet
Assessment/ ualit
Verification
l. ~Anal sis
The assessment
of this functional
area is based
on
a review of
licensee
implementation of safety policies; activities related to
license
amendments,
exemptions,
and relief requests;
responses
to
Generic Letters, Bulletins,
and Information Notices; resolution of
safety issues
(10 CFR 50.59 reviews); safety review committee
activities;
and use of feedback
from self-assessment
programs
and
activities.
These activities were viewed during routine
and special
inspections
and comunications
throughout the assessment
period.
The licensee
was responsive
in supporting the numerous
NRC team
inspections
(See section V.B).
In all the areas
inspected,
the
licensee's
performance
was found to exceed regulatory requirements.
Special
mention was
made of the licensee's
successful
preparation
efforts, which included self-assessments
conducted
by QA and use of
outside contractor specialists
where appropriate.
The licensee
also
supported
several
large management
meetings
w'ith the
NRC at the site
to discuss
progress
in a wide range of issues.
In addition, the
licensee
briefed
NRC personnel
on the planning
and scheduling
progress for the dual unit outage
scheduled
to start late in 1990.
21
These meetings
required significant resources
by the licensee
and the
presentations
were substantive,
well prepared,
and helpful.
The licensee
has
taken corrective actions in response
to the
Independent
Management Appraisal
(IMA), which was performed to comply
with NRC Order'EA-87-85,
dated
October
19,
1987.
Positive personnel,
program,
and attitude
changes
have occurred
since the
IMA results
were issued.
The changes
included defining the educational,
experience,
and performance
requirements for 35 identified positions
noted in the
IHA report; approving written job descriptions;
and
filling those positions with qualified personnel.
Also, the licensee
has
suspended
their
management
development rotation program.
This
decision
was
made to maintain
a stable organization,
to develop
teamwork
and accountabil,ity,
and to ensure that managers
take
a
long-term view of the performance of their organizations.
Management
has
become
more directly involved in plant operations,
by:
monthly
evaluation of performance
indicators against site goals,
communicating established
goals to plant personnel
through monthly
meetings,
and increasing
management
presence
in the field.
This
management
involvement has
been
augmented
by operators
and system
engineers
being directed to identify deficient plant conditions,
and
the establishment
of a planning
and scheduling
group within the
Operations
Department.
The results of these efforts have
been
an
increased
awareness
in personal
accountability,
a downward trend in
the
PMO backlog,
and
an improved material condition of the plant.
.In
- addition,
new controls
on the commitment tracking process
have
reduced
the
number of overdue
comnitments
and
have
improved
comnunications
between
the licensee
and the
NRC.
The licensee
recently upgraded their employee
concern
program.
It is
now called the Speakout
Program
and
became effective on April 2,
1990.
The Speakout
manager is located in the Juno
Beach office and
reports directly to the Vice President
for Nuclear Assurance.
The
Turkey Point Speakout
supervisor
answers directly to the corporate
manager.
A special
team inspection of the Speakout
Program found
that the program was effective in identifying and resolving employee
concerns
and
had strong management
support.
The Speakout
Program is
a significant improvement over the previous
employee
concern
program.
The licensee
has self-identified
14 violations of NRC requirements
during this
SALP period.
In each case,
prompt and thorough
corrective actions
were taken
and,
as
a result,
these violations were
not cited by the
NRC.
In addition, self-assessment
activities were
carried out to review implementation of commitments to the
NRC
resulting from the Independent
Management Appraisal,
NRC maintenance
and fire protection
team inspections,'he
earlier Management-on-Shift
(MOS) program,
and several
other 'activities.
The Regulatory
Compliance section
has performed or participated in audits in
radiation protection, chemistry,
emergency
operating
procedures,
emergency
preparedness,
and fire protection/Appendix
R.
These audits
resulted
in positive
NRC inspection findings.
Vertical slice audits
have.-been
performed in the In-Service Inspection
and Hotor Operated
Valve programs.
The Performance
Monitoring section
has initiated
22
concerns
in several
areas
where subsequent
NRC inspections identified
similar concerns;
i.e.,
a concern regarding
the readiness
of a
recombiner
system
was identified prior to an
NRC inspection
of the
same area,
questioning
the adequacy of the flood protection
program
was initiated by gA, and the adequacy, of clearance
orders
and
work contr'ols
had also
been identified as
a concern
by the licensee.
The quality of LERs and special
reports
was generally good.
The
reports
were well written and provided adequate
information to
describe
the major aspects
of the events,
and they generally included
thorough analysis
and identification of the root causes
of the
events.
Three exceptions
were noted.
concerning
a
reactor trip on
high-high water level
due to
failure of a feedwater valve controller hand/auto station, did not
address
the potential effect of the post-trip cooldown at core end of
life when the shutdown margin would be most limiting.
regarding
a potential single failure design deficiency
discussed
in the Engineering/Technical
Support area, is another
example of an inadequate
analysis.
Also,
a special
report dated
June
19, )990, regarding Unit 3 standby feedwater
pump unavailability, did
not adequately
address
safety significance,
root cause,
corrective
actions,
or previous occurrences.
A high percentage
(65%) of the
34
LERs was attributed to personnel
errors
(see section V.G.).
Operational
personnel
errors
are discussed
further in the Operations
area.
During this evaluation
period there were two major licensing review
activities,
and
a number of generic
issues
and
NRC Bulletins were
resolved
and closed.
No emergency
Technical Specifications
(TS) were
requested.
Throughout the period, the licensee
showed significant
improvement in the timeliness of submittals
and responses
to
NRC
initiatives.
One major licensing review activity which has
been
ongoing is the conversion to Standard
Technical Specifications.
The
licensee
provided the necessary
resources
and timely,'igh quality
responses
to questions
to permit the
NRC staff to complete its
No
Significant Hazards
Evaluation
and its Safety Evaluation.
Another
major licensing review activity has
been
the Emergency
Power System
(EPS)
enhancement
effort.
At significant cost,
FPL is making
a major
safety improvement at the plant by upgrading
the emergency
power
system,
including the addition of two emergency diesel
generators,
an
extra station battery,
and two battery chargers.
During the
NRC
staff's review of these modifications
and associated
TS, the licensee
provided high quality responses
to questions
in a timely manner.
In the area of coomunications with NRC headquarters
staff, there were
a few minor problems associated
with the organizational shift of
licensing responsibility from corporate
headquarters
to the site.
However, since then improvement
has occurred.
The two violations cited in this area
involved the closure of a
Non-conformance
Report prior to completion of required actions,
and
failure to take corrective action in response
to electrical terminal
block corrosion that had
been previously identified.
23
2. Performance
Ratin
Category:
1
3. Recommendations
None
V.
SUPPORTING
DATA
A. Licensee Activities
Units
3 and
4 began
the assessment
period at power operation.
Unit 3
operated
very well with only two short interruptions until it
was shut
down on February 4,
1990, for a refueling outage.
The unit
restarted
again in early June
and
was at full power at the
end of the
period.
Unit 3 experienced
a relatively high availability of about
62K, considering
the four-month refueling outage.'nit
4 operated
throughout the period, but suffered
a number of brief shutdowns
and
interruptions of operations
due to equipment failures
and operational
problems.
Availability for Unit 4 was about
76%.
At the end of the
assessment
period, Unit 4 had
been shut
down for two weeks to repair
pressurizer
spray valves
and
RCS leaks.
A sumnary of the reactor trips
and unplanned
shutdowns for both units is in paragraph
F of this
section.
The licensee
made
one request for TS relief.
In May, 1990, the 48
Intake Cooling Water
( ICW) Pump experienced
low flow problems.
Aware
that replacing the
ICW pump within the
TS allowable time would be
difficult, the licensee briefed the
NRC on the technical
issues
and
requested
a Temporary Waiver of Compliance in a timely manner.
During this
SALP period,
FPL made significant organizational
changes,
creating
a separate
nuclear division and staffing it with
experienced
people.
8. Direct Inspection
and Review Activities
During the assessment
period,
32 routine, eight special,
and
no reactive
inspections
were performed, at Turkey Point by the
NRC staff.
Additionally, in October,
1989,
a team from NRR visited the
FPL Juno
Beach offices to review the licensee's
station blackout proposal.
The
special
inspections
included:
Fire Protection
and
10 CFR 50 Appendix
R safe
shutdown
requirements
Observation of operators
in simulator
and control
room
Performance
Enhancement
Program
Independent
Management
Assessment
followup
Maintenance
Team Inspection followup
Emergency Operating
Procedures
~ I
~ ~
t
24
Design Validation
Regulatory
Guide 1.97,
Instrumentation for Accident Conditions
C. Escalated
Enforcement Actions
1. Orders
None
2. Civil Penalties
None
D. Licensee
Conferences
Held During Appraisal
Period
August 21,
1989
-
Meeting held at
NRC headquarters
to discuss
the
Technical Specifications
revision project.
September
19,
1989
-
Heeting held at Turkey Point to discuss
management
issues,
engineering,
maintenance,
training,
and security.
November 1,
1989
-
Meeting held at
NRC headquarters
to discuss
calculation method for irradiation damage
function, Regulatory
Guide 1.99,
Rev. 2.
December
6,
1989
-
Meeting held at
NRC headquarters
to discuss
FPL's Probabilistic Risk Assessment.
January
9,
1990
-
Meeting held at Turkey Point to discuss
management
issues,
engineering,
maintenance,
training,
and security.
April 9-11,
1990
-
Meeting held at
NRC headquarters
to discuss
FPL's
Emergency
Power Systems
Enhancement
project.
May 16,
1990
-
Heeting held at Turkey Point 'to discuss
the dual
unit outage
and other programmatic
issues.
July 17,
1990
-
Meeting held at
NRC headquarters
to discuss
licensee's
proposed controls
and approach for
assuring
plant safety during the upcoming dual
unit outage.
July 26,
1990
-
Meeting held at RII office to discuss
the
licensee's
assessment
of their performance.
E. Confirmation of Action Letters
None
F. Reactor Trips and Unplanned
Shutdowns
~
~
t
25
Unit 3 experienced
three
unplanned
manual
shutdowns,
was manually taken
off line once,'and
had
two unplanned reactor trips during this
evaluation period.
Unit 4 experienced
six unplanned
manual
shutdowns,
was manually taken off line twice,
and
had four. unplanned
during this evaluation period.
The unplanned trips, taking the unit
off line, and shutdowns
are listed below.
l. Unit 3
June
9, 1990:
The unit tripped from 26K power on steam generator
high level
due to a feedwater
valve controller problem.
June
15,
1990:
The unit tripped from 10K power during shutdown
due
to personnel
error in pulling rods to control reactor coolant
temperature
with the turbine tripped.
Unplanned
Reactor
Shutdowns / Offline
August 7,
1989:
The unit was shut
down due to high steam generator
conducti Iity from condenser
tube leaks.
December
25,
1989:
The unit was taken off line to facilitate
corrective actions for MSIV solenoid
power electrical junction box
terminal strip corrosion
problems.
Hay 27,
1990:
The unit was shut
down to correct problems with new
atmospheric
dump valves failing to actuate
properly.
June
4, 1990:
The unit was shut
down due to continued
problems with
atmospheric
dump valves failing to actuate
properly.
2. Unit 4
September
15,
1989:
The unit was manually tripped from 100" power
following a transient
caused
by the left turbine stop valve
inadvertently closing due to an oil leak.
December
23,
1989:
The unit tripped from 94K power when the 4A main
steam isolation valve spuriously closed
due to electrical junction
box terminal strip corrosion.
April 9, 1990:
The. unit tripped from 100K power due to the failure
of an underfrequency
relay in the 48 4KV bus which tripped the
4B and
pumps
on
a false underfrequency
signal.
May 26, 1990:
The unit was inadvertently manually tripped from
approximately ll power due to personnel
error. when the reactor
operator
pushed
the reactor trip pushbuttons
in lieu of continuing
the reactor startup
as
planned.
~
I'J
~ 0
26
Unplanned
Reactor
Shutdowns/Of fline
August 16;
1989:
The unit was shut
down to correct gasket
installation problems with the main generator
hydrogen coolers.
September
6,
1989:
The unit was taken off line to correct main
condenser
tube leaks.
October
19,
1989:
The unit was shut
down to repair leaks in the
turbine control oil system.
January
9, 1990:
The unit was shut
down to correct
pump vibration problem.
May 18,
1990:
The unit was taken off line to correct
problems with
t'urbine control oil leaks.
May 20,
1990:
The unit was shut
down to facilitate cleanup of
turbine oil which became
contaminated
following an auxiliary oil pump
failure.
N
July 17,
1990:
The unit was shut
down to correct pressurizer
spray
valve leakage
problems.
G. Review of Licensee
Event Reports
During the assessment
period,
a total of 34
LERs were analyzed.
The
distribution of these
events
by cause,
as determined
by the
NRC staff,
is as follows:
Cause
Component Failure
Design
Construction,
Fabrication,
or Installation
Unit 3 or Conmon
Unit 4.
Personnel
Error
- Operating Activity
- Maintenance Activity
- Test/Calibration Activity
- Other
8'
2
0
Other
ota
Note 1:
With regard to the area of "Personnel
Error," the
NRC
considers
lack of procedures,
inadequate
procedures,
and erroneous
procedures
to be classified
as personnel
error.
27
Note 2:
The "Other" category is comprised of LERs where there
was
a
spurious
signal or
a totally unknown cause.
H. Licensing Activities
During the assessment
period the staff completed
seven licensing
actions.
Also, .a total of 36 multiplant actions for the
two units were closed.
I. Enforcement Activity
Functional
Area
No. of
eviat>ons
and Vio ations in
Each Severity Level
Dev.
V
IV
III II
I
Unit 3/Unit4
Plant
perat>ons
Radiological Controls
Maintenance/Surveillance
Emergency
Preparedness
Security
Engineering/Technical
Support
Safety Assessment/equality
Verification
6
2/0
2/2
0/0
1/1
1/1
2/2