ML17349A433
| ML17349A433 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/20/1992 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Rogers, Selin I, The Chairman NRC COMMISSION (OCM) |
| Shared Package | |
| ML17349A434 | List: |
| References | |
| NUDOCS 9210270414 | |
| Download: ML17349A433 (6) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20666 October 20, 1992 HEHORANDUH FOR:
The Chairman Commissioner Rogers Commissioner Curtiss Commissioner Remick Commissioner de Planque FROM:
SUBJECT:
=
Background===
James H. Taylor Executive Director for Operations TURKEY POINT UNIT 4.- SHUTDOWN BECAUSE OF OFFSITE EHERGENCY PREPAREDNESS CONCERNS Hurricane Andrew caused the shutdown of Turkey Point Units 3 and 4 on August 24, 1992.
Following substantial effort on the part of Florida Power and Light (FPKL) to repair storm-'related
- damage, Unit 4 was ready for restart by late September.
Unit 3 was in a refueling outage.
On September 28,
- 1992,
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the NRC staff.concurred in the licensee's readiness to restart Unit 4.
Subsequently, the plant commenced startup and attained 30X power by October 1, 1992.
On October 1,
1992-, after several conference calls with and a request from senior NRC management, FPKL senior management agreed to a shutdown of Turkey Point Unit 4.
The basis for the r'equest and subsequent shutdown was a Federal Emergency Hanagement Agency (FEHA) concern regarding the status of offsite emergency preparedness (EP), incl,uding verification of.offsite emergency planning,"verification of the availability of facilities and equipment, and analysis of the unique conditions existing in the emergency planning zone (EPZ) in the wake of Hurricane Andrew.
FEHA had not been 'given sufficient notification by.the NRC of the impending Unit 4 startup and therefore had not had the opportunity to perform the 'necessary verification of offsite emergency preparedness.
Subsequent to the plant shutdown, FEHA dispatched a team to Dade County, Florida to commence the,verification activities.
NRC personnel assisted..the FEHA team and functioned as team members under the leadership of the FEHA team manager.
Initial analysis of the NRC's management of the offsite emergency preparedness aspects of the Turkey Point Unit 4 restart indicated a number of weaknesses or lapses in coor'dinating the pr'ocess.
Consequently, to determine root causes and lessons
- learned, both Region II and'he Office of Nuclear Reactor Regulation (NRR) performed critical self-analyses of their respective roles in the'estart process.
These reports are enclosed.
In addition, Jim Sniezek and I met with the key NRC headquarters and Region II.personnel associated with the Turkey Point restart to explore the root'causes for this breakdown in our restart process related to offsite EP.
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The Commission Discussion Extensive onsite and offsite damage occurred at Turkey Point as a result of Hurricane Andrew.
FP&L and the NRC coriducted comprehensive,onsite damage assessments
'and inspections following the storm.
FP&L identified and the NRC concurred in the equipment and other items to be repaired,
- restored, retested, or otherwise addressed as a prerequisite to plant restart.
These items formed the basis of the restart criteria arid inspection plan developed by Region II.
Region II formed a task force to monitor the licensee's recovery operations and activities.
,During the recovery period, Region II and NRR maintained close and active contact with the licensee.
However, the restart process was flawed in that acknowledgement of the status of offsite emergency preparedness was lacking and sufficient coordination with FEHA had not taken place.
A variety of factors contributed to a flawed restart process resulting in premature restart concurrence and the subsequent shutdown of Unit 4.
Deficiencies included poor. internal and external communications and coordination, lack.of a formalized restart process with attendant procedures and checklists, a lack of management and staff foc'us on the effect that unique offsite conditions would have on plant restart, and inadequate
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training/knowledge of the role of and relationship with FEHA.
Communications/Coordination The chronologies attached to the enclosed Region II and NRR self-assessments
, demonstrate substantial coordination in the restart process.
Nevertheless, inadequate communications and coordination at several levels were major contributors in the failure to identify the need for an offsite EP assessment..
Limited coordination and inadequate communications between Region II divisions resulted in incomplete participation in the restart process by the technical division with'responsibility for EP.
Communications between Region II tech'nical divisions,and their counterparts in NRR were inadequate and, in part, contributed to NRR's'ailure to provide FEMA headquarters with current and complete information regarding the schedule and status for startup of Turkey Point.
Within NRR, inadequate coordination between Projects and the Division of Radiation Protection and Emergency Preparedness (DREP) also contributed to the failure of the NRC to communicate adequately with FEHA headquarters.
A more proactive posture on the part of DREP in following the progress of,Turkey Point restart and in communicating with FEMA headquarters would also have been beneficial..
Finally,'he external communication between Region II and FEHA Region IV was inadequate in that FEMA was not contacted until after plant startup.
Restart Process While the restart plan used by Region II for Unit 4 startup was extensive and included substantial inspection activities, it was developed in an ad hoc manner.
Without a defined formalized 'restart p'rocess, restart criteria were developed by Region II that did not include any requirements related to offsite EP.
Consequently, the need to coordinate EP assessment activities with FEMA was never identified.
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The Commission Management/Staff Focus Staff and management attention following the hurricane was appropriately focused on reactor -safety.
NRC activities for several weeks after the hurricane wer'e concentrated on-assessing storm-related
- damage, licensee actions to maintain reactor safety, and actions to restore equipment/systems necessary for plant restart.
The staff did an excellent job in this regard.
- However, although aware'f the storm effects in the surrounding
- area, the NRC focus at Turkey Point generally remained "inside the fence."
The staff was generally not sensitive to the impact of the s'torm on offsite EP and consequently did not include appropriate consideration for verification of offsite EP.
Additionally, as restoration at Turkey Point progressed, NRC emphasis on restart, activities became more routine.
Management and staff attention returned to other high priority issues.
Consequently, as restart approached, senior NRC manage'ment missed an 'opportunity to question the restart criteria and in particular the'tatus of offsite EP.
Another contributing factor in *this area was a lack of staff recognition of the uniqueness of the situation at Turkey Point and the surrounding area.
This was the first nuclear power plant to suffer such a major natural disaster and the impact of the resultant devastation of the surrounding area was not fully appreciated.
As a result, a special approach to match the uniqueness of the situation was not used.
Knowledge/Training In general, the level of staff understanding of the. role and responsibilities of FEMA regarding offsite EP as well as the NRC relationship with FEHA appears to be inadequate.'
variety of staff, including managers, expressed a lack of knowledge regarding these issues; While training in these areas has been conducted in the past, either it had,limited effectiveness or a broad enough audience was not included.
An associated deficiency involves confusing inspection guidance related'o EP.
Some inspection procedures imply that it is an inspector's responsibi'lity to assess aspects of offsite EP that are normally within the purview of FEHA.
Conclusion While the post-hurricane onsite activities of the staff were'omprehensive and well-coordinated, a significant deficiency i.n the staff approach to plant restart existed.
The combined factors noted above resulted in incomplete restart criteria regarding the need for verification of the acceptability of offsite EP and in inadequate communication and coordination with FEHA.
The Commission OCT sg tggp Actions Corrective actions are necessary to address each of. the factors noted above.
Additional training of headquarters and regional staff in the role and responsibilities of FEHA and the relationship of the NRC to FEHA will be conducted.
Existing gui'del.ines for pl'ant restart (NRC Inspection Manual Chapter 0350) will be modified to incorporate lessons learned and address restart plans and criteria for plants shut down following significant events.
Inspection procedures will be reviewed to ensure they properly reflect the separation of NRC'nd FEMA 'responsibilities regarding EP.
In addition, although not an immediate factor'in the Turkey Point restart
- issue, the NRC-FEHA Memorandum of Understanding will be reviewed and revised as necessary to ensure the respective roles of the NRC.'and FEHA are clearly defined for situations similar to this.
'Discussions have been held with appropriate staff
'and managers involved in the restart to ensure their understanding of the issues and deficiencies.
This paper and the Region II and NRR self-
,assessments will ha'v'e wide dissemination in the staff to ensure the lessons learned'are thoroughly under'stood.
I will provide the Commission with the details of these corrective actions as they are further developed.
Original Signed By-
)ames lk Taylor James H. Taylor Executive Director for Operations
Enclosures:
As stated cc: