ML17349A787
| ML17349A787 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/02/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17349A786 | List: |
| References | |
| 50-250-93-03, 50-250-93-3, 50-251-93-03, 50-251-93-3, NUDOCS 9304130113 | |
| Download: ML17349A787 (44) | |
See also: IR 05000250/1993003
Text
ENCLOSURE
INITIALSALP BOARD REPORT
U. S. NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
INSPECTION REPORT NUMBER
50-250/93-03 AND 50-251/93-03
FLORIDA POWER AND LIGHT
TURKEY POINT UNITS 3 AND 4
SEPTEMBER 29, 1991 - JANUARY30, 1993
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TABLE OF
CONTENTS
I.
INTRODUCTION .............................
Pa<ac
II. SUMMARY OF RESULTS .........................................
III. CRITERIA ...............
3
IV.
PERFORMANCE ANALYSIS
A.
B.
C.
D.
E.
F.
G.
Plant Operations ...................
Radiological
Controls ..............
Maintenance/Surveillance ........
Emergency
Preparedness .............
Security ...........................
Engineering/Technical
Support ......
Safety Assessment/equality
Verification
3
6
9
13
15
17
20
V.
SUPPORTING
DATA
A.
B.
C.
D.
E.
F.
G.
H.I.
Licensee Activities ................
Reactor Trips and Unplanned
Shutdown
Direct Inspection
and Review Activit
Escalated
Enforcement Actions ......
Confirmatory Action Letters ........
Licensee
Conferences ...............
Licensing Activities ...............
Review of Licensee
Event Reports ...
Enforcement Activity ...............
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23
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25
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25
25
26
27
'e,
INTRODUCTION
The Systematic
Assessment
of Licensee
Performance
(SALP) program is an
integrated
Nuclear Regulatory
Commission
(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
SALP 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 assessment
of their facility's pe}formance in each functional
area.
An NRC SALP Board,
composed of the staff members listed below,
met on
March 15,
1993, to review the observations
and data
on performance,
and
to assess
licensee
performance
in accordance
with NRC Manual
Chapter
0156,
"Systematic
Assessment
of Licensee
Performance."
This report is the NRC's assessment
of the licensee's
safety performance
at Turkey Point Units 3 and
4 for the period September
29,
1991, through
January
30,
1993.
The
SALP Board for Turkey Point was
composed of:
J.
R. Johnson,
Deputy Director, Division of Reactor Projects
(DRP),
Region II (RII) (Chairman)
J.
P. Stohr, Director, Division of Radiation Safety
and Safeguards
(DRSS), RII
A. F. Gibson, Director, Division of Reactor Safety
(DRS), RII
M. V. Sinkule, Chief, Reactor Projects
Branch 2,
DRP, RII
R.
C. Butcher,
Senior Resident
Inspector,
Turkey Point,
DRP, RII
H.
N. Berkow, Director, Project Directorate II-2, Office of Nuclear
Reactor Regulation
(NRR)
L. Raghavan,
Project Manager,
Turkey Point, Project Directorate
II-2,
NRR (by telephone)
Attendees
at
SALP Board Meeting:
K. D. Landis, Chief, Project Section
2B,
DRP, RII
W. H. Rankin, Chief, Facilities Radiation Protection Section
(FRP),
DRSS, RII
A. T. Boland, Radiation Specialist,
FRP,
DRSS, RII
G.
B. Kuzo, Senior Radiation Specialist,
Radiological Effluents
and
Chemistry. Section .(REC),
DRSS, RII
W.
M. Sartor,
Senior Radiation Specialist,
Emergency
Preparedness
Section
(EP),
DRSS, RII
A. Gooden,
Radiation Specialist,
EP,
DRSS, RII
W. J. Tobin, Senior Physical Security Specialist,
Safeguards
Section
(SS),
DRSS, RII
D.
H. Thompson,
Physical Security Specialist,
SS,
DRSS, RII
G. A. Hallstrom, Reactor Inspector,
Materials
and Processes
Section,
DRS, RII
R.
P. Schin, Project Engineer,
Project Section
2B,
DRP, RII
SUMMARY OF
RESULTS
During this 16-month
assessment
period,
Turkey Point continued to
demonstrate
improved performance.
Preparations
for and recovery from
Hurricane Andrew were conservative,
timely, and effective.
Excellent performance
in the Plant Operations
area continued.
Operators
performed well during plant startups,
plant shutdowns,
and transient
conditions.
Conservative
management
actions in preparing, operators
and
the plant for Hurricane
Andrew, control
room oversight, verification of
operator log keeping,
control of shared
systems
(fossil/nuclear),
and
comprehensive
plan of the day meetings contributed to the strong
performance
in this area.
Conservatism
was also demonstrated
by the
performance of full-scale post-refueling type star tup tests
on Unit 3
following the dual-unit outage.
Post-hurricane
morale problems, staff
attrition,
and personnel
errors were aggressively
addressed
by management
actions
but continued to be
a challenge.
Improved performance
was noted in the area of Radiological Controls.
Personnel
exposure controls
and collective doses
were improved by
effective As Low As Reasonable
Achievable
(ALARA) Program efforts
including resistance
temperature
detector
(RTD) bypass
removal
and
effective contamination control.
A strong environmental
monitoring
program, effective management 'of liquid and gaseous
effluents,
and
a
substantial
reduction in onsite
r adwaste
volume also contributed to this
improvement.
Areas for further improvement included procedural
adherence
and resin transfer controls.
Improvement continued in the Maintenance/Surveillance
area.
Work
planning
and scheduling,
equipment reliability initiatives, corrective
maintenance
backlog reductions,'and
general
plant material condition
and
housekeeping
were improved.
Areas for further improvement included
surveillances
and the quality of maintenance
work.
Superior performance
in Emergency
Preparedness
(EP)
was maintained.
Strengths
included preparation for and recovery from Hurricane Andrew,
management
support for the
EP program,
and performance
during
exercises.
Areas for further improvement included originality of
exercise
scenarios
and in-plant paging audibility.
Superior performance
in Security was also maintained,
with strengths
in
site management,
tactical
response .training, .equipment condition,
and the
Fitness-For-Duty
program.
Improved performance
in Engineering/Technical
Support
was demonstrated
by
the quality of modification packages,
reduction in engineering
backlogs,
prioritization of engineering
work, training, self-assessments,
and
excellent support for Hurricane Andrew recovery.
Conservative
actions
were demonstrated
by the performance of IOOX eddy current testing
on
tubes.
Areas for further improvement included drawing
0'
. quality, contractor oversight,
and equipment selection
and procurement.
The Safety Assessment/guality
Verification area
performance
continued to
be excellent.
Management
involvement
and support,
a strong quality
organization,
effective audit programs
and self-assessments,
and good
root cause
evaluations directly contributed to this performance.
Areas
for further improvement included timeliness
and quality of licensing
submittals.
Overall, performance
continued to improve in almost all areas.
This
improved performance
was due to the licensee's
continued
commitment to
self-identification and correction of potential
problems;
a strong
management
team;
and
a dedicated,
experienced staff.
Facilit
Performance
Summar
Functional
Area
Rating Last
Rating This
Period
Period
Plant Operations
(Operations
& Fire Protection)
Radiological
Controls
Maintenance/Surveillance
Emergency
Preparedness
.
Security
Engineering/Technical
Support
Safety Assessment/
equality Verification
Outage
III. CRITERIA
2 improving
2 improving
1
1
2
1
2 improving
1
1
2 improving
1
NA
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.
Therefore,
these criteria are
not repeated
here,
but will be presented
in detail at the public meeting
to be held with licensee
management.
IV.
PERFORMANCE ANALYSIS
A. Plant
0 erations
I .
~Anal
s i s
s
This functional
area
addresses
control
and performance of activities
directly related to operating the unit,
as well as fire protection.
During this assessment
period, there were no reactor trips due to
operator errors.
Unit 3 had one manual reactor trip in response
to
a mechanical
failure of a fitting in the turbine control oil piping,
and Unit 4 had
one automatic reactor trip due to
a switch failure
during surveillance testing of the containment isolation racks.
0
During the previous
SALP period, Unit 4 had one automatic trip due
to
a personnel
error.
On
an operating time basis, this represented
a performance
improvement over previous
SALP periods.
Operations
personnel
performed well during plant startups,
shutdowns,
and transients.
Performance
on NRC-administered
operator
license
examinations
was excellent (all five crews
and
41 of 42
operators
passed),
as further discussed
in the Engineering/
Technical
Support section.
Several
positive operator actions
were
noted during this
SALP period.
For example,
during
a surveillance
that inappropriately permitted axial flux deviations outside the
target
band at
100X power,
an operator recognized
the discrepancy
and immediately reduced reactor
power to less
than 90X.
In
addition,
when Unit 3 entered
Node
3 following the dual-unit outage,
an oncoming operator recognized that the Unit 4 refueling water
storage
tank did not meet the technical specification-required
water
volume.
Also, prompt operator actions
aided in preventing
two
reactor trips following plant transients
due to equipment failures.
The licensee routinely made conservative
decisions affecting plant
operations.
For example,
following the dual-unit outage,
the
licensee
performed
a full-scale post-refueling type startup test
program even though Unit 3 had not been refueled.
The Unit 3 fuel
had
been offloaded
and reinstalled in the
same configuration.
In
addition, the stationing of managers
in the control
room during
critical plant evolutions
and the use of shutdown risk management
controls during shutdowns
were noted
as strengths.
In response
to
industry events
and prior to a related
NRC Information Notice, the
licensee
aggressively initiated operator log reviews.
These
reviews
identified problems with non-licensed
operator logs, for which
prompt corrective action
was taken.
In preparation for Hurricane
Andrew, licensee
management
required all operating
crews to attend
simulator training to practice the most likely scenarios
they might
encounter (i.e., loss of offsite power, loss of intake cooling
water, etc.).
Operator
and reactor plant performance during
Hurricane Andrew was excellent.
During previous
SALP periods,
the
NRC expressed
concern regarding
high operator turnover
and overtime.
During the last
SALP period,
the licensee
increased
the licensed
operator training class size
and
increased
incentives to retain personnel
such that six shifts could
be implemented.
During this period, the oper ating staff remained
on
a six-shift rotation with eight-hour shifts.
A second Assistant
Nuclear,. Plant .Supervisor..(ANPS)
position was added, -creating
a Unit
3- and
a Unit 4-specific
ANPS position.
This provided additional
supervisory oversight for each unit.
The increase
in operations
staffing and six-shift rotation aided in reducing operator overtime
from 14X in 1991 to
12X in 1992.
However, the attrition rate for
operations
personnel
increased after Hurricane Andrew.
From August
24,
1992, to January
30,
1993, eight licensed
and three non-licensed
operators
resigned.
To compensate
for the loss of licensed
operators,
a licensed
operator training class of nine career
path
non-licensed
operators
was started
in October,
1992.
To fill the
operator career
path,
a non-licensed entry-level class of 20 was
authorized to start in February,
1993.
The licensee
had addressed
operator attention to detail
and
equipment clearance
problems during the last
SALP period.
During
this
SALP period, there
were
an increased
number of operator errors
after Hurricane Andrew (i.e. inadvertent
power operated relief valve
lifts and
a clearance
error with personnel
contamination).
To
further address
the operator error and clearance
problems during the
post-hurricane
Unit 3 refueling outage,
licensee
management
formed
a
configuration control review team to review evolutions requiring
increased
management
attention.
Prior to performance of a task,
the
team was chartered
to review all clearances
to ensure that adequate
boundaries
existed
and that all vents
and drains were located within
the isolation boundary,
to review clearance
releases
for correct
order, to review all clearance
boundary modifications
and test
releases
prior to implementation,
and to review complex evolutions
to ensure that all precautions
were taken to minimize any risks.
Pre-evolution briefings were conducted prior to releasing
clearances
to ensure
system integrity.
Also,
a third (independent)
verification was performed
on all clearances
on radioactive
systems.
Poor quality drawings were noted
as contributing to several
personnel
errors.
The licensee
has prepared
upgraded
and
computerized plant operating drawings,
which are scheduled
to be in
place early this year.
At the
end of the
SALP period, operator
personnel
errors
were still being observed,
indicating
a continuing
need for management
attention.
The plan-of-the-day
(POD) meeting continued to be comprehensive
and
well controlled such that all disciplines
were involved in the
planning
and defining of the next few days'ork objectives
and
critical path work.
This helped minimize the time spent in limiting
conditions for operation
when equipment
was taken out of service.
The
POD tracked several critical indicators
such
as off-normal
control
room green tags,
the leak list, open temporary
system alterations,
and equipment out of service.
To emphasize
the
need to address
the plant work order backlog,
the ten oldest plant
work orders in each discipline were highlighted.
The number of
control
room deficiency tags
was reduced
from about
65 during the
last
SALP period to about
15 at the end of this
SALP period.
During th'e last
SALP period, control of work on shared
systems
(between
the. fossil
and nucl.ear..units)
was .noted
as
a problem.
The
licensee initiated program
changes
to control work in the switchyard
and
on other shared
systems.
One of the controls
was
a requirement
to notify the nuclear plant supervisor prior to any work in the
There were
no fossil/nuclear interface
problems
identified during this
SALP period.
An inspection of the fire protection
program was conducted
following
the recovery from Hurricane Andrew.
The results indicated that the
0
fire protection
program improved over the previous
SALP period.
For
example,
the number of fire protection
system impairments,
which had
averaged
between
40 and
60 in 1990,
was reduced to an average of
less than
10 by the end of 1991
and was maintained at about that
level during this assessment
period.
Hissed surveillances
in the
fire protection
area
were noted
as
a problem in the last
period; there were none noted during this
SALP period.
The
licensee's
response
(Thermo-lag insulation)
was
prompt
and effective.
That response
included the installation of
video camera
coverage for Thermo-lag areas that did not have
installed fire detection.
2.
Five violations were cited in the Operations
area during this
assessment
period.
Performance
Ratin
3.
Category:
1
Recommendations
None
B. Radiolo ical Controls
~Anal sis
This functional area
addresses
those activities directly related to
radiological controls, radioactive waste
management,
environmental
monitoring, water chemistry,
and transportation of radioactive
material.
The radiation protection
(RP) program was effective in controlling
personnel
exposure to radioactive materials
and protecting the
health
and safety of plant personnel
and the public.
No internal or
external
exposures
in excess
of 10 CFR 20 limits occurred during the
assessment
period.
During the assessment
period, the licensee's
RP department
was
reorganized.
The restructuring established
the
ALARA and dosimetry
groups
as separate
entities,
reporting directly to the Health
Physics Supervisor,
and facilitated management
involvement in these
areas.
Adequate
numbers of qualified staff were available to
support both. routine
and outage activities...The technician training
program continued to be
a strength
as indicated
by comprehensive
job
performance
measures
for contractor technicians,
the inclusion of
integrated
mock-ups
and systems orientation in continuing training,
and licensee
support for National Registry of Radiation Protection
Technicians certification.
The Chemistry Department staff was well-
trained,
and staffing levels remained stable.
The
RP and chemistry self-assessment
programs
were generally
0
9'
proactive during the assessment
period.
Audits of both programs
were well-planned
and documented
with detailed information and
recommendations
to facilitate implementation of required corrective
actions.
In addition, the Radiological
Incident Report System
and
the recently-initiated Supervisory Surveillance
Program were used
effectively by the licensee to appropriately identify, trend,
and
correct health physics
problem areas.
Overall, the licensee
conti.nued to effectively manage collective
dose,
expending
approximately
419 person-rem during the assessment
period.
Collective doses for 1991
and
1992 were 938 and 325 person-
rem, respectively
(both under the estimated
person-rem
goals for the
periods).
For 1991, the majority of the dose
expended
was
associated
with the dual-unit outage
which included dose-intensive
work such
as resistance
temperature
detector
(RTD) removal.
For
1992, the dose primarily reflected operating conditions, with
approximately
64 outage
days.
The dose
was consistent with work
scope,
and the licensee
realized
a dose reduction from previous
assessment
periods, particularly with respect to dose during non-
outage conditions.
Efforts in ALARA during the assessment
period were effective in
reducing overall collective dose.
The licensee
realized significant
reduction in steam generator
channel
head
loop piping dose rates
(by approximately
one half) due to the
effective implementation of a lithium/boron coordinated
chemistry
shutdown
program,
as well as reduced
dose rates
due to the removal
of the
RTDs during the previous
assessment
period.
The licensee's
improved performance of repetitive refueling tasks during the
1992
Unit 3 refueling outage resulted
in the completion of many tasks
with less
dose than their past best performance.
In particular, the
use of new reactor vessel
head tensioning
equipment
reduced
dose
considerably.
Other
ALARA efforts were undertaken
during this
assessment
period,
such
as the implementation of digital alarming
dosimeters,
to further reduce
doses.
I
The licensee's
radiation protection work planning
and program
implementation
were generally good;
however,
several
examples of
lack of attention to detail
as regards
procedural
compliance
were
identified during the review cycle.
These
included the failure to
conduct
ALARA pre-job briefings for workers in accordance
with
radiation work permit
(RWP)
and procedural
requirements;
the failure
to perform routine radiological
surveys consistent with procedural
requirements;-end
the failure -to adequately -leak test Iron-55 sealed
sources.
Corrective actions
associated
with these
areas
were
completed or in progress
at the end of the assessment
period.
Weaknesses
identified during the previous
assessment
period related
to the respiratory protection
program were corrected.
Continued
improvement
was noted in the licensee's
control of
contamination.
During the assessment
period, the licensee
decreased
contaminated
surface
area to an average of approximately
6110 square
feet,
approximately five percent of the radiation-controlled
area.
In addition,
personnel
contamination
events for 1992 were
approximately
66,
as
compared to a goal of 100, which was
a decrease
from previous years.
The licensee
continued to pursue
improvement
in laundry/protective clothing monitoring for further reduction in
personnel
contamination
events.
Overall,
improvements
were observed
in general
housekeeping
and radioactive material control,
particularly in,yard and radioactive material
storage
areas.
Plant water chemistry
was maintained within Technical Specification
(TS) limits and
an accurate
radiochemical
analysis
program continued
during the assessment
period.
Initiatives included the development
of methods to upgrade plant operations,
including the use of a
reverse
osmosis
process
to produce very high quality water for the
Mater Treatment
Plant for use in the primary and secondary plant.
During the assessment
period,
the licensee
took steps to correct
long-standing
problems with the operation of the secondary
system
polishers for removal of filterable solids.
Water chemistry
controls contributed to the fact that very few steam generator
tubes
have required plugging.
The radiochemical
analysis
program
effectiveness,
including sample collection
and analyses
accuracy,
was demonstrated
by overall
agreement
between results for analyses
conducted
using licensee
and the Region II mobile laboratory systems
during
a confirmatory measurements
inspection.
During the assessment
period, the liquid and gaseous
effluents
release
program was managed effectively.
Plant effluent releases
'ere
small fractions of their allowable regulatory limits, with no
unplanned
releases
reported.
Preparation
and recovery actions
regarding effluent control
and monitoring associated
with the August
24,
1992, hurricane
were timely, met
TS requirements,
and were
considered
appropriate.
These actions
included initially securing
all effluent release
pathways
and implementation of supplemental
monitoring as
a result of damage to the main stack
and radioactive
waste
(radwaste)
building ventilation systems
from the storm.
The licensee's
Radiological
Environmental
Monitoring Program
(REAP),
a program strength, verified that facility operations
resulted
in
minimal environmental
impact.
For the assessment
period,
measured
doses
and radionuclide concentrations
were significantly less than
TS reporting values or the specified lower limit of detection.
No
trends in the environmental
monitoring data were noted
compared to
previous
assessment
periods.
Accuracy of sample
analyses
was
confirmed--independently-
by -favorable-comparison
of licensee
analytical results with values for selected
environmental
samples
sent to the
NRC contractor laboratory.
Licensee
actions to restore
. the
REAP following the hurricane
were considered
timely and
appropriate.
With the exception of a July 9,
1992,
spent resin transfer spill
event,
improvements
in the processing,
storage,
and shipping of
radwaste
were noted during the assessment
period.
The resin spill
e
2.
contaminated
approximately
2000 square feet (ft~) of floor space
due
to the failure to follow procedures for equipment set-up
and
verification.
Poor housekeeping
in the area,
weak interfaces
between licensee
and vendor procedures,
and partially blocked floor
drains also contributed to the spill.
No concerns
were identified for shipping activities
and
improved
compliance with posting
and labeling requirements
were noted
as
compared to the previous
assessment
period.
Further,
management
commitments
and staff actions resulted
in a significant reduction of
contaminated
equipment
and dry active waste maintained onsite.
From
June
1992 through October
1992, the licensee effectively reduced
the
volume of radioactive
waste stored onsite
from 52,000 to 2,500 cubic
feet (ft ).
This reduction contributed to the lack of radioactive
waste
problems during Hurricane Andrew.
One violation was cited in the area of Radiological
Controls during
this assessment
period.
Performance
Ratin
3.
Category:
1
Recommendations
None
C. Haintenance
Surveillance
~Anal sis
This functional
area
addresses
activities related to equipment
condition, maintenance,
testing,
and surveillance.
In addition to
routine inspections,
a special
inspection of the motor operated
valve program
was conducted.
Although equipment failures continued to impact plant operations,
equipment reliability was improved over previous
SALP periods.
This
was evidenced
by reliable plant operation prior to the shutdown of
both units for Hurricane Andrew and by the fact that all necessary
equipment functioned
as required during the hurricane.
Additionally, unit availability was improved significantly over
previous
SALP periods.
During this assessment
period, there were
no
reactor trips due to maintenance. or surveillance
personnel
errors.
Equipment problems requiring plant shutdowns or power reductions
during this assessment
period included:
piping failures in the
turbine control oil system, oil leakage
from the
3B and
4C reactor
coolant
pumps,
and
a leaking weld joint on
a
flow
transmitter.
The licensee
implemented
several
programs to improve equipment
reliability and reduce the impact of equipment malfunction
on plant
10
operation,
which resulted
in improved plant operations
as noted
above.
A procedure
was established
between
the Haintenance,
Engineering,
and Technical
Departments
to require
a root cause
analysis of equipment failures which recur following maintenance
action and/or engineering resolution.
Examples of specific issues
which were analyzed for root cause
and resolution during this period
include failures in the following systems:
residual
heat
removal
pump mechanical
seals,
area radiation monitoring system,
main
turbine control oil piping, spent fuel
pump shaft,
intermediate
range nuclear instrumentation,
turbine auxiliary oil pump,
and small
bore piping welds in the charging
system.
Also, the licensee's
aggressive
approach to a comprehensive
Generic Letter 89-10 Hotor
Operated
Valve program continued to improve equipment reliability.
Equipment availability was enhanced
by using
a quarterly schedule.
This method allowed each discipline to ensure that all necessary
maintenance
was performed
and coordinated
as
one equipment
outage.
This program also reduced
the number of hours safety-related
equipment
was in a Limiting Condition for Operation for planned
maintenance.
In addition, the quarterly schedule activities were
reviewed from a Probabilistic Risk Assessment
standpoint to evaluate
risk peaks
associated
with out-of-service
equipment.
The
Reliability Group of the Haintenance
Department started
a new
program in December
1992 to perform
a reliability-centered
maintenance
analysis
on
an entire system rather than just at the
component level.
The feedwater
system,
which was under review at
the end of this
SALP period,
was the first system
chosen
based
on
the number of corrective maintenance
manhours
expended
and the
potential reliability gains.
The licensee's
attention.to
reducing the backlog of corrective
maintenance
plant work orders
(PWOs), control
room deficiency tags,
and out-of-service control
room instruments
improved during this
period,
as all three indicators
reached all-time lows.
The non-
outage corrective maintenance
PMO backlog
was reduced
from 750 at
the end of the last
SALP cycle to approximately
425 at the end of
this cycle, which was significantly below the licensee's
goal of
700.
In addition, the ten oldest of these
PWOs for each maintenance
discipline were tracked at the daily
POD meeting,
which resulted in
completing the oldest
ones
(from 1986 to 1989).
The Haintenance
Department
continued to complete
more than
50X of the non-outage
corrective maintenance
PMOs within 3 months of initiation.
In
addition, the total
number of these
PWOs older than
12 months
was
reduced 'to 374 at the end of 1992, which was "well below the
licensee's
goal of 580.
Control
room deficiency tags
were reduced
from a low of 44 in the last
SALP period to
12 at the end of this
SALP period.
Out-of-service control
room instruments
were reduced
from a low of 28 in the last
SALP period to 5 at the end of this
SALP period.
In August 1992, licensee
management
established
a
dedicated
Haintenance/Engineering
task team
on
PWO reduction.
During the assessment
period,
the team processed
136
PWOs that were
previously
on hold for Engineering input.
In addition, the team
0
11
issued
nine standard
engineering specifications that allowed the
maintenance
disciplines to perform certain activities without
waiting for direct engineering
support.
The Maintenance
Department
continued to focus
on upgrading the
material condition of the facility.
During this
SALP period,
significant progress
was noted in this area
both prior to and after
The formal weekly management
walkdowns with area
supervisors
continued to be effective.
Followup inspections
were
conducted to ensure that identified deficiencies
were either
promptly corrected
or entered into the plant work control system.
Improvement in the material condition was evident throughout the
plant.
The licensee
formalized
an insulation upgrade
program which
contributed to this improvement.
The Maintenance
Department
also
provided extensive
support to the licensee's
efforts on reducing the
amount of contaminated floor space.
Plant management
increased
emphasis
on reducing plant leaks
by establishing
a leak reduction
task force responsible for maintaining
a data
base of leaking
components
which resulted in a reduced
number of leaks.
This
program received direct management
attention
when it was discussed
at the daily
POD meeting.
equality of maintenance
work had
been
a problem in the last
period
and deficiencies
continued throughout this period.
However,
improvement
has
been noted.
A number of rework issues
were noted
during this assessment
period, including:
intake traveling screen
transmission
installed backwards,
charging
pump failures, electric
fire pump workmanship deficiencies,
pump
B
vendor information deficiency.
In some cases,
Maintenance failed to
adequately prioritize work activities once identified.
Two recent
examples
included the failure to adequately
seal
the Unit 3
generator
housing (allowing water entry during heavy rains),
requiring
a shutdown of the unit and the failure to repair
a
corroded lube oil storage
tank pipe, resulting in subsequent
failure
and leakage of oil into the discharge
canal.
In addition, during
calibration of a refueling water storage
tank level transmitter,
a
maintenance
technician
removed the wrong unit, wrong train level
transmitter
from service.
The Maintenance
Department
implemented
several
actions to improve
the quality of work during this
SALP cycle.
The responsibilities
for the preparation,
review,
and revision of department
procedures
were returned to the Maintenance
Department
(as well as other
departments)
-from -a separate
procedures-group
to provide direct
ownership.
During critical maintenance activities, the Maintenance
Department
provided around-the-clock on-shift management
coverage.
The Department
also
implemented
a self-checking policy during this
cycle to enhance
the quality of work.
The routine preventive maintenance
(PM) program
was maintained
current
(except for approximately
one month immediately following
the hurricane) with an average of less than
10 overdue
PMs per
12
month.
The success
of the
PH program contributed to the previously
noted reduction in the corrective maintenance
PWO backlog.
The
licensee
began
an engineering
review of the
PH program to reverify
the basis for the existing program, delete
unnecessary
PHs,
add
PHs
where warranted,
and establish
the groundwork for implementation of
the
new
NRC Haintenance
Rule.
The first system
under review was the
chemical
and volume control system.
The
PH program continued to be
an asset
by identifying potential
problems prior to failure; for
example,
detecting
increasing vibrations of the
pump.
The
pump motor and rotating assembly
were subsequently
replaced
during
a refueling outage.
Haintenance
Department overtime, training, staffing levels,
and
turnover rates
were adequate
throughout this assessment
period.
Overtime was reduced
from approximately
25X at the beginning of this
SALP period to 18X at the end.
The majority of the supervisors
completed
formal classroom training to help improve supervisory
performance.
Hock-up training (reactor coolant
pump seals,
conoseals,
and moisture separator
reheater
drain line repair)
and
vendor training for newly installed equipment
(HOVATS, Eagle
21,
and
the area radiation monitoring system) significantly improved the
quality and duration of critical maintenance activities
and also
contributed to reduced radiation doses for maintenance
personnel.
Training instructors
were used on-shift during the Unit 3 refueling
outage to both enhance
the technical
expertise
on shift and provide
current plant experience
to the instructors.
Staffing levels for
the four maintenance
disciplines were adequate.
Overall performance
in the surveillance
area
was adequate.
During
the previous
SALP period,
the licensee identified problems with
due to surveillance
scheduling
and tracking.
The licensee
developed
a computerized
surveillance tracking program
for the tracking
and scheduling of all TS-required surveillances
with test intervals of one week or more.
Although this computerized
program was effective in eliminating missed TS-required
surveillances
which were caused
by tracking and scheduling errors,
the number of surveillance-related
problems attributed to other
causes
increased
since the last assessment
period.
During this asses'sment
period,
the licensee
issued
14 Licensee
Event
Reports
(LERs) regarding surveillance-related
problems.
These
problems
were caused
by a series of unrelated
personnel
errors
and
procedural
deficiencies.
Examples of .personnel
errors included
three-missed
ASHE Code. required tests,- two.missed
mode change
required tests,
and the failure of a vendor to test diesel
fuel oil
for sulfur content in accordance
with the method specified in the
TS. 'xamples of procedural
deficiencies
included
an inadequate
analog
channel
operating test of the overpressure
mitigation system;
failure to adequately recirculate the contents of the waste monitor
tank prior to sample acquisition;
inadvertent
automatic start of the
4B emergency diesel
generator;
and inadvertent de-energizing
of the
3A safeguards
bus.
The licensee's
corrective actions for these
13
2.
issues
resulted
in a decrease
in the number of surveillance-related
problems during the later part of this
SALP assessment
period
and
no
have occurred since
September
1992.
During this period, there
was
one violation cited in the area of
Haintenance/Surveillance.
Performance
Ratin
3.
Category:
2
Trend:
Improving
Recommendations
None
D.
Emer enc
Pre aredness
~Anal sis
This functional
area
addresses
activities related to the
implementation of the Emergency
Plan
and procedures,
training of
onsite
and offsite emergency
response
organizations,
licensee
performance
during emergency
exercises
and actual
events,
maintenance
of facilities,
and staffing.
There were four actual
emergency
events:
one Alert (Hurricane Andrew) and three Notices of
Unusual
Events.
Overall, the emergency
preparedness
(EP) program received
strong
management
support,
thereby ensuring
a state of readiness
for
responding to emergencies.
For example,
the licensee
took actions
to improve activation
and staffing of the
Emergency Operations
Facility (EOF)
by assigning
several
members of the plant staff to
fill minimum required positions within the
EOF formerly filled by
corporate office personnel.
In addition, following Hurricane
Andrew, the allocation of resources
for restoration efforts to
ensure
a state of readiness
for the emergency
preparedness
program
was prompt and well organized.
The licensee
continued to maintain adequate
emergency
response
facilities (ERFs)
and equipment,
with appropriate
equipment
surveillance
and functional testing.
ERF communications
were
enhanced
by the utilization of video monitoring capability to
tr ansmit incident status
updates
from the Technical
Support Center
to the
Emergency Operations-Facility- and Operational
Support Center.
The licensee
continued to experience audibility problems with the
plant paging
system during the assessment
period.
Plant paging
problems
have
been identified by the licensee
and the
NRC for
several
years,
including during the
1991
emergency exercise.
Previous corrective actions
have not eliminated the problem.
During
the assessment
period,
the licensee identified additional corrective
actions for the paging problems that will be completed during the
14
next
SALP period.
The licensee's
performance during annual
exercises,
as well as
during an NRC-observed
simulator drill and interviews with response
personnel,
demonstrated
an emergency
response
organization that was
well trained
and prepared
to carry out the
Emergency
Plan
and
implementing procedures.
The licensee
demonstrated
an effective
response
capability during both the calendar year
1991
and
1992
exercises.
During these exercises,
the emergency classification
procedures
were effectively used to promptly and correctly classify
the scenario
accidents.
The response
organization
demonstrated
timely and effective communications with State
and local
authorities.
Accident mitigation information flow was effective
between
the
and, with one exception,
the appropriate protective
action recommendations
(PARs) were
made for onsite personnel
and the
public.
The one exception resulted
in an exercise
weakness
due to
overly conservative
PARs based
on erroneous
data provided to the
by the engineering
accident
assessment
team.
The licensee's
critique was effective in the identification of the
PAR weakness
and
improvement items.
A computerized tracking system
was
implemented
for tracking exercise findings to resolution.
During the assessment
period,
observed
exercise
strengths
included
interface with State
and local officials;
ERF staffing;
emergency
classification; notification; Operational
Support Center operations
(team assembly,
briefings,
and deployment); facility status
boards;
and control
room staff responding
in the simulator.
The licensee
used the simulator during
an annual
exercise for the first time,
and
it performed well.
The exercise
scenarios
were detailed
and
posed
challenges
to the entire emergency organization.
However,
review of
the scenario
by the
NRC disclosed that the initiating conditions for
the graded exercise of 1991 contained similarities to that of the
previous year,
and the
1992 NRC-evaluated
exercise
contained similar
as those of training exercises
conducted
during
April 1992.
The licensee
acknowledged
the exercise similarities and
committed to scenario
reviews to preclude recurrence.
Four emergency declarations
were
made during the
SALP period.
The
most significant event during the period was the Alert declaration
made
on August 24,
1992,
as
a result of Hurricane Andrew.
The
remaining events
were classified
as Notifications Of Unusual
Events
(NOUEs).
In each event, classifications
were correct
and timely.
With the exception of the Alert classification, notifications to
offsite authorities
were made"in accordance
with requirements.
During the hurricane,
the licensee's
communications
systems
became
disabled,
resulting in loss of the capability to notify offsite
authorities'onsequently,
the facility was unable to make the
notifications
as specified in 10 CFR Part 50.
After the hurricane,
the licensee
took prompt corrective actions to restore all
communications
systems.
Corrective actions
included
enhancements
as
well as replacements.
For example,
the previous
phone lines were
replaced with an underground fiber optic cable;
a microwave system
15
2.
was
added
as
a backup;
and two new radio systems
were installed with
replaceable
antennas.
In addition,
prompt actions
were taken to
repair and/or replace all sirens
used for alerting the public.
The
licensee
performed extremely well in hurricane-related
response
activities, including:
storm preparation; facility activations
(including decision-making
regarding relocation of ERFs); protection
of plant personnel
and the identification of potential safety
hazards;
approach to identification and resolution of issues
affecting onsite
and offsite emergency
preparedness;
and the prompt
well-organized restoration efforts (affected
ERFs,
communications,
staffing,
and offsite interface).
During the assessment
period,
one exercise
weakness
and
no cited
violations were identified in the Emergency
Preparedness
area.
Performance
Ratin
3.
Category:
1
Recommendations
None
E. ~Securit
~Anal sis
This functional
area
addresses
security activities associated
with
the plant's safety-related vital equipment
and the Fitness-For-Duty
program.
The site's security force was fully staffed to meet the licensee's
security manning
commitments of the Physical
Security Plan
and
continued to perform security functions very well.
The licensee's
security force was effectively managed,
well supervised,
and
had
very good procedures.
A thorough self-assessment
program concluded
that the Security Section
was well managed
and met the commitments
of the Physical
Security Plan
and procedures.
Security training was well planned
and executed.
The Meapons
gualification Program exceeded
the requirements
of the Security
Training and gualification Plan.
The progressive
security training
program
has contributed to outstanding
personnel
performance
in
daily-operations
and responses
to.contingency drills.. A major.
strength of'he training program was the continued joint tactical
response
training conducted with local law enforcement
agencies.
The most recent joint training culminated in a large-scale
contingency exercise
involving Federal,
State,
and local agencies
including maritime response
units.
Site management's
continued
support
was demonstrated
by funding and beginning construction of a
new firing range
and training facilities to replace facilities
destroyed
by the hurricane.
Additional management
support included
16
the availability of site personnel
and resources
to participate in
the joint contingency exercises
and the priority given to the
replacement
and repair of security
systems
and equipment
damaged
by
the hurricane.
During this assessment
period, the licensee
completed the major
upgrade of the security system that was ongoing during the previous
assessment
period.
The system
upgrade significantly improved
security program effectiveness
through
enhancement
of intrusion
detection
and assessment,
access
controls,
and operational
management
of the security force.
Completion of the security system
upgrade resulted in the, elimination of nine long-term compensatory
posts;
a significant savings in security manpower requirements.
Additional improvements
in the security system during the assessment
period included the addition of a video capture
system to the closed
circuit television
assessment
equipment
which greatly enhanced
the
ability of the alarm station operators
to assess
perimeter fence
alarms.
2.
The operational
capability and survivability of the upgraded
security
system
was severely tested
by Hurricane Andrew.
Although a
major portion of the system withstood the hurricane winds, security
system
components
and facilities sustained
considerable
damage,
necessitating
extensive
use of compensatory
measures.
The licensee
aggressively
responded
to the challenge to promptly restore
the
security
system to full operational
status.
Through the aggressive
rebuilding effort, which was 'strongly supported
by senior
management,
the licensee
restored
the physical security system to
'peration
and reduced
compensatory
measures
to a minimum within 28
days.
The licensee's
Fitness-For-Duty
program continued to be effective in
meeting the objectives of a drug-free workplace
and licensee
commitments relative to access
authorization
and the prevention of
the introduction of contraband
items into the protected
area.
Random testing for drugs
and alcohol
was conducted
in accordance
with procedural
requirements
and the confidentiality of test results
was assured.
Reportable
events
were thoroughly addressed
and
reported in a timely manner.
No violations were cited in the Security area during this assessment
period.
Performance
Ratin
'3.
Category:
1
Recommendations:
None
17
F.
En ineerin
Technical
Su
ort
~Anal sis
This functional area
addresses
activities associated
with the design
of plant modifications
and engineering
and technical
support for
operations,
maintenance,
outages,
and licensed operator training.
In addition to routine inspections,
four special
inspections
were
conducted:
Allegation Team Inspection,
Procurement
Engineering,
Structural
Design Audit, and Hurricane Andrew Recovery.
The licensee's
performance
in providing engineering
and technical
support
was good during this assessment
period, with some
improvements
noted over the previous period.
The engineering
and
technical
support groups generally took a proactive
approach to
resolving difficult engineering
problems.
Emergent
issues for both
operations
and maintenance
were generally aggressively identified
and resolved.
However,
weaknesses
continued
from the previous
period in contractor oversight
and the selection
and specification
of reliable plant equipment.
Weaknesses
were also identified in
other areas
including procedure
review, technical
communication,
and
plant drawings.
Notable actions
completed
by engineering
and technical
support
during the period included elimination of the drawing update
backlog
ahead of schedule,
issuance
of new computer-generated
piping and
instrumentation
drawings that superseded
existing plant operating
drawings,
reduction in the number of temporary
system alterations
(TSAs) from approximately
30 in the last
SALP period to 14,
and
successful
completion of the senior reactor operator certification
training by the engineering
manager
and the technical
support
manager.
Engineering
and technical
support for plant modifications was
generally good.
A documented
design
bases for Turkey Point Units 3
and
4 has
been developed
and the design
bases
documents
were updated
and programmatically controlled.
The quality and technical
content
of the modification packages
were good.
The Project'eview
Board effectively prioritized engineering
work.
High priority design
changes
and emerging technical
support
activities were documented
in the top 20 list for each unit, to be
worked during outages,
and the top 30 list to be worked while the
units were on-line.-
New work-items could only. be added
when
an item
was completed
on one of the above lists.
The result
was more active
engineering
involvement in providing timely day-to-day support to
the plant
and
a very low backlog of items
on hold for engineering
and techni'cal
support
by the end of the period.
For example,
the
backlog of Non-conformance
Reports
(NCRs) decreased
from 300 in 1990
to an average of less than
20 by the end of 1992 and,
as noted
previously, the backlog of TSAs decreased.
18
The licensee's
assessments
of Architect-Engineering
(AE) activities,
Plant Engineering
Group
(PEG) actions,
design reviews, guality
Assurance
(gA) audit support,
and the Technical Alert Program
(an
engineering
communication tool) were effective in identifying areas
for improvement within the design organization.
These efforts
demonstrated
the licensee's
ongoing proactive
approach
toward
enhancing
the quality "of engineering
support.
During this assessment
period, the licensee initiated several
actions to help improve performance
in the engineering
and technical
support area.
These actions included:
developing generic
engineering specifications to support routine repetitive
maintenance/construction
activities (i.e. temporary
lead shielding,
conduit routing, mounting standards,
etc.); involving the system
engineers
and the Probabilistic Risk Analysis
(PRA) Group in the
Maintenance
Department quarterly schedule of activities;
and issuing
a Nuclear Policy that restricted the use of unproven
or one-of-a-
kind designs
and required testing if proven
components
were not
available.
The plant-specific
PRA model for Turkey Point was applied to the
design control
and the preventive maintenance
programs during this
assessment
period.
PRA information was used for the evaluation of
plant modifications to the instrument air system.
Engineering
and technical
support staff provided excellent plant
support for the
damage appraisal,
recovery,
and restart efforts
foll.owing Hurricane Andrew.
The engineering
evaluations for the
fossil Unit
1 chimney demolition, the Unit 2 chimney condition,
and
the required plant change/modification
packages for the fire
protection
system recovery effort were timely and well done.
Other proactive actions in the Engineering/Technical
Support
area
included:
continuation of 100 percent
eddy current testing of all
each
outage,
performance of a post-refueling
startup test program
on Unit 3 after the dual-unit outage
even
though
no refueling or core design
change
had occurred,
and
development of an outage
shutdown risk management
procedure that
controlled equipment to be taken out of service.
Meaknesses
in drawings
and operator training contributed to plant
events during this assessment
period.
For example,
an oil spill of
approximately
100 gallons
on the Unit 4 turbine deck was caused
by
an inadequate
clearance
attributed to the -lack. of plant operating
drawings
and insufficient operator training on the turbine bearing,
control,
and guarded oil systems.
Poor quality drawings contributed
to an inadequate
clearance
and the subsequent
spill of slightly
radioactive water in the auxiliary building.
A drawing error in the
fire protection
system
and discrepancies
in control of temporary
system alterations
and controlled diagrams
were also noted during
this period.
19
Weaknesses
in engineering
oversight of contractors
were noted both
early and late in the
SALP period.
The early event
was associated
with a Westinghouse
Eagle
21 system that replaced
several
Hagan
reactor protection
system
(RPS) racks.
was contracted
to design, install, test,
and provide procedures
and training for
the Eagle
21 modification.
Due to inadequate
communications
and
followup, problems with discrepancies
in tuning constants
used to
process
excore detector signals for overtemperature
delta tempera-
ture
and overpower delta temperature
were identified during low
power physics testing.
Subsequently,
during Incore/Excore nuclear
detector calibration at
50X reactor
power, the range of adjustment
for the scaling factor for the overtemperature
delta temperature
setpoint
exceeded
the acceptance
capability of the Eagle
21
hardware.
Late in the
SALP period,
a licensee
investigation into an
unexpected
increase
in the local peaking factor and
a more positive
power distribution following a Unit 3 post-refueling startup
determined
the cause to be improperly manufactured
wet annular
burnable
absorbers
(WABAs).
The
WABA rod absorber centerlines
were
incorrectly positioned for both units.
There
was evidence of inadequate
procedure
review.
During the Unit
3 startup
from the dual-unit outage,
an operator
observed that
operating
procedures
permitted axial flux deviations outside the
target
band while at
100X reactor
power.
However,
TS did not permit
operation outside the target
band at or above
90X reactor
power.
The operators
realized this and reduced
power to less than
90X after
violating the
TS requirement while following the procedure.
Problems
were observed
in the engineering
selection
and
specification of reliable equipment.
There were problems with new
equipment installed during the dual-unit outage.
The
new emergency
diesel
generator
(EDG) air compressors
required engineering
redesign
to operate properly.
Also, the auto test feature
on the
new
safeguards
sequencer
failed and
a redesign
was required.
engineering
subsequently
completed
adequate
redesigns.
Effective licensed operator training was demonstrated
during this
assessment
period
by performance
on licensing examinations.
In
October
1992, initial examinations
were administered to eight
Reactor Operators
(ROs)
and nine Senior Reactor Operators
(SROs).
In April 1992, initial examinations
were administered
to three
and two SROs.
A 100X pass rate
was attained for both examinations.
Six of seven operator candidates
passed
the Generic
Fundamentals
Examination.
Requalification examinations. were administered
in
.
February
1992, to two,ROs
and eighteen
SROs.
Seventeen
and all
ROs passed
the examinations.
All five crews evaluated
passed
the
requalification simulator examinations.
Five violations were cited in the Engineering/Technical
Support
area
during this assessment
period.
20
2.
Performance
Ratin
3.
Category:
2
Trend:
Improving
Recommendations
None
G. Safet
Assessment
ualit
Verification
~nal sis
This functional
area
addresses
licensee
implementation of safety
policies; license
amendments,
exemptions,
and relief requests;
responses
to Generic Letters, Bulletins,
and Information Notices;
resolution of safety issues;
reviews of plant modifications
made
under
10 CFR 50.59; safety review committee activities;
and use of
feedback
from self-assessment
programs
and activities.
During this assessment
period, the licensee
demonstrated
a proactive
and conservative
approach to nuclear safety in preparing for and
coping with Hurricane Andrew.
Comprehensive
procedures,
early
severe
weather preparations,
and reinforcement training of reactor
operators
at the simulator for various accident
scenarios
as the
storm approached
were examples of good planning.
The licensee's
damage
assessment
and restart efforts following the storm were also
thorough,
demonstrating
technical capabilities
and commitment to
plant safety.
Licensee
corporate
management
maintained direct involvement with
plant status
by monthly status
meetings.
The meetings
were
beneficial in ensuring that issues
were forwarded to the appropriate
level of management
and in ensuring that assignees
of recommended
actions
were held accountable for their responses.
Increased
management
and supervisory
presence
in the field was also evidenced
by the stationing of managers
in the control
room during critical
plant evolutions
and by the development of. an off-hours tour program
for managers.
The licensee's
self-assessment
oversight groups,
including the Plant
Nuclear Safety Committee
(PNSC), the
Company Nuclear Review Board
(CNRB),
and the Independent
Safety Engineering
Group (ISEG),
performed well during this period.
The
PNSC provided
a
comprehensive
overview of plant performance
and effectively ensured
that matters
concerning nuclear safety were brought to the attention
of plant management.
The
CNRB effectively provided
a comprehensive
and independent
overview of plant performance
by experienced
personnel
with varied backgrounds.
CNRB members
attended
PNSC
meetings,
reviewed
NRC and equality Assurance
audit findings,
and
reported
on observations
during site tours.
Special
ISEG reviews
and
CNRB meetings
were conducted to assess
plant readiness
for
restart following Hurricane Andrew.
0
21
During this assessment
period, the licensee's
guality Department
audit program continued to be comprehensive
and effective in
identifying problems.
The guality Department
conducted
performance-
based
evaluations
which contributed to the facility's overall
assessment
efforts.
The group's audits identified several
issues of
non-compliance with NRC regulations
whi'ch were then promptly
corrected.
Examples
included the failure of a subcontractor
to test
diesel
fuel oil for sulphur content in accordance
with the test
method specified in the technical specifications,
the failure to
perform post-maintenance
testing of a component cooling water heat
exchanger drain valve and of the Unit 4 spent fuel pool purification
pump,
and the inadequate
line supervisory capability of the
intrusion detection
system.
In addition, investigations
were
initiated based
on reports of industry events
and resulted
in
findings related to deficiencies
in operator log-keeping.
As a
result,
the Operations
Department instituted
a monthly audit program
and the guality Department
began
random quarterly independent
audits
of log-keeping.
For major problems,
the guality Department
performed
independent
root cause
analyses
using management
oversight risk tree techniques.
The guality Department
also provided on-shift coverage
during major
plant evolutions, utilized outside technical
experts for audits in
the areas of environmental qualification and security to provide
current industry knowledge,
and performed post-Hurricane
Andrew
reviews in support of recovery
and restart activities.
In addition,
there
was
an improvement in the amount of time audit findings
'emained
open awaiting corrective action.
At the end of the
previous
SALP period, there were
no open findings older than
180
days, while at the end of the current
assessment
period, there were
no open audit findings older than
60 days.
This indicated
a
continued
improving trend in timeliness of correcting issues.
Event Review Team reports
and Nuclear Division Performance
Honitoring Hanagement
Information Reports
were reviewed at various
levels of management
for the effectiveness
of self-assessment
activities.
The Event Review Team reports identified several
areas
for improvement in plant procedures
and processes
based
on the root
cause
analysis of problems.
Some of the problems
analyzed
during
this assessment
period by the Event Review Team included the
pump outboard thrust bearing failure, the
3B
tube failures,
an exciter field ground,
an
inadvertent safety injection during a containment isolation rack
surveillance,
and high sodium concentrations 'in the steam
generators.
Nuclear Division Performance
Honitoring Hanagement
Information Reports,
which were distributed to upper management
on
a
monthly basis,
were effective for monitoring plant performance,
defining corrective actions,
and tr acking
and trending nuclear
safety issues.
During this assessment
period, the licensee
took several initiatives
to help improve plant performance.
To strengthen
management
22
operating
knowledge, five managers
completed
a Senior Reactor
Operator certification class
which began in February
1992.
Another
group of managers
was scheduled
to attend this course later in 1993.
The Operations
Manager also attended
a five-week Senior Management
Course.
In addition, the
CNRB Chairman attended
a Senior Reactor
Operator certification class at St. Lucie.
To focus resources
and
efforts, the licensee initiated annual strategic
planning tasks with
assigned
task teams
and periodic progress
reviews during the monthly
status
meetings.
One of the
1992 tasks
involved developing
and
implementing
a new consolidated
reporting system to provide
a single
reporting process
by which conditions of concern to the plant staff
may be identified, evaluated,
analyzed,
and corrected.
This system
reduced
the number of different types of reporting systems
and
provided
a mechanism for all employees
to easily identify problems
to site management
for corrective actions.
Another 1992 task
involved the development
and implementation of a detailed quarterly
work schedule to improve maintenance
efficiency and equipment
reliability (See Section IV.C.).
The licensee's
submittals to the
NRC during the previous
SALP period
included
some which were not of good quality.
During this
assessment
period, the quality of the licensee's
submittals in
support of licensing activities was again mixed.
Many of these
submittals
were comprehensive,
timely, and reflected
a sound
understanding
and appreciation of the technical
issues,
regulatory
requirements
and the
NRC licensing processes.
For example,
three
requests
for temporary waivers of compliance
were comprehensive,
timely,
and well-supported.
During the recovery period following
Hurricane Andrew, the licensee
prepared
and submitted several
excellent
and timely safety evaluations
supporting activities
such
as the interim fire protection system,
demolition of the Unit
1
chimney,
and
an assessment
of the Unit 2 chimney condition.
Licensee
Event Reports
submitted during this period were generally
timely, well-written, and adequately
addressed
root causes
and
corrective actions.
On the other hand, there were
a number of licensing submittals
during the period which were inadequate.
For example,
a request for
a TS change to modify relays in the 480-volt degraded
voltage
protection
scheme
in the engineered
safety features
actuation
system
was deficient in scope
and justification and did not reflect
a sound
understanding
of the technical
issues.
The licensee's
evaluation in
support of a relief request to enable
a non-Code repair of a leaking
main -steam drain pipe did not properly consider the loads
on the
pipe necessary
to demonstrate
structural integrity.
The licensee
requested
and was granted interim approval of certain inservice
inspection testing relief requests,
but failed to follow up promptly
with revised
permanent relief requests.
When submitted,
the
permanent relief requests
were not adequate,
needed
several
iterations,
and required
a last-minute expedited staff review to
support the licensee's
schedule
needs.
23
No violations were cited in the Safety Assessment/Quality
Verification area during this assessment
period.
2.
Performance
Ratin
Category:
1
3.
Recommendations
None
V.
SUPPORTING
DATA
A. Licensee Activities
B.
Units 3 and
4 began this assessment
period in a dual-unit outage for
electrical
upgrades
and both units ended the period at power.
Unit 3 was placed
on line on October
1,
1991.
It remained
on line
for the remainder of the period, with the exception of one manual reactor trip, three
unplanned
shutdowns,
two other occasions
when the
unit was taken off line for maintenance,
and
a combined Hurricane
Andrew/refueling outage late in 1992.
Unit 3 availability for the
period was
74X.
Unit 4 was placed
on line on October 29,
1991.
It remained
on line
for the remainder of the period, with the exception of one automatic reactor trip, five unplanned
shutdowns,
three other occasions
when the
unit was taken off line for maintenance,
and
outage late in 1992.
Unit 4 availability for the period was 83X.
The licensee's
Quality Department
was reorganized
in November
1991 with
Quality Assurance
and Quality Control
becoming
one organization
reporting to a Site Quality Hanager.
Reactor Tri
s
and
Un lanned
Shutdowns Un't Taken Off Line
October 3,
1991:
Unit 3 was manually tripped in response
to a
mechanical failure of a piping nipple in the turbine control oil
system.
The unit was
down for 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br />.
Narch 26,
1992:
- Unit -4 tripped automatically
due to a switch failure
during surveillance testing of containment isolation racks.
The unit
was
down for 39 hours4.513889e-4 days <br />0.0108 hours <br />6.448413e-5 weeks <br />1.48395e-5 months <br />.
Unplanned
Reactor Shutdowns/Unit
Taken Off Line:
December
10,
1991:
Unit 4 was manually shut
down for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
due to
a load sequencer
failure.
The unit remained
down for an additional
165
hours to repair
a conoseal
leak.
Unit 4 was returned
on line on
'
December
18.
January
3,
1992:
Unit 3 was manually shut
down to repair
3B
RCP oil
leakage.
The unit was
down for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
January
28,
1992:
Unit 4 was manually shut
down for repairs to
a
leaking welded joint on
a flow transmitter
on the
4C steam generator.
The unit was
down for three days.
March 25,
1992:
Unit 4 was taken off line to correct
a turbine
generator exciter water intrusion problem.
The unit was off line for
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
April 27,
1992:
Unit 3 was manually shut
down to replace
the
3C
seal.
The unit was
down for 15 days
and was returned
on line on May
12,
1992.
May 7,
1992:
Unit 4 was taken off line due to steam generator
chemistry problems.
The unit was off line for eight hours.
August 23,
1992:
Unit 4 was manually shut
down for Hurricane Andrew.
The unit remained
down for post-hurricane
repairs for 37 days
and was
restarted
on September
29.
August 23,
1992:
Unit 3 was manually shut
down for Hurricane Andrew.
The unit remained
shut
down for post-hurricane
repairs
and
a refueling
outage.
The unit was
down for 102 days
and
was returned
on line on
December
3.
September
29,
1992:
Unit 4 was manually shut
down from Mode
2 in
response
to the identification of two missed
TS surveillances
and
problems with the
B AFW pump overspeed trip.
The unit was
down for
eight hours,
then restarted.
October
1,
1992:
Unit 4 was manually shut
down from 30K power - this
was
a voluntary licensee
action until
FEMA completed
an evaluation
of offsite state
and county emergency
preparedness.
The unit was
down
for 23 days
and
was restarted
on October 24.
December
4,
1992:
Unit 3 was taken off line for turbine overspeed
testing
and to correct
a main generator exciter fan problem.
The unit
was off line for two days.
January
7,"1993:
Unit 4 was taken off line to repack the
4A steam
generator
feed regulating valve.
The unit was off line for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
January
8,
1993:
Unit 3 was taken off line to repair
a steam leak on
a
3B moisture separator
reheater
drain line.
The unit was off line for
32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />.
0'
25
C. Direct Ins ection
and
Review Activities
During the assessment
period,
35 routine
and
seven special
inspections
were performed at Turkey Point by the
NRC staff.
The special
inspections
were:
Allegation Team Inspection of Engineering Actions
Procurement
Engineering
Structural
Design Audit
MOV Program Inspection
Hurricane Andrew Recovery (three inspections)
D. Escalated
Enforcement Actions
l. Orders
None
2. Civil Penalties
None
E. Confirmator
Action Letters
None
F. Licensee
Conferences
During the
SALP period,
17 meetings
were held with the licensee
to
discuss
active licensing issues,
other issues of interest,
and licensee
self-assessments,
accomplishments,
and plans.
The subjects of the more
significant meetings
included:
October
15,
1991
January
9,
1992
April 3,
1992
July 9,
1992
Sept.
10,
1992
Sept.
22,
1992
November 2,
1992
November
16,
1992
Eagle
21 problems during Unit 3 startup
Engineering initiatives
New load sequencers
and instrumentation
setpoints
Proposed
temporary
non-Code repairs to main
steam drain line
Status of restoration of nuclear units
after Hurricane Andrew
Interim fire protection configuration; Unit
2 chimney evaluati'on,
and Unit 4 restart
plan after Hurricane Andrew
Licensee
self-assessment
presentation
Unit 3 restart
plan after Hurricane Andrew
and refueling
26
G.
icensin
Activities
During the assessment
period, the staff completed
51 licensing
activities, while 44 new ones
were opened.
Eight of the closed
items were
amendments
and the remainder
were multi-plant and other
regulatory activities, including
NRC Bulletins and Generic Letters.
H. Review of Licensee
Event
Re orts
For 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
1.
Component Failure
2. Design
3. Construction,
Fabrication,
or Installation
Unit 3 or Common
Unit 4
4. Personnel
Error
a. Operating Activity
b. Maintenance Activity
c. Test/Calibration Activity
d. Other
2
1
10
1
5. 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.
Note 2:
The "Other" category is comprised of LERs where there
was
a
spurious signal,
a totally unknown cause,
or an external
cause
such
as natural
phenomena.
Note 3:
In addition to the above,
one voluntary
LER was submitted,
which was not considered
in this report.
27
I. Enforcement Activit
unctsona
Area
o.
o
so atsons
1n
ac
ever>ty
eve
V
IV
III
II
I
Unit 3/Unit4
ant
peratlons
Radiological
Controls
Maintenance/Surveillance
Emergency
Preparedness
Security
Engineering/Technical
Support
Safety Assessment/equality
Verification
1/1
1/1
0/0
0/0
5/5
0/0
Net total
(each Violation counted
once)
12
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