ML17352A801
| ML17352A801 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 09/23/1994 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Goldberg J FLORIDA POWER & LIGHT CO. |
| Shared Package | |
| ML17352A802 | List: |
| References | |
| NUDOCS 9410120057 | |
| Download: ML17352A801 (10) | |
See also: IR 05000250/1994099
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W., SUITE 2900
ATLANTA,GEORGIA 303234199
September
23,
1994
Florida Power
and Light Company
ATTN:
Hr. J.
H. Goldberg
President
- Nuclear Division
P.
O.
Box 14000
Juno
Beach,
FL
33408-0420
SUBJECT:
SYSTEMATIC ASSESSMENT
OF LICENSEE
PERFORMANCE
(SALP)
(NRC
INSPECTION
REPORT
NO. 50-250/94-99
AND 50-251/94-99)
Gentlemen:
The
NRC Systematic
Assessment
of Licensee
Performance
(SALP) has
been
completed for your Turkey Point nuclear plant.
The facility was evaluated for
the period of January
31,
1993,
through August 27,
1994.
The results of the
evaluation
are documented
in the enclosed
SALP report.
This report will be
discussed
with you at
a public meeting to be held at the Turkey Point site
on
October
6,
1994, at 3:00 p.m.
This
SALP. evaluation
was conducted
under the revised
SALP process
implemented
by the Nuclear Regulatory
Commission
on July 19,
1993.
The revised
process
assesses
four functional areas:
Plant Operations,
Maintenance,
Engineering,
and Plant Support.
The overall level of safety performance
at Turkey Point has significantly
improved, attaining superior ratings in all
SALP functional areas.
This high
level of performance
resulted
from a dedication to excellence
and teamwork of
all those associated
with the operation of the facility.
Of particular note
is that senior managers
set high standards
of safety performance,
were
involved in site activities,
and made conservative
decisions relative to
operation of the facility.
In addition, your self-assessment,
quality
verification,
and associated
corrective actions
were effective in assuring
that the high standards
were attained.
We commend you and your staff for this superior level of performance.
In accordance
with Section 2.790 of the NRC's "Rules of Practice,"
a copy of
this letter
and its enclosure will be placed in the
NRC Public Document
Room.
FPLL
2
Should you have
any questions
or comments,
I would be pleased
to discuss
them
with you.
Sincerely,
Docket Nos.
50-250,
50-251
License
Nos.
Enclosure:
SALP Report
cc w/encl:
H.
N. Paduano,
Manager
Licensing
5, Special
Programs
Florida Power
and Light Company
P. 0.
Box 14000
Juno
Beach,
FL
33408-0420
L.
W. Pearce
Plant General
Manager
Turkey Point Nuclear Plant
P. 0.
Box 029100
Miami, FL
33102
T. F. Plunkett
Site Vice President
Turkey Point Nuclear Plant
P. 0.
Box 029100
Miami, FL
33102
T. V. Abbatiello
Site guality Manager
Turkey Point Nuclear Plant
P. 0.
Box 029100
Miami, FL
33102
E. J.
Weinkam
Licensing Manager
Turkey Point Nuclear Plant
P. 0.
Box 4332
Miami, FL
33032-4332
cc w/encl:
Continued
see
page
3
Stewart
D. Ebneter
Regional Administrator
FPEL
cc w/encl:
Continued
Harold F, Reis,
Esq.
Newman
and Holtzinger,
P.C.
1615
L Street,
NW
D.
C.
20036
John T. Butler,
Esq.
Steel,
Hector
and Davis
4000 Southeast
Financial
Center
Miami,
FL
33131-2398
Bill Passetti
Office of Radiation Control
Department of Health
and
Rehabilitative Services
1317 Winewood Boulevard
Tallahassee,
FL
32399-0700
Attorney General
Department of Legal Affairs
The Capitol
Tallahassee,
FL
32304
Jack Shreve
Public Counsel
Office of the Public Counsel
c/o The Florida Legislature
ill West Madison Avenue,
Room 812
Tallahassee,
FL
32399-1400
Joaquin
Avino
County Manager of Metropolitan
Dade County
111
NW 1st Street,
29th Floor
Miami,
FL
33128
Joe Myers, Director
Division of Emergency
Preparedness
Department of Community Affairs
2740 Centerview Drive
Tallahassee,
FL
32399-2100
700 Galleria Parkway
Atlanta,
GA
30339-5957
SALP REPORT - TURKEY POINT NUCLEAR PLANT
50-250/94-99
AND 50-251/94-99
I.
BACKGROUND
The
SALP Board convened
on September
8,
1994, to assess
the nuclear
safety performance of Turkey Point Units
3 and
4 for the period
January
31,
1993,
through August 27,
1994.
The Board was conducted
per
Nanagement Directive 8.6,
"Systematic
Assessment
of Licensee
Performance."
Board members
were Bruce A. Boger (Board Chairperson),
Acting Director, Division of Reactor Projects; Albert F. Gibson,
Director, Division of Reactor Safety; J. Philip Stohr, Director,
Division of Radiation Safety
and Safeguards;
and Herbert
N. Berkow,
.
Director, Project Directorate II-3,
NRC Office of Nuclear Reactor
Regulation.
This assessment
was reviewed
and approved
by Stewart
D.
Ebneter,
Regional Administrator,
NRC Region II.
II.
PLANT OPERATIONS
This functional
area
addresses
the control
and execution of activities
directly related to operating the plant.
It includes activities such
as
plant startup,
power operation,
plant shutdown,
and response
to
It also includes initial and requalification training
programs for licensed operators.
Overall performance
in the Plant Operations
area
remained superior
during this assessment
period.
Operator
performance
was excellent.
Operator training programs
were strong,
as evidenced
by exam results
and
performance during unit startups,
shutdowns,
and events.
Operations
was
well supported
by management,
maintenance,
engineering,
and plant
support organizations.
Teamwork
among these
groups
was effective,
as
indicated
by strong outage
performance,
testing
and maintenance
activities,
and special
and infrequent tests
or evolutions
where multi-
disciplined groups
were effectively integrated.
Operators
responded
in
a timely and effective manner during abnormal
conditions
and unit
such
tube leaks, turbine generator
problems,
and moisture separator
drain line steam leaks.
Operators
were
also alert
and proactive in addressing
abnormal
equipment indications
and associated
problems including reactor coolant
pump seal
problems,
a
pressurizer
manway leak,
and main generator
voltage fluctuations.
In
addition, operators
performed very well during planned
and short-notice
outages.
Management
oversight
and conservatism
were exemplary
and assured
safe
unit operation.
Conservative
operating decisions
were
made to remove
a
unit from service to repair degraded
equipment well before potential
failures or approaching
applicable technical specification limits.
Examples included cold shutdowns to repair
a leaking pressurizer
manway
and
a leaking pressurizer
spray valve.
Effective management
oversight
and conservatism
were evidenced
by the thorough unit restart
readiness
verification .process
used in returning each unit to service following
refueling outages.
Independent
reviews
by quality assurance
and the safety review
committees
were effective
and demonstrated
a strong safety attitude
and
perspective.
For example, quality assurance
performed
a review of
operational
problems
and effectively identified root causes
and
corrective actions.
The onsite
and offsite safety review committees
conducted
comprehensive
self-assessments,
especially during reviews of
equipment degradation
and prior to unit startups
from refueling.
Root cause
and corrective action
programs
were effective.
Event review
teams
were assembled
to perform collective, multi-disciplined, real-time
problem reviews.
These
teams
were successful
in identifying causes
and
proposing corrective actions.
Examples
included moisture separator
drain line steam leaks,
emergency
core cooling system
minimum flow problems,
and emergency
containment cooler valve failures.
The licensee's
commitment to risk management
was evident.
Troubleshooting activities which could place the units at risk were
controlled by the "red sheet"
process.
This assured
that
a well
thought-out,
detailed,
precise
plan
was in place prior to commencing
work and that
management
had reviewed
and concurred
in the process.
Infrequently performed tests
and evolutions were also controlled
by a
special
administrative
procedure with requirements
for a pre-evolution
briefing and oversight
by an appointed test director
and manager.
Management
conservatism
and commitment to reduce
shutdown risk were
noted
by the practice of completely offloading the reactor core prior to
beginning mid-loop operations.
During a refueling outage,
a risk
assessment
team
was initiated to review critical path evolutions, safety
system availability,
and risk.
This team
made recommendations
to change
the outage
sequence
in order to minimize overall risk.
Operators generally displayed strong attention to detail with good
supervisory oversight.
However, late in 1993,
several
instances
of poor
control
room oversight resulted
in a reactor trip,
an overdilution
-event,
and other noted errors.
These
issues
were partially caused
by
poor communications
and
a lack of self-checking.
Management
aggressively
addressed
these
instances
by emphasizing
expectations
that
all personnel
meet
a high standard of performance
and accountability,
relocating the Assistant Nuclear Plant Supervisors
into the controls
area,
and improving oversight of non-licensed
operators.
These actions
were effective,
as evidenced
by strong personnel
and unit performance
during the last six months of the assessment
period.
The Plant Operations
area is rated Category
1.
NINTENNGE
This functional area
assesses
activities associated
with diagnostic,
predictive, preventive,
and corrective maintenance
of plant structures,
systems,
and components.
It also includes all surveillance testing
and
other tests
associated
with equipment
and system operability.
Overall
performance
in this area
was superior during this period.
Overall maintenance
program management
was
a strength during this
period,
as exemplified by effective processes
and well-qualified staff.
Management
actions
were effective in eliminating past SALP-identified
weaknesses
involving the quality of work and surveillances.
Management
involvement
and conservative
management
decisions
were evident.
The licensee
has
addressed
identified weaknesses
in maintenance
work
quality through individual counselling,
procedural
enhancements,
and
process
improvements.
Peer verification and self-checking
programs
were
also initiated to reduce the personnel
error rate.
These
management
actions
have
been effective in improving performance
in this area.
Performance
in the surveillance
area
improved during this period in that
personnel
and procedural
weaknesses
were effectively addressed.
Notwithstanding the improved performance,
there
were still some
surveillance-related
problems;
the most significant of which was caused
by
a lack of adequate
program oversight
and attention to detail.
This
resulted
in
a number of missed valve surveillance tests.
However, the
licensee identified the problem near the
end of the
SALP period
and took
effective followup actions.
Effective maintenance
wor k backlog management
resulted
in continued
reductions
in both the size
and
age of the backlog during this period.
Specifically, the non-outage corrective maintenance
plant work order
(PMO) backlog,
PMOs greater
than
12 months old, control
room deficiency
tags,
and out-of-service control
room instruments
continued to decrease
as they have during the previous
two SALP periods.
In addition,
performance
has
been better than the licensee's
established
goals.
These
are strong indicat'ions of effective backlog management.
Excellent coordination
and cooperation
both within the maintenance
organization
and with other groups
was
a significant strength.
This was
a major contributor both to the maintenance
and operations
performance.
This was illustrated by the repair of a leak on the Unit 4 spare control
rod drive mechanism
canopy seal,
repair of a failed component cooling
water system outlet isolation valve associated
with the
3C
emergency'ontainment
cooler,
and troubleshooting of a July 1993 relay failure
while performing containment isolation periodic tests.
These efforts
were characterized
by excellent planning, interdisciplinary teamwork,
management
oversight,
high quality work,
and timely completions.
Two
exceptions to this good performance
were
pressurization
prior to completion of seal table leak repails
as
a
result of poor work control
and communications
weaknesses
and
a safety-
related cable pull performed without calculating the pull stress
during
3B charging
pump work.
These
lapses
were isolated occurrences;
and, in
both cases,
aggressive
and effective followup and corrective actions
were taken.
Maintenance
made significant contributions to excellent
equipment
reliability and plant availability.
No instrumentation
and control
(I&C)-related trips occurred during the period.
Maintenance
has
been
completed in
a time1y manner with good quality, contributing to safe
and
efficient refueling outages
and minimizing plant transients.
Some
examples
of superior maintenance
performance
include the efforts
related to auxiliary feedwater,
intake cooling water, startup
transformer,
and main feedwater
pump check valve maintenance
during
September
- October
1993; preventative
and corrective maintenance
as
well
as troubleshooting
on the reactor protection
system
(RPS),
emergency diesel
generator
(EDG),
and safety injection (SI) motor in
late
1993; corrective maintenance
on valve packing,
RPS relays,
motor,
and spent fuel pool
components
in early 1994; motor-operated
valve,
EDG, reactor vessel,
erosion/corrosion,
and fuel up-ender
work in
April 1994;
and
I&C troubleshooting of rod position indication problems
in October of 1993.
Exceptions to this excellent
performance
included
a Unit 4 shutdown to
repair
a corrosion-induced
thimble tube leak on the incore instrument
system that was most likely caused
by improper cleaning of the seal
table area during
a previous outage.
Also,
a lack of attention to
detail
and inadequate
procedures
led to high reactor cavity seal
leakage
due to missing studs
on nuclear instrumentation
covers during the
1993
Unit 4 refueling outage.
Many power reductions
and
some unit shutdowns
have
been necessary
during
this period
as
a result of balance-of-plant
(BOP) problems.
The root
causes
of the individual events
were assessed;
however, collective
causes
of and corrective actions for possible
challenges
to operators
and safety systems resulting from BOP equipment failures or degradation
are of concern.
Potential
inadequacies
relative to equipment
aging,
maintenance,
and design
should continue to be addressed.
The Maintenance
area is rated Category l.
ENGINEERING
This functional
area includes activities associated
with the design of
plant modifications
and engineering
support for operations,
maintenance,
and outage activities.
Performance
in this area continued to improve
and was
an important contribution to good performance
in other
functional areas.
Management
oversight
and control were effective in
improving performance.
Good teamwork was apparent
between
engineering
and other site
organizations.
For example,
engineering
design priorities were set
by a
Plant Review Board which included the Site Vice President
and the
Managers of Operations,
Maintenance,
and Engineering.
This process
assured
that the resultant plant modifications met the needs of user
organizations.
Engineers
from design,
technical
support,
and
construction organizations
worked together effectively to assure
proper
design, installation,
and testing of each modification.
Design
modification packages
were critiqued before
and after implementation.
Management of the backlog of engineering
work was effective.
The
backlogs of Requests
for Engineering Assistance,
Plant
Change
Modifications,
and Nonconformance
Reports
were reduced
in size,
appropriately prioritized,
and closely monitored
by station
management.
A long-term program to eliminate
a large backlog of drawing updates
was
successfully
completed early in the period.
System walkdowns
and
additional
updates
have continued to improve the quality of drawings.
Strong design
and system engineering
programs
provided
good support to
operations
and maintenance.
System engineers
were well qualified and
exercised full responsibility for the, condition of their assigned
systems.
Plant performance
was improved by implementing the
recommendations
of reliability improvement
teams.
Continued reductions
in temporary
system alterations,
lighted annunciators
in the control
room,
and other operator
"work arounds"
reduced
the potential for
operator errors.
Weaknesses
in contractor oversight that wer e evident during the previous
SALP period were corrected
during this assessment
period.
A task force
was established
and corrective actions
implemented to strengthen
vendor
interfaces.
The licensee
continued to-reduce
dependence
on contractors
for engineering
services.
Engineering
performance
was improved by strong self-assessment
efforts
which identified areas for improvement.
Effective corrective actions
were taken to address
the self-assessment
findings.
Weaknesses
in
engineering
performance identified in the previous
SALP period were
corrected,
and performance
measures
were established
and monitored to
assure that challenging goals
were met.
The Engineering
area is rated Category l.
PLANT SUPPORT
The Plant Support functional area
addresses
all activities related to
radiological controls,
emergency
preparedness,
security, plant
chemistry, fire protection,
and plant housekeeping.
Performance
in the radiological controls area continued at
a high level.
The as low as reasonably
achievable
(ALARA) program was effective in
reducing doses,
both during outages
and routine operations.
Effective
ALARA activities during this period included the use of mockup training,
source
term reduction efforts associated
with plant chemistry,
and the
installation of non-Stellite parts
and equipment.
Also, person-rem
managers
were assigned
by individual departments
to enhance
efforts.
As a result,
the
1993 personnel
exposures
were the lowest
since the beginning of plant operation.
The 1994 Unit 3 refueling
outage collective dose
was controlled to well within the dose goal for
the outage work.
Contamination control programs facilitated maintaining
internal
exposures
well below regulatory limits by effectively
maintaining
a relatively low contaminated floor area.
A well run
respiratory protection
program also contributed.
Respirator
usage
was
reduced
as part of the effort to reduce total effective exposure,
without an appreciable
increase
in internal
exposures.
During the
period,
there
were
some isolated
cases
of failure to follow radiation
work procedures
associated
with personnel
dosimetry
and radioactive
material control requirements
for which corrective actions
were promptly
implemented.
An aggressive
waste
management
program was
implemented
which resulted in minimizing the generation
and storage of dry
radioactive wastes.
Radiological effluents were well managed;
and
releases
were only a small fraction of the regulatory limits, as
verified by the environmental
monitoring program.
A weakness
was
identified in the program for measuring certain beta emitting
radionuclides
in liquids.
The weakness
included unexplained
biases
in
some measurements
and inadequate
procedures
and training for staff, but
this was not significant regarding environmental
doses.
Improvements
were
made to the meteorological
monitoring equipment with the addition
of supplemental
power supplies
and the upgrading of the electrical
switching equipment.
Radiological control
program audits
were well
planned.
thorough,
and well documented
and followup actions
were timely
with items tracked to completion.
Performance
in the emergency
preparedness
area continued to be strong.
With good management
support,
the emergency
preparedness
training
program maintained excellent
response
proficiency.
This was reflected
in excellent
performance
during the full participation exercise
during
this period in which the emergency facilities were activated
and staffed
properly,
events
were properly classified,
and notifications were timely
and proper with appropriate protective action recommendations.
Also,
the response
to an actual
event during this period was appropriate
and
in accordance
with the
Emergency
Plan.
Emergency facilities and
equipment
were maintained in an excellent
manner.
Communications
enhancements
included the installation of a high frequency radio system
and
an upgrading of the containment public address
system.
The
emergency
preparedness
audit program,
including the exercise critique
process,
was considered
a strength.
Corrective actions
were
sound
and
timely.
Interactions with offsite agencies
were effective,
and good
working relations
were maintained with State
and local agencies.
Performance
in the physical security area continued at
a superior level.
Security training was effective, trainers
were knowledgeable,
and
an
extensive array of training materials
and equipment
was available.
Hanagement
support for this area
was evidenced
by the new firing range
and training building.
The Security,
Contingency, Training,
and
gualification Plans
and implementing procedures
were maintained current.
Access controls were well maintained,
and the new hand geometry
access
control program was effectively implemented.
The number of loggable
security incidents trended
downward during the period
and was
reflective, in part, of good testing
and maintenance
support for the
security equipment.
Alarm assessment
aids were enhanced with the
installation of an improved model of video capture
equipment,
reducing
the number of false
and nuisance
alarms.
Security audits were thorough
and detailed.
The fitness-for-duty
(FFD) program was
a strength.
The
FFD staff was well trained
and qualified, collection facility operations
were well run, procedures
were good, conservative
screening
levels were
set,
and program audits
were effective.
The fire protection program performance
was generally good.
During the
period, the fire brigade
responded
to four actual fires with the
response
being timely and effective in extinguishing the fires.
One of
the fires was outside of the protected
area at the HcGregor substation,
and this led to interaction with offsite support.
During the earlier
portion of the period there were
some instances
of lack of attention to
detail associated
with failure to establish fire watches,
an inadequate
fire plan,
and
a failure to control combustible material.
However,
these
weaknesses
were not observed later in the period.
Overall, housekeeping
was good, with a noted
improvement in the latter
portion of the period.
The Plant Support
area is rated Category l.