ML20138Q833
| ML20138Q833 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/31/1985 |
| From: | Weiss E HARMON & WEISS |
| To: | Felton J NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| FOIA-85-729 NUDOCS 8512300025 | |
| Download: ML20138Q833 (4) | |
Text
I HARMON, WEISS & tIORDAN 2001 S STREET.N.W.
SUITE 430 WASHINGTON, D.G. cocoo Gall McGREEVY H ARMON TELEPHONE ELLYN R. WEISS (2O2)328 3500 WILLIAM.S. JORDAN 111 Ol AN E~ CU RRAN DEAN R. TOUSLEY October 31, 1985 Mr. Joseph Felton, Director FREEDOta OF INFORM A f10is Division of Rules and Records ACT RE ? ' S :
T FOIA-PS - 74 Office of Administration U.S. Nuclear Regulatory Commission h // - -b Washington, D.C.
20555 RE:
FREEDOM OF INFORMATION ACT REQUEST
Dear Mr. Felton,
Pursuant to the federal Freedom of Information Act, I hereby request a copy of each of the following:
1.
NRC's recent " system evaluation" of the auxiliary feedwater system at Turkey Point Units 3 and 4.
This evaluation is more fully described in the attached article which appeared in the October 29, 1985 issue of "Inside NRC".
2.
All related documents including but not limited to reports, memoranda, notes, draf ts prepared by NRC staf f and/or contractors in connection with this system evaluation.
3.
All documents prepared by Florida Power and Light and/or its contractors, employees or agents in connection with this system evaluation or in response to the evaluation.
Your response within ten days will be appreciated.
Very truly yours, Ellyn R. Weiss ENC.
ERW/jjh 8512300025 851031 50-450 PDR FOIA WEISS85-729 PDR
.: cyp,.f 1
eeInsideNR.C M
An exclusive report on the U.S. Nuclear Reg ulatory Comruisnion Vol. 7..%. 22 - htober 29. t 985
,') PROTESTS NRC REVIEWS OF INPO-ACCREDITED TRAINING PROGRAMS The Institute of Nuclear Power Operations (INPO)is asking NRC Execunve Director for Opera-tions Wilham Dircks to stop the NRC staff from checkmg on utihty traimng programs after INPO has
- accredited them. INPO President Zack Pate has also wntien the NRC comrmwioners asking their help jn reming in the staff. The statT activities. Pate said, "are impedmg or undermmmg INPO efforts."
The NRC commissioners agreed last year not to pass new training rules for two years so INPO could prove that voluntary utihty efforts to meet INPO accreditation standards produced surenor re-sults. The commissioners said, however, that the stafi would momtor the situation (INRC,1 April,13)
In July, INPO and NRC signed a coordmation plan. Pate wrote: "INPO has cooperated fully with the NRC ir. this area and recogmzes the NRC s ne-d to memtor trammg progress " But some recent NRC actions, he said, "are not in keeping with the... coordination plan."
Pate complained of staff actions in three areas. First, he said, the staff has distributed Nuren/CR-4344, " Instructional Skills Evaluatmn m Nuclear Industry Training " The document duphcates maten-al in two INPO documents but contams some different recommendations, he said, addmg, "NRC issu-ance of documents that duphcate INPO training related documents is specifically precluded by the coordination plan."
Second, without consulting INPO. NRCs Office of Nuclear Reactor Regulation (NRR) an-nounced it will conduct " post-accreditation reviews of (INPO) accredited traimng programs using new-ly developed criteria," Pate wrote. " Superimposing these reviews on the accreditation process and the performance-onented inspections conducted by I&E (NRC Office of Inspection & Enforcement) and C
(Continued on pere 4)
FIRST NRC ' SYSTEM EVALUATION' SLAMS TtlRKEY POINT MAINTENANCE The first of NRCs new system evaluations, on the s.uxiliary feedwater (AFW) system at Flonda Power & Light Co.'s (FP&L) Turkey Point 3 and -4, has resulted in a report harshly cntical of FP&L's mamtenance, trainmg. modificanon design and testmg, and quahty anurance at the plant. Ac-cordmg to the report, a special NRC inspection team assessing the operational readmess of the AIN system found modifications made without analysis of their safety impacts, operators untrained in the system's peculianties, design flaws that could lead to uncontrolled radiation releases in a steam genera-tor tube rupture or total loss of AFW flow control valves, a maintenance backlog that kept control room instruments out of service for months, and a maintenance training program suspended since March 1984 while the traimng department prepared programs to meet Institute of Nuclear Power Op-erations (INPO) accreditation requirements.
The inspection is the first of at least three system evaluations that the NRC staff plans to perfwm while developing new performance-based regulatory enteria. The other pLnts have not been named.
The shift is occurring as the NRC staff takes a tougher regulatory kne after a series of plant mishaps blamed on poor plant management (INRC,14 Oct.,1). Ilesides forcing management attention to what NRC perceives as lingering maintenance problems at Turkey Point (INRC,30 Sept.,1), the staff will be using the mspection findings to develop new methods to get substantial changes at poorly managed plants.
For the inspection, NRC called in design and engineering experts from NRC headquarters and Region Il and NRC contractors. They started with the AIM system as desenhed in the operating li-cense and then traced modifications, hmking for design control, maintenance and surveillance quality, operating procedures, and adequacy of testing. especially after modifications or maintenance. In his let-N INSIDE THIS ISSUE Commisioners retect CPA L EQ deedhne charige
- p5 NRC staff urges tougher safety goal pien
-pll Rancho Seco testart timing in doubt
-p5 ACRS membas miscire Indian Pning tuhng
- PI 3 hatts Bar welding assues resurfacing
- p6 Comanche Peak pains enempemn chauenged
-pl 3 AntWrug pobey snagged on enforcement
-p7 Assetstane enseits on applying backist rule
-pl$
6tesesseh reorients to and plant operstens
-p9 Fiscal yest 191l5 fines charted
-pl5 20
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r ter accompanying the inspection report, James Taylor, director, of the Othee of Inspection & Enforce-ment (IE), said 10 fmdings could result in enforcement action.
FP&L has not yet responded formally to the report,'according to spokeswoman Stacy Shaw, but the utility has protested several findings, in the exit interview and in a subsequent letter (INRC,14 Oct.,19). Taylor noted that management began a " performance enhancement program" after receismg low ratings on the last SALP (systematic assessment of licensee performance) report, but said, "The in-spection team noted that performance in the functional areas of mamtenance, sur eillance tesung, and design changes and modifications has not markedly improved." Taylor said he understood the utihty "took prompt action...to address the team's safety concerns," adding NRC will follow up Specific finCags from the report included:
-The safety grade backup air system for the non-safety grade m>trument air system, sital to keeping AFW flow control valves (and the system) operating, had never been functionally tested though it had been "substantially modified." A test showed operators had only six to sesen mmutes, in-stead of 15 to 20 mmutes, to valve in new mirogen bottles to the backup system in the worst case. Re-sponse would have been hampered by an mcorrect annunciator response procedure, and the annuncia-tor alarm set. point was halved without a safety evaluation. "The team cencluded that the weaknev.es identified...could have all contributed to a significant nsk of a loss of AFW flow."
-The AFW system is shared by Turkey Point-3 and -4, and its design basis requires that one pump be able to remove decay heat from both umts. Ilowever, operators must assure the correct divi-sion of flow between the units. Operators were not trained in the situation and thei procedures did not -
cover it.
-The AFW turbine steam supply isolation valves could not be shut from the control room if an AFW actuation signal was present. Operators had no training to recognize the signal's override of con-trol room switches. "The team concluded that the lack of operator awareness that the steam fLwpaths m question couki not be isolated remotely from the control room could have resuhed in an unnecessary and potentially significant radioactive release to the environment following a steam generator tube rup-t u re."
- Programmatic weaknessess" were found in maintenance, includmg "the consistent failure to evaluate the root cause of equipment malfunctions and to trend these failures to provide input to the preventive maintenance program," though key parts of the AFW system had expenenced recurrent
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component failures
- Formal classroom training sessions for rnaintenance technicians had been discontmued m Au-gust 1984. Licensee management stated that mamtenance training had been disconimued to dedicat-trainmg resources to developing training materials required to support INPO accreditation of the main-tenance training program....A very hmited amount of on the job training and vendor supphed traimng had been conducted smce the decision to discontinue clawoom training."
- Over half of the I&C (instrument & control) technicians that conduct surveillance tests (15 of 27 at the time of the inspection) had an average ofless than 6.5 months of experien : at Turkey Point.
The electncal and mechanical maintenance groups have also recently experienced high turnover rates among their technicians."
- Management controls did not exist to ensure that safety related maintenance activities were performed by qualified personnel.... Maintenance procedures generally lacked detail. Complex safety re.
lated miintenance activities were often caidered to be within the scope of the ' skill of the trade' and therefore not requiring procedures.... Post-maintenance testing requirements were typically not included as part of electrical and I&C plant work orders (PWOs)."
-The apparent result was "a large backlog of safety related PWOs throughout both units."
Steam jet air ejector process radiation monitors had been out of service about six months, the unit 4 containment sump high level annunciator had been out since December 1984 and two of four post.acci-dent sump level monitors out since February, and several area radiation monitors on both umts were out of service for greater than six months. Iloth units had leaking power operated relief valves (porvs) and unit 4's bhick valves also leaked, resulting in elevated temperatures in the common discharge pipe downstream of the pressunter safety relief valves. As a result of the last, all three unit 4 control niom annunciators continuously showed alarms, impairing operators' abihty to recognite rehef valve failures
- Dunng a system walkdown, the drain lmes on the turbine casings and the exhaust silencen were noted to be hot Water was flowing from the drains on the A and C turbines. The steam supply isolation valves for the A and C turbines were leakmg and allowilig steam to reach the turbmes even though the valves were closed....He associated steam supply valves on umt 4 also appeared to be lea-king....Re Il turbine did not appear to have any leakage from its steam supply valves....No current 2
instDf. N.R.C. - Octotwe 2N,195$
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9 y.
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. PWOs were noted on the leaking steam supply valves."
' -Seismic qualification "was not being properly maintained," with control air lines not properly anchored and a temporary scaffolding erected 'above all four instrument racks for both units' A flow transmitters so that a collapse could have failed all AFW.
- Programmatic weaknesses" were found in the design change process. "The engineering g often did not provide post. modification testing requirements.. Modifications were installed witho
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0 detailed design analysis.... Design bases for safety related systems were difficult to retrieve." Th found the unlity " frequently hase(d) design changes on engineering judgment that the new desi bounded by the origmal design analysis. Documentation justifying the engineenng judgment did not exist."
-At least partially as a result, "Four of six AFW steam supply isolation valve motor operators were changed from AC to DC motors without adequate design analysis. Motor overload protec the new DC motors was not properly sized. Further, the new power cables were not properly sized to
. ensure adequate operating voltage forihe motor operators in the event of a loss of off-site power.
licensee had not' performed any cable sizmg calculations to support this design change."
-Potentials for common mode fa lures were introduced by design changes. Common relays and hmit switches were put into redundant Train A and 11 flow control circuits and design of mirogen backup systems could fait redundant control room annunciator circuits.
-Safety related station batteries were modified but no calculations were done to show the new ones could meet the design basis and plant procedures and technical specifications were not chang recognize the new batteries
- different requirements.
- Excessive reliance was placed on operator action instead of design features to ensure the prep-er functioning of the AFW system."
- A review of the corporate and site quahty assurance (QA) auditing activities revealed that these audits, as implemented, neither had identified nor were capable of identifying qual ty concer a technical and operational nature" like those NRC found. "Both the corporate vendor audit and the plant audit programs were designed to assure that QA programs met NRC requirements and li commitments from a programmatic basis only....(which) meant that FP&L management was not re-ceiving important feedback on the quality of activities affecting the safe operation of the plant."
Several industry sources said ITAL was objecting to some of the report's conclusions and pressing
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to have them changed. They said industry groups are concerned about the apparent new mihtancy in the NRC staff and will try to get the NRC commissioners or fnendly members of Congress to inter-vene.
In developing performance indicators, NRC is also conducting special maintenance program re-views at seven plants. William Russell of the Office of Nuclear Reactor Regulation said NRC is ahead in developing performance indicators in the maintenance area since staffers have already been visiting plants to determine where industry initiatives are working and where NRC action is needed (INRC,1 Aug.,1). Turkey Point is also on that list, with a review scheduled for later this year, along with Caro-Ima Power & Light Co.'s I runswick and Arkansas Power & Light Co.*s Arkansas Nuclear One. Pro-gram reviews have already been done at Northeast Utilities' Millstone. Toledo Edison Co.'s Davis-Besse, Sacramento Municipal Utility District's Rancho Seco, and Wisconsin Public Service Corp.'s Kewaunee.
Region II Administrator Nelson Grace noted INPO and the Nuclear Utility Management & Ilu-man Resources Committee (Numarc) want NRC to stay out of management areas and said he agreed NRC should not be managing plants. But, he said,"We can and must touch on those areas, to the ex-tent that all of out (inspection)(mdings must be laid at the doorstep of top management..The buck stop; there."-Margaret L Ryan and Eric Lindeman. Washington MERITS OF USER FEE SCHEME TO BE RESOLVED BY HOUSE SENATE CONFERENCE The merits of a propmed seneme by which NRC would be required to collect user fees to offset 50% ofits authorized budget will t e battled out by llouse and Senate conferees when a budget confer.
ence begins meeting this week. The flouse was expected to approve by the end of last week its version of the budget reconciliation bill, which includes the user fee scheme. Since the proposal is not included in the Senate versian of the bill,it will first he considered by that body in conference.
The conference is expected to continue for at least a week, so it is uncertain when the user fee
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provision will be considered. In the meantime, industry lobbyists are working to kdl the provision, questioning the basis for setting budget recovery at 50%. l'ighting in the industry's corner is Rep. Dan Rostenkowski(D.llt.), chairman of the House Ways & Means Committee, who argued before the
. Rules Committee that the user fee is really a las and so must he considered by hn committee first. The 3
INSIDE N.IL.C, - October 28,1985
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