ML20141N312

Further Response to FOIA Request for NRC Insp Rept & Records Re Evaluation of Auxiliary Feedwater Sys.Documents on App G Withheld (Ref FOIA Exemption 5)

ML20141N312
Person / Time
Site:	Turkey Point
Issue date:	01/09/1986
From:	Grimsley D NRC OFFICE OF ADMINISTRATION (ADM)
To:	Weiss E HARMON & WEISS
References
FOIA-85-729 NUDOCS 8603060133
Download: ML20141N312 (2)

Text

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pa at;e jog UNITED STATES

- o NUCLEAR REGULATORY COMMISSION O < wAsHWGTON, D. C. 20555 s ....../

JAM 0s !$15 Ellyn R. Weiss, Esquire Hannon, Weiss & Jordan 2001 S Street, NW, Suite 430 IN RESPONSE REFER e Washington, DC 20009 TO F01A-85-729

Dear Ms. Weiss:

This is in further response to your letter dated Octo er 31, 1985, in which you requested, pursuant to the Freedom of Information Act (F0IA), copies of the NRC inspection report and related records regarding the evaluation of the auxiliary feedwater system at Turkey Point Units 3 and 4.

The 4 documents listed on the enclosed Appendix G contain predecisional advice, opinions, and recommendations of the staff regarding an ongoing evaluation and are being withheld from public disclosure pursuant to Exemption (5) of the F0IA (5 U.S.C. 552(b)(5)) and 10 CFR 9.5(a)(5)'of the Commission's regulations. Disclosure of the information would inhibit the candid and frank exchange of communications in future deliberations and thus would not be in the public interest. There are no reasonably segregable factual portions, and the documents are being withheld in their entirety.

Pursuant to 10 CFR 9.9 of the Commission's regulations, it has been determined that the information withheld is exempt from production or disclosure, and that its production or disclosure is contrary to the public interest. The persons responsible for this denial are the undersigned and Mr. James M.

Taylor, Director, Office of Inspection and Enforcement.

This denial may be appealed to the Commission's M cutive Director for Operations within 30 days from the receipt of this letter. As provided in 10 CFR 9.11, any such appeal must be in writing, addressed to the Executive Director for Operations, U.S. Nuclear Regulatory Commission, Washington, DC 20555, and should clearly state on the envelope and in the letter that it is an " Appeal from an Initial F0IA Decision."

The NRC has not completed its search for and review of documents subject to your request. We will respond as soon as those actions are completed.

Sincerely, 8603060133 860109 PDR

%l " # k t..dd<f FOIA /

WEISS85-729 PDR Donnie H. Grimsley, Director Division of Rules and Records l Office of Administration

Enclosure:

As stated l

l

Re: FOIA-85-729 APPENDIX G b

1. Undated Turkey Point Inspection Findings. (6 pages)

2. Undated Summary of the Florida Power and Light Meeting of 10/23/85 in the Region II Office. (9 pages)

3. Undated Notes to Support E00 Discussion with Mr. Hudiburg of Florida Power and Light. (10 pages)

4. Undated Draft Order with annotations. (6 pages)

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u HARMON, WEISS Oc t.IORDAN 2001 S STREET N.W.

SulTE 430 WASIIINGTON, D.G. cocoo GAIL McGREEVY H ARMON TELEPHONE ELLYN R. WEISS (202)328 3500 WILLIAM S JORDAN, lli DIANE CURRAN DEAN R. TOUSLEY October 31, 1985 Mr. Joseph Felton, Director FRELOOW OF INFORM A HON Division of Rules and Records ACT PE? EE!

Office of Administration fQ1Q-g3. [y U.S. Nuclear Regulatory Commission Washington, D.C. 20555 h //~h-N 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 'e 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, d raf 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.

3 Your response within ten days will be appreciated. ,

Very truly yours, N '

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Ellyn R. Weiss i

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, Inside N R.C An emolusive report on the U.S. Nuclear Reg ulatory Cornrnission iM Vol. 7. .%. 22 - Rtober 29.19M i

') PROTESTS NRC REVIEWS OF INPO-ACCREDITED TRAINING PROGRAMS The Institute of Nuclear Power Operations (INPO) is asking NRC Executive Director for Opera-tions William Dircks to stop the NRC staff from checking on utihty trainmg programs after INPO has accredited them. INPO President Zack Pate has also wntien the NRC commiwoners asking their help jn reining in the staff. The staff activities, Pate said. "are impeding or undermming INPO efforts." '

The NRC commissioners agreed last year not to pass new training rules for two years so INPO could prove that voluntary utthty efforts to meet INPO accreditation standards produced superior re-nilts. The commissioners said, however. that the staff would monitor the situanon (INRC,1 April,13)

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f n Ju!), INPO and NRC signed a coordmation plan. Pate wrote: "INPO has cooperated fully with the g NRC in this area and recogmzes the NRCs need to menster traimng progress" But some recent NRC I actions, he said, "are not m keepmg with the...coordmation plan."

Pate complained of staff actions in three areas. First, he said, the staff has distributed Nurer/CR-4344. "Instnactional Skills Evaluation m Nuclear Industry Training " The document duplicates maten-al in two INPO documents but contains some different recommendations. he said, adding "NRC issu-ance of documents that dupheate INPO training-related documents is specifically precluded by the coordmation plan."

Second, without consulting INPO, NRC s OtTice of Nuclear Reactor Regulation (NRR) an- ,

nounced it will conduct " post accreditation reviews of (INPO) accredited training programs using new-l ly developed enteria," Pate wrote. " Superimposing these reviews on the accreditation process and the '

performance-onented inspections conducted by I&E (NRC Office of Inspection & Enforcement) and

( (Conrmued em pare 4)

FIRST NRC ' SYSTEM EVALUATION' SLAMS TURKEY POINT MAINTENANCE The first of NRCs new system evaluations, on the auxiliary feedwater (AFW) system at Florida Power & Light Co.'s (FP&L) Turkey Point-3 and -4, has resulted in a report harshly critical of FP&L's mamtenance, training, modification design and testmg, and quahty assurance at the plant. Ac.

cordmg to the report, a special NRC inspection team assessing the operational readiness of the AFW 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 nspture or total loss of AFW flow control valves, a maintenance backlog that kept control room instnaments 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 perform while developing new performance-based regulatory criteria. The other plants have not been named.

The shift is occurring as the NRC staff takes a tougher regulatory line 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 inspection findings to develop new methods to get substantial changes at poorly managed plants.

For the inspection, NRC called m design and engineering experts from NRC headquarters and Region II and NRC contractors. They started with the AFW system as desenhed in the operating li- 1 cense and then traced modifications, looking for de ip control, maintenance and surveillance quality, operating procedures, and adequacy of testing, esy ially after modifications or maintensnce. In his let-N INSIDE THIS ISSUE l Commissioners reject CPA L EQ deadline change -p5 NRC ataff urges tougher safety poal plan -pil i Rancho Seco restart timing in doubt -p5 ACRS members criticare Indian Point rutsng -pl3 l

hatts tiar weldmg assues resurfacing - p6 Comanche Peak paint esemption chauenged -pl 3 Anti drug pohey snagged on enforcement -p? Asselstine insists on applying backist rule -pl5 l Research reorients to aid ptant operatsons - p9 l ascal year 1985 fines chartal - pl 5-20 l l

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ter accompanying the inspection report, James Taylor, director of the Office 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 receiving low ratings on the last SALP (systematic ar.scssment of licensee performance) report, but said, "The in-spection team noted that performance in the functional areas of maintenance, surveillance testmg, 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 findings from the report included:

-The safety grade backup air system for the non. safety grade instrument air system, sital to keeping AFW flow control valves (and the system) operating, had never been functmnally tested though it had been "substantially modified." A test showed operators had only six to seven mmutes, in-stead of 15 to 20 minutes, to valve in new nitrogen bottles to the backup system in the worst case. Re-spome would have been hampered by an incorrect annunciator response procedure, and the annuncia-tor alarm set-point was halved without a safety evaluation. "The team concluded that the weaknesses identified...could have all contributed to a significant risk 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 units. Ilowever, operators must assure the correct divi. _

sion of flow between the units. Operaton were not trained in the situation and their procedures did not coser 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 flowpaths in question could not be isolated remotely from the control room could have resulted in an unnecessary and potentially significant radioactive release to the environment following a steam generator tube rup-t ure."

- Programmatic weaknessess" were found in maintenance, including "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 experienced recurrent component failures.

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- Formal classroom training sessions for maintenance technician, had been discontinued in Au-gust 1984. Licensee management stated that maintenance training had been discontinued to dedicate training resources to deseloping training materials required to support INPO accreditation of the main-tenwee training program...A very limited amount of on-the. job training and vendor supplied training had been conducted smee the decision to discontinue classroom 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 experience at Turkey Point.

The electrical 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 quahfied personnel .. Maintenance procedures generally lacked detail. Complex safety re-lated maintenance activities were often considered 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 units were out of service for greater than six months. Both units had leaking power operated relief valves (porvs) ,

and unit 4's block valves also leaked, resulting in elevated temperatures in the common discharge pipe i downstream of the pressunzer safety relief valves. As a result of the last, all three unit 4 control room l annunciators continuously showed alarms, impairing operators' ability to recognize relief valve failures.

- Durmg a system walkdown. the drain lines on the turbine casings and the exhaust silencers 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 leaking and allowing steam to reach the turbines even (

though the valves were closed....The associated steam supply valves on unit 4 also appeared to be lea-king....The B turbine did not appear to have any leakage from its steam supp y valves....No current 2 INSIDE N.R.C - (ktober 25,1985

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' PWOs were noted on the leaking steam supply vcives." l l

-Seismic qualification "was not being properly maintained," with control air lines not proper y anchored and a temporary scaffolding erected above all four instrument racks for both units' AF flow transmitters so that a collapse could have failed all AFW.

- Programmatie

" weaknesses" were found in the design change process. "The engineering g (i~ often did not provide post. modification testing requirements.... Modifications were installed witho detailed design analysis.... Design bases for safety related systems were difficult to retrieve." The found the utility " frequently base (d) design changes on engineering judgment that the new design w bounded by the origmal design analysis. Documentation justifying the engineenng judgment ty did not exist."

-At least partially as a result, "Four of six AFW steam supply isolation valve motor i operators f

were changed from AC to DC motors without adequate design analysis. Motor i doverload to protect on or the new DC motors was not properly sized. Further, the new power cables were not properly s ze ensure adequate operating voltage for the motor operators in the event of a loss of ofr-site pow bcensee had not performed any cable sizmg calculations to support this design change."

-Potentials for common mode fadures were introduced by design changes. Common relays and hmit switches were put mto redundant Train A and 11 flow control circuits and design of mtrogen backup systems could fail 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 recogmre the new battenes' different requirements.

- Excessive

" reliance was placed on operator action instead of design features to ensure the prop-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 ofidentifying quality concerns a technical and operational nature" like those NRC found. "lloth the corporate vendor audit and the plant audit programs were designed to assure that QA programs met NRC requirements and lic '

commitments from a programmatic basis only....(which) meant that FP&L management was not re-ceiving important feedback on the quahty of activities affecting the safe operation of the plant." .

Several industry sources said FP&L was objecting to some of the report's conclusions and pressing

( to have them changed. They said industry groups are concerned about the apparent new militancy in the NRC staff and will try to get the NRC co nmissioners or friendly 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 visitin plants to determine where industry initiatives are working and where NRC action is needed (INRC Aug.,1). Turkey Point is also on that list, with a review scheduled for later this year, along with Caro-hna Power & Light Co.'s Brunswick and Arkansas Power & Light Co.'s Arkansas Nuclear One. Pro-gram reviews have already been done at Nartheast Utilities' Millstone, Toledo Edison Co's Davis-Ilesse Sacramento Municipal Utihty 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 our (inspection) findings must be laid at the doorstep of top management....The buck stops there."-Margaret L Ryan and Eric Lindeman. Washington MERITS OF USER FEE SCHEME TO BE RESOLVED BY HOUSE-SENATE CONFERENCE The merits of a proposed scheme by which NRC would be required to collect user fees to offset 50% ofits authorized budget will be battled out by llouse and Senate conferees when a budget confer-ence begins meeting this week. The llouse 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 version of the bill,it will first be 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

( provision will be conudered. In the meantime, industry lobbyists are working to kill the provision, questioning the basis for setting budget recovery at 50% Fighting in the industry's comer is Rep. Dan Rostenkowski (D.lll.), chairman of the llouse ways & Means Committee, who argued before the Rules Committee that the user fee is really a tax and so must he considered by his committee first. The 3

INSIDE N.R.C, - Octotm 28,1985