ML20199E398
| ML20199E398 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 01/06/1986 |
| From: | Grimsley D NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Weiss E HARMON & WEISS |
| Shared Package | |
| ML20199E404 | List:
|
| References | |
| FOIA-85-729 NUDOCS 8603270202 | |
| Download: ML20199E398 (5) | |
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d UNITED STATES
, ~8 NUCLEAR REGULATORY COMMISSION o
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WASHINGTON. D. C. 20555
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JAN 'S Ellyn R. Weiss, Esquire Harmon, Weiss & Jordan 2001 S Street, NW, Suite 430 IN RESPONSE REFER Washington, DC 20009 TO F01A-85-729
Dear Ms. Weiss:
This is in further response to your letter dated October 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 systen at Turkey Point Units 3 and 4.
The 2 documents listed on the enclosed Appendix C are already available in the NRC Public Document Room (PDR).
Copies of the 16 doculnents listed on the enclosed Appendix D are being placed in the NRC PDR in folder F01A-85-729 under your name.
The 2 documents listed on the enclosed Appendix E contain predecisional advice, opinions, and recommendations of the staff regarding the system 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 riot be in the public 4,
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 Dr. J. Nelson Grace, Administrator, NRC Region II.
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i Ellyn R. Weiss, Esquire l This denial may be appealed to the Commission's' Executive Director for Operations within 30 days from the receipt of this letter. As provided in 1
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 j.
an " Appeal from an Initial F0IA Decision."
The NRC has not completed its search.for and review of documents sub,iect to your request. We.will respond as soon as those actions are completed.
Sincerely, 1
%u S/k,dx.
Donnie H. Grimsley, Director Division of Rules and Records Office of Administration
Enclosures:
As stated e
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Re:
F01A-85-729 APPENDIX'C 1.
06/09/85 NUREG-1154 Less of Main and Aux. Feedwater Event at D' avis-Besse Plant. ACN 8508150428-PDR (98 pages)
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2.
11/01/85 Letter.to Thompson from Williams re: Turkey Point Units 3.and 4, Standby Steam Generator Feedwater Pumps. - ACN 8511050030-PDR (2 pages)~
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Re:
F0IA-85-729 APPENDIX D 1.
10/09/72 Nitrogen Backup Supply. System Piping and Instrument-Diagram -
(4 pages) 2.
07/26/85 Memo from Brian to Jones,
Subject:
Turkey Point Unit 3 and 4 Auxiliary Feedwater System Update and Schedule - (5 pages) 3.
08/07/85 Memo from Williams to Dager,
Subject:
Turkey Point Unit Nos.
3 and 4 Auxiliary Feedwater System - (18 pages) 4.
08/22/85 Turkey Point Units 3 and 4 ' Operating Procedure 7201.1 -
(6 pages)
~ 5.
08/22/85 Turkey Point Units 3 and 4 Operating Prncedure 9408.3 -
(3 pages) 6.
08/23/85 Turkey Point Units 3 and 4 Operating Procedure 9408.2 -
(11pages) 7.
08/23/85 Turkey Point Units 3 and 4 Operating Procedure 7308.1 -
(17 pages) 8.
09/30/85 Letter from Williams to Grace, re: Turkey Point Units 3 and 4 Auxiliary Feedwater System.
(2 pages) 9.
10/01/85 Press Release.
(2 pages).
10.
10/28/85 Handwritten Notes, re: ~RII, OIE, FPL Conference Call on 10/28/85.
(3 pages)
- 11.. Undated List of Auxiliary Feedwater PC/M's.
(10 pages)
- 12. Undated
. List. of PC/M's that Affect AFW Support Systems.. (11 pages)
- 13. Undated. Response to NRC Findings Auxiliary Feedwater System Turkey
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Point.
(29 pages)
- 14. Undated Handwritten List of Attendees.
(2 pages)
- 15. Undated Draft Memo from Elrod to Callahan,
Subject:
. Turkey Point AFW Problems.
(1 page )
- 16. Undated Integrated Safety System Implementation Plan.
(1 page) d i
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Re:
FOIA-85-729 APPENDIX E 1.
Undated Chart showing Turkey Point Issues with Inspector Coments.
(7 pages) 2.
Undated Inspector's Notes Regarding Turkey Point Issues. (43 pages) m
1 HARMON, WEISS & tIORDAN 2001 S STREET. N.W.
SulTE 430 WASHINGTON, D.G. eoooo G All McGREEVY H ARMON TELEPHONE ELLYN R. WEISS (202)328 3500 WILLIAM S. JORDAN, Ill DIANE CURRAN DEAN R. TOUSLEY October 31, 1985 Mr. Joseph Felton, Director FRGAX)M OF INFOHW NON Division of Rules and Records ACT Pr ?'E E!
FoIA-PS - 749 Of fice of Administration U.S. Nuclear Regulatory Commission h //- -b Washington, D.C.
20555 RE:
FREEDOM OF INFORMATION ACT REQUEST
Dear Mr. Felton,
Pursuant to che federal Freedom of Information Act, I hereby
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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, i
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e e InsideNR.C M
An exclusive report on the U.S. Nuelear Regulatory Comunission Vol 7. No. 22 - October 29.1985 3 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 training programs after INPO has accredited them. INPO President Zack Pate has also wntien the NRC commissioners askmg their help gremmg in the staff. The staff activities, Pate said. "are impedmg or undermining INPO etTorts?
The NRC commissioners agreed last year not to pass new training niles for two years so INPO could prove that voluntary utility efforts to meet INPO accreditation standards produced superior re-suits. The commissioners said, however, that the staff would monitor the situation (INRC,1 April,13).
In Ju!), INPO and NRC signed a coordination plan. Pate wrote: "INPO has cooperated fully with the NRC ir. :his area and recogmzcs the NRCs need to monitor traimng pregrss " But mme recent NRC
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actions, he said, "are not m keeping wnh the...coordmation plan "
Pate complained of staff actions in three areas. First, he said, the staff has distributed Nureg/CH-4344," Instructional Skills Evaluation m Nuclear Industry Training." The document duplicates maten-al in two INPO documents but contams some different recommendations, he said, adding, "NRC issu-ance of documents that duphcate INPO training-related documents is specifically precladed by the coordmation plan."
Second, without consuhing INPO. NRCs OtTice of Nuclear Reactor Regulation (NRR) an-nounced it will conduct " post-accreditation reviews of (INPO) accredited training programs using new-ly developed critena," Pate wrote. "Supenmposing these reviews on the accreditation process and the performance-onented inspections conducted by I&E (NRC OtTice of Inspection & Enforcement) and C
(Connnued on pace 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 Cols (FP&L) Turkey Pomt-3 and -4, has resulted in a report harshly entical of FP&L's mamtenance, training, modification design and testing, 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 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-erstions (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). Besides forcing management attention to what NRC perceives as lingering maintenance problems at Turkey Point (INRC,30 Sept.,1), the staff wil:
be using the inspection findings to develop new methods to get substantial changes at poorly managed plants.
For the mspectior., NRC called in design and engmeering experts from NRC headquarters and Region 11 and NRC contractors. They started with the AFW system as desenbed in the operating li-cense and then traced modifications, looking for design control, maintenance and surycillance quality, operating procedures, and adequacy of testing, especially after modifications or maintenance. In his let-
?
i INSIDE THIS ISSUE Commissioners reject CPA L EO deadhne change
- p5 NRC staff s eges tougher safety goal plan
-pil Rancho Seco aestart timang in doubt
-p5 ACRS mer sbes: criticare indsan PoinI tulang
- PI 3 hatts Bar welding essues resurfacing
- pe>
O>manche Peak paint esemption chailenged
-pl 3 Anti <1 rug pohey snagpd on enforcement
-p7 Asselstine insists on applysng backfit rule
-pl$
Research reorients to aid plant operatsons
-p9 Fiscal year 1985 fines charted
-p15 20
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ter accompanying the inspection report, James Taylor, director of the Office of Inspecimn & 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 receivmg Iow ratings on the last SALP (systematic assessment of licensee performance) report, but said, "The in-spection team noted that perfonnance in the functional areas of mamtenance, 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 wi!! follow up Specific findings from the report included:
-The safety grade backup air system for the non-safety grade instrument air system, vital 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 seven mmutes. in-stead of 15 to 20 mmutes, to valve in new mtrogen bottles to the backup system in the worst case. Re.
sponse 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 hase all contnbuted 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-s, ion of flow between the units. Operatois were not trained in the situation and the; proadures did not cover it.
-The AFW turbme steam supply isolation valves could not be shut from the control roor, if an AFW actuation signal was present. Operators had no training to recognize the sign #s override of con-trol room switches. "The team concluded that th'e 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-ture?
- Programmatic weaknessess" were found in maintenance, including "the consistent failure to evaluate the root cause of equipment malfunctions and to trend these failures to pmvide input to the preventive mamtenance program," though key parts of the AFW system had expenenced recurrent
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component failures.
- Formal classroom training sessions for maintenance technicians had been discontmued in Au-gust 1984. Licensee management stated that mamtenance training had been discontinued to dedicate trainmg resources to developing training materials required to support INPO accreditation of the main-tenance traming program....A very hmited amount of on-the-job training and vendor supplied training had been conducted smce the decision to discontinue classroom training."
- Over half of the I&C (instrument & control) technicians that conduct surveillance tes's (15 of 27 at the time of the inspection) had an average ofless than 6.5 months of experience 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 quahfied personnel.... Maintenance procedures generally lacked detail. Complex safety re-i lated miintenance 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 Icvel monitors out since February, and several area radiation monitors on both umts 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 downstream of the pressunzer safety relief valves. As a result of the last, all three unit 4 control room annunciators continuously showed alarms, impairing operators' ability to recognize rehef valve failures.
-"Dunng a system walkdown, the drain hnes on the turbine casings and the exhaust sdencers 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 turbme did not appear to have any leakage from its steam supply valves....No current 2
IN$tDE N.R.C. - ocioba 28,1985
PWOs were noted on the leaking steam supply valves."
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-Seismic quasification "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 flow transmitters so that a collapse could have failed all AFW.
- Programmatic weaknesses" were found in the design change process. "The engineering often did not provide post-modification testing requirements.... Modifications were installed wi
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detailed design analysis.... Design bases for safety related systems were difficult to retrieve." Th found the utility " frequently base (d) design changes on engineering judgment that the new de bounded by the original design analysis. Documentation justifying the engineciing judgment ty did not exist.'
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-At least panially as a result, "Four of six AFW steam supply isolation va've motor operators i f were changed from AC to DC motors without adequate design analysis. Motor overload protect on o l i d to the new DC motors was not properly sized. Further, the new power cables were not proper y s ze ensure adequate operating voltage for the motor operators in the event of a loss of off-site po licensee had not performed any cable sizing calculations to support this design change."
-Potentials for common mode failures were introduced by design changes. Common relays an hmit switches were put into redundant Train A and B flow control circuits and design of mirogen backup systems could fail redundant control room annunciator circuits.
-Safety related station batteries were modified but no calculations were done to show the ne ones could meet the design basis and plant procec:ures and technical specifications were not c recognize 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 quality assurance (QA) auditing activities revealed that these audits, as implemented, neither had identified nor were capable of identifying quality conc a technical and operational nature"like those NRC found. "Both the corporate vendor audit and the plant audit programs were designed to assure tiat QA programs met NRC requirements and 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 FP&L 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 militancy in the NRC staff and will try to get the NRC commissioners 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 visit 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 Brunswick 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-l Besse, Sacramento Municipal Utility District's Rancho Seco, and Wisconsin Public Service Corp.'s Kewaunee.
i Region II Administrator Nelson Grace noted INPO and the Nuclear Utility Management & Hu-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-I 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 j
$0% of its authorized budget will be battled out by llouse and Senate conferees when a budget confer-ence begins meeting this week. The Ilouse 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 f;rst 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
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provision will be considered. 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 corner is Rep. Dan Rostenkowski (D-Ill.), chairman of the llouse Ways & Means Committee, who argued before the Rules Committee that the user fee is really a tax and so must be considered by his committee first. The j
INSIDE N.R.C. - Octoba 28,1985
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