ML20247H091

Requests NRC to Take Immediate Actions to Cause Imposition of Escalated Civil Penalty,Suspension of Licenses DPR-31 & DPR-41 & Order to Correct Numerous Plant Deficiencies

ML20247H091
Person / Time
Site:	Turkey Point
Issue date:	04/26/1989
From:	Saporito T AFFILIATION NOT ASSIGNED
To:	Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML17347B178	List: ML20246N215 ML20247H091 ML20247H129 ML20247H172
References
2.206, NUDOCS 8909190213
Download: ML20247H091 (2)

Text

. _ _ _ _ _ . -

p &

-(  : 6 Victor Stello, Jr.

q~ 1 o 'Mr. April'26, 1999 g(4,4,_ .

Executive Director for Operations U.S.' Nuclear Regulatory Commission- j4N L FAXED & Certified  :

Washington, D.C. 20555 (P 982 346 227) OkuEy RE: 10 CRF 2.206 - Turkey Point Nuclear Stations Dockets Nou. 50-250/50-251- Operating Licenseu DPR-31 & DPR-41 Please be' advised and -officially informed as this letter represents formal notification to your office requesting specific actions pursuant to 10 CRF 2.206 (by your-cffice) as delineated below1and appropriately' warranted as provided in the basis and justification text of this official' petition. -

SPECIFIC REQUEST: i

'Take immediate actions to cause the imposition of an escalated civil penalty.

Take immediate actions to cause the suspention of ooerating licenses ,

DPR-31 and DPR-41. 1 Take-immediate actions to cause an order to your licensee' outlining the required steps and measures to be taken within a defined time frame to correct the numerous operation, maintenance, security, plant equipment, and employee / operator training de Ficiencies.

BASIS &' JUSTIFICATION: )

i Conduct of maintenance performed by your licensee' Turkey Point Nuclear  !

Station regarding repair work to the Unit #2 Thimble Guide Tuoe Assemblies, departed from approved SAFETY RELATED procedures.

This event 15 yet another example of the CRISIS MANAGEMENT ongoing at your license 6' nuclear facility. Your licensee' zeal,to return these (2) nuclear units ON-LINE has resulted in-their work force performing rush work. Additionally, your licensee' work force has been

continuously working an excessive amount of overtime in an effert to quickly effect equipment repairs. (Quick Fix) i The potential for a severe accident resulting from this event cannot be underestimated as the primary (RCS) Reactor Coolant System boundary could not have tweq physically isolated by velve manipulation. Had this work not terminated prior to Thiihble Guide Tube (L-9) being penetrated, a significant loss of RCS inventory would have occurred resulting in an ALERT CONDITION and contamination to personnel and equipment would have been extensive. l Your licensee has a well documented history involving departures from approved procedures and resulting enforcement action in the form of i escalated civil penalties by the NRC, Nuclear Regulatory Commission.

has not demonstratively been a detsement for future occurrence nor has your licensee's performance in this area improved, as repetitive v.iolations continue at the nuclear station.

0213 890722 hyk'Il DOCK 0D000200 .

1 -

-p

)

PDR 1

e '(k ,

J

SABIS & JUSTIFICATION:

Your licensee is overwhelmed with equipment problems, poor operator l ' training, poor personnel (worker) . training, poor security training, l security problems, etc. The Nuclear Regulatory Commission Headquarters must now act decisively and without hesitation in that the operating j licenses warrant immediate suspention. This license action will:

demonstrate' to your licensee that continuous violations of the Federal ,

Regulations .as they apply to Commercial Nuc1 car Power Generation will d E not and cannot be tolerated. It is imperative that your office initiate I

measures to cause the aforementioned license action as the i responsibility for the Health and Safety of the Public is your very l mandate. j i

1 CLOSING STATEMENT:  !

I respectfully request a written response pursuant to 10 CFR 2.206 reflecting the actions which the Nuclear Regulatory Commission is I taking to address and resolve these grave issues. ,

i I am very disappointed and concerned. over the lack of appropriate enforcement action by the NRC Headquar.ters and the tolerance of the NRC Headquarters .to. permit their licensee to continue operations without~ 1 the NRC Headquarters being able to ensure that their licensee has 1 resolved the root causes of their problems. It is unsettling knowing that grave issues ongoing at this nuclear facility continue and that.I 1 am' raising a family in an area which can be 6dversely affected by a significant event at that nuclear facility.

I respectfully request that you take immediate actions to cause a meeting between yourself, NRC Chairman Lando Zech, NRC Regional Administrator Steward Ebneter, NRC Regional Allegation Coordinator Oscar de Miranda, NRC-Office of Investigations Inspector Robert Burch.

United States Senator John Breaun, and myself, to candidly discuss the conduct and behaviour of the NRC Headquarter

• personnel concerning the operation of the Turkey Point Nuclear facility. 4 l l cc: U.S. President George Bush Sincerely, U.S Senator John Breaux .

j d

Congressman Dante B. Fascell Thomas J. Saporito, Jr.

off NRC Regional Adm. Steward Ebneter NRC RAC Oscar de Miranda 1202 Sioux Street ALL MEDIA SOURCES Jupiter, Florida 33458

7 A, . , ,

, .; 4 Executtvo Directer fcr Operotions .

~

1' 3 United States Nuclear Regulatory commission , ..

Washington, D.C. 20555 < " -

' Thomas J. Saporito, Jr. .

1282 Sioux Street- ..

Jupiter. Florida 33458 /

(487) 747-8873 y

%p ,  ;

.o; re: Title (10) Code of Federal , Regulations Part (2.296) q

, ygi . y<

Dear Sir:

' 21DEC8df Ik, y i M Please be advised and officially informed as this' letter repiresents @

formal request to your office in rosards to your licensee Florida Powers

& t,isht Company, (Turkey Point Nuclear Station), locatedin}{omestead,I Florida for actions by your office as specified below, p p Snecific Recuest: /.., S.

The request is hereby made upon your office to insure!that your-licensee is not permitted to bring the (Unit 3 or Unit 4)/ Reactors!

Critical until such time as your licensee completes it's!taterney safety invest 1satton and until such time as the Nuclear Consissioncompletesit'sinvestigationrelatingtothesafety$*ssulatory/ concorrisM addressed in the report of 95DEC88 furnished toNRCRes;ionIIof 86DEC88 by Thomas J. Saporito, Jr. -

.p 3

Basis and Justification: N  !

Reference

(

is made to the fact that this nuclear station has Pfevious1h-Q been rated as one of the ten worst nuclear stations in the couhtry. 4 Reference is made to the past l

INPO(InstituteofPlantOkera statton inspectton reports as these reports problems at the . station which resulted in the revealed aianificantf station recelying very' poor evaluation ratinas by the INP0 team, f Q Peference is madetotheEnerconServivesreportwhichinfaktwasak independent Management Appraisal as this agency was contracting by thi .

Florida Power & Lisht company in an effort to address the coscerns of.'

continuous poor performance at it's Turkey Point Nuclear Station. This; report identified (5) root causes attributing to Turkeyt Point's; performance deficiencies as defined herein. t

)

)

81 Inadequate leadershipisreflectedinthefailuretoestahlishand..,

communicate effective goals for plant improvement.  ; )

1. 2 An inadequate sense of personal accountability persists within the Turke:/ Point work force as manasement is not adequately usins' information provided by the Quality Assurance and Qualltf Control,,

orseniaations. 1-7 +

1. 3 The IMA team identified a lack of sufficient technical sup$ ort as av root cause of several performance deficiencies at Turkey; Point as various Jngirieerin8 organizations, both onsite and offsite ~

arenott j properly structured to support the station. ..

g.

, , m. ,

y= , a en ds oo% io emen 1 . .

Page 2

1. 4 The INA team identified inadequacies in several key-suppo at Tarkey Point which included inadequate plant information a inefficient system for producins and contro111ns Plant Work inadequate Instrument and Control support for plant o Additionally, excessive -us e of overtime is a further ind inadequate support systems.

85 The IMA tona identified a lack of a strong sense of plant and leadership in the Operations Department as the Department has a tradition of accepting and overcomisfa plant and support deficiencies, rather than demanding axes 11 enc l supporting departments such as natntenance, technical a training.

Reference is made to the Nuclear Regulatory Consission's Saf  ;,

Functional Inspection Report (50-250/85-32: 50-251/85-32) as repo identified the following concerns. ' !.

.M %,u. W.  ;

1. 1 Umarade of the Auxiliarv_Feedwater Systen: NRC recognises 1 ' $fd by FPL and the team reviewed details of the upgrade program, oweve the tema believes a uuuber of the inspection issues should-ve'. .be '

identified by FPL and incorporated into it's upgrade program,i g.'t3.:Q" 1- o.

82 Non-Safety Grade Standby Feedwater System: The NRC team at the time of the ~ inspection, that there were no adal <

controls or Technical Specification requirements in place.to ,

availability on demand of this standby system. Consequently, concluded that it would be inappropriate to take into conside [t6 capabilities t ion:.t of this systen during the team's analysis i of t inspection findings. '! -. -

1. 3 Safety Related Nitronen Systes: The NRC team determine cannot be assumed that control roca operators would shiftdhoffl htab control valves from automatic to manual mode within (6-7 iininutes following an accident because (1) some operators were trained , h assum . <

they had (15-20 minutes) available to take action, and (2) a< plicabl j energency procedures did not include requirements for the opecators t shift the flow control valves to manual.

Reference is made to the fact that the Turkey Point St tion ha demonstrated past weaknesses in the areas of plant opkations maintenance, and quality assursace programs as these functio!41 area -

were rated Category (3) on the Systematic Assessment of 1.icense Performance ($ ALP) dated 01JUL83 - 310CT84 Additionally , plan operations was rated Category (3) in the previous SALP as wellp. g,;

. I.

w . ,,

/'

f: <

1 O L.-

u: .

r,O k,, -

h

,.y Peso 7 7, ,

Reference is made to SALP (Systematic Assessment o th Performance) Inspection Report Number (50-250/88-15: 89-25 -ft 1

dated 91JUN87 throush 38JUN88 and which identifled th I concerns at the Turkey Point Stations .

$,fl;,T

(-

81 The security prosram continues to show a weakness as i ap)eltlz the continued number of violations which are repetitive in na Q  !

1. 2 Durins the first half of this SALp period, licensee per sin the area of Operations was narsinal as demonst/ated b uf ~ [

problems, plant availability, number of escalated enforceae and the number of special NRC inspections.

a' p-  !

LJ

1. 3 For the last six months of 1987, Unit 3 had an avallobi of less than lot. Followins the repairs to the conoseal 1 l return'ed to service in July and had an up and down operation F for the renainder of 1987. '

A

1. 4 An event occurred at the end of the SALP period, which loss of the required boric acid flow paths. '

1. 5 A special NRC trtspection conducted in June 1987  % j escalated enforcement action and a civil penalty. ,

86 In July 1987, another event occurred resulting in a Seve III violation as this event identified that a turbine opera  ; )

the backup nitrogen supply valves to the Auxiliary Feedwater 5

. 87 In september 1987, an unauthorized. unlicensed indi allowed to manipulate the dilution controls of Unit 3 with t  :

at power as (4) licensed operators observed the even intervening. [

.Jt

1. 5 In October 1987 voids were detected in the Unit 4 re

~

reston with the plant at cold shutdown as and evaluation a that nitrogen from an accumulator had entered the pria

,4pif- if throush a leakiris accumulator isolation valve.

.f

1. 9 Fifty-one LERs (Licensed Event Reports), were submitted i 1}t seven months of 1987 and 14 were submitted in 1988 LS lj';i 7 1 9 ' p f_ '/.-

1. 18 Four reactor trips occurred during this evaluation perio offviis 3 as two of the trips were due to personnel error and Que!'!

equipment malfunction.

.c '.. K :

m 2 .. i 811 The leadsrship of the operators has also inadvertently be Jdiluf y through several corrective incorrect actions in response to identified p Technical Specification interpretations lets t

'v(' be -- l documented over the past several years. K l(.,;:

I

.h '

'wy -

9

$ l 1:T

• p* "

0-

.- s %. s a ,

9000 s " *: :.

As evidenced herein, the Turkey Point station over the<past continuounty demonstrated a poor conduct of maintena "dp b leadership, poor quality improveasnt, unprofessional r-behaviour, and a lack of ability on the part of the erst management to properly and effectively address and yes easeg'

'.the concorns as this conduct of maintenance continues at the pres .. time.

Please be informed that I.have concerns that other eeploy et "

Turkey Point Station any have~ knowledge of additional safet Moe, which may not readily surface as these employees are being i a by the licensee and these employees have witnessed my consequ s; '

have made known my safety concerns to outside agencies an '

therefore reluctant to come forward with their concern preventing the address and resolution of any safety concern EMa be aware of. It is therefore_Jemerative that the Ifeense- 'drf Point Stations Reactors, not be permitted to become critical imrt cysr time as th_a aforementioned safety investigations are conclu " Naud < *

- -s . -

the nroper and correct autdance to your licensee to this end. ..

vb. 'f

'l .,

Sincerely: Certified Msile (P 982 346  ;

, . - - - , y' " : .

o'

?

Thomas J. aporito, Jr.

f'( '

.+

n

, \

I i 1 w  :

)$

~

k$ a r.y. ,

?i u- \

q /U.* ...

l

., ,,. f 5..\

,f.*luf

'l. :t

. 5 "T, i 4# .

• _ .. .. . .- ---