ML17354A718

Responds to NRC Ltr Re Violations Noted in Insp Repts 50-250/97-10 & 50-251/97-10 on 970810-0920.Corrective Actions:Components Were Tagged & Placed in Radiation Controlled Area

ML17354A718
Person / Time
Site:	Turkey Point
Issue date:	11/18/1997
From:	Plunkett T FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-250-97-10, 50-251-97-10, L-97-283, NUDOCS 9711240294
Download: ML17354A718 (28)

See also: IR 05000250/1997010

Text

CATEGORY,1

REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)ACCESSION NBR:9711240294

DOC.DATE: 97/11/18 NOTARIZED:

NO FACIL:50-250

Turkey Point Plant, Unit 3, Florida Power and Light C ,50-251 Turkey Point Plant, Unit 4, Florida Power and Light C AUTH.NAME AUTHOR AFFILIATION

PLUNKETT,T.F.

Florida Power&Light Co.RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)SUBJECT: Responds to NRC ltr re violations

noted in insp repts 50-250/97-10

&50-251/97-10

on 970810 to 970920.Corrective

actions:components

were tagged&placed in RCA.DISTRIBUTION

CODE: IE01D COPIES RECEIVED:LTR

'NCL S1ZE: TITLE: General (50 Dkt)-Insp Rept/Notice

of Violation Response~NOTES: DOCKET 05000250 05000251 RECIPIENT ID CODE/NAME PD2-3 PD INTERNAL: AEOD/SPD/RAB

DEDRO NRR/DISP/PIPB

NRR/DRPM/PECB

NUDOCS-ABSTRACT

OGC/HDS3 t EXTERNAL: LITCO BRYCE, J H NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME CROTEAU,R FILE C R DRCH/HHFB NRR/DRPM/PERB

OE DIR RGN2 FILE 01 NOAC NUDOCS FULLTEXT COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 0 0 N NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE.TO HAVE YOUR NAME OR ORGANIZATION

REMOVED FROM DISTRIBUTION

LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 18 ENCL 18

Jv

Florida Power&Light Company, P.O.Box 14000, Juno Beach, FL 33408.0420

NVv 18 199l L-97-283 10 CFR 2.201 U.S.Nuclear Regulatory

Commission

Attn: Document Control Desk Washington, D.C.20555 Re: Turkey Point Units 3 2 4 Docket Nos.50-250/251

Reply to Notice of Violation Florida Power 8.Light Company has reviewed the subject inspection

report and, pursuant to 10 CFR 2.201, the required response is attached.If there are any questions, please contact us.Very truly yours, T.F.Plunkett President Nuclear Division L"-I CLM Attachment

cc: Regional Administrator.

Region II, USNRC Senior Resident Inspector, USNRC.Turkey Point Plant 97ii240294

97iii8 PDR ADGCK 05000250 6 PDR d g~~~I)an FPL Group company IIIIIIIIIIIIIIIIIII!I!IIIIIIIIIIIIIIIII

Attachment

to L-97-283 Page 1 REPLY TO NOTICE OF VIOLATION RE: Turkey Point Units 3 and 4 Docket Nos.50-250 and 50-251 NRC Inspection

Report 97-10 F~INDIN A"During an NRC inspection

conducted on August 10, to September 20, 1997, violations

of NRA.'equirements

were identified.

In accordance

with the General Statement of Policy and Procedures

for NRC Enforcement

Actions, NUI&G-1600, the violations

are listed below: Title 10 CFR Part 20.1501(a), requires, in part, that each licensee make or cause to be made, surveys that may be necessary for the licensee to comply with the regulations

and are reasonable

under the circumstances

to evaluate the extent of concentrations

or quantities

of radioactive

material;and the potential radiological

hazards that could be present.Title 10 CFR Part 20.1801 requires the licensee to secure from unauthorized

removal or access licensed materials that are stored in controlled

or unrestricted

areas.Title 10 CFR Part 20.1802 requires the licensee to control and maintain constant surveillance

of licensed material that is in a controlled

or unrestricted

area and that is not in storage.Licensee Technical Specification 6.8.1 requires written procedures

be established, implemented, and maintained

covering procedures

recommended

in Appendix A of Regulatory

Guide 1.33, Revision 2, February 1978, Sections 5.1 and 5.3 of ANSI N18.7-1972.Licensee procedure O-HPS-021.3,"Release of Material from the Radiation Controlled

Area," Revision dated August 20, 1997, required in step 6.7,"Tools or equipment painted purple may NOT be released from the RCA until all the purple paint is removed, and the tools or equipment verified free of radioactive

contamination." Contrary to the above, these requirements

were not met in that: l.On August 11, 1997, the licensee failed to survey and control contaminated

motor operated valve actuators released to an unrestricted

area.The components

had

Attachment

to L-97-283 Page 2 fixed byproduct contamination

up to approximately

130,000 dpm/100 cm~.On September 18, 1997, the licensee failed to follow procedures

for the control of byproduct materials for a contaminated

temperature

gauge released from the licensee's

Radiation Control Area and Protected Area, even though the purple paint had not been removed and it was not verified'to

be free of radioactive

contamination.

The temperature

gauge had fixed byproduct contamination

up to approximately

7,500 dpm/100 cm'.This is a repeat Severity Level IV violation (Supplement

IV)." RESPON E TO FINDIN A First Exanip/e: Main Steani Bypass Valve Motor Actuators Florida Power 8c Light Company (FPL)concurs with the finding.The following information

is provided: a)The two MOV actuators were removed from the Protected Area and taken to the Nuclear Training Center in April of 1997.These actuators originated

from the turbine and were never in the Radiation Controlled

Area (RCA).b)The contamination

on the MOV actuators was up to 13,000 disintegrations

per minute (dpm)per probe area as measured with an HP-380B scintillation

probe.The extent of contamination

however was very localized'and

did not extend beyond one probe area (less than 100 square centimeters).

The total activity therefore was approximately

13,000 dpm on one actuator and 5,000 dpm on the second actuator.2.Reason for the violation:

The Main Steam Bypass Valve actuators from valves 3-1401 and 3-1402 were discovered

on 8/11/97 by a Radiation Protection

Technician (RPT)during a quarterly survey of the Nuclear Training Building.The actuators read 1000 and 2600 counts per minute above background

respectively

with an HP-380B scintillation

probe which is approximately

5,000 and 13,000 dpm respectively, based on the 20%efficiency

of the probes.The radiological

risk to the public and the workers from this violation was very low because of the small amount of radioactive

material involved, and because the fixed contamination

is not expected to spread.No other contaminated

secondary side components

have been found outside the Protected Area during our ongoing site survey.

0

t Attachment

to L-97-283 Page 3 A condition report was initiated and an Event Response Team (ERT)led by the new Radiation Protection

and Chemistry Super visor was formed immediately

aAer discovery of the contaminated

actuators.

The ERT was composed of cross discipline

personnel from Radiation Protection, Operations, Maintenance, Engineering, Work Controls, and Training.The ERT met numerous times over a period of three weeks to evaluate the causes of this event and related events.The ERT determined

that in the late 1970's, contaminated

steam from packing leaks impinged on turbine components

leaving residual low level contamination.

Cesium-137, with a half life of 30 years, was the only radionuclide

detected on the actuators.

The team determined

that Unit 4 (and to a lesser extent Unit 3)operated with primary to secondary steam generator leakage combined with some fuel defects in the late seventies and early eighties which provided suAicient low level contamination

to be detectable

today.Records show that certain turbine areas (which are outside the RCA)were posted and controlled, but were incorrectly

deposted sometime in the 1980's with this residual external contamination

on some installed components.

The actuators in question were removed during the March 1997 Unit 3 refueling outage, and taken to the Training Department

in April without Radiation Protection

surveys.The causes of this event are not similar to any recent events in that these components

were never released from the RCA.In each of the previous cases, the causes and corrective

actions focused appropriately

on the controls and processes for release of material from the RCA.A review of these previous events did not disclose any information

that would have led FPL to assess the possibility

of external contamination

of secondary plant components.

The Main Steam Bypass Valve actuators were contaminated

over ten years ago.The actions identified

by the ERT which led to the event were: 1)the decision to operate the units in the late seventies and early eighties with primary to secondary leakage combined with fuel defects, 2)the inadequate

surveys by HP in the early eighties deposting the turbine areas, and 3)removal of the two contaminated

actuators from the Protected Area.Du'ring the root cause analysis, the team identified

25 additional

contaminated

components

still installed on Unit 4 secondary systems, and 7 contaminated

components

still installed on Unit 3.Surveys of the Training Building and other storage areas revealed no additional

contaminated

components

removed from secondary systems.The root causes identified

by the ERT for the inappropriate

actions associated

with MOV actuators are:

Attachment

to L-97-283 Page 4 a)Radiation Protection

staA'believed

that the activity in the-secondary

systems was confined to the inside of the piping, and did not question contamination

of external components.

b)In the early eighties, the Radiation Protection

program at Turkey Point focused more'on the worker occupational

health issues than on the control of very low levels of contamination.

c)The plant staff did not understand

the mechanism of steam contamination

of external surfaces of components

in the secondary system.Specifically, leaks such as packing glands deposited long lived Cs-137 on components

on the exterior of the system when operating with primary to secondary steam generator leakage.This phenomenon

manifested

itself in the late seventies and early eighties when the plant was experiencing

both primary to secondary steam generator leakage and fuel defects.3.Corrective

steps which have been taken and the results achieved: HP immediately

controlled

the contaminated

components.

The components

were tagged and placed in the RCA.b)c)The turbine areas where the components

had been taken from were immediately

posted as Radioactive

Material Areas.k A thorough survey of the training building shop and storage areas was performed.

No additional

radioactive

material was found.d)An Event Response Team (ERT)was formed as directed by plant management.

The ERT performed Event and Causal Factor Charting and a Barrier Analysis.e)Regarding the decision to operate in the late seventies with the fuel leaks and the primary to secondary leakage: The current culture and procedures

at Turkey Point would not permit such a decision today.Procedures

3-ONOP-067, Radioactive

ENuent Release, and 3-0NOP-071.1, Secondary Chemistry Deviation from Limits, were reviewed and found to be more conservative

than Turkey Point's Technical Specifications.

In addition, a rate of change criteria is built into the procedures

to limit allowable steam generator leakage.No further corrective

action was needed.Procedure O-HPS-21.3, Release of Material from the Radiation Controlled

Area, was revised to clarify and strengthen

material release surveys and documentation.

Attachment

to L-97-2S3 Page 5 Information

Bulletin 97-37, Control of Licensed Material, was distributed

to all departments

o'n August 21, 1997.h)Training Brief P692 entitled"Control of Licensed Material" was issued to Radiation Protection, Operations, and contract HPs on August 22, 1997.Training Brief 8692 communicated

the importance

of attention to detail during surveys of clean areas, which may have material that has come from secondary systems.A program was developed and implemented

to control radioactive

material on the.secondary side of the plant.This program is designed to identify and control radioactive

material during the U-4 outage and during maintenance

activities.

Success with this program was achieved when other installed radioactive

components

were identified.

As a result, the turbine building has been posted for radioactive

materials.

An additional

Radiation Protection

contract technician

crew was brought in for the outage to augment the controls for work on the secondary systems to assure components

would be surveyed, and properly identified

and controlled

if contaminated.

As a result no additional

instances of improperly

released contaminated

material occurred, although several contaminated

components

were found installed, as described above.k)A program was developed to evaluate/survey

all outgoing material and equipment from the plant Protected Area and to survey selected incoming material and equipment during the U-4 outage.This program was designed to identify and control radioactive

material.As a result, numerous contaminated

items were prevented from leaving the RCA, and contamination

was discovered

on several incoming items.Three of these discoveries

resulted in notifications

in accordance

with 10CFR50.72.

An evaluation

was performed on personnel exit controls.These controls have been strengthened

by requiring personnel to momentarily

pause on the foot detector grating (using foot print outlines)improving monitor sensitivity.

A memo from the Operations

Manager was distributed

to all plant personnel regarding changes in plant Protected Area requirements.

During the Unit 4 refueling outage, a security oAicer was stationed at the Nuclear Entrance Building exit and ensured that the personnel training was effective.'.

Corrective

actions which will be taken to prevent further violations:

The deficiencies

discussed in the inspection

report and corrective

actions described herein

0)

Attachment

to L-97-283 Page 6 have been covered in HP department

meetings, and will be communicated

to all incoming contract HP technicians.

The following is a list of corrective

actions that will be taken to prevent further violations:

a)Training Brief II692 described above will be added to initial and continuing

training for all Radiation Protection

personnel.

b)Health Physics will provide a list of components

externally

contaminated

to the Work Controls department

in order to establish a computerized

mechanism to alert the staff of the need for controls for future work.c)The program for controlling

radioactive

material/components

on secondary systems (outage and non-outage)

will be incorporated

into procedures.

d)A thorough one-time surveillance

of areas inside and outside of the Protected Area (laydown areas, storage areas, buildings, and other areas)is being performed to identify contaminated

material which may have come from secondary systems or contaminated

material released from the RCA.The surveillance

was started in August 1997.Because of the size of the site (approximately

3300 acres), 1)areas most likely to contain improperly

released contaminated

material are being surveyed first, and 2)the surveys of the low probability

areas will be completed by March 1, 1998.e)Health Physics will evaluate the quarterly clean area surveys for potential improvements

in the instrumentation

and procedure.

This will include evaluating

the use of the Micro-R meter or other suitable instruments

for detecting low level sources at a distance.f)The effectiveness

of these actions will be monitored during the upcoming year to verify that radioactive

material controls on secondary systems are appropriate

and secondary controls are followed by all plant personnel.

The date when full compliance

was or will be achieved Although no contaminated

items are presently known to be outside the Turkey Point Protected Area, FPL will not consider Turkey Point to be in full compliance

until the completion

of the one-time site surveillance

described in 4d above, by March 1, 1998.

0

Attachment

to I.-97-283 Page 7 Seconrl Evan<pie: Teniperalrrre

gauge Response to violation:

FPL concurs with the finding.The following additional

information

is provided: a)Our records indicate that the temperature

gauge was last issued in 1994 with a 6 month calibration.

The gauge was contaminated

only with Cobalt 60.The absence of Cobalt 58 indicates that the gauge was not contaminated

recently.The gauge could have been released from the RCA several years ago although we could not determine the actual date of release.A survey of the temperature

gauge using hand held friskers indicated 100 to 250 cpm above background, which is equivalent

to approximately

1000 to 2500 dpm.b)Due to the small amount of purple coloring, and the presence of other colors of paint (yellow and white)on the temperature

gauge's magnets, it is not believed that the temperature

gauge was ever part of the purple tool program at Turkey Point.The purple coloring may have adhered to the magnets incidental

to the gauge's use in the plant.c)The temperature

gauge found on September 18, 1997 was brought back into the RCA and checked for contamination

because the Radiation Protection

Technician

had recently received training on FPL Information

Bulletin 97-37 (August 21, 1997)and Training Brief II692 (August 22, 1997).This training had been done by FPL to heighten awareness of all site personnel concerning

the events surrounding

the Steam Bypass Valve actuators found in the Training Building on August 11, 1997.A condition report was immediately

initiated and the event was thoroughly

investigated.

2.Reason for violation:

Items in Turkey Point's"purple tool" program are normally spray painted.Measuring and test equipment is normally not included, particularly

when the paint could interfere with the proper function of the equipment as would be the case with the bi-metal coil on the back of a contact temperature

gauge.The Radiation Protection

technician

who picked up the gauge in the parking lot near the Training Building inspected it closely and noticed the small amount of purple coloring on the magnets.The"purple paint" found on the magnets of the temperature

gauge was not obvious unless closely examined and no evidence of overspray existed.It is not clear that the purple substance on the gauge magnets was paint;it is similar in color to dye penetrant used for non-destructive

testing (liquid penetrant testing).

Attachment

to L-97-283 Page 8 The temperature

gauge was placed in the Small Articles Monitor (SAM-9)and contamination

was detected.With a standard HP-210 pancake GM probe the temperature

gauge contamination

measured approximately

1000 to 2500 dpm, and consisted of fixed activity much smaller than the probe area (two half-inch diameter magnets).Isotopic analysis identified

only Co-60 (with no Co-58)which was not indicative

of the isotopic mixture present during outages.The isotopic activity measurement

was 2900 dpm which is in good agreement with the pancake GM measurement.

Lack of detection of Co-58 is indicative

of contamination

that is approximately

two years old or more.Further investigation

revealed that temperature

gauge 8 92-033 has been identified

as belonging to FPL's Nondestructive

Examination

Metallurgical

Facility in Riviera Beach.Temperature

gauge 892-033 was last calibrated

on August 21, 1992, and calibrations

of these temperature

gauges are only good for 6 months.Instruments

are not signed out of the lab at Riviera Beach which makes it impossible

to find out to whom it was last checked out.Currently, these same type gauges are routinely used by the Turkey Point Inservice Inspection (ISI)Group, to document temperature

conditions

for piping and components

to assure they are within the procedural

requirements

for their tests.Due to the lack of significant

rust and the functioning

of the gauge, FPL concluded that the gauge had not been outside in the elements for long.Interviews

with all personnel involved were unsuccessful

in determining

how or when the temperature

gauge came to be in the parking lot.No evidence could be found showing when or if this temperature

gauge had b<en released from Turkey Point's RCA.To be conservative

however, we are assuming that this temperature

gauge was released from the RCA via one of three scenarios:

a)The gauge was contaminated

a number of years ago (most likely in the 1992/1993 timeframe, based on the Juno Beach records)and was taken out of the RCA at that time in a person's pocket via the PCM-IB and not detected.b)The gauge was contaminated

a number of years ago (as above)and was taken out of the RCA at that time, either in a person's pocket or in a toolbox via hand frisking with a standard pancake GM probe.The gauge was not detected during a survey of the person or the tools due to the low level of the contamination (well below 5000 dpm)combined with the motion of the standard HP-210 probe.Studies have shown that items less than 5000 dpm may go undetected

using the type of GM detector that FPL used prior to July 1997 (NRC Circular 81-07).c)The gauge was contaminated

a number of years ago (as above)and was taken out of the RCA more recently in a person's pocket while exiting through a PCM-1B.The PCM-1B will not reliably detect activity well below 5000 dpm particularly

if

Attachment

to L-97-283 Page 9 the article is in someone's pocket, as the monitors use beta detectors.

FPL believes that this is the least likely scenario due to the age of the expired calibration.

FPL does not believe that the causes of this event are similar to the previous events in that this component was not a purple painted tool and was most likely released from the RCA prior to the previous events.A review of these previous events did not disclose any information

that would have enabled FPL to prevent this event.Corrective

actions from the previous events and the Main Steam Bypass Valve actuators event were responsible

for the heightened

awareness of our Radiation Protection

Technician

who found and returned the gauge.Corrective

steps which have been taken and the results achieved: a)The contaminated

gauge was immediately

controlled

by Radiation Protection.

b)The parking lot and adjacent areas were searched and surveyed revealing no additional

contaminated

material.c)The ISI Group equipment storage area was surveyed with no additional

contaminated

material found.d)A thorough survey of the training building shop and storage areas was performed.

No additional

contaminated

material was found.(This action had been initiated from the MOV actuator event.)e)Procedure O-HPS-21.3, Release of Material from the Radiation Controlled

Area, was revised to clarify and strengthen

radioactive

material release surveys and documentation.(This action had been initiated from the MOV actuator event.)f)Information

Bulletin 97-37, Control of Licensed Material, was distributed

to all departments

on August 21, 1997.(This action had been initiated from the MOV actuator event.)g)Training Brief 8692 entitled"Control of Licensed Material" was issued to Radiation Protection, Operations, and contract HPs on August 22, 1997.(This action had been initiated from the MOV actuator event.)h)'tate-of-the-art

Small Articles Monitors and large area scintillation

probes were put into use in May and June 1997, which improve our capability

for detection of contaminated

material over the traditional

pancake GM detector friskers.

Attachment

to L-97-283 Page 10 i)In addition to the plant management

investigations, a corporate security investigation

was conducted involving the contaminated

gauge.The corporate security investigation

failed to develop any substantive

evidence to indicate that anyone intentionally

placed the contaminated

gauge outside the Protected Area.Corrective

actions which will be taken to prevent further violations:

a)A thorough one-time surveillance

of areas inside and outside of the Protected Area is being done to identify contaminated

material which may have come from secondary systems or contaminated

material released from the RCA.The surveillance

was started in August 1997.(This action was initiated from the MOV actuator event.)b)The main FPL control point area is being remodeled and stafFed to increase Radiation Protection

oversight of survey and release of personnel and material from the RCA.The plans include a central island for the Radiation Protection

personnel to directly monitor personnel entering and leaving the RCA.A free release survey area is incorporated

to provide an improved work area for surveys of material to be released.c)Control of material release will be strengthened

at the Turbine Building RCA control point.This will be accomplished

by additional

training of the personnel authorized

to use this control point, and installation

of video and two-way communication

capability

with the Radiation Protection

personnel at the main control point.d)An enclosed building is being procured, and will be constructed

at the alternate material release area (" Gate 50")exiting the RCA to improve the quality of this work area for Radiation Protection

release surveys of large equipment and components.

The building will provide improved lighting, weather protection, and air conditioning

in order to better support the free release survey function.The date when full compliance

was or will be achieved: Although no contaminated

items are presently known to be outside the Turkey Point Protected Area, FPL will not consider Turkey Point to be in full compliance

until the completion

of the one-time site surveillance

described in 4a above, by March 1, 1998.

I

Attachment

to L-97-283 Page Il FINDING 8 B."Turkey Point Facility Operating License Condition L, Amendment 193 (Unit 3)and Amendment 187 (Unit 4), dated February 11, 1997, state in part that the licensee shall fully implement and maintain iii effect all provisions

of the Commission-approved

Physical Security Plan.The licensee's

Physical Security Plan, Revision 10, dated May 19, 1997.states,'Unescorted

access to the Protected Area is granted to persons who have a work related need for entry.'ontrary

to the above, the licensee continued to grant unescorted

access to a terminated

employee frotn June 18, 1997, to August 5, 1997, who no longer had a work related need for entry." The individual

was authorized

access to the Protected Area only;however, no entries were made during the 47 days following termination.

This is a Severity Level IV violation (Supplement

III)." RE PONSE TO FINDIN B 1.Florida Power&, Light Company (FPL)concurs with the finding.2.Reason for the violation:

The investigation

revealed that the contractor

employee had favorably resigned from his company on June 18, 1997.His last access to the site was on June 12, 1997.The Chemistry Supervisor

signed off on his 31 Day Review for June, on June 17, 1997, prior to the individual's

resignation.

Therefore, the contractor

employee was still employed when the Chemistry Supervisor

signed off on the 31 Day Review.During the month of July, the 31 Day Review process and the Contractor

Fitness for Duty Verification

packages failed to identify the contractor

employee's

resignation.

From the Contractor

Fitness for Duty Verification

package signed and dated July 30, 1997, it is evident that a contractor

representative

confirmed that the individual

still required access.The Chemistry Supervisor

had signed off on the 31 Day Review for July, on July 31, 1997.At this point-the Chemistry Superviso~

did not recall seeing the contractor

employee recently, and asked another Chemistry department

individual

to verify employment

of the contractors.

The individual

from the Chemistry department

that was asked to verify employment

was informed that the contractor

employee in question had resigned on June 18, 1997.The Chemistry department

individual

turned in the paperwork to terminate the access on August 5, 1997.At that time, the contractor

employee's

access was,terminated.

Attachment

to L-97-283 Page 12 In order to determine reportability, the individual's

access was reviewed to see if he had gained entry into the plant following his resignation.

A review of the security printout showed that he had not gained entry following his resignation.

The contractor

also followed up with a confirmation

letter.Following the event, a Security Information

Report was completed.

3.Corrective

steps which have been taken and the results achieved: a)Immediately

upon notification

on August 5, 1997, the individual's

access was terminated.

b)FPL reviewed all employee access authorizations

at the site;for individuals

whose badges are not required and have not been used in the last 30 days, their access levels were suspended.

Access is not restored until all requirements

for access are satisfied and access is authorized

by the supervisor.

c)FPL has developed a Security Department

Badge Usage surveillance

on all badges.The surveillance

reviews all badge usage to identify badges not used in the last 30 days.d)The 31 Day Review printout has been revised to display the individual's

date of last use.This data aids supervisors

in their determination

of the need for continued access.e)The Chemistry Supervisor

and the other Chemistry department

individual

were counseled on their duties and responsibilities

with respect to access authorization.

f)The contractor

was contacted by FPL and has accepted responsibility

for inappropriately

including his terminated

employee on the Contractor

Fitness For Duty Verification

package signed July 30, 1997.The contractor

has provided written corrective

actions to FPL, including a second review of their future verifications.

4.Corrective

actions which will be taken to prevent further violations:

a)An FPL policy has been developed to ensure all FPL personnel are aware of the badging requirements.

Site personnel are being trained on the new Policy.

Attachment

to L-97-283 Page 13 b)The quarterly Contractor

Fitness for Duty Verification

Package has been revised to clarify badging requirements, and will be sent to the contractors

during the next quarter.c)Standard Terms and Conditions

for contracts have been revised to include more stringent requirements

for contractors

on badge deactivation, and will be sent to all contractors.

These revisions include requirements

to immediately

notify Turkey Point Security if an employee is terminated, is arrested, or has not been under the observation

of a supervisor

for the last 30 days.The revisions also include monetary penalties for failure to comply with the requirements.

5.The date when full compliance

was or will be achieved: Full compliance

was achieved on August 5, 1997, when the contractor

employee's

access was terminated.