ML080630669: Difference between revisions

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{{Adams
#REDIRECT [[IR 05000250/2008001]]
| number = ML080630669
| issue date = 03/03/2008
| title = Annual Assessment Letter (NRC Inspection Report 05000250/2008001 and 05000251/2008001)
| author name = Shea J
| author affiliation = NRC/RGN-II/DRP
| addressee name = Stall J
| addressee affiliation = Florida Power & Light Co
| docket = 05000250, 05000251
| license number = DPR-031, DPR-041
| contact person =
| document report number = IR-08-001
| document type = Inspection Report, Letter
| page count = 9
}}
See also: [[see also::IR 05000251/2008001]]
 
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II SAM NUNN ATLANTA FEDERAL CENTER  61 FORSYTH STREET, SW, SUITE 23T85 ATLANTA, GEORGIA  30303-8931
  March 3, 2008
Florida Power and Light Company ATTN: Mr. J. A. Stall, Senior Vice President
Nuclear and Chief Nuclear Officer P. O. Box 14000
Juno Beach, FL 33408-0420
  SUBJECT: ANNUAL ASSESSMENT LETTER - TURKEY POINT NUCLEAR PLANT (NRC INSPECTION REPORT 05000250/2008001 AND 05000251/2008001)
Dear Mr. Stall:
 
On February 7, 2008, the NRC staff completed its performance review of the Turkey Point
 
Nuclear Plant.
  Our technical staff reviewed performance indicators (PIs) for the most recent quarter and inspection results for the period from January 1 through December 31, 2007.  The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility.
 
This performance review and enclosed inspection plan do not include security information.  A separate letter designated and marked as "Official Use Only--Security Information" will include the security cornerstone review and resultant inspection plan.
Overall, Turkey Point Units 3 and 4 operated in a manner that preserved public health and
safety and fully met all cornerstone objectives.  Plant performance for Turkey Point Unit 3 was within the Licensee Response Column of the NRC Action Matrix for the last two quarters of CY 2007 and within the Regulatory Response Column for the first two quarters of CY 2007,
because of a single White inspection finding in the Initiating Events cornerstone, originally
identified during the third quarter of 2006.  This White finding was associated with a loss of
decay heat removal capability during a period of reduced reactor coolant inventory which reflected performance at a level requiring increased regulatory response.  Therefore, in addition to the reactor oversight process baseline inspection program, a Supplemental Inspection using Inspection Procedure (IP) 95001, "Inspection for One or Two White Inputs In a Strategic
Performance Area," was conducted during the week of April 9, 2007, and no findings of
significance were identified.
FP&L 2  Plant performance for Turkey Point Unit 4 for the most recent quarter as well as the previous
three quarters was within the Licensee Response Column of the NRC's Action Matrix, based on
all inspection findings being classified as having very low safety significance (Green) and all PIs indicating performance at a level requiring no additional NRC oversight (Green). 
 
Additionally, in our mid-cycle assessment letter dated August 31, 2007
, we advised you of the continuation of a substantive cross-cutting issue in the problem identification and resolution area involving weaknesses in the thorough evaluation of identified problems (P.1.c).  The end-of-
cycle assessment of this cross-cutting issue included a review of inspection results over the 12-
month period from January 1 through December 31, 2007. 
 
During this period, the inspectors reviewed licensee improvement initiatives and noted some improvements.  A focused inspection to evaluate the effectiveness of your corrective action program (CAP) improvement initiatives was completed on December 17, 2007.  There were no new inspection findings identified during this review.  The inspection team noted that you had recently implemented a pilot process, in November 2007, to aid in reducing the backlog and improving the timeliness and quality of condition reports (CR).  The team also found that you had completed your analysis of the most recent safety conscious work environment (SCWE) and site culture surveys, had identified areas needing improvement, and had scoped and planned actions to address these identified issues.  The team also highlighted key planned
activities such as the addition of a new CAP improvement management team in January 2008
and the planned conversion of your work processes to the Passport System in 2009.  These new initiatives were recognized as positive moves to address the identified weaknesses.
The inspection team also documented five exampl
es where important corrective actions to prevent recurrence (CAPRs) had not been fully implemented to address weaknesses
associated with CR 2006-25531, which addressed the substantive cross-cutting issue identified in 2006.  These corrective actions had not been completed, partly due to the large number of changes made to the CAP improvement plan and
the Turkey Point "Road to Excellence Plan" which appeared to place more emphasis on CAP backlog reduction and not the corrective
actions to address the PI&R substantive cross-cutting issue from 2006. 
 
In one instance, the team identified that required periodic reviews of trend reports by the newly established condition report oversight group (CROG) had not been performed during 2
nd and 3 rd quarter 2007, resulting in a missed opportunity for the CROG to identify that certain department
level performance monitoring groups (Corrective Action Review Boards - CARBs) had failed to
submit completed trend reports because of competing priorities and other routine job activities
(especially, the impact of a 3
rd quarter refueling outage). 
In a second instance, it was noted that considerable turnover within the initial group of corrective
action program coordinators (CAPCOs).  Only thirteen of the initial twenty-three CAPCOs
remained.  CAPCOs are assigned to effectively monitor the CAP expectations for the departments and carry out specific duties aimed at reducing the backlog of work orders and
condition reports.  The inspectors noted multiple examples where selected CAPCOs had not completed formal training qualifications and, in other cases, the CROG had not completed a timely review and approval process for several recently qualified CAPCOs that were actively
attending and participating in meetings and perform certain condition report evaluations.  While
most of these CAPCOS had numerous years of nuclear industry experience, most had little 
FP&L  3familiarity with Turkey Point plant specific operation or knowledge of its programs and operating
history before being assigned.
The NRC has also identified more than three Green inspection findings with documented cross-
cutting aspects in problem identification and resolution and an increasing trend in the cross-
cutting theme of appropriate and timely corrective action (P.1.d).  This increasing trend indicates
that the underlying weaknesses within the PI&R cross-cutting area may not yet have been addressed or fully understood to assure consistent and sustainable future performance.  Based on these observations, the staff noted that sustained licensee progress will require continued
strong management involvement given the number of findings in the problem identification and
resolution
area.  Therefore, this cross-cutting issue will remain open. 
Since this is the fourth consecutive assessment letter identifying the same substantive cross-
cutting issue, the NRC would normally request that you conduct a safety culture assessment. However, we are aware that a safety culture survey was already completed at Turkey Point
during this assessment period.  Therefore, we request that you conduct an independent
assessment of the effectiveness of your implementation of key CAPRs and the causes behind the failure to complete required training for key individuals assigned responsibility to assess and recommend actions to resolve backlogged, longstanding issues at Turkey Point.  This
independent assessment should be conducted by individuals that are not associated with the
CAP at Turkey Point Nuclear Station or the FP&L corporate office.  We also request that you
provide the regional office with a schedule for completion of this evaluation, so that we may plan
and schedule a follow-up visit to evaluate the scope and results of your review. The NRC will also conduct additional onsite review
s within the upcoming assessment period to continue to evaluate the overall effectiveness of the newly implemented programs.  These evaluations will be conducted mainly during planned inspections scheduled for March and June
 
2008.
The enclosed inspection plan details the inspections, less those related to physical protection scheduled through September 30, 2009.  In addition to the ROP baseline inspections, we plan
 
to conduct several non-ROP inspections which include TI 2515/171, Verification of Site Specific (B.5.b) Phase 2 and 3 Mitigation Strategies*- and TI 2515/172, Reactor Coolant System 
 
Dissimilar Metal. 
 
The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of inspector arrival onsite.  Routine resident
inspections are not listed due to their ongoing and continuous nature.  The inspections in the
last nine months of the inspection plan are tentative and may be revised at the mid-cycle review. 
 
In accordance with 10 CFR 2.390 of the NRC
=s A Rules of Practice,@ a copy of this letter and its
enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
     
FP&L  4If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible.  Please contact Marvin Sykes at (404) 562-4629 with any questions you may have regarding this letter or the inspection plan.
Sincerely,    /RA By H. Christensen For/
  Joseph W. Shea, Acting Director              Division of Reactor Projects
 
Docket Nos. 50-250, 50-251
License Nos. DPR-31, DPR-41
Enclosure: Turkey Point Inspection/Activity Plan (03/01/08 - 09/30/09)
 
cc w/encl:  (See page 3)   
 
 
_________________________ OFFICE RII:DRP RII:DRP RII:DRP RII:DRP    SIGNATURE /RA/ /RA By MSykes
For//RA/ /RA/    NAME MSykes JHamman HChristensen JShea    DATE 3/3/08 3/3/08 3/3/08 3/3/08    E-MAIL COPY?    YES NO  YES NO  YES NO  YES NO  YES NO  YES NO  YES NO 
FP&L 5  cc w/encl: William Jefferson, Jr.
Senior Vice President
Turkey Point Nuclear Plant Florida Power and Light Company
Electronic Mail Distribution
 
James Connolly
Licensing Manager
Turkey Point Nuclear Plant Florida Power and Light Company
Electronic Mail Distribution
 
Don E. Grissette Vice President
Nuclear Training and Performance
Improvement
 
Florida Power & Light Company
Electronic Mail Distribution
Michael O. Pearce
 
Plant General Manager
 
Turkey Point Nuclear Plant
Florida Power and Light Company
Electronic Mail Distribution
Mark Warner
Vice President
Nuclear Operations Support
 
Florida Power & Light Company Electronic Mail Distribution
  Rajiv S. Kundalkar Vice President
 
Nuclear Technical Services
Florida Power & Light Company Electronic Mail Distribution
 
M. S. Ross
 
Managing Attorney
 
Florida Power & Light Company Electronic Mail Distribution
Marjan Mashhadi
 
Senior Attorney
 
Florida Power & Light Company Electronic Mail Distribution
William A. Passetti
Bureau of Radiation Control
Department of Health Electronic Mail Distribution
Alejandro Sera
Emergency Management Coordinator
Miami-Dade County
Electronic Mail Distribution
Craig Fugate
 
Director
Division of Emergency Preparedness
Department of Community Affairs Electronic Mail Distribution
Mano Nazar
Senior Vice President
  and Nuclear Chief Operating Officer
 
Florida Power & Light Company Electronic Mail Distribution
 
FP&L 6  Letter to J. A. Stall from Joseph W. Shea dated March 3, 2008
SUBJECT: TURKEY POINT - NRC INTEGRATED INSPECTION REPORT 05000250/2008 AND 05000251/2008
Distribution w/encl:
C. Evans, RII (Part 72 Only)
L. Slack, RII 
OE Mail (email address if applicable) RIDSNRRDIRS
INPO
ROP Reports
 
PUBLIC
B. Mozafari, NRR
 
Turkey Point
Inspection / Activity Plan
03/03/2008
-09/30/2009
Inspection
Type Inspection Activity
Planned Dates
Start          End
No. of Staff
on Site Title Unit Number Page 1 of 2
03/03/2008
17:35:09 Report 22 1 EB3-ISI-U4 INSERVICE INSPECTION
Baseline Inspections
Inservice Inspection Activities - PWR
04/14/2008
04/18/2008
      4 7111108P IP 1 PI&R-PREP TRIP-PROBLEM ID AND RESOL
Baseline Inspections
Identification and Resolution of Problems
04/28/2008
05/02/2008
    3, 4 71152B IP 1 PSB1-RP-RADIATION PROTECTION-ACCESS CONTROLS
Baseline Inspections
A ccess Control to Radiologically Significant Areas
04/28/2008
05/02/2008
    3, 4 7112101 IP Baseline Inspections
Radiation Monitoring Instrumentation and Protective Equipment
04/28/2008
05/02/2008
    3, 4 7112103 IP 1 EB1-SUMP-TI 2515/166 CONTAINMENT SUMP INSPECTION
Safety Issues
Pressurized Water Reactor Containment Sump Blockage [NRC GENERIC LETTER 2004-02]
05/05/2008
05/09/2008
      4 2515/166 IP 6 PI&R-PROBLEM IDENTIFICATION AND RESOLUTION
Baseline Inspections
Identification and Resolution of Problems
06/09/2008
06/13/2008
    3, 4 71152B IP Baseline Inspections
Identification and Resolution of Problems
06/23/2008
06/27/2008
    3, 4 71152B IP 2 EB3TI172-TI-172 Generic Safety Inspecti
o Reactor Coolant System Dissimiliar Metal Butt Welds
06/16/2008
06/20/2008
    3, 4 2515/172 IP 3 TI-171-B.5.B PHASE 2&3
Generic Safety Inspecti
o Verification of Site Specific Implementation Of B.5.b Phase 2 & 3 Mitigating Strategies
07/28/2008
08/01/2008
    3, 4 2515/171 IP 9 EB1-CDBI-COMPONENT DESIGN BASIS INSPECTION
Baseline Inspections
Component Design Bases Inspection
08/25/2008
08/29/2008
    3, 4 7111121 IP Baseline Inspections
Component Design Bases Inspection
09/08/2008
09/12/2008
    3, 4 7111121 IP Baseline Inspections
Component Design Bases Inspection
09/22/2008
09/26/2008
    3, 4 7111121 IP Baseline Inspections
Component Design Bases Inspection
10/06/2008
10/10/2008
    3, 4 7111121 IP 3 OL EXAM-INITIAL EXAM PREP
Not Applicable
TURKEY POINT/FEBRUARY 2009 EXAM AT POWER FACILITIES
02/02/2009
02/06/2009
    3 V23299 3 PSB1EP-EP EXERCISE
EP Baseline Inspection
Exercise Evaluation
02/16/2009
02/20/2009
    3, 4 7111401 IP EP Baseline Inspection
Emergency Action Level and Emergency Plan Changes
02/16/2009
02/20/2009
    3, 4 7111404 IP Baseline Inspections
Drill/Exercise Performance
02/16/2009
02/20/2009
    3, 4 71151-EP01
IP Baseline Inspections
ERO Drill Participation
02/16/2009
02/20/2009
    3, 4 71151-EP02
IP Baseline Inspections
A lert & Notification System
02/16/2009
02/20/2009
    3, 4 71151-EP03
IP 3 OL EXAM-INITIAL EXAM
Not Applicable
TURKEY POINT/FEBRUARY 2009 EXAM AT POWER FACILITIES
02/23/2009
03/06/2009
    3 V23299 1 EB3ISI-UNIT 3 ISI
Baseline Inspections
Inservice Inspection Activities - PWR
03/16/2009
03/20/2009
    3 7111108P IP 5 PI&R-PROBLEM IDENTIFICATION AND RESOLUTION
Baseline Inspections
Identification and Resolution of Problems
05/18/2009
05/22/2009
    3 71152B IP This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
Turkey Point
Inspection / Activity Plan
03/03/2008
-09/30/2009
Inspection
Type Inspection Activity
Planned Dates
Start          End
No. of Staff
on Site Title Unit Number Page 2 of 2
03/03/2008
17:35:09 Report 22 5 PI&R-PROBLEM IDENTIFICATION AND RESOLUTION
Baseline Inspections
Identification and Resolution of Problems
06/01/2009
06/05/2009
    3 71152B IP 3 OL EXAM-INITIAL EXAM PREP
Not Applicable
TURKEY POINT/AUGUST 2009 EXAM AT POWER FACILITIES
07/27/2009
07/31/2009
    3 V23313 3 OL EXAM-INITIAL EXAM - WEEK 1
Not Applicable
TURKEY POINT/AUGUST 2009 EXAM AT POWER FACILITIES
08/17/2009
08/21/2009
    3 V23313 3 OL EXAM-INITIAL EXAM - WEEK 2
Not Applicable
TURKEY POINT/AUGUST 2009 EXAM AT POWER FACILITIES
08/31/2009
09/04/2009
    3 V23313 3 OL EXAM-INITIAL EXAM - WEEK 3
Not Applicable
TURKEY POINT/AUGUST 2009 EXAM AT POWER FACILITIES
09/14/2009
09/18/2009
    3 V23313 This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
}}

Revision as of 20:00, 14 November 2019