ML080630669

Annual Assessment Letter (NRC Inspection Report 05000250/2008001 and 05000251/2008001)

ML080630669
Person / Time
Site:	Turkey Point
Issue date:	03/03/2008
From:	James Shea Division Reactor Projects II
To:	Stall J Florida Power & Light Co
References
IR-08-001
Download: ML080630669 (9)

See also: IR 05000251/2008001

Text

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.