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 NRCs 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 examples 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 2nd and 3rd

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 3rd 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 3

familiarity 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 reviews 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 ARules 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 4

If 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 /RA/ /RA/

For/

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: Rajiv S. Kundalkar

William Jefferson, Jr. Vice President

Senior Vice President Nuclear Technical Services

Turkey Point Nuclear Plant Florida Power & Light Company

Florida Power and Light Company Electronic Mail Distribution

Electronic Mail Distribution

M. S. Ross

James Connolly Managing Attorney

Licensing Manager Florida Power & Light Company

Turkey Point Nuclear Plant Electronic Mail Distribution

Florida Power and Light Company

Electronic Mail Distribution Marjan Mashhadi

Senior Attorney

Don E. Grissette Florida Power & Light Company

Vice President Electronic Mail Distribution

Nuclear Training and Performance

Improvement William A. Passetti

Florida Power & Light Company Bureau of Radiation Control

Electronic Mail Distribution Department of Health

Electronic Mail Distribution

Michael O. Pearce

Plant General Manager Alejandro Sera

Turkey Point Nuclear Plant Emergency Management Coordinator

Florida Power and Light Company Miami-Dade County

Electronic Mail Distribution Electronic Mail Distribution

Mark Warner Craig Fugate

Vice President Director

Nuclear Operations Support Division of Emergency Preparedness

Florida Power & Light Company Department of Community Affairs

Electronic Mail Distribution 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

Page 1 of 2 Turkey Point

03/03/2008 17:35:09 Inspection / Activity Plan

Report 22

03/03/2008 - 09/30/2009

Unit No. of Staff Planned Dates Inspection

Number Inspection Activity Title on Site Start End Type

EB3-ISI - U4 INSERVICE INSPECTION 1

4 IP 7111108P Inservice Inspection Activities - PWR 04/14/2008 04/18/2008 Baseline Inspections

PI&R - PREP TRIP-PROBLEM ID AND RESOL 1

3, 4 IP 71152B Identification and Resolution of Problems 04/28/2008 05/02/2008 Baseline Inspections

PSB1-RP - RADIATION PROTECTION-ACCESS CONTROLS 1

3, 4 IP 7112101 Access Control to Radiologically Significant Areas 04/28/2008 05/02/2008 Baseline Inspections

3, 4 IP 7112103 Radiation Monitoring Instrumentation and Protective Equipment 04/28/2008 05/02/2008 Baseline Inspections

EB1-SUMP - TI 2515/166 CONTAINMENT SUMP INSPECTION 1

4 IP 2515/166 Pressurized Water Reactor Containment Sump Blockage [NRC GENERIC LETTER 2004-02] 05/05/2008 05/09/2008 Safety Issues

PI&R - PROBLEM IDENTIFICATION AND RESOLUTION 6

3, 4 IP 71152B Identification and Resolution of Problems 06/09/2008 06/13/2008 Baseline Inspections

3, 4 IP 71152B Identification and Resolution of Problems 06/23/2008 06/27/2008 Baseline Inspections

EB3TI172 - TI-172 2

3, 4 IP 2515/172 Reactor Coolant System Dissimiliar Metal Butt Welds 06/16/2008 06/20/2008 Generic Safety Inspectio

TI-171 - B.5.B PHASE 2&3 3

3, 4 IP 2515/171 Verification of Site Specific Implementation Of B.5.b Phase 2 & 3 Mitigating Strategies 07/28/2008 08/01/2008 Generic Safety Inspectio

EB1-CDBI - COMPONENT DESIGN BASIS INSPECTION 9

3, 4 IP 7111121 Component Design Bases Inspection 08/25/2008 08/29/2008 Baseline Inspections

3, 4 IP 7111121 Component Design Bases Inspection 09/08/2008 09/12/2008 Baseline Inspections

3, 4 IP 7111121 Component Design Bases Inspection 09/22/2008 09/26/2008 Baseline Inspections

3, 4 IP 7111121 Component Design Bases Inspection 10/06/2008 10/10/2008 Baseline Inspections

OL EXAM - INITIAL EXAM PREP 3

3 V23299 TURKEY POINT/FEBRUARY 2009 EXAM AT POWER FACILITIES 02/02/2009 02/06/2009 Not Applicable

PSB1EP - EP EXERCISE 3

3, 4 IP 7111401 Exercise Evaluation 02/16/2009 02/20/2009 EP Baseline Inspection

3, 4 IP 7111404 Emergency Action Level and Emergency Plan Changes 02/16/2009 02/20/2009 EP Baseline Inspection

3, 4 IP 71151-EP01 Drill/Exercise Performance 02/16/2009 02/20/2009 Baseline Inspections

3, 4 IP 71151-EP02 ERO Drill Participation 02/16/2009 02/20/2009 Baseline Inspections

3, 4 IP 71151-EP03 Alert & Notification System 02/16/2009 02/20/2009 Baseline Inspections

OL EXAM - INITIAL EXAM 3

3 V23299 TURKEY POINT/FEBRUARY 2009 EXAM AT POWER FACILITIES 02/23/2009 03/06/2009 Not Applicable

EB3ISI - UNIT 3 ISI 1

3 IP 7111108P Inservice Inspection Activities - PWR 03/16/2009 03/20/2009 Baseline Inspections

PI&R - PROBLEM IDENTIFICATION AND RESOLUTION 5

3 IP 71152B Identification and Resolution of Problems 05/18/2009 05/22/2009 Baseline Inspections

This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

Page 2 of 2 Turkey Point

03/03/2008 17:35:09 Inspection / Activity Plan

Report 22

03/03/2008 - 09/30/2009

Unit No. of Staff Planned Dates Inspection

Number Inspection Activity Title on Site Start End Type

PI&R - PROBLEM IDENTIFICATION AND RESOLUTION 5

3 IP 71152B Identification and Resolution of Problems 06/01/2009 06/05/2009 Baseline Inspections

OL EXAM - INITIAL EXAM PREP 3

3 V23313 TURKEY POINT/AUGUST 2009 EXAM AT POWER FACILITIES 07/27/2009 07/31/2009 Not Applicable

OL EXAM - INITIAL EXAM - WEEK 1 3

3 V23313 TURKEY POINT/AUGUST 2009 EXAM AT POWER FACILITIES 08/17/2009 08/21/2009 Not Applicable

OL EXAM - INITIAL EXAM - WEEK 2 3

3 V23313 TURKEY POINT/AUGUST 2009 EXAM AT POWER FACILITIES 08/31/2009 09/04/2009 Not Applicable

OL EXAM - INITIAL EXAM - WEEK 3 3

3 V23313 TURKEY POINT/AUGUST 2009 EXAM AT POWER FACILITIES 09/14/2009 09/18/2009 Not Applicable

This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.