ML18227B579
| ML18227B579 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 06/14/1974 |
| From: | Adomat E Florida Power & Light Co |
| To: | Moseley N US Atomic Energy Commission (AEC) |
| References | |
| RO:II:RCL 50-250/74-4 | |
| Download: ML18227B579 (13) | |
Text
P.o. BOX 3100 MIAMI, FLORIDA 33101 FLORIDA POWER 8I LIGHT COMPANY June 14, 1974 .
Mr. Norman C. Moseley, Director Directorate of Regulatory Operations Region II Suite 818 230 Peachtree Street, N. W.
Atlanta, Georgi a 30303
Dear Mr. Moseley:
Re: Turkey Point Units 3 6 4 RO:II:RCL 50-251/74-4 & 50-250/74-4 In our letter to you dated May 30, 1974, we submitted a response to your letter of April 26, 1974, which reported the findings of an inspection carried out by Messrs. Lewis, Upright and Cantrell. Through discussions with you and your staff on June 10, ll and 12, we now have a better under-standing of your concerns about the implementation of our management control systems that permitted deficiencies to occur. Consequently, we are resub-mitting our response to your letter of April 26 with major revisions which more clearly describe those actions taken and planned to improve the effec-tiveness of our management control systems for Turkey Point. This letter will be amplified by a subsequent. submittal not later than June 21 which will describe action being taken to correct specific deficiencies identified by your inspectors. Please disregard our May 30 letter in its entirety.
With reference to your findings regarding the CNRB, we acknowledge the defi-ciencies reported, and the CNRB is now operating in full compliance with the Technical Specifications in accordance with the interpretation of your inspectors. To assure that the CNRB continues to operate in full compliance with the Technical Specifications, we have established a full time staff position af Executive Secretary of the CNRB. The Executive Secretary reports to the Chairman of the CNRB. His principal responsibilities, include:
(a) Revise the CNRB charter, as necessary, and prepare detailed implementing procedures governing the activities of the CNRB.
(b) Assist the Chairman in planning and preparing for CNRB meetings.
Such assistance will include gathering and disseminating to the members data pertinent to agenda items. For complex technical subjects requiring a decision by the CNRB, arrange for a pre-sentation and recommeridation by a qualified person or subcommittee .
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Mr. Norman Moseley June 14, 1974 I
I (c) Attend meetings of the Turkey Point PNSC and maintain a file on all PNSC transactions. Initially, this activity will be for approximately 100% attendance at the meetings and provide an independent review and verification of the documentation needed to process changes. The results of this review. will be presented to the CNRB prior to approval. Later, at the dis-cretion of the CNRB the frequency of this activity may be reduced.
(d) Maintain a file on all CNRB transactions.
(e) Participate in an annual audit of'he FPL Quality Assurance Department and present the results of the findings to the CNRB.
Effective June 1, 1974, Mr. N F. Ajluni has been assigned the responsibility
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of Executive Secretary to the CNRB. Mr. Ajluni has a BS in Mechanical Engi-neering and 26 years of engineering experience. Prior to joining FPL, Mr.
Ajluni was Manager of Quality Systems for the General Electric Company. His prior position at FPL was Assistant Manager of Quality Assurance for System Development where he made a major contribution to the updating of the FPL QA Program to make it consistent with the latest AEC requirements. Mr. Ajluni will work full time as Executive Secretary to the CNRB.
To maintain the strong QA System Development effort initiated by Mr. Ajluni we have appointed Mr. J. E. Vessely to the positi'on of Assistant Manager of Quality Assurance for System Development. Mr. Vessely has a BBA in Industrial Engineering and Management and 22 years of experience. Prior to joining FPL, Mr. Vessely was Manager of the Washington, D. C. Program Office for the General Electric Company where he was Program Manager for the following types of pro-grams: Quality and Reliability, Configuration Control, Data Management, Information Systems.
Since the Quality Assurance area was essentially in compliance, each individual violation has been treated on a case by case basis. The information to be provided by June 21 will treat each QA violation (paragraph I.A.2. f(2), I.A.2. f.
(3), I.A.2.g(l), I.A.2.g.(2) and I.A. 3.b.) individually and will describe the action being taken to assure. full compliance with pertinent. requirements. Full compliance with the procedures required to correct the QA violations will be achieved by June 30, 1974.
In view of the extensive findings of your inspectors we are in the process of reviewing the implementation of our management control systems that permitted these deficiencies to occur. Ãe have taken the following action to improve the effectiveness of our management control systems:
(a) Group Vice President L. C. Hunter, who is responsible for the operating plants, is giving this matter his personal attention.
(1) He has had several meetings with personnel from the QA Department to gain a thorough understanding of manage-ment performance at Turkey Point. relative to the requirements of the operating license'.
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Mr. Norman C. Mosel
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(2) He has met with the Plant Manager and the Plant Super-intendent Nuclear at Turkey Point to gain an under-standing of the best way to apply corporate resources to improving, plant management.
(3) He has met with the Director of Power Resources and the Manager of Power Resources Nuclear to stress that it is the objective of FPL top management to operate the nuclear plants in full compliance with the requirements of the operating license and to dis-cuss the most effective means for accomplishing this objective at Turkey Point.
(b) The Quality Assurance Department with assistance from the Turkey Point Quality Control Coordinator has presented two series of three 2-hour lectures on 10 CFR 50 Appendix B, the FPL QA Pro-gram and relevant plant procedures. These lectures were presented at Turkey Point and 31 supervisory plant personnel attended.
(c) Nine supervisory plant personnel attended a Quality Assurance Workshop held in Miami on May 6-10, 1974. Five attended the full week and four attended the first two days. A total of 87 persons from FPL attended the first two days which included discussions of the FPL QA Program and the AEC "Orange Book" on Operations QA. On the first day of the meeting Executive Vice President E. A. Adomat discussed top management's role in Quality Assurance. A copy of his speech is attached.
Over the next few weeks the following specific actions will take place to im-
'prove the effectiveness of our management.'control systems for the plant:
(a) On or before July 1, 1974, Group Vice President L. C. Hunter will meet with the Turkey Point Supervisory personnel to explain that the FPL Corporate position is to operate the plant in full compliance with the requirements of the operat-ing license.
(b) The Manager of Power Resources Nuclear, H. J. Dager, will spend at least 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s/week at the Turkey Point Plant from June 17 until July 15 to determine what caused the defi-ciencies identified by the inspectors. At the conclusion of his study Mr. Dager will present recommendations to FPL top management on organizational restructuring, additional personnel requirements, and specific needs for support from the Corporate technical staff.
Mr. Norman C. Moseley June 14, 1974 We trust that this response demonstrates that the Florida Power and Light Company is taking appropriate action to improve the effectiveness of our management control systems. Although there were some differences of opinion regarding the interpretation of the Technical Specifications which led to some of the deficiencies cited by the inspectors, we will accept and abide by the interpretation of the inspectors until such time as revisions to the Technical Specifications are obtained in accordance with procedures provided in the Federal Regulations.
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Sincere y E. A. Adomat Executive Vice President EAA/RGC:ns Attachment cc: Mr. Jack R. Newman Dr. R. E. Uhrig
UALITY ASSURANCE WORKSHOP TOP MANAGEMENT<S ROLE IN FLORIDA POWER & LIGHTsS QUALITY ASSURANCE PROGRAM l.
E. A; ADOMAT The group today is primarily concerned with the Quality Assurance of nuclear power. Florida Power 6 light is in what I would call the second phase of our involvement with a formalized approach to Quality. Assurance. Our initial phase started approximately 20 months ago'ith the Quality Assurance organization under Joe Williams.. We have come a long way. There is no debate as to the contribution Quality Assurance can make in achieving and maintaining the neces-sary and desired safety and reliability of nuclear plants. I shall assume that we all agree on this point and that it needs no 'further elaboration. Top Manage-ment feels so strongly about this contribution that additional steps of broad-ening our Quality Assurance Programs to the rest of the operating plants are in the planning and formalizing stage. Fossil plants will have a Quality Assurance Program initiated in 1975 which will then be followed by transmission. and distri-bution Quality Programs. I When the need for a formalized Quality .Assurance Program became evident, we had to determine the goals of the program. As I see it, the goals of Quality Assurance can very simply be stated as safety, reliability and economy. We must assure that all of the systems of a nuclear plant will operate as they are supposed to do.
We also must assure that we operate these systems as they are designed to be
. operated. This will provide predictable performance and maximize our ability to provide electric energy to our customers.
'In the operation of our conventional plants, safety of our employees and of the equipment is all we need consider. Safety has taken on a completely new dimension
'in the operation of nuclear plants. In the nuclear plant this must be broadened to include the general public.'
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Operating delays and outages that are due to deficiencies in equipment, construc-
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tion, maintenance, 6r incorrect operation are not only .costly to us and our customers, but also can jeopardize the power supply of the entire region. The cost of replacement power for just. one unit assuming that such replacement power is available runs in excess of, $ 100,000 per day. The only way to control these costs is through effect'ive management, supported by a viable Quality Assur-ance Program. Quality Assurance must be implemented beginning with site invest-igation and continue through the operating life of the plant.
While the methods of achieving Quality Assurance may vary, it is readily apparent
~ that, there must be a formalized organization with written procedures that neces-sarily include extensive documentation. This requires that there be peisonal commitment to the philosophy of Quality Assurance by all levels of management.
This commitment must be regularly .communicated to all levels of the organization to obtain the team effort that is required for implementation. All of the indi-viduals on the team whether they be mechanics, electricians, operators, tech-nicians, engineers, foremen or
~ managers - need to understand that Quality Assur-ance is a program carefully designed to assist them in achieving a necessary and worthwhile goal. Fully supporting and carrying out the program is the only way an individual can do a satisfactory job.
Basic'uality responsibility rests in the hands of the company's top management.
In present-day industry, the job of total Quality Assurance cannot be effectively pursued with quality responsibility for the company's various operational elements because they are so widely separated. There must be an associated mechanism to assist in the integration and measuring these responsibilities. In the large companies where top management cannot by itself act as such a mechanism, manage-ment establishes an organizational component, as the pivotal point of its quality assurance organization to provide the required integration and control.
Bob Cockrell's Quality Assurance Department is Florida Power 6 Light's pivotal C
point for Quality Assurance. The creation of this Quality Assurance Department does not relieve other departments of'their delegated quality responsibilities, for the discharge of which they are best qualified.
Integration is accomplished by a common Quality Assurance Program, in the form oi our. manual. Each department has a Quality Assurance 'function coordinated with the Quality Assurance Department and other xelated departments. The control from the company's standpoint is our Quality'Assurance Department's audit and surveillance groups. The Quality Assurance Department reports through a separate organizational channel to top management, and has the responsibility of auditing and reporting to top management the performance 'of the various departments and operating plants. It thus provides the core of the organizational pattern for making effective the total quality assurance technological framework.
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I would be less than candid if I did not admit that our company's desire to establish 0 and implement a comprehensive Quality Assurance Program was sparked by the AEC requirements. However, we have come to realize that this really need not be a burden thrust upon us. Instead it can be an effective tool to assist ua to carry out our responsibilities to the public, to our stockholders, and to our. employees.
'C the beginning, I mentioned what I believe are three broad goals of Quality Assurance.. They were: safety, 'reliability and economy. What am I going to look for in performance to know that we are achieving these The following goals'actions are expected:
o Scientific Inspection Planning A o Promotion 'of Operator Enthusiasm for Quality Establishment of Good Vendor Relations I o Assurance that Quality is built into the plant and its operation
o Setting of the Quality Standard o Coordination of Quality Problems o Channeling of Quality Information through Organization o Measurement of Quality these actions will be measured with the following results:
o Xmprovement in Performance Quality o Improvement in Construction Design o Reduction in Operating Cost o Reduction in Operating Losses o Reduction in Construction Bottlenecks I
o Improvement in Enployees'orale o Improvement in AEC Evaluations Xn these times, electric utilities are involved in one rate case after another.
Cost control has always been a vital factor in our business, but now it is even more important than ever. The most expensive equipment we own is nuclear genera-tion equipment that is out of operation. A strong Quality Assurance Program is an effective means of minimizing this expense.
The final point X would make is that. we need to manage in a way that the public is aware of our Quality Assurance policies and practices. It is only human for people to fear the unfamiliar. And, unfortunately, not mahy people recognize that we in management are as deeply concerned with public safety as we are with reliability and economy.
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X believe that we should make broad sectors'f the general public aware of what we are accomplishing through Quality Assurance. And, I submit that such an aware-ness will translate into public acceptance, and to growing support for the fact that nuclear energy works'or the public good.
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