3F0589-05, Comments on SALP Insp Rept 50-302/88-35.Major Areas in Engineering Organization Realigned & Improved Definition of Roles & Responsibilities within Areas Being Developed.Util Reemphasizing Team Concepts Throughout Nuclear Operations

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Comments on SALP Insp Rept 50-302/88-35.Major Areas in Engineering Organization Realigned & Improved Definition of Roles & Responsibilities within Areas Being Developed.Util Reemphasizing Team Concepts Throughout Nuclear Operations
ML20247D834
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 05/05/1989
From: Wilgus W
FLORIDA POWER CORP.
To: Ebneter S
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
3F0589-05, 3F589-5, NUDOCS 8905260011
Download: ML20247D834 (8)


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. Power C O R P O R A T 10 N i

May 05, 1989 3F0589-05 l

Mr. Stewart D. Ebneter Regional Administrator, Region II U. S. Nuclear Regulatory Ctanission 101 Marietta St. N. W., Suite 3100 Atlanta, GA 30323

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating Licensee No. DPR-72 Systematic Anwemant of Licensee Performance (SALP)

Inspection Report 88-35 l

Dear Sir:

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'1 Florida Power Corporation (FPC) is dedicated to the safe operation of Crystal River Unit 3 and to maintaining a strong safety culture throughout our FPC appreciates the significance of the SALP process and organization.

respects the criticism provided. We are also pleased that the areas of improved performance and continued good performance were recognized. Our overall performance was rated as satisfactory; however, we are ccanmitted to continually striving to inprove our performance and to resolving the concerns with technical support and supervisory review.

FPC has ftv' aced considerable attention to the engineering area. We recognized problems existed and had corrective actions underway or planned prior to the SALP report. '1he rating in this area was not unexpected.

Internally recognized weaknesses, confirmed by the Operational Safety Team Inspection (OSTI) and other inspections clearly indicated a need to perform an assessment of the technical sugaort area. 'Ihis encacemant has resulted in additional efforts to uLugthen specific areas through redirected and i additional resources. Major areas in the engineering organization have been I realigned and impmed definition of the roles and responsibilities within those areas are being developed. We are also re-emphasizing " Team" concepts thlughout Nuclear Operations. l l

1 8905260011 89050b l PDR ADOCK 05000302 Q PDC

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POST OFFICE BOX 219 + CRYSTAL RIVER, FLORIDA 32629-0219 + (904) 563-2943 g\ )

A Florida Progress Company L_ _ -- - - nu l

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Mr. Stewart D. Ibneter Regional. Administrator, Region II U. S. Nuclear Regulatory himion 3F0589 May 5, 1989 Page 2 Mr. B. L. Griffin, Executive Vice President, stated at the SAIP meetiry that FPC is ocmnitted to striving for higher ratings. We are actively perfonning assessments in eadi of the SAIP functional areas to identify and correct h and to identify and pursue opportunities to further enhance cur performance. We consider periodic self amammant - ntial to assuring the drive for inproved performance is not lost and does not sta.gnate. We are taking positive steps in each area that will help us achieve performance improvements. We recognize open, professional cxanunication with the NRC as another element in our ongoing efforts to achieve high levels of performance.

We feel considerable improvement has been made throughout the past SALP evaluation period, and we look forward to a continuation of this good ccaminication in the future.

Florida Power Corporation's detailed response to the category 3 area is provided in Attachment A. cu-c.uits on the remainder of the evaluation are provided in Attachment B. We look forward to di-=ing our progress with you in the near future.

Sincerely, AcnelG f

lWalterS. 11gus Vice President Nuclear Operations WSW/sdw Attachment I

ATTAQMENT A RESIUEE 'IO CATIDORY 3 RATING F. Ernineerirn/Tedinical Suogod; FPC management recognizes the ergineerlJg organization is not achieving a high level of quality performance on a consistent basis. Several prwtarus and initiatives to improve performance have been under development. %ese l irclude the Configuration Management Prwrmu, Ergineerirg Assurance, Design Basis Issue Resolution and System Engineering. Extensive resource i cmmitments have been made to these prograns ard they are beginning to ,

produce results. Recent fow1 hack frun the industry and through the SALP f have dumisdaated the need to go further ard to assess the role of ergineerire in the support of Crystal River Unit 3. mis n-c:mont has resulted in establishing a Design Basis Issue Resolution Project Team, initiatirg a review of the Envitumuital Qualification Fr%tmn, ard I establishire a prwrarn to set the expectations ard responsibilities for the Systems Ergineers.

We Configuration Management Pr@tain is urderway to capture, reconstruct ard document the design basis of the plant. m is program is established as a separate organization with dedicated TPC supervision. mis group is not effected by the design activities or day-to-day support of the plant. We objective of this program is to dwnant the design basis information, l provide the information in a readily retrievable for nat to those who need it, assure the physical plant conforms to the design basis, and to assure the plant procedures conform to the design basis.

l Nuclear Operations Engineering (NOE) has primary responsibility for the l resolution of design related questions ard the design of plant modifications. NOE controls the desigry' modification pzocess ard is accountable for design input ard assurirg the design solution resolves the problem effectively. Wey are also accountable to assure modifications are l fully implemented ard tested in accordance with the design includirg

! procedure cnanges, drawirg revisions, ard transfer of the final quality records to file.

f Site Nuclear Engineering Services (SNES) provides the day-to-day technical

! support to the plant. mis function includes the System Ergineer Program,

( Procurement Engineering, ard discipline engineering support for i modifications, technical problems, the Functional Test Pr@ tau, Post l Maintenance Test Frwsmu, ard the ASME Section XI Repair ard Replacement l Fr@tmu. Site Nuclear Services plays an important role in the operation of l CR-3 ard is intimately involved in all critical decisions of a technical j nature.

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We Design Basis Issue Resolution Project Team has been recently established. W e furction of this team is to deal with design basis issues l that cme up in any area. We team is composed of dedicated, disciplined engineers, a licensirg engineer, ard a safety analysis engineer. The team will receive potential design basis issues and be responsible for the initial nec:mont of safety significance, the preliminary evaluation for deportability, rw=nondirg any needed changes in operational node, ard sufficient technical review of the issue to determine alternatives for the ultimate resolution.

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L F. Erniriaarirn/Techrdrml 9wwwt (Ourtt'd)

Structuring the engineering support in this manner will provide effective technical support and contribute to enhanced interaction with the plant i

organizations. 'Ibe actions taken cbs==Luote management's intention to l

resolve the problems in this area.

FPC intends to arrange a meet ing with the NRC in June 1989 to discuss the details of our programs and the role of Engineering at CR-3.

N Training area continues to diss=Lcate a high level of performance which will be further enhanced by the sim21ator which will be operational in 1990.

e h SALP Report irmuuctly references SOTA problems with E0P's. The identified problem was with VP's (VP-540 and BP-580).

Nuclear Operations Training was not required to respond to a concern in NRC Report 50-302/88-09 where a reference was made to indication of insufficient training for SOIA's regarding VP-540 and VP-580. However, Nuclear Operations Training evaluates all training deficiencies and, in this case, the following actions were taken:

1. All SorA's were evaluated on shift by a qualified NSS or ANSS.
2. Training walk-thtughs on VP-540 and VP-580 were given to all SOTA's.
3. Lesson Plans covering these VP's were added to the initial SOIA curriculum.
4. An actual walk-through was orielari to the SOIA Job Performance Manual.

l 'Ihese actions were coupleted in Octcber of 1988.

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ATIMONENf B FPC QMENIS (N 1988 SAIP Overall Evaluaticn Florida Power Corporation (FPC) is in general agreement with the overall SALP ratings. FPC also appreciates the recognition by the NRC that many initiatives are uMerway to improve overall performance aM to correct the weaknesses identified. FPC is firmly ommitted to developing consistently high quality performance in all areas aM with identifying and resolving problems in an expeditious manner.

FPC is pleased that the NRC has noted the improvement in procedure adherence aM procedural adequacy. FPC has dedicated considerable resources to the issue and it continues to be an ama of sharp managemmt focus.

Supervisory responsibility ard involvement is an ama that FPC also believes is critical to safe, efficient operations. Immediate steps are being taken in several areas and management evaluation for longer term improvements is underway.

A. Plant Operations te six-shift rotation has made it possible to mduce overtime and allow an extra shift on duty during normal working hours. mis additional availability of licensed operators has improved work flow throughout Nuclear Operations. he shift team concept for operations was also implemented during this SALP period. Continued improvement in operations is expected from these changes and as the newer operators hu- more experie: red.

We Operations staff has shown initiative in the development of operator professionalism. Rese efforts will continue to be encouraged by management. Efforts am underway to exterd these initiatives and to enhance the professional environment in which our training is done.

FPC took immediate steps to resolve the concerns with the EOP's identified by the E0P inspection. We are also participating with the B&W Owners Group to address discrepancies with technical content. We plant specific simulator, which will be operational next year, will contribute significantly to the verification and validation that can be accomplished on E0P's.

B. RadiolocTical Controls FPC is pleased with continuing improvements in this area. As noted, considerable management support ard involvement has been present.

Improvements in the ability to safely process personnel in and out of the RCA have been made. FPC is continuing to identify vppudonities to improve the Radiological Protection Program and has several actions underway through the cambined efforts of the Health mysics and Radiological Support Services departanents. Rese include cmpletion of the Radiological Protection Plan, issuing a periodic newsletter on radiation protection, and closer coordination between these departments.

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B. Radiolenim1 Controls (Cant'd)

A self a - - nt of the overall AIAPA pigram is underway. 'Ihis assessment has been undertaken since we now have several years experience with the ptwima and new guidance has been developed since our program was implemented. 'Ihis is an area where additional improvement is achievable and expected.

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Maraf:sasnt attention continues to enphasize plant rh Amination.

Unencumbered access to the plant is recognized as a contributor to safe operation, as well as a means to reduce overall cost.

C. Maintenance / Surveillance Maintenan is critically inportant to the safe, reliable operation of Crystal River Unit 3. FPC places a strug emphasis in this area and is very pleased with your assessment of our performance. We are continuing to pursue improvements and are currently in the process of a major assessment of maintenance. We are considering the multitude of activities, including engineering, materials, contracts, quality pi.Wtmus, etc., that form a cm plete, overall maintenance ptwtmu. This aummt is based on information frun irdustry, both danestic and international, INEO, the NRC, and our internally developed experience. FPC considers this effort a key factor in the future performance of CR-3 and the continued high level of performance in maintenance.

A significant cannitment to inproving the Surveillance testing performance was made following the previous SALP period. A large percentage of the procedures were rewritten to the approved writers guide format; technical aduyncy has been upgraded; and the procedures were validated by both the responsible ergineers and the users. 'Ihe results of these efforts are now being evaluated to assure the cbjectives of our effort have been met.

Additional improvements will be implemented as they are needed.

'Ibe implementation of the new 10 year in-service inspection and testing programs, along with the administrative changes and staff increases, will provide a sLtus foundation for continuing performance improvement in this area.

D. Enhauts s V Prepat=dmi:ss Emergency Preparedness is an area that has shown continued strength. The deficiencies noted with the last emergency exercise have been corrected.

l The dose a--nt capability has been improved through increased team I sizes, enhanced training, and improved ccmunication.

E. Security The achievenunt of Category 1 in Security is particularly satisfying considering past performance. The efforts to inprove the management of this area have been successful and improved the security effectiveness.

High performance levels will be maintained in this area. Current management attention is being directed to the assessment of the security systems ard facilities. A program to upgrade systems and equignent is being developed. It is anticipated this will be a phased program over the next several years.

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F. ErnineerinUTednical Suocort See Attachment A.

G. Safety Ass. - eit/Ouality Verification Resources have been directed toward the nonconfonnance identification ard corrective action process. A ocmprehensive review has been perfonned and a major rework of the program is under develognent. This effort will resolve the mncerns identified and will be implemented later in this SALP period.

Management emphasis is continuing an procedural adherence. The Human Performance Evaluation PrWima is expanding and the Safety Training Observation Pi@tmu (STOP) has been implemented. This prWimn addresses not only safety issues, but all facets of task performance including procedures, radiation protection, workmanship, etc.

Extensive Vendor Technical Information program enhancements were completed at the end of the SALP period. Efforts are continuing in this area to further ulturgthen this program.

A significant assessment of overall licensing activity has been takirg place. Efforts to provide more distinct definition of the roles ard responsibilities, as well as the expectations, of the licensirs staff will l achieve improved and more consistent performance. Improved communication with the NRC at technical and management levels also contributes to improved performance in this area.

FN considers the cmments on A7WS and the additional source of feedwater to be misleading. Although the resolution of these issues was mutually agreeable, FPC does not consider the NRC Staff's actions on these issues to have been timely or responsive. There was considerable delay in FPC receiving an NRC position that clearly identified the specific problems. In both cases, the issues came down to regulatory M w m fort and not technical issues. When this was camnunicated FEC could, and did, aggressively pursue appropriate resolution.

The Configuration Management program is currently a model for the industry.

FPC's approach is to do it right through a comprehensive, well-planned-out program. The depth ard quality of the effort does make the schedule longer than would be desired. However, much of the information and benefit will be available to the users as the program progresses. FPC developed this program internally and is managing the program through dedicated resources.

This will assure maximum benefit is obtained by the in-house staff.

FPC has made charges in the operation and guidance for the Plant Review Committee (PRC) . It is noted, however, that the PRC operates under an IRC approved alternate approach. This may contribute to the perceived weaknesses. FPC will review the PRC operation and evaluate opportunities for improvement.

H. Licersim Activities No C mment

,) . ; d 4 et - 8 ' 6 ^ f I. Ehfacenert Activity No Otm unt s

J.: React:ar Trips No nr=*nt K. crvt*=1 - River thit 3 Effluert Release Summary No arenants f

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