IR 05000302/1996099

SALP Rept 50-302/96-99 for Period 950917-961005

ML20135C848
Person / Time
Site:	Crystal River
Issue date:	11/25/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20135C832	List: IR 05000302/1996099 ML20135C830
References
50-302-96-99, NUDOCS 9612090117
Download: ML20135C848 (6)

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i SALP REPORT - CRYSTAL RIVER >

50 302 i SEPTEMBER 17. 1995 - OCTOBER 5. 1996 J

l BACKGROUND

The SALP Board convened on October 30. 1996, to assess the nuclear safety performance of Crystal River Unit 3 for the period of September 17, 1995, through October 5. 1996. The Board Meeting was conducted pursuant to NRC Management Directive 8.6. " Systematic Assessment of' Licensee Performance." Board members were Johns Jaudon. (Chairperson). Deputy Director. Division of Reactor Safet Region II (RII): Jon R. Johnson: Deputy Director. Division of Reactor

, Projects. RII; and Frederick J. Hebdon. Director. Project

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Directorate I/II. Office of Nuclear Reactor Regulatio The performance category ratings and the assessment functional areas used below are defined and described in NRC Management Directive " Systematic Assessment of Licensee Performance (SALP)."

I PERFORMANCE ANALYSIS PLANT OPERATIONS This functional area addresses the control and execution of activities directly related to operating the plant. It includes activities such as plant startup power operation, plant shutdown, and response to transients. t also includes initial and requalification training progress for licensed operator Overall performance in the Plant Operations area was acceptable. The early part of this period demonstrated completion of a successful j o)erating cycle. During the latter part of this period..there was the 1 l clallenge of an extended refueling outage and other forced outages.

l l Routine operational activities conducted by control room operators were j considered acceptable. Significant improvement had been made with l respect to encouraging operators to identify problems as demonstrated by i the large number of Precursor Cards written. This demonstrated a good i cuestioning attitude, especially with regard to the adequacy of plant ;

cesign or translation of the design into programs and procedures.. The operations staff assigned to the Emergency Operating Procedures I reevaluation group identified design issues associated with the High

! Pressure Injection System instrumentation, which led to an early -l l shutdown for the April Refueling outage. Performance was not as consistent with the initiation of Problem Reports or the conduct of root cause evaluations for refueling events or human performance issues.

! During this assessment period licensee management responded to i significant NRC enforcement action regarding previous unacceptable management standards for procedural adherence, the conduct of tests and

, safety evaluations, and interfaces with the engineering staf l 1 Initiatives were taken to strengthen plant operations management and ;

shift crews. Routine operational activities and decisions indicated l

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^ adequate safety focu Technical support to plant operations demonstrated improvement later in the period with a decrease in the number of control room deficiencies.

Management oversight and involvement in refueling activities and I

overtime control continue to be a challenge. Senior Reactor Operators showed inattentiveness, a. lack of close oversight, and a lack of formal corrective actions for fuel handling errors. During the forced outage

.at the end of the period, station management strengthened overtime controls and limited routinely scheduled working hour ;

Operator response late in the period to two plant maneuvers and to a reactor trip were well supervised; however, interfaces between plant

. operators and other organizations remained a challenge. Performance by licensed operators indicated a weakness in the interface between Plant Operations and the Nuclear Training Department. 'A senior operator misinterpreted a procedure and exceeded the RCS cooldown rate limit: an i

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operating crew chose not to implement a new procedure for a more rapid response to a condenser tube rupture because the crew was not comfortable using it: and weakness was demonstrated in the program for notifying Nuclear Training staff of new or revised procedure Normal operating and emergency operating procedures in' general were adequate for accomplishing their intended functions. Observation of plant tours and operation surveillances indicated deficiencies in log taking and inconsistencies in equipment monitoring. Management 3rovided support staff resources to complete the E0P enhancement program ay the latter part of this perio Quality Assurance audits failed to provide a full assessment of various operational programs and policies on-site. These audits were checklist'

or question-oriented and lacked full discussion or safety significance of problems. The Operations Department was responsive to.outside recommendations; however. Plant Operations was not effectively utilizing its own self-assessment program to improve performanc l The Plant Operations area was rated Category III. PERFORMANCE ANALYSIS MAINTENANCE ,

l This functional area assesses licensee activities in the areas of

! testing and maintaining plant structures, systems, and components.

l Activities assessed include preventive. predictive. and corrective l l maintenance, as well as balance of plant equipment condition, and '

surveillance testing activities.

i During the middle period of the SALP, Crystal River was shut down for a j

! refueling outage. During power ascension, there were two reactor i

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transients and one reactor trip as a result of secondary side equipment

problems or maintenance errors, indicating a need for additional In general, outage activities, both during the

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management attention.

l refueling outage and on-line system outages, were implemented well.

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Strengths were noted in the effectiveness of one on-line maintenance l program and productive use of diagnostic equipment to identify and i correct problems. However, the on-line maintenance backlog has !

continued to grow. During the refueling outage, maintenance issues that could be performed on-line, were postponed to future on-line maintenance activitie This resulted in a significant increase in the non-outage

. maintenance backlog and a large backlog of control room deficiencies following the outage. Following startup from the refueling outage, a maintenance error caused an unplanned unit outag ,

Failure to follow procedures which was a )roblem during the previous SALP 3eriod continued to be a challenge t1is period. Maintenance rewort is still a challenge due to weak work practices. Craftsmen !

accomplished work in spite of procedure deficiencies. not as a result of !

compliance with procedure I

Several instances of inattention to detail were also noted, such as

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deferral of the B-K-1 welds in the second 10-year ISI program, which is not permitted by the ASME Code and which violated the Technical Speci fications. Other failures resulted in inoperable equipment and i equipment failures. In some case these failures have indicated an '

inadequate sensitivity to regulatory requirements.

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In addition, there have been incidents of maintenance workers failing to kee) the control room operators adequately informed of ongoing work witlin the plan During the latter part of the SALP period, the licensee initiated new i

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maintenance work control, planning and tracking programs including use I of a top-10 list of activities and a 13-week rolling schedule. These

initiatives, if properly implemented, should address previous work

. planning problems and avoid work being classified as " emergent."

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The licensee's self-assessment of the maintenance program did not reveal l insights into strengths and weaknesses of the maintenance program.

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i The Maintenance area is rated Category !

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IV. PERFORMANCE ANALYSIS - ENGINEERING

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The functional area assesses activities associated with the design of

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plant modifications and engineering support for operations maintenanc ;

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surveillance, and licensing activitie '

4 Licensee performance in this area continued to decline. Weaknesses from the last SALP period persisted in the areas of management oversight, human performance errors. control of modifications, and quality of licensing submittals. During this SALP period, the NRC noted a lack of improvement and identified the major areas of continuing engineering weakness as 1) insufficient management oversight and involvement. 2)

marginally effective engineering organization. 3) lack of an adequate understanding and knowledge of the Crystal River 3 design basi I

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l and 4) lack of sensitivity to and/or knowledge of regulatory ,

rec uirement NRC enforcement actions in the engineering area increased >

anc included .five severity level III violation !

Insufficient management oversight and involvement were evident by a weak I

, corrective action program errors in recent engineering work, and a !

large engineering work backlog. Also evident was a lack of appropriate l standards including root cause. evaluations and event investigations I 10 CFR 50.59 safety evaluations, self-assessments, o)erability ;

evaluations. licensing submittals, and the role of tie quality j organizatio .

l The corrective action program was weak, as indicated by several l l

instances of failures to initiate appropriate corrective actions, untimely corrective actions, and inadequate corrective' action ,

However, an improvement was noted in problem identification in that 1 there were increases in the numbers of Precursor Cards and Licensee

[ vent Reports for design issues.

A marginally effective engineering organization was indicated by L examples of failures to follow procedures, design control errors, and l missing or improper design outputs. Some of the engineering process l errors led to design deficiencie Lack of an adequate understanding and knowledge of the Crystal River 3 l

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design basis was evidenced by design errors in the electrica instrumentation and control. Appendix R. mechanical. and hydraulic *

areas. In addition, there were design-related inadequacies in safety

. classification of equipment, surveillance requirements, and operating l procedure A lack of sensitivity for the need to comply with regulations was

evident in the continued poor quality of licensing submittals, including l incorrect information and deficient analyses. There were also examples of untimely reporting to the' NRC and improper interpretation and implementation of the Technical Specification During the SALP period. the licensee acknowledged the need for im3 roved performance and initiated many changes to address engineering pro)lems

, including chartering an Independent Review Panel, with members from l outside of FPC. to review the design basis issues and management design

' control processes and creating a Nuclear Safety Assessment Team (similar to an Independent Safety Engineering Group). Other changes included operations review of engineering calculation inputs, engineering review of Emergency Operating Procedure revisions, and creation of an Engineering Design Review Panel to review modifications. Improved management oversight and involvement will be required to assure effectiveness of these changes in improving the control of the design i process, the engineering support to plant operations and maintenance.

and the quality of licensing submittals.

i The Engineering area is rated Category 3

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j PERFORMANCE ANALYSIS PLANT SUPPORT j This functional area addresses radiological _ controls. radioactive

effluents, chemistry, emergency preparedness, security, fire protectio : and housekeeping controls, d

-0verall the radiological control program was effectively im)lemente ;

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Personnel radiation exposures were well controlled during t1e period i with exposures significantly below regulatory limits. Radiation work

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permit compliance was an area requiring additional licensee attention .

, during the assessment aeriod. The site collective dose in 1996 was

! significantly higher tlan anticipated due to several developments including: the deletion of a source term reduction procedure during the 3- refueling outage shutdown schedule, the increased maintenance activities i performed during the extended refueling outage, and unanticipated forced

outages late in the assessment period.

l Chemistry and radiological effluent programs remained effective. The ,

issuance of a chemistry quality control manual was a program t

enhancement. An effective-effluent control program limited effluents

and associated doses to the public to a small fraction of regulatory i limits. Environmental monitoring demonstrated that )lant operations had caused negligible impact to environs of the plant. Radioactive material

!' Wds transported in accordance with regulatory requirements. The i licensee maintained an aggressive i system degradation was minimize plant chemistry Challenges _ includedprogram better to assure that i documentation of corrective actions and strict adherence to regulatory

? requirement The emergency preparedness program continued to provide a high level of

readiness to respond to events. The licensee's performance during i November 1995 annual emergency preparedness exercise was satisfactory.

) _W ith the exception of the technical support center emergency ventilating system, the licensee's emergency response facilities were good and

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adequately maintained. The emergency preparedness staff was experienced

< and' licensee management demonstrated good support for emergency planning l

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and preparedness at the Crystal River sit !

i l The overall security program was adequately implemented. However, j

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inspectors found. assessments and corrective actions for safeguards '

contingency plan issues and other aroblems identified during the period

! were not always thorough or compre1ensive. Management oversight of the  ;

security alan implementation and changes to it was also a significant '

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program clallenge.

! The fire protection program remained effective during this assessment l 3 period. Combustible materials were properly controlled and facilities i

were satisfactorily maintained. However, some maintenance and  !

engineering concerns associated with fire protection equipment were

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6 1 identi fied. Good progress was made by the licensee in resolving Thermo- l Lag problem The Plant Support area is rated Category 2 l

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