ML20009D498
| ML20009D498 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 07/13/1981 |
| From: | Griffin B FLORIDA POWER CORP. |
| To: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| 3-071-12, 3-71-12, NUDOCS 8107240123 | |
| Download: ML20009D498 (12) | |
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July 13, 1981 S; Wc a
File:
3-0-3-a-2 3-071 -12 4
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,6 Mr. Victor Stello, Jr., Director
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Office of Inspection and Enforcement N
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U. S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Management Appraisal 50-302/81-1 (PAS)
Reference:
(1) Letter, Stello to Griffin, Management Appraisal 50-302/81-1 (PAS), dated June 3, 1981 (2) Letter, Baynard to O'Reilly, CIE Inspection 81-06, dated June 19, 1981.
Dear Mr. Stello:
In reference to the NRC's management inspection, as reported in Management Appraisal 50-302/8'-1 (PAS) for Crystal River Unit 3
(Reference 1).
Florida Power Corporation hereby provides inforination on the management controls implemented to improve identified weaknesses, as well as further enhance the effectiveness of other programs.
While the Nuclear Operations organization within Florida Power Corporation is a relatively new organization, we have made significant strides in improving the management of our nuclear prograrn.
Your appraisal is of tremendous value in gauging our progress in achieving the goals which we, as an organization, have established for ourselves.
Many of the weaknesses ident i fied by the Performance Appraisal Team had previously been identified, and work was and is in progress to correct deficiencies.
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Mr. Victor Stello, Jr.
July 13, 1981 Page ?
In addition to addressing the improvements Florida Power Corporation has taken or plans to take in improving maragement controls in areas where there are identified significant weaknesses we will also address management's attention toward further enhancing our nuclear program by responding to the program areas which are average or above average. Our response is as follows:
1.
Committee Activities:
Average (Section 2).
Both the Nuclear General Review Committee (NGRC) and Plant Review Cocrnittee (PRC) were active committees composed of qualified and capable individuals.
The cormi ttee s appeared to be effective in their review of most safety-related issues.
The principal deficiencies found in this area were:
the NGRC's repeated use of one person subcormittees for review of potential safety issues, a practice that forecloses the benefit of multi-discipline,
independent review, and examples which indicated thac some Technical Specification violations were not receiving PPC review.
Response
The Nuc??ar General Review Committee is strengthening its use of subcormittees by including additional members on subcommittees, thereby providing expertise in nulti-d4scipline areas and by employing improved subc orrni ttee reports that present sufficient information, con-clusions, and recommendations that allow ot her members to perform an adequate review of the subcommittee report.
This will enhance the multi-discipline independent review process by the entire Committae while still retaining the detailed technica} review performed by the subcorrittee members.
Full implementation will be completed by September 9, 1981.
The Plant Review Oxrnittee will modify its procedo-es to assure the review of all Technical Specification violations that may be identified in audits.
Full implementation of this change will be achieved by August 10, 1981.
W
Mr. Victor Stello, Jr.
July 13, 1981 Page 3 2.
Quality Assurance Audits:
Average (Section 3).
The existence of an auditing function under the site management, separate from the corporate audit program, was a positive indication of the licensee's corrmitment to quality assurance.
The corporate or Quality Programs audit function was an effective program for resolving substantial safety concerns.
Weaknesses,
- however, existed as follows:
audit checklists lacked, in most cases, scope and depth, did not require management review, and were not specific with regard to sample size; auditors failed to assess the effectiveness of various program elements; and there were inadequacies in reviews of audits by management outside the Quality Programs Department (QPD).
Response
In May, 1981, CPD began the development of a Quality Assurance (CA) program ecntrol system.
This cceputerized system will provide improvements to the Quality program in several areas identified by the PAS team.
A.
Audit Scope The system will be used to assist audit teams in preparing for audits.
The scope and depth of audit checklists will evolve frce a computerized system wnich searches FPC cccmitments in the area to be audited, and the Quality Assurance program control system has been implemented for the area of training and qualification and will continue to be developed for all quality program areas.
It is our intent to have the entire data base complete ar.d functional by January 1,
1983.The system will permit a systematic assessment of the completeness of the audit program and should enable a nore effective use af manpower devoted to the audit func tion.
B.
Management Review The new CA program control system will be used to assist management in evaluating the adequacy of eacn audit as well as the overall program.
Program sunnaries in each CA functional rea will be developed to indicate the periodicity of quality requirements and the completeness of the audit program with regard to these requirements.
Mr. Victor Stello, Jr.
July 13, 1981 Page 4 C.
Effectiveness of Program Elements In addition to improvements in this area that should evolve from using the QA system described above, an effort will be made to upgrade the composition of future audit teams to include technical expertise in the functional area to be audited.
To meet this objective, QPD management intends to utilize other FPC departments and contractors and to upgrade technical capabilities of department personnel through a comprehensive technical training program.
This effort is currently being implemented.
D.
Audit Review by Management Outside Quality Programs Departmemt QPD will, in the future, secure the services of a quali fied, independent consultant to perform periodic audits of the overall Quality Program, including the QPD audit function.
E.
Expand or Improve Training QPD has developed a detailed report on technical training for 1981.
This document provides the training needs and priority for each person in the department.
A program is underway to identify technical course material and courses to meet these needs.
Tnis program will begin implementation during the second half of 1981.
F.
Audit Program Implementation versus Program Adequacy & Effectiveness QPD management recognizes the need for corrective action to improve the audit program.
The steps outlined above should prod uce the desired results.
These steps are:
1.
Implement a
computerized QA program control system for all Quality areas; 2.
Increase management review of audit
- scope, content, and effectiveness;
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Mr. Victor Stello, Jr.
g July 13, 1981 Page 5 5
M 3
Enhance technical 3xpertise on each audit team;
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Implement a technical training program for CPD m
in 1981.
A 3
Design Changes and Modifications:
Average (Section 4).
e m
Although significant weaknesses were discovered in the handling of two madifications, these weaknesses did not mpear to be generic to the management controls for this art
Response
=
The areas of weakness identified by the inspector involved isolated problems concerning two Modification Approval e
Records (MAR) packages that were issued in May, 198C.
g Generic program deficiencies do not exist in the design control process as evidenced by his review of additional MAR packages which were found acceptable.
The Nuclear Operations Engineering procedures were revised extensively in August, 1980, to provide better guidance to the engineers and to insure that our design program met
=
the requirements of ANSI N45.2.11, Quality Assurance M
Requirements for the Design of Nuclear Power Plants.
These changes involved the addition of design and
-N verification checklists to insure uniform consideration by the engineers of the design and safety requirements for
- -. 2 Crystal River Unit 3 In addition, by August 15,
- 1981, Nuclear Operations Engineering procedures will be revised to be consistent with in-plant procedures, to respond to several Ouality Programs Department audits concerning the design process,
.-J and to in lude other changes which will improve the desi n d
control process.
M 4
Maintenance:
Below Average (Section 5).
This area contained numerous significant weaknesses.
Work Requests had several deficient areas, such as a lack of trending, inadequate
- reviews, and poor corrective actions; maintenance histories and the preventive maintenance system were inadequate; training was weak; and uncontrolled vendor manuals were used.
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l Mr. Victor Stello, Jr.
July 13, 1981 Page 6
Response
The Maintenance Department at Crystal River Unit 3 is dedicated to the achievement of excellence in its employee training, preventive maintenance, equipment history data collection, the proper writing of work requests, and the trending of all these activities in such a way that the system will Duild on lessons learned and enhance equignent performance.
The Maintenance Department is currently developing a
computerized preventive maintenance (PM) program along with other computerized systems to coordinate the information for
- trending, identifying problems, and assuring more comprehensive reviews.
Data is currently being gathered utilizing work requests for the development of the PM program.
A building process is involved to provide sufficient data for trending.
By February 1,
- 1982, there should be sufficient data to begin trending these frequent failures to assure that corrective actions better address generic corrective action, as well as the remedial corrective actions.
In
- addition, to enhance these activities, a concentrated "c ra ft" training program has been implemented.
- However, there is a learning curve for each new employee at Crystal River Unit 3 relative to site specific requirements.
The control of vendor manuals continues to be a problem which should be alleviated by the responsibility for the maintenance of vendor manuals by Nuclear Operations Administrative Services, Document Control.
The staff has been instructed to assure they are utilizing controlled manuals.
We feel that the changes to the maintenance program, that have been accomplished subsequent to the inspection and those changes that are impending, will not only improve the Maintenance Department but will strengthen weak areas.
2
w Mr. Victor 3tello, Jr.
July 13, 1981 Page 7 5.
Plant Operations:
Above Average (Section 6).
The written procedures for plant operations were well written, understood, and effectively controlled.
The shift complement maintained an extra licensed operator over the TS requirement, and all operations personnel interviewed displayed high morale and a positive attitude toward safety.
Significant weaknesses included a
nisinterpretation of Technical Specification requirements regarding AC power supplies and improper authorization of a
safety-related equipment clearance, botn of which appeared to be isolated problems.
There was also a need for a program to ensure timely elimination of jumpers.
Response
Safe plant operations is at the top of management's priority list for accomplishing our work and is closely followed by our commitment to operate it within the requirements of our license.
The proper interpretation of Technical Specifications requirements has been aided by the NRC's Resident Inspector Program and our increased on-site presence of nuclear licensing support.
Increased emphasis has beer. placed on contacting Nuclear Licensing when there is a question over the interpretation of Technical Specifications.
With the experience our nuclear organization has gained in the past few months working as a team, we anticipate further gains in the coming months in assuring our management controls are implemented and further improved, as appropriate.
The jumper program is an example of such a management control.
6.
Corrective Active Systems:
Below Average (Section
').
The management controls for corrective action systems exhibited numerous significant weaknesses.
Both work requests and noncon forming operations reports were found to be inadequately trended, not rev iewed for their generic implications, poorly tracked and followed up, contained descriptions that lacked deta i. received token reviews,
~
and contained corrective action proposals that seldom specified actions to prevent recurrence.
Work Requests that reported discrepant conditions were not considered a part of the corrective action system as required.
Some work had been per formed without a Work Request.
Failure history analysis was cumberscme using the existing system, and therefore, was seldun accomplished.
Noncon. arming and correcti ve action reports had historically been used in very limited situations, and had not been an effective system, although this show 1 recent signs of improving.
Mr. Victor Stello, Jr.
July 13, 1981 Page 8 Licensee Event Reports received only limited trending.
Aside from corrective actions, another weakness was the lack of a current, comprehensive list of regulatory commitments.
Response
The effectiveness of our corrective action program will be greatly enhanced by the system for trending equignent performance and failures that is currently being implemented by the Maintenance Department.
From the data base that is being compiled, access will be provided to easily extract information that can be used to trend and track non-conformances and corrective actions.
This information will be utilized to trend generic performance and failure history and will ensure a much closer control on both short and long-term corrective actions.
The administrative controls for this program will be in place by February 1, 1982.
Management is studying the possibility of creating a new organizational unit dedicated to reliability / risk assessment as a support functior to the plant staff, engineering, and others.
Decisions on this organizational strategy will be developed by January 1, 1982.
All Non-Con fonning Cperating Reports (NCOR's), regardless of their reportability, are reviewed by the Plant Review Connittee (PRC),
the Nuclear Plant
- Manager, and the Nuclear General Review Committee (NGRC).
Corrective actions required to close out the non-reportable NCOR's are assigned responsibility to take action by the Nuclear Plant Manager, and the assigned corrective action is tracked by the Nuclear Compliance Section ur.t i l resolution.
Both Licensee Event Reports (LER's) and NCOR's will be trended as information too's ir evaluating management controls; however, their trending will not be relied upon to control the Corrective Action System for equipment problems.
This control will be provided by the utilization of the maintenance performance and history drta base.
L_______
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Mr. Victor Stello, Jr.
July 13, 1981 i
1 Page 9 LER's are reviewed by an "LE9 Board", comprised of the Nuclear Plant Manager and Nuclear Plant Department Heads. 'Ihis board comprehensively reviews the LER for both accuracy and the appropriate corrective action to be taken.
Following the in-plant review, Nuclear Support Services reviews LER's for an independent generic review, appropriateness of correction, and conformance to Nuclear Licensing philosphy and cocmitments prior to submittal to the NRC.
Once the corrective action has been for.nul ated,
responsibility for it is assigned by the Nuclear Plant
- Manager, and it is tracked by the Nuclear Compliance Section until the LEP is closed out by NRC Pegion II.
Since all LER's are generated as a esult of a NCCR, all NCOR's evaluated as " reportable" fall into this review.
y A continuing training program to insure that plant personnel are aware of the available Corrective Action Systems is part of the general employee training.
This asoect of general employee training is currently being c.;1aated and will be
- revised, as appropriate, by January 15, 1982, to ensure that the maximum attention feasible is applied to this critical area.
Those instances pointing out the performance of work without work requests are isolated cases and are not indicative of a major breakdown in procedural control.
The performance of work without a work request is nct procedurally allowed except for the performance of scheduled Surveillance Procedures (SP's) and during times c.
" Emergency".
The Shift Supervisor on dt.
is notified at the cocmencement and completion of the and work m
that is performed during emergency conditions will be documented, and complete work packages will be generated as soon as the plant condition will allow.
The concerned personnel have been reinstructed as to the procedural controls on the performance of work.
A comprehensive cccmitment tracking system is currently being aeveloped by Nuclear Licensing.
The data will be identified for tracking purposes by February 1,
- 1982, and will be automated by January 1, 1983
Mr. Victor Stello, Jr.
July 13, 1981 Page 10 7.
Licensed Training:
Average (Section P).
Recent reorganization changes, growth of the Department, and management support has made the training program for licensed personnel effective.
Weaknesses existed in meeting records storsge requirements and the absence of security bri.efings for licensed personnel.
Resoonse:
General Employee Training which incorporates the security briefing will be conducted for all licensed personnel by July 15, 1981.
It will become a part of the licensed training program and the requalification program.
Nuclear Operations Training is presently in the process of a complete documentation system update.
The records will be updated biweekly for all training conducted.
Nuclear Operations Administration will mainta., these records in accordance with ANSI 45.2.9-1974.
8.
Non-Licensed Training:
Below Average (Section 8).
This area had significant weaknesses throughout the licensee's organization.
It appeared to be a generic weakness affecting all areas inspected.
Beyond the limited initial General Employee Training there was minimal formal training.
Response
Florida Power Co! poration nanagement rec ognized this generic weakness in non-licensed training some time ago.
Consequentl y the Nuclear Operations Training Group was reorganized early in 1980 to include non-licensed training for the balance of Nuclear Operations.
Additional personnel were allocated to effect this task, and an intensive development effort is currently under way.
A repetitive training cycle for non-licensed personnel is well under development and is currently being presented as developed.
Plant specific systems training for " craft" and
" engineering" personnel has been ongoing since l
February, 1981.
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Mr. Victor Stello, Jr.
A July 13, 1981 Page 11 w
In addition, all technical areas are developing technical
-M training requirements and schedules for implementation.
The program will be established by May 1,
1982, and W
l implementation will begin by January 1,
1983 This 1
program is a skills level type program and will be an
.M evolving progression toward documented and specified
-Z training requirements.
FPC Management is and has been 6
dedicated to full development of this program as a key N-means toward meeting both safety and reliability n
objectives.
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9.
Physical Protection:_
Below Average (Section 9).
Bere were numerous problems in the implementation of tne m
j programs for physical protection.
Such areas as visitor
-6
- escort, meeting guard force qualification requirements,
- training, and retraining all exhibited significant weaknesses.
Security ma.agement failed to audit the c
implementatlan of their program and gave onl3 limited support to Quality Program audits of security.
E
Response
_=
Florida Power Corporation is concerned over the effectiveness of the Management of the Security Program a'
_-J Crystal River Unit 3.
as commented on in the "RC OIE Inspection 81-06, Reference (2), as well as identified by us in our visit with ehe Region II OIE staff on June 5, N
1981.
Prior to the NRC inspectior, F PC has formulated a 4
plan to improve FPC security management.
Based on the C
finding of the PAT visit, the Vital Area Assessment Team,
-5 OIE Inspection 81-06, and an independent assessment by FPC
.g m,nagement, a
number of actions were immediately implemented to correct obvious problems.
Some of these immediate steps taken were as follows:
M A.
On April 1,
a full time Security Training Officer was appointed and the FPC Training and Qualification Program was implemented.
J' B.
On April 28, 1981, a group was formulated inclucing d
corporate, plant
- staff, and nucloar licensing personnel to study the entire Security Program ana to J
make chart and long-term solution recxriendations of security problems.
Included in the e f forts :f this group will be (a) to provide 10 CRF 50.54p changes assure compliance with the currant Security Flan August 3,
1981; and (t) compl ete rewrite of the Security Plan to sutin it to the NRr by September 1,
R 1981, for NRC 2pproval 5-m
l Mr. Victor Stello, Jr.
July 12, 1981 Page 12 C.
A reevaluation of Crystal River Unit 3 Security Management and reassi gnment of reporting responsibility was accomplished.
In June, 1981 Plant Security was assigned to Technical Support Superintendent reporting directly to the Plant
- Manager, whose primary responsibility is the management of the Security Program.
I, addition, the
.aanagement of the guard for ce contract is the responsibility of the Technical Support Superintendent.
The details of the administration of other security changes will be addressed by Sep-tember 1,1981, since we are currently evaluating problem areas to assure that corrective actions will enhance the overall effectiveness of the Security Program.
During thi: oeriod, a representative from Corporate Security is assigned to the Plant site to aid in formulation of revised plans and procedures.
D.
A, cociram was instituted for the reorganization of tne Security Force that includes the following:
a.
Upgrading and adding supervisory positions, and b.
Reassignment of resnonsibilities.
E.
Guardforce management is currently being reevaluated from both the may-to-day on-shif t supervision and the redefinition of Corporate Security and Plant Securitys' roles and responsibilities to further enhance the effective management of these personnel and the Security Program.
This change will be pr ovided in the September 1,
1981, submittal on the revised Security Plan fvr NRC approval.
The management of Floridr Power Corporation is exmit ted to excellence in performing our jobs.
Although we have identjried management weaknesses, we are striving to correct these weaknesses.
Our goal is to meet the ever changing demands of the nuclear industry in a
- safe, legal, and efficient manner with a
keen interest in personal and professior.al ne eds of our employees.
We intend to c;ntinue to progress toward the achievement of our goals and objecti"es.
Very truly y pes, rjY,.f>WW(
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. L. Griffin
.