ML20041G326

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Forwards IE Mgt Appraisal Rept 50-302/81-01 on 810202-13 & 23-27 & Executive Summary
ML20041G326
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 06/03/1981
From: Stello V
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To: Griffin B
FLORIDA POWER CORP.
Shared Package
ML20041G327 List:
References
NUDOCS 8203220078
Download: ML20041G326 (6)


See also: IR 05000302/1981001

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JUN 3

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Docket No. 50-302

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Florida Power Corporation

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ATTN:

Mr. B. L. Griffin

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Engineering and Construction'y} 2!

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Senior Vice President

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P. O. Box 14042, Mail Stop C-4

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St. Petersburg, Florida 33733

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Gentlemen:

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Subject:

Management Appraisal 50-302/81-1 (PAS)

This refers to the management inspection conducted by Messrs. J. Woessner,

W. Ang, F. Jablonski, P. Johnson, and W. Kushner of the Perforiiiance Appraisal

Section of the Division of Program Development and Appraisal, Office of

Inspection and Enforcement, on February 2-13, and February 23-27, 1981, of

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activities authorized by NRC Operating License DPR-72, for the Crystal River

Nuclear Plant at Crystal River, Florida, and the Florida Power Corporation

corporate offices in St. Petersburg, Florida; and to the significant observa-

tions discussed with you and others of your staff on February 13, and

February 27, 1981, at the Crystal River Nuclear Plant.

The enclosed management appraisal report 50-302/81-1 (PAS) identifies the

areas examined during the inspection.

Within these areas, the inspection

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consisted of a comprehensive examination of your management controls over

licensed activities which included examination of procedures and records,

and interviews with management and other personnel.

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This inspection is one of a series of management appraisal inspections being

conducted by the Performance Appraisal Section of the Division of Program

Development and Appraisal, Office of Inspection ar.d Enforcement.~ The results

of this inspection will be used to evaluate the performance of your management

control systems on a national perspective.

The enclosed appraisal report

includes observations which may be potential enforcement findings.

These

items will be followed by the IE Regional Office.

The enclosed appraisal

report also addresses other observations and the conclusions made by the team

for this inspection.

Section 1 of the report provides further information

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regarding the observations and how they will be utilized.

Appendix A to this

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letter is an Executive Summary of the conclusions drawn for the nine functional

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areas inspected.

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Of the nine areas inspected and evaluated, one area was considered above average

and four areas were considered average; however, significant weaknesses were

identified in these areas which will require managemen . attention.

Four areas

8203220078 810603

PDR ADOCK 05000302

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Florida Power Corporation

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were considered below average.

These were the areas of maintenance, corrective

action systems, non-licensed training, and physical protection.

The bases for

these ratings are included in the attached Executive Summary.

In each of the

areas considered below average, the licensee and tne NRC Region II Office were

aware of several of the weaknesses described prior to the PAS inspection.

Because of this, corrective action was planned or in progress for several of

these areas.

This action was considered to reflect favorably sn the efforts

applied by the Florida Power Corporation toward correction of these recognized

problem areas.

As a result of the significant weaknesses identified in the four areas rated

below average, you are requested to inform this office within 30 days of receipt

of this report of the actions you have taken or plan to take to improve the

management controls in these areas.

Your response to this office and your actions

regarding identified weaknesses will be followed by the IE Regional Office.

In accordance with Section 2.790(d) of the NRC's " Rules of Practice," Part 2,

Title 10, Coda of Federal Regulations, your facility security procedures are

exempt from disclosure; therefore, the pertinent section of the Appraisal

Report, Attachment 'A' will not be placed in the Public Document Room and will

receive limited distribution.

Attachment 8 to this report is a detailed listing of the persons contacted

and the documents reviewed during this inspection.

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In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of

this letter and the enclosed inspection (or investigation) report will be

placed in the NRC's Public Document Room.

If this report contains any

information that you (or your contractors) believe to be exempt from

disclosure under 10 CFR 9.5(a)(4), it is necessary that you (a) notify

this office by telephone within ten (10) days from the date of this letter

of your intention to file a request for withholding; and (b) submit within

twenty-five (25) days from the date of this letter a written application to

this office to withhold such information.

If your receipt of this letter has

been delayed so that less than seven (7) days are available for your review,

please nofify this office promptly so that a new due date may be established.

Consistent with section 2.790(b)(1), any such application must be accompanied

by an affidavit executed by the owner of the information which identifies

the document or part sought to be withheld, and which contains a full state-

ment of the reasons on the basis which it is claimed that the information

snould be withheld from public disclosure.

This section further requires

the statement to address with specificity the considerations listed in

10 CFR 2.790(b)(4).

The information sought to be withheld shall be incor-

porated as far as possible into a separate part of the affidavit.

If we

do not hear from you in this regard within the specified periods noted

above, the report will be placed in the Public Document Room.

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Florida Power Corporation

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JUM 3

G81

If you have any questions concerning this inspection, we will be glad to

discuss them with you.

Sincerely,

.

Victor Stallo, Jr. , Director

Office of Inspection and Enforcement

Enclosures:

1.

IE Management Appraisal Report 50-302/811 (PAS)

2.

Appendix A

3.

Attachment A*

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Attachment B

Distribution:

(w/ Attachments A* and B)

Chairman Hendrie

w/o Attachment A*:

Commissioner Gilinsky

POR

Commissioner Bradford

LPOR

Commissioner Ahearne

NSIC

SECY

T1C

OCA (3)

RII Reading Room

W. J. Dircks, E00

State of Florida

H. R. Denton, NRR

All Licensees

W. Haass, NRR

S. H. Hannauer, NRR

B. Burnett, NMSS

G. W. McCorkle, NMSS

C. Michelson, AE00

H. Boulden, OIA

SALP Chairman

T. Statka, NRC Senior Resident Inspector

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V. Stallo, IE

H. D. Thornburg, IE

N. C. Moseley, IE

J.'M. Taylor, IE

PAS Files

Regional Directors

Central Files

NRR Project Managers

E. P. Wilkinson, INPO

"Contains 10 CFR 2.790 Information ,

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Appendix A

Executive Summary

A team of five NRC inspectors from the Performance Appraisal Section conducted

an announced inspection at the Crystal River Nuclear Plant and Florida Power

Corporation offices during February 2-27, 1981.

Management controls in nine

areas were inspected.

Of these, one area was considered above average, four

areas were considered average, and four areas were considered below average.

A summary of the results of the inspection is given below.

Committee Activities:

Average (Section 2).

Both the Nuclear General Review

Committee (NGRC) and Plant Review Committee (PRC) were active committees

composed of qualified and capable individuals.

The committees 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

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person subcommittees for review of potential safety issues, a practice that

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forecloses the benefits of multi-discipline, independent review, and

examples which indicated that some Technical Specification violations were

not receiving PRC review.

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Quality Assurance Audits:

Averaae (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 commitment to quality assurance.

The corporate or Quality Programs audit function was an effective program for

resolving substantial safety concerns. Wea)nesses, 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 elemer. s;

and there were inadequacies in reviews of audits by management outside the

Quality Programs Department.

Desian Changes and Modifications:

Average (Section 4).

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Although significant weaknesses were discovered in the handling of two modifi-

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cations, these weaknesses did not appear to be generic to the management

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controls for this area.

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Maintenance:

Below Averace (Section 5).

This area contained numerous signi-

ficant weaknesses.

Work Requests had several deficient areas, such as a lack

of trending, inadequate reviews, and poor corrective actions; maintenance

histories and the preventive mai.ntenance system were inadequate; training was

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weak; and uncontrolled vendor manuals were used,

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Plant Operations:

Above Average (Section 6).

The written procedures for

plant operations were well written, understood, and effectively controlled.

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The shift complement maintained an extra licensed operator over the TS

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requirement, and all operations personnel interviewed displayed high morale

and a positive attitude toward safety.

Significant weaknesses included a

misinterpretation of Technical Specification requirements regarding AC power

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Appendix A (Continued)

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supplies and improper authorization of a safety-related equipment clearance,

both of which appeared to be isolated problems.

There was also a need for a

program to ensure timely elimination of jumpers.

Corrective Action Systems:

Below Average (Section 7).

The management con-

trols for corrective action systems exhibited numerous significant weaknesses.

Both work requests and nonconforming operations reports were found to be in-

adequately trended, not reviewed for their generic implications, poorly tracked

and followed up, contained descriptions that lacked detail, received token

reviews, and contained corrective action proposals that seldom specified

actions to prevent recurrence. Work Requests that reported discrepant condi-

tions were not considered a part of the corrective action system and these

items were not followed up by a corrective action system as required.

Some

work had been performed without a Work Request.

Failure history analysis

was cumbersome using the existing system, and therefore, was seldom accomplished.

Nonconforming and corrective action reports had historically been used in very

limited situations, and had not been an effective system; although, this

showed rvcent signs of improving.

Licensee Event Reports received only

limited trending. Aside from corrective actions, another weakness was the

lack of a current, comprehensive list of regulatory commitments.

Licensed Training: Average (Section 8).

Recent organization changes, growth

of the Department, and management support had made the training program for

licensed personnel effective. Weaknesses existed in meeting records storage

requirements and the absence of security briefings for licensed personnel.

Non-Licensed Training:

Below Average (Section 8).

This area had significant

weaknesses througout 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.

Physical Protection:

Below Average (Section 9).

There were numerous problems

in the implementation of tne programs for physical protection.

Such areas as

visitor escort, meeting guard force qualification requirements, training, and

retraining all exhibited significant weaknesses.

Security management failed

to audit the implementation of their program and gave only limited. support to

Quality Program audits of security.

The reasons for the areas rated below average and for other identified weak-

nesses were numerous, often complex, and certainly could not be completely

identified in a single inspection.

The conclusions that could be drawn from

this inspection point to a combination of several factors affecting management

control systems. The licensee was completing a major reorganization.

The

number of staff positions had increased substantially, some of which had not

yet been filled. Crafts were also understaffed.

Other positions had been

filled by persons who, although qualified, lacked experience.

Training in

many of the new procecures and recent program changes had not been accom-

plished. There appeared to be more pressure on managers and other personnel

to complete work assignments than to expand or improve training.

Management

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Appendix A (Continued)

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priorities in several areas of licensee activities were significant contri-

buting factors:

priorities that emphasized corrective maintenance over

preventative maintenance; short-term remedial action on work requests and

nonconforming operations reports over long-term corrective action; the

efficiency of management and committee reviews over the depth of reviews;

and audits of program implementation over audits of program adequacy and

effectiveness.

Some of these reasons were recognized by the licensee;

there were corrective actions planned or in progress in several areas.

Other areas identified in the inspection report had not been identified

by the licensee and require management attention to correct.

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