ML20127M373
| ML20127M373 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 03/05/1985 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20127M361 | List: |
| References | |
| 50-302-85-03, 50-302-85-3, NUDOCS 8507010209 | |
| Download: ML20127M373 (25) | |
See also: IR 05000302/1985003
Text
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March 5, 1985
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, . ENCLOSURE
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'I ~ , SALP BOARD REPORT ~
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,3 O. S. NUCLEAR REGULATORY COMMISSION
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REGION II
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_.. SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
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INSPECTION REPORT NUMBER
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50-302/85-03
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FLORIDA POWER CORPORATION
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CRYSTAL RIVER UNIT 3
July 1, 1983 through October 31, 1984
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I. INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect available observations and data on a
periodic basis and to evaluate licensee performance based upon this informa-
tion. SALP is supplemental to normal regulatory processes used to ensure
compliance to NRC rules and regulations. SALP is intended to be suffi-
ciently diagnostic to provide a rational basis for allocating NRC resources
and to provide meaningful guidance to the licensee's management to promote
quality and safety of plant construction and operation.
A NRC SALP Board, composed of the staff members listed below, met on
January 22, 1985, to review the collection of performance observations and
data to assess the licensee performance in accordance with the guidance in
NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance." A
summary of the guidance and evaluation criteria is provided in Section II of
this report.
This report is the SALP Board's assessment of the licensee's safety perfor-
mance at Crystal River Unit 3 for the period July 1, 1983, through
October 31, 1984.
SALP Board for Crystal River Unit 3:
J. P. Stohr, Director, Division of Radiation Safety and Safeguards (DRSS),
Region II (RII) (Chairman)
P. R. Bemis, Director, Division of Reactor Safety (DRS), RII
R. D. Walker, Director, Division of Reactor Projects (DRP), RII
D. L. Zeiman, Chief, Procedures and Systems Review Branch, Division of
Human Factors, Office of Nuclear Reactor Regulation (NRR)
V. L. Brownlee, Chief, Projects Branch 2, DRP, RII
Attendees at SALP Board Meeting:
V. W. Panciera, Chief, Projects Section 2B, DRP, RII
H. Silver, Project Manager, Operating Reactors Branch 4, Division of
- Licensing, NRR
T. Stetka, Senior Resident Inspector, Crystal River, DRP, RII
J. Tedrow, Resident Inspector, Crystal River, DRP, RII
R. Carroll, Project Engineer, Projects Section 28, DRP, RII
D. S. Price, Reactor Inspector, Technical Support Staff (TSS), DRP, RII
T. C. MacArthur, Radiation Specialist, TSS, DRP, RII
C. M. Upright, Chief, Quality Assurance Program Section, DRS, RII
D. R. McGuire, Chief, Physical Security Section, DRSS, RII
W. E. Cline, Chief, Emergency Preparedness Section, DRSS, RII
F. Jape, Chief, Test Program Section, DRS, RII
D. M. Montgomery, Chief, Independent Measurements and Environmental "
Protection Section, DRSS, RII -
J. J. Blake, Chief, Materials and Processes Section, DRS, RII
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II. CRITERIA
Licensee performance is assessed in selected functional areas, depending
upon whether the facility is in a construction, preoperational, or operating
phase. Each functional area normally represents areas which are significant
to nuclear safety and the environment, and which are normal programmatic
areas. Some functional areas may not be assessed because of little or no
licensee activities or lack of meaningful observations. Special areas may
be added to highlight significant observations.
One or more of the following evaluation criteria were used to assess each
functional area.
A. Management involvement and control in assuring quality
B. Approach to resolution of technical issues from a safety standpoint
C. Responsiveness to NRC initiatives
D. Enforcement history
E. Reporting and analysis of reportable events
F. Staffing (including management).
G. Training effectiveness and qualification
However, the SALP Board is not limited to these criteria and others may have
been used where appropriate.
Based upon the SALP Board assessment, each functional area evaluated is
classified into one of three performance categories. The definition of
these performance categories is:
Category 1: Reduced NRC attention may be appropriate. Licensee manage-
ment attention and involvement are aggressive and orientated toward nuclear
safety; licensee resources are ample and effectively used so that a high
level of performance with respect to operational safety or construction is
being achieved.
Category 2: NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are concerned
with nuclear safety; licensee resources are adequate and are reasonably
effective so that satisfactory performance with respect to operational
! safety or constr0ction is being achieved.
Category 3:. Both NRC and - licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers
nuclear safety, but weaknesses are evident; licensee resources appear to be
strained or not effectively used so that minimally satisfactory performance
with respect to operational safety or construction is being achieved.
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'The SALP Board has also categorized the performance trend over the course of
the SALP assessment period. The trend is meant to describe the general or
prevailing tendency (the performance gradient) during the SALP period. This
categorization is not a comparison between the current and previous SALP
ratings; rather the categorization process involves a review of performance
during the current SALP period and categorization of the trend of perfor-
mance during that period only. The performance trends are defined as
follows:
Improving: Licensee performance has generally improved over the course of
the SALP assessment period.
Constant: Licensee performance has remained essentially constant over the
course of the SALP assessment period.
Declining: Licensee performance has generally declined over the course of
the SALP assessment period.
III. SUMMARY OF RESULTS
Overall Facility Evaluation
The Crystal River Facility was effectively managed and has achieved a
satisfactory level of operational safety. Strength was noted in the
maintenance area. Weaknesses were noted in the areas of surveillance
and security. Management involvement has resulted in improved plant
availability. The plant operations area has shown improvement due to
increased procedure adherence, increased operating knowledge by the staff,
and reduced operating shift turnover. The surveillance area, however, has
shown continuing performance degradation primarily due to the licensee's
failure to take adequate corrective action to 4revent the recurrence of
previously identified problems. There has been some decrease in performance
in the radiological control area primarily due to weaknesses in chemistry
technician training. The maintenance area has shown improvement; however,
the problem with adequate control over management of contract personnel is-
still apparent. It should be noted that serious problems associated with
_ Licensed Operator Training Program documentation were identified subsequent
to the end of the assessment period. These deficiencies will be discussed
in the next SALP Report.
Trend During
July 1,1982 - July 1, 1983 - Latest SALP
Functional Area June 30, 1983 October 31, 1984 Period
Plant Operations 2 2 Improving
Radiological Controls 1 2 Constant
Maintenance 2 1 Improving <
Surveillance 2 3 Declining
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Trend During
July 1,1982 - July 1, 1983 - Latest SALP
Functional Area June 30, 1983 October 31, 1984 Period
Fire Protection 2 Not Rated Not Determined
Emergency Preparedness 2 2 Constant
Security 2 3 Declining
Refueling 1 Not Rated Not Determined
Quality Programs and 2 2 Declining
Administrative Controls
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Affecting Quality
Licensing Activities 2 2 Improving
IV. PERFORMANCE ANALYSIS
A. Plant Operations
1. Analysis
During this evaluation period, inspections of plant operations
were performed by the resident and regional inspection staffs.
Management involvement and control to assure quality of operations
has been satisfactory and was evident in the approach to reso-
lution of technical issues and responsiveness to the NRC. Major
operational decisions were made at a management level adequate to
assure appropriate supervisory involvement. The organizational
restructuring that took place during the last assessment period
has resulted in improvement in this area. The plant had a very
successful operating cycle during this assessment period as
evidenced by increased operating time and a minimum of enforcement
issues. This demonstrated increased experience and familiarity
with plant operation by the operations staff.
Two instances of inadequate control of plant operations were
observed. One instance that occurred in August 1983 resulted in a
. reactor trip due to operator error during a plant startup. The
other instance occurred in August 1984 when the containment
internal pressure was allowed to approach the technical specifica-
tion limit of 17.7 psia because timely action was not taken to
maximize containment cooling. This event resulted in a consid-
erable expenditure of time for both the licensee and NRC staffs
and required the use of a system which was neither designed to nor
- met the requirements for containment purging. Specific NRC
a'pproval was given to use this system to correct the pressure
Concern.
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Six reactor trips from power operation occurred during the assess-
ment period. Five of these trips were caused by equipment
failures and one by operator error. The plant had several
scheduled short-term maintenance shutdowns. These shutdowns were
well planned as evidenced by the excellent performance exhibited
in meeting schedule commitments. A modified startup from the
refueling outage at the beginning of the assessment period had to
be conducted with only three of the four reactor coolant pumps
available due to pump seal degradation. This startup and post-
refueling testing was witnessed by the NRC staff and was found to
be done well.
Operations staffing and training were adequate. Because there has
been little licensed operator turnover, there has been good
continuity in understanding and implementing plant procedures and
practices. The addition of a sixth operating shift has improved
morale and allowed the staff additional time to improve plant
operating procedures and practices without the use of excessive
overtime. There was, however, a moderate turnover of non-licensed
operators which might affect the input into the licensed operator
program and could result in a future shortage of licensed
operators. In addition, findings by an NRC training assessment
team subsequent to the end of the assessment period uncovered
problems associated with Licensed Operator Training Program
documentation. Such problems could also affect the availability
of onshift licensed operators.
Three operator licensing examination visits were conducted during
the evaluation period. Written and operating examinations were
administered. Five reactor operator, eight senior reactor opera-
tor, and five senior reactor operator / instructor certification
examinations were administered. All of the operator and senior
reactor operator candidates passed their examinations and received
licenses. Four instructor candidates passed and received certifi-
cates. This performance demonstrates a very good passing rate
with regard to initial licensed operator training.
The information provided in the narrative sections of the Licensee
Event Reports (LERs) was sufficient to provide a good under-
standing of the event. There were no significant problems with
the coded information provided by the licensee. The descriptions
of the events were adequate. The apparent cause of the occur-
rences was explained and well documented. When the licensee
promised to issue an updated report, it was submitted. Addi- ,
tionally, in most cases the licensee referenced the LERs per-
taining to previous events of similar nature. Multiple events
were combined correctly in a single LER in accordance with NRC '
guidelines.
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Two of the violations identified below involved procedural
adequacy and approval. The procedural adequacy violation
indicated a problem in the procedure review and approval process.
While some improvements have been made in this area, procedure
processing problems continue to exist. The procedure approval
violation indicates a reluctance on the part of operations
personnel to use a temporary approval process, rather than the
more time consuming permanent approval procedure. This appears to
have been resolved as evidenced by the expanded use of the
temporary procedure change method when timely changes were needed,
and by the reduction of the procedure change backlog. However,
additional management attention to the procedure review and
approval process is necessary in order to reduce the time needed
to implement a change.
Three violations were identified and are not indicative of a
programmatic breakdown:
a. Severity Level IV violation for failure to perform inde-
pendent verification of electrical switch and breaker
alignments.
b. Severity Level IV violation for an inadequate operations
procedure that resulted in violating a Technical Specifi-
cation limiting condition for operation.
c. Severity Level V violation for performing plant operations
using unapproved procedures.
2. Conclusions
Category: 2
Trend: Improving
3. Board Recommendations
The licensee's use of resources in this areas was reasonably
effective. The Board believes, however, that the moderate
turnover rate of non-licensed operators could create future
problems in the supply of experienced licensed operator candi-
dates. Additionally, a recent training a:;sessment has uncovered
apparent problems of a programmatic nature in the operator
licensing training program. These apparent problems will be
addressed in the next SALP assessment. No change in the level of
NRC staff resources applied to the routine inspection program is
recommended.
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B. Radiological Controls
1. Analysis
During the evaluation period, inspections were conducted by the
resident and regional inspection staffs.
The radiation protection program continues to exhibit improvement
with the upgrading of procedures, increased management attention,
and improved training programs for Health Physics Technicians.
Management involvement was evident in the approach to resolution
of technical issues and responsiveness to the NRC.
The licensee's health physics staffing level was adequate and
compared well to other utilities having a facility of similar
size. An adequate number of ANSI qualified licensee and contract
health physics technicians were available to support routine and
outage operations. The performance of the health physics staff in
support of routine operations and outages was adequate.
The ALARA management program continued to be very well managed.
The facility's man-rem total for the evaluation period was 108.6
man rem. This value is well below average for a single unit
pressurized water teactor.
During the evaluation period, the licensee disposed of 23,944
cubic feet of solid radioactive waste. The radioactive material
shipping area was generally well managed, although it accounted
for one violation listed below. The liquid and gaseous effluent
release program was well managed, with evidence that all releases
were adequately and effectively monitored.
Confirmatory Measurements and Environmental Inspections were
conducted during the evaluation period. Results of split sample
analyses conducted between licensee and the Region II Mobile
Laboratory Ge(Li) detectors were satisfactory. The confirmatory
measurements inspection identified a need for the licensee to
evaluate two items: effect of high dead-time on Ge(Li) detector
accuracy and evaluation of systematically high measurements of
gaseous radioactivity. The inspection also determined that
licensee identified problems in the radio-chemistry and chemistry
cross check programs were not resolved in a timely manner. As a
result of previously identified items, the licensee upgraded their
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, site meteorological program. The ensuing changes were undergoing
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' evaluation at the close of this SALP evaluation period. All other
aspects of the radiological measurements and environmental
programs were adequate.
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An area of weakness concerning chemistry personnel and procedures
was identified. The weakness involved the failure to follow
chemistry procedures which, in this instance, indicated a lack of
adequate personnel training. Although some improvements were
made, subsequent observations by the NRC of chemistry department
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activities indicated continuing problems with procedure adherence
and adequacy. In addition, it appeared that chemistry department
personnel may not have had sufficient system training. A recent
violation (violation 1 in the surveillance section below) was the
result of lack of attention by chemistry personnel, and procedure
inadequacy. The root cause which led to this violation had been
previously identified by Florida Power Corporation and corrective
actions initiated. However, the corrective actions were not
sufficient to prevent this recent violation.
A post accident sampling system (PASS) inspection identified the
system to be inoperable due to its inability to return a sample to
containment in accordance with the licensee's procedure. This
resulted from conflicting procedures creating contradictory valve
alignments. The licensee had not determined the system to be
inoperable because they were unaware of the contradictory proce-
dures.
The following violations were identified and are not indicative of
a programmatic breakdown:
a. Severity Level IV violation for failure to identify that the
PASS was inoperable.
b .~ Severity Level IV violation for failure to follow Chemistry
and Radiation Protection procedures.
c. Severity Level V violation for failure to adequately deter-
mine the quantity of radioactive material delivered for
transport.
d. Severity Level V violation for failure to use properly
calibrated equipment to perform instrument calibrations.
e. Severity Level V violation for use of a chain and padlock to
control access to a high radiation area.
2. Conclusion
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Category: 2
Trend: Constant
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3. Board Recommendations
Management attention in this area was evident. It appears,
however, that additional management attention is needed to address
weaknesses in the training of chemistry personnel and procedural
compliance. No change in the level of NRC staff resources applied
to the routine inspection program is recommended.
C. Maintenance
1. Analysis
During this evaluation period, inspections were conducted by the
resident inspection staff.
The maintenance program continued to show improvement due to high
management involvement in maintenance planning and practices.
There continued to be improvement in the area of procedure
adherence. First line supervisors and maintenance personnel
continued to indicate a high awareness for procedure adherence.
The maintenance department has made substantial progress in
revising procedures to make them more user-oriented. This
contributed to the improved procedure adherence attitudes of
facility personnel.
In most areas, the licensee's approach to the resolution of tech-
nical issues continued to be sound. This was evidenced by the
conservative decision to replace reactor coolant pump seals
showing degradation, final resolution of the hydraulic snubber
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failure problem, replacement of the leaking steam generator
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feedwater nozzle, and the replacement / repair of plant equipment
when degradation evidence was indicated by the predictive mainte-
nance program.
Preplanning for outages was a strength of the maintenance program.
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Even for outages of short duration, the work was properly planned
with regard to scope, repair pcrts and work procedures. The use
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of a predictive maintenance analysis was a strength of the
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licensee's program. This technique has enabled the licensee to
predict degrading trends in equipment performance and effect
repairs before equipment failure occurs. Additionally, the
licensee has coordinated the surveillance testing of equipment
with the preventive maintenance program to minimize equipment
downtime and excessive equipment starts.
The weakness identified by violation b, failure to properly
schedule or plan a maintenance activity, has been strengthened "
through the requirement that representatives from the various
shops attend the shift turnover meetings held at the beginning of
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each operating shift. Observations by the NRC indicate that this
has been effective in assuring that the operations shift was aware
of ongoing plant activities.
The licensee was still very reliant on contractor personnel to
conduct a major portion of their plant modifications and to
perform selective testing. An apparent problem continued to exist
in those instances where large tasks were turned over to a
contractor without direct licensee management oversight to ensure
adequate control. Violations a and c were the result of the
inadequate control placed over contractor personnel under such
circumstances.
An observed weakness during the previous SALP period, failure to
follow codes and regulatory requirements, has been corrected.
Three violations were identified and are not indicative of a
programmatic breakdown:
a. Severity Level IV violation for failure to conduct adequate
post maintenance / modification inspections resulting in
equipment not being returned to proper status.
b. Severity Level IV violations for failure to properly schedule
or plan a maintenance activity.
c. Severity Level IV violations for failure to follow a main-
tenance procedure.
2. Conclusion
Category: 1
Trend: Improving
3. Board Recommendations
A high level of performance was achieved in this area, however,
increased management oversight of contractor activities appears
warranted. .The Board was particularly impressed with the success
of the licensee's predictive maintenance program.
Because licensee performance at a Category I level has only been
recently achieved, and because NRC inspection activity in this
area has been limited, no change in the level of NRC staff
resources applied to the routine inspection program is recom-
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mended.
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D. Surveillance
1. Analysis
During this evaluation period, routine inspections were performed
by the resident and regional inspection staffs.
Two weaknesses evident in the surveillance area were the methods
of issuing new procedures and revising existing procedures. The
surveillance procedure responsibility has been assigned to the
plant engineering and technical services group. There were
indications that this group had insufficient input from other
groups (e.g., operations, instrumentation and control, etc.) which
contributed to the issuance of inadequate surveillance test
procedures.
There has also been a continuing problem in the instrumentation
calibration program. This problem was originally identified
during the last SALP period. The weaknesses in the licensee's
corrective action program and control of contracted personnel
contributed to these problems. The licensee has expended
considerable effort in utilizing its own personnel to resolve
these problems .and in providing an effective calibration program.
Initial review efforts by NRC indicate that the licensee's efforts
should be effective in improving the calibration program.
Routine and post-refueling core performance tests were witnessed
and the results reviewed. All of the associated surveillance
procedures 'were adequate and were acceptably performed. Indepen-
dent measurements of reactor coolant system leakage gave accept-
able results. However, the licensee's surveillance procedure in
use at the time did not provide corrections for changes in average
temperature or pressurizer level. The need for such corrections
had been identified to the licensee several months prior to the
inspection; however, it took an excessively long time for the
corrections to be added to the procedure.
An additional area of weakness involved microfilming. Microfilm
records of surveillance procedures were found to have been poorly
organized prior to microfilming. The microfilms were unreadable
in many cases. There were no apparent standards imposed on the
quality of the material to be filmed.
Inspections were performed in the area of inservice testing (IST)
of pumps and valves. One weakness identified in this area was
that the licensee was not maintaining a summary listing of the
status of the IST pumps and valves.
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.An inspection was made of the licensee's secondary water chemistry
program. It was noted that while the licensee has not fully
endorsed the " Steam Generator Owners Group / Electrical Power
Research Institute" guidelines, the water chemistry program was
considered acceptable and was being implemented by well trained
personnel using state-of-the-art sampling systems and analytical
instrumentation. Some items of technical concern were being
reviewed by licensee management because of serious economic
questions which must be answered. These concerns included
continual failure of CuNi condenser tubes; rapid depletion of the
condensate cleaning system; and the seemingly generic. issue of the
build-up of sludge in the once-through steam generators to the
point that power reductions were required because of secondary
flow problems.
During the evaluation period, an inspection in the area of
containment leak rate testing was performed involving the wit-
- nessing of the containmert integrated leak * ate test (CILRT). No
deviations or violations were identified. Management involvement
in planning and performance of the CILRT was satisfactory. The
test procedure was in compliance with Appendix J to 10 CFR 50.
Test deviations were minor and quickly resolved.
Violations in this area have covered all aspects of surveillance
testing including failure to adhere to procedures (5 violations),
failure to perform surveillance testing _ when required (3 viola-
tions), failure to perform adequate surveillance tests (2 viola-
tions), and failure to use calibrated instrumentation during the
performance of surveillance testing (3 violations).
Many of these violations were recurrent in nature which indicates
that the licensee's corrective actions have not been effective.
For example, two of the violations (violations e and 1), involving
the use of uncalibrated instrumentation, occurred on two separate
occasions during the performance of the same surveillance test
procedure by operations personnel. Violation m, again involving
use of an uncalibrated instrument, was also caused by operations
personnel. If adequate corrective actions were taken when
violation m had occurred (i.e., ensuring that all personnel
verified use of calibrated instrumentation prior to test perfor-
mance), then violations e and i may not have occurred.
Fourteen violations were identified:
a. Severity Level IV violation for failure to perform a surveil-
lance every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
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b. Severity Level IV violation for failure to follow surveil-
lance procedures.
c. Severity Level IV violation for failure to perform an
adequate surveillance test.
d. Proposed Severity Level IV violation for failure to follow a
surveillance procedure.
e. Severity Level IV violation for failure to use calibrated
instrumentation during performance of a surveillance
requirement. ,
f. Severity Level IV violation for failure to follow surveil-
lance procedures and for failure of supervisors to review
completed surveillance data to detect anomalies,
g. Severity Level IV violation for failure to perform an instru-
ment calibration.
h. Severity Level IV violation for failure to follow surveil-
lance procedures.
i. Severity Level IV violation for failure to use a calibrated
instrument during the performance of a surveillance proce-
dure.
J. Severity Level IV violation for an inadequate surveillance
procedure.
k. Severity Level IV violation for failure to follow surveil-
lance procedures.
1. Severity Level IV violation for failure to perform a surveil-
lance test after a greater than 15% power change.
m. Severity Level V violation for failurc to use a calibrated
instrument during the performance of a surveillance require-
ment.
n. Severity Level V violation for failure to maintain a summary
list of pumps and valves to display the current status of the
test program.
2. Conclusion
Category: 3 '
Trend: Declining
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3. Board Recommendations
Management involvement in this area should be increased. Greater
quality assurance involvement in surveillance activities, and
increased management oversight of this quality assurance involve-
ment and of the implementation of corrective actions to prevent
recurrent problems, are needed. The Board recommends that NRC
staff resources applied to the routine inspection program be
increased.
E. Fire Protection
1. Analysis
During this assessment period, limited inspections were conducted
by the resident inspection staff. These inspections encompassed
the implementation of the plant's fire protection program. No
discreprancies were identified. The most recent in-depth review
of the licensee's fire protection program was in November 1981.
2. Conclusion
Category: Not Rated
Trend: Not Determined
3. Board Comment
There was insufficient activity in this area during the appraisal
period to justify a rating.
1. Analysis
During the assessment period, inspections were performed by the
resident and regional inspection staffs. These included observa-
tion of an exercise, and inspections addressing emergency
responses and related implementing procedures. The exercise
involved substantial State and local participation.
Routine inspections and exercise observations disclosed that the
emergency organization and staffing were adequate. An adequately
staffed corporate emergency planning organization provided support
to the plant. Key positions in the corporate and plant emergency
response organizations were filled. Corporate management was
'directly included in the annual exercise and followup critique. "
The licensee has been responsive to NRC initiatives.
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During the last evaluation period, the need for management atten-
tion to training of personnel assigned to emergency organizations
was identified. Although improvement in this area was achieved
and most of the outstanding training items were resolved, training
weaknesses continued to persist. More than one third of the
inspector followup items identified during the current evaluation
period involved training. Weaknesses were largely confined to
team activities and procedural reviews. These issues are expected
to be closed during 1985. Generally, however, key personnel
assigned to emergency organizations were cognizant of their
responsibilities and authorities, and understood their assigned
functions during routine operations and simulated emergency
situations.
The following essential elements for emergency response were found
acceptable: Emergency worker protection; post accident measure-
ments and instrumentation; changes to the emergency preparedness
program; and annual quality assurance audits of plant and corpor-
ate emergency planning programs. The exe cise demonstrated that
the emergency plan and procedures could be implemented by the
licensee's staff, although some difficultees were noted in the
adequacy of radiological assessment and prompt notification
procedures, and the transfer of authority from the Shift Super-
visor to the Emergency Coordinator. Observation of the subject
exercise disclosed one violation regardinr the adequacy of radio-
logical assessment.
An adequate working relationship appeared to exist between the
licensee and offsite emergency support agencies.
During this evaluation period, three violations were identified
regarding the licensee's implementation of the Emergency Planning
Program and procedures and related Technical Specifications. The
violations are listed below.
a. Severity Level IV violation disclosed an inadequate imple-
menting procedure addressing the " Initial Assessment" portion
of EM-204, " Release and Offsite Dose Assessment during Radio-
logical Emergencies at CR-3."
b. Severity Level V violation for a failure to specify the use
of the child thyroid dose in making dose assessments.
c. Severity Level V violation for a failure to maintain written
procedures for emergency plan implementation.
2. Conclusion
Category: 2
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Trend: Constant
3. Board Recommendations
Management attention in this area was evident, however, additional
attention and program improvements are needed in the area of
radiological assessment of emergencies. No change in the level of
NRC staff resources applied to the routine inspection program is
recommended.
G. Security
1. Analysis
During this evaluation period, inspections were conducted by the
resident and regional inspection staffs.
Although the licensee demonstrated some evidence of prior planning
and prioritization of safeguards matters, there remained a long
standing regulatory issue relating to the functional capability of
the protected area intrusion detection system. The licensee has
initiated a study to address this issue, however, a schedule for
implementation and completion of adequate corrective action has
not yet been established. Aggressive management attention and
involvement are needed to ensure improvement in this area.
Inspection observations and findings indicate that the licensee
tended to rely on the NRC to identify problems and contractors to
provide solutions rather than maintaining a rigorous self-audit
and evaluation program. In addition, licensee personnel did not
always exhibit a thorough understanding of the approved physical
security plan and associated procedures. The apparent lack of
program understanding resulted in six of the violations identi-
fled. The continued occurrence of violations that adversely
impact security effectiveness indicates inadequate management
support of the security program.
.
The licensee was generally responsive to NRC concerns. In
response to one such concern, the licensee completely revised the
physical security plan to improve its readability and reduce
internal inconsistencies and ambiguities.
The licensee maintained an effective security training qualifica-
tion program which has produced well-trained security personnel.
The licensee security management staff and the contractor security
force were adequately staffed.
. _ _ .
__
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18
Although one violation resulted from the licensee's failure to
report a safeguards event within the prescribed time, required
reports were generally provided in a timely manner.
The violations indentified below, of which item a. was cited as a
Severity Level III problem and associated civil penalty, resulted in
general from inadequate understanding and support of the security
program _by licensee management and failure of personnel to adhere
to established procedures. It should be noted that late in the
assessment period, there ,as an apparent improvement in management
support of the security program. However, this trend occurred too
late to show a meanine'ul improvement during this period.
a. Proposed Severity Level III problem composed of two violations
for failure to fully implement and maintain in effect certain
provisions of the NRC approved physical security plan.
b. Severity Level IV violation for failure to identify an
unsecured opening in a Vital Area barrier.
c. Severity Level IV violation for having an unescorted visitor
in a Vital Area.
d. Severity Level IV violation for failure to provide portions
of the alarm system with a tamper-indication feature.
,
e. Severity Level IV violation for failure to control protected
area access.
f. Severity Level IV violation for failure to maintain security
equipment in an operable condition,
g. Severity Level IV violation for failure to report a safe-
guards event within prescribed time limits.
2. Conclusion
.
Category: 3
Trend: Declining
3. Board Recommendations
Licensee management attention and involvement in this area should .
be. increased and security issues should be viewed with a higher
priority by management. The Board recommends that NRC staff
resources applied to the routine inspection program be increased.
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H. Refueling
1. Analysis
No refueling outage occurred during the assessment period.
2. Conclusion
Category: Not Rated
Trend: Not Determined
3. Board Recommendations
Because no refueling outages occurred during the assessment
period, there was insufficient inspection activity to justify a
rating.
I. Quality Programs and Administrative Controls Affecting Quality
1. Analysis
During this assessment period, inspections were performed by the
resident inspection staff.
On June 10, 1983, the licensee submitted for NRC review, a revised
Quality Assurance (QA) program. Comments were generated by NRC
based upon a review of the program and were submitted to the
licensee. Based on a meeting held between NRC and the licensee to
discuss the QA Program and the _ licensee's response to NRC
questions, the QA program description was considered acceptable.
Problems were identified during this assessment period concerning
the licensee's corrective action system. A problem had been
previously identified with the correction and maintenance of
procedures. In an attempt to verify licensee currective action on
this issue, NRC personnel walked down five safety-related systems.
Additional problems were identified in that procedure valve
line-ups did not accurately reflect actual plant conditions. This
resulted in violation a listed below.
The licensee's response included procedure revisions addressing
the specific inadequacies identified, and a plant walkdown of
additional systems. The long-term corrective action included
establishment of policy for the type of valves to be included in
valve line-ups.
<
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During the previous SALP reporting period, a problem was identi-
fied with the calibration of Section XI instruments used for
testing. In addition to calibrating the necessary instrumentation
prior to the Cycle 5 startup, the licensee's corrective action
included an evaluation of all systems which were subject to IST
requirements to determine if any were inoperable due to out-of-
calibration instrumentation. While attempting to verify comple-
tion of the licensee's corrective action, the NRC identified that
not all IST related instrumentation had been calibrated and that
the evaluation of the effect of uncalibrated instrumentation upon
the operability of systems was not performed. This resulted in
the deviation listed below.
Both of the above problems required timely and defilitive correc-
tive action. The final corrective action for bot 1 items was
adequate; however, management attention was not sufficiently
focused to assure that commitments were completed within stated
timeframes.
These two examples, when combined with examples discussed in the
surveillance section of this report, indicate a lack of management
corrective action control. The corrective action system in these
examples was not complete, did not prevent recurrence, and was not
timely within the boundary established by management.
One violation and one deviation were identified:
a. Severity Level IV violation for failure to complete correc-
tive action as specified in response to an NRC violation.
b. Deviation for failure to complete corrective action in
response to an NRC violation.
2. Conclusion
Category: 2
Trend: Declining
3. Board Recommendations
Management involvement in this area was evident. However,
licensee management should ensure that attention is directed to
the quality assurance staff's effective involvement with all
facility programs affecting quality. No change in the level of
NRC staff resources applied to the routine inspection program is
recommended. 6
.
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, .
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J. Licensing Activities
1. Analysis
The licensee continued to modify its management structure by
adding a layer of management between the licensing and engineering
organizations, and the Vice President, Nuclear. This should have
the effect of increasing the management attention devoted to these
organizations. The licensee has developed an effective computer-
ized tracking system for its NRC licensing commitments, and an
excellent program to track progress on items in the equipment
qualification program. Improvement has been noted in the extent
and consistency of management involvement and control since the
last SALP report. This is illustrated by the demonstrated
increased management involvement brought to bear in finally
resolving an auxiliary feedwater system issue, and by the effec-
tive performance in resolving environmental qualification issues.
On the other hand, issues of less significance did not always
attract sufficient management attention. A logical extension of
these efforts would include application to integrated schedules
for all principal plant activities.
In general, the licensee's approach to resolution of technical
issues demonstrated an adequate understanding of those issues and
resulted in sound and timely resolutions. In the area of environ-
mental qualification, the licensee's action was prompt and
effective in producing sound substantiation of qualification.
However, in some areas, this was not always the case. Licensee
approaches to the resolution of issues sometimes lacked thorough-
ness and depth. For example, in the Tect..:ical Specification
amendment for the decay heat removal system, the licensee's
submittal did not include an adequate safety evaluation. In the
licensee's original proposal for modified steam generator operat-
ing level limits, the licensee requested a maximum level which had
not been shown to be acceptable, and in the issue of an alternate
off-site power supply, the licensee initially and unnecessarily
requested an emergency Technical Specification amendment.
Finally, the licensee's approach to the request to vent the
containment on a one-time basis to relieve high containment
pressure did not indicate that adequate prior planning had taken
place to avoid the problem, or that the proposed resolution had
been thoroughly thought through. In all the cases which have been
completed, adequate resolution was obtained after interaction with
the NRC staff.
Responsiveness to NRC licensing matters was in general considered-
"
adequate. In the area of the auxiliary feedwater system eval-
uation, responsiveness was considerably improved, leading to ;
timely resolution of outstanding issues. Similarly, the licensee ,
i
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'
responded quickly and well to an environmental qualification
meeting and to subsequent staff requests for additional infor-
mation. .Several other individual actions were also rated highly
with regard to responsiveness. On the other hand, the licensee
required frequent extensions of time to respond to NRC requests
for additional information regarding the post-accident sampling
system review. Unresolved issues still remain in this area.
In summary, the licensee's responsiveness was generally judged to
be timely and prompt. Management involvement has increased and is
judged to be good and the licensee's approach to resolution of
technical issues demonstrated an adequate understanding in some
areas but in other areas, a lack of thoroughness caused delays in
the timely resolution of technical issues.
2. Conclusion
Category: 2
Trend: Improving
3. Board Recommendations
. More attention to detail during the next SALP period could produce
a Category I rating.
V. SUPPORTING DATA AND SUMMARIES
A. Licensee Activities
During the assessment period, the major licensee activities at Crystal
River included: normal power operations; post refueling start-up
testing; Type A containment integrated leak rate test; replacement of
leaking feedwater nozzle on a once-through steam generator; inspection
of inaccessible hydraulic snubbers; and replacement of control rod
drive stators.
_
B. Inspection Activities
During the assessment period, the routine inspection program was
conducted by the resident and regional inspector staff.
C. Licensing Activities
The performance assessment was based on NRC evaluation of the
licensee's performance in support of licensing actions that had a
significant level of activity during the evaluation period. These
actions included licensee requests for license amendments and for
exemptions or relief from regulatory requirements, responses to generic
letters, and variods submittals of information for multi plant and TMI
items. Active actions during this period are classified below. A
total of 39 licensing actions were completed.
e s -
23
23 Plant-specific actions (19 completed): Actions included in
this category which were used to provide input for this evaluation
were:
-
On-Line Emergency Safeguards Logic Testing
-
Fuel Pool Enrichment Limit
-
Proposed Alternate Off-Site Power Supply
- Decay Heat Removal System
-
Administrative Control of Containment Isolation
Valves
-
Physical Security Plan Revisions
-
High Radiation Area Technical Specifications (TS)
-
Steam Generator Operating Level Limits
-
Auxiliary Building Ventilation System TS
- 16 Multi plant actions (9 completed): Actions included in this
category which were used to provide input for this evaluation
were:
-
Masonry Wall Design
-
Automatic Actuation of Shunt Trip Attachment
-
Environmental Qualification of Safety-Related
Electrical Equipment
-
Appendix I Review
-
Asymmetric LOCA Loads
- 18 TMI (NUREG-0737) actions (11 completed): Actions included in
this category which were used to provide input for this evaluation
were:
-
Post-Accident Sampling Modifications
-
Auxiliary Feedwater System Evaluation
-
High Point Vents
- ECC System Outages
D. Investigations and Allegations Review
No major investigation or allegation activities occurred during tnis
review period.
E. Escalated Enforcement Actions
1. Civil Penalties
One civil penalty of $50,000 was proposed for a Severity Level III
'
violation involving failure to fully implement and maintain
provisions for the physical security plan regarding vital area
protection. (Issue Date: January 10,1985)
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2. Orders (only those relating to enforcement)
No orders relating to enforcement matters were issued.
F. Management Conferences Held During Appraisal Period
An enforcement conference was held on September 2, 1983, to discuss an
apparent violation associated with vital area safeguards measures.
A management meeting was held on October 20, 1983, to review the
results of the first phase of NRC's appraisal of the licensee's
regulatory performance. -
A management meeting was held on December 20, 1983, to discuss a
forthcoming 10 CFR 50.54(p) change and other security related topics.
A management meeting was held on February 14, 1984, to discuss the
licensee's current management activities and future plans.
A management meeting was held on May 30, 1984, to discuss federal field
exercise experience, current regulatory requirements in the emergency
planning area, and scenario development issues.
A management meeting was held on June 6, 1984, to discuss the optional
quality assurance program.
An enforcement conference was held on September 6,1984, to discuss
three separate issues: failure to provide adequate vital area
barriers; failure to adhere to facility procedures; and calibration
program deficiencies.
G. Confirmation of Action Letters
No Confirmation of Action Letters were issued during this assessment
period.
.H. Review of Licensee Event Reports and 10 CFR 21 Reports Submitted by the
Licensee
During the assessment period, tcere were 55 LERs reported for the
facility. The distribution of these events by cause, as determined by
the NRC staff, was as follows:
Cause # LERs
Component Failure 23
Design '
2
Construction, Fabrication, or
Installation 2
Personnel
-
Operating Activity 5
.
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Cause # LERs
-
Maintenance Activity 5
-
Test / Calibration Activity 8
-
Other 3
Out of Calibration 1
Other 6
TOTAL 55
It was noted that 80% of the LERs fell into two categories:
component failures (42%); and personnel error (38%).
I. Inspection Activity and Enforcement
FUNCTIONAL NO. OF VIOLATIONS IN EACH SEVERITY LEVEL
AREA V IV III II I
Plant Operations 1 2
Radiological Controls 3 2
Maintenance 3
Surveillance 2 12**
Fire Protection
Security 6 1*
Refueling
Quality Programs and 1
Administrative Controls
Affecting Quality
TOTAL 8 27** 1*
This represents a proposed Severity Level III problem composed of two
violations in the area of security.
- One of the twelve Severity Level IV violations in the area of
.
surveillance is proposed.
..
C