ML20138J729
| ML20138J729 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 01/31/1997 |
| From: | Jaudon J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Beard P FLORIDA POWER CORP. |
| References | |
| EA-96-365, EA-96-465, EA-96-527, NUDOCS 9702070470 | |
| Download: ML20138J729 (81) | |
Text
.
January 31, 1997 i
EA 96-365 EA 96-465 EA 96-527 Florida Power Corporation Crystal River Energy Complex Mr. P. M. Beard, Jr. (SA2A)
Sr. VP, Nuclear Operations ATTN: Mgr., Nuclear Licensing 15760 West Power Line Street Crystal River FL 34428-6708
SUBJECT:
MEETING SUV, MARY - PREDECISIONAL ENFORCEMENT CONFERENCE CRYSTAL RIVER 3 - DOCKET NO. 50-302 p
Dear Mr. Beard:
This refers to the meeting on January 24, 1997, at the Region II office in Atlanta, Georgia. The purpose of the meeting was to discuss ap)arent violations regarding inadequate design control, inadequate 10 C R 50.59 Safety Evaluations and inadequate corrective actions.
The apparent violations are associated with the Emergency Diesel Generators, the Emergency Feedwater System, and containment penetrations.
It is our opinion, that this meeting was beneficial to our understanding of the issues.
Enclosed is a list of attendees, NRC's presentation material, and Florida Power Corporation's presentation material.
In accorJance with Section 2.790 of NRC's " Rules of Practice," Part 2.
Title 10 Code of Federal Regulations, a co)y of this letter and its enclosures will be placed in the NRC Public Document Room.
Should you have any cuestions concerning this meeting, please contact Mr. K. Landis at (404) 331-5509.
Sincerely, (Original signed by Johns P. Jaudon)
Johns P. Jaudon, Director Division of Reactor Safety EA 96-355 EA 96-465 EA 96-527 Docket No.
50-302 License No.
DRP-72
Enclosures:
1.
List of Attendees NRC Presentation Material 3.
FPC Presentation Material
() 7 n A e e.
OFFICIAL COPY T
9702070470 970131 g
PDR ADOCK 05000302 G
PDR ggy[.
4 i
FPC 2
cc w/encls:
Gary L. Boldt, Vice President i
Nuclear Production (SA2C)
FPC. Crystal River Energy Complex 15760 West Power Line Street Crystal River, FL 34428-6708 B. J. Hickle, Director Nuclear Plant Operations (NA2C)
FPC. Crystal River Energy Complex 15760 West Power Line Street Crystal River, FL 34428-6708 L. C. Kelley, Director (SA2A)
Nuclear Operations Site Support FPC. Crystal River Energy Complex 15760 West Power Line Street Crystal River. FL 34428-6708 R. Alexander Glenn. Corporate Counsel FPC, MAC - ASA P. O. Box 14042 St. Petersburg. FL 33733-4042 Attorney General Department of Legal Affairs The Capitol Tallahassee. FL 32304 Bill Passetti Office of Radiation Control De)artment of Health and Relabilitative Services 1317 Winewood Boulevard Tallahassee. FL 32399-0700 J
Joe Myers. Director Division of-Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, FL 32399-2100 Chairman Board of County Commissioners Citrus County 110 N. Apopka Avenue Inverness. FL 34450-4245 Robert B. Borsum Framatome Technologies 1700 Rockville Pike, Suite 525 Rockville, MD 20852-1631
FPC 3
Distribution w/encls:
L. Raghavan NRR B. Crowley. RII J. Lieberman OE B. Uryc. RII OE EA File (Attn: B. Summers. OE)
PUBLIC NRC Resident Inspector U. S. Nuclear Regulatory Commission 6745 N. Tallahassee Road Crystal River. FL 34428 i
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LIST OF ATTENDEES FLORIDA POWER CORPORATION l
l P. Beard. Senior Vice Preseident. Nuclear Operations G. Boldt. Vice President., Nuclear Production D. Kunsemiller. Director. Nuclear Site Services V. Baumstark. Quality Programs B. Hickle. Director. Nuclear Operations. FPC F. Sullian Manager. Nuclear Operations Engineering l
J. Terry. Manager Nuclear Plant Technical Support G. Halnon. Assistant Director Nuclear Site Support i
R. Anderson. Senior Vice President. Florida Power Corporation J. Cowan. Named Site Vice President. Crystal River M. Hendrix. Senior Public Relations Coordinator R. Grumbir Senior Simulation Engineer (Root Cause Team Leader)
R. Knoll. Supervisor. Fuel management and Safety Analysis l
K. Baker. Manager. Nuclear Configuration Management NUCLEAR REGULATORY COMMISSION l
E. Merschoff. Acting Deputy Regional Administrator Region II (RII)
J. Johnson Director. Division of Reactor Projects (DRP). RII J.. Jaudon. Director. Division Of React.or Safety (DRS). RII F. Hebdon. Director. Project Directorate (PD) II-3, Office of Nuclear Reactor l
Regulation (NRR)
K. Landis Chief. Branch 3. DRP. RII L. Raghavan. Project Manager. PD II-3, NRR G. Tracy. Senior Regional Coordinator. Office of the Executive Director foi Operations l
C. Casto. Chief. Engineering Branch. DRS. RII H. Christensen. Chief. Maintenance Branch DRS RII l
B. Uryc. Director. Enforcement and Investigations Coordination Staff (EICS).
RII l
C. Evans Regional Counsel, RII l
R. Bernhard. Senior Reactor Analyst RII J. Lenahan Reactor Inspector. DRS. RII I
R. Schin. Reactor Inspector. DRS. RII M. Thomas. Reactor Inspector. DRS. RII l
S. Cahill. Senior Resident Inspector. Crystal River. RII l
L. Watson. Enforcement Specialist. EICS. RII l
R. Hannah. Public Affair Officer. RII l
i l
t j
UNITED STATES i
NUCLEAR REGULATORY l
COMMISSION 8
4 l
i NRC OPEN PREDECISIONAL ENFORCEMENT CONFERENCE CRYSTAL RIVER 3 NUCLEAR PLANT MEETING January 24,1997
1
']
PREDECISIONAL ENFORCEMENT CONFERENCE AGENDA CRYSTAL RIVER 3 JANUARY 24,1997, AT 10:00 A.M.
NRC REGION 11 OFFICE, ATLANTA, GEORGIA 1.
OPENING REMARKS AND INTRODUCTIONS E. Merschoff, Acting Dupty Regional Administrator 11.
NRC ENFORCEMENT POLICY B. Uryc, Director Enforcement and Investigation Coordination Staff 111.
SUMMARY
OF THE ISSUES E. Merschoff, Acting Dupty Regional Administrator IV.
STATEMENT OF CONCERNS / APPARENT VIOLATION J. Jaudon, Director Division of Reactor Safety V.
LICENSEE PRESENTATION P. Beard, Senior Vice President, Nuclear Operations Florida Power Corporation VI.
BREAK / NRC CAUCUS Vll.
NRC FOLLOWUP QUESTIONS Vill.
CLOSING REMARKS E. Merschoff, Acting Dupty Regional Administrator
Q ISSUES TO BE DISCUSSED INADEQUATE 10 CFR 50.59 EVALUATIONS - FACILITY CHANGES 1
RESOLUTION OF UNREVIEWED SAFETY QUESTIONS EMERGENCY DIESEL GENERATOR LOADS INCREASED IN EXC e
OF LIMITS IN FSAR AND TECHNICAL SPECIFICATIONS REDUCING THE MARGIN OF SAFETY AUTOMATIC OPENING 0F ALTERNATE STEAM ADMISSION VA e
(ASV-204) TO TURBINE-DRIVEN EFW PUNP (TRAIN B PUMP CHANGED TO TRAIN A EFW INITIATION SIGNAL RESULTING IN POTENTIAL INCREASE IN PROBABILITY OF DAMAGE TO TURBINE-DRIVEN EFW PUMP REMOVAL 0F AUTOMATIC OPEN SIGNAL FROM VALVE ASV-204, e
DISABLING ONE AUTOMATIC STEAM SUPPLY TO TURBINE-DRIVEN EFW PUMP REDUCING RELIABILITY AND INCREASING PROBABILITY OF FAILURE PRIMARY METHOD OF PREVENTING BORON PARTICIPATION I e
CORE CHANGED T0 " GAP" METHOD, WHICH WAS NRC-APPROVED ONLY AS BACKUP i
NOTE:
THE APPARENT VIOLATIONS DISCUSSED IN THIS PREDECISIONAL ENFORCEMENT CONFERENCE ARE SUBJECT TO FURTHER REVIEW AND ARE SUBJECT TO CHANGE PRIOR TO ANY RESULTING ENFORCEMENT ACTION.
I
f 1,t i
INADEQUATE DESIGN CONTROL - INADEQUATE TRANSLATIO REQUIREMENTS INTO PROCEDURES AND INSTRUCTIONS AN PROCEDURE FOR VERIFICATION OF CALCULATIONS (10 CFR 50, APPENDIX B, CRITERION III)
FSAR, ENHANCED DESIGN BASIS DOCUMENT, AND TECHNICAL e
SPECIFICATIONS NOT UPDATED TO STATE THAT TURBINE-DRIVEN EMERGENCY FEEDWATER PUMP (EFP-2) ASSUMED RUNNING WHEN MOTOR-DRIVEN FEEDWATER PUMP (EFP-TRIPPED AT 500 PSIG FOR CERTAIN ACCIDENT SCENARIO FAILED TO EVALUATE CREDIT TAKEN FOR EFP-2 OPERAT e
AFTER EFP-1 TRIPPED WHEN RCS PRESSURE DECREASED BELOW 500 PSIG DURING SMALL BREAK LOCA CONCURRENT WITH LOOP AND FAILURE OF TRAIN B BATTERY WHEN AUTOMATIC OPENING 0F ASV-204 WAS DISABLED.
THIS PREVENTED THE AUTOMATIC START OF EFP-2 IN CERTAIN SCENARIOS AND RESULTED IN OPERATING OUTSIDE THE DESIGN BASIS AND IN NO EFW FOR A TIME DURING AN EVENT CALCULATION FOR OPERATING CURVE 15 DID NOT CORREC e
MODEL HEAT INPUTS TO NUCLEAR CLOSED CYCLE COOLING SYSTEM (SW)
ALLOWING A LARGER NUMBER OF SW HEAT EXCHANGER TUBES TO BE BLOCKED. SW HEAT EXCHANGER OUTLET TEMPERATURE COULD HAVE EXCEEDED DESIGN LIMIT AND SYSTEM NOT CAPABLE OF REMOVING DESIGN BASIS HEA FROM SAFETY RELATED EQUIPMENT PROCEDURE NEP-210 ALLOWED UNVERIFIED CALCULATIONS TO e
SUPPORT N0DIFICATION, INSTALLATION, AND RETURN TO SERVICE AND INCORRECT CONCLUSIONS THAT N0DIFICATIONS DID NOT CAUSE A EDG LOADING PROBLEM. A MODIFICATION BASED ON AN UNVERIFIED CALCULATION INTRODUCED AN UNREVIEWED SAFETY QUESTION WITH EDG LOADING NOTE:
THE APPARENT VIOLATIONS DISCUSSED IN THIS PREDECISIONAL ENFORCEMENT CONFERENCE ARE SUBJECT TO FURTHER REVIEW AND ARE SUBJECT TO CHANGE PRIOR TO ANY RESULTING ENFORCEMENT ACTION.
.,i a
INADEQUATE SURVEILLANCE PROCEDURE - DID NOT INCLUDE T SPECIFICATION SURVEILLANCE REQUIREMENTS
)
FOR APPR0XIMATELY 82 CONTAINMENT VALVES AND BLIND e
FLANGES, RESULTING IN FAILURE TO DEMONSTRATE OPERABILITY AS REQUIRED BY TECHNICAL SPECIFICATIONS i i
4 NOTE:
THE APPARENT VIOLATIONS DISCUSSED IN THIS PREDECISIONAL ENFORCEMENT CONFERENCE ARE SUBJECT TO FURTHER REVIEW AND ARE SUBJECT TO CHANGE PRIOR TO ANY RESULTING ENFORCEMENT ACTION.
O INADEQUATE CORRECTIVE ACTION - CORRECTIVE ACTION OR ADEQUATE TO PRECLUDE RECURRENCE (10 CFR 50, APPENDIX B, CRITERION XVI)
POTENTIAL EDG LOADING IN EXCESS OF TECHNICAL e
SPECIFICATIONS NOT CORRECTED IN A TIMELY MANNER CORRECTIVE ACTIONS FOR PREVIOUS FAILURES TO AD e
EDG LOADING IN 50.59 EVALUATIONS FAILED TO PREVEN H0DIFICATIONS WITH UNREVIEWED SAFETY QUESTIONS RELATIVE TO EDG LOADING CORRECTIVE ACTIONS FOR FAILURE TO TEST PENETRAT e
IN ACCORDANCE WITH TECHNICAL SPECIFICATIONS IN 19 WERE INADEQUATE TO PREVENT A RECURRENCE IN 1996 NOTE:
THE APPARENT VIOLATIONS DISCUSSED IN THIS PREDECISIONAL ENFORCEMENT CONFERENCE ARE SUBJECT TO FURTHER REVIEW AND ARE SUBJECT TO CHANGE PRIOR TO ANY RESULTING ENFORCEMENT ACTION.
@riorie.
4 Power CO R P O R ATION 4
Crystal River Unit 3
~
l Pre-Decisional Enforcement Conference Nuclear Regulatory Commission I
Region II Office 4
Atlanta, Georgia January 24,1997 I
)
q GENERAL OFFICE: 3201 Thirty-fourth Street South e P.O. Box 14042
)
)
Agenda
)
umggggg _,,,,;;jgggy
=mo :
e In': roc uction P. Beard e MCAP Roo': Causes o.Boldt 3
e Corrective Actions /Results 50.59 F. Sullivan 3
Design Control / Procedures Corrective Action Implementation o Ex':en: of Condi': ion J. Terry e Ro.e of Assessmen':s and Oversight J. saumstark e Closinc Remar<s P. Beard
)
i Florida Power Corp i
1 J
)
Opening Remarks g,,
o Carefully reviewed IR 96-12 and IR 96-19 e No material disagreement with the
)
facts o Acknowledge apparent violations 3
occurred in 4 areas as described in IR 96-19 e Apparent violations largely reflect historic, not current performance deficiencies e Root causes and corrective actions
)
subsumed within MCAP ll initiatives e Additional specific corrective actions 3
included in Restart Plan Florida Power Corp 2
)
(
Opening Remarks
)
==mm mmmmm-m wa mmera m a zzamman o Specific root cause analyses confirm prompt, timely, and comarehensive nature of MCAP 11
)
actions o As MCAP ll initiatives result in enhanced
)
sensitivity to sa"ety, ac ditional past problems may surface o Committed to fundamental change:
9/96 voluntary shutdown to assure aroad,
)
lasting corrective actions 11/96 revision to MCAP 11 Recruitment of new 3ersonnel and management from outside the company
-Chief Nuclear Officer
)
-Site Vice President
-Engineering Director 3
-Site Su aport Director Florida Power Corp 3
)
Relationship of the Apparent Violations to MCAP II
_ _,., - m y g g _ _ 2 o MCAP ll was established to direct FPC's corrective action to the root cause(s) of problems rather than their symptoms The MCAP root cause determination was performed in August of 1996 :o address prior problems.
MCAP 11 includes broad, comprehensive corrective actions Florida Power Corp 4
Relationship of the l
Apparent Violations to MCAP II n nr-a n=:
-8 ~
e Our review has shown that MCAP ll root causes bound
(
the root causes of the 11 apparent violations This is significant because it adds further credibility to MCAP and reasonable assurance that if additional issues are discovered in ':he 3
extent of condition review, they will also be bounded We will address our basis for this position Florida Power Corp 5
)
?
Relationship of the Apparent Violations to MCAP II
)
N"=e3C?f@E-3EEC;...
4.
? N E F* M " * * '# " '
^
)
e FPC views the apparent violations as symptomatic of deficiencies that predate MCAP I:
10CFR50.59 evaluations:
)
96-12-02,96-19-03 96-19-06,96 '9-07 3
Design control:
96-19-04,96 '9-05,96-19-08 Corrective action im alementation:
)
96-12-03,96-19-02 Procedures:
)
96-12-04,96-19-01
)
Florida Power Corp 6
)
)
Relationship of the Apparent Violations to MCAP II n,-,,=gy; ggggg_
e Totai - 11 apparent violations:
7 related to ASV-204 4 related to three other issues:
-Boron precipitation 50.59
-SW heat load assumptions
-Containment penetrations (2) e The root causes and corrective actions for these apparent violations remain bounded by the broad based root cause and corrective action plan incorporated in MCAP 11
)
Florida Power Corp 7
)
Relationship of the Apparent Violations to MCAP II a
" # " # 7 5$$ # E : E ;._....... 1.l.[ [ 33 N N E
- o e Review of the root causes l
addressed in MCAP ll o
e Engineering Performance MCAP Root Cause:
o
- An appropriate safety culture was not established o
e Activities were not given a level of safety attention commensurate with that given to production or cost g
priorities e Design basis concerns were primarily resolved through analytical means in a
lieu of physical means directed at maintaining or improving design margins a
Florida Power Corp 8
o
Relationship of the 5
Apparent Violations to MCAP II MiBfSEdHEEJEEE;.......:............. _.._.................lEsiiEEEEEEEE~_l_"~'?
D e Engineering Performance MCAP Root Cause (cont'd):
3
-Insufficient communication of management expectations, 3
particularly with res aect to safety culture D
D D
D Florida Power Corp 9
D
)
Relationship of the Apparent Violations to MCAP II
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^
o Configuration Management and 3
Design Basis a
MCAP Root Cause:
-Insuficient emphasis on nuclear safety culture in relation to more 3
traditional production priorities, such as capacity anc cost, resulting in:
3 e Inadequate design margins that had not been addressed e Limited definition, consolidation, and
)
understanding of the plant design basis e Lack of comprehensive configuration 3
controls e Lack of networking with other B&W plants to maintain consistent 3
designs / design margins Florida Power Corp 10 J
Relationship of the Apparent Violations to 3
MCAP II 3
ammamema rseasan = = gsar
- =maraway a m anmaamme i
o Using the new, enhanced root 3
cause process developed as a corrective action of MCAP ll:
a FPC conducted an extensive root cause analysis for the ASV-3 204 USQ's and containment penetration issues The apparent causes of the boron a
precipitation 50.59 and SW heat load issue are bounded by the above root causes 3
e The process is based on FPI methodology and training 3
Florida Power Corp 11 3
Relationship of the Apparent Violations to MCAP II suunnumracaiaaamm.easdaac <
- misshm,_aammergem..
o ASV-204 Example:
Established a team (expended nearly 3
60 man-weeks)
- Richard Grumbir (Team Leader)
- Mike Lord
)
- Harvey Liles
- Tim Catchpole f
- Richard Starck (MPR)
- Andy Hon (FPI) p Process consisted of:
- documentation review
- personnelinterviews
)
- barrier analysis
- event and causal factor charting
)
- accountability determination Florida Power Corp 12
]
3 Relationship of the Apparent Violations to P
MCAP II emTmmem;1l't ".-...."....r a is:: E m r r s i n u s s a n 1 T J e w t
...-:,.....;....~+....:........,~........~....,.............:...:.......,..
d
}o e ASV-204 Results (7 root j
causes):
i MCAP Root Cause: Safety I
Culture j
-Lac < of commitment to project teams jo
-Design engineer and supervisor j
failec to appreciate ITS review io res aonsiailities 4
l
- A consistent level of qua ity in l
10CFR50.59 evaluations has not ueen maintained
-Wea < commitment to PRC review o
program Florida Power Corp 13 0
6 Relationship of the b
Apparent Violations to MCAP II ers arese a _ ______ _ a s srec e -
o ASV-204 Results (cont'd):
3 MCAP Root Cause:
Management Expectations o
-Engineering management did not adec uately convey modification o
review expectations MCAP Root Cause:
O Configuration Controls
- EFP/LPI interlock modification did not translate EFP-2 rec uirements to design input o
documents
- Design basis cocument update process failed in this instance Florida Power Corp 14 o
3 Relationship of the Apparent Violations to MCAP II
. g.
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)
e
Conclusion:
The root causes of:
-the ASV-204 USQ's,
-boron precipitation 50.59, p
-SW heat load assumptions,
-and containment penetration P
issues are bounded by the root J
causes and corrective ac: ions of MCAP 11 3
J Florida Power Corp 15 J
i
)
Relationship of the Apparent Violations to 3
MCAP II
)
-===r mm
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3 e Conclusion (cont'd)
There is reasonable assurance
?
that the broad, comprehensive root causes and corrective f
actions of MCAP ll will continue to bound any P
additional issues that may surface during the extent of 3
concition review J
Florida Power Corp 16 D
Inadequate 10CFR 50.59 Evaluations
=p Problem Scope o Inadequate Evaluations 3
Failure to address all aspects of the activity f
Failure to identify USQs Questionable utilization of the a
screening technique One discipline verification Conducted at the end of the
(
design process 3
Florida Power Corp 17 D
Inadequate 10CFR
~
D 50.59 Evaluations D
....m_.233dia___._.211_.[.$.222EE$iSEE@E@**N Root Causes D
i i
e Bounded by MCAP ll P
4
- 1) Leadership oversight and P
involvement has not been effective in establishing the 3
appropriate Safety Culture.
Lack of management 3
expectations on 50.59 3
50.59's considered a burcen D
Florida Power Corp 18 D
)
Inadequate 10CFR 50.59 Evaluations 1
-,__ygggymL g g =mmm -
Root Causes <<< cont >;
Misunderstanding of USQ p
purpose b
Minimal training p
Q.A. Oversig ht insufficient i
4 h
Lac < of appreciation for the l
technical content of the FSAR
)
)
Florida Power Corp 19 J
Inadequate 10CFR 50.59 Evaluations
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,,gg;;;ggg Root Causes << cont';
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h
- 2) Configuration Management weaknesses have existed in implementing programs for maintaining plant configuration 10 CFR 50.59 screening process 3
)
Florida Power Corp 20 3
Inadequate 10CFR 50.59 Evaluations
_,_,yyy m ; _;_,ys Extent of Condition of
?
10CFR 50.59 Issue i
6 e 12 -EDG, EFW, EFIC modifications reviewed as a result of the ASV-204 Issues 3
e 32 additional safety related modifications reviewed from the 3
1990 to 1996 time frame e 12 of the above 44 10 CFR 3
50.59's require further in-depth review 3
e Sample size will be reviewed following completion of evaluation 3
Florida Power Corp 21 J
Inadequate 10CFR 50.59 Evaluations Extent of Condition of 10CFR 50.59 Issue e Additional planned reviews prior to restart 3
Refuel 10 EOP evaluations System timelines/ extent of a
condition Recent FSAR comments identified by NRR project 3
manager J
Florida Power Corp 22 J
l Inadequate 10CFR r
50.59 Evaluations
)
< we 53 m 7-
- j gg Corrective Actions Completed e Engineering stand-down o Single point review of all 5
screenings / evaluations
(
e Development of the Safety Analysis Group p
Multi-disciplinary l
Broad based skills / knowledge Expert experience from outside FPC Questioning attitude
)
Florida Power Corp 23
)
Inadequate 10CFR 50.59 Evaluations p,
, ggggggg, Corrective Actions Completed e Require development of p
evaluations at the beginning of i
projects o Multi-pass reviews integrated 3
with safety review o No screening out of modifications 3
to be subjected to 50.59 review w/o approval a
e 10 CFR 50.59 Sensitivity Training (Performec by Licensing and 3
Safety Analysis Groups) 3 Florida Power Corp 24 3
?
Inadequate 10CFR l
50.59 Evaluations
" "*" "*W5fli__.__,4$$8"ilt? T~??
fLAd%D p
Corrective Actions Comp"eted
(
e Provided additional training to the Safety Analysis Group e Stand alone 50.59 evaluation 3
documents e Established safety analysis 3
representation on PRC o Established 10 CFR 50.59 Task Force J
e Development of an enhanced 50.59 Procedure for CR3 3
Florida Power Corp 25 2
D Inadequate 10CFR 50.59 Evaluations a
_____eass a s;_ _ _ _ 2 = c: =
Corrective Actions Comy.etec.
o 0
e Nuclear Operations Engineering Standard on 0
50.59 evaluation expectations issued a
O O
e Florida Power Corp 26 e
Inadequate 10CFR 50.59 Evaluations
___,y=3,_;_gmyy-Corrective Actions P:.anned g
e Additional training on the development and review of 10 CFR 50.59 screenings / evaluations 3
o Enhanced utilization of the safety function / logic diagrams e Expanding the Safety Analysis Group reviews to include all D
CR-3 50.59 evaluations (until the new process is firmly entrenched)
J O
Florida Power Corp 27 D
Inadequate 10CFR 50.59 Evaluations mumummersumae gaamaggsgn4 er ragggggg g,-
(
Corrective Actions P:.anned e Issue enhanced CR-3 10 CFR50.59 Procedure.
3 o Unified evaluations e Development of Safety Analysis Group 50.59 Reviewer Report
)
e Development of performance 3
indicators
)
Florida Power Corp 28 J
Inadequate 10CFR 50.59 Evaluations
)
7"m?
L azamemmw-m
~~~=
Resu:.ts Achievec.
e Culture changes g
e PRC performance e NRC inspector questions on draft 50.59 during Inspection Report 96-17 previously identified by Safety Analysis Group o Marked improvement in 50.59 3
evaluation quality Florida Power Corp 29
)
)
Design Control Process & Procedures
)
umununnameswzugusammare ~
~" wnamenu secar.-
Scope of Problem p
e Recent design issues have j
raised concerns about some 5
detailed aspects of the CR-3 design process.
?
Utiization of unverified electrical diesel case studies, f
hydrau ic system case studies, and sta': ion blackout case studies to support instal ation of plant modifications.
Florida Power Corp 30
)
Design Control Process & Procedures D
- 33335$lli
_._i.2li.i12533!E93E Scope of Problem Failure to update design a
i documents to incorporate design information (ASV-204 a
issue) p l
A calculation did not identify a
[
limiting parameter for a safety l
system evaluation. (IPAP issue l
on SW system temperatures O
vs. heat exchanger fouling) 3 Florida Power Corp 31 0
Design Control Process & Procedures
_ _,, -,s_
Root Causes b
e Bounded by MCAP ll 3
o Leadership oversight and 3 -
involvement has not been effective in establishing the 3
appropriate safety culture.
Plant involvement in design process importance in maintaining Design Basis Documents 3
Florida Power Corp
Design Control Process & Procedures yyysyr_:
- ,yy m m Root Causes <'Contn>
p l
e Configuration Management 3
Weaknesses have existed in implementing programs for a
maintaining plant configuration.
3 150 day time frame to update design documents
'D Unverified case studies J
Florida Power Corp 33 D
)
Design Control Process & Procedures f = = m e m ac
_ ze m m l
(
Extent of Condition e Due to the issues identified regarding unverified case studies, it has been decided to
)
implement a Design Process Self Assessment e The assessment will focus on identifying other areas for improvement in the design process 3
a Florida Power Corp 34
?
i
Design Control Process & Procedures
?
gg=gg_
Corrective Actions Completec.
o Design Review Boards 3
o Safety Analysis Group i
t e Field Walkdowns Mandatory i
e Verification of Case Studies e Second Review of Design Inputs Florida Power Corp 35 J
Design Control Process & Procedures a s:ss % _ _ _ c a re = :_ = _
Corrective Actions Completec.
o Issued NOD 55 " Control of f
Design Basis Information"
(
e Design Basis Document Updates in a timely manner.
L o The following NOE Standards have been Issued:
f Analysis /Ca culations i
System Assignments b
Design Review Boards 2
Florida Power Corp 36
Design Control Process & Procedures
" - ese=me_____eere- -
Corrective Actions P anned e Verification Report o Equipment Return to Service 3
Review J
e Implementation of Design Engineer System Assignments e Issue NOE Standard on Scope Team Expectations a
D D
Florida Power Corp 37 J
)
Design Control Process & Procedures
?
== m --
easse== -
(
Corrective Actions P:Lanned s
e Issue NOE standard on project lead expectations /
a responsibilities e Complete design process self assessment
)
i Florida Power Corp 38
)
Design Control Process & Procedures mess:::s_a___2s==re-Results e Culture Changes (DRB}
Plant Ownership b
Multi-discipline; Multi-organizational
)
Questioning attitude Operations questions during DRB h
process Better Field Packages
)
1
)
1 Florida Power Corp 39
)
Inadequate Corrective Actions
---_=
Pro alem Scope /
Extent of Condition e Previous problems identified at CR-3 have not been resolved in a satisfactory manner.
PR94-0218 described a problem where engineers failed to address
)
EDG loading in the modification process. This is similar to the j
a issue identified with EDG loading (referencing kW loading) for MAR 3
96-04-12-01 "ASV-204 'A' EFIC Auto Open Removal."
3 Florida Power Corp 40
)
(
Inadequate Corrective Actions
.. w w a u s g e garagt^== --
mersgamumeuumarmaammmen i
Problem Scope 3
3 LER 94-007 identified where containment penetration s0rveillance procedures were not 3
revised. It was recently found that additional valves / blind 3
flanges were also not-being verified per ITS requirements.
O e
Florida Power Corp 41 0
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3 An inadequate root and common cause analysis process inhibits management from addressing the correct 3
issues in the right priority.
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J Inadeq,uate Corrective Actions D - u______:urre -
Corrective Actions Completed a
l 6
o Implemented CR-3's new Corrective Action Program h
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e Completed a Root Cause f
Analysis on ASV-204 Issue.
o Completed a Root Cause l
Analysis on the Containment Penetration Surveillance Issue.
3 3
Florida Power Corp 43 3
Inadequate Corrective Actions
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e Precursor Card graded approach process D
Grade A, B, C, and D e Precursor Card Screening g
l Committee o Root Cause Team f
r e CARB (Correc':ive Action Review i
Board) e Corrective actions cesigned to prevent recurrences 3
Florida Power Corp 44 J
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e Final approval and issuance of ASV-204 Issue Root Cause Report
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l e Final approval and issuance of k
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Surveillance Issue Root Cause D
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Florida Power Corp 45
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e Better Prepared / Trained 3
Personnel 4
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e Improved Root Causes
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Florida Power Corp 46 D
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J EXTEXT OF COXDITION D
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D e Project Mission Statement Provide Reasonable Assurance System Configuration for Operation is:
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EXTEXT OF COXDITIOX
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Determine " Extent of Condition" for:
- Acceptab e Design Margins
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-Licensing Basis Compliance 3
Focus Reviews on:
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-10CFR50.59 Evaluations
- Procedure Conformance to Design Basis 3
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i Florida Power Corp 49 I
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EXTEXT OF COXDITION
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o Graded Approach Methodology Select Systems for Appropriate Levels of Reviews 3
Perform Graded Review Verify Adequacy of Design &
J Identify Problems Generic Review of Problems Found Disposition Problems J
Review & Signoff of System Readiness 3
Turnover to O aerations J
Florida Power Corp 50 J
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e Graded Approach for System Assessment of 105 Systems Level 1 - System Readiness P
certification i
b Level 2 - System Readiness Assessment 3
Level 3 - System Reaciness 3
Walkdown 3
Florida Power Corp 51 D
L EXTEXT OF COXDITIOX
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a e Evaluation Results System Readiness Certification (Level 1)
- Emergency Diesel Generators &
3 Support Systems
- Engineered Safeguards 3
-Make up & Purification
-Decay Heat Removal System 3
- Emergency Feedwater
- Emergency Feedwater Initiation 3
& Control
-Core Flood D
Florida Power Corp 52 D
l EXTEXT OF a
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e Air Handling
- e Building Spray
- o e DC Electrical System o Electrical Distribution (6,900 Vac - 480 Vac) b e Reactor Coolant
- e Raw Water o
e Nuclear Services CCC (SW)
- complete and assess timeline e
Florida Power Corp 53 0
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Florida Power Corp 54 J
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EXTE~ T OF CO.. DITION
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(Level 3) j Project Reduced System Approach Team Team Manager D
Review Design & Licensing Yes Focused Open items Documentation Review System Materiel Yes Yes Yes Condition Documentation D
As-Found System Condition Project Reduced System Walkdown Team Team Manager j
identification of Deficiencies Yes Yes Yes D
Disposition, Tracking &
es Yes Yes J
Reporting Restart Restraints As-Left System Condition es Yes Yes Walkdown O
Final System System Final Reporting Requirements Readiness Readiness Walkdown Report Summary Summary G
Tumover to Operations Yes Yes Yes Florida Power Corp 56 e
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EXTEXT OF CONDITION D
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STRENGTHS c
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Florida Power Corp 57 D
EXTEXT OF COXDITIOX
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e THE NEXT STEP Schedule Development &
Resource Requirement Identification lssue Restart Readiness Guideline f
Project Team Formation of Level 1 Systems Level 2 & 3 Reviews & As-(
Found Walkc owns
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Florida Power Corp 58 2
Role of Assessments and Oversight z,,
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Assessments Operating Experience Review 3
Program Plant Review Committee 3
Nuclear General Review Committee 3
3 Florida Power Corp 59 3
Role of Assessments and Cversight
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J e Audits and Surveillances
'97 Audit Plan and 3
Methodology Restructured Role of Surveillances 3
Enhanced D
D D
D Florida Power Corp 60 D
l l
Role of Assessments and Oversight mes nzu
- m=== - -
3 e Self and Third Party Assessments 3
impact of Nuclear Operations j
Directive NOD-45 / Link to 3
Compliance Procedure CP-111 Role of Administrative Instruction Al-501 (Plant Ops Focus) 3 Draft Plant Staff Self-Assessment Document (Maintenance, 3
ChemRad, Work Control focus)
Restructure Manager Level Self Assessment 3
Significant Third-Party Assessment Effort in Licensing 3
61 Florida Power Corp J
Role of Assessments and Cversight
= _
)
e Operating Experience Review Program Existing program "ound fragmented, uncoordinated, with limitec staff 3
support.
Redefined and expanded scope;
)
consolidated effort in one organization.
4 Dedicated staff of 3 engineers with
)
improved access to industry, regulatory, and plant networks.
3 Increasing visibility of role as site asset.
)
Florida Power Corp 62
)
D Role of Assessments and Cversight
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-Restructured process based on self assessment / benchmarking O
NGRC
- Restructured /re-membered D
- Asking questions pertinent to current / future issues D
D e
Florida Power Corp 63 e
Role of Assessments and Oversight
_ yggsy e What Quality Programs Sees Now 3
Revised corrective action process gaining momentum Better 50.59s based on enhanced interim process increased awareness of design basis issues Improved awareness of and sensitivi':y to regulatory issues 3
J Florida Power Corp 64 J
a Relationship of Apparent Violations to MCAP II Root Causes and Corrective Actions 10 CFR 50.59 Evaluations MCAP II References
)
96-12-02 Three examples where safety evaluations Section B failed to identify USQ's Root cause 1 (actions 1-4) i 96-19-03 Inadequate safety evaluation when ASV-204 Section C
)
was moved to the A side IDRP Section III (action 3)
IDRP Section VI 96-19-06 Removal of one of two steam supplies to (actions 2-4)
EFP-2
)
Section D Root Cause 1 96-19-07 Boron Precipitation safety evaluation (action 6)
Appendix A (action FU-1)
)
Design Control MCAP II References 96-19-05 Modification to remove auto open of Section B ASV-204 failed to include dependency on Appendix A j
EFP-2 (action 2) l
)
l MAR impact assessment did not take into Section C account impact on MOV & SBO Root Cause 1 (actions 6-8) 96-19-04 EFP/LPI Interlock modification failed to IDRP Section I
)
incorporate design information (actions 1-8)
IDRP Section II 96-19-08 An error in the calculation of total heat loads (actions 1-4)
IDRP Section III to the SW system and subsequent effect on (actions 1,2,5,6) curve.
?
IDRP Section IV (actions 1-5)
IDRP Section VII (actions 2,3,5,7) l l
MCAP LEGEND Section A:
Leadership Oversight & Involvement Section B:
Engineering Performance Section C:
Configuration Management & Design Basis Section D:
Regulatory Compliance
)
Section E:
Operation Performance
)
l l
B Relationship of Apparent Violations to MCAP II Root Causes and Corrective Actions Inadequate Corrective Actions MCAP II References D
96-12-03 May 31,1996, PC96-2750 identified a potential problem with the EDG loading after Section A MAR 96-04-12-01 was installed, questioning Root cause 3 the 3500 kW limit.
(actions 1-5)
July 2,1996, PC96-3192 identified that the 3
50.59 screenings and safety evaluations July 3,1996, PR 96-0210 was written to address PC96-2750, no safety concern Section B Licensee identified that PR94-0218, dated Root cause 1 June 24,1994, described a similar problem (action 8) 3 where engineers failed to address EDG Root cause 2 loading in modifications.
(action 3) 96-19-02 Containment penetration surveillance Contributing Cause 1 procedures were not revised based on LER (action 1,2)94-007, the procedure was not reviewed to 3
determine to determine if any additional valves / blind flanges were not being tested Section C per TS requirements.
Root Cause 1 (actions 4,5,7)
D Procedures MCAP II References 96-19-01 Three inadequate containment penetration Section A surveillance procedures resulting in missed Root cause 3 Technical Specification surveillances (actions 1-5)
{
(3.6.3.3, 3.6.3.4, 3.6.3, and 3.9.3)
Section B D
96-12-04 NEP-210 improperly allowed the general use Root cause 2 of unverified electrical calculations, (action 2) j hydraulic system calculations, and station Appendix A blackout calculations to support design, (action 2) j installation, and use of plant modifications.
IDRP Section C i
(action 8) 9 Section C (action 8)
MCAP LEGEND IDRP Section II (actions 1,3)
Section A:
Leadership Oversight & Involvement
[9pp Section III O
Section B:
Engineering Performance (achon O Section C:
Configuration Management & Design B. sis IDRP Section IV Section D:
Regulatory Compliance Section E:
Operation Performance (actions Al-4, B1)
IDRP Section VII (action 7)
D S
Why the work we are doina l
right now is adequate
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o Overall Safety Awareness increased
- Stand downs with feedback
- Site meetings with feedback
- Communication of expectations and status
- New Corrective Action process
- Teamwork
- Additional 50.59 Training Modifications and EOP Changes
-Safety Analysis Group e 50.59 trained e focus solely on safety analysis for mods and EOPs Other Procedure and Program Changes
- Safety Evaluation Process for Procedures enhanced e Al-400C e PRC reviews more challenging Florida Power Corp 31
{\\ SA LICENSING TEL:904-563-4451 Jan 26'97 10:57 No.001 P.01 l
i
_ _ - _ = =.
i l
To: Kerry Landis 1
l XRC RegionII i
i l
Please acd to end of FPC/ Crystal River Pre-i Decisional Enforcemetn Conference Presentation held on January 24,1997 Florida Power Corp
- SA LICENSING TEL:904-563-4451 Jan 26'97 10:57 No.001 P.0 ie l
FPC Closing Remarks
=-
=
l e MCAP II initiated before ASV-204 i
issues came to light identification of issues that maintained plant shutdown j
e Demonstrated that we have identified fundamental root causes and initiated broad corrective actions and specific corrective actions to address specific issues e With regard to safety significance, we have reason to believe that systems would have mitigated the design accidents considering our EOP 's and operator training Florida Power Corp
SA LICENSING TEL:904-563-4451 Jan 26'97 10:57 No.0VA P.05 o
l l
Safety and Regulatory 4
l Implications j
,=
l e Exercise of discretion is appropriate i
> Imposition of significant sanction would be l
inconsistent with an appropriate regulatory l
message l
> FPC has recently received a significant civil l
penalty ($500,000 in 1996) l
> FPC placed Crystal River in an extended shutdown in 9/96 to address issues from earlier action and current issues
> FPC is on the right track
> Situation is analogous to those contemplated by enforcement policy for enforcement discretion in response to:
- Violations identified during extended shutdowns
- Violations involving old design issues
- Violations identified due to previous escalated enforcement action Florida Power Corp
-