ML20198J818
| ML20198J818 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 01/10/1998 |
| From: | Baumstark J FLORIDA POWER CORP. |
| To: | |
| Shared Package | |
| ML20198J675 | List:
|
| References | |
| NUDOCS 9801140218 | |
| Download: ML20198J818 (8) | |
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Florida Power C O M P O R A14 O N l,
CRYSTAL RIVER U slT 3 i
ASSESSING PERFORMANCE AND ORGANIZATIONAL ROLES J. S, Bat (mstark Director, Quality Programs P
A C
2 p
Assessing Operating organizations that successfully identify their own problems Performance are able to achieve higher levels of safety, regulatory and economic performance. Assessments provide a means for individuals at all levels to become involved in attaining excellence and maintaining the levels of plant and staff performance necessary for success. All orspoliations on site participate in performance assessments, ranging from self-a,sessments, which are a part of the Al 256 readiness for restart process, to the oversight role of the Nuclear General Review Committee (NCRC).
Self Assessments Examples of the major changes / impacts at CR-3 as a result of self-assessments include the following:
lhe Configuration Documentation Integration Project, which e
resultcd from a combined CR-3 personnel and industry expert assessment team Work Control Process improvements, which resulted from a combined CR-3 personnel and INPO technical assistance team Design Review Board improvements, which resulted from the Design Engineering Management assessment of departmental communications lhe Operations leadership Plan, which was developed from an e
existing Operations improvement Plan based on the results of self-assessment CRSA 97-19 The Operations Observation Program, which underwent major e
revision due to the results of self-assessment CRSA 9719 During the outage, over 40 self assessments were completed.
Third Party Multiple third party assessments were conducted.
Examples of Assessments independent reviews are as follows:
PRE-OSTI, Executive Advisor: Mr. Stew Ebneter (former NRC Regional Administrator).
ENGINEERING READINESS, Team Leader: Dr. Donald Knuth (former NRR Senior Manager).
- LARGE BORE PIPING, Team Leader: Mr. John Stevenson (Recognized industry piping expert).
CONflGURATION MANAGEMENT, Team Leader: Mr. Henry Wong (Recognlied industry configuration control expert).
JCOs, Team Leader: Mr. T. P. Noonan (previous Vice President Nuclear Operations and Plant Manager, Beaver valley Power Station).
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EDG (3 separate assessments), condue 'ed by Mr. Carl Woodard (Recognized industry diesel expert), MPK, and Duke Engineering.
APPLNDIX R, Team Leader: Mr. Nick fiorvahte (former NRC staff member).
fME A, conducted by f ailure Prevention international, e
10Cf R50.59 Process, conducted by Altran Corporation.
e CCHE, conducted by MPR.
INPO ASSIST VISITS,10 assist visits have been provided in the areas of Operations, Maintenance, and Engineering, QUAllTY Of LICENSING SUBMl1TALS, conducted by Mr. Ed o
f uller (Recognized industry leader in performance assessments).
During the outage, over 70 third party assessme 's were conducted.
Oversight QA conducted 12 compliance based audits and 150 performance Organizations based assessments (surveillances) during 1997.
Quality Assessment (QA)
Surveillances included reviews in areas such as:
General process / program effect3 eness (22 occasions) e Corrective action (21 o. rasions) e Restart effart (6 occasions) e licensing product (8 occasions) e Self assessment (7 occasions) e Safety Assessment /Unreviewed Safety Question Determination (SA/USQD) process (3 occasions)
Restart closure package reviews (200 packages completed by the e
end of the year)
QA activities in which significant process / programmatic issues were identified included:
Quality Surveillance QPS 97-0062, which identified Technical Specification surveillance testing was not always performed on the dates specified in the Surveillar ce Schedule and frequently took advantage of a portion of the 25% interval as part of the normal frequency for testing.
This resulted in an overhaul of the surveillance scheduling process, Quality Surveillances QPS 97-0073 and QPS 97-0134, which e
assessed control of the 500kv and 230kv switchyards and determined that maintenance of switchyard equipment required improvement. This resulted in focused attention on switchyard maintenance prior to restart.
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1 Qualliy Surveillance QPS'97-0118, which assessed the EOP/AP development schedule and alerted management that the schedule l
would not support the approval of EOPs & APs prior to conducting training. This resulted in realignment of resources to support task completiori.
Quality Surveillance QPS 97 0129, which found the gading of l
'D' Precursor Cards initiated during the first five months of 1997 l
had inappropriately included conditions adverse to quality and did not meet CP-111 standards. This resulted in a total review of all
- C' and "D" Precursors generated between November 1996 and May 1997 for proper closure.
i Quality Surveillance QPS 97 0138, which identified deficiencles in the translation of Standard Technical Specificatien (STS) equirements to the Improved Technical Specifications OTS). This resulted in an upgrade of the change control process.
Quality Surveillance QPS 97 0163, which disclosed a weakness in the training of Maintenance contractor personnel.
The overall awareness for the consequences of not fulfilling the procedural requirements of the safety clearance and tagging progam by electrical craft personnel was deficient. This resulted in a change in the contractor training process.
Plant Review The PRC assists the Director Nuclear Plant Operations in monitoring Committee (PRC) plant safety by reviewing changes to programs, procedures, and equipment which are used in routine and emergency activities of the plant.
l To accomplish the required reviews necessary to support restart, two teams were crt ated, PRC A & B, which used a single Chairman for consistency.
Each team consisted of managers from Operations, Maintenance, _ Work Controls, Chem / Rad, Safety Assessment Group, Engineering, and Licensing.
During the. outage, over, 200 PRC meetings _ were conducted,- and approximately 550 items were =
reviewed. Additionally, a dedicated subcommittee, chaired by the Operations Manager, conducted 16 meetings dedicated to the review of EOPs.
The PRC was a fully integated member of the restart effort, providing -
valuable oversight for prorx> sed modifications, testing, and procedure revisions.
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Nuclear General The NGRC, comprised of senior individuals with executive industry, Review Committee INPO, and NRC experience, provides an additional level of executive (NGRC) oversight to Quality Program functions. The NGRC has met at least quarterly during the outage to review the station's performance, and, based on its oversight activities, has provided feedback and recommendations directly to the Senior Vice President Nuclear Operations. The NGRC has general oversight of the Quality Programs function as well as other aspects of nuclear safety. To adequately assess key elements of the outage, two ad hoc subcommittees of the NCRC were established:
1he Restart Readiness Subcommittee, which focused its oversight on the adequacy of the restart process, the quality of the work, and an operational readiness review.
As part of its efforts, this subcommittee evaluated Readiness Reviews for six systems, six Restart issue Closure packages, and various engineering issues.
The Safety Evaluation Review Subcommittee, which, on completion of the site's SA/USQD training program, reviewed, for oversight, nine Safety Evaluations, in addition, NCRC resources were used extensively to provide insight into the strategies use t 'o develop licensing amendments and resolve USQs. During the ouiage, NGRC members reviewed all level 1 and 2 SRRs (26 systems) from the perspective of the system's ability to perform its design and mitigation function.
The NGRC's November meeting was dedicated totally to restart readiness.
Each standing subcommittee reported the results of its deliberations and made a positive restart recommendation. The full NGRC further reviewed restart readiness with the Restart Director and Site Director before concluding that although physical work, testing, procedure issues and regulatory issue closures remained, satisfactory identification of remaining issues had been accompCshed and organizational structure, policies, programs and practices to support safe restart were in place.
The NCRC then concluded that, upon completion of currently planned activities, CR 3 would be ready to safely restart.
Safety Analysis The Safety Analysis Group provides a third party review of Group (SAG) 10CFR50 59 evaluations performed at CR 3. Over 1800 documents have been reviewed. The quality of these assessmen;s has shown significant improvement as evidenced by recent internal and external inspections.
4 To completely ensure FPC's ownership, control, and in-house knowledge of the design and licensing bases, it was recognized that the plant safety analysis (FSAR Chapter 14) needed to be fully understood 5
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by i PC personnel. The organization which led this task was the Safety Analysis Group.
Its formation represented an integration of four elements: (1) a key licensing function (50.59 review and approval), (2) ownership of Chapter 14 and related events, (3) maintenance of the PSA rnodel and PSA plant support, and (4) fuel management. The integration of these capabilitief, has helped ensure the integrity of CR-3's operating bases.
Corrective Action 1he CARB provides increased management oversight and direction in Review Board conducting the cause analysis and correction of grade A and B (CARB) precursors and other issues which warrant increased management attention.
T he following personnel are the designated CARB members:
Director Nuclear Plant Operations (Chairman)
Director Site Nuclear Operations (Co-Chairman)
Director Nuclear Engineering and Projects Director Nuclear Regulatory Affairs Director Quality Programs e
Director Nuclear Operations Training Director Nuclear Site and Business Support a
Manager Nuclear Safety Assessment Team (Co<hairman) e CARB sets the standard for the importance of apparent and root cause evaluations in resolving the station's issues.
It communicates and enforces implementation of management's expectations for l'ne corrective action program.
During the course of the year, CARB provided oversight review of 235 root causes.
Restait / Restart The Restart Panel was established by NOD 57, " Restart Management,"
issue Screening to provide oversight of restart issue management, including evaluations Panel against screening criteria, development of action plans, and completion of clasure packages.
The Panel consisted of the Site Director, Engineering Director, Nuclear Plant Operations Director, Regulatory Affairs Director, Training Director, Restart Director, and Quality Programs Director, who served as Chairman. The Panel provided the primary interface with the NRC Restart Panel and will provide a recommendation concerning restart to the senior nuclear corporate officer.
Meeting weekly, the Panel conducted oversight reviews, including restart issue action plans, system readiness reviews (including all level 1 systems), contingency plans for addressing potential issues in key safety and non-safety systems during startup and power ascension, and the implementation plan for startup (Al 256). The Panel was instrumental in resolving issues related to restart issue criteria, closure of restart issue packages, and establishing criteria for mode restraint lists and restart punch list items.
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The Restart issue Screening Panel (RISP), consisting of managers from Operations, thensing, Engineering, and MaintenanceAvork Control, and chaired by the Restart Director, was established to screen issues for inclusion in the outage. The Panel also dispositioned items that were not screened as restart items.
The RISP provided managerial overview which helped control the scope of the outage. Meeting as often as twice a week, the RISP screened 744 issues, dispositioning each as required for restart or to be resolved by other means (work. a line, work in future outages, administrative issue, etc.).
I integrated The Integrated Verification Plan was developed to provide assurance Verification that:
Plan (IVP)
Modifications and emergency operating procedure changes had not increased the burden on Operations before and dur:ng transient response.
Safety margins had not been reduced by modifications and EOP changes.
Interrelationships with other systems important to safety had not caused additional issues needing resolution prior to restart.
The team that developed the IVP included a former Operations Manager,2 SROs,1 RO,1 Engineer,21.icensing and 1 SAG member, and concluded that:
The overall effect of the modifications and procedure changes enhanced the ability of the operator to prevent and mitigate accidents There was an obvious increase in the knowledge level of the staff, most notably the system engineers, operators, and design engineers Activities where deficiencies existed during normal operation had been resolved, resulting in reduced operator burden and assuring stable operation Emergency response had been enhanced through this gain in knowledge of the design and licensing basis of the plant, as well as through modifications performed to the Technical Support Center and Emergency Operating facility The IVP report was provided to the NRC on December 3,1997. The areas needing follow-up in the IVP were incorporated into the now completed efforts to resolve potential issues and fine tune the design and licensing basis of the plant.
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Al.256 Al 256, " Station Readiness for Restart Sequence, Reactor Restart and Power Accension Plan," provides a structured plan for assessing Station Readiness to commence the Restart Sequence, it required individual departments to conduct readiness assessments as well as the development of the Startup, Power Ascension and Near Term Operation Plan. It provides control of an integrated startup schedule including special system tests and inspections, post maintenance testing, MAR functional testing, SPs and pts, and infrequently performed tests or evolutions.
Al 256 provid., the bridge between integrated verification activities, performed part of the CR 3 Restart Program, and normal plant operatior effectively providing operational checks of systems and equiprr.
and multi-discipline verifications of readiness for startup and powe. 3perations. As part of this effort, the test program has been carefully di aloped and is being implemented to assure that the tests are thoroughly and safely conduc'ed. AI-256 is discussed in detail in the "Startup and Power Ascension Plan" section.
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