ML20198J882
| ML20198J882 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 01/10/1998 |
| From: | Grazio R FLORIDA POWER CORP. |
| To: | |
| Shared Package | |
| ML20198J675 | List:
|
| References | |
| NUDOCS 9801140234 | |
| Download: ML20198J882 (9) | |
Text
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Power i
9Flonida C O M P O M 414 O N e
CRYSTA _ RIVER J SIT 3 t
c 'OCENSING f.d)-tsy. .-
'R.E. Grario U Director, Nuclear Regulatory Affairs 9001140234 900110 1 PDR ADOCK 0D000302
((. - - P- , - _ _ . - . PDR . - . _ . _ _ _ _ , _ _ _ _ _ _ _ _ __ ___ _ _
Key issue Assure that rPC Licensing personnel are properly focused on safety, have a sufficient questioning attitude, and demonstrate sufficient leadership, knowledge, and skills to assure that the plant systems are mainhined within the prescribed design and licensing bases.
Executive Licensing has aggressively sought to improve performance by assessing Summary and addressing issues identified including those by the NRC (1996 SALP Report). Through systematic evaluations, assessments, and analysis, the underlying root and contributing causes of poor licensing performance problems were identified, the most comprehensive of which was a third party assessment conducted in 1996. These evaluations demonstrated that a key focus of the corrective actions must be on improving Licensing personnel knowledge of the plant, licensing basis, communication skills, and sense of ownership. In addition, assessment activities demontirated that there was a need to improve practices and processes, as well as to reduce the regulatory backlog.
During the course of the current CR 3 shutdown FPC has prepared and submitted over 130 licensing submittals to support unit restart or to resolve historical and outstanding regulatory issues The restart required submittals included: (1) submittals that suppon resolution of past discrepancies identified during the System Readiness and Licensing Docket Reviews; (2) Technical Specification (TS) Operating License amendments that support plant upgrades and sesolve USQs; (3) submittals that document resolution of potential unreviewed safety questions (USQ) and; (4) submittals that provide resolution of issues identificd during NRC Inspections. In addition, some submittals were requiru to address licensing issues which were not adequately addressed in the past due to a lack of CR 3 regulatory understanding.
Initiatives in September 1997, Licensing developed a guidance document entitled,
" Principles of Regulatory Interface," which established a foundation for Afission Statement regulatory interactions. This document was developed to ensure awareness by our personnel of the basic licensing principles of operating nuclear power plants in a saf9, reliable, economic and environmentally sound manner. Specifically, emphasis included:
- Principles of regulatory interface
- Responsibility for regulatory compliance e Self assessment and corrective action program as the cornerstones for effectiveness
- Effective communication at all levels
. Thr overall roles and responsibilities of Licensing 2
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These key elements provided the foundation for continued improvements at CR 3 to achieve: (1) a culture that identifies and promptly corrects issues, (2) a questioning attitude and willingness to self identify problems and (3) a common goal to do what is right.
Training and The level of Licensing performance on design and license basis issues Quali// cations was directly tied to the knowledge and skill possessed by personnel.
IPC recognized that at the heart of previous licensing problems was a lack of knowledge and respect for NRC regulations. This required comprehensive remedial training of Licensing personnel as well as reassignment of some personnel. The training focus areas included:
. Safety Assessment /Unreviewed Safety Question Determination e Design and Licensing Basis
- Configuration Management in addition, several licensing engineers received Apparent Cause and Root Cause Analysis Training in support of the Corrective Action Program change initiated in the past year.
I PC has recognized personnel performance issues and continues to deal with these via the personnel evaluation process.
Self-Assesstnents Measurement of regulatory effectiveness was obtained by performance of organizational self-asseo.nents and an assessment in accordance with Al 256, Station Readiness for Restart Sequence, Reactor Restart and Power Ascension Plan.
The self assessments focused on assessing the effectiveness of: (1) actions that were implemented to address past regulatory performance issues; (2) key licensing program and p:ocess improvements; (3) established performance objectives; and (4) organization skills. Among other things, the assessments evaluated the practices and processes with regard to their effectiveness in providing responsive quality products.
The assessment effort included interviews and evaluations by:
. Licensing and Engineering personnel involved in the preparations of submittals, LERs, and NOV responses
- Other departments (such as Operations) that depend on the quality and accuracy of Licensing work products e Third party experts and peers lhere were a number of third party and self-assessments of the Licensing and Regulatory Compliance Departments and their programs. These 3
assess nents provided recommendations that were implemented to l
. improve the Licensing and Regulatory Compliance processes. Some of the significant assessments and the corrective actions are as follows:
- Self-assessments e Licensing and Regulatory Performance (1/97) which identified numerous areas for improvement including 10CFR50.59, submittal quality, licensee Event Report / Notice of Violation quality and inadequate staffing. ;
e Review of Technical Specification Change Request Number 210 and f the Technical Specification Change process (5/97).
- Third Party Assessments. ,
e Three independent assessments and an NRC Inspection on FPC's 10CFR50.59 Safety Evaluation Program.
- Nuclear Regulatory Affairs Startup Readiness (11/97).
These assessments provided valuable insight for development of corrective actions for areas of weakness as well as methods to build on areas of si (.ngth. Some of the key changes made include:
- Completely revised 10CFR50.59 program (discussed in Design and 1.icensing Basis White Paper).
. improved LER/NOV process including a grading system which has shown significant improvement in submittal quality ( on a scale of 0
. to 8, scores have increased from less than 2 to over 6.5 since May 1997).
- Staffing levels were increased with both temporary contracte s and permanent FPC employees.
- The assessment of Nuclear Affairs Startup Readiness concluded that the " weaknesses identified in the SALP, and in other assessments, have been resolved to the extent that Nuclear Regulatory Affairs is ready to support restart and power ascension." The assessment team gave Regulatory Affairs an overall rating of 3/..' on a scale of 1 to 4, with 3 being satisfactory and 4 being a potential strength, t
To ensure effective assessments, FPC developed self-assessment measurement criteria derived from various industry "best practices" sources and current industry guidelines (e.g., INPO 97-002,
" Performance Objectives and Criteria for . Operating Nuclear Elect ic Generatin), Stations") and benchmarking against the top performing utilities, fhe assessment process then baselined each practice and process to determine how it functions, what works well, what-is not working - satisfactorily and why, and then what is .needed -to be improved. This was accomplished by various means, including self-a 4 ;
assessments, procedure reviews, process flowcharting, and team focus groups, f ach practice and process was then benchmarked against industry "best practices."
The recent results of assessments performed indicate the fol!owing:
. The quality assurance process for improving the licensing submittals is working effectively, in early 1997, the Licensing Department took the initiative to raise the standard of licensing submittals. A comprehensive third party assessment had concluded that poor quality submittals were the result of insufficient understanding of the regulations, incomplete procedural guidance, and inconsistent verification and validation of the technical content of the submittals.
Therefore, a programmatic improvement plan was implemented to address the past concerns. Changes were made in the summer of 1997 to the submittal process that included.
- Specific validation of all factual statements
- Completion of a package of the validation documentation
- Consistency by use of a comprehensive checklist
- Multi-discipline review of the submittal with a concurrence sheet
- Initiation of the Licensing Amendment Review Board Plant Review Committee review of technical content Nuclear General Review Committee (NGRC) review of both regulatory and technical content. In addition, grading of the submittals by the NGRC was donc to make subsequent improvements
- The current process continues to incorporate the validation of the technical information to ensure the submittals provide accurate information. in addition, this process assures a consistent methodology is applied for verification and validation of the technical content of the submittals.
e lhe improved 10 CFR 50.59 process is working effectively. The process improvements, incorporation of lessons-learned and training of personnel have all contributed to a sound and effective process.
- Personnel are qualified in accordance with their job description.
However, performance issues have been identified and are being addressed individually, e Personnel understand the need to champion an awareness of regulatory requirements as well as nuclear safety with site pa onnel.
In addition, site personnel have an understanding and sensitivity of the need to comply with regulations. However, the practice of people believing they " knew' what the NRC wanted, which was 5
prevalent and therefore guided some previous submittals, was 1 changed to *Do What is Right," This now includes: 1 i
e Review of the regulation e Discussing issues with other Plants
- Requiring extensive docket reviews of the issue prior to formulating technical and regulatory positions Continuous The results of the self assessments also indicated that continuous improvements improvements and enhancements are needed to achieve sustained excellent performance. The following enhancements to the licensing processes are being addressed:
. Streamlining of the internal regulatory submittal review process to improve the efficiency and timeliness of submittals
- Improve process for limely identification of regulatory commitments to the proper organization for implementation e Standardite the format for outgoing regulatory correspondence
. Improve personnel knowledge of the regulations Upon successful restart from the current outage, further process and program improvements will be made once again by benchmarking other utilities and involving the NGRC, which includes the former NRC Executive Director for Operations, in addition, self-assessments are planned for 1998 that will focus on assessing the effectiveness of:
. Correspondence control process tii. toding the verification and validation process) e final Safety Analysis Report (FSAR) Update process
- License amendment request (LAR) process
. 10 CfR 50,59 process The Licensing Department will continue to use the self assessment process for determining the effectiveness of the organization, in addition, a new licensing manager has been hired and with her arrival in January, the organizational responsibilities will be refined and changed.
Licensing During the course of the unit shutdown, over 160 regulatory submittals Submittals were made.135 of these submittals were related to restart issues, The overall process and strategy for submittals included first submitting the concept, then supplementing with preliminary details, then finalizing the required information. It was recornfred that this process was a "non traditional" approach which had a subsequent perception of r 6
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" Quality" issue. However, the CR 3 licensing history of convoluted ,
submittals, historical ornissions, and previous plant changes without full [
NRC concurrence resulted in the need to provide information in pieces l instead of one large submittal. This resulted in the need for multiple !
technical meetings and follow-on Requests for Additional information ,
(RAI).
A significant number of regulatory submittals were required to support resolution of historical and outstanding regulatory issues or resolution of issues identifk'd during the course of the plant shutdown. In addition, licensing submittals were required to support plant upgrades for resolution of past equipment performance issues and conformance to the regulatory design / licensing basis requirements.
Submittals included: TSCRN 209 RG 1.97, Post Accident Monitoring capabilities; TSCRN 210 - Small Break Loss of Coolant Accident Analysis (SBLOCA) and Emergency Diesel (EDG) Upgrade; TSCRN 213 -
Resolution of Low Temperature Over Pressurization (LTOP) issue; LAR 220 - resolution of Decay Heat flow instrumentation requirements; operator actions for Emergency Operating Procedures (EOPs) and Abnormal Procedures (APs); High Pressure Injection (HPI) Pump design capabilities; upgrade of low Pressure injection (LPI) mission time; Emergency feedwater (EfW) system upgrade; resolution of Appendix R compliance issues; resolution of letdown Rupture Line issue; upgrade of Control Complex Ventilation System (CCHE) and Control Room Habitability study; resolution of Post Accident Monitoring (PAM) capabilities; and resolution of Service Water Cooling capabilities.
Because of the technical and regulatory complexity of some of the issues, more than 25 potential Unreviewed Safety Questions (USQ) were identified. During the course of resolution of these design / licensing basis issues, the potential USQs required extensive NRC review and approval. License Amendment Requests (LAR) were t imptly submitted by FPC.
Examples include: LAR 216 - LDG Fan upgrade, LAR 217 - AHF 1C upgrade, LAR 218 - Letdown Line Rupture, LAR 219 - EDG Protective Trips During Engineered Safety Actuation and Loss of Off site Power; HPl Pump Recirculation analysis, LAR 222 - CCHE leakage and dose methodology, LAR 223 - Boron Precipitation Mitigation Plan, LAR 214 -
ECCS Mode 4 Mitigation Plan, LAR 224 - SW/RB fans Ultimate Heat Sink cooling capacity and Topical Report for Boron Precipitation Prevention, Hot leg injection Method.
in addition, a significant number of licensing submittals were made to support resolution of NRC Generic Letter, NRC inspection issues and other restart related issues.
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Examples include: resolution of large Bore Piping and Piping Support issue; resolution of USI A-46, Seismic Qualification of Equipment; Generic Letter (GL) 96-01, Testing of Safety Related Logic Circuits; GL 96-06, Assurance of Equipment Operability and Containment during Design Basis Accident Conditions; Tendon Surveillance Report; resolution of RCS attached piping issue; failure Modes and Effects Analysis for loss of DC Power; resolution of mission time for LPl Injection; ASME Code relief requests; resolution of Appendix R issues; and various Tcchnical Spmification (TS) and TS Bases changes. With the large and complex composition of regulatory issues, licensing has demonstrated its capability to steadily improve performance.
Organliational The Licensing organization has recently been restructured to provide improvements and more effective and proactive support to CR-3 engineering, operations, Cualifications and maintenance, for example, a permanent Licensing Manager has been hired and Licensing has been integrated into day-to-day Engineering, Operations, and Maintenance issues.
Improved Work The work processes have been enhanced at CR-3. Specifically, the Processes and quakty of the licensing submittals has shown to improve. The facility Upgrades verification and validation process for control of outgoing submittals has been effective.
We are now utilizing standard time lines for the preparation of Licensee Event Reports (LER) and responses to Notices of Violation (NOV). NOV response preparation now begins immediately after the exit when a potential violation is identified by the inspector.
T he process for assembling and approving restart issue closure packages has been enhanced to improve both quality and timeliness. These improvements, which include an index of the package, standards for completeness and an in process review by the Regulatory Compliance group, are also being applied to closure packages for inspection and LER commitments.
The quality and timeliness of Licensing products and services to support station operations has improved. This has also resulted in, among other things, improved quality and time liness of inputs to licensing from other departments, in the area of Emergency Preparedness, we have refurbished and upgraded the Technical Support Center. The changes include an improved layout, usaded data displays and a more functional layout.
The EOF has also received new data dhplays and a more functional layout.
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l Conclusi0n f PC has implemented an aggressive licensing plan to improve performance. Personnel and process changes have been made, and performance has improved. The standards have been raised acro's the organization with heightened focus on problem identification, problem solving, and corrective action. Culture surveys indicate an improvement in knowledge, skills, and attitudes of the staff. As a result of thest.
actions, licensing Department's leadership and personnel are focused on safety, have a questioning attitude and have demotestrated the ability to effectively resolve issues. Processes have been established to en<ure sustained improvement by the Licensing Department.
In addition, upgrades to Emergency Planning Facilities (TSC anti EOF) will enhance the ability of fPC, the NRC, state agencies ard local agencies to respond to a plant event.
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