View source for 3F0194-08, Provides Summary of Util Enforcement Conference Presentation to Facilitate NRC Preparation Efforts,W/Regard to Deviations Noted in Insp Rept 50-302/93-16.Corrective Actions:Eops Upgraded.Action Plan, EOPs Task Force Encl

{{Adams
| number = ML20059H592
| issue date = 01/14/1994
| title = Provides Summary of Util Enforcement Conference Presentation to Facilitate NRC Preparation Efforts,W/Regard to Deviations Noted in Insp Rept 50-302/93-16.Corrective Actions:Eops Upgraded.Action Plan, EOPs Task Force Encl
| author name = Beard P
| author affiliation = FLORIDA POWER CORP.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000302
| license number = 
| contact person = 
| case reference number = RTR-NUREG-0800, RTR-NUREG-1358, RTR-NUREG-800, RTR-NUREG-CR-0899, RTR-NUREG-CR-1875, RTR-NUREG-CR-1977, RTR-NUREG-CR-1999, RTR-NUREG-CR-899
| document report number = 3F0194-08, 3F194-8, NUDOCS 9401310018
| package number = ML20059H594
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 5
}}

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Florida Power CORPORATION NTE:l January 14, 1994 3F0194-08 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C.       20555

==Subject:==
NRC Inspection Report No. 50-302/93-16 NRC to FPC letter, 3N1293-40, dated December 30, 1993

==Dear Sir:==

Florida Power Corporation (FPC) appreciates your cooperation in re-scheduling the enforcement conference associated with the subject Emergency Operating Procedure (E0P) inspection.        Our assessment of the causes underlying the identified deviations highlighted the necessity of our reviewing both the historical development of the B&W Owners Group (B&W0G) generic emergency operating guidelines (GE0G) and our previous interactions with the NRC. The complexity, potential significance, and generic implications of the deviations identified in the report warranted additional preparation time to maximize the benefit of the conference.                                                                                                                -
To facilitate your preparation efforts, this letter provides a summary of our enforcement conference presentation. FPC acknowledges that deviations from the expected E0P development process and documentation requirements occurred at CR-3 and has implemented corresponding corrective actions. We appreciate that the details of the E0P development process are important to.the primary concern of ensuring the integrity and adequacy of the E0Ps themselves. We will address this .
at the conference and demonstrate that the development process which we did use for our E0P program and the associated management oversight did ensure the technical adequacy of CR-3's E0Ps.                                                                                        >
To help understand how we proceeded, our presentation will first provide an overview of the B&WOG/NRC interface involved in the development of the B&WOG generic technical guidelines (GTG)                    NRC review of the B&WOG guidance is 2/0107 1
i CRYSTAL RIVER ENERGY COMPLEX: 15760 W Power une St . Crystal River, Florida 34428-6708 e (904) 795-6486
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U. S. Nuclear Regulatory Commission 3F0194          Page 2 of 5-ongoing. When FPC made commitments (in response to Generic Letter 83-23) and the staff accepted them in the associated Confirmatory Order, the B&WOG GTG, then called the Anticipated Transient Operating Guidelines (AT0G), were general in nature. In 1988, the B&WOG addressed open items resulting from the NRC's review of ATOG in the Technical Basis Document (now referred to as Volume 3). Before         ,
1992, Volume 3 served as the baseline from which to identify and document           '
deviations at all B&WOG facilities. In 1992, in response to the NRC's stated preference, FPC adopted Volume 1 (GE0G) as the basis' upon which to justify'EOP deviations. As explained below, this transition process is a contributing factor to the E0P process issues identified in the inspection report.                        ,
Turning now to the specifics of the inspection report, the first apparent violation (EEI 302/93-16-01) is the failure to develop an adequate Plant              .
Specific Technical Guidelines (PSTG) because of the lack of an adequately maintained " deviation document." FPC acknowledges this shortcoming.          The     .
deviation document prepared in the 1989-91 time frame was not formally updated.
Nevertheless, FPC developed technically sound E0Ps derived from the generic guidelines (initially Volume 3 and more recently, Volume 1).                CR-3's representative on the B&WOG Operators Support Committee, which is responsible.for the development of the GTG, is the author of the CR-3 E0Ps and understands the implications of deviations from them. He is intimately familiar with the GTG and      ;
their technical bases. Thus, FPC did not ignore the importance of having a technically sound basis for deviating from the CT9 and met the intent' although not the documentation requirements, associated with the preparation of a              '
deviation document. In addition, our E0Ps have been fine-tuned by this same 3
individual on the basis of feedback from extensive plant-specific simulator validation activities.                                                                +
The second apparent violation (EEI 302/93-16-02) identifies a failure to take adequate corrective action in response to previously identified deficiencies.         !
We do not agree with this item.         FPC has dealt with E0P-related concerns       3 previously raised by the NRC, INPO, and internally. For instance, before 1988, FPC did not have a formal deviation document. By 1991, we developed such a document, as well as other critical process elements, in response to NRC concerns and inspection findings. Due to the concurrent evolution of the E0Ps and GTG,         .
FPC did not issue the supporting elements as controlled documents. The NRC reviewed our progress and closed the associated finding. Some' elements of the E0P program, such as completion and maintenance of the deviation document, were inappropriately relegated to follow-up status after E0P issuance .and implementation. Those directly involved in E0P development and FPC management-        ,
focussed on the end-product instead of the supporting details of the developmental process. We upgraded the E0Ps ' using methods in which we had justifiable confidence, as shown by the results, but which did not include all the appropriate process elements.                                                   .;
The third item (EEI 302/93-16-03) notes FPC's failure to maintain adequate             '
control of documents. We generally agree with the identified deficiencies. The deviation document was never formally issued. As recently as 1991, FPC reviewed and provided the deviation document to others (INPO) but never issued it as a controlled document. The second example cited in the inspection report, the FSAR update error, has been ~ corrected and should not recur. FSAR updates will be i

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U. S. Nuclear Regulatory Commission 3F0194-08 Page 3 of 5 automatically incorporated as we transition to a computerized mode of- FSAR; distribution.
Item number four (EEI 302/93-16-04) causes us the greatest concern because it            >
calls into question our confidence in the quality of the upgraded E0Ps. Based on a careful review of all identified E0P procedural issues, we do not agree that         ,
CR-3's E0Ps provide inadequate guidance. In some cases, we disagree with the              ,
positions on how to address certain scenarios. These differences of opinion are          ;
unavoidable consequences of the kinds of judgement we believe all licensee's will         ;
have to exercise as they utilize Probabilistic Safety Assessment (PSA) techniques       1 and other insights gained as part of overall Accident Management efforts. Other           ,
issues already had been addressed through interim guidance. We will address each'        :
of the cited potential deficiencies in information we will provide at the conference.
The fifth apparent violation (EEI 302/93-16-05) pertains to the adequacy of our verification and validation efforts.          We strongly believe that our validation efforts were technically sound although it's documentation was inappropriate.
All six operating crews thoroughly challenged the new E0Ps through two. complete requalification cycles.        Identified concerns were appropriately resolved. Our re-verification and re-validation efforts will further' confirm the technical adequacy of existing procedures.
Item number six (EEI 302/93-16-06) addresses the adequacy of 10 CFR 50.59 reviews. FPC acknowledges the shortcomings in the 50.59 evaluations for existing-E0P revisions. Nevertheless, the deficiencies are not safety significant. As long as the E0P revisions are based on strategies consistent with FSAR analyses and are adequate, they cannot present unreviewed safety questions.
The bottom line is that, although we did not implement specific elements of the expected process, we did substantially improve CR-3's E0Ps. However, we share your disappointment in the process deficiencies even though they~ are not. safety        ;
significant.      We will aggressively pursue their correction and resolution and        i institute measures to prevent a similar recurrence. Our plan for doing so, which is summarized below and described in detail in corrective action, will be-discussed fully at the conference:                                                       #
(1)      FPC has assembled an E0P _ Task Force comprised of qualified individuals to review existing E0P content and to generate appropriate- documentation.         ;
The team includes representatives from System Engineering, Licensing, QA, Training, and Operations. Most either currently hold or previously have-held SRO licenses.                                                              ,
(2)      FPC will work with the NRC to resolve any open items critical to final          i resolution of issues identified in the inspection report. This ' includes agreement on mitigation strategies, the baseline from which to ' justify        ,
deviations, the deviations which require justification, and the extent _of       .
such justifications. SRP 13.5.2 appears to provide appropriate guidance, although the inspection report implied a more extensive scope is                ;
necessary.
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U. S. Nuclear Regulatory Commission 3F0194-08 l         Page 4 of 5 (3)    Fundamental process procedures will be reviewed 'and revised to reflect current practices.         This includes the Writers Guide, as well as Verification and Validation procedures.         We have previously revised procedures for performing 10 CFR 50.59 safety evaluations (and associated training) to reflect the industry guidance in NSAC-125. - The NRC reviewed them during the inspection.
(4)    All E0Ps will be reviewed, revised, re-verified, and re-validated, as necessary. We expect that this review will not result in a large number of substantial technical changes, so the validation may be table-top in nature. FPC also will address any training needs associated with such       ,
procedure changes.
(5)    Our QA department will perform various in-process reviews and other verification activities. If possible, the review team will include peers from other B&WOG utilities.
This will be a thorough and open effort. We will provide a detailed schedule to facilitate follow-up inspections or reviews by your staff. The status of this effort will .be regularly communicated to FPC management, your resident-inspectors, and project management.         We expect to ~ complete these corrective actions before restart from the upcoming refueling outage.              In order to accomplish our goals without adversely impacting other tasks, we plan to complete most corrective actions in the next two months.
FPC also has reviewed the management oversight associated with the E0P program.
Key management at every level thoroughly reviewed the end-product of the process (the E0Ps themselves), as well as their use by CR-3 operators. FPC management has been and remains satisfied with the E0Ps. The status of the process elements was not effectively communicated within the various functional areas.          Thus, management erroneously assumed that the administrative aspects of the E0P program were being fully implemented at CR-3. Sufficient verification did not occur in a timely manner. Management has taken steps to institute more aggressive oversight to assure that this situation will not recur.                               i Our review of the NRC lessons learned information in Information Notice 92-76 and NUREG-1358, Supplement I led us to the discovery of these process-related shortcomings immediately before the inspection.           Specifically, our review processes require the shift technical advisor to concur in the closure of applicable technical information.         The reviewer noted many of the concerns identified by the inspection team and held the item open pending completion of         ,
the NRC inspection, which was to transpire in the following weeks.                 In .
retrospect, this information should have been communicated more fully and promptly to management and the inspection team.                                       ;
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      'U. S. Nuclear Regulatory Commission 3F0194-08 Page 5 of 5 In conclusion, FPC strongly believes the current E0Ps provide effective guidance to the operators at CR-3 and represent a substantial improvement over pre-existing guidance. We can and will thoroughly address the process issues           i identified in the inspection report. FPC is taking appropriate action to enhance   i management oversight over this and similar activities to preclude recurrence.
We look forward to discussing our E0P program with you more fully at the upcoming conference, and throughout our ongoing review.
Sincerely, lov P. M. eard, Jr.
Senior Vice President Nuclear Operations PMB/KRW:ff xc:      Regional Administrator, Region II NRR Project Manager Senior Resident Inspector                                                  ,
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