IR 05000302/1998099

SALP Rept 50-302/98-99 for 961006-980509

ML20249A737
Person / Time
Site:	Crystal River
Issue date:	06/04/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20249A727	List: IR 05000302/1998099 ML20249A726
References
50-302-98-99, NUDOCS 9806180160
Download: ML20249A737 (5)

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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REPORT CRYSTAL RIVER UNIT 3

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50 302/98-99 BACKGROUND The SALP Board convened on May 21. 1998, to assess the nuclear safety performance of the Crystal River Unit 3 for the period October 6.1996, through May 9. 1998. Originally. the assessment was scheduled to end on October 6. 1997. The assessment period was expanded to end May 9.199 so that the assessment would include the plant restart. The SALP Board placed strong emphasis on the last six months which captured the preparations for restart. the return to operation, and the first few ronths of power operation. The SALP Board was conducted in accordance with Management Directive 8.6. " Systematic Assessment of Licensee Performance." Board members were J. P. Jaudon (Board Chairperson)

Director. Division of Reactor Safety: C. A. Casto. Deputy Directo Division of Reactor Projects; and F. J. Hebdon. Director. Project Directorate II-3. Office of Nuclear Reactor Regulation. This assessment was reviewed and approved by the Regional Administrato I PLANT OPERA.TIONS This functional area addresses the control and execution of activities directly related to operating the facility. It includes activities such as plant startup power operation, plant shutdown and response to transients. It also includes initial and requalification training programs for licensed operator Overall performance in the area of Plant Operations was good during this assessment period. The plant was operated competently with few operator-induced problems. Performance improvement initiatives were effective in communicating management expectation Problems such as the deportability process and an unclear shift crew hierarchy and accountability have been addressed effectively. Senior management oversight in Operations was evident, and self-assessments were very self-critical . Operator ownership of the plant and coordination with other groups have improve Control room professionalism and fundamental operating skills were notably improved. Management oversight has led to improved operator communications better shift turnovers, better procedural adherence, and enhanced coordination. Shift supervision aggressively pursued operatior,al and design issues. An NRC Operation Safety Team Inspection concluded that shift comrand and control operator performance, and oversight were excellent. Plant performance after the restart was very good and demonstrated the improved operations performanc Operator performance during transients. outage caerations, and equipment 3roblems las been good, but some problems were o) served indicative of cn& ledge deficiencies. Operator training on plant modifications, plant systems and reactor startup was effective and comprehensiv Operators 9806180160 900604 PDR ADOCK 05000302 O PDR

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L exhibited some knowledge weaknesses attributable to inadequate training on TechnicaLSpecification requirements, application of ris .

information, and specific details on a few systems. Overall o)erator L training was adequat Operator knowledge and inquisitiveness lave

shown improvemen Operations programs and process, while improved were not fully effective. The corrective action, self-assessment, and reporting requirement programs improved from adecuate early in the assessment period to strong The procedure change, of performance the assessment at the enc clearance tagging, and routine a perio continued at an adequate level. Design configuration control and

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tracking systems including controls over annunciators, temporar modifications, component labeling, plant computer configuration, containment penetration status, and other administrative control -

programs exhibited some weaknesses. Senior management focused activities on reducing operator. equi At the end of the assessment period,pmentmany of O and administrative burden programs were undergoing significant upgrades.peration's processes and Operator coordination and communications with other groups have improved. Improved work control and schedule processes were implemented and included insights from other facilities. Significant improvement was noted in coordination of hydrostatic testing as well as with establishing condenser vacuum in the secondary plan Numerous problems related to the development of Emergency Operating Procedures were identified. Most notably, issues were identified concerning inadequate technical justifications, verification and validation, guidance for some plant manipulations. incorporation of in-plant actions into work control processes, guidance for Technical J Support Center actions, and corrective actions for some verification and '

validation issues. The procedures themselves were corrected in order to provide sufficient guidance prior to restar ;

Improvements were made in the self-assessment, quality oversight. and corrective action programs. Some areas still contained minor deficiencies, but these programs were instrumental in assessing and improving the plant performanc The Plant Operations area is rated Category III. MAINTENANCE This functional area addresses activities associated with diagnostic,.

predictive, preventive. and corrective maintenance of structures, systems, and component It also includes all surveillance testing. in-service inspection and other tests associated with equipment and system operability.

L Good corrective maintenance performance was identified in the areas of

, backlog control, strong supervision presence at the job site, detailed

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training program, and adequate procedures for complex maintenance

. activitie Implementation of a 12-week rolling schedule.for maintenance activities was a strength. Performance in accordance with procedures in the areas of hold points and interface with other organizations was good. However, the good performance was offset by instances of poor performance of work activities and inadequate procedure A strength was identified in the on-line risk monitor used as part of the maintenance rule program. Predictive and preventive maintenance performance was generally good, and the very large backlog of overdue preventive maintenance was significantly reduced. Although there were some specific instances noted of poor performance in the area of 3reventive maintenance activities, preventive maintenance was effective

)y the end of the appraisal perio Some improvements were made in coordinating hydrostatic testing, and, in general, surveillance were satisfactorily proceduralized. performed, and documente However, some problems continued to be identified relative to performance of required tests, marginal acceptance criteri failure to test adequately, failure to provide adequate procedures, and failure to evaluate out-of-tolerance installed maintenance and test equipment (M&TE).

Overall. plant material condition improved and was good. However, the material condition in the reactor building was only average despite significant work to upgrade it. Activities associated with Foreign Material Exclusion (FME) were not always implemented effectively. The plant restart and subsequent power operations after a sixteen-month outage were very good. This was a reflection of improved maintenance effectiveness at the end of the appraisal perio Quality Control hold points and Quality control involvement were adequate for complex mechanical maintenance and corrective actions to evaluate whether maintenance activities could affect in-plant Emergency Operating Procedure actions were appropriate. However, corrective actions were inadequate for a number of specific problems, and knowledge 4 and understanding of the second party verification program was not I always adequat The liaintenance area is rated Category I i

I ENGINEERING This functional area assesses the adequacy of technical and engineering l support for plant activitie It includes activities associated with the design and testing of plant modifications engineering and technical support for operations, maintenance, outages testing. surveillance and i procurement: configuration management; training of the engineering  !

staff: and support for licensing activitie _ _ _ _ _ _ - _ - -_ - _ _ _ - _ - _ _ _ _ _ _ _ - _ _ - _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - -

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Performance in engineering improved significantly, especially during the latter. half-of this assessment-cycle .The management oversight of engineering became a strength, and individual Performance improved accordingly. Knowledge of the plant's design ) asis improved. The l design basis was revalidated by system readiness reviews, of varied scope and depth based on risk significance, for all 105 plant systems.

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Issues of safety significance such as the loading of the Emergency Diesel Generators during postulated design basis accidents were identified and addressed through modifications, training, and procedure

. changes as appropriate. Communications between engineering and other

. groups improved markedly. Knowledgeable and capable system engineer played an important part in the improvement of engineering performanc Innovative technical solutions were found and implemented through almost 200 plant modifications. The process to assess whether or not modifications were acceptable or contained unreviewed safety questions-was strengthened and functioned satisfactorily by the end of the assessment period. The implementation of the design change process became rigorous and served to assure that the multiple changes made were well accomplished. In addition to resolving long standing and difficult technical-issues, the readiness reviews and corrective action system in combination identified numerous new issues which were appropriately dispositione As a result of the detailed reviews, there were several issues identified which were found to be acceptable for the short term under the provisions'of Generic Letter 91-18. Revision 1. Final closure of these issues'by the committed dates provides a significant engineering challeng '

The interface between the licensee and the agency concerning licensee amendments needed to implement:the technical solutions developed did not i operate well in several instances in which complex changes were requested. Management intervention to address these issues came relatively late in the assessment period, and while these actions appear

.to have improved the interface, this is considered to remain an area of challenge Engineering' involvement in the revision of Emergency Operating Procedures led to improved, adequately validated procedures. This process required multiple interactions with the staff and also presents a challenge to assure these procedures will provide adequate plant

. specific guidance if underlying assumptions or guidelines chang The Engineering area is rated Category PLANT SUPPORT This functional area assesses activities related to the plant support function, including radiological controls, radioactive effluents and waste, plant chemistry, emergency preparedness, security, fire protection and housekeepin _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _

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L . The performance of security improved markedly. By the end of the.

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assessment period, management-demonstrated an ability to identify issues and take effective corrective actions. Upgrades of the facilities and systems were completed, and previous problems with the control of safeguards material did not recur as the result of effective corrective measures. Another previous problem, knowledge of regulatory requirements, also was not evident during the latter half of this

. assessment period.

l The emergency preparedness function was highlighted by the construction of new and improved facilities, such as the redesigned Technical Support Center, the improved Operational Support Center, and the upgraded Emergency Operations Facility. While the licensee had maintained regulatory compliance using the previous facilities, the improvements enhanced the licensee's ability to deal with contingencies. should they occur. The im) lamentation of more frequent and aggressive training also-

! demonstrated t1e management commitment to maintaining effective l emergency preparednes The fire protection area was also improve The licensee's comprehensive review of 10 CFR 50. Appendix R commitments, and the i subsecuent corrective actions implemented provided a better level of

'conficence that, should a serious fire occur, plant response would be effective. The licensee's withdrawal of previously granted Appendix R ( exemptions demonstrated a strong commitment to addressing.the threat posed by, fire. Modifications to prevent " hot short"' problems with valves needed to take to the plant to cold shutdown after a fire also-demonstrated the management commitment to the fire prevention and

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protection program.

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Radiological Controls had not been part of the reasons for the plant j shutdown and were not directly addressed in the Confirmatory Action  ;

,. Letter. Since the plant was shut down for much of the )eriod, the challenges in this area were comparatively minor, and tie doses accumulated were low. However, inspections of this area just prior to and after restart indicated that there had not been the same degree of change and improvement as had been seen in the other areas of plant l: support. Human performance continued to be a challenge in the chemistry l

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and radiation protection programs, resulting in problems with procedural adherence. The relatively low doses notwithstanding, the ALARA program lacked the aggressiveness seen in other areas of the plant's performance, and ALARA presents a challenge, i: -Waste generation was relatively low. Chemistry was acceptable, and I

steam generator performance after restart indicated that there were not serious problems in this area. The material condition of the i containment was a focus during the shutdown, and although it improve ,

it was still judged to be in the average rang l

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The Plant Support area is rated Category :

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