IR 05000302/2006009: Difference between revisions
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| issue date = 07/20/2006 | | issue date = 07/20/2006 | ||
| title = IR 05000302-06-009 on 06/05/2006-06/09/2006 and 06/19/2006-06/23/2006 for Crystal River, Unit 3; Identification and Resolution of Problems | | title = IR 05000302-06-009 on 06/05/2006-06/09/2006 and 06/19/2006-06/23/2006 for Crystal River, Unit 3; Identification and Resolution of Problems | ||
| author name = Munday J | | author name = Munday J | ||
| author affiliation = NRC/RGN-II/DRP/RPB3 | | author affiliation = NRC/RGN-II/DRP/RPB3 | ||
| addressee name = Young D | | addressee name = Young D | ||
| addressee affiliation = Florida Power Corp, Progress Energy Florida, Inc | | addressee affiliation = Florida Power Corp, Progress Energy Florida, Inc | ||
| docket = 05000302 | | docket = 05000302 | ||
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=Text= | =Text= | ||
{{#Wiki_filter | {{#Wiki_filter:July 20, 2006Mr. Dale E. Young, Vice PresidentCrystal River Nuclear Plant (NA1B) | ||
ATTN: Supervisor, Licensing &Regulatory Programs15760 West Power Line Street Crystal River, FL 34428-6708SUBJECT:CRYSTAL RIVER UNIT 3 - NRC PROBLEM IDENTIFICATION ANDRESOLUTION INSPECTION REPORT 050000302/2006009 | |||
ATTN: Supervisor, Licensing &Regulatory Programs15760 West Power Line Street Crystal River, FL 34428- | |||
==Dear Mr. Young:== | ==Dear Mr. Young:== | ||
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FPC2In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and itsenclosure, will be available electronically for public inspection in the NRC Public DocumentRoom or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). | FPC2In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and itsenclosure, will be available electronically for public inspection in the NRC Public DocumentRoom or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). | ||
Sincerely,/RA by Son Ninh Acting for/Joel T. Munday, ChiefReactor Projects Branch 3 Division of Reactor ProjectsDocket No. 50-302License No. DPR-72 | Sincerely, | ||
/RA by Son Ninh Acting for/Joel T. Munday, ChiefReactor Projects Branch 3 Division of Reactor ProjectsDocket No. 50-302License No. DPR-72 | |||
===Enclosure:=== | ===Enclosure:=== | ||
Inspection Report 05000302/2006009 | Inspection Report 05000302/2006009 w/Attachment: Supplemental Information | ||
Supplemental | |||
REGION IIDocket No:50-302 License No:DPR-72 Report No:05000302/2006009 Licensee:Progress Energy Florida - Florida Power CorporationFacility:Crystal River Unit 3Location:15760 West Power Line StreetCrystal River, FL 34428-6708Dates:June 5-9 and June 19-23, 2006 Inspectors:C. Patterson, Senior Resident Inspector, Team LeaderT. Morrissey, Senior Resident Inspector T. Nazario, Project Engineer M. Speck, Resident InspectorApproved by:Joel T. Munday, Chief Reactor Projects Branch 3 Division of Reactor Projects SUMMARY OF FINDINGSIR 05000302/2006009; 06/05/2006-06/09/2006 and 06/19/2006-06/23/2006; Crystal RiverNuclear Plant, Unit 3; Identification and Resolution of Problems. A finding was identified in the area of effectiveness of corrective actions.The inspection was conducted by two senior resident inspectors, a resident inspector and aproject engineer. One Green finding of very low safety significance was identified during this inspection. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors isdescribed in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000. Identification and Resolution of ProblemsThe team concluded that in general, problems were properly identified, evaluated, prioritized,and corrected within the licensee's problem identification and resolution program. Evaluation of issues was generally comprehensive and technically adequate. Formal root cause evaluations for issues classified as significant conditions adverse to quality were comprehensive and detailed. Overall, corrective actions developed and implemented for issues were effective in correcting the problems. One exception was noted concerning corrective action for identified deficiencies with three motor-operated valves.The processes and procedures of the licensee's corrective action program (CAP) weregenerally adequate; thresholds for identifying issues were appropriately low, and in most cases, corrective actions were adequate to address conditions adverse to quality. Nuclear Assessment Section audits and departmental self-assessments were effective in identifying issues and directing attention to areas that needed improvement. Licensee identified weaknesses and issues in self-assessments were appropriately entered into the CAP and addressed. However, the inspectors observed that several lower threshold issues had not been entered into the CAP. Based on discussions and interviews conducted with plant employees from variousdepartments, the inspectors did not identify any reluctance to report safety concerns. A.Inspector Identified FindingsCornerstone: Mitigating Systems Green. A Green finding was identified by the inspectors for failure to conduct anextent of condition evaluation when three motor operated valves (MOVs) which were thought to not be susceptible to incorrect pinion gear installation were found with their pinion gears installed backwards.This finding is more than minor because it affected the equipment performanceattribute of the mitigating system cornerstone and affected the cornerstoneobjective of ensuring reliability of a mitigating system. Using NRC M anualChapter 0609, "Significance Determination Process, " Appendix A, Phase 1, this finding was determined to be of very low significance (Green), because the 3finding has not resulted in a loss of safety function and was not screened aspotentially risk significant due to external events. The primary cause of the finding was related to the cross cutting area of Problem Identification and Resolution, in that station personnel failed to determine the need for additional MOV inspections when three MOVs which were initially thought to not be susceptible to incorrect pinion gear installation were found with reversed pinion gears, one of which was also discovered with an improperly staked pinion key.B.Licensee Identified ViolationsNone. | |||
Report Details4.OTHER ACTIVITIES (OA)4OA2Problem Identification and ResolutionThe team based the following conclusions, in part, on issues identified during the period,July 2, 2004 (The last biennial problem identification and resolution inspection) to the end of the inspection on June 23, 2006. In addition, the team reviewed problems for selected systems, which were identified outside this assessment period whosesignificance may be age dependent. a.Effectiveness of Problem Identification (1)Inspection ScopeThe inspectors reviewed the licensee's corrective action program (CAP) procedureswhich described the administrative process for initiating and resolving problems primarily through the use of nuclear condition reports (NCRs). The inspectors reviewed selectedNCRs, and attended meetings where NCRs were screened for significance, todetermine whether the licensee was identifying, accurately characterizing, and enteringproblems into the CAP at an appropriate threshold.The inspectors selected NCRs for review which involved issues covering the sevencornerstones of safety identified in the NRC's Reactor Oversight Process (ROP). Theselected samples involved various licensee classified severity levels and assigned site departments. The inspectors also conducted a detailed review of NCRs for several risksignificant systems. These systems were selected based on equipment performancehistory, Maintenance Rule (MR) considerations, and risk significance insights from the licensee's probabilistic safety assessment. The systems selected for review were theEmergency Diesel Generators (EGDGs) and Diesel Fuel Tanks; Decay Heat Removal, Decay Heat Closed Cycle (DC); Decay Heat Raw Water (RW); and Emergency and Auxiliary Feedwater systems. The inspectors reviewed NCRs, maintenance history, andselected completed work orders (WOs) for the systems and reviewed associated systemhealth reports. The inspectors also reviewed NRC inspection reports dating back twoyears which documented NCRs. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP. | Report Details4.OTHER ACTIVITIES (OA)4OA2Problem Identification and ResolutionThe team based the following conclusions, in part, on issues identified during the period,July 2, 2004 (The last biennial problem identification and resolution inspection) to the end of the inspection on June 23, 2006. In addition, the team reviewed problems for selected systems, which were identified outside this assessment period whosesignificance may be age dependent. a.Effectiveness of Problem Identification (1)Inspection ScopeThe inspectors reviewed the licensee's corrective action program (CAP) procedureswhich described the administrative process for initiating and resolving problems primarily through the use of nuclear condition reports (NCRs). The inspectors reviewed selectedNCRs, and attended meetings where NCRs were screened for significance, todetermine whether the licensee was identifying, accurately characterizing, and enteringproblems into the CAP at an appropriate threshold.The inspectors selected NCRs for review which involved issues covering the sevencornerstones of safety identified in the NRC's Reactor Oversight Process (ROP). Theselected samples involved various licensee classified severity levels and assigned site departments. The inspectors also conducted a detailed review of NCRs for several risksignificant systems. These systems were selected based on equipment performancehistory, Maintenance Rule (MR) considerations, and risk significance insights from the licensee's probabilistic safety assessment. The systems selected for review were theEmergency Diesel Generators (EGDGs) and Diesel Fuel Tanks; Decay Heat Removal, Decay Heat Closed Cycle (DC); Decay Heat Raw Water (RW); and Emergency and Auxiliary Feedwater systems. The inspectors reviewed NCRs, maintenance history, andselected completed work orders (WOs) for the systems and reviewed associated systemhealth reports. The inspectors also reviewed NRC inspection reports dating back twoyears which documented NCRs. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP. | ||
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Items reviewed generally covered a two year period of time, however, in accordance with the inspection procedure, a five year review was performed for selected systems forage dependent issues.The inspectors conducted plant walkdowns of equipment associated with the selectedsystems to assess the material condition and to look for any deficiencies that had notbeen entered into the CAP. Control Room walkdowns were performed by the inspectors to verify the accuracy of the main control room (MCR) deficiency list and to ascertain whether deficiencies were entered into the CAP. Control room operator logs and site observation items were also reviewed to verify that issues identified were properly entered into the CAP. | Items reviewed generally covered a two year period of time, however, in accordance with the inspection procedure, a five year review was performed for selected systems forage dependent issues.The inspectors conducted plant walkdowns of equipment associated with the selectedsystems to assess the material condition and to look for any deficiencies that had notbeen entered into the CAP. Control Room walkdowns were performed by the inspectors to verify the accuracy of the main control room (MCR) deficiency list and to ascertain whether deficiencies were entered into the CAP. Control room operator logs and site observation items were also reviewed to verify that issues identified were properly entered into the CAP. | ||
6The inspectors reviewed selected industry operating experience items associated withthe selected systems, including NRC generic communications, to verify that these wereappropriately evaluated for applicability and whether issues identified through thesereviews were entered into the CAP.The inspectors reviewed licensee Nuclear Assurance Section (NAS) audits, NAS qualityreports, and department self-assessments including those which focused on problem identification and resolution to verify that findings were entered into the CAP and to verify that these findings were consistent with the NRC's assessment of the licensee's CAP.The inspectors attended various plant meetings to observe management oversightfunctions of the corrective action process. These included plan of the day meetings, a Plant Nuclear Safety Committee (PNSC) meeting, shift operations turnover meeting, and department CAP rollup meetings. Documents reviewed are listed in the Attachment. (2)AssessmentThe inspectors determined that the licensee's CAP was generally effective at identifyingproblems. Industry operating experience items were effectively evaluated for applicability and entered into the CAP. NAS audits and departmental self-assessmentswere effective in identifying issues and directing attention to areas that needed improvement. Licensee identified weaknesses and issues in self-assessments were appropriately entered into the corrective action program and addressed. Operator control room logs thoroughly documented problems giving very specific detail of conditions observed and actions taken to correct the problem. Trending was effective in monitoring programs' health. However, the inspectors observed some cases where several lower threshold issueshad not been identified or entered into the CAP. Examples include: not having acalculation to support operability of the EDGs with a flood flap raised at the air inletstructure; deficiencies identified during a walkdown on the emergency feed water (EFW) | |||
systems that were not previously identified (work orders were written); and no NCR for along standing issue with a cycling service water check valve. Specific NCRs written arelisted in the attachment. b.Prioritization and Evaluation of Issues (1)Inspection ScopeThe inspectors reviewed NCRs, including root and apparent cause evaluations, site anddepartment trend reports, and observed other activities as discussed in Section 4OA2.a to verify that the licensee appropriately prioritized and evaluated problems in accordance with their risk significance. The inspection was intended to verify that the licensee adequately determined the cause of the problems, including root cause analysis where appropriate, and adequately addressed operability, reportability,common cause, generic concerns, extent of condition, and extent of cause. | systems that were not previously identified (work orders were written); and no NCR for along standing issue with a cycling service water check valve. Specific NCRs written arelisted in the attachment. b.Prioritization and Evaluation of Issues (1)Inspection ScopeThe inspectors reviewed NCRs, including root and apparent cause evaluations, site anddepartment trend reports, and observed other activities as discussed in Section 4OA2.a to verify that the licensee appropriately prioritized and evaluated problems in accordance with their risk significance. The inspection was intended to verify that the licensee adequately determined the cause of the problems, including root cause analysis where appropriate, and adequately addressed operability, reportability,common cause, generic concerns, extent of condition, and extent of cause. | ||
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This finding is more than minor because it affected the equipment performance attribute of the mitigating system cornerstone and affected the cornerstone objective of ensuringreliability of a mitigating system. Using NRC Manual Chapter 0609, "SignificanceDetermination Process, " Appendix A, Phase 1, this finding was determined to be of very low significance (Green), because the finding has not resulted in a loss of safety function and was not screened as potentially risk significant due to external events. The primary cause of the finding was related to the cross cutting area of Problem Identification and Resolution, in that station personnel failed to conduct an extent ofcondition evaluation when three MOVs which were initially thought to be not susceptible to incorrect pinion gear installation were found with reversed pinion gears, one of which was also discovered with an improperly staked pinion key.Enforcement: The failure to conduct an extent of condition evaluation when three MOVswhich were thought to not be susceptible to incorrect pinion gear installation were found with their pinion gears installed backwards did not constitute a violation of regulatory requirements. This finding is identified as FIN 05000302/2006-009-01, Failure to Conduct an Extent of Condition Review after Three Motor Operated Valves Were Found with Their Pinion Gears Installed Incorrectly. An evaluation is being performed to determine any necessary short and long term corrective actions. | This finding is more than minor because it affected the equipment performance attribute of the mitigating system cornerstone and affected the cornerstone objective of ensuringreliability of a mitigating system. Using NRC Manual Chapter 0609, "SignificanceDetermination Process, " Appendix A, Phase 1, this finding was determined to be of very low significance (Green), because the finding has not resulted in a loss of safety function and was not screened as potentially risk significant due to external events. The primary cause of the finding was related to the cross cutting area of Problem Identification and Resolution, in that station personnel failed to conduct an extent ofcondition evaluation when three MOVs which were initially thought to be not susceptible to incorrect pinion gear installation were found with reversed pinion gears, one of which was also discovered with an improperly staked pinion key.Enforcement: The failure to conduct an extent of condition evaluation when three MOVswhich were thought to not be susceptible to incorrect pinion gear installation were found with their pinion gears installed backwards did not constitute a violation of regulatory requirements. This finding is identified as FIN 05000302/2006-009-01, Failure to Conduct an Extent of Condition Review after Three Motor Operated Valves Were Found with Their Pinion Gears Installed Incorrectly. An evaluation is being performed to determine any necessary short and long term corrective actions. | ||
10 d.Assessment of Safety-Conscious Work Environment (1)Inspection ScopeThe team randomly interviewed on-site workers regarding their knowledge of thecorrective action program at Crystal River and their threshold to write NCRs or raisesafety concerns. Additionally during technical discussions with members of the plant staff, the inspectors conducted interviews to develop a general perspective of the safety- | 10 d.Assessment of Safety-Conscious Work Environment (1)Inspection ScopeThe team randomly interviewed on-site workers regarding their knowledge of thecorrective action program at Crystal River and their threshold to write NCRs or raisesafety concerns. Additionally during technical discussions with members of the plant staff, the inspectors conducted interviews to develop a general perspective of the safety-conscious work environment at the site. The interviews were also conducted to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns. The inspectors reviewed the licensee's employee concerns program (ECP) and interviewed the ECP manager. Additionally, the inspectors reviewed a select number of completed ECP reports to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate. (2)AssessmentBased on this inspection and the NCR reviews, the inspectors concluded that licenseemanagement emphasized the need for all employees to promptly identify and report problems using the appropriate methods established within the administrative programs. | ||
conscious work environment at the site. The interviews were also conducted to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns. The inspectors reviewed the licensee's employee concerns program (ECP) and interviewed the ECP manager. Additionally, the inspectors reviewed a select number of completed ECP reports to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate. (2)AssessmentBased on this inspection and the NCR reviews, the inspectors concluded that licenseemanagement emphasized the need for all employees to promptly identify and report problems using the appropriate methods established within the administrative programs. | |||
The inspectors did not identify any reluctance on the part of the licensee staff to report safety concerns. 4OA6Exit MeetingOn June 23, 2006, the inspectors presented the inspection results to Mr. Dale Youngand other members of his staff who acknowledged the finding. The inspectors confirmed that proprietary information was not provided or examined during the inspection. The inspector re-exited with Mr. Dale Young on July 18, 2006, who acknowledged the Green finding. The finding was determined not to be a violation of regulatory requirements. ATTACHMENT: SUPPLEMENTAL INFORMATION AttachmentSUPPLEMENTAL INFORMATIONKEY POINTS OF CONTACTLicensee personnel | The inspectors did not identify any reluctance on the part of the licensee staff to report safety concerns. 4OA6Exit MeetingOn June 23, 2006, the inspectors presented the inspection results to Mr. Dale Youngand other members of his staff who acknowledged the finding. The inspectors confirmed that proprietary information was not provided or examined during the inspection. The inspector re-exited with Mr. Dale Young on July 18, 2006, who acknowledged the Green finding. The finding was determined not to be a violation of regulatory requirements. ATTACHMENT: SUPPLEMENTAL INFORMATION AttachmentSUPPLEMENTAL INFORMATIONKEY POINTS OF CONTACTLicensee personnel |
Revision as of 14:47, 13 July 2019
ML062010432 | |
Person / Time | |
---|---|
Site: | Crystal River |
Issue date: | 07/20/2006 |
From: | Joel Munday NRC/RGN-II/DRP/RPB3 |
To: | Young D Florida Power Corp, Progress Energy Florida |
References | |
IR-06-009 | |
Download: ML062010432 (21) | |
Text
July 20, 2006Mr. Dale E. Young, Vice PresidentCrystal River Nuclear Plant (NA1B)
ATTN: Supervisor, Licensing &Regulatory Programs15760 West Power Line Street Crystal River, FL 34428-6708SUBJECT:CRYSTAL RIVER UNIT 3 - NRC PROBLEM IDENTIFICATION ANDRESOLUTION INSPECTION REPORT 050000302/2006009
Dear Mr. Young:
On June 23, 2006, the NRC completed a team inspection at your Crystal River Unit 3. Theenclosed report documents the inspection findings which were discussed on June 23, 2006, with you and other members of your staff.This inspection was an examination of activities conducted under your license as they relate tothe identification and resolution of problems, and compliance with the Commission's rules and regulations and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of plant equipment and activities, and interviews with personnel.On the basis of the samples selected for review, the inspectors concluded that in general, your corrective action program processes and procedures were effective; thresholds for identifying issues were appropriately low; and problems were properly evaluated and corrected within the problem identification and resolution program (PI&R). However, there was one Green finding identified during this inspection associated with a failure to conduct an extent of condition evaluation when three motor operated valves which were thought to not be susceptible to incorrect pinion gear installation were found with their pinion gears installed backwards. This finding was determined not to be a violation of NRC requirements.
FPC2In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and itsenclosure, will be available electronically for public inspection in the NRC Public DocumentRoom or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA by Son Ninh Acting for/Joel T. Munday, ChiefReactor Projects Branch 3 Division of Reactor ProjectsDocket No. 50-302License No. DPR-72
Enclosure:
Inspection Report 05000302/2006009 w/Attachment: Supplemental Information
REGION IIDocket No:50-302 License No:DPR-72 Report No:05000302/2006009 Licensee:Progress Energy Florida - Florida Power CorporationFacility:Crystal River Unit 3Location:15760 West Power Line StreetCrystal River, FL 34428-6708Dates:June 5-9 and June 19-23, 2006 Inspectors:C. Patterson, Senior Resident Inspector, Team LeaderT. Morrissey, Senior Resident Inspector T. Nazario, Project Engineer M. Speck, Resident InspectorApproved by:Joel T. Munday, Chief Reactor Projects Branch 3 Division of Reactor Projects SUMMARY OF FINDINGSIR 05000302/2006009; 06/05/2006-06/09/2006 and 06/19/2006-06/23/2006; Crystal RiverNuclear Plant, Unit 3; Identification and Resolution of Problems. A finding was identified in the area of effectiveness of corrective actions.The inspection was conducted by two senior resident inspectors, a resident inspector and aproject engineer. One Green finding of very low safety significance was identified during this inspection. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors isdescribed in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000. Identification and Resolution of ProblemsThe team concluded that in general, problems were properly identified, evaluated, prioritized,and corrected within the licensee's problem identification and resolution program. Evaluation of issues was generally comprehensive and technically adequate. Formal root cause evaluations for issues classified as significant conditions adverse to quality were comprehensive and detailed. Overall, corrective actions developed and implemented for issues were effective in correcting the problems. One exception was noted concerning corrective action for identified deficiencies with three motor-operated valves.The processes and procedures of the licensee's corrective action program (CAP) weregenerally adequate; thresholds for identifying issues were appropriately low, and in most cases, corrective actions were adequate to address conditions adverse to quality. Nuclear Assessment Section audits and departmental self-assessments were effective in identifying issues and directing attention to areas that needed improvement. Licensee identified weaknesses and issues in self-assessments were appropriately entered into the CAP and addressed. However, the inspectors observed that several lower threshold issues had not been entered into the CAP. Based on discussions and interviews conducted with plant employees from variousdepartments, the inspectors did not identify any reluctance to report safety concerns. A.Inspector Identified FindingsCornerstone: Mitigating Systems Green. A Green finding was identified by the inspectors for failure to conduct anextent of condition evaluation when three motor operated valves (MOVs) which were thought to not be susceptible to incorrect pinion gear installation were found with their pinion gears installed backwards.This finding is more than minor because it affected the equipment performanceattribute of the mitigating system cornerstone and affected the cornerstoneobjective of ensuring reliability of a mitigating system. Using NRC M anualChapter 0609, "Significance Determination Process, " Appendix A, Phase 1, this finding was determined to be of very low significance (Green), because the 3finding has not resulted in a loss of safety function and was not screened aspotentially risk significant due to external events. The primary cause of the finding was related to the cross cutting area of Problem Identification and Resolution, in that station personnel failed to determine the need for additional MOV inspections when three MOVs which were initially thought to not be susceptible to incorrect pinion gear installation were found with reversed pinion gears, one of which was also discovered with an improperly staked pinion key.B.Licensee Identified ViolationsNone.
Report Details4.OTHER ACTIVITIES (OA)4OA2Problem Identification and ResolutionThe team based the following conclusions, in part, on issues identified during the period,July 2, 2004 (The last biennial problem identification and resolution inspection) to the end of the inspection on June 23, 2006. In addition, the team reviewed problems for selected systems, which were identified outside this assessment period whosesignificance may be age dependent. a.Effectiveness of Problem Identification (1)Inspection ScopeThe inspectors reviewed the licensee's corrective action program (CAP) procedureswhich described the administrative process for initiating and resolving problems primarily through the use of nuclear condition reports (NCRs). The inspectors reviewed selectedNCRs, and attended meetings where NCRs were screened for significance, todetermine whether the licensee was identifying, accurately characterizing, and enteringproblems into the CAP at an appropriate threshold.The inspectors selected NCRs for review which involved issues covering the sevencornerstones of safety identified in the NRC's Reactor Oversight Process (ROP). Theselected samples involved various licensee classified severity levels and assigned site departments. The inspectors also conducted a detailed review of NCRs for several risksignificant systems. These systems were selected based on equipment performancehistory, Maintenance Rule (MR) considerations, and risk significance insights from the licensee's probabilistic safety assessment. The systems selected for review were theEmergency Diesel Generators (EGDGs) and Diesel Fuel Tanks; Decay Heat Removal, Decay Heat Closed Cycle (DC); Decay Heat Raw Water (RW); and Emergency and Auxiliary Feedwater systems. The inspectors reviewed NCRs, maintenance history, andselected completed work orders (WOs) for the systems and reviewed associated systemhealth reports. The inspectors also reviewed NRC inspection reports dating back twoyears which documented NCRs. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP.
Items reviewed generally covered a two year period of time, however, in accordance with the inspection procedure, a five year review was performed for selected systems forage dependent issues.The inspectors conducted plant walkdowns of equipment associated with the selectedsystems to assess the material condition and to look for any deficiencies that had notbeen entered into the CAP. Control Room walkdowns were performed by the inspectors to verify the accuracy of the main control room (MCR) deficiency list and to ascertain whether deficiencies were entered into the CAP. Control room operator logs and site observation items were also reviewed to verify that issues identified were properly entered into the CAP.
6The inspectors reviewed selected industry operating experience items associated withthe selected systems, including NRC generic communications, to verify that these wereappropriately evaluated for applicability and whether issues identified through thesereviews were entered into the CAP.The inspectors reviewed licensee Nuclear Assurance Section (NAS) audits, NAS qualityreports, and department self-assessments including those which focused on problem identification and resolution to verify that findings were entered into the CAP and to verify that these findings were consistent with the NRC's assessment of the licensee's CAP.The inspectors attended various plant meetings to observe management oversightfunctions of the corrective action process. These included plan of the day meetings, a Plant Nuclear Safety Committee (PNSC) meeting, shift operations turnover meeting, and department CAP rollup meetings. Documents reviewed are listed in the Attachment. (2)AssessmentThe inspectors determined that the licensee's CAP was generally effective at identifyingproblems. Industry operating experience items were effectively evaluated for applicability and entered into the CAP. NAS audits and departmental self-assessmentswere effective in identifying issues and directing attention to areas that needed improvement. Licensee identified weaknesses and issues in self-assessments were appropriately entered into the corrective action program and addressed. Operator control room logs thoroughly documented problems giving very specific detail of conditions observed and actions taken to correct the problem. Trending was effective in monitoring programs' health. However, the inspectors observed some cases where several lower threshold issueshad not been identified or entered into the CAP. Examples include: not having acalculation to support operability of the EDGs with a flood flap raised at the air inletstructure; deficiencies identified during a walkdown on the emergency feed water (EFW)
systems that were not previously identified (work orders were written); and no NCR for along standing issue with a cycling service water check valve. Specific NCRs written arelisted in the attachment. b.Prioritization and Evaluation of Issues (1)Inspection ScopeThe inspectors reviewed NCRs, including root and apparent cause evaluations, site anddepartment trend reports, and observed other activities as discussed in Section 4OA2.a to verify that the licensee appropriately prioritized and evaluated problems in accordance with their risk significance. The inspection was intended to verify that the licensee adequately determined the cause of the problems, including root cause analysis where appropriate, and adequately addressed operability, reportability,common cause, generic concerns, extent of condition, and extent of cause.
7The review included the appropriateness of the assigned significance, the timeliness ofresolutions, level of effort in the investigation, and the scope and depth of the causal analysis. The review was also performed to verify that the licensee appropriately identified corrective actions to prevent recurrence and that those actions had been appropriately prioritized.The inspectors also attended several plan of the day meetings and a PNSC meeting todetermine if plant problems were being properly characterized, prioritized, assigned, and if appropriate, management attention was applied to significant plant issues. (2)AssessmentThe inspectors determined that overall, the licensee had appropriately assessed andprioritized issues. Each NCR written and priority level assigned was reviewed during theplan of the day meeting which was chaired by the superintendent shift operations andattended by upper management and department heads. Management reviews of NCRswere thorough and adequate consideration was given to system or componentoperability and associated plant risks. Additionally, the inspectors attended a PNSCmeeting and reviewed meeting minutes from several other PNSC meetings and concluded that additional quality was added to the licensee's process by the PNSC.
One example of being proactive was a recent modification to the main transformer to provide real time monitoring of gassing issues which provided a high degree of confidence for detecting any further degradation of the transformer. The inspectors concluded that evaluation of issues was generally comprehensive and technically adequate. Formal root cause evaluations for issues classified as significant conditions adverse to quality were comprehensive and detailed. However, several examples were identified where problem evaluations were not thorough or were narrowly focused: NCR 197916 was written to address some valid NCRs which were cancelled byreference to another NCR, not in accordance with the administrative process. There was a potential for some trending data to be lost.NCR 135880 contained information about RWV-59, Decay Heat Removal HeatExchanger relief valve, failure but did not contain all of the history concerning other similar valve failures. NCR 136908 documented a water hammer in the feedwater system and treatedthis as an equipment failure but did not address the cause of the water hammer.NCR 138035 documented an instrument affected by a water hammer event. However, other instruments potentially affected in the system were notaddressed. NCRs 175671 and 175674, documented active boric acid leaks which werescreened as priority level 3 instead of priority level 2, however, these NCRs were processed like level 2 NCRs.
8Nonconformance Evaluation (NCON) concerning a MOV operability did notconsider NRC IN 85-22, Failure of Limitorque Motor-Operated Valves Resultingfrom Incorrect Installation of Pinion Gear or other external operating experience items. The NCON only used operating experience from the plant. c.Effectiveness of Corrective Actions (1)Inspection ScopeThe inspectors reviewed a sample of NCRs, selected licensee effectiveness reviews, andwork orders initiated to resolve NCRs to verify the licensee had identified andimplemented timely and appropriate corrective actions to address problems. The inspectors verified that the corrective actions were properly assigned, documented, and tracked to ensure completion. The review was also conducted to verify the adequacy of corrective actions to address equipment deficiencies and maintenance rule (MR)
functional failures of risk significant plant safety systems. (2)AssessmentThe inspectors determined that overall, corrective actions were effective in correcting theproblems. The effectiveness of corrective action was correlated to good material conditon of the systems reviewed. The Diesel Generators, Service Water, EFW, DecayHeat Removal, Decay Heat DC,and Decay Heat RW areas were free of leaks and standing water. The policy of Zero Tolerance for Equipment Failure was seen as a proactive approach to increase equipment reliability and performance. Although theinspectors identified that most corrective actions implemented by the licensee were appropriate for the severity and risk significance of the problem identified, one exception was noted in the finding below:
(3)FindingIntroduction: A Green finding was identified by the inspectors for failure to conduct anextent of condition evaluation when three MOVs which were thought to not be susceptibleto incorrect pinion gear installation were found with their pinion gears installed backwards.Description: In September 2003, NRC Information Notice (IN) 2003-015, Importance ofFollowup Activities in Resolving Maintenance Issues, was issued and documented a need for followup activities to verify implementation of corrective actions to resolve maintenance issues for safety-related components at nuclear power plants. The IN discussed a number of instances concerning deficiencies associated with motor pinion gear installation.The licensee assessed the IN as OPEX item 104270 and determined that six out ofseventy-five MOVs were potentially susceptible to the condition identified in the IN. This determination was based on the fact that maintenance procedure revisions were madein 1989, in part, to ensure proper installation of the motor pinion gear. The licensee concluded that after the maintenance procedure was revised, the likelihood of installingthe pinion gear incorrectly was low and therefore, chose to only inspect those valves that had undergone maintenance before the upgraded procedure was implemented.
9As of the date of this report, five of the six susceptible MOVs had been inspected withno problems noted.However, during the 2005 refueling outage, the licensee identified three valves which had undergone maintenance since the procedure was revised and had the motor pinion gears installed backwards. Those valves were the MOV FWV-31, FWV-32 (feedwater isolation valves) and DHV-35 (borated water storage tank (BWST) isolation valve)
documented in NCRs 174467,175291,and 173501. Additionally, the licenseedetermined that the motor pinion gear shaft key for the DHV-35 was improperly staked and extended beyond its normal location. All three valves were restored to their design configuration prior to being returned to service. The inspectors reviewed NCR 175291which recommended that the scope of valves to be inspected be extended, however, the recommendation was rejected. The inspectors questioned the licensee on the adequacy of the initial determination of which MOVs to inspect under OPEX 104270 given that the three valves with the incorrectly installed pinion gears were initially determined to not need inspection. The licensee initiated NCR 196742 to provide ageneric operability determination for installed MOVs that were susceptible to having thepinion gears installed backwards and to reevaluate the need to inspect MOVs that were initially thought to be not susceptible.Analysis: The failure to conduct an extent of condition evaluation after three MOVs thatwere initially thought to not be susceptible to incorrect pinion gear and pinion key installation were found with the pinion gear installed backwards is a performance deficiency that could affect the reliability of MOVs associated with mitigating systems.
This finding is more than minor because it affected the equipment performance attribute of the mitigating system cornerstone and affected the cornerstone objective of ensuringreliability of a mitigating system. Using NRC Manual Chapter 0609, "SignificanceDetermination Process, " Appendix A, Phase 1, this finding was determined to be of very low significance (Green), because the finding has not resulted in a loss of safety function and was not screened as potentially risk significant due to external events. The primary cause of the finding was related to the cross cutting area of Problem Identification and Resolution, in that station personnel failed to conduct an extent ofcondition evaluation when three MOVs which were initially thought to be not susceptible to incorrect pinion gear installation were found with reversed pinion gears, one of which was also discovered with an improperly staked pinion key.Enforcement: The failure to conduct an extent of condition evaluation when three MOVswhich were thought to not be susceptible to incorrect pinion gear installation were found with their pinion gears installed backwards did not constitute a violation of regulatory requirements. This finding is identified as FIN 05000302/2006-009-01, Failure to Conduct an Extent of Condition Review after Three Motor Operated Valves Were Found with Their Pinion Gears Installed Incorrectly. An evaluation is being performed to determine any necessary short and long term corrective actions.
10 d.Assessment of Safety-Conscious Work Environment (1)Inspection ScopeThe team randomly interviewed on-site workers regarding their knowledge of thecorrective action program at Crystal River and their threshold to write NCRs or raisesafety concerns. Additionally during technical discussions with members of the plant staff, the inspectors conducted interviews to develop a general perspective of the safety-conscious work environment at the site. The interviews were also conducted to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns. The inspectors reviewed the licensee's employee concerns program (ECP) and interviewed the ECP manager. Additionally, the inspectors reviewed a select number of completed ECP reports to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate. (2)AssessmentBased on this inspection and the NCR reviews, the inspectors concluded that licenseemanagement emphasized the need for all employees to promptly identify and report problems using the appropriate methods established within the administrative programs.
The inspectors did not identify any reluctance on the part of the licensee staff to report safety concerns. 4OA6Exit MeetingOn June 23, 2006, the inspectors presented the inspection results to Mr. Dale Youngand other members of his staff who acknowledged the finding. The inspectors confirmed that proprietary information was not provided or examined during the inspection. The inspector re-exited with Mr. Dale Young on July 18, 2006, who acknowledged the Green finding. The finding was determined not to be a violation of regulatory requirements. ATTACHMENT: SUPPLEMENTAL INFORMATION AttachmentSUPPLEMENTAL INFORMATIONKEY POINTS OF CONTACTLicensee personnel
- M. Annacone, Manager, EngineeringW. Brewer, Manager, Maintenance R. Hons, Manager, Training J. Franke, Plant General Manager J. Hays, Manager, Outage and Scheduling J. Holt, Manager, Operations P. Infanger, Supervisor, Licensing M. Rigsby, Superintendent, Radiation Protection D. Roderick, Director, Site Operations J. Stephenson, Supervisor, Principal Nuclear Emergency Preparedness T. Hobbs, Manager, Nuclear Assessment D. Young, Vice President, Crystal River Nuclear PlantITEMS OPENED, CLOSED AND DISCUSSEDOpened and Closed05000302/2006009-01FINFailure to Conduct an Extent of Condition Review afterThree Motor Operated Valves Were Found with Their Pinion Gears Installed Incorrectly (4AO2.c).
A-2AttachmentCRYSTAL RIVER PROBLEM IDENTIFICATION AND RESOLUTION DOCUMENT NEEDS1.A copy of all corporate and site level procedures associated with the corrective actionprocess, operating experience program, risk assessment programs, maintenance rule program, employee concerns program, self-assessment programs, NRC reportability,operability determination process, and system health report program.2.A list of all condition reports initiated (at least) since June, 2004 (corresponding toperformance of last PI&R inspection). Also, provide a list of all condition reports specifically for the following risk significant systems initiated since June, 2004. Thesystems include: Emergency Diesel Generators (EDGs) and diesel fuel tanks;emergency and auxiliary feedwater; and decay heat removal and decay heat sea water.
Ensure these lists include a brief description of the problem and the classification.3.A listing of all condition report documents associated with LERs, Cited and Non-CitedNRC violations, NRC inspection report findings, issued since June 2004.4.Corrective action program statistics such as the number initiated by department,backlogs, human performance errors by department, and others as may be available.5.A list of industry operating experience documents entered into the "industry operatingexperience program" (i.e., NRC Bulletins, NRC Generic Letters, NRC RISE, NRCInformation Notices, Part 21 reports, and vendor information letters and information from other sites etc. affecting the risk significant systems listed in Item #2 above).6.Copy of all Corporate Nuclear Safety Review Board (CNSRB) and Plant Nuclear SafetyCommittee (PNSC) meeting minutes/documents issued since June 2004.7.A list of all Employee Concern Program items received since June 2004.
8.A copy of System Health Reports issued since June 2004.
9.A list of systems which are or have been classified as (a) (1) in accordance with theMaintenance Rule since June 2004. Include applicable procedures for classifying systems or components as (a) (1), date and reason for being placed in (a) (1), andactions completed and current status.10.Provide a list of Maintenance Preventable Functional Failures since June 2004. Includeactions completed and current status.11.Provide a list of all maintenance work requests generated on the systems discussed inItem #2. Include at least a general description to reasonably determine what maintenance problem involved12.A list of Temporary Modifications and instrument calibration failure reports for thesystems annotated in Item #2.
A-3AttachmentLIST OF DOCUMENTS REVIEWEDProceduresAI-1701, System Engineering StandardsADM-NGGC-0006, Online EEOS models for risk assessment REG-NGGC-0001, Employee concerns program CAP-NGGC-0201, Self-assessment program CAP-NGGC-0200, Corrective action program CAP_NGGC-0202, Operating experience program ADM-NGGC-0101, Maintenance rule program CP-153B, Monitoring the performance of systems structures and components undermaintenance rule CAP-NGGC-0205, Significant adverse condition investigations CAP-NGGC-0206, Corrective Action Program Trending and Analysis MP-402C, Maintenance of Limitorque SMB -0-4 OPS-NGGC-1305, Operability DeterminationsAI-500, Conduct of Operations Department Organization and Administration PM-275, General Preventive Maintenance Work ADM-NGGC-0107,Equipment Reliability Process GuidelinePM-275, General Preventative Maintenance Work, Rev. 20 SP-5206, Rev. 8, CR-3 Piping Specification, Specification for Progress Energy, Crystal River Unit 3PNSC Minutes2004-40, 2005-12, 2005-24, 2005-27, 2005-42, 2006-04, 2006-05, 2006-06, 2006-07, 2006-08,2006-09, 2006-11NCRs priority 1 108023, 110023, 122486,123632, 125149,136752,136888,149509,152651, 152691, 154522,169029, 174440, 174428,175491,175996, 177191, 178612, 179131, 183114NCRs priority 2 113185, 122648, 126195, 127002, 127520, 127521, 129933, 130384, 130666, 130907, 131530, 131567, 132238, 133077, 133187, 133275, 133510, 133687, 134171, 135232, 135606, 135833, 135834, 135836, 135880, 136018, 136305,136336, 136397, 136583, 136773, 136908, 137086, 138035, 139269, 140914, 141890, 143450, 143484, 145881, 146127, 146166, 146865, 148225, 148764, 149219, 149380, 149426, 149507, 151818, 154024, 154651, 155599, 155682, 155892, 156573, 156649, 156692, 157144, 157172, 159013, 159522, 159552, 159694, 159784, 160188, 160449, 162292, 164021, 165025, 166376, 167426, 167646, 169752, 170139, 171501, 171986, 173501, 173747, 174467, 175040, 175072, 175082, 175240, 175291, 175559, 175926, 175987, 176598, 178271, 178313, 179127, 188885, 188942, 190038, 190142, 190986, 195121 A-4AttachmentNRCs priority 3 167513, 168541, 169932, 171745, 174497, 175671, 175674, 176265, 176428, 176429, 176606, 178313, 184715, 185181, 187714, 190333 NCRs priority 5 144642, 155884, 163727, 188906, Rejected/Cancelled NCRs (June 2004-June 2006)Work Orders 14148, 149038, 152042, 160191, 160832, 173543, 180377, 187594, 189277, 211609, 213772, 216659, 217051, 217052, 217792, 220939, 225688, 228636 ReportsList of Main Control Board Deficiencies/DiscrepanciesSite CAP Rollup & Trend Analysis - 1 st Quarter 2006Self Evaluation CAP Program Status Report - NCR data (J une 8, 2006)Chemistry CAP Rollup & trend analysis - 1 st Quarter 2006Radiation Protection - Rollup & trend analysis - 1 st Quarter 2006Maintenance - Rollup & trend analysis - 1 st Quarter 2006Engineering - Rollup & trend analysis - 1 st Quarter 2006Crystal River Self Evaluation Monthly Indicators - March 2006 Nuclear Assessment Section Self Evaluation Report (C-SE-04-01) dated February 9, 2005.
Self Assessment of the Corrective Action Program and Operating Experience Program conducted March 13-17, 2006.
Self Assessment of the Corrective Action Program conducted February 16-20, 2004.
Corporate CR seven day database dated 6/13/2006 System Health Report (EFW)
Equipment Performance Priority List dated 6/8/2006 Self-Assessment 87180: Engineering Trending and Monitoring dated 7/21/2003 Self-Assessment 143581: Cross-Functional Self-Assessment of the OE Program and Select SOER Recommendations dated 3/24/2005-9/30/2005Nuclear Assurance Assessment AR 15292 of System Health Status dated 2/2005 System Health Report, January to June, 2005, Decay Heat Closed Cycle Cooling (DC) and Domestic Water (DO) System BACC Program Health Report, January, 2006 Operating experience items (screened documents reviewed)
104270, 121708, 122987, 124998, 128756, 132054, 136923, 137310, 138667, 144516, 146650, 148845, 149148, 151255, 151458, 155028, 155052, 157457, 160623, 162949, 165080, 167520, 168350, 168361,168380, 170814, 170822, 175716, 175191 A-5AttachmentNon-cited Violations, Findings, and LERsNCV50-302/2004-04-01Failure to Follow Procedure in 10 CFR 50.59 ScreeningNCV50-302/2004-05-01Failure to investigate deficient condition of boric acid leakageaffecting the low pressure injection system as required by boricacid corrosion control procedure.NCV 50-302/2004-05-02Failure to establish adequate corrective actions for fire brigaderesponse results in a recurrent problem.NCV50-302/2004-05-03Redundant channels of a post accident monitoring function notoperable due to reversed power supplies.NCV50-302/2005-03-01Failure to establish appropriate quantitative acceptance criteria toassure Crystal River 3 Technical Specification 3.8.1 operability ofthe offsite power supply.NCV50-302/2005-03-02Failure to properly evaluate and correct emergency dieselgenerator loss of fuel oil header prime condition caused by leakage past the fuel header check valves.NCV50-302/2005-04-01Failure to properly assess and correct condition of water in the 1Adiesel fuel tank.FIN50-302/2005-05-01Inadequate procedure guidance resulted in a loss of condensateflow and a reactor trip.NCV50-302/2005-09-01Failure to conduct adequate corrective action during review ofSteam Generator Inspection results during R12 refueling outage inspection.NCV50-302/2005-09-02Complete and accuracy of information provided to the NRCconcerning steam generator inspection results.LER50-302/2004-001Reactor Trip By Failed Circuit Card Board in the Main FeedwaterIntegrated Control System.LER 50-302/2004-002Emergency Diesel Generator Inoperable Due to Fuel Oil HeaderOutlet Check Valve Leaking Past Seat.LER50-302/2004-003Reactor Trip and Emergency Feedwater Actuation Caused by 230Kilovolt Switchyard/Transmission Faults.LER50-302/2005-001Design Change Creates Engineered Safeguards Bus ProtectiveRelay Scheme Single Failure Vulnerability.
A-6AttachmentLER50-302/2005-002Emergency Diesel Generator Inoperable Due to Fuel Oil Header Check Valve Leaking Past Their Seats.LER50-302/2005-003Manual Reactor Trip and Subsequent Emergency FeedwaterActuation Due to Condensate Pump Loss.LER50-302/2005-004Motor-Operated Feedwater Isolation Valve Inoperable Due toMotor Rotor Oxidation/corrosion.LER50-302/2005-005Inadvertent B Train Engineered Safeguards Actuation Due toInadequate Procedures. NCRs Initiated during CR-3 NRC PI&R Inspection196712, Newly Initiated NCR daily summary report improvement (Cancel and Reject)
196742, NRC PI&R MOV Motor Pinion Orientation may not be correct196848, MRG-1 (EGDG Inlet Structure) Flap Position 196916, Unsecured ladder
197154, NRC PI&R Inspection: Corrective Action Inappropriately Closed (CORR to PMR)
197704, NRC PI&R Inspection Observation: SWV-10 Banging on Backstop197887, Disable Annunciator not labeled per AI-500 197916, Some NCRs are given a cancelled status inappropriately198289, Potential Finding