ML20244D967
ML20244D967 | |
Person / Time | |
---|---|
Site: | Crystal River |
Issue date: | 05/26/1989 |
From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
To: | Wilgus W FLORIDA POWER CORP. |
References | |
NUDOCS 8906200085 | |
Download: ML20244D967 (28) | |
See also: IR 05000302/1988035
Text
._
_- ,
,
., -o_,
V [,
'
. May 26, 1989 /
Docket No. 50-302
License No. DPR-72
Florida Power Corporation
Mr. W. S. Wilgus, Vice President,
Nuclear Operations
ATTN: Managar, Nuclear Operations Licensing
P. O. Box 219-NA-21
Crystal River, FL 32629
Gentlemen:
SUBJECT: SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
REPORT N0. 50-302/88-35
This refers to the NRC's Systematic Assessment of Licensee Performance (SALP)
for your Crystal River facility which was sent to you on March 27, 1989; our
meeting of April 5,1989, at which we discussed the report; and your written
comments dated May 5, 1989.
We appreciate .your efforts in evaluating the SALP report and providing
corrections and clarification to the Interim Report. I have enclosed a
summary of our presentation meeting, a copy of your written comments, a copy
of the slides which were used at the presentation, an errata sheet which
provides the basis for changes to the Interim SALP and the Final SALP report
for the period September 1, 1987 - December 31, 1988.
In accordance wits Section 2.790 of the NRC's " Rules of Practice," Part 2,
Title 10, Code of Federal Regulations, a copy of this letter with the
referenced enclosures will be placed in the NRC's Public Document Room.
No reply to this letter is required; however, should you have any questions
concerning these matters, I will be pleased to discuss them with you.
Sincerely,
Original Signed by
Charles W. Hehl /for
Stewart D. Ebneter
Regional Administrator
Enclosures: (See page 2)
,
'
89062000ss e90526 d /
ADOCK 0300
'
2
{DR
__ __ __ ??$ L
, - _ - - - _ - _ _
.. , . ,_
%
,.
F16rida Power Corporation 2
May 26,19857
l
l
l Enclosures:
1. SALP Presentation Meeting Summary
2. Written Comments Received from
Licensee
3. Copy of SALP Presentation Slides
,
4. Final SALP Report Errata Sheet
'
5. Final SALP Report as Revised
i
from Interim Report
cc w/encls:
G. L. Boldt, Vice President,
Nuclear Production
A. H. Stephens, General Counsel
R. C. Widell, Director, Nuclear
Operations Site Support
P. F. McKee, Director, Nuclear
Plant Operations
State of Florida
bcc w/encls:
NRC Resident Inspector
Document Control Desk
l
RII R RII RII RII
d ,k #
8772 C-- /7 es[- //
KPoertner Rdr jak PF*ed ickson ibson DCollins L
05/af/89 0 /89 05/jgs9 05g(,/89 05/Zl/89 05/>[/89
RII
MErnst
05/ /89
. _ - _ _ _ _ _ _ _ _ - _ - _ -
_ _ _ _ _ _ _ _ - _ - _ - _ _ . _ _ _ _ ._ _. _
__,
..a,
-
t. ..
,
'
L May'26. 1989
-
g
.
ENCLOSURE'1
. A. A meeting was held on April 5,1989, at the Crystal River site to discuss
the SALP report for the period September 1,.1987 - December 31, 1988.
B. Licensee Attendees
FPC'
B. Griffin Executive Vice President
W.'Wilgus Vice President, Nuclear Operations
G. Boldt, Vice President, Nuclear Production.
B. Simpson, Director, Nuclear Engineering
R. Widell, Director, Nuclear Operations Site Support
J. Alberdi, Manager, Nuclear Plant Technical Support
l K.- Baker, Manager, Nuclear Engineering Assurance
- G. Becker, Manager, Site Nuclear Engineering Services
,
J. Brandely, . Manager, Nuclear Integrated Planning
!
B. Hickle, Manager, Nuclear Plant Operations
K. Lancaster, Manager, Site Nuclear Quality Assurance
l
P. McKee, Director Nuclear Plant Operations
V. Roppel, Manager, Nuclear Operations Maintenance
W. Rossfeld, Manager, Nuclear Compliance
C. NRC Attendees
-
S. D. Ebneter, Regional Administrator, Region II (RII)
A. F. Gibson, Director, Division of Reactor Safety. RII
H. N. Berkow, Director, Project Directorate 11-2, NRR
R. V. Crienjak, Chief, Section 2B, Division of Reactor Projects, RII
P. Holmes-Ray; Senior-Resident, Crystal River
J. Tedrow, Resident Inspector, Crystal River
H. Silver, Project Manager, NRR
_-___-______ -__ _ _ _ _ _ __ -
)
., . ., ENCLOSURE 3
.
'
~
EXITED STATES
XECLEAR REGELATORY
@
COMMISSIOX
SYSTEMATIC ASSESSMEXT
OF
LICEXSEE PERFORMANCE
G
'SA _Pj'
d
-- - - - - - - ----- --- --- --------- - -- -- -
.. ..
.
.
~
'
FLORIDA POWER t
i
CORPORATION
i
SE3TEMBER 1, ' 987 .irougl DECEMBER 31, 1988
.
CRYSTAL RIVER
A3RIL 5, ' 989
.
CRYSTAL RIVER, ILOR JA
- _ _ - _ _ _
- - - - - - - - - - - - - - _ - - _ - - - - - - _ -
'
'
.
-
-
1
.
SALP PROGRAM OBJECTIVES
1. JEsTY ~REs)S \ _CENS E 3ER20RVA\C-
.
_
2. 310V JE A 3AS S 20.R A__0CA"0\'
Or s RC RESOURCES
c 3. V3 ROVE N RC REGUXORY. 3ROGRAV
- - - --- - - _ ---- _ --------
.. ..
.
t
.
l
l'
l
V
R V S CLNS
4
_ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - - - -
,
... .
.
,
a.
'
'
mas 0R C 'ANGES "0 "4E
SALP 'R0 GRAM CONSIS" 0F...
- Redefinition of functional Areas
- Reduction in Number of Separate
Functional Areas
- Two--New functional Areas
- Engineering / Technical Ssupport
- Safety Assessment /Quality Verification
- Attributes Addressing Fuman Performance
and Self- Assessment
- Emphasis on Analysis
-- _
1
.. ..
'
.
'
PERFORMANCE AXALYSIS AREAS !
L
FOR OPERATING REACTORS i
.
1. PLANT OPERATIONS
.
2. RADIOLOGICAL CONTROLS
3. MAINTENANCE / SURVEILLANCE
5. SECURITY
6. ENGINEERING / TECHNICAL SUPPORT
7. SAFETY ASSESSMENT / QUALITY VERIFICATION
\
---
+. ..
a
-
.
.
.
- Expanded discuss"on nient
Redefinit"on of the categories to clarify
the"r meaning
- - - - - -
- --- - -
..
-
..
,
.
'
'
AREA PERFORMANCE
CATEGORY 1
LICENSEE MANAGEMENT ATTENTION AND INVOLVEMEN
ARE READILY EVIDENT AND PLACE EMPHASIS ON SU
.
PERFORMANCE-0F NUCLEAR-SAFET(-0R-SAFECUARDS r-
ACTMTIES WITH THE RESULTING PERFORMANCE SUB -
STANTIALLY EXCEEDING REGULATORY REQUIREMENTS.
LICENSEE RESOURCES ARE AMPLE AND EFFECTIVELY U
S0 THAT A HIGH LEVEL OF PLANT AND PERSONNEL
PERFORMANCE IS BEING ACHIEVED. REDUCED NRC ATT
MAY BE APPROPRIATE.
.
_ _ _ . _ _ _ _ _ _ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
.. . .
,
e
~
'
AREA PERFORMANCE
1
CMEGORY2
UCENSEE MANAGEMENT ATTENTION TO AND INVOLVEMENT
IN THE PERFORMANCE OF NUCLEAR SAFETY OR SAFEGUA
ACTMTIES. ARE GOOD. JHE .UCENSEE HAS ATTAINED-A-- - -
LEVEL 0F PERFORMANCE AB0VE THAT NEEDED TO MEET
REGULATORY REQUIREMENTS. UCENSEE RESOURCES ARE
ADEQUATE AND REASONABLY ALLOCATED S0 THAT GOOD P
AND PERSONNEL PERFORMANCE IS BEING ACHIEVED. NRC
ATTENTION MAY BE MAINTAINED AT NORMAL LEVELS.
.
_ . _ _ _ _ - . _ . _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ -
--
.. ..
,
-
-
. .
'
AREA PERFORMANCE
CHEGORY J
UCENSEE MANAGEMENT ATTENTION TO AND INVOLVEMENT
IN THE PERFORMANCE OF NUCLEAR SAFETY OR SAFEGUARD
ACTMTIES ARE NOT SUFFICIENT. THE UCENSEE'S
PERFORMANCE DOES NOT SIGNIFICANTLY EXCEED THAT NEED
TO MEET MINIMAL REGULATORY REQUIREMENTS. UCENSEE
RESOURCES APPEAR TO BE STRAINED OR NOT EFFECTIVELY
USED. NRC ATTENTION SHOULD BE INCREASED AB0VE NORMA
LEVELS.
.
. _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . .
, _
. . . .
e
'
i
-
.
V C E C s ~S.JMMAR.Y
' SEPTEMBER '1,1987 through DECEMBER 31, 1988
. l ll Ill IV V
.. . - . . . - - . _ . - . . - .
.
CRYSTAL RIVER 0 0 2 22 4
.
. . .. .
. . .
REGION ll AVE. 0 0 1 17 4
.
~
- .
PER UNIT
-
.
,.,,s. -
'
- *
. .,
..,,,, . , , . , ',
'
l
1
_ , _ _ _ _ _ _ _ - _ - _ - - - - - - - - - - - -
- - - - - -
. .. . ..
.
0PERATIONS PHASE VIOLATIONS /0PERATING REA
SEPTEMBER 1,1987 through DECEMBER 31, 1988
LEGEND
3.. R 11 AVE
CRYSTAL RIVER!
""
UTIUTIES
2s -
g ,
"
!
- -.
.
. _ _ _
__ _
. _ ... ._
l
, , ..
c
'
j io .
-
-
5" -
g.- -a w - - a
-
4
CRYS Rll AV CPL VEP SERI '
UTILIT(
-__-
-- - _ - _
.. . . .
2 :0
-
33s :?:33
SEPTEMBER 1,1987 through DECEMBER 31,1988
LEGEND
3. 3 b NAT' LAVE.
CRYSTAL RIVER
30'
PLANT TYPE
, 2, .
5
n
E,,. _: __ r _.
- - - -
-
18
!is-
10-
5-
3 A\~~ ~Y3E
_
l
_______ ___-__-__- - ___- _ _ _ _ -
__
.. ..
'
CRYSTAL RIVER LERs
'
.
(?_.AN1
SEPTEMBER 1,1987 through DECEMBER 31, 1988
.
.
'
PERSONNEL *-
54.5%
.
9
OTHER 6.1%
9.1%
30.3%
COMP. FAILURE
DESIGN /CONST.
1
_ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ . _ _ _ _ _
____ ___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ .
... . .
b
~
-
CRYSTAL RIVER LERS
'
(PERSO 4NEL)
SEPTEMBER 1,1987 through DECEMBER 31, 1988
i
TEST /CAUB.
'
16.7%
MAINTENANCE
22.2%
___._.-_;..--
OTHER 5.6%
OPERATIONS
55.6%
_ _ _ _ _ _ _ _ _ _ ______________ _ - _ _
.. ..
2
'. '
TJNCTONA_ AREA COV?AR SON -
70R REG.ON
'
1
7AC_~ES
CYC_E V
14 -
n
LEGEND
CATEGORY 1
b CATEGOR
-
,,
bk CATEGOR
0 ,
89 -
,_ -
'
-
gl*- _
.
--
LO . \
\
-
,
g. .
-
<--
\ \ -
2" .
t
i
)
.
\
\ \
'
0- .
'
'
.
. . . .
RAD CON SUIN FIRE PROT
FUNCTIONAL AREA
l - - - - - - - - - - - -
_
4 * . .
3
.
.
.\C:~ 0\ A_ AEA COM?ARSO\
.
.
7
.
01 REG.0 \ rAC _T~ ES
CYCLE V
! ""
LEGEND
l
'
/ EM CATEGOR
-
f/ : :- I// CATEGOR
,,
$N CATEGOR
0
gg ,
-
.
- **
"
25 ' / / :
!! 'f, / f
.,. ,/
Z
/f
/ / / *
~
f f //
- // / / 7 f ,
/8 /
/ / / /j/
/ / -
' - % L L lb il 4
~
e&e e e s.
.
-
FUNCTIONAL AREA
_ _ - _ - - - _ - - - - - - - - - -
,
_ - _ - . __- _ ___ __ ___ __ . _ - _ _ __ ._ _ - _ _
.~ . .
.
-
l .
.
h
PLANT OPERATIONS - CATEGORY 2
PLANT. GENERALLY OPERATED IN A CONSERVATIVE MANNER
'
SATISFACTORY CONTROL 0F PLANT OPERATIONS
IMPROVED OPERATIONS STAFFING
.
ADEQUATE PROCEDURAL ADHERENCE
'
IMPROVED PROFESSIONALISM IN CONTROL ROOM
ADEQUATE IMPLEMENTATION OF FIRE PROTECTION PROGRAM
,
1
l
__ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . . _ _ _ _ _ _ _ . _ . _ _ . _ _ _ _
_ __ _ _ _ _ _ _ _ - _ _ _ _ _
w. . - ,, . ,
.
'
.
4
.
RADIOLOGICAL CONTROLS - CATEGORY 2
THREE -YEAR- AVERAGE COLLECTIVE DOSE (1986-88) SLIGHTLY
-BELOW INDUSTRY AVERAGE
,
CONTINUED REDUCTION IN SIZE OF CONTAMINATED AREAS
-
-
NUMBER OF PERSONNEL CONTAMINATION WAS LOW IN 1987 .AND
1988
-'
RADI0 ACTIVE EFFLUENTS WERE WITHIN TECHNICAL
SPECIFICATIONS LIMITS
'
STRONG MANAGEMENT SUPPORT AND INVOLVEMENT
,
,
b
___________.__m. - - - - - -
_ - _ _ _ _
. _ - _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
.. -. . ;
'
-
l
. i
.
' MAINTENANCE / SURVEILLANCE - CATEGORY 2
,
MAINTENANCE CONTINUES TO BE A STRENGTH
CONTINUING TO ENHANCE TRENDING 0F EQUIPMENT FAILURES
'
USE OF M0CKUPS
ADEQUATE CONTROL OF MAINTENANCE ACTIVITIES
IMPROVED OUTAGE CONTROL AND PLANNING
IMPROVED CORROSION CONTROL
MISTAKES DURING MAINTENANCE AND SURVEILLANCE ACTIVITIES
l
CAUSED ESF ACTUATION
WEAKNESSES IN IST FOR CHECK VALVES
'
.
IMPROVED SURVEILLANCE SCHEDULING
L____.____ - - - - -
<.
.
!d ' . .
'
.
.
i
EMERGENCY PREPAREDNESS - CATEGORY 2
IMPROVED PERFORMANCE DURING 1987 REMEDIAL- DRILL
SATISFACTORY PERFORMANCE DURING JUNE 1988 DRILL
SATISFACTORY CAPABILITY CONFIRMED BY JULY 1988 ROUTINE
INSPECTION-
i
.
- - - - _ _ _ _ _ _ - - _ _ _ - _ _ - - - - - _ - _
___ ___ -____ - _
[. g. , ,
.
.4
(
,
SECURITY - CATEGORY 1
-
EFFECTIVE PERFORMANCE DURING CONTINGENCY DRILLS
.
EFFECTIVE TRAINING FROGRAM
.
SECURITY PLAN WELL MAINTAINED
SECURITY EFFECTIVE IN IDENTIFYING FIREARM INTRUSIONS
CORPORATE AND SITE MANAGEMENT SUPPORT SECURITY
_ _ _ _ _ _ _ - _ - _ _
___ _ _ _ _
. ..
'
.
.
ENGINEERING / TECHNICAL SUPPORT - CATEGORY 3
ENGINEERING CALCULATIONS DID NOT CONSISTENTLY IDENTIFY
ASSUMPTIONS AND DESIGN INPUTS
INADEQUATE CONSIDERATION OF EQ
PRIORITIZATION OF WORK NEEDED IMPROVEMENT
FAILURE TO TRANSLATE DESIGN BASES INTO TEST AND
OPERATING PROCEDURES
CONFIGURATION MANAGEMENT PROGRAM STRENGTHENED TO MORE
EFFECTIVELY CONTROL DESIGN CHANGES
1
' *
SYSTEM ENGINEER PROGRAM HAS BEEN ESTABLISHED
SIZE OF THE ENGINEERING STAFF INCREASED
.
TRAINING 0F ENGINEERS STRENGTHENED
_ _ - _ - _ _ _
_ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _
v. ..
.
. . .
'
. . .
.
SAFETY ASSESSMENT / QUALITY VERIFICATION - CATEGORY-2
.
'-
!
QA' AUDITS WERE PERFORMANCE BASED
CORRECTIVE ACTIONS NOT ADEQUATE
PARTICIPATION IN PRC MEETINGS WEAK
LACK 0F INTERDEPARTMENTAL COOPERATION
.
SATISFACTORY ROOT CAUSE ANALYSES
INCONSISTENT PERFORMANCE ON LICENSING ACTIONS
GOOD RESPONSE TO GENERIC ISSUES
4
SATISFACTORY QUALITY AND TIMELINESS OF LERS
,
W
. - _ _ . - - - _ _ _ _ - - - - _ - _ - - _ _ _ - - _ _ _ _ - _ _ . _ _ _ _ _ - - - _ - - _ . _ - -
__ _ - - - - _
,v <
..a . .
[ .' e
W ~
. .
May 26, 1989
ENCLOSURE 4
'
ERRATA SHEET
Page Line Interim Report Reads Final Report Now Reads-
[ 24 29-30 ... unfamiliarity with ... unfamiliarity with
the E0Ps .... the Verification
Procedures....
"
Basis: Revised to clarify the procedures that the 50TA's were found to
exhibit unfamiliarity with.
-27 22-31 Only after this extended After reinforcement ....
period of. disagreement and the ATWS rule the
after reinforcement .... licensee exhibited a
the ATWS rule did the very cooperative
licensee exhibit a attitude. 'The licensee.
cooperative attitude. .The .... a design ....
licensee .... a conceptual Another example of good
design .... Another example responsiveness after.
of belated good responsive- extended discussion ....
ness ....
Basis: Revised to more accurately describe,the licensee's actions with
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - -
. , _ - _ - _ _ _ _ _ _ _ _ ._ . _ -
. , 1
e
'. /* *
ENCLOSURE 2
l
j
,
.
...
.
i ) ,,
> g . . . o,,
.
8
PI; q
-
Power
COR POR ATION
May 05, 1989
Mr. Stewart D. Ebneter
Regional Administrator, Region II
U. S. Nuclear Regulatory rw einnion
101 Marietta St. N. W., Suite 3100
Atlanta, GA 30323
Subject: Crystal River Unit 3
Docket No. 50-302
Operating Licensee No. DPR-72
Systematic Awcment of Licensee Ibrformance (SAIP)
Inspection Report 88-35
.
. . . . . .
Dear Sir:
Florida Power Corporation (FEC) is dedicated to the safe operation of Crystal
River Unit 3 and to maintaining a strong safety culture throughout our
organization. FPC appreciates the significance of the SALP process and
respects the criticism provided. We are also pleased that the areas of
inproved performance and continued good performance were recognized. Our
overall performance was rated as satisfactory; however, we are ocenitted to
etntinually striving to inprove our performance and to resolving the concerns
with tectinical support and supervisory review.
FPC has focused considerable attention to the engineerirxy area. We
recognized problens existed and had wuwt.ive actions un$erway or planned
prior to the SAIP report. 'Ibe ratiry in this area was not unexpected.
Internally reca;nized weaknesses, confirmed by the Operational Safety 'Ibam
Inspection (OSTI) and other inspections clearly iniicated a need to perform
an awc:mant of the tactinical support area. 'Ihis amert has resulted in
additional efforts to strengthen specific areas through redirected and
achiitional resources. Major areas in the engineering organization have been
realigned and inproved definiticn of the roles and responsibilities within
those areas are being develcped. We are also re-enghasizirg "feam" concepts
I throupiout Nuclear Operations.
,
t! . ' .1 ") f f I
[C . ( }e n+3#
.,
POST OFFICE BOX 219 * CRYSTAL RIVER. FLORIDA 326294219 * (904) 563-2943
A Florida Progress Company
_ - _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - - - -
_ _ _ _ _ _ - _ _ - _ _ - -
.
'
.. ;. .
.
'
-
-
Mr. Stewart D. Ibneter
Regional Administrator, Region II
U. S. Nuclear Regulatory hinaian
3FT)589-05 - May 5,1989
Page 2
Mr. B. L. Griffin, Executive Vice President, stated at the SAIP meeting that
FPC is ocanitted to striving for higher ratings. We are actively performing
asseaamants in eads of the SAIP functional areas to identify and correct
weakrwaaan
performance.
and to identify and pursue wrtunities to further enhance our
We consider periodic self amaaaamant essential to assurirg the
drive for impIUved performance is not lost and does not stagnate. We are
taking positive steps in eads area that will help us adlieve performance
improvements. We recognize open, professional n =mutication with the NRC as
another element in our ongoing efforts to adileve high levels of performance.
We feel cand.Jerable improvement has been made throughout the past SALP
cvaluation period, arxl we look forward to a continuation of this good
ocumInication in the future.
Florida Power Corporation's detailed response to the Category 3 area is
provided in Attadunent A.
provided in Attadiment B. C=.utus on the reainder of the evaluation are
you in the near future. We look forward to dianwrcing our progress with
Sincerely,
-
k rush - -
Walter S. 11gus
Vice President
Nuclear Operations
R3W/sdw
Attadunent
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - _
__- __ _ _ _ - _ - -_ _ - _ _ _ _ _ _ - - _ _ _ _ _ - _ _ _ _ - _ _ - - _ _ - _ _ _ - _ . - _ _ - _ _ - _ _ _ _ - . . _
.
,,
- ,; ; .- .
.,
'-
. .
.
mg
REERMSE '10 QGEIRY 3 RNFING
F. Drrin==rirmmaremir=1 9====t
,
FPC management recognizes the engineering organization is not adieving a
hiW1 level of quality performance an a consistent basis. Several programs
and initiatives to improve performance have been under develve-A.. These
include the Configuration Management Pregam, Engineering Assurance, Design
Basis Issue Resolution and System Engineering.' Extensive resource
crnanitments have been made to these programs and they are beginning to'
pro &aos results. , Roosnt faadhar* from the industry and through the.SMP
have demonstrated the need to' go further and to amaa== the role of-
engineering in the support of Crystal River Unit 3.. ' mis assessment has
resulted . in establishing a Design Basis Issue Rasolution Project Team,
initiating.a review of the Envitu miumi Qualification .Prupam, an1
establishing a program to set the expectations and respcrisibilities for the
Systens Engineers.
'Iha Configuration Man , _ d. Prupam is underway to capture, I=usid.ruct
'and document the design basis of the plant. ' mis program is established as
.a separate organization with dedicated FPC supervision.. ' mis group is not
effected by the ' design activities or day-to-day sqport of the plant. The
objective of. this rogam is to dmanaric the design basis- information
provide the infonnation in a raadily retrievable format to those who.need
it, assure the physical plant conforms to the design basis, and to assure
the plant r - tnas ocnform to the design basis.
~
Nuclear Operations Engineering (NDE)' has primary responsibility for' the *
resolution of design related questions and the design of plant
modifications. NOE controls the, design / modification prmaan and is -
accountable for design input and assuring the design solution resolves the
problem effectively. They are also arvvunitable to assure modifications are
fully? implemented and ~ tested in au dar = with the design including
rig- two &anges, drawing revisions, and transfer of the final quality
records to file.
Site Nuclear Engineering Services (SNES) provides the day-to-day technical
angport to the plant. ' mis function includes the System Engineer Pregam,
Procurement . Engineering, and discipline engineering support for
modifications, te&nical problems, the Manctional Test Prupam, Post
Maintenance Test Prupam, and the ASME Section XI Repair and Replacement
Pru am. Site Nuclear Services plays an important role in the operation of -
CR-3 and is intimately involved in all critical decisions of a tednical
nature.
'Ihe Design Basis Issue Resolution Project Team has been recently
established. The function of this team is to deal with design basis iamma
that ocune tp in any area. The team is W of dedicated, disciplined
engineers, a licensing engineer, and a safety analysis engineer. 'Ihe team
will reonive potential design basis l a= == and be responsible for the
initial assessment of safety significance, the preliminary evaluation for
b:en. Lability, reocenending any rmadad changes in operational mode, and
sufficientresolution.
ultimate tednical review of the i=== to determine alternatives for the
.
___m__m____ _ _ _ _ _ _ _ _ _ . _ _ . _ . _ _ _ . . _ _ _ .
.. _ _. - - - . - . _- -
.
.,[*;, ' .'
- , -,
'
.
, -- F. ; 'r irwun- - ir=1 a---- U (C a.'d)
Structuring the engineering support in'this manner will ptwide effective 3
tactinical s@ port and contribute to enhanced interaction with the ' plant
e organizations.- The acticos taken demcmstrate rwp--it's intention to
resolve the problems in this area. '
FPC intends to arrange a meeting with the NRC in June 1989 to diacu== the'
details .of our programs and the role of Engineering at CR-3.
The Training area continues to asunr=1 strate a ' hiWi level of performance
whicts will be' further enhanced by the simlator whicts will be operational
in 1990.
<
2he SALP Report irwuactly references. Som problems with E0P's. The
identified problem was with VP's (VP-540 and BP-580).
Nuclear Operations Training was not required to ruegini to a concern in NRC-
,
Report 50-302/88-09 where a reference was nede to indication .of
insufficient training for SOIA's regarding VP-540 -and VP-580. However,
!
Nuclear Operations Training evaluates all training deficiencies and, in
this case, the following actions were taken:
1. All Som's were evaluated on shift by a qualified'NSS or ANSS.
2. Training walk-throughs ~ an VP-540 and VP-580 were given to all
SOM's.
3. Tasuenri. Plans. covering _these VP!s were added-to-the-initial ,90m--
cxtrricultan.- --- -
- - ~
4. An actual walk-through was addad to the som Job 1%rformance Manual.
These actions were ocmpleted in ot+rhr of 1988.
4
- - - . _ _ _ . . _ _---.-.n__ .---
_ - . _ _ _ - _ _ _ _ _ _ _ _ _ _ _
.
.. . . . .
,
,
'
,-
,
,
i
L.
l' Overall Evaluatim
Florida Power Cuiputatica (FPC) is in general agreement with the overall SAIP
' ratings. FPC also~ appreciates the recognition by the NRC that. many
initiatives are underway to improve overall perfomance and to correct the
weaknesses identified. FPC .is firmly ev=nitted to developing cxxisistently
high quality performance in all areas . and with identifying and resolving
prtblems.in an expeditious manner. '
FPC is. plaaaad that the NRC has noted the impwz .L in n MW adherence
and g Mwal Magwy. - _ FPC has dedicated considerable resources to the
issue and it continues to be an area of sharp man:, _.t focus.
Supervisory responsibility and involvement is an area that FPC also believes
is critical to safe, efficient operations. Tunadiate steps are being taken in
several areas and management evaluation for . langer term improvements is
underway.
A. Plant Operaties
'!he six-shift rotation has' made it possible to rdww overtime and allow an
extra shift on duty during normal working hours. 'this additional
availability of licensed operators has improved work flow throujhaut
Nuclear _ Operations. 'Iha shift team umuayL for operations was also
implemented during~thiis SAIP~isidEiBd.~~Cbntinues iwtw _ .L in operations .
is expected frtan these changes and as the newer operators beame 'more
experienced.
'Ihe operations staff has shown initiative in the development.of operator
professionalism. 'Ibese efforts will continue to be encouraged by
marwynant. _ Efforts are underway to extend these initiatives - and to
enhance the professional envitw===st in which our training is done.
ITC took innadiate steps to resolve the ocncerns with the BDP's identified .
by the BOP innpection. We are also participating with the BfM Owners Group
to address dwgies with tedinical cantant. 'the plant specific
.sindator, W11ch will be operational next year, will contribute
significantly to the verification and validation that can be accomplished
on E0P's.
B. Endiological controls
FPC is plamaad with continuing improvements in this area. As noted,
considerable marwpunant support and involvement has been present.
Improvements in tg ability to safely process personnel in and out of the
Rch have been made. FPC is continuing to identify uw0itanities to inprove
the Radiological Protection Fxvg am and has several actions underway
through the cambined efforts of the Health Physics and Radiological Support
Services departmpets. 'Ihese include coupleticm of the Radiological
Protection Plan, issuing a periodic newsletter an radiaticm protection, and
closer coordination between these depad-da.
.
_ . - __ . _ _ _ . _ _ . . - - _ _ _ _ _ - _ _ . - - - . - - - - _ _ _ . _ _ -
_ _ - _ . - .. - _ _ _ _ . _ _ _ . ______ __-__ _ _ _ - _ _ _ _ - _ - _ _ _ - _ _ _ _ _ - _
.
t ,
'
c :< ' a, .
.,
,1
s
'
..
'
-
B. n.Mn1,we=1 Qxitzn1= La.'d)
A self assessment of the overall . AIARA program is underway. '1his
amaa==arit has been undertaken since wa now have several years expecience
with the program and new guidance has been developed sinos our sur- = was
implemented. '1his is an area where additional grovenant .is actuevable
and ==='M.
A .; , d. attention continues to sephasize plant decontamination.
Unernnemrod amaan to the plant is recognized as a contributor to safe
operation, as well as a means to r*= overall cost.
C. Maintenance / Surveillance
Maintenance
Crystal River Unit. 3.
is critically Important to the safe, reliable operation of
FPC places a . Lug esphasis in this area and is
very pleased with your assessment of our perfonannae. We are continuirq to.
pursue improvements and are currently in the prmaan of a major assessment
of maintenanos. We are considering the maltitude of_ activities, including
engineering, materials, contracts, . quality programs, etc., thati form a
ocuplete,. , overall maintenance program. '!his aammam ant is' hamad on
information frun industry, both <hantic and international, INPO, the NRC,
a:L our internally. developed experience. FPC considers this effort a key
-factor in the future performance of CR-3 and the continued high level!of
performance in maintenance.
- A significant <v=nitment to improving the Surveillance testing performance
was made following the previous SAIP period.: . A large p.=;w ,Unge of the
p -- bnm were rewritten to the approved writers guide format; technical
W=y has been yrgaGed; and the g<-- bres were validated by both the
reepansible engineers and the users. 'Ihe results of these efforts are now
being evaluated to assure the objectives of our. effort have been met.
Additional improvements will be implananted as they are riaaded.
'Ihe implementation of the new 10 year in-service inspection and testing
programs, along with the administrative changes arti staff increases,'will
provide a . Lug foundation for continuing performance inprovenant in this
. area.
.
D. Baettamcy Preparedness
Emergency Preparedness is an area that has shown continued L=.#1. '1he
' deficiencies noted with the last emergency exercise have been corrected.
'Ihe does assessment capability has been improved through incranaad team
sizes, enhanced training, and improved rvemmication.
-
E. Security
.
'Ihe achievement of Category 1 in Security is particularly satisfying
oansidering past performance. 'Ihe efforts to improve the management of
this area have been avv=aaful and improved the recurity effectiveness.
,
Hi@t performance levels will be maintained in this area. Current
managmaant
systems and facilities.
attention is beiny directed to the mananamarit of the security
being developed.
A pupam to tpp.3E systems and ecpiprrent is
It is anticipated this will be a phased gwpam over the
next several years.
'.
.
. -
_ _ _ _ . - - - - - - -- -
.__- _ - _ _
l'
>
- . .. .
'
l
'
,
F. Dnineerim/Tednical 9-ww=t
See At' xhment A.
G. Safety Aaaaanmant/G =1ity Verificaticm
Resources
correctivehave beenga=.
acticri directed toward the nanocnformance identification and
A medensive review has been performed and
a major rework of the pr%imu is urder development. 'Ihis effort will
resolve the acroerns identified and will be inpleented later in this SAIP
period.
Manacfasit emphasis is contiming on procedural adherence. 'Ihe Human
Performance Evaluation Frwimu is expanding and the Safety Training
Observation Pr w sma (SIOP) has been implemented. 'Ihis ptwtan ack!r m e= =
nct only safety issues, but all facets of task performance includirq
w w dares, radiation protection, workmanship, etc.
Extensive Vendor 'Ibchnical Information program enhumsis were completed
at the end of the SAIP period. Efforts are continuing in this area to
further mi.uuidien this program.
A significant ===anent of overall licensirg activity has been taking
place. Efforts to provide more distinct definition of the roles and
responsibilities, as well as the expectations, of the licensing staff will
achieve inproved and more consistent performance. Improved ocannunication
with the NRC at technical and management levels also contributes to
improved performance in this area.
FB::
to beconsiders the m.=rds on' A'IWS and the achiitional source of feedwater
misl=11ng. Although the resolution of these i=== was mutually
agreeable, FPC does not consider the NRC Staff's actions on these issues to
have been timely or responsive. 'Ibere was cruisiderable delay in FPC
receiving an NRC position that clearly identified the specific problems. In
both < a==a, the issues came down to regulatory riiar= fort and not technical
issues. When this was ocamunicated FPC could, and did, aggressively pursue
appropriate resolution.
'Ibe Configuration Manacfasit gwima is currently a mial for the industry.
FPC's approach is to do it right through a med,Eussive, well-planned-out
program. 'Ihe depth and quality of the effort does make the schadule larger
than would be desired. However, nuch of the information and benefit will
be available to the users as the program pr%s . FPC developed this
piwimu internally and is managing the s wima thtu gh dedicated resources.
'Ihis will aaatte mavi== benefit is obtained by the in-house staff.
FPC has made changes in the operation and guirlance for the Plant Review
Omnittee (PRC) . It is noted, however, that the PRC operates under an NRC
approved alternate approach. 'Ihis may ocritribute to the perceived '
weakrmaaa. FPC will review the PRC operation and evaluate uwerwnities
for improvement.
H. Idosisiin Activities
No Ctznent
_____-____-_-__ ___ - - - _
_ - _ - - _ _ - _ _ - - - - - - - - -
-
1, ;
..,;...-...
Fi ,. .
'
, '-
I. Ehfaroummt Activity
No &=nant
J. Reactor Trisas
No ownant
K. Crystal River Iktit 3 Efflust: Dal---- A
-
w
No Ocaments
,
_ _ _ _ _ _ . - . _ - _ _ _ - - - - - - - - - - - - - - -
__ _ _ _ - _ _ . .__ .
'
., -
,.
!
t
-
. May 26, 1989
!
l
I
l
ENCLOSURE 5
FINAL SALP REPORT
U. S. NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
INSPECTION REPORT NUMBER
!iO-302/88-35
FLORIDA POWER CORPORATION
CRYSTAL RIVER UNIT 3
September 1, 1987 - December 31, 1988
l
5+ n, vn, ;- i n i,'7n /,n 7 Ts u, ,lLl) -
-. - - - - _ - - --__
'
1
-
, .,- .
1
.
.
5
TABLE OF CONTENTS
Page
I. INTRODUCTION ............................................... 1
A. Licensee Activities ................................... 2
B. Direct Inspection and Review Activities ............... 2
II. SUMMARY OF RESULTS ......................................... 3
III. CRITERIA ................................................... 4
IV. PERFORMANCE ANALYSIS ....................................... 6
A. Plant Operations ...................................... 6
8. Radiological Controls ................................ 10
C. Maintenance / Surveillance ............................. 13
1
D. Emergency Preparedness ............................... 17 i
E. Securi,ty .......r....................-.. ......r.......... 19
F. Engineering / Technical Support . . . . . . . . . . . . . . . . . . . . . . . . 20
G. Safety Assessment / Quality Verification ............... 25
V. SUPPORTING DATA AND SUMMARIES ............................. 29
A. Investigation Review ................................. 29
B. Escalated Enforcement Action ......................... 30
C. Management Conferences ............................... 30
D. Confirmation of Action Letters ....................... 31
E. Review of Licensee Event Reports . . . . . . . . . . . . . . . . . . . . . 31
F. Licensing Activities ................................. 31
G. E n fo rc eme n t Ac t i v i ty . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2
H. R e a c to r T r i p s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2
1. Ef fl uent Rel ea se Summa ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
I
_ _ _ _ _ _ _ _ _ - _ _ _ _ - - _ _ _
_ _ _ _ _ _ _ _ _ -
-
. .
.
.
.
I. INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect available observations and data on
a periodic basis and to evaluate licensee performance on the basis of this
information. The program is supplemental to normal regulatory processes
used to ensure compliance with NRC rules and regulations. It is intended
to be sufficiently diagnostic to provide a rational basis for allocation
of NRC resources and to provide meaningful feedback to the licensee's
management regarding the NRC's assessment of their facility's performance
in each functional area.
An NRC SALP Board, composed of the staff members listed below, met on
February 23, 1989, to review the observations and data on performance, and
to assess licensee performance in accordance with Chapter NRC-0516,
" Systematic A3sessment of Licensee Performance." The guidance and
evaluation criteria are summarized in Section III of this report. The
Board's findings and recommendations were forwarded to the NRC Regional .
Administrator for approval and issuance. I
This report is the NRC's assessment of the licensee's safety performance
at Crystal River Unit 3 for the period September 1, 1987 through
December 31, 1988.
The SALP Board for Crystal River Unit 3 was composed of:
L. A. Reyes, Director, Reactor Projects Division (DRP), Region II (RII)
(Chairman)
A. F. Gibson, Director, Division of Recctor Safety (DPS), RII
D. M. Collins, Acting Director, Division of Radiation Safety and
Safeguards (DRSS),RII
B. A. Wilson, Chief, Reactor Projects Branch 2, DRP, RII
H. N. Berkow, Director, Project Directorate 11-2, Office of Nuclear
Reactor Regulation (NRR)
P. Holmes-Ray, Senior Resident Inspector, Crystal River, DRP, RII
H. Silver, Project Manager, Project Directorate 11-2, NRR
Attendees at SALP Board Meeting:
R. V. Crienjak, Chief, Project Section 28, DRP, RII
M. S. Lewis, Project Engineer, Project Section 2B, DRP, RII ,
J. E. Tedrow, Resident Inspector, Crystal River, DRP, RII '
P. A. Balmain, Reactor Engineer, Technical Support Staff (TSS), !
DRP, RII '
I
I 1
'
I
I
i
_ _ _ _ - _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _
. - . - -. - - - -. - - - - - - - - - - -
L
p.,,..
L -
1. a ,
-
2
.A. Licensee Activities
This assessment period included a continuous operating record of 216
E days, 'as well as a refueling outage and three short maintenance
outages. The unit sustained two reactor trips, and had an average
capacity factor for 1988 of 80%. This capacity factor compared
favorably to the average B&W capacity factor of 62.5%.
'
Crystal River began this assessment period by achieving criticality
on September 1,1987, following a maintenance outage to repair a.
mechanical seal on a reactor coolant pump. On September 19, 1987, a
plant shutdown was commenced for a scheduled refueling outage.. Major
work included: inspection and maintenance on the emergency diesel
generator (EDG), removal of a pressurizer safety.- valve for
maintenance, replacement of main steam code safety valves, and
replacement of a Nuclear Services Closed Cycle Cooling System pump
discharge valve. On January 8, 1988, followfng the refueling outage.
a reactor startup was commenced and criticality achieved. The
reactor tripped from approximately 55% power on February 28, 1988,
due to high reactor coolant system pressure. A broken stem nut
caused the failure of a main feedwater block valve to close which
caused a feedwater transient and a Reactor Coolant Pressure
transient. The reactor was critical and resumed power operations on
~ March 2, 1988. On March 7,1988, the plant was shut down for a
maintenance outage to perform maintenance on the. main feedwater
system. Power operations resumed on March 8,1988. The plant was
, shut down on October 9, -1988, to replace leaking emergency feedwater
check valves. Criticality was achieved on October 27, 1988; however,
the reactor tripped on October 28, 1988, from 20% power due to
problems with the turbine header pressure controls. Criticality was
achieved on the same day, and power operations resumed. The plant
was shut down for a maintenance outage to investigate and repair
vibration problems with a reactor coolant pomp on December 7,1988.
The plant continued in cold shutdown conditions for the remainder of
this period.
During the assessment period, ten technical specification amendments
were issued, as well as five reliefs and one exemption.
B. Direct Inspection and Review Activities
During the assessment period, routine inspections were performed at
Crystal River Unit 3 by the NRC staff. Special inspections were
conducted as follows:
-
August 24-September 4, 1987; This special Operational Safety
Team Inspection was to monitor operational activities and
operations support interfaces.
-
October 5-9, 1987; This inspection was conducted to review the
licensee's check valve testing program.
-
October 14-16, 1987; This special inspection was conducted to
review the circumstances surrounding the removal of Icad
bricks serving as the access barrier to the reactor cavity
area.
- - _ - - - _ _ -
__- _ _ _ _ _ _ --- - _- _-- ___- __ - _ _ - - -. _- - _-
u- .,
,
W .: *
,
a
l: .. 3
-
October 20-21,.1987;- This reactive inspection was performed to
evaluate the licensee's imple:nentation of its Emergency
Plan when an alert was declared.
- November 30-December 4,.1987; This inspection was-in the_ area of
- emergency ' diesel generator (EDG) loading.
- December _7-17, 1987; This inspection was in the areas ofs
engineering safeguards test witnessing, review of: EDG-load
. testing procedures, and review of. procedures for, flow
balance testing of selected. safety-related components.
- January 5-7, 1988; Tnis 'special inspection was: performed to
review the circumstances surrounding a. radiation worker's
-entry-into a high radiation area.-
- March 28-April 8,1988; This inspection was to review the
adequacy of the. emergency operating procedures.
- November 14-18, 1988; This inspection was conducted to determine
-the cause for higher than industry average collective exposure
in 1983 through 1987.
'
II. SUMMARY OF RESULTS
The Crystal River facility was effectively managed and has achieved a
satisfactory level of operational safety. The licensee continuei to
exhibit a strong maintenance program and has made significant improvement
.in the areas of security and to a lesser degree, radiological controls.
However, weaknes.ses have been identified covering inadequate supervisory
review. in the areas of operations and surveillance. Significant-
weaknesses (inadequate staff / staff training) were noted .in the area of
engineering / technical support.
The weaknesses associated with supervisory review resulted in a lower
overall rating in both the operations and surveillance areas. In.the
operations area, the severity of several events was compounded because of
'
the lack of appropriate safety assessment by responsible supervisors. In
the surveillance area, several failed surveillance were passed as
satisfactory because of inadequate supervisory reviews.
.The licensee's resources in the engineering and technical support staffs
are at minimal levels. This has resulted in several . examples where
requested / required engineering analysis was not timely or not provided at
all. There were examples where engineering lacked insight in prioritizing
work in regards to plant safety. Additionally, engineering does not
appear to be a part of the plant " team", thereby having a negative effect
on inter-departmental cooperation.
As described in the two previous paragraphs, the performance attributes of
both supervisory reviews and engineering sensitivity (i.e., establishing
priorities based on plap safety) have been marginal. These weaknesses
were also noted in most SALP categories. However, because of the
importance of these attributes on overall quality, a significant negative
impact was noted on the area of safety assessment / quality verification.
___-____--________-_-_a
- ..
. .
.
..
,
.
4
A noteworthy improvement has been observed in the security area. As noted
in the previous SALP, there has been a significant effort by the licensee
to improve this area. This effort resulted in increased awareness by all
site personnel and considerable expenditure of money and resources to
improve security. The appointment of a new security supervisor at the end
of the previous SALP period has resulted in providing this area with the
necessary leadership to reach and continue to perform at a high level.
The maintenance area has continued to be a strong performer within the
plant organization. However, surveillance has been added to this area
and, although somewhat improved, it has not progressed to the level of the
maintenance area. Emphasis by the licensee is still required in the
surveillance area to bring it on par with maintenance.
[ April 1, 1986 Through August 31,1987]
Rating Last Trend Last
Functional Area Period Period
Plant Operation 2
Radiological Controls 2
Maintenance 1
Surveillance 3
Fire Protection 1
Emergency Preparedness 2 Improving
Security 2
Outages --
-- . . _ __ 2
Quality Programs and . ..
Administrative Controls
Affecting Quality 2
Licensing Activities 2
Training 2 Improving
[ September 1,1987ThroughDecember 31,1988]
Rating This Trend This
Functional Area Period Period
Plant Operations 2
(operations & fire protection)
Radiological Controls 2
Maintenance / Surveillance 2
l Security 1
l Engineering / Technical Support 3
(engineering, training & outages)
'
Safety Assessment / 2
Quality Verification
(quality programs & licensing)
III. CRITERIA
Licensee performance is assessed in selected functional areas, depending
on whether the facility is in a construction or operational phase.
!
l
l _ - ------___-----__--o
,___ _ _-_ . _ _ _ _-_ __ . _ _ - . - __
_ _ - _ _ _ _ - _ _ - _ _ - _ _ _ _ _ _ _ _ _
.: .
.. .
.
. j
- . 5
Functional areas normally represent areas significant to nuclear safety
and the environment. Some functional areas may not be assessed because of
little or no licensee activities or lack of meaningful observations.
Special areas may be added to highlight significant observations.
The' following evaluation criteria were used, as applicable, to assess each
functional area:
1. Assurance of quality, including management involvement and control;
2. Approach to the resolution of technical issues from a safety
standpoint;
3. Responsiveness to NRC initiatives;
4. Enforcement history;
5.
.
Operational
of, reportingand
of, construction
and corrective events (including)
actions for ; response to, analyses
! 6. Staffing (including. management); and
7. Effectiveness of training and qualification program
However, the NRC is not limited to these criteria and others may have been
used where appropriate.
On the basis of the NRC ' assessment, each functional area evaluated is
rated according to three performance categories. The definitions of these
performance categories are as follows:
1. Category 1. . Licensee management attention and involvement are
readily evident and place emphasis on superior performance-of nuclear ;
safety or safeguards activities, with-the resulting ~ performance
substantially exceeding regulatory requirements. Licensee resources
are ample and effectively used so that a high level of plant and
personnel performance is being achieved. Reduced NRC attention may
be appropriate.
2. Category 2. Licensee management attention to and involvement in the
performance of nuclear safety or safeguards activities are good. The
licensee has attained a level of performance above that needed to
meet regulatory requirements. Licensee resources are adequate and
reasonably allocated so that good plant and personnel performance is
being achieved. NRC attention may be maintained at normal levels.
3. Category 3. Licensee management attention to and involvement in the
performance of nuclear safety or safeguards activities are not
sufficient. The licensee's performance does not significantly exceed
F
that needed to meet minimal regulatory requirements. Licensee
resources appear to be strained or not effectively used. NRC
attention should be increased above normal levels.
The' SALP Board may also include an appraisal of the performance trend of a
functional area. This performance trend will only be used when both a
definite trend of performance within the evaluation period is discernable
and the Board believes that continuation of the trend may result in a
change of performance level. The trend',-if used,'is defined as:
_ _-_-__ -
, -_ _ _ _ _ ._ -- _
_- ._ _
-, c . , ,.-
L .
'
.
-
6
Improving: Licensee performance was determined to be improving near the-
-close of the assessment period.
1
Declining: Licensee performance was determined to be declining near the
close of the assessment period and the licensee had not taken meaningful
steps to address this pattern. l
IV. PERFORMANCE ANALYSIS
l
A. Plant Operations
1. Analysis
In addition to routine inspections, an Operational Safety Team
Inspection (OSTI) was completed during this assessment period.
The principle objectives of the OSTI were operational safety
performance, operations support, design, corrective actions,
safety committee function, and ' management oversight.
Inspections of the licensee's Emergency Operating Procedures
(E0P) and fire protection program were also performed.
Plant operations were generally conducted in a conservative
manner to ensure plant safety. An indication of this
conservative approach to operation was the decision to stop a
reactor coolant pump in November 1988, when an increase in pump
vibration was indicated. One instance of a non-conservative
operational decision was the continued operation of the plant
with a bonnet leak from an emergency feedwa_ter check valve even
though a plant shutdown provided an opportunity to repair this
leak. The leak resulted in emergency feedwater piping
temperatures exceeding the piping design temperature. The plant
staff was observant of Limiting Conditions for Operation (LCOs)
and generally conservative in its application of action
statement requirements.
Overall control of plant operations was satisfactory. A
continuous on-line Crystal River operating record of 216 days
was achieved during this assessment period. In addition,
Crystal River's average capacity factor of 80% for 1988 compared
favorably to the Babcock and Wilcox plant average of 62.5%. Two
reactor trips occurred; the same number of trips that occurred
in the preceding evaluation period. During one of these reactor
trips, plant operators responded expeditiously and prevented
excessive cooldown of the primary system when the main turbine
failed to automatically trip. Effective operator action was
also evident in April 1988, when a main steam isolation valve
inadvertently closed and a high pressure reactor trip was
averted. In January 1988, another high pressure reactor trip
was avoided when a feedwater valve failed closed and caused a
feedwater transient. These actions are noteworthy considering
the rapid response required to mitigate primary system
transients induced by secondary transients in babcock and Wilcox
plants.
. . _ _ _ _ _ _ _ _ _ _ _ _ . . -_
_ -_ _ - _ - _ _ - _ _ _ _ _ _ _ - _ -
}. ,
c
4
'-
.4
. 7
Two instances of deficient operator' performance were also noted.
During the process of placing the main. turbine generator on line '
for a plant startup'in October 1988, an excessive-steam flow
transient occurred that resulted in one of the two reactor-
trips.- During this event, an operator increased steam flow in
response to annunciated alarms instead of-decreasing steam flow,
which would have helped to reduce the pressure transient.
During a _ plant ,heatup in October 1988, an inadvertent loss of
decay heat removal cooling occurred because operators were
unaware of a: change to the isolation pressure setpoint for this
system.
Operations staffing has improved. A six shift rotation. for
operators has been implemented. This rotation allows' for three
operating. crews, an off crew, daily work group / relief crew, and '
a crew in training. Based on feedback from numerous operators,_
i- this rotation was favorably received and has raised the morale
of the operations staff. Coincident with this effort, the use
of operator overtime has been significantly reduced. As'a
drawback however, the use of less experienced operators
contributed to the problem the licensee has had with adherence
to plant procedures.
The use of less experienced operators to perform plant
operations heightened the need for increased - supervisory
attention. Several of the violations listed below, and
nonconformances identified by the licensee, could have been - - - -
avoided had ' increased supervisory rev'few of the' inexperienced
operator activities been performed. NRC management met with the
licensee's management on November 9,1988, to discuss concerns
i of plant personnel performance and corrective actions for
improvement.
l Several strengths in the operations area were noted by the OSTI,
including the general sensitivity of operators to strict adher-
ence to procedures, and timely and thorough shift turnovers.
Although the sensitivity of operators to adherence to procedures
has been heightened, problems in this area still exist. Failure
, of operators to properly implement procedures account for most
l of the violations listed below (violations b, c, d, e, f and g).
'
The licensee has been responsive to this problem and is continu-
ing to implement corrective actions to identify and correct the
root causes for these events. These corrective actions are
discussed in more detail in the Safety Assessment / Quality
Verification section of this report. The operations staff has
instituted a working group which reviews all completed surveil-
lance and operating procedures performed by operations, to
detect procedure noncompliance.
An inspection of the licensee's E0Ps identified numerous minor
procedure deficiencies. However, overall the E0Ps were found to
be adequate for continued operation of the facility. While none
of the individual deficiencies noted were significant enough to
- - - - _ - _ . - - _ _ - . - - _ - , - _ _ . _ - _ _ - - _ --
- _ _ - - -
V.*; .
..
r s
- < ,
-
8
be issued as violations, the larg number found reduces the
margin _ of safety of plant operation by placing unnecessary
demands on the operators required to take prompt corrective
measures during events. Many discrepancies in the areas of
procedure technical content, writer . guide adherence, and human
factors were identified, including procedure nomenclature and
control board labeling inconsistencies. The number of these
inadequacies indicate that the E0P verification and validation
program had not been adequately performed. To alleviate
concerns, the licensee committed to rewrite and revalidate all
the E0Ps.
The ~ licensee has undertaken several efforts to improve
professionalism in the control room including the development of
an Operator Code of Ethics. This document was developed by the
plant operations staff to establish high standards of
performance. To focus attention of the operators to the control
board, the licensee has modified the control room furniture
arrangement such that the desks now directly face the consoles
,
instead of away from.
The installation of an " Operations Lunchroom" has removed much
of the traffic in the control room at lunch time. The licensee
has also moved the operations turnover meeting to a location
ot.tside of the control room, reducing the. traffic and noise
level in the control room. On two occasions, non-work related
material was noted in the control room. Although this material
did not appear to hinder the control board operator performance,
it was' considered to be inappropriate for maintaining the
professional environment and attitude necessary in the control
room.
The conduct of shift turnover meetings continues to be a strong
point in plant operations. A _ representative from the site
engineering staff has augmented the representatives from the
other organizations at these meetings. This addition improves
the overall plant control, coordination and support needed by
the operations department.
Plant operators are encouraged to identify equipment
deficiencies and initiate work requests for repair. This action
is readily apparent in the number of deficiency tags initiated
from the operations department and is reflected by the generally
good material condition of plant equipment. The licensee'is
striving to operate with a " black board" in the control room.
Approximately six annunciators are presently alarmed when the
unit is operating at 100 percent power.
The licensee's administrative control procedures, which
implement the fire protection program, control fire hazards
within the plant, and training requirements for the plant fire
brigade, were found to meet NRC requirements and guidelines, and
were adequate to meet the licensee's fire protection program,
i ------____ ______ _ _
_ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _
.. + .. .
it *
, .
.,.
-
9 1
Implementation of the fire prevention administrative controls,
and the control of combustible and. flammable ~ materials 'in
safety-related areas of the plant were satisfactory.
The. fire protection extinguishing systems, fire protection
system, and. fire barrier assemblies required for protection of
safe shutdown of systems were functional. The licensee's' fire
brigade organization -staffing. 'and training met NRC
requirements. The training and drills for the fire brigade
members met the frequency specified by plant procedures. The
effectiveness of the fire brigade emergency response was also
evaluated during an unannounced drill observed by.the NRC staff.
The overall brigade and brigade leader performances in the drill--
were very good and demonstrated .the capability to effectively
respond to emergency fire events. The observed drill was
considered realistic.
Although housekeeping in most of the plant was considered
adequate,- housekeeping in several' plant areas was noted to be
poor. Areas such as the diesel fuel oil. transfer pits, sodium
hydroxide storage- tank room, low level waste compacting room,
decay .. heat pits, and seawater room declined in general
cleanliness. When the NRC brought these conditions to_ the
licensee's attention, appropriate actions were taken to remedy
the situations.
Seven violations were-identified: - - - - _. _
a. Severity Level V violation for. failure to determine the
reactor coolant system cooldown rate at least every 30
minutes as required by technical specifications.
(302/87-28-02)
b. Severity. Level IV violation for failure to adhere to
operating procedures during radioactive liquid release.
(302/87-30-02)
c. Severity Level IV violation for failure adhere to
procedures requiring an adequate fire watch during
welding activities. (302/87-34-02)
d. Severity Level IV violation for failure to adhere to plant
procedures related to clearances. (302/87-40-01)
e. Severity Level IV violation with three examples of failure
to implement plant procedures. (302/88-01-01)
f. Severity Level IV violation for failure to implement the
requirements of plant procedures. (302/88-14-02)
9 Severity Level IV violation for failure to have two.
operable battery chargers to supply the 'B' station
battery. (302/88-29-02)
2. performance Rating
Category: 2
_ _ _ . _ _ _ _ _ _ _ _ _ _ - -
y
4- .c.
.
..
,
.
10
3. Recommendations
,
None
B. Radiological Controls
1. Analysis
'
'
Inspections were conducted in the areas of radiation protection,
radiological effluent and confirmatory measurements during this
assessment period. A special team inspection was also conducted
to assess the licensee's program for maintaining radiation
exposures as low'as reasonably achievable (ALARA).
The Acting Superintendent of Chemistry / Radiation was confirmed
in the position, the former Chemistry Manager was promoted to
Assistant Superintendent of Chem / Rad with new responsibilities
in health physics, and the former Staff Chemist became the new
Nuclear Chemistry Manager.
The licensee's health physics, radwaste, and chemistry staffing
levels were ' adequate and compared well with other utilities
having facilities of similar size. An adequate number of
American National Standards Institute (ANSI) qualified licensee
health physics _(HP) technicians were available to support
routine operations. During outage . operations, additional
contract HP technicians were used to supplement the permanent HP
staff. ' The ovdrall. ~qua~lityland:experiencelevel of the HP . staff
are viewed as a program strength. Radiation protection training
was considered good.. The licensee's general employee training
(GET) in radiation protection was well defined. The GET program
not only included standard topics as outlined in 10 CFR 19, but
also findings of licensee audits and NRC inspections. The HP
was accredited by the Institute of Nuclear
technician
Power training (INP0) during this assessment period.
Operations
Management support of and commitment to training were evident in
that sufficient time was allowed for training and employees were
encouraged to attend.
Management support and involvement in matters related to
radiation protection were demonstrated by improvements in the
instrument calibration facility, relocation of the contaminated
clothing laundry, and the development of a new radiation
controlled area (RCA) exit which resulted in lower radiation
levels in the personnel contamination monitoring area. The
licensee has also purchased new monitoring instruments, which
have improved the monitoring of tools and equipment leaving the
RCA.
Resolution of technical issues was adequate, as evidenced by the
licensee's development of a comprehensive program for the
containment and monitoring of .small highly radioactive
particles. Response to NRC initiatives was conducted in an
effective and acceptable manner. Specifically, in response to
NRC inquiries, the licensee verified the vendor software for the
- _ _ _ - - _ _ _ - - _ _ _ _ -
- _ - _ _ .
. .' .. .
.
.
-
11
new whole body counter and formalized the methods us2d by the HP
staff in upgrading protective clothing requirements specified in
radiation work permits.
The licensee's respiratory protection program was adequate,
although a violation (violation b) was identified relating to an
individual who was issued and wore a respirator when hic medical
qualification had been withdrawn. The licensee aggressively
evaluated this finding and took prompt and effective corrective
actions.
Near the beginning of the assessment period, there was an event
involving the removal of several lead bricks from a permanent
shielding barrier blocking the reactor cavity access by an
unauthorized auxiliary nuclear operator. Mhen the lead bricks
were removed from the reactor cavity access, a high radiation
area of 50 R/hr, which was uncontrolled with respect to
barricading, posting, and access, was created. This radiation
field existed for a period of approximately 30-45 minutes until
it was discovered and controlled by a HP technician. Although
the radiation dose to the worker was less than NRC limits, there
was a significant potential for the worker to receive exposure
in excess of NRC limits. During an NRC inspection, additional
violations were identified, which involved a plant worker
entering a posted high radiation area without the required
radiation monitoring device and failure to follow plant proce-
dures. The violations from these two events (violation a) were
collectively categorized as a Severity Level III problem.
After the events, the licensee promptly notified the NRC and
took extensive corrective actions. The quality of the radiation
protection program improved during the assessment period.
The 1987 collective radiation dose was 487 person-rem,
approximately 32% above the national average of 368 person-rem
per pressurized water reactor (PWR). For the years 1986 through
1988, the three year average was 335 person-rem as opposed to a
national three year average of 345 person-rem for PWRs. In
1988, the station's collective radiation dose was 71 person-rem,
which was significantly below the national average. However,
there was no refueling or major maintenance outages in 1988.
, The NRC performed a special assessment of the licensee's program
for maintaining occupational radiation doses ALARA. A high
level of plant and corporate management awareness of and support
for the dose reduction program was noted. The licensee has
taken a number of initiatives, including reorganization of the
Nuclear Integrated Planning Scheduling Group, to effectively
manage outage related tasks and reduce collective radiation
dose. The effectiveness of these initiatives in reducing the
collective radiation dose for a major maintenance or refueling
outage is yet to be demonstrated.
I
_ _ _ _ - - _ - _ - _
. e
.
l
'
.
-
12
l
l At the end of 1987, the area of the plant controlled as
radioactively contaminated was approximately fourteen percent of
the total area that potentially could become contaminated. At
the end of 1988, the area contaminated was approximately seven
percent. The total area contaminated was in the median for
Region II plants. The licensee's decontamination efforts during
the assessment period have significantly improved personnel
eccess to the spent fuel pool floor and the miscellaneous waste
evaporator room. The continued reduction in the size of
contaminated areas throughout the plant has had a positive
effect on plant operations by reducing the use of protective
clothing and respirators as well as radiation exposures and
personnel contaminations.
The licensee experienced 131 personnel contaminations in 1987,
56 of these were skin contaminations. The number of personnel
contaminations in 1987 was among the lowest in Region II. The
number of personnel contaminations in 1988 declined to 56; 43 of
these were skin contaminations.
The licensee's program for packaging and shipping radioactive
material was generally adequate. However, a violation
(violation c) was issued for exceeding the NRC limit for free
standing liquid in a waste container transported to a low level
waste burial facility.
'
Liquid and gaseous radioactive effluents were within the
technical specification (TS) limits and in compliance with
40 CFR 190 limits on radiation dose and radioactivity
concentration in effluents. Fission and activation products in
gaseous effluent were slightly lower in 1987 than in 1985 and
1986. Radioactivity in liquid effluent was approximately the
same in 1987 as compared to 1986. There was no significant
trend in the quantity of radioactivity in gaseous and liquid
effluents discharged from the plant. Effluent summary data for
1985, 1986, and 1987 are contained in Section V.I of this
report.
Three violations were identified:
a. Severity Level III violation for failure to adequately
control access to high radiation areas, failure ta
provide adequate radiation instruction to an Auxiliary
Nuclear Operator in a restricted area, failure to
establish adequate radiation protection and refueling
operations procedures, failure to have a radiation dose
instrument upon entry into a high radiation area,
failure to provide and implement adequate procedures for
prompt corrective action for radiation safety violations,
and failure to follow radiological control procedures
(302/87-35,88-03).
b. Severity Level IV violation - for failure to maintain
. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. _ - - _ .
,- ,.
.
-
13
adequate records to implement the approved respiratory
protection program (302/87-29-01).
c. Severity Level IV violation for failure properly solidify
liquid waste transported for burial (302/87-39-01).
2. Performance Rating
Category: 2
3. Recommendations
None
C. Maintenance / Surveillance
1. Analysis
In addition to routine inspections, a special check valve test
program inspection was conducted during this assessment period.
Significant surveillance activities included an integrated
containment leak rate test and snubber surveillance. A
refueling outage occurred during this assessment period, along
with three relatively short maintenance outages to repair main
feedwater control valves, emergency feedwater check valves and a
reactor coolant pump.
, The check valve. inspection focused mainly on the ability of the
licensee's testing program to establish check- valve disk and
seat integrity, location of check valves with respect to sources
of turbulence, review of the maintenance and failure history of
check valves, and the licensee's response to industry recommen-
dations for improving check valve testing programs. Weaknesses
were noted in the licensee's inservice testing program for check
valves; for example, the program only satisfied the minimum
requirements of the code, most of the check valves were not
being tested to demonstrate that the valve could perform all of
its safety functions in the open and closed positions, and most
of the valves were located closer to sources of turbulence thL.
recommended by the manufacturer for optimal performance. An
emergency feedwater system overtemperature event, which occurred
in June 1988, could have been averted had the safety function of
this system's check valve, in the closed position, been tested
and deficiencies corrected.
l Weaknesses in scheduling surveillance and in the overall
I
management of the inservice inspection and testing programs were
discussed in the previous SALP. To correct the scheduling
problems, the licensee revised the scheduling procedure, and is
also implementing a computerized system to eventually replace
this procedure. The computer system will schedule and track
accomplishment of all surveillance, with the exception of
special condition surveillance, which will continue to be
tracked with procedures.
I
L____________._--__. _ _
!
..
,,s
.
l' ;'
~
.
14
l The licensee's surveillance testing program was satisfactorily-
l: established and implemented. The licensee implemented a new 10
year inservice inspection and testing program in.1988 and
committed to a more recent edition of the inservice inspection
and testing code. This program was developed and controlled by
the licensee in contrast to the previous program which was-
developed by a contractor. All inservice inspection testing
procedures were rewritten,- verified and validated to the new
code.
Past problems with the overall management of the ISI/IST
programs were in the areas of. procedural adherence, program
implementation and documentation, and program change review and
approval. These areas were reviewed on three inspections during
the current assessment period. To improve' performance, the .
licensee has reorganized its staff so that the Nuclear Technical
Support Superintendent can be dedicated to inservice inspection
and testing issues. Staffing has been expanded to five
permanent employees by adding two senior results engineers,
thereby reducing the dependence on contractors. This expansion
is expected to enhance the trending of data being placed into a
computerized data base. For further improvement, the adminis-
trative controls in this area have been rewritten and
strengthened. Additionally, three program documents have been
created, Non Destructive Examination, Repair and Replacement,
and Hydrostatic Testing, to better define program activities ano
responsibilities. Through interviews and review of programs,
procedures and records, the NRC staff has ascertained that
management's actions have effectively addressed the past
problems and enhanced the ISI/IST programs over the SALP period.
Surve111ances in the areas of snubbers and containment leakrate
were conducted with well written procedures, knowledgeable staff
and adequate preplanning.
Maintenance continues to be a strength of the licensee's
performance. An example is the use of predictive maintenance
analysis. Oil and vibration analysis on mechanical equipment,
as well as infrared analysis on electrical equipment, predict
degrading trends in equipment pe dormance, allowing equipment to
be repaired before failure occurs. This program has predicted
the impending failure of a reactor coc'! ant pump and a gear box
for a closed cycle cooling water pump.
The adequacy of preventive maintenance procedures was identified
as a weakness in the previous SALP. To correct this deficiency,
the licensee has reviewed and revised .93 preventive maintenance
procedures to verify technical accuracy and inclusion of human
factor principles. The development of preventive maintenance
procedures for the Integrated Control System (ICS) should
strengthen the maintenance program. These procedures include
pre-operational and periodic checks of ICS components, response
testing of ICS instrumentation, and calibration of ICS control
. _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ - -
L>>.
s 3, p ,; . , ,
- )
, ,
,
..y . , .' i
'
,
15
n
circuitry. . Although the-procedures have been written, they have
L not been. fully implemented.
"
.The. licensee has implemented a non-safety related equipment
reliability improvement policy. This policy ' directs that
improvements be madecin operation, maintenance, and failure
4
analysis measures for equipment that is critical to plant
operation. These measures have historically been used only on
. safety related equipment. Some of the; non-safety related
equipment selected for the improved treatment include main
1 '
feedwater control valves, ICS, critical . electrical power
supplies, normal reactor heat removal systems,. turbine generator
protection. systems, fire systems, security systems and critical
heating and ventilation equipment.
A Motor Operated Valve Analysis and Testing System (MOVATS) has
been implemented. This system' tests the operability and proper
switch settings for motor- operated valves. Training on this
system is conducted using a-training valve and generating faults.
to enhance the' diagnostic skills of the workers. Although the
licensee developed maintenance procedures for the use of M0 VATS,
deficiencies were noted, including the . omission of,. problems
. identified. in two NRC information notices, and the method for
performing the. stroke timing.of valves. The licensee plans to
.. perform diagnostic testing of all motor operated valves regard-
L less of use. This action exceeds the recommended regulatory
action required.
The reliability centered maintenance program.is still evolving.
The program uses machinery history data and the frequency at
which components fail to predict future failures. The licensee
is continuing to improve the equipment data base to enhance
computer trending of_ equipment failures.
Another strength of the maintenance program is the use of mockup
facilities for. workers to develop and practice good trouble-
shooting techniques. This practice was evident during
inspections of reactor vessel core nozzles and skirt welds, and
the equipment qualification modification to terminal blocks
located inside the reactor buildi g. The use of mockups in the
pre-job training for this work reduced equipment downtime and
substantially reduced the worker's stay time in high radiation
areas.
Overall control of maintenance activities was adequate. However,
mistakes made by maintenance technicians while performing
maintenance or surveillance testing resulted in four actuations
of-Engineered Safety Features (ESF) systems. This number of ESF
actuations accounts for approximately half of the actuations
that occurred during this assessment period. In another case,
the lack of extensive maintenance troubleshooting techniques
employed to determine and correct main feedwater valve control.
problems that caused an Emergency Feedwater system actuation in
. _ _ - _ - _ _ _ _ -
.. - .
. ,
.
l
-
i
.
16
January 1988, resulted in a second actuation of the system a few
days later. The maintenance department backlog of work requests i
remained fairly consistent in 1988, at an average of 290 work i
requests. l
All the violations listed below pertain to procedure adherence ,
and procedure adequacy. The failure of supervisory personnel to
conduct adequate reviews is a weakness that has been repeatedly ,
'
identified to facility management and was noted to be a weakness
in the previous SALP assessment. To correct this deficiency,
1 the licensee is training the first line supervisors in root
cause analysis and human performance evaluations. To improve
the adequacy of surveillance procedures, the engineering staff
has devoted considerable time and effort to rewrite and validate
all the procedures.
The licensee improved the overall control and planning for
outages. A strength in this area is the continued use of outage
planning meetings, which are held twice daily to schedule
activities and resolve conflicts. A new group called Integrated
Planning was formed after the 1987 refueling outage. This group
serves the function of outage planning and scheduling as well as
day-to-day maintenance planning, and has performed well in the
two outages following formation of this group. The planning
group has made a positive impact on maintenance activities by
causing less scheduling changes and more efficient use of
available manpower. Another strength for controlling- work-
during outages is the establishment of job sponsors. They
'
perform the project manager functions for maintenance activities
that have a potential need for coordinated efforts. Job
sponsors plan and schedule all aspects of the activity including
resolving the problems that could delay work.
Major improvements were noted in corrosion control and plant
operations to limit corrosion. These improvements were the
results of several licensee activities including the successful
removal of corrosion products from the steam generators,
increased surveillance and maintenance related to the main
condenser, replacement of copper-nickle alloy tubes in the
moisture separator reheaters, and improved training and quality
control within the Chemistry Department. The chemistry program
has been strengthened through the promulgation of a corporate
policy statement that endorsed the water chemistry guidelines
recommended by the Steam Generator Owners Group (SG0G) and the
Electric Power Research Institute (EPRI).
- Five violations were identified;
a. Severity level IV violation for failure to test the emer-
gency power supply to the 'A' pressurizer heaters as
required by technical specifications. (302/88-11-01)
b. Severity level V violation for failure to adhere to
9
_ _ _ _ _ _ . _ _ _ _ - _ _ _ _ _ _ _ - _ _ - -_ _ _ _ _ _ _--
_
_ _ _ - . _ . _ - _ _ _ _ _ ___ _ _ - . _ _ - ._. __ _ ___-
,;.
c
.
i *
17
procedures regarding boron concentration analysis for the
'
core flood tanks. (302/88-16-02)-
c. Severity level IV-violation for failure to have an adequate
maintenance procedure for'the replacement of a hotleg
RTD. (302/88-29-01)
d. Severity level IV violation for failure to properly
implement a surveillance procedure during engineered
safeguards channel calibrations. (302/88-29-05)
e. Severity t.evel IV violation for_ failure to. set RPS trip set-
point conservatively, resulting in only two RPS chan-
nels operable for a three hour period. (302/88-34-01)
2. Performance Rating
Category: 2
3. Recommendations
The licensee is encouraged to complete implementation of.-its
computerized tracking system and preventive maintenance on the
integrated control system.
1. Analysis-
The inspections conducted during this assessment period by both
resident and regional staffs included a remedial radiological.
medical emergency drill, a reactive emergency preparedness
inspection, an exercise with full participation by the risk
counties, and a supplemental dose assessment drill to
demonstrate corrective actions taken in response to an exercise
weakness.
The remedial radiological medical emergency drill was conducted
on September 3, 1987, to demonstrate corrective action to
deficiencies observed during the 1987 emergency exercise. The
1987 emergency exercise was not part of this SALP period. The
remedial drill disclosed that effective management and control
of the drill were implemented, and that health physics practices
and contamination control were significantly improved and
considered adequate.
The reactive emergency preparedness inspection evaluated the
licensee's implementation of its Emergency Plan on October 16,
1987, when an Alert emergency condition was declared as a result
of events accompanying the loss of offsite power. The scope of
, the reactive inspection was expanded to include a similar event
that occurred on October 14, 1987. The inspection identified
one violation that addressed a procedural noncompliance problem.
A subsequent inspection found the licensee's corrective action
to be adequate. '
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
_
_ _ _ _ _ _ _ - - _ _ _ _ _ _
'f',;
. *.
.. .
4
18
The routine emergency preparedness inspection performed in July
1988 disclosed that the licensee maintained a capability for
3
prompt notification of the affected counties in the event of an
emergency. Organization and management of the Emergency
Preparedness program were reviewed and determined to be-
adequate. Review of an independent audit of the program,
conducted by the licensee's Quality- Programs Department,
i. disclosed that all findings identified were tracked for adequate
response and required closeout action.
Additionally,~the routine inspection reviewed the status of the
training program, including the review of selected lesson plans,
examinations and test results for Emergency Coordinator Training
and Emergency Sample Team Training. The inspection also
included an interview in the Control Room with the Shift
Supervisor on duty. The individual exhibited a broad knowledge
of the Emergency Plan and its . implementing procedures.
The emergency exercise, with full participation by the risk
counties, was conducted in June 1988, and demonstrated that the
licensee could satisfactorily respond _ to an emergency at the
-facility. However, two exercise weaknesses were identified.
One of the weaknesses addressed the failure'to fu'lly meet the
exercise objective of demonstrating an understanding of
Emergency Action Limits (EALs) and proficiency .in recognizing
and classifying emergency conditions 'in the Technical Support
Center (TSC). Specifically,-the exercise controllers prompted. -
the Site Area Emergency (SAE) declaration whe'n exercise partici-
pants failed to promptly declare a-SAE based on greater than 50
mR/hr at the site boundary for greater than 30 minutes. The
other exercise weakness addressed the need for timely and
correct'offsite dose projection data in the Emergency Operations
.
'
. Facility (E0F). This occurred because of the time-consuming
practice of obtaining radiological and meteorological data from
the Control Room and then providing the information to the dose
assessment teams in the TSC and the E0F via telephonic communi-
cations. The licensee identified the source of their problem
and took aggressive corrective action. Corrective actions
included additional instruction on the new dose assessment
computer model along with a computerized display of radiological
and meteorological data in the TSC and E0F. The licensee fully
demonstrated this capability to the NRC on November 10, 1988,
with a supplemental dose assessment drill.
One violation was identified:
Severity Level IV violation for failure to maintain and
implement the Emergency Plan Implementing Procedures
(302/87-36-01).
2. Performance Rating
Category: 2
_ _ _____-__
[,. ...
.
4
-
19
l
3. Recommendations
None
E. Security
1. Analysis
During this assessment period, five security inspections were
performed by the regional staff. In addition, the resident
inspectors devoted numerous hours to the review of daily on-duty
security force performance.
The licensee has submitted changes to the Physical Security Plan
through change No. 4-22 and 4-24, dated July 18, 1988. These
plan changes were submitted in accordance with 10 CFR 50.54(p)
and did not decrease the effectiveness of the security program.
The licensee also submitted revisions to the Physical Security
Plan to address the Miscellaneous Amendment and Search Require-
ments regulation. The licensee's submittals were sound and
consistent, demonstrating the existence of well developed
policies and procedures for the control of security related
activities.
In an effort to improve the effectivenesses of the Physical
Security Plan, Safeguards Contingency Plan, and Training and
Qualification Plan, the licensee,is in the process of rewriting
these plans. The plans were recently submitted for NRC review
and comment. To expedite the review process, the licensee has
met with the NRC to discuss concerns and make the necessary
adjustments. These meetings, along with the early submittal of
the plan change proposals, have aided both the licensee and the
NRC in ensuring tinely and effective implementation of the new
plans. It was further noted that the licensee has revised
security procedures, and has augmented the security procedures
with individual security post orders.
Although there are no established requirements for security
'
lighting to be equipped with a back-up power source, the
licensee, in response to a previous Regulatory Effectiveness
Review finding, completed actions to include a portion of the
protected area lighting on the Technical Support Center
The security staff, with positions and responsibilities well
defined, is adequate to implement the physical protection
program. In addition, the security training program is well
established and is oriented towards both formal classroom
instructions and hands-on proficiency evaluations. Recent
inspections have verified that the training programs are
providing effective training to responders as evidenced during
contingency response drills. The responders were able to
effectively neutralize the threat by applying sound tactical
_ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ - -
_ _ _ _ - -
t ,3 3
^
l .
!
-
.
1:
'
20
'
deployment. maintaining control of the situation, and using good i
radio discipline. It was further noted that the alarm station
operators, were capable of communicating and maintaining direct
command. and control of security . activities during the contin-
gency response drills.
Another example of the licensee's on duty security force
alertness has been their ability to detect, on numerous
occasions, th: attempted introduction of firearms :into the
facility through' both the personnel and vehicle access portals.
Corporate and Site management exhibited a knowledge and
understanding. of security requirements, as well as ' a demon-
strated supportive attitude towards enhancing the physical
security features. This has been evidenced by the willingness
to upgrade the perimeter. intrusion system 'and through the
procurement of a state-of-the-art computer system. However,
during testing, the new computer system was found unreliable and
failed to achieve the NRC's security requirements. Therefore,
the licenta will continue to utilize the old security computer
system pending an in-depth review to determine what type system
-will best be adaptable to their needs.
No violations were identified during this rating period.
2. Performance Ratig
- . _ . . .
,
3. Recommendation
None
F. Engineering / Technical Support
1. Analysis
The Engineering / Technical Support functional area addresses the
adequacy of technical and engineering support for all' plant
activities. To determine the adequacy of the support provided,
specific attention was given to the identification and resolu-
tion. of technical issues, responsiveness to NRC initiatives,
enforcement history, staffing, effectiveness of training, and
qualification. Activities evaluated include those associated
with the design cf plant modifications; technical support
provided for operations, maintenance, testing and surveillance;
training; and configuration management. This evaluation is
based on routine and special inspections conducted by the NRC in
this area and related functional areas and on the licensee's
day-to-day performance. The results of the Operational Safety
Team Inspection (OSTI), which was started at the end of the
previous assessment period, will be addressed in this report
..
_______ _______ ________ _ ._ _
_ _ __ ..
.
If,_c
.
.
+
'
.
l *:
21
because the results were issued and responded to in this
assessment period.
Engineering weaknesses' were identified in -this assessment
period. The weaknesses were programmatic inadequacies related
to control of engineering calculations, quality of design base
information, prioritization of- plant requests for engineering
assistance, awareness of environmental qualification (EQ)
requirements, translation of design basis information into plant
precedures, soundness and completeness of licensee-analyses, and
control of vendor technical information.
Engineering calculations did not consistently identify
- assumptions and design inputs. Examples of the use of
unverified calculations .in the development of design parameters -
were identified. Additionally, engineering calculations were
not consistently filed and readily retrievable. These
calculation deficiencies indicate that the design bases are not
well documented.
The continuing and expanding Configuration Management Program
(CMP) is a' major effort to improve engineering performance.
This program will provide field validation of accident analysis
base documents, improvement and validation of design basis
documents, development of a computerized safety list system and
a configuration management information system. This long term
program is: intended to substantially improveithe. quality and .
timeliness of engineering reviews and design activity. The
projected CMP completion period of five years, due to resource
constraints, impacts the timeliness of resolution.
A lack of prioritization for engineering assistance requests
from the plant was a contributing factor to violations (e) and
(f) discussed in the Safety Assessment / Quality Verification
section related to overtemperature of energency feedwater
piping. An engineering evaluation requested for a potential
overtemperature condition was not performed, therefore a poten-
tial safety significant condition was not identified.
Design engineering's inadequate familiarity with EQ requirements
and issues was a major contributing factor to violations (b) and
(c). This poor EQ familiarity resulted in inadequate EQ
consideration in modifications, incorrect removal of components
from the EQ list, and inadequate EQ master list control.
Previously existing deficiencies which were identified this
assessment period included the translation of design bases into
equipment design, operating, or test procedures. Specific
examples of these deficiencies included the design loading of
emergency diesel generators, ultimate heat sink temperatures,
and minimum design cooling flows to safety related components.
An additional example identified that the surveillance test for
..
________________-______ - - - -
_ _ _ ._ _ ____-_ - _
c' .' -
4
-
.
22
the Reactor Building Spray Pumps was based on ASME section XI
requirements, which did not fulfill system design requirements.
Other programmatic problems identified included failure to
include High Energy Line Break (HELB) analysis in modification
package development and inadequate evaluation of incoming vendor
technical information. The design basis requires HELB analysis
for safety related modifications as an on-going design criterion
and this analysis has never been performed. With respect to
vendor technical information, the incoming information had not
been adequately evaluated to determine the impact on the design
function of the associated component or system.
Inattention to detail resulted in an additional violation and
deviation. The technical support staff welding engineers failed
welders, resulting in violation (d).to assure that (fproduction
Deviation resulted welds we
from inadequate implementation of a design requirement into a
modification. This modication, which implemented a Regulatory
Guide 1.97 requirement for a containment high range radiation
monitor control room recording and indicating display, failed to
assure the required recording display was installed.
The licensee's resolution of the previously discussed weaknesses
and resulting deficiencies demonstrated broad-based problems in
Crystal River's responsiveness to NRC initiatives, resolution of
technical issues,. and the identificati.on and correction of
problems. The licensee took an uncertain, non-comprehensive,
approach to defining the actual EDG load to assure adequacy in
the short term. The licensee did not respond initially to NRC
suggestions to perform actual load testing, and response to both
the long and short term solutions to the loading problem was not
timely. Regarding the ultimate heat sink temperature
discrepancy, the immediate corrective action was adequate;
however, the final proposed limiting temperature and TS
submittal were delayed nearly one year. The licensee's
resolution of the HELB analysis deficiency is a comprehensive
program but with an extended proposed completion date due to
resource constraints and other commitments. These examples of
extended resolutions and limited response activity indicate a
poor responsiveness to NRC initiatives.
The resolution of issues from a safety standpoint has also been
demonstrated to be 6 weakness. For example, the original
submittal to resolve the HELB analysis problem was not adequate
and required amplification and clarification before the NRC
staff agreed to permit continued operation. As another example,
the licensee requested discretionary enforcement in September
1988, to permit containment purging for nine days prior to
shutdown to reduce containment radiation levels caused by an
l unidentified 0.6 GPM primary system leak. This request was not
f granted because radiation levels did not justify compromising
containment integrity. ,
l
t
_ _ - _ _ - _ - _ _ _ -
, ~ ., :.
-
1.
l
.
,
-
'23
Crystal River was deficient in problem correction in the design
area as demonstrated by the resolution of the EDG overload and
combustion air inlet temperature issues. The failure to correct
identified problems in a timely manner resulted in violation (a) '
and a civil penalty. Although the licensee identified the load
calculation error, the event chronology of discovery, reporting
and resolution indicated a non-aggressive corrective action
strategy for resolving a potentially serious problem. The
evaluation and short term resolution of the combustion inlet
temperature problem was inadequate.
Management and staff responded positively to NRC requests for
engineering evaluations to determine the root cause of letdown
cooler failures and suitability of replacement. A third cooler
was added to enhance plant safety. In the evaluation of a
feedwater block valve failure, the engineering staff was
knowledgeable, responsive to NRC questions, and provided
considerable detail of the event. Management involvement in the
evaluation was evident. Good response to NRC initiatives was
demonstrated by engineering staff support and response to the
NRC inspection teams for Emergency Operating Procedures and
Probabilistic Risk Assessment.
The licensee has continuing and recently initiated activities to
address engineering staff weaknesses. A major contributor to
improved engineering support is the implementation of a system
,
engineering program. The system engineer concept provides the 1
advantages of improved trending of system performance and a
designated responsible individual for interface contact and
system information consolidation.
The large amount of engineering effort required by present
commitments (ATWS, CMP, HELB, response to bulletins and generic
letters, etc.) has placed a heavy burden on available resources.
Recognizing that staff shortages or strained resources impact
all areas of engineering performance, the licensee has increased ,
its staff approximately 30 per cent and plans to continue this
growth in an effort to reduce reliance on contract employees.
This reduction in contract employees is, in part, a response to
a weakness recognized during the previous assessment period. In
conjunction with staff increases are efforts at staff improve-
ment, which include engineering training classes. These classes
are designed to increase overall plant system knowledge by
providing instruction in systems, plant operations and system
interactions. Training in EQ requirements is not included in
the system engineering training but is to be included in a
training plan for design engineers.
During this assessment period the licensee has initiated and
continued significant efforts to improve engineering perform-
ance. Much of this effort has directly resulted from weaknesses
identified in the previous SALP period and ind' cates 1
management's intention to dedicate resources for resolving i
problems in this functional area. The staff has demonstrated
1
i
. _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _
. _ _ . _ _ _ _ _ _ _ _ _ _ _
.,,.'.
,
- *
- e,
, , -
e
..
.
24
>
4ej the capability of responding competently and effectively to
plant conditions and specific technical or regulatory issues.
However
technical licensee response to NRC initiatives, resolution of
issues and correct.on of problems has been
inconsistent. -The examples of poor performance previously
a iscussed in these. areas indicate a need for increased emphasi
pe resources to provide consistent high quality engineering
ormance.
Opera r licensing examinations
administered during the
assess
reactor nt period achieved _ a 100 per cent pass rate. Six-
were admiperator
istered.and four senior reactor operator examinations
operator t ining program.This success rate indicates a high quality
examinations One detriment to the training and !
simulator is as the absence of a plant specific simulator. The
in 1990. esently scheduled to be delivered and operational
'
Information provi
d to examiners for examination development
was
the Joblegible, curren , and effective in relating lesson plans to
Task Analyst
for operators. Lesson plans- for licensed
the learning objectivesand non-licensed oper tor training wer
of the plans good. ere clear and concis'e, and the content
During the evaluation of E0Ps, the performance of Shift
Operations Technical Advisor (SOTAs) was found to be weak and
the quality of SOTA training
selection of SOTAs exhibited dentified as ' the root cause. A
which govern their actions duri unfamiliarity with the EDPs
post trip recovery. These
individuals made incorrect assess
were unaware of various plant instrnts of proposed symptoms and
ent indications.
Four violations and two deviations we
.
identified.
a. Severity Level III violation for fa
priate corrective actions to resol urea to deficiency take appro-
regarding diesel generator electrica loads.
(302/87-41-01)
b. Severity Level IV violatica for failure identify
components on the EQ list, and failure t have test
c. data in an auditable form. (302/88-27-01
Severity Level IV violation for failure to a ress
instrument accuracy in EQ files.
d. (302/88-2
Severity level IV violation for failure to meet02)SME Code
Section IX welder performance qualification re ire-
ments. (302/87-32-01)
e.
Deviation involving FSAR requirements for maximum u imate
heat sink temperature.
f. (302/88-14-01)
Deviation involving failure to implement a R.G.1.97
commitment (302/87-40-03) '
.
_ _ , _ _ _ _ _ _ _ _ _ _ - _ _ - - - - - - - - - - - ' ^ ' ' ' ^ ' ^ ~ ^ ^ ' ~ ~ ~
-_- -
3* . p.
..
.
.
' -
24
the capability of responding competently and effectively to
plant conditions and specific technical or regulatory ' issues. 1
!
However licensee response to NRC initiatives, resolution of I
technical issues and correction of problems has been
inconsistent. . The examples of poor performance previously
discussed in these areas indicate a need for increased emphasis
and resources to provide consistent high quality engineering
performance.
Operator licensing examinations administered during -the
assessment period achieved a 100 per cent pass rate. Six
reactor operator and four senior reactor operator examinations
were administered. This success rate indicates a high quality
operator training program. One detriment to the training and
examinations was the absence of a plant specific simulator. The
simulator is presently scheduled to be delivered and operational
in 1990.
Information provided to examiners for examination development
was legible, current, and effective in relating lesson plans- to
the Job Task Analysis for operators. Lesson plans for' licensed
and non-licensed operator training wert technically adcquate,
the learning objectives were clear. and concise, and the content
of the plans good.
During the evaluation of E0Ps, the performance of Shift
Operations Technical Advisors (50TAs) was found to be weak and-
the quality of S0TA training identified as the root cause. A
selection of S0TAs exhibited an unfamiliarity with the
Verification Procedures which govern their actions during post
trip recovery. These individuals made incorrect assessments of
proposed symptoms and were unaware of various plant instrument
indications.
Four violations and two deviations were identified.
a. Severity Level III violation for failure to take appro-
priate corrective ' actions to resolve a deficiency
regarding diesel generator electrical loads.
(302/87-41-01)
b. Severity Level IV violation for failure to identify
components on the EQ list, and failure to have test
data in an auditable form. (302/88-27-01)
c. Severity Level IV violation for failure to address
instrument accuracy in EQ files. (302/88-27-02)
d. Severity Level IV violation for failure to meet ASME Code
Section IX welder performance qualification require-
ments. (302/87-32-01)
e. Deviation involving FSAR requirements for maximum ultimate
heat sink temperature. (302/88-14-01)
f. Deviation involving failure to implement a R.G.1.97
commitment (302/87-40-03)
- _ _ _ _
l
-__ __ _
- ,~* ,..
4 .
... ,
L 25
2. Performance Rating
Category: 3
3. Recommendations
The licensee is encouraged to increase inter-departmental
cooperation and to place priority on developing the system
engineer program and guiding the current resources to benefit
the plant organization.
G. Safety Assessment / Quality Verification
1. Analysis
The licensee's quality program organization is continuing to
,
conduct audits based on organizational performance. .They
inspect a specific organization in all functional areas for
which that organization is involved. The intent of this audit
'
process is to identify any programmatic or significant findings
that remained undetected in the past. Quality assurance
inspections are also being performed on selected plant systems
using a similar technique to the NRC's Safety System Functional
Inspechons (SSFI). The licensee has examined the emergency
feedwater, decay heat removal, and high pressure injection
systems using this technique.
The licensee's Quality Assdrance' (QA) staff is adequate.
Permanent employees have been hired and contractors eliminated
to help stabilize this staff. Contractors are still utilized to
provide technical advisors for the various audit teams. The
quality program organization has improved the methods of
reporting nonconformances in its own organization. However,
other site organizations have retained their own various
reporting systems. The many different systems create potential
confusion and have resulted in one case (violation e) where a
nonconformance was not reported to the NRC in a timely manner as
required. This nonconformance was identified by the engineering
organization, but no trigger was established by this
organization's reporting system to involve the operation's
nonconformance system. This lack of interaction between the
systems was identified by the licensee and corrective action is
being taken to remedy the situation. Lack of interdepartmental
cooperation contributed to this problem.
Weaknesses were noted in the management controls affecting
quality. Management involvement was lacking in resolving an
identified deficiency that existed since 1980 involving a
slamming check valve, and a 1982 deficiency involving the
correct pitch setting for a diesel generator radiator fan. The
existence of these problems for such a long period of time is
indicative of management's failure to demand appropriate correc-
tive action to correct the deficiencies. The OSTI found addi-
tional examples of inadequate or untimely corrective action, and
i
,
m______.____.____.__________.___ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ . _
__
_f ,3
7
,-
.
26
two examples -listed below (violations d and f) involve a
failure to provide adequate corrective action. Also the lack of
management involvement to remedy inadequate post supervisory
reviews of activities discussed in the Operations and
Maintenance / Surveillance areas of_this report is considered to
be a weakness.
The licensee's analyses of root causes of plant problems 'has in
general, been satisfactory. However, there are- two examples
where plant problems were not adequately analyzed. In the case
of overheating of the emergency feedwater lines, inadequate root
cause evaluations were made to identify.and correct the problems
.both in the early stages of the event and in several previous
similar events. Had the leaking emergency feedwater valve been
repaired earlier, overheating of the line would have been
avoided. In another example, faulty operation of main feedwater
low-load valves has contributed to several low-power plant trips
in the past. Incomplete root cause analyses and failure to
correct all problems with these valves resulted in subsequent'
plant transients.
Management involvement is evident in the attempt to solve
procedure adherence problems. Procedure adherence was
identified as a general weakness, encompassing all areas in the
preceding SALP assessment. Plant management is continuing to.
stress the importance of procedure compliance and the policy of
high level management-review-of-recurrent-instances of procedure
noncompliance. The addition of a Human Performance Evaluation?
System to assist in investigating and reporting human
performance problems has strengthened the effort to solve this
problem. This system is used with the Root Cause Evaluation
Program to focus . on contributing causes related to human
performance, and has been effective in identifying human factor-
considerations.
A review of licensee evaluation packages of incoming vendor
technical issues .found weaknesses. Four out of nine packages
reviewed were incomplete or inadequate to properly determine the
impact of the identified issue on the design function of the
component or system. Furthermore, a review of the procedures
that control incoming vendor information indicated that the
licensee had failed to establish appropriate procedures to
evaluate this information (violation g). Each department
established its own instructions, without verification of the
impact on other departments' controls. A licensee quality
programs surveillance agreed that this program was weak. The
licensee is revising its administrative controls in this area.
The licensee's performance in handling licensing actions was
inconsistent. While many submittals were of acceptable quality,
some respons.es .were not always complete and comprehensive,
,. requiring repeated modification. For example, in the review of
fire protection exemptions, there was evidence of prior planning
and management awareness of the importance of the issues
involved, and of a clear understanding and conservative approach
l
_ . _ _ _
.,
,A
....'-
h
,
-
, Q,g 27
h6 to resolution of the technical issues. But the licensee's
responses did not always satisfactorily address the riRC's
concerns with the first submittal, and final resolution of NRC
concerns took about one year. Resolution of the complex EDG
capacity problem required multiple submittals involving
cmtinuously changing figures.to define worst case EDG loads,
th three related Inservice Inspection relief requests, although
tim technical approach was sound and the licensee's responses
by th y,4eckWanagement involvement and planning was evident
staff urgent. nature of the requests, which required accelerated
the tec eview to preclude delays in planned plant restart. In
actions ical specification change _ request to provide specific
(DC) cont be taken when one battery supplying direct current
is inoperab 1 power to the 230 kilovolt (Ky) switchyard breakers
evidence of , the submittal was of high quality with clear
issues involve .od understanding and effective resolution of the
Interpretation o
and conformance with the Anticipated Transient
Without Scram (
S) rule (10 CFR 50.62) has been under
discussion
including FPC,withfor
ows rs
meoftime.
Babcock & Wilcox (B&W) reactors,
of disagreement and Only af ter this extended period
schedular requirements ter reinforcement by NRC staff of the
f the ATWS rule did the licensee exhibit
a cooperative attitude.
conceptual design which The licensee defined and documented a
interpretation of the requ onformed closely with the staff's
implementation on an acceptements of the rule and committed to
belated good responsiveness i le schedule. Another example of
,
the agreement by FPC to provide
i
an additional source of emer ncy feedwater to the steam
generators to improve the system s reifability.
'
During this evaluation period the icensee voluntarily prepared
and submitted a full level-1 Prob bilistic Risk Assessment
.
(PRA)* During NRC review, and especia ly during a meeting at the
site to discuss the PRA, the licensee 5 extremely cooperative.
The PRA was initially prepared by a co tractor, but FPC has
developed in-house capability to facilit te the use of the PRA
in making design decisions and to maintain nd update the PRA to
reflect plant modifications.
Another effort initiated earlier, and continu actively durin
this period is an extensive configuration mana ement program.g
Part of this program will be definition and vert cation of the
plant's design basis and review of plant conforman e with these
design bases. Some of the pre-existing problems scussed in
the Engineering / Technical Support area were identi ied as a
result of this program. Licensee management has
-
significant commitment to this effort. ade a
l
Along with other B&W owners, the Itcensee has activ ly
, participated in the B&W Owners Group (BWOG) Safety a
Performance Improvement Program (SPIP), which has identifie a
large number of modifications which will enhance plant safet .
a
__ _
. _ _ _ _ _ _ - _ _ _ _ _ _
' *
, ,
.
'
- .
,
'
27
l
to resolution of the technical issues. But the licensee's q
responses did not always satisfactorily address the NRC's ,
concerns with the first submittal, and final resolution of NRC
concerns took. about one year. Resolution of the complex EDG
capacity problem required multiple submittals involving
continuously changing figures to define worst-case EDG loads.
On three related Inservice Inspection relief requests, although
the technical approach was sound and the licensee's responses
timely, lack of management involvement and planning was evident
by the urgent nature of the requests, which required accelerated
staff review to preclude delays in planned plant restart. In
the technical specification change request to provide specific
actions to be taken when one battery supplying direct current
(DC) control power to the 230 kilovolt (KV) switchyard breakers
is inoperable, the submittal was of high quality with clear
evidence of good understanding and effective resolution of the
issues involved.
Interpretation of and conformance with the Anticipated Transient
Without Scram (ATWS) rule (10 CFR 50.62) has been under
discussion with owners of Babcock & Wilcox (B&W) reactors,
including FPC, for some time. After reinforcement by NRC staff
of the schedular requirements of the ATWS rule the licensee
exhibited a very cooperative attitude. The licensee defined and
documented a design which conformed closely with the staff's
interpretation of the requirements of the rule and committed to
implementation on an acceptable schedule. . Another. example of
good responsiveness after extended discu'ssion is the agreement
by FPC to provide an additional source of emergency feedwater to
the steam generators to improve the system's reliability.
During this evaluation period the licensee voluntarily prepared
and submitted a full level-1 Probabilistic Risk Assessment
(PRA). During NRC review, and especially during a meeting at the
site to discuss the PRA, the licensee was extremely cooperative.
The PRA was initially prepared by a contractor, but FPC has
developed in-house capability to facilitate the use of the PRA
in making design decisions and to maintain and update the PRA to
reflect plant modifications.
l Another effort initiated earlier, and continued actively during
this period is an extensive configuration management program.
Part of this program will be definition and verification of the
plant's design basis and review of plant conformance with these
design bases. Some of the pre-existing problems discussed in
l the Engineering / Technical Support area were identified as a
l result of this program. Licensee management has made a
f significant commitment to this effort.
l
j Along with other B&W owners, the licensee has actively
'
participated in the B&W Owners Group (BWOG) Safety and
Performance Improvement Program (SPIP), which has identified a
large number of modifications whi::h will enhance plant safety. i
l -_-___-______________ -
_ _ _ _ _ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . __ _ - _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ - _ _ -
" . - ."
, j
.; . l
'
28 I
i
FPC management is well represented in. BWOG ~ direction a'nd has
made major. contributions to the success of the SPIP program thus ,
far. In addition to SPIP, the licensee continues as an active' '
participant in other BWOG activities, such as the Technical ,
Specification Improvement Program.
The licensee responses to Bulletins and Generic Letters 'were
timely and acceptable. FPC is among the relatively few.
i utilities to respond positively to Generic Letter 88-02 by
indicating a willingness to consider pursuit of i.he Integrated
Safety Assessment Program. Response to Bulletin 88-01 was-
acceptable and the Bulletin closed out. The licensee's response
to Generic Letter 88-05 provided assurance that the plant has a
program in place to deal with boric acid leakage. In evaluation
of a 10 CFR Part 21 report regarding cable qualification, the
licensee incorrectly stated that the cables in question ~were not
insSlled at the plant. A second evaluation was handled
properly and the cable was found to be acceptabh for
application.
An inspection was held of the licensee's reviews performed in
accordance with 10 CFR 50.59. The NRC concluded that the
licensee's evaluations ranged from adequate to thorough. The
design change process, of which the 50.59 reviews are a part, is
adequately planned, executed, and documented. The quality of
the reviews represents a meaningful-improvement over past 10 CFR
50.59 reviews performed by_the_ licensee.
NRC inspectors attended several Plant Review Committee (PRC)
meetings and noticed that participation in PRC meetings was
weak. A contributing factor for this observation was the
licensee's utilization of a qLalified reviewer process to
prepare meeting material, with little pre-meeting study of the
material by committee members. Committee members seldom saw
material to be discussed before the meeting unless they were y
involved with the qualified reviewer process and the material to
be reviewed was not readily available for cembers. The guidance
procedures that direct PRC activities were noted to be weak,
resulting in poor control and distribution of responsibilities.
No noticable improvements have been noted in this area.
Licensee Event Report (LERs) analyzed during the assessment
period generally described the major aspects of the events,
including component or system failures that contributed to the !
events and the corrective action taken or planned to prevent I
recurrence. Root causes were identified in most of the LERs.
Of the LERs submitted during the assessment period, two were
categorized as significant. These events involved the discovery
of a potential for overloading the emergency diesel generators
and check valve leaks that led to elevated emergency feedwater
temperatures.
____ _- _ - - _ _ _ -
._
_ _ - _ _
.' ,, "
',
,,
.: ,
29
In the ' area of licensee conformance to Regulatory Guide (RG)
n 1.97, the licensee installed and modified the instrumentation
needed to comply with the RG with the exception of Deviation (f)
l- noted in the' previous section. The licensee recognized the need
for updating drawings after completion of modifications and
developing -instrument loop drawings, but had placed no priority
on the effort. The licensee was responsive to NRC's concerns
regarding the need to commit more engineering effort to this
task and committed to expand this effort.
Eight violations'were identified:-
'
a. Severity level IV violation for failure to meet Nuclear
General Review Committee membership qualifications in
accordance with technical specification requirements.
(302/87-28-01)
b. Severity level V violation for failure to recertify the
qualified reviewers on a periodic basis as required by
technical' specifications. (302/87-28-05)
c. Severity level IV violation for failure to have seismic
monitoring instrumentation in the required measurement
range. (302/88 01-03)
d. Severity level IV violation for failure to provide adequate
corrective action to prevent exceeding liquid waste
releare rates. (302/88-16-05)
e. Severity level IV violation for failure to properly
evaluate a,nd report excessive temperatures in the
emergency feedwater piping. (302/88-18-01)
f. Severity level IV violation for failure to provide adequate
corrective actions to prevent exceeding the design
temperatures in the emergency feedwater system.
(302/88-18-02)
9 Severity IV violation for inadequate evaluation and
procedures to control incoming vendor technical issues.
(302/88-24-02)
h. Severity level V violation for failure to report a condi-
tion in which containment airlock seal leakage tests
were inadequate. (302/88-26-01)
2. Performance Rating
Category: 2
3. Recommendations
None
V. SUPPORTING DATA
A. Investigation Review
None
_ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _
,-___.
!-
p ,,7 .s+
4
i. , . ;.-
. , - -_,
-
30
B.- . Escalated Enforcement Action
1. Civil Penalties
-. Severity Level III violation -issued on March 17, 1988, for
failure to control access to a high radiation area, provide
adequate training, establish adequate procedures, . provide a-
. radiation monitoring device, and follow procedures. The
propt, sed civil penalty of $100,000 was mitigated to $50,000- by
order dated November. 17, 1988.
Severity Level III violation issued on May 4, 1988, for failure
to take appropriate corrective actions to resolve emergency
diesel generator loading deficiencies. The proposed civil-
penalty of $50,000 was mitigated to $25,000 by order dated
October 31, 1988.
2. Orders
None. (except as noted in paragraph V.B.1 above)
C. Management Conferences
September 14, 1987 Quarterly SALP management meeting at
Region II.
December 11, 1987 Enforcement Conference at Region 11 to
,
discuss health' physics event.,
December 18, 1987 Management. meeting at Crystal River
Nuclear Plant to discuss the previous
SALP Board assessment.
February 22, 1988 Enforcement Conference at Region 11 to
discuss the emergency diesel
generator loading issues. ,
March 9, 1988 Enforcement Conference held by tele-
phone concerning issues related to
unauthorized entry into a_high
radiation area. !
March 30, 1988 Management meeting at NRC Headquarters
to discuss emergency feedwater
reliability, OSTI issues, and station
blackout.
July 8, 1988 Management meeting at NRC Headquarters
to discuss check valve leaks in the
August 16, 1988 Management meeting at NRC Headquarters
to discuss emergency diesel generator
modifications, ultimate heat sink
temperature, ATWS, and OSTI response.
November 9, 1988 Management meeting at Crystal River
Nuclear Plant concerning plant person-
nel performance and the status of
equipment qualification program.
_ _ _ _ _ _ _ _ - _ -
_ _ - - - -_ _ _
.o-
, !
>? .' ,
L . .
31
November 29,.1988 Management meeting at NRC Headquarters
to discuss ATWS concerns.
December.21, 1988 Management meeting at NRC Headquarters
to discuss HELB submittal and final
resolution of EDG pressure.
D.- . Confirmation of Action Letters
1. On November 17, 1987, the NRC issued a Confirmation of Action
Letter (CAL) confirming that the licensee would satisfactorily
complete specified actions with regtrd to OSTI findings on the
diesel generator loading, ultimate heat sink temperature, and
service water flow balancing issues.
2. On July 6,1988, the NRC issued. a CAL confirming licensee's
actions with regard to the emergency feedwater system
overtemperature caused by check valve leaks.
E. Review of Licensee Event Reports (LERs)
,
During the assessment period, 33 LERs were analyzed. .The
! distribution of these events by cause, as determined by the NRC
staff, are as follows:
Cause Number
Component Failure 3
Design 8
Construction, Fabrication, 2
or Installation
Personnel
- Operating Activity 10
- Maintenance Activity 4
-- Test / Calibration Activity 3
-
Other- 1
Other' Activity 2
'
Total 33
F. Licensing Activities
During the evaluation period, the staff completed review of 37
licensing actions which resulted in issuance of 10 amendments, five
reliefs, and one exemption. In addition, significant effort was
expended on 11 other issues which were not completed. Some of the
more significant matters include the EDG and HELB problems and the
request for containment purging.
1
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _
1
,-- -_
- 9',' '
,
.
-
,.
'
32
G. Enforconent Activity
, NO. OF DEVIATIONS AND VIOLATIONS IN EACH
FUNCTIONAL SEVERlTY LEVEL
AREA Dev. V IV III II I
Plant Operations 0 1 6 0 0 0
Radiological Controls 0 0- 2 1 0 0
'
Maintenance / Surveillance 0 1 4 0 0 0
Emergency Preparedness 0 0 1 0 0 0
Security 0 0 0 0 1 0
Engineering / Technical
Support 2 0 3 1 0 0
Safety Assessment / Quality
Verification 0 2 6 0 0 0
TOTAL 2 4 22 2 0 0
!
Two automatic reactor trips occurred during this assessment period.
On February 28, 1988, the unit sustained an 6utomatic reactor
trip from 55 percent power on high RCS pressure due to a failure
of the main feedwater block valve to fully close.
On October 28, 1988, the unit sustained an automatic reactor trip from 20 percent power due to problems with the turbine
header pressure controls.
I. Crystal River Unit 3 Effluent Release Summary
1985 1986 1987
Activity Released (Curies)
!
Gaseous Effluents
Fission and Activation 1.96 E+3 2.76 E+3 1.10 E+3
Gases
Iodine and Particulate 8.46 E-4 1.01 E-3 3.49 E-3
Liquid Effluents
t
,
Fission and Activation 1.51 E+0 8.20 E-1 9.55 E-1
Products
Tritium 1.75 E+2 1.73 E+2 3.56 E+2
- _ _ _ _ _ - _ _ _