IR 05000302/2012007

IR 05000302-12-007, January 17 - 23, 2012, and January 30 - February 2, 2012; Crystal River Unit 3; Biennial Inspection of the Problem Identification and Resolution Program

ML120680661
Person / Time
Site:	Crystal River
Issue date:	03/08/2012
From:	Hopper G T Reactor Projects Branch 7
To:	Franke J A Progress Energy Florida
References
IR-12-007
Download: ML120680661 (15)

Text

March 8, 2012

Mr. Jon A. Franke, Vice President Crystal River Nuclear Plant (NA1B) 15760 West Power Line Street Crystal River, FL 34428-6708

SUBJECT: CRYSTAL RIVER UNIT 3 - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000302/2012007

Dear Mr. Franke:

On February 2, 2012, the U. S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution biennial inspection at your Crystal River Unit 3. The enclosed inspection report documents the inspection results that were discussed on February 2, 2012, with you and other members of your staff.

This inspection was an examination of activities conducted under your license as they relate to problem identification and resolution and compliance with the Commission's rules and regulations and the conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.

Based on the inspection sample, there were no findings identified. The inspection team concluded that the implementation of the corrective action program and overall performance related to identifying, evaluating, and resolving problems at Crystal River was effective. Identified problems were entered into the corrective action program; prioritized and evaluated commensurate with the safety significance of the problems. In addition, corrective actions were generally implemented in a timely manner; operating experience was generally reviewed and applied when appropriate. Audits and self-assessments were generally used to identify problems and appropriate actions.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document FPC 2 system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/ George T. Hopper, Chief Reactor Projects Branch 7 Division of Reactor Projects Docket No. 50-302 License No. DPR-72

Enclosure:

Inspection Report 05000302/2012007

w/Attachment:

Supplemental Information cc w/encl. (see page 3)

___ML120680661______________ X SUNSI REVIEW COMPLETE OFFICE RII:DRP RII:DRS RII:DRP RII:DRP RII:DRP RII:DRP RII:DRP SIGNATURE NLS2 RCT1 CWR1 SON by email NRS2 by email GTH1 DWR1 NAME NStaples RTaylor CRapp SNinh NChilds GHopper DRich DATE 03/08/2012 03/08/2012 03/08/2012 03/08/2012 03/08/2011 03/07/2012 03/08/2012 E-MAIL COPY? YES NO YES NO YES NO YES NO YES N O YES N O YES NO FPC 3 cc w/encl.

Kelvin Henderson, General Manager Nuclear Fleet Operations Progress Energy Electronic Mail Distribution Robert J. Duncan II, Vice President Nuclear Operations Progress Energy Electronic Mail Distribution Brian C. McCabe Manager, Nuclear Oversight Shearon Harris Nuclear Power Plant Progress Energy Electronic Mail Distribution

Terry Hobbs, Plant General Manager Crystal River Nuclear Plant (NA2C) 15760 W. Power Line Street Crystal River, FL 34428-6708

Stephen J. Cahill Director - Engineering Nuclear Crystal River Nuclear Plant (NA2C) Electronic Mail Distribution

R. Alexander Glenn, General Counsel Progress Energy Electronic Mail Distribution

Jeffrey R. Swartz Director Site Operations Crystal River Nuclear Plant Electronic Mail Distribution

Donna B. Alexander Manager, Nuclear Regulatory Affairs (interim) Progress Energy Electronic Mail Distribution Thomas Sapporito, Consulting Associate (Public Correspondence Only) Post Office Box 8413 Jupiter, FL 33468 William A. Passetti, Chief Florida Bureau of Radiation Control Department of Health Electronic Mail Distribution

Daniel R. Westcott, Supervisor Licensing & Regulatory Programs Crystal River Nuclear Plant (NA1B) Electronic Mail Distribution

Joseph W. Donahue, Vice President Nuclear Oversight Progress Energy Electronic Mail Distribution Jack E. Huegel Manager, Nuclear Oversight Crystal River Nuclear Plant Electronic Mail Distribution David T. Conley, Senior Counsel, Legal Department Progress Energy Electronic Mail Distribution Mark Rigsby Manager, Support Services - Nuclear Crystal River Nuclear Plant (NA2C) Electronic Mail Distribution Attorney General Department of Legal Affairs The Capitol PL-01 Tallahassee, FL 32399-1050 Bryan Koon, Director Florida Division of Emergency Management Electronic Mail Distribution Chairman Board of County Commissioners Citrus County 110 N. Apopka Avenue Inverness, FL 36250

FPC 4 Letter to Jon from George Hopper dated March 8, 2012.

SUBJECT: CRYSTAL RIVER UNIT 3 - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000302/2012007

Distribution w/encl:

C. Evans, RII EICS L. Douglas, RII EICS OE Mail RIDSNRRDIRS PUBLIC RidsNrrPMCrystal River Resource

Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION II

Docket No. 50-302 License No. DPR-72 Report No. 05000302/2012007 Licensee: Progress Energy (Florida Power Corporation)

Facility: Crystal River Unit 3 Location: Crystal River, FL Dates: January 17 - 20, 2012 January 30 - February 2, 2012 Inspectors: N. Staples, Senior Project Inspector, Team Leader R. Taylor, Senior Project Inspector S. Ninh, Senior Project Engineer N. Childs, Resident Inspector C. Rapp, Senior Project Engineer

Approved by: G. Hopper, Chief Reactor Projects Branch 7 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000302/2012007; January 17 - 23, 2012, and January 30 - February 2, 2012; Crystal River Unit 3; Biennial Inspection of the Problem Identification and Resolution Program.

The inspection was conducted by two senior project inspectors, two senior project engineers, and a resident inspector. No findings were identified. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process."

Identification and Resolution of Problems The inspectors concluded that, in general, problems were properly identified, evaluated, prioritized, and corrected. The licensee was effective at identifying problems and entering them into the corrective action program (CAP) for resolution, as evidenced by the relatively few number of deficiencies identified by external organizations (including the NRC) that had not been previously identified by the licensee, during the review period. Generally, prioritization and evaluation of issues were adequate, formal root cause evaluations for significant problems were adequate, and corrective actions specified for problems were acceptable. Overall, corrective actions developed and implemented for issues were generally effective and implemented in a timely manner.

The inspectors determined that overall; audits and self-assessments were adequate in identifying deficiencies and areas for improvement in the CAP, and appropriate corrective actions were developed to address the issues identified. Operating experience usage was found to be generally acceptable and integrated into the licensee's processes for performing and managing work, and plant operations.

Based on discussions and interviews conducted with plant employees from various departments, the inspectors determined that personnel at the site felt free to raise safety concerns to management and use the CAP to resolve those concerns.

REPORT DETAILS

4OA2 Problem Identification and Resolution

a. Assessment of the Corrective Action Program (CAP)

(1) Inspection Scope The inspectors reviewed the licensee's CAP procedures which described the administrative process for initiating and resolving problems primarily through the use of condition reports (CRs). To verify that problems were being properly identified, appropriately characterized, and entered into the CAP, the inspectors reviewed CRs that had been issued between April 2010 and February 2012, including a detailed review of selected CRs associated with the following risk-significant systems: Decay Heat (DH), Raw Water (RW), Spent Fuel Pool (SF), and Emergency Diesel Generators (EDGs). Where possible, the inspectors independently verified that the corrective actions were implemented as intended. The inspectors also reviewed selected common causes and generic concerns associated with root cause evaluations to determine if they had been appropriately addressed. To help ensure that samples were reviewed across all cornerstones of safety identified in the NRC's Reactor Oversight Process (ROP), the inspectors selected a representative number of CRs that were identified and assigned to the major plant departments, including operations, maintenance, engineering, health physics, chemistry, and security. These CRs were reviewed to assess each department's threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions. The inspectors reviewed selected CRs, verified corrective actions were implemented, and attended meetings where CRs were screened for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold.

The inspectors conducted plant walkdowns of equipment associated with the selected systems and other plant areas to assess the material condition and to look for any deficiencies that had not been previously entered into the CAP. The inspectors reviewed CRs, maintenance history, completed work orders (WOs) for the systems, and reviewed associated system health reports. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP. Items reviewed generally covered a two-year period of time; however, in accordance with the inspection procedure, a five-year review was performed for selected systems for age-dependent issues.

Control room walkdowns were also performed to assess the main control room (MCR) deficiency list and to ascertain if deficiencies were entered into the CAP. Operator Workarounds and Operator Burden screenings were reviewed, and the inspectors verified compensatory measures for deficient equipment which were being implemented in the field.

The inspectors conducted a detailed review of selected CRs to assess the adequacy of the root cause and apparent cause evaluations of the problems identified. The inspectors reviewed these evaluations against the descriptions of the problem described in the CRs and the guidance in licensee procedure CAP-NGGC-0205, "Condition Evaluation and Corrective Action Process." The inspectors assessed if the licensee had adequately determined the cause(s) of identified problems, and had adequately addressed operability, reportability, common cause, generic concerns, extent-of-condition, and extent of cause. The review also assessed if the licensee had appropriately identified and prioritized corrective actions to prevent recurrence.

The inspectors reviewed selected industry operating experience items, including NRC generic communications to verify that they had been appropriately evaluated for applicability and that issues identified through these reviews had been entered into the CAP. The inspectors reviewed site trend reports to determine if the licensee effectively trended identified issues and initiated appropriate corrective actions when adverse trends were identified.

The inspectors attended various plant meetings to observe management oversight functions of the corrective action process. These included the CAP roll-up meetings, Performance Improvement Oversight Committee (PIOC), and Work Oversight Committee (WOC) meetings.

Documents reviewed are listed in the Attachment.

(2) Assessment Identification of Issues The inspectors determined that the licensee was generally effective in identifying problems and entering them into the CAP and there was a low threshold for entering issues into the CAP. This conclusion was based on a review of the requirements for initiating CRs as described in licensee procedure CAP-NGGC-0200, "Condition Identification and Screening Process," management's expectation that employees were encouraged to initiate CRs for any reason, and the relatively few number of deficiencies identified by inspectors during plant walkdowns not already entered into the CAP.

Trending was generally effective in monitoring equipment performance. Site management was actively involved in the CAP and focused appropriate attention on significant plant issues.

Based on reviews and walkdowns of accessible portions of the selected systems, the inspectors determined that system deficiencies were being identified and placed in the CAP.

Prioritization and Evaluation of Issues Based on the review of CRs sampled by the inspection team during the onsite period, the inspectors concluded that problems were generally prioritized and evaluated in accordance with the licensee's CAP procedures as described in the CR severity level determination guidance in CAP-NGGC-0205, "Condition Evaluation and Corrective Action Process." Each CR was assigned a severity level at the PIOC meeting, and adequate consideration was given to system or component operability and associated plant risk.

The inspectors determined that station personnel had conducted root cause and apparent cause analyses in compliance with the licensee's CAP procedures and assigned cause determinations were appropriate, considering the significance of the issues being evaluated. A variety of formal causal analysis techniques were used depending on the type and complexity of the issue consistent with CAP-NGGC-0205.

Effectiveness of Corrective Actions Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that overall, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected and non-recurring. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence in that a review of performance indicators, CRs, and effectiveness reviews demonstrated that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to prevent recurrence (CAPRs) were sufficient to ensure corrective actions were properly implemented and were effective.

(3) Findings No findings were identified.

b. Assessment of the Use of Operating Experience (OE)

(1) Inspection Scope The inspectors examined licensee programs for reviewing industry operating experience, reviewed licensee procedure CAP-NGGC-0202, "Operating Experience and Construction Experience Program," reviewed the licensee's operating experience database to assess the effectiveness of how external and internal operating experience data was handled at the plant. In addition, the inspectors selected operating experience documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, vendor notifications, and plant internal operating experience items, etc.), which had been issued since December 2008 to verify whether the licensee had appropriately evaluated each notification for applicability to the Crystal River plant, and whether issues identified through these reviews were entered into the CAP. Procedure CAP-NGGC-0202 was reviewed to verify that the requirements delineated in the program were being implemented at the plant. Documents reviewed are listed in the Attachment.

(2) Assessment Based on a review of documentation related to the review of operating experience issues, the inspectors determined that the licensee was generally effective in screening operating experience for applicability to the plant. Industry OE was evaluated by plant OE Coordinators and relevant information was then forwarded to the applicable department for further action or informational purposes. OE issues requiring action were entered into the CAP for tracking and closure. In addition, operating experience was included in all root cause evaluations in accordance with licensee procedure CAP-NGGC-0202, "Operating Experience and Construction Experience Program."

(3) Findings No findings were identified.

c. Assessment of Self-Assessments and Audits

(1) Inspection Scope The inspectors reviewed audit reports and self-assessment reports, including those which focused on problem identification and resolution, to assess the thoroughness and self-criticism of the licensee's audits and self assessments, and to verify that problems identified through those activities were appropriately prioritized and entered into the CAP for resolution in accordance with licensee procedure CAP-NGGC-0201, "Self Assessment/Benchmark Programs."

(2) Assessment The inspectors determined that the scopes of assessments and audits were adequate. Self-assessments were generally detailed and critical, as evidenced by findings consistent with the inspector's independent review. The inspectors verified that CRs were created to document all areas for improvement and findings resulting from the self-assessments, and verified that actions had been completed consistent with those recommendations. Generally, the licensee performed evaluations that were technically accurate. Site trend reports were thorough and a low threshold was established for evaluation of potential trends, as evidenced by the CRs reviewed that were initiated as a result of adverse trends.

(3) Findings No findings were identified.

d. Assessment of Safety-Conscious Work Environment

(1) Inspection Scope The inspectors randomly interviewed 16 on-site workers regarding their knowledge of the corrective action program at Crystal River and their willingness to write CRs or raise safety concerns. During technical discussions with members of the plant staff, the inspectors conducted interviews to develop a general perspective of the safety-conscious work environment at the site. The interviews were also conducted to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns. The inspectors reviewed the licensee's Employee Concerns Program (ECP) and interviewed the ECP manager. Additionally, the inspectors reviewed a sample of ECP issues to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate.

(2) Assessment Based on the interviews conducted and the CRs reviewed, the inspectors determined that licensee management emphasized the need for all employees to identify and report problems using the appropriate methods established within the administrative programs, including the CAP and ECP. These methods were readily accessible to all employees. Based on discussions conducted with a sample of plant employees from various departments, the inspectors determined that employees felt free to raise issues, and that management encouraged employees to place issues into the CAP for resolution. The inspectors did not identify any reluctance on the part of the licensee staff to report safety concerns.

(3) Findings No findings were identified.

4OA6 Meetings, Including Exit

On February 2, 2012, the inspectors presented the inspection results to Mr. Jon Franke and other members of the site staff. The inspectors confirmed that all proprietary information examined during the inspection had been returned to the licensee.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

J. Agcoili, CAP Coordinator

T. Burnett, Performance Improvement Supervisor

S. Chapin, Emergency Preparedness Specialist

J. Curham, Fire Protection Program Manager

M. Danford, Corporate Fleet Manager

B. Gapp, Security Training Supervisor

C. Kish, Safe Shutdown Program Manager

S. McDaniel, Licensing Engineer

R. Murray, Work Control Superintendent

J. Payne, Operating Experience Coordinator

M. Rigsby, Site Support Services Manager

B. Taylor, EG System Engineer

K. Wilson, Licensing and Regulatory Programs Supervisor

NRC personnel

T.Morrisey, Senior Resident Inspector

G. Hopper, Chief, Branch 7, Division of Reactor Projects

LIST OF DOCUMENTS REVIEWED

Procedures

ADM-NGGC-0101, Maintenance Rule Program, Revision 22

ADM-NGGC-0117, Minor Maintenance, Revision 0

ADM-NGGC-0104, Work Implementation and Completion, Revision 40

ADM-NGGC-0116, Nuclear Planning, Revision 5

ADM-NGGC-0203, Preventive Maintenance & Surveillance Testing Administration Rev. 17

AI-511, Operations Department Work Control Center, Revision 5

CAP-NGGC-1000, Conduct of Performance Improvement, Revision 6

CAP-NGGC-0200, Condition Identification and Screening Process, Revision 34

CAP-NGGC-0202, Operating Experience and Construction Experience Program, Revision 20

CAP-NGGC-0205, Condition Evaluation and Corrective Action Process, Revision 14

CAP-NGGC-0206, Performance Assessment and Trending, Revision 6

CAP-NGGC-1000, Conduct of Performance Improvement, Revision 6

EGR-NGGC-0209, Buried Piping Program, Rev 3

EGR-NGGC-0010, System & Component Trending Program & System Notebooks, Revision 17

EMG-NGGC-1000, Fleet Conduct OF Emergency Preparedness, Revision 2

MNT-NGGC-1000, Conduct of Maintenance, Revision 7

OENP-29, Wire Number Assignment, Revision 1

OPS-NGGC-1305, Operability Determinations, Revision 4

Attachment

WCP-NGGC-300, Work Request Initiation, Screening, Priority and Classification, Revision 2

Condition Reports

Reviewed

00148225

00266356

279893

00286080

00309669

00316682

00341272

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00364258

00368082

00379036

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00396736

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00408032

00409263

00413261

00413523

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00414139

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00487068

00487174

00489931

00492058

00494845

00494856

00496442

00501732

00504214

00504630

00506777

Action Request

346859

348173

351549

354188

365957

386891

419400

432195

332465

335290

387720

441111

481126

Work Orders

01123267-02

01689724-01

01743074-01

01796772-01

01821163-04

01687556-01

01687556-03

01695431-01

01715713-02

01801212-01

01912354-01

01960799-01

01970108-01

01355909-01

01355909-02

01966816

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01159696

01749863

01764980

01886575

01901935

01972443

01981132

01986680

01999641

01981243

01940864

Attachment Self-Assessments

C-EP-11-01, Assessment of Emergency Preparedness, 2/22/2011

Other Documents

2009 - Spent Fuel Pool System Health Report 2010 - Spent Fuel Pool System Health Report 2011 - Spent Fuel Pool System Health Report 2011 - Emergency Diesel Generator System Health Reports 2010 - Emergency Diesel Generator System Health Reports

2009 - Emergency Diesel Generator System Health Reports 2011 - Raw Water System Health Report (3

rd quarter) 2011 - Buried Piping Program Health Report (3

rd quarter) Enhanced Design Basis Document For the Emergency Diesel Generator System, 2/28/90 Crystal River 3 Alternate AC Generator Preventive Maintenance Review SE11-0040, Maintenance Rule Expert Panel Meeting Minutes, 09/08/2011 SE11-0046, Maintenance Rule Expert Panel Meeting Minutes, 10/17/2011

EPSG-005, Maintenance and Distribution of Rosters and Directories, Revision 11 NCR Initiation Using the Kiosk,

SEC-LP-102, Revision 1

SP-354C, Functional Test of the Alternate AC Diesel Generator

EGDG-1C, Revision 13

MP-499, Filter Maintenance, Revision 37

EC 74541, Modify Design of

RWV-36 to Reduce Excessive Wear, Rev 0

2602.101-01, Calculation, Crystal River Nuclear Plant Buried Piping Program Basis Document, Rev 0

Drawings

FD-302-621, Spent Fuel Cooling, Sheet 1, Rev. 54

FD-302-621, Spent Fuel Cooling, Sheet 2, Rev. 24

FD-302-621, Spent Fuel Cooling, Sheet 3, Rev. 34

FD-302-281, Emergency Diesel Generator Compressed Starting Air and Engine Exhaust, Rev.3 P-304-724, Spent Fuel Pit Leak Chase Piping System, Rev. 4

S-521-110, Spent Fuel Pit Liner Plate Plans and Sections, Rev. 10

S-521-111, Spent Fuel Pit Liner Plate Sections, Rev. 5 S-521-112, Spent Fuel Pit Liner Plate Sections and Details, Rev. 9

Condition Reports

Generated

CR 513823, Lack of Documentation Rigor for OE Evaluations

CR 510193, Initiation of Anonymous CRs and WRs Process Need Improvement

CR 510172, During PI&R Inspection - NCR Kiosks Not Operational

CR 510547, During PI&R Inspection Inadequate Documentation of CAPR in

EMG-NGGC-1000

CR 513399, NRC PI&R Team Identified an Opportunity to Clarify NCON

456729

CR 514061, NRC PI&R Team Identified

CR431407 Cause and Effect Table Improvement

CR 513392, Calibration Gauge Block Standard Did not Meet Vendor Specification