ML20148E753
| ML20148E753 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 03/21/1988 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20148E750 | List: |
| References | |
| 50-302-87-27, NUDOCS 8803250306 | |
| Download: ML20148E753 (28) | |
See also: IR 05000302/1987027
Text
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ENCLOSURE
APPENDIX TO FLORIDA POWER CORPORATION
CRYSTAL RIVER UNIT 3
SALP BOARD REPORT NO. 50-302/87-27
(DATED NOVEMBER 20,1987)
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I. Meeting Summary
A. A meeting was held at 9:00 a.m.aon December 18, 1987, at the Crystal
River Nuclear Plant, in Crystal River, Florida, to discuss the SALP -
Board Report for the Crystal River Unit 3 facility.
B. Licensee-Attendees
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L. H. Scott, President and Chief Executive Officer
B. L. Griffin, Executive Vice President
W. S. Wilgus, Vice President, Nuclear Operations
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P. F. McKee, Director, Nuclear Plant Operations
E. C. Simpson, Director, Nuclear Site Support
R. C. Widell, Director, Nuclear Operations Engineering and Projects
E. E. Renfro,-Director, Nuclear Operations Materials and Controls
G. R. Westafer, Director, Quality Programs
The list of Licensee Attendees above does not include the large
number of FPC employees that were present at the SALP presentation.
The personnel were managers, supervisors, and various plant staf f.
This large turnout was beneficial to the SALP process and is highly
recommended for future presentations.
C. NRC Attendees
M. L. Ernst, Deputy Regional Administrator, RII
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L. A. Reyes, Director, Division of Reactor Projects (DRP), RII
H. N. Berkow, Director, Project Directorate II-2, Division of
Reactor Projects, Office of Nuclear Reactor Regulation (NRR)
H. Silver, Project Manager, Project Directorate II-2, NRR
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B. A. Wilson, Chief, Reactor Projects Branch 2, DRP, RII
T. F. Stetka, Senior Resident Inspector, Crystal River, DRP, RII
J. Tedrow, Resident Inspector, Crystal River, DRP, RII
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D. SALP Meeting Clarification
A clarification was requested concerning an improving trend in the
functional area of Radiological Controls that was noted during the
SALP presentation but was not reflected in the SALP report. The SALP
Board noted improvement in your perfnrmance in the recommendation
section but did not vote for an improving trend overall.
l E. SALP Meeting Slides
See Attachment 1
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II. Errata Sheet - Crystal River SALP ,
PAGE LINE NOW READS SHOULD READ
11 29-35 However, the' licensee In addition, in
had not provided a response to SG0G
management' level commitment inititives the-
... to implement the SG0G- licensee ... towards
criteria. full implementation of
the SG0G criteria.
BASIS FOR CHANGE: To clarify that the licensee responded appropriately
to SG0G recommendation and issued a corporate
management level policy statement .in May 1987
concerning the implementation of SGOG criteria.
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III. Licensee Comments
Licensee comments submitted in response to the SALP Board Report follow.
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without the technical base provided by an. cademically trained
chemist. To provide additional superviso y coverage, a third
laboratory supervisor had been added to nage chemistry control
on back shifts.
During the fifth fuel cycle, the licensee continued to
experience difficulties with chem try and oxygen control
because of inleakage of air and sa ine water into the secondary
cooling system and because of tra port of corrosion products to
the once-through-steam generator (OTSG). Although the licensee
had attempted to eliminate b ckage of tube-to-tube sheet
broached holes by a "slap-cle ing" procedure at the end of the
fourth fuel cycle, the unit continued operations load limited
in the fifth fuel cycle bec use of this problem. This cleaning
procedure is scheduled to repeated during the fifth refueling
outage. These actions ar an indication of improved management
attention to the need fo enhanced chemistry controls.
The licensee was con inuing to address the multiple problems
associated with the SG through the OTSG Task Force. This Task
Force was made up engineers from several disciplines and had
been given lead esponsibility for recommending means and
priorities for ac feving efficient operation of the OTSGs.
Additional res ictions have been placed on chemistry control by
the use of c per alloy tubes in the main condenser. The main
condenser ws also being degraded through galvanic and
microbiolo cally-induced corrosion mechanisms. These problems,
as yet, h not caused a plant shutdown.
The ch istry control implementing procedures were revised to
inclu the technical guidelines developed by the Steam
Gener tors Owner's Group (SGOG). However, the licensee had not
pro ded a management level commitment of policy statement to the
fa ility enclosing the SG0G guidelines as a priority for all
f cility organizations. Such a policy statement is recommended
y the SG0G to establish as a company policy and priority the
need for all components in the organization (not ,just the
chemistry organization) to work to implement the SG0G criteria.
Improvements in the responsiveness to NRC initiatives and
aggressiveness in addressing radiation control problems have
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y been noted during the SALP period. For example,
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state-of-art whole body friskers (PCM-l's) and whole body
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&g counters have been obtained for use at the facility.
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l [ protection programs were found to be adequate. The licensee has
l upgraded their RWP program since the previous assessment period
& to provide for revising RWP's to address change of work
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conditions after a RWP had been issued.
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without the technical base provided by an academically trained
chemist. To provide od.di ti onal supervisory coverage, a third
laboratory supervisor had been added to manage chemistry control
on back shifts.
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During the fifth fuel cycle, the licensee continued to
experience difficulties with chemistry and oxygen control
because of inleakage of air and saline water into the secondary
cooling system and because of transport of corrosion products to
the once-through-steam generators (OTSG). Although the licensee
had attempted to eliminate blockage of tube-to-tube sheet
broached holes by a "slap-cleaning" procedure at the end of the
fourth fuel cycle, the unit continued operations load limited
in the fif th fuel cycle because of this problem. This cleaning
procedure is scheduled to be repeated during the fif th refueling
outage. These actions are an indication of improved management
attention to the need for enhanced chemistry controls.
The licensee was continuing to address the multiple problems
associated with the OTSG through the OTSG Task Force. This Task
. Force was made up of engineers from several disciplines and had
been given lead responsibility for recommending means and
priorities for achieving efficient operation of the OTSGs.
Additional restrictions have been placed on chemistry control by
the use of copper alloy tubes in the main condenser. The main
condenser was also being degraded through galvanic and
microbiologically-induced corrosion mechanisms. These problems,
as 'yet, had not caused a plant shutdown.
The chemistry control implementing procedures were revised to
include the technical guidelines developed by the Steam
Generators Owner's Group (SG0G). In addition, in response to
SG0G initiatives the licensee endorsed a policy in May 1987
establishing a need for all entities in the organization (not
just the chemistry organization) to work' toward full
implementation of the SG0G criteria.
Improvements in the responsiveness to NRC initiatives and
aggressiveness in addressing radiation control problems have
been noted during the SALP period. For example,
state-of-art whole body friskers (PCM-l's) and whole body
counters have been obtained for use at the facility.
The licensee's radiation work permit (RWP) and respiratory
protection programs were found to be adequate. The licensee has
upgraded their RWP program since the previous assessment period
j to provide for revising RWP's to address change of work
' conditions after a RWP had been issued.
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IV. NRC Response to Licensee's January 18, 1988 Specific Written Comments
The NRC has reviewed your letter dated January 18, 1988, concerning the
NRC Systematic Assessment of Licensee Performance (SALP) for Crystal River
Unit 3, .and acknowledges your comments.
A review of the ratings for the Training and Emergency Planning areas was
conducted. Your January 18, 1988, letter requested re-evaluation of the
Emergency Planning area based on your belief that both Training and
Emergency Planning were penalized for deficiencies in the emergency
response team training area. You indicated it appeared appropriate that
the training aspects of Emergency Planning be included in the SALP section
for training, not in the Emergency Planning Section. As stated in the
subject SALP report, one negative finding ,<as indeed that training was a
cause of less than acceptable demonstration of capabilities. This lack of
training contributed to your level of performance during emergency
exercises. This performance led to the SALP classification of Category 2.
It is our position that performance in a SALP area will be evaluated as
part of the area even though training is a direct contribution of
performance. Training in each functional area is reviewed to determine an
overall SALP category for training.
This rating reflected the significant improvements in training over the
previous SALP 3 rating. Additionally, the Emergency Planning training
deficiencies were not evaluated or included in the SALP Board's evaluation
of the Training and Qualification Effectiveness area.
Your continued commitment to improving the areas of training procedural
adequacy and adherence to procedures should result in improvements in
overall plant operations.
Our assessment of your plant chemistry program relating to staff resources
was based on the fact that the assignment of the nuclear chemist to the
OTSG task force was for the duration of the task force (which was expected
to be at least several months) and that the nuclear chemist had few
opportunities to participate in activities relating to the routine plant
chemistry operations. This depleted the chemistry staff of the only
academically trained chemist available to the Nuclear Chemistry Manager to
control plant chemistry in a manner recommended by the SGOG.
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UNITED STATES .
NUCTRAR REGUIATORY .
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1. JEA" Y TOS N CEASEE >ERIORVANCE
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2. ? ROV J E A 3AS S L70R A__0CA"O \
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PERFORMAXCE AXALYSIS AREAS
FOR OPERATIXG REACTORS
1. PLANT OPERATIONS
2. RADIOLOGICAL CONTROLS
3. MAINTENANCE
4. SURVElLLANCE
5. FIRE PROTECTION
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8. OUTAGES
9. QUAUTY PROGRAMS
10. LICENSING ACTIVITIES
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11. TRAINING
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ARE AGGRESSNE AND ORIENTED TOWARD NLCLEAR .
SAFETY; UCENSEE RESOURCES ARE Artf AND
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EFFECTNELY USkD SUCH THAT GH EVEL A OF
PERFORMANCE WITH RESPECT TO OPERATIONAL
SAFETY OR CONSTRUCT!0N IS BEING ACHOED.
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EVAILATION CRITERIA
1. MANAGEMENT INVOLVEMENT IN ASSURING
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2. APPROACH TO RESOLUTION OF TECHNICAL I
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FROM A SAFETf STANDPOINT
3. RESPONSIVENESS TO NRC INITIATIVES
4. ENFORCEMENT HISTORY
5. REPORTING AND ANALYSIS OF REPORTABLE E
6. STAFFING (INCLUDING MANAGEMENT)
7. TRAINING EFFECTIVENESS AND QUAUFICATION
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VOXON S VVARY
PL :', :.986 - AUGUS" 3:.',1987
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SEVERITY LEVEL l ll Ill IV V
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CRYSTAL RIVER 0 0 1 42 4
REGION 11 AVE 0 0 3 16 5
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ALLEGATIONS PER UTILITY / SITE ~
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Power
connoaatio=
January 18, 1988
Dr. J. Nelson Grace
Regional Administrator, Region II
U. S. Nuclear Regulatory Commission
101 Marietta St. N. W., Suite 3100
Atlanta, Ga 30323 ,
Subject: Crystal River Unit 3
Docket No. 50-302
Operating License No. DPR-72
Systematic Assessment of Licensee Performance (SALP)
Inspection Report 87-27
Dear Sir:
The attachment to this letter provides Florida Power Corporation's
(FPC's) detailed response to the subject inspection report.
At the on-site SALP presentation Mr. L. H. Scott, President and
Chief Executive Officer of Florida Power Corporation, mentioned, it
- is human nature to believe one deserves a higher grade when one's
performance is evaluated. However, if the nuclear industry is to
reach the performance levels we all demand, we must look at all the
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data available and learn how to improve. We believe the most recent
SALP of Crystal River 3 (CR-3) is an excellent opportunity for
developing strategies for CR-3 to become what we believe it can be,
a consistently safe, well managed, vital part of Florida's electric
energy supply. We were especially pleased to receive recognition
for improving our communication with your staff. This is not by
accident, but is an integral part of our current management
direction. We believe our staff's continued efforts, as well as
those of your own, will' produce a professional, meaningful and
mutually beneficial dialogue and trust as we face future
challenges.
na 1 . ~ rJ m at [bo \ __
vvyle' q v (" u lI '
A Florida Progress Company
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Dr. J. Nelson Grace
Regional Administrator, Region II
U. S. Nuclear Regulatory Commission
Page 2
overall, we believe the SALP ratings were generally fair and
accurate. In the attached discussion we hope to address some
apparent misconceptions and to document our own self-assessment.
These comments are an integral part of the Nucleaf Operations
Department goals for 1988 and beyond. We welcome further feedback
from your office or staff and hope the attached comments serve to
underscore our commitment to excellence.
Sincerely,
MI
Walter S. Wilgu
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Vice President ( .
Nuclear operations
WLR: mag
Attachment
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OVERALL EVALUATION
FPC agrees procedural adequacy and adherence is the single largest
opportunity for improvement department-wide. In addition, we agree
that supervisory review of completed procedures is a concern and we
will continue to address this area. We do not perceiv6 that "trying
harder" will suffice, although we will continue to strive to do just
that. In addition, we will look broadly at our approach to
proceduralization of work activities in our efforts to find
additional ways to improve. We expect your staff to be a good
source for proven programs and innovative ideas, as well as a
supporter for any changes to licensed programs needed to facilitate
this improvement. In the next several months, we will be putting
together a plan for addressing this situation. We look forward to
meeting with you to share these ideas and strategies.
In certain limited areas of contractor control we agree with your
assessment. We do not believe contractor control is as broad a
problem as you imply. You reference the In-service Inspection /In-
service Testing (ISI/IST) area as an example. The ISI/IST program,
supported principally by Babcock & Wilcox (B&W), was largely managed
by B&W with inadequate input from FPC. Even though few, if any, of
the identified nonconformances were directly a result of B&W
activities, we agree FPC should exert more effective contractor
control in this area. FPC's second ten year program will be managed
by FPC. We will be sharing with you in coming months the plans we
have for ISI/IST management improvements. Since this is the
beginning of our second ten year interval, it affords an excellent
opportunity for improvements in this area.
PLANT OPERATIONS
We share your concern regarding operator overtime. We believe we
can and must succeed in reducing overtime levels. We are encouraged
that the staff's efforts to refocus NRC administered
requalification exams appears to be directed to relieve any
unnecessary additional stress. If enough operator licenses are
obtained by the additional operators currently being tested by the
NRC, FPC will initiate a six-shift rotation. This, in turn, will
reduce operator overtime.
RADIOLOGICAL CONTROLS
We agree the adverse trend in this area noted in the previous SALP
has been reversed. Some confusion existed at the presentation as to
whether you intended to note an improving trend. We believe one is
present and we will endeavor to further enhance this area so that no
confusion will exist at the end of the present SALP period.
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The comment in your report regarding transfer of an academically
trained chemist appears misleading. This was a temporary assignment
and did not adversely affect our chemistry section long term. In
fact the support available to chemistry has been generally improved.
The once Through Steam Generator (OTSG) task force includes a
degreed Chemical Engineer, who is pursuing certification as a
Corrosion Engineer. Several other organizations within Nuclear
operations contain support personnel with extensive chemistry
backgrounds. Further, you noted the absence of a management level
commitment or policy statement associated with the Steam Generator
owners Group (SGOG) guidelines. Such a policy was endorsed by
management in May 1987. We apologize for our apparent failure to
keep you well informed in these areas.
MAINTENANCE
FPC appreciates the continuing positive assessment of Maintenance by
the NRC. The efforts of numerous individuals, on the plant staff
and within other support groups on-site and at the corporate
headquarters, combined to make this achievement possible.
SURVEILLANCE
The SALP Report noted a declining trend of performance in
surveillance activities. The SALP Report noted eleven violations
and one deviation in the surveillance area during the evaluation
period. We are in agreement that this area warrants our particular
attention for 1988 and beyond. We will attempt to clarify those
areas that we believe warrant increased attention. The following
paragraphs also comment specifically on each of the deficient areas
mentioned in your report and present FPC's plan for improvements in
these areas.
1. Surveillance Schedulina
Two of the violations mentioned were a result of scheduling
deficiencies. Several months ago the responsibilities of the
Technical Specifications coordinator were realigned as a result of
FPC's awareness of this problem. The position has been reassigned
to the operations Planning Section to bring the function
organizationally closer to the plant staff who perform most of the
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surveillances. The single responsibility of the Coordinator and
associated clerical support is now surveillance Scheduling, other
previous job responsibilities have been reassigned.
In addition, a new computerized Surveillance Tracking System was
implemented during Decembt ' 1987. This system is now being refined
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and utilized as the primary means of scheduling and tracking
l surveillance procedures. With the implementation of this new
system, FPC will be able to more closely monitor and schedule
surveillances. Thus, the chances of missed or overlooked
requirements will be greatly reduced.
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Finally, FPC plans to pursue some clarification of, or changes to,
certain Technical Specification Requirements, including Technical
Specification 4.0.2, which will simplify the scheduling process.
2. Procedural Adeauacy
The report noted four violations and several Licensee Event Reports
(LER's) which identified surveillance procedures which were
determined to be inadequate in implementing requirements, or were so
poorly written so as to impede successful accomplishment of the
procedure.
The SALP Board concluded these deficient procedures were the result
of "inexperience of the engineering staff" and writing procedures
"with little or no input from the field organizations". FPC
be'.'. eves this has been corrected. FPC has adopted a "system
angineer" concept which will identify a single point of contact,
develop expertise, and instill a "pride of ownership" in all aspects
of operations, testing and maintenance. This same concept is being
applied in areas other than engineering for individuals responsible
for various aspects of system maintenance and testing. In
addition, new surveillance procedures not performed by the
organization who writes the procedure, will be walked through on a
dry run with the organization who will perform it prior to issuance.
The writing organization will also perform field validation with the
organization performing it.
In addition, FPC has developed a Surveillance Procedure Verification
and Validation Program. This program will confirm the technical
adequacy of surveillance procedures and ensure that surveillance
procedures not performed by the organization responsible for it will
be field validated at least once and re-validated after a major
technical rewrite. FPC has also developed an INPO accredited
Engineering Training Program to enhance the engineer's overall
understanding of CR-3 plant systems and operations.
We believe the processes described above to be a strength and what
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you saw as a weakness was the growing pains of initiating a new
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technique. We plan to keep the resident NRC inspectors informed of
our progress with these new concepts and programs.
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3. Surveillance Procedure Adherence
The report noted three vi'olations relating to lack of adherence to
surveillance procedures. In addition to the areas described in the
Overall Evaluation section, the Director of Nuclear Plant Operations
meets with Plant Superintendents each month and reviews each
department's procedure adherence problems with proposed corrective
actions. This is done to stress the high management concern with
procedure adherence. This group also reviews the actions to improve
procedures in progress to ensure they are accomplishing what is
expected. We agree supervisory review of completed procedures is
also a concern and we "ill continue to address this area. Many
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in,itiatives are in progress and, as we improve, we may discontinue
some initiatives and add others. We plan to keep the resident NRC
inspectors informed of our on-going programs.
4. In-Service Insoection and Testina Procrams
The report noted a weakness associated with the overall management
of FPC's in-service inspection and in-cervice testing programs.
Three violations in this area were mentioned. The overall
management of FPC's in-service inspection program is under review
and the following actions are being taken:
o The position of Nuclear Technical Support Superintendent
was previously used to manage the OTSG Integrity Section
and the In-service Inspection Section. The OTSG Integrity
Section is now reporting to another manager thereby
allowing the Nuclear Technical Support Superintendent to
devote 100% of his time to ISI management issues.
o The ISI Section which presently consists of three employees
will be expanded to five employees, thereby reducing its
dependence on contractors.
o The overall administrative contro) for In-service
Inspection is presently being complet( .y rewritten. The
objective of the re-write is to strengthen the controls
over our ISI programs.
o In addition to the re-write of AI-701, Conduct of In-
Service Inspection, eight stand-alone ISI related program
documents are under development. These include: NDE
Program, Repair and Replacement Program, Pump and Valve
Program, Eddy Current Test Program, Hydro Program,
Surveillance Capsule Program, Snubber Program, and Leak
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Rate Test Program.
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During 1988 FPC will begin a program to ensure ISI commitments are
properly addressed in FPC's Nuclear Operations Commitment System.
The issue of contractor control was discussed in the overall
Evaluation section.
, FIRE PROTECTION
l We agree with the assesstient by the SALP Board in this area. We
would add that the efforts of Licensing, Engineering, Site Nuclear
. Services, Operations, Maintenance, and Construction were
l instrumental in the Appendix R compliance effort.
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EMERGENCY PLANNING
As we read your current and past assessments in the area of
Emergency Planning, and having listene'd to your discussion of this
category at the SALP meeting, we respectfully request re-evaluation
of this category to a SALP 1 rating. From our understanding, we did
not receive a "1" in Training and Emergency Planning due to Team
Training deficiencies. We believe it is unfair and misleading to
penalize hgih categories for deficiencies in this area. Since
Emergency Planning has been highly regarded in the past, we
sincerely believe this category should be given a Rating of 1 for
this SALP period.
SECURITY and SAFEGUARDS
We agree with your assessment of the progress made to date, and with
the opportunity and need for continued improvement.
OUTAGES
We agree with your assessment, especially, as it relates to short
forced outages and longer outages driven by modifications. A major
focus in 1988 vill address lessons learned from the recontly
completed refueling outage. We believe this will go a long way
toward improving FPC's performance in this area.
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QUALITY ASSURANCE and ADMINISTRATIVE CONTROLS AFFECTING OUALITY
We are in agreement with your assessment of this area including
strengths and weakness listed.
LICENSING ACTIVITIES
We agree with your overall assessment of Licensing as supported by
related engineering efforts.
The LER assessment provided by AEOD was very helpful. Even though >
we are ranked in the top 10-15% we have taken the constructive
l criticism, as well as the other assessment guidelines, and
l Implemented a review guide for LER's.
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We believe we have been effective in improving communication with
the staff and our plans to develop resolution strategies for all
outstanding items have been well received by the staff. We look
forward to continued improvement in this area.
TRAINING AND OUALIFICATION EFFECTIVENESS
We are in agreement with your assessment. We will continue to
analyze our performance and make improvements in all areas of
Training whenever an opportunity exists to do so.
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CONCLUSION
Although we have provided some different perspectives in several
areas which will help make the record more accurate, we do agree
with your overall assessment of our performance, with the exception
of Emergency Planning, which we believe to be more properli assessed
as a category 1.
We commend you on the open dialogue we have had on the SALP process
via the American Nuclear Society's Utility /NRC Interface Workshops
and believe the staff is contemplating many potentially significant
improvements in this assessment system. Additionally, we wish to
commend you and offer our support of the new concept you have
initiated of holding the SALP review meetings at the Plant Site and
encouraging large attendance of utility personnel at these meetings.
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