IR 05000302/1985003
| ML20128A306 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 05/30/1985 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20128A295 | List: |
| References | |
| 50-302-85-03, 50-302-85-3, NUDOCS 8507020623 | |
| Download: ML20128A306 (3) | |
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May 30, 1985 ENCLOSURE APPENDIX TO FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 SALP BOARD REPORT (Dated March 5, 1985)
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fg7020623850530 G ADOCM 05000302 PDR
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May 30, 1985 I. MEETING SUMMARY A meeting was held at 1:00 p.m. on March 12, 1985, at Florida Power Corporation's St. Petersburg, Florida corporate offices to discuss the SALP Board Report for the Crystal River facilit Licensee Attendees:
L. H. Scott, President B. L. Griffin, Exective Vice President W. S. Wilgus, Vice President, Nuclear Operations M. H. Kleinman, Vice Chairman, Nuclear General Review Committee E. M. Howard, Director, Site Nuclear Operations E. E. Renfro, Director, Nuclear Operations, Material and Control E. C. Simpson, Director, Nuclear Operations, Engineering and Licensing J. T. Telford, Director, Quality Programs R. P. Blush, Director, Public Information G. R. Westafer, Manager, Nuclear Licensing and Fuel Management P. F. McKee, Nuclear Plant Manager G. L. Boldt, Nuclear Plant Operations Manager V. R. Roppel, Nuclear Plant Engineering and Technical Manager J. Alberdi, Manager of Site Nuclear Operations Technical Service NRC Attendees:
J. A. 01shinski, Deputy Regional Administrator, Region II (RII)
V. L. Brownlee, Chief, Reactor Projects Branch 2, Division of Reactor Projects, RII D.'L. Ziemann, Chief, Procedures and Systems Review Branch, Division of Human Factors Safety, Office of Nuclear Reactor Regulation T. F. Stetka, Senior Resident Inspector, Crystal River, RII J. E. Tedrow, Resident Inspector, Crystal River, RII
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2 May 30, 1985 II. LICENSEE COMMENTS Licensee coments submitted in response to the SALP Board Report follo _
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- 1. 7 : 51 Power CORPOR ATION April 11,1985 3F0485-09 Dr. 3. Neison Grace Regional Administrator, Region II Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, GA 30323 Subject: Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 IE Inspection Report No. 85-03 Systematic Assessment of Licensee Performance
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Dear Sir:
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Florida Power Corporation (FPC) provides the attached as our response to the subject inspection report. We also wish to make some generic comments regarding the Systematic Assessment of Licensee Performance (SALP) program in general
! and the recent review of Crystal River 3 (CR-3).
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It is our opinion that the report is developed out of isolated events which give an -
Inaccurate perspective in many of the categories. In many cases, the items used as a basis for the evaluation were misleading. The events or violations cited do not reflect programmatic or management problems, but in most cases represent-individual instances of personnel errors or minor procedural deficiencies and focus-on old violations or other issues that have little or no significance to current program Many of the specific items were not a valid measure of the management effectiveness or operational safety achieved over the period. As an example, it is inappropriate to include in the report a violation that identified a thermometer in the control room measuring ambient air temperature which was overdue for calibration and ignore the strides made during the period by management in improving the calibration facilities, organizational changes affecting the calibration laboratory management, and assuring that critical safety-related instrumentation is properly calibrate * 4 [ f -, & r n }
w t- DW.V(b Yh y
G EN ERAL OFFICE 3201 Thirty-fourth Street South e P.O. Box 14042, St. Petersburg, Florida 33733 e 813-8165151
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l 3F0485-09 Page 2 It appears to us, that the SALP report totally ignores the remarkable improvement that has been made at CR-3 in management effectiveness, operational proficiency, dedication to safety and security and professional excellence, and rather, concentrates on a few isolated items having minor safety significance. While other peers in our industry, both private and Federal, hold CR-3 as a prime example of how a single nuclear unit utility can achieve excellence, the SALP report provides an image of mediocrity and in some cases " poor" performance. We do not believe
, that such treatement is deserved nor does it reflect favorably on the industry and the SALP process.
i It is clear from the report that the assessment, contrary to the stated limitations, was not based entirely on activities which occurred during the report period. A training inspection which occurred after the report period was mentioned once in the cover letter and three times in the report. Section G.1 of the report cited a
- " Severity Level III violation and associated civil penalty" as one of the bases for
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rating security as Category 3. FPC has challenged the severity level of this violation and the civil penalty. Evidence has been docketed which demonstrates that this violation was improperly classified. No mention was made in the report of the fact that this matter is still under NRC review. The report did note, i however, "an apparent improvement in management support of the security
- program" which occurred during the report period but gave no credit for it. Thus, it seems that negative events can be considered even if they do not occur during the report period, but some positive events may not be considered even if they do.
l FPC believes that the items presented in the report do not justify the performance ratings given or that any reasonable rationale for such ratings exists. The trends indicated in the report seemed ambiguous and contradictory, with no clear -
explanation, when compared to the previous SALP report. Publishing such e report without opportunity for even cursory commentary by the licensee before publication is fraught with opportunity for erro It is our understanding that the SALP report has already been placed in the Public Document Room (PDR). The submittal of the report to the PDR prior to receipt and resolution of FPC's comments is in FPC's opinion a poor practice. Media interest in the problems of the nuclear industry can only be dealt with fairly when they receive both sides of the story at the same time. The NRC should make a better effort in trying not to detract from the image of nuclear power in the United States as a safe, reliable and economical source of energy. Giving the media mediocre report cards to plants that have been performing well can only help to destroy the industry in the longer ter .
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May 30, 1985 39g3 3F0483-09 .
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In conclusion, we believe that this report is not a fair assessment of FPC's performance during the report period in all areas. We believe that examination of the positive evidence available as well as the negative evidence would have resulted in a more balanced and realistic picture of FPC performanc
Sincerely,
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W. S. Vilgus Vice President Nuclear Operations
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AEF/feb Attachment
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- May 30, 1985 ENCLOSURE
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I FLORIDA POWER CORPORATION REPORT NO. 50-302/83-03 (5 ALP) RESPONSE IV - PERFORM ANCE ANALYSIS PLANT OPERATIONS (CATEGORY 2)- COMMENTS
" The alleged Instance of inadequate control of plant operations involving containment internal pressure has been misrepresented in our view. The July 1983 to March 1985 operating cycle was the first major
operating period conducted subsequent to NRC direction to cease continuous purging of the containment atmospher Upon l reconstructing this event, it can be seen that containment internal
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pressure will routinely increase and stabilize at 1 to 1.5 psig due to reactor coolant system heatup from Mode 5 (less than 2000F) to Mode 1 (5790F average Reactor Coolant System temperature and 6000F
, main steam temperature) with the containment " bottled up" in
compliance with technical specifications. If the plant is returned to
! service during the winter months, subsequent seasonal changes can i
cause containment pressure to app oach the two (2) psig alarm
, setpoint. It was found that starting an extra Reactor Building fan i cooler or shifting cooling water supplies in order to increase (maximize) containment cooling had little impact on reducing pressure.
- This event can be discussed in greater detail, but the point we wish to i make is that this event resulted from an inherent problem stemming from the NRC requirement to cease continuous purging, and was not
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L caused by " inadequate control of plant operations because timely action was not taken to maximize containment cooling". It should also be pointed out that the NRC had previously approved the same corrective action immediately upon restart of Cycle . -- The reference to moderate turnover of non-licensed operators and the effect it "might" have on the licensed operator program or future manpower shortages appears to be purely speculative and, therefore,
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has no place in a performance revie ~
l The comments on licensed operator training program documentation are in reference to an assessment made outside the period covered by
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this report and should not have been included.
l RADIOLOGICAL CONTROLS (CATEGORY 2)- COMMENTS
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The rating, Category 2 and constant, does not appear consistent with the discussion, considering that the area was rated Category 1 in the last SALP
. report. While this category received a constant rating, we feel that the
strides made in ALARA, waste treatment, and radiological performance,
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May 30, 1985
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i both on-site and off-site, have been significant. With the exception of training program for Chemistry personnel, this category is vastly improved overall, and we firmly believe that an " improving" rating was warrante MAINTENANCE (CATEGORY 1)- COMMENTS No comment ! SURVEILLANCE (CATEGORY 3)- RESPONSE Surveillance Procedure
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) Florida Power Corporation believes our surveillance program is much better i than the category 3 rating implies. The SALP report does not reflect the improvements that were made during the evaluation period. An in-depth review of the technical adequacy of SPs was made during the period to ensure that all technical specification surveillance requirements were correctly referenced and satisfied within each procedure. This effort utilized three plant staff engineers, as well as representatives from Quality Programs and Licensing, and resulted in several procedure revisions. The violations referenced in the report are primarily administrative errors, do _
, not represent any true safety significance, and do not indicate a declining trend of performance in this area.
Program Improvements (Corrective Action)
Since the evaluation, several actions have been taken to improve the
- surveillance program. An SP writer's guide has been implemented to ensure
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consistency of format and technical adequacy through an extensive checklist
- for use during procedure revisions and biennla! review. In addition, much of the writer's guide is devote'd to the proper implementation of human factor
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guidelines in the surveillance procedure As mentioned in the SALP report, responsibility for SPs is assigned to the plant Engineering and Technical Services department. Each plant engineer is responsible for a number of SPs consistent with plant system assignment .
. Since October of 1984, each engineer has been required to perform a field j validation of any surveillance procedure which undergoes a significant j revision. This validation includes " hands-on" performance /walkdown of the i _ procedure with the appropriate end user (I&C technician, mechanic,
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electrician, operator), and any identified problems / comments are resolved prior to final issue of the procedure. In addition, personnel from Operations and Maintenance are identified to review proposed revisions as part of the review process before the validation takes place. As a further check to enhance the quality of SPs, a program is being estab!!shed for walkdowns of selected SPs by key management personnel on a continuing basis.
l The method of issuing new procedures and revising existing procedures has also been improved. A paralk! review process is being established along
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May 30, 1985 with o trccking progrcm f:r procedure status during revision and quick 2r -
turnaround from document control. This new system will be very effective
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in timely issue of new/ revised procedures. In addition, procedures are annotated to indicate implementation of NRC actions during the review
, process and are tracked by a computerized tracking system to ensure due dates are me i
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Microfilm Records Florida Power Corporation disagrees with the NRC opinion expressed in this
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area. Nuclear operations procedure NOD-04 specifies the standards for hard i copy documents to be microfilmed. The CR-3 film process meets or
- exceeds all applicable ANSI standards for film quality density resolution, visual page to page, overall film quality, and archival quality. Occasionally, some difficulty in legibility has occurred, as a result of source document
quality. As a part of a continuing effort to eliminate this problem, a training video presentation is being prepared.
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! Inservice Testing (IST) of Pumps and Valves The summary listing of the status of the IST of oumps and valves was established in February 1985.
i Secondary Water Chemistry Programs The secondary chemistry at CR-3 has consistently exceeded the recommendations in the " Steam Generator Owners Group /EPRI" guidelines, i as seen in the graphs of secondary chemistry parameters (See Attachment A). The virtual absence of primary to secondary leakage in CR-3 steam generators attests to a very effective water chemistry program. EPRI .
guidelines for parameter limit actions and monitoring requirements are being evaluated.
l Although we have not experienced " continual failure of CuNi condenser 4 tubes" as stated in the report, several programs have been instituted to
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minimize condenser in-leakage problems. A policy specifying strict action '
- levels for salt water in-leakage has been in use for nearly two years and CR- -
l 3 staff personnel are well trained in its application. Our technicians can i readily determine whether leakage is from a condenser tube or from the tube to tubesheet interface and locate it for repair. We have also applied an
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epoxy coating that has been very effective in sealing tube to tubesheet
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leakage. For longer range planning, a condenser study is being conducted to l Identify a replacement tubing material if and when retubing becomes necessar The concern with the rapid depletion of the condensate demineralizing system resin has been resolved. Extensive testing of the resin indicated existing resin fines upon receipt." Florida Power Corporation created a
- purchase specification with more stringent requirements which is becoming
, a model for the industry, as evidenced by inquiries and copy requests from
- other utilitie i
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. An aggressive program to solve the once through steam generator (OTSG) debris buildup problem was launched in early 1983 with the formation of the OTSG Task Force. This is a full-time group composed of several multidisciplined Florida Power Corporation engineers and technicians. It is augmented by operations and technical support staff, as well as technical assistance from the OTSG vendor and a highly respected consulting firm. We are attacking this problem on several fronts: Florida Power Corporation will bore two inspection ports to the secondary side of the "A" OTSG during Refuel V. These inspection ,
ports will allow characterization of the type and composition of the flow blockage debris. This will be accomplished with state-of-the-art fibroscopic video and mechanical equipmen . A hydraulic cleaning method will be used during Refuel V to remove deposits in both OTSG's. This method was developed with the participation of Florida Power Corporation and truly represents the leading edge of technology in this field. The success of this project has already been demonstrated at another utility with on-site, hands-
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on, participation by Florida Power Corporation engineer . An extensive secondary system study was performed during 1984 to determine all potential sources of oxygen, silica, iron, and copper in
- our feedwater system which may affect the deposition rate in the i
OTSG. Several plant improvements have resulted:
. Several condenser air in-leakage paths have been identified for
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repair during Refuel .
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. Secondary system pH has been increased since initial startup, resulting in a 60% reduction in iron deposition rate as measured by an Integrated sampl . Amerzine addition to the condensate storage tank is used to deoxygenate water used for condensate makeup and emergency feedwater suppl . We are planning to replace secondary in-line monitors (O2 , PH,
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conductivity) with better equipment and add in line ion
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chromatography and a total organic carbon analyzer within the
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next yea . Long term planning includes involvement with chemical cleaning
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technology should that become necessary at a later time.
l In summary, Florida Power Corporation believes we have a very effective i
overall surveillance program and will continue to give management attention to improvement. One of our primary objectives for the next SALP
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evaluation period will be to create a heightened awareness within the NRC of the improvements and positive results of our surveillance progra i l
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May 30, 1985 l - FIRE PROTECTION (NOT RATED)- COMM,ENTS No comment EMERGENCY PREPAREDNESS (CATEGORY 2)- COMMENTS Present emphasis in the area of Eniergency Preparedness will correct noted deficiencie SECURITY (CATEGORY 3)- RESPONSE We are very disappointed with your decision to rate Security as a Category It is our feeling that the overall program and the efforts toward improvement are deserving of a higher rating.
We are concerned, following evaluation of your SALP report, that the i proposed Severity Level III Violation may have unjustly influenced your overall assessment of our Security Program resulting in the Category 3
< rating. As you are aware, FPC does not agree with such a severity level for i the identified violations. Consequently, we have formally requested that such violations be downgraded to a Severity Level V and the proposed imposition of a civil penalty be withdrawn. This is based on our position
- that the violations were minor in nature and did not pose a compromise to the protection of the public health and safety. We feel our response to the proposed Civil Penalty Action EA84-104 justifies our position on this concern.
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SECTION 1:
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The first concern references a long standing regulatory issue relating to the functional capability of the Protected Area intrusion syste The Security organization has identified and is aggressively pursuing, as a departmental goal for 1985, the correction of problems associated with the intrusion detection system. This has involved the development of a "
comprehensive study identifying all known security hardware problem areas --
. and proposed solutions to concerns. Input to the study has been provided by FPC Security and Engineering personnel along with outside engineering firms. Evaluation of problems and recommended corrective actions have already been completed by FPC Security and Engineering personne }
Management support of this goal has resulted in the following preliminary -
Implementation schedule which has a 90% confidence factor in its achievabilit Begin engineering for modification by Aprl! 1985 Final design phase by August 1985 Begin construction by October 1985 Complete construction by December 1985 t
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The second concern references a tendency to rely on the NRC to identify problems and contractors to provide solutions rather than maintaining a rigorous self-audit and evaluation progra Technical self sufficiency in the area of security has been a concern of FPC management for some time. The improvements noted in the report reflects management attention to this concern. We are confident the following accomplishments and future plans will eliminate future concerns in this
. area: A Security management staff has been assembled which is composed of professional security personne . Nuclear Security Superintendent - Four year degree in
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Criminology, eight (8) years law enforcement background, ten
- (10) years experience in Nuclear Power Plant Security.
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- Nuclear Security Officer - Four year degree in Government and Criminal Justice, twelve (12) years experience in Nuclear Power Plant Securit . Nuclear Security Specialist - Two year degree in Criminal Justice, twenty (20) years of Security experience in Physical, Technical and Personnel Security, and four (4) years experience in Nuclear Power Plant Security.
! The assignment of a dedicated plant engineer to assist, as required,
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with security equipment concerns and issue ~ The assignment of a full time security force officer to outage and modifications activitie The implementation of a security equipment preventive maintenance i program. This program was designed by FPC Maintenance and Engineering personne ,
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- The completion of an extensive vital area barrier survey by FPC Security, Operations and Engineering personne * The completion of a Security Plan technical review by FPC Security,
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Quality Programs and Engineering personne * The completion of a technical review of the Training and Qualification Plan by FPC Security personne * Complete a technical review of security procedures by FPC Security personnel by June 198 Complete an engineering study and evaluation of the CAS/SAS access control equipment by FPC Security and Engineering personnel by late 1985 or early 198 .
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May 30, 1985 Establishment of a 1986 Goal to update and replace equipment as recommended by the above stud * These areas are felt to represent accomplishments and commitments toward a rigorous self-audit posture. PPC will continue to aggressively, pursue such activitie The third concern references the lack of a thorough understanding by licensee personnel of the Physical Security Plan and associated procedure This lack of understanding resulted in six (6) of the violations identified.
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To address this concern, management has directed the Security staff to implement a Security Awareness Training program. This training will be
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oriented to security issues which are the responsibility of all plant l employees. Such training is to be provided to key managers of the Nuclear
, Operations staff. We feel the accomplishment of this training will instill
- appropriate awareness of security requirements by FPC personnel. This
. combined with the previously mentioned response actions should serve to reduce violations during the next reporting period.
i The final paragraph in this section stated, in part:
"It should be noted that late in the assessment period, there was an apparent improvement in management support of the Security 1 program. However, this trend occurred too late to show a meaningful improvement during this period."
i j We share your assessment of the improving management support of the Security program. We remain confident this improving support has resulted
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in the further enhancement of the sound founda'tlon for the Security effort at our facility. This improvement will continue toward the elimination of concerns identified per your SALP repor SECTION 2:
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Trend - Declining -
As stated earlier, we remain confident the above identified response actions will reverse future perceptions of a declining trend. The above actions do not support a finding of a declining tren }
, SECTION 3:
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l Broad Recommendations - Increased licensee management attention and
' involvement in the Security program.
l As stated within the above response, we feel the commitments already in
, place provide for a sound security foundation. This, combined with further corrective activities, will correct the concerns noted in the 1983/84 SALP i report.
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May 30, 1985 REFUELING (NOT RATED)- COMMENTS .
No comment ; QUALITY PROGRAMS AND ADMINISTRATIVE CONTROLS AFFECTING
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QUALITY (CATEGORY 2)- COMMENTS
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Florida Power Corporation understands the issues identified in this'
. evaluation and is taking steps to improve the handling of program nonconformances. These changes will result in an increased involvement of
QA in those programs designed to evaluate and correct problems.
! Quality Programs will review the scope of the audit that is conducted every
, six months to assure that it contains sufficient depth to evaluate the i effectiveness of existing corrective action systems in each of the operating j organizational areas. Specific consideration will be given to address the i implementation of program procedures and controls in order to determine their effectiveness in addition to reviewing the more programmatic issue Secondly, Quality Programs will conduct periodic reviews of both the
! surveillance test program and the various corrective action systems. The i
reviews will be conducted in conjunction with the audits in tlwse areas in
. order to maintain a closer continuing overview during the SALP report
perio . LICENSING ACTIVITIES (CATEGORY 2)- COMMENTS The Nuclear Licensing interface activities between the NRC and FPC are
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based on providing requests and responses based on the safe, legal, and
! efficient operation of CR-3. FPC believes our licensing activities during
! the SALP review period promote this philosophy. Included below are
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clarifications and corrections to items identified in section 3 of your SALP review of licensing activitie Living Schedule
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l The SALP report stated that FPC should be using an integrated schedule for all principal plant activities. FPC has utilized integrated scheduling for i nearly a decade. Whenever the need arose, FPC has shared this with the NRC staff (Supplement I to NUREG-0737). Our reluctance to pursue an
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- - integrated living schedule with staff involvement is based on the lack of any l obvious licensing advantages to FPC. FPC is, however, developing a 5-year integrated schedule to use in our internal planning. The integration of this schedule into the NRC living schedule concept will be reviewed later this year.
4 Decay Heat Technical Specifications The report faulted FPC for not including an adequate safety analysis in our i submittal for amendment of the decay heat removal system technical -
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- May 30, 1985
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specification. kn fact, the original NRC request to submit such a change
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(dated June 11, 1980) was based on NUREG-0103, B&W 5tandard Technical Specifications, Revision 3, July 1979. The NRC request did not take into account that a Revision 4 to NUREG-0103 was in preparation. FPC responded to the NRC request on October 16,1980, requesting clarification to certain parts of the Standard Technical Specification which FPC considered operationally non-realistic. Some of these questions were, interestingly enough, answered by changes to the Standard Technical Specification issued at about the same time as Revision 4 to NUREG-010 The issue was not raised again until a telephone conversation late in 1983 when the NRC requested FPC to submit a Technical Specification which we considered more operationally realistic. This was submitted on February 16, 1984. Numerous telephone conferences were then held clarifying the B&W NSSS design and operating characteristics, not changes to the design or operation of the system which would have necessitated a safety evaluatio It has been over one year since the last FPC submittal, and the issue is four months overdue for approval according to the " Orange Book" (NUREG 0748 TAC M42121 and M54445). s OT5G Technical Specifications The comments regarding the acceptability of the maximum level on our technical specification on Once Through Steam Generator level submittal are incorrect. FPC had B&W perform a specific analysis to substantiate this change reques The NRC staff requested FPC to demonstrate the secondary effects of a thermodynamically non-credible event (flooding of the aspirating ports would have resulted in entry into the action statement).
Rather than expend critical time convincing the staff of the accuracy of the analysis, we included an existing administrative limit in the technical specifications. FPC considers it fundamentally unfair for the staff to criticize FPC for failure to anticipate what we still believe is a rather minor concer Venting Technical Specification
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The comments on proposed resolution of this issue are also incorrect. The staff had previously approved the exact same corrective action immediately upon restart of Cycle 5. The staff requested confirmation of several items
- after the close of the work day and it took hours to retrieve files that would
_ normally have been available in a few minutes for resolution of the request (see also comments under plant operations).
SUPPLEMENTARY COMMENTS - TR AINING Nuclear Operations Training agrees with the comment concerning the weaknesses
In Chemistry Technician training and has initiated plans to provide hands-on training which should increase performance in the radiological controls are .
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Please note that Nuclear Operations Training has provided continuous training for the Chemistry Technicians during the evaluation period.- -
The course entitled, "The How and Why of Procedures", Lesson Plan 5T-03, should alleviate many of the concerns quoted in this section. As larger numbers of Staff members attend this course, we believe that the overall trend will be toward greater adherence to procedure Ongoing efforts continue to increase participation in this cours The most recent efforts of the Nuclear Operations Training Staff seem to have effected a reversal on the issue of management attention to training. Significant strengthening of " training weaknesses" is exemplified by the success of the recent Emergency Preparedness Exercise. Although the exercise was held after the i
reporting period, the excellent results achieved were due, in part, to strong j management attention to this issue.
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