IR 05000302/2010006

IR 05000302-10-006 on 04/05/10 - 04/23/10 for Crystal River, Unit 3, Biennial Inspection of the Identification and Resolution of Problems

ML101340020
Person / Time
Site:	Crystal River
Issue date:	05/14/2010
From:	Hopper G Reactor Projects Branch 7
To:	Franke J Florida Power Corp
References
IR-10-006
Download: ML101340020 (16)

Text

UNITED STATES May 14, 2010

SUBJECT:

CRYSTAL RIVER UNIT 3 - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000302/2010006

Dear Mr. Franke:

On April 23, 2010, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Crystal River Unit 3. The enclosed report documents the inspection findings, which were discussed on February 6, 2009, with you and other members of your staff.

The inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of plant equipment and activities, and interviews with personnel.

On the basis of the samples selected for review, there were no findings of significance identified during this inspection. The team concluded that problems were properly identified, evaluated, and resolved within the corrective action program (CAP). However, during the inspection, some examples of minor issues were identified concerning your evaluation of operating experience and adherence to site procedures.

In accordance with 10 CFR 2.390 of the NRCs 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 NRCs document system (ADAMS). Adams is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

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

Enclosure:

Inspection Report 05000302/2010006 w/Attachment: Supplemental Information

REGION II==

Docket No.: 50-302 License No.: DPR-72 Report No.: 05000302/2010006 Licensee: Progress Energy (Florida Power Corporation)

Facility: Crystal River Unit 3 Location: Crystal River, FL Dates: April 5 - 23, 2010 Inspectors: D. Merzke, Senior Project Engineer (Team Leader)

T. Morrissey, Senior Resident Inspector P. Higgins, Project Engineer A. Nielsen, Health Physics Inspector Approved by: G. Hopper, Chief, Reactor Projects Branch 7 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000302/2010006; April 5 - 23, 2010; Crystal River Unit 3; biennial inspection of the identification and resolution of problems.

The inspection was conducted by a senior project engineer, project engineer, health physicist, and senior resident inspector. No findings of significance were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Identification and Resolution of Problems The team 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 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 team 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 licensees processes for performing and managing work, and plant operations. However, the team found examples where operating experience was not adequately evaluated.

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.

NRC Identified and Self-Revealing Findings

None

Licensee Identified Violations

None

REPORT DETAILS

4OA2 Problem Identification and Resolution

a. Assessment of the Corrective Action Program

(1) Inspection Scope The inspectors reviewed the licensees CAP procedures which described the administrative process for initiating and resolving problems primarily through the use of nuclear condition reports (NCRs). To verify that problems were being properly identified, appropriately characterized, and entered into the CAP, the inspectors reviewed NCRs that had been issued between April 2008 and April 2010, including a detailed review of selected NCRs associated with the following risk-significant systems: Nuclear Service and Decay Heat Seawater, Decay Heat, Makeup/High Pressure Injection, and Radiation Monitor systems. 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 NRCs Reactor Oversight Process (ROP), the team selected a representative number of NCRs that were identified and assigned to the major plant departments, including operations, maintenance, engineering, health physics, chemistry, and security. These NCRs were reviewed to assess each departments threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions. The inspectors reviewed selected NCRs, verified corrective actions were implemented, and attended meetings where NCRs 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 NCRs, 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 team conducted a detailed review of selected NCRs 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 NCRs and the guidance in licensee procedure CAP-NGGC-0205, Significant Adverse Condition Investigations and Adverse Condition Investigations - Increased Rigor. 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 team 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 team 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 NCR screening meetings, the Quality Review Board (QRB), and the Plant Nuclear Safety Committee (PNSC).

Documents reviewed are listed in the Attachment.

(2) Assessment Identification of Issues The team 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 NCRs as described in licensee procedure CAP-NGGC-0200, Corrective Action Program, management expectation that employees were encouraged to initiate NCRs for any reason, and the fact that inspectors did not identify any deficiencies 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 NCRs sampled by the inspection team during the onsite period, the team concluded that problems were generally prioritized and evaluated in accordance with the licensees CAP procedures as described in the NCR significance determination guidance in CAP-NGGC-0200. Each NCR was assigned a priority level at the NCR screening meeting, and adequate consideration was given to system or component operability and associated plant risk.

The team determined that station personnel had conducted root cause and apparent cause analyses in compliance with the licensees 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.

However, the team identified one performance deficiency associated with NCR 379949 in that the licensee failed to recognize and appropriately classify two functional failures of Air Handling Fan 1A (AHF-1A), a Reactor Building cooling fan, on December 12, 2009 and February 5, 2010. The failures resulted in the component exceeding the established performance criteria, without being evaluated to determine if Maintenance Rule (a)(1)classification and goal setting was appropriate, in accordance with licensee procedure ADM-NGGC-0101, Maintenance Rule Program. Because the licensee identified the cause of the failures and completed corrective actions, and no cornerstone objectives were adversely affected, the team determined the performance deficiency was of minor significance, and is not subject to enforcement action in accordance with the NRCs Enforcement Policy. The licensee initiated NCR 395045 to address this issue.

Effectiveness of Corrective Actions Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the team 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, NCRs, 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 of significance were identified.

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

(1) Inspection Scope The team examined licensee programs for reviewing industry operating experience, reviewed licensee procedure CAP-NGGC-0202, Operating Experience Program, reviewed the licensees operating experience database, and interviewed the OE Coordinator, to assess the effectiveness of how external and internal operating experience data was handled at the plant. In addition, the team 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 April 1, 2008, to verify whether the licensee had appropriately evaluated each notification for applicability to Crystal River Unit 3, and whether issues identified through these reviews were entered into the CAP. Documents reviewed are listed in the Attachment.

(2) Assessment Based on interviews with the OE coordinator and a review of documentation related to review of operating experience issues, the team determined that the licensee was generally effective in screening operating experience for applicability to the plant.

Industry OE was evaluated at either the corporate or plant level depending on the source and type of the document. 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 apparent cause and root cause evaluations in accordance with licensee procedure CAP-NGGC-0205. During the review, the team identified three performance deficiencies associated with failure to follow the guidance in licensee procedures. The following issues were identified:

• Per CAP-NGGC-0202, Attachment 2, NRC Information Notices require a formal OPEX evaluation. Contrary to this, NRC Information Notice 2009-06 was not entered into the OPEX process. The licensee initiated NCR 391942 to address this issue.

• Per REG-NGGC-0013, Evaluating and Reporting of Defects and Noncompliance in Accordance with 10 CFR 21, any employee who receives 10 CFR Part 21 information from any source that is applicable to a Progress Energy licensee should initiate an NCR to determine if a substantial safety hazard exists or could be created. Contrary to this, in 2006, TYCO submitted a Part 21 concerning improper valve springs in pressure relief valves, which was determined to be applicable to Crystal River Unit 3, for which an NCR was not initiated to evaluate if a substantial safety hazard existed. However, the licensee did evaluate the issue in their OPEX program. The licensee initiated NCR 392410 to address this issue.

• Per CAP-NGGC-0200, all personnel are responsible to promptly initiate NCRs to document significant adverse conditions, adverse conditions, and improvement items. Contrary to this, during the evaluation of NRC Information Notice 2008-06, the evaluator identified that the degraded condition concerning solder joints discussed in the Information Notice might be applicable to the Heating, Ventilation, and Air Conditioning system, and no NCR was generated to initiate that evaluation. The licensee initiated NCR 391678 to address this issue.

Based on an initial review, no safety concerns were identified, and no cornerstones appeared to have been adversely impacted. Therefore, the team determined these performance deficiencies were of minor significance, and are not subject to enforcement action in accordance with the NRCs Enforcement Policy.

(3) Findings No findings of significance were identified.

c. Assessment of Self-Assessments and Audits

(1) Inspection Scope The team 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 team determined that the scopes of assessments and audits were adequate. Self-assessments were generally detailed and critical, as evidenced by findings consistent with the teams independent review. The team verified that NCRs 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 NCRs reviewed that were initiated as a result of adverse trends.

(3) Findings No findings of significance were identified.

d. Assessment of Safety-Conscious Work Environment

(1) Inspection Scope The team randomly interviewed 31 on-site workers regarding their knowledge of the corrective action program at Crystal River Unit 3 and their willingness to write NCRs 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 licensees Employee Concerns Program (ECP) and interviewed the ECP coordinator. Additionally, the inspectors reviewed a sample of completed ECP reports to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate.

(2) Assessment Based on the interviews conducted and the NCRs reviewed, the team 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 of significance were identified.

4OA6 Exit

Exit Meeting Summary

On April 23, 2010, the inspectors presented the inspection results to Mr. J. Franke, Site Vice President, and other members of licensee management. The inspectors confirmed that proprietary information was not provided or examined during the inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

J. Holt, Plant General Manager

J. Dufner, Manager, Maintenance

S. Cahill, Manager, Engineering

J. Huegel, Manager, Nuclear Oversight

L. Hughes, Superintendent, Chemistry

P. Dixon, Manager Training

M. Kelly, Manager Shift Operations

D. Westcott, Supervisor, Licensing

B. Akins, Superintendent, Radiation Protection

C. Poliseno, Supervisor, Emergency Preparedness

I. Wilson, Manager Outage and Scheduling

J. Franke, Vice President, Crystal River Nuclear Plant

T. Burnett, Supervisor, Self-Evaluation Unit

NRC personnel

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

LIST OF ITEMS

OPENED, CLOSED

Opened and Closed

None

Closed

None