ML20128A291
| ML20128A291 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 05/30/1985 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Wilgus W FLORIDA POWER CORP. |
| Shared Package | |
| ML20128A295 | List: |
| References | |
| NUDOCS 8507020620 | |
| Download: ML20128A291 (4) | |
See also: IR 05000302/1985003
Text
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May 30, 1985
Florida Power Corporation
ATTN: Mr. W. S. Wilgus
Vice President Nuclear Operations
P. O. Box 14042, M.A.C. H-2
St. Petersburg, FL 33733
Gentlemen:
SUBJECT: SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE, REPORT NO. 50-302/85-03
This refers to the NRC's Systematic Assessment of Licensee Performance (SALP)
Board Report for your Crystal River facility which was sent to you on March 5,
1985; our meeting of March 12, 1985, at which we discussed this report; and your
written comments dated April 11, 1985, relative to the report.
Thank you for your efforts in evaluating the SALP Board Report and in providing
programmatic comments for improving the SALP program.
I appreciate these
comments and assure you they have received careful evaluation in our continuing
efforts to make the SALP program more valuable.
Several of your general comments reflect your belief that the SALP assessment was
based upon isolated events having minor safety significance and did not properly
account for improvements implemented during the assessment period. As discussed
below, the recurrent nature of these isolated events is seen, in the broader
context, as a breakdown in your corrective actions program. We believe that the
SALP program allows the NRC staff to take a broader view of licensee performance
than is available in a single inspection and provides the mechanism for identifi-
cation of this type problem.
You also state that the Board did not properly
credit many of your initiatives. We are aware that, at times, the nature of the
inspection program makes NRC's recognition of management initiatives difficult.
However, we believe that the most important aspect of these improvement programs
is not their establishment but, rather, the actual improvement which results from
their implementation.
Although, the programs themselves provide the potential
for improved performance, the actual performance changes brought about by the
programs are of more immediate concern to the SALP Board. Thus, if your efforts
in correcting weaknesses discussed in the SALP assessment are successful, improved
performance will be noted in future SALP assessments.
Irrespective of this
potential for improved performance brought about by the implementation of new
initiatives, the actual performance during the assessment period was addressed
by the SALP Report.
Your letter questions the philosophy used in assigning the category ratings and
trends in each area.
During the SALP Board's consideration of each functional
area, there are normally strengths as well as weaknesses identified in each area.
Individually, these attributes could place the evaluation in Category 1,
Category 2, or Category 3.
The final rating for each functional area, however,
is a composite of these attributes tempered with judgement as to the significance
of individual items.
With regard to the determination of the performance trend,
page 4 of the SALP Report notes that the trend Categorization is not a comparison
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Florida Power Corporation
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May 30, 1985
between the current and previous SALP ratings.
Instead, the trend is meant to
describe the general or prevailing tendency during the SALP period.
Your letter also questions the practice of making the SALP Report public prior to
providing the opportunity for utility response. The NRC staff has discussed this
issue at length.
We have determined that our responsibility to the public to
promptly release the completed SALP document would not be met if we delayed
issuance in order to obtain licensee comments.
We believe that the ample
opportunity given the licensee to respond, as you have done here, and the equal
distribution given both the Report and your comments, provide an equitable
mechanism for conduct of the SALP program.
With regard to your coments pertaining to the plant operations area, I agree
with the SALP Board's characterization of your containment internal pressure
event and do not believe it to be a misrepresentation of the event.
It is
important for you to recognize that the annunciator which should have warned the
operators of the increasing containment pressure was out of calibration.
You
imply that you have no control over the maintenance of containment pressure due
to the NRC requirement that you cease continuous purging.
As you are aware,
this requirement was imposed because it appeared that your purge valves would
not shut as designed during a loss of coolant accident and were subject to
excessive leakage after being shut. The requirement for closure of these valves,
in this situation, has been uniformly applied to licensed power plants, and the
conduct of your operations must account for this closure.
I also disagree with your coment concerning the appropriateness of the SALP
Board's coment regarding the turnover of non-licensed operators. The reference
to this turnover was not a part of the analysis section of the assessment and so
was not considered in the performance rating process. However, the situation was
of sufficient concern for a Board coment to be made.
Also, with respect to the plant operations area, it is incorrect to conclude that
the coments on licensed operator training program problems should not have been
included in the SALP Report.
Information on these problems was not considered in
the evaluation process.
In fact, specific references were made to the fact that
these problems were identified outside the assessment period and would not be
discussed until the following assessment.
However, the SALP Board believed, and
I agree, that the omission of all references to these problems would not have
presented a totally accurate picture of this area.
With regard to your performance in the radiological controls area, the rating and
trend assigned by the SALP Board were not based solely upon your radiation
protection program but encompassed performance of the chemistry program and post
accident sampling system as well.
It was your combined performance in these areas
that resulted in the overall rating of 2 and constant, with which I concur.
With respect to your performance in the surveillance area, the SALP Board's
Category 3 rating in this area appears appropriate. The corrective actions which
you have taken should result in improved performance during the current SALP
assessment period.
We will closely monitor this area and discuss the results in
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Florida Power Corporation
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May 30, 1985
the next SALP assessment.
I am concerned, however, by your characterization of
the fourteen violations identified in the surveillance area.
You refer to these
violations as administrative errors not involving safety significance.
These
violations, many of which were recurrent in nature, involved five examples of
failure to adhere to surveillance procedures, five examples of failure to perform
adequate or timely surveillance tests, and three examples of failure to use
calibrate & instrumentation.
The SALP Board recognized that although each
individual violation represented only a single failure, their cumulative effect
was the indication that your corrective actions have not been effective.
This
conclusion involves safety significance and requires the attention of senior
plant management.
Your response to the SALP Board's analysis of your performance in the security
area detailed several programs you have initiated to address identified weaknesses.
Although you have implemented programs to address these NRC concerns, the SALP
Board's rating for your performance during the assessment period was appropriate.
We will monitor the results of your corrective programs and address any improve-
ments in the next SALP Report. As I am sure you are aware, each reference in the
SALP Report to the Severity Level III security plan problem was preceded by an
annotation indicating that this problem was " proposed."
This annotation placed
the problem in the proper perspective.
Also, as stated in the SALP Report,
management support of the security program improved; however, it occurred too
late in the period to reverse the otherwise declining performance trend.
Finally, your comments on the licensing activities functional area do not
significantly affect or, in some cases, do not bear directly on the rating in
this area.
The reference in the SALP Report to integrated schedules was not a
factor in the rating determination, and your remaining remarks on licensing
activities do not appear to contradict our basic findings.
No reply to this letter is required; however, should you have any questions
concerning these matters, I will be pleased to discuss them with you.
Sincerely,
lh U
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1fuM
J. Nelson Grace
Regional Administrator
Enclosure:
Appendix to Florida Power Corporation
Crystal River Unit 3, Board Report
(Dated March 5, 1985)
/cc w/ encl:
E. M. Howard, Director
Site Nuclear Operations
pG.R.Westafer, Manager
. F. McKee, Nuclear Plant Manager
Nuclear Operations Licensing
and Fuel Management
bec w/ encl:
(See page 4)
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' Florida Power Corporation
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May 30, 1985
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