3F1097-07, Forwards Response to Violations Noted in Insp Rept 50-302/97-11.CAs:Health Physics Personnel Assigned Responsibility for Providing Ventilation for OTSG Work Were Counseled for Failing to Secure Temporary Purge Fans
| ML20211M310 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 10/08/1997 |
| From: | Holden J FLORIDA POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 3F1097-07, 3F1097-7, 50-302-97-11, NUDOCS 9710140124 | |
| Download: ML20211M310 (8) | |
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- t Florida Power fr:1;%.
oom m October 8,1997 3F1097 07 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 0001
Subject:
Reply to Notices of Violation, NRC Inspection Report No. 50 302/97-11, NRC to FPC letter, 3N0997 09, dated September 12,1997
Dear Sir:
In the subject letter, Florida Power Corporation (FPC, received Notices of Violation.
This correspondenco provides our response to the violations.
Sincerely, 9{ Y J. / Holden Director Site Nuclear Operations
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Regional Administrator, Region ll Senior Resident inspector NRR Project Manager 1 4 A (1 A 1 9710140124 97100s DR ADOCK 05000302 PDR CRYST AL RIVER ENERGY COMPLEX:istso w Power une street. crystai River.Fiones H42s470s.osa ns44ss 4 Fevre Progress Company I
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- 11. S. Nucl:ar Rcgul: tory Commission 3F1097 07 Page 2 of 8 ATTACHMENT 1 FLORIDA POWER CORPORATION NRC INSPECTION REPORT NO. 50 302/9711 REPLY TO NOTICES OF VIOLATION l
VIOLATION 50 302/971102 l
10 CFR 50, Appendix B, Criterion V, requires, in part, that activities affecting quality shall be prescribed by procedures, of a type appropriate to the circumstances, and shall be accomplished in accordance with these procedures.
Contrary to the above, on July 28,1997, licensee personnel performed quality related work to restore once through steam generators-during reduced reactor coolant system inventory operation without a written and approved procedure. Consequently, a step to secure the ventilation fan connected to the A once-through steam generatnr upper hand holes prior to replacing the lower diaphragms and manways was omitted resulting in an indicated reactor coolant system level decrease.
This is a Severity LevelIV violation (Supplement 1).
ADMISSIGN OR DENIAL OF THE ALLEGED VIOLATION Florida Power Corporation accepts the violation.
REASON FOR THE VIOLATION The reason for the violation was a process weakness. Maintenance Procedure MP-110A, Steam Generator Primary Side Maintenance, did not contain provisions to prevent manway closure with the Inspection cover purge fans in operation. A contributing factor was cognitive personnel error. Health Physics personnel assigned responsibility for providing ventilation for the once through steam generator (OTSG) work failed to ensure the upper OTSG inspection cover purge fans were secured prior to installing the lower OTSG manway.
CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Health Physics personnel assigned responsibility for providing ventilation for the OTSG work were counseled for failing to secure temporary purge fans prior to manway installation.
The subject violation occurred during final recovery from reduced reactor coolant system (RCS) inventory operations. FPC does not expect to enter reduced RCS inventory operation before the next refueling outage (R11) which is currently scheduled for late 1999. Therefore, no further immediate actions were deemed necessary.
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- d. S. Nuclxr R:gul: tory Commission 3F1097 07 a
Page 3 of 8 i
. CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS l
l A statement will be added to the Limits and Precautions section of Operating Prncedure OP-301, Operation of the Reactor Coolant System, by November 15,1997. This s,atement will I
caution Operations personnel that Reactor Coolant level indication perturbatloas may be l
caused during manway installation.
Attention to detail, using the above event as an example, will be stressed during the Spring, 1998 Health Physics Block Training regarding Nuclear Safety. -This action is scheduled for completion by March 31,1998.
Expectations for remote Health Physics coverage during OTSG work will be proceduralized by December 12,1997.
MP 110A will be revised by January 15,1998, to add steps requiring that either one manway is open or the inspection cover purge fans are secured prior to manway closure.
Other activities performed at reduced RCS inventory operations have been identified that may have the potential to create unexpected RCS level perturbations due to the use of temporary ventilation for radiological control of contaminants. Those activities are described in the following procedures: (1) MP-101, RCS RTD and Thermowell Maintenance; (2) MP 102, RCV-8 and RCV 9 Pressurizer Relief Valvo Removal / Installation; (3) MP-107, Pressurizer Maintenance; (4) MP 108A/B, CRDM Contrcl Rod Drive Handling Electrical / Mechanical; (5)
MP 115/., Reactor Coolant Pump Inspection and Replacement; and (6) MP 155, Electromatic Pressurizer Relief Valve RCV 10 and Block Valve RCV 11 Removal and installation.
Procedures MP 101, 102, -107, -108A/B, 115A, and -155 will be evaluated to ensure adequate guidance exists to prevent temporary ventilation from causing inadvertent RCS pressure changes or RCS level indication perturbations during reduced RCS inventory operations. Procedures will be revised, as necessary, by March 31,1998.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance will be achieved by March 31,1998, when actions to prevent recurrence have been implemented.
VIOLATION 50 302/97-11-06 Technical Specification 5.6.1.1, Procedures, requires that written procedures be established and implemented for activities recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978, including general procedures for the control of replacement and modification work.
Licensee Procedure NEP-254, Plant Equm,at Equivalency Replacement Evaluation (PEERE), Revision 13, step V.A.2, defines one type of equipment replacement, equipment-equivalency replacement, as replacing an item with another item which is different from the licensee specified requirements but which has been determiaed, through engineering evaluation, to be equivalent in that the replacement item fulfills the licensee required critical
N. S. Nucirr R gulatory Commission 3F1097 07 Page 4 of 8 4
design characteristics and is equivalent in form, fit, function, and structural integrity A note attached to that step states that in the case where a critical design characteristic is changed or where the replacement results in operational, functional, or performance changes, the replacement, or that portion of the replacement which represents the change, would require a modification approval record (MAR) or commercial grade work request (CGWR).
Contrary to the above, PEERE 1497 was issued on April 10,1997, to document modifications made to the building spray pump impellers, These modifications were made to increase the l
Net Positive Suction Head (NPSH) margin for the pumps, which the PEERE ident{ed as a l
critical characteristic of the pump. These modifications were performed under the PEERE process instead of the MAR process.
This is a Severity Level IV Violation (Supplement 1).
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Florida Power Corporation accepts the violation.
REASON FOR THE VIOLATION The reason for the violation was a process weakness. Nuclear Engineering Procedure NEP-254, Plant Equipment Equivalency Replacement Eva' ition, did not contain adequate guidance to restrict the use of the PEERE process foi.aulpment replacement. NEP 254 states that changes to FPC specified critical design characteristics cannot be accomplished through the PEERE process. NEP 254 also states that the critical design characteristics of a sub component are normally the responsibility of the manufacturer. The impellers, a sub-component of the pumps, were sent to the vendor to be modified. Based on the inadequate guidance contained in NEP 254, FPC personnel incorrectly determined that installation of the reworked impellers did not change FPC specified critical design characteristics.
CORRECTIVE STEPS THAT HAVE BEEN OR WILL BE TAKEN AND THE RESULTS ACHIEVED NEP 254 guidance for determining if the MAR process should be invoked is based on whether an FPC specified critical design characteristic is being changed. PEEREs with ' return to service" requirements are considered to have the highest potential for changing FPC specified critical design characteristics. Of approximately 1700 PEEREs that currently exist,24 PEEREs have " return to service" requirements. A review of those 24 PEEREs concluded that only two PEEREs (#685 and #1491 could possibly change an FPC specified critical design characteristic, one of which (#1497) had been previously identified by the NRC. Based on this review, inappropriate use of the PEERE process is not considered to be widespread or to represent an adverse trend. PEERE #685 has been voided. PEERE #1497 will be voided by November 25,1997.
A keyword search of Corrective Action Program Precursor Cards (PCs) and Problem Reports (prs) was performed to determine whether misapplications of the PEERE process had been previously identified. No previous similar conditions were found.
- d. S. Nucbtr R:gul: tory Commission 3F1097 07 Page 5 of 8 An Interoffice Correspondence has been issued to engineering personnel describing the circumstances surrounding this violation and providing interim guidance for ensuring proper application of the PEERE process. The interim guidance is in the form of a checklist which included 10CFR50.59 screening as a criteria. If an Unroviewed Safety Question Determination is required for the activity, the PEERE procecs cannot be used.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS NEP 254 will be revised by January 15,1998, to provide additional guidance for determining whether the PEERE process should be applied for equipment replacement versus the MAR i
process.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Florida Power Corporation will achieve full compliance by January 15,1998.
6 VIOLATION 50 302/97 11 07 10 CFR 50.71(e), in part, requires licensees to update periodically the Final Safety Analysis Report (FSAR) originally submitted as part of the application for the operating license to assure that the information included in the FSAR contains the latest material developed.
This submittal shall contain all the changes necessary to reflect information and analyses submitted to the Commission by the licensee pursuant to the Commission requirement since the submission of the original FSAR or, as appropriate, the last updated FSAR. The updated FSAR shall be revised to include the effects of all safety evaluations performed by the licensee in support of requested license amendments.
4 In support of its request for License Amendment No,149, relating to improved technical specifications (ITS), the licensee proposed and the Commission approved (by issuance of License Amendment No.149 and the accompanying safety evt Nation report dated December 20,1993) relocating the provisions for reactor coolant water chemistry from the then Technical Specifications (TS) 3.4.7 to the FSAR and appropriate plant procedures.
Contrary to the above, as of July 18,1997, the licensee's updated FSAR, Revision 23, dated November 18, 1996, did not include the effects of the safety evaluation performed by the licensee in support of its requested License Amendment No.149 for implementing the ITS in lhat the FSAR did not reflect information relating to the reactor coolant quality specifications pursuant to Commission requirement since ti,e last updated FSAR.
This is a Severity Level IV Violation (Supplement 1).
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Florida Power Corporation accepts the violation.
4 U. S. Nucle:r R:gulatory Commission 3F1097 07 Page 6 of 8 REABON FOR THE VIOLATION The reason for the violation was cognitive personnel error. The level c' intall which remained in the FSAR after deletion of the RCS water chemistry tables was not adequate to ensure proper control under the 10CFR50.59 process. A contnbuting factor was a weakness in the process for implementing the requirements of 10CFR50.71(e). Procedures did not contain adequate guidant,e for controlling the removal or relocation of Information from the FSAR.
CORRECTIVE STEPS THAT HAVE BEEN OR WILL BE TAKEN AND THE RESULTS ACHIEVED The FPC FSAR Operational Review Program was completed on February 28,1997, and identified discrepancies between the FSAR and operational documents..The Configuration Document Integration Project (CDIP) was subsequently developed as an expansion of the FSAR Operational Review Program to integrate the resolution of identified discrepancies with the extent of condition reviews being done in the present outage, in conjunction with the System Readiness Reviews, the CDlP is integrating the significant changes to the facility and the resolution of the findings from both the FSAR Operational Review and the System Readiness Reviews into the main configuration control documents, including the FSAR. The next scheduled revision to the CR 3 FSAR (Revision 24) is being coordinated by the CDIP in accordance with the CDIP Process Guide. CDIP personnel have been made aware of expectations related to the removal of information from the FSAR.
Previous FSAR Tables 410,411, and 9 3 will be corrected, as necessary, and incorporated into FSAR Revision 24, which is scheduled for submittal by December 8,1997.
License Amendment Nos.149 (upgrade from the Standard Technical Specifications to the Improved Technical Specifications), 150,151,152,153,154, and 155 have been reviewed for compliance with FSAR infremation inclusion requirements. Several discrepancies have been-identified. Those discrepancies will be resolved or'or to submittal of FSAR Revision 25, which is scheduled for July 31,1998.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS By letter dated April 25,1997, FPC docketed Revision 2 to the Management Corrective Action Plan (MCAP ll). In MCAP 11, item D RC10, FPC committed, in part, to benchmark the regulatory process for updating the FSAR against SALP 1 plants and revise the process as necessary, The revised process willinclude guidance for controlling the removal or relocation of information from the FSAR. The revised process is scheduled to be completed by January 31,1998.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Florida Power Corporation will achieve full compliance by July 31,1998.
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0 U. S. Nucirr Regul: tory Commissl:n 3F1097 07 Page 7 of 8 6 TTACHMENT 2 The following table contains a listing of commitments contained in this response:
Section Commitment Due Date Page 3 A statement will be added to the Limits and November 15,1997 Precautions section of Operating Procedure OP 301,
" Operation of the Reactor Coolant System," by November 15, 1997.
This statement will caution i
Operations personnel that Reactor Coolant level indication perturbations may be caused during manway installation.
Page 3 Attention to detall, using the above event as an March 31,1998 example, will be stressed during the Spring,1998 Health Physics Block Training regarding Nuclear Safety. This action is scheduled for completion by March 31,1998, Page 3 Expectations for remote Health Physics coveiage December 12,1997 during OTSG work will be proceduralized by December 12,1997.
Page 3 MP 110A will be revised by January 15,1998, to add January 15,1998 steps ensuring that either one manway is still open or the inspection cover purge fans are secured prior to manway closure.
Page 3 Procedures MP 101, 102, 107, -108A/B, -115A, and March 31,1998 155 w;ll be evaluated to ensure that - adequate guidance -exists to prevent the use of temporary ventilation from causing inadvertent RCS pressure changes or RCS level indication perturbations during reduced RCS inventory operations. Procedures will be revised, as necessary, by March 31,1998.
Page 4 PEERE #1497 will be volded by November 25,1997.
November 25,1997 ~
Page5 NEP 254 will be revised by January 15,1998, to January 15,1998 provide additional guidance for determining whether the PEERE process should be applied for equipment replacement versus the MAR process.
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? age 6 Previous FSAR Tables 410, 411, and 9-3 will be December 8,1997 corrected, as necessary, and incorporated into FSAR Revision 24, which is scheduled for submittal by December 8,1997.
U. S. Nucl:cr Rcgulatory Commission 3F1097 07 Page 8 of 8 a
Section Commitment Due Date Page 6 License Amendment Nos.149 (upgrade from the July 31,1998 Standard Technical Specifications to the improved l
Technical Specifications), 150, 151, 152, 153, 154, and 155 have been reviewod for compliance with FSAR information inclusion requiren,9nts.
Several discrepaneles have been identified.
Those discrepancies will be resolved prior to submittal of FSAR Revision 25, which is scheduled for July 31, 1998.
Page6 By letter dated April 25,1997, FPC docketed Revision January 31,1998 2 to the Management Corrective Action Plan (MCAP ll), in MCAP 11, item D RC16, FPC committed, in part, to benchmark the regulatory process for updating the FSAR against SALP 1 plants and revise the process as necessary. The revised process will include guidance for controlling the removal or relocation of information from the FSAR. The revised process is scheduled to be completed by January 31, 1998.
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