3F0298-09, Provides NRC W/Actions Carried Forward as non-restart follow-up Items for Which Util Committed Future NRC Submittal or Where NRC Action on Submittal Pending

Provides NRC W/Actions Carried Forward as non-restart follow-up Items for Which Util Committed Future NRC Submittal or Where NRC Action on Submittal Pending

ML20202B742
Person / Time
Site:	Crystal River
Issue date:	02/09/1998
From:	Holden J FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
3F0298-09, 3F298-9, CAL, GL-91-18, NUDOCS 9802120084
Download: ML20202B742 (7)

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February 9,1998 3F0298-09 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Non-Restart Follow-up Items

References:

1. NRC to FPC Confirmatory Action Letter, dated March 4,1997 b] 2. NRC Generic Letter 91-18, Revision 1

Dear Sir:

The purpose of this letter is to provide the NRC with those actions which are being carried forward as non-restan follow-up items for which FPC committed a future NRC submittal or where NRC action on an FPC submittalis pending.

Restart issues Process At the beginning of this outage, FPC developed issue screening criteria which were used as the basis for determining whether identified items would be classified as restart issues. The screening process was proceduralized (NOD-57) and is the basis whereby each item was assessed as being either a restan

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or a non-restart issue. This restart list included items addressed in the Confirmatory Action (Reference 1), FPC's Corrective Action Program, System Readiness Review program and NRC restart items. Each issue was evaluated against the restart criteria for restart determination. Further, for each of the activities determined to be a restart issue, a "Restan Closure Package" was developed and, upon completion, provided to the NRC for their review. The identified restart issues are closed. NRC inspections have verified that FPC restart activities have adequately addressed the issues. Items that were evaluated against the issue screening criteria, and determined not to be restart related, are being managed and tracked in accordance with FPC processes and practices for resolution Non-Restart Follow-up Items ll I.l l.l!I. I. !!.11. .I As noted above, the restart effon at CR-3 resolved and corrected issues that were both restart and non-restart actions. Non-restan actions that were not completed are being tracked for post restan closure.

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LU.S. Nuclear Regulatory Commission f i 3F0298-09

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FPC recently revised their processes to incorporate the guidance provided in NRC Generic Letter (GL) :

91 18, Revision 1.j. Subsequently, a number ofissues _have been evaluated and were found to meet the.

criteria'of GL 9118,' Rev.(L Each of these items has been evaluated in'accordance with FPC's -i 10CFR50.59 process a:xi the Corrective Action Program. These issues are being managed as actions 1 Lwhich will be completed' post restart.1 This information has been previously discussed with the NRC and provided in other forums.K License'amedments are also being tracked as post testart follow-up i actions with the NRC. Resolution of remaining' plant design issues are also being carried forward.-

Issues for which FPC has committed ~a future NRC submittal 'or where NRC_ action is peding are-

- summarized in Attachment A. - FPC is working with the NRC staff te establish firm request dates for-

NRC action where request dates are not included in Attachment A.  !

,With the closure of MCAP_ II, the remaining elever actions were evaluated and concluded not to be restart related Each of these former MCAP 11 actions has been rolled into either the Long Range -

Business Plan or the Corrective Action Program for res>lution post restart JCommitments containedin this letter are described in Attachment 'B. If you have any questions -

regarding these matters, please call me at (352) 563-4477.'

Sincerely,

// J

_ Jo 1 Holdens Director -

? Site Nuclear Operations iJJH/mhl Z -

- Attachments cc:: Johns P. Jaudon, NRC Director, Division of Reactor Safety :

NRR Project Managerc

Senior Resident inspector

Regional Administrator, Region 11

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U.S. Nuclear Rcgulatory Commission Attachment A 3F0298-09 Page1of4 Non-Restart Follow-UD IS$Ues I. License Amendments

1. License Amendment Request (LAR) 214 - Request for Decay Heat -Removal Requirements in Mode 4, submitted 10,":37. FPC requested in the submittal that the L NRC consider this license amendment and provide approva! as soon as possible.

2. LAR 217 - Fan Logic Modification to AIIF-lc Motor Control Center ES-MCC-3AB, submitted 10/4/97 FPC requested in the submittal that this license amendment be approved by 2/16/98.

3. LAR 218 - Revision of the Makeup System Letdown Line Failure Accident Analysis, submitted 9/9/97.

4. LAR 221 "B" OTSG Tube Surveillance Program, submitied 10/1/97 FPC requested in the submittal that this license amendment be approved by 9/30S8.

'5, LAR 222 - Control Room Emergency Ventilation and Emergency Filters, submitted 12/5S7, to be revised 6 months aller restart to address NRC requested items. FPC requested in the submittal that this license amendment be approved prior to Refueling -

Outage 11, which is currently scheduled for the fourth quarter of 1999.

6. LAR 223 - Post-LOCA - Boron Precipitation Prevention, submitted 10/31/97.

Supplemental information will be provided on final calculations by 2/28/98,

7. LAR 224 - Reactor Building Fan Starting Logic Modification, submitted 12/5S7. FPC requested in the submittal that this license amendment be approved by 2/13S8. <

8. LAR 225 - Protection Against Dynamic Effects of LOCA, scheduled for submittal

-5/29S 8.

9. LAR 228 - EFP-1 Service Factor, scheduled for submittal by 7/15/98.

10. LAR 229 - DHV- 34,- 35 position, scheduled for submittal by 10/16/98 (FPC to NRC letter 3F0298-11, dated 2/6/98).

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U.S. Nuclear Regul: tory Commission Attachment A 3F0298-09 Page 2 of 4 l

II. Desien issun Summary

1. Appendix R issues Appendix R program documentation (design drawings and Fire study update of miscellaneous items) to be updated 3/3 l/98 (LER 97-046-00, LEE 97-035 00).

Actions to resolve Thermo-Lag issues (sprinklers, rerouting circuitry, emergency lighting) to be complete by 11/30/2000.

Fire barriers and penetration seals - upgrade and enhance the ability of CR-3 to document and maintain the design basis of penetrations seals. Completion date to oc established based upon future NRC interaction (NRC IFI 97-11-09).

2. Large Bore Piping qualification - F?C plans to perform a comprehensive and rigorous inspection, revalidation and/or requalification of CR-3 safety-related large bore piping and pipe supports during the next 4-6 years (LER 97-040-00). It will also address jet impingement concems as part ofitem 3. A schedule for completion will be established by ,

6/30/98.

3. Protection against dynamic effects of LOCA - provide justification for use of GL 87-11 and NUREG/CR-2913 as the licensing basis for CR-3 and/or propose additional modifications to be completed prior to startup from Refueling Outage 11 (FPC to NRC letter 3F0198-34, dated 1/23/98).

4. USI A-46 resolution Complete resolution of all outliers by restart from Refueling Outage 11 and submit confumation of resolution to the NRC (FPC to NRC letter 3F1297-24, dated 12/16/97).

Conduct a confirmatory self-assessment (audit) of the USI A-46 program by restan from Refueling Outage 11 and forward results of the audit to the NRC (FPC to NRC letter 3F1297-24, dated 12/16/97).

5. Waste (gas and liquid) disposal tanks outlet piping - to be upgraded to seismic class 1 prior to restart from the next scheduled Refueling Outage 11R (LER 97-038-00).

6. RCS attached piping - perform a Class I fatigue analysis for specified RCS attachment piping and revise affected design and licensing basis documents by 11/30/98 (FPC to NRC letter 3F1197-24, dated 11/21/97).

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U.S. Nuclear Regulatory Commission Attachment A 3F0298-09 Page 3 of 4

7. Remaining EFIC/EFW modifications will be completed by the end of Refueling Outage 11 (FPC to NRC letter 3FI196-07, dated 11/4/96).

8. Cable ampacity qualification - evaluate cable sizing and cable remaining qualified life.

Evaluation to be completed by the end of Refueling Outage 11.

9. Boron precipitation - llot leg injection, FPC to proside a submittal on this method for boron precipitation mitigation by 2/27/98 (FPC to NRC letter 3F0198-44, dated 1/31/98).

10. IIPI throttling and crossover line - the evaluations of cross-tie designs will be completed in time for both the cross-ties and passive flow control devices to be installed during Refueling Outage 11R (FPC to NRC letter 3F0997-27, dated 9/17/97).

I 1. EDG upgrades /DG Driven EFW Pump - FPC will implement the permanent actions to address EDG capacity limitations by the end of Refueling Outage 11. The two primary options under consideration are either to modify the existing diesels or install a diesel driven EFW pump (FPC to NRC letter 3F0697-10, dated 6/14/97).

12. CCHEissues resolution Perform an additional control room dose analysis for steam generator tube rupture (SGTR) events using methods and assumptions within SRP 15.6.3 as guidance.

Results of the analysis to be submitted to the NRC with the revised control room habitability report to demonstrate compliance with 10CFR50, Appendix A, GDC 19, i by 8/14/98 (FPC to NRC letter 3F0198-26, dated 1/14/98).

Following receipt of NRC approval of the Control Room Habitability Report and LAR 222, complete modifications and/or procedures determiaed by FPC to implement the approved design and licensing basis for CR-3 control room habitability prior to startup from Refueling Outage 11 (FPC letter to NRC 3F0198-26, dated 1/14/98).

13. RG 1.97 Instrumentation Upgrades - modify the power supply for the SPDS to separate it into a train "A" and train "B" redundant system, powered from safety-related inverters which are backed up by the. station standby power sources during Refueling Outage 11 (FPC to NRC letter 3F0797-21, dated 7/29/97).

14. LPI crosstie and HPl/LPI performance - analyze HPl/LPI system performance (including the LPI crossover mode) and consider possible engineering solutions to address system performance (to ii.clude valve positioning for DHV-5, -6, -34, -35, -110, and -111). These actions are to be completed by 10/16/98 (FPC to NRC letter 3F0298-11. dated 2/6/98).

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U.S. Nuclear Regulatory Commission Att chment A 3F0298-09 Page 4 of 4

15. Outstanding JCOs will be resolved in a timely manner. LARs, modifications, or other engineering analyses will be conducted to resolve nonconformances documented in FPC Deficiency Report /JCO process (John Paul Cowan to Chairman Jackson, November 1997).

16. Security sideo capture system - to be installed to detect intmder presence prior to ,

generating / receiving an alarm indication by 4/17/98 (FPC to NRC letter 3F0198-46, dated 1/30/98).

17. Calculations FPC is developing an Analysis / Calculation Upgrade Program. A program plan ia being developed to include scope, prioritization, schedule, and methodology. The plan will be wmpleted by 6/19/98 and implementation will begin thereafter. By 6/19/98, FPC will provide the schedule for completion of the program to the NRC.

Drif1 calculations - evaluate instrument drift data and impact ofincreased surveillance intervals and make any necessary revisions to calibration intervals or setpoints 180 days afler startup from Refueling Outage 11 (FPC to NRC letter 3F0797-25, dated 7/21/97).

III. FSAR Revision 25 To be submitted July 1998 (FPC/NRC meeting 1/12/98).

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U.S. Nuclear Regulatory Commission Attachment B 3F0298-09 Page1of1 FPC CommitmvDts The following table identifies those actions committed to by Florida Power Corporation in this document. Any other actions discussed in the submittal represent intended or planned actions by Florida Power Corporation. They are described to the NRC for the NRC's information and are not regulatory commitments. Please notify the Manager, Nu:: lear Licensing of oly questions regarding this document or any associated regulatory commitments.

Commitment Due Date Submit LAR 228 to the NRC - EFP-1 July 15,1998 Service Factor.

A schedule for completion of Large Bore June 30,1998 piping qualification will be established.

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Evaluate cable sizing and cable remaining Complete by end of Refueling Outage 11.

qualified life.

FPC is developing an Analysis / Calculation The plan willbe completed by June 19, Upgrade Program. A program plan is 1998 and implementation willbegin being developed to include scope, thereailer.

prior:.ization, schedule and methodology.

FPC will provide to the NRC the schedule for completion of the program by June 19, 1998.

Actions to resolve Thermo-Lag issues are November 30,2000 to be completed.

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