3F0998-09, Notifies NRC of Commitment Changes to Previously Docketed Correspondence from Fpc.Rept Listing Changes,Encl

Notifies NRC of Commitment Changes to Previously Docketed Correspondence from Fpc.Rept Listing Changes,Encl

ML20151W090
Person / Time
Site:	Crystal River
Issue date:	09/10/1998
From:	Grazio R FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
3F0998-09, 3F998-9, NUDOCS 9809150173
Download: ML20151W090 (19)

Text

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Finrida Power E?SBJE" 8;;=;#.in-n September 10,1998 3F0998-09 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

Subject:

NRC Commitment Change Report - September 1998

Dear Sir:

The purpose of this letter is to notify the NRC of commitment changes to previous docketed correspondence from Florida Power Corporation (FPC). Attached is a report listing these changes. It contains the Nuclear Operations Commitment System (NOCS) archive number, source of the original commitment, statement of the original commitment, statement of the revised commitment, and justification for the changes. This report is being submitted per the NRC-endorsed Nuclear Energy Institute (NEI) document " Guidelines for Managing NRC Commitments."

If you have any questions regarding this submittal, please contact Mr. Walter Pike, Manager, Nuclear Compliance at (352) 563-4988.

Sincerely, Robert E. Grazio Director Nuclear Regulatory Affairs [

t REG /tak yk Attachment . I I I xc: Regional Administrator, Region II Senior Resident Inspector NRR Project Manager n

9809150173 980910 ADOCK 05000302 9J PDR '

p PDR CRYSTAL RIVER ENERGY COMPLEX: 16760 W. Powor Line Street

• Crystal River, Florida 34428-6708 * (352)7954486 A Flodde Progress Company

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Crystal River Unit 3 3

i NRC COMMITMENT CHANGE REPORT

September 1998 i

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Attachment to FPC Letter Number 3F0998-09 Dated September 10,1998

. U.S. Nuclear Regulatory Commission Attachment f 3F0998-09 Page1of17 ,

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commitment Number: NOCS #01103  :

Source Document:

FPC to NRC letter 3F0580-02, dated May 2,1980, Nuclear Safety Task Force Priority Items and Confirmatory Order for Crystal River Unit 3 dated 4/14/80.

Original Commitment:  ;

ITEM 13 ,

Emergency Procedure EP-113," Plant Shutdown from Outside Control Room," will be revised to include adequate operator verification of proper feedwater water system status prior to  !

leaving the control room.

Revised Commitment:

This commitment is INACTIVE.

Justification for Change:

. Generic Letter (GL) 86-10 provided NRC guidance for compliance with 10CFR50 App R. ,

Question 3.8.4 in GL 86-10 limited actions in response to control room fires to those which can

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be accomplished prior to evacuation of the control room. The only manual action GL 86-10  ;

credits prior to control room evacuation is reactor trip.

For additional control room activities deemed necessary prior to evacuation, GL 86-10 requires I a demonstration of the capability of performing such actions. Additionally, assurance must be l

provided that such actions could not be negated by subsequent spurious actuation signals '

caused by a postulated fire. The original commitment was made prior to the issuance of GL i 86-10 and is not consistent with these subsequent requirements. l l

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. U.S. Nuclear Regulatory Conunission Attachment 3F0998-09 Page 2 of17 i

Commitment Number: NOCS #01107 Source Document:

FPC to NRC letter 3F0580-02, dated May 2,1980, Nuclear Safety Task Force Priority items and Confirmatory Order for Crystal River Unit 3 dated 4/14/80.

Original Commitment:

ITEM 14  ;

Administrative Instruction 500, " Conduct of Operations," has been revised to provide the following guidelines: {

l. Plant stable and under control within existing equipment, procedures and personnel capability.

2. Surveillance of redundant equipment will be determined to be operable before removing the degraded equipment from service.

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3. Additional compensating measures shall be considered (i.e., dedicated operator, etc.). -j

4. Any equipment out of. service that causes entry into an action statement of Technical l Specifications shall be worked around the clock with all resources necessary to repair the equipment and place it back in service in the shortest possible time. i 1

5. If an emergency diesel is'to be taken out' of service, no equipment in the opposite )

Emergency Safeguards train can be out of service. )

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6. If " A" emergency diesel is taken out of service, the steam-driven EF pump shall be determined to be operable.  ;

i Revised Commitment:

ITEM 14  !

Procedural controls provide for the following:

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1. Plant stable and under control within existing equipment, procedures and personnel {

capability. I

2. Surveillance of redundant equipment will be determined to be operable before removing  !

the' degraded equipment from service.

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. U.S. Nuclear Regulttory Commission Attachment 3F0998 Page 3 of17 l

' 3. Additional compensating measures shall be considered (i.e., dedicated operator, etc.).  ;

'4.

Any equipment out of service that causes entry into an action statement of Technical Specifications shall be worked around the clock with all resources necessary to repair the 3 equipment and place it back in service in the shortest possible time. ,

i 5.' If an emergency diesel is to be taken out of service, no equipment in the opposite (

Emergency Safeguards train can be out of service. j

6. If "A" emergency diesel is taken out of service,- the steam-driven EF pump shall be l determined to be operable. j i

Justification for Change:  !

The only change to this commitment is " Administrative Instruction 500" is no longer the f

. implementing procedure.- Other' procedures now implement this commitment. Future l procedural implementation may change to provide appropriate implementation in other  ;

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. U.S. Nucl:ar Regulatory Commission Attachment 3F0998-09_ Page 4 of 17 Commitment Number: NOCS #01115  ;

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- Source Document: i FPC to NRC letter 3F0580-02, dated May 2,1980, Nuclear Safety Task Force Priority Items  ;

and Confirmatory Order for Crystal River Unit 3 dated 4/14/80. l Original Commitment: }

6 ITEM 27  !

Include in operator training and plant procedures methods ofisolating letdown and makeup in i the event ofloss ofICS or NNI power supplies. .

RESPONSE

The operator can isolate letdown from the control room by closure of makeup system valve MUV-49 or valves MUV-40 and MUV-41. These valves are the system containment isolation -

valves and are powered by Engineered Safeguard power which is independent of NNI and ICS  :

power supplies.  ;

Operators will be advised by training and procedure that these valves are available to isolate letdown in the event of a loss of NNI or ICS power supplies.

Revised Commitment:

ITEM 27 Include in operator training and plant procedures methods ofisolating letdown and makeup in ,

the event ofloss ofICS or NNI power supplies.  !

RESPONSE

The operator can isolate letdown from the control room by closure of makeup system valve l MUV-49 or valve MUV-567. These valves are system containment isolation valves and  !

receive an Engineered Safeguard actuation signal. Air operated valve MUV-49 is DC

. controlled from an Engineered Safeguard power source. Motor operated valve MUV-567 is  !

also Engineered Safeguard powered. Therefore, both of these valves are independent of NNI and ICS power supplies, i

Operators will be advised by training and procedure that these valves are available to isolate l

. letdown in the event of a loss of NNI or ICS power supphes.

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. U.S. Nuclear Regulatory Commission ' Attachment 3F0998 Page 5 of17 Justification for Change:

' Valves MUV-40 and MUV-41 are rated to close against a maximum differential pressure of i 1800 psid. Calculations have shown that these valves could be subject to differential pressure as high as 2380 psid under design basis conditions. A new valve (MUV-567) rated for these conditions has been -installed and replaces the. Engineered Safeguards Actuation System l containment isolation requirements of MUV-40/41.

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l U.S. Nuclear Regulatory Commission Attachment 3F0998-09 Page 6 of17 l i

Commitment Number: NOCS #01926 Source Document:

FPC to NRC letter 3F1179-27, dated November 11,1979, Notice of Violation.

Original Commitment:

The'CR-3 Chemistry and Radiation Protection ' staff has established a scheduled surveillance that requires a "once per shift" inspection of all accessible, posted, high radiation areas within the facility. These scheduled inspections will be conducted by Chem / Rad technicians and corrective actions taken, as required. The results of these inspections, including any -

discrepancies will be documented in the Health / Physics Log Book.

Revised Commitment:

FPC commits to implement and maintain the scheduled surveillance that requires a "once per shift" inspection of all routinely accessed posted high radiation areas within the facility. These i scheduled inspections will be conducted by Health Physics technicians and corrective actions taken, as required. The results of these inspections, including any discrepancies, will be i documented on either a special survey generated by the Health Physics routine, or documented j in the corrective action program. 1 Justification for Change:

The term " accessible" is changed to " routinely accessed" in order to implement the As Low As Reasonably Achievable (ALARA) concept in performing the surveillance. This will limit the requirement for Health Physics technicians to routinely inspect infrequently accessed high -

radiation areas and therefore reduce their radiation exposure.

Access to infrequently accessed high radiation areas is controlled by Radiation Work Permit ,

(RWP) and is denied to workers until areas are re-surveyed and current conditions established, infrequently accessed high radiation areas include high radiation areas inside locked high radiation areas, and areas that require additional equipment (e.g., ladders) to gain access. Since i personnel infrequently access these areas, and radiation workers are trained to properly replace control barriers, the potential to inadvertently defeat control barriers at infrequently accessed areas is low. Therefore, "once per shift" control barrier inspections at infrequently accessed high radiation areas is not necessary.

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. U.S. Nuclear Regulatory Commission Attachment 3F0998-09 Page 7 of 17 I

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Commitment Number: NOCS #09829 I

Source Document:

FPC to NRC letter 3F0398-20, dated March 12,1998, page 10, NRC Commitment Change Report for 1997.

y Original Commitment:

FPC has tightened the control over portable calibration instruments that are removed from the calibration laboratory during backshin hours.

1) A new signout log has been added in the control room to control the calibration lab key.

This log will be completed prior to the shift supervisor authorizing the removal of the key for entry into the calibration lab.

2) Any equipment signed out and removed from the calibration lab during the weekend or on backshifts will be logged on the measuring and test equipment control issue / return form.

Revised Commitment:

1) Access to the Calibration Laboratory other than normal working hours will be controlled.

Examples of controlled access include supervisor permission, security, video monitoring, or key entry.

2) Any equipment signed out and removed from the calibration lab during the weekend or on backshifts will be logged on the measuring and test equipment control issue /retum form.

Justification for Change:

Personnel entering the control room to sign out the calibration laboratory key are creating unnecessary traffic in the control room. Operations is attempting to minimize interruptions to control room operators. The purpose of controlling access to the calibration laboratory is to maintain control of test equipment.

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. : U.S. Nucirr Regulatory Commission Attachment -

3F0998-09 ~ Page 8 of 17 i;

Commitment Number: NOCS #26019

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1. FPC. to NRC letter 3F0390-01, dated ; March - 1, 1990, '10CFR26 " Fitness-For-Duty"'

Additional Drugs.

- 2. FPC to .NRC letter 3F0292-03, dated February 12,1992,10CFR26 Fitness-For-Duty-Program Performance Data (6 Month Report). I Original Commitment:

1. Below is a' list of 5 additional drugs which are included in the pre-access testing of FPC employees (non-contractors) and .for-cause testing of FPC employees (including contractors) with unescorted access. During initial screening, the following cut-offlevels are used when testing specimens for these additional drugs.

Initial Test Additional Drugs and Cut-Off Levels 1

' Barbiturates 300 ng/mi

. . Benzodiazepines ' 300 ng/ml

, . Propoxyphene. 300 ng/ml Methadone'- 300 ng/ml-Methaqualone 300 ng/ml Specimens identIfiedLas positive' on'the-initial screening will be confirmed using gas chromatography / mass spectrometry (GM/MS), at the cut-off levels listed below for each  ;

drug.

Confirmatory Test Additional Drugs and Cut-Off Levels ,

Barbiturates 200 ng/ml Benzodiazepines 200 ng/ml Propoxyphene 200 ng/mi

. Methadone 200 ng/ml

. Methaqualone 200 ng/ml a

p, 2. . As of July 1,1991, FPC will perform all contractor pre-access testing.

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U.S. Nuclear Regulatory Commission Attachment ,

3F0998-09. Page 9 of 17 Revised Commitment: 1 This commitment is INACTIVE.

' Justification for Change:

1. Testing for the additional drugs is above the requirements in 10CFR26. No problems .

have been'noted. FPC continues to test for the required 5 drugs and alcohol in 10CFR26.

2. .There is no requirement for FPC to perform all contractor pre-access testing. In the j future FPC . may elect .to utilize contractor pre :.ccess testing as warranted by  ;

. circumstances such as cost versus benefit.

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. U.S. Nuclear Regulatory Commission Attachment 1 3F0998-09 Page 10 of 17 Commitment Number: NOCS #40204 Source Document:

FPC to NRC letter 3F1288-12, dated December 16,1988, Inspection Report 88-29.

Original Commitment:

Procedure MP-101 will be revised to do a leak check after RTD replacement. Work requests .

will be reviewed using the Post Maintenance Testing Program Manual (PMTM) as guidance to establish appropriate post-maintenance testing.

Revised Commitment:

This commitment is INACTIVE.

Justification for Change:

The Reactor Coolant System (RCS) thermowells have been welded in place via Modification Approval Record (MAR) 95-05-02-01. Leak testing is no longer necessary.

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• 3F0998-09 Page11 of17 i

Commitment Number: NOCS #40376 j .

l Source Document:

1. FPC to NRC letter 3F0889-13, dated August 24,1989, LER89-028, page 4 of 4: Personnel Errors During Development of Revision to Surveillance Procedure Results in Containment L Integrity Valves Not Being Properly Surveilled.

2. FPC to NRC letter 3F0989-16, dated September 27,1989, inspection Report 89-19.

Original Commitment:

l. Surveillance Procedure SP-341 has been revised to include the affected valves. The b revision has been issued and performed as an interim to become permanent revision.

Additionally, emphasis will be placed on performing immediate verification following significant procedure revisions.

2. The Surveillance Procedure was revised, validated, and verified to ensure applicable containment integrity valves are fully addressed.

Revised Commitment:

k This commitment is INACTIVE.

5 l E Justification for Change: i l

This commitment resulted as a corrective action in LER89-028, and response to Violation 89-19-02. The problem reported was failure to surveil containment isolation valves in accordance with Standard Technical Specification 4.6.1.1.a.1 which stated.  :

I Primary containment integrity shall be demonstrated once per 31 days by verifying all penetrations not capable ofbeing closed by operable containment automatic isolation valves and required to be closed during accident conditions are closed by valves, blindflanges, or deactivated automatic valves secured in their positions, except ti.ose valves that may be opened under administrative controls per specification 3.6.3.1.

This problem was reported in error. The valves subject in this problem were not containment isolation valves, and no requirement existed to surveil them.

Main steam and feedwater water of pressurized water power reactors are not included for Type C testing in 10CFR50 Appendix J, Section II, Explanation of Terms H.4. Type C surveillance testing for main steam and feedwater valves is requised O boiling water power reactors. In Pressurized Water Reactors the main steam and feedwater lines are part of the containment boundary because it is a closed loop through containment. Furthermore, FPC's FSAR Table 6 5.9 does not require surveillance of these valves.

. U.S. Nuclear Regulatory Commission Attachment 3F0998-09 Page 12 of17 i

, Commitment Number: NOCS #40478 Source Document:

. FPC to NRC letter 3F1088-17, dated October 21, 1988, Preliminary Report LER88-023 regarding redundant power supplies for pressurizer heaters.

Original Commitment:

FPC is currently taking the following actions:

o Modify appropriate normal and abnormal operating procedures to reflect the single power  ;

source dependency of the interlock. ,

o This new alignment will be tested prior to restart to assure the sequence will indeed work as anticipated. This will be accomplished by utilizing a new periodic surveillance procedures.

Revised Commitment:

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This commitment is INACTIVE. ,

iustification for Change:  !

I A modification was installed (Modification Approval Record MAR 88-11-05-01) to provide the ,

capability to manually align up to three groups (126KW each) of pressurizer heaters to each  !

redundant emergency power source in the event of the loss of offsite power. This allows selection of the necessary quantity of pressurizer heaters required to maintain appropriate pressure in the reactor coolant system to ensure natural circulation cooling during a loss of  :

offsite power. l 1

The modification also removed the power supply for the pressurizer low-level interlock relay  ;

.from the non-safety related pressurizer heaters MCC power supply. Power for the new l low-level interlock is from the 120 volt AC Vital Bus source as is the instrument level loop. l This provides isolation between the safety-related level loop and the non-safety related pressurizer heater controls. Therefore, loss of the pressurizer heater MCC power supply will not prevent the use of the pressurizer heaters from redundant emergency power sources.

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U.S. Nuclear Regu'atory Commission Attachment 3F0998-09 Page 13 of17  !

Commitment Number: NOCS #62536 I

Source Document:  !

FPC to NRC letter 3F0297-01, dated February 8,1997, page 19, Response to Request for Information Pursuant to 10CFR50.54(f) Regarding the Adequacy / Availability of Design Basis

' information.  !

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Original Commitment:

Crystal River Unit 3 (CR-3) c trrently uses a tiered process to control changes to the facility I

and procedures. Nuclear Operations directive NOD-11 establishes the site-wide requirements l for maintaining the current licensing basis. This directive is based on the guidance of J NSAC-125/NEI 96-07. The dire:tive provides high-level guidance for evaluating activities in accordance with 10CFR50.59. Lower level department-specific procedures assure the requirements of the higher tier directive are implemented properly for appropriate activities.

Revised Commitment:

Procedure CP-213 establishes the site-wide requirements for evaluating changes to the facility in accordance with 10CFR50.59. This procedure is based on the guidance of NEI 96-07.

Administrative processes such as for Modification Approval Records (MARS), and changes to maintenance or operations procedures which have the potential to change the facility, refer to CP-213 for a 10CFR50.59 evaluation or assessment of the need for such an evaluation. Certain procedures such as AI-400C contain checklists which may be used to justify "non-intent" changes; however, these controls are recognized by CP-213.

Justification for Change: .

When the original commitment was made, FPC used a tiered process for controlling the {

10CFR50.59 process ~. ' This allowed for several lower tiered procedures to describe different l methods ofimplementing the guidance. Procedure CP-213 now replaces these multiple sets of l guidance and provides a centralized procedure with all organizational units using the same procedure for guidance, training, and format.

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. U.S. Nucl:ar Regulatory Commission Attachment 3F0998-09 Page 14 of 17 m

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Commitment Number: NOCS #62588 Source Document:

FPC to NRC letter 3F0697-12, dated June 16, 1997, NRC Notice of Violation, Integrated l Inspection Report No. 50-302/96-19.

Original Commitment:

From item 5 of page 3 in letter 3F0697-12:

Modifications are currently required to have a complete 10CFR50.59 evaluation even if the established screening requirements would result in none required. Under limited conditions, the Design Engineering Manager may waive the requirement for this 10CFR50.59 safety evaluation ifit is clear none is required. This process will continue until formal training and establishment of qualified reviewers for 10CFR50.59 evaluation is complete.

Revised Commitment:

This commitment is INACTIVE.

Justification for Change:

Formal training and qualification of personnel to perform 10CFR50.59 safety evaluations is complete. In the same letter referenced above, item 4 on page 5 states, "Only personnel who have been trained and qualified under the new program will be authorized to perform or review 10CFR50.59 evaluations after June 30, 1997." This commitment is archived under NOCS 62587 and encompasses the establishment of utilizing qualified reviewers for 10CFR50.59 evaluations. This commitment has been procedurally incorporated.

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. U.S. Nuclear Regulatory Commission Attachment 3F0998-09 Page 15 of17 *

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Commitment Number: NOCS #62802 l Source Document:

FPC to NRC letter 3Fil96-05, dated November 15,1996, page 7 of 7, Resolution of Spent Fuel Storage Pool Safety Issues: Information to Assist in the Backfit Analyses for Crystal River Unit 3.

Original Commitment:

OP-406 will be revised to require that SFV-83 and SFV-84 be closed and locked before the Fuel Transfer Covers are removed. Valves SFV-181 and SFV-182 '111 be required to be ,

closed and locked before the 30" gate valves are opened.

Revised Commitment:

Procedure OP-406 will be revised to require SFV-83 and SFV-84 be closed and locked before the Fuel Transfer Covers are removed. Valves SFV-180 and SFV-181 will be required to be  !

. closed and locked before the 30 inch gate valves are opened.

Justification for Change:

This commitment change corrects a typographical error. Valve SFV-182 was included in the origDal commitment. Valve SFV-180 replaces SFV-182 in this commitment.

. U.S. Nuclear Regulatory Commission Attachment 3F0998-09 Page 16 of 17 Commitment Number: NOCS #62809 Source Document:

FPC to NRC letter 3F0393-09, dated March 25,1993, Changes to the NDE/ISI Plan.

Original Commitment:

Attached please find copies of the updated administrative controls and program description sections of the Inservice Inspection Program which for the remainder of the second ten-year interval are provided as the ISI Plan. FPC will periodically submit revisions to these sections as they are updated.

Revised Commitment:

This commitment is INACTIVE. l Justification for Change:

There is no requirement to submit periodic revisions of the ISI Program / Plan after NRC approval of the 10 year ISI Program / Plan, as long as compliance with the ASME code of  !

record continues. As required by 10CFR50.55a, proposed alternatives to the ASME code must be submitted to the Director of the Office of Nuclear Reactor Regulation for approval.

Changes that create an unreviewed safety question are made in accordance with 10CFR50.59.

Therefore, inactivating the original commitment will eliminate the additional administrative burden for NRC and FPC.

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, U.S. Nuclear Regulatory Commission Attachment 3F0998-09 Page 17 of 17 ,

Commitment Number: NOCS #62847 Source Document:

FPC to NRC letter 3F1196-07, dated November 4,1996, Page. 4, Violation Notice No.

50-302/96-09.  ;

Original Commitment:

Nuclear Training is in the process of developing a video to be administered to all visitors. This

- video will add emphasis and improve communication of CR-3's expectations to our visitors for their conduct while on site.

Revised Commitment: ,

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This commitment is INACTIVE.'

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Justification for Change: l Experience has shown the video to add minimal value to the understanding of visitor and escort requirements. In letter 3F1196-07 on page 4, item 1, FPC stated, " A visitor and escort questionnaire was developed and implemented to assure both the visitor and escort have a complete understanding of the CR-3 expectations concerning escort and visitor requirements."

This commitment is archived under NOCS 62851. Tine questionnaire has become a good I indicator se the understanding of visitor and escon requirements, and provides immediate feedback v correct a lack of understanding for the visitor and escort.

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