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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217F9941999-10-15015 October 1999 Discusses FPC 970819 Request for Temporary Relief from ASME Code Section XI Requirements to Repair ASME Class 3 Nuclear Service & Decay Heat Sea Water System Piping.Forwards SE Containing Results of Staff Review ML20217J5171999-10-13013 October 1999 Informs That on 990930,NRC Staff Completed mid-cycle PPR of Plant,Unit 3 & Did Not Identify Any New Areas That Warranted More than Core Insp Program.Previously Planned Regional Initiative Insp of safety-related Mod Will Be Performed 3F1099-14, Requests Copy of NRC Radtrad Code & Copy of User Instructions.Conditions for Receiving Code Listed1999-10-13013 October 1999 Requests Copy of NRC Radtrad Code & Copy of User Instructions.Conditions for Receiving Code Listed 3F1099-11, Provides Info on Requested Minor Permit Mod of Encl NPDES Permit.No New Regulatory Commitments Are Made1999-10-0404 October 1999 Provides Info on Requested Minor Permit Mod of Encl NPDES Permit.No New Regulatory Commitments Are Made ML20212L0771999-10-0404 October 1999 Forwards SER Accepting Licensee Relief Requests 98-012 Through 98-018 Involving Containment Insps at Crystal River Unit 3 Pursuant to 10CFR50.55a(a)(3)(i) & 10CFR50.55a(a)(3)(ii) ML20217D6551999-10-0101 October 1999 Requests That Natl Communication Sys Arrange for Licensee Participation in Government Emergency Telecommunications Service,Per NRC Info Notice 99-025 ML20212J8481999-10-0101 October 1999 Forwards Safety Evaluation Re Second 10 Yr Interval ISI Program Requests for Relief 98-009-II.Reliefs Granted for 98-009-II,Parts B & C & 98-010-II & 98-011-II 3F0999-03, Notifies of Approved Change to NPDES Permit Applicable to Crystal River Unit 3 IAW Section 3.2.3 of Epp.Proposed Change Was Approved on 990914 by State of Fl & Provided in Attachment1999-09-27027 September 1999 Notifies of Approved Change to NPDES Permit Applicable to Crystal River Unit 3 IAW Section 3.2.3 of Epp.Proposed Change Was Approved on 990914 by State of Fl & Provided in Attachment 3F0999-18, Notifies NRC That Due Date for Commitment Common to Ltrs 980115 & 980209 Will Be Extended.Revised Completion Date for Cable Ampacity Project Is 0003311999-09-27027 September 1999 Notifies NRC That Due Date for Commitment Common to Ltrs 980115 & 980209 Will Be Extended.Revised Completion Date for Cable Ampacity Project Is 000331 ML20212F7251999-09-23023 September 1999 Discusses Staff Review of Util 980330 Response,As Suppl on 990514,to GL 97-06, Degradation of SG Internals. Staff Concludes That Licensee Responses to GL Provide Reasonable Assurance That Condition of SG Internals Acceptable ML20212F7331999-09-23023 September 1999 Discusses Util Licensing Action for GL 98-01, Year 2000 Readiness of Computer Systems at Nuclear Power Plants. NRC Ack Efforts Util Completed to Date in Preparing Crystal River,Unit 3 for Y2K Transition 3F0999-20, Forwards Summary Re Justification to Defer USI A-46 Commitment,Per Work Needed to Resolve GL 87-03, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors,Usi A-461999-09-21021 September 1999 Forwards Summary Re Justification to Defer USI A-46 Commitment,Per Work Needed to Resolve GL 87-03, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors,Usi A-46 ML20212E6741999-09-21021 September 1999 Forwards Safety Evaluation Accepting Proposed EAL Changes Submitted by ,As Supplemented by 981120,990713 & 0831 Ltrs,Incorporating Guidance in NUMARC/NESP-007,Rev 2, Methodology for Development of Eals 3F0999-01, Forwards FPC Crystal River Unit 3 Plant Reference Simulator Four-Year Simulator Certification Rept Sept 1995-Sept 1999, Per 10CFR55.45(b)(5)(ii) & 10CFR55.45(b)(5)(iv)1999-09-17017 September 1999 Forwards FPC Crystal River Unit 3 Plant Reference Simulator Four-Year Simulator Certification Rept Sept 1995-Sept 1999, Per 10CFR55.45(b)(5)(ii) & 10CFR55.45(b)(5)(iv) 3F0999-19, Provides Clarification of Minor Inconsistency Identified During Review of NRC SE for Plant Third 10-year Interval Inservice Insp Program Plan & Associated Requests for Relief1999-09-15015 September 1999 Provides Clarification of Minor Inconsistency Identified During Review of NRC SE for Plant Third 10-year Interval Inservice Insp Program Plan & Associated Requests for Relief ML20212F3141999-09-13013 September 1999 Forwards Insp Rept 50-302/99-05 on 990704-0814.Violations Noted,But Being Treated as non-cited Violations ML20211L9081999-09-0303 September 1999 Informs of Completion of Licensing Action for GL 92-08, Thermo-Lag 330-1 Fire Barriers, Dtd 921217,for Crystal River Unit 3 ML20211Q7581999-09-0101 September 1999 Forwards Summary of 990812-13 Training Managers Conference in Atlanta,Georgia Re Recent Changes to Operator Licensing Program.List Conference Attendees,Copy of Presentation Slides & List of Participant Questions Encl 3F0899-23, Provides Addl Info in Response to Several NRC Staff Questions Needed to Complete Review of Request to Adopt NEI 97-03,Draft Final Rev 3, Methodology for Development of Eals1999-08-31031 August 1999 Provides Addl Info in Response to Several NRC Staff Questions Needed to Complete Review of Request to Adopt NEI 97-03,Draft Final Rev 3, Methodology for Development of Eals ML20211G7111999-08-30030 August 1999 Modifies Approval of 980521 Request for Exception to 10CFR50.4(b)(6) & Grants Util Approval to Submit Copies of Future Updates to FSAR as Listed ML20211G7031999-08-30030 August 1999 Informs of Approval of Util 980521 Request for Exception to 10CFR50.4(b)(6),allowing Util to Submit Updates to Plant Ufsar.Ltr Modifies That Approval & Grants Util Approval 3F0899-07, Provides Formal Notification to NRC of FPC Plans Relative to Renewal of Crystal River Unit 3,FOL DPR-72.FPC Plans to Submit Application for License Renewal by End of 20021999-08-27027 August 1999 Provides Formal Notification to NRC of FPC Plans Relative to Renewal of Crystal River Unit 3,FOL DPR-72.FPC Plans to Submit Application for License Renewal by End of 2002 ML20212C1351999-08-27027 August 1999 Requests Withholding of Proprietary Version of Enhanced Spent Fuel Storage Project Engineering Input 3F0899-20, Forwards six-month fitness-for-duty Program Performance Data for Period 990101-990630,IAW 10CFR26.711999-08-26026 August 1999 Forwards six-month fitness-for-duty Program Performance Data for Period 990101-990630,IAW 10CFR26.71 3F0899-05, Forwards Response to NRC 990716 RAI Re Proposed Alternate Repair Criteria for Axial Tube End crack-like Indications in Crystal River Unit 31999-08-20020 August 1999 Forwards Response to NRC 990716 RAI Re Proposed Alternate Repair Criteria for Axial Tube End crack-like Indications in Crystal River Unit 3 3F0899-17, Submits Relief Request 99-0001-RR,seeking NRC Approval for Evaluation Performed by Util on through-wall Flaw in Nuclear Svc & Decay Heat Sea Water (RW) Sys,Per Guidance of GL 90-051999-08-19019 August 1999 Submits Relief Request 99-0001-RR,seeking NRC Approval for Evaluation Performed by Util on through-wall Flaw in Nuclear Svc & Decay Heat Sea Water (RW) Sys,Per Guidance of GL 90-05 3F0899-16, Informs That Licensee Is Requesting State of Fl Dept of Environ Protection to Make Changes in Plant NPDES Permit to Modify Conditions on Use of Biocide in Instrument Air Compressor Sys.No New Commitments Are Made in Submittal1999-08-19019 August 1999 Informs That Licensee Is Requesting State of Fl Dept of Environ Protection to Make Changes in Plant NPDES Permit to Modify Conditions on Use of Biocide in Instrument Air Compressor Sys.No New Commitments Are Made in Submittal 3F0899-02, Forwards Rev 2 to Cycle 11 COLR IAW Plant TS Section 5.6.2.18.Rev 1 of Cycle 11 COLR Was Not Submitted Due to Administrative Error.Changes Made in Rev 1 Listed & Incorporated in Encl Rev 21999-08-16016 August 1999 Forwards Rev 2 to Cycle 11 COLR IAW Plant TS Section 5.6.2.18.Rev 1 of Cycle 11 COLR Was Not Submitted Due to Administrative Error.Changes Made in Rev 1 Listed & Incorporated in Encl Rev 2 3F0899-06, Forwards Monthly Operating Rept for July 1999 for Crystal River,Unit 3,per ITS 5.7.1.2.Revised Repts for Apr,May & June 1999,also Encl.Data on Line Item 6 Updated to Agree with More Accurate Computer Point That Measures Value1999-08-13013 August 1999 Forwards Monthly Operating Rept for July 1999 for Crystal River,Unit 3,per ITS 5.7.1.2.Revised Repts for Apr,May & June 1999,also Encl.Data on Line Item 6 Updated to Agree with More Accurate Computer Point That Measures Value 05000302/LER-1997-038, Forwards LER 97-038-01,IAW 10CFR50.73(c).Submittal Also Provides Notification That Commitment Common to LER 97-038-00 & Reply to NOV 50-302/97-16 Has Been Revised & Revised Commitment Has Been Implemented1999-08-13013 August 1999 Forwards LER 97-038-01,IAW 10CFR50.73(c).Submittal Also Provides Notification That Commitment Common to LER 97-038-00 & Reply to NOV 50-302/97-16 Has Been Revised & Revised Commitment Has Been Implemented ML20210Q4511999-08-0505 August 1999 Informs That NRC Plans to Administer Generic Fundamentals Exam Section of Written Operator Licensing Exam on 991006 ML20210P0741999-08-0505 August 1999 Forwards SE Accepting Licensee 980416 & 1130 Ltrs Re Third 10-year Interval ISI Program Plan & Associated Requests for Relief for Plant,Unit 3 3F0799-30, Forwards List of Licensing Actions Currently Estimated for Fys 2000 & 2001,in Response to Administrative Ltr 99-02,dtd 9906031999-07-29029 July 1999 Forwards List of Licensing Actions Currently Estimated for Fys 2000 & 2001,in Response to Administrative Ltr 99-02,dtd 990603 ML20210G8551999-07-27027 July 1999 Forwards Insp Rept 50-302/99-04 on 990523-0703.One Violation Identified & Being Treated as Noncited Violation 3F0799-09, Provides Response to NRC 990625 Telcon RAI Re Util Use of Relief Request 98-009-II for Plant ASME Section XI, Inservice Insp Second Interval.Ltr Established No New Regulatory Commitments1999-07-19019 July 1999 Provides Response to NRC 990625 Telcon RAI Re Util Use of Relief Request 98-009-II for Plant ASME Section XI, Inservice Insp Second Interval.Ltr Established No New Regulatory Commitments ML20209H5211999-07-16016 July 1999 Forwards Request for Addl Info Re Licensee Proposed Alternate Repair Criteria for Axial Tube End crack-like Indications in CR-3 once-through Steam Generators in Order to Complete Review ML20209G3231999-07-15015 July 1999 Forwards Biological Opinion Issued by Natl Marine Fisheries (NMFS) of Dept of Commerce.Nmfs Concluded That Operation of Cw Intake Sys of Crystal River Not Likely to Jeopardize Existence of Species Listed in Biological Opinion ML20209G3481999-07-15015 July 1999 Transmits Natl Marine Fisheries Svc (NMFS) Biological Opinion Based on Review of Continued Use of Cw Intake Sys at Crystal River Energy Complex.Concludes That Continued Use of Cw Intake Sys Not Likely to Adversely Affect Gulf Sturgeon 3F0799-21, Forwards Copy of Revised NPDES Permit IAW Section 3.2.3 of Unit 3 Environ Protection Plan,Per 990430 Request to Allow Use of Biocide in Station Air Compressor Cooling Sys. Wastewater Permit FL0000159 Issued 990630 Also Encl1999-07-14014 July 1999 Forwards Copy of Revised NPDES Permit IAW Section 3.2.3 of Unit 3 Environ Protection Plan,Per 990430 Request to Allow Use of Biocide in Station Air Compressor Cooling Sys. Wastewater Permit FL0000159 Issued 990630 Also Encl 3F0799-05, Requests Exemption from 10CFR70.51, Matl Balance,Inventory & Records Requirements, as It Relates to 10CFR70.51(d) Re Physical Inventory of SNM for Crystal River Unit 3.Detailed Justification for Request,Encl1999-07-14014 July 1999 Requests Exemption from 10CFR70.51, Matl Balance,Inventory & Records Requirements, as It Relates to 10CFR70.51(d) Re Physical Inventory of SNM for Crystal River Unit 3.Detailed Justification for Request,Encl 3F0799-25, Forwards License Renewal Applications for Four Individuals, IAW 10CFR55.57.Without Encl1999-07-14014 July 1999 Forwards License Renewal Applications for Four Individuals, IAW 10CFR55.57.Without Encl 3F0799-26, Provides Notice of Change in Status for Senior Operator,Iaw 10CFR50.74(a).RD Demontfort,License Number SOP 20528-2,has Been Reassigned & No Longer Requires License Effective 9907301999-07-14014 July 1999 Provides Notice of Change in Status for Senior Operator,Iaw 10CFR50.74(a).RD Demontfort,License Number SOP 20528-2,has Been Reassigned & No Longer Requires License Effective 990730 3F0799-22, Provides Update & Rev to Submittal Made by Util Ltr with Regard to EAL Classification Methodology for Unit 3.Reponses to NRC Staff Questions Provided as Attachment D to Ltr & Reflects Discussions Held1999-07-13013 July 1999 Provides Update & Rev to Submittal Made by Util Ltr with Regard to EAL Classification Methodology for Unit 3.Reponses to NRC Staff Questions Provided as Attachment D to Ltr & Reflects Discussions Held 3F0799-03, Forwards Rev 5-0 to Safeguards Contingency Plan,Replacing Current Rev to Safeguards Contingency Plan,Rev 4,in Entirety.Rev Withheld,Per 10CFR73.211999-07-0808 July 1999 Forwards Rev 5-0 to Safeguards Contingency Plan,Replacing Current Rev to Safeguards Contingency Plan,Rev 4,in Entirety.Rev Withheld,Per 10CFR73.21 3F0799-02, Submits Rev 7-3 to Physical Security Plan,Replacing Current Rev to CR-3 Physical Security Plan,Rev 7-2,in Entirety.Rev Withheld,Per 10CFR73.211999-07-0808 July 1999 Submits Rev 7-3 to Physical Security Plan,Replacing Current Rev to CR-3 Physical Security Plan,Rev 7-2,in Entirety.Rev Withheld,Per 10CFR73.21 ML20196L1261999-07-0707 July 1999 Discusses Closeout of TAC MA0538 Re License Response to RAI Re GL 92-01,Rev 1,Suppl 1, Rv Structural Integrity, Issued on 950519 to Plant,Unit 3 3F0799-10, Submits Copy of Historical NPDES Permit Rev That Was Made in 1997 Re Use of Biocide at Crystal River Unit 31999-07-0707 July 1999 Submits Copy of Historical NPDES Permit Rev That Was Made in 1997 Re Use of Biocide at Crystal River Unit 3 ML20196J4991999-07-0101 July 1999 Advises That Info Contained in ,Which Included TR BAW-2346P,will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5) ML20209C0811999-06-25025 June 1999 Forwards Overdue Controlled Document Transmittals for Listed Documents 3F0699-06, Submits Final Response to GL 98-01,Suppl 1 Re Year 2000 Readiness of Nuclear Power Plants.Year 2000 Readiness Disclosure for Crystal River,Unit 3,encl1999-06-23023 June 1999 Submits Final Response to GL 98-01,Suppl 1 Re Year 2000 Readiness of Nuclear Power Plants.Year 2000 Readiness Disclosure for Crystal River,Unit 3,encl 1999-09-03
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEAR3F1099-14, Requests Copy of NRC Radtrad Code & Copy of User Instructions.Conditions for Receiving Code Listed1999-10-13013 October 1999 Requests Copy of NRC Radtrad Code & Copy of User Instructions.Conditions for Receiving Code Listed 3F1099-11, Provides Info on Requested Minor Permit Mod of Encl NPDES Permit.No New Regulatory Commitments Are Made1999-10-0404 October 1999 Provides Info on Requested Minor Permit Mod of Encl NPDES Permit.No New Regulatory Commitments Are Made 3F0999-03, Notifies of Approved Change to NPDES Permit Applicable to Crystal River Unit 3 IAW Section 3.2.3 of Epp.Proposed Change Was Approved on 990914 by State of Fl & Provided in Attachment1999-09-27027 September 1999 Notifies of Approved Change to NPDES Permit Applicable to Crystal River Unit 3 IAW Section 3.2.3 of Epp.Proposed Change Was Approved on 990914 by State of Fl & Provided in Attachment 3F0999-18, Notifies NRC That Due Date for Commitment Common to Ltrs 980115 & 980209 Will Be Extended.Revised Completion Date for Cable Ampacity Project Is 0003311999-09-27027 September 1999 Notifies NRC That Due Date for Commitment Common to Ltrs 980115 & 980209 Will Be Extended.Revised Completion Date for Cable Ampacity Project Is 000331 3F0999-20, Forwards Summary Re Justification to Defer USI A-46 Commitment,Per Work Needed to Resolve GL 87-03, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors,Usi A-461999-09-21021 September 1999 Forwards Summary Re Justification to Defer USI A-46 Commitment,Per Work Needed to Resolve GL 87-03, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors,Usi A-46 3F0999-01, Forwards FPC Crystal River Unit 3 Plant Reference Simulator Four-Year Simulator Certification Rept Sept 1995-Sept 1999, Per 10CFR55.45(b)(5)(ii) & 10CFR55.45(b)(5)(iv)1999-09-17017 September 1999 Forwards FPC Crystal River Unit 3 Plant Reference Simulator Four-Year Simulator Certification Rept Sept 1995-Sept 1999, Per 10CFR55.45(b)(5)(ii) & 10CFR55.45(b)(5)(iv) 3F0999-19, Provides Clarification of Minor Inconsistency Identified During Review of NRC SE for Plant Third 10-year Interval Inservice Insp Program Plan & Associated Requests for Relief1999-09-15015 September 1999 Provides Clarification of Minor Inconsistency Identified During Review of NRC SE for Plant Third 10-year Interval Inservice Insp Program Plan & Associated Requests for Relief 3F0899-23, Provides Addl Info in Response to Several NRC Staff Questions Needed to Complete Review of Request to Adopt NEI 97-03,Draft Final Rev 3, Methodology for Development of Eals1999-08-31031 August 1999 Provides Addl Info in Response to Several NRC Staff Questions Needed to Complete Review of Request to Adopt NEI 97-03,Draft Final Rev 3, Methodology for Development of Eals ML20212C1351999-08-27027 August 1999 Requests Withholding of Proprietary Version of Enhanced Spent Fuel Storage Project Engineering Input 3F0899-07, Provides Formal Notification to NRC of FPC Plans Relative to Renewal of Crystal River Unit 3,FOL DPR-72.FPC Plans to Submit Application for License Renewal by End of 20021999-08-27027 August 1999 Provides Formal Notification to NRC of FPC Plans Relative to Renewal of Crystal River Unit 3,FOL DPR-72.FPC Plans to Submit Application for License Renewal by End of 2002 3F0899-20, Forwards six-month fitness-for-duty Program Performance Data for Period 990101-990630,IAW 10CFR26.711999-08-26026 August 1999 Forwards six-month fitness-for-duty Program Performance Data for Period 990101-990630,IAW 10CFR26.71 3F0899-05, Forwards Response to NRC 990716 RAI Re Proposed Alternate Repair Criteria for Axial Tube End crack-like Indications in Crystal River Unit 31999-08-20020 August 1999 Forwards Response to NRC 990716 RAI Re Proposed Alternate Repair Criteria for Axial Tube End crack-like Indications in Crystal River Unit 3 3F0899-16, Informs That Licensee Is Requesting State of Fl Dept of Environ Protection to Make Changes in Plant NPDES Permit to Modify Conditions on Use of Biocide in Instrument Air Compressor Sys.No New Commitments Are Made in Submittal1999-08-19019 August 1999 Informs That Licensee Is Requesting State of Fl Dept of Environ Protection to Make Changes in Plant NPDES Permit to Modify Conditions on Use of Biocide in Instrument Air Compressor Sys.No New Commitments Are Made in Submittal 3F0899-17, Submits Relief Request 99-0001-RR,seeking NRC Approval for Evaluation Performed by Util on through-wall Flaw in Nuclear Svc & Decay Heat Sea Water (RW) Sys,Per Guidance of GL 90-051999-08-19019 August 1999 Submits Relief Request 99-0001-RR,seeking NRC Approval for Evaluation Performed by Util on through-wall Flaw in Nuclear Svc & Decay Heat Sea Water (RW) Sys,Per Guidance of GL 90-05 3F0899-02, Forwards Rev 2 to Cycle 11 COLR IAW Plant TS Section 5.6.2.18.Rev 1 of Cycle 11 COLR Was Not Submitted Due to Administrative Error.Changes Made in Rev 1 Listed & Incorporated in Encl Rev 21999-08-16016 August 1999 Forwards Rev 2 to Cycle 11 COLR IAW Plant TS Section 5.6.2.18.Rev 1 of Cycle 11 COLR Was Not Submitted Due to Administrative Error.Changes Made in Rev 1 Listed & Incorporated in Encl Rev 2 05000302/LER-1997-038, Forwards LER 97-038-01,IAW 10CFR50.73(c).Submittal Also Provides Notification That Commitment Common to LER 97-038-00 & Reply to NOV 50-302/97-16 Has Been Revised & Revised Commitment Has Been Implemented1999-08-13013 August 1999 Forwards LER 97-038-01,IAW 10CFR50.73(c).Submittal Also Provides Notification That Commitment Common to LER 97-038-00 & Reply to NOV 50-302/97-16 Has Been Revised & Revised Commitment Has Been Implemented 3F0899-06, Forwards Monthly Operating Rept for July 1999 for Crystal River,Unit 3,per ITS 5.7.1.2.Revised Repts for Apr,May & June 1999,also Encl.Data on Line Item 6 Updated to Agree with More Accurate Computer Point That Measures Value1999-08-13013 August 1999 Forwards Monthly Operating Rept for July 1999 for Crystal River,Unit 3,per ITS 5.7.1.2.Revised Repts for Apr,May & June 1999,also Encl.Data on Line Item 6 Updated to Agree with More Accurate Computer Point That Measures Value 3F0799-30, Forwards List of Licensing Actions Currently Estimated for Fys 2000 & 2001,in Response to Administrative Ltr 99-02,dtd 9906031999-07-29029 July 1999 Forwards List of Licensing Actions Currently Estimated for Fys 2000 & 2001,in Response to Administrative Ltr 99-02,dtd 990603 3F0799-09, Provides Response to NRC 990625 Telcon RAI Re Util Use of Relief Request 98-009-II for Plant ASME Section XI, Inservice Insp Second Interval.Ltr Established No New Regulatory Commitments1999-07-19019 July 1999 Provides Response to NRC 990625 Telcon RAI Re Util Use of Relief Request 98-009-II for Plant ASME Section XI, Inservice Insp Second Interval.Ltr Established No New Regulatory Commitments ML20209G3481999-07-15015 July 1999 Transmits Natl Marine Fisheries Svc (NMFS) Biological Opinion Based on Review of Continued Use of Cw Intake Sys at Crystal River Energy Complex.Concludes That Continued Use of Cw Intake Sys Not Likely to Adversely Affect Gulf Sturgeon 3F0799-25, Forwards License Renewal Applications for Four Individuals, IAW 10CFR55.57.Without Encl1999-07-14014 July 1999 Forwards License Renewal Applications for Four Individuals, IAW 10CFR55.57.Without Encl 3F0799-21, Forwards Copy of Revised NPDES Permit IAW Section 3.2.3 of Unit 3 Environ Protection Plan,Per 990430 Request to Allow Use of Biocide in Station Air Compressor Cooling Sys. Wastewater Permit FL0000159 Issued 990630 Also Encl1999-07-14014 July 1999 Forwards Copy of Revised NPDES Permit IAW Section 3.2.3 of Unit 3 Environ Protection Plan,Per 990430 Request to Allow Use of Biocide in Station Air Compressor Cooling Sys. Wastewater Permit FL0000159 Issued 990630 Also Encl 3F0799-05, Requests Exemption from 10CFR70.51, Matl Balance,Inventory & Records Requirements, as It Relates to 10CFR70.51(d) Re Physical Inventory of SNM for Crystal River Unit 3.Detailed Justification for Request,Encl1999-07-14014 July 1999 Requests Exemption from 10CFR70.51, Matl Balance,Inventory & Records Requirements, as It Relates to 10CFR70.51(d) Re Physical Inventory of SNM for Crystal River Unit 3.Detailed Justification for Request,Encl 3F0799-26, Provides Notice of Change in Status for Senior Operator,Iaw 10CFR50.74(a).RD Demontfort,License Number SOP 20528-2,has Been Reassigned & No Longer Requires License Effective 9907301999-07-14014 July 1999 Provides Notice of Change in Status for Senior Operator,Iaw 10CFR50.74(a).RD Demontfort,License Number SOP 20528-2,has Been Reassigned & No Longer Requires License Effective 990730 3F0799-22, Provides Update & Rev to Submittal Made by Util Ltr with Regard to EAL Classification Methodology for Unit 3.Reponses to NRC Staff Questions Provided as Attachment D to Ltr & Reflects Discussions Held1999-07-13013 July 1999 Provides Update & Rev to Submittal Made by Util Ltr with Regard to EAL Classification Methodology for Unit 3.Reponses to NRC Staff Questions Provided as Attachment D to Ltr & Reflects Discussions Held 3F0799-02, Submits Rev 7-3 to Physical Security Plan,Replacing Current Rev to CR-3 Physical Security Plan,Rev 7-2,in Entirety.Rev Withheld,Per 10CFR73.211999-07-0808 July 1999 Submits Rev 7-3 to Physical Security Plan,Replacing Current Rev to CR-3 Physical Security Plan,Rev 7-2,in Entirety.Rev Withheld,Per 10CFR73.21 3F0799-03, Forwards Rev 5-0 to Safeguards Contingency Plan,Replacing Current Rev to Safeguards Contingency Plan,Rev 4,in Entirety.Rev Withheld,Per 10CFR73.211999-07-0808 July 1999 Forwards Rev 5-0 to Safeguards Contingency Plan,Replacing Current Rev to Safeguards Contingency Plan,Rev 4,in Entirety.Rev Withheld,Per 10CFR73.21 3F0799-10, Submits Copy of Historical NPDES Permit Rev That Was Made in 1997 Re Use of Biocide at Crystal River Unit 31999-07-0707 July 1999 Submits Copy of Historical NPDES Permit Rev That Was Made in 1997 Re Use of Biocide at Crystal River Unit 3 ML20209C0811999-06-25025 June 1999 Forwards Overdue Controlled Document Transmittals for Listed Documents 3F0699-12, Provides Suppl Info for LAR 240,rev 0 & Pump Curve for EFP-3 to Facilitate Review,As Requested1999-06-23023 June 1999 Provides Suppl Info for LAR 240,rev 0 & Pump Curve for EFP-3 to Facilitate Review,As Requested 3F0699-06, Submits Final Response to GL 98-01,Suppl 1 Re Year 2000 Readiness of Nuclear Power Plants.Year 2000 Readiness Disclosure for Crystal River,Unit 3,encl1999-06-23023 June 1999 Submits Final Response to GL 98-01,Suppl 1 Re Year 2000 Readiness of Nuclear Power Plants.Year 2000 Readiness Disclosure for Crystal River,Unit 3,encl 3F0699-08, Provides Updated Info to Licensee Response to GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions. Ltr Establishes No New Regulatory Commitments1999-06-21021 June 1999 Provides Updated Info to Licensee Response to GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions. Ltr Establishes No New Regulatory Commitments 3F0699-09, Forwards FPC 1998 Annual Financial Repts for Two Participating co-owners of Crystal River Unit 3.Financial Statements & Independent Auditors Repts for City of Alachua,Fl,Encl1999-06-0404 June 1999 Forwards FPC 1998 Annual Financial Repts for Two Participating co-owners of Crystal River Unit 3.Financial Statements & Independent Auditors Repts for City of Alachua,Fl,Encl 3F0599-21, Submits Addendum to B&W Owners Group Topical Rept BAW-2346P, Rev 0.Addendum Includes Leak Rate Values Based on CR-3 Plant Specific Main Steam Line Break Tube Loads1999-05-28028 May 1999 Submits Addendum to B&W Owners Group Topical Rept BAW-2346P, Rev 0.Addendum Includes Leak Rate Values Based on CR-3 Plant Specific Main Steam Line Break Tube Loads 3F0599-10, Submits Changes Made to Crystal River,Unit 3 Its,As Required by ITS 5.6.2.17.Encl Provides Revs to Plant ITS Bases That Will Update NRC Copies of Its.Instructions for Updating ITS, Encl1999-05-26026 May 1999 Submits Changes Made to Crystal River,Unit 3 Its,As Required by ITS 5.6.2.17.Encl Provides Revs to Plant ITS Bases That Will Update NRC Copies of Its.Instructions for Updating ITS, Encl ML20207E4341999-05-25025 May 1999 Submits 30-day Written Rept on Significant PCT Changes in ECCS Analysis for ANO-1.CRAFT2 Limiting PCT for ANO-1 Was Bounded by 1859 F PCT Calculated at 2568 Mwt for Crystal River 3 Cold Leg Pump Discharge Break Size of 0.125 Ft 3F0599-22, Forwards non-proprietary Version of B&Wog Topical Rept BAW-2346NP, Alternate Repair Criteria for Tube End Cracking in Tube-to-Tubesheet Roll Joint of Once-Through Sgs1999-05-21021 May 1999 Forwards non-proprietary Version of B&Wog Topical Rept BAW-2346NP, Alternate Repair Criteria for Tube End Cracking in Tube-to-Tubesheet Roll Joint of Once-Through Sgs 3F0599-18, Forwards 1998 Annual Radiological Environ Operating Rept for Crystal River,Unit 3. Rept Is Submitted in Accordance with CR-3 ITS 5.7.1.1(b) & Section 6.6 of ODCM1999-05-14014 May 1999 Forwards 1998 Annual Radiological Environ Operating Rept for Crystal River,Unit 3. Rept Is Submitted in Accordance with CR-3 ITS 5.7.1.1(b) & Section 6.6 of ODCM 3F0599-17, Submits Update Response to GL 97-06, Degradation of SG Internals. Ltr Establishes No New Regulatory Commitments1999-05-14014 May 1999 Submits Update Response to GL 97-06, Degradation of SG Internals. Ltr Establishes No New Regulatory Commitments 3F0599-07, Submits Guarantee of Payment of Deferred Premiums for CR-3 in Accordance with 10CFR140.21.Internal Cash Flow Projection Was Prepared in Accordance with Suggested Format Outlined in Reg Guide 9.4 Dtd Sept 19781999-05-14014 May 1999 Submits Guarantee of Payment of Deferred Premiums for CR-3 in Accordance with 10CFR140.21.Internal Cash Flow Projection Was Prepared in Accordance with Suggested Format Outlined in Reg Guide 9.4 Dtd Sept 1978 3F0599-03, Provides Update Curves for Facility Pressure/Temp Limits Rept,Rev 2 & Updated Rev Bar ITS Pages Associated with LAR, in Response to NRC RAI Re Subject LAR1999-05-12012 May 1999 Provides Update Curves for Facility Pressure/Temp Limits Rept,Rev 2 & Updated Rev Bar ITS Pages Associated with LAR, in Response to NRC RAI Re Subject LAR 3F0599-05, Responds to 990402 RAI Re Third 10-year Interval ISI Program Plan Requests for Relief.Util Revised Relief Requests 98-010-II,98-003-PT,98-005-PT & 98-001-SS Based on Responses to Rai.Revised Relief Requests Encl1999-05-12012 May 1999 Responds to 990402 RAI Re Third 10-year Interval ISI Program Plan Requests for Relief.Util Revised Relief Requests 98-010-II,98-003-PT,98-005-PT & 98-001-SS Based on Responses to Rai.Revised Relief Requests Encl 3F0599-08, Forwards Licensee Clarification of Info Provided in Amend 171 Re post-LOCA Boron Dilution Precipitation Prevention.Ltr Establishes No New Regulatory Commitments1999-05-0303 May 1999 Forwards Licensee Clarification of Info Provided in Amend 171 Re post-LOCA Boron Dilution Precipitation Prevention.Ltr Establishes No New Regulatory Commitments 3F0599-09, Forwards Crystal River Unit 3 Radioactive Effluent Release Rept - 1998 & Revised Crystal River Unit 3 Radioactive Effluent Release Rept - 1997. Licensee Informs That ODCM & PCP Were Not Revised During 19981999-05-0101 May 1999 Forwards Crystal River Unit 3 Radioactive Effluent Release Rept - 1998 & Revised Crystal River Unit 3 Radioactive Effluent Release Rept - 1997. Licensee Informs That ODCM & PCP Were Not Revised During 1998 3F0499-24, Forwards Summary of Proposed Changes to Crystal River,Unit 3 NPDES Permit,That Are Being Submitted to Florida Dept of Environ Protection.Proposed Change Will Allow Use of Scale Inhibitor,Biocides & Foam Control Agent1999-04-30030 April 1999 Forwards Summary of Proposed Changes to Crystal River,Unit 3 NPDES Permit,That Are Being Submitted to Florida Dept of Environ Protection.Proposed Change Will Allow Use of Scale Inhibitor,Biocides & Foam Control Agent 3F0499-09, Forwards FPC Annual Financial Rept & Annual Financial Repts for Eight of Ten Participating co-owners of Crystal River Unit 3 Nuclear Station.Outstanding Annual Financial Rept Will Be Submitted by 9907301999-04-30030 April 1999 Forwards FPC Annual Financial Rept & Annual Financial Repts for Eight of Ten Participating co-owners of Crystal River Unit 3 Nuclear Station.Outstanding Annual Financial Rept Will Be Submitted by 990730 3F0499-23, Submits Repts Required by App B,Environ Protection Plan,Of Crystal River,Unit 3 Operating License.Fl Dept of Environ Protection Has Provided Clarification Re Ph Monitoring Requirements1999-04-23023 April 1999 Submits Repts Required by App B,Environ Protection Plan,Of Crystal River,Unit 3 Operating License.Fl Dept of Environ Protection Has Provided Clarification Re Ph Monitoring Requirements 3F0499-18, Informs of Recent Senior Management Change at Fpc,Which Will Not Affect Std Recipients of Incoming NRC Correspondence. Updated Util Mailing List,Encl1999-04-20020 April 1999 Informs of Recent Senior Management Change at Fpc,Which Will Not Affect Std Recipients of Incoming NRC Correspondence. Updated Util Mailing List,Encl 3F0499-05, Forwards Rev 19 to Radiological Emergency Response Plan. Changes to Plan Marked with Vertical Bars in Left Margin1999-04-16016 April 1999 Forwards Rev 19 to Radiological Emergency Response Plan. Changes to Plan Marked with Vertical Bars in Left Margin 3F0499-08, Forwards FPC Annual ITS Dose Rept for Period Jan-Dec 1998. Rept Provides person-rem Radiation Exposures,According to Work & Job Function,At CR-3 for Period Jan-Dec 19981999-04-16016 April 1999 Forwards FPC Annual ITS Dose Rept for Period Jan-Dec 1998. Rept Provides person-rem Radiation Exposures,According to Work & Job Function,At CR-3 for Period Jan-Dec 1998 1999-09-27
[Table view] Category:UTILITY TO NRC
MONTHYEAR3F0990-11, Forwards Final Status Update Re Design & Operations Verification for Instrument Air Sys Per Generic Ltr 88-141990-09-20020 September 1990 Forwards Final Status Update Re Design & Operations Verification for Instrument Air Sys Per Generic Ltr 88-14 3F0990-05, Forwards 1990 Inservice Insp Summary Rept. Rept Contains Owners Data Rept,Data Summary Sections for Class 1,2 & 3 Components,Rept for Repair & Replacements & Listing of Exams1990-09-14014 September 1990 Forwards 1990 Inservice Insp Summary Rept. Rept Contains Owners Data Rept,Data Summary Sections for Class 1,2 & 3 Components,Rept for Repair & Replacements & Listing of Exams 3F0990-08, Forwards Response to Violations Noted in Insp Rept 50-302/90-23.Corrective Actions:Training Session Conducted to Stress Importance of Attachments Being Part of Work Package When Required by Procedure1990-09-13013 September 1990 Forwards Response to Violations Noted in Insp Rept 50-302/90-23.Corrective Actions:Training Session Conducted to Stress Importance of Attachments Being Part of Work Package When Required by Procedure 3F0890-23, Discusses Decommissioning Financial Assurance Rept Dtd 900726.Amount Util Collecting Exceeds Amount Necessary Based on NRC Formula & Does Not Include Estimated Cost of Removal & Disposal of Nonradioactive Structures & Matls1990-08-30030 August 1990 Discusses Decommissioning Financial Assurance Rept Dtd 900726.Amount Util Collecting Exceeds Amount Necessary Based on NRC Formula & Does Not Include Estimated Cost of Removal & Disposal of Nonradioactive Structures & Matls ML20028G8251990-08-29029 August 1990 Advises That Supplemental Response to Insp Rept 50-302/89-18 Will Be Submitted by 901030 ML20059G1721990-08-24024 August 1990 Submits Info Re Change in Operator License Status.Re Rawls & Wa Stephenson Senior Reactor Licenses Should Be Terminated, Effective 900817 Due to Reassignment from Position Requiring Licenses 3F0890-15, Forwards Fitness for Duty Program Performance Data for Period of Jan-Jun 19901990-08-23023 August 1990 Forwards Fitness for Duty Program Performance Data for Period of Jan-Jun 1990 3F0890-21, Forwards Semiannual Radioactive Release Rept Jan-June 1990 for Crystal River Unit 3 & Rev 15 to Crystal River Unit 3 Odcm1990-08-23023 August 1990 Forwards Semiannual Radioactive Release Rept Jan-June 1990 for Crystal River Unit 3 & Rev 15 to Crystal River Unit 3 Odcm ML20059A0031990-08-16016 August 1990 Responds to NRC 900613 Request for Addl Info Re Util 871222 Response to Violations Noted in Insp Rept 50-302/87-30 3F0890-03, Forwards Rev 11 to Inservice Insp - Pump & Valve Program, Crystal River Unit 31990-08-16016 August 1990 Forwards Rev 11 to Inservice Insp - Pump & Valve Program, Crystal River Unit 3 3F0890-10, Advises That Util Completed Mods to Comply w/10CFR50.62 Requirements Re Reduction of Risk from ATWS Events1990-08-16016 August 1990 Advises That Util Completed Mods to Comply w/10CFR50.62 Requirements Re Reduction of Risk from ATWS Events 3F0890-05, Forwards Addl Info Re Response to Mode 3 Loca,Per 900711 Request,Providing Background of Factors Considered During Evaluation of Tech Spec Change Request 1741990-08-10010 August 1990 Forwards Addl Info Re Response to Mode 3 Loca,Per 900711 Request,Providing Background of Factors Considered During Evaluation of Tech Spec Change Request 174 ML20058L2001990-08-0202 August 1990 Provides Current Status of Reg Guide 1.97 Activities. Pressurizer Heater Status & Main Steam Safety/Relief Valve Position Indications Completed 3F0790-10, Forwards Justification for Continued Operation Re Emergency Diesel Generator Block Loading Voltage Dips.Util Will Install Higher Accuracy Relays to Improve on Accuracy & Repeatability of Load Intervals1990-07-18018 July 1990 Forwards Justification for Continued Operation Re Emergency Diesel Generator Block Loading Voltage Dips.Util Will Install Higher Accuracy Relays to Improve on Accuracy & Repeatability of Load Intervals 3F0790-06, Forwards Rev 1 to Cycle 8 Core Operating Limits Rept, Correcting Typo in Note 1 of Figures 1-8 & Note 2 of Figures 1,2 & 4-81990-07-12012 July 1990 Forwards Rev 1 to Cycle 8 Core Operating Limits Rept, Correcting Typo in Note 1 of Figures 1-8 & Note 2 of Figures 1,2 & 4-8 ML20055D5561990-06-29029 June 1990 Forwards 890505 & s to Be Placed in Plant File 3F0690-15, Informs That Tech Spec Actions Identified in Util Addressed as Part of Tech Spec Improvement Program,Per 900518 Request for Programmed Enhancements for Generic Ltr 88-171990-06-29029 June 1990 Informs That Tech Spec Actions Identified in Util Addressed as Part of Tech Spec Improvement Program,Per 900518 Request for Programmed Enhancements for Generic Ltr 88-17 3F0690-22, Forwards Annual Financial Repts for 1989 for Orlando Utils Commission & Cities of Bushnell,Leesburg,Ocala & Tallahassee,Per 10CFR50.71(b)1990-06-27027 June 1990 Forwards Annual Financial Repts for 1989 for Orlando Utils Commission & Cities of Bushnell,Leesburg,Ocala & Tallahassee,Per 10CFR50.71(b) 3F0690-19, Responds to Deviations Noted in Insp Rept 50-302/90-15. Corrective Actions:All Reg Guide 1.97 Category 1 Instruments on Main Control Board Marked & Engineered Safeguards Matrix Indicating Lights Arranged in Unique Array1990-06-25025 June 1990 Responds to Deviations Noted in Insp Rept 50-302/90-15. Corrective Actions:All Reg Guide 1.97 Category 1 Instruments on Main Control Board Marked & Engineered Safeguards Matrix Indicating Lights Arranged in Unique Array ML20043H5781990-06-21021 June 1990 Responds to Generic Ltr 89-06, Spds. All Open Issues Identified in NRC SER & Plant SPDS Satisfies NUREG-0737, Item I.D.2 & Suppl 1 ML20044A6121990-06-21021 June 1990 Forwards Payment of Civil Penalty,Per NRC 900524 Order Based on Findings in Insp Rept 50-302/89-09 ML20043J0221990-06-21021 June 1990 Submits Info in Support of Tech Spec Change Request 175,Rev 1,Suppl 1 Re Spent Fuel Pool Storage Capacity at Plant ML20043H4151990-06-21021 June 1990 Forwards Response to Generic Ltr 90-04, Request for Info on Status of Licensee Implementation of Generic Safety Issues Resolved W/Imposition of Requirements or Corrective Actions. 3F0690-18, Responds to Violations Noted in Insp Rept 50-302/90-09. Corrective Action:Temporary Lettering Placed on Index Plates for Consistency W/Previous Markings Immediately Following Discovery of Error1990-06-20020 June 1990 Responds to Violations Noted in Insp Rept 50-302/90-09. Corrective Action:Temporary Lettering Placed on Index Plates for Consistency W/Previous Markings Immediately Following Discovery of Error ML20043H2901990-06-15015 June 1990 Forwards Results of Refuel 7 once-through Steam Generator (OTSG) Eddy Current Insp,Per Tech Spec Section 4.4.5.5.Eight Defective Tubes & Two Administratively Plugged Tubes in OTSG a Resulted from Review of Insp Data ML20044A0641990-06-13013 June 1990 Forwards Rev 5 to Physical Security Plan,Replacing Currently Approved Rev 4 W/Amends.Rev Withheld (Ref 10CFR73.21) ML20043G2271990-06-12012 June 1990 Suppls 900604 Ltr Describing How Control Room Habitability Dose Would Be Adversely Affected by Elimination of Reactor Bldg Flood Vol Unless Overly Conservative Failure Postulations Also Changed.Quarterly Updates to Be Provided ML20043G3711990-06-12012 June 1990 Forwards 1990 Internal Cash Flow Projection for Plant Which Updates Utils Utilization of Alternative (E) ML20043G2361990-06-12012 June 1990 Forwards Info Re Fire Protection Sys Reliability for Providing Water to Intermediate Bldg Following High Energy Line Break.B&W Issued Contract to Verify Mass/Energy Release & Motor Starters & Terminal Blocks Insulated ML20043F1601990-06-0404 June 1990 Provides Supplemental Info on Reactor Bldg Flooding,Per Util 900517 Ltr Describing Resolution Plan Being Pursued.Util Has Limited Vol of Water Contributed by Borated Water Storage Tank & Sodium Hydroxide Tank to Flood Level ML20043C8721990-05-31031 May 1990 Forwards Rev 0 to Crystal River Unit 3 Cycle 8 Core Operating Limits Rept, Per Tech Spec 6.9.1.7 ML20043B8431990-05-24024 May 1990 Describes Alternative Testing of Reactor Bldg Spray Suction Valves BSV-1 & BSV-8,per Generic Ltr 89-04.At Least One Valve Will Be Disassembled & Inspected During Each Refueling Outage Using Alternate Insp Method ML20043B2771990-05-18018 May 1990 Advises of Mod to Original Commitment & Plans to Store Seal Ring in Original Storage Location During Plant Operations, Per 790606 Ltr.Mod Minimizes Personnel Exposure & Enhances Seal Plate Leak Tightness Due to Less Handling ML20043B0321990-05-17017 May 1990 Provides Details of Resolution Util Will Pursue Re Reactor Bldg Flooding Detailed in Encl LER 90-005.Mod Will Be Installed to Add Alarm in Main Control Room to Indicate When Flood Level Reaches Point & Operator Action Begins ML20043A5441990-05-16016 May 1990 Discusses Status of Safety & Performance Improvement Program Portion of B&W Owners Group EOP Review Project ML20042G7681990-05-10010 May 1990 Submits Unsatisfactory Performance Testing Incident Repts, Per 10CFR26, Fitness for Duty. Results of Three Positive Blind Test Samples Certified to Contain No Drugs ML20043A4931990-05-10010 May 1990 Forwards Executed Amend 8 to Indemnity Agreement B-54 ML20042G2101990-05-0707 May 1990 Provides Notice of MW Kirk Permanent Reassignment from Position & Requests Termination of Senior Reactor Operator License 20481-1,effective 900505 ML20042E8611990-04-26026 April 1990 Forwards Annual Financial Repts for Six Participating Owners of Plant ML20012F2941990-03-30030 March 1990 Forwards Nonproprietary Rev to 51-1176431-02, Crystal River 3 Reactor Vessel...Temp Overpressure Protection, in Support of Tech Spec Change Request 174,Suppl 1 Re Response to Generic Ltr 88-11 ML20042D8321990-03-30030 March 1990 Provides Supplemental Response to Station Blackout Rule Implementation & Affirms That Diesel Generator Target Reliability Will Be Maintained ML20012E2041990-03-23023 March 1990 Requests Temporary Waiver of Compliance Granted on Tech Spec 3.9.8.2 Re DHR Power Source Requirements ML20012D9471990-03-21021 March 1990 Requests Approval of Capsule Withdrawal Schedule in Table 3-19 of BAW-1543,Rev 3, Master Integrated Reactor Vessel Surveillance Program to Allow Plant Refuel 7 Outage Plans to Continue on Schedule.Changes Needing NRC Approval Listed ML20012D7371990-03-19019 March 1990 Responds to Generic Ltr 89-19 Re Resolution of USI A-47. Util Will Implement Appropriate Sys to Protect Against Overfill Concerns ML20012C4501990-03-13013 March 1990 Forwards Listing of Insurance Policies in Place for Plant as of 900225 ML20012B4821990-03-0707 March 1990 Forwards Inservice Insp Pump & Valve Program Relief Request V-371 Proposing Alternate Acceptance Criteria Requirements for IWP-4150 for Fluctuations in Hydraulic Instrument Readings ML20012B3651990-03-0101 March 1990 Lists Five Addl Drugs Included in 10CFR26 Re fitness-for- Duty Testing Program.Specimens Identified as Positive on Initial Screening Will Be Confirmed Using Gas Chromatography or Mass Spectrometry at Listed cut-off Levels ML20012A4041990-02-27027 February 1990 Forwards 1989 Annual Rept of Personnel Exposure in Accordance w/10CFR20.407 & Tech Spec 6.9.1.5.(a) & Annual Rept of Facility Changes,Tests & Experiments in Accordance w/10CFR50.59 ML20006G1731990-02-23023 February 1990 Advises That Util Voluntarily Agrees to Participate in Emergency Response Data Sys Proposed in Generic Ltr 89-15 ML20011F2411990-02-21021 February 1990 Provides Followup on & Documents Discussion in 900116 Meeting Re Emergency Diesel Generator Loading 1990-09-20
[Table view] |
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coneoaniow January 26, 1990 3F0190-15 Mr. James Lieberman, Director Office of Enforcement U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555
Subject:
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Proposed Imposition of Civil Penalty Inspection Report 89-200 and 89-24 Enforcement Action EA 89-172
Dear Sir:
In accordance with 10 CFR 2.201, Florida Power Corporation provides
, Attachment ~I to this letter as our response to the Notice of Violation, and in accordance with 10 CFR 2.205, provides Attachment II as our answer to the Proposed Imposition of Civil Penalty dated i December 1, 1989. The appropriate office directors are copied due l to.the backfit issues raised in this response.
l-l The attached response clearly states FPC's position that the proposed enforcement action is inappropriate. FPC takes this position because we believe our procurement program provided reasonable assurance that items intended for safety-related applications were suitable for the intended service based on good engineering practice and regulatory guidance available at the time.
FPC is also concerned that such enforcement action will have a negative impact on continued industry /NRC progress on resolution of. the procurement issues facing the industry. Further, the
' generic backfit implications warrant a thorough review.
l ZEl'4IlI
. GENERAL OFFICE: 3201 Thirty fourth Street South
- P.o. Box 14042 + St. Petersbur0, Florida 33733 + (813) 866 5151 9002020132 90012b "
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A Florida Progress Company
!j PDR ADOCK.05000302:
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- January 26, 1990 3F0190-15 Page 2 The technical issues raised on both the raw water pump and the procurement items have been aggressively addressed and dispositioned. The review of the raw water pump issue helped improve our post maintenance test program. The commercial Grade Items Reverification Study demonstrated that all of the procurements were performed in accordance with then existing applicable requirements. Also, the study effort assisted in improving our implementation of the new industry guidelines on dedication of commercial grade items. FPC considers these issues ,
closed from a regulatory perspective.
FPC would be pleased to meet and discuss our response to the proposed violations. Your consideration is appreciated.
Sincerely,
-C f P.M. Beard, Jr.
Senior Vice President Nuclear Operations PMB:REF:ead
. Attachments xc: Regional Administrator, Region II Senior Resident Inspector Director, Nuclear Reactor Regulation j Director, Analysis and Evaluation of Operational Data l
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ATTACHMENT I FLORIDA POWER CORPORATION NRC INSPECTION REPORT N0. 50-302/89-200 AND 89-24 REPLY TO NOTICE OF VIOLATION
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VIOLATION 10 CFR Part 50, Appendix B, Criterion III, " Design Control", requires that measures be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to tie safety-related functions of structures, systems and components.
Contrary to the above, inadequate measures were established for selection and 1 review for suitability of application of materials, parts, and equipment that are essential to the safety-related functions of systems and components.
Specifically.
A. Pursuant to the actions initiated by the indicated material qualification !
form (MQF) or Purchase Order (PO), the following commercial grade items that are essential to the safety related functions of systems and components were ;
installed, as of April 24, 1989, without adequate selection or review for suitability:
- 1. MQF 1436 Transferred three ASCO series 8321, three way, air-operated solenoid valves, initially procured as non-safety, from the CR4 fossil plant to CR3 in January 1989. These valves were installed in valves CAV-6 SV and CAV-7 SV in the chemical addition system. The basis for .
dedication was limited to a visual inspection, part number comparison with page 48 of ASCO's commercial grade catalog No. 31, and a continuity check of the solenoids electrical coil.
P
- 2. MQF 1433 Upgraded two series 8321 and two HT 8320A20 three way air operated ASCO solenoid valves. The electrical coils from the 8320 series valves were installed in the 8321 series valves that were subsequently installed in main steam valves MSV 130 and 138 in January 1989. The dedication basis for the four ASCO valves was limited to a visual inspection and a part number comparison with the ASCO commercial grade catalog.
- 3. MQF 1413 Upgraded two Agastat 7012 ac model time delay relays.
Characteristics verification was limited to a visual check of the physical dimensions per the Agastat catalog, a verification of nameplate details, such as voltage and time range and a check for physical damage.
- 4. MQF 1332 Upgraded a 600 volt, three phase,10-ampere, HE 3A010-type l ITE molded-case circuit breaker for valve MVV-53, located in the makeup system, in January 1988. Characteristic verification was limited to a visual inspection to verify the dimensions and part number and to check l for physical damage.
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- 5. MQF 1301-87 : - Upgraded a three phase, HE 3A025 type ITE molded case circuit breaker required to replace a failed breaker on motor center 381 (unit 118), which povers a motor-operated valve located in the decay heat removal system, ir. November 1987. The characteristic verification was limited to checking the dimensions and part number.
- 6. MQF 972 85 - Upgraded three Model VIIHAA three way air operated solenoid valves, manufactured by Johnson Controls, for use in the air damper system for the 1B EDG in August 1985. Dedication was limited to a visual inspection to determine equivalency with the manufacturer's catalog.
- 7. P0 F9038125V - Issued on October 1985 to Norton Corrosion Limited for an extended snout, 9 inch shielded Bayanode element used for cathodic protection and installed in the service water system. A review of the procurement file revealed the following deficiencies: Hardness testing was not performed; electrical characteristics were not addressed; traceability was not established from the material manufacturer's certificate to that of the Bayanode's manufacturer's certificate; and a review for suitability of critical operating requirements was not performed.
B. During the Spring 1989 overhaul of raw water pump 28, an incorrect impeller, which was procured in 1981, was installed, resulting in the pump being unable to provide the flow rate specified in the plant design.
This is a Severity Level III violation (Supplement I).
Civil Penalty - $50,000 FLORIDA POWER CORPORATION (FPC1 POSITION l FPC respectfully denies both parts of the violation. As will be discussed below, Part B of the cited violation does not represent a violation of 10 CFR Part 50, Appendix B, Criterion 111. Further, FPC denies Part A of the violation.- In this regard, FPC's commercial grade procurement program complied with available NRC guidance and, therefore, enforcement action represents an inappropriate backfit. As the following discussion provides, even if Parts A and B represented violations of NRC requirements they should not rise to the level of escalated enforcement. The followig discussion provides the support for our position. <
RESPONSE TO VIOLATION PART B In October, 1980, FPC initiated a purchase request for spare parts to be used in refurbishing any one of the five raw water pumps (RWP) located at the Crystal River Unit 3 (CR-3) facility. The RWPs were designed and L manufactured by Bingham Wil11mette (Bingham). A purchase order (P.O. #
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F10946Q) was completed and submitted to Bingham in June,1981. Among the parts being ordered was the impeller which was ultimately used in RWP-28.
l The originator of the purchase request specified the type of impeller based on the information contained in the vendor's technical manual for the five I
RWPs. The purchase order provided all of the ordering information requested '
by the technical manual, including the part numbers of the five pumps it was intended to support, and the pump type. In addition, the purchase order 2-e
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requested certification of the impeller to the requirements of the original purchase order (P.O. #PR3-Il60) and FPC's specifications (R.O. #2755) for the five pumps. FPC was, and is, not in possession of detailed design drawings due to the proprietary nature of such information.
FPC was confident the correct spare impeller would be delivered since it was ordered from. the original manufacturer, and the part would be provided pursuant to a 10 CFR 50, Appendix B quality assurance program which had been approved by FPC. The apparent deficiency in the procurement process, t1erefore, fell squarely upon Bingham. This is further demonstrated by the fact that while the 1981 purchase order identified the serial numbers of all five RWPs, the combination of vane configuration and diameter supplied by Bingham was not appropriate for any of the five pumps specified.
In 1982, Bingham again apparently failed to recognize there were five (versus seven) vanes on the impeller in question. Specifically, FPC ordered a second impeller in January,1982 and, before manufacturing the order, Bingham called FPC to advise that the impellers for the five pumps specified on the )urchase order had 3 different diameters. Bingham asked FPC for which, of tie pumps the spare impeller was intended. Apparently, there was subsequent (undocumented original spar)e part order (#F10946Q) was trimmed for RWP-2A&B. discussion th FPC then modified the second spare part order (001798930) to require 2 impe11ers; one trimmed for RWP 1 and one trimmed for RWP-3A&B. Bingham never identified to FPC that more than one vane configuration was available.
The thoroughness of FPC's procurement action is demonstrated by the actions taken ont.c the RWP-2B impeller was received at CR-3 in October,1981. First, FPC performed a recei)t inspection (Inspection Report No. 4528) consistent with those performed ay the rest of industry for similar purchases. Among other things, this involved ensuring an adequate certificate of compliance from the Part 21 vendor, checking for the proper part/model number of the i spare part, and ensuring that there was no evidence of damage. FPC performed l various dimensional fit checks on the impeller when it was being installed I l: in RWP-2B in May, 1989 (Work Request No. 112399). These checks identified no inconsistency in parameters. (As demonstrated by the photographs provided at the enforcement conference, the visual difference of a five and seven vane impeller is not as obvious as it may seem). Once the impeller was installed, FPC performed its post-installation test according to procedure SP-344B.
As FPC previously explained at the enforcement conference, and in Licensee Event Report (LER) No. 89-30 and its Sup31ement, the most likely cause of the incorrect flow measurement during tie post-maintenance test and the :
resulting failure to identify the impeller problem was related to the man- i machine interface with the instrumentation used. The root cause of the flow rate error may have been the failure of test personnel to fully close the low pressure side instrument vent needle valve resulting in an erroneous flow measurement. If an inadequacy existed, it resulted from several unique events which created an isolated occurrence which was not reasonably foreseeable by FPC. This is further supported by the fact that the subsequent quarterly surveillance test using the same test method and
= instruments identified that the flow rate for RWP-2B was not within the '
surveillance requirements. FPC had been using this particular test method for a relatively short time (i.e. about a year) and had no data to indicate 3
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- L i that this scenario could occur. FPC has subsequently recognized that certain i physical and/or procedural enhancements can be made in the test method. ;
o The above discussion demonstrates that there was no procurement-related :
deficiency on the part of FPC. Therefore, the NRC incorrectly characterized the violation under 10 CFR Part 50, Appendix B, Criterion III. It is FPC's position that Part 8 of the violation should be considered separately from l Part A because they are unrelated. ;
Finally, the engineering analysis set forth in our LER (and Supplant) -
clearly demonstrates that even in its " degraded" condition, RWP-2B would have !
been capable of providing water flow sufficient to meet the accident cooling load requirements (during a design basis accident (DBA).) Consequently, in accordance with the NRC's Enforcement Policy (10 CFR Part 2, Appendix C),
FPC should agi be cited for a violation when this item is considered '
separately. ,
RESPONSE TO VIOLATION. PART A i
- 1. Backaround l As the above discussion demonstrates, the only procurement-related activities addressed by the Notice of Violation (NOV) are those described in Part A. Therefore, the following discussion will address the :
appropriateness of the NRC's citation to 10 CFR Part 50, Appendix B, Criterion Ill for these activities. The discussion will demonstrate that the NRC inspection and enforcement efforts related to the commercial -
grade (CG) procurement activities cited in Part A of the NOV constitute a backfit under 10 CFR Part 50.109,
- 2. Backfittina imolications
- a. Introduction and Summary j The NOV cites seven examples in which commercial grade items were ;
i procured and installed in safety-related applications in a manner
!. that allegedly violated the requirements of Appendix B, Criterion ,
l Ill. Contrary to the NOV, FPC has demonstrated that our procurement i and dedication practices have met NRC requirements to assure that items installed are suitable for their application. Our compliance was confirmed by the NRC during previous reviews of procurement practices. Moreover, NRC requirements and guidance in this area have previously been extremely broad or even nonexistent. The NRC in this enforcement action is, in effect, redefining what constitutes adequate procurement practices. While FPC has and will continue to
- 1. improve its program, FPC believes that enforcement action is L inappropriate in this context and that the NOV should be withdrawn, if the violation is not withdrawn, we respectfully request that the Staff position be reviewed under 10 CFR Part 50.109 before being imposed, l
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Below, we first discuss past NRC acceptance of our CG procurement and dedication practices and then review the existing .NRC
, requirements in this area to show that the Staff position reflected
, in ti,e NOV is not explicitly required by NRC regulation.
b.. The NRC Has Previousiv Acoroved FPC's CG Procurement and Dedication Practices FPC's procurement program for Commercial Grade Items (CGI) has been in place since 1982, and has undergone enhancements since implementation. Previous NRC inspections have directly and indirectly reviewed FPC's program against the requirements in effect at the time and found both the program and implementation to be acceptable. However, recent NRC/ Industry concerns regarding misrepresented material and the detailed guidelines for CGI procurement have raised some concerns about existing industry practices. This has resulted in revised NRC inspection procedures and new. industry initiatives regarding CGI procurement. However, such initiatives are not applicable to past procurements. The NRC inspection and enforcement efforts have the practical effect of applying such initiatives to past CGI procurements and thus constitute a backfit.
FPC's CGI procurement program was adopted in 1982 based on the i
requirements of 10 CFR Part 50, Appendix B and ANSI N45.2 The program identified CGI procurements intended for safety related applications at the time the procurement was initiated, and:
l Provided for the review of supplier quality assurance programs for such items.
Provided for the review of procurement requirements by dedicated procurement engineering and procurement quality assurance groups.
L Specified stringent vendor packaging requirements for such items.
Required vendor documentation of conformance to requirements.
Provided for an independent inspection at receipt, not limited to a review of documentation.
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Provided for the identification of non-conformances at receipt L and corrective actions by CGI suppliers.
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Provided for the storage of such items under appropriate, controlled conditions prior to installation. ,
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E This program was consistent with other successful licensee programs !
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'which we understand the NRC reviewed and approved. FPC's CGI i procurement program was subsequently reviewed in NRC inspections .
dealing specifically with procurement (Inspection Reports 83-04 &
p 85-40) and found to comply with applicable requirements. Further, :
o aspects of the program have been reviewed by the NRC.in connection l I with the Systematic Assessment of Licensee Performance (SALP) review process in 1983 and 1985, and found to be well controlled-and in '
compliance with requirements. FPC believes that the CGI procurement program met applicable standards in effect prior to the NRC's ,
inspection in April and May, 1989. ;
FPC has continued to enhance its program since inception, adding to !
procurement and inspection requirements as the industry has gained '
experience. FPC has enhanced its knowledge of procurement issues and .
has contributed to the advancement of industry standards by active !
participation in the EPRI/NCIG effort that produced the NCIG-07 CGI
- Guidelines as well as the NUSQAC/NUPIC quality assurance group and i NUMARC. ,
The 1989 NRC procurement inspection did not cite FPC for failure to
- follow its program or procedures. The NRC inspection, and the resultant report, cited FPC for failure to implement adequate measures for the selection and review for suitability of certain CGI components. The practical effect of the specific measures cited is the imposition of several elements of new industry initiatives including:
Field surveillance of commercial grade suppliers.
Identification of all CGI critical characteristics.
Verification of all critical characteristics via vendor i inspection, source inspection or receipt inspection, r The industry initiative (EPRI NP-5652 (NCIG 07)) and NRC endorsement ;
(Generic Letter 89-02) were not issued until March,1989. The initiative was, as committed by NUMARC, effective as of January 1, 1990. Nonetheless, the April /May,1989 inspection report addressing ,
CGI procurement from 1982 through 1988 cites FPC for noncompliance with specific guidance which was not published until the 1988/1989 :
time frame. While it is understandable . that some of these contemporary criteria may have been inadvertently applied by the NRC -
inspection team, FPC cannot concur with the application of new criteria to past actions as a basis for enforcement, The above referenced initiative and NRC Generic Letter represent several facets of a dynamic situation regarding procurement of CGI, A variety of NRC bulletins and information notices have been issued from 1987 through 1989 documenting misrepresented material (as recently summarized in NRC Information Notice 89-70 dated October 11, 1989). These documents are evidence of growing NRC/ Industry concern. FPC and other licensees have been making continual L adjustments in procurement programs to address these problems. It 6- !
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became evident that the available NRC/ Industry guidance for ;
procurement of CGI was extremely limited, and an industry group -
produced the NCIG-07 document under EPRI sponsorship. This document was published in June,1988, adopted by the industry as an initiative ['
in March,1989, endorsed in general by NRC Generic Letter in March, l 1989, and was to be in effect as an-industry (NUMARC) initiative on January 1, 1990. Thus, the NRC inspection of FPC's procurement :
program was conducted at a time of considerable change in the approach to procurement of CGI. Much effort on the part of both the NRC and industry had finally resulted in tangible guidance and :
criteria for both the industry and NRC. '
FPC has taken a number of actions to date to respond to recent .
regulatory and industry guidance in the area of CGI procurement as !
follows- t t
- Participation in EPRI/NCIG effort to develop CGI guidelines (NCIG-07). ;
- Leadership in NUSQAC/NVPIC industry, joint quality assurance effort addressing implementation of Guidelines for CGI suppliers.
- Participation in EPRI Task Force to develop additional criteria ;
o for CGI critical characteristics to implement CGI Guidelines. >
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Management commitment to implement NCIG 07 Guidelines prior to NRC Inspection (actual implementation July 1,1989).
- Reverified operability of 41 CGI procurement packages questioned by the NRC procurement inspection.
- l. - Reverified 174 additional procurement packages to address NRC
! inspection team concerns. (CGI Reverification Study) '
t Committed to enhance inspection programs for electrical items procured as CGI to fully implement NCIG-07 Guidelines.
7 Replaced the Material Qualification (MQF) Process with processing in accordance with NCIG-07 Guidelines.
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Added traceability critoria to procurement procedures based on l i recent industry data.
Regarding the CGI Reverification Study completed in 1989, FPC ,
believes that the results demonstrate that all of the procurements were performed in accordance with FPC's procurement program which met applicable requirements. This program was designed to provide reasonable assurance that CGI dedicated for safety-related service met their intended safety function.
Considering FPC's review of these 174 procurements and the NRC's review of over 150 packages during the inspections, including the 41 reverified by FPC for operability, it is clear that a reasonable sample of CGI procurements has been rereviewed. FPC believes that
- o. 3 this effort provides reasonable assurance that the CGI procured for use at CR-3 are properly dedicated.
Based on the above, FPC believes that enforcement is inappropriate, and that a backfit of requirements has clearly occurred in this instance. FPC has demonstrated th&t it has complied with applicable requirements and guidelines in effect at the time of procurement.
Further, FPC's actions have demonstrated full awareness of both requirements and industry trends, as well as a commitment to improve its procurement program as warranted by changes in both requirements
' and industry trends. FPC has been aggressive in implementing improvements to its program, and has been heavily involved in industry efforts aimed at improving CGI procurement,
- c. The Staff Position Reflected in the NOV is not Suonorted by Existina NRC Reauirements 10 CFR Part 50, Appendix B, establishes general quality assurance requirements for safety-related structures, systems and components.
It does not explicitly address commercial grade item procurement and dedication and does not establish any precise steps that licensees must follow to assure that items and components are suitable for their application.
l Criterion III, " Design Control," contains only a broad provision that
"[m]easures shall also be established for the selection and review L.
for suitability of application of materials, parts, equipment, and processes that are essential to the safety related functions of the structures, systems and components." This. provision, which the NRC cites as the basis for the present violation, is not further defined in Appendix B or in the rulemaking history.
Moreover, there is little or no regulatory guidance on the meaning of this provision of Criterion III. Significantly, even the current Standard-Review Plan fails to provide any guidance on the meaning of this provision. SRP 6 17.1.3, " Design. Control," is silent
[ regarding the " suitability application" provision, and the related i guidance in Acceptance Criterion 3A of SRP 517.1 merely states that design control activities should - address " compatibility of materials." ;
The broad provisions of Appendix B have been clarified over the years in various industry guidelines. The primary guidance document was ANSI N18.7, to which FPC is committed for its QA program. ANSI N18.7 i provides general guidance on QA for procurement. The NRC endorsed ,
ANSI N18.7-1976 in Regulatory Guide 1.33 as an adequate basis for !
complying with the requirements of Appendix B. However, ANSI N18.7 addresses commercial grade items only very briefly, and does not 3 l discuss dedication of CG items for safety-related use. ANSI l N45.2.13, which was endorsed by the NRC in Regulatory Guide 1.123, ,
provides more specific guidance on QA for procurement of items and '
- i. services. The standard, however, does not explicitly address l
commercial grade procurement and dedication.
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- < .c l Thus, on the specific ^ regulatory provision cited as the basis for-the violation, virtually no guidance exists as to the nature-of 1
activities that licensees are expected to undertake. It follows that i i licensees have been free to implement programs that in their judgment 1 meet the intent of .the requirement. For this reason alone, I enforcement action that would establish specific new procedural and !
? documentation requirements is. inappropriate. - Absent a showing that i l installed items are not suitable for their application,- new I requirements should be applied only prospectively.
l FPC 'is well aware that as a result' of the fraudulent and counterfeit l equipment problems that arose in- 1988, which were identified by l industry procurement programs in effect at the time, the NRC for the first time published detailed guidance on commercial grade item 1 procurement and _ dedication. Generic letter 89-02, " Actions to- '
Improve the Detection of Counterfeit and Fraudulently Marketed ,
Products," issued March 21,1989,~ conditionally endorsed NCIG-07 and I provided additional guidelines to apply to the dedication process. 1 While the Generic letter stated that those guidelines, as modified l by the Generic Letter, established methods for satisfying " existing" 1 requirements of Appendix B, the Staff did not explain the legal basis I for such a conclusion.
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1 On March 16, 1989, the NRC published an Advance Notice of Proposed l Rulemaking (ANPR) (54 Fed. Reg. 9229) on procurement practices, '
specifically including commercial grade item dedication. The
- j. Commission noted that it was reconsidering the adequacy of current o regulations in this area. Questions posed in the ANPR strongly j t
suggest that the Commission did not believe that existing regulations require the extensive verification tests assumed in the NOV. For i
. example, the Commission asked: )
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How should products . . . be inspected to verify that all critical characteristics are satisfied? ,
Should all upgrade inspections be restricted to inspections and tests or should they include, on a sample basis, destructive '
inspections and tests to verify chemical and physical characteristics?
How should inspections verify all critical characteristics (for example, chemistry physical properties, dimensions, special processes,etc.)?
Had the Commission believed that these actions were already mandated by existing regulations (as the NOV assumes), there would have been no need to pose these questions. The only conclusion that can be L drawn is that the Commission did not believe these requirements were within the contemplation of the current regulations.
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4 d.- Conclusion
'In summary, it can be seen from-the above survey of the regulations
! and guidance that: (1) the regulations do not contain explicit standards and requirements for CG procurement and dedication; and (2) ' the regulations do not contain explicit criteria on which specifications are to be included in procurement documents and the' scope of receipt inspections and examinations. Indeed, as the NRC's-own Inspection Procedure states, " consistent criteria for determining an item's suitability for its intended application have not been
- clearly established," (Inspection Procedure 38700, at page 2.)
Given the absence of . clear regulatory criteria governing CG procurement, enforcement action is wholly inappropriate.
Florida Power Corporation therefore respectfully requests that the Notice of Violation be withdrawn. We must also observe that the NRC's apparent reliance on new standards to review past procurement activity could greatly discourage industry sel f-improvement.
Enforcement action in these circumstances would therefore not be in the public interest.
- 3. Clarifications to Notice of Violation Findinas The following information is provided as clarification to the 'seven procurement items cited in the Notice of Violation.
I NRC Findings I and 2:
-h HQF-1436-89 and MQF 1433-89 were installed in accordance with a design modification. This type of commercial product is part of CR3's original design. The design input and material selection was detailed in the design modification process, as per FPC procedures. In addition to inspections verifying manufacturer's markings, nameplate information, >
and dimensional configuration to the catalog, a modification functional test was performed to verify critical operation characteristics. ;
NRC Finding 3:
MQF 1413-88 was initiated to replace original, installed items. This upgrade was to replace an existing original design component with a like component. The function of the subject relay in this application is non-safety related but was conservatively classified by the procurement i program as safety-related commercial grade.
NRC Finding 6:
MQF 972-85 authorized the use of a "like-for-like" replacement Johnson Controls solenoid valve. In addition to physical inspections, the item was functionally tested after installation. The system also undergoes monthly periodic testing under SP-354A and SP-354B.
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[: NRC Finding 7: ,
L Purchase Order F9038125V was for an anode. The item has no electrical
[ safety function and therefore no electrical characteristics needed to be identified. Reasonable assurance of material hardness was obtained via the material test report provided by the manufacturer detailing i physical and chemical properties. j l
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i', '.o ATTACHNENT II FLORIDA POWER CORPORATION ENFORCENENT ACTION EA 89-172 NRC INSPECTION REPORT N0. 50-302/89-200 AND 50-302/89-24 ANSWER TO NOTICE OF VIOLATION Florida Power Corporation (FPC) provides the following in response to Enforcement Action EA 89 172. This response is provided in accordance with 10 CFR 2.205.
FPC believes that the information provided in the Reply to Notice of Violation, Attachment I, shows more than sufficient facts to support the conclusion that no violations should be cited for the events described in the Notice of Violation (NOV). The facts presented in Attachment I demonstrate that at worst, Parts A and B of the violation cited in the NOV rise only to the level of separate Severity Level IV or V violations. Therefore, no civil penalty is warranted for these incidents.
However, should the NRC decide that a civil penalty is warranted, the discussion below offers facts to support the conclusion that the Enforcement Policy provides for full mitigation of the proposed civil penalty.
With respect to the application of Adjustment Factors, the NOV states that the
" escalation and mitigation factors in the Enforcement Policy were considered."
Because the NOV specifically discusses only three of the six factors, corrective action to prevent recurrence, past performance, and multiple occurrences, the only conclusion that may be reasonably drawn is that those re.;.:.ining factors were deemed to have no effect on the proposed base civil penalty. FPC agrees that ,
the factors of prior notice of similar events and duration are not applicable. t However, FPC believes that the factor of identification and reporting should have been included and that the NRC did not properly apply the factors of past performance and multiple occurrences.
- 1. Past Performance l With regard to past performance, the NOV indicates that NRC balanced FPC's i i
Systematic Assessment of Licensee Performance (SALP) rating in the "en ineering category" and the recent escalated enforcement action (EA 89- ,
118 addressing environmental qualification (EQ) against FPC's " good overall '
qua ity assurance program and recognition of active participation in industry initiatives." In sum, NRC concluded that "neither escalation nor mitigation is warranted." Contrary to the NRC's reasoning, however, FPC believes that the facts of this case and NRC's prior enforcement precedent demonstrate that >
mitigation is warranted.
First, the October 13, 1988 (53 Fed. Reg. 40019) change to the Enforcement Policy states that:
(this) factor (past performance) has been changed to provide more ;
flexibility in considering past performance in the assessment process.
Currently, past performance focuses on prior performance in the area of concern though overall performance can be considered. The effect of deleting the reference to general area of concern is to permit greater consideration of overall performance.
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Consistent with this change, the NRC in a recent escalated enforcement action (EA 89-135) permitted 100 percent mitigation for the utility involved because its overall SALP performance. However, not only did the NRC not consider FPC's overal1 SALP performance, but it focused on the individual area of concern (i.e., the functional area of ' engineering). This is clearly inconsistent 'with both the Enforcement Policy, as revised, and prior L enforcement precedent.
Second, the October 13, 1988 Enforcement Policy change (53 Fed. Reg. at 40020) specifically eliminated the terminology " area of concern" as applied to prior violations. Nevertheless, with respect to 9111 violations, the NRC suggests in the Policy that it intends to apply a more limited focus. The NRC indicates, by way of example, that such violations must be "similar problems," (53 Fed. Reg, at 40025). The word similar is explicitly defined in footnote 3 of the Enforcement Policy as follows:
The word "similar," as used in this policy, refers to those violations which could have been reasonably expected to have been prevented by the licensee's corrective action for the previous violation, (53 Fed. Reg.
at40024).
In applying the past performance factor to this case, NRC's use of EA 89-118, which involved EQ concerns, is improper. EQ and CG procurement are not "similar." EA 89118 has not been resolved in that FPC's appeal is under review. Further, the corrective actions taken for EQ concerns would not have reasonably prevented the issues raised by NRC in the present procurement NOV.
Therefore, this purported " negative factor" was improperly included in the consideration of the past performance civil penalty adjustment factor. ;
Consequently, upon proper consideration, additional mitigation is warranted.
- 2. Multiole Occurrences With regard to multiple occurrences, the NOV states that:
In this case, the civil penalty has been escalated 50 percent in recognition of the added significance of an example in which a replacement part, the raw water pump impeller, was not only of indeterminate quality but was demonstrably unsuitable for its 3 application.
Contrary to the NRC's reasoning, FPC believes that the facts of this case, as well as a reasonable interpretation of the Enforcement Policy, demonstrate that escalation is not warranted under this factor.
First, based on the NRC's statements, there can be no doubt that the principal consideration for escalation under this factor was the circumstances associated with the pump impeller issue (Part B of the NOV). l This is further demonstrated by a comparison of the FPC proposed enforcement action with EA 89-130. In the latter case, which also dealt with procurement-related examples, there was absolutely no mention of the multiple occurrences factor -- and EA 89-130 included nine examples, whereas the FPC NOV only contains eight.
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Second, given the above, and irrespective of the relative numbers issue, I the impeller concern should not have been considered as part of this factor
, because it is not a procurement related concern, as discussed in Attachment
- 1. Thus, it should not have been considered as one of the " multiple occurrences of a particular violation."
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Third, and perhaps most significantly, the NRC has incorporated an inappropriate consideration into this escalation factor. A plain reading I of the Enforcement Policy shows that the " quality," or perceived l j significance, of a particular example is not a consideration appropriate E for civil penalty adjustment under this factor. Regulatory or safety 1 significance of deficiencies are to be addressed in the Severity Level 1 determination, not under the escalation factors. Furthermore, a review of. j the regulatory history for the Enforcement Policy demonstrates that 1
- quality," or regulatory concern, has never been part of the multiple ]
occurrences factor. NRC's statements, supra, clearly demonstrate that it l was the alleged quality, or the nature of the impeller concern, that was -
principally responsible for NRC's escalation under the multiple occurrences i factor. This reasoning forms an inappropriate- basis for escalation.
Furthermore, the purported significance is in error since FPC has clearly demonstrated the impeller could indeed have performed its intended safety i function.
Finally, a review of the regulatory history also shows that, even if the i impeller issue could have been used as an escalation factor, its effect was -
! offset by FPC's prompt identification and reporting of this concern as l discussed below. ,
- 3. Identification and Reportina The Statement of Consideration for the March 8,1984 Enforcement Policy i revision (49 Fed. Reg. 8583, 8585) states that " escalation under [the I multiple occurrences) factor may- be offset by mitigation for prompt l identification and reporting." It is recognized that since the Harr.h 8,1984 Enforcement Policy revision, there have been several other revisions.-
However, no substantive change has been made to the multiple occurrences factor. Therefore, it is appropriate to use the 1984 Statement of Consideration in evaluating NRC's actions in this case.
NRC Inspection Report 50-302/89 24, dated September 18, 1989, as well as LER 89-30 (and its Supplement), support the conclusion that FPC promptly reported and corrected the impeller concern once we became aware of the problem.
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With respect to identification, FPC's performance must be viewed in the
, context of the circumstances. Consistent with the subfactors discussed in
., the Enforcement Policy under the identification and reporting factor, FPC '
had very little opportunity to discover this problem and there was no ease >
of discovery. Furthermore, FPC provided prompt and complete reporting of the incident. Therefore, based on this consideration alone, escalation under the multiple occurrences factor for the impeller concern should be offset. ,
In summary, FPC believes a complete and proper consideration of all the appropriate adjustment factors would support full mitigation of any civil ,
penalty. ;
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