ML20057D213
| ML20057D213 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 09/20/1993 |
| From: | Silver H Office of Nuclear Reactor Regulation |
| To: | Beard P FLORIDA POWER CORP. |
| References | |
| TAC-M85836, NUDOCS 9310010267 | |
| Download: ML20057D213 (14) | |
Text
(
gpP RICg UNITED STATES
[h)(N!ZL[tj NUCLEAR REGULATORY COMMISSION f
WASHINGTON, D.C. 205 5 0001 September 20, 1993 Docket No. 50-302 Mr. Percy M. Beard, Jr.
Sr. Vice President Nuclear Operations Florida Power Corporation ATTN: Manager, Nuclear Liceasing (NA21)
Crystal River Energy Comp'.ex 15760 W Power Line Street Crystal River, Florida 34428-6708
Dear Mr. Beard:
SUBJECT:
SPECIAL AUDIT OF CONTROL PROCESSES FOR COMMITMENTS AND CURRENT LICENSING BASIS, CRYSTAL RIVER UNIT 3 GENERATING PLANT (TAC NO. M85836)
This letter provides the results of the commitment management audit conducted by the Office of Nuclear Reactor Regulation at the Crystal River plant from March 29 through April 2, 1993. As you are aware, the staff conducted audits at a cross-section of reactor plants to assess the processes used by licensees for controlling commitments that affect the plant's current licensing basis.
The staff will use the information gathered during the audits to evaluate the regulatory process in this area. Crystal River was the second site visited by the staff and our audit report is enclosed.
The audit team focused on three principal areas:
(1) managing commitments made to the U.S. Nuclear Regulatory Commission (NRC), (2) reporting changes to commitments made to the NRC, and (3) maintaining and updating the final safety analysis report (FSAR).
In addition to reviewing the governing programs for these subjects, the team reviewed the status of commitments made to the NRC in response to specific issues (selected generic letters, bulletins, licensee event reports, ar.d notices of violation) in order to examine the programs in actual practice.
t Overall, the team found that commitments affecting the plant's current licensing basis were being implemented and maintained.
It also found that you relied on the judgement of the licensing and compliance managers for deciding if a change to a commitment warranted notification of the NRC.
Finally, the i
team found that the commitments it reviewed that affected the plant FSAR were captured by the FSAR update process, except for changes made to the instrument air system in response to a generic letter. The team did not identify any items of significance in its review of commitments made in response to the specific issues.
(hb 9310010267 930920 f
PDR ADDCK 05000302 1
g
}
7 Mr. Percy M. Beard, Jr. The team thanks that plant staff for its candor in its discussions and for its cooperation in providing the information necessary to conduct an efficient audit.
If you have any questions or comments concerning this report, please contact me at (301) 504-1475 or Eric J. Leeds at (301) 504-1133.
This completes our efforts on Tac No. M85836.
(Original Signed By)
Harley Silver, Senior Project Manager Project Directorate II-2 Division of Reactor Projects - I/II Enclosure.
Audit Report cc/w enclosure:
See next page Distribution Docket' File NRC & Local PDRs PDII-2 RF S. Varga l
G. Lainas l
H. Berkow E. Tana H. Silver 0GC i
ACRS (10)
M. Sinkule, RII 0FC LA:PDII-2 PM:POIL-2 D PQI,b.2s NAME ETana N ( HSik k Hhfer b )
DATE
- 7 /Jo/93 7/dC/93 4)/3:/93 OFFICIAL RECORD COPY FILENAME: A: AUDIT.CR3 i
Mr. Percy M. Beard Crystal River Unit No.3 Florida Power Corporation Generating Plant cc:
Mr. Gerald A. Williams Mr. Joe Myers, Director
-Corporate Counsel Div. of Emergency Preparedness Florida Power Corporation Department of Community Affairs MAC-ASA 2740 Centerview Drive P. O. Box 14042 Tallahassee, Florida 32399-2100 St. Petersburg, Florida 33733 Mr. Bruce J. Hickle, Director Chairman Nuclear Plant Operations Board of County Commissioners Florida Power Corporation Citrus County P. O. Box 219-NA-2C 110 North Apopka Avenue Crystal River, Florida 34423-0219 Inverness, Florida 32650 Mr. Robert B. Borsum Mr. Rolf C. Widell, Director B&W Nuclear Technologies Nuclear Operations Site Support 1700 Rockville Pike, Suite 525 Florida Power Corporation Rockville, Maryland 20852 P. O. Box 219-NA-21 Crystal River, Florida 34423-0219 Regional Administrator, Region II U. S. Nuclear Regulatory Commission Senior Resident Inspector 101 Marietta Street N.W., Suite 2900 Crystal River Unit 3 Atlanta, Georgia 30323 U.S. Nuclear Regulatory l
Commission Mr. Bill Passetti 6745 N. Tallahassee Road Office of Radiation Control Crystal River, Florida 34428 Department of Health and Rehabilitative Services Mr. Gary'Boldt 1317 Winewood Blvd.
Vice President - Nuclear Tallahassee, Florida 32399-0700 Production Florida Power Corporation Administrator P.O. Box 219-SA-2C Department of Environmental Regulation Crystal River, Florida 34423-0219 Power Plant Siting Section l
State of Florida I
2600 Blair Stone Road Tallahaseee, Florida 32301 l
Attorney General Department of Legal Affairs The Capitol Tallahassee, Florida 32304
I l
COMMITMENT MANAGEMENT AUDIT OF THE CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT MARCH 29-APRIL 2, 1993 I.
ScoDe and Participar,ts j
The purpose of the audit conducted at Crystal River was to assess the effec-i tiveness of the licensee's programs for identifying and controlling commit-ments that affect the facility's current licensing basis.
The audit focused on three principal areas:
(1) managing commitments made-to the U.S. Nuclear.
Regulatory Commission (NRC), (2) reporting changes to commitments made to the NRC, and (3) maintaining and updating the final safety analysis report (FSAR).
i The audit team reviewed the licensee's administrative procedures involving commitment management; reporting; action tracking; control of design, configu-t ration, tests and experiments; and others.
To examine the programs in actual practice, the team reviewed the status of commitments made by the licensee to the NRC in response to specific issues.
Five of these issues, generic in nature, were the following:
10 CFR 50.62 Anticipated Transient Without Scram (AlWS)
Generic Letter 89-13 Service Water System Problems Affecting Safety-Related Equipment Generic Letter 88-14 Instrument Air System Problems Af fecting Safety-Related Equipment i
Bulletin 85-01 Steam Binding of Auxiliary Feedwater Pumps NUREG-0737, I.C.5 Procedures for Feedback of Operating Experience to Plant Staff l
The remaining issues were specific to Crystal River, involving licensee commitments made in licensee event reports (LERs) and responses.to notices of 4
violation (NOVs).
The team also reviewed the licensee's enhanced design basis document (EDBD) program to determine how a commitment from the program would be captured in the commitment management process.
The team relied on standard NRC inspection practices in conducting the review of specific commitments.
In conducting the audit, the team performed system walkdowns, reviewed applicable documentation (including design change pack-ages, training records, and procedures), and interviewed plant staff. A detailed review for each issue specified above is contained in the appendix.to.
this report.
The following NRC personnel participated in this audit:
Eric J. Leeds, Team Leader James E. Beall H
Steven R. Stein Anthony J. D' Angelo II.
Findinas and Conclusions The following are the team's findings and conclusions for the three major areas of focus:
(1) commitment management, (2) reporting changes to commit-ments made to the NRC, and (3) maintaining and updating the FSAR.
f Commitment Manaaement: Overall, the team found that commitments affecting the plant's current licensing basis were being implemented and maintained.
In its-review of licensee commitments in response to specific issues, the team found no significant deficiencies in identifying, tracking, completing, and main-taining licensee commitments in design, equipment, procedures, and programs.
The licensee's processes for the origination and the permanent revision of plant procedures provided assurance that existing commitments would be incorporated in new and permanently revised procedures.
For plant modifica-tions, the licensee's program required that certain, specific regulatory issues and any resulting commitments be reviewed as part of the process.
However, for modifications other than those involving specific regulatory issues (discussed in detail later in this report), there was no defined process for design modifications requiring the review of previous commitments.
The team did not identify any examples in which a committed modification was inadvertently altered by a subsequent modification and attributed this to the experience level of the engineering organization and the multiple levels of review and approval required by the design change process.
Reportina Chanaes to Commitments Made to the NRC: The licensee did not include specific guidance in its procedures for reporting changes to commit ments made to the NRC but rather relied on the judgment of its licensing and compliance managers for making such decisions. The team did not identify any instances in which it questioned the judgment of the licensee in the area of reporting changes to commitments made to the NRC. Although requirements for reporting changes to commitments were not specifically included in commitment management procedures, the modification program procedure required reviews of associated commitments for cancelled modifications.
In its review of Generic Letter (GL) 88-14, the team found that the licensee's programs provided the proper linkage to ensure recognizing a commitment affected by a canceled modification.
Maintainino And Updatina The Final Safety Anlysis Report: The team found that the commitments it reviewed that affected the plant FSAR were captured by the FSAR update process except for changes made to the instrument air system in response to a generic letter.
The te s reviewed plant modifications made to fulfill commitments made regarding ATWS, the instrument air system, the diesel generator fuel oil day tanks, and others.
Except for the instrument air system, the team found that in all other cases, the design changes that affected the FSAR were captured in the FSAR update process. Modifications made to the instrument air system were reflected in the FSAR process and instrumentation drawings. However, the text description of the instrument air system did not include the changes made to the system in response to GL 88-14 and did not describe the system as operated in the plant at the time of the
)
audit.
III. Discussion A.
Commitment Manaaement The team found that commitments affecting the plant's current licensing basis were being implemented and maintained.
In its review of licensee commitments made in response to specific issues, the team found no significant deficien-cies in identifying, ' mking, completing, and maintaining licensee commit-ments in design, equi m n procedures, and programs.
The team found one isolated instance in ws h rommitment made in LER 87-12 to add a caution 2
i
F i
note in a technical specification action statement had been inadvertently closed without being completed. The licensee was not aware of the oversight and indicated that it intends to revise the LER.
The licensee maintained two computerized systems for tracking commitment-related items. The nuclear operations tracking and expediting system i
(NOTES) applied to commitments to be completed by a date or event and that, once completed, would be considered closed. The nuclear operations commitment system (NOCS) applied to commitments involving actions on a continuing or periodic basis. The NCCS and NOTES programs were clearly defined and explained in Nuclear Operation Department Procedures N00-9 and NOD-10, respectively. Other programs, such as the enhanced design basis document (EDBD) program, contained mechanisms to screen and assess items for inclusion in NOTES and NOCS as commitments.
The licensee's processes for the origination and the permanent revision of plant procedures provided excellent assurance that existing commitments would i
be incorporated in new and permanently revised procedures.
The team reviewed the licensee's administrative instructions (Als) for new procedures (AI-400B) and permanent revisions (AI-400C).
Both Als specifically required the originator to obtain a listing of all applicable commitments and gave detailed instructions on commitment implementation. All procedural commitments made in response to the specific issues reviewed by the team (see the appendix to this report) had been incorporated in the applicable procedures and were in effect at the time of the audit.
In addition, the team identified commitments from docketed correspondence affecting three separate surveillance procedures (SP-0110, 0421, and 0910) and requested the commitment input regarding the revision of the three procedures. The commitment listings for all three procedures accurately reflected the commitments identified independently by the team.
The team concluded that the licensee's program for procedure origination and permanent revision was comprehensive and effectively imple-mented.
For plant modifications, the licensee's program required that certain regulatory issues and any resulting commitments be reviewed. Modifications are implemented through a modification approval record (MAR) that documents 1
engineering activities to perform a plant modification. The MAR process included a checkoff list for specific issues such as fire protection, high-energy line break, environmental qualification, station blackout, and license conditions. The list provided guidance to the MAR preparer regarding poten-tial requirements and commitments that might not be obvious (such as in the FSAR) but could affect the proposed design. However, other than modifications involving those specific regulatory issues, there was no defined process for design ma ifications requiring the review of previous commitments. The team did not identify any examples in which a committed modification was inadver-tently altered by a subsequent modification and attributed this to the experience level of the engineering organization and the multiple levels of review and approval required by the design change process.
The licensee defined commitments as " documented obligations to organizations that have been accepted by Nuclear Operations management and that establish requirements or promise actions to be performed." The licensee further categorized commitments as " regulatory commitments," " licensing commitments,"
quality assurance commitments," and " Florida Power Company management 3
r
commitments," each with a distinct definition. During the audit, there were no instances of disagreement between the team and the licensee involving the identification, interoretation or intent of any commitment. The team concluded that the licensee's definition was adequate to capture the pertinent information and identify this information as commitments.
B.
Renortina Chanaes to Commitments Made to the NRC The licensee did not include specific guidance in its procedures for reporting changes to commitments and relied on the judgment of its managers for making such decisions.
The licensee indicated that meeting commitment dates was very important and, therefore, the NRC would be formally notified of changes to commitment schedules through docketed correspondence.
The licensee also indicated that the NRC would be formally notified of changes that altered the intent of the original commitment and to changes in commitments that the licensee judged to be of particular interest to the NRC.
If, in the judgment of the licensee's management, a change to a commitment did not alter the intent of the commitment, the licensee would document and justify the change and annotate its tracking system without notifying the NRC of the change. The licensee relied on the expertise of its licensing and compliance managers to '
decide those issues that may be questionable regarding a commitment's intent.
The team noted that the licensee's modification program procedure required a review of cancelled modifications to ensure affected site organizations were notified and associated commitments were properly evaluated, even though its commitment management procedures did not specifically address reporting changes to commitments. Only one commitment the team reviewed, a modification made in response to GL 88-14, was subsequently changed and had been canceled only recently.
The team found that the licensee's tracking systems provided linkage between the engineering organization implementing the modification and the nuclear compliance organization responsible for tracking commitments. The team concluded that the licensee's program would result in notification of the NRC of the change in the commitment once the licensee completed its processing of the cancelled modification.
The licensee provided the team several examples where it notified the NRC of changes to previous commitments. The examples included (1) notifications of reductions in commitments in the Crystal River quality program, as required by 10 CFR 50.54(a)(3); (2) notification of a change to a previous commitment made
.l in docketed correspondence t.ven though prior NRC approval was not required for the change, and (3) an oral notification of an NRC inspector, which was documented in the inspector's inspection report, of a change to a commitment
{
documented in an earlier inspection report.
These examples, including the GL 88-14 item discussed above, indicated to the team that the licensee managed and reported changes to commitments it has made to the NRC.
C.
Maintainino And Vodatina The Final Safety Analysis Report The licensee controlled updates to the FSAR through procedures used in the design change process. During the audit, the team reviewed MARS generated to support the installation of the ATWS system, changes to the instrument air system, modifications to the diesel generator fuel oil day tanks, structural changes inside the containment to add personnel platforms, and others.
Except 4
- _. ~
for the instrument air system, the team found that, in all other cases, the design changes that affected the FSAR were captured in the FSAR update process.
The MAR process included two methods to ensure a plant modification would i
result in an FSAR update.
First, changes to FSAR drawings categorized as 300 Series drawings are automatically incorporated into the annual update of the FSAR by the document control department.
The individual generating the MAR does not need to prepare separate documentation to updata the FSAR. The 300 Series drawings are the process and instrumentation drawings (P& ids) for all major systems, such as high-pressure injection, containment spray, and condensate.
The second method required a separate form to be completed by the originator i
of the MAR to indicate if an FSAR update was necessary for text and figures that were part of the FSAR, but not designated as 300 Seri.es drawings. The procedure that controlled the MAR review for 10 CFR 50.59 applicability specifically instructed the engineer to check for changes to the FSAR.
The MAR packages reviewed by the team contained a discussion of the FSAR applica,
bility for the modification and the appropriate text and/or figures that required revision, except for the instrument air system MARS.
The team noted that modifications made to the instrument air system to increase the air system reliability were not incorporated in the FSAR text.
The licensee had added two emergency air compressors and an instrument air drying column to the system.
Although these modifications were reflected in the applicable FSAR P&ID 300 Series drawing, the text description of the system had not been revised to describe the second air column and the addi-tional air compressors.
}
i t
8 5
,,.-vr--,-,--
r,-. - -.r,~v
,~w,...
..n,w,w..r,..
_.w._,w---,-
r-APPENDIX - SPECIFIC ISSUES REVIEWED AT CRYSTAL RIVER To examine the implementation of the licensee's programs, the team reviewed the licensee's response to the following specific issues:
10 CFR 50.62 Anticipated Transient Without Scram Generic Letter 89-13 Service Water System Problems Affecting Safety-Related Equipment Generic Letter 88-14 Instrument Air System Problems Affecting Safety-Related Equipment Bulletin 85-01 Steam Binding of Auxiliary Feedwater Pumps NUREG-0737, I.C.5 Procedures for Feedback of Operating Experience to Plant Staff Enhanced Design Basis Document Program Notices of Violation 50-302/89-01, 50-302/89-15, and 50-302/89-19 (NOVs)
Licensee Event Reports 87-12, 87-16, 87-19, 87-20, 87-23, 88-13 88-16, 88-23, 88-25, and 89-01 10 CFR 50.62 - Anticipated Transient Without Scram (ATWS)
The team reviewed the licensee's commitments to the NRC concerning ATWS that had been incorporated into the physical plant and were tracked in the licensee's configuration management system. The team also reviewed the modification approval records (MARS) that were generated to install the ATWS modifications in the facility and performed plant walkdowns of the installed modifications. The licensee had reviewed the ATWS system modifications for 10 CFR 50.59 applicability and submitted the appropriate changes to the technical specifications to the NRC. All commitments made by the licensee to the NRC involving the ATWS system that were reviewed by the team had been met.
The team reviewed the two major subsystems of the ATWS system, the diverse scram system and the ATWS mitigating system actuation circuity for changes to the system that may have affected past commitments made to the NRC.
No deficiencies were identified. The licensee had incorporated the Babcock and Wilcox Owners' Group recommendations regarding ATWS in the design and instal-lation of the ATWS system. The team concluded that the MAR review process provided an adequate review for the installation of the ATWS system with respect to incorporating commitments made to the NRC.
Generic letter 89-13. " Service Water System Problems Affectina Safety-Related Ecuipment" The licensee's control and implementation of commitments made in response to Generic Letter (GL) 89-13 were acceptable. The licensee had documented actions taken to address generic letter in its response of January 30, 1990.
Previous problems with ultimate heat sink temperatures and technical specifi-cation limits had resulted in the implementation of analyses, testing, and
i
~
maintenuce programs that essentially addressed all the GL 89-13 requirements.
As a result, no hardware modifications were made and no significant procedure changes were documented as part of the licensee's response.
Generally, the i
actions identified by the licensee in its response were the continuation of l
existing programs.
The team confirmed that those actions had been entered in the licensee's tracking systems and identified as commitments.
Generic letter 88-14. " Instrument Air System Problems Affectina Safety-Related Eauipment"-
The licensee responded to GL 88-14 by letter dated February 9, 1989, and listed 15 actions as part of its plan to resolve issues for its air systems.
The licensee provided a final status for the 15 actions in a letter dated September 20, 1990, which also included the status of 9 additional actions related to the air systems from its safety performance improvement program.
The actions included adding a new instrument air dryer, revising system drawings, developing test and emergency operating procedures, developing lesson plans, performing several studies, and installing a dew point monitor i
and accumulator drain valves. The team verified implementation of the 15 actions and several of the improvement program items and found that 14 of the 15 actions had been implemented and had not changed since they were implemented.
The one ::ction that had not yet been implemented was adding remote control and indication for all instrument and service air compressors.
The licensee had developed modification packages to implement this item, but decided to cancel the modifications several days before the audit.
The licensee's tracking system (nuclear operations tracking and expediting system) provided a positive link between the engineering department responsible for developing and implementing the modifications and the nuclear compliance group responsible for tracking commitments.
In addition, the licensee's modification program required the supervisor in the group canceling a modification to be responsi-ble for ensuring that closure activities are completed, which included ensuring that corrective action commitments associated with the modification are evaluated.
The team found that the licensee's program was adequate to ensure that a changed commitment would be recognized and the NRC would be notified of the change. However, cancellation of the modifications was so recent that the licensee had not yet notified the NRC.
The team reviewed the licensee's commitments made in response to GL 88-14 against the current FSAR.
It found that the text description of the air systems in the FSAR was not representative of the systems as installed and operated in the plant, although the system process and instrumentation drawing in the FSAR had been updated to reflect the current plant configuration.
In reviewing the modification to install the second instrument air dryer, the team subsequently found that the 10 CFR 50.59 safety evaluation indicated that a change to the system description in the FSAR was not needed and, therefore, no change had been made.
The team believed, however, that a change to the system description in the FSAR was warranted.
The licensee indicated in discussions with the team that it would consider revising the description of the air systems in the next update of the FSAR.
However, the team did not consider the sparse description in the FSAR to be particluarly safety significant. The air systems are not safety related, the only safety-related air components are accumulators on selected equipment that 2
7 are identified in the FSAR, and the air systems were adequately described in other documents such as the licensee's enhanced design-basis document and lesson plans for operator training.
NRC Bulletin 85-01. " Steam Bindina of Auxiliary Feedwater Pumps" The licensee's control and implementation of commitments made in response to Bulletin 85-01 were complete and comprehensive. The licensee had committed to make procedural changes, including (1) monitoring of emergency feedwater (EFW) pump discharge piping temperature once every 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shift and (2). if steam binding was. detected, recovery of the EFW pumps in accordance with the applicable section of Operating Procedure-605, "Feedwater System."
1 The commitments made by the licensee involving the procedural changes were implemented and still existed in the current operating procedures even though the original procedures had been revised a number of times since the licensee's response to the bulletin in February 1986. ' For example, the procedure to recover a steam-bound EFW pump is now located in OP-450, "Emer-gency Feedwater System."
In addition to reviewing the procedures, the team performed a system walkdown verifying the procedural steps for recovery of a '
steam-bound EFW pump and located the instrumentation for obtaining the EFW pump discharge piping temperature.
It also reviewed the logged EFW discharge piping temperatures for the past 6 months. No deficiancies or anomalies were noted.
NUREG-0737.I.C.S. " Procedures for Feedback of Operatino Experience to Plant Staff" The licensee's control and implementation of commitments made in response to the requirements of Item I.C.5 were complete, and the resulting program for the review and feedback of operating experience met these requirements. The team also reviewed the licensee's actions in response to a specific issue, discussed in NRC Information Notice 92-36, "Intersystem LOCA (Loss-of-Cool ant i
Accident) Outside Containment," to examine the licensee's implementation of its operating experience feedback program. The licensee had performed a comprehensive, multidisciplined review of the intersystem LOCA issue.
The review was conducted by representatives from the quality program audit group, Licensed Operating Training Program, the nuclear quality assurance surveil-lance group, and nuclear operating engineering. Actions taken in response to the information notice were in accordance with the licensee's program for the feedback of operating experience.
The team reviewed a second specific example of response to operating experi-ence feedback as the result of discussions with the EFW system engineer.
During the walkdown of the EFW system, the team noted that the EFW pump i
turbine governor valve was disassembled (the plant was in a mid-cycle outage during the audit). Discussions with the system engineer indicated that the valve was disassembled for preventive maintenance as the result of the feedback of recent industry experience involving turbine overspeed trips at two different nuclear plants that occurred because a governor valve failed to stroke properly.
The governor valve malfunctions were due to stem corrosion.
The team reviewed the operating experience review forms and EFW governor valve work request.
The actions taken in response to the industry operating i
3
f i
l experience were appropriate and performed in accordance with the licensee's program. The team noted that this was an example of the benefit of learning from industry operating experience.
Enhanced Desian Basis Document (EDBD) Proaram The EDBD program involved a detailed assessment of the design and performance requirements for a total of 37 safety systems and key non-safety systems. The licensee had essentially completed the EDBD program at the time of the audit,
+
and all planned ' system documents had been issued or were being developed. The program review had identified 458 items needing resolution. Of the 458 items, only 37 remained open at the time of the audit. The team noted that the t
licensee had procedures in place that controlled the evaluation of EDBD opec.
I items for operability, reportability, and prioritization.
i The EDBDs emphasized the minimum performance requirements.for each system and major component.
For example, the EDBD might identify a 50-gpm pump flow requirement from an accident analysis while the FSAR contained a design-basis value of 100 gpm and the acceptance criterion in the applicable test proce-dures might be 90 gpm.
The EDBD, therefore, would be used as an aid to assess equipment or system operability. This emphasis and the licensee's stated intention to keep the EDBDs current as living documents provide enhanced assurance that significant system and component performance commitments will be effectively maintained.
NOV 50-302/89-01 The NOV was issued following a personnel error that caused an inadvertent actuation of the EFW system. As part of the corrective actions, the licensee committed to add cautions to the plant heatup procedure (0P-0202) and the feedwater system operating procedure (0P-0605). The team verified that both procedures contained the designated caution statements and that the commitment was properly characterized in the licensee's tracking system to preclude inadvertent deletion of the caution statements during subsequent revisions.
l NOV 50-302/89-15 A. Battery Electrolyte tevels Above Maximum level The NRC resident inspector had found the electrolyte levels slightly above the I
maximum level mark in several cells of both station batteries.
The licensee declared the batteries inoperable because the raised electrolyte levels did not satisfy the technical specification surveillance requirements for battery operability. The licensee subsequently established, in conjunction with the battery manufacturer, a new acceptable maximum level and modified its battery surveillance procedures and added operator aids to each battery cell.
The team reviewed the battery surveillance procedures and verified that the operator aids were installed on the batteries. The procedures contained the revised instructions to ensure that electrolyte levels do not exceed the acceptable maximum levels and all the battery cells retained the operator aids. The licensee's tracking system linked each battery surveillance procedure to the commitment for the new electrolyte level to ensure that the commitment would remain in the procedures if the procedures were revised.
4
NOV 50-302/89-19 A. Channel Functional Test Not Performed for Hydrocen Monitors. and NOV 50-302/89-19 B. Manual Valves Not Verified Closed Every 31 Days In regard to the first violation, the licensee had failed to perform a required technical specification surveillance test on the containment hydrogen monitors within 31 days after it issued the surveillance test procedure. The test and procedure were developed as a result of a change to the technical specifications, and the licensee determined that the test had not been performed because responsibilities and authorities for the new test procedure were not well defined.
In response to the NOV, the licensee added the appropriate responsibilities to the initial issue of its Nuclear Compliance-Procedures Manual NC-01, " Nuclear Compliance Instructions." The audit team found that the commitment was entered in the licensee's tracking system (nuclear operations commitment system (NOCS)), was linked to the associated sections of the NC-01 procedure, and had remained in the procedure after several revisions although the wording (but not the intent-) had been changed.
In regard to the second violation, the licensee had failed to include several manual isolation valves in a surveillance procedure and, therefore, failed to-t periodically verify the position of the valves. The licensee subsequently added the valves to the surveillanca procedure, and the team verified that the valves were listed in the current revision.
The licensee linked the surveil-lance procedure to the LER issued for the missed valve surveillance in its tracking system (NOCS).
Licensee Event Reports (LERs)
The team reviewed the commitments associated with the corrective actions contained in the fnllowing 10 LERs:
87-12 Failure to Complete Technical Specification Required Surveillance for Vital Bus Transfer 87-16 Personnel Cognitive Error Results in SP Specifying RPS Setpoints Outside Required TS Values 87-19 Exceeding Emergency Diesel Generator Design Rating During Surveillance Testing 87-20 Personnel Error During Original Plant Design Specification Development Leads to Ultimate Heat Sink Temperature Exceeding Limit and to Opera-tion Outside Design Basis 87-23 Defective Procedures Lead to Technical Specification Violation of Not Providing Audible Neutron Flux Indications Prior to Entering Mode 6 88-13 Apparent Subcontractor Failure to Develop and Submit Detailed Design Documents Leads to HVAC Control Air Tubing Installation Not in Accor-dance with Seismic Requirements 88-16 Operating Outside the Design Basis Due to the Failure to Treat the High Energy line Break Analysis as an On-Going Design Criteria 5
. ~ - -
88-23 Miscommunication of Requirements Resulted in Technical Specification Violation and Failure To Satisfy NRC Requirements 88-25 Failure To Recognize Out of Specification Readings Leads to Failure To Enter Into Action Statement Thus Violating Technical Specifications 89-01 Unknown Cause Leads to Installation of Improperly Sized Three-Way Solenoid Air Valves and Results in Plant Being Outside Design Basis The sampled LERs contained commitments to a wide variety of corrective actions including hardware modifications, technical specification and FSAR changes, procedure revisions, and technical studies.
The team did not identify any safety-significant deficiencies with respect to the licensee meeting and maintaining the commitments in the sampled LERs.
In the case of LER 87-12, one omission was noted. One of.the commitments in the LER was to place a caution note in a technical specification action statement. No such note was present, the licensee's internal system showed the item as being closed, and the affected page had never been revised. The,
LER was submitted because personnel error resulted in a missed surveillance requirement. The significance of this missed commitment was mitigated by the i
licensee's administrative controls for ensuring completion of required surveillances.
The licensee stated at the exit meeting that it intended to revise LER 87-12.
LER 88-16 stated that certain modifications would be completed by the end of refueling outage 8; however, they had not been performed at the time of the audit, nearly a year after refueling outage 8 had been completed. The team noted that the licensee's overall response to this issue had been the subject of several docketed letters and meetings with the NRC in which changes to the LER commitment were discussed.
The NRC-licensee interactions resulted in NRC acceptance of actions that were different from those proposed in the LER.
The licensee stated it would consider a revision to the LER to remove the poten-tial for confusion.
With the exception of the isolated omission discussed above concerning LER 87-12, commitments made in LERs were recorded in the licensee's tracking systems, had been properly implemented, and were being maintained.
i l
6
)
^ ^ -
-