ML20198J781
| ML20198J781 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 01/10/1998 |
| From: | Holden J FLORIDA POWER CORP. |
| To: | |
| Shared Package | |
| ML20198J675 | List:
|
| References | |
| NUDOCS 9801140209 | |
| Download: ML20198J781 (29) | |
Text
.- - _- - - - - - - - . - - . - -_
Power
@ Florida CORPORATtON M~ l CRYSTAL RIVER U slT 3 _ l i
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l DESIGN AND l LICENSING BASIS 1
l l
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J. J. l(ofden Director, Site Nuclear Operations 1
9001140209 960110
.. PDR ADOCK 05000302
=\, p PDR
. . ~ . , _ _ _ _ , _ , , , _ . . _ _ - . . _ _ , . , _ _ . _ . _ _ ,_ _ _ _ .
I Key issue liistorically, CR 3 had not properly maintained the Design and l Licensing Basis documents. Failure to properly update the FSAR over time resulted in many discrepancies between it and the plant, Plant :
changes had been made without adequate review of the impact on Design and Licensing Basis documentation. Licensing and Engineering Personnel did not have adequate understanding of the Design and :
Licensing Basis nor the information readily available to research the i
Design and Licensing Basis.
Executive There has been a significant increase in site wide level of knowledge of >
Summary the CR 3 Design and Licensing Basis. For example, over 240 personnel l were trained and tested on changes made to the 10CFR50.59 process. !
The testing was revealing in that inillally 1 of every 3 people failed after 2 days of training. Further emphasis and more rigorous standards l improved the pass rate to an acceptable level. The FSAR has undergone a major revision (Revision 24) and will be revised 6 months after restart :
(Revision 25), license documents have been added to an electronic search process to facilitate availability of the latest design basis information. Training has been given to improve understanding of Design and Licensing Basis and Configuration Management. Emergency .
Operating Procedures have been integrated with the accident analysis :
and other Design and Licensing Basis Documents. j Initiatives 10CIR50.39 The 10CFR50.59 Safety Evaluation process has undergone significant imprevement improvement with the implementation of the Safety Assessment and Unreviewed Safety Question Determination (SNUSQD) procedure (CP 213). The key areas of improvement have been:
e implements latest NRC and Industry Guidance - Procedure incorporates lessons learned from NRC inspections and the key elements of NEl 96-07 and Generic letter 91 18, Revision 1, e increased level of detaif Each SNUSQD is required to be written as ,
a stand alone document.
- More complete documentation - References must be specific and l readily retrievable or attached.
- SNUSQD Preparer / Reviewer qualifications - In order to perform SNUSQDs, all Preparers / Reviewers must successfully complete initial and requalification training programs.
- Integrity of Licensing Programs ensured - The Safety Assessment requires evaluation of the potential impact that the change could 4 have on twenty-eight plant plans and programs.
- Basis for USQD Screening dxumented - The Safety Assessment '
process ensures reasons for not performing USQD is documented.
e Consistency All workgroups on site use the same SNUSQD procedure.
.2
_ ~ - _ _ _ _ _ _ . - - _ _ _ __- -___.
l e Safety Analysis Group (SAG) SAG independently reviews all USQDs and ensures high quality of safety evaluations. :
e The NGRC, which includes previous utility, INPO, and NRC l executives, independently reviews identifiNi USQDs associated with- ;
a USQ, as well as other USQDs on an ad hoc basis, providing feedback for Improvement. ,
The emphasis on the Safety Evaluation program has increased the preparers / reviewers awareness of the impact that plant changes 5:an have l
on the Design and Licensing basis.' The program has been evaluated and found acceptable by FPC Quality Assurance, an NRC 19spection f Team and independent third party reviewers, Continued improvements to program implementation are planned through continued training, newsletters on current tods and concerns, and feedback from SAG and the NGRC.
Yhere were a number of outside and self assessments of the 10Cf R50.59 p'ogram and individual SNUSQD cvaluations. These assessments r,rovided recommendations that were implemented to improve the 10CFR50.59 process. Some of the significant assessments and the corrective actions are as follows: ,
Self Assessments e licensing and Regulatory Performance (1/97) which identified the weaknesses in the 50.59 procest e Review of SNUSQDs associated with Technical Specification Change Request Number 210 (6/97)
Third Party Assessments e Review of the new SNUSQD process ensured new procedures met NRC requirements O/97) e followup assessment six months later to ensure SNUSQD process was being properly implemented (9/97)
. Altran performed an independent review of selected SNUSQDs to determine adequacy of reviews (10/97' e NRC Inspection Report 97-08 (7/97) ,
These assessments provided assurance that the revised 50.59 program was meeting regulatory requirements and provided the necessary tools to ensure that the integrity of our Design and Licensing basis was maintained. In addition, the assessments identified a number of areas for -improvement. - These recommendations were incorporated into revisions the SA/USQD procedure made in September and November -
1997, in July 1997 (Inspection Report 97-08), the NRC evaluated the !
SNUSQD process and concluded that "the licensee's 10CFR50.59 l program - was goode ~ The '50.59 procedure and 50.59 evaluations j
3
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}
reviewed were generally thorough, detailed and comprehensive. The Licensee's self assessments of performance in this area were adequate."
The NRC also assessed fPC's performance relative to 10Cf R50.59 in five areas of concern and rated them as follows:
- Management Oversight Cocxl e Engineering Effectiveness - Good
- Knowledge of Design Basis Good
. Compliance with Regulations - Good
- Operator Performance - N/A Dedgn and Several Design and Licensing Basis projects have been undertaken at iIcensIng Basis CR 3. A timeline that gives an overview of these activities is included as Documentation figure 1 attached.
CDIP 1he Configuration Document Integration Project (CDIP) has been the cornerstone of the Design and Licensing Basis upgrade process. The goal of CDIP was to integrate the docketed Design and Licensing Basis information to provide an effective tool for evaluating the impact of plant changes. CDIP was formed to ensure proper integration of the significant issues resolved during the outage. A facility was established housing all of the necessary functions in an organized fashion to facilitate good communication and sharing of information. Extensive knowledge of the design and licensing basis was developed and CDIP refocused operations and design activities back to the fundamental documents (Improved Technical Specifications and Bases, fSAR and Design Basis Documents). The process used by CDIP was a direct input to the development of a lasting, comprehensive, and integrated approach to configuration management being implemented at CR 3.
CDIP also developed a sophisticated electronic FSAR change log which effectively ties the pending changes and the source documents into a user friendly tool.
CDIP developed Revision 24 to the FSAR which has done the following:
. Validated the Chapter 14 Accident Analysis
- Documented the eight committed design margin improvements e included the resolution of USQs approved by the NRC e Updated sections to reflect modifications and procedure changes made during this outage e Revised numerous areas for clarity and readat.ility
- Integrated approximately 850 resolutions from the Corrective Action Program and other extent of condition reviews
. Utilized CD-ROM technology to create cor. trolled, paperless copies of the FSAR.
CDIP will continue and be fully functional in 1998 until the integration concepts are implemented into the CR 3 Configuration Management 4
processes. Revision 25 to the fSAR, which is planned to be issued six months after startup, will incorporate further improvernents and the -
additional issues found during the later part of the outage. These improvements coupled with the improved FSAR document search tools l will facilitate continued improvement of Engineering and Licensing reviews and ensure that CR 3 continues to operate within its Design and ;
Licensing Basis. !
Complimenting CDIP and directly supporting the System Readiness Reviews, FPC performed an in depth review and collation of docketed NRC requirements, commitments and required codes and standards on i a system by system basis. The review included over 12,000 docketed items dating back to 1976. The project produced a set of Licensing '
Basis Review System Notebooks, an electronic, searchable database and -
an fSAR with changes annotated back to Revision 0. A clear and concise licensing basis was developed for each system allowing quick - :
and accurate access to information critical to each of the System Readiness Review systems. These documents and tools were essential to the System Readiness Review and CDIP process and will continue to ;
be a valuable resource as further evaluations of proposed modifications ,
are performed. ,
Resolution of On October 8,1997, the NRC issued Revision 1 to Generic Letter (GL)
Nonconforming No. 91 18 "Information to Licensees Regarding NRC In>pection Manual fquipment and Section on Resolution of Degraded and Nonconforming Conditions."
Materiel FPC incorporated applicable information from this GL revision into FPC Conditions Compliance Procedure CP 111 " Processing of Precursor. Cards for Corrective Action Program." Primarily, this involved changes to existing instructions for the preparation of Deficiency Reports (DRs) for ,
the disposition of nonconforming conditions.
FPC now requires a DR for any nonconforming equipment or materials that are not returned to a conforming condition within 90 days. The 90 day clock starts when the nonconforrning condition is documented on a :
Precursor Card. The DR process includes a Safety Assessment /
Unreviewed Safety Question Determination evaluation for all cases in which the nonconformance is not returned to original specifications within 90 days.
Many of the DRs that have been generated by this new process are internally referred to as "JCOs (Justifications for Continued Operation)."
The JCO reference in this case is not consistent with the NRC definition in GL 91-18, Revision 1; however,- it is consistent with the FPC definition in Compliance Procedure CP-150 *ldentifying and Processing Operability Concerns." CP 150 uses the term JCO in much the same -
way as other plants use the term " Operability Determination." in short, it is the technical basis for equipment operability with a nonconforming condition. - j
Several of the DRs processed during the current outage have addressed nonconformances involving Unreviewed Safety Questions (USQs). f PC has attempted to correct as many USQ related nonconformances as possible during the current outage; however, several of nonconformances will require correction in a future outage, or will i require NRC review prior to final resolution.
Each DR receives a level of review that is based on component type and the results of the Safety Assessment, if required. At a minimum, all DRs receive verification and supervisor approval. If the DR does not specify restoration to original specifications within 90 days, then a Safety Assessment is competed as part of the process, and Operations Department review is required. Specifically, the Operations
- Department review, if required, is completed by the Assistant Director Nuclear Operations or a licensed SRO. If a Safety Assessment is required, it is reviewed by the Safety Analysis Group. If the Safety Assessment shows that an Unreviewed Safety Question Determination (USQD) is required, then the USQD is reviewed by the Plant Review Committee (PRC).
Although not currently required by procedure, each DR involving a USQ is being prewnted to the Nuclear General Review Committee for additional assurance that plant safety is not compromised by operation with the identified condition.
Results: The FPC process for the resolutlen of nonconforming equipment and materiel conditions is consistent with the guidelines in Revision 1 of Gl. 91 18, and provides appropriate levels of review if the nonconforming condition is not corrected within 90 days of identification. Not all nonconforming equipment and materiel conditions have been resolved this outage; however, the DR process will provide reasonable assurance that plant safety will not be compromised by operation with these conditions. Internal and external assessments of the quality of the FPC Deficiency Reports have bean conducted and are ongoing. To date, the results show that the conditions have been adequately dispositioned.
JCOs/DRs supporting CR 3 restart were in<iependently reviewed by T. P.
Noonan and Associates. This independent review concluded that the JCOs/DRs quality was adequate for CR 3 restart. It also concluded that the quality of the JCOs/DRs were increasing as personnel were becoming more familiar with this new rrocess.
-Integrated An Interdisciplinary Integrated Verification Team (IVT) was formed to Verification Team review the' impact of outage modifications on FSAR Chapter 14 accidents, operator actions and safety margins. This verification was performed late in the outage after almost all of the modifications were either complete or in process. Additionally, the EOPs were 95%
complete and the mitigation strategies had all been validated on the 6
simulator and in the plant. Each of the safety assessments from the LOPS and modifications affecting ECCS systems were reviewed in detail to ensure the following attributes were maintained:
. Proper process controls and communication
- Closure of open issues regarding accident mitigation e Proper consideration of operator and staff burden
. Verification and validation of design and plant practices The IV1 found that the Chapter 14 accidents were adequately covered in the modifications and emergency operating procedure revisions made during the outage. Over 20 percent of the restart modifications directly enhanced the ability of the operator to operate the plant. The balance indirectly enhanced the case of operation through restoration of design and safety margins. Thirteen follow up actions were recommended with one requiring immediate action relative to a conflict in the design of the Nuclear Services Closed Cycle Cooling System versus LOP accident management. Once the concern was identified and presented to Engineering management, prornpt action was taken to address and resolve the problem.
The IVT concluded that overall effects of the modifications and procedure changes enhances the ability of the operator to prevent and mitigate accidents, it was concluded that there was an obvious increase in the knowledge level of the staff, most notably the system engineers, operators, and design engineers. Activities where deficiencies existed during normal operation have been repaired or analyzed to relieve operator burden and ensure stable operation. Emergency response has also been enhanced through this gain in knowledge of the design and licensing basis of the plant, and through modifications made to the Technical Support Center and Emergency Operating facility.
Tralning Training in the area of Design and Licensing Basis ha also been improved. A Design and Licensing Basis awareness seminar was held for key CR-3 management personnel to provide them with the skills needed to oversee regulatory issues. A third party was brought in to develop a complete training program that included the latest NRC guidance, industry practices, and NEl guidance. A comprehensive two-day training course was then conducted for Engineering personnel and other SA/USQD qualified preparers to reinforce the importance of Design Basis documentation and Configuration Management. The class reviewed Licensing, Design, and Regulatory Basis concepts.
Management expectations and commitrnent to the Nuclear Operations Directives that implement Design Basis and Configuration Management programs were also stressed.
The Training for SA/USQD was also increased to a three-day class to include a written test and a practical exam. The practical exam required that each student perform an actual SA/USQD on a realistic and 7
1
challenging plant modification or procedure change. Successful completion of the written test and practical exam were required to complete the course. Both the SA/USQD and Design Basis Documentation and Configuration Management courses must be successfully completed before a person is qualified to prepare or review SA/USQDs. The results of this program showed significant improvement in the quality of SA/USQDs based on fewer comments by the Plant Review Committee members during document reviews, follow up reviews conducted by Quality Assurance and a third party, and favorable comments received from regulatory personnel.
fmergency improvements to the Design and Licensing Basis included changes to Operating the Emergency Operating Procedures (EOPs) and Abnormal Procedures Procedure (APs). The EOP/AP Enhancement Program included a ground up Rewrite reconstruction of the EOPs and a substantial improvement in the quality of the Abnormal Procedures (APs). The objective of the program was to ensure that the EOPs and APs are technically correct and optimized from a human factors perspective.
A dedicated team of experienced Operations, Engineering, and Licensing personnel was formed to upgrade the COPS. This team had offices at the Nuclear Operations Training Center, which provided direct access to the CR 3 simulator and the resources of the training staff and operating crews, it also allowed the team to maintain close contact with the operating crews for comment resolution and discussion throughout the upgrade program. This resulted in higher quality procedures and instilled a sense of ownership for the procedures with the crews. This close coordination also provided the opportunity for the operating crews to be exposed to the new procedures during the development process, allowing them to become familiar with the procedures over a five month period, through four training cycles.
The EOPs were rewritten to resolve outstanding technical issues and to integrate the revised accident mitigation strategies resulting from the analysis and modifications related to Small Break Loss of Coolant Accident (LOCA) mitigation, including the solution sets which form the basis for TSCRN 210. Extensive technical and human factors reviews I
were performed. Program requirements included technical reviews by System and Design Engineering as well as Licensing and Operations.
Writer's guides were used to ensure consistency in format and human factors aspects, Qualified reviews were a!so performed to assure the quality control aspects of the docun.bntation.
Throughout the program, the technical I ss . the procedural actions and the resolution of technical issacs wert .b mented. The result was a cross-reference technical basis deviations document fully explaining why actions appear as they do. Upon completion, comprehensive 10CFR50.59 Safety Evaluations were performed for each of the cross-referenced documents. The CR-3 simulator was used extensively during a
1 the program as both a developmental tool and for validation of the procedures. In addition, table top and field validations were utillied to fully ensure procedure adequacy.1he in-plant and field verification and validation process included walkdowns to assess labeling and tagging; segregation of LOP field equipment into separate tool boxes; time evaluations for tasks and assessment of environmental considerations.
INPO, the Quality ISograms department, and the NRC each performed reviews or inspections of the procedure developrr.ent process and the final products. Comments from each of these reviews were incorporated into the procedures. This process, in essence, tied together the design and licensing needs, operating aew burden reduction requirements, and verification of field actions under one umbrella. The rewrite resulted in restructured procedures that are technically correct, effective in accident mitigation, and are clear and straightforward for the operators. In December, the licensed operators completed their annual examinations, which included use of these procedures, with a 100%
pass rate.
The final EOPs are a substantial improvement over those previously in place at CR 3. lhe number of manual operator actions during the citical stages of the event (i.e., within 20 minutes of event initiation) was reduced by one. More lmportantly, the burden on the operator was markedly reduced through a number of efforts. Examples include:
- Procedurallied operator actions were simplified, in the past, steps such as HPI flow balancing were imbedded in EOPs which required the operators to perform a series of steps such as reading n.ultiple flow meters and operating flow control valves to balance HPl flow.
Our new procedures have simplified these steps and now require flow in an HPl line to be isolated if is deteimined that the line may be faulted.
. New instrumentation was installed to simplify the burden on the operators, for example, HPl flow indication was changed from edgewiw meters to digital meters which read out in GPM. This reduces the effort needed to ascertain HPl flow in each HPl line.
- A large [fW cross-tie valve, which previously had to be opened manually, has been motorlied with its controls located within the Control Complex.
. Procedures have been clarified to remove ambiguity and improve their case of use.
The EOP/AP Enhancement Program has included over 30,000 man-hours of effort resulting in EOPs that are consistent with the CR-3 design and licensing basis and the B&WOG Technical Basis Document.
9
Conclusion The improvement to the Design and Licensing Basis documentation and update processes will ensure that personnel making changes to the plant will have reliable resources available to perform complete and accurate Safety Assessments and Unreviewed Safety Question Determinations.
The enhanced training has provided personnel with the knowledge to use the proper dc.umentation in the review process and perform the appropriate updates as needed. The EOPs now accurately ensure design basis assumptions are translated to the procedures. The Design Basis and Configuration Management directives demonstrate CR 3's commitment to these programs, and convey the importance of the role these programs play in the safe operation of CR 3. All of the above accomplishments have contributed to:
e Improved knowledge of safety margins e Improved Operator performance e improved Configuration Management e improved Safety Analysis process e improved resolution of Engineering and Licensingissues e Improved Regulatory Compliance i
i I
10
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parating Procedures 1997 1998 M J J A S O N D 97 300 97-12 (7/16/97)
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- RAI- EOPs (9/17) Additional info -EDG test plan (11/5)
LAR 216, EDG elr handling (8/26)
Future HPI mods Response to 11/5 NRC RAI(11/15)
Proposed EOPs (8/4) l ~ (9/17) Response to 12/3 J7- , \d/ \/ \/ \h7 \[/ "" "^'j'*' ',
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ds(C) - EDG Appendix R cables (C) j ongoing) - EDG radetor replacement (C) 1
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(9/12)
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'n (6/26) indicator (8/4) LAR 2203223 Additionalinfo (12'20)
X7 V V Vm.
VN/V, . .. .
! LAR 223 I
Addrtional info (12/4)
Weakness in inconsistencies in 10CFR50.59 -
LAR 2M & 223 (10/9) (12/9)
V .. . . . . . .
V ;]
Thermocouple Crastie FW cabo1' Return to Scryk e Instr. Upgrade (OngoN)
- MWahn, Return to Service
-, _ X7 ( "S*"S) q 9801140200- ,
1
Control Complex Habitability 1994 1995 1996
, J F M A 95 02 95 09 95 21, URI 97 05 (Ca (2/22) (7/7) (2/26) (
insp. V7~
s7 V7 '
Reports ' 21 '23 23 95 11 94 25 95 16 (12/20) ~
III24) - - (10/31)
Meetings / ,
Telecons TSCRN 208
- LER 95-09 withdrawn LER 95-04 01 (6/30)
I I TSCRN 208 LER 9410 submitted (12/23) 8/28 Submittals-T7-
\ /\ /
N/- - -
N/-
/\ n /\ /\
LER 96 04 I I Restart issue CCH LER 9510 - MC AP 11 action - Opei (3/7) plan 4/8 NRC , \/
Letters R:,
Plant ,
Mods
.n
Envelope i,LAR 222) 1997 1998 M J J A S O N D 97 07 s) 97,33
- 2) I I (10/16)
T,7 T7 T7 ,
8/21 -
0 11/14 NRR - MeeHng N technical (1/
Restart Panel es art Panel 0I Technical x7 v v \/
10/30 Restart Panel 4^ _ 11/20 Restart Panel LER 97 22 00 - LER 97 22 01 LAR 222 (8/27) Subtrittal 12/5
- tiabitability Report
- s. after restart))
r p . rability commitment
- U
~
\./ \./ \.! .
5
/\ L Test results JCO 11/10 - 12/15
'3 REVS RAIon R Al on NPn approval
>ility (use of 3.0.3) Letdown Line CCHE si LAR 222 12/9 12/24 (by R11)
X7 N/ x7 10/18 10/12 Install vestibules
- Perform CCHE 12/6 leak test - Install new iso. Turnover to 10/4 dampers - Operations
' sign start (7/97) l Upgrade q (complete) penetrations j g \7 Information test 9801le0209 O ,-
USI A-4(
1987-90 1991-96 J F M
- *9C C_ - u_
t 43, Meeting Telecon -discuss outlier (5/26/93) resolution (4/18) l Meetings / .
Telecons
_ Plan for responding to Resoonse regarding IPEEE GL 87@ (9/N92) seismic being done under A-46 ~~
Clarification of intent with (12/19/91) PSP (4/16/93)
Notify NRC of intent to use Revision 0 of PSF and Technical setsmic experience data -- - Bash Docent _
(7/18/91) 3) Response to NRC 4/12/94 letter (6/94)
Submittals--
Respond to NRC ansmM ' Seismic
- Evaluation Report for 7/9/93 RAI(9/7/93)
Transmit RB floor response USl A-46' R0(12/31/95)
Revision 1 of PSP spectra (10/6/93)
(9/16/94)
Acknowledge SER on re< ponse spectra /further clarification m PSP Respond to NRC 4/12/94 (1/7/94)
RM @ m
_ 5/26/93 Meeting minutes (5/26/93) sp nse to F _ RAI for De response GL 87-02 (4/20/87) 8742 resg A - W ra W 3)
(IIII E 2) SER for fbor
{7 -. spectrum (12/16/93)
NRC r-V' .NV ehs ' '
Comments on 4--
RAI on " Seismic PSP,RO (4/12/94) I Evaluation Report for SER for plant specific criteria and USl A-46'(1/28) procedures for A-46 (5/2/96)
Plant Mods "
.n
.Rrclution 1997 1998 M J J A S O N D Site audtt of A-46 (11/3-7) l
\[ ., Telecon- Ust of post restar Telecon - provide update to current status
- outlier eqpt. (OCR) for NR
'"I'*III 0) of resolution of outliers (1/7/98)
Telecon status of resolution of outliers (5/2) Meeting - Discuss schedule for resolutior) Meeting > status of Telecon esolution of outliers of overall A-46 program (12/2) ] - resolution of outliers from wt.ndown (5/16) v- . . . - t'\/ \/ .
\ / (1/8/98)
_ /\
TeWon- Provide copy of Te econ Provide cross reference table (12/19)
(12/19) hspond to NRC Second Response to NRC - b pp me aI to 28/97 RAI(3/27) 1/28/97 RAI (8/1) Documents 12/2 m*eting results and plan for resolving outfiers (12/8)
NR ,
l l V xx.7 (12/16) e
]
initiate program to resolve outliert (Sep/97)
V .
98 0114 02 09 -Ch -
n~
Large E 1988-1990 1991-96 o F M A M NRC Insp. ' ~ ~
Meetings / _ _ _ _ _
~ -'
Telecons Piping comphes with B31.1.0-1967. Other than R tested to B31.1.0-1967, fabricated, erected, inspected to B31.7. Plan developed for Cia fatigue analysis by 9/30 (6)
Submittalg NRC RAI- FSAR does not indicate rigorous fatigue _
analysis required for Class I piping (4/7)
NRC L ._.
\7
- SW piping reanatysis due t
- SFP cooling piping reanaly-
- RW spool piece ieplacemej
- Cl piping upgrade from norj Demin. water - seismic upg
- Relocation of MUV 103 This outage - piping / support work - Muv s67 addition
- RW cyclone separator strai
- Decay heat vent valve add!t EDG fire service header se
- Thermal relief valves and pi
- WGDT seismic upgrade
-IA backup air supply Plant \/- - DH closed cycle coolina reli Mods '
-~
mm __-._ _. m 70 Piping 1997 1998 J J A S O N .D
Restart meeting Meeting p'an for (10/31) resoMng issue (12f2)
_ V y Plan & schedule for fa.tigue analysis for LER 97 040@(12/4)
RCS attached piping to be complete by Voluntary 11/30/98 (11/21) Plan for resoMng Address SSFl questions raised by **
I _
NRC (11/10) !
\/
NM R- ,
Corrective action plan and
/\ /\
I consultant reports (11/18)
'~
Response to NRC 12/2 RAI(12/18)
RAI (12/2)
\/ ,
er LOCA temp.
e to seismic overlap and rod uplift nic13 seismic piping
- Ongoing upgrade go. \/
9801140209-O7 _
=
Jet li 1988-1990 1991-96 J 'F M A 95 15 95-21 (0/11/95) ] { (296)
NRC , \[\[
Insp.
Meetings /
Telecons '
Response
4/10/97 F Submittals tr_._._ _ _. _._-.
NPS RAl. dynamic effects of LOCA(4/10)
NRC '
\!
letters Su tw PIP a
Plant '
\ \/
Mods
,-s-.
1 i
l ing ment 1997 1998 J J A -S O N D Meeting- discuss 10/9 NRC letter / actions (10/22)
\/
Response to NRC 5)
~
- 0 - IN #'IUIN) -m 1/ _
v -
v v 10/22 Meeting minutes (10/29)
Questions use of 30 vs 20 degree cone Requests additional info regarding angle and 50.59 process (10/9) extent of conddion reviews (12/23)
VV V Engineering Evaluations . ongoing e
m for SW Additional surgeline walkdown n->x.y
. 98 0114 02 00 -Oh
n ,, .-
t Letdown (
1988 - 1990 1991 - 1996-J F M A C
~ 97-01 97-06 (3/24) (4/17)
\/ \/
Insp.
Report [
"'* ' ' ' ' ' ' ' ' i 21 Meetings! ' ~
Telecons Submittals .
s
%< , , ~
NRC I' * '
'H lettem i
g -
i
[nJ Rupture (LAR 218) 1997 1998 J J A S O N D EA 97102 (6/5)
\/
- 3 IIII9 10/14 Telecon RAI -
Telecon RAI (RELAP) t _'
X7 y
\/
. 61 11/7 11/25 LAR 218 Response to 9S respond to RAI 11/19 telecon LAR 218 Respond to 12/9 NRC-RAI (TBD)
\/ \/ \/ \/
m 10/10 IN LAR 218 RAI - RAl-(Cmtd - I Room Dose)
LAR 218 noticed in FR
\/ \/ \/
.a.w =
a 9801140209- f .
Low Tei 1988-90 1991 96 J F M NRC Insp.
Meetings / ,
Telecons Revise response TSCR 174 15 EFPY to GL 6811 - (10/31/89) #" '
Schedule for (8/14/89)
_ submitting 32 LTOPs JCO and initial response to GL _ _ TSCR 174 additbnal EFPY P-T curves Code Case N-514 -
88-11(11/23/88) Info (8/10S0) request (4/7)
Submittals t_u_ *o -
V (9/6/96) -
TSCR 174, Suppl.1
/Y\
l (3/30/90) _ Response to GL 90 @ (12/20/90)
TSCR 151 approval for RAI Operator Request for LTOP testing of PL
,8 feSponse (7/11/90) be incl. in TS (2/4) ,}
Approvalof P-T GL 68-11, NRC - curves for 15 EFPY (2/7/91) Approvalof GL embrittleme /2 i ''""
nac '
\W V V V letters Denialof LTOP methodology (8/31/95)
l l
perature - Over Pressure (LAR 213) 1997 1998 A M J J A S O N D Telecon RAI
- Telecon (9/10) ~ Telecon . SER questions (8/13) discrepancies (12/29)
V v r -
_ _ \/
TSCRN 213, R0 TSCRN 213, LTOP JCO j~ ~ TSCRN 213, R1 ementation LTOPs (7/18) (10,d)
(6/6) TSCRN 213, change of RAI L 0 _ commitment (11/21)
- .a.. - - - -
V V .- -
W V V _,
3 notice NRC RAI Instrument e N.514 w?(10/7) LTOP SER -
(MI) Amendment 161 Approvalof code _ _ NRC RAl- 12 (12/22) case N-514 (7/3) questions (8/12)
V _
V V V _
V 98 0114 02 0 9 -[C _ _
l
- i: a - : : - --
I sn PAM( -
1988 90 1991-96 J F M A NRC Insp. -
Telecon - Discuss status of
- interim measures for SAT Telecon - Requett NRC approvalto deviate from - Telecon - discuss RG 1.97 (4/3/96) - TS change to be sent (8/29/96)
Meetings /
Telecons ,. - h/
/,\ Telecon discuss TSCRN 209 - verbal RAI (12/10/96)
Description of plans to reclassify TSCRN 209,R0 subcoohng margin as Type A (7/8/96) identified addit 9G72)
Submittals 1 -
\#/
NRC ,
letters SPDS Tsat Upgrade (5/96)
Plant
\/
V Mods -
ww
RG 1.97) - TSCRN 209 1997 ' !98-99 M J J A S O N D Telecon- answer NRC questions on TSCRN 209, R1 (10/6) l
\/
TSCRN M. R1 Respond to NRC nal Type A variab!es 1 (7/29) l 11/7 RAI(10f29) I I
\/ \/
Amendment 162 issued (12/22)
NRC RAI(10/7)
\/ Y .,
Additional SPDS upgrade (Refuel 11)
_ = ..- -
\/
9801140209- . .
.v. -
1 OTSGjTSCI 1993 1994 1995 1996 J F M 94 11 96-03 (6/13) [_ (5/24)
NRC insp.
Z_ V
- I 12/15 ;
8/21 Meetings / g_'
\p7 7 v 7 Telecons n
3/18 nonth report CAL, use of word -
(5/31)
' Preliminary (3S)
- Response to RAI Withdrawhl of (12/6)
TSCRN 198 (5/5)
Additonalinfo __ ~ Request to withhold prop. RAI info (12/13) 0 SG
, ,,, 4) - TSCRN 203 Additionalinfo (4/15) 90-day TS report (8/15 ST Tube Pull -
Concerns regardin!
*""8I7 )
U X7U J criteria for SG tubin Submittal (' 7.."
\/V s/X/
^
~.
U\7 W -.
f[._\ / \/h ('\/ \ /_N/\ '
TSCRN203 notifications prior
[\
OTSG - to Mode 4 (4/8)
Insocctons(9/30)
Refuel 9 .- TSCRN 203 R2 (3/22) TS
- nsp. Plan (4/19) - _ TSCRN 203 R1 ~,(3 (3/17)
Completon of CAL 1-6 (5/25) - - Response to GL 9543 (6/23)
CAL ltem 9, TSCRN 203 (5/31) -
GL 95-03 (4/28) ~ TSCRN 203 RAI(10/24)
Satisfacton of CAL -
- Amendment 154 issued (4/30) items 1-6(5/27)
- Concern relating LAR for Alt. Rep. Cri, Confirmatory for SG tubing (6/7)
L d er GL95-03 RAl (6/21)
{
NRC letters
, E'N ' \2'd./ k \/ . . . .
4 211 and LAR 221) 1997 1998 A M J J A S O N D 97 11 l (9/12).
\/ ,
Regression Regressin.. technique (6/10) technique OTSG Insp.
festion (5/28) l Update (6/18) q
/\/\
RAI discussion /
RAl on TSCRN 211 (6/16) - Insmtbn uNate (7/1)
TSCRN 211 R0 LAR 221, R0 Mode 4 RAI response (8/20) (10/1) and 90-day
' R for Alt. repair A
report (12,5)
Response)(9/12) a w X7. . .
\/' N/
.3 b
TSCRN 211, R1 tN 211, RO i
GL 97-06 (12/30)
GL 97-05 (12/17)
Amendment 158 Approvalof h LAR 221 issued (10/28)
(TBD)
GL 95-03 I Completion (5/19)
T7 y \/\/ \/
9801140209- . -
Al 1988-90 1991-96 J F M A NRC '
Insp.
Telecon - TSCRN 212 Telec<
(4/1) ] l (4/2)
Meeting / \>/
~
Telecons '
Plans for One-time schedular exemption TSCRN 212, RO P* "**[j - (5/19/95) (App. J, Option B)
(2/17)
Submittals <
V \/
5 Env. Assessment of request for _ lssue schedular exemption from exemption (B/28/95) App.J (9/29.95)
NRC , \i\/
letters Plant
'~"~
Mods
Ondix J, Option B 1997 1998 M J J A S O N D l
TSCRN 212 - Telecon panetrations not tested during ILRT (6/29)
"N7 LER 9741400 _ Additionalinfo (penetration test results)implemen.
(7/11) of License Amendment 156 (8/12)
_ TSCRN 212, R1 Additionallnfo,lmplementation of I )
License Amenoment 156 V V '
lasue Amendment 156 for App. J Option B (7/24)
V ,
9801140209 -/ 3 _ _
1976 1987 1988-90 1991 96 J F M [
NRC I.
Insp. -
TSCRN 210, RO . in<
- TSCRN 174, Adddionalinfo (8/10/1990) to evaluate M Submittals - -
Operating License Amendment 149. ITS (12/3/1976) (12/20<93)
NRC V ,
57 letters Plant -
C' --
Mods I
,~
ECCS Mode 4 (LAR 214) 1997 1998 M J J A S O l N D a
- <;r i]
M commMment LAR 214 t 4 requirements (10/31)
(6/14)
~ \/ ,
NRC approve license amendment (TBD)
.- l
._- a 9801140209-
o AHF-1C Mc 1988-90 1991-96 J F M A
-. l NRC ,_
insp.
Meetings / _ _
Telecons '-~~'~_
LER 96-005-00 LER 96-00501 LER 96-005-02 (2/282) (5/1/96) , (2/28/97)
Submittals - - \k/
.4- -
NRC letters' Plant '
Mod w.,
h a dification (LAR 217)
V 1997 1998
[M J J A S O N D
..a. _ .,
m_---- 1 LAR 217 (10/4)
. - \,/_ ,
NRC approval of LAR 217 (TBD) l
\/
Modification complete, return to MR 97474141 sennce upon NRC approval of I start (7/1)
LAR 217 V \/
f 9801140209- . -
. - _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ m______.______-__-_____-m_-_- _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ - _ . _ _ ___ _ m . - . _ _ . _ _ _ _ _ -
w 1988-90 1991-96
-J F M A NRC '
Insp. '
Meetings / , g Telecons Submittals i:- Ja NRC , ,
letters g 9 Plant '
Mode
< ._ s
Sorvice Water Overheating (LAR 224) 1997
-. 1998 J J A S O N D
c1 -
~
i
=:.*~~."~~T.=~~~~~'~~---._.=__-'~~ -~~~~ ~ ~ "m LER 97-02541 LER 97-02540 Ind. FMEA (9/10) (1/9/98)
V .
7 \/
/\
LAR 224 (12/5)
_ NRC approve LAR 224 (Requested 2/1398)
\/
Modifcation to be returned to service tapprovalof NRC LAR)
Modification for RB fan logic ins'.311ed,
~
tested, terreved from service (1/198)
=_. _._. ._ __. m ,- -
a i
0114v2.09-(( .
,, , - ~
+
me .
i b
I 1994 1995 1996 J F M 964) 9644 97 01 NRC (4/5) (6/17) (3/24) 4 g .
, ,_ \/
Insp. g g 96-06 l 96 17 (7/26) (12/23)
Thermolog meetine _ _ _ _ Thermche meeting ' Therm (2/28 0 ) (10/1W96) status /es Meetings /
Telecons r \7 \7 Mecah TeetN LER 9 TLC 2241 (2/14) j LER 9640101 (3/8) Schedule for LER 98 Piens (10/31)
~
_ 0'
,,'g[' 0 '* - r 9/27)
Submittals t- - V,7 T#-7 (M3) -\ /
- - - - m-- T,7 -
s 6 <-f1 21- /\--
CR 3 hrW Resolution of CT .
P lR on GL 9210 Program --
T (1/29)
LER 9640100 ~ LER 96-022-00 (2/8) (12/20)
Meeting minutes.
Meeting Minutes . Plan tc '3ke orodit for
'N w m, comp
,', - Thermole0 rwoolution Meeting minutes.
(10/24) Thermolag resolution
($10)
NRC #I
%: _ ~ .
letters
3PENDIX R 1997 1998 A M J s A S O N D 97-02 97-05 97 11
,[ (4/21) (6/2) (9/12) ~~~)
-.. _. _Y ,
og meeting . _ _. Meeting . Overview of restart App. R iedule (5/20) work status (6/11)
=_ X._7 _-
X7 _ _ _ __ .
Ind. Assessment description (7/3)
LER 97-00941 (6/27)
Schedule Update (7/26) - L.ER 97-03340 LER 96-01042 (6/23) -- 11/10) 50 59's for CT profectors LER 97 03540 Ca@ahn of 110-00(5/20) - - and fusing (8/19)
- (g gf33) lll.G and 111 L 0~ Exemption requesi Wahdraw 1110 compl. with s) - for remote oil fill - exemptton for oil original SER Imes (9/5) colkx: tion (11/13) (TBD)
. _..s 7 . _ _ _ ~. _
_ Y - . -
Tharmolag .- -. - -
ampacity/derating - d- LER 97-029 00 Revised 72 hr. cooldown results (7/3) (10/14) (12/10)
Exempton request for Thermolag and ~ Overview of App. R restart work Emerg Lighting in Auxilnterm. Oldg. - (9/25)
(70) IN 9218 resolution program (9/18)
Results of 72 br, cooldown (&29) LER 97-026-00 (9/13)
IC,J and L AcWege rece# of IN 9218 res a work (7/7) ~ -
ance review Acknowledge hfo(10/20) SE addressing Thermolag related
(!17) receipt of App. R ampacity derating issues (11/14)
~ restart over view Approval of 1110 exempton for 1 (i. I remote fill hnes (11/21)
Xz- o+ V7 V7 N.6j q
Acknowledge receipt of 72 hr.
cooldown letter (9/19)
Od> EA for remote fill hnes exemption (10/29)
EA for Thermolag exemption - .- Denial of Emer. Lighting exemption (10/29)
Approval of Thermolag exemptior',(10/29) st @ 2) 98.0t'40200 tf -
.. _ _ _ . - _ - . .__ _ . __ _ ..m.. ._ ._.__ .__ _
..--..._._._._..__.._-__m_ . _ . . . _ . . . _ _
i l
t
-l t
?
l 1
)
1994 1995 l 1996 I J F i
l i
)
1 i
. - 111.0.3 and lil.L .
MCR/RSP leoistion start - l (2/15) i i
CT secondary protectors l
- stort (2/1) j 1 ,
)
I
, Start Ill. O, J, and L wTfz s _ .
j review (tr27/96) :
i Plant /- \[\/
Mods' <
i l
1 1
l
(._
i:
i i
m APPENDIX R (Cont..)
1997 1998
~1 A M J J A S O N D l
Thermolag restart IN 9218 resolution start resolution start (7/1) ~ ~ (9/1) 111. 0 ContpMe Ill.G. J, and L kCP c2 collecta compliance review (11/19) start (8/1)
Start lll.G.1 and
~ UE% Quu,"%ie (1/5S8)
,h7 .
V. _
V7 \/ -
U V7 a 7 CT secondary protecto<s 7g, r
complete (11/25)
App. R documenta' ion Complete ( lil.G.1 and '-
updates / enhancements i
lit.J emergency -
fighing start (8/1) lit.G,2) isolation and -
(1/5f/30SB) teroutes (12/5)
RCP oil collection Fire study / Procedures Start fire study complete (12/15) ~ revised (1/9) and Procedure revisions (8/1)
Restart Thermolag -- IN 9218 complete (12/16) _gg complete (12/31)
Ill.G 3 and lit.L.
MCR/RSP isolation completo (12/28) 98 0114 02 09-[f - .