ML20211N266
| ML20211N266 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 02/19/1987 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20211N244 | List: |
| References | |
| RTR-REGGD-01.033, RTR-REGGD-1.033 GL-85-01, GL-85-1, GL-86-10, NUDOCS 8703020030 | |
| Download: ML20211N266 (7) | |
See also: IR 05000302/1986012
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ENCLOSURE
STAFF EVALUATION OF LICENSEE RESPONSE
INSPECTION REPORT 86-12
Restatement of Violation 2 (86-12-06)
Technical Specification 6.8.2.b requires that certain procedural changes receive
intradepartmental and interdisciplinary reviews by qualified reviewers prior to
approval by the responsible superintendent or manager. The Plant Review
Comittee (PRC) shall then review the 10 CFR 50.59 evaluation within 14 days of
approval.
Technical Specification 6.8.1.a requires that written procedures be established
to cover those activities recomended in Regulatory Guide 1.33, November 1972.
Regulatory Guide 1.33, Section A, recomends that administrative procedures be
established to provide the method for changing procedures.
-Contrary to the above, procedure AI-401, Origination of and Revisions to P0QAM
Procedures, which implements TS 6.8.2.b., was found to be inadequate in that it
allows Housekeeping Changes (HKCs) to be made to procedures and implemented
following approval by the responsible superintendent or manager. These HKCs do
not receive the required review by appropriate intradepartmental and
interdisciplinary qualified reviewers nor are the associated safety evaluations
reviewed within 14 days by the PRC.
As a result, several curves in the OP-103 series, Plant Curve Book, have been
changed using HKCs. These include curves for radiation monitors for the Reactor
Building air and Auxiliary Building liquid release paths and the reactor plant
heatup/cooldown curves.
Additionally, on March 20, 1986, a HKC was used to add a quality control (QC)
hold point to a maintenance procedure (MP-174) without receiving the reviews
required by TS 6.8.2.b.
This is a Severity Level IV violation (Supplement I).
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Sumary of Licensee's Response
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! Florida Power Corporation agrees that Housekeeping Changes (HKCs) should not have
been used to include curves for radiation monitors for the reactor building air
and auxiliary building liquid release paths and the reactor plant heatup/cooldown
l curves. FPC takes exception to the example that a HKC was incorrectly used to
add a QC hold point to MP-174.
Relative to the observation during the performance of MP-174 on March 20, 1986,
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no new QC inspection / verification requirements were added. The signature blanks
l added to steps 7.2.19 and 7.2.21 were redundant to information already included
in Enclosure 6, which is referenced by steps 7.2.19 and 7.2.21. These signature
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Enclosure 2
blanks were added for clarity and consistency with other procedures to remind the
person performing the procedure to notify QC prior to proceeding. The addition
of the signature blank and words " Hold Point" to step 7.2.31 was a poor choice of
words, but was not an unapproved change to MP-174 since that step referred the
user to Enclosure 3 which already contained QC inspector verification signature
blank. Again, the signatures were added to the applicable procedure step to
ensure the requirement to notify QC was not missed. These Housekeeping Changes
were made in accordance with the instructions in AI-401, and in FPC's opinion did
not circumvent the procedure review and approval process required by TS 6.8.2.
NRC Evaluation
The NRC Staff has carefully reviewed the licensee's response and notes the
licensee's position that a Housekeeping Change was appropriate in the addition
of a QC Hold Point to procedure MP-174.
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The staff concurs with the position that the signature block additions to steps
7.2.19 and 7.2.21 were redundant to information included in Enclosure 6 and that
no new inspection / verification requirements were added. The staff does not
concur that the addition of the signature blank and the words " Hold Point" added
in step 7.2.31 were the same as the signature required on Enclosure 3.
The QC signature required on Enclosure 3 is to ensure that a QC inspector has
verified that the new materials to be used have received proper inspection
through the issuance of Quality Control Inspection (QCI) documentation. The
notes on this Enclosure state: "QCI documentation for new materials must be
attached to the work package." and "QC Inspector verify QCI's
Date "
. This inspection could be performed before or after the snubber is
rebuiTt and would not stop personnel from proceeding with subsequent steps in the
procedure. The " Hold Point" added to step 7.2.31, however, requires Enclosure 3
to be completed Crior to proceeding on in the procedure. Therefore, the signature
addition to step 7.2.31 does not have the same meaning as the signature required
on Enclosure 3.
The staff has also reviewed your position on the HKC's. The NRC position on such
procedure changes is that only changes due to typographical errors can be made
without the review required by Technical Specification 6.8.2. All other changes
must be reviewed and approved as required by the Technical Specifications.
NRC Conclusion
For the above reasons, the violation occurred as stated.
Restatement of Violation 3 (86-12-04)
10 CFR 50.73 (a)(2)(v)(B) requires the subnittal of a Licensee Event Report (LER)
within 30 days of the event for any condition that could result in a loss of the
plant's ability to remove residual reactor heat.
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Enclosure 3 I
Contrary to the above, on December 19, 1985, it was determined that a design
error could cause a loss of residual reactor heat removal ability and no LER was
issued.
Summary of Licensee's Response
FPC disagrees with this violation. This design problem was identified and
evaluated by FPC personnel according to established procedures and determined not
to be reportable under 10 CFR 50.73(a)(2)(v)(B). That part of the rule requires
licensees to report, "(v) anj event or condition that alone could have
prevented the fulfillment of the safety function of structures or systems that
are needed to:...(B) remove residual heat;." The design problem (failure to
protect the bearing flush water supply to the Nuclear Services seawater pumps and
the decay heat seawater pumps from fire damage) would not alone have prevented
the function of systems required to remove residual heat. It shoald be noted
that upon uin.overi of liis inisuiiuersi.oiidien) ui Ris v=:iidur- i riiviiiis i.iuie , FFC
performed an analysis, as suggested by Generic Letter 85-01 (superseded by
Generic Letter 86-10), and voluntarily submitted this information to the
appropriate NRC office for review and concurrence. Thus, FPC notified the NRC
even though we chose not to report it via a particular means (an LER). Our
normal practice to carbon copy the NRC Regional Office was not followed due to
administrative oversight. However, the NRC Senior Resident Inspector was, in
accordance with normal practices, copied via FPC's internal distribution.
If fire damaged the systems providing the bearing flush water supply to the plant
during normal power operation, the turbine driven emergency feedwater pump would
have remained available to remove residual heat. To continue to cool down, or
for fire damage occurring at cold shutdown, one train of decay heat removal
equipment including one of the decay heat seawater pumps will remain operable.
If fire damages all sources of bearing flush water (redundant A and B domestic
water pumps plus Nuclear Service closed cycle cooling water supplied through
redundant motor operated valves) only one operating decay heat seawater pump
would be damaged. The non-operating decay heat seawater pump would not be
affected. The non-operating pump would only autostart on an ES signal and
therefore would remain unaffected, since other plant accidents need not be
considered concurrent with a fire (See Branch Technical Position APCSB 9.5-1
l AppendixA,ItemA-4).
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The loss of bearing flush water supplies could disable both Nuclear Service
seawater systems and eliminate the Nuclear Services closed cycle cooling water
heat sink. However, the Nuclear Services closed cycle cooling pumps would remain
operable for the purpose of supplying bearing flush water for the decay heat
r seawater pumps through either of the two redundant motor operated valves. Manual
l action may be required to open one of the motor operated flush water supply
valves depending on specific fire damage. Sufficient time for manual action
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would be available before the decay heat system was required, and access to the
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area following a fire would not be a problem since the duration of an
unsuppressed fire from the combustion of all material in the area has been
conservatively evaluated to be approximately 12 minutes. This fire duration
estimate takes no credit for sprinklers or fire barriers around cable trays that
now exist in this area.
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Enclosure 4
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The Inspection Report fails to note that this entire area would not meet literal
Appendix R requirements and thus a Technical Exemption for this fire area was
sought and granted. The primary technical basis for this exemption is detection,
suppression, amount of combustible materials, and room geometry (high ceiling
with hot gas traps inherently present). These continued to exist and supported a
reduced level of concern with regard to the identified error. FPC continues to
maintain that this design error did not create a reportable condition under
NRC Evaluation
The licensee stated, that the design problem, of failure to protect the bearing
flush water supply to the Nuclear Services Seawater Pumps (RWP) and the Decay
Heat Seawater Pumps (DCP) wcid not alone have prevented the function of systems
required to remove residual heat. On December 19, 1985, in a letter to the
Licensing Project Manager (LPM), NRR, the licensee provided their fire protection
evaluation of the Domestic Water Supply to Nuclear Services Seawater Pumps and
decay heat seawater pumps bearings. In this evaluation FPC identified that the
RWPs are considered hot shutdown equipment and the DCPs are considered cold
snutdown equipment. The licensee's evaluation states that, "... without either A
or B domestic water pump, or without opening of either redundant back-up supply
valve from the Nuclear Service Closed Cycle Cooling Water System, the seawater
pumps would fail."
The staff's review of the MAR Package included review of the licensee's
Nonconformance Operations Report (NCOR), No.85-209. This NCOR also identified
the cause of the event as a design error in that the analysis of the domestic
water supply was not included in the Appendix R design. The evaluation and NCOR
clearly identify this condition was a result of design and analysis inadequacies
of the original Fire Hazards Analysis in that none of the redundant bearing
Flushwater Systems for the safe shutdown equipment were analyzed for the effect
of fire within fire area AB-95-3T.
10 CFR 50.73(a)(2)(vi) states that events covered in paragraph (a)(2)(v) of this
section may include discovery of design and analysis inadequacies.
As stated in the violation 10 CFR 50.73(a)(2)(v)(B) the licensee shall submit a
LER for any event of the type in this paragraph.
It appears that the NCOR, however, in Parts 2, 3, and 4 does not indicate any
reference to a review of this event against the reporting requirements of 10 CFR
50.73. The licensee's response appears to justify their action of voluntarily
submitting their evaluation information to the NRC/NRR office on December 19,
1985, in lieu of a LER as a means suggested by Generic Letter (GL) 86-10. This
item was addressed by paragraph "C" of the GL as related to Fire Area Boundaries.
Also in the Generic Letter, paragraph E, the licensees are reminded of their
obligation to notify the NRC of Fire Protection deficiencies which meet the
criteria of 10 CFR 50.72 or 10 CFR 50.73. In fact, several comments within the
evaluation columns of Part 2 and 3 of Enclosure 1 to Procedure CP-111, Rev. 32,
indicate that the event was considered significant, but further guidance was
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required to determine the-safety significance, yet the event was not identified
as reportable.
Paragraph 2 and '3 of the licensee's response appear to discuss the plant's
operational and-technical aspects of its non-compliance with the requirement of
Appendix R and FPC's evaluations to justify the corrective actions taken. These
aspects discussed, however, are not gemain to the issue of the reportability of
a design and Fire Hazards Analysis . inadequacy as described in the proceeding
paragraphs. Also, the licensee stated that the Ins
that a Technical Exemption for Fire Area (AB-95-32)pection
was sought Report failedThe
and granted. to note
licensee should be reminded that this Technical Exemption applied specifically to -
the separations-of the RWP and SWP where the protection of redundant pump power
circuits in one hour fire enclosure / wraps was provided. At the time of the
inspection, this ~ same level of fire protection was not provided for the circuits
of the domestic water pumps (D0P-2A, 2B) or the redundant Motor Operated Valves
(D0V-210,238) which are located within the same fire zone, AB-95-3T.
NRC Conclusion
Based upon the NRC staff's review as outlined above, we conclude that FPC's
discovery of the _ design and analysis inadequacies in the plant Fire Hazards
Analysis as related to loss of the bearing flush water supplies to safe shutdown
equipment did in fact constitute an event as defined by 10 CFR 50.73(a)(2)(vi)
and that these deficiencies were not properly reported in accordance with the
requirements of 10 CFR 50.73(a)(2)(v)(B). For the above reasons, the violation
occurred as stated.
Restatement of Deviation (86-12-05)
In a letter to the Nuclear Regulatory Commission from Florida Power Corporation
dated December 19, 1985, the licensee identified a design error that could result
in a loss of the Nuclear Services Seawater and the Decay Heat Seawater pumps in
the event of a fire. In the corrective actions for this design error, the
licensee committed to continue 20-minute roving fire watches until such time that
plant modifications to prevent this loss of pumps were completed.
Contrary to the above, at 2:00 p.m., on March 14, 1986, the roving fire watch was
secured even though the plant modification for these pumps was not completed.
Summary of Licensee's Response
FPC disagrees with this deviation. FPC maintained a level of protection for the
functions at risk that was appropriate to the hazard that existed. This
protection included periodic surveillance by roving security officers and plant
operators. Their normal duties include observation of abnomal conditions,
including fire, and response to those conditions. The FPC letter of December 19,
1985, referenced in the Notice of Deviation, was a fire protection evaluation
-forwarded under the guidance of draft Generic Letter 85-01 as reaffirmed by
Generic Letter 86-10. FPC chose this approach in a proactive effort to keep the
.NRC staff aware of our fire protection activities. The alternate approach
offered by draft Generic Letter 85-01 was simply retaining this evaluation in our
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Enclosure- 6
files available for review. Since the second alternative existed FPC felt
justified in adjusting our compensation to the hazard at the time.
FPC's letter noted the 20-minute roving fire watch was in place at that time. In
addition, it stated " Roving fire watches will continue in.the areas containing
components necessary for maintenance of the current bearing flush water supply l
until modifications are complete." This commitment does not state the 20-minute l
frequency would be maintained without regard to plant status- '
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At the time the evaluation was written, Crystal River Unit-3 (CR-3) was in power
operations and 20-minute roving fire watches were being used as compensation in l
the auxiliary building for uncompleted fire barrier construction around cable
trays and conduits. At the time of the alleged deviation CR-3 had been shutdown
for approximately two and one half months and all cable and conduit fire barrier
construction had been completed. FPC believes the fire protection provided in
the area, which included operable automatic sprinklers, operable automatic fire
detection, and roving patrols by security and operations personnel, was adequate
for the hazard.
Prior to discontinuing the 20-minute roving fire watches -which had been
established as part of Appendix R Schedular Exemption, FPC Licensing contacted
both the NRR Fire Protection Reviewer and the NRC Senior Resident Inspector for
CR-3. FPC contacted the NRR Fire Protection Reviewer regarding the Appendix R
requirements when the plant is in cold shutdown. Based on discussion regarding
the fact that Appendix R requirements are not clearly defined when the plant is
in cold shutdown, FPC was justified in modifying the protection to more closely
match the hazard. On March 13, 1986, one day prior to discontinuing the fire
watches, FPC Licensing informed the Senior Resident Inspector for CR-3 that the
20-minute roving fire watches were being discontinued. FPC informed the Senior
Resident this was because the schedular exemption modifications were complete and
because we were not aware of any specific Appendix R guidelines applicable to
cold shutdown. The Senior Resident was also informed the seawater pumps bearing
flush water modification was not complete. There was no discussion with the
Senior Resident Inspector specifically addressing the commitments in FPC's
- December 19 letter, but there was no objection voiced to the discontinuance of
the 20-minute roving fire watches.
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It is FPC's position that sound fire protection was maintained for the seawater
pumps, that our actions were taken after careful consideration of the guidance
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that exists, and after consultation with NRC staff. Based on the foregoing, FPC
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requests this Deviation be withdrawn.
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j NRC Evaluation
In a letter to the NRC licensing project manager (LPM) from Florida Power
Corporation dated December 19, 1985, the licensee identified an inadequacy of
their Fire Hazards Analysis of failure to identify and to protect the bearing
flush water supply to the Nuclear Services Seawater and Decay Heat Seawater pumps
which are considered hot shutdown and cold shutdown equipment, respectively. In
the corrective actions, FPC in lieu of providing fire protection features in
accordance with Appendix R,Section III.G.2.a, b or c, elected to perform a plant
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Enclosure 7
modification which would provide bearing flush water to both the Nuclear Services
and Decay Heat Seawater pumps from the pumpage of the seawater pumps themselves.
FPC in their December 19, 1985 letter indicated that these modifications would be
completed by March 31, 1986, and that the compensatory 20 minute roving fire
watches, which were required and approved by the NRC in order to provide FPC
scheduled relief to complete Appendix R modifications, would be continued in the
areas containing components necessary for maintenance of the current bearing
flush water supply until the flush water modifications were complete.
Based on NRC Region II's review of FPC's December 19, 1985 submittal, the region
concluded no additional compensatory measures were required of FPC and that the
existing 20 minute roving fire watches would provide sufficient assurance that,
during all modes of plant operation, a fire would be detected and suppressed
prior to causing fire damage to redundant seawater pump bearing flush water
systems.
Although, the Senior Resident Inspector was notified that the 20-minute roving
fire watches were being discontinued, he was not informed that this action was
being taken contrary to the commitments made in the December 19, 1985 letter. In
addition, it is our policy that relief from commitments made to the NRC cannot be
verbally granted by the Senior Resident Inspector. It is the licensee's
l responsibility to comply with all commitments made unless granted relief through
proper channels.
NRC Conclusion
For the reasons stated above, we conclude that on March 14, 1986, FPC deviated
from their December 19, 1985 fire watch commitments.
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