View source for 3F1297-20, Forwards Response to Violations Noted in Insp Rept 50-302/97-16.Corrective Actions:Liquid & Gas Outlet Piping for Waste Gas Decay Tanks Will Be Upgraded to Seismic Class 1 Prior to Entering Mode 2

{{Adams
| number = ML20197A924
| issue date = 12/17/1997
| title = Forwards Response to Violations Noted in Insp Rept 50-302/97-16.Corrective Actions:Liquid & Gas Outlet Piping for Waste Gas Decay Tanks Will Be Upgraded to Seismic Class 1 Prior to Entering Mode 2
| author name = Holden J
| author affiliation = FLORIDA POWER CORP.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000302
| license number = 
| contact person = 
| document report number = 3F1297-20, 50-302-97-16, NUDOCS 9712230246
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 8
}}

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* l Florida Power
                =L December 17,1997 3F1 !97 20 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 0001

==Subject:==
Reply to Notices of Violation, NRC Inspection Report No. 50 302/97-16, NRC to FPC lettor, 3N1197 21, dated November 24,1997

==Dear Sir:==

In the subject letter, Florida Power Corporation (FPC) received Notices of Violation.
This correspondence provides our response to those violations.
Sincerely, e W
                                     . J. Holden Director Site Nuclear Operations JJH/dwh Attachments                                                                                      s I'               g xc:     Regional Administrator, Region 11 Senior Resident inspector NRR Project Manager                    ,
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      * , U.S' '. Nuclear Regulatory C mmission 3F1297-20 Page 2 of 8 ATTACHMENT 1 FLORIDA POWER CORPORATION NRC INSPECTION REPORT NO. 50 302/9716 REPLY TO NOTICES OF VIOLATION VIOLATlON 50-302/97-16-03 10 CFR 50, Appendix B, Criterion Ill, requires, in part, that applicable regulatory requirements and the design basis, as specified in the license application, for those structures, systems, and components to which Appendix B applies, are correctly translated into specifications, drawings, procedures, and instructiont..
(1)       The seismic design basis description in the Final Safety Analysis Report (FSAR)
Section 5.1.1.1 states, in part, that those structures, components, and systems, whose failure might cause or result in an uncontrolled release of radioactivity are dnsignated Seismic Class 1. This FSAR section required that the waste gas decay tanks (WGDT) and the associated gas outlet piping be designed Seismic Class 1. The licensee's Enhanced Design Basis Document (EDBD) also stated that the WGDTs and the associated gas outlet piping were designed Seismic Class 1.
Contrary to the above, as of October 24,1997, the design basis requirements for the WGDT gas outlet piping were not correctly translated into licensee design drawings, in that, design drawing FD-302-691 showed the WGDT gas outlet piping as being designed Seismic Class 111 instead of Seismic Class I, and the gas outlet piping for the WGDTs was installed Seismic Class Ill. The design drawings and the installed gas outlet piping have never matched the FSAR seismic design basis description.
(2)       The seismic design basis description in FSAR Section 5.1.1.1 states, in part, that those structures, components, and systems, whose failure might cause or result in an uncontrolled release of radioactivity, were designated Seismic Class 1. FSAR Section 5.1.1.1.i further stated ' hat the liquid outlet piping for 14 radioactive waste disposal system (WDS) tanks (to and including the second isolation valve downstream from each of the tanks and the process piping associated with the reactor coolant drain tank) was designated Seismic Class I. The EDBD also described the liquid outlet piping as being Seismic Class I.
Contrary to the above, as of October 24,1997, design basis requirements for the WDS liquid outlet piping was not correctly translated into licensee design drawings, in that, drawings FD-302-681 and FD-302-691 showed the WDS liquid outlet piping as being designed Seismic Class lil instead of Seismic Class I and the liquid outlet piping for six of fourteen WDS tanks was installed Seismic Class 111. The six tanks with Seismic Class 111 liquid outlet piping installed were the miscellaneous waste storage tank, reactor coolant drain tank, three (3) waste gas decay tanks, and the spent resin storage tank. The design drawings and the installed WDS liquid outlet piping hcve never matched the FSAR seismic design basis description.

F.
U. Si. Nuclear Regulatory Commission
   * ,3F1297 20 Page 3 of 8 ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Florida Power Corpuration accepts the violation.                                         .
REASON FOR THE VIOLATION The reason for the violation was engineering oversight during construction of Crystal River Unit 3 (CR 3). The seismic classification of the subject Wasta Disposal System (WDS) piping has not changed from the original design. Engineers responsible for the initial design and installation of the WDS failed to recognize that the design drawings conflicted with the Final Safety Analysis Report (FSAR).
CORRECTIVE STEPS THAT HAVE BEEN OR WILL BE TAKEN AND THE RESULTS ACHIEVE _ D The subject WDS seismic classification discrepancies were identified through a System Readiness Review performed on the WDS. No further review of the WDS for seismic classification deficiencies is necessary.
The liquid and gas outlet piping for the Waste Gas Decay Tanks (WGDTs) will be upgraded to Seismic Class I prior to entering MODE 2.
The liquid outlet piping for the Miscellaneous Waste Storage Tank and Spent Resin Storage Tank will be upgraded to Seismic Class I prior to restart from the next scheduled refueling outage (R11).
A Justification for Continued Operation (JCO) for other WD System tank liquid outlet piping (excluding the Reactor Coolant Drain Tank (RCDT)) has been developed, consistent with the guidelines contained in Generic Letter 91-18, Revision 1.
The RCDT liquid outlet piping has been evaluated in accordance with 10CFR50.59 for a change to the FSAR. The evaluation concluded no unreviewed safety question existed with respect to changing the FSAR seismic classification of the affected piping from Class I to Class 111.
CORRECTIVE STEPS THAT HAVE BEEN TAKEN TO AVOID FURTHER VIOLATIONS The deficiencies occurred during the construction of CR 3. The current process for modifying CR-3 would prevent implementation of changes without determining whether the change was creating a conflict with the FSAR. This process is described in Compliance Procedure CP-213,    ;
Preparation of a Safety Assessment and Unreviewed Safety Question Determination
[SA/USQD) (10CFR50.59 Safety Evaluation), and Nuclear Engineering Procedure NEP-210, Modification Approval Records. NEP-210 requires the performance of a SA/USQD per CP-213. Additionally, the conceptual design review process for modification approval records at     l FPC, as described in NEP-202, Preparation and Processing of Conceptual Designs and              4 Design Walkdowns, requires a preliminary safety assessment to be performed to identify          l potential changes to the FSAR.

    , U. S. Nuclear Regulatory Commission 3F1297-20 Page 4 of 8 DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED FPC will achieve full compliance prior to restart from the end of the next scheduled refueling outage (R11).
VIOLATION 50-302/9716-04 Technical Specification 5.6.1.1 requires that written procedures shall be established, implemented, and maintained covering the applicable activities recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Appendix A, paragraph 1.d, includes administrative procedures for procedural adherence.
Licensee Compliance Procedure CP-111, Processing of Precursor Cards for Corrective Action Program, Revision 56, dated February 25,1997, stated that a 10 CFR 50.59 safety evaluation was required when a non-confo' ming condition conflicted with the Final Safety Analysis Report (FSAR) description and the condition was not corrected for an extended period of time (greater than 90 days). Precursor card (PC) 971515 was written March 17,1997, descr;bing piping in the radioactive waste disposal systein (WDS) which conflicted with the FSAR seismic design basis description.
Contrary to the above, as of October 24,1997, a 10 CFR 50.59 safety evaluation had not been performed as required within 90 days on the WDS piping non-conformin0 condition.
Over 200 days had passed since PC 97-1515 was written.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Florida Power Corporation accepts the violation.
REASON FOR THE VIOLATION The reason for the violation was personnel error. The design engineering individual and supervisor responsible for resolving Precursor Card (PC) 97-1515 failed to fo!!ow the requirements of CP-111, Revision 56, due to a misunderstanding of the procedural requirements.
CORRECTIVE STEPS THAT HAVE BEEN OR WILL BE TAKEN AND THE RESULTS ACHIEVED The d9 sign engineering individual and supervisor responsible for resolving PC 97-1515 have been counsoled on meeting the requirements of CP-111. Specifically, the requirement to perform a SA/USQD for FSAR discrepancies that will not be corrected within 90 days has been re-emphasized.
Three (3) USQDs have been completed for PC 971515: (1) JCO for the WGDT liquid and gas outlet piping, (2) JCO for other WD System tank liquid outlet piping (excluding the RCDT), and (3) FSAR change to reflect the RCDT liquid outlet piping as Seismic Class 111.                 )

       , U. . Nuclxr Regul; tory Commission 3F1297-20 ~
Page 5 of 8 FPC will perform an extent of condition review of open Precursor Cards initiated prior to October 1,1997, The review will determine whether the failure to identify nonconforming conditions requiring performance of a SA/USOD was widespread or an isolated case. This action will be completed by January 31,1998.
_CQRRECTIVE STEPS THAT HAVE BEEN TAKEN TO AVOID FURTHER VIOLATIONS CP 111, Revision 60, became effective October 1,1997, and estaulished Enclosure 5, Deficiency Report [DR] Instructions. CP-111, Revision 61, became effective November 21, 1997, and incorporated guidance contained in Generic Letter 91-18, Revision 1, Information to Licensees Regarding NRC Inspection Manual Section on Resolution of Degraded and Nonconforming Conditions. DRs are initiated when a nonconforming item requires a use-as-is, interim use-as-is, or repair disposition or when the nonconforming item is Code Class 1, 2, or
: 3. DRs must be completed within 90 days and require performance of a SA/USQD. These enhanced procedural requirements will ensure nonconforming conditions in conflict with the FSAR receive a SA/USOD if not corrected within 90 days.
DATE WHEN FUL L COMPLIANCE WILL BE ACHIEVED FPC will achieve full compliance by January 31,1998.
VIOLATION 50 302/97-16-05 Technical Specification (TS) 5.6.2.3, Offsite Dose Calculation Manual (ODCM) states, in part, that the ODCM shall contain the controls for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable. Those controls include monitoring, sampling, and analysis of radioactive liquid and gaseous effluents.
TS 5.6.2.3 further states that licensee initiated changes to the ODCM shall be documen'ed and records of reviews performed shall be retained. This documentation shall contain sufficient _ information to. support the change, together with the appropriate analyses or evaluations justifying the changes.
.         ODCM surveillance requirement 2.17.1 states that the quantity of radioactive material in each waste gas decay tank (WGDT) thall be determined to be within the limit (less than or equal 39,000 curies, considered as Xenon 133) at least once per 7 days whenever radioactive materials are being added to the tank, and a least once per 24 hours during primary coolant system degassing operations. The NRC stated in its review of this surveillance requirement (NRC Safety Evaluation Report (SER) dated June 27, 1984, and referenced Technical
         - Evaluation Report EGG-PHYS-6171), that this surveillance was acceptable since the WGDT was sampled at the frequency required during degassing.
Contrary to the above, as of October 24,1997, the licensee was not complying with TS 5.6.2.3 for the following instances:
4 l

ju, $; Nuclear Regulatory Commission 3F1297 20 Page 6 of 8 t
The quantity of radioactive material in each WGDT was-not being determined as-specified by ODCM surveillance requirement 2.17.1. Per licensee surveillance procedure SP-730, Explosive Gas and Storage Tank Monitoring Chemistry Surveillance Program, the licensee was sampling the makeup tank (MUT) instead of the WGDT in oroer to satisfy the ODCM surveillance requirement for determining ;he radioactivity in each WGDT.
Tee licensee had not performed a 10 CFR 50.59 safety evaluation to support the r.nange for sampling the MUT instead of the WGDT as the method for determining the radioactivity in each WGDT.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Florida Power Corporation accepts the violation.
HEASON FOR THE VIOLATION The reason for the violation was personnel error. FPC personnel reviewing the NRC SER for the Radiological Effluent Technical Specifications (RETS) failed to recognize and resolve the deficiency between the SER terminology and methodology employed by SP-730. As a consequence, FPC personnel failed to recognize the need to perform a 10CFR50.59 evaluation to support sampling the MUT instead of each WGDT.
Sampling the MUT had been considered an acceptable method of ensuring the quantity of radioactive material in each WGDT did not exceed a predetermined value sinca September 24,
         '1981, when SP-732, Revision 0, Gaseous Radwaste Weekly Surveillance Program, was issued. This method of determining the quantity of radioactive materialin the WGDTs had not changed since 1981.
CORRECTIVE STEPS THAT HAVE BEEN OR WILL BE TAKEN AND THE RFSULTS ACHIEVED Chemistry Department personnel have been made aware of the subject violation.
The ODCM has been revised to albw use of an indirect method for determining the quantity of radioactive materialin each WGDT. Also, a USQD is being performed to support sampling the MUT instead of each WGDT, A letter will be submitted to the NRC by January 31,1998,' clarifying FPC's implementation of the NRC SER Technical Evaluation Report statement related to sampling each WGDT.
        . CORRECTIVE STEPS THAT HAVE BEEN TAKEN TO AVOID FURTHER VIOLATIONS
         ;On August 6,1997, Compliance Procedure CP-215, Revision 0, Preparation of an Operating
        ; License Amendment, became effective. Section 4.1.9 requires the lead licensing engineer, with input _ from the responsible department contacts, to prepare an improved Technical
        . Specification / License Amendment implemt          ?n Actions Form. Section 4.4 requires the assigned lead licensing engineer to revie     ., . .oved license amendments and the SER for I

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                     .,U. $i. Nuclear Regulatory Commlision
                  - 3F1297 20 -
                      ; Page 7 of 8 '
commitments and deviations from the license amendment request. Instructions are'provided for addressing _ deviations. These administrative controls provide a process for ensuring SER .
                     - requirements are met.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED FPC will achieve full compliance by January 31,1998.
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U. S: Nucle:r R:gul: tory Commission .
     * ,3F1297-20
      ' Page 8 of 8 ATTACHMENT 2
        - The following table contains a listing of commitments contained in this response:
Section                           Commitment                                 Due Date Page 3      The liquid and gas outlet piping for the WGDTs will be    Prior    to    entering upgraded to Seismic Class I prior to entering MODE 2. MODE 2 Page 3      The liquid outlet piping for the Miscellaneous Waste      Prior - to restart from Storage Tank and Spent Resin Storage Tank will be         the next scheduled upgraded to Seismic Class l prior to restart from the     refueling outage (R11) next scheduled refueling outage (R11).
Page 4      FPC will perform an extent of condition review of open January 31,1998 Precursor Cards initiated pnor to October 1,1997.
The review will determine whether the failure to identify nonconforming conditions requiring performance of a SA/USQD was widespread or an isolated case. This action will be completed by January 31,1998.
Page 6      A letter will be submitted to the NRC by January 31,      January 31,1998 1998, clarifying FPC's implementation of the NRC SER Technical Evalcation Report statement related to sampling each WGDT.
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