3F0897-15, Provides Response to Violations Noted in Insp Rept 50-302/97-09.Corrective Actions:Mod Approval Record MAR 97-08-01-01 Will Be Implemented by 971130 to Modify Each EDG Automatic Protection Scheme

Provides Response to Violations Noted in Insp Rept 50-302/97-09.Corrective Actions:Mod Approval Record MAR 97-08-01-01 Will Be Implemented by 971130 to Modify Each EDG Automatic Protection Scheme

ML20210K616
Person / Time
Site:	Crystal River
Issue date:	08/11/1997
From:	Cowan J FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
3F0897-15, 3F897-15, 50-302-97-09, 50-302-97-9, NUDOCS 9708190333
Download: ML20210K616 (6)

Text

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• E Florida Power e3 Ducket No. 60 302 August 11, 1997 l

3F089715 U.S. Nuclear Regulatory Commission

. Attn: Document Control Desk l Washington, D.C. 20555-0001 l

l

Subject:

Response to Apparent Violations in NRC Inspection Report No.

50-302/97 09, NRC to FPC letter,3N079711, dated July 14,1997 Gentlemen:

In the subject letter, Florida Power Corporation (FPC) received two apparent violations. On July 18,1997, FPC notified the NRC that a predecisional enforcement conference would not be requested and that a response to the apparent violations-would be forthcoming. This correspondence provides the FPC response to the epparent violations.

Sincerely, b &

John Paul Cowan Vice President 7

Nuclear Production JPC/dwh (, j Attachments xc: Regional Administrator, Region 11 Senior Resident inspector NRR Project Manager 9708190333 970811 Illl!DIWlllllllIllllll\,tl,ll\

PDR ADOCK 05000302 G PDR

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O U. S. Nucle:r Regulatory Commission 3F089715 Page 2 of 6 STATE OF FLORIDA COUNTY OF CITRUS -

John Paul Cowan states that he is the Vice President, Nuclear Production for Florida Power

! Corporation; that he is authorized on the part of said company to sign and file with the Nuclear L Regulatory Commission the information attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, information, and belief.

l

$ 0J%

John Paul Cowan

- Vice President Nuclear Production Sworn to and subscribed before me this // -

day of N 8']&J/ 1997, by John Peil Cowan.

U$A ANN MCBRIDE Signature o[ Notary Public State of Florida l l "['

ucm Yip 5 m Comm. No. CC 505458 L ls Ar M.o m s u tsc (Print, type, or stamp Commissioned Name of Notary Public)

Personally Produced Known y -OR -

Identification N

.i

c U. S. Nucle:r Regul: tory Comrusion 3F089715 Page 3 of 6 ATTACHMENT 1 FLORIDA POWER CORPORATION NRC INSPECTION REPORT NO. 50 302/97-09 REPLY TO APPARENT VIOLATIONS AEEARENLVlOLATION eel 50 302L9109:01 An apparent violation (eel 50 302/97 09-01) was identified for an inadequate safety evaluation for a modification that was performed in 1987. The modification added five protective trips to l each emergency diesel generator (EDG) control circuu, for protection from bus faults and i prolonged overcurrent conditions. The added EDG trips were not bypassed during emergency .

l operation and were not installed with two out of three coincidence logic. Thus a single failure in the added circuitry could cause an EDG to fall inappropriately. The modification increased the probability of failure of the EDGs and created an unreviewed safety question (USQ). The safety evaluation for the modification failed to recognize the USQ and the modification was performed without obtaining the required prior NRC review and approval.

ADMLSSION OR DENIAL OF.THE APPARENT VIQLATION Florida Power Corporation accepts the apparent violation.

REASON FOR THE APPARENT VIOLAYlON The reason for the failure to identify an unreviewed safety question (USO) for the modification implemented in 1987 was lack of a formal 10CFR50.59 training and qualification program for personnel involved with the 10CFR50.59 process. Modification Approval Record (MAR) 80-09 13-01 added relays to the protection circuitry for the Emergency Diesel Generators (EDGs). l The associated 10CFR50.59 evaluation concluded that no unreviewed safety question (USQ) existed.- Additions to the EDG protection circuitry did increase the probability of EDG failure.

However, the increase was determined to have been offset by the increase in safety gained by preventing the EDGs from connecting to a faulted bus.

CORRECTIVE STEPS THAT WILL BE TAKEN.AND THE RESULTS ACHIEVEQ Modification Approval Record MAR 97-08-01-01 will be implemented by November 30,1997, to modify each EDG automatic protection scheme. This modification is expected to involve an unreviewed safety question. Only the generator differential over-current protective relaying, engine overspeed switch, and low-lube oil pressure switches (2 out of 3 matrix) will be able to trip the EDG output breaker and shut down the diesel generator unit during an accident condition. The balance of the protective relaying (original and protective relaying added in 1987) will trip the diesel generator output breaker only. This protection scheme will allow the diesel generator to start and operate in the stand-by condition for any protective actuation except the generator differential over-current relaying, engine overspeed, or low-lube oil pressure. The protective relaying which affects the diesel generator breaker will be single

U. S. Nucle:r Regul; tory C,ommission 3F0897-15 Page 4 of 6 channel trip and will not be bypassed during an accident condition. This approach is consistent with the CR 3 original design philosophy and is also consistent with current industry practice.

A license amendment will be submitted by September 30, 1997, requesting NRC review and approval of the proposed modification to the EDG protective circuitry.

QQRRECTIVE STEPS THAT HAVE BEEN TAKEN TO AY_QJD FURTHER VIOLATIONS The 10CFR50.59 process was upgraded on March 31,1997, when Compliance Procedure CP-213, " Preparation of Safety Assessment and Unreviewed Safety Question Determination,"

Revision 0, became effective. CP 213 established a stand alone safety evaluation format that l

requires an integrated analysis of the proposed change and its effects. CP-213 requires that personnel receive initial training and subsequent biennial retraining in order to be considered

. qualified to prepare and review safety assessments and make unreviewed safety question determinations. CP-213 initial training of over 180 staff personnel was completed in June 1997.

l l

FPC previously established the Safety Analysis Group (SAG) which is currently staffed with FPC engineering and contractor personnel knowledgeable in design basis accident analyses.

SAG is tasked with reviewing and approving 10CFR50.59 evaluations.

DAIE_WHEN FULL COMPLIANCE WILLBEACHIEY.ED Florida Power Corporation is in full compliance.

l APPARENT VIOLATION eel- 50 392/97-09 02 A second apparent violation (eel 50-302/97-09-02) was identified for failure to update the FSAR to describe the added EDG protective trips. This apparent violation and another recent example of failure to update the FSAR, for a 1996 revised small break loss of coolant accident mitigation strategy (see EA 97-162 and Inspection Report 50-302/97-06), indicate a weakness in control of the design bases.

ADMIS$1QN OR DEMIAL OF THE APPARENT VIOLATIOR Florida Power Corporation accepts the apparent violation.

REASON FOR THE APPARENT VIOLATION The reason for the apparent violation is the same as stated for eel 50 302/97 09-01. The initial determination for identifying the need to make a process-driven FSAR change was and is currently accomplished through implementation of the 10CFR50.59 program. The program in effect in 1987 did not provide for training and qualification of personnel involved with the

• 10CFR50.59 process. Personnel performing 10CFR50.59 evaluations were not provided with sufficient guidance to determine the need for making FSAR changes when the modification affected the FSAR beyond the level of detailincluded in the FSAR.

0 U. S. Nucle:r Regulatory Commission 3F0897-15 Page 5 of 6 Modification Approva! Record (MAR) 80-0913-01 added relays to the protection circuitry for the EDGs, The MAR 10CFR50.59 evaluation form was marked *NO' for changes required to the Final Safety Analysis Report (FSAR). The decision not to update the FSAR was base on the 1987 FSAR not including a description of EDG protective relays.

CORRECTIVE STEPS THAT HAVE BEEN OR WILL BE TAKEN AND THE RESULTS JLCBIEV.ED As stated in response to eel 50 302/97-09-01 above, the EDG protection circuitry modification installed in 1987 will be modified to permit the EDGs to start and attain rated speed and voltage j- but will prevent the EDG output breaker from closing if a faulted bus condition exists. The l current 10CFR50.59 process must be applied. This process ensures that FSAR changes, if necessary, are identified and processed.

The FPC FSAR Operational Review Program was completed on February 28,1997, and identified discrepancies between the FSAR and operational documents. The Configuration Document Integration Project (CDIP) was subsequently developed as an expansion of the FSAR Operational Review Program to integrate the resolution of identified discrepancies with the extent of condition reviews being done in the present outage, in conjunction with the System Readiness Reviews, the CDIP is integrating the significant changes to the facility and the resolution of the findings from both the FSAR Operation Reviews and the System Readiness Reviews into the main configuration control documents, which includes the FSAR.

C_QRRECTIVE STEPS THAT HAVE BEEN OR WILL BE TAKEN TO AVOID FURTHER V101AllDRS The 10CFR50.59 process was upgraded on March 31, 1997, when CP-213, Revision 0, became effective. CP-213 established a stand-alone safety evaluation format that requires an integrated analysis of the proposed change and its effects. CP 213 endorses the philosophy that changes beyond the level of detail contained in the FSAR may require an FSAR revision.

CP 213 requires that personnel receive initial training and subsequent biennial retraining in order to be considered qualified to prepare and review safety assessments and make unreviewed safety question determinations. CP 213 initial training of over 180 staff personnel was completed in June 1997.

By letter dated April 25,1997, FPC docketed Revision 2 to the Management Corrective Action Plan (MCAP _ll). In MCAP 11, Item D-RC1-6, FPC committed, in part, to benchmark the regulatory process for updating the FSAR against SALP 1 plants and revise the process as necessary. This action is scheduled to be completed by January 31,1998.

DATE WHEN FULL COMPLIANC.EMILL BE ACHIEVED Florida Power Corporation is in full compliance.

U. S. Nucle:r Regulat:ry Commission 3F089715 Page 6 of 6 ATTACMAENT 2 'l The following table contains a listing of commitments contained in FPC's response:

RESPONSE COMMITMENT DUE DATE SECTION  !

Page 3 Modification Approval Record MAR 97-08-01 01 will be November 30,1997 Implemented by November 30,'1997, contingent upon 1 NRC review and approval of the proposed design, to i modify each EDG automatic protection scheme. Only the generator differential over-current protective relaying, engine overspeed switch, and low lube oil pressure switches (2 out of 3 matrix) will be able to trip the EDG output breaker and shut down the diesel generator unit during an accident condition. The balance of the protective relaying (original and protective relaying added in 1987) will trip the diet.el generator output breaker only. This protection scheme will allow the diesel generator to start and operate in the stend by condition for any protective actuation except the generator differential over-current relaying, engine overspeed, or low-lube oil pressure. The protective relaying which affects the diesel generator breaker will be single channel trip and will not be bypassed during an accident condition.

Page 4 A license amendment will be submitted by September 30, September 30,1997 1997, requesting NRC review and approval of the proposed modification to the EDG protective circuitry.

Page 5 By letter dated April 25,1997, FPC docketed Revision 2 January 31,1998 to the Management Corrective Action Plan (MCAP 11).

In MCAP 11 Item D-RC1-6, FPC committed, in part, to benchmark the regulatory process for updating the FSAR against SALP 1 plants and revise the process as necessary.}