ML20134J706

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Forwards Insp Rept 50-302/96-12 on 960826-1011.Violations Noted Being Considered for Escalated Enforcement Action
ML20134J706
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 11/04/1996
From: Gibson A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Beard P
FLORIDA POWER CORP.
Shared Package
ML20134J709 List:
References
NUDOCS 9611180002
Download: ML20134J706 (4)


See also: IR 05000302/1996012

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November 4. 1996

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EA 96-365

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Florida Power Corporation

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Crystal River Energy Complex

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Mr. P. M. Beard Jr. (SA2A)

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Sr. VP Nuclear Operations

ATTN:

Mgr.. Nuclear Licensing

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15760 West Power Line Street

Crystal River. FL 34428-6708

SUBJECT:

NRC INSPECTION REPORT NO. 50-302/96-12

1

Dear Mr. Beard:

,

This refers to the inspection conducted on August 26 through October 11. 1996.

-at the Crystal River facility. The purpose of the ins)ection was to review

the Emergency Diesel Generator (EDG) loading issues. w1ich resulted from the

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Emergency Feedwater System modification performed at your facility during the

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recent refueling outage in April - May 1996, and also to review the root

causes of these issues. The enclosed report presents the results of this

-inspection.

1

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Based on the results of this inspection. three apparent violations were

identified and are being considered for escalated enforcement action in

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accordance with the " General Statement of Policy and Procedures for NRC

Enforcement Actions" (Enforcement Policy). NUREG-1600.

The first a) parent violation involves three instances where Unreviewed Safety

Questions (JSQs) related to increased EDG loading were introduced by an April

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1996 plant modification, a May 1996 emergency operating procedure revision,

and a June 1990 plant operating procedure revision.

In each of these

instances, the US0s were not recognized by the 10 CFR 50.59 safety evaluations

that were_ performed prior to making the changes

Consequently, your failure

to obtain the required NRC review and approval prior to making the changes

constitutes an apparent violation of 10 CFR 50.59.

The second apparent violation involves two examples of inadequate corrective

actions related to the April 1996 plant modification.

Your corrective action

for a similar problem in June 1994 failed to prevent.the April 1996 inadequate

10 CFR 50.59 safety evaluation, and your corrective action implemented after

this issue was . identified and documented by members of your staff in a May

1996 Precursor Card was not adequate.

The third apparent violation involves an engineering procedure that improperly

allowed an unverified April 1996 EDG loading calculation to be used to support

the above. referenced April 1996 plant modification.

When you later undertook

appropriate verification and review of EDG loading in October 1996. you

identified a nonconservative error that was in the unverified April 1996 EDG

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loading calculation.

The engineering procedure also impro)erly permitted the

general use of unverified electrical system calculations

lydraulic system

calculations, and station blackout calculations to support the design.

1, _ s , installation, and use of p] ant modifications.

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No Notice of Violation is presently being issued for these inspection

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findings. The number and characterization of the apparent violations

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described in the enclosed inspection report may change as a result of further

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NRC review.

A predecisional enforcement conference to discuss these apparent violations

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will be scheduled at a later date. The decision to hold a predecisional

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enforcement conference does not mean that the NRC has determined that a

violation has occurred or that enforcement action will be taken. This

conference will be held to obtain information to enable the NRC to make an

enforcement decision, such as a common understanding of the facts, root

causes, missed opportunities to identify the apparent violation sooner,

corrective actions, significance of the issues and the need for lasting and

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effective corrective action.

In particular, we expect you to address any

additional examples you may have identified of similar inadequate US0

determinations inadequate corrective actions, or unverified calculations that

were relied upon to support plant modifications.

Also, since your independent

reviews of the modification and procedure revisions did not identify the US0s

or the inappropriate use of unverified calculations, please address how

independent reviews of modifications, operating 3rocedures, and engineering

procedures are conducted at your facility.

Furtier since your engineering

self assessment of April 19. 1996, was generally ineffective and failed to

conclude that your use of unverified calculations to support plant

modifications was contrary to NRC. regulations, please address how self

assessments are conducted at your facility.

In addition, this will be an

opportunity for you to point out any errors in our inspection report and for

you to provide any information concerning your perspectives on 1) the severity

of the violations. 2) the application of the factors that the NRC considers

when it determines the amount of a civil penalty that may be assessed in

accordance with Section VI.B.2 of the Enforcement Policy. and 3) any other-

application of the Enforcement Policy to this case, including the exercise of

discretion in accordance with Section VII.

You will be advised by separate correspondence of the results of our

deliberations on this matter.

No response regarding these apparent violations

is required at this time.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice." a copy of

this letter and its enclosure will be placed in the NRC Public Document Room.

Sincerely..

Original signed by

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Albert F. Gibson

Albert F. Gibson. Director

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Division of Reactor Safety

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Dov et No. 50-302

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License No. DPR-72

Enclosure:

Inspection Report

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See page 3

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PUBLIC

NRC Resident Inspector

U.S. Nuclear Regulatory Commission

6745 N. Tallahassee Road

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