IR 05000302/1996012
| ML20137E523 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 03/12/1997 |
| From: | Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Richard Anderson FLORIDA POWER CORP. |
| Shared Package | |
| ML20137E528 | List: |
| References | |
| EA-96-365, EA-96-465, EA-96-527, NUDOCS 9703270308 | |
| Download: ML20137E523 (6) | |
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SUBJECT:
NOTICE OF VIOLATION AND EXERCISE OF ENFORCEMENT DISCRETION (NRC INSPECTICiN REPORT NOS. 50-302/96-12 AND 50-302/96-19)
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Dear Mr. Anderson:
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This refers to NRC inspections completed on December 6,1996, at Florida Power
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Corporation's (FPC) Crystal River Unit 3 nuclear facility. During these reviews, the NRC'
examined a number of issues related to your implementation of the Engineering program at Crystal River. The results of the inspections were formally transmitted to you by letters dated
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was conducted in the Region 11 office on January 24,1997, with members of your staff to l
discuss the apparent violations, the root causes, and corrective actions to preclude recurrence. A summary of the conference was sent to FPC by letter dated January 31,1997.
Based on the information developed during the inspections and the information you provided during the conference, the NRC has determined that violations of NRC requirements occurred. The violations are discussed in detailin Enclosure 1. Enclosure 2 provides the Notice of Violation (Notice). The circumstances surrounding the violations are described in the subject inspection reports.
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The violations identified during our inspections indicate a broad spectrum of problems existed
in FPC's Engineering program. Our review of these violations disclosed major weaknesses in
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I three specific areas. Six violations were identified for failure to meet the requirements of
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10 CFR 50.59. These violatiuns have been categorized in the aggregate as a Severity
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Level ll problem, identified as Violation A in the enclosed Notice, due to the regulatory and
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safety significance associated with the programmatic deficiencies in the performance of 10 CFR 50.59 safety evaluations and operation of the Crystal River facility with a number of unidentified unreviewed safety questions (USQ) that impacted the design margin and
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i operability of safety-related equipment. Violation B indicates prcgrammatic weaknesses with l
the implementation of measures to ensure that regulatory and plant design basis j
requirements are met. Violation B has been categorized as a Severity Level 111 violation.
Violation C involves three examples of untimely and inadequate corrective actions resulting in the failure to identify significant USQs and containment integrity issues and has been categorized as a Severity Level til violation.
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FPC's significantly poor performance in these areas is evidence of a systemic breakdown in control of engineering processes at the Crystal River facility. Violation A is of particular concern because of the regulatory significance associated with the failure to implement an adequate 10 CFR 50.59 program and the potential safety consequences that could result from the introduction of a number of USQs that significantly reduced the design margin of certain safety-related systems. Failure to resolve these USQs is a serious safety concern because, in certain accident scenarios, vital equipment could have failed resulting in the loss of the one train of onsite emergency power and unavailability of an emergency feedwater pump. Reactor safety also could have been compromised due to inadequate boron precipitation control in the event of a loss of coolant accident. In addition, failure to identify
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many of these USQs indicates that your staff failed to recognize design conditions that seriously degraded the margin of safety in several safety-related systems. With regard to Violation B, we are concemed that numerous examples were identified where FPC engineering design control programs lacked sufficient rigor to ensure that design inputs and controls properly maintained the design and licensing bases. Similar weaknesses in the i
engineering program were identified previously in an escalated enforcement action (EA 95-126), dated July 10,1996. In addition, FPC failed to take advantage of several opportunities to correct the root causes of these violations prior to NRC involvement and therefore, missed the opportunity to resolve the USQs related to the emergency diesel generator and identify and correct containment configuration control deficiencies.
In accordance with the Enforcement Policy, civil penalties would normally be considered for the Severity Level 11 problem and Severity Level 111 violations. However, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Regulatory Effectiveness, Program Oversight, investigations and Enforcement, to exercise enforcement discretion in accordance with Section Vll.B.(6) of the Enforcement Policy and not propose a civil penalty in this case. It should be stressed that the NRC considered the proposed imposition of a significant civil penalty in this case.
However, the NRC has concluded that discretion is appropriate in that: (1) NRC issued a
$500,000 civil penalty on July 10,1996 (EA 95-126) which included sanctions for engineering violations; (2) following NRC identification of the current issues, FPC voluntarily extended the shut down of the Crystal River facility and developed a comprehensive program for problem identification and correction; (3) FPC has demonstrated that remedial action will be taken to ensure reestablishment of design margins for plant systems prior to plant restart; and, (4) FPC's decision to restart the Crystal River facility requires NRC concurrence in accordance with a Confirmatory Action Letter issued on March 4,1997. FPC's corrective actions willinclude: (1) completion of a comprehensive restructuring of management; (2) completion of in-depth reviews and corrective actions to ensure compliance with the design bases of the facility; and, (3) implementation of broad and in-depth engineering program changes.
The exercise of this discretion is intended to recognize that FPC has placed the unit in a safe configuration and has committed significant resources to identify and correct deficient conditions. Nonetheless, the NRC must emphasize that failure to implement your
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improvement plans successfully and substantially improve performance in the engineering area at Crystal River could lead to more significant regulatory sanctions and substantially delay NRC concurrence with restart of Crystal River Unit 3.
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As discussed with you at the predecisional enforcement conference, we believe it is imperative that FPC conduct rigorous reviews to ensure that the extent of the deficiencies are bounded and root causes of the conditions are well understood. It is also important to implement long lasting, comprehensive corrective actions that not only correct the deficiencies identified but also strengthen the engineering organization and design review processes. Effective measures to ensure the qualifications of the engineering staff and strong management oversight of the engineering process are also key elements in precluding recurrence of the violations. As part of the responsibility to ensure safe plant operation, the NRC expects licensees with identified programmatic breakdowns to reestablish, without delay, a high level of confidence that design requirements are correctly reflected in the installation and operation of plant equipment and that licensee staff is fully qualified and dedicated to ensuring safe operation of the facility. As discussed at the predscisional enforcement conference, FPC has committed to provide the NRC with additionalinformation as implementation of its improvement plans proceeds to ensure that design margins are appropriately re-established. The NRC will continue to monitor implementation of the improvement program and rigorously review your preparations for restart of Crystal River Unit 3.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its enclosures, and your response will be placed in the NRC Public Document Room.
Should you have any questions concerning this letter, please contact us.
Sincerely, Original Signed by Luis A. Reyes Luis A. Reyes Regional Administrator Docket No. 50-302 License No. DPR-72 Enclosures:
1. Description of Violations 2. Notice of Violation cc w/encls: (See page 4)
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cc w/encls:
John P. Cowan, Vice President Bill Passetti l
Nuclear Production (SA2C)
Office of Radiation Control
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Florida Power Corporation Department of Health and Crystal River Energy Complex Rehabilitative Services 15760 West Power Line Street 1317 Winewood Boulevard Crystal River, FL 34428-6708 Tallahassee, FL 32399-0700
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B. J. Hickle, Director Joe Myers, Director Nuclear Plant Operations (NA2C)
Division of Emergency Preparedness Florida Power Corporation Department of Community Affairs
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Crystal River Energy Complex 2740 Centerview Drive 15760 West Power Line Street Tallahassee, FL 32399-2100 Crystal River, FL 34428-6708 Chairnia:,
David F. Kuncemiller, Director (SA2A)
Board of County Commissioners Nuclear Operations Site Support Citrus County Florida Power Corporation 110 N. Apopka Avenue Crystal River Energy Complex inverness, FL 34450-4245 15760 West Power Line Street Crystal River, FL 34428-6708 Robert B. Borsum B&W Nuclear Technologies R. Alexander Glenn 1700 Rockville Pike, Suite 525 Corporate Counsel Rockville, MD 20852-1631 Florida Power Corporation MAC - ASA P. O. Box 14042 St. Petersburg, FL 33733
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Attorney General
Department of Legal Affairs l
The Capitol
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Tallahassee, FL 32304 i
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l DESCRIPTION OF VIOLATIONS A.
Inadeauate implementation of 10 CFR 50.59 The NRC determined that a number of unreviewed safety questions (USQs) had been
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created by plant modifications at Crystal River, and the USQs were not identified in the safety evaluations performed. Each failure to perform an adequato evaluation to
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determine if a proposed change to the facility or procedures constitutes a USQ is a violation of 10 CFR 50.59. The NRC views each failure to meet the requirements of 10 CFR 50.59 where a USQ existed and the required license amenoment was not
sought as a significant regulatory issue.
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The USQs identified included increases in the emergency diesel generator (EDG)
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loads for certain accident scenarios in excess of three design load limits which reduced the margin of safety as defined in the Final Safety Analysis Report (FSAR)
and Technical Specification (TS) bases; hydraulics and potential net positive suction head (NPSH) problems created by a change to the initiation logic of the attemate
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steam admission valve for the turbine-driven emergency feedwater (EFW) pump resulting in an increase in the probability of damage to the pump; disabling of one of
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the automatic steam supplies to the turbine-driven EFW pump, reducing the reliability
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and increasing the probability of failure of the pump; and, a change to the primary method credited for prevention of boron precipitation in the core following a postulated loss of coolant accident.
The safety consequences of these violations included the potential loss of the "A" train EDG, potential failure of the turbine-driven EFW pump, and potentialinadequate control of boron precipitation in the core in the event of a loss of coolant accident.
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The violations also introduced significant errors in the defined licensing envelope of the plant because documents defining the licensing bases were not updated or were inaccurate.
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Commensurate with the regulatory significance of the programmatic deficiencies in the i
evaluation of plant modifications and procedure changes under the 10 CFR 50.59 program and the potential safety consequences of operating with a number of unidentified USQs, these violations are classified in the aggregate in accordance with
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the " General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, as a Severity Level 11 problem.
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Inadeauate Desian Control Five examples of the failure of FPC's engineering design control programs to assure that design inputs and controls properly maintained the design and licensing bases were ioentified. These examples indicated a significant breakdown in the control of engineering processes at Crystal River. The failure to establish measures to ensure that regulatory requirements and the design basis are correctly translated into specifications, procedures and instructions is a violation of 10 CFR 50, Appendix B, Criterion Ili, Design Control.
Enclosure 1 e
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Description of Violations
Design control requirements were violated in the following cases: (1) the FSAR, the Enhanced Design Basis Document, and the TS Bases were not updated with regard to operation of the turbine-driven EFW pump (EFP-2) for certain accident scenarios resulting in inadequate evaluation of EDG loading; (2) automatic opening of Valve ASV-204 was disabled preventing the auto-start of EFP-2 in certain accident scenarios; (3) the heat input to the nuclear closed cycle cooling system (SW) heat exchangers was not correctly modeled; (4) unverified calculations were used to support modifications to the EFW system; and, (5) configuration control of containment penetrations was lost in that a significant number of valves and blind flanges were not included in surveillances required to ensure containment integrity.
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Therefore, this violation has been categorized in accordance with the Enforcement Policy, NUREG-1600, at Severity Level 111.
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Failure to Take Timelv and Comprehensive Corrective Actions Three examples were identified involving the failure to implement timely and appropriate corrective actions and to ensure corrective actions were adequate to
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preclude recurrence of significant conditions adverse to quality. Failure to take appropriate corrective actions resulted in the creation of USQs and led to reductions in safety margins as discussed below.
The potential for EDG loading in excess of TS limits, identified in May and July of 1996, had not been corrected as of October 11,1996. Corrective actions identified in a 1994 Licensee Event Report for failure to test containment penetrations in
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accordance with TS requirements, were inadequate to prevent a recurrence, resulting i
in failure to identify that numerous additional valves / blind flanges were omitted from surveillance procedures and therefore, were not verified to be closed.
The failure to establish measures to assure that conditions adverse to quality are promptly corrected is a violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective l
Action. Therefore, this violation has been categorized in accordance with the Enforcement Policy, NUREG-1600, at Severity Level 111.
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