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Discusses Insp Rept 50-302/97-06 on 970319-21 & Forwards Nov.Violations of Concerns Because FPC Failed to Identify Changes Involved USQ That Required NRC Review & Approval Prior to Implementation
	ML20140E747
Person / Time
Site:	Crystal River
Issue date:	06/05/1997
From:	Reyes L; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Richard Anderson; FLORIDA POWER CORP.
Shared Package
ML20140E754	List: ML20140E747; ML20140E774;
References
	50-302-97-06, 50-302-97-6, EA-97-162, NUDOCS 9706120195
	Download: ML20140E747 (6)
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EA 97 162

Florida Power Corporation

Crystal River Energy Complex

Mr. Roy A. Anderson (SA2A)

Sr. VP, Nuclear Operations

ATTN: Mgr., Nuclear Licensing

15760 West Power Line Street

Crystal River, Florida 34428 6708

SUBJECT:

NOTICE OF VIOLATION AND EXERCISE OF ENFORCEMENT DISCRETION

(NRC INSPECTION REPORT NO. 50 302/97 06)

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Dear Mr. Anderson:

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This refers to the inspection conducted March 19 21, 1997, at Florida Power

Corporation's (FPC). Crystal River Unit 3 nuclear facility. The purpose of the

inspection was to assess _ changes made to the unit's Final Safety Analysis

Report (FSAR) and operating procedures that involved a substantial increase in

the number of operator actions necessary to mitigate a design basis small

break loss of coolant accident (LOCA). The results of the inspection were

formally transmitted to you by letter dated April 17, 1997.

Based on the information developed during the inspection, the NRC has

determined that a violation of NRC requirements occurred. The violation is

cited in the enclosed Notice of Violation (Notice), and the circumstances

-surrounding the violation are described in detail in the subject inspection

report. The violation involved (1) the failure to identify that the addition

of required operator actions to mitigate a design basis small break LOCA

constituted an unreviewed safety question (USQ); and (2) the subsequent

failure to obtain NRC review and approval of that mitigation strategy. The

apparent root causes of the violation were inadequate safety evaluations for

procedure and FSAR revisions that added operator actions for design basis

small break LOCA mitigation.

Specifically, FPC failed to identify that, per

10 CFR 50.59(a)(2), the addition of operator actions to the previously

approved design basis accident mitigation strategy may result in an increase

in the probability of occurrence of a malfunction of eq ipment important to

safety previously evaluated in the FSAR and the possibi ity of a malfunction

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of a different type than any evaluated previously in the FSAR. The changes

introduced additional opportunities for operator error during small break LOCA

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mitigation and an increase in the probability of reactor coolant pump seal

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failure. Accordingly, FPC failed to identify that the changes involved an US0

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that required NRC review and approval prior to implementation.

Further, when

FPC recogni7ed that the additional operator actions were required, it failed

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to incorpe ate this latest developed information into an FSAR revision that

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was intended to reflect this change. This violation is a significant failure

to meet the requirements of 10 CFR 50.59, including a failure such that a

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required license amendment was not sought and, therefore, has been categorized '

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as a Severity Level III violation.

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FPC

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

Enforcement Actions" (Enforcement Policy). NUREG 1600, a civil penalty

normally would be considered for a Severity Level III violation.

However, I

have been. authorized, after consultation with the Director Office of

Enforcement, to exercise enforcement discretion in accordance with Section

VII.B.(6) of the Enforcement Policy and not propose a civil penalty in this

case. The NRC has concluded that discretion is appropriate in that:

(1) the

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Crystal River facility is shutdown for performance reasons including

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engineering violations such as the ones in this case and those issued on

March 12,1997 (EAs 96 365, 96 465 and 96 527) which involved a Severity

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Level II problem for the failure to perform adequate reviews pursuant to

10 CFR 50.59: (2) the Crystal River facility will remain shut down until

completion of a comprehensive program of improvements in the engineering area:

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(3) FPC has demonstrated that remedial action is being taken to ensure

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reestablishment of design margins for plant systems prior to plant restart:

(4) NRC issued a $500,000 civil penalty on July 10, 1996 (EA 95 126) which

included sanctions for engineering violations: and, (5) FPC's decision to

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restart the Crystal River facility requires NRC concurrence in accordance with

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a Confirmatory Action Letter issued on March 4,1997.

During the NRC review of the safety evaluation for FSAR Revision 23, it was

determined that errors in the evaluation are similar to those identified in

the March 12, 1997 escalated enforcement action described above. The FSAR

Revision 23 safety evaluation contains inappropriate reasoning for determining

if a USQ exists.

For example, the evaluation states that no change was made

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to the function of any safety related equipment when in fact automatic

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functions assumed in the safety analysis were replaced by manual actions.

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addition, the evaluation utilizes industry guidelines that have not been

accepted by the NRC. These and other statements are of concern to the NRC

because FPC had indicated that this safety evaluation was a final

3roduct of

its reanalysis effort at.the time of the March 1997 inspection. T1erefore,

FPC is requested to include in its response those corrective actions necessary

to ensu.e that safety evaluations contain sound reasoning and comalete

analysis to support a determination that a USQ does not exist. T1e NRC also

noted that the FSAR Revision 23 safety evaluation contained a reevaluation of

a letdown line break which concluded that the potential offsite dose was

greater than stated in the FSAR. The NRC will conduct further reviews of this

FSAR change.

You are required to respond to this letter and should fcllow 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.

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FPC

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

this letter, its enclosure, 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

Regional Administrator

Docket No.

50 302

License No. -DPR 72

Enclosure:

Notice of Violation

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cc w/ encl:

John P. Cowan, Vice President

Nuclear Production (NA2E)

Florida Power Corporation

Crystal River Energy Complex-

15760 West Power Line Street

Crystal River, FL 34428-6708

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B. J. Hickle Director

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Nuclear Plant Operations (NA2C)

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Florida Power Corporation

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Crystal River Energy Complex

15760 West Power Line Street

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Crystal River, FL 34428 6708

Robert E. Grazio, Director (SA2A)

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Nuclear Regulatory Affairs

Florida Power Corporation

Crystal River Energy Complex

15760 West Power Line Street

Crystal River, FL 34428 6708

James S. Baumstark (SA2C)

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Director. Quality Programs

Florida Power Corporation

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Crystal River Energy Complex

15760 West Power Line Street

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Crystal River, FL 34428 6708

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cc w/ encl cont'd:

(See page 4)

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cc W/ encl cont'd:

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R. Alexander Glenn

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Corporate Counsel

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Florida Power Corporation

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ASA

P. O. Box 14042

St. Petersburg, FL 33733

Attorney General

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Department of Legal Affairs

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The Capitol

Tallahassee, FL 32304

Bill Passetti

Office of Radiation Control

De)artment of Health and

lehabilitative Services

1317 Winewood Boulevard

Tallahassee, FL 32399-0700

Joe Myers, Director

Division of Emergency Preparedness

Department of Community Affairs

2740 Centerview Drive

Tallahassee,'FL 32399 2100-

Chairman-

Board of County Commissioners

Citrus County

110 N. Apopka Avenue

Inverness, FL 34450 4245

Robert B. Borsum-

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B&W Nuclear Technologies

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1700 Rockville Pike. Suite 525

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Rockville, MD 20852-1631

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Distribution w/ encl:

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LChandler, OGC

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CChristensen, RI,I-(IFS Action. Required,'-

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RSchin, RII

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RTrojanowski, RII

NRC Resident Inspector

U.S. Nuclear Regulatory Commission

6745 N Tallahassee Road

Crystal River, FL 34428

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