ML20140E774

Notice of Violation from Insp on 970319-21.Violation Noted:Licensee Made Changes to Facility & Procedures Described in FSAR That Involved USQs Based on Inadequate SE

ML20140E774
Person / Time
Site:	Crystal River
Issue date:	06/05/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20140E754	List: ML20140E747 ML20140E774
References
50-302-97-06, 50-302-97-6, EA-97-162, NUDOCS 9706120199
Download: ML20140E774 (3)

Text

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I NOTICE OF VIOLATION Florida Power Corporation Docket No. 50 302 l Crystal River Nuclear Plant License No. DPR 72

Unit 3 EA 97 162 I

l During NRC inspections conducted March 19-21, 1997, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions " NUREG 1600, the violation is listed below:

10 CFR 50.59(a)(1). states, in part, that licensees may make changes to the facility or procedures as described in the safety analysis report, ,

without prior Commission approval, unless the proposed change involves an unreviewed safety question (USQ). 10 CFR 50.59(a)(2) states, in  !

l part, that a proposed change shall bq deemed to involve a USQ (i) if the 1

! probability of occurrence of a malfunction of equipment important to l safety previously evaluated in the safety analysis report may be increased or (ii) if a possibility for a malfunction of a different type than any evaluated previously in the safety analysis report may be j i created. 10 CFR 50.59 (b)(1), in part, states that the licensee shall maintain records of changes in the facility and of changes in procedures made' pursuant to this section. These records must include a written safety evaluation which provides the bases for the determination that l the change does not involve a USQ. 10 CFR 50.59(c) states that a  !

licensee who desires to make a change in the facility or arr.edures 4 described in the safety analysis report which involves a JSQ shall l submit an application for amendment of his license pursuant to 10 CFR 50.90.

l Prior to May 2,1996, Ihe facility Final Safety Analysis Report (FSAR) described the facility's mitigation strategy for a design basis small break Loss of Coolant Accident (LOCA), and that strategy included two j oaerator actions. Those actions were: initiate high pressure injection

, (iPI) flow through all four injection lines within 20 minutes (per FSAR l Table 619); and balance flows in the HPI injection lines within 20 minutes (per FSAR Sections 6.1.3.1.2 and 4.2.2.5.7.2). The NRC had previously (in 1979) approved the use of one operator action to mitigate a design basis small break LOCA, i.e., initiate HPI flow through all four injection lines by 10 minutes after the LOCA.

Contrary to the above, on the dates indicated below, the licensee made changes to the facility and procedures described in the FSAR that involved USQs. The changes involved the addition of the operator actions described below to ensure that the design basis requirements for small break LOCA mitigation were met. The FSAR itself was also changed to include some of the operator actions. These changes were made based

on inadequate safety evaluations, and as a result, a license amendment

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.was not sought for conditions that involved USQs.

The facility was changed by analysis in Calculation M96 0032, Reevaluation of High Pressure Injection Requirements During Small Break Loss of Coolant Accidents, dated May 2,1996, such that additional F operator actions were required to mitigate the consequences of a design 4

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Notice of Violation 2 l

basis small break LOCA. However, the additional operator actions had i not been approved by the NRC to be relied upon for mitigation of a  !

design basis'small break LOCA. The operator actions added or changed '

included:

(1) isolate letdown within 10 minutes, l (2) ' isolate normal makeup within 20 minutes, l- (3) isolate reactor coolant pump (RCP) seal injection within 20 minutes, ,

(4) isolate a broken HPI injection line within 20 minutes, and l (5) control steam generator level above the Emergency Feedwater '

L Initiation and Control automatic setpoint within 20 minutes.

In summary, this change added operator actions [(1), (2), (3), and (5),  !

l above] and changed one operator action [(4) above, which replaced the  ;

previous operator action to balance flows in the HPI injection lines 1 l

within 20 minutes] in the facility's mitigation strategy for a design basis small break LOCA.

l Procedures described in the FSAR, i.e., the emergency operating procedures, were changed by Short Term Instructions (STI) 95-0061, effective November 8,1995 to February 8,1996: STI 96 0068, effective i February 8, 1996 to May 6, 1996: and Revision 4 to Emergency Operating L Procedure E0P 03, dated May 2, 1996; to add the operator action to isolate RCP seal injection. The remaining operator actions had been in the emergency operating procedures since the late 1970s, but at least four of them had not been relied upon to satisfy the design basis as stated in the FSAR.

The FSAR was changed by Revision 23, titled "FSAR Revision due to HPI Reevaluation," dated November 18, 1996, to incorporate the results of Calculation M96 0032 into the FSAR. This change included the operator actions listed above, with the exception of action (5). The safety evaluation for FSAR Revision 23 was dated April 30, 1996.

The required safety evaluations that supported Revision 23 to the FSAR, STI 95 0061, STI 96 0068, and Emergency Operating Procedure E0P 03, Rev. 4, were inadequate in that they failed to recognize the introduction of USQs. (There was no separate safety evaluation for Calculation M96 0032.) The inadequacies involved a failure to recognize that the increase in the number of operator actions required to mitigate a design basis small break LOCA introduced the possibility of a r malfunction of a different type than any evaluated previously in the l FSAR, and also~ increased the probability of occurrence of a malfunction 4

of. equipment important to safety previously evaluated in the FSAR. The

changes-introduced additional opportunities for operator errors. The

, inadequacies also involved a failure to recognize that the addition of the action to isolate RCP seal injection increased the probability of 4

occurrence of a malfunction of equipment important to safety previously evaluated in the FSAR in that it increased the probability of seal failure. Therefore, the changes involved US0s.

Notice of Violation 3 The safety evaluation for FSAR Revision 23 was also inadequate in that it failed to address, and failed to ensure that the FSAR included, all of the required operator actions for small break LOCA mitigation that were stated in Calculation M96 0032. Operator action (5) was not addressed by the safety evaluation for FSAR Revision 23 and was not included in the FSAR revision. (01013)

This is a Severity Level III violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Florida Power Corporation (Licensee) is hereby required to submit a written statement or exalanation to the U. S. Nuclear Regulatory Commission, ATTN: Document Control Jesk, Washington, D. C. 20555 with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector at the Crystal River facility, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the l corrective steps that have been taken and the results achieved, (3) the l corrective steps that will be taken to avoid further violations, and (4) the l date when full compliance will be achieved. Your response may reference or include previously docketed correspondence, if the correspondence adecuately addresses the required response. If an adequate reply is not receivec within the time specified in this Notice, an order or Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

Under the authority of Section 182 of the Action, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Because your res3onse will be placed in the NRC Public Document Room (PDR), to the extent possi ale, it should not include any personal privacy, 3roprietary, or safeguards information so that it can be placed in the PDR wit 1out redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must s)ecifically identify the portions of your response that you seek to have withield and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Atlanta, Georgia this 5th day of June 1997 i