ML20153E554
| ML20153E554 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 05/04/1988 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Wilgus W FLORIDA POWER CORP. |
| Shared Package | |
| ML20153E558 | List: |
| References | |
| EA-88-034, EA-88-34, NUDOCS 8805100049 | |
| Download: ML20153E554 (4) | |
See also: IR 05000302/1987041
Text
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MAY 0 41988
Docket No. 50-302
' License No. DPR-72
EA 88-34
Florida Power Corporation
Mr. W. S. Wilgus
Vice President Nuclear Operations
ATTN: Manager, Nuclear Licensing
Post Office Box 219
Crystal River, Florida 32629
Gentlemen:
SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY
(NRC INSPECTION REPORT N0. 50-302/87-41)
This refers to the Nuclear Regulatory Commission (NRC) inspection conducted at
the Crystal River Nuclear Plant on November 30 - December 4, 1987. The
inspection included a review of the circumstances surrounding diesel generator
overload due to failure to take appropriate corrective actions to resolve a
design error. The report documenting this inspection was sent to you with a
letter dated January 12, 1988. As a result of this inspection, a significant
failure to comply with NRC regulatory requirements was identified, and accordingly,
NRC concerns relative to the inspection findings were discussed in an Enforcement
Conference held on February 22, 1988.
The violation described in the enclosed Notice of Violation and Proposed
Imposition of Civil Penalty (Notice) involved a failure to take appropriate
corrective action to resolve a deficier.cy regarding the electrical loads placed
on one of two plant emergency diesel generators (EDGs), namely, E0G/A.
It
appears that this failure was caused by errors made in the interpretation of
the EDG vendor's load ratings and in the assessment of equipment electrical
loads in incorporating a design change in May 1980, which connected the
emergency feedwater pump as an automatic load to EDG/A.
This failure resulted
in the lack of assurances that the onsite emergency power system would perform
its intended safety function for certain worst case accident scenarios for
which the system was initially designed. This potential EDG overload condition
was identified by Florida Power Corporation (FPC) during an NRC Operational
SafetyTeamInspection(OSTI)inAugust1987. A reevaluation performed by FPC
determined that the EDG vendor's ratings had been improperly interpreted and
that an incorrect and non-conservative power factor (0.8 vice 0.9) was applied
to determine the total loads that were to be carried by the EDGs. At that time
the design electrical load was calculated to be as high as 3545 KW under worst
case accident scenarios. This calculated load exceeded the EDG vendor's rated
performance capability of 2750 KW (continuous operation), 3000 KW (for 2000
hours cumulative operation), and 3300 KW for 30 minutes of cumulative
operation) .
8805100049 880504
DR
ADOCK 05000302
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The possibility of a deficiency regarding the overloading of EDG/A was originally
ideatified by FPC in May 1980, even using the incorrect power factor of 0.8.
To resolve this matter, tests were conducted which incorrectly concluded that
the EDGs were not overloaded; however, the tests were in error since they did
not represent flow conditions which would be encountered under the worst case
accident conditions. Therefore, from May 1980 until October 1987, the plant
operated at times with a potentially overloaded EDG.
In addition, the OSTI
found during its special inspection that surveillance test requirements in the
plant Technical Specifications permitted operation of the EDGs in excess of the
electrical load rating provided by the EDG vendor.
In this regard, correspondence
received from the EDG vendor in September 1987, confirmed that the maximum load
ratings for EDG/A had been exceeded in the performance of the Technical
Specification-required 18-month surveillance tests. This oversight is attributed
to FPCs incorrect application of the EDG vendor's ratings.
We recognize that this problem was identified as a result of programmatic
review processes initiated as a result of the FPCs Configuration Management
Program (CMP).
In this particular case, on or about September 14, 1987, FPC
received correspondence from the EDG manufacturer which led to the realization
that the EDG 30-minute rating had been exceeded during the performance of the
EDG 18-month surveillance test.
FPC subsequently initiated a reevaluation
of the EDG loading which revealed the power factor error. A review of the
chronology associated with this problem, particularly the period from June 1987
when a problem related to under-voltage conditions when some loads were transferred
to the EDGs and from August 1987 when the first indication of a potential
problem was discovered during performance testing to October 1987 when the
Technical Specification / Design Basis conflict was reported, suggests a less than
aggressive corrective action strategy for resolving a potentially serious problem.
To emphasize the importance of the identification and correction of problems in
the area of design and incorporation of design changes into Technical Specifications
and procedures, I have been authorized, after consultation with the Director,
Office of Enforcement, and the Deputy Executive Director for Operations, to
issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty
in the amount of Fifty Thousand Dollars ($50,000) for the violation described
in the enclosed Notice.
In accordance with the "General Statement of Policy
and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987)
(Enforcement Policy), the violation described in the enclosed Notice has been
categorized as a Severity Level III violation. The escalation and mitigation
factors in the Enforcement Policy were considered. While we recognize that you
identified the EDG problem, you had prior opportunity to identify the problem
in June 1987. While you have committed to enhance the CMP, this effort was
started at the urgings of the NRC to correct weaknesses in your past performance
in design controi.
For these reasons, no adjustment of the base civil penalty
amount has been deemed appropriate.
The CMP represents a positive management commitment to programmatic configuration
enhancement; however, weaknesses still exist in your design control process
as is evidenced by the EDG issue, which need to be remedied in your planned
efforts to improve the effectiveness of the CMP for prompt corrective action
in the resolution of design problems.
Your intention (discussed at the Enforcement
Conference) to keep the NRC briefed on CMP status, to keep the Senior Resident
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Inspector briefed on significant CMP findings, to discuss CMP issues at quarterly
management meetings with NRC, and to provide periodic written reports to the
NRC staff regarding the CMP strongly supports your commitment.
You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response.
In your
response, you should document the specific actions taken and any additional
actions you plan to prevent recurrence.
In addition, you should describe what
action has been taken, or that you plan to take to determine whether there
may be other systems affected by design evaluation errors in need of prompt
corrective action. After reviewing your response to this Notice, including
your proposed corrective actions, the NRC will determine whether further NRC
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enforcement action is necessary to ensure compliance with NRC regulatory
requirements.
In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2,
Title 10, Code of Federal Regulations, a copy of this letter and its enclosure
will be placed in the NRC Public Document Room.
The responses directed by this letter and its enclosure are not subject to the
clearance procedures of the Office of Management and Budget as required by the
Paperwork Reduction Act of 1980, Pub. L. No.96-511.
Should you have any questions concerning this letter, please contact us.
Sincerely,
ORIGINAL SIGNED BY
k/_.On5F
J. Nelson Grace
Regional Administrator
Enclosure:
Notice of Violation and Proposed
Imposition of Civil Penalty
cc w/ encl:
P. F. McKee, Director, Nuclear
Plant Operations
E. C. Sinpson, Director, Nuclear
Site Support
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MAY 0 41988
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Florida Power Corporation
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DISTRIBUTION:
bec w/ encl:
NRC Resident Inspector
DRS Technical Assistant
Document Control Desk
State of Florida
LPDR
SECY
CA
JMTaylor, DEDP.
JNGrace, RII
JLieberman, OE
JStefano, OE
LChandler, OGC
FIngram, PA
Enforcement Coordinators
RI, RII, RIII, RIV, RV
TMurley, NRR
BHayes, 01
EJordan, AE0D
SConnelly, 01A
EA File
ES File
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