IR 05000302/1997009: Difference between revisions

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{{Adams
{{Adams
| number = ML20149H098
| number = ML20212B939
| issue date = 07/14/1997
| issue date = 10/16/1997
| title = Insp Rept 50-302/97-09 on 970602-20.Apparent Violations Being Considered for Escalated Ea.Major Areas Inspected: Engineering of Functional Areas
| title = Ack Receipt of 970908 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-302/97-09 on 970905
| author name =  
| author name = Jaudon J
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
| addressee name =  
| addressee name = Anderson R
| addressee affiliation =  
| addressee affiliation = FLORIDA POWER CORP.
| docket = 05000302
| docket = 05000302
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-302-97-09, 50-302-97-9, NUDOCS 9707240209
| document report number = 50-302-97-09, 50-302-97-9, EA-97-330, NUDOCS 9710280313
| package number = ML20149H091
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 3
| page count = 7
}}
}}


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U.S. NUCLEAR REGULATORY COMMISSION REGION 2
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Docket No: 50-302 License No: DPR-72
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Report No: 50-302/97-09 Licensee: Florida Power Corporation Facility: Crystal River 3 Nuclear Station
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October 16, 1997 EA 97 330
Location: 15760 West Power Line Street Crystal River, FL 34428-6708 Dates: June 2 through June 20, 1997 Inspectors: R. Schin, Senior Reactor Inspector M. Miller. Reactor Inspector Approved b H. Christensen, Chief Engineering Branch Division of Reactor Safety l
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Florida Power Corporation Crystal River Energy Complex Mr. Roy (SA2A)
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Sr. VP, Nuclear Operations ATTN: Mgr., Nuclear Licensing 15760 West Power Line Street Crystal River. FL 34428 6708 SUBJECT:    NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-302/97 09)
I Enclosure
 
      ]
==Dear Mr. Anderson:==
l 9707240209 970714 PDR ADOCK 05000302 G  PDR
Thank you for of Violation (your      NOV)supplemental  res)onse issued on Septem)er of September 5. 1997, concerning8.activities 1997, to our Notice conducted at ,vour Crystal River facility. We have evaluated your response and found that it meets the requirements of 10 CFR 2.201. We will examine the implementation of your corrective actions during future inspections.
      )


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We appreciate your cooperation in this matter.
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EXECUTIVE SUMMARY Crystal River 3 Nuclear Station NRC Inspection Report 50-302/97-09 This special inspection addressed the engineering functional area. The
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purpose of the inspection was to follow up on open item IFI 96-201-14. EDG Protective Trips Not Bypassed During Emergency Mode of Operatio Enaineerina An apparent violation (EEI 50-302/97-09-01) was identified for an inadequate safety evaluation for a modification that was performed in 1987. The modification added five protective trips to each emergency diesel generator (EDG) control circuit, for protection from bus faults and prolonged overcurrent conditions. The added EDG trips were not bypassed during emergency operation and were not installed with two out of three coincidence logic. Thus a single failure in the added circuitry could cause an EDG to fail ina)propriately. The modification increased the probability of failure of the E Ms and created an unreviewed safety question (US0). The safety evaluation for the modification failed to recognize the US0 and the modification was performed without obtaining the required prior NRC review and approva (paragraph E8.1)
A weakness was identified in the licensee's 10 CFR 50.59 safety evaluation program in that the licensee in 1997 erroneously relied on NSAC-125 guidance, which the NRC has not endorse (paragraph E8.1)
A second ap)arent violation (EEI 50-302/97-09-02) was identified for failure to update t1e FSAR to describe the added EDG protective trias. This apparent violation and another recent example of failure to update t1e FSAR. for a 1996 revised small break loss of coolant accident mitigation strategy (see EA 97-162 and Inspection Report 50-302/97-06). indicate a weakness in control of the design bases. (paragraph E8.1)
The inspectors assessed the licensee's performance concerning the five areas of continuing NRC concern in the following paragraph: the assessment is limited to the specific issue addressed in the respective paragrap NRC AREA 0F CONCERN  ASSESSMENT PARAGRAPH E Management Oversight I Engineering Effectiveness I
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Knowledge of Design Basis I Compliance With Regulations I Operator Performance S = Superior G = Good A = Adequate / Acceptable I = Inadequate Blank = Not Evaluated / Insufficient Information y oeo bpra on I
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Sincerely
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Report Details
Original Signed By:
      . Epaineerina
J. P. Jaudon
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Johns P. Jaudon. Director Division of Reactor Safety Docket No. 50 302 License No. DPR 72 cc:  John P. Cowan. Vice President Nuclear Production (NA2E)
'E8 -Hiscellaneous Engineering Issues    -
FPC. Crystal _ River Energy Complex 15760 West Power Line Street
      '
  . Crystal River. FL 34428-6708 cc:   Continued see page 2
E8.1 -(Closed) IFI 96-201-14. EDG Protective Trios Not Bvoassed Durino Emeraency Mode of Ooeration Insoection Scoce (92903)
[E! E        ,302 i
This IFI was-originated during an NRC inspection in July 1996 when an NRC inspection team identified .that numerous protective trips for the -
IllllllMERill Mc/
emergency diesel generators (EDGs) were not bypassed during the  '
emergency mode of operation. Also, the current FSAR (Section 8.2. and Figure 8-9) did not correctly reflect the installed EDG protective trip feature The licensee had implemented a-plant modification in 1987. that increased the number _ of EDG protective trips. At the time of the modification, guidance in effect regarding the design of EDG 3rotective trips was #
provided in NRC Regulatory Guide (RG) 1.9 and IEEE Standard 387-198 The licensee's modification was not consistent with RG 1.9: however, the licensee was not committed to RG 1.9. The licensee issued Problem Report 96-0263 to address this issu ;
During this inspection, the inspectors followed up on this IFI by reviewing Problem Report 96-0263: portions of plant modification MAR 80- '.
09-13-01: RG 1.9 Revision 2. dated December 1979: and FSAR Figure 8- Revisions 1 and 14. Emergency Diesel Generator Control. The inspectors also discussed the EDG protective trips and related 10 CFR 50.59 safety evaluations with engineers, the Safety Analysis Group, and plant management, Dbservations and Findinas I
The inspectors found that the licensee had implemented plant modification MAR 80-09-13-01. EDG Relaying Modification, from February 7. 1987, through December 21, 1987. The modification added ,
five EDG protective trips to the control circuit of each EDG to 3rotect ,
the EDG from bus faults and prolonged overcurrent conditions. T1e five added trips, which were installed as inputs to the EDG lockout rela '
were: overcurrent on the EDG output, ground fault, and overcurrent trip on any of the three breakers that could supply offsite power to the ES bus. The MAR description of the modification was that it changed the original " bus differential" relay from a single relay trip to an "86 lockout" relay that had six relay trip inputs. These inputs to the "86 lockout" relay were from the following relays: 1) existing bus differential (87 current differential). 2) 51V overcurrent with voltage restraint, 3) 64 ground fault. 4) 3205 (3206) overcurrent + ground fault. 5) 3207 (3208) overcurrent + ground fault. 6) 3211 (3212)
overcurrent + ground fault. (The numbers in parentheses 3206. 3208, and 3212 are for the second EDG.)


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FPC      2 cc:  Continued C. G. Pardee, Director Nuclear Plant Operations (NA2C)    '
 
FPC, Crystal River Energy Complex 15760 West Power Line Street Crystal River, FL 34428 6708 Robert E. Grazio Director Nuclear Regulatory Affairs (SA2A)
fPC, Crystal River Energy Complex 15760 West Power Line Street Crystal River, FL 34428 6708 James S Baumstark, Director Quality Programs (SA2C)
FPC, Crystal River Energy Complex 15760 West Power Line Street Crystal River, FL 34428 6708
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R. Alexander Glenn, Corporate Counsel
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Florida Power Corporation MAC - ASA P. O. Box 14042 St Petersburg, FL 33733 4042 Attorney Gent.'al Department of Legal Affairs      ,
The inspectors-reviewed RG l'.9. Rev.2. dated' December.1979 which was in
The Capitol Tallahassee, FL 32304 Bill Passetti Office of Radiation Control
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effect during the modification preparation and installation in 1986 and 1  1987. RG 1.9 . stated:' {emergencydieselgenerator engine-overs)eed  -
. and generator-differential trips may be implemented}by a single-clannel -
,:  trip. All.Other diesel-. generator protective trips should be handled in
 
one of two ways: Either. (1) a trip should be implemented with two or
, more-independent measurements for each trip parameter with coincidental
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logic provisions .for. trip actuation, or (2) a trip may be bypassed under f  -
accident conditions. 3rovided the operator has sufficient time to react  '
appropriately to an a) normal diesel-generator unit conditio Modification MAR 80-09-13-01 was not consistent with the guidance of .  :
RG 1.9 in that it added EDG trips that were not bypassed under accident-conditions and were not installed with coincident logic provisions for.
 
;  -trip activation. Thus, a single failure in the added trip circuitry  '
could result in an inappropriate failure of the EDG.
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The 10 CFR.50.59 safety evaluation for MAR 80-09-13-01 did not address i
Dept of Health and Rehab. Serv.
E the fact that a single failure of any one of the added protective relays  ;
for an EDG could result in an -inappropriate failure of the EDG. The
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modification increased the probability of failure of the EDGs and
!  represented an unreviewed safety question (US0). The safety evaluation 4  did not recognize the US0 and allowed the modification to be performed
!  without the required prior NRC review and a) proval. The inspectors
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identified this apparent violation of 10 CFR 50.59 as EEI 50-302/97-09-01. Unreviewed Safety Question Involving Added EDG Protective Trip l The current FSAR (Figure 8-9. Rev. 14) had not been updated to include the modification as of the date of this inspection, but the licensee had prepared a draft revised FSAR Figure 8-9 to go in the next FSAR  '
revision. The failure to update the FSAR to include MAR 80-09-13-0 :
within two years after the MAR was installed in 1987, is identified as  '
an apparent violation of-10 CFR 50.71: EEI 50-302/97-09-02. Failure to  ,
Update the FSAR to Include Added Emergency Diesel Generator Trip The EDG protective trips in effect prior to the installation of MAR 90-09-13-01 were shown in FSAR Figure 8-9. Rev. They included overspeed. bus differential, and low lube' oil pressure. These same trips. in addition to the MAR 80-09-13-01 trips, were the EDG trips that were currently installed. The inspectors found that the overspeed, bus differential. and low lube oil pressure trips had been installed prior to initial licensing: thus, they had been reviewed by the NRC. Als ,
the low lube oil pressure trip included a two out' of three coincident logic. The inspectors concluded that the overspeed, bus differentia i and low lube oil pressure trips were all consistent with RG '
The licensee addressed the EDG protective trips modification concern in
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Problem Report (PR) 96-0263. Corrective action for the PR included a  1 detailed 10 CFR'50.59 safety evaluation dated July 26, 1996. That  i safety evaluation concluded that MAR 80-09-13-01 did not introduce a  -)
US The licensee further assessed the potential for a US0 in an  ;
interoffice correspondence from the Manager. Nuclear Licensing dated  ;
April 29,1997: in an interoffice correspondence from the Manage l l
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Safety Analysis Group, dated May 9. 1997: and in a written statement provided at the NRC exit for this inspection, dated June 20, 1997. All of these analyses concluded that the modification introduced no US The licensee stated that their analyses were based on industry guidance in NSAC-125. The inspectors noted that the NRC does not endorse NSAC-12 NSAC-125 provides that a small increase in the probability of failure is not considered to involve a US0. However. 10 CFR 50.59
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requires that a proposed change shall be deemed to involve a US0 if the probability of occurrence of a malfunction of equipment important to safety may be increase c. Conclusions The inspectors concluded that the licensee's safety evaluation for a modification (MAR 80-09-13-01) that was installed in 1987 was inadequate. The modification added five protective trips to each EDG control circuit, for protection from bus faults and prolonged overcurrent conditions. The added EDG trips were not bypassed during emergency operation and were not installed with two out of three coincidence logic. Thus a single failure in the added circuitry could cause an EDG to fail. The modification increased the probability of failure of the EDGs and created a US0. The safety evaluation for the modification failed to recognize the US0 and the modification was performed without obtaining the required prior NRC review and approva This ap3arent violation of 10 CFR 50.59 is identified as EEI 50-302/97-09-01, Jnreviewed Safety Question Involving Added EDG Protective Trip The inspectors also noted that in 1997, the licensee erroneously relied on NSAC-125 guidance, which the NRC does not endorse, to again determine ,
that MAR 80-09-13-01 did not introduce a US0. The inspectors concluded l that the licensee's reliance on NSAC-125 guidance indicated a weakness '
in their program for performing 10 CFR 50.59 safety evaluation In addition, the inspectors noted that the licensee had failed to update I the FSAR within two years to describe EDG protective trips added in i 1987. This apparent violation of 10 CFR 50.71 is identified as EEI ;
50-302/97-09-02. Failure to Update the FSAR to Include Added Emergency l Diesel Generator Trip ,
The inspectors further concluded that this failure to update the FSAR I and another more recent failure to update the FSAR, for a 1996 revised !
small break loss of coolant accident mitigation strategy (see EA 97-162 l and Inspection Report 50-302/97-06), indicated a weakness in the ;
licensee's control of the design base The inspectors assessed the licensee's performance, relative to this issue, in the five areas of continuing NRC concern-


e Management Oversight - Inadequate e Engineering Effectiveness - Inadequate e Knowledge of the Design Basis - Inadequate j
1317 Winewood Boulevard Tallahassee, FL 32399 0700 Joe Myers Director Div, 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 Framatome Technologies 1700 Rockville Pike, Suite 525 Rockville, MD 20852-1631
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  )istribution:
  .. Raghavan, NRR.          ;
  -'0E:EA File (BSuntners) (2LTRHD)
R. Schin, Ri!          i P. Steiner, Ril          l PUBLIC            l
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NRC Resident inspector          l U.S. Nuclear Regulatory Conrn.          :
6745 N. Tallahassee Road-Crystal River, FL 34428          .
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e Compliance with. Regulations - Inadequate e-~ Operator ~ Performance - N/A II Manaaement Meetinas '
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sSl as r, j i OAT ( ' 10 / l Y / 97 10 / t[/ 97 Nh / 97 -10 _/ \b / 97     !
X1 Exit Meeting Summary The inspection scope'and findings were summarized in an exit meeting  !
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held on June 20. 1997. Proprietary information is not contained in this ;
report. Dissenting comments were received from the licensee. The '
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licensee stated that, based on NSAC-125 guidance, they still concluded that MAR 80-09-13-01 did not introduce a US0. The inspectors noted that
; the NRC does not endorse NSAC-125, On June 24 the licensee's Director of Engineering told'the.NRC's Mr. K. Landis, at a meeting at the NRC .
headquarters. that the licensee decided to withdraw the dissentin comments and now agreed that MAR 80-09-13-01 did introduce a US PARTIAL LIST OF PERSONS CONTACTED  l Licensees J. Baumstark, Director Quality Programs  :
J. Cowan Vice President Nuclear Production  ;
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R. Grazio Director, Regulatory Affairs J. Holden Director Nuclear Engineering and Projects R. Knoll, Manager, Safety Assessment Group  -
C. Pardee, Director Nuclear Plant Operations  ,
W. Pike. Manager, Regulatory Assurance S. Powell, Senior Licensing Engineer NRC K. Landis, Branch Chief, Division of Reactor Projects, Region II S..Cahill, Senior Resident Inspector    ;
INSPECTION PROCEDURES USED IP.92903: Followup - Engineering ITEMS OPENED, CLOSED, AND DISCUSSED
 
00ened Tygg Item Number- Status Rescriotion and Reference (
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EEI 50-302/97-09-01 Open Unreviewed Safety Question Involving ,
l    Added EDG Protective Trips (paragraph E8.1)  l
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;  EEI 50-302/97-09-02 Open -Failure to Update the FSAR to i
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,    Include Added Emergency Diesel Generator Trips (paragraph E8.1)
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Closed Iygg Item Number Status Description and Reference
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IFI 96-201-14 Closed EDG Protective Trips Not Bypassed During Emergency Mode of Operation (paragraph E8.1)
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Discussed lyng Item Number Status Description and Reference none LIST OF ACRONYMS USED CFR - Code of Federal Regulations EA- - Enforcement Action EDG - Emergency Diesel Generator EEI - Escalation Enforcement Item FSAR - Final Safety Analysis Report IEEE - Institute of Electrical and Electronic Engineering IFI - Inspector Followup Item MAR - Modification Approval Record NRC - Nuclear Regulatory Commission PR - Problem Report RG - (NRC) Regulatory Guide USQ - Unreviewed Safety Question VIO - Violation l
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Revision as of 15:30, 21 January 2021

Ack Receipt of 970908 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-302/97-09 on 970905
ML20212B939
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 10/16/1997
From: Jaudon J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Richard Anderson
FLORIDA POWER CORP.
References
50-302-97-09, 50-302-97-9, EA-97-330, NUDOCS 9710280313
Download: ML20212B939 (3)
v • d • e


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October 16, 1997 EA 97 330

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Florida Power Corporation Crystal River Energy Complex Mr. Roy (SA2A)

Sr. VP, Nuclear Operations ATTN: Mgr., Nuclear Licensing 15760 West Power Line Street Crystal River. FL 34428 6708 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-302/97 09)

Dear Mr. Anderson:

Thank you for of Violation (your NOV)supplemental res)onse issued on Septem)er of September 5. 1997, concerning8.activities 1997, to our Notice conducted at ,vour Crystal River facility. We have evaluated your response and found that it meets the requirements of 10 CFR 2.201. We will examine the implementation of your corrective actions during future inspections.

We appreciate your cooperation in this matter.

Sincerely

.

Original Signed By:

J. P. Jaudon

'

Johns P. Jaudon. Director Division of Reactor Safety Docket No. 50 302 License No. DPR 72 cc: John P. Cowan. Vice President Nuclear Production (NA2E)

FPC. Crystal _ River Energy Complex 15760 West Power Line Street

. Crystal River. FL 34428-6708 cc: Continued see page 2

[E! E ,302 i

IllllllMERill Mc/

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FPC 2 cc: Continued C. G. Pardee, Director Nuclear Plant Operations (NA2C) '

FPC, Crystal River Energy Complex 15760 West Power Line Street Crystal River, FL 34428 6708 Robert E. Grazio Director Nuclear Regulatory Affairs (SA2A)

fPC, Crystal River Energy Complex 15760 West Power Line Street Crystal River, FL 34428 6708 James S Baumstark, Director Quality Programs (SA2C)

FPC, Crystal River Energy Complex 15760 West Power Line Street Crystal River, FL 34428 6708

R. Alexander Glenn, Corporate Counsel

'

Florida Power Corporation MAC - ASA P. O. Box 14042 St Petersburg, FL 33733 4042 Attorney Gent.'al Department of Legal Affairs ,

The Capitol Tallahassee, FL 32304 Bill Passetti Office of Radiation Control

,

Dept of Health and Rehab. Serv.

1317 Winewood Boulevard Tallahassee, FL 32399 0700 Joe Myers Director Div, 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 Framatome Technologies 1700 Rockville Pike, Suite 525 Rockville, MD 20852-1631

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)istribution:

.. Raghavan, NRR.  ;

-'0E:EA File (BSuntners) (2LTRHD)

R. Schin, Ri! i P. Steiner, Ril l PUBLIC l

NRC Resident inspector l U.S. Nuclear Regulatory Conrn.  :

6745 N. Tallahassee Road-Crystal River, FL 34428 .

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