ML20198N621

Notice of Violation from Insp on 971026-1129.Violation Noted:On 971105,licensee Failed to Perform Adequate Se,Per 10CFR50.59 for Functional Test Procedure for B Emergency Diesel Generator Power Upgrade & Radiator Replacement Mods

ML20198N621
Person / Time
Site:	Crystal River
Issue date:	12/29/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20198N614	List: ML20198N612 ML20198N621 ML20198N627
References
50-302-97-17, NUDOCS 9801210147
Download: ML20198N621 (2)

See also: IR 07100026/2011029

Text

NOTICE OF VIOLATION

Florida Power Corporation

Docket No. 50-302

Crystal River Unit 3

License No. DPR-72

During NRC ins)ections conducted on October 26 through November 29. 1997,

violations of iRC requirements were identified.

In accordance with the

" General Statement of Policy and Procedure for NRC Enforcement Actions." NUREG 1600, the violations are listed below:

A.

10 CFR 50.59 states that a licensee may make changes in procedures as

described in the safety analysis report or may conduct tests not

described in the safety analysis report. without prior NRC approval.

unless the proposed change or test involves a change in the technical

specifications incorporated in the license or an unreviewed safety

question.

The licensee must maintain records of changes to procedures

or of tests conducted, including a written safety evaluation which

provides the bases for the determination that the change, test. or

experiment does not involve an unreviewed safety question.

Contrary to the above, on November 5. 1997, the licensee failed to

perform an adequate safety evaluation. per 10 CFR 50.59 for the

functional test procedure for the "B" emergency diesel generator power

Ungrade and radiator replacement modifications. MAR 97-05-15-01. in tnat

tIleevaluationfailedtorecognizethatallowableoperatingparameters

had been ciianged from those in the reviewed and approved surveillance

procedure incorporated in the test procedure.

This resulted in the lack

of evaluation for the changes in the procedure.

This is a Severity Level IV Vioistion (Supplement 1).

B.

10 CFR 50. Appendix B. Criterion III. Design Control. requires in part,

that measures be established to assure that appitcable regulatory

requirements and the design basis. as defined in 10 LFR 50.2.

Definitions, and as specified in the license application, are correctly

translated into specifications, procedures, and instructions.

Tiicse

measures shall include provisions to assure that appropriate quality

standards are specified and included in design documents and that

deviations from such standards are controlled.

In addition, the design

control masures shall provide for verifying or checking the adequacy of

design, such as by the performance of design reviews.

Contrary to the above. in December 19e4. the licensee incorrectly

translated design specifications and removed thermal relief valves from

several heat exchangers when they incorrectly assumed that these valves

were redundant. The valves were needed to protect components in the

Decay Heat Closed Cycle Cooling (DC) and Nuclear Services Closed Cycle

Cooling (SW) systems from thermal overpressurization.

In addition, as

of November 19, 1997, under Modification Approval Record 96-10-04-02.

Enclosure 1

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which installed the missing relief valves-and replaced other

inadequately sized relief valves, an erigineer overlooked the replacement

of existing valve DCV-109 when preparing tM work requests to install

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the valves.

Because of this oversight. DCV-109 was not included in the

_ design change package and therefore, not replaced in the system.

Closure of the design change package and closure of the associated

restart issue failed to detect the oversight.

This is a Severity Level IV Violation (Supplement 1).

Pursuant to the provisions of 10 CFR 2.201. Florida Power Corporation is

hereby required to submit a written statement or explanation to the U.S.

Nuclear Regulatory Commission. ATTN: Document Control Desk. Washington, DC

20555 with a copy to the Regional Administrator. Region II, and a copy to the

NRC Resident Inspector, at Crystal River, 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 a 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 corrective steps that have been taken and

the results achieved, (3) the corrective steps that will be taken to avoid

further violations, and (4) the date when full como11ance will be achieved.

Your response may reference or include previous docketed correspondence if

the correspondence adequately addresses the recuired response. If an adequate

reply is not received within the time specifiec

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

3 roper

should not be taken. Where good cause is shown, consideration will

3e given

to extending the response time.

Because your res)onse will be placed in the NRC Public Document Room (PDR)

to

the extent possi)le, it should not include any personal privacy. 3roprietary,

or safeguards information so that it can be placed in the PDR witlout

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 withleld 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 29th day of December 1997

Enclosure 1

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