IR 05000219/1993080
| ML20044E197 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 05/17/1993 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | J. J. Barton GENERAL PUBLIC UTILITIES CORP. |
| Shared Package | |
| ML20044E200 | List: |
| References | |
| EA-93-055, EA-93-55, NUDOCS 9305240061 | |
| Download: ML20044E197 (8) | |
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MAY 171993
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Docket No. 50-219
License No. DPR-16 EA 93-055 I
Mr. John Vice President and Director GPU Nuclear Corporation
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Oyster Creek Nuclear Generating Station Post Office Box 388 Forked River, New Jersey 08731
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Dear Mr. Barton:
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SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL t
PENALTY - $50,000 (NRC Inspection Report No. 50-219/93-80)
This letter refers to the NRC Augmented Inspection Team conducted on January 26 through February 2,1993, at the Oyster Creek Nuclear Generating Station, Forked River, New Jersey.
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The inspection report was sent to you on February 23,1993. The inspection was conducted to
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review the circumstances associated with an event that occurred at Oyster Creek between January 23 and 25,1993. Specifically, the temperature of the reactor water increased to levels -
above 212 degrees F, resulting in the plant being in a condition prohibited by the technical specifications (TS). This event was identified and reported to the NRC by your staff on January 25,1993. On April 2,1993, an enforcement conference was conducted with you and i
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members of your staff to discuss the event, its causes, your corrective actions, and the potential violations.
On January 25,1993, while the facility was in a refueling outage with fuel in the reactor vessel, the reactor vessel metal temperature was found to be above 212 degrees F indicating that reactor water temperature may have inadvertently increased above that temperature. This condition was detected by your staff following performance of a main steam line isolation valve (MSIV) local
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leak rate test (LLRT). Your staff also subsequently confirmed that reactor water temperature had exceeded 212 degrees F. When reactor water temperature exceeds that level, the plant TS i
require that specific safety systems be operable, primary containment integrity be maintained, and a Shift Technical Advisor (STA) be on duty. These requirements were not met. After identification of this condition, the operators promptly increased shutdown cooling flow through the core, and reduced the temperature to less than 212 degrees F.
CERTIFIED MAIL RETURN RECEIPT REOUESTED
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Mr. John MAY 171993
I A temporary procedure change (TPC) to the shutdown cooling system operating procedure led to this condition. The revised procedure, when implemented on January 23, 1993, allowed performance of the MSIV LLRT simultaneously with reactor recirculation pump maintenance
based on a draft engineering analysis for shutdown cooling. To allow the recirculation pump
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maintenance, all of the recirculation pumps were secured, and to create a post-MSIV LLRT vent j
path, the reactor water level was lowered to 165 inches above the top of the active fuel (a level
below the normally required level of 185 inches). One recirculation loop was kept open to l
ensure communication between the water in the reactor vessel annulus and the water within the i
core shroud. This configuration contributed to the increase in water temperature by allowing some of the shutdown cooling flow to bypass the active fuel. This was not accounted for in the
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TPC which, rather than requiring the minimum shutdown cooling flow rate specified in the
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engineering analysis, only required that both shutdown cooling pumps be in operation.
The NRC is concerned that the TPC was approved for use without ensuring that adequate f
shutdown cooling system flow existed to prevent reactor coolant " heat up".
Although the
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procedure change was being implemented for the first time based on a draft engineering analysis, l
no precautions or monitoring criteria, such as requiring a minimum shutdown cooling flow rate j
or the monitoring of reactor vessel metal temperatures, were specified in the TPC to ensure i
adequate shutdown cooling and decay heat removal. Implementation of the TPC with these process deficiencies constituted a violation of the 10 CFR Part 50, Appendix B,~ Criterion V, i
which requires that the activities affecting quality be prescribed by procedures appropriate to the
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circumstances.
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Although your Licensee Event Report (LER 93-002) identified personnel error-to be the root
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cause of the violation, as discussed at the enforcement conference, the NRC determined that the i
inadequate procedure was not solely attributable to an individual personnel error. A significant I
contributing factor was a programmatic weakness in the TPC process that allowed this TPC to l
be implemented without technical and safety reviews commensurate with the scope of the j
change. That weakness stems from the failure to have comprehensive guidance available as to
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what constitutes a " change of intent" which is the threshold for in-depth review prior to the
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approval of a TPC. The NRC recognizes that there are differences across the industry as to the l
definition of " change of intent." However, evaluating the intent of specific procedural steps l
against the overall procedure purpose, as presented by your staff at the enforcement conference,
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ever be changes of intent using that standard. The NRC notes that as part of your corrective l
actions you intend to address this issue. Given its potential effect on every plant procedure, it
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is expected that this issue will be resolved in a careful and expeditious manner.
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MAY 171993 i
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i Mr. John NRC IE Circular No. 81-11 and General Electric (GE) Service Information Letter (SIL) No.
357, issued in June 1981, identified the possibility of reactor coolant temperature stratification
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if recirculation was secured and shutdown cooling was insufficient. The SIL recommended monitoring of reactor vessel temperature. You had identified before that a reactor level of 185
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inches should be maintained when no recirculation pumps were running, but the TPC revised this requirement without any compensating measures as recommended in the SIL. This industry information, if followed, would have provided a prior opportunity to prevent the increase in reactor coolant temperature.
The NRC recognizes that the safety impact of the plant " heat up" was low in that the reactor
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core remained adequately cooled throughout the event and there was no fuel damage or release
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of radioactivity.
Nevertheless, a progmmmatic weakness in your TPC process allowed implementation of this substantive TPC after minimal review and led to your failure to maintain the plant within TS limits. This weakness is safety-significant and is a regulatory concern because it permits limited and perhaps inadequate technical and safety reviews before a
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substantive change is implemented. Therefore, in accordance with the " General Statement of
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Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy) 10 CFR Part 2, Appendix C, this violation has been categorized at Severity Level III.
The NRC also recognizes that subsequent to the identification of the violation, you took immediate corrective actions to restore adequate core cooling and initiated three separate reviews
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of the event. In addition, you implemented interim changes to the TPC process to prevent recurrence. These corrective actions, which were described either during the inspection or at the enforcement conference, included, but were not limited to: (1) establishing' an interim requirement to complete a technical review, and independent safety review (if required) prior
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to implementation of a TPC; (2) requiring the Group Shift Supervisors to challenge the need for specific TPCs so as to minimize their use; (3) requiring that the STA review all TPCs prior to implementation; (4) establishing guidance on what constitutes a change of the intent of a
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procedure; (5) providing additional guidance on the safety review / determination process to help
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determine the potential impact of a proposed change on nuclear safety; (6) determining the need for long term revisions to the TPC process; and (7) revising the shutdown cooling procedure to
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address all prior concerns.
While the. proposed corrective actions were acceptable, the completion status for the longer term actions noted at the time of the enforcement conference
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did not reflect an aggressive schedule and some of these actions were not yet defined.
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MAY 171993
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Mr. Jolin l
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To emphasize the importance of (1) maintaining proper control of activities affecting quality so
as to ensure the plant is operated and maintained in accordance with the TS limits, and l
(2) ensuring that changes to approved plant procedures receive a level of review commensurate l
with their significance, I have been authorized, after consultation with the Director, Office of l
Enforcement, and the Deputy Executive Director for Nuclear Reactor Regulation, Regional
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Operations and Research, to issue the enclosed Notice of Violation and Proposed Imposition of l
Civil Penalty (Notice) in the amount of $50,000 for the violation set forth in the enclosed l
l Notice.
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i The base civil penalty amount for a Severity Level III violation is $50,000. The escalation and
mitigation factors set forth in the Enforcement Policy were considered and, on balance, the base
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civil penalty was neither escalated nor mitigated. The violation was identified by your staff, and l
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therefore, 50 percent mitigation of the base civil penalty on this factor was appropriate. In
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addition, mitigation in the amount of 50 percent of the base penalty was appropriate based on l
your good performance in shutdown risk management.
Full mitigation under licensee
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performance factor was not applied because it was not supported by your overall performance,
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as represented by SALP Category 2 ratings in the areas of operations and engineering / technical l
support. The civil penalty was also escalated by 100 percent of the base civil penalty based on
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the prior opportunity to prevent the violation which was provided to you by NRC IE Circular l
No. 81-11 and GE SIL No. 357. The other adjustment factors in the Policy were considered i
and no further adjustment to the base civil penalty was considered appropriate.
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You are required to respond to this letter and should follow the instructions specified in the
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enclosed Notice when preparing your response. In your response, you should document the
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specific actions taken and any additional actions you plan to prevent recurrence. After reviewing
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your response to this Notice, including your proposed corrective actions and the results of future
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inspections, the NRC will determine whether further NRC enforcement action is necessary to
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ensure compliance with NRC regulatory requirements.
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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and j
its enclosuse will be placed in the NRC Public Document Room.
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MAY 171993
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Mr. John !
The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction
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Act of 1980, Pub. L. No.96-511.
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Sincerely, Gr! jni si;ad BT.
E Thatnas T. lWh.a.
Thomas T. Martin Regional Administrator
Enclosure: Notice of Violation and Proposed Imposition
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of Civil Penalty
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e MAY 171993
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Mr. John