ML17289B062
| ML17289B062 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 12/14/1992 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17289B060 | List: |
| References | |
| EA-92-206, NUDOCS 9212290002 | |
| Download: ML17289B062 (6) | |
Text
i NOTICE OF VZOIATION AND PROPOSED IMPOSITION OF CIVIL X'ENALTY Washington Public Power Supply System Docket No.
50-397 Washington Nuclear Project No.
2 (WNP-2)
License No.
NPF-21 EA 92 206 During an NRC inspection conducted on October 5 through 21,
- 1992, violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C.
- 2282, and 10 CFR 2.205.
The particular violations and associated civil penalty are set forth below:
I.
V'olatio s Assessed a
C vi ena t A.
10 CFR Part 50, Appendix 8, Criterion V, as implemented by the WPPSS Operational {}ualityAssurance Program Description, Section 5, states that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances, and shall be accomplished in accordance with these instructions, procedures, or drawings; and that these instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Contrary to the above, as of August 15, 1992, plant procedures for establishing reactor control rod patterns did not provide appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished, in that 1.
Plant Procedures Manual (PPM) Procedure 9.3.12, Revision 6, "Plant Power Maneuvering", paragraph 7.1.3, allowed deviations from the approved control rod withdrawal sequences after the rod sequence control system (RSCS) and the rod worth minimizer (RWM) were above the Low Power Setpoint (LPSP, at 204), but did not provide appropriate qualitative or quantitative acceptance criteria for the review and approval of the rod sequence deviations.
2.
PPM procedure 9.3.12, Revision 6, paragraph 7.1.4, "Performing a Rod Set", subparagraph b, ~Principles and Objectives", required that radial peaking be flattened in selecting control rod positions for the 92i2290002 92i2i4 PDR ADOCK 05000397 8
Notice of Violation final rod pattern, but did not provide appropriate acceptance criteria for the peaking factors.
3.
PPM 9.3.12, Revision 6, para'graph 7.1.5.c, "Power Distribution Constraints",
required that care be taken to prevent excessive
- peaking, but did not provide appropriate acceptance criteria for "excessive" peaking.
4.
PPM 9.3.12, Revision 6, paragraph 7.1.5.d, "Power Distribution Constraints",
stated that due to preconditioning limits, establishing too large a bottom peak would prevent opening of the flow control valves for recirculation pumps A and B to 20,000 and 24,000 GPM, respectively, following recirculation pump speed shift to 60 Hertz, but did not provide appropriate acceptance criteria for the peaking factors.
5.
PPM 9 3.12, Revision 6, paragraph 7'.5.d, "Power Distribution Constraints", prohibited "overly aggressive" operator actions when pulling shaper rods, but did not provide appropriate acceptance criteria for.the positioning of shaper rods.
6.
PPM 9.3.12, Revision 6, paragraph 7.1.5.e, "Power Distribution Constraints",
stated that the more time spent at low power, the more "fierce" the xenon burn would be following power increase, and required minimization of the time spent using slow speed recirculation pumps when performing a rod set following a reduction in power or prior to the second ramp in a startup.
However, it did not provide appropriate acceptance criteria for the time spent at low power using slow speed recirculation pumps for the noted conditions or for defining the "fierce xenon burn."
B.
WNP-2 Technical Specifications Section 6.2.3.1 states that the Nuclear Safety Assurance Group (NSAG) shall function to examine unit operating characteristics, NRC issuances, industry advisories, Licensee Event Reports, and other sources of unit design and operating experience information, including units of similar
- design, which may indicate areas for improving unit safety; and that the NSAG shall make detailed recommendations for revised procedures, equipment and modifications, maintenance activities, operations activities, or other means of improving unit safety to the Director of Licensing and Assurance.
Notice of Violation Contrary to the above, as of August 15, 1992, NSAG had not reviewed the industry advisory contained in a March 18,
- 1992, BWR Owners'roup (BWROG) letter, and had not made any recommendations for revising procedures, training, operating activities, or otherwise improving unit safety associated with core stability and the BNROG advisory.
C.
10 CFR Part 50, Appendix B, Criterion III, as implemented by the WPPSS Operational Quality Assurance Program Description, Section 3, states that measures shall be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of structures, systems and components.
As stated in the bases for Technical Specification 3/4.2.6, the licensee has established as a design criterion, for core stability essential to the safety-related function of the core, that operation is forbid-den in regions having calculated decay ratios of 0.9 or greater.
Contrary to the above, design evaluations, which were measures to review the suitability of application of fuel in the reactor coze, performed by the licensee for both the Cycle 7 and Cycle 8 core reloads, were not adequate.
In particular, the licensee's evaluations foz Cycles 7 and 8, as described in the Core Operating Limits Report and the Reload Analysis Repozt (RAR) for both cycles, did not adequately consider possible core power oscillations.
The RARs evaluated core hydrodynamic stability, and in both cases incorrectly determined that decay ratios for both reloads were within acceptable limits.
However, subsequent calculations indicated a core-vide decay ratio of 1.05 and an out-of-phase decay ratio of 1.0 for the operating conditions at the time of the August 15 power oscillation.
This is a Severity Level IIIproblem (Supplement I).
Civil Penalty
$75,000.
II. Violation ot Assessed a
C v 1 Pe a t Technical Specification 4.0.4 states that entry into an operational condition or other specified applicable condition shall not be made unless the surveillance requirements associated with the Limiting Condition for
Notice of Violation Operation have been performed within the applicable surveillance interval, or as othervise specified.
Technical Specification 3.2.2 states that the following requirement is applicable in Operational Condition 1, when thermal power is greater than or equal to 25 percent of rated thermal power:
"The APRM flow biased simulated thermal power-upscale scram trip setpoint (S) and flow biased neutron flux-upscale control rod block trip setpoint (Srb) shall be established according to the following relationships:
i Set o
owab e Va u S < (0. 66W + 514) T S < (0. 66W + 54%) T Srb < (0 ~ 66W + 424) T Srb < (0 ~ 66W + 454) T vhere:
S and Srb are in percent of RATED THERMAL POWER W ~ Loop recirculation flow as a percentage of loop recirculation flow vhich produces a rated core flow of 108.5 million lbs/hr T
Lowest value of the ratio of FRACTION OF RATED THERMAL POWER divided by the MAXIMUMFRACTION OF LIMITING POWER DENSITY.
T is always less than or equal to 1."
Contrary to the above, several thermal limits printouts indicated on August 14 and 15, 1992, that "S" and "Srb" were less conservative than the Allowable Values, and the licensee did not make appropriate flov biased setpoint ad)ustments before exceeding 25 percent pover.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, the Washington Public Power Supply System (Licensee) is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U. S. Nuclear Regulatory Commission, within 30 days of the date of this Notice of Violation and Proposed Imposition of Civil Penalty (Notice).
This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each alleged violation:
(1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, or if denied, the reasons
- why, (3) the corrective steps that, have been taken and the results achieved, (4) the corrective steps that will be taken to avoid further violations, and (5) the date when full compliance will be achieved.
If an adequate reply is not
received vithin the time specified in this Notice, the Commission may issue an order or a demand for information as to vhy the license should not be modified, suspended, or revoked or vhy such other action as may be proper should not be taken.
Consideration may be given to extending the response time for good cause shown.
Under the authority of Section 182 of the Act, 42 U.S.C.
- 2232, this response shall be submitted under oath or affirmation.
Within the same time as provided for the response required above under 10 CFR 2.201, the Licensee may pay the civil penalty by letter addressed to the Director, Office of Enforcement, U.S.
Nuclear Regulatory Commission, vith a check, draft, money order, or electronic transfer payable to the Treasurer of the United States in the amount of the civil penalty proposed above, or may protest imposition of the civil penalty in whole or in part, by a vritten answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission.
Should the Licensee fail to answer vithin the time specified, an order imposing the civil penalty will be issued.
Should the Licensee elect to file an answer in accordance vith 10 CFR 2.205 protesting the civil penalty, in whole or in part, such answer should be clearly marked as an "Answer to a Notice of Violation"'nd may:
(1) deny the violations listed in this Notice, in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons vhy the penalty should not be imposed.
In addition to protesting the civil penalty in whole or in part, such an answer may request remission or mitigation of the penalty.
In requesting mitigation of the proposed penalty, the factors addressed in Section VI.B.2 of the NRC Enforcement Policy should be addressed.
Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition.
The attention of the Licensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.
Upon failure to pay any civil penalty due which subsequently has been determined in accordance vith the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney
- General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C 2282c.
The response noted above (Reply to a Notice of Violation, letter with payment of civil penalty, and Answer to a Notice of Violation) should be addressed to:
Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C. 20555 vith a copy to the Regional
Notice of Violation Administrator, U.S. Nuclear Regulatory Commission, Region V, and a copy to the NRC Senior Resident Inspector, Washington Nuclear Project No. 2.
Dated at Walnut Creek, California This fgrw day of December, 1992