ML20027B359
| ML20027B359 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 08/25/1982 |
| From: | Linder F DAIRYLAND POWER COOPERATIVE |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20027B354 | List: |
| References | |
| LAC-8525, NUDOCS 8209200309 | |
| Download: ML20027B359 (6) | |
Text
.
D
/RYLAND k
COOPERAT/VE
- P.O. BOX 817
- 2615 EAST AV SOUTH
- LA CROSSE. WISCONSIN S4601 August 25, 1982 In reply, please refer to LAC-8525 DOCKET NO. 50-409 Mr. James G. Keppler, Regional Administrator U. S. Nuclear Regulatory Commission Directorate of Regulatory Operations Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
SUBJECT:
DAIRYLAND POWER COOPERATIVE LA CROSSE BOILING WATER REACTOR PROVISIONAL OPERATING LICENSE NO. DPR-45 IE INSPECTION REPORT 50-409/81-23
REFERENCES:
(1) NRC Letter, Keppler to Linder, dated July 27, 1982 (2) DPC Letter, Linder to Keppler, LAC-7993, dated December 28, 1981
,(3) DPC Letter, Linder to Keppler, LAC-8007 dated January 6,1982 (4) DPC Letter, Linder to Keppler, LAC-8470, dated August 6, 1982 1
Dear Mr. Keppler:
This letter constitutes the written statement required in reply to the December 22, 1981 - March 31, 1982 Inspection Report (Reference 1), which was received August 2, 1982. The Notice of Violation listed three items of j
noncompliance. The first item was initially reported to the NRC in Reference 2, with follow-up information provided in References 3 and 4.
NRC ITEM 1 Technial Specification 4.2.2.4.e states:
"The Forced Circulation loops shall not be pressurized unless their tempemture is above 70*F and shall not be pressurized above 280 peig unless their tempenture is at least 130 *F. '
Technical Specification 6.8.1 states, in part, " Written procedures shall be established, implemented and mintained."
Step 16 of Section 2.3.2 of the norml plant shutdown procedure in Volume I of the Opentions Manual states, in part, "Every 15 minutes during reactor cooldoon record the " Reactor Vessel Wall Tempenture Recorder" on the " Reactor Heatup and Cooldoon Data Sheet." Do not exceed the limits of Section 2.1.3 Step 2. " Section 2.1.3 Step 2 restricts cooldoun mte at the forced circulation suction of 60*F/hr.
WP-1.6.2 8209200309 820914 PDR ADOCK 05000409 AUG 3 0 1982 G
Mr. James G. Keppler, Regional Administrator August 25. M32 U. S. Nuclear Regulatory Commission LAC-8525 Annunciator alarm response in Volume I of the Opentions Manual for Alarme E2-1 and E2-2 (FC Pump 1A and 1B Tripped) states, in part, under Immediate Action Step 3,
" Ensure tempenture in the shutdown loop remaine greater than 200*F by reducing seat inject flou into the shutdoun pump to minimum allouable D/P."
Contmry to the above, on December 24, 1981, chile recovering from the scram on h cember 23, 1981, an unintentional cooldoon of the 1B forced circulation loop to 86*F occurred chile loop pressure 01e greater than 280 peig. This violation of Technical Specification 4.2.2.4.e resulted from the foltooina violations of the above mentioned procedures.
Plant personnel failed to take the required 15 minute reading for the 1A and 1B forced circulation loop suction tempemtures.
Plant personnel failed to restrict the cooldoon mte on the 1B forced circulation loop to 60*F/hr.
Plant personnel increased mther than decreased the seat injection flou to the shutdoon pumpe.
This is a Severity Level IV violation (Supplement I).
DPC RESPONSE Corrective Action Taken and Results Achieved Procedures were examined for their adequacy to handle the event. The alarm response procedure for Annunciator E2-2 "FC Pump 18 Tripped" does state, " Ensure temperature in the shutdown loop remains greater than 200 F by reducing seal inject flow into the shutdown pump to minimum allowable D/P."
There were a considerable number of alarms present, however, for two of which the procedure response was to increase seal injection flow.
Several procedures were changed to provide more detail to improve response in the event of a similar reoccurrence.
Training was provided to all operations personnel on the lessons learned during this incident.
Specific attention was focused on the explanation of the Forced Circulation Pumps behavior and what errors had been made.
The Forced Circulation Pumps need not be in operation for safe recovery from a scram.
Additional corrective actions taken included modification of the operator log sheets. The logs now specify during what conditions specific readings need to be taken. This action should help prevent operators from missing changes in a parameter which could be important. Memos were sent to Operations Department Personnel concerning time marking of charts and keeping of the Control Room log book to improve both, to facilitate review of an incident.
WP-1.6.2 _.
Mr. James G. Keppler, Regional Administrater August 25, 1982 U. S. Nuclear Regulatory Commission LAC-8525 Corrective Action to be Taken to Avoid Further Noncompliag.e_
A method of prioritizing alarms is being developed to highlight those of safety consequence to help the operators channel their effort when numerous alarms annunciate. Therefore, in the future, if alarm response procedures require conflicting actions, those with safety significance will be presented with higher priority.
Date Full Compliance Achieved The procedure changes were accomplished in February,1982. Training was completed January 21, 1982.
NRC Item 2 Technical Specification 6.8.1 requires, in part, that critten procedures be implemented covering activities referenced in Appendim A of Regulatory Guide 1.33, Revision 2.
Appendix A of Regulatory Guide 1.33, Revision 2, references in Pamgraphe 4.l and 4.m opention of the min steam system.
Plant procedures contained in Sectior.e 2.1.3, 2.3.2, 3.3.1.3 of Volume I of the Opentione Manual and response procedures for Alarms A1-3, B14-3 and D2-3 provide for the use of the min steam bypass valve during normal plant startups and shutdouns and during times when the reactor coolant eyotem pressure is increasing above an established value but indicate that the tulve is normbly closed during power opemtion. '(Theen plant procedures are consistent with the procedures and eyetem descriptione contained in the safety analysis report.) Neither the plant procedures nor the safety analysis report indicate that the min steam bypass valve vill be used to bypass all of the gene nted steam directly to the condenser during power ope mtion.
Technical Specification 2.10.3.3 requires that the nuclear instrumentation be capable of initiating semm actions as specified in Technical Specification Table 1. Table 1, Item 1, requires the setpoint of the ecmm for Reactor Pover-High to be in accordance uith Table 4.0.2.2.1-1. Table 4.0.2.2.1-1, Item 6.b, requires the trip setpoint for the Reactor Pover-High to be < 120% of mted thermt pouer whenever indicated power is above 15%.
Contmry to the above described plant procedures and safety analysie l
report provisione for use of the min steam bypase valve, on March 16, 1981, the reactor 02e opemted at appromimtely 87% indicated pooer for l
approximately 12 minutes with all of the genented steam bypassed to the condenser via the min steam bypass valve. Additionally, a violation of Technical Specification 2.10.3.3 resulted since this made of opemtion involved a lose of all feedoater heating which rendered the nuclear instrumentaiton incapable of accumtely detecting power (i.e., the actual pocer oas 102% when the indicated pocer Das 87%) and initiating a somm at
< 120% of mted thermi pover.
This is a Severity Level IV violation (Supplement I).
WP-1.6.2.
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_Mr. James G. Keppler, Regional Administrator August 25, 1982 U. S. Nuclear Regulatory Commission LAC-8525 DPC RESPONSE Corrective Action Taken and Results Achieved The mechanical problem which caused the incident for which the corrective action taken involved bypassing the steam through the main steam bypass valve has been fixed. The problem was that small particles in the turbine relay oil were getting caught between the turbine governor control system secondary relay's piston and sleeve, affecting the control of the turbine steam inlet valves.
During May,1981, the turbine oil was cleaned using a portable filtration system. No further problems with the secondary relay manifested themselves following the filtration. Also, a new on-line oil filter assembly was installed during the 1982 refueling outage.
The report on this incident was reviewed by all members of the Opera' ions Department. As discussed, under Item 3 below, the procedure which was written following the incident, allowing the method used on March 16 to be utilized as corrective action to a similar occurrence, has been withdrawn.
There is one circumstance, other than those mentioned, in which reactor operation with substantial steam flow through the main steam bypass valve is expected.
If a tornado is sighted within 10 miles of the plant, heading towards it, a plant procedure requires reduction of power to 20 MWe, so the plant can handle a loss of load incident and supply house loads.
In that condition, the majority of steam flow would be through the main steam bypass valve. This procedure was developed in response to a -
request by the Advisory Committee for Reactor Safety (ACRS to AEC, Okrent to Seaborg, dated November 17,1966).
Corrective Action to be Taken to Avoid Further Noncompliance No further action is needed to avoid a repeat occurrence.
Date Full Compliance Achieved December 2, 1981 NRC ITEM 3
"(a)(1) The hold r pf a license authorizing 10 CFR 50.59 etates, in part, e
l opeation pf a production or utilization facility may...(ii) make changes in the procedures as described in the safety analysis report...without prior Conniesion approvat, untees the proposed change... involves a change in the Technical Specificatione incorporated in the license on an unreviewed safety question...(b) The licensee shalt maintain recorde pf...
changes in procedurea made pursuant to this section...
These recorde shall include a critten safety evaluation which provides the bases for the determination that the change...does not involve an unreviewed safety question..." Sectione 8.3 and 13.4 of the safety analysis report specify i
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. Mr. James G. Keppler, Regional Administrator August 25, 1982 U. S. Nuclear Regulatory Commission LAC-8525 the opentional uses of ths min steam bypaso valve and those uses do not include use of the n1tve,;o bypass the total steam floo directly to the condeneer during power opemtion.
Procedurce and changes thereto that are requried for the opemtion of the main eteam system are among those procedures chich are required by Technical Specification 6.8.2 to be revieced by the Opention Revico Committee prior to implementation.
Contmry to the above, on March 17, 1981, Revision 1 to Opentions Memomndum No. WC-86 me implemented (issued) changing the procedure for the opention of the min steam bypass valve (i.e., attooing the valve to be used to bypass the total steam floo directly to the condenser during high power opemtion) without a safety evaluation being performed to determine if an unrevieved safety question me involved and without revieu by the Ope ntion Reviev Committee.
This is a Severity Level IV violation (Supplement I).
DPC RESPONSE Corrective Action Taken and Results Achieved On March 17, 1981, Revision 1 to Operations Memorandum No. DPC-86 was approved by the Operations Review Committee without a safety analysis, since Operations Memorandums were not required to have safety analyses.
In April,1981, in response to concerns expressed by the NRC Resident Inspectors, Revision 2 of Operations Memorandum No. DPC-86 was issued, which deleted the portion added on March 17. On April 29, 1982, an Operations Manual change, complete with safety analysis, was reviewed by the ORC. This change incorporated the alternate method of taking the turbine off-line to recover from the turbine governor control system malfunction into the response procedure to Annunciator B14-3, " Main Steam Bypass Valve Not Closed" which was normally the first alarm indicating commencement of the problem. On July 16, 1981, the procedure was modified following analysis by a consulting firm.
On December 2,1981, following the expression of additional concerns by the NRC, a temporary change was instituted, removing the alternate recovery method from the procedure. The temporary change was fully incorporated into the Operations Manual by a procedure change reviewed by the ORC in July 1982. The procedure will not be reinstituted unless the safety analysis is submitted to the Nuclear Reactor Regulation Branch of the NRC for review.
All Operations Memorandum were cancelled as of July,1982, after being incorporated into formal procedures, if necessary. Operations Memorandum will no longer be used in lieu of procedures. Any memorandums issued will solely provide information.
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'. Mr. James G. Keppler, Regional Administrator August 25, 1982 U. S. Nuclear Regulatory Commission LAC-8525 Futher Correction Action to be Taken to Avoid Further Noncompliance No further correct *ye action is necessary. All members of the LACBWR management staff have been reminded of the need for actions to be properly analyzed prior to being implemented. The restriction of Operations Memorandums for information only has eliminated an avenue of implementation without proper evaluation.
Date Full Compliance Achieved December 2,1981 If there are any questions, please contact us.
Yours truly, DAIRYLAND POWER 0 PERATIVE Frank Linder, General Manager FL:LSG:eme cc: Resident Inspector WP-1.6.2.
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