ML20033B234
| ML20033B234 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 10/22/1981 |
| From: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20033B231 | List: |
| References | |
| EA-81-080, EA-81-80, NUDOCS 8112010077 | |
| Download: ML20033B234 (4) | |
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APPENDIX NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Dairyland Power Cooperative Docket No. 50-409 Lacrosse Boiling Water Reactor License No. DPR-45 EA 81-80 As a result of an inspection conducted at Lacrosse Boiling Water Reactor, Genoa, Wisconsin, during the period May 1-31, 1981, it appears that several violations of NRC requirements have occurred.
The most serious concern relates to the modification of a pressure sensing line from the Containment Building which was made on~ April 1, 1981, and removed on May 19, 1981.
The installation of this modification resulted in the temporary loss of the automatic actuation signal for one of two High Pressure Core Spray Pumps, one of two Low Pressure Coolant Injection Pumps, and one of two Alternate Core Spray Valves.
The installation also resulted in a system not meeting applicable quality standards being attached to a Containment Building pressure sensing line.
In this case the action was repetitive of a similar modification for which the licensee was found in noncompliance.
Because Nuclear Regulatory Commission approval should have been obtained prior to making the modification, since it involved violation of the Technical Speci-fications, and because of the safety significance of inadequate implementation of procedures controlling facility changes, the Nuclear Regulatory Commission proposes to impose a civil penalty in the amount of $38,000.
In accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7,1980), anti pursuant to section 234 of the Atomic Energy Act of 1954, as amended ("Act"), 42 U.S.C. 2282, PL 96-203, and 10 CFR 2.205, the particular violation and associated civil penalty is set forth in Section I below:
I CIVIL PENALTY VIOLATION 10 CFR 50.59(a)(1) states, in part, "The holder of a license authorizing operation of a prcduction or utilization facility may (i) make changes in the facility as described in the safety analysis report,...without prior Commission approval, unless the proposed change, test or experiment involves a change in the technical specifications incorporated in the license..."
Technical Specification 4.2.2.15 states, in part, "One core spray pump may be removed from service for maintenance provided that all control rods are fully inserted, the reactcr pressure is less than 85 psig, and the ' Control Power' key switch is in the '0FF' position."
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Appendix (Continued) Technical Specification 4.2.2.18 states, in part, "The low pressure coolant injection system (Alternate Core Spray) shall be available for
'utomatic operation except at times when the reactor is shut down and the syste depressurized to approximately atmospheric pressure."
Technical Specification 6.8.1 requires procedures be followed.
Procedure ACP-04.1, " Design and Facility Changes," defines the requirements for initiating and processing a Facility Change from concept through subsequent design and design verification.
Procedure ACP-04.1 requires, in part, the following:
1.
Section 4.12 - The Quality Assurance Department shall review all Facility Changes to assure that, as a minimum, original system quality is maintained, and adherence to the LACBWR QA Program is obtained.
2.
Section 4.16 - The 0perations Review Committee shall review the Facility Change Design and all associated documents.
3.
Section 4.17 - All approvals shall be obtained prior to implemen-tation of the Facility Change.
10 CFR 50, Appendix J, Section IV.A, requires any replacement of a com-ponent which is part of the primary containment boundary be followed by an applicable leakage test.
Contrary to the above, on April 1,1981, with ;,he plant operating at 85%
power the licensee disabled for approximately one minute on two occasions the automatic initiation signal to 1B High Pressure Core Spray Pump, to 1B High Pressure Service Water / Alternate Core Spray Pump (Low Pressure Coolant Injection), and to the A.C. Alternate Core Spray Valve and thereby violated Technical Specification 4.2.2.15 and Technical Specification 4.2.2.18.
This occurred when the isolation valve between the Containment Building and Pressure Switch 37-25-702 was closed during the modification of the sensing line between the Containment Building isolation valve and the switch.
The modification was made without seeking prior Commission approval; without conducting an evaluation of the safety significance of the change in order to determine whether a change to Technical Specifi-cations or an unreviewed safety question was involved; and without following Procedure ACP-04.1 which governs facility changes and requires an Operations Review Committee review, application of the QA Program, and complete approval of a Facility Change.
In addition, during the modifi-cation, a portion of the Containment Building pressure sensing line
Appendix (Continued) (i.e., component which is part of the primary reactor containment boundary) was replaced and the replacement was not followed by an applicable leakage test.
This is a Severity Level III violation (Supplement I).
(Civil Penalty - $38,000).
II VIOLATIONS NOT ASSESSED CIVIL PENALTIES A.
Technical Specification 4.0.2.2.1 states, "The reactor safety system reactor shutdown instrumentation setpoints shall be set consistent with the Trip Setpoint values shown in Table 4.0.2.2.1-1 and LSSS curves of Figure 4.0.2.2.1-1."
Table 4.0.2.2.1-1, Item 8, requires the setpoint for Reactor Power-to-Forced Circulation Flow to be 148.3%.
Contrary to the above, during the period September 1973 to April 1981 on 72 occasions the trip setpoints for both Power-to-Flow Channels were set to values in excess of 48.3% and on 47 occasions the trip setpoint for one of the channels was set to a value in excess of 48.3%.
The maximum amount the setpoints exceeded the limit was 0.7%.
This is a Severity Level IV violation (Supplement I).
B.
Technical Specification 4.2.2.22.g states, in part, "In Operational Condition 1 or 2, with THERMAL POWER changed by more than 15% of RATED THERMAL POWER within one hour, perform the sampling and analysis requirements of Item 1c and 4c of Table 4.2.2.22-1."
Items Ic and 4c require respectively, that a gross beta and gamma activity deter-mination and an isotopic iodine analysis be made for samples taken two to six hours following the power level change.
Contrary to the above, on two occasions on March 16, 1981, the Thermal Power was changed by approximately 19% and the sampling and analysis requirements of Items Ic and 4c of Table 4.2.2.22-1 were not performed.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Dairyland Power Cooperative is hereby required to submit to this office within thirty days of the date of this 1
Notice a written statement or explanation, including for each alleged violation:
(1) admission or denial of the alleged violation; (2) the reasons for the violation if admitted; (3) the corrective steps which have been taken and the results achieved; (4) the corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved.
Consider-ation may be given to extending the response time for good cause shown.
Under the authority of Section 182 of the Act, 42 USC 2232, this response shall be submitted under oath or af.firmation.
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Appendix (Continued) Within the same time as provided for the response required above under 10 CFR 2.201, Dairyland Power Cooperative may pay the civil penalty in the cumulative amount of Thirty-eight Thousand Dollars or may protest imposition of the civil penalty in whole or in part by a written answer.
Should Dairyland Power Cooperative fail to answer within the time specified, this office will issue an Order imposing the civil penalty in the amount proposed above.
Should Dairyland Power Cooperative elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, such answer may:
(1) deny the violation listed in this Notice in whole or in part; (2) demonstrate extenuating circumstances; (3) show error in this Notice; or (4) show other reasons why the penalty should not be imposed.
In addition to protesting the civil penalty in whole or in part, such answer may request remission or mitigation of the penalty.
Any 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 by specific reference (e.g., giving page and paragraph numbers) to avoid repetition.
Dairyland Power Cooperative's attention 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 has been subsequently deter-mined in accordance with 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. 2282.
FOR THE NUCLEAR REGULATORY COMMISSION wd, Victor Stell, Jr.,
irector Office of I spectio'n and Enforcement Dated at Bethesda, Maryland this 22nd day of October, 1981 l
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