ML20052A193
| ML20052A193 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/29/1982 |
| From: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20052A191 | List: |
| References | |
| EA-82-039, EA-82-39, NUDOCS 8204270563 | |
| Download: ML20052A193 (3) | |
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.o APPENDIX,
NOTICE OF VIOLATION AND PROPOSED IMPOSITION DF CIVIL PENALTIES' Tennessee Valley Authority Docket No. 50-378 Sequoyah Nuclear Plant Unit 2 License No. DPR-79 EA 82-39 As a result of a special inspection conducted on December 29, 1981 at Sequoyah Nuclear Plant Unit 2 in Hamilton County, Tennessee, it appears that several violations of the NRC requirements occurred.
NRC concerns regarding these vio-lations were. discussed in a telephone conversation between Mr. J. A. Coffey, TVA Assistant Director of Nuclear Power, and Mr. R. D. Martin, Deputy Regional Administrator, NRC Region II, on December 23, 1981.
TVA responses to NRC con-cerns were discussed in an Enforcement Conference held at Region II on January 6, 1982.
In accordance with Technical Specifications, the licensee established rod with-drawal limit curves based on boron endpoint determinations and isothermal temperature coefficient measurements.
The curve limitations were to be<used until a burnup of 1000 fu!D/l1TU had been achieved.
However, operational < person-nel were not adequately instructed to follow the curves during startup nor were the curves incorporated into startup procedures.
On December 21, during the first normal startup following low power physics testing, the estimated critical point was calculated without reference to rod withdrawal limits.
The reactor was then brought to 3 percent power with no assurance that moderator temperature coefficient was less positive than 0 delta k/k/ F.
Appr'oximately eight and one-half hours later the reactor operator compared the actual rod positions against the rod withdrawal limitation curves and discovered that the rods were withdrawn beyond the limits.
He took immediate steps to dilute the boron con-centration to reestablish control rod positions within operating limits.
l In order to emphasize the need for the licensee to provide appropriate training and procedures to assure strict observance of Technical Specification limiting conditions for operation, the NRC proposes to impose civil penalties in the cumulative amount of Fifty Thousand Dollars for this inatter.
In accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), and pursuant to Section 234 of the Atomic Energy Act of 1954, as amended ("Act"), 42 U.S.C.-
2282, PL 96-295, and 10 CFR 2.205, the particular violations and their associated penalties are set forth below:
A.
Technical Specification 3.1.1.3.a requires the licensee, for operation within modes 1 or 2 when the moderator temperature coefficient (MTC) is more positive than 0 delta k/k/'F (for the all rods withdrawn, beginning of cycle life, hot zero thermal power condition), to maintain the control 8204270663
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~ Appendix A (Continued) rods within established withdrawal limits until a subsequent calculation
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verifies that the MTC has been restored to within its limit for all rods withdrawn condition.
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Contrary to the above, between 7:00 p.m. on December 21 and 3:30 a.m. on December 22, 1981, the licensee operated within mode 2 when the MTC was more positive than 0 delta k/k/ F for the all rods withdrawn condition, but did not maintain the control rods within established withdrawal limits.
This i3 a Severity Level III violation (Supplement I).
(Civ'l Penalty - $15,000).
B.
Technical Specification 6.4.1 requires the licensee to maintain a unit staff retraining program that meets the requirements of Section 5,5 of ANSI N18.1-1971.
Contrary to the above, the licensee did not maintain a unit staff retraining program that met certain requirements of Section 5.5.
Section 5.5 speci-fies that training shall include operational limitations.
The licensee did not train Unit 2 reactor operators on the operational limitations established for control rod withdrawal, which were necessary to meet Technical Specifica-tion 3.1.1.3.a.
This is a Severity Level III violation (Supplement I).
(Civil Penalty - $15,000).
C.
Technical Specification 6.8.1.a requires the licensee to implement estab-lished procedures covering activities identified in Appendix A of Regu-latory Guide 1.33, Revision 2, February 1978.
Section 2 of the Appendix identifies procedures for startup and operation of the reactor.
Contrary to the above, on December 21 and 22,1981 the licensee did not implement Technical Instruction 28 which is.an established procedure for startup and operation of the reactor.
This is a Severity Level III violation (Supplement I).
(Civil Penalty - $20,000).
Pursuant to the provisions of 10 CFR 2.201, TVA is hereby required to submit to
-this office within 30 days of the date of.this 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 cor-rective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved.
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.
Appendix A (Continued) Within the same time as provided for the response required above under 10 CFR 2.201, TVA may pay the civil penalties in the cumulative amount of $50,000 or may protest imposition of the civil penalties in whole or in part by a written answer.
Should TVA fail to answer within'ths time specified, this office will issue an order imposing the civil penalties in the amounts proposed above.
Should TVA elect to file an answer in accordance with 10 C.FR 2.205 protesting the civil penalties, such answer 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 why the penalties should not be imposed.
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 by specific reference (e.g., giving page and paragraph numbers) to avoid repetition.
TVA's attention is directed to the other pro-vision of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.
Upon failure to pay any civil penalties due, which have 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 penalties, 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
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- Ei & f.5*ly,f <+A RichardC.De' Young,Difector Office of Irispection and Enforcement s
Dated at Bethesda, Maryland this 29 day of March 1982 O
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