ML20117E185
| ML20117E185 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 08/31/1984 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20115A155 | List: |
| References | |
| FOIA-84-665 DD-84-21, NUDOCS 8505100352 | |
| Download: ML20117E185 (16) | |
Text
DD-84 21 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Harold R. Denton, Director In the Matter of
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MISSISSIPPI POWER & LIGHT COMPANY
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Docket No. 50-416 MIDDLE. SOUTH ENERGY, INC.
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SOUTH MISSISSIPPI ELECTRIC POWER
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(10 CFR 2.206)
ASSOCIATION
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(Grand Gulf Nuclear Station, Unit 1)
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DIRECTOR'S DECISION UNDER 10 CFR 2.206 INTRODUCTION By Petition dated March 29, 1984, Cynthia Stewart, on behalf of Jacksonians United for Livable Energy Policies (hereinafter referred to as JULEP or the Petitioner), requested that the Nuclear Regulatory Commission issue an order to Mississippi Power and Light Company (hereinafter referred to as MP&L) to show
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cause why the low power operating license for the Grand Gulf Nuclear Station, Unit 1, should not be revoked and a stay of operatioE should not be issued.
Notwithstanding its request for license revocation, the Petitioner also requested that the operating license be modified to remove management personnel responsible for past problems at Grand Gulf and to ensure implementation and verification of corrective actions associated with technical specification discrepancies and other deviations from NRC requirements.
Additionally, the Petitioner requests hearings before an Atomic Safety and Licensing Board. 1/ As grounds for 1/ The Petitioner also asked for appointment of an " independent panel" to inquire into the propriety and effectiveness of NRC personnel's actions related to Grand Gulf.
Although this request is beyond the scope of relief normally contemplated under 10 CFR 2.206, a copy of the petition was provided to the Comission's Office of Inspector and Auditor for appropriate action.
Bjj51og2841113 BELL 84-665 PDR
, granting this relief, the Petitioner asserts the following: (1) the technical specifications issued for the plant were, and continue to be, erroneous; (2) operator qualifications were falsified; (3) the drywell cooling system was inadequately designed and constructed; (4) the electric power system is inadequate; (5) MP&L had no previous nuclear experience and until recently none of the staff had operated a comercial reactor; and (6) given the history of problems and consistent poor management performance of the licensee, NRC will be unable to assure compliance by the licensee with NRC requirements.
In accordance with usual NRC practice, the Petition was referred to the staff for appropriate action in accordance with 10 CFR 2.206. A notice was published that the petition was under consideration.
49 FR 22168 (May 25, 1984).
On May 30, 1984, pursuant to 10 CFR 50.54(f) and section 182 of the Atomic Energy Act, MP&L was requested to' respond to the petition.
On July 5,1984, MP&L filed its response.
As explaihed in this decision, a number of actions have been taken to ensure implementation and verific,ation of corrective actiqns for identified problems at Grand Gulf.
In view of these actions, the staff does not believe that institution of further proceedings to modify or revoke the Grand-Gulf license is warranted.
Accordingly, I have concluded that Petitioner's request should be denied.
DISCUSSION Discrepancies in Technical Specifications and Surveillance Procedures A brief historical review is helpful at this point tn place the Petitioner's assertions-in proper perspective.
On June 16, 1982, a low power license was issued for the Grand Gulf Nuclear Station, Unit 1.
Inspections by Region II
. with regard to compliance of surveillance procedures with the Technical Specifi-cations were performed from June 16, 1982, to October 8, 1982, and discrepancies in the surveillance procedures and Technical Specifications were identified.
See Inspection Reports 50-416/82-55, 50-416/82-58, 50-416/82-60, 50-416/82-65, and 50-416/82-67.
Based on these inspections a Confirmation of Action letter was issued on October 20, 1982, confirming the licensee's commitment to restrict the next criticality (the plant was then shut down for other reasons) until the identified discrepancies were resolved.
At the conclusion of this phase of the licensee's review, in late August 1983, another inspection was held to evaluate operational readiness.
See Inspection Report 50-416/83-38.
The plant returned to criticality on September 25, 1983, and low power tests were conducted until November.8, 1983.
The plant was shut down after completion of testing which was followed by an extensive licensed operator recertification program, during which time MP&L and the staff again reviewed the Technical Specifications as
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issued through Amendment No. 12 to the Operating Lice'nse.
Further problem areas were identified, resulting in a complete review of the Technical Specifications by MP&L beginning on March 2, 1984.
This review was completed in April 1984.
As a result of these actions, Technical Specification problem areas were identified by MP&L.
The staff determined that changes to the Technical Specifi-cations needed to be made.
The staff performed a safety evaluation in order to determine which changes were required for 5% power operation. 2/ On April 18, 2_/ The staff determined that operation at a power level of up to 5% power did not require all problems with the Technical Specifications to be resolved at that time.
1984, the Director of the Office of Nuclear Reactor Regulation issued an Order Restricting Conditions for Operation, effective ininediately, which provided:
MP&L shall not operate the Grand Gulf plant under the terms of License No. NPF-13 unless such operation is in conformance with the revised Technical Specifications appended to this Order and MP&L, prior to entry into mode 2, certifies to the Regional Administrator, Region II, that MP&L's procedures have been modified and training conducted to reflect the revised Technical Specifications.
49 FR 17832,17833 (April 25,1984).
This order implemented some 23 changes in the Technical Specifications that were required to restore the safety margins for low power operation.
Resolution of the remaining items identified by the NRC staff and MP&L has been p
accomplished.
See Supplement No. 6 to the Safety Evaluation Report.
MP&L has submitted amendment requests to the Technical Specifications in order to make these changes.
These Technical Specifications have been included in the
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amendment authorizing full power operation.
Operation in accordance with the amended Technical Specifications provides reasonable assurance that the plant can be operated at full power with no significant ha'zard to the health and safety of the public.
Falsification of Operator Qualifications Discrepancies in the documentation of operator training were identified during a special training inspection conducted in February 1983 and a special safety inspection conducted by Region II during August, October and November
^1983.
See Inspection Reports 50-416/83-06, 50-416/83-38, and 50-416/83-53.
An evaluation of these inspections by Region II concluded that these discrepancies were not limited to documentation errors and that some information submitted to the NRC on applications for operator's licenses was inaccurate.
At Region II's
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. request, an investigation was conducted by the Office of Investigations (0I) from October 18, 1983, through February 10, 1984.
To ensure that the individuals granted licenses had the requisite qualifi-cations to retain their licenses, the staff has taken a number of actions.
During,the week of October 31, 1983, Region II conducted a second training assessment inspection.
This inspection was to follow up on problems identified during the February 1983 assessment with particular attention to the training of licensed operators.
In this assessment, Region II conducted walk-through type evaluations on selected systems for 13 licensed operators.
Three operators were identified as being deficient in knowledge level and were removed from licensed duties by MP&L.
The issuance of further licenses at Grand Gulf was suspended.
In the staff's judgement, the indicated weaknesses in operator training were not of such significance to warrant revocation of the licenses.
On November 11 and November 18, 1983, Region II,'and MP&L met concerning a recertification program to be conducted for all licensed operators, shift advisors and shift technical advisors.
MP&L agreed to implement an extensive program to recertify licensed operators which would include areas of identified weaknesses.
This special program began in November 1983 and was essentially completed in February 1984.
The recertification program included an individual examination of each licensed operator on each of 68 systems listed on a licensed operator qualification card acceptable to Region II.
These examinations were a
monitored by MP&L, representatives of two other utilities, by the nuclear steam supply vendor (General Electric), and by NRC.
At the completion of this examination process, the records of the operators were reviewed by a Grand Gulf w.
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_ Operator Training Evaluation Committee (0TEC) consisting of representatives of plant management.
The committee examined operator training records and the results of the examinations and conducted additional oral examinations as necessary.
Out of 27 individuals examined by the committee, one was found to be unqualified and was removed from licensed duties.
The NRC conducted an independent recertification examination of these 26 individuals.
The results of the independent NRC recertification examination were that 23 of the 26 oper-ators' passed.
The remaining three who failed were removed from licensed duties.
Following retraining, these three were reexamined by the NRC.
Two passed, and one who failed the reexamination is no longer employed at Grand Gulf.
Region II also examined the training and qualification of shift technical advisors.
The training was reviewed against FSAR commitments, and previous exams were reviewed for weak areas.
Retraining was provided by the utility to
' strengthen weak areas, and exams were given.
The exams were prepared and
' administered by the utility and reviewed by NRC examiners.
OTEC reviewed the training and exam records, gave each advisor an oral exam, and recertified the shift technical advisors.
These actions to review operator qualifications provide reasonable assur-ance that the operating staff at Grand Gulf have met the NRC requirements for training and obtaining a license.
While revocation of the Grand Gulf operating license is not warranted, enforcement action will be taken with regard to the the applications for operator's licenses.
Lack of Experience of MP&L Staff Petitioner raises as an issue the lack of operator experience similar to i
' Diablo Canyon 1/ and the inexperience of MP&L as an operator of nuclear facilities.
Improvements in MP&L's management are discussed in the latter portion of this decision.
With respect to operator experience, the Commission has expressed similar concern about the limited prior operating experience possessed by members of the operating shifts at certain plants including Grand Gulf.
An industry working grou'p was fonned to respond to this concern.
The working group developed proposed criteria for shift operating experience and presented these criteria to the Commission in February of this year.
These criteria require the four operators on each shift to possess at least 13 years of power plant experience, at least 6 of which must be nuclear.
Weighting fact' ors are used in assessing experience.
The criteria further require at least one senior reactor operator with six months " hot" participation at the same type plant on each shift or a qualified shift advisor until such time as the plant meets this participation requirement.
With a few improvements, the industry criteria were recently accepted by the Connission.
See Generic Let'ter 84-16, " Adequacy of On-Shift Operating Experience for Near Tenn Operating License Applicants" (June 27, 1984).
Region II has conducted an assessment and has concluded that the operating experience at Grand Gulf exceeds the Commission-approved criteria.
During the startup phase, Grand Gulf has enhanced operating experience by use of contract personnel in an advisory capacity.
In addition to the rcnnal shift technical advisor, a nuclear shift advisor has been assigned to each shift to participate in shift training.
The shift advisors previously held senior 1/ ee Pacific Gas & Electric Co. -(Diablo Canyon buclear Power Plant, Unit 1),
S 1TT-84-5, Slip Op. at 11-12 (April 13,1984).
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. reactor operator licenses at other BWR facilities.
Although they do not hold licenses at Grand Gulf, they have been certified by MP&L, and a specific training program was developed to provide each of these individuals with training on the differences between Grand Gulf, a BWR-6, and earlier boiling water reactor designs.
This program involved training lectures on plant systems, procedures and technical specifications followed by an OTEC examination.
Each shift advisor also received two weeks of simulator training in power ascension and emergency operating procedures and an examination on that training.
The operating staff at Grand Gulf has gained experience in system operations and surveilla'nce testing during the low power testing program. These activities were monitored by NRC inspectors.
The planned, deliberate power ascension pro-gram will add to this experience.
Region II staff has conducted broad-based operational readiness inspections at Grand Gulf prior to the plant's exceeding 5% power and will inspect again prior to its exceeding 50% power.
Design and Construction of the Drywell Cooling System Petitioner alleges that the drywell cooling system was inadequately designed and constructed.
Grand Gulf Nuclear Station, Unit 1 is the first of the General Electric BWR 6/ Mark III reactor / containment designs to be built in the United States.
As such, a new product line and a prototype reactor sometimes experience some difficulties in going from design to actual operation.
In fact, the purpose of preoperational testing and the start-up test program is to identify anomalies during the initial phases of operation.
An inadequacy in the performance' characteristics of the drywell cooling system was identified during the non-nuclear heatup as part of the preoperational testing.
The problem
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. resulted from inadequate insulation which led to higher than anticipated heat losses to the drywell.
MP&L solved this problem by making several modifications to the plant.
The modifications included repairs and rework to existing reflec-tive insulation, the addition of insulation in certain areas, modifications and additions to the air distribution systems, and the addition of a 1200 ton chiller capacity to the drywell cooling.
With these modifications, MP&L is capable of meeting the requirement in the Technical Specifications to limit the temperature in the drywell to 135*F to protect the structure and safety-related equipment.
While the operational mode of the plant was restricted by this deficiency, the anomaly did not pose a risk to the public health and safety.
Adeouacy of the Electric Power System On August 12, 1983, the main crankshaft on one of the three emergenc'y diesel generators at the Shoreham Nuclear Power Station, which were manufactured by Transamerica Delaval, Inc., (TDI[, broke during a load test.
During the course of the evaluation of the failure, information related to the operating history of TDI engines was identified which called into question the reliability of all TDI diesels, including the TDI diesel generators installed at the Grand Gulf facility.
As a result, an Owners Group was organized with all plants utilizing TDI engines in order to resolve this problem.
Subsequently, NRC staff conducted an evaluation of the effect of failure of TDI diesel generators at Grand Gulf at the maximum power level of 5% then authorized by the license.
The staff concluded that the total failure of the Delaval diesels at Grand Gulf would not significantly increase the risk of low power operation and that the risk of low power operation was acceptably small.
1 Nevertheless, some very low probability environmental events were contributors to that risk, and that risk would be reduced if the reliability of the TDI diesel generator is enhanced.
Consequently, the staff determined that it would be appropriate to have increased assurance as to reliable onsite power.
- Moreover, for full-power operation, a high degree of reliability is required for the diesel generators.
The staff found that the most appropriate method to obtain information about the specific conditions of the diesel generators at Grand Gulf would be to disassemble and inspect the diesel generator which had been operating the longest.
In view of these findings, the Director of NRR issued an Order Requiring Diesel Generator Inspection, effective immediately, on May 22, 1984, which provided that the Division I TDI diesel generator be disassembled for _ inspection, all defective parts be replaced prior to declaring the engine
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operable, (the engine block and engine base could be excepted if indications were not significant) and that preoperational testing be performed on the
' inspected engine prior to declaring it operable.
49 TR 22532 (May 30, 1984).
MP&L has completed the teardown and inspection as required by the Order.
The only significant finding involved the failure of some capscrews in the turbocharger.
Subsequently, the turbochargers for both diesels were refurb-ished by the manufacturer.
As a result of its review of the diesel generator issue, the NRC staff has concluded that the TDI diesel engines at Grand Gulf will provide a reliable standby source of onsite power.
This finding is based upon the reviews of (1) the current status of the TDI Owners Group Program in resolving the TDI diesel engine issue; (2) actions taken by MP&L to verify the reliability of the Division I and II engines, including those actions taken in e
. response to the NRC order dated May 22, 1984; (3) the Augmented Engine Maintenance and Surveillance Program to which MP&L committed in letters dated July 20 and 22, 1984; and (4) changes to the Technical Specifications to limit future testing of the engines to 185 psig brake mean effective pressure.
In addition, certain license conditions have been imposed to provide future assur-ance that the diesel generators will be acceptable at Grand Gulf.
The results of the staff's review and the basis for its findings are contained in Supplement No. 6 to the Safety Evaluation Report for Grand Gulf.
Certain exemptions have been issued with respect to the onsite power supply, but the staff believes that full power operation with the exemptions will not pose an undue risk to public health and safety.
These exemptions are not related to the TDI diesel engine performance.
Since the licensee's inspection and the NRC staff's review, on July 26,
~1984, a cylinder head on the Division 1 diesel was found to be leaking water
'into the cylinder from the jacket water cooling systam. The' leak was found during a surveillance check specifically intended to identify such leakage.
The source of the leak was identified as a crack located in a region of the head which has not previously been identified as a potential problem area and which had not been subject to the inspections performed under the Order.
The leaking cylinder head has been replaced.
Surveillance checks for cylinder head leakage will be performed periodically while the engines are in an operable standby mode.
The staff believes that this surveillance provides adequate assurance that any future leaks will not impair the operability of the engines and that this event does not modify the staff findings as stated above.
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Assurance that Licensee Will Meet NRC Requirements The Petitioner argues that, in view of the licensee's past difficulties 4
in meeting NRC requirements and the consistent poor performance of the licensee's management, NRC can have no assurance that the licensee will operate the facility competently in the future.
In support of this charge, the Petitioner cites the licensee's failures to meet regulations in the case of employee training, the discrepancies between the physical plant and technical specifications, and the fact that in the NRC's annual Systematic Assessment of Licensee Ferformance (SALP) reviews MP&L management has consistently scored poorly.
To put this issue in perspective, it is important to consider that, beginning on October 1, 1983,'a new organizational structure was implemented at the Grand Gulf site.
The ma,jor thrust was to establish more managerial con-trol over plant operations.
Three p&rallel assistant plant managers reporting to the plant manager were established. One has the o'peratioris superintendent and the operating crews reporting to him along with health physics and chemistry.
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One has.all maintenance personnel reporting to him.
The third has training and security reporting to him, along with various administrative functions. Manage-ment changes within the training area included elevating the training function to report directly to an assistant plant manager, consolidating the training staff, assigning additional personnel to the training department, initiation of a special financial incentive program to improve the staff retention rate, and the addition of a corporate nuclear human resource manager directly responsible i
for increasing the number and level of competence of personnel entering the training program.
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. A number of other management and personnel changes have also been made in an effort to augment the previous limited commercial nuclear experience avail-able on the Grand Gulf staff.
The former assistant plant manager for operations was made plant manager.
His experience includes service as an instrumentation engineer at TVA's Browns Ferry facility, assistant plant manager at Watts Bar and assistant plant manager at Sequoyah.
A former Director of nuclear power for TVA who has extensive nuclear experience, particularly in the operation and maintenance of BWRs, has assumed the position of Technical Advisor to the Vice President.
It is also important to note that MP&L has a new President who has direct experience in the operation of commercial nuclear power plants and a new Senior Vice President with extensive nuclear Navy and corporate experience.
These changes represent a significant improvement in the experience and capability of the licensee's management.
Moreover, as noted in earlier portions of this decision, appropriate measuhes have been taken to review deficiencies in operator qualifications and plant Technical Specifications and to ensure appropriate remedial action.
In connection with the resolu. tion of these issues, MP&L management has demonstrated marked improvement in its control of licensed activities.
Thus, the staff believes that Grand Gulf can be operated in com-pliance with the Commission's requirements and with reasonable assurance that the health and safety of the public will not be endangered.
CONCLUSION The Petitioner bases its request for relief upon past difficulties with the Grand Gulf facility.
As discussed above, NRC has taken actions to resolve these difficulties.
The staff believes that the actions taken with regard to
- these problems are sufficient to provide reasonable assurance of the safe operation of the plant.
Therefore, Petitioner's request for revocation of the license for Grand Gulf Nuclear Station, Unit 1, is denied.
As the Commission has taken actions to resolve the problems with the diesel generators, technical specification discrepancies, and falsification of operator qualifications and because management has changed, Petitioner's requests to replace management and ensure implementation and verification of corrective actions for identified problems at Grand Gulf have been essentially satisfied.
However, institution offurtherproceedingstoimplementtheseactionsisunnecessary.S/
A copf of this decision will be filed with the Secretary for the Comission's review'in accordance with 10 CFR 2.206(c) of the Comission's regulations.
/f T-Harold R. Denton, Director Office of Nuclear Reactor Regulation Dated at Bethesda, Maryland this 31st day of August 1984.
d/ onsequently, the Petitioner's request for initiation of hearings before an C
Atomic Safety and Licensing Board is also denied.
The holding of hearings on the Petitioner's 52.206 request is not required.
Porter Count of the Izaak Walton League v. NRC, 606 F.2d 1363 (D.C. Cir. 1979)y Chapter
- People of the State of Illinois v. NRC, 591 F.2d 12 (7th Cir.1979).
Because appro-
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priate actions have.been taken or will be taken in connection with the authorization of a full power license, initiation of further enforcement proceedings, which might result in the holding of the adjudicatory hearings that the petitioner requests, is not warranted.
7590-01 UNITED STATES NUCLEAR REGULATORY COMMISSION DOCKET NO. 50-416 MISSISSIPPI POWER AND LIGHT COMPANY MIDDLE SOUTH ENERGY, INC.
SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION GRAND GULF NUCLEAR STATION, UNIT 1 ISSUANCE OF DIRECTOR'S DECISION UNDER 10 CFR 2.206 Notice is hereb'y given that the Director, Office of Nuclear Reactor Regula-tion has denied the Petition filed under 10 CFR 2.206 by the Jacksonians United for Livable Energy Policies regarding the Grand Gulf Nuclear Station, Unit 1 (the facility).
The Petitioner requested that the Nuclear Regulato' y Commission issue an r
order to Mississippi Pcwer and Light Company to show cause why the license for the facility should not be revoked and a stay of operation should not be issued.
.The Petitioner also requested that the operating license be modified to remove responsible management personnel and ensure implementation and verification of corrective actions associated with techncial specification discrepancies.
The Commission has taken actions to resolve these problems and Grand Gulf has taken corrective actions for the identified problems.
Because appropriate corrective r
measures have been initiated, institution of further proceedings to implenent these actions is unnecessary.
The reasons for the above conclusions are fully described in a " Director's Decision Under 10 CFR 2.206," dated lAUS 3 1 1984 which is available for l
public inspection in the Connission's Public Document Room located at 1717 H j
Street, N.W., Washington, D. C.
20555, and the Hinds Jr. College, George M.
McLendon Library, Raymond, Mississippi 39154.
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2-A copy of the decision will be filed with the Secretary for the Commission's review in accordance with 10 CFR 2.206(c).
Dated at Bethesda, Maryland this 31st day of August 1984.
FOR THE NUCLEAR REGULATORY COMMISSION Harold R. Denton, Director Office of Nuclear Reactor Regulation e
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