ML20132E629
| ML20132E629 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 12/13/1996 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Campbell W CAROLINA POWER & LIGHT CO. |
| Shared Package | |
| ML20132E632 | List: |
| References | |
| EA-96-442, NUDOCS 9612230353 | |
| Download: ML20132E629 (6) | |
See also: IR 05000324/1996016
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December 13, 1996
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-EA 96 442
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Carolina Power & Light Company
ATTN: Mr. W. R. Campbell
Vice President
Brunswick Steam Electric Plant
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Post Office Box 10429
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Southport, North Carolina 28461
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SUBJECT:
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(NRC INSPECTION REPORT NOS. 50 325/96 16 AND 50 324/96 16)
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Dear Mr. Campbell:
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This refers to the integrated inspection completed on October 26,19% at your-
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Brunswick facility. The inspection included a review of your failure to
provide temperature compensation for the Plant Process Computer (PPC)
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feedwater flow algorithm which resulted in operation of Brunswick Unit 2 in -
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excess of (1) the maximum thermal aower authorized by the license and
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(2) thermal limits required by Tec1nical Specification (TS) 3.2.1.
The
inspection report was sent to you by letter dated November 22, 1996. -A
closed, predecisional enforcement conference was conducted in the Region II
office on December 9,1996, with you and members of your staff to discuss the
apparent violations, the root causes, and your corrective actions to preclude
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recurrence. A list of conference attendees NRC slides, and a copy of your.
presentation materials are enclosed.
Based on the information developed during the inspection and the information
you provided during the conference. the NRC has determined that violations of
NRC requirements occurred. The violations are cited in the enclosed Notice of
Violation (Notice) and the circumstances surrounding them are described in
detail in the subject inspection report.
Violation A involves the failure to
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maintain the Unit 2 thermal power within the operating license limits. On
August 28, 1996, a reactor engineer reviewing core thermal power calculations
associated with the Power Uprate Project determined that the Unit 2 PPC point
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value for feedwater flow was not properly compensated for feedwater
temperature deviations from the normal operating temperature. The condition
had existed on Unit 2 since the unit restarted after a refueling outage ending
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in July 1994 when Unit 2 was modified to add a new PPC and associated
software. Due to the failure to temperature compensate the feedwater flow-
process point value, the core thermal power calculated and indicated by the
PPC was less than the actual core thermal power. During periods when
feedwater temperature was lower than the normal operating value, Unit 2 was
operated at indicated power levels of up to 100 percent power or 2436
megawatts (MW) thermal which was equivalent to actual power levels of up to
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102.4 percent power or 2494 MW thermal. This is a violation of License
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Condition 2.C.1 of Facility Operating License Number DPR 62 which requires
that Unit 2 be operated at or less than 2436 MW thermal.
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9612230353 961213
ADOCK 05000324
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Violation B involves the failure to maintain the calculated Average Planar
Linear Heat Generation Rate (APLHGR) within the limits of TS 3.2.1.
The
APLHGR limits vary based on power level and feedwater flow to assure that the
fuel thermal-mechanical design criteria are preserved during abnormal
transients. TS 3.2.1 specifies the approved methodology for determining the
limits placed on ALPHGR for a given power level and feedwater flw rate.
Due
to the failure to appropriately compensate for feedwater temperature, the
calculated reactor aower level inputs to the APLHGR calculation were incorrect
and the resulting A)LHGR value was non conservative. The APLHGR values, as
calculated using the actual power levels, exceeded the limits specified by
TS 3.2.1 between December 10 and December 20, 1995. During the predecisional
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enforcement conference, your staff noted that the approved methodology for
calculating the APLHGR limits specified by TS 3.2.1 was based on generic
APLHGR adjustment factors. Your re analysis of the APLHGR limits using cycle
specific adjustment factors indicated that the APLHGR values, based on actual
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power levels between December 10 and December 20, 1995, were within cycle
specific design limits. Although the re analysis indicates that the actual
safety consequence of Violation B was low; the NRC considers any change in
reactor parameters that cause unanticipated reductions in the margin of safety
to be a significant regulatory concern.
The root causes of the violations included the failure of your design team to
properly link the Unit 2 feedwater flow process points to the appropriate
compensation formula in the Unit 2 compensation database. The com) uter index
labels for the Unit 2 feedwater flow process points were changed w1en
additional process points were loaded into the database.
Due to the
inappropriate index labels, the computer linked a compensation value of one to
the points instead of the correct compensation value.
Your post modification
acceptance testing for the new PPC did not verify that process point numbering
was the same in both units and did not verify that the correct relationships
between process points and compensation values were preserved when your design
team, in an effort to reduce differences between the two units, copied the
existing PPC database configuration from the Unit 1 PPC to the Unit 2 PPC.
These violations represent a significant failure to control design parameters
that affected the integrity of reactor core protection systems. The NRC
expects licensees to provide meticulous oversight of vendor changes to plant
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process computer software and to conduct comprehensive post-modification
testing of new software used to assure operation within specified acce) table
fuel design limits.
In this case, the NRC is particularly concerned t1at
specified core operating limits were exceeded due to the inadequate design
control and testing. Therefore, these violations are classified in the
aggregate in accordance with the " General Statement of Policy and Procedures
for NRC Enforcement Actions" (Enforcement Policy) NUREG 1600, as a Severity
Level III problem.
In accordance with the Enforcement Policy, a base civil penalty in the amount
of $50,000 is considered for a Severity Level III problem.
Because your
facility has been the subject of escalated enforcement actions within the last
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two years , the NRC considered whether credit was warranted for
Jdentification and Corrective Action in accordance with the civil
analty
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assessment process described in Section VI.B.2 of the Enforcement
)olicy. The
NRC concluded that credit was warranted for Identification because your staff
identified both violations. With regard to consideration for Corrective
Action, your corrective actions included:
(1) effective, immediate corrective
actions to reduce power and correct the software deficiency; (2) revalidation
of critical plant process computer functions and confirmation of appropriate
testing of the software: (3) review of other computer applications:
(4) enhancements to the control of design and testing of computer products;
and, (5) training on lessons learned and software configuration control.
Based on the above, the NRC determined that credit was warranted for
Corrective Action.
The application of the factors considered in the civil penalty assessment
process, absent the exercise of discretion, resulted in no civil penalty.
However, you should be aware that the NRC considered imposing a civil penalty,
under Section VII.A of the Enforcement Policy, because of the potential impact
of weak vendor oversight and inadequate design control and testing of software
affecting core operating parameters. However, because your reactor engineer
demonstrated a safety conscious attitude which resulted in the identification
of the software deficiency and to encourage prompt identification and
comprehensive correction of violations, I have been authorized, after
consultation with the Office of Enforcement, not to propose a civil penalty in
this case. Significant violations in this area in the future could result in
a civil penalty.
You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response.
In your
response, you should document the specific acticas taken and any additional
actions you plan to prevent recurrence. After reviewing your response to this
Notice, including your proposed corrective actions and the results of future
inspections, the NRC will determine whether NRC enforcement action is
necessary to ensure compliance with NRC regulatory requirements.
I A severity Level III violation was issued on November 19.1996. (EA 96 354) related to
environmental qualification program deficiencies. A severity Level III violation was issued on
July 12.1996. (EA % 181) related to design control measures for service water system
modifications. A severity Level III violation was issued on April 4.1996, (EA 96-054) for
failure to meet fitness for duty requirements. A severity Level III violation was issued on
November 20.1995. (EA 95 228) related to suitability of materials used in valves in the residual
heat removal system. A severity Level III problem was issued on september 8.1995. (EA 95166)
related to design control. modification and testing of the high pressure injection system and
reactor core isolation cooling system.
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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of
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this letter, its enclosures, and your response will be placed in the NRC
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Public Document Room (PDR).
Sincerely,
Original Signed by
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Luis Reyes for
Stewart D. Ebneter
Regional Administrator
Docket Nos. 50 324
License Nos. DPR 62
Enclosures:
1.
2.
List of Conference Attendees
(Not to be Published in NUREG 0940)
3.
Licensee Presentation Material
(Not to be Publi.ched in NUREG 0940)
4.
NRC Slides (Not to be Published in NUREG 0940)
cc w/ encl:
W. Levis Director
Site Operations
Brunswick Steam Electric Plant
P. O. Box 10429
Southport, NC 28461
R. P. Lopriore
Plant Manager
Brunswick Steam Electric Plant
Carc, lina Power & Light Company
P. O. Box 10429
Southport, NC 28461
J. Cowan Vice President
Operations & Environmental
Support
MS OHS 7
Carolina Power & Light Company
P. O. Box 1551
Raleigh, NC 27602
Gerald D. Hicks
Manager
Regulatory Affairs
Carolina Power & Light Company
P. O. Box 10429
Southport, NC 28461
cc w/encls cont'd: (see next page)
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cc w/encls cont'd:
W. D. Johnson, Vice President
Public Service Commission
and Senior Counsel
State of South Carolina
Carolina Power & Light Company
P. O. Box 11649
P. O. Box 1551
Columbia, SC 29211
Raleigh, NC 27602
Jerry W. Jones, Chairman
Dayne H. Brown. Director
Brunswick County Board of
Division of Radiation Protection
Commissioners
artment of Environmental
P. O. Box 249
N. C. Dep& Natural Resources
Health
Bolvia NC 28422
P. O. Box 27687
Raleigh, NC 27611 7687
Dan E. Summers
Emergency Management Coordinator
Karen E. Long
New Hanover County Department of
Assistant Attorney General
Emergency Management
State of North Carolina
P. O. Box 1525
P. O. Box 629
Wilmington, NC 28402
Raleigh, NC 27602
William H. Crowe, Mayor
Robert P. Gruber
City of Southport
Executive Director
201 East Moore Street
Public Staff - NCUC
Southport, NC 28461
P. O. Box 29520
Raleigh, NC 27626 0520
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Distribution w/encls:
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PUBLIC
JTaylor, EDO
JHilhoan, DEDR
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RZimmerman, NRR
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SEbneter, RII
LChandler, OGC
JGoldberg, 0GC
JLieberman, OE
Enforcement Coordinators
RI, RIII, RIV
EHayden, OPA
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EJordan, AE0D
EJulian, SECY
BKeeling, CA
PRabideau, OC
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DDandois, OC
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GCaputo 01
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HBell, 0IG
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OE:EA File (B. Summers, OE)
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(e mail plus 2 letterhead)
MSatorius, OE
AGibson, RII
JJohnson, RII
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CEvans, RII
Buryc, RII
KClark, RII
RTrojanowski,RII
CCasto RII
MShymlock RII (IFS entry required)
DTrimble, NRR
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MMiller, RII
RAiello, RII
GHallstrom, RII
,
NRC Resident Inspector
U.S. Nuclear Regulatory Commission
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8470 River Road, SE
Southport, NC 28461
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