ML20245E810
| ML20245E810 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 04/21/1989 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Morris K OMAHA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8905020153 | |
| Download: ML20245E810 (2) | |
See also: IR 05000285/1989002
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APR 21 1989
In Reply Refer To: _
Docket:
50-285/89-02
Omaha Public Power District
ATTN:
Kenneth J. Morris, Division Manager
Nuclear Operations
1623 Harney Street
Omaha, Nebraska 68102
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Gentlemen:
Thsnk you for your. letter of April 7,1989,:in response -to our letter and
Notice of Violation dated February 27, 1989. We have reviewed your reply and find it
responsive to the concerns raised in our Notice of Violation. We will review
the implementation of your corrective actions during a future inspection to
determine that full compliance has been achieved and will te maintained.
Sincerely.
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L. J. Callan, Director
Division of Reactor Projects
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cc:
Fort Calhoun Station
ATTN:
W. G. Gates, Manager
P.O. Box 399
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Fort Calhoun, Nebraska 68023
Harry H. Voigt. Esq.
LeBoeuf. Lamb Leiby & MacRae
1733 New Hampshire Avenue, NW
Washington, DC 20036
Nebraska Radiation Control Program Director
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Dmaha Public Power District
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R.D. Martin, RA
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RSTS Operator
Project Engineer (DRP/B)
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Lisa Shea, RM/ALF
P. Milano, NRR Project Manager (MS:
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W. C. Seidle
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H. Bundy
T. McKernon
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Omaha Public Power District
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1623 Harney Omaha. Nebraska 68102 2247
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April 7, 1989
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LIC-89-288
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U. S. fluclear Regulatory Commission
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Attn: Document Control Desk
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Mail Station Pl-137
Washington, DC 20555
References:
1.
Docket No. 50-285
2.
Letter from NRC (L. J. Callan) to OPPD (K. J. Morris) dated
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February 27, 1989
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Gentlemen:
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SUBJECT:
Response to Notice of Violation NRC - Inspection Report
50-285/89-02
Omaha Public Power District (0 PPD) received Reference 2, Notice of Violation.
The violation concerned a failure to perform sufficient evaluations of Low
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Power Physics Test results and use of an incorrect equation in comparing test
results to review criteria.
Please find attached OPPD's response to this
violation in accordance with 10 CFR Part 2.201.
An extension was granted by
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the Senior Resident Inspector to provide adequate corrective actions.
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If you have questions concerning this response, please contact us.
Sincerely,
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/' f Morris
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Division Manager
Nuclear Operations
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Attachment
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LeBoeuf, Lamb. Leiby & MacRae
R. D. Martin, NRC_ Regional Administrator
P. D. Milano, NRC Project Manager
P. H. Harrell, NRC Senior Resident Inspector
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Attachment
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RESPONSE TO NOTICE OF VIOLATION
During an NRC inspection conducted on January 30 through February 3, 1989, a
violation of NRC requirements was. identified.
The violation involved a failure
to perform sufficient evaluations of test esults.
In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR. Part 2. Appendix C (1988), the violation is listed below:
Criterion XI of Appendix B to 10 CFR 50, required, in ptrt, that all
testing shall be performed -in accordance with written test procedures which
incorporate the requirements and acceptance limits' contained in the
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applicable design documents.
Furthermore, test results shall .be documented
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and evaluated to assure the test. requirements have been satisfied. The
licensee has implemented these requirements, in part, in Fort Calhoun
Station Procedure SP-PRCPT-1, Revision 28, " Post Refueling Core Physics
Testing and Power Ascension," dated January 28, 1989.
Contrary to the above, the following findings were made by the NRC'
inspectors:
_Fajlure to Perform Sufficient Test Results Evaluation
A.
a
The licensee failed to perform a comprehensive evaluation of test
results, in that, data used in manual and computer software worksheet
calculations for low power physics testing data reduction were in
error. The failure to perform a sufficient results evaluation
resulted in an erroneous moderator temperature coefficient which
inaccurately represented the true margin.of safety to the Technical
Specification limit specified in Technical Specification 2.10.1(3)b.
This is a Severity Level IV violation.
(Supplement I) (285/8902-01)
OPPD's ResDonse
1.
Reason for the Violation, if Admitted
OPPD admits the violation occurred as stated.
The reason for the violation
were inadequate procedures and personnel error.
The procedure in use at the time of the violation did not specify the steps
to be followed when calculating the most positive Moderator Temperature
Coefficient (MTC) from the measured Isathermal Temperature Coefficient -
(lTC).
This calculation was performed by a qualified, knowledgeable and
experienced engineer without specific written guidance.
The engineers
assigned to perform the Cycle 12 Low Power Physics Tests were highly
qualified with experience ranging from three to six cycles of Low Power
Physics Startup Testing.
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During the performance of Cycle 12 Low Power Physics Testing, OPPD began
analyzing the data immediately following completion of each portion of the
test. Once the data was collected ard analyzed, the calculations were
checked by another test engineer not involved in the analysis process.
This check was limited to a numerical check of calculations and was not a
procedural requirement.
Following completion of the last Low Power Physics
Test, the data was analyzed, checked, and was compared against the
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acceptance criteria located in Appendix 0 of SP-PRCPT-1, "Special
Procedure:
Post Refueling Core Physics Parameter Evaluation." After
acknowledgment of meeting the acceptance criteria, the Plant Review
Committee (PRC) members completed the necessary sign-offs for the beginning
of power ascension.
The NRC reviewed the ITC test data and discovered that an incorrect Fuel
Temperature Coefficient (FTC) was applied to the MTC calculation which
resulted in a
ess c nsenah E Gan mom M de E
-1.47 x 10-5 ap/*F was used to calculate an MTC of +4.43 x 10-5^"p/*F.
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The inspectors determined that this FTC value was not the FTC for Beginning
of gycle (B0C), Hot Zero Power (HZP), and that the correct iTC was -1.97 x
10 5 ap/ .* F .
Use of the correct FTC would result in an MTC of +4.93 x
10-
3pf F.
The corrected value o
Specificationslimitof+5.0x10gMTCdidnotviolatetheTechnical
Ap/*F.
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OPPD has determined that the FTC used in the original calculations was the
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FTC at B0C, Hot Full Power (HFP).
The Hot Full Power FTC value was located
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directly below the HZP value in the Cycle 12 Reload License Evaluation and
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was transposed incorrectly for use in the MTC calculation.
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calculations were checked shortly after the completion of the ITC test, but
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the check did not ensure that the FTC used in the calculation was indeed
the correct value.
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2.
Corrective Steos Which Have Been Taken and Results Achieved
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After the NRC inspector had identified the calculation error, an
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independent review of preliminary results was conducted.
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Concurrent with the independent review of the preliminary results, an
investigation of the method used to derive the FTC was conducted due to
concern over the value of predictgd MTC and its margin to the Technical
Specification limit of +5.0 x 10-
ap/ * F .
Combustion Engineering (CE)
was consulted and their review indicated that OPPD calculations used a
significantly conservative application of physics methodology.
CE offered
an alternative to the OPPD calculation methods which more accurately
predictsthgFTC.
Application of this method resulted in an HZP FTC of
-1.49 x 10-
op/*F.
Upon completion of the FTC investigation in which Combustion Engineering
participated and the independent review by 0 PPD, a memo was transmitted to
the PRC containing the revised preliminary results from low power t
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testing. The memo documented the measured and predicted MTC values and
demonstrated acceptability of tSe results within the SP-PRCPT-1 acceptance
and review criteria.
The PRC reviewed and approved the revised
information.
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Formal analysis and analysis verification of the data collected during low
power physics testing is conoucted under the Production Engineering
Division Quality Procedure PED QP-5.
The Cycle 12 Engineering Analysis
(EA) was completed, including analysis verification, un March 9, 1989 and
the results were within the. acceptance criteria limits of Appendix D, Table
1, SP-PRCPT-1.
Therefore, the error did not create a significant safety
concern.
3.
Corrective Steos Which Will Be Taken to Avoid Further Violations
Changes to SP-PRCPT-1 have been initiated which.will require independent
review of the preliminary results be performed and documented prior to
presentation to the PRC. Data reduction and summary sheets which
demonstrate acceptable or unacceptable test results will be included in the
revision to SP-PRCPT-1.
The summary sheet will also document the
incorporation of the alternate FTC calculational method recommended by
Combustion Engineering.
These changes are to be implemented by June 30,
1989.
The revised procedure will be available for use prior to the next,
refueling outage.
OPPD has reviewed other similar procedures and has
determined that the procedures are adequate.
4.
The Date When Full Compliance Will be Achieved
Full compliance will be achieved when SP-PRCPT-1 is revised by June 30,
1989.
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comply with the requirements of SP-PRCPT-1.
Therefore, OPPD believes that
compliance with the procedure was achieved, however OPPD agrees with the
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NRC.that documentation did not clearly support compliance to the procedure
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in comparing measured to predicted values.
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A memorandum containing the revised preliminary 'results from low power
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physics testing was transmitted to the PRC upon completion of an
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independent review.
This memo clearly documented.the measured and
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predicted values and demonstrated acceptability with the SP-PRCPT-1
acceptance and review criteria.
The PRC reviewed and approved the revised
information.
3.
Corrective Steos Which Will Re Taken to Avoid Further Violelions'-
Changes to SP-PRCPT-1.have been initiated which require an independent'
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review of the preliminary calculations to be presented to the PRC prior to
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power ascension.
In addition, data reduction and summary sheets will be.
included as revisions to the procedure,'which clearly require a comparison
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between predicted and measured values and either demonstrate acceptable or
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unacceptable test results.
These changes are expected to be implemented by
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June 30, 1989.
The procedures will not be used until the next refueling
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outage,
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4.
The Date When Full Compliance Will be Achieved
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Full compliance will be achieved when changes to SP-PRCPT-1 are implemented
by June 30, 1989.
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B.
Use of Incorrect Formula 'in Comparina results to Review Criteria
The licensee used a formula for evaluating. control element assembly .
group worths review criteria, which was different from that inferred
ty the review criteria stated in Appendix D of the above re#erenced
procedure.
This is a Severity Level IV violation (Supplement I) (285/8902-01)
OPPD's Response
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1.
Reason for the Violation. if Admitted
The reason for the violation was inadequate procedures.
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The procedures in use at the time of the. violation did not specify how data
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would be transmitted to the PRC for their review.
The procedure required
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the Startup Test Group to reduce physics test data and compare the data to
the acceptance criteria listed in Table 1 of Appendix 0 of the procedure.
Once the comparison was completed and all low power physics test results
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had met the acceptance criteria, the. procedures allowed power ascension to
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commence.
The PRC was required to review the results of the low power
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physics tests and give authorization to proceed with power ascension.
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A' summary sheet, entitled "Results from Cycle 12 Low Power Physics Testing"
was created to give the test engineers a summary of the comparison of the
test results to the acceptance and review criteria and was intended to be.
used only within the startup test engineer group.
Test results were added
to this sheet after every test was completed and the results checked.
Both
measured and predicted values for each test were included along with review
criteria specifics with the exception of the control rod worths tests.
Percent differences from the measured values of the control rod worths test
were calculated in accordance with CE Topical Report for using the Rod
Exchange Technique (CE NPSD-366) with the understanding that those percent
differences were not part of the SP-PRCRT-1 procedural requirements.
The summary sheet was to be used within the startup testing group as a
quick calculational guide only to see if any control rod group worths were
close to or exceeded the acceptance criteria.
A member of the PRC
requested the summary sheet, made copies, and distributed the information
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to the PRC without knowledge of the Startup Test Group.
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2.
Corrective Steos Which Have Been Taken and Results Achieved
PRC members were told at the preparation for power ascension meeting that
the measured values were to be compared to those predicted in accordance
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with the acceptance and review criteria of Table 1 of Appendix D.
Based
upon the results of the rod worth-tests, no rod groups exceeded the
criteria of +/-15% of the predicted worth.
This was done as demonstrated
on a marked up copy of the summary sheet and retained by one of the PRC
members. After completion and acceptance of the values, the PRC completed
ths sign-offs for commencement of power ascension activities.
These steps
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