ML20214Q615
| ML20214Q615 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 06/01/1987 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | ARKANSAS POWER & LIGHT CO. |
| Shared Package | |
| ML20214Q587 | List: |
| References | |
| EA-86-151, NUDOCS 8706050092 | |
| Download: ML20214Q615 (8) | |
Text
UNITED STATES Nb' CLEAR REGULATORY COMMISSION In the Matter of Arkansas Power and Light Company -
Docket No. 50-313 Arkansas Nuclear One, Unit 1 License No. DPR-51 EA 86-151 ORDER IMPOSING CIVIL MONETARY PENALTY I
Arkansas Power and Light Ccmpany (licensee) is the holder of Operating License No. DPR-51 { license) issued by the Nuclear Regulatory Comission (NRC/ Commission) on May 21, 1974. The license authorizes the licensee to operate Arkansas Nuclear One in accordance with the conditions specified therein.
II A special inspection of the licensee's activities was c6nducted on Jcnuary 6-31, 1936. The results of this inspection indicated +5at the licensee Md not conducted its activities in full compliance with NRC requirements. A written Notice of Violation and Proposed Imposition of Civil Penalty (Notice) was served upon the licensee by letter dated November 12, 1986. The Notice stated the nature of the violation, the provicion of the NRC's requirement tLat the ticensee had violated, and the amount of the civil penalty proposed for Violstion I. The licensee responded to Violation I of the Notice of Yiolation and Proposed Imposition of Civil Penalty by letter dated Deceaber 12, 1986 8706050092 870601 PDR ADOCK 0500C313 O PDR
III After consideration of the licensee's response and the statements of fact, explanation, and argunent for citigation contained therein, the Deputy Executive Director for Regional Operations has determined, as set forth in the Appendix to this Ordcr, that Violation I occurred as stated and that the penalty proposed for this violation in the Notice of Violation and Proposed Imposition of Civil Penalty should be imposed.
IV In view of the foregoing and pursuant to Section 234 of the Atomic Energy ect of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205, IT IS HEREBY ORDERED THAT:
The licensee pay a civil penalty in the amount of Fifty Thousand Dollars ($50,000) within 30 days of the date of this Order, by check, draft, or money order, payable to the Treasurer of the United States and mailed to the Director, Office of Enforcement, U.S. Nuclear Reguletory Commission, ATTN: Document Control Desk, Washingtca, D.C. 20555.
1 The licensee may request a hearing within 30 days of the dote of this Order. A l request for a hearing should be clearly marked as a " Request for an Enforcement Hearing" and shall be addressed to the Director, Office of Enforcement, U.S.
l Nuclear Regulatory Comission, ATTN: Document Control Desit, Washington, D.C.
20555, with a copy to the Assistant General dounsel for Enforcement, Office of the General Counsel, U.S. Nuclear Regulatory Comission, Washington, D.C. 20555; the Regional Administrator, U.S. Nuclear Regulatory Comission, Region IV; and the NRC Resident Inspector.
. If a hearing is requested, the Comission will issue an Order designating the time and place of the hearing. If the licensee fails to request a hearing within 30 days of the date of this Order, the provisions of this Order shall be effective without further proceedings. If payment has not been made by that time, the matter may be referred to the Attorney General for collection.
In the event the licensee requests a hearing as provided above, the issues to be considered at such hearing shall be:
(a) whether the licensee was in violation of the Comission's requirements as set forth in Violation I of the Notice of Violation and Proposed Imposition of Civil Penalty referenced in Section II above and (b) whether, on the basis of such violation, this Order should be sustained.
FOR THE NUCLEAR REGULATORY COMMISSION
/ l da s M. Tay1
-C l puty Execu ive Director for i Regional Operations !
Dated at Bethesdt, Maryland, this g'd' day of June 1987.
l
1 APPENDIX EVALUATIONS AND CONCLUSIONS On November 12, 19ES, a Notice of Violation and Proposed Imposition of Civil Penalty (Notice) was issued for violations identified during an NRC Safety System Functional Inspection (SSFI). A civil penalty of $50,000 was proposed for Violation I set out in the Notice. Arkansas Power and Light Company responded to Violation I of the Notice by letter on December 12, 1986. In its response the licensee admits that the violation occurred as stated, but argues that certain factors mitigated the scriousness of the violation, and requests mitigation of the proposed civil penalty. The NRC's evaluation and conclusion regarding the licensee's arguments are as follows:
Restatement of Violation (
10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that the design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculation methods, or by the performance of a suitable testing program.
Contrary to the above, design control measures for design change package -
DCP 82-D-1050 failed to properly assess or verify the adequacy of design regarding the potential for a single failure, loss of one power supply, to cause the simultaneous blowdown of both steam generators during a main steam line break accident, a situation outside the plant's design basis.
This condition was caused when the design change package was implemented during the Unit 11984 refueling outage without certain check valves, the purpose of which was to prevent the simultaneous blowdown.
This is a Severity Level III violation (Supplement I).
Civil Perialty - $50,000.
I Suninary of Licensee's Response l
The licensee admits that the Violation I did occur as stated, in that an
, inadequate safet feedwater (EFW)single y evaluation was performed failure scenario for thetosituation identify the specific without emergency certain check valves. The decision to delete the check valves was based on the desire to improve overall system reliability.
The licensee presents arguments related to the safety significance of the violation. The licensee asserts that, while the design basis of EFW system i does consider the loss of offsite power, i.he design basis does not consider a l Main Steam Line Break (MSLB) concurrent with a loss of offsite power. Therefore, it wcald be consistent with the plant's design basis for the scenario described not to consider the loss of offsite power and thus give credit for the operation of the EFW and main feedwater systems.
Appendix The licensee further states, that even without the check valves, the EFW system would have performed adequately during -anticipated transients and accident scent;{os and that a number of long-term measures were available to isolate the steam generators, provide water to the steam generators, or use feed and bleed to achieve safe shutdown. In addition, the licensee asserts that the calculated containment peak pressure would not be increased and the results of the analysis are bounded by current FSAR analyses. Offsite dose consequences were calculated by the licensee to be less than 7% of the 10 CFR Part 100 thyroid limits, even assuming no mitigation of the accident for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
NRC Evaluation of Licensee's Response While it may be that the design basis of the EFW system does not consider a MSLB concurrent with a loss of offsite power, the NRC staff believes that the
. plant's design basis did consider a MSLB concurrent with a single failure, namely the loss of one power supply. This formed the basis of the violation.
Section 14.2.2.1 of the Arkansas Nuclear One, Unit 1 Final Safety Analysis Report describes the accident analysis for a main steam line failure. Section 14.2.2.1.3.1 states that the Emergency Feedwater Instrumentation and Control System is designed to protect against the consequences of a simultaneous blow-down of both steam generators. Section 14.2.2.1.3.3 further states that
" Additional information regarding potential single failures in the emergency feedwater during recovery from a steam line break is included in Table 10-1."
Table 10-1 describes the capability of the EFW system to adequately perform its function under the single failure criteria and specifically the loss of Bus A3 which results in the loss of all AC " red" power. The design basis of the EFW system was not met in the matter at hand in that, when the check valves were deleted from the design, the simultaneous blowdown of both steam generators was not prevented under the circumstances of a main steam line break and the loss of Bus A3, as it should have been as described in Section 14.2.2.1 and Table 10-1 of the FSAR. The design change package, DCP 82-D-1050, was issued and implemented without evaluating the potential for the simultaneous blowdown of both steam generators, a violation of 10 CFR Part 50, Appendix 0, Criterica III.
The licensee asserts that the check valves were deleted to improve the overall EFW system reliability; however, in doing so this created the potential for the simultaneous blowdown of both steam generators during a steam line break, a situation which clearly was intended by design to be prevented. The design change failed to properly evaluate a single failure scenario to ensure that the EFW system would function as intended. !
The licensee contends that, even withcut check valves installed, the consequences of the steam line break accident were within the capability of the plant's systems and structures, relying on manual operator actions. While it appears ,
that these consequences were within the capability of the plant, the staff l generally does r.ot give credit for manual actions for systems which were designed to function automatically. In addition, at the time the design change package was issued and implemented, there had been no evaluation performed to ensure that the EFW system would function during postulated accident and single failure 1
l I
Appendix scenarios, specifically the steam line break accident with the failure of Bus A3.
Without such evaluation and without the check valves installed, the plant was placed in a condition outside its design basis and one for which it was not known whether the EFW system could perform its intended function under all postulated events. This was cause for significant regulatory concern.
Based on the above discussion, the NRC staff considers that the violation did occur as stated in the Notice, that the single failure scenario described in the violation is a design basis event for a main steam line break, and the violation is appropriately categorized as a Severity Level III violation.
Sun # nary of Request for Hitigation of Civil Penalty The licensee asserts that, after the SSFI identification of concerns which in
. part formed the bases for Vf olation I, an insnediate review was performed and notification to the NRC was made. Further, immediate actions were taken to install swing check valves in the steam supply lines and initiate procurement and design efforts to obtain lift check valves.
The licensee contends that, prior to and subsequent to the identification of the deficiancy, the licensee had recognized the need to improve the design modification process, the 10 CFR 50.59 review program and the training of engineers, and had initiated major improvements in these areas.
The licensee also contends that it has demonstrated good performance in the general area of design control and that the violation was somewhat isolated to the specific instance rather than indicative of an overall programmatic failure of the design change process.
NRC Evaluation of Licensee's Response The NRC views the licensee's actions in reporting the design discrepancy as pruder t and appropriate. However, as the discrepancy was identified by the NRC, mitigation for prompt identification and reporting is not warranted.
While the licensee installed check valvec in the steem lines and took other corrective actions to address the programmatic concerns, these actions were not so unusually prompt and extensivo as to warrant mitigation of the civil penalty.
The NRC SSFI team did view the design of the emergency feedwater (EFW) system to be sound in general; however, the SSFI team also identified significant concerns. The licensee's performance in the design control area wcrrants l neither mitigation nor escalation of the proposed civil penalty based on ;
Category 2 and 3 SALP ratings in the areas of operations, maintenance, and surveillance for the past rating periods with a single Category 1 rating in operations in the latest SALP. Therefore, mitigation of the civil penalty was not considered app opriate. l l
i I
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l I
Appendix 1 I
NRC Conclusion l
After careful consideration of the licensee's response, th's NRC staff concludes that the violation is significant in that the. plant was placed in a condition l
outside its design basis and the violation is appropriately classified as a '
Severity Level III violation. The staff also concludes that the licensee has Accordingly, -
not providedcivil the proposed a sufficient penalty inbasis for mitigation the amoent of'the civil of Fifty Thcusand penalty Dollars (.
$50,000) should be imposed.
0 9
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