IR 05000269/1992024

Discusses Violations Noted in Insp Repts 50-269/92-24, 50-270/92-24 & 50-287/92-24 on 920926-1103 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $100,000

ML20127F074
Person / Time
Site:	Oconee
Issue date:	12/28/1992
From:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Hampton J DUKE POWER CO.
Shared Package
ML16148A733	List: IR 05000269/1992024
References
EA-92-211, NUDOCS 9301200132
Download: ML20127F074 (8)

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DEC 2 8- 1902 Docket Nos. 50-269, 50-270 and 50 287 License Nos. DPR-38, DPR-47  ;

and DPR-55 EA 92-211 Duke Power Company ATTN: Mr. J. W. Hampton Vice President Oconee Site Post Office Box 1439 Seneca, South Carolina 29679 Gentlemen:

SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY - $100,000 (NRC INSPECTION REPORT NOS. 50-269/92-24, 50-270/92-24 AND 50-287/92-24)

This refers to the Nuclenr Regulatory Commission (NRC) inspection conducted by Mr. P. Harmon on September 26 - November 3, 1992, at the Oconee Nuclear Station. The inspection included a review of the facts and circumstances related to the degraded low pressure service water (LPSW) system flow condition through a Unit 3 low  !

pressure injection (LPI) coole This condition was identified by the plant staff as a result of a system review performed by .i the NRC Resident Inspector. The report documenting this  ;

inspection was sent to you by letter dated November 16, 1992. As .i a result of this inspection, a violation of NRC requirements was identifie ]!

An enforcement conference was held on November 24, 1992, in the '

NRC Region II office to discuss the violation, its cause, and your corrective actions to preclude recurrenc This enforcement conference was open for public observation in accordance with the- )

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Commission's trial program for conducting open enforcement conferences as discussed in the Federal Register, 57 FR 30762,_ i, July 10, 1992. A summary of the enforcement conference was sent '

to you by letter dated December 9, 199 The violation in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) involved the failure to take-adequate corrective action to resolve a reduced LPSW flow-condition through the 3B LPI coole On September 14, 1992, with Unit 3 in a refueling outage and preparation underway to resume full-power operation, plant personnel initiated LPSW flow testing to verify LPSU system operability. At the start of the flow test for the 3B LPI cooler, LPSW flow to the 3A LPI cooler and the ]

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main turbine oil cooler were isolated, and selected air operated valves were placed in their failed positio In this system configuration, the required flow of.5200 gpm through the 3B LPI cooler could not be achieved using a single LPSW pump-and a subsequent investigation identified that valve 3LPSW-78, a manual isolation valve downstream of the cooler flow control valve, was not fully open due to an actuator problem. This valve is a butterfly valve and the pin connecting the actuator to the stem had dislodged resulting in_the valve being in a throttled position with the handwheel indicating full ope Prior to Unit 3 shutting down for the scheduled refueling outage, the NRC questioned whether the 3B LPI cooler was capable of achieving a LPSW flowrate of 5200 gpm using a single pump, which is necessary for single LPI cooler operation'following~the transfer of the LPI system's suction to the containment sump during postulated loss of coolant accident. The LPSW portion of periodic test PT/3/0150/22A, " Operational Valve Stroke Test,"

which had been performed on June 9, 1992, while Unit 3 was operating at full power, required that a flowrate of 5200 gpm be attained through the applicable LPI cooler. NRC review noted that during the performance of the test of June 9, 1992, 5200 gpm could not be achieved through the 3B LPI cooler with only one LPSW pump running, so the operators in the control room started a second LPSW pump to achieve the required flow. Further review showed that this potential flow deficiency had been evident as early as June 199 In response to NRC questions, your plant personnel (including operators, operations staff, and performance engineering staff)

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explained that the 3B LPI cooler had "always" exhibited lower flow than the 3A LPI cooler, which consistently met the required flow of 5200 gpm with one pump. The operational practice of starting a second pump was not viewed as unusual by the operators given the variable nature of non-safety: loads also being supplied

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during the test and the-fact that this practice.was not prohibited by the procedure. In addition, your staff indicated that the purpose of this procedure was-to test the valves and not to perform a system-flow verification test. During the enforcement conference, your staff maintained-that the judgements

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made by the plant operators were reasonable-given the~ procedure-

, objective and the changing nature of_ flow demands in the LPSW-syste The NRC is concerned with several aspects of this event that contributed to both the event's safety and regulatory significance. The first concern is the 3B LPI cooler's inability to meet the 5200 gpm-flow-requirement with a single pump, assumed in-the plant design basis and specified in the emergency

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operating procedures, for a period of over one year. At the enforcement' conference your staff stated that further analysis indicated the degraded condition would not have impacted plant safet In our_ view, the limited impact of this event was-only fortuitous given that valve 3LPSW-78 could have failed to any partially open position. However, a more significant concern is the operational practice of routinely starting a second LPSW pump to meet the flow requirements of the periodic test. Your explanation of why this practice went unchallenged is not entirely persuasiv The operators assumed that variations in non-safety loads necessitated the starting of the second pump, but no effort was made to verify this assumption through calculations and flow measurement Additionally, even if the variation in non-safety loads is assumed to be a reasonable rationale for starting a second pump, your plant staff never resolved why variations in the B train non-safety loads routinely necessitated starting a second pump and variations in the A train non-safety loads never necessitated a similar actio In summary, our concern is not only that your staff failed to recognize the potential for a degraded condition after a single performance of the periodic test; but, that your staff failed-to adequately resolve the trend indicated by several performances of the periodic test which had been accomplished on both trains under varying plant condition Historically, some problems related to the Oconee LPSW system have been addressed while others remained unresolved. For example, a Self-Initiated Technical Audit (SITA) conducted in 1987 identified several problems related to the LPSW system-that included a lack of LPSW testing and engineering calculations, yet there was no prompt action to_ address those problems. If adequate actions had been taken on those issues, it is likely that the plant staff would have been in aJmuch better position to have identified the flow degradation caused by valve 3LPSW-7 At the enforcement conference, your staff seemed satisfied.in relying on calculations without the benefit of sufficient system testing as a followup verification. 'This is of' concern-because, as illustrated by the degraded flow condition at issue, calculations alone can describe the best estimate condition for a-particular system, but-not its actual operating conditio Operating the LPSW system from June'9 until September 14, 1992, without investigating and correcting the inadequate <3BELPI cooler flow is viewed as a significant safety issue which required-immediate ' resolutio The root cause of this problem was a1 deficiency for which prompt corrective action was not implemented, as well as a lack of management oversight relative to development and implementation of corrective actions.

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Therefore, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," Enforcement Policy 10 CFR Part 2, Appendix C (57 FR 5791, February 18, 1992), this violation has been categorized at Severity Level II The staff recognizes that your staff initiated immediate corrective action to correct the hardware problem associated with the 3B LPI cooler by repairing the affected valve and installing mechanical stops on certain LPSW valves to limit flo in addition, similar LPI valves in Units 1 and 2 were also verified to be fully functiona To emphasize the importance of ensuring that corrective actions for conditions adverse to quality are.promptly developed and implemented, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) in the amount of $100,000 for the Severity Level III violation. The base value of a civil penalty for a Severity Level III violation-is $50,00 The escalation and mitigation factors in the Enforcement Policy were considered. The base civil penalty was escalated by 50 percent for identification because the problem involving the inadequate flow in the 3B LPI cooler and the necessity of usin two LPSW pumps to obtain the required flow was identified by the NR Neither escalation nor mitigation was warranted for corrective action because your immediate corrective actions to address specific hardware problems such as the installation of mechanical stops on the valves and verification of the-operability of valves in the other units.were offset by your failure to develop and implement appropriate management. processes to improve the overall corrective action program in the long ter Escalation of 50 percent was warranted for licensee performance based on previous enforcement history. For example, on

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February 3, 1992, the NRC issued a Notice of Violation and

Proposed Imposition of Civil Penalties (EA 91-167) as a result of an Augmented Inspection Team inspection that reviewed the facts and circumstances associated with the degradation of decay heat removal on September 7, 1991, and the over-pressurization of.the low pressure injection system piping on September 19 and 20, 1991. The letter transmitting the Notice with a proposed civil penalty of $125,000, placed^ emphasis on the need for effective implementation of corrective action and management oversigh Additional escalation for this factor was offset by the overall SALP history for the past two SALP periods that reflects a better

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than average overall SALP score. The.other adjustment factors-were considered, and no further. adjustment to the base' civil penalty is considered appropriate. Therefore, the-base civil penalty has been increased by 100 percen You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your respons In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence including actions you plan to take regarding your overall corrective action program which allowed this violation to occur. After reviewing your response to this Notice, including your proposed corrective actions and the results of: future inspections, the NRC will determine whethe r further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirement In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice,"~

a copy of this letter and its enclosure will be placed11n the NRC Public Document Roo The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of .

Management and Budget as required by the Paperwork Reduction Act (

of 1980, Pu L~. No. 96-51 Should you have any questions concerning this letter, please contact u

Sincerely,

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ORIGINAL SIGNED BY 1.* A+ REYES Stewart D.'Ebneter Regional Administrator Enclosure:

Notice of Violation and Proposed *

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Imposition of Civil Penalty cc w/ encl:

M. E. Patrick Compliance Duke Power Company P. O. Box 1439 Seneca, SC 29679

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cc w/ encl con't: (See next page) y*m --

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Duke Power Company -

6-cc w/ encl con't:

A. V. Carr, Es Duke Power Company 422 South Church Street Charlotte, NC 28242-0001 County Supervisor of Oconee County Walhalla, SC 29621

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Robert B. Borsum, B&W Company Nuclear Power Generation Division 1700 Rockville Pike, Suite 525 Rockville, MD 20852 J. Michael McGarry, III, Es Winston and Strawn 1400 L Street, NW Washington, D. C. 20005 Office of Intergovernmental Relations 116 West Jones Street Raleigh, NC' 27603 Heyward G. Shealy, Chief, B/RH South Carolina Department of Health-and Environmental Control 2600 Bull Street Columbia, SC 29201

' Manager, LIS NUS Corporation 2650 McCormick Drive Clearwater, FL 34619-1035 R. L. Gill NuclearfGeneration Department Mail Stop-EC050 Duke-Power Company _

-P. O. Box 1006 Charlotte, NC 28201-1006 Karen E. Long Assistant Attorney General N._C. Department of Justice

- -P. C. Box 629 Raleigh,-NC 27602 State of South Carolina'

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Distribution:

PDR CA SECY J. Sniezek, DEDR S. Ebneter, RII J. Lieberman, OE J. Luehman, OE J. Partlow, NRR J. Goldberg, OGC Enforcement Coordinators RI, RII, RIII, RIV, RV B. Hayes, OI D. Williams, OIG-V. Miller, SP E. Jordan, AEOD L. Wiens, NRR W. Miller, RII G. A. Belisle, RII A. R. Herdt, RII EA File Day File Document Control Desk NRC Resident Inspector U.S. Nuclear Regulatory Commission Route 2, Box 610 Seneca, SC 29678 Ts_e eJpreviou s y page ~ f o re conc u r r encely ~g}

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