IR 05000325/1987045
| ML20247M886 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 03/16/1989 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Utley E CAROLINA POWER & LIGHT CO. |
| References | |
| EA-88-316, NUDOCS 8904060145 | |
| Download: ML20247M886 (5) | |
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MAR 161989 Docket No.
50-325 License No.
DPR-71 EA 88-316 Carolina Power and Light Company J
ATTN:
Mr. E. E. Utley j
Senior Executive Vice President Power Supply and Engineering and Construction Post Office Box 1551 Raleigh, North Carolina 27602 Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT N0. 50-325/87-45)
This refers to the Nuclear Regulatory Commission (NRC) inspection conducted on -
December 14-21, 1988, at the Brunswick Steam Electric Plant.
The inspection l
included a review of two simultaneous events that individually resulted in the ~
loss of Unit I secondary containment integrity during the period of December 11-14, 1988.
The report documenting this inspection was sent to you by letter dated
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December 30, 1988.
Significant failures to comply with NRC regulatory require-ments were identified as a result of this inspection. We discussed the inspec-tion findings with you in an Enforcement Conference held on January 13, 1989.
A summary of this conference was sent to you by letter dated January 30, 1989.
The enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) describes Technical Specification violations which resulted in the loss of secondary containment integrity while irradiated fuel assemblies were being moved to conduct fuel sipping operations.
Secondary containment integrity is necessary whenever irradiated fuel is handled to ensure that, in the event of a dropped assembly, any radioactive gases released are processed through the standby gas treatment (SBGT) system prior to elevated dispersal to minimize ariy gr00iid leielTilease.
Both an operable $3CT system ar.d cpcr bic rcacter building ventilation' secondary containment isolation dampers (SCID) are required to perform this safety function.
The first violation involved an inoperable SBGT system. On December 14, 1988, the resident inspector noted that the inlet isolation valve for SBGT train B did not indicate open at its respective motor control center (MCC).
Subsequent review revealed that the inlet isolation valves on both trains of the SBGT system were only 5 percent open, rendering the system inoperable.
Factors contributing to this problem included deficiencies in design, training, procedures, and operator actions.
In 1984, you were aware that Unit 1 differed from Unit 2 in that the Unit.1 isolation valves did not automatically open on SBGT initiation.
Had the Unit 1 design been updated to conform with Unit 2, 8904060145 990316 g
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Carolina Power & Light Company-2-MARi$ W
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I this particular situation would not have resulted in an inoperable SBGT system.
In addition, the confusing control room design for the inlet valve position indication contributed directly to the operators believing the valves were open.
Notwithstanding the confusing design, this event could still have been prevented had the operators been better trained on the anomaly between the misleading valve indication in the control room and at the local control board, and the actual valve indication found on the respective MCC and locally at the valve. Although the procedure for SBGT operation has contained a caution for this indication anomaly since 1983, neither the fuel sipping procedure nor the periodic SBGT filter leak test, which was performed just prior to the time of the event, informed the operators about this potential pitfall or referenced the SBGT operating procedure for valve alignment purposes.
Lastly, we agree with the statement made in the enforcement conference by your plant manager that routine operator plant tours should have identified the " intermediate" position indication on the MCC prior to its being discovered by our resident inspector.
The second violation involved all four 72-inch reactor building ventilation SCIDs (two supply and two exhaust in series) being inoperable during the same time-frame as the fuel handling evolution which took place while SBGT was inoperab.le.
Operators discovered this problem when one damper failed to reposition during
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testing on December 16, 1988.
Subsequent review revealed that the portion of the instrument air system needed to reposition these dampers had been inadver -
tently isolated on December 9, 1988, due to a licensed operator who failed to do an adequate operations clearance review.
This clearance review was apparently quite complicated and required several hours to complete.
The number and complexity of drawings that the operator had to refer to contributed to the error of isolating the air supply to the SCIDs.
Although accumulators are provided to reposition these dampers in case instrument air is lost, subsequent leak checks by your staff revealed that all four dampers would not have received sufficient air pressure to assure that they would have shut and remained sealed during the entire fuel handling evolution.
Each of the events which resulted in the violations individually rendered Secondary Containment Integrity inoperable at a time when it was required by Technical Specifications.
Even though we recognize that a postulated fuel handling accident with the conditions present at the time of these events would l
result in only-a minor radioactive release within 10 CFR Part 100 limits, we
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are concerned about the broad breakdown of checks and balances that allowed this to happen.
Ili order to emphasize the significance of safety systems being unable to perform their intended function, I have been authorized, after l
consultation with the Director, Office of Enforcement, and Deputy Executive Director for Nuclear Materials Safety, Safeguards, and Operations Support, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of One Hundred Fifty Thousand Dollars ($150,000) for the violations described in the enclosed Notice.
In accordance with the " General Statement of
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Policy and Procedures for NRC Enforcement Actions," in 10 CFR Part 2, Appendix C (1988) (Enforcement Policy), the violations described in the enclosed Notice have each been categorized as a Severity Level III.
The base value of a civil penalty for a Severity Level'III violation is $50,000.
The escalation and mitigation factors in the Enforcement Policy were considered for each violation as discussed below.
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Carolina' Power & Light Company-3-MAR 1e m
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The inoperable SBGT system was identified by the resident inspector after numerous operator plant tours had the opportunity to identify the problem, but failed. The NRC believes that you should have reasonably identified this violation through the' routine operator tours, and the base civil penalty is therefore escalated by 50 percent.
Your corrective actions discussed at the enforcement conference focused on the design deficiencies, but did not adequately address indicated weaknesses in your training program. We believe operator training should focus on design differences between the two units, and more significantly, on those system design anomalies that are counter to accepted plant convention. Therefore, no mitigation or escalation was applied to this factor.
Your past performance is considered weak.
Though you have initiated plans to conduct safety system functional inspections to identify other possible design problems as a long term solution for system and hardware deficiencies, personnel error and inatten-tion to detail at Brunswick remains a concern to the NRC. An escalated enforce-ment action was taken in July 1988 because operator error and inattention to
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detail resulted in a second uncontrolled plant heatup within four months. To emphasize our continued concern, the base penalty has been increased by another
50 percent for pocr past performance.
No further escalation or mitigation du.e to prior notice or duration is considered appropriate.
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The second violation, inoperable SCIDs, was identified on December 16, 1988,
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when your operators attempted to reposition the dampers to test a design modi-fication.
No mitigation is considered appropriate for identification because the condition existed for 10 days and was not found until after the fuel sipping was complete.
No further escalation or mitigation was deemed appro-priate based on your corrective actions and past performance.
Your stated
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plans that include the upgrade of your equipment clearance process and correction of various design deficiencies identified by you are offset by a continuing concern with operator attention to detail.
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 actions taken and any additional actions you plan to prevent recurrence.
Your response should address what actions are being taken to sensitize your staff on the conduct of plant tours, to review the need-to improve your procedures and drawings used for establishing j
equipment clearances, and to ensure that your system engineering staff becomes l
I involved in the de' sign review of plant systems.
After reviewing your response to this Notice, including your proposed corrective actions.and the results of further inspections, the NRC will determine whether further enforcement action is necessary to ensure compliance with NRC regulatory requirements.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
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i Carolina' Power & Light Company-4-MAR 16' W J
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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 I.
by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
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Should you have any questions concerning this letter, please contact us.
Sincerely,
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Stewart D. Ebneter Stewart D. Ebneter Regional Administrator Enclosure:
Notice of_ Violation and Proposed Imposition of Civil Penalty cc w/ encl:
R. B. Starkey, Jr., Manager
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Brunswick Nuclear Project
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J. L. Harness, Plant General Manager State of North Carolina
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Carolina Power and Light Company-5-
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POR LPDR SECY CA HThompson, DEDS JTaylor, DEDR JLieberman, OE MErnst, RII LChandler, 0GC TMurley, NRR
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SVarga, NRR i -i Enforcement Coordinators
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RI, RII, RIII, RIV, RV WRuland, Resident Inspector FIngram, GPA/PA BHayes, 01 SConnelly, 01A
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EJordan, AE0D
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WTroskoski, OE 0E:Chron OE:EA DCS The State of North Carolina i
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