IR 05000445/1993041

Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000 for Violation Noted in Insp Repts 50-445/93-41 & 50-446/93-41

ML20059C344
Person / Time
Site:	Comanche Peak
Issue date:	12/30/1993
From:	Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
Shared Package
ML20059C348	List: IR 05000445/1993041 ML20059C361
References
EA-93-275, NUDOCS 9401050115
Download: ML20059C344 (5)

Text

.- g p atCO UNITED STATES . ?g NUCLEAR REGULATORY COMMISSIOM y [ j REGION IV ,

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Docket Nos. 50-445 and 50-446 '

License Nos. NPF-87 and NPF-89 EA 93-275 -

TU Electric ATTN: W. J. Cahill, Jr., Group Vice President Nuclear Engineering and Operations Skyway Tower 400 North Olive Street, L.B. 81 Dallas, Texas 75201 SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY -

$50,000 (NRC INSPECTION REPORT N0. 50-445/93-41; 50-446/93-41)

This is in reference to the inspection conducted October 26-November 3, 1993, -

at the Comanche Peak Steam Electric Station (CPSES) nuclear power plant, Units 1 and 2. This special inspection was conducted to review the circumstances surrounding the accidental release of approximately 24,000 gallons of contaminated water to the containment floor and sumps in two separate events which occurred on October 26, 1993. A report documenting the results of our inspection was issued on November 24, 1993. On December 2, 1993, you and other TU Electric representatives attended an enforcement conference in the NRC's Arlington, Texas office to discuss NRC's preliminary conclusion that potentially significant violations of NRC requirements had occurre As described in the inspection report in more dstail, the events that prompted this inspection occurred with CPSES Unit 1 in a refueling outage with the fuel stored in the spent fuel pool and the reactor vessel drained down below the steam generator nozzles to facilitate eddy current testing of two steam generators. A portion of the refueling cavity remained flooded to approximately 23 feet above the level of the reactor vessel flange. This area was isolated from the drained portion of the refueling cavity and partially drained vessel by a 40-foot tall refueling cavity lift gate, which is equipped with a pneumatic sea On October 26, 1993, at approximately 9:50 a.m., the pneumatic seal was inadvertently depressurized, allowing 18,000 to 20,000 gallons of contaminated water to flow into the drained portion of the refueling cavity, into the reactor vessel, through the coolant loops, out the open steam generator manways on Steam Generators 1 and 4, and onto the containment floor and sum The lift gate seal was depressurized when auxiliary, nonlicensed operators were in the process of switching the seal pressurization source from the plant's service air system to a nitrogen bottl Later on the same day, approximately 4,000 gallons of water was inadvertently sluiced from the flooded refueling cavity to the drained portion of the refueling cavity, allowing the water to flow into the reactor vessel and out the steam generator manways. This event occurred when operations personnel attempted to transfer G

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water from the flooded portion of the refueling cavity to the refueling water storage tan These events did not threaten the safety of the reactor fuel, which was stored in the spent fuel pool, and did not result in injuries or contamination of-personnel. Although the first event posed a potential risk to personnel -

involved in steam generator eddy current testing, fortunately none were in the ;

steam generator bowls or steam generator compartments at the time of the incident. Jespite these mitigating factors, the NRC remains concerned about *

these events because they were caused by a combination of inattention to ;

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design control requirements, a failure to use established procedures, a failure to assure that existing procedures were adequate in all respects, a *

lack of control of licensed activities by shift supervision, poor communications between shift personnel, poor decisions by the very personnel that TU Electric was relying upon to improve field activities, i.e., field support supervisors, and a failure to pay sufficient attention to prior NRC information regarding pneumatic seals (Information Notice 88-92). Although TU Electric asserts that its efforts to improve personnel performance have been successful and is able to produce data to support this assertion, there are nonetheless similarities between these events and previous problems, such as the May 1992 loss of spent fuel pool cooling event (EA 92-107), in the areas ,

of personnel performarce, communications and attention to detai Based on the NRC's review of information developed during the inspection and the information exchanged during the enforcement conference, the NRC has ,

determined that seven violations of requirements occurred. The violations !

are: 1) A failure to assure that refueling gates and seals were included in !

an operational quality assurance program; 2) a failure to assure that ,

materials and equipment essential to the safety-related function of the r refueling cavity lift gate were adequately controlled; 3) a failure on the part of the involved personnel to use existing procedures for establishing :

pressure to the refueling cavity lift gate seal; 4) a failure to conduct prejob briefings prior to the initial hookup of the lift gate seal apparatus *

or the subsequent changes of pressure supplies; 5) a failure to assure proper authorization for contract personnel who manipulated the pressurization source to the cavity lift gate seal; 6) a failure to assure that existing procedures provided adequate instructions for assuring a reliable pressure source to the l lift gate seal; and 7) a failure to assure that existing procedures cautioned i operators to the potential for sluicing water from one side of the lift gate :

to the other when suction valves on both sides of the refueling cavity lift gate were opened simultaneousl t From the NRC's perspective, these violations represent a significant lack of attention to licensed responsibilitie In addition, the failure to :

adequately control licensed activities created an unnecessary risk to ;

personne It was fortuitous that the events did not result in injuries to or contamination of individuals. Thus, the NRC has classified the violations in *

the aggregate as a Severity Level III problem in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (Enforcement Policy).

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TU Electric -3-TU Electric appears to have taken or initiated action to address all of the factors that played a significant role in or contributed to the occurrence of '

these events and violations of requirements. These actions, which were described in your enforcement conference handout, included immediate actions !

to protect against a recurrence of the events, decontaminate the affected ;

areas, increase monitoring of fuel building gates, assign a system engineer to gates and seals, provide additional training, and form a task team to conduct an in-depth evaluation of the events. As a result of the task team findings, '

TU Electric has planned action to address several issues related to personnel performance, the condition of safety-related materials such as the lift gate seal, the control of components that perform a safety-related function such as pre-staged hoses, and the adequacy of procedure To emphasize the importance of ensuring control of licensed activities, I have been authorized after consultation with the Director, Office of Enforcement to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) in the amount of $50,000 for the Severity Level III problem described abov The base value of a civil penalty for a Severity Level III problem is $50,00 [

The civil penalty adjustment factors in the Enforcement Policy were considered i but resulted in no change to the base value. This determination was based on the following considerations: 1) TV Electric's co rective actions appeared to warrant a decrease equal to 50 percent of the base value; and 2) TU Electric's failure to include the refueling cavity lift gate in the plan developed in response to NRC Information Notice 88-92 appeared to warrant an increase equal to 50 percent of the base value. The remaining adjustment factors were considered but no further adjustments were deemed appropriate, t Three additional apparent violations that are not discussed above were '

described in the inspection report and were discussed at the enforcement conference. These included an apparent failure to properly translate a minor modification into design drawings, an apparent failure to inform shift ,

supervision of the near-depressurization of the refueling cavity lift gate seal on October 24, 1993, and an apparent failure to complete a ONE Form on .

October 24, 1993, for known leakage from the lift gate seal. Based on the NRC's review of the information TU Electric provided at the enforcement conference, these issues are not being cited as violations. However, the NRC maintains that communications were poor with regard to the difficulties ,

encountered in pressurizing the lift gate seal on October 24, and that shift :

supervision should have been made aware of these difficultie '

TU Electric is required to respond to this letter and should follow the ,

instructions specified in the enclosed Notice when preparing its response. In -

its response, TU Electric should document the specific actions taken and any additional actions it plans to prevent recurrence. After reviewing TU Electric's response to this Notice, including its proposed corrective actions

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and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory ,

requirement ,

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TU Electric -4-In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy _ of i this letter and its enclosure will be placed in 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 i by the Paperwork Reduction Act of 1980, Pub. L. No. 96-51 ,

pncerely, e il egional Administrator Enclosure: Notice of Violation and Proposed Imposition of Civil Penalty cc w/ Enclosure:

TU Electric  :

ATTN: Roger D. Walker, Manager of Regulatory Affairs for Nuclear Engineering Organization

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Skyway Tower 400 North Olive Street, L.B. 81 Dallas, Texas 75201 Juanita Ellis President - CASE 1426 South Polk Street Dallas, Texas 75224 GDS Associates, In Suite 720 1850 Parkway Place  ;

Harietta, Georgia 30067-8237 TU Electric Bethesda Licensing 3 Metro Center, Suite 610 Bethesda, Maryland 20814 .

Jorden, Schulte, and Burchette ATTN: William A. Burchette, Es Counsel for Tex-La Electric [

Cooperative of Texas 1025 Thomas Jefferson St., Washington, D.C. 20007

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Newman & Holtzinger, ATTN: Jack R. Newman, Es !

1615 L. Street, !

Suite 1000 '

Washington, l Texas Department of Licensing & Regulation ATTN: G. R. Bynog, Program Manager /

Chief Inspector  ;

Boiler Division l P.O. Box 12157, Capitol Station  :

Austin, Texas -78711  !

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Honorable Dale McPherson County Judge P.O. Box 851 Glen Rose, Texas 76043 i

Texas Radiation. Control Program Director r 1100 West 49th Street -

Austin, Texas 78756 ,

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