ML16148A609
| ML16148A609 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 02/03/1992 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML16148A610 | List: |
| References | |
| EA-91-167, NUDOCS 9202260207 | |
| Download: ML16148A609 (7) | |
Text
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES Duke Power Company Docket No. 50-269 Oconee Nuclear Station License No. DPR-38 Unit 1 EA 91-167 During an NRC inspection conducted on November 5-7, 1991, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1991), the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act),
42 U.S.C. 2282, and 10 CFR 2.205. The particular violations and associated civil penalties are set forth below:
A. Technical Specification 6.4.1 requires that the station be operated and maintained in accordance with approved procedures.
10 CFR Part 50, Appendix B, Criterion V (Instructions, Procedures, and Drawings), and the licensee's accepted Quality Assurance Program (Duke Power Company, Topical Report, Quality Assurance Program, Duke-i-A),
Section 17.2.5 (Instructions, Procedures, and Drawings), require that activities affecting quality be prescribed by procedures of a type appropriate to the circumstances and that such activities be accomplished in accordance with these procedures.
The licensee failed to develop adequate procedures and failed to adhere to established procedures, as evidenced by the following violations:
- 1. TT/1/A/251/11, "VOTES Testing of LPI Header MOVS," step 12.1.2, references OP/1/A/1104/04, "Low Pressure Injection System," for aligning the low pressure injection system in the decay removal mode.
Contrary tothe above, OP/1/A/1104/04, as referenced in-TT/1/A/251/11, was inadequate in that it did not contain guidance for aligning the low pressure injection system in'the decay heat removal mode.
Because of this, on September 7, 1991, the low pressure injection system was aligned in the decay heat removal mode without admitting cooling water to the decay heat cooler. This resulted in an unmonitored reactor coolant system heat-up.
- 2. PT/1/A/600/01, "Periodic Instrument Surveillance," required periodic verification for proper operation of various instruments and systems including reactor coolant system temperature at shift change (every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />).
9202260207 920203 PDR ADOCK 05000269 PDR
-2 Contrary to the above, the PT/1/A/600/01 requirement of recording reactor coolant temperature at shift change (every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) was inadequate in that the time interval was too long to ensure that all applicable requirements were being met. Because of this inadequacy, on September 7, 1991, reactor coolant temperature increased from approximately 110 degrees F to 187 degrees F over approximately a four-hour period without being detected by the control room operators.
This resulted in reactor coolant exceeding the 140 degree F maximum temperature specified in TT/1/A/251/11, "VOTES Testing of LPI Header MOVS."
- 3. TT/1/A/251/11, "VOTES Testing of LPI Header MOVS," specifies in subsection 6.3 of section 6.0, "Limit and Precaution" that reactor coolant temperature is not to exceed 140 degrees F during the performance of the VOTES test.
Contrary to the above, on September 7, 1991, activities were not accomplished in accordance with this procedure in that the 140 degrees F maximum reactor coolant temperature was exceeded by 47 degrees F.
- 4. Operations Management Procedure (OMP) 2-1, "Duties and Responsibilities of Reactor Operators, Non-Licensed Operators, and the Senior Reactor Operator in the Control Room," requires the reactor operator to provide surveillance of operations and instrumentation monitored from the control room to ensure the safe operation of the unit. During shutdown periods, the reactor operator shall ensure that continuous safe shutdown conditions exist.
OMP 2-1 also requires that the control room senior reactor operator's primary concern is to ensure the safe operation of the unit from the control room.
Contrary to the above, on September 7, 1991, the control room reactor operators did not ensure that continuous safe shutdown conditions existed in that, over a period of four hours, reactor coolant system temperature increased approximately 77 degrees F when it was expected to be maintained constant at 110 degrees F. Additionally, the control room senior reactor operator's primary responsibility of ensuring the safe operation of the unit was not met in that critical safety parameters were not monitored by subordinate reactor operators.
- 5. Operations Management Procedure (OMP) 1-18, "Communications and EOP Implementation Standard," requires that all operations personnel are responsible for ensuring that effective communication is used during normal and abnormal plant operations. Additionally, when performing.
a.normal evolution, that is, a process that changes the status of a system in the plant, a brief explanation of the evolution, its purpose, action to be taken, and desired outcome shall be given.
Contrary to the above, on September 7, 1991, communications were ineffective in that, in response to the reactor coolant system heat-up, when the control room operators elected to place the A Train low pressure injection system in operation, the operators did not notify the VOTES test personnel that the train had been placed in service. This resulted in the subsequent loss of decay heat cooling when the test personnel cycled one of the system valves closed, interrupting system flow.
B. 10 CFR Part 50, Appendix B, Criterion XIV (Inspection Test and Operating Status),, and the licensee's accepted Quality Assurance Program (Duke Power Company, Topical Report, Quality Assurance Program, Duke-i-A), Section 17.2.14 (Inspection Test and Operating Status), require that, in order to assure that equipment status be clearly evident and to prevent inadvertent operation, nuclear safety-related structures, systems and components which are in an other than operational status be identified as such.
Contrary to the above, on September 7, 1991, equipment status was not evident for Train A of the low pressure injection system. The system was not.in an operational status (the system was being tested) and was not identified as such. The system was lost soon after being called into service for.decay heat removal in response to the elevated reactor coolant system temperature. System flow was lost due to continued testing of the train when a valve was cycled shut by test personnel who were not in contact with the control room.
This is a Severity Level III problem (Supplement I).
Cumulative Civil Penalty -
$75,000 (assessed equally among the six violations under Items A and B.)
C. Technical Specification 6.4.1 requires that the station be operated and maintained in accordance with approved procedures.
10 CFR Part 50, Appendix B, Criterion V (Instructions, Procedures, and Drawings), and the licensee's accepted Quality Assurance Program (Duke Power Company, Topical Report, Quality Assurance Program, Duke-i-A),
Section 17.2.5 (Instructions, Procedures, and Drawings), require that activities affecting quality be prescribed by procedures of a type appropriate to the circumstances and that such activities be accomplished in accordance with these procedures.
The licensee failed to develop adequate procedures and failed to adhere to established procedures, as evidenced by the following violations:
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- 1. OP/1/A/1102/01, "Unit Startup From Cold Shutdown to RCS Temperature and Pressure of 250 degrees F and 350 psig," step 2.5, references OP/1/A/1104/04, "Low Pressure Injection System,,' which requires that the low pressure injection system be aligned in the "switchover mode" of operation as outlined in enclosure 3.9, "LPI ES to Switch over Mode Valve Checklist," prior to exceeding 125 psig reactor coolant system pressure.
Contrary to -the above, on September 19, 1991, activities were not accomplished in accordance with this procedure in that the low pressure injection system was not aligned in the "switchover" mode prior to exceeding 125 psig reactor coolant system pressure. This resulted in the overpressurization of portions of the low pressure injection system and the loss of approximately 12,400 gallons of primary coolant from the system.
- 2. Operations Management Procedure (OMP) 2-1, "Duties and Responsibilities of Reactor Operators, Non-Licensed Operators, and the Senior Reactor Operator in the Control Room," requires the reactor operator to provide surveillance of operations and instrumentation monitored from the control room to ensure the safe operation of the unit. During shutdown periods, the reactor operator shall ensure that continuous safe shutdown conditions exist.
OMP 2-1 also requires that the control room senior reactor operator's primary concern is to ensure the safe operation of the unit from the control room.
Contrary to the above, on September 19-20,,1991, the control room reactor operators did not ensure that continuous safe shutdown conditions existed, and the control room senior reactor operator's primary responsibility of ensuring the safe operation of the unit was not met in that procedures were not followed and reactor system pressure was increased above 125 psig, overpressurizing the low pressure injection system and spilling 12,400 gallons of primary coolant to the auxiliary building floor. Specifically, 1) the control room senior reactor operator was distracted by the outage workload and was not fulfilling his responsibilities pertaining to monitoring overall plant operations and ensuring procedures were followed, 2) the unit supervisor was not sufficiently involved in the control room routine on the day of the event so as to have an understanding of the impact of outage work on operator performance and plant operations, 3) there was inadequate oversight of control room operations by the unit supervisor due to his lack of control room tours during the subject shift, and 4) the reactor operator commenced the reactor coolant system pressurization without first reviewing the procedure.
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- 3. Operations Management Procedure (0MP) 1-18, "Communications and EOP Implementation Standard," requires that all operations personnel are responsible for ensuring that effective communication is used during normal and abnormal plant operations. -Additionally, when performing a normal evolution, that is, a process that changes the status of a system in the plant, a brief explanation of the evolution, its purpose, action to be taken, and desired outcome shall be given.
Contrary to the above, on September 19, 1991, communications were ineffective and a brief of the evolution was not conducted in that the unit supervisor by-passed the control room senior reactor operator when communicating by telephone to the reactor operator to raise reactor coolant system pressure. Additionally, the unit
-supervisor made the communication without reviewing plant status and conducting a briefing with the operating staff. This resulted in the low pressure injection system not being aligned in the "switchover" mode prior to raising reactor coolant system pressure above 125 psig.
D. 10 CFR Part 50, Appendix B, Criterion XVI (Corrective Action), and the licensee's accepted Quality Assurance Program (Duke Power Company, Topical Report, Quality Assurance Program, Duke-i-A), Section 17.2.16 (Corrective Action), collectively require that conditions adverse to quality be promptly identified and correctejd, and that station personnel are responsible for taking appropriate corrective action whenever any deficiency in the implementation of the requirements of the (operational quality assurance) program is determined.
Contrary to the above, corrective action implementation was inadequate in that corrective actions taken by facility management in response to the September 7, 1991 reactor coolant system heat-up event were not effectively implemented to ensure that deficiencies in operator and supervisor responsibilities and watchstanding practices were corrected.
Specifically, station management did not succeed in ensuring that all operations personnel understood station management's expectations with respect to the corrective action. This failure led to continued lapses in the overview of shift operations, in particular, the lack of the unit supervisor and control room senior reactor operator overview of plant.
status, which directly resulted in the September 19-20, 1991, over pressurization of the low pressure injection system and subsequent spill of 12,400 gallons of primary coolant to the auxiliary building.
This is a Severity Level III problem (Supplement I).
Cumulative Civil Penalty -
$50,000 (assessed equally among the four violations under Items C and D.)
- 6 Pursuant to the provisions of 10 CFR 2.201, Duke Power Company (Licensee) is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice of Violation and Proposed Imposition.of Civil Penalties (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each alleged violation: (1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, and if denied, the reasons why, (3) the corrective steps,that have been taken and the results achieved, (4) the corrective steps that will be taken to avoid further violations, and (5) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice. an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
Within the same time as provided for the response required above under 10 CFR 2.201, the Licensee may pay the civil penalties by letter addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, money order, or electronic transfer payable to the Treasurer of the United States in the amount of the civil penalties proposed 'above, or may protest imposition of the civil penalties in whole or in part, by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission. Should the Licensee fail to answer within the time specified, an order imposing the civil penalties will be issued. Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, in whole or in part, such answer should be clearly marked as an "Answer to a Notice of Violation" and may:
(1) deny the violations listed in this Notice in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalties should not be imposed. In addition to protesting the civil penalties in whole or in part, such answer may request remission or mitigation of the penalties.
In requesting mitigation of the proposed penalties, the factors addressed in Section V.B of 10 CFR Part 2, Appendix C (1991), should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers).to avoid repetition. The attention of the Licensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.
Upon failure to pay any civil penalty due which subsequently has been determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised,.remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282c.
- 7 The response noted above (Reply to Notice of Violation, letter with payment of civil penalties, and Answer to a Notice of Violation) should be addressed to:
Director,'Office of Enforcement, U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region II, and a copy to the NRC Senior Resident Inspector at the Oconee Nuclear Station.
Dated at Atlanta, Georgia this5itday of February 1992