ML19325E265
| ML19325E265 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/25/1989 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19325E264 | List: |
| References | |
| EA-89-158, NUDOCS 8911060010 | |
| Download: ML19325E265 (4) | |
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NOTICE OF VIOLATION-AND PROPOSED IMPOSITION OF CIVIL PENALTY Public Service Company of New Hampshire Docket No.
50-443 E
Seabrook Station License No. NPF-67 EA 89-158 On June 28 - 30, 1989, an NRC Augmented Inspection Team (AIT) inspection was conducted at the Seabrook Station to establish and evaluate the facts associ-ated with an event which occurred at the facility on June 22, 1989.
Based on an evaluation of the event and the findings of the AIT inspection, 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, (1989), the Nuclear Regulatory Commission (NRC) 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 associ-ated civil penalty are set forth below:
A.
10 CFR Part 50, Appendix B, Criterion V, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, appropriate to the circumstances. The procedures or drawings shall include appropriate acceptance criteria for determining that important activities have been satisfactorily acenmplished.
10 CFR Part 50, Appendix B, Criterion XI, requires, in part, that a test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Test procedures shall include provisions for assuring that all prerequisites for the given test have been met, and test results shall be documented and evaluated to assure that test requirements have been satisfied.
1.
Seabrook Startup Test Procedure 1-ST-22, entitled Natural Circulation Test, Attachment 9.3, Section B.5, sets forth the manual trip criteria for the test, and requires that the test be terminated and the reactor tripped if pressurizer water level is less than 17%.
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Contrary to the above, during the performance of Startup Test Procedure 1-ST-22 on June 22, 1989, pressurizer level decreased below 17% and the reactor was not tripped by the operating shift as required.
2.
Seabrook Startup Test Procedure 1-ST-22, Section 3.0, Prerequisites, Step 3.6.7 requires a sign-off confirming the availability of the steam dump, including the atmospheric relief valves, as a prerequisite to the test.
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8911060010 891025 QDR ADOCK 050 m
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Contrary to the above, prior to the performance of Startup Test g
i Procedure 1-ST-22 on June 22, 1989, Step 3.6.7 was signed off by the Test Director confirming the availability of'the main steam dump system (includes valve No, MS-0V-3011); however, at the time, the valve was not ready to support the test because Work Order No. WR7W005592 (which requires a stroke test of the valve at normal operating temperature and pressure) was still open.
3.
Seabrook Startup Test Procedure 1-ST-22, Section 3.0, Prerequisites, Step 3.2 requires a signoff confirming that personnel involved with the performance of the procedure have been briefed on the procedure content and informed of the respective duties.
Contrary to the above, prior to the performance of Startup Test Procedure 1-ST-22 on June 22, 1989, Step 3.2 was signed off by the Test Director confirming the adequacy of the pre-test briefing; l
however, the briefing was inadequate in that one of the two control t
board operators assigned to assist the shift crew was not briefed on the procedure's reactor trip criteria.
4.
Seabrook Operations Managen.ent Manual, Section 1.8, requires that shift evolution briefings shall be conducted for individuals involved in the performance of an evolution. This section also states, in part, that complex evolutions requiring close coordination of individuals should include examinations of each individual's specific involvement and responsibility.
Contrary to the above, prior to the performance of Startup Test Procedure 1-ST-22 on June 22, 1989, the shift briefings were inadequa'.e in that the briefings were conducted in a fragmented manner and not for the operations crew as a group, and the briefings were not sufficiently detailed.
For example, the briefings did not cover each operator's specific involvement, responsibility, and understanding of the required interfaces and communications.
B.
10 CFR Part 50, Appendix B, Criterion XVI, requires, in part that measures be established to. assure that conditions adverse to quality are promptly identified and corrected.
Contrary to the above, meas.ures were not adequately established to assure that a condition adverse to quality was promptly identified and corrected as evidenced by the following examples:
1.
During the performance of Startup Test Procedure 1-ST-22 on June 22, 1989, the Startup Manager, the Shift Test Director, and the Test Director became aware of a condition adverse to quality, but failed to ensure that the condition was promptly corrected.
The adverse condition consisted of the pressurizer level dropping below the trip criteria specified in the test procedure and the failure of the operations staff to trip the reactor as required.
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t Notice of Violatio'n 3
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Subsequent to the June 22, 1989 failure to promptly effect a manual reactor trip as required by the criterion in Startup Test Procedure 1 ST-22, licensee management did not promptly identify and correct associated personnel performance failures in that management initially made a decision to resume testing without completing a detailed and thorough analysis of the underlying causes of the event and without correcting the related human performance deficiencies.
Theso violations are classified in the aggregate as a Severity Level III problem (Supplement I).
Civil Penalty - $50,000 - assessed equally among the six violations Pursuant to the provisions of 10 CFR 2.201, Public Service Company of New Hampshire 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.
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 viola-tion if admitted, (3) the corrective steps.that have been taken and.the results achieved, (4) the corrective steps that will be taken to avoid further viola-tions, and (5) the date when full compliance will De achieved.
If an' adequate reply is'not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.
Consid-eration 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 under 10 CFR 2.201, the Licensee may pay the civil penalty by letter to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, or money order payable to the Treasurer of the United States in the amount of the civil penalty proposed above, or may protest imposition of the civil penalty 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 penalty will be issued.
Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the notice of violation and proposed imposition of civil penalty, in whole or in part, such answer should be clearly marked as an " Answer to a Notice of Violation and Proposed Imposition of Civil Penalty" and may:
(1) deny the violatias listed in this Notice in whole or in part; (2) demonstrate extenu-ating cirTJmstances; (3) show error in this Notice; or (4) show other reasons why the p:.nalty should not be imposed.
In addition to protesting the civil penalty, in whole or in part, such answer may request remission or mitigation l.
of the penalty.
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In requesting mitigation of the proposed penalty, the factors addressed in Section V.B of 10 CFR Part 2, Appendix C, 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 ihe applicable provision 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.
The responses to the Director, Office of Enforcement, noted above (Reply to a Notice of Violation, letter with payment of civil penalty, and Answer to a Notice of Violation and Proposed Imposition of Civil Penalty) 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, Region I, U.S. Nuclear Regulatory Commission, 475 Allendale Road, King of Prussia, Pennsylvania 19406, and a copy to the NRC Senior Resident Inspector, Seabrook Station.
FOR THE NUCLEAR REGULATORY COMMISSION j
Original Signed By UlLLILF. T. EJSSELL Willian T. Russell Regional Administrator Dated al King of Prussia, Pennsylvania this AO day of October 1989 l
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