ML19354D605
| ML19354D605 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 12/19/1989 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Tucker H DUKE POWER CO. |
| Shared Package | |
| ML19354D606 | List: |
| References | |
| EA-89-178, NUDOCS 8912280207 | |
| Download: ML19354D605 (7) | |
Text
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DEC 191989 Docket No. 50-414 Licen e No. NPF-52 i
EA 89-178 Duke Power Company ATTW:' Mr. H. B. Tucker, Vice President Nuclear Production Department 422 South Church Street Charlotte, NC 28242 Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY - $50,000 (NRC INSPECTION REPORT NOS. 50-413/89-25 and 50-414/89-25 This refers to the Nuclear Regulatory Commission (NRC) inspection conducted by W. T. Orders and M. S. Lesser at the Catawba facility on August 1 - 28 and September 12 - 15, 1989.
The inspection included a review of two separate events relating to the operability and reliability of the auxiliary feedwater system.
The report documenting this inspection was sent to you by letter dated September 25, 1989.
As a result of this inspection, failures to comply with 4
NRC regulatey requirements were identified, and accordingly, NRC concerns relative to the inspection findings were discussed in an Enforcement Conference held on October 12, 1989.
The letter summarizing this Conference was sent to you on October 26, 1989.
The violation described in Section I of the enclosed Notice of 'iolation and Proposed Imposition of Civil Penalty (Notice) involves your f6;.ure to take adequate corrective action following the Turbine Driven Auxiliary Feedwater Pump (CAPT) surveillance test failures of July 31, 1989.
During the perfor-mance of the test, the turbine oversped and trirped three consecutive times due to governor valve stem sticking caused by coirosion on the stem surface.
Following these failures, your immediats corrective action consisted of manip-ulating the governor valve and associated linkages.
Though this served to temporari'y free the valve stem, you failed to identify the ongoing corrosion problem. -When the surveillance test was performed immediately after the mechanical exercising of the governor linkages, the CAPT met the procedural acceptance critaria and was declared operable.
It should have been recognized that the test eas not adequate to demonstrate the ability of the CAPT to perform its. intended design function because the linkage had been manipulated prior to performing the surveillance test, thus pre-conditioning the system.
However, the corrosion problem persisted and caused the valve stem to bind again.
Consequently, the CAPT oversped and tripped during the next scheduled start on August 7, 1989.
Bated on our revitw, several deficiencies became apparent with the implementation of your testing and corrective maintenance programs as well as your process to determine system operability.
Though there is a declaration of initial inoperability in the control room log, the CAPT was declared operable and the completed surveillance test was signed-off as satisfactorily completed without any indication that three separate test failures hau occurred, the reasons for the failures, or the corrective action taken.
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DEC 191989 Duke Power Company
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Additionally, work conducted to loosen the valve stem was not authorized by your procedures.
Your corrective maintenance program requires that a work request be generated to inspect and repair identified deficiencies.
Personnel performing the test did not initiate a work request and the shift supervisor failed to question their actions or operability determination.
This led to work being i
conducted on safety-related equipment outside the scope of the approved programs i
and the subsequent failure to document activities and correct the deficiency prior to returning the equipment to service.
After management became aware that maintenance was performed without a work request, prompt corrective action to assure compliance with station administrative controls was not taken.
During the days following the test failures on July 31, 1989, concerns reman d e
with your maintenance staff regarding the implications of the overspeeding event and the possibility that the root cause may not have been determined.
Furthrtrmore, an adequate evaluation of available information was not performed prior to removing a redundant auxiliary feedweter pump and associated support equipment from service while those concerns remained unresolved.
Though it was initially thought that the problem was caused by using the wrong lubricant on the valve linkages, you failed to actively follow up this potential generic concern by testing the CAPT on the other unit.
This matter is of significant regulatory concern because the CAPT was prematurely driclared operable following three successive failures without adequate understanding of the root causes.
The number of plant groups including engineers and operators, involved in this violation and tne length of time needed to achieve satisfactory resolution demonstrates the need for greater management attention.
Therefore, to emphasize the importance of aggressive problem resolution and conducting corrective actions within established programs and procedures, I have been authorized, after consultation with the Director, Office of Enforce-ment, and the 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 $50,000 for the violation described in Section I of the enclosed Notice.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, (1989)
(Enforcement Policy), the violation described in Section I of the enclosed Notice has been categorized as a Severity Level III violation.
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.
No escalation was deemed warranted for identification and reporting because the problem was discovered by you after the pump failed a pre-maintenance test requested by the resident inspectors.
No mitigation is warranted for your corrective actions because, though sufficient, they did not address the aspect of determining equipment operability after multiple test failures without assuring that the root cause was satisfactorily addressed.
Consequently, no adjustment of the base civil penalty amount has been deemed appropriate.
The violations described in Section II of the enclosed Notice involve the defeat of the automatic swapover feature of the " assured" source of makeup water for the motor driven auxiliary feedwater pumps and the subsequent failure by an operator to promptly respond to observed control room alarms which indicated the condition.
During this time, the turbine driven auxiliary feedwater pump was inoperable so that modifications and pipe flushing evolutions could be
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Duke Power Company DEC 191939 I
performed.
A step in the pipe flushing procedure was poorly worded and lacked a caution step to maintain the valves in automatic.
Consequently, the operator p
placed the control board switches from the Auto position to the Close position i
even though the valves were already closed.
This rendered the auxiliary feed-I water pump's safety-related " assured" flowpath automatic swapover function 1
inoperable, Another contributing factor was an apparent lack of understanding on the part o
L of the operator as to the safety requirements of the swapover feature.
Specifi-l cally, the operator should have recognized the significance of placing the switches in the close position.
It is expected that operators assure that procedural steps are understood and results anticipated prior to performing the steps.. The inoperable condition was immediately illuminated on the 1.47 Bypass Panel; however, the associated audible alarm was not functional nor had it been operable since initial licensing of the Unit.
The failure to have the audible alarm operable, as assumed in your FSAR, represents a design change for which no safety evaluation was prepared.
Bocause you identified and immediately corrected this problem, no citation will be issued for this licensee-identified violation.
It is reasonable to assume the inoperability of the auxiliary feedwater pumps would have been quickly recognized, had the audible alarm been functional.
Nevertheless, the visual alarm was observed some five minutes later by the operator.
Prompt corrective action was not initiated, however, to determine the nature of the alarm nor was supervision informed until the condition was identified by the NRC resident inspector.
Because of the extremely small likelihood that neither of the two non-seismic
. water sources would have been available during the period of time involved, these violations have been categorized at Severity Level IV.
Nevertheless, we are concerned about the safety implications of the errors that contributed to the violation of technical specifications and expect comprehensive corrective actions to be taken.
1 You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.
In your re-sponse, you should document the specific actions taken and any additional actions you plan to prevent recurrence.
In doing so, you should also consider actions ~that you have taken, or plan to take, to assure that personnel responsible for conducting surveillance tests clearly understand under what conditions the component or system must be declared inoperable, and what actions they are required to take prior to returning the component or system back to service.
After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether
-further NRC 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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L DEC 191989 Duke Power Company 4
The responses directed by this letter and enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Redi,ction Act of 1980, Public Law No.96-511.
Should you have any questions concerning this letter, please contact us, t
Sincerely,
@ Stewart D. Ebneter al S W By:
Stew 4
- d. Ebneter Regional Administrator
Enclosure:
Notice of Violation and Proposed Ittposition of Civil Penalty cc w/ enc 1:
T. B. Owen, Station Manager Catawba Nuclear Station P. O. Box 256 Clover, SC 29710 A. V. Carr, Esq.
Duke Power Company 422 South Church Street Charlotte, NC 28242 J. Michael McGarry, III, Esq.
Bishop, Cook, Purcell and Reynolds 1400 L Street, NW Washington, D. C.
20005 North Carolina MPA-1 3100 Smoketree Ct., Suite 600 P. O. Box 29513 Raleigh, NC 27626-0513 Heyward G. Shealy, Chief Bureau of Radiological Health South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 Richard P. Wilson, Esq.
Assistant Attorney General S. C. Attorney General's Office P. O. Box 11549 Columbia, SC 29211
f l' uke Power Compar.y DEC 191989 Michael Hirsch Federal Emergency Management Agency 500 C Street, SW, Room 840
'1 Washington, D. C.
20472 North Carolina Electric Membership Corporation 3400 Sumner Boulevard P. O. Box 27306
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Raleigh, NC 27611 L,
Karen E. Long Assistant Attorney General N. C. Department of Justice P. O. Box 629 Raleigh, NC 27602 Saluda River Electric Cooperative, Inc.
P. O. Box 929 Laurens, SC 29360 S. S. Kilborn, Arra Manager
-Mid-South Area ESiD Projects Westinghouse Ele'.tric Corporation MNC West Tower Bay 239 P. O. Box 335
- Pittsburg, PA 15230 County Manager of York County York County Courthouse York, SC 29745 l-Piedmont Municipal Power Agency 100 Memorial Drive Greer, SC 29651 State of South Carolina
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