ML19354D610
| ML19354D610 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 12/19/1989 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19354D606 | List: |
| References | |
| EA-89-178, NUDOCS 8912280216 | |
| Download: ML19354D610 (5) | |
Text
{{#Wiki_filter:- NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY i Duke Power Company Docket Nos. 50-413, 50-414 Catawba Nuclear Station License No. NPF-52 Unit 2 EA 89-178 During the Nuclear Regulatory Commission (NRC) inspection conducted on August 1-28 and September 12-15, 1989, violations of NRC requirement 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 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 penalty are set forth below: l I. Violation Assessed A Civil Penalty 10 CFR Part 50, Append x B, Criterion XVI requires that measures be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the nieasures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management. Technical Specification 6.8.1 requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33 (RG 1.33) Revision 2, February 1978. Appendix A of RG 1.33 requires the establishment of administrative procedures for the conduct of safety-related activities and procedures for operation, maintenance, and testing, as appropriate to the circumstances. The Administrative Policy Manual for Nuclear Stations, Section 3.3.2.3, established pursuant to RG 1.33, requires that maintenance be performed under the control of the Work Request System in accordance with written procedures which conform to applicable codes, standards, specifications and criteria. Section 3.3.2.5 requires that, in the event of an equipment failure, the cause shall be evaluated and equipment of the same type shall be evaluated to deteruine whether or not it can be expected to continue to function in an appropriate manner. Station Directive 3.3.7, Work Request Preparation, established pursuant to RG 1.33, states that the Work Request is the basic document of the Maintenance Management Program for corrective and preventive maintenance and that employees requesting maintenance assistance are required to comply with the provisions of the program. q912280216 891219 -{DR ADOCK 05000414 -PDC
7 F Notice of Violation L o Maintenance Management Procedure 1.0, Work Request Preparation, established pursuant to RG 1.33, further defines Work Request requirements including L authorization and definition of work to be performed, documentation of clearance to begin work, procedures to be used, description of maintenance activities performed, and documentation of retest activities and acceptance by operations, i Station Directive 3.2.2, Development and Conduct of the Periodic Test r Program, Section 6.0, established pursuant to RG 1.33, requires that, for any reason a surveillance test fails to meet acceptance criteria, the ' Shift Supervisor shall ensure that the proper course of action for returning the equipment to operable status is pursued. p i Station Directive 3.1.14, Operability Determination, established pursuant to RG 1.33, states.that when responsible station personnel believe a-component is operable but have concerns related to it, necessary actions l shall be taken expeditiously to resolve the concerns, identify any root l cause,.and confirm operability. -These actions shall include additional testing, engineering evaluations, and calculations or inspections, as appropriate to the circumstances. The directive further requires an " Operability Evaluation Form" to be completed to document the concern, the basis for the evaluation, and any alternate methods of compensatory measures needed to fulfill the component's safety function. Contrary to the above, on July 31, 1989, the Turbine Driven Auxiliary Feedwater Pump (CAPT) failed a surveillance test on overspeed, and the root cause of the failure was not determined, nor was adequate corrective action taken to preclude repetition. After the CAPT failed the surveillance test the Shift Supervisor did not assure that the proper course of action was taken to return the equipment to operable status. The maintenance activities were not performed under the control of the Work Request System. Consequently, the root cause of the CAPT overspeed trip was not determined prior.to returning it to service. This directly contributed to the CAPT trip on the subsequent surveillance test performed on August 7, 1989. This violation has been evaluated as a Severity Level III violation (Supplement I). Civil Penalty.- $50,000 II. Violations Not Assessed A Civil Penalty A. Technical Specification 3.7.1.2 requires at least three independent steam generator auxiliary feedwater pumps and associated flow paths be operable in Modes 1, 2 and 3. With three auxiliary feedwater pumps inoperable, immediate corrective action to restore at least one auxiliary feedwater pump to operable status as soon as possible must be taken. l' Contrary to the above, on September 12, 1989, with Unit 2 in Mode 1, the associated flow path for all three auxiliary feedwater pumps
y ~ l .= lw L Notice of Violation f were inoperable for a period of about 35 minutes, and immediate corrective action was not taken. } This is a Severity Level IV violation (Supplement I) B. . Technical Specification 6.8.1 requires that written procedures be i established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33 (RG 1.33), Revision 2, February 1978. Appendix A of RG 1.33 requires the establish-E ment of procedures covering operation, maintenance, and testing, as } appropriate to the circumstances. Contrary to the above: 1. Performance Test PT/2/A/4200/59, Nuclear Service Water (RN) to I Auxiliary feedwater (CA) Piping Flush, which was written to implement the requirements of RG 1.33, was inadequate in that Step 12.2.6 requires the operator to " Ensure the following valves are closed: 2CA-15 and 2CA-18;" however, the procedure failed to require the operator to ensure that the control board switches for the valves remained in the AUTO position. This t' contributed to the oparator incorrectly placing the switches in y the CLOSE position on September 12, 1989, with Unit 2 in Mode 1. 2. Operations Management Procedure 1-8, Authority and Responsibility of Licensed Reactor Operators and Licensed Senior Reactor Operators. which was written to implement the requirements of RG 1.33, requires the Operator At The Controls (OATC) to ensure the Control Room Supervisor is notified of all abnormal conditions and to ensure that appropriate followup action is taken for all alarms. This procedure was not implemented. Specifically, on September 12, 1989, the OA10, after having observed the "CA Train A Bypassed" and "CA Train B Bypassed" alarms illuminated on the 1.47 Bypass Panel, failed to notify the Control Room Supervisor of the alarms and failed to initiate prompt followup action. 3. Operating Procedure OP/2/B/6100/07E, Annunciator Response For 1.47 Bypass Panel, which was written to implement the require-ments of RG.1.33 requires the exact cause of each light illu-minated on the panel to be determined and the verification that any equipment required to be operable by Technical Specifications and causing an alarm is operable or is properly declared inoper-able. This procedure was not adequately implemented. ' Spec-ifically, on September 12, 1989, the OATC failed to determine the cause of the light on the 1.47 Bypass Panel or to verify that the motor driven CA pumps causing the alarm were inoperable, or properly declared inoperable, until prompted by the NRC. This is a Severity Level IV violation (Supplement I). I .m.
1 ) Notice of Violation l t Pursuant to the provisions of 10 CFR 2.201, Duke Power Company 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: (1) admission or denial of the violation, j (2) the reasons for the violation, if admitted, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps which 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 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. 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 af firmation. Within the same time as provided for the response required above under 10 CFR 2.201, the Licensee may pay the civil penalty by letter addressed 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 the cumulative amount of the civil penalties if more than one civil penalty is proposed, 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 civil penalty, in whole or in part, such answer should be clearly marked as an " Answer to a Notice of Violation," and may: (1) deny the violation (s) listed in this Notice, L in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalty should not be im-posed. In addition to protesting the civil penalty, such answer may request remission or mitigation of the penalty. In requesting mitigation of the proposed penalty, the factors addressed in Section V.B of 10 CFR Part 2, Appendix C (1989) should te 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 the penalty due, which has been subsequently 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, remit-ted, or mitigated, may be collected by civil action pursuant to Section 234c of the the Act, 42 U.S.C 2282.
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- 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 l
Notice of Violation) should be addressed to: Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, l DC 20555, with a copy to the Regional Administrator, Region II and a copy to the NRC Resident Inspector, Catawba Nuclear Station, j FOR THE NUCLEAR REGULATORY COMMISSION 1 i MI SIBR8d 97! t F Stevet D. Ebneter Stewart D Ebneter Regional Administrator j u Dated at Atlanta, Georgia l thisliM5dayofDecember1989 j k r 1 = l.. t- + h a l[ 4u----- w -aw- ,y- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _., _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _., _. _ _ _ _ _ _ _}}