ML20010H589
| ML20010H589 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 09/02/1981 |
| From: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20010H588 | List: |
| References | |
| EA-81-070, EA-81-70, NUDOCS 8109280065 | |
| Download: ML20010H589 (3) | |
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j APPENDIX NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Niagara Mohawk Power Corporation Docket No. 50-220 Nine Mile Point Nuclear Station License No. DPR-63 Unit 1 EA 81-70 An inspection conducted at the Nine Mile Point Nuclear Station, Unit 1, Scriba, New York on July 29, 1981, discovered that with the reactor mode swi;ch in "Run," the emergency cooling isolation key-lock switches hao been placed in a bypass condition.
The bypassing of these switches defeated the emergency core cooling systems' automatic isolation functions which are designed to limit the release of radioactive materials to the environment in the event of an accident.
This was caused, in part, by a failure to follow an administrative control requirement which provided for verifying that the applicable technical speci-fication was followed. The Nuclear Regulatory Commission proposes to impose a civil penalty in the amount of $50,000 for this event which indicates a weak-ness in your controls over facility operations and a need for increased and dedicated management attention to provide your plant staff with the necessary elements of motivation to prevent recurrence of this type cf evenc.
In accurdance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), 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, PL 96-295, and 10 CFR 2.205, in the amount set forth for the violation listed below:
Technical Specifications, Table 3.6.2c, " Instrumentation that Initiates or Isolates Emergency Cooling", states that the minimum number of tripped or operable trip systems required for isolation of each Emergency Cooling System is one for the Emergency Cooling Vent Radiation Monitors and two for Emergency Cooling System Steam Line High Flow.
j Technical Specification 6.8.1 states that written procedures and administrative policies shall be established, implemented. and maintair.ed 1
that meet or exceed the requirements and recommendations of Sections 5.1 and 5.3 of ANSI N18.7-1972 and Appendix "A" of USAEC Regulatory Guide 1.33.
Administrative Procedure APN-2A, Revision 5, dated February 20, 1981, Section 4.2 states that a log of all station equipment, which may limit station output or which must be normally operable as defi;ied in Technical Soecifications or which may require cognizance of Quality Control prict to placing in service, shall be maintained in the Station Shift Supervisor's office wnenever the equipment or system is not capable SYo$000ff0 PDR l
Appendix (Continued) '
of performing its intended function in its required manner.
The Status Log shall include the applicable Technical Specification paragraph, and verification of review.
Contrary to the above, on July 29, 1981 with the reactor mode switch in "run," both Eme gency Cooling System isolation logic key-lock switches were found to bc in the " bypass" position, thus defeating both the High Radiation and the Steam Line High Flow isolation functions.
As a result, no isolation trip systems were operable for either Emergency Cooling System.
Further, the Equipment Status Log did not indicate either a review or verification of the technical specification applicable to the removal from service of these required functions.
As a result of this failure to fully implement APN-2A, the licensee failed to prevent making the emergency cooling system isolation trip systems inoperable.
This is a Severity Level III violation (Supplement I).
(Civil Penalty - $50,000).
t Pursuant to the provisions of 10 CFR 2.201, Niagara Mohawk Power Corporation is hereby required to submit to this office within thirty days of the date of this Notice a written statement or explanation, including:
(1) admission or denial of the alleged violation; (2) the reasons for the violation if admitted; (3) the corrective steps which 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.
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, Niagara Mohawk Power Corporation may pay the civil penalty in the cumulative amount of Fifty Thousand Dollars or may protest imposition of the civil penalty in whole or in part by a written answer.
Should Niagara Mohawk l
Power Corporation fail to answer within the time specified, this office will issue an order innposing the civil penalty in the amount proposed above.
Shoulo Niagara Mohawk Power Corporation elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, such answer may:
(1) deny the violation listed in this Notice in whole ur in part; (2) demonstrate extenuating circum-stances; (3) show error in this Notice; or (4) show other reasons why the penalty should not be imposed. In addition to protesting the civil penalty in whole or in part, such answer may request remission or mitigation of the penalty.
Any written answer in accordance with 10 CFR 2.205 should be set forth deparately from the statement or explanation in reply purs m t to 10 CFR 2.201, but may incorporate by speci"ic reference (e.g., giving p Ne and para-j graph numbers) to avoid repetition.
Niagara Mohawk Power Corporation's
Appendix (Continued) attention 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 has been subsequently deter-mined 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. 2282.
The responses directed by this Notice are not subject to the clearance pro-cedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
FOR THE NUCLEAR REGULATORY COMMISSION J
Victor Stel o, Jr.
- Director, Office of Inspect' n and Enforcement Dated at Bethesda, Maryland this 2nd day of September,1981 i
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