ML20024A726
| ML20024A726 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 04/22/1983 |
| From: | Allan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20024A724 | List: |
| References | |
| EA-83-026, EA-83-26, NUDOCS 8306220159 | |
| Download: ML20024A726 (5) | |
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l NOTICE OF VIOLATION AND PROPOSED IMPOSITION 0F CIVIL PENALTY Pennsylvania Power and Light Company Docket No. 50-387 Susquehanna Steam Electric Station, Unit 1 License No. NPF-14 EA No. 83-26 During an NRC inspection conducted between January 12, 1983 and March 8, 1983, violations of NRC requirements were identified. One violation involved (1) the inadequate review and approval of a maintenance activity, which resulted in inoperability of both subsystems of the standby gas treatment system (SGTS) in violation of a technical specification limiting condition for operation (LCO);
and (2) the failure to recognize this condition when sufficient information l
existed in the control room. The other violation involved the failure to report to the NRC that both subsystems of SGTS were inoperable at the same time.
On February 28, 1983, at approximately 11:20 a.m., SGTS subsystem "A" was taken out of service to remove test canisters from the charcoal filter beds. The appropriate equipment release form (ERF), prepared by the maintenance department prior to this activity, specified that during the performance of this activity, cross-tie dampers TD 07560A and TD 07560B were required to be blocked shut to provide personnel protection. When the ERF was reviewed by the unit supervisor, he directed that circuit breaker No.11 on panel 1Y236 and circuit breaker No.
11 on panel 1Y246 be opened to disable the power supply to the cross-tie dampers.
The preparation, review, and approval by maintenance and operations personnel of the ERF and tag permit authorizing the opening of the breakers apparently was done without realizing that these breakers also supply control power to both SGTS fans discharge vanes and other SGTS equipment. With the breakers open, these discharge vanes would not have opened as required on_the initiation of the SGTS, thus rendering both SGTS subsystems inoperable in violation of an LCO.
Several damper and instrument indications were lost on control room panel OC 681 when the circuit breakers were opened. Also, an SGTS instrument power failure alarm was received for both subsystems. Although the SGTS subsystem "A" alarm and indications were expected as a result of equipment tagouts for maintenance, the_SGTS subsystem "B" alarm and attendant indications ~should have put operators on notice that both subsystems were inoperable.
Nonetheless, the indications and alarms were not adequately investigated, and the alarms were not entered into logs during shifts and at shift turnovers as required by procedure, indi-l cating operators were not aware of the inoperability of both SGTS subsystems.
l On March 1,1983, at approximately 11:30 a.m., an attempt was made to start SGTS l
subsystem "A" upon completion of the maintenance activity.
The "A" SGTS sub-system fan started but -tripped after fifteen seconds on low air flow. After the No.11 circuit breakers on panels 1Y236 and 1Y246 were closed, and after a retest
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1; was unsuccessful as a result of an unrelated SBGT system heater problem', a /t subsequent retest demonstrated operability pfjGTS subs 9 stem "A", at;d* the s g subsystem was declared operable at 12:10 a.rni Oa March:1, 1983.
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00 p.m. that bott SGT) 3yQ appears that the licensee did not recognize unti M :
1 subsystems had been inoperable during the entlyWeriod the circuit bredersg A "3 g
These events were not reported to the NRC Operations Center >as ( g iV$ 'T.
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o In. order to emphasize the 'rieie_d for improvemedtshn:i(1)3hNrocessfor reviewing l Oi 4
and approving maintenance activities to assure these activities do not af,.fect i
safe plant operation; and (2) alarm response procedures, and'trt.ining ofs
.{Q operating personnel in responding to and investigating r@ rms dnd,, indications, so that the facility is operated in accordance with technical sp yification's,-
the Nuclear Regulatory Commission proposes to impose a'c'ivil penalty in the 1
amount of Sixty Thousand Dollars (560,000) for the viot tion set forth in 1
Section I of this Notice.
In accordance with.the NRC-Enforcement Policy (10 Yu CFR 2, Appendix C), 47 FR 9987 (March 9,,1982), and persi'pt to Section 234 of
-4 y the Atomic Energy Act of 1954, as amended, 42 U.S.C.'2282, PLi36-295 and 10 g id CFR 2.205, this particular violation and its associated civil penalty is set forth below:
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VIOLATION ASSESSED A CIVIL PENALTY i
Technical. Specification 6.8.1.a require { writte( procedures be established, implemented and maintained covering the procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978.
Contrary to the above, the required written procedures-were not established, implemented, and maintained, as evidenced below. As.a result, from approximately 11:20 a.m. on February 28, 1983 until approximately 12:10 p.m. on March 1, 1983, when the average reactor coolant temperature
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exceeded 200 F, both SGTS subsysten,s were inoperable in violation of Technical Specification 3.6.5.3, and action Was not taken within one hour I to place the reactor in cold shutdown within tne's'ubsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in violation of Technical Specification 3.0.3.
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Section 1.c of Appendix A requires procedures for equipment control.
Administrative Procedure AD-QA-306, Revision 32, " System / Equipment Release" Section 6.4.1.a requires that shift supervision, upon receipt of an equipment release form, review the form for complete-ness regarding the equipment and blocking requested. Attachment "B", Section 1 to Administrative Procedure AD-QA-306, Revision 2 requires that shift supervision ensure that adequate levels of system availability will exist after removal of the equipment / system to maintain safe operation. Administrative Procedure AD-QA-103, Revision 2, " Protective Permit and Tag System," Section 6.4.1.c requires that shift supervision evaluate blocking requests upon receipt of an equipment release form, taking into account the adequacy of the blocking and technical specification requirements.
However, on February 28, 1982 maintenance was performed on SGTS sub >,
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' system "A", a safety-related system, which was not properly prepla ped y
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and performed. An equipment release ~ form and associated tag permit, authorizing maintenance on SGTS subsection."A," including the opening of circuit breaker No. 11 on panel 1Y236 and circuit breaker No. 11 s
on panel 1Y246, were; reviewed and approved by shift supervision without appr w riate drawings acd without recognition that these breakers supply control power to the SGTS subsystem fans "A" and "B" discharge vanef..
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Section 1.g.of Appendix A requires procedures for shift and relief turrovers. ' Administrative Procedure AD-QA-303, Revision 0, " Shift Routine," section 6.1.6.c requires that oncoming personnel complete and sign the appropriate section of the shift turno'ver sheet to indicate that control room panels and alarms have been reviewed.
3 However, tke shift turnover sheet for February 28 through March 1, 1983 i'did not indicate that oncoming personnel, during their required review of tieWontrol room panels and alarms, identified the indicators which signaled {GTS inop'trability.
SectidE 1.h of kppendix A' raquires procedures for log entries.
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Adginistrati'.3 Procedure,A,0-QA-303, Revision 0, " Shift Routine,"
ssc*.4cn 6.2:5?d requires that log entries include occurrences of g
significaritN nnunciatpr dlarms and actions taken in response to the clarms.' bih%ithstanding this procedure, no control room log entry was madeT W 1n'dicate the activation of these alarms or any actions t
taker. inn (esponse'to the alarms.
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Sectic6 d of Appendix.A'rcouires that each saf'ety-related annunci-
,N ator should have its cvn w'rittestprocedure, which should normally containtheimmediateope.cationhetion.
How per, Alarm Response Procedure AR-29-001, Revision 0 was not in acco-dance with section 5, as it did not specify the immediate
,in opetition action to be talten to investigate the operability of the SGTS subsystems upon receipt of an SGTS subsystem instrument failure alarm.
This is a Severity Level III violation (Supplement I) c Civil Penalty - $60,000 s
i II. VIOLATION NOT ASSESSED A CIVIL PENALTY i
10 CFR 50.72 requires the NRC Opera 6 on Center be notified as soon as possible and in all cases within o'ne hour of any event requiring initiation of the shutdown of the reactor in accordance with a technical specification limiting condition for operatio7, or any event resulting from personnel l
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error or procedural inadequacy which, during normal operations, anticipated operational occurrences, or accident conditions, prevents or could prevent, by itself, the fulfillment of the safety function of those sytems important to safety that are needed to limit the release of radioactive material to acceptable levels.
Contrary to the above, at approximately 3:00 p.m. on March 1, 1983, the licensee recognized that both SGTS subsystems which function to limit the release of radioactive material to 10 CFR 100 limits following a loss-of-coolant accident, had been inoperable from approximately 11:20 a.m. en February 28, 1983 until approximately 12:10 p.m. on March 1, 1983, a condition which resulted from personnel error and procedural inadequacy, and requiring initiation of a shutdown because of violation of Technical Specification Limiting Condition for Operation 3.6.5.3, and the NRC Operations Center was not notified of this occurrence.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Pennsylvania Power and Light Company is hereby required to submit to the Director, Office of Inspection and Enforcement, USNRC, Washington, D.C.
20555, with a copy to this office, within 30 days of the date of this Notice a written statement or explanation, including for each alleged violation:
(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, the response shall be submitted under oath or affirmation.
Within the same time as provided for the response required above under 10 CFR 2.201, Pennsylvania Power and Light Company may pay the civil penalty in the amount of Sixty Thousand Dollars (560,000) or may protest imposition of the civil penalty in whole or in part by a written answer. Should Pennsylvania Power and Light Company fail to answer within the time specified, the Director, Office of Inspection and Enforcement will issue an order imposing the civil penalty in the amount proposed above.
Should Pennsylvania Power and Light Company elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, such answer 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 penalty should not be imposed.
In requesting mitigation of the proposed penalty, the five factors addressed in Section IV(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 by specific reference (e.g., citing page and paragraph numbers) to avoid repetition.
Pennsylvania Power and Light Company's attention is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.
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Upon failure to pay the civil 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, remitted, or mitigated may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282.
FOR THE NUCLEAR REGULATORY COMMISSION ORIGINAL SIGieu BY:
JAMES V ALLAN James M. A,.lan Acting Regional Administrator Dated at King of Prussia, Pennsylvania this,71dayofApril,1983 i
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