ML20024A737
| ML20024A737 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 06/02/1983 |
| From: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Tucker H DUKE POWER CO. |
| Shared Package | |
| ML20024A738 | List: |
| References | |
| EA-83-041, EA-83-41, NUDOCS 8306220171 | |
| Download: ML20024A737 (4) | |
Text
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JUN 0 21983
- Dde Power Company ATTN: Mr. H. B. Tucker, Vice President Nuclear Production Department
'422 South Church Street Charlotte, NC 28242 Gentlemen:
SUBJECT:
PROPOSED CIVIL PENALTIES:
EA 83-41 (REFERENCE INSPECTION REPORT NOS. 50-269/83-11, 50-270/83-11, AND 50-287/83-11)
A special inspection was conducted by NRC Region II inspectors on March 17-28, 1983, to determine the circumstances leading to two apparent violations of Technical Specification (TS) Limiting Conditions for Operation (LCO). The findings from this inspection were discussed at an Enforcement Conference held in the Region II office on March 23, 1983. At that meeting, the Regional Administrator related NRC safety concerns to Duke Power Company management. The chronology'of events and the violation identified are presented in the enclosed Noticc of Violation and Proposed Imposition of Civil Penalties.
Itie inspection findings indicate that on March 17, 1983, a test valve on the Oconee Unit 3 reactor building emergency air lock was found to have been left open, apparently after the performance of an NRC required surveillance conducted om December 17, 1982. The test valve should have been closed when the surveil-lance was completed. This failure, combined with a leaking equalization valve
.for the inner hatch, provided a pathway for air flow from the reactor building to-the envi.ronment. Meticulous attention to maintaining the operability of the containment system is both necessary and required.
The integrity of containment systems 13 a vital part of the engineered safety systems designed to protect the public,in-event of an accident.
NUREG-0737 suggests that one means of ensuring operability of engineered safety systems is to provide independent verification ofoperability/bypersontotherthanthosewhoperformedworkonsuchasystem.
In this case, this check of operability was not performed nor was it required as a part of the procedure.
i
- s
- 'n aThe inspection findings also-indicatesthat the Oconee facility's compliance with s
the requir ements of an NRC Confirmatory Order dated July' 10, 1981, was inade-
-quate..That Confirmatory Order' confirmed a Duks : Power Company (DPC) commitment 3
.to review and revise procedures to ensure operability of' systems after perform-ance of maintenance. A'similar failure, involving inadequate restoration of containment in,tegrity in March 1982, due to the lack of procedures requiring y
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CERTIFIED MAIL RETURN SECEIPT REQUESTED j
8306220171 830602
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independent verification of operability, led to the imposition of a civil penalty by NRC Order dated October 12, 1982.
In the letter traasmitting that Order, the Director, Office of Inspection and Enforcement, asked DPC to reexamine its program for independent verification of correct performance of operating activities to ensure that verifications were performed in accordance with paragraph I.C.6 of NUREG-0737.
Duke Power Company's actions in response to this request to reexamine its commitments to the NRC failed to prevent the violations of containment integrity addressed in the enclosed Notice of Violation.
In addition to the March 17, 1983 event, on March 21, 1983, the emergency air lock inner door on Oconee Unit I was found to be cracked open.
In this case, however, no direct leakage pathway existed for air to flow from the reactor containment to the environment.
It appears that inadequate training and poor communications between the personnel involved contributed to this second example of a breach of containment integrity. The procedure that applied to this situation was inadequate in that, despite local and remote (control room) indication that the inner door was open, operating and maintenance personnel failed to recognize the unsatisfactory condition.
It appears, once again, that the basic cause was a failure to provide a satisfactory method of verifying operability of the system after maintenance.
The NRC attaches importance to comprehensive licensee programs for detection, correction, and reporting of problems that may constitute, or lead to, violation of regulatory requirements. We are concerned about the violations themselves; however, the violations take on more sigificance because: (1) you have a prior history of similar violations with the same causal factor; (2) you had prior notice of problems of a similar nature and failed to take effective actions to avoid future occurrences; and (3) you clearly had sufficient information available so you should have known these violations existed. The violations have been categorized as Severity Level III (Supplement I) pursuant to the NRC Enforcement Policy published in the Federal Register, 47 FR 9987 (March 9, 1982).
For the reasons stated in the Notice of Violation and Proposed Imposition of Civil Penalties, we have concluded that a total penalty of One Hundred and Eighty Thousand Dollars should be assessed.
Each Severity Level III base penalty has been increased by 25 percent for failure to adequately implement corrective action for a prior similar problem. An additional 25 percent has been applied because prior rotice of this problem had been given to DPC by NUREG-0737, at an enforcement conference on May 21, 1982, and in our Order Imposing Civil Monetary Penalties dated October 12, 1982. The resultant penalty for each violation is, therefore, Sixty'Thousand Dollars.
After consultation with the Director of the Office of Inspection and Enforcement, I have been authorized to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalties in the cumulative amount of One Hundred and Eighty Thousand Dollars as set forth in the Notice enclosed with this lette. You are required to respond to the Notice and should follow the instructions specified therein when preparing your response. Your reply to this letter and the results of future inspections will be considered in determining whether further action is appropriate.
JU N 0 21983.
' Ouke Power Company 3
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice" Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosure will be placed in the NRC's Public Document Room.
The responses directed by this letter and the enclosure are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Sincerely, James P. O'Reilly Regional Administrator b
Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalties cc w/ encl:
J. Ed Smith, Station Manager
Duke Power Company 4
l l
bec w/ encl:
Hon. Daniel R. McLeod V. Stello, DEDROGR Attorney General EDO Reading File Robert C. Dennis Of fice Building Regional Administrator, RII P. O. Box 11549 Enforcement Director, RII Columbia, SC 29211 Resident Inspector, Oconee Regional Distribution Rudolph Mitchell, Chairman ACRS Public Service Comm.
J. Crooks, AE00 111 Doctor's Circle CA Columbia, SC 29203
- Document Management Branch IE Files LPDR NSIC PDR TIC J. Lieberman, ELD Enforcement Director, RI, RIII, RIV, RV
'J. Axelrad, IE (1 copy by Fax and 1 copy by Express Mail)
R. C. DeYoung J. H. Sniezek E. Jordan J. Taylor IE/EA File IE/ES Circulation (6)
IE/ES CHRON H. Denton, NRR M. Williams, NRR E. Conner, NRR B. Hayes, OI J. Cummings, OIA F. Ingram, PA SECY
- The original RII concurrence copy goes to the DMB thru IE:ES N
o w n o p' IE:ES AD:ES ELD RII DD:IE D:IE GBarber JAAxelrad Lieberman M
kett JHSniezek RCDeYoung 5/ /83 5/
/83 5/
/83 83 5/
/83 5/ /83
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