ML20028B985
| ML20028B985 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 12/30/1982 |
| From: | Fiedler P GENERAL PUBLIC UTILITIES CORP. |
| To: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| EA-82-108, NUDOCS 8301050059 | |
| Download: ML20028B985 (11) | |
Text
GPU Nuclear U
N ked Rive, New Jersey 08731 609-693-6000 Writer's Direct Dial Number:
December 30, 1982
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/o 0 Mr. Richard C. DeYoung, Director Of fice of Inspection and Enforcement U.S. Nuclear Regulatory Commission Wa shing ton, C.C.
20555
Dear Mr. DeYoung:
Subj ect : Oyster Creek Nuclear Generating Station Docket No. 50-219 Notice of Violation and Proposed Imposition of Civil Penalties Dated November 30, 1982 In accordance with 10 CFR 2.201, the attachment to this letter provides our responses to the Notice of Violation contained in your letter of November 30, 1982. The responses address the corrective actions taken and the severity level associated with each noncompliance.
As noted therein, we agree with the substance of the noncompliances as stated. However, it is our understanding that the fundamental basis for determining the severity level of a particular violation is the actual or potential impact on the health and safety of the public. Based on the above, we disagree with the severity level III classification of both noncompliances and request that the imposition of civil penalty be eliminated. The reasoning and justification for our position is also presented in the attachment to this letter.
Each incident was reviewed to determine if management controls or established programs were deficient with regard to safe operation and assurance of Technical Specification compliance.
Our review concluded that the two viointions are isolated events not indicative of n rmal performt.nce at Oyster Creek. We also conclude that the two violations are not related in a meani ngful sense, i.e.,
are not "similar" which is defined in 10 CFR 2 as involving " violations which could have been reasonably expected to have been prevented by the licensee's corrective action for the previous violation."
Thus, we consider that the two violations should each be evaluated individually.
8301050059 821230
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PDR ADOCK 05000219 0
PDR GPU Nuc!Nr is a part of the General Pubhc Utmt'es System
Mr. Richard C. DeYoung Page 2
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We understand that the NRC reviews each proposed civil penalty case on its own merits and adjusts the base civil penalty values upward or downward based on defined consideration. Your letter, however, did not describe what factors were considered in the assessment of the civil penalty. Thus, we cannot comment specifically on the magnitude of the civil penalty as proposed.
However, our evaluation of the violations in accordance with published NRC guidance is that violation A is severity level IV and violation B is severity level V.
Civil penalties are not normally imposed for level IV or v violations. In addition, we note that NRC enforcement policy states that the NRC will not generally issue a notice of violation for a violation that has been identified by the licensee, fits a severity level IV or V, was reported by the licensee, was corrected and included measures to prevent recurrence, and was not a violation that could reasonably be expected to have been prevented by corrective action of a previous violation.
We question if any purpose is served by issuing civil penalties for infractions which occurred well in the past and have since been corrected. As discussed at our meeting of May 4,1982 at Region I headquarters, we have taken aggressive and comprehensive action to strengthen control of operation at Oyster Creek and minimize the possibility of future violations.
Based on the enclosed responses as summarized above, we request reconsideration of the violations and deletion of any civil penalty.
If there are any questions, please contact me or Mr. Michael Laggart of my staf f at (609) 971-4643.
Very truly yours,
'bAE (I_ _ : _
Peter B. Fiedler Vice President and Director Oyster Creek d
Sworn to pnd subscribed to before me this d/(7 day of dfff f h 1982.
Ye A
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Notary Public
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PBF:MWL:1s e Attachment
cc: NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, NJ 08731 Mr. Ronald C. Haynes, Administrator Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 l
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ATTACHMENT Violation A as stated in the NRC " Notice of Violation":
i Table 3.1.1, Section H of the Technical Specifications requires that, for each trip function listed in the section, there be a minimum of two operating trip systems capable of isolating the isolation condenser, except for when the reactor temperature is less than 2120F and the vessel head is removed or ve nt e d. The system must be capable of automatically closing two redundant valves in the influent steam line and two redundant valves in the condensate return line of an isolation condenser whenever a high flow condition in either the steam or condensate line is detected.
If this specification cannot be met, the isolation condenser must be manually isolated.
Contrary to the above, between 8:45 p.m. on December 3,1981 and 11:45 a.m. on December 4,1981, while the reactor temperature was greater than 212 F, the trip system for the "A" Isolation Condenser was inoperable in that one of the redundant isolation valves (V-14-30) in the steam influent line to the "A" Isolation Condenser, would not close automatically and the "A" Isolation Condenser was not manually isolated.
This is a Severity Level III Violation (Supplement I).
(Civil Penalty - $20,000)
GPUN Response:
We agree that the decision to declare the Isolation Condenser valve operable, considering the results of the Surveillance Test, was in error. We note that at no time were the Technical Specifications knowingly violated, but rather the violation occurred as a result of a judgement error. The NRC report also questioned the engineering judgement of licensed supervisory staf f members that would lead them to a decision of declaring a component operable in light of the test results that exhibited successive failures prior to operating properly.
An investigation was conducted by licensee management to review the circumstances surrounding the incident and to discuss with the personnel involved, the basis for the decision that resulted in declaring the component operable. Af ter reviewing the incident, it is our opinion that the activities in progress at the time and past experience contributed to the decision to declare the isolation condenser operable. At the time of the occurrence, the plant was experiencing dif ficulties with one of the five electromatic relief valve s.
This dif ficulty required that the surveillance in question be done to assure that the limiting conditions for operation under these circumstances were being met.
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Page 2 GPUN Response:
( Continued)
It was during the surveillance test that difficulties occurred with one of the isolation condenser isolation valves (V-14-30). The Group Shif t Supervisor reports that based on his knowledge of recent incidents of valve binding due to tight packing and several instances of torque switches out of adjustment, he concluded that the original failure to operate had been corrected by the cycling. He did, however, document the occurrence, fill out a deviation report on the failure, and initiate a job order to have the isolation condenser isolation valve (V-14-30) checked by Maintenance. He also notified the Operations Manager at his home. This notification was made to inform the Operations Manager of current plant status and not to seek guidance or a decision regarding valve operability. Thus, the Operat *ons Manager did not make a determination regarding the valve operability as stated in the notice of violation.
Discussion with the Group Shif t Supervisor as to the basis for his actions revealed that the overriding factor af fecting his decision was the previous maintenance history of the valve.
From the maintenance standpoint, he felt since the valve now operated, a maintenance check would not have accomplished anything more than confirmation that the valve was working properly and should be watched in the future.
This incident is considered an isolated event and not indicative of the type of decisions being made daily at Oyster Creek. The Group Shif t Supervisors are in a position of routinely making operating decisions based on review of operational parameters and discussions with cognizant personnel. Past history has shown that in accordance with management direction, for the most part, Group Shif t Supervisor decisions which require the exercise of judgement have been made in the conservative direction.
To help preclude any recurrence, this incident and our conclusion that it involved an error in judgement has been reviewed with all shif t supervisors.
They have also been reinstructed to be conservative in situations involving Technical Specifications regardless of any impact on plant operation, to contact Operations management without hesitation, and to be critical in accepting completed maintenance. The Manager Plant Operations met one-on-one with all Shif t Supervisors to assure adequate communications exist and management's direction is clearly understood.
We disagree with the severity level III classification of this violation. As stated in your letter, the redundant isolation valve, V-14-31, was operable as demonstrated by a surveillance test. Thus, there existed assurance that automatic isolation would have occurred, if needed. This event resulted in a loss of redundarcy, not a loss of function. In addition, the Operations Manager did not declare the valve operable. He was given a status report on the plant, and was not asked to make a determination regarding valve operability. Thus, based on the safety significance and the above clarification regarding the Operations Manager, we believe the severity level should be IV with no accompanying civil penalty.
1 Page 3 CPUN Response: (Continued)
In conjunction with the above, we note that the Technical Specification referenced in the violation (Table 3.1.1, Section H) requires that all four isolation valves be capable of the isolation function. This means that racking out a breaker for preventive or corrective maintenance requires that the isolation condenser be isolated, thereby reducing the redundancy of an alternate heat sink. We are currently evaluating this situation and performing a safety analysis to determine if this is the most conservative specification.
A Technical Specification change request will be submitted to either make the isolation function more explicit or, if our evaluation shows it warranted, to revise it to keep the higher degree of redundancy.
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Page 4 Violation B as stated in the NRC " Notice of Violation":
Technical Specification 3.5.A.3 requires, in part, that primary containment integrity be maintained whenever the reactor is critical or the reactor water temperature is above 2120F with fuel in the reactor vessel.
Section 1.13 of the Technical Specifications defines primary containment integrity and requires, in part, that all automatic containment isolation valves specified in Table 3.5.2 be either operable or secured in the closed position. Table 3.5.2 of the Technical Specifications, entitled Containment Isolation Valves, lists the Reactor Building to Suppression Chamber Vacuum Breakers as Containment Isolation Valves.
Technical Specifications 3.5. A.4.a requires that two reactor building to suppression chamber vacuum breakers in each line shall be operable at all times when primary containment integrity is required.
If this condition is not met, the reactor shall be in cold shutdown in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, subject to the provisions in Technical Specification 3.5. A.4.b.
Technical Specification 3.5. A.4.b permits operation for up to seven days with one inoperable reactor building to suppression chamber breaker provided the vacuum breaker is locked closed and primary containment is not violated.
Contrary to the above, between May 14, 1980 and February 26, 1982, valve V-26-16, which is both a primary containment isolation valve and a reactor building to suppression chamber vacuum breaker, was inoperable because of incorrect reassembly. As a result:
- 1) the automatic isolation function of the valve was inoperable and the valve was not secured in the closed position, and
- 2) only one suppression chamber vacuum breaker was operable during all those periods between May 14, 1980 and February 26, 1982 when the reactor was critical or the reactor water temperature was greater than 2120F with fuel in the reactor vesrel.
This is a Severity Level III Violation (Supplement I)
(Civil Penalty - $20,000)
GPUN Response:
We agree the events as described in the violation are correct. The primary cause of this event was inadequacies in Procedure No. 704.1.010 " Reactor Building to Torus Air Operated Vacuum Breaker Inspection" and Procedure No.
665.5.006 " Local Leak Rate Tests".
Insuf ficient maintenance instructions, contained in Procedure No. 704.1.010, allowed the valve to be assembled i ncor rectly. The leak test did not reveal the initial error because Procedure No. 665.6,006 did not require the test engineer to verify the valve position with the control room prior to performing the test. Both procedures will be revised accordingly. It should be noted that the combination of the two procedural deficiencies was required to cause this violation.
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GPUN Response: (Continued)
An additional corrective action has been to increase supervision at the job site. The maintenance crew size that a first line supervisor directs has been significantly reduced since the occurrence of this event in 1980. The current supervisor to worker ratio is approximately 1 to 6.
Increased supervision of day to day activities has improved the quality of maintenance activities at Oyster Creek.
In order to ensure these valves are not reassembled incorrectly again in the fu t ure, the unused keyways on the valve shaf ts for both air operated vacuum breakers will be physically blocked when the valves are disassembled for future corrective or preventative maintenance. In addition, we will review other valves which may have multi-keyed shaf ts in order to revise the applicable procedures and have the unused keyways blocked.
We disagree with the severity level III classification of this violation.
Supplement 1 of the NRC Enforcement Policy (March 9,1982) describes severity level III as significant violations involving:
1.
A Technical Specificction Limiting Condition for Operation being exceeded where the appropriate Action Statement was not satisfied that resulted in:
I a.
Loss of a safety function; or b.
A degraded condition, and suf ficient, information existed which should have alerted the licensee that he was in an Action Statement condition; 2.
A system designed to prevent or mitigate a serious safety event not being able to perform its intended function under certain conditions (e.g., safety system not operable unless of fsite power is available; materials or components not environmentally qualified);
3.
Serious dereliction of duty on the part of personnel involved in licensed activities; 4.
Changes in reactor parameters which cause unanticipated reductions in margins of safety; 5.
Release of radioactivity of fsite greater than the Technical Specifications limit; or 6.
10 CFR 50.59 such that a required license amendment was not sought.
Page 6 CPUN Response: ( Co ntinued)
Items 2 through 6 clearly do not apply to this violation. With regard to Items la and Ib, a Technical Specification Limiting Condition for Operation was exceeded and the appropriate action statement was not satisfied; however, this did not result in either:
a.
A loss of safety function.
As referenced in your letter and in the NRC inspection report, the redundant train, valves V-26-15 and V-26-16 would have performed the vacuum relief function for the torus, if needed.
If containment isolation was called for, valve V-26-17 in the af fected train and valves V-26-15 and V-26-16 in the redundant train would have performed the isolation function. This event resulted in a loss of redundancy, not a loss of function. Attached is a sketch of the above system for clarification purposes.
b.
A degraded condition with suf ficient information existing to alert the licensee that he was in an action statement condition.
As stated in the corrective action section of this response, a leak test had been performed and reported as satisfactory. It is clear now that the test had been done improperly. However, information available and reviewed at that time and right up to the recent leak test which revealed the error, was not suf ficient to indicate to licensee that he was in an action statement condition. The next scheduled performance of the leak test, in February 1982, disclosed the valve misalignment. The violation was promptly identified, corrected, and reported by us.
Our Licensee Event Report No. 50-219/82-12/0lT identifies the safety significance of this event as follows:
The vacuum relief system from the reactor building to the pressure suppression chamber consists of two 100% vacuum relief breaker subsystems (2 parallel sets of 2 valves in series). The purpose of the vacuum relief valve is to equalize pressure so that containment external design pressure limits are not exceeded.
Operation of either subsystem will maintain the suppression chamber external pressure less than its design pressure of 1 psi. With redundant loop (V-26-15 and 16) performing its intended vacuum relief function, the safety significance is considered minimal.
Page 7 Re s ponse :
(Continued)
Each redundant loop contains a vacuum breaker check valve and an air operated vacuum breaker in series (V-26-15, V-26-16, and V-26-17, V-26-18). Both valves in each loop are considered primary containment isolation valves. The air operated vacuum breakers (V-26-16 and V-26-18) are normally closed during reactor operation. Also, they will close on a high drywell pressure signal.
Upon total loss of air supply to the valve operator, the valves will both fail in the open position. With the incorrect valve shaf t alignment that existed, if V-26-18 indicated closed, the dise was actually in the open position. The vacuum breaker check valve in this loop (V-26-17) was verified in the "as found" condition to be leak tight. With V-26-17 in this loop performing its intended isolation function and the redundant loop (V-26-15, V-26-16) performing its inter,ded isolation function, the safety significance is considered minimal.
The NRC Enforcement Policy describes Severity Level V as violations that have minor safety or environmental significance. Based on the safety significance for both the vacuum relief function and the isolation function, and that at the next scheduled opportunity we identified, corrected, and promptly reported the event, we believe the severity level should be a level V with no accompanying civil penalty imposed.
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