ML20035G272
| ML20035G272 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/19/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20035G270 | List: |
| References | |
| EA-93-023, EA-93-23, NUDOCS 9304270067 | |
| Download: ML20035G272 (4) | |
Text
.
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF civil PENALTY Houston Lighting & Power Company Dockets 50-498; 50-499
. South Texas Project Electric Licenses NPF-76; NPF 80 Generating Station EA 93-023 During NRC inspections conducted between September 13, 1992, and February 1, 1993, violations of NRC requirements were identified.
In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C, the Nuclear Regulatory Commission proposes to 4
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:
4 Technical Specification 6.8.1.a requires that written procedures shall be established, implemented, and maintained for those activities recommended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2.
February 1978.
RG 1.33, Appendix A, Jtem 1.d recommends operating procedures for procedure adherence.
STP Procedure OPGP03-ZA-0010, Revision 15, " Plant Procedure Adherence and Implementation and Independent Verification," Step 4.2.1, states, "For performance of procedures which require manipulation of plant equipment, prior to performing any step or group of steps of a procedure, the individual performing that step SHALL first implement the seven step Self Verification program.
i i
The Self Verification program is defined in the procedure and requires that an employee stop and think about the task, locate the device to be operated, touch the device, verify the correct device, anticipate the expected and unexpected responses and the actions to be taken, 1
manipulate the component, and observe for expected and unexpected responses.
3 t
Step 4.2.1.2 of the Self Verification program states " LOCATE device to be operated" and includes the following directions: a) Ensure you are on the correct UNIT; b) Ensure you are on the correct TRAIN; and c) Ensure
]
you are on the correct DEVICE.
3
{
Contrary to the above, from September 28, 1992, through January 9, 1993, l
licensee personnel did not verify the correct device, did not ensure j
j they were on the correct unit, did not ensure they were on the correct t
train or otherwise complete the self-verification program required by a
procedure OPGP03-ZA-0010 in the following eight instances:
A.
On September 28, 1992, Equipment Clearance Order 1-92-8030 was j
issued to allow chemical cleaning of Condenser Waterbox 12N.
Seven of 64 Wated,x outlet bolts for Condenser Waterbox 12S were removed before
.r leakage revealed that work was being conducted on tht arong component.
i 9304270067 930419 PDR ADOCK 05000498 j
G PDR
?
. l B.
On October 12, 1992, work specified by Work Package ll6446-EP01 for Essential Cooling Water Pipe Support EW-Il07-HL5006 was performed on Essential Cooling Water Pipe Support EW-ll28-HL5003.
J C.
On October 19, 1992, an underfrequency trip actuating device operational test was performed on Reactor Coolant Pump 2A whereas work permission had only been given to perform the test on Reactor Coolant Pump 2C.
D.
On October 29, 1992, a local leak rate test was performed on Containment Isolation Valves CV0033A, B, and C whereas the procedure was written for performing the test on Containment j
isolation Valves CV0034A, B, and C
)
E.
On November 2, 1992, while performing Procedure OPSP02-SI-0964,
" Accumulator C Pressure Group 3 ACOT (P-0964)," a technician incorrectly lifted wire TB-J from terminal 7 and wire TB-J from terminal 8 when the procedure called for lif ting wire TB-J from terminal 10 and wire TB-J f rom terminal 11.
F.
On November 5,1992, during final review of Unit 1 Qualified Display Parameter System work packages, it was determined that Service Requests AM-164610 and AM-164611 were performed in Unit 1 on October 30, 1992, whereas the service requests were written for and intended to be performed in Unit 2.
G.
On November 7, 1992, Service Request 173475 was written to repair a steam leak on Heater Drip System Valve N2HDLC7222 whereas the leak was actually on valve N2HDLC7223; this resulted in repairs being made to the leaking valve but not the valve identified on the service request.
H.
On January 9, 1993, a technician failed to implement the seven step Self Verification program while attempting to adjust the high neutron flux setpoint for channel N-0041 from 84.5 to 109 percent.
As a consequence, the setpoint was erroneously set at 99 percent.
l These violations represent a Severity Level 111 problem (Supplement 1).
Civil Penalty - 525,000.
Pursuant to the provisions of 10 CFR 2.201, Houston Lighting & Power Company (Licensee) 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 of Violation and Proposed Imposition of Civil Penalty (Notice).
This reply should be clearly marked as a Reply to a Notice of Violation" and should include for each alleged violation:
(1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, and if denied, the reasons why, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps
7
. that will be taken to avoid further violations, and (5) the date when f ull compliance will be achieved.
If an adequate reply is not received within the time specified in this Notice, an order or demand for information may be issued as to 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 affirmation.
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, money order, or electronic transfer payable to the Treasurer of the United States in the amount of the civil penalty proposed above, 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 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 addition to protesting the civil penalty, in whole or in part, such answer may request remission or mitigation of the penaity.
In requesting mitigation of the proposed penalty, the factors addressed in Section VI.B.2 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 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 any civil penalty due which subsequently has been 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 234(c) of the Act, 42 U.S.C. 2282c.
i e
.i 1 l i
- .i The response noted above (Reply to Notice of Violation, letter with payment of l
civil penalty, and Answer to a Notice of-Violation) should be addressed to:
Director, Office of Enforcement, U.S. Naclear Regulatory Commission, ATTN.
Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Reginn'lV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011 and a copy to the NRC Resident j
Inspector at the South Texas Project.
t t
Dated at Arlington, Texas r
this 19th day of April 1993 l
l t
I i
r
'l i
i i
5 I
r i
l Ii l
[