ML20035G289
| ML20035G289 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/19/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20035G281 | List: |
| References | |
| EA-93-047, EA-93-47, NUDOCS 9304270083 | |
| Download: ML20035G289 (4) | |
Text
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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 93-047 During an NRC inspection conducted February 17-19 and February 23-26, 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 impose a civil penalty pursua,t 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:
I 1.
Violations Assessed a Civil Penalty i
i A.
10 CFR 50, Appendix B, Criterion XVI, states that " measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective i
material and equipnent, and nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is. determined and corrective action taken to preclude repetition.
The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management."
Contrary to the above, in April 1989 and November 1989, the licensee identified a significant condition adverse to quality related te an inoperable motor on Unit 2 safety-related valve SI-31 A, out did not replace the motor until October 1990.
i Further, the licensee did not determine the cause of the failure and take action to preclude recurrence, or document and report the condition to appropriate levels of management until the motor failed again under similar circumstances on February 9, 1993.
B.
Technical Specification 3.5.2 requires for operation in Modes 1, 2, and 3, that three independent Emergency Core Cooling System j
(ECCS) subsystems shall be operable with each subsystem comprised of, in part, one operable Low Head Safety injection (LHSI) pump and an operable flowpath capable of taking suction from the containment sump during the recirculation phase of operation.
through a LHS1 pump and its respective RUR heat exchanger into the Reactor Coolant System.
An inoperable ECCS subsystem must be restored to an operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the unit must be placed in hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Contrary to the above, from April 1989 to October 1990, Unit 2 was operated for one fuel cycle, predominantly in Mode 1, with the Train A ECCS LHSI subsystem inoperable.
Motor-operated valve b
8 a
i
- =.
I J
SI-31A, cold leg injection isolation for.the Train A LHSI pump, l
was inoperable during this period of time because of a failed j
motor; consequently, the valve, normally open, could not have been closed electrically or manually following a loss of coolant accident to enable initiation of hot leg recirculation, a safety function assumed in the updated safety analysis report.
]
Violations 1. A and B are a Severity Level III problem (Supplement I).
I Civil Penalty - 575,000 l
11.
Violation Not Assessed a Civil Penalty i
10 CFR 50, Appendix B, Criterion XVI, states, in part, that measures i
shall be established to assure that conditions adverse to quality are I
promptly identified and corrected.
1 l
Contrary to the above, on February 2, 1993, the licensee determined that i
five STP Unit 1 Residual Heat Removal suction isolation motor-operated valves had incurred torque loadings of up to 253% of the actuator l
qualified limit for up to 50 cycles, a ' condition adverse to quality, but j
failed to identify the full scope of the deficiency and take adequate j
corrective action.
Specifically, the licensee concluded that the valves were operable based on valve internal inspections conducted during the previous outage, which recorded " excessive" wear on the worm gear f
(a component vulnerable to the effects of high torque). The licensee developed no justification or basis consistent with the recommendations i
of the actuator vendor or information published by or for.the users of
[
motor-operated valves in the nuclear power industry for the continued I
application of torque values in excess of the qualified limit.
fl This is a Severity Level IV violation (Supplement 1).
i
{
3 Pursuant to the provisions of 10 CFR 2.201, Houston Lighting & Power Company
'i (Licensee) is hereby required to submit a written statement or explanation to 3
the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, j
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 t
a a Notice of Violation" and should include for each alleged violation:
l (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 j
that will be taken to avoid further violations, and (5) the date when' full j
compliance will be achieved.
1 i
If an adequate reply is not received within the time specified in this Notice, i
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 l
proper should not be taken.
Consideration may be given to extending the l
t 5
i
. l 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 L.cector, 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 the cumulative amount of the civil penalties if more than one civil penalty is i
proposed, 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 exten-uating 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 penalty.
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 f ailure 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.
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. Nuclear Regulatory Commission, ATIN:
Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011 and a copy to the NRC Resident inspector at the facility that is the subject of this Notice.
Dated at Arlington, Texas this 19th day of April 1993 l
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