ML20043E235
| ML20043E235 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 05/29/1990 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Tucker H DUKE POWER CO. |
| Shared Package | |
| ML20043E240 | List: |
| References | |
| EA-90-066, EA-90-66, NUDOCS 9006120187 | |
| Download: ML20043E235 (6) | |
Text
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Docket No. 50-413 l
License No.
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Duke Power Company.
ATTN:.
H. B. Tucker, Vice President i
Nuclear Production Department 422 South Church Street Charlotte, NC 28242 Gentlemen:
SUBJECT:
. NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY -
$100,000(NRCINSPECTIONREPORTNOS. 50-413/90-10AND50-414/90-10)
This refers to the Nuclear Regulatory Commission (NRC) inspection conducted on March 22-26, 1990, at the Catawba Nuclear Station. The inspection included a review of the March 20, 1990, ReactorCoolantSystem(RCS)lowtemperature pressurization event.
The report documenting this inspection was sent to you by letter dated April 16, 1990.
As a result of this inspection, significant
. failures to comply with NRC regulatory requirements were identified.
An 4
Enforcement Conference was held with members of your staff on April 25, 1990 i
to discuss your management control of plant configuration and the failure to conduct a Technical Specification surveillance test of the Power Operated ReliefValves(PORV).
The letter summarizing this Conference was sent to you on April 30,.1990.
, Violations I. A and I.B. described in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice), involve your failure to 1
establish adequate measures for plant configuration control while in modes 5
-(cold shutdown) and 6 (refueling).
Specifically, Violation I. A addresses the J
March 20 RCS event that occurred because RCS pressure transmitter instrument root valves were left closed following a design modification.
The wc,rk order. to reopen the root valves was not completed prior to entering a plant condition in mode 5 that required these instruments to be operable.
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r The t'ransmitters provided signals to (1) the control room indication used by the operators to monitor the initial RCS pressurization following the outage, Residual Heat Removal (RHR) pressure Protection (LTOP) System, and (3) the (2) the Low Temperature Over suction valves.
The isolation of these signals gave the operators erroneous information which led them to continue pressurizing the RCS beyond the procedural limits, and prevented the Power Operated Relief Valves (PORV) from automatically opening after the safety setpoints were reached.
This also would have prevented the RHR suction isolation valves from automatically closing on overpressure if that system's set point had been exceeded.
It is fortuitous that your subsequent engineering analyses showed that the various system design pressure limits were not exceeded.
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Duke Power Company 2
NAY 2 91990 Violation I.B involved the failure to perform a Technical Specification required surveillance test to verify operability of the PORVs.
The surveillance is required to be run within 31 days prior to entering a condition in which the PORVs are required. Although the failure to perform the surveillance did not contribute to the March 20 event, nor would it have detected the closed root valves for the pressure transmitters, it exposed weaknesses in your program for scheduling surveillances required for certain plant conditions. Adequate provisions were not established to either reschedule the test after conflicting work conditions prevented completion when originally scheduled, or to otherwise flag the incomplete test status.
These examples collectively indicate inadequate manage-ment control of programs to assure that the operating staff has accurate knowledge of plant equipment status at the Catawba Nuclear Station.
To emphasize the need for effective management controls to ensure that admini-strative measures are established for accurately indicating the operating status of plant systems and components, I have been authorized, af ter' consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Material Safety, Safeguards, and Operations Support, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) in the-amount of $100.000 for the Severity Level III problem described in the er. closed Notice.
In accordance with the " General Statement of Policy and Procedure for i
NRC Enforcement Actions " 10 CFR Part 2, Appendix C (1990), Violations 1.A and I.B have been classified in the aggregate at the Severity Level III. The base value of a civil penalty for a Severity Level 111 problem is $50,000. The escalation and mitigation factors in the Enforcement Policy were considered.
The staff recognizes that immediate and long-term corrective actions were taken following the pressurization event to correct problems associated with the administrative controls for maintenance and modification work. However, no mitigation was deemed appropriate for this factor because two subsequent events indicate that those immediate corrective actions were not effective.
The first event involved the failure to unisolate the steam generator PORVs af ter completion of ESF testing on March 24, 1990.
The second event involved the failure to return the Containment Valve Injection Water System alignment l
to normal following a testing tagout on March 27, 1990.
Both conditions were not discovered until April 5,1990.
Escalation was applied for poor past performance as a result of several previous
~ enforcement actions which involved, to varying degrees, inadequate management controls and inadequate performance in plant operations. These included:
(1) inadequate implementation of the test program for the auxiliary feedwater system, and an associated flow path configuration control problem (EA 82-96, Severity Level 111), (2) inadequate post-modification testing of the hydrogen skimmer system (EA 89-46, Severity Level III, $75,000 civil penalty), (3) the failure to restore the reactor vessel level indication system alignment prior to entering mode 3 (EA 89-138, Severity Level Ill), and (4) inadequate corrective actions following the test failure of an auxiliary feedwater pump (EA 89-178, Severity Level Ill, $37,500 civil penalty). Given this performance record, full escalation of 100 percent for past performance is warranted notwithstanding the SALP rating of 2 with an increasing trend in operations.
None of the other adjustment factors in the Policy were considered appropriate.
Therefore, based i
on the above, the base civil penalty has been increased ay 100 percent, j
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Duke Power Company 3
MAY 2 91990 The violation described in Part II of the enclosed Notice addresses a failure of the operations staff to adequately review the effects of station modification CN-10942. This review failed to identify the power dependence of the relay ad@d to the "B" train RHR suction valve circuitry which resulted in control room operators being unable to electrically reopen the valve following the March 20, 1990 pressurization event. This violation has been categorized at a Severity Level IV.
In reviewing the reportability of the pressurization event, the staff agrees with your final conclusion that based on the analysis of the event it was not
-reportable.
However, during and immediately following the event, initial indications tended to support the assumption that an overpressurization of the RCS had occurred.
This condition should have been reported within four-hours.
Subsequent analysis established that an_overpressurization did not occur. The conservative approach to that condition would have been to make a four hour report based on the initial indications and then to rescind the report.
We recognize your efforts to increase your staff's awareness of the reportability criteria as described during the Enforcement Conference.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.
In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosure will be placed in the NRC Public Document Room, i
The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required i
by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
Should you have any questions concerning this letter, please contact uss Sincerely.
Origina! 0;;ned Dy:
StewM D. Ebneter Stewart D. Ebneter Regional Administrator
Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty cc w/ encl:
(See page 4) i
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- T. B. Owen, Station Manager i
Catawba Nuclear Station P. O. Box 256 1
Clover, SC 29710 i
A. V. Carr, Esq.
Duke Power Company i
422 South Church Street Charlotte, NC 2B242 J. Michael McGarry, III. Esq.
Bishop,. Cook, Purcell and Reynolds 1400 L Street,-NWc Washington, D. C.
20005 l
L North Carolina MPA-1 3100 Smoketree Ct., Suite 600 P. O. Box 29513 Raleigh NC-27626-0513
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Heyward G. Shealy, Chief i
Bureau of Radiological Health South Carolina Department of Health and Environmental Control a
2600 Bull Street Colunbia, SC 29201 l
l Richard P. Wilson, Esq.
I
- Assistant Attorney General S. C. Attorney General's Office i
P. O. Box 11549
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Columbia, SC 29211
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Michael Hirsch i
Federal' Emergency Management Agency
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500 C Street, SW, Room 840 Washington, D. C.
20472 North Carolina Electric Membership Corporation 3400 Sumner Boulevard P. O. Box 27306 L.
Raleigh, NC 27611 Karen E. Long Assistant Attorney General N. C. Department of Justice P. O. Box 629 Raleigh, NC 27602 cc_w/enci cont'd:
(See page 5)
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Saluda River Electric l
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P. 0. Box 929-Laurens, SC 29360 S. S. Kilborn, Area Manager Mid-South Area ESSD Projects Westinghouse Electric Corporation MNC West. Tower - Bay 239 P.-0. Box 335 i
Pittsburg, PA 15230 7
County Manager of York County.
York County Courthouse York, SC 29745 Piedmont Municipal Power Agency-121 Village Drive Greer, SC 29651 State of South' Carolina t
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