ML20044H069
| ML20044H069 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 05/28/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20044H066 | List: |
| References | |
| EA-93-057, EA-93-57, NUDOCS 9306070338 | |
| Download: ML20044H069 (7) | |
Text
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MAY '? B 1993 NOTICE OF VIOLATION AND PROPOSED IMPOSITION:0F LIVil PENALTIES 1
Houston Lighting & Power Company Docket Nos.
50-498 and 50-499 South Texas Project Electric Licenses Nos.
NPF-76; NPF 80 Generating Station EA 93-057 During an NRC inspection conducted March 8-12. 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 civil penalties 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 penalties are set forth below:
j 1.
Violations related to turbine-drivan auxiliar_y feedwater cumos A.
Technical Specification 3.7.1.2 requires, in part, that at least four indepenaent steam generator auxiliary feedwater pumps and associated flow paths shall be OPERABLE. with one steam turbine-driven auxiliary feedwater (TDAFW) pump capable of being powered from an OPERABLE steam i
supply system in Modes 1-3.
Action b.4 states, in part, that with the TDAFW pume inoperable, restore the,affected turbii.e-driven auxiliary feedwater pump to operaole status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or place the reactor inatleastHOTSTANDBYwithinthe;next6hoursandHOTSHUTDOWNwithin 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 December 25. 1992. to February 4, 1993, a perioo of 33 days, ano with STP Unit 1 in Modes 1-3, the Unit 1 T0AFW pump was inocerable and the licensee did not take the actions described above to piace the reactor in hot stanoby or hot shutdown.
B.
10CFRPart50,AppendixB.CriterhonXVI, states,inpart,that measures shall be taken to assure that conditions adverse to quality, such as f ailures, malfunctions, deficiencies, deviations, defective material ano equipment, 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 is taken to preciude repetition.
I 10 CFR Part 50.AppenoixB.CriterjonXI. states,inpart,thatall testing reauired to demonstrate that structures, systems and components aill perform satisfactorily in service is identified and performed in accoroance with written test proceoures which incorporate appropriate requirements and acceptance limitsi The test procedures shall include provisions for assuring that.11 prerecuisites for the given test have been met, that adeuuate test instrumentation is available and used, and that the test is performeo unoer suitable environmental conditions.
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-a-Contrary to the above, the licensee failed to assure that the cause(s) of the turbine driven auxiliary feedwater pump (TDAFW pump) overspeed trips, a significant conattion adverse to quality, were identified and adeouate corrective action taken to preclude repetition.
Specifically, following maintenance troubleshooting, the licensee performed procedures OPSP03-50-0019D. Revision 0, " Turbine Driven Auxiliary feedwater Pump Actuation And Response Time Test," and OPSP03-AF-0007, Revision 7, " Auxiliary feedwater Pump 14 Inservice Testing," to demonstrate TDAFW pump operaoility'on June 11, 1990 December 27, 1992, and January 30. 1993, for the Unit 1 TDAFW pump; and on December 11, 1991 for the unit 2 TDAFW puro.
The successful completion of these test procedures was not sufficient'to anure that the TDAFW pumps would perform satisfactorily in service because the TOAFW pumps were act returned to their normal stancby condition prior to retest after the initial test failed.
C, Technical Specification 6.8.1.a requires. in part, that written procedures be established, implemented. and maintained covering the applicable procedures recommenced in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, February 1978.
RG 1.33. Appendix A, Item 9a.
reco n nds, in part, that maintenance that can affect the performance of safety-related equipment be properly pre-planned and performed in accorcance with written procedures'sppropriate to the circumstances, f
Contra to the above, in Novemoer 1992, maintenance on the STP Unit 1 TDAFW imp governor valve was not performed in accordance with written procec. es that were appropriate to the circumstances, Preventative Mainte-oce Work Instruction MM l-AF-89003576, the document that l
proviced the guidance to adjust the governor valve, did not contain sufficient cuantitative and cualitative acceptance criteria to ensure that the governor valve would perform satisfactorily in service, resulting in an improper adjustment that contributed to overspeed trips of the pumo on December 27. ;992, and January 28. 1993.
D.
Technical Specification 6.8.;,a requires, in part, that written proceaures be establisheo.
mulemented. and maintained covering the applicable procedures recommended in Aopendix A of Regulatory Guide (RG) 1.33. Revision 2. February 1978.
RG 1.33. Appendix A, Item 1.d recommends operating proceaurus for procedure adherence.
STP Procedure OPGP03-ZA-0010. Section 4.2.3. states that activities affecting quality ~
relatea structures. systems and components SHAll be conducted in accoroance with written, acprovea procedures.
STP Procedure 2 POP 02-AF-000), luxiliary Feedwater." was modified by Field Change Request 92-0220 on April 15. 1992, to align Valve MS-517, the oypass valve for the Unit 2 TDAFW pump steam admission line drain line steam trao, in the open nosition.
Contrary to the above, in January 1993, the licensee did not assure that activities affecting quality-related components were conducted in l
l accoraance with written, approveu procedures.
Specifically, Valve MS-
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517 was fully closed on January 24j 1993, and remained closed through February 3. 1993.
As a result of this conoition, the Unit 2 TOAFW pump tripped on overspeed due to water builduo in the steam admission line shen the pump was called upon to perform its safety-related function on February 3. 1993.
E.
Technical Specification 6.8.1.a requires that written procedures be established, implemented. and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide (RG) 1.33.
Rev1sion 2. February 1978.
RG 1.33. Appenoix A, Item 9a. recommends. in part, that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures approoriate to the circumstances.
STP Procedure OPGP03-ZA-0090. Revi$1on 5. 1ork Proce: S Program,"
Section 4.2.1.1 lists work activities that may be performed immediately by personnel reporting to the issuing Authority without originating a Service Reauest.
In addition, a note in Section 4.2.1.1 states in part, that personnel performing these work activities should have appropriate prior training consistjng of completion of qualification per job task analysis.
l Contrary to the above, on January. 25, 1993, the licensee failed to pre-olan or conduct maintenance on the' Unit 2 TDAFW pump overspeed trip linkage in accordance with written-procedures appropriate to the circumstances.
The maintenance activity was performed without a required Service Request by an individual wno had not satisfactorily completed the requisite maintenance job task analysis training requirements.
These violations represent a Severity Level !!! problem (Supplement I).
Civil Penalty - 5175.000 i
II.
Violations _related to emeroency dDsel_qenerators l
A.
Technical Specification 3.8.1.1.b reoutres, in part that three separate and indeoenaent standby (emergency) diesel generators be oDeraDie in Modes 1-4.
Technical Specification 3.8.1.1. Action b, reouires, in part. that an inopersole emergency diesel generator be restored to operable staths witnin 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or (that the reactor) be in at least HOT $HUTDOWN.within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLO SHUTDOWN within the followino 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Contrarytotheabove,frombecemoer 29, 1992, until January 22.
1993, a period of 24 days, and with STP Unit 1 in Modes 1-4.
Emergency Diesel Generator (EDG) 13 was inoperable and the licensee did not take the actions reouired above to place the reactor in hot shutdown or cold shutcown.
Specifically, EDG 13 would not have run if it had' received a start signal due to paint having dripped into faei methring rod ports.
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W 28 1993 B.
10 CFR 50, Appendix 8, Criterion V, states, in part, that activities affecting quality shall be prescribed by documented procedures, and that these procedures shall include appropriate quantitative or qualitalive acceptance criteria for determining that important activit % have Deen satisfactorily accomplished, Technical Specification 6.8.1.a requires, in part, that written procedures be established, implemented, and maintained covering the applicable proceoures recommended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2 _ February 1978.
RG 1.33, Appendix A, Item 9a. recommends, in part. that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performeo in accordance with written procedures appropriate to the circumstances.
Contrary to the above, on Decemoer 29-31, 1992, maintenance that could affect safety-related equipment (painting of an EDG) was not performed in accordance with written procedures appropriate to the circumstances.
Specifically, Work Request XG-ll6382 did not provide for a post-maintenante test to assure the operability of Emergency Diesel Generator 13 following the painting of the machine.
As a result of the: painting evolution, Emergency Diesel Generator 13 was later determine 0 to have been inoperable from Decerber 29, 1992, until January 22, 1993.
C.
Technical Specification 3.8.1.1.b requires that three separate and independent standby (emergency) diesel generators be operable in Modes 1-4.
Technical Specification 3.8.1.1. Action f, requires, in part, that with two or three emergency diesel generators inoperable, restore at least two emergency diesel generators to operable within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or (that the reactor) be in at least 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 COLD SHUTDOWN Within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Contrary to the above, from January 12-14, 1993, a period 61 l
hours. Emergency Diesel Generators 12 and 13 were inoperable and l
the licensee did not take the actions described above to place the l
reactor in not standby or cold shutdown.
This condition occurred l
when EDG 12 was taken out of; service for maintenance concurrent l
with EDG 13 being inoceraoleldue to point having dripped into fuel metering rod ports.
l These violations represent a Severity Level III problem (Supplement I).
Civil Penalty - 3150.000 Pursuant to the provisions of 10 CTR 2.201. iouston Lighting & Power Company (Licensee) is hereoy required to s; omit a wr,tten statement or explanation to l
the Director. Office of Enforcerrent. U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice of Violation and Proposed Imposition of Civil Penalties (Notice).
This reply should be clearly marked as a " Reply to a Notice of Violation" ano should include for each alleged violation:
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E (1) admission or denial of the alleged iolation. (2) the reasons for the violation if aamitted, and if denied, the reasons why, (3) the corrective steps that have been taken and the resul.ts achieved. (4) the corrective steps that will be taken to avoid further violations. and (5) the date when full compliance will be achievea.
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If an adequate reply is not received within the time specified in this Notice.
an order or demand for information may tie issued as to why the license should not be modified, suspended, or revoked 0r why such other action as may be proper should not ce taken.
Considerati,on 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 penalties by letter addressed to theDirector.OfficeofEnforcement,U.SLNuclearRegulatoryCommission,with a check, draft, money order, or electronic transfer payable to the Treasurer of the United States in the cumulative amount of the civil penalties proposed, or may protest imposition of the civil penalties, in whole or in part, by a aritten 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 penalties will be issued.
Should the Licensee elect to file an answer in accordance with 10 CFR 2.20S protesting thecivilpenalties,inwholeorinpartisuchanswershouldbeclearlymarked 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 penalties should not be imposed.
Iniaddition to protesting the civil penalties. in whole or in part, sucn answer may request remission or mitigation of the penalties, i
in reouesting mitigation of the procosedipenalties, the factors addressed in Section VI.B.2 of 10 CFR Part 2. Appendix C should be addressed.
Any written answer in accoroance 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 rdply by specific reference (e.g.,
citing page ano 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 eay any civil penalty due which subsequently has been determineo in accoroance 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 mitigateo.
aylbe collected by civil action pursuant to Section 234(c) of the Act. 42 U.S.C. 2282c.
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MAY y & Iggg Notice of Violation 6-i l
The responses noted above (Reply to Notice of Violation, letter with payment of civil penalties, 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 Pegulatory Commission, Region IV, 611 Ryan Plaza Drive, Suite 400. Arlington, Texas 76011 and a copy to the NRC Resident Inspector at the South Texas Project Electric Generating Station.
Dated at Arlington. Texas thisfPwdayofMay1993 i
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