ML20046C576
| ML20046C576 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 08/05/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20046C571 | List: |
| References | |
| EA-93-167, NUDOCS 9308110172 | |
| Download: ML20046C576 (4) | |
Text
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y NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Gulf States Utilities Docket No. 50-458 River Bend Station License No. NPF-47 St. Francisville, Louisiana EA 93-167 During an NRC inspection conducted April 21 - June 22,1993, 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 pursuant to Section 234 of the Atomic Energy Act of 1954, as ameaded (Act), 42 U.S.C.
2282, and 10 CFR 2.205.
The particular violations and associated civil penalty are set forth below:
I.
Violations Assessed a Civil Penalty A.
10 CFR Part 50, Appendix B, Criterion X, states, in part, that a program for inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity.
Contrary to the above, a program for inspection of activities affecting quality was not established or executed, in that, on or about June 16, 1992, Main Steam Isolation Valve 1B21*A0VF022B was not inspected to verify conformance with the valve manufacturer's drawings that were used to accomplish valve repairs.
B.
Technical Specification 6.8.1. requires, in part, that written procedures be established, implemented, and maintained covering surveillance and test activities of safety-related equipment.
Administrative Procedure ADM-0015, " Station Surveillance Test Program,"
Section 4.6.4, states that the shift supervisor / control operating foreman is responsible for signing surveillance procedures signifying that the acceptance criteria have been met.
Surveillance Test Procedure (STP) 051-0201 is a monthly channel functional test performed to verify closure capability for main steam isolation valves (MSIVs), including MSIV IB21*A0VF022B.
Step 7.4.5 recuires depressing the MSIV test push button until the double indication light is received.
Step 8.1 lists satisfactory completion of Step 7.4.5 as one of the acceptance criteria for completing the channel functional test.
Contrary to the above, on February 27, 1993, and April 1, 1993, Administrative Procedure ADM-0015 was not properly implemented during performance of STP-051-0201.
Specifically, the shift supervisor and control operating foreman signed the procedure as complete, when the acceptance criteria of Step 7.4.5 had not been met for MSIV IB21*A0VF022B.
9308110172 930805 PDR ADOCK 05000458 G
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Technical Specification 3.4.7 states, in part, that two main steam line isolation valves (MSIVs) per main steam line shall be operable with closing times greater than or equal to 3 seconds and less-than or equal to 5 seconds while in Operational Ccnditions 1, 2, and 3.
With one or more MSIVs inoperable, this Technical Specification requires the licensee within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to restore the inoperable valve to operable status or isolate the affected main steam line by use of a deactivated MSIV in the closed position. Otherwise, the plant must be placed in at least hot shutdown 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 cold shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Contrary to the above, from February 27 to April 18, 1993, with the plant in Operational Conditions 1, 2, and 3, Main Steam Line Isolation Valve IB21*A0VF022B was r.ot operable (in that the valve would not close) and the actions described in Technical Specification 3.4.7 were not taken.
These violations represent a Severity Level III problem (Supplement I).
Civil Penalty - $100,000 II.
Violation Not Assessed a Civil Penalty 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 1.33, Revision 2, February 1978.
Regulatory Guide 1.33 recommends that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
Corrective Maintenance Procedure CMP-9141, " Main Steam Isolation Valves 1821*A0VF022A, B, C, D and IB21*A0VF028A, B, C, D Disassembly, inspection, Rework and Reassembly," Revision 48, provides instructions for certain maintenance affecting the performar.ce of safety-related main steam isolation valves (MSIVs).
The procedure specifically requires the valve to be in the closed position prior to beginning disassembly.
Maintenance Work Order (MWO) R159695 provided instructions related to reassembly of safety-related MSIV IB21*A0VF022A.
Step 59 states:
" Stroke the valve to assure the 11" stroke length.
If adjustment is reqd. perform per Steps 43-48 pg. 23 of manual. "
Contrary to the above:
1.
On April 23, 1993, maintenance on safety-related MSIV IB21*A0VF022B was not performed in accordance with written 4
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'l t procedures and documented instructions appropriate to the circumstances.
Procedure CMP-9141 was used for disassembly with the valve in the open position, such that several actions taken by plant mechanics during the disassembly were not provided for, or were contrary to, the requirements of the procedure.
2.
On May 11, 1993, during the reassembly of safety-related MSIV IB21*A0VF022A, maintenance was not performed in accordance with MWO R159695, Step 59, in that the 11" stroke length was not ensured, nor was a required valve adjustment performed per Steps 43-48 of the applicable manual.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Gulf States Utilities (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 that will be taken to avoid further violations, and (5) the date when full 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.
j 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 tra sfer 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 proposed, or may protest imposition of the civil penalty, in whole or in part, i
by a written answer addressed to the Director, Office of Enforcement, U.S.
I Nuclear Regulatory Commission.
Should the Licensee fail to answer within the J
time specified, an order ;.aposing.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 t!,e 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 234c of the Act, 42 U.S.C. 2282(c).
The response noted above (Reply to Notice of Violation, letter with payment of civil penalty, and Answer to a Notice of Violation) should be addressed to:
Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C. 7.0555 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 River Bend Station.
Dated at Arlington, Texas this 5th day of August 1993