ML20057G002
| ML20057G002 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 10/12/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20057F995 | List: |
| References | |
| 50-298-93-17, NUDOCS 9310200069 | |
| Download: ML20057G002 (5) | |
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NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES Nebraska Public Power District Docket No. 50-298 Cooper Nuclear Station License No. DPR-46 EA 93-137 During an NRC inspection conducted March 29 through April 2 and May 3-7, 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:
I.
Violations Assessed Civil Penalties A.
Appendix B to 10 CFR Part 50, Criterion XVI requires that measures shall be established to assure that conditions adverse to quality 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.
1.
Contrary to the above, on March 12, 1993, the secondary containment was declared operable without promptly identifying and correcting a significant condition adverse to quality which contributed to the secondary containment failure to meet its integrity test on March 8, 1993.
It was subsequently identified that a loop seal had not been established in a pipe from the reactor building to the radwaste building because of a construction deficiency. This condition created a direct leakage path between the reactor and radwaste buildings.
(01013) 2.
Contrary to the above, on November 16, 1992, the licensee did not promptly identify and correct emergency diesel generator Fuel Oil Tanks A and B particulate concentrations which exceeded the limit established in Station Procedure 6.3.12.3, Revision 13, " Diesel Fuel Oil Quality Test." Measures to correct the high particulate concentrations were not implemented until after April 2, 1993.
The emergency diesel generators were required to be operable frca November 16, 1992, until the plant was shut down for a refueling outage on March 6, 1993.
(01023) 3.
Contrary to the above, on May 1, 1992, after identifying primary system leakage past the inboard and outboard shutdown cooling suction isolation Valves RHR-M0-18 and -17, the licensee did not establish measures to promptly correct the condition. On March 29, 1993, the licensee identified that a significant condition adverse to quality existed in that Valve RH-M0-18 failed the 10 CFR Part 50, Appendix J local leak rate test.
It was found that five cracks existed in the valve seat and disc.
(01033) 9310200069 931012 PDR ADOCK 05000298 G
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' 4.
Contrary to the above, on March 30, 1993, it was determined that the licensee had not promptly identified and corrected a significant condition adverse to quality for paint blistering in the Emergency Condensate Storage Tanks A and B.
An inspection of Tanks A and B, as authorized by Maintenance Work Request 93-1271, had identified blistering of the tank interior coating; however, the results of the inspection were not documented in the maintenance work request and no other
'ive action measure was initiated to evaluate and correct this condition.
(01043)
These violations represent a Severity Level III problem (Supplement I).
Civil Penalty - $75,000 B.
Technical Specification Table 3.2.H states that the primary containment Hydrogen Concentration Analyzers PC-AN-H,/0, -I and -11 are required to be operable at all times except when the reactor is in cold shutdown or j
in the REFUEL mode during a refueling outage.
Contrary to the above, from April 1990 until March 6,1993, with the reactor not in cold shutdown or REFUEL mode during a refueling outage 1
l (at various times), primary containment Hydrogen Concentration Analyzers PC-AN-H /0, -I and -II were not operable.
Specifically, it 2
was identified that the inline sample line filter canisters and the sample line slopes resulted in the accumulation of moisture, which resulted in erratic readings and unreliable analyzer operation.
(01053)
This is a Severity Level Ill violation (Supplement I).
Civil Penalty - $75,000 C.
10 CFR 50.55a(g)(1) requires, in part, for boiling, water-cooled nuclear power facilities with construction permits issued prior to January 1, 1971, that safety-related components that are not part of the reactor coolant pressure boundary meet the requirements of 10 CFR 50.55a(g)(4) and (5).
10 CFR 50.55a(g)(4) requires, in urt, that throughout the service life of a boiling, water-cooled nucleer power facility, components (including supports), which are classified as ASME Code Class 1, 2, and 3, must meet the requirements, except design and access provisions and preservice examination requirements, set forth in Section XI of the ASME Boiler and Pressure Vessel Code and Addenda.
10 CFR 50.55a(g)(5)(i) requires, (151) program for a boiling, water-cooledin part, that the inservice inspection be revised by the licensee, as necessary, nuclear power facility, must 10 CFR 50.55a(g)(4).
to meet the requirements of Contrary to the above, the licensee, which had received a construction permit prior to January 1,1971, did not include the safety-related components of the service water and reactor equipment cooling systems in
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the initial licensed ISI program and did not update the requirements I
relative to these systems to ASME Section XI equivalency. This condition had existed since initial plant operation in 1974. Since February 12, 1976, when the revisions to 10 CFR 50.55a(g) went into effect, the licensee did not include the essential portions of the
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service water and reactor equipment cooling systems in the ASME Section XI ISI Program.
(01063) l l
This is a Severity Level III violation (Supplement I).
Civil Penalty - $50,000 II.
Violations Not Assessed A Civil Penalty A.
Appendix B to 10 CFR Part 50, Criterion V, Instructions, Procedures, and Drawings, states that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall bc accomplished in accordance i
with these instructions, procedures, or drawings.
1.
Contrary to the above, on April 10, 1993, craft personnel failed l
to implement Step 5 of Maintenance Work Requcst 93-3021 which required a system engineer to inspect the inside of the two No. I emergency diesel generator aftercoolers prior to cleaning. The craft personnel proceeded to clean the left aftercooler (Step 7) prior to the system engineer conducting the required inspection.
This is a Severity Level IV violation (Supplement I).
2.
Contrary to the above, on March 6, 1993, a station operator failed to implement the requirement of Operating Procedure 2.2.18, Revision 33, "4160V Auxiliary Power Distribution," Step 8.1.4 to l
rack out the Core Spray Pump A breaker.
Instead, the station operator proceeded to rack out the breaker to a safety-related substation, by first tripping the breaker, and caused a loss of shutdown cooling.
1 This is a Severity Level IV violation (Supplement I).
3.
Contrary to the above, on March 8, 1993, two contract mechanical maintenance personnel entered the special work permit area i
surrounding the drywell without reading and signing the special work permit as required by Health Physics Procedure 9.1.1.4, Sections 8.4.3.1 and 8.4.3.5.
l This is a Severity Level IV violation (Supplement IV).
l 4.
Contrary to the above, as of March 29, 1993, the licensee had not established appropriate quantitative acceptance criteria in l
Procedures 6.3.1.13, Revision 9, " Division I H,/0, Analyzer l
Calibration and Functional / Functional Test," and 6.3.1.14, I
-m e.
4
. Revision 10, " Division II H,/0, Analyzer Calibration and Functional / Functional Test," to verify operability of the hydrogen / oxygen analyzer heat tracing. The heat tracing is required to be operable to support operability of the hydrogen / oxygen analyzers as required by Technical Specification Table 3.2.H, POST-ACCIDENT MONITORING INSTRUMENTATION 1
REQUIREMENTS.
This is a Severity Level IV violation (Supplement I).
B.
Appendix J to 10 CFR Part 50, Section III.C, states, in part, for valve local leak rate tests that the test pressure shall be applied in'the same direction as that applied when the valve would be required to perform its safety function, unless it can be determined that the results from the tests for a pressure applied in a different direction will provide equivalent or more conservative results.
Contrary to the above, since initial plant operation in 1974, the licensee performed reverse direction testing of 26 containment isolation valves without the local leak rate test results being equivalent or more conservative.
This is a Severity Level IV violation (Supplement I).
C.
Technical Specification 4.7. A.2 requires integrated leak rate testing to verify primary containment integrity at 58 psig.
Contrary to the above, since installation of the hydrogen / oxygen analyzers in April 1988, the licensee had not tested the cabinet internals at 58 psig.
The cabinet internals constitute a primary containment boundary during a design basis event.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Nebraska Public Power District (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 I
of Civil Penalties (Notice). This reply should be clearly marked as a " Reply i
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
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' response time for good cause shown.
Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this rr.sponse 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 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 penalties proposed above, or the cumulative amount of the civil penalties if more than one civil penalty is e
proposed, or may protest imposition of the civil penalties, 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 i
i the time specified, an order imposing the civil penalties will be issued.
I Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, 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 penalties should not be imposed.
In addition to protesting the civil penalties, in whole or in part, such answer may request remission or mitigation of the penalties.
In requesting mitigation of the proposed penalties, 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 civil penalties.
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.
l The response noted above (Reply to Notice of Violation, letter with payment of l
civil penalties, and Answer to a Notice of Violation) should be addressed to:
Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, ATTN:
i Document Control Desk, Washington, D.C. 20555 with a copy to the Regional l
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 Cooper Nuclear Station.
j t
Dated at Arlington, Texas this 12th day of October 1993
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