ML20149L151
| ML20149L151 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 02/19/1988 |
| From: | NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | NORTHERN STATES POWER CO. |
| Shared Package | |
| ML20149L154 | List: |
| References | |
| EA-87-147, NUDOCS 8802240133 | |
| Download: ML20149L151 (7) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Northern States Power Company Docket No. 50-263 (Monticello)
Licensee No. DPR-22 EA 87-147 ORDER IMPOSING CIVIL MONETARY PENALTY I
Northern States Power Company (licensee) is the holder of Operating License No. DPR-22 issued by the Nuclear Regulatory Commission (NRC/Consnission) on January 19, 1971. The license authorizes the licensee to operate the Monticello plant in accordance with the conditions specified therein.
II A special inspection of the licensee's activities was conducted during the period June 17-18 and July 6, 1987.
The results of this inspection indicated that the licensee had not conducted its activities in full compliance with NRC requirements. A written Notice of Violation and Proposed Imposition of Civil Penalty was served upon the licensee by letter dated October 5, 1987.
The Notice states the nature of the violation, the provision of the NRC's requirements that the licensee had violated, and the amount of the civil penalty proposed for the violation.
The licensee responded to the Notice of Violation and Proposed Imposition of Civil Penalty by letter dated November 4,1987 admitting the violation, but requesting ccmplete mitigation of the proposed civil penalty.
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III After consideration of the licensee's response and the statements of fact, explanation, ahd argument for nitigation contained therein, the Deputy Executive Director for Regional Operations has determined, as set forth in the Appendix to this Order that the penalty proposed for the violation designated in the Notice of Violation and Proposed Imposition of Civil Penalty should be imposed.
IV In view of the foregoing and pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205, IT IS HEREBY ORDERED THAT:
The licensee pay a civil monetary penalty in the amount of Fifty Thousand Dollars ($50,000) within 30 days of the date of this Order, by check, draft, or money order, payable to the Treasurer of the United States and nailed to the Director of Enforcement, U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555.
d The licensee may request a hearing within 30 days of the date of this Order.
A request for a hearing should be clearly marked as a "Request for an Enforcement Hearing" and should be addressed to the Director of Enforcement,
\\ U.S. Nuclear Regulatory Comission, ATTN:
Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Administrator, Region III, and a copy to the NRC Resident inspector, Monticello plant.
If a hearing is requested, the Commission will issue an Order designating the time and place of the hearing.
If the licensee fails to request a hearing within 30 days af the date of this Order, the provisions of this Order shall be effective without further proceedings.
If payment has not been made by that tilne, the matter may be referred to the Attorney General for collection.
In the event the licensee requests a hearing as provided above, the issue to be considered at such hearing shall be whether the proposed civil penalty should be imposed in whole or in part.
FOR THE NUCLEAR REGULATORY COMMISSION
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Japes M. Tay r, Deputy Executive Director for Regional Operations Dated at Bethesda, Maryland this /'7 day of February 1988.
I i
Appendix Evaluations and Conclusions On October 5,1987, a Notice of Violation and Proposed Imposition of Civil Penalty (Notice) was issued for a violation of 10 CFR Part 50, Appendix 8, Criterion V.
Northern States Power Company responded to the Notice on November 4, 1917.
In its response, the licensee agreed that the violation occurred, but stated that it believed total mitigation of the proposed civil penalty was waPranted because of its pronpt identification and reporting of the violation, prompt and extensive corrective actions, its prior good enforcement history, and other considerations.
Restatement of Violation 10 CFR Part 50, Appendix B, Criterion V states, in part, that activities affecting quality be prescribed by documented instruction, procedures, or drawings, of a type appropriate to the circumstances.
Contrary to the above, from August 1986 to July 1987, activities involving the review and performance of electrical coordination to determine the effects of changes to the electrical power system on other portions of the electrical power system were not prescr1 bed by electrical design change control procedures.
As a result, when the electrical distribution system was modified by replacing trip devices in load center circuit breakers for essential buses with devices having ground fault protection, the potential of loss of an essential bus due to a fault in a nonsafety-related component was created.
Sunnary of Licensee's Response The licensee acknowledges the occurrence of the violation, but requests the proposed civil penalty be completely mitigated.
The licensee's arguments concerning mitigation are based on the following:
1.
Prompt Identification and Reporting The licensee states that the grnund fault coordinatien problem was discovered by plant personnel and promptly reported to the NRC.
The licensee further states that even though the problem existed for 11 months, there were only two opportunities to discover the breaker coordination problen prior to its identification by the licensee.
2.
Corrective Action to Prevent Recurrence The licensee states that pronpt and extensive corrective actions were taken as a result of the event, including consideration of other potential coordination problems in other, unrelated, plant modifications.
It is further argued that the corrective actions were on the initiative of plant personnel and were broad in scope.
3.
Past Perfonnance The licensee states that only one event involving inadequate design control was identified in the prior two years and that SALP ratings in this area have been consistently above average.
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Appendix 4.
Prior Notice of Similar Events The licensee states there was no prior notice of this problem.
5.
Multiple Occurrences The licen.see states that this is the first occurrence of this type at Monticellb.
6.
Other Considerations The licensee clariff es a point in the Notice concerning the existence of procedures. The licensee states that procedures did exist for electrical coordination studies for changes to the electrical power system. The licensee acknowledges that a procedure for the review of the coordination of Motor Control Center (NCC) loads did not exist.
The event was considered to be an isolated event. While the licensee admits that the failure to provide adequate ground fault coordination when circuit breaker trip devices were replaced was a serious error, it believes that the impact on plant safety due to this failure was small.
NRC Evaluation of Licensee's Response Regarding prompt identification and reporting, the NRC agrees that the licensee identified the problem, but not until the issue was disclosed by the June 7 and June 14, 1987 events which re,uired the licensee to investigate.
The coordination problem occurred when t1e licensee failed to properly evaluate the effects of replacing existing electrical circuit breakers with solid state trip devices which had ground fault protcction not previously provided. An electrical coordination review was not performed at the time of replacement and is considered the first opportunity to identify the problem.
Of the next two opportunities to discover the problen, the licensee failed to take advantage of the first chance because the fault was meggered and not continuity tested which would have identified the problem.
The fault on June 14 was identified only after the containment fan cooler motor tripped on high current, not as a result of p!anned testing or maintenance.
Overall, the fact that the licensee eventually identified the violation is balanced by the fact that the licensee failed to take advantage of opportunities to identify the problem earlier. Therefore, mitigation was not considered appropriate for this factor.
With respect to corrective actions the NRC acknowledges that the licensee took corrective acticns that should prevent recurrence, but does not believe that such actions were unusually prompt and extensive in response to the significance of the event. The NRC staff points out that the corrective actions were necessarily broad in scope and additional electrical coordination problems had been identified which delayed start-up of the plant.
The NRC considers that the corrective actions taken were appropriate to the significant nature of the problem identified and therefore considers mitigation for the corrective actions taken unwarranted.
6 Appendix The NRC recognizes the licensee's good enforcement history in the area of maintenance and modifications and considered mitigatien of the base civil penalty for this factor. However, the NRC notes declining performance in the area of engineerino which was the cause of the violation cited in this enforce-ment action and also a violation (Severity Level III) given in December 1986 for deficiencies in the Standby Liquid Control System.
The significance of the violation in the current enforcenent action is also increased because of the fact that the problem existed for 11 months prior to its discovery.
It is considered significant that during this time, under certain conditions, the potential existed for ground faults in nonsafety-related equipment to cause the loss of essential motor control center loads.
Consideration of mitigation of the base civil penalty because of the licensee's enforcement history in the area of maintenance and modifications is balanced by the declining performance in the engineering area and the duration for which the violation existed while the plant operated in condition which could have had a significant impact on the availability of safety systems.
Therefore, neither mitigation ror escalation is deemed appropriate.
Regarding other considerations, the NRC recognizes that the plant had procedures for electrical coordination studies; however, as the licensee admits, there was no procedure for electrical coordination studies for Motor Control Center (MCC) loads. As discussed earlier, the NRC believes that the event was significant in that various safety systems were affected by the coordination problem.
NRC Conclusion The NRC has reviewed Northern States Power Company's response to the proposed imposition of civil penalty and arguments for mitigation of the base civil penalty.
The NRC concludes that an adequate basis for mitigation of the civil penalty was not provided by the licensee.
Consequently, the proposed civil penalty in the amount of $50,000 should be imposed.
Northern States Power Company DISTRIBUTION:
PDR SECY CA JMTaylor, DEDO TMartin, DEDRO LChandler, OGC JLieberman, OE JLuehman, OE ABDavis, RIII Enforcement Coordinators RI, RII, RIII, RIV, RV FMiraglia, NRR BHayes, OI SConnelly, OIA EJordan, AEOD FIngram, PA DNussbaumer, GPSP DCS I
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