ML20195K082
| ML20195K082 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 01/26/1988 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML20195K084 | List: |
| References | |
| EA-87-062, EA-87-62, NUDOCS 8801290148 | |
| Download: ML20195K082 (8) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Arkansas Power & Light Company Docket No.
50-313 Arkansas Nuclear One, Unit 1 License No.
DPR-51 EA 87-62 ORDER IMPOSING CIVIL MONETARY PENALTY I
Arkansas Power and Light Company (licensee) is the holder of Operating License No. DRP-51 issued by the Nuclear Regulatory Commission (NRC/ Commission) on May 21, 1974 The license authorizes the licensee to operate Arkansas Nuclear One, Unit 1 in accordance with the conditions specified therein.
II A routine safety inspection of the licensee's activities was conducted during February 1-28, 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 June 25, 1987. The Notice stated the nature of the violation, the provision of the NRC's requirement 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 September 18, 1987 acknowledging the violation but requesting full mitigation of the proposed civil penalty.
8801290148 890126 yDR ADOCK 05000313 PDR
. III After consideration of the licensee's response and the statements of fact, explanation, and argument for mitigation 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 penalty in the amount of Twenty-five Thousand Dollars ($25,000) 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, Office of Enforcenent, U.S. Nuclear Regulatory Commission, ATTN: Document control Desk Washington, D.C.
20555.
The licensee may request a hearing within 30 days of the date of this Order. A i
request for a hearing should be clearly marked as a "Request for an Enforcement Hearing" and shall be addressed to the Director, Office of Enforcenent, U.S.
1
. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.
20555, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, and a ccpy to the NRC Resident Inspector, Arkansas Nuclear One.
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 of the date of this Order, the provisions of this Order shall be effective without further proceedings.
If payment has not been made by that time, the matter may be referred to the Attorney General for collection.
n 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 NUCLIAR REGULATORY COMMISSION
,el s M. Tay r, Deputy Executive Director or Regional Operations Dated at Bethesda, Maryland, this 26th day of January 1988.
APPENDIX EVALUATION AND CONCLUSIONS On June 25, 1987, a Notice of Violation and Proposed Imposition of Civil Penalty (NOV) was issued for the violation identified during an NRC inspection.
Arkansas Power and Light Company responded to the Notice on September 18, 1987.
In the response the licensee admits that the violation occurred as stated, but argues that certain factors provide a basis for full mitigation of the proposed civil penalty.
The NRC's evaluation and conclusion regarding the licensee's arguments are as follows:
Restatement of Violation Technical Specification 3.1.1.3 requires that both pressurizer code safety valvos be operable when the reactor is critical. With one pressurizer code safety inoperable, either restore the valve to operable status within 15 minutes or be in Hot Shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
The associated basis for this technical specification states that the lift set point for the safety valve shall be set at 2500 psig i i percent tolerance for error.
Contrary to the above, on December 21, 1986, pressurizer code safety valve PSV-1002 was found inoperable, a condition that likely existed since September 1985 and during which time the reactor was critical.
The valve lift setpoint was at least 500 psi above the required 2500 psig i i percent setpoint.
This is a Severity Level III violation (Supplement !1.
Civil Penalty - $25,000.
Summary of Licensee's Response The licensee concluded that the high lift setpoint likely occurred as a result of pressurizer code safety valve maintenance performed during an outage in September 1985, although its investigation of the activity did not identify specific personnel errors or procedural discrepancies.
The licensee presented background information in its response that each of the two pressurizer code safety valves is rated for total relief capacity of the system and that during the period from September 1985 to December 1986, reactor coolant system overpressure protection was maintained with the one remaining operable pressurizer code safety valve.
Background information was also provided describing the methods for testing the setpoints of the pressurizer code safety valves.
Appendix The licensee further described in its response a sequence of events that began on September 24, 1986, when ANO-2 experienced a reactor trip.
During the post trip review of the transient, plant computer data indicated that one of the pressurizer code safety valves lifted prematurely.
In-situ tests were conducted that confirmed that both ANO-2 pressurizer code safety valve setpoints were slightly below Technical Specification limits.
Subsequently, in-situ testing of the recently installed Unit 1 pressurizer code safety valve was also conducted.
Upon finding the setpoint on this Unit i valve to be slightly low, a test was performed on the other Unit 1 pressurizer code safety valve which had been in service since September 1985. This test revealed a very high setpoint, and the valve was adjusted and retested satisfactorily.
The licensee indicated that this pressurizer code safety valve with the high setting had been refurbished and tested by the licensee onsite, while the other pressurizer code safety valves with the lower settings had been set and tested by an off site vendor.
Because results of the preliminary investigation could not rule out mechanical failure, the licensee decided to replace the valve with the higher setting with a spare pressurizer code safety valve.
The licensee described the short-term root cause investigation, and because the results of the short-term investigation were inconclusive, the licensee contracted a third party to assist with the investigation efforts. After describing the detailed efforts of the third party investigation, the licensee concluded that no factor was identified which would have resulted in the anomalous condition.
Therefore, the licensee stated that "the reason for the violation is unknown".
The licensee discussed the corrective steps that have been and will be taken.
These included the replacement of the safety valve in December 1986, even though the valve setpoint had been adjusted within tolerance.
The licensee also pointed to program improvements made prior to the finding of the inoperable valve and not as a result of the event. As a result of the event, procedure changes are being made to increase Quality Control involvement in safety valve testing and maintenance (pressurizer and main steam system code safety valves), development of management guidelines for handling safety-related equipment found to be in an abnormal condition, and an additional Quality Assurance program review based on the results of the root cause investigation.
NRC Evaluation of Licensee's Response The licensee's response did not dispute the classification of the violation as a Severity Level III or the findings related to pressurizer code safety valve maintenance and testing documentation and procedural deficiencies discussed in l
NRC Inspection Report 50-313/87-05 and in the Notice of Violation and Proposed Imposition of Civil Peralty dated June 25, 1987.
The licensee's root cause investigation, though extensive, did not identify a specific factor which would have resulted in the high lift setpoint.
Based on the licensee's description of the event, the licensee's actions appear to be acceptable.
The actions include short-term corrective actions associated l
Appendix with the pressurizer code safety valve high setpoint condition, including plant cooldown to replace the pressurizer code safety valve in December 1986, safety valve disassembly for inspection, site records and industry experience review, specific site and vendor procedures review, review of work performed in September 1985, and discussions with personnel.
The licensee's description of the short-term and long-term corrective actions regarding the program and procedure improvements associated with the pressurizer code safety valves, the main steam system code safety valves, and other safety-related equipment to improve the overall performance of safety-related activities are acceptable, and were necessary to correct the identified problems.
Sumary of Licensee's Recuest for Mitigation of Civil Penalty The licensee requested full mitigation of the proposed civil penalty based on the facts that the condition was identified because of its initiative to investigate a maintenance prcblem, the condition was promptly reported, corrective actions had been taken to address related issues prior to identifi-cation of the condition, maintenance and ouality program improvements were already underway due to management initiatives already in place, there was adequate margin of capacity with one safety valve operable, and the funds expended investigating possible generic implications have eliminated the need to impose a monetary penalty.
NRC Evaluation of Licensee's Request for Mitigation In accordance with the NRC's General Statement of Policy and Procedure for Enforcement Actions, the followin determining whether to mitigate (g matters are appropriately considered in or escalate) a civil penalty:
1.
Prompt Identification and Reporting The NRC staff acknowledges that once the licensee became aware of the problen it was promptly reported. However, because of the duration of the problem and the fact that proper QC checks would have provided the licensee opportunities to identify the problem earlier mitigation under this factor is not appropriate.
2.
Corrective Action to Prevent Recurrence The licensee's corrective action to prevent recurrence is not considered extensive in view of the significance of the identified problems.
The NRC expects its licensees to aggressively pursue correction of identified findings.
These actions were particularly necessary because the licensee's previous corrective actions regarding similar problems (SALP Category 2 in maintenance during 1984-1985) were not fully effective. After re-adjustment of the pressurizer code safety valve to within tolerance, the licensee elected to cool down the unit and raplace the valve since the short-term investigation did not rule out mechanical failure as a cause for high setpoint.
The NRC staff considers this action by the licensee to be prudent ar_ conservative but expected, due to the importance of the
Appendix reactor system code safety valves to protect the integrity of the reactor coolant system, a fission product boundary. Further, the expenditure of funds deemed appropriate by the licensee to investigate possible generic implications of such a significant problem is considered, by the NRC staff, to be part of the necessary corrective actions.
3.
Past Performance The base civil penalty was originally mitigated by 50% due to generally good past performance in the maintenance area as demonstrated by some improvement in the SALP ratings from Category 3 to Category 2.
The NRC staff believes that further mitigation for improving performanco would be inappropriate given that performance level is still categorized as satisfactory.
4.
Prior Notice of Similar Events Escalating factor only.
5.
Multiple Occurrences Escalating factor only.
NRC Conclusien The NRC staff concludes that in order to emphasize the importance of providing appropriate controls during plant operations and maintenance including verificaiton of safety valve operability, it is not appropriate to fully mitigate the civil penalty. Accordin Thousand Dollars (gly, the proposed civil penalty in the amcunt of Twenty-five
$25,000) should be imposed.
' Arkansas Power & Light Co.
l DISTRIBUTION bec w/ encl:
PDR SECY CA-JMTaylor, DEDRO TEMurley, NRR JLieberman, OE LChandler, OGC Enforcement Officers RI, RII, RIII, RV HDenton, 0GPA EJordan, AE0D SConnelly, OIA OE:ES File OE:EA File BSummers, OE (ltr hd)
DCS RIV Distribution:
RMartin Division Director Deputy Division Director Section Chief Inspector JGilliland (ltr hd)
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