ML20211K422

Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000.Violation Noted:Design Control Measures for Design Change Package DCP 82-0-1050 Failed to Properly Verify Single Failure or Loss of Power Supply

ML20211K422
Person / Time
Site:	Arkansas Nuclear
Issue date:	11/12/1986
From:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20211K417	List: ML20211K409 ML20211K422
References
EA-86-151, NUDOCS 8611170170
Download: ML20211K422 (8)

Text

m NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Arkansas Power & Light Company Docket No. 50-313 Arkansas Nuclear One-Unit 1 License No. DPR-51 EA 86-151 During an NRC inspection conducted on January 6-31, 1986, 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 (1986), the Nuclear Regulatory Commission proposes to inpose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended, ("Act"),

42 U.S.C. 2282, PL 96-295, and 10 CFR 2.205. The particular violations and associated civil penalty are set forth below:

I- Violation Assessed a Civil Penalty 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that the design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program.

Contrary to the above, design control measures for design change package DCP 82-D-1050 failed to properly assess or verify the adequacy of design regarding the potential for a single failure, loss of one power supply, to cause the simultaneous blowdown of both steam generators during a main steam line break accident, a situation outside the plant's design hasis.

This condition was caused when the design change package was implemented during the Unit 1 1984 refueling outage without certain check valves, the purpose of which was to prevent the simultaneous blowdown.

This is a Severity Level III violation (Supplement I).

Civil Penalty - $50,000.

II. Violations Not Assessed a Civil Penalty A. 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly trans-lated into specifications, drawings, procedures, and instructions.

The AN0 Quality Assurance Manual - Operations, Section 3.0, Design Control, implements this reouirement and connits the licensee to the provisions of Regulatory Guide 1.64 and ANSI N45.2.11-1974.

Sections 4.0 and 6.0 of ANSI N45.2.11-1974 require, in part, that design activities are to be performed in a controlled, planned, and correct manner that is traceable to the design basis.

8611170170 861112 3 DR ADOCK 0500

Notice of Violation Contrary to the above, as of January 6,1986, the licensee's program for design control did not assure that design and design reviews were properly performed. -

1. The emergency feedwater (EFW) system design analysis was inadequate, in that:

a. The consequences of certain high energy line breaks in the area referred to as the " penthouse" on EFW system components coincident with a single failure and the consequences of a EFW high energy steca line break on other safety-related equipment in the area were not addressed.

b. The determination as to whether safety-related room cooling was needed when both EFW pumps were operating was not performed.

2. Design calculations and verifications associated with certain electrical equipment were inadequate in that:

a. The correction factors for operation of the station battery at minimum temperature, specified as 60 F in Procedure 1307.006, D07 Quality Surveillance, were not included (Calculation GE-830-1032-01, January 25,1984).

b. The station battery sizing calculations did not consider meter inaccuracy or increased loads during a design basis event (Calculation 83-1032-06, January 24,1986).

c. The valve actuator sizing analysis for motor starting torque did not adequately consider the design requirements (Calculations 80-1083A-02, January 14, 1986; 80-1083A-04, January 24, 1986; and 83D-1032-07, January 24,1986).

d. The compatibility of the DC distribution system components with the new, larger batteries was not determined (Calcula-l tion 83D-1032-02, February 17,1984).

l l e. The protective relay study for breaker A311 for the EFW j pump motor failed to document the source of the critical parameters (Calculation 84E-0083-12, November 19,1985).

3. Vendor-supplied motor operated valve design data were not adequately translated into controlling documents, in that:

a. Valve maintenance procedures did not include certain vendor information for torque switch settings and as a result the torque switch open setting for valve I CV 2627 was set below the manufacturer's tested setpoint.

Notice of Violation b. There were no documented bases for the torque switch settings for valves CV 2870 and CV 3851.

This is a Severity Level IV violation (Supplement I).

B. 10 CFR Part 50, Appendix B, Criterion XI, Test Control, requires, in part, that a test program shall be established to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.

The ANO Quality Assurance Manual - Operations, Section 11.0, Test Control, implements this requirement and commits the licensee to Regulatory Guide 1.33 and ANSI N18.7-1976.

ANSI N18.7-1976, Section 5.2.19, Test Control, requires, in part, that a test program be established, including preoperational tests, surveillance tests, and maintenance / modification tests such that the safety of the plant is assured by demonstrating the satisfactory performance of a system or component following plant maintenance or modifications.

Contrary to the above, as of January 6,1986, the licensee's program for test control did not demonstrate that components would perform satisfactorily in service.

1. The modification acceptance tests for the station batteries did not demonstrate that the batteries would perform acceptably.

a. The post-modification service test for battery 007 (ANO J0 05396) performed on March 24, 1984, in accordance with design change package DCP 83-1032 and calculation GE-83D-1032-01 did not include certain design requirements, including electrolyte temperatures, actual test current, battery minimum voltage limits, and discharge voltage profile calculations.

b. The post-modification testing performed approximately 1983-1984 in accordance with Special Work Plan 1409.29, after the removal of two cells from each station battery (DCP-83-119), used a battery temperature for which its basis could not be determined and the temperature correction factor was incorrectly applied.

2. The EFW system discharge piping valves (CV-2620, CV-2626, CV-2627, CV-2670, CV-2869, and CV-2870), installed during the 1984 refueling outage as part of the EFW upgrade modification (DCP 80-1083), had not been tested or evaluated to demonstrate the capability to operate under system flow conditions.

Notice of Violation 3. Post-maintenance testing had not been performed in accordance with Procedure 1402.09, Emergency Fcedwater Pump Maintenance, following three separate maintenance activities performed during the 1984 refueling outage for EFW pump P7A. Procedure 1402.09 provides detailed guidance for taking post-maintenance vibration readir.gs in the horizontal, vertical, and axial directions and requires that they be compared to a set of pre-maintenance vibration results.

a. The testing documented for the December 23, 1984, mainte-nance on EFW Pump P7A under JO 76916 was conducted on January 17, 1985; however, the test records did not document that additional modifications to the pump had been made on January 7-11 end therefore, the test 49 did not reflect the work done under J0 76916.

b. The testing documented on J0 81212 for replacement of a thrust bearing was missing some axial r'easurements and there was no pre-maintenance data for comparison.

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c. There was no post-maintenance test data or reference to test data recorded on J0 75648 for maintenance conducted on January 11, 1985.

4. The initial calibration and functional checkout of the Condensate Storage Tank (CST) level indication transmitter (LIT-4203) were not adequately performed and documented, and routine surveillance procedures were not developed and performed following installation of LIT-4203 during the 1984 refueling outage as part of the EFW upgrade modification (DCP 80-1083 and DCP 84-1045).

5. The required routine inservice testing of certain valves associated with the EFW system was not adequately performed and documented. The operability and the full stroke response of valves CS-98, CS-99, CS-261, CS-262, FW-55A, FW-55B, FW-56A, FW-56B, FW-10A/FW-61, and FW-10B/FW-62 had not been demonstrated and documented, although acceptable flow had been demonstrated through the flowpaths in routine pump flow tests.

This is a Severity Level IV violation (Supplement I).

C. Technical Specification 6.8.1 requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, November 1972.

Section I of Appendix A to Regulatory Guide 1.33, November 1972, states, in part, that maintenance affecting safety-related equipment

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Notice of Violation should be properly preplanned and perforned in accordance with written procedures, documented instructions, or drawirgs appropriate to the circumstances.

Contrary to the above, several discrepancies were identified regarding EFW motor operated valve (MOV) maintenance Procedures 1402.160, Limitorque Motor Operated Valve SMB-000 Maintenance, Revision 3; 1402.161, Limitorque Motor Operated Valve SMB-00 Maintenance, Revision 1; and 1402.71, EIM Motor Operated Valve Maintenance, Revision 2.

1. All three procedures referenced drawing E-195 for the description of the motor operated valve limit switch operation. However, this drawing did not show the Limitorque limit switch contact scheme and the EIM limit switch scheme incorrectly showed contact "LSO/G" as being closed continuously throughout valve travel.

2. Valves CV-2663, CV-2620, CV-2870, CV-3850, CV-3851, CV-2627, CV-2626, and CV-2869 were not identified as dc powered MOVs or as Q-listed valves.

3. The open and closed adjustments for torque switches were shown as reversed in Procedures 1402.160 and 1402.161.

4 Procedure 1402.161 incorrectly listed CV-3851 and CV-2620 as model SMB-00 operators, rather than as SMB-000 operators as installed.

5. The operation of the closed limit switches was incorrectly described in all three procedures.

6. Procedure 1402.71 incorrectly identified CV-3850 as a

" modulating" valve rather that a " seal-in" type design.

7. Procedure 1402.71 did not provide for independent verification of the removal of a test jumper which could interfere with normal valve operations.

This is a Severity Level IV violation (Supplement I).

D. 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings appropriate to the circumstances.

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Notice of Violation The ANO Quality Assurance Manual - Operations, Section 5.0, Instructions, Proceduras, and Drawings, implements the above requirement art requires, in part, that instructions, procedures, and drawings are provided for the control of activities which affect quality and safety at the nuclear plant, and include, as a minimum, administrative, general plant operation, rrodification, maintenance and repair, and control cf activities related to the ASME Code,Section III, Class 1, 2, or 3 components required to be operable.

Contrary to the above, as of January 6,1986, the licensee's prngram failed to assure that instructions and drawings were appropriate to the circumstances.

1. The following piping and instrumentation diagrams associated with systems important to safety were found to have incorrect valve positions, incomplete locked valve positions indicated..

or missing instrumentation bubbles:

a.

Drawing Emergency M-204, SheetRevision Feedwater, 3 of 4, Pip (ing 2 two & Instrument Diagram, examples).

b. Drawing M-206, Sheet 1 of 2, Piping & Instrument Diagram, Steam Generator Secondary System, Revision 45 (three examples).

c. Drawing M-202, Piping & Instrument Diagram, Main Steam, Revision 33 (two examples).

d. Drawing M-212, Sheet 1 of 2, Piping & Instrument Diagram, Plant Makeup Domestic Water Systems, Revision 29 (two examples).

2. The piping design specification for ANO-Unit 1, M-84, Piping Class Drawing, Revision 22, contained errors and was not adequately controlled.

a. DCP 80-10838 identified that a revision to the piping design specification was required; however, evidence of this change was not apparent.

b. Errors were identified between a controlled copy of specification M-84 and the one in Document Control. .

3. There were 18 examples of drafting errors or incorrect information noted on controlled drawings.

This is a Severity Level IV violation (Supplement I).

Notice of Violation Pursuant to the provisions of 10 CFR 2.201, Arkansas Power & Light Company is hereby required to submit to the Director, Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 611 Ryan Plaza Drive, Suite 1000, Arlington, Texas 76011, within 30 days of the date of this Notice a written statement or explanation, including for each alleged violation: (1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps which 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, the Director, Office of Inspection and Enforcement, may issue an order to show cause 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.

Within the same time as provided for the response required above under 10 CFR 2.201, Arkansas Power & Light Company may pay the civil penalty by letter addressed to the Director, Office of Inspection and Enforcement, with a check, draft, or money order payable to the Treasurer of the United States in the cumulative amount of Fif ty Thousand Dollars ($50,000) or may protest imposition of the civil penalty in whole or in part by a written answer addressed to the Director, Office of Inspection and Enforcement. Should Arkansas Power & Light Company fail to answer within the time specified, the Director, Office of Inspection and Enforcement, will issue an order imposing the civil penalty in the amount proposed above. Should Arkansas Power & Light Company elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, such answer may: (1) deny the violation listed in this Notice in

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(2) demonstrate extenuating circumstances, (3) show error in whole or in part(4) this Notice, or 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 five factors addressed in Section V.B 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. Arkansas Power & Light Company's attention is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.

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l Notice of Violation 1 Upon failure to pay any civil penalty due which has been subsequently determined in accordance with the applicable previsions of 10 CFR 2.205, this matter may be referred to the Attorney Ger.eral, 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.

FOR THE CLEAR F.EGULATORY COMMISSION obert D. Martin W

Regional Administrator Dated at Arlington, Texas, this TNay of November,1986.

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