ML20214F739
| ML20214F739 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 11/12/1986 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Tucker H DUKE POWER CO. |
| Shared Package | |
| ML20214F741 | List: |
| References | |
| EA-86-147, NUDOCS 8611250415 | |
| Download: ML20214F739 (6) | |
Text
t e-i NOV 121966 a
Docket Nos. 50-413 and 50-414 License Nos. NPF-35 and NPF-52 7
EA86-1q7 Duke Power Company ATTN: VHr. H. B. Tucker, Vice President Nuclear Production Department 422 South Church Street Charlotte, NC 28242 Gentlemen:'
N
SUBJECT:
NOTICE OF: VIOLATION AND PROPOSED IFPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT NOS. 50-413/86-25 AND 50-414/86-27)
ThisreferstoTheNRCinspectionconductedonJune28-July 2,1986,ofactivities authorized by NRC Licenses NPF-35 and NPF-52 for your Catawba facility.
This inspection was conducted as followup to the Catawba Unit 2 depressurization event of June 27, 1986, which occurred during a loss of control room test.
During this inspection, violations of NRC requirements were identified, and the report docu-menting the results of the inspection was sent to you by letter dated July 25, 1986.
These matters were also discussed by Dr. J. N. Grace, Regional Administrator, with Mr. G. E. Vaughn, General Manager, Nuclear Stations, in an Enforcement Conference held in the Region II Office on August 11, 198G.
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Violation A in the enclosed Notice of Violation and' Proposed Imposition of Civil Penalty (Notice) involves a significant failure in your' design control
. program.
The violation indicates that you had not exercised adequate control to ensure that a design change, Design Change Authorization (DCA) CN-2-M-1527, which changed the design bases of a system, was reviewed for its effect on established procedures and for human fac. tors considerations.
The DCA, which changed the~ mode of control of the steam generator power operated relief valves, was not reviewed for its' effect on an operating. procedure used to establish initial controller settings in preparation for the Loss of Control Room Test.
As a result,' during the_ test, on the transfer of control from the control room to the Auxiliary Shutdown Panels and the Unit 2 Auxiliary Feedwater Pump Turbine Control Panel,'the steam generator power _ operated relief valves opened to approximately 75 percent of the full open position rather than remaining closed as intended; causing a rapid decrease'in both pressure and level in the reactor coolant system.
In addition, inadequate labeling of the controllers prevented the plant operators at the remote shutdown panel from diagnosing the problem and regaining control of the plant.
It is significant that for six minutes after the steam generator power operated relief valves opened, no operator action was taken to transfer control to the control room.
It is fortuitous that there were no adverse thermal-hydraulic or nuclear effects on the plant because of-this design control failure.
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Duke Power Company NOV 121986 Violation B in the enclosed Notice involves the failure to establish adequate procedures for the Loss of Control Room Test.
Procedures used in the Loss of Control Room Test were inadequate in that they specified improper initial settings such that, upon transfer of control to the Auxiliary Feedwater Pump Turbine Control Panel from the control room, the charging flow and seal injection flow control valves went to positions not as intended.
The test procedures were also inadequate in that neither the limitations of the remote shutdown panels nor consideration of safety system parameters were taken into account in guidance provided to the plant operators for termination of the Loss Control Room Test.
One such limitation was the fact that safety injection could not be initiated from actions at the remote shutdown panels.
Actions would have to be performed at other locations in the plant in order to start and align the required components.
Significant reactor coolant system parameters of pressurizer level and pressure were not available to the plant operators at the Auxiliary Shutdown Panels when these parameters went bblow the range of the instruments. Violation B also in-vd ves the failure of plant personnel to follow a procedure which provided guidance for changes to the remote shutdown panels involving human factors considerations.
The labeling of valve controllers indicated the opposite of that intended and resulted in plant operators manipulating the valves improperly.
These violations are significant because they demonstrate the need for more thorough reviews of test procedures and design changes and their effects on plant procedures.
The difficulties encountered during the Loss of Control Room Test indicate that at the time of the test, existing plant hardware and procedures were. incapable of assuring that when the reactor was shutdown from outside the control room it could be maintained in a stable condition. While we recognize that this test was intended to demonstrate this capability, there were opportunities during the design, installation, and testing of the steam generator power operated relief valve controllers to identify the types of problems which occurred during the Loss of Control Room Test.
Therefore, to emphasize the importance of complete and thorough reviews of design changes, the necessity of adequate procedures and procedural adherence, I have been authorized, after consultation with the Director, Office of Inspection and Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Fifty Thousand Dollars
($50,000) for the violations described in the enclosed Notice.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C (1986) (Enforcement Policy), the violations described in the enclosed Notice have been categorized as a Severity Level III problem.
The base civil penalty for a Severity Level III violation or problem 1s $50,000.
The escalation and mitigation factors in the Enforcement Policy were considered.
Although we acknowledge your prompt and extensive corrective actions, including the review of all design changes, we also note the occurrence of previous testing deficiencies during Unit 2 cold hydrostatic tests that resulted in overpressurization of residual heat removal system piping and the volume control tank.
Therefore, neither mitigation nor escalation of the base civil penalty is deemed appropriate in this case.
Duke Power Company NOV 121986 During this inspection, an unresolved item was also identified.
This item concerns the adequacy of training of licensed personnel on facility design changes.
In accordance with the current NRC policy statement on training and qualification of nuclear power plant personnel, this violation is not cited.
However, the promptness and adequacy of your corrective actions will be reviewed at a future date to assure compliance with 10 CFR Part 50, Appendix B, Criterion XVI.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.
In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence.
After reviewing your response to this Notice, including your proposed corrective actions, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Room.
Theresponsedirectedbythisletteranditsenclosuresarenotsubjecttothe clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Sincerely, r /9 '
J. Nelson Grace Regional Administrator
Enclosures:
1.
Notice of Violation and Propo:;ed Imposition of Civil Penalty 2.
Enforcement Conference Summary cc w/encls:
J. W. Hampton, Station Manager, Catawba
ENCLOSURE 2 ENFORCEMENT CONFERENCE
SUMMARY
Licensee:
Duke Power Company Facility:
Catawba Nuclear Station License Nos.:
NPF-35 and NPF-52 Docket Nos.:
50-413 and 50-414 On August 11, 1986, representatives of the Duke Power Company (DPC) met with membersoftheNRCRegionIIstaffinAtlanta,Georgiatodiscussthereactor coolant system depressurization event during Unit 2 s loss of control room test on June 27, 1986.
The following was discussed in detail:
1.
NRC Opening Remarks 2.
Duke Power Company Opening Remarks
^
3.
Overview of Depressurization Incident 4.
Description of Incident a.
Sequence of Events b.
Actions Taken c.
Consequences d.
Corrective Action 5.
Design Process and Corrective Action a.
Design Change Authorization Process b.
Corrective Actions c.
Huran Engineering Deficiency Prioritization 6.
Duke Power Company Closing Remarks 7.
NRC Closing Remarks In closing, the NRC expressed that the meeting had enhanced the understanding of the incident and the extensive corrective actions taken by the licensee.
s
Duke Power Company NOV 121986 During this inspection, an unresolved item was also identified.
This item concerns the adequacy of training of licensed personnel on facility design changes.
In accordance with the current NRC policy statement on training and qualification of nuclear power plant personnel, this violation is not cited.
However, the promptness and adequacy of your corrective actions ~will be reviewed at a future date to assure compliance with 10 CFR Part 50, Appendix B, Criterion XVI.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.
In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Room.
The.esponse directed by this letter and its enclosures are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Sincerely, Original signed by J. Nelsen Grace J. Nelson Grace Regional Administrator
Enclosures:
1.
Notice of Violation and Proposed Imposition of Civil Penalty 2.
Enforcement Conference Summary
'c w/encls:
j/J. W. Hampton, Station Manager, Catawba
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