ML20214F758
| ML20214F758 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 11/12/1986 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20214F741 | List: |
| References | |
| 50-413-86-25, 50-414-86-27, EA-86-147, EA086-147, EA86-147, NUDOCS 8611250421 | |
| Download: ML20214F758 (10) | |
Text
.
NOTICE OF VIOLATION Aku Duke Power CompanyPROPOSED IMPOSITID T0F CIVIL PENALT Catawba Units 1 and 2 Y
Docket Nos. 50-413 and 50-414 License Nos. NPF-35 and NPF-48 July 2,1986, violations of NRC rDuring the Nuclear Re EA 86-147 involved the failure of d mss $n equirwen(ts were identified.NRC) inspection and implement procedures. esign control measures and the f il e 28 -
and Procedure for NRC Enforcement A ti The violations In accordance with the " General St ture t the Nuclear Regulatory Commissi a
to Section 234 of the Atomic En c
ergy Act of 1954, as amendedon pro a ement of Polic 42 U.S.C. 2282, PL 96-295, and 10 CFR associated civil penalty are set fo th "Act"y pursuant 2.20E.
The particular, v(iolations and
),
A.
r below:
(
measures be established to assure th t, Criterion III, D and the des procedures,ign basis are correctly translated into spe ifi a
and instructions.
applicable regulatory requirements I
a Contrary to the above, as of Jun cations, drawings, c
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design control did not assure that D
(
e 27, 1986, CN-2-M-1527 esign Change Authorization (DCA)the the steam ge,nerator power operatedwhich changed the design b
{
or correctly tra j,
instructions. nslated into specifications, drawings (S/G PORVs), wa relief valves i
Specifically:
\\
, procedures, and 1.
DCA CN-2-M-1527 was not properly j
required by Station Directive 3 0 3 reviewed by plant personnel as for the effects on Operating Pro i
\\
Outside the Control Room from Hot St
.., Management of Shutdown Requests cedure OP/2/A/6100/04,
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result and inc,orrectly spec.5 of Procedure OP/2/A/6100/04 wasandby to i
of remaining ified the setpoint of the S not modified As a of full open. closed the S/G PORVs opened to app /G PORVs.
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Instead DCA CN-2-M-1527 was not properly roximately 75 percent 2.
i j
required Changes by Design Engineering Procedure EDP 3 17 human factors considerationsHandling, in that there wa i
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, Control Room the control mode of the S a uation done for Pump Turbine Control Panelthe S/G PORV controlle r labeling at the Auxiliary Feedwate e
e change to r
8611250421 861112 PDR ADOCK 0S000413 0
10 CFR Part 50 Appendix B, Criterion V, Instructions, Procedures, and t
Drawings, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the above, as of June 27, 1986, certain procedures affecting quality were inadequate or not properly implemented and contributed to the depressurization event of June 27, 1986.
Specifically:
1.
Operating Procedure OP/1/A/6100/04, Shutdown Outside the Control Room from Hot Standby to Cold Shutdown, was inadequate in that.5 to the procedure specified initial settings for valves 2NV-309 and 2NV-294 which resulted in these valves going to incorrect positions when control was transferred to the remote shutdown panels (Auxiliary Shutdown Panels A and B and the Auxiliary Feedwater Pump Turbine Control Panel).
2.
Test Procedure TP/2/A/2650/03, Loss of Control Room Functional Test, was inadequate in that the procedure lacked speci'fic criteria for termination of the test if the plant was determined to be in an uncontrolled or uncontrollable condition with control transferred to the remote shutdown panels.
3.
Operations Management Procedure OMP 1-6, Control Panel Information Changes, dated May 10, 1982, was not followed by plant operations personnel in the labeling of valves 2NV-294 and 2NV-309 at the remote shutdown panels.
OMP 1-6 states that changes to the control panel will conform to human factor guidelines and conventions.
However, the labels placed on the controllers for valves 2NV-294 and 2NV-309 were reversed and indicated opposite of the intended and anticipated meaning.
Collectively, these violations have been categorized as a Severity Level III problem (Supplement I).
(Cumulative Civil Penalty - $50,000 assessed equally between the violations.)
Pursuant to the provisions of 10 CFR 2.201, Duke Power Company is hereby required to submit to the Director, Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission, Region II, within 30 days of the date of this Notice a written statement or explanation including fnr 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.
NOTICE OF VIOLATION AND PROPOSED IMPOSITI F 0F CIVIL PENALTY' Duke Power Company Docket Nos. 50-413 and 50-414 Catawba Units 1 and 2 License Nos. NPF-35 and NPF-48 EA 86-147 During the Nuclear Regulatory Commission (NRC) inspection conducted on June 28 -
July 2,1986,- violations of NRC requirements were identified.
The violations involved the failure of design control measures and the failure to establish and implement procedures.
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 impose 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:
A.
10 CFR Part 50, Appendix B, Criterion III, Design Control, requires that measures be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions.
Contrary to the above, as of June 27, 1986, the licensee's program for design control did not assure that Design Change Authorization (DCA)
CN-2-M-1527, which changed the design basis for the mode of control for the steam generator power operated relief valves (S/G PORVs), was correctly translated into specifications, drawings, procedures, and instructions.
Specifically:
1.
DCA CN-2-M-1527 was not properly reviewed by plant personnel as required by Station Directive 3.0.3, Management of Shutdown Requests, for the effects on Operating Procedure OP/2/A/6100/04, Shutdown Outside the Control Room from Hot Standby /6100/04 to Cold Shutdown.
As a result, Enclosure 4.5 of Procedure OP/2/A was not modified and incorrectly specified the setpoint of the S/G PORVs.
Instead of remaining closed the S/G PORVs opened to approximately 75 percent of full open.
2.
DCA CN-2-M-1527 was not properly reviewed by design personnel as required by Design Engineering Procedure EDP 3.17, Control Room Changes - Handling, in that there was no evaluation done for human factors considerations.
The DCA was implemented and changed the control mode of the S/G PORVs without any visible change to the S/G PORV controllers or labeling at the Auxiliary Feedwater Pump Turbine Control Panel.
8611250421 861112 PDR ADOCK 05000413 O
T Notice of Violation B.
10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures,, or drawings.
Contrary to the above, as of June 27, 1986, certain procedures affecting quality were inadequate or not properly implemented and contributed to the depressurization event of June 27, 1986.
Specifically:
1.
Operating Procedure OP/1/A/6100/04, Shutdown Outside the Control Room from Hot Standby to Cold Shutdown, was inadequate in that.5 to the procedure specified initial settings for valves 2NV-309 and 2NV-294 which resulted in these valves going to incorrect positions when control was transferred to the remote shutdown panels (Auxiliary Shutdown Panels A and B and the Auxiliary Feedwater Pump Turbine Control Panel).
2.
Test Procedure TP/2/A/2650/03, Loss of Control Room Functional Test, was inadequate in that the procedure lacked specific criteria for termination of the test if the plant was determined to be in an uncontrolled or uncontrollable condition with control transferred to the remote shutdown panels.
3.
Operations Management Procedure OMP 1-6, Control Panel Information Changes, dated May 10, 1982, was not followed by plant operations personnel in the labeling of valves 2NV-294 and 2NV-309 at the remote shutdown panels.
OMP 1-6 states that changes to the control panel will conform to human factor guidelines and conventions.
However, the labels placed on the controllers for valves 2NV-294 and 2NV-309 were reversed and indicated opposite of the intended and anticipated meaning.
Collectively, these violations have been categorized as a Severity Level III problem (Supplement I).
(Cumulative Civil Penalty - $50,000 assessed equally between the violations.)
Pursuant to the provisions of 10 CFR 2.201, Duke Power Company is hereby required to submit to the Director, Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission, Region II, 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.
Notice of Violation Within the same time as provided for the response required above under 10 CFR 2.201, Duke Power 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 Fifty 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 Duke Power 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 Duke Power Company elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, such answer may:
(1) deny the violations listed in this Notice in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) 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.
Duke Power Company's attention is directed to the other provisions of 10 CFR 2.205 regarding the procedure for imposing a civil penalty.
Upon failure to pay any civil penalty due which has been subsequently 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 234c of the Act, 42 U.S.C. 2282.
FOR THE NUCLEAR REGULATORY COMMISSION Original signed by J. Nelsen Grace J. Nelson Grace Regional Administrator Dated at Atlanta, Georgia, thisf L day of November 1986
l'.
ENCLOSURE 2 NOV 12 886 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 membersofthe_NRCRegionIIstaffinAtlanta,Georgiatodiscussthereactor coolant' system depressurization event during Unit 2 s loss of control room test i
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 i
b.
Actions Taken c.
Consequences d.
Corrective Action 5.
Design Process and Corrective Action
+
. a.
Design Change Authorization Process b.
Corrective Actions c.
Human 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.
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q NOV 12 $86 ATTENDANCE LIST Ouke Power Company G. E. Vaughn, General Manager, Nuclear Stations J. W. Hampton, Station Manager, Catawba N.~A. Rutherford, Nuclear Licensing Supervisor H. B. Barron, Superintendent Operations, Catawba C. L. Hartzell, Compliance Engineer, Catawba R. L. Dobson, Design Engineer U.S. Nuclear Regulatory Commission J. N. Grace, Regional Administrator A. F. Gibson, Director, Division of Reactor Safety (DRS)
G. R. Jenkins, Director, Enforcement and Investigation Coordination Staff (EICS)
L. A. Reyes, Deputy Director, Division of Reactor Projects (DRP)
V. W. Panciera, Deputy Director, DRS V. L. Brownlee, Chief, Reactor Projects Branch 3, DRP T. A. Peebles, Chief, Reactor Projects Section 3A, DRP
'B. Wilson, Acting Chief, Operational Programs Section, DRS P. Skinner, Senior Resident Inspector, Catawba K. Van Doorn, Senior Resident Inspector, Catawba W. Lanning, Acting Deputy Director, DRP P.Burnett,ReactorInspector,TestProgramsSection,CRSg H.Christensen,ProjectEngineer,DRP S. F. Guenther, Resident Inspector, McGuire M. Thomas, Reactor Inspector, Test Programs Section, DRS L. Trocine, Enforcement Specialist, EICS T. O'Connor, Reactor Engineer, DRS 4
f
_.m.
NOTICE OF VIOLATION AND PROPOSED IMPOSITIUN 0F CIVIL PENALTY Duke Power Company Docket Nos. 50-413 and 50-414 Catawba Units 1 and 2 License Nos. NPF-35 and NPF-48 EA 86-147 During the Nuclear Regulatory Commission (NRC) inspection conducted on June 28 -
July 2, 1986, violations of NRC requirements were identified.
The violations involved the failure of design control measures and the failure to establish and implement procedures.
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 impose a civil penalt to Section 234 of the Atomic Energy Act of 1954, as amended, ("Act"y pursuant
),
42 U.S.C. 2282, PL 96-295, and 10 CFR 2.205.
The particular violations and associated civil penalty are set forth below:
A.
10 CFR Part 50, Appendix B, Criterion III, Design Control, requires that ceasures be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions.
Contrary to the above, as of June 27, 1986, the licensee's program for design control did not assure that Design Change Authorization (DCA)
CN-2-M-1527, which changed the design basis for the mode of control for the steam generator power operated relief valves (S/G PORVs), was correctly translated into specifications, drawings, procedures, and instructions.
Specifically:
1.
DCA CN-2-M-1527 was not properly reviewed by plant personnel as required by Station Directive 3.0.3, Management of Shutdown Requests, for the effects on Operating Procedure OP/2/A/6100/04, Shutdown Outside the Control Room from Hot Standby to Cold Shutdown.
As a result, Enclosure 4.5 of Procedure OP/2/A/6100/04 was not modified and incorrectly specified the setpoint of the S/G PORVs.
Instead of remaining closed the S/G PORVs opened to approximately 75 percent of full open.
2.
DCA CN-2-M-1527 was not properly reviewed by design personnel as required by Design Engineering Procedure EDP 3.17, Control Room Changes - Handling, in that there was no evaluation done for human factors considerations.
The DCA was implemented and changed the control mode of the S/G PORVs without any visible change to the S/G PORV controllers or labeling at the Auxiliary Feedwater Pump Turbine Control Panel.
10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the above, as of June 27, 1986, certain procedures affecting quality were inadequate or not properly implemented and contributed to the depressurization event of June 27, 1986.
Specifically:
1.
Operating Procedure OP/1/A/6100/04, Shutdown Outside the Control Room from Hot Standby to Cold Shutdown, was inadequate in that.5 to the procedure specified initial settings for valves 2NV-309 and 2NV-294 which resulted in these valves going to incorrect positions when control was transferred to the remote shutdown panels (Auxiliary Shutdown Panels A and B and the Auxiliary Feedwater Pump Turbine Control Panel).
2.
Test Procedure TP/2/A/2650/03, Loss of Control Room Functional Test, was inadequate in that the procedure lacked specific criteria for termination of the test if the plant was determined to be in an l
uncontrolled or uncontrollable condition with control transferred i
to the remote snutdown panels.
l 3.
Operations Management Procedure OMP 1-6, Control Panel Information Changes, dated May 10, 1982, was not followed by plant operations personnel in the labeling of valves 2NV-294 and 2NV-309 at the remote shutdown panels.
OMP 1-6 states that changes to the control panel will conform to human factor guidelines and conventions.
However, the labels placed on the controllers for valves 2NV-294 and 2NV-309 were reversed and indicated opposite of the intended and anticipated meaning.
Collectively, these violations have been categorized as a Severity Level III problem (Supplement I).
(Cumulative Civil Penalty - $50,000 assessed equally between the violations.)
Pursuant to the provisions of 10 CFR 2.201, Duke Power Company is hereby required to submit to the Director, Office of Inspection and Enforcement, l
U.S. Nuclear Regulatory Commission, Region II, within 30 days of the date of this i
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.
r-Notice of Violation 'dithin the same time as provided for the response required above under 10 CFR 2.201, Duke Power 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 Fifty 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 Duke Power 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 Duke Power Company elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, such answer may:
(1) deny the violations listed in this Notice in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) 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.
Duke Power Company's attention is directed to the other provisions of 10 CFR 2.205 regarding the procedure for imposing a civil penalty.
Upon failure to pay any civil penalty due which has been subsequently 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 234c of the Act, 42 U.S.C. 2282.
FOR THE NUCLEAR REGULATORY COMMISSION a
J. Nelson Grace Regional Administrator Dated at Atlanta, Georgia, this / b day of November 1986
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.
Human Engineering Deficiency Prioritization 6.
Duke Power Company Closing Remarks-7.
NRC Closing Remarks i
In closing, the NRC expressed that the meeting had enhanced the understanding of the incident and the extensive corrective actions taken by the licensee.
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ATTENDANCE LIST Duke Power Company G. E. Vaughn, General Manager, Nuclear Stations J. W. Hampton, Station Manager, Catawba N. A. Rutherford, Nuclear Licensing Supervisor H. B. Barron, Superintendent Operations, Catawba C. L. Hartzell, Compliance Engineer, Catawba R. L. Dobson, Design Engineer U.S. Nuclear Regulatory Commission J. N. Grace, Regional Administrator A. F. Gibson, Director, Division of Reactor Safety (DRS)
G. R. Jenkins, Director, Enforcement and Investigation Coordination Staff (EICS)
L. A. Reyes, Deputy Director, Division of Reactor Projects (DRP)
V. W. Panciera, Deputy Director, DRS V. L. Brownlee, Chief, Reactor Projects Branch 3, DRP T. A. Peebles, Chief, Reactor Projects Section 3A, DRP B. Wilson, Acting Chief, Operational Programs Section, DRS P. Skinner, Senior Resident Inspector, Catawba K. Van Doorn, Senior Resident Inspector, Catawba W. Lanning, Acting Deputy Director, DRP P. Burnett, Reactor Inspector, Test Programs Section, DRS H.Christensen,ProjectEngineer,DRP S. F. Guenther, Resident Inspector, McGuire M. Thomas, Reactor Inspector, Test Programs Section, DRS L. Trocine, Enforcement Specialist, EICS T. O'Connor, Reactor Engineer, DRS