ML20216B258
| ML20216B258 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 08/29/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20216B215 | List: |
| References | |
| EA-97-055, EA-97-55, NUDOCS 9709050265 | |
| Download: ML20216B258 (7) | |
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1 NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Virginia Electric and Power Company Docket Nos, 50 280 and 50 281 Surry Power Station License Nos. DPR 32 and DPR 37 EA 97 055 During an NRC inspection conducted between January 13 and 17, 1997, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG 1600, the NRC proposes to impose a civil penalty Atomic Energy Act of 1954, as amended (Act) , 42 pursuant U.S.C. 2282, to Section and 10 CFR 234 2.205.
of the The particular violations and associated civil penalty are set forth below:
A. 10 CFR 50.65(a)(1) requires, in part, that the holders of an operating license shall monitor the performance or condition of structures, systems, or components ('SSCs) within the scope of the rule as defined by 10 CFR 50.65(b), against licensee established goals, in a manner sufficient to provide reasonable assurance that such structures, systems, and components, are capable of fulfilling their intended functions. Such goals shall be established commensurate with safety.
When the performance or condition of a structure, system, or com)onent does not meet established goals, appropriate corrective action s1all be taken.
Contrary to 10 CFR 50.65(a)(1), as of January 13, 1997, the licensee
- failed to monitor the perforir.ance-and establish goals commensurate with safety for the emergency switch gear heating ventilation and air conditioning system, as required by 10 CFR 50.65(a)(1), in a manner sufficient to provide reasonable assurance that such a structure, system, and component, was capable of fulfilling its intended functions.
The emergency switch gear heating ventilation and air conditioning system is a system required in. order for the facility to shut down the reactor and maintain it in a safe shutdown condition. (01013)
B. 10 CFR 50.65(a)(1) requires, in part, the holders of an operating license shall monitor the performance or condition of SSCs, as defined by 10 CFR 50,65(b), against licensee established goals, in a manner sufficient to provide reasonable assurance that such structures, systems, and components are capable of fulfilling their intended functions. When the performance or condition of a structure, system, or component does not meet established goals, appropriate corrective action shall be taken.
'10 CFR 50.65(a)(2) requires, in part, that monitoring as specified in M CFR 50.65 Section (a)(1) is not required where it has been der.Onstrated that the performance or condition of a structure, system, or component is being effectively controlled through the performance of appropriate preventive maintenance, such that the structure, system, or component remains capable of performing its intended function.
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Notice of Violation and Proposed 2 Imposition of Civil Penalty Contrary to 10 CFR 50.65(a)(2), as of July 10, 1996, the time that the licensee elected to not monitor the performance or condition of certain SSCs against licensee established goals pursuant to the requirements of Section (a)(1), the licensee failed to demonstrate that the performance or condition of SSCs within the scope of 10 CFR 50.65 had been effectively controlled through the performance of ap 3reventive maintenance, as evidenced by the following examples,propriate each of w11ch would constitute a separate violation:
(1) The licensee failed to demonstrate that the performance of the risk significant, direct current power, emergency switch gear heating, ventilation and air conditioning (chillers), and service water systems, and the non risk significant emergency lighting and condensate polishing systems, had been effectively controlled through the performance of appropriate preventive maintenance in accordance with the requirements of 10 CFR 50.65(a)(2).
Specifically, the licensee failed to evaluate the appropriateness of the performance of preventive maintenance on these systems prior to placing these SSCs under Section (a)(2). The evaluation of the appropriateness of the preventive maintenance system failures was not adequate because it failed to consider system failures prior to July 10, 1996. Without an evaluation of the appropriateness of preventive maintenance performed on these systems prior to July 10, 1996, the licensee was unable to demonstrate that the performance or condition of these systems were effectively controlled through the performance of appropriate preventive maintenance, such that the SSCs remain capable of performing their intended functions.
(2) The licensee failed to demonstrate that the >erformance of the non risk significant radiation monitors had aeen effectively controlled through the performance of appropriate preventive maintenance in accordance with the requirements of 10 CFR 50.65(a)(2), Specifically, the licensee failed to adequately evaluate the appropriateness of the performance of preventive maintenance on the radiation monitors prior to placing these SSCs under Section (a)(2). The evaluation of the appropriateness of the preventive maintenance was not adequate because it had failed to identify that maintenance performed on the system had not 3revented excessive inoperability and unavailability of tie radiation monitors such that the monitors may not have been capable of performing their intended function of either (1) alerting the licensee that radiological set points had been exceeded, or (2) initiating an automatic sefety system actuation.
(3) The licensee failed to demonstrate that the 3erformance of the risk significant reactor protection system (1PS) and the safety injection actuation system (SIAS) were being effectively controlled through the performance of appropriate preventive
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Notice of Violation and Proposed 3 Imposition of Civil Penalty maintenance in accordance with the requirements of 10 CFR 50.65(a)(2). Spedfically, 7.he licensee failed to demonstrate it had established adequate measures to evaluate the effectiveness of preventive maintenance on these risk significant SSCs prior to placing these SSCs under Section (a)(2) in that it used a standard that would allow u) to three maintenance preventible functional failures (M)FF) per operating cycle.
Allowing three MPFFs for the risk significant RPS and SIAS would not demonstrate that the performance of the SSCs were being effectively controlled through appropriate preventive maintenance.
(4) The licensee failed to demonstrate that the performance of the risk significant component cooling water pumps and the instrument air compressor had been effectively controlled through the performance of appropriate preventive maintenance in accordance with the requirements of 10 CFR 50.65(a)(2). Specifically, the licensee failed to establish any measure to evaluate the a>propriateness of the performance of preventive maintenance on t1e component cooling water pumps and the instrument air compressor prior to placing these SSCs under Section (a)(2).
Measures to evaluate the appropriateness of the 3reventive maintenance were necessary to demonstrate that t1e performance or condition of the components were being effectively controlled through appropriate preventive maintenance such that the component ,
cooling water pumps and the instrument air compressor remain capable of performing their intended function.
(5) The licensee failed to demonstrate that the performance of the risk significant reactor coolant system code safety valves had been ef fectively controlled through the >erformance of appropriate preventive maintenance in accordance wit 1 the requirements of 10 CFR 50.65(a)(2). Specifically, the licensee had failed to establish adequate measures to evaluate the appropriateness of the performance of preventive maintenance on the reactor coolant system code safety valves prior to placing these SSCs under Section (a)(2). The measures used in the evaluation of the appropriateness of the preventive maintenance-were not adequate because they failed to consider set point drift of the valves.
Measures for the evaluation of set point drift were necessary because, if preventive maintenance fails to preclude change to the set point of the reactor coolant system code safety valves, the valves may not be capable of performing their intended function of protecting the reactor coolant system from over pressurizing and failing.
(6) The licensee failed to demonstrate that the performance of the risk significant emergency service w&ter system had been effectively controlled through the performance of appropriate preventive maintenance in accordance with the requirementt of 10 CFR 50.66(a)(2). Specifically, the licensee failed to
l 6 Notice of Violation and Proposed 4 Imposition of Civil Penalty adequately evaluate the appropriateness of the performance of preventive maintenance on this system prior to placing this SSC under Section (a)(2). The evaluation of the appropriateness of the preventive maintenance system failures was not adequate because it failed to consider failures of periodic tests for system operability prior to July 10, 1996. Without an evaluation of the appropriateness of preventive maintenance performed on this system prior to July 10, 1996, the licensee was unable to demonstrate that the performance of the system was effectively controlled through the performance of appropriate preventive maintenance, such that this SSC remains capable of performing its intended function.
(7) The licensee failed to demonstrate that the performance of standby functions of the electro hydraulic control system, bearing cooling system, boric acid transfer auxiliary building heating, pumps (emergency boratior mode), ventilation and co the control room emergency ventilation system had been effectively controlled through performance of appropriate preventive maintenance in accordance with the requirements of 10 CFR 50.65(a)(2). Specifically, the licensee failed to establish any measures to evaluate the appropriateness of the performance of preventive maintenance on these SSCs prior to placing these SSCs under Section (a)(2). Without any measures to evaluate these standby functions, the licensee was unable to demonstrate that the performance or condition of these SSCs were effectively controlled through the >erformance of appropriate preventive maintenance, such that taese SSCs remain capable of performing their intended function. (01023)
C. Technical Saecification (TS) 6.4, Unit Operating Procedures, states in Part A.7, tlat detailed written procedures with appropriate checkoff lists and instructions shall be provided for preventive or corrective maintenance operations which could have an effect on the safety of the reactor. Part 0 of TS 6.4 states that ali procedures described in Specification 6.4. A shall be followed.
Virginia Power Station Administrative Procedure VPAP 0815, Maintenance Rule Program, Revision 3, and VPAP 2001, Station Planning and 2
Scheduling, were established to provide instructions for preventive and corrective maintenance operations.
(1) VPAP 0815, Revision 3, included the screening criteria for cause determinations of Maintenance Preventable Functional Failures (MPFF), an activity which could have an effect on the safety of the reactor. Section 4.11 of VPAP 0815 included a requirement that a SSC within the scope of the Rule must experience a failure which resulted in a loss of risk significant or standby train function and/or loss of a non risk significant system function that affected plant level monitoring criteria prior to screening for a MPFF.
Notice of Violation and Proposed 5 Imposition of Civil Penalty Contrary to the above, as of January 13, 1997, the instructions )
3rovided in Virginia Power Station Administrative Procedure !
VPAP 0815. Revision 3, were not appropriate, in that VPAP 0815 did not prescribe adequate instructions regarding cause determinations 1 for HPFFs in the main feedwater, chemical ar.d volume control, and i radiation monitoring systems. Specifically, Section 4.11 of VPAP 0815 did not provide instructions to allow for screening of HPFFs for a SSC within the scope of the Rule without experiencing a failure which resulted in a loss of risk significant or standby .
train function and/or loss of a non risk significant system '
function that affected plant level monitoring criteria. During the inspection, examples of HPFFs were identified for the main feedwater, chemical and volume control, and radiation monitoring systems which had not been identified by the licensee due to this procedure inadequacy. Limiting the screening of functional failures to failures that actually cause plant transients does not provide assurance that the main feedwater system, the chemical and volume control system, and the radiation monitoring system remain capable of performing their intended function thereby affecting the safety of the reactor. (01033)
(2) VPAP 0815. Revision 3, Section 5.12, requires the Maintenance Rule review, and approve performance criteria Working Group toand for risk significant develop, Maintenance Rule structures, systems, an components. .
Contrary to the above, the licensee failed to follow VPAP 0815 in that the performance criteria for the reactor protection system, a system where performance has an effect on the safety of the reactor, was changed on January 16, 1997 without approval of the Maintenance Rule Working Group as required by Section 5.12 of VPAP 0015. (01043)
(3) VPAP 2001, Revision 3, Section 6.7,2, requires that the approval of the Assistant Station Hanager Operations and Maintenance be obtained whenever two or more risk significant systems or-components are to be unavailable which are not addressed in the site matrix for removing equipment from service during on line operations.
Contrary to the above, the licensee failed to obtain approval from the Assistant Station Manager Operations and Maintenance on October 17, 1996, when one pressurizer power operated relief valve was blocked and an instrument air compressor was unavailable (both risk significant components whose removal from service would have an effect-on the safety of the reactor and not addressed in the.
site matrix) as required by Section 6.7.2 of VPAP 2001. (01053) 4 These violations represent a Severity Level III problem (Supplement I).
Civil Penalty $55,000 f
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Notice of Violation and Proposed 6
-Imposition of Civil Penalty i
Pursuant to the provisions of 10 CFR 2.201, Virginia Electric and Power Company (Licensee) is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice of Violation and Pro wsed Imposition of Civil Penalty (Notice). This reply should be clearly mar (ed as a
- Reply to a Notice of Violation" and should include for each alleged violation: (1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, and if denied, the reasons why, (3) the corrective steps that have been taken and the results achieved.
(4) the corrective steps that 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, an order or a Demand for Information may be issued as 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, the Licensee may pay the civil penalty by letter addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, money order, or electronic transfer payable to the Treasurer of the United States in the amount of the civil penalty proposed above, or the cumulative amount of the civil penalties if more than one civil penalty is proposed, or may protest imposition of the civil penalty in whole or in part, by a written answer addressed to the Director Office of Enforcement, U.S.
Nuclear Regulatory Commission. Should the Licensee fail to answer within the time specified, an order imposing the civil penalty will be issued. Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil genalty, in whole or in part, such answer should be clearly marked as an Answer to a Notice of Violation" and may: (1) deny the violation (s) 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 factors addressed in Section VI.B.2 of the Enforcement Policy 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. The attention of the Licensee is direct::d 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 subsequently has been 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. 2282c.
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i Notice of Violation and Proposed 7 Imposition of Civil Penalty The response noted above (Reply to Notice of Violation, letter with payment of l civil >enalty, and Answer to a Notice of Violation) should be addressed to:
L James _ieberman, Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, One White Flint North,11555 Rockville Pike, Rockville, MD 20852-2738, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region 11 and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice.
Because your res>onse will be placed in the NRC Public Document Room (PDR), to the extent possi ale, it should not include any personal privacy, aroprietary, or safeguards information so that it can be placed in the PDR wit 1out redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you mwit s>ecifically identify the portions of your response that yot! seek to have withield and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2,790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described-in 10 CFR 73.21.
Dated at Atlanta, Georgia this 29th day of August 1997
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