ML20244B102
| ML20244B102 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 04/07/1989 |
| From: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20244B097 | List: |
| References | |
| EA-88-284, NUDOCS 8904190008 | |
| Download: ML20244B102 (5) | |
Text
_ - _ -
APR -71989 NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES Arkansas Power & Light Company Dockets:
50-313; 50-368 Arkansas Nuclear One (ANO)
Licenses: DPR-51; NPF-6 EA 88-284 During NRC inspections conducted October 24 through November 30, October 30 through November 4, November 28-29, and December 1-31, 1988, violations of NRC requirements were identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 Co Part 2, Appendix C 53 Federal Register 40019 (October 13,1988), the Nuclear Regulatory Commission proposes to impose civil penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as amended, 42 U.S.C. 2282, and 10 CFR Part 2.205. The particular violations and associated civil penalties are set forth below:
1.
Violation Involving Failure to Take Prompt Corrective Action Criterion XVI of Appendix B to 10 CFR Part 50 requires in part that conditions adverse to quality, such as failures, malfunctions, deficien-cies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
Contrary to the above, AP&L failed to promptly correct identified conditions adverse to quality as evidenced by the following:
A.
Licensee Memorandum NOC-10313 dated January 8, 1982, identified that certain calculated equipment nozzle loads exceeded design and/or vendor-allowable loads. For example, the calculated load on the decay heat removal pump suction nozzle was 14,870 ft-lbs versus an allowable of 3,800 ft-lbs. A report for a nozzle-load study performed by Bechtel was issued to AP&L on December 31, 1985. This report again identified equipment nozzle loads which exceeded vendor-allowable loads in 22 cases and Bechtel Power Corporation-allowable loads in seven cases. Corrective action for this matter was not orompt in that the identified deviations from allowable equipment, nozzle loads were not resolved until November 1988.
B.
Report of Abnormal Condition (RAC) 2-88017 issued by the licensee on February 3,1988, documented a problem with Unit 2 engineered safety features (ESF) response time testing methodology. Procedure 2305.03,
" Engineered Safety Features System Response Time Test," did not measure or account for the time required for ESF actuated pumps or fans to accelerate and develop required discharge pressure or air flow. The discrepancy in the test method applied to the previous ESF response time tests for high pressure safety injection pumps, low pressure safety injection pumps, containment spray pumps, emergency l
feedwater pumps, and containmer.t cooling f ans. Corrective action for this identified condition was not prompt in that testing of components l
and comparison with Technical Specification (TS) requirements was not completed until October 27, 1988.
8904190008 890407 PDR ADOCK 05000313 Q
APR -71989 Notice of Violation I
-C.
Concerns with performance of the Unit 1 penetration room ventilation system were identified by an NRC inspector and documented as an unresolved item in NRC' Inspection Report 50-313/87-18; 50-368/87-18 issued on July 16, 1987. These concerns related to the ability of the system to produce a vacuum in and draw air from each of the six penetration rooms in accordance with the system design. Licensee test data indicated that vacuum in the penetration rooms was significantly less than the low vacuum alarm setpoint during system
)
operation. Corrective action to verify that this system would perform as designed was not prompt in that system performance was not verified until November-1988.
D.
ConditionReport(CR) 1-88-0122 initiated by the licensee on August 5, 1988, identified a deficiency in that there were no existing stress-calculations for certain piping containing Valves CV-2123, CV-2126, CV-2133, and CV-2136 in_the Unit 1 penetration room ventilation system.
The CR stated that~ operability of the system during a seismic event could not be shown by the existing qualifying calculations since the
-weights of the' valves were not. included in the analyses.. Corrective action for this issue was not prompt in that the deficiency was not scheduled to be resolved prior to the plant entering an operational condition where this system was required to be operable. The assigned action had a due date of December 1, 1988, but the plant was scheduled to restart from a refueling outage in November 1988.
This is a Severity Level III violation.
Civil Penalty - $100,000 II. Violations Involving Inadeauate Control of Safety-related Equipment l
Status A.
Violation of Technical Specifications TS Section 3.4.1 states that the reactor shall not be heated above 280 F unless both emergency feedwater (EFW) pumps and their flow paths are operable.
Contrary to the above, on November 24, 1988, Unit 1 was heated above 280 F with the P7A turbine driven emergency feedwater pump inoperable because it was not coupled to its turbine driver.
B.
Violation of 10 CFR Part 50, Appendix B, Criterion XIV Criterion XIV of Appendix B to 10 CFR Part 50 requires that measures shall be established for indicating the operating status of systems of the nuclear power plant, such as by tagging valves and switches, to prevent inadvertent operation.
i
^
~
APR -71989 Notice'of Violation Contrary to the above, on November 28, 1988, it was found that measures were not established to prevent inadvertent operation of the uncoupled P7A turbine driven emergency feedwater pump. The system.
was aligned for automatic initiation and inadvertent operation was possible for a period of up to 4 days, creating the potential for equipment damage or personnel injury.
C.
Violations of 10 CFR Part 50, Appendix B, Criterion V Criterion V of Appendix B to 10 CFR Part 50 requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomp.lished in accordance with these instructions, procedures,'or drawings.
1.
Contrary to the above, on December 16, 1988, with Unit 1 in hot standby, appropriate work instructions were not implemented for a seal weld repair of Valve MU-45C. After repairing this manual high pressure safety injection valve, the valve was reopened before the packing gland studs were. reinstalled, resulting in an approximate 25 gpm high pressure reactor coolant system leak.
2.
Contrary to the above, on December 16, 1988, the licensee discovered that previous maintenance work on high pressure safety injection manual isolation valve MU-450 had been performed without implementation of appropriate work instructions. This led to the improper reassembly of the valve in that the yoke was only partially threaded (three threads) i into the valve body, creating the potential for a failure of this yoke and an unisolable reactor coolant system leak.
The above violations are considered collectively as a Severity Level III problem (Supplements).
Civil Penalty - $75,000. (Assessed equally among the violations)
Pursuant to the provisions of 10 CFR 2.201, Arkansas Power & Light 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. This reply should be clearly marked 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 l
violation if admitted, (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)thedatewhenfullcompliancewillbeachieved.
If an adequate reply is not received within the time specified in this Notice, an order may be issued 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 ta ke n. 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.
I J
l
APR - 71989 Notice of Violation !
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, or money order payable to the Treasurer of the United States in the cumulative amount of the civil penalties proposed above or may protest imposition of the civil penalties 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 penalty, 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 listed in this Notice in whole or in part (2) demonstrate extenuating circumstances, (3) show error inthisNotice,or(4)showotherreasonswhythepenaltyshouldnotbeimposed.
In addition to protesting the civil pe-lty h whole or in part, such answer may request remission or mitigation of the per alty.
In requesting mitigation of the proposed per.alty, the 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. The attention of the Licensee 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 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, i
remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282c.
The responses t<
the Director, Office of Enforcement, noted above (Reply to a Notice of Violation, letter with payment of civil penalty and answer to a Notice of Violation) should be addressed to: Director, Office of Enforcement, U.S. 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 copy to the NRC Resident Inspector, at Arkansas l
Nuclear One.
FOR THE NUCLEAR REGULATORY COMMISSION J
. h bM l
d
,obert D. M
' Regional Administr or j
Dated at Arlington, Texas, This 7th day of April 1989.
3$"
g 7 lggg g
Arkansas Power & Light Company DISTRIBUTION PDR-SECY CA HThompson, DEDS JTaylor, DEDR-TMurley,-NRR
~_SVarga, NRR JLieberman, OE LChandler, OGC' Enforcement Officers-RI, RII', RIII, RV-FIngram, PA/0GPA cEJordan, AE0D-BHayes, 01 FHerr, 0IA JLuehman, OE-
. Day File EA File
'BSummers, 0 (ltrhd) gDCSl(IE14))
\\\\
RIV DISTRIBUT ON:
RRartin.
'JMontgomery RBangart LCallan JMilhoan ABeach Chamberlain WJohnson, SRI JGilliland (ltr hd)
CHackney WBrown-RWise DRP Files DRS' Files DRSS Files
.E0 Files RIV Files RSTS Operator MIS Coordinator OE.
RA:RIV D:0E DEDS i
JLuehman RDMartin JLieberman HThompson 3\\/89 4Q/89 4/3/89 4/$89 c nqi-t oy a 4&/e7
]
caam 1
j