ML20246L813

Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $25,000.Violation Noted:Breakers for Three Valves Left Closed & Energized,Contrary to Desired Position on Tagout Sheet & Test Accepted W/O Noting Discrepancy

ML20246L813
Person / Time
Site:	Pilgrim
Issue date:	08/23/1989
From:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20246L788	List: ML20246L782 ML20246L813
References
EA-89-095, EA-89-95, NUDOCS 8909070048
Download: ML20246L813 (4)

Text

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NOTICE OF VIOLATION AND

. PROPOSED IMPOSITION OF CIVIL PENALTY

! Boston Edison Company Docket.No. 50-293 Pilgrim Nuclear Power Station - License No. DPR-35 EA 89-95 On April 13-19, 1989, an NRC Augmented Inspection Team (AIT) inspection was conducted to establish and evalutte the facts associated with the overpressure-zation of the Reactor Core Isolation Cooling (RCIC) System on' April 12, 1989.

Based on an evaluation of the AIT inspection, violations of NRC requirements were identified. In accordance with the "Ger.aral Statement of Policy and Procedure for NRC Enforcement Actions,".10 CFR Part 2, Appendix C, (1989), the Nuclear Regulatory-Commission (NRC) 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, and 10 CFR 2.205. The particular violations and associated civil penalty are set forth below:

Technical Specification 6.8.A requires that written precedures and administrative policies be established and imp 19mented that meet or-exceed the requirements of Section 5.1 of ANSI N18.7-1972. ANSI N18.7-1972, Section 5.1,." Rules of Practice," states that rules and instructions pertaining to personnel conduct and control and method of conducting operations shall be established. Section 5.1.2 states that procedures shall be followed.

A. Procedure 1.4.5, "PNPS Tagging Procedure," Revision 24, Step 2.1.4 states that whenever work is to be done on or near any equipment under the jurisdiction of Boston Edison Company, this procedure shall be followed. Step 6.2.1 states that red tags must be placed by use of the tagout sheet. Step 6.4.8 states that the Operating Supervisor will assign another responsible person to verify the isolation (if required).

Procedure 1.3.34, " Conduct of Operations," Revision 17, Step 6.5[4](b)(1) states that the verifier may not accompany the individual who performed the lineup and may not participate j in the activity being verified.

Contrary to the above, at about 8:23 a.m. on April 12, 1989, I during installation of the tagout in preparation for a system logic test of the Reactor Core Isolation Cooling System in J

accordance with Procedure 8.M.2-2.10.11.3, the above mentioned '

procedures were not followed in that, 1

1. tagging errors occurred in thd braakers for three valves (Nos.

MD-1303-48, 26 and 22) were left clased and energized, contrary to the desired position on the tagout sheet; breakers for two valves (Nos. M0-1301-60 and 62) were opened /deenergized, contrary to the tagout sheet's desired position of closed /

energized; and the breaker for valve M0-1301-17 was left OFFICIAL RECORD COPY CP PKG PILG EA 89 0006.0.0 gO o 9// ff 172 9 08/18/89 y a ay,pn

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- open/deenergized and tagged in that position contrary to the1 fact that this breaker was not to have7been affected by the

-tagout; and'

2. operators required to perform and verify the tagouts for the

'  : system logic testing per Procedure 8.M.2-2.10.11.1' performed these activities in the same location (MCC-D7) at the same time.

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.B. Procedure 1.4.5, "PNPS Tagging Procedure," Revision 24, Step 6.4.10 states that'the supervisor who is in charge of the work for which the isolation is made (or a designated member of the work crew)

'shall review the physical isolation and tagging in the field prior to beginning work. The supervisor or work crew member shall sign

-the " Isolation Reviewed / Inspection By" block on the tagout sheet.

. Contrary to the above, at about 8:37 a.m. on April 12 -1989, during preparations for the test of the RCIC system logic testing in accordance with' Procedure 8.M.2-2.10.11.1,.neither the supervisor nor.a designated alternate in charge of the testing physically e

-inspected the equipment isolation and tagging, as required, prior i to the beginning of the work.

o.- C. Procedure 1.3.34, " Conduct of Operations," Revision 17, Step.6.10 states that certain complex or infrequently performed activities warrant a pre-evolution briefing which;is to be conducted for events which may result in challenges to safety systems if improperly conducted (such as Logic System Tests).

Step 5.6[2] states that the Nuclear Plant Reactor Operator (NPRO) is responsible'for reviewing plant status upon relieving the watch and for maintaining an awareness of changes in plant conditions. Step 5.6[3] states that the NPR0'is responsible for maintaining alertness at all times in order to ensure that the plant is operating safely.

Contrary to the above, on April 12, 1989., a pre-evolution briefing-was not conducted prior to the commencement of the test of the RCIC system logic testing in accordance with. Procedure 8.M.2-2.10.11.1.

Further, the licensed Nuclear Plant Reactor Operator did not maintain awareness of plant conditions at all times in that when he performed control board switch manipulations per Procedure 8.M.2-2.10.11.1, he did not notice that the position indicator Mghts for eight of the RCIC system valves were incorrectly lit.

D. Procedure 1.3.3d, "ConductofOperations," Revision 17, Step 6.12[1]

states that approved written procedures and instructions shall be adhered to by all station personnel. The Acceptance Criteria of the RCIC system logic testing (Procedure No. 8.M.2-2 10.11.1) require that the test be performed as written without discrepancies, and is so indicated by Attachment A being completed with required signatures and initials, and second verification of system restoration.

OFFICIAL RECORD COPY CP PKG PILG EA 89 0007.0.0 08/18/89

3 Contrary to the above, on October 5,1988, although an apparent discrepancy existed when the system logic of the RCIC system was performed in accordance with Procedure 8.M.2-2.10.11.1, the test was accepted without noting the apparent procedural discrepancy.

Specifically, the procedure contained an erroneous breaker identi-fica. tion for the RCIC pump discharge downstream injection valve; however, test personnel tagged the correct breaker without noting the discrepancy or pursuing a procedure change.

These violations are classified in the aggregate as a Severity Level III problem (Supplement 1).

Civil Penalty - $25,000 Pursuant to the provisions of 10 CFR 2.201, Boston Edison 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) admis-sion or denial of the alleged violation, (2) the reasons for the violation if 4 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) the date when full compliance will be achieved. 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 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 under 10 CFR 2.201, the Licensee may pay the civil penalty by letter to the Director, Office of 1 Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, or money order payable to the Treasurer of the United States in the amount of the civil penalty proposed above, 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 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 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 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 OFFICIAL RECORD COPY Cp PKG PILG EA 89 0008.0.0 08/18/89

4 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 provision 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.

The responses to 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, Region I, U.S. Nuclear Regulatory Commission, 475 Allendale Road, King of Prussia, Pennsylvania 19406, and a copy to the NRC Senior Resident Inspector, Pilgrim Nuclear Power Station.

FOR THE NUCLEAR REGULATORY COMMISSION Original Signed By PIILI.IAJ T. RUSS:LL William T. Russell Regional Administrator Dated at King of Prussia, Pennsylvania this A3tay of August 1989 0FFICIAL RECORD COPY CP PKG PILG EA 89 0009.0.0 08/18/89 i

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