ML20212N578
| ML20212N578 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/27/1986 |
| From: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | LOUISIANA POWER & LIGHT CO. |
| Shared Package | |
| ML20212N576 | List: |
| References | |
| EA-86-050, EA-86-50, NUDOCS 8608280289 | |
| Download: ML20212N578 (7) | |
Text
.
s .
. e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
LOUISIANA POWER & LIGHT COMPANY Docket No. 50-382 Waterford Steam Electric Station ) License No. NPF-38 Unit 3 ) EA 86-50 ORDER IMPOSING CIVIL MONETARY PENALTY I
Louisiana Power & Light Company (the licensee) is the holder of Operating License No. NPF-38 (the license) issued by the Nuclear Regulatory Commission (the NRC or i
the Commission). The license authorizes the licensee to operate the Waterford Steam Electric Station, Unit 3 in accordance with the conditions specified therein.
II A safety inspection of the licensee's activities under its license was conducted from January ,1-31,1986. The' results of this inspection indicated that the licens2e had not conducted its activities in' full compliance with the Technical Specifications in its license. The results of this inspection were discussed with licensee representatives during an enforcement conference on March 5, 1986.
A written Notice of Violation and Proposed Imposition of Civil Penalty (N0V) was subsequently served upon the licensee by letter dated April 16, 1986. This NOV stated the nature of the violations, the license conditions that were violated, and the amount of civil penalty proposed for one of the violations. An answer dated May 16, 1986 to the Notice of Violation and Proposed Imposition of Civil Penalty I
was received from the licensee. - -
l I
,v .
86082.80289 860827 ,
i ?
2-III Upon censideration of the licensee's response and the statements of fact, explanation, and arguments for mitigation of the proposed civil penalty or reclassification of the severity level of Violation I contained therein, as set forth in the Appendix to this Order, the Director, Office of Inspection and Enforcement, has determined that the violation occurred as stated and the penalty proposed for the violation designated in the Notice of Violation and Proposed Impositior, of Civil Penalty should be imposed.
IV In view of the foregoing and pursuant to Section 234 of Ehe Atomic Energy Act of 1954, as amended (42 U.S.C. 2282, PL 96-295), and 10 CFR 2.205, IT IS HEREBY ORDERED THAT:
The licensee pay the civil penalty in the amount of Fifty Thousand Dollars
($50,000) within thirty days of ttd date of this Order, by check, draft, or money order payable to the Treasurer of the United States and mailed to the Director, Office of Inspection and Enforcement, U. S. Nuclear Regulatory Commission, Washington, D.C. 20555.
d
..n
e Q o
V The licensee may, within 30 days of the date of this Order, request a hearing.
A request for hearing shall be addressed to the Director, Office of Inspection and Enforcement, U. S. Nuclear Regulatory Commission, Washington, D.C., 20555.
A copy of the hearing request also shall be sent to the Assist:nt General Counsel for Enforcement, at the same adaress. If a hearing is requested, the Commission will issue an Order designating the time and place of hearing. Upon failure of the licensee to request a hearing within thirty days of the date of this Order, the provisions of this Order shall be effective without further proceedings. If payment has not been made by that time, the matter may be referred to the Attorney General for collection.
In the event the licensee reouests a hearing as provided cbove, the issues to be considered at such hearing shall be:
(a) whether the licensee violated NRC requirements set forth in the Notice of Violation and Proposed Imposition of Civil Penalty, and (b) whether, or. the basis of such violation, this Order should be sustained.
I FOR THE NUCLEAR REGULATORY COMMISSION
/_
Ja s M. Taylo Director fice of Inspection and Enforcement Dated at Bethesda, Maryland the)'[2' day of August,1986.
e ,
APPENDIX On April 6,1986, a Notice of Violation and Proposed Imposition of Civil Penalty (N0V) was issued for violations identified during a routine NRC safety inspection. Louisiana Power and Light responded to the NOV on May 16, 1986.
Only Violation I in the NOV was assessed a civil penalty and, accordingly, was reconsidered in response to the licensee's requests for reclassification of the violation to Severity Level IV and for mitigation of civil penalt" The NRC's evaluation and conclusion regarding the licensee's requests are as follows:
Restatement of Violation Technical Specification (TS) 3.6.2.1 requires that two independec.t containment spray systems be OPERABLE with each. spray system capable of taking suction from the RWSP on a containment spray actuation signal and automatically transferring suction to the safety injection system sump on a recirculation actuation signal. This applies to MODES 1, 2, 3, and 4.
TS 3.0.4 requires that entry into an OPERATIONAL MODE or other specified condition shall not be made unless the conditions of the limiting condition for operaticn are met without reliance on provisions contained in the ACTION requirements.
Contrary to the above, on December 16, 1985, the plant entered Mode 3 while relying on the ACTION requirements of TS 3.6.2.1 in that Train B of the Containment Spray system was inoperable due to a closed discharge header valve (CS-1118). .,
This is Severity Level III violation (Supplement I). .
(Civil Penalty - $50,000)
Summary of Licensee's Response The licensee admits the violation but requests reduction in its severity level.
The licensee believes that the characteristics of a Severity Level III violation as described in 10 CFR Part 2, Appendix C, Supplement I are more severe than ,
those of the subject violation. The licensee points out that while no specific example in Supplement I deals with a violation of TS 3.0.4, it should be noted that TS 3.6.2 allows a single Containment Spray System (CSS) train to be inoperable for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and that prompt action on the part of the licensee personnel restored operability of CSS Train B in approximately 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />. In addition, similar Severity Level III examples in Supplement I involve a safety system not being able to perform its safety function. The redundant CSS train in this case was available to perform its intended safety function throughout the time in question. Thus, the licensee believes the violation should be classified at a Severity Level IV since it is more similar to the Severity Level IV examples given in 10 CFR Part 2, Appendix C, Supplement I.
The licensee also requests mitigation of the proposed civil per. city based on prompt identification and reporting, and its corrective action to prevent recurrence. The licensee feels it identified the problem with the closed valve (CS-1118) which made Train B of the CSS inoperable some 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> after 6
Appendix the action statement of TS 3.6.2.1 was entered. The TS action statement can be relied on for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if no mode change is made. The licensee feels that the operations staff, considering the level of plant activity, performed quickly and professionall~y in identifying the problem of the disconnected reach rod to CS-1118 and su b equent reporting of the TS violation to the NRC. Furthermore, the licensee indicates that a detailed corrective action plan has been implemented as outlined in the Appendix to its letter of May 16, 1986. Corrective actions were implemented to prevent recurrence as well as longer term in-depth actions to assure that remote operators would be considered as essential components of plant equipment. The licensee states that "All corrective actions were implemented on its initiative, independent of NRC's inspection activities." These actions were prompt and effective in preventing recurrence of a similar situation.
Evaluation of Licensee's Response After a thorough review of the licensee's response and its request for reduction of the severity level of the violation, the NRC has determined that the classification at a Severity Level III is appropriate. The licensee argues that a safety system (all redundant trains) not being able to perform its safety function is a Severity Level III violation. The staff disagrees. Whcre this condition exists it may represent a Severity Level II violation (Supplement I, B.1). Inoperability of one train of a system may be a Severity Level III violation (Supplement I,C.2).
In this case, although only one train of the CSS was inoperable, a number of factors led to the inoperability of CSS Train B that indicate a significant lack of attention to detail and that a Severity Level III classification of the violation is warranted. Improper maintenance of plant equipment, inaccurate procedures, and a misleading annunciator window were causes of.the violation.
The Shift Supervisor made a decision to change modes in violation of Technical Specification requirements based on the assumption that there was only a valve electrical indication problem, yet he did not thoroughly investigate nor verify that assumption. As discussed in Inspection Report 50-382/86-02, it also appeared that,at the time of the valve lineup, licensee personnel other than those performing the lineup knew valve reach rods were disconnected yet no corrective action had been initiated. These factors reflected significant weaknesses in the operation of the Waterford facility that are cause for significant concern and that resulted in the inoperability of CSS Train B for 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />. Therefore, a reduction in the Severity Level of the violation is not appropriate.
In evaluating the licensee's request for mitigation, the NRC considered the factors addressed in the licensee's response, and in each' instance, found that mitigation was not appropriate. Although the NRC staff recognizes that the licensee reported the event, implicit in prompt reporting is the necessity to provide an accurate report of the event. In this case, the report of the event did not address the fact that valve CS-117B was found to have a disconnected reach rod, that an annunciator window had been poorly labeled, and that an annunciator response procedure had been mislabeled. It is also misleading in that it referred to the white annunciator window as an " annunciator green light."
Because of these errors and omissions in reporting, mitigation on the basis of prompt identification and reporting is not considered appropriate.
d.
e e
Appendix The NRC staff also recognizes that prompt short-term corrective actions were taken. However, the actions taken by the licensee would normally be expected in response to such cn event. Furthermore, the NRC staff believes that not all corrective actions were taken independent of NRC inspection activities. NRC inspectors identified deficiencies in the reporting of the event and some of the corrective actions were subsequently generated as a result of the NRC inspectors' questions in this area. The inspectors were concerned that the licensee's corrective actions failed to address timely response to actuated annunciators per approved procedures, to address proper and timely identification of out-of-service plant equipment including disconnected reach rods, and whether other annunciators were also ambiguous. The NRC expects licensees to vigorously pursue root causes of abnormal plant conditions so that prompt and effective corrective actions can be taken. The licensee failed to identify the root causes of the event and provide comprehensive corrective actions to preclude recurrence.
Therefore, an adequate basis has not'been provided for mitigating the civil penalty.
NRC Conclusion Neither an adequate basis for a reduction of the severity level of Violation I nor for mitigation of the civil penalty associated with Violation I was provided by the licensee. Consequently, the proposed civil penalty in the amount of
$50,000 should be imposed.
e e
J
. , ,- I , m -. - - ,
AUG I 7 798S Louisiana Power & Light Company DISTRIBUTION bec w/ encl:
PDR SECY CA JMTaylor, IE RStarostecki, IE JAxelrad, IE' JLieberman, OGC HRDenton, NRR JSniezek, DED/ROGR Enforcement Officers RI, RII, RIII, RV G. Johnson, RM JPartlow, IE FIngram, PA -
JCrooks, AE0D BHayes 01 SConnelly, 01A DNussbaumer, OSP IE:ES File IE:EA File DCS RIV Distribution:
Regional Administrator, RMartin Division Director Branch Chief (RPB)
Section Chief (RPSC)
DPowers HBundy Resident Inspector CWisner(1trhd)
RDoda RIV Files 44 _
IE:ES OGC 5.6 RIVOdume ES:D2 bg IES y ABeac lJLieberman i RMartin iJAxelrad RSt ostecki y'or 8/20/86 ap/18/86 8//2 /86 /g/86 8/2 186 /2f/86
.