IR 07100120/2012018

Discusses Insp on 871120-1218 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty.Insp Included Review of Failure to Place Inoperable Steam Flow Channels in Trip and Perform Adequate post-maint Testing

ML20151B835
Person / Time
Site:	North Anna, 07100120
Issue date:	03/08/1988
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
Shared Package
ML20151B839	List: IR 07100120/2012018 ML20151B845
References
EA-87-246, NUDOCS 8804110298
Download: ML20151B835 (4)

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MAR 081988 Docket Nos. 50-338, 50-339 License Nos. NPF-4, NPF-7 EA 87-246 Vjrginia Electric and Power Company MTTN: Mr. W. L. Stewart, Vice President, Nuclear Operations Post Office Box 26666 Richmond, Virginia 23261 Gentlemen:

SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT NOS. 50-338/87-38 AND 50-339/87-38)

This refers to the Nuclear Regulatory Commission (NRC) inspection conducted by J. Caldwell at North Anna power Station, Unit 2, on November 20 through December 18, 1987. The inspection included a review of the circumstances surrounding the failure to place inoperable steam flow channels in trip an perform adequate post maintenance testin The report documenting this inspec-tion was sent to you by letter dated January 15, 1988. As a result of this inspection, significant failures to comply with NRC regulatory requirements were identified, and accordingly, NRC concerns relative to the inapection findings were discussed in an Enforcement Conference held on January 21, 198 The letter summarizing this Conference was sent to you on February 16, 198 The violation described in Section I of the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) involved a failure to place inoperable steam flow channels in trip as required by Technical Specifications (TS). On November 4, 1987, Unit 2 was operated from Mode 3 through Mode 1 up to 25 percent power with an inoperable steam flow channel in both the "A" and

"B" steam flow lines. This resulted in the unit operating at low power with inoperable steam flow channels that caused a loss of diversity and redundancy

'of signals to the Reactor Trip System and Engineered Safety Features Actuation System. A major concern resulting from this violation is that the operations staff knew that the steam flow channels were not responding properly for approx-imately 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> before actually declaring them inoperable. Furthermore, during that period, the operations staff discussed the matter with licensee management, yet the channels were not declared inoperable and appropriate TS actions were not taken until four hours after the unit was placed on line and at power levels greater than 25 percent. Although the specific cause of this violation was personnel error in that untimely operator action resulted in the violation of TS action requirements, a broader issue is the management tolerance that permitted the operators to "live with" indication problems at low steam flow. Your recognition that there is an "operational problem" with management tolerance of nonconforming conditions, which was addressed by your staff during the Enforcement Conference, is important to the process of correcting the mis-perception of operational standards and ensuring operability decisions are accurate and promp C004110298 880308 gg PDR ADOCK 05000338 G DCD f,'

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VirgilliaElectricand -2- MAR 08 W Power Company The violation described in Section II.A of the enclosed Notice involved the failure to perform adequate post maintenance testing on a steam flow channel instrumen In this particular case, the leads to the instrument were reversed during maintenance and the problem was not discovered until power operations were resumed. Compounding this problem was the lack of documenta-tion for post-maintenance testing and verification of testing completio The violation in Section II.B of the enclosed Notice involved the failure to provide an adequate Licensee Event Report (LER) in that LER 87-015 did not contain available pertinent information regarding the testing and status of the inoperable flow instrumen Previous concerns related to problems that your operating staff has encountered during other plant startups and outages are documented in Inspection Reports 50-338, 339/87-19 and 87-36, dated September 10, 1987 and January 4, 1988, respectively. During the inspection documented in Inspection Report 50-338, 339/87-19 (June 17 - August 18, 1987), several problems related to the Unit I refueling outage and restart were identifie Similar proble.ms were also experienced during the Unit 2 refueling outage and restart and were documented in Inspection Report 50-338, 339/87-36. These problems shared a common threcd of inadequate procedures and/or failure to follow procedure Even though you had a system of identifying problems and mistakes, there needs to be increased management emphasis on promptly establishing and promptly implementing correct-ive actions. Our concern about the promptness of corrective action was amplified at the Enforcement Conference when your staff explained that the corrective action for the inoperable steam flow channels had not been fully implemente The operating staff did not follow standard instructions with regard to declar-ing the steam flow channels inoperable and that improper intern"etation of standards raises a concern about making timely operability decisions when nonconforming conditions occur. Your recognition of this develop 1ng i;;ue is noted; however, prompt action is required to ensure that timely decisions ce made concerning operability and that corrective actions for identified prob', ems are implemented in a timely manne To emphasize the importance of timely operability decisions and properl/

interpreting operations standards, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Regional Operations, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amoun- of One Hundred Thousand Dollars ($100,000) for the violations described in Section I of the erclosed Notic In accordance with the "General Statement of Policy and Procedure for NRC Entorce-ment Actions," 10 CFR Part 2, Appendix C (1987) (Enforcement Policy), the violation in Section I of the enclosed Notice has been categorized as a Severity Level III violation. The base civil penalty amount for a Severity Level III violation is $50,000. The escalation and mitigation factors in the Enforcement Policy were consicbred, and the base civil penalty amount has been increased bj 100 percent for the following reasons: First, prompt and adequate corrective actions were not taken, in that, your operations staff was aware that the steam

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Virginia Electric and -3- kOAR 0 81988 Power Company flow channels were not responding properly for about ten hours before they were declared inoperable. Second, your past performance during other than normal operations such as outages and startups has been less than satisfactory, in that, similar problems have occurred in the pas You are required to respond to this letter and the enclosed Notice and should

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follow the instructions specified therein when preparing your response. In your response, you should document the specific actions taken and any addi-tional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirement In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Room.

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The responses directed by this letter and its enclosure are not subject to the clearance procedures of the Office of Management and Budget as required by '.he Paperwork Reduction Act of 1980, Pub. L. No. 96-51 Should you have any questions concerning this letter, please contact u

Sincerely, ORIGMAL SIGNED BY J. MIL 90N GRACE J. Nelson Grace Regional Administrator

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Enclosure:

Notice of Violation and Proposed l

Imposition of Civil Penalty cc w/ enc 1:

4EI W. Harrell, Station Manager

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N. E. Hardwick, Manager - Nuclear Programs and Licensing i

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Virginia Electric and Power Company - 3 - MAR 0 8 G88

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