ML20059M634
| ML20059M634 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 11/12/1993 |
| From: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| NSD931162, NUDOCS 9311190201 | |
| Download: ML20059M634 (18) | |
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bh COOPER NL, CLEAR STATION J$$y'SD9fifs1) Nebraska Public Power District
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E November 12, 1993 Director, Office of Enforcement U.
S.
Nuclear Regulatory Commission Attna Document Control Desk
-Wushington, DC 20555 centlemens
Subject:
Reply To a Notice of Violation References Letter from J. L. Milhoan (NRC) to G. R. Horn (NPPD) dated October 12, 1993, " Notice of Violation and Proposed Imposition of Civil Penalties - $200,000 (NRC Inspection Report No. 50-298/93-17)"
This letter, including Attachments 1 and 2, constitutes Nebraska Public Power District's (District). reply ~to the referenced Notice of Violation - (NOV) and Proposed Imposition of Civil Penalties in accordance with 10 CFR. 2. 2 01. is a certified check in the amount of $200,000, for paymentr of the Civil Penalties.
Although Attachment 1 includes discussions on specific.causes of each violation and identifies corrective actions completed or in progress, it is important that' the District address other broader issues that were not cited.as a violation.
As reflected by our broad and comprehensive corrective actions, the District takes very seriously, the collective effects of underlying deficiencies that ' led -
to the - violations.
Management ' has. responded not ' only to the.NRC's message represented by the NOV, but also has responded to its awakening L that ~ some -
processes, attitudes, and hardware were not working as well as: believed.
Event investigations necessitated District management's reevaluation. ofJ perceptions, expectations, and performance. It became apparent'that changes'in management and employee attitudes and organizational. cu.'.ture were necessary.
Accordingly, as expressed during the August.13,'1993, En.!oicement Conference, management has taken unprecedented action to return the,overall effectiveness of our operations, and particularly the Corrective Action Program (CAP),' to a level-that satisfies the expectations of both the District and the: Nuclear Regulatory -
Commission.
In the last year, District management directed ' the ' performance' of. severali assessments and/or investigations of the District's corrective Action Program.
The resulting conclusions and recommendations were generally consistent.. The-reports of these assessments identified a number of underlying root causes and:
. highlighted areas = of significant' management concern regarding the District's nuclear operation. These reports were also consistent with the most recent'NRC SALP. Report. An analysis of the reports concluded that the concerns were focused in five broad categories:
Corrective Action Program Communications e
Organizational' Effectiveness e
Trending and Feedback e
Accountability e
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Director, Offica of Enforcement U.S. Nuclser Ragulatory Commission Novemb.er 12, 1993 Page 2 of 4 As an interim measure, CNS management assembled a Corrective Action Program
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Oversight Group (CAPOG) to supplement corrective action efforts until procedure and program changes were fully implemented..This group will remain in effect until the new Safety Assessment Organization is in place and working sufficiently to allow transfer of this responsibility.
As a long-term meas,re, management developed and issued the Nuclear Power Group Strategic Plan For Performance Improvement (SPPI).
le SPPI provides a plan and schedule for improving performance by addressing the recommendations of the reports, including the most recent SAr.P Report, in an integrated fashion. The activities identified in the SPPI are *Jcheduled to be completed by the end of 1994 with certain key activities 2
such as implementation of a new CAP, being completed by the early part of 1994.
As a final step in assessing the overall causes of the underlying issues noted
- above, District management directed the performance of a comprehensive Organizational and Programmatic Assessment of Cooper Nuclear Station.
The I
technique utilized for this assessment entailed the review of pertinent docomentation which reflects the station's recent performance (e.g., prevAous two SALT Reports, most recent INPO Evaluation, recent Notice of Violations, recent j
Licensee Event Reports, and recent assessments), analysis of the resulting data to determine potential " common causes", and a validation of the data through personnel interviews. The results of this analysis verified ongoing improvement plans and also identified the need for a higher tier document to provide an overall recovery plan that will ensure continuous improvement. As a result, a business plan is currently being developed and the draf t plan is scheduled to be sent to Senior Management for review and comment by November 12, 1993.
i 1
Implementation of the activities contained in the SPPI and the business plan will result in fundamental improvements in the attitudes, culture and levels of l
performance of the District's Nuclear Power Group.
These actions address, in l
full, the causes identified by the District at the August 13, 1993 Enforcement Conference, as contributing to the violations identified in the ' reference, namely, there was a willingness to correct deficiencies.without documenting them in the corrective action program, a rigid corrective action program that made its use undesirable, a lack of problem ownership, a perception that the corrective action program was. an NRC program as opposed to a program that provided benefits to NPPD, a perception that corrective action documents were negative performance indicators, a perception that managers responded negatively to problems, and a t
(
l ek of personal accountability.
The District recognizes, as stated in the Reference, that correcting the fundamental weaknesses that led to the numerous examples of violaulons given in the Inspection Report will demand a substantial effort from all District NPG employees over a long period of time.
We recognize that this is one of the greatest challenges to face us in the history of Cooper Nuclear Station, but I want to assure you that the District will commit the resources and the energy to
.successfully accomplish this opportunity before us.
We will continue to.
periodically brief members of the staff on our progress in achieving this obje tive.
Sho d y u have any questions concerning this matter, please contact my office.
Cm.~--
G.
Horn V
President - Nuclear
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Dircctor,.Offica of Enforcament U.S.
Nuclear Regulatory Commission November 12, 1993 Page 3 of 4
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Regional Administrator NRC Region IV NRC Resident Inspector Cooper Nuclear Station i
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Director,..Offics of Enforcim2nt U.S. Nuclear Regulatory Commission November 12, 1993-Page 4 of 4 STATE OF NEBRASKA)
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Horn, being first duly sworn, deposes and says that he is an authorized.
representative of the Nebraska Public Power District, a public corporation and political subdivision of the State of Nebraska; that he is duly authorized to submit t a response on behalf of Nebraska Public Power District; and that'the stateme a containe~ herein are true to the best of his knowledge and belief.
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Horn N
N Subscribed in my presence and sworn to before me this day of AK)t/FM SF FL 1993.
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- Attechment 1 to NSD931162 Page 1 of 14 REPLY TO OCTOBER 12, 1993 NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES EA 93-137 COOPER NUCLEAR STATION NRC DOCKET NO..50-298, LICENSE DPR-46 During an NRC inspection conducted March 29 through April 2 and May 3-7,
- 1993, violations of NRC requirements were identified. In accordance with the " General-Statement of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the Nuclear Regulatory Commission proposes to impose civil penalties 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 the Nebraska Public Power District's (District) responses are set forth below I.
VIOLATIONS ASSESSED CIVIL PENALTIES The following four violations were cited against 10 CFR 50 Appendix B,
Criterion XVI, and collectively represent a Severity Level III problem (Supplement I).
Civil Penalty - S75,000 Appendix B to 10 CFR Part 50, Criterion XVI requires that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
VIOLATION I.A.1 contrary to the above, on March 12, 1993, the secondary containment was declared operable without promptly identifying and correcting a significant condition adverse to quality which contributed to the secondary containment failure to meet its integrity-test on March 8, 1993.
It was subsequently identified that a loop seal had not been established in a pipe from the reactor building to the radwaste building because of a construction deficiency.
This condition created a direct. leakage' path between the reactor and radwaste buildings.
(01013)-
ADMISSION OF VIOLATION The District admits the violation.
REASON FOR VIOLATION When the Secondary Containment Test failed on March 8th, a Nonconformance Report (NCR) should have been written.
The failure to write an NCR was a result of the test failure not being recognized as a nonconforming condition, since the secondary containment was not required to be operable at the time, the complex nature of the criteria set out in the implementing procedures for the Corrective Action Program (CAP),
and historical acceptance of corrective action proceedir.g in conjunction with trouble-shooting efforts utilizing the Work Item process. It was not recognized as necessary to thoroughly analyze the causes of leakage during secondary containment troubleshooting efforts since such failures were expected due to normal degradation of leakage paths (e.g.
door and loop seale).
Similarly, when the apparent. interconnection between the' Reactor Building and the Radwaste Building was identified on March 11, 1993 the District failed to write an NCR.
Attcchment l' to.NSD931162 Page 2 of 14
.i This lack of a timely response to the anomaly resulted from:-
1)
Shortcomings in the Secondary Containment Testing procedures due to not specifying the proper initial conditions with adjacent building H&V Systems, and 2)
An inadequate definition of design basis requirements for secondary containment in that testing was not always performed for the most limiting conditions per the design basis.
Later, clarification was given that the secondary containment integrity must be met for a Loss Of Offsite Power (LOOP) scenario and surveillance testing conducted accordingly. Since normal ventilation fans in adjacent buildings are electrically powered from sources that would be lost in a LOOP, the Secondary containment Integrity Test would have to be run assuming the loss of those fans as the most limiting condition.
CORRECTIVE STEPS TAKFN AND THE RESULTS ACHIEVED The loop seal was installed in the pipe from the Reactor Building to the Radwaste Building.
Subsequently, on April 7,
1993 a test of Secondary i
containment was performed with the Radwaste Building differential pressure (dp) reduced to -0.05 inches wg and control and Turbine Building ventilation systems of f or at minimum dp.
The flow through the missing loop seal was estimated at 150 cfm. With this leakage f actored in, the DL P-ict concluded in hindsight, that the test on March 11 did, in fact, ve fy operability of Secondary Containment.
Subsequent investigation of maintenance performed on secondary containment between March 11 and April
.7, did not reveal any notable activities which would reverse this conclusion.
A procedurc change was initiated and approved on April 14, 1993 for procedure 6.3.10.8 to minimize the effects of adjacent / adjoining H&V Systems on secondary containment leak rate testing.
In addition, changes were approved for Procedures 0.26 and 6.3.10.17 to. clarify expectations of the Surveillance Program and to increase the preventive maintenance frequency of Secondary Containment penetrations to monthly.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Long term corrective actions include clarifying the transient' and accident assumptions and methods in the Updated Safety Analysis Report, Chapter 14, to clearly define the basis for the system and, subsequently, to evaluate the adequacy and effectiveness of the surveillance procedures.
' Improvements in the Corrective Action Program are being implemented. to -
l ensure the timely identification and documentation of equipment anomalies.
As an interim measure, the Corrective Action Program is being overviewed to ensure management expectations in this area are being met.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The District is currently in full compliance.
VIOLATION I.A.2 contrary to the above, on November 16, 1992, the licensee did not promptly j
identify and correct emergency diesel generator Fuel Oil Tanks A and'B particulate concentrations which exceeded the limit established in Station i
t
.i' to NSD931162 Page 3 of_14 Procedure 6.3.12.3, Revision 13, " Diesel Fuel Oil Quality Test."- Measures to correct-the high particulate concentrations were not implemented until after April 2,'1993.
The emergency Diesel generators were required to be operable..f rom November 16, 1992, until - the plant was shut down for a refueling outage on March 6, 1993.
(01023)-
ADMISSION OF VIOLATION The District admits the violation.
REASON FOR VIOLATION On August 13, 1992, the Revision 13 of Surveillance Procedure 6.3.12.3 was approved which added determination of particulate concentration to diesel generator fuel oil quality testing. The particulate concentration limit was established at 10 mg/L. However, no guidance was provided in the procedure regarding the basis for the limit or what actions to take if the limit was.
- j exceeded.
The root cause of this violation was personnel error in that a deficiency report was not generated when required prior to proceeding to determine the significance of the anomaly and inadequate documentation of the evaluation.
j performed to justify the District's position.. A contributing cause was the inadequate procedure.
. j CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED
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~
As discussed in the April 29, 1993 letter, G. R. Horn:to_J.'L. M11hoan, the.
District retained the services of a fuel oil expert to review and enhance; our maintenance program to further assure continued diesel generator fuel.
oil quality. Addition'al filtering of the fuel oil' system was performed to.
- i reduce the level of particulate to within acceptable limits. The affected-procedure, 6.3.12.3 was revised-to clarify the_ potential impact of diesel.
?
fuel oli particulate.
A License Amendment request was forwarded to the NRC-on June 23,f1993;to j
incorporate Standard Technical-Specification limits ' for fuel oil quality verification, including particulate concentration and water into the:CNS Technical Specifications, per correspondence NSD920537.. This request was approved by the NRC on July 16, 1993 as CNS License Amendment.No. 165, CORRECTIVE STEPS THAT WILL BE TAKEN'TO AVOID'FURTHER VIOLATIONS The f ailure to enter the CAP is being addressed in the. revamping of the CAP and in management meetings with perr.onnerl regarding expectations--in the implementation of the CAP.:
i DATE WHEN l'ULL C'HiELIANCE WILL BE ACHIEVED
- The District is currently.In full compliance.
VIOLATION I.A.3 Contrary to the above,.on'May 1, 1992, after. identifying primary system p-
- leakage past the inboard and outboard shutdown cooling' suction isolation l
I.
Valves RHR-MO-18 and
-17, the ' licensee did not ' establish measures ' to
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promptly correct-the condit.L'on.. On March 29, 1993, the licensee identiflad
- i that' a significant condition adverse to. qualityf existed in ; that Valve i
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4" to NSD931162 Page 4 of 14 RH-MO-18 f ailed the 10 CFR Part 50, Appendix J local leak rate test. It was found that five cracks existed in the valve seat and disc.
(01033)
ADMISSION OF VIOLATION The District admits the violation.
REASON FOR VIOLATION 3
A significant portion of the rationale for the decision not to repair the af fected valves prior to the 1993 outage was not documented. The rationale included the fact that leakage rate determinations were periodically performed to ensure that the valve condition was not degrading.
In addition, Standard Technical Specification Pressure Isolation Valve (PIV) leakage limits were used, in part, as the basis for the acceptance of the observed reactor coolant pressure boundary leakage.
Initially, the District concluded that the root cause of this violation was the failure to initiate a corrective action document which resulted in no clear, documented justification for the decisions to repair or not repair the valves in question.
After further review of the NCR procedure,-the District now concludes that the NCR process, as then implemented, did not have the appropriate thresholds and therefore, inadequate procedural guidance may have precluded utilization of the CAP.
Therefore, inappropriate thresholds in the CAP is at least a contributing root cause of this violation.
i CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED Valves RHR-MOV-MOl7 and MOl8 were repaired during the 1993 Refueling Outage.
Successful Local Leak Rate Testing and PIV Testing was then performed in the accident direction for these valves.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Long term corrective actions include the development of a formal PIV testing program, and implementation of improvements to the CAP discussed above to better ensure that deficiencies of this type are identified and entered into -
the CAP, and communication of management expectations to Nuclear Power Group personnel'.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The District is currently in full compliance.
VIOLATION I.A 4 Contrary to the above, on March 30, 1993, it was determined that the-licensee had not promptly identified and corrected a significant condition adverse to quality for paint blistering in the. Emergency Condensate Storage Tanks A and B.
An inspection of Tanka A and B, as authorized by Maintenance Work Request 93-1271, had identified. blistering ' of - the tank - interior coating;'however, the results of the inspection.were not documented in the maintenance work request. and no other corrective action measure was initiated to evaluate and correct this condition.
(01043)
- sv i
to NSD931162 Page 5 of-14 ADMISSION OF VIOLATION The District admits the violation.
REASON FOR VIOLATION Following the observation of the blistered coating on the walls of the Emergency Condensate Storage Tanks (ECST), the chemistry Technicians inspecting the tank, failed to properly document the results on the Maintenance Work Request (MWR) and in the Corrective Action Program via a Deficiency Report (DR).
The inspection of the tanks was intended to be a chemistry responsiollity.
However, after the discovery of blistering, responsibility for evaluating the condition of the tank coatings should have been referred ~to Engineering for evaluation, via a DR.
The root cause in this case was personnel error by the technicians since it was evident-they were aware of the problems, as noted in their hand-written report describing the blistering. The District is further concerned that perceived schedular pressure on the individuals to refill the tanks and restore them to service -
apparently influenced the technician's decisions.
CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED On April 2,
1993, after NRC questioning, the hand written note from the Technician to the Chemiet was formally typed. On April 8, 1993, an expert coating consultant inspected the tanks and provided a report. recommending a course of action.
Deficiency Report 93-159 was written on April 26, 1993, to document the examination of the tanks.
An Operability Evaluation determined that the condition and expected degradation.of the tanks allowed operation for one additional operating cycle before reccating ' work would be necessary.
Subsequently, the District plans to recoat the ECSTs during the. next scheduled refueling outage.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Long term corrective actions include improvements to the Corrective Action Program to better ensure that potential lower threshold deficiencies are adequately addressed and communication of management's expectations to Nuclear Power Group personnel.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The District is currently in full compliance.
VIOLATION I.B Technical Specification Table 3.2.H states that the primary containment Hydrogen Concentration Analyzers PC-AN-H:/02 -I and -II are required to be operable at all times except when the reactor is in cold shutdown or in the REFUEL mode during a refueling outage.
Contrary to the above, from April 1990 until March 6,1993, with the reactor not in cold shutdown or REFUEL mode during a refueling' outage (at various-times), primary containment Hydrogen Concentration Analyzers PC-AN-H /0
-I 2 2 and -II were not operable. Specifically, it was identified that the inline sample line filter canisters'and the sample line slopes resulted in the
1*
Attcchment 1-
+
.4 to NSD931162
' J Page 6 of 14 accumulation of moisture, which resulted in erratic readings and unreliable analyzer operation.
(01053)
This is a Severity Level III violation (Supplement I).
Civil Penalty - $75,000 ADMISSION OF VIOLATION The District admits the violation.
REASON FOR VIOLATION Although the H /02 analyzers were recognized to be unreliable, as evidenced 2
by the determination to modify them, it was determined that periodic maintenance could be used as an interim corrective measure.
However, the interim corrective action failed to address the need for continuous operability of the analyzers under post-accident conditions. The root cause for the failure to evaluate the condition was that the corrective action process in place at that time would not have accommodated or demanded entry into the CAP.
CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED Following the NRC's ~ March 1993 inspection, and as discussed in the District's letter to J.
L.
Milhoan dated June 7,
1993, the District initiated an historical operability evaluation of the hydrogen / oxygen analyzers. The evaluation indicated that the analyzers were inoperable due to the moisture intrusion problem, which was exacerbated by the particulate filters.
This conclusion is based largely on the fact that the filters would not have been accessible for moisture removal in a post-LOCA environment.
Corrective actions included permanently removing the filters and re-sloping the lines as part of DC 90-320.
As committed to in'the District's letter to J.
L. Milhoan dated July 16, 1993, supplemental testing was developed to further enhance effectiveness.
Extensive post-modification, testing was conducted on the H /02 Analyzer system to verify that the previous problems 2
with moisture accumulation in the sample lines has been resolved.
To further ensure the. ef fectiveness of the system upgrade, an enhanced instrument surveillance program was implemented during the initial stages of power operation following the recent refueling outage.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Long term corrective action includes upgrading the Corrective Action Program as previously discussed.
The District will perform an evaluation to determine the need to perform a formal post design change effectiveness review process as an enhancement to
' the design change process.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The District is currently in full compliance.
i '.
Attechment 1 to NSD931162 Page 7 of 14 4
VIOLATION I.C 10 CFR 50.55a(g)(1) requires, in part, for boiling, water-cooled nuclear power facilities with construction permits issued prior to January 1,1971, that safety-related components that are not part of the reactor coolant pressure boundary meet the requirements of 10 CFR 50.55a(g)(4) and (5).
10CFR 50.55a(g)(4) requires, in part, that throughout the service life of a boiling, water-cooled nuclear power facility, components (including supports), which are classified as ASME Code Class 1, 2, and 3, must meet the requirements, except design and access provisions and preservice examination requirements, set forth in Section XI of the ASME Boiler and Pressure Vessel Code and Addenda.
10 CFR 50.55a(g)(5)(i) requires, in part, that the inservice inspection (ISI) program for a boiling, water-cooled nuclear power facility, must be revised by the licensee, as necessary, to meet the requirements of 10 CFR 50.55a(g)(4).
Contrary to the above, the licensee, which had received a construction permit prior to January 1,
1971, did not include the safety-related components of the service water and reactor equipment cooling cystems in the initial licensed ISI program and did not update the requirements relative to these systems to ASME Section XI equivalency. This condition had existed since initial plant operation in 1974.
Since February 12, 1976, when the revisions to 10 CFR 50.55a(g) went into ef fect, the licensee did not. include the essential portions of the service water and reactor equipment cooling systems in the ASME Section XI ISI Program.
(01063)
This is a severity Level III violation (Supplement I).
Civil Penalty - $50,000 ADMISSION OF VIOLATION The District admits the violation.
HEASON FOR VIOLATION The reason for this violation is that the District performed an inan9quate evaluation of the 10 CFR 50.55a regulation when it was promulgated in'1976.
As a result, the applicable portions of these systems were not incorpr> rated into the ISI program. While the District cannot fully establish the reason for this inadequate evaluation, it is believed that confusion nay have resulted from the pre-ASME classification categories of systems used at CNS since construction and in the conversion of these to the ASME classification categories given in the regulation. Subsequent discovery of this erroneous situation Nas hampered by numerous letters through the years between the District and the NRC on the ISI program methodology and contents. Based on the District's interpretation of this correspondence, it mistakenly believed that the NRC had concurred with the Service Water System classification.
CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED Through the years, the District has performed a number of inspections of the systems in question for various issues such as pipe supports and erosion / corrosion.
The NRC Staff acknowledged in Inspection' Report No. 50-298/93-17 dated June 17, 1993, that the District has conducted ~"a sufficient number of ultrasonic examinations for the purpose of monitoring
e-Attcchment 1 to NSD931162 Page 8 of 14 the structural integrity of the [ Service Water) system" and concludes that "the number of inspections performed provide [s] a reasonable assurance that the structural integrity of the service water system will be maintained during the next operating cycle." The Staf f states, however, that exclusion of the Service Water.(SW) and Reactor Equipment Cooling (REC)^ systems from the ISI program has allowed the systems to perform with temporary repairs and that hydrostatic pressure testing of the service water system to 110%
of design pressure has not been performed.
While agreeing that the systems should be included in the ISI program, the District disagrees with suggestions in IR 93-17 (at page 27) that the construction classification of the SW and REC systems was inappropriate or non-conservative.
This classification was specifically approved by the Atomic Energy Commission at the time of licensing (SER dated February 14, 1973, at Page 3-3) and as such remains part of the CNS licensing basis. The District does not believe adequate justification has been given to change that classification.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Long term corrective actions include the District's commitment to include safety related portions of the SW and REC systems in Section XI Test and Inspection programs.
The District has also committed to evaluate other safety related non-code class 1,
2, and 3 systems for potential reclassification regarding Section XI test and inspection.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The District will have included safety related portions of SW and REC in the ISI Program by the next refueling outage. The evaluation of other~ safety related non-code class 1, 2, and 3 systems will be completed by October 1994 and, if applicable, will also be included in the ISI Program prior to the next refueling outage.
i II. VIOLATIONS NOT ASSESSED A CIVIL PENALTY The following four violations were cited against 10 CFR 50 Appendix B,
Criterion V.
VIOLATION II.A.1 Appendix B to 10 CFR Part 50, criterion V, Instructions, Procedures, and Drawings, states that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to-the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the above, on April 10, 1993, craft personnel failed to-implement Step 5 of Maintenance Work Request (MWR) 93-3021 which required a system engineer to inspect the inside of the two No. 1 emergency diesel generator af tercoolers prior to cleaning. The craft personnel proceeded to clean the lef t aftercooler (Step 7) prior to the system engineer conducting the required inspection.
This is a Severity Level IV violation (Supplement I).
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~Attcchment 1 to NSD931162 Page 9 of 14 ADMISSION OF VIOLATION The District admits the violation.
BEASON FOR VIOLATION This violation resulted when personnel f ailed to follow the instructions on the MWR due to inadequate coordination between workers and supervision which resulted in proceeding with work out of sequence.
CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED The System Engineer was contacted and conducted the required inspections of the diesel generator in accordance with the MWR instructions. Meetings were held with mechanical maintenance workers to emphasize the importance in following specific instructions given in work documents.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Long _ term corrective action involves improving the enforcement of accountability, strensing of ownership and accountability by management, and communication.
To preclude recurrence, it is imperative that management clearly express and stress their expectations regarding procedure, adherence, and supervisory involvement at the job site.
These and other concerns will be further pursued as part of a scheduled organizational assessment of the CNS Maintenance. Department.
Following the organizational assessment and the implementation of any resulting changes, a Maintenance Department Self-Assessment will be conducted.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The District is currently in full compliance.
VIOLATION II.A.2 Contrary to the above, on March 6, 1993, a station operator failed to -
implement the requirement of Operating Procedure 2.2.18, Revision' 33, "4160V Auxiliary Power Distribution," Step 8.1.4 to rack out the Core Spray Pump A breaker. Instead, the station operator proceeded to rack out the breaker to a safety-related substation, by first tripping the breaker, and caussi a loss of shut-down cooling.
This is a Severity Level IV violation (Supplement I).
ADMISSION OF VIOLATION The District admits the violation.
REASON FOR VIOLATION The cause of this violation is personnel error - failure to implement self-checking.
~
Attcchment 1 to NSD931162 Page 10 of 14 CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED NCR 93-020 was initiated on March 6,
1993, to document this event.
LER 93-003 was subsequently written and forwarded to the NRC.
On March 11, 1993, a Corrective Action' Review Board (CARB) convened to evaluate this event.
Recommendations from CARB included (1) additional labeling of breakers and (2) enhance self-checking training. Corrective action included disciplinary action taken.for the operator.
CORRECTIVE STEPS TH,AT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Referring to corrective action specified above, human factors improvements have been completed regarding added labeling of the breakers, and self checking training has been enhanced by revision and administration of training lesson plans.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The District is currently in full compliance.
VIOLATION II.A.3 contrary to the above, on March 8,1993, two contract mechanical maintenance personnel entered the special work permit area surrounding the drywell without reading and signing the special work permit as required by Health Physics Procedure 9.1.1.4, Sections 8.4.3.1 and 8.4.3.5.
e This is a severity Level IV violation (Supplement IV).
ADMISSION OF VIOLATION The District admits the violation.
REASON FOR VIOLATION The root cause of the violation was personnel error. Training received by the contract workers adequately emphasized attention to postings, and signing special Work Permits as required. However, ; f actors contributing to the violation include the following:
The control point was not appropriately located to ensure closer direct line-of-sight ~ control of the step-of f pad by Health Physics (HP)
Technicians.
The workers were inappropriately advised and " guided" by a contract HP Technician.
5 The District mechanic, who was their supervisor, lost physical control of the workers who were. relatively inexperienced in CNS outage practices.
ROBBECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED O
Upon discovery of the condition, a Radiological Safety Incident Report (RSIR) was immediately initiated.
Corrective actions were taken to immediately remove the workers from the protected. area, to provide them remedial training, and to relocate the Drywell access ~ control table.
Corrective actions also included counseling of the District mechanic who was
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Attcchment 1 to NSD931162 Page 11 of 14 assigned to supervise the contract workers.
Control point personnel were.
also counseled regarding this violation.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS This event will be incorporated into Industry Events Training for Maintenance and HP personnel in order to prevent recurrence. A review will be performed to clarify the balance between HP control responsibilities and the training comprehension expectations for contract workers.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The District is currently in full compliance.
VIOLATION II.A.4 Contrary to the above, as of March 29, 1993, the licensee had not established appropriate quantitative acceptance criteria in Procedures 6.3.1.13, Revision 9,
" Division I
H /02 Analyzer Calibration and 2
Functional / Functional Test," and 6.3.1.14, _ Revision 10, " Division II H /0 2 2 Analyzer Calibration and Functional / Functional Test," to verify operability of the hydrogen / oxygen analyzer heat tracing. The heat tracing is required to be operable to support operability of the hydrogen / oxygen analyzers as required by Technical Specification Table 3.2.H, POST-ACCIDENT MONITORING INSTRUMENTATION REQUIREMENTS.
This is a Severity Level IV violation (Supplement I).
ADMISSION OF VIOLATION The District admits the violation.
REASON FOR VIOLATION f
The District has concluded that measuring system temperature as prescribed in the affected procedures did not equate to a determination of operability of the heat trace.
The heat trace on the lines leading to the detection chambers (where temperature is sensed) operates at approximately llO*F. Air.
sample temperature at the detection chamber below 105'F would be indicative of heat trace failure.
However, the temperature of the air' entering the chamber is seasonally affected and at times may be high enough-(in' excess of 105'F) that-heat trace failure would not be detected by measuring temperature alone.
Therefore, the root cause of this violation is' an inadequate procedure in that it failed to recognize and account for environmental conditions that could mask heat trace failure.
CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED-The operability of the heat trace was verified through the use of a clamp-on ammeter. Procedures 6.3.1.13 and 6.3.1.14 were revised to include the use of a clamp-on ammeter to verify heat trace operability.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The procedure revisions specified above will prevent recurrence.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The District is currently in full compliance.
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Attcchment 1 to NSD931162 Page 12 of 14 VIOLATION II.B Appendix J to 10 CFR Part 50 Section III.C, states, in part, for valve local leak rate tests that the test pressure shall be applied'in the;same direction as that applied when the valve would be required to perform its safety function, unless it can be determined that the results from the tests for a pressure applied in a different direction will provide equivalent or more conservative results.
Contrary to the above, since initial plant operation in 1974, the licensee performed reverse direction testing of 26 containment isolation valves-without the local leak rate test results being equivalent or more conservative.
This is a Severity Level IV violation (Supplement I).
ADMISSION OF VIOLATION I
The District admits the violation.
REASON FOR VIOLATION NRC Inspection Report 77-06 was issued on May 24, 1977. This IR identified that CNS was not able to provide objective evidence that reverse direction testing of containment isolation valves was equivalent to or more conservative than accident direction testing.
This was carried as Unresolved Item 7706-2.
On March 10, 1980, NRC Inspection Report 80-1 was issued closing out Unresolved Item 7706-2 on the basis of action taken by.
CNS and NRC review. The action taken by CNS consisted of obtaining letters from the appropriate valve manufacturers that provided ' indication _ that reverse direction testing should be equivalent to, or more conservative-than, accident direction testing.
Notwithstanding the above, the District determined during the 1993 ' Refueling Outage that reverse (non-accident) direction testing for certain large valves did not always yield conservative results.
A total of 47 valves were identified which were being tested in the reverse direction. Of these, -
10 valves could not be demonstrated to produce equivalent or more conservative results when tested in the reverse direction.
The existing configuration for eight other valves allowed testing in the accident direction.
The root cause for this violation was the District's acceptance in this case, at face value and without further scrutiny, information on expected valve performance received from the valve vendors.
CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED The eight valves that were configured to allow testing in the accident direction were no tested prior to startup from the 1993 Refueling Outage.
Of the remaining 39 valves (out of the total of 47), 29 were determined to produce equivalent or more conservative results when tested in the reverse versus accident direction.
On June 7,
1993, the District submitted a request for schedular exemption to Appendix J testing for the remaining'10 valves. This exemption request was for one operating cycle. NRC approval of the exemption request was received on June 23, 1993.
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AttschmInt 1 to NSD931162 Page 13 of 14 CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS During the upcoming cycle, either evaluations will be performed to demonstrate the adequacy of testing in the reverse direction, o*
modifications will be implemented to allow leakage testing in the accleant direction.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The District is currently in full compliance.
VIOLATION II.C Technical Specification 4.7. A.2 requires integrated leak rate testing to verify primary containment integrity at 58 peig.
Contrary to the above, since installation of the hydrogen / oxygen analyzers in April 1988, the licensee had not tested the cabinet internals at 58 psig.
The cabinet internals constitute a primary containment boundary during a design basis event.
This is a Severity Level IV violation (supplement I).
ADMISSION OF VIOLATION The District admits the violation.
'l REASON FOR VIOLATION The root cause of this violation was the failure of the 3.4 Station Modification Series procedures to address Appendix J criteria.
CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED Satisf actory testing to full accident pressure of the H /Ch Analyzer system tubing within the instrument cabinets was completed' prior to startup from the refueling outage. All portions of the H /02 Analyzer piping that would 2
be subject to primary containment accident pressure have now been tested with satisf actory results achieved. The additional leakage measured for the piping within the H /02 instrument cabinets was factored into our previous 2
Integrated Leak Rate Test results and the total leakage rate remains well below allowable criteria.
Procedure 6.3.1.1.1 was written to ensure the system is leak tested to 58 l
psig whenever the pressure boundary is open.
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As stated in the District's letter to J.
L.
Milhoan dated June 7,
- 1993, other primary containment sample system configurations would be reviewed to ensure no other similar configurations existed. Per the District's July 16, 1993 letter, no similar concerns were identified as a result of this review.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS l
As stated in the District's letter to J. L. Milhoan dated June 22, 1993, a detailed review of all containment penetrations and their associated Appendix J testing requirements will be performed during the next operating l
cycle and necessary changes, if any, implemented prior to startup from the next refueling outage.
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' Attachment 1-to NSD931162-Page 14 of.14 Long term corrective action includes. revisions to the 3.4 Design Change Series' Procedures and formal training on Appendix J testing requirements.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The District is currently in full compliance.
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