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EA-98-221 - Peach Bottom 2 & 3 (PECO Nuclear)June 11, 1998
Dear Mr. Rainey: Based on the information developed during the inspections, and the information provided during the enforcement conference, two violations of NRC requirements are being cited and are described in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice). The first violation involves the failure to establish adequate instructions and procedures to prevent foreign material from entering the 3A core spray subsystem during a replacement modification of emergency core cooling system (ECCS) suction strainers in October 1997. Although the foreign materials exclusion (FME) plan developed for the modification provided FME controls for the material entering and leaving the torus, the plan did not provide similar controls for the suction strainers, resulting in foreign material, in the form of a rigging sling protector pad, being left in the 3A core spray subsystem after the modification. As a result, the second violation occurred involving the failure to maintain the 3A core spray subsystem operable in that during testing on March 22, 1998, the 3A core spray pump failed to meet discharge pressure and flow specifications. Following that test, further testing and evaluation of the pump was conducted and revealed fibrous material (from the rigging sling protector pad) wrapped around the impeller shaft and parts of the impeller vanes, as well as small bunches of this fibrous material in the piping between the suction valve and pump discharge check valve. The NRC is concerned that adequate controls were not in place to preclude foreign material from entering the Unit 3 CS and RHR systems during the replacement of the strainers. Although your staff, at the beginning of the outage, initially logged all material that was introduced into, and removed from the torus, this practice was discontinued near the end of the outage. At the time, approximately 4000 items had been logged into the torus while only approximately 2000 items had been logged out. In place of this FME control, you enhanced your originally planned torus catwalk walkdowns and dive swim through of the underwater torus portion. While these walkdowns were capable of detecting foreign material in the torus, they were not capable of detecting foreign material inside the piping with the suction strainers. However, your engineering personnel, during reviews of the FME plan and other evaluations, apparently did not recognize this inadequacy. In addition, the engineering oversight of the modification work activities was poor in that there was a lack of accountability for FME coordination, as well as a lack of formal observation of activities by personnel other than Quality Assurance personnel. The NRC is also concerned that even though your QA organization, while overseeing the outage, identified several deficiencies with your FME controls, your corrective actions at the time to address those deficiencies were narrowly focused on specific findings, and did not lead to earlier identification of the fibrous material in the system. For example, a QA Surveillance Report issued in August 1997, prior to the outage, indicated that no FME controls were defined in written instructions or practiced during mock-up training. Another QA Surveillance Report issued in October 1997 indicated that FME controls at the torus entrances needed to be strengthened. That same report documented several deficiencies, including difficulties with the system for accounting for items taken into the torus; omission of details in the required logs; inattentiveness by plant monitors to individuals going into the torus with material; and a lack of a copy of the FME administrative procedure at the control point. In addition, a QA Surveillance Report issued on December 22, 1997, indicated a breakdown of the FME controls during the suction strainer modification, noting that stringent FME controls in the torus were viewed as a challenge to the schedule rather than a necessary means of maintaining system cleanliness, and the contractor's acceptance of a final inspection in lieu of FME controls during work was a concern. Two days later, on December 24, 1997, during a quarterly surveillance test of the 3A core spray pump, the discharge pressure was found to be 212 psig, yet this finding was not questioned even though the observed discharge pressure during the previous five years of tests had been typically between 220-225 psig, providing indications of a degraded core spray pump which could have lead to earlier identification of fibrous material in the system. The failure to exercise appropriate FME controls at Peach Bottom during the October 1997 outage indicates a significant lack of attention towards licensed responsibilities. This failure is particularly disturbing given the findings of your QA department, as well as the fact that the NRC had issued a Severity Level III Notice of Violation to your Limerick facility in October 1996 for the failure to establish adequate controls to exclude foreign material from the Limerick I suppression pool. That failure resulted in substantial accumulation of debris on a suppression pool suction strainer causing some cavitation of an RHR pump. In my October 17, 1996, letter transmitting the Notice of Violation for Limerick, I noted that the findings demonstrated the importance of management taking appropriate action to assure that (1) the FME program is appropriately implemented, and (2) your staff is proactive in evaluating adverse conditions identified at one facility to ensure degraded conditions do not exist at the other facility. Notwithstanding those prior cautions, adequate FME controls were not exercised at Peach Bottom during October 1997 and this represents a significant regulatory concern. Therefore, the violations are classified in the aggregate as a Severity Level III problem in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600 (Enforcement Policy). A base civil penalty in the amount of $55,000 is considered for each Severity Level III violation or problem. Because Peach Bottom has been the subject of escalated enforcement actions within the last 2 years,(1) the NRC considered whether credit was warranted for Identification and Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. Credit for identification is not warranted, even though you identified this violation during a required surveillance test, because you had prior opportunities to identify and preclude these violations as a result of the QA findings in October 1997. Credit for your corrective actions is warranted because at the time of the enforcement conference, your actions were considered prompt and comprehensive. These actions included, but were not limited to, plans to (1) conduct an independent FME review of design and installation of modifications; (2) enhance training of staff on the FME plan; (3) benchmark other industry FME programs, including suction strainer replacement FME controls; and (4) assure accountability of all rigging material after each use. The NRC plans to continue to follow your actions closely to determine the effectiveness of your actions in precluding future problems. Therefore, to emphasize the importance of appropriate FME controls at your facilities, as well as appropriate response to QA findings, I have been authorized, after consultation with the Director, Office of Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of $55,000 for these violations. During the conference, another apparent violation was discussed involving the 2A reactor feedwater pump turbine high water level trip function not being maintained operable. Upon further review, the NRC has decided not to cite a violation based on information that you provided during the conference that the function was operable. Nevertheless, the NRC is concerned that this trip function exhibited degraded performance in April 1997 and November 1997, but a lack of systematic troubleshooting resulted in a failure to determine all potential causes of the degradations. Further, your corrective actions did not prevent subsequent degraded performance in December 1997 and February 1998. At the enforcement conference, you admitted that your troubleshooting was neither comprehensive nor consistent, and you provided a number of actions to strengthen this program. You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements. In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response will be placed in the NRC Public Document Room (PDR).
Docket Nos. 50-277; 50-278 ENCLOSURE
During an NRC inspection conducted between March 30 and April 24, 1998, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, 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 associated civil penalty are set forth below: A. 10 CFR Part 50 Appendix B, Criterion V, Instructions, Procedures and Drawings, requires, in part, that activities affecting quality be prescribed by documented instructions or procedures, of a type appropriate to the circumstances. These violations are classified in the aggregate at Severity Level III (Supplement 1). Civil Penalty - $55,000. Pursuant to the provisions of 10 CFR 2.201, PECO Nuclear (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 receipt of this Notice of Violation and Proposed Imposition of Civil Penalties (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 violation if admitted, and if denied, the reasons why, (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 or a Demand for Information may be issued as to 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 above under 10 CFR 2.201, the Licensee may pay the civil penalties by letter addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, money order, or electronic transfer payable to the Treasurer of the United States in the 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 penalties will be issued. Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, 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 penalties should not be imposed. In addition to protesting the civil penalties in whole or in part, such answer may request remission or mitigation of the penalties. In requesting mitigation of the proposed penalties, the factors addressed in Section VI.B.2 of the Enforcement Policy 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 that 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, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282c. The response noted above (Reply to Notice of Violation, letter with payment of civil penalty, and Answer to a Notice of Violation) should be addressed to: James Lieberman, Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, One White Flint North, 11555 Rockville Pike, Rockville, MD 20852-2738, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region I, and a copy to the NRC Senior Resident Inspector at the facility that is the subject of this Notice. Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR. If redactions are required, a proprietary version containing brackets placed around the proprietary, privacy, and/or safeguards information should be submitted. In addition, a non-proprietary version with the information in the brackets redacted should be submitted to be placed in the PDR. Dated at King of Prussia, Pennsylvania 1. e.g., A Notice of Violation was issued on January 3, 1997 for a Severity Level III violation of the maintenance rule (Reference: EA 96-370). |
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