ML18152B002
| ML18152B002 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 06/13/1988 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152B000 | List: |
| References | |
| EA-88-074, EA-88-74, NUDOCS 8806240051 | |
| Download: ML18152B002 (3) | |
Text
NOTICE OF VIOLATION AND PROPOSED IMPOSITI~OF CIVIL PENALTY Virginia Electric and Power Company Surry Units 1 and 2 Docket Nos. 50-280, 50-281 License Nos. DRP-32, DPR-37 EA 88-74 During an NRC inspection conducted during the period of February 1 -
27, 1988, violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions, 11 10 CFR Part 2, Appendix C (1988), the Nuclear Regulatory Commission 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:
A.
Technical Specifications (TS) 3.2.B.5 and 3.2.C.5 for one unit and two unit operation of the Chemical and Volume Control System (CVCS),
respectively, require that two channels of heat tracing be operable for boric acid flowpaths requiring heat tracing.
TS 3.2.D.3 states that one heat tracing circuit may be inoperable for a period not to exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provided that immediate attention is directed to repairing the circuit.
Contrary to the above, as of February 19, 1988, heat tracing circuits on both channels required for the eves boric acid flowpaths to Unit 1 and Unit 2 were inoperable for periods in excess of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
B.
Technical Specification (TS) 4.1.A, Table 4.1-2A, Item 12, requires that the eves Boric Acid Tracing Circuits be verified as operable on a monthly basis.
TS 6.4.A.2 requires written procedures with appropriate instructions for testing of components and systems involving nuclear safety of the station.
Contrary to the above, from December 1984 for Unit 1 and May 1985 for Unit 2 until February 19, 1988, surveillance procedures 1-PT-27H, 1-PT-27I, and 2-PT-27G, required by TS 6.4.A.2 and which were used to verify CVCS Boric Acid Tracing Circuits system operability on a monthly basis, were determined to be inadequate in that these procedures did not test the boric acid flowpath heat trace control circuits, and did not enable verification of operability in accordance with TS Table 4.1.A-2A, Item 12.
Collectively these violations have been categorized as a Severity Level III problem (Supplement I).
Cumulative Civil Penalty - $50,000 (assessed equally between the violations).
8806240051 F'DR ADOCI<
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Notice of Violation Pursuant to the prov1s1ons of 10 CFR 2.201, Virginia Electric and Power Company 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 11 Reply to a Notice of Violation 11 and should include for each violation (1) admis-sion or denial of the alleged violation, (2) the reasons for the violation if admitted, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps which 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 above under 10 CFR 2.201, the licensee may pay the civil penalty by letter addressed to the Director, Office of 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 the cumulative amount of the civil penalties if more than one civil penalty is proposed, 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 11Answer to a Notice of Violation 11 and may:
(1) deny the violation 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, such answer may request remission or mitigation of the penalty.
In requesting mitigation of the proposed penalty, the five factors addressed in Section V.B of 10 CFR Part 2, Appendix C (1988), 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 the penalty due, which has been subsequently 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. 2282.
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Notice of Violation 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:
Directot, Office of Enforcement, U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, Region II and a copy to the NRC Resident Inspector, Surry Power Station.
Dated at Atlanta, Georgia this /3-rAday of June 1988 FOR THE NUCLEAR REGULATORY COMMISSION ORIGINAL SIGNED Bl!
I. NELSON GRACE J. Nelson Grace Regional Administrator