ML20052A189
| ML20052A189 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 03/29/1982 |
| From: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20052A187 | List: |
| References | |
| EA-82-018, EA-82-18, NUDOCS 8204270556 | |
| Download: ML20052A189 (5) | |
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APPENDIX NOTICE OF VIOLATION AND PROPOSED' IMPOSITION OF CIVIL PENALTIES Georgia Power Company Docket No. 50-321 Edwin I. Hatch Nuclear Plant License No. DPR-57 Unit 1 EA 82-18 As a result of a special inspection conducted at the Edwin I. Hatch Nuclear Plant near Baxley, Georgia from Septer.ber 29 to Octcber 2,1981, it appears that 'several violations of NRC requirements occurred.
NRC concerns regarding these vio'lations were discussed with Georgia Power Company management during a meeting in the NRC Region II office in Atlanta on October 29, 1981.
T!.e violations relate to successive ruptures of replacement diaphragms used in a valve in the high pressure coolant injection (HPCI) turbine pump overspeed complex between July 21 and September 14, 1981.
On July 2, 1981 the licensee receivec' a General Electric Company Service Information Letter (SIL) informing it that purchase orders for replacement diaphragms placed directly with the valve manufacturer would result in the supply of a " thin, non-reinforced Neoprene diaphragm with severely reduced duty cycle life." The SIL described a methbd for obtaining acceptable diaphragms.
Between July 12 and August 11, 1981, the licensee installed two diaphragms which did not meet the original design specifications for that component.
Before the installation of the second diaphragm on August 11, 1981, the licensee had information that the replacement diaphragms were substandard, yet the licensee failed to act on this information.
On August 18, 1981 the substandard diaphragm failed again.
During this succession of diaphragm failures, the HPCI system was declared inoperable only while diaphragm replacement activities were being conducted, even though the information contained in the SIL came to the attention of licensee management on August 7, 1981. On August 18, 1981 the Plant Review Board (PRB) received a recommendation from the Quality Assurance (QA) Site Supervisor that the HPCI be declared inoperable.
Because of the proven unreliability of the substandard diaphragm which was failing within the surveillance cycle, the HPCI system should have been declared inoperable on August 7, 1981.
The licensee installed diaphragms of two different designs, both,known to be substandard, but did not evaluate the effect of either design on the HPCI system to ensure that such use did not involve an unreviewed safety question.
Had plant personnel initiated internal ~ deviation reports for each diaphragm rupture as required by plant procedures, this matter would have received.
earlier attention by appropriate licensee management and the NRC.
The NRC did not know about the matter until September 9, 1981 when the licensee reported the diaphragm rupture of August 11.
82042 W M
Appendix (Continued) In order to emphasize the need for the Georgia Power Company to promptly iden-tify, evaluate, report and document safety related changes to facility systems or equipment, the NRC proposes to impose civil penalties in the cumulative amount of $50,000 for this matter.
In accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), and pursuant to section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, PL 96-295,.and 10 CFR 2.205, the l
particular violations and their associated penalties are set forth below:
A.
Technical Specification 6.5.1.6d states that the PRB shall be responsible for review of all proposed changes or modifications to unit systems or equipment that affect nuclear safety.
Contrary to the above, between August 7 and September 14, 1981, the licensee made facility changes without prior NRC approval or without having conducted an evaluation as required.
Use of valve diaphragms in the HPCI system which did not meet design specifications constituted a facility change.
This is a Severity Level III Violation (Supplement I).
(Civil Penalty - 515,000).
B.
10 CFR 50, Appendix B, Criteria V and XVI, as implemented by the licensee's accepted QA program, final safety analysis report (FSAR) Sections D.9.5 and D.9.16, respectively, require the licensee to establish and implement mea-sures for ensuring that deviations are promptly identified and corrected.
Contrary to the above, the licensee did not implement an established mea-sure for ensuring that deviations were promptly identified and corrected.
Although HNP-425, " Deviation Report," an established measure, requires the licensee to initiate a deviation report at the time it discovers a condi-I tion in the plant that may degrade a safety system, the licensee did not initiate deviation reports upon discovery of failures of a valve diaphragm in the HPCI system, a condition that degraded a saf'ety system, on July 21 and August 11, 1981.
This is a Severity Level III Violation (Supplement I).
(Civil Penalty - $10,000).
C.
Technical Specification 6.9.1.9b requires the licensee to submit a written report to the NRC within 30 days of its discovery of a condition that leads to operation in a degraded mode.
Technical Specification 6.9.1.8e requires the licensee to report to the NRC the failure or malfunction of one or more components tha.t prevents or could prevent, by itself, the fulfillment of the functional requirements of a system used to cope with accidents analyzed in the safety analysis report (SAR).
This report must be submitted within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and a fol-lowup written report must be submitted within 14 days.
~ Appendix (Continued) Technical Specification 6.9.1.8i requires the licensee to repo'rt to the NRC performance of a system that requires corrective measures to prevent operation in a manner less conservative than assumed in the SAR.
It requires.the licensee to submit a report within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the event, and a written followup report within 14 days.
Contrary to the above, the licensee did not report to the NRC within 30 days of its discovery, on July 21, 1981 that the HPCI system was inoper-able, a condition that led to operation in a degraded mode.
On July 21, August 11 and August 18, 1981, the licensee did not report to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> the failure of a valve diaphragm that could prevent by itself the fulfillment of the functional requirements of the HPCI system, a system used to cope with accidents analyzed in the SAR.
On August 12, 1981 the licensee did not report to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> its estab-lished procedure for biweekly replacement of HPCI valve diaphragms, a corrective measure intended to prevent operation in a manner less conser-vative than assumed in the SAR.
This is a Severity Level III Violation (Supplement I).
(Civil Penalty - $10,000).
D.
When the HPCI system is inoperable, Technical Specification 4.5.D.2 requires, among other things, that the automatic depressurization system (ADS) actuation logic and reactor core isolation cooling (RCIC) system be demonstrated immediately to be operable.
This specification also requires the RCIC system and ADS logic to be demonstrated operable daily thereafter, until the HPCI system is returned to normal operation.
Contrary to the above, on August 7, 1981 when the HPCI system was inoper-able, the licensee did not demonstrate immediately the operability of the -
RCIC system and the ADS logic.
In addition, between August 7 and 22, 1981, the licensee did not demonstrate daily that the RCIC system and ADS logic were operable.
This is a Severity Level III Violation (Supplement I).
(Civil Penalty - $5,000).
E.
10 CFR 50, Appendix B, Criteria V and XVI, and the licensee's QA program, specifically FSAR Section D.4.1, reqJire the licensee to establish and implement procedures to ensure that conditions adverse to quality are promptly identified and corrected.
Contrary to the above, on and after August 18, 1981 the licensee did not implement procedure QA-05-13, a procedure established to ensure that conditions adverse to quality are promptly identified and corrected.
Although paragraph A.3.c of the pr~ocedure requires the QA Site Supervisor to report (through the QA Field Supervisor to the Manager of QA) findings for which the site QA group and site management reach a corrective action e
m..
Appendix (Continued) impasse ~and findings that require immediate action because of a safety con-cern, the QA Site Supervisor did not report such findings.
On August 18, 1981, the QA Site Supervisor and site management (PRB) reached a corrective action impasse with respect to the QA. Site Supervisor's recommendation that the HPCI system be declared inoperable until such time as valve diaphragms that met design specifications could be installed.
This finding should have been reported by the QA Site Supervisor to the Manager of QA as called for by procedure QA-05-13.
In addition, this finding should have been reported, as it constituted a safety concern and required immediate action.
This is a Severity Level III Violation (Supplement I).
(Civil Penalty - $5,000).
F.
Technical Specification 6.5.-l.8 requires the PRB to maintain for each meeting written minutes, documenting results of.its activities.
Technical Specifi-cation 6.5.1.6e requires the PRB to investigate all violations of Technical Specifications.
Technical Specification 6.5.1.7b requires the PRB to render decisions in writing with regard to whether or not items considered under 6.5.1.6 constitute unreviewed safety questions.
Contrary to the above, the PRB minutes of its meeting on August 18, 1981 did not document that the QA Site Supervisor appeared before the PRB and stated that the HPCI system should be declared inoperable because of the diaphragm problems.
This was, in substance, an allegation of violation of the operability requirements of Technical Specification 3.5.D.
The minutes did not document the PRB decision regarding whether or not the use of substandard diaphragms in the HPCI system constituted an unreviewed safety question and whether or not the operability requirements of Technical Specification 3.5.D were being met.
This is a Severity Level IV Violation (Supplement I).
(Civil Penalty - $5,000).
Pursuant to the provisions of 10 CFR 2.201, Georgia Power Company is hereby required to submit to this office within thirty days of the date of this Notice, a written statement or explanation in reply, including for each violation:
(1) admission or denial of the alleged violation; (2) the reasons the violation occurred, if admitted; (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.
Considera-tion may be g-;ven to extending the response time for good cause shown.
Under the authority of Section 182 of the Act, 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, Georgia Power Company may pay the y
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3 Appendix A (Continued) civil penalties in the cumulative amount of $50,000 or may protest' imposition of the civil penalties in whole or in part by a written answer.
Should Geor_gia Power Company fail to answer within the time specified, this office will issue an order imposing the civil penalties in the amount proposed above.
Should Georgia Power Company elect to file an answer in accordance with 10 CFR 2.205 protesting the~ civil penalties, each answer 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.
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 by specific reference (e.g., citing page and paragraph numbers) to avoid repetition.
Georgia Power Company's attention 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 penalties due, which have been s'ubsequently deter-mined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalties unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282.
FOR THE NUCLEAR REGULATORY COMMISSION
/
e RichardC.!eYoung I D
Director Office of(I'nspection and Enforcement Dated at Bethesda, Maryland this 29 day of March 1982 l
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