ML20058J130
| ML20058J130 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/16/1990 |
| From: | Hairston W GEORGIA POWER CO. |
| To: | NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| NUDOCS 9011270277 | |
| Download: ML20058J130 (7) | |
Text
_.
C.of;I a f'OM
,wty I'
i l
3M l'ietvil w.se Ahnita Go-ng-a 33Idi Temp %oe 404 8.;% W, M ung tej;trast.
e %.,nm cou, e %a, n
Iwl OtN o fW 1/M Dw9of wit Atatient. 3bM'1 lutepNv.e ;M M,8 LMt November 16, 1990 i
n.< # m,,
, ~,,
W. Q. Hairston,181 9 3,wenna,a 0703 swu, ow.c.u,,,
Docket Nos.
50-474 50-40 Director, Office or Enforcement U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C.
20555 Gentlemen:
V0GTLE ELECTRIC GENERATING PLANT REPLY TO A NOTICE OF VIOLATION l
AND PROPOSED IMPOSITION OF CIVIL PENALTY Pursuant to 10 CfR 2.201, Georgia Power Company (GPC) submits the enclosed information in response to two violations identified in Inspection Report 50-424/90-16 and 50-425/90-16 which concerns the Incident Investigation Team review conducted between March 23 and June 8, 1990 and the inspection conducted i
by E. D. Teste on July 9-13, 1990, in the enclosure, transcription of the violation precedes GPC's response.
In addition to the enclosure, a check in the amount nf $40,000 is enclosed, in response to the civil penalty.
Please contact this office if you have any questions.
Sincerely, y).k. [W m-~
W. G. Hairston, 111
?
WGH,Ill/NJS/gm j
i
\\-
Enclosures:
Violations and GPC Response I
c(w): Georoia Power ComneDY
' ~ ~
Mr. C. K. McCoy ' ~ ~
Mr. W.'B. Shipman Mr. R. M. Odom Mr. P. D. Rushton NORMS U. S, Ngelear Reaulatory CommissiQD Mr. S. D. Ebneter, Regional Administrator Mr. D. S. Hood, Licensing Project Manager, NRR Mr. B. R. Bonser, Senior Resident inspector, Vogtle
/ jg 9o1127o277 9o1116 I (
af gm osoogy g1g[/
miock
F ENCLOSURE 1 V0GTLE ELECTRIC GENERATING PLANT NRC NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVll PENALTY ($40,000) AND GPC RESPONSE "1. Violation Assessed a Civil Penalty 10 CFR Part 50.47(b)(5) requires that, as part of licensee emergency response plans, procedures be established for notification, by the licensee, of State and local response organizations, 10 CFR Part 50, Appendix E, Section IV.O 3 requires, as part of the required emergency response plan, that licensees have the capability to notify responsible State and local governmental agencies within 15 minutes after declaring an emergency.
Technical Specification 6.7 l(d) requires that written procedures shall be established, implemented, and maintained covering the Emergency Plan implementation.
Section E.2 of the Vogtle Electric Generating Plant Emergency Plan states, in part, that the Emergency Director is responsible for the notification of the Georgia Emergency Management Agency Emergency Operations Center (EOC)
Communicator, and Burke County Emergency Operations Center (EOC) i Communicator, within 15 minutes after the declaration of an emergency.
i Procedure 91002-C, Revision 15. " Emergency Notifications," which implements Section E.2 of the Emergency Plan, states, in part, that initial notification of the State of Georgia, Burke County, Savannah Piver Site, State of South Carolina, Aiken County, Barnwell County, and Allendale County offsite authorities shall be accomplished within 15 minutes of the declaration of an emergency or an upgrade to a more severe emergency classification level.
Contrary to the above, during the March 20, 1990, Site Area Emergency, declared at 9:40 a.m. EST, initial notifications to Burke County and Georgia i
Emergency Management Agency Operations Center Connunicators were not accomplished until approximately 10:40 a.m. EST, a period of time in excess of 15 minutes.
This is a Severity Level 11 violation (Suppleacnt Vill).
Civil Penalty -
$40,000" i
E-1-1
)
l
1 ENCLOSURE 1 (CONTINVED)
NRC NOTICE Of VIOLATION AND PROPOSED IMPOSITION Of civil PENALTY ($40.000) AND GPC RESPONSE RESPONSE TO VIOLATION ASSESSED A CIVit PENALTY:
Admission or Denial of the Vio].glign:
The violation occurred as stated in the notice of violation above.
Reason for the Violation:
The reasons for the late initial notification of Burke County and Georgia Emergency Management Agency (GEMA) are:
a.
Failure of the Emergency Notification Network (ENN) in the Control room, due to loss of vital AC power.
b.
The design of the back-up ENN which did not include Burke County and GEMA as subscribers on the circuit.
c.
The ENN in the Technical Support Center (TSC) was operational because it received power from the security diesel and was not used.
d.
The Site Emergency Director did not adequately control the initial notification process.
e.
Burke County and GEMA were not accorded priority for initial emergency notification due to procedural deficiencies.
Corrective Steps Which Have Been Taken And The Results Achieved:
The following corrective steps have been taken:
a.
Battery back-up power has been installed for the ENN in the Control Room.
b.
Burke County and GEMA have been added to the back-up ENN.
c.
All Site Emergency Directors have received training on the revised notification procedures, power supplies for emergency telephone communication circuits and the importance of prompt notification of emergencies to offsite government agencies, d.
The following procedures have been revised to accord priority to Burke County and GEMA for initial notification and to emphasize the responsibility of the Emergency Director for notificat0n of offsite agencies.
Procedure 91001-C, " Emergency Classification and Implementing Instructions "
E-1-2
'o
)
INCLOSURE 1 (CON!!NVED)
NRC NOTICE Of VIOLATION AND PROPOSED IMPOSITION Of CIVIL PENALTY (ilDJDD) AND GPC RESPOREL Procedure 91002-C, ' Emergency Notifications."
Procedure 91102-C, "Dutics of the Emergency Director."
e.
A simultaneous facsimile transmission capability has been installed to increase the reliability of emergency notification.
This system was successfully employed during the annual emergency exercise on August 1, 1990.
[orrective' Steos Which Will Be Taken To Avoid further Viola 11Dni:
The corrective steps which have been taken are adequate to minimize the potential for recurrence.
No further corrective actions are warranted.
Dale When full Compl1Ange Will Be Achievtd:
Full compliance was achieved on August 1,1990, when prompt notification to state agencies t w demonstrated during the emergency exercise.
All corrective actions listed above were completed September 4, 1990 upon installation of battery back-up power for the ENN in the Control Room.
11
+
kh 4
E-1-3
/(
ENCLOSURE 2 V0GTLE ELEC1RIC GENERATING PLANT NRC NOTICE OF VIOLATION AND GPC RESPONSE "II.
Violation Not Assessed a Civil Penalty Technical Specification 6.7.1 requires that written procedures shall be established, implemented, and maintained for activities covered in Regulatory guide 1.33, Revision 2, Appendix A.
Regulatory Guide 1.33 delineates the type of safety-related activities that should be covered by written procedures and includes General Plant Operating Procedures and Procedures for Combatting Emergencies and Other Significant Events.
Procedure 12006-C, Revision 15, provides instructions for taking the u')it from hot standby to cold shutdown.
Step D4.2.15a(1) requires that the containment equi > ment hatch be capable of being closed within 57 minutes or that the hatc1 be closed prior to reducing Reactor Coolant System level below three feet below the reactor vessel flange.
Contrary to the above, the licensee failed to develop appropriate
)rocedures for the timely closing of the Unit I containment equipment intch within 57 minutes.
This resulted in the March 20, 1990 event in which this hatch was not closed until 74 minutes after the decision to initiate the closure.
This is a Severity Level IV violation (Supplement 1).'
RESPONSE TO VIOLATION NOT ASSESSED A civil PENALTY Admission or Denial of the Violation:
The violation occurred as stated in the notice above.
Reason for the Violation:
l The reasons for the violation were lack of procedural guidance, and inadequate work controls, i
Lock of Procedural Guidance:
Procedure 12006-C, " Unit Cooldcwn to Cold Shutdown," included a step to ensure that the containment eculpment hatch is capable of being closed within 57 minutes.
Procec ure 27505-C, " Opening and Closing -
Containment Equipment Hatch," provided instructions for opening and closing the containment equipment hatch during normal refueling activities. However, no procedural guidance or work instructions existed, during the March 20 event, for closing the containment equii nt hatch during emergency conditions.
E-2-1
i ENCLOSURE 2 (CONTINUED)
NRC NOTICE OF VIOLATION AND GPC RESPONSE
[
inadequate Work Controls:
On the date of the event, scaffolding and other equipment was i
required to be removed from the equipment hatch area prior to lowering the hatch.
Sufficient work controls to limit equipment blockage in the hatch area were not in place.
Corrective Steos Which Have Been Taken and the Results Achieved:
During the Unit 2 Refueling outage the following corrective steps were performed:
l Provisions were made for use of a temporary system to close the containment equipment hatch. Temporary work instructions in the form of an open Maintenance Work Order (MWO) were written to provide guidance for closing the containment equipment hatch during emergency conditions including a loss of all vital power.
In addition, i
maintenance personnel trained on emergency hatch closure were stationed at the hatch while it was open during mid-loop operation.
These personnel demonstrated that the hatch could be manually closed using chainfalls within the required time.
During the outa,b a permanent design change was implemented on Unit 2 which enables closure of the equipment hatch with or without electrical power and which eliminates the need for the use of chainfalls.
This design change, which has been installed ind tested satisfactorily on Unit 2, employs an air motor and air bottle which will be in place whenever the equipment hatch is open.
Administrative controls were implemented to ensure the containment equipment hatch remains sufficiently clear of obstructions to enable l
rapid closure, Procedure 12008-C, "Mid-loop Operations", was written to integrate mid-loop operating guidelines from procedures 12006-C, " Unit Cooldown to Cold Shutdown;" 12007-C, ' Refueling Operations;" 12000-C, " Post Refueling Operations;" and 13005-1/2, " Reactor Coolant System Draining." This procedure (12008-C) requires that during mid-loop operations with the equipment hatch open, personnel and equipment will be available to close the equipment hatch in a timely manner in the event of loss of AC power, i
E-2-2 l
a ENCLOSURE 2 (CONTINUED)
NRC NOTICE OF VIOLATION AND GPC RESPONSE Lorrective Steps Which Will Be Taken to Avoid further Violatica:
During the next refueling outage for Unit 1, the closure mr.thod involving the use of chainfalls will be used initially and the permanent design change, which was installed on Unit 2, will also be installed. The administrative controls and guidance developed during the Unit 2 outage will also apply to Unit 1.
Procedure 27505-C, which will replace the temporary work instructions, will be revised to provide guidance and written instructions on closing the containment equipment hatch during emergency conditions including a loss of vital power, it will ensure the equipment hatch is closed in a timely manner prior to the core being uncovered, accounting for environmental conditions inside containment.
This procedure revision will be applicable after implementation of the design change during the next scheduled Unit 1 outage.
Dite Whea full Como11ance Will Be Achievad:
Compliance was achieved with the writing of work instructions, the demonstration of a prompt closure method for Unit 2, and the assignment of the dedicated l
closure crew during the Unit 2 Refueling outage.
Corrective action listed above will be completed during the next refueling outage for Unit I when the method already employed on Unit 2 for closing the containment equipment hatch will be implemented.
l l
1 l
E-2-3
-+.
-