ML20133F535
| ML20133F535 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/31/1996 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Mccoy C GEORGIA POWER CO. |
| Shared Package | |
| ML20133F538 | List: |
| References | |
| EA-96-479, NUDOCS 9701140250 | |
| Download: ML20133F535 (6) | |
See also: IR 05000424/1996011
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December 31, 1996
EA 96-479
Georgia Power Company
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ATTN:
Mr. C. K. McCoy
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Vice President
Vogtle Electric Generating Plant
P. O. Box 1295
Birmingham AL 35201
SUBJECT:
NOTICE OF VIOLATION (NRC Inspection Report Nos. 50-424 and
50-425/96-11)
This refers to the inspection conducted during the period September 29 through
November 9. 1996, at your Vogtle Electric Generating Plant (VEGP).
The
inspection included a review of the facts and circumstarjces surrounding
installation deficiencies associated with certain safety-related motor coolers
as well as the program for maintaining this equipment.
The results of this
inspection were discussed with members of your staff on November 12. 1996 and
were formally transmitted to you by letter dated December 5. 1996.
In
addition, on November 27, 1996. you submitted Licensee Event Report
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No. 50-424/96-010 which addressed the inoperability of the Unit 1 safety
injection pump B (18 SIP) due to degraded motor cooling. An open
predecisional enforcement conference was conducted in the Region II office on
December 19, 1996, with you and members of your staff to discuss the apparent
violation, the root causes and corrective actions to preclude recurrence. A
list of conference attendees, a copy of your presentation materials, and NRC
slides are enclosed.
Based on the information developed during the inspection and the information
that was provided during the conference. the NRC has determined that
violations of NRC requirements occurred.
The violations are cited in the
enclosed Notice of Violation (Notice), and the circumstances surrounding them
are described in detail in the subject inspection report.
Violation A
involved the inoperability of the 18 SIP for a period greater than that
allowed by Technical Specifications (TS) due to inadequate pump motor cooling.
The inoperable condition existed from at least September 1991 when maintenance
was last performed on the 18 SIP motor coolers and may have existed for some
indeterminate period prior to that time.
Specifically, during the aeriod
October 23-25. 1996. you determined that the cooling flow through t1e two
motor coolers for this pump was degraded to approximately one-sixth of the
normai flow.
The condition was caused by improper installation of a gasket on
the inboard motor cooler which blocked all flow in that cooler and improper
installation of a plenum in the other motor cooler which reduced flow through
it by two-thirds.
In addition your subsequent investigation identified
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similarly reversed plenums on a Unit 2 Train A containment spray pump motor
cooler, a Unit 1 Auxiliary Component Cooling Water (ACCW) Pump 2 motor cooler,
and both Unit 2 ACCW Pump 1 motor coolers.
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9701140250 961231
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Violation B involves your failure to establish adequate procedures for the
disassembly and reassembly of the motor coolers during maintenance activities.
Although some guidance was 3rovided in the maintenance checklist to instruct
personnel to re-install gascets and plenums, the procedure was general and
provided insufficient specific guidance or precautions regarding gasket or
plenum orientation.
The 3rocedural deficiency was compounded by the lack of
detailed information in t1e vendor manuals and a lack of knowledge on the part
of plant personnel that the motor coolers were three-pass coolers instead of
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the assumed one-pass configuration.
Although the inoperability of the 1B SIP did not have a significant
consecuence to safety because it was not called upon to operate during this
Jerioc , the violations are nonetheless of significant regulatory concern
3ecause an important emergency core cooling system (ECCS) component was
inoperable for an extended period of time.
Although your safety analysis
indicates that the 1B SIP would have operated for approximately one-hour post-
accident, it would have likely failed following that period due to motor
bearing failure resulting in its unavailability for subsequent accident
mitigation.
The NRC also recognizes that the overall safety function was not
lost in this case due to the availability of the 1A SIP.
However, as you
described at the conference, there were periods during the time in which the
18 SIP was inoperable that the 1A SIP was out of service for maintenance or
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testing: thus, the plant was operated for short periods of time in a condition
which was prohibited by TS.
Therefore, these violations are classified in
the aggregate in accordance with the " General Statement of Policy and
Procedures for NRC Enforcement Actions" (Enforcement Policy). NUREG-1600, as a
Severity Level III problem.
In accordance with the Enforcement Policy, a base civil penalty in the amount
of $50,000 is considered for a Severity Level III problem.
Because your
facility has been the subject of escalated enforcement action within the last
two years the NRC considered whether credit was warranted for Identification
and Corrective Action in accordance with the civil penalty assessment process
described in Section VI.B.2 of the Enforcement Policy. The NRC concluded that
credit was warranted for Identification because your staff identified the
violations. The attentiveness and questioning attitude of the plant equipment
o)erator responsible for identifying and pursuing temperature differences in
t1e two motor coolers for the 1B SIP and the site engineer who identified the
possibility of reversing the motor cooler plenums are particularly noteworthy.
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With regard to consideration for Corrective Action, at the conference you
stated that your immediate and long term corrective actions included:
(1) proper installation of the gasket and plenum on the 1B SIP: (2) inspection
and correction of other ECCS motor coolers for reversed plenums:
(3) development of a plant procedure which provides detailed instruction for
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correct disassembly and reassembly of motor coolers and revision of the
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existing maintenance checklist to reference the new procedural requirements:
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(4) inspection and correction of ACCW motor coolers plenum installation
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deficiencies: (5) training of maintenance personnel scheduled in January 1997
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and continuing as part of the Continuing Training Program: (6) establishment
of concurrent, dual verification of gasket and plenum installation; and
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(7) initiation of a review to determine the appropriate methodology for
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periodic functional testing of heat exchangers.
Based on the above. the NRC
determined that your corrective actions were prompt and comprehensive, and
credit was warranted for this factor.
Therefore. to encourage prompt identification and comprehensive corrective
action for violations. I have been authorized. after consultation with the
Office of Enforcement, not to propose a civil penalty in this case.
However,
significant violations in the future could result in a civil penalty.
You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response.
In addition.
at the conference you stated that efforts have been initiated to determine the
appropriate functional testing criteria for heat exchangers.
Due to the
importance of this effort in assuring future operability of heat exchangers
for safety-related equipment we request that your response include a detailed
description and proposed schedule for your actions in this regard.
The NRC
will consider your response, in part, to determine whether further enforcement
action is necessary to ensure compliance with regulatory requirements.
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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice." a copy of
this letter, its enclosures, and your response will be placed in the NRC
Public Document Room (PDR).
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Sincerely.
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Stewart D. Ebneter
Regional Administrator
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Docket Nos. 50-424, 50-425
Enclosures:
1.
2.
Conference Attendees
3.
NRC Slides
4.
Licensee Presentation Material
cc w/encls:
J. D. Woodard
Senior Vice President
Georgia Power Company
P. O. Box 1295
Birmingham. AL 35201
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cc w/encls:
(Cont'd on Page 4)
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cc w/encls (Cont'd):
J. B. Beasley
General Manager Plant Vogtle
Georgia Power Company
P. 0. Box 1600
Waynesboro. GA 30830
J. A. Bailey
Manager-Licensing
Georgia Power Company
P. O. Box 1295
Birmingham. AL 35201
Jim Hurt. Director
Consumers' Utility Counsel Division
Governor's Office of Consumer Affairs
2 M. L. King Jr. Drive
Plaza level - East: Suite 356
Atlanta. GA 30334-4600
Office of Planning and Budget
Room 6158
270 Washington Street. SW
Atlanta, GA 30334
Office of the County Commissioner
Burke County Commission
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Waynesboro, GA 30830
Harold Reheis. Director
Department of Natural Resources
205 Butler Street SE. Suite 1252
Atlanta, GA 30334
Thomas Hill, Manager
Radioactive Materials Program
Department of Natural Resources
4244 International Parkway
Suite 114
Atlanta. GA 30354
Attorney General
Law Department
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132 Judicial Building
Atlanta GA 30334
cc w/encls:
(Cont'd on Page 5)
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cc w/encls (Cont'd):
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Thomas P. Mozingo
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Manager of Nuclear Operations
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Oglethorpe Power Corporation
2100 E. Exchange Place
Tucker, GA 30085-1349
Charles A. Patrizia. Esq.
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Paul, Hastings, Janofsky & Walker
10th Floor
1299 Pennsylvania Avenue
Washington. D. C.
20004-9500
Steven M. Jackson
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Senior Engineer - Power Supply
Municipal Electric Authority
of Georgia
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1470 Riveredge Parkway NW
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Atlanta, GA 30328-4684
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Distribution w/encls:
PUBLIC
JTaylor. EDO
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JMilhoan. DEDR
GTracy. OEDO
SEbneter RII
LChandler. OGC
JGoldberg. OGC
RZimmerman. NRR
EJulian. SECY
BKeeling. CA
Enforcement Coordinators
RI. RIII. RIV
JLieberman. OE
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OE:EA File (BSummers) (2 letterhead)
MSatorius. OE
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EHayden. OPA
GCaputo. OI
EJordan. AE00
HBell. OIG
CEvans RII
Buryc. RII
KClark. RII
RTrojanowski, RII
EMerschoff. RII
AGibson, RII
PSkinner. RII (IFS Action Required)
Rcarrion. RII
HBerkow. NRR
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LWheeler. NRR
NRC Senior Resident Inspector
U.S. Nuclear Regulatory Commission
8805 River Road
Waynesboro GA 30830
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