ML20141G411

Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000.Violations Noted:Cold Leg Injection Header Isolation Valves XVG-8888A & XVG-8888B Closed, Rendering Both RHR Subsystem Flowpaths Inoperable

ML20141G411
Person / Time
Site:	Summer
Issue date:	01/06/1986
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20141G395	List: IR 05000801/2009006 ML20141G411
References
EA-85-121, NUDOCS 8601100193
Download: ML20141G411 (3)

Text

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NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES South Carolina Electric & Gas Company Docket No. 50-395 V. C. Summer License No. NPF-12 EA 85-121 During a Nuclear Regulatory Commission (NRC) inspection conducted on August 1 -

September 6, 1985, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"

10 CFR Part 2, Appendix C (1985), the Nuclear Regulatory Commission proposes to impose civil penalties pursuant to Section 234 of the Atomic Energy Act, as amended, ("Act"), 42 U.S.C 2282, PL 96-295, and 10 CFR 2.205. The particular violations and associated civil penalties are set forth below:

I. Technical Specification (TS) 3.5.2 requires that when the plant is in Mode 1, 2, or 3, two independent Emergency Core Cooling Systems (ECCS) subsystems shall be operable with each subsystem comprised of:

a. One OPERABLE centrifugal charging pt.mp,

b. One OPERABLE residual heat removal (RHR) heat exchanger,

c. One OPERABLE RHR pump, and

d. An OPERABLE flow path capable of taking suction from the refueling water storage tank on a safety injection signal and automatically transferring suction to the RHR sump during the recirculation phase of operation.

TS 3.0.4 specifies that entry into an operational mode shall not he made unless the conditions of the Limiting Condition for Operation (LCO) are met without reliance on the provisions of the action statements.

TS 3.0.3 requires that when a LC0 is not met, except as provided in the action statement, within one hour, action shall be initiated to place the plant in a Mode in which the specification does not apply.

TS 6.8.1 requires that written procedures be established, implemented, and maintained for applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, 1978.

Procedure 50P-112 requires that during plant startup, which includes the plant going from Mode 4 to Mode 3, cold leg injection header isolation valves XVG-8888A and XVG-8888B be open.

Contrary to the above, on August 23, 1985, cold leg injection header isolation valves XVG-8888A and XVG-88888 were closed rendering both RHR subsystem flowpaths inoperable for ECCS injection. While in this condition, the plant went from Mode 4 to Mode 3 and remained in Mode 3 for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 15 minutes with the inoperable flowpath.

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Notice of Violation 2 II. A. TS 2.2.1, " Reactor Trip System Instrumentation Setpoints," requires that the reactor trip system instrumentation and interlock setpoints be consistent with the Trip Setpoint values of Table 2.2-1. TS Table 2.2-1 requires that the shift in OP Delta T setpoint for decreasing T ave be zero.

Contrary to the above, on August 29, 1985, because required jumpers were omitted from the OP Delta T trip circuitry, a condition that existed since initial plant startup in October 1982, the shift in the OP Delta T setpoint for a decreasing T ave was not zero as mandated by TS.

B. 10 CFR Part 50, Appendix B, Criterion V requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstance and shall be accomplished in accordance with the instructions, procedures or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Contrary to the above, as of August 29, 1985, calibration test procedures STP-302.001, 302.002 and 302.003 and surveillance procedures STP-345.001, 345.002 and 345.003, which pertain to OP Delta T trip instrumentation, did not contain appropriate channel calibration and surveillance acceptance criteria to determine that the OP Delta T instrument setpoint shift would be zero for a decreasing T Ave.

This is a Severity Level III problem (Supplement I).

(Civil Penalty - $50,000 assessed equally between the violations.)

Pursuant to 10 CFR 2.201, South Carolina Electric and Gas Company is hereby required to submit to the Director, Office of Inspection and Enforcement, U.S.

Nuclear Regulatory Commission, Washington, D. C. 20555, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region II, 101 Marietta Street, N.W. , Suite 2900, Atlanta, Georgia 30323, within 30 days of the date of this Notice a written statement or explanation, including for each alleged violation: (1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, (3) the corrective steps which 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, the Director, Office of Inspection and Enforcement, may issue an order 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, the response shall be submitted under oath or affirmation.

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Notice of Violation 3 Within the same time as provided for the response required above under 10 CFR 2.201, South Carolina Electric and Gas Company may pay the civil penalties by letter addressed to the Director, Office of Inspection and Enforcement, with a check, draft, or money order payable to the Treasurer of the United States in the amount of Fifty Thousand Dollars ($50,000) or may protest imposition of civil penalties in whole or in part by a written answer addressed to the Director, Office of Inspection and Enforcement. Should South Carolina Electric and Gas Company fail to answer within the time specified, the Director, Office of Inspection and Enforcement, will issue an order imposing the civil penalties in the amount proposed above. h 'd O uth Carolina Electric and Gas Company elect to file an answer in acco aance with 10 CFR 2.205 protesting the civil penalty, such answer may: (1) dr .y 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 penalty 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 five factors addressed in Section V.B of 10 CFR Part 2, Appendix C 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 South Carolina Electric and Gas Company 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.

FOR THE NUCLEAR REGULATORY COMMISSION ORIGINAL SIGNED BY JOHN A. OLSHINSKI J. Nelson Grace Regional Administrator Dated at Atlanta, Georgia, this (a day of December 1985 L a