ML20151W105

Discusses Insp Rept 50-424/88-24 on 880607-09 & Forwards Notice of Violation.Violation Re Failure to Adequately Design Upper Cable Spreading Room Penetration Sealing Sys to Be Water Tight.Record Copy

ML20151W105
Person / Time
Site:	Vogtle
Issue date:	08/17/1988
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Hairston W GEORGIA POWER CO.
References
EA-88-167, NUDOCS 8808230294
Download: ML20151W105 (4)

See also: IR 05000424/1988024

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AUG 171988

Docket No. 50-424

License No. NPF-68

EA 88-167-

Gjergia Power Company

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' ATTN: Mr. W. G. Hairston, III

Senior Vice Preside? -

Nucleer Operations

Post Office Box 4545

At'.anta, Georgia 30302

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Gentlemen:

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SUBJECT: NOTICE OF VIOLATION

(NRC INSPECTION REPOR NO. 50-424/88-24)

This referr, to the Nuclear 3egulat:ory Comission (NRC) inspection conducted

at the Vogtle facility on June 7-9, 1988. The inepection included < review of

the circumstances surrounding the June 3, 1988, event where water leakage

through the (:pper cable spreading room penetrations occurred. The report

documenting this inspection was sent to you by letter dated June 29, 1988. As

a result of this inspection, a significant failure to ccmply with NRC

regulatory requirements was identified, and accordingly, NRC concerns relative

to the inspection findings were oiscussed in an Enforcement Conference held on

July 5, 1988. The letter summarizing this Conference was sent to you on

July 21, 1989,

The violation described in the enclosed Notice of Violation involved a failure

to adequately design the upper cable spreadi:g room penetration sealing syetem

to be water tight. The event that resulted in this violation included water

leakage into the control room which in turn caused the spurious operation of

safe shutdown components and the cubsequent identification of an unreviewed

safety issue. This water leakage into the control room occurred as a result of

inadequate hydrostatic prototype design testing of the upper cable spreading

room penetrations to assure a water tight seal.

A postulated fire in the "B" train cable spreading room with eithee automatic

actuation of the cable sp 9ading room sprinkler system anu/or manual fire

suppression activities as -esult of a fire could have rendered the "B" train

of safe shutdown equipmen v3 'ble. As demonstrated by the June 3,1988

event, the condition of ' .e p o cation i s with respect to their inability ,

to preclude water from en? .he cor' mm could have rendered the "A"

train instrumentat1on ine_ t to e eaking through the "B" train

cable spreading room pent- : 1(ltrating into the associated

"A" train instrumentatio ,(, , e control room i..imediately below

the *8" trein cc hie sprenir. u an increased importance of

maintaining the "A" train c a, a sperable status because a fire in

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the "B" train cable spreading room would render the auxiliary shutdown panel

reqaired to meet the fire protection shutdown criteria inoperable.

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In accordance with the "General Statement of Policy and Procedure for NRC

Eaforcement Actions," 10 CFR Part 2, Appendix C (1988), the violation described '

in the enclosed Notice has been classified as a Severity Level III violation.

Normally, a civil penalty is considered for a Severity Level III violation.

However, after consultation with the Director, Office of Enforcement, and the i

Deputy Executive Director for Regional Operations, I-have decided that a civil

penalty will not be proposed in this case because of your prorept and extensive

compensatory measures and short term corrective actions in response to the

June 3,1988, event; your proposed corrective actions associated with the 4

redesign of the penetration sealing system; and your prior good performance

with respect to design control.

You are required to respond to this letter and the enclosed Notice and should

follow the instructior.s specified therein when preparing your r9sponse. In

your iesponse, you should document the specific actions taken and any additional

actions you plan to prevent recurrence. In particular, describe the final

design of the penetr4Llon seals to ensure a water tight seal. After reviewing

your response to this Notice, including your proposed corrective actions and

the results of future inspections, the NRC will determine whether further NRC

enforcement action is necessary to ensure compliance with NRC regulatory

requirements.

In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2,

Title 10, Code of Federal Regulations, a copy of this letter and its enclosure ,

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will be placed in the NRC Public Doc m nt Room.

The responses directed by this letter and its enclosure is not subject to the

clearance procedures of the Office of Management and Budget as required by the

Paperwork Reduction Act of 1 20, Pub. L. No.96-511.

Sincerely.

ORIGINAL SIGNED BY:

, 1. NELSON GRACE ,

! ,, J. Nelson Grace

Regional Administrator i

4

Enclosure:

Notice of Violation

cc w/ encl:

R. P. Mcdonald, Executive Vice

President, Nuclear Operations

tPID. Rice,VicePresident, Project

Director

cc w/ encl: (cont'd on page 3)

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AUG 171988

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(c:w/ enc 1:-(cont'd)

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. W. Hayes, Vogtle Quality

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)ssui'anceManager.  !

w..Bockhold, Jr., General Manager,

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Jiuclear .0perations

lV.-Gucwa, Manager, Nuclear Safety

. and Licensing

6(A. Bailey,ProjectLicensing

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LK W. Churchill, Esq . Shaw,

. fittman, Potts and Trowbridge

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W. Kirkland, III, Counsel,

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Office of the Consumer's Utility

J:ouncil

W. Feig, Georgians Against

Nuclear Energy

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State of Georgia

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T. E. Conlon

M. V. Sinkule

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NOTICE OF VIOLATION

Georgia Power Company Docket No. 50-424

Vogtle Electric Generating Plant License No. NPF-68

Unit 1 EA 88-167

During the Nuclear Regulatory Commission (NRC) inspection conducted on

June 7-9, 19PB, a violation of NRC requirements was identified. In accordance

with the "General Statement of Policy and Procedures for NRC Enforcement

Actions", 10 CFR Part 2, Appendix C (1988), the violation is listed below:

License Condition 2.G requires that the licensee implement and maintain

in effect all the provisions of the approved Fire Protection Program as

described in the Final Safety Analysis Report for the facility and as

approved in the NRC Safety Evaluation Report (SER) (NUREG-1137) through

Supplement 5.

Section 9.5.1.1, "Fire Protection Requirements," of the SER (NUREG-1137)

dated June 1985, states that General Design Criteria (GDC) 3 requires

that fire fighting systems be designed to eneure that rupture or

inadvertent operation does not significantly impair the safety capability

of structures, systems, and components important to safety. The SER also

states that in order to satisfy the requirements of GDC 3, the licensee

by letter dated February 22, 1985, stated that the components required

for shutdown are designed so that rupture, inadvertent operation, or

intentional operation of Fire Suppression Systems will not adversely

affect the operability of these components. In addition, redundant

trains of components that are susceptible to damage from water spray

are physically separated so that manual fire fighting activities will

not adversely affect the operability of the components not involved in

the postulated fire.

Contrary to the above, as of June 3,1988, the fire suppression systems

were not designed to assure that operation of the systems or manual fire

fighting activities would not adversely affect the operability of compo-

nents required for shutdown er components not involved in the postulated

fire. Specifically, because of improperly designed floor penetration

seals, a fire in the "B" train cable spreading room could have caused a

loss of the auxiliary shutdown panel, the "B" train safe shutdown

functions, and due to th? woter leakage into the control room from firr

suppression activities, tne "A" train safe shutdown process monitoring

could have been rendered inoperable.

ThisisaSeverityLevelIIIviolation(SupplementI).

Pursuant to the provisions of 10 CFR 2.201, Georgia Power Company is hereby

required to submit a written statement or explanation to the Nucle'.r Regulatory

Comission, ATTN: Document Control Desk, Washington, D.C. 20555, with a copy

to the Regional Administrator, Region II, and a copy to the NRC Resident

Inspector Vogtle, within 30 days of the date of the letter transmitting this

Notice. This reply should be clearly marked as a "Reply to Notice of Violation'

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and should include: (1) admission or denial of the violation, (2)- the reasons

for the violation if admitted, (3) the corrective steps which have been taken

to avoid further violations, and (4) the corrective steps which will be taken

to avoid further viciations, and (5) the date when full c.ompliance will be

achieved. Where good cause is shown, consideration will be given to extending

the response time. 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 o+.her action as may

be proper should not be taken.

FOR THE NUCLEAR REGULATORY COMMISSION

ORIGINAL SIGNic gy,

1. NELSON ggggg

J. Nelson Grace

Regional Administrator

Dated at Atlanta, Georgia

thisI7#3 day of August 1988

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