ML20214A147
| ML20214A147 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 05/08/1987 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| EA-87-027, EA-87-27, SL-2348, NUDOCS 8705190292 | |
| Download: ML20214A147 (12) | |
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Telephoe 404 526 6526 Mailing Address:
Fbst Oft:ce Box 4545 Atlanta, Georgia 30302 GeorgiaPower Ma age Nuclear Safety and Licensing SL-2348 1307C X7GJ17-H120 May 8, 1987 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D. C.
20555 PLANT HATCH - UNITS 1, 2 NRC 00CKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 ENFORCEHENT ACTION 87-27 Gentlemen:
In response to your request of April 8,1987, and in accordance with to the provisions of 10 CFR Section 2.201, we have enclosed our response to the Notice of Violation and Proposed Imposition of Civil Penalty associated with the Enforcement Action identified above.
The Notice of Violation refers to the partial loss of water from the spent fuel pools.
The response to Violation 86-43-01 will be transmitted under separate Cover.
If you should have any questions in this regard, please contact us at any time.
Sincarely, fA " m L. T. Gucwa MJB/lc l
Enclosures:
I 1.
NRC Notice of Violation 86-41-01 2.
GPC Response to Notice of Violation 86-41-01 3.
Request for Mitigation of Civil Penalty 4.
Check #936981 c:
(see next page) gasu8aat E8any
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O-GeorgiaPowerA U. S. Nuclear Regulatory Commission May 8, 1987 Page Two c: Georaia Power Company Mr. J. P. O'Reilly Mr. J. T. Beckham, Jr.
GO-NORMS U.S. Nuclear Reaulatory Commission. Reaion II Dr. J. N. Grace, Regional Administrator Mr. P. Holmes-Ray, Senior Resident Inspector - Hatch 1
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1307C
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k Georgia Power h ENCLOSURE 1 NOTICE GF VIOLATION 86-41-01 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 ENFORCEMENT ACTION 87-27 VIOLATION 50-321/87-41-01 and 50-366/87-41-01
" Technical Specification 6.8.1.a requires that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Appendix A of Regulatory Guide 1.33 specifies that procedures are required for equipment control and the operat'on of the instrument air system.
Technical Specification 6.8.1.b requires that written procedures be established, implemented, and maintained covering activities for refueling operations.
Contrary to the above, written procedures for equipment control and the instrument air system were not implemented.
Specifically, A.
Section 8.1.2.1 of Procedure 10AC-MGR-004-0S, Revision 1, Deficiency Control System, requires that a Maintenance Work Order (MHO) be used to control the correction of defects in plant equipment.
- However, prior to the loss of spent fuel pool water on December 2-3, 1986, no MHO was written to document a defect in plant equipment when the air regulator supplying air to the transfer canal seals was found to be defective and a valve in the same line was throttled to control air to the seals.
B.
Operations Department Interoffice Correspondence LR-0PS-002-0286, dated February 3, 1986, requires hose station valves to be tagged open on a clearance.
However, prior to the loss of spent fuel pool water on December 2-3, 1986, the hose station lever valve that supplied air to the transfer canal seals was not tagged open on a clearance.
C.
Calibration Procedure 57CP-CAL-094-2, Revision 1, requires at the end of the calibration that the drain valve to the level switch be closed and the isolation valve be opened. However, on October 10, 1986, the drain valve to level switch 2G41-N019, a safety-related instrument on the transfer canal leak detection system, was incorrectly left open and the isolation valve was incorrectly closed after the performance of Procedure 57CP-CAL-094-2.
This rendered the transfer canal seal leak detection system inoperable and defeated the system's ability to-detect a leak.
1307C El-1 5/8/87 SL-2348 700775
GeorgiaPower d ENCLOSURE 1 (Continued)
NOTICE OF VIOLATION VIOLATION 50-321/87-41-01 and 50-366/87-41-01 (Con't)
D.
Section 5.3.1.3 of Procedure 10AC-MGR-003-0S, Revision 5, Preparation and Control of Procedures, requires personnel to stop, notify their supervisor, and back out of a procedure if it is wrong.
However, the transfer canal seal leak detection system was calibrated on October 10, 1986, using Calibration Procedure 57CP-CAL-094-2, Revision 1 even though this procedure was wrong in that it did-not provide instructions for the removal from service for level switch 2G41-N019.
This is a Severity Level III violation (Supplement I).
(Civil Penalty - $50,000.)"
1 i
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l Georgia Power A ENCLOSURE 2 RESPONSE TO NOTICE OF VIOLATION PLANT HATCH - UNITS 1, 2 NRC 00CKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 ENFORCEMENT ACTION 87-27 ADMISSION OR DENIAL OF VIOLATION:
The violation occurred.
He have included as Enclosure 4 a check for the full amount of the proposed Civil Penalty.
For ease of our discussion we note that the violation is based on two separate and unrelated events.
He identify Violation I.A and I.B as constituting Event 1 and Violation I.C and I.D as constituting Event 2.
REASON FOR VIOLATION:
EVENT 1 Violation I. A This violation occurred due to personnel error in that an unknown person failed to properly identify a failed or degraded transfer canal seal air supply regulator.
No Maintenance Work Order (MWO) or Deficiency Report (DR) was initiated as required by plant administrative control procedures.
Violation I.B A violation occurred but not precisely as stated.
The Plant Equipment Operator (PEO), who actually closed the partially open air supply valve, did so under the guidance of 34G0-0PS-179-0S, Rev. O,
" GENERAL GUIDELINES FOR ISOLATING AND RESTORING EQUIPMENT" and of Operations Department Letters LR-0PS-001-1285 and LR-0PS-002-0286 which required hose station valves in use to be tagged open on a clearance.
In this case, no clearance was issued because the problem with the regulating valve had not been identified to supervision.
In any event, the action the PE0 took was consistent with his training on the use of ball valves (i.e., ball valves are either fully open or fully closed).
Since this valve was -just barely open, he assumed it had been inadvertently bumped and corrected a cen:tition he thought was in error.
Notwithstanding the above clarifying discussion, GPC concurs that a procedural violation occurred.
He agree with the NRC that the genesis for the sequence of events leading to the partial loss of inventory from the spent fuel pools was the violation cited as item I.A.
He believe that had Violation I.A not occurred (i.e., a MHO and/or DR having been written at the time of the air regulator failure) one of two sequences of events would have taken place:
- 1) the air regulator would have been promptly repaired or replaced or 2) if materials were not available to repair the regulator, additional controls would have been implemented to ensure that proper air pressure was maintained on the transfer canal seals.
1307C E2-1 5/8/87 SL-2348
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'l Georgia Powerb l
ENCLOSURE 2 (Continued)
RESPONSE TO NOTICE OF VIOLATION EVENT _2 Violation I.C The violation occurred due to an inadequate procedure and a
personnel error.
The. detector, 2G41-N019, was calibrated per Procedure 57CP-CAL-094-2S on October 10, 1986.
This procedure..is a i
j generic calibration procedure for Robert Shaw Level Switches.
i i
Instrument 2G41-N019 was listed in. Tables 'I and. 2 of_ the Procedure, i
indicating that this was the correct procedure to use.
The specific instructions. regarding " removal from service" for various instruments-i are contained in Table 3 of the Procedure.
However, 2G41-N019 was aqt listed in Table 3 at the time _ of the event.
Personnel error by Instrument and Control -(I&C) personnel consisted. of incorrectly using -
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and filling out Data Package 1 of the Procedure prior to calibrating the instrument.
Data Package 1 documents the completion of steps required to remove an instrument and return it to service.
Violation I.D The violation occurred. He consider this Violation to be the cause for Violation I.C.
Consequently, we believe that I.C and I.D should be considered together as one event _ relative to the inoperability of the transfer canal leak detec' tion system.
]
As discussed in the response to Violation I.C, the condition we identified as Event 2 was due to the initial error made by the technicians when the decision was made to use Procedure 57CP-CAL-094-2S j
to calibrate instrument 2G41-N019.
If a generic procedure.does not list a
specific instrument in the respective table concerning the instructions for " removal from service" for that instrument, then the procedure should aqi be used to perform calibration for the instrument in question.
The failure of the procedure to provide correct and clear i
instructions for the removal from service of the instrument is due to an j
inadequate procedure and is considered a contributing cause to this 1
event.
The continued use of this procedure was a. failure to realize improper application of the procedure.
It should be noted that Procedure 57CP-CAL-094-2S had not been through the' Procedures Upgrade Program (PUP) at the time of the incident.
PUP is.a major program designed to substantially upgrade our plant procedures.
1 CORRECTIVE ACTIONS TAKEN t
Georgia Power has implemented programmatic and specific corrective actions to preclude similar events, and to further instill a philosophy of proactive, aggressive identification, and ~ timely correction of problems. The Deficiency Control System Procedure (10AC-MGR-004-OS) was revised and made effective December 22, 1986.
This revision to the Procedure streamlines the process for identification and resolution of deficient conditions and, consequently, should help avoid problems such as those identified in Events 1 and 2.
1 1307C E2-2 5/8/87 SL-2348 7"'!'
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k Georgia Power h ENCLOSURE 2 (Continued)
RESPONSE TO NOTICE OF VIOLATION It should also be noted that the revision of the Deficiency Control System Procedure was begun on or about October 1,1986, at the request of plant management in order to make the procedure more " user friendly",
as well as to implement a pocket size Deficiency Card which would be readily available and that would be carried by plant personnel.
This enhancement, combined with training and supervisor example, would make personnel more familiar with the Deficiency Procedure.
This initiative demonstrates a commitment to the philosophy of promptly identifying defects and to procedure compliance, adherence, and attention to detail.
As part of the revision process to the Deficiency Procedure, 10AC-MGR-004-0S, Rev.
O, the following training was completed.
These actions reflect an ongoing and emphasized interest of GPC management to assure procedural adherence and attention to detail:
- 1) Deficiency control system - video tape (
Reference:
Departmental Directive VPH-04 December 8-16, 1986).
- 2) Quarterly information meeting (December 1986) presentation made by Nuclear Safety and Compliance concerning changes made in 10AC-MGR-004-0S and use of the Deficiency Card.
- 3) Effective January 1, 1987, the Training Department has permanently incorporated training on the use of Deficiency Cards into the new employee training program.
- 4) Effective January 1, 1987, the Training Department has temporarily (at least for one year) incorporated training on the use of Deficiency Cards into the annual general employee requalification training program.
Relative to Event 1 (Violation I. A & I.8), additional, specific corrective actions have been taken:
1)
The " DAILY INSIDE ROUNDS PROCEDURE" procedure, 34GO-0PS-030-IS, was revised to require personnel to record air pressure of the following (if installed): fuel pool gate seals, fuel transfer canal gate seals, transfer canal cask storage gate seals, and the transfer canal seal assembly.
The procedure also provides acceptance criteria for the pressure of each seal.
These changes were incorporated into Revision 4 of the procedure which was made effective January 3, 1987.
2)
Clearances and name tags were placed on refueling floor inflatable seal air supply isolation valves.
1307C E2-3 5/8/87 SL-2348 1
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Georgia Power d ENCLOSURE 2 (Continued)
RESPONSE TO NOTICE OF VIOLATION I
Relative to Event 2 (Violation 1.C & 1.D) 1)
The transfer canal leakage detection system was properly placed in service (i.e., the drain was closed).
2)
Calibration procedures associated with the transfer canal leakage detection system and the_ seal air supply syste;n have been revised.
Procedures involved are 57CP-CAL-094-2S, 57CP-CAL-061-lS, 57CP-CAL-036-lS, and 57CP-CAL-012-1S.
The revisions included instrument 2G41-N019 in Table 3 of Procedure 57CP-CAL-094-2S and the incorporation of a temporary design change (discussed later).
Specific corrective actions relevant to both Events:
1)
On December 3, 1986, immediately on recognition of the problem, dams using sand bags, resin bags, and earth were built to contain the water that was exiting the storm drain system.
Temporary dams were also built to preclude offsite _ runoff from the swamp.
Extensive mobilization of earthmoving equipment was initiated and implemented, and conceptual plans were examined for large-scale retention of the swamp.
No large or permanent dams / dikes were erected in the swamp since such construction would have required governmental authorization.
Discussions on possible mitigative measures did occur, however, with governmental agencies.
It was concluded that temporary dams were appropriate in light of potential adverse impact of major dams relative to the s'.nall actual hazard from water containing low levels of activity.
The NRC, which had been kept fully informed of, and participated in, several of the conversations relative to the retaining structures, concurred with the GPC course of action.
2)
Immediately following discovery on December 3,1986, of the loss of air to the fuel transfer canal pneumatic seals (approximately 2202 EST), the air supply was restored, and the seals were reinflated (approximately 2203 EST).
The reinflation of the seals terminated the leak. At approximately 2255 EST, fuel pool level had been returned to normal.
The fuel pool cooling and cleanup system was returned to normal level and service at 0045 EST December 4, 1986.
3)
Temporary Design Changes (DCR 86-422T and 86-423T) were approved and implemented to provide independent air supplies to the transfer canal seals.
1307C E2-4 5/8/87 SL-2343
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l GeorgiaPower d ENCLOSURE 2 (Continued)
RESPONSE TO NOTICE OF VIOLATION 4)
Personriel were made aware of this event and steps leading to it (Ref. Department Directive VPH-86-03).
Management emphasized that each individual is responsible to initiate action (maintenance work orders and/or deficiency reports) to correct deficient conditions in the plant.
Personnel involved in activities leading to the event were disciplined (including letters of reprimand and conferences with management).
5)
An Oversight Board was established to provide on-going management level review of the activities of all the groups involved with the spill.
The Board was comprised of site and corporate management.
6)
Corporate Nuclear Safety and Licensing reviewed General Design Criterion 61 to assure that the Plant Hatch fuel storage and handling systems meet the requirements of the criterion.
7)
Site Engineering has reviewed the design of the seal air supply system to assure that it conformed to the recommendations of Significant Event Report 72-84 Supplements 1 & 2, Significant Operating Event Report 85-01, IE Information Notice 84-93, and IE Bulletin 84-03.
8)
Evaluations were conducted to ensure that any design changes which may have occurred were consistent with appropriate safety and design criteria.
9)
Technical Specifications limits were not affected during this incident and no off-site releases occurred.
- 10) Significant efforts were undertaken to reclaim as much of the contaminated water as possible from the swamp area and transfer it to Radwaste for processing.
Approximately 71,000 gallons of water (approximately one-half the total released from the fuel pools) were recovered from the on-site outfall and processed through Radwaste facilities.
- 11) Radiological sampling of the swamp and river commenced on December 4, 1986.
Analysis showed that contamination of the swamp was limited to the west side (i.e., closest to the plant structures), and that migration of radionuclides to the river did not occur.
An augmented radiological environmental monitoring program was established December 15, 1986, and reported to NRC via letter dated January 7, 1987.
The augmented environmental monitoring program will remain in effect in accordance with the criteria described in that letter.
1307C E2-5 5/8/87 SL-2348 700775
i Georgia Power d ENCLOSURE 2 (Continued)
RESPONSE TO NOTICE OF VIOLATION
- 12) Portions of the storm drain system, areas inside the plant buildings, nitrogen storage tank area, road pavement, trucks, and containers which were contaminated as a result of the spill have been successfully decontaminated to appropriate limits.
- 13) The radiological consequences of the event were evaluated and Georgia Power has concluded that there were no actual safety consequences which resulted from the event.
- 14) As part of the integrated response to the sequence of events both corporate and site augmented their on-duty management and technical staffs on a 24-hour-a-day basis.
This mobilization continued until the plant and environs had been returned to a stable, understood configuration.
Although none of the actuation levels of the Emergency Plan were entered, several of the Emergency Response Facilities were utilized as command posts for personnel involved with the event.
- 15) Corporate Engineering was involved in the event providing coordination of event response from offsite engineering groups, evaluation of potential engineering solutions to potential or real problems associated with the event, evaluation of the safety significance of the event, and provided feedback on the changing conditions of the evolving event to offsite agencies.
They conducted an engineering review of refueling floor air supply systems.
In addition, they established and maintain the action plan to close out all open issues associated with the event. The action plan provides management oversight of the coordinated corrective actions including the augmented radiological environmental monitoring, the temporary design
- changes, the permanent design changes and the safety evaluations.
CORRECTIVE ACTIONS WHICH HILL BE TAKEN TO PREVENT RECURRENCE:
No specific further corrective actions are proposed with respect to the cited violations to prevent recurrence.
- However, the following actions are being taken as part of the ongoing, overall betterment related to the spill event.
1)
The transfer canal inflatable seal assembly is scheduled for replacement subsequent to the 1987 Unit i refueling outage.
2)
Site Engineering has conducted a review of the design of the leak detection system and has already written Design Change Request (DCR) 87-99 to enhance overall system performance.
This issue is being tracked by the NRC, as URI 86-41-02, and by GPC.
1307C E2-6 5/8/87 SL-2348 700775
Georgia Power d ENCLOSURE 2 (Continued)
RESPONSE TO NOTICE OF VIOLATION 3)
As stated previously, temporary design changes 86-422T and 86-423T were implemented following the spill event to add the necessary redundant air supplies, and annunciation in the control room on loss of seal air pressure.
These temporary modifications will be replaced by permanent piping and associated equipment per DCR 87-100.
DCR 87-100 will be implemented after the 1987 Unit I refueling outage.
4)
Specific training on the overall spill event and lessons learned is being conducted for operations personnel (licensed and non-licensed) during requalification training.
l DATE WHEN FULL COMPLIANCE HILL BE ACHIEVED:
Full compliance has been achieved.
GPC remains committed to a philosophy which emphasizes management insistence on procedural adherence and attentian to detail.
The actions notea in this correspondence, some of which had been initiated before the events cited, provide some of the vehicles by which this philosophy is being realized.
An extensive program to enhance i
procedures, coupled with appropriate personnel and supervisor training and discipline are key elements in the betterment process.
Realignment of the on-site organization has provided for more direct involvement and more in-plant time for managers and supervisors.
1307C E2-7 5/8/87 SL-2348 700'7S
e Georgia Power 1 ENCLOSURE 3 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 ENFORCEMENT ACTION 87-27 RE0 VEST FOR HITIGATION OF CIVIL PENALTY The sequence of events which contributed to Violation 86-41-01 is inexcusable.
However, we believe that the NRC's Enforcement Policy contemplates mitigation of civil penalties in appropriate instances (10 CFR Part 2 Appendix C), particularly in cases of prompt extensive corrective action.
He clearly recognize that the causes of the cited events have certain commonality and we do not take the implications lightly, as indicated by our broad corrective actions.
At the same time, we respectfully request that the civil penalty be reduced to support and recognize the significant consequence reducing actions taken by GPC.
Specifically our request is based upon the following factors:
1) the
- prompt, competent, extensive, and comprehensive corrective and mitigation efforts following the ptrtial loss of the spent fuel pool inventory, and 2) the prompt reporting of the spill event, including the on-going written and oral updating to the NRC and the coordination with the State of Georgia, once the event was manifested.
He recognize the State's and NRC's assistance in this regard, in particular the timeliness of review relative to potential containment of the swamp by construction of large structures (dams / dikes) with large equipment procured for any eventuality actually onsite.
With respect to corrective actions, the conservative, extensive, and plant-wide actions, set forth previously, tell part of the story.
What is not adequately reflected is the prompt commitment of substantial resources and dedication of personnel to deal in a timely and creatise fashion with an evolving event, including the locating of potential offsite release points and monitoring of activity levels to assure appropriate response.
As recognized by the NRC's report, the highest management in the Company was directly involved in determining appropriate, immediate mitigation actions.
While we view the sequence of events as inexcusable, our prompt and extensive corrective actions effectively precluded offsite releases from exceeding regulatory limits, a factor which we believe may not be reflected adequately with the present level of civil penalty.
He certainly believe the event to be an " undesirable" milestone in our plant improvement programs, yet we feel strongly that our reactions were exemplary.
Notwithstanding, we are using this event to focus plant-wide attention on issues such as attention to detail and on operational knowledge and involvement.
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