ML20236F487
| ML20236F487 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 07/28/1987 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20236F473 | List: |
| References | |
| 50-277-87-11, 50-278-87-11, EA-87-088, EA-87-88, NUDOCS 8708030362 | |
| Download: ML20236F487 (3) | |
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AND PROPOSED IMPOSITION OF CIVIL PENALTY
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Philadelphia Electric Company Docket Nos.
50-277; 50-278 Peach Bottom Atomic Power Station License Nos. DPR-44; DPR-56 Units 2 and 3 EA 87-88 During an NRC inspection conducted on April 9,1987, NRC inspectors reviewed the circumstances associated with examples of a violation of NRC requirements identified by the licensee and reported to the NRC.
In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended ( Act), 42 U.S.C. 2282, and 10 CFR 2,205. The particular violation and associated civil penalty are set forth below:
10 CFR 50, Appendix R, Section III.G.1 requires, in part, that fire protection features shall be provided for structures, systems and components important to safe shutdown.
These features shall be capable of limiting fire damage so that one train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control stations is free of fire damage.
Section III.G.2 states, in part, that where cables or equipment of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment, a means of maintaining one of the trains free of fire damage shall be provided.
Contrary to the above, the licensee identified to the NRC, in letters dated May 22, September 17, and October 31, 1986, numerous instances where cables and equipment of redundant trains of systems necessary to achieve hot shutdown were located within the same fire area outside of primary containment, and a means of maintaining one of the trains free of fire damage was not provided.
Specific examples of these failures included the following:
1.
Control power cables for the redundant Emergency Service Water Pumps A and B were located in the same fire area, Fire Area 43 for Units 2 and 3.
The operation of one of these pumps is needed for safe shutdown in that they supply service water to the diesel generators, the emergency AC power source.
2.
Control power cables for the four redundant Residual Heat Removal (RHR) pumps (Nos. 2AP35, 2BP35, 2CP35 and 2DP25) were in Fire Area No. 35 of Unit 2.
The operation of one of these pumps is needed in the Suppression Pool Cooling Mode to remove decay heat and achieve safe shutdown.
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3.
Reactor Water Level Indicators (Nos. LI3-2-3-85A, LI3-2-3-85-B, LI3-2-3-86, LR3-2-3-110A, LR3-2-3-110B), Reactor Pressure Indicators (Nos. PI3-6-90A, PI3-6-908), and Reactor Pressure Recorders (Nos.
PR3-2-3-404A, PR3-2-3-404B, and PR3-6-96) were located in fire area l
l No. 13N of Unit 3.
These indicators and recorders are needed for the l
monitoring and control of reactor water level and pressure to achieve i
4.
Various power, control, and indication components of the Reactor Core Isolation Cocling (RCIC) system, control cables for the High Pressure 1
Coolant Iniection (HPCI) system, and components for the RHR System or l
s the Core Spray (CS) system were located in Fire Area No. 6S of Unit j
2.
The RCIC system, HPCI system, RHR system in the Low Pressure j
Coolant Injection Mode, and the Core Spray System in conjunction with i
the manual operation of safety relief valves, are needed to provide f
coolant makeup to the reactor to achieve safe shutdown.
I 5.
The instrument air supply copper tubing to the Safety Relief Valves j
(SRVs) and the redundant nitrogen supply copper tubing to the SRVs I
were located in Fire Area No. '13S of Unit 3.
The tubing is used to provide pneumatic power for manual operation of the SRVs, which in turn provides for depressurization of the reactor when needed to achieve safe shutdown.
This is a Severity Level III violation (Supplement I).
Civil Penalty - $50,000 Pursuant to the provisions of 10 CFR 2.201, Philadelphia Electric Company (Licensee) is hereby required to submit a written statement or explanation to i
the Director, Of fice of Enforcement, U.S. Nuclear Regulatory Commission, within 1
30 days of the date of this Notice.
This reply should be clearly marked'as a
" Reply to a Notice of Violation" and should include (1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, (3) the corrective steps that have been taken and the results achieved, (4) corrective steps that 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, an order may be issued 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, this response shall be st.bmitted under oath or affirmation.
Within the same time as provided for the response required above under 10 CFR 2.201, the Licensee may pay the civil penalty by letter to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, or money order payable to the Treasurer of the United States in the amount of the civil penalty as proposed abcve or may protest imposition of the civil penalty in whole or in part by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission.
Should the Licensee fail to answer within the time specified, an order imposing the civil penalty will be 0FFICIAL RECORD COPY CP PKG PEACH BOTTOM REV 1 -
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Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, in whole or in part, such answer should be clearly marked as an " Answer to a Notice of Violation" and may: (1) deny the violation listed in this Notice in whole or in part, (2) demonstrate extenu-ating 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 penalty, such answer may request remission or mitigation of the penalty.
In requesting mitigation of the proposed penalty, the five factors addressed in
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Section V.B. of 10 CFR Part 2, Appendix C (1987), 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 10 CFR 2.201 reply by specific reference (e.g., citing l
page and paragraph numbers) to avoid repetition.
The attention of the Licensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.
I Upon failure to pay any civil penalty due which subsequently has been 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 j
to Section 234c of the Act, 42 U.S.C. 2282c.
1 The responses to the Director, Office of Enforcement, noted above (Reply to a Notice of Violation, letter with payment of civil penalty, and Answer to a l
Notice of Violation) should be addressed to:
Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, Region I, U.S. Nuclear f
Regulatory Commission, and, a copy to the NRC Resident Inspector, at the facility which is the subject of this Notice.
FOR THE NUCLEAR REGULATORY COMMISSION i
William T. Russeil i
Regional Administrator Dated at King of Prussia, Pennsylvania I
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