ML20238C389

Discusses Insp on 870418-0619 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000. Action Based on Failure to Declare Reactor Trip Breaker Inoperable Causing Improper Application of Action Statement

ML20238C389
Person / Time
Site:	Vogtle
Issue date:	09/03/1987
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	James O'Reilly GEORGIA POWER CO.
Shared Package
ML20238C391	List: ML20238C389 ML20238C407
References
EA-87-115, NUDOCS 8709100074
Download: ML20238C389 (5)

Text

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SEP 03 887 Docket No. 50-424 License No. NPF-68 EA 87-115-Georgia Power Company ATTN: Mr. James P. O'Reilly Senior Vice President-Nuclear Operations

' Post Office Box 4545 1 Atlanta, GA 30302 Gentlemen:

SUBJECT:

NOTICE OF VIOLATION AND PROPOSED-IMPOSITION OF CIVIL PENALTY

.(NRC INSPECTION REPORT NOS. 50-424/87-31 AND 50-424/87-37) l This refers to the. inspections conducted on April 18 - May 22 and on May 23 - '

June 19,-1987, at the Vogtle Electric Generating Plant. The inspection included a review of the circumstances surrounding the failure to comply with Technical Specifications (TS) for the Reactor Trip Breaker and Residual Heat Removal System. The results of these inspections were forwarded to you in letters dated June 26 and June 29, 1987, respectively. NRC concerns relative to the inspection findings associated with the events were discussed during an Enforcement Conference held on July 1, 1987, at the Vogtle Electric Generating Plant.

The violations described in the enclosed Notice of Violation and Proposed '

Imposition of Civil Penalty (Notice) involve (1) the improper evaluation of component and system operability which led to the failure to comply with the applicable Technical Specification (TS) requirements and (2) the failure to take prompt corrective action for identified deficiencies. Violation A, which ,

occurred on June 2, 1987, while the unit was in Mode 1, involved the operations  !

personnel failing to recognize that when a Reactor Trip Breaker (RTB) is bypassed for maintenance, it becomes inoperable. Failure to declare the RTB inoperable resulted in an improper application of the TS action statements.

While the TS action statement required the unit to be placed in hot standby within six hours if the RTB was inoperable, the unit remained in Mode 1 for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and 34 minutes. Further, with the improper application of TS requirements, plant operations personnel believed the unit could have remained ,

in Mode 1 for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> with the breaker bypassed for maintenance.

Violation B, which occurred while the Unit was in Mode 1 on April 28-29, 1987, involved the failure to take prompt corrective action after discovering a 4 condition which could cause degraded flow in the Residual Heat Removal (RHR)

System. A deficiency report prepared by a knowledgeable engineer, who had been involved with the pre-operational testing of the RHR system, described the potential for insufficient flow rates due to the RHR heat exchanger outlet L valves not being fully open. In an evaluation of this deficiency, the l

operations staff improperly assessed the significance of the valve positions 8709100074 870903 L PDR ADOCK 05000424 i

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Georgia Power Company SEP 031987 and failed to take prompt' action to restore the valves to the full open condition. While it is recognized that the calculated flow reduction from the valves not being fully open was not significantly below the TS flow requirement, the failure to restore the system to full operability or assess the effect on the low pressure injection flow requirement in a timely manner is of concern. It is noted that had the surveillance of ECCS valve positions been conducted using local observation rather than status indication lights, the partially closed position of these valves may have been found. The remote indications were set up such that the lights would indicate the valves were open until the valves were ~ nearly shut (approximately 5 percent open).

A major factor contributing to.these events was a lack of communication between the operations, engineering, and other organizations of your staff. Communica-tion is necessary to assure proper evaluation of component operability and that Technical Specification requirements are met.

To emphasize the need for improved performance in correcting deficiencies, f understanding Technical Specification requirements, and communicating more  !

effectively between site personnel, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Regional Operations, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Fifty Thousand Dollars ($50,000) for the violations described in the enclosed Notice. In accordance with the

" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR i Part 2, Appendix C (1987) (Enforcement Policy), the violations described in the enclosed Notice have been categorized collectively as a Severity Level III pro-blem because they indicate a weakness in the understanding of Technical Specification requirements and the potential effect on these requirements when components are found to be deficient. The escalation and mitigation factors in the Enforcement Policy were considered, and no adjustment has been deemed appropriate.

During the Enforcement Conference, we also discussed the issue regarding your interpretation of the diesel generator license condition and compliance with TS I

action statements relative to the diesel generators. The issue was initially i identified as a violation in Inspection Report 50-424/87-37. Instead, pending i further evaluation by the Office of Nuclear Reactor Regulation, that issue is considered an Unresolved Item. Our actions relative to this matter were discussed in Inspection Report No. 50-424/87-45 which was forwarded to you j in a letter dated July 14, 1987.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional 1 actions you plan to prevent recurrence. 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.

i In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, i Title 10, Code of Federal Regulations, a copy of this letter and its enclosure '

will be placed in the NRC Public Document Room.

)

Georgia Power Company SEP 031987 The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwcrk Reduction Act of 1980, Pub. L. No.96-511.

Should you have any questions concerning this letter, please contact us.

Sincerely, ORIGINAL SIGNED BY:

J. NEL3ON GRACf J. Nelson Grace Regional Administrator

Enclosure:

Notice of Violation and Proposed Imposition of Civil Penalty ec w/ enc 1:

'P. D. Rice, Vice President, Project

, Director iC. W. Hayes, Vogtle Quality

/ Assurance Manager

/

/G. Bockhold, Jr. , General Manager,

/, Nuclear Operations ll.. Gucwa, Manager, Nuclear Safety IandLicensing A. Bailey, Project Licensing Manager 4 . . Churchill, Esq. , Shaw, ittman, Potts and Trowbridge E. Joiner, Troutman, Sanders, 7AcckermanandAshmore U. Kirkland, III, Counsel, Office of the Consumer's Utility

/ Council

4. Feig, Georgians Against jNuclear Energy

,M. B. Margulies, Esq., Chairman, Atomic Safety and Licensing Boaro

- Panel f.O.H. Paris,AdministrativeJudge Atomic Safety and Licensing Board anel f A. Linenberger, Jr. , Administrative Judge

/'r/. Atomic Safety and Licensing Board Panel blKirkland,III, Counsel, Office of the Consumer's Utility Council

i 8 Georgia Fewer Company SEP 031987 pdeig,GeorgiansAgainst N.cclear Energy (J Y B. Margulies, Esq., Chairman, y Atomic Safety and Licensing Board

.Ppnei S M 0. H. Paris, Administrative Judge Atomic Safety and Licensing Board i' Panel gA.1.inenberger, Jr. , Administrative Judge Atomic Safety arid Licensing Board Panel

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