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April 21.1998 | |||
Southern Nuclear Operating Company. Inc. | |||
ATTN: Mr. H. L. Sumner. Jr. | |||
Vice President. Hatch Plant | |||
Nuclear Operations | |||
P.O. Box 1295 | |||
Birmingham AL 35201 | |||
SUBJECT: | |||
EXERCISE OF ENFORCEMENT DISCRETION | |||
(NRC INTEGRATED INSPECTION REPORT 50-321/98-01. 50-366/98-01) | |||
t | t | ||
Dear Mr. Sumner: | |||
On March 21. 1998, the Nuclear Regulatory Commission (NRC) completed an | |||
inspection at your Hatch facility. | |||
The results of that inspection were | |||
discussed at an exit meeting conducted on March 27. 1998. and documented in | |||
NRC Inspection Report No. 50-321/98-01. 50-366/98-01 issued on | |||
April 20.1998. | |||
During the inspection, the NRC examined an issue related to the Main Control | |||
Room Environmental Control (MCREC) system. | |||
On February 16. your staff | |||
identified that a tem3erature switch was not installed on each of the two | |||
MCREC trains. | |||
On eac1 MCREC filter train, the missing temperature switch left | |||
an approximately one-half inch diameter hole that was open to a conduit | |||
containing the wiring for each missing temperature switch. The holes left by | |||
the missing temperature switches allowed bypass flow to enter the control room | |||
' | ' | ||
without filtration by charcoal filters installed in the affected MCREC filter | |||
trains. The design basis of the plant includes limiting thyroid dose to | |||
control room personnel to less than 30 Rem during and following a design basis | |||
accident. | |||
As documented in NRC Inspection Report No. 50-321/98-01. | |||
50-366/98-01. and in your Licensee Event Report 50-321/98-001. Inoperable | |||
MCREC System Filter Trains Result in Entry Into LCO 3.0.3. dated March 18. | |||
1998. with the charcoal filters in both MCREC trains bypassed as a result of | |||
l | |||
the openings created by the missing temperature switches. the thyroid dose | |||
received by control room personnel would have exceeded 30 Rem in the event of | |||
a design basis accident. | |||
, | , | ||
Based on the information developed during the inspection. the NRC has | |||
; | |||
; | determined that a violation of NRC requirements occurred. | ||
10 CFR 50 | |||
' | ' | ||
Appendix B. Criterion III. Design Control, requires that measures shall he | |||
established to verify the adequacy of design, such as by design reviews, | |||
alternate or simplified calculational methods, or suitable testing. | |||
In this | |||
case. the requirements of Appendix B. Criterion III. were not met because | |||
measures were not established to verify the adequacy of the as-installed MCREC | |||
, | |||
system filter tr.in d a ign. | |||
This violation resulted in the MCREC system not | |||
being able to pe:Torm its intended safety function under certain design basis | |||
! | |||
conditions | |||
A violctirm involving a safety-related system which is unable to | |||
perform its intended safety function under certain conditions is generally | |||
) | |||
98050502a7 980421 | |||
~ | |||
PDR | |||
ADOCK 05000321 | |||
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PDR | |||
{ | |||
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- | |||
. | |||
. | |||
SNC | |||
2 | |||
characterized as a Severity Level III violation in accordance with the | |||
" General Statement of Policy and Procedures for Enforcement Actions" | |||
(Enforcement Policy). NUREG-1600. | |||
However, as provided in Section VII.B.3 of | |||
the Enforcement Policy, the NRC may refrain from issuing a Notice of Violation | |||
(Notice) and proposing a civil penalty for a Severity Level III violation | |||
which involves old design issues. | |||
After review of this violation and consultation with the Director Office of | |||
Enforcement, the NRC has concluded that while a violation did occur, | |||
enforcement discretion is warranted end issuance of a Notice is not | |||
appropriate in this case. | |||
The specific bases for the decision to exercise | |||
enforcement discretion are: (1) your staff identified the deficiency during | |||
planned testing and calibration of the MCREC filter trains, when a special | |||
effort was made to remove the charcoal filter beds out of Josition to look | |||
behind a portion of the system that was not easily accessi)le: (2) you | |||
promptly declared both MCREC system filter trains inoperable and entered the | |||
required action statement of Technical Specification (TS) 3.0.3: (3) as part | |||
of your immediate corrective actions, the Standby Gas Trer.tment Systems for | |||
both units, which have a similar configuration as the MCREC system, were | |||
verified to have no missing temperature switches: (4) you promptly implemented | |||
an appropriate temporary modification for each MCREC system filter train in | |||
accordance with plant procedures, and exited TS 3.0.3: (5) the temporary | |||
modification for each train was removed and a temperature switch for each | |||
train was installed and properly tested in accordance with plant procedures: | |||
(6) the deficiency is considered an old design issue, was not likely to be | |||
identified through routine licensee efforts, and is not reflective of current | |||
licensee performance: and (7) the issue was reported to the NRC in Licensee | |||
Event Report 50-321/98-001. Inoperable MCREC System Filter Trains Result in | |||
, | , | ||
Entry Into LCO 3.0.3, dated March 18, 1998. | |||
This letter closes apparent violation EEI 50-321,366/98-01-08, and no formal | |||
response to the apparent violation is recuired. | |||
NRC's final evaluation of | |||
your corrective actions will be addressec during the review and closeout of | |||
-LER 50-321/98-001. | |||
! | |||
* | |||
i | . | ||
I | i | ||
In accordance with 10.CER 2.790 of the NRC's " Rules of Proctice " a copy of | |||
I | |||
this letter will be'pbiced in the NRC Public Document Room. | |||
* | |||
Sincerely. | |||
. | |||
% | |||
Original Signed by L. | |||
A. | |||
Reyes | |||
Luis A. Reyes | |||
Regional Administrator | |||
Docket Nos. | |||
50-321 and 50-366 | |||
License Nos.. | |||
DPR-57 and NPF-5 | |||
cc: see Page 3 | |||
T | |||
- | |||
, | |||
. | |||
SNC | |||
3 | |||
cc: | |||
. J. D. Woodard | |||
Executive Vice President | |||
Southern Nuclear Operating Co., Inc. | |||
P.. 0. Box 1295 | |||
Birmingham AL' 35201-1295 | |||
Mr. P. H. Wells | |||
; | General Manager. Hatch | ||
Southern Nuclear Operating Co., Inc. | |||
; | |||
U.S Highway 1 North | |||
- | - | ||
P. O. Box 2010 | |||
l | l | ||
Baxley, GA 31515 | |||
D. M. Crowe | |||
; | |||
Manager Licensing - Hatch | |||
l | |||
Southern Nuclear Operating Co., Inc. | |||
; | |||
P. O. Box 1295 | |||
Birmingham AL 35201-1295 | |||
Ernest L. Blake. Esq. | |||
Shaw. Pittman. Potts and | |||
Trowbridge | |||
2300 N Street. NW | |||
- | |||
Washington, D. C. | |||
20037 | |||
j | |||
Charles H. Badger | |||
Office of Planning and Budget | |||
Room 610 | |||
270 Washington Street. SW | |||
Atlanta, GA 30334 | |||
! | |||
Harold Reheis. Director | |||
Department of Natural Resources | |||
205 Butler Street. SE. Suite 1252 | |||
Atlanta, GA 30334 | |||
I | |||
Thomas Hill | |||
Manager | |||
l | |||
Radioactive Materials Program | |||
i | |||
Department of Natural Resources | |||
l | |||
4244 International Parkway | |||
1 | |||
Suite 114 | |||
Atlanta. GA 30354 | |||
; | |||
Chairman | |||
! | |||
Appling County Commissioners | |||
1 | |||
County Courthouse | |||
Baxley. GA 31513 | |||
., | |||
-- | |||
. | |||
. | |||
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SNC | |||
4 | |||
i | i | ||
cc: | |||
Continued | |||
! | ! | ||
R. D. Barker | |||
Program Manager | |||
Fossil & Nuclear Operations | |||
i | |||
i | i | ||
Oglethor3e Power Corporation | |||
2100 E. | |||
Exchange Place | |||
! | : | ||
! | |||
Tucker, GA 30085-1349 | |||
Charles A. Patrizia. Esq. | |||
Paul | |||
Hastings, Janofsky & Walker | |||
10th Floor | |||
1299 Pennsylvania Avenue | |||
i | Washington, D. C. | ||
20004-9500 | |||
Steven M. Jackson | |||
, | |||
Senior Engineer - Power Supply | |||
i | |||
Municipal Electric Authority | |||
~ | ~ | ||
of Georgia | |||
1470 Riveredge Parkway NW | |||
. | . | ||
Atlanta, GA 30328-4684 | |||
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Enforcement Coordinators | |||
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OE:EA File (BSummers. OE)(2 letterhead) | |||
PUBLIC | |||
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.NRC Resident Inspector | |||
U.S. Nuclear Regulatory Commission | |||
, | |||
, | |||
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11030 Hatch Parkway North- | |||
Baxley GA 31513 | |||
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OfflCIAL RECORD M Y DOCUMENT NAME:H'I\\1980 PEN.ENF\\98209 HAT.DIR\\DISCLTR.HA V | |||
}} | }} | ||
Latest revision as of 03:43, 23 May 2025
| ML20217N307 | |
| Person / Time | |
|---|---|
| Site: | Hatch |
| Issue date: | 04/21/1998 |
| From: | Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Sumner H SOUTHERN NUCLEAR OPERATING CO. |
| References | |
| 50-321-98-01, 50-321-98-1, 50-366-98-01, 50-366-98-1, EA-98-209, NUDOCS 9805050287 | |
| Download: ML20217N307 (5) | |
See also: IR 05000321/1998001
Text
{{#Wiki_filter:. l < . . 1 ! l April 21.1998 Southern Nuclear Operating Company. Inc. ATTN: Mr. H. L. Sumner. Jr. Vice President. Hatch Plant Nuclear Operations P.O. Box 1295 Birmingham AL 35201 SUBJECT: EXERCISE OF ENFORCEMENT DISCRETION (NRC INTEGRATED INSPECTION REPORT 50-321/98-01. 50-366/98-01) t Dear Mr. Sumner: On March 21. 1998, the Nuclear Regulatory Commission (NRC) completed an inspection at your Hatch facility. The results of that inspection were discussed at an exit meeting conducted on March 27. 1998. and documented in NRC Inspection Report No. 50-321/98-01. 50-366/98-01 issued on April 20.1998. During the inspection, the NRC examined an issue related to the Main Control Room Environmental Control (MCREC) system. On February 16. your staff identified that a tem3erature switch was not installed on each of the two MCREC trains. On eac1 MCREC filter train, the missing temperature switch left an approximately one-half inch diameter hole that was open to a conduit containing the wiring for each missing temperature switch. The holes left by the missing temperature switches allowed bypass flow to enter the control room ' without filtration by charcoal filters installed in the affected MCREC filter trains. The design basis of the plant includes limiting thyroid dose to control room personnel to less than 30 Rem during and following a design basis accident. As documented in NRC Inspection Report No. 50-321/98-01. 50-366/98-01. and in your Licensee Event Report 50-321/98-001. Inoperable MCREC System Filter Trains Result in Entry Into LCO 3.0.3. dated March 18. 1998. with the charcoal filters in both MCREC trains bypassed as a result of l the openings created by the missing temperature switches. the thyroid dose received by control room personnel would have exceeded 30 Rem in the event of a design basis accident. , Based on the information developed during the inspection. the NRC has
determined that a violation of NRC requirements occurred. 10 CFR 50 ' Appendix B. Criterion III. Design Control, requires that measures shall he established to verify the adequacy of design, such as by design reviews, alternate or simplified calculational methods, or suitable testing. In this case. the requirements of Appendix B. Criterion III. were not met because measures were not established to verify the adequacy of the as-installed MCREC , system filter tr.in d a ign. This violation resulted in the MCREC system not being able to pe:Torm its intended safety function under certain design basis ! conditions A violctirm involving a safety-related system which is unable to perform its intended safety function under certain conditions is generally ) 98050502a7 980421 ~ PDR ADOCK 05000321 G PDR { .1?O!
- . . SNC 2 characterized as a Severity Level III violation in accordance with the " General Statement of Policy and Procedures for Enforcement Actions" (Enforcement Policy). NUREG-1600. However, as provided in Section VII.B.3 of the Enforcement Policy, the NRC may refrain from issuing a Notice of Violation (Notice) and proposing a civil penalty for a Severity Level III violation which involves old design issues. After review of this violation and consultation with the Director Office of Enforcement, the NRC has concluded that while a violation did occur, enforcement discretion is warranted end issuance of a Notice is not appropriate in this case. The specific bases for the decision to exercise enforcement discretion are: (1) your staff identified the deficiency during planned testing and calibration of the MCREC filter trains, when a special effort was made to remove the charcoal filter beds out of Josition to look behind a portion of the system that was not easily accessi)le: (2) you promptly declared both MCREC system filter trains inoperable and entered the required action statement of Technical Specification (TS) 3.0.3: (3) as part of your immediate corrective actions, the Standby Gas Trer.tment Systems for both units, which have a similar configuration as the MCREC system, were verified to have no missing temperature switches: (4) you promptly implemented an appropriate temporary modification for each MCREC system filter train in accordance with plant procedures, and exited TS 3.0.3: (5) the temporary modification for each train was removed and a temperature switch for each train was installed and properly tested in accordance with plant procedures: (6) the deficiency is considered an old design issue, was not likely to be identified through routine licensee efforts, and is not reflective of current licensee performance: and (7) the issue was reported to the NRC in Licensee Event Report 50-321/98-001. Inoperable MCREC System Filter Trains Result in , Entry Into LCO 3.0.3, dated March 18, 1998. This letter closes apparent violation EEI 50-321,366/98-01-08, and no formal response to the apparent violation is recuired. NRC's final evaluation of your corrective actions will be addressec during the review and closeout of -LER 50-321/98-001. !
. i In accordance with 10.CER 2.790 of the NRC's " Rules of Proctice " a copy of I this letter will be'pbiced in the NRC Public Document Room.
Sincerely. . % Original Signed by L. A. Reyes Luis A. Reyes Regional Administrator Docket Nos. 50-321 and 50-366 License Nos.. DPR-57 and NPF-5 cc: see Page 3
T - , . SNC 3 cc: . J. D. Woodard Executive Vice President Southern Nuclear Operating Co., Inc. P.. 0. Box 1295 Birmingham AL' 35201-1295 Mr. P. H. Wells General Manager. Hatch Southern Nuclear Operating Co., Inc.
U.S Highway 1 North - P. O. Box 2010 l Baxley, GA 31515 D. M. Crowe
Manager Licensing - Hatch l Southern Nuclear Operating Co., Inc.
P. O. Box 1295 Birmingham AL 35201-1295 Ernest L. Blake. Esq. Shaw. Pittman. Potts and Trowbridge 2300 N Street. NW - Washington, D. C. 20037 j Charles H. Badger Office of Planning and Budget Room 610 270 Washington Street. SW Atlanta, GA 30334 ! Harold Reheis. Director Department of Natural Resources 205 Butler Street. SE. Suite 1252 Atlanta, GA 30334 I Thomas Hill Manager l Radioactive Materials Program i Department of Natural Resources l 4244 International Parkway 1 Suite 114 Atlanta. GA 30354
Chairman ! Appling County Commissioners 1 County Courthouse Baxley. GA 31513
., -- . . l SNC 4 i cc: Continued ! R. D. Barker Program Manager Fossil & Nuclear Operations i i Oglethor3e Power Corporation 2100 E. Exchange Place
! Tucker, GA 30085-1349 Charles A. Patrizia. Esq. Paul Hastings, Janofsky & Walker 10th Floor 1299 Pennsylvania Avenue Washington, D. C. 20004-9500 Steven M. Jackson , Senior Engineer - Power Supply i Municipal Electric Authority ~ of Georgia 1470 Riveredge Parkway NW . Atlanta, GA 30328-4684 l 1 l l
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p u + a. . l Distribution: r. l' LJCallan. EDO- HThompson DEDR AThadani. DEDE LChandler. OGC l JGoldberg OGC EJulian,:SECY BKeeling CA l Enforcement Coordinators l RI. RIII. RIV ! JLieberman. OE l WBeecher. OPA l GCaputo. 01 l TMartin. AE0D l HBell. OIG i CEvans. RII ! KClark RII . LPlisco. RII ' BMallett. RII PSkinner. RII MTschiltz. OEDO l ABoland. RII ! SSparks. RII LOlshan NRR 'TReis. OE RCarrion. RII l OE:EA File (BSummers. OE)(2 letterhead) PUBLIC ' i ' .NRC Resident Inspector U.S. Nuclear Regulatory Commission , , l 11030 Hatch Parkway North- Baxley GA 31513 . ( , sh +9 ge / / . SENDTOPUBLICDOCUMENTR00M7[ [ [/ // YES OFFICE di! +pWP - Rll:0k / RilhtpS [ RI/ydR[ RI!:0[[ A L EVAN D 4/ N /98 I/ /98 4/ d[/ /98 4/ M /98- k/ N /9 0 DATE [0) k fES) h COPY? YES - YES YES No NO YES YES NO OfflCIAL RECORD M Y DOCUMENT NAME:H'I\\1980 PEN.ENF\\98209 HAT.DIR\\DISCLTR.HA V }}