ML20137F583

Ack Receipt of 960923 Response to Notice of Violation Issued on 960830 Re Activities Conducted at Plant Hatch Facility. Informs That NRC Will Evaluate Denial to Violation

ML20137F583
Person / Time
Site:	Hatch
Issue date:	03/12/1997
From:	Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Sumner H GEORGIA POWER CO.
References
NUDOCS 9704010149
Download: ML20137F583 (9)

Text

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March 12, 1997 i

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Georgia Power Company i ATTN: Mr. H. L. Sumner..Jr.  ;

Vice President. Plant Hatch ,

Nuclear Operations i P.O. Box 1295  !

Birmingham. AL 35201

SUBJECT:

NRC INTEGRATED INSPECTION REPORT 50-321/96-10, 50-366/96-10

Dear Mr. Sumner:

Thank you for your response of September 23. 1996, to our Notice of Violation (Notice) issued on August 30, 1996, concerning activities conducted at your Plant Hatch facility. We stated in our letter of October 2,1996, that we would evaluate your denial to the violation and notify you of the results of this evaluation at a later date.

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We have reviewed your response to Violations B and C of NRC Integrated Inspection Report 50-321/96-10, 50-366/96-10. Violation B (96-10-05) specifically identified a condition where a deficient alarm for the 10 600 volt AC safety related bus was not promptly corrected. The deficiency was ident'ified on April 18, 1995, and was not corrected as of August 3. 1996.

As a result, control room personnel received an erroneous alarm on the safety-related 600V AC Bus 10. on July 25. 1996.

In your response to Violation B. you denied that a violation occurred as stated. You stated that the fact that-a deficient condition reoccurs before -

corrective actions can be implemented is not a violation of regulatory l requirements. You further stated that the problem was not operationally or l safety significant and correct 1ve action was assigned a low priority relative i .to other work activities.

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! Violation C (96-10-02) specifically identified a condition where a four-hour L reporting requirement was not met on June 29. 1996, in that a maintenance deficiency was discovered that made the High Pressure Coolant Injection system -

(HPCI) inoperable. A report was not made to the NRC in accordance with 10 CFR

50.72.(b)(2)(iii)(D) until July 3. 1996.

In your response to Violation-C. -you denied that a violation occurred as 4

! stated. You stated that the event which made the Unit 1 HPCI system

. inoperable on June 29. 1996. was reported within four hours of the event being  ;

determined to be reportable. Your conclusion was based upon guidance provided-1 in NUREG-1022. Supplement No.1. Licensee Event Report System. February 1984.  !

1 You stated per the guidance given in the NUREG. the "reportability date" is

"when someone decides or " discovers' that the event is reportable". Using I l this guidance referencing "reportability date", you additionally stated that j the applicable reporting requirements were met and no violation occurred.  ;

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GPC 2 ,

After careful consideration of the bases for your denial of the aforementioned  !

violations and an additional review conducted by the Region II staff, we are  :

withdrawing Violation B. However, we have concluded, for reasons presented in the enclosure to this letter, that Violation C occurred as stated in the .

Notice of Violation. Therefore, in accordance with 10 CFR 2.201(a).. please i submit to this office within 30 days of the date of this letter a written statement describing steps which have been taken to correct Violation C and  :

the results achieved. corrective steps which will be taken to avoid further  !

violations, and the date when full compliance will be achieved. i We will examine the implementation of your actions to correct this violation i during future inspections. j The response directed by this letter and its enclosure are not subject to the clearance 3rocedures of the Office of Management and Budget as required by the Paperwork leduction Act of 1980. Pub. L No.96-511. l In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice." a copy of this letter, its enclosure, and your response will be placed in the NRC Public Document Room (PDR).

We appreciate your cooperation in this matter.

Sincerely.

(Original signed by Jon R. Johnson)

Jon R. Johnson. Director Division of Reactor Projects Docket Nos.: 50-321 and 50-366 License Nos.- DPR-57 and NPF

Enclosure:

Evaluation and Conclusion (Violation 96-10-02) cc w/ encl: P. Wells General Manager. Plant Hatch Georgia Power Company P. O. Box 439 Baxley. GA 31513 l- i l

D. M. Crowe l f Manager Licensing - Hatch Georgia Power Company P. O. Box 1295  !

Birmingham. AL 35201 l

! cc w/ encl cont'd: (See Page 3)'  !

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GPC 3 i

cc w/ encl: Continued  !

Ernest L. Blake Esq. l

-Shaw, Pittman, Potts and-  !

Trowbridge.  !

2300-N Street, NW i i Washington. D. C. 20037 l

l Charles H. Badger .

Office of Planning and Budget.  :

Room 610 270 Washington Street. SW'  :

. Atlanta. GA 30334 i l Harold Reheis. Director  ;

Department of Natural Resources -

205 Butler Street, SE. Suite 1252 l Atlanta GA 30334 -

s l Thomas Hill, Manager l Radioactive Materials. Program

Department of Natural Resources 4244 International Parkway Suite 114 1 Atlanta, GA 30354 Chairman Appling County Commissioners County Courthouse l Baxley, GA 31513 l

l Thomas P. Mozingo Manager of Nuclear Operations j Oglethor)e Power Corporation  :

2100 E. Exchange Place Tucker, GA 30085-1349

! Charles A. Patrizia. Esq.

l. Paul. Hastings, Janofsky & Walker

10th Floor l- 1299 Pennsylvania Avenue Washington, D. C.

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20004-9500 Distribution w/ encl:

K. N. Jabbour, NRR P. H. Skinner. RII R. P. Carrion, RII W. P. Kleinsorge. RII

, M. E. Ernstes, RII l PUBLIC

Distribution w/ encl' cont *d

(See Page 4) i

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GPC 4  !

Distribution w/ encl: Continued NRC Senior Resident Inspector  !

U.S. Nuclear Regulatory Comission i 11030 Hatch Parkway North '

Baxley, GA 31513 i i

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EVALUATION AND CONCLUSION (Violation 96-10-02)  !

On August 30. 1996. A Notice of Violation (Notice) was issued for a violation  !

identified during a routine NRC inspection. Georgia Power Company (GPC)  !

responded to the Notice on September 23. 1996. In the response. GPC denied  !

the violation occurred as stated in the Notice. The NRC's evaluation and  ;

conclusion regarding the licensee's response are as follows:  !

Restatement of Violation  ;

10 CFR 50.72 (b)(2)(iii)(D). four-hour reports, states in part that, tha  !

licensee shall notify the NRC as soon as practical and in all cases, within l four hours of...any event or conditi^n that alone could have prevented the i fulfillment of the safety function of structures, or systems that are.needed i to mitigate the consequences of an accident.

l Contrary to the above a four-hour reporting requirement was not met on June 29. 1996. During system surveillance activities to verify operability of  :

the Unit 1 high 3ressure coolant injection system, a maintenance deficiency r was discovered tlat made the system inoperable and a report was not made until '

11:14 a.m. on July 3. 1996. '

Summary of Licensee's Violation Resoonse l

The licensee denied that the violation occurred as stated in the Notice. The i licensee stated that the event which made the Unit 1 High Pressure Coolant i Injection (HPCI) system inoperable on June 29, 1996. was reported within four  !

hours of the event being determined to be reportable as required by 10 CFR 50.72 (b)(2)(iii)lD). Per the guidance given in NUREG-1022. Supplement No.1.

" Licensee Event Report System." February 1984, the "reportability date" is when someone decides or discovers that the event is reportable [Page 22, Item 3 of the answer to question 14.5]. The subject event was reported within four hours of GPC personnel determining it was reportable per the requirements of 10 CFR 50.72 (b)(2)(iii)(D). The licensee concluded that the applicable reporting requirements were met and no violation occurred.

The Unit 1 HPCI system was inoperable for planned maintenance on the oil system. a condition not reportable per 10 CFR 50.72(b)(2)(iii)(D). On June 29. 1996, prior to restoring system operability following completion of the oil system maintenance, a valve failed. This failure, which was unrelated to the oil system maintenance, would have rendered the system inoperable:

however, personnel did not immediately re) ort this event because the system l was already considered inoperable. The C R does not clearly state this event l was reportable regardless of the status of the system upon discovery of the '

l valve failure. Only after GPC engineers reviewed additional guidance, j

! provided in NUREG-1022. Sup)lement No. 1 [Section II " Questions and Answers -

from the LER Workshops." Su)section 7.0, cuestions and answers 7.9 and 7.10.

page 11] as part of a routine review of ceficiency cards, was it determined l- this event was reportable. i t

I.

i Enclosure

,/ ,C 3

3. The "Reportability" Date when someone decides or

" discovers" that the event is reportable.

~ 4. The Report Date when the LER is submitted (entered in Item 7).

If there is a significant length of time (>30 days) between event date and either the discovery or "reportability" date.

the reason for the delay should be discussed in the LER text.

The review indicated that operations supervision had the responsibility to review this issue in a timely manner but failed to do so. It was stated in

.NRC Integrated Inspection Report 50-321/96-10, 50-366/96-10, section 03.1, subsection b, that the Superintendent on Shift (SOS) is one of the individuals identified as being responsible for making the report. This responsibility is described in procedure 00AC-REG-001-05 Federal and State Reporting Requirements, Revision 4. This section of the report further stated that a member of the Nuclear Safety and Compliance (NSAC) staff was always on call to assist personnel in making detailed analyses for reportability. In this case.

operations )ersonnel did not solicit NSAC assistance. Hence, the NRC staff concludes tlat Operations: supervision failed to take prompt reportability actions for the event until the reporting deficiency was discovered by NSAC several days later.

The review of NUREG/BR-0195. Rev. 1. Chapter 7, Section 7.10. Violations of Reporting Requirements, indicated "A licensee normally will not be cited for failing to report an issue if the licensee was not aware of the information that was reportable. However, a licensee should be cited for failure to report an issue if the licensee knew of the information to be reported, but did not recognize that a report was required. (Ignorance of the reporting requirement is not an excuse)."

NRC Conclusion For the above stated reasons, the NRC staff concludes that Violation C (96-10-02) occurred as stated.

Enclosure