ML20209C053

Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000.Violations Noted:Written Procedures for Equipment Control & Instrument Air Sys Not Implemented

ML20209C053
Person / Time
Site:	Hatch
Issue date:	04/08/1987
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20209B973	List: ML20209B970 ML20209C053
References
EA-87-027, EA-87-27, TAC-64455, TAC-64456, NUDOCS 8704280575
Download: ML20209C053 (4)

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NOTICE OF VIOLATION AND ,

PROPOSED IMPOSITID F0F CIVIL PENALTY Georgia Power Company Docket Nos. 50-321 and 50-366

-Hatch Units 1 and 2 License Nos. DPR-57 and NPF-5 EA 87-27 i

I During an augmented Nuclear Regulatory Commission (NRC) inspection of a loss of fuel pool water due to isolation of the air supply to inflatable seals in the fuel transfer canal, conducted on December 4-7, 1986, and an inspection conducted on December 20, 1986 - January 23, 1987, concerning the inoperability of the standby gas treatment system, violations of NRC requirements were identified.

In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), 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 violations and associated civil penalty are set forth below:

I. Violation Assessed a Civil Penalty Technical Specification 6.8.1.a requires that written procedures be estab-lished, 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 operation of the instrument air system.

Technical Specification 6.8.1.b requires that written procedures be estab-lished, 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 (MW0) 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 MWO 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 1 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 8704200575 B70408 PDR ADOCK 05000321 G PDR

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Notice of Violation on the transfer canal leak cetection 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.

D. Section 5.3.1.3 of Procedure 10AC-MGR-003-05, 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.)

II. Violation Not Assessed a Civil Penalty Unit 1 Technical Specifications 3.7.B.I.a requires a minimum of three (two in Unit 1 and one in Unit 2) of the four independent standby gas treatment system trains to be operable at all times when Unit 1 secondary containment integrity is required. With one of the Unit I standby gas treatment systems inoperable, Unit I reactor operation and fuel handling is permitted for seven days provided that all active components in the remaining operable standby gas treatment systems in each unit be demonstrated to be operable within four hours and daily thereafter. Further, if the inoperable Unit i standby gas treatment system is not made fully operable within the seven-day period, the Unit I reactor shall be shutdown and placed in the cold shutdown condition within the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and Unit 1 fuel handling operations shall be terminated within four hours.

Unit 2 Technical Specifications 3.6.6.1 requires two Unit 1 and two Unit 2 independent standby gas treatment subsystems be operable in Conditions 1, 2, and 3. With one subsystem inoperable, the inoperable subsystem must be restored to the operable status within seven days or Unit 2 must be in at least hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in cold shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Contrary to the above, from November 25, 1985 to March 11, 1986 during various times when Unit 1 secondary containment integrity was required or when Unit 2 was in Condition 1, 2, or 3, the 1A standby gas treat-ment subsystem (train) was inoperable for greater than seven days and actions were not taken to: (1) demonstrate all active components in the remaining operable standby gas treatment systems in Units 1 and 2 were operable within four hours and daily thereafter, (2) for Unit 1, shutdown the reactor and be in the cold shutdown condition within the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, (3) terminate Unit 1 fuel handling operations within four hours, or (4) for Unit 2, be in hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in cold shutdown within the l

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Notice of Violation .

following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The 1A train was inoperable because the associated charcoal filter bed had become wet and unable to perfonn its intended safety function for the removal of methyl iodine.

This is a Severity Level IV violation (Supplement I). ,

i Pursuant to the provisions of 10 CFR 2.201, Georgia Power Company is hereby I required to submit a written statement or explanation to the Director, Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, with a copy to the Regional Administrator, U.S. Nuclear Regulatory <

Connission, Region II,101 Marietta Street, N.W., Suite 2900, Atlanta, Georgia l 30323, within 30 days of the date of this Notice. This reply should include for each alleged violation: (1) admission or denial of the violation, (2) the reasons for the violation if admitted, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps which 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, the Director, Office of Inspection and Enforcement, may issue an order to show cause why the license should not be modified, suspended, or revoked or why such i other action as may be proper should not be taken. Consideration may be given to l 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 submitted under ]

oath or affirmation. l Within the same time as provided for the response required above under 10 CFR 2.201, Georgia Power Company may pay the civil penalty by letter addressed to the Director, Office of Inspection and Enforcement, with a check, draft, or money order payable to the Treasurer of the United States in the cumulative amount of Fifty Thousand Dollars ($50,000) or may protest imposition of the civil penalty in whole or in part by a written answer addressed to the Director, Office of Inspection and Enforcement. Should Georgia Power Company fail to answer within the time specified, the Director, Office of Inspection and Enforcement, will issue an order imposing the civil penalty in the amount proposed above. Should Georgia Power Company elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, such answer may: (1) deny the violation listed in this Notice in whole or in part, (2) demonstrate extenuating 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 in whole or in part, such answer may request remission or mitigation of the penalty.

In requesting mitigation of the proposed penalty, the five factors addressed in i Section V.B of 10 CFR Part 2, Appendix C (1986), should be addressed. Any written j answer in accordance with 10 CFR 2.205 should be set forth separately from the l statement or explanation in reply pursuant to 10 CFR 2.201 but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and j paragraph numbers) to avoid repetition. Georgia Power Company's attention is directed to the other provisions of 10 CFR 2.205 regarding the procedure for imposing a civil penalty.

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Notice of Violation Upon failure to pay the penalty due which has been subsequently 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 to Section 234c of the Act, 42 U.S.C. 2282.

FOR THE NUCLEAR REGULATORY COMMISSION Original signed by J. Nelson Grace J. Nelson Grace Regional Administrator Dated at Atlanta, Georgia this Efhday of April 1987

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