ML20140H616

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Forwards Response to Jr Bass 840102 Request for Info Re 831227 Proposed Civil Penalty in Amount of $100,000.Listed Documentation,Including NRC 831227 Proposed Civil Penalty & Computer Printout Describing Violations,Encl
ML20140H616
Person / Time
Site: Hatch, 05000000
Issue date: 02/28/1984
From: Dircks W
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To: Thomas L
HOUSE OF REP.
Shared Package
ML20140C961 List: ... further results
References
FOIA-85-478 NUDOCS 8510230048
Download: ML20140H616 (4)
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(v The Honorable Lindsay Thomas United States House of Representatives Washington, DC 20515

Dear Congressman Thomas:

1 am pleased to respond to the questions raised by your constituent Mr. J. Richard Bass. Mr. Bass's January 2, 1984 letter asked several questions concerning the $100,000 civil penalty issued by the NRC on December 27, 1983 to the Georgia Power Company. Enclosure 1 contains the answers to Mr. Bass's questions. _

The Georgia Power Company paid the proposed civil penalty and responded to the ,

violations by letter dated January 25, 1984. Copies of (1) NRC's December 27, 1983 proposed civil penalty and the January 6,1984 correction letter, (2) Georgia Power's January 25, 1984 response, (3) the NRC's February 14, 1984 acknowledgement, and (4) a computer printout containing a brief description of the violations identified at Hatch Units 1 and 2 during the past two years are enclosed.

Sincerely, islgned)T. A.Rohd illiam J. Dircks Executive Director for Operations

Enclosures:

As stated 8510230048 851004 l PDR FOIA PDR JACOBS85-478

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FEB 2 8 1984 s

The Honorable Lindsay Thomas United States House of Representatives Washington, DC 20515

Dear Congressman Thomas:

I am pleased to respond to the questions raised by your constituent Mr. J. Richard Bass. Mr. Bass's January 2,1984 letter asked several questions concerning the $100,000 civil p,enalty issued by the NRC on December 27, 1983 to the Georgia Power Company. Enclosure 1 contains the answers to Mr. Bass's questions. _

The Georgia Power Company paid the proposed civil penalty and responded to the ,

violations by letter dated January 25, 1984. Copies of (1) NRC's December 27, 1983 proposed civil penalty and the January 6, 1984 correction letter, (2) Georgia Power's January 25, 1984 response, (3) the NRC's February 14, 1984 acknowledgement, and (4) a computer printout containing a brief description of the violations identified at Hatch Units 1 and 2 during the past two years are enclosed.

Sincerely, 751gned)T. A Rehm illiam J. Dircks Executive Director for Operations

Enclosures:

As stated l

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, s Enclosure 1

. Answers to the questions contained in Mr. Bass's January 2,1984 letter.

Question s According to the source of information the plant was fined $100,000 for not reporting something that could have developed into a very critical matter.

Answer The civil penalty was not based upon a failure to report information to the NRC. The civil penalty was based upon three violations. These violations 4 concerned the failure of .the operators at Hatch Unit 2 to follow procedures during a reactor shutdown on July 14, 1983. The NRC resident inspector entered the control room when the improper reactor shutdown was in progress. He asked several questions concerning the method being used to shut down the reactor.

The improper reactor shutdown was stopped and the reactor was then properly i shut down. Since the NRC resident was aware of the violation as it was -

l occurring, there was no failure to report information to the NRC in this instance. .

Question If the plant officials at Plant Hatch violated this regulation and were fined

$100,000, how do you or I know that they are not violating a number of other regulations?

Answer Companies such as Georgia Power which receive a license from the Nuclear i Regulatory Commission (NRC) to operate a nuclear power plant have the primary responsibility for safe operation of the facility. While no program can guarantee that every requirement is properly satisfied, the NRC has a program of site inspections to ensure that nuclear power plants are operated safely

and in compliance with regulatory requirements.

The NRC conducts daily inspections at the Hatch facility. These inspections are performed by two NRC resident inspectors who are assigned to the Hatch

facility. Additionally, inspectors from the NRC's Region II office in Atlanta also perform regular inspections at the Hatch facility. These inspections are supplemented by periodic special NRC inspections. This inspection program is typical of the inspections which are conducted at all operating commercial nuclear power plants.

Additionally, companies operating nuclear power plants, such as the Georgia Power Company, are required to make reports to the NRC. The Georgia Power Company has a good record of identifying and reporting violations as required j by NRC regulations.

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, , i Enclosure 1 ,

l Question I woul'd appreciate it very much if you could send me a list of the violations of the Hatch Plant which'are recorded by the Nuclear Regulatory Agency in Washington.

Answer The enclosed computer printouts. contain a brief description of the violations which have been identified at Hatch Units 1 ano 2 during the past two years. ,

These violations are more fully described in NRC inspection reports. These reports are available to the public in the Public Document Room located in the Appling County Public Library, 301 City Hall Drive, Baxley, Georgia 31563.

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Georgia Power Comoany ATTN: Mr. R. J. Kelly Executive Vice President P.O. Box 4545 Atlanta, GA 30302 Gentlemen:

SUBJECT:

PROPOSED IMPOSITION .0F CIVIL PENALTIES: EA 83-86 l IMPROPER SHUIDCWN (

REFERENCE:

INSPECTION REPORT NO. 50-366/83-23)

The enclosed Notice of Violation and Proposed Imoosition of Civil Denalties '

is. based upon the fincings of an NRC special inspection. The inspection examined the circumstances associated with the improper snutcown of Hatch, -

Unit 2, on July la, 1983.

This inspection was conducted by the NRC Resident and Region-based inspectors I on July 14 and 15, 1983 to review the circumstances of the improper shutcown of your Haten Unit 2 reactor on July 14, 1983 (the findings are set forth in Insoection Report No. 50-366/83-23). The detailed findings of this inspection were ciscussed at the site with facility management at the conclusion of the inspection. In addition, NRC safety concerns were discussed curing enforcement conferences held in the Region II office in Atlanta, Georgia, on July 21, 1983, at Plant Hatch on Novemoer 2, 1983, anc in the NRC offices in Wasnington, D.C. on Novemcer 14, 1983.

The findings of the inspection revealed that on July 14, 1983, while Unit 2 was Deing returned to service, a problem was experienced with main concenser vacuum. This problem required a recuction in reactor power to avoic a reactor shutcown. The on-shift coerators anc :neir supervisors recognized that tne normal method of reducing power would not achieve a sufficiently timely power reduction to avoid a scram. These incividuals, accarently strongly influenced by advice from two snif t tecnnical advisers, mace a " consensus cecision" to acnieve tne necessary -acic power recuction by cycassing both the Rod Worth Minimi:er and.the Roc Secuence Controller and oy selectively scramming incividual control "Ods, witnout an accroved procecure, from the Scram Time Test Panel wnicn is out of signt of, anc out of normal voice communications witn, tne reactor control console. The " consensus cecision" and tne resulting actions resulted in a control rod configuration tnat nad not been analyzed fMm a reactor safety viewooint.

CERTIFIED MAIL RETURN RECEIcT REGUESTED

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.g DEC 37 333 Georgia Power Company b To emphasi:e the level of unacceptability of the manner in wnicn tne reactor was controlled on July'14, 1983, and after consultation with the Director of the Office of Inspection and Enforcement, I have been autnorized to issue tne enclosed Notice of Violation and Proposed Imposition of Civil Penalties in :ne amount of One Huncred Thousand Dollars based uoan the findings of the first inspection. Three separate violations were identifiec and a separate civil

. penalty could have been assessed for each. However, since all three violations stemmed from the same fundamental proolem, the violations have been classified together as a Severity Level II problem (Supplement I) pursuant to the NRC Enfo'rcement Policy, 10 CFR Part 2 iocendix C. and a single civil penalty is proposed. 'The base penalty of $64,000 has ceen escalatec to $100,000 because of the' seriousness of tnis event, the number of Tecnnical Specifications that were violated, and the number of licensed ocerators and supervisors involvec.'

You are required to respond to the Notice and should follow the instructions-scecifiec tnerein when preparing your response. The secuence of events that ,

occurred on July 14, 1983 gives rise to a numcer of questions which the NRC believes must be address'ed by the Georgia Power Comoany. First, has the-Georgia Power Company's colicy of " safety first" been compromised by improper consideration by indivicual. members of the Plant Hatch staff of " keeping the plant running" without proper consideration of overall plant safety? Second,

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has the Georgia Power Company's policy of strict acherence to approved operating procedures ceen compromised at Plant Hatch by individual supervisors and managers and has an effective system of audits been implemented to assure compliance with tre policy? Third, is each operations supervisor fully aware'of nis/her indivicual responsibilities for making decisions? Fourtn, is the role and the autnority of the snift technical adviser clear to them and to each operations i supervisor? And finally, is each licensec operator aware of the importance of adherence to Technical Specifications and knowledgeable of aoproved intercretations of those Technical Soecifications? Your resconse to the attacned Notice of Vfclation and Proposed Imposition of Civil penalties snould accress, in detail, each of these cuestions witn carticular emonasis on assuring gooc vertical communications between Plant Haten in Eaxley, Georgia, and tne corporat'e offices in Atlanta, Georgia. It is further requestec tnat you crovice sufficient information On :nese scecific matters so snat we may conclude that your corrective actions will ce effective over tne long run.

Your reply to this letter, and the results of future insoectiors, will ce consicered in determining wnetner furtner action is accrocriati.

In accorcance with 10 CFR 2.790 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Feceral Regulations, a cooy of tnis letter and tne Notice :#

V1olation will be placed in tne NRC's Duolic Jocument R00m. To orotect tne privacy of tne individuals involvec, tre Letters of Reorimanc will not ce ,

olaced in tne Puolic Occument Room at tnis time.

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MC 3 7 - 1983 l Georgia Power Company ..

The responses directed.by tnis letter and the enclosure are not subject to the clearance procedures ofsthe Office of Management and Budget as required by tne Paperwork Reduction Act of 1930 PL 96-511.

Sincerely, b G James P. O'Reilly Regional Acministrator

Enclosure:

Notice of Violation and Procosed Imoosition of Civil Penalties cc w/ encl: '

J. T. Becknam, Vice President and .

General Manager-Nuclear Generation H. C. Nix, Site General Manager C. E. Selflower, Site QA Supervisor s

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0 NOTICE OF VIOLATION

. AND

' PROPOSED IMPOSITICN OF CIVIL DENALTIES Georgia power Company Docket No. 50-366 Ha:cn Unit 2 License No. NPF-2 EA 83-86 A special inspection conducted at Hatch Unit 2 on July 14 and 15, 1983 disclosed that wnile Unit 2 was being returned to service, a problem was experienced with main condenser vacuum. This problem required a reduction in reactor power to avoid a reactor snutdown. The on-shift operators and tneir supervisors recogni:ed snat the normal method of reducing cower would not

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acnieve a sufficiently timely power reduction to avoid a scram. These incivicuals, apoarently strongly influenced by advice from two shift tecnnical advisers, made a " consensus decision" to achieve tne necessary rapid power recuction cy bypassing both the Roc Worth Minimi:er and the Rod Secuence -

Controller and by selectively scramming indivicual control rods, without an approvec crocedure, from tne Scram Time Test Panel which is out of sight of, .

and out of normal voice communications with, the reactor control console. The

" consensus cecision" and the resulting actions resulted in a control rod configuration that had not been analyzed from a reactor safety viewpoint.

To emchasi:e the need to adhere to facility operations' and administrative procecures and to upgrade plant management control systems relating to licensed personnel shift tecnnical advisers, and suoervisor's decision-making resconsibilities, NRC procoses to impose a civil penalty in the amount of

$100.000 for tne matter of the improper reactor shutdown event' on July 14, 1982.

In accordance witn the General Policy and Procedure for NRC Enforcement Actions, 10 CFR Part 2 Apcendix C, and pursuant to Section 234 of the Atomic Energy Act of 1954, as amended, the violations and tne associated civil cenalties are set fortn below:

A. Tecnnical Specification 6.3.1 states that procedures snall be written, approvec and implementec for reactor coerations.

Contrary to the above, on July 14, 1983, control rod manipulations were conducted in violation of written and apor0ved crocecures, resulting in control rod patterns outsice those analy:ec for the Rod Drop Accioent described in FSAR cnacter 15.1.38. These maniculations were imorcoerly accomplished by scramming control rocs from tne scram time test canel (2H11-P610) and inserting cont-ol rocs using the Emergency In switen instead of the approved procecural .metnoc of inserting control rocs in notch control from tne main control panel (2H11-0603).

Examples of procecures wnich were not followed include:

1) Procedure, HNP-2-34, Rules for Performing Procedures, requires that veroatim comoliance is mancatory (?aragraoh 13.2) anc :nat, 'f an acoroved procedure cannot be performed as written, stop and cnange the crocecure. On July 14, 1983, Procedures HNP-2-9402 and HNP-2-9207 were not being followed vereatim nor was the event stopoec, and tne crocedures were not cnanged.

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, . .s-Notice of Violation 2) Procedure',' HNP-2-9402, Control Rod Scram Testing, requires, in step E.17, return.of tne scrammed rod to its initial position prior to scramming the next rod.s On July 14, 1983, the rods scrammed from tne time test panel (2H11-P610) were not being returned to their initial position prior to scramming the next rod.

3) Procedure, HNP-2-9207, Control Rod Movement, Paragraph 0.4 and Data Sheet i requires notch control for rods identified witn an asterisk.

This asterisk was on all rod groups moved during the shutdown of July 14, 1983, up to the point-wnere-the reactor manual scram was initiated, and tnese movements were not conducted by notch control.

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4) Procedure, HNP-2-9207, Control Rod Movement, Paragrach E.5 requires that rod movement be stopped if proper operatio.1 of the Rod Sequence Control System (RSCS) is not confirmed. On July 14, 1983, rod move-ment was continued even though the RSCS was circumvented and -

tnerefore inoperative.

B. Technical Specification 3.1.4.1 requires the Rod Worth Minimizer (RWM) to be coerable or a second licensed operator or otner qualified member of the technical staff to be present at the reactor console to verify compliance with the prescribed control rod pattern. -

Contrary to the above on July 14, 1983, after bypassing the RWM, a second perso^ did not verify compliance with the prescribed rod pattern. As a consequence, the rod insertion sequence was violated as evidenced by Control Rod 42-39 at notch 12 versus the required notch 48.

C. Technical Saecification 3.1.4.2 requires that the Rod Secuence Control System (RSCS) be operable in Operation Condition 1 when :nermal power is below 20%.

Contrary to the above, on July 14, 1983, unfle in Cperation Condition 1, with thermal power below 20%, the RSCS was not operational in tnat it was not performing its intended function of notch control.

The required notch control was circumvented by use of :ne Emergency In switch and the scram switenes on the scram time test canel.

Collectively, the above violations nave ceen evaluated as a Severity Level : ~.

proolem. (Supplement I)

Cumulative Civil Penalty - 5100,000 assessed equally among tne violations.

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Notice of Violation '

Pursuant to tne provision of 10 CFR 2.201, Georgia Power Comoany is herecy recuired to suomit to the Director, Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, and a copy to the Regional Acministrator, U.S. Nucl' ear Regulatory Commission, Region II, witnin 30 cays of tne date of nis Notice a written statement or explanation, including for each allegec violation: (1) acmission or denial of the alleged violations; (2) :ne reasons for tne violation if acmitted; (3) tne corrective steps wnich have been taken anc the results achieved; (4) the corrective steps wnich will be taken to avoic further violations; and (5) the date when full compliance will be achieved.

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, the response snall be suomittec uncer catn or affirmation.

Within the same time as provided for the response required above under 10 CFR 2.201, Georgia Power Company may pay the civil penalties in the cumulative amount of

$100,000 or-may protest imposition of tne civil cenalties in whole or in part by a written answer. Should Georgia Power Company fail to answer within the time specified, the Director, Office of Inspection and Enforcement, will issue an I

order imposing the civil penalties in the amounts proposed above. Should -

) Georgia Power Company elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, such answer may: (1) deny the violations 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 penalties should not be imposed. In addition to protesting the civil penalties in whole or in part, such answer may request remission or mitigation of the penalties.

In recuesting mitigation of the proposed penalties, the five factors accressed in Section IV(B) of 10 CFR Part 2, Appendix C should be adcressed. Any written answer in accorcance with 10 CFR 2.205 should be set forth separately from tne statement or explanation in reply pursuant to 10 CFR 2.201, but may incorocrate oy specific reference (e.g., citing cage and paragrapn numoers) to avoic repetition. Georgia Power Company's attention is directed to the other provisions of 10 CFR 2.205, regarding the procecure for imoosing a civil cenalty.

Upon failure to pay tne cumulative penalties cue, which have been subsequently determinec in accordance with the applicable.crovisions of 10 CFR 2.205, tnis matter may be referred to the Attorney General, and the penalties, unless compromised, remitted, or mitigatec may be collected by civil action pursuant to Section 234c of tne Act, 42 U.S.C. 2282.

FOR THE NUCLEAR REGULATCRY COMMISSION U[ /J James P. O'Reilly Ylt8 Regional Acministrator Datec at Atlanta, Georgia

nisj_7BayofDecemoer1983

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