ML20133F535

Discusses Insp Repts 50-424/96-11 & 50-425/96-11 on 960929-1109,predecisional EC Conducted on 961219 & Forwards Notice of Violation,Conference Attendees,Nrc Slides & Licensee Presentation Matls

ML20133F535
Person / Time
Site:	Vogtle
Issue date:	12/31/1996
From:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Mccoy C GEORGIA POWER CO.
Shared Package
ML20133F538	List: ML20133F535 ML20133F545
References
EA-96-479, NUDOCS 9701140250
Download: ML20133F535 (6)

See also: IR 05000424/1996011

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December 31, 1996

EA 96-479

Georgia Power Company

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ATTN:

Mr. C. K. McCoy

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Vice President

Vogtle Electric Generating Plant

P. O. Box 1295

Birmingham AL 35201

SUBJECT:

NOTICE OF VIOLATION (NRC Inspection Report Nos. 50-424 and

50-425/96-11)

This refers to the inspection conducted during the period September 29 through

November 9. 1996, at your Vogtle Electric Generating Plant (VEGP).

The

inspection included a review of the facts and circumstarjces surrounding

installation deficiencies associated with certain safety-related motor coolers

as well as the program for maintaining this equipment.

The results of this

inspection were discussed with members of your staff on November 12. 1996 and

were formally transmitted to you by letter dated December 5. 1996.

In

addition, on November 27, 1996. you submitted Licensee Event Report

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No. 50-424/96-010 which addressed the inoperability of the Unit 1 safety

injection pump B (18 SIP) due to degraded motor cooling. An open

predecisional enforcement conference was conducted in the Region II office on

December 19, 1996, with you and members of your staff to discuss the apparent

violation, the root causes and corrective actions to preclude recurrence. A

list of conference attendees, a copy of your presentation materials, and NRC

slides are enclosed.

Based on the information developed during the inspection and the information

that was provided during the conference. the NRC has determined that

violations of NRC requirements occurred.

The violations are cited in the

enclosed Notice of Violation (Notice), and the circumstances surrounding them

are described in detail in the subject inspection report.

Violation A

involved the inoperability of the 18 SIP for a period greater than that

allowed by Technical Specifications (TS) due to inadequate pump motor cooling.

The inoperable condition existed from at least September 1991 when maintenance

was last performed on the 18 SIP motor coolers and may have existed for some

indeterminate period prior to that time.

Specifically, during the aeriod

October 23-25. 1996. you determined that the cooling flow through t1e two

motor coolers for this pump was degraded to approximately one-sixth of the

normai flow.

The condition was caused by improper installation of a gasket on

the inboard motor cooler which blocked all flow in that cooler and improper

installation of a plenum in the other motor cooler which reduced flow through

it by two-thirds.

In addition your subsequent investigation identified

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similarly reversed plenums on a Unit 2 Train A containment spray pump motor

cooler, a Unit 1 Auxiliary Component Cooling Water (ACCW) Pump 2 motor cooler,

and both Unit 2 ACCW Pump 1 motor coolers.

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9701140250 961231

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Violation B involves your failure to establish adequate procedures for the

disassembly and reassembly of the motor coolers during maintenance activities.

Although some guidance was 3rovided in the maintenance checklist to instruct

personnel to re-install gascets and plenums, the procedure was general and

provided insufficient specific guidance or precautions regarding gasket or

plenum orientation.

The 3rocedural deficiency was compounded by the lack of

detailed information in t1e vendor manuals and a lack of knowledge on the part

of plant personnel that the motor coolers were three-pass coolers instead of

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the assumed one-pass configuration.

Although the inoperability of the 1B SIP did not have a significant

consecuence to safety because it was not called upon to operate during this

Jerioc , the violations are nonetheless of significant regulatory concern

3ecause an important emergency core cooling system (ECCS) component was

inoperable for an extended period of time.

Although your safety analysis

indicates that the 1B SIP would have operated for approximately one-hour post-

accident, it would have likely failed following that period due to motor

bearing failure resulting in its unavailability for subsequent accident

mitigation.

The NRC also recognizes that the overall safety function was not

lost in this case due to the availability of the 1A SIP.

However, as you

described at the conference, there were periods during the time in which the

18 SIP was inoperable that the 1A SIP was out of service for maintenance or

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testing: thus, the plant was operated for short periods of time in a condition

which was prohibited by TS.

Therefore, these violations are classified in

the aggregate in accordance with the " General Statement of Policy and

Procedures for NRC Enforcement Actions" (Enforcement Policy). NUREG-1600, as a

Severity Level III problem.

In accordance with the Enforcement Policy, a base civil penalty in the amount

of $50,000 is considered for a Severity Level III problem.

Because your

facility has been the subject of escalated enforcement action within the last

two years the NRC considered whether credit was warranted for Identification

and Corrective Action in accordance with the civil penalty assessment process

described in Section VI.B.2 of the Enforcement Policy. The NRC concluded that

credit was warranted for Identification because your staff identified the

violations. The attentiveness and questioning attitude of the plant equipment

o)erator responsible for identifying and pursuing temperature differences in

t1e two motor coolers for the 1B SIP and the site engineer who identified the

possibility of reversing the motor cooler plenums are particularly noteworthy.

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With regard to consideration for Corrective Action, at the conference you

stated that your immediate and long term corrective actions included:

(1) proper installation of the gasket and plenum on the 1B SIP: (2) inspection

and correction of other ECCS motor coolers for reversed plenums:

(3) development of a plant procedure which provides detailed instruction for

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correct disassembly and reassembly of motor coolers and revision of the

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existing maintenance checklist to reference the new procedural requirements:

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(4) inspection and correction of ACCW motor coolers plenum installation

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deficiencies: (5) training of maintenance personnel scheduled in January 1997

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and continuing as part of the Continuing Training Program: (6) establishment

of concurrent, dual verification of gasket and plenum installation; and

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(7) initiation of a review to determine the appropriate methodology for

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periodic functional testing of heat exchangers.

Based on the above. the NRC

determined that your corrective actions were prompt and comprehensive, and

credit was warranted for this factor.

Therefore. to encourage prompt identification and comprehensive corrective

action for violations. I have been authorized. after consultation with the

Office of Enforcement, not to propose a civil penalty in this case.

However,

significant violations in the future could result in a civil penalty.

You are required to respond to this letter and should follow the instructions

specified in the enclosed Notice when preparing your response.

In addition.

at the conference you stated that efforts have been initiated to determine the

appropriate functional testing criteria for heat exchangers.

Due to the

importance of this effort in assuring future operability of heat exchangers

for safety-related equipment we request that your response include a detailed

description and proposed schedule for your actions in this regard.

The NRC

will consider your response, in part, to determine whether further enforcement

action is necessary to ensure compliance with regulatory requirements.

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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice." a copy of

this letter, its enclosures, and your response will be placed in the NRC

Public Document Room (PDR).

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Sincerely.

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Stewart D. Ebneter

Regional Administrator

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Docket Nos. 50-424, 50-425

License Nos. NPF-68. NPF-81

Enclosures:

1.

Notice of Violation

2.

Conference Attendees

3.

NRC Slides

4.

Licensee Presentation Material

cc w/encls:

J. D. Woodard

Senior Vice President

Georgia Power Company

P. O. Box 1295

Birmingham. AL 35201

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cc w/encls:

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cc w/encls (Cont'd):

J. B. Beasley

General Manager Plant Vogtle

Georgia Power Company

P. 0. Box 1600

Waynesboro. GA 30830

J. A. Bailey

Manager-Licensing

Georgia Power Company

P. O. Box 1295

Birmingham. AL 35201

Jim Hurt. Director

Consumers' Utility Counsel Division

Governor's Office of Consumer Affairs

2 M. L. King Jr. Drive

Plaza level - East: Suite 356

Atlanta. GA 30334-4600

Office of Planning and Budget

Room 6158

270 Washington Street. SW

Atlanta, GA 30334

Office of the County Commissioner

Burke County Commission

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Waynesboro, GA 30830

Harold Reheis. Director

Department of Natural Resources

205 Butler Street SE. Suite 1252

Atlanta, GA 30334

Thomas Hill, Manager

Radioactive Materials Program

Department of Natural Resources

4244 International Parkway

Suite 114

Atlanta. GA 30354

Attorney General

Law Department

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132 Judicial Building

Atlanta GA 30334

cc w/encls:

(Cont'd on Page 5)

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cc w/encls (Cont'd):

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Thomas P. Mozingo

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Manager of Nuclear Operations

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Oglethorpe Power Corporation

2100 E. Exchange Place

Tucker, GA 30085-1349

Charles A. Patrizia. Esq.

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Paul, Hastings, Janofsky & Walker

10th Floor

1299 Pennsylvania Avenue

Washington. D. C.

20004-9500

Steven M. Jackson

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Senior Engineer - Power Supply

Municipal Electric Authority

of Georgia

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1470 Riveredge Parkway NW

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Atlanta, GA 30328-4684

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Distribution w/encls:

PUBLIC

JTaylor. EDO

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JMilhoan. DEDR

GTracy. OEDO

SEbneter RII

LChandler. OGC

JGoldberg. OGC

RZimmerman. NRR

EJulian. SECY

BKeeling. CA

Enforcement Coordinators

RI. RIII. RIV

JLieberman. OE

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OE:EA File (BSummers) (2 letterhead)

MSatorius. OE

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EHayden. OPA

GCaputo. OI

EJordan. AE00

HBell. OIG

CEvans RII

Buryc. RII

KClark. RII

RTrojanowski, RII

EMerschoff. RII

AGibson, RII

PSkinner. RII (IFS Action Required)

Rcarrion. RII

HBerkow. NRR

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LWheeler. NRR

NRC Senior Resident Inspector

U.S. Nuclear Regulatory Commission

8805 River Road

Waynesboro GA 30830

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