ELV-00698, Responds to Violations Noted in Insp Repts 50-424/89-14 & 50-425/89-15.Corrective Actions:Engineering Personnel Instructed That Legibility & Reproducibility of as-built Includes Entire as-built Notice Page

Responds to Violations Noted in Insp Repts 50-424/89-14 & 50-425/89-15.Corrective Actions:Engineering Personnel Instructed That Legibility & Reproducibility of as-built Includes Entire as-built Notice Page

ML20246K919
Person / Time
Site:	Vogtle
Issue date:	07/12/1989
From:	Hairston W GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ELV-00698, ELV-698, NUDOCS 8907180297
Download: ML20246K919 (7)

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' 1530n J.J. . l July 12, 1989 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 PLANT V0GTLE - UNITS 1, 2 NRC DOCKETS 50-424, 50-425 OPEPATING LICENSES NPF-08, NPF-81 REPLY TO A NOTICE OF VIOLATION Gentlemen:

In accordance with the provisions of 10 CFR 2.201, Georgia Power Company (GPC) submits the enclosed information in response to NRC Inspection Report Numbers 50-424/89-14 and 50-425/89-15 which concern the inspection conducted by Mr. J.

F. Rogge and Mr. R. F. Aiello of the NRC Region II staff on March 18 - May 5, 1989. A copy of this response is being provided to the NRC Region II office for review.

In the enclosure, transcription of the NRC violation precedes the GPC response.

Should there be any questions in this regard, please contact this office at any time.

Sincerely, gt). . d '*

W. G. Hairston, III WCG,III/JH/gm

Enclosure:

1. Violation 50-424/89-14-01 and 50-425/89-15-01 with GPC Response xc (w): Georgia Power Company Mr. C. K. McCoy Mr. G. Bockhold, Jr.

Mr. R. M. Odom Mr. J. P. Kane NORMS 1

U. S. Nuclear Regulatory Commission Mr. S. D. Ebneter, Regional Administrator Mr. J. B. Hopkins, Licensing Project Manager, NRR Mr. J. F. Rogge, Senior Resident Inspector, Vogtle 8907180297 890712 gDR ADOCK0500g4 /l t j

L ENCLOSURE PLANT V0GTLE - UNITS 1, 2 NRC DOCKETS 50-424, 50-425 OPERATING LICENSES NPF-68, NPF-81 NRC NOTICE OF VIOLATION 50-424/89-14-01, 50-425/89-15-01 AND GPC RESPONSE "10 CFR Part 50, Appendix B, Criterion V, states activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordare with these instructions, procedures, or drawings.

Technical Specification 6.7.1.a requires that written procedures be established, implemented, and maintained covering activities delineated in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Contrary to the above, six examples were identified where the licensee failed to appropriately establish or implement procedures as follows:

1. On April 28, 1989, following an NRC inspection of a major portion of the control rooms and TSC drawings, the inspector identified that administrative procedure 00101-C, " Drawing Control," Step 3.4.4, and engineering procedure 50009-C, "As-Built Notices," Step 4.6.3, were not implemented in that the primary safety-related drawing's as-built notices were not ensured of drawing legibility prior to distribution.

2. On April 2,1989, the inspector identified that operations procedure 12004-C, " Power Operation," Steps 4.1.3.g and 4.1.4, were not implemented in that the licensee failed to open all four Unit 2 bypass feed isolation valves and failed to stabilize #3 Steam Generator level prior to placing the bypass feed regulation valve in automatic.

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3. On April 3,1989, following a feedwater isolation, the licensee identified tlat startup test procedure 2-6AB-01, " Dynamic Automatic Steam Dump Control, " was not adequately established in that attachment 10.5 incorrectly specified the wrong polarity for a test input signal which resulted in six steam dumps opening fully. This procedure error was identical to an error discovered during the Unit 1 startup test program.

4. On April 7,1989, following a feedwater isolation on Unit 2, the licensee identified that a failure to implement procedure 12004-C, '/ower Operation," Step 4.1.3, had occurred in that long-cycle feedvater recirculation cleanup was not secured which resulted in all four steam generators being cross connected. Thic condition lasted until a level j imbalance resulted in a feedwater isolation.

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5. On March 26, 1989, the licensee identified a failure to a.dequately establish procedures 13105-1 and 13105-2, " Safety Injection System," in that the procedure for filling accumulators resulted in the inoperability of the safety injection flow path during Mode 3 operation. This procedure was utilized on nine occasions on Unit 1 and one occasion on Unit 2.  ;

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..- ,v ENCLOSLRE (CONTINUED)

PLANT V0GTLE - UNITS 1, 2 NRC DOCKETS 50-424, 50-425 OPERATING LICENSES NPF-68, NPF-81 NRC NOTICE OF VIOLATION 50-424/89-14-01, 50-425/89-15-01 AND GPC RESPONSE 6 On December 8,.1988, with Unit 1 at 100% power, the inspector identified that the licensee had failed to esta' lish o an adequate procedure 12004-C,

" Power Operation," Step 4.1.37, for placing AMSAC equipment in operation in that the procedure specified the equipment .in service at 60% when the design basis specifies 40%. AMSAC equipment is required by 10 CFR 50.62 to automatically initiate the auxiliary feedwater system and initiate a turbine trip under conditions indicative of an anticipated transient without scram.

,This is a Severity Level IV violation (T1pplement I)."

Response to Violation 50-424/89-14-01 and 50-425/89-15-01 Admission or Denial of Alleged Violation:

The violation occurred as stated.

Reason for the Violation:

Example 1 - Legibility of As-Built Notices The cause of the violation was personnel error. Engineering Procedure 50009-C, "As-Built Notices," requires that the responsible ' engineer ensure the As-Built Hotice (ABN) supplement is legible and reproducible. Administrative Procedure 00101-C, " Drawing Control," requires that the document control supervisor ensure drawing legibility prior to distribution. These required procedure steps were not fully implemented.

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PLANT V0GTLE - UNITS 1, 2 NRC DOCKETS 50-424, 50-425 OPERATING LICENSES NPF-68, NPF-81 NRC NOTICE OF VIOLATION 50-424/89-14-01, 50-425/89-15-01 AND GPC RESPONSE Example 2 - Transfer from Auxiliary Feedwater to Main Feedwater The cause of the violation was personnel error. The Balance of Plant (BOP) and Steam Generator Water Level Operator knew the transfer from Auxiliary Feedwater (AFW) to main feedwater was a sensitive evolution and thought their method would provide a smoother transfer. Step 4.1.3.g of Procedure 12004-C was signed by the previous shift, when the Bypass Feedwater Isolation Valves (BFIVs) were opened. Due to leakage past the closed Feedwater Regulation Valve (FRVs), the shift re-closed the BFIV's and did not annotate Step 4.1.3.g to indicate the BFIV's had been re-closed. The on-coming operating crew also failed to identify this procedural error.

Example 3 - Testing of Steam Dumps The cause of the violation was an inadequate review of Procedure 2-6AB-01 to ensure that proper connections were made for injecting test signals or modifying control circuits. In addition, Unit 1 Startup Tests were not adequately reviewed for inclusion of problem resolutions, where applicable, into Unit 2 Startup Test Procedures.

Example 4 - Failure to Secure from Long-Cycle Recirculation The operating crew on April 6,1989, failed to remove long cycle recirculation from service by Procedure 13615-2, Section 4.2.4 or Procedure 12004-C, Step 4.2.3. Both procedures required closing the manual isolation valves for the steam generators. The shift crew that removed long-cycle from service informed the on-coming crew that long-cycle was secured; hov'ever, they did not inform them that it was not removed from service per procedur 3. It was assumed by subsequent shifts that long-cycle was secured by procedure and the manual isolation valves were shut. This assumption was supported by the working copy of Procedure 12004-C, which had the removal steps for long-cycle initialled off. Actually, the removal of long-cycle had occurred on a previous attempt to transfer from AFW to main feedwater, but problems encountered had forced the operating crew to back out of the procedure and re-establish long-cycle. The operating crew failed to annotate the sign-off steps in Procedure 12004-C to indicate that long-cycle had been re-established.

Example 5 - Failure to Maintain Safety Injection Operable Procedures 13105-1 and 13105-2, " Safety Injection System," provided instructions for filling accumulators, but restrictions for filling while in Mode 3 were confusing and inadequate. Procedure 12002-C, " Unit Heat Up to Normal Operating Temperature and Pressure (Mode 4 to Mode 3)" did not require accumulator fill to be completed prior to Mode 3 erstry.

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' ENCLOSURE'(CONTINUED)

PLANT V0GTLE -_ UNITS 1, 2

.NRC DOCKETS 50-424,-.50-425'

' 0PERATING LICENSES NPF-68, NPF-81 NRC NOTICE'0F VIOLATION 50-424/89-14-01,- 50-425/89-15-Ol AND_ GPC' RESPONSE Example 6 - Failure to Ensure AMSAC was Available Procedure 12004-C, Revision 14, required verification- that AMSAC was in service at 60% power to ensure that the feedwater system configuration for full _ power operation (i.e., second Condensate Pump and Main Feed Pump placed in service) was established prior to placing AMSAC.in service. There were concerns regarding AMSAC response following feed flow perturbations that might.

occur _while starting the second Condensate Pump or Main Feed Pump AMSAC'was a new retrofit system with no operating record and operators were unsure of proper AMSAC operation. . Specification of 60% power instead of 40% power for placing AMSAC in service was an error in understanding of the design basis.

- Corrective Steps'Which Have Been Taken and Results Achieved:

Exanple l '-' Legibility .of As-Built Notices Engineering personnel were instructed that the legibility and reproducibility of the "As-Built" includes the entire ABN page, not just the clouded portion of the ABN. . Document Control personnel were counseled on not accepting an "As-Buil.t" which is not thoroughly legible and reproducible. The primary safety related drawings are in the normal revision cycle for incorporating the ABNs. The' expected completion date to incorporate the ABNs is September 30,

- 1989.

Example 2 - Transfer from Auxiliary Feedwater to Main Feedwater The involved operators were counseled. The need for procedure compliance was emphasized. The operators and Shift Supervisor in, Ived in reclosing the BFIVs were counseled regarding the proper methodology for' backing out of a procedure and annotating previously performed steps that were " undone." A Night 0rder was issued by tha Operations Manager which detailed the proper method for undoing a previously completed procedureal (sign off) step.

- Example 3 - Testing of Steam Dumps l' A Test Change Notice (TCN) to Procedure 2-6AB-01 to reverse the polarity of the signal as required, was generated. I&C foremen or supervision reviewed all remaining Unit 2 startup tests which inject a signal or modify a control circuit to verify that' proper connections were specified. A review was conducted of the corresponding Unit 1 startup tests for all remaining Unit 2 tests to identify any problem resolutions that should be incorporated into the Unit 2 test procedures. All identified resolutions were incorporated.

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ENCLOSURE (CONTINUED)

PLANT V0GTLE - UNITS 1, 2 NRC DOCKETS 50-424, 50-425 OPERATING LICENSES NPF-68, NPF-81 NRC NOTICE OF VIOLATION ~ 50-424/89-14-01, 50-425/89-15-01 AND GPC RESPONSE

. Example 4 - Failure to Secure from Long-Cycle Recirculation Supervisors.and operators involved in removing long-cycle recirculation were counseled on the need for procedural compliance. Operators and Shift Supervisors involved in re-establishing long-cycle recirculation were counseled regarding the proper methodology for backing out of a procedure and annotating previously performed steps that were " undone." A Night Order was issued by the Operations Manager which detailed the proper method for undoing a previously completed procedural (sign off) step. Supervisors and operators involved were counseled on the need for detailed turnover to an on-coming shi f t. A copy of the associated LER 50-425/89-015 was placed in the Operations Reading Book to ensure licensed operators and supervisors are awart of the event and the need for procedure compliance and detailed turnovers.

Example 5 - Failure to Maintain Safety Injection Operable Procedure 12002-C was revised to include a sign off ensuring that Safety Injection (SI) accumulator fill is completed prior to Mode 3 entry.

Procedures 13105-1 and 131005-2 were revised to incorporate precise caution statements which direct operators not to perform the associated low RCS pressure accumulator fill process while in Mode 3, and additionally, were revised to include a new section which allows SI accumulators to be filled at low RCS pressure while in Mode 3 without rendering both SI pumps inoperable.

(This section provides required guidance for the fill of SI accumulators that become out of specification for level or boron concentration while at low RCS pressure in Mode 3.) A co)y of the associated LER 50-425/89-011 was placed in the Operations Reading Boo < to ensure licensed operators and supervisors are aware of the event. " Lessons Learned" from the event were incorporated into the Operator Requalification Program.

Example 6 - Failure to Ensure AMSAC was Available AMSAC has been placed in service and is operating on Unit 1 and 2. Procedure 1 12004-C was revised to require verification that AMSAC is in service above 40% i power (instead of 60%). Procedures 17005-1 and 17005-2 have been revised to provide guidance for the removal of AMSAC from service when it is determined to be inoperable. Guidance is also provided for contingency actions, including notifications to plant management, when AMSAC is inoperable. Steps were incorporated for returning AMSAC to service when restored to operable status. Engineering Procedures 54804-1 and 54804-2 have been revised to include quarterly surveillance testing of AMSAC and a revision is scheduled prior to refueling to include appropriate refueling surveillance. Operation of AMSAC circuitry and associated logic have been incorporated into the Licensed Operator Requalification Program.

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'4 ENCLOSURE (CONTINUED) h PLANT V0GTLE - UNITS 1, 2 NRC DOCKETS 50-425, 50-425 OPERATING LICENSES NPF-68, NPF-81 NRC NOTICE OF VIOLATION 50-424/89-14-01, 50-425/89-15-01 AND GPC RESPONSE Corrective Steps Which Will Be Taken to Avoid Further Violations:

It is believed that the aforementioned actions taken should prevent recurrence of these examples of the violation.

Date When Full Compliance Will Be Achieved:

1 Full compliance is expected to be achieved for Example 1 by September 30, 1989.

p Full compliance was achieved for Examples 2, 3, 4, 5 and 6 on April 7, May 9, April 28, May 11 and June 12, 1989, respectively.

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