ELV-03148, Requests That Supplemental Response to NRC Demand for Info Be Withheld from Placement in PDR Per 10CFR2.790 Until Decision Is Made in Matter & Responds to Questions Not Previously Addressed
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October 1, 1991.
INFO TI N l
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c ELV-03148 l
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j Docket Nos. 50-424 1
50-425 i
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U.
S. Nuclear Regulatory Commission
-Washington, DC 20555 3
ATTN: ~ Mr. James H. Sniezek l
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t Gentlemen:
I VOGTLE ELECTRIC GENERATING PLANT t
SUPPLEMENTAL RESPONSE TO NRC DEMAND FOR INFORMATION i
s.
On September 19, 1991, the Georgia Power Company ("GPC") met with the NRC at Region-II'for'an enforcement conference addressing an event that occurred at the Vogtle Electric Generating Plant ("VEGP") in October 1988.
We appreciated the open and. frank exchange of information concerning the event and N
j' the opportunity to respond to questions raised by our August 28, f
g 1991 response (the "GPC Response") to the NRC's June 3, 1991 Demand for Information on this matter.
We request that this g%
Supplemental Response be withheld from placement in the Public Document Room pursuant to 10 C.F.R. $ 2.790 until a decision is i
made in this'. matter.
J l-During the enforcement conference, the NRC raised two i
i questions not previously addressed in the Demand for Information or'the GPC Response.
First, based upon information supplied to the NRC by individual operators involved in this event, you questioned whether the operating crew had exhibited adequate i
integrated operations' control, and whether the On shift Operations Supervisor and Unit Shift Supervisor had exhibited satisfactory " command and control" over unit operations.
- Second,
.the NRC staff members present asked GPC to submit a clarification ofithe use'of the words "should" and "shall" in our internal E
guidance documents issued in October 1989 and August 1991 addressing the issue.of voluntary entry into technical 4
l 9611040016 960827 PDR FOIA KOHN95-211
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Mr. James H. Sniezek
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October 1, 1991 l
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j-specification (" Tech Spec")~ limiting conditions for operation l
("LCO") requiring immediate actions.
This letter is intended to i
j respond to these two matters.
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I.
Introduction
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As discussed in our meeting, the GPC Response to the j
Demand for Information with respect to the October 11-12, 1988 i
i event did not attempt to address'the matter af operator " command and control."
To address the concern raised in the meeting, and
.to satisfy myself that performance in this area was adequate, l
following the enforcement conference I initiated a review of thi
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j issue.
This included a review of the relevant logs and j
-activities of the night shift of October 11-12, as well by thw
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earlier responses submitted to the NRC by the on Shift Ope-0"
-s Supervisor ("OSOS") and the Unit Shift Supervisor ("USS*;
t' she i
personal statement of the Support Shift Supervisor ("SSS").
i also personally interviewed the OSOS and USS.
The Reactor
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Operator ("RO") involved in the relevant operation was also
- interviewed and I reviewed his responses.
Based on this evaluation, I am confident that proper " command and control" was exercised on this shift.
During the enforcement conference, you pointed to several statements in the operators' responses potentially indicating l_
that the operators were not fully aware of all relevant operations being conducted on the night shift.
As I indicated during the enforcement conference, I did not believe-that such a reading would reflect the operators' intent.
In general, these operators acknowledge that, on October 12, 1988, they had an j
imperfect understanding (1) of the " loops not filled" condition, and (2) that nitrogen injection into the steam generators was significant to entry into the " loops not filled" condition.
i Based on my interviews, however, I am assured that the operators were well aware of the status of the reactor coolant system draindown and the nitrogen injection evolutions.
The addition of chemicals to the Chemical Mixing Tank was also well known to the shift, and was planned and appropriately delegated to the SSS, a licensed SRO..The major evolutions, limitations and conditions applicable to this shift were known and appropriately supervised.
i I believe, apart from the issue of training and guidance respecting the " loops not filled" condition, this shift was functioning in a properly integrated and supervised manner.
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Mr. James H. Sniezek October 1, 1991 Fage 3 II.
Discussion of Specific Evolutions:
October 11-12, 1988 on October 11, 1988, at about 6:30 p.m. Central Time
("CT"), the night shift began duty in the Unit 1 Control Room.
The shift crew compliment included the OSOS, the USS, the SSS, the RO, the Balance of Plant Operator, and a number of other licensed operators who were assigned to various areas of the plant or who were to assist the shift as directed.
According to VEGP Procedure 10000-C, Revision No. 9 then in effect, the function and duties of the shift crews were as follows:
The OSOS (now the Shift Superintendent) was the senior plant management representative on each shift and was responsible for the overall safe and efficient operation of the plant.
The OSOS maintained a broad perspective of operational conditions affecting safety of the plant.
The USS reported to the OSOS and was responsible for the safe and efficient operation of the unit to which he was assigned.
The USS's duties included' directing operational activities of the unit from the Control Room unless relieved by a qualified licensed SRO and supervising operators assigned to specific shift positions on the unit.
The SSS reported to the OSOS and provided technical and l
administrative assistance to the USS, including clearance l
and tagging review.
The SSS also supervised shift operators who were common to both units or who were not assigned a specific shift position, The RO reported to the USS and was the licensed operator e
assigned to operate the reactor and related controls from the Control Room.
His duties included (1) maintaining continuous surveillance of unit conditions and system parameters in the control Room until properly relieved, (2) instructing operators to perform prescribed plant operations, and (3) remaining alert and knowledgeable of all unit operations in progress that involved the functioning of equipment controlled from the Control Room.
During the first refueling outage of VEGP Unit 1, the draindown of the Reactor Coolant System ("RCS") was initiated at 7:21 a.m. CT on October 11, 1988.
By the time the night shift began duty at about 6:00 p.m. CT, the draindown had been secured I
and the RCS water level was being maintained at the 194' i
elevation.
The night shift crew began with a shift briefing during which, I understand, the OSOS, the USS, the SSS, the RO i
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~ Mr. James H. Sniezek' I
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October 1, 1991 Page 4 l
and the shift crew discussed the planned activities for the night
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shift including, among other things, the RCS draindown, nitrogen injection to the steam generators, and tha chemical addition i
evolution.
While maintaining the RCS water level at the 194' elevation, the night shift began injecting nitrogen into the primary side of the steam generators at 7:06 p.m. CT on October 11.
By 1:50 a.m. CT on October 12, the primary water in the l
4 steam generator tubes had been completely forced out of the tubes.
It is my understanding that because the RCS water level
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rises during the nitrogen injection process, the operators i
simultaneously drained water from the RCS to maintain the RCS water level at the 194' elevation.
However, it was not until the completion of the nitrogen injection process than the draindown i
of the.RCS (to levels below the 194' elevation) was resumed.
With respect to the OSOS on the night shift of October 11-12, 1988, I am satisfied that he did not lose "comnand and i
control" as a result of being focused on other specific
- activities.
The OSOS as then defined at VEGP was a fairly unique position with overall responsibility for safe operations of the plant and all plant personnel.
Within this context, his job was to ensure good communications and teamwork between Operations and other plant departments and to resolve any particular problems of significance to the plant activities.
In the August 29, 1991 response of the OSOS, he suggested that the "most memorable" event to him on the date in question l
was. damage that occurred that night to a diesel generator heater.
j He stated that he spent several hours inspecting the diesel generator and making plans to replace the damaged heater, including locating a spare.
I am assured by my interview with j
this operator that he did not intend to suggest he was not aware of the other activities being conducted on the shift -- only that the diesel generator event was the most memorable.
In fa'ct, 4
while he did not monitor the detailed performance of each task, 4
he appears to have been well aware of the general activities of j
RCS draindown, nitrogen injection, and hydrogen peroxide addition.
With respect to his allocation of his time to the diesel generator repair, I concur with his decision.
Given the j '
responsibilities and functions of the OSOS position at VEGP, he was properly fulfilling his role.
t My expectations of a USS's performance include direction l~
of operational activities of the unit, explanation of activities prior to implementation, assurance of an adequate shift relief turnover, and supervision of other operators.
The USS has control over all activities on his unit and the responsibility to ensure that those activities are conducted in a manner which j
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Mr. James H. Sniezek October 1, 1991 Page 5 maintains reactor safety and fulfills regulatory requirements.
He must remain aware of the status of the plant and significant evolutions in progress.
I have concluded that the USS fulfilled these expectations on October 11-12, 1988.
More specifically, he was well aware of the status of the RCS draindown and the various changes in RCS water elevation.
The shift crew, working as a team, diligently and continuously monitored the changes in RCS water elevation, and controlled those levels.
In fact, the crew anticipated reaching the RCS water level which was designated for the hydrogen peroxide addition and prepcsitioned the SSS and an equipment operator for this task.
The USS appropriately delegated the loading of the Chemical Mixing Tank with hydrogen peroxide (preparatory to its addition to the RCS) to another SRO.
This SRO, the SSS, had principal responsibility for the
" clearance and tagging" activities and was assigned control over the detailed implementation of this activity.
This, in my judgment, was an appropriate delegation of a specific delineated task to be performed by a qualified individual.
At the beginning of the night shift, the planned activities for the shift were discussed.
The USS for the first time became aware that the hydrogen peroxide addition would be done on his shift, as stated in his August 29, 1991 response.
He clearly knew that his overall duties as a USS included oversight of chemical addition activities.
Indeed, he had prior experience with addition of other chemicals.
The USS also understood fully his overall responsibility for every operational activity on his
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shift and it was not his intention in his response to imply otherwise.
The USS was generally aware of and his crew controlled the addition of nitrogen into.the primary side of the steam generator to facilitate draining of the RCS.
What, specifically, he was not aware of was the fact that this addition, and the associated displacement of reactor coolant, placed the unit into a " loops not filled" condition.
In hindsight, and as he stated in his response, this lack of awareness resulted from inexperience and lack of guidance.
I agree with his assessment.
Further, I concur with his view that lack of guidance concerning the "mid-loop" and " loops not filled" conditions contributed to his failure to identify the issue of voluntary entrance into the LCO.
The RO on duty during the night shift of October 11-12, 1988 maintained the Unit 1 Control Log.
The entries made in that Control Log indicate that the RO was properly performing his
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Mr. James H._Sniezek October 1, 1991 Page-6 I
~ duties and was cognizant of numerous activities conducted during that shift, including:
Operation of RHR system to maintain the temperature of the e
RCS.
i Circulation of RCS water through the CVCS-demineralyzer e
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'via the RHR system.
Draindown and monitoring of the RCS water level.
e connection of nitrogen supply lines to the steam generator e
channel heads and displacement of primary water from the j
steam generator tubes.
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Completion of routine Tech Spec surveillance requirements.
- e Venting of the Safety Injection Accumulators.
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Lay-up of the secondary side of the steam generators.
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j With respect to the injection of nitrogen to the steam i
4 generators, the RO, who was required to remain at the reactor controls in the Control Room, was in direct communication (via I
head phones) with the individual who performed that activity in I
the Containment' Building.
The RO verbally kept the USS informed j
of the status of evolutions on a routine basis as was his normal practice.
The RO on the night shift of October 11-12, 1988 was also interviewed in the preparation of this response.
Although he cannot specifically remember, when shown a copy of the control Log and the shift turnover sheets (for both the beginning and and of that night shift), the RO indicated that there was a real l
probability that, during the night shift, he was aware that the Chemical Mixing Tank had been loaded with hydrogen peroxide.
At i
the end of the night shift, the RO recorded a note to the day shift in the shift turnover sheet which indicated that he was then aware that the injection of chemicals to the RCS was
_expec et d to occur during the next shift.
Furthermore, I understand-that the chemical addition evolution was discussed as l
a preplanned evolution during the shift briefing preceding the i
night shift which_was attended by the RO.
Finally, it is the RO's opinion that the loading of chemicals into the chemical 4
Mixing Tank (without injection of those chemicals into the RCS) was a minor isolated activity and his attention would have been appropriately focused on the major shift activities which-affected the plant,-i.e., the RCS water level draindown/
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Mr. James H. Sniezek October 1, 1991 l
Page 7 monitoring and the nitrogen injection to the steam generators.
I concur with this assessment.
III.
Operatino Shift Performance:
Procrammatic Imorovements The command and control practices for plant operations at i
Vogtle are established in Procedure 10000-C, " Conduct of Operations."
This procedure was initially approved for use in June of 1984, and its purpose is to establish the responsibilities of operations personnel and provide administrative instructions for daily conduct of plant i
operations.
Revision 9 of this procedure was in effect on
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October 11, 1988, and Revision 22 is used today.
(Copies of Revision 9 and Revision 21 were included as Exhibits 32 and 33, respectively, to the GPC Response.)
This procedure has been used in the training of licensed operators, and is used in conduct of operations at VEGP on each shift.
One of the primary purposes of Procedure 10000-C is to define an integrated or team approach to operations on shift, with a clear chain of command and clear responsibilities.
The procedure describes a specific chain of command and lists specific duties and responsibilities for each J
member of the operations team.
The basic command and control practices and responsibilities of operating crews at VEGP, as defined by l
procedure, have remained generally consistent since October 1988.
However, we have made enhancements over the past few years to strengthen the ability of the nn shift crews to perform their functions safely, efficiently and in an integrated manner.
For instance, the role of the OSOS has been strengthened to include more overall shift management.
The title was changed to " Shift Superintendent" to reflect the role this position has in providing overall management direction to ensure good coordination of work activities.
GPC has taken other significant measures since 1988 to address in practice the performance of operating crews.
With the management changes at GPC and VEGP in 1988-91, there has been increased emphasis on excellence in shift operations performance.
Management has frequently observed control room crews at the plant and during simulator training.
Recommendations and directions to improve both individual operator performance as well as team performance were specifically made.
We believe that operational performance has been significantly enhanced during this time interval.
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Mr. James H. Sniezek October 1, 1991 Page 8
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GPC management continues to emphasize excellence in Control Room performance.- Management makes routine visits to the Control Room and the simulator to observe operator and operating crew performance.- It is our philosophy during these visits to probe operators' awareness of plant conditions and evolutions, to emphasize teamwork on shift, and to verify knowledge of and compliance with applicable procedures.
Overall, based on NRC's and others' recent reviews as well as my personal observations, I believe performance on shift has improved considerably since October 1988.
IV.
GPC Policies on Voluntary Tech Soec Entry During the enforcement conference the NRC also raised a question regarding the October 2, 1989 and August 15, 1991 policy statements addressing voluntary entry _into Tech Spec LCOs requiring immediate action.
Specifically, the NRC's-question appears to focus on whether GPC in those policies (a)
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acknowledged that a Tech spec violation occurred on October 12-
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13, 1988, and (b) took strong enough action to prevent-future j
similar Tech Spec entries.
i The two policy statements must be placed in proper l
perspective.
At the outset, to be clear, it is GPC's position today -- as it was in 1989 when the first policy was issued --
that no Tech Spec violation occurred in 1988.
At that time the j
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entry made was reasonably consistent with established practice and guidance.
Such an entry certainly was not prohibited and thus no violation resulted.
Nonetheless, in 1991 the NRC has made clear a new interpretation of this issue, and would preclude such actions.
Accordingly, if such a Tech Spec entry were made 4
today or in the future, we believe there would be a Tech spec violation.
The clear intent of the August 15, 1991 policy issued by Mr. Shipman is to prohibit voluntary entry into Tech Spec LCOs i
requiring immediate action, absent an extraordinary safety concern.
A closer look at the two policy statements in this context illustrates our point.
The October 2, 1989 policy, drafted by Mr. Stringfellow for my signature,-stated:
(B]ecause of the potential for placing the plant in an unanalyzed condition, voluntary entry into an l
LCO which expressly prohibits a given condition and requires immediate corrective action should that condition exist, should not be made.
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d Mr. James H. Sniezek October 1, 1991 Page 9 This conclusion was based on two other conclusions:
(a) the voluntary entry was Indi prohibited by Tech Specs or regulations, and (b)-the entry in October 1988, due to a misunderstanding of the FSAR accident analysis, resulted in an unanalyzed condition.
Therefore, as a corporate policy, the memorandum intended that such entries "should not" be made in the future.
The choice of the words "should not" versus "shall not" in
-the memorandum is largely an academic issue.
In accordance with general GPC procedures, "should not" was used because the policy was based only on a Company management position.
"Shall not" is reserved for positions compelled by regulatory requirements.
At that time, it was not the conclusion of the Company that the policy was compelled by Tech Specs.
Nonetheless, in effect, the choice makes no difference; VEGP personnel understand that the terms are treated as equivalent by procedure writers pursuant to administrative procedure 00050-C, Revision No. 10.
The NRC also raised a question regarding the Plant Review Board ("PRB")' understanding of the October 1989 policy.
Based on our reviews, the PRB had an historically appropriate understanding of the memorandum; it served as part of their basis for concluding that no reportable condition existed.
The PRB interpreted the memorandum as saying that no Tech Spec violation had occurred, but that prudent, conservative practice indicates that voluntary entry into "immediate" action statements should not be made due to the possibility of creating an unanalyzed condition.
Because the conclusion was that there was no Tech Spec violation during the October 12-13, 1988 avant, the event was not reportable on this basis.
The PRB also recognized that j-this event had created an unanalyzed condition; however, the condition was not reportable because it did not "significantly compromise plant safety."
The August 15, 1991 memorandum from Mr. Shipman was issued in a different context, based on new guidance from the NRC as evidenced in the June 3, 1991 Demands for Information and
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internal NRC documentation.
Mr. Shipman's memorandum states in part:
GPC has recently become-aware of an NRC position that Tech Spec LCOs and their Associated Action Statsaents which de Det Provide a specific LCo J
l action time (often referred to by the NRC as an l
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" allowed outage time" or "AOT") should not be j
voluntarily entered except as expressly provided in associated Surveillance Requirements.
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Mr. James H. Sniezek i.
October 1, 1991 Page 10 As stated above, the intent here was to pass on clear guidance from the NRC that voluntary entries of this type not be made, absent an extraordinary safety concern.
We recognize that j
the memorandum could have said (perhaps should have said) "shall 4
not" rather.than "should not."
However, in context, the policy is not' ambiguous.
Also, again, under plant administrative procedures, plant personnel understand that the two terms are treated as equivalent when used in procedures.
We conclude that the policy was a clear and effective communication to the 4
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operators.
v.
Conclusion 4
I trust that the information provided herein will satisfy you that the VEGP Unit i night shift crew of October 11-12, 1988 exercised adequate command and control over the shift activities j
on that unit.
As I have indicated, the responses of the individual operators were not written to address a command and control concern since that was not identified as an issue in the NRC June 3, 1991 Demands for Information.
Also, as stated 4
i herein, I am satisfied that the OSOS, the USS and the RO on shift 1
that night were in full command and control of the shift's activities.
l Sincerely, 8. Of '
C. K. McCoy
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CKM/ JAB /jaf l
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U.
S.
Nuclear Reculatory Commission Mr. James Lieberman Mr. Stewart Ebneter Mr. Alan Herdt l
Assistant General Counsel for Hearings and Enforcement l
Mr. David B. Matthews j
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