ELV-03831, Responds to NRC 920528 Notice of Violation Enforcement Action 92-041.Corrective Actions:Temporary Change to Procedure 24812-1 Initiated & Bistable Adjusted to Correct Setpoint & Results Appropriately Documentated
| ML20101H287 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 06/23/1992 |
| From: | Mccoy C GEORGIA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| EA-92-041, EA-92-41, ELV-03831, ELV-3831, NUDOCS 9206290277 | |
| Download: ML20101H287 (6) | |
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<n June 23. 1992 ELV-03831 1900 Docket No. 50 #24 U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D. C.
20555 Gentlemen:
V0GTLE ELECTRIC GENERATING PLANT REPLY TO A NOTICE OF VIOLATION ENFORCEML!iT ACTION 92-041 By letter dated May 28, 1992, the NRC issued a Notice of Violation (NOV) resulting from the activities of two Instrument and Control ter.hnicians while performing a surveillance on reactor trip system instrumentation on January 28, 1992.
In accordance with 10 CFR 2.201, our response is provided in the enclosure, in addition, Georgia Power Company wishes to reiterate that we in no way condone the actions of the technicians which are the subject of the NOV.
As we stated during the May 13, 1992, enforcement conference, the integrity of our employees is fundamental to our confidence in the condition and status nf our plant.
Georgia Power Company remains committed to this fundamental principle, and we believe that the corrective actions described in the enclosure and discussed during the enforcement conference will serve to reemphasize that commitment to the employees at the Vogtle Electric Generating Plant.
Sincarely, C. K McCoy CKM/NJS
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Enclosures xc: Georaia Power Company Mr. W. B. Shipman Mr. M. Sheibani NORMS U. S. Nuclear Reaulatory Commission Mr. S. D. Ebneter, Regional Administrator Mr. D. S. Hood, Licensing Project Manager, NRR
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Mr. B. R. Bo:ser, Senior Resident inspector, Vogtle Q
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ENCLOSURE 1 V0GTLE ELECTRIC GENERATING PLANT UUli 1 REPLY TO A NOT:CE OF VIOLATION ENFORCEMENT ACTION (EA) 92 041 The following is transcription of the violations as cited in the Notice of Violation (NOV):
A. " Technical Specification 6.7.la requires that written procedures be established, implemented, and maintained covering activities delineated in Appendix A of Regulatory Guide 1.33 Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A, " Typical Procedures for Pressurized Water
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Reactors and Boiling Water Reactors," paragraph 8.b provides, in part, that the licensee establish and follow written procedures for surveillance tests, inspections, and calibrations for reactor protection system tests and calibrations.
Procedure 24812-1, Delta T/T Avg Loop 3 Protection Channel 111 IT-431 Analog Channel Operations Test and Channel Calibration, provides instructions for analog channel operational test and channel calibration of this Delta T/T Avg loop. The procedure requires that if as found readings are not within limits specified, protecd to the appropriate calibration sub section.
Contrary to the above, on January 28, 1992, technicians failed to follow procedure 24812-1 in that upon identifying Over Pressure Delta Temperature (0PDT) runback bistable settings outside allowable limits, they willfully did not perform the calibration section of the procedure when adjusting the bistable.
This resulted in an incorrect setting of the OPDT runback bistable and a procedure error which would have been apparent had the procedure been performed correctly was not identified.
This is a Severity Level IV violation (Supplement 1).
B. 10 CFR 20.9 requires that information provided to the Commission by an applicant for a license or by a licensee or information requif ed by statue or by the Commission's regulations, orders, or license conditions to be maintained by the licensee shall be complete and occurate in all material respects.
Contrary to the above, information required by the license conditions to be maintained by the licensca was not complete and accurate in all material respects, in that, or. January 28, 1992, data entered into Procedure 24812-1, Data Sheet 37, was fabricated by the technicians performing this activity.
This information was material to the NRC because it related to calibration of the reactor protection system.
This is a Severity Level IV violation (Supplement 1)."
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ENCLOSURE 1 V0GTLE ELECTRIC GENERATING PLANT - UNIT 1 REPLY TO A NOTICE Of VIOLATION ENFORCEMENT ACTION (EA)92-041 RESPONSE 10 VIOLATION A admission or Denial of the Violation The violation occurred as stated in the NOV and as discussed in the May 13, 1992, enforcement conference.
Reason for the Violation The reason for this violation was the Instrument and Control (l&C) technicians failed to follow Procedure 24812-1
" Delta T/T Avg Loop 3 Protection Channel 111 IT 431 Analog Channel Operational Test and Channel Calibration."
In addition, when Procedure 24812-1 was changed in January 1992, one of the data sheets was not completely revised to reflect the change, s
Corrective Stens Which Have Been Taken and the Results Achieved o A temporary change to Procedure 24812-1 was initiated to include the correct values on the analog channel operational test (ACOT) data sheet, and the
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runback bistable was adjusted to the correct setpoint on January 29, 1992.
Procedure 24812-1 was revised on February 7, 1992, to incorporate the correct
- values, o The technicians were disciplined in accordance with the GPC Positive Discipline Program and were issued a Decision Making leave - the most severe discipline short of dismissal.
This includes placing the technicians on probation for an 18-month period such that an infraction of any type may result in employment termination.
o A memorandum was sent to all plant personnel stating plant and corporate management's expectation for integrity due to the special public trust placed in plant workers.
A copy of the NRC's deliberate misconduct rule was attached to this memorandum. A copy of this memorandum is attached as enclosure 2.
o A series of management and supervisory meetings with 1&C technicians were conducted to strongly emphasize expectations for procedure compliance and reliance on the integrity of the plant staff as a fundamental job requirement and a basis of employment, o A self assessment of VEGP practices is being performed in light of Information Notice 92-30.
Further action will be implemented as appropriate.
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ENCLOSURE 1 V0GTLE ELECTRIC GENERATING PLANT - UNIT 1 REPLY TO A NOTICE Of VIOLATION ENFORCEMENT ACTION (EA)92-041 Corrective Steos Which Will Be Taken to Avoid Further Violations No further actions are warranted ether than those identified above.
Date When full Compliance Will Be Achieved Compliance was achieved on January 29, 1992, when the bistable was restored to the correct setpoint and the temporary change to Procedure 24812 1 was initiated to correct the ACOT data sheets.
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ENCLOSURE 1 V0GTLE ELECTRIC GENERATING PLANT - UNIT 1 REPLY TO A NOTICE OF VIOLATION ENFORCEMENT ACTION (EA) 92 041 RESPONSE TO VIOLATION B Admission or Denial of the Violation The violation occurred as stated in the NOV and as discussed in the May 13, 1992, enforcement conference.
Reason for the Violation The reason for the violation was the Instrument and Control (l&C) technicians failed to follow Procedure 24812-1.
The technicians did not proceed to the appropriate subsectiol. of the procedure for bistable calibration.
Just prior to turning in the surveillance package to their foreman for close-out review, one of the technicians realized that no data sheet existed for the calibration of ITB-431H. He then decided to fill out data sheet 37 with values that he believed would support the adjustments made in the field earlier.
No actual "As Found" or "As Left" data were ever taken for this data sheet.
Corrective Steos Which Have Been Taken and the Results Achieved o Disciplinary actions are the same as mentioned in Violation A.
o The bistable was adjusted to the correct setpoint on January 29, 1992, and the results were appropriately documented.
o A series of supervisory and management meetings were conducted with all I&C technicians explaining management expectations for procedural compliance.
o The involved individual as well as other members of his crew were interviewed.
These interviews revealed no information which would indicate other instances of falsely documenting work.
In addition, samples of the individual's previous work documents were reviewed to detect patterns of possible falsification or improper work or documentation.
No improper or suspicious documentation was found.
t Corrective Steps That will Be Taken to Avoid Ferther Violations No further actions are warranted.
Date-When Full Comoliance Will be Achieved Compliance was achieved on January 29, 1992, when the surveillance was reperformed and documented appropriately.
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' ENCLOSURE 7.
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lnterefflee Correspondenee Ceorgia Pcmcr d Date:
May 11,1992 RE:
Responsibilities of Nuclear Plant Employess Log: NOVC632 FROM:
W. B. Shipman TO:
As a result of several recent events In our industry,i want to share with you some of my thoughts concerning our individual responsibilities as nuclear plant workers. As nuclear plant employees of Georois Power Company, we have accepted a special trust relative to our work at Vogtle Electric Generating Plant. The safe operation of our pla,1t requires that we perform our work reliably and in accordaico with procedures.We also cepend on each employee to honestly and ccmpletoly report any known problems or errors so that they may be promptly corrected.
The perscnal traits required to fulfill this trust (integrity, honesty, trustworthiness),
while desirable f.,,r everyone, are essential for nuclear plant employees. In our business, because of the possible consequencos of an accident such as Three Mlle Island or Chernobyl.
We are expected to meet high personal standards and we must conr,tantly strive to maintain these standards and to assist our fellow workers in meeting these expectations, i
As Osneral Manager at Vogtle Electric Gonorating Plant,I expect each employee here to abide by the rules, regulations and procedures that govern our operation of this facility.
If you find yourself in a condition where you have made a mistake or an error either consciously or inadvertently, I urge you to immediately inform four supervision of this situation. Appropriate disciplinary er'lon will be taken for negligence or consclous violations of our rules, regulations or procedures; but mitigation of the disciplinary action is much more likely if you report tha mistake to your supervision than if they discover it through other means.
As additionalinformation. I am attaching a Nuclear Regulatory Commission information notice portainmg to recent Industry events on this general subject, as well as a recent revision to the NRC regulations that addresses deliberate misconduct by unlicensed Individuals. It is apparent that the NRC, as well as Georgia Power Company is concerned about failure of nuclear workers to meet expectations of Integrity and honesty. Workers who do not meet these standards will be held accountable by the NRC as well as the Company.
I encourage you to read these documents as they explain potential f4RC enforcement actions which the NRC may take against individuals that are In addition to those actions normally taken by Georgia Power Company.
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WBS:gww Attachmer.ts xc: C. K. McCoy NORMS TOTfL P.09
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