ML20005G947

Responds to NRC Ltr Re Violations Noted in Insp Repts 50-424/89-31 & 50-425/89-36.Util Denies Violations

ML20005G947
Person / Time
Site:	Vogtle
Issue date:	01/16/1990
From:	Hairston W GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ELV-01232, ELV-1232, NUDOCS 9001230310
Download: ML20005G947 (2)

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> Georgs Power Company 333 Pedmont Aenue Atlanta, Georp a 30308 biephone 404 520 3195 ,

Marting Address  !

40 inerness Contet Parkway i Post Office Box 1295 Birmingham. Alabama 35201 i Telephone 205 BOB $581 l

the soume.in t#ctic systern W. G. Hairston, til Seneor Vice Presdent Ncicar Operations ELV-01232 0201 j Docket Nos. 50-424 50-425 U. S. Nuclear Regulatory Commission  !

ATTN: Document Control Desk Washington, D. C. 20555 V0GTLE ELECTRIC GENERATING PLANT REPLY TO A NOTICE OF VIOLATION Pursuant to 10 CFR 2.201, Georgia Power Company (GPC) subnits the enclosed information in response to Inspection Report 50-424/89-31 and 50-425/89-36 which l concerns the inspection conclucted by Mr. S. G. Tingen of the NRC from October 30

- November 3, 1989 and November 13 - 17, 1989. In the enclosure, transcription of the violation precedes GPC's response. l Please contact this office if you have any questions.

Sincerely, l.ti './ -

W. G. Hairston, III WGH,III/NJS/gm

Enclosure:

Violations 50-424/89-31-01 and 50-425/89-36-01 and GPC Response

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c(w): Seoraia Power Company Mr. C. K. McCoy Mr. G. Bockhold, Jr.

Mr. P. D. Rushton  :

Mr. R. M. Odom NORMS U. S. Nuclear Reaulatory Commission Mr. S. D. Ebneter, Regional Administrator j Mr. J. B. Hopkins, Licensing Project Manager, NRR '

Mr. R. F. Aiello, Senior Resident Inspector, Vogtle l

^l 9001230310 900116 e s  !

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ENCLOSURE 1 V0GTLE ELECTRIC GENERATING PLANT - UNITS 1 & 2 {

NRC NOTICE OF VIOLATIONS 424/89-31-01 AND 425/89-36-01 AND GPC RESPONSE  !

" Technical Specification 4.4.4.1 requires each Power Operated Relief Valve (PORV) to be demonstrated operable at least once every 18 months by performance i of a channel calibration and operating the valve through one cycle of full I travel. A channel calibration is required to encompass the entire channel  ;

including sensors and alarm, interlock and/or trip functions such that the  :

entire channel is calibrated. i Contrary to the above, PORY channel calibrations did not fully test the portions i of both the PORV channels that actuate automatically on a pressurizer high pressure signal. As such, the entire PORV channel was not calibrated.

This is a Severity Level IV violation (Supplement I)." j i

RESPONSE TO VIOLATIONS 50-424/89-31-01 AND 50-425/89-36-01 Admission or Denial of the Violations:

Georgia Power Company denies the violations.

Georgia Power Company does not agree that automatic opening of the pressurizer PORV is required to be tested for the following reasons:

a. Automatic PORV operation is not assumed for accident mitigation in the safety analyses. Thus, PORV operability is not dependent on the automatic opening of the PORV. PORVs are not required for overpressure protection, Consequently, automatic operation of the PORVs is not required and 't surveillance testing of the manual portion of the PORV control circuit is rufficient to meet Technical Specification requirements. I

b. Furthermore, action statement a. of Technical Specification 3.4.4 allows indefinite operation with both PORV block valves closed in the event of excessive seat leakage. Closing of the block valves precludes automatic 1 operation of the PORVs. Consequently, the Technical Specifications acknowledge reactor operation without the automatic portion of the PORV control circuit.

c. Moreover, for several accident conditions the PORVs are operated in the manual mode. Emergency procedures provide direction to the operators for I operation of the PORVs. Consequently, the manual control circuit for the PORVs is relied on to ensure safe operation.-

In summary, Georgia Power Company does not consider the automatic portion of the PORV control circuit to be covered by the surveillance requirement. The manual portion of the PORV actuation circuit is covered by the Technical Specifications and is addressed in surveillance test procedures. However, after discussion with the NRC, Georgia Power Company agrees to test the automatic opening portion  ;

for these valves at least once per 18 months. Although testing will be #

performed, it is not considered a requirement to meet Technical Specification '

requirement 4.4.4.1.

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ENCLOSURE 1 V0GTLE ELECTRIC GENERATING PLANT - UNITS 1 & 2 '

NRC NOTICE OF VIOLATIONS 424/89-31-01 AND 425/89-36-01 AND GPC RESPONSE

" Technical Specification 4.4.4.1 requires each Power Operated Relief Valve (PORV) to be demonstrated operable at least once every 18 months by performance of a channel calibration and operating the valve through one cycle of full ,

travel. A channel calibration is required to encompass the entire channel '

including sensors and alarm, interlock and/or trip functions such that the l entire channel is calibrated. '

Contrary to the above, PORV channel calibrations did not fully test the portions of both the PORV channels that actuate automatically on a pressurizer high pressure signal. As such, the entire PORV channel was not calibrated.

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

RESPONSE TO VIOLATIONS 50-424/89-31-01 AND 50-425/89-36-01 Admission or Denial of the Violations: -

Georgia Power Company denies the violations.

Georgia Power Company does not agree that automatic opening of the pressurizer PORV is required to be tested for the following reasons: .

a. Automatic PORV operation is not assumed for accident mitigation in the safety analyses. Thus, PORV operability is not dependent on the automatic opening of the PORV. PORVs are not required for overpressure protection.

Consequently, automatic o)eration of the PORVs is not required and surveillance testing of tie manual portion of the PORV control circuit is sufficient to meet Technical Specification requirements,

b. Furthermore, action statement a. of Technical Specification 3.4.4 allows indefinite operation with both PORV block valves closed in the event of -

excessive seat leakage. Closing of the block valves precludes automatic operation of the PORVs. Consequently, the Technical Specifications acknowledge reactor operation without the automatic portion of the PORV control circuit.

c. Moreover, for several accident conditions the PORVs are o)erated in the manual mode. Emergency procedures provide direction to tie operators for

operation of the PORVs. Consequently, the manual control circuit for the PORVs is relied on to ensure safe operation.

In summary, Georgia Power Company does not consider the automatic portion of the PORV control circuit to be covered by the surveillance requirement. The manual portion of the PORV actuation circuit is covered by the Technical Specifications and is addressed in surveillance test procedures. However, after discussion with the NRC, Georgia Power Company agrees to test the automatic opening portion for these valves at least once per 18 months. Although testing will be performed, it is not considered a requirement to meet Technical Specification '

requirement 4.4.4.1.

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