ML20056F076
| ML20056F076 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 08/19/1993 |
| From: | Mccoy C GEORGIA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LCV-0111, LCV-111, NUDOCS 9308260028 | |
| Download: ML20056F076 (12) | |
Text
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Georg,a Poaer Ca v or/
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C,K.McCoy August 19, 1993 Georgia Power
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"f! W" OtKAIC T, Fn yu;e P apc LCV-Olll Docket Nos. 50-424 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Gentlemen:
V0GTLE ELECTRIC GENERATING PLANT REPLY TO NOTICE OF VIOLATION Pursuant to 10 CFR 2.201, Georgia Power Company (GPC) submits the enclosed information as response to the violations identified in Inspection Reports 50-424;425/93-11. In the enclosure, a transcription of the NRC violation precedes GPC's response.
This inspection served as Vogtle Electric Generating Plant's Electrical Distribution System Functional Inspection and was conducted by a team led by Ed Girard during the period May 10 - June 11, 1993.
Should you have any questions, please contact this office.
Sincerely, i
C. K. McCoy CKM/AFS/gmb
Enclosure:
Response to EDSFI NOV xc:
Georoia Power Company Mr. J. B. Beasley, Jr.
Mr. M. Sheibani NORMS U. S. Nuclear Reaulatory Commission i
Mr. S. D. Ebneter, Regional Administrator Mr. D. S. Hood, Licensing Project Manager, NRR Mr. B. R. Bonser, Senior Resident Inspector, Vogtle l
9308260028 930819
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ENCLOSURE 1 VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425/93-11 The following is a transcription of the violations as cited in the Notice of Violation (NOV):
" A.
10 CFR 50 Appendix B, Criterion III, requires design control measures which assure that regulatory documents and the design basis are properly translated into drawings, specifications, instructions, and procedures.
Contrary to the above, in the following examples the licensee's design control measures did not assure the accuracy of design calculations, equipment qualifications, and FSAR design information. These documents provide data and information that is used in translating regulatory documents and the design basis into drawings, specifications, instructions, and procedures:
(1) Calculations X3CH03, X3CK05, and X3CK05-A incorrectly assumed negligible lengths of control cable to the auxiliary relays for operation of the Nuclear Service Cooling Water Bypass and Spray valves. Actually, the cables were several thousand feet in length. As a consequence of the incorrcet assumptions in the calculations, relays would not be assured to receive sufficient voltage to operate at degraded grid conditions.
(2) Calculations, such as Diesel Generator Steady State Load Study X3CE01, incorrectly assumed that the safety related Containment Spray (CS), Residual Heat Removal (RHR), and Auxiliary Feedwater (AFW) pump motors would not exceed their nameplate horsepower ratings during design accident scenarios. Additionally, for the above three pump motors plus the Centrifugal Charging pump motor, environmental qualification (EQ) records in the EQ file did not support qualified motor lives that considered the maximum design accident of the pumps, as required by 10 CFR 50.49.
(3) EQ file cable reports (AWV-06-80, AWV-02-8, and the EQ Report for Instrument and Specialty Cable) for cable used for Class 1E applications inside the containment did not reflect the correct containment maximum design basis accident temperature and did not adequately support qualification for the accident temperature stated.
i The required environmental qualification temperature was specified as 352 degrees F -
in Calculation X3AJ01, but the cable had only been tested to 346 degrees F.
(4) A 352 degrees F maximum containment temperature profile was given in FSAR Figure 6.2.1-33. However, the license had information (letter GP-14580 dated August 18,1989) indicating a different profile was applicable. This information indicated a lower maximum cornainment temperature of 303 degrees F.
ENCLOSURE 1 (CONTINUED)
VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425/93-1_],
(5) FSAR Section 8.3.1.1.8 incorrectly indicated that the maximum horsepower required by the driven load under normal running or runout conditions would be the nameplate horsepower for all motors rated above 480V, except the Centrifugal Charging pump motor. As noted in (2) above, this was incorrect for the CS, RHR, and AFW pump motors.
t This is a Severity Level IV violation (Supplement I).
B.
10 CFR 50 Appendix B, Criterion XI, as implemented by FSAR Section 17.2.11, requires establishment of a test program which assures that tests are performed to demonstrate that systems and components are operable and that the results of the tests are documented and i
evaluated.
Contrary to the above, the licensee's test program did not assure the performance of a test and documentation of the test results to demonstrate that the replacement for a failed circuit breaker returned the involved system to full operability. When a failed Post LOCA Cavity Purge Fan breaker,1-ABE-29-2, was replaced on December 20,1991, the only documented test did not demonstrate that the replacement retumed the system to service, permitting the fan to operate. Subsequently, Maintenance Work Request 19105873 (December 23,1991), identified that the purge fan associated with the replaced breaker would not start because the breaker repeatedly tripped on fan start.
This is a Severity Level IV violation (Supplement I)."
1 RESPONSE TO VIOLATION "A" (50-424/93-11-01):
Violation A Exampic (1)-
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" Calculations X3CH03, X3CK05, and X3CK05-A incorrectly assumed negligible lengths of
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control cable to th: awdliary relays for operation of Nuclear Service Cooling Water Bypass and i'
Spray valves. Actually, the cables were several thousand feet in length. As a consequence of the incorrect assumptions in the calculations, relays would not be assured to receh e su0icient voltage to operate at degraded grid conditions."
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ENCLOSURE I (CONTINUED)
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VOGTLE ELECTRIC GENERATING PLANT - UNITS 1 & 2 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425/93-i1 Admission or Denial of the Violation:
This example of violation A occurred as stated in the notice of violation.
Reason for the Violation:
This example of the violation was due to personnel error in making an incorrect assumption in the calculation. The assumption was based on utilizing only single line diagrams and the information from an automatic cable routing program known as Ple.nt Data Management System (PDMS).
The PDMS information was inappropriately applied to detennine whether the cables were internal or extemal to a specific piece of equipment. Also, the assumption was not properly verified by the checker.
Corrective Steps That IInve Been Taken And The Results Achieved:
An audit was conducted and determined the existing procedures and design criteria are adequate.
The audit found this to be an isolated case resulting from the originator's misunderstanding of infonnation contained in the PDMS and the checker's failure to verify the assumption. Individuals involved have been reminded on the proper use of PDMS information and personal accountability for following procedures.
The efTect ofincorrect assumptions in the calculation was reviewed during the EDSFI audit and found to have no safety concerns.
The same type and model relays as the auxiliary relap myolved in the nuclear service cooling water bypass and spray valve control circuits were tested and found to operate at a much lower voltage than assumed in the calculation. Qualification of the auxiliary relays at degraded grid conditions is in progress. Preliminary results from a qualification test lab confirmed that the same type and model relays will operate under seismic conditions at degraded voltages.
Corrective Steps That Will be Taken To Avoid Further Violations:
Project engineers will be counseled on requirements to properly utilize and verify information in performing and checking design calculations.
The affected calculations are being reviewed and revised appropriately.
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ENCLOSURE I (CONTINUED)
VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425/93-11 Date When Full compliance Will Be Achieved:
Corrective action is scheduled for completion by December 31,1993.
Violalion A. Example (2):
" Calculations, such as Diesel Generator Steady State Load Study X3CE01, incorrectly assumed that the safely related Containment Spray (CS), Residual Heat Removal (RHR), and Auxiliary i
Feedwater (AFW) pump motors would not exceed their nameplate horsepower ratings during design accident scenarios.. "
Admission or Denial of the Violation:
This example of violation A occurred as stated in the notice of violation.
Reason for the Violation:
I The example of the violation was caused by the lack of adequate communication between the nuclear steam supply system (NSSS) vendon, Westinghouse, and the architect engineer (A/E) and/or between the disciplines within the A/E during the original design. As a result of the inadequate communications during the original desiga process, the maximum required pump horsepower (HP) was not used in the design calculations.
The above referenced pump motors, with the exception of auxiliary feedwater (AFW) pump, were purchased with 1.15 service factor. The maximum sustained required HP for the maximum sustained flow condition for the pumps, with the exception of AFW pump, are all within the 1.15 service factor rating. For the AFW pump the additional HP requirements were identified, reviewed, and approved by the pump / motor manufacturers prior to commercial operation.
Corrective Steps That IInve Been Taken And The Results Achieved:
A preliminary analysis was completed during the EDSFI audit and found that the diesel generator has adequate capacity to supply the additional HP requirements identified above. Applicable calculations are being revised to reflect this change.
Corrective Steps That Will be Taken To Avoid Further Violations:
The pump flow requirements are being reviewed for the remaining 4160 V Class 1E pumps.
Findings from this review will also be incorporated into the calculations as appropriate.
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i ENCLOSURE 1 (CONTINUED) 1 VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425/93-11 Design criteria will be revised to incorporate these design requirements.
Future additions of Class 1E pumps or fans will be designed to meet maximum flow requirements.
1 Appropriate personnel will also be counseled on the importance of proper communication between the disciplines of the A/E as well as with other applicable parties involved in the design process.
Date When Full comnliance Will Be Achieved:
i Corrective action is scheduled for completion by October 29,1993.
Violation A, Examnle (2):
.. Additionally, for the above three pump motors (RHR, CS, and AFW) plus the Centrifugal Charging pump motor, emironmental qualification (EQ) records in the EQ file did not support qualified motor lives that considered the maximum design accident of the pumps, as required by 10 CFR 50.49."
Admission or Denial of the Violation:
This example of violation A occurred as stated in the notice of violation. However, the qualified i
lives of the motors are based on maximum normal operating conditions rather than accident i
conditions.
Reason for the Violation:
I The reason for this example of the violation was due to personnel error in the application of motor heat rise data and identification of overload horsepower conditions.
The qualified life of the motors is based on the normal operating temperature plus heat rise from the energized windings. The heat rise used in EQ documentation was based only on an average I
temperature rise of the windings and did not account for hot spots in the electrical windings which may occur duiing normal operation.
Of the four pump motors stated in the example of violation, only the AFW pump motor equipment qualification documentation did not account for overload horsepower conditions.
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ENCLOSURE 1 (CONTINUED)
VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425/93-11 Corrective Stens That Have Been Taken And The Results Achieved:
A preliminary analysis was performed during the audit for each motor using temperatures based on normal operating conditions, overload horsepower, and hot spots. The results of the analysis demonstrated that the motors are capable of performing their required functions.
Corrective Steps That Will Be Taken To Avoid Further Violations:
The qualified life analysis will be reviewed and revised, as required, to address issues associated with hot spots and overload horsepower. In addition, appropriate design criteria will be revised i
to prevent future occurrences.
Date When Full Compliance Will Be Achieved:
The specific EQ files for CS, RHR, CCP, and AFW will be revised by October 18,1993. A broadness review for the correct motor hot spot considerations will be completed by December 1, 1993.
Violation A, Example (3):
l "EQ file cable reports (AWV-06-80, AWV-02-8, and the EQ Report for Instrument and Specialty Cable) for cable used for Class 1E applications inside the containment did not reflect the correct 2
containment maximum design basis accident temperature and did not adequately support qualification for the accident temperature stated. The required environmental qualification i
temperature was specified as 352 degrees F in calculation X3 AJ01, but the cable had only been i
tested to 346 degrees F."
Admission or Denial of the Violation:
)
This example of violation A occurred as stated in the notice of violation. However, the EQ cable reports (AWV-06-80, AWV-02-8) and required EQ temperatures were documented in EQDPs X3 AJ01 and X3 AJ02 rather than a calculation.
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ENCLOSURE I (CONTINUED)
VOGTLE ELECTRIC GENERATING PLANT-UNITS I & 2 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425/93-11 Reason for the Violation:
The reason for this example of the violation was due to personnel error in using an inappropriate reference to an EQ requirement during the original design. The peak containment accident temperature as documented in FSAR Figure 3.11.B.1-1 (Sheet 9 of 17) and FSAR Figure j
6.2.1-33 is 352 degrees F. The EQ files for 5 kV cable indicate that the qualification temperature is 346 degrees F. Tojustify the difference, the vendor provided an analysis based on degradation i
equivalency to demonstrate that the dt o,radation of the cable under test conditions was more severe than the anticipated degradation under postulated accident conditions. However, the degradation equivalency was questioned since it did not address operability at the peak required i
temperature including margin.
Corrective Steps That IInve Been Taken And The Results Achieved:
The existing procedures and design criteria are adequate. Our review has found no similar errors; thus, this is an isolated case.
The peak containment temperature of 352 degrees F was based on preliminary analysis, which was performed during the original design. The final analysis, based on actual as-built data (including heat sink area), established a peak temperature of 303 degrees F.
Corrective Steps That Will Be Taken To Avoid Further Violations:
Appropriate EQ documentation will be revised to prevent future occurrences.
t Date When Full Compliance Will Be Achieved:
The EQ files for the subject cable will be revised by September 1,1993.
t Violation A. Example (4h l
"A 352 degrees F maximum containment temperature profile was given in FSAR Figure 6.2.1-33.
However, the licensee had information (letter GP-14580 dated August 18,1989) indicating a different profile was applicable. This information indicated a lower maximum containment temperature of 303 degrees F."
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ENCLOSURE I (CONTINUED)
VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425/93-11 1
Admission or Denial of the Violation:
This example of violation A occurred as stated in the notice of violation.
Reason for the Violation:
The reason for the violation was personnel error in not revising the FSAR to indicate the new analyzed peak containment temperature of 303 degrees F. The peak containment temperature of 352 degrees F was based on preliminary analysis including margin during the original design. The' I
final analysis, based on actual as-built data including heat sink area, established a peak i
temperature of 303 degrees F. The peak containment accident temperature as documented in FSAR Figure 3.11.B.1-1 (Sheet 9 of 17) and Figure 6.2.1-33 is 352 degrees F.
Corrective Steps That Have Been Taken And The Results Achieved:
The equipment inside containment that was not properly documented to satisfy the accident temperature requirements of 352 degrees F has been verified to be enveloped by the new containment peak temperature analysis of 303 degrees F.
Corrective Steps That Will Be Taken To Avoid Further Violations:
An FS AR revision will be prepared to indicate the lower peak containment temperature of 303 degrees F.
Date When Full Compliance Will Be Achieved:
The FSAR revision is scheduled for completion by October 8,1993.
[
t Violation A, Example (5):
"FSAR Section 8.3.1.1.8 incorrectly indicated that the maximum horsepower required by the driven load under normal running or runout conditions would be the nameplate horsepower for all motors rated above 480 V, except the Centrifugal Charging pump motor. As noted in (2) above, this was incorrect for the CS, RHR, and AFW pump motors."
Admission or Denial of the Violation:
This example ofviolation A occurred as stated in the notice ofviolation.
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ENCLOSURE I (CONTINUED)
VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425/93-11 Reason for the Violation:
The example of the violation was caused by the lack of adequate communication between the NSSS vendor, Westinghouse, and the architect engineer (A/E) and/or between the disciplines within the A/E during the original design. As a result ofinadequate communications in the design process, the maximum required pump horsepower was not used in the original design calculations and not reflected in the FSAR.
The above referenced pump motors, with the exception of auxiliary feedwater pump, were purchased with 1.15 service factor. The maximum sustained required HP for the maximum sustained flow condition for the pumps with the exception of AFW pump are all within the 1.15 service factor rating. For the AFW pump the additional HP requirements were identified, reviewed, and approved by the pump / motor manufacturers prior to commercial operation.
Corrective Steps That Have Been Taken And The Results Achieved:
A preliminary analysis was completed during the EDSFI audit and found that the diesel generator has adequate capacity to supply the additional HP requirements identified above. Applicable calculations are being revised to reflect this change.
Corrective Steps That Will be Taken To Avoid Further Violations:
The pump flow requirements are being reviewed for the remaining 4160 V Class IE pumps.
Findings from this review will also be incorporated into the calculations as appropriate.
Future additions of Class 1E pumps or fans will be designed to meet the maximum flow requirements. Appropriate personnel will also be counseled on the importance of proper communication between the disciplines of the A/E as well as with other applicable parties involved in the design process.
An FSAR revision to section 8.3.1.1.8 will be prepared to revise the maximum HP required for CS, RHR, and AFW pump motors.
Date When Full compliance Will Be Achieved:
Corrective action is scheduled for completion by October 8,1993.
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ENCLOSURE 1 (CONTINUED)
VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425/93-11 RESPONSE TO VIOLATION "B" (50-424/93-11-02):
Violation B:
"..., the licensee's test program did not assure the performance of a test and documentation of the test results to demonstrate that the replacement for a failed circuit breaker returned the involved system to full operability. When a failed Post LOCA Cavity Purge Fan breaker,1-ABE-29-2, was replaced on December 20,1991, the only documented test did not demonstrate that the replacement returned the system to service, permitting the fan to operate. Subsequently, Maintenance Work Request 19105873 (December 23,1991), identified that the purge fan associated with the replaced breaker would not start because the breaker repeatedly tripped on fan start."
Admission or Denial of the Violation:
The violation for failing to document a post maintenance start of post LOCA purge fan occurred as stated in the notice of violation.
Reason for the Violation:
The violation occurred as a result of operators failing to adequately document the post maintenance start of the post LOCA purge fan after replacement of breaker 1-ABE-29-2 on December 20,1991. Georgia Power Company (GPC) believes that a start was performed on the fan after breaker maintenance, based on interviews with involved individuals and our operational policy of starting downstream motors following circuit maintenance. Georgia Power Company has determined that the post maintenance start performed on December 21,1991, was the activity which first identified the breaker failure and resulted in the corrective maintenance work order dated December 23,1993. Based on a review of this event, it was found that this was an isolated occurrence.
Corrective Steps That llave Been Taken and the Results Achieved:
When the violation was identified during May 1993, corrective action for the breaker tripping each time an attempt was made to stan the purge fan had already been completed via maintenance work order (MWO) 19105873 on December 26,1991, with a subsequent successful post maintenance stan and documentation that the purge fan started.
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ENCLOSURE I (CONTINUED)
VOGTLE ELECTRIC GENERATING PLANT-UNITS I & 2 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425/93-11 Corrective Steps That Will Be Taken to Avoid Further Violations:
A review of policies and procedures that provide guidance for the documentation of post maintenance motor starting will be performed to determine if any revisions or enhancements are required. Once the review is completed, any revisions or enhancements will be appropriately incorporated by November 1,1993.
Training and/or reemphasis will be provided to operating personnel to ensure they are cognizant of GPC's policies and procedures for documentation of post maintenance equipment operation.
Georgia Power Company expects this action to be completed by November 15,1993.
Date When Full Compliance Will Be Achieved:
Full compliance was achieved at 1748, on December 26,1991, when the post LOCA cavity purge fan was successfully started and the post maintenance start documented, after replacing breaker 1-ABE-29-2.
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