ML20059E805
| ML20059E805 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 01/07/1994 |
| From: | Mccoy C GEORGIA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LCV-0244, LCV-244, NUDOCS 9401120263 | |
| Download: ML20059E805 (5) | |
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January 7, 1994 LCV-0244 Docket No.
50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Gentlemen:
VOGTLE ELECTRIC GENERATING PLANT REPLY TO A NOTICE OF VIOL,ATION Pursuant to 10 CFR 2.201, Georgia Power Company (GPC) submits the enclosed response to the violation identified in Inspection Reports 50424/93-26 and 50-425/93-26 concerning the inspection conducted by hir. B. Bonser during the period of October 24 through November 20, 1993.
Sincerely,
. Yk l
C. K. McCoy CKM/NJS Enclosure xc:
Grpfgia Power Comaally hir. J. B. Beasley, Jr.
hir. hi. Sheibani NORhiS U. S. Nuclear Reculatory Commis3jipn hir. S. D. Ebneter, Regional Administrator hir. D, S. Ilood, Licensing Project hianager, NRR hir. B. R. Bonser, Senior Resident Inspector, Vogtle i
9401120263 940107 PDR ADOCK 05000424
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ENCLOSURE 1 VOGTLE ELECTRIC GENERATING PLANT - UNIT 2 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425/93-26 The following is a transcription of the violation as cited in the Notice of Violation (NOV):
" Technical Specification (TS) 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.
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Regulatory Guide 1.33, Appendix A, " Typical Procedures for Pressurized Water Reactors and Boiling Water Reactors," delineates the types of safety-related activities that should be covered by written procedures for startup, operation, shutdown, and procedures for performing maintenance.
l Procedure 14900-2, Containment Exit Inspection, section 5.2, requires a visual inspection of all areas entered at the completion of each containment entry and recording of the inspection results on Data Sheet 2 of the procedure. This includes an inspection for loose debris that could be transported to the containment sumps and cause restriction of the Emergency Core Cooling Systems pump suctions during accident conditions.
Contrary to the above, on October 16,1993, maintenance personnel failed to follow procedure 14900-2 in that Data Sheet 2 of the procedure was completed indicating a visual containment inspection was performed with no discrepancies when, in fact, loose insulation and other material was len by these personnel on the containment floor when they exited containment. This occurred due to a misunderstanding between the maintenance personnel and their foreman.
This is a Severity Level IV violation and applies to Unit 2 only. (Supplement I)."
RESPONSE TO VIOLATION (50-425/93-26-01)
Admission or Denial of the Violation l
This violation occurred as stated in the NOV.
Reason for the Violation This violation was attributed to the failure of maintenance personnel to properly review and understand the requirements of Procedure 14900-2 prior to making a containment entry in Mode
- 4. On October 16,1993, maintenance personnel entered the Unit 2 containment after the plant entered Mode 4 to perform work on the reactor coolant drain tank pump (RCDTP). The work included removal ofinsulation which was completed by day shift personnel. Night shift personnel later entered containment to complete the assigned work. Upon completion of the work, they E-1
l ENCLOSURE 1 (CONTINUED)
VOGTLE ELECTRIC GENERATING PLANT - UNIT 2 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION ' REPORTS 50-424:425/93-26 exited containment and signed data sheet 2 of Procedure 14900-2, indicating that no loose debris was lefl in containment that could get to the emergency sumps. After exiting containment, the maintenance personnel notified their foreman that they were unable to install the insulation. The maintenance foreman advised the maintenance personnel that he would have insulators install the insulation. However, the foreman failed to have the insulation reinstalled.
On October 27,1993, a licensed operator entered containment to look for possible sources of a nitrogen leak from the safety injection accumulators. It was during this entry that the previously removed insulation was discovered and removed by the licensed operator. Management was informed of this situation and an engineering evaluation was performed to determine what effect the insulation would have on the containment sumps. It was determined that the insulation would not have restricted the emergency sumps to a degree that the net positive suction head (NPSH) of the sump pumps would have been adversely affected.
The maintenance manager interviewed the individuals involved and determined that all maintenance personnel did not have a consistent interpretation of the procedural requirements.
The involved maintenance personnel believed that the requirements only applied to materials that they entered containment with and not materials that were already there, or were in the work control process, such as the insulation removed for the RCDTP work. Georgia Power Company has concluded that other personnel may not have had a clear understanding of the meaning anJ intent of the requirements of Procedures 14900-1/2.
Georgia Power Company does not believe that the involved personnel willfully or knowingly violated Procedure 14900-2. Georgia Power Company has concluded that this violation was the result of personnel not fully understanding the intent of the containment inspection and the consequences ofloose material that could be transported to the containment sumps.
Corrective Steps Which Have Been Taken and the Results Achieved
- 1. The involved maintenance personnel were counseled and appropriately disciplined for their actions that contributed to this violation.
- 2. Maintenance and operations personnel were briefed on this incident and reminded of the importance of understanding what they are doing when they sign or initial that a task is completed.
- 3. The work planning group now provides copies of Procedures 14900-1/2 in maintenance work orders requiring containment entry during Modes 1 - 4. This will ensure that maintenance personnel performing work in containment have the procedure in hand to verify that nothing was lerl in containment that could adversely affect the ability of the containment sumps to perform their intended safety function.
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ENCLOSURE I (CONTINUED)
VOGTLE ELECTRIC GENERATING PLANT-UNIT 2 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425/93-26 Corrective Steps Which Will De Taken to Avoid Further Violations Appropriate plant personnel will be trained by May 1,1994, on the specific requirements of Procedures 14900-1/2 as they relate to the containment emergency sumps and associated Technical Specification surveillances. Until the above training is completed, briefings on the use of Procedures 14900-1/2 will be conducted during ALARA briefings for containment entries during Modes 1 - 4.
Date When Full Compliance Will Be Achieved Full compliance was achieved on October 27,1993, at 1520 EDT, when the insulation was removed from containment thereby preventing any potential clogging of the containment sump pump screens.
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