ML20078E051
| ML20078E051 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 10/31/1994 |
| From: | Mccoy C GEORGIA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9411090322 | |
| Download: ML20078E051 (6) | |
Text
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Georgia Power Comparry-7
'40 Inverness CerW r Parkway
- Poct Offce Box 12'M-Bimingham. Alabama 35201 :
Tetephone 205 877 7122 l
i GeorS a Power C.K.McCoy von Prm.x>3nt Nickw Vog% Prorct the sou:twrn ekutt smem October 31, 1994 4
l LCV-0496 i
' Docket No.
50-424 l
'50-425 l
U. S. Nuclear Regulatory Commission j
ATTN: Document Control Desk l
Washington, D. C. 20555 i
f Ladies and Gentlemen:
VOGTLE ELECTRIC GENERATING PLANT REPLY TO A NOTICE OF VIOLATION l
1 Pursuant to 10 CFR 2.201, Vogtle Electric Generating Company (VEGP) submits the j
enclosed information in response to violations identified in Inspection Reports 50-424;425/94-22 which concern the inspection conducted by the VEGP Resident Inspectors from August 21-September 17,1994.
i Should you have any questions feel free to contact this ofIice.
i i
i Sincerely,
. &/ '
C. K. McCoy l
CKM/AFS
Enclosure:
Reply to NOV 94-22 cc: (Continued next page) f 941t090322 94I031 DR ADOCK 05000424 PDR 3 f n,..
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GeorgiaPower1 U. S. Nuclear Regulatory Commission Page 2 cc: Georgia Power Company Mr. J. B. Beasley, Jr.
Mr. M. Sheibani NORMS U. S. Nuclear Regulatory Commission Mr. S. D. Ehneter, Regional Administrator Mr. D. S. Hood, Licensing Project Manager, NRR Mr. B. R. Bonser, Senior Resident Inspector, Vogtle LCV-0496 1
ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-424:425/94-22 NRC INSPECTION REPORT NOS. 50-424:425/94-22-01, VIOLATION A The following is a transcription of the violation as cited in the Notice of Violation (NOV):
"During the NRC inspection conducted on August 21 through September 17,1994, two violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," the first of the two violations is listed below.
A.
Criterion XVI of Appendix B of 10 CFR 50 requires that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-confomiances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective actions taken to preclude repetition.
Contrary to the above, efTective corrective actions were not taken to identify and correct conditions adverse to quality following the start of Residual Heat Removal (RHR) pump 2A on July 24,1994, without Component Cooling Water (CCW) cooling to the RHR pump seal. This failure to take effective corrective action contributed to a second similar event on September 11,1994, involving the Unit 1 RHR pump IB. The IB RHR pump was run without CCW to the pump seal for approximately 27 minutes.
l This is a Severity Level IV violation (Supplement 1).
l RESPONSE TO VIOLATION A (50-424:425/94-22 01)
Admission or Denial of the Violation:
This violation occurred as stated in the notice of violation.
Reason for the Violation:
This violation was attributed to inadequate corrective action taken as a result of a similar situation that occurred on Unit 2 July 24,1994. Corrective actions for the July 24,1994 event were counseling of the involved operator and shift supervisor as well a briefing of the shift crews on the event and the lessons learned. For System Operating Procedures (SOPS), prerequisites and initial conditions are placed in one section at the front of the (SOP). A procedure revision was initiated to add steps to the appropriate sections of the procedure for operation of RHR to ensure CCW was in service prior to starting the RHR pump. However, the procedure revision was being pmcessed as a routine revision at the time of the Unit i event which occurred on September 11, 1994. Subsequently, on September 11,1994, a Temporary Procedure Change (TCP) was made j
ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-424:425/94-22 i
to procedure 13011-1/2 to include the requirement for the operation of the CCW system prior to starting the RHR pumps. A permanent change to procedure 13011-1/2 was approved on September 15,1994.
1 As a result of the September 11,1994 event on Unit 1, an Event Review team was formed to determine the cause and effects of RHR pump "B" being placed in service without CCW being in service. In addition to the procedure formatting problems, the event team identified that the involved operator was distracted by an unusually high number of calls for him concerning activities on which he was working. The day the event occurred was also the first day of the 1R5 refueling outage, which may have also contributed to this event since there was a high number of control room activities being performed.
Corrective Steps Which IIave Been Taken and the Results Achieved:
i 1.
Procedure 13011-1/2 was revised at the appropriate procedural section on September 15, 1994, in order to add the prerequisite to place CCW in service prior to starting the RHR pumps.
- 2. Immediately following the September 11,1994 event, an engineering evaluation was performed to determine what impact the event had on the RHR system and pump seal i
integrity. The evaluation found that the RHR system was operable.
- 3. Additional monitoring of the RHR pump seal performed during the remainder of Unit l's fiflh J
refueling outage (IRS) indicated proper seal performance.
Corrective Steps Which Will Be Taken to Avoid Further Violations:
- 1. A review of SOPS will be performed to consider placing critical prerequisites at the appropriate locations in the main body of the procedures. If any procedures are identified that would require a revision, the appropriate procedures will be revised by April 15,1995.
- 2. Management will evaluate by February 1995, the control room stafTmg and coordination of activities during outages.
Date When Full Compliance Will Be Achieved:
Full compliance was achieved on September 11,1994, at 1514 EST when CCW was started thereby reducing RHR temperatures.
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ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-424:425/94-22 NRC INSPECTION REPORT 50-424:425/94-22-02, VIOLATION H The following is a transcription of the second example of a violation as cited in the Notice of Violation (NOV):
"During the NRC inspection conducted on August 21 through September 17,1994, two violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," the second of the two violations is listed below.
B.
License condition 2(E) to License No. NPF-68 issued March 16,1987, and License No.
NPF-81 issued March 31,1989, requires the licensee to fully implement all provisions of the NRC approved "Alvin W. Vogtle Nuclear Plant Physical Security Plan."
Technical Specification 6.7.1 requires that written procedures shall be established, implemented, and maintained covering the activities under the Security Plan.
Paragraph 5.4.2.4 of the Physical Security Plan requires that designated vehicles inside the Protected Area (PA) not attended by an individual with unescorted access or a security oflicer as appropriate are secured to prevent movement. Possession of the keys by the authorized individual or security oflicer or physical restraint of the vehicle accomplishes this objective.
Procedure 00653-C, Protected Area Entry / Exit Control, Step 4.4.8, states that should a designated vehicle be left unattended in the PA the keys shall be kept by an authorized individual.
Contrary to the above, on September 9 and September 13,1994, one designated vehicle, i
on each respective date, was identified inside the protected area unsecured and unattended, with the keys in the ignition.
This is a Severity Level IV violation (Supplement III)."
RESPONSE TO VIOLATION B (50-424:425/94-22-02)
Admissian or Denial of the Violation:
This violation ccet.rred as stated in the notice of violation.
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ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-424:425/94-22 Reason for the Violation:
Both instances of this violation are attributed to cognitive personnel error in that the involved individuals failed to follow the requirements of procedure 00653-C, Protected Area Entry / Exit Control, which requires removing the keys from any unattended designated vehicle within the protected area (PA).
Corrective Steps Which Have Been Taken and the Results Achieved:
The individuals involved have been counseled on their failure to adhere to procedural -
requirements and remi:ded of the procedural intent relating to designated vehicles.
In view of the increased numbers of vehicles within the PA during the recent outage, personnel entering the PA with a vehicle were reminded of the procedural requirements. Additional emphasis was placed on observance of vehicles in the PA.
Corrective Steps Which Will Be Taken to Avoid Further Violations.
Emphasis will be placed on informing the appropriate personnel during outage pre-briefings of the procedural requirements for correctly utilizing designated vehicles within the PA.
Date When Full Compliance Will Be Achieved:
Full compliance was achieved on September 9 and September 13,1994, when the keys were removed from the unattended designated vehicles.
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