ML20082H308
| ML20082H308 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/07/1995 |
| From: | Mccoy C GEORGIA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LCV-0532-B, LCV-532-B, NUDOCS 9504140289 | |
| Download: ML20082H308 (3) | |
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Geo*ga Power Company
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_40 byerness Center Parkway i
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- Pact off,ce Bon 1295.
Bwungham. Natana 35?Of 1
Teephone 205 877 7122 Georgia Power c.K. ucco, Vce Prwjent Nudear Vorpe Protect the soothern e<ectrc systern
. April 7, 1995 LCV-0532-B Docket No.
50-424 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Ladies and Gentlemen:
VOGTLE ELECTRIC GENERATING PLANT REPLY TO A NOTICE OF VIOLATION Pursuant to 10 CFR 2.201, Georgia Power Company submits the enclosed information in response to a violation identified in Inspection Reports 50-424;425/95-03 which concerns the inspection conducted by the Vogtle Electric Gene ating Plant (VEGP) NRC Resident Inspectorr from January 22 - February 18,1995.
Should you have any questions feel free to contact this office.
Sincerely, N
C. K. hicCoy CKhi/AFS T
Enclosure:
Reply to NOV 50-424/95 03 01 cc: OtorgiaPower Company i
hir, J. B. Beasley, Jr.
hir, ht. Sheibani NORhtS U. S. Nuqlear Regulatory Comminiqu hir. S. D. Ebneter, Regional Administrator hir. D. S. Hood, Licensing Project hianager, NRR hir. B. R. Bonser, Senior Resident Inspector, Vogtle 140001
- iR*48EEbEE$34 Q
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ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT-UNIT 1 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425/95-03 The following is a transcription of the violation as cited in the Notice of Violation (NOV):
"During the NRC inspection conducted on January 22 through February 18,1995, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below.
Technical Specification 3.4.1.4.1, Cold shutdown - Loops Filled, requires at least one Residual ficat Removal (RIIR) train to be operable and in operation, and either one additional RHR train to be operable or the secondary side water levd of at least two steam generators to be greater -
than 17% of wide range. Implicit in this requirement is that the steam generators will be capable of performing an adequate heat removal function via natural circulation when the reactor coolant pumps are secured.
Contrary to the above, on September 16,1994, with Unit I shutdown and in Mode 5 with loops filled, and RilR train A declared inoperable, the licensee failed to ensure that the steam generators were capable of providing an adequate decay heat removal function.
This is a Severity Level IV violation (Supplement I). This violation is applicable to Unit I only."
RESPONSE TO VIOLATION (50-424/95-03-01)
Admission or Denial of the Violation:
This violation occurred as stated in the notice of violation and as reported in LER 424/94-09 submitted to the Commission on December 22,1994.
Reason for the Violation:
The cause of this violation was a lack of understanding of the plant conditions required to satisfy Technical Specification bases for using the steam generators (SGs) as a source for decay heat removal. Although the Technical Specifications (TSs) take credit for SGs as a source of decay heat removal, appropriate guidance was not provided to operators informing them that the decay heat removal capability via the SGs may have been degraded with the RCS in certain conditions. For the SGs to be available as a heat removing component as specified in the TS basis, the RCS must actually be capable of being pressurized. The removal of the pressurizer safeties therefore caused the heat removal capability, via natural circulation, to be degraded and only one train of RHR (B train) was operable. The plant conditions necessary to support the SGs as a heat 1
removing component were not clearly understood nor included in plant procedures.
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o ENCLOSURE i
VOGTLE ELECTRIC GENERATING PLANT-UNIT 1 REPLY TO NOTICE OF VIOLATION 50-424/95-03-01 NRC INSPECTION REPORTS 50-424:425/95-03 Corrective Stens Which llave Ileen Taken and the Results Achieved:
The appropriate procedures were reviewed and the procedure for unit cooldown to cold shutdown was revised to ensure that the procedural guidance provided to rely upon natural circulation is adequate for TS compliance in appropriate plant conditions.
Corrective Stens Which Will Be Taken to Avoid Further Violations:
Since the corrective action for the cited violation has been completed, no further corrective action related to the violation is warranted at this time. However as a result of a broadness review subsequent to the discovery of this condition, additional analysis of the loops filled condition determined that clarification for boration dilution events is also required As a result of this additional review, appropriate documentation will be revised i
to reflect changes for the loops filled condition by April 30,1995.
Date When Full Compliance Will lle Achieved:
Full compliance was achieved on September 16,1994, at 2350 EST, when RHR train A was declared operable thereby resulting in both trains of RHR being operable and the SGs were no longer relied upon for TS compliance.
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