ML20082V269
| ML20082V269 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 05/03/1995 |
| From: | Mccoy C GEORGIA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LCV-0601-A, LCV-601-A, NUDOCS 9505090153 | |
| Download: ML20082V269 (5) | |
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. Georg.a Power Company 40 inverness Center Parkway Post Office Box 1295 Birmingham. Atabama 35201 Telephone 205 877 7122 Georgia Power c.K. uccoy Vce Prescent. Nuclev Vogt> Prosect the southern electrc system LCV-0601-A Docket Nos. 50-424 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Gentlemen:
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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 violations identified in Vogt Electric Generating Plant (VEGP) Inspection Report Nos. 50-424/95-06 and 50-425/95-06 which concerns the inspection conducted by VEGP NRC Resident Inspectors from February 19 - March 18,1995.
Sincerely, C. K. McCoy CKM/ JAB /gmb
Enclosure:
Reply to NOV 50-424;425/95-06 Georgia Power Company cc:
Mr. J. B. Beasley, Jr.
Mr. M. Sheibani NORMS U. S. Nuclear Regulatory Commission Mr. S. D. Ebneter, Regional Administrator Mr. D. S. Hood, Licensing Project Manager, NRR Mr. B. R. Bonser, Senior Resident Inspector, Vogtle 9505090153 950503 PDR ADOCK 05000424 E
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ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT - UNITS I & 2 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425/95-06 The following is a transcription of the violation as cited in the Notice of Violation (NOV):
"During the NRC inspection conducted on February 19, through March 18,1995, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the first of the two violations is listed below.
A.
10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, requires activities affecting quality to be prescribed by documented instmetions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings.
Vogtle procedure 28835-C, Electric Hydrogen Recombiner Visual and Electrical Check, provides instmetions to verify that hydrogen recombiner electrical heater circuit integrity exists by measuring resistance to ground.
Contrary to the above, the licensee failed to prescribe activities affecting quality by documented instructions, procedures, or drawings of type appropriate to the circumstances, in that procedure 28835-C, Revision 6, failed to delineate sufficient instructions for maintenance personnel on how and where to perform the surveillance.
The failure to provide sufficient instructions contributed to the surveillance procedure being inconsistently and incompletely performed on March 14,1995. The lack of appropriate instructions resulted in the surveillance being pa~.ially performed at the incorrect system component, which resulted in the technicia not collecting all required surveillance data as specified by the procedure.
This is a Severity Level IV violation (Supplement I) (Unit 2 only)."
RESPONSE TO VIOLATION A (50-425/95-06-02)
Admission or Denial of the Violation:
The violation for failing to provide an adequate procedure occurred as stated in the notice of violation. However, the method for performing the procedure in order to meet the surveillance raquirement was documemed on appropriate data sheets in previous surveillances and was found to be acceptable. Although the surveillance requirements were met, the lack of a clear, consistent method of recording data contributed to not fully completing each procedure step.
l ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT - UNITS I & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425/95 06 Reason for the Violation:
The cause of this violation was a procedure that was inadequate for a maintenance technician that had not performed the surveillance on the hydrogen recombiner previously.
The format of the procedure was based on the technician having extensive knowledge and experience on performing the surveillance and the technician assigned this particular surveillance had not performed it previously. Procedure format for performing electrical checks was confusing to the technician thereby resulting in some procedure data not being obtained from the appropriate test points for the heater circuit.
Corrective Steps Which Have Been Taken and the Results Achieved:
- 1. Procedure 28835-C," Electric Hydrogen Recombiner Visual and Electrical Checks,"
was revised on March 24,1995, to clarify measuring resistance to ground test points.
The procedure was subsequently re-performed satisfactorily on March 24,1995.
- 2. The individuals involved were reminded of the importance of maintaining a questioning attitude when performing procedures and the actions to take when a procedure proves difficult to perform.
Corrective Steps Which Will Be Taken to Avoid Perther Violations:
Since all corrective actions have been completed, no additional corrective action is w:trranted.
Date When Full Compliance Will Be Achieved:
Full compliance was achieved on March 24,1995, when procedure 2RR35-C was revised and the surveillance was re-performed satisfactorily.
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ENCLOSURE 4
VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425/95-06 The following is a transcription of the second violation as cited in the Notice of Violation (NOV):
"During the NRC inspection conducted on February 19, through March 18,1995, violations of i
NRC requirements were identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the second of the two violations is listed below.
B.
10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires measures to be established to assure that conditions adverse to quality, such as failures, malfunctions, t
deficiencies, deviations, defective material and equipment, and nonconformances 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 preclud0 repetition.
Contrary to the above, corrective actions to preclude repetition of a e.anificant condition adverse to quality were inadequate. On September 9 and 17,1994, a failure to Follow Fjotected Area Entry / Exit Procedures involving unsecured designated vehicles in the F r:otected Area was identified as violation 50-424,425/94-22-02. The licensee's corrective 4
actions were completed on September 9 and 17, respectively. On Februay 11 and March 7,1995, repetitions of this adverse condition to quality were identified when two additional unsecured designated vehicles were found inside the Protected Area.
This is a Severity level IV violation (Supplement I)"
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RESPONSE TO VIOLATION B (50-424:425/95-06-0),J 1
Admission or Denial of the Violation:
This violation occurtW as stated in the notice of violation.
Reason for the Violation:
The cause of this violation was a failure by plant personnel to follow procedures for controlling designated vehicles within the protected area (PA). Contributing to this violation was a lack of understanding by plant personnel of what constitutes a secured vehicle. In the March 7,1995, example, the ignition switch was found to be defective thereby allowing the vehicle to be started without a key. Plant personnel utilizing this vehicle failed to notify appropriate personnel of this condition. The February 11,1995, example was attributed to a failure to follow procedural requirements and was identified during a routine Security department PA patrol. Corrective actions from the previous violation,424;425/94-22-02, were not effective in precluding the March 7 and February 11,1995, examples.
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ENCLOSURE l-VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425/95-06 Corrective Stens Which Have Been Taken and the Results Achieved:
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- 1. Security awareness meetings were held with appropriate departments to emphasize the requirements for securing vehicles within the PA. As a result of one awareness meeting with warehouse personnel on March 28,1995, it was discovered that forklias utilized within the warehouse were not being secured as required. This condition was l
attributed to a misinterpretation of the requirements by warehouse personnel. The affected forklins are now being secured as required by the VEGP Security Plan and Procedures.
- 2. An annunciator voice alarm, " KEY PRESENT ", has been added to most designated -
vehicles to remind operators not to leave the vehicle unsecured before exiting. For those vehicles where it was not practical to install the annunciator, a placard was conspicuously placed in the vehicle reminding the operator to properly secure the l
vehicle.
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- 3. Personnelinvolved were counseled and reminded ofperformance expectations and procedural requirements.
- 4. The General Employee Training " Retraining Handbook" was revised to cover the controls expected during the use of designated vehicles within the PA.
i Corrective Stens Which Will Be Taken to Avoid Further Violations:
Management will continue to monitor performance trends concerning the use of vehicles within i
the PA during 1995, in order to evaluate the effectiveness of corrective actions taken.
l Date When Full Comoliance Will Be Achieved:
Full compliance was achieved when the key was removed from the vehicle on February 11,' 1995, the vehicle with the defective ignition switch was removed from the PA on March 7,1995, and the forkliRs discovered unsecured in the warehouse were secured on March 28,1995, in accordance with the VEGP Security Plan and Procedures.
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