ML20127B929
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UNITED STATES NUCLEAR REGULATORY COMMISSION i
In the Matter:of
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Docket No.
55-20117 William F. Kitchens.
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License No. 50P-20467-1 Vogtle Electric Generating Plant
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EA 91-064 DEMAND FOR INFORMATION I
William F. Kitchens (Licensee) is the holder of Senior Reactor Operator License No. SOP-20467-1 (License), issued by _the Nuclear Regulatory Commission (NRC or Consission) pursuant to 10 CFR Part 55_on Septenber 16, 1988. The License authorizes the Licensee to direct the licensed activities of licensed operators 1
at, and to manipulate all controls of the Georgia Power Company's ',gtle Electric Generating Plant:(VEGP), Unit 1, Facility License No. NPF-68, in accordance with conditions specified therein.
II In. January 1990, NRC Region Il received information alleging that VEGP Unit I was intentionally placed in a condition prohib;;ni by Technical Specifications.
In response to that information, the NRC initiated an investigation to determine
.the facts and circumstances of the allegation. The NRC Office of Investigations completed its investigation on March 19, 1991, and concluded that Technical Specification 3.4.1.4.2 was knowingly and willfully violated with the Licensee's express knowledge and concurrence.
J At the: time of'VEGP's first: refueling outage, the Final Safety Analysis Report, Chapter 15.4.6.2.1.1, Dilution During Refueling, required that valves 1-1208-04-175, 1-1208-U4-176, 1-1208-U4-177, and 1-1208-U4-183 be locked closed fduring refueling in. order to prevent a boron dilution accident. Technical c
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- Specification 3.4.1.4.2~ and VEGP Procedure 12006-C, " Unit Cooldown to Cold Shutdown," Section D4.2.14 were instituted as required to prevent such an inad-vertent boron dilution during Mode 5 reactor coolant loops not filled or Mode 6.
The _ Technical Specification stated, in part, " Reactor Makeup Water Storage Tank (RMWST) discharge valves (1208-U4-175, 1208-U4-176, 1208-U4-177, and 1208-U4-183) shall be closed and secured in position." The locking closed of these valves prevents-the flow of unborated water from the Reactor Makeup Water Storage Tank into the Reactor Coolant System. At that time, boron dilution flow analyses did not exist for Mode 5 reactor coolant loops not filled or Mode 6, und, since these analyses had not been done for VEGP, the above mentioned valves were required to be locked closed in Mode 5 reactor coolant loops not filled and Mode 6.
Based on the investigative findings, the NRC is concerned that the Licensee may have intentionally disregarded Technical Specifications in an apparent attempt to facilitate outage activities. Notwithstanding claims that reasonable interpretation of the Technical Specifications would allow opening of the valves for-a short period of time, the NRC concludes that the wording of the Technical
. Specification is exceptionally clear and is not open to any interpretation that would allow the intentional manipulation to the open position of the above-listed valves with the plant in the specified condition. This is viewed as a particularly significant matter because of the position held by the Licensee at the time of the event. As Operations Manager as well as a Senior Licensed Operator, it was
'the Licensee's responsibility to ensure compliance with Technical Specifications.
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Specification 3.4.1.4.2 and YEGP Procedure 12006-C, " Unit Cooldown to Cold j
Shutdown," Section D4.2.14 were instituted as lequired to prevent such an inad-vertent boron dilution during Mode 5 reactor coolant loops not filled or Mode 6.
The Technical Specification stated, in part, " Reactor Makeup Water Storage Tank 1
(RMWST) discharge valves (1208-U4-175, 1208-U4-176, 1208-U4-177, and 1208-U4-183)
.shall be closed and secured in position." The locking closed of these valves 4
prevents the' flow of unborated water from the Reactor Makeup Water Storage Tank into the Reactor Coolant System.: At that time, boron dilution flow analyses did not exist for Mode 5 reactor coolant loops not filled or Mode 6, und, since these analyses'had not been done for VEGP, the above mentioned valves were required to be locked closed in Mode 5 reactor coolant loops not filled and Mode 6.
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Based on the investigative findings, the NRC is concerned that the Licensee may have intentionally disregarded Technical Specifications in an apparent attempt to facilitate outage activities. Notwithstanding claims that reasonable interpretation of the Technical Specifications would allow opening of the valves for.a short period of time, the NRC concludes that the wording of the Technical Specification is exceptionally clear and is not open to any interpretation that
- would allow the intentional manipulation to the open position of the above-listed valves with the plant in the specified condition. This is viewed as a particularly significant matter because of the position. held by the Licensee'at the time of 4
the event.. As Operations Manager as well as a Senior Licensed Operator, it was the Licensee's responsibility to ensure compliance with Technical Specifications.
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.'A full and complete discussion of the Licensee's decision making process regarding compliance with Technical Specifications and the methods used
.to impart that process to subordinates. Specifically, the discussion should cover how the Licensee addresses Technical Specification require-i ments he does'not fully understand as well as other unusual conditions.
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A full and complete discussion regarding the Licensee's actions following the event and the Licensee's involvecent in and information provided to the VEGP Plant' Review Board in the review of the event.
i Copies also shall be sent to the Assistant General Counsel for Hearings and Enforcement at the same address as above, and to the Regional Administrator, NRC Region II,101 Marietta Street, N.W., Suite 2900, Atlanta, Georgia 30323.
After reviewing the Licensee's response, the NRC will determine whether further action is necessary to ensure compliance with regulatory requirements.
FOR THE NUCLEAR REGULATORY COMMISSION d ix o
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J hmes H. Sniezek Jeputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research Dated at Rockville, Maryland this 3<Aday of June 1991
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