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VEGP-10004-C 7
2 of 3 mId' 3.4 Prior to as's.1 ming niai f t-d t i cr.,
ec. -, on e ming operatot shall:
a.
Review the narret ive log, roumis f hc ete and checklists for his atstion.
The review shall l
include narrativo logs c.nce the lac-chift worked i
or the precedin.3 5 days, hi<-hewer is itse, b.
Initici esed doeurent av it is rev! w od, c.
Discuss relevant ite.mn affecting p!^nt operation j
l with his of f-going t.o ani.erpart.
3.5 Each SS, USS, RO, B.5p and PEG chall cc ::p12te his relief l
checklist prior to asraning h.is duties and obtain completo information on carrant p1-2.t status.
3.6 If discrepancies are dir. cover +d whlie tc.:e t. in g annunciator panels, action ch01 t.
- 1. nit t stu to correct them.
i 3.7 On-coming and off-going opersto.n jr.intly walk-down their ansigned control bearh if cpplicsL'.o to verify lj checklist items and discusy equip:ter t st uas.
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abnormal. lineups or off rurnal rara'itione are roted on h
the checklist.
3.0 The on-coming and off-qc'.,9 Ur.it Shift fauparriser (USS) i shall jointly walk-down che ccotrol bocedo.
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'The Shift Superintendent.' S S ), or bis de:r gtm.c. should conduct a shift briefing tor 9.titt cpora!. a when
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3.10 After review by the SS, ca.T.plev.d indiviixl pcsition j
checklj sts a*e forwcrdad to DocuMot Cont ol, thru the i
Superintendent Unit (Shift Op<ra.i.>s).
3 3.11 When they have comp:ctc 3 shif rM :<.f and.sssamed the duties of thejr position.
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Non licensed <)peretors shall MAe e : eport. to the g
Control Doom, I
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Ranctor Operator, P. eland ef Plant oper.3 tor and Shift Support Supervisor chsl.'. :eport tu t.he Unit Shif t Sup<. rvise:,
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.j-Mathng Address-40 inverness Center Parkway Post Othee Box 1295 "I
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Ine southern ecectic systerr R. P. Mcdonald Executive Vice President Nuclear Operations April 1, 1991 ELV-02684 1213 Docket Nos.
50-424 50-425 U. S. Nuclear Regulatory Commission Washington, D. C.
20555 ATTN: ' Thomas E. Murley, Director Office of Nuclear Reactor Regulation i
Gentlemen:
V0GTLE ELECTRIC GENERATING PLANT REGARDING PETITION OF M. B. HOBBY AND A. L. MOSBAUGH By letter dated February 28, 1991, the NRC requested Georgia Power Company
("GPC"orthe" Company")toprovideadditionalinformationconcerningarequest for proceedings filed with the NRC by counsel for Messrs. Marvin B. Hobby and Allen L. Mosbaugh (the " petitioners"). Enclosed herewith, GPC provides additional information supplementing its September 28, 1990 letter concerning petitioners' September 11, 1990 request for proceedings, as well as information responding to the allegations contained in the petitioners' October 1,1990 i
supplemental letter.
The information provided herein is true and correct to the best of my knowledge.
Sincerely, e
Mr. R. P. Mcdonald RPM / JAB /cir Sworn to and signed before me
-this Y
day of [
, 1991.
/
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Notary $blic
.q' WCOMSSON EXPRES MNUM12,1993
/
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Georgia Power A U. S. Nuclear Regulatory Commission ELV-02684 1
Page 2 xc: Georaia Power ComRADY Mr. A. W. Dahlberg (w/o Volume II)
Mr. W. G. Hairston, III (w/o Volume II)
Mr. C. K. McCoy (w/o Volume II)
Mr. W. B. Shipman (w/o Volume II)
Mr. P. D. Rushton (w/o Volume II)
Mr. J. T. Beckham (w/o Volume II)
Mr. S. H. Chesnut (w/o Volume II) l l
NORMS (w/o Volume II)
U. S. Nuclear Reaulatory Commission i
Mr. S. D. Ebneter, Regional Administrator (w/ Volume II)
Mr. D. S. Hood, Licensing Project Manager, NRR (w/ Volume II)
Mr. B. R. Bonser, Senior Resident Inspector, Vogtle (w/ Volume II)
Document Control Desk (w/ Volume II) l 1
I
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ENCLOSURB l'
ADDITIONAL INFORMATION REGARDING THE HOBBY /MOSBAUGH PETITION i
i
Background
By letter dated Sept' ember 11, 1990, legal counsel for the petitioners submitted to the NRC a request that NRC institute licensing-proceedings (the " Petition").
The Petition contained a list of nine allegations, only some of which were supported by alleged examples.
The attachments referred to in that Petition were forwarded to the NRC on September 21, 1990.
On September 1
28, 1990, GPC provided the NRC with a brief, initial response to
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the Petition which demonstrated, to the extent of the information available at the time, the inappropriateness of a proceeding as requested by the'patitioners.
The Company also indicated that j
'the petitioners were abusing the NRC process-for identifying safety concerns and for requests for proceedings for the purpose j
of merely' improving their chances of obtaining a negotiated i
settlement of the Department of cases which they had brought against the Compar4y.pabor (" DOL")
i On October 1, 1990, the petitioners filed with the NRC a l
document entitled " Supplemental Information to the September 11, 1990 Hobby /Mosbaugh Petition Concerning the Illegal Transfer of Control,of Georgia Power Company's Licenses to SONOPCO" (the "Supploment") containing four allegations intended to support their previously-raised " illegal license transfer" allegation.
On October 23, 1990, the NRC adv~ised the petitioners' counsel j
that it had received the Petition and the Supplement and that they had been referred to the Director of NRC's Office of Nuclear Reactor Regulation (the " Director") for preparation of a decision i
pursuant to 10 C.F.R. S 2.206.
The NRC also concluded that no immediate action was necessary based on several NRC investiget ans and inspections at the Vogtle Electric Generating Plant ("VEPG" or "Vogtle") aimed at determining the facts surrounding several allegations and the safety significance of various issues.
On February 28, 1991, the NRC requested GPC to provide additional information within 30 days concerning the allegations raised in the Petition and the Supplement.
1Because the Petition contains. allegations based on wild speculation, obvious matetial omissions and inaccurate statements, GPC questions whether petitioners' counsel had authority to submit the Petition to the NRC on behalf of the petitioners.
The NRC might inquire whether the petitioners would
- attest to the accuracy of the statements contained in the Petition.
^
In the attachments to this Enclosure, the Company provides further information addressing each of the broad allegations raised in the Petition including information concerning the alleged examples included in the Petition and the Supplement.2 j
Due to the lack of specificity of several allegations and the general nature of the February 28, 1991 request, this response may not address areas for which the Director desires more extensive information.
If such is the case, GPC suggests that a further request for information is appropriate rather than the initiation of proceedings, particularly when the petitioners have failed to adequately identify factual bases for allegations.
The balance of.this Enclosure (1) provides an update of the petitioners' DOL actions, (2) discusses the legal requirements applicable to Section 2.206 petitions as applied to the petitioners, (3) discusses the NRC Staff evaluations of Vogtle operations which negate the need for the requested proceeding, and (4) provides the Company's overall conclusions respecting the Petition.
UDdate of Petitioners' DOL Actions The Company's September 28, 1990 letter described three
)
DOL actions filed by petitioners, one by Mr. Hobby and two by Mr. Mosbaugh, and the DOL preliminary findings in favor of GPC in those actions.
Both petitioners appealed those DOL decisions.
)
In October and November of 1990, Mr. Hobby's appeal was heard by DOL Administrative Law Judge Joel R. Williams.
Judge Williams' decision in the Hobby v. GPC proceeding is pending.
Mr. Mosbaugh filed a third complaint against GPC with DOL under Section 210 of the Energy Reorganization Act of 1974 on September 19, 1990, which he subsequently amended on October 17, 1990.
That complaint alleges that adverse employment action was taken against him because he provided the NRC " evidence of criminal conduct" and because he filed the Petition.
On November 16, 1990, the DOL investigator issued a preliminary
~
decision, in favor of Mr. Mosbaugh, which concluded that "the weight of the evidence to date" indicated that discrimination for engaging in protected activities "was a factor in the actions which comprise his complaint."
A full, de novo evidentiary l.
i 2'For the commission's convenience, the attachments are
. numbered to correspond to the numbers assigned to the allegations in-Section III of the Petition (see the " List of Attachments" which appears at the end of this Enclosure).
2 i'
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,,_m
hearing of that third pomplaint, consolidated with the second complaint, is pending.
In Hobby v. GPC, numerous depositions were taken and extensive testimony (944 transcript pages) was heard before the DOL.
Significant portions of that record are relevsnt to certain of the allegations raised in the Petition (agg Sections III.1, III.2 and III.4) and items 1, 2 and 3 of the supplement.
Likewise, but to a lesser extent, some of the deposition testimony taken in Mosbauch v. GPC is relevant to the Petition's allegations (333 footnote 1 of the Supplement).
As a res:11t, the Company's detailed responses provided herein concerning those allegationsgorrowfromthedepositionandtrialtestimonyin those cases.
A copy of the pertinent pages from the various transcripts cited in the attached GPC responses is provided in a separately bound document enclosed herewith and entitled
" Volume II - Transcript Excerpts."
The Company maintains that the petitioners' primary and controlling motivation for their filings is to obtain a favorable result in their DOL actions against GPC.
In addition to the j
information provided in the Company's September 28, 1990 letter, a recent order issued by DOL Administrative Law Judge Bernard J.
Gilday, Jr. supports the Company's position in this regard.
On February 19, 1991, Judge Gilday, who was assigned the appeal of l
Mr. Mosbaugh's first complaint, granted the NRC's motion for a partial stay of execution of an order which compelled l
Mr. Mosbaugh to produce certain documents.
Judge Gilday I
questioned Mr. Mosbaugh's motives and goals, as well as the techniques of his counsel, because it was the second time that s
Mr. Mosbaugh had " trotted to the [NRC) for comfort, relief and solace" when he was confronted with an order to produce documentation.
Judge Gilday further stated that it appeared some of the documents Mr. Mosbaugh delivered to the NRC in January 1991 had not been previously disclosed to the NRC.
A copy of Judge Gilday's order is attached to this Enclosure.
Additionally, on February 14, 1991, when the NRC offered to return to Mr. Mosbaugh many of the tape recordings which he delivered to the NRC, Mr. Mosbaugh refused to accept them.
At 3Any one or more of the DOL proceedings brought by Mr.
.Mosbaugh are hereinafter referred to as Mosbauch v. GPC.
' References in the attached GPC responses to the depositions taken in Hobby v. GPC and Mosbauch v. GPC are identified as
"(name of deponent)- (date of deposition) Dep. at XX."
References i
herein to the transcript of the Hobby trial appear as " Trial Tr.
t at XX."
i l
l*
the time, Mr. Mosbaugh was under a DOL order to deliver the tapes to GPC when he received them from the NRC.
On February 19, 1991, i
Mr. Mosbaugh withdrew his first DOL complaint against GPC, which negated the DOL order in that case requiring him to deliver the tapes to GPC.
GPC contends that this information calls into i
question the foundation of the petitioners' allegations and is a proper consideration of the Director in reaching a decision.
l The Leaal Reauirements For Section 2.206 Petitions In response to a petition filed pursuant'to 10 C.F.R.
S 2.206, the Director must reach the conclusion that substantial health'or safety issues have been raised before granting requested relief, including the initiation of a proceeding.
4 1
Consolidated Edison Co. of N.Y.
(Indian Point, Units 1, 2 and 3),
i CLI-75-8, 2'NRC 173, 176 (1975).
A mere dispute over factual issues will not suffice to support such a conclusion and the Director is required to make an " inquiry appropriate to the facts asserted."
Id at 175-76.
The Director "is not required to accord presumptive validity to every assertion of fact, irrespective of its degree of substantiation, or to convene an adjudicatory proceeding in order to determine whether an adjudicatory proceeding is warranted.
Rather, his role at this preliminary stage is to obtain and assess the information he believes necessary to make that determination.
Provided he does not abuse his discretion, he is free to rely on a variety of sources of information, including staff analyses of generic issues, documents issued by other agencies, and the comments of 1
the licensee on the factual allegations."
Northern Indiana Public Service Co. (Bailly Generating Station, Nuclear-1), CLI-78-7, 7 NRC 429, 432-33 (1978).
In the case of the Hobby /Mosbaugh Petition, the Director's task, therefors, is to first determine whether the Petition raises any substantial health or safety issues based on credible i
and probative evidence.
The Consolidated Edison case dictates that mere allegations such as those submitted by the petitioners i
do not establish a basis for granting relief pursuant to Section 2.206; the Director-must conduct an appropriate inquiry.
A careful inquiry is especially appropriate where the licensee, as in this case, disputes the factual allegations of the 1
petitioners.
And, in the course of his inquiry into the i
Petition's allegations, it is appropriate for the Director to rely on (1) the NRC Staff's inspections and evaluations which are relevant to the allegations, (2) the testimony taken in the related DOL cases, and (3) the information provided by GPC in this response,.in the Company's September 28, 1990 letter, during NRC inspections, and, if requested, further responses.
Previous Director's Decisions which illustrate application of the substantial health or safety issue standard to Section 4
e N A.'- -
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____ -~_ _ _ _ _ _ _ _ _ _ _._ __
2.206 petitions include: Philadelnhia Electric Co. (Limerick Generating Station, Units 1 and 2), DD-85-11, 22 NRC 149 (1985);
Wolf creak muclear oneratina corn. (Wolf Creek Generating Station, Unit 1), DD-89-4, 29 NRC 545 (1989) and Florida Power &
Liaht Co.,
(Turkey Point Nuclear Generating Plant, Units 3 and 4), DD-89-5, 30 NRC 73 (1989).. Those Director's Decisions illustrate that the petitioners bear a heavy burden in establishing that a substantial health or safety issue exists.
For example, the identification of violations of NRC requirements and unsatisfactory management practices did not constitute sufficient grounds in those cases for the issuance of a show-cause order.
A Section 2.206 petitioner must also demonstrate that such violations and practices evidence a pattern of inadequate management oversight indicative of an overall progr===mtic breakdown.
Limerick, 22 NRC at 161-62; Wolf Creek, 29 NRC at 551-52; Turkey Point, 30 NRC at 78-79, 83.
Furthermore, those same Director's Decisions have placed great emphasis on whether licensees have attempted to cure the identified deficiencies in plant operations.
Provided the licensee has taken steps to correct problems identified in a Section 2.206 petition, a show cause order is generally unwarranted notwithstanding remaining isolated areas where corrective action is needed.
Limerick, 22 NRC at 161-62; HQlf Creek, 29 NRC at 551-52; Turkey Point, 30 NRC at 80-83.
The Company contends that the.above Directors' Decisions correctly apply the legal requirements for Section 2.206 petitions and establish that the proper decision in this case is for the Director to deny the Petition in its entirety for failure to raise any substantial health or safety issue.
Based on the NRC Staff evaluations to date, any deficiencies in GPC's Vogtle-related operations identified by the Petition's allegations are clearly isolated incidents which do not show a pattern of inadequate management oversight and are of relatively minor safety significance.
Such deficiencies can appropriately be addressed by the NRC in the routine exercise of its inspection and enforcement authority and, therefore, are not an appropriate i
basis ~on which to issue a show cause order.
333, aenerally, H211 creek, suora.
Furthermore, the Company has taken steps to correct identified deficiencies; it consistently takes corrective action when the NRC, or GPC itself for that matter, identifies violations or areas requiring attention.
j Additionally, petitions reviewed under Section 2.206 must meet certain minimum standards before the NRC makes the inquiry described above.
In addition to specifying the action requested, a petition must " set forth the facts that constitute the basis for the request," and absent such a showing by a petitioner the
-petition should be denied.
Duke Power Co. (Oconee Nuclear
' Station, Units 1, 2 and 3), DD-79-6, 9 NRC 661, 661-62 (1979);
Limerick, 22 NRC at 154; Turkey Point, 30 NRC at 75; 10 C.F.R.
S 4
2.206(a).
Certain of the Petition's allegations fail to meet 5
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f.
i
- f.
- i 1
this specificity requirement, including items III.5, III.6(d),
III.7 and III.9.
Therefore, the Director should deny the Petition with respect to those allegations for failure to meet the minimum requirements applicable to Section 2.206 petitions.
1 i
The NRC Staff Evaluations of Voctie i
4 On August 6 through 17, 1990, the NRC conducted an 3
Operational Safety Inspection at Vogtle following the receipt of
{
several allegations related to operational activities which the j
Company believes were submitted by Mr. Mosbaugh.
The inspection
{
was conducted by two inspection groups -- an operations follow-up group and an allegations follow-up group.
The allegations i
follow-up group examined the technical validity and safety 4
significance of each of the allegations with the assistance of l
tha NRC Office of Investigations ("OI").
On January 11, 1991, the NRC issued Inspection Report Nos. 50-424/90-19 and 50-425/90-i 19 (the " Inspection Report") which provided the results of the operations follow-up group inspection.
Although two level-four violations were identified, the' inspection report's primary l
conclusion was that the facility "was operated in a safe manner 1
in accordance with the requirements of the licensee's operating license."
In addition, several operational practices were identified which, while complying with NRC requiraments, could be enhanced.
Further, the operations follow-up group made factual j
determinations which are relevant to certain allegations raised i
in the Petition.
For example, the Inspection Report includes findings concerning VEGP-Technical Specification interpretations (pp. 7-9), voluntary entry into limiting conditions for operation j
(p. 15) and completed surveillance procedures (p. 27).
Therefore, the Inspection Report supports a finding by the Director that no substantial health or safety issue is raised by j
certain of the Petition's allegations..
The NRC's OI has also conducted an investigation of certain operational activities at Vogtle which are addressed in Sections III.6(a) and (b) of the Petition.
The results of that l
investigation have not been provided to the Company to date.
However, the company is confident that the OI investigators have determined that Mr. Mosbaugh historically submitted allegations to the NRC which are largely based on unsubstantiated hearsay, j
speculation, and limited personal knowledge.
On December 10, 1990, the NRC issued a Systematic Assessment of Licensee Performance report for the Vogtle facility covering ths period october 1, 1989 through September 30, 1990 (the "SALP i-Report").
That SALP Report concluded that during the assessment period Vogtle "has been operated.in a sAtu runner" although operational occurrences and inspections had Jdentified areas requiring attention.
The SALP Report assionsd ratings of "2" or above to all assessment areas except emergency preparedness and l
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security.
The emergency preparedness area is not a subject of the Petition's allegations.
In the area of security, the SALP i
Report notes (p. 2) that GPC continues to experience difficulty although improvements were noted in training, armed responsa j
capability, and search equipment.
However, relevant to the i
Petition's allegations is the SALP Report's finding (p. 17) that i
an on-site review of safeguards events indicated proper identification and reporting by GPC.
i conclusion j
The Company respectfully submits that, based on the NRC Staff evaluations to date and the information provided to the NRC by the Company, and considering the motivation for, the lack of merit and detail and the speculative nature of, the Petition, the Director should deny the Hobby /Mosbaugh Petition.
Any deficiencies in GPC's Vogtle-related operations to date, or which might be identified by on-going NRC evaluations, are isolated in 2
nature and of relatively minor safety significance, and are being, or can be, appropriately addressed through the NRC's i
routine. inspection and enforcement authority.
The deficiencies 1
l identified by the Petition have been, or can be, adequately addressed by licensee corrective action and do not indicate a programatic breakdown or otherwise raise a substantial health or safety issue.
Therefore, the Company respectfully requests the i
l Director to deny the relief requested by the petitioners for i
failure to raise any substantial health or safety issue.
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7
LIST OF ATTACEMENTS GPC Response to Section III.1 of the Petition and the October 1, 1990 Supplement.
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GPC Response to Section III.2 of the Petition.
GPC Response to Section III.3 of the
)
Petition.
GPC Response to Section III.4 of the Petition.
GPC Response to Section III.5 of the Petition.
GPC Response to Sections III.6(a) and (a) & (b)
(b) of the Petition.
GPC Response to Section III.6(c) of the (c)
Petition.
GPC Response to Section III.6(d) of the (d) 1 Petition.
GPC Response to Sections III.6(e) (1), (e)
(e) (ii) and (e) (iii) of the Petition.
GPC Response to Section III.7 of the Petition.
GPC Response to Section III.8 of the i
Petition.
GPC Response to Section III.9 of the Petition.
=ADMzN ocsG4 And
- c. c 1 oso W Ammwaveentm Judoes
(
.S. Department of Labor ass ww evoet, suas soo cmous.oue sem l
ss i
IN TBE NATTER OF e
i
, ALLEN MOSBAUGH, FEB191991 j
one.
1 v.
Case No: 90-ERA-58 a
e GEORGIA PONER COMPANY, 4
s l
Respondent 8 : : : : : : : : : : : : : : : : :
ORDER GRANTING MOTION FOR PARTIAL STAT 0F EKRCUTION _OF ORDER 'm_urnNG ::F4MD
}
l JANUARY 22,199J 1850np i l stay of The Nuclear Regulatory commission has moved for a part a issued on execution of the Order Granting Motion To Compel, teen on the ground that disclosure of seven l
f documents could seriously comproatse the investigation od saf January 22, 1991, f
Respondent for alleged violations of health an ding, but not Respondent's stout opposition to this action, inclu d privilege, prejudice in the preparation of d d the 1
is spread upon l
questionable tactics and practices of Complainant duce and his the record.
For a second time, when confronted with an order To Pro l-d to the back literaily against the wall, Complainant has trotte t
l ce. On Nuclear Regulatory Commission for comfort, relief and s l
l by* Respondent, esistence of which was hidden until he was deposed 12, 1990, l
tect september were delivered to the Nuclear Regulatory Commission. To pro but to an on-going investigation, the Commission had no choice 13, 1990, a stay of I-intervene, seek and obtain, on September 29, 1991, esecution of an order Compelling Production. On January h
Order to the date when Complainant faced compliance with anot er documents, Produce, he' delivered approximately twenty bones of l.
Eeadquarters.
which were subject to this Order, to Region II 0:
been It appears that some of the delivered docum l inant l
tigation.
well knew of and had contributed to the Commiss his true complaimant's actions raise serious questions, not only h iques which l
motives and goals, but also about the quality d
i; l
d time, on fair play been exhibited, substantial effort, expense an i
t appears to the part of many, would have been saved. A ersonally l
l t
m designed. Be that as it may, the merits of the Commission's motion must be addressed.
by Movant maintains that release of seventeen docum Complainant to NRC Investigator Robinson could seriously l tions, compromise the investigation of alleged violations of MRC regu a l
some of which could or may be criminal in nature. It is a sof Understan l
Appropriately noted that a Memorandum o ides Nuclear Regulatory Commission and the Department of Labor prov for cooperation so that administrative efficiency a f
delay Privilege argument, thusly, is non-persuasive. Additionally,thho in prov: ding discovery to Respondent is not tantamount to wi d
discovery. However, RespondentJs right, hereafter, to claim an lly establish prejudice because of Complainant's actions is fu i l 8tay reserved. I find, therefore, that the Motion For Part aOrder Compelling 22, 1991 of Execution of the January is well taken and 'must be granted.
b d
WHEREFORE, IT IS ORDERED that each and all of the docum made a part hereof and incorporated herein a l t ly 22, as if rewritten, be and they are hereby exempt from the January 1991 Order Compelling Production until the Nuclear Regulatory l
of Commission notifies the Parties and this Tribunal that l
Commission said documents would not compromise the Nuclear Regu atory investigation and/or possible referral to the Department of J li t
an exact Upon release of any or all of said documents to Comp a nan,
ith, be copy of every document returned to Complainant shall, forthw delivered by Complainant to Respondent.
n %. -
ne
_ BERNARD J GILDAyURW ADMINIS IVE LAW JUDGE 1
l O
a 1
v h.:
3 ALLEGATION REVIEW PANEL RII-91-A-0065 0FFICIALUSEONLY SPECIAL W DLING REQUIRED RETURN THIS DOCUMENT TO EICS WHEN NO LONGER REQUIRED THIS DOCUMENT MUST BE SECURED WHEN NOT PERSONALLY ATTENDED. ACCESS TO IWORMATION CONTADED HEREIN IS LIRITED TO THE REGION II EWORCEMENT & INVESTIGATION COORDINATION STAFF AND AUTHORIZED REDION II STAFF MERBERS. DISCLOSURE OF INFORRATION TO UNAUTHORIZED PERSONS IS PROHIBITED.
' SUBJECT ALLEGED INACCURATE INFORMATION PROVIDED BY LICENSEE MANAGER DURING DEPARTNENT Of LABOR HEARING
. FACIL I TY:
GEORGIA POWER CONPANY DISTRIBUTION:
DA TE: APRIL 2, 1991 EBNETER W MILHOAN W JENKINS hf REYES Bf]
VERRELLI []
SINKULE []
HERDT W GIBSON []
JULIAN []
PEEBLES []
_STOHR []
COLLINS []
CLINE []
URYC W TODD []
DEMIRANDA.[]
VORSE M OTHER []
j
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ALLEGATION REVIEW PANEL SCHEDUL$D FOR:
AT LOCA TIONI f
$ $ $ NOTE FOR MRDT PLEASE SCMDULE ALLEGATION REVIEW PANEL AND
?
ADVISE JNDIVIDUALS. INDICATED ABOVE.
l 4
2-o
A i
i MEMORANDUM FOR CASE FILE
SUBJECT:
ALLEGED INACCURATE INFORMATION PROVIDED TO DEPARTMENT OF LABOR l
DURING ADMINISTRATIVE HEARING i
FACILITY: GEORGIA POWER COMPANY FILE NO: RII-91-A-9665 DATE RECEIVED: MARCH 26, 1991 TIME RECEIVED: 8:15 A.M.
DATE PREPARED: APRIL 02, 1991 PREPARED BY: BRUNO URYC, JR.
SUMMARY
OF IWORMATION: On March 26, 1991 L. ROBINSON, DI/RII, provided the enclosed document which he received from M. KOHN, an attorney representing Mr.
i A. MOSBAUOH and M. HOBBY. ROBINSON advised that he was providing the letter as an allegation received from KOHN for whatever action deemed appropriate by the staff.
1 1
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trc!rar m26199q11 l'
xoss. xoss a cowmro, p.e.
ATTO R N EYS AT t.AW WASM N 8308 334 4.30001 a.
3 March a2, 19el l
- 'r.::::
- =:::::
l
,CONFIDEN m
m Via Facsimile 1
j Larry Robinson Office of Investigations j
U.S. Nuclear Regulatory Commission Dear Mr. Robinsont While reviewing depositions taken earlier during Mr.
Allen Mosbough's section 210 case,Mr. R.P. Mcdonald made a I have found evidence demonstrating,ataminimum[sknowledgeabouttheNRC-CI that-falso statement regarding h j
investigation into the "mid loop" issue.
Attached hereto, are excerpts of deposition transcripts of Mr. Arthur Domby and Mr. R.P. Mcdonald. The depositions i
wre taken under oath, g
Domby Depo. Tr. at p. 4.,gg, Mcdonald Depo. Tr. at p. 4 and Mr. Domby testified that he first learned of the NRC-CI 4
"a few days prior to... January 30th when the first interviews were held R. Patrick Mcdonald.A" and that he learned of it from "Mr.
)
Domby Depo. Tr. at p. 6.
Mr.
Mcdonald apparently testified falsely when he stated that the first he learned about the NRC-CI investigation was "when the OI investigator came to Plant Vogtle." Mcdonald Depo. at 19.
Mr. Mcdonald stated that his " starting knowledge" of the investigation commenced when the a0I inspector came on site."
Id., at p. 22.
Hobby,y clients M
Mr. Allen L. Mosbaugh and Mr. Marvin B.
request khat NRC-01 investigate whether Mr. Mcdonald
. knowingly made a falso statement under oath (i.e. whether he, in fact, had knowledge of NRC-CI's investigation prior to NRC-0Z's arrival on site).
On behalf of Masrs. Mosbaugh and Hobby, I remain sincerely, LW
\\
Michael D. Kohn
-65b/ rob i
d ALLEGATION REVIEW PANEL
SUBJECT:
ALLEGED INTEGRITY ISSUE INVOLVING LICENSEE SENIOR MANAGER i
FACILITY:
GEORGIA POWER COMPANY FILE NO:
RII-91-A-0065 DATE RECEIVED:
04/05/91 PARTICIPANTS:
REYES, URYC, JENKINS, ROBINSON, HERDT PREPARED BY:
BRUNO URYC. JR.
i
~
SUMMARY
OF INFORMATION:
An Al1egation Review Panel was conducted to evaluate the above allegation.
The Panel found insufficient evidence and information to warrant this matter being referred to DI for investigation.
ROBINSON explained the details of the request and provided background as to why the letter was sent.
It was noted that the ALLEGER is accusing the senior manager of knowingly making a false statement under oath, when there is the possibility that the attorney may have provided inaccurate information.
Consideration was also given the length of time that elapsed between the start of the investigation and the date of DOL testimony.
There was not a radical difference in the actual days being contested and there is the possibility that the senior manager provided information to the best of his recollection.
There is also no reason to suspect why the senior manager would not provide accurate information unless there is some motive or agenda that the ALLEGER has not provided.
ROBINSON also advised that he discussed this matter with OGC (MULLINS) who advised ROBINSON that providing inaccurate information to DOL does not constitute providing inaccurate information to the NRC.
Furthermore, there is no regulatory requirement that would have been violated in this case.
This allegation simply raises the question as to the alleged truthfulness of testimony and does not impact on NRC regulatory actions.
The Panel directed that JENKINS prepare a letter to the ALLEGER explaining that the allegation was evaluated and that no action would be taken.
The ALLEGER is to be advised that he should provide his information to the Administrative Law Judge that heard the case.
f / [ h/
ACTION:
URYC to prepare draft letter for review by JENKINS.
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Mi-04 aA5 /
UNITE 3 STATES
-/jptateuqg NUCLEAR REGULATORY COMMIS$10N 4.
y REGION u 7,,,,Of 3
]
101 MARIETTA STREET, N.W.
'j" t
ATLANTA, GEORGI A 30323 J
/
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APR 161991
'Doclif *Nos. 50-424, 50-425 License Nos. NPF-68, NPF-81 i
i l
r Georgia Power Company i
ATTN: Mr. W. G. Hairston, III j.
Nuclear Operations Senior Vice President -
3 P. O. Box 1295 j
Birmingham, AL 35201
/
Gentlemen:
i j
SUBJECT:
NRC INSPECTION REPORT N05. 50-424/91-05 AND 50-425/91-05
-This refers to the inspection conducted by Brian Bonser of this office on February 24 - March 23,1991.
The inspection included a review of activities authorized for your Vogtle facility. At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the i
enclosed inspection report.
Areas examined during the inspection are identified in the report.
Within i
these areas, the inspection consisted of selective examinations of procedures i
and representative records, interviews with personnel, and observation of activities in progress.
1
'Within the scope of the inspection, no violations or deviations were identified.
I In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of j
this letter and the enclosure will be placed in the NRC Public Document Room.
Should you have any questions concerning this letter, please contact us.
Sincerely,
[
(!)!
Alan R. Herdt, Chief 4
Reactor Projects Branch 3 Division of Reactor Projects
Enclosure:
NRC Inspection Re, port ec w/ encl:.(Seepage 2).
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-i Georgia Power Company 2
gpg i
~ cc w/enci:
R. P. Mcdonald Executive Vice President-Nuclear Operations i
Georgia Power Company
.P. O. Box 1295 Birmingham, AL 35201 4
C. K. McCoy Vice President-Nuclear Georgia Power Company P. O. 1295 Birmingham, AL 35201 W. B. Shipman 4
General Manager, Nuclear Operations Georgia ~ Power Company P. O. 1600 Waynesboro, GA 30830 J..A. Bailey Manager-Licensing Georgia Power Company P. O. Box 1295 Birmingham, AL 35201
' D. Kirkland, III, Counsel Office of the Consumer's Utility Council Suite 225, 32 Peachtree Street, NE Atlanta, GA 30302 4
Office of Planning and Budget Room 6158 270 Washington Street, SW Atlanta, GA 30334 Office of the County Commissioner Burke County Connission Waynesboro, GA 30830 Joe'D. Tanner, Connissioner 4
Department of Natural Resources 205 Butler Street, SE, Suite 1252.
Atlanta, GA 30334 Thomas Hill, Manager Radioactive Materials Program Department of Natural Resources 878 Peachtree St., NE..-Room 600
. Atlanta, GA '30309 4
(ce w/enci cont'd - see page 3)
>re Power Company 3
APR 16 53; w/ enc 1:.(Continued)-
- orney General i Department
' Judicial Building anta, GA 30334 i S2ith:
> gram Director of 2ower Production iethorpe Power Corporation Crescent Centre
<er, GA 30085 tries A, Patrizia, Esq.
41, Hastings, Janofsky & Walker
)
- h Floor.
'O Connecticut Avenue, NW l
.11ngton, D. C.-
20036 i
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DETAILS 1.
Persons Co'ntacted Licensee Employees
- H. Beacher Senior Plant Engineer J. Beasley, Manager Operations S. Bradley, Engineering Supervisor
- S. Chesnut, Manager Technical Support
' *C. Christiansen, Safety Audit and Engineering Group Supervisor C. Coursey, Maintenance Superintendent
- T. Greene, Assistant General Manager Plant Support
- H. Handfinger, Manager Maintenance M. Hobbs, I&C Superintendent
- K. Holmes, Manager Training and Emergency Preparedness
- M. Horton, Manager Engineering Support
- 0. Huyck, Nuclear Security Manager
- W. Kitchens, Assistant General Manager Plant Operations
- R. LeGrand, Manager Health Physics and Chemistry
- G. McCarley, Independent Safety Engineering Group Supervisor
- M. Sheibani, Nuclear Safety and Compliance Supervisor - Acting
- W. Shipman, General Manager Nuclear Plant
- C. Stinespring, Manager Plant Administration
- J. Swartzwelder Manager Outage and Planning Operations Other licensee employees contacted included technicians, supervisors, engineers, operators, maintenance personnel, quality control inspectors,
'and-office personnel.
Olgethorpe Power Company Representative
- E. Toupin NRC Resident Inspectors l
- B. Bonser
- D. Starkey.
- P. Balmain i
- Attended Exit Interview 4
1 An alphabetical list of acronyms and initialisms is located in the last
. aragraph of the inspection report.
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I 2..
Plant Operations - (71707) a.
General f
The. inspection staff reviewed plant operations throughout the reporting period to verify conformance with regulatory requirements, Technical Specifications, and administrative controls. Control logs, j
shift supervisors' logs, shift relief records, LCO status logs, night i
orders and standing orders, lifted wires and jumper logs, and clearance logs were routinely reviewed. Discussions were conducted with plant operations, maintenance, chemistry, health physics, i
engineering support and technical support personnel. Daily plant status meetings were routinely attended.
t Activities within the control room were monitored during shifts and i
shift changes. Actions observed were conducted as required by the licensee's procedures. The complement of licensed personnel on each shift met or exceeded the minimum required by TSs. Direct observations were conducted of control room panels, instrumentation and recorder traces-important to safety. Operating parameters were observed to verify they were within TS limits. The inspectors also reviewed DCs to determine whether the licensee was appropriately documenting problems and implementing corrective actions.
Plant tours were taken during the reporting period on a routine i
basis. They included, but were not limited to, the turbine building, the auxiliary building, electrical equipment rooms, cable spreading rooms, NSCW towers. DG buildings, AFW buildings and the low voltage switchyard.
During plant tours, housekeeping, security, equipment status and radiation control practices were observed.
I The inspectors verified that the licensee's health physics policies / procedures were followed. This included observation of HP practices and review of area surveys, radiation work permits, postings, and instrument calibration.
The-inspectors verified that the security organization was properly manned and security personnel were capable of perfoming their assigned functions; persons and packages were checked prior to entry
.into the PA; vehicles were properly authorized, searched, and escorted within the PA; persons within the PA displayed photo identification badges; and personnel in vital areas were authorized.
b.
Unit 1 Summary The unit began the-period operating at full power. On February 25,
' power was reduced to 90% for replacement of heater drain pump A due to high vibration.. Power was reduced further on February 28 to approximately 80% due to~ potential electrical grid instabilities a.
i 3
resulting from the West Macintosh 500 KV line being out of service.
Power was returned to 90% on March 5, repairs to HDP A were completed l
and power was increased to 99%. On March 6, an ESF actuation i
occurred due to a voltage transient on the B train de system that i
resulted in a control room ventilation and containment ventilation f
isolation..The ESF actuation had no effect on power operations. The unit operated at full power through the end of the report period.
c.
Unit 2 Summary The unit began the period in Mode 3 following an automatic reactor trip on Overtemperature Delta T due to a circuit card failure. On j
February 24, criticality was achieved; the unit entered Mode 1 and
]
the main generator was tied to the grid. The unit reached 100% power l
on February 25 and operated a.t full power until March 16. On March 16, the unit was shutdown for a planned outage to install a main j
turbine EHC modification and to repair a leak on a SG #4 handhole.
j The unit achieved criticality and the generator was tied to the grid 4
on March 24.
d.
Unplanned Emergency Diesel Generator Start On March 21, during performance of procedure 14608-1 SSPS Slave l
Relay K601 Train A Test Safety Injection, an unplanned start of the l
1A EDG occurred. Personnel performing the surveillance had i
incorrectly depressed the " Test SI" push button instead of the "SI OR l
U/V Test Output Switch 1A & IC" as called for in the procedure. The personnel involved had walked.through the procedure prior to its performance and during the walk through had incorrectly identified which test push button'was to be used. Three licensed personnel were present during the walkdown and none noticed that the panel pushbutton which they intended to use was not the one described in j
the procedure. This event was not considered to be reportable since the EDGs are not, by definition. ESF equipment. However, the 2
licensee did write a DC, 1-91-079, which will require a formal -
disposition as to reportability and corrective actions. The licensee stated that the specific procedure step will be reword 3d and that a broadness review of similar procedures will be performed to eliminate i-possible future misinterpretations. The resident inspectors consider this event to be an example of operator inattention to detail in following a plant procedure.
e.-
Unit 2'SG Secondary Side Access Handhole Leak Repair During recent Unit 2 operation, a leak developed around the seating surface'of a secondary side handhole on SG #4 The leak became apparent when the Containment Air Cooler Condensate Leak Detection system was alarming continuously. ~An analysis of the leak.off determined the leak was not from the RCS. Walkdowns in containment detemined that the leak was from a secondary side _handhole close to
=
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4 4
l the tube sheet on the #4 steam generator. Calculations on the magnitude of the. leak ranged up to 4 gpm.
The licensee developed a repair scheme which called for shutting down the unit to Mode 3 (Hot Standby) and pressure injection of a sealant l
compound into the handhole covar plate. This repair scheme was intended to seal the void between the handhole cover and the SG shell.
Injection of the sealant compound involved drilling holes into the handhole cover plate. The licensee's safety evaluation of the leak repair technique involved the assessment of two issues:
an j
evaluation of the structural aspects of the SG shell to detemine j
j that SG integrity was maintained; and the resultant effect on secondary side chemistry following introduction of the sealant compound. The inspectors reviewed the licensee's temporary modification request and 10 CFR 50.59 safety evaluation and were j
satisfied the licensee was taking a safe and conservative approach.
i i
Over the weekend of March 16, Unit 2 was shutdown to Mode 3 to perform the leak repair. The first attempt to stop the leak failed.
i Following this attempt, the licensee discovered that the sealant used in the effort was inadequate for the temperature and pressure j
involved. Apparently, at normal operating temperature and pressure, the sealant turned to powder. The licensee in preparing the i
Temporary Modification Request failed to adequately consider the l
effects of temperature. A second attempt at injecting sealant, using a metal clamp around the outside diameter of the flange and a different sealant, also failed to stop the leak. On March 20, Unit 2 l
was taken to Mode 5 (Cold Shutdown). The #4 steam generator was drained and the leaking flange was removed for inspection and repair.
i At the end of the inspection period the repairs had been completed and the unit was returning to power.
f.
Technical Specification Clarifications i
i During this inspection report period, the inspectors noted three i
occasions where the licensee found it necessary to clarify or evaluate TS for continued conduct of operations. These three evaluations were all associated with the leak on the Unit 2 #4 steam l
generator.
In all three cases, the inspectors assessed the licensee's clarifications as safe and conservative. The inspectors paid particular attention to these interpretations because they all i
The conservatism of involvedweighingsafetyandeconomicfactors.
i the licensee s interpretations have been questioned in the past.
The first clarification involved the Containment Air Cooler Condensate Leak Detection system being in constant alam (TS 3.4.6.1).
The question was whether the constant alam rendered this l
portion of the RCS leak detection system inoperable. The licensee's conclusion was that the alam function is not required for the system l
i
i' i
j 5
a to perform its function. The system was operable as long as it was capable of being used for leakage detection. The licensee initiated a surveillance to calculate leak rate from air cooler condensate once per shift.
i
' The second decision involved a judgement on whether to go to Mode 4 (Hot Shutdown) or Mode 5 (Cold Shutdown) for removal and/or repair of a
J the SG handhole.
In Mode 4, the Containment Integrity TS was still applicable. With the potential removal of the handhole cover, the question arose whether Containment Integrity would be violated if the plant was still in Mode 4. After considering this and other factors, the licensee decided to go to Mode 5.
i The third clarification, applicable in Mode 5 only, involved a footnote in TS 3.4.1.4.1 which requires a RCP not be started unless secondary water temperature of each SG is less than 50 degrees F above each RCS cold leg temperature. The licensee wanted to start a RCP with no RCPs running (in Mode 5)' after securing the only running e
RCP upon receiving a high vibration alarm (which later proved false),
1 i
The basis for this TS is to prevent RCS pressure transients through energy addition from the secondary side. With SG #4 drained for the handhole repair a question arose as to applicability of'the TS to the l
empty SG. The licensee performed a thermodynamic analysis of air and water and concluded it was acceptable to start a RCP with a SG drained.
g.
ESF Actuations - Containment Ventilation Isolation And Control Room Isolation On March 6, personnel were troubleshooting an electrical ground in j
the Unit 1 125 vdc switchgear. As a part of this process, the IB battery output breaker, 1801-01, was opened creating a disconnect j
between the battery chargers and the batteries. When the battery l
chargers began making variable pitched noises and the indicator light on the bus began to fluctuate in intensity the equipment operator reclosed the breaker.
In the control room a large number of annunciators were recieved including indications that a containment ventilation isolation and control room isolation had occurred. All valves and dampers actuated as designed.
The licensee's investigation determined that when circuit breaker 1801-01 was opened one of the two battery chargers (IBDICA) ex trienced voltage fluctuations from 90 to 140 volts. A protection circuit in inverter 18D1112 automatically shutdown inverter operation when voltage from the chargers went below 105 volts. When the
. inverter. tripped, power was lost to various radiation monitors and i
other equipment that had annunciated in the control room. This caused the radiation monitors to send ESF actuation signals upon loss 4
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of power. It was found that the voltage fluctations in battery charger IBDICA could be stopped when any one of its six control circuit boards was replaced. The licensee could not explain this unusual condition. A search for a specific failure is continuing.
The licensee will report this event in LER 424/91-04.
i i
No violations or deviations were identified.
I 3.
ESF System Walkdown (71710)
On March 19, the inspectors completed a system walkdown of both trains of the Unit 1 Containment Spray System. The purpose of the walkdown was to determine whether the system lineup procedure, Containment Spray System Alignment, 11115-1, Rev. 5, agreed with the plant piping and i
instrumentation diagram,1X4DB131. Rev. 22 and to identify equipment conditions and items that might degrade plant performance.
Material condition of those areas inspected was good and nothing was
]
observed which might affect system operability. However, several discrepancies were noted regarding labeling of components. Specifically, two valves were missing plastic identification tags, the wording on seven valve identification tags did not exactly match the valve description in the system alignment procedure, and all twelve electrical breaker ID tags i
differed from the alignment procedure written description. These labeling discrepancies were discussed with the licensee and corrective action will i
be taken. The inspectors had no other concerns regarding this Containment Spray System walkdown.
No violations or deviations were identif'ied.
4 4.
Surveillance Observation (61726)
~
i Surveillance tests were reviewed by the inspectors to verify procedural i.
and performance adequacy. The completed tests reviewed were examined for necessary test prerequisites, instructions, acceptance criteria, technical content, data collection, independent verification-where required, handling of deficiencies noted, and review of completed work. The tests i
witnessed, in whole or in part, were inspicted to determine that approved 4
4 procedures were available, equipment was calibrated, prerequisites were met, tests' were conducted according to procedure, test results were acceptable and systems restoration was completed.
l 4
I 7
i Listed below'are surveillances which were either reviewed or witnessed:
Surve'111ance No.
Title
~
11121-C Containment Coolers Condensate Collection Calculation 14546-1 Turbine Driven Auxiliary Feedwater Pump Operability Test 14553-2 ESF Room Cooler And Safety Related Chiller Flow Path Verification 14980-1 Diesel Generator Operability Test (6 month fast load test) 14980-2 Diesel Generator Operability Test
-28911-2 Seven Day Battery Inspection And Maintenance Main Feedwater Regulating Valves And Bypass Valves Testing a.
During the licensee's review of Generic Letter 89-19. " Safety implication of Control Systems in LWR Nuclear Power Plants"., it was identified that the MFRVs and BFRVs, according to Westinghouse, are credited in the safety analysis as a backup to the Feedwater Isolation Valves. Termination of main feedwater flow to a faulted steam generator is assumed in the steam line break and feed line break analyses in order to-limit the RCS cooldown and mass release from the break. As a result, the licensee added the MFRVs and BFRVs to the active valve list in the FSAR and included them in the Inservice Testing Program. When the Unit I active list, IST program, and TS were originally developed the MFRVs and BFRVs were deliberately excluded because it was thought that they were not required by the safety analyses.
4 To date, the Unit 1 BFRVs and the Unit 2 MFRVs and BFRVs have been
(
tested with satisfactory results. The only remaining valves are the Unit 1 MFRVs which will not be tested within the time requirements now established in the testing program (MFRVs can only be tested with the plant shutdown).
Due to the inability to stroke test the MFRVs at power, the resident inspectors requested that the licensee justify the capability of the MFRVs to close within the specified time until the plant is in a mode i
in which the valves can be tested. The licensee, using completed ESF Response Time Summation procedures and I&C loop calibration
8 procedures, obtained data which included times for the sensors, SSPS processing and closure times for the MFRVs. The response times for each of the MFRVs was calculated to verify that they could meet the feedwater isolation response time requirements and the inservice testing requirements. All the calculations were within the specified time requirements.
Once the need for testing of these valves was identified, the licensee took appropriate action to add them to the IST program, test the valves if possible, and address the safety issue on the Unit 1 MFRVs.
No violations or deviations were identified.
5.
Maintenance Observation (62703)
During this inspection period, a maintenance team inspection (MIT) was conducted at Vogtle by inspectors from Region II and NRR. The results of 2
that comprehensive inspection will be documented in report 50-424,425/91-03.
No violations or deviations were identified.
i 6.
ReviewofLicenseeReports(90712)(92700)
The below listed Licensee Event Reports were reviewed to determine if the information provided met NRC requirements. The determination included:
adequacy of description, verification of compliance with TS and regulatory 4
requirements, corrective action taken, existence of potential generic problems, reporting requirements satisfied, and the relative safety significance of each event.
a.
(Closed) 50-425/90-03, Rev. O, "_ Trip Of Heater Drain Pump Results In Exceeding The Reactor Power License Limit."
Reactor power was reduced to 90% of rated thennal power and was maintained at that power until previously scheduled maintenance on the heater drain pump was completed. The manual actuation pin for the HDT high level dump valve was disengaged and the valve was returned to automatic operation. The pins were modified so that ttey are. now restrained in the automatic position. Licensed operators were trained during a subsequent requalification class on the conditions that led up to and caused the over power event.
4
o 9
b.
(Closed) 50-424/90-20, Re'v. O, " Personnel Error Leads To A Technical Specification Violation."
'The GPC electrician and foreman involved wer counseled regarding the importance of attention to detail. The Maintenance Manager sent a memo to other appropriate personnel describing this event and the need for adequate reviews. Battery cell #35 was designated a pilot cell, which required weekly testing and should allow future problems with cell (35 to be identified sooner. Finally, battery procedures were reviewed and revised to simplify data recording and to eliminate duplication.
c.
(Closed) 50-425/90-12, Rev. O, " Personnel Errors Lead To Containment Spray Pumps' Deactivation."
The SS who approved the clearance to remove the containment spray pump from service was counseled regarding the importance of accuracy in reviewing clearances related to equipment required to be operable per TS. The Reactor Operator was counseled regarding the importance of maintaining a questioning attitude in the performance of his duties. A copy of this LER was included in the Operations Reading Book and was reviewed during a subsequent operator requalification cycle.
d.
(0 pen) 50-425/91-03, Rev. O, " Diesel Generator Failures May Have Resulted In Loss Of Ability To Mitigate Accident Consequences."
The K4 transfer relays for both the 2A and 2B DG.s were replaced and both DGs were demonstrated to be operable. The transfer relay contacts on DG 1A were tested and no-problems were found. The K4 transfer relay was replaced on DG 18 due to a somewhat higher resistance across contacts 1 and 7.
Furthermore, each DG has been instrumented to measure voltage drop during paralleling operation.
No abnormal readings were observed. Testing will continue on the 2A DG in an effort to identify the root cause of the failure.
If' the licensee determines a defective cause of the failure, a supplemental LER will be submitted. This LER will remain open pending further developments in the licensee's investigation.
No violations or deviations were identified.
7.
Followup (92701,92702) a.
(Closed) Part 21 Report. 50-424, 425/91-02, " Cooper Energy Services Potential Defect With EDG Starting Air Admission Valve."
Energy Services Group of Cooper Industries, in a letter to GPC dated July 31, 1990, recomended a plan of action to address the valve sticking problem. GPC subsequently. completed all recomended work for valves in service on all Unit 1 and Unit 2 EDGs. Additionally, appropriate maintenance procedures were revised to require that all
w 10 air start valves in the warehouse be modified prior to installation on a EDG.
b.
(Closed) VIO 424,425/90-20-01, " Inadequate Diesel Generator Procedure Resulting In Violation Of TS 6.7.la."
i The licensee responded to the violation in correspondence dated November 15, 1990. Corrective actions included briefing on-shift operations personnel regarding the correct methods for shutting down a diesel generator after an; emergency start; additional training incorporated into licensed operator requalification; and revision of plant procedures 13145-1 and 2 " Diesel Generators", to provide guidance'on actions to t&ke concerning shutting down the diesels after emergency starts. Based on a review of the licensee's completed corrective actions this violation is closed.
8.
Exit Meeting The inspection scope and findings were sununarized on Ma'rch 22, 1991, with those persons indicated in paragraph 1.
The inspector described the areas inspected and discussed in detail the inspection findings listed below.
No dissenting comments were received from the licensee. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during this inspection.
9.
Acronyms And Initialisms BFRV Bypass Feed Regulating Valve DC Deficiency Cards de Direct Current EDG Emerge.ncy Diesel Generator EHC Electro-Hydraulic Control ESF Engineered Safety Features FSAR' Final Safety Analysis Report HDP
' Heater Drain Pump HP Health Physics IST Inservice Test KV Kilo-Volts LER Licensee Event Reports MFRV Main Feed Regulating Valve RCS Reactor Coolant System RCP.
Reactor Coolant Pump l
SI.
Safety Injection TS Technical Specification UV Undervoltage.
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Vogtle Bectric Generating Plant
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1 of 29 MANUAL SET CONDUCT OF OPERATIONS j
1.0 BTRPOSE This procedure establishes the responsibilities of Operations Department personnel and provides administrative instructions for conduct of plant operations.
2.0 QBSANIZATION AND RESPONSIBILITIES Figure 1 gives a basic organization chart for the Operations Department.
Specific responsibilities, duties and reporting relationships are as follows.
2.1 MANAGER OPERATIONS The Manager Operations is responsible for the overall management of the Operations Department to ensure safe and efficient rporation of Plant Vogtle.
Specific duties and rugxting relationships are described in Plant Administrative Procedure 00001-C, " Plant Organization; Managarial Staff Responsibilities And Authority".
m e
0 3
l s' 1
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PROCEDURE NO.
REVISION PAGE NO.
j VEGP 10000-C 21 2 of 29 2.2 SHIFT SUPERINTENDENT The Shift Superintendent (SS) reports to the l
Superintendent Unit (Shift Operations).
The SS is the j
senior management representative on each shift and is i
responsible for the safe and efficient operation of the i
plant. He assumes duties previously of the on-Shift Operations Supervisor (OSOS) and has the following l
duties and responsibilities.
i a.
Functions as senior management representative for plant operations on shift, 1
b.
Has authority and responsibility to declare j
emergencies in accordance with the VE3P Emergency i
Plan.
Upon declaration, the SS will:
- 1) function l
as Sita Emergency Director until relieved by,a i
higher ranking nr. nager; 2) ensure immediate j
mitigating actions are implemented under the I
direction of the Unit Shift Supervisor; and 3) l ensure required on-site and off-site communications are properly executed.
i l
c.
Ensures that plant operations are conducted in j
accordance with the Technical Specifications and approved procedures, i
i d.
Reviews operations narrative logs and round cheats i
in accordance with 10001-C, "Logkeeping",
i l
e.
Ensures shift relief is conducted in accordance l;
with 10004-C, " Shift Relief",
l f.
Ensures standing orders and night orders are j
carried out, i.
g.
Ensures that the shift is properly manned, the i
Fire Team constituted and team captain designated j
in accordance with 10003-C, " Manning The Shift",
h.
Ensures appropriate notifications of reportable j'
occurrences are performed, t
i 1.
Maintains a broalt perspective of operational i
conditions affecting the safety of the plant as a j
natter of highest priority at all times, j.
Does not become involved in any single operation that distracts him when multiple operations are required in the control Room.
During plant t
transients or an emergency he should not become totally involved in any single operation that l
distracts him from the rest of the operations
- mquired in the control Room, 1-
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k*
i PROCEDURE NO.
REVISION PAGE NO.
e VEGP 10000-C 21 3 of 29 l
)
k.
Ensures that shift activities are conducted in j
a manner that keeps personnel radiation exposures as low as reasonable achievable, i
1.
Ensures temporary procedure changes are properly administered on shift in accordance with 4
j 00052, " Temporary Changes To Procedures",
i i
m.
Tours plant areas on a routine basis, noting condition of the plant and equipment, and 2
nonitoring rounds performance.
i j
2.3 UNIT SHIFT SUPERVISOR I
One Unit Shift Supervisor (USS) is assigned to each operating unit on each shift.
He is responsible for the safe and efficient operations of the assigned unit.
i The US8(s) reports to the Shift superintendent (88) and has the following specific duties and responsibilities:
a.
Ensures that unit operations arw conducted in l
accordance with Technical Specifications and approved procedures, b.
Directs reactor to be shut down when:
l (1)
Safety of the reactor is in jeopardy, or i
j (2) operating parameters exceed any of the reactor protection system trip setpoints and i
i automatic reactor trip does not occur, or l
(3)
Persannel or equipment safety require it, or i
l i
(4)
Unusual circumstances warrant it.
1 l
c.
Directs operational activities of the assigned j
unit from the control Roca unless relieved by a l
qualified licensed SRO, 4
d.
Authorizes maintenance and/or testing activities 3
to be performed on the assigned unit, and ensures plant conditions,are suitable for performing such l
activities.
Maintains status of equipment, and determines operability of equipment upon return to
- service, e.
Issues equipment clearances and ensures proper control of tags in accordance with Plant Administrative 00304-C, " Equipment i
clearance And Tagging",
i J
4 1
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j PROCEDUAE NO.
REVISION PAGE NO.
VEGP 10000-C 21 4 of 29 f.
Ensures proper control of temporary jumpers, i
lifted wires, and pulled annunciator cards i
in accordance with C0306-C, " Temporary 1
Jumper And Lifted Wire Control", and 10018-C, l
" Annunciator Status Control",
i g.
Explains plans, procedures, and safety precautions to shift operating personnel prior to infrequent or unusual activities, 1
h.
Ensures shift relief is conducted in accordance with 10004-C, " Shift Relief",
e 1.
Maintains the Unit Shift Supervisor narrative log and administers logkeeping in accordance with j
10001-C, "Logkeeping",
2 l
j.
Supervises operators assigned to specific shift i
positions on the unit, k.
Maintains operating work spaces in a clean and orderly condition, and ensures good housekeeping practices by operators assigned to the unit, l
1.
Conducts periodic safety meetings for operators on-shift, enforces safe practices, ensures appropriate protective equipment is used, prepares accident reports, and obtains medical attention, i
when needed, n.
Limits access t6 the Control Room in accordance with Procedure 00301-C, " Main Control Roon Access And Personnel Conduct",
n.
Tours plant areas on a periodic basis, noting condition of the plant and equipment, and monitoring rounds performance.
f 2.4 SHIFT SUPPORT SUPERVISOR he Shift Support Supervisor (SSS) reports to the Unit Shift Supervisor (USS).
Specific duties and responsibilities inclyde but are not limited to:
a.
Coordinates clearance and tagging review for the
- USS, I
b.
Coordinates control of keys required for plant operation per Procedure 00008-C, " Plant Lock And i
Key Control",
c.
Performs WRT, maintenance work order, and deficiency card reviews for the USS,
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S PROCEDURE NO.
REVISION PAGE NO.
VEGP 10000-C 21 5 of 29 d.
Supervises shift operators who are not assigned a specific shift position, fire protection technician, shift clerk, and radwaste operators.
a.
Assists the Shift Superintendent (SS) in implementing work scheduled per the Plan-of-the-Day, and provides input to the POD work process, f.
May serve as Fire Team Leader if designated by the SS, g.
Tours plant areas on a routine basis, noting condition of the plant and equipment and i
monitoring rounds performance.
i i
2.5 REACTOR OPERATOR 1'
The Reactor Operator (RO) reports to the USS.
He is j
the licensed operator assigned to operate the reactor i
and related controls from the Control Room.
The RO normally operates the Primary Plant Systems (located on Control Room Panels A2 and C).
Specific duties and responsibilities includes a.
Maintains the unit in a safe condition, including i
shutting down the reactor when:
l (1)
Safety of the reactor is in jeopardy, or i
(2)
Operating parameters exceed any of the reactor protection circuit set points and automatic shutdown does not occur, or (3)
Required to protect personnel and equipment, j
or i
l (4)
Unusual circumstances warrant it.
I b.
Initiates immediate actions necessary to maintain 3
the unit in a safe condition during abnormal and emergency operations, c.
Performs shift operations and surveillance testing in accordance with approved procedures, standing i
orders, and the Technical Specifications, d.
Exercises continuous sarveillance of unit conditions and system parameters.
Remains in the "at the controls" area unless properly relieved.
"At the controls" is defined in 10003-C, " Manning i
The Shift",
s.
Instructs the Balance of Plant Operator to perform prer -ibed plant operations,
. = _. _. -.
i-1 PROCEDURE NO.
REVISION PAGE NO.
VEGP 10000-C 21 6 of 29 i
J f.
Manipuistes the controls and equipment to start i
up, operate, and shut down the unit as required by j
operating schedules and load demand, 1
g.
Maintains.the Unit control Log and completes round
. sheets for his position.
Maintains recorder j
charts for his work station, h.
Promptly notifies the USS of unusual conditions, i.
Remains alert and knowledgeable of all unit operations in progress that involve the j
functioning of equipment controlled from the Main i
Control Room, l
5 j.
Functions as a team member during initiation of I
the site Emergency Plan, i
k.
Coordinates startup and shutdown operations of the i
nuclear reactor, turbine generator and auxiliary i
equipment, j
1.
Responds to the system operator requests at.the j
direction of the USS.
t 4
2.6 BAIANCE OF PLANT OPERATOR l
is a second The Balance of Plant Operator (BOP)
{
licensed operator assigned to each unit.
He reports to the USS. He normally operates primary support and 1
balance of plant systems and controls (located on l
Control Room Panels A1, B1, B2 and those panels not located in the at-the-controls area)
Specific duties i
l and responsibilities include:
i a.
Maintains the unit in a safe condition, including i
shutting down the reactor when:
l (1)
Safety of the reactor is in jeopardy, or i
(2)
Operating parameters exceed any of the i
reactor protection circuit set points and 4
automatic shutdown stoes not occur, or (3)
Required to protect personnel and equipment, 4
or i
(4)
Unusual circumstances warrant it, J
i b.
Initiates the immediate actions necessary to maintain the unit in a safe condition during abnormal or emergency operations,
}
PROCEDURE NO.
REVISION PAGE NO.
VEGP 10000-C 21 7 of 29 c.
Performs shift operations and surveillance testing in accordance with approved procedures, standing l
orders, and Technical Specifications,
)
d.
Exercises continuous surveillance of unit
)
conditions and system parameters, e.
Receives instruction from the Reactor Operator, f.
Completes check lists for his position, maintains recorder charts for his work station, and assists the Reactor Operator in maintaining the Unit control Log, g.
Promptly notifies the Uss of unusual conditions, h.
Remains alert to and knowledgeable of all unit operations in progress that involve the functioning of equipment under his control, i.
Functions as a team member during initiation of the site Emergency Plan, j.
Maintains the control Room in a clean and orderly condition, i
i k.
Relieves the RO when authorized by the USS, l
l 1.
Normally remains in the control Room unless performing necessary duties elsewhere in the l
plant.
2.7 PLANT EQUIPIGNT OPERATORS There will normally be four Plant Equipment operators (PEO) on shift for each unit A Turbine Building Operator (TO), an Auxiliary Building Operator (AO), an j
outside Area Operator (OAO) and a Control Building j
Operator (CBO).
l The PEOs report to the shift support supervisor (SSS),
but may also receive direction from the 20 or BOP.
Specific duties and responsibilities includes a.
Forforms rounds to ensure proper operation of equipment in assigned work area, b.
Executes routine shift duties as directed'by the l
- Uss, c.
Removes equipment from service and executes clearance orders; restores equipment to service l
and. removes clearances as directed by the USS, i
i
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PROCEDURE NO.
REVISION PAGE NO.
VEGP 10000-C 21 8 of 29 j
d.
Maintains clean and orderly work area, e.
Acts as Fire Team member when designated by the j
Shift Superintendent (SS).
2.8 RADWASTE OPERATOR The Radwaste Operator reports functionally to the Shift Support Supervisor (SSS) and administratively to a Radweste Foreman.
Specific duties and responsibilities include:
i l
a.
Operates Radwaste Systems in accordance with j
approved procedures and Standing Orders, i
i b.
Maintains round sheets and logs for his position, i
i c.
Executes routine shift duties as directed by the j
Radweste Foreman or USS, J
i d.
Maintains clean and orderly work area.
2.9 SHIFT TECHNICAL ADVISOR The Shift Technical Advisor (STA) provides engineering i
expertise during operational emergencies to assess plant status and assist in implementing EOPs.
t l
An STA is not required on shift if the Shift Superintendent (SS) or a USS holds a bachelors degree l
in engineering or a rslated science.
The SSS may also i
be designated to perform the STA function, if j
qualified.
j If an STA is assigned on sh*it, he or she will' report to the SS.
i i
2.10 SUPERINTENDENT UNIT The Superintendent Unit includes two functional positions:
2.10.1 The Superintendent Un,it (Outage & Work Planning) reports to the Manager Operations.
He has tha l
following duties and responsibilities:
a.
Ensure proper scheduling and coordination of work activities to achieve optinua plant availability i
and material condition, I
l b.
Identify system / component outages when necessary and ensure all desired work activities are included and properly supported by the various work mroups,
PROCEDURE NO.
REVISION PAGE NO.
VEGP 10000-C 21 9 of 29 I
i c.
Decide what work activities are to be included on j
the forced outage schedule, i
d.
Ensure Operations Department support of refueling j
outage activities, 1
e.
Develop and prioritize the design change worklist, j
f.
Review and approve operating procedures, as designated by the Manager Operations, I
J g.
Ensure plant operations are conducted in accordance with Technical Specifications r>:d approved procedures, h.
Serve on the Plant Review Board when designated, j
j 1.
May function as Manager Operations when j
designated.
1 2.10.2 The Superintendent Unit (Shift Operations) reports to i
the Manager operations.
He has the following duties and responsibilities:
i l
a.
Supervises the activities of the Shift Superintendents (SS),
l l
b.
Provides diracLion to the Shift Superintendents for routine scheduling and coordination of 1
Operations shift activities, including interfacing l
with other plant-departments, to achieve optimum plant availability and material condition,
}
c.
Ensure development of supervisory skills of l
on-shift supervision, s
d.
Ensures plant operations are conducted in accordance with Technical Specifications and approved procedures,
)
e.
Maintains shift crew (s) continuity, f.
Serven on the. Plant Review Board when designated, g.
Implements outage and work scheduling for shift efficiency, h.
Reviews and approves operating procedures, as i
designated by the Manager Operations, i.
May function as Manager Operations when j
designated.
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PROCEDURE NO.
MEVISiON PAGE NO.
VEGP 10000-C 21 10 of 29 2.11 SUPERINTENDENT OPERATIONS (SUPPORT)
The Superintendent Operations (Support) reports to the Manager Operations.
He has the following duties and responsibilities:
a.
Supervises the preparation and review of plant operating procedures, b.
Provides input to the Training Department for development and conduct of training and qualification of Operations Department personnel, c.
Develops and maintains personnel records such as shift schedules, vacation schedules, and seniority
- lists, d.
Provides interface between Operations and other departments on all administrative matters, e.
Serves on the Plant Review Board when designated, f.
May function as Manager Operations when specifically designated.
2.12 PIANT ENGINEERING SUPERVISOR (OPERATIONS) i The Plant Engineering Supervisor in Operations reports l
to the Superintendent Operations (Support) and has the j
following duties and responsibilities:
L a.
Coordinates Operational Experience Assessment Program activities pertaining to plant operation j
(with Nuclear Safety and Compliance Section),
l b.
Maintains plant operating procedures current and
- accurate, i
I i
c.
Reviews plant design changes to ensure timely revisions to operating procedures when necessary, d'.
Provides technical and administrative support to the operations Superintendents and Manager l
Operations, j
e.
Supervises administration of the Operations Reading Book per Procedure 10017-C, " Operations l
Reating Books",
f.
Coordinates operations responses to plant open items.
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i PROCEDURE NO.
REVISION PAGE NO.
VEGP 10000-C 21 11 of 29 2.13 OPERATIONS TRAINING SUPERVISOR Operations Training Supervisor reports to the Superintendent Operations (Support) and has the following duties and responsibilities:
a.
Assures that each applicant has the knowledge and skills to competently perform the assigned
- position, b.
Monitors on-the-job-training (0JT) performance and operations Department training needs, c.
Primarily and routinely interfaces with the Training Department, d.-
Maintains Training Qualification Checklist and OJT documents, Obtains and distributes training material, e.
f.
Attends training course IN-001, " Instructor Development Program" within one year of being appointed to the position, g.
Establishes and maintains a list of approved l
Operations Department G7T Trainers / Evaluators, h.
Serves on the Operations Training Committee, i
i 1.
Coordinates and7 chedules evaluations and t
- training, l
j.
Performs evaluations and training, k.
Identifies area of candidate's deficiencies and provides feedback to Trainirq and operations management.
h l
l l
I
E 4
PROCEDURE NO.
REVi&lON PAGE NO.
VEGP 10000-C 21 12 of 29
)
2.14 RADWASTE SUPERVISOR t
j The Radwaste Supervisor reports to the Superintendent operations (Support).
He has the following duties and responsibilities:
i a.
Plans, directs, and supervises operations Department liquid and gaseous radioactive wastes processing, and coordinates these activities with 4
other plant departments as necescary, 4
b.
Conducts routine administration and scheduling for radwaste personnel, i
c.
Advises the Training Department on requirements for developing and conducting training of radwaste personnel, i
d.
Ensures liquid and gaseous radwdste operation's are
}
conducted in accordance with state and federal i
j regulations, and approved procedures, i
e.
Tracks and trends water usage in the pir.nt, and coordinates water management activities plant wide j
to ensure efficient and safe operations.
j f
2.15 RADWASTE FOREMAN The Radwaste Foreman reports to the Radwaste i
Supervisor.
He has the following duties and responsibilities:
a.
Directs the activities of the Radweste Operators, j
b.
Coordinates and schedules radwaste activities, j
c.
Reviews Radwaste Operator logs, i
d.
Initiates corrective actions for out-of-limit l
conditions and notifies the Radwaste Supervisor and the USS, e.
Coordinates and schedules Chemistry, HealtL i
Physics and Maintenance support, f.
Conducts the Radwaste operator Qualificat.on Program.
i F
I PROCEDURE NO.
REVISION PAGE NO.
I VEGP 10000-C 21 13 of 29 l
i i
3.0 SHIFT OPERATIONS
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l 3.1 SHIFT Cos(PLEMENT The shift superintendent (ss) shall ensure that the operating shift is properly manned, in accordance with j
Procedure 10003-C, " Manning The shift".
I
-3.2 SHIFT WORK HOURS 3.2.1 shift Hourr The shifts will be' conducted on a 24-hour clock system, using Central standard Time (or Central Daylight 3
l Savings Time),
specific shift schedules will be posted l
. by the superintendent operations (support).
3.2.2 overtime i
\\
i overtime should not be routinely scheduled to meet the j
shift crew staffing requirements.
In the event that l '
overtime must be used, the overtime restrictions of Procedure 00005-C, " Overtime Authorisation", will be followed.
3.2.3 Notification of Absences j
Anyone expecting to be late or unable to report for shift duty at the scheduled time shall, at the earliest i
possible time, inform the shift superintendent (SS) or Uss.
i 3.2.4 Call Out Authority j
c The ss is authorized to call out anyone required for
)
the safe plant operation, per Plant Administrative Procedures 00007-C, "Vogtle Duty Manager / Response Team" and'00012-C, " shift Manning Requirements".
e
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I;.
1 PROCEDURE NO, REVISION PAGE NO.
j VEGP 10000-C 21 14 of 29 i,
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l l
3.3 GENERAL WORK PRACTICES i
j All personnel assigned to shift operations shall:
a.
Be aware that the primary responsibility of the i
operating shif'c is to assure the safe operation of l
the plant under all conditions, j
b.
Protect plant personnel, the health and safety of 1
the public and plant equipment,
)
1 I
c.
Conduct plant operations in accordance with approved written procedures, d.
be attentive to the condition of the plant at all j
times.
They must be alert to ensure that the plant is operating safely and take action to i
prevent any progress toward a condition that might be unsafe, i
e.
Believe and respond to instrument indications until they are proven to be incorrect, 4
f.
Not bypass, reset bypasses, defeat safety systems L
or interlocks or remove Category 1, 2, or 3 instrument channels from service, unless allowed j
to do so by an approved procedure.
l 3.3.1 Shift Conduct.
3.3.1.1 Each member of the shift crew shall perform in a professional manner.
Potentially distracting i
i activities shall not be conducted in ther Control Room area.
Activities prohibited include loitering, listening to music, hobbies,'non job-related reading l
material, and horseplay. The full focus of the shift complement's attention shall be the safe and efficient l
operation of the plant.
3.3.1.2 Operations personnel on shift must be aware of and responsible for the plant status rat all times.
This includes supervisors being responsible for the performance of personnel assigned to their shift who j
could affect plant safety.
3.3.1.3 All operations personnel on shift must be alert and remain within their work arsas until properly relieved.
Operators are responsible for monitoring the instrumentation and controls located within their work areas.
They are_ responsible for taking timelv and proper actions to ensure safe operation of thw facility.-
4 PROCEDURE NO.
REVISION PAGE NO.
l VEGP 10000-C 21 15 of 29 3.3.1.4 Controls that directly affect the reactivity or power level of a reactor shall only be manipulated by licensed operators, except for training purposes.
3.3.1.5 Mechanisms and apparatus, other than controls, that may indirectly affect the power level ori reactivity of a reactor shall only be operated with the knowlsdge and prior consent of a licensed operator.
3.3.2 Abnormal Indications The SS, U58, RO, and BOP have the authority and responsibility to perform the tasks necessary to limit plant operations or to shutdown the unit when such action is warranted by unit conditions or unucual circumstances.
When analyzing such situations, shift operating personnel shall consider instrument readings and control indications to be true unless they are proven to be incorrect.
When abnormal indications occur, operations personnel shall determine the cause of the abnormal indication and initiate appropriate corrective action.
3.3.3 Instrument setpoints shift operating personnel shall not manipulate instrument, control or. alarm setpoints, other than those available on the control console or those normally required during routine operation.
setpoint changes shall be entered in the Unit control Log or the j
Shift supervisor's Log.
I i
Anyone performing a function that may affect a unit's operation or a control Room indication shall notify the Control Room operators before initiating the function, i
3.3.4 Control Room Access I
Control Room access shall be limited to official business only in accordance with Plant Administrative Procedure 00301-C, " Main Control Room Access And l
Personnel Conduct".
f
.I
4 PROCEDURE NO.
REVISION PAGE NO.
VEGp 10000-C 21 16 of 29 1
3.3.5 Generator Load changes Normally generator load changes will be made as requested by the System operator.
If approved by the shift superintendent (ss), and if plant operating conditions and operational orders permit, the Reactor operator will comply with the request The RO shall inform the USS when the requested load change is completed.
Whenever plant conditions require a load change, the System operator shall be notified as soon as possible of the proposed load and rate of change.
Scheduled outage requests shall be initiated by the Manager operations and approved by the General Manager and system operator prior to scheduled plant shutdown.
3.3.6 Control Room Housekeeping The control Room will be maintained in a clean and orderly condition in the interest of safe and efficient operations.
Dusting and cleaning of control consoles, instrument panels, and computer consoles will be performed by shift operating personnel.
3.3.7 Manual Operation of Motor Operated Valves l
Avoid overtravel.
Some MOV's are adjusted to stop traveling open for less than 1004 stroke due to pump or l
system flow restriction requirements.
NOTE Excessive closing or opening -
l force during manual operation i
can damage the limitorque l
operator.
If manual seating or backseating is required, the associated handswitch shall be caution tagged to indicate that the valve has been manually operated.
Safety related MOV's which receive an actuation signal or are required to be repositioned to fulfill a safety j
related function shall be considered inoperable.
l l
The valve shall be manually unseated and then stroked j.
using the motor operator prior to returning the MOV to remote service or for the case of safety related MOV's, declaring the MOV operable.
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PROCEDURE NO.
REVISION PAGE NO.
VEGP 10000-C 21 17 of 29 l
3.4 NOTIFICATION REQUIREMENTS The Shift Superintendent (SS) is responsible for the notification of the NRC, plant management and staff in
]
special situations.
Notifications required during day l
shift, Monday thru Friday, should be to the Superintendent Unit (Shift Operations) and at other times to the Operations Duty Manager and Vogtle Duty l
Manager, who may direct the SS to call the Manager Operations.
g 3.4.1 Notification Of Duty Manager I
l The SS shall notify the Operations Duty Manager and the l
Vogtle Duty Manager if the following occurs i
a.
Reportable Occurrences requiring NRC red phone i
notification per Plant Administrative Procedure l
00152-C, " Federal And State Reporting Requirements",
b.
Conditions that require the use of Abnormal operating Procedures, c.
Unscheduled entry into an LCO action statement with less than or equal to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Notification should also be made when abnormal conditions occur during scheduled LCO entries for surveillances, testing, etc, d.
Equipment failures that could necessitate a
- dorate, e.
A major failure resulting in structural damage to company property, f.
Any serious personnel injury, g.
Any call for offsite assistance, h.
A fire with activation of the plant fire team, i.
serious environmental problems, such as toxic chemical, oil, or hasardous waste spills, j.
Technical assistance or management direction is needed for issues of reportability, operability, technical specification compliance, or procedural adequacy.
J.
l PROCEDURE NO.
REVISION PAGE NO.
3 VEGP 10000-C 21 18 of 29
)
i 3.4.2 NRC Immediate Notification Events The Shift Superintendent (SS) is responsible for notification of the NRC Operations Center for prompt reportable occurrences in accordance with Plant Administrative Procedure 00152-C, " Federal And State i
Reporting Requirements".
j 3.5 SHIFT RELIEF AND EVOIRTION BRIEFINGS i
3.5.1 Each shift relief shall be conducted in an orderly, 5
professional manner in accordance with Procedure 10004-C, " Shift. Relief".
The SS may add to these j
minimum requirements as he sees fit.
3.5.2 Briefings shall be conducted for individuals involved j
in complex or unusual evolutions.
The detail of the briefing is dependent on the degree of complexity,
{
routineness, logistics, or number of people involved.
l 3.5.3 The individual who is to perform an activity is i
responsible to adequately review its procedure, to j
fully understand what he is doing, and to be cognizant of all the limitations and precautions and requirements.
l 3.5.4 Evolutions involving'many individuals, especially from i
two or more departments or disciplines, may require i
large formal briefings or pre-planning sessions.
If j
the evolution is complex and involves close coordination, the briefing session should include:
I j
a.
A review of the appropriate sections of the i
procedure by key parties, I
b.
An examination of each individual's specific j
j involvement and responsibility, s
c.
A discussion of expected results or performance, d.
A review of limitations, ho'1d points, i
l e.
A review of emergency action to be taken in j
contingencies, t
l f.
Checks to ensure that everyone understands the j
interface and communications required, g.
Identification of individual in charge of the evolution.
= - -..
i s.
1 i
PRoctouRE NO.
REVISION PAGE NO.
4 VEGP 10000-C 21 19 of 29 h
3.' 6 SHIFT RECORDS s
j~
Shift records include logs, round sheets, check lists, recorder charts, computer printouts and other data j
generated during operations.
I 3.6.1 Logs g
i a.
Operations narrative logs, round sheets, recorder charts and computer printouts shall be kept in J
accordance with the provisions of 10001-C, "Imgkeeping",
b.
Where instrument numbers are provided in Rounds l
Sheets and Technical Specification Surveillance j
Imgs, it is not intended to limit recording of the specified parameter from only the instrument i
number specified if an equivalent instrument is available which measures the same parameter.
)
i L
3.6.2 Night orders and Standing Orders 1
Night orders and Standing orders are issued in l
j accordance with 10002-C, " Plant Operating orders".
1 3.6.3 Reactor Trip Review j
l The Shift Superintendent (SS) shall initiate review of i
reactor trips in accordance with 10006-C, " Reactor Trip l
Review".
l 3.7 KEY CONTROL Keys required for plant operation are controlled in accordance with 00005-C, " Plant Inck And Key Control".
i 3.8 RADICIAGICAL CONTROLS 3.8.1 Each person on the plant staff is responsible to use proper radiological practices and procedures.
Everyone must be continuously aware of the radiological aspects of the work he is involved in and take appropriate generation and spread'posure and to control the actions to minimise exof radioactive contamination.
l i
3.8.2 Refer.to 43007-C, " Issuance, Use And Control of Radiation Work Permit", for control of work in radiation and high radiation areas.
3.9 SAFETY CLEA3ANCE AND TAGGING clearance and tagging for personnel and equipment safety.is conducted in accordance with 00304-C,
" Equipment Clearance And Tagging".
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PROCEDURE NO.
REVISION PAGE NO.
VEGP 10000-C 21 20 of 29 4
e i
3.10 EQUIPMENT RETURN TO SERVICE i
l Following maintenance on or modification to a system or component, operations shall verify the operable condition of that system or component.
Verification may be by functionally testing or by surveillance j
testing.
If the component or system is not covered by a surveillance procedure and a special functional test is not performed, a return to service functional inspection should be performed.
The inspection should i
i
' address items such as the following:
a.
Mechanical coupling, i
b.
Blind flanges installed / removed, c.
Electrical connections, d.
Area cleanliness, e.
Valve alignment, j
l f.
Proper lubrication, i
j g.
system integrity, i
h.
Function of remotely operated valves.
}
3.11 TECHNICAL SPECIFICATION CIARIFICATIONS 3.11.1 Technical specificatton clarifications may be made i
usitig Figure 2 as follows:
l i
a.
Immediate Need i
The requestor will contact one of the below listed i
individuals:
l l
(1)
Shift Superintendent, (2)
Manager Operations, (3)
An operations superintendent.
The clarification will be given verbally, and may be followed up by the clarifier with a written L
request form.
i 1
l
PROCEDURE NO.
REVISION PAGE NO.
VEGP 10000-c 21 21 of 29 b.
Normal Need The requestor fills in the first two portions of the request form and forwards it to the Manager Operations.
After clarification is made, review and concurrence is obtained from Technical Support Manager, after which final approval is obtained from Manager Operations.
The clarification is numbered (year-sequential number), " controlled copies" made for the Technical Specification clarification Book (s) in the control Room area and the office of the Manager Operations, and the original sent to Document control.
Information copies will be distributed to (1)
Technical support Manager, (2)
Engineering Support Manager, (3)
Plant Training & Emergency Preparedness
- Manager, I
(4)
Operations Readir.g Book, (5)
HP & chemistry Manager, (6)
Manager Licensing.
l c.
Review A periodic review of the Technical Specification clarification Book will be conducted by the operations Manager or his designee.- This review is to verify appropriateness and applicability, d.
Deletion j
when it is determined that a clarification is no i
longer valid, a Tech. Spec. clarification Termination Request (Figure 3) is completed and J
forwarded to the Technical Support Manager and Manager Operations for approval.
The completed Figure 3 will be maintained as in b. hbove.
I t
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PROCEDURE NO.
REVISION PAGE NO.
{
VEGP 10000-C 21 22 of 29 i
i 4.O PIANT OPERATING PROCEDURES i
j 4.1 PROCEDURE COMPLIANCE l
4.1.1 Operating personnel will follow approved plant procedures as directed by 00054-C, " Rules For i
Performing Procedures".
4.1.2 In emergencies, Operations personnel are directed to l
take such action as is necessary to minimize personnel injury and damage to the plant; to return the plant to a stable, safe conditions and to protect the health and i
safety of the general public and personnel on site.
4.1.3 In emergencies, personnel may take reasonable action that departs from a license condition or a Technical specification when this action is immediately needed to protect the public health and safety and no action consistent with license conditions and Technical j
specifications that can provide adequate or equivalent protection is immediately apparent.
i l
4.1.4 Personnel action permitted by Paragraph 4.1.3 shall be l
approved, as a minimum, by a licensed Senior Reactor j
Operator prior to taking the action.
l 4.2 PROCEDURE IMPLEMENTATION l
l 4.2.1 Procedures for other than simple, frequently performed operations shall be followed step-by-step with the procedure present.
Many procedures will require signoffs.
Routine procedural actions that are i
l frequently performed may not necessitate the presence of a procedure.
If the operator is not completely 1
familiar with the procedural action to be performed, f
the procedure must be present.
Immediate operator actions of emergency procedures shall be committed to memory.
4 4.2.2 Independent Verifications required by procedures which do not have signotf spaces shall be documented using 11879-C, " Independent verification Documentation Log Sheet".
j l
4.2.3 If an evolution is suspended for an extended period of time, reverification of prerequisites and necessary t
j applicable system alignments is required.
h l-r l
PROCEDURE NO.
REVISION PAGE NO.
VEGP 10000-C 21 23 of 29 4.3 SYSTEN L'iNEUPS AND SYSTEM STATUS FILE System lineups establish and confirm the status of equipment and systems.
The current lineup for each system is maintained in a system status file.
The file contains the most recent complete lineup and those partial lineups performed subsequently which collectively reflect the current status of the entire system.
4.3.1 Complete system lineups are performed as directed in unit operating procedures.
Partial lineups are performed on portions of systems inside clearance boundaries, after clearances are released, when directed by the Shift Supervisor.
Partial lineups are also performed on portions of systems affected by i
procedure revisions when directed by an operations i
Superintendent.
Complete or partial lineups may be performed when directed by the USS.
4.3.2 Each system lineup will be performed at least every 30 months.
The operations Manager or his designee will designate system lineups that will be performed prior to unit startup following cold shutdown.
Any exceptions to this policy will be approved by the Assistant General Manager - operations.
i 4.3.3 Lineups should be performed in sequence identified in i
Lineup procedure unless otherwise directed by the USS.
l l
4.3.4 The operator shall compare the position of the component with the condition required on the alignment, j
and initial in the spaces provided. - Report components found not to be in the required position to the USS for evaluation prior to repositioning to the condition l
required.
i 4.3.5 A control valve condition is verified to be AVAILABLE by ensuring that power or air, as appropriate, is i
available to the valve operator and that no physical i
obstructions that could prevent operation are apparent.
4.3.6 All components left in other than the condition i
required shall be noted on the comments section of each j
alignment procedure and the reason for the exception l
shall be entered.
l 4.3.7 While performing lineups, the operator should compare l
the component tag with the alignment procedure i
component I.D. and description.
Discrepancies should he'noted on the comments section of the alignment procedure.
i l'
PmocEoumE NO.
MEvlslON PAGE NO.
)
VEGP 10000-c 21 24 of 29 i
f 4.3.8 Independent position verification shall be performed in j
accordance with 00300-C, " Independent Verification i
Policy" and Cub-subsection 4.2.2.
)
i j
4.3.9 The Uss or Sss shall review the completed system lineup j
for completeness and to ensure exceptions do not l
warrant further corrective action.
The original lineup 1
is placed in the system ctatus file.
Superseded lineups are forwarded to Document Control.
Care must i
be taken when removing lineups from the file to ensure l
that the file reflects the current status of the i
systems (e.g., partial lineups can supersede only j
partial lineups on the same components; partial lineups can only supersede complete lineups if, collectively, j
they constitute a complete lineup.)
l 4.4 sURVEILIANCE TESTING 4.4.1 Operations surveillance Tests s 4.4.1.1 The operations Department shall perform, document and j
review operations surveillance tests.
4.4.1.2 The approval of the Uss shall be obtained before starting each surveillance test.
The operator performing the test shall record information as required by the test procedure and initial each step as it is completed.
He shall sign and date the procedure l
upon completion of the test.
If a step is not completed the explanation shall be recorded on the procedure.
If a test' does not meet the specified i
acceptance criteria, the Uss shall be notified and corrective action initiated.
i 4.4.1.3 The shift superintendent (ss) or Uss shall review all operations surveillance tests performed on his shift e
for completeness and accuracy. He shall indicate his i
review by signing and dating the procedure in the l
appropriate space.
4.4.1.4 Refer to 00404-c, " surveillance Test Prograu" for method of tracking Tech. Apoc. surveillance tests i
during normal conditions.
4.4.2 special Condition or Off-Normal Surveillance i
Requirements i
The Uss shall ensure 14915-1/2, "special Condition surveillance Logs" is or has been initiated as required to comply with Technical specifications in conditional or off-normal situations.
i
MOCEDURE NO.
REVISION PAGE NO.
VEGP 10000-C 21 25 of 29 4.4.3 The USS shall ensure 14000-1/2 " Operations Sh.ift &
l Daily Surveillance Ings" surveillances are started within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of shift turnover and worked to completion, provided circumstances warrant.
1 5.}
REFERENCES 5.1 FSAR - Chapter 13 5.2 VEGP Technical Specifications 5.3 PROCEDURES i
5.3.1 00001-C,
" Plant organization; Managerial Staff j
Responsibilities And Authority" 5.3.2 00005-C,
" Overtime Authorization" 5.3.3 00007-C, "Vogtle Duty Manager / Response Team" 5.3.4 00005-C,
" Plant Inck And Key Control" i
5.3.5 00012-C,
" Shift Manning Requirements" i
5.3.6 00052-C,
" Temporary Changes To Procedures" 5.3.7 00054-C,
" Rules For P.erforming Procedures" l
5.3.8 00152-C,
" Federal And State Reporting Requirements" I
5.3.9 00301-C,
" Main Control Room Access And Personnel Conduct" 5.3.10 00304-C,
" Equipment clearance And Tagging" 5.3.11 00306-C,
" Temporary Jumper And Lifted Wire Control" l
5.3.12 00308-C,
" Independent verification Policy" 5.3.13 00404-C,
" Surveillance Test Program" 5.3.14 10001-C, "Imgkeeping" i
j 5.3.15 10002-C,
" Plant Operating Orders" a
5.3.16 10003-C,
" Manning The Shift" 5.3.17 10004-C,
" Shift Relief" 5.3.18 10006-C,
" Reactor Trip Review" 5.3.19 10017-C,
" Operations Reading Book"
7.
~
r PROCEDURE NO.
REVISION PAGE NO.
a VEGP 10000-C 21 26 of 29
~
5.3.20 10018-C, "Annunciat'or Control" 5.3.21 11879-Ce
" Independent Verification Documentation Log Sheet" 5.3.22 14000-1/2, " Operations shift And Daily Surveillance Logs" 5.3.23 14915-1/2, "Special Conditions Surveillance Imgs" 5.3.24 43007-C,
" Issuance, Use And Control Of Radiation Work Permits" END OF PROCEDURE TEXT O
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1 PROCEDURE NO.
REYW ON PAGE NO.
VEGP 10000-C 21 28 of 29 PLANT V0GTLE UNITS 1 & 2 TECH SPEC CIARIFICATION -
CIARIFICATION #2 i
McR SPEC $3 QUESTION OR AltEA NEEDING CIARIFICATION:
CIARIFICATION:
i T
4 1-l f
f l
E i
J t
l
- Review &
Concurrence Tectmical Support Ma3ser Date l
Approved By:
Date Manager Operations 1
FIGURE 2
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PROCEDURE NO.
REVS ON PAGENO.
~
VEGP 10000-C 21 29 of 29 i
PLAMT V0GTLE - UNITS 1 & 2 TECH SPEC CIARIFICATION TERMINATION REQUEST 1
j Request Termination of Tech spec Clarification No.
Tech Spec No.
Effective Date of Deletion:
i Remarks:
1 1
l i
Approved By:
l Technical Gupport Manager Date Manager operations Date FIGURE 3