ML20129H920
Text
_.
r DATE: July 30, 1991 MEMO TO: PIERCE SKINNER FROM: VOGTLE RESIDENT INSPECTORS
SUBJECT:
ALLEGATION CONCERNING ERRORS MADE IN UNIT 1 SHUTDOWN MARGIN CALCULATION ON JANUARY 19, 1989.
At 5:35 pm on January 19, 1989, control room operatr.,rs manually tripped the Unit 1 turbine and reactor to enter a planned outage to repair a leaking socket weld on the pressurizer loop seal safety relief valve drain.
After the unit was shutdown, an extra shift supervisor on shift completed procedure 14005-1, Shutdown Margin Calculation, which is required to be completed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when in Mode 3, 4, or 5, and signed the procedure at 7:13 pm on January 19, 1989.
The extra SS, however, incorrectly completed Data Sheet 2, which applied to conditions when TAVG 2 557 degrees Fahrenheit, when he should have completed Data Sheet 4, which applied to conditions related to entering Cold Shutdown (Mode 5).
That SDM calculation, using the wrong data sheet, resulted in a calculated SDM of 6.6% delta k/k and a required SDM of 2.58% delta k/k which indicated to operators that no boron addition to the RCS was required in order to enter Cold Shutdown.
On January 20, 1989, at approximately 9:00 am, a reactor engineer questioned the apparently low RCS boron concentration of 1333 ppm. Due to his concern, the unit cooldown was stopped until the SDM calculation was verified.
At 10:22 am the reactor engineer completed a SDM calculation that assumed a RCS temperature of 68 degrees Fahrenheit and 0 pcm Xenon worth.
His calculation, without taking credit for Xenon worth, showed that 1800 ppm boron concentration was necessary i
to obtain a SDM of 4.015% delta k/k compared to a required SDM of 3.47% delta i
k/k. It should be noted again that no credit was taken for Xenon worth which would have added approximately 3.8% delta k/k to the SDM and provided more than an adequate margin above TS requirements without further boration. Since no TS limit was exceeded, the licensee did not submit a report to the NRC.
On January 20,1989 at 1:38 pm, the On-Shif t Operations Supervisor, re-performed the SDM calculation which had been incorrectly performed at 7:13 pm on January i
19, 1991 using plant data in effect on January 19.
Those calculations, using Data Sheet 4, determined the SDM was 4.185% delta k/k compared to the required SDM of 1.92% delta k/k.
The resident inspectors reviewed procedure 14005-1, Data Sheets 2 and 4, the calculations concerning these data sheets dated January 19-20, 1989, and control room logs for,that time period.
The SDM calculation performed at 7:13 pm on i
January 19, 1989 was incorrect in that the wrong Data Sheet of procedure 14005-1 was used. However, there was no evidence to suggest that TS SDM limits were ever j
exceeded or that an inadvertent criticality would have occurred due to the use i
of the wrong data sheet. A factor contributing to the error was the confusing instructions on Data Sheet 2 of procedure 14005-1.
That procedure was subsequently revised on March 26, 1989 to simplify, consolidate and clarify the data sheets.
It should also be noted that the licensee failed to write a deficiency card for this event which would have prompted a licensee followup review of the error.
1 (1/
J 3DM11989.WP ev 9611040118 960827 PDR FOIA KOHN95-211 PDR
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l PRIORITY ATTENTION REQUIRED MORNING REPORT - REGION II AUdUST 12, 1991 t:
_ LICENSE E/ F ACILITY NOTIFICATION /5UBJECT
'GPC/V0GTLE le 2 ORGANIIATION CHANGES EVENT EVENT NO. N/A THE FOLL0hING ORGANIIATIONAL CHANGES hERE ANh0VNCED AT PLANT v0GTLE:
PAUL RUSHTON - PRESENTLY V0GTLE MANAGER OF EhGINEERING AND LICINSING
~ l AT THE CORPORATE OFFICE WILL BE MOVING TO THE PLAhT AS A MANAGER-IN-TRAINING IN TME SENIOR REACTOR OPERATOR LICEhSE TRAIhING PROGRAM.
PLANT SUPPCRT WILL TOM GREENE - PRESENTLY ASSISTANT GENERAL MANAGER BE MOVING TO THE CDRPORATE OFFICE AS V0GTLE MANAGER OF EhGINEERING ANO LICENSE.
g -
~-
ASSISTANT GENERAL MANAGER - OPERATICNS WILL (SKIPKITCHENS-PRESENTLY MOVE TO A SSIST ANT GENERAL MANAGER - PLANT SUPPORT.
RNIE BEASLEY - PRESENTLY MANAGER OPERATIONS AT THE P L A P.T WILL et y TO ASSIST ANT 'GENER AL MANAGER - OPERATIONS.
1 THE EFFECTIVE DATE OF THE CHANGES HAS NOT BEEN DETERMINE 0.
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REGIONAL ACTION: FOR INFORMATION ONLY.
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CONTACT!
S. SPARKS i !
FTS:
841-5619 i
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interoffice Correspondence Georgia Power ao.
I 1
DATE:- August 15,-1991 RE:
Technical specification Clarifications Log:
NOTS-00898 j
FROM:. William B. Shipman l
TO:
Operations Department Employees i
j
- Earlier this year, the NRC Resident Inspecte rs at VEGP reviewed three i
- cccasions where VEGP Operations Department personnel found it j
necessary.to clarify specific Technical Specifications.
In these i
three instances, the Resident Inspectors determined that - VEGP's clarifications were safe and conservative.
(See the NRC's Inspection i
Report No. 91-05, dated. April 16,.1991, Section 2.f, at pages 4-5,
. copy attached).
The Resident Inspectors noted that this conservative cyproach taken in the evaluation and-clarification of Tech. Specs.
4 constituted a strength.
As many of you know, we have strengthened this important area of operations in recent times, in part as a result cf.NRC observations, including a revision to VEGP Procedure 10000-C
{
(Section 3.11) to provide for interdepartmental review of Tech. Spec.
1 clarifications.
I commend your efforts and urge you to maintain vigilance in assuring VEGP's compliance with Tech. Specs.
I also urge your continued adherence to established policy and practice for obtaining clarifications.
Of
- course, where the wording of the Tech.
Specs.
is
- clear, otraightforward application of the wording, without clarification, is oppropriate.
Examples of instances where it would be appropriate to obtain Tech.
Spec.
clarification are any of the three examples L
discussed.in NRC Inspection Report No.
91-05 and some other determinations of
" operability."
As you
- know,
" operability" l
clarifications frequently require the expertise of VEGP Departments i
i cutside the Operations Department, including Technical Support and Engineering, as well as the expertise of vendors and consultants on j
occasion.
one specific-area of' Tech. Spec. clarification which has come under NRC scrutiny over the past' year is the voluntary entry into Tech.
Spec. LCOs.
GPC has recently become aware of an NRC position that Tech.- Spec. LCOs and their associated Action Statements which d2 D91 l.
j.
provide a specific LCO action time (often referred to by the NRC as an
" Allowed Outage. Time" or "AOT") should not be voluntarily entered j
cxcept as expressly provided in associated Surveillance Requirements.
Further NRC guidance exists concerning voluntary entry into LCOs during power operations in order to perform preventive maintenance.
- l.
That. guidance explains that on-line preventive maintenance, primarily for.the purpose of reducing plant outage time or other operational r
convenience, should not-be undertaken without a-full appreciation of
{
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operaticas Departa nt Bspleyaco
_j' Toohaisal specification clarifications August 15, 1991 Page two the effects of_this practice on plant safety.
This would not apply to on-line preventive maintenar.ca to be performed in conjunction with corrective maintenance during a system / equipment outage.
WBS/
xc:
T. V. Greene, Jr.
W.
F. Kitchens J.
B. Beasley S.
H. Chesnut NORMS I
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GP-15309 I i new seccaa.m.
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Westinghouse EnergySystems i
Bectric Corporation nm pmewsipennsywsu 15230.c355 l'
i August 16 -1991 i
NSL-0PL-I-91-490 f
1 Ref: 1) Log: ELV-03040 2
GP-14649 3)JWCAP-ll338 Mr. C. K. McCoy Vice President, Nuclear, Vogtle Project i
Georgia Power Company P. O. Box 1295 i
Birmingham, AL 35201 4
f V0GTLE ELECTRIC GENERATING PLANT UNIT 1 l
Mode 5b Baron Dilution
Dear Mr. McCoy:
Georgia Power Company has reqJested that Westinghouse examine the effect of l
opening Chemical and Volume Control System Valves (CVCS) 1208-U4-176 and 177 j
during Mode 5b (RCS drained to aid loop) operation at the end of Cycle I for Vogtle Unit 1.
The Boron Dilution event in Mode 56, with the above valves open, i
was not specifically analyzed for Cycle I because it was administrative 1y
)
Thus, Georgia Power Company requested that the event in
' precluded from occurring.
l this mode for Cycle 1 be specifically addressed, as outlined in Reference 1.
p Analyses performed for Vogtle Unit I demonstrate that the Mode 5b boron dilution event, with the above mentioned valve's open, and the Cycle I high flux at shutdown setpoint of 3.16, will yield accssptable results for Cycle 1.
he analyses used assumptions consistent with those presented in Reference 2, but with a high flux j
i at shutdown setpoint of 3.16. The analyses were performed with initial boron concentrations specifically requested by Georgia Power Company. Two cases were examined. Case 1 assumed an initial boron concentration of 774 ppe and Case 2 assumed 1130 ppe (see Reference 1), based on the time that the CVCS valves were These two cases also assumed a critical boron concentration of 515 ppm (see 4
open.
Table 6.1 of Reference 3 for End of Life Conditions, 68'F), per Georgia Power's l
request.
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GP-15309 Mr. C. K. McCoy.
The results of the Case 1 and 2 analyses are summarized in Table 1 on the following page. Specifically, the analysis demonstrates that there was more than 15 minutes (minimum acceptance criterion) from the time of alarm prior to criticality for the operator to take appropriate actions to mitigate the Baron Dilution event.
If there are any questions, please contact Steve D1Tommaso at (412) 374-5277.
Sincerely.
WESTINGHOUSE ELECTRIC CORPORATION
,.[.
J. L. Tain, Manager Georgia Power Company Projects Attachment cc:
C. K. McCoy IL, IA R. J. Bush IL, IA NORMS (Vogtle Site)
IL, IA G. L. Greenwood IL, IA P. D. Rushton IL, IA W. B. Shipman IL, lA L. A. Ward IL, IA A. E. Cardona IL, lA R. Florian IL, IA 4
1 h
1637Camr/081491
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2 Table 1 Boron Dilution Results for Mode 5 - Drained L1wn Q13 Initial Baron Conc.
Total Time Time from Alarr to Crit.
I 774 ppm 2900 min 538 min 2
1130 ppe 5593 min
>1000 min Acceptance Criterion = 15 minutes 9
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i s 40 invemess Center Par 6rw2y' l-Pest Offce Box 1295 BemingNim. Alabama 35201 i
Teie none 205 877 7122 m
GeorgiaPower 4
I C. K. McCoy
.Vice Presioent, Nuclear mesww n:?nc nste-vog:le Protect I
l August 28, 1991
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f LETTER CONTAINS 3'
INFORMATION EXEMPT FROM DISCLOSURE j
UNDER 10 CFR 5 2.790 j
J l
i Mr. James Lieberman Director, Office of Enforcement
~
~U.S. Nuclear Regulatory Commission
. Washington, D.C. 20555 f
Ret Response to Demand for Information
[
Dear Mr. Lieberman:
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}
This letter responds to a letter of June 3, 1991 from Mr. James Sniezek, Deputy Executive Director for Nuclear Reactor j
Regulation.
Mr. Sniezek's letter forwarded a Demand for
'Information concerning an event which occurred at Georgia Power L
Company's Vogtle Electric Generating Plant ~("VEGP") on October 12 14j l
and 13, 1988..- Since Mr. Sniezek's transmittal was not to be 9
placed in the Public Document Room until a decision in this h
4 matter is made, GPC requests that this letter and the enclosed g
Response be similarly treated as exempt from disclosure under 10 4
CFR S 2.790.
The NRC's letter and Demand for Information expresses concern that certain VEGP managers and supervisors may have intentionally disregarded Technical Specifications in an attempt to facilitate outage activities.
As you may be aware, the NRC's Office of. Investigations ("OI") initiated a review of this event in late January, 1990 after the NRC received an allegation
. stating that VEGP Unit I was willfully and intentionally placed i
'i in a condition prohibited by its Technical Specifications.
OI's investigation was completed on March 19, 1991, more than a year j
.after its initiation.
Nonetheless, Georgia Power Company ("GPC")
is convinced that an impartial and thorough review of the i
information supplied in the-enclosed Response to the Demand for Information will. conclusively demonstrate that Technical kp Specifications were not-intentionally disregarded or willfully
,,)d -
t violated by these employees.
r The enclosed Response specifically responds to the Demand f
f
'for Information. -As more fully explained in the enclosed Y9A -
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- - - - -- - - - - -~
- - l i
l Mr. James Lieberman j
August 28, 1991 i
Page 2 1
4 Response, the Reactor Makeup Water Storage Tank ("RMWST")
~
. discharge valves -176 and -177 were opened on the night shift of j
October 11-12, 1988 to permit the filling of the " chemical addition pot" with hydrogen peroxide.
The hydrogen peroxide was j
to be added to 121e Reactor Coolant System ("RCS") to chemically clean the System as a pre-planned and scheduled outage activity.
1 This shift did not recognize a Technica'l Specification conflict, 3;
j-much less commit a willful violation.
As to the activities on (ggtL this shift, GPC has identified the specific causes which fg93 t-contributed to the failure of the operators to recognize a Technical Specification compliance issue as 1) inadequate planning'and procedures, and 2) inadequate training and guidance.
J This was aggravated by lack of experience as this was.the first outage performed at Plant Vogtle.
The actual context of the event, then, was a pre-planned evolution conducted for the first i
-time at VEGP by relatively inexperienced operators who had been l
provided inadequate guidance.
The first opening of the subject valves on October 12, 1988
)
was personally directed by a Support Shift Supervisor.
In accordance.with the pre-planned procedure, this operator specifically supervised the actual opening of the discharge valves -176 and -177 on the night shift of October 11-12, 1988.
The shift was under the general supervision of Messrs. Bowles and Cash.
Messrs. Bowles and Cash, the Support Shift Supervisor, and p,
the other. shift personnel did not recognize that the plant was in,d ;oi i
a " loops not filled" condition requiring those valves to be
\\;c,
'Instead, these operators were closed and secured in position.
4 focused on lowering the RCS level to "mid-loop" or the " top of /d, Y
the hot legs" which they equated with the " loops not filled" condition.
This "mid-loop" conditipn was not reached on the night shift of October 11-12, 1988.
These operators, who IGPC observes that the allegation supplied to the NRC in
-January, 1990 also erroneously equates a "mid-loop" elevation condition of the'RCS of 1888-0" with " loops not filled" Mode 5.
An with these three operators on the night shift of October 11-12, the submitter of the allegation apparently viewed the terms-of."mid-loop" and " loops:not filled" as interchangeable.
Such is not the case.
On the morning'of October 12, 1988 by about 3:30 (CT) the RCS water level had been drained down to the 1898-a.m.
.0" level, and the steam generator tube bundles had'been drained; 1the Plant was in' Mode 5 with loops not filled, and Technical
. Specification 5 3.4.1.4.2 was applicable.
However, the RCS water level had not yet been lowered to a "mid-loop" condition as than 4
' understood by these operators.
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Mr.-James'Lieberman j
. August 28, 1991 i
Page 3'
]
. possessed inadequate training and guidance concerning the " loops i
l not filled" status of the RCS, believed that the condition 1
triggering the Technical Specification had not yet been reached.
j j
Later, on the morning of October 12, 1988, the on-coming Shift Supervisor identified the Technical Specification as a potential constraint to the chemical cl'eaning evolution.
At that i
point.in time, somewhere-between 5:07 and 5:33 a.m.
(CT),
fg, Mr. Bowles, who was being relieved as Shift Supervisor, j -
recognized for the.first time the potential applicability of the H
i.
Technical Specification with respect to the opening of RMWST j
- valves -176 and -177 on his shift.
Mr. Bowles recorded a " late entry" which acknowledged his crew's activities and the specific i
Technical Specification at issue.
This log entry, in GPC's view, confirms the straightforward, simplistic manner in which the
~
chemical ~ cleaning evolution was approached by the night shift and i
the late realization that Mode 5 " loops not filled";might have i
been entered.
Again, to GPC's knowledge, no night shift crew j
member held any reservation or concern, or identified any regulatory constraint, applicable to the pre-planned and I
scheduled chemical cleaning evolution.
4 In'the Demand for Information and its transmittal letter, the NRC states that OI has concluded previously that this event j
involved willful Technical Specification violations.
GPC takes these charges very seriously and, accordingly, we have conducted a thorough review of this matter, including the portions of the ggpt.
With respect kuhd'.
OI record available to us.
GPC has substantial reservations as to the completeness and accuracy of the OI review.
g737 i
to the licensed personnel on the night shift of October 11-12, pg@ca) 1988,-the record is clear that they were unaware of the g'
implications of Technical Specification 3.4.1.4.2 to scheduled activities prior to shift turnover.
This apparent deficiency in D[)t,7 l
OI's analysis is underscored by OI's failure to interview the W'
l SRO-licensed Support Shift Supervisor who personally supervised l
the addition of hydrogen peroxide to the chemical mixing tank
!i l
during the night. shift.
GPC also believes'that OI ignoran the institutional causes
~
of the entrance into the LCO by thir shtti crew.
The specific procedure relevant and central to thig ar;tivity was the detailed @9*g procedure for the outage chemistry activities contemplated for
&Mgo Unit 1 which.was developed by the Health Physics and Chemistry t..
Department (Procedure 49006-C, approved June 9, 1988).
This procedure, at page 15 of 36, prcvides for the drain-down to mid-
-loop'and reguires that "when tac drain-down is complete, Hydrogen
' Peroxide should be added.n The developer of this procedure had i
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0-i-
Mr. James Lieberman August-28,-1991 e
[
Page 4' i-1 incorrectly concluded that no change to Technical Specificatien was involved.
With respect to the activities of the day s'hift of October 12, 1988, GPC's enclosed response reviews the actions of the i
Operations Manager, Mr. W. F. (Skip) Kitchens relative to his interpretation of Technical Specification 3.4.1.4.2 as permitting 4 the RMWST valves to be opened for a short period of time for chemical. cleaning activity.
Substantial doubt exists that LMr. Kitchens knew, or should have known, that the manipulation to S l
the open position of the RMWST valves was prohibited by-the 1
cTechnical Specification (as indicated in the Demand).
Also, no ygp
-doubt exists that he reached his interpretation that his actions
\\d pr
'were allowed by the Technical Specification after conscientiously 0
i and openly reviewing the matter, after obtaining advice from a l-more experienced Operations manager and others, after reviewing l
documentation relevant to interpreting the Technical l
Specification, and after applying principles of Technical Specification compliance which are established and recognized in d
j-the industry.
His actions were consistent with NRC guidance pLb 1
l issued prior to the activity which stated that "the NRC endorses. g23044 j.
Voluntary Entry into the Action Statement Conditions and has F
structured the Technical Specification to permit the licenses to l
exercise judgment within the latitude permitted by the Action (01 Statement language in the Technical Specifications."
Thus, if I
his actions led to a Technical Specification violation, it i.
certainly sas not a willful violation.
3 Moreover, the enclosed Response establishes that reasonable i
minds can differ as to whether the actions taken on October 12-j 13, 1988 violated NRC requirements.
These actions were viewed, d0 in good faith, as voluntary. entries into a Limiting Condition for operation ("LC0") in which the required action was completed "A
g within an "immediate" duration as required by the Action b
i Statement.
As one basis for this proposition, GPC is aware of a more recent, similar event reviewed:by Region-II involving the voluntary. entry into a Limiting Condition for operation at i
ggf another. facility where the required "immediate" action was viewed
@.7 JAC- !
by the. licensed operator as permitting voluntary entry into the 2
LCO'for a duration of time for a planned evolution.
This
. demonstrates tliat other operators are still making this judgment.
S<jayW l 9
GPC's posit? 9 that well-intentioned persons can reasonably
~
interpret -Technic al Specification 3.1.4.1.2 as permitting
.. voluntary entrance for short durations is supported, also, by the history of-the January, 1990 allegation which prompted the NRC's
-review of this matter. -The allegation was submitted anonymously 2:
5 E
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4 Mr. James Lieberman August 28, 1991 Page 5 i
t i
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by a former manager and Plant Review Board member.
On November 17, 1989 this individual voted that the October, 1988 i
event was not reportable to the NRC under 10 CFR S 50.73, reflecting his conclusion at that time that the events were not t
prohibited by Technical Specification.
He testified to this f
j jSAD effect on February 8, 1990 in a transcribed OI interview.
These events, and the fact that NRC and indus'try representatives have Wguh pg, i
long recognized the. ambiguity inherent in the use of the word"imme i
l NRC guidance to licensed operators is far more appropriate than 4-formal enforcement action.
OI's oversight of relevant and material facts surrounding l
}
the October, 1988 chemical cleaning also is reflected by an apparent total discounting of Mr. Kitchens' good faith, I
i straightforward efforts in interpretation of the relevant 4
Technical Specification.
Mr. Kitchens postponed the chemical cleaning, applied a well-established and observed principle of Technical Specification construction (i.e., voluntary entrance into an LCO is permissible provided that the associated Action l
Statement is complied with), consciously reviewed the relevant portions of the FSAR, and obtained input from a more experienced t
Operations manager in addressing the meaning and application of i
the Technical Specification.
This review was open and shared with those on shift and others, perhaps including an NRC Resident 4
. Inspector.
For OI to reach a conclusion of willful and i
i intentional wrongdoing while possessing this information is I
inconceivable.
j After a careful and thorough review, GPC has concluded this j
matter is not reflective of wrongdoing on the part of VEGP
- dbpg, licensed operators but is indicative of historic institutional l
weaknesses (i.e., planning and procedures for infrequent gegvd6 O
gV evolutions and training and guidance for operators responsible f
f for such evolutions) and ambiguous terminology in Technical Specifications in light of historic practices and interpretations (i.e., routine voluntary entrance into LCOs for maintenance j
activities; "immediate" durations in LCOs and arsociated action statements).
NRC representatives have ir,41cated that significant 4
. internal discussions and disagreements concerning the appropriate l
interpretation of the subject-Technical Specification and the
~
reasonableness of Mr. Kitchens' interpretation preceded the issuance of the Demand for Information.
This discussion, the extensive time taken by.OI in reaching _a conclusion (over a year Jaince completion of interviews of the operators and Mr.. Kitchens),.and the clear potential in the future for similarly-situated operators to' reach the same type of conclusion
Mr. James:Lieberman August'28,'1991 Page 6 demonstrate the inappropriateness of formal enforcement action in
.this matter.
GPC recognizes that the NRC now views."immediate" LCOs and-associated action statements as action statements which implicitly prohibit voluntary entrance., The Company has already implemented measures to assure that this position is implemented by VEGP operators.
The information provided herein is true and correct to the best of-my knowledge.
Sincerel yours s
C. Kenneth McCoy Sworn to and subscribed before me this gj day of August, 1991.
4m +. Glu Notary Public
(
My Commission expires:
in owwpu,JWt n'.)1.Ma CKMinjf Enclosure cc: _ Mr. James Sniezek Mr. Stewart Ebneter Mr. Alan Herdt Assistant General Counsel for Hearings and Enforcement Mr. David-B.'Matthews u
u
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION' e
In the Matter of l
GEORGIA POWER COMPANY, Docket Mos. 50-424 l
31 31 50-425 j
EA 91-063 4
(Vogtle Electric Generating Plant, Units 1 and 2) 4 3
i-GEORGIA POWER COMPANY'8 RESPONSE TO TEE NRC'S JUNE 3, 1991 DEllAND FOR INFORMATION O
s 2
(
4
i TABLE OF CONTENTS
~
1 1
I.
INTRODUCTION.
1 II.
BACKGROUND.
A.
The First VEGP Unit 1 Refueling Outage And 1
The Chemical Cleaning Process J
B.
The VEGP Technical Specifications And 2
Facility Safety Analysis Report 1.
VEGP Technical Specification 5 2
3.4.1.4.2 l
2.
VEGP Facility Safety Analysis Report, 3
3 Section 15.4.6 GEORGIA POWER COMPANY'S DETAILED RESPONSE TO SECTION 4
III. III OF THE NRC JUNE 3, 1991 DEMAND FOR INFORMATION.
4 A.
The Actions of Messrs. Kitchens, cash And Bowles With Respect To The Addition of Chemicals To The VEGP Unit 1 Reactor Coolant System On October 12 And 13, 1988 4
1.
The Night Shift of October 11-12, 1988 and the Actions of Messrs. Bowles and l
4 cash 9
2.
The Day Shift of October 12, 1988 and 8
the Actions of Mr. Kitchens.
i B.
Messrs. Kitchens, Cash And Bowles Should Not Be Removed From Licensed Activities Because They Did Not Willfully Violate The Tech.
10 Specs.
1.
The Standards for " Willfulness" and for Enforcement Against Individuals.
10 The " Willfulness" Standard 11 a.
I b '.
Enforcement Actions Involving 13 Individuals a
2.
Messrs. Bowles and Cash Lacked the
)
Necessary State-of-Mind Requisite to a 14 Willful Violation.
i 1
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i s.,
TABLE OF CONTENTS, continued 3.-
Mr. Kitchens' Interpretation of. Tech.
i Spec. $ 3.4.1.4.2 was Reasonable and in 18 4
Good Faith i
4.
The Chemical Addition Evolution Lacked 22 Safety Significance.
1 5.
Reasonable Minds Can Differ as to Whether, in 1988, Voluntary Entry into l
the Tech. Spec. 5 3.4.1.4.2 LCO was Permissible.
24 Georgia Power Company Procedures Relating To I
C.
The Issuance And Control Of Technical i.
Specification Clarifications.
32 i
\\
1.
The Policies and Procedures in Place at the Time of the Addition of Chemicals on October 12 and 13, 1988 32 2
2.
Current Policies and Procedures.
32 4
s D.
The Georgia Power Company Outage Planning 34 Process
/
i 1.
Planning for the 1R1 Outage and Development of the Procedures to Add Chemicals to,the RCS at the Mid-loop Condition of Mode 5.
34 2.*
Current Outage Planning Process.
36 E.
Georgik Power Company Policies, Procedures, Practices And. Training Respecting Compliance With The VEGP Technical Specifications.
37 i
4 IV.
REASONABLE ASSURANCE EXISTS THAT GEORGIA POWER COMPANY CURRENTLY CONDUCTS AND WILL IN THE FUTURE CONDUCT l
LICENSED ACTIVITIES IN ACCORDANCE WITH THE VEGP i
TECHNICAL SPECIFICATIONS AND ALL OTHER NRC 39 REQUIREMENTS,.
4 41
)
i V.
' CONCLUSION.
i 1
11 i
4 I.
INTRODUCTION.
On June 3, 1991, the Nuclear Regulatory Commission ("NRC")
issued a " Notice of Enforcement Conferencs and Demand for I
Information" to the Georgia Power Company ("GPC" or the
" Company") with respect to the addition of chemicals to.the
. reactor coo ant system of Vogtle Electric Generating Plant l
("VEGP") Unit 1 on October 12 and 13, 1988, during the first refueling outage of that unit.
The Notice stated that the event involved "the apparent willful violation of Technical Specification 3.4.1.4.2" which had been investi' gated by the NRCThe in response to information the NRC received in January 1990.
Notice contained a " Demand for Information" listing five specific items.of information which GPC was to provida.
A similar Notice of Enforcement Conference and Demand for Information was sent to Mr. W. F. Kitchens, the VEGP Manager of Operations during the event.
Also, separate Demands for Information were sent to Mr.
J. P. Cash and Mr. J. E. Bowles, who were licensed Senior Reactor Operators "on shift" on October 11-12, 1988.
Following a brief background discussion (Section II), GPC provides herein (Sections III.A through III.E), the specific information required by the Demand for Information.
Exhibits 1-47, referred to herein, are included herewith, separately bound as " Appendix I."
Attachments 1, 2 and 3, referred to herein, are included herewith, separately bound as " Appendix II."
)
II.
BACKGROUND.
The First VEGP Unit 1 Refueling Outage And The Chemical A.
Cleanina Process.
5 The first VEGP Unit i refueling outage (sometimes referred to as "1R1") began on October 8, 1988 and lasted 52 days.
Numerous major activities typical of a first refueling outage were performed.
Also, the addition of hydrogen peroxide to the Reactor Coolant System ("RCS") was scheduled to be performed i
during the Cold Shutdown mode, as a planned evolution.
Addition of hydrogen peroxide to the RCS is an established and accepted method of chemically cleaning the internals of the i
RCS in order to' remove contaminated particles (referred to as
" crud") such that the radiation exposure to individuals working in and around the RCS during the outage is significantly reduced.
The procedure is referred to as a " crud burst" or " chemical cleaning" and is performed during Cold Shutdown (Mode 5) prior to opening up the RCS for refueling (Mode 6).
While the procedure may be performed with the RCS full, it may be, and has been, performed at other plants with a reduced RCS coolant inventory.
1 i
Planning for the chemical addition evolution at VEGP during the 1R1 outage began in December 1987.
By April 1988, a decision had been made to add the chemicals while the RCS was at a reduced inventory pursuant to the recommendation of the VEGP Health The 1R1 outage schedule Physics and Chemistry Department.
identifying the chemical addition evolution was approved by the VEGP General Manager after it had been approved by all VEGP A more detailed discussion of the planning Department Managers.
process for the 1R1 outage relative to this evolution is provided in Section III.D of this response.
In the case of VEGP, the addition of hydrogen peroxide to the RCS.was to be accomplished with the Chemical and Volume control System ("CVCS").
As illustrated on the simplified piping Valve 177 controls the discharge diagram attached as Exhibit 1, of unborated water from the Reactor Makeup Water Storage Tank j
and Valves 175, 176, and 183, located downstream of
("RMWST"), govern three independent flow paths leading to the Valva 177, The flow path through Valve 176 is the one used to add RCS.
chemicals to the RCS and Valve 176 regulates the input of RMWST water into the chemical Mixing Tank (also referred to as the
" Chemical Mixing Pot" or " Chem. Add Pot").
Therefore, to add RNUST water to the Chemical Mixing Tank, Valves 177 and 176 must be opened.
Valve 181 (the outlet valva), must also be opened before the discharge from the chemical Mixing Tank can flow into the RCS.
The VEGP Technical Specifications And Facility Safety B.
Analysis Report.
1.
VEGP Technical Specification 5 3.4.1.4.2.
From March 1987, when the Unit 1 operating license was issued, through 1989, Technical Specification (" Tech. Spec.") S 1
l 3.4.1.4.2 required, in relevant part, that the RMWST discharge Valves 175, 176, 177, and 183 be closed and secured in position j
while the reactor is in Mode 5 with the RCS in the " Loops Not i
Filled" condition.
l The Westinghouse analysis of the boron dilution accident divides Mode 5 into two conditions: Mode Sa, " Loops Filled," and Mode 5b, " Loops Not Filled."
The " Loops Not Filled" condition is not defined in the VEGP Tech. Specs.
Also, in October 1988, the
" Loops Not Filled" condition had not been explicitly defined for the VEGP operators during their training or in any guidance documents or procedures.
The Westinghouse analysis of the boron dilution accident defined " Loops Not Filled" based on volumes which. equated approximately with a RCS water level below 192 feet SI when the RCS piping, including the primary side of the steam generator tubes, was not full (e.g., there was an air void
.me i
i
d i
- somewhere in the RCS piping, including the primary side of the steam generators).
333 Exhibit 17.
The relevant " Action Statement" for Tech. Spec. S 3.4.1.4.2 l
reads:
With the [RMWST discharge valves) not closed and secured in j
position, immediately close and secure in position the RMWST discharge valves.
sheet 1 of 2" 1
Egg Tech. Spec. S 3.4.1.4.2, attached as Exhibit 2, The " Bases" section of the Tech. Specs. explains the purpose of Tech. Spec. S 3.4.1.4.2 as follows:
1 The locking closed of the required valves in Mode 5 (with the loops not filled) precludes the possibility of uncontrolled boron dilution of the filled portion of the Reactor Coolant System.
This action prevents flow to the RCS of unborated water by closing flowpaths from sources of unborated water.
These limitations are consistent with the initial conditions assumed for the boron dilution accident in the safety analysis.
I
)
Egg Exhibit 2, sheet 2 of 2.
i VEGP Facility Safety Analysis Report, Section 15.4.6.
2.
Section 15.4.6 of the VEGP Facility Safety Analysis Report l
( FSAR ) describes the analysis of a boron dilution accident j-resulting from a malfunction in the CVCS.
In October 1988, FSAR S 15.4.6 contained the following j
language in Section 15.4.6.2.2.2:
i For dilution during cold shutdown,~the Technical Specifications provide the required shutdown margin as a l
function of RCS boron concentration.
The specified shutdown margin ensures that the operator has 15 min from the time of i
i the high flux at shutdown alarm to the total loss of shutdown margin.
q Egg Exhibit 3 at p. 15.4.6-4.
Additionally, Section 15.4.6.2.1.2 expressly stated that an analysis had been performed "to evaluate i
i-boron dilution events during cold shutdown."
It identified four 2
" initiators" which had been analyzed, including the " failure to secure chemical addition," but that initiator was not identified as the most limiting.
It also included the following paragraph i
at the very and of the section:
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August 29, 1991 4
Note to:
Vogtle F e, R 90-09) i i
i From:
DickHop jg
Subject:
Telecon with H. Kohn 4
Completed a telecon with M. Kohn at 1:15 p.m. this day.
He i
requested status of DOL issue.
I informed him that the misrepresentation issue has been forwarded to DOL for their consideration.
In the interim, the NRC will do no more.
b will await DOL consideration of the matter but will ultimately address f
the issue in a 2.206 Decision.
Mr Kohn.also inquired as to whether the upcoming enforcement conference re Vogtle dilution incident would be transcribed and whether Mr. Mossbaugh and his attorney could attend.
I informed him that enforcement conferences are transcribed on a case-by-l case basis and that neither Mr. Mossbaugh nor his attorney would be permitted to attend.
He also inquired as to whether GPC had a copy of the OI Report.
I informed him that the Reports are not normally provided to licensees at thia stage.
Usually, only the synopsis of the Report is provided.
I followed up with George Jenkins.
He informed me that the i
enforcement conference would be transcribed and that the OI Report has not been released.
I called back Mr. Kohn and informed him regarding these matters.
cc:
J. Goldberg, OGC H. McGurren, OGC
- y. Hood, NRR VG. Jenkins, RII 1
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renan
-