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UNITED STATES i
S NUCLEAR REGULATORY COMMISSION o
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WASHINGTON, D. C. 20666 January 8,1992 bIC1510iiAL 8QIONONLY Docket No. 50-424 i
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MEMORANDUM FOR: James Lieberman, Director j
office of Enforcement 4
i FROM:
James G. Partlow Associate Director for Projects Office of Nuclear Reactor Regulation
SUBJECT:
PROPOSED LEVEL IV VIOLATION - V0GTLE UNIT 1 l
The Division of Reactor Projects I/II and the Division of Systems Technology have reviewed the Regional Enforcemerit Recommendation dated December 27, 1991, regarding Vogtle Unit 1 proposing three Severity Level IV violations without escalated enforcement. The three violations are associated with the AIT's review of the loss of decay heat removal capability that occurred at Vogtle Unit 1 on October 26, 1991', and involve procedure and reporting issues, and system modification controls. We concur with the action proposed by the Region.
Our specific connents regarding the questions on the Enforcement Action form are enclosed.-
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N i
Jalus G. Partlow l
Associate Director for Projects Office of Nuclear Reactor Regulation
Enclosure:
As stated i~
CONTACT:
D. Hood, NRR i
504-3049 SENSIT nt-uttfSr!"L !"FOLiiun -WERNALDISTRiovuun vid5 A,p/.
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J 9611040167 960827 PDR FOIA KOHN95-211 PDR
s s Rt4LC_LSIONAt1M)hrditTERNAC DISTRI SE C
0FFICE OF NRR COMENTS ON REGIONAL ENFORCEMENT RECOMMENDATION EA 91-195
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Were the violations technically accurate and factual?
Yes Did the region properly assess the root causes of the violations and the adequacy of corrective actions?
Yes Were the licensee's prior and current performance and prior notice of the violations properly reflected?
Yes Is the regulatory significance of the violations or root causes properly evaluated?
Yes Is the licensee's position, if known, regarding the violations properly reflected?
Yes Is the message given to the licensee appropriate to the situation?
Yes Suspension, etc.)y different type of enforcement action appropriate (Order,(Not amou Is a significantl
, and if so, why?
No Any other consents on factual or technical issues.
NRR Office
Contact:
D. Hood, NRR 504-3049 DATE:
SENSIT4N;DEQSIONJL -MF5RemiiGN---MTERt#C515TRI BtJT10N h
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UNITED STATES j
k,j NUCLEAR REGULATORY COMMISSION
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o REGION la l4 3
,g 101 MARIETTA STREET,N.W.
ATLANTA, GEORGI A 30323
\\*YNos.50-424,50-425
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. Doc JAN 14 #.
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-EA 91-195
. Georgia Power Company ATTN: Mr. W.;G. Hairston, III Senior Vice President -
Nuclear Operations
- P. O. Box 1295 i
Birmingham, AL 35201
)
Gentlemen:
I
SUBJECT:
NOTICE OF VIOLATION (NRCINSPECTIONREPORTNOS. 50-424/91-30 AND 50-425/91-30)
This refers to the special inspection conducted by the Nuclear Regulatory Commission (NRC) (Augmented Inspection Team (AIT) at your Vogtle ElectricVEG i
Generating Plant l
The AIT was chartered on October 28, 1991, and directed to review the loss of decay heat removal -capability that occurred at your facility on October 26, i.
1991.
The report documenting this inspection was sent to you by letter dated
[
December 2, 1991.
The findings of the AIT indicate that operations personnel failed to exercise adequate control over the Unit 1 reactor cavity draindown evolution, which
.resulted in the interruption of decay heat removal for approximately 16 minutes and a resultant 20 degree Fahrenheit increase in core temperature.
While. the. sudden increase in core temperature did not have significant consequences, the performance of the operations staff which allowed this l
. condition to occur, particularly the control room operators, is cause for concern.
The AIT found that' the off-going Unit Shift Supervisor was not aware of the commencement of the draindown.
Additionally, the Auxiliary Plant Operator i
(APO) sent to monitor the reactor cavity-vessel level locally, did not.use the 4
tygon tubing level indicator as directed. Rather the APO used the wrong level instrument (sight glass) which was valved-out of service because it was a new modification that had not been tested and turned over to the station. About one hour after the. start of the draindown, an oncoming Plant Equipment Operator (PEO), who relieved the APO, discovered that the sight glass was valved out and notified the control. room.
Apparently, the PE0.did not recognize that the tygon. tubing which was located about 8 feet away should I
have been the correct indication to be monitored.
Though. control room personnel halted the draindown until the sight glass was valved in, they not only failed.to recognize the. error but also failed to assure the sight glass system was walked down and operable as one' isolation valve' remained closed.
'Moreover the plant operations staff was not aware that the level instruments in the control room were inaccurate because of a HEPA filter ventilation
. system connected to the Unit 1 pressurizer. vent point.
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Georgia Power Company 2
l As the draindown continued, the control room. operators noted indications that 4
the B Residual Heat Removal (RHR) pump was cavitating.
The B RHR pump was i
placed on miniflow and the A RHR pump was realigned from the draindown j
configuration to refill the reactor vessel. The draindown, which was intended to drain the water from the reactor cavity to a level of two feet below the vessel flange (192 foot level), progressed down to the mid-loop (186 feet i
. level). In view of the lack of adequate level indication, it was fortuitous 1
that a more significant situation did not occur.
4 Based on the results of the AIT inspection, certain of your activities i
appeared to be in, violation of NRC requirements, as specified in the enclosed Notice of Violation. (Notice).
Consideration was given to categorizing the j'
violations in the Notice at a higher severity level due to the performance problem and the inadequate design and installation procedures for reactor water level indication which resulted in a common mode failure for all level instruments.
Concerns with assuring adequate level indication and decay heat.
. removal have been, the subject of NRC generic communication with the industry.
Should similar violations occur in the future, escalated enforcement action i
may be taken.
I You are required to respond to this letter and should follow the instructions specified in' the enclosed Notice when preparing your response.
In your j
response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your reponse to this Notice, including your proposed corrective' actions and the results of future j
inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements, The responses directed by this letter and the enclosed Notice are not subject i
to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Action of 1980, Pub., L. No.96-511.
In accordance with 10 CFR 2.790(a), a copy of this letter and its enclosures
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will be placed in the NRC Public Document Room.
4 Should you have any questions concerning this letter, please contact us.
Sincerely, l
Luis A. Reyes, ctor i
Division of R a or Projects j
Enclosure:
5 Notice of Violation cc w/ encl:
(see next page) o 4
m._a_.
. Georgia Power Company 3
cc w/ encl R. P. Mcdonald Executive Vice President-Nuclear Operations Georgia Power Company P. O. Box 1295 4
Birmingham, AL 35201 C. K. McCoy
\\
f Vice President-Nuclear
- Georgia Power Company P. 0. 1295
-Birmingham, AL 35201 W. B. Shipman General Manager, Nuclear Operations Georgia Power Company i
P. O. 1600 Waynesboro, GA 30830 i
J. A. Bailey Manager-Licensing Georgia Power Company P. O. Box 1295 l
Birmingham, AL 35201 Nancy Gibson Cowles Consumers' Utility Counsel Office of Consumers' Utility Counsel 84 Peachtree Street, N.W., Ste. 201 Atlanta, Georgia 30302-2318 Office of Planning and Budget Room 615B 270 Washington Street, SW-Atlanta, GA. 30334 Office of the County Commissioner Burke County Commission Waynesboro, GA 30830 Joe D. Tanner, Commissioner Department of Natural Resources 205 Butler Street, SE, Suite 1252 Atlanta, GA 30334 cc w/enci cont'd:
(seenextpage)
I
,1 Georgia Power Company 4
cc w/ encl cont'd:
- Thomas Hill, Manager Radioactive Materials Program Department of Natural Resources 4244~ International' Parkway l
-Suite 114 Atlanta, GA 30354 i
' Attorney General
. Law Department 132 Judicial Building
' Atlanta, GA 30334' Dan Smith, Program Director of Power Production Oglethorpe Power Corporation 12100 East Exchange Place.
.P. O. Box 1349 l
Tucker, GA 30085-1349 Charles A. Patrizia, Esq.
Paul Hastings, Janofsky & Walker 12th Floor 1050 Connecticut Avenue, NW Washington, D. C.
20036 State of Georgia l
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NOTICE OF VIOLATION Georgia Power Company Docket No. 50-424 Vogtle Unit 1 License No. NPF-68 During the NRC inspection conducted on October 29 - November 1,1991, a violation of NRC requirements was identified.
In accordance with the " General Statement of Policy (1991), the violations are listed below:
and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, A.
Technical Specification 6.7.1.a requires written procedures be established, implemented, and maintained covering activities referenced in Regulatory Guide 1.33, Appendix A, Revision 2, February 1978.
Activities referenced include general plant operating procedures for refueling.
Implicit in this TS is the requirement that the procedures contain adequate guidance to ensure those activities are conducted properly.
Contrary to the above, on October 26, 1991, procedures used for reducing reactor water level provided no instructions directing Operations to verify that a correct reactor water level indication lineup existed, and provided no instructions to ensure an adequate vent path was established.
This is a Severity Level IV violation (Supplement 1).
B.
10 CFR 50, Appendix B, Criterion III, Design Control, requires that design control measures shall provide for verifying the adequacy of design, such as by performance of design reviews.
In addition, design
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changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design.
Measures shall also be established for the identification and control of design interfaces and for coordination among participating design organizations.
Contrary to the above, 1.
The licensee failed to verify the adequacy of the design for the reactor water level indicating system.
The connection of a High l
Efficiency Particulate Absorber (HEPA) filter to the Unit 1 pressurizer vent point affected the visual and electronic water level instruments in a nonconservative manner during the October 26, 1991, reactor water level draindown. An analysis for connecting the HEPA filter to this safety related system was not performed. Thus, the effect of this design change was not adequately reviewed.
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2.
The licensee failed to establish control and coordination among participating design organizations for the Unit I reactor water c
F level indicating sightglass.
The sightglass modification had not been adjusted and functionally tested by the Maintenance department.
Thus, the Control Room had not been notified in writing that the modification was complete and ready for use.
During the October 26, 1991' event in which reactor water level was reduced, the Operations department used the reactor water level indicating sightglass as one j
method of water level indication.
This.is a Severity Level IV violation (Supplement 1).
C.
10 CFR 50.72(b)(2)(iii)(B) requires the licensee to notify the NRC within four hours of the occurrence of an event that could have prevented the fulfillment of the safety function of systems needed to remove residual heat.
Contrary to the above, on October 26, 1991, the licensee failed to notify the NRC within four hours when the "B" RHR pump was removed from service due to. a cavitation. problem.
Had the "A" RHR pump been placed in operation under existing conditions, it would have experienced a similar cavitation problem.
Thus, the RHR system could not have performed its l
safety function..
l This is a Severity Level IV' violation (Supplement 1).
Pursuant to the provisions of 10 CFR 2.201, Georgia Power Company is hereby required to-submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control _ Desk Washington, D. C. 20555,
. with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector, Vogtle Electric Generating Plant, within 30 days of the date of the letter transmitting this Notice of Violation.
This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for i
each violation:
(1) the reason for the violation, or, if contested, the basis i
for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will. be taken to avoid further violations, and (4) the date when full compliance will be achieved.
If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified.
suspended, or revoked, or why such other action as may be proper should not be taken. -Where good cause is shown, consideration will be given to extending the response time.
' Dated at Atlanta,~ Georgia; this.14 day of Jan.1992
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January 30, 1992 ELV-03377 I
001000 i
l Docket No.80-424 4
l U. 8. Nuclear Regulatory Commission 1
ATTN: Document' Control Desk t
I, Washington, D. C.
20585 Gentlemen:
V0GTLE ELECTRIC GENERATIN8 PLANT l
REPLY TO A NOTICE OF VIOLATION AND 1
PR0p0$ED INP0$1 TION OF t!VIL PfMALTY h
On December 31,1991, the NRC issued a Notice of Violation (taforcement and proposed a $100.000 civil penalty _against Georgia Power i
Action $1-141)for alleged violations at the Vogtle Electric Generating Plant Company (CPC)
(VEGP). The enforcement action relates to an Incident at VESP which occurred in October 1988. is GPC's reply to the' Notice of Violation (NOV) in l
accordance with 10 CFR !.201. Georpia Power Company dentes the violations and i
protests the i.mposition of the civt penalty. Our response to the civil l-pensity, pursuant to 10 CFR t.205, is provided es Enclosure t.
Georgia Power Company respectfully requests reconsideratten of the violations and the civil penalty. As discussed in detail in the enclosures SPC denies that the violations occurred as alleged, and we consider the civl1 penalty to be 4
l unwarranted.
j Stacerely.
l C. K. McCoy I
Enclosures a
xc: teoreta Pow er Comennv Mr. W. B. 551 pean Mr. N. Sheibant i
NORMS f
L 5. helaar esaulatory Comminnina i-tr. 3. D. Ebneter, Regional Ads < n strator Mr. D. S. Wood, licensing Project Manager. NRA Mr. 8. R. Sonsor, Senior Resident Inspector, Vogtle
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.tNCLOSURE 1 V0GTLE ELECTRIC GENERATING PLANT - UNIT I REPLY TO A NOTICE OF VIOLATION NRC OUICf 0F INVf1TICAT10Ni Rfp0AT No. 2-e1001. EA 91-141 i
The following is a transcription of the. four violations as cited in the Notice of Violations A.
' Technical Specification (78) 3.4.1.4.2 (be OPERA 1H4 edition required that two residual heat removal (tion).
RNR trains shall train shall be in opera Reactor Makeu discharge valves (1208-U4-178,1208-U4-176,p Water storage Tank (RMWST) 1208-U4-177, and 1208-U4-183 i
shall be closed and secured in position whenever the plant is in Mode 5 w)ith reactor coolant loops not filled.
ACTION c. of TS 3.4.1.4.2 required that with the RMWST valves not closed and secured in position, ismediately close j
and secure in position.
4 s'
Contrary to the above, on October !! and 13 1988, with Unit 1 in Mode 5, loops not filled RMW57 valves 1204-U4-176 a,nd !!04 U4-177 were opened i 4
j order to add chemiuls to the. reactor coo 14at system.
f 8.
40.73(a)(!)(li)(3) reevires licensees to submit a Licensee Event Report (LER) within 30 days after the discovery of any event or conditten that basis of the plant.resulted in the nuclear power plant being in a condition ou
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Contrary to the above, on or about Movember 17, 1989, (PRB) determined that the opening of the RMWST valves specified inthe P i
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~ TS 3.4.1.4.2 was not reportable and, therefore, an LER was not subsf tied within 30 days, even though opening the valves on October it, and i
had placed the plant in a condition outside the desi n basis. Opening the 13,1988 valves constituted a condition outside the plant dest a basis because at the time the valves were opened an analysis for a boron d lution accident j
through the valves did not exist.
- c. Technical Specification 6.7.1 requires written procedures shall be i
by Appendix A of Regulatory Guideestablished, implemented, and Section 2 of Append' x A of RG 1.33,(AG) 1.33, Revuston 2. February 1978.
recoenends procedures for general plant l
operation.
4 The following procedures, in part implement 78 6.7.1.
I Vogtle Electric Generating Plant (tdown) Operations Proced 1.
VEGP i
It004-C, Unit Cooldown to Cold Shu i
statedinSectionD4.2.14thatvalves1-1208-U4-175,in use on Oc 1988
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1-Itb8-U4-174,1-1208 U4-177,1-1208-U4-183, and others be c locked and tagged in Mode 5, loops not filled.
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5 ENCLOSURE 1 (CONT.)
V0GTLE ELECTRIC GENERATING PLANT - UN!T 1 REPLY TO A NOTICE OF VIOLATION j
uncOytti0FINVf1TICATIONSREPORTNo. 2-91-001. fA el-141
- 2..Vtsp Procedure 10000-C, Conduct"of Operations, Section 2.10.2 in use October It and 13,1988 statedthattheUnitSuperintendent(US)is responsible to ensure plant operations are conducted in accordance with Technical Specifications and approved procedures.
f Contrary to the above:
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- 1. On October 12 and 13,1988, licensee personnel failed to implement the I
recuirements of procedure nember 12006-C in that,d, loc valves 1-1208-04-176 l
and -177 and 181, which were required to be close were opened in Mode 5, loops net filled.
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2.
On October 12 and 13,1984, the U$ did not ensure that plant operations t
i were conducted in accordance with Tschnical Specifications in that valves 1-1208-04-176 and -177. were opened in 4de 5 loops not filled, j
with the express knowledge of the US.
0.
10 CFR 50, Appendix B Criterion V, requires, in part, that activities affecting quality shall be prescribed by documented instructions, i
procedures, or drawings of a type appropriate to the circumstances and shall be accesplished in accordance with these instructions procedures, or drawings.
VEGP procedure No. 13007-1, VCTGasControlandRCsChemical i
Addition, Section 4.7 provide the instructions en chemical additions to the j
Contrary to the above, on October it and 13 1988 VESP Procedure Nos.
13007-1 and 35110-C were inadequate in that lhese p,rocedures did not contain provisions for addi chealcals to the reactor coolant systen in Node 5, loops not filled.
3 ocifically, the procedures specify such conditions as j
having a reactor coo ant pump running which is not possible in Mode 5, loops not f'lled.
This is a Severity Level !!! probles (supplement I).
Civil Penalty - $100.000 (assessed equally among the four violations).'
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ENCLO$URE 1 (CONTINUED) i V0GTLEELECTR!7CENERATINGPLANT-UNIT 1 reply TO A NOTICE OF VIOLATION l
NRC 0FFiff 0F INVf1TICAT10NS RfPORT No. f.90 001. EA 91-141 f
RE)P0NSE 70 V10LAtl0N A Adelant' n or Denial of the Violation a
l As stated in our October 1,1991. letter (Nr. C. K. McCoy to Mr. James N.
l
$ntezek, ELV-03148) and during the September it,1991 enforcement conference, when RMW$T valves y violation of the TS occurred on Octobe i
VEsp denies that an
- 1984, 176 and -177 were opened. The decision to volunterf i
the Limiting Condition for Operation (LCO of TS 3.4.1.4.2 1988 edition was consistent with the language of the T$ as)well as establishe(d practice an)d N i
guldence available at the time.
Because such an entry was not prohibited, no violation occurred.
l santi far Denial In its transmittal of December 31, 1991,- the NRC sets out the rationale behind the alleged violation of the T5: "the words of the T.S. prohibit uncontrolled boron dilution in Mode 5, loops not filled, hg erohibittna an dilutions throuah i
gg {1gg agg 31,1133..... tie words of the requ' rement clearly prohibit i
entering Action 6(sic)c of T.S. 3.4.1.4.t" (emphasis added)he word ' prohib This interpretation, which is cast in the negative case, i.e., t not to be found anywhere in the pertinent TS, is at odds with the overall structure and function of the TS, as well as a specific controlling TS i
prevision.
It is also at odds with all guidance as it existed in 988, and indeed prior to this enforcement action.
l First, as established by an NRC position which predated the October 1988 event by several years:
'The NRC endorses Voluntary Entry into the Action Statement Conditions and i
has structured the T5 to pennit the licensee to exercise judgement within i
the latitude permitted by the Action Statement language in the T$.'
i (See Attachment 1 to this Enclosure.)
I Conseeuently, entering Action Statement c of TS 3.4.1.4.2 was not prohibited for
'all dilutions." Rataer, only those dilutions which are not 'within the latitude permitted" by the Action Statement language of the 15 were proscribed.
I Second, the Vogtle TS expressly contemplates licensee judgement within the latitude permitted by the Action Statement language by defining two conditions which must occur prior to a violation:
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'Nonco'ap11ance with a specification shall exist when the requirements of the l'
Limiting Condition for Operation And associated Action requirements are not j
met within the specified time intervals.' (78 3.0.t, emphasis added) f#
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ENCLQSURE 1 (CONTINVEO)
V0GTLE ELECTRIC GENERATING PLANT - UNIT 1 1
REPLY TO A NOTICE OF V10LAT!0N i
NRC 0FFICE OF INVESTitAT10N1 REPORT No. f-e1001. EA #1-141
(
l In 1948, the latitude conferred by TS h4.1.4.1 Action Statement c allowed i
voluntary entry into the LC0 and associated Action requirements a in t>t specified 'ispediate' ilme interval contemplated by the TS.
Contrary to the NRC's assertion, T$ 3.4.1.4.2 was not violated by all dilutions through the flowpath at issue. A violation would have occurred only if the time interval allowed by the T5 was exceeded.. It was not. This interval was, for j
i this application reasonably detemined to be 15 minutes by consulting the Standard Review hlan criteria applicable to relevant dilution analyses. And, at least historically and prior to the event, entrance for this duration in the course of plant operations or for "whatever Mason' was not prohibited.
(See i
AttachmentttothisEnclosure.)
l ters 'ismediate' re$ondence confirms and Minforces VEGp's conclusion Intarnal NRC corres stivetorequiredActionissubjecttointerpretationbased on its context.
In May 1977, Mr. J. H. Snletek (then Assistant Director for i
Field Coordination) addressed the term "issnedtate" relative to the Mguired i
Action of 'imediate' testing of redundant systems upon the failure of one. His May 20th memorandue to Mr. G. Flore111 concludes that a proposed duration of 4 mC1 for "imediate* Action may be too long in some cases (e.e., stobability not likelp that the of redundant systes failure) and too short in others (e.s.,itation 'aight create second system will fail by the same mode and the 4-hour lim i
i arushedsituation'). There Mr. Snierek concluded that the NRC would have to j
' rely on the technical judgement of the NRC inspection staff on a case-by-case basis' to determine the appropriate duration of 'issediate' Action, to this Inclosure.p Later NRC internal correspondence se l-demonstrates that the time 4vai able for the required Action is far free clear.
(See Attachment 4 to this Inclosure; e.
26,1990, esmorandum to Mr. Sus C. Lainas free Mr. Luis A. Reyes requeskin. Mayg technical assistance for l
interpretation of the TS.)
l V[tP is entirely comfortable that the technical judgement applied in 1984 by its licensed operators, in concluding that an administratively controlled chemical j
addition with a duration of 5 minutes as an acceptable time interval, was reasonable and did not violate 15 3.4.1.4.2.
For the NRC to now impose a i
definition of 'imediate' as having no duration in an enforcement action runs i
afoul of the spirit and intent of the Enforcement Policy as well as 10 CFR 50.109. While genuine differences of opinion may exist as to whether the actions taken in 1988 are optimum rectice, those actions did not violate the T5 nor are they appropriately the sub ect of enforcement sanctions. Further, VEGP 2
i is confortable that the chemical 4 dition evolution was not adverse te safety as demonstrated by our contemporaneous operational analysis our subsequent review, and the MRt's approval of the amendment to TS 3.4.1.4.2 In February 1990. The 4
i safety significance of an event should not be a function of the ngulatory scrutiny which that event receives.,
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ENCI,0$UREI(CONTINUED)
V0GTLE ELECTRIC GENERATING pt, ANT - UNIT 1 AEptY TO A NOTICE OF VIOLATION j
mac orrtef 0F INVf1Tf3ATIONS Afpott No.1.e1001. fA 91 141 l
t furthermore as late as Nard 1991, licensed personnel at another utilit NRC Region II used the same lopic as did the VEGp operations staff when / within 4 hey i
chose to voluntarily enter an.C0 which required immediate action. While this i
utility later chose to report this event as a condition prohibited by the 78 l
(Exhibit 31 of Appendix I to our August 28, 1991, response to the June 3,1991, t
Demand For Information by the NRC)f the 78 such less pro it is noteworthy that the NRC chose not to cite the utility for a violation o i
VE4p maintains that this is an example of Inconsistent application of the j
regulatory process.
Finally in 1991, the NRC has now made clear to VEGP that their interpretation of i
this issue would preclude voluntary entry into an LCO which requires isnediate action.
Therefore, while VEGP does not necessarily agree that this j
interpretation was clear or consistently applied unti 1991, we have adopted it j
as our practice.
4 Reasans for the twent 4
i While VEGp denies that any violation occurred in October 1988, we offer the j
following reasons for this event:
1 1.
The first manipulation of valves 1-1208-U4-176 and 1-1208-04-177 was made without recognition of potential T3 limitations due erincipally to the fact i
that the responsible Operations personnel did not fully understand the i
' loops not fillod' condition, and therefore did not appreciate that the TS i
applied at the time.
It should be noted that no dilutten occurred because i
no water was added to the reactor coolant systes (RCS at this time only chemicals and water were added to the chemical ad)dition tank j
l t.
The later instances when these valves were opened were preceded by due consideration of T$ applicability and the Final Safety Analysis Report there)w,as no safety significance.as well as an operational analysis wh (F5AR l
4 Violation B.
The decision to volun(See Footnote 1 to our response to Operationof)TI taril edition) y enter the Lietting Condition for 3.4.1.4.2 (1988 was believed to be consistent with i
established practice, NRC guidance, and safety..
' As stated above, guidance issued by the NRC prior to this event stated that
'the NRC endorses Voluntary Entry into the Action Statement Conditions and i
has structured the Technical Specification to permit the licenses to exercise judgement within the latitude permitted by the Action Statement i
language in the Technical Specifications.' As a result of this saidance and the associated established industry erectice of voluntary entry Into LCOs within the latitude contemplated by Action Statements in the exercise of I
reasoned judgement, the interpretive efforts of the involved personnel
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I ENCLOSURE 1(CONTINUED)
V0GTLE ELICTRI'C'GENEAATING PLANT - UNIT 1 REPLY TO A NOTICE OF VIOLATION HRC 0FFlef 0F INVf1TIGAT10NS REPORT No. f-el-801. EA el-141 focused on the duration associated with the ters 'immediate.' Ned clear NRC utdance existed prohibiting specif'ic categories of LC0 voluntary entries or efining the ters 'isenediate' (thereby ellainating ay need for centsat-related interpretation), this event would most probably not have occurred.
3.
The F5AR, with regard to boren dilution scenarios (chapter Ill, was ambiluous.concerning the chemical addition evolution due to hLstoric changu to t se document and ultimately led the responsible personnel to conclude FSAR. pening valves -176 and -177 was a condition ttot was analyzed in the that o
- 4. The outage planning process, with respect to review of planned evolutions, was weak in that it failed to identi the potential TS interpretation issue related to opening valves -176 and -) 7 during Mode 5 with the loops not filled.
5.
The T5 written interpretation process (at the time) was too narrow in that it did not provide for an interdepartmental review. Ve believe a broader review say have identified the fact that this condition was not analyzed in the FSAR.
Correttive Steen Taken and Results Achieved
- 1. At the time of tne October 1988 chemical addition evolutten, operator guidance concerning RCS water levels during drain-down and mid-loop activities was weak. Since that time the plant Technical Data look has been revised to add further details co,ncerning the information provided by the mid-loop level instrumentation and to add pictorials which provide a clear picture of the relationship between RCS water level and tie various components of the RCS.
In addition, on February it,1989, a T3 interpretation was issued and later revised on March 30, 1990) which addressed the leons not filled con (dition for the pg.:. of compliance with TS 3.4.1.4.t.
The Shift Briefing Book and the Operations Readt Book were revised in earl 1989 to address the required positions for th RMW5T discharge valves du in Mode 5 with the loops not filled and duri Mode 6.
Furthermore opera or training has been revised to include informa ton specific to the lo, ops not filled condition and the use of the RMWST discharge valves.
Finally, a number of VtGP procedures have been revised to add a precaution and limitation concerning the T$ requirements for the RMWST discharge
.~.
g}-g
INCLOSURE I (CONTINUtO)
V0GTLEELECTRICGENERATINGPLANT-UNIT 1 RiptY 70 A N0f!CE OF VIOLATION NRc NFict Of INVt1Tffdff0NS REPORT No. f.e1001. EA el-141 valves. (See our letter dated August 28 1991, in response to the June 3, 1991, Demand for Inferination by the-NRC., Specifically, pages 37 and 38 and Appendia 11, Attachment i discuss traintne and additional guidance provided to operations personnel as a result of this event.)
VitP recognizes the additional guidance provided,78 LCOs which requireas a result of 2.
by the NRC in 1991 regarding voluntary entry inte isoediate action. Speelfically, VEGP now understands that the NRC's position is that such action constitutes a T5 violation. This position has been adopted as ytGP policy with respect to T3 compliance. On August 15, 1991, the VISP General Manager issued a memorandue advising operators that LCOs which do not have spec fic allowed outage tiass should not be voluntarily entered except an expressly prov'ded in associated Surveillance Requirements.
3.
Section 15.4.6 of the F5AR was revised in March 1991 to clarify the use of the RMWST discharge valves in Mode I with the loops not filled and in Mode 6.
4.
When the scope of an outage is known and the needed work activities have beenidentified,OutagePlanninfor planning the day-o-day act vptes of the outage.
l experience and expertise of the VESP (0&P) eroup has been strengthened, and the depth of review during the outage planning process for potential operational limitations has been increased.
outage schedule to affected departments for&P personnel send a prelisinary lefore a planned refueling outage begins 0 inset and review. Licensed senior reactor operators now review the schedule at a detailed level to ensure compliance with the T1. This is an iterative process with the end result bei a detailed outage schedule whose activities have been intensely examined.
See the August it,1991, letter la response to the June 3,1991, NRC Desand or Information, specifically pages 36 and 37.) Also, as a result of the event of March 20, 1990 VESP sede improvements in its outage and the NRC noted those improvements in its December 10,1990, sanagement, Assessment of Licensee Performance (SALP) Report on VEGP.
Systematic l.
The need for a broader review of T5 clarifications was identified as a weakness in Inspection Reports 50-424 428/90-19 which concerned the inspection conducted by an NRC Spec 14I Inspection Teas during August 1990.
l In response, VEGP has broadened the review of written T5 clarifications by charging the Manager of Technical Support with responsibility for obtaining the appropriate departmental reviews, including licensing personnel, as we I as consviting with the NRC staff as appropriate. (See our letter dated February 8, 991,ILV-02446.)
(1-7 l
(WCLO5URE 1 (CONTINUED)
V0GTLE ELfCTRIC GENERATING PLMT - UNIT 1 REPLY TO A NOTICE OF VIOLATION kat 0FFICE OF INVf1TICAT10N1 MMWLT No. f.el-001. Il el-141 6.
The requirements 'of TS 3.4.1.4.2 were seended in February 1990 by the NRC in response to our application dated #4vember it.1949, to ellow the use of RMW5T discharge valves -176 and -177 under administrative control pre -Ided certain specific conditions are not.
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ENCLO5yRE 1 (CONT!NVEO)
V0GTLE ELECTRIC GENERATING ptANT - UNIT 1 REPLY TO A NOTICf 0F V!0LAT10N Mit 0FFICE OF INyt371aATIONS Afp6RT ho. f.91-001. EA 91 141 RE1PONSt to VlotAT10N R Aaainnien er Benial af the Violatten Yttp dentes this Violation. This is a new issue that was not addressed during the September 19 1991, enforcement conference or in any of the correspondence t
preceding the enforcement conference.
Vitp saintains that openin discharpe valves specified in TS 3.4.1.4.2 on October 12 and 13, g the RMWST1988, di place.t.w plant in a condition outside the design basis. Thus, no violation of the reperting requirement of 10 CFR50.73 (a)(t)(11)(8) occurred.
Santa far Dental Section 50.2 of Title 10 of the Code of Federal Regulattens defines desten basis as 'informatto.s which identifies the specific functions to be pe-femed 6y a structure systes, or component of a facility, and the specific values or ran of values, chosen for controlling parameters as reference boundt for design.' ges The physical design of the chemical addition portion of the chemical and volume control system is such that the cheatcal addition evolution of October 1988 did not exceed the acceptance criteria specified in the Staadard Review Plan ($Rp).
$ection 15.4.6 of the 3Rp specifies that if operater action.fs required to terstante the transient, the following minimus time intervals must be available between the time when an alars announces an unplanned moderator dilution and the time of loss of shutdown margin:
- s. During refueling: 30 minutes.
- b. During startup, cold shutdown, het standby, and power operation:
15 minutes.
In eetting this design basis, the physical design of the flowpath in question is such that the above 3Rp criteria are met with considerable margin.
This was demonstrated by the analysis performed in November 1989 (AC Dem Exhib' t il of Appendix
! to our August 28. 1991, response to the June 3,1991, N Infomation) in support of the 15 amendment approved by the NRC in February 1999.
The TS lases for 13 3.4.1.4.2 state that the subject valves are closed to prevent an unenntrollod baron dilution event. The purpose of the TS is to enivre the design bas's is maintained.
The administratively controlled manner in which the chemical addition evolution was performed in October 1988 precluded an uncontrolled dilution event.
This was demonstrated by a calculation perfonnd by Westinghouse in August 1991 (Exhibit 23 of Appendix ! to the August 28, 1991, letter).
11-9 i
I
o ENCLQ$URE1(CONTINUED) i-V0GTLE ELECTRIC GENERATING PLANf - UNIT 1 j
REPLY 10 A NOTICf 0F VIOLATION une cFFIcF OF INVf1TfcAT10N1 Rfp0A7 NO.1-el-061. EA el-141 1
VElp recognizes as the PRI did in 1989 that use of the f1 was not' currently analysed in the FSAR.; H ath in question i
the design basis of the plaat and therefore was not reportable.
1 how the operating personnel involved in 1988 faile I
i valves created a condition that was not analyzed in the FSAR. y that opening t i
analysis existed which In July 1985 met the rsisvant 5AP cr,iteria concerning uncontrolled i
{ 8 to the August it,1991, letter).
t,
'}
revised, and the portion related to the ches" cal addition flowiath athtained current. Therefore, technically as concluded by tis PRS s
condition existed in 1988 which was not analyzed in the FSAR when i
4 addition valves were opened.
i In November 1989, the analysis for the chemical addition flowpath w re erfomed and it was again demonstrates that the 5Rp criteria we si nificant margi-si inum acceptance c(riteria of 15 minutes by appro i.e., the time available for operator action exceeded the i
4 specific event in October 1984, the time available for operator actten'w i.
t deters!ned to be 538 minutes in one case and greater than 1000 min another.
See Exhibit is of Appendix ! to the August 28 19hl 1990, the(NRC a1:e concluded that actions such i
letter.) In l
1988 cheatcal addition evolution are not safety significant and basis reevirements. Specifically, the language of the N*C safetg reart JSER for the T5 amendment allowing use of the s
' tie $Ri acc)eptance criteria have been met or exc l'
k 4 va vos states that i
changes would not have any adverse affect on safety.' (,See tahib i
t Appendix ! to the August 18, 1991, letter.)
i la October 1988 reviewed the impact of the controlled chemical add evolutten on core reactlytty prior to the evolution and demonstr effects were negligible.3 not analyaed in the F5AR from the standpoint of a hypoth i
I dilution event, the specific event in question was reviewed for core reactivity and foutd to be of no sefsty significance prior to the i
svolution. tience, the avet did not constitute an unanalyzed cond i
analysis, r,esponsible Operations personnel dir3 Rot prior to the specific evolution of October ifh.ierfore an operaticnal analysis RC$ concentration of 780 pas and the RMW5T discharge (specifiedintheFSAR dilution (less than 1 p)p,a)lution was n t taere would be an insignificant amount of boron i
known that the planned evo for the planned chea' cal addition. Therefore, it was j
, o adverse to safety.
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j o n.. -a m l
ENCLOS,URE 1 (CONTINUE 0)
V0GTLE ELECTRIC' GENERATING ptANT - UNIT 1 I
REPLY TO A NOTICE Of VIOLATION NRC 0FFICE OF WYfSTf TAT 10N1 Rfp0RT NO. 2-91-001 FA el-lol significantly comproatsed plant safety or a condition outside t of the plant.
Furthermore, the Motice of Violation states that the event of outside the design basis of the plant because in October 1988 uncontrolled dilution event via this flowpath did not exist.
Novover, 10 CFR 50.73any unanalyzed condition is necessarily o design basis of the pla(nt(an)d unanalyzed condition a) 2 (11) treets conditions outside the compromise plant safety as two separate and diattact criterla If any unanalyzed condition necessarily places the plant ou basis, then there is no need for two different criteria.
to existing NRC guidance, specifically NUREG lett, ' License j
System.' The NURIG in its guidance concerning paragraph 50 focuses on the offs,t.:
of a given condition on the principal safety1 ti),
(e.g., the fuel cla containment) and thw safety significance of the condition. lin rs j
i has deeonstrated a wide margin to criticality for The NAC has evolution.
Therefore, the principal safety barriers were never challeng tnd as was concluded by the PR8 in 1989, this event was not repo alleged in the violation.
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El-11
ENCLOSURE 1 (CONTINUED)
V0GTLE ELECTAIC GENCAATING PLANT - UNIT 1 RtpLY TO A NOTICE OF VIOLATW NRC 0FFICE OF INVISTICATION1 REPORT No. f-el-Di. EA #1-141 1[120Nif TO VIOLATION C Admiulan er Dantal af the Violatian VEsp denies the violation. We maintain that a violation of 78 3.4.1.4.! did not occur in October 1948 as stated in our response to'Violatten Al Furthemore we do not agree that a(procedural violation oc~ curred through taplement a procedure required by Regulatory Suide 1.33 as stated in Violation C.
Vitp also otserves that the NRC has mis-cited the applicable section of Procedure 10000-C from the revision in use in October 1988 and has also misnamed the relevant operation staff position. The appropriate procedure revision for October 1988 was included as Exhibit 32 to our August is 1991 response. The appropriate position title was On-Shift Operations Supe,rvisor,,
and the appitcable procedure 5ection was 2.4.
Rash far Denial Ites 1 of the violation deals with the fact that valves 1-1808-U4-176 -177, and els: were opened in Mode 5 with the loops not filled.
Procedure !!00I-C places ade' 'strative control on these valves by requiring them to be locked closed and tag conkrv. ;mter to draining the llc 5 below a specified level. The purpose of this 1 is to prevent an uncontrolled boron dilution. Comp 11ance with It006-C occurred on October 11 accordance with It006-d.1p88, when the valves were locked clued and tagged in This violation deals with the opening of the valves following completten of the applicable section of 12006-C. The octual openine of the valves occurred under close administrative control and ta accordance wIth plant proceduras. (See our response to Violation D.) Unit Operating Procedure i
12006-C subseque,nt plant operations; rather, it was intended to be used as a i
i administrative control to prevent uncontrolled dilution. In this function it was successful. Therefore, VfGp believes that ne violatis of T3 6.7.1 j
occurred.
Ites t of the violation states that because a vietation of the T3 occurred and i
precedure 20000-c, ' Conduct of Operations
- section f.4, required that the On Shift Operations supervisor lG503) (pre,sent title is Shift Superintendent) be responsible for ensuring that p ant operations are conducted in accordance with the T5 and approved procedures, that a violation of procedure 10000-C occurred.
YEGp, however, disagrees that a violation of Procedure 20000-C did or could occur in the manner suggested by the N0Y. Procedure 10000-C is an i
organisational procedure establishing broad areas of responsibility for Operations personnel, by position, s'milar to an organization chart. These i
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(1-33 i.
i
ENCLO5URE 1 (CONT]NU(0) i*
V0GTLE ELECTRIC GENERATING PLANT - UNIT 1 i
REPLY TO A NOTICE OF VIOLATION 1
NRC 0FFICE OF INVESTitAff 0MS Rfp0Af No. f.91-001. IA 91-141 a
responsibilities include the responsibi.lities of the 0$0S to ensure 18 i
compliance. However, Procedure 10000-C is not violated by every T8 violation, j
A> art from the fact that VtGP does not agree that a TS violation occurred in
, a is violation does not osan the seabers of the inis case (as discussed above)d to meet their responsibility. Any other organtaation necessarily faile i
conclusion would mean that every T5 violation is a violation of Procedure i
10000-C, and 'thus, also a violation of TS 6.7.1.
t Also, once a TS issue is identified it is clear 1 the responsibility of Operations personnel to ensure coepitance. A viofetion of Procedure 10000-C l
l would occur only if in these circumstances the rattens personnel had abdicated their responsibility to ensure TS c tance or willfully ignored the l
T3. This is AA1 what occurred in this case.
ction 3.11 of Procedure 10000-C provided instructions for making T5 interpretations when needed (Exhibit 32 of 28,1991,d.the po)tential confilet, the applicable letter. When the day shift 0$0S on both 1
Appendix ! to our August discovere l
October 12 and 13, 1988, l
instructions of section 3.11 ware followed. He stopped the evolution and consulted with other $nos, including the operations hnager. He then proceeded with the evolution after concluding that the evolution could be conducted in accordance with 15 requirements. As discussed it eur response to Violation A, his actions'were made in good faith, were consistent with available NRC guidance, and fulfilled h s responsibilities as set forth in Procedure 10000-C.
i Therefore, VEGP believes that in this case also, no violation of 75 6.7.1 occurred.
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)
1 INCLOSURt 1 (CONTINUt0) i*
V0GTLE ELECTRIC CENtRATING PLANT - UNIT 1
)
REPLY TO A NOTICE OF VIOLATION
]
NRC OFFICf 0F INVESTIGATION! Af>0R7 No f.el-001. EA 91-141 Attp0Ntf 10 VIOLATION D
~
AAmientan er Benial af the Violattan VitP dentes that the procedures controlling the chemical addition evolution were j
inadequate.
Rasin for benfal 1
j Part 50, Appendix 5, Criterton V, of Title 10 to the Code of Federal Regulattens reqvfres, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type a>propriate to the circumstances and shall be accomplished in accordance with t wse instructions, 4
j procedures,tances had been established for the chemical addition evolutio or drawings.
the circums October 1988. These procedures were followed. Thus, ne violation of Criterion i
V occurred.
The NOV references only one factor, a limited aspect of Procedure 13007-1,as i
the basis for the violation. The NOV states that the procedures call for a reactor coolant p to be running to assure thorough alming, but this is not possible in Mode ith the loops not filled.
l Thr. reinant portion of procedure 13001-1, apparently alluded to by the NOV, is j
as fallows:
i j
4.7 REACTOR COOLANT $YSTEM CNDl! CAL AD0! TION NOTE To enwe thorough sizing, t Pump at lenic one Reactor Coe an i
i should be in operation while chemicals are beleg added to the system.
4.7.1
!$0 LATE the cheefcal mixing tank by verifying the following valves are CLD$tD:
i (For additional information on the tart of this procedure
)
see Exhibit 12 of Appendix ! to our August 28,191 j
response to the Ju.'e 3,1991, NRC Demand for Inform,ation.)
i 4
However, it appears that the NRC is erroneous in limiting their view to only i
this portion of the procedure. Then was a hierarchy of procedures app.11 cable
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l (1-14 i
E
(NCLOSURE1(CONTINUt0)
V0GTLt (LECTAIC GtNERATING PUWT - UNIT 1 RtptY TO A NOTICE Of VIOLATION Met OFF1f t 0F INVElff tATIONS REMiii No. F.el-001. EA el-141 to the evolution in October 1948.
the addition of chemicals in Mode 8 and ensured proper sizing.In to Procedures 13007-1 and 35110-C addressed the specific task of adding chemicals to the RC5.
configuration and unit status required for performing chem The procedure that accomplished this was 49006-C Department Cutage Activities Implementing Pro,cedure. Health Physics And Che The purpose of 49006-C is to identify the Chemistry outage activities for activities for reducing radioectivity leve,ls in plant syst exposure to personnel durin complete these activities, g an outace, to describe the support necessary to support for accomplishing these activities.and to define the responsibilities fo (See Exhibit 49 of Appendix ! to our August 28,1991 response to the June 3 3ection 4.4.4 of Pro,cedure 49006-C specifica.lly addresses the condin199 ws for chemical addition to the RC5 and chemicals in Mode I with the loop,s not filled.in October 1988, was written for add Section 6.4.4.c stated:
c.Cooldown/Draindown NOTE i
Draining of the RCS shall be through the purification (CVC8)
Mixed led desineraliser at approximately 78 gallons per sinute. Flow depends en systes i
pressure.
1.
The to 1$0 #F, and drained down to aldloop vla thelant i
l purificatten (CVCS) mixed bed desineralizers prior to Hg0g addition.
As can be seen, this procedure clearly established t j
the use of the AHR systes.
development of Procedure 49006-C for failure to identify a potent edged a weakness in the i
conflict, the procedure was adequate for the chemical addition evolution.
meet Appendix 8 Criterion V.was adequate to ensure proper sizing in Mode It i
(1-15 i.
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(NCLOSURE 1 (CONTINUED)
V0GTLE ELECTA!C GENERATING PLANT UNIT 1 REPLY To A NOTICE OF VIOLATION 4
MAC 0FFftf 0F INVFSTICATIONs ifVuiti i
Guidance given to plant personnel in 1988 concern i
. IA 11-141 orocedures was provided in p1snt Administrati Development.'
e use of nets, in 1
This guidance ues and continues to be as follo j
rocedure
' Notes are used, if needed, to supply addition 3
help the user to undantand a step or process 'al informa been tatended to be used as procedural I
i i
n the NOV have never in Node I w,ith the loops not filled in O i
with the intent of a
tion of chemicals i
loops no. Moreover,the note in Procedure 49008-C i
n o lowed accordingly 13007-1 therefore believes that adequete pre:Procedu being satisfied by Procedure, t filled did not invalidate 13007-1.
the chemical addit edures had been established for th i
did not occur. ion evolution in Octobe k
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7, smw wnw.
XTTA04ME.AJT1
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878 Sectfen 8.9
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Vol$ntary intry inte Aetten Statements Issa este Wat l
j Intersretatleet Veluntary Entry inte Action Statement Condittene of the Techn(sel Specifisettens j
(78).
l tems:
Te erovide the 28 positten seneerning Voluntary 8stry tale T8 Aetten Statement tenditions.
~
l Eunt.in8 10 Cft H.HFe)(3)iseellity or performance level of equipment that tede l
lowestfunedensis i
required for the safe operatten of the-festlity. Peregraph H.M(c)(t) j else states that the licensee shall shutdoe the reacter er fellow ey i
i remedist setten permitted by the 78 whenever a lletting senditlen for operstien sonnet be met.
e l
The litt endorses Velutary intry into the Action Statsoent tenditions ee; has structured the 78 to rett the 11eensee to emersise judgment witMs i
% *('
the latitude persitted the Aetten Statement 1 in t w 78, it.
i fl else restricts fact 11 speration in the speeff dsetts' l'
operation to the Ifvited period of time designated to relates 71 4Wittoa. Itee 4.0.4 of the ff8 prehttits entry inte en operette :1e unless the tendittens for the lletting sendition for operation e o e -
witneut re114nce en previstens contained in the cetten feesteere t 1atter ites provides assurance that all opereb(11ty requines.ss s-settsfied peler to the mest recent startap.
Agfg333:
flamorshdus 8. L Grimes to 8. Niryons dated June 13.19?f.
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EMC.LO$URL i s,.e*/
f ATTAC.HM ENT;2.
August it.' 19m l~
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i NDtmMNM FOAA el. L Snisset < Assistant Mrector, Division of teacter i
Operations Inspectise
. F15:
Enri & Ge11er6 Assistant:Mrector far operating.
nonasere -
$UBJECg TECRWICAll 3PRCIFICAT10ll ACTICE STATDENT8 1
Yevr.mensNF'1Ey"W,"1377 regnes.ted gutdenes rege. ding.the esseptability of licenstes placine cesponentaior systeme<1e av. isoperatie status as 1
i allend 4t techniest spect(icattenisatica statettats f6r three sess.
. mea.ef slant enemitamme m1 ant.nedificationst and Dreymtive:ssin ce J
Iinclusing s&iisillance). As you se,i uy nww. sens asumws perfereed.withih the centext af these categerlles any set he sch ant 4
{
to a.2 day ftporting requirement pur$vant,to Regulatery Guide e' 4.
t l
Act en stataments were developed to attensedate those. instances ehen
' eq puent. cesponents er other specirse'aenditiene of the spesifisetter.s:
ces d not 6e set because of whatever ceases. He recognised then well as now that.th, estantial ea< sted fe_r liesseees es tamindv..es.antage,
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ef these amistent a afser se non
, uumies wilMt ' he:u ree -
~
ca ries.
sch As AMt suur..we ceasiseres us "ellousag.
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restr et such activttibet l
- s. Limiting the lengthief time that speciftet esepenents or tys ans.
gremain inoperable before further action would:be requi i
.b. Limiting the ausber.ef times and/or the tota.1 esaulative length of tim during.a specified period.of tias.t:st specified sempements.
j er systems any he inoperable..
11enver6 in view of the.conplus and extensive record keepire probigui.
i pad ths.1sek of an adequate data basa:fres which.to infer eccep' table limiting estate.per4edse we did not seasider the;tenefits to ts ined i
.instifi&ble when hatanced against thetincreased effort required Ifuastes and 1&t inspection personnel. ' Additionally, we nel that we would 64 able to remain cognisant of setsible abuse of outage :
tinas threvsh review of LER's'. supplemented where necessa.. tr notification estion of the !&E iinspectori assigaul to each acility,:
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.gu..u c - w c-i XO l M o i J 0 WG 3pp.
1 p p. o N r. 4. J.
Augv:t 10,.1Dn
- ATTAMMM L. t.
J.11. Safersk l.
Dased upon eve er.peHense te date.twe see ne reason ta modify our position on action statements or e.11mble outsee times.: We de, i
however. recognise the need for additional tvidence regarding inter?retation of that por. tion of sne Technical 4pesifications relatin, to substission of 30 ' day reports for operation in desended sodes. We have prepared the enclosed interpretatten to clarify -
l the intent of itens to be coperted.
t If we have further evestions on thid subject, you any clontact J tartar of sy staff.
i 9
l-AU.R 42!.
4 Mr1 A Seller. Assistant Director fort 6 i
etviss..perating Rateters.
.f worstu,, neen.r.
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Enclosure:
interpretation esw/enelesures' i
V. Ste11e i
D. Eisenhut.
1
& Thornburg-L Seyfrit STs aroup Moders i l
OR Branch. Chiefs I
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,l 1MTERPRETAT16N OF TECMMICAL IPfCIFICAT'!ONS, ' I
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technical Specification Abinistrative Centrols retvire consistent.
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with Regulatory Svide 1.16. Rev. 4. a thirty day written report for '
' Conditions leading to operation in a degraded mode perwitted by a
{
liniting condition for operation, or plant shutdown requind by a W.
limiting conditten for operation.' Following is svidence on when such reports are n quired.
e
- In. s The purpose of this thirty ay written report is to provide data en i
equiseent failure, includi inoperability. Therefore, a report is,
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- 1. When the failure is detected while performins a tesi, rs'evired
- k"; ~.
i by the Technical Specifications to demonstrale operability of the envipment.. This is true even if the failure is detected in a rede for which the Technical Specifications do not require operability of the equipment, l
- t. When the fattore is detected while the fosility is operatinn in.
i a mode for which the Technical Specifications le not specif' sally state that operability of the ft(1ed equipment is ggg,requind for that sede (so that operability.in that mode is resputred, i
either directly or by implication).
I day written report need not be svtsitted when eeripment ir d
l A thirtyfrom service, for reasons other than failure, to enter alternate removed i
or degraded pedes of operation consistent with the provisions of a
(
technical specification.
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_e ENClosup,( 1 ATTACMMLMT:.S nay 30,1871
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3 Mp0MNDUM POR: 6. Finnlit. Chief Roseter rationsand RusburSupportIronsh,AI FROM:
- 4. L Sntesek. Assis tOfrectorforField Coordination. R03/
'sUNICT:
OPEAA8!LITY $!MONITRATION Of At00NIMT 8YSTEMI (F i
l i
We have discussed with 00R the issue reised (a pour neuertadva ef*
i April 27.1877 The NRC ph hy of testing niondant n aMape. The curresh fee'ystems when one system falls is un 14l 18 that i
to take ttu redundant sys vt of service ftr test < as. If ' As first.
i system fat's crests: the risk of the second system a1H failing. It has Men obse'eved that failures of the second systes as eften stated i
j to the test itself and is not en indication that the system muld have j
fatled shev14 f t have been needed.
1 A11 current STS mflest this thinkis and some 15 shanges arp essvering j
to taprem older 78. 8ese elder facilities Jos ify n,el anodistely newever aro N vetaat to
.I suest thes improvenant besavec la order 14 1
i b
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testing the redundant s an intmund interval. ystes,ill not assept athat system sust Iroutinelptestasat i
00R w
' et' en of 'spediate nevndant testing withest 1sproved Mutine surveillsnw fretancies.
Ts sincifically answer Mur Mtvest that 'iN8diate' be intefonted 4:
v%hia fove hoves.ight be tee ten while init was fait that this testi be gnerally a splied, i
In some easts it s easta the fter+ ser i
period stimt steate a reched si t'
ut la an tecreased stoab(11 y of hunsa f619ure ress 'en that see i i
6 a se the bestup s; sten.
New soon the test shnid be tendus 11 n the cause t' the afstas failure. As a tvidelineIgnet fa {tre uns gener a such that i
the ndundant a1th% nel ft the taas Messn than the i
sast snev1 te lates as seen as poss46 e
is met like the setend systes wilt IlbyOn the other hand, he if it seat neds t there is le urgency to conduct the test. Thus P the ensen,t the ate wi11 rely on the tashnical Judynnt of the NIC alpestion staff en a sese4y.sase basis.
N itsek O
rField inaties etw/te.comins:
+1. H. Movsh. NRR..4. L. Madsn.RV
' RIV 8.J.BrunnerI!
RI
- d. L. Crews.
F. 4. Long, A L Te 8eyfrit. It
- (*
<==Ts ggsia i.
( b bE dP*
.