ML20129J043
Text
., ~.-..,-.. -.
. ~..
. - ~
1' X LIMITED DISTRIBUTION - Not For Public Release
_DRAF P PREDECISIONAL INFORMA N,_
j w
v y
. ENCLOSURE 1 NOTICE OF VIOLATION
~ Georgia' Power. Company Docket Nos. 50-424 and 50-425
.Vogtle! Electric' Generating.-Plant License Nos. NPF-68 and NPF-81 Units 1.and.2 4
?.
l
.During an.NRC-inspection conducted-on August 6 through 17, 1990, violations of NRC. requirements.were identified.
In accordance with 4
Lthe'" General. Statement of Policy and Procedure for NRC Enforcement
- Actions," - 10 CFR Part 2, ' Appendix C (1990), the violations are listed below.
2:
A.
- 10 CFR Part 50.9, " Completeness and Accuracy of Information,"
requires that information provided to the NRC by a licensee 2
shall'be complete and accurate in all material respects.
]
Contrary to the above, the ' licensee provided inaccurate information to the inspection team.on three separate occasions.
Although the information was provided in unsworn, oral statements, the information provided was significant to the : licensing. process.
The information was provided by licensed operators, supervisors and management concerning information which was within their specific responsibilities.
The five examples' were as follows.
(50-424/90-xx-05; 50-425/90-xx-05)
~
1.
Containment Isolation Valves:
During a
Unit 2
surveillance procedure, the unit shift supervisor (USS)
L stated, and the operations manager later confirmed, that the' containment isolation valves for the hydrogen monitor system were allowed to be opened without entering the i-limiting condition for operation (LCO) action requirements for Technical Specification (TS) 3.6.3 L
because the valves received an automatic isolation
. signal. The inspection identified that these containment isolation valves were remotely-operated, manual valves
- without'. automatic isolation signals.
(Discussed in Section 2.2.1.1 of Inspection Report 50-424/90-19;50-
-425/90-19) 2.
Snubber Reduction:
The operations manager stated that,
-after the second Unit ~ 1 : refueling 1 outage (1R2), the p
modifications to-the snubbers were done in conjunction t
t 1
9611040236 960827 m
. POR-FO! A.
KOHN95_211 PDR
t f
y LIMITED DISTRIBUTION - Not For Euhrbigelease v. DRAFT - PREDECISIONAL INFORMATION N
j%-
with preplbnn~ d system outages which were required for e
other preventive or corrective maintenance or testing.
The inspection identified that few of the snubber modifications were done jointly with pre-planned system outages.
(Discussed in Section 2.1.1.4 of Inspection Report 50-424/90-19; 50-425/90-19) 3.
Emergency Diesel Generator (EDG)
Reliability:
VEGP incorrectly counted the number of starts and failures of the EDGs and incorrectly represented the EDG reliability in a Region II presentation on April 9, 1990.
Although the presentation was not intended to represent a specific number of successful valid tests as specified in Regulatory Guide (RG) 1.108 and TS 4.8.1.1.2a, but rather to describe the EDG maintenance test program and the EDG
/
reliability status, the NRC was not informed of the incorrect information until the NRC asked for it during the inspection.
The confirmation of action (CAL) response and Licensee Event Report (LER)90-006 were also incorrect because they were based on the EDG start information that was compiled for the VEGP presentation in the Region II Office.
(Discussed in Section 2.7 of this inspection report)
This is a Severity Level IV violation (Supplement VII).
B.
Technical Specification 6.7.1.a requires that written procedures be established or implemented for those activities delineated in Appendix A of Regulatory Guide 1.33, Revision 2,
February 1978.
Contrary to the above, two examples were identified in which the licensee failed to establish or implement the procedures for these required activities as follows:
(50-424/90-xx-02; 50-425/90-xx-02) 1.
Administrative Procedure 00150-C, " Deficiency Control,"
states that a deficiency card must be written if the deficiency involves safety-related components which are to be dispositioned "use-as-is/ repair,"
or other conditions' involving safety-related components which require engineering support or other technical assistance to determine if the component is deficient.
On August 17, 1990, the NRC identified that a deficiency card was not written on residual heat removal (RHR) pump
- 1B (a safety-related component) to document the pump's JMI Release 1
i 1
~ LIMITED DISi" BUTION,Not For Public Release DRAFTS-PREDECI.SIOffAL INFORMATION
/
degraded conditions which were dispositioned "use-as-is".
(Discussed in Section 2.2 of this inspection j
report) i 2.
Administrative Procedure 00100-C,
" Quality Assurance Records Administration," Paragraph 4.1.1.8, specifies j
that quality assurance (QA) records will exhibit necessary and appropriate signatures or initials and dates.
On August 17, 1990, the NRC identified that the Unit Superintendent incorrectly initialad, dated, and signed a QA record which voided Temper 7 Change Procedure (TCP) 1802-C-7-90-1 to Abnormal
. ting Procedure 18028-C,
" Loss of Instrument Air," t i ? he date of June 12, 1990,
'in lieu of the actual date 4ne 35, 1990) on which the document was signed.
(Discussed in Section 2.5 of this inspection report)
This is a Severity Level IV violation (Supplement I).
C.
Criterion XVI,
" Corrective 4
Action," requires measures to be established to ensure that conditions adverse to quality are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures are required to ensure that the cause of the condition is determined and corrective action is taken to preclude repetition.
Contrary to the above, two examples were identified in which the licensee failed to determine and implement adequate corrective actions to preclude repetition as follows:
(50-424/90-xx-03; 50-425/90-xx-03) 1.
On August 17, 1990, the NRC determined that the licensee did not identify the format and normal use of the LCO status sheet as one of the causes of the event described in Licensee Event Report (LER)90-004, " Failure To Comply With Technical Specification 3.0.4 Occurs on Entry Into Mode 6"; therefore, corrective action was not taken to
-preclude repetition of the failure to review LCO-required actions or remarks which may be on the back side of the LCO status sheet.
(Discussed in Section 2.4 of this inspection report) 2.
Technical Specifications 4.8.1.1.3 and 6.8.2 require that all valid or non-valid EDG failures be reported to the
~
LIMMED'DibTEIBUTh e
LIMITED DISTRIBUTION - Not Eor-Public Release N
'l)RAFTdPREDECISIONAE INFORMATIOff NRC in a special report within 30 days.
In addition, Operations Procedure 55038-C, " Diesel Start Log," Section 7.0, requires that all EDG failures shall be reported to the NRC in a special report.
On August 17,
- 1990, the NRC identified that the corrective actions taken in response to a previous notice of violation were inadequate.
Inspection Report 50-424/87-57 (dated November 5,1987) previously identified a violation of Technical Specification 4.8.1.1.3, in that, all EDG failures were not reported to the NRC in a special report.
During a review of the start records for EDG #1B during the period of March 21 through June 14,
- 1990, the NRC identified that EDG failures had occurred which were not submitted to the NRC in a special 1
report.
In addition, the NRC identified that Operations Procedure 55038-C provided inadequate guidance to j
identify and classify EDG failures.
(Discussed in Section 2.7 of this inspection report)
This is a Severity Level IV violation (Supplement I).
j I
Pursuant to the provisions of 10 CFR 2.201, Georgia Power Company is hereby required to submit a written statement or explanation to i
the U.S.
Nuclear Regulatory Commission, ATTN:
Document Control
- Desk, Washington, DC
- 20555, with a copy to the Regional Administrator, Region II, and, if applicable, a copy to the NRC Resident Inspector within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation:
(1) the reason for the violation, or, if contested, the basis 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 LIMITED DISTRIBUTION % Not For Public Release d
4 \\
L
n LIMITED DISTRIBUTION -diot For Public Release
~~~~
DRAFT - PREDECISIONAL INFORMATION J
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.
FOR THE NUCLEAR REGULATORY COMMISSION Stuart D.
Ebneter Regional Administrator Region II
\\
Dated'_at Atlanta, Georgia this day of 1990 LIMI
})ISTRIBUTION
-