ML20133B494
| ML20133B494 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/30/1996 |
| From: | Mccoy C GEORGIA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LCV-0933-A, LCV-933-A, NUDOCS 9701030225 | |
| Download: ML20133B494 (6) | |
Text
Geor[yc Power Company 40 Invemess Center Parkway Post Office Box 1295 Birmingham. Alabama 35201 Telephone 205 992-7122 GeorgiaPower C.K.McCoy the southern ekctnc system Vice President, Nuclear Vogtle Project December 30, 1996 LCV-0933-A Docket No.
50-424 50-425 U. S. Nuclear Regulatory Commission
]
ATTN: Document Control Desk Washington, D. C. 20555 t
Ladies and Gentlemen:
VOGTLE ELECTRIC GENERATING PLANT REPLY TO A NOTICE OF VIOLATION Pursuant to 10 CFR 2.201, Georgia Power Company submits the enclosed information for Vogtle Electric Generating Plant in response to violations identified in Nuclear Regulatory
)
Commission (NRC) Integrated Inspection Reports 50-424;425/96-11, which concerns the inspection conducted by NRC Resident Inspectors from September 29,1996 through November 9,1996.
Should you have any questions feel free to contact this office.
Sincerel,
C. K. McCoy CKM/CTT/AFS
Enclosure:
Reply to NOV 50-424;425/ 96-11 cc: Georgia Power Comoany Mr. J. B. Beasley, Jr.
Mr. M. Sheibani NORMS U. S. Nuclear Regulatory Commission Mr. S. D. Ebneter, Regional Administrator Mr. L. L. Wheeler, Licensing Project Manager, NRR
- g Cl,l Mr. C. L. Ogle, Senior Resident Inspector, Vogtle 9701030225 961230 PDR ADOCK 05000424 G
ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO A NOTICE OF VIOLATION I
NRC INSPECTION REPORTS 50-424: 425/96-11 VIOLATION A. 50-424: 425/96-11-01 The following is a transcription of violation A as cited in the Notice of Violation (NOV):
"During the NRC inspection conducted on September 29 through November 9,1996, violations of NRC requirements were identified. In accordance with the ' General Statement of Policy and Procedure for NRC Enforcement Actions,' Nuclear Regulations (NUREG-1600), one of the i
violations is listed below:
A.
Technical Specification 6.7.1.a requires that written procedures be established for the activities identified in Appendix A of Regulatory Guide 1.33, Revi.< ion 2, February 1978.
Regulatory Guide 1.33, Revision 2, requires that procedures defining authorities and responsibilities for equipment control (e.g., locking and tagging) be established.
Procedure 10000-C, Conduct of Operations, establishes the responsibilities of Operations Department personnel to issue equipment clearances and ensure proper control of tags in i
accordance with Procedure 00304-C, Equipment Clearance and Tagging.
)
Procedure 00304-C, provides instruction to operate equipment, as necessary, and attach hold tags in accordance with written clearances.
Contrary to the above, operation personnel failed to establish Procedure 00304-C in that plant equipment clearances were not properly installed and maintained in accordance with designated hold tag positions. Specifically, on October 5,1996, the Unit 2 handswitch for valve 2-HV-8220, Reactor Coolant System Hot Leg Post Accident Sample Isolation, was not maintained in the open position as designated on clearance 29600288, Gross Failed Fuel Detector. In addition, on October 8,1996, handswitch 2-HS-7791, Reactor Cavity Sump Pump, was not installed properly in that the handswitch was identified in a different position (than] designated on clearance 29616044, Reactor Cavity Sump Pump 018.
This is a Severity Level IV violation (Supplement I)."
RESPONSE TO VIOLATION A (50-424: 425/96-11-01)
Admission or Denial of the Violation:
This violation occurred as stated in the notice of violation. However, it should be noted that handswitch 2-HS-7791 was not improperly installed, but the clearance associated with it was improperly implemented.
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ENCLOSURE 4
VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/96-11 Reason for the Violation:
On September 24,1996, valve 2-HV-8220, Reactor Coolant System Hot Leg Post Accident Sample Isolation, was placed in the open position to be used as a clearance point to establish a vent path ensuring that the reactor coolant system remained drained during maintenance activities.
On October 5,1996, the handswitch indication for this valve indicated the valve was in the closed i
position. A subsequent review of the unit shift supervisors log, control room logs and outage electrical configuration plans did not determine a cause for this valve position to be contrary to the clearance requirements. This violation was a result of tagging open a fail closed valve not in accordance with procedure 00304-C, Equipment Clearance and Tagging. One possible reason the valve could have been mispositioned was due to outage activities that potentially de-energized the electrical bus that powered this solenoid valve. A loss of power would have caused the valve to reposition to its fail safe (closed) position. Procedure 00304-C states that solenoid valves and relays energized in the desired position shall not be used as a clearance point without the component being mechanically blocked in the desired position. This valve was not mechanically blocked in the desired (open) position.
In the other example, on October 8,1996, handswitch 2-HS-7791, Reactor Cavity Sump Pump, was identified to be in the automatic position, whereas the clearance required the handswitch to be in the stop position. An investigation determined that personnel error was the reason for the handswitch to be in a position contrary to the clearance requirements. The operator involved observed that the handswitch light indication for the pump was off, however failed to place the handswitch in the stop position while attaching the clearance tag.
Corrective Steps Which Have Been Taken and the Results Achieved:
The operations supervisors were counseled regarding clearance and tagging restrictions using solenoid valves as clearance points.
2.
The operator was counseled regarding clearance and tagging requirements and the importance of ensuring the component is positioned in accordance with the clearance requirements.
Corrective Steps Which Will Be Taken to Avoid Further 'Liolations:
Licensed and non-licensed operators will receive training on this violation with emphasis on clearance and tagging requirements. Completion date will be March 15,1997.
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ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/96-11 l
Date When Full Compliance Will Be Achieved:
For the first example, full compliance was achieved on October 5,1996, when the clearance was released on valve 2-HV-8220 with the valve in the closed position. In the second example, full compliance was achieved on October 8,1996, when handswitch 2-HS-7791 was positioned in the stop position in accordance with the clearance.
VIOLATION B,50-424: 425/96-11-02 The following is a transcription of the violation B as cited in the Notice of Violation (NOV):
i "During the NRC inspection conducted on September 29 through November 9,1996, violations of NRC requirements were identified. In accordance with the ' General Statement of Policy and Procedure for NRC Enforcement Actions,' Nuclear Regulations (NUREG-1600), one of the violations is listed below:
B.
Technical Specification 4.5.2. Emergency Core Cooling Systems, requires that a visual inspection be performed inside containment prior to containment integrity being established to verify no debris is present that could have the potential to be transported to the emergency sumps.
Procedure 14900-C, Containment Exit Inspection, provides instructions that require prior to containment integrity being established, the licensee verify that debris is removed from j
the containment that could be transported to containment sumps and cause restriction of the emergency core cooling system pump suction during loss of cooling accident i
conditions.
Contrary to the above, on October 8,1996, the license [e] failed to properly perform surveillance Procedure 14900-C, Containment Exit Inspection, in that loose debris was identified on October 9,10, and 11,1996, afler containment integrity was established for Unit 2, that could be transported to the containment sump screens. These findings resulted in a licensee determination that indicated that residual heat removal pump train B would not have had sufficient net positive suction head to perform its intended safety function if called upon during an accident.
This is a Severity Level IV violation (Supplement I)."
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1 ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/96-11 1
RESPONSE TO VIOLATION B (50-424: 425/%11-02)
I Admission or Denial of the Violation-This violation occurred as stated in the notice of violation.
Reason for the Violation:
The violation was a result of personnel error. On October 8,1996, while in Mode 5 (cold shutdown), containment integrity was established following a containment walkdown for loose debris, as required by the Technical Specifications. Personnel entering the containment building on October 9,10,11, and 12,1996, discovered various materials that were not secured and were not being controlled. Upon these individuals exit from the containment building each day they removed the loose debris and material they had discovered. The cause of this event was a failure to clean up areas in the containment as work was completed. Contributing to this event was an inadequate walkdown to remove debris from containment.
l On October 15,1996, an evaluation was completed that indicated that if all the materials had been left in the containment building they would have caused train B of the residual heat removal (RHR) system to not have adequate net positive suction head (NPSH) available to support operation during post accident plant conditions. The surface area of the materials which were capable of being transported to the sumps would have partially blocked the sump screen. The resulting partial blockage of the sump screen would have caused the NPSH requirements to not be met by a small margin, thereby preventing sufficient recirculating water from reaching RHR train B suction line. However, analysis indicated that the train A RHR pump would have remained operable. Also, the excess amount of material that would have led to the loss of adequate NPSH was discovered and removed while the unit was in mode 4, prior to mode 3 entry where the capability of two trains of RHR to recirculate sump water is required. Finally, no event occurred from the time the unit entered mode 3 until the remaining materials were removed, that required RHR recirculation capability.
Corrective Steps which Have Been Taken and the Results AchieveJ:
All uncontrolled materials were removed from containment upon their discovery.
Corrective Steps Which Will Be Taken to Avoid Further Violations:
1.
A revie'w ofinspection techniques and material control methods has been undertaken and appropriate changes will be completed by April 3,1997.
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ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/96-11 2.
Improvements in housekeeping polices will be developed prior to the next refueling outage and completed by May 1,1997.
3.
Housekeeping expectations will be emphasized to plant and contractor personnel by August 15,1997.
Date When Full Compliance Will Be Achieved:
Full compliance was achieved on October 12,1996, when the uncor 4 rolled material was removed from containment.
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