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UNITED STATES ACTION - Lieberman, OE f
NUCLEAR REGULATORY COMMISSION Cys:
Taylor i
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WASHIN GTON,0.C. 20555 i
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Thompson l;
December 27, 1991 Blaha Murley j
OFFICE OF THE Ebneter SECRETARY H3yg5 Nw l
MEMORANDUM FOR:
James M. Taylor j
Executive Director for Operations i
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FROM:
U,' Samuel J. Chilk, Secretary J
SUBJECT:
SECY-91-387 - PROPOSED ENFORCEMENT ACTION l
AGAINST GEORGIA POWER COMPANY, VOGTLE ELECTRIC GENERATING PLANT UNITS 1 & 2 l
(EA 91-141) l l
j This is to advise you that the Commission has not objected to the j
Notice of Violation and Proposed Imposition of Civil Penalty to i
be issued to Georgia Power Company and the letters to be issued j
to William Kitchens, Jimmy Cash and John Bowles, j
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The Chairman Commissioner Rogers Commissioner Curtiss j
Commissioner Remick Commissioner de Planque i
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SECY NOTE:
THIS SRM AND SECY-91-387 INVOLVE ENFORCEMENT ACTION - LIMITED TO NRC UNLESS THE COMMISSION DETERMINES OTHERWISE
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information in inis record was deleted in accordance with tpeedom of information
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DEC 3 f1991 i
i Docket No. 50-424 License No. NPF-68 EA 91-141 i
Georgia Power Comany j
ATTN: Mr. W. G. 4airston III J
Senior Vice President -
Nuclear Operations i
Post Office Box 1295 Bimingham, Alabama 35201 i
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Gentlemen:
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SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY - $100,000 (NRC OFFICE OF INVESTIGATIONS REPORT NO. 2-90-001) 4 This refers to the investigation conducted by the Nuclear Regulatory i
i Commission's Office of Investigations (01) at Georgia Power Company's (CPC) i Vogtle Electric Generating Plant (VEGPJ which was completed on March 19,1991.
l The investigation was initiated as a result of infomation received by Region II i
l in January 1990, alleging that VEGP Unit I was intentionally placed in a con-dition prohibited by Technical Specifications (TS). The event in questio.i involved the alleged willful violation of TS 3.4.1.4.2 that occurred when f
Unit 1 Reactor Makeup Water Storage Tank (RMWST) valves.were opened to i
j facilitate chemical cleaning of the Reactor Coolant System (RCS) in October 1988, while the plant was in a refueling outage. The TS required the RMWST i
valves to be closed and secured in position while the plant was in Mode 5 with the reactor coolant loops not filled. A notice of enforcement conference and Demand for Information was sent to you on June 3,1991. An enforcement conference was held on September 19, 1991, in the Region II office to discuss l
this issue, its cause, and subsequent corrective actions taken. As a result of i
' questions raised during the enforcement conference, a supplemental response to the Demand for Infonnation was requested. The additional infonnation was 3
received by the NRC on October 1, 1991. The list of personnel in attendance at j
t the enforcement conference and copies of the presentation material provided by your staff during the enforcement conference are enclosed.
The violations described in the enclosed Notice of Violation and Proposed j
ImpositionofCivilPenalty(Notice)resultedfromthefailureofGPCmanage-ment to provide adequate procedures, appropriate training and guidance relativt to mid-loop operation, and planning assistance to operations personnel at VEGP during the first refueling. outage and associated chemical cleaning evolution that involved the injection of chemicals into the RCS. As a resu.t of this i
failure, several VEGP operators and operations management personnel placed the l
plant in an unanalyzed condition. Furthermore, the root cause that led to t!e l
improper valve manipulations condition were not fully addressed by GPC manage-ment until more than a year after the events.
Inform'affon in this record was deleted in accordance with tiltheedom of Infornistion
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- DEC 3 l'1991 3
- Georgia Power Company i
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'The NRC staff recognizes that GPC maintains that the basis of TS 3.4...,
i precluding an uncontrolled boron dilution, was met by operating the valves under administrative controls. However, the words of the T.S. prohibit J
uncontrolled boron dilutions in Mode 5, loops not filled, by prohibiting all Additionally, the NRC staff under.
i dilutions through the flow path at issue.
stands your position about voluntary entry into the TS ACTION requirement..
4 Again the NRC staff concludes that the words of.the requirement clearly 1
prohibit entering ACTION 6c. of TS 3.4.1.4.2.
However, the issues specific to 1
j the TS aside, procedures and training were inadequate.
The violations, when considered collectively, indicate a significant breakdown f
in managerial and administrative controls of licensed activities in a number of Such a breakdown is'also indicative of a significant lack interrelated areas.
This breakdown j
of attention to licensed responsibilities by plant personnel.
in control was wide-ranging in that it not only involved inadequate actions and 1
faulty decisions during the event by individual senior licensed operators in management positions, but included the Plant Review Board which subsequently performed an inadequate review of reportability.. failed to recognize that an unanalyzed condition existed, and consequently confirmed the reasonableness of Therefore, in accordance with a flawed Technical Specification interpretation.
the " General Statement of Policy and Procedure for NRC Enforcement Actions,"
(Enforcement Policy) 10 CFR Part 2. Appendix C (1988), the violations are i
j classified in the aggregate as a Severity Level III problem.
After careful delibefation, the NRC has concluded that based on the evidence I
available a willful violation of regulatory requirements due to the manipu-This 1ation of the RMWST valves in October 1988 could not be substantiated.
i-conclusion was based on the OI report, a review of the infomation provided by l
your staff in the several responses.to Demands for Information which were received on August 29, 1991, as well as presentations at the enforcement j
conferences on September 19, 1991. The NRC also recognizes that the personnel who were directly involved in this matter provided credible assurances that l
they intend to comply with regulatory requirements in the future.
To emphasize the importance of ensuring that plant staff is complying with Technical Specifications and that management is maintaining control of plant activities, I have been authorized, after cor,sultation with the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research, and to issue the enclosed Notice of Violation and Proposed the Connission for the Severity Level III Imposition of Civil Penalty in the amount of $100,000The base valu i
i problem.
The escalation and mitigation factors in the Enforcement Policy were l
$50,000.
considered.
The base civil penalty was escalated by 50 percent because the violations were l
identified by the NRC and should have been identified when the questions were Escalation of 50 percent was applied for the corrective raised by your staff.
action factor since no long-ters corrective action was taken to prevent Even as late as one year after the initial occurrence, the Plant i
recurrence.
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DEC 311991
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Georgia Power Company -
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Review Board had still not made the appropriate reportability decision regarding the circumstances of opening the RMWST valves because an adequate root cause evaluation had yet to be made. They did, however, initiate actions to change the applicable Technical Specification. The other adjustment factors in the Policy were considered and no further adjustment to the base civil penalty is considered appropriate. Therefore, based on the above, the base civil penalty has been increased by 100 percent.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. Your response may cross reference your previous submittals concerning these events.
In your response, you should document the specific actions taken and ay additional action you plan to prevent recurrence. After reviewing'your response to this Notice, including your proposed corrective actions and the retults of future inspections, the NRC will determine whether further NRC enfortement action is necessary to ensure compliance with NRC regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice " a copy of this letter and its enclosure's will be placed in the NRC Public Document Room (PDR). Also being placed in the PDR now that our evaluation of these events is complete, are the Demand for Information sent to you and your response to it.
The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
Sincerely, O
i t art D. Eb ter Regional Administrator
Enclosures:
1.
Notice of Violation and Proposed Imposition of Civil Penalty 2.
Copy of licensee presentation material 3.
List of Attendees at NRC enforcement conference, 9/19/91 cc w/encls:
R. P. Mcdonald Executive Vice President-Nuclear Operations Georgia Power Company -
P. O. Box 1295 Binningham, AL 35201 C. K. NcCoy Vice President-Nuclear Georgia Power Company P. O. 1295 Binningham, AL 35201
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DEC 811991 Georgia Power Company
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W. B. Shipman General Manager, Nuclear Operations Georgia Power Company P. O. 1600 Waynesboro, GA 30930 J. A. Bailey.
Manager-ticensing Georgia Power Company P. O. Box 1295 Binningham, AL 35201 D. Kirkland, III, Counsel Office of the Consumer's Utility Council Suite 225, 32 Peachtree Street, NE Atlanta, GA 30302 Office of Planning and Budget Room 6158 j
270 Washington Street, SW Atlanta, GA 30334 Office of the County Connissioner Burke County Connission Waynesboro, GA 30830 Joe D. Tanner, Connissioner j
i Department of Natural Resources 205 Butler Street, SE, Suite 1252 j
Atlanta, GA 30334 4
Thomas Hill, Manager l
Radioactive Materials Program j
Department of Natural Resources 1
878 Peachtree St., NE., Room 600 Atlanta, GA 30309 Attorney General Law Department 132 Judicial Building Atlanta, GA 30334 Dan Smith, Program Director of Power Production Oglethorpe Power Corporation 2100 East Exchange Place P. O. Box 1349 Tucker, GA 30085-1349 f
cc w/ enc 1 cont'd: (seenextpage)
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DEC 311991
. Georgia Power Company cc w/ enc 1 cont'd:
Charles A. Patrizia. Esq.
Paul, Hastings, Janofsky & Walker 12th Floor 1050 Connecticut Avenue, NW Washington, D. C.
20036 Georgia Power Company State of Georgia 6
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DEC 811881
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Georgia Power Company
- Distribution PDR SECY-CA JSniezek DEDR SEbneter, RII JLieberman, OE JLuehman, OE JPartlow. NRR JGoldberg, OGC Enforcement Coordinators RI, RII, RIII, RIV, RV FIngram.PA-BHayes, O!
DWilliams,CIG
.EJordan,idOD EA File Dayfile S. Sparks, RII D. Hood, NRR P. Skinner, RII A. Herdt, RII Document Control Desk
.To Tokese,fut NRC Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 572 Waynesboro, GA 30830 RI R
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AND PROPOSED IMPOSITION OF CIVIL PENALTY l
Docket No. 50-424 Georgia Power Company License No. NPF-68 Vogtle Electric Generating Plant EA 91-141 Unit 1 During an iRC investigation conducted between February 1,1990, and March 19,
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1991, violations of NRC requirements were identified.. In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205. The particular violations and associated civil penalty are set forth below:
3.4.1.4.2 (1988 edition) required that two Technical Specification (TS) residual heat removal (RHR) trains shall be OPERABLE and at lea A.
Reactor Makeup Water Storage Tank (RMWST) train shall be in operation.
discharge valves (1208-04-175,1208-U4-176,1208-U4-177, and 1208-U4-183 shall be closed and secured in position whenever the plant is in Mode 5 ACTION c. of TS 3.4.1.4.2 required with reactor coolant loops not filled.
that with the RMWST valves not closed and secured in position, imediately close and secure them in position.
with Unit 1 in Mode 5, Contrary to the above, on October 12 and 13,1988, loops not filled, RMWST valves 1208-U4-176 and 1208-U4-177 were opened in order to add chemicals to the Reactor Coolant system.
50.73(a)(2)(ii)(B) requires licensees to submit a Licensee Event Report (LER) within 30 days after the discovery of any event or condition that B.
resulted in the nuclear power plant being in a condition outside the design basis of the plant.
17, 1989, the Plant Review Contrary to the above, on or about November Board (PRB) determined that the opening of the RMWST valves specified in TS 3.4.1.4.2 was not reportable and, therefore, an LER was not submitted within 30 days, even though opening the valves on October 12, and 13,1988 had placed the plant in a condition outside the design basis. Opening the valves constituted a condition outside the plant design basis because at the time the valves were opened an analysis for a boron dilution accident through the valves did not exist.
Technical Specification 6.7.1 requires written procedures shall be estab-lished, implemented, and maintained covering the activities recommended by C.
Appendix A of Regulatory Guide (RG) 1.33. Revision 2. February 1978.
Section 2 of Appendix A of.RG 1.33, recosmends procedures for general plant operation.
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- The following procedures, in part implement TS 6.7.1.
Vogtle Electric Generating Plant (VEGP) Operations Procedure Number 1.
12006-C, Unit Cooldown to Cold Shutdown, in use on October 12 and 13, 1988, stated in Section D4.2.14 that valves 1-1208-U4-175,1-1208-U4-176, 1-1208-U4-177, 1-1208-U4-181, 1-1208-U4-183, and others be closed, locked and tagged in Mode 5, loops not filled.
2.
VEGP Procedure 10000-C Conduct of Operations, Section 2.10.2 in use October 12 and 13,1988, statedthattheUnitSuperintendent(US)is responsible to ensure plant operations are conducted in accordance with Technical Specifications and approved procedures.
Contrary to the above:
1.
On October 12 and 13, 1988, licensee personnel failed to implement the requirements of procedure number 12006-C in that, valves 1-1208-U4-176 and -177 and 181, which were required to be closed, locked and tagged, were opened in Mode 5, loops not filled.
2.
On October 12 and 13, 1988, the US did not ensure that plant 1
operations were conducted in accordance with Technical Specifications in that valves 1-1208-U4-176 and -177 were opened in Mode 5 loops not filled, with the express knowledge of the US.
i D.
10 CTR 50, Appendix B, Criterion V, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. VEGP Procedure No. 13007-1, VCT Gas Control and RCS Chemical
. Addition, Section 4.7, Procedure No. 35110-C, Chemistry Control of the Reactor Coolant System, Section 4.7 provide the instructions on chemical additions to the Reactor Coolant System.
Contrary to the above, on October 12, end 13,1988, VEGP Procedure Nos.13007-1 and 35110-C were inadequate in that these procedures did not contain provisions for adding chemicals to the reactor coolant system in Mode 5, loops not filled. Specifically, the procedures specify such 4
conditions as having a reactor coolant pump running which is not possible in Mode 5, loops not filled.
ThisisaSeverityLevelIIIproblem(SupplementI).
l Civil Penalty - $100,000 (assessed equally among the four violations).
i Pursuant to the provisions of 10 CFR 2.201, Georgia Power Conoany is hereby l
required to submit a written statement or explanation to the )irector, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice of Violation and Proposed Imposition of Civil Penalty (Notice).
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!. Notice of Violation This reply should be clearly marked as a " Reply to a Notice of Violation" and 4
i (1) admission or denial of the should include for each alleged violation:
alleged violation (2) the reasons for the violation if admitted, and if i
denied, the reasons why, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps that will be taken to avoid further If an l
violations, and (5) the date when full compliance will be achieved.
adequate' reply is not received within the time specified in this Notice, an f
order or a demand for inforination may be issued as to why the license should
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not be modified, suspended, or revoked or why such other action as may be j
proper should not be taken. Consideration may be given to extending the i
Under the authority of Section 182 of the i
response time for good cause shown.
' Act 42 U.S.C. 2232, this response shall be submitted under oath or affirination.
Within the same time as provided for the response required above under I
10 CFR 2.201, the Licensee may pay the civil penalty by letter addressed to the i
Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, money order, or electronic transfer payable to the Treasurer of 1
the United States in the amount of the civil penalty proposed above, or may protest imposition of the civil penalty in whole or in part, by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Should the Licensee fail to answer within the time 1
Regulatory Comission.
Should the specified, an order imposing the civil penalty will be issued.
i Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, in whole or in part, such answer should be clearly marked as an (1) deny the violations listed in
" Answer to a Notice of Violation" and may:
this Notice in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalty should not i
In addition to protesting the civil penalty in whole or in part.
be imposed.
such answer may request remission or mitigation of the penalty.
j' d in Section V.B of 10 CFR Part 2, Appendix C (1988)y, the fac In requesting mitigation of the proposed penalt I
, should be addressed. Any written ar.swer in accordance with 10 CFR 2.205 should be set forth separately l
from the statement or explanetion in reply pursuant to 10 CFR 2.201, but may i
incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing l
The attention of the Licensee page and paragra
>h numbers) to avoid repetition.is directed to t)e other provisions o i
for imposing a civil penalty.
Upon failure to pay any civil penalty due which subsequently has been deter-l mined in accordance with the applicable provisions of 10 CFR 2.205, this matter l
may be referred to the Attorney General, and the penalty, unless compromised, Section 234c of the Act. 42 U.S.C. 2282(c)y civil action purs remitted, or mitigated, may be collected b
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The response noted above (Reply to Notice of Violation, letter with payment of civil penalty, and Answer to a Notice of Violation) should be addressed to:
Director, Office of Enforcement, U.S. Nuclear Regulatory Comission. ATTN:
i Document Control Desk, Washington, D.C. 20555 with a copy to the Regional i
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4-Notice of Violation Administrator, U.S. Nuclear Regulatory Commission, Region II, a copy to the NRC Resident inspector at the Vogtle Electric Generating Plant.
Dated at Atlanta, Georgia this'3fL* day of December 1991 b
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ENCLOSURE I
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Blaha Doccmbor 27, 1991 Murley I
Ebneter omes or tus Hayes scenerAny hi MEMORANDUM FOR:
James M. Taylor Executive Director for Operations
(/' a$muel J. Chilk, Secretary 7
o FROM:
SECY-91-387 - PROPOSED ENFORCEMENT ACTION SUBJECT AGAINST GEORGIA POWER COMPANY, V0GTLE ELECTRIC GENERATING PLANT UNITS 1 & 2 (EA 91-141)
This is to advise you that the Commission has not objected to the Notice of Violation and Proposed. Imposition of Civil Penalty to be issued to Georgia Power Company and the letters to be issued to William Kitchens, Jimmy Cash and John Bowles.
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Commissioner de Planque 000 OCAA OIG THIS SRM AND SECY-91-387 INVOLVE ENFORCEMENT SECY NOTE:
ACTION - LIMITED TO NRC UNLESS THE COMMISSION DETERMINES OTHERWISE.
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ENCLOSURE 2 I
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REVIEW OF EvYNTI GPC CONCLUSIONS I.
DISCUSSION OT 01's CONCLUSIONS 11-12, 1988 II.
NIGHT SNIFT OT OCTOBER DAY SNITT OT OCTOBER 12, 1988 1988 INTERPRETATION CONSISTENT WITN 1988 III.
SATETY SIGNIFICANCE IV.
INSTITUTIONAL WEAKNESSES V.
CORRECTIVE ACTIONS AND ENHANCD(ENTS VI.
ASSURANCE OF TECH SPEC COMPLIANCE VII.
.VIII.
SUMMARY
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4 OPC CONCLUSIONS 1
NO DELIBERATE OR WILLIVL TECH SPEC VIOLATI l
TS INTERPRETATION WAS MADE IN GOOD FAITH, WITH COMPLIANCE AS THE OBJECTIVE l
ENTOP, CEMENT FOR A TECH SPEC V101ATION IS UNWARRANT i
VOLUNTARY ENTRY WAS CONSISTENT WITH EXIST l
REGULATORY GUIDANCE, PRACTICE ALTHOUGH OPERATORS MISTAXENLY PLACED PLA i
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CONDITION WHICH WAS NOT TULLY ANALYZED, TECH SPEC VIOLATION DID NOT OCCUR BETTER INDUSTRY GUIDANCE WAS AND IS STILL t
1 IN THIS AREA i
THIS EVENT MAD MINIMAL SAFETY SIGNIFICANCE f
i APPROPRIATE REVIEW AND ADMINISTRATIVE C l
EXERCISED CONFIRMED BY WESTINGHOUSE ANALYSIS ENTRY INTO TECH SPEC LCO WITH "IMMEDIATE*
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DISCD8810N OF WRC-0!'8 CONCLUSION TH VEGP OPERATORS WILLFULLY VIOLATED TE THE THERE IS HO EVIDENCE OF WHICH WE ARE OPERATORS HAD EITHER (1) TECH SPECS, OR (2 REQUIREMENTS.
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1981 ActioWS oF THE WIGHT SEIFT ON OCTOBER 11-12, SENIOR LICENSED OPERATORS WERE UNAWA WAS APPLICABLE AT THE TIME THEY AUTH 176 AND 177.
BASED ON THEIR TRAINING AND GUIDA I
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TECH SPEC WAS APPLICABLE.
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4 12-13, 1988 ACTIONS OF DAY 8HIFT OF OCTOBER l
5 OPERATIONS MANAGER ' EXERCISED REASON I
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OPERATIONS MANAGER TIRST PLACED i
THE TECH SPEC BASES STATED AN INTENT TO P UNCONTROLLED BORON DILUTION I
OPERATIONS MANAGER REVIEWED THE TSAR AN l
PLANNED EVOLUTION HAD BEEN ANALYZED AN j
AVAIIABLE FOR THE SPECITIED OPERATOR ACTION 1
OPERATIONS MANAGER CONSULTED WITH OTHERS, INCLUD l
j EXPERIUCED OPERATIONS MANAGER OPERATIONS MANAGER'S KNOWLEDGE AND EXPE INTERPRETATION OF THE TECH SPEC l
HO ONE ON-SHIFT RAISED A CONCERN ABOUT TH I
OPERATIoHS HANAGER WAS NOT MOTIVATED BY SC ECON 0 HIC BENEFITS
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INDEPENDENT AFTER-THE-TACT REVIEWS BY THE NSAC MA PLANT GENERAL MANAGER, THE CORPORATE OFFICE AND THE l
CONTIRHED THE REASONABLENESS OF THE INTERPR l
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1988 INTERPRETATION CON 818 TENT WITE GUIDAN THE VOLUNTARY ENTRY INTO A TECH SPEC LCO R ACTION IS AN EVOLVING INDUSTRY ISSUE OVER W HINDS CAN DIrrER JANUARY, 1982 NRC GUIDANCE.
"THE NRC ENDORSES VOLUNTARY ENTRY INTO THE I
STATEMENT CONDITIONS AND HAS STRUCTURED THE PERHIT THE LICENSEE To EXERCISE JUDGHENT WIT LATITUDE PERMITTED BY THE ACTION STATEMENT THE TS.*
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VOLUNTARY 1987 VIEW OT NRC REGION V ADMINISTRATOR:
ENTRY INTO TECH SPEC $ 3.0.3 WAS APPROPRIATE O OCCASION.
" REGION V CONTENDS THAT INTENTIO 3.0.3 FOR OPERATIONAL CONVDIENCE SHOULD NOT BE HADE, EXCEPT UNDER EXTREMELY UNUSUAL CIRCUMSTANCES DETAILED REVIEW BY THE LICENSEE HAS CONCLUDE REDUCTION IN SAFETY WILL RESULT."
VOLUNTARY ENTRY INTO TECH SPEC LCos WHICH USE "SHALL" IS CONDONED BY THE NRC.
"THE CONTAINHENT ISOLATION VALVES SHALL BE EXAMPLE:
OPERABLE.... WITH ONE OR MORE OF THE CONTAINHENT VALVE (S) INOPERABLE... RESTOR THE INOPERABLE VALVE (S) WITHIN 4 HOURS
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SAFETY SIGNIFICANCE 4
ENTRY INTO TECH SPEC 3.4.1.4.2 HAD MIN
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OCTOBER 12, 1988 4
j SATETY CONSEQUENCES ENTRY MADE UNDER ADMINISTRATIVE CONTROLS 1989 WESTINGHOUSE ANALYSIS CONFIRMS T OPENING OF RMWST VALVES IS NOT A SAFETY IS i
l AT LEAST 15 MINUTES AVAILABLE TO MITIGA MODE 58.
j TEBRUARY,1990 TECH SPEC AMENDMENT BASED ON LAC f
SATETY IMPACT AUGUST,1991 WESTINGHOUSE ANALYSIS OF THE ACTUA THE OCTOBER,1988 EVOLUTION:
12, 07:00 774 PpH BORON CONCENTRATION OT OCTOBEROPENED; OVER 48 HOURS WHEN VALVES 176, 177, 181 (9 HOURS FROM HIGH FLUX AIARM) WOULD M 1
NECESSARY 70 REACH CRITICALITY.
i Iso 1ATED EVOLUTION /N0 BROAD APPLICATION e
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INSTITUTIONAL TEAKNE88E8 IDENTIFIED e-OPERATIONS OUTAGE PLANNING PROCESS / REVIEW INSUFFICIENT:
REVIEW FAILED TO IDENTITY POTENTIAL TECH SPEC INSUFFICIENT GUIDANCE / TRAINING REGARDING CONDITION OF MODE 5 No GUIDANCE CONCERNING VOLUNTARY ENTRY IN "IMMEDIATE" ACT AMBIGUITIES IN FSAR ACCIDENT ANALYSIS FOR TH TECH SPEC INTERPRETATION PROCESS TOO NARROW 4
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CORR ECT Iviii ACT I ON 8 / ENHANC EN ENTE f
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OUTAGE PLANNING 4
4 MATURED SINCE FIRST REFUELING IN 1988 VEGP PROCEDURE 29537-C, REV. 5 DEFINES A MULT i
PROCESS LICENSED SROS IN OUTAGE PLANNING GROUP; GR f
DEPARTMENT REVIEW OF OUTAGE SUBTASKS i
D SPECIAL CONSIDERATION To CONFIGURA I
RCS COOLANT INVENTORY 1
GREATER " RISK MANAGEMENT"
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I CORRECTIVE ACTION 8/ENEANCEXENTS 4
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" LOOPS NOT FILLED" GUIDANCE FEBRUARY,1989 UNIT 2 VIOLATION LED TO SIGNITICANT ENHANCIXENTS TECH SPEC INTERPRETATION FROM OPERf MANAGER SPECIFICALLY ADDRESSED TEC FEBRUARY 22, 1989
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EARLY 1989, SHIrf BRIEFING BOOK AND OPERATIONS j
ADDRESSED REQUIRED POSITIONS FOR RMW I
j 58 AND 6 OTHER PROCEDURES, INCLUDING VEGP PROCEDURE 70 ADD PRECAUTION REGARDING RMWST VALVES NORE GUIDANCE AVAILABLE TO OPERATOR l
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AT REDUCED INVENTORIES i,
TRAINING NOW PROVIDED CONCERNING "Ih0PS CONDITION FURTHER CLARIFICATION BASED ON DATA MARCH 30, 1990 i
l NESTINGHOUSE DURING REQUALIFICATION TRAINING, OPERATORS REC j
TRAINING ON REVISED PROCEDURE 12006-C i
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RMNST DISCHARGE VALVES AND TS INTERP l
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CORRECTIVE ACTIONS /ENCMMI 1
1 VOLUNTARY TS ENTRY 1
OCTOBER 2,1989 CORPORATE POLICY FROM C. K. McC0Y:
" VOLUNTARY ENTRY INTO AN LCO WH SHOULD HOT BE MADE.8 l
MIMORANDUM FROM VEGP GENERAL MANAGER ADVISED OPERATORS TMAT NRC DOES EQI AUGUST 15, 1991 INTO LCOs WHICH DO NOT HAVE SPECIFIC A07:
"GPC HAS RECENTLY BECOME AWARE OF A SPEC LCOs AND THEIR ASSOCIATED ACTION STATEME EQT PROVIDE A SPECIPIC LCO ACTION T i
THE NRC AS AN " ALLOWED OUTAGE TIME" VOLUNTARILY ENTERED.EXCEPT AS EXPRESS ASSOCIATED SURVIILLANCE REQUIREMDTS."
i.
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congEcTIvf ACTION 8/ENEANCEXENTA
-SAR ACCIDENT ANALYSIS T
1, BORON DILUTION ACCIDENT HAS BEEN 4
(NOVEMBER, 1989)
SUPPORTED TECH SPEC CHANGE TO SPECITICALL OPENING RMWST VALVES FOR SHORT PERIODS l
/
TSAR SCHEDULED FOR TURTHER CLARI 4
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CORRECTIVE ACTION 8 /ENHANCEMENTi TECH SPEC INTERPRETATION PROCESS GOVERNED BY VEGP PROCEDURE 10000-C; REVISED S 1988 INCORPORATED COMMENTS OF NRC SPECIA AUGUST, 1990 MAY BE MADE BY SNIFT SUPERINTENDENT, OPERATIONS SUPERINTENDENT, MANAGER OT OPERATIONS CONCURRENCE MUST NOW BE OBTAINED TROM MANAGER CORPORATE LICENSING SUPPORT (SOUTHER EXTENSIVE THAN IN OCTOBER,1988 TINAL APPROVAL FROM MANAGER OF OPERATIONS COMMUNICATIONS WITH NRC HAVE ALSO SIG 1
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3 Ovr.rALL ASSURANCE OF TECE 8PEC COMPLIANCE t
OPERATOR TRAINING EMPHASIZES TECH SPEC COMPLI i
REQUALITICATION TRAINING ADDRESSES PLANT MODITICATION PROCEDURAL CHANGES, SIGNIFICANT OPERATING EXPERIENCE VEGP PROCEDURE 10000-C ASSIGNS SPECITIC RES i
OPERATIONS PERSONNEL TO ASSURE COMPLIANCE OPERATIONS DEPARTMENT MANAGEMENT EMPHASIS ON:
SAFETY AND COMPLIANCE ARE PRIMARY; i
QUEST 10HING APPROACH TO OPERATIONS; d
l ACCESS 70 MADGEMENT; TEAMWORK.
DEPARTMENT MANAGERS TASXED TO ROUTINELY OBSERV ACTIVITIES / COMPLIANCE POSITIVE DISCIPLINE POLICY TOR INDIVIDUAL ACCOU (COMPLIANCE WITH TECH SPECS, PROCEDURES) j l
MANAGEMENT EXPECTS COMPLIANCE-ORIENTED 'SATET i
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SUMMARY
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NO DELIBERATE OR WILLTUL VIOLATION i
TS INTERPRETATI0H MADE IN GOOD TAITH, WITH REASONED JUDCMENT INDIVIDUA1J ENTORCEMENT UNWARRANTED TECH SPEC VIOLATION TO GPC IS INAPPROPRIATE TS ENTRY WAS CONSISTENT WITH EXISTING GUIDANCE, j
]
g PRACTICE i
VOLUNTARY ENTRY IS AN EVOLVING GENERIC ISSUE, i
1 APPROPRIATELY ADDRESSED IN GENERIC GUIDANCE OR CORRESPONDENCE.
l OCTOBER,1988 INCIDENT DEMONSTRATED TO HAVE NO SIGNIFICANTf SAFETY OR REGULATORY IMPACT ADHINISTRATIVE CONTROL EXERCISED CONTIRMED BY WESTINGHOUSE ANALYSIS i
ISOLATED EVENT GPC HAS MADE SIGNIFICANT ENHANCEMENTS THAT COM ADDRESS THE INSTITUTIONAL WEAXNESSES HIGHLIGHTED BY OCT 1988 INCIDENT i
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O ENCLOSURE 3 1
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, f NRC ENFORCEMENT CONFERENCE GEORGIA POWER COMPANY V0GTLE ELECTRIC GENERATING PLANT September 19, 1991 NRC Region 11, Atlanta, Georgia J. Sniezek, USNRC/HQ, EDO S. D. Ebneter, USNRC/Ri!
J. Lieberman, USNRC/HQ, OE J. G. Partlow, USNRC/HQ, NRR J. L. Milhoan, USNRC/R!l D. B. Matthews, UNRC/HQ, NRR/PD!l-3 H. J. McGurren, USNRC/HQ, OGC B. Hayes, USNRC/HQ, 01 G. C. Lainas USNRC/HQ, NRR E. W. Merschoff, USNRC/Ril, DRP J. Y. Vorse. USNRC/RII, 01 G. R. Jenkins, USNRC/Ril, EICS P. H. Skinner, USNRC/RII, DRP
- 5. J. Vias. USNRC/Ril, DRP B. Uryc, USNRC/Ril EICS J. G. Luehman, USNRC/HQ, OE R. Hoefling, USNRC/HQ, OGC C. F. Evans, USNRC/Ril, ORA C. T. Tate, USNRC/RII, 0!
D. Hood, USNRC/HQ, NRR/PDII-3 M. P. Huber, USNRC/RI!!, DRP A. R. Herdt, USNRC/RII, DRP M. J. Ajlunt, SNC R. P. Mcdonald, GPC W. G. Hairston,111, GPC J
C. K. McCoy, GPC W. B. Shipman, GPC/YEGP A. H. Daly', GPC D. A. Repka, GPC i
i J. Lamberski, GPC l
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