ML20140D662
| ML20140D662 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 06/06/1997 |
| From: | Mccoy C SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-424-97-04, 50-424-97-4, 50-425-97-04, 50-425-97-4, LCV-1050-A, NUDOCS 9706110033 | |
| Download: ML20140D662 (5) | |
Text
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C. K. McCoy Souttrarn Nuclear Vice President Operati;p Company.1:c.
Vogtle Project 40 inverniss Center Parkway R0. Box 1295 Birmingharn, Alabama 35201 Tel 205.992.7122 fax 205.992.0403 k
SOUTHERN h June 6, 1997 COMPANY Energy to Serve YourWorld" i
Docket No.
50-424 50-425 LCV-1050-A U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Ladies and Gentlemen:
VOGTLE ELECTRIC GENERATING PLANT REPLY TO A NOTICE OF VIOLATION Pursuant to 10 CFR 2.201, Southern Nuclear Operating Company (SNC) submits the enclosed information for Vogtle Electric Generating Plant (VEGP) in response to violations identified in Nuclear Regulatory Commission (NRC) Integrated Inspection Report Nos. 50-424; 425/97-04, which concerns an inspection conducted from March 16, j
through April 26,1997. In the enclosure, a transcription of each violation precedes i
SNC's response.
Should you have any questions feel free to contact this office.
Sincerel,
f$
C. K. McCo CKM/AFS
Enclosure:
Reply to NOV 50-424;425/ 97-04 i
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cc: Southern Nuclear Operatina Company Mr. J. B. Beasley, Jr.
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Mr. M. Sheibani NORMS U. S. Nuclear Reaulatory Commission Mr. L. A. Reyes, Regional Administrator Mr. L. L. Wheeler, Licensing Project Manager, NRR Mr. C. R. Ogle, Senior Resident Inspector, Vogtle 9706110033 970606 IlllillOlllllOlllOllEl.l!Ill
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ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/97-04 1
VIOLATION A (50-424 / 97-04-01)
The following is a transcription of violation A as cited in the Notice of Violation (NOV):
"During an NRC inspection conducted March 16,1997, through April 26,1997, violations of NRC requirements were identified. In accordance with the ' General Statement of Policy and Procedure for NRC Enforcement Actions,' (NUREG 1600), the violations are listed below:
A.
10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires in part that activities afTecting quality be prescribed and accomplisned in accordance with procedures.
Procedures 00303-C, " Containment Entry," Revision 18, is provided to control entry in the containment building. This procedure required that material taken into containment be removed prior to entry into Mode 4 or ifit is to remain in containment be evaluated by engineering support or be attended at all times.
Contrary to the above, between March 29,1997, and April 4,1997, with Unit 1 in Modes 3 and 4, numerous examples of unattended and unevaluated debris were identified in the Unit I containment.
This is a Severity Level IV violation (Supplement I). This violation is applicable to Unit 1 only."
RESPOKSE TO VIOLATION A (50-424 / 97-04-01)
Admission or Denial of the Violation:
This violation occurred as stated in the notice of violation.
Reason for tha Violation:
On March 28,1997, Unit I was shutdown for a planned maintenance outage. On March 29, 1997, Unit 1 entered modes 2,3, and 4, and remained in mode 4 during the maintenance outage.
Personnel entering the containment building between March 29,1997, and April 4,1997, discovered various material and debris that were not secured and were not being controlled. As e.ach item was discovered, it was removed. The material and debris were most probably the result of an inadequate walkdown to remove these items during the previous IR6 refueling outage, which was completed in April,1996. Increased emphasis and improved housekeeping practices implemented since the 2R5 refueling outage, which was completed in October 1996, have helped maintain better material control. This was evidenced during the Unit 1 planned maintenance outage.
ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/97-04 l
Based on engineering evaluations, the material and debris discovered would not have caused a malfunction of the containment spray or residual heat removal systems. The residual heat removal and containment spray pumps would have had adequate net positive suction head to perform their function.
Corrective Steps Which Have Been Taken and the Results Achieved:
l All uncontrolled material and debris were removed from containment upon their i
discovery.
Corrective Steps Which Will Be Taken to Avoid Further Violations:
1.
Housekeeping expectations will be emphasized to plant and contractor personnel prior to the next refueling outage.
2.
A review ofinspection techniques and material control methods has been conducted and appropriate changes will be implemented during future refueling outages, which are scheduled to begin in September,1997.
]
Date When Full Compliance Will Be Achieved:
Full compliance was achieved on April 4,1997, when the uncontrolled material and debris was removed from containment.
VIOLATION B,(50-424: 425 / 97-04-02)
The following is a transcription of violation B as cited in the Notice of Violation (NOV):
B.
"10 CFR 50.54 (q) requires that nuclear power plant licensees follow and maintain in effect emergency plans which meet the planning standards of 10 CFR 50.47 (b) and the requirements in Appendix E to 10 CFR Part 50. Section O of the licensee's Emergency Plan (Revision 25) states, ' Revisions are distributed to holders of controlled copies of the Plan and/or procedures [ i.e., Emergency Plan Implementing Procedures or EPIPs] shortly after approval.'
EPIP 91701-C, ' Preparation and Control of Emergency Preparedness Documents,'
Revision 7, dated 08/04/95, states in Section 2.3 that 'The DOCUMENT CONTROL SUPERVISOR is responsible for:
. Maintaining all documents in all ERFs [ Emergency Response Facilities] up to date.' Table 1 of this procedure lists the applicable documents, among which was the 'VEGP Emergency Plan l
Implementing Procedures' in the Operations Support Center (OSC), one of the licensee's ERFs.
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ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT - UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/97-04 Contrary to the above, on April 15,1997, eight Emergency Plan Implementing 4
Procedures in the OSC were identified for which revisions dated between November 21,1996, and April 7,1997, had not been distributed shortly after approval to all required locations.
This is a Severity Level IV violation (Supplement VIII)."
RESPONSE TO VIOLATION B (50-424: 425 / 97-04-02)
Admission or Denial of the Violation:
e This violation occurred as stated in the notice of violation.
Reason for the Violation:
This violation was the result of personnel error. During November 1996, Document Control personnel discontinued updating the EPIP manuals in the ERFs. This was a result of e J
miscommunication between Document Control personnel, who were not thoroughly familiar with distribution requirements for EPIPs in the ERFs, and the Emergency Preparedness staff. Shonly thereafter, the discrepancy was identified and the EPIP manuals at the Technical Support Center and Emergency Operations Center were corrected. However due to a failure to communicate the discrepancy to all cognizant personnel, the Operations Support Center EPIP manual was not corrected. Also, another contributing factor to this violation was that the Document Control distribution matrix used for maintaining ERF documentation was not correct.
Corrective Steps Which ve Been Taken and the Results Achieved:
1.
Document Control personnel have received training for proper EPIP distribution and the importance of maintaining these documents.
2.
The Document Control distribution matrix for maintaining ERF documentation has been corrected.
s 3.
The Emergency Preparedness and Training Department ERF controlled distribution list was revised to specify the controlled documentation that is required to be located in the ERFs.
3
e.
ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/97-04 Corrective Stens Which Will Be Taken to Avoid Further Violations:
No additional corrective actions are planned at this time.
Date When Full Compliance Will He Achieved:
Full compliance was achieved on April 16,1997, when the eight EPIPs were updated with the current revisions and added to the Document Control distribution matrix.
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