ML20141E862

Submits Response to Violations Noted in Insp Repts 50-424/97-01 & 50-425/97-01.Corrective Actions:Afw Valves Were Locked & Added to Safety Lock Valve Specification Checklist

ML20141E862
Person / Time
Site:	Vogtle
Issue date:	05/09/1997
From:	Mccoy C SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-424-97-01, 50-424-97-1, 50-425-97-01, 50-425-97-1, LCV-1011-A, NUDOCS 9705210135
Download: ML20141E862 (11)

Text

l J C. K. McCoy Southern Nucleer Vice President Operating Company. lac.

Vogtle Project 40 inverness Center Parkway l R0. Box 1295  ;

Birmingham Alabama 35201 Tei2059923122 Fax 205.992.0403 May 9, 1997 SOUTHERN h

' Docket No. 50-424 COMPANY q Eneryto Serve krWorld" l 50-425 LCV-1011-A U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Ladies and Gentlemen:

VOGT' 'LECTRIC GENERATING PLANT REPLx 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 Reports 50-424; 425/97-01, that concerns the inspection conducted by the resident site inspectors from February 2,1997, through hfarch 15,1997. In the enclosure, a transcription of each violation precedes SNC's response.

Should you have any questions feel free to contact this office.

Sincerel ,

. k ^

C. K. hicCoy CKM/CTT/AFS

Enclosure:

Reply to NOV 50-424;425/ 97-01 cc: Southern Nuclear Operating Company Mr. J. B. Beasley, Jr.  ;

Mr. M. Sheibani l NORMS l

\

U S. Nuclear Regulatory Commission j Mr. L. A. Reyes, Regional Administrator Mr. L. L. Wheeler, Licensing Project Manager , NRR

. Mr. C. R. Ogle, Senior Resident Inspector, Vogtle 2001an WI,REREn.gg'

a 9705210135 970509- ..

PDR ADOCK 05000424 G PDR .

i ENCLOSURE i

VOGTLE ELECTRIC GENERATING PLANT - UNITS 1 & 2 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/97-01 VIOLATION A.30-425 / 97-01-01 The following is a transcription of violation A as cited in the Notice of Violation (NOV): ,

"During an NRC inspection conheted February 2,1997, through March 15,1997, 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. Technical Specification (TS) Surveillance Requirement (SR) 3.7.5.1. Auxiliary Feedwater System, requires that each manual valve in each water flow path for the three auxiliary feedwater (AFW) pumps that is not locked, sealed, or otherwise secured in position be verified in the correct position every 31 days. >

t Contrary to the above, from October 5,1996, until February 6,1997, the positions of valves 2-1302-U4-180 through -185 were not verified every 31 days as ,

required. These six valves are in the AFW pump recirculation flow paths.

This is a Severity Level IV violation (Supplement I).

This violation is applicable to Unit 2 only."

'!ESPONSE TO VIOLATION A (50-425 / 97-01-01) l Admission or Denial of the Violation:

l This violation occurred as stated in the notice of violation.

i Reason for the Violation:

During the Fall 1996 refueling outage, a design change was instituted in the auxiliary feedwater (AFW) system. This change added piping and six new valves to the system so that the AFW miniflow could be routed to either of two different condensate storage tanks. The piping and valves were placed in service at the end of the outage in October 1996. The cause of the AFW valves not being properly secured was the failure of engineering and operations personnel to ensure appropriate TS surveillance requirements were met upon completion of the design change.

Corrective Steps which llave Been Taken and the Results Achieved:

1. The AFW valves were locked and added to the safety related locked valve verification checklist.

2. Lessou learned from this event have been included in training sessions for appropriate personnel.

i ENCLOSURE

'ibdTLE ELECTRIC GENERATING PLANT- UNITS I & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/97-01

3. Shift operations personnel recently received specific training emphasizing component positioning and verification techniques and expectations.

Corrective Steps Which Will Be Taken to Avoid Further Violations:

The Unit 1 AFW design change package and procedures will be updated to ensure the new unit 1 AFW valves are properly secured upon implementation of the design change.

This will be completed by October 15,1997.

Date When Full Compliance Will Be Achieved:

Full compliance was achieved on February 13,1997, when the Unit 2 AFW valves were locked in their required positions and added to the safety related locked valve verification checklist.

VIOLATION B,50-424:425/ 97-01-02 The following is a transcription of violation B as cited in the Notice of Violation (NOV):

B. " Technical Specification Section 5.4.1.d, Fire Protection Program, states that written procedures shall be establkhed, implemented, and maintained covering the fire protection program.

Paragraph 2.G of the opardng license for Units 1 and 2 requires the licensee to implement and maintain in efTect all provisions of the approved fire protection program as described in tk Updated Final Safety Analysis Report (UFSAR). <

UFSAR Table 9.5.1-10, Item 1.4.1 states that each required fire detection instrument which is accessible during plant operation shall be demonstrated operable at least once per 12 months by performance of a trip actuating device operational test.

Procedure 29227-1 and -2, Fire ad Smoke Detector Operational Test (Panel LZIP 2-1813-Q3-F27), Revision 1 and 29231-1 and -2, Fire and Smoke Detector Operational Test (Panel LZIP l-1813-Q3-F31), Revision 2,' require that operational tests on the fire detect'.on panel and fire detectors be perfonned once every 24 months on a staggered test basis, thus implementing the 12-month performance test required by UFSAR Table 9.5.1-10.

Contrary to the above, the time between operational tests for the fire detectors supplied by Panels LZIP l-1813-Q3-F31 and LZIP 2-1813-Q3-F27 exceeded 12 months. Specifically, the time between the February 11,1996, and June 17,1994 tests for Panel LZIP l-1813-Q3-F31 was approximately 19 months and 11 days 2

.- l ENCLOSURE l I

VOGTLE ELECTRIC GENERATING PLANT- UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION l NRC INSPEgION REPORTS 50-424: 425/97-01 a..d the time between the January 22,1997, and November 1,1994, tests for Panel LZIP 2-1813-Q3-F27 was approximately 25 months and 22 days.

i This is a Severity Level IV violation ($s pplement I)"

RESPONSE TO VIOLATION n (M-ne- (2N 97-01-02)

Admission or Denial of the Violation:

This violation occurred as stated in the notice of violation.

Reason for the Violation:

Initially, the testing for the fire detectors and panels was accomplished utilizing the Preventative Maintenance (PM) program which required sensitivity and operability tests to be performed every 12 months. In 1989, the frequency for the sensitivity tests was revised to 24 months, which complied with the requirements of the National Fire Protection Association code. In 1990, the program for testing the detectors and panels was moved from the PM program and included in the surveillance tracking program with a 24 month frequency established for both tests. This was in error since the required operability test frequency is 12 months.

Corrective Steps Which Have Heen Taken and the Results Achieved:

1. A broadness review was condacted to determine if surveillance operability tests for otner i fire panels or detectors in the inspection program had exceeded 12 months. As a result, it  !

was discovered that a total of 39 surveillances had exceeded the maximum surveillance )

interval in the past, however no surveillances were found to be currently out of date. The inccrrect surveillance task sheets have been revised to specify the correct 12 month testing frequency.

)

2. All other fire protection surveillance task sheets were reviewed to ensure the correct J

frequencies were specified. No other similar problems were found. '

3. A review was conducted of the overall surveillance tracking system to ensure there were l no other similar problems with staggered test frequencies in other areas. No other similar problems were found. l Corrective Steps Which Will Be Taken to Avoid Further VQiations:

No additional corrective actions are planned at this time.

3

ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT- UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/97-01 Date When Full Compliance Will Be Achieved: ,

Full compliance was achieved on March 13,1997, when the surveillance task sheets were corrected specifying testing on a 12 month basis.

VIOLATION C. 50-424:425/ 97-01-03  !

The Mcwing is a tra%cription of violation C as cited in the Notice of Violation (NOV):

i C. "10 CFR 30.71(e) states, in part, that each person licensed to operate a nuclear  !

power reactor shall update periodically the UFSAR to assure that the information included contains the latest material developed.- The updated UFSAR shall be l revised to include the effects of all changes made to the facility and the analysis of l new safety issues performed. Revisions to the UFSAR must be filed annually or six months after each refueling outage provided that the successive updates to the  ;

UFSAR does not exceed 24 months.  :

I Procedure 00402-C, Licensing Document Change Request (LDCR), Revision 15,  ;

provides instructions for changes to licensing documents. (The current procedure is Revision 15: however, the following requirements have existed for several years and were in effect on the date when the required UFSAR changes were identified.) i Section 2.2 of this procedure requires a form, similar to that of Figure 1 of the procedure, to be used to initiate a change, document the change, and approve reqcests for changes to licensing documents. Section 3.3 requires the originator of an LDCR to complete applicable portions of the LDCR form, describe the proposed dange, providejustification for the change and identify other affected documents. Section 3.4 requires the originating department manager to assign a qualified individual to perform the necessary supporting evaluations for the LDCR.

Contrary to the above, required 10 CFR 50 Appendix R related changes to the UFSAR were identified by the licensee, but an LDCR form was not initiated by the i

. problem identifiers, supporting evaluations for the changes were not developed, ,

and the UFSAR was not revised to reflect actual as-built plant conditions related

to Appendix R safe shutdown issues. In addition, several other issues were also identified in which an appropriate LDCR form was not prepared to perform the required safety review and make the appropriate changes to the UFSAR or other licensing related documents.

This is a Severity Level IV violation (Supplement I)"

4 ]

1

__ _ _ . _ . __ .. . .~ . - -

ENCLOSURE i VOGTLE ELECTRIC GENERATING PLANT- UNITS 1 & 2 i

REPLY TO NOTICE OF VIOLATION NKf' INSPECTION REPORTS 50-424: 425/97-01 RESPONSE TO VIOLATION C (50-424:425/ 97-01-03) l i

Admission or Denial of the Violation:

This violation occurred as stated in the notice of violation.

Reason for the Violation:

Subsequent to a review of NRC Information Notice 92-18, it was determined that several discrepancies were identified in UFS AR Table 9.5.1-1. A comparison of UFSAR subject table to the design analyses on which it was based revealed that the table was consistent with the design.

However, minor discrepancies between the table and other UFSAR sections were identified.

To address the discrepancies, normally a Licensing Document Change Request (LDCR) is ,

prepared and submitted with the required changes. Personnel failed to initiate the LDCR as required to address the discrepancies.

Corrective Steps Which linve Been Taken and the Results Achieved:

1. An LDCR has been initiated and approved to address the minor discrepancies in Table 9.5.1-1 of the UFSAR.

2. The applicable procedure has been revised to enhance the administrative controls for processing LDCRs.

3. A broadness review was conducted for similar LDCR problems. The other issues mentioned in the violation were determined to be administrative log keeping errors.

Corrective Steps Which Will Be Taken to Avoid Further Violations:

Department managers will review this violation with appropriate personnel. This action will be completed by June 23,1997.

Date When Full Compliance Will Be Achieved:

Full compliance was achieved on May 8,1997, when an LDCR was initiated and approved.

I 5

l

.- 1 ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT- UNITS 1 & 2 REPLY TO NOTICE OF VIOIATION NRC INSPECTION REPORTS 50-424: 425/97-01  :

VIOLATION D,50-424:425/ 97-01-04 The following is a transcription of violation D as cited in the Notice of Violation (NOV):

D. "10 CFR 50, Appendix B, Quality Assurance Criteria,Section III, Design Control, requires the licensee to, in pan, provide design control measures for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods or by the performance of a suitable testing program.

Contrary to the above, the licensee did not verify the adequacy of the Woodward Governor Company (WGC) 701 Digital Speed Control (DSC) design by the 4

performance of an acceptable design review or by the performance of a suitable 4 testing program. Several deficiencies had been identified by vendor program '

deficiency notices dated September 13,1993. Also, inconsistencies between the original start up setpoint data, dated September 30,1994, and setpoints downloaded from the Train l A diesel generator as well as DSC calibration constants recorded on March 24,1996, compared to data downloaded from the Train 1 A diesel generator were noted.

This is a Severity Level IV violation (Supplement I)" ,

i RESPONSE TO VIOLATION D (50-424:425/ 97-01-04)

Admission or Denial of the Violation:

This violatian occurred as stated in the notice of violation.

Reason for the Violation:

The documentation of the verification and validation (V&V) plan, the validation .

procedure, and the closure of deficiencies associated with the Woodward 701 DSC commercial grade dedication process performed by the VEGP EDG vendor, Cooper ,

Energy Services (CES), was inadequate in that it was not readily available for review and inspection by the NRC. Also the functional test was inadequate in that it did not fully test certain aspects of operation of the new governor.

Southern Nuclear Operating Company audited CES's commercial grade dedication program in 1994, including the deficiencies identified by CES on September 13,1993.

The disposition of the deficiencies was reviewed and found to be acceptable.

Subsequently the basis of the deficiency closure could not be located by CES for review and inspection by the NRC.

6 i

ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT- UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/97-01 The issue of the inconsistencies concerning the setpoint data is cited as a separate violation and is discussed in detail in response to that violation as seen below in " Response to Violation E, 50-424;425 /97-01-05."

Corrective Steps Which if ave Been Taken and the Results Achieved:

l. The current setpoint data was reviewed and determined not to affect the operability of the EDGs.

2. Cooper Energy Services was requested to conduct further bench simulation testing on the Woodward 701 DSC to. test for abnormal responses to simulated inputs. The results of this testing were satisfactoiy.

Corrective Steps Which Will Be Taken to Avoid Further Violations:

1. Southern Nuclear Operating Company (SNC) and the design architect engineer will jointly develop a standard guideline for use in digital upgrades to safety related ,

equipment. This action will be completed by August 31,1997.

2. An audit will be conducted of CES to review the deficiency identification and corrective action closure process. This audit will be completed by October 1, 1997.

3. The deficiencies dated September 13,1993, are being re-investigated by CES to ,

assure adequate documentation and closure. VEGP will follow the resolution of these items and review their outcome. This action will be completed by August 31,1997.

Date When Full Compliance Will Be Achieved:

Full compliance was achieved on April 10,1997, when further bench simulation testing performed under the guidance ofIEEE/ ANSI-7-4.3.2-1993 by CES verified the .

Woodward 701 DSC was acceptable for use in safety related functions. The test report l will be added to the existing design change records by May 13,1997.  ;

i 7

F'

• • ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT- UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/97-01 VIOLATION E. 50-424:425/ 97-01-05 The following is a transcription of violation E as cited in the Notice of Violation (NOV):

E. "10 CFR 50, Appendix B, Quality Assurance Criteria,Section XVII, Quality Assurance Records, requires the licensee to, in part, maintain records to furnish evidence of activities affecting quality. The records shall include at least the following: Operating logs and the results of reviews, bspections, tests, audits, monitoring of work performance, and materials analyses.

Contrary to the above, the licensee failed to maintain records of safety-related equipment settings and calibration constants under configuration control in that there was no record of accessing the 701 DSC settings since September 30,1994, resulting in discrepancies between the current 701 DSC setpoints for the Train l A

- Diesel Generator and the setpoints contained in the test data sheets.

This is a Severity Level IV violation (Supplement I)"

i RESPONSE TO VIOLATION E (50-424:425/ 97-01-05)

Admission or Denial of the Violation:

This violation occurred as stated in the notice of violation.

Reason for thqViolation:

The reason for the violation was inadequate procedural guidance associated with documentation of the 701 DSC functional test.

Corrective Steps Which llave Been Taken and the Results Achieved:

Cooper Energy Services reviewed the EDG 1 A existing governor setpoints, and indicated that the existing 701 DSC setting were acceptable and updated their records. A Q/A record change notice was issued to the VEGP quality records on February 27,1997, to reflect the current EDG 1 A and IB 701 DSC settings.

Corrective Steps Which Will Be Taken to Avoid Further Violations:

Procedural requirements are under development to formally document the as-left EDG . I I

701 DSC settings. This procedural change is expected to be completed by July 30,1997.

8 d

ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT- UNITS I & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/97-01 Date When Full Compliance Will He Achieved:

Full compliance was achieved on February 27,1997, when the existing EDG 1 A and IB 701 DSC settings were formally documented as Q/A records.

VIOLATION F,50-424:425/ 97-01-06 l

The following is a transcription of violation F as cited in the Notice of Violation (NOV):

F. "10 CFR 50.59, Changes, tests, and experiments, in part, prohibits, the licensee from making any change which constitutes an unresolved safety question.

l Contrary to the above, the licensee's 10 CFR 50.59 safety evaluation associated with Design Change Package (DCP) 93-VIN 0050-0-1, dated February 28,1994, and supporting documentation did not provide an acceptable basis to conclude that the 701 governor modification does not create a possibility for a malfunction of a different type than any previously evaluated in the FSAR.

This is a Severity Level IV violation (Supplement I)"

RESPONSE TO VIOI,ATION F (50-424:425/ 97-01-06)

Admission or Denial of the Violation:

This violation occurred as stated in the notice of violation.

Reason for the Violation:

! A 10 CFR 50.59 cvaluation for the EDG digital governor modification concluded that the modification was not an unreviewed safety question. However, since the supplier's program was inadequate, and the safety evaluation was based on the supplier's program, the safety evaluation is also inadequate.

Corrective Stens Which IInve Been Taken and the Results Achieved:

CES was requested to conduct further bench simulation testing on the Woodward 701 DSC to ,

test for abnormal responses to simulated inputs. The results of this testing were satisfactory.

9

l ENCLOSURE

~

VOGTLE ELECTRIC GENERATING PLANT- UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/97-01 l

Corrective Steps Which Will Be Taken to Avoid Further Violations *

1. Southern Nuclear Operating Company and the design e.rchitect engineer willjointly develop a standard guideline for use in digital upgrades to safety related equipment. This action will be completed by August 31,1997.

2. Ar audit will be conducted of CES to review the deficiency identification and co.rective action closure process. This audit will be completed by October 1, d97.

3. The applicable safety evaluation will be revised by May 13,1997, to add references to the recently completed abnormal events and conditions testing performed on the Woodward 701 DSC.

Date When Full Compliance Will Be Achieved:

Full compliance will be achieved by May 13,1997 when the applicable safety evaluation will be revised to add references to the recently completed abnormal events and conditions testing performed on the Woodward 701 DSC conducted by CES.

10