ML20148H193
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| ML20148H193 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/07/1988 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Head G GEORGIA POWER CO. |
| References | |
| NUDOCS 8803290344 | |
| Download: ML20148H193 (40) | |
See also: IR 05000424/1987058
Text
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MAR 07 9R
Docket Nos. 50-424, 50-425
License Nos. NPF-68, CPPR-109
Georgia Power Company
L4TTN: Mr. George F. Head
Senior Vice President -
Nuclear Operations
P. O. Box 4545
Atlanta, Georgis 30302
Gentlemen:
SUBJECT: SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE,
REPORT NOS. 50-424/87-58 AND 50-425/87-40
This refers to the NRC's Systematic Assessment of Licensee Performance (SALP)
Board Report for your Vogtle facility which was sent to you on January 11,
1988; our meeting of January 19, 1988, at which we discussed this report; and
your written comments dated February 15, 1988, relative to the report.
We have reviewed your written comments and will monitor the improvements you
are proposing in future inspections. The enclosed Appendix incorporates a
change which is in response to your comment on Fire Protection and provides
the errata for final approved version of the SALP Board Report.
Additionally, we have enclosed a photocopy of the slides that were used during
the presentation.
I
No reply to this letter is required; however, should you have any questions
concerning these matters, I will be pleased to discuss them with you.
Sincerely,
(Original signed by J. N. Grace)
J. Nelson Grace
Regional Administrator
Enclosure:
Appendix to Georgia Power Company '
i Vogtle Facility SALP Board
Report Nos. 50-424/87-58 and
50-425/87-40 (dated January 11, 1988)
cc w/ enc 1: (See page 2)
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cc w/ encl:
p D. Rice, Vice President
Project Director
'pf W. Hayes, Vogtle Quality
Assurance Manager
g. Bockhold, Jr.,-General Manager
Nuclear Operations
1)/Gucwa, Manager,NuclearSafety
and Licensing
pA. Bailey,ProjectLicensing
Manager
g W. Churchill, Esq., Shaw,
Pittman, Potts, and Trowbridge
g Kirkland, III,' Counsel,
_ Office of the Consumers, Utility
Jouncil
- 15. Feig, Georgians Against
Nuclear Energy
bec w/ encl:
d airman Zech
L&6mmissioner Roberts
LC'ommissioner Bernthal
(gommissioner Carr
gpmissionerRogerw
cE. M. Taylor, DEDR0
t.<f Lieberman, OE
LT( E. Murley, NRR
E L. Jordan, AE00-
dr' L. Thompson, NMSS
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c M. Troskoski, EDO
. T. Russell, RI
(N' B. Davis, RIII
LE D. Martin, RIV
L B. Martin, RV
d}. N. Berkow, NRR
g Hopkinc, NRR
(Jecords Center, INPO
Rpgion II Distribution List C
J RC Resident Inspector
Document Control Desk
State of Georgia
L.IMPELL Corporation
JTTN: Kevin Kimball
L&ary Baker, Nucleonics Week
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APPENDIX TO GEORGIA POWER COMPANY.
! V0GTLE FACILITY.
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SALP BOARD REPORT-NOS. 50-424/87-58; 50-425/87-40
, -(DATEDJANUARY'll,1988) [' ! 1 i }
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MAR 071988 -
I. Meeting Summary <
A. A meeting was held on January 19, 1988, at Vogtle plant site to
discuss the SALP Board Report for the Vogtle facility. The free
exchange of views during this meeting was beneficial. Additionally,
a photocopy of the slides that were used during the presentatign are
enclosed.
B. License Attendees: H. G. Baker, Senior Executive Vice President
P. D. Rice, Vice President, Project Director
J. P. O'Reilly, Senior Vice President, Nuclear
Operations
G. Bockhold, General Manager, Nuclear Operatiuns
L. T. Gucwa, Manager, Nuclear Safety and
Licensing
M. Howard, Manager, EP and Security
R. M. Bellamy, Plant Manager
T. V. Greene, Plant Support Manager
R. Pinson, Vice President, Construction
C. Whitney, General Manager, Project Support
C. NRC Attendees: J. Nelson Grace, Regional Administrator,
Region II (RII)
L. A. Reyes, Director, Division of Reactor
Projects (DRP), RII
E. W. Merschoff, Deputy Director, Division of
Reactor Safety, RII
V. L. Brownlee, Chief, Reactor Projects Branch 3,
DRP, RII
M. V. Sinkule, Chief, Reactor Projects
Section 3B, DRP, RII
D. R. McGuire, Chief Physical Security Section,
,
Nuclear Materials Safety and Safeguards Branch,
l Division of Radiation Safety and Safeguards
S. A. Varga, Director, Division of Reactor
Projects-I/II, NRR
l '
J. Hopkins, Project Manager Vogtle, Project
Directorate II-3, Division of Reactor Projects,
NRR
J. F. Rogge, Senior Resident Inspector
(Construction), Plant Vogtle, DRP RII
C. W. Burger, Resident Inspector, Plant Vogtle, ,
DRP, RII
II. Errata Sheet - Vogtle SALP
Pace Line Now Reads Should Read
25 10 b. Severity Level IV b. Severity Level V
violation ........ violation ........
!
Basis for change:
'
l reorganization of error l ! Note: Original page and Errata Sheet are enclosed.
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.. .. MAR 071998
2
III. License Comments
Licensee commnents dated February 15, 1988, in response to the Vogtle SALP
Board Report attached.
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25
service, revised the plant procedure which a eared to allow all
three pumps to be removed from service for seven days vice 48
hours and reinstated the shift superviso as the person in
charge of directing the fire response ef ort. Inspectors noted
that the licensee has not updated the a repriate FSAR limiting
r.ondition for operation action stateme ts in this area.
The following violations were ident ied:
a. Severity Level IV violation or failure to implement fire
protection procedures (50-4 4/87-19-03).
b. Severity Level IV viol tion for failure to properly
implement the fire pro ection evaluation for maintenance
work orders involving emoval of radiant energy shields for
instruments PT-403 a LT-459 (50-424/87-02-02).
2. Conclusion
Category: 2
3. Recommendations
Licensee manage ent attention is warranted in order to further
reduce the nu er of false alarms associated with the fire
protection sy tem.
F. Emergency Prepa dness
1. Analysis
Durin the assessment period, inspections were performed by
regi nal and resident staffs. There were five inspections
add essing implementation of the Radiological Emergency Plan and
Pr cedures, and review / assessment of licensee corrective actions
.plemented in response to improvements and incomplete items
identified during the Emergency Preparedness Appraisal conducted
in March 1986. The Annual Emergency Preparedness Exercise was
observed and evaluated by regional and resident staffs. No
Emergency Plan revisions were submitted during this period.
The annual emergency preparedness exercise disclosed no adverse
findings regarding the licensee's emergency organization and
staffing. An adequately staffed corporate emergency response
g[4 and planning organization routinely provided support to the
plant. Key positions in the corporate and plant emergency
response organizations were filled. Corporate management
t continued ,to demonstrate a strong cohJnitment to maintenance of
an effective emergency response program. Corporate management
$g, was also' directly involved in the 1987 annual emergency
preparedness exercise and followup critiques. Consistent with
.
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25
service, revised the plant procedure which appeared to allow all
three pumps to be removed from service - for seven days vice 48
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hours and reinstated the shift supervisor as the person in
charge of directing the fire response effort. Inspectors noted
that the licensee has not updated the appropriate FSAR limiting
condition for operation action statements in this area.
The following violations were identified:
a. Severity Level IV violation for failure to implement fire
protection procedures (50-424/87-19-03).
b. Severity Level V violation for failure to properly
implement the fire protection evaluation for maintenance
work orders involving removal of radiant energy shields for
instruments PT-403 and LT-459 (50-424/87-02-02).
2. Conclusion
Category: 2
3. Recommendations
Licensee management attention is warrai;ted in order to further
reduce the number of false alarms associated with the fire
protection system.
F. Emergency Preparedness
1. Analysis
During the assessment period, inspections were performed by
regional and resident staffs. There were five inspections
addressing implementation of the Radiological Emergency Plan and
Procedures, and review / assessment of licensee corrective actions
implemented in response to improvements and incomplete items
identified during the Emergency Preparedness Appraisal conducted
in March 1986. The Annual Emergency Preparedness Exercise was
observed and evaluated by regional and resident staffs. No
Emergency Plan revisions were submitted during this period.
The annual emergency preparedness exercise disclosed no adverse
findings regarding the licensee's emergency organization and
staffing. An adequately staffed corporate emergency response
and planning organization routinely provided support to the
plant. Key positions in the corporate and plan * emergency
response organizations were filled. Corporate management
continued to 'Jemonstrate a strong commitment to maintenance of
an effective emergency response program. Corporate management
was also directly involved in the 1987 annual emergency
preparedness exercise and followup critiques. Consistent with
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- i : l- UNITED STATES 1
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COMMISSION
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GE0RGIA
P0WER
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COMPAL ~~Y
OCTOBER :.', :.986 - SE??3MBER E0,1987
..
V072 ";XZ:S :. & 2
JANUARY :.9, :.988
WAYN3SB030, G30RGIA
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SALP PROGRAM OBJECTIVES
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0FFICE OF THE ADMINISTRATOR
.
Administrator J. Nelson Grace
Deputy Administrator Malcolm L. Ernst
1
' Secretary Hellan Mallettl
' 5ecretary Nancy HugheyI
_____________
__
Public Affairs Staff Regional Counsel State and Government Enforcement and Investigation
Staff Coordination Staff
Director K. Clark Reg. Counsel R. Goddard Director R. Trojanowski Director G. Jenkins
Recept. W. Bryant R. Woodruff L. Trocine B. Uryc
0. DeMiranda
G. Reid Off. Asst.
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Division of Division of Division of Radiation Division of Resource
Reacto: Projects Reactor Safety Safety and Safeguards Management and Administration
Director L. Reyes g _ Director A. Gibson G Director J. Stehr G Director R. Maley
Dep. dir. C. Hehl Dep. Dir. E. Merschoff Tech. Asst. W. Rank W
*D. Collins, Acting Directorg
* Attended Unit 2 Session only. (f
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j REACTOR PROJECTS DRANCH NO. 3
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Chief V. Brownlee 9
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, ! Secretary J. Wheeler l ! ! l ! ! ' I I t
Projects Section 3A
Projects Section 38
Chief T. Peebles Thief
'
M. 51nkule
Project Engineer
B. Bonser Project Engineer
C. Patterson
Catawba - K. Van Doorn* L. Trocine
M. Lesser
Hatch - P. Holmes-Ray *
(Sec. L. Besterfeldt) J. Menning
McGuire - W. Orders * R. Musser
R. Croteau
(Sec. E. Dyal)
D. Nelson Vogtle - H. Livermore* '
(Sec. L. Roth) J. Rooge* O
Oconee - J. Bryant*
R. Schepens
P. Skinner * C. Burger
L. Wert (Sec. D. Dorsey)
(Sec. M. Jordan)
* Senior Resident Inspector
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NRR ORGANIZATION ,
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OFFICE OF
I NUCLEAR REACTOR REGULATION
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Director Thomas E. Morley
Deputy Director James H. Snierek
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POLIC1. OEVELOPMENT.
fr ANAa.f 68S STAFF
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Director F.P. Gissesp.,
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ASSOCIATE DIRECTOR A IA OR FM
FOR PROJECTS I ION b TECHNICAL
ASSESSMENT
. j Frank Mireglie
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DIVISION OF DIVISION OF
, REACTOR PROJECTS - 1. II ENG8NEERING ND SYSTEM REACTOR sNSPECTION AND
.. , SAFEOUARDS
Director Steven A. Verge
C. h Director James G. Portlow
L. Crocker Acttag Project Director $ Deputy mrector han Grimes
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M. A. Miller Project Manager g '
j DIVISION OF DIVISION OF t
REACTOR PROJECTS fil/IV/V DfV*SION OF
'= OPERATIONAL EVENTS RADIATION PROTECTION AND
] AND SPECIAL PROJECTS '= ASSESSMENT =
- (MERGENCY PREPAREDNESS
I Director Dennie M. Crutchfiehl D6 rector .i
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C.E. Rosei Disector Frank Congst
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3. .
i i DIVISION OF *
LICENSEE PERFORMANCE ANO f'
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Director Jack W. Roe
Deputy Director J. A. Zwthi
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PERFORMANCE AXALYSIS AREAS i
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FOR OPERATING REACTORS ,
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3. VALN"EN'A.sCE
L. SURVE _ A\CE
5. RE 3R0"EC"Os
6. EVERGENCY 3RE3AREls ESS
7. SECUrY
8. OU"AGES
9. QUA_"Y 3ROGRAVS
' O. _ C EN S ,5 G AC"V " ES
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' 3. S"AFU 3 "ES" \G
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PERFCRMANCE ANALYSIS AREAS
KR CCXSTRUCTIOX SITE REACTORS
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1. S0ILS AND FOUNDATIONS
2. CONTAINMENT, SAFEW RELATED,
AND MAJOR STEEL SUPPORTS
3. PIPING SYSTEMS AND SUPPORTS
4. SAFETY RELATED COMPONENTS
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5. AUXIUARY SYSTEMS
6. ELECTRICAL EQUIPMENT AND CABLES
7. INSTRUMENTATION
8. QUAUW PROGRAMS
9. PREOPERATIONAL TESTING
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10. OTHER LICENSEE ACTMTIES
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CATEGORY 1
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REDUCED EC ATTENTKW MY BE APPROPRIATE.
l)CENSEE MANAGEMENT ATTENTION AND NVOLVEMENT
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ARE AGGRESSNE AND ORIENTED TOWARD NUCLEAR
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SAFET(; UCENSEE RESOURCES ME AMPLE AND
EFFECTNELY USED SUCH THAT A HGH LEVEL OF
PERFORMANCE WITH RESPECT TO OPERATIONAL
SAFETY OR CONSTRUCTION IS BEING ACHEVED.
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AREA PERFORMANCE
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NRC ATTEhTION S-0ULD BE
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LICEhSEE
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ARE
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LICEhSEE RESOURCES ARE ADEQUATE ~
AhD ARE REASONABLY
EFFECTIVE -
SUCH THAT SATISFACTORY
PERFORMAhCE
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EVAIATIM CRITERIA
1. MANAGEMENT INVOLVEMENT IN ASSURING QUAUT(
2. APPROACH TO RESOLUTION OF TECHNICAL ISSUES
FROM A SAFETf STANDPOINT
~3. RESPONSIVENESS TO NRC INITIATIVES
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4. ENFORCEMENT HISTORY
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5. REPORTING AND ANALYSIS OF REPORTABLE EVENTS
6. STAFF 1NG (INCLUDING MANAGEMENT)
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7. TRAINING EFFECTIVENESS AND QUAUFlCATION
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VCXC\ S VVARY
OC"0BER :., :.986 - S3?TEEBER 30, :.987
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V0GTLE 1 0 0 6 22 3
V0GTLE 2 0 0 0 10* 2 ,
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REGION 11 AVE 0 0 2 11 4
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INCLUDES ITDJS WHICH APPLY TO UNIT 1 CONSTRUCT 10N ACT
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OPERATIONS
OCTOBER PHASE 1 , 1986
910LATIONS/ OPERATING REACTOR
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NOTE 1: NATL AVG INCLUDES ALL WE PLANTS y.
NOTE 2: VOGTLE TRIP DATA FROM 4/1 -
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OCTOBER 1,1986 -
SEPTEMBER 30,1987
PERSONNEL
57.4%
OTHER 7.4% -
18.5% 16.7% [
COMPONENT FAILURE DESIGN / CONST
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SEPTEMBER 30,1987
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35.5% 22.6%
OTHER
16.1%
25.8%
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MAINTENANCE
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333 P4cmont Ace %e
Apanta Georg,a 30306
Ve:echore 404 536 785'
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Attanta Georgia 30302
Jemes P. O'Reilly
Senior vice Prescent
Nvc: ear Ooeratons
!
SL-4052
0783U
X7GJ17-V120
February 15, 1988
U. S. Nuclear Regulatory Commission
Attn: Document Control Oesk
Hashington, D. C. 20555
PLANT V0GTLE - UNIT 1
NRC DOCKET 50-424
OPERATING LICENSE NPF-68
RESPONSE TO SYSTEMATIC ASSESSMENT OF
LICENSEE PERFORMANCE
Gentlemen:
Georgia Power Company (GPC) has reviewed the information presented in
the Systematic Assessment of Licensee Performance (SALP) Report transmitted
by your letter dated January 11, 1988,
and the NRC at the Plant Vogtle site on Januaryand 19, 1988.at the meeting held betwee
He appreciate the constructive comments made in the SALP evaluation, as
well as your recognition of GPC's efforts and successes in improving our
performance. GPC also appreciates the NRC's explanation of the SALP
Board'sofevaluation
ability GPC personneland the NRC's comments at the SALP meeting regarding the
problems. to recognize, evaluate and correct operational
plants.GPC is fully committed to safe and efficient 6peration of its nuclear
He take the SALP Board recommendations seriously and will use this
information in the continuing process of improving our performance.
GPC has placed major emphasis on
security. improving plant operations and
He recognized problems in these areas during the SALP period and
implemented a number of corrective action programs. Those improvement
programs have been thoroughly discussed with thecNRC. staff. These efforts
will continue until GPC is assured that they have. achieved and maintained
high levels of performance,
c .
nn
( . ;l} '
5[) , , I "
19q .
_ _
-_ .. .. - .
. _. -
. -. -- _ -.
: .
'
Geol;gia Poner
'
U. S. Nuclear Regulatory Commission
February 15, 1988
Page Two
The GPC responses to the NRC SALP findings in each functional area are
contained in the enclosure to this letter. The initiatives identified in
our responses will be actively pursued in our continuing effort to improve
overall
plant performance, particularly in the araas of plant operations
and security.
Should
activities, you have any questions regarding this letter or Plant Vogtle
I will be pleased to discuss them with you.
Sincerely,
c/rnAA. Ol
J mes P. O'Reilly
JPO:ju
C
Enclosure: Response to SALP Report
Q
c: (see n' ext page)
I 1
emp *[ . - -
. . . *
0783U
: :
Geoi;gia Poner b
U. S. Nuclear Regulatory Commission
February 15, 1988
Page Three
c: Georola Power Comoany
Mr. P. D. Rice
Mr. G. Bockhold, Jr.
Mr. L. T. Gucwa
Mr. J. E. Swartzwelder
Mr. C. H. Hayes
GO-NORMS
Southern Comoany Services
Mr. R. A. Thomas
Mr. J. A. Bailey
Shaw. Pittman. Potts & Trowbridge
Mr. B. M. Churchill, Attorney-at-law
Troutman. Sanders. Lockerman & Ashmore
Mr. A. H. Domby, Attorney-at-Law
U. S. Nuclear Regulatory Commission
Dr. J. M. Grace, Regional Administrator
Mr. J. 8. Hopkins, licensing Project Manager, NRR (2 copies)
- Mr. J. F. Rogge, Senior Resident Inspector-Operations, Vogtle
.
1 .
~ . .
__
1 I
e
0783U
. _ .
GhorgiaPoner d
ENCLOSURE
PLANT YOGTLE - UNIT 1
NRC DOCKET 50-424
OPERATING LICENSE NPF-68
RESPONSE TO SYSTEMATIC ASSESSENT
OF LICENSEE PERFORMANCE
PLANT OPERATIONS:
GPC is aware that problems existed in the area of plant operations
during
testing. the first half of 1987 during initial operations and startup
Strong Anagement action was taken to effectively identify root
causes and to correct probl ems. While instantaneous recovery was not
accomplished, better implementation of improved programs has produced, over
a few months, greatly improved conditions. These actions are serving as a
sound foundation for long-tem, superior plant operations performance.
Some of the actions taken by GPC to improve plant operations a.e described
below.
1. gqanizational Changes
Several organizational enhancements were made to assist in the
improved implementation of operations programs. These
enhancements are associated with: the rotation of several managers
to broaden experience and technical expertise, the reassignment of
some managers, and the creation of new management positions. Some
of the positions affected by these organizational improvements
included the Plant Manager, Plant Support Manager, Chemistry and
Health Physics Manager, Security Manager, Deputy Operations
Manager, and Technical Assistants to the General Manager and Plant
Manager.
In addition, plant management was authorized to augment the plant
staff as necessary to assure that GPC goals were achieved.
Specific areas targeted for improvement, and where improvements
have been made, include the reduction of outstanding maintenance
work orders, improved problem identification and resolution, and
problem prevention. Also, the use of vendors with special nuclear
expertise was increased to facilitate lessons learned at other
,
nuclear facilities.
e *
.- .
.
0783U E-1 KWW/02-lS-88
. :
ENCLOSURE (Continued)
G.eolgia Poner
RESPONSE TO SYSTEMATIC ASSESSENT
OF LICENSEE PERFORMANCE
l
In concert with the actions outlined above, the corporate office '
l
developed a regulatory sensitivity training class which has been
presented to key managers and staff to uke them more aware of the
need to understand and pay closer attention to the relationship
between regulations and nuclear safety. This program, our
"comitment to safety" was designed to provide higher assurance on
complying with the safety intent of regulations.
2. _Special Teams or Comittees
A Trip Reduction Connittee was established to oversee the Trip i
Reduction Program. The key elements of the Trip Reduction Program
are the post-trip review team, industry experience reviews and
failure analyses. The Independent Safety Engineering Group was
instrumental in developing and integrating the various elements
into the overall program which includes comprehensive root cause
evaluations.
A Special Startup Detail, in addition to the normal crew, was
created to ensure that the most experienced operators, engineers,
and r.anagers are used during plant startups. These experts are
assigned to supplement positions in the shift organization such
as: reviewing critical data, ensuring correctness of estimated
critical rod position calculations, checking valve position
alignments, and being available to respond to the needs of the
operating staff as mechanical, electrical, or instrumentation and
control issues arise. - This special detail is stationed prior to
reactor startup and remains on watch through completion of
critical evolutions such as the transition to main feedwater
system operation and in the initial loading of the turbine
generator.
l
A Trip Response Team was also established to evaluate each trip in
l an organized and structured fashion. The team is generally
cogosed of the Plant Manager or his designee; die Engineering
Superintendent; and representatives from 0 pre ra tions, Nuclear
Safety and Compliance, Independent Safety Er]ineering Group, and,
as appropriate, Quality As surance, and rr.presentatives from
Nuclear Steam Supply System and Architect Engineer. As a part of
the post trip evaluation, the root t.ause of the event leading to
the trip is detennined. The root cause detennination process is
based on a number of management techniques most appropriate for
' the situation, including the Management Oversi.ght and Risk Tree
approach, Xepner Tregoe methods, and Casual. Factors Charting. A
determination relative to The Human Perfonnance Evaluation System
is also included.
0783U E-2 KW/02-15-88
, --- .
.- - - _ _ - - _ - . - . _ . _ _ - - _ . . _ _ _ _ _ - _ . .
. . .
G orgiaPoner
ENCLOSURE (Continued)
RESPONSE TO SYSTEMATIC ASSESSMENT
OF LICENSEE PERFORMANCE
An Operations Management Council has recently been established to
oversee and evaluate operational activities including the work
performed by the Plant Review Board.
3. Other Controls and Procrams
Biweekly operational meetings
communications and staff integration.
were initiated to improve
These meetings allowed the-
Sr. Vice President, and the senior corporate managers, to meet
with the plant General Manager and his senior technical staff to
review current problems and plans for resolution.
In mid-1987 two important programs were initiated to achieve
greater benefit from lessons learned from nuclear
The Industry Events Analysis and Resolution Program,and plant
theevents.
Plant
Events
togetherAnalysis and Resolution Program were developed.
the various aspects of event analysis, Each pulls
including
applicable procedures, and provides overall company guidance.
,
A third program, the Positive Valve and Breaker Control Program,
was initiated to establish control to ensure that plant valves and
breakers are in, and remain in their
proper position. A
multi-disciplined
the program. review team was used to develop and implement
The objectives were: (1) review Plant Vogtle events
in which mispositioned valves or breakers played a significant
role, (2) determine the root causes of the valve or breaker
mi spositioning, and (3) provide detailed
achieve improved controls. recommendations to
The review assisted plant management
in formulating corrective actions to reduce the likelihood of
future valve and breaker mispositioning.
i
The theme of teamwork was integrated into all programs. As an
I example,
now held aevery largerwork and more
da aggressive plan of the day meeting is
with working level personnel from
Maintenance, Operations, y Engineering,
Scheduling, and Health
- Physics and Chemistry Departments to discuss and plan the next
. day's work activities. This allows for smooth integration of all
l
work activities and higher completion rates for scheduled work
l functions. Also, engineering personnel were required to become l ! more involved in plant trip evaluations and recoveries through
mandatory participation on Trip Response Teams. Also, key
personnel from co
Reduction Program. gnizant departments'participa 2~-~ ted in the Trip
l
0783U E-3 KWH/02-15-88
l
---- - _ _ - _ _ __ - - --_ _ - _- - ___ -
_ - .-_
' *
.
G.eorgia Poner ENCLOSURE (Continued)
RESPONSE TO SYSTEMATIC ASSESSENT >
0F LICENSEE PERFORMANCE l
!
RADIOLOGICAL CONTROLS
While GPC does not take issue with the SALP Board's evaluation of
Health Physics and Chemistry activities, some of the coments made do not
seem appropriate or in balance.
The HP programs, did suffer from staffing
questions, but established goal s for personnel exposure, contamination
events, contaminated areas and volume of radioactive waste generated were
achieved. The staffing issue has been addressed and Plant Yogtle is near
completing the filling of 34 new positions. The SALP report also addressed
NRC concerns regarding the Biological Shield Survey
adequacy, the
qualification and experience of those staff members conducting the survey,
and the use of NSSS vendor experience in such surveys. We wish to note
that this item is not fully resolved. This subject has been discuss .d
several times with Region !! staff and Region supervision and several
interface issues have been raised and resolved. GPC still maintains that
the startup survey was complete and acceptable and that we met NRC
requirements.
In sunina ry, Yogtle experienced problems in the Chemistry and Health
Physics areas during startup and initial operation. GPC took prompt action
to address the root causes of these problems, including assigrunent of the
corporate Radiological Safety Manager to the plant staff. We believe our
current performance will warrant an improved rating during this current
SALP period.
MAINTENANCE
,
GPC appreciates the recognition of our maintenance activities by the
I NRC SALP Board as indicated by the Category I rating. The Board's analysis
of the maintenance area will be carefully evaluated. While we believe the
few identified weaknesses have been corrected, a thorough reassessment will
be made wi th special attention to your recomendation regarding the
prioritizing of open saintenance work orders for items related to safety.
SURVEILLANCE
The NU Plant Yogtle SALP Board found that, in general, surveillance
testing was conducted by personnel who were knowledgeable of the system
and/or component being tested and that tests were performed without
incident. However, some weaknesses were identified dealing primarily with
the compatibility of some surveillance procedures and the corresponding
Technical Specification requirements. As noted in the SALP report,
l '
effective corrective action was taken to resolve 11dentified deficiencies
and GPC management and Quality Assurance Group involvement was prompt in
addressing surveillance relate <1 problems.
l l l , 07830 E.4 l
KW/02-15-88
1 l . - - - - . - - . - - - --- - - - --------- ^ -^ ~
G$orgia Power d
ENCLOSURE (Continued)
RESPONSE TO SYSTEMATIC ASSESSMENT
OF LICENSEE PERFORMANCE
that GPC recognizes the importance of regular testing of plant equipment '
is maintained in a standby mode to provide maximum assurance of
operations in the event it is called upon to perform its design function.
Corporate and plant personnel will i
surveillance testing activities. continue to work together to improve i
FIRE PROTECTION
The SALP Report listed two Severity Level IV violations that were cited
by the NRC during the SALP evaluation period. Violation "b" was downgraded
to a Severity level V as documented in an NRC letter from Mr. Reyes to Mr.
O'Reilly dated April 1, 1987. Corrective actions and actions to prevent
recurrence were taken as outlined in the GPC response to Inspection Report
50-424/87-02.
understood by GPC. The importance of the fire protection system is fully
He recognize that certain aspects of fire protection
have been identified that need to be improved. The appropriate level of
attention is being given to these conditions and that level of attention
will continue.
EMERGENCY PREPARE 0 NESS
The SALP Board assigned a rating of Category 1 for emergency
preparedness for the second consecutive period. This rating recognized a
strong program that has been effectively implemented. GPC appreciates this
NRC recognition of good performance by dedicated personnel functioning as a
team. GPC will strive to maintain the high standard demonstrated in this
functional area.
SECURITY
The SALP Board rating for security at Plant Vogtle stated that serious
problems existed during the early part of the SALP evaluation period. GPC
agrees with the assessment. GPC management realizes that they may not have
been as prompt as they should have been in recognizing the seriousness of
security deficiencies. While the NRC identl~fied a pattern of weaknesses
during preliminary plant operations, we wish .to note that no actual
security hazard occurred as a result of those weaknesses.
Inadequate management attention to the security program was the major
contributor to each of the identified problems. This was attributed
! primarily to an initial lack of nuclear management experience in the
security area. The inexperience factor was- Emplified by management's
i failure to include physical security preparedness in our Readiness Review
program for Plant Vogtle Unit 1. To help preclude similar problems from
recurring at Plant Vogtle Unit 2, physical security was made a significant
part of the readiness review program for Unit 2.
0783U E-S KHH/02-15-88
l
G[orgia Poner d.
ENCLOSURE (Continued)
RESPONSE TO SYSTEMATIC ASSESSMENT
OF LICENSEE PEEORMANCE
Hith the issuance of the operating license in January 1987, the need
for full operational capability of the Vogtle Security Department personnel
and security related equipment was immediate.
deficiencies either unidentified or In regard to equipment,
apparent. underestimated became clearly
In order to increase the reliability of this equipment, GPC
address problems.force of vendors, engineers, and security specialists to
initiated a task
force mernbers experienced in construction security were im
to the rigors and details required in an operating nuclear facility. Due
to managemerit's failure to fully recognize problems in training, testing,
and procedure
acceptable levels.adherence; security personnel performance was not up to
than the hardware
This personnel
problem.
problem was more difficult to address
However, the following actions were
successfully taken:
1. The entire security training staff was replaced
nuclear-experienced personnel, with
and responsibility for security
training was moved from site training control to security control;
2. Security procedure training was enhanced;
3.
Approximately 20 management, supervisory, response, and training
personnel experienced
the security staff; at operating nuclear plants were hired for
4.
Forty new GPC nuclear security officers were recruited, hired and
trained;
5.
Absenteelse rules were consistently applied and enforced; and
6. Corporate and site management, including senior executive
management, held discussions with the entire security force and
received and resolved concerns.
Security administration also did not meet our standards. The following
actions were taken to correct this problem.
1.
A corporate nuclear security coordinator, whose primary expertise
is in administration, was assigned to Plant Vogtle to implement
enhanced administrative processes, and to get the existing ones on
track and working properly, -
3 -
2. An adtrinistrative specialist was assigned to each shift to
coordinate the preparation of reports and records; and
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RESPONSE TO SYSTEMATIC ASSESSENT
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3. Administrative procedures were strengthened to assure that records
and reports were being properly handled.
GPC is fully committed to compliance with all NRC requirements. It is
expected that the level of performance in the area of security will
continue to improve during the current SALP period.
QUALITY PROGRAMS AND ADNINISTRATIVE CONTROLS
AFFECTING QUALITY
GPC appreciates SALP Board coments in the area of Quality Programs.
We will carefully evaluate your recomendation to determine how best to
provide increased management support to ensure that QA audit findings are
promptly and properly resolved. GPC takes quality assurance seriously. We
are fully comitted to achieving the highest level of perfomance and have
developed management supported programs to assure both quality perfomance
and timely, effective corrective action in response to quality assurance
findings.
LICENSING ACTIVITIES
The SALP Board noted a nucter of strengths and weaknesses associated
with Itcensing activities. GPC appreciates NRC recognition of some of our
good performance as well as constructive criticism in other t.reas. We are
in general agreement with your assessment, but we wish to clarify a few of
your observations in the interest of better cosuunications. This is
important in that GPC places high priority on responsiveness to NRC
recomendations.
With regard to your reference to inadequate GPC management involvement
relative to corporate and site organizations, SPC acknowledges that several
revisions to the FSAR concerning corporate and site organizations were made
close to Unit I licensing. The issue is timing of the organizational
changes. These revisions, in part reflected an expansion of the corporate
organization in preparation for Vogtle operation. Nuclear Operations
general office staffing increased approximately 40% during the SALP rating
period. The organization changes were intended to assure the highest level
of competence in the management and technical support of Plants Yogtle and
Ha tch. GPC regrets the additional review burden placed on the Staff by
these revisions. We strongly believe that the net affect of the changes is
an enhancement of plant safety. While the FSAR revisions did contain some
errors, they were few in number, were minor, and were promptly carrected.
3 .- _..
Regarding insufficient management involvement -in - the design of the
spent fuel racks referenced on page 33, we do believe that the information
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ENCLOSURE (Continued)
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submitted by GPC compiled with the applicable NRC guidance and addressed
NRC requirements and concerns known to GPC at the time of submittal. The
information was prepared by licensing personnel
experienced in the
licensing of spent
spent fuel racks at Plants Farley and Hatch.
fuel racks having participated in the licensing of the
well in advance of the date for which approval The was
information
needed.was submitted
The NRC
questions on seismic design
resulting from the Diablo Canyon review. GPC promptly addressed of the racks represented new issues apparently
questions received. all
Only minor revisions to the initially submitted
information were necessary as a result of NRC questions.
associated With regard with tothethe Fuel delayed submittal in response to a staff request
Handling Building Post-accident Ventilation
Actuation System referenced on pages 34 and 35, the discrepancy in the
Technical Specifications noted by the staff did not represent an imediate
safety concern; and the revision was not requested by a specific date.
GPC,
revision. therefore, did not place the highest priority on processing the
incorporatedIn fact, the revision was held for some time so that it could be
into another Technical Specification change request. GPC
makes every effort to meet submittal deadlines; however, we were not
informed of any urgency associated with this issue and no deadline was set.
IRAINING AND OUALIFICATION EFFECTIVENEM
GPC appreciates the SALP Board's
l
performance in the area of Training and Qualificationrecognition of our high level o
indicated by a Category I rating. This performance level Effectiveness as
l was attained
- through dedication and a concerted effort of all individuals involved with
l
the training program plus a strong management comitment of resources and
staffing.
'
The Category I rating is a source of great pride and we are
confident that the same level of effort will continue in the future.
l l
PRE 0PERATIONAL TESTING
l
GPC recognizes that some documentation. weaknesses
I associated with
preoperational
test program. testing existed during the later part of the preoperational
However, we are disappointed that the SALP Board or NRC in
general perceived those conditions and GPC actions to be unresponsive to
NRC concerns. GPC may not always agree with NRC findings, but we
diligently strive to be responsive to concerns in a timely manner. Some
preoperational tests were delayed because of ttle. difficulty associated with
performance of the tests without nuclear heat. .' Re also wish.to note that
the preoperational test staff exercised considerable restraint to schedule
pressure particularity during the ESFAS testing, always assuring that
safety and quality were given first priority. Heaknesses and difficulties
identified during Unit I testing will be evaluated and the lessons learned
will be used to improve the preoperational testing program for Unit 2.
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STARTUP TESTING
GPC agrees with the SALP Board rating in this functional area. The NRC
analysis is appreciated. The frequency of reactor trips is addressed in
the operations section of this enclosure. The problems encountered during
startup testing
management were quite visible to top management and received top level
attention.
Several important lessons were learned that will
contribute to a more efficient startup test program for Vogtle Unit 2.
.
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