ML20149H066
| ML20149H066 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/18/1997 |
| From: | Mccoy C SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-424-97-05, 50-424-97-5, 50-425-97-05, 50-425-97-5, LVC-1068-A, NUDOCS 9707240197 | |
| Download: ML20149H066 (6) | |
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C K.McCoy Southern Nucl:ar Vice President Operating Company,Inc.
Vogtle Project 40 Inverness Center Parkway i
P.O. Box 1295 l
Birmingham, Alabama 35201 Tel 205.992.7122 '.
l Fax 205.992.0403 July 18, 1997 Energy toServe YourWorld" Docket No.
50-424
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50-425 LCV-1068-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; 425/97-05, that concerns the inspection conducted from April 27, through May 31,1997. 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. McCoy CKM/CTT/afs
Enclosure:
Reply to NOV 50-424;425/ 97-05 cc: Southern Nuclear Operatina Company d'I Mr. J. B. Beasley, Jr.
Mr. M. Sheibani NORMS i
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U. S. Nuclear Regulatory Commission Mr. L. A. Reyes, Regional Administrator Mr. L. L. Wheeler, Senior Project Manager, NRR Mr. C. R. Ogle, Senior Resident Inspector, Vogtle gg gg 9707240197 97o71g -
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ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425 / 97-05 VIOLATION A. (50-424:425 / 97-05-0l)
The following is a transcription of violation A as cited in the Notice of Violation (NOV):
"During an Nuclear Regulatory commission (NRC) inspection conducted April 27,1997, a
through May 31,1997, 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 (Code Of Federal Regulation) Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures be established to ensure that conditions adverse to quality are promptly identified and corrected.
Contrary to the above, during a containment pressure release on April 6,1997, anomalous behavior of 2I.-7777, Unit 2 Containment South. Sump Level, was not detected or corrected. Subsequently, on May 22,1997, the licensee determined that the behavior of the transmitter indicated that transmitter calibration or replacement was required.
This is a Severity Level IV violation (Supplement I). This violation is applicable to Unit 2 only."
RESPONSE TO VIOLATION A. (50-424:425 / 97-05-01)
Admission or Denial of the Violation:
This violation occurred as stated in the notice of violation.
Reason for the Violation:
Previous to April 6,1997, VEGP Units 1 and 2 experienced similar occurrences with anomalous responses for this type of transmitter. As a result of these previous occurrences, in 1996 an investigation determined that the transmitters for Units 1 and 2 would be replaced with those of a ditTerent design. Also, as part of the investigation, an informal process was formed with operations and engineering support personnel to review transmitter responses during containment venting. However, personnel failed to review the anomalous responses of 2LT-7777 on April 6, 1997, hence an evaluation was not performed to determine the appropriate corrective action.
The failure of operations personnel to promptly recognize the anomalous responses of 2LT-7777 subsequent to a containment pressure release on April 6,1997, was due in part to a lack of procedural guidance to specifically require checks of the instmment sump levels when changing containment pressure during routine venting. Additionally, operations personnel were not sufTiciently sensitive to the anomalous responses of the transmitters. Furthermore, operations
ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 i
REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425 / 97-05 personnel did not have guidance to determine an acceptable shin in transmitter level during containment venting.
Corrective Steps Which Have Been Taken and the Results Achieved:
1.
The defective transmitter for 2LT-7777 was replaced with a new one.
2.
Engineering Support monitoring has been established for the containment sump transmitter level shins.
3.
Operations department procedures, 13125-1/2, " Containment Purge System," have been revised to provide specific guidance for implementation of appropriate actions when transmitters exhibit anomalous responses.
Corrective Steps Which Will Be Taken to Avoid Further Violations:
The Units 1 and 2 transmitters will be replaced with a transmitter of a different design during the 2R6 refueling outage, scheduled for the spring of 1998, and during the IR8 refueling outage, scheduled for the spring of 1999, Date When Full Comoliance Will Be Achieved:
d Full compliance was achieved on May 1,1997, when transmitter 2LT-7777 was replaced and returned to an operable status.
l VIOLATION B. (50-424:425 / 97-05-02)
The following is a transcription of violation B as cited in the Notice of Violation (NOV):
"B.
10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality be prescribed and accomplished in accordance with procedures appropriate to the circumstances.
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l Procedure 10008-C, " Recording Limiting Conditions for Operation," Revision 19, I
was provided to prescribe the method for recording the failure to meet a Technical Specification (TS) Limiting Condition for Operation (LCO) or Technical Requirement (TR). This procedure required completion of a LCO/TR Status Sheet and LCO/TR Status Log entry prior to the end of shift if entry into an action statement is required.
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ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION l
NRC INSPECTION REPORTS 50-424:425 / 97-05 l
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Contrary to the above, on April 28,1997, following discovery of a potentially l
inoperable Unit 2 Containment South Sump Level Instrument,2L-7777, the l
LCO/TR Status Sheet did not document entry into all applicable LCOs.
Specifically, the status sheet ailed to identify TS 3.3.3, Post Accident Monitoring.
f This is a Severity Level IV violation (Supplement I). This violation is applicable to Unit 2 only."
RESPONSE TO VIOLATION B. (50-424:425 / 97-05-02)
Admission or Denial of the Violation:
This violation occurred as stated in the notice of violation.
Reason for the Violation:
The operations unit shin supervisor and shin superintendent failed to reference Technical Specifications 3.3.3, Post Accident Monitoring, on the Limiting Condition for Operations (LCO).
This administrative oversight was the result of personnel error.
Although Technical Specifications 3.3.3 was not referenced on the LCO Status Shect, actions taken in accordance with Technical Specifications 3.4.15 ensured compliance with the Technical Specifications.
Corrective Steps Which Have Been Taken and the Results Achieved:
l The unit shin supervisor and shin superintendent were counseled on the importance of referencing all applicable Technical Specifications and ensuring all applicable actions are listed on the LCO Status Sheet.
Corrective Stens Which Will Be Taken to Avoid Further Violations:
No additional corrective actions are planned at this time.
Date When Full Compliance Will Be Achieved:
l Full compliance was achieved on May 1,1997, when transmitter 2LT-7777 was returned to an operable status.
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ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425 / 97-05 l
VIOLATION C. (50-424:425 / 97-05-07)
The following is a transcription of violation C as cited in the Notice of Violation (NOV):
"C TS Section 5.4.1.d, Fire Protection Program, required that written procedures be implemented covering fire protection program implementation.
Paragraph 2.G of the operating license for Units 1 and 2 required that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report (UFSAR).
UFSAR Table 9.5.1-10, Section 5.4.1, required that each of the fire hose stations given in Table 9.5.1-10c be demonstrated operable at least once per 31 days by i
visual inspection of the fire hose stations accessible during plant operation.
UFSAR Table 9.5.1-10c, in part, lists fire hose stations in the Nuclear Service 4
Cooling Water (NSCW) Tower tunnels ITSA,1TSB, 2T5A, and 2T5B.
Procedure 29100-C," Portable Fire Extinguishers and Fire Hose Stations Visual Inspections," Revision 8, implements the 31-day surveillance performance test required by UFSAR Table 9.5.1-10. This procedure required visual inspections of the fire hose stations, including fire extinguishers contained therein, located in the Unit I and 2 NSCW tower tunnels.
Contrary to the above, the time between performances of Procedure 29100-C, for i
visual inspection of fire extinguishers and fire hose stations, exceeded 31 days.
Specifically, between April 3,1997, and May 13,1997, the surveillance performance interval was 40 days.
j This is a Severity Level IV violation (Supplement I)."
RESPONSE TO VIOLATION C. (50-424:425 / 97-05-01)
Admission or Denial of the Violation:
l This violation occurred as stated in the notice of violation.
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ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425 / 97-05 Reason for the Violation:
In an attempt to coordinate the annual fire extinguisher surveillance with the regularly scheduled monthly fire extinguisher / hose station surveillance, the 31 day requirement to complete the monthly surveillance was exceeded. This was due to an administrative oversight by the individual reviewing the surveillance checklists. The individual reviewing the surveillance checklists made an incorrect assumption that all of the checklists had been completed, when in fact some had not.
Corrective Steps Which Have Been Taken and the Results Achieved:
1.
The monthly surveillance was completed with no problems noted.
2.
Individuals in the Fire Protection Team were briefed on this violation.
3.
Procedures 29100-C," Portable Fire Extinguisher and Fire Hose Station Visual Inspection," and 29134-C, " Portable Fire Extinguisher Annual Surveillance," have been revised to provide better coordination of the performance of annual and monthly surveillances.
Corrective Steps Which Will Be Taken to Avoid Further Violations:
No additional corrective actions are planned at this time.
Date When Full Compliance Will Be Achieved:
Full compliance was achieved on May 13,1997, when the monthly surveillance was performed.
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