ML20149M631
| ML20149M631 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 02/19/1988 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| SL-4070, NUDOCS 8802260204 | |
| Download: ML20149M631 (4) | |
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Georgia Power Company 333 Piem Annue
- Attanta, Georg's 30308 Telephone 404 5264526 MGng AM ess:
Post off<e Box 4545 Attanta, Georg a 30302 Georgia Power L.T Gucwa fN Ktd COEC S/ mrv 71 Manager NucMar Safety and Lkensing SL-4070 0754m X7GJ17-V120 February 19, 1988 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D.C.
20555 PLANT V0GTLE - UNIT 1 4
NRC DOCKET 50-424 OPERATING LICENSE NPF-68 j
REPLY TO A NOTICE OF VIOLATIOR.
Gentlemen:
In accordance with the provisions of 10 CFR 2.201, Georgia Power Company (GPC) submits the enclosed information in response to NRC Inspection Report 50-424/87-68 which concerns the inspection conducted by Mr. P. G. Stoddart of the NRC Region II staff on December 7-11, 1987.
A copy of this response is being provided to the NRC Region II office for
- review, i
In the enclosure, transcription of the NRC violation precedes GPC's response.
Should you have any questions in this regard, please contact this office at any time.
Sincerely,
/7 &
L. T. Gucwa i
JAE/Im i
Enclosure:
1.
Violation 87-68-01 and GPC Response c:
(see next page)
I )
F k
Georgia Power n U. S. Nuclear Regulatory Commission February 19, 1988 Page Two c: Georaia Power Cemoany Hr. G. F. Head Mr. P. D. Rice Mr. G. Bockhold, Jr.
Mr. C. H. Hayes Mr. E. H. Howard Mr. J. E. Swartzwelder GO-NORMS Southern Comoany Servitel Mr. R. A. Thomas Mr. J. A. Bailey Shaw. Pittman. Potts & Trowbridgg Mr. B. H. Churchill, Attorney-at-Law Troutman. Sanders. Lockerman & Ashmorg Mr. A. H. Domby, Attorney-at-Law U. S. Nuclear Regulatory Commission Dr. J. N. Grace, Regional Administrator Mr. J. B. Hopkins Licensing Project Manager, NRR (2 copies)
Mr. J. F. Rogge, Senior Resident Inspector-0perations, Vogtle 0754m en
~
1 Georgia Power A l
ENCLOSURE PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 NRC NOTICE OF VIOLATION 87-68-01 AND GPC RESPONSE i
VIOLATION 50-424/87-68-01 i
"Technical Specification 6.7.1.b requires the licensee to implement I
established procedures.
Chemistry proceduras 35611-C, Remote Analysis with the Post Accident Sampling System, 35625-C, Calibration of the Post Accident Sampling System Dissolved Oxygen
- Monitor, and 35629-C, Recalibration of the Post Accident System Ion Chromatograph, require that certain tests be performed at monthly intervals but not to exceeJ 45 days.
Contrary to the above, a review of licensee records indicated that required procedural actions had not been performed for periods in excess of 45 days.
These were (a) Procedure 35611-C, system testing was not performed between June 15, 1987 and August 17, 1987, an interval of two i
months plus two days; (b) Procedure 35625-C, calibration of the dissolved l
oxygen monitor was not performed between March 10, 1987 and July 14, 1987, an interval of four months plus four days; and (c) Procedure 35629-C, recalibration of the ion chromatograph was not performed between 3
June 10, 1987 and August 16, 1987, an interval of two months plus six days.
This is a Severity Level V violation (Supplement IV)."
RESPONSE TO VIOLATION 50-424/87-68-01 Admission or denial of alleged violation:
The events occurred as stated with regard to calibration procedures 35625-C, Rev. O and 35629-C, Rev. O.
However, in the case of procedure 35611-C, there is no procedural requirement to perform this analytical procedure on a monthly basis.
Procedure 35611-C provides instruction for performing remote sampling using the Post Accident Sampling System (PASS) under normal conditions and, thus, has no requirement specified therein for testing the system on a monthly basis.
It is believed that procedure 35611-C should not have been cited in the Notice of Violation and that the provisions of NRC NUREG-0737,Section II.B.3 do not apply to that procedure.
0754m 2-1 02/19/88 SL-4070 m
k Georgia Power h ENCLOSURE (Continued)
EC NOTICE OF VIOLATION 87-68-01 AND GPC RESPONSE Reason for the violation:
The cause of this violation was lack of attention to detail in the maintenance of the surveillance schedules.
Corrective steos which have been taken and the results achieved:
The following corrective actions were taken:
- 1) The position of PASS Specialist, in the Health Physics & Chemistry Department, was filled in January, 1988.
The PASS Specialist will oversee maintenance of the PASS program including surveillance requirements.
- 2) Procedure 31010-C, Rev.
6, "Process Analyzer Calibration and Scheduling Program," was revised to include monthly or semi-annual calibration frequencies, as appropriate, for PASS.
This procedure references procedures 35625-C and 35629-C.
- 3) The existing surveillance scheduling system was augmented by using "tickler cards".
The scope of implementation includes surveillance analysis as required by procedure 30025-C, Rev. 6, "Periodic Analysis Scheduling Program."
Corrective steos which will be taken to avoid further violations:
The corrective actions described above should preclude further violations concerning calibration of PASS components.
Date when full comoliance will be achieved:
Full compliance had been maintained for a period of several months prior to the NRC inspection.
It should be noted that at the time of the NRC inspection, no PASS instruments were out of calibration.
Full compliance with procedure 35625-C was achieved as of November 24, 1987.
Full compliance with procedure 35629-C was achieved as of November 27, 1987.
0754m E-2 02/19/88 SL-4070
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