ML20153B425
| ML20153B425 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/14/1988 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| SL-4278, NUDOCS 8803220134 | |
| Download: ML20153B425 (8) | |
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Gectg:a Power C+.mpany 333 Pedmont Avenue Atlanta, Gsorga 30308 Te' phone 404 5?c 6526 4
r Ott ox 545 Ar.anta, Georg:a 30'92 Georgia Power L.T.Gucwa the southem e/ccfre system Managet Nuclear Safety and Lcensng SL-4278 0813m X7GJ17-V120 March 14, 1988 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D.C.
20555 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 REPLY TO A NOTICE OF VIOLATION 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 50-424/87-69 which concerns the inspection conducted by Mr. R. Moore and others from the NRC Region II staff on November 30 -
December 4 December 14-18, 1987 and January 5, 1988.
A copy of this response is being provided to the NRC Region II office for review.
In each of the enclosures, transcription of the hRC violation precedes GPC's response.
Should there be any questions in this regard, please contact this office at any time.
Sincerely, g gi_m L. T. Gucwa JAE/im
Enclosures:
1.
Violation 87-69-01 and GPC Response 2.
Violation 87-69-02 and GPC Response 3.
Violation 87-69-03 and GPC Response c:
(see next page) h 8803220134 080314 PDR ADOCK 05000424 O
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GeorgiaPower A U. S. Nuclear Regulatory Commission March 14, 1988 Page Two c: Georgia Power Comoany Mr. P. D. Rice Mr. G. Bockhold, Jr.
G0-NORMS U. S. Nuclear Reaulatory Commission Dr. J. N. Grace, Regional Administrator Mr. J. B. Hopkins, Licensing Project Manager, NRR (2 copies)
Mr. J. F. Rogge, Senior Resident Inspector-Operations, Vogtle i
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GeorgiaPower d ENCLOSURE 1 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 NRC NOTICE OF VIOLATION 87-69-01 AND GPC RESPONSE VIOLATION 50-424/87-69-01 "10 CFR 50.49(a) requires that each holder of a license establish a program for. qualifying electric equipment.
10 CFR 50.49(b)(3) lists certain post-accident monitoring system equipment as being important to safety.
10 CFR 50.49 paragraphs (f), (k), and (j), NUREG-0588, and IEEE 323-1974 require that:
1.
This equipment be installed in a manner and position equivalent to the as tested /as analyzed condition and; 2.
Documentation be maintained to verify the equipment is qualified for its application for the entire period during which the covered item is installed in the Nuclear Power Plant.
Contrary to the
- above, a
Core Exit Thermocouple Junction Box (post-accident monitoring instrumentation) in containment was left in an unqualified environmental condition following system maintenance.
This condition was identified on April 13, 1987, on HH0 18704972 which stated that no documentation could be located to verify installation of the environmental seal for the junction box.
The condition was not corrected until October 10, 1987, following six months of power operation.
This is a Severity Level IV violation (Supplement I)."
RESPONSE TO VIOLATION 50-424/87-69-Q1 Admission or denial of alleaed violation:
4 The violation occurred as stated in that both the Train "A" and Train "B" core exit thermocouple junction boxes were in an unqualified condition until October 18, 1987 when the boxes were sealed.
Reason for the violation:
The violation occurred due to personnel error.
Although the unsealed junction boxes were identified as deficiencies, the significance of the unsealed condition in terms of operability of the core exit thermocouples was not recognized.
Consequently, the applicable Technical Specification 0813m El-1 03/14/88 SL-4278
GeorgiaPower A ENCLOSURE 1 (Continued)
NRC NOTICE OF VIOLATION 87-69-01 AND GPC RESPONSE Limiting Condition of Operation (Technical Specification section 3.3.3.6, Table 3.3-8, Action Statement 30.C) was not entered and the action statement time interval was exceeded.
Corrective steos which have been taken and the results achieved:
Corrective actions include the following:
- 1) The core exit thermocouple junction boxes were sealed during the October, 1987 outage, and
- 2) A training program, "Commitment to Safety,"
was conducted for appropriate plant operations personnel and discussed operability i
determinations.
This training program stressed the need for on-shift personnel to solicit engineering support to perform operability determinations whenever on-shift personnel were unable to supply the appropriate level of evaluation.
Corrective steos which will be taken to avoid further violations:
In addition to the aforementioned corrective actions, the Vogtle Unit 2 core exit thermocouple junction boxes will be verified to be properly sealed prior to fuel load on Vogtle Unit 2.
Date when full como11ance will be achieved:
Full compliance was achieved on October 18, 1987 when the boxes were sealed.
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GeorgiaPower d ENCLOSURE 2 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 i
NRC NOTICE OF VIOLATION 87-69-02 AND GPC RESPONSE VIOLATION 50-424/87-69-02 "10 CFR 50 Appendix B Criterion V, and the licensee's accepted QA program, Final Safety Analysis Report (FSAR) Section 17.2.5, require that activities affecting quality shall be prescribed by documented procedures and shall be accomplished in accordance with these procedures.
The licensee Deficiency Control Procedure, 00150-C, Revision 6. Sections 1 and 1.2, require that conditions adverse to quality 5e identified and processed per this procedure, Contrary to the above, problems involving main steam, chemical and volume control, main feed, pow?r operated relief valves, and post-accident monitoring instrumentation systems were not identified as conditions adverse to quality.
They were processed via the maintenance work order program rather than the approved deficiency control program.
The specific work orders are:
HWO 18705430 MHO 18706938 MHO 18701732 MHO 18702035 MHO 18704972 This is a Severity Level V violation (Supplement I)."
RESPONSE TO VIOLATION 50-424/87-69-02 Admission ur denial of alleged violation:
The violation occurred as stated.
Reason for the violation:
failure to follow procedures is attributed as the cause of the violation.
Procedure 00150-C, "Deficiency Control,"
specifically requires that a Deficiency Card (DC) be initiated when conditions exist that are adverse to quality.
Plant personnel identified the deficiencies through the Maintenance Work Order (HW0) program rather than through the use of DCs as required by Procedure 00150-C.
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I Georgialbwer A ENCLOSURE 2 (Continued)
HRC NOTICE OF VIOLATION 87-69-02 AND GPC RESPONSE Corrective steos which were taken and the results achieved:
Corrective actions include the following:
- 1) Training was provided to Operations, Nuclear Safety and Compliance,
- Training, and selected ' management and supervisory personnel on regulatory sensitivity and the importance of identi fying and reporting deficiencies.
- 2) A Hork Planning Group (HPG) memorandum was i; sued on December 17, 1987 with instruction to WPG personnel on initiating a DC in the event that a deficient condition is documented in an MH0, and
- 3) The Engineering Support Department reviewed the safety-related HH0s for deficiencies.
This review was completed on December 17, 1987.
Deficiency Cards were generated for MH0s documenting a deficient condition.
None of the deficiencies were determined to be significant.
Corrective steos which will be taken to avoid _fprther violations:
t The aforementioned corrective actions are expected to preclude further violations.
Date when full comoliance will be achieved:
Full compliance was achieved after Engineering Support performed a review of the open safety-related MW0s for deficiencies.
As stated earlier, DCs were initiated and none of the deficiencies were determined to be significant.
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GeorgiaPower A ENCLOSURE 3 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 NRC NOTICE OF VIOLATION 87-69-03 AND GPC RESPONSE VIOLATION 50-424/87-69-03 "10 CFR 50 Appendix B Criterion XI, and the licensee's accepted QA program, FSAR Section 17.2.11, collectively require that a test program be established to assure that all testing required to demonstrate that systems will perform satisfactorily in service is performed in accordance with written test procedures.
Additionally, Procedure SUM-22, Maintenance Hork Orders, Revision 16, Section 6.7.1, states that where applicable (during the preoperational phase),
a functional test is required after maintenance work to verify that, systems are capable of performing their intended function {
Contrary to the above, following preoperational modifications to the,
turbine driven auxiliary feedwater (AFH) pump' turbine ' speed indication circuit under HHO 10620139 a functional test was not performed to verify that this system would perform satisfactorily in service.
Thec modification placed an oversized resistor in the circuit which resulted in 'a loss of AFH turbine tpeed indication in the control room and shutbown Panel C.
This condition was discovered three months later and was not repaired until after two nonths of power operations.
This is a Severity Level V violation (Supplement I)."
l RESPONSE TO VIOLAT.10N 50 424/87-69-03 Admission or denial of alleced violation 1 The violation occurred as stated.,
Reason for the viol & tion:
Personnel error is attributed as the cause of the violation in that the Test Supervisor failed to obtain the concurrence of the Lead Test Supervisor for waiver of the fune'cional test following completion of preoperational test.
In addition, the Hork Planning Group failed to verify "Adequacy and Completeness of Documentation" per SUH-u., 6.9.1.2, "Haintenance Work Orders" dur*.nj review of the Maintenance Work Order (HHO).
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ENCLOSURE 3 (ContinuedT m
NRC NOTICE OF VIOLATION 87-69-03 AND_ 1% E SP_QNfd s
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Corrective actions taken and the results utdfs.ed:,, '
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A Design Change Program (DCP) has been irnplemented as folloD.1;
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- 1) Procedure 00400-C, Rev. 6T, "Plant Hodificationt," id utilized to x
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control plant modifi cations.
Design changes are ceveloped by an 3 C S
independent design organization and receive multidiscipline reviews s4 of functional test assignment,
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- 2) DCPs are reviewed per Procedure 50007-C, Rcy. I N"Enyjneering Review
'a of Design Change Packages."
Per this precedure, DCP ftMtional test 3
assignments are reviewed, then concurred with, by multiple levels of x(-
the plant engineerir.g staff, j
- 3) DCP implementation and closure is conirolled by Procedure 50008-C,
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Rev.
1, "DCP Implementation and Closure".
This procedure requires that the Implementation Coordinator initiate MW0s to control DCP,
' l [. j implementation per Procedure 00350-C, Rev. 11, "Maintenance Program",
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- 4) Procedure 00350-C requires the Work Planning Group to functional test assignment and adequacy of functional test results upon completion of the work implementing the modificati6n, and
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- 5) The DCP also receives closure review by the appropriate level of plant supervision and the Plant Review Board, if applicable. '
Correcti/e steos which will be taken to avoid.fprther violations 1 The Plant Modification (Design Changa) Program as 'distusted ' abov lis expected to preclude any further violations,
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.s 5,k Date when full comoliance will be achievejl, q
A full compliance was achieved in January,1968 when the mkit Hodificatira (Design Change) Program per Procedure 00400-C was implemented.
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