ML20197G493
| ML20197G493 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/22/1997 |
| From: | Mccoy C SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-424-97-10, 50-425-97-10, LCV-1135-A, NUDOCS 9712310037 | |
| Download: ML20197G493 (5) | |
Text
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C1McCoy Southern Nulser j
%ce Presidont Opsr: ting Company. Inc.
6 WyyJe Project 40 hverus Center Pwkway PO Box 1295 Birmmtwn. Alabama 35201 Tel 2059321122 Iaa 205932 0403 SOMM h December 22, 1997 COMPANY Docket No.
50-424 50-425 Emy to Smr Your%Id*
U. S. Nuclear Regulatory Commission LCV-1135-A ATTN: Document Control Desk Washington, D. C. 20555 Ladies and Gentlemen:
VOGTLE ELECTRIC GENERATING PLANT REPLY TO A NOTICE OF VIOLATION AND WEAKNESS Pursuant to 10 CFR 2.201, Southern Nuclear Operating Company (SNC) submits the enclosed infc:Tnation for Vogtle Electric Generating Plant (VEGP) in response to violations identified in Nuclear Regulatory Commission (NRC) Integrated inspection Report Nos. 50-424;425 / 97-10, during an inspection conducted from September 21,1997, through November 1,1997. In the enclosure, a transcr*,ption of each violation precedes SNC's response.
Per your request, Enclosure 2 contains a discussion e' e actions to address the weaknn.a identified in the subject Inspection Report concerning the failuu an operations crew to recognize that a Limiting Condition for Operation was entered and exited for an emergency core cooling system.
Should you have any questions feel free to contact this office.
Sincerely, dOW C. K. McCoy CKM/CTT/afs g O{
Enclosures:
Enclosure 1: Reply to NOV $0-424;425/ 97-10 : Reply to Weakness Identified in Inspection 50-424;425/ 97-10 /
cc:.Sauthern Nuclear Operatine Comp 3ny Mr. L B, Beasley, Jr.
I Mr. M. Sheibani j
NORMS l
U O U de$
U. S. Nuclear Remilatory Commission Mr. L. A. Reyes, Regional Administrator
]' L}L[", i ;' ; (u N,,)
Mr. D. H. JafTe, Senior Project Manager, NRR u
Mr. John Zeiler, Senior Resident inspector, Vogtle 9712310037 971222 PDR ADOCK 05000424 G
PDR.
ENCLOSURE 1 VOGTLE ELECTRIC GENEkATING PLANT - UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/ 97-10 VIOLATION A. (50-424 / 97-10-01)
The following is a transcription of violation A as cited in the Notice of Violation (NOV):
"During an NRC inspection conducted September 21, through November 1,1997, 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 Specifications 5.4.1.a requires that written procedures be implemented for the activities identified in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, February 1978.
RG 1.33, Revision 2, requires that procedures for operation of onsite alternating current (AC) electrical systems be implemented.
Procedure 11430-1,"480V AC Non IE Electrical Distribution System Alignment,"
Revision 12, was established to control, in part, the alignment of Unit I diesel generator train A unit heater breakers located on 480-Volt Non IE motor control center (MCC) IN'BG. This procedure specified that all breakers on INBG were required to be closed unless tagged.
Contrary to the above, on October 3,1997, ten unit heater breakers on MCC INBG were found open and not tagged.
This is a Severity Level IV violation (Supplement 1). This violation applies to Unit 1 only."
RESPONSE TO VIOL ATION A (50-424 / 97-lG-01)
Admission or Denial of the Violation:
This violation occurred as stated in the notice of violation.
Reason for the Violation:
During the IR7 refueling outage maintenance activities wue being performed on the 1 A diesel generator. Due to the heat in the building, maintenance personnel requested that the building heaters be turned "off." Operations personnel failed to comply with existing administrative controls when positioning the building heater breakers "open" without attaching clearance tags to the breakers or annotating the appropriate clearance log. At the completion of the maintenance activities on the 1 A diesel generator personnel indicated to operations that the heaters could be turned "on." However, since the breakers were not tagged or the clearance log was not 1
ENCLOSURE 1 VOGTLE ELECTRIC GENERATING PLANT - UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425 / 9710 annotated, there was no mechanism in place to ensure the breakers were positioned "c:osed" and aligned per the applicable lineup procedure.
Corrective Stens Which IInve Been Taken and the Results Achieved:
1.
The building heater breakers were positioned " closed" in accordance with the lineup procedure.
2.
This event was discussed with operations personnel emphasizing the appropriate administrative controis when manipulating plant equipment.
Corrective Steps Which Will He Taken to Avoid Further Violations:
There are no additional corrective actions planned at this time.
Date When Full Compliance Will He Achieved:
Full compliance was achieved on October 27,1997 when the building heater breakers were
" closed."
VIOI.ATION H. (50-424 / 97-10 04)
The following is a transcription of violation B as cited in the Notice of Violation (NOV):
"B.
10 CFR 50 Appendix B Criterion XVI states, in part, that measures shall be established to assure that conditions adverse to quality, such as deficiencies, are promptly identified and corrected.
Contrary to the above, the licensee issued revision 4 of the APEX users manual without implementing adequate corrective actions to provide explicit guidance on the use of the APEX computer code with a core that has less than a ten (10) days bum up history. This issue was first identified in October 1996. The licensee failed to implement identified corrective actions in revision 4 of the APEX us-s manual prior to the startup of Unit I from the seventh refueling outage. The Unit I startup occurred in October 1997.
This is a Severity Lcvd IV violation (Supplement 1)."
RESPONSE TO VIOLATION D (50-424 / 97-10 04)
Admission or Denial of the Violation:
This violation occurred as stated in the notice of violation.
2
ENCLOSURE 1 VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION ERC INSPECTION REPORTS 50-424: 425 / 97-10 Reason for the Violation:
During the 2RS refueling outage in the Fall of 1996, the NRC identified Non-Cited Violation (NCV) 96-11-04, " Inaccurate Calculation of Estimated Critical Condition." This NCV identifi:d difficulties in performing an Estimated Critical Position (ECP) using the APEX computer code for a core with less than ten days burnup history. Subsequently, corporate and site engineering reviewed the APEX User Manual and identified deficiencies which would affect the calculation of ECP. Specific corrective actions were planned to address this problem, including the revision of the manual. The manual was revised prior to tartup of Unit I from the IR7 refueling outage, however, the revision did not include adequate corrective actions to provide explicit guidance on.
l the use of the APEX cmr.puter code for a core that has less than ten days bumup history.
{
This violation was a tesult of personnel failing to ensure timely corrective actions were completeti to address the deficiencies ide itified in the APEX Us-r Manual.
Corrective Steps Which Mave Been Taken and ti.* 'esults Achieved 1.
The APEX User Manual has been revised to provide specific gt.
ensure an accurate EC" can be determined after a reactor trip for a core wim ness than ten days be nup history.
2.
Personnel have been counseled on the importance of timely completion of corrective actions.
QLrcytive Stens which Will He 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 Nos ember 12,1997, when training was completed on the use of the revised APEX User Manual, Revision 4 dated October 1997.
3
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I ENCLOSURE 2 VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO WEAKNESS NRC INSPECTION REPORTS 50-424: 425/ 97-10 The following information concerning an identified weakness is being submitted at the request ofIntegrated Insocction Report (50-424,425/ 97-10), dated November 26,1997:
Inspection Report (50-424,425/ 97-10) identified a weakness for an operations crew failing to recognize that a Limiting Condition for Operation (LCO) was entered and exited for an emergency core cooling system.
This Technical Specification application error was caused by operations personnel focusing primarily on the 4 he, r time limit to complete safety injection system alignment, but not considering the 375 degree temperature limit which was also applicable. This oversight was caused by a failure to appropriately reference all applicable Technical Specification requirements and relying on plant experience.
To address this weakness, training for licensed operators will be conducted during the first requalification segment in 1998 to discuss this and other recent Technicai specification application errors. This training will focus on the importance of properly refe encing Technical Specification and bases documents during LCO entry and reviews.
For additional inforri.ation relating to this item reference VEGP Licensee Event Report 1-97-11, submitted on November 14,1997, 1
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