ML20199F777
| ML20199F777 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/14/1997 |
| From: | Mccoy C SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-424-97-09, 50-424-97-9, 50-425-97-09, 50-425-97-9, LCV-1123-A, NUDOCS 9711250012 | |
| Download: ML20199F777 (7) | |
Text
. C. K. McCoy Southern Nuclear Vc President Operating Company,Inc.
Vogtle Project 40lnverness Center Parkway -
P0. Don 1295 Bemingham, Alabama 53201 Tel2059321122
+
fax 2059920403 SOUTHERN COMPANY November 14, 1997.
Energy oSmrenur%ld" Docket No.
50-424 50-425 U. S. Nuclear Regulatory Commission -
LCV-1123-A 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 / 97-09, during an inspection conducted from August 3,1997, through September 20,1997, in the enclosure, a transcription of each violation precedes SNC's response.
Should you have any questions feel free to contact this oflice.
Sincerely, C.K.McCo CKM/CTT/afs -
/
Enclosure:
Reply to NOV 50-424,425/ 97-09
\\
cc: Scathern Nuclear Oneratinu Comoany l'
Mr. J. B. Beasley, J'.
~
r Mr. M. Sheibani NORMS
. U. S. Nuclear Regulatory CommissinD Mr. L. A Reyes, Regional Administrator Mr, L L; Wheeler, Senior Project Manager, NRR NRC Senior Resident Inspector, Vogtle lll0{$!!!h!I!$I!b 9711250012 971114 i+
PDR ADOCK 05000424 G
ENCLOSURE VOGTLE ELECTRIC GKNERATING PLANT-UNITS 1 & 2:
REPLY TO A NOTICE OF VIOLATION -
NRC INSPECTION REPORTS 50-424: 425/97-09 VIOLATION A. 50-424:425/97-09 0i The following is a transcription of violation A a, cited in the Notice of Violation (NOV):
"During an NRC inspection conducted August 3,1997, through September 20,1997, violations of NRC requirements were identified. In accordance with the ' General Statement of Policy'and Procedure for NRC Enforcement Actions,' (NUPEG 1600), the violations are Lsted below:
A.
Technical Specifications 5.4.1, Procedures, requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.
Regulatory Guide 1.33, Appendix A, identifies maintenance procedures as one of the recommended procedures.
Maintenance Procedure 00350-C, Work Request Program, Revision 29, paragraph 4.1,1 states, in part,"When conditions requiring maintenance are identified all plant personnel are responsible for ensuring a Work Order (WO) is generated in the work order database with an accurate and concise description of the condition."
Contrary to the above, on September 11,1997, the licensee failed to implement the requirements of Maintenance Procedure 00350-C when maintenance was performed on the 28 diesel generator to repairjacket water cooling system leaks without first obtaining the required work order.
This is a Severity Level IV violation (Supplement I). This violation is applicable to Unit 2 only."
RESPONSE TO VIOLATION A (50-424:425/97-09-01)
Admission or Denial of the Violation:
This violation occurred as stated in the notice of violation.
Reason for the Violation:
On September 11,1997, during the scheduled monthly surveillanu. test for the 2B diesel generator, a leak was discovered on thejacket water cooling system. The system engineer was contacted and inspected the leak at the threaded union connections. The leak was considered significant and larger than typically experienced on previous diesel generator surveillance tests, however, the leak would not affect diesel generator operability or the surveillance test.
Maintenance personnel were conta:ted and successfully stopped the leak while the diesel
EN(LOSURE VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/97-09 generator was operating. Maintenance personnel made an incorrect assumption that procedure 00350-C allowed this type of minor maintenance to be performed without a work order.
A contributing factor to this violation was the sense of urgency, due to the significance of the leak, communicated to the maintenance personnel. This resulted in a failure to focus on the administrative controls to properly document the work.
Corrective Steps Whic' 'Inve Been Taken and the Results Achieved:
1.
On September 11,1997, a werk order was initiated to document the work performed to stop the leak.
2.
Discussions were conducted with the maintenance personnel involved in this event stressing the importance of complying with procedure 00350-C, with particular emphasis on which activities are allowed to be performed without a work order.
Corrective Steps Which Will Be Taken to Avoid Further Violations:
The preventive maintenance checklist utilized during the monthly surveillances will be revised to allow jacket water cooling system leakage to be corrected per the guidance in the checklist. This will be completed by Ne vember 30,1997.
Date When Full Compliance Will He Achieved:
Full compliance was achieved on September 11,1997, when a work order was initiated to document the maintenance on the 2B diesel generator.
VIOI ATION B, 50-424:425/97-09-03 The following is a transcription of violation B as cited in the Notice of Violation (NOV):
"B.
License Condition 2(E) to License Number NPF-68 issued March 16,1987, and License Number NPF-81 issued March 31,1989, requires that the licensee fully implement all provisions of the NRC-approved ' Alvin W. Vogtle Nuclear Plant Physical Security Plan.'
Paragraph 5.3.3.2 of the Physical Security Plan, Amendment 34, dated April 28, 1997, requires that Category 111 packages which constitute a danger to the individual or would render the object being searched unusable are not opened for narch until the person whom the package is addressed to is notified and either gives permission to search the package or personally opens the package.
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ENCLOSURE VOGTL.E ELECTRIC GENERATING PLANT - UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/97-09 Procedure 90019-C," Warehouse Materials Acwss Controls," Revision 7, Step 4.1.10, states that all packages and material shall be physically searched prior to entering the protected area or is handled as one of four categories. One of the categories, Category III, requires positive control of packages and material until search of the material can be performed.
Contrary to the above, on September 8 through 10,1997, positive control of packages and _ material, designated as Category III, were not maintained when materials and equipment were permitted to enter a Unit i vital area without being searched by security personnel.
This is a Severity Level IV violation (Supplement III)."
RESPONSE TO VIOLATION B (50-4?4:425/97-09-03)
Admission or Denial of the Violation:
This violation occurred as stated in the notice of violation.
Reason for the Violation:
In preparation for the IR7 refueling outage, packages designated as Category Ill (Category III defined as: Packages and material excluded from search because search constitutes a danger to the individual or would render the object being searched unusable or contaminated. These packages and materials shall be positively controlled. For example, stored in a locked area controlled by persons familiar with the material.) entered the }rotected area (PA) and were temporarily stored in a controlled area under the supervision of security. These packages contained refueling outage materials / tools. Since these were Category III packages they were not searched prior to entering the PA, which was in accordance with procedure 90019-C,
" Warehouse Materials Access Controls." Subsequently, the packages were released from security to responsible individuals within a Unit I vital area (VA)/ radiation controlled area (RCA) without being searched.
Security personnel had interpreted paragraph 5.3 3.2 of the Physical Security Plan and step 4.1.10 of procedure 90019-C, " Warehouse Materials Access Controls," to allow Category III packages to be released to responsible individuals without being searched by security personnel. The responsible individuals were expected to appropriately search the packages since they were familiar with the contents and due to the fact the contents were contaminated. This mis-interpretation of the requirements resulted in this violation.
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ENCLOSURE VOGTLE ELFCTRIC GENERATING PLANT-UNITS I & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/97-09 Corrective Steos Which Have Been Taken and the Results Achieved:
l.
The Category 111 packages in question werc searched by security personnel. No items were identified that would have threatened personnel or plan: equipment.
2.
Interim guidance was provided to security personnel requiring that all Category III packages be searched by security personnel upon entry to the PA or when the packages are released to the responsible individuals.
3.
Procedure 90019-C, " Warehouse Materials Access Controls," has been revised to provide specific guidance concerning proper search of Category III packages.
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 September 17,1997, when the Category Ill packages in question were searched by security personnel.
VIOL,ATION C,50-424:425/97-09-04
- The following is a transcription of violation C as cited in the Notice of Violation (NOV):
"C.
Technical Specification Section 5.4.1.d, Fire Protection Program, requires that written procedures be implemented covering fire protection program -
implementation.
Fire prctection program Procedure 92020-C, Revision 11," Control ofIgnition Sources," requires fire extinguishers, used to control potential ignition sources, to be inspected within 28 days of the date that is on the inspection sticker on the extinguisher.
Contrarv ) the above, on August 15,1997, fire extinguishers were issued to plant l
perso-control ignition sources that exceeded the 28-day criteria.
l Specifically,54 fire extinguishers whose inspection sticker was dated July 1,1997, were issued from the time between July 30,1997, and August 15,1997, and did not meet the inspection criteria of Procedure 92020-C.
This is a Severity Level IV violation (Supplement 1)."
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ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/97-09 RESPONSE TO VIOL ATION C (50-424:425/97-09-04)
Admission or Denial of the Violation:
This violation occurred as stated in the notice of violation.
Er3.3on for the Violation:-
The fifly four fire extinguishers issued for use between July 30 and August 15,1997, had expired inspection stickers indicating the extinguishers had exceeded the 28 day inspection frequency.
Fire watch personnel obtained fire extinguishers from the maintenance tool room to be used to controlignition sources. In accordance with procedure 92020-C," Control ofIgnition Sources, "
fire watch personnel are required to have the extinguishers inspected by qualified fire protection personnelif the extinguishers Imve expired inspection stickers. Fire watch personnel failed to accomplish this for the fifty four extinguishers. Also, maintenance tool room personnel issued fire extinguishers with expired inspection stickers, therefore contributing to the violation.
Additionally, there was inadequate guidance in procedure 92020-C, in that the procedure required the fire extinguisher inspection date be documented on the burn permit whereas the permit did not provide an entry location for the inspection date.
Corrective Steps ' Jhich IInvc Heen Taken and the Results Achieved:
1.
The filly four fire extinguishers with expired inspection stickers were replaced with fire extinguishers with valid inspection stickers.
2.
Fire watch personnel received additional training on fire extinguisher inspections and their responsibilities.
3.
Fire technicians and maintenance tool room personnel received additional training on fire extinguisher inspection requirements.
4.
Procedure 92020-C, " Control ofignition Sources," has been revised to strengthen the fire extinguisher inspection process. This revision will provide specific directions for personnel to ensure that only fire extinguishers with valid inspection stickers are used to controlignition sources.
Corrective Stens Which Will Be Taken to Avoid Further Violations:
No additional corrective acticas aie planned at this time.
ENCI,OSURE VOGTLE ELECTRIC GENERATING PLANT-UNITS I & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/97-09 Date When Full Comollance Will Be Achieved:
Full compliance was achieved on August 16,1997, when the fire extinguishers with expired inspection stickers were replaced with fire extinguishers with valid inspection stickers.
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