ML20205H156

Notice of Violation from Insp on 880808-0912.Violations Noted:Failure to Adequately Maintain Surveillance Procedure 24546-C in That Steps for Adjusting Back Pressure Regulator Incorrect

ML20205H156
Person / Time
Site:	Vogtle
Issue date:	10/14/1988
From:	Ernst M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205H154	List: IR 05000424/1988033 ML20205H150 ML20205H156
References
50-424-88-33, NUDOCS 8810280404
Download: ML20205H156 (4)

Text

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0 0 ENCLOSURE 1 NOTICE OF VIOLATION Georgia Power Company Docket No. 50-424 Vogtle Unit 1 License No. NPF-68 During the Nuclear Regulatory Commission (NRC) inspection conducted on August 8 - September 12, 1988, violations of NRC requirements were identified.

In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violations are listed below:

A. Technical Specification 6.7.1.a requires that written procedures Se established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Revision 2, February 1978, Appendix A, requires that specific procedures for surveillance tests be maintained.

Contrary to the above, the licensee failed to adequately maintain surveillance procedure 24546-C, Triple Range Catalytic Combustion Analyzer AAIC-1118 Analog Channel Operation Test, Rev. 4, in that the steps for -

adjusting the back pressure regulator were incorrect.

P This is a Severity Level IV violation (Supplement I).

B. 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires that measures be established to assure that conditions adverse to quality are promptly identified and corrected. In the case of significant conditions adverse to quality, the reasures shall assure that corrective action is taken to preclude repetition.

Contrary to the above, corrective actions for a previous licensee self-identified violation were inadequate. Specifically, on August 10, 1988, the NRC identified four operators who had not read required reading materials in a timely manner. This was a repetitive deficiency in that in  ;

January 1988, NRC Inspection Report No. 424/88-07 docurented a licensee self-identified vialetion concerning the inadequate implementation of the required reading program. This deficiency was identified prior to the NRC inspection and corrective actions were planned; therefore, a violation was not cited at that time.

I This is a Severity Level IV violation (Supplement !).

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Georgia Power Company 2 Docket No. 50-424 ,

Vogtle Unit 1 License No NPF-68 C. 10 CFR 20.202(a) requires that each licensee shall supply appropriate personnel monitoring equipment to, and shall require the use of such equipment by each individual who enters a restricted area under such circumstances that he receives, or is likely to receive, a dose in any .

calendar quarter in excess of 25 percent of the applicable value i specified.

10 CFR 73.55(d)(5) requires that all individuals display picture badges while inside the protected aiea. -

Administrative proceduro 00950-C. Personnel Dosimetry Program, Rev. 6s requires each individual, who has an assigned thermoluminescent dosimetry (TLD), will wear the TLD at all times while inside a radiation control ,

zone (RCZ). Additionally. 00950-C requires that prior to entering the RCZ '

or any radiation control area, the individJal Will select and Wear a whole body Direct Reading Device.

2 Contrary to the above, on August 12, 1988, an NRC inspector observed an electrician who was not wearing the required personnel monitoring device or picture badge while in a radiation control zone within the protected ,

area.

l This is a Severity Level IV Violation (Supplements III and IV). f a

D. 10 CFR 50.59 allows the licensee to make changes in the facility as ,

i described in the Final Safety Analysis Report (FSAR) under certain  !

conditions. Wher such changes are made, a written safety evaluation is ,

l required, i

)  !

The FSAR describes a control room annunciator that will indicate trouble '

i on 125V de distribution panel 1A012. The annunciator combines under-voltage, ground, and breaker trip alarms.  ;

Contrary to the above, the licensee made a change to the facility, as described in the FSAR, in that on June 28, 1988, the licensee disabled the i control room annunciator for 125V de panel IAD12 by disconnecting the annunciator card without performing a safety evaluation. l t

i y This is a Severity Level IV violation (Supplement I).

1 E. Technical Specification 6.7.4.e requires a program to be established, implemented, and maintaintd which will ensure the capability to monitor plant variables and systems operating status during and following an accident. This program shall include those instruments provided to

indicate system operating status and furnish information regarding the release of radioactive materials (Category 2 and 3 instrumentation as defined in Regulatory Guide 1.97, Rev. 2) and provide for preventive J maintenance and periodic surveillance of the instrumentation. Regulatory Guide 1.97. Instrumentation for Lighi-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident,

Georgia Power Company 3 Docket No. 50-424 Vogtle Unit 1 License No. NPF-68 Rev. 2, specifies "Letdown Flow - Out" as an instrument necessary to monitor the system operating status of the Chemical and Volume Control System. Flow Transmitter FT-132 is utilized by the licensee to monitor letdown flow.

TS 6.7.1 requires that procedures be implemented concerning the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, including the calibration of safety-related water storage tank level instrumentation. TS 3.7.5 requires that the Ultimate Heat Sink (VHS) be operable. The UHS consists of the Nuclear Service Cooling Water (NSCW) pumps, fans and tower basins. The surveillance required by TS 4.7.5 includes verifying the water level of the NSCW tower basin which is monitored by level transmitters 1-LT-1606 and 1-LT-1607.

Contrary to the cove, the licensee failed to perform the required calibrations for FT-132, 1-LT-1606 and 1-LT-1607 because the three instruments had not been incorporated into the periodic calibration program when the program was established prior to startup of Unit 1.

This is a Severity Level IV violation (Supplement I).

F. 10 CFR 50, Appendix B, Criterion VI Document Co1 trol, requires that measures be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting quality. In addition, Criterion VI requires that the measures shall assure that chages are distributed to and used at the location where the prescribed activity is performed.

Contrary to the above, the licensee failed to maintain control of documents which prescribe activities affecting quality based on the following findings. On August 23, 1988, an NRC inspector found an uncontrolled and out-of-date copy of Final Safety Analysis Report (FSAR)

Table 3.2.2-1 Classifications of Structures, Componenti and Systems, located in the Support Shif t Supervisor's office. The licensee replaced the uncontrolled copy with controlled copy number 125 of the FSAR.

Subsequent review of controlled copy 125, on September 12, 1988, indicated that Table 3.2.2-1 contained nine pages which were either missing or had been superseded.

This is a Severity Level IV violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Georgia Pcwer is hereby required to submit a written statement or explanation to the Nuclear Regulatory Comis.; ion, ATTN: Document Control Desk, Washington, DC 20555, with a copy to the Regional Admini'trator, Region II, and a copy to the NRC Reside.nt Inspector.

Yogtle, within 03 days of the date of the letter transmitting this Notice.

This reply should be clearly marked as a "Reply to a Notice of Violation" and should include [for each violation]: (1) admission or denial of the violation, (2) the reason for the violation if admitted, (3) the corrective steps which have been taken and the rcsults achieved. (4) tha corrective steps which will be taken to avoid further violations, and (5) the date when full compliance

Georgia Power Company 4 Docket No. 50-424 Vogtle Unit 1 License No. NPF-68 will be achieved. Where good cause is shown, consideration will be given to e'. tending the response time. If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.

Security or safeguards information should be submitted as an enclosure to facilitate withholding it from public disclosure as required by 10 CFR 2.790(d) or 10 CFR 73.21.

FOR THE NUCLEAR REGULATORY COMMISSION y-y/c,P

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,cp Malcolm L. Ernst Acting Regional Administrator Dated at Atlanta, Georgia this 14 th day of October , 1988 i