ML20207R700
| ML20207R700 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/13/1987 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| SL-2127, NUDOCS 8703180039 | |
| Download: ML20207R700 (4) | |
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Georgia Pow;f Company.
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333 Piedmont Avenus
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.- Atlanta, Georgia 30308
- Telephone 404 526-6526 0f 545
. Atlanta, Georgia 30302 GeorgiaPower
-- L T. Gucwa the southem electric system Manager Nuclear Safety and Ucensing SL-2127 -
0149m March 13,1987 U. S. Nuclear Regulatory Commission ATTNt Document Control Desk Washington, D.C.
20555 NRC DOCKET 50-424 OPERATING LICENSE'NPF-61 V0GTLE ELECTRIC GENERATING PLANT UNIT 1 RESPONSE TO NRC I&E REPORT 50-424/87-02 Gentlemen:
The following ' information is submitted in response to Inspection Report 50-424/87-02 for Vogtle. Unit 1 and concerns the inspection conducted by Mr. W. H. Miller, Jr. of NRC Region II on January 12-16, 1987. One apparent violation was identified. _ A copy of this response to the subject report has been provided to NRC Region II for review.
VIOLATION "10 CFR 50.54(a)(1) requires Georgia Power Company (GPC) to implement the quality, assurance (QA) program described or referenced in its Safety Analysis Report.
Section 17.1.5 of GPC QA Program requires that activities affecting quality be prescribed by documented instructions, GPC procedures, or drawing of a type appropriate to the circumstances.
Procedure No. 00350-C, Maintenance Program, requires the maintenance work group to ensure that the maintenance program is supported, program planned and scheduled so as not to compromise the safety of the plant and a fire protection work. evaluation is required to be performed on all work orders by qualified personnel. Procedure No. 92026, Fire Protection Work Evaluation, provides the instructions for determining the. impact of-proposed work activities on the plant's fire protection program and instructions for filling out the Fire Protection Checklist, Figure 4, required by Procedure 20050-C, Maintenance Work Planning Group Work Order Processing.
Contrary to the above, Maintenance Work Order Nos. 18621678 and 18624536 issued on November 10 and December 3,1986, specified maintenance and calibration work to be. performed on Reactor Coolant System Pressure transmitter PT-403 and Pressurizer Level transmitter LT-459, but did not identify that the work would be removed and thus defeat.the three hour fire rated radiant energy shields provided for these instruments.
These shields are needed to meet the safe shutdown fire protection separation
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from redundant shutdown equipment requirements.
This fire rated radiant energy " shield. material for 'these instruments were thus removed and n
resulted in redundant. safe shutdown components being exposed to possible y
damage in the event of fire.
This is a Severity Level IV Violation (Supplement II)."
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RESPONSE
' Admission or denial of alleged violation:
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This event, which had no actual -safety consequences, did occur as stated l'
. in the Inspection Report.
After careful and considered review of the severity categories listed in Supplement II to 10 CFR Part 2, Appendix C, and additional review of the event, Georgia Power Company -(GPC) has concluded that a more appropriate severity classification is Severity
-Level V - violations that have minor safety or environmental significance.
Both transmitters, PT-403 and LT-459 have redundant channels, thus a local-fire that has the potential of destroying both -transmitters, would not have prevented safe shutdown of the plant. ; Additionally, both transmitters are located in Fire Zone 140 and the Control Room personnel would have been alerted by the fire detection system of any. fire within
-that fire zone.
Once alerted, Control Room personnel would be cognizant
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of 'any - fire-induced failures by using approved procedures. that are
. located in the Control Room.
Vogtle -Unit 1 was in a pre-fuel load status prior to receipt of a low power license, and the missing fire barriers were identified during a surveillance inspection.
GPC believes, therefore, the violation should be reduced to a Severity Level V since it is clearly a violation that has minor safety or environmental significance.
Reason for the violation:
The' individual responsible for performing fire protection evaluations in accordance with Procedures 00350-C, 20050-C and 92026-C, failed to utilize the applicable procedures and drawings while completing the fire orotection checklist.
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GeorgiaPower d U. S. -Nuclear Regulatory Connission March 13,1987 Page Three Corrective steps which have been taken and the results' achieved:
Maintenance Work Order Nos. 18624488 and 18700599 were initiated to replace the - radiant energy shields on transmitters LT-459 and PT-403 respectively.
This work was completed on both by January 23, 1987.
The individahl' responsible for completion of the fire protection checklist has been counseled regarding the usage of Procedures 00350-C and 92026-C.
5 Corrective steps.which will be taken to avoid further violations:
Procedure 92026-C, Fire Protection Work Evaluation, will be revised to include more explicit instructions for identifing components-with radiant energy shields.
In addition,'the subject procedure will be reviewed and revised, as necessary, to ensure its purpose and scope. statements are adequately addressed in the body of the procedure.
Also, maintenance work planners have been made aware of this violation in. correspondence from appropriate supervisory personnel reemphasizing procedural adherence.
Date when full compliance will be achieved:
The revision to Procedure 92026-C and training of work planners to the
' revision is scheduled to be completed by April 30, 1987.
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Should you have any questions in this regard, please contact this
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office at any time.
Sincerely.
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- GeorgiaPower A U. S. Nuclear Regulatory Comission March 13,1987 Page Four c: Geors ia Power Company Mr.
F,. E. Conway Mr. J. P. O'Reilly Mr. G. Bockhold, Jr.
Mr. J. F. D' Amico GO-NORMS Southern Company Services Mr. J. A. Bailey Shaw, Pittman, Potts & Trowbridge Mr. B. W. Churchill, Attorney-at-Law Troutman, Sanders, Lockerman & Ashmore Mr. J. E. Joiner, Attorney-at-Law U. S. Nuclear Regulatory Comission Dr. J. N. Grace, Regional Administrator Mr. H. H. Livermore, Senior Resident Inspector-Construction, Vogtle Ms. M. A. Miller, Licensing Project Manager, NRR (2 copies)
Mr. J. F. Rogge, Senior Resident Inspector-Operations, Vogtle Georgians Against Nuclear Energy Mr. D. Feig Ms. C. Stangler 0149m 700775