ML20211F525
| ML20211F525 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 09/25/1997 |
| From: | Mccoy C SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-424-97-07, 50-424-97-7, 50-425-97-07, 50-425-97-7, LCV-1091-A, NUDOCS 9710010109 | |
| Download: ML20211F525 (4) | |
Text
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C. K. MrCoy Southern Nuclear V4te President Operating Company. Inc.
Vugile Project 40 invemess Contor Parkway PO Box 1295 Bemingham Alabama 35201 Tel 205 932 7122 f as 205 997 0433 SOUTHERN COMPANY September 25, 1997 r,,ergy ro serve nurwid" Docket No.
50-424 50-425 LCV-1091 A U. S. Nuclear Regulatory Ccmmission ATTN: Document ControlDesk Washington, D. C 20555 Ladies and Gentlemen:
VOGTLE ELECTRIC GENERATING PLANT REPLY TQ A NOTICE OF VIOLATION Pursuant to 10 CFR 2.201, Southern Nuclear Operating Company (SNC) hereby 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/ 97-07, that concerns the inspection conducted from July 6, through August 2,1997. In the enclosure, a transcription of each violation precedes SNC's response.
Should you have any questions feel free to contact this office.
Sincerel,
[.k C. K. hicCoy CKhi/CTT/afs
\\f\\
Enclosure:
Reply to NC"' 50-424;425/ 97-07 cc: __ Southern Nucltnr Operatina Comoany hir. J. B. Beasley, Jr.
hir. hi. Sheibani NORhtS U. S. Nuclear Regulatory Corpmission Mr. L. A. Reyes, Regional Administrator hir. L. L. Wheeler, Senior Project hianager, NRR NRC Senior Resident inspector, Vogtle
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ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO A NOTICE OF VIC ~ATION NRC INSPECTION REPORTS 5' 424:425/ 97-07 VIOLATION A. 50-424:425/ 97-07-01 The following is a transcription of violation A as cited in i 3 Notice of Violation (NOV):
"During an NRC inspection conducted July 6,1997, through August 2,1997, violations of NRC requirements were identified. In accordance with the ' General Statement of Policy and P;ocedure for NRC Enforcement Actions,' (NUREG 1600), the violations are listed below:
A.
10 CFR 50 Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities alTecting quality be prescribed and accomplished in accordance with procedures appropriate to the circumstances.
Procedure 10008 C, " Recording Limiting Conditions for Operation," Revision 19, i
prescribed the method for recording the failure to meet a Technical Specification (TS) Limiting Condition for Operation (LCO) or Technical Requirement (TR).
This procedure required completion of a LCOffR Status Sheet and LCO/TR Status Log entry prior to the end of the shin if entry into an action statement is required.
Contrary to the above, on July 8,1997, during maintenance on a shan seal in the Unit I personnel airlock, the licensee failed to document entry into the appropriate action condition for TS LCO 3.6.2, Containment Air Locks. The licensee documented entry into Action Condition "A"instead of the required Action Condition "C."
This is a Severity Level IV violation (Supplement 1). This violation is applicable to Unit 1 only."
RESPONSE TO VIOLATION A (50-424:425/ 97-07-01)
Admission or Denial of the Violation:
This violation occurred as stated in the notice of violation.
Reason for the Violation:
On July 8,1997, operations personnel entered TS 3.6.2,"Coatainment Air Locks," LCO Action Condition "A" for maintenance activities on the Unit 1 personnel containment air lock shan seal.
Action Condition "A" provides required actions in the event that an air lock door is rendered inoperable. The decision to enter Action Condition "A" was based on an interpretation that maintenance activities on the shan seal had an equivalent or less impact on containment leakage than that of an inoperable air lock door.
I
ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425/ 97 07 Corrective Stcos Which llave Been Taken und the Results Achieved:
On July 9,1997, aller further discussion and investigation by plant staff, the decision was made to document entry into Action Condition "C" retroactive to the start of the initial shaft seal maintenance. The air lock door seal was restored to service within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> which ensured compliance with required actions of TS 3.6.2.
Corrective Steos Which Will Be Taken to Avoid Further Violations:
l i
This event and application of TS 3.6.2 LCO Action Conditions will be reviewed during l
liccased operator requalification training. This will be completed by December 1,1997.
lbte When Full Comollance Will Be Achieved:
Fall co'.nplial 'e was achieved on July 9,1997, when TS 3.6.2 LCO Action Condition "C" was ente, 1.
VIOLA "8% B,50-424:425/ 97-07-07 The following is a transcription of violation B as cited in the Notice of Violation (NOV):
"B.
License Condition (E) of the Vogtle Operating License, dated March 17,1997, states in part that Southern Nuclear shall fully implement and maintain in effect all provisions of the Commission approved physical security, guard training and qualification, and safeguards contingency plans...and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).
Vogtle Electric Generating Plant Physical Security and Contingency Plan, Ameadment 34, dated April 28,1997, Table 4 1, designated the Unit 1 Diesel Generator Buildings and their controls as vital areas.
Site Drawing AX1D02FA06, Revision 0, dated 1988, designated the outermost boundary of the Unit 1 Diesel Generator Buildings as a vital barrier.
Procedure 90106-C, Revision 22, dated August 6,1996, Section 4.7 stated, in part, that decreased effectiveness of physical barriers shall be compensated by posting armed security ofricers.
Contrary to the above, on July 8 to July 9,1997, for approximately 19 hours2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br />, the licensee failed to compensate for a decrease in effectiveness of a vital area barrier by failing to post an armed oflicer.
This is a Severity LevelIV violation (Supplement 111). This violation is applicable to Unit i only."
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ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT. UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425/ 97-07 RESPONSE TO VIOI.ATION B (50-424:425/ 97-07-07)
Admission or Denial of the Violationt This violation occurred as stated in the notice of violation.
Reason for the Violationt On July 8,1997, security established a compensatory post for the removal of a vital area barrier to the diesel generator 1B day tank vent room to allow citanup of a fuel oil spill that had occurred during previous maintenance activities. Later on July 3,1997, a security shill captain inspected the vital area barrier opening. Removal of this barrier allowed access to safety related piping penetrating the diesel generator concrete wall, liowever, after evaluating the opening the security shifi captain determined that no unauthorized entry could be gained to components in the diesel generator building; therefore, the compentatory post was released. This cognitive decision l
by the security shill captain constituted a failure to follow procedural requirements for the removal of a vital area barrier and establishment of a compensatory post. Subsequent to the release of the compensatory post, increased security surveillance checks were performed until the vital area barrier was replaced. On July 9,1997, security observed the replacement of the vital area barrier.
Corrective Stens Which llave Been Taken and the Results Achieved:
1.
The security shift captain was counseled concerning the removal of vital area barriers and the decision process for establishment of compensatory posts.
2.
Security department shift supervision were briefed on this event.
Corrective Stcos Which Will Be Taken to Avoid Further Violations:
No additional corrective actions are planned at th' time.
Date When Full Comollance Will He Achieved:
Full compliance was achieved on July 9,1997, when the vital area barrier was replaced under the supervision of security.
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