ML20212H674
| ML20212H674 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 02/27/1987 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| SL-2037, NUDOCS 8703060187 | |
| Download: ML20212H674 (5) | |
Text
Georgia Power Comp:ny
=.
333 Piedmont Avenus AtlInte. Georgi 3 30308 Telephon@ 404 52S4526 MaMng Address:
Fbst Office Box 4545 -
Atlanta, Georgia 30302 Georgia Power L T. Gucws the sourNm electnc system Manager Nuclear Safety SL-2037 and Licensing 0108m February 27, 1987 U. S. Nuclear Regulatory Commission ATTN: 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 50-424/86-132 Gentlemen:
The following information is submitted in response to Inspection Report 50-424/86-132 for Vogtle Unit 1 and concerns the inspection conducted by Messers. L. E. Nicholson and M. Thomas of NRC Region II on December 8-19, 1986.
One apparent violation was identified.
A copy of the response to the subject report has been provided to Region II for review.
VIOLATION:
"10 CFR 50, Appendix B, Criteria V and XI require adherence to procedural measures established for documentation and evaluation of preoperational test results to assure that test requirements have been satisfied.
The Vogtle Start-Up Manual (SUM) is the controlling document for the preoperational test phase of the initial test program.- The SUM contains the following requirements with regard to preoperational testing:
Procedure SUM-12-C requires in part that each blank space on a procedure shall be filled in.
Procedures SUM-4 and SUM-13 require in part that test results be reviewed against acceptance criteria contained in the test procedure and verify that the results are adequately documented.
Contrary to the above, the requirements of the SUM were not adhered to in the following instances:
1.
Data sheets for documenting transferring control of parameters from the control room to remote shutdown panel B and from remote shutdown panel B back to the control room were not completed during performance of preoperational test 1-300-10, Shutdown Panel Preoperational Test, on August 13-14, 1986 The data sheets were contained in abnormal operating procedure (A0P) 18038-1, Operation From Remote Shutdown Panels.
The A0P was included in the completed test results package.
T60 f f
Il 8703060187 870227 g
PDR ADOCK 05000424 i
G PDR
~
1 a
Georgia Pbwer A U.. S. _ Nuclear Regulatory Commission February 27, 1987 Page Two' 2.
The test results package was inadequately reviewed in that the results had received final review and approval without either the blank data sheets nor the signed acceptance criteria steps being identified as a discrepancy.
This is a Severity Level IV Violation (Supplement II)."
RESPONSE'TO VIOLATION:
Admission or denial of alleged violation:
This event, which had no. actual safety consequences, did occur as stated 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.
The purpose of Preoperational Test 1-300-10
" Remote Shutdown" and its attached Abnormal Operation' Procedure (A0P) 18038-1 was to demonstrate
~ the operability of the remote shutdown panels.
The operability of the remote shutdown panel and the validity of the tests performed to demonstrate' the panel 's operability have not been questioned.. An Operations Deficiency Report (ODR) T-1-86-4680 was subsequently initiated to address the missing sign-offs.
The disposition of ODR T-1-86-4680 indicated that control of the unit was effectively transferred from the control room to the remote shutdown panel and back to the control room.
The prescribed test objective was met as shown by the appropriate sign'-offs in Section 9.0 of Preoperational Test 1-300-10.
Since the prescribed test objective was met and the validity of the tests not cuestioned, GPC believes the violation has been inappropriately class fied as a Severity Level IV and, since it is clearly a violation that has minor safety or environmental significance, should be reduced to a Severity Level V.
Reason for the violation:
Preoperational Test 1-300-10, " Remote Shutdown", referenced performance of A0P 18038-1 which had been temporarily revised, specifically for use in hot functional testing, to include sign-offs for control transfers.
Abnormal operating procedures typically do not provide sign-offs for 700776'
o Georgia Power b U. S. Nuclear Regulatory Commission February 27, 1987 Page Three other than compl etion.
Personnel performing transfers of controls overlooked part of the sign-offs temporarily provided in the Hot Functional Testing (HFT) version of Abnormal Operating Procedure 18038-1.
Unsigned control transfer steps were not noted for correction in the review of Preoperational Test 1-300-10 results because the marked-up version of AOP 18038-1, which was included in the results package, was mistakenly interpreted as supporting information rather than test data.
Corrective steps which have been taken and the results achieved:
ODR T-1-86-4680 was written to assess the acceptability of the test.
Pursuant to that ODR, the responsible Operations Department personnel have signed statements attesting to the fact that the steps were performed.
The Test Supervisor has also attested that the transfers were completed as indicated by his signature on steps 6.18 and 6.28 of Preoperational Test 1-300-10.
The ODR has been evaluated as acceptable and closed.
Corrective steps which will be taken to avoid further violations:
This issue was discussed in the Test Review Board (TRB) meeting of January 14, 1987.
The TRB was counseled to ensure that all procedures have received appropriate step sign-offs.
Since Preoperational Test 1-300-10 is the only preoperational test which had an attached procedure, no other such cases exist.
Instructions for the Writer's and Reviewer's Guide will be revised for instances where supporting documents may require sign-offs to demonstrate that testing has been completed.
The supporting documents will be referenced in the preoperational test, and the test will state if signatures are required in the supporting documentation.
The Review Checklist will be revised to state that any referenced document, stated by the procedure text to contain test completion sign-offs, will also be reviewed for complete signatures and filled in blanks.
The above corrective actions, which apply only for a unit undergoing preoperational
- testing, i.e.,
Unit 2,
will be accomplished through revision to the Writer's and Reviewer's Guide prior to Unit 2 Preoperational Testing.
700775
GeorgiaIbwerI U. S. Nuclear Regulatory Comission February 27, 1987 Page Four Date when full compliance was achieved:
Full compliance has been. achieved.
Should you have any questions in this regard, please contact this office at any time.
Sincerely, 8b L. T. Gucwa PAH/1m 0108m 7W775
gr-Georgia Power n$k U. S. Nuclear Regulatory Commission February 27, 1987 Page Five c:
Georgia Power Company Mr. R. E. Conway
. Mr. J. P. O'Reilly Mr. G. Bockhold, Jr.
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 Commission Dr. J. N. Grace, Regional Administrator Ms. M. A. Miller, Licensing Project Manager, NRR Mr. J. F. Rogge, Senior Resident Inspector-0perations, Vogtle Georgians Against Nuclear Energy Mr. D. Feig Ms. C. Stangler 0108m 700775