ML20214G568

Responds to Violation Noted in Insp Rept 50-424/87-01 on 870105-09 & 12-16.Corrective Actions:Workers Counseled & Retrained on Importance of Procedural Compliance Re Battery Insp,Monitor Calibr,Current Document Version & Log Maint

ML20214G568
Person / Time
Site:	Vogtle
Issue date:	05/18/1987
From:	Gucwa L GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
SL-2435, NUDOCS 8705270108
Download: ML20214G568 (7)

Text

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.; 333 Piedrnont Avenue . -

Attenta, Georgia 30308 -

Telephone 404 526-6526 -

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- Malling Address:

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' Post Offico Box 4545 Atlanta, Georgia 30302 f Georgia Power-

~ L T. Gucwe the southern electresysteni Manager Nuclear Safety

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.0265m X7GJ17-V120 May '18,1987 U. S. Nuclear Regulatory Commission ATTH:~ Document Control Desk Washington, D.C. 20555 PLANT V0GTLE - UNIT 1

' NRC DOCKET 50-424 OPERATING LICENSE NPF-68 RESPONSE TO NRC INSPECTION REPORT-d

-Gent 1emen:

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Pursuant to the provisions of 10 CFR 2.201, - Georgia Power Company (GPC) submits the following information in response to . NRC . Inspection -

Report 50-424/87-01' for Plant Vogtle Unit 1 concerning the inspection 2

' conducted by Ms'. L. J. Watson and others of NRC Region II on January 5-9,A

1987 .and January 12-16, 1987. One apparent ' violation was- identified.

copy 'of ~ this response to ' the subject report has ~ been - provided -to NRC.

-Region II for review.

A transcription of the NRC Notice of Violation - is provided--as i~ Encl osure' .1. GPC's response is provided us Enclosure 2.

Should you have any questions in this regard, - please contact this office at any time.

f Sincerely, 87052 PDR g $ 73 h>DRu P L. T. Gucwa G

. JAE/im

Enclosures:

1. NRC Notice of Violation

2. Georgia Power Company Response c: .(see next.page)

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Georgia Power d U. S. Nuclear Regulatory Commission

-May 18, 1987 Page Two

.c: Georgia Power Company Mr. R. E..Conway

' Mr. J. P. O'Reilly Mr. G. _ Bockhold, Jr.

Mr. J. F. D' Amico Mr. C. W. Hayes-GO-NORMS Southern Company Services Mr. J. A. Bailey Mr. R. A. Thomas

- Shaw, Pittman, Potts & Trowbridge

- Mr. B. W. Churcnill, Attorney-at-Law Troutman, Sanders, Lockerman & Ashmore-Mr. A. H. Domby, Attorney-at-Law-U. S. Nuclear Regulatory Commission Dr. J. N. Grace, Regional Administrator .'

Ms. M. A. Miller, Licensing Project Manager, NRR (2 copies)

Mr.- J. F. Rogge, Senior Resident Inspector-0perations, Vogtle Georgians Against Nuclear Energy Mr. D. Feig -

Ms. C. Stangler 0265m

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Georgia Pbwer A ENCLOSURE 1 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68

'NRC NOTICE OF VIOLATION VIOLATION '50-424/87-01-01 "10 CFR 50, Appendix B, Criterion V, states that activities affecting

1. quality shall 'be prescribed by documented procedures 'and shall be accomplished- in accordance with these procedures. VEGP FSAR, Section 17.2, ' Operations Quality Assurance Program, also requires that activities affecting quality be accomplished- in accordance with documented g procedures.

y I 1. Procedure 00404-C, Surveillance Test Program, Step 4.5.4.1, requires an independent reviewer to confirm that surveillance test results b

p satisfy the acceptance criterie.

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!' ' Contrary to the above, the independent reviewer failed to follow

' procedure 00404-C by signing the Surveillance Task - Sheets for the Class lE 18-Month Batte ry Inspection and Maintenance procedures, which indicated that the acc'otance criteria had been met. In actuality, the Technical Specir!<.ation acceptance criteria of 50 X 10-b ohms,' for intercell resistance had been exceeded.

2. Step 5.1 of procedure 34223-C, Channel Calibration of the Gaseous Effluent Monitors, Rev. 1, requires that the technician - ensure a Quality Control (M) representative has signed the checklist indicating a QC review cf the' procedure for hold points.

Additionally, step 5.2 requires that the technician notify the Operations Shift Supervisor, or his designee, of the work to be performed and obtain his authorizing signature.

p Contrary to the above, a technicfan failed to follow procedure 34223-C and did not obtain either the signature of the QC representative or the Operatior: Shift Supervisor prior to performance of the procedure.

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. Georgia Pbwer k ENCLOSURE 1 (Continued)

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NRC NOTICE OF VIOLATION

3. Administrative procedures 00103-C, Document Distribution and Control, and 00101-C, Drawing Control, require the licensee to verify every seven - days that " working copy" drawings and vendor manuals are _the latest revision and contain all applicable design change notices and temporary changes to procedure.

Contrary to the above, the inspector observed technicians performing work authorized by maintenance work orders 18624165, 18700429, 18624440, and 18700453 with " working copy" documents that . had not been verified to be current.

4. - Administrative procedure '10004-C, Shift Relief, - Rev. - 3, indicates that the _ on-coming operator is to review. and initial the narrative logs since the last shift worked 'or the preceding five days, whichever is less. Administrative procedure 10001-C, Logkeeping, Rev. 3, also indicates that narrative logs shall be reviewed and initialed by the on-coming operator.

Contrary to the above, on January 15, 1987, the day-shift shift supervisor failed to follow procedures 10004-C and 10001-C~ in t. hat he failed to review and initial the Shift Supervisor's log for the previous night's log entries.

This is a Severity Level IV violation (Supplement 1)."

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iGebrgia Powerb

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. ENCLOSURE 2 -

PLANT V0GTLE - UNIT 1

'NRC DOCKET 50-424

. OPERATING LICENSE NPF-68 RESPONSE TO NRC NOTICE OF VIOLATION RESPONSE T0' VIOLATION 50-424/87-01-01 Admission or- denial:of alleged violation:

. For ease :of - consideration, the response is divided linto -the constituent examples cited in the Notice of Violation.

The events did occur as stated in the Inspection Report. Notwithstanding

- our admission of the -violation, we believe it appropriate to ' note that

-after review of the severity categories listed in Supplement I to'10.CFR Part 2, Appendix C, and additional review of: the event,-Georgia Power Company (GPC)-believes that a more appropriate severity classification is Severity Level .V -- violations :that have minor safety or environmental-significance. . You may wish to consider this belief in your future evaluations..

Reasons for the violation:-

Example 1 - Personnel error associated -with the origination of. the Maintenance Technical Specification Surveillance Program in conjunction with a draft Technical,l Specification omission of a reference to resistance of- jumpers for jumpered-terminals.

Example 2 - Failure of technician to follow procedure.

- Example 3 - Lack ~ of understanding of

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Procedure. 20407-C and/or performance by maintenance work- planners and maintenance personnel.

Example. 4 - This example was due to the misinterpretation of when review / initialing of the log was . required. The responsible shift supervisor interpreted that signed logs did' not also require initialing.

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Georgia Powerk l

ENCLOSURE 2 (Continued)

RESPONSE TO NRC NOTICE OF VIOLATION

~ Corrective ' steps which have been taken and the results achieved:

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_ Subsequent to the identification of the cited _ examples, . immediate corrective _ action ~ was taken to correct discrepancies prior to plant operation. - Additionally, lit.was noted in the LInspection Report that the drawings and vendor manuals _ addressed in Example 3 were the latest revisions and that the shift supervisor had provided verbal approval of.

work' that wasl addressed in Example 2.

Example 1 - The responsible foreman was counseled on the-importance of procedural compliance and , Technical Specification' values.

Procedure 28910-C, Revision 10, was approved on February 3, 1987 to correctly measure intercell resistance checks.

Example '2 - Work was stopped on the calibration of radiation monitor.

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1RE-12444C, the data sheet was updated to reflect a -Quality

> Control holdpoint review and -it was determined that a maintenance work - order was required to disassemble the detector skid.. Deficiency Report 1-87-203 was initiated to identify the discrepancy- and a " toolbox" training session was conducted to reemphasize procedural requirements with regard to calibration of radiation monitors.

Example 3 - Technicians were counseled on the importance of verifying that the current version of all working documents were being used in accordance with Procedure 00103-C. In addition, all supervisors and foreman were -instructed by letter to inventory" work packages twice weekly to ensure personnel are complying with procedural requirements.

) Example 4 - The Operations Supervisor and the Operations Superintendent supervising the responsible Shift Supervisor, individually

discussed the problem of misinterpreting the requirement to

' review / initial the appropriate logs. Each shift held a shif t briefing to emphasize the~ requirement to initial each document reviewed. A night order was written and posted to stress to the shift that it is required to initial each document reviewed.

In addition, an article emphasizing procedural requirements was placed in the Operations - Rcquired Reading Book to ensure that personnel who were not on shift when briefings 1

were held, would be cognizant of this event.

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- Georgia Power A ENCLOSURE 2 (Continued)

RESPONSE TO NRC NOTICE OF VIOLATION Corrective steps which will be taken to' avoid further violations:

Immediate corrective action was taken which should preclude recurrence of the cited events.

Date when full compliance will be achieved:

Full compliance was achieved on February 16, 1987, with the l'ssuance of Procedure 28910-C, Revision 10, and after completion of the actions detailed above.

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