ML20215G594
| ML20215G594 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 06/18/1987 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| SL-2607, NUDOCS 8706230311 | |
| Download: ML20215G594 (5) | |
Text
Georgia Fbwer Company 333 P4edmont Avenue Atlanta, Georgia 30308 Telephone 404 526-6526 Ma?ing Address:
Fbst Office Box 4545 Athnta, Georgia 30302 h
Georgia Power L T. Gucwa the southem electnc system Manager Nuclear i afety and Ocensing 0331m X7GJ17-V120 June 18, 1987 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 RESPONSE TO NRC INSPECTION REPORTS 4
Gentlemen:
Pursuant to the provisions of 10 CFR 2.201, Georgia Power Company (GPC) submits the following information in response to NRC Inspection Reports-50-424/87-24 and 50-424/87-27 for Plant Vogtle Unit 1 concerning -
the inspections conducted by Mr.
P.
Burnett of NRC Region II on March 6-20, 1987 and Messrs.
H.
H.
Livermore, J.
F.
- Rogge, and R. J. Schepans, also of NRC Region II on March 10 - April 17, 1987, respectively.
Two apparent violations were cited in the Notices of Violation for Plant Vogtle Unit 1.
A copy of this response has been provided to NRC Region II for review.
I As discussed with Region II staff, one response is being submitted for both identified violations because procedural inadequacies addressed q
in the Notices of Violation are for the same procedure, 14905-1, and the corrective actions were the same for both violations.
He believe that the Notice of Violation for NRC Inspection Report 50-424/87-27 as submitted by NRC Region II letter dated May 19, 1987, incorrectly refers to Plant Vogtle Unit 2 by docket number and as a result implies that it is in violation also.
The Report Details section of the Inspection Report specifically identifies the violation as being applicable to Plant Vogtle Unit 1
by the violation designator "50-424/87-27-02." Accordingly, our response addresses only Plant Vogtle Unit 1.
Unless we hear otherwise, we will assume that our determination on applicability is correct.
j i
A transcription of the NRC Notices of Violation is provided as.
GPC's response is provided as Enclosure 2.
kONbN 5%y
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GeorgiaPower A U. S. Nuclear Regulatory Commission June 18, 1987 Page Two I
Should you have.any questions in this regard, please contact this office at any time.
Sincerely, L. T. Gucwa JAE/1m
Enclosures:
1, NRC Notices of Violation 2.
Georgia Power Company Response c: Georaia Power Comoany Mr. R. E. Conway Mr. J. P. O'Reilly Mr. G. Bockhold, Jr.
Mr. J. F. D'Amico Mr. C. H. Hayes-G0-NORMS Southern Comoany Services Mr. R. A. Thomas Mr. J. A. Bailey Shaw. Pittma,1. Potts & Trowbridae Mr. B. H. Churchill, Attorney-at-Law Troutman. Sanders. Lockerman & Ashmore Mr. A. H. Domby, Attorney-at-Law U. S. Nuclear Reaulatory Commission Dr. J. N. Grace, Regional Administrator Ms. M. A. Miller, Licensing Project Manager, NRR (2 copies)
Mr. J. F. Rogge, Senior Resident Inspector-Operations, Vogtle Georaians Aaainst Nuclear Enerov Hr. D. Feig Ms. C. Stangler 0331m 7WMS.
GeorgiaPower A J
ENCLOSURE 1 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 NRC NOTICES OF VIOLATION I
y10LATION 50-424/87-24-01
" Technical Specification 4.4.6.2.1 - requires that the reactor coolant system unidentified leakage be demonstrated to be less than one gallon per minute in modes 1,
2, 3,.and 4. by the performance of ~a reactor coolant system inventory balance at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Contrary to the above, Procedure 14905-1 in use for this Technical Specification surveillance during a period encompassing March -7,
- 1987, was inadequate to perform the task in that it did not properly account for. changes in average-system temperature or pressurizer level in determining the change in inventory.
This is a Severity Level IV violation-(Supplement I)."
VIOLATION 50-424/87-27-02
" Technical Specification 6.7.la requires that procedures shall be established, covering activities delineated in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Operations Procedure No..14905-1, Rev.
6 "RCS Leakage Calculation (Inventory Balance)" contains the methodology to calculate unidentified leakage.
Contrary to the above, on April 7, 1987, the NRC inspection identified that Operations Procedure No. 14905-1 had not been adequately established in that the procedure was not capable of calculating the unidentified leakage appropriately to determine if the acceptance criteria had been exceeded.
This is a Severity Level IV Violation (Supplement I)."
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GeorgiaPower A ENCLOSURE 2 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 RESPONSE TO NRC NOTICES OF VIOLATION RESPONSE TO VIOLATIONS 50-424/87-24-01 AND 50-424/87-27-02 Admission or denial of alleaed violations:
The events did occur as stated in the Inspection Reports.-
Reason for the violations:
Procedure 14905-1 was implemented to meet Technical Specification 4.4.6.2.1.d with the required compensation for pressure isolation valves (PIV) leakage performed in accordance with Procedure 14450-1.
PIV leakage was measured at a test pressure less than operating pressure and corrected per the requirements of the 1983 edition of the ASME Section XI Code, Paragraph IWV-3427(b).
The correction produced a potentially high PIV leak rate resulting in a negative unidentified leak rate value.
Additionally, the RCS water volume used in the development of Procedure 14905-1 was determined to be too small.
After additional reviews and discussions, it was determined that a larger RCS water volume was more appropriate and was more consistent with the RCS leak rates calculated in accordance with NUREG-1107, "RCSLK9:
Reactor Coolant System Leak Rate Determination for PWRs."
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GeorgiaPower d l
ENCLOSURE 2 (Continued)
RESPONSE TO NRC NOTICES OF VIOLATION
_ Corrective steos which have been taken and the results' achieved:
Procedure :14905-1 was revised to provide correction factors for RCS temperature, pressurizer level, chemistry sampling, CVCS filter leakage, and pressure isolation valve leakage.
Subsequent to issuance of revised
' Procedure 14905-1, no negative unidentified leak rates have been
. calculated.
Additionally, the Operations Department has utilized the RCSLK9 program to validate Procedure 14905-1 calculations with results obtained being within the.2 GPM for acceptable procedures.
Corrective steos which will be taken to avoid further violations:
Corrective actions for these violations have been completed.
Date when full como11ance will be achieved:
Full compliance was achieved with. the approval and implementation of Procedure 14905-1, Revision 8, dated May 8, 1987.
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