ML20215J919
| ML20215J919 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 05/01/1987 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| SL-2450, NUDOCS 8705080330 | |
| Download: ML20215J919 (7) | |
Text
r; Georgi 2 Power cornpany 333 Piedmont Avenue
^ ' ~
' Atlanta.Georgta 30308 I lephons 404 526-6526 Mailing Address; Ebst office Box 4545 Atlanta. Georgia 30302 -
GeorgiaPower s
L. T. Gucwe the soutt'em etictnc syMem Manager Nuclear Safety
""d " *"S'"8 SL-2450 0269m May 1, 1987 U. ' S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 PLANT V0GTLE - UNIT 1 NRC DOCKET NUMBER 50-424 OPERATING LICENSE NPF-68 RESPONSE TO NRC INSPECTION REPORT Gentlemen:
Pursuant to the provisions of 10 CFR 2.201, Georgia Power Company (GPC) submits the enclosed information in response to NRC Inspection Report 50-424/87-12, which concerns the inspection conducted by-Messrs.
H. H. Livermore, J. F. Rogge, and R. J. Schepans from January 24 to March 9, 1987.
A copy of this response is being provided to the NRC Region II Office.
Two apparent violations were identified in the subject inspection report.
A transcription of the NRC Notice of Violation is provided as.
GPC's response is provided as Enclosure 2.
Please contact this office if you have any questions.
Sincerely,
- 4 -- =
L. T. Gucwa JH/1m
Enclosures:
1.
NRC Notice of Violation 2.
Response to NRC Notice of Violation c:
(see next page) l 8705000330 070501 PDR ADOCK 05000424 G
PDR l
J
Georgia Power d '
U. S. Nuclear Regulatory Commission MAy 1, 1987 Page 2 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 G0-NORMS Southern Company Services Mr. R. A. Thomas Mr. J. A. Bailey Shaw, Pittman, Potts & Trowbridge Mr. B. W. Churchill, 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 J
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Georgia Power A ENCLOSURE 1 NRC NOTICE OF VIOLATION GEORGIA POWER COMPANY PLANT V0GTLE UNIT 1
-OPERATING LICENSE NO. NPF-68 NRC INSPECTION REPORT NO. 50-424/87-12 MAY 1, 1987 VIOLATION 50-424/87-12-01:
" Technical Specification 6.7.la. requires that written procedures be established, implemented and maintained covering activities delineated in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, February 1978.
Operations Procedure No. 10019-C, Rev. 0 " Control of Safety Related Locked Valves" establishes the guidelines including the use of the independent verification policy (00308-C) for controlling locked valves in safety related systems.
Contrary to the above, Procedure No. 10019-C " Control of Safety Related Locked Valves" was not implemented in that:
1.
On February 18, 1987, after an outage on the Train A Diesel Generator (DG-1A) and during the initial performance of the DG-1A Operability Surveillance Test Procedure No. 14980-1 the main fuel oil valve (1-2403-U4-031) was found in the locked closed position in lieu of the required locked open position.
2.
On February 26, 1987, during a NRC inspection of the Auxiliary Feedwater System Valve Lineup the Steam Generator No. 2 main steam supply valve (1-1301-04-007) to the turbine driven Auxiliary Feedwater Pump was found to be in the locked closed position in lieu of the required locked open position.
l This is a Severity Level IV Violation (Supplement I)."
i Violation 50-424/87-12-02:
l l
"10 CFR 50, Appendix 8, Criterion V, and the accepted QA program (FSAR l
17.2.5) collectively require that activities affecting quality be l
prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstance and be accomplished in accordance with l
these instructions, procedures, or drawings.
l l
l l
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A Georgia Power d ENCLOSURE 1 NRC NOTICE OF VIOLATION Contrary-to the above, an activity.affecting quality, Procedure 50040-C, Rev 0,
" Component Cyclic or ' Transient Limits, was not appropriate in establishing an adequate program for tracking and evaluating Transient or Operational cycles in that:
1.
No full definition of. what constitutes a cycle. other than presented in Technical Specification existed.
2.
The systems, structures, or. components of-concern were not identified to support a proper evaluation of when a cycle had occurred.
3.
No method existed for partial cycle counting.
4.
Notification to engineering was not established within all referenced' procedures.
5.
Cycle collection and evaluation on equipment that is not in 'the Technical Specification had not been established.
6.
Not all cycles placed on -the plant from Hot Functional Test ~ to present had been counted.
This is a Severity Level V Violation (Supplement I)."
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L-l i
r 0269m El-2 5/1/87 SL-2450 1
700775
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Georgia Power 1 ENCLOSURE 2 RESPONSE TO NRC NOTICE OF VIOLATION GEORGIA POWER COMPANY PLANT V0GTLE UNIT 1 OPERATIONS LICENSE NO. NPF-68 NRC INSPECTION REPORT NO. 50-424/87-12-02 MAY 1, 1987 V(%
ResDonse to Violation 50-424/87-12-01:
Admission or Denial of Alleaed Violation:
Although our procedure was not properly implemented, we are pleased to report that the events did not result in a safety problem.
Specifically the events did occur as stated in the Inspection Report.
Part 1: When Diesel Generator 1A tripped on February 18, 1987, due to the mispositioned main fuel oil
- valve, the plant was in Operating Mode 5.
Technical Specification 3.8.1.2 requires at
</
least one operable off-site circuit and one operable Diesel Generator while in Mode 5.
Both off-site circuits and Diesel
/j t
Generator 1B were operable when Diesel 1A tripped, thus plant safety was not actually compromised.
The Diesel 1A valve lineup t'
was corrected immediately after the trip.
Part 2: When the Turbine Driven Auxiliary Feedwater Pump (TDAFHP) steam supply valve was found in the locked closed position, the plant was in Mode 3 and had not yet made initial entry into Mode 2.
Technical Specification 3.7.1.2 issued with low power license NPF-61 was not applicable until initial entry into Mode 2.
Additionally, the TDAFHP has two steam supplies and one steam supply was still operable, thus plant safety was not compromised.
Reason for the Violation:
The violation occurred as a result of a failure to adequately implement the " Locked Valve Hanipulation Log" as required by Procedure 10019-C and failure to adequately verify proper equipment configurations following l-maintenance activities.
(
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.e Georgia Power A ENCLOSURE 2 RESPONSE TO NRC NOTICE OF VIOLATION Corrective Steos Hhich Have Been Taken and the Results Achieved:
1.
As. noted in the ' inspection report, 'a locked ' valve ' manipulation ~ log was implemented on February 24.- 1987, per Procedures. 11888-1 and 10019-C.
2.
All operating crews-have been counseled on the necessity of i
maintaining proper system configurations and the - methods of doing so.
They have also been counseled on the requirements for restoring equipment following extensive outages.
~
1-87-073) was written on March 9, 1987 on the 3.- A Deficiency Card (DC Diesel Generator incident.
The necessity to properly document all deficient conditions per Procedure 00150-C has been emphasized to the Operations staff.
i Corrective Steos Which Hill Be Taken to Avoid Further Violations:
-1.
Procedure 10019-C is being revised to provide an updated listing of valves.
Procedure 11888-1 is being-revised to provide for signing in and out the keys to locked valves in addition to other changes to enhance its use.
2.
A special Task Force is being-established to review, in detail, valve position problems and the subject of independent verification.
3.
Our Safety Review Board has been directed to review this matter in that we consider this issue to be important.
Date when Full Comoliance Hill be Achieved:
I Full compliance will be achieved when the above revisions to Procedures i-10019-C and 11888-1 are completed. This is scheduled for June 15, 1987.
Response to Violation 50-424/87-12-02:
Admission or Denial of Alleaed Violation 1 1
The cited events occurred as stated in the inspection report.
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Georgia Power d ENCLOSURE 2 RESPONSE TO NRC NOTICE OF VIOLATION Reason for the Violation:
The violation occurred as a result of narrowly focusing on Technical Specification requirements for the basis of the program.
Corrective Actions Which Have Been Taken and Results Achieved:
A meeting was held among the Plant Manager and the Operations and Engineering department heads to coordinate assignments for development of an adequate and detailed program to meet our requirements.
Our preliminary review of data collection requirements has been completed.
Corrective Steos Hhich Hill Be Taken to Avoid Further Violations:
In developing the detailed program, engineering evaluations will be performed to define the transients and the specific data or parameters required.
Upon completion of these evaluations, Procedure 50040-C,
" Component Cyclic or Transient Limits" and other affected procedures will be promptly revised. The revised program and procedures are scheduled to be implemented by June 15, 1987.
Following implementation of the new program, historical records will be reviewed to ensure that the necessary transient data is collected and included in our records.
Date When Full Comoliance Hill Be Achieved:
Full compliance will be achieved when the detailed program for collecting and evaluating transient data is implemented and the review of historical data is complete.
These activities are scheduled for completion by August 15, 1987.
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