ML20217N743
| ML20217N743 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/29/1998 |
| From: | Woodard J SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-424-98-02, 50-424-98-2, 50-425-98-02, 50-425-98-2, NUDOCS 9805050412 | |
| Download: ML20217N743 (3) | |
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J. D. Woodard -
Southern Nuclear l
. Executive Vice Presidant :
Operating Company,Inc.
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40 invemess Center Parkway Post Office Box 1295 i
Birmingham. Alabama 35201 Tel 205.992.5006 k
SOUTHERN L COMPANY
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Apri3'29, 1998 Energy to ServeYourWorld" LCV-1208 Docket Nos.: 50-424
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50-425 U. S. Nuclear Regulatory Commission i
ATTN: Document Control Desk Washington, D. C. 20555 Ladies and Gentlemen:
VOGTLE ELECTRIC GENERATING PLANT REPLY TO A NOTICE OF VIOLATION Pursuant to 10 CFR 2.201, Southern Nuclear Operating Company (SNC) submits the enclosed information for Vogtle Electric Generating Plant (VEGP)in response to a Notice
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of Violation (NOV) identified in Nuclear Regulatory Commission (NRC) Inspection Report No. 50-424; 425/98-02 which concerns an inspection conducted from January 25, 1998 through March 7,1998.
j Should you have any questions, please contact this office.
Sincerely, J
J.
. Woodard l.
JDW/CTT/bhw
Enclosure:
Reply to Notice of Violation 50-424;425/98-02-01 xc: Southern Nuclear Operating Company Mr. J. B. Beasley, Jr.
Mr. M. Sheibani SNC Document Management
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.U. S. Nuclear Regulatory Co. mmission T
Mr. L. A. Reyes, Regional Administrator p
Mr. D. IL Jaffe, Senior Project Manager, NRR Mr. J. Zeiler, Senior ResMent Inspector, VEGP 980505d412990429
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ENCLOSURE 1 VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424; 425/98-02 VIOLATION,50-424;425/98-02-01 s
The following is a transcription of the violation ae. cited in the Notice of Violation (NOV):
"During an NRC inspection conducted January 25 through March 7,1998, a violation of NRC requirements was identified. In accordance with the ' General Statement of Policy and Procedure for NRC Enforcement Actions,' (NUREG 1600), the violation is listed below:
Technical Specifications 5.4.1.a requires that written procedures be implemented for the activities identified in Appendix A of Regulatory Guide (RG) 1.33, Revision (.Rev.) 2, including procedures for making TS Limiting Conditions for Operation (LCO) log entries.
Procedure 10008-C, ' Recording Limiting Conditions for Operation,' Rev. 20, was provided to prescribe the method for recording the failure to meet a TS LCO or Technical Requirement (TR). This procedure required completion of a LCO/TR Status Log entry prior to the end of shift if entry into an action statement is required.
Contrary to the above, on February 19,1998, the Unit 2 Shift Supervisor authorized maintenance on Control Room Emergency Filtration System train B without recognizing the work would render the train inoperable and subsequently failed to document entry into the applicable LCO for TS 3.7.10, ' Control Room Emergency Filtration Sys+em - Both Units Operating' prior to the end of shift.
This is a Severity Level IV violation (Supplement I). This violation is applicable to Unit 2 only."
RESPONSE TO VIOLATION (50-424;425/98-02-01)
Admission or Denial of the Violation:
This violation occurred as stated in the notice of violation.
Reason for the Violation:
On February 19,1998, the Unit 2 Shift Supervisor (USS) authorized maintenance on Unit 2 "B" Train Control Room Emergency Filtration System (CREFS) to replace the silicon-controlled rectifier on the heater control panel. This work made the available heater capacity less than that required by Technical Specifications (TS) 5.5.11," Ventilation Filter Testing Program," thus rendering the B Train CREFS inoperable. Failure to meet TS 5.5.11 causes surveillance I
ENCLOSURE 1 l
r VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424; 425/98-02 requirement SR 3.7.10 to not be satisfied. The USS failed to recognize that he no longer met the LCO requirements for TS 3.7.10.
Contributing factors to the USS's failure included:
The USS did not obtain a thorough understanding of the work to be performed and therefore, failed to apply the appropriate TS.
1 Personnel who processed the work order (WO) had detailed knowledge of the work to be performed. However, the WO did not provide sufficient information about the impact to system operability.
Corrective Steps Which Have Been Taken and the Results Achieved:
1.
On February 20,1998.. a system engineer and a different USS reviewed the work status and identified the need for entry into the required action statement for TS 3.7.10. The TS was entered and conective maintenance activities and functional testing were completed.
As a result, the duration that Unit 2 Train B CREFS was inoperable did not exceed the completion time for the applicable TS required actions.
2.
The USS was counseled concerning this violation and the need to thoroughly review all applicable requirements prior to determining LCO status.
Corrective Steps Which Will Be Taken to Avoid Further Violations:
1.
Expectations for appropriately detailed technical review of work for applicable TS impacts will be reinforced to licensed supervisors in requalification training. This training will be completed by June 15,1998.
2.
Specific training to strengthen licensed operator knowledge of TS section 5.0 will be conducted. This training will be completed by July 17,1998.
3.
Procedure 00350-C, " Work Request Program", will be revised to more clearly indicate responsibility for LCO review of WOs. Affected personnel will be trained on these responsibilities. This will be completed by May 31,1998.
c Date When Full Compliance Will Be Achieved:
Full compliance was achieved on February 20,1998, when personnel documented the applicable LCO entry and exit.
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