ML20235J947
| ML20235J947 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 09/28/1987 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| SL-3229, NUDOCS 8710020173 | |
| Download: ML20235J947 (5) | |
Text
'A Geo g a Fbwer Cornpany
+
A 333 Piedrnont Avenue Attanta, Georg:a 30308 felephone 404 526-6526 Ma;'ing Address-Ibst Office Box 4545 Atlunta, Georgia 30302 h
Georgia Power L. T. Gucwa it >out'n <n eigtoc syWm Manager Nuclear Safety and Licensing SL-3229 0553m X7GJ17-V120 September 28, 1987 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, O.C.
20555 PLANT V0GTLE - UNIT 1 s
NRC DOCKET 50-424 OPERATING LICENSE NPF-68 RESPONSE TO NRC INSPECTION REPORT Gentlemen:
In accordance with the provisions of 10 CFR 2.201, Georgia Power Company (GPC) submits the enclosed information in response to NRC Inspection Report 50-424/87-44, which concerns the inspection conducted by Messrs. J. F. Rogge and R. J. Schepans of NRC Region II on. lune 20 -
July 24, 1987.
One apparent violation was cited.
A copy of this I
response is being provided to the NRC Region II office for review.
In the enclosure, transcription of the NRC violation precedes GPC's response.
An extension to the response due date was verbally requested by GPC during a telephone conversation with NRC Region II staff personnel on September 23, 1987 and was granted by the NRC.
Should you have any questions in this regard, please contact this office at any time.
Sincerely, W% sh /4 L. T. Gutwa JAE/Im
Enclosure:
1.
Violation 87-44-01 and GPC Response c:
(see next page) 8710020173 870928
/
PDR ADOCK 0500042r4 M
G PDR Y
4
e l
l Georgia Power n$
i I
U. S. Nuclear Regulatory Commission September 28, 1987 Page Two c:
Gepraia 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 Shaws Pitt man. Potts & Trowbridge Mr. B. H. ".hurchill, Attorney-at-Law Ifoutman. Sanders. Lockerman & Ashmore Mr. A. H. Domby, Attorney-at-Law U. S. Nilclear 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 Hs. C. Stangler 0553m 700775
Georgia Power 1 ENCLOSURE PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 NRC NOTICE OF VIOLATION 87-44-01 AND GPC RESPONSE VIOLATION 50-424/87-44-01:
" Technical Specification 6.7.1.a.
requires that written procedures be established, implemented and maintained covering activities delineated in Appendix A of Regulatory. Guide (RG) 1.33, Revision 1, February 1978.
Administrative Procedure (AP) 00307-C
describes the method to assure that Temporary Modifications are properly identified, controlled, and evaluated.
Contrary. to the above, on July '20, 1987, the NRC identified that AP-00307-C was not properly implemented in that on April 8,
1987, the turbine building and auxiliary building train "A" supply ventilation fan
-(equipment No.1-1540-B7-005) was removed from service for an indefinite period of time on clearance No.
1-87-1070 for personnel safety protection.
Failure to implement AP-00307-C prior to the hanging of the clearance resulted in a safety related system described in the FSAR being disabled from performing its intended safety function without an adequate engineering basis documented in the form of a safety evaluation as required by AP-00307-C.
This is a Severity Level IV violation (Supplement I)."
RESPONSE TO VIOLATION 50-424/87-44-01:
Admission or denial of alleaed violation:
A violation related to the circumstances described in the referenced Inspection Report and the associated Notice of Violation occurred.
The violation did not occur as specifically cited in the Notice of Violation in that implementation of Procedure AP-00307-C,
" Temporary Modifications," was not applicable to the establishment of the subject equipment clearance.
Removal from service of the Turbine Building and Auxiliary Building train "A" supply ventilation fan by opening a power supply breaker, of itself, is not a plant modification within the scope of Procedure AP-00307-C.
A procedure violation did occur,
- however, in that an inadequate I
evaluation of the requirement for operability of the subject fan under postulated accident conditions was performed prior to the issuance of the clearance.
0553m E-1 09/28/87 SL-3229
GeorgiaPower d ENCLOSURE (Continued)
EC NOTICE OF VIOLATION 87-44-01 AND GPC RESP _QEE Reason for the violation:
The violation occurred as a result of the limited scope of Procedure 00304-C, " Clearance and Tagging", in conjunction with an inadequate review of the impact ' of a noted design discrepancy (i.e., a firewall prevented proper air flow in the subject Turbine Building and Auxiliary Building Train."A" Tunnel.)
Specifically, the procedure does not directly require l
operability evaluations beyond those specified by the Technical Specifications before taking safety related systems out of service.
- Thus, the implications of the removal of the fan from service relative to assumptions made in the licensing analysis were not adequately evaluated.
These implications should have been addressed as part of the evaluation of the noted design discrepancy.
Therefore, the failure, due to oversight, of the system engineer to initiate a deficiency card upon discovery of the design discrepancy contributed to the event.
If the deficiency card had been initiated, an appropriate evaluation of the problem would have been made which could have precluded this violation.
l Corrective steos which have been taken and the results achieved 1 Deficiency Card 1-87-1862 was generated on July 21, 1987, to address the problem related to the subject fan in response to the concerns expressed by the NRC Resident Inspector.
Operations personnel promptly reviewed and processed the deficiency in accordance with the deficiency control procedure.
Engineering has determined that the fan may be out of service
{
so long as a predetermined temperature is not exceeded.
The fan may be activated manually by a switch located on the heating ventilation and air conditioning panel in the control room.
Should conditions dictate, the fan would be started and other compensatory actions taken, as appropriate.
In addition, Engineering personnel have been counseled on the importance of promptly generating deficiency cards when problems, including design deficiencies, are detected in the plant.
Corrective steos which will be taken to avoid further violations:
A review of Procedure 00304-C, " Equipment Clearance and Tagging", and Procedure 10005-C, " Operability Status Indication for Plant Safety Systems",
0553m E-2 09/28/87 SL-3229
""5
H.
Georgia Power 1 l
ENCLOSURE (Continued)
NRC NOTICE OF VIOLATION 87-44-01 AND GPC RESPONSE has been initiated to assure equipment being removed from service, or otherwise rendered inoperable,. receives the appropriate evaluation to determine the impact on associated systems.
In addition, Procedure 00150-C, " Deficiency Control", will be reviewed to assure that adequate provision is made ' for. proper consideration and disposition of noted design discrepancies.
These reviews will be completed and appropriate revisions approved by plant management' by December 15,-
1987.
Any training required as a result of these potential revisions will be completed and the revised procedures implemented within one month of their approval.
An evaluation to address the long term resolution the the design discrepancy which necessitated, the removal of the subject fan from service will be performed by November 15, 1987.
That resolution, be it physical modifications or revision of the licensing documents, will be scheduled for implementation upon definition.
Date when full comoliance will be achieved:
Full compliance has been achieved in that an adequate engineering basis for removal of the fan from service has been performed and documented.
0553m E-3 09/28/87 SL-3229m
- 70CM5