ML20235U094
| ML20235U094 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 10/05/1987 |
| From: | James O'Reilly GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| EA-87-115, SL-3315, NUDOCS 8710130357 | |
| Download: ML20235U094 (12) | |
Text
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Georgia Fbwer Company a
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- 333 Piedmont Avenue Atlanta Georgia 30308 Telephone 404 526 7851 Maihng Address:
Post Othee Box 4545 Atlanta Georgia 30302
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James P. O'Reitty tre southerrt ela:ttg. system Senior Vice President
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Nuclear Operabons j
l SL-3315 0538m X7GJ17-V120 l
October 5, 1987 i
Director, Office of Enforcement U. S. Nuclear Regulatory Commission ATTN: Document Control Desk q
Hashington, D.C.
20555 l
PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 REPL'/ TO A NOTICE OF VIOLATION i
Gentlemen:
In accordance with the provisions of 10'CFR 2.201, Georgia Power l
Company (GPC) hereby submits its response to NRC Region II Enforcement i
Action letter EA 87-115 dated September 3, 1987.
The subject NRC letter I
l concerned the inspections conducted on April 18 - May 22 and on May 23 -
June 19, 1987, at the Vogtle Electric' Generating Plant - Unit 1.
The inspections included a review of the circumstances surrounding' the interpretation of Technical Specifications for the Reactor Trip 8reakers and the Residual Heat Removal (RHR) Systein.
Georgia Power Company's response to_the cited violations is povided as Enclosure 1.
Payment of the $50,000 Civil Penalty is provided as Enclosure 2. ~A copy of this response is-being provided to the NRC Region II office for review.
The violations described in the Notice of Violation and Proposed l
Imposition of Civil Penalty (Notice) which accompanied the enforcement action letter are considered significant by GPC since these events represent non-conservative interpretations of the Technical Specifications by licensed senior reactor operators. Our concern is heightened by identification, during recent discussions with NRC i
inspectors, of similar problems with definitions and interpretations related to Diesel Generator performance and surveillance.
In order to correct this broad concern, we have initiated a special training program i
under the direction of the Manager of Nuclear Safety and Licensing which l
will involve the managers, supervisors, and the licensed operators from j
the Operations Department, as well as key personnel in the onsite Nuclear Safety and Compliance organization.
The scope of this special program h
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U..S. Nuclear Regulatory Commissior, October 5, 1987 l
Page Two i
.l will include tha bases of selected Technical Specifications, the revised process of Technical Specification interpretation, and sensitivity to licensing issues. This program, which will utilize the knowledge and experience of both senior plant and corporate managers, will address the broader implications of the cited events.
This program is in addition to the specific corrective actions noted in the enclosed detailed discussions of the cited events. Completion of this program is scheduled for January 31, 1988.
This schedule will allow thorough and orderly
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training of all crews.
GPC shares the NRC's belief stated in the Enforcement Action letter that good communication is necessary to assure that a proper evaluation of component operability is made and that the requirements of Technical Specifications are met. Good communication is vital in all aspects of plant operation, particularly in off-normal situations.
Based on this identified need, we have already made substantial improvements in interpersonal and interdepartmental communications, and in employing an enhanced teamwork approach to operations'. A cornerstone of these improvements is the Bi-Heekly Operations Status Review Meeting held among on-site and corporate managers, including the Senior Vice President of Nuclear Operations.
In these on-site meetings, key issues are discussed in depth to focus the entire management team's attention to the critical decisions required to ensure safe, efficient plant operations.
In addition, these meetings serve as a high-level interdepartmental forum to optimize effective teamwork, evaluate. performance trends, and to evaluate individual's concerns and suggestions.
i Other examples of ongoing efforts to provide major improvements in plant operations are the Positive Valve Program, Event Analysis and l
Resolution Program, Trip Reduction Committee, weekly management problem j
solving meetings, interdepartment meetings to review situations where potential for operational error existed but.did not occur, and the Vogtle Improvement Program (VIP).
The VIP effort is, as discussed in recent meetings with the NRC, a comprehensive management approach to excellence in plant operations.
Among other aspects of operations addressed by the VIP are achievement through' teamwork and good communications.
The VIP focuses on a number of=
0538m I
U. S. Nuclear Regulatory Commission October 5, 1987 Page Three key issues regarding good communications and effective use of available expertise through teamwork.
Improvements have already been made in the following areas:
o shift briefings with key personnel to provide direction and specify levels of support; I
o pre-evolution briefings with Key personnel before plant l
transients are initiated; o status meetings during the shift to discuss key problems and the course of action undertaken; o operating shift personnel's use of groups outside the Operations Department, particularly the system engineers, for resolving problems and making technical interpretations; o deficiency cards and shift logs; and o event summaries, written critiques, daily work plans, and outage schedules.
GPC believes that the emphasis placed on good communications and teamwork by these initiatives have substantially enhanced plant operations.
These actions, particularly the Bi-Weekly Operations Status Review Meeting, are designed to assure positive implementation over the long term.
He believe that the aforementioned actions, in conjunction with those specific corrective actions discussed in the enclosed response to the cited events, address the NRC's concerns.
While we fully acknowledge the significance of these events, we feel it necessary to note that the cited violations concern matters of technical interpretation and engineering judgement.
Further, we wish to note that necessary corrective actions to respond to the problems cited in the NRC enforcement action letter were taken in a prompt and comprehensive manner.
We are disappointed that the NRC has found it necessary to emphasize its concern by the issuance of a civil penalty on these matters.
GPC reaffirms its commitment to compliance with NRC requirements and has devoted, and will continue to devote, resources to achieve that goal.
0538m
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l U. S. Nuclear Regulatory Commission October 5, 1987 l
Page Four Should you have any questions regarding this reply, please contact this office.
l James P. O'Reilly states that he is Senior Vice President of Georgia Power Company and is authorized to execute this oath on behalf of Georgia Power Company, and that to the best of his knowledge and belief, the facts set forth in this letter and enclosure are true.
GEORGIA POWER COMPANY l
By:
wtk&\\N Ja s P. O'Reilly
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i Sworn to and subscribed before me this 5th day o cto er, 1987.
OwavI'7And Not@y@ublic Notary Pubuc, Cobb County.Ga, j
My Commission Emires Mayli,1990 HEB/JAE/1m
Enclosures:
1.
NRC Notice of Violation "A" and "B" and GPC Response j
2.
Payment of Civil Penalty - GPC check no. 024390 dated 09-21-87 j
c:
(see next page) 1 0538m
U. S. Nuclear Regulatory Commission October 5, 1987 Page Five c: Georaia Power Comoany Mr. R. E. Conway Mr. G. Bockhold, Jr.
Mr. J. F. D'Amico Mr. L. T. Gucwa Mr. C. H. Hayes GO-NORMS Scythern Company Services Mr. R. A. Thomas Mr. J. A. Bailey Shaw. Pittman. Potts & Trowbridag Mr. B. H. Churchill, Attorney-at-Law Troutman. Sanders. Lockerman & Ashmore Mr. A. H. Domby, Attorney-at-Law U. S. Nuclear Regulatory Commission Document Control Desk, USNRC 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 Georaians Against Nuclear Enerav Mr. D. Feig Hs. C. Stangler 0538m t
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l ENCLOSURE PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 l
OPERATING LICENSE NPF-68 NRC NOTICE OF VIOLATION "A" AND "B" AND GPC RESPONSE "A. Technical Specification (TS) 3.3.1 and associated Table 3.3-1 require, in part, that a minimum of two channels of_the Reactor Trip Breaker _(RTB) functional unit of the Reactor Trip System (RTS) be operable in Modes 1 and 2.
The associated action statement (Action Statement 10) requires that with the number of operable channels one less than the " minimum channels operable" requirement, the unit must be in at least hot standby within six hours; however, one channel may be bypassed for up to two hours for surveillance testing per Technical Specification 4.3.1.1, provided the other channel is operable.
Contrary to the above, on June 2, 1987, one of the two RTS channels required for operation (one less than the minimum channel operable requirement) became inoperable in that the "B" RTB was bypassed for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and 34 minutes with the unit in Mode 1 (power operation), and the unit was not placed in hot standby within six hours as required by Action Statement 10.
B.
10 CFR Part 50, Appendix B, Criterion XVI, requires, in part, that conditions adverse to quality such as deficiencies be promptly identified and corrected.
Contrary to the above, at 1:45 p.m. on April 28, 1987, the Residual Heat Removal Heat Exchanger outlet valves (1HV-0606 and 1HV-0607) were identified to be less than full open, and prompt actions were not taken to correct the deficiencies.
The On-Shift Operations Supervisor did not recognize that the as-found valve positions affected the operability of the system as defined'in the Technical Specifications.
The valves were not restored to full open condition until 10:00 p.m. on April 29, 1987. As a result of the partial closure of these valves, the RHR flow during the low pressure i
injection operation was calculated to be potentially below the i
minimum TS value of 3788 gpm.
Train A was determined to be 3762 gpm l
(.7 percent below TS limit) and Train B to be 3686 (2.7 percent below 1
TS limit).
Collectively, these violations have been categorized as a Severity Level l
III violation (Supplement I).
Civil Penalty -'$50,000 (assessed equally between the violations)."
0538m E-1 10/5/87 SL-3315
I ENCLOSURE (Continued)
NRC NOTICE OF VIOLATION "A" AND "B" AND GPC RESPONSE RESPONSE TO VIOLATION "A"
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Reference:
Violation 50-424/87-37-01 regarding Reactor Trip Breakers)
Admission or denial'of alleaed violation:
GPC agrees that the "B" RTB was bypassed for a period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 34 minutes beyond the 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> allowed by Technical Specification Table 3.3-1 Action Statement 10, and that the unit was not placed in hot standby within that time.
Reason for the violation:
The cited violation resulted from.an interpretation by a shift supervisor of an ambiguous Technical Specification. As currently written, the applicability of Action Statement 13 of Technical Specification Table 3.3-1 is unclear.
It allows operation for up to forty-eight hours with one of the diverse trip features inoperable in recognition of the ability of either of the diverse trip features to initiate a reactor trip on demand.
It further allows the' breaker to be bypassed for maintenance to restore the breaker to operable' status. Action Statement 10 states:
"Hith the number of OPERABLE channels one less than the minimum channels OPERABLE requirement, be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; however one channel may be bypassed for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing per specification 4.3.1.1, provided the other channel is OPERABLE."
However, no time limit for bypass operation is specified in Action Statement 13, and'there is no indication that Action Statement 10 applies concurrently.
Thus, one can reasonably, albeit incorrectly, conclude that the forty-eight hour allowance applies to the maintenance action required to restore the trip feature to an operable condition.
This logic was used in the determination by the. shift supervisor that Action Statement 13 was applicable, the operability of the breaker was addressed by the provision of Action Statement 13, and that the plant could, I
therefore, continue to operate for forty-eight hours while maintenance was performed on the trip feature.
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ENCLOSURE (Continued) i NRC NOTICE OF VIOLATION "A" AND "B" AND GPC RESPONSE
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Corrective steos which have been taken and the results achieved:
1.
The trip breakers, notwithstanding the subsequent discussion, were restored in the normal manner to a fully operable status upon conclusion of the approximately 8 and 1/2 hour repair of the trip feature.
2.
On June 19, 1987, the NRC's interpretation of Technical Specification 3.3.1 was provided by the Resident Inspector after consultation with the Office of Reactor Regulation.
A GPC clarification of the specification specifying concurrent application of Action Statements 10 and 13 was promptly issued to operations personnel.
3.
Training on the specific circumstances of the event, system design and operations, and the specific Technical Specification interpretation has been completed.
Corrective steos which will be taken to avoid further violations:
Corrective steps to prevent further violations have already been completed as noted above.
However, a proposed revision to Technical Specification Table 3.3-1 is scheduled to be submitted to the NRC by January 31, 1988, to clarify the meaning of Action Statement 13 to obviate the need for the aforementioned written interpretation (e.g.,
with one of the diverse trip features, undervoltage or shunt trip attachment, inoperable restore it to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or declare the breaker inoperable and apply ACTION 10.
The breaker may be bypassed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for performance of maintenance to restore the breaker to OPERABLE status, provided the other channel is OPERABLE
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Date when full como11ance will be achieve 4:
l Full compliance was achieved with the completion of maintenance and restoration of the "B" RTB on June 2, 1987.
0538m E-3 10/5/87 SL-3315
ENCLOSURE (Continued)
NRC NOTICE OF VIOLATION "A" AND "B" AND GPC RESPONSE i
i RESPONSE TO VIOLATION "B"
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Reference:
Violation 50-424/87-31-02 regarding RHR valves)
Admission or denial of alleged violation:
GPC agrees that on April 28, 1987, the Residual Heat P9moval (RHR) Heat Exchanger outlet valves (1HV-0606 and 1HV-0607) were identified to be less than fully open, and were not restored to the fully open condition until April 29, 1987.
Further, it is agreed that a potential for less than the Technical Specification value for minimum RHR flow through those valves existed during this period.
Reason for the violation:
On April 28, 1987, at approximately 13:45 CDT, the Residual Heat Removal test engineer observed that RHR valves 1-HV-0606 and 1-HV-0607 (heat exchanger outlet valves for Train "A" and "B", resp'ctively) were 90 to 95% open, when they should have been fully open.
It was also determined that there was full demand (100%) on the remote hand controllers, HIC l
0606A and HIC 0607A, and the valves' status monitor lights indicated the i
valves were fully open.
The On-Shif t Operations Supervisor (OSOS) discussed the condition of the Residual Heat Removal (RHR) System with two engineers and the system engineer who discovered the condition.
Following a review of the FbAR, Technical Specifications, surveillance procedures, and vendor drawings, the OSOS judged the system to be l
operable and capable of performing its design function.
l Maintenance work orders were written to restore the valves to their fully open position. Since the RHR System was still judged operable, the work was processed in accordance with normal procedures and completed the next day.
Based on all immediately available information, the OSOS made what he believed to be a reasonable decision regarding operability and subsequent repairs were, under that assumption, made in a timely manner.
0538m E-4 10/5/87 SL-3315 i
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ENCLOSURE (Continued)
NRC NOTICE OF VIOLATION "A" AND "B" AND GPC RESPONSE The two valves. 1-HV-0606 and 1-HV-0607, are 8-inch butterfly valves, manufactured by Fisher Controls Company (Continental Division). On January 9, 1987, and on February 3, 1987, Surveillance Procedure 14896-1, u
"ECCS Check Valve Cold Shutdown Inservice Test," was' performed for RHR l
Trains "B" and "A", respectively, to verify check' valve' position.
The flow rates recorded during this surveillance were 3875 gpm for Train "A" and 3829 gpm for Train "B", above the Technical Specification minimum
' flow rate limit of 3788 gallons per minute (GPM). On April 21, 1987, Surveillance Procedure 14460-1 was conducted which verified that valves 1-HV-0606 and 1-HV-0607 were in the ~ full open position. On April 25, 1987, maintenance was performed on each valve to investigate reported seat leakage. While investigating the seat leakage for 1-HV-0607, the limit switches and valve linkage were removed, inspected, and replaced, but technicians stated that no adjustments were necessary for either valve during this work.
The valves were fully stroked.
The partial closure of valve 1-HV-0606 was caused by a cable ID tag restricting the movement of the bellows assembly in the controller.
The valve controller for 1-HV-0606 was also out of calibration.
Valve 1-HV-0607 was partially closed because the positioner was out of calibration. 'This affected the valve opening stroke and prevented the valve from fully opening.
No work was performed on the controllers during the April 25, 1987, maintenance described above.
Therefore, it is unlikely that this work could have contributed to the controllers-being out of calibration.
Furthermore, it is possible that the problem existed at the time of the i
surveillance on January 9 and February 3, 1987, in which case the minimum flow rate was met.
The valves were roughly determined as being 90~to 95% open by the systems engineer, therefore, the most conservative value of 90% open was used for all flow calculations.
Investigation into the throttling of RHR valves 1-HV-0606 and 1-HV-0607 was completed on May 14, 1987.
The review determined that the calculated flow rate with the valves 90% of full open
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0538m E-5 10/5/87 SL-3315 j
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i ENCLOSURE (Continued)
NRC NOTICE OF VIOLATION "A" AND "3" AND GPC RESPONSE was 3762 gpm for~1-HV-0606 and 3686 gpm for 1-HV-0607; which is below the specified minimum of 3788 gpm.
Further calculations determined that the minimum valve position required to achieve 3788 gpm for valves 1-HV-0606
-and 1-HV-0607 is 91. percent and 92.5 percent open, respectively.
Therefore, the partial closure of the valve to 90 percent open could have possibly reduced the flow to a value. below the margin of safety established in the Technical Specifications for one subsystem. However, the percentage of partial closure could not be precisely determined and the system may well-have been above the minimum flow requirements.
Technical Specifications require the RHR System to be capable of delivering 3788 gpm, with a single pump running, in the cold injection mode from the Reactor Water Storage Tank (RHST). This requirement l
ensures that sufficient emergency core cooling capability is available in 4
the event of a Loss of Coolant Accident (LOCA) assuming the loss of one subsystem. With the flow specified, in conjunction with the Reactor Coolant System (RCS) accumulators, either subsystem is capable of supplying sufficient core cooling to limit the peak cladding temperatures within acceptable limits for all postulated break sizes.
In addition, each subsystem is capable of supplying sufficient long term core cooling
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in the recirculation mode during accident recovery.
It'should be noted that both subsystems were available during the time in question.
Carrective steps which have been taken and the results achieved:
i 1.
RHR. valves 1HV-0606 and lHV-0607 were restored to fully open position
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at approximately 2000 CDT on April 29, 1987.
The cable identification tag for valve 1-HV-0606 was relocated so that it could not interfere with the movement of the bellows assembly of the controller.
The controller was recalibrates and'the valve was a
returned to service in the full open position.
The positioner for 0538m E-6 10/b/87 SL-3315
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l ENCLOSURE-(Continued)-
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NRC NOTICE OF VIOLATION "A" AND "B" AND GPC RESPONSE valve 1-HV-0607 was recalibrates and the valve was returned to service in the full open position.
2.
Plant procedure 00350-C, " Maintenance Program," was revised to define
" URGENT" work, a new class of work orders, to allow prompt repairs of similar deficiencies. This enhancement ht.s proven to work well.
- 3. -The frequency of loop calibration for both valves- (1-HV-0606 and 1-HV-0607).was increased from once per 24 months.to once per 6 months.
4.
The General Manager of Plant Vogtle in a memorandum of June 10,~1987, established that the classification of-operability is the
-responsibility of the Operations Department. Other groups are responsible to observe conditions in.the plant, identify specific-problems, and assist the Operations Department in making a determination of the status of plant equipment. A policy of. reliance on collective knowledge for the classification of equipment operability, establishment of Limiting Conditions for Operations as appropriate for inoperable equipment, and timely correction of equipment problems was also promulgated by that memo.
5.
The Plant Manager briefed all control room crews on this event to stress operability requirements.
Corrective actions which will t'e taken to avoid further violation 1:
Corrective a'ctions to prevent recurrence of this violation have been completed as noted above.
Date when full comoliance will be achieved:
1 Full compliance was achieved on April 29, 1987 with the restoration of RHR valves 1HV-0606 and 1HV-0607 to their fully open position.
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