ML20236D839

Forwards Response to NRC Ltr Re Violations Noted in Insp Rept 50-424/87-31.Violation Re Performance of Maint W/O Work Order Should Be Rescinded Based on Listed Criteria

ML20236D839
Person / Time
Site:	Vogtle
Issue date:	07/27/1987
From:	Gucwa L GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
SL-2862, NUDOCS 8707310081
Download: ML20236D839 (4)

Text

- _ - _ - - _ _ - _ - -

'1 Georgia Power Company i

' 333 Piedmont Avenue Atlanta, Georgia 30303

. Telephone 404 5?6-6526 Malling Address:.

Post office Box 4545 Atlanta, Georgia 30302 g

Georgia Power

. L. T. Gucwa

!!+ southern e4ttre syc!cm Manager Nuclear Safety and Licensing SL-2862 0410m i

X7GJ17-V120 1

l July 27, 1987 U. S. Nuclear Regulatory Commission ATTN:

Document Control Desk i

Washington, D.C.

20555 i

PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 i

RESPONSE TO NRC INSPECTION REPORT 1

i Gentlemen:

Pursuant to the provisions of 10 CFR 2.201, Georgia Power Company.

(GPC) submits the enclosed information in response to NRC Inspection i

Report 50-424/87-31, which concerns the inspection. conducted by Messrs.

l J. F. Rogge and R.

J.

Schepens from April 18 -to May 22,.1987.

One apparent violation was cited in the Notice of Violation included in the 1

subject inspection report.

1 I

The enclosure to.this letter contains a transcription of the NRC violation and GPC's response.

j Please contact this office if you have any questions.

Sin erely,

.M M

L. T. Gucwa-i JH/im-l

Enclosures:

1.

. Violation 87-31-01 and GPC Response 2.

Licensee Event Report 50-424/1987-027 c:

(see next page) 8707310081 070727 PDR ADOCK 05000424 G

PDRg

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Georgia Power 1 i

(

I U. S. Nuclear Regulatory Commission July 27, 1987 Page Two 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 GO-NORMS Southern Comoany Services Mr. R. A. Thomas Mr. J. A. Bailey Shaw. Pittman. Potts & Trowbridae Mr. B. H. Churchill, Attorney-at-Law Troutman. Sanders. Lockerman & Ashmora 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 Enerav Hr. D. Feig Ms. C. Stangler l

l 1

1 0410m 700775

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Georgia Power d ENCLOSURE 1 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 NRC VIOLATION 87-31-01 AND GPC RESPONSE VIOLATION 50-424/87-31-01

" Technical Specification 6.7.la requires that written procedures shall be established, implemented, and maintained covering activities delineated in Appendix A of Regulatory Guide 1.33, Revision 2, February 1987.

Administrative Procedure 00350-C " Maintenance Program" establishes administrative controls for maintenance activities by providing for identification, control and documentation of maintenance activities.

Contrary to the above, on May 13, 1987, maintenance was performed on MSIV 1HV-3006B to correct a solenoid valve hydraulic leak without an approved Maintenance Work Order detailing the work instructions.

The failure to provide written instructions resulted in MSIV (lHV-3006B) closing when power to the solenoid valves was removed.

This resulted in a steam transient which caused a low-low level in the No. 1 steam generator and a subsequent reactor trip from 90 percent reactor power.

This is a Severity Level IV violation (Supplement II)."

RESPONSE TO VIOLATION 50-424/87-31-01 GPC agrees that the violation occurred as stated in the inspection report.

After careful and considered review of 10 CFR 2, Appendix C, Part V. A, GPC requests recision of the violation based upon compliance with the following criteria:

4 (1) It was identified by GPC; (2) It fits in Severity Level IV; (3) It was reported; (4) It will be corrected, including measures to prevent recurrence, within a reasonable time; and j

(5)

It was not a violation that could reasonably be expected to have been prevented by the GPC's corrective action for a previous violation.

0410m El-1 07/27/87 SL-2862 700775

1 i

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4 Georgia Pcaver AbL l

ENCLOSURE 1 (Continued) i NRC VIOLATION 87-31-01 AND GPC RESPONSE Subsequent to the occurrence of the ever.t, GPC submitted a Licensee Event Report (LER) pursuant to the requirements of 10 CFR 50.73(a)(2)(iv).

Cause, analysis, and corrective actions for the event are addressed in LER 50-424/1987-027 dared June 12, 1987.

A copy of that LER is enclosed for ease of review.

1 GPC believes that the information contained in the LER satisfies the i

above criteria and justifies recision of the violation.

1 l

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~...,n.i On Nay 13,1987 at 0304 CDT while in Mode 1 at 90% rated thermal power, a reactor trip occurred when steam generator (SG) #1 reached its Low-Low water level setpoint.

The reactor trip was caused by the inadvertent closure of the corresponding outboard main steam isolation valve (MSIV) during maintenance.

(Vogtle has two MSIVs in series on each main steam supply line.) (The closure of t$e MSIY caused a rapid pressure increase in SG F1 whiah produced an innediate decrease in the level of SG #1 to the Low-Low water level setpoint, initiating a reactor trip.

The corresponding atmospheric relief valve opened to control pressure in SG

1. 1.

Operators closed the remaining train "B" MSIVs to slow the cooldown rate of the Reactor Coolant System and restored the plant to stable conditions by 0322 CDT.

The trip was caused by inadequate work instructions for performing maintenance on the MSIVs.

Corrective action was taken to establish written guidelines describing proper methods to maintain valve position while performing maintenance.

/

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PLANT V0GTLE - UNIT 1 0151010 l o (4 l 2l 4 47 0 l2l7 Op 0(2 0F 0 14 w o anc % mamm A.

REQUIREMENT FOR REPORT This report is required per 10 CFR 50.73 (a)(2)(iv), since the event resulted in an

• planned automatic actuation of the Reactor Protection. System (RPS).

B.

-UNIT STATUS AT TIME OF EVENT At the time of the event, Unit 1 was in Mode 1 at 90% of rated I

thermal. power (RTP).

Reactor Coolant System (RCS) pressure and temperature were approximately 2235 psig and 584 degrees 1

Fahrenheit, respectively.

The main generator was on line.with an electrical load of 1070 MWE. The plant was being maintained at l

approximately 90% RTP for startup testing.

Maintenance was being j

performed on main steam isolation valve (MSIV).(HV-3006B).

Plant i

Vogtle has two MSIV's in series'on each main steam supply line (MSSL).

C.

DESCRIPTION OF EVENT On May 13,1987, at 0304 CDT, a reactor trip occurred when steam generator (SG) #1 reached its Low-Low water level setpoint.

)

Maintenance was being performed on the-corresponding MSSL outboard MSIV to correct a small hydraulic. leak in the actuator that was causing the hydraulic pump to stroke excessively.

During this maintenance, the MSIV was inappropriately blocked open, both mechanically ang h; hydraulically.

The hydraulic blocking of the MSIV should have ben Accomponhed by closing the redundant hydraulic shutoff valves, which would have locked the actuator in a fixed position.

Instead, only one of the two hydraulic shutoff valves was 1solated. When the MSIV hydraulic fluid dump valves were i

de4nergized, the hytiraulic fluid flowed to the overflow tank,

thWs applying a closing force.

The hydraulic closing. force disabled the mechanical block, allowing the valve to close.

The closure of the MSIV caused a rapid pressure increase in SG #1 which produced an insnediate decrease in the level of SG #1 to the Low-Low water level setpoint; initiating a reactor trip, an Auxiliary Feedwater (AFW) system actuation. and subsequently a turbine trip, and feedwater isolation-(FWI).. The corresponding atmospheric relief valve opened to control pressure in SG #1.

Operators closed the remaining train "B" MSIVs to slow the cooldown rate of the RCS and restored tne' plant to stable conditions by 0322 CDT.

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EXP#RES. 8t3tes DOCKET NUMSER (2)

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CAUSE OF EVENT

~

The immediate cause of the event was the water level decrease in SG

1. 1 to the Low-Low water level setpoint.

This was caused by the I

rapid pressure increase in the SG #1 due to the closure of the MSSL i

outboard MSIV.

The root cause of the trip was inadequate work instructions for performing maintenance on MSIVs while operating at power.

The MSIV disassembly procedure does not address performing maintenance of the MSIV in a fully open position.

Verbal work instructions (an emergency work order) were provided to the i

maintenance personnel to hydraulically block open the affected MSSL j

outboard MS.IV. However, the MSIV was mechanically blocked open and only one of the redundant hydraulic lines was blocked (isolated).

The power was subsequently removed from the MSIV isolation valve, whereupon the mechanical block failed and the MSIV closed.

E.

ANALYSIS OF EVENT Unit I was in Mode 1 when the reactor automatically tripped due to SG #1 water level decreasing to the Low-Low water level setpoint.

Automatic systems functioned as required.

The control rods fully inserted into the core upon receipt of the trip signal.

Atmospheric relief valve (lPV-3000A) opened to control pressure in SG #1.

The remaining train B MSIVs were closed at 0305 CDT to control the cooldown rate.

The plant was taken to Mode 3 at 0322 j

CDT by applicable plant procedures.

The plant's systems are capable of responding appropriately to similar events at any power i

levels.

Based upon the above information, it is concluded this

]

event had no adverse impact on plant safety or the health and safety of the public, j

F.

C0kRECTIVEACTIONS 4 i

(1)

Guidelines describing proper methods to maintain valve position while performing maintenance on MSIV's have been i

i established and provided to Work Planning for i

implementation.

Additionally, this action was expanded to j

include other critical valves in the main steam supply 1

system.

(feedwater isolation valves).

i (2)

The administrative control of emergency maintenance procedures has been redefined in plant procedure 00350-C,

" Maintenance Program".

+

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EXpfRts. S/31/3 PActuTV alAAAE Hg DOCKET NVesSER (2)

LER NUMSG A (61

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PLANT V0GTLE - UNIT 1 0 l510 lo l o l 412l 4 87 012l7 0 10 0 14 oF 0 14

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(3).

The MSIV disassembly procedure has been revised to properly sequence the steps for hydraulically isolating the MSIV.

l (4)

Miscellaneous valves associated with the hydraulic operators of the MSIVs, and feedwater isolation valves were temporarily tagged.

A permanent tag is expected to be installed on these valves by August 3, 1987.

G.

ADDITIONAL INFORMATION (1 )

Previous Similar Events None (2)

Energy Industry Identification Code Main Steam System - SB Condensate and Feedwater System - SJ Auxiliary Feedwater System - BA q

Control Rod Drive System - AA

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