ML20236P560

Responds to Violations Noted in Insp Repts 50-424/98-04 & 50-425/98-04 on 980419-0516.Corrective Actions:Valves That Would Not Open Was Repaired & Opened & Personnel Involved Were Counseled on Performance of Procedure 00054-C

ML20236P560
Person / Time
Site:	Vogtle
Issue date:	07/13/1998
From:	Woodard J SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-424-98-04, 50-424-98-4, 50-425-98-04, 50-425-98-4, LCV-1234-A, NUDOCS 9807170021
Download: ML20236P560 (5)

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J. D.Woodard . Southern Nuclear Executive Vice President Operating Company, lac.

40 invemess Center Parkway Post Othee Box 1295 Birmingham, Alabama 35201 Tel 205.992.5086 1 SOUTHERN h COMPANY Energy ro ServehurWorld" July 13, 1998 LCV-1234-A s 1

Docket Nos. 50-424 50-425 U. S. Nuclear Regulatory Commission 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 submits the enclosed information in response to two violations identified in Inspection Reports' 50-424,425/98-04 concerning an inspection conducted from April 19 through May 16,1998.

Please contact this oflice ifyou have any questions.

Sincerely, Woodard d

JDW/BHW

Enclosure:

Reply to a NOV 50-424,425/98-04 xc: Southern Nuclear Operating Comnany Mr. J. B. Beasley Mr. M. Sheibani' { '

SNC Document Management l U. S. Nuclear Regulatory Commission I j

Mr. L. A. Reyes, Regional Administrator -

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Mr. D. H. JafTe, Senior Project Manager, NRR Mr. J. Zeiler, Senior Resident Inspector, Vogtle l 9907170021 980713 -

l PDR ADOCK 05000424; G PDR;~

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ENCLOSURE VOGTLE ELECTRIC GENERATING PLANT- UNITS 1 & 2

, REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425/98-04

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VIOLATION A. 50-424:425/98-04-01 The following is a transcription of the violation as cited in the Notice of Violation (NOV):

"During an NRC inspection conducted April 19,1998, through May 16,1998, violations of NRC requirements were identified. In accordance with the ' General Statement of Policy and Procedure for NRC Enforcement Actions,' (NUREG 1600), the violations are listed below: l A. Technical Specifications 5.4.1.a requires that written procedures be implemented for the activities identified in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, which includes administrative procedures for personnel compliance with plant procedures.

i Operations Administrative Procedure 00054-C, ' Rules For Performing Procedures,' Revision i1, provides iustmetions for performing activities in accordance with approved procedures. This procedure requires that plant procedure steps be performed in sequence unless special circumstances warrant or deviations are allowed by the procedure. The procedure further states that the Unit Shift Supervisor (USS) may allow procedure steps to be performed out of sequence ifit does not result in the omission of required work, violate the intent of the procedure, or create an unsafe plant condition.

Startup Operating Procedure 12001-C, ' Unit Heatup to Hot Shutdown ,

(Mode 5 to Mode 4)', Revision 38, Step A4.2.3.b, requires that, while the reactor coolant system (RCS) is in a water solid condition, ensure all letdown orifice isolation valves remain open.

Contrary to the above, on April 15,1998, upon identification that one of the three letdown orifice isolation valves would not open, the Unit 2 USS proceeded to allow operation of the unit in water solid conditions with only two of three letdown orifice isolation valves in the prescribed position.

The third letdown orifice isolation valve was opened on April 17 following maintenance repairs.

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

RESPONSE TO VIOLATION A (50-424:425/98-04-01) 1 l.

J l ENCLOSURE i l VOGTLE ELECTRIC GENERATING PLANT- UNITS I & 2 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424:425/98-04 Admission or Denial of the Violation:

! This violation occurred as stated in the notice of violation.

Reason for the Violation:

l On April 15,1998, during a reactor stanup following a Unit 2 refueling outage, operations personnel were preparing to enter water solid operation. In accordance with the requirements of procedure 12001-C," Unit Heatup to Hot Shutdown (Mode 5 to Mode 4)", while the reactor coolant system is in a water solid condition, the three letdown orifice isolation valves will remain open. Personnel were unable to open one of the three letdown orifice isolation valves.

Subsequently, based on plant conditions, the unit shift supervisor (USS) made a decision to enter water solid operations with one valve closed. The USS noted in

,the procedure that the valve could not be opened and initiated a work request to have the valve repaired.

The decision to enter water solid operation with one letdown orifice isolation valve closed resulted from a failure to recognize that having all three letdown orifice isolation valves open was a FSAR requirement. Because this was not recognized

, as a FSAR requirement, shift supervision and plant management did not consider l

entering water solid operations with one letdown orifice isolation valve closed to be a change in the intent of the unit operating procedure (12001-C.) Procedure 00054-C, allows under certain circumstances, the USS to perform procedure steps out of sequence as long as it does not violate the intent of the procedure.

This violation was a result of personnel error, in that, shift supervision and plant l

management did not fully understand the requirement of having all three letdown orifice i isolation valves open with the plant in a water solid condition.

Corrective Steps Which Have Been Taken and the Results Achieved:

1. On April 17,1998, the valve that would not open was repaired and opened.

2. Personnel involved were counseled on procedure performance and applying the guidance in procedure 00054-C.

3. This event has been included in the licensed operator requalification program.

Corrective Steps Which Will Be Taken to Avoid Further Violations:

1. Procedure 12001-C, will be revised to provide clear direction to ensure that all three letdown orifice isolation valves are open when entering water solid conditions. This will be completed by July 30,1998.

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l ENCLOSURE l

VOGTLE ELECTRIC GENERATING PLANT- UNITS 1 & 2 REPLY TO A NOTICE OF VIOLATION l NRC INSPECTION REPORTS 50-424:425/98-04 I

2. Operations shift briefings will be conducted on this event, particularly on applying the guidance provided in procedure 00054-C. This will be completed by July 21,  !

1998.

Date When Full Comoliance Will Be Achieved:

i Full compliance was achieved on April 17,1998, when the valve that would not open was i repaired and subsequently opened.

VIOLATION B,50-424:425/98-04-03 I l

i The following is a transcription of the violation as cited in the Notice of Violation (NOV):

"B. 10 CFR 50, (Code of Federal Regulation) Appendix B, Criterion V, ,

Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality be prescribed and accomplished in accordance with procedures appropriate to the circumstances.

Procedure 00254-C, ' Foreign Material Exclusion and Plant Housekeeping Programs,' Revision 18, requires that tools, equipment, and material entering and leaving a designated Zone II, foreign material exclusion area be logged on the foreign material exclusion inventory log forms.

Contrary to the above, on April 28,1998, approximately eight miscellaneous tools, equipment, and materials were identified inside the designated Zone II area around the Unit I and Unit 2 spent fuel pools that were not logged on the foreign material exclusion inventory form. Further, one item was identified as being inside the Zone II area (via an open inventory form line item) that had been removed five days earlier. The licensee failed to log out the item in accordance with procedure requirements.

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

RESPONSE TO VIOLATION H (50-424:425/98-04-03)

I Admission or Denial of the Violation:

This violation occurred as stated in the notice of violation.

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I ENCLOSURE 1

VOGTLE ELECTRIC GENERATING PLANT- UNITS 1 & 2 REPLY TO A NOTICE OF VIOLATION

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NRC INSPECTION REPORTS 50-424:425/98-04 Reason for the Violation:

Due to personnel error, on April 28,1998, various materials inside the Units 1 and 2 Spent Fuel Pool (SFP) Zone II areas were not being controlled in accordance with the requirements of procedure 00254-C. Personnel from various departments p#orming work activities in the Zone 11 areas failed to properly control material in accordance with the applicable foreign material exclusion (FME) procedural requirements.

A contributing factor to this violation involved the vagueness of certain procedural l requirements in procedure 00254-C. I Corrective Steps Which Ilave Been Taken and the Results Achieved:

1. Items that could not be accounted for on the Zone 11 logs were immediately removed.

2. As an interim measure until fmal corrective steps are complete, the SFP Zone II  !

area is manned continuously to control access and ensure total compliance with l current procedural requirements.

Corrective Steps Which Will Be Taken to Avoid Further Violations:

1. Procedure 00254-C, will be revised to clarify procedural requirements for maintaining FME controls in Zone 11 areas. This will be completed by July 30, 1998.

2. Subsequent to the revision of procedure 00254-C, appropriate personnel will 4 receive training on the new procedural requirements for maintaining Zone 11 FME controls. This will be completed by September 1,1998.

Date When Full Compliance Will Be Achieved:

Full compliance was achieved on April 28,1998, when the items that could not be accounted for on the Zone Il logs were immediately removed.

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