ML20237A918
| ML20237A918 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/14/1987 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| SL-3692, NUDOCS 8712150350 | |
| Download: ML20237A918 (8) | |
Text
Georgia fher Company i
333 hedenant Avenue AUanta, Georgia 30308 Telephone 404 526 6526 Maihng Address Post Ofhce Box 4545 Attarta. Georgta 30302 M
Georgia Power L. T. Guewa f'+
/ "T W d'C WA"m Ma':ager Nuclear Safety a:,d Licensmg SL-3692 0684m X7GJ17-V120 December 9,1987 U. S. Nuclear Regulatory Commission
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ATTN:
Document Control Desk N
Hashington, D.C.
20555
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PLANT V0GTLE UNIT 1
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NRC DOCKET 50-424
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OPERATING LICENSE NPF-68 KSPONSE TO NRC INS 1ELTION REPORT 3
N 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 50-424/87-57 which concerns the inspection conducted by Messrs. A.
J.
Szczepaniec and M.
Thomas of the NRC Region II staff on September 21-25, 1987.
Two apparen: violations were cited in the Notice of Violation included in the subject inspection report.
A copy of this response is being provided to the NRC Region II office.
In each enclosure, transcription of the NRC violation precedes GPC's response.
On December 7,1987, GPC personnel contacted the NRC Region II office and notified the appropriate individual that our response to NRC Inspection Report 50-424/87-57 would be several days late.
The individual contacted by GPC acknowledged that our response would be late.
Should you have any questions in this regard, please contact this office at any time.
Sincerely, 8712150359 g,,g,4 i
gDR ADOCK 0500 4
p4 L. T. Gucwa PAH/JAE/Im
Enclosures:
1.
Violation 87-57-01 and GPC Response 2.
Violation 87-57-02 and GPC Response
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4k Georgia Power h U. S. Nuclear Reculatory Commission December 9, 1987 Page Two c: Georaia Power Company Mr. J. P. O'Reilly Mr. P. D. Rice Mr. G. Bockhold, Jr.
Mr. C. H. Hayes Mr. J. E. Swartzwelder GO-NORMS Southern Comp 3ny Services Mr. R. A. Thomas Mr. J. A. Bailey Shaw. Pittman. Potts & Trqwbridag Mr. B. H. Churchill, Attorney-at-Law Troutman. $3nders. Lgg.k..gagn & Ashmara Mr. A. H. Domby, Attorney-at-Law U. S. Nuclear Regulatory Commission Dr. J. N. Grace, Regional Administrator Mr. J. B. Hopkins, Licensing Project Manager, NRR (2 copies)
Mr. J. F. Rogge, Senior Resident Inspector-Operations, Vogtle 0684m I
72775
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k Georgia Power n
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ENCLOSURE 1 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 NRC NOTICE OF VIOLATION 87-57-01 AND GPC RESPONSE VIOLATION 50-424/87-57-01 "Vogtle Technical Specification (TS) 4.8.1.1.2.a and Tabl e 4.8-1 require i
that each diesel generator (DG) shall be demonstrated operable on a staggered test basis once per seven days if the number of failures in the last 20 valid tests is greater than or equal to two.
The associated test frequency shall be maintained until seven consecutive failure free demands have been performed and the number of failures in the last 20 valid demands has been reduced to one.
Technical Specification 4.0.2 requires that each surveillance requirement shall be performed within the t
specified time interval.
Contrary to the above, the licensee failed to meet the above TS surveillance requirements as follows:
1.
During the preoperational test program the licensee increased the test frequency of DG1B from once per 31 days to once per seven days af ter experiencing valid failures.
When Unit i received an operating l
license on January 16, 1987, DG1B had had three valid failures in five valid tests since completion of DGlB reliability demonstration 3
testing (which was performed during the preoperational test i
program).
Upon issuance of the license, the licensee continued to maintain the seven day test frequency.
This seven day test frequency met the requirement of TS Table 4.8-1.
DG1B start logs indicat. that i
a number of start attempts were performed beyond the a nimum requirement.
It was stated by licenseo personnel that the additional starts were performed so that the criteria of TS Tabl. 4.8-1 for returning to the 31 day test frequency would be met.
The licensee went to the once per 31 days test frequency for DGIB on February 21, 1987.
However, review of the logs by the inspectors revealed that a number of the start attempts did not meet the criteria for a valid l
test.
Therefore, DGlB should have remained on a seven day test frequency; but DGIB remained on the 31 day test frequency (instead of the required seven day test frequency) from February 21, 1987 until September 28, 1987.
DG1B was therefore, considered to be technically inoperable at various times during the above period when the seven day test frequency time interval wcs exceeded.
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k Georgia Power h 1
ENCLOSURE 1 (Continued)
NRC NOTICE OF VIOLATION 87-57-01 AND GPC RESPONSE 2.
Diesel generator l A (DGl A) had a valid failure on August 24, 1987, (overspeed trip due to malfunction of the mechanical governor) which was the second valid failure in 15 valid tests since completion of the DG1 A reliability testing during the preoperational test program.
The mechanical governor was replaced and the DG successfully tested on August 26, 1987.
However, DGI A remained on the once per 31 days I
test frequency (instead of going to the required increased test i
frequency of once per seven days) from August 26, 1987 until l
September 24, 1987.
DGIA was therefore, considered to be technically i
inoperable from September 4-24, 1987 (period that the surveillance time interval had been exceeded).
The next surveillance test was 3
performed successfully on September 24, 1987.
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As a result of failing to meet the required test frequency based on j
the number of valid failures, both DGs were considered to be l
technically inoperable simultaneously for over 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> on August 24, I
and 25, 1987 when DGlA failed its surveillance test and the time interval for testing DGlB (which was last tested on August 11, 1987)
I had been exceeded.
Both DGs were again considered technically inoperable simultaneously for 11 days (September 4, 1987 to September k
15, 1987) when each DG exceeded the time interval for testing.
This is a Severity Level IV violation (Supplement I)."
l RESPONSE TO VIOLATION 50-424/87-57-01 l
Admission or denial of alleged violation 1 I
Georgia Power Company acknowledges the violation.
Reason for the violation:
Personnel erroneously applied the second footnote of Technical Specification Table 4.8-1 in that acceptable diesel generator starts were considered to be " valid demands" and therefore formed a basis for returning to a 31 day testing interval.
This error was predicated on an improper differentiation between " tests" and " demands" due to misleading wording in Table 4.8-1.
As noted in NRC Inspection Report 50-424/87-57
" Report Details" paragraph 6,
NRC-NRR provided clarification to NRC Region II personnel on September 28 and 29,1987, that " valid tests" and
" valid demands" were to be considered synonymous, and that the criteria specified in Regulatory Guide 1.108 must be met in order to be considered a valid successful test.
This clar fication was provided to GPC in a i
telephone conversation with NRC Region II personnel on September 29, 1987.
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Georgia Power b ENCLOSURE 1 (Continued)
NRC NOTICE OF VIOLATION 87-57-01 AND GPC RESPONSI Corrective steps which hayg been taken and the retults achieved:
The surveillance test frequencies for the Diesel Generators, DG1A and
- DGlB, were returned to the once per seven day test interval on l
September 29, 1987, following the previously cited telephone conversation with NRC Region II personnel in which the clarification from NRC-NRR was
-I provided. Operability of the diesels was confirmed by resultant testing.
Corrective steos which will be taken to avoid further violations:
1 The Diesel Start Logs record the classification of diesel generator tests as either valid or nonvalid.
" Valid tests" will be employed as the basis for test frequency adjustments in the future vice " acceptable starts" which previously had been erroneously interpreted as " valid demands".
i The revised
- logs, with proper records management, should prevent recurrence.
Clarification of the wording of Technical Specification
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Table 4.8-1 is under consideration for proposal to the NRC to eliminate j
misleading terminology.
Date when full comoliance will be achieved:
Full compliance was achieved when the test frequencies for DG1A and DG1B were returned to seven day intervals following the September 29, 1987 clarification from the NRC.
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700775
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Georgia Power b ENCLOSURE 2 PLANT V0GTLE - UNIT 1 i
NRC DOCKET 50-424 l
OPERATING LICENSE NPF-68 NRC NOTICE OF VIOLATION 87-57-02 AND GPC_ RESPONSE VIOLATION 50-424/87-57-02 q
" Technical Specification 4.8.1.1.3 and 6.8.2 require that all DG failures, valid or nonvalid, shall be reported to the Commission in a Special Report within 30 days.
Reports shall include the information recommended in Regulatory Position C.3.b of Regulatory Guide 1.108, l
Revision 1, August 1977.
Contrary to the above requirements, as of September 25,
- 1987, the licensee had not submitted a Special Report for DGI A failures which occurred on February 18, 1987, during DGl A start attempts nos. 43, 44, and 45.
The start attempts were evaluated by the licensee and determined to be nonvalid failures.
These failures are documented in DG1A start records as nonvalid failures.
This is a Severity Level V violation (Supplement I)."
RESPONSE TO VIOLATION 50-424/87-57-02 q
l Admission or denial of alleged violation-I Georgia Power Company (GPC) has reviewed the NRC's allegation that GPC failed to report nonvalid diesel generator failures.
Based upon the following discussion, GPC requests that the NRC hold the issuance of the violation in abeyance pending the resolution of our comments.
Discussion:
Regulatory Position 3.b of Regulatory Guide 1.108 states:
"All diesel generator unit failures (emphasis added by GPC), valid or invalid, should be reported consistent with the licensees reporting requirements."
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Georgia Power n ENCLOSURE 2 (Continued) i NRC NOTICE OF VIOLATION 87-57-02 AND GPC RESPONSE Regulatory Position C.2.e.2 of Regulatory Guide 1.108 states:
" Unsuccessful start and load attempts that can definitely be attributed to operating error, to spurious operation of a trip that is bypassed in the emergency operating mode, to malfunction of equipment that is not operative in the emergency operating mode l
(e.g., synchronizing circuitry) or is not part of the defined diesel generator unit design should not be considered valid tests or failures."
Georgia Power Company interpreted Regulatory Position C.2.e.2 as stating that:
Unsuccessful start and load attempts that can definitely be attributed to:
(1) Operator error; (2) Spurious operation of a trip that is bypassed in the emergency operating mode, (3) Malfunction of equipment not operative in the emergency operating mode; or (4) Malfunction of equipment not part of the defined diesel generator unit design should neither be considered failures nor valid tests.
GPC associated the word " valid" only with the word " tests".
Therefore, any start attempt that failed for one of the above four reasons was not defined as a " failure".
Further, Part B of Regulatory Guide 1.108 states
"' failure'is taken to mean the failure to start, accelerate and assume the design-rated load within and for the time prescribed during an emergency or a valid test".
By these definitions, there was no failure, either valid or nonvalid, and a reportable condition as defined by Regulatory Posi tion 3.b did not exist.
Therefore, a report was not submitted.
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Georgia Power L l
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l ENCLOSURE 2 (Continued)
NRC NOTICE OF VIOLATION 87-57-02 AND GPC RESPONSE i
i Georgia Power Company believes that our interpretation of Regulatory Position C.2.e.2 is valid.
However, we also realize that a differing conclusion could be drawn based on an interpretation that the word
" valid" should also be associated with " failures".
GPC contacted some other utilities outside NRC Region II regarding our interpretation of Regulatory Position C.2.e.2.
Our interpretation is consistent with that of several other utilities.
Three utilities stated that their interpretation of Regulatory Position C.2.e.2 had been discussed with NRC personnel and that they had been informed this was a valid interpretation.
He, therefore, request that the NRC review this concern and issue a clarifying interpretation through an information notice or generic letter so that a uniform application of the reporting criteria may be applied throughout all regions.
Additional review of the
" invalid failures" associated with start attempts numbers 43, 44, and 45 of Diesel Generator 1A has revealed that, from the time of February 7, 1987 to February 19, 1987, the diesel 3
l generator was declared inoperable under the provision of an "information only" Limiting Condition of Operation (LCO).
This information has not i
previously been presented to the NRC inspector since it was only recently I
determined.
Our review of Regulatory Guide 1.108 was unable to discern clear guidance relative to post-maintenance veri fication (i.e.,
not troubleshooting, but scheduled maintenance).
We, therefore, further i
request that the NRC provide clarification of whether start attempts l
performed to verify proper completion of maintenance activities whether l
corrective or preventive, which are made prior to the DG being returned i
I to an operable status, should be considered as valid tests and successes l
or failures, as appropriate.
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