ML20237C469
| ML20237C469 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 08/18/1998 |
| From: | Beasley J SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-424-98-05, 50-424-98-5, 50-425-98-05, 50-425-98-5, LCV-1245, NUDOCS 9808210196 | |
| Download: ML20237C469 (5) | |
Text
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Southera Nucint Oper: ting Comp:ny. inc.
I Post Office Box 1295 Damingham, Alabama 352011295 Tel 205 992.5000 SOUTHERN COMPANY August 18, 1998 Euro so Scrue l'our hid
LCV-1245 Docket Nos.
50-424 50-425 U. S. Nuclear Regulatory Commission A'ITN: Dacument Control Desk Washington, D. C. 20555 i
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 a violation identified in Inspection Reports 50-424; 425/98-05 concern:ng an inspection conducted from May 17,1998, through June 27,1998.
Please contact this office if you have any questions.
Sincerely, g/
Q J B.
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Enclosure:
Reply to a NOV 50-424; 425/98-05 xc: Southern Nuclear Operating Company Mr. J. T. Gasser Mr. M. Sheibani SNC Document Managment U. S. Nuclear Regulatory Commission Mr. L. A Reyes, Regional Administrator Mr. D. H. Jaffe, Senior Project Manager, NRR g
Mr. J. Zeiler, Senior Resident inspector, VEGP ag}
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ENCLOSUREl VOGTLE ELECTRIC GENERATING PLANT - UNITS 1 & 2 I
REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424; 425/98-05 VIOLATION 50-424; 425/98-05-01 The following is a transcription of the violation as cited in the Notice of Violation (NOV):
"During an NRC inspection conducted May 17,1998, through June 27,1998, a violation of NRC requirements was identified. In accordance with the ' General Statement of Policy and Procedure for NRC Enforcement Actions,' (NUREG 1600), the violation is listed below:
Unit 2 Technical Specification (TS) Limiting Condition for Operation (LCO) 3.0.4 states that when a limiting condition of operation is not met, entry into a mode or other specified condition in the Applicability shall not be made except when the associated actions to be entered permit continued operation in that mode or other specified condition in the Applicability for an unlimited period of time. Exceptions to LCO 3.0.4 are stated in the individual Specifications.
Contrary to the above:
1.
On April 19,1998, Unit 2 entered Mode 2 (from Mode 3) without meeting the LCO of TS 3.3.2, ' Engineering Safety Feature Actuation System (ESFAS)
Instrumentation,' Table 3.3.2-1, item 5, which requires two trains of the Turbine Trip function to be operable prior to entering Mode 2. Action Condition 11 was applicable and has a limited completion time of six hours. TS 3.3.2 does not contain an LCO 3.0.4 exception statement.
2.
On June 10,1998, Unit 2 entered Mode 4 (from Mode 3) without meeting the LCO of TS 3.4.12, ' Cold Overpressure Protection Systems,' which required two reactor coolant system relief valves to be operable. The licensee entered Mode 4 while in Action Condition D of TS 3.4.12, for one pressurizer power operated relief valve (PORV) being inoperable. This Specification has a limited completion time of 7 days and does not contain an LCO 3.0.4 exception statement.
This is a Severity Level IV violation (Supplement 1)."
l RESPONSE TO VIOLATION (50-424; 425/98-05-01) l EXAMPLE I Admission or Denial of the Violation:
i This violation occurred as stated in Example lof the notice of violation.
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ENCLOSURE 1 VOGTLE ELECTRIC GENERATING PLANT - UNITS 1 & 2 i
REPLY TO NOTICE OF VIOLATION l
NRC INSPECTION REPORTS 50-424; 425/98-05 i
Reason for the Violation:
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_ On April 19,1998, electrical links in the Unit 2 electro-hydraulic control (EllC) cabinet had been opened to defeat some reactor trip breaker inputs to the turbine trip function. This allowed j
l personnel to intermittently open the main turbine valves to warm the turbine shell with the reactor trip breakers open. Otherwise, a turbine trip would have been generated due to the reactor trip breakers being open. Subsequently, Unit 2 entered Mode 2 from Mode 3. In accordance with the TS, the turbine trip function is required to be operable in Mode 2.
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'lle electrical links in the Unit 2 electro-hydraulic control (EllC) cabinet were closed approximately 2 and 1/2 hours later, restoring the turbine trip function. It was later determined
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that entry into Mode 2, with the links opened, constituted operation of the unit in a condition prohibited by the Technical Specifications.
The cause of this event was inadequate administrative controls of the work process that allowed the links to remain open when Mode 2 was entered. Departmental procedures did not require the electrical links be closed or the caution tag log be checked prior to the mode change.
I Corrective Steps Which Ilave Been Taken and the Results Achieved:
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1.
Procedures have been revised to require closure of the links when the reactor trip breakers are closed prior to the mode change.
2.
Unit operating procedures were also revised to require that the caution tag log be checked prior to mode changes.
3.
This event and issues associated with turbine testing / warming during startup have been addressed in licensed operator requalification training. In addition, shift supervisors have been advised to document, with information LCOs, open links and similar items extending beyond a shift period.
Corrective Steps Which Will He Taken to Avoid Further Violations:
j A TS change that allows Mode 2 entry with administrative controls on the main feedwater system isolation valves has been evaluated. A TS change is planned for submittal to the NRC to support implementation prior to power ascension following the Spring 1999 refueling outage.
Date When Full Compliance Will Be Achieved:
l Full compliance was achieved on April 19,1998, when the links were closed restoring the turbine trip i
function.
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l ENCLOSURE 1 1
VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 j
REPLY TO NOTICE OF VIOLATION i
NRC INSPECTION REPORTS 50-424; 425/98-05 l
EXAMPLE 2 Admission or Denial of the Violation:
Southern Nuclear Company denies that a violation of TS occurred as stated in Example 2 of the Notice of Violation.
I Basis for Denial The former VEGP TS (TS 3/4.4.9.3, Cold Overpressure Protection Systems), based on NUREG-0452,
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draft Revision 5, contained a specific exception to LCO 3.0.4 which would have explicitly permitted the mode change cited in Example 2 of the violation. Furthermore, the Bases to the former TS LCO 3.0.4 l
stated that the purpose of LCO 3.0.4 was to prevent initiation of facility operation or proceeding to a l
higher mode of operation while corrective action is being taken to obtain compliance with a specification.
The explicit exception to LCO 3.0.4 that was part of former TS 3/4.4.9.3 was deleted with the implementation of the improved TS to be consistent with NUREG-1431. However, the Bases to LCO 3.0.4 as contained in Revision 0 to NUREG-1431, dated September 28,1992, included the following statement:
"In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from a normal shutdown."
Therefore, while the improved TS do not contain an explicit exception within LCO 3.4.12, Cold Overpressure Protection Systems, as did the former TS, the Bases to LCO 3.0.4 state that the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from a normal shutdown.
It is pertinent to this discussion to note the physical circumstances of the unit at the time of Example 2.
Specifically, the unit was in Mode 3 with an inoperable pressure transmitter that, in part, provided input I
to one of the power operated relief valves (PORV) for cold overpressure protection purposes. The other PORV was fully operable for cold overpressure protection purposes. The temperature of the RCS was still relatively high (h 350*F), and there was still a bubble in the pressurizer. In this condition, and just after entry into Mode 4, the RCS was less susceptible to a cold overpressure event than, for example, Mode 5 with the RCS water solid. Due to abnormal reactor coolant pump seal leakoff parameters, a decision was made to transition to Mode 4 to investigate the apparent condition. The time available for continued operation in Mode 3 is constrained by the availability of condensate makeup to the s*cmn generators. Therefore, the only alternative to entering Mode 4 would have been to remain in Mode 3 l
while trying to repair the inoperable pressure transmitter. On the other hand, the unit could be taken to l
Mode 4 with a fully operable PORV for the relatively short temperature span before the residual heat removal system could have been placed in service, restoring full cold overpressure protection. Hence the evolution itself was sound from a safety standpoint, and therefore consistent with the LCO 3.0.4 Bases statement regarding a normal shutdown.
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ENCLOSURE 1 VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 i
REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424; 425/98-05
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in addition, Revision 1 to NUREG 1431 revised the actual TS language of LCO 3.0.4 to state that it was not to prevent changes in MODES or other specified conditions that are part of a shutdown of the unit.
The language that now appears in Revision I to NUREG 1431 existed in the form of a traveler (BWR-
- 26) against Revision 0 of NUREG-1431 at the time that the VEGP improved TS were under review by the NRC. At that time, SNC elected not to incorporate the language of BWR-26 due to the fact that other facets of BWR-26 would have required an extensive review, and SNC believed that the Bases language contained in the Revision 0 version sufficiently clarified the intent of LCO 3.0.4 to meet our needs.
Nevertheless, it is important to note that the Revision i version of LCO 3.0.4 would also have allowed the evolution that is the subject of Example 2 af the violation.
Revision 0 to NUREG-1431 was issued by the NRC for industry use on September 28,1992, after years of development. The development process involved extensive participation by the NRC along with the commercial nuclear power industry. Furthermore, SNC believed that the new Bases were developed to aid in the interpretation and proper application of the improved TS. In a January 1988 letter from Thomas E. Murley, Director Office of Nuclear Reactor Regulation, to Joe F. Colvin, Executive Vice President and Chief Operating Officer NUMARC, entitled "NRC Staff Response to NUMARC Technical -
Specification Working Group Key implementation Issues for Restructured Technical Specifications,"the NRC staff wrote the following about the improved TS Bases:
"TS Bases will provide information to facilitate proper interpretation and application of TS requirements. Bases are also used for determining the purpose of existing requirements when changes to the TS are being considered. In short, Bases provide the technical underpinning for TS requirements. Any change to this technical underpinning that would influence the way the requirement might be interpreted or applied should be subject to prior staff approval because it would, in effect, be a TS change. However, changes that do not erode this technical underpinning should not require staff approval."
SNC views the Bases statement that LCO 3.0.4 shall not prevent a normal shutdown as a clarification that
" facilitated proper interpretation and application of TS requirements."
In summary, prior to making the evolution cited by Example 2, SNC management reviewed the TS and Bases, and, based on our understanding of the purpose and intent of LCO 3.0.4 as established by NRC approved documents in the form of the former VEGP TS, the improved Standard TS (NUREG-1431),
and the VEGP improved TS, made a decision that the evolution was permissible. The evolution cited in Example 2 was performed in good faith, and SNC continues to believe that it was in compliance with regulatory requirements. Therefore, SNC denies that a violation as stated in Example 2 occurred.
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