ML20248M098

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Forwards Response to Violations Noted in Insp Repts 50-424/98-03 & 50-425/98-03.Corrective Actions:White Deposit Identified by NRC Inspector Removed Prior to Exam
ML20248M098
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 06/08/1998
From: Woodard J
SOUTHERN NUCLEAR OPERATING CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-424-98-03, 50-424-98-3, 50-425-98-03, 50-425-98-3, LCV-1217, NUDOCS 9806120384
Download: ML20248M098 (5)


Text

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

40 invemess Center Parkway Post Office Box 1295 8 tmingham, Alabama 35201 l

l Tel 205 932.5006 sounisiu m COMPANY Energy to Serve YourWorld" June 8, 1998 LCV-1217 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 NRC INSPECTION REPORT 50-424;425/98-03 REPLY TO A NOTICE OF VIOLATION Pursuant to 10 CFR 2.201, Southern Nuclear Operating Company (SNC) submits the enclosed information for Vogtle Electric Generating Plant (VEGP) in response to a Notice of Violation (NOV) identified in Nuclear Regulatory Commission (NRC) Inspection Report No.

50-424;425/98-03, which concerns an inspection conducted from March 8,1998 through April 18,1998.

Should you have any questions, please contact this office.

Sincerely, J. D. Woodard JDW/CTT/bhw l

Enclosure:

Reply to Notice of Violation 50-424;425/98-03

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cc:

Southern Nuclear Operating Company Mr. J. B. Beasley, Jr.

Mr. M. Sheibani i

SNC Document Management

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' a;v U. S. Nuclear Regulatory Commission y

Mr. L. A. Reyes, Regional Administrator

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Mr. D. H. Jaffe, Senior Project Manager, NRR Mr. J. Zeiler, Senior Resident Inspector, Vogtle 9806120304 990608 PDR ADOCK 05000424:

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l ENCLOSUREI r

VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 l

REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/98-03 VIOLATION A. 50-424.,.o/98-03-04 i

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

"During an NRC inspection conducted March 8,1998, through April 18,1998, 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 i

below:

L A.

Technical Specifications 5.4.1.a requires that written procedures be implemented l

for the activities identified in Appendix A of Regulatory Guide (RG) 1.33, l

Revision 2, February 1978. RG 1.33, Revision 2, Appendix A, requires that procedures for maintenance activities be implemented.

Procedure PT-V-605, " Liquid Penetrant Examination Procedure," Revision 3, paragraph 9.2, states in part that,"The examination area and the adjacent areas within at least 1 inch shall be dry and free of any dirt, grease, lint, water, scale, welding flux, weld spatter, oil or other extraneous matter that could interfere with the examination."

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Contrary to the above, on April 1,1998, Procedure PT V-605, was not properly implemented, in that, liquid penetrant pre-examination cleaning for safety injection system weld No. 21204-122-6, was inadequate. A tenaciously adhering white deposit approximately % x % inch was left at the toe of the weld after precleaning l

and prior to the application of the penetrant. This deposit was of a size that could mask relevant rejectable indications.

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

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

Admission or Denial of the Violation:

This violation occurred as stated in the notice of violation.

Reason for the Violation:

On April 1,1998, a non-destructive examination (NDE) examiner performed a liquid penetrant examination for safety injection system weld No. 21204-122-6. During the examination, the examiner determined that an area on the weld may not have been adequately cleaned. The examiner reperformed the entire examination, which included cleaning the area in question. Prior l

ENCLOSUREI VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/98-03 i

i to the examiner applying the penetrant, the NRC inspector requested to inspect the examination area for cleanliness and noted a white deposit at the toe of the weld. This violation was a result of personnel error, in that the examiner failed to adequately clean the weld area in accordance with the applicable procedure.

l Corrective Steps Which Have Been Taken and the Results Achieved:

1.

The "hite deposit identified by the NRC inspector was removed prior to the examination.

2.

A review was conducted of other liquid penetrant examinations performed by this examiner with no problems noted with inadequate clean'ag.

3.

The examiner was counseled on the cleanliness requirements vhen performing lic,uid penetrant examinations.

Corrective Stecs Which Will Be Taken to Avoid Further Violations:

I No additional corrective actions are planned at this time.

r Date Whenfull Compliance Will Be Achieved:

Full compliance was achieved on April 1,1998, when the white deposit identified by the NRC

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inspector was removed.

VIOLATION B,50-424:425/98-03-06 f

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

."B.

License Condition (E) of the Vogtle Operating License, dated March 17,1997, states, in part, that Southern Nuclear shall fully implement and maintain in effect all provisions of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans...and to the authority of 10 CFR l

50.90 and 10 CFR 50.54(p).

l'

~, ogtle Electric Generating Plam Physical Security and Contingency Plan, Revision 34, Section 3.2.3, states that procedures exist to document the structure of the security orgt.nization and to detail the duties of security officers and others responsible for security.

Procedure 00652-C," Personnel Escort-Duties and Responsibilities," Revision 5, Section 4.8, states that an escort shall maintain control of and visual contact with a visitor.

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ENCLOSUREI VOGTLE ELECTRIC GENERATING PLANT-UNITS I & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/98-03 Contrary to the above, on March 30 and March 31,1998, an escort was observed as not rr.aintaining control and visual contact of a visitor inside the Unit 2 Train B emergency diesel generator building.

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

RESPONSE TO VIOLATION B (50-424:425/98-03-06)

Admission or Denial of the Violation:

This violation occurred as stated in the notice of violation.

Reason for the Violation:

On March 30,1998, during the scheduled Unit 2 refueling outage, a contractor employee escorting a visitor in the B train emergency diesel generator building did not maintain control and visual contact of the visitor. Again, on March 31,1998, the same escort was observed in the B train emergency diesel generator building not maintaining control and visual contact of the visitor.

These individuals were performing maintenance activities on the emergency diesel generators.

The reason the violation occurred was that the escon failed to fully understand the significance of escort duties and responsibilities.

Corrective Steps Which IInve Been Taken and the Resalts Achieved:

1 On March 30,1998, afler the escort was observed not maintaining control and visual contact of the visitor, compensatory actions were taken which includ:d counseling the escort.

2.

Again on March 31,1998, after the escort was observed not maintaining control and visual contact of the visitor, compensatory actions were taken which included additional counseling for the escert.

3.

The security department has begun issuing a written summary of escon duties and responsibilities to the escorts prior to issuance of the visitor's badge to the visitor.

Corrective Steps Which Will Be Taken to Avoid Further Violations:

No additional corrective actions are plarned at this time.

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FNCLOSURE1 VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/98-03 Date When Full Compliance Will Be Achieved:

Full compliance was achieved on March 30 and 31,1998, when appropriate compensatory actions were taken to ensure the visitor was being properly escorted.

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