NL-17-0844, Reply to a Notice of Violation; EA-17-014

Reply to a Notice of Violation; EA-17-014

ML17143A300
Person / Time
Site:	Vogtle
Issue date:	05/23/2017
From:	Taber B Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-17-014, IR 2017504, NL-17-0844
Download: ML17143A300 (3)

Text

~ Southern Nuclear B. Keith Taber Vice President 4821 River Road Waynesboro, GA 30830 Vogtle- Units 1 & 2 706 848 3151 tel 205 980 3321 fax bktaber@southernco.com May 23, 2017 Docket Nos.: 50-424 NL-17-0844 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant, Units 1 and 2 Reply to a Notice of Violation: EA-17-014

Reference:

NRC letter to Southern Nuclear Operation Company, EA-17-014, Final Significance Determination of a White Finding and Notice of Violation and Assessment Follow-up Letter (NRC Inspection Report 05000424/2017-504 and 05000425/2017-504), dated April 24, 2017.

Ladies and Gentlemen:

In accordance with the provisions of 10 CFR 2.201, the Nuclear Regulatory Commission (NRC) has issued to Southern Nuclear Operating Company (SNC) a violation, as restated in the enclosure. SNC acknowledges and concurs with the violation . This letter constitutes the required response submittal.

This letter contains no new NRC commitments. If you have any questions, please contact Dom Sutton at 706.848.1428.

~.*zvL B. Keith Taber BKT/JMG

Enclosure:

Reply to Violation cc: Regional Administrator NRR Project Manager- Vogtle 1 & 2 Senior Resident Inspector- Vogtle 1 & 2 RType: CVC7000

U.S. Nuclear Regulatory Commission Enclosure to NL-17-0844 Reply to Violation - Page 1 RESTATEMENT OF VIOLATION 10 CFR Part 50.54( q)(2) requires that a holder of a nuclear power reactor operating license under this part, shall follow and maintain the effectiveness of an emergency plan that meets the planning standards in 10 CFR Part 50.47(b) and the requirements in Appendix E to this part.

10 CFR Part 50.47(b)(4) requires a standard emergency classification and action level scheme, the bases of which include facility and system effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.

10 CFR Part 50, Appendix E, Section IV.B., "Assessment Actions," requires that means to be used for determining the magnitude of, and for continuously assessing the impact of, the release of radioactive materials shall be described, including emergency action levels (EALs) that are to be used as criteria for determining the need for notification and participation of local and State agencies, the Commission, and other federal agencies.

The EALs shall be based on in-plant conditions and instrumentation, in addition to onsite and offsite monitoring.

Contrary to the above, from October 2014 to October 2016, the licensee failed to maintain the effectiveness of their emergency plan and a standard emergency classification scheme which included facility effluent parameters. Specifically, the emergency classifications RG1 (General Emergency) and RS1 (Site Area Emergency) contained effluent radiation monitor threshold values for RE-12444E (plant vent radiation monitor) and RE-12839E (steam jet air ejector radiation monitor) that were forty-two times different than the correct values. These radiation monitors were being relied upon to determine the magnitude of, and for continuously assessing the impact of, the release of radioactive materials, as well as providing criteria for determining the need for notification and participation of local and State agencies.

This violation is associated with a White significance determination process (SOP) finding .

REASON FOR THE VIOLATION In the October 2014 revision of the Vogtle Electric Generating Plant (VEGP) Emergency Plan, version 62, incorrect values were entered for radiation monitors RE-12839E (Steam Jet Air Ejector)- SJAE) and RE-12444E (Plant Vent Stack- PVS) threshold values for Initiating Conditions (ICs) RG1 and RS1 . The incorrect values were the result of a transposition error from the calculation document such that the calculated values for RE-12839E were entered for RE-12444E and, similarly, the RE-12444E values were entered for RE-12839E. These errors occurred during the transfer of information from the calculation to the VEGP Emergency Plan and was not an error in the actual calculation.

This transposition error carried over into NMP-EP-110-GL03, VEGP EALs-ICs, Threshold Values and Basis; the EAL wall board; and NMP-EP-112-003, Vogtle Specific PAR Instruction, which are used in classifying events and determining PARs.

U. S. Nuclear Regulatory Commission Enclosure to NL-17-0844 Reply to Violation - Page 2 CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED CR 10283097 was generated on October 6, 2016 to document this issue in the corrective action program. Actions were taken to verify the correct information and put compensatory measures in place. Those measures were to correct the EAL boards and place an Operations Standing Order (C-2016-8) in the simulator, control room and Technical Support Center. That action was completed on October 6, 2016.

Procedures NMP-EP-110-GL03, Version 9.0 and NMP-EP-112-003, Version 2.0 were subsequently revised following a re-verification of the calculation values. That action was completed on October 11, 2016.

A line-by-line review of the Emergency Plan against the Safety Evaluation Report was performed by an independent contractor to determine the extent of condition. That action was completed on December 6, 2016.

A Root Cause Evaluation (RCE) has been completed and approved, actions associated with the RCE that will prevent recurrence of the event have been captured in the Corrective Action Program (CAP).

CORRECTIVE STEPS THAT WILL BE TAKEN There are no additional corrective steps that are necessary for VEGP to be in compliance with the regulations.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Corrective Actions to address the identified violation are complete. VEGP is in full compliance with applicable regulatory requirements.