View source for NL-17-0384, Response to EA-17-014, Preliminary White Finding and Related Apparent Violation from Inspection Report 05000424/2017503 and 05000425/2017503

{{Adams
| number = ML17075A476
| issue date = 03/16/2017
| title = Response to EA-17-014, Preliminary White Finding and Related Apparent Violation from Inspection Report 05000424/2017503 and 05000425/2017503
| author name = Taber B
| author affiliation = Southern Nuclear Operating Co, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000424, 05000425
| license number = 
| contact person = 
| case reference number = EA-17-014, IR 2017503, NL-17-0384
| document type = Letter type:NL, Licensee Response to Notice of Violation
| page count = 2
| project = 
| stage = Other
}}

=Text=
{{#Wiki_filter:.t. Southern Nuclear                            B. Keith Taber Vice President Vogtle- Units1 & 2 4821 Rive Road Waynesboro, GA 30830 706 848 3151 tel 205 980 3321 fax bktaber@southernco.com March 16, 2017 Docket Nos.: 50-424                                                      NL-17-0384 50-425 U. S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant, Units 1 and 2 Response to EA-17-014, Preliminary White Finding and Related Apparent Violation from Inspection Report 05000424/2017503 and 05000425/2017503

==Reference:==

NRC letter to Southern Nuclear Operation Company, EA-17-014, Vogtle Electric Generating Plant, NRC Inspection Report Number 05000424/2017503 and 05000425/2017503, Preliminary White Finding and Related Apparent Violation, dated February 8, 2017.
Ladies and Gentlemen:
As provided in the referenced letter, Southern Nuclear Operating Company (SNC) is exercising its option to submit a 40-day response.
SNC acknowledges the violation due to the transposition of threshold values for Emergency Action Levels (EALs) for Vogtle Electric Generating Plant Units 1 and 2 (VEGP). Specifically, NRC inspectors identified violations of: 10 CFR 50.54(q)(2), failure to follow and maintain the effectiveness of emergency plans which met the requirements of 10 CFR 50.47(b)(4); and 10 CFR 50, Appendix E, to have a standardized EAL scheme in use based on facility system and effluent parameters.
On October 6, 2016, Condition Report 10283097 was written and immediate corrective actions were implemented to correct EAL declaration threshold values using Standing Order C-2016-008.
As conveyed in conversations with NRC personnel, SNC recognizes the inspection manual determines the finding level based on a specific EAL being degraded. Additionally, SNC notes the general emergency declaration for an event being considered would also be declared through other EALs.
SNC acknowledges the transposition of threshold values occurred. Although the risk significant planning standard was determined by the NRC to be degraded and a preliminary white finding has been determined to be appropriate, SNC believes the redundant and diverse avenues which lead to event declaration would have ensured

U. S. Nuclear Regulatory Commission NL-17-0384 Page 2 timely and accurate event classification and PAR recommendations if an actual event had happened during the time these threshold values were transposed.
This letter contains no new NRC commitments. If you have any questions, please contact Dom Sutton at (706) 848-1428.
Respectfully submitted,
 ~. KC) ~J__
B. Keith Taber Vice President Vogtle - Units 1 & 2 BKT/JMG cc:   Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. B. K. Taber, Vice President- Vogtle 1 & 2 Mr. B. J. Adams, Vice President- Engineering Mr. D. D. Sutton, Regulatory Affairs Manager- Vogtle 1 & 2 RType: CVC7000 U.S. Nuclear Regulatory Commission Ms. C. Haney, Regional Administrator Mr. M. D. Orenak, NRR Project Manager- Vogtle 1 & 2 Mr. M. F. Endress, Senior Resident Inspector- Vogtle 1 & 2}}