ML20246N562

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-424/89-13.Example Two of Violation 50-424/89-13-01 Still Considered Valid

ML20246N562
Person / Time
Site:	Vogtle
Issue date:	07/10/1989
From:	Gibson A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Hairston W GEORGIA POWER CO.
References
NUDOCS 8907190397
Download: ML20246N562 (2)

See also: IR 05000424/1989013

Text

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July 10, 1989

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G=rs'a Fow.:- Company

ATTN: Mr. W. G. Hairston, III

Senior Vice President -

Nuclear Operations

P. O. Box 1295

Birmingham, AL 35201

Gentlemen:

SUBJECT: REPORT N0. 50-424/89-13

Thank you for your response of June 14, 1989, to our Notice of Violation, issued

on May 15, 1989, concerning activities conducted at your Vogtle facility. We

have evaluated your response and found that it meets the requirements of

10 CFR 2.201.

However, we disagree with your reasoning for denial of example two of violation

50-424/89-13-01. Specifically, the basis of our disagreement is your statement

that "the training was provided during Licensed Operator Requalification

Training during 1988 Requal Segment 88-07. 'his training used LO-LP-35205

Revision 2, which was in effect from 9/30/8e through 2/21/89. This ;esson plan

included information relating to the use of the Technical Specification (TS)

cooldown curves (including instruments used)." Lesson plan LO-LP-35205

Revision 2 did have hand written information which addressed the new changes

to the TS cooldown curve, but the TS graphs in the training material depicting

the cooldown limits did not contain the current TS cooldown curve information,

i.e., which instrument /s were to be used during cooldown. Furthermore, your

contention that "once training is complete and changes are incorporated into

plant documents or the plant, training on that particular item is no longer

needed", is not acceptable. In this particular situation, subsequent training

would have been conducted using lesson plan LO-LP-35205 Revision 3. This lesson

plan contained the same cooldown curves as revision 2, hence incorrect TS

cooldown graphs would have been utilized. These graphs did not contain

information as to which instruments were to be used. Therefore, the second

examole of the above violation is still considered valid. However, during

the inspection adequate corrective act:ons were implemented and issued in

requalification lesson plan, LO-LP-35205-04. This item is considered closed

and no further response is necessary.

Additionally, Georgia Fower Company GPC offered information in mitigation of the

conclusion drawn with regard to example one and three of Violation 424/89-13-01,

which was that the Corrective Action Program is ineffective. Your presentation

explained that while 100 percent compliance has not been achieved with the

required reading program, the reading program has undergone several evolutions

since its original conception and many weaknesses noted by both the NRC and

the licensee have been addressed and corrected. This explanation, though

reasonable, is not sufficient reason for mitigation. In addition, the

repetitiveness of missed reviews of the required reading book coupled with the

fact that the responsible supervisors were unaware that some individuals were

repeat offenders causes concern about the adequacy of your corrective action

program to prevent recurrence.

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L lWelwillLexamine <theDimplementation.-of your corrective: actions during future

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Inspections. We . appreciate your cooperation in this matter.

Sincerely,

,

-(ORIGINAL SIGNED BY E. W. MERSCHOFF FOR)-

.

Albert F. Gibson', Director

Division of Reactor Safety

-cc: 'R. P. Mcdonald, Executive Vice

"

. President-Nuclear' Operations

. C. ' K. - McCoy, .Vice President-Nuclear

G. R. Fredrick, Quality Assurance

Site Manager.:

G. Rockhold,, Jr. , General Manager.-.

. _ Nu lear Operations

J. A.., Bailey, Manager-Licensing

B. W. Churchill, Esquire, Shaw,

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-Pittman, Potts, and Trowbridge

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J. E. Joiner, Esquire, Trotman,

Sanders, Lockerman, and

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Ashmore

D.

Kirkland, III, Counsel,

Office of the Consumer's Utility

Council

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-State of Georgia

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bec: E. Reis, OGC

~J.'Hopkins, NRR

M. Sinkule, RII

.NRC Resident Inspector

bM!tfc"ument Control Desk

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The Gibson

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