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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217P3791999-10-21021 October 1999 Forwards NRC Form 396 & NRC Form 398 for Renewal of Licenses SOP-20607-1 & SOP-20610-1.Without Encls ML20217N2521999-10-20020 October 1999 Provides Supplemental Info Re 990405 Containment Insp Program Requests for Relief RR-L-1 & RR-L-2,in Response to 991013 Telcon with NRC ML20217K7541999-10-15015 October 1999 Forwards Rev 1 to Unit 1,Cycle 9 & Unit 2 Cycle 7 Colrs,Iaw Requirements of TS 5.6.5.Figure 5, Axial Flux Difference Limits as Function of Percent of Rated Thermal Power for RAOC, Was Revised for Both Units ML20217G6751999-10-13013 October 1999 Requests Withholding of Proprietary Info Contained in Application for Amend to OLs to Implement Relaxations Allowed by WCAP-14333-P-A,rev 1 ML20217G1071999-10-0707 October 1999 Informs That on 990930,NRC Staff Completed mid-cycle PPR of Vogtle & Did Not Identify Any Areas in Which Performance Warranted More than Core Insp Program.Nrc Plans to Conduct Core Insps at Facility Over Next Six Months ML20216J9041999-10-0101 October 1999 Forwards Response to RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves ML20216J9161999-10-0101 October 1999 Forwards Response to NRC 990723 RAI Re GL 95-07, Pressure Locking & Thermal Binding of SR Power-Operated Gate Valves ML20217B0141999-10-0101 October 1999 Forwards Insp Repts 50-424/99-06 & 50-425/99-06 on 990725- 0904 at Vogtle Units 1 & 2 Reactor Facilities.Determined That One Violation Occurred & Being Treated as non-cited Violation ML20212E8751999-09-20020 September 1999 Forwards Response to NRC GL 99-02, Lab Testing of Nuclear Grade Activated Charcoal. Description of Methods Used to Comply with Std Along with Most Recent Test Results Encl ML20212E7481999-09-20020 September 1999 Requests Approval Per 10CFR50.55a to Use Alternative Method for Determining Qualified Life of Certain BOP Diaphragm Valves than That Specified in Code Case N-31.Proposed Alternative,Encl ML20212C2191999-09-16016 September 1999 Forwards NRC Form 536, Operator Licensing Exam Data, Which Is Current Need for NRC Operator Licensing Exams for Years 2000 Through 2003 of Plant Vogtle,Per Administrative Ltr 99-03 ML20211Q4801999-09-0101 September 1999 Informs That on 990812-13,Region II Hosted Training Managers Conference on Recent Changes to Operator Licensing Program. List of Attendees,Copy of Slide Presentations & List of Questions Received from Participants Encl ML20211J5291999-08-30030 August 1999 Forwards Snoc Copyright Notice Dtd 990825,re Production of Engineering Drawings Ref in VEGP UFSAR ML20211J5251999-08-30030 August 1999 Forwards Response to NRC 990727 RAI Re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design Basis Accident Conditions ML20211J7381999-08-27027 August 1999 Informs That Licensee Vessel Data Is Different than NRC Database Based on Listed Info,Per 990722 Request to Review Rvid ML20211E9251999-08-23023 August 1999 Forwards fitness-for-duty Performance Data for Jan-June 1999,as Required by 10CFR26.71(d).Data Reflected in Rept Covers Employees at Vogtle Electric Generating Plant ML20210V0881999-08-16016 August 1999 Forwards Insp Repts 50-424/99-05 & 50-425/99-05 on 990620- 0724.No Violations Noted.Vogtle Facility Generally Characterized by safety-conscious Operations,Sound Engineering & Maintenance Practices ML20210Q4611999-08-0505 August 1999 Informs That NRC Plans to Administer Generic Fundamentals Exam Section of Written Operator Licensing Exam on 991006 for Vogtle.Requests Info Re Individuals Who Will Take Exam. Sample Registration Ltr Encl ML20210L2181999-08-0202 August 1999 Forwards NRC Form 396 & Form 398 for Renewal of Listed Licenses,Iaw 10CFR55.57.Without Encl ML20210N1191999-08-0202 August 1999 Discusses 990727 Telcon Between Rs Baldwin & R Brown Re Administration of Licensing Exam at Facility During Wk of 991213 ML20210G3351999-07-27027 July 1999 Forwards Second Request for Addl Info Re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design Basis Accident Conditions ML20210E0121999-07-23023 July 1999 Forwards Second Request for Addl Info Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves ML20210D9341999-07-22022 July 1999 Discusses Closure of TACs MA0581 & MA0582,response to Requests for Info in GL 92-01,rev 1,suppl 1, Reactor Vessel Structural Integrity ML20210C8011999-07-21021 July 1999 Provides Response to NRC AL 99-02,which Requests That Addressees Submit Info Pertaining to Estimates of Number of Licensing Actions That Will Be Submitted for NRC Review for Upcoming Fy 2000 & 2001 ML20210E0431999-07-15015 July 1999 Forwards Insp Repts 50-424/99-04 & 50-425/99-04 on 990502- 0619.Two Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20209H3881999-07-14014 July 1999 Forwards Revs 1 & 2 to ISI Program Second 10-Year Interval Vogtle Electric Generating Plant Unit 1 & 2 ML20209C4041999-07-0101 July 1999 Forwards Rev 29 to VEGP Units 1 & 2 Emergency Plan.Rev 29 Incorporates Design Change Associated with Consolidation of Er Facilities Computer & Protues Computer.Justifications for Changes & Insertion Instructions Are Encl ML20196H8081999-06-28028 June 1999 Discusses 990528 Meeting Re Results of Periodic PPR for Period of Feb 1997 to Jan 1999.List of Attendees Encl ML20212J2521999-06-21021 June 1999 Responds to NRC RAI Re Yr 2000 Readiness at Nuclear Power Plants.Gl 98-01 Requested Response on Status of Facility Y2K Readiness by 990701 ML20196F9171999-06-21021 June 1999 Forwards Owner Rept for ISI for Vogtle Electric Generating Plant,Unit 1 Eighth Maint/Refueling Outage. Separate Submittal Will Not Be Made to NRC on SG Tubes Inspected During Subj Outage ML20195F8031999-06-11011 June 1999 Forwards Changes to VEGP Unit 1 Emergency Response Data Sys (ERDS) Data Point Library.Changes Were Completed on 990308 While Unit 1 Was SD for Refueling Outage ML20207E7421999-06-0303 June 1999 Refers to from NRC Which Issued Personnel Assignment Ltr to Inform of Lm Padovan Assignment as Project Manager for Farley Npp.Reissues Ltr with Effective Date Corrected to 990525 ML20207F6201999-06-0202 June 1999 Sixth Partial Response to FOIA Request for Documents.Records in App J Encl & Will Be Available in Pdr.App K Records Withheld in Part (Ref FOIA Exemptions 7) & App L Records Completely Withheld (Ref FOIA Exemption 7) ML20207D9861999-05-28028 May 1999 Informs That,Effective 990325,LM Padovan Was Assigned as Project Manager for Plant,Units 1 & 2 ML20207D2701999-05-19019 May 1999 Forwards Insp Repts 50-424/99-03 & 50-425/99-03 on 990321- 0501.One Violation of NRC Requirements Identified & Being Treated as non-cited Violation Consistent with App C of Enforcement Policy ML20206M5141999-05-11011 May 1999 Informs That NRC Ofc of Nuclear Regulation Reorganized Effective 990328.As Part of Reorganization,Div of Licensing Project Mgt Created.Rl Emch Section Chief for Vogtle. Reorganization Chart Encl ML20206U4061999-05-11011 May 1999 Confirms Telcon with J Bailey Re Mgt Meeting Scheduled for 990528 to Discuss Results of Periodic Plant Performance Review for Plan Nuclear Facility Fo Period of Feb 1997 - Jan 1999 05000424/LER-1998-006, Forwards LER 98-006-03 Re Motor Control Ctr Breaker Buckets Not Being Seismically Qualified.Rev Is Submitted to Document Results of Seismic Testing That Demonstrated That No Condition Outside Design Basis of TS Requirements Exi1999-05-10010 May 1999 Forwards LER 98-006-03 Re Motor Control Ctr Breaker Buckets Not Being Seismically Qualified.Rev Is Submitted to Document Results of Seismic Testing That Demonstrated That No Condition Outside Design Basis of TS Requirements Existed ML20206D6411999-04-29029 April 1999 Forwards Vogtle Electric Generating Plant Radiological Environ Operating Rept for 1998 & Vogtle Electric Generating Plant Units 1 & 2 1998 Annual Rept Annual Radioactive Effluent Release Rept ML20206D5881999-04-29029 April 1999 Forwards Rept Which Summarizes Effects of Changes & Errors in ECCS Evaluation Models on PCT for 1998,per Requirements of 10CFR50.46(a)(3)(ii).Rept Results Will Be Incorporated Into Next FSAR Update ML20206D6951999-04-28028 April 1999 Provides Update of Plans for VEGP MOV Periodic Verification Program Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs ML20206C2241999-04-21021 April 1999 Forwards Revised Monthly Operating Repts for Mar 1999 for Vogtle Electric Generating Plant,Units 1 & 2.Page E2-2 Was Iandvertently Omitted from Previously Submitted Rept on 990413 ML20206A6371999-04-21021 April 1999 Forwards SE Authorizing Licensee Re Rev 9 to First 10-yr ISI Interval Program Plan & Associated Requests for Relief (RR) 65 from ASME Boiler & Pressure Vessel Code ML20205Q3351999-04-15015 April 1999 Forwards Insp Repts 50-424/99-02 & 50-425/99-02 on 990214-0320.Three Violations Identified & Being Treated as Non-Cited Violations ML20205T2351999-04-0909 April 1999 Informs That on 990317,B Brown & Ho Christensen Confirmed Initial Operator Licensing Exam Scheduled for Y2K.Initial Exam Date Scheduled for Wk of 991213 for Approx 10 Candidates ML20205K7501999-04-0505 April 1999 Informs That Effective 990329,NRC Project Mgt Responsibility for Plant Has Been Transferred from Dh Jaffe to R Assa ML20209A3741999-04-0505 April 1999 Submits Several Requests for Relief for Plant from Code Requirements Pursuant to 10CFR50.55a(a)(3) & (g)(5)(iii).NRC Is Respectfully Requested to Approve Requests Prior to Jan 1,2000 ML20205H3481999-03-31031 March 1999 Forwards Georgia Power Co,Oglethorpe Power Corp,Municipal Electric Authority of Ga & City of Dalton,Ga Status of Decommissioning Funding for Each Reactor or Part of Reactor Owned for OLs NPF-68 & NPF-81 ML20205F9091999-03-29029 March 1999 Submits Rept of Number of SG Tubes Plugged During Plant Eighth Maintenance/Refueling Outage (1R8).Inservice Insps Were Completed on SGs 1 & 4 on 990315.No Tubes Were Plugged ML20205G0761999-03-26026 March 1999 Provides Results of Individual Monitoring for 1998.Encl Media Contains All Info Required by Form NRC 5.Without Encl 1999-09-20
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217P3791999-10-21021 October 1999 Forwards NRC Form 396 & NRC Form 398 for Renewal of Licenses SOP-20607-1 & SOP-20610-1.Without Encls ML20217N2521999-10-20020 October 1999 Provides Supplemental Info Re 990405 Containment Insp Program Requests for Relief RR-L-1 & RR-L-2,in Response to 991013 Telcon with NRC ML20217K7541999-10-15015 October 1999 Forwards Rev 1 to Unit 1,Cycle 9 & Unit 2 Cycle 7 Colrs,Iaw Requirements of TS 5.6.5.Figure 5, Axial Flux Difference Limits as Function of Percent of Rated Thermal Power for RAOC, Was Revised for Both Units ML20217G6751999-10-13013 October 1999 Requests Withholding of Proprietary Info Contained in Application for Amend to OLs to Implement Relaxations Allowed by WCAP-14333-P-A,rev 1 ML20216J9161999-10-0101 October 1999 Forwards Response to NRC 990723 RAI Re GL 95-07, Pressure Locking & Thermal Binding of SR Power-Operated Gate Valves ML20216J9041999-10-0101 October 1999 Forwards Response to RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves ML20212E7481999-09-20020 September 1999 Requests Approval Per 10CFR50.55a to Use Alternative Method for Determining Qualified Life of Certain BOP Diaphragm Valves than That Specified in Code Case N-31.Proposed Alternative,Encl ML20212E8751999-09-20020 September 1999 Forwards Response to NRC GL 99-02, Lab Testing of Nuclear Grade Activated Charcoal. Description of Methods Used to Comply with Std Along with Most Recent Test Results Encl ML20212C2191999-09-16016 September 1999 Forwards NRC Form 536, Operator Licensing Exam Data, Which Is Current Need for NRC Operator Licensing Exams for Years 2000 Through 2003 of Plant Vogtle,Per Administrative Ltr 99-03 ML20211J5291999-08-30030 August 1999 Forwards Snoc Copyright Notice Dtd 990825,re Production of Engineering Drawings Ref in VEGP UFSAR ML20211J5251999-08-30030 August 1999 Forwards Response to NRC 990727 RAI Re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design Basis Accident Conditions ML20211J7381999-08-27027 August 1999 Informs That Licensee Vessel Data Is Different than NRC Database Based on Listed Info,Per 990722 Request to Review Rvid ML20211E9251999-08-23023 August 1999 Forwards fitness-for-duty Performance Data for Jan-June 1999,as Required by 10CFR26.71(d).Data Reflected in Rept Covers Employees at Vogtle Electric Generating Plant ML20210L2181999-08-0202 August 1999 Forwards NRC Form 396 & Form 398 for Renewal of Listed Licenses,Iaw 10CFR55.57.Without Encl ML20210C8011999-07-21021 July 1999 Provides Response to NRC AL 99-02,which Requests That Addressees Submit Info Pertaining to Estimates of Number of Licensing Actions That Will Be Submitted for NRC Review for Upcoming Fy 2000 & 2001 ML20209H3881999-07-14014 July 1999 Forwards Revs 1 & 2 to ISI Program Second 10-Year Interval Vogtle Electric Generating Plant Unit 1 & 2 ML20209C4041999-07-0101 July 1999 Forwards Rev 29 to VEGP Units 1 & 2 Emergency Plan.Rev 29 Incorporates Design Change Associated with Consolidation of Er Facilities Computer & Protues Computer.Justifications for Changes & Insertion Instructions Are Encl ML20196F9171999-06-21021 June 1999 Forwards Owner Rept for ISI for Vogtle Electric Generating Plant,Unit 1 Eighth Maint/Refueling Outage. Separate Submittal Will Not Be Made to NRC on SG Tubes Inspected During Subj Outage ML20212J2521999-06-21021 June 1999 Responds to NRC RAI Re Yr 2000 Readiness at Nuclear Power Plants.Gl 98-01 Requested Response on Status of Facility Y2K Readiness by 990701 ML20195F8031999-06-11011 June 1999 Forwards Changes to VEGP Unit 1 Emergency Response Data Sys (ERDS) Data Point Library.Changes Were Completed on 990308 While Unit 1 Was SD for Refueling Outage 05000424/LER-1998-006, Forwards LER 98-006-03 Re Motor Control Ctr Breaker Buckets Not Being Seismically Qualified.Rev Is Submitted to Document Results of Seismic Testing That Demonstrated That No Condition Outside Design Basis of TS Requirements Exi1999-05-10010 May 1999 Forwards LER 98-006-03 Re Motor Control Ctr Breaker Buckets Not Being Seismically Qualified.Rev Is Submitted to Document Results of Seismic Testing That Demonstrated That No Condition Outside Design Basis of TS Requirements Existed ML20206D5881999-04-29029 April 1999 Forwards Rept Which Summarizes Effects of Changes & Errors in ECCS Evaluation Models on PCT for 1998,per Requirements of 10CFR50.46(a)(3)(ii).Rept Results Will Be Incorporated Into Next FSAR Update ML20206D6411999-04-29029 April 1999 Forwards Vogtle Electric Generating Plant Radiological Environ Operating Rept for 1998 & Vogtle Electric Generating Plant Units 1 & 2 1998 Annual Rept Annual Radioactive Effluent Release Rept ML20206D6951999-04-28028 April 1999 Provides Update of Plans for VEGP MOV Periodic Verification Program Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs ML20206C2241999-04-21021 April 1999 Forwards Revised Monthly Operating Repts for Mar 1999 for Vogtle Electric Generating Plant,Units 1 & 2.Page E2-2 Was Iandvertently Omitted from Previously Submitted Rept on 990413 ML20209A3741999-04-0505 April 1999 Submits Several Requests for Relief for Plant from Code Requirements Pursuant to 10CFR50.55a(a)(3) & (g)(5)(iii).NRC Is Respectfully Requested to Approve Requests Prior to Jan 1,2000 ML20205H3481999-03-31031 March 1999 Forwards Georgia Power Co,Oglethorpe Power Corp,Municipal Electric Authority of Ga & City of Dalton,Ga Status of Decommissioning Funding for Each Reactor or Part of Reactor Owned for OLs NPF-68 & NPF-81 ML20205F9091999-03-29029 March 1999 Submits Rept of Number of SG Tubes Plugged During Plant Eighth Maintenance/Refueling Outage (1R8).Inservice Insps Were Completed on SGs 1 & 4 on 990315.No Tubes Were Plugged ML20205G0761999-03-26026 March 1999 Provides Results of Individual Monitoring for 1998.Encl Media Contains All Info Required by Form NRC 5.Without Encl ML20205H4051999-03-25025 March 1999 Forwards Info on Status of Decommissioning Funding for Each Reactor or Part of Reactor Owned for OLs NPF-68 & NPF-81,as Requested IAW 10CFR50.75(f)(1) ML20205H3891999-03-25025 March 1999 Forwards Info on Status of Decommissioning Funding for Each Reactor or Part of Reactor Owned for OLs NPF-68 & NPF-81,as Requested IAW 10CFR50.75(f)(1).Page 2 in Third Amend Power Sales Contract of Incoming Submittal Not Included ML20205A9441999-03-25025 March 1999 Forwards VEGP Unit 1 Cycle 9 Colr,Per TS 5.6.5.d ML20205H3811999-03-24024 March 1999 Forwards Info on Status of Decommissioning Funding for Each Reactor or Part of Reactor Owned for OLs NPF-68 & NPF-81,as Requested IAW 10CFR50.75(f)(1) ML20205H3621999-03-22022 March 1999 Forwards Info on Status of Decommissioning Funding for Each Reactor or Part of Reactor Owned for OLs NPF-68 & NPF-81, as Requested IAW 10CFR50.75(f)(1) ML20204G4361999-03-18018 March 1999 Forwards Summary Rept of Present Level & Source of on-site Property Damage Insurance Coverage for Vegp,Iaw Requirements of 10CFR50.54(w)(3) ML20204C0591999-03-17017 March 1999 Forwards Rev 0 to WCAP-15160, Evaluation of Pressurized Thermal Shock for Vegp,Unit 2 & Rev 0 to WCAP-15159, Analysis of Capsule X from Vegp,Unit 2 Reactor Vessel Radiation Surveillance Program ML20207K9551999-03-11011 March 1999 Forwards Response to Rai,Pertaining to Positive Alcohol Test of Licensed Operator.Encl Info Provided for NRC Use in Evaluation of Fitness for Duty Occurrence.Encl Withheld,Per 10CFR2.790(a)(6) ML20207L9721999-03-10010 March 1999 Forwards Rev 15 to EPIP 91104-C of Manual Set 6 of Vogtle Epips.Without Encl ML20207B0191999-02-25025 February 1999 Forwards Fitness for Duty Performance Data for six-month Reporting Period 980701-1231,IAW 10CFR26.71(d) 05000424/LER-1998-009, Forwards LER 98-009-00 Re Event in Which Improper Testing Method Resulted in Inadequate Surveillances on 9812291999-01-27027 January 1999 Forwards LER 98-009-00 Re Event in Which Improper Testing Method Resulted in Inadequate Surveillances on 981229 ML20199F7701999-01-13013 January 1999 Submits Revised Response to RAI Re Licensee 980713 Proposed Amend to Ts,Eliminating Periodic Response Time Testing Requirements on Selected Sensors & Protection Channels. Corrected Copy of Table,Encl ML20199F7981999-01-13013 January 1999 Forwards Corrected Pages to VEGP-2 ISI Summary Rept for Spring 1998 Maint/Refueling Outage. Change Bar in Margin of Affected Pages Denotes Changes to Rept ML20199G1381999-01-13013 January 1999 Forwards Copy of Permit Renewal Application Package for NPDES Permit Number GA0026786,per Section 3.2 of VP Environ Protection Plan 05000424/LER-1998-007, Forwards LER 98-007-00,re Inadequate Surveillances Due to Improperly Performed Response Time Testing,On 981215,IAW 10CFR50.731999-01-13013 January 1999 Forwards LER 98-007-00,re Inadequate Surveillances Due to Improperly Performed Response Time Testing,On 981215,IAW 10CFR50.73 ML20198F6131998-12-18018 December 1998 Forwards Revised Certification of Medical Exam Form for License SOP-21147.Licensee Being Treated for Hypertension. Util Requests That Individual License Be Amended to Reflect Change in Status ML20198L6631998-12-18018 December 1998 Forwards Amend 37 to Physical Security & Contingency Plan. Encl 1 Provides Description & Justification for Changes & Encl 2 Contains Actual Amend 37 Pages.Amend Withheld,Per 10CFR73.21 ML20198D9291998-12-16016 December 1998 Forwards Requested Info Re Request to Revise TSs Elimination of Periodic Pressure Sensor Response Time Tests & Elimination of Periodic Protection Channel Response Time Tests ML20198D9991998-12-16016 December 1998 Forwards Responses to 980916 RAI Re Response to GL 97-01, Degradation of Control Rod Drive Mechanism Nozzle & Other Vessel Closure Head Penetrations ML20198D8171998-12-14014 December 1998 Forwards NRC Form 396 & Form 398 for Renewal of License OP-20993.Without Encls ML20206N3051998-12-0808 December 1998 Submits RAI Re Replacement of Nuclear Instrument Sys Source & Intermediate Range Channels & post-accident Neutron Flux Monitoring Sys 1999-09-20
[Table view] Category:UTILITY TO NRC
MONTHYEARELV-02056, Forwards Operator Exam Schedule for Facility,Per Generic Ltr 90-07 Request,Including Number of Candidates to Be Examined During NRC Site Visits,Requalification Schedules & Number of Candidates to Participate in Generic Fundamentals Exam1990-09-0606 September 1990 Forwards Operator Exam Schedule for Facility,Per Generic Ltr 90-07 Request,Including Number of Candidates to Be Examined During NRC Site Visits,Requalification Schedules & Number of Candidates to Participate in Generic Fundamentals Exam ELV-01599, Discusses Mods to HED-1114 Re Plant Dcrdr,Per . Amber Monitor Light Covers Installed for Spare Pumps to Make Status of Pumps Readily Apparent to Operator1990-09-0404 September 1990 Discusses Mods to HED-1114 Re Plant Dcrdr,Per . Amber Monitor Light Covers Installed for Spare Pumps to Make Status of Pumps Readily Apparent to Operator ELV-02059, Clarifies 900409 Response to 900323 Confirmation of Action Ltr.Util Made 31 Successful Start Attempts for Diesel Generator (DG) 1A & 29 Successful Start Attempts for DG 1B1990-08-30030 August 1990 Clarifies 900409 Response to 900323 Confirmation of Action Ltr.Util Made 31 Successful Start Attempts for Diesel Generator (DG) 1A & 29 Successful Start Attempts for DG 1B ELV-01956, Forwards Listed Documents in Response to Request for Addl Info Re Settlement Monitoring Program,Per 900614 Request1990-08-30030 August 1990 Forwards Listed Documents in Response to Request for Addl Info Re Settlement Monitoring Program,Per 900614 Request ELV-02050, Responds to Violations Noted in Insp Repts 50-424/90-08 & 50-425/90-08.Corrective Actions:Administrative Procedures Controlling Verification & Validation of Emergency Operating Procedures Will Be Evaluated & Revised as Required1990-08-30030 August 1990 Responds to Violations Noted in Insp Repts 50-424/90-08 & 50-425/90-08.Corrective Actions:Administrative Procedures Controlling Verification & Validation of Emergency Operating Procedures Will Be Evaluated & Revised as Required ELV-02028, Forwards Fitness for Duty Performance Data for First Six Month Period,Per 10CFR26.71(d)1990-08-22022 August 1990 Forwards Fitness for Duty Performance Data for First Six Month Period,Per 10CFR26.71(d) ELV-02022, Forwards Revised LER Re Apparent Personnel Error Leading to Unsecured Safeguards Info.Ler Withheld1990-08-22022 August 1990 Forwards Revised LER Re Apparent Personnel Error Leading to Unsecured Safeguards Info.Ler Withheld ELV-02027, Forwards Rev 0 to Core Operating Limits Rept, for Cycle 3, Per Amends 32 & 12 to Licenses NPF-68 & NPF-79,respectively1990-08-20020 August 1990 Forwards Rev 0 to Core Operating Limits Rept, for Cycle 3, Per Amends 32 & 12 to Licenses NPF-68 & NPF-79,respectively ELV-01973, Submits Rept Re Results of Leakage Exams Conducted During Spring 1990 Refueling Outage,Per TMI Item III.D.1.1.None of Identified Leakage Considered Excessive.Work Orders Issued in Effort to Reduce Leakage to Level as Low Practical1990-08-14014 August 1990 Submits Rept Re Results of Leakage Exams Conducted During Spring 1990 Refueling Outage,Per TMI Item III.D.1.1.None of Identified Leakage Considered Excessive.Work Orders Issued in Effort to Reduce Leakage to Level as Low Practical ELV-01918, Responds to NRC 900612 Request for Comments & Suggestions on Draft risk-based Insp Guide.Util Conducting Individual Plant Exam & Will Withhold Comment on risk-based Insp Guide Until Completion1990-08-0303 August 1990 Responds to NRC 900612 Request for Comments & Suggestions on Draft risk-based Insp Guide.Util Conducting Individual Plant Exam & Will Withhold Comment on risk-based Insp Guide Until Completion ELV-01943, Responds to Violation & Proposed Imposition of Civil Penalty in Insp Repts 50-424/90-11 & 50-425/90-11.Corrective Action: Complete Audit of Contents of Safeguards Info Container Performed & Unassigned Safeguards Info Dispositioned1990-07-27027 July 1990 Responds to Violation & Proposed Imposition of Civil Penalty in Insp Repts 50-424/90-11 & 50-425/90-11.Corrective Action: Complete Audit of Contents of Safeguards Info Container Performed & Unassigned Safeguards Info Dispositioned ELV-01949, Forwards Info Re Status of Pen Branch Fault Investigation. Investigations Conducted So Far Still Indicate That Pen Branch Fault Not Capable1990-07-26026 July 1990 Forwards Info Re Status of Pen Branch Fault Investigation. Investigations Conducted So Far Still Indicate That Pen Branch Fault Not Capable ELV-01500, Forwards Nuclear Decommissioning Funding Plan for Plant.Info Provides Assurance That NRC Prescribed Min Funding Will Be Available to Decommission Facilities1990-07-25025 July 1990 Forwards Nuclear Decommissioning Funding Plan for Plant.Info Provides Assurance That NRC Prescribed Min Funding Will Be Available to Decommission Facilities ML20055H6441990-07-23023 July 1990 Submits Summary of Snubber Types & Sample Plans for Functional Testing to Be Performed During Sept 1990 Outage ML20044B0311990-07-13013 July 1990 Forwards Vogtle Electric Generating Plant Unit 1 Reactor Containment Bldg 1990 Integrated Leakage Rate Test Final Rept. ML20044B1541990-07-12012 July 1990 Responds to NRC 900612 Ltr Re Violations Noted in Insp Repts 50-424/90-08 & 50-425/90-08.Corrective Actions:Eop Step Deviation Documents to Be Upgraded,Adding More Justification & Temporary Change Issued to Correct EOP Deficiencies ELV-01867, Responds to Violations Noted in Insp Repts 50-424/90-10 & 50-425/90-10.Corrective Action:Level Indication Error Corrected After Discrepancy Discovered1990-07-12012 July 1990 Responds to Violations Noted in Insp Repts 50-424/90-10 & 50-425/90-10.Corrective Action:Level Indication Error Corrected After Discrepancy Discovered ML20055F1651990-07-0909 July 1990 Forwards Comments Re NUREG-1410 ELV-01858, Advises That Full Compliance W/Violation Will Not Be Achieved Until Nov 1990,when Evaluation of VP-2693 Complete1990-07-0606 July 1990 Advises That Full Compliance W/Violation Will Not Be Achieved Until Nov 1990,when Evaluation of VP-2693 Complete ML20044A8851990-07-0606 July 1990 Forwards Response to NRC Question on Steam Generator Level Instrumentation Setpoints,Per Revised Instrument Line Tap Locations.Tap Location Will Be Changed from Above Transition Cone to Below Transition Cone ELV-01834, Forwards Response & Comments to Regulatory Effectiveness Review Rept.Encl Withheld (Ref 10CFR73.21)1990-06-28028 June 1990 Forwards Response & Comments to Regulatory Effectiveness Review Rept.Encl Withheld (Ref 10CFR73.21) ML20044A2791990-06-25025 June 1990 Responds to Generic Ltr 90-04, Request for Info on Status of Licensee Implementation of Generic Safety Issues Resolved W/Imposition of Requirements or Corrective Actions. Table Indicating Status of Each Generic Safety Issue Encl ML20043J0171990-06-22022 June 1990 Discusses Corrective Actions for Plant Site Area Emergency, Per 900514 Ltr.Jacket Water High Temp Switches Calibr for Diesel Generators,Using Revised Calibr Procedure ML20043H3061990-06-15015 June 1990 Forwards Rev 3 to ISI-P-014, Inservice Insp Program, for Review & Approval,Per Tech Spec 4.0.5 Re Surveillance Requirements.Rev Includes Withdrawal of Relief Requests RR-45,47,48 & 54 ML20043G2071990-06-12012 June 1990 Forwards Amend 18 to Physical Security & Contingency Plan. Amend Withheld (Ref 10CFR73.21) ML20043G1021990-06-0606 June 1990 Requests Temporary Waiver of Compliance from Requirements of Action Statement 27 of Tech Spec 3.3.2 for Period of 6 H When Two Operating Control Room Emergency Filtration Sys Trains Shut Down for Required Testing ML20043E6901990-06-0505 June 1990 Forwards Rev 12 to Emergency Plan & Detailed Description & Justification of Changes.W/O Rev ML20043G7651990-06-0505 June 1990 Forwards Rev 13 to Emergency Plan & Description & Justification of Changes ML20043B5991990-05-25025 May 1990 Forwards Scope & Objectives Re 1990 Annual Emergency Preparedness Exercise to Be Conducted on 900801 ML20043B5981990-05-24024 May 1990 Responds to Violations Noted in Insp Rept 50-424/90-05 on 900217-0330.Corrective Actions:Locked Valve Procedure Revised to Eliminate Utilization of Hold Tag on Valves Required by Tech Specs to Be Secured in Position ML20043B6291990-05-22022 May 1990 Forwards Rev 5 to ISI-P-008, Inservice Testing Program, Per Tech Specs 4.0.5 Re Surveillance Requirements & Generic Ltr 89-04 ML20043B6351990-05-22022 May 1990 Forwards Rev 2 to ISI-P-016, Inservice Testing Program, Per Generic Ltr 89-04, Guidance on Developing Acceptable Inservice Testing Programs. ML20042H0601990-05-14014 May 1990 Forwards Summary of Corrective Actions for 900320 Site Area Emergency Due to Loss of Offsite Power Concurrent W/Loss of Onsite Emergency Diesel Generator Capability.Truck Driver Disciplined for Lack of Attention ML20042G7301990-05-11011 May 1990 Forwards Revised Pages for May 1989,Jan & Mar 1990 Monthly Operating Repts for Vogtle Electric Generating Plant,Units 1 & 2.Revs Necessary Due to Errors Discovered in Ref Repts ML20042E2911990-04-18018 April 1990 Forwards Amend 17 to Security Plan.Amend Withheld (Ref 10CFR2.790) ML20042E7481990-04-0909 April 1990 Requests Approval to Return Facility to Mode 2 & Subsequent Power Operation,Per 900320 Event Re Loss of Offsite Power Concurrent W/Loss of Onsite Emergency Diesel Generator Capability ML20012E9001990-03-28028 March 1990 Provides Supplemental Response to Station Blackout Rule,Per NUMARC 900104 Request.Mods & Associated Procedure Changes Identified in Sections B & C W/Exception of Mods to Seals Will Be Completed 1 Yr from Acceptance of Analysis ML20012E8581990-03-28028 March 1990 Suppls Response to NRC Bulletin 88-010,Suppl 1 Re Traceability Reviews on Molded Case Circuit Breakers Installed in safety-related Applications.All Breakers Procured & Installed in Class 1E Equipment Reviewed ML20012E9761990-03-27027 March 1990 Requests Withdrawal of Inservice Insp Relief Requests RR-45, RR-47,RR-48 & Conditional Withdrawal of RR-54 Based on Reasons Discussed in Encl,Per 900206 Conference Call ML20012D8561990-03-22022 March 1990 Submits Special Rept 1-90-02 Re Number of Steam Generator Tubes Plugged During 1R2.One of Four Tubes Exceeded Plugging Limit & Required Plugging.Remaining Three Tubes Plugged as Precautionary Measure.No Defective Tubes Detected ML20012D6641990-03-22022 March 1990 Provides Followup Written Request for Waiver of Compliance to Make Tech Spec 3.04 Inapplicable to Tech Spec 3.8.1.2 to Permit Entry Into Mode 5 W/Operability of Diesel Generator a & Associated Load Sequencer Unverified ML20012D3681990-03-19019 March 1990 Forwards Proprietary & Nonproprietary Suppl 2 to WCAP-12218 & WCAP-12219, Supplementary Assessment of Leak-Before-Break for Pressurizer Surge Lines of Vogtle Units 1 & 2, Per 900226 Request.Proprietary Rept Withheld (Ref 10CFR2.790) ML20012D3401990-03-19019 March 1990 Submits Response to 891121 Request for Addl Info Re Settlement Monitoring Program.Current Surveying Procedures Used by Plant to Monitor Settlement of Major Structures Outlined in Procedure 84301-C.W/41 Oversize Drawings ML20012D6631990-03-15015 March 1990 Responds to Generic Ltr 89-19 Re Resolution of USI A-47 on Safety Implications of Control Sys in Lwrs.Overfill Protection Sys Sufficiently Separate from Control Portion of Main Feedwater Control Sys & Not Powered from Same Source ML20012C4681990-03-0606 March 1990 Provides Summary Rept of Property Damage Insurance Levels, Per 10CFR50.54(w)(1) ML20012B2891990-03-0606 March 1990 Forwards Plant Pipe Break Isometrics,Vols 1 & 2 & Advises That Encl Figures Have Been Revised to Be Consistent W/Pipe Analysis in Effect at Time That Unit 2 Received Ol,Including Revs Through 890930.W/309 Oversize Figures ML20012B2421990-03-0606 March 1990 Forwards Cycle 3 Radial Peaking Factor Limit Rept & Elevation Dependent Peaking Factor Vs Core Height Graph ML20011F5291990-02-26026 February 1990 Withdraws 881107 Proposed Amend to Tech Spec 3.8.1.1, Revising Action Requirements for Inoperable Diesel Generator to Clarify Acceptability of Air Roll Tests on Remaining Operable Diesel Generator ML20011F5261990-02-26026 February 1990 Forwards 1989 Annual Rept - Part 1. Part 2 Will Be Submitted by 900501 ML20011E8911990-02-12012 February 1990 Advises That Hh Butterworth No Longer Employed by Util 1990-09-06
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Georgia Power Comparry 333 P edmont Avenue At!anta, Georgia 30308 Telephone 404 5264526 Mahng Address Post Off.ce Box 4545 A!!anta. Georg a 30302 Georgia Power L. T. Gucwa the southem e,'ectrc system Manager Nuclear Sa'ety and Lcensing SL-4404 0849m X7GJ17-V120 April 18, 1988 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D.C. 20555 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 REPLY TO A NOTICE OF VIOLATION Gentlemen:
In accordance with the provisions of 10 CFR 2.201, Georgia Power Company (GPC) submits the enclosed information in response to NRC.
Inspection Report 50-424/88-09 which concerns the inspection conducted by Messrs. J. F. Rogge and C. H. Burger of the NRC Region II staff on January 30 -
February 26, 1988. A copy of this response is being t provided to the NRC Region II office for review. '
In each of the enclosures, transcription of the NRC violation precedes GPC's response.
Should there by any questions in this regard, please contact this office at any time.
Sincerely, ed?~ -%=.
L. T. Gucwa JAE/1m
Enclosures:
- 1. Violation 88-09-01 and GPC Response
- 2. Violation 88-09-02 and GPC Response c: (see next page)
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GeorgiaPower A U. S. Nuclear Regulatory Commi.sion April 18, 1988 Page Two.
c: Georaia Power Comoany Mr. P. D. Rice Mr. G. Bockhold, Jr.
GO-NORMS U. S. Nuclear Regulatory Commission Dr. J. N. Grace, Regional Administrator Mr. J. B. Hopkins Licensing Project Manager, NRR (2 copies) l Mr. J. F. Rogge. Senior Resident Inspector-Operations, Vogtle l I
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Georgia Power d ENCLOSURE 1 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 HRC NOTICE OF VIOLATION 88-09-01 AND GPC RESPONSE VIOLATION 50-424/88-09-01 "Technical Specification 6.7.la requires that procedures shall be established, covering activities delineated in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Maintenance Procedure No.
24551-1, Rev. 7 "Containment Hydrogen Monitor Train A Analog Channel Operational Test And Channel Calibration" and Maintenance Procedure No.
24552-1, Rev. 7 "Containment Hydrogen Monitor B Analog Channel Operational Test And Channel Calibration" contains the specific procedures for the required surveillance tests.
Contrary to the above, on February 1, 1988, Maintenance Procedure Nos.
24551-1 and 24552-1 had not been adequately established in that these procedures did not contain measures to preclude rendering the respective monitors inoperable as a result of performing the surveillance.
This is a Severity Level IV Violation (Supplement I)."
RESPONSE TO VIOLATION 50-424/88-09-01 Admission or denial of alleged violation:
The violation occurred as stated.
Reason for the violation:
The violation occurred due to noncomplience with the surveillance procedure. The procedure required that internal leads be disconnected; however, the field leads were disconnected.
Corrective steos which have been taken and the results achieved:
(1) The GPC Instrument and Controls technician who violated the surveillance procedure has been counseled rega.-ding the importance of procedural compliance.
(2) The hydrogen monitor field leads have been labeled to identify the terminals to which they are to be connected.
0849m El-1 04/18/88 SL-4404 l
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Georgia Power d ENCLOSURE 1 (Continued)
NRC NOTICE OF VIOLATION 88-09-01 AND GPC RESPONSE (3) Procedure 24551-1, Rev. 7, "Containment Hydrogen Monitor Train A Analog Channel Operational Test and Channel Calibration," and Procedure 24552-1, Rev. 7, "Containment Hydrogen Monitor Train B Analog Channel Operational Test and Channel Calibration," were revised to preclude recurrence of this event.
(4) The independent verification process for unlabeled wires was revised so that Jumper and Lifted Hire tags will not be removed until the 1
verification process is completed. Applicable procedures were revised by April 15, 1988.
Corrective steos which will be taken to avoid further violations:
The corrective actions discussed above are expected to preclude further violations.
Date when full comoliance will be achieved:
Full compliance was achieved on April 15, 1988 when applicable procedures revisions concerning the independent verification process for unlabeled wires were completed.
0849m El-2 04/18/88 SL-4404
Georgia Power d ENCLOSURE 2 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 NRC NOTICE OF VIOLATION 88-09-02 AND GPC RESPONSE VIOLATION 50-424/88-09-02 "10 CFR 50.73 requires in part, that the Licensee Event Report shall be submitted within 30 days after discovery of an event. 10 CFR 50.73(a)(2), requires, in part, a report for any operation or condition prohibited by the plant's Technical Specification.
Contrary to the above, the licensee failed to report events within 30 days of discovery as follows:
- 1. On July 23, 1987, an event was discovered which occurred on July 12, 1987, involving a failure to perform an Analog Channel Operational Test Surveillance on the Power Low Setpoint prior to the unit startup.
- 2. On June 24, 1987, an event was discovered which ider,ti fi ed that missed surveillances were not always reported. Five missed surveillances were not reported because the subsequent surveillance was performed satisfactorily.
Failure to perform a required surveillance is a condition prohibited by the plant's Technical Specification.
This is a Severity Level IV Violation (Supplement I)."
RESPONSE TO VIOLATION 50-424/88-09-02 VIOLATION EXAMPLE 1 Admission or denial of alleged violation:
The alleged violation occurred as stated based on example I cited in the Notice of Violation. However, based upon our review of the "Details" associated with NRC Inspection Report 50-424/88-09, GPC does have comments. In the "Details" associated with the inspection report, it was stated:
"TS Section 4.0.2 is to be applied to surveillance requirements only and has no applicability to the limiting conditions for operability or the action statements. Action statements invoking surveillance requirements should be met without the benefit of 4.0.2 provisions, since the unit is in a degraded condition and licensee attention is focused on ensuring that the plant is maintained in the safest condition. It is for this reason, that a grace period does not exist in the 3.0.X section of the TS."
0849m E2-1 04/18/88 SL-4404 700??S
Georgia Power d ENCLOSURE 2 (Continued)
NRC NOTICE OF VIOLATION 88-09-02 ANG GPC RESPONSE He agree. The main point of the above discussion, however, is that extensions to action statement requirements of Section 3.0.X of the Technical Specifications are not allowed. By a point of definition, in the referenced example, GPC was not "in" Section 3.0.X of the Technical Specifications. Rather, the applicable section was 4.3.1.1 (and Table 4.3-1, Reactor Trip System Instrumentation Surveillance Requirements).
The note associated with the Analog Channel Operational Test is an "S/U (1)". In the "Table Notations" for the referenced table, the Technical Specification (page 3/4 3-13), Note (1) states:
"If not performed in previous 31 days".
On August 18, 1987, corporate GPC was informed by Plant Vogtle personnel that an Analog Channel Operational Test (ACOT) surveillance was not performed during the reactor startup of July 12, 1987. However, the ACOT was performed during the reactor startup of June 5, 1987 and July 23, 1987. A review of the Technical Specifications indicated that there are no provisionary notes in the Table Notations to indicate that 4.0.2 does not apply. Additionally, there are no notes associated with the Surveillance Requirements of the Reactor Trip System Instrumentation (page 3/4 3-1) to indicate that 4.0.2 does not apply.
In reviewing this condition, GPC noted that the surveillance of June 12, 1987 and July 23, 1987 have successfully demonstrated the operability of the equipment; thus, there was no reason to assume the equipment would not have functioned correctly during the intervening period of July 12, 1987 to July 23, 1987. The situation in question involved a surveillance which is to be performed prior to each startup, with a provision that, if an ACOT was performed in a startup within the previous 31 days, the ACOT did not have to be performed. In this case, successful ACOT's were performed before and after the event in question. Additionally, since there were no provisions to indicate otherwise, GPC applied the provision of 4.0.2 to this 4.3.1.1 surveillance and concluded that a licensee event report was not required. That is, since the surveillance in question was completed within 38 days (31 days + 257.) of the surveillance that occurred on June 5,1987, it was concluded that the July 12 startup was within Technical Specification requirements. Since the purposes of surveillances are to demonstrate that equipment is functioning properly and since this surveillance was within 4.0.2 requirements of the T.S. and bounded by the surveillances performed on June 5 and July 23, 1987, GPC believed that the missed surveillance was not reportable. Thus, this event does involve an interpretation of the applicability of 4.0.2, not Section 3.0.X of the Technical Specifications.
0849m E2-2 04/18/88 SL-4404 70077$ .
Georgia Power d ENCLOSURE 2 (Continued)
NRC NOTICE OF VIOLATION 88-09-02 AND GPC RESPONSE Reason for the violation _;.
At the time this condition was detected, a review indicated that the surveillance was not required since the inspection interval of 3. days could be extended by 25%. It now appears that the provisions of 4.0.2 may have been incorrectly applied to the extension of the surveillance interval.
Corrective steos which have been taken and the results achieved:
Subsequent to the issuance of generic letter 87-09, GPC conducted a l review of the letter and decided to report all missed surveillance; i.e.,
except those performed within the 25% grace period of 4.0.2. In this case, we believed we were within the 25% grace period, therefore the event was not reported. ,
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Corrective steos which will be taken to avoid further violations: l I
A memo was dictated on July 13, 1987 that explained that as a result of NRC Generic Letter 87-09, all missed surveillances will be reported. As previously mentioned, since we believed that this surveillance met the provision of 4.0.2, it was not reported. Since that time, we have reported missed surveillances to the NRC. Additionally, a memo concerning 4.0.2 applicability will be developed by appropriate GPC personnel and distributed to appropriate personnel by May 6, 1988.
D3te when full comoliance will be achieved:
Full compliance was achieved with the issuance of the July 13, 1987 memo. Since that time, missed surveillances, i.e., those beyond the 25%
grace period allowed by Section 4.0.2, have been reported. As previously discussed, we believe that this surveillance was not missed since it fell under the provision of 4.0.2.
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GeorgiaPower b ENCLOSURE 2 (Continued)
NRC NOTICE OF VIOLATION 88-09-02 AND GPC RESPONSE VIOLATION EXAMPLE 2 Admission or denial of alleaed violation:
The violation illustrated as the second example did not occur as stated.
Pursuant to the following discussion, GPC requests that the example be withdrawn, recognizing that the other example does support the cited violation.
Georgia Power Company decided, prior to the issuance of the NOV, that LER's were not required for missed surveillances where the surveillance was performed within the applicable LCO time period and operability was demonstrated as a result of the surveillance.
In the Statement of Considerations for the proposed rule 10 CFR 50.73(a)(2)(i)(B) for the Licensee Event Report System (Federal Regulation Vol. 47, No. 88, Thursday, May 6,1982) it states:
"Finally the licensee must report events where an Action Statement contained in a Limiting Condition for Operation is not met. For an Action Statement that gives the licensee alternatives (e.g., repair a specific component or achieve hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />), the Action Statement is met if either alternative is met (e.g., the component is repaired or the plant is in hot shutdown within'12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />). Failure to comoly with a Surveillance Reauirement need not be reoorted as an LER.
but should be tabulated in the Monthlv Operating Reoort" (emphasis throughout this discussion added by GPC). The final rule (which appeat ed in the Federal Register /Vol. 48, No. 168/ Monday, August 29, 1983) contained no clarifications in the supplementary information on the paragraph-by-paragraph interpretation of the LER rule to indicate that there had been a fundamental change in the NRC's position. The proposed rule of also discussed Technical violation of action statements rather than violation Specifications. It should also be noted that the NRC did indicate fundamental changes to the interpretation of the requirements of the final LER rule, but no clarifications were indicated for surveillance requirements.
Additionally, NUREG-1022 Supplement 1 was reviewed for additional guidance and interpretations. Section 2.0 discussed Technical Specification Violations.
Question 2.1 asked "Is it correct that I do not have to submit a LER unless I actually reach the end of an LC0 clock"? The NRC response was "Yes. f_qr.the 0849m E2-4 04/18/88 SL-4404
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Georgia Power A ENCLOSURE 2 (Continued)
NRC NOTICE OF VIOLATION 88-09-02 AND GPC RESPONSE ouroose p11his criterion (i.e., a2iB) an LER is not required unless the conditions of the LC0 and its associated Action Statement are not met (i.e., are violated) or the plant must be shut down because of a Technical Specification requirement (i.e., 'the end of an LC0 clock')."
GPC applied this Q&A response as reflecting the Proposed Rules intent of L
not reporting missed surveillances unless the LCO also was exceeded or action statements not met.
Question 2.3 asked, "We believe that surveillance testing and redundancy together promise assurance of operability. Further, we often have 7-day LCO's and we perform surveillance tests on 30-day intervals. Is an LER required every time we find a problem during surveillance testing?" The NRC's responce was "No." In general, for the purpose of evaluating the reportability of situations found during surveillance tests, it should be assumed that the situation occurred at the time of discovery unless there is firm evidence to believe otherwise." GPC interpretated this Q&A as stating that LER's for missed surveillances were evaluated based on the time of discovery; not the' time the surveillance was originally missed.
This interpretation, :<e felt, was consistent with the NRC's explan-tion of 10 CFR 50.73 (a)(2)(1)(B) in NUREG-1022, which stated in part: "If -
the condition is corrected oefore the (LC0) time limit for being shutdown (i.e., before completion of the reported."
shutdown) the event need not be In other words, upon discovery of a missed surveillance, the
, LCO action statement and time limits applied and, provided that the condition was corrected before the LC0 clock expired, a report was r.ot required.
He believe it clear that LC0's and Action Statements were the focus of the original rule and a separate "clock" for reporting missed surveillances did not exist.
Georgia Power Company applied the regulatory guidance in these NRC documents and concluded that the purpose of a surveillance test is to demonstrate the operability of a component in order to ensure compliance with the associated LCO. If a surveillance test is missed, the components' operability has not been demonstrated; thus, upon discovery, one conservatively enters the applicable Action Statement.
This is similar to a component failing a surveillance test, declaring the component inoperable, and entering the applicable Action Statement. As previously promulgated in NUREG-1022, Supplement No. 1. Question 2.3, a failed surveillance test is not reportable under 10 CFR 50.73(a)(2)(i)(B), provided that the applicable LC0 Actioh Statement is entered and followed.
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GeorgiaPower A ENCLOSURE 2 (Continued)
NRC NOTICE OF VIOLATION 88-09-02 AND GPC RESPONSE In Generic Letter 87-09 the NRC expanded its position in direct conflict, we believe, with the original LER rule. This letter states:
"To avoid any conflict among or misreading of Specifications 3.0.2, 4.0.3, and 4.0.2, the staff wishes to make clear (1) that Specification 3.0.2 shall not be construed to imply that the completion of a missed surveillance within the allowable outage time limits of the Action Requirements--whether or not the additional 24-hour time limit is included--negates the violation of Specification 4.0.3, and (2) that the failure to oerform a surveillance within the allowable surveillance interval defined by Soecification 4.0.2 constitutas a reoortable event under 10 CFR 50.73(a)(2)(1)(B) because it is a condition orchibited by the olant's TS."
This paragraph provided the first indication that the NRC interpreted that a missed surveillance that exceeded the allowable time limits of the Action Requirements and the failure to perform a surveillance as defined by Specification 4.0.2 constituted a reportable event separate and distinct from violating action statements. Thus, at present, a new NRC interpretation is being retroactively applied to the group of events in the second example cited in the inspection report.
In any event, GPC, on July 13, 1987, modified its prior interpretation and has no plans to challenge this new NRC interpretation as a backfit.
However, we request the withdrawal of the examples of violations since the violation is based on a "i.tw" reporting requirement. Prospectively, any missed surveillance that is not performed within its frequency interval + 251,will be reported under the Generic Letter requirement.
0849m E2-6 04/18/88 SL-4404 700775