HL-2009, Responds to NRC Re Violations Noted in Insp Repts 50-321/91-30 & 50-366/91-30.Corrective Actions:Clarification Program Revised to Require All Changes to FHA Be Reviewed for Technical Accuracy

Responds to NRC Re Violations Noted in Insp Repts 50-321/91-30 & 50-366/91-30.Corrective Actions:Clarification Program Revised to Require All Changes to FHA Be Reviewed for Technical Accuracy

ML20091K706
Person / Time
Site:	Hatch
Issue date:	01/17/1992
From:	Beckham J GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HL-2009, NUDOCS 9201270036
Download: ML20091K706 (4)

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Hittch Pr0{ect HL-2009 January 17, 1992 002 M U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES OPR-57, NPF-5 REPLY TO A NOTICE OF VIOLATION Gentlemen:

In response to your letter of December 19, 1991, and in accordance with the provisions of 10 CFR 2.201, Georgia Power Company is providing the enclosed response to the Notice of Violation associated with NRC Inspection .

Report 91-30. A co)y of this respoitse is being provided to NRC Region 11  ?

for review. In t ie enclosure, a transcription of the NRC violation precedes GPC's response.

Sincerely,

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M p.T.Beckham,Jr.

J1b/cr Enclosure cc: Georaia Power Company Mr. H. L. Sumner, General Manager - Nuclear Plant NORMC U.S. Nuclear Reaulatory Commission. Washinaton. D.C.

Mr. K. Jabbour, licensing Project Manager - Hatch

_ U.S. Nuclear Reaulatory Commission. Reaion 11 Mr. S. D. Ebneter, Regional Administrator

• Mr. L. D. Wert, Senior Resident Inspector - Hatch I

9201270036 920117 Li PDR ADOCK 05000321

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ENCLOSURE PLANT HATCH-UNI ,1 AND 2 NRC DOCKETS 50-321 AND 50-366 OPERATING LICENSES DPR-5) AND NPF-5 VIOLATION 91-30-01 AND GPC RESPONSI yJ0LAT10N 91-30-01 Operating License paragraph 2.C.(3) for Unit I and paragraph 2.C.(3).b for Unit 2 states that Georgia Power shall implement and maintain in effect all provisions of the fire protection program, which is referenced in the Final Safety Analysis Report for the facility, as contained in the updated Edwin I. Hatch Nuclear Plant Units 1 and 2 Fire Hazards Analysis and fire Protection Program, originally submitted by a letter dated July 22, 1986.

The Licensee may make chang s to the fire protection program without prior approval of the Commission only if the changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

The Fire Hazards Analysis (FHA), Appendix D, Item IV.B.6.c, states that procedures for fire brigade training have been written in accordance with the NRC guidelines contained in the June 20, 1977 document entitled Nuclear Plant Fire Protection Responsibilities, Administrative Controls and Quality Assurance. Attachment 2 to the 1977 NRC guidelines identifies an acceptable fire brigade training program, including fire brigade drills.

Fire brigade drills are to be performed at regular intervals but not to exceed three months for each brigade.

The FHA Appendix H states that the fire detection system at Hatch conforms to the requirements of National Fire Protection Association (NFPA) 72E, Automatic fire Detectors, except for some minor spacing and location deviations. NFPA 72E, Sections 8-2.4 and 8-3.4.1, require each automatic smoke detect ( to be visually inspected at least semiannually and operationally :sted annually with smoke or other aerosol acceptable to the manufacturer.

Contrary to the above, these requirements were not met in.that:

1. Jocedure 40AC-008-0S (sic), Fire Protection Program, Section 8.2.3 aires 11y one annual, unannounced fire brigade drill per year and

.our tra ng evolutions in conjunction with the fire brigade retraining essions for each shift brigade. The procedure does not require drills to be performed at regular intervals with the interval between drills not to exceed three months for each shift brigade.

002809 HL-2009 E-1  !

i l

I ENCLO5URE (Continued)

VIOLATION 91-30-01 AND GPC RESfQldi

2. Inst Procedure 42SV-fPX-037-05, fire Detection Instr N ntation Surveillance, requires only one operationai test of one detector per

-:one per year. Many of the fire detector tones for safety related

.,eas contain mor9 than 10 detectors. Each smoke detector is not visually checked semiannually and is not operationaily tested annually.

This is a Severity Level IV Violation (Supplement 1).

REE QlGJ TO VIOLATION 91-30-01 Admission of_ denial of the violatjno: i The events occurred as described in the Notice of Violation.

R, anon for the viohltan:

Exampic 1 of the violation was caused by personnel error. The writers and technical reviewers of procedures 40AC-ENG-008-0f,, " Fire Protection Program,' and 73TR-TRN-003-OS, " Fire Training Program," failed to ensure the pro:edures met the requirements of Attachment 2 to

• Nuclear Plant fire  !

Protection Responsibilities. Administrative Controls and Quality Assurance."

Example 2 of the violation was caused by personnel error. Plant Engineering personnel furnished inccrrect i. Snical information in the

, request for changes to the firr detecto" /veillance requirements in section 2.2.2 of Appendix B to the fire Wazards Analysis (FHA), Plant Nuclear Safety and Compliance personnel inadvertently incorporated the incorrect information into the applicable safety evaluation. The proposed changes were subsequently approved and incorporated into the FHA.

Corrective stens which have been taken.gDd the resulLS achieved:

Plant procedure 00AC-REG-003-05 " Licensing Document Revision and Clarification Program," has been revised to require that all changes to the FHA be reviewed for technical accuracy by Plant Hatch's architect / engineer priot to initiation of the site approval process.

Corrective steos which will be taken to avoid further violations:

The writers and technical reviewers of procedures 40AC-ENG-008-05 and 73TR-TRN-003-0S will be counseled regarding their errors and the consequences thereof. This- action has been completed. The personnel responsible for the incorrect safety evaluation for the fire detector surveillance changes no longer work for GPC; therefore, they cannot be counseled.

002809 HL-2009 E-2

ENCE050RE (Continued)

Procedures YlDIAILOL9h19:1LRitLDfl.BUE0!1H to once require that firedrills 40**-ENG-008-OS and 731R-1RN-003 05 "Nuclearevery 3 months and 2) for each brigade will be revised by 2/28 Plant fire 1) and Quality Assurance.Protectioncover

" the items sp:ecified stinbe performed at l during the second quarter of 1992 Performance ofResponsibilities, rols A

the new drills will lhe fire detectors listed in be initiated inspected by 2/20 Appendix B Smoi ,.

aerosol acceptable /92. to the IHA will to the - detectors will be Section

cturer by $/1/92. tested using smokebe visually smoke 2.2.2 of Appendix or an B to tne j smoke ondetectors be visuO ly insp(cted onceFitA will be 7/31/92. an aerosol once every 12 months. revised to require that Procedure will The revision will be in place byev 42SV-fPX-037-OS be revised to comply,with the" fire Detection The revision will be effective /92.

by 7/31FHA revised surveillance requiremen PLLt_whta_htl_1__tETA111!1t93111Ja Athjivid:

Examt.'e

' 1 - Full 40AC-ENG-008-OScompliance will be requirements for drill frequency Example n ent.

and co tand 73TR TRN-003 05 are r when procedures accurately reflect the 2 - full compliance will fire detector surveillances are com lbe achieved by 5/1/92 when p eted.

the required

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