HL-5374, Responds to NRC Re Violations Noted in Insp Rept 50-321/96-15.Corrective Actions:Involved Personnel Were Counseled Re Errors & Procedure Enhanced

Responds to NRC Re Violations Noted in Insp Rept 50-321/96-15.Corrective Actions:Involved Personnel Were Counseled Re Errors & Procedure Enhanced

ML20138F921
Person / Time
Site:	Hatch
Issue date:	04/25/1997
From:	Sumner H SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-321-96-15, HL-5374, NUDOCS 9705060094
Download: ML20138F921 (4)

Text

• Lewis Sumner Southern Nuclear

,, ,s. Vice President Operating Company,Inc.

Hatch Project Support 40 Invemess Parkway

. Post Office Box 1295 Birmingham. Alabama 35201 Tel 205 992.7279 Fax 205.992.0341 SOUTHERN COMPANY Energy to Serve Your World" April 25,1997 Docket No. 50-321 HL-5374 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Edwin I. Hatch Nuclear Plant ' Unit 1 Reviv to a Notice of Violation Gentlemen:  ;

1 In response to your letter dated April 3,1997, and according to the requirements of l 10 CFR 2.201, Southern Nuclear Operating Company (SNC) is providing the enclosed revised response to Notice of Violation 96-15-02 associated with Inspection Report 96-15. In the enclosure, a transcription of the NRC violation precedes SNC's  !

response. I Should you have any questions in this regard, please contact this office.

Sincerely, ,

~.

\ $d4V) sW H. L. Sumner, Jr.

OCV/eb

Enclosure:

Violation 96-15-02 and Revised SNC Response cc: (See next page.)  ;)

9705060094 970425 PDR ADOCK 05000321 G PDR OUO- , , ,,

4 i U. S. Nuclear Regulatory Commission Page 2 April 25,1997 cc: Southern Nuclear Overating Company

Mr. P. H. Wells, Nuclear Plant General Manager NORMS U. S Nuclear Revidatory Commission. Washington. D. C.

Mr. K. Jabbour, Licensing Project Manager - Hatch U. S Nuclear Revulatory Commission. Reelon H

Mr. L. A. Reyes, Regional Administrator Mr. B. L. Holbrook, Senior Resident Inspector - Hatch

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11L-5374

Enclosure Edwin I. Hatch Nuclear Plant Violation 96-15-02 and Revised SNC Resnonse VIOLATION 96-15-02 Hatch Technical Specification 5.4 requires that written procedures be established, implemented, and maintained covering activities delineated in appendix A of Regulatory Guide (RG) 1.33, Revision 2, February 1978.

RG 1.33, Appendix A: Typical Procedures for Pressurized Water Reactors and Boiling Water Reactors, paragraph 1.d, recommends procedures for Procedure Adherence.

Procedure 10AC-MGR-019-OS, Procedure Use and Adherence, Revision 0, Step 8.1, states, in part, that the user must review the procedure prior to use, follow steps in sequence unless otherwise allowed, and complete documentation as required.

Procedure SIGM-MNT-034-0S, MOV Electrical Backseating With Instantaneous Circuit Breaker Trip Protection, Revision 2, step 4.3.2, stated, in part, that prior to performing backseating, the Shift Supervisor on duty will review the engineering evaluation for the impact on stroke time requirements and will indicate the results of the review in the work '

performed section of the Maintenance Work Order. Step 4.3.5 states, in part, that a Maintenance Work Order must be initiated for internal inspection on the valve to be backseated.

Contrary to the above, written procedures were not implemented in that:

On December 27,1996, during the performance of procedure 51GM-MNT-034-0S for electrically backseating a Reactor Core Isolation Cooling Inboard Steam Isolation valve, 1E51-F007, a review of the engineering evaluation for impact on stroke time requirements was not documented in the work performed section of a Maintenance Work Order, as required by Step 4.3.2 of the procedure. Also, a Maintenance Work Order was not initiated and documented for an internal valve inspection on the backseated valve, as required by step 4.3.5 of the procedure.

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

HL-5374 E-1

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• Enclosure ,

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Violation 96-15-02 and Revised SNC Response l l

REVISED RESPONSE TO VIOLATION 96-15-02 l l I Reason for the violation: i j

I This violation was caused by personnel error. Maintenance personnel responsible for i valve backseating activities exercised poorjudgment in not obtaining the Shift  :

3 Supervisor's signature in the work performed section of the Maintenance Work Order. l l Personnel felt that, since valve stroking from the backseat would be performed by Operations personnel and the stroke-time documented on the normal Operations l

surveillance procedure, the information required by procedure 51GM-MNT-034-0S,  !

"MOV Electrical Backseating With Instantaneous Circuit Breaker Trip Protection," did  ;

not need to be recorded on the Maintenance Work Order. ,

4 Maintenance personnel also exercised poorjudgment in failing to initiate another Maintenance Work Order to inspect the valve internals as required by procedure 51GM-MNT-034-0S. They chose instead to add instructions to the existing Maintenance Work j

Order to repack the valve, inspect the valve actuator, and perform motor operated valve actuator testing following valve removal from the backseat. These instructions were intended to obtain information from which the system engineer or the MOV Coordinator  :

l could determine whether an internal inspection was needed. Although these actions were {

acceptable from an engineering standpoint, they were not in compliance with the  !

requirements of the procedure. Involved personnel failed to revise the procedure to allow the actions they took.

Corrective steps which have been taken and the results achieved:

The involved personnel were counseled regarding their errors. I I

Procedure 51GM-MNT-034-0S was enhanced to include an additional step in Section 7.0 and sign-offin the procedure attachment to ensure the requirement contained in step 4.3.2 is identified as a work activity which must be completed when a valve is backseated. The g

requirements of step 4.3.5 also were changed. This revision was effective 2/21/97.

Corrective steps which will be taken to avoid further violations:

No additional corrective actions to avoid further violations are necessary at this time.

Date when full compliance will be achieved:

Plant Hatch presently is in full compliance with the requirements of procedure 51GM-MNT-034-0S.

- HL-5374 E-2