IR 05000321/1980011
| ML19312F005 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 04/15/1980 |
| From: | Dance H, Rogers R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19312E993 | List: |
| References | |
| 50-321-80-11, 50-366-80-11, NUDOCS 8006180338 | |
| Download: ML19312F005 (9) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION g
a REGION il
o 101 MARIETTA ST N.W., SUITE 3100
o ATLANTA, GEORGIA 30303
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Report Nos. 50-321/80-11 and 50-366/80-11 Licensee: Georgia Power Company 270 Peachtree Street, N.W.
Atlanta, GA 30303 Facility Name: Hatch I and 2 Docket Nos. 50-321 and 50-366 License Nos. DPR-57 and NPF-5 Inspection at P1 nt Hatch, Units I and 2 Inspector:
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/J 8t R.' F. yogers
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Approved by:
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H.' C. Dance, Section Chief, RONS Branch fate signed SUMMARY Inspection on February 2 - March 7, 1980 Areas Inspected This inspection involved 112 in :pector-hours onsite in the areas of technical specification compliance, reportable occurrences, housekeeping, operator perfor-mance, overall plant operations, quality assurance practices, station and cor-porate management practices, corrective and preventative maintenance activities, j
site security procedures, radiation control activities and surveillance activities.
Results Of the eleven areas inspected, no apparent items of noncompliance or deviations were identified in six areas; six items of noncompliance were found in five
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areas (Infraction -failure to follow procedure, paragraph 9; Infraction - Failure to operate the RSCS properly, paragraph 10; Infraction - Failure to make immediate
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notification to the NRC, paragraph 11; Infraction - Failure to limit rod motion with RSCS inoperable, paragraph 12; Infraction - Failure to evaluate procedure change, paragraph 13; Infraction - Failure to provide updated plant drawings in the control room, paragraph 14).
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DETAILS 1.
Persons Contacted Licensee Employees
- M. Manry, Plant Manager
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- T. Moore, Assistant Plant Manager
- T. Greene, Assistant Plant Manager S. Baxley, Superintendent of Operations R. Nix, Superintendent of Maintenance C. Coggins, Superintendent of Engineering Services W. Rogers, Health Physicist / Radiochemist C. Bellflower, QA Site Supervisor Other licensee employees contacted included technicians, operators, mechanics, security force members, and office personnel.
- Attended exit interview.
2.
Exit Interview The inspection scope and findings were summarized on February 22, and March 7, 1980, with those persons indicated in Paragraph I above. These findin discussed again on April 2,1980 (See Inspection Report 50-366/80-18)gs were
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3.
Licensee Action on Previous Inspection Findings Not inspected.
4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
Plant Operations Review (Units 1 and 2)
The inspector periodically during the inspection interval reviewed shift logs and operations records, including data sheets, instrument traces, and records of equipment malfunctions. This review included control room logs, auxiliary logs, operating orders, standing orders, jumper logs and equipment tagout records. The inspector routinely observed operator alertness and demeanor during plant tours. During abnormal events, operator performance and response actions were observed and evaluated. The inspector conducted random off-bours inspections during the reporting interval to assure that operations and security remained at an acceptable level. Shift turnovers
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were observed to verify that they were conducted in accordance with approved licensee procedures.
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6.
Plant Tours (Units 1 and 2)
The inspector conducted plant tours periodically during the inspection interval to verify that monitoring equipment wt re. ording as required,
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equipment was properly tagged, operations perse iel were aware of plant conditions, and plant housekeeping efforts were lequate. The inspector also detere:ined that appropriate radiation contr 1s were properly er. tab-
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lished, critical clean areas were being controlled in accordance with procedures, excess equipment or material is stored properly and combustible material and debris were disposed of expeditiously.
During tours the inspector looked for the existence of unusual fluid leaks, piping vibrations, pipe hanger and seismic restraint settings, various valve and breaker positions, equipment caution and danger tags and component positions, adequacy of fire fighting equipment, and instrument calbration dates. Some tours were conducted on backshifts and weekends.
7.
Technical Specification Compliance (Units 1 and 2)
During this reporting interval, the inspector verified compliance with selected limiting conditions for operation (LCO's) and results of selected surveillance tests. These verifications were accomplished by direct obser-vation of monitoring instrumentation, valve positions, switch positions, and review of completed logs and records. The licensee's compliance with selected LCO action statements were reviewed on selected occurrences as they happened.
8.
Physical Protection (Units 1 and 2)
The inspector verified by obserm tion and interview during the reporting interval that measures taken
'a assure the physical protection of the facility met current requiremerb Areas inspected included the organization of the security force, the establishment and maintenance of gates, doors and isolation zones in the proper condition, that access control and badging was proper, that search practices were appropriate, and that escorting and communications procedures were followed.
9.
Control Rod Insert Errors (Unit 2)
During a reactor startup on January 28 and 29, 1980, rod 46-43 (Group 2)
and rod 10-47 (Group 3D) were left at positions 00 and 12 respectively, rather than fully withdrawn as required. The inspector's investigation of this occurrence also determined that the safety systems designed to indicate and prevent an out-of-sequence rod pattern had either been ignored or erroneously bypassed by the licensee. Hatch Nuclear Plant Procedure HNP-2-9207, Rod Movement Sequences, requires that control rods be moved in the proper sequence and appropriately documented. The procedure gives the actual pull sequence required for the operator. Upon examination of HNP-2-9207, the inspector noted that the sign-off for rod 46-43 had been left blank and that for rod 10-47 had been signed off as being withdrawn to notch 48 (fully withdrawn) but had not.
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The rod worth minimizer (RkM) is a computer monitoring system which serves to backup procedural controls to limit control rod worth during startup and low power operations. If during these plant conditions, a rod drop accident (RDA) were to occur, the limited reactivity addition rate, due to the sequence supervised by the Rkh, lessens the extent of the fuel damage that
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might occur. During the startup in question, both out of sequence rods were displayed on the rod worth minimizer panel (located above the rod
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control switches) as " insert errors" when they occurred, but this indication was virtually ignored by control room operators on two shifts (approximately a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval).
The rod sequence control system (RSCS) is a hardwired system which is redundant to and backs up the Rhh in imposing restrictions on control rod i
movements to reduce the consequence of a rod drop accident. During this incident, rod 46-43 had been erroneously bypassed by the licensee. This action rendered the RSCS supervision of that rod inoperable and contributed to the severity of the occurrence.
In summary, the failure of procedural controls, operator inattention to the Rkt and the erroneous bypassing of the RSCS all led to the out of sequence condition which could have been prevented by any one of these mechanisms.
This is an item of noncompliance (366/80-11-01).
10.
Rod Sequence Control System Operation (Unit 2)
During a reactor startup on January 28, 1980, rods 46-43 and 14-43 were by-passed full out with operable reed switches to facilitate rod selection in the rod manual control system. Both are Group 2 rods, rod 46-43 was mis-takenly left inserted and rod 14-43 was fully withdrawn. Plant operators bypassed these rods tc. facilitate selection of Group 3 rods to continue a startup. Technical specification 3.1.3.7.a.2 allows bypass of rods only if the reed switch is inoperable (which it was not), the control rod position is known (which it was not - rod 46-43 was full in not out) and the rods are moved in the proper sequence (rod 46-43 was not). It was subsequently determined that the inability of the operator to select a Group 3 rod was because rod 46-43 was not properly pulled out and the RSCS system was trying to enforce the proper sequence. Operator bypassing of this safety system removed this restraint.
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During the restoration of the two out of sequence rods on January 29, 1980,
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cperators again bypassed the RSCS system contrary to technical specification
] imitations. In order to restore Group 2 rod 46-43 to the withdrawn position, all Groups 3 and 4 rods in il.e "A" sequence had to be bypassed full in to be able to select that rod. These occurrences constitute an item of noncom-pliance (366/80-11-02).
11.
Failure to Submit an Immediate Report (Unit 2)
Technical Specification 6.9.1.8.f requires that any personnel error or procedural inadequacy which prevents or could prevent, by itself, the fulfillment of the functional requirements of systems required to cope with
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accidents analyzed in the safety analysis report is required to be reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the NRC. On January 29, 1980, the licensee was aware of an out of sequence rod pattern involving two control rods, 46-43 and 10-47, at approximately 10% power.
In order to reach this condition, a multiple breakdown of procedural controls, lack of attention to rod worth minimizer indications and the rod sequence control system erroneous bypassing occurred.
Restrictions and controls on rod sequencing are required to mitigate the consequences of a Rod Drop Accident (RDA) and an "in-sequence" condition is in fact assumed as an initial condition in the FSAR description of the accident. Although the RWM did not " block" rod motion in this instance, it is significant that these two rods were displayed to the operator as " insert
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errors" and ignored (it takes three " insert errors" to block the RWM).
Failure to report this incident within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> constitutes an item of noncompliance (366/80-11-03).
12.
Rod Motion with RSCS Inoperable (Unit 2)
Technical Specification 3.1.4.2.b requires that once control rod withdrawal has commenced and thermal power is less than 20%, control rod movement is not allowed except by scram with the Rod Sequence Control System inoperable.
On two occasions, the licensee withdrew rods to facilitate a plant startup with the RSCS system inoperable. On January 29, 1980, when the licensee discovered that a Group 2 rod was left fully inserted, RSCS rods in Groups 3 and 4 were bypassed full-in (RSCS inoperable) in order to be able to pull the Group 2 rod fully out. Also on that date, when the operator entered Group 5 in the pull sequence, it was apparent that something was wrong with the RSCS group notch control mode. The operator continued to pull to Group 7 rods before declaring RSCS inoperable and limiting further rod motion in accordance with technical specification requirements. These two occurrences constitute an item of noncompliance (366/80-11-04).
13.
Failure to Properly Review a Procedure Change (Unit 2)
Technical specifications 6.8.2 and 6.8.3 describe the levels of review and approval required to change plant procedures once approved by the Plant Review Board (PRB). The licensee's decision to restore two out of sequence rods at 10% power changed the intent of HNP-2-9207, Rod Movement Sequences, which requires a consecutive withdrawal sequence. The change should have had prior PRB approval to assure that an unreviewed safety question as defined by 10 CFR 50.59 did not exist.
The inspector in concert with licensee and regional core physics engineers subsequently determined that an unreviewed safety question had, in fact, i
not occurred. The licensee's failure to adequately review this procedure change is an item of noncompliance (366/80-11-05).
14. Updated Drawings (P& ids) in the Control Room (Unit 2)
The inspector randomly audited the revision status of approximately 30 unit 2 P& ids. The sixteen drawings listed below were at least one revision out
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of date. These drawings were in routine daily use in the control room to perform system tagging evolutions, troubleshoot plant problems and other related activities.
Actual Correct Revision Drawing No.
Revision In Use H-21023
7 H-21026
10 H-26001
8 H-26011
4 H-26015
6 H-26017
4 H-26026
10 H-26028
5 H-26029
5 H-26030
10 H-26031
13 H-26032
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H-26035
6 H-26045
12 H-26046
9 H-26047
10 Criterion VI of Appendix B to 10 CFR 50 requires that measures be implemented that assure that corrected drawings are used at the proper locations.
The licensee's program to assure that out of date drawings are not in use through strict drawing issuance and accountability requires improvement.
This is an item of noncompliance (366/80-11-06).
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