ML19263E624

Responds to NRC 790306 Ltr Re Violations Noted in IE Insp Repts 50-321/79-08 & 50-366/79-10.Corrective Actions:New Policy Re Definition of Operability Has Been Established & Test Results Will Be Reported

ML19263E624
Person / Time
Site:	Hatch
Issue date:	04/10/1979
From:	Staffa R GEORGIA POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19263E622	List: ML19263E624 ML19263E626
References
NUDOCS 7906200527
Download: ML19263E624 (2)

Text

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Georg.a Power Company

. 230 Namtree St ect Pcat Ove Bow 4545 Atura Gev gia r 30103 Telepn wm 404 522 f(s00 Power Supply Engineering and Services gg 3 g ,g-April 10, 1979 , , , , ,,,

United States Nuclear Regulatory Commission Office of Inspection and Enforcement

REFERENCE:

Region II - Suite 3100 RII: RFR, III 101 Marietta Street 50-321/79-8 Atlanta, Georgia 30303 50-366/79-10 ATTENTION: Mr. James P. O'Reilly Gentlemen:

The following information is submitted in response to your letter dated March 6, 1979, containing inspection report 50-321/79-8 and 50-366/79-10.

50-366/79-10 (Infraction)_

This infraction resulted from failure to report that both HPCI (lligh Pressure Coolant Injection) and RCIC (Reactor Core Isolation Cooling) systems were apparently inoperable at the same time. Although such reporting is required by Section 6.9.1.9.c of the Tech Specs, the plant staff did not con-sider HPCI to be inoperable at the times indicated by the NRC inspector. HPCI was tested in accordance with Section 4.5.1.a and b of Tech Specs by a manual start and full flow test, but this application of operability was disputed by the inspector.

Previous practice has been to perform a manual rated flow and/or valve operability test following maintenance. This practice appeared to conform to the operability requirements, but these requirements may not be clearly defined particularly with regard to HPCI and RCIC. Tech Specs Section 4.5.1 does not '

require an automatic initiation, whereas paragraph 1.20 " Operable-Operability" '-

implies that an automatic initiation nay be required. This difference is not significant for other pumps because the pump response is the same for both manual and automatic starting; however, HPCL and RCIC may have different responses to manual and automatic starting.

Georgia Power Company management has evaluated the question of what consti-tutes operability and has developed the following position. An operable compo-nent does not require the performance of an au".omatic start; however, should a faica occur in response time, overspeed trip, or control system problems which could affect the ability of the pump to automatically function, an automatic initiation test (without injection into the vessel) in addition to other testing, as appropriate, would be performed to prove operability. This policy would also be extended to any modification or routine maintenance which could affect the ability of the pump to automatically function. An important distinction is that the electrical logic, which is tested by a logic system functional test, would not be included in the automatic initiation because it cannot affect pump response after the start signal has been received.

- 2287 037 f ob .20 0 5 2l 790 ISO .

gewroon

Georgia Power d U. S. Nuclear Regulatory Commission ATTN: Mr. James P. O'Reilly Page Two April 10, 1979 Procedureo fer automatae start testing of HPCI and RCIC as required will be completed no later than May 15, 1979, and appropriate reporting will be made of the aforementioned event no later than May 1, 1979.

50-366/79-10-02 The failure to report the exceeding of the Level 1 acceptance criteria far recirculation flow coastdown following a turbine trip at seventy-five per-cent power was caused primarily by the nuclear steatr. supply manufacturer having advised the plant staff that the actual observed values tould be acceptable.

General Electric Company was advised of the circumstances and iscued permission, both verbally and in writing, to ascend in power and continue testing. Plant management reviewed the justification and the d xision was made to proceed to the next power level. General Electric later notified Georgia Power that their justification had been in error and the plant was lowered to the fifty percent power level. This was determined to have been an administrative error and will be appropriately reported no later than May 1, 1979.

This report contains no information which is considered to be proprietary.

Very truly yours,

/ & w-R. W.. aff Manaf , Quality Assurance DRS/bg 2287 038 MO620_0-rq