ML19312E997
| ML19312E997 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 05/27/1980 |
| From: | Widner W GEORGIA POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19312E993 | List: |
| References | |
| NUDOCS 8006180323 | |
| Download: ML19312E997 (4) | |
Text
Georg a Power Company 230 P(ach*ree Street g
Post O'$ce Bo= 4545 e
n At ava Ger/a a 30302 I
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A May 27, 1980 b
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U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement
REFERENCE:
Region II - Suite 3100 RII: HCD 101 Marietta Street, NW 50-321/80-11 Atlanta, Georgia 30303 50-366/80-11 ATTENTION:
Mr. James P. O'Reilly Gentlemen:
The inspection conducted by Mr. R. F. Rogers of the U. S. Nuclear Regulatory Commission's Region II Office of Inspection and Enforcement on j
February 2 through rarch 7, 1980, resulted in the determination that certain activities under our license appeared to be in noncompliance with NRC re-quirements. Your letter of April 29, 1980, which was received by Georgia Power on May 7, 1980, cited those violations and requeated that each be addressed by Georgia Power Company explaining the corrietive action taken or planned. Submitted herein is that response.
INFRACTION A.
As required by Technical Specification 3.3.3.7.a.2.b), a control rod which is bypassed in the rod sequence control system is required to be moved to the correct position in the proper se-quence in order to continue reactor operation.
Technical Speci-fication 6.8 requires that written procedures shall be established and implemented. Hatch nuclear plant procedure HNP-2-9207, Rod Movement Sequences, requires that control rods be moved in the proper sequence.
Contrary to the above, during a reactor startup commencing on January 28, 1980, the reactor was taken to power with control rod 46-43 left fully inserted and bypassed in the rod sequence control system rather than fully withdrawn and control rod 10-47 left at Notch 12 rather than fully withdrawn due to personnel errors.
B.
As required by Technical Specification 3.1.3.7.a.2, control rods may be bypassed in the rod sequence control system if the control rod reed switch full-in and/or full-out position indicators are inoperable.
Contrary to the above, on January 28, 1980, control rods 46-43 and 14-43 were bypassed full out with operable reed switch position indicators to facilitate rod selection during a reactor startup.
Also on January 29, 1980, all Group A 3/4 rods bypassed with operable reed switch position indicators to restore mispositioned control rod 46-43 to its proper position in order to continue a plant startup.
GeorgiaPbwerd U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement May 27, 1980 Page Two
RESPONSE
Twice during the incident the RSCS bypass switches were improperly used as explained in Appendix A, Items A and B of the above report (366/80-011-01,02). Procedures HNP-1 and 2-9207, Control Rod Movement, have been revised to include critiera on the use of the switches based on Tech Specs requirements.
The change includes a data sheet to be completed when using the switches to ensure the -
above criteria are met.
INFhACTION C.
As required by Technical Specification 6.9.1.8.f, 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 accidents analyzed in the SAR 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 director of the regional office.
Contrary to the above, on January 29, 1980, the existence of an out of sequence rod pattern involving two control rods at approxi-mately 10% power which neither the rod worth minimizer, the rod sequence control system, procedural controls, nor operator alertness prevented, was not reported by the licensee.
The above two safety systems impose restrictions on rod pattenis to mitigate a rod drop accident.
RESPONSE
Appendix A, Item C of the report discusses the failure to report the incident as required by Tech Specs 6.9.1.8.f (366/80-011-03).
It is the review board's contention that the present organization is adequate and that this oversight was an isolated event. No further action is planned.
INFRACTION D.
As required by Technical Specification 3.1.4.2.b, once control rod withdrawal has started and thermal power is less than 20% of rated power, control rod movement is not permitted except by scram with the rod sequence control system (RSCS) inoperable.
Contrary to the above, on Janaury 29, 1980, after an out of sequence situation was discovered at approximately 10% power, the licensee bypassed all Group A 3/4 rods full-in making that portion of the RSCS system inoperable in order to withdraw a Group 2 rod which had been erroneously.left inserted. Also on January 29, 1980, a reactor startup continued from Group 5 to Group 7 control rods while it was known to the operator that the group notch control mode of RSCS was inoperative. 7 e
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GeorgiaPbwerd U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement
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May 27, 1980 Page Three E.
As required by Technical Specification 6.8.2, changes to plant procedures shall be reviewed by the Plant Review Board (PRB) and approved by the plant manager prior to implementation. Technial Specification 6.8.3 allows temporary changes to procedures provided the intent of the original procedures is not altered, the change is documented, reviewed by the PRB and approved by the plant manager within 14 days.
Contrary to the above, on Janaury 29, 1980, the licensee restored two out of sequence rod; to their required positions while at 10%
power which changed the intent of HNP-2-9207, Rod Movement Sequences, which requres rod withdrawal in a predetemined, consecutive order.
This change was not documented as a temporary change or a change requiring prior approval.
RESPONSEi
.I As explained in Appendix A, Items D and E of the report, once the M
withdrawal error was discovered, improper corrective actions were taken in moving the rods to their target postion (3667/80-011-04,05). HNP-1 and 2-9207 have been revised to specify the corrective action to be taken in the event an error is discovered in the future. Depending on the situation, the new section delineates the proper actions to be taken to comply with Tech Specs and precidde the possiblility of an unreviewed safety question.
INFRACTION F.
As requited by Criterion VI of Appendix B to 10 CFR 50 and as l
describedJln the Final Safety Analysis Report, Section 17.2.6.3, measures shall be established to control the issuance of drawings changes which assure that ;hese changes are distributed to and f
used at the location where the prescribed activity is performed.
Contrary to the above, on March 4, 1980, during a spot check of Unit 2 drawings maintained in the control room, 16 of 30 drawings checked were not the current revision and were routinely being used in the conduct of plant operations.
RESPONSE
The large size drawings described in Appendix A, Item F have 'aeen removed from the control room (366/80-011-06). They have been replaced with " controlled" microfilmed prints. These prints are controlled under procedures BNP-O-10, Document Distribution and U
/f Control, and BNP-0-813, Drawing Control.
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U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement May 27, 1980 c,
Page Four If further clarification or information is required, please contact this office.
Very truly yours, i
.h W. A. Widner Vice President and General Manager Nuclear Generation DLT/mb I
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