ML19318A490
| ML19318A490 | |
| 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 | |
| ML19318A484 | List: |
| References | |
| NUDOCS 8006230218 | |
| Download: ML19318A490 (2) | |
Text
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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 50-321/80-18 Atlanta, Georgia 30303 50-366/80-18 ATTENTION:
Mr. James P. O'Reilly Gentlemen:
The inspection conducted by Mr. H. C. Dance of the U. S. Nuclear Regulatory Commission's Region II office of Inspection and Enforcement on March 31 to April 2,1980, resulted in the determination that certain activities under our license appeared to be in noncompliance with NRC requirements. Your letter of April 30, 1980, and received by Georgia Power Company May 6, 1989, cited a violation and requested that it be addressed by Georgia Power Company describing the corrective action taken or planned.
Submitted herein is that response.
INFRACTION As required by Technical Specification 6.8.1, written procedures are required to be established and implemented covering test activities of safety-related equipment. Plant procedure HNP-809, Plant Modification, states that functional tests which are more than simple tests which can be described on the Maintenance Request must be provided a written and approved functional test procedure.
Contrary to the above, the functional test performed on January 16, 1980, was not timely nor adequate to determine that a modification involving the Rod Sequence Control System (RSCS) and completed on December 2, 1979, during power operation, had defeated the RSCS notch control mode of operation.
Th RSCS was subsequently found inoperable by the licensee on January 27, 1980.
RESPONSE
The designated functional test for DCR 79-342 and Maintenance Request 2-79-4099 would have been sufficient had it been performed within the region of RSCS operability (i.e., below 30% reactor power) as was intended. A written and approved functional test was not necessary or applicable in this instance in that operability could have been positively demonstrated through performance of existing plant procedures for RSCS operability (i.e., HNP-2-1001, NORMAL STARTUP, or HN"-2-1020, NORMAL REACTOR SHUTDOWN).
OFFICIAL COPY 8 00623 0 2.W 4
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GeorgiaPower d U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement May 27, 1980 Page Two RESPONSE (Continued)
The designated functional test could have been enhanced or further clarified had it specified the exact plant conditions required for testing and the plant procedure to be utilized.
In this regard, designated Maintenance Request functional tests for Design Change Requests (DCR's) implementation are now being reviewed for adequacy by a knowledgeable and responsible engineering supervisor, and by the plant Quality Control Department.
With regard to the timeliness of the functional test, it was intended that RSCS operability be demonstrated during the first controlled shutdown, startup, or reactor maneuver in the region of RSCS opera-bility; i.e.,
the first time RSCS would have been required to be operable. Failure to perform the functional test the first opportunity can also be attributed to lack of specificity on the Maintenance Request.
We believe that with review for adequacy and timeliness by an engineering supervisor and by quality control we are in full compliance with the Technical Specification requirements for adequacy and timeliness of test activities on safety-related equipment.
i If you desire additional clarification or information, please contact this office.
Very truly yours, kM. WL
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W. A. Widner Vice President and General Manager
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