ML19321A837

Responds to NRC 800519 Ltr Re Violations Noted in IE Insp Repts 50-321/80-17 & 50-366/80-17.Corrective Actions:New Airlock Scheme Installed.Actions Re Event & Deviation Reportability Justified

ML19321A837
Person / Time
Site:	Hatch
Issue date:	06/12/1980
From:	Widner W GEORGIA POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19321A829	List: ML19321A837
References
NUDOCS 8007240264
Download: ML19321A837 (4)

Text

_ _

l a m an:...cevey

.. ye eerwe su.a v . vw w .: en. wg A' a ?l: fy 3 a '40 ft2 Tggr, q j t. 67' fj,3 A

June 12, 1980 g U W. A. WWner #

e1;  ;. Georgia Power YD aN5? ~ """ emm em +

U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement

REFERENCE:

Region II - Suite 3100 RII: RFR III 101 Marietta Street, NW 50-321/80-17 Atlanta, Georgia 30303 50-366/80-17 ATTENTION: Mr. James P. O'Reilly Gentlemen:

This refers to the Notice of Violation based on the NRC inspection of March 8 through April 11, 1980, of the activities authorized by NRC license Nos. DPR-57 and NPF-5 for the Hatch facility. Following is a description of the items of violation and Georgia Power Company's response to each.

INFRACTION 1

A. As required by Technical Specification 3.7.C.1, the integrity of l the secondary containment shall be maintained. 10 CFR 50, Appendix l B, Criterion XVI, implemented by Hatch Quality Assurance Manual, l Section 16, paragraph 16.1, states in part that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected, and in any case of significant co'nditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.

Contrary to the above, secondary containment integrity has been

ompromised sixteen times in the past year as reported in Licensee tventReport(LER) 50-321/80-28. The failure to correct this long-term problem constitutes ineffective corrective action and was the subject of an identical citation in NRC Report 50-321/79-11 and 50-366/79-15 dated May 18, 1979.

RESPONSE

During normal personnel movements into and out of the Reactor Buildings vit airlocks, simultaneous openings of both airlock doors have occurred. This situation is more in evidence d:tring outages when many visitors and new contract personnel re :ssigned to the site. Steps taken to prevent simultaneous openings of airlock doors, i.e. , annunciated doors, indication lights, interlocks, and administrative enforcement actions have not produced desired results.

Di4'FINI

1 Y Georgia Power A U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 3100 .

June 12, 1980 Page Two .

To prevent violations of secondary containment as defined in Tech Specs and the FSAR, Georgia Power is installing a new airlock inter-lock scheme which should eliminate simultaneous opening of the airlock doors.

Following a previously submitted schedule, Georgia Power still expects to complete the present modifications by 10-1-80, at which time full compliance is expected.

Georgia Power may consider another criteria for determining violation of secondary containment. The bases for such criterion would be the effect on the negative pressure maintained in reactor buildings. The vast majority of the violations are of such duration (a matter of 1 or 2 seconds) that the integrity of secondary containment is not affected. Georgia Fcwer will therefore pursue not only the completion of the new airlock interlock scheme and the enforcement of present methods to prevent simultaneous opening of airlock doors, but may also pursue de changing of the Tech Specs as applicable to airlock doors.

INFRACTION B. As required by Technical Specification 6.9.1.8.1, performance of systems that require remedial action or corrective measures to prevent operation in a manner less conservative than assumed in the accident analyses shall be reported to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Technical Specification 6.9.1.9.b requires that conditions leading to operation in a degraded mode permitted by a limiting condition for operation be reported within 30 days.

Contrary to the above:

A report was not m' e i thin 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the seismic design 1.

deficiency disc.v5 red o, *he U lt 2 residual heat removal system which required co rectf.s action to assure that a portion of the system would not M1 'en subjected to a design seismic event. This event was oc..nented in LER No. 50-366/80-12.

2. A report was not made to the NRC within 30 days of the failure of the Unit 1 "lC" diesel generator manual voltage regulator on February 26, 1980. This was documented in plant deviation report No. 1-80-101.

3. A report was not made to the NRC within 30 days of the failure of the Unit I standby PSW Pump during surveillance (HNP-1-3801) performed on January 30, 1980, which was documented in plant deviation Report No.1-80-56.

1 Georgia Power A U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement -

Region II - Suite 3100 June 12, 1980 Page Three

RESPONSE

The report cites 3 examples which the inspector felt that the licensee failed to report properly. While the categories listed in sections 6.9.1.8 and 6.9.1.9 have descriptions to guide the licensee as to how to report an item (i.e., promptly or 30-day), the classi-fication assigned to a reportable item is, in the end, the decision of the licensee. In the instances cited in the report, the inspector and the licensee have differing opinions. In defense of the decisions on reportability, the following brief explanations are given.

LER(50-366/80-02) Lack of seismically qualified RHRSW and PSW minimum flow piping supports.

This event was classed as a 30-day report based on conversations with the architect engineer. While these supports would fail, it was detennined that the failure would not propagate to the main dis-charge piping. In light of these facts it was felt that safe shutdown of the plant would not be impaired as these pumps would

! continue to function. Hence, it was the opinion of the PRB to report under the 30-day classification. Subsequent to this initial finding an analysis by the A/E, assuming the piping was not full of water (usual condition for this piping), revealed that the supports would not fail as originally reported.

LER(50-321/80-24) Failure of "C" Diesel Generator Voltage Regulator in the Manual Mode  ;

The event that occurred on the "C" D/G was deemed to be not reportable ,

since the surveillance required (HNP-1-3801-0 D/G Manual Start, Data '

~

Sheet 1) was successfully completed. Troubleshooting of the regulator by the maintenance shop revecled no failed components. The regulator performed satisfactorily thrNghout the procedure. A LOCA or LOSP will automatically place the regulator in the auto mode. The manual regulator components were considered of no consequence for normai standby operation. When the manual regulator prevented completion ,

of the procedure on 2-29-80, reporting was in order. Theref e, in I the opinion of the PRB the D/G was demonstrated to be operable by plant procedures, and no reporting was required.

Deviation Report 1-80-56 Failure of Standby PSW Pump During HNP 3801 ,

When HNP-1-3801 was performed on 1-30-80, there was confusion on the part of personnel performing the procedure as to the relationship 1

i Georgia Pbwer1 U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement .

Region II - Suite 3100 June 12,1980 Pagt. Four between pump differential pressure and pump flow. It was erroneously thought that lowering pump differential pressure would also lower pump flow (which was on the lower limit of acceptability). The pump was declared inoperative. A subsequent test on 1-31-80, revealed the error of the previous test and suitable adjustments were made to bring the pump within limits. Therefore, the pump should have never failed the 1-30-80 test. It was the opinion of the PRB that. the pump was erroneously declared inoperative and was actually operable during the time period between the two tests. It was felt that an incorrect assumption of pump pressure / flow characteristics had been made which prevented satisfactory completion of the previous test.

Therefore, while the inspector may disagree with the decisions made on reportability of these three examples, it is felt that an adequate review of each situation was performed at the time of occurrence and the decisions made were justified.

Should you have any questions concerning this letter, please contact this j ortice.

. Sincerely,

?,,' {l 7f % E n L W. A. Widner Vice President and General Manager Nuclear Generation DLT/mb r