ML20003F363
| ML20003F363 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 04/03/1981 |
| From: | Widner W GEORGIA POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20003F353 | List: |
| References | |
| NUDOCS 8104200655 | |
| Download: ML20003F363 (6) | |
Text
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George Power Con.pany 4
333 Piedrnoat Av?,;nue Ai.anta. George 30308 Ttlephone 404 526-6526
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Maihng Address:
Post Office Box 4545 i-Atlanta. Georgia 30302 GeorgiaPower W. A. Widner Vice President and Gener9 Manager Nuclear Generation April 3, 1981 United States Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 3100 101 Marietta Street, NW REF: 50-321/
Atlanta, Georgia 30303 50-366 ATTENTION: Mr. James P. O'Reilly Gentlemen:
Georgia Power Company offers the following in response to the violations ci:ed in NRC I&E Report Nos. 50-321/81-03 and 50-366/81-03 dated March 11, 1981. As noted, the violations are applicable to Unit 2 only.
VIOLATION A.
Technical Specification 6.8.1 requires that procedures shall be impl emented. HNP-8, " Maintenance Request (MR)", Revision 13 dated 3/80, paragraphs 12.c, d, and e requires that when parts for requested maintenance are obtained with an Inventory Material Request (IMR),
a ' copy of the IMR will be attached to the MR or if an IMR is not used, the parts will be noted on the back of the MR. Also, the worker will attach any QA conformance tags, for parts used, to the MR.
Contrary to the above, HNP-8 was not implemented in that:
for the replacement of four Local Power Range Monitors, neither the IMR nor the notation on the back of the MR nor the QA conformance tags were attached to MR-2-80-4176 dated 12/2/80; and for the replacement of a control rod reed switch position indicating assembly, the QA tags were not attached to MR-2-80-4023 dated 12/11/80.
Both MR's had been reviewed by the appropriate foreman and by the station QC department.
This violation is applicable only to Unit 2.
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GeorgiaPower d Mr. James P. O!Reilly April 3,1981 Page ~2
RESPONSE
1.
Admission or denial of the alleged violation (s):
Failure to implement HNP-8 is acknowledged in that the applicable IMR and QA Confo; :ance tags were not attached to MR 2-80-4176.
There was no violation of HNP-8 in conjunction with MR 2-80-4023 in that replacement materials used were "Non-Q" parts. The materials used were listed on the back of MR 2-80-4023 per the requirements of HNP-8, Step 12e.
2.
The reason (s) for the violation if admitted:
There were not any IMR or QA Conformance tags attached to MR 2 4176 because the materials were removed from the Warehouse per HNP-2-9600, "Special Nuclear Material Inventory and Transfer Control."
The maintenance request originally written to do the work of moving the Local Power Range Monitor detector strings from the Warehouse to the refueling floor was voided because the work was done per HNP-2-9600. The IMR and QA Conformance tags were consequently lost.
3.
The corrective steps which have been taken and the results achieved:
Immediate corrective action performed was to acquire copies of the appropriate IMR and QA Conformance tags and attach them to MR 2 4176.
4.
Corrective steps which will be taken to avoid further violations:
HNP-2-9600 has been revised to require that a maintenance request be written when any special nuclear material is to be removed from the warehouse and to require the IMR and any applicable QA Conformance tags be attached to the maintenance request.
5.
The date when full compliance will be achieved:
Compliance was achieved as of March 27, 1981, when procedure.HNP 9600 was revised.as discussed in response to item 4 above.
VIOLATION B.
Technical Specification 4.6.1.2.e requires that an error analysis shall be performed to select a balanced integrated leakage measurement system. Technical Specification 3.6.1.2.c requires a leakage of less than 11.5 scf per hour for any one main steam isolation valve when tested at 28.8 psig, be verified.
GeorgiaPower A Mr. James P. O'Reilly April 3, 1981 Page 3 i
Contrary to the above, an error analysis was not done for the measured type C leakage for the main stean isolation valves in that the flow meter used for the testing was calibrated at 59 psig and used at 28.8 psig and no attempt was made to confirm with the i
manufacturer or the calibration laboratory that the error of the instrument was within expected and within allowable tolerances.
This information is required for an error analysis.
This violation is applicable to (Init 2 only.
This is a Severity Level V Violation (Supplement I.E.).
RESPONSE
1.
Admission or denial of the alleged violation (s):
Failure to perform adequate error analyses for the measured type C leakage for Main Steam Isolation Valve is acknowledned in that consideration was not made for differing instrument tolerances of flowmeters when used at other than calibrated pressure.
-2.
The reason (s) for the violation if admitted:
It was believed that the correction formula appearing in procedure HNP-2-3952, "Primarf Containment Periodic Type B and Type C Leakage Tests", Data Sheet 1, was sufficient to compensate for the use of the test flowmeter at other than calibrated pressure. Therfore, the difference in calibration tolerance between the calibrated pressure of the flowmeter and the pressure at which the flowmeter was not considered.
3.
The corrective steps which have been taken and the results achieved:
The immediate corrective action taken was to contact the flowmeter manufacturer to determine the magnitude of error which could be I
experienced at a test pressure of 28.8 psig for a flowmeter calibrated at 59 psig. According to the manufacturer the difference in possible error would not be of a great enough magnitude to cause any leak rate test previously passed by the leak rate test coordinator to fail. The fl swmeter calibrated at 59 psig was later compared to a flowmeter calibrated at 28 psig. The results of that comparison are attached, l
4.
Corrective steps which will be taken to avoid further violations:
Flowmeters have been acquired which are calibrated at the pressure c
which the leak rate for Main Steam Isolation Valves are performed.
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Personnel involved with leak rate testing have been counseled as to the importance of using flowmaters of the correct calibrated pressure.
In addition, the decision has been made to change flowmeter vendors in an effort to upgrade availability of correctly calibrated flowmeters.
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GeorgiaPower A Mr. James P. O'Reilly April 3,1981 Page 4 5.
The date when full compliance will be achieved:
As of March 27, 1981, the unit is in full compliance.
VIOLATION C.
10 CFR 50, Appendix B, Criterion XVII requires that records shall be identifiable and retrievable. The accepted Quality Assurance program (FSAR Section 17) states that requirements of Regulatory Guide 1.88 are complied with, which endorses ANSI N45.2.9-1974 which requires that document storage systems shall provide for the accurate retrieval of information without undue delay.
Contrary to the above, records were not retrievable in that:
(1) of 8 completed Maintenance Requests (MR) which were requested by the inspector, one was not retrieved (2-80-1873,) and 4 (2-80-1541, 2-80-1242, 2-80-1915 and 2-80-3145) required 2 days or longer to retrieve; (2) two completed procedures (HNP-2-5025 and HNP-2-6035) which were accomplished with MR-2-80-4176 dated 12/2/80 were not retrieved; and (3) the calibration data for the flowmeter used in the type C leak rate testing of the Main Steam Isolation required more than one day to retrieve.
This violation is applicable only to Unit 2.
This is a Severity Level V Violation (Supplement I.E.).
RESPONSE
1.
Admission or denial of the alleged violation (s):
Failure to retrieve documents in a timely manner is an admitted violation.
2.
The reason (s) for the violation if admitted:
The violation was the result of documentation and attachments being out of their normal file locations due to a bulletin review.
This caused undue delay in locating the specific placement of the records in question.
3.
The corrective steps which have been taken and the results achieved:
Subsequent to the inspection, all maintenance requests and attachments have been relocated in the document control section in specified files. This centralized the probable location of these and similar type records. All records associated with the inspection are now located in the records room and timely retrieval demonstrated.
GeorgiaPower d Mr. James P. O'Reilly April 3,1981 Page 5 4.
Corrective steps which will be taken to avoid further violations:
Additional department personnel have been trained in retrieving "in process" hard copy records.
Personnel are being trained in terininal retrieval techniques and filing methods.
In-process records are being relocated in order to make retrieval of specific record types more timely.
Personnel are being made available to accelerate the processing of hard-copy records into the computerized retrieval system.
5.
The date when full compliance will be achieved:
Tentatively, the unit will be in full compl.fance as of January 1, 1982.
If you have any questions in this regard, please contact my office.
W. A. Widner states that he is Vice President of Georgia Power Company and 13 authorized to execute this oath on behalf of Georgia Power Company, and that to the best of his knowledge and belief the facts set forth in this letter are true.
Georgia Power Company by:
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f"M W. A. Widner Sworn to and subscribed before me this 3rd day of April.1981.
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Notary Public JAE/mt notary Public, Gaorgia, State at Large My Commission Expires Sept. 20,1983 Attachment xc:
M. Manry R. F. Rogers, III
ATTACHMENT Flow Comparison at 28 psig in SCFH.
L510809 L510846 Calculated using L510846
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4.4 6
4.56 5.2 7
5.32 5.9 8L 6.08 6.7 9
6.85 7.45 10 7.61 8.1 11 8.37 9.13 8.8 12 9.5 13 9.89 10.3 14 10.65-11.0 15 11.41 11.7 16 12.17 12.5 17 12.93 13.25 18 13.7 13.9 19 14.46 14.6 20 15.22 15.4 21 15.98 16.2 22 16.72 L51Q809 is a 4.40 SCFH flowmeter calibrated at 28 psig.
L51Q846 is a 0-22 SCFH flowmeter calibrated at 59 psig.
Maximum percent error between indicated flow on L51Q809 and calculated flow using reading on L51QS46 using formular on Data Sheet 1.of HNP-2-3952 is 4.07%.
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ATLANTA, GEORGIA 30303 MAR 1 119y Georgia Power Company ATTN:
J. H. Miller, Jr.
Executive Vice President 270 Peachtree Street Atlanta, GA 30303 Gentlemen:
Subject:
Report Nos.. 56-321/81-03 and 50-366/81-03 This refers to the routine safety' inspection conducted by T. A. Peebles of this office on February 17-20, 1981, of activities authorized by NRC Operating License Nos. OPR-57 and NPF-5 for the Hatch facility. Our preliminary findings were discussed with T. V. Greene and C. T. Moore at the conclusion of the inspection.
Areas examined during this inspection included refueling surveillance testing and maintenance. Within these areas, the inspection consisted of selective exami-nations of procedures and representative records, interviews with personnel, and observations by the inspector.
During the inspection, it was found that certain activities under your license appear to violate NRC requirements. These items and references to pertinent requirements are listed in the Notice of Violation enclosed herewith as Appendix A.
Elements to be included in your response are delineated in Appendix A.
In accordance with Section 2.790 of. the NRC " Rules of Practice," Part 2, Title l
10, Code of Federal Regulations, a copy of this letter and the enclosed inspec-tion report will be placed in the NRC Public Document Room.
If this report contains any information that you believe to be proprietary, it is necessary that you make a written application within 20 days to this office to withhold such information from public disclosure. Any such application must include the basis for claiming that the information is proprietary and the proprietary information i
l should be contained in a separate part of the document.
If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.
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Should you have any questions concerning this letter, we will be glad to discuss them with you.
Sincerely
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Richard C. L 'is, Acting Director Division of Resident and Reactor Project Inspection
Enclosures:
1.
Appendix A, Notice of Violation 2.
Inspection Report Nos. 50-321/81-03 and 50-366/81-03 cc w/ encl:
M. Manry, Plant Manager C. E. Belflower, Site QA Supervisor W. A. Widner, Vice President and General Manager-Nuclear Generation 6
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e APPENDIX A NOTICE OF VIOLATION Georgia Power Company Docket No. 50-50-366 Hatch 2 License No. NPF-5 As a result of the inspection conducted on February 17-20, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980),
the following violations were identified.
A.
Technical Specification 6.8.1 requires that procedures shall be implemented.
HNP-8, " Maintenance Request (MR)", Revision 13 dated 3/80, paragraphs 12.c, d and e requires that when parts for requested maintenance are obtained with an Inventory Material Request (IMR), a copy of the IMR will be attached to the MR or if an 'IMR is not used, the parts will be noted on the back of the MR. Also, the worker will attach any QA conformance tags, for parts used, to the MR.
Contrary to the above, HNP-8 was not implemented in that: for the replace-ment of four Local Power Range Monitors, neither the IMR nor the notation on the back of the MR nor the QA conformance tags were attached to MR-2-80-4176 dated 12/2/,80; and for the replacement of a control rod reed switch position indicating assembly, the QA tags were'not attached to MR 2-80-4023 dated 12/11/30. Both MR's had been reviewed by the appropriate foreman and by the station QC department.
This ' violation is ~ applicable only to Unit 2.
This is a Severity Level V Violation (Supplement I.E.).
A similiar item was brought to your attention in our letter to you dated August 22, 1980.
B.
Technical Specification 4.6.1.2.e requires that an error analyses shall be performed to select a balanced integrated leakage measurement system.
Technical Specification 3.6.1.2.c requires a leakage of less than 11.5 scf per hour for any one main steam isolation valve when tested at 28.8 psig, be veri fi ed.
Contrary to the above, an error analyses was not done for the measured type C leakage for the main steam isoittion valves in that the flow meter used for the testing was calibrated ac 59 psig and used at 28.8 psig and no attempt was made to. confirm with the manufacturer or the calibration labo-ratory -that; the error sof thec instrument was. within expected and within allowable. tolerances. This information is required for an error analysis.
This violation is applicable only to Unit 2.
' This f s a Severity Level V Violation (Supplement I.E~.').
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1 Georgia Power Company 2
Docket No. 50-366 Notice of Violation License No. NPF-5 C.
10 CFR 50, Appendix B, Criterion XVII requires that records shall be identifiable and retrievable. The accepted Quality Assurance program (FSAR Section 17) states that requirements of Regulatory Guide 1.88 are complied with, which endorses ANSI N45.2.9-1974 which requires that document storage systems shall provide for the accurate retrieval of information without undue delay.
Contrary to the above, records were not retrievable in that:
(1) of 8 completed Maintenance Requests (MR) which were requested by the inspector, one was not retrieved (2-80-1873,) and 4 (2-80-1541, 2-80-1242, 2-80-1915 and 2-80-3145) required 2, days or longer to retrieve- (2) two completed procedures (HNP-2-5025 and HNP-2-6035) which were accomplished ~with MR-2-80-4176 dated'12-2-80 were not retrieved; and (3) the calibration data for the flow meter used in the type C leak rate testing of the Main Steam Isolation Valves required more than one day to retrieve.
This violation is applicable only to Unit 2.
This is a Severity Level V Violation (Supplement I.E.).
Pursuant to the provisions of 10 CFR 2.201, you are hereby required to submit to this office within twenty-five days of the date of this Notice, a written statement or explanation in reply, including:
(1) admission or denial of the alleged violations; (2) the reasons for the violations if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective
, steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation.
Date:
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101 MARIETTA ST N.W.. SUITE 3100 Q
ATLANTA, GEORGIA 30303 Report Nos. 50-321/81-03 and 50-366/81-03 Licensee: Georgia Power Company 270 Peachtree Street Atlanta, GA 30303 Facility Name: Hatch Facility Docket Nos. 50-321' and 50-366 License Nos. DPR-57 and NPF-5 Inspection at Hatch site near Baxley, Georgia 3 /0/8/
Inspector:
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Date Signed T.A.Peebleg G
Approved by:
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J. C. Br/ Ant, Section phiq/f, Dfvision of Date S4gned f
Resident and Reactor PPoject Inspection
SUMMARY
Inspe tion on February 17-20, 1981 Areas Inspected This routine announced inspection involved 32 inspector-hours on site in the area of refueling activities, including surveillance testing and maintenance.
Results In the one area inspected, three violations were found. (Failure to implement a procedure, paragraph 5.b(2); Failure to retrieve documents, paragraph 5.b.(2);
Failure to accomplish an error analysis, paragraph 5.c.).
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DETAILS 1.
Persons Contacted Licensee Employees
- S. Curtis Sr.' Senior Technical Advisor
- Roger Tracy, Junior Engineer s
- C. E. Belflower, QA Site Supervisor
- W. P. Wagner, QAFR
- 0., L. McDaniel,. Supt. gof Administration
- B.' Ti Nix, Supt; of Maintenance
- C. R. Miles, Jr.,- QA Field Supervisor
- H. D. Byrd, I&C Foreman
- C. D. Henry, I&C Foreman
- P. Branch, QC
- C. H. Williams, QC C. L. Coggin, SPES
- D. A. McCusker, QC Supervisor "J. T. Beckham, Manager of Nuclear Generation
- T. V. Greene, Ass't Plant Manager
- C. T. Moore, Ass't Plant Manager T. Elton, Engineering D. Morgan, Engineering P. Fornel, QAFR Other licensee employees contacted included'3 technicians, 4 operators, and 12 office personnel.
- Attended exit interview NRC Resident Inspector
- R. F. Rogers i
2.
Exit Interview
.The inspection scope and findings were summarized on February 20, 1981, with those persons indicated in Paragraph 1 above.
i 3.
Licensee Action on Previous Inspection Findings l
Not inspected.
.4.
Unresolved I' ems t
Unresolved items were not identified during this inspection.
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5.
Refueling Activities a.
Safeguards Functional Test with Loss of Offsite Power The inspector reviewed the Unit 2 refueling functional tests with the cognizant engineer with specific attention to:
technical content, resolution of discrepancies, procedural adherence, and evaluation of results.
The tests reviewed were HNP-2-3830, HNP-2-3831 and HNP-2-3832. All aspects of the testing met regulatory requirements.
In addition, after large scale maintenance on the 2C diesel, the licensee re-ran the 24-hour surveillance test.
The monthly diesel
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' operability-test of the'20idiesell was observed by the ' inspector and was:
adequate.
b.
Reactivity Control Systems (Surveillance Testing and Maintenance)
(1) The inspector verified that the control rod seque'nce input to the Rod Worth Minimizer had been verified to be correct and that the control rod ~ sequencing pattern had been properly transmitted to the operations group for use prior to the start-up of Unit 2 in accordance with Technical Specification (T.S.) 3.4.1.4.
(2) The inspector reviewed maintenance records of four Local Power Range Monitors (LPRM) which had been replaced during the on going refueling of Unit 2.
The Maintenance Request (MR) (2-80-4176) completed on 12/2/80, did not have the Invertory Material Requests (IMR) or notation on the back"of the MR as to parts used or have~
the QA tags attached as HNP-8 (procedure for implementing MR's) required..T.his item, together. with the example in paragraph 5.b.(3) constitites a' violation (366/81-03-01) for failure to implement a procedure.
A similar item was brought to the licensee's attention in our letter dated August 22,1980. ~The response to this infraction stated that a detailed MR training program would be completed by November 1, 1980.
The onsite Quality Assurance group verified that this had been accomplished and closed out their item on 11/23/80.
The procedure for replacement of the LPRM's (HNP-2-6035) did not have a step to require that initial settings for new LRPM's be obtained from the reactor engineer and the instrcment re-set in accordance with current approved calibration procedures.
The licensee changed the procedure and made the correct initial settings;for.these LPRM's prior to the unit start-up.
. The completed procedures for this MR (2-80-4176), which were used to bench test the LPRM's and to install them, were requested so that a review could be done. They were not retrieved and are an example of non-retrievability of records without ' ndue delay as is.
u required by ' ANSI;N45.2.9-1974,- per commitment-to-Regulatory Guide
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1.88 in the FSAR section 17.2 and Appendix A.
Other examples are shown in paragraphs 5.b.3 and 5.c and together constitute a violation (366/81-03-32).
(3) The inspector reviewed maintenance records of replacement and repair of control rod reed switch position indicators.
The MR's were noted as being safety-related (Q) and some as not being safety-related (Not-Q). A copy of the MR's were requested and one (MR-2-80-4023 dated 12/11/80) was found, was marked Q and did not have the QA tags attached. This MR had been reviewed and is an example of not impl.ementing HNP-8. An attemot was then made to review'a sufficient number of theiother MR's completed on the control rod reed switch position indicators to ascertain if these examples were an oversight; however, of the eight MR's requested, four required two days or longer to retrieve (MR's 2-80-1541, 2-80-1242, 2-80-1915 and 2-80-3145) and one was not retrieved (2-80-1873).
This is an example of non-retrievability of documents. Only one MR had the required QA tags (2-80-2131).
Discussions with corporate management indicates that the problem of document retrievability was being investigated.
c.
Primary Containment Leakrate Testing The inspector reviewed the primary containment periodic type B and type C leakage procedure: (.HNP-2-3952) for testing technique, instrument '
calibration, test result evaluation and T.S. conformance. All aspects of'the testing were acceptable, except that of the calibration of the flow ; instrument used.for the main steam isolation valve leak rate _
testing an'd the' evaluat'.on of this data. When this instrument was m
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recei.ved from the. calibration vendor,-it was note.d by the licensee that.
the pressure that the instrument was calibrated at was noted to be 59 psig, which was questioned as it should have been 28.8 psig. The vendor responded that 59 psig was-the pressure used. The licensee did not question the difference in accuracy which would be caused by using the instrument at 28.8 psig and assumed that there would not be a difference.
When the inspector questioned the basis for no error difference, the licensee contacted the vendor and it was determined j
that a decrease in accuracy would have to be taken into account. It l
was agreed that the maximum postulated inaccuracy would not cause the recalculated leakages to be outside the margin allowed and the Technical Specification leakage limits were being met.
This is considered a violation (366/81-03-03) as an error analysis was not done to assure that the margin to the Technical Specification limits was being met with known instrument tolerances per Technicial Specification 3/4.6.1.2.e.
l The calibration data for the flow meter was requested for review. The retrieval of this document required more than a day and is considered i
an example of document non-retrievability;
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Reactor Engineering The procedure for Shutdown Margin Demonstration (HNP-2-9401) and the form completed after criticality were reviewed with no discrepancies found.
The control rod scram testing procedure (HNP-2-9402) and the data on the control rods that had been tested were reviewed. The test evalu-ation was being accomplished, but there was no method of documenting the evaluation. A formal evaluation and review was requested prior to the control. rods being declared operable. This was completed. Also, a
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' chang'e to' th4 procedure was requestid'to ' assure the continuing' evalua -
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tion and review of the scram times 'and this was initiated.
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