ML20058G620

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Responds to NRC Re Violations Noted in IE Insp Repts 50-321/82-09 & 50-366/82-09.Corrective Actions: Isolation Actuation Instrumentation Setpoint for Reactor Core Isolation Cooling Inboard Isolation Valve Corrected
ML20058G620
Person / Time
Site: Hatch  Southern Nuclear icon.png
Issue date: 06/22/1982
From: Beckham J
GEORGIA POWER CO.
To: Robert Lewis
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20058G617 List:
References
RII:RFR, NUDOCS 8208030377
Download: ML20058G620 (10)
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REFERENCE:

Office of Inspection and Enforcement RII: RFR Region II - Suite 3100 50-321/50-366 101 Marietta Street, NW Inspection Report Atlanta, Georgia 30303 82-09 ATTENTION: Mr. R. C. Lewis GENTLEMEN:

Georgia Power Company (GPC) submits the following information in response to the Notice of Violation in Appendix A of your letter dated May 18, 1982. GPC has reviewed the alleged violations and hereby responds in accordance with 10 CFR 2.201.

VIOLATION A Technical Specification 3.3.2 requires that the isolation actuation instrumentation channels in Table 3.3.2-1 be operable with trip setpoints consistent with the values shown in Table 3.3.2-2. If not operable, the channel must be restored to operable status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or the affected system isolated.

1. Contrary to the above, the isolation actuation instrumantation setpoint for the high steam flow isolation signal of the RCIC inboard isolation valve was not set less than or equal to 3004 of rated flow as required by Table 3.3.2-2 Item 5.a. The system was not isolated and declared inoperable as required by Table 3.3.2-2 Item 5.a. This conc'ition had existed for approximately two and one half years as a result of a misplaced design change request DCR (79-376). The misplac id DCR was discovered and the corrected setpoint changes was accomplished on January 11, 1982.
2. Contrary to the above Technical Specification, the isolation actuation j setpoint for the RCIC inboard steam line isolation valve was erroneously '

set to a nonconservative value on January 28, 1982, due to the licensee's failure to properly implement a change to procedure l FNP-2-3410, RCIC Steam Line Delta P Instrument Functional Test and Calibration.

RESPONSE TO VIOLATION A.1 l

1. Admission or cenial of the alleged violation.

The violation did occur as stated.

8208030377 820723 PDRADOCK05000g u

l Georgia Power A U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 3100 June 22, 1982 Page Two

2. Reasons the violation occurred:

The violation occurred due to site personnel not immediately recognizing that the reduction of the RCIC instrument setpoint implied the previous '

setpoint was non-conservative with respect to Technical Specifications.

3. Corrective steps that have been taken and the results achieved:

The nonconservative setpoint was corrected upon discovery of the problem on January 11, 1982.

4. Corrective steps that will be taken to avoid further violations:
a. A review of all open DCR's was performed to detemine if any other DCR similar to the subject DCR was unresolved. No similar DCR was found to be unresolved.
b. Site engineers have been given training on the importance and the proper handling of Technical Specification related DCR's. A training outline for new engineers was initiated on January 1, 1982. This outline delineates in a checklist format certain areas to be discussed with a new engineer. A discussion of Technical Specifications is included as part of_ the outline. This training was completed on March 26, 1982.
c. Improved information exchange when responsibilities for engineering activities are transferred from one engineer to another is expected with the implementation of the system turnover checklist on April 1, 1982. A discussion of outstanding DCR's status is to take place when an engineer is either assigned a new system or relinquishes responsibility for a system.
5. Date when full como11ance will be achieved:

Full compliance was achieved on January 11, 1982 with correction of the nonconservative isolation setpoint.

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l GeorgiaPower A U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 3100 June 22, 1982 Page Three RESPONSE TO VIOLATION A.2

1. Admission of denial of the alleged violation:

The violation occurred as stated.

2. Reasons the violation occurred:

The violation occurred because the method of handling temporary procedure changes, per HNP-9 " Procedure Use and Control" was deficient.

The procedure did not contain a method of " tracking" temporary procedure changes made prior to the issuance of the permanent procedure revision, and thus provided no assurance of incorporation of necessary temporary changes to the procedure prior to implementation. Due to the method of handling temporary procedure changes, the "RCIC Steam Line Hi dP FT&C" procedure (HNP-2-3410) was not revised properly, prior to the implementation of the procedure as a part of normal surveillance performed on January 28, 1982.

3. Corrective steps that have been taken and the results achieved:

The plant modifications procedure HNP-809 was revised in October of 1981 to require the architect-engineer to write all 10 CFR 50.59 evaluations for each safety-related design change. The evaluation by the A/E provides additional technical review to assure that the proposed change is properly evaluated for its safety significance.

4. Corrective steps that will be taken to avoid further violations Procedure HNP-9 " Procedure Use and Control", was revised to prevent the recurrence of a similar event. Temporary procedure changes are now handled as follows: the temporary procedure changes is submitted to the department superintendent. The department superintendent is responsible for stating on the temporary procedure change whether the change is to be permanently incorporated into the procedure at a later date. A copy of the " marked-up" procedure is then placed in the Shift Foreman's and the departmental procedure book, if the change is to be made permanent.

Upon permanent revision the copy of the temporary change is removed.

5. Date when full compliance was achieved:

Full compliance was achieved on February 8,1982 with the correction of the nonctoservative isolation setpoint.

Georgia PowerA U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 3100 June 22, 1982 Page Four VIOLATION B Technical Specification 6.9.1.8.1. requires when performance of components (sic) requires remedial action or corrective measures to prevent operation in a manner less conservative than assumed in the accident analyses, safety - analysis report or technical specification bases that it be reported to the regional office within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. -

Contrary to the above, the existence of a non-conservative setting for the RCIC inboard steam line isolation valve trip setpoint was not reported promptly to the regional office withire 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as required when it was discovered in the fall of 1979 and again on January 11, 1982 (two examples).

RESPONSE TO VIOLATION B

1. Admission or denial of the alleged violation:

The violation did occur as stated.

2. Reasons the violation occurred:

The violation occurred as a result of the following:

a. A deviation report was not initiated for the fall 1979 event due to the site staff failure to recognize that the revised setpoint was non-conservative as discussed in Response to Violation A under 2.a. Since the deviation report was not written and the reportability therefore not determined, no - report was made to the regional office at the time of the event.
b. The plant staff did not determine that Technical Specification 6.9.1.8.1 (24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> reporting) was applicable for the event on January 11, 1982, but instead reported the event per Technical Specification 6.9.1.9.c. (30-day reporting; reference LER 50-366/1982-05).
3. Corrective steps that have been taken and the results achieved:

A deviation report was written for the January 11, 1982 event. This deviation report was reported under LER 50-366/1982-05.

1 Georgia Power A U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 3100 June 22, 1982 Page Five

4. Corrective steps that will be taken to avoid further violations:

A training lesson plan was issued at the plant which clarified the reporting requirements so as to minimize future misinterpretations of Technical Specification Section 6.9. This lesson plan is scheduled to be reviewed by all Plant Review Board members by July'1, 1982.

5. Date when full compliance was achieved:

Full compliance was achieved on February 9, 1982.

VIOLATION C Technical Specification 6.8.1 requires that written procedures shall be established, implemented and maintained covering the applicable procedures recommended in Appendix "A" of Regulatory Guilde 1.33, Revision 2, February 1978 and surveillance and test activities of safety-related equipment.

1. Contrary to the above, on June 14, 1981, plant procedure FNP-801 was not followed in that a nonconformance report was not issued when eight control- rod drive mechanisms were unable to satisfy the acceptance criteria stated in FNP-1-9404, " Control Rod Drive Timing".

This applies to Unit 1.

2. Contrary to the above Technical Specification, riant procedure FNP-2-3410, " Surveillance of the RCIC Steam Line Delta Instruments",

was not properly maintained or reviewed in that an ira rect setpoint value'of +142 inches of water existro in step F.2.0 of the procedure for setting the RCIC high steam flow isolation setpoint for the inboard isolation valve.

This applies to Units 1 and 2.

GeorgiaPower A U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 3100 June 22, 1982 Page Six

3. Contrary to the above Technical Specification, plant procedure HNP-820, Plant Records Management, paragraph E.2 was not followed in that plant records on control rod drive tests were not forwarded to the document control section subsequent to completion of control rod testing on June 14, 1981. On February 2, 1982, the records of only 51 of 137 rods tested were plant records. The remaining records were located in an engineers desk drawer.

This applies to Unit 1.

RESPONSE TO VIOLATION C.1

1. Admission or denial of the alleged violation:

The violation occurred as stated.

2. Reasons the violation occurred:

Procedures HNP-1-9404 and HNP-2-9404 were inadequate in that no provision existed for initiation of a nonconformance report when control ,

rod movement failed to meet acceptance criteria.

3. Corrective steps that have been taken and the results achieved:

Proceoures HNP-1, 2-9404 " Control Rod Drive Timing" were revised to reference HNP-801 and to outine steps to be taken if a CRD does not meet the acceptance criteria.

4. Corrective steps which will be taken to avoid further violations:

Inasmuch as the cause of this violation was an inadequate procedure, the corrective steps already taken should prevent further violations.

5. Date when full compliance will be achieved:

Procedures HNP-1, 2-9404, were revised and incorporated in their revised form on April 16, 1982 and April 30, 1982 respectively.

Georgia Power A U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 3100 June 22, 1982 Page Seven RESPONSE TO VIOLATION C.2

1. Admission or denial of the alleged violation:

The violation occurred as stated.

2. Reasons the violation occurred:

The violation occurred as a result of the failure by site personnel to properly revise plant procedure HNP-2-3410, "RCIC Steam Line High Delta P FT&C". The procedure was revised as a result of implementation of DCR 79-376 on January ll, 1982. The procedure went from revision 11 to revision 12 on February 4, 1982, to incorporate changes made per DCR 79-376. During the revision process personnel failed to change the text

portion of the procedure (step F.2.0) although the remaining portion of the procedure was revised correctly. The oversight did not result in the instrument being miscalibrated, and upon discovery of the deficiency the procedure was immediately changed per plant procedure HtF-9,

" Procedure Use and Control".

3. Corrective steps that have been taken and the results achieved:

Upon discovery of the improper setpoint in step F.2.0 in the procedure, the procedure was temporarily changed, reflecting the proper setpoint,

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per HNP-9 " Procedure Use and Control", as discussed in the response to Violation A. A permanent revision to the procedure was submitted and approved on February 20, 1982. Plant procedure HNP-1-3410 was revised on April 7, 1982 to eliminate the setpoint tolerance discrepancies noted in the inspection report

4. Corrective steps which will be taken to avoid further violations:

The changes made to date should preclude any further violation.

5. Date when full compliance will be achieved:

Full compliance was achieved on February 20, 1982.

Georgia Power A U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 3100 June 22, 1982 Page Eight RESPONSE TO VIOLATION C.3

1. Admission or denial of the alleged violation:

The violation occurred as stated.

2. Reasons the violation occurred:

The violation occurred due to personnel error. On June 14, 1982, HNP-1-9404, " Control Rod Drive Timing for Cycle 5 Startup" was completed and sent to documentation. Prior to this, on April 4,1981, and June 6, 1981, data packages were completed and turned over to the CRD systems engineer. Combined, these three sets of data comprised the entire Cycle 5 CRD timing effort. The systems engineer was than reassigned and he turned the first two sets of data over to the Reactor Engineering Department. These two sets of data were to be held until the third set of data was obtained, to be transmitted to records management together.

However, upon completion of the June 14, 1981, data, this set of data was transmitted directly to documentation. The other two sets of data remained in engineering until located during an audit.

3. Corrective steps that have been taken and the results achieved:

The subject data sheets were forwarded to the records department.

4. Corrective steps which will be taken to avoid further violations:

All personnel involved were Instructed in the proper handling of data packages per HNP-820, Plant Records Management.

5. Date when full compliance will be achieved:

With the return of the plant data sheets the plant was in full compliance.

3 GeorgiaPower A U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 3100 June 22, 1982 Page Nine VIOLATION D 10' CFR 50 Appendix 8 Criterion V requires activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures,- or drawings. Plant procedure HNP-822, Material Inspection Request, Step 6.1.a requires a two part QC hold tag be attached to material to be inspected.

Contrary to the above, on January 21, 1982, QC hold tags were not attached as required to approximately 100 spare Johnson pump parts in the warehouse.

1. Admission or denial of the alleged violation:

The violation occurred as stated.

2. Reasons the violation occurred:

The violation occurred due to the misinterpretation of the procedure which controlled the use of Hold Tags, HNP-822.

3. Corrective steps that have been taken and the results achieved:

Until procedure revision could be effected, all parts addressed in the violation were immediately tagged as required by the procedure.

4. Corrective steps that will be taken to avoid further violations:

Final corrective action consisted of procedure revision (FNP-822) which made it clear that Hold Tags may be-placed on boxes, pallets, etc. where i numerous items are stored.

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l 5. Date when full compliance will be achieved:

Full compliance was achieved immediately upon notice of violation on l January 21, - 1982 and final corrective action was achieved on I

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1 Georgia Power A U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 3100 June 22, 1982 Page Ten March 3, 1982 when revision was approved to procedure FNP-822 which allowed use of Hold Tags on containers rather than individual like items stored together.

J. T. Beckham, Jr. states that he is Vice President of Georgia Power Company and is 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: h/ - - h-pJ.T.Beckham,Jr'.

Sworn t ribed fore d of June, 1982 "g ,1 Notaty/ Publg CBS/mb SIN,',g',*, state t.

Enclosure xc: H. C. Nix R. F. Rogers, III l

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