ML20070M379

Responds to NRC Re Violations Noted in IE Insp Repts 50-321/82-35 & 50-366/82-33.Corrective Actions:New Procedures Written for one-time Testing of Portions of Standby Gas Treatment Sys Logic

ML20070M379
Person / Time
Site:	Hatch
Issue date:	12/28/1982
From:	Gucwa L GEORGIA POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20070M354	List: ML20070M379
References
NUDOCS 8301250169
Download: ML20070M379 (3)

Text

. . .

w ,

Gmga Power Carrpanj

. 333 Pedmorit Avenue Anarna Georg a 30'408 Te!cpnone 404 526 652G g ,, ,,1 Ma.hng Adyess '.--

Post Omce Box 4545 Arama Geor7a 30302 h-

, a1 03 Georgia Power Power Generat on e rtm nt I '

U. S. Nuclear Regulatory Commission

REFERENCE:

Office of Inspection and Enforcement RII: JP0 Region II - Suite 2900 50-321/50-366 101 Marietta Street, NW Inspection Report Atlanta, Georgia 30303 82-35/82-33 ATTENTION: Mr. James P. O'Reilly GENTLEMEN:

The referenced inspection report identified a violation of NRC requirements. We have reviewed the violation and offer the following response.

VIOLATION Technical Specification 6.8.1 requires that procedures controlling the operation of safety-related systems be implemented. Plant procedures HNP-1-3654 and HNP-2-3654, Standby Gas Treatment Train Automatic Initiation, was written to implement the requirements of Technical Specification 4.7.B.l.d. and 4.6.6.1.d.2, respectively.

Contrary to the above, HNP-1-3654 and HNP-2-3654 did not adequately implement the requirements of Technical Specification 4.7.B.l.d and

4. 6. 6.1.d . 2. Although surveillance testing was scheduled and being conducted, a technical inadequacy existed, in that a complete test from sensor to activated device was not accomplished for Loss of Coolant Accident and the refueling floor radiation monitor signals.

RESPONSE

Admission or denial of the alleged violation: The violation occurred.

Reason for the violation: A complete test from sensor to activated device was not accomplished for the Unit 1 and Unit 2 Standby Gas Treatment Systems due to inadequacies in the testing procedures of the system. The testing of this system logic involves several procedures each of which covers testing of only a portion of the total logic train. Several portions of the logic system were inadvertently not included in any one of these procedures, resulting in untested gaps in the logic train run from sensor to activated device.

I 8301250169 830105

, PDR ADOCK 05000321

'_ G PDR_

Georgia Power m k

i U. S. Nuclear Regulatory Coninission Office of Inspection and Enforcement Region II - Suite 2900 December 28, 1982 Page Two Corrective steps which have been taken and the results achieved: New procedures were written for the one time testing of the portions of the Unit 1 and Unit 2 Standby Gas Treatment System logics whict were previously excluded from testing under plant procedures HNP-1-3654 and HNP-2-3654. The testing covered by these new procedures was performed and completed on October 14, 1982.

Logic test procedurn for all Unit 2 safety-related systems were reviewed and techniral inadequacies in testing were also found to exist-in other safety-ralated systems. New procedures were issued and performed or existing procedures were revised and performed to test logic excluded in I nit 2 logic testing procedures as identified by this review. Reportable Occurrence Report No. 50-366/1982-112, listing the systems which had inadequate testing procedures, has been submitted to the NRC.

Unit 2 safety-related systems for which surveillance testing under the new and revised proceduras has been completed include the following:

System Unit 2 Technical Specification Reactor Core Isolation Cooling 4.3.4.1 and Table 3.3.4-1 High Pressure Coolant Injection 4.5.1.c.1 Automatic Depressurization 4.5.2.a Residual Heat Removal 4.6.3.2 Corrective steps which will be taken to avoid future violations: Prior to startup from the current Unit 1 refueling outage, the logic test procedures for all Unit 1 safety-related systems will be reviewed for adequacy and revised as necessary. The new procedures written to test logic excluded in previous Unit 2 logic testing procedures are for one

! time tests and will be submitted for permanent revision by March 1, 1983. This will result in correct procedures being in place prior to the next logic system functional test required by Technical Specifications for each of these systems.

700775

r e

• Georgia Power 4k m.

U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II .',uite 2900 December 28. 1982 Page Three Date when full compliance will be achieved: Full compliance was achievid on October 14, 1982.

Should there be any any questions regarding this issue, please contact this office.

Very truly yours, f5 4~"

L. T. Gucwa Chief Nuclear Engineer CBS/mb xc: J. T. Beckham, Jr.

H. C. Nix, Jr.

Senior Resident Inspector l

l runs