ML20079K360

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Responds to NRC Re Violations Noted in IE Insp Rept 50-321/83-30.Corrective Actions:Personnel Counseled on Importance of Writing Deviation Repts in Timely Manner. New Deviation Rept Procedure Written
ML20079K360
Person / Time
Site: Hatch Southern Nuclear icon.png
Issue date: 01/06/1984
From: Gucwa L
GEORGIA POWER CO.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20079K327 List:
References
NED-84-001, NED-84-1, NUDOCS 8401240584
Download: ML20079K360 (3)


Text

i Georgia Power Compar'y 333 Pe1mont Avunue Attarta Geo g'a 303M Telephone 404 5266526 Maikng Address Poe,t Ott:ce Box 4545 Atlanta, Georgia 30302 Georgia Power L T. Gucwa the soo"un entre sg, tem Manager Nuclear Engineenng and Chef Nuclear Eng:neer NED-84-001 January 6, 1984 U. S. Nuclear Regulatory Ccamission

REFERENCE:

Office of Inspection and Enforcsent RII: JPO Region II - Suite 2900 50-321 101 Marietta Street, NW Inspection Report Atlanta, Georgia 30303 50-321/83-30 ATITNTION: Mr. J mes P. O'Feilly GENTLEMEN:

The following information is sutnitted in response to Inspection Report Ntaber 50-321/83-30 conducted by Mr. R. V. Crlenjak of your office on October 1-31, 1983. One apparent violation was found.

VIOLATION:

Technical Specification 6.8.1 rquires that the licensee establish, implement and maintain procedures covering the applicable procedures reccamended in Appendix A to Regulatory Guide 1.33, Revision 2,

February 1978.

Procedure HNP-425, " Deviation Report", an approved station procedure covering the issuance of plant deviation reports, requires mong other things that a deviation report be written inmediately upon the discovery that a limiting condition for continued operation as defined in the Technical Specifications is exceeded.

Unit 1 Technical Specification 3.13-1 Action Statment rquires that with the ntuber of operable fire detection instrtments less than required, establish a fire watch patrol to inspect the zone with the inoperable instrinents at least once per hour.

Contrary to the above, on Septaber 6,1983, the licensee failed to write a deviation report concerning inoperability of circuitry supervision for the fire detection systems.

Frcm Septaber 6 to Septaber 12, 1983, while this supervisory circuit was inoperable, a fire watch was not established and maintained.

' Ibis is a Severity Level IV Violation (Suppleent 1) 8401240584 840113 PDR ADOCK 05000321

'O PDR

6 a

g GeorgiaPower d U. S. Nuclear Regulatory Ccumission Office of-Inspection and Enforement Region II - Suite 2900 101 Marietta Street, Mt Atlanta, Georgia 30303 i

January 6, 1984 Page 2 RESPONS" Achission or denial of the alleged violation:

% e violation occured.

Reason for violation:

While conducting routine fire protection surveillance, maintenance personnel noted that see sub-caponents were not fully operable. %is finding was discussed with operations personnel to determine if _this condition rendered a portion of the fire protection systs inoperable.

At the conclusion of these discussions the involved _ parties departed each thinking that the other would research the problen and submit a deviation report which would have established fire watches as raguired. It is felt that the failure to submit a

deviation - report, contrary to existing procedures, was the result of poor connunications between maintenance and operations personnel.

We lack of proper reporting resulted in the failure to post fire watches as required.

Corrective steps which have been taken and results achieved:

As.

reported in LER's No.

321/1983-088 and 366/1983-091, involved personnel were counseled on the importance of writing deviation reports in a timely manner.

In addition to these actions taken at the time of the LER subnittals, all operations supervisors have been made aware, through the placenent of the Notice of Violation along with a written discussion of these-events in the Night Order Book for their review, of the significance of these events and the importance

of deviation reports. All maintenance fire protection personnel have been given additional counseling based upon this violation and the events that led to the Notice of Violation.

Fire protection engineers were supplied a copy of this vio'sation to assure they understand the importance of empleting deviation reports in a timely manner. - %ese actions should result in all involved personnel being

.more aware of the need to ceplete deviation reporting so that proper actions may be taken to maintain the plant in a safe condition at all times.

700775

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GeorgiaPower A U. S. Nuclear Regulatory Ccmaission Office of Inspection and Enforc sent Region II - Suite 2900 101 Marietta Street, NW Atlanta, Georgia 30303 January 6, 1984 Page 3 Corrective steps which will be taken to avoid future violations:

Georgia Power Cmpany (GPC) has conducted a review of the existing deviation report procedure (due to the referenced LER's and for other reasons). This review noted that confusion existed' regarding whether a non-conformance or a deviation report is required for a given situation.

Also noted was a weakness in the existing wording regarding who is assigned responsibility to submit required reports for action. To resolve these concerns a new procedure (HNP-444) was drafted to c mbine the existing deviation report and the non-conformance report into a single deficiency report.

This draft procedure also clearly states that the person finding a deficiency is rquired to subnit the report, thereby starting the reviews which will make the detemination of actions which are required to maintain the plant in empliance with requirments.

This draft procedure has been reccmnended for approval by the Plant Review Board. Approval of this procedure is corrently awaiting the cmpletion of a training program for implemention of the procedure.

This procedure and the associated training will be cmpleted by March 7,1984.

Date when full empliance will be achieved:

Full empliance was achieved on Septaber 12, 1983, when the involved fire protection systes were tested and returned to service.

Very truly yours,

[f'h L. T. Gucwa WEB /eb xc: J. T. Beckh m, Jr.

H. C. Nix, Jr.

J. P. O"Reilly Senior Resident Inspector room

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