ML20080B949
| ML20080B949 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 11/28/1994 |
| From: | Beckham J GEORGIA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9412070064 | |
| Download: ML20080B949 (3) | |
Text
Geor0 a Power Company i
40 invemess Center Parkway Post Othce Box 1295 Birmingham. Alabama 35201 Telephone 205 877-7279 m
Georgia Power J. T. Dockham, Jr.
Vice President - Nuclear Hatch Projoct November 28, 1994 Docket No. 50-321 IIL-4744 50-366 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Edwin I. Hatch Nuclear Plant Revision to a Reply to a Notice of Violation Gentlemen:
In response to your letter dated November 2,1994, Georgia Power Company (GPC) is providing the enclosed, revised response to the Notice of Violation associated with Inspection Report 94-17. The response has been revised to address corrective actions for inadequate procedural controls for ensuring that the appropriate keys are identified and replaced following the replacement of remote shutdown panel locks.
Sincerely..
f p. T. Beckham, Jr.
J JKB/et
Enclosures:
- 1. Violation 94-17-02 and Revised GPC Response l
cc: Georgia Power Company Mr. H. L. Sumner, Nuclear Plant General Manager NORMS i
U. S. Nuclear Remdatory Commission. Washington. D. C.
Mr. K. Jabbour, Licensing Project Manager - Hatch U. S. Nuclear Remdatory Commission. Region H Mr. S. D. Ebneter, Regional Administrator Mr. B. L. Holbrook, Senior Resident Inspector - Hatch
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9412070064 941128 I
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l Edwin I. Hatch Nuclear Plant Violation 94-17-02 and Revised GPC Response VIOLATION 94-17--02 10 CFR 50, Appendix B, Criterion V," Instructions, Procedures, and Drawings," requires that activities affecting quality be accomplished in accordance with procedures.
Administrative Control Procedure 80AC-SEC-002-05," Key and Annunciated Door Control," Section 4.2.4, requires the Operations Department to " Control locks and keys to keylock switches and instrument cabinets."
Contrary to the above, a key located in the Unit 2 EOP File cabinet that was designated to unlock the Unit 2 Auxiliary Shutdown Panel, cabinet 2C82-P001, was not the proper type of key and would not unlock the panel.
This is a Severity Level IV violation (Supplement I).
RESPONSE TO VIOL.ATION 94-17-02 Admission or denial of the violation:
The violation occurred as described in the Notice of Violation.
Re_ason for the violation:
This violation was caused by a less than adequate plant procedure and a lack of procedural cor.trols for lock replacement.
Procedure 341T-EOP-001-0S,"EOP Equipment Checks," requires that an annual audit of the EOP filing cabinet materials be performed. The audit includes a check of the number of EOP key rings in the cabinets, and verification of the number and designation of the keys that are on each key ring. However, this procedure does not require that each key be confirmed to open its designated lock (s). This procedure is less than adequate in this regard.
HL-4744 El-1
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k Encfosure 1 Violation 94-17-02 and Revised GPC Response It appears that the lock for the Unit 2 Remote Shutdown Panel was previously replaced and the keys on the key rings in the EOP filing cabinets were not replaced with the proper key. Procedural controls were not sufficient to ensure that EOP keys for locks without a breakaway feature, such as the remote shutdown panels, are identified and replaced when a lock is replaced. However, access to the remote Shutdown Panel was ensured because the appropriate keys on the EOP key rings for the Shin Operations Supervisor and the Shift Clerk were replaced with the proner key.
Corrective steps which have been ta(en anc the results achieved:
As a result of this violation, the following corrective actions have been performed:
- l. Copies of the key to the replaced Unit 2 Remote Shutdown Panel lock were made, verified to open the Remote Shutdown Panel, and placed on the applicable EOP key rings. The previous keys were removed from the key rings.
- 2. All EOP keys have been verified to open their designated locks. 'No additional problems were noted.
- 3. Administrative controls have been implemented to ensure that the keys for the remote shutdown panels and other EOP keys for locks without a breakaway a
feature are replaced when the locks are replaced.
Corrective steps which will be taken to avoid further violations:
- 1. Procedure 34IT-EOP-001-0S will be revised and issued by 12/30/94 to require that all keys be verified to open their designated locks. The verification will be required to be done during the annual audit of the EOP filing cabinets. It should be noted that this verification has been completed for 1994 by performance of the corrective actions previously discussed.
Date when full comoliante will be achievei Full compliance was achieved by 9/9/94 when the correct keys were placed on the EOP -
. key rings and all the EOP keys were verified to open the applicable locks.
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