ML20087M320
| ML20087M320 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 03/01/1984 |
| From: | Beckham J GEORGIA POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20087M319 | List: |
| References | |
| NUDOCS 8403290194 | |
| Download: ML20087M320 (6) | |
Text
e George Power Corrpany 333 Pedmont Avenue Attanta, Georg a 30308 Telephone 404 526-iO20 Malng Address' Post Of' ice Box 4545 Attanta. Gecrg a 30302 0%Om 8'l MM 5
,y*.yarch1,1984 h
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J. T. Beckham, Jr.
Vice President and General Manager Nuclear Generation Office of Inspection and Enforcement Attention: Mr. J.P. O'Reilly, Region Mministrator U.S. Nuclear Regulatory Canission Region II 101 Marietta Street, N.W.
Atlanta, Georgia 30303 NRC DOCIGTS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HA'ICH NUCLEAR PIANT UNITS 1, 2 Response To I&E Inspection Report 50-321/83-25 and 50-366/83-26 Gentleen:
Georgia Power Cmpany provides the following response to violations identified during an inspection conducted on July 21 - August 20, 1983, and reported by your letter of February 1, 1984.
VIOLATION 1:_
Criterion XIV of Appendix "B" to 10 CFR Part 50 as impleented by Hatch Unit 2 FSAR Chapter 17.2.14 rquires 'in part that measures shall be established for indicating the operating status of structures, systes and cmponents to prevent inadvertent operation.
Technical Specification E.8.1.a rquires that written procedures be established, impleented and maintained covering the applicable procedures recanended in Appendix "A" of Regulatory Guide 1.33 Revision 2, February 1978.
Contrary to the above, during the period fra July. 12-25, 1983, after Unit 2 had returned to power following an extended refueling outage, it was found that safety related equipnent and systes were not aligned as rq uired by approved operating or surveillance procedures to assure safe operation under all conditions.
Specifically, through inadquacies in the administrative and managerial control systes, prerq uisites for startup did not confirm that necessary instrments were operable, valves properly aligned, and-electrical links in the correct positions.
Exmples where this lack of proper confirmation existed were:
8403290194 840315 PDR ADOCK 05000366 G
GeorgiaPower d Attention: Mr. J.P. O'Reilly Region II March 1, 1984 Page 'IWo a.
The Anticipated Transient Without Scram (A' INS) trip was found to have a valve shut which isolated the redundant signal to each trip systen.
b.
Jet ptups Nos.18 and 19 were found to have flow instrtmentation isolated.
c.
The Standby IJguid Control Systen was found to have the pump discharge pressure instrtmentation isolated.
d.
The High Pressure Injection Systen was found to have the autanatic shut feature of the minimtsn flow valve electrically isolated.
e.
The "B" bydrogen Reconbiner, was found to have the "B" recombiner discharge valve improperly shut.
his is a Severity Ievel IV Violation (Supplanent I).
RESPONSE
Adnission or Denial of Alleged Violation:
W e violation occurred.
Reason for the Violation: % e violation occurred because administrative controls failed to ensure independet verification of valves and links following maintenance, modification, surveillance, calibration or trouble shooting. Further, the adninistrative controls were unclear in defisaing how independent verification was to be done.
Corrective Steps Which Have Been Taken and the Results Achieved:
Fran July 28, 1983 to July 31, 1983 "a mispositioned link inspection and evaluation program" was performed by the Quality Control and Engineering i-Departments. %e inspection and evaluation involved control roan panels and safety related local panels.
The inspection was conducted on an around the clock basis for most of the period.
As each deviation was identified, equipnent was restored to proper operation and an engineering analysis of potentially degraded modes of operation was 1
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f Attention: Mr. J.P. O'Reilly Region II March 1, 1984 Page %ree s
made.
%e mispositioned links inspection and evaluation report was issued to the Plant Hatch General Manager on August -1, 1983.
%e purpose of this report was to doctment the results of the control roca and local panel inspection.
i Due to preliminary findings of the initial control rocun investigation, the inspection was expanded on July 28, 1983 to include accessible instrument valves and valves that have locked position requirements. -
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%ese valves were checked for proper valve position, secured and labled per the instructions of Standing Order 83-33 issued on July 28, 1983.
Maintenance Requests (MR) issued to control work during - the Unit 2 outage and to perform functional tests on Unit 2 outage Design Change I
Requests (DCR's) were reviewed.
%is review was to determine the adequacy of the MR instructions for installation of equipnent and systen restoration after plant modification. %is review was to also identify '
l any other potential mispositioned valves or links.
i j
Temporary additional security measures were taken until the Plant Review Board determined that insufficient evidence existed to suggest that j
intentional mispositioning of valves and. links was involved.
Until the.
I determination was made, access was limited to Georgia Power Company and Georgia Power Ocupany escorted _ personnel. - Also,. additional security' patrols were established, -the corporate manager of security' was l-notified, and corporate investigators were put on alert.
}
On July 28, 1983, the Plant Review Board (PRB) and Safety Review Board i-(SRB) met at Plant Hatch to review the open links and mispositioned 1
valve situation.- -%e purpose of the meeting was to make a determination of plant status and to determine the adstuacy of corrective actions.
Also, on July 28,1983 a special, independent ccmunittee was established j
to investigate the mispositioned valves and misaligned terminal strip links at Plant Hatch. - On August 1,1983 the ccmunittee issued -its report to the Vice President and General Manager of Nuclear Generation. Among its findings-were the reccmunendations. - to clarify how independent verification was to be done, to instruct personnel regarding.independait verification and procedure compliance, and to review and upgrade certain i
procedures.-
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t GeorgiaPower d Attention: m, J.P. O'Reilly Region II March 1, 1984 Page Four On August 10, 1983, an enforement conference was held between ;PC and the NRC.
GPC presented the results of its investigation regarding the extent of the proble.
GPC also presented the actions that were being taken to prevent further occurrence of this proble.
The NRC concurred with these actions.
Corrective Steps hhich Will Be Taken to Avoid Ebture Violations:
Existing administrative controls were upgraded to stress indeperdent verification for the restoration of any safety-related cmponents that are placed in an off-normal condition.
Specifically, " Lifted Wire and Teporary Japer Control", HNP-504, was revised September 15, 1983 to require its use whenever specific steps in procedures and tests do not restore links, or when " Red Line" procedures are not used.
A new procedure, HNP-514, " Control of Incked Valves", was approved on August 30, 1983.
Also, HNP-34, " Rules for - Performing Procedures", regarding procedure empliance was re-sphasized to plant personnel via a training directive empleted on July 28, 1983.
Adninistrative controls were strengthened to ensure that when work is interrupted, the condition of the plant is identified and accounted for prior to declaring systeas operable.
Syste restoration is being sphasized in Operations, Maintenance, Quality Assurance and Quality Control training progras.
By Septaber 15, 1983, valve lineup procedures were revised to ensure proper valve positioning.
Date hten Full Cmpliance Was Achieved: Full cmpliance was achieved on September 15, 1983 when administrative controls were strengthened and identified probles were corrected.
VIOIATION 2:
Technical Specification 3.0.4 requires that entry into an Operational Condition shall not be made unless the conditions of the Limiting Condition for Operations are met without reliance on provisions i
contained in the Action Statments unless otherwise excepted.
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Georgia Power d Attention: Mr. J.P. O'Reilly Region II March 1, 1984 Page Five Technical Specification 3.6.1.4 requires that two main stem isolation leakage control system subsystes shall oe operable in operational conditions 1, 2, and 3.
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Contrary to the above, on July 12, 1983, the Unit entered Operational Condition 1, Power Operation, without meeting the Limiting Condition For Operation for the main stem isolation leakage control systs subsysts in that both subsystems were inoperable.
Tt is a Severity Level IV Violation (Suppleent 1).
RESPONSE
Admission or Denial of Alleged ViolationL W e violation occurred.
Reason for the Violation:
During the Unit 2 outage, work on Design Change Rquest (DCR)81-139 was started. We DCR work required the 2E32 tranm itters to be changed frm Rossount to Bartens.
With the transmitters out of service and sme wiring changes already empleted, the decision was made to discontinue the Barton installation and restore the Rossount instrments. GE was notified to restore the systs to its original design.
Maintenance was not notified to
" Redline" the Rossount reinstallation.
'IVelve electrical links that were used to isolate the transmitters for replacment were not reclosed after the Rossounts were reinstalled. A Maintenance Request (MR) had been issued to redline the DCR wiring when the DCR work was empleted but, because all the DCR work had not been cmpleted prior to Unit startup, the MR rquiring redlining was not performed.
The Lifted Wire and Teporary Jumper Procedure (HNP-504) was not used to docment the opening of the 12 electrical links.
Corrective Steps Which Have Been Taken and the Results Achieved: % e 12 open electrical links were closed.
Additional corrective action, as detailed in response to VIOLATION 1, was also performed.
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GeorgiaPower d Attention: Mr. J.P. O'Reilly Region II March 1, 1984 Page Six Corrective Steps Which Will Be Taken to Avoid Future Violations:
On Septenber 15, 1983, the " Lifted Wire and Ter.porary Jmper Control" procedure was revised to require its use whenever specific steps in procedures or tests do not restore links, or when " Red Line" procedures are not used.
Date When Full Cmpliance Was Achieved:
Full c m pliance was achieved on July 27,1983 when the 12 open electrical links were discovered and closed.
'Ihis cmpletes GPC's response to IER 50-321/83-25 and 50-366/83-26.
If you have any questions regarding this response or rsluire further information regarding our actions in this matter, please contact this office.
Very Truly Yours, h
YSf
.T. Beckham, Jr.
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