ML20112G995
| ML20112G995 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 03/27/1985 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 1517N, NED-85-162, NUDOCS 8504020085 | |
| Download: ML20112G995 (7) | |
Text
Gecrgia Power Company 333 Piedmont Averue Atlanta, Georg>a 30308 Telepwe 404 5264526 Maiing Address:
Post Othce Box 4M5 Atlanta, Georgia 30302 g
Georgia Power L T. Gucwa the southern etectic sys:cm Manager Nuclear Engineenng ard Chief Nuclear Engineer ED-85 162 1517N March 27, 1985 U. S. Nuclear Regulatory Commission
REFERENCE:
Office of Inspection and Enforcement RII: JNG Region II - Suite 2900 50-321/50-366 101 Marietta Street, NW I&E Inspection Report Atlanta, Georgia 30323 85-02 ATTENTION: Dr. J. Nelson Grace GENTLEMEN:
Georgia Power Company (GPC) hereby provides the following information in response to the violations cited in NRC I&E Report No. 50-321/85-02 and 50-366/85-02 dated February 25, 1985.
The subject violations were identified during the MIC inspection conducted at Plant Hatch Units 1 and 2 l
by Mr. R. V. Crlenjak of your staff on December 21, 1984 - January 28, 1985.
VIOLATION 1:
Technical Specification 3.5.F.1.a Iequires the seven valves of the Automatic Depressurization System (ADS) be operable prior to startup from a cold shutdown.
Contrary to the above, one Automatic Depressurization System valve was not operable prior to startup from cold shutdown.. m the "B" valve, a States Block Link was open, thereby preventing the ADS signal from Ieaching the solenoid which operates the "B" ADS valve. The reactor was started with this valve not operational in the manual or ADS mode.
This is a Severity Level IV Violation (Supplement I) applicable to thit 1.
8504020005 050327
\\
PDR ADOCK 05000321 G
PDR (90 i i
Georgia Power d U. S. Nuclear RegulatoIy Commission Office of Inspection and Enforcement Region II - Suite 2900 March 27,1985 Page Two RESPONSE TO VIOLATION 1:
Admission or denial of alleged violation: The violation occurred.
Reason for the violation:
The Aur.omatic DepIessurization System (ADS) valve was made inoperative as a Iesult of a combination of personnel errors.
Responsible personnel did not properly perform system restoration for the "B" ADS valve per Data Package 2 of procedure HNP 1-6020.
The personnel who were initially working on the procedure data package were pulled off the job prior to its completion.
A separate worker Ieviewed the complete Maintenance Work Order (MWO) and signed off the procedure HNP-1-6020 data package, incorrectly assuming that the previous workers had finished the job and had failed to initial the required steps.
Another worker incorIectly assumed that completion of procedure HW 1-6020 met the performance requirements of the SRV functional test contained in p rocedule HNP-1-3902.
In fact, this j
functional test had not been pe rformed and it would not have been j
possible for the "B" SRV to function in the manual or ADS modes due to the open links. Additionally, the functional test for the SRVs which is required prior to startup was combined on the same MWO with the l
functional test required after startup.
The Plant Review Board (PRB) erroneously designated the entire functional test for the MWO to be performed after startup; theIefoIe,
procedure HP 1-3902 was not performed.
It should be noted that the "B"
SRV would have still functioned as a pressure relief valve.
Corrective steps which have been taken and the results achieved:
After a thorough investigation of the incioent, the links were closed, the system restored to normal alignment and functionally tested per proceduIe HW 1-3901 which requires the SRV to be cycled.
Responsible personnel Ieceived disciplinary action in the form of time off without pay.
In addition, a Management Directive was issued to maintenance personnel to clarify practices in the signing of completed procedures, and meetings with shift personnel were conducted to emphasize the importance of paying attention to detail and assuring compliance with procedures.
The PRB ' members responsible for the erroneous designation of the performance date for proceduIe HNP 1-3902 were given reprimands.
Corrective steps which will be taken to avolo further violations:
PIoceduIE HNP-1-6020 is Deing revised to include the actions in proceduIe HP 1-3902 so that whenever SRV maintenance is performed the functional test will also be performed as part of the procedure.
This Ievision will be completed by April 31, 1985, and will encompass Unit 2 changes also, l
700775
{
GeorgiaPower A U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 2900 MaIch 27, 1985 Page Three Date when full compliance was achieved: Full compliance was achieved on JanuaIy 13, 1985 when the subject safety relief valve was retumed to service after successful functional testing per proceduru hbp 1-3901.
VIOLATION 2:
Technical Specification 6.8.1 Iequires that writter pIocedures be established, implemented and maintained for safety-related activities.
Contrary to the above:
a.
Procedure M 1-6020, " Main Steam Relief Valves Maintenance", was not pIoperly implemented in that isolation links were left open which disabled the Manual and Automatic Depressurization System mode of one safety relief valve even though the procedure was signed off as complete.
Also the lifted wire and jumper tag was not removed when a link was closed.
b.
Procedure Fff 1-3902, " Safety Relief Valve Functional Test", was not implemented when Iequired by HPP 1-6020, " Main Steam Relief Valve Maintenance", and when Iequired as the functional test by the maintenance work oIder.
The Unit was critical at about 150 psi when the licensee realized this procedure was not complete.
c.
Procedure hbp-1-3820, " Safety / Relief Valve Position, Primary and Secondary, Indicators Functional Test and Calibration", was not properly maintained in that the incoIporation of a Design Change Request was not complete, resulting in an inadvertent initiation of Low Low Set logic and attendant actuation of a safety relief valve.
This is a Severity Level IV Violation (Supplement I) applicable to Lnit 1.
RESPONSE TO VIOLATION 2a:
Admission or denial of alleged violation:
The violation occurred.
Reason for the violation:
PIoceduIe HtP-1-6020 was not properly implemented as a Iesult of personnel errors resulting from inadequate attention to detail.
See the response for Violation 1 above for details.
Additionally, personnel did not comply with proceduIe HtP-504 (Lifted Wire and TemporaIy Jumper Procedure) in that the liftec wiIe and jumper tags were not removed when the links for the "H" SRV were closed upon completion of the Ieauired portion of proceduIe HtP 1-6020.
'*m
l Georgia Power d -
U. S. Nuclear Regulatory Commission -
Office of Inspection and Enforcement Region II - Suite 2900 March 27, 1985 Page Four RESPONSE TO VIOLATION 2a (continued):
Corrective steps which have been taken and the results achieved:
See corrective actions for Violation 1 above.
In addition to those actions, the subject lifted wire and jumper tags were removed per procedure HW-504.
Corrective steps which will be taken to avoid further violations:
The above corrective steps for Violation 2a are sufficient to prevent Iecurrence.
Date when full compliance was achieved: Full compliance was achieved on JanuaIy 13,. 1985 when the tags were removed per proceduIe HNP-504, procedure HNP 1-6020 was completed, and the SRVs were satisfactorily tested by performing procedure HP 1-3901.
RESPONSE TO VIOLATION 2b:
Admission or denial of alleged violation: The violation occurred.
Reason for the violation:
As noted in the reason for Violation 1, above, procedure HW-1-3902 was not implemented as a result of personnel failing to properly implement proceduIe HP 1-6020 and the PRB failing to properly categorize the functional test portion of the MWO.
Corrective steps which have been taken and the results achieved:
See corIective actions for Violation 1 above.
Corrective steps which will be taken to avoid further violations:
The aDove corrective actions for violation 1 are surricient to prevent Iecurrence.
Date when full compliance was achieved:
Full compliance was achieved en January 13, 1985 when the SRVs were satisfactorily tested by performing procedure HP 1-3901.
. RESPONSE TO VIOLATION 2c:
Admission or denial of alleged violation: The violation occurred.
Reason for the violation:
The incomplete incorporation of Design Change Request (DCR)83-138 in procedure HNP-1-3820 was the result of personnel e rro r.
Personnel failed to comply with procedure HP-809 (Plant Mndifications Approval and Implementation) which states that the responsible department must modify procedures affected as a result of a plant modification.
700775
GeorgiaPower b U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement 1
Region II - Suite 2900 March 27,1985 Page Five RESPONSE TO VIOLATION 2c (continued):
Corrective steps which have been taken and the results achieved:
PIoceduIe HNP-1-3820 was immediately revised to reflect DCR 83-138.
Two departments conducted a joint sampling of procedures which are usually affected by DCRs and determined that the problem was not systematic.
The individual that failed to identify the required change to the procedure was instructed on the importance of fully implementing DCRs.
Corrective steps which will be taken to avoid further violations:
The above actions are sufficient to prevent Iecurrence.
Date when full compliance was achieved:
Full compliance was achieved en FebIuary 2, 1985 when procedure HtF-1-3820 was revised to reflect DCR 81 138.
VIOLATION 3:
Technical Specification:
a.
Table 4.3.21, Trip Function item 1.d, Iequires that the Main Steam Line Tunnel Temperature-High receive a channel functional test monthly.
Contrary to the above, the monthly Main Steam Line Tunnel Temperature-High was not performed on a monthly basis.
This surveillance had been an 18-month surveillance prior to Technical Specification Amendment No. 39 which changed it to monthly.
Two monthly surveillances were missed.
b.
Table 4.3.6.4 1, Instrument items 1 and 2,
required that the Reactor Vessel Pressure Instrumentation (2821-R623 A88) and the Reactor Vessel Water Level Instrumentation (2821-R610, R615) receive a quarterly channel calibration.
Contrary to the ~above, due to an improper procedure change which changed the surveillance frequency from quarterly to every 18 months, the quarterly channel calibration for the Reactor Vessel PIessure Instrumentation (2821-R623 A, B) was not performed for the period from receipt of Amendment No. 39 to Unit 2 Technical Specifications (approximately JJne 1984) until November 1984.
The above is also the case for the Reactor Vessel Shroud Water Level Instrumentation (2BRl-R610, R615).
This is a Severity Level IV Violation (Supplement I) applicable to Unit 2.
Georgia Power d '
U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region'II - Suite 2900 March 27,1985 Page Six RESPONSE TO VIOLATION 3:
Admission or denial of alleged violation: The violation occurred.
Reason for 'the violation:
The ~ surveillance tests for Table 4.3.2-1, Trip Function item Id; and Table 4.3.6.4 1, Instrument items 1 and 2 were missed as a result of personnel errors involving incorrect incorporation of testing frequency changes Iequired by Amendment No. 39
- to the Unit 2 Technical Specifications.
The individual Insponsible for surveillancs scheduling failed to adjust the frequency in the surveillance program for the Main Steam Line Tunnel Tenperature-High instrumentation.
The personnel responsible for the surveillance procedures, for the Reactor Vessel Fressure and Water Level
. Instrunentation haa changed all of the surveillance frequencies for these instruments from a quarterly to an 18-month inteIval. This was an improper change as the instrumentation in question was nct affected by Amendment No. 39 and therefore, the applicable surveillence intervals should not have been changed.
- Corrective steps which have teen taken and the results achieved:
Upon discoveIy or the surveillance scheduling erIDIs ano Iesultant - missed surveillance, the proper personnel were notified and the surveillances performed that same day.
The computerized surveillance progmm which is used by plant personnel to track and perform instrument testing within the time intervals ~ required by. Technical Specificaticns has been corrected.
Plant personnel have completed an initial Ieview of the Technical Specification Surveillance Scheduling PIogram to ensure. the existence of procedures to perform each surveillance and that they meet the frecuency reauirements.
No further frequency problems have been found.
The individual Iesponsible for surveillance scheduling and the supervisor responsible for ensuring that the surveillance proceoures are properly Ievised were given Ieprimands.
The personnel responsible for improperly changing the surveillance procedure were inst:aacted on the importance of properly implementing-Technical Specification changes.
i-d M'!L
r GeorgiaPower d U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 2900 March 27,1985 Page Seven RESPONSE TO VIOLATION 3 (continued):
Corrective steps which will be taken to avoid further violations:
The corrections made to the computerized surveillance program ensure that instrument testing Iecutred by Technical Specifications will be performed in a timely manner in the future.
PIoceduIe HNP-2-3173 has been revised and procedure HW-2-3170 will be revised by April 22, 1985.
In
- addition, the - administrative procedure governing the surveillance tracking program will be revised by June 30, 1985 to require independent verification of all scheduling changes.
There are interim measures in effect to central this evolution now.
A more in depth review of the the Surveillance Scheduling Program is currently being performed by an outside contractor to check the applicable surveillance procedures to ensure that the surveillance Iequirements are consistent with the Technical Specifications and the surveillance data base.
Site Quality Assurance is alsa providing audit services in this a rea.
Corrective action for any possible discrepancies will be determined following review of the results of audits in this area.
Reportable deficiencies determined from the above audits will be submitted as per Licensee Event Report 50-366/1984-30.
Date when full compliance was achieved,:
Full compliance was achieved on November 29, 1984 when the enannel functional test and channel calibrations for the surveillances in question were performed satisfactorily and the Amendment No. 39 changes were properly made.
Should you have any questions in this mgard, please contact this office.
Very truly yours, lf W L. T. Gucwa CBS/mb xc:
J. T. Beckham, Jr.
H. C. Nix, Jr.
Senior Resident Inspector 700775