ML20127L424

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-321/85-02 & 50-366/85-02

ML20127L424
Person / Time
Site:	Hatch
Issue date:	04/10/1985
From:	Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Kelly R GEORGIA POWER CO.
Shared Package
ML20127L428	List: IR 05000321/1985002 ML20127L424 ML20127L431 ML20127L440
References
NUDOCS 8505220338
Download: ML20127L424 (1)

See also: IR 05000321/1985002

Text

--

(406 a.\

'

.

APR 101985

Georgia Power Company

ATTN: Mr. R. J. Kelly

Executive Vice President

P. O. Box 4545

Atlanta, GA 30302

Gentlemen:

SUBJECT: REPORT NOS. 50-321/85-02 AND 50-366/85-02

Thank you for your response of March 27, 1985, to our Notice of Violation issued

on February 25, 1985, concerning activities conducted at your Hatch facility. We

have evaluated your response and found that it meets the requirements of 10 CFR

2.201. We will examine the implementation of your corrective actions during

future inspections.

We appreciate your cooperation in this matter.

Sincerely,

m D nd E *aRath'

SA Roger D. Walker, Director

Division of Reactor Projects

cc: J. T. Beckhaai, Vice President and

General Manager-Nuclear Operation

H. C. Nix, Site General Manager

P. E. Fornel, Site QA Supervisor

L. Gucwa, Chief, Nuclear Engineer

i

bec: NRC Resident Inspector '

Hugh S. Jordan, Executive Secretary

Document Control Desk i

State of Georgia I

.

l

hbk $Doh [

G

i

!

RII RII RII RII

!, k

.-SNi rth:Jw

W$

RCarroll

<W

VPancidra

V

VBr niee

4/of/85 4/f/85 4/ 7 /85 4/g/85

.. - __

h

e

760/__ .

-

2

,

#

'd 90: Pt

98/ro/po.,H3gH 41 *s

5  %

,

\ Scorpa Power CcmCaey '

333,Secracnt Aveat.e

Allarite. C(O'; a J.0308 *

s

. Telecter. 404 5 64526

VaV Accrets

• W cdce 8:4 4.u]

Ran'a. G+org a 20302

GeorgiaPower

" =='e sr='"'

hld*L.., e y.e,,n,

aro cm..c.ar :i c rey .

ED-85 162

1517N

March 27, 1985

U. S. Nuclear Regulatory cor:vnission REFERENCE:

Office of Inspection and Enforcement RII: JNG

Region II - Suite 2900 50-321/50-366

101 Marietta Street, NW I6E Inspection Report

Atlanta, Georgia 30323 85-02

ATTENTION: Dr. J. Nelson Grace

GENTLEMEN:

Georgia Power Company (GPC) bereby provides the following information in

response to the violations cited in NRC IdE RepoIt No. 50-321/85-02 and

50-366/85-02 dated February 25, 1985.. The subject violations were

identified during the MIC inspection concucted at Plant Hatch Units 1 ano 2

by Mr. R. V. Crlenjak of your staff on December 21, 1984 - January 28, 1985.

VIOLATION 1:

Technical Specification 3.5.F.1.a requires 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 shutoown. On the "B" valve, a ,

States Block Link was open, thereby preventing the ADS signal from l

zeaching 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

Unit 1.

1

I

- S L ? WWC F -

un j ,y y ~

7 PP-

• c *d LO:Pi 58/tO/t0 . . HD10H.*dSNI *S3M WOdd

' .

l ,

g

'

,

t .

GeorgiaPower A

U. S. Nuclear Regulatory Commission

Office of Inspection ano Enforcement l

Region II - Suite 2900

MeIch 27, 1985

Page Two

RESPONSE TO VIOLATION 1:

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

l Reason for the violation: The Automatic Depressurization System (ADS) l

l

Valve was made inoperaEIve as a result of a combinatien of personnel i

'

errors. Responsible personnel did not properly perform system i

Iestoration for the "B" ADS valve per Data Package 2 of procedure

HP -1-6020. The personnel who were initially working on the proceduIe

data package were pulled off the job prior to its completion. A

i

separate worker reviewed the complete Maintenance Work Order (MWO) and

signed off the proceduIt HNP-1-6020 data package, incorrectly assuming

that the previous workers had finished the job and had failed to initial

the requireo steps. Another worker incorrectly assumed that completion

of procedure HP-1-6020 met the performance Iequirements of the SRV

functional test contained in procedure HNP-1-3902. In fact, this

.

l

functional test had not been performed and it would not have been

possible for the "B" SRV to function in the manual or ADS modes due to

the open links. Adoitionally, the functional test for the SRVs which is

recuired prior to startup was combined on the same MWO with the

functional test requireo after startup. The Plant Review Board (PRB)

erroneously designated the entire functional test for the MWO to be

performed after startup; therefaze procedure HW J -3902 was not

performed. It should be noted thab the "B" SRV vould have still

functioned as a pressure relief valve.

! Corrective steps which have been taken and the results achieved: After

l a thorough investigation of the incioent, the links were closed, the

'

system Iestored to normal alignment and functionally tested per

proceoure HW 1-3901 which requires the SRV to be cycled. Responsible

personnel receiveo 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 p:acedures,

and meetings with shift personnel were conducted to emphasize the

importance of payi g attention to detail and assuring compliance with

procedures. The PdB ' members responsible for the erroneous designation

of the performance date for procedure HNP-1-3902 were given Ieprimands.

Corrective steps which will be taken to avolo further violations:

PIUceoure HW-1-602u is ceing Ieviseo to incluoe tne actions in

pIcceoure HP-1-3902 so that whenever SRV maintenance is performed the

functional test will also be performed as part of the procedure. This

revision will be completed by April 31, 1985, and will encompass Unit 2

changes also.

exw . - - - , . - .

. P *d 80:P! G8/PO/7Q . H310H *dSNI 'S38 WOdd! '

'

. ,

,

. \

.

.

- Georgia Power A

U. S. Nuclear Regulatory Commission

,

Office of Inspection and Enforcement

Region II - Suite 2900

, March 27, 1985

Page Three

l

Date when full como11ance was achieved: Full compliance was achieved on

January 13, 1985 when the subject safety relief valve was returned to

service after successful functional testing per procedure HNP-1-3901.

VIOLATION 2:

Technical Specification 6.8.1 requires that written procedures be

established, implemented and maintained for safety-related activities.

Contrary to the above:

a. PIocedure M 1-6020, " Main Steam Relief Valves Maintenance", was

not properly implemented in that isolation links were left open

which disabled the Manual and Automatic Depressurization System

moce 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 M-1-3902, " Safety Relief Valve Functional Test", was

not implemented when requized by HW-1-.6020 " Main Steam Relief

Valve Maintenance", and when required as the functional test by the

maintenance work order. The Unit was critical at about 150 psi

when the licensee realized this procedure was not complete.

c. Procedure HW-1-3820, " Safety / Relief Valve Position, Primary and

Secondary, Indicators Functional Test and Calibration", was not

preparly maintained in that the incorporation 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

Unit 1.

RESPONSE TO VIOLATION 28:

Admission o_r denial of alleged violation: The violatinn occurred.

Reason for the violation: Procedure HFP-1-6020 was not properly

implementco as a result 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 HNP-504

(Lifted Wire and TemporaIy Jumper Procedure) in that the liftec wire and

jumper tags were not removed when the links for the "H" SRV were closed

upon completion of the recuired portion of procedure HW 1-6020.

700775

' 9 'd 60 PI 98/Po/WO HDiOH 'dSNI 'S38 WONd

.

B

,

• -

,.

GeorgiaPower d

U. S. Maclear Regulatory Commission

Office of Inspection and Enforcement

Region II - Suite 2900

March 27,1985 M

Page Four

RESPONSE TO VIOLATION 2a (continueo):

See

Corrective _ steps which have been _taken_ and the results achieved:

In adoition to those actions,

corrective actions for Violation 1 above.

the subject lifted wire and jumper tags were removed per pmcedure

HP-504.

The

Corrective steos which will be taken to avoid further violations:

above corrective steps for violation 2a are sufficient to prevent

recurrence.

Date when full como11ance was achieved: Full compliance was achieved on g

'

January 13, 1965 wnen ene tags were removed per proceduIe HNP-504, ,

procedure HNP-1-6020 was ccmpleted, and the STC were satisfactorily

tested by performing pIccedure HP-1-3901. f

-a

RESPONSE TO VIOLATION %: ]

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

Reason for the violation: As noted in the reason for Violation 1, d--

above, proceouIe HP-1-3902 was not implemented as a result of personnel -

failing to properly implement procedure HP-1-6020 and the PRB failing 3

_

to properly categorize the functional test portion of the PWO. =

Corrective steps which have been taken and the results achieved: See q

4

corrective actions for violation 1 above. -s

The

-

Corrective steps _ which will be taken to _avolo further violations: d

above corrective actions ror violation 1 are surricient to prevent  ;

recurrence. 2

Date when full compliance was achieved: Full compliance was achieved on '

January 13, 1985 when the SRVs weIe satisfactorily tested by performing 4

procedure HP 1-3901. i

RESPONSE T0_ VIOLATION 2c:

3

Admission or denial of alleged violaticn: The violation occurred.

The incomplete incorporation of Design Change ,

Reason for the violation: -

Recuest (DCR)83-138 in procedure HNP-1-3820 was the result of personnel

Personnel failed to comply with procedure HP-809 (Plant 3

erIo r.

Modifications Approval and Implementation) which states that the

,

responsible department must modify procedures affected as a result of a

plant mooification.  ;

- - - - - - - . _ . . . . _ ,,,

-- . ._ __

,

j. , ,

S 'd OI:Pt G8/P0/f 0* 'H010H *dSNI 'S38 WOdd

..

9

- 0-

GeorgiaPbwerA

U. 5. Nuclear Regulatory Commission

Office of Inspection and Enforcement

Region II - Suite 2900

March 27, 1985

Page Five

RESPONSE TO VIOLATION 2c (continued):

Corrective steps which _have been taken_ and the results achieveo:

Procecure hep-1-3820 was immediately revised to zerlect OCR 83-136. 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 reouizeo enange to the

procedure was instructed on the importance of fully implementing DCRs.

Corrective steps which will be taken to avoid further violations: The

aDove actions are surricient to prevent recurrence.

Date when full compliance was achieved: Full compliance was achieved on

FeDruaIy 2, 1985 wnen proceoure HW-1-3820 was reviseo to reflect DCR

81 138.

VIOLATION 3:

Technical Specification:

a'. Table 4.3.2-1, Trip Function item 1.d, requires that the Main Steam

Line Tunnel Temperature-High Inceive 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

l surveillance had been an 18-month surveillance prior to Technical

l 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, zequired that the

Reactor Vessel Pressure Instrumentation (2921-R623 AaB) and the

l Reactor Vessel Water Level Instrumentation (2821-8610, R615)

l receive a quarterly channel calibration.

Contzury to the above, due to en improper procedure change which

changed the surveillance frecuency from quarterly to every 18

months, the quarterly channel calibration for the Reactor Vessel,

Pressure Instrumentation (2821-R623 A, 8) was not performed for the

period from receipt of Amendment No. 39 to LFlit 2 Technical

l- Specifications (approximately June 1984) until November 1984. The

l aoove is also the case for the Reactor Vessel Shroud Water Level

L Instrunentation (2BRl-R610, R615).

L This is a Severity Level .IV Violation (Supplement I) applicable to

imit 2.

1

, , ,

s u - -e <& -

.

-

,

O

Georgia Power d

U. S. Nuclear Regulatory Commission

Office of Inspection and Enforcement

Region II - Suite 2900

March 27,1985

Page Five

RESPONSE TO VIOLATION 2c (continued):

Corrective steps which have been taken and the results achieveo:

Procecure HNP-1-3820 was immediately reviseo to zerlect 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 recuired change to the

procedure was instzucted on the importance of fully implementing DCRs.

Co_rrect_ive steps which will be taken to avoid further violations: The

above actions are sufficient to prevent recurzence.

Date _when full compliance was achieved: Full compliance was achieved on

FebIuary 2, L985 wnen procedure HW-1-3820 was revised to reflect DCR

81 138.

VIOLATION _3:

Technical Specification:

a. Table 4.3.2-1, Trip Function item 1.d, requires that the Main Steam

'

Line Tunnel Temperature-High Inceive 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, zequired that the

Reactor Vessel Pressure Instrumentation (2821-R623 AaB) and the

Reactor Vessel Water Level Instrurentation (2821-R610, R615)

receive a quarterly channel calibration.

Contrazy to the above, due to an improper procedure change which

changed the surveillance frequency fIom cuarterly to every 18

months, the Quarterly channel calibration for the Reactor Vessel.

Pressure Instrumentation (2B21-R623 A, 8) was not performed for the

period from zeceipt of Amendment No. 39 to leit 2 Technical

ifications (approximately June 1984) until November 1984. The

ve is also the case for the Reactor Vessel Shroud Water Level

Instrumentation (2BRl-R610, R615).

This is a Severity Level IV Violation (Supplement I) arplicable to

Unit 2.

mm.

1

. ,. ,

L 'd of:PI S8/Po/fo' HD10H 'dSN! 'S38 Wodd

.= .

.

.

GeorgiaPowerA

'

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 allegea violation: The violation occurred.

Reason for the violation: The surveillance tests for Table 4.3 2-1,

Trip Function Item Ad; and Table 4.3.6.4 1, Instzument items 1 and 2

were- missed as a result of personnel errors involving incorrect

incorporation of testing frequency changes required by Amendment No. 39

to the Unit 2 Technical Specifications. The individual responsible for

surveillance scheduling failed to adjust the frequency in the

suzveillance program for the Main Steam Line Tunnel Temperature-High

instzumentation. The personnel responsible for the suzveillance

proceouzes for the Reactor Vessel Pressure and Water Level

Instrumentation hao changed all of the surveillance frecuencies for

these instruments from a quarterly to an 18. month interval. This was an

,_ improper change as the instrumentation in question was not affected by

,

Amendment No. 39 and therefore, the applicable surveillance intervals

should not have been changer.

Corrective- steps which have_ been taken and the results achieved: Upon

ciscovery or tne surveillance scheduling errors ano zesultant missed

l- surveillance, the proper personnel were notified and the surveillances

performed that same day. The computerized surveillance progxam which is

useo by plant personnel to track and perform instrument testing within

the time intezvals required by Technical Specifications has been

corrected. Plant personnel have completed an initial review of the

'

E Technical . Specification Surveillance Scheduling Program to ensure the ~

J existence of procedures to perform each surveillance and that they meet

the frecuency requirements. No further frequency problems have been

found. The individual responsible for surveillance scheduling and the

supervisor responsible for ensuring that the surveillance proceoures are

properly zevised were given zeprimands. The personnel zesponsible for

impzoperly changing the surveillance procedure were instructed on the

importance of properly implementing Technical Specification changes.

i

,.

,

o.

, 8 ' d 4010L 8 'd II:Pt G8/P0/P0 H310H *dSNI 'S3d WOdd

s .. ,

,

4

.

,

.

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 computerizeo survelliance pIugzam ensure that

instrument testing recuired by Technical Specifications will be

performed in a timely manner in the future. PzaceduIt HNP-2-3173 has

been revised and proceduIe HNP-2-3170 will be revised by April 22,

1985. In addition, the administrative procedure governing the

surveillance tracking program will be reviseo by June 30, 1985 to

recuire independent verification of all scheculing changes. There are

interim measures in effect to control this evolution now. A more in

depth review of the the Surveillance Scheduling PIUgram is currently

being performeo by an outside contractor to check the applicable

surveillance procedures to ensure that the surveillance requirements are

consistent with the Technical Specificaticos and the surve111ance data

base. Site Quality Assurance is also providing audit services in this

area. Corrective action for any possible discrepancies will be

determined following zeview of the results of audits in this a rea.

Reportable deficiencies determineo 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 channel functional test and channel

were performed

calibrations for the surveillances in cuestion

satisfactorily and the Amendment No. 39 changes were properly made.

Should you have any questions in this regard, please contact this office.

Very truly yours,

'

/ *f" Q22

. L. T. Gucwa

CBS/mb

xc: J. T. Beckham, Jr.

H. C. Nix, Jr.

Senior Resident Inspector

. . . .