ML20127L424
| 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: |
| References | |
| NUDOCS 8505220338 | |
| Download: ML20127L424 (1) | |
See also: IR 05000321/1985002
Text
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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
bec: NRC Resident Inspector
'
Hugh S. Jordan, Executive Secretary
Document Control Desk
i
State of Georgia
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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.
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U. S. Nuclear Regulatory Commission
Office of Inspection ano Enforcement
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
Valve was made inoperaEIve as a result of a combinatien of personnel
i
errors.
Responsible
personnel
did
not
properly
perform
system
'
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
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
l
functional test contained in procedure HNP-1-3902.
In fact, this
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.
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U. S. Nuclear Regulatory Commission
Office of Inspection and Enforcement
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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:
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
" Main Steam Relief
not implemented when requized by HW-1-.6020
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.
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Office of Inspection and Enforcement
Region II - Suite 2900
March 27,1985
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Page Four
RESPONSE TO VIOLATION 2a (continueo):
See
Corrective _ steps which have been _taken_ and the results achieved:
corrective actions for Violation 1 above.
In adoition to those actions,
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
'
January 13, 1965 wnen ene tags were removed per proceduIe HNP-504,
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procedure HNP-1-6020 was ccmpleted, and the STC were satisfactorily
,
tested by performing pIccedure HP-1-3901.
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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
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failing to properly implement procedure HP-1-6020 and the PRB failing
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to properly categorize the functional test portion of the PWO.
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Corrective steps which have been taken and the results achieved:
4
corrective actions for violation 1 above.
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-
Corrective steps _ which will be taken to _avolo further violations:
d
above corrective actions ror violation 1 are surricient to prevent
recurrence.
2
Full compliance was achieved on
Date when full compliance was achieved:
'
when the SRVs weIe satisfactorily tested by performing
4
January 13, 1985
procedure HP 1-3901.
i
RESPONSE T0_ VIOLATION 2c:
Admission or denial of alleged violaticn: The violation occurred.
3
The incomplete incorporation of Design Change
,
Reason for the violation:
Recuest (DCR)83-138 in procedure HNP-1-3820 was the result of personnel
-
erIo r.
Personnel failed to comply with procedure HP-809
(Plant
3
Modifications Approval and
Implementation)
which states
that
the
responsible department must modify procedures affected as a result of a
,
plant mooification.
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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).
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This is a Severity Level .IV Violation (Supplement I) applicable to
imit 2.
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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.
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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
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Technical . Specification Surveillance Scheduling Program to ensure the ~
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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.
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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
calibrations
for
the
surveillances
in
cuestion
were
performed
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,
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L. T. Gucwa
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CBS/mb
xc:
J. T. Beckham, Jr.
H. C. Nix, Jr.
Senior Resident Inspector
. . . .