ML20133G838
| ML20133G838 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 06/28/1985 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 1838N, NED-85-488, NUDOCS 8508090090 | |
| Download: ML20133G838 (3) | |
Text
Georgia Power Cortpany 333 P.edmont Avenue Atlanta. Georgia 30308
,q j
Telephone 404 5266526
,C, / / W/d 8 MaMng Address:
A Post Office Box 4545 Atranta. Georgta 30302 h
B5 m 9 A7:23 Georgia Power L T. Gucwa the sourtem emctnc system Manager Nuclear Engineenng and Cruef N; clear Engtneer NED-85-488 1
1838N June 28, 1985 U. S. Nuclear Regulatory Commission
REFERENCE:
Office of Inspection and Enforcement RII: RDW Region II - Suite 2900 50-321/50-366 101 Marietta Street, NW I&E Report Atlanta, Georgia 30323 85-12 ATTENTION: Dr. J. Nelson Grace Gentlemen:
Georgia Power Company hereby provides the following information in response to the alleged violations cited in NRC I&E Report 50-321, 366/85-12 dated May 31, 1985.
The subject violations were identified during the bRC inspection conducted at Plant Hatch by Mr. M.
F.
Runyan of your staff on April 29 to May 3, 1985.
VIOLATION 1:
10 'CFR 50 Appendix B,
Criterion XII, and the accepted QA program require that measures be established to assure that tools, gages, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits.
10 CFR 50 Appendix B, Criterion V, requires that activities affecting quality be prescribed by procedures appropriate to the circumstances which include quantitative or qualitative acceptance criteria.
Contrary to the above, measures have not been established to control the calibration of instruments in the maintenance shop in that procedures are inadequate to control this activity. FNP-6943, Calibration Check on precision Measuring Equipment, Revision 1,
does not provide environmental requirements, step-by-step instructions, or acceptance criteria for the calibration of micrometers, vernier calipers, depth gauges, and dial indicators.
Other calibration procedures and those currently under development are also potentially deficient.
This is a Severity Level IV violation (Supplement 1).
8500090090 850628 l
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Georgia Power d U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 2900 June 28, 1985 Page Two RESPONSE TO VIOLATION 1:
Admission or denial of alleged violation: The violation occurred.
Reason for Violation 1:
The failure to provide adequate calibration procedures in the maintenance tool shop is the result of oversight when establishing this program for the control and performance of these calibrations.
Corrective steps which have been taken and the results achieved:
Plant Hatch has initiated a prooram for review and assessment of all maintenance and administrative calibration procedures (including procedure HNP-6934) for environmental
- controls, step-by-step instructions, and acceptance criteria.
Additionally, data from tool vendors will be compiled in parallel with the procedure review to aid in the technical writing of calibration procedures.
Corrective steps which will be taken to avoid further violations:
The above review program and data compilation will be complete by August 23, 1985.
Those procedures requiring changes will be revised by December 13, 1985.
Date when full compliance will be achieved:
Full compliance will be achieved by December 13, 1985, when all necessary procedures will have been revised.
VIOLATION 2:
Unit 1
Technical Specification 1.0 (II) requires that periodic surveillance tests be performed within the specified surveillance interval which may be adjusted plus or minus 25 percent.
Contrary to the above, the licensee has established a surveillance test schedule which permits test performances to exceed the 25 percent extension.
The following examples are monthly tests required every 31 days not to exceed 38.75 days between performances.
Residual Heat Removal Pump Flow (LPCI Flow Switch) Test required by TS Table 4.2-5(7)
I was not performed from 1/7/85 to 2/20/85, or 44 days.
Main Steam Isolation Valve Closure Test, required by TS Table 4.1-1(10) was not performed from 7/26/84 to 9/5/84, or 41 days.
High Drywell Pressure Instrument Functional Test required by TS Table 4.1-1(5) was not performed from 1/3/85 to 2/12/85, or 40 days.
These examples are not all inclusive.
This is a Severity Level V violation (Supplement I).
This violation applies to thit 1 only.
e Georgia Power d U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 2900 June 28, 1985 Page Three RESPONSE TO VIOLATION 2:
Admission or denial of alleged violation: The violation occurred.
Reason for Violation 2:
The failure to comply with Unit 1 Technical Specifications surveillance test frequencies was a
result of misinterpretation of the Technical Specifications.
The Technical Specification surveillance program is set up to schedule the surveillance on the same day of each cycle.
In the past, the due date was not adjusted if the surveillance was performed plus or minus 25 percent of the surveillance interval with respect to the due date.
Corrective steps which have been taken and the results achieved:
The program database was adjusted to require Technical surveillance Specification surveillances be performed between the scheduled due date and the due date plus 25 percent of the surveillance interval. However, the latitude will still exist to perform surveillances earlier than the due date as implied by the Technical Specifications.
Correspondingly, the algorithm will make adjustments to the new due date.
This will ensure surveillances are parformed within the specified surveillance interval plus or minus 25 percent.
Corrective steps which will be taken to avoid further violations:
In addition to the above, procedure 40AC-REG 01, " Technical Specifications Surveillance Program", will be revised to remove the "minus 25 percent" reference.
The change to the procedure is being made in order to avoid j
potential misunderstanding of the intent of the procedure.
The procedure will be revised by October 18, 1985.
l Date when full compliance was achieved:
Full compliance was achieved on June 10, 1985 when the Surveillance Program Database was correctly adjusted.
Should you have any questions in this regard, please contact this office.
Sincerely yours, L. T. Gucwa MJB/mb xc:
J. T. Beckham, Jr.
H. C. Nix, Jr.
Senior Resident Inspector 1
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