ML20134M280

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Responds to NRC Re Violations Noted in Insp Rept 50-366/85-18.Corrective Actions:Drywell Pneumatic Sys Procedures Will Be Revised by 851004 to Establish Instructions for Swapping Pneumatic Medium
ML20134M280
Person / Time
Site: Hatch 
Issue date: 08/23/1985
From: Gucwa L
GEORGIA POWER CO.
To: Grace J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
2005N, NED-85-598, NUDOCS 8509040064
Download: ML20134M280 (4)


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REFERENCE:

Office of Inspection and Enforcement RII: RDW Region II - Suite 2900 50-366 101 Marietta Street, NW Inspection Report Atlanta, Georgia 30323 85-18 ATTENTION: Dr. J. Nelson Grace Gentlemen:

Georgia Power Company (GPC) submits the following response to NRC Inspection Report 50-366/85-18, dated July 22, 1985 concerning the inspection period of May 24 - June 28, 1985 for Plant Hatch Unit 2.

One apparent violation was identified.

VIOLATION:

Technical Specification 6.8.1 requires that procedures shall be establisned, implemented and maintained covering safety-related activities.

Contrary to the above.

Procedure HNP-2-1500, Primary Containment Atmospheric Control System, was not properly implemented in that on May 24, 1985, two nitrogen makeup valves were found out of the position required by Data Package 1 of HNP-2-1500.

The position of these valves, being shut instead of open, caused a SCRAM when the air was secured to the Main Steam Isolation valves in preparation for inerting the drywell.

This is a severity Level IV violation (Supplement 1).

RESPONSE

Admission or denial of alleged violation:

The violation occurreo.

However, such conditions do not constitute a severity Level IV violation in that the conditions had only a minor safety or environmental significance. Furthermore, no deliberate action by GPC personnel led to the conditions which caused the violation.

Consequently, HNP-2-1500 was not complied with only to the extent of the mispositioned valves, since the procedure was in fact properly perforred.

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AUG 26 '85 09815 00? GPC HUC OPS P.03 GeorgiaPower d U. S. Nuclear Regulatory Cost.ission Office of Inspection and Enforcement August 23, 1985 Page Two Reason for Violation:

The motor operated nitrogen makeup valves, 2T48-F025 and F027, were found improperly positioned.

Investigation of circumstances leading to the incident provided no conclusive explanation for the misalignment of the nitrogen makeup valves.

Refilling of the Unit 2 Nitrogen storage tank and the performance of Logic System Functional Tests (LSFTs) for this system were perfortred around the same time as completion of HNP-2-1500.

Review of data developed in implementing HNP 2-1500 indicates compliance of GPC actions with this document.

Corrective Steps Which Have Been Taken ano the Results Achieved:

The nitrogen makeup valves, 2T48-F026 and F027, were properly positioned on May 24, 1985.

An extensive investigation was undertaken to determine the precise cause for the mispositioned valves.

Data Package 1 of hhp-2-1500 was verified to be satisfactorily completed on May 16, 1985 by two very competent licensed operators using independent verification.

Additionally, the valves within Data Package 1

of HNP-2-1500 were reverified to be in the proper position on May 24.

No other valves were found to be out of the expected position.

No Maintenance Work Orders (MW0s) er valve clearances were found requiring these valves to be closed.

No entries were found in the Operations or Snift Supervisor's logs concerning these two valves.

Personnel interviews and a review of the available data did not provide conclusive evidence that the other activities peforced on this system, as described above in the " Reason for Violation", had affected the position of those valves.

Additionally, no f actual-basis could be estabitshed that would support the premise that the interruption of plant operation had been a deliberate act by plant personnel or a third party.

Site management issued letters to plant personnel describing the incident, requesting further information concerning the incident, and stating plant policy on valve control and manipulation.

No further information was received.

Also, the valve control switches in the main control room were relabe.ed to emphasize the effect of shutting valves 2T48-F026 and F027 on the pneumatics for the Main Steam Isolation Valves.

Corrective Steps Which Will Be Taken to Avoid Further Violati_on_s:

Fracedures 3450-P70-001-1 ano 2 (HNP-1, 2-1500) and 3450-T48-004-1 and 2,

Drywell Pneumatic System will be revised by October 4,

1985 to clarify the permissible methods for shif ting of the drywell pneumatic supply by establishing a proceduralized set of instructions for the swapping of the pneumatic medium from nitrogen to plant air and vice versa.

AUG 26 '85 09816 007 GPC HUC OPS P.04 GeorgiaPower d U. S. Nuclear Regulatcry Ccemission Office of Inspection and Enforcement August 23, 1985 Page Three Cate When Full COTpliance Was Achieved:

Full compliance was achieved en May 24, 1985.

Very truly yours, kb L. T. Gucwa CBS/blm xc: J. T. Beckham, Jr.

H. C. Nix, Jr.

J. F. Stolz (NRC-NRR)

Senicr Resident Inspector, Plant Hatch

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