ML20134P492
| ML20134P492 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 02/10/1997 |
| From: | Jaudon J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Woodard J GEORGIA POWER CO. |
| References | |
| NUDOCS 9702260001 | |
| Download: ML20134P492 (4) | |
See also: IR 05000321/1996012
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February 10, 1997
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Georgia Power Company
ATTN: Mr. J. D. Woodard
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Senior Vice President
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Nuclear Operations
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P. O. Box 1295
Birmingham, AL 35201
SUBJECT:
NRC INSPECTION REPORT NO. 50-321/96-12 AND 50-366/96-12
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Gentlemen:
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Thank you for your response of December 19,1996, to our Notice of Violation issued
November 22,1996, concerning activities conducted at your Hatch facility. We initial *y
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responded to your December 19,1996, letter by a letter of January 9,1997. We stated in
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that letter that we were evaluating your response to Violations 50-321, 366/96-12-01 and 50-
321, 366/96-12-02, and would document our conclusions in a letter to you after appropriate
NRC staff review of your response.
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We have completed our review of your response to Violations 50-321,366/96-12-01
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(Violation A) and 50-321,366/96-12-02 (Violation B), and the additional information provided.-
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After careful consideration of the bases for your denial of the violations and the supplemental
Information, we have concluded, for the reasons presented in the enclosure to this letter, that
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the violations occurred as stated in the Notice of Violation. Therefore, in accordance with 10
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CFR 2.201(a), please submit to this office within 30 days of the date of this letter a written-
statement describing the steps which have been taken to correct the violations, and the
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results achieved, corrective steps which will be taken to avoid further violations, and the date
when full compliance will be achieved.
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We will examine the implementation of your actions to correct the violations during future
inspections.
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We have also addressed your comments to our NRC inspection report cover letter in the
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enclosure.
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9702260001 970210
ADOCK 05000321
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GPC
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We appreciate your cooperation in this matter.
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Sincerely,
MMBY
SOSRJIMON
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Johns P. Jaudon, Director
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Division of Reactor Safety
Docket Nos.: 50-321, 50-366
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Enclosure: Eva!uations and Conclusions
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cc w/ encl:
H. L. Sumner, Jr.
Thomas P. Mozingo
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General Manager, Plant Hatch
Manager of Nuclear Operations
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Georgia Power Company
Oglethorpe Power Corporation
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P. O. Box 439
2100 E. Exchange Place
Baxley, GA 31513
Tucker, GA 30085-1349
D. M. Crowe
Charles A. Patrizia, Esq.
Manager Licensing - Hatch
Paul, Hastings, Janofsky & Walker
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Georgia Power Company
10th Floor
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P. O. Box 1295
1299 Pennsylvania Avenue
Birmingham, AL 35201
Washington, D. C. 20004-9500
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Ernest L. Blake, Esq.
Steven M. Jackson
Shaw, Pittman, Potts and
Senior Engineer - Power Supply
Trowbridge
Municipal Electric Authority
2300 N Street, NW
of Georgia
Washington, D. C. 20037
1470 Riveredge Parkway NW
Atlanta, GA 30328-4684
Charles H. Badger
Office of Planning and Budget
Thomas Hill, Manager
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Room 610
Radioactive Materials Program
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270 Washington Street, SW
Department of Natural Resources
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Atlanta, GA 30334
4244 International Parkway
Suite 114
Harold Reheis, Director
Atlanta, GA 30354
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Department of Natural Resources
205 Butler Street, SE, Suite 1252
Chairman
Atlanta, GA 30334
Appling County Commissioners
County Courthouse
Distribution w/ encl: (See page 3)
Baxley, GA 31513
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M. E. Ernstes, Ril
M. Satorius, OE
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NRC Senior Resident inspector
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U.S. Nuclear Regulatory Commission
11030 Hatch Parkway North
Baxley, GA 31513
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EVALUATIONS AND CONCLUSIONS
On November 22,1996, a Notice of Violation (Notice) was issued for violations identified
during a NRC Maintenance Rule Baseline Team inspection. Georgia Power Company (GPC)
responded to the Notice on December 19,1996. In the response GPC denied that violation
A and part of violation B occurred as stated in the NOV. The NRC's evaluations and
conclusions regarding the licensee's response are as follows:
Restatement of Violation A
10 CFR 50.65 (b) establishes the scoping criteria for selection of safety related and non-
safety related structures, systems, or components to be included within the Maintenance Rule
program. Scoping criteria shallinclude, in part, non-safety related structures, systems, or
components that are relieu spon to mitigate accidents or transients, or are used la .he plant
emergency operating procedures, or whose failure could prevent safety-related structures,
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systems, and components from fulfilling their safety-related function, or whose failure could
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cause a reactor scram or actuation of a safety-related system.
Hatch Nuclear Plant Administrative Procedure,40AC-ENG-020-OS, MAINTENANCE RULE
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(10 CFR 50.65) IMPLEMENTATION AND COMPLIANCE, Revision 1, and the HATCH
NUCLEAR PLANT 10 CFR 50.65 MAINTENANCE RULE SCOPING MANUAL, Revision 1,
implemented the requirements of 10 CFR 50.65 and identified those systems and
components included within the scope of the Maintenance Rule.
Contrary to the above,
As nf October 25,1996, the licensee failed to include a number of systems or components
98@ the scope of the Maintenance Rule, as required. Specifically, the following systems
should have been included within the scope of the Maintenance Rule, but were not.
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Communications System, Emergency Lighting System, and Appendix R Emergency
Lighting System - These non-safety related systems were not included in the scope of
the Maintenance Rule even though they are relied upon io mitigate accidents or
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Cooling Towers System - This non-safety related system was not included in the
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scope of the Maintenance Rule even though the system experienced a failure on
March 24,1995, which could have caused a Unit 2 reactor scram and actuation of a
safety-related system; and experienced a similar failure on September 1,1995, which
resulted in a Unit 2 reactor scram and actuation of a safety-related system.
Summary of Licensee's Response to Violation A
The licensee denied that the violation occurred as stated in the Notice.
The licensee stated, "the communications, emergency lighting, Appendix R emergency
lighting, and cooling tower systems do not meet the scoping criteria of 10 CFR 50.65(b).
Therefore they are not required to be ,ncluded in the Hatch Maintenance Rule program and
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their exclusion does not represent a violation of the requirements of 10 CFR 50.65 or
administrative control procedure,40AC-ENG-020-OS; ' Maintenance Rule (10 CFR 50.65)
Implementation and Compliance'."
The licensee further stated, " Contrary to that stated in item 1 of the Notice of Violation,
neither the communications system, the emergency lighting system, nor the Appendix R
emergency lighting system is relied upon to mitigate any accident or transient described in
the Hatch Unit 1 or Unit 2 Updated Final Safety Analysis Reports. The statement that these
systems are " relied upon to mitigate an accident or transient" is an cpinion not supported by
any documented accident or transient analysis in the Updated Final Safety Analysis Reports.
Furthermore, the more specific scoping guidance provided in NUMARC 93-01, " Industry
Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,"
Revision 0
uld not lead to the conclusion any of these systems is within the scope of the
Maintenanc. Hule. NUMARC 93-01, Revision 0, has been endorsed in its entirety by the
NRC in Regulatory Guide 1.160."
The licensee further stated, "Per section 8.2.1.2 of NUMARC 93-01, Revision 0, only non-
safety related structures, systems, or components that are relied upon to mitigate accidents
or transients are required to be included within the scope of the Mainteriance Rule. A review
of Chapter 14, " Plant Safety Analysis," of the Unit 1 Updated Final Safety Analysis Report
and Chapter 15, " Accident Analysis," of the U,n 2 Updated Final Safety Analysis Report
reveals that neither the communications system, the emergency lighting system, nor the
Appendix R emergency lighting system performs either an active or a passive function in
mitigating any analyzed accident or transient. Moreover, none of these systems performs a
support role for any structure, system, or component which is used to mitigate analyzed
accidents or transients."
The licensee further stated, " Operation of these systems is not vital to the successful
completion of actions required by Emergency Operating Procedures or other procedures
which might be used in responding to an accident or transient. Per section 8.2.1.3 of
NUMARC 93-01, Revision 0, a non-safety related structure, system, or component should be
included in the scope of the Maintenance Rule if it adds "significant value to the mitigation
function of an EOP by providing the total or a significant fraction of the total function ability
required to mitigate core damage or radioactive release." These three systems do not meet
this definition. Their failure, either singularly or in combination, will not prevent the successful
completion of the actions required by the Emergency Operating Procedures and other
abnormal operating procedures. That is, their proper operation does not provide a significant
portion of the " total functional ability" required tc complete the actions required by the
aforementioned procedures. Failures of the communication and/or emergency lighting
systems can be overcome easily without a significant adverse affect on the operators' ability
to complete required procedure actions. The scoping guidance provided in the NRC-
endorsed NUMARC 93-01, Revision 0, would not lead to the conclusion that the
communications, emergency lighting, and the Appendix R emergency lighting systems are
wi'.hin the scope of the Maintenance Rule."
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.The licensee further stated, "It should be noted the communication system is a highly reliable
system by virtue of the fact it can be powered by either one of two redundant Class 1E power
supplies. The Class 1E power supplies are included in the Hatch Maintenance Rule
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Program. Additionally, the emergency lighting and the Appendix R emergency lighting
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systems are tested periodically using plant procedures 52lT-MEL-001-0N, " Emergency
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Lighting inspection and Test," and 42SV-FPX-003-OS, " Emergency Lighting Surveillance,"
respectively. The latter test is required by Appendix B of the Hatch Fire Hazards Analysis.
The testing performed using these two procedures provides reasonable assurance the
emergency lighting systems will function properly."
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The licensee further stated, "The failure of the cooling tower system cannot directly cause a
scram or actuation of a safety-related system. Neither of the events listed in item 2 of the
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Notice of Violation directly caused a reactor scram or an actuation of a safety-related system.
The 3/24/95 event resulted in a power reduction only; no reactor protection or other safety-
related system actuation occurred. The 9/1/95 event eventually resulted in the insertion of a
manual scram; however, this action was necessary only because inadequate procedure
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instructions prevented the proper venting of a main condenser waterbox. With one of the
waterboxes air-bound, vacuum could not be maintained and a manual scram was inserted as
a conservative action. Had the procedure provided proper instructions for venting the
waterbox, vacuum could have been maintained and no manual scram would have been
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necessary. Problems in the main condenser and circulating water systems more directly led
to the decrease in vacuum and the subsequent manual scram; these two systems are in the
Hatch Maintenance Rule Program. The failure of the cooling tower system did not result in a
reactor scram. Therefore, the system does not meet the criteria listed in 10 CFR 50.65(b)(2)(iii) and it is not required to be included in ti'e scope of the Maintenance Rule.
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The scoping guidance provided in the NRC-endorsed NUMARC 93-01, Revision 0, would not
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lead to the conclusion that the cooling tower system is within the scope of the Maintenance
Rule."
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The licensee concluded by stating, " Georgia Power Company believes it has correctly
implemented the requirements of 10 CFR 50.65, by using the NEl (NUMARC) guidance,
endorsed by the NRC. GPC has concluded that NUMARC 93-01 does not require the
communications, emergency lighting, Appendix R emergency lighting, and cooling tower
systems be included in the Maintenance Rule scope for Plant Hatch. Therefore, Georgia
Power Company respectfully denies this violation. If the NRC requires that these systems be
included, then the issue should be resolved with NEl."
NRC Evaluation of Violation A
The NRC staff has carefully reviewed the licensee's response and has concluded that the
licensee did not provide any information that was not already considered in determining that
a violation of 10 CFR 50.65(b) occurred.
In reviewing the applicability of the communications, emergency lighting, and Appendix R
emergency lighting systems for inclusioa in the scope of the Maintenance Rule, the
inspectors focused on structures, systems, or components (SSCs) which were required to
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support plant operators in performance of their duties for mitigation of accidents or transients.
The operators normally used Emergency Operating Proceoures to mitigate accidents, and
more frequently used off-normal or abnormal operating procedures to mitigate transient
events. In cases where operators were performing the duties described above, the
inspectors determined that communications system equipment (radios, telephones, public
announcement equipment) was used. The report stated, in part, in Section M1.1.b, "The
operators verified, based on the inspectors questions, that communications equipmen plays
a vital role in responding to off-normal conditions." The inspectors also determined that
proper procedure performance would require lighting when operators were performing
accident or transient mitigation evolutions. The inspectors determined that the emergency
lighting system and the Appendix R emergency lighting system provided lighting in plant
areas for operators to perform their accident or transient mitigation duties on a loss of normal
plant lighting.
On January 9,1997, the NRC staff met with the Nuclear Energy Institute and industry
representatives and discussed issues that have been identified during NRC baseline team
inspections relating to Maintenance Rule implementation. The NRC staff stated their position
that SSCs such as emergency lighting and communications that are relied on to mitigate
accidents or transients should be included within the scope of the Maintenance Rule. This
position is based on operator reliance on this equipment to successfully mitigate accidents or
In reviewing the applicability of the cooling tower system for inclusion in the scope of the
Maintenance Rule, the inspectors focused on structures, systems, or components that caused
unit transients over the last two years. Fill material failures in the cooling tower system
caused two unit transients in 1995, and one of the failures was the initiating event that
resulted in a Unit 2 manual reactor scram on September 2,1996.10 CFR 50.65(b)(2)(iii)
provides, in part, that the scope of the monitoring program shall include non-safety related
SSCs, "whose failure could cause a reactor scram or actuation of a safety-related system."
The inspectors determined that the two unit transients in 1995, could have resulted in reactor
scrams and actuation of safety-related systems if operator actions had not mitigated the
NRC Conclusion for Violation A
For the above stated reasons, the NRC staff concluded that the violation occurred as stated.
Restatement of Violation B
10 CFR 50.65 (a)(1) requires, in part, that each holder of an operating license shall monitor
the performance or condition of structures, systems, or components against licensee
established goals. Such goals shall be established commensurate with safety.
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Contrary to the above,
As of October 25,1996, the licensee failed to establish reliability and/or availability goals or
performance criteria commensurate with safety for risk significant structures, systems or
components for the following systems:
Primary Containment System
Feed and Condensate System
Electro-hydraulic Control System
Unit 2 Containment Chilled Water System
AC Electrical System
DC Electrical System
Primary Containment isolation System
Analog Transmitter Trip System
For these systems the licensee either failed to establish performance criteria, or established
performance criteria that would not satisfactorily monitor system performance.
Summary of Licensee's Response to Violation B
The licensee denied that the violation occurred for 3 (AC Electrical System, DC Electrical
S' stem, and Analog Transmitter Trip System) of the 9 systems as stated in the Notice.
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The licensee stated, " Georgia Power Company, however, respectively denies performance
criteria for the AC and DC electrical and analog transmitter trip systems were not properly
established. These systems have reliability criteria established in the Hatch Maintenance
Rule Program. Availability criteria for these systems are adequately established by the Hatch
Unit 1 and Unit 2 Technical Specifications as very limited out-of-service times. For example,
the Unit 1 Technical Specification Limiting Condition for Operation 3.8.4, Action C, allows one
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station service DC electrical power subsystem to be inoperable for only two hours before the
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plant must begin to shut down. Simi!arly restrictive requirements exist for inoperable
components in the AC electrical system. Inoperable components in the analog transmitter
trip system may be required by the applicable Technical Specification to be placed in the
tripped condition in as little as six hours. Realistically, these limited out-of-service times
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require the systems to be available virtually 100 percent of the time. In effect, the existing
plant Technical Specifications establish very stringent availability criteria and no additional
availability criteria are necessary. The effectiveness of maintenance on these systems is
readily apparent because the short out-of-service times allowed by the Technical
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Specifications would quickly result in adverse effects on continued unit operation. Additional
availability criteria would serve no useful purpose and are not necessary to comply with the
requirements of 10 CFR 50.65(a)(1). Therefore Georgia Power Company respectfully deriies
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these three examples constitute a violation of NRC requirements."
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The licensee further stated, "The existing NEl (NUMARC 93-01) and NRC (R.G.1.160)
guidance documents do not address availability of systems which are required to be virtually
100% available by the plant Technical Specifications. GPC believes that including additional
performance criteria for these three systems in the Maintenance Rule program will serve no
useful purpose. A draft revision to NUMARC 93-01 guidance document has been developed
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by NEl. The NRC has drafted endorsement to this revision with a draft revision to R.G.1.160.
We believe that these documents further support GPC's position on these three systems."
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NRC Evaluation of Violation B
The NRC staff has carefully reviewed the licensee's response and has concluded that the
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licensee did not provide any information that was not already considered in determining that
a violation of 10 CFR 50.65(a)(1) occurred for the three systems discussed above.
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Section M1.2.b.2 of the inspection report discussed performance criteria. The report stated,
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in part, that "the license did not establish unavailability performance criteria for several risk
significant highly reliable functions. The licensee stated that unavailability criteria for these
functions was not necessary since these functions were historically highly reliable and
availability was adequately controlled by Hatch technical specifications. Examples of these
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risk significant SSC functions included Plant AC Electrical System, DC Electrical System, ,
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and the Analog Transmitter System. The team concluded the licensee could not determine
the effectiveness of maintenance of these systems without monitoring unavailability."
Additional reviews have reached the same conclusion.
The NRC staff recognizes that the Hatch Technical Specifications (TS) have short Limiting
Condition for Operation (LCO) ACTION statements for these systems. However, the TS LCO
ACTION statements are intended to be a one-time limit for some condition, whereas, the
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Maintenance Rule performance criteria for availability (unavailability) provides an indication of
the cumulative time an SSC is out-of-service, independent of how many times the SSC is
taken out-of-service over some established period (e.g.,2 years). Exceeding the
Maintenance Rule availability criteria may be an indicator of ineffective maintenance or poor
reliability of the SSC. For example, the inspectors were aware of circumstances where the
DC electrical system vital batteries were made inoperable for short periods of time to jumper
cells for replacement. Although the inoperable windows did not appear to exceed the TS
LCO ACTION in each instance, the cumulative time the batteries were inoperable and
unavailable was not being tracked. In addition, although components in the analog
transmitter trip system may be required by the applicable TS LCO ACTION to be placed in
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the tripped condition in as little as six hours, lack of tracking of inoperable or unavailable time
for specific trains or components also prevents monitoring of system (train) performance as
required by the Maintenance Rule. In addition, the inspectors also noted that these systems
continue to provide risk significant functions when the units are not operating in Mode 1;
however, the time constraints imposed by the TS LCO ACTION statements for these systems
are significantly relaxed and would not ensure that these systems were available as
described in the response.
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NRC Conclusion for Violation B.
For the above stated reasons, the NRC staff concluded that the violation occurred as stated.
Cover Letter Comments
In your response, you provided feedback to address our comments included in the cover
letter containing our Notice of Violation. Our cover letter stated "your implementation of the
Maintenance Rule did not demonstrate good integration of other maintenance programs with
Maintenance Rule requirements." Your comment regarding this statement was, 'We
respectfully submit that this comment is not supported by examples or other comments in the
Inspection Report."
With regard to your comment, we believe that the inspection report does provide examples of
a lack of good integration of other maintenance programs with Maintenance Rule
requirements in Section M1.2.b.2, associated with 10 CFR 50, Appendix J, and Sections
M1.6.b.3 & b.6, where licensee corrective actions for specific maintenance problems were
considered " goals" under the Maintenance Rule. We also specifically identified a procedure
weakness in the administrative procedure implementing the Maintenance Rule requirements
on page 10 of the report (associated with Primary Containment System performance criteria).
A second comment in our cover letter stated,"Although Safety Audit and Engineering Review
Group audits on Maintenance Rule implementation identified areas for improvement, few
findings were documented. Also, some issues discussed in this report had not been entered
into your deficiency control system until NRC discussed the problems with your staff. These
indicators call into question the threshold for formal identification of deficiencies and the
effectiveness of your corrective action program." In your comments, you stated,"Under the
GPC QA audit process, a finding is issued when a noncompliance to the QA program is
identified which requires corrective action. The review of the Maintenance Rule audit notes
by the NRC inspector included the GPC auditors' observations which may have provided
enhancements to GPC's Maintenance Rule program, but did not result in noncompliance with
NRC rules or with GPC procedures. It is the opinion of GPC that the comments in the cover
letter are subjective and do not reflect a potential weakness in the corrective action program."
With regard to your comment, a review of Maintenance Rule Audits was fully discussed in
Section M7.1. The inspector listed several issues which were considered to reach a
threshold where a deficiency card may have been warranted. In addition, several other
issues were identified in the report which indicated a weakness in formal documentation cnd
disposition of problems. Examples of these issues were identified in Sections M1.4, M1.5,
and M1.6.
ENCLOSURE