ML20148B680

Responds to NRC Re Violations Noted in Insp Repts 50-321/86-35 & 50-366/86-35 on 861103-07.Corrective Actions: Tests Conducted on States Terminal Block/Resistance Temp Detector Circuits & States Terminal Block/Transmitter

ML20148B680
Person / Time
Site:	Hatch
Issue date:	03/16/1988
From:	Gucwa L GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
SL-4303, NUDOCS 8803220085
Download: ML20148B680 (12)

Text

- -

(. .

, Georgta Poaer Company 333 P,edmont Avenue Manta. Georg<a 30308 Tellphons 404 526-6526 Ma. ling Address.

Post Offce Box 4545 Manta. Georgia 30302 Georgia Power L. T. Gucwa the southern electrc system Yanager Nuclear Sa'ety and Licensing l

SL-4303 01591 X7GJ17-H120 March 16, 1988

! U. S. Nuclear Regulatory Commission l ATTN: Document Control-Desk Hashington, D.C. 20555 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 RESPONSE TO INSPECTION REPORT 86-35 l

l Gentlemon:

l In accordance with the provisions of 10 CFR 2.201, Georgia Power Company (GPC) is providing the enclosed response to your February 25, 1988 letter. This letter transmitted the Notice of Violation associated I with the inspection conducted on November 3 to November 7, 1986 at Plant

Hatch. A copy of this response is being provided to NRC Region II for l review. In the enclosures, a transcription of the NRC violation precedes GPC's response.

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

Sincerely, i

L. T. Gucwa I LGB/lc

Enclosures:

1. Transcription of NRC Violation 50-321/86-35-02 and 86-35-03 and 50-366/86-35-03 and 86-35-04 (Violation "A") and GPC Response

2. Transcription of NRC Violation 50-321/86-35-01 and 86-35-04, and l 50-366/86-35-02 and 86-35-05 (Violation "B") and GPC Response c

(see next page) l l 8803220085 880316 PDR ADOCK 05000321 { '

G PDR

\

1 GeorgiaPower A L U. S. Nuclear Regulatory Commission March 16, 1988 Page Two c: Georaia Power Comoany Mr. J. T. Beckham, Jr., Vice President - Plant Hatch G0-NORMS U. S. Nuclear Reaulatory Commission. Washington. D. C.

Mr. L. P. Crocker, Licensing Project Manager - Hatch U. S. Nuclear Reaulatory Commission. Region II Dr. J. N. Grace, Regional Administrator Mr. P. Holmes-Ray, Senior Resident Inspector -' Hatch 01591 700775

GeorgiaPower A ENCLOSURE 1 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 TRANSCRIPTION OF NRC VIOLATION 50-321/86-35-02 AND 86-35-03.

AND 50-366/86-35-03 and 86-35-04 (VIOLATION "A") AND GPC RESPONSE TRANSCRIPTION OF VIOLATION "A" 10 CFR 50.49 paragraphs (f) and (k) respectively require in part that: (1) each item of electrical equipment important to safety must be qualified to this part via methodologies delineated or; (2) applicants for and holders of operating licenses are not required to requalify electrical equipment important to safety in accordance with the provisions of this section if the Commission has previously required qualification of that equipment in accordance with "Guideline for Evaluating Environmental Qualification of Class lE Electrical Equipment in Operating Reactors", November 1979 (00R Guidelines). Additionally, the D0R guidelines, section 5.2.5, required that instrument accuracy requirements based on the maximum error assumed in the plant analysis should be included in the failure criteria.

Contrary to the above, at the time of the inspection and as far back as November 30, 1985:

1. EQ file QDP-26 did not adequately document qualification of Rosemount 1153 8 transmitters to the 00R guidelines, in that the transmitter accuracy calculation and comparison with plant requirements did not include an analysis of the error contributed by terminal blocks located in a harsh environment.

2. EQ file QDP-4 did not adequately document qualification of states terminal blocks (ZHH and NT) to the 00R guidelines in that a comparison of the errors determined during type testing with plant application performance criteria was never performed for resistance temperature detector (RTD) circuits.

This is a Severity Level IV violation (Supplement I).

0159I El-1 03/16/88 SL-4303 700775

GeorgiaPower d ENCLOSURE 1 (Continued) l TRANSCRIPTION OF NRC VIOLATION 50-321/86-35-02 AND 86-35-03.

AND 50-366/86-35-03 and 86-35-04 (VIOLATION "A") AND GPC RESPONSE RESPONSE TO VIOLATION "A" Admission or denial of violation:

The violation occurred as cited in the Notice of Violation. However, Georgia Power Company (GPC) requests that the violation be downgraded from a Severity Level IV violation to a Severity Level V violation.

GPC bases this request on the guidance provided in 10 CFR Part 2, Appendix C, Section III (Severity of Violations) and and 10 CFR Part i 2, Appendix C, Supplement I, Subsection D (Severity IV) and l Subsection E (Severity Level V).

These sections state that Severity Level IV (SL-IV) violaticns are less serious (than Severity Level III violation) but are of more than minor concern; i.e., if left uncorrected, they could lead to a more serious concern. This statement is a pivotal one in our justification for the lower severity level because Severity Level V (SL-V) violations are of minor safety or environmental concern. This particular violation could not have led to a more serious concern.

Additionally, the guidance provided in Supplement I, Subsections 0 and E provide guidelines for the assignment of the severity classification for a violation. Severity Level IV violations are normally assessed for the following reasons:

1 0159I El-2 03/16/88 SL-4303 I

roons

GeorgiaPower d ENCLOSURE 1 (Continued)

TRANSCRIPTION OF NRC VIOLATION 50-321/86-35-02 AND 86-35-03.

AND 50-366/86-35-03 and 86-35-04 (VIOLATION "A") AND GPC RESPONSE

1. A less significant violation of a Technical Specification Limiting Condition for Operation where the appropriate Action Statement was not satisfied within the time allotted

by the Action Statement.

l

2. Failure to meet the requirements of 10 CFR 50.59 that does not result in a Severity Level I, II, or III violation.

! 3. Failure to meet regalatory requirements that have more than

! minor safety or environmental significance.

1 I 4. Failure to make a required Licensee Event Report. '

Severity Level V violations are normally assessed only for violations that have minor safety or environmental significance.

GPC believes this violation does not satisfy the criteria for a SL-IV violation but clearly satisfies the criterion of a SL-V violation.

The cited violation concerns documentation deficiencies that have a minor adverse impact. The justifications for this statement (any errors were shown to be acceptable, leakage currents were insignificant, no measurable error shown in circuits) were provided 1 to representatives of the NRC in an enforcement conference that was held in Region II Headquarters on 1/13/88. If the conditions detailed in the Notice of Violation were left uncorrected, these discrepancies would not lead to a serious safety concern. This conclusion is based on tests and analyses and, as discussed in the enforcement conference, were found to be of limited safety significance.

0159I El-3 03/16/88 SL-4303

'*"s

GeorgiaPower A ENCLOSURE 1 (Continued)

TRANSCRIPTION OF NRC VIOLATION 50-321/86-35-02 AND 86-35-03.

AND 50-366/86-35-03 and 86-35-04 (VIOLATION "A") AND GPC RESPONSE Reason for the violation:

The violation was the result of personnel error on the part of I employees of Plant Hatch's Architect / Engineering fi rm. It was incorrectly assumed by the Architect / Engineer, during the original qualification analysis, that leakage currents were insignificant and, therefore, did not have to be quantified and documented.

Corrective steps which have been taken and the results achieved:

As a result of this event, the following corrective actions were implemented:

1. Tests were conducted at Hyle Labs on actual States Terminal Block /Trans,nitter and States Terminal Block /RTD circuits. The results of the tests (Hyle test 48842) indicate "that leakage is not a concert, for Plant Hatch's inside and outside containment RTD ci rcui t s . (Southern Company Services letter LSH-NS-3937 dated 10-29-87.) The test results also indicated that leakage current, during tne worst case event, will not exceed 0.2 ma.

For most transmitter circuits, this represented a maximum error of only 1.25% of calibrated span during a High Energy Line Break (the "worst case" event).

2. For those Unit 1 and Unit 2 transmitter circuits where the test results indicated the circuits could experience the maximum error of 1.25%, a Justifica. tion for Continued Operation (JCO) was written and approved (Flant Review Board Meeting No.87-129 on 11-6-87).

0159I El-4 03/16/88 SL-4303 I I

700775

GeoigiaPower A ENCLOSURE I (Continued)

TRANSCRIPTION OF NRC VIOLATION 50-321/86-35-02 /,ND 86-35-03.

AND 50-366/86-35-03 and 86-35-04 (VIOLATION "A") AND GPC RESPONSE Corrective steos which will be taken to avoid further violations:

1. Leakage current evaluations and test results for transmitter and RTD circuits ~containing States Terminal Blocks will be incorporated into the Environmental Qualification (EQ) Central File in the June, 1988, update.

2. For those transmitter circuits with the maximum, non-conservative, leakage current error of 1.257. of calibrated span, the States Terminal Blocks will be bypassed by splicing the circuit using qualified splices or the setpoints will be changed to account for the leakage current error. This will be done for the Unit 2 circuits during the current Unit 2 refueling outage (currently scheduled to end March,1988) and for the Unit I circuits during the next Unit 1 refueling outage (currently scheduled to begin September 1988).

Date when full como11ance will be achieved:

Full compliance was achieved on November 6,1987, when the Unit 1 and Unit 2 test results and JCOs were reviewed and approved by the Plant Review Board.

0159I El-5 03/16/88 SL 4303 mm _

I GeorgiaPower d ENCLOSURE 2 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES OPR-57, NPF-5 TRANSCRIPTION OF NRC VIOLATION 50-321/86-35-01 AND 86-35-04.

AND 50-366/86-35-02 and 86-35-05 (VIOLATION "B") AND GPC RESPONSE TRANSCRIPTION OF VIOLATION "B" l 10 CFR 50 Appendix B, Criterion XVII requires maintaining sufficient records to furnish evidence of activities affecting quality.

Additionally, 10 CFR 50.49 paragraph (j) requires in part, that a record of the qualification, including documentation in paragraph (d) of this section must be maintained in an auditable form to permit verification that each item of equipment important to safety covered by this section is; (1) qualified for its application and, (2) meets it specified performance requirements when it is subjected to the conditions predicted to be present when it must perform its safety function.

Contrary to the above, at the time of the inspection:

1. EQ files QDP-14 and 29 did not adequately document qualification of Okonite cable and splices, in that a comparison of performance data taken during the LOCA test, and definitions of plant electrical performance requirements were not included in the file.

2. EQ file QDP-10 did not adequately document qualification of Target Rock solenoid valves, in that (1) the qualified life of the equipment was not determined, and (2) sufficient design information was not available to establish similarity between installed and tested equipment to verify the fail safe mode assigned to the valve.

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

0159I E2-1 03/16/88 SL-4303 700775

GeorgiaPbwer d ENCLOSURE 2 (Continued)

TRANSCRIPTION OF NRC VIOLATION 50-321/86-35-01 AND 86-35-04.

AND 50-366/86-35-02 and 86-35-05 (VIOLATION "B") AND GPC RESPONSE RESPONSE TO VIOLATION "B" Admission or denial of violation:

The violation occurred as cited in the Notice of Violation. However, Georgia Power Company (GPC) requests that the violation be downgraded from a Severity Level IV violation to a Severity Level V violation.

GPC bases this request on the guidance provided in 10 CFR Part 2, Appendix C, Section III (Severity of Violations) and and 10 CFR Part 2, Appendix C, Supplement I, Subsection D (Severity IV) and Subsection E (Severity Level V).

These sections state that Severity Level IV (SL-IV) violations are less serious (than Severity Level III violation) but are of more than minor concern; i.e., if left uncorrected, they could lead to a more serious concern. This statement is a pivotal one in our justification for the lower severity level because Severity Level V (SL-V) violations are of minor safety or environmental concern. This particular violation could not have led to a more serious concern.

Additionally, the guidance provided in Supplement I, Subsections D and E provide guidelines for the assignment of the severity classification for a violation. Severity Level IV violations are normally assessed for the following reasons:

1. A less significant violation of a Technical Specification Limiting Condition for Operation where the appropriate Action Statement was not satisfied within the time allotted by the Action Statement.

0159I E2-2 03/16/88 SL-4303 mn _ _ _ _ _ _

- GeorglaPower A ENCLOSURE 2 (Continued)

JRANSCRIPTION OF NRC VIOLATION 50-321/86-35-01 AND 86-35-04.

AND 50-366/86-35-02 and 86-35-05 (VIOLATION "B") AND GPC RESPONJE

2. Failure to meet the requirements of 10 CFR 50.59 that does not result in a Severity Level I, II, or III violation.

3. Failure to meet regulatory requirements that have more than minor safety or environmental significance.

4. Failure to make a required Licensee Event Report.

Severity Level V violations are normally assessed only for violations that have minor safety or environmental significance.

GPC believes this violation does not satisfy the criteria for a SL-IV violation but clearly satisfies the criterion of a SL-V violation.

The cited minor violation concerns documentation deficiencies that have a adverse impact. The justifications for this statement (evaluations showed the effects were insignificant, qualified equipment life in accordance with maintenance schedule, i files l centained sufficient information to show similarities) were provided to representatives of the NRC in an enforcement conference that was held in Region II Headquarters on 1/13/88. If the conditions ,

detailed in the Notice of Violation were left uncorrected, these discrepancies would not . lead to a serious safety concern. This conclusion is based on tests and analyses and, as discussed in the enforcement conference, were found to be of limited safety significance.

)

Reason for the violation:

The violation was the result of changing documentation requirements for Environmental Qualification (EQ) components.

0159I E2-3 03/16/88 SL-4303 1

l l

mm  !

GeorgiaPower A ENCLOSURE 2 (Continued)

IReNSCRIPTION OF NRC VIOLATION 50-321/86-35-01 AND 86-35-04.

AND 50-366/86-35-02 and 86-35-05 (VIOLATION "B") AND GPC RESPONSE A 1983 NRC review of the Plant Hatch environmental qualificatico program did not identify any problems with existing Okonite cable and splices performance / performance criteria documentation. Similarity concerns for Target Rock Solenoid Valves, expressed by the NRC during the 1983 review, were resolved at that time to the mutual satisfaction of the NRC and GPC.

A contributing cause to the event was personnel error on the part of GPC personnel. Specifically, in 1985 the EQ Central File was incorrectly revised to indicate the Target Rock Solenoid valves were qualified to the 10 CFR 50.49 standards. (The standards were established in late 1985.) In fact, tne 00R guidelines (which did not require the establishment of a qualified life for the energized valves), were the applicable standards. Documentation to support qualification to the 10 CFR 50.49 standards was not in the EQ Central File in 1985.

Corrective steos which have been taken and the results achieved:

As a result of this event, the following corrective actions were implemented:

1. GPC, during the November, 1986, NRC inspection, obtained from Okonite the performance data for cable and splices and performed the required comparison evaluation. The performance data and the results of the evaluation supported qualification of Okonite cable and splices. This information was added to the EQ Central File in March, 1987.

0159I E2-4 SL-4303 03/16/88 mm

GeorgiaPower A ENCLOSURE 2 (Continued)

TRANSCRIPTION OF NRC VIOLATION 50-321/86-35-01 AND 86-35-04.

AND 50-366/86-35-02 and 86-35-05 (VIOLATION "B") AND GPC RESPONSE

2. /idequate documentation to support the qualification of the Target Rock Solenoid Valves to the 10 CFR 50.49 standards was generated by GPC during the November, 1986, NRC inspection.

This documentation included establishment of a qualified life for the valves and similarity between installed and tested components.

This documentation was added to the EQ Central File in March 1987.

Corrective steos which will be taken to avoid further violations:

No further corrective actions are required to prevent recurrence.

Date when full compliance will be achieved:

l

' Full compliance was achieved in March,1987, when the EQ Central File was revised to include the required component qualification documentation.

1 I

1 l

l 0159I E2-5 03/16/88 SL-4303 t

___m.__II._.__--____-___.-------------------------------------------------

_ -