ML20151A452
| ML20151A452 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 03/29/1988 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| SL-4380, NUDOCS 8804070023 | |
| Download: ML20151A452 (9) | |
Text
1 33 A enue A:tatu. Georg a 30308 Telephcre 404 526 6526 Maong Ad@ess Pes: Cece Box 4545 Aras Georg a 30302 Georgia Power L.T.occwe tre souvn eWrec s>s'em Manager Nuc! car Sa'oty and L<e4DQ SL-4380 01891 X7GJ17-H120 March 29, 1988 U. S. Nuclear Regulatory Commission 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 88-05 Gentlemen:
In accordance with the provisions of 10 CFR 2.201, Georgia Power Company (GPC) is providing the enclosed response to your March 10, 1988 letter.
This letter transmitted the Notice of Violation associated with the inspection conducted on January 23 to February 19, 1988 at Plant Hatch.
A copy of this response is being provided to NRC Region II for 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, L. T. Gucwa LG8/lc
Enclosures:
- 1. Transcription of Violation 88-05-01 and GPC Response
- 2. Transcription of Violation 88-05-04 and G% Response c:
(see next page)
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Georgia Power A U. S. Nuclear Regulatory Comission March 29, 1988 Page Two c: Georaia Power Comoany Mr. J. T. Beckham, fr., Vice President - Plant Hatch GO-NORMS U. S. Nuclear Reaulatory Comission. Washington. D. C.
Mr. L. P. Crocker, Licensing Project Manager - Hatch U. S. Nuclear Regulatory Comission. Reaion II Dr. J. N. Grace, Regional Administrator Mr. P. Holmes-Ray, Senior Resident Inspector - Hatch 0189I um
l Georgia Power d ENCLOSURE 1 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 TRANSCRIPTION OF VIOLATION 88-05-01 AND GPC RESPONSE TRANSCRIPTION OF VI.0LATION 88-05-01 Table 3.1-1 of the Technical Specification requires a minimum of two operable channel inputs per Reactor Protection System (RPS) channel for the APRM Downscale scram function during power operations.
If the minimum number of operable inputs cannot be met for an RPS channel, the affected RPS channel must be tripped.
Contrary to the above, on February 9,1988, Unit I was operating at 100 percent of rated power with only one APRM channel available to provide APRM Downscale scram input to RPS channel A, and the RPS channel was un-tripped.
APRM channels A and C had been bypassed and only channel E remained available for the Awnscale scram input for at least several hours.
This is a Severity Level IV violation (Supplement I).
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Georgia Power b ENCLOSURE I (Continued)
TRANSCRIPTION OF VIOLATION 88-05-01 AND GPC RESPONSE RESPONSE TO VIOLATION 88-05-01 Admission or denial of violation:
The violation occurred as cited in the Notice of Violation.
Reason for the violation:
The violation was the result of inadequate procedures.
Specifically, plant procedures 34SV-C51-002-IS (APRM Instrument FT&C),
and 34GO-0PS-001-IS (Plant Startup), did not provide appropriate guidance for bypassing both the Intermediate Range Monitors (IRMs) and the i
Average Power Range Monitors (APRMs) while the reactor was in the run mode (power operations).
Carrective stent which have been takertand the results achieved:
As a result of this event, the following immediate corrective actions were implemented:
1.
On 2/9/88 at approximately 1410 CST, plant operations personnel determined that Unit 1 may not have been in compliance with the Technical Specifications requirements l
relative to the minimum number of operable APRH downscalt-trip channels.
The shift supervisor directed that the C IRM be removed from the bypassed condition, j
This action immediately returned the unit to compliance with the Technical Specifications requirements (Table 3.1-1, item 8).
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Georgia Power A i
ENCLOSURE I (Continued) 1 TRANSCRIPTION OF VIOLATION 88-05-01 AND GPC RESPONSE l
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An event review team was formed, as outlined in the plant's administrative control procedures, to thoroughly investigate the event.
3.
Plant personnel notified other members of the nuclear industry, especially other Boiling Hater Reactor (BHR) i operators, of this problem by issuing a notice on the I
Nuclear Network.
4.
Plant operations personnel placed caution tags on the IRH bypass switches.
This will prevent the use of the bypass switches while the reactor is operating in the run mode.
Corrective stens which will be taken to avoid further violationsl Immediate corrective actions were
- taken, as described above.
However, plant personnel determined that the following additional corrective actions would be implemented:
1.
Plant procedures 34SV-C51-002-IS (APRM Instrument FT&C -
Unit 1),
34GO-0PS-001-IS (Plant Startup Unit 1),
345V-C51-002-2S (APRM Instrument FT&C Unit 2),
and 34GO-0PS-001-2S (Plant Startup - Unit 2) will be revised.
The revisions will provide sufficient guidance for bypassing IRMs and APRMs when the reactor is in the run mode.
These revisions will ensure that the Technical i
Specifications requirements are met.
The procedure revisions are scheduled to be in place by approximately June 1, 1988.
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t (iecn];ia Potver ambi ENCLOSURE 1 (Continued) i TRANSCRIPTION OF VIOLATION 88-05-01 AND GPC RESPONSE i
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Plant personnel will continue to implement the on going Procedures Upgrade Program (PUP) at the plant.
The PUP is the long term corrective action to detect and correct errors in plant procedures.
Date when full comoliance will be achieved:
t Full compliance was achieved on Februt.ry 9, 1988, when - the above immediate corrective actions were completed.
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Georgia Power A 3
i ENCLOSURE 2 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 1
OPERATING LICENSES OPR-57, NPF-5 TRANSCRIPTION OF VIOLATION 88-05-04 AND GPC RESPONSE 7
i TRANSCRIPTION OF VIOLATION 88-05-04 l
Technical Specifications section 6.8.1.a requires the licensee to establish, implement, and maintain written procedures covering the applicable activities in Appendix A of Regulatory Guide 1.33 Revision 2,
February 1978.
Appendix A of Regulatory Guide 1.33 recommends that maintenance that can affect the performance of safety related equipment, be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
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Contrary to the above, in October of 1987, the instructions of MHO J
1-86-7823 for the re-wiring of vacuum breaker test solenoid valves i
IT48-342 C, E, and F wer3 inadequate and resulted in incorrect wiring l
of the test circuitry.
Subsequent to this maintenance, vacuum breakers IT48-F323 C, E, and F failed to test properly during the months of November and December in 1987.
The incorrect wiring of the test solenoid valves did not impair the ability of the torus to drywell vacuum breakers to function in the normal, self actuating j
mode.
This is a Severity Level IV violation (Supplement I).
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l ENCLOSURE 2 i
TRANSCRIPTION OF VIOLATION 88-05-04 AND GPC RESPONSE RESPONSE TO VIOLATION 88-05-04 i
Admission or denial of violation:
The violation occurred as stated in the Notice of Violation.
Reason for the violation:
The violation was the result of Engineering Support Department personnel error in that work instructions, written by plant engineering personnel for the re-wiring of the vacuum breaker test solenoid valves, were inadequate.
The Work Process Sheets (HPSs) attached to the Maintenance Work Order (MHO) did not address all work activities necessary to properly re-wire the test solenoid valves.
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A contributing factor in this event was mislabeled cables.
Two separate cables were labeled the same.
This resulted in confusion as to which wires were supposed to be connected to the test solenoid 1
valves.
This confusion contributed to the valves being wired t
incorrectly.
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Corrective steos which have been taken and the results achieved:
i As a result of this event, the following immediate corrective actions were implemented:
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Georgiaibwer h ENCLOSURE 2 TRANSCRIPTION OF VIOLATION 88-05-04 AND GPC RESPONSE 1.
MH0s 1-87-7517, 1-87-7624, and 1-87-7950 were performed to re-wire and re-label vacuum breaker test solenoid valves IT48-F342F, IT48-F342C, and IT48-F342E, respectively.
Following completion of this work, torus to drywell vacuum breakers IT48-F323C, IT48-F323E, and 1T48-F323F were successfully tested using plant procedure 34SV-T48-002-15, (Suppression Chamber to Drywell Vacuum Breaker System Operability Surveillance).
j 2.
Plant engineering personnel generated As-Built Notice (ABN) 88-23.
This ABN revised plant drawing H-17989 and the associated circuit schedules to indicate the proper (as-left) wiring configuration for the three test solenoid valves.
3.
Engineering Support Department personnel were remindad of the need to provide clear, concise, and complete work i
instructions with MH0s.
Cu ective stens which will be taken to avoid.fttther violations 1 No further corrective actions are required to prevent recurrence.
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DAte when full como11ance will be achieved:
Full compliance was achieved on January 14, 1988, wi.en the test solenoid valves were re-wired and re-labeled, and the vacuum breakers were successfully tested.
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