ML20151G973
| ML20151G973 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 07/18/1988 |
| From: | Hairston W GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| SL-4927, NUDOCS 8808010081 | |
| Download: ML20151G973 (9) | |
Text
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Georgia Power Nuclear Operat;ons Department SL-4927 0371I X7GJ17-H120 July 18, 1988 U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 RESPONSE TO INSPECIl0N REPORT 88-15 Gentlemen:
In response to your letter of June 17, 1988, and in accordance with the provisions of 10 CFR 2.201, Georgia Power Company (GPC) is providing the enclosed response to the Notice of Violation associated with Inspection Report 88-15.
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, 5d.
. hu C
W. G. Hairston, III Senior Vice President JJP/lg
Enclosures:
- 1. Violation 88-15-03 and GPC Response
- 2. Violation 88-15-04 and GPC Response c:
(see next page) 40\\
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Georgia Power h U. S. Nuclear Regulatory Commission l
July 18, 1988 Page Two l
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l c: Georaia Power Comgany l
Mr. J. T. Beckham, Jr., Vice President - Plant Hatch Mr. L. T. Gucwa, Manager Nuclear Safety and Licensing l
G0-NORMS U. S. Nut 11ar Regulatory Commission. H15hington. D. C2 Mr. L. P. Crocker, Licensing Project Manager - Hatch 1.L_SJutieat_RegulatoIy_Commlisiondagion I1 Dr. J. N. Grace, Regional Administrator Mr. J. E. Henning, Senior Resident Inspector - Hatch 03711 nw m
Georgia Power b ENCLOSURE 1 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 VIOLATION 88-15-03 AND GPC RESPONSE VIOLATION 88-15-03 10 CFR 50, Appendix 8, Criterion III, Design Control, requires that measures shall be established to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled.
The licensee established procedurt 52GM-MEL-011-0S, Installation and Maintenance f
of Automatic Switch Company (ASCO) Solenoid Valves, Rev.1, to ensure that appropriate quality standards are established and maintained for the installation of ASCO solenoid valves. Procedure 52GM-MEL-011-05,Section I.1.b.,
Mounting, states, "The followirg valves must be mounted vertical and upright:
NP8323 (Solenoid A), 206-380, 206-381 and 206-832."
This requirement implements the vendor mounting requiremtnts for maintaining environmental qualification of the valves.
4 Contrary to the
- above, the licensec failed to maintain the appropriate quality ? tandards for installation of Model 206-380 ASCO solenoid valves in that, on May 16, 1988, an NRC inspector determined i
that the Model 206-380 ASCO solenoid valves for control of Unit I standby gas treatment system section valves IT41-F032A and -F032B were mounted in an orientation which violates the requirements of Procedure 52GM-MEL-011-OS.
This is a Severity Level IV violation (Supplement 1).
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03711 El-1 7/18/88 SL-4927 N
k Georgia Power h ENCLOSURE 1 (Continued)
VIOLATION 88-15-03 AND GPC RESPONSE BESPONSE TO VIOLATION 88-15-03 Mm_13sion or denial of violation:
The violation is admitted.
Model 206-380 ASCO solenoid valves for control of Unit I standby gas treatment system suction valves 1T41-F032A and 1T41-F0328 were mounted in an orientation which violated the requirements of plant procedure 52GM-MEL-011-0S, "Installation and Maintenance of ASCO Solenoid Valves," and vendor mounting requirements.
Reason for the violation:
The root cause of the violation is personnel error.
The damper actuator collars on which the ASCO solenoid valves were mounted were rotated such that the two available air ports were pointing downward.
To mount the solenoid valves to the air ports as shown on the air operated dangers' dimensional drawing (plant drawing SX15581, Revision A) required the solenoid valves be oriented downward.
At the time of the original installation, there was apparently no direction given that would indicate a proper or desired collar orientation.
Also, there is no information available that indicates a change of orientation occurred since original installation.
When these solenoids were determined to be environmentally qualified (EQ) components, the EQ data package required a vertical orientation.
No walkdown for these solenoids was performed to ensure the solenoids were oriented as required by the EQ file.
0371I El-2 7/18/88 SL-4927 TX ? Fl
Georgia Power A t
ENCLOSURE 1 (Continued) 1 VIOLATION 88-15-03 AND GPC RESPONSE Corrective steps which have beffLtaken and the results achieved:
As a
result of this
- event, the following corrective actions were implemented:
1.
Deficiency Card 1-88-2140 was written to document the event as required by the plant's administrative control procedures.
2.
Maintenance Hork Orders 1-88-2349 and 1-88-2350 were initiated I
to reorient the two ASCO solenoid valves to the "vertical and I
upright" position as required by plant procedure 52GM-ME L-011-05, which implements the vendor mounting I
requirements.
This work, which consisted of moving the valves i
from the collar's air port to an air port on the end of the spring cylinder where the solenM d valves could be mounted I
d correctly, was completed on Hay 17, 1983.
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i 3.
An evaluation of the solenoid valves' "as-found" position was t
[
conducted by Southern Company Services and Hyle Labs.
The evaluation concluded "that there was reasonable assurance that t
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the solenold valves as installed would have perform (sic) their
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required safety function" even under the worst case temperature and pressure conditions of a Main Steam Line Break (HSLB)
[
]
accident.
The evaluation also varified the solenoid valves
[
would operate properly after a seismic event and would not inadvertently hold closed the dampers on a loss of system air.
E 4.
A walkdown of all Unit 1206-series ASCO solenoid valves, except f
for two valves (which are ASCO valves that actuate valves
(
i IE11-F122A and B) located in the drywell, was performed on May i
1 16, 1988.
Valves 1E11-F122 A and B are on one inch lines i
i bypassing check valves IE11-F050 A and B and are used for line j
warming.
The valves serve no safety function.
No other L
problems were found.
(Unit 2, 206-series ASCO solenoid valves i
6 had been walked down previously with no problems found.)
Site l
Engineering determined a failure of the two solenoid valves in i
the drywell (i.e.,
the two not walked down) would have no adverse consequences.
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x Georgia Power d ENCLOSURE 1 (CONTINUED)
VIOLATION 88-15-03 AND GPC RESPONSE Corrective steps which will be taken to avoid further violations:
Georgia Power Company believes that the above corrective actions are sufficient to prevent recurrence of this event.
No further actions are anticipated at this time.
Date when full como11ance will be achieved:
Full compliance was achieved on May 17, 1988 when the two ASCO solenoid valves were reoriented to the vertical and upripat position.
The ASCO solenoid valves located in the drywell, as previously discussed, are not required to operate to perform a safety function.
03711 El-4 7/18/88 SL-4927
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Georgia Power b ENCLOSURE 2 PLANT HATCH - UNIT 2 NRC DOCKET 50-366 OPERATING LICENSE NPF VIOLATION 88-15-04 AND GPC RESPONSE VIOLATION 88-15-04 10 CFR 50, Appendix B, Criterion VI, Document Control, requires that measures be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting quality.
In addition, Criterion VI requires that the measures shall assure that changes are distributed to the location where the prescribed activity is performed.
The licensee established administrative control procedure 20AC-ADH-001-OS, Document Distribution and Control, Rev.
2, to accomplish this requirement.
This procedure required the recipient of controlled documentation to remove superseded documentation and file the current issue document in its appropriate place.
Contrary to the above, on May 15, 1988, an NRC inspector found that copy number 2 of the Unit 2 Technical Specifications located at the Shift Supervisor's desk in the control room contained eight pages which were either missing or had been superseded.
Further licensee review revealed additional examples of controlled documents in the control room that were not current.
This is a Severity Level IV violation (Supplement 1),
(Unit 2 only)
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0371I E2-1 7/18/88 SL-4927 700?PS
Georgia Power A ENCLOSURE 2 (Continued)
VIOLATION 88-15-04 AND GPC RESPONSE RESPONSE TO VIOLATION 88-15-04 Admission or denial of violation:
The violation is admitted.
Controlled copies of the Unit 2 Technical Specifications located in the Control Room contained superseded pages and were ciissing pages.
RfAson for the violation:
The root cause of the violation was personnel error.
Investigation of this problem revealed one Shift Clerk had incorporated into the Control Room Technical Specifications the amendments which were found to contain superseded pages and had pages missing.
The Shift Clerk who made the errors was new to the position.
Corrective _ steps which_have been taken and the retults achiend:
As a result of this event, the following corrective actions were implemented:
1.
Document Control personnel immediately replaced the superseded pages with the current pages and placed the missing pages in copy 2 of the Unit 2 Technical Specifications.
2.
Document Control personnel performed a complete review of all controlled copies of the Unit 1
and Unit 2
Technical Specifications against the current Active Page List. Additional errors were found in the Control Room's Technical Specifications.
These errors were corrected promptly.
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03711 E2-2 7/18/88 SL-4927 I
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- Georgia Power b ENCLOSURE 2 (Continued)
VIOLATION 88-15-04 AND GPC RESPONSE 3.
An investigation was performed to determine the cause of the errors.
Signed Document Transmittals were reviewed to determine if any pattern existed for the errors found.
It was determined a single Shif t Cierk had received and incorporated all the amendments which were found to have suporseded or missing pages.
No programmatic problems were found.
4.
The Shift Clerk was counseled and retrained as to the proper way to incorporate amendments / changes to. controlled documents.
It was stressed to her the importance of ensuring all superseded i
pages are removed and replaced with the current revision or amendment and no pages are removed inadvertently or misplaced.
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Corrective slepf, which willhe_taken to avoid further violations; Georgia Power Company believes the above corrective actions are sufficient l
to prevent reoccurrence of this event.
No further actions are planned at l
this time.
l Date_when fulj_rampliance will be achievedt i
Full compliance was achieved on May 16, 1988 when the errors in the j
controlled Technical Specifications were corrected.
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