ML20195J306

Responds to NRC Re Violations Noted in Insp Repts 50-321/87-30 & 50-366/87-30.Corrective Actions:Fire Drill & Critique Repts Completed Per Procedure 41FP-FPX01-0. Procedure Revised to Require Completion of Repts on Time

ML20195J306
Person / Time
Site:	Hatch
Issue date:	01/18/1988
From:	Gucwa L GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
SL-3948, NUDOCS 8801270219
Download: ML20195J306 (12)

Text

a Georg a Power Company -

333 P,edmont Avenue Atlanta. Georg a 30308 Telephone 404 526-6526 Ma<ltng Address.

R>st Off ce Box 4545 Atlanta. Georg a 30302 Georgia Power L. T. Gucwa

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Manager Nclear Safety and Ucensing SL-3948 1891C X7GJ17-H120 January 18, 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 87-30 Gentlemen:

In accordance with the provisions of 10 CFR 2.201, Georgia Power Company (GPC) is providing the enclosed response to your December 18, 1987 letter. This letter transmitted the Notice of Violation associated with the inspection conducted on November 16 - November 20, 1987 at Plant Hatch by Mr. G. R. Hiseman. 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.

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

Sincerely,

'f/$ jr

t. L. T. Gucwa LGB/lc I

Enclosures:

1. Transcription of Violation 87-30-02 and GPC Response

2. Transcription of Violation 87-30-03 and GPC Response i c: (see next page) l 8801270219 880118 g l

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' Georgia Porver sib t j q

u .i U. S. Nuclear Regulatory Commission January 18, 1988 Page Two

.c: Georaia Power Comoany-Mr. J. P. O'Reilly, Sr. Vice President - Nuclear Operations ~

Mr. J. T. Beckham, Jr., Vice President - Plant Hatch GO-NORMS U. S. Nuclear Reculatory Commission. Hashinaton. D. C.

Mr. L. P. Crocker, Licensing Project Manager - Hatch U. S. Nuclear Reculatory Commission. Reaion II .

Dr. J. N. Grace, Regional Administrator Mr. P. Holmes-Ray, Senior Resident Inspector - Hatch ,

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Georgia Power A U

ENCLOSURE 1

i PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 TRANSCRIPTION OF VIOLATION 87-30-02 AND GPC RESFONSE TRANSCRIPTION OF VIOLATION 87-30-02 Licensing Condition 2.C.(3) requires Georgia Power Company to maintain and implement in effect provisions of the fire protection ,

program as contained in the Units 1 and 2 Fire Hazards Analysis and -

Fire Protection Program.

Contrary to the above, the licensee did not implement in effect the documentation and records management provisions of the Fire Protection Program as shown below: .

l. Section 7.2 of Fire Protection Procedure 41FP-FPX01-0 states in part, that during the performance of each drill, members of the Engineering group with fire protection responsibilities shall complete the Fire Drill and Critique Report. However, of the six drills performed in 1986 and 1987, not all the Fire Drill ,

and Critique Reports were completed to the point of signature and documenting the drill as being sati sfactory or unsatisfactory.

2. Section 7.4 of Fire Protection Program Procedure 41FP-FPX01-0 requires that copies of the Fire Drill and Critique Reports and other Training Reports be maintained by the engineering group with fire protection responsibilities and be sent to Document '

Control in accordance with Document Control procedures.

However, the Fire Drill and Critique Reports for 1986 and 1987 -

had not been transmitted to Document Control.

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GeorgiaPower sh ENCLOSURE 1 (Continued)

TRANSCRIPTION OF VIOLATION 87-30-02 AND GPC RESPONSE

3. Section 8.3.5 of Administrative Control Procedure 20AC-ADH-002-0S requires Document Control to ensure that all required records have been received on a quarterly basis by comparing the log of received records to those identified as being required within that period in the Record Matrix.

However, this procedural requirement had not been accomplished in 1987 for all required fire protection records, i.e., the Fire Drill and Critique Reports.

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

RESPONSE TO VIOLATION 87-30-02 This violation consists of three examples. For ease of discussion, each of the three examplec will be responded to separately.

EXAMPLE 1 Admission or denial of violation:

The event occurred as stated in example 1 of the Notice of Violation.

Reason for the violation:

The violation occurred as the result of personnel error on the part of Fire Protection Engineering personnel. Specifically, the personnel failed to complete the Fire Drill and Critique Reports (as required by plant procedure 41FP-FPX01-0 [ Drill Planning, Critiques and Training Documentation]). A contributing factor to this error is that the procedure does not specifically provide time constraints relative to the maximum allowable time that can elapse 1 between the end of the drills and the completion of the documentation. As such, the fire drill critiques were not completed in a timely manner.

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GeorgiaPower d ENCLOSURE 1 (Continued)

TRANSCRIPTION OF VIOLATION 87-30-02 AND GPC RESPONSE Plant procedure 41FP-FPX01-0, Revision 0, states the following in section 7.4.1:

"Copies of Fire Drill and Critique Reports and Training Reports shall be maintained by the engineering group with fire protection responsibilities on each member of the Fire Brigade or Fire Emergency Support Group. Original training reports shall be sent to the Training Department to be placed in each member's training file."

Section 7.4.2 states the following:

"Copies of training reports shall be sent to Document Control in accordance with 20AC-DCX02-0, Document Control, and be maintained as permanent plant records in accordance with 20AC-DCX02-0, Plant Records Management."

1he disposition of the originals of the Training Reports is specifically addressed by the procedure. These originals are to be forwarded to the Training Department. The distribution of copies of these records is also addressed. The fire protection engineering personnel are to maintain a copy of these records and a copy of the records is to be transmitted to Document Control.

The Inspection Report that was attached to the Notice of Violation, on page 7 stated in part:

... None of the drill packages had been transmitted to Document Control as required by Section 7.4 of Procedure 41FP-FPX01-0.

All drill records reviewed were found in the possession of Engineering Fire Protection Group."

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Georgia Power b  :

ENCLOSURE 1 (Continued)

TRANSCRIPTION OF VIOLATION 87-30-02 AND GPC RESPONSE Corrective steps which have been taken and the results_ achieved:

The Fire Drill and Critique Reports were completed as required by plant procedure 41FP-FPX01-0. Fire Protection Engineering personnel were counseled regarding the need to complete the reports in a timely manner and the consequences of their actions.

Corrective steos which will be taken to avoid further violations:

Plant procedure 41FP-FPX01-0 will be revised to require Fire Drill and Critique Reports to be completed in a timely manner following a drill. This revision will be in place by June 1, 1988.

Date when full como11ance will be achieved:

Full compliance was achieved on November 20, 1987 when the above corrective actions were implemented.

EXAMPLE 2 Admission or denial of viola 1Lon:

The events did not occur as stated in example 2 of the Notice of Violation.

The Notice of Violation specifically states:

"Section 7.4 of Fire Protection Program Procedure 41FP-FPX01-0 requires that copies of the Fire Drill and Critique Reports and other Training Reports be maintained by the engineering group with fire protection responsibilities and be sent to Document Control in accordance with Document Control procedures.

However, the Fire Drill and Critique Reports for 1986 and 1987 had not been transmitted to Document Control."

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GeorgiaPower d l

ENCLOSURE 1 (Continued)

TRANSCRIPTION OF VIOLATION 87-30-02 AND GPC RESPONSE From the' quoted sections of plant procedure 41FP-FPX01-0, it can be seen that there is no procedure requirement for the records to be transmitted to Document Control. Since all of the records that the inspectors reviewed were found in the possession of the Fire Protection Group, Georgia Power Company (GPC) believes this example supporting the violation is not valid. GPC requests that this section of the violation be withdrawn.

Corrective steos which will be taken to avoid further violations:

Since GPC request: this example be withdrawn, no corrective actions are anticipated at this time.

Date when full comoliance will be_ achieved 1 Since GPC believes no violation occurred, GPC believes it was always in full compliance.

EXAMPLE 3 Admission or denial of violation: .

The violation occurred as stated in example 3 of the Notice of Violation.

Reason for the violation:

'he violation occurred as a result of procedure inadequacy.

Specifically, plant procedure 41FP-FPX01-0 does not establish a "frequency of generation" for Fire Drill and Critique Reports. Thase recorts are not generated at a set period (e.g. monthly, quarterly, jearly, etc.). Rather, the reports are generated "as required".

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GeorgiaPower d ENCLOSURE 1 (Continued)

TRANSCRIPTION OF VIOLATION 87-30-02 AND GPC RESPONSE The quarterly record check required by step 8.3.5 of procedure 20AC-ADH-002-0S (Plant Records Management), can not be performed on records with no established frequency of generation because Document Control personnel would not know when the reports are to be generated. As such, were such records not present were Document Control personnel to perform a quarterly record check, Document Control personnel would logically assume that the report was not required to be generated (and therefore, Document Control would not have a data package).

Additionally, plant administrative control procedure 20AC-ADH-002-0S was developed primarily on the document control requirements of ANSI N45.2.9 .- 1974 (Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants). This ANSI standard is referenced in the implementing references section of the procedure.

This ANS1 standard contains no specific requirement to perform a quarterly records check. This item was an enhancement to the Document Centrol program that GPC believed would be beneficial.

However, by containing this quarterly records check requirement, the plant procedure created the potential for non-compliance were it to be applied to records that have no fixed frequency of generation (as discussed above). This led to the violation.

Corrective steos which have been taken and the results achieved:

As a result of this event, a Temporary Change was implemented to remove the requirement to perform a records check from plant procedure 20AC-ADH-002-0S.

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GeorgiaPower d ENCLOSURE 1 (Continued)

TRANSCRIPTION OF VIOLATION 87-30-02 AND GPC RESPONSE It should be noted that a permanent revision to remove this requirement had been initiated prior to this inspection. GPC had recognized the potential for non-compliance for records with no fixed frequency of generation. However, before the corrective actions were implemented, the violation was cited.

Corrective steps which will be taken to avoid further violations:

Plant procedure 20AC-ADH-002-0S will be revised permanently to remove the requirement to perform a records check. This permanent revision will be in place by June 1, 1988. Procedure 41FP-FPX01-0 does not need revision (except as noted in other sections of this violation response) because, with deletion of the requirement to perform a recerds check, a frequency of generation for the Fire Drill and Critique Reports does not have to be established.

.Date when full comoliance will be achieved:

Full compliance was achieved on November 20, 1987 when the above corrective actions were performed.

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Georgia Power d ENCLOSURE 2 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 TRANSCRIPTION OF VIOLATION 87-30-03 AND GPC RESPONSE TRANSCRIPTION OF VIOLATION 87-30-03 Licensing Condition 2.C.(3) requires Georgia Power Company to maintain and implement in effect provisions of the fire protection program as contained in the Units 1 and 2 Fire Hazards Analysis and Fire Protection Program.

Contrary to the above, the licensee did not implement in effect the fire brigade drill provisions of the Fire Protection Program contained in administrative Procedure 40AC-FPX-007-0S (deleted 4/6/87) and 40AC-ENG-008-0S in that:

Section 8.2.5.4 and 8.2.3.4.5 respectively of the above proceduras, require that unsatisfactory fire brigade drill performance be followed by a repeat drill within 30 days.

Comments in the drill critique for unannounced drills held 12/18/86,12/19/86, 7/1/87, and 7/30/87 indict.te the drilis were unsatisfactory; however, re-drills were not conducted.

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

RESPONSE TO VIOLATION 87-30-03 edmission or denial of violation:

The violation occurred as cited in the Notice of Violation.

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Georgia Powerkh l

l ENCLOSURE 2 (Continued)

TRANSCRIPTION OF VIOLATION 87-30-03 AND GPC RESPONSE Reason for the violatioD:

The violation occurred as the result of personnel error on the part of Fire Protection Engineering personnel. Specifically, the personnel failed to comply with the re-drill requirements of procedure 41FP-FPX01-0.

Corrective steps which have been taken and the results achievedi The involved Fire Protection Engineering personnel were counseled about the event and the need for strict adherence to all plant procedures.

Additionally, plant personnel reviewed subsequent fire protection drill data packages per the requirements of plant procedure 41FP-FPX01-0. The review was to determine if any unsatisfactory drills occurred and to determine if re-drills for unacceptable driils were necessary and had occurred as required.

Based on the required review, it was determined that the procedural requirements of plant procedures 41FP-FPX01-0 and 40AC-ENG-008-0S (Fire Protection Program) were satisfied with the performance of six drills in the months of November and December,1987 (five unannounced drills and one re-drill). These six drills were properly documented on Fire Drill and Critique Report forms as required by the procedure. The completed report forms were transmitted to Document Control.

Corrective steps which will be taken_to avoid further violations:

Based on the above corrective actions, GPC believes that no additional corrective actions are required at this time.

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- Georgia Power d ENCLOSURE 2 (Continued)

TRANSCRIPTION OF VIOLATION 87-30-03 AND GPC RESPONSE Date when full como11ance will be achieved:

Full compliance was achieved on November 20, 1987 when the Fire Protection Engineering personnel were counseled as part of the co rective actions for violation 87-30-02, example 1.

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