ML20204F390

Responds to NRC Re Violations Noted in Insp Repts 50-321/88-24 & 50-366/88-24.Corrective Actions:Plant Drawing Revised to Accurately Reflect Physical Arrangement of Electrohydraulic Control Unit Piping

ML20204F390
Person / Time
Site:	Hatch
Issue date:	10/11/1988
From:	Hairston W GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
0502I, 502I, HL-100, NUDOCS 8810210568
Download: ML20204F390 (8)

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Sv gr y ce Pre's de'1 FLc'e.?r C's erdt ces HL-100 0502I X7GJ17-H120 October 11, 1988 U. S. Nuclear Regulatory Cornmission ATTN: Document Control Desk Hashington, D.C. 20555 PLANT HATCH - UNITS 1, 2 HRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 RESEQESE TO INSPECTION REPORT 88-24 Gentlemen:

In response to your letter of September 22, 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 88-24. 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, j{},) kro- W H. G. Hairston, III JJP/lg

Enclosures:

1. Violation 88-24-01 and GPC Response

2. Violation 88-24-02 and GPC Response c: (see next page) pl 8G10210568 891011 8 i PDR ADOCK 050007?1 g PDL

Georgia Power d U. S. Nuclear Regulatory Commission October 11, 1988 Page Two c: Georola Power Company Mr. H. C. Nix, General Manager - Plant Hatch Mr. L. T. Gucwa, Manager Licensing and Engineering GO-NORMS U. S. Nuclear Regulatory Commission. Washington. D. C.

Mr. L. P. Crocker, Licensing Project Manager - Hatch U. S. Nuclear Regulatory Commission. Region II Dr. J. N. Grace, Regional Administrator Mr. J. E. Henning, Senior Resident Inspector - Hatch 0502I

Geo gia Power d ENCLOSURE 1 PLANT HATCH - UNIT 2 NRC DOCKET 50-366 OPERATING LICENSES NPF-5 VIOLATION 88-24-01 AND GPC RESPONSE VIOLATION 88-24-01 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances.

Contrary to the above, an inadequate Electrohydraulic Control (EHC)

, system drawing resulted in an inappropriate equipment clearance which, in turn, resulted in inadvertent closing of the Unit 2 low pressure turbine intercept valves on August 9,1988. Drawing H-21243 did not accurately reflect the as-built EHC pump discharge piping.

, This inadequate drawing was used in the preparaticn of equipment clearance resulted in 2-88-1336 and a clearance that was inappropriate for existing plant conditions. The intercept valves i were inadvertently closed when the clearance was being placed on the

EHC system.

1 This is a Severity Level IV violation (Supplement 1). (Unit 2 only)

RESPONSE TO VIOLATION 88-24-01 l

i Madis10a_0Ldenial of violation:

The violation occurred as described in the Notice of Violation.

l i

0502I El-1 10/11/88 HL-100

Georgia Power d ENCLOSURE 1 (Continued)

VIOLATION 88-24-01 AND GPC RESPONSE Reason for the violation:

The violation was caused by personnel error in that plant engineering personnel incorrectly revised a plant drawing which resulted in the inadvertent isolation of electrohydraulic control (EHC) fluid to the turbine valves during the performance of a clearancs. Following implementation of Design Change Request (DCR)83-175, plant drawing H-21243, "Turbine Generator Auxiliary Systems I. E. D.: Control Oil and Control Fluid," was updated via As-Built Notices (ABNs)87-630, 88-377, and 88-392 to reflect the physical changes to the system.

These ABNs were performed incorrectly in that they indicated valve 2N32-FV20 would not affect the flow of EHC fluid to any of the turbine valves when, in fact, closing the valve isolated EHC fluid to two of the four Turbine Combined Intercept Valves (CIVs).

On 08/09/88, plant Operations personnel used the improperly updated plant drawing to write clearance 2-88-13M o replace EHC pump 2N32-C0018. The clearance required valve 2N32-FV20 to be closed.

When the clearance was performed and valve 2N32-FV20 closed, EHC fluid to the CIVs was isolated.

Corrective steos_which have been taken and thL results_ achieved:

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

1. Plant drawing H-21234 was revised on 8/10/88 by ABN 88-505 to accurately reflect the physical arrangement of EHC hydraulic unit piping. The ABN clearly shows that closing valve 2N32-FV20 isolates EHC fluid to the turbine valves.

05021 El-2 10/11/88 HL-100

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Ge ugia Power d ENCLOSURE 1 (Continued)

VIOLATION 88-24-01 AND GPC RESPONSE

2. Plant personnel determined that the engineer who had made the error is no longer employed by Georgia Power Company (GPC). As such, there are no corrective actions that apply to this individual. However, GPC will implement corrective actions for engineers who are currently employed, as described in the section presenting corrective steps to avoid further violations.

Corrective stens which will be taken to avoid further violations:

As part of the investigation of this event, plant personnel reviewed the DCR package for Unit 1. (This DCR package installed a modification on Unit I that was similar to the modification installed on Unit 2.) During the review, they determined that there was no plant drawing (i.e., a drawing assigned a specific "H" drawing number) for the Unit 1 EHC System. A plant drawing is being created from the vendor's (General Electric) drawing and will correctly reflect the as built EHC system for Unit 1. (It should be noted that the vendor drawing was on site and was used by plant personnel.) The new drawing will be completed and issued by 1/20/89.

As previously stated, the engineer who committed the error is no longer employed by GPC. However, this event will be included in the fourth quarter's (1988) Engineering Continuing Training in order to emphasize the importance of completing accurate ABNs.

Date_yhen full compliance will be achieved:

Full compliance was achieved on August 10, 1988 when the above corrective actions were implemented.

0502I Ei-3 10/11/88 HL-100

Georgialbwer A 1

ENCLOSURE 2 PLANT HATCH - UNIT 1 i NRC DOCKETS 50-321 l OPERATING LICENSES DPR-57 VIOLATION 88-24-02 AND GPC RESPONSE t

VIOLATION 88-24-02 Technical Specification 6.8.1.a requires that written procedures be established, implemented, and maintained for the applicable activities i. Appendix A of Regulatory Guide 1.33, Revision 2 .

February 1978.

Appendix A of Regulatory Guide 1.33, Revision 2, recommends I ,

procedures for operation of the turbine-generator system. L Procedure 3450-N34-008-1N, "Turbine Generator Bearing 011 System",

3 provides written instructions for operation of the Unit I turbine-generator bearing oil system.

l Contra ,' to the above, procedure 3450-N34-008-1N was inadequate in i that it did not provide instructions for the swapping of lube oil l coolers. On April 19, 1988, operations personnel performed the (

swapping operation without procedural guidance and inadvertently introduced air into the turbine lube oil system. This resulted in a j turbine trip and automatic scram in Unit 1.

This is a Severity Level IV violation (Supplement 1). (Unit 1 only) i j RESPONSE TO VIOLATION 88-24-02 l

! Mahslon or _ denial of violation: '

1 The violation occurred as stated in the Notice of Violation.  !

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f 0502I E2-1 10/11/88 HL-100 i I

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Georgia Power d ENCLOSURE 2 (Continued)

VIOLATION 88-24-02 AND GPC RESPONSE

[

Reason for the violation:

The violation was caused by an inadequate procedure in that procedure 34S0-N34-008-1N, "Turbine Generator 8 earing 011 System," did not include detailed steps for removing from service the operating lubrication oil cooler and starting the standby lubrication oil cooler. A contributing cause was personnel error by plant Operations personnel in that the shift supervisor assigned a Plant Equipment Operator (PEO) to perform the exchange of the turbine lubrication oil coolers without verifying the PE0 had sufficient experience to perform this task. Furthermore, the PE0 failed to inform the shif t supervisor he was unfamiliar with the task.

Corrective steps which have been_taken and the results achieved:

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

1. The involved operations personnel were counseled relative ,

to this event and its consequences. i

2. Procedures 34S0-N34-008-IN and 34SO-N34-008-2N, "Turbine Generator Bearing Oil System," were revised to include the detailed steos necessary for removing from service the 4

operating 1 ,rication oil cooler and starting the standby lubricatic til cooler. These revisions were effective  !

5/11/88 and 5/13/88, respectively. [

Corrective steps which will be taken_to_ayoid further violation 1:

Corrective actions were taken, as described above, which should preclude recurrence of the cited events. No further corrective  :

t actions are anticipated at this time. '

0502I E2-2 10/11/88 l HL-100 i

Georgia Poner d

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ENCLOSURE 2 (Continued)

VIOLATION 88-24-02 AND GPC RESPONSE Date whe 1 full c - 11ance will be achieved:

Full compliance was achieved on May 13, 1988 when the above corrective actions were implemented.

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0502! E2-3 10/11/88 HL-100