ML20205D793
| ML20205D793 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 07/29/1986 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | John Miller GEORGIA POWER CO. |
| References | |
| NUDOCS 8608180174 | |
| Download: ML20205D793 (3) | |
See also: IR 05000321/1986011
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JUL 2 91486
Georgia Power Company
WATTN: Mr. J. H. Miller, Jr.
President
P. O. Box 4545
Atlanta, GA 30302
Gentlemen:
SUBJECT: REPORT NOS. 50-321/86-11 AND 50-366/86-11
Thank you for your response of May 30, 1986, to our Notice of Violation issued on
April 30, 1986, concerning activities conducted at your Hatch facility.
After careful consideration of the bases for your denial of the violation, we
agree with your analysis that there was not a violation relative to performance
of pressure tests since the tests were not required by previous Codes and were
performed prior to the end of the recent maintenance / refueling outage for the
particular unit, thereby meeting the 1980 Edition of the ASME Section XI Code.
However, for reasons presented in the enclosure to this letter, we still consider
that a violation existed relative to not having procedures for scheduling the
required tests.
We have concluded that the Severity Level should be decreased
from Severity Level IV to Severity Level V.
In accordance with 10 CFR 2.201(a),
please submit to this office within 30 days of the date of this letter a written
statement describing steps which have been taken to correct the violation and the
results achieved, corrective steps which will be taken to avoid further viola-
tions, and the date when full compliarce will be achieved.
The response directed by this letter is not subject to the clearance procedures
of the Office of Management and Budget issued under the Paperwork Reduction Act
of 1980, PL 96-511.
We appreciate your cooperation in this matter.
Sincerely,
\\S\\
J. Nelson Grace
Regional Administrator
,
Enclosure:
Staff Assessment of Licensee
Response
cc w/ enc 1:
(See page 2)
8608180174 860729
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Georgia Power Company
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A . P. O'Reilly, Senior Vice President,
d.NuclearOperations
T. Beckham, Vice President and
_ j eneral Manager-Nuclear Operation
G
m. C. Nix, Site General Manager
' #. Fraser, Acting Site QA Supervisor
rk. Gucwa, Manager, Nuclear Safety
and Licensing
bec w/ encl:
JRC Resident Inspector
A"jh S. Jordan, Executive Secretary
Document Control Desk
State of Georgia
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ENCLOSURE
STAFF ASSESSMENT OF LICENSEE RESPONSE
Region II has reviewed the licensee's response of May 30, 1986, to the Notice of
Violation issued April 30, 1986.
After a careful review of the Georgia
Power Company response, the staff has found the licensee's response to part of
the violation (relative to the performance of required pressure tests) to be
acceptable, but part of the response (relative to the requirement for procedures
for scheduling pressure tests) to be unacceptable.
The licensee's letter of response states, "no specific regulatory requirement
exists for implementing procedures for scheduling and tracking of surveillance
items, such as pressure tests."
Contrary to this statement, Hatch Units 1 and 2
Technical Specification (TS) 6.8.1 requires that " written procedures shall be
established, implemented, and maintained covering the activities referenced
below."
Paragraph c. of TS 6.8.1, as referenced in the Notice of Violation,
requires procedures for " Surveillance and test activities of safety-related
equipment."
To further define what procedures are required, paragraph a. of
TS 6.8.1 requires, "The applicable procedures recommended in Appendix "A" of
Regulatory Guide 1.33, Revision 2. February 1978." Paragraph 1.f. of Regulatory
Guide 1.33 recommends Administrative Procedures for, " Schedule for Surveillance
Test and Calibration." Therefore, specific regulatory requirements do exist for
implementing procedures for scheduling and tracking surveillance items such as
pressure tests.
Based on the above discussion, the violation remains for not having implementing
procedures for scheduling pressure tests.
Since it appears that all required
tests were performed as required by code, the Violation is changed from Severity
Level IV to Severity Level V.
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