ML20207N104

Responds to NRC Re Violations Noted in Insp Repts 50-321/86-30 & 50-366/86-30 on 861005-09.Corrective Actions: Special Purpose Procedure 52SP-100386-IE-1-2S Revised & Performed on 861009 & ASME Code Clarified

ML20207N104
Person / Time
Site:	Hatch
Issue date:	12/31/1986
From:	Gucwa L GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
SL-1815, NUDOCS 8701130464
Download: ML20207N104 (8)

Text

Georgia Power Cornpany 333 Piedmont Avenue

- Att:nta, Georgia 30308 Telephone 404 526-6526 Mailing Address:

Post Office Box 4545 Attanta, Georgia 30302 Georgia Power L T. Gucwe the southern electrc system Manager Nuclear Safety and Ucensing SL-1815 1006C December 31, 1986 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 ,

NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF EDWIN I. HATCH NUCLEAR. PLANT UNITS 1, 2 INSPECTION REPORT 86-30 Gentlemen:

The following information _is submitted in response to the Notice of

' Violation cited in NRC Inspection Report Nos. 50-321/86-30 and 50-366/8d-30, dated December 1, 1986.- The report addresses the inspection performed by Mr. S. D.~ Stadler during the period October 5 through October 9,1986.

NRC NOTICE OF VIOLATION A:

" Technical Specification 6.8.1.a req'uires 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 reconnends establishment of procedures to - control contamination and for the performance of safety-related maintenance.

Technical Specification 6.8.1.c requires the licensee to establish and implement procedures for the conduct of surveillance and test activities of safety related equipment.

Plant Procedure 62RP-RAD-017-0, Release Surveys for Trash and Materials leaving Operating Buildings, requires that the Health Physics Technician at C-52 is responsible for ensuring that all persons exiting the control building use the monitors upon exit.

Preventive Maintenance Procedure 52PN-MNT-005-0S, Revision 3, Limitorque Valve Operator Inspection, step 7.6.6.13, states in part, perform limit switch adjustment in accordance with 52GM-MNT-017-0S, Limitorque Valve Operator Setup and Test. Procedure 52GM-MNT-017-0S was replaced by Procedure 52GM-MEL-022-0S on February 1986. 52GM-MEL-022-0S contains the limit switch adjustment instruction.

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Georgia Power d U. S. Nuclear Regulatory Commission Document Control Desk December 31, 1986 Page 2 NRC NOTICE OF VIOLATION A: (continued)

Contrary to the above,

1. The licensee failed to provide adequate procedures to control test activities on the 2C emergency diesel generator on Monday, October 6 and Wednesday, October 8,1986.

2. The requirement that personnel use the monitors when exiting the control building and that the HP technician ensure this is accomplished was not met in that on October 9,1986, a contractor was observed exiting the RCA at Control Point C-52 without using the monitor.

3. In August 1986, for Maintenance Work Orders, 2-86-2136, 2-86-2137 and 2-86-54 the licensee failed to perform the required limit switch adjustments in accordance with Preventive Maintenance Procedure 52PM-MNT-005-0S.

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

RESPONSE TO NRC NOTICE OF VIOLATION A:

Admission or Denial of alleged violation: Certain elements of the Notice of Violation, which had no actual safety consequences, occurred, but not as stated. For ease of consideration, the Notice of Violation is divided into its three component subparts. Subpart 1 cccurred, but not as stated; subpart 2 cannot be determined and, therefore, is denied; and, subpart 3 is denied.

Reason for violation:

1. Special purpose procedure 52SP-100386-IE-1-2S, Diesel Generator 2C Low Speed Run, was developed to provide instructions for performing a low speed run of the 2C diesel generator in order to " break-in" a newly installed turbocharger. The procedure was intended to be performed in conjunction with 34SV-R43-001-2S, Diesel Generator Manual Start. Therefore, contrary to statements in the inspection report, procedure F?SP-100386-IE-1-2S was not performed to meet testing or surveil'.ance requirements of the plant Technical Specifications and, therefore, was not required by Technical Specifications 6.8.1.c. The procedure was reviewed and approved in accordance with 10AC-MGR-003-0S, Rev. 5, which required maintenance department manager approval and Plant Review Board review.

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Georgia Power d U. S. Nuclear Regulatory Commission Document Control Desk December 31, 1986 Page 3 RESPONSE TO NRC NOTICE OF VIOLATION A: (continued)

Procedure 52SP-100386-IE-1-2S did not include all necessary prerequisites for conducting a low speed run of the 2C diesel generator. The procedure writer and the technical reviewer did not identify the discrepancies. Also, the pre-test briefing, as required by AG-MGR-21-0386N, Evolution Pre-Test Brief Requirements, did not address the inadequacies of Rev. O of the special purpose procedure or identify and resolve misconceptions inherent in Rev. 1 of thi::

special purpose procedure. We strongly believe that this is not a severity level IV violation, i.e., failure to meet regulatory requirements that have more than minor safety or environmental significance. It is our belief that the limited safety significance of this portion of the violation is such that it warrants being downgraded to a Severity Level V.

2. The information in the inspection report contains insufficient information to confirm or deny the alleged violation. Under certain circumstances, it is clearly permissible to bypass the monitor at portal C-52 without frisking. As far as we can determine, the NRC inspector did not take action to stop the violation or the subject individual after it occurred. Also, Health Physics Supervision was not notified of the alleged violation, and, therefore, was not able to investigate at or near the time of the event. It is quite possible that the contractor in question frisked at the PCM-1 monitor at C-52, received a contamination alarm, and reported to the Health Physics personnel for a confirmatory frisk. Af ter reporting to the Health Physics parsonnel for a frisk and determining that he was not contaminated, it would have been proper for the contractor to exit the RCA through C-5 without having to refrisk at the PCM-1 monitor which the inspector may have witnessed. We have sensitive portal J

monitors such that the above scenario is highly possible. This violation is denied.

3. As stated in the Notice of Violation, limit switch adjustments were not made in accordance with 52GM-MNT-017-0S, Limitorque Valve Operator Setup and Test, as set forth in step 7.6.6.13 of Rev. 3 of 52PM-MNT-005-OS, Limitorque Valve Operator Inspection. Even though step 7.6.6.13 states " perform limit switch adjustments in accordance with 52GM-MNT-017-0S ...", the intent of the procedural step was to require limit switch adjustment only if necessary. Maintenance personnel determined that limit switch adjustment was not necessary since a satisfactory functional test was perfonned per 52PM-MNT-005-0S to verify proper limit switch operation. Therefore, the intent of the procedural requirement was clearly met. This violation is denied. We also wish to note respectfully that our 1006C

'*"* - . _____ __ = _ -__ _ - --. _ _ _ - . ._-.-_. _.

GeorgiaPowerd U. S. Nuclear Regulatory Connission Document Control Desk December 31, 1986 Page 4 RESPONSE TO NRC NOTICE OF VIOLATION A: (continued)

Procedures Upgrade Program (PUP) will result in Plant Hatch developing a large number of very detailed procedures. These procedures will . be thoroughly validated (as required by the PUP) to insure they are technically adequate, user friendly, and completely incorporate all regulatory licensing requirements. We are totally committed to obtaining and following excellent procedures. However, our major improvement efforts seem to be causing a relatively large number of non-compliance issues. This has, in our view, inappropriate and negative implications on our performance. A discussion on the implications of such NRC policy seems appropriate. We plan on contacting you for a meeting on this subject in the near future.

Corrective steps which were taken and the results achieved:

! 1. Special . purpose procedure 52SP-100386-IE-1-2S was revised and satisfactorily performed on October 9,1986.

2. Training and existing Health Physics controls are adequate to ensure the proper frisking of personnel exiting the RC A.- However, your observation resulted in additional attention being directed to our '

controls which provide further assurance that they are being properly implemented.

3. Procedure 52PM-MNT-005-0S was revised on October 29, 1986, in order to clarify further the procedural requirement for performing limit switch adjustments. The procedure now requires that "if limit switches do not make and break as required, limit switch adjustments must be made per approved plant procedure."

Corrective steps which will be taken to prevent recurrence:

1. Concerned personnel will be counseled by' January 15, 1987, concerning special purpose procedure 52SP-100386-IE-1-2S and pre-test briefings.

2. No further actions are believed to be required.

3. No further actions are believed to be required.

Date when full compliance will be achieved:

1. Full compliance was achieved with the satisfactory performance of 52SP-100386-IE-1-2S.

2. Plant Hatch is in full compliance with it regulatory commitments reflected in procedure 62RP-RAD-017-0.

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- Georgia PowerA U. S. Nuclear Regulatory Coannission Document Control Desk December 31, 1986 Page-5 l RESPONSE TO NRC NOTICE OF VIOLATION A: (continued)

3. Full compliance was achieved.with the current interpretation of the requirement . in our revision of. procedure _52PM-MNT-005-0S that L clarified the limited procedural requirement.

. NRC NOTICE OF VIOLATION B:

" Unit 1 Technical Specifications 3.7.D.1. and 4.7.D.1 and Unit 2 Technical

Spect fications. 3.6.3 . and 4.6.3.3 require that primary containment n isolation valves listed be operable, and that the isolation times shall be demonstrated to be within the required limits.

, Unit 2 Technical Specification 4.0.5 . require that inservice testing of '

ASME Code Class.1, 2, and 3 valves shall be performed in accordance with

. Section XI of the . ASME Boiler and Pressure Vessel Code except where i specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i). ASME Section XI defines stroke time as .the time interval from initiation of the actuating signal to the end of the actuating cycle. The E. I. Hatch Pump and Valve Test Plan also defines

' full-stroke time as that time interval from initiation of the actuating

. signal to the end of the actuating cycle.

i Contrary to the above, the licensee does not stroke time test power operated valves from initiation of the actuating signal to the end of the actuating cycle'as required by Technical Specifications and ASME Section XI and the licensee has not received specific written relief from the requirements of the ASME code that requires stroke time testing from initiation of the actuating signal to the end of the actuating cycle.

This is a Severity Level IV violation (Supplement 1)."

RESPONSE TO NRC VIOLATION B:

)

i Admission or Denial of alleged violation: The event, which had no safety consequences, occurred. However, GPC respectfully requests withdrawal of this violation due to the contribution of unclear Code requirements coupled with- GPC's conscious, good faith efforts to comply with its

! reasonable interpretation of those requirements. Imposition of a violation in this unique circumstance would not be a fair application of

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NRC's Enforcement Policy (10 CFR 2, App. C). More specifically, since

! GPC had attempted to interpret and resolve the Code requirements on stroke time testing and had concluded that light-to-light timing

= measurements were permissible, GPC believes that, at the time of the alleged violation, the Code commitment as presently construed by the NRC 1006C

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Georgia Power d U. S. Nuclear Regulatory Commission Document Control Desk December 31, 1986 Page 6 RESPONSE TO NRC NOTICE OF VIOLATION B: (continued) was not a legally binding requirement. Viewed relative to Code interpretations prior to issuance of the Notice of Viol ation, GPC's interpretation of Code requirements conflicted with that of the NRC; i.e., the " commitment" was subject to different interpretations. Upon NRC's specific notification, however, GPC immediately adopted the NRC interpretation.

Reason for violation: The violation was apparently the result of misinterpreting the requirements of paragraph IWV-3413 of the 1980 Edition of the ASME Code,Section XI. As a result of the then 10 CFR 50.55a requirements, GPC, in April 1979, updated the inservice inspection program to the requirements of the 1974 Edition of the ASME Code,Section XI, with Addenda through Summer 1975. That particular edition and addenda of the Code required inservice inspection of pumps and valves at Hatch Unit 1 for the first time relative to Code requirements. At the -

time the program was updated, it was determined based on an interpretation of the wording that stroke time testing of power operated valves would be performed li ght-to-l i ght. Light-to-light stroke time testing provided indication of valve movement; therefore it was considered by GPC as an adequate method for monitoring valve degradation. It should be noted that " full stroke time" for power operated valves was not defined by the 1974 Edition of the ASME Code,Section XI, with Addenda through Summer 1975. Inservice testing of pumps and valves at Hatch Unit 2 originally was conducted to the requirements of the 1974 Edition of the ASME Code,Section XI, with Addenda through Summer 1975.

In 1983, based on an NRR recommendation, the ISI/IST program was voluntarily updated to the 1980 Edition of the ASME Code,Section XI, with Addenda through Winter 1980 for both Hatch units. The intent of this voluntary update was to have both units placed under the same edition and addenda of the Code regardless of their commercial operation dates on which the ten-year inservice inspection interval is based. The updated ISI/IST was submitted to NRR by letter dated August 12,1983, and specifically indicated that usage of the aforementioned edition and addenda of the Code would become effective January 1,1984. Paragraph IWV-3413 of the 1980 Edition of the ASME Code,Section XI, with Addenda through Winter 1980 defined full stroke time as the time interval from initiation of the actuating signal to the end of the actuating cycle. In reviewing the code changes while preparing the update of the ISI/IST program, the full stroke time requirement was apparently misinterpreted in that the light position indication was taken as being indicative of the initiation of the " actuating signal". Therefore, a change was not made to the plan nor was relief from the Code requested. The discrepancy

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s. a Georgia Power d U. S. Nuclear Regulatory Commission Document Control Desk December 31, 1986 Page 7.

RESPONSE TO NRC NOTICE OF VIOLATION B: (continued) between the light-to-light testing and the Code requirement was later noted in a Quality Assurance Audit in November 1984 (ref. QAFR .

84-SA-7/174). At that time, GPC and its consultant confirmed that the intent of the Code . was met by the light-to-light timing. Due to .this fact, a relief request to Code requirements was not requested. Based on review of our August 12, 1983, submittal, NRR indicated that GPC must submit a new ISI/IST program by June 30, 1985, for the new ten-year inspection interval that was to - begin on January 1, 1986, for Hatch Unit 1. The program also requested that a new inspection interval for Hatch Unit 2 be allowed to consnence on January 1,1986, in order that the two units could be placed under the same edition and addenda of the Code for ISI/IST purposes. In our ISI/IST program document submitted by GPC letter NED-85-483, dated June 25, 1985, a general note was incorporated into the program document noting that valve stroke timing would be performed "by measuring the interval between the start and end of . valve travel as shown by the remote indicating lights, unless otherwise specified in this program." The 1980 Edition of the ASME Code, Section

• XI, with Addenda through Winter 1981 was the Code of record for the NRC requested update.

As noted above, on several different occasions GPC interpreted paragraph IWV 3413 to mean light-to-light. The intent of the paragraph is to monitor potential valve degradation. By measuring from light-to-light, GPC met the intent of the paragraph. GPC has always been open in stating our interpretation of the ASME Code. The technical difference between light-to-light and switch-to-light is considered to be of such a nature not to be of an immediate safety concern. The corrective actions both taken and to be taken reficct this belief.

Corrective steps which were taken and the results achieved: Steps have been taken to request a formal interpretation of the ASME Code as to the meaning of " actuating signal". Appropriate personnel have been notified of the apparent incorrect interpretation of the Code requirement for full stroke time testing of power operated valves. The misinterpretation is '

considered to be an isolated occurrence. The existing program for review of the ISI/IST updates and Code changes is sufficient to prevent recurrence.

Corrective steps which will be taken to prevent recurrence: The ISI/IST Program will be revised to meet the requirement for full stroke time testing as specified in paragraph IWV-3413 of the 1980 Edition of the 1006C um _____ _ _.

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Georgia Power 1 U. S. Nuclear Regulatory Commission Document Control Desk December 31, 1986 Page 8 RESPONSE TO NRC NOTICE OF VIOLATION B: (continued)

ASME Code,Section XI, with Addenda through Winter 1981 in that power operated valve stroke time testing will be performed switch-to-light rather than light-to-light unless specifically exempted by the NRC. An engineering analysis will be made of existing stroke tine requirements to determine if changes to the stroke times are required. Stroke times specified in Hatch Units 1 and 2 Technical Specifications and the Pump and Valve Test Plan will be revised as required. Approximately 24 procedures are expected to be revised to incorporate the revised stroke time testing methodology.

Date when full compliance will be achieved: Initial engineering analysis of the existing stroke times will be performed by April 1, 1987.

The results of the initial analysis will indicate what additional steps, including additional analysi s, will be necessary. ISI/IST Program changes will be submitted in a revision to the program document that was submitted to NRR by our letter NED-85-483. This revision is scheduled to be submitted April 1, 1987. Technical Specification changes, if required based on the analysis, will be submitted after completion of the final analysis. Procedure changes will be made through the Procedures Upgrade Program. As stated previously, GPC request withdrawal of this proposed violation.

If you have any questions, please contact this office.

X Sincerely, fWm L. T. Gucwa MJB/lc c: Georgia Power Company U. S. Nuclear Regulatory Commission Mr.s. P. O'Reilly Dr. J. N. Grace, Regional Administrator Mr. J. T. Beckham, Jr. Mr. P. Holmes-Ray, Senior Resident Mr. H. C. Nix, Jr. Inspector - Hatch GO-NORMS 1006C 7""$ ____. . - . . _ _ . , . _. --.