ML20207R893
| ML20207R893 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 03/09/1987 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| SL-2085, NUDOCS 8703180266 | |
| Download: ML20207R893 (3) | |
Text
7-Georga Fbwer Cornp:ny 333 Piedmont Avca n y
Ati:sta Georga 30'40 Telephon) 404 526 6526 Maihng Address Fbst Ottsce Box 4545 Atlanta, Georg,a 30302 Georgia Power L T. Gucwa n,, w,,n,.y pr ggfn Marager Nuclear Safety SL-2085 and ucensno ll69C March 9, 1987 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C.
20555 NRC 00CKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1, 2 INSPECTION REPORT 86-39 Gentlemen:
The following information is submitted in response to Inspection Report Nos. 50-321/86-39 and 50-366/86-39 dated February 6, 1987.
The report concerns the inspection performed on November 15-November 21,1906.
NRC NOTICE OF VIOLATION:
" Paragraph III. A.l(a) of Appendix J to 10 CFR 50 and Paragraph 4.2. of ANSI-N45.4-1972, incorporated into the regulations by Paragraph III.A.3(a) of Appendix J to 10 CFR 50, require that the Type A test shall be performed prior to making any repairs or adjustments to the containment boundary so that the "as is" (also called "as found")
containment integrated leak rate can be determined.
Where repairs or adjustments to the containment boundary prior to the Type A test are necessary, Paragraph !!!.A.l(a) in conjunction with Paragraph III. A.l(b) of Appendix J to 10 CFR 50 permit the repairs or adjustments provided:
(1) the change in leakage rate resulting from such repairs or adjustments is determined using local leakage testing methods; and (2) the corrective action taken, the change in leakage rato detemined from the local tests, and the "as is" containment integrated leakage rate determined from the local leakage and Type A test results are obtained, and the results are included in the report to the Coumission.
Contrary to the above, during the 1986 Unit 2 refueling outage, repairs or adjustments were made on two equipment hatches and one isolation valve limitorque actuator prior to the Type A test.
The change in Icakage rate resulting from the repairs or adjustments was not measured using local leakage test methods.
Failure to quantify the change in leakage rate resulting from these repairs or adjustments to the containment boundary renders the calculation of the "as is" containment integrated leakage rate indeterminable.
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This is a Severity Level IV violation (Supplement I)."
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Georgia Power A U. S. Nuclear Regulatory Commission March 9, 1987 Page Two RESPONSE TO NRC NOTICE OF VIOLATION:
Admission or Denial of alleged violation:
The violation did occur.
It should be noted that the cited cases were licensee identified:
a.
The failure to perfom a Local Leak Rate Test (LLRT) on the two drywell equipment hatches at the required time was reported via Deficiency Report number 2-86-452 on September 19, 1986.
b.
The failure to LLRT valve 2P42-F052 at the required time was reported via Deficiency Report number 2-86-598 on October 16, 1986.
The Deficiency Reports were determined to be non-reportable under the provisions of 10 CFR 50.73.
The circumstances described fit a Severity Level V category as being an item of minor safety significance.
- However, this item qualifies for full mitigation since corrective actions will be completed in a reasonable and timely manner, as explained below.
There have been no similar violations.
Therefore, we request that this violation be mitigated in its entirety as provided by enforcement policy (10 CFR 2 Appendix C.V.A.).
Reason for Violation:
The failure to LLRT the two drywell equipment hatches at the required time was due to an inadequate procedure.
The
" work requested" section of Maintenance Work Orders 2-86-3655 and 2-86-3657 called for removal of the hatches "following 'as found' LLRT."
llowever, the " work instruction" section of the same MW0s called for " work per 52GM-Mite-005-0S".
Procedure 52GM-MME-005-0S did not have a step, nor was there a QC hold point, to insure the LLRT was performed prior to renoval of the hatches.
The failure to LLRT valve 2P42-F052 at the required time was the result of inadequate administrative procedure, in that there was inadequate infomation to ensure the LLRT was performed prior to valve actuator disassembly.
Corrective steps which were taken and the results achieved:
The personnel responsible for the drywell equipment hatches being removed prior to the LLRT being performed were counseled as to the sequence of events, the actions they should have taken, and the consequences of their error.
Corrective steps which will be taken to prevent recurrence:
The administrative control procedure that controls the performance of site main'enance via an MWO (i.e.,
the " MAINTENANCE PROGRAM" procedure, 50/I-MNT-001-05) will be revised to require that plant personnel screen itW0s, and if an LLRT component is involved, they are to indicate on the MWO that the LLRT coordinator is to be contacted prior to beginning work on the component.
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Georgia Powerd U. S. Nuclear Regulatory Commission March 9,1987 Page Three RESPONSE TO NRC NOTICE OF VIOLATION: (continued)
Date when full compliance will be achieved: Procedure 50AC-MNT-001-0S is scheduled to be revised and in effect by May 8,
1987.
This is approximately 17 months before the next outage in which a Type A test will be required.
GPC requests that the citation be withdrawn consistent with the NRC's Enforcement Policy.
As explained in the Policy (10 CFR 2 Appendix C.V.8), the "NRC attaches great importance to comprehensive licensee programs for detection, correction and reporting of problems that may constitute, or lead to, violation of regulatory requirements.
This is emphasized by giving credit for effective licensee audit programs when licensees
- find, correct, and report problems expeditiously and ef fectively. "
In the instances supporting the cited violation, GPC's Deficiency Reporting program, which has been augmented recently by increasing training and distribution of "Stop Deficiency" cards to be carried by employees, resulted in the identification of the cited events, hence they were " licensee identi fied. "
The additional administrative controls requiring the LLRT coordinator's oversight of MW0s assures corrective action sufficient to preclude similar instances.
- Finally, with respect to reporting, the events were determined to be non-reportable under applicable regulations.
In view of the foregoing, GPC believes good cause exists for withdrawal of the violation.
GPC contends that a balanced review of the events, as well as the condition of the containment of Unit 2, indicates that minor safety significance existed. As recognized in the Inspection Report, failure to determine the "as found" leak rate "is not an immediate safety problem,"
and a subsequent licensee initiated test verified the ability of the containnent to perform its safety function.
Additionally, it is noted in the body of the report as being applicable only to Unit 2; however, the citation does not reficct this determination.
If you have any questions in this regard, please contact this office at any time.
Sincerely, cW.
e L. T. Gucwa HJB/lc c: Georgia Power Company U. S. Nuclear Regulatory Conaission Mr. t. P. O'Reilly UF J. N. Grace, Regional Administrator fir. J. T. Beckham, Jr.
fir. P. Holmes-Ray, Senior Resident j
l Mr. H. C. Nix, Jr.
Inspector - Hatch I
GO-NORMS l
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