ML20209E784

Responds to Violations Noted in Insp Repts 50-321/86-15 & 50-366/86-15.Corrective Actions:Leaking Hydraulic Snubber 2E11-RHR-R90 Replaced & Records for Snubbers Reviewed

ML20209E784
Person / Time
Site:	Hatch
Issue date:	08/25/1986
From:	Gucwa L GEORGIA POWER CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
0042G, 42G, SL-1107, NUDOCS 8609110354
Download: ML20209E784 (3)

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Geore a Pow:r Company g 333 Piedmont Avenue Atlanta, Georgta 30308 Telephor>e 404 52S-6526 Mailing Address A Post Office Box 4545 Atlanta Georgia 30302 i!6SEP5 A9: 4 i Georgia Power L T. Oucwa tr+ c utM m e:nr rt w en Manager Nuclear Safety and Licensing SL-1107 0042G August 25, 1986 U. S. Nuclear Regulatory Commission

REFERENCE:

Office of Inspection and Enforcement RII: JNG Region II - Suite 2900 50-321/50-366 101 Marietta Street, NW NRC Inspection Atlanta, Georgia 30323 Report 86-15 ATTENTION: Dr. J. Nelson Grace Gentlemen:

The following information is submitted in response to NRC Inspection Report Nos. 50-321/86-15 and 50-366/86-15, dated June 30, 1986. During a review of our initial response to the violation, dated July 30, 1986, we determined that additional information would have amplified the response.

Georgia Power Company Quality Assurance personnel had previously identified the potential problem cited in the Notice of Violation, and corrective actions were underway to resolve the problem prior to the citation. However, the corrective actions had not been completed at the time the violation occurred. The event occurred between the completion of the line-by-line review of the Technical Specifications and full implementation of corrective actions undertaken as a result of the QA audit. The line-by-line review of the Technical Specifications was initiated by Georgia Power Company as a result of other audit findings. Tne following information provides amplification in the format used in our initial response:

l Correc tive steps which were taken and the results achieved: Upon l discovery of the snubber inoperability, a 72-hour LC0 was initiated per Technical Specifications Section 3.7.4, ACTION Statement. Immediate I corrective action was accomplished on March 18, 1986, when the leaking (and thus, innperable) hydraulic snubber 2 Ell-RHR-R90 was replaced and returned to service. In addition, the records for hydraulic snubbers inspected following the site's implementation of Amendment 51 were reviewed. It was determined tnat hydraulic snubber 2E11-RHR-R90 was the only leaking snubber. An engineering evaluation was performed, as required by Uni t 2 Technical Specifications Section 4.7.4.c. This evaluation concluded that the inoperable snubber did not adversely affect the components it supported, because the snubber did not prevent the components from performing theit design function. Prior to this event, site Quality Assurance (QA) Open Item 85-SURV-1/90 had identified a weakness in the program whereby plant procedures were revised to implement changes in the Technical Specifications. As a result of this item, the

" TECHNICAL SPECIFICATIONS SURVEILLANCE PROGRAM" procedure (40AC-REG-001-0S) and the " REVISIONS TO LICENSING DCCUMENTS" procedure 8609110354 86002S 1

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. 9 Georgia Power d U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 2900 August 25, 1986 Page Two (43RC-CPL-001-05) were revised. Interim training relative to these changes was conducted for plant personnel on October 3, 1985, via Departmental Directive DGM 85-69. No other incidents of this nature have occurred since the interim training was conducted.

Following conversations with the Senior Resident Inspector, we believe that a time line of events relative to this violation will further clarify our response:

Quality Assurance Audit of Technical Specification Surveillance (85-SURV-1) (May 29 - June 24,1985)

Initiation of line-by-line Technical Specification review (early July 1985)

QA audit report issued (July 9,1985) - AFR 85-SURV-1/90 "The control program for timely incorporation of Tech Specs is considered inadequate."

Issuance of Technical Specification Amendment 110/51 - Snubber Technical Specifications (August 5,1985)

Completion of line-by-line Technical Specification review (August 16,1985)

Partial implementation of Amendment 51 (September 4,1985)

Corrective actions from QA audit implemented Interim training (October 3, 1985)

Revise procedure 40AC-REG-001-0S (February 10, 1986)

Reviso procedure 43RC-CPL-001-0S (February 13, 1986)

Inoperable snubber (2E11-RHR-R90) identified (February 26, 1986)

Inoperable snubber (2E11-RHR-R90) replaced (March 18, 1986)

Licensee event report 366/86-006 -

procedural inadequacy results in non-compliance with Technical Specifications - reports snubber inoperable per Amendment 51 ( April 18,1986)

Issuance of IE Inspection Report 86-15 violation - Failure to identify an inoperable snubber (June 30, 1986)

Submittal of response to violation (July 30, 1986)

Revise snubber procedure (52SV-SUV-001-2S) prior to next use 0042G twm

Georgia Power d l U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 2900 August 25, 1986 Page Three It is our belief, based on the facts above, that the failure to incorporate Amendment 51 is an isolated event that occurred between the end of the line-by-line Technical Specifications review and the implementation of the corrective actions from the QA audit. Other amendment packages received during this time period have been reviewed with no problems identified relative to procedural implementation. The corrective actions from the audit are sufficient to prevent recurrence of the violation. We hope that this additional information clarifies our initial response. If you have further questions, please contact this office at any time.

Sincerely, l

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L. T. Gucwa MJB/lc c: Georgia Power Company U. S. Nuclear Regulatory Commission Mr. t . P. O'Reilly Mr. P. Holmes-Ray, Sr. Resident Inspector Mr. J. T. Beckham, Jr.

Mr. H. C. Nix. Jr.

I GO-NORMS 0042G 10011%