ML20210E347
| ML20210E347 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 01/12/1987 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | John Miller GEORGIA POWER CO. |
| References | |
| NUDOCS 8702100285 | |
| Download: ML20210E347 (4) | |
See also: IR 05000321/1986028
Text
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JAN 121987
Georgia /owerCompany
ATTN: VMr. J. H. Miller, Jr.
President
P. O. Box 4545
Atlanta, GA 30302
Gentlemen:
SUBJECT:
NRC INSPECTION REPORT NOS. 50-321/86-28, 50-321/86-33, 50-366/86-28,
AND 50-366/86-33
Thank you for your response of December 12, 1986, to our Notice of Violation
issued on November 7,
1986, concerning activities conducted at your Hatch
facility under NRC License Nos. OPR-57 and NPF-5.
We are ualuating your
response and would like more information concerning activities at Hatch.
In your response to Violations A and B, you state that the events "had no actual
or potential safety consequences." We believe your position is not correct
since the violations do involve potential safety consequences.
The Unit I and
Unit 2 Technical Specifications (TS) basis states that the TS requirements in
this area ersure "the calculated doses would be less than the allowable levels
stated in Criterion 19 of the General Design Criteria for Nuclear Power Plants,
Appendix A to 10 CFR Part 50."
Criterion 19 requires that a control room shall
be provided from which actions can be taken to maintain the reactor in a safe
condition under accident conditions and adequate radiation protection shall be
provided to permit . access and occupancy of the control room under accident
conditions.
Failing to verify the operability of the main control room
ventilation system in accordance with the TS as described in Violations A and B
does involve potential safety consequences since actions to mitigate the effects
of an accident may be impaired due to a lack of control room habitability.
Violation A Response
In your response to Violation A, you imply the system was found to be satisfactory
when the surveillance test was performed on September 26, 1986. We believe the
actual as-found system flow was out of specification and had to be adjusted to be
within the TS limits.
Also in your response to Violation A, you do not address the basic problem of
not providing adequate detail in your procedure to ensure compliance with TS
requirements.
This problem was also evident in the Unit 1 Emergency Diesel
Generator (EDG) day tank (volume) conversion problem discussed in Inspection
Report 86-33.
Inspection Report 86-33 requested that you discuss the cause and corrective
actions relating to the Unit 1 EDG day tank (volume) conversion problem. Your
response addressed the immediate corrective actions but did not provide any
explanations as to the cause of the problem.
The corrective actions did not
8702100285 870112
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Georgia Power Company
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JAN 12 B87
address the more basic problem of inadequate procedures and failure to follow
procedures.
For example, how has this procedure been performed in the past
since personnel could not verify the day tank level using the guage, and what
actions will be taken to minimize these types of procedural deficiencies in
other instructions?
Violation B Response
In your response to Violation B, you state that personnel error contributed to the
violation and surveillance "due dates" were incorrectly assigned based upon the
operating cycle completion date. We would like more detail on the nature of the
personnel error and on any procedures you may have to provide guidance in scheduling
surveillances which were in existence at that time or are in place at this time.
You stated that I&C personnel documented satisfactory performance of the surveillance
test on December 6, 1985. At the time of the inspection, this documentation was not
available.
The resident inspectors will verify the documentation you state
exists in the follow-up of this violation.
Also in your response to Violation B, you discuss how frequency " changes" are
independently verified since the strengthening of the program in May 1985. You
also state that since the surveillance test in question has been performed within
the required frequency since the changes in 1985, these previous changes will
preclude this occurrence.
It is not clear to us that the missed surveillances
addressed in Violation B occurred due to frequency " changes."
In your description
of the reason for Violation B, you assign personnel error and Unit 1/ Unit 2 TS
differences, but no mention is made of problems due to frequency changes.
It
does not appear that the changes made in May 1985 constituted corrective steps
for Violation B.
Also under corrective steps taken, you state you now schedule surveillance due
dates based upon the previous "due" date of the surveillance and not " solely"
upon the operating cycle completion date.
This implies that you still use the
operating cycle completion dates in some way to arrive at the surveillance due
dates and we would like more information on how the due date is scheduled. Also,
it appears that scheduling a surveillance due date based on the previous due date
may lead to further violations of the specified frequencies. If a surveillance
test is performed earlier than the due date and the next test is scheduled based
on the due date instead of the actual performance date, then the required frequency
will be exceeded if the 125 percent allowable interval is used. It appears that
it would be more appropriate to schedule the next surveillance test based on the
actual performance date.
Under corrective steps which will be taken to prevent recurrence, you state "No
further corrective steps are necessary beyond the performance of the procedure
at its next due date in order to be in compliance with the 3.25 times 18-month
surveillance interval." This addresses the next surveillance but does not ensure
future tests will be scheduled within the TS required 3.25 times the specified
interval for this or other surveillance tests.
In summary, we would like additional information in the following areas.
1.
What is the justification for considering the violations to have no potential
safety consequences?
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Georgia Power Company
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JAN 121987
2.
Was the as-found flowrate on September 26, 1986, outside the TS required
flowrate?
3.
Will your Procedure Upgrade Program (PUP) or other programs ensure that
procedures can be performed to meet TS requirements and contain adequate
detail to prevent occurrences like Violation A and the EDG day tank level
problem?
4.
What was the cause of the EDG day tank level problem (i.e., had the gauge
been replaced recently, procedure changed, etc.)?
1
5.
How has this procedure been performed in the past, since personnel could not
verify the day tank level using the gauge?
6.
Have there been and are there any procedures which provide guidance in
scheduling surveillances?
7.
What are the details of personnel error involved with Violation A?
{
8.
How does the May 1985 change to the Technical Specification surveillance
scheduling program revision process constitute a corrective step for
Violation B (i.e., was this violation due to a frequency change)?
9.
Are surveillance due dates scheduled using operating cycle completion dates?
If so, what means are in place for not exceeding the TS required frequency?
10. .How will you prevent exceeding the TS required frequency using previous due
dates vice actual completion dates to schedule the next surveillance tests?
11. How will you prevent exceeding the 3.25 times the surveillance interval for
future surveillance tests in general?
Please provide the above information within 30 days of receipt of this letter.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,
Title 10, Code of Feaeral Regulations, a copy of this letter will be placed in
the NRC Public Document Room.
The responses directed by this letter are not subject to the clearance procedures
of the Office of Management and Budget as required by the Paperwork Reduction Act
of 1980, PL 96-511.
Should you have any questions concerning this letter, please contact us.
Sincerely,
Original signed by/
J.
Nelson Grace
J. Nelson Grace
Regional Administrator
cc:
(See page 4)
e
Georgia Power Company
4
JAN 121987
cc:
J. P. O'Reilly, Senior Vice President
Nuclear Operations
. T. Beckham, Vice President, Plant Hatch
. C. Nix, Site Operations General
/ Manager
V A). Fraser, Acting Site QA Supervisor
vi.. Gucwa, Manager, Nuclear Safety
and Licensing
bec. NRC Resident Inspector
V Hugh S. Jordan, Executive Secretary
Document Control Desk-
Strce of Georgia
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