ML20212G443

Forwards Input for Feb 1987 SALP Board Meeting for Facility Covering Jul 1985 - Dec 1986.Overall Rating of Category 2 Assigned in Functional Area of Licensing Activities

ML20212G443
Person / Time
Site:	Hatch
Issue date:	01/15/1987
From:	Rivenbark G Office of Nuclear Reactor Regulation
To:	Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8701200469
Download: ML20212G443 (11)

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q' January 15,~1987 1

Docket Nos. 50-321/366 -DISTRIBUTION IstemetJue NRC PDR/L PDR MEMORANDUM FOR: Louis Reyes, Acting Director RMBernero Division of Reactor Projects PDf2 Plant File Region II GRivenbark DMuller THRU: Robert M. Bernero, Director _ SNorris Division of BWR Licensing THRU: Daniel R. Muller, Director BWR Project Directorate #2 Division of BWR Licensing FROM: George W. Rivenbark, Project Manager BWR Project Directorate #2 Division of BWR Licensing

SUBJECT:

NRR SALP INPUT FOR THE GEORGIA POWER COMPANY EDWIN I. HATCH NUCLEAR PLANT, UNITS NOS. 1 AND 2 Enclosed is NRR's input for the February 1987 SALP Board meeting for the Hatch facility. As discussed in the enclosure, our evaluation was conducted according to NRR Office Letter No. 44, Revision 1 dated December 22, 1986 and NRC Manual Chapter 0516, Systematic Assessment of Licensee Performance. The overall performance rating in the functional area of Licensing Activities is Category 2.

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George Rivenbark, Project Manager BWR Project Directorate #2 Division of BWR Licensing

Enclosure:

As stated cc w/ enclosure:

P. Holmes-Ray Resident Inspector DBL DBL: DB .

DBL:D SN GRivqnbark/cd D RMBernero 1/N/87 1//4/87 1/h[/87 1/ f f /87 0FFICIAL RECORD COPY 8701200469 870115 PDR ADOCK 05000321 G PDR

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Dockets Nos. 50-321/366 FACILITY: Edwin I. Hatch Nuclear Plant, Units 1 and 2 LICENSEE: Georgia Power Company (GPC)

EVALUATION PERIOD: July 1, 1985 to December 31, 1986 PROJECT MANAGER: George W. Rivenbark

1.0 INTRODUCTION

This report contains NRR's input to the SALP review for the Edwin I. Hatch Nuclear Plant. The assessment of the licensee's performance was conducted according to NRR Office Letter No. 44, NRR Inputs to SALP Process, Revision 1 dated December 22, 1986. Office Letter No. 44 incorporates NRC Manual Chapter 0516 Systematic Assessment of Licensee Performance.

2.0

SUMMARY

NRC Manual Chapter 0516 specifies that each functional area evaluated will be assigned a performance category (Category 1, 2 or 3) based on a composite of a number of attributes. The performance of GPC in the functional area of Licensing Activities is rated Category 2.

3.0 CRITERIA The evaluation criteria used in this assessment are given in NRC Manual Chapter 0516 Appendix, Table 1, Evaluation Criteria with Attributes for Assessment of Licensee Performance.

4.0 METHODOLOGY This evaluation represents the integrated inputs of the Project Manager (PM) and those technical reviewers who expended significant amounts of effort and/or prepared a Safety Evaluation for the Edwin I. Hatch Nuclear Plant licensing actions during the current rating period. Using the guidelines of NRC Manual Chapter 0516, the PM and each reviewer applied specific evaluation criteria to the relevant licensee perfonnance attributes, as delineated in Chapter 0516, and assigned an overall rating category (1, 2 or 3) to each attribute. The reviewers included this information as part of each Safety Evaluation transmitted to the PM. The PM, after reviewing the inputs of the technical reviewers, combined this information with his own assessment of licensee performance and arrived at a composite rating for the licensee. This rating also reflects the comments of the NRR Senior Executive assigned to the Hatch SALP assessment.

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The basis for this appraisal was the licensee's performance in support of licensing actict.s that had a significant level of activity during the current rating period. These actions, consisting of amendment requests, exemption requests, code relief requests, responses to generic letters, TMI and Salem ATWS items, and other actions, are listed below:

Multiplant Actions A - 04 AppendixJLeakTestingExemption(Unit 1only)*

B - 76 Post Trip Review Program and Procedures

• B - 79 Post Maintenance Testing - RTS Components

• B - 88 Post Maintenance Testing - All SR Components

• D - 19 Diesel Generator Reliability Technical Specifications D - 20 Mark 1 Drywell Vacuum Breakers F - OS Procedures Generation Package Review F - 26 Inadequate Core Cooling Instrumentation

• l Plant Specific Actions ISI Relief Requests

• Exemption to Appendix R*

Inservice Inspection - Second 10 year Program

• CoreSpraySpargerInspection(Unit 1Only)*

Licensed Operator Requalification Program

• ATWS Implementation Schedules

• IGSCC Inspection and Repair (Unit 1 Only)*

Seismic Analysis Descrepancies Extend License Expiration Date Technical Specification Changes:

Analogue Transmitter Trip System Setpoints*

Standby Gas Treatment System Fast Acting Dampers Surveillance

• Drywell Pneumatic System Valves Listing

• Containment Isolation Yalves Listing

• RCIC Suction Auto-Transfer Setpoint (Emergency Basis - Unit 2 Only)*

Reactor Vessel Pressure - Temperature Operating Limits (Unit 1 Only)*

Gaseous Effluents Sampling Requirements

• HydrogenInjectionTestingRequirements*(Unit 2Only)*

Rod Worth Minimizer, Rod Sequence Control and MAPLHGR Limits

• Diesel Generator Containment ElectricalOperability Requirements Penetration Overcurrent (Emergency Protection Basis Unit 2 Only)(Unit Requirements 2Only)*

Removal of Fire Protection Specification

• Control Room Environmental Control System Operability

• Settlement of Structures Surveillance (Unit 2 Only)

Scram Discharge Volume Isolation Valve Closure Time Limits Primary Coolant System and Component Surveillance Reactor Protection System Instrument Surveillance Single Loop Operation Limits low River Water Level Operability Limit

• Indicates action completed

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5.0 ASSESSMENT OF PERFORMANCE ATTRIBUTES 4

This evaluation of the licensee's performance was based on consideration of five of the six elements specified in NRC Manual Chapter 0516. These are:

l - Management Involvement and Control in Assuring Quality

- Approach to Resolution of Technical Issues from a Safety Standpoint L - Responsiveness to NRC Initiatives j - Reporting and Analysis of Reportable Events l -Staffing (includingManagement) ij For the remaining element, Enforcement History, there is no basis for a rating by NRR.

i In addition, this evaluation includes an assessment of the licensee's l housekeeping practices and the conduct of control room personnel.

4 5.1 MANAGEMENT INVOLVEMENT AND CONTROL IN ASSURING QUALITY i The licensee has upgraded its management organization by adding a Senior Vice President dedicated to Nuclear Operations who has extensive experience in l

} nuclear regulatory and safety matters. It has also added substantial

! managerial strength to this senior vice president's staff. Late in the SALP report period it moved a vice president to the Hatch site to assume overall

! management of the Hatch Units 1 and 2 activities. These changes have provided i heightened management attention to all Hatch activities including licensing l related activities. There has been extensive management participation in '

licensing activities associated with the major Unit 1 and 2 refueling and

, maintenance outages that occurred during the report period. These activities

. ^ include Appendix R exemption requests, IGSCC inspection of Unit 1 piping, and l exemption requests associated with the completion of the first 10 year i in-service inspection program. There has also been extensive management

involvement in responding to the staff's review of the 2nd 10 year in-service i inspection program and its related exemption requests.

i The licensee has taken a proactive role in the hRC's program to improve j Technical Specifications. Hatch Unit 2 has been designated as the lead plant j for the BWR Owners Group on Technical Specification Improvements. The licensee i

has also implemented an extensive procedures upgrade program that includes

! checking, correcting, and upgrading all the existing Hatch Technical .

! Specifications. All of the above indicate a growing management attention to '

j licensing matters.

A l However, there continues to be some areas that need improved management l attention. One of these areas is in the quality of the Sholly evaluations that 4 the licensee submits with each requested license amendment. The bases for concluding that no significant hazards consideration is involved with the proposed changes has been only marginally adequate for most of the submittals. ,

j Another area that needs improved management attention is information provided 4

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ir. justification of an emergency or expedited technical specification change request. Since expedited action on the part of the staff is being requested in these cases, adequate and complete information should be submitted at the time of the request. The request for the emergency change to allow continued operation with an inoperable diesel generator and the request for an expedited change related to main control room environmental control system operability requirements are cases during the report period where the initial information was insufficient and reflect that insufficient management attention has been given to the licensing requirements.

Based on the above considerations the overall rating for this element is Category 2.

5.2 APPROACH TO RESOLUTION OF TECHNICAL ISSUES FROM A SAFETY STANDPOINT In most cases the licensee has exhibited an understanding of the issues, conservatism and sound approaches in its licensing proposals.However, in some of its proposals the licensee has indicated a lack of understanding of the issues or has lacked conservatism, thoroughness or depth. Examples of these issues are: a) modifying the nitrogen gas lines without prior staff approval when a technical specification change related to the modification was required b) qualification requirements for IGSCC inspectors c) proposed removal of upper pressure limit related to interlocks for valves isolating the low pressure from the high pressure system, and d) certain inservice inspection exemption requests.

Based on these considerations the rating for this element is Category 2.

5.3 RESPONSIVENESS TO NRC INITIATIVES The licensee has generally responded to NRC requests, including generic letters and plant specific requests, both oral and written, in a timely and technically adequate manner. In some cases it provided information in an extremely timely manner. Examples of such submittals include the revised 10 year inservice inspection program, and its May 1986 Appendix R exemption request. However, it delayed in an untimely manner in responding to the staff concerns and request for discussion concerning legal aspects of the discrepancy between the Hatch Unit 2 FSAR and the actual seismic design of the Unit. It also delayed in an untimely manner its response to the staff concerns related to GPCs proposal to delete Unit 2 building settlement monitoring technical specification. It also submitted the results for its IGSCC inspection of Unit 2 in an untimely manner - leaving little time for staff review prior to the scheduled restart of Unit 2. Finally, it responded to late staff review questions concerning Appendix R exemptions requests in untimely manner, taking almost a month to provide its response.

Based on these considerations, the rating for this element is Category 2.

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5.4 REPORTING AND ANALYSIS OF REPORTABLE EVENTS

. Operating Events To be provided later. Input being prepared by the Facility Operations Branch Occupational Dose To be provided later. Input being prepared by the Facility Operations Branch Conclusion To be provided later. Input being prepared by the Facility Operations Branch 5.5 STAFFING

, During this rating period, the licensee has modified the corporate and plant organization. A new senior vice president for nuclear operations and several -

new staff members reporting to this senior vice president have been added, including management for trair.mg, security and procedures upgrading. Appendix R fire protection modification activities were organized under a project manager. An additional manager was added to the Hatch licensing staff. A vice president was moved to the site to manage all Hatch Unit 1 and 2 activities. The Hatch plant staff was reorganized to provide a better

division of management functions. A plant support manager was added to the staff to oversee the security, engineering support, outage planning and general support functions, relieving the plant manager of these functions, and allowing the plant manager to focus on activities related to day-to-day

operation of the plant. (operations, maintenance, and health physics) Training

! and nuclear safety and compliance functions were elevated to report to the n6w '

! onsite vice president.

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! Based on the above considerations the overall rating for this element is

! Category 1.

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! 5.7 HOUSEKEEPING AND CONTROL ROOM CONDUCT Observations made by the NRR project manager while visiting the site on

. several occasions during this rating period indicate that the licensee's

. housekeeping practices are adequate. Control room personnel appeared to -

conduct themselves in a professional manner,

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The rating for this attribute is Category 2.

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6.0 CONCLUSION

An overall performance rating of Category 2 has been assigned in the licensing

area.

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Section 043 of the Manual Chapter 0516 defines the meaning of rating the licensee's performance Category 2 as follows: "NRC attention should be maintained at normal levels. Licensee management attention and involvement yy are evident and are concerned with nuclear safety. Licensee resources are adequate and reasonably effective so that satisfactory performance with respect to operational safety and construction is being achieved.",

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7 Information to be added to Section 5 of SALP Report " Support Data and Sumary"

1. NRC/ Licensee Meetings Visits Site Visits: February 12-13, June 2-3, August 25-29, 1986 Meetings:

July 17, 1985 Quarterly GPC-Overview Meetings on Hatch September 17, 1985 SALP 8oard Meeting on Hatch '

October 24, 1985 Quarterly GPC-NRC Overview Meeting on Hatch I November 8,1985 Crack in Unit 1 Nitrogen Makeup Line December 13, 1985 GPC Repair Plan for Safe End-to Nozzle Weld February 12, 1986 Quarterly GPC-NRC Overview Meeting March 27, 1986 Seismic Response Design Decrepancy June 2, 1986 Quarterly GPC-NRC Overview Meeting June 18,1986 Problems with Seismic Design of Cable Trays  ;

June 19, 1986 Technical Specification Improvement Program '

July 16, 1986 Appendix R Exemption Request September 11, 1986 Seismic Design October 21, 1986 Building settlement Monitoring Tech Spec.

November 4,1986 Quarterly GPC-NRC Overview Meeting November 20, 1986 Procedure Upgrade Program

2. Commission Briefings NONE

3. Schedular Extensions Granted August 6, 1985 Extended deadline for E0P implementation and DCDR Summary Report to 12/31/86 September 19, 1985 ATWS modification implementation, Unit 1 January 24, 1986 ATWS modification implementation, Unit 2

4. Relief Granted i

! November 7, 1985 ISI requirements, Unit 1 January 21, 1986 ISI requirements, Unit 1 September 29, 1986 ISI requirements-2nd 10 year Program

5. Exemptions Granted October 30, 1986 Appendix J Leak Testing l January 2,1987 Appendix R l

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6. License Amendments Issued Unit 1 - Unit 2 Date Subject

1. 49 July 16, 1985 Definition of " Operable"

1. 50 #111 August 5, 1985 Leak rate limit & testing requirement for ADS

1. 51 #112 August 5, 1985 Snubbers

1. 52 August 27, 1985 ADS bypass timers

1. 53 #113 August 27, 1985 Deletes high drywell pressure scram bypass

1. 54 #114 September 9,1985 Deletes completion date for EQ equipment

1. 55 September 9, 1985 HCU pressure alarm setpoint

1. 56 #115 September 9,1985 Deletes aerial photo requirement from Appendix B

1. 57 September 11, 1985 Emergency-RCIC suction auto tranfer setpoint

1. 116 October 15, 1985 Corrects on error in Tech Specs.

1. 117 November 19, 1985 Delete reporting requirements

1. 58 #118 December 11, 1985 Purge and vent isolation valve

1. 119 December 23, 1985 ISI requirements

1. 59 #120 December 26, 1985 Drywell pneumatic system

1. 60 January 9, 1986 Overcurrent protection for containment penetrations

1. 121 January 17, 1986 Analogue transmitter trip system

1. 122 January 29, 1985 Automatic depressurization system f61 February 4, 1986 Hydrogen recombiner heater testing

1. 123 March 4,1986 Delete " Cumulative Downtime" definition

1. 62 #124 March 26, 1986 H, and 0, post accident monitors

1. 125 May 21, 1986 Main steam line high radiation scram (hydrogen injection test)

1. 126 June 20, 1986 Reactor vessel operating temperature and pressure limits

1. 127 June 20, 1986 Additional fire and smoke detectors

1. 128 June 26, 1986 Component cyclic and transient limits

1. 63 July 30, 1986 Emergency-diesel generator inoperability

1. 129 September 25, 1986 Primary containment isolation valves f64 October 22, 1986 Overcurrent protection for containment penetrations

1. 65 #130 October 23, 1986 Sampling gaseous effluents

1. 131 October 30, 1986 Appendix J testing f66 #132 October 31, 1986 Control rod withdrawal limits

1. 67 November 6, 1986 Analogue transmitter trip system setpoints f68 November 10, 1986 Primary containment isolation valves

v-e Unit 1 - Unit 2 Date Subject Continued

1. 69 November 17, 1986 ATWS and E0C recirc pump trip instr.

1. 70 #133 Nobember 24, 1986 Delete fire protection Tech Specs and change fire protection license conditions

1. 71 December 29, 1986 Main control room environmental control system operability

7. Emergency / Exigent Technical Specifications September 11, 1985 RCIC suction auto transfer setpoint July 30, 1986 Diesel generator inoperability

8. Orders Issued None

9. NRR/ Licensee Management Conferences None d

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9 SALP Performance During Two Previous Rating Periods Functional Area Category Category Trend (11/1/82-10/31/83) 11/1/83-6/30/85 T171783-6/30/85 Plant Operations 3 2 Improving Radiological Controls 2 1 Constant Maintenance 3 3 Improving Surveillance 2 2 None Fire Protection Not Rated 2 Nor,e Emergency Preparedness 1 2 Declining Security 1 2 Declining Refueling / Outages Not Rated 2 None Training Not Rated 3 Improving Quality Programs and 3 2 Constant Administrative Controls Affecting Quality Licensing Activities 2 2 Constant Y

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