ML20213F518
| ML20213F518 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 05/06/1987 |
| From: | James O'Reilly GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| SL-2391, NUDOCS 8705150354 | |
| Download: ML20213F518 (11) | |
Text
n' Georgia Pow:r Company 333 Piedmont Avenue
. A!!anta, Georgia 30308
-Telephone 404 526-7851 Maihng Address:
Post othce Box 4545 Attanta, Georgia 30302 Ie%r*v$ceNioen:
. Nuclear Operations SL-2391 02230 X7GJ17-H120 May 6, 1987 U. S. Nuclear Regulatory Commission ATTN: Document-Control Desk Hashington, D. C. 20555 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RESPONSE Gentlemen:
Georgia Power Company (GPC) has reviewed the information presented in the ' Systematic Assessment of Licensee Performance- (SALP) Board Report forwarded by your letter dated March 4, 1987, and in the meeting held between GPC and NRC on April 6,
1987.
He agree with -the evaluations contained in the SALP report and are pleased with the SALP Board's recognition of our continuing efforts to improve performance at Plant Hatch. GPC sincerely appreciates the NRC comments presented at our April 6,1987 ' meeting at the Plant Hatch site, which included plant operating personnel, which further explained the SALP Board's evaluation.
The purpose of this letter is to comment on the findings of the SALP Board in each functional area evaluated.
GPC's response to the Board's findings are contained in Enclosure 1 to this letter.
GPC is fully committed to the safe and efficient operation of Plant Hatch.
GPC takes the SALP Board ratings and recommendations seriously and uses this information in the continuing process of evaluating and 4
improving our performance.
It remains our objective to achieve and maintain levels of performance which will truly earn high ratings. to this letter details some of the actions implemented to achieve our objective.
8705150354 870506 R
ADDCK 0500 1
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L U. S Nuclear Regulatory Commission
- May 6, 1987 Page Two GPC is particularly concerned with the Category 3 (improving) rating received in the functional area of security.
GPC recognized during the first twelve months of the SALP period that tne nuclear. security program.
at Plant Hatch was not performing at the desired level.
As a result, a-number of improvements were made to improve this situation both in the short term and long term.
Some of these actions are summarized -in.
He are striving to fully implement areas of improvement detailed in the enclosure.
He plan to update you regarding the status and results of our programs periodically.
Should you have any questions concerning this letter, I will. be pleased to discuss them with you.
Sincerely, mi. O' J es P. O'Reilly OMS:jhu
Enclosure:
Response to SALP Report c: Georaia Power ComDany Mr. J. T. Beckham, Jr.
GO-NORMS U. S. Nuclear Regulatory Commission Dr. J. N. Grace, Regional Administrator Mr. P. Holmes-Ray, Senior Resident Inspector - Ha,tch Mr. L. P. Crocker, Licensing Project Manager - Hatch 0223U L
1-ENCLOSURE 1 PLANT HATCH - UNITS 1, 2 NRC 00CKETS 50-321, 50-366-OPERATING LICENSES DPR-57, NPF-5 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RESPONSE PLANT OPERATIONS:
GPC appreciates the fact that the SALP Board recognized our high level of management involvement with operations and our overall commitment to safe operation.
RADIOLOGICAL CONTROLS:
The SALP Board commented that GPC showed "some we6kening of the radiation protection program," and expressed concern about repeated-violations in the health physics area.
He accept this comment and will address this observation in our program reviews.
GPC expects the following areas of improvement to reflect positively on our performance:
1.
Commitment of management in supporting our radiation protection program.
a.
Plant Hatch has led the industry in development ~ and implementation of more reliable and sensitive contamination monitoring equipment and programs.
In
- 1986, the contamination monitors at Plant Hatch were used more than 1.5 million times.
In conjunction with Eberline Instrument Corporation, a tool monitor ~ has been developed, field tested, and placed into operation.
b.
Significant improvements in volumes of liquid and solid wastes and in gaseous activity releases have been made.
c.
The size of our in-house health physics staff has been increased.
- I 0223U E-l May 6, 1987 SL-2391
ENCLOSURE 1 (Continued)
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RESPONSE RADIOLOGICAL CONTROLS: (Cont'd) d.
GPC -has instituted a daily inspection program to identify and correct potential leaks in piping which could.cause a noble gas problem.
e.
Major strides have been ' taken in improving our training-program.
2.
Efforts to reduce fatigue of the in-house health physics staff were initiated.
a.
Limits were placed on the amount of overtime our permanent plant health physics staff can work.
b.
Radiation work permit requirements have been streamlined without jeopardizing
- safety, thereby reducing manhours required prior to and during work in radiation control areas.
3.
Commitment of management in supporting our radwaste control program.
a.
A 400,000 pounds per square inch compactor was purchased in 1986 and has been effective in reducing the volume of solid radioactive waste shipped.
b.
An overall volume reduction of 351. of the 1983-85 average radwaste volume shipped was accomplished in 1986.
c.
The volume of radwaste shipped per reactor in 1986 was below the industry average.
d.
Personnel involved in loading and inspection of low specific activity (LSA) containers are receiving additional training.
Hechanical handling equipment has been modified to avoid potential container damage, e.
Different LSA container configurations are now being used to avoid potential physical damage to adjacent containers.
0223U E-2 May 6, 1987 SL-2391
4 l
J ENCLOSURE-1 (Continued)~
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RESPONSE I
I-RADIOLOGICAL CONTROLS: (Cont'd) i L
- 4. ' Data compiled. for-the Semi-annual effluent. reports arel reviewed by -
several management tiers prior to submittal of:the reports to NRC.
5.
A computer-based tracking program is being developed to ensure radiation detection and surveying instrument calibration dates are-tracked.
I 6.
Several Eberline tool monitors 'have been purchased and placed in j
service to assist in tool frisking.
-In summary, GPC accepts the SALP' Boards findings and will act appropriately.
However, GPC wishes to note that we - have not' relaxed in '
.this important area over the last.one and one-half years.
GPC will i'
increase management attention 'and support of radiation protection t
activities including the diligent review and implementation--of existing j
programs.
i MAINTENANCE:
1 j
GPC appreciates the fact that the SALP Board ' recognized that' we have i
expended considerable resources in upgrading our maintenance related programs to ensure their comprehensiveness and the fact that our maintenance training and procedures upgrade program ' are particularly comprehensive.
~
GPC makes a continuing commitment to achieve enhanced performance-in the maintenance areas. Specifically, we wish to note the following:
1.
A program to ensure feedback of operating experience to maintenance personnel was implemented in January 1987.
1 i
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l 0223U E-3 May 6, 1987 SL-2391 i
j.
m.-
ENCLOSURE 1 (Continued)
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RESPONSE-MAINTENANCE: (Cont'd) a.
This program is part of the continuing training program and places emphasis on getting the basic programs in place with continuing training as second priority.
b.
INP0- has reviewed this-program as part of their accreditation process.
c.
Additional measures were taken in March to ' formalize and further strengthen the transfer of operating experience and industry events.
2.
Upgraded maintenance programs involving outage management have been -
implemented extensively, including contractor training, improved work packages, improved preplanning of valve work, outage organization improvements, incentive contracts and reduced number of contractors.
3.
Management maetings between NRC and GPC to discuss maintenance program progress, held in the first and second quarters of 1986 provided a solid understanding of NRC concerns and provided a form to discuss the GPC initiatives for improvement of maintenance at Hatch.
He plan to meet periodically with the NRC to discuss our programs.
4.
GPC is requiring all maintenance personnel to complete the entire i
upgrade training and qualification
- program, which will improve
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overall proficiency in the maintenance area.
5.
A validation review by qualified personnel, including a walkthrough or use of the procedures, will improve the quality and usability of new procedures.
6.
Attention to detail with corresponding disciplinary action has been increased.
Some foremen have been replaced and positive disciplinary type contacts with craft personnel have increased.
7.
The ten INP0 recognized training programs have been accredited at Plant Hatch.
0223U E-4 May 6, 1987 j
SL-2391
1 EELQSIBL1 (Continued)
SYSTEM SURYHLlCEI The SALP review period. report The following improvements to thlists 6 violatio ensure that similar violations do n t o
e programreported during 1.
the further examined by the procedTeclinical adequac pecifications for volunteered to upgrade program.be the lead plant in the NRC Techniure upg Also, Hatch has 2.
A re-evaluation of the local cal Specification has been leak rate test program for both aggressively resolved local leak rate test issu pursued.
This effort has units 3.
The Maintenance Department has identified es.
electrical and personnel implementation of surveillanto be part of aassigned a foreman and m EIRE _ER0IECIl0H1 ce requirements. surveillance team to improve and
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rating in this functional areaGPC is pleased to be recogn the major corporate and plant i
by the SALP Board with a categ e
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protection pro our view commitment in,the upgrading of outhe SALP of Appendix R. gram and in the detailed implementati
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ory I
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r fire on of the requirements EHERGEELPAEPAREDESS t
k
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GPC is pleased with the sal.P Board's emergency preparedness area i
to this program of both our.
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The Board recognized therating in the category I they acknowledged the strengths
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site and corporate managementstrong commitment
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perform emergency identificatio of our Plant Hatch st In addition, and correct decisions and recommend ti i
ns and classification, aff to proficiently and clearly defined roles
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state and local governments were a ons.
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The strengthened relationshipand to m of responsibility for coordinatio will continue to place major attenti also noted as program strengths
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n with the on to this important area.
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SL-2391 E-5 May 6, 1987
ENCLOSURE _1.
(Continued)
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RESPONSE
'l SECURITY:
Georgia Power Company recognized that during the first twelve months of the SALP period that the nuclear security program at Plant Hatch had difficulties. A number of actions were taken to reverse this situation:
1.
A review of the security procedures was initiated 2.
Compensatory measures were better defined and reduced.
3.
Management oversight was increased, including placing nuclear security organizational 1y under Nuclear Operations.
4.
The new Corporate Nuclear Security Department was staffed.
I In addition to the above, a major hardware problem has been addressed and resolved.
The cause of frequent computer failures, which resulted in many compensatory measures, has been corrected to the extent that there i
has not been an unplanned outage of our security computers since August, 1986.
Georgia Power Company has embarked on a long term and aggressive program to permanently improve the performance of the Plant Hatch nuclear security function.
This program consists of revised security plans, training and physical improvements.
He commit to continued management attention in fully implementing our upgrade program.
In December, 1986, the NRC's Regulatory Effectiveness Review (RER) team visited Plant Hatch.
He are pleased to recognize that the SALP l
report notes that the team found no significant weakness, and had several favorable comments, which we feel reflects the state of security at Plant Hatch.
REFUELING /00TAGE:
l l
l The Board noted GPC's continued management commitment to improved scheduling for outages during the assessment period and the fact that the l
position of outt.ge planning manager was filled.
In addition, the management involvement, record keeping, and training program involved in Inservice Inspection were all mentioned as program highlights. GPC 1
0223U E-6 May 6,1987 SL-2391
ENCLOSURE 1 '(Continued)
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RESPONSE' REFUELING /0UTAGE: (Cont'd.)
I intends for outage schedules to be aggressive and the work accomplished during the outages to be consistent with the durations.
In view of the fact that both units have performed well since-the recent outages, ' we believe that the outages were successful in reaching their objective of preparing the plant for cycles of safe and reliable operation.
He are continuing to place major emphases on refueling outages.
TRAINING:
GPC is extremely pleased with the Category I rating received in this-
' functional area and appreciates the Board's recognition of our high level of performance and the' many improvements made during the review period.
GPC worked hard to improve. its training programs in all areas.
He believe substantial improvements in safety and reliability will be achieved.
The recognition by the NRC supports our efforts.
He also believe it appropriate to note that the GPC is now a full member of 'the National Nuclear Training Academy.
QUALITY PROGRAMS AND ADMINISTRATIVE CONTROLS AFFECTING OUALITY:
The SALP Board report defines this area.as "the ability of the licensee to identify and correct their own problems.
As such, it encompasses all plant activities, all plant personnel, as well as those corporate functions and personnel that provide services to the plant.
The plant and corporate QA-staff are part of the entity, and as such, they have responsibility for verifying quality.
The rating in this area specifically denotes results for various groups in achieving quality -as well as the QA staff in verifying that quality is achieved."
0223U E-7 May 6, 1987 SL-2391
~
r ENCLOSURE 1 (Continued) l l
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RESPONSE 00ALITY PROGRAMS AND ADMINISTRATIVE CONTROLS AFFECTING OUALITY:
l Cont'd.
l In their review of this functional area, the SALP Board listed apparent strengths and weaknesses of the program which were obtained from their review of all sections of the SALP report.
GPC believes the areas of improvement noted in the other sections of this attachment will result in enhanced future performance and coordination in this area.
Also, we l
wish to note that the GPC has implemented the Human Performance Evaluation System (HPES) program at both plants Vogtle and Hatch and that we are placing a major focus on " lessons learned".
LICENSING ACTIVITIES:
1 This functional area contained several suggestions for improvements.
In view of the SALP Board's suggestions and comments, GPC notes the 1
following specific areas or....;rovement:
1.
GPC has been instrumental in establishing an industry ad-hoc effort to provide improved guidance in development of 10 CFR 50.92 evaluations.
2.
GPC will establish criteria to assure that Emergency Technical Specification submittals meet stricter standards of quality of content.
3.
GPC and its contractors have met the requirements governing the qualification of inspection personnel involved with the detection (and sizing) of IGSCC.
GPC affiliated inspection personnel and
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contractors performing IGSCC inspections at Plant Hatch have repeatedly demonstrated the ability to detect and size IGSCC in both field and laboratory conditions.
A recent NRC audit at Plant Hatch concerning compliance with Generic Letter 84-11, which included welds examined, qualification of inspectors, and overall implementation resulted in no violations, unresolved items, or follow-up items.
NRC noted Plant Hatch will be used as a " benchmark" in evaluating other plants' compliance with Generic Letter 84-11.
4.
GPC will place additional management attention on NRC requests for information.
It is our goal to respond in as timely a manner as possible.
l 0223U E-8 May 6, 1987 l
SL-2391
y ENCLOSURE 1 (Continued)-
.7 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RESPONSE LICENSING ACTIVITIES:(Cont'd.)
In addition to the above, and as noted by the SALP Board, GPC maintains extensive management involvement and attention to licensing activities. Upgrades to our management organization are evidence of this commitment.-
He will continue to stress improvements on all activities relating to licensing.
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0223U E-9 May 6,'1987
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SL-2391
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