ML20214A227
| ML20214A227 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 05/04/1987 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | James O'Reilly GEORGIA POWER CO. |
| References | |
| NUDOCS 8705190336 | |
| Download: ML20214A227 (9) | |
See also: IR 05000321/1986030
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May 4, 1987
Docket Nos. 50-321, 50-366
Gporgia Power Company
v4TTN: Mr. James P. O'Reilly
Senior Vice President-
Nuclear Operations
P. O. Box 4545
Atlanta, GA 30302
Gentlemen:
SUBJECT: NRC INSPECTION REPORT NOS. 50-321/86-30 AND 50-366/86-30
As discussed in our letter of February 3,1987, you.* response of December 31,
1986, to our Notice of Violation issued on December 1,1986, concernirg activi-
ties conducted at your Hatch facility, has been evaluated. The results of our
evaluation are provided below.
After careful consideration of the bases for your request to downgrade
Violation A, example 1, we have concluded, for the reasons presented in the
enclosure to this letter, that this request is denied. Note that your responso
did not adequately address the corrective actions over the control of special
procedures and the date when full compliance will be achieved.
We have also
evaluated your denial of Violation A, examples 2 and 3, and have concluded, for
the reasons presented in the enclosure to this letter, that the violations
occurred as stated in the Notico of Violation.
Your response to Violation B admitted the violation but requested withdrawal of
the violation.
Af ter careful consideration of the bases for your request for
withdrawal, we have concluded, for the reasons presented in the enclosure to
this letter, that the violation occurred as stated in the Notice of Violation.
Therefore, in accordance with 10 CFR 2.201(a), please submit to this office
within 30 days of the date of this letter a written statement describing steps
which have been taken to correct Violation A, examples 1, 2, and 3, and
Violation 0 and the results achieved, corrective steps which will be taken to
avoid further violations, and the date when full compliance will be achieved.
The responses directed by this letter and its enclosure 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.
0705190336 070D04
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Georgia Power Company
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May 4, 1987
We appreciate your cooperation in this matter.
Sincerely,
C W '"At t w ~-
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0fi C::
J. Nelson Grace
Regional Administrator
Enclosure:
Staff Evaluation of Licensee
Response to Inspection Report
50-321/86-30 and 50-366/86-30
gc w/ encl:
W . T. Beckham, Vice President.
stI.PlantHatch
C. Nix, Site Operations General
Manager
/A. Fraser, Acting Site QA Supervisor
vl. Gucwa, Manager, Nuclear Safety
and Licensing
Xc w/encI:
pHughS. Jordan,ExecutiveSecretary
RC Resident Inspector
Document Control Desk
State of Georgia
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ENCLOSURE
STAFF ASSESSMENT OF LICENSEE'S RESPONSE
Restatement of Violation A. Example 1
Technical Saecification 6.8.1.a requires the licensee to establish, implement,
and maintain written procedures covering the applicable activities in
Appendix A of Regulatory Guide 1.33, Revision 2. February 1978.
Appendix A
of Regulatory Guide 1.33 recommends establishment of procedures to control
contamination and for the performance of safety-related maintenance.
Technical Specification 6.8.1.c requires the Itcasee to establish and
implement procedures for the conduct of surveillance and test activities of
safety-related equipment.
Contrary to the above,
1.
The licensee failed to provide adequate procedures to control test
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activities on the 2C emergency diesel generator on Monday, October 6,
and Wednesday October 8, 1986.
Summary of Licensee's Response
The licensee stated that Violation A, Example 1, occurred, but not as stated,
and requested that the violation be downgraded from a Severity Level IV to a
Severity Level V violation.
The licensee stated that the special purpose
procedure, 52SP-100386-!E-1-25, Diesel Generator 2C Low Speed Run, was
developed to provide instructions for performing a low speed run of the 2C
diesel generator in order to " break-in" a newly installed turbocharger and that
the procedure was intended to be performed in conjunction with 345V R43-001-25
Diesel Generator Manual Start. The licensee argued that contrary to statements
in the inspection report, procedure 52SP-100386-!E-1-2S was not performed to
meet testing or surveillance requirP,itts of the plant Technical Specification
and, therefore, was not required by Technical Specification 6.8.1.c.
The
licensee stated that the procedure was reviewed and approved in accordance with
10AC-MGR-003-05, Rev. 5, which required maintenance department manager approval
and Plant Review Daard review.
The ifcensee agreed that procedure 52SP-100386 !E-1-25 did not include all
necessary prerequisites for. conducting a low speed run of the 2C diesel genera-
tor and that the procedure writer and the technical reviewer did not identify
the discrepancies.
Also, the licensee stated that the pre-test brief, as
recuired by AG-MGR-21-0306N, Evolution Pre-Test Orief Requirements, did not
ad(ress the inadequacies of Rev. O of the special purpose procedure or identify
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and resolve misconceptions inheront in Rev. 1 of this special purpose procedure.
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Enclosure
2
The licensee expressed a strong belief that Example 1 was not a Severity
Level IV violation,
i.e., failure to meet regulatory requirements that have
more than minor safety or environmental significance, and that the limited
safety significance of Example 1 of the violation was such that it warranted
being downgraded to a Severity Level V.
NRC Evaluation
The NRC staff does not agree with the licensee's statement that Technical Specification 6.8.1.c applies only to the testing or surveillance requirements
of the plant Technical Specifications.
Technical Specification 6.8.1.c
requires the establishment and implementation of procedures for test activities
of all safety-related equipment.
This requirement is not limited to surveil-
lance test activities required by Technical Specifications.
Based on the
licensee's comments, the NRC staff believes that the licensee should examine
its appItcation of Technical Specification 6.8.1.c and confirm in the response
to this letter that procedures are established and implemented for the cor. duct
of surveillance and test activities of safety-related equipment.
The test in question was a special test of an emergency diesel generator
following major maintenance.
The diesel generator is safety-related.
The
special test of 2C diesel generator was first attempted on Monday, October 6,
1986, but contradictions between the special test and operating procedures
resulted in a delay.
These procedure conflicts and the resulting operator
confusion should have been resolved prior to the test attempt and in the
pre-test briefing.
The test )rocedure was revised by the licensee.
PNSC
reviewed and approved the rev'sion, and the test was rescheduled two days
later.
The licensee's response to the violation admits that both the revised
test procedure and the pre-test briefing were deficient.
During the second
test, the inspectors observed the following procedure and operator knowledge
deficiencies:
The vendor directed operators to depress the voltage trip button and then
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to reset it at full RPMs.
This was done to prevent overheating of the
field at low RPMs, but was not in the procedure and was not covered in the
pre-test briefing.
The special procedure contained a caution statement to closely monitor the
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cooling water pressure because the low pressure trip had been defeated.
The procedure did not specify a minimum acceptable cooling water pressure,
and the operator had not been briefed on a limit.
The diesel generator oil level was incorrectly measured prior to the start
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of the test ar.d at 800 RPMs was discovered to be approximately 100 gallons
low. This resulted in a two-hour shutdown to add oil.
The normal operating procedure contained a caution statement against
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operating a diesel generator at low loads for exter 'ad periods of time.
Although this special test required extended diesel operation at reduced
RPHs and loads, the special procedure did not contain this caution, and
the operators were unaware whether the caution was applicable.
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Enclosure
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The above deficiencies in the revised procedure and associated pre-test
briefings had at least a potential to result in a degradation of the diesel's
performance which would not be readily detec able in operability testing.
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procedure and pre-test briefing should have been adequate for the first test
dttempt, and most certainly should have been resolved prior to the second
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attempt. The testing of safety-related equipment under vendors' direction does
not relieve management of the responsibility for ensuring continued integrity
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cf that :"luipment.
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HRC Conclusion
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For the above reasons, the NRC staff denies the licensee's request for down-
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grade of Violation A, Example 1, from a Severity Level IV to a Severity
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Level V.
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Restatement of Violation A, Example 2
Technical Specification 6.8.1.a requires the licensee to establit.h. implement,
and maintain written procedures covering the applicable activities in
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Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Appendix A
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of Regulatory Guide 1.33 recomends establishment of procedures to control
contamination and for the performance of safety-related maintenance.
Plant Procedure 62RP-RAD-017-0 Release Surveys for Trash and Materials Leaving
Operating Duildings, requires that the Health Physics Technician at C-52 is
responsible for ensuring that all persons exiting the control building use the
monitors upon exit.
Contrary to the above,
2.
The requirement that personnel use the monitors when exiting the control
building and that the HP technician ensure this is accomplished was not
met in that on October 9,1986, a contractor was observed exiting the RCA
at Control Point C-52 without using the monitor.
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Sumary of Licensee's Response
The licensee stated that the ins)ection report contained insufficient infor-
mation to confirm or deny the alleged violation and therefore, denied the
violation.
The licensee argued that under certain circumstances, it was
clearly permissible to bypass the monitor at portal C-52 without frisking. The
licensee further stated that if the contractor in question had received a
contamination alarm while frisking and had been refrisked by Health Physics and
releasedt that the individual could leave the area without refrisking.
The licensee contended that as far as they could determine, the NRC inspector
did not take action to stop the violation or the subject individual after the
event occurred and Health Physics supervision was not notified of the alleged
violation, and therefore, was not able to investigate at or near the time of
the event,
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Enclosure
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NRC Evaluation
The inspector informed the three Health Physics technicians present at the C-52
portal of the occurrence immediately.
The contractor in question had already
exited the area and could not be located by the inspector.
The technicians
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stated that they had not noticed the occurrence, which is a violation of Plant
Procedure 62RP-RAD-017-0.
This procedure requires that the technician at C-52
ensure that all persons exiting the control building use the monitors upon
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exit.
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The technicians further stated that all personnel exiting the controlled area
must be frisked prior to exit.
It appears to the inspector that the technicians
on duty at the control point would have been aware of the scenario described
in the licensee's response, if it had occurred.
It was clear to the ins,ector
that the technicians on duty were not aware of the contractor not fris .ing
prior to exit.
Additionally, even though the inspector could identify the
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contract finn that employed the individual, the technicians failed to initiate
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any action to identify the individual involved to prevent recurrence.
NRC Conc 7usion
For the above reasons, the NRC staff concludes that the violation occurred as
stated.
Restaterient of Violation A. Example 3
Technical Specification 6.8.1.a requires the licensee to estaolish, implement
and maintain written procedures covering the applicable activities in
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Appendix A of Regulatory Guide 1.33, Revision 2. February 1978. Appendix A of
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Regulatory Guide 1.33 reconinends establishment of procedures to control
contamination and for the performance of safety related maintenancu.
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Preventive Maintenance Procedure 52PM-MNT 005-05, Revision 3. Limitorque
Valve Operator Inspection, step 7.6.6.13, states in part, perform limit switch
adjustment in accordance with 52GM-MNT-017-05 Linitorque Valve Operator Setup
and Test.
Procedure 52GM-HNT-017-05 was replaced by Procedurn 52GM-MEL-022-05
on February 1986.
Procedure 52GM-MEL-022-05 contains the limit switch
adjustment instruction.
Contrary to the above.
3.
In August 1986, for Maintenance Work Orders 2 86-2136, 2 86-2137 and
2 86-2154, the licensee failed to perform the required limit switch
adjustments in accordance with Preventive Maintenance Procedure
52PM MNT-005 05.
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Enclosure
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Sunmary of Licensee's Response
The licensee denied the violation. The licensee admitted that as stated in the
Notice of Violation, limit switch adjustments were not made in accordance with
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52GM-MNT-017-05. Limitorque Valve Operator Setup and Test, as set forth in
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step 7.6.6.13 of Rev. 3 of 52PM-MNT-005-05, Limitorque Valve Operator Inspec-
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tion.
The licensee argued however that, even though step 7.6.6.13 states
"perfom limit switch adjustments in accordance with 52GM-MNT 017-OS ...", the
intent of the procedural step was to require limit switch adjustment only if
necessary.
The licensee maintained that Maintenance personnel had deterrained
that limit switch adjustment was not necessary since a satisfactory functional
test was performed per 62PM-MNT-005-OS to verify proper limit switch operation
and therefore, the intent of the procedural requirement had been met.
The licensee also noted that the Hatch Procedures Upgrade Program (PUP) wot;ld
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result in development of a large number of very detailed procadures.
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licensee maintained that these procedures would be thoroughly validated (as
recuired by the PUP) to ensure they are technically adequato, user friendly.
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anc completely incorporate all regulatory licensing requirenents.
The licensee
stated that Georgia Power is totally consnitted to obtaining and following
excellent procedures; however, major improvement efforts were seen as a source
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of a relatively large number of noncompliance issues, which the licenseu
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contended had inappropriate and negative implications on their performance,
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The licensee stated that procedure 52PM MNT-005-05 was revised on October 29,
1986, in order to clarify further the procedural requirement for perfoming
limit switch adjustments and that the procedure now requires that "if limit
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switches do not nuko and break as requured, limit switch adjustnents must be
made per approved plant procedure."
NRC Evaluation
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The NRC staff has carefully reviewed the licensee's response and has concluded
that the licensee did not prnvide any information that was not already
considered in determining the violation.
The licensee stated that Maintenance
personnel detemined that limit switch adjustment was not necessary sinco a
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satisfactory functional test was perforned per 52PM-MNf 005 05 to verify proper
limit switch operation.
The functional test the licensee cited does not
fulfill the same function as step 7.6.6.13 of Procedure 52PM MNT-005 05,
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Revision 3.
Step 7.6.6.13 requires the limit switch to be adjusted by using
procedure 52GM MEL 022 05.
This procedure takes certain neasurements that the
licensee's functional test does not requiro.
The procedure verifies that the
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rotor operates prior to 1/8 inch stem travel, in the open and closed direc-
tions, and if not, it requires adjustment.
It also requires the documentation
and observation of the internittent gear shaf t's direction of rotation.
Proceduru $2GM MEL 022 05 also his a precaution on electrical saf ety that
Procedure 52PM MNT 005 05 dccs nn contain.
Both proceduros require the
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valves' closing and opening times be measured, but 62GM MEL 022 05, requires
the test be run three tihes, where the other procedure only requires the timing
to be run once.
Additionally, 5 CGM MEL 022 05 has instructions on how to
adjust the rotors if the valve ooes not pass the timing test. Both procedures
were lacking adequato acceptance criteria for valve closing / opening timing,
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Enclosure
6
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The licensee also states, through the Procedure Upgrade Program, that the
procedures will be thoroughly validated to ensure they are technically
adequate, user friendly, and Coc.pletely incorporate all regulatory licensing
requirements.
Procedure 52PM-MNT-005-05. Rev. 3, which was cited in the
violation, was not a PUP procedure; however, Rev. 4 was an upgrade procedure
and it also required the limit switch adjustnents per Procedure 52GM-MEL-022-05,
step 7.5.2.14
As the licensee stated, these procedures were validated to
ensure technical adequacy, and the Plant Hatch validation process must have
determined that limit switch adjustments per Procedure 52GM MEL-022-05 were
required to ensure proper valve operations.
NRC_ Conclusion
For the above reasons, the fiRC staff concludes that the violation occurred as
stated.
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Re'.tatement of Violation D
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Unit 1 Technical Specifications 3.7,0.1 and 4.7.0.1 and Unit 2 Technical Specifications 3.6.3 and 4.6.3.3 require that primary containnent isolation
valves listed bu operable, and that the isolation times shall be demonstrated
to be within the required limits.
Unit 2 Technical Specification 4.0.5 requires that inservice testing of ASME
Code Class 1, 2, and 3 valves shall be perforned in accordance with Section XI
of the ASME Duiler and Pressure Vessel Code except where specific written
relief has been granted by the Conmission pursuant to 10 CFR 50.55a(g)(6)(1).
ASHC Section XI defines stroke time as the tine interval from initiat1on of the
actuating signal to the end of the actuating cycle.
The E. 1. Hatch Pump and
Valve Test Plan also defines full-stroku time as that tine interval from
initiation of the actuating signal to the end of the actuating cycle.
Contrary to the above, the licensee does nut stroke tine test power operated
valves from initiation of the actuating signal to the end of the actuating
cycle as required by Technical Specifications and ASME Section XI, and the
licensee has not received specific written relief from the requirements of the
ASME Code that requires stroke time testing from initiation of the actuating
signal to the end of the actuating cycle.
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Sumary of Licensee's Response
The licensee admitted that the event, occurred; however, the licensee stated
that tho event had no safety consequences and requested withdrawal of the
violation.
The licensee argued that the contribution of unclear Code require-
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nwnts coupled with a conscious, good faith of fort to comply with a reasonable
interpretation of those requirements would make the imposition of a violation
in this uniquo circumstance an unfair application of f4RC's Enforcenent Policy
App, C).
The licensee bulievel that since it had attempted to
interpret and resolve the Code requiren'ents on stroke time testing and had
concluded that light to-light timing measurenents were permissible, that at the
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timo of the alleged violation the Code connitnent as presently construed by the
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Enclosure
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NRC was not a legally binding requirement.
The licensee stated that viewed
relative to Code interpretations prior to issuance of the Notice of Violation,
GPC's interpretation of Code requirements conflicted with that of the NRC;
i.e., the " commitment" was subject to different interpretations; and upon NRC's
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specific notification, GPC innediately adopted the NRC interpretation.
NRC Evaluation
The licensee does not stroke time test power operated valves as required by
Technical Specifications and ASME Section XI.
The licensee stated in their
response that the violation was the result of a misinterpretation of the ASME
Code requirements.
The inspector conside-s the licensee's initial interpreta-
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tion to be in the non-conservative direction in that the time required tor a
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valve to stroke using the " light-to-light" method will almost always be less
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than the time from the initiation of the actuating signal to the end of the
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actuating cycle, as required by ASME Section XI.
This misinterpretation
was initially identified by the licensee in a Quality Assurance Audit in
November 1984, anu again by the f;RC in July 1986, as documented in Inspection
Report No. 50-321,366/86-22.
It does not appear to the NRC staff that the
licensee took any prompt corrective action to resolve the issue until a
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violation was imminent.
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NRC Conclusion
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For the above reasons, the NRC staff concludes that the violation occurred as
stated,
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