ML20214K287
| ML20214K287 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 05/14/1987 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | James O'Reilly GEORGIA POWER CO. |
| References | |
| NUDOCS 8705280395 | |
| Download: ML20214K287 (8) | |
See also: IR 05000321/1986022
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May 14, 1987
orgia Power Company
TTN: Mr. James P. O'Reilly
Senior Vice President-Nuclear
Operations
P. O. Box 4545
Atlanta, GA 30302
Gentlemen:
SUBJECT:
REPORT NOS. 50-321/86-22 AND 50-366/86-22
Thank you for your response of November 17, 1986, to our Notice of Violation
issued on October 17, 1986, concerning activities conducted at your Hatch
facility.
We have evaluated your response and found that it meets the
requirements of 10 CFR 2.201.
We will examine the implementation of your
actions to correct Violations A, B, and C during future inspections.
After careful consideration of your request that Violation A be withdrawn,
we have concluded, for the reasons presented in the enclosure to this letter,
that the violations occurred as stated in the Notice of Violation.
As
described in the enclosure, the NRC has decided to downgrade Violation C
from Severity Level IV to V due to limited safety significance. Additionally,
Violation D is considered licensee identified and will be withdrawn.
Should you have any questions concerning this letter, please contact us.
Sincerely,
(Original signed by A. F. Gibson for)
J. Nelson Grace
Regional Administrator
Enclosure:
Staff Assessment of Licensee
Response
cc w/ enc 1:
(See page 2)
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8705280395 870514
ADOCK 05000321
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Georgia Power Company
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May 14, 1987
f.c w/ encl:
VJ. T. Beckham, Vice President,
/ Nuclear Operation
VH. C. Nix, Site Operations
/A. Fraser, Acting Site
General Manager
QA Supervisor
,/ L. Gucwa, Manager, Nuclear
Safety and Licensing
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bec w/ encl:
RC Resident Inspector
Hugh S. Jordan, Executive Secretary
-Document Control Desk
State of Georgia
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ENCLOSURE
STAFF ASSESSMENT OF LICENSEE RESPONSE
Restatement of Violation A
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10 CFR 50, Appendix B, Criterion V, and the licensee's accepted QA program
(HNP-2, FSAR-17, Section 17.2.5) require that activities affecting quality
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shall be prescribed by documented procedures of a type appropriate to the
circumstances and shall be accomplished in accordance with these procedures.
Hatch procedure 50AC-MNT-001-05, Maintenance Program, requires that
deficiencies or nonconforming equipment noted during maintenance activities
shall be documented and controlled in accordance with 10AC-MGR-004-0,.
Deficiency Control System, and documented on the maintenance work order (MWO)
in " Actual Work Performed" (Block 27).
If it is necessary to change the scope
of work during maintenance activities, an MWO will be written to cover the
change.
Hatch Procedure 10AC-MGR-004-05 also requires that a Deficiency Report be
written for deficiencies on nonconforming equipment identified during
maintenance activities.
Contrary to the above:
The HPCI turbine failed to meet acceptance criteria under maintenance work
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order (MW0) No.1-86-3998 on April 30, 1986, and the licensee failed to
write a new MWO to cover an expansion in scope of the maintenance
activities.
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A procedural deficiency was identified during the calibration of a
turbidimeter under MWO 1-84-4872 on May 31, 1986, and the licensee failed
to initiate a Deficiency Report to document the deficiency and ensure
prompt corrective action.
An investigation of the failure of a fuel pool cooling pump to start
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conducted under MWO 1-86-3426 on April 10, 1986, determined a discrepancy
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between actual and rated full load current.
No Deficiency Report was
written on corrective action taken.
Summary of Licensee's Response
The licensee argues that although the events occurred, there were no actual or
potential safety consequences.
The licensee stated that the involved plant
personnel erred in not initiating the required MWO to cover changes in
work scope and that deficiency reports (DRs) were not initiated as required
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because personnel did not clearly understand when a DR was required or who was
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responsible for initiating the DR because the DR procedure was not sufficiently
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clear in those areas.
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Enclosure
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The licensee indicated that Deficiency Report No.
1-86-1201 was written on
November 7, 1986, to address the cited instances and that control of work scope
authorized by a particular MWO would be re-emphasized with the Maintenance
Department in training meetings by December 10, 1986. The licensee states that
prior to the NRC inspection, site Quality Assurance (QA) had identified
inadequacies in the Deficiency Control System procedure (10AC-MGR-004-05).
In
addition to resolving the QA concerns, the licensee was revising the procedure
to make it easier for plant personnel to understand when a DR must be initiated
and by whom.
Part of this corrective action would be the appropriate training
of plant personnel on the procedure revision.
The procedure was scheduled to
be implemented by December 26, 1986.
The licensee requested that Violation "A" be downgraded to an Inspector
Followup Item based on the fact that procedure 10AC-MGR-004-0S was in the
process of revision at the time of the citation due to a licensee identified
problem.
The licensee contends that the corrective action for the licensee
identified item would have prevented the cited violation.
NRC Evaluation
For a violation to be considered licensee identified, it must have been
identified by the licensee; fit in a Severity Level IV or V category; be
reported if required; and most importantly, it should not be a violation that
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could reasonably be expected to have been prevented by the licensee's
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corrective action for a previous violation.
Contrary to the above requirements, the corrective actions stated in the
licensee's response,
i.e., training of maintenance personnel on control of
work scope and the revision of procedure 10AC-MGR-004-0S did not occur until
December 10 and 26, 1986, respectively.
The three examples cited in the
violation occurred in April and May 1986, and were not prevented by the
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corrective actions implemented in December.
In addition, a similar violation was cited on December 26, 1984,
(50-321,366/84-46-02), and the corrective actions implemented appear neither
timely nor adequate.
The most recent event involving accidental release of
spent fuel pool water appears to be a further indication of a generic failure
of the corrective action program to ensure effective corrective action for
deficiencies identified during maintenance activities.
NRC Conclusion
For the above reasons, the NRC staff denies the licensee's request to downgrade
the violation to an Inspector Followup Item.
The three examples cited in the
violation occurred approximately six months prior to the implemented corrective
actions, and do not meet the requirements of Part 2, Appendix C, for licensee
identified violations.
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Enclosure
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Restatement of Violation 8
NRC Confirmatory Order 7590-01, dated July 10, 1981, required implementation
of NUREG-0737 Item I.C.5,
Establishment of Procedures for Feedback of
Operating Experience to Plant Staff.
Paragraph 7 of Item I.C.5 requires
that the feedback program functions effectively at all levels.
Hatch procedure 30-AC-0PS-003, Plant Operations, Section 4.2.3, requires that
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the Engineering Department conduct an audit of the functioning of the Operating
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Experience Feedback Program at all levels on a biennial frequency.
Contrary to the above, audits of the functioning of the Operating Experience
Feedback Program at all levels have not been performed and documented by the
Engineering Department.
This is a Severity Level IV violation (Supplement II).
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Summary of Licensee's Response
The licensee noted that it is subsection 8.11.3.4 of 30AC-0PS-003-0S which
requires the biennial audit of the Operating Experience Feedback Program. The
licensee stated that due to personnel oversight, Engineering Department
procedures or instructions were not prepared and approved to perfonn the
required audit.
The licensee noted that the August 1986, INP0 evaluation
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identified (number OE.1-1) that the effectiveness of the existing Operating
Experience Feedback Program was not periodically assessed.
A procedure was
being drafted to establish the criteria for the audit. The licensee committed
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to implement a procedure for the Operating Experience Program review by
February 28, 1987.
The licensee argues, however, that although the event
occurred, there were no actual or potential safety consequences.
NRC Evaluation
The NRC does not agree with the licensee's statement that the violation had no
actual or potential safety consequences.
The NRC staff noted that in April of
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1985, the licensee was cited for a failure to provide operational experience
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feedback training to maintenance personnel (321, 366/85-07-03). The licensee's
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responses indicated that maintenance personnel would be added to the procedure
governing operational feedback training (HNP-911), and that operating
experience feedback training would be provided to maintenance personnel.
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During the current inspection, over a year later, it was determined that this
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required training had still not been implemented for maintenance personnel.
In
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addition, the failure to perform the audits of the functioning of the program
at all levels, as cited above, resulted in this deficiency continuing for an
extended period of time, and in less than timely corrective action to the 1985
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violation.
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Enclosure
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NRC Conclusion
The NRC considers that the licensee's statement that the violation had no
actual or potential safety consequences was not appropriate.
The implementa-
tion of program features which assure quality and the prompt correction of
deficiencies are considered essential to plant safety.
Restatement of Violation C
10 CFR 50, Appendix B, Criterion V, and the licensee's accepted QA program
(HNP-2, FSAR-17, Section 17.2.5) require that activities affecting quality
shall be prescribed by procedures of a type appropriate to the circumstances
and shall be accomplished in accordance with these procedures.
Hatch administrative control procedure 50AC-MNT-001-0S, Maintenance Program,
Step 8.6.2, requires that:
the results of all inspections and tests performed
shall be documented and further action based on results and the documentation
will become part of the MW0 package.
Contrary to -the above, the licensee failed to document the results of the
preliminary leak rate test associated with MW0s 1-86-5083 and 1-86-5084
concerning repairs on drywell vent valves 1T48-F319 and IT48-F320.
Summary of Licensee's Response
The licensee stated that the cause of the violation was attributed to
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unclear procedural wording that exceeds the intent of the procedure.
The
licensee also argues the following points.
The procedure was not
intended to transform diagnostic tests into formal tests for which documenta-
tion was required.
It was a standard practice for the local leak rate test
(LLRT) personnel to perform a preliminary diagnostic test after valve repair
and reinstallation prior to completing reassembly (i.e., installation and
hookup of valve operator).
This diagnostic check was intended to minimize
both labor and radiation exposure by early identification of problems, prior to
formal LLRT.
In the cited case, the diagnostic test was performed subsequent
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to the repair of valves 1T48-F319 and 1T48-F320.
Excessive leakage was
apparent, and the valves were removed, repaired and reinstalled as part of the
process of correcting the observed leakage.
The fact that a diagnostic test
was performed was not noted on the MWO continuation; thus, the inspector, as
noted in the inspection report, could not determine why the valves had been
removed.
The licensee stated that on November 3,1986, a memo was issued requiring that
diagnostic tests be noted on an MWO continuation sheet. The licensee concluded
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that the Maintenance Program procedure (50AC-MNT-001-0S) was over inclusive and
stated that it would be revised to differentiate between the documentation of
required tests and those which are being performed for diagnostic or other
purposes. The licensee committed to complete this revision by January 10, 1987.
With regard to Violation "C", the licensee argued that the violation had minor,
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if any, safety significance.
The licensee requested that, consistent with
the Commission's Enforcement Policy (10 CFR Part 2, App. 2), that the cited
Violation be recategorized as a Severity Level V.
The licensee stated that the
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Enclosure
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literal words of adrinistrative control procedure 50AC-MNT-001-0S were over
inclusive, requirirg diagnostic steps if characterized as a " test" to be
documented.
The licensee committed to correct the administrative control
procedure so that only tests which are used to determine operability or to
meet operability criteria are documented.
The licensee argued, however, that
diagnostic tests, such as the one identified by the inspection report, are
akin to visual observations of conditions and are not intended to be formally
documented.
NRC Evalut. tion
The NRC staff does not agree with the licensee's statement that formal
documentation would be limited to only tests that determine operability
or meet operability criteria.
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3.2/N18.7-1976, which the licensee is committed to in their Quality Assurance
Program (HNP-2, FSAR-17, Appendix A.33), Section 5.2.7, Maintenance and
Modification, requires that means for assuring quality of maintenance and
modification activities (for example, inspections, measurements, tests,
welding, heat treatment, cleaning, nondestructive examination and worker
qualification in accordance with applicable codes and standards) and measures
to document the performance thereof shall be established. ANS-3.2/N18.7-1976,
defines inspections as examination, observation or measurement to determine
the conformance of materials, supplies, components, parts, appurtenances,
systems, personnel performance, procedures, processes or structures to
predetermined requirements.
Additionally, the standard defines testing as
performance of those steps necessary to determine that systems or components
function in accordance with predetermined specifications.
As per the committed standard, tests, inspections, observations and/or as the
licensee states diagnostic tests are means for assuring quality'of maintenance
and require documentation.
NRC Conclusion
The NRC accepts the licensee's statement that this single event has minor
safety significance, therefore, the severity level will be changed to V.
Restatement of Violation D
10 CFR 50, Appendix B, Criterion XII, and the licensee's accepted QA program
(HNP-2, FSAR-17, Section 17.2.12) require that measures shall be established to
assure that tools, gauges, instruments, and other measuring and testing devices
used in activities affecting quality are properly controlled, calibrated, and
adjusted at specified periods to maintain accuracy within necessary limits.
Contrary to the above, the licensee failed to assure that torque multiplier
number 391A268517 was properly calibrated or adjusted to maintain accuracy
within necessary limits when used in conjunction with MW0s 1-86-5083 and
1-86-5084.
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Enclosure
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Summary of Licensee's Response
The licensee denied the violation.
The licensee argued that calibration of
torque multipliers is an issue which had been previously identified by the
licensee as a result of ongoing evaluations related to valve maintenance and
was being resolved at the time of the inspection.
The licensee stated that
corrective steps included the review of torquing practices at other plants and
issuance, on November 6,1986, of a Standing Order requiring the use of direct
reading torque indicators with torque multipliers or, when a direct reading
indicator cannot be used, a calibrated torque multiplier or other engineering
means for confinning proper torque.
In addition, a general maintenance procedure on torquing (51GM-MNT-033-05) had
been prepared and was in the review, approval, and validation process.
The
licensee stated that this procedure contained requirements similar to those in
the above Standing Order.
The procedure was scheduled to be issued by
December 10, 1986.
NRC Evaluation
At the time of the inspection, the week of July 28, 1986, the licensee did not
indicate or provide any ongoing evaluation related to the use and/or calibra-
tion of torque multipliers.
If the evaluation was ongoing, the continued
use of non-calibrated test equipment (torque multipliers) until November 6,
1986, a three-month period, appears to be marginal for timely corrective actions.
However, the NRC accepts the licensee's statement that the item was licensee
identified.
NRC Conclusion
For the above reasons, the NRC staff concludes that the violation will be
withdrawn. Our records will be adjusted to reflect the withdrawal.
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