ML20214W057

Responds to Violations Noted in Insp Repts 50-321/86-22 & 50-366/86-22 on 860728-0801.Corrective Actions:Control of Work Scope Authorized by Maint Work Orders Reemphasized W/ Maint Dept.Downgrading of Violation a Requested

ML20214W057
Person / Time
Site:	Hatch
Issue date:	11/17/1986
From:	Gucwa L GEORGIA POWER CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
0908C, 908C, SL-1576, NUDOCS 8612100065
Download: ML20214W057 (6)

Text

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• .* Georgia Power company -

333 Piedmont Avenue Atlanta, Georgia 30308 Telephone 404 526-6526

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. Mailing Address:

Post Office Box 4545 Atlanta. Georgia 30302 M gi d ; Neorgia Power L. T. Gucwa IN S0"I'Ur 1 emf"C 3W" Manager Nuclear Safety and Licensing SL-1576 November 17, 1986 U. S. Nuclear Regulatory Commission

REFERENCE:

Office of Inspection and Enforcement RII: JNG Region II - Suite 2900 50-321/50-366 101 Marietta Street, NW Inspection -!

Atlanta, Georgia 30323 Report 86-22 ATTENTION: Dr. J. Nelson Grace Gentlemen:

The following information is submitted in response to the violations cited (

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in Inspection Report No. 50-321/86-22, 50-366/86-22, dated October 17, 1986.

The report concerns the inspection performed by Mr. S. D. Stadler on July 28, through August 1,1986.

NRC NOTICE OF VIOLATION A:

"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 documented procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these procedures.

Hatch procedure 50AC-MNT-001 - 05 [ sic], 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 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-004-0 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 order (MWO) No. 1-86-3998 on April ?0,1986, and the licensee failed to write a new MWO to cover an expansion in scope of the maintenance activities.

- A procedural deficiency was identified during the calibration of a turbidmeter 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.

8612100065 861117 PDR ADOCK 05000321 f G PDR g O g o/

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GeorgiaPower A U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II November 17, 1986 Page 2 NRC NOTICE OF VIOLATION A: (continued)

- An investigation of the failure of a fuel pooling [ sic] pump failure to start conducted under MWO 1-86-3426 on April 10, 1986, determined a discrepancy between actual and rated full load . current. No Deficiency Report was written on corrective action taken.

This is a Severity Level IV violation (Supplement II)."

RESPONSE TO NOTICE OF VIOLATION A:

Admission or denial of alleged Violation: The events, which had no actual or potential safety consequences, occurred.

Reason for Violation: The involved plant personnel erred in not initiating the required MWO to cover changes in workscope. Deficiency Reports (DRs) were not initiated as required because personnel did not clearly understand when a DR was required or who ;as responsible for initiating the DR. The DR procedure is not sufficiently clear in these areas.

Corrective steps which were taken and the results achieved: Deficiency Report number 1-86-1201 was written on November 7, 1986, to address the cited instances.

Corrective steps which will be taken to prevent recurrence: Control of work scope authorized by a particular MWO is being re-emphasized with the Maintenance Department in training meetings. This will be completed by December 10, 1986. Prior to the NRC inspection, site Quality Assurance (QA) had identified inadequacies in the " DEFICIENCY CONTROL SYSTEM" procedure (10AC-MGR-004-0S) . In addition to resolving the QA concerns, the procedure currently is being revised to make it easier for plant personnel to understand when a DR must be initiated and by whom. Part of this corrective action will be the appropriate training of plant personnel on the procedure revision. The procedure is currently scheduled to be implemented by December 26, 1986.

Date when full compliance was achieved: Full compliance was achieved on November 7,1986, when the required Deficiency Report was written.

We request 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 corrective action for the licensee identified item would have prevented the cited violation.

0908C 700775 -

Georgia Power A U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II November 17, 1986 Page 3 NRC NOTICE OF VIOLATION B:

"NRC Confirmatory Order 7590-01, dated July 10, 1981, required implementation of NUREG-0737 Item 10.5 [ sic], Establishment of Procedures for Feedback of Operating Experience to Plant Staff. Paragraph 7 of Item 1C.5 [ sic] requires that the feedback program functions effectively at all levels.

Hatch procedure 30-AC-0PS-003, Plant Operations, Section 4.2.3, requires that the Engineering Department conduct an audit of the functioning of the Operating 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)."

NRC NOTICE OF RESPONSE TO VIOLATION B:

Admission or Denial of alleged violation: The event, which had no actual or potential safety consequences, occurred. It should be noted that it is subsection 8.11.3.4 of 30AC-0PS-003-0S which requires the biennial audit of the Opera'ing Experience Feedback program.

Reason for Violation: Due to personnel oversight, Engineering Department procedures or instructions were not prepared and approved to perform the required audit.

Corrective steps which were taken and the results achieved: The August 1986, INPO evaluation identified (number OE.1 -1 ) that the effectiveness of the existing Operating Experience Feedback Program was not periodically assessed.

A procedure is being drafted to establish the critera for the audit.

Corrective steps which will be taken to prevent recurrence: The effectiveness review procedure for the Operating Experience Program is scheduled to be impicmented and a review performed by February 28, 1987.

Date when full compliance will be achieved: Full compliance will be achieved by February 28, 1987.

0908C 700775

,- s-Georgia Powerd U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II November 17, 1986 Page 4 NRC NOTICE 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-001-05 [ sic], Maintenance Program, Step 8.6.2, states: 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 MWO 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 1T48-F320.

This is a Severity Level IV violation (Supplement II)."

RESPONSE TO NRC NOTICE OF VIOLATION C:

Admission or Denial of alleged violation: The event, which had no actual or potential safety consequences, occurred.

Reason for Violation: The cause is attributed to the unclear procedural wording that exceeds the intent of the procedure. The procedure was not intended to transform diagnostic tests into formal tests for which documentation is required. It is a standard practice for the local leak rate i

test (LLRT) personnel to perform a preliminary diagnostic test after valve l

repair and re-installation prior to completing reassembly (i.e., installation and hookup of valve operator). This diagnostic check is 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 to the repair of valves 1T48-F319 and 1T48-F320. Excessive leakage was apparent, and the valves were removed, repaired and re-installed as part of the process of correcting the observed leakage. The fact that a diagnostic l 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.

Corrective steps which were taken and the results achieved: On November 3, 1986, a memo was issued requiring that diagnostic tests be noted on an MWO continuation sheet.

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GeorgiaPower A U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II

. November 17, 1986 Page 5 Corrective steps -which will be taken to prevent recurrence: The " MAINTENANCE PROGRAM" procedure (50AC-MNT-001-05) is currently over inclusive and will be revised to differentiate between the documentation of required tests and those which are being performed for diagnostic or other purposes. This revision will be implemented by January 10, 1987.

Date when full compliance was achieved: Full compliance was achieved on November 3, 1986.

With regard to Violation 'C', Georgia Power believes that the violation had minor, if any, safety significance. Consequently, Georgia Power respectfully requests that, consistent with the Commission's Enforcement Policy (10 CFR Part 2, App. 2), the cited Violation be recategorized as a Severity Level V. As recognized in the Violation, the results of a

. preliminary, diagnostic leak rate test was not documented. GPC acknowledges that the literal words of administrative control procedure were over inclusive, requiring diagnostic steps if characterized as a " test" to be documented. In response to this particular Violation, GPC will correct the administrative control procedure, so that only tests which are used to determine operability or to meet operability criteria are documented.

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 NOTICE 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, gages, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calitrated, and adjusted at specified periods to maintain accuracy within necessary limits.

Contrary to the- above, the licensee failed to assure that torque multiplier number 391/.268517 was properly calibrated or adjusted to maintain accuracy within necessary limits when used in conjunction with MW0s 1-86-5083 and 1-86-5084.

This is a Severity Level IV violation (Supplement II)."

RESPONSE TO NRC NOTICE OF VIOLATION D:

Admission or Denial of alleged violation: The violation is denied.

Calibration of torque multipliers is an issue which had been previously identified by GPC as a result of ongoing evaluations related to valve 0908C l

Georgia Power 1 U. S. Nuclear Regulatory Comission Office of Inspection and Enforcement Region II November 17, 1986 Page 6 RESPONSE TO NRC NOTICE OF VIOLATION D: (continued) maintenance and was being resolved at the time of this inspection. Corrective steps which have been taken are:

1) Torquing practices at other plants have been reviewed.

2) A Standing Order requiring the use of direct reading torque indicators with torque multipliers or, when a direct reading indicator can not be used, a calibrated torque multiplier or other engineering means for confirming proper torque was issued on November 6,1986.

A general maintenance procedure on torquing (51GM-MNT-033-0S) has been prepared and is in the review, approval and validation process. This procedure contains requirements similar to those in the above Standing Order.

This procedure is scheduled to be issued by December 10, 1986.

If you have any questions in this regard, please contact this office at any time.

Sincerely, L. T. Gucwa MJB/lc c: Georria Power Company U. S. Nuclear Regulatory Commission Mr. s . P. O'Reilly Mr. P. Holmes-Ray, Senior Resident Mr. J. T. Beckham, Jr. Inspector - Hatch Mr. H. C. Nix, Jr.

G0-NORMS 0908C

. 700775