ML20214W367

Responds to Violations Noted in Insp Repts 50-321/86-20 & 50-366/86-20.Corrective Actions:Engineering Evaluation of as-found Configuration Initiated & Design Drawing Modified to Show Acceptable Installation W/O Plain Punched Washers

ML20214W367
Person / Time
Site:	Hatch
Issue date:	09/19/1986
From:	Gucwa L GEORGIA POWER CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
1186T, SL-1193, NUDOCS 8610030073
Download: ML20214W367 (3)

Text

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• Georgia Power Company

• . 'I 333 P;edmont Avenue Atlanta, Georgia 30308 Terephone 404 526 6526 Mamng Address Post Cffice Bc4 4545 Atlanta. Georg a 30302 h Georpa Power L. T. Gucwa [ SEP 26 A 9 : a6 ,. m. .- .

Manager Nuclear Safety and Licensing SL-1193 ll86t September 19, 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, tN Inspection Atlanta, Georgia 30323 Report 86-20 ATTENTION: Dr. J. Nelson Grace Gentl emen:

The following information is submitted in response to Inspection Report No. 50-321/86-20, 50-366/86-20, dated August 20, 1986. The report concerns the inspection performed by Mr. P. Holmes-Ray, of your office, from July 1-31, 1986. Please note our request for reconsideration of Severity Level (SL) Assignment.

NRC NOTICE OF VIOLATION "10 CFR 50 Appendix B, Criterion V requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Contrary to the above, the requirement was not met in that none of the Unit 1 Control Rod Drive Hydraulic Control Units (CRD HCUs) were installed in the design support mounting configuration as required by design drawing 9190615. The CRD HCUs were mounted without the required American Standard Type B common steel plain punched washers.

This is a Severity Level IV violation (Supplement I) and is applicable to Unit 1."

RESPONSE TO NRC NOTICE OF VIOLATION:

Admission or Denial of alleged violation: The event, which had no actual or potential safety consequences, occurred. It should be noted that the use of the existing mounting configuration did not affect the ability of the HCUs to meet their design function.

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Georgia Power A U. S. Nuclear Regulatory Commission Office of Insp& tion and Enforcement Region II - Suite 2900 September 19, 1986 Page Two RESPONSE TO NRC NOTICE OF VIOLATION: (Continued)

Reason for Violation: The event occurred because design and installation controls in place at the time of the HCU installation failed to detect the fact that the washers were not installed per design drawings.

Corrective steps which were taken and the results achieved: Upon discovery, an engineering evaluation of the as-found configuration was initiated. Preliminary results indicated that the configuration did not represent a problem with respect to continued safe operation of the unit. The unit would have been operable during a design basis seismic event. The final results of the engineering evaluation have confirmed the preliminary assessment. Investigation verified that the Unit 2 HCUs do have the plain punched washers installed as required by design drawing 919D615. The entire work control process has been strengthened since initial plant construction. Present plant procedures (e. g., " Design Control ," 40AC-ENG-003-0S; "DCR Processing," 42EN-ENG-001 -0S ; and

" Maintenance Program," 50AC-MNT-001-0S) provide improved design and work control s. These procedures should prevent recurrence of a similar event. The configuration as installed meets the seismic requirements of the system.

Corrective steps which will be taken to prevent recurrence: GPC will have the design drawing modified to show that installation without the plain punched washers is an acceptable condition.

Date when full compliance will be achieved: Compliance will be achieved when the design drawing is modified to reflect the as-built condition.

This action is scheduled to occur before December 31, 1986.

As noted above, GPC has demonstrated that the HCUs would have performed their design function if called upon to do so. The HCUs, in the existing configuration, have not revealed any degradation of performance or service life, nor would their safety function be impaired by a seismic event, because nf the missing washers. The administrative controls for plant modifications described above, which have been in place at Plant Hatch since March 21, 1974 (which is after the installantion of the HCOs), provide appropriate assurance that a similar omission would not now occur. Therefore, due to the " minor safety or environmental significance" of the subject event, we respectfully request that the severity level of this violation be lowered from a SL IV to a SL Y.

1186t 70011$

P GeorgiaPower b U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 2900 September 19, 1986 Page Three If you have any questions in this regard, please contact this office at any time.

Sincerely, eper Q_ _

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

GO-NORMS 1186t 700775

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