ML20215F798
| ML20215F798 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 12/12/1986 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 0934C, 934C, SL-1643, NUDOCS 8612240067 | |
| Download: ML20215F798 (17) | |
Text
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. muo:"1
-Dpc Attrnta. Georgia 30308 -
Telephona 404 5264526
/
' Mailing Address:
Tbst Office Box 4545 Atlanta, Georgia 30302 -
A Georgi Power 3
L T. Gucwe the souttem ettc system Manager Nuclear Safety
(
and Licensing 0934C
-o December 12, 1986 (A
o 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 NRC Inspection Atlanta, Georgia 30323 Reports 86-28, 86-33 ATTENTION: Dr. J. Nelson Grace Gentlemen:
The following information is submitted in response to the violations cited in NRC Inspection Report. Nos. 50-321/06-28 and 50-366/86-28, dated October 20, 1986.
The Notice of Violation was transmitted by letter I
dated November 7,1986.
The Notice and the associated Report addresses the inspection performed by Mr. P. Holmes-Ray, Senior Resident Inspector, from August 30 through September 30, 1986.
This response also addresses specific issues identified by Mr. Holmes-Ray in Inspection Report Nos.-
50-321/86-33 and 50-366/86-33.
NRC NOTICE OF VIOLATION A:
"TS 4.12. A.1.a for Unit 1 and TS 4.7.2.e.1 for. Unit 2 require verification of less than a 6 inches water (gauge) pressure drop across the main control room combined HEPA filters and charcoal absorber banks while operating at the system design flow rate, 2,500 cf n +/- 10%.
TS 6.8.1.c for Units 1 and 2 requires written procedur% for surveillance and test activities of safety related equipment.
The p w.edure for the preparation and control of procedures, 10AC-MGR-003-05, Revision 4,
Section 8.3.2.3.12, requires that acceptance criteria shall be contained in the text of a procedure and must include acceptance range where applicable.
Surveillance procedure 57SV-Z41-002-1, Revision 0, is the written procedure for accomplishing the above TS required surveillance.
Contrary to the above, surveillance procedure 57SV-Z41-002-1, Revision 0, I
was inadequate in that it did not ensure that the volumetric flow rate was at the TS required flow prior to measuring the pressure drop across the main control room HEPA filters and charcoal absorber banks.
This procedure did not provide a manometer differential pressure acceptance l
criterion nor a conversion method to obtain the required volumetric flow rate.
This is a Severity Level' IV violation (Supplement I) - Both units."
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Georgia Power d U. S. Nuclear Regulatory Conenssion Office of Inspection and Enforcement Region II December 12, 1986 Page Two RESPONSE TO NOTICE OF VIOLATION A:
Admission or dental of alleged violation:
The event, which had no actual or potential safety consequences, occurred.
It should be noted that procedure 57SV-Z41-002-1S, Rev. O, did have a requirement to ensure that the volumetric flow rate was at the Technical Spec;fication value prior to measuring the pressure drop across the main control room HEPA filters and charcoal adsorber banks.
Reason for violation:
The violation was the result of an inadequate procedure in that 57SV-Z41-002-15 did not fully incorporate the requirements of procedure HNP-9.
(Procedure HNP-9 is the predecessor to 10AC-MGR-003-0S )
Corrective steps which were taken and the results achieved:
Surveillance test 575V-Z41-002-lS was performed satisfactorily on September 26, 1986.
The Engineering Department assisted in the performance of this test procedure by performing a 20-point Pitot Traverse Test.
The volumetric flow rate requirement of 2500 CFM + 10% (i.e., 2250 to 2750 CFM), with a pressure drop of less than 6 inches water gauge, was satisfied for both filter trains.
Corrective steps which will be taken to prevent recurrence:
During the implementation of the Procedure Upgrade
- Program, procedure 57SV-Z41-002-1S will be superseded; the contents of the former procedure will be incorporated into procedure 42SV-T46-003-1S, " Testing of C.
R.
and SBGT Filter Trains by Vendor."
Detailed instructions for converting the field measurements to the values necessary for direct comparison to the requirements of the Technical Specifications will be included.
The upgrade of 42SV-T46-003-1S will be completed by August 17, 1987; and at a result procedure 42SV-T46-003-1S will meet the current requirements of procedure 10AC-MGR-003-0S and enable demonstration of compliance with the Technical Specifications prior to the next scheduled surveillance due date as shown in the RESPONSE TO NOTICE OF VIOLATION 8.
Date when full compliance will be achieved:
Full compliance with the Technical Specifications was achieved on September 26, 1986, wher. the procedure performance demonstrated compliance with the Technical Specifications requirements.
Full compliance with respect to the requirements of procedure 10AC-MGR-003-0S will be achieved by August 17, 1987, when the acceptance criteria requirements have been incorporated into procedure 42SV-T46-003-1S.
0934C
~
Georgia Power A U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II December 12, 1986 Page Three ADDITIONAL TOPICS RELATIVE TO INSPECTION REPORT 86-33:
Inspection Report Nos. 50-321/86-33 and 50-366/86-33 requested that the response to this violation (86-28-01) discuss the following:
"...the cause of the Unit 1 emergency diesel generator day tank [ volume] conversion problem identified in this report and proposed corrective actions to preclude similar occurrences."
In Report No.
86-33, the conversion problem was described as:
"During the review of the monthly diesel generator (D/G) manual start surveillance, procedure 34SV-R42-001-1S [ sic],
Revision 3,
the Resident Inspector found that:
Step 7.4.4.4 required the Unit-1 control room D/G reading be greater than 900 gallons after this test.
However, no procedural means was established to convert the unitless control room D/G day tank scale of 0 to 1 into gallons of fuel.
Al so, the Unit-1 D/G fuel oil transfer pump operability procedure, 34SV-Y52-001S, Revision 1,
step 7.2.8, had the same discrepancy.
This problem did not apply to Unit-2, since procedure, 34SV-R43-002-2, Revision 0, provides the conversion from control room D/G day tank indication to volume."
RESPONSE TO ADDITIONAL TOPICS:
On November 12, 1986, the Unit 1 day tank level indicators were " marked" and labeled "900 GAL," thereby allowing plant personnel to observe the i
indicator and confirm that a level of greater than 900 gallons exist.
Therefore, a conversion factor is not needed in the procedure.
In addition, even though the Unit 2 procedure has a conversion formula, the Unit 2 day tank level indicators will be " marked" in the near future to preclude a similar conversion error.
NRC NOTICE OF VIOLATION B:
"TS 4.12. A.1.a for Unit 1 and TS
- 4. 7. 2. e.1 for Unit 2 require verification of the pressure drop across the main control room combined HEPA filters and charcoal adsorber banks at least once every 18 months.
i l
0934C rwns
Georgia Power A U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II December 12, 1986 Page Four NRC NOTICE OF VIOLATION B: (Continued)
TS 4.0.2.b for Unit 2 requires the frequency of each TS surveillance requirement not exceed 3.25 times the specified surveillance interval for any 3 consecutive surveillance intervals.
Contrary to the above, surveillance procedure 57SV-Z41-002-1, Revision 0, was not performed within the TS required 18 month interval for two intervals since 1979.
In addition, the Unit 2 limit of 3.25 times the 18 month surveillance interval for three consecutive surveillances was exceeded by more than 2 years.
The last four times that surveillance procedure 57SV-Z41-002-1 was done were:
September 25, 1986; October 25,1984; March 13,1981; and May 8, 1979.
The periods of 43 months between 1981 and 1984 and of 23 months between 1984 and 1986 both exceeded the 18 months surveillance frequency of each unit.
The period of 85 months between the 1979 and 1986 surveillances exceeded the TS limit of 3.25 times the surveillance interval for three consecutive surveillances by more than 2 years (Unit 2).
This is a Severity Level IV violation (Supplement I) - Both units."
RESPONSE TO NOTICE OF VIOLATION B:
Admission or denial of alleged violation:
As shown below, the event, which had no actual or potential safety consequences, occurred.
The following infromation is included to amplify the details of the violation:
Due Latest Actual Date Date Performance Date 02/24/81 07/10/81 03/13/81 08/24/82 01/08/83 10/25/82*
02/24/84 07/10/84 10/25/84 08/24/85 01/08/86 12/06/85 02/24/87 07/11/87 09/26/86
- This date is not documented as discussed in the next section.
093cC res
Georgia'Pbwer d U. S. Nuclear Regulatory Conunission Office of' Inspection and Enforcement Region II 9ecember 12, 1986 Page Five RESPONSE TO NOTICE OF VIOLATION B: (continued)
For ease of discussion, the stated violation is divided into three " events":
- 1. Failure to perform the required surveillance at the required 18-month frequency in accordance with Unit 1 Technical Specification 4.12.A.1.a and Unit 2 Technical Specification 4.7.2.e.1 for the 43-month period between March 13, 1981, and October 25, 1984.
- 2. Failure to perform the required surveillance at the required 18-month frequency in accordance with Unit 1 Technical Specification 4.12.A.1.a dnd Unit 2 Technical Specification 4.7.2.e.1 for the 23-month period between October 25, 1984, and September 26, 1986.
- 3. Exceeding the limit given in Unit 2 Technical Specification 4.0.2.b of 3.25 times the 18-month interval for the performance of any three consecutive surveillances.
Event "1"
occurred, althcugh it should be ncted that the Plant Hatch Surveillance Coordinator's ecords indicate that the Control Room Filter Train differential pressure te.i t (then procedure HNP-1-3562, now procedure 57SV-Z41-002-1 ) was performed on October 25, 1982. Assuming that this date is j
correct, the required surveillance would have been performed once during the 43-month period; however, the October 25 date is unsupported by " official" documentation (i.e., a completed data package). ' Furthermore, if the October 25, 1982, performance date is valid, a 24-month period between this date and October 25,1984, (the next performance date) would exist.
Event "2" did not occur, because involved I & C personnel documented that procedure 57SV-Z41-002-1 was performed satisfactorily on December 6,1985.
i Event "3"
occurred, because the three consecutive surveillances perfonned between May 8,1979, and December 6,1985, spanned a period of approximately 79 months, which is 20.5 months longer than the allowed 58.5 months (3.25 times the 18 month surveillance interval ).
These calculations take into account the (recently supported) December 6, 1985, performance but not the unsupported surveillance date of October 25, 1982.
Because these calculations use the December 6, 1985, performance date, a 10-month discrepancy exists between the numbers listed above and the numbers indicated in the subject l
violations.
i i
Reason for violation:
The violation was the resul t of personnel error combined with a difference in the requirements of the Unit 1 and the Unit 2 Technical Specifications. The surveillances were thought to have been l
1 j
0934C mm
k Georgia Power n U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II December 11, 1986 Page Six RESPONSE TO NOTICE OF VIOLATION B: (continued)
Reason for violation:
(continued) scheduled to satisfy the requirements of the more restrictive Unit 1
Technical Specifications.
- However, the surveillance "due dates" were incorrectly assigned based upon the operating cycle completion date and not upon the previous due date of the surveillance (i.e. the scheduled due date was assigned to be 18 months after the reactor startup following a scheduled refueling outage).
Misplaced documentation relative to the October 25, 1982, and December 6,1985, performance data or improperly completed surveillance assignment sheets were contributing factors to the violation.
Corrective steps which were taken and the results achieved:
The Technical Specification surveillance scheduling program revision process (e.g., changes in frequency and due date) was strengthened in May 1985 in response to missed surveillances caused by an error in a frequency change.
As part of the corrective action in response to these problems, frequency changes are independently verified to ensure they were made properly.
Since that time, no missed surveillances caused by a change in the scheduling frequency have been identified.
Procedure 575V-Z41-002-1 was performed on September 26, 1986.
Involved I&C personnel stated that procedure 57SV-Z41-002-1 was performed on December 6, 1985.
With these two performances, the surveillance has been performed at the required frequency (of both Technical Specifications) since the October 25, 1984, performance.
In addition, surveillance due dates are now based upon the previous due date of the surveillance (taking into consideration the operating cycle time length) and not solely upon the operating cycle completion date.
We believe the lost documentation to be an isolated incident.
Corrective steps which will be taken to prevent recurrence:
No further corrective steps are necessary beyond the performance of the procedure at its next due date in order to be in compliance with the 3.25 times 18-month surveillance interval.
The surveillance is currently scheduled for August 17, 1987.
Date when full compliance will be achieved:
With the September 26, 1986, performance of procedure 57SV-Z41-002-lS, the last three surveillances October 25, 1984; December 6, 1985; and September 25, 1986) were performed within the required frequency.
The performance of procedure 42SV-T46-003-lS (which will replace procedure 57SV-241-002-lS, as noted in the RESPONSE f0 NOTICE OF VIOLATION A) by the required due date of August 17, 1987, to meet the appropriate Technical Specifications requirements will ensure that the last three surveillances will be within "the 3.25 times the 18-month surveillance interval."
0934C mm
Georgialbwer A U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II December 12, 1986 Page Seven ADDITIONAL INSPECTION REPORT 86-28 TOPICS:
In addition to the need for corrective action regarding the specific matters identified in the enclosed Notice, we are concerned about the implementation of your Procedure Upgrade Program (PUP) to prevent missed surveillances.
Consequently, your response should describe those particular actions taken or planned to PUP milestones and completion [ sic] program including the improve the effectiveness of your dates.
I RESPONSE TO ADDITIONAL TOPICS:
i The Procedure Upgrade Program currently in progress at Plant Hatch is resulting in procedures that are technically correct and complete.
This i
process will verify that the procedures fully satisfy the requirements of the Technical Specifications.
As part of this process, procedures relative to systems that are shared between the units, such as the control room, will be jointly reviewed to assure compliance with both unit's Technical Specifications.
Thus, the end result will be a system of procedures that will prevent missed surveillances which could result from technically inadequate surveillance procedures.
Enclosed is a copy of the information which Georgia Power Company representatives distributed on November 20, 1986, during a meeting with NRR Project Licensing Management and the NRC Staff.
The information describes the Procedure Upgrade Program and includes graphs that show its current The schedule calls for the Procedures Upgrade Program to be status.
J completed by December 31, 1987.
If you have any questions in this regard, please contact this office l
at any time.
1 l
Sincerely, L. T. Gucwa y
Enclosures MJB/lc mrm
s Georgialbwer A U. S. Nuclear Regulatory Consission Office of Inspection and Enforcement Region II December 12, 1986 Page Eight 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. ~
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