ML20215M225

Responds to NRC Re Violations Noted in Insp Repts 50-321/86-30 & 50-366/86-30.Corrective Actions:Special Purpose Procedure 52SP-100386-IE-1-2S Revised & Testing Satisfactorily Performed on 861009.Personnel Counseled

ML20215M225
Person / Time
Site:	Hatch
Issue date:	06/23/1987
From:	Gucwa L GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
SL-2541, NUDOCS 8706260317
Download: ML20215M225 (10)

Text

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Georgia Power Company 333 Piedmont Avenue Atlanta, Georgia 30308 Telephor.e 404 526 6526 l Maihng Address FMt Office Bor 4545 Atlanta. Georgia 30302 b Georgia Power L T. Gucwa # " N '" 7" "EF"3 M"*

Manager Nuclear Safety and Ucensing SL-2541 l 1399C X7GJ17-H120

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June 23, 1937 j i

U. S. Nuclear Regulatory Commission  !

ATTN: Document Control Desk j Hashington, D. C. 20555 j PLANT HATCH - UNITS 1, 2 )

hRC DOCKETS 50-321, 50-366 j OPERATING LICENSES DPR-57, NPF-5 '

RESPONSE TO INSPECTION REPORT 86-3_Q Gentlemen:

In rc:poan tc your letter of May 4,1987, and in accordance with the l Fovisions of 10 CFR Section 2.201, we have enclosed our revised )

responses to the Notice of Violation associated with Inspection Report 86-30.

Through beneficial discussions with members of the Region II staff, we have carefully reviewed our assessment of the findings identified and are j providing additional information. This letter has been delayed to permit '

those discussions with Region II personnel. If your should have any questions in this regard, please contact us at any time.

Sincerely, 2v g . T.

l Gucwa MJB/lc l

Enclosures:

1. Violation 86-30-01 and GPC Response

2. Violation 86-30-02 and GPC Response c: (see next page) v T

B706260317 870623 DR ADOCK 05000321 /) \

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1 Georgia Power 1 U. S. Nuclear Regulatory Commission June 23, 1987 Page Two c: G90raia Power Company Mr. J. P. O'Reilly, Sr. Vice President - Nuclear Operations Mr. J. T. Beckham, Jr., Vice President - Plant Hatch GO-NORMS L S. Nuclear Regulatory Commission. Reaion II Dr. J. N. Grace, Regional Administrator Mr. P. Holmes-Ray, Senior Resident Inspector - Plant Hatch ,

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Georgia Powerkn ENCLOSURE 1 PLANT' HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 .

NRC NOTICE OF VIOLAIJON 86-30-01 AND GPC RESPONSE NRC NOTICE OF VIOLATION 86-30-01

" Technical Specification 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 1987 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 licensee Lto establish and implement procedures' for the conduct of ' surveillance and . test activities

.of safety related equipment.

Plant Procedure 62RP-RAD-017-0, Release Surveys for Trash and ' Materials Leaving Operating Buildings, 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.

Preventive Maintenance Procedure 52PM-MNT-005-0S, Revision 3, ~ Limitorque Valve Operator Inspection, step 7.6.6.13, states in part, perform limit' switch adjustment in accordance with 52GM-MNT-017-OS, Limitorque Valve Operator Setup and Test. Procedure 52GM-MNT-017-0S was replaced by

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Procedure 52GM-MEL-022-OS on February 1986. 52GM-MEL-022-0S contains-the limit' switch adjustment instruction.

Contrary to the above,

1. The licensee failed to provide adequate procedures to control test activities on the 2C emergency diesel generator on Monday, October 6 and Wednesday, October 8, 1986, 1399C- El-1 6/23/87 SL-2541 j

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Georgia Powerkh ENCLOSURE 1 (Continued)

NRC NOTICE OF VIOLATION 86-30-01 AND GPC RESPONSE

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. i

3. In August 1986, for Maintenance Hork' . Orders, 2-86-2136, 2-86-2137 and 2-86-54[ sic] the licensee failed to perform the required limit switch adjustments in accordance with ' Preventive Maintenance Procedure 52PM-MNT-005-05.

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

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ResDonse to ViQllt1QD:

1 For. ease of consideration, the Notice of Violation is ' divided into its

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three component subparts.

Suboart 1  ;

Admission or denial of violatips: The violation occurred.

Reason ' for ' violation: GPC's administrativ'e. control'/- provide assurance that Technical Specifications 6.8.1.c is met by rc:;uiring that procedures  ;

be developed and implemented for surveillance and test activities related j to safety-related equipment. To clarify our statements in the December- '

31, 1986, response, Special Purpose Procedure 52SP-100386-IE-1-2S was ' -

developed, reviewed and approved as required by :10AC-MGR-003-0S and Technical Specifications 6.8.1.c. This procedure was not performed for a  !

surveillance or test required by the_ Technical Specifications. The procedure was developed and used for testing of a new turbocharger that was being installed as preventative maintenance.

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[ ENCLOSURE 1 (Continued) s NRC NOTICE OF VIOLATION 86-30-01 AND GPC RESPONSE l

Ho'deser, due to an inadequate technical review of Special Purpose Procedure 52SP-100386-IE-1-2S and an inadequate. pre-test briefing, a violation of regulatory requirements did . occur. Specifically, procedure ,

52SP-100396-IE-1-2$ did not contain all necessary prerequisites for I conducting a loV speed run of the 2C. diesel generator and this deficiency was siot detected by by 'the writer or..the~ technical reviewer. The pre-test briefing was deficient in that it did not address the inadequac3ed *of Revision 0 of the special' purpose procedure, nor did. it .'

resohe some '

'of the misconceptions inherent in Revision 1 to this I procedur). '+

Y Correciive steos which have been taken: The special purpose procedure was revisediand stesting was satisfactorily performed on October 9,1986.  !

As a result ofi our further evaluation. of the event, an additional  !

- corrnc tive measure was taken: . involved - personnel were counseled I concerning the ,use of special purpose procedures and pre-test briefings.

s C_qriettive stens which wil'1 be_ taken to orevent recurrence: No further actions are required...

\ DLte whfn fuli compliance will be achieved: Full compliance has been achieved.

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' Suboart 2: ,

Admission or denial of violation: This subpart can neither' be admitted - s nor denied. 1 s

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ENCLOSURE 1 (Continued) .

NRC NOTICLOF VIOLATION 86-30-01 AND GPC RESPONSE Rg3 son for violation: He have carefully reviewed your letter of May 4, 1987. In order to be sure that we were not overlooking something, GPC cor. ducted an additional review- of our records and notes, and had discussions with members of the plant staff. . No new information .has . been {

identified which might support the existence of a violation. GPC, therefore, cannot acknowledge the. violation, nor can we deny the violation.

As noted in our letter in response to Inspection Report 86-34 dated May 29, 1987, GPC has historically been in the vanguard of the nuclear industry with respect to Health. Physics practices and intends to continue.

its leadership role. Plant Hatch has led the industry in development and  !

implementation of more reliable and sensitive contamination monitoring equipment and programs.

Georgia Power Company (GPC) pioneered the use of automated " stand-in" ,

personnel- friskers at U. S. nuclear power plants through installations at )

Plant Hatch in 1984. One of the best ways to assure frisking at the proper rate is to place the item or person to be frisked in a monitor with a fixed counting time. The one advantage of this approach is ~ the resultant frisk is -faster than the hand-held frisk. In 1986 the contamination monitors at Plant Hatch were used more than 1.5 million j times. GPC will continue to both search for ways to automate surveys, where practical, and continue to stress the use of proper frisking techniques by our staff.

Corrective steps which have been taken: Additional actions have been ,

taken which address the concerns of the inspector. Procedure i 62RP-RAD-017-0S has been revised to include additional clari fication. of ~

responsibilities for the proper use of personnel contamination monitors.

A departmental directive has been sent to all Health Physics technicians instructing them to re-read Procedure 62RP-RAD-017-0S and follow the procedure. '

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Georgia Powerkh ENCLOSURE 1 (Continued)

NRC NOTICE OF VIOLATION 86-30-01 AND GPC RESPONSE Carrective steos which will be taken to prevent recurrenre: No further actions are required.

DAte when full como11ance will be achieved: Full compliance has been achieved.

Suhpart 3:

Admission or denial of violation: The violation occurred.

Reason for violation: This violation occurred due to the failure of maintenance personnel to comply verbatim with procedure 52PM-MNT-005-0S.-

Personnel involved with the performance of .this procedure in August 1986-assumed that if the limit switches did not need adjustment then step 7.6.6.13, which states to adjust limit switches in' accordance with procedure 52GM-MNT-017-0S, was not applicable. While we believe the:

judgement made by the maintenance personnel was correct and satisfied the intent of the procedure, the action taken did not comply with procedure,.

52PM-MNT-005-0S, Rev. 3, exactly as written.

Corrective steps which have been Lahn: Revision.-5 of Procedure 52PM-MNT-005-0S was made effective in October '1986 'to clarify the requirements for performing limit switch adjustment.. Procedure 52PM-MNT-005-0S step 7.7.3.9 currently states, "If limit switches do not make and break as required, limit switch adjustments must be made per approved plant procedure."

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1' Georgia Power b ENCLOSURE.1 (Continued)

NRC NOTICE OF VIOLATION 86-30-01 AND GPC RESPONSE

~ Corrective st'gos which will be taken to prevent recurrence:

No further.

actions are required.

Date when full co_mpliance ~ wjl1 be achieved: Full compliance has been achieved.

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e '1 Georgia PowerkL ENCLOSURE 2 I

PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 NRC NOTICE OF VIOLATION 86-30-02 AND GPC RESPONSE NRC NOTICE OF VIOLATION 86-30-02

" Unit 1 Technical Specifications 3.7.D.1 and '4.7.D.1 and Unit 2 Technical Specifications 3.6.3 and 4.6.3.3 require that primary _ containment  ;

. isolation valves listed be operable, and that the isolation times shall be demonstrated to be within the required limits. i Unit 2 Technical Specification 4.0.5 require. that inservice testing of.

ASME Code Class 1, 2, and 3 valves shall be performed in accordance with j Section XI of the ASME Boiler and Pressure Vessel Code except 'where l specific written relief has been granted by the' Commission pursuant to 10 )

CFR 50, Section 50.55a(g)(6)(i). ASME Section XI defines stroke time 'as the time interval from initiation of the actuating signal to the end of the actuating cycle. The E. I. Hatch Pump and Valve Test Plan also defines full-stroke time as that time interval from initiation of the actuating signal to the end of the actuating cycle.

Contrary to the above, the licensee does not stroke time 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 the initiation of the actuating signal to the end of the actuating cycle. "

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

i Response to violation:

1 The admission of the violation and the reason for the violation are j discussed in our letter of December 31,1986. The following discussion is provided as an update of our corrective actionsigiven in that letter.

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Georgia Powerkn ENCLOSURE 2 (Continued)

NRC NOTICE OF VIOLATION 86-30-02 AND GPC RESPONSE Corrective steps which have been taken: Since GPC has adopted the NRC interpretation of switch-to-light stroke time testing for power operated valves, a formal interpretation of the ASME Code concerning the meaning of " actuating signal" will not be requested. Appropriate personnel have been notified of the new interpretation of the Code requirement for full stroke time testing. Preliminary engineering analysis of existing valve stroke times was completed on March 30, 1987. The preliminary analysis indicated that additional testing would be required in order to develop appropriate acceptance criteria for the new stroke times on some valves.

A Test or Experiment Request (TER 87-1) has been written to gather necessary data on the switch-to-light valve stroke times.

Corrective steps which will be taken to orevent recurrence: The ISI/IST Program will be revised to meet the requirement for full stroke time testing as specified in paragraph INV-3413 of the 1980 Edition of ,

the ASME Code,Section XI, with Addenda through Hinter 1981 in that power I operated valve stroke time testing will be performed switch-to-light rather than light-to-light. ISI/IST Program changes will be promulgated as a revision to the program document that was submitted by our letter of June 25, 1985. This revision is scheduled to be submitted by July 31, 1987. GPC will continue to review existing requirements for stroke time testing. Emphasis will be on the technical basis for the present established parameters. Performance of the TER began during the present a Unit i refueling outage with completion expected prior to the completion I of the next quarterly Section XI valve stroke time tests after the ou te.g e. The TER will be completed during the winter 1988 refueling i outage for Unit 2. Valve stroke times specified in Hatch Units 1 and 2 Technical Specifications and -the Pump and Valve Test Plan will be revised, where necessary, based on the TER after completion of the final analysis in order to consolidate and simplify testing requirements. l Approximately 24 procedures are expected to be revised to incorporate the revised stroke time testing methodology through the Procedures Upgrade Program. These procedures will be revised prior to their next scheduled 4

1 performance following TER completion for each unit.  !

Dale when full comoliance will be achieved: Full compliance will be achieved upon completion of the TER for each unit. i i

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