ML20234B631
| ML20234B631 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 09/11/1987 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| SL-3154, NUDOCS 8709210016 | |
| Download: ML20234B631 (6) | |
Text
Georgia Fbwer Company 333 Piedmont Avenue At!anta, Georgia 30308 Telephone 404 526-6526 Mailing Address:
Post Of fice 804 4545 Atlanta. Georgta 30302 b
Georgia Power L T. Gucwa Ife ^ # " 6 M C M lU'"
Manager Nuclear Safety and Licensina SL-3154 1653C X7GJ17-H120 September 11, 1987 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D.C.
20555 PLANT HATCH - UNITS 1 NRC DOCKETS 50-321 OPERATING LICENSES DPR-57 RESPONSE TO INSPECTION REPORT 87-19 Gentlemen:
In response to your letter of August 18, 1987, and in accordance with the provisions of 10 CFR Section 2.201, Georgia Power Company (GPC) is providing the enclosed response to the Notice of Violation associated with inspections conducted at Plant Hatch during the period of July 4-31, 1987.
The Notice of Violation concerns a failure to provide adequate procedures for the repair of the Local Power Range Monitoring (LPRM) system.
A transcription of the NRC Notice of Violation is provided as.
GPC's response is provided as Enclosure 2.
Should you have any questions in this regard, please contact this l
office at any time.
Sincerely, dr&
L. T. Gucwa LGB/lc
Enclosures:
- 1. NRC Notice of Violation
- 2. Georgia Power Company Response c:
(see next page) l
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U. S. Nuclear Regulatory Commission September 11, 1987 Page Two c:
Georgia Power Comoany Mr. J. P. O'Reilly, Sr. Vice President - Nuclear Operations Mr. J. T. Beckham, Jr., Vice President - Plant Hatch G0-NORMS U. S. Nuclear Regulatory Commission. Hashington. D. C.
Mr. L. P. Crocker, Licensing Project Manager - Hatch U. S. Nuclear Regulatory Commission. Region II Dr. J. N. Grace, Regional Administrator Mr. P. Holmes-Ray, Senior Resident Inspector - Hatch 1653C I
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Georgia Power A -
l ENCLOSURE 1
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PLANT HATCH - UNIT 1 NRC 00CKETS 50-321 OPERATING LICENSES DPR-57 NRC NOTICE OF VIOLATION 87-19
.l NRC NOTICE OF VIOLATION 87-19-01 Technical Specification 6.8.1.a requires the licensee to establish, i
implement and maintain written procedures covering ' the applicable activities in Appendix. A of Regulatory Guide 1.33, Revision 2,
l February 1978.
Appendix A of Regulatory Guide 1.33, paragraph 9, i
recommends establishment of procedures 'for performing repair of the incore flux monitoring system.
I i
Contrary to the above; The licensee failed to provide adequate procedures for the repair f
of the Local Power Range Monitoring (LPRM) system.
The procedure
'l step that detailed the connection of the cable (s) to the detector (s) called for.the verification and hookup of each detector cable in sequence for A, 8, C, and D, detector in a given string.
The data package contained a single verification for each string i
vs. each individual connection.
This difference led to ten LPRM cables improperly connected.
This is a Severity Level IV violation (Supplement I) i l
1653C El-1 9/11/87 l
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' Georgia Power h i
ENCLOSURE 2 PLANT HATCH - UNIT 1 NRC 00CKETS 50-321 OPERATING LICENSES DPR-57 RESPONSE TO NRC NOTICE OF VIOLATION j
RESPONSE TO VIOLATION 50-321/87-19-01 Mmission or denial of violation:
The violation occurred as cited in the Notice of Violation.
Georgia Power Company-(GPC) would like to note that evaluation of i
the process computer edits revealed that adequate thermal limit margins-existed at all time 3 when the reactor was in operation.
Furthermore, no impact on the Average Power Range Monitor (APRM) and Rod Block Monitor (RBM) operability was experienced as a result of this incident.
Reason for the violation:
The violation occurred due to the following procedural deficiencies:
1.
Procedure 52GM-C51-001-IS (LPRM Removal and Installation)-
was ambiguous with regard to the sequence of steps required for ' proper Local Power Range Monitor (LPRM) signal cables re-connection and their corresponding documentation in the data package.
This procedural ambiguity resulted in the improper re-connection of ten (10) LPRM signal cables by the Instrumentation and Control (I&C) technicians.
2.
Procedure 52GM-C51-001-IS was deficient in the re-connection verification process in that the data package sign-off required more than one action to be performed but provided for only one independent verification sign-off.
1653C E2-1 9/11/87 SL-3154 700776
r GeorgiaPower A ENCLOSURE 2 (Continued)
RESPONSE TO NRC NOTICE OF VIOLATION' It should be noted that the procedure had not yet been' through 'the full Procedure Upgrade Program (PUP) process at the time of this event.
Corrective steos which have been taken and the results achieved:
f As a. result of this event, the following corrective actions were
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implemented:
j 1.
Immediate corrective actions were taken to correct the LPRM wiring problem.
Maintenance Work Order (MHO) 1-87-5195 was initiated on 6/28/87 and was closed on 7/10/87.
2.
Procedures 52GM-C51-001-1S (for Unit 1) and 52GM-C51-001-2S (LPRM Removal and Installation) (for Unit 2) have been i
revised with an effective date of 7/30/87.
The revisions include:
a.
Clari fying the sequence of steps required for LPRM signal cable re-connections, b.
Requiring the completion of each step to be documented as a separate item rather than lumping multiple actions into one sign-off.
c.
Requiring independent verification of proper LPRM signal cable re-connection.
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- Georgia Power n ENCLOSURE 2 (Continued)
RESPONSE TO NRC NOTICE OF VIOLATION Corrective steos which will be taken to avoid further v'.olations:
Immediate corrective actions were taken, as described above, which should preclude recurrence of the cited events.
The procedures involved in the event (52GM-C51-001-1S and 25) have been revised to l
address the cited deficiency but have not yet been through the full PUP upgrade _ process.
These procedures are currently in the upgrade process and will later be consolidated into a plant wide procedure (52GM-C51-001-0S).
i The long term corrective action to detect, correct, and prevent procedure inadequacies is the Procedure Upgrade Program (PUP) which includes the procedure validation process.
The PUP is also a long term program to ensure that plant procedures are technically adequate and incorporate all license conditions. Details of the PUP have been presented to NRC - NRR and NRC - Region II personnel.
The procedure revision / review / development process is documented in plant procedure 10AC-MGR-003-0S (Preparation and Control of Procedures).
The validation process required by the PUP is contained in this procedure and this process will be continued.
The GPC response to Inspection Report 87-12 also describes the PUP validation process.
Date when full compliance will be achieved:
As previously stated, the mis-connected LPRM signal cables were properly re-connected on 6/28/87.
Full compliance was achieved on 7/30/87 when the revised procedure 52GM-C51-001-1S became effective.
1653C E2-3 9/11/87 SL-3154 4
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