ML20236J789

Forwards Response to Transmitting Notice of Violation from Insp Repts 50-321/87-22 & 50-366/87-22 on 870831-0904.Violation Re Inadequate Spec for Pressure Switch Denied

ML20236J789
Person / Time
Site:	Hatch
Issue date:	10/30/1987
From:	Gucwa L GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
SL-3495C, NUDOCS 8711060280
Download: ML20236J789 (5)

Text

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3*j' Georgia Fbwer Company ;

i333 Piedmont Avenue a

. . Manta, Georgia 30308 i

Telephone 404 526-6526 L afiing Address: .-.

Fost Office Box 4545 -

Atlanta Georgia 30302 h

Georgia Power j L. T. Gucwa IN southan electrc system Manager Nuclear Safety  !

and Licensing j

i SL-3495c 1785C. q X7GJ17-H120 October'30, 1987 i

.i U.'S. Nuclear. Regulatory Commission .j ATTN: ' Document Control. Desk 1 Hashington, D. C. .

20555 l PLANT HATCH - UNITS 1, 2 NRC 00CKETS-50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 I RESPONSE TO INSPECTION REPORT 87-22

. Gentlemen:

In accordance with the provisions of 10 CFR 2.201, Georgia Power Company (GPC) is providing the enclosed response to your October 8,1987 letter, which transmitted the Notice of Violation associated with  ;

inspections conducted at Plant Hatch during the period of. August 31 -

September 4, 1987. The Notico of Violation concerns . inadequate  !

acceptance criteria for pressure switch 2E41-N752 calibration. A copy of 1 this response is being provided to NRC Region II for review. In the, "

enclosure, transcription of the NRC Violation precedes GPC's response.

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

Sincerely,

% s L_ /& i i

L. T. Gucwa 1 JCJ/lc

Enclosure:

NRC Notice of Violation 87-22-01 and GPC Response c: (see next page) g 8711060280 871030 PDR ADOCK 05000321 l Q PDR

$k Georgia Power AL.

U. S. Nuclear Regulatory Commission i October 30, 1987  !

Page Two i

l c: Georaia Powgr Comoany i Mr. J. P. O'Reilly, Sr. V ce President - Nuclear Operations  !

Mr. J. T. Beckham, Jr., Vice President - Plant Hatch (

GO-NORMS U. S. Nuclear Reaulatory Commission. Washinaton. D. C.

Mr. L. P. Crocker, Licensing Project Manager - Hatch  !

U. S. Nuclear Reculatory Commission. Region.II Dr. J. N. Grace, Regional Administrator Mr. P. Holmes-Ray, Senior Resident Inspector - Hatch i

1785C l

1 o r=7n 1

T l l Georgia PowerI i

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

NRC NOTICE OF VIOLATION 87-22-01 AND GPC RESPONSE I]LANSCRIPTION OF VIOLATION 87-22-01

'10 CFR 50, Appendix B, Criterion V as implemented by Georgia Power accepted QA program (FSAR Chapter 17.2) requires that activities j affecting quality shall be prescribed by documented instructions, )

procedures or drawings of a type approprf ate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings, which shall include appropriate quantitative or qualitative '

acceptance criteria for determining that important activities have been satisfactorily accomplished.

Contrary to the above, on September 2, 198i, it was found that the acceptance criteria was inadequately specified for pressure switch 2E41-N752 in Calibration Procedure 57CP-CAL-067-2S. The acceptance criteria for the low setpoint and the reset values overlap in that the low setpoint is listed as 6-8 psig and the high setpoint value (reset) is 7-9 psig.

This is a Severity Level V violation (Supplement I).

RESPONSE TO VIOLATION 87-22:01 Mmission or denial of the angged violatiqn:

Georgia Power Company respectfully denies the violation based upon the i following justifications:

(1) The instrument acceptance criteria for the High and Low 4 Setpoints listed in Attachment 3 of procedure 57CP-CAL-067-25, SQUARE-D PRESSURE SHITCH 9012 & 9013 CALIBRATION, allow the Instrumentation and Controls (I&C) Technician the proper latitude when performing the calibration on the switches.

Additionally, the particular models governed by the aforementioned procedure always have a minimum differential between high and low setpoint based on the range of the switch.

For the particular pressure switch, 2E41-N752, the minimum differential is 0.5 psig. Due to the physical characteristics of the Square-D Model 9012 and 9013 pressure switch, the pressure switch cannot trip and reset at the same value, and SL-3495 E-1 10/30/87 1785C

=m , _

P Georgia Power k A.

j' ENCLOSURE (Continued) llRC NOTICE OF VIOLATION 87-22-01 AND GPC RESPONSE therefore, an overlap condition cannot occur by aesign. The acceptance criteria also take into account the instrument accuracy.

(2) Steps 7.2, SWITCH CALIBRATION CHECK and 7.3, SWITCH SETPOINT CALIBRATION contained within the body of the procedure are written such that the high and low setpoint values will not overlap and the reset differential will be approximately 1.0 psig. The procedure follows the guidelines set forth in the High Pressure Coolant Injection (HPCI) Turbine technical manual which states (concerning 2E41-N752): "This switch is provided to activate an alarm in the event of low oil pressure. It is set for 5-7 psig, that is, alarm will sound when oil pressure dips below 5-7 psig (contact closed) and will continue until the pressure rebuilds beyond 6-8 psig l (contact open)." (NOTE: 2E41-N752 actual setpoints are conservatively set 1 psig higher).

(3) I&C technicians who calibrate 2E41-N752 fully understand the steps in the procedure and are knowledgeable of the terms "high setpoint and " low setpoint" and the proper usage of the acceptance criteria. Calibration data retrieved from the permanent records retention facility for 2E41-N752 for the periods of July 18, 1986 and September 3,1987 support this fact:

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(a) 7/18/87 calibration data:

As found low setpoint - 6.80 psig.  ;

As found high setpoint - 7.77 psig.

Differential - 0.97 psig. l 1

All values were left as found.

(b) 9/03/87 calibration data:

As found low setpoint - 7.4 psig.

As found high setpoint - 8.8 psig.

Dif ferential - 1.4 psig.

As left low setpoint - 7.0 psig.

As left high setpoint - 8.1 psig.

Differential - 1.1 psig.

SL-3495 E-2 10/30/87 1785C

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G,eorg.

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' ENCLOSURE (Continued) 1 NRC NOTICE OF VIOLATION 87-22-01'AND GPC RESPONSE- )

l' It should be noted that even though the pressure switch was

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within the . specified acceptance criteria : :(on j

September 3,1987), the instrument was calibrated .in the~.

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presence of the NRC inspector. The I&C technicians -!

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, experienced no difficulty - in . performing- the  ;.

aforementioned calibration procedure.  !

Additionally, paragraph 6 of the Inspection Report states, in part:

~"The only. setpoint is the. Low Setpoint which is .7.0 psig. The. reset function is' incorrectly identified as. the High Setpoint." GPC believes that the "High Setpoint" term' referenced in the calibration procedure is correct. The . terminology (e.g., high setpoint and ' low ~ ]

l setpoint) is taken both from the HPCI Turbine technical manual and the ' '

Square-D Model 9012 pressure switch name plate data.

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l SL-3495 E-3 10/30/87 1785C-l 1

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