ML20236J878
| ML20236J878 | |
| 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-3525C, NUDOCS 8711090011 | |
| Download: ML20236J878 (5) | |
Text
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'i
.. Georgia Power Company
-)
4 333 Piedmont Avenue t
Atlanta, Georgia 30308 i
- Telephone 404 526-6526
~
7'.. "g Address:
A Fost Office Box 4545 l
Aranta, Georgia 30302, L
j L
. Georgia Power.
j
' L T. Gucwa.
ftwnovthem electro system j
. Maaager Nuclear Safety j
and Licensing :
SL-3525c 1796C
-X7GJ17-H120 1l October 30, 1987 i
l i
l U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Hashington, D. C.
20555 J
PLANT HATCH - UNIT 2 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 RESPONSE TO INSPECTION REPORT 87-23 J
Gentlemen:
l l
In accordance with.the provisic,ns of 10 CFR 2.201, Georgia Power j
s Company (GPC) is 'providing the enclosed response to your October 7,19J7
- letter, which transmitted the Notice of Violation associated with inspections conducted at Plant Hatch during the period of August 29 -
. September 25, 1987.' The Notice of Violation concerns ta failure to revise l
a surveillance procedure.
A copy of this response.is being provided to NRC Region II for review.
In the enclosure, traliscription 'of.the NRC 3
Violation precedes GPC's response.
If you have any questions in this regard, please contact this office at any time.
Sincerely, W% rk (L l
L. T. Gucwa j
JCJ/lc
Enclosure:
NRC Notice of Violation 87-23-01 and GPC Response c:
(see next page) 00cn$50000ss V
. Georgia ?ow :r A l
U. S. Nuclear Regulatory Commission October 30, 1987 Page Two c: Georaia Power Comoany Mr. J. P. O'Reilly, Sr. Vice President - Nuclear Operations Mr. J. T. Beckham, Jr., Vice President - Plant Hatch GO-NORMS U. S. Nuclear Regulatory Commission. Washington. D. C.
Mr. L. P. Crocker, Licensing Project Manager - Hatch Q. S. Nuclear Reaulatory Commission. Reaion II Dr. J. N. Grace, Regional Administrator Mr. P. Holmes-Ray, Senior Resident Inspector - Hatch 1796C rwns
i p
Georgia Power 1 ENCLOSURE PLANT HATCH UNIT 2
.NRC DOCKET 50-366 OPERATING LICENSE NPF-5 i
NRC NOTICE OF VIDIATION 87-23-01 AND GPC RESPONSE l
' TRANSCRIPTION OF VIOLATION 87-23-01 l
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,
February 1978.
Appendix A of Regulatory Guide 1.33 recommends establishment of procedures for procedure review 'and approval.-
Licensee's procedure 40AC-REG-001-OS establishes requirements for the incorporation of Technical Specification changes into surveillance procedures.
Section 5.3.2 of this procedure requires that surveillance procedures be issued and effective on' or before the day 1
the revised Technical Specifications are implemented.
Contrary to the above, the licensee failed to promptly revise a surveillance procedure to reflect. the requirements of Amendment No. 71 to the Technical Specifications. Amendment No. 71 became effective. on i
February - 27, 1987.
Surveillance procedure 57SV-011-016-2S was not revised to accommodate Amendment No. 71 until September - 7, 1987.
During this time period, procedure 57SV-D11-016-0S did not provide for 4
testing of' the Main Con'rol. Room Environmental Control System pressurization logic to the relays at' the point of end of logic identity during weekly functional testing. of the main steam line radiation monitors, as required by Amendment No. 71.
This is a Severity Level V violation (Supplement I).
RESPONSE TO VIOLATION 87-23-01 Mmission or denial of the violatioil:
The events occurred as stated in NRC Notice of Violation 87-23-01.
Reason for the violation:
As reported in Licensee Event Report (LER) 2-87-11, the violation occurred due to maintenance supervisory personnel failing to fully comply with the existing Administrative Control Procedure (ACP) 40AC-REG-001-0S,
" TECHNICAL SPECIFICATIONS SURVEILLANCE PROGRAM".
i SL-3525 E-1 10/30/87
.1796C m
w 4
- Georgia Power h ENCLOSURE (Continued)
NRC NOTICE OF VIOLATION 87-23-01 AND GPC RESPONSE The ACP provides guidance on departmental responsibilities relating to l
document revisions (i.e.
procedures) resulting from Technical 1
Specification (T.S.) amendments.
Specifically, the procedure requires the responsible department to revise it's _ affected procedures. and 1
issue them on or.before the date a T.S. amendment becomes effective.'
l Maintenance Department supervision was informed of the requirement to review T.S.
Amendment No. 71 and revise any affected procedures.
Maintenance personnel reported to the Nuclear Safety and Compliance (NSC).' department on Februt /y" 6, 1937 that, with regards to necessary procedure revisions,
...Rev.
have been done...".
NSC interpreted "Rev."
to, mean " revision" and ' assumed that the required procedure revisions'.had been completed, therefore the tracking of the procedure revision was closed out.
In reality, the term "Rev. vas meant by maintenance supervision to indicate that the review of the T.S.
ameridment for. potential procedure revisions 'had been completed.
Maintenance supervision did identify procedure 57SV-D11-016-2S. as needing revision, ho.vever they failed to ensure that the revision was in place prior to February 27, 1987.
farrective.steos which have been taken and the results achieved:
i As noted in the Inspection Report, the Procedure Upgrade Program (PUP) l personnel discovered on September 2,
1987 that procedure 57SV-Dil-016-2S, "GE NUMAC MAIN STEAM LINE LOGARITHMIC RADIATION i
MONITOR FUNCTIONAL TEST", did not reflect the requirements of T.S.
Amendment No. 71.
The PUP personnel initiated a deficiency card reporting the event.
Temporary Change 87-1178 was initiated for procedure 57SV-011-016-2S on September 3,1987, to include Unit 2 T.S. Amendment No. 71 testing requirements.
The testing of the Main Control Room Environmental Control System (MCREC) pressurization logic to the relays at the point
)
of end of logic identity for the required weekly functional testing of the main steam line radiation monitors was satisfactorily performed on September 7, 1987 using the temporarily changed procedure.
SL-3525 E-2 10/30/87 1796C
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- 775
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1 E'
s iGeorgia Power n\\
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ENCLOSURE (Continued)
L NRC NOTIfE OF VIOLATION 8't-23-01 AND GPC RESPONSE o
' Licensee Event Report 2-87-11 was submitted.on October 2,.
1987 describing the event.
The involved Maintenance supervisory personnel were counselled regarding the event.
In addition, Nuclear Safety and j
Compliance personnel were instructed to veri fy the accuracy of' 1
responses received.
j i
The - administrative controls governing the review of T.S. amendments and their incorporation into plant procedures were reviewed and determined to be adequate.
Other surveillance procedures affected by Amendment No. 71 were reviewed to ensure that they had been revised properly with satisfactory results.
Corrective steos which will be taken to avoid further violations:
The-Temporary Change to Procedure 57SV-D11-016-2S will be incorporated into a permanent revision to ensure continued compliance with T.S.
1
. Amendment No. 71.
The procedure is scheduled to be validated by '
l November 16, 1987'and in place by December 16, 1987.
1 Rgte when full como11ance will be achieved:
Full' compliance was achieved on September 7, 1987 when the required T.S. surveillance test was satisfactorily performed.
'SL-3525 E-3 10/30/87 1796C
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