ML20237J694
| ML20237J694 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 08/19/1987 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| SL-2962, NUDOCS 8708260267 | |
| Download: ML20237J694 (7) | |
Text
. Georgia Power Company 333 Piedmont Avenue Atlanta, Georgia 30308 Telephone 404 526 0526 Mailing Address.
fbst Office Dox 4545 Atlanta. Georgia 30302 b
Georgia Power L T. oucws Manager Nuclear Safety and Licensing SL-2962 1569C X7GJ17-H120 August 19, 1987 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 PLANT HATCH - UNITS 1, 2 HRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 RESPONSE TO INSPECTION REPORT 87-14 Gentlemen:
In response to your letter of July 23, 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 June 29 -
July 2, 1987.
The Notice of Violation concerns a failure to have written procedures pursuant to Technical Specification requirements.
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 office at any time.
Sincerely, L. T. Gucwa p
LGB/lc
Enclosures:
- 1. NRC Notice of Violation
- 2. Georgia Power Company Response c:
(see next page) 8708260267 B{$$b21 PDR ADOCK PDR I l 0
1 4k Georgia Power n U. S. Nuclear Regulatory Commission August 19, 1987 Page Two l
l c:
Georaia Power Company Mr. J. P. O'Reilly, Sr. Vice President - Nuclear Operations Mr. J. T. Beckham, Jr., Vice President - Plant Hatch GO-NORMS O. S. Nuclear Regulatory Commission. Washinaton. D. C.
Mr. L. P. Crocker, Licensing Project Manager - Hatch D. S. Nuclear Reaulatory Commission. Region II Dr. J. N. Grace, Regional Administrator Mr. P. Holmes-Ray, Senior Resident Inspector - Hatch 1569C
l-Georgia Power A ENCLOSURE 1-PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES.DPR-57, NPF-5 NRC NOTICE OF VIOLATION 87-14
-NRC NOTICE OF VIOLATION 87-14-01' Units 1
and 2 Technical. Specifications 6.8.1 require written procedures for activities referenced in Appendix A. of Regulatory Guide 1.33, Revision 2, Februa.y 1978.
Paragraph 8.b of Appendix A requires. that. specific procedures for each surveillance test listed in the Technical Specifications be written.
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. Contrary to the above, procedures were not written for the i
l surveillance: test. required by Unit
- 1. Technical Specifications.
H 4.6.L.2.(3)(a).and (b) and Unit 2
Technical Specifications
'4.7.4.(3)(a) and (b) to inspect. mechanical snubbers. which
-experienced a severe dynamic event to assure the snubbers have.
freedom of r.ovement and are not frozen up.
This is a Severity Level V violation (Supplement I) 1 i
k 1569C El-1 8/19/87 SL-2962 I
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L<
l Georgia Poiver A 1
ENCLOSURE 2 PLANT' HATCH:- UNITS 1, 2 NRC 00CKETS 50-321, 50-366 0PERATING LICENSES DPR-57, NPF-5 RESPONSE TO NRC NOTICE OF VIOLATION I
RESPONSE TO VIOLATION 50-321. 50-366/87-14-01 Admission or denial of violation:
The violation occurred as cited in the Notice of Violation.
While' this' event did occur, it should be noted that this issue wa's previously identified by the Plant Hatch Quality Assurance (QA)
Department during a routine audit earlier in 1987.
Specifically, this' item was identified in-QA audit 87-SA-1 dated March 19, 1987.
The finding, as stated in the audit report, is presented below.
Where brackets occur, this is explanatory material that is not contained in the audit report.
"Reaui rement:
Tech. Specs., section 6.8.1.c - Hritten procedures shall be established, implemented, and maintained covering the surveillance and test activities of safety related equipment.
Findina:
The following is a list of Tech. Spec. items that were not found in plant procedures or were unclear Tech.
Spec.
I requirements.
These examples will be tracked by the existing AFR
[ Audit Finding Report]
84-SURV-3/175, Category I.
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' ENCLOSURE 2 (Continued)
RESPONSE TO NRC NOTICE OF VIOLATION Unit I Tech. Soec.
Comments (3) 4.6.L Paragraph 2.b - Can not find a
procedure reference to snubber inspection after a
dynamic event.
Unit 2 (10) 4.7.4.b.
Cannot verify requirements b.3.a.,b, i, or ii are' in a procedure.
[b.3.b refers to inspections after dynamic events]."
Reason for the violation:
The violation occurred when procedure writers and reviewers failed to
-incorporate the technical inspection requirements. of-Technical Specifications sections 4.6.L.2.(3)(a) and (b) into plant procedure 52IT-MME-002-1S (Inspection and Testing Pacific Scientific Mechanical
' Snubbers ~ for Unit-1) and 4.7.4.(3)(a) and (b) into plant procedure 52IT-MME-002-2S (Inspection and Testing Pacific Scientific Mechanical Snubbers for Unit 2).
i 1569C E2-2 8/19/87 SL-2962
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Georgia Power 1 ENCLOSURE 2 (Continued)
RESPONSE TO NRC NOTICE OF VIOLATIM At the conclusion of QA audit 87-SA-1, the finding summarized above, along with other related issues, was reviewed by knowledgeable site personnel in order to determine the actions necessary to achieve full compliance with the Unit One and Unit Two Technical Specifications.
This review revealed that several procedural changes were needed and the changes were subsequently incorporated into mechanical and hydraulic snubber inspection and test procedures.
However, when plant personnel were reviewing the QA findings and determining what modifications to the procedures were required, they concluded that the exact words in the Technical Specifications (dealing with the inspection of snubbers after a dynamic event) did not need to be included verbatim into the procedures as one of the required changes.
Plant personnel believed that procedures 52IT-MME-002-lS and 52IT-MME-002-2S (for Unit 1
and Unit 2,
respectively) met the intent of the Technical Specifications surveillance requirement to inspect snubbers after a dynamic event.
This conclusion was based not only on the words in the procedures but also on the procedural implementation in the plant.
When, during the course of snubber inspections, a snubber fails visual inspection and is subsequently found to be bound up or otherwise inoperable, the surrounding snubbers on the system are also inspected to verify that the problem is localized.
In other words, the scope of the snubber inspection is increased.
This increase in the numbers of snubbers inspected aids in the determination that a dynamic event has not occurred.
Since this is the normal practice during snubber inspections, (and this method of inspection satisfies the intent of verifying the operability of snubbers following a dynamic event),
plant personnel did not believe it was necessary for the procedure to specifically state this inspection requirement.
Consequently, the procedures were not revised to address verbatim the cited Technical Specification section (even though the intent was already being performed).
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Georgia Power A ENCLOSURE 2 (Continued)
RESPONSE TO NRC NOTICE OF VIOLATION Conective steos which have been taken and the results achieved:
As a result of this Notice of Violation, procedures 52IT-MME-002-OlS and 52IT-MME-002-2S have been deleted and replaced with new procedures.
The new procedures are 52SV-SUV-004-1S (Inspection and Testing Pacific Scientific Hechanical Snubbers for Unit 1) and 52SV-SUV-004-2S (Inspection and -Testing Pacific Scientific Mechanical Snubbers for Unit 2).
The revisions will specifically require that mechanical snubbers, which have experienced a severe dynamic event, be inspected to assure that the snubbers are operable.
The procedure revisions were made effective on 8/13/87.
Plant personnel have no conclusive evidence that any dynamic events have occurred. since the last refueling outage.
Since no severe dynamic events are believed to have been experienced, it is concluded that the currently installed snubbers are still capable of performing their intended safety-functions.
Additionally, as previously mentioned, the scope of the inspections performed at the scheduled refueling outages allows for the detection and correction of any dynamic event induced inoperabilities with any snubber in the surveillance program.
Corrective stens which will be taken to avoid further violations:
Immediate corrective actions were taken, as described above, which should preclude recurrence of the cited events.
No further corrective actions are anticipated at this time.
Date when full comoliance will be achieved:
Full compliance was achieved on 8/13/87 when the procedure revisions were made effective.
1569C E2-4 8/19/87 SL-2962 7007F5