ML20245D492

Notice of Violation from Insp on 890227-0317.Violation Noted:Procedure Did Not Provide for Incorporation of Vendor Recommendations in Maint Procedures for 4,160-volt Ac metal- Clad Switchgear

ML20245D492
Person / Time
Site:	Hatch
Issue date:	06/15/1989
From:	Gibson A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20245D457	List: ML20245D454 ML20245D492 ML20245D531
References
50-321-89-02, 50-321-89-2, 50-366-89-02, 50-366-89-2, NUDOCS 8906270132
Download: ML20245D492 (7)

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ENCLOSURE 1 NOTICE OF VIOLATION Georgia. Power Company Docket Nos. 50-321 and 50-366 Hatch License Nos. OPR-57 and NPF-5 During the Nuclear Regulatory Commission (NRC) inspection conducted on February 27 - March 17,1989, violations of NRC requirements were identified.

In accordance with the " General Statement. of Policy und procedure for NRC .

Enforcement Actions," 10 CFR Part 2, Appendix C (1989), the violations are listed below:

A. 10 CFR Part 50, Appendix B, Criterion V, states that activities affecting quality shall be prescribed by documented procedures of a type appropriate to the circumstances.

In. response to NRC Generic Letter 83-28, licensee letters dated August 21, 1986, and July 1, 1987, state that, in accordance with HNP procedure DI-ADM-05-1085, Rev. 2, the procedure upgrade program includes a require-ment to ensure that applicable vendor recommendations and manuals are included in all procedures.

Contrary to the above, on March 17, 1989, procedure DI-ADM-05-1085 was not appropriate to the circumstances in that it did not provide for incorpora-tion of vendor recommendations in maintenance procedures or alternately a documented evaluation of why vendor recommendations are not appropriate.

This inadequate administrative procedure resulted in the preventive maintenance procedure (52PM-R22-001-05) for the 4160 Volt AC Metal-Clad Switchgear not incorporating vendor maintenance recommendations as follows:

Vendor recommendations specify that: The switchgear installation should be given a thorough overall maintenance check at least annually. The following items require attention:

1. Buses and Connections

2. Main Disconnecting Contacts and Supports Procedure 52PM-R22-001-05 specifies a five year " recommended" maintenance interval with an allowable 251, grace period. The buses, connectors, and main disconnecting contacts are not included in the procedures.

This is a Severity level IV violation (Supplement I).

B. 10 CFR Part 50, Appendix B, Criterion XVI, states in part, that measures shall be established to assure that conditions a.dverse to quality, such as l deviations and nonconformances, are promptly identified and corrected. In l the case of significant conditions adverse to qualify, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.

l- 89G6270132 DR 890615 ADOCK 05C00321 I PDC

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2 Docket Nos. 50-321 and 50-366 l Hatch License Nos. OPR-57 and NPF-5 'l i

Licensee Technical Specification 6.11 requires that radiation control.

procedures be followed. Licensee procedure 60AC-HPX-006-05, Revision 3,- 1 Respirator Protection Program, references ANSI 288.2-1969, Practices for Respiratory Protection, as a developmental and implementing reference. i

ANSI 288.2 - 1969 states in section 5.3 that air-line couplings for 4 air-line supplied respirators shall be incompatible with outlets for other f

gas systems to prevent inadvertent servicing of air line respirators with nonrespirable gases or oxygen.

NRC Information Notice (IN) 87-56 provides details of inadequate bolting  ;

on BWR Hydraulic Control Units (HCUs). Licensee internal correspondence, l LOG: LR-REG-029-1287 states that there are no actions required as a  ;

result of this IN due to pr:vious plant actions in response to NRC Violation 321/86-20-02 (Failure to Use Washer Per Design Drawing) and i Unresolved Item 321/86-20-01 (Seismic Adequacy Question). Correspondence l LOG: LR-REG-029-1287 further states that:

During the construction of both Units 1 and 2 the torque value for the HCU hold-down t,olts was not specified.

The torque value information was subsequently obtained from GE (letter G-GPC-6-266 of July 22,1986).

Maintenance work orders were issued and completed to torque the bottom hold-down bolts to 45-50 foot pounds for all Unit I and Unit 2 HCUs. .

GE correspondence G-GPC-6-266 specifies a torque value of 50 foot pounds for the 0.50 inch bottom bolts and 15 foot pounds for the 0.375 inch top cap screws and states, ". . . . subject to the conditions that no previous upset or faulted events have occurred at the Hatch 1 and 2 site and that the six extreme bolts in the eleven bolt hold-down bolt pattern are in place and are at least snug tight, the installed HCUs will remain operable through at least one future faulted event." The six extreme bolts are the ,

four bottom bolts and the two top bolts.  !

Contrary to the above, adequate corrective actions were not taken to assure that deviations and non-conformances are promptly identified and ]

corrected to preclude repetition as evidenced by the following: j The licensee procedures require unique fittings to be utilized on plant breathing air system (Service Air System). The licensee lj recognized and documented the need to utilize unique fittings for 4 breathing air in a study made in 1981 (Reference is made to Request for Engineering Assistance HT-0718). Deficiency Cards 2-87-659 issued October 6, 1987, and 2-88-1452 issued March 16, 1988, reported that other system outlets had the same fittings as Service Air System outlets. On March 3, 1989, NRC observed that many of the licensee's Instrument Air System outlets had the same fittings as Service Air l System outlets.

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.t Georgia Pow 2r Company 3 Docket Nos. 50-321 and 50-366

' Hatch License Nos. OPR-57 and NPF-5 v- No corrective action regarding torque verification of top HCU mounting bolts was ' initiated prior to this inspection. Maintenance work orders 1-89-01077 and 2-89-00724 were completed during this inspection and found excessively loose bolts on 18 Unit 2 HCUs and 5 Unit 1 HCUs.

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

C. Technical specification 6.11 states in part that procedures for personnel radiation protection shall be prepared consistent with the requirements of 10-CFR Part; 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

Administrative Control Procedure 60AC-HPX-006-05, Revision 3, Respiratory Protection Program, requires that respirable air supplied by. air compres-sors and air cylinders meet the minimum requirements of Grade D air as prescribed by the Compressed Gas Association and be sampled quarterly.

Contrary to the above, during the last calendar quarter of 1988, the breathing, air system used to fill self contained breathing apparatus (SCBA) was not sampled for breathing air quality as required.

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

Pursuant to the provisions of 10 CFR 2.201, Georgia Power Company is hereby b ' required to submit a written statement or explanation to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector, Hatch, within 30 days of the date of the letter transmitting this Notice. This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) admission or denial of the violation,.(2) the reason for the violation if admitted, (3) the'correctivo steps which.have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time. If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.

FOR THE NUCLEAR REGULATORY COMMISSION original signed by Albert F. Gibson Albert F. Gibson, Director Division of Reactor Safety Dated c Atlanta, Georgia 7

this I (day of June 1989 I

ENCLOSURE 2 l EXECUTIVE

SUMMARY

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Background

The Nuclear Regulatory Commission considers effective maintenance of equipment and components a major aspect of ensuring safe nuclear plant operat. ion and has made this ares one of the NRC's highest priorities. In this regard, the Commission issued a Policy Statement dated March 23, 1988, that states, "it is the objective of the Commission that all components, systems, and structures of nuclear power plants be maintained so that plant equipment will perform its intended function when reouired. To accomplish this objective, each licensee should develop and implement a maintenance program which provides fo- tne periodic evaluation, and prompt repair of plant components, systems, and structures to ensure their availability."

To ensure effective implementation of the Commission's maintenance policy, the NRC staff is undertaking a major program to inspect and evaluate the effectiveness -f licensee mai ntenance activities. As part of this inspection activity, the current inspection was performed in accordance with guidance provided in NRC Temporary Instruction 2515/97, Maintenance Inspection Guidance, dated November 3, 1988. The temporary instruction includes a " Maintenance Inspection Tree" that identifies the major elements associated with effective maintenance. The tree was designed to ensure that all factors related to maintenance are evaluated.

Conduct of Inspection The maintenance inspection at the Hatch Nuclear Station was initiated with a site meeting on January 24-26, 1989, where the inspection scope, including the maintenance inspection tree, was discussed. At that meeting, the licensee presented to the inspection team leader an overview of the site maintenance program. In addition, a comprehensive package of material, as requested by NRC letter dated January 10, 1989, was provided for inspection preparation.

The inspection was conducted by a team consisting of a team leader and six inspectors. Four of the inspectors were from RII and two were from NRR. The team spent two weeks, February 27-March 3 and March 13-17, 1989, on site conducting the inspection.

The inspection was performance based, directed toward evt.luation of equipment conditions; observation of in process maintenance activities; review of equipment histories and records; and evaluation of performance indicators, maintenance control procedures, and the overall maintenance program. Based on known industry problems, plant specific problems, and discussions with the Hatch krsident Inspectors, the team selected five systems and directed the inspection toward determining whether these systems were being properly maintained and assessing if the current maintenance system would ensure proper maintenance in the future. The systems selected were: Ell (RHR), 321 (Main Steam), N21 (Condensate and Feedwater), PS2 (Instrument Air), and E41 (HPCI).

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The team performed walkdown inspections of portions of the selected systems to determine the material conoition of the equipment. In addition, maintenance history records for the last two years were obtained and reviewed for any adverse trends. NPRDS data were also reviewed for the selected systems. In review of equipment history records, any questionable trends were examined in i detail to determine if equipment was being properly maintained. In the course of the inspection, the team also observed general housekeeping and equipment condition for a large part of the plant.

! Results After completion of the inspection, the maintenance program was evaluated using the NRC TI and inspection tree as a tool. See paragraph 2 of the Inspection Report for details of the rating scheme.

The inspection results are presented pictorially in Figure 1 as the completed inspection tree. As noted in Figure 1, overall, the Hatch program for establishing and implementing an effective maintenance program was rated " Good" both in program and implementation. For the three major areas: (1) Overall Plant Performance was rated " GOOD", (2) Management Support was rated

" SATISFACTORY" for prograr;; and implementation, (3) Maintenance implementation was rated "3ood" for program and implementation. These ratings were based on specific screngths and weaknesses identified in the report details. The following are the more significant strengths and weaknesses identified:

Strengths -

Overall, the training program for maintenance was very strong. The facilities and the use of actual components as training aids were outstanding.

In general, plant housekeeping was good.

The maintenance data base and equipment records (NPMIS) were very good. The data base appeared to be user friendly 1 and records were readily retrievable.

The overall maintenance staff was a strength. Staffing levels appeared to be adequate. Team work was evident.

Management was well qualified and enthusiastic.

The QC staff was well organized, qualified, and heavily involved in the maintenance process.

The licensee has a strong program for controlling the maintenance backlog. The backlog is low.

The licensee makes good use of performance indicators.

Overall, plant equipment condition was good.

A strong program (deficiency card system) for identifi-cation of deficiencies and intiation of action was in place and appeared to be working well.

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Interfaces between maintenance organization and other organizations were well established and appeared to be working well. Daily planning meetings were well organizej and appeared to be a strong point in the maintenance process.

Both clean and " hot" machine shops were indicative of good maintenance facilities.

Weaknesses -

Weaknesses were identified in the PM program for electrical equipment in that vendor recommended PMs were-not included in procedures and no doct.mented justification existed for excluding the recommendations - examples: 4160 volt switchgear, busbars and cable compartments not included in procedures and no requirement to check protection charac-teristics for molded-case circuit breakers.

Weaknesses were identified in . the root cause analysis program as follows: the procedure needs strengthening to provide more detail on how to perform root cause analysis, a motor failure on a HPCI valve did not receive a root cause analysis, excessive time was taken to determine cause of Feedwater Pump Seal leakage.

Responsibilities for Systems Engineers were not well defined.

Some procedural weaknesses were identified - examples: the maintenance program procedure and predictive maintenance vibration analysis procedure needs to include cross reference to ASME Section XI requirements for ASMB Section XI components; the maintenance program procedure needs to include additional detail relative to ensuring proper functional / operability test when changes are made to the MWO; and the procedure controlling the proceaure update program was inadequate to insure that vendor recommended maintenance is included in maintenance procedures.

Weaknesses in the program for personnel safety were )

identified - examples: failure to have unique fittings j for connecting breathing air to instrument air and procedure ' for maintenance of electrical equipment could  ;

be strengthened by adding some safety precautions. '

The level and clarity of detail on some MW0s was poor resulting in difficulty in determining details of work performed - examples: MW0s 2-88-4862, 2-88-1906 and 2-88-3177.

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't-iv Weaknesses were identified relative to corrective action -

examples: failure to properly torque upper mounting bolts on hydraulic control units (HCus) and failure to ensure that all fittings for connecting breathing air were unique fitt',gs.

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