ML20246F304
| ML20246F304 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 07/07/1989 |
| From: | Hairston W GEORGIA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-83-28, HL-637, IEIN-87-056, IEIN-87-56, NUDOCS 8907130210 | |
| Download: ML20246F304 (11) | |
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l HL-637 0736I July 7, 1989 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D.C.
20555 PLANT HATCH - UNITS 1, 2 NRC 00CKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 RESPONSE TO INSPECTION REPORT 89-02 Gentlemen:
In response to your letter of June 15, 1989, and in accordance with the provisions of 10 CFR 2.201, Georgia Power Company (GPC) is providing the enclosed response to the Notice of Violation associated with Inspection Report 89-02.
A copy of this response is being provided to NRC Region II for review.
In the enclosures, a transcription of the NRC violation precedes GPC's response.
Should you have any questions in this regard, please contact this office at any time.
Sincerely, bY->b. $
.W H. G. Hairston, III DLM/eb
Enclosures:
- 1. Violation 89-02-01 and GPC Response
- 2. Violation 89-02-02 and GPC Response
- 3. Violation 89-02-03 and GPC Response c:
(See next page.)
4Q 8907130210 690707
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PDR ADOCK 05000321 i
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PDC L __ -- __ __
U.S. Nuclear Regulatory Commission July 7, 1989 Page Two c: Georaia Power Comoany Mr. H. C. Nix, General Manager - Nuclear Plant Mr. J. D. Heidt, Manager Engineering and Licensing - Hatch GO-NORMS U.S. Nuclear Regulatory Commission. WashinatonmQL Mr. L. P. Crocker, Licensing Project Manager - Hatch U.S. Nuclear Reculatory Commission. Region II Mr. S. D. Ebneter, Regional Administrator Mr. J. E. Menning, Senior Resident Inspector - Hatch I
0736I
I ENCLOSURE 1 PLANT HATCH - UNITS 1 AND 2 NRC DOCKETS 50-321 AND 50-366 OPERATING LICENSES DPR-57 AND NPF-5 VIOLATION 89-02-01 AND GPC RESPONSE yJ01ATION 89-02-01 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
requirement 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 incorporation 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-OS) 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-R22-001-0S specifies a
five year
" recommended" maintenance interval with an allowable 257. grace period.
The buses, connectors, and main disconnecting contacts are not included in the procedures.
This is a Severity Level IV violation (Supplement I).
RESPONSE TO VIOLATION 89-02-01 Admission or denial of violation:
The violation occurred as described in the Notice of Violation.
0736I HL-637 El-1
l ENCLOSURE 1 (Continued) i VIOLATION 89-02-01 AND GPC RESPONSE R n Nn for the violation:
The violation was caused by an inadequate procedure.
Procedure 01-ADM-05-1085N, " Upgraded Procedure Development and Processing," was not clearly written regarding the requirement to incorporate vendor recommendations into upgraded plant procedures or document why recommendations were not included.
Consequently, Procedure Upgrade Program procedure writers did not always document justification for not incorporating vendor recommendations.
Corrective steos which have been taken and the results achieved:
As a result of this event, the following corrective actions were taken:
1.
Procedure DI-ADM-05-1085N was revised.
Revision 3,
effective 4/4/89, explicitly requires the procedure writer to ensure "the procedure is not at variance with the Vendor manual, unless documented on Attachment 1.", " Writer's Checklist,"
remains with the procedure package, therefore, it is reviewed along with the procedure and becomes part of the procedure's history package stored in Document Control.
2.
Five upgraded preventive maintenance procedures were chosen at random and reviewed to determine if unjustifiable differences between the procedures and the applicable vendor recommendations existed.
Although some differences were found, they were all technically sound.
The differences were documented in a memo from the Maintenance Engineering supervisor to the Maintenance Manager dated 4/18/89.
3.
Procedure 52PM-R22-001-OS.
"4160 Volt AC Switchgear and Associated Electrical Components Preventive Maintenance," was marked-up to address the vendor recommended checks of the buses and connections and the main disconnecting contacts and supports.
The revision has been approved and was made effective 06/30/89.
It should be noted the frequency of performance was not changed.
The vendor manual allows deviations from vendor recommendations based on plant specific experience.
Maintenance Engineering reviewed the frequency and determined, based on maintenance history, that once per five years is adecuate.
07361 HL-637 El-2
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ENCLOSURE 1 (Continued)
VIOLATION 89-02.01 AND GPC RESPONSE Corrective steos which will be taken to avoid further violations:
Additional upgraded preventive maintenance procedures will be reviewed such that a total of 10% of the applicable procedures will have been reviewed.. The review, which will be to determine if any differences between the procedures and vendor recommendations are technically sound, will be completed by 3/1/90.
Further corrective actions will be taken, if appropriate, based upon the results of. this-review.
The ' requirement to incorporate vendor recommendations into procedures or provide-justification for not doing :,o will be included in administrative control procedure 76AC-MGR-003-05, " Preparation and Control of Procedures." This will be done prior to the cancellation of procedure DI-ADM-05-1087N at the end of the Procedure Upgrade Program.
Date when full comoliance will be achieved:
Full compliance was achieved by 06/30/89 when the revision to procedure 52PM-R22-001-0S became effective.
07361 HL-637 El-3
ENCLOSURE 2 PLANT HATCH - UNITS 1 AND 2 NRC 00CKETS 50-321 AND 50-366 OPERATING LICENSES DPR-57 AND NPF-5 VIOLATION 89-02-02 AND GPC RESPONSE VIOLATION 89-02-02 10 CFR Part 50, Appendix B,
Criterion XVI, states in part, that measures shall be established to assure that conditions adverse to
- quality, such as deviattors and non-conformances, are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Licensee Technical Specification 6.11 requires that radiation control procedures be followed.
Licensee procedure 60AC-HPX-006-0S, Revision 3, Respirator Protection Program, references ANSI 288.2-1969, Practices for Respiratory Protection, as a
developmental and implementing reference.
ANSI 288.2 1969 states in section 5.3 that air-line couplings for air-line supplied respirators shall be incompatible with outlets for other 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, LOG: LR-REG-029-1287 states that there are no actions required as a result of this IN due to previous plant actions in response to NRC Violation 321/86-20-02 (Failure to Use Washer Per Design Drawing) and Unresolved Item 321/86-20-01 (Seismic Adequacy Question). Correspondence 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 bolts 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 1 and Unit 2 HCUs.
0736I HL-637 E2-1 1
ENCLOSURE 2 (Continued) l VIOLATION 89-02-02 AND GPC RESPONSE 1
I 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 re.nain 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:
The licensee procedures require fittings to be utilized on plant breathing air system (Service Air System).
The licensee recognized and documented the need to utilize unique fittings for breathing air l
in a study made in 1981 (Reference is made to Request for Engine 6 ring l
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
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Air System outlets had the same fittings as Service Air System outlets.
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).
1 RESPONSE TO VIOLATION 89-02-02 Admission or denial of violation:
The violations occurred as described in the Notice of Violation.
Reason for the violation:
The first event was caused by a failure to implement the recommendations generated in response to Request for Engineering Assistance HT-0718.
07361 HL-637 E2-2
ENCLOSURE 2 (Continued)
VIOLATION 89-02-02 AND GP_C_ RESPONSE The second event was caused by Engineering Support Department personnel error.
In. responding to NF.C item 86-20-01, Engineering personnel failed to recognize the need to verify the torque of the top mounting bolts in r
addition to the bottom bolts.
The immediate issue was the torque of the i
bottom bolts, consequently, it was not noted that GE letter G-GPC-6-266 also referred to the top mounting bolts.
The error was not discovered when the response to IN 87-56 was written.
Corrective steos which have been taken and the results_ achieved:
As a result of this event, the following corrective actions were taken:
1.
An administrative hold waF placed on the use of air line supplied respiratory protection eqaipment.
The administrative hold will remain in effect until unique fittings can be installed.
2.
Unique fittings with upstream check valves have been ordered.
3.
Maintenance Work Orders (MH0s) 1-89-2641 and 2-89-3409 have been issued to replace existing Unit 1
and Unit 2
- fittings, respectively, with unique fittings and check valves.
As a result of the second event, the torque of all Unit I and Unit 2 Hydraulic Control Unit top mounting bolts was checked and any loose bolts torqued to the required values.
This was completed on 3/7/89 under MW0s 1-89-1077 and 2-89-0724.
Carrective stens which will be taken to avoid further violations:
For the first event, unique fittings with check valves will be installed on all breathing air fittings.
All Unit 2 fittings in accessible areas will be replaced prior to the start of the next scheduled Unit 2 refueling outage (currently scheduled to begin approximately 9/06/89).
All Unit 2 fittings in inaccessible areas will be replaced prior to startup from that outage.
All Unit 1 fittings in accessible areas will be replaced prior to the start of the next scheduled Unit i refueling outage (approximately 3/90).
All Unit 1 fittings in inaccessible areas will be replaced prior to startup from that outage.
1 07361 HL-637 E2-3
ENCLOSURE 2 (Continued)
VIOLATIOM 89-02-02 AND GPC RESPONSE Air line respiratory protection equipment (e.g., supply boxes, manifolds) will be modified prior to the start of the next scheduled Unit 2 refueling outana 'o accept only the new, unique fittings.
Initial and requalific;.uon respiratory protection training programs will be revised prior to the start of the next scheduled Unit 2 refueling outage to include information concerning identification of proper breathing air connections.
For the second event, the violation, its consequences, and the lessons learned will be included in the Continuing Engineering Training program for the fourth quarter of 1989.
Date when full como11ance will be achieved:
For the first event, full compliance will be achieved prior to startup from the next scheduled Unit I refueling outage (approximately 6/90).
For the second event, full compliance was achieved on 3/7/89 when the top mounting bolts' torque was checked and all loose bolts were torqued to the required value.
07361 HL-637 E2-4
ENCLOSURE 3 PLANT HATCH - UNITS 1 AND 2 NRC DOCKETS 50-321 AND 50-366 OPERATING LICENSES DPR-57 AND NPF-5 VIOLATION 89-02-03 AND GPC RESPONSE VIOLATION 89-02-03 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 compressors 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).
RESPONSE TO VIOLATION 89-02-03 Admission or denial of violation:
The violation occurred as described in the Notice of Violation.
Reason for the violation:
The viclation was caused by an inadequate procedure.
Procedure DI-RAD-03-1087N, " Survey / Inspection Frequency and Work Scheduling," is used to track the performance of certain Health Physics / Chemistry Department routine activities, including respirable air sampling.
This procedure was not adequate because it was not specific regarding respirable air sampling.
It did not provide exact locations at which samples were required to be taken.
As a result, sampling at all locations was not performed in the fourth quarter of 1988, i.e.,
one sample location was overlooked.
07361 HL-637 E3-1
ENCLOSURE 3 (Continued)
VIOLATION 89-02-03 AND GPC RESPONSE Corrective steos which have been taken and the results achieved:
All required air samples were taken on 3/8/89.
This was completed prior to it being discovered that one sample had not been taken in the fourth quarter of 1988, thus, it was not necessary to obtain any samples following discovery of the violation.
Procedure DI-RAD-03-1087N was revised to
- indicate, with designated sign-off
- blocks, the exact respirable air sampling locations. The revision was effective on 3/16/89.
Corrective steos which will be taken to avoid further violations:
Procedure 62RP-RAD-003-0S, "Use and Care of Respirators," will be revised by 7/28/89 to include when, where, and by whom respirable air samples are to be taken.
This will further ensure samples are taken at all required locations at the proper frequency.
Date when full comoliance will be achieved:
Full compliance was achieved on 3/8/89 when all required air samples were taken.
0736I HL-637 E3-2
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