ML20247G463

Responds to NRC Re Violations Noted in Insp Repts 50-321/89-08 & 50-366/89-08.Corrective Actions:Procedure Revised to Include Periodic Analysis of Fuel Oil Parameters & Change Sampling Methodology

ML20247G463
Person / Time
Site:	Hatch
Issue date:	09/14/1989
From:	Hairston W GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HL-725, NUDOCS 8909190074
Download: ML20247G463 (6)

Text

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i !. * , George Power Company

, 333 Wedmont Avenett.

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Attanta. Gecga 30308 .

Telephone 404 5243195 -

Mailtng Addren

. 40 inverness Center Parkway Post Office Box 1295 Birmingham, Alabania 35201 Telephone 205 808 5581 rw wurnwn mrtre system W. G. Hairston, til Senior Vice President Nuclear Operations

.HL-725 0289V September 14, 1989

-U..S. Nuc1 ear' Regulatory Commission

' ATTN: Document Control Desk Hashington, D.C. 20555 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 RESPONSE TO INSPECTION REPORT 89 Gentlemen:

In response to your letter of August 18, 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 and concern associated with Inspection Report 89-08. 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, N. $

H. G. Hairston, III DLM/dm

Enclosures:

1. Violation 89-08-01 and GPC Response

'2. NRC Concern and GPC Response c: (See next page.)

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Georgia Power d U. S. Nuclear Regulatory Commission September 14, 1989 Page Two c: Georaia Power Comoany Mr. H. C. Nix, General Manager - Hatch Mr. J. D. Heidt, Mar.ager Nuclear Engineering and Licensing GO-NORMS U. S. Nuclear Regulatory Commission. Washington. D. C.

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

U. S. Nuclear Regulaforv Commission. Region II j Mr. S. D. Ebneter, Regional Administrator 1 Mr. J. E. Menning, Senior Resident Inspector - Hatch l l

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I 0289V

C ENCLOSURE 1 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 VIOLATION 89-08-01 AND GPC RESPONSE VIOLATION 89-08-01 10.CFR 50, Appendix B,Section XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.

A. Sampling and analysis requirements for the Emergency Diesel Generator fuel oil storage tanks are specified in the Technical Specifications (Unit 1, section 4.9.A.2.d and Unit 2, section 4.8.1.1.2.c). The Technical Specifications for both units state that operability of the Emergency Diesel Generators shall be maintained "At least once per 92 days by verifying that a sample of Emergency Diesel Generator fuel oil from the fuel oil storage tank, obtained in accordance with ASTM-D270-65, is within the acceptable limits specified in Table 1 of ASTM D975-74 when checked for viscosity, water and sediment." These fuel sampling discrepancies were identified during a quality assurance audit conducted during November 1988, 88-MNT-2.

Contrary to the above, sampling methods did not comply with methods described in ASTM D270-65, Sampling Petroleum and Petroleum Products, as required by Technical Specifications, in that the sample methodology did not assure representative samples of the Emergency Diesel Generator fuel oil storage tanks.

B. Section 9.5.4.5 of the Unit 2 Final Safety Analysis Report states that " Samples of the fuel oil from all tanks are analyzed periodically to ensure that the fuel oil quality requirements of the Emergency Diesel Generator manufacturer are met." Fuel oil specifications as stated in the vendor manual, Fairbanks-Morse, include requirements for viscosity, carbon residue, sulphur, flash point, bottom sediment, water, ash, pour point, distillation, potential gum, cetane number, high heat value and A. P. I. gravity. Procedure Number 62CH-SAM-003-05, Revision 2, and the Technical Specifications only address requirements for viscosity, water and sediment. These discrepancies were identified during a quality assurance audit conducted during November 1988, 88-MNT-2.

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e ENCLOSURE 1 (Continued)

VIOLATION 89-08-01 AND GPC RESPONSE Contrary to the above, the discrepancies between the procedure.

Technical Specifications and Final Safety- Analysis Report have not been resolved and the corrective actions had not been finalized or implemented by the end of this inspection.

RESPONSE TO VIOLATION 89-08-01 ,

Admission or denial of violation:

The violations occurred as described in the Notice of Violation.  !

Eeason for the violation: j The first event was caused by a misinterpretation of the sampling I methodology requirements of ASTM D270-65, " Standard Method of l Sampling Petroleum and Petroleum Products." Section 3.18 of ASTM j 0270-65 defines a continuous sample as a sample "obtained from a l pipeline in sud manner as to give a representative average of a j moving . stream." Section 7.1 states that directions for sampling  :

cannot be made evolicit enough to cover all cases and good judgment l must be used f- asure representative samples. It was felt that the sampling methodology of procedure 62CH-SAM-003-0S, " Diesel Fuel Oil Sampling," was in agreement with the requirements of ASTM D270-65 as  !

given in Sections 3.18 and 7.1 and, consequently, did ensure l representative samples of diesel fuel oil. This was a  !

misinterpretation of the requirements of ASTM D270-65. j The second event was the result of an oversight during development of the sampling procedure. The procedure was written to comply with the Unit 1 and Unit 2 Technical Specifications' requirements to analyze the diesel fuel oil for viscosity, water and sediment which are the j most critical parameters relative to the capability of a diesel  !

engine to start and run continuously. The additional requirement to l analyze the diesel fuel oil to ensure it met the manufacturer's requirements as stated in the Unit 2 Final Safety Analysis Report (FSAR) was overlooked. This oversight apparently was caused by the 1 original procedure's writer and reviewers concentrating only on the )

analysis requirements of the Technical Specifications.

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ENCLOSURE 1 (Continued)

VIOLATION 89-08-01 AND GPC RESPONSE The discrepancies were not resolved in a more timely manner following QA Audit 88-MNT-2 for ' the same reason. The analysis required by the procedure and its acceptance criteria were confirmed to comply with the Unit 1 and Unit 2 Technical Specifications when the discrepancies were ~ first noted during the quality assurance audit. Because the procedure was in. compliance with the Technical Specifications -

resolution of this item was not given a higher priority.

CorIn:tive stens which have been taken and the results achieved:

As a result ' of these events, procedure 62CH-SAM-003-0S' has been revised to change the sampling methodology to comply with ASTM

'0270-65 and to include periodic - analysis of all fuel oil parameters required by the diesel generator's manufacturer as given in service information letters dated June 30, 1989.

Also, a management bulletin. has been issued to all' personnel emphasizing the importance of timely incorporation of FSAR requirements .into procedure revisions when~ discrepancies are identi fied.

Corrective stres which will be taken to avoid further violations:

No further corrective actions are required to prevent recurrence.

Date when full compliance will be achieved:

Full compliance was achieved on 9/11/89, when the revision to procedure 62CH-SAM-003-0S was made effective.

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ENCLOSURE 2 PLANT HATCH - UNITS 1 AND 2 NRC DOCKETS 50-321 AND 50-366 OPERATING LICENSES DPR-57 AND NPF-5 NRC CONCERN AND GPC RESPONSE During the inspection, a concern was raised concerning the implementation of the inservice -testing of pumps and valves on the emergency . diesel generator system. The concern, as stated in the inspection report, is that:

The surveillance program for the fuel oil transfer pumps and the starting air check valves does not adequately verify functionality of the safety related components. Degradation of a fuel transfer pump would not be detected and fuel starvation could occur when the diesel is in use. Leakage of air check valves may not be detected because the air compressors will maintain air pressure on the starting air tank. Reliance on these non-safety grade compressors to compensate for leaking check valves is not acceptable. He are aware that relief requests have been submitted on these components which have not been responded . to as yet. However, you should perform adequate testing until relief is granted, as stated in Generic Letter 89-04. Please describe action to address this concern in your response to this inspection.

Georgia Power Company agrees with the concern and is developing methods for testing the identified components. Design modifications are also being considered which would facilitate testing of the fuel transfer pumps and may alleviate the need for testing air start check valves by eliminating any plausible line break scenario. Corrective actions will be tracked as response to IFI 50-321/366-89-08-25, Emergency Diesel Generator Component Inservice Testing, which embodies this concern and is scheduled to be completed by September, 1990.

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