View source for HL-1586, Responds to NRC Re Violations Noted in Insp Repts 50-321/91-04 & 50-366/91-04.Corrective Actions:Design Change Request 2H91-023 Implemented to Raise Condensate Storage Tank Level Switch Setpoints Approx 22 1/2 Inches

{{Adams
| number = ML20073E008
| issue date = 04/26/1991
| title = Responds to NRC Re Violations Noted in Insp Repts 50-321/91-04 & 50-366/91-04.Corrective Actions:Design Change Request 2H91-023 Implemented to Raise Condensate Storage Tank Level Switch Setpoints Approx 22 1/2 Inches
| author name = Beckman J
| author affiliation = GEORGIA POWER CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000321, 05000366
| license number = 
| contact person = 
| document report number = 001480, 1480, HL-1586, NUDOCS 9104300017
| title reference date = 03-27-1991
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 10
}}

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* is      +(*:    r. p , t HL-1586 001480 April 26, 1991 U.S. Nuclear Regulatory Commission ATTN:                  Document Control Desk Washington, D.C. 20555 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-32), 50-366 OPERATING LICENSES DPR-57, NPT-5 RESPONSE TO INSPECTION REPORT 91-04 Gentlemen:
In response to your letter of March 27, 1991 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 NRC Inspection Report 91-04. A copy of this response is being provided to NRC Region 11 for review,                   in the enclosure,                     a transcription of the NRC violation precedes GPC's response.
Should you have any questions                                                  in this regard, please contact this office.
Sincerely,
                                                                                                                                 )      - n J. T. Beckham, Jr.
JKB/cr Enclosures cc:              (See page two.)
9104300017 910426 DR ADOCK 0500                          1 TEo /
                                                                                                                                                       'It

Geolgia Powerkh U.S. Nuclear Regulatory Commission April 26, 1991 Page Two cc:   Georaia Power Company Mr. H. L. Sumner, General Manager - Nuclear Plant Mr. J. D. Heidt, Manager Engineering and Licensing - Hatch NORMS U.S. Nuclear Reaulatory Commission. Washinoton. D.C.
Mr. K. Jabbour, Licensing Project Manager - Hatch U.S. Nuclear Reaulatory Commission. Reaion 11 Mr. S. D. Ebneter, Regional Administrator Mr. L. D. Wert, Senior Resident Inspector - Hatch i
700? ?$

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* ENCLOSURE 1 PLANT HATCH - UNIT 2 NRC DOCKET $0-366 OPERATING LICENSE NPF-5 VIOLATION 91-04-01 AND GPC RESPON${
VIOLATION 91-04-01 10 CFR 50 Ap)endix B Criterion 111, Design Control, requires, in part, for measures 'to se established to assure that design basis requirements are correctly translated into procedures and instructions.                                      ,
1 Contrary to the above,        between February 1985 and February 1991, design basis requirements contained in engineering calculations were not correctly translated. into procedures in that the High Pressure Core Injection (HPCI)
Condensate Storage Tank (CST) level switch setpoints (level switches                        ;
2E41-N002 and 2E41-N003) were incorrectly set to ensure a successful                        '
transfer of the HPCI suction source to the torus on low CST water level.
This is a Severity Level IV Violation (Supplement 1).
This violation is applicable to Unit 2 only.                                                l RESPONSE TO VIOLATION 91-04-01 Admission or denial of violation:
The violation occurred as described in the Notice of Violation.
Reason for the violation:
The level switch setpoint changes calculated as                aart of DCR 84-138 for Condensate Storage Tank'(CST) level switches 2E41-N002 and 2E41-N003 were not    implemented in 1985 as a result of personnel error. Specifically, individuals involved in the development, review, and implementation of the level' switch setpoint changes in 1985 apparently failed to attach the appropriate level of significance to the setpoint changes, in part, because the existing.setpoints were in compliance with the literal wording of the Technical Specifications. A contributing cause was a design change process which did not require detailed documentation that would prominently identify deficient plant conditions.-
Proposed- new setpoints for CST level switches 2E41-N002 and 2E41-N003 were transmitted to Plant Hatch in April 1985 as part of Design Change Request (DCR) 84-138. :This DCR was initiated as part of a program to establish an instrument setpoint index, establish consistency with the recommendations of Regulatory Guide 1.105, and implement setpoint changes calculated by the plant's Architect / Engineer (A/E). This DCR contained many setpoint changes covering numerous plant systems and components.
001480 HL-1586                                                 El-1

ENCLOSURE I (Continued)
VIOLATION 91-04-01 AND GPC RESPONSE The new setpoints for the level switches proposed by DCR 84-138 were approximately     22 inches higher than the existing setpoints. The information transmitted to the plant by the A/E stated the existing setpoints were " lower than the PS. (process safety limit).' However, it was not clear that the existing setpoints represented equipment operability or Technical Specifications compliance concerns. In fact, a review of the design    modification transmittal packages associated with DCR 84-138 indicated a potential for a misunderstanding with regard to the necessity for implementing the higher setpoints.
An earlier setpoint index transmittal          dated 9/11/84 noted the aroposed setpoint changes did not constitute previous design deficiencies aut were upgrades of the design philosophy to then present day standards (e.g.,
Regulatory Guide 1.105 recommendations).         The proposed changes identified in the April     1985 transmittal were described as more conservative than existing setpoints. It should be noted the existing level switch set)oints were    in compliance with the            literal wording    of the      Tec1nical Specifications, i.e., initiate suction source transfer with 10,000 gallons of water remaining in the CST, hence the identification of their change as
                                      " conservative". Finally, a subsequent transmittal stated the proposed setpoint changes constituted an improved design.          Given this information, it appears that individuals involved in the development, review,               and implementation of DCR 84-138 in 1985 failed to realize the significance of the setpoint changes to CST level             switches 2E41-N002 and 2E41 N003.
Consequently,    the level switch setpoint changes were not impicmented untti their significance became clear in January 1991.
Corrective steos which have been taken and the results achieved:
As a result of this event, the following corrective actions have been taken:
: 1. Upon determination the setpoints for CST level switches 2E41-N002 and 2E41-N003 were incorrectly set, the level switches were declared inoperable. The High Pressure Coolant injection (HPCI) system,    at the time the CST level switches were declared inoperable,     was already aligned to take suction             from the Suppression Pool, its alternate suction source. The HPCI system was left with the Suppression Pool as its suction source until the CST level switch setpoints were changed.
: 2. DCR 2H91-023 was      implemented to raise the CST level           switch setpoints approximately 22 1/2 inches. A/E calculations show the HPCI system will have adequate flow and suction pressure throughout the entire suction scurce transfer sequence at the new,            higher setpoints.
001480 HL-1586                               El-2

9                                                                                                                                                   l 3
ENCLOSURE 1 (Continued)
V10LA110N 91-04-01 AND CPC RESPONSE 3,   CST level switches 2E41 N002 and 2E41-N003 were functionally tested per -plant procedures following implementation of DCR 2H91-023.
They were declared operable on 2/8/91 at approximately 0400 CST.
The HPCI system was aligned to take suction from the CST, its normal suction source.
: 4. The setpoints for the corresponding CST level                                                                   switches for the Unit 1 HPCI system and the Unit 1 and Unit 2 Reactor Core Isolation Cooling systems were reviewed. These setpoints were determined to 1
be correct.
: 5. A review of all the setpoint changes within the scope of DCR 84-138 l                                 was                     initiated- to ensure all proposed changes either have been
;                                 implemented or the unmodified setpoints do not present any safety concerns.                                 The review of the proposed f.etpoint changes for both Unit 1 and Unit 2 safety-related instruments has been completed.
No unmodified setpoints were found to present any safety concerns.
: 6. The existing design change process is substantially different from the one which existed in 1985. Specifically, present design change packages have more detailed narrative design sunnaries and safety 4
evaluations than were typically prepared for DCRs in the 1985 time
,                                 frame.                                  These more                                        detailed documents prominently identify unacceptable plant conditions and place more emphasis on the need to change them. Also,.in general, multiple plant systems are no longer                                 covered by a -single DCR. This 1elps ensure safety significant changes are not masked by numerous other changes to=a variety of plant systems.
: 7. Due to the elasped time since the personnel error occurred, counseling of involved individuals was not considered to be effective.
2
[ptrective steos which will be taken to avoid further violations:
No further corrective actions are necessary to prevent recurrence.
Date when full comoliance will be achieved:
                      - Full    compliance was achieved on 2/8/91 when the setpoints for CST level p                      switches 2E41-N002 and -2E41-N003 were raised per DCR 2H91-023, and the l
                      - level switches were functionally tested per plant procedJres and declared operable.
001480 HL-1586                                                                                                      El-3 1

I l
ENCLOSURE 2                                                                             .
PLANT HATCH - UNIT 1 NRC DOCKET 50-321 OPERATING LICENSE DPR-57 VIOLATION 91-04-02 AND GPC RESPONSE VIOLATION 91-04-02 Technical                                                            6.8.1.a requires that written procedures be established,Specification implemented,(TS)d                 an                                maintained as recommended in Appendix 'A' of Regulatory Guide 1.33. Revision 2, February 1978.
Section 6u of Appendix 'A' of Regulatory Guide 1.33, recommends procedures for respondthg to a Reactor Trip.
Procedure 3 % 9 5 060-15                                         Rev. 1, ' Scram Procedure' provides written instructiots for merator actions to be performed in the event of a reactor scram.       This proteture specifies the insertion of Source Range Monitors (SRMs) and Intermediate Range Monitors (IRMs) as an initial operator action following a scram.
Contrary to the above, on February 12, 1991, the SRMs and IRMs were not inserted until approximately 25 minutes after the Unit I reactor scram.
This is a Severity Level IV Violation (Supplement 1).
This violation is applicable to Unit 1 only.
RESPONSE TD VIOLATION 91-04-02 Admission or denial of violation:
The violation occurred as described in the Notice of Violation.
Reason for the violation:
The violation is the result of personnel                                                                                error by- licensed Operations                      -
personnel. The Operator responsible for inserting the Source Range Monitor and Intermediate Range Monitor detectors failed to ensure the detectors were inserted as required by procedure 34AB-0PS-060-IS, ' Scram Procedure.'
In order to insert the detectors, they must be selected by depressing their respective select push buttons. The ' drive in' push button then must be depressed.            Apparently, the Operator depressed the ' drive in' push button, but did not depress the four select push buttons for the Source Range                                                                                                   a-l                                            Monitor detectors and the eight select push buttons for the Intermediate i                                            Range Monitor detectors. Consequently, the detectors did not move. The j                                            Operator also failed to verify detector movement by observing the 'out' light for each detector extinguished and the "in' light illuminated.
1 001480-HL-1586                                                                                     E2-1

1 fC
!                                                                ENCLOSURE 2-(Continued)
VIOLATION 91-04-02 AND GPC RESPONSE Corrective steos which have been taken and the results achieved:
As a result of this event, the involved Operator has been counseled                                                                      I regarding attention to detail and the need for self-checking of his                                                                      '
y                       actions.
Corrective steos which will be taken to avoid further violations:
The 0)erations Department will perform beginning of shift training which                                                                l descri>es the event the root cause of the event, and the importance for                                                                 '
attention to detail and the need for self-checking of actions. This training will be complete 5/15/91.                                                                                                     -
Date when full comoliance will be achievedi Full compliance was achieved on 2/12/91 when the Source Range Monitor and Intermediate Range Monitor detectors were inserted as required by procedure 34AB-0PS-060-IS.
i l.
l 001480 HL-1586                                                     E2-2 L
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ENCLOSURE 3 PLANT HATCH - UNIT 1 NRC DOCKET 50-321 OPERATING LICENSE OPR-57 VIOLATION 91-04-04 AND GPC RESPONSE VIOLATION 91-04-0_4 TS 6.8.1.c requires that written procedures be established, implemented and     l maintained     for surveillance and test activities        of srfety related equipment. Plant administrative procedure 10AC-MGR-003-OS;    " Preparation i and Control of Procedures", contains the requirements for the " independent     i verification" process. The independent verification process is utilized         I throughout the surveillance testing program.
: 1. Step 7.5.19 of procedure 345V-071-005-15. " Turbine Control     Valve fast Closure Instrument functional Test," requires a jumper to be removed and independently verified as such from relay IC71-K80.
Contrary to the above, on February 22, 1991, the jumper was not removed and the independent verification process was not properly performed. During a subsequent surveillance, on February 27, 1991, the Unit     I reactor scrammed due to the failure to remove the jumper.
: 2. Steps 7.1.46.5 and 7.1.46.6 of procedure 57SV-Dll-016-IS; *GE Numac Main Steam Line Logarithmic Radiation Monitor functional Test",
requires links DD-16 and 00-17 to be closed and         independently verified as such.          Additionally, step 4.3.4 of procedure 575V-Dil-016-lS requires the use of temporary modification tags in conjunction with the performance of the surveillance.
Contrary to the above, on February 27, 1991, the links were not closed and the independent verification process was not properly performed.      In addition, temporary modification tags were not utilized.
This is a Severity Level IV violation (Supplement I).
This violation is applicable to Unit 1 only.
RESPONSE TO VIOLATION 91-04-04 Admission or denial _of violation:
The violations occurred as described in the Notice of Violation.
!                             001480 Hl.-1586                              E3-1

ENCLOSURE 3 (Continued)
VIOLATION 91-04-04 AND GPC RESPONSE Reason for the violationt The violations were caused by personnel error by Instrument and Control
(!&C) technicians.        In both events, I&C technicians failed to follow procedure requirements,       in the first event, I&C technicians failed to remove a jumper and independently verify its removal as required by procedure 345V-C71-005-IS, " Turbine Control Valve Fast Closure Instrument functional Test." In the second event, I&C technicians failed to close links and independently verify their closure as required by procedure 575V-Dil-016-IS, "GE Numac Main Steam Line Logarithmic Radiation Monitor Functional    Test."     The    technicians also failed to use temporary modification tags as required by the procedure.
Car _rfetive steos which have been taken and the results achieved:
As a result of this event, the following corrective actions have been taken:
: 1. The Unit I and Unit 2 Main Control Room panels were inspected for proper condition of relays and links. No similar conditions were found, although some deficiencies were identified and corrected.
: 2. Involved personnel were disciplined in accordance with GPC policy.
They were suspended from their duties and their certification for performing safety related activities was revoked. The disciplinary action included personal interviews with the plant General Manager.
They were retrained on quality activity performance requirements.
The retraining included written exams and in-plant demonstrations.
: 3. The General Manager directed that each department manager conduct meetings with every employee to emphasize the importance of these events._    Specific areas which were stressed were, attention to detail,    strict procedural compliance, the significance of personal signatures,     and the personal        accountability of individuals performing safety related activities.
: 4. Within the Maintenance Department,          the Manager of Maintenance directed that all personnel receive formal training with regard to the requirements for independent verification. This training has been completed,      in addition, tool box meetings were conducted for all Maintenance personnel which involved detailed discussions of the causes and consequences of the five scrams as of March 1,1991.
001480 HL-1586                               E3-2

.                                                                                                                                       ENCLOSURE 3 VIOLATION 91-04-04 and GPC RESPONSE
: 5.              As a direct result of the examples of inadequate independent 4                                                                                verification,                  the Manager of Maintenance required,                                                                          for a two week period,            that for                      any activity                                                                  which required independent verification,                  a third party "as left" inspector would confirm that                                                                                   i both the activity and verification were performed in strict                                                                                                           i procedural compliance, No deficiencies were identified.
Corrective steos which will be taken to avoid further violations:
No further corrective actions are necessary to prevent recurrence.
Date when full comoliance will be1 achieved:
Full compliance was achieved on 2/27/91 when the-jumper was removed and the two links closed.
                                                                                                                                                                                                                                                       )
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1 001480-HL-1586                                                                                       E3-3
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