View source for HL-3044, Responds to NRC Re Violations Noted in Insp Repts 50-321/92-22 & 50-366/92-22.Corrective Actions:Design Change Will Be Implemented by 930531 to Remove Ability to Override Automatic Isolation Function for Dampers

{{Adams
| number = ML20125B756
| issue date = 12/07/1992
| title = Responds to NRC Re Violations Noted in Insp Repts 50-321/92-22 & 50-366/92-22.Corrective Actions:Design Change Will Be Implemented by 930531 to Remove Ability to Override Automatic Isolation Function for Dampers
| author name = Beckham 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 = HL-3044, NUDOCS 9212100139
| title reference date = 11-06-1992
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 5
}}

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Georgia Power Company 40 inverness Center Parkway Post Off.co Box 129s
,*        Birmingham. Alabama 3s201 Tolophone 20s 877 7279 u
J. T. u.ekham. Jr.                                                                                             Georgia' Power
          %ce Presdont Nuclear Hatch Project                                                                                              P+ s: v"em e.= Pc sg> e HL-3044 004344 December 7, 1992 U.S. Nuclear Regulatory Commission ATTN:           Document Control Desk Washington, D.C. 20555 PLANT HATCH - UNITS 1, 2 NRC DOCKF.TS 50-321, 50-366 OPERATING LICENSES DPR-57, HPF-5 REPLY TO A NOTICE OF VIOLATION Gentlemen:
s In response to your letter of November 6, 1992, 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 92-22. 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, h
J. T. Beckham, Jr.
                                                                                                                             ^
JKB/cr Enclosure cc:         Georaia Power Comoany Mr. H. L. Sumner, General Manager - Nuclear Plant NORMS U.S. Nuclear Reaulatory Commission. Washinoton. D.C.
Mr. K. Jabbour, Licensing Project Manager - Hatch U.S. Nuclear Regulatory Commission. Reaion 11 Mr. S. D. Ebneter, Regional Administrator Mr. L. D. Wert, Senior Resident inspector - Hatch
                                                                              ^                                                              '
j (t y/  Vl  1 9212100139 PDR O
ADOCK 030003%                     92120'7'f          PDR v
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ENCLOSURE-1 PLANT HATCH - UNITS 1 AND 2 NRC DOCKETS 50-321 AND 50-366' OPTRATING LICENSES DPR-57 AND NPF-5                                                                 i VIOLATION 92-22-01 AND GPC RESPONSE i
VIOLATION 92-22-01                                                                                                                       l 1
Hatch Unit 2 TS 3.9.5.2 requires that secondary containment ventilation system                                                           ;
automatic isolation dampers 2T41-F003A, F003B, F023A, and F0238 shall t,e -                                                             i operable in operational condition 5 and when irradiated fuel is being handled in the Hatch Unit 1 secondary containment.
Hatch Unit 1 TS 3.7.C requires that secondary containment integrity shall be-maintained during all modes' of Unit 1 operatinn except when certain conditions are met. These conditions include the provisions that irradiated fuel is not being moved in the reactor building and the Unit I reactor is subcritical.
The TS definition of secondary containment integrity specifies that all automatic ventilation system isolation valves be operable or secured in the isolated position.
Contrary          to the above, from approximately 1:30                                         a.m. to =l:30 p.m. on September 30, 1992, dampers 2T41-F003A, F003B, F023A, and F023B were -inoperable.
The dampers failed to automatically shut on a low reactor vessel level following a Unit 1 reactor scram. Movement of irradiated fuel in the Unit I secondary containment was in progress during this period.
This is a Severity Level IV violation.                           (Supplement I)
RESPONSE TO VIOLATION 92-22-01 l
Admission or denial of the violatiora                                                                                                   l The violation occurred as described in the Notice of Violation.
Reason for the violation:
The violation was caused by a less than adequate design.                                                       The -automatic isolation function of the dampers could be defeated by placing their control switches to the "open" nosition.                             No other secondary containment isolation
           - dampers have switches which function in this manner.
At        approximately 0130 EDT               on 9/30/92,                         following         clearance restoration activities,_         .a     licensed Operator moved the control                                       switches for dampers 2T41-F003A and B and 2T41-F023A and B from " auto" to "open."                                              The Operator usid l
HL-3044 004344                                                       El-1
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i ENCLOSURE 1 (Continued)                                      ,
I VIOLATION 92-22-01 AND GPC RESPONSE procedure 3450-T41-006-25, " Refueling Floor Ventilation System," to align the Unit 2 Refueling Floor Ventilation system to its normal configuration following restoration of a clearance. The procedure required that isolation dampers 2T41-F003A and B and 2T41-F023A and B be confirmed to be in the open position.
Because the term "open" was capitalized in the procedure, the Operator thought the procedure required him to place the control switches for these dampers to               j the switch position labeled "open." He did this and the dampers opened as expected; and consequently, returned to . their normal. position. Due to an-inadequate design, the automatic secondary containment isolation function of l
these dampers is overridden with the control switches in the "open" position.
Hence, they could not close upon receipt of a secondary containment isolation-signal per design and therefore were inoperable.
I During review of the Safety Parameter Display System tape from the Unit.1 scram on 9/30/92, plant personnel noted that secondary containment isolation dampers 2T41-F003A and B and 2T41-F023A and B did not close as-required. Investigation into this problem revealed the dampers' control switches were in the incorrect position. At approximately 1330 EDT on 9/30/92, the control switches were.
placed in the " auto" position, restoring the dampers to an operable status.
Corrective steps wnich have been taken and the results achieved:
As a result of this event,       a clearance was placed on the-control switches for dampers 2T41-F003A and B and 2T41-F023A and B to administratively maintain the switches in the " auto" position. This was done on 10/1/92. It was determined that a similar problem did not exist for the Unit 2 reactor building secondary            .
containment and the Unit I refueling floor and reactor building secondary containment isolation dampers because these dampers do not have control switches.
[qrrective steps which will be taken to prevent further violations:
A design change will be implemented by 5/31/93 to remove the- ability to override the automatic isolation function for dampers 2T41-F003A and B and 2T41-F023A and B when they are in the open position.                Until the design change can be       i implemented, appropriate administrative controls will remain in place to ensure the dampers remain operable.
Rate when full compliance will be achieved:
Full compliance was achieved on 9/30/92 at approximately 1330 EDT~when the control switches for dampers 2T41-F003A and B and 2T41-F023A and B were returned to the " auto" position thereby restoring the dampers to an operable status as required by the plant's Technical Specifications.
  ~
HL-3044 004344                                   El-2

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ENCLOSURE 2 PLANT HATCH - UNIT 2
:                                                    NRC DOCKET 50-366 OPERATING LICENSE NPF-5 VIOLATION 92-22-02 AND GPC RESPONSE                                                 >
VIOLATION 92-22-02 Hatch     Unit 2 Technical          S>ecification         (TS)    3.9.6  requires that            direct communications be maintained aetween the control room and the refuelin; platform.
personnel     during core alterations. -As                     stated in the TS      bases, this communications capability ensures that personnel                      involved in. the refueling                  .
activities can be promptly informed of significant changes in the facility status or core reactivity condition during fuel movement within the reactor vessel.                                                                                                           .
Contrary to the above, on September 22, 1992, direct communications and monitoring requirements were not maintained between the control room and- the refueling platform personnel during core alterations in that the operator-assigned to perform these duties was inattentive. This condition was observed to exist for several seconds before corrective actions were initiated by the inspector.
This is a Severity Level IV violation.            (Supplement I)
This violation is applicable to Unit 2 only.
RESPONSE TO VIOLATION 92-22-02 Admission or denial of the violation:
The violation occurred as described in the Notice of Violation.
Reason for the violation 1 The violation was caused by personnel error. The operator assigned the task of maintaining communication with refueling platform personnel failed to remain alert and attentive to his duties. He had not worked an excessive amount of overtime nor had he rotated through different shifts (night, day, evening) prior to this event. In fact, he had worked normal, eight-hour day shifts for :the-preceding- week and_a hal f. Therefore, fatigue from overtime and/or sleeping-pattern disruptions from changes in shift schedule were not factors in this.
event.
            . HL-3044 004344                                         E2-1l

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ENCLOSURE 2 (Continued)
VI0lATION 92-22-02 AND GPC RESPONSE Corrective stens which have been taken and the results ach,eved:                                                                                     ,
As a result of this event, the following actions have been taken:                                                                                     c 1,         "a e operator was removed from licensed duties.                                Additionally,-he was                                       '
formally disciplined under GPC's Positivc Jiscipline Program.
: 2.        This event was reviewed with each operations shift crew.                                   The importance of remaining alert was stressed and the need for the crews to take actions necessary to ensure that crew members remained alert was emphasized.
: 3.         Operations management performed checks during back shifts to observe the attentiveness of operations shift crew members. No problems were found.
Corrective steps which will be taken to prevent further violations:
No additional corrective actions are necessary at this time to prevent further violations.
Date when full co.mpliaqce will be achieved:
Full              compliance was achieved on 9/22/92 at approximately 1455 EDT when the operator was made attentive.                       He had assumed his station at                               approximately-1445 EDT; . therefore, the violation of Unit 2 Technical                                                          Specifications requirements existed for only 10 minutes.
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HL-3044                                                                                                                                               ,
004344                                                 E2-2
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