IR 05000321/1986028: Difference between revisions

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{{Adams
{{Adams
| number = ML20215L089
| number = ML20210E347
| issue date = 10/17/1986
| issue date = 01/12/1987
| title = Insp Repts 50-321/86-28 & 50-366/86-28 on 860830-0920. Violation Noted:Failure to Comply W/Tech Spec Surveillance Requirement & Failure to Perform Surveillance within Required Tech Spec Frequency
| title = Ack Receipt Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-321/86-28, 50-321/86-33.50-366/86-28 & 50-366/86-33.Addl Info on Violation B Re Surveillance Due Dates Requested in 30 Days
| author name = Holmesray P, Ignatonis A, Nejelt G
| author name = Grace J
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
| addressee name =  
| addressee name = Miller J
| addressee affiliation =  
| addressee affiliation = GEORGIA POWER CO.
| docket = 05000321, 05000366
| docket = 05000321, 05000366
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-321-86-28, 50-366-86-28, NUDOCS 8610280462
| document report number = NUDOCS 8702100285
| package number = ML20215L078
| title reference date = 12-12-1986
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| page count = 9
| page count = 4
}}
}}


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C JAN 121987 Georgia /owerCompany ATTN: VMr. J. H. Miller, J President P. O. Box 4545 Atlanta, GA 30302 Gentlemen:
UNITED STATES
SUBJECT: NRC INSPECTION REPORT NOS. 50-321/86-28, 50-321/86-33, 50-366/86-28, AND 50-366/86-33 Thank you for your response of December 12, 1986, to our Notice of Violation issued on November 7, 1986, concerning activities conducted at your Hatch facility under NRC License Nos. OPR-57 and NPF-5. We are ualuating your response and would like more information concerning activities at Hatc In your response to Violations A and B, you state that the events "had no actual or potential safety consequences." We believe your position is not correct since the violations do involve potential safety consequences. The Unit I and Unit 2 Technical Specifications (TS) basis states that the TS requirements in this area ersure "the calculated doses would be less than the allowable levels stated in Criterion 19 of the General Design Criteria for Nuclear Power Plants, Appendix A to 10 CFR Part 50." Criterion 19 requires that a control room shall be provided from which actions can be taken to maintain the reactor in a safe condition under accident conditions and adequate radiation protection shall be provided to permit . access and occupancy of the control room under accident conditions. Failing to verify the operability of the main control room ventilation system in accordance with the TS as described in Violations A and B does involve potential safety consequences since actions to mitigate the effects of an accident may be impaired due to a lack of control room habitabilit Violation A Response In your response to Violation A, you imply the system was found to be satisfactory when the surveillance test was performed on September 26, 1986. We believe the actual as-found system flow was out of specification and had to be adjusted to be within the TS limit Also in your response to Violation A, you do not address the basic problem of not providing adequate detail in your procedure to ensure compliance with TS requirements. This problem was also evident in the Unit 1 Emergency Diesel Generator (EDG) day tank (volume) conversion problem discussed in Inspection Report 86-3 Inspection Report 86-33 requested that you discuss the cause and corrective actions relating to the Unit 1 EDG day tank (volume) conversion problem. Your response addressed the immediate corrective actions but did not provide any explanations as to the cause of the problem. The corrective actions did not 8702100285 870112 PDR ADOCK 05000321 PDR     g Il l
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  'o  NUCLEAR REGULATORY COMMISSION REGION ll
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101 MARIETTA STREET, *', ,j c  ATLANTA, GEORGI A 30323
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Report Numbers: 50-321/86-28 and 50-366/86-28 Licensee: Georgia Power Company P.O. Box 4545 Atlanta, GA 30302 Docket Numbers: 50-321 and 50-366 License Numbers: DPR-57 and NPF-5 Facility Name: Hatch 1 and 2 Inspection Dates: August 30 - September 20, 1986 Inspection at Hatch site near Baxley, Georgia Inspectors: /kdA d, m[e  /4// ry/r/
PeterHolets-faf,565iorResidentInspector Dtte Signed Ad is dis  n/i7/sz Date Signed o Gregory K/ NejfgJt, Resident Inspector Appraved by: /7 O < -[b [d,  /o// 7/r/; '
A. J. Ignpfnis, (Chfef,~ ~ Project Section 3B Dat~e Sfgned Division of Reactof Projects SUMMARY Scope: This routine inspection was conducted at the site in the areas of Licensee Action on Previous Enforcement Matters, Operational Safety Verification, Maintenance Observation, Surveillance Observation, Plant Modification Observa-tion, Engineering Safety Feature System Walkdown, and Reportable Occurrence Results: Two violations were identified - procedural inadequacy resulting in failure to comply with a' Technical Specification (TS) surveillance requirement; and failure to perform surveillance within the required TS frequenc go280462 eslogo O ADOCK 05000321 PDR


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  , u Georgia Power Company 2 JAN 12 B87 address the more basic problem of inadequate procedures and failure to follow procedures. For example, how has this procedure been performed in the past since personnel could not verify the day tank level using the guage, and what actions will be taken to minimize these types of procedural deficiencies in other instructions?
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Violation B Response In your response to Violation B, you state that personnel error contributed to the violation and surveillance "due dates" were incorrectly assigned based upon the operating cycle completion date. We would like more detail on the nature of the personnel error and on any procedures you may have to provide guidance in scheduling surveillances which were in existence at that time or are in place at this tim You stated that I&C personnel documented satisfactory performance of the surveillance test on December 6, 1985. At the time of the inspection, this documentation was not available. The resident inspectors will verify the documentation you state exists in the follow-up of this violatio Also in your response to Violation B, you discuss how frequency " changes" are independently verified since the strengthening of the program in May 1985. You also state that since the surveillance test in question has been performed within the required frequency since the changes in 1985, these previous changes will preclude this occurrence. It is not clear to us that the missed surveillances addressed in Violation B occurred due to frequency " changes." In your description of the reason for Violation B, you assign personnel error and Unit 1/ Unit 2 TS differences, but no mention is made of problems due to frequency changes. It does not appear that the changes made in May 1985 constituted corrective steps for Violation Also under corrective steps taken, you state you now schedule surveillance due dates based upon the previous "due" date of the surveillance and not " solely" upon the operating cycle completion date. This implies that you still use the operating cycle completion dates in some way to arrive at the surveillance due dates and we would like more information on how the due date is scheduled. Also, it appears that scheduling a surveillance due date based on the previous due date may lead to further violations of the specified frequencies. If a surveillance test is performed earlier than the due date and the next test is scheduled based on the due date instead of the actual performance date, then the required frequency will be exceeded if the 125 percent allowable interval is used. It appears that it would be more appropriate to schedule the next surveillance test based on the actual performance dat Under corrective steps which will be taken to prevent recurrence, you state "No further corrective steps are necessary beyond the performance of the procedure at its next due date in order to be in compliance with the 3.25 times 18-month surveillance interval." This addresses the next surveillance but does not ensure future tests will be scheduled within the TS required 3.25 times the specified interval for this or other surveillance test In summary, we would like additional information in the following area . What is the justification for considering the violations to have no potential safety consequences?
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REPORT DETAILS Persons Contacted Licensee Employees
  *H. C. Nix, Site General Manager T. Greene, Deputy Site General Manager
  *P. R. Bemis, Manager Engineering Liaison Department
*H. L. Sumner, Operations Manager
*T. Seitz, Maintenance Manager
*T. R. Powers, Engineering Manager R. W. Zavadoski, Pealth Physics and Chemistry Manager 0. M. Fraser, Site Quality Assurance (QA) Manager (Acting)
C. T. Moore, Training Manager
*S. B. Tipps, Superintendent of Regulatory Compliance Other licensee errployees contacted included technicians, operators, mechanics, security force members and office personne * Attended exit interview ExitInterview(30703)
The inspection scope and findings were sumarized on September 22, 1986, with those persons indicated in paragraph 1 above. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during this inspectio Two violations were identified. The licensee acknowledged the finding and took no' exceptio (0 pen) Violation 50-321,366/86-28-01 - The control room filter train differential pressure test procedure did not provide an acceptance criterion needed to determine the volumetric flow rate. This resulted in a failure to meet the flow requirements for this test (paragraph 6).


(0 pen) Violation 50-321,366/86-28-02 - Surveillance fre room filter train exceeded the TS required frequency.paragraph (quency6).
. 0 Georgia Power Company  3 JAN 121987 Was the as-found flowrate on September 26, 1986, outside the TS required flowrate? Will your Procedure Upgrade Program (PUP) or other programs ensure that procedures can be performed to meet TS requirements and contain adequate detail to prevent occurrences like Violation A and the EDG day tank level problem? What was the cause of the EDG day tank level problem (i.e., had the gauge been replaced recently, procedure changed, etc.)?  1 How has this procedure been performed in the past, since personnel could not verify the day tank level using the gauge? Have there been and are there any procedures which provide guidance in scheduling surveillances? What are the details of personnel error involved with Violation A? { How does the May 1985 change to the Technical Specification surveillance scheduling program revision process constitute a corrective step for Violation B (i.e., was this violation due to a frequency change)? Are surveillance due dates scheduled using operating cycle completion dates?
If so, what means are in place for not exceeding the TS required frequency?
10. .How will you prevent exceeding the TS required frequency using previous due dates vice actual completion dates to schedule the next surveillance tests?
11. How will you prevent exceeding the 3.25 times the surveillance interval for future surveillance tests in general?
Please provide the above information within 30 days of receipt of this lette In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Feaeral Regulations, a copy of this letter will be placed in the NRC Public Document Roo The responses directed by this letter are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-51 Should you have any questions concerning this letter, please contact u


of the control Licensee Action on Previous Enforcement Matters (92702)
Sincerely, Original signed by/
Licensee's actions on previous enforcement natters that have been taken were determined to be acceptable by the inspector verifying the licensee's response with no discrepancies noted for the following violations and unresolved item:
J. Nelson Grace J. Nelson Grace Regional Administrator cc: (See page 4)
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  (Closed) Violation 50-321/86-03-01 -
Failure to maintain Unit-1 secondary containment integrity. GPC letter of April 29, 1986 and NPC response of May 19, 1986, were reviewe r
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  - (Closed) Violation 50-321/86-03-02 - Failure to properly implement a safety related test procedure. GPC letter of April 29, 1986 and NRC response of May 19, 1986, were reviewe (Closed) Violation 50,321,366/86-03-03 - Failure to adequately prepare two safety related procedures. GPC letter of April 29, 1986 and NRC response of May 19, 1986, were reviewe (Closed) Violation 50-321/86-12-01 - Failure to maintain shutdown cooling operational when required by TS. GPC letter of June 11, 1986 and NRC response of July 2, 1986, were reviewe (Closed) Violation 50-366/86-09-01 - Failure to return Unit-2 core spray jockey pump into servic GPC letter of May 21, 1986 and NRC response of June 3, 1986, were reviewe (Closed) Unresolved Item 50-366/86-20-03 - Unit-2 diesel generator battery rack qualification concerns. The '.nspector questioned the seismic qualification of the Unit-2 diesel generator 125 VDC batteries due to failure to have the rack spacing and mounting criteria in accordance with original design specifications. The licensee requested an engineering evaluation be conducted to determine the qualification of the batteries. An analysis conducted by an engineering firm and
e Georgia Power Company 4 JAN 121987 cc: J. P. O'Reilly, Senior Vice President Nuclear Operations
  -
. T. Beckham, Vice President, Plant Hatch
independently by the battery vendor concluded that the seismic quali-fication of the batteries and racks was valid even though the presence of spacing gaps between the batteries and rack side-rails was in excess of that specified on design drawings. The licensee performed a modification on the battery / rack configuration to bring the design into conformance with design specifications. An engineering evaluation concluded that this modification is acceptable and seismic qualifi-cation is maintained. This item is close Operational Safety Verification (71707)
. C. Nix, Site Operations General
The inspectors kept themselves informed on a daily basis of the overall plant status and any significant safety matters related to plant operation , Daily discussions were held with plant management and various members of the plant operating staf The inspectors made frequent visits to the contrcl roo Observations included instrument readings, setpoints and recordings, status of operating systems, tags and clearances on equipment, controls and switches, annunciator alarus, adherence to limiting conditions for opera-tion, temporary alterations in effect, daily journals and data sheet entries, control room manning, and access controls. This inspection activity included numerous informal discussions with operators and their supervisors. Weekly, when on site, selected Engineering Safety Feature The confirmation was made by
/ Manager V A). Fraser, Acting Site QA Supervisor vi.. Gucwa, Manager, Nuclear Safety and Licensing bec. NRC Resident Inspector V Hugh S. Jordan, Executive Secretary Document Control Desk-Strce of Georgia RII-GJenkins 01 /
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(ESF) systems were confirmed operabl verifying the following: Accessible valve flow path aligrment, power supply
{- RII@ A L RC oteau:ht FJCa htrell% VLBrownlee LReyes j DWa er MErnst 12/ /86 'g /06 12/~)/86 $(/7/86 / $ /86 12/
' breaker and fuse status, instrumentation, major component leakage,
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lubrication, cooling, and general condition.


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General plant tours were conducted on at least a biweekly basis. Portions of the control building, turbine building, reactor building, and outside areas were visited. Observations included safety related tagout verifica-tions, shift turnover, sampling program, housekeeping and general plant conditions, fire protection equipment, control of. activities in progress, radiation protection controls, physical security, problem identification systems, and containment isolatio In the course of the monthly activities, the Resident Inspectors included a review of the licensee's physical security program. The performance of various shifts of the security force was observed in the conduct of daily activities to include: protected and vital access controls, searching of personnel, packages and vehicles, badge issuance and retrieval, escorting of visitors, patrols and compensatory posts. Also, the inspectors verified that additional security personnel were posted in the plant, because of the Unit-2 refueling outag No violations or deviations were identifie . MaintenanceObservation(62703)
During the report period, the inspectors observed selected maintenance activitie The observations included a review of the work documents for adequacy, adherence to procedure, proper tagouts, adherence to technical specifications, radiological controls, observation of all or part of the actual work and/or retesting in progress, specified retest requirements, and adherence to the appropriate quality control On September 6,1986, an electrical relay coil,1A71B-K40, failed. This resulted in a blown fuse, which caused a Unit-1 isolation of the hydrogen and oxygen analyzers; and fission product monitor. It was found during the review of maintenance work order (MWO) 1-86-8048 that the retest requirement was to verify that the isolation signal was cleared to restore operations of the primary containment atmospheric detectors. The specific function of the replaced relay coil was to provide an isolation signal to an already closed residual heat removal (RHR) isolation check valve bypass,1E11-F122A. Also, no verification was perforred to demonstrate that replaced coil was goe The safety significance of this particular maintenance retest was minimal and did not warrant a violation by itsel Procedure 34SV-Z41-002-1, Revision 1, for the control room air intake isolation valve operability did not check the timing for the control room exhaust isolation valves (1Z41-F018A and -F0188). Based en drawing H-16042, Revision 15, these valves would close with the same high chlorine isolation signal received by the control room intake isolation valves (1Z41-F011,
-F012, and -F016). The control room isolation function test, 42SV-Z41-001-15, Revision 2, did check the closure of the control room exhaust isolation valves within 7 seconds of an isolation signal. However, Unit-1 TS 4.12.B specifically addressed only the control room intake
 
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isolation valve timing requirements. The inspector reviewed maintenance performed on control room isolation valves and found that the intake isolation valves were timed, as required, after work was done. No record of any maintenance performed on the control room exhaust isolation valves was foun No violations or deviations were identifie . SurveillanceObservations(61726)
The inspectors observed the performance of selected surveillances. The observation included a review of the procedure for technical adequacy, conformance to Technical Specifications, verification of test instrument calibration, observation of all or part of the actual surveillances, removal from service and return to service of the system or components affected, and review of the data for acceptability based upon the acceptance criteri The control room filter train differential pressure test procedure, 57SV-Z41-002-1, Revision 0, did not the establish the design flow rate test condition of 2,500 cfm (* 10%) required by Unit-1 TS 4.12.A.1.a and Unit-2 TS 4.7.2.e.l. This Unit-1 procedure was applicable for Unit-2, because of the common main control room for both units. The TSs required establishing a flow rate of 2500 cfm (* 10%) and then measuring the pressure drop across the combined HEPA filters and charcoal absorber bank to verify a pressure drop of less than 6 inches of wate The inspector found that the actual flow rates established across the control room HEPA filters by procedure 57SV-Z41-002-1 had exceeded the maximum allowable value of 2,750 cfm by 15% or greater, since 1979. The inspector determined the actual volumetric flow rates based on the manometer readings measured and recorded by 57SV-Z41-002-1 in " inches of water" for each control room supply fan (1741-C012A and -C012B). The manometer pressures were then converted to flows by the inspector using the equation provided in procedure 42SV-Z41-001-IS, Revision 2, Data Package 1, Step 62. Procedure 575V-Z41-002-1, Revision 0, was found to be inadequate, because neither a differential pressure acceptance criterion nor a conversion method
! to obtain the volumetric flow rate was stated in the procedure. Plant Hatch l Quality Assurance Manual (QAM), Section 11.2.C.2.b, and procedure 10AC-MGR-003-0S, Revision. 4, Section 8.3.2.3.12, required the establishment of such an acceptance criterio Also, the manometer installed by 57SV-241-002-1, Step F.3, was not procedurally remove The failure to establish the required surveillance flow condition across the control room HEPA filters and use of an inadequate procedure is considered a violation (50-321,366/86-28-01). . __ _ _ . - _ . _ - _ _ _ _ .  . _
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The inspector ident1fied that procedure 57SV-Z41-002-1 was not performed within the frequendy required by Unit-1 TS 4.12.A.1.a; and Unit-2 TSs 4.7.2.e.1 and 4.0.2.b. As stated previously, procedure 57SV-Z41-002-1 was applicable for Unit-2, because of the common main control room for both unit The last four times procedure 57SV-Z41-002-1 was performed were:
September 25, 1986*; October 25, 1984; March 13, 1981; and May 8, 1979. The period of 43 months between 1981 and 1984 and of 23 months between 1984 and 1986 with no surveillance performed exceeded the 18 month surveillance frequency required by Unit-1 TS 4.12.A.1.a and Unit-2 TS 4.7.2.e.l. Also, these dates exceeded the Unit-2 TS 4.0.2.b limit of 3.25 times the 18 month surveillance interval for consecutive surveillances by 30 month Furthermore, a review of the 1986 Licensee's Event Reports (LERs) identified the following missed TS surveillances:
Date Unit # LER # TS #  Topic 02-07-86 1
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86-004 4.9.A. "1B" Diesel Generator Battery Service Tes .3.6. Drywell Fire Detector Alarm .7. Hydraulic Shocks and Sway Arrester (Note: cited as a violation in IE Report 50-321,366/86-15).
 
07-07-86 1 86-026 Table 4.1-1 Reactor Water Level Item 6 Instrumen .9.A.7. V Automatic Rus Rev. 1  Transfer Circuitr .6.1.1. Primary Containment Manual Valves.
 
; In 1985, the licensee conducted a line-by-line comparison of both unit
! procedures with the Unit-1 and Unit-2 TS surveillance requirements. The results of these reviews were documented in LERs: 50-321/85-028, 50-321/85-032, 50-366/85-28, and 50-366/85-2 Also, most recently in LER 50-366/86-016, the licensee stated:
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*The last completion date for surveillance 57SV-Z41-002-1 was changed from December 6, 1985, as stated at the exit interview, to September 25, 1986. It I was found, after a request by the inspector to produce the supporting
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documentation, that the GPC surveillance coordinator's performance date of
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December 6, 1985, was unsupported by documentatio The computer sheet used to track surveillances performed was returned initialed to the surveillance coordinator, indicating that the work was complete . ._ -  ..  , -
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"The Procedure Upgrade Program (PUP) currently implemented at Plant Hatch and previously described... ensure surveillance procedures properly address Technical Specificaticns requirements. Completion of this program should preclude recurrence of this type of event fer each procedure that implements a Technical Specification requirement. The particular procedure described in this event [345V-SUV-001-2] had not yet been through the upgrade process."
 
The failure to perform the control roem HEPA filter surveillances within the required TS frequencies is considered a violation (50-321,366/86-28-02). In the response to this violation, the licensee is further requested to address the missed surveillance in terms of the PUP milestones and completion date . Plant Modification Observations (37700)
The inspectors observed the performance of selected plant modification Design Change Requests (DCRs). The observation included a review of the DCR for technical adequacy, conformance to Technical Specifications, verifica-tion of test instrument calibration, observation of all or part of the actual surveillances, removal from service and return to service of the system or components affected, and review of the data for acceptability based upon the acceptance criteri It was noted by the inspector that since 1982 as-built notices (ABNs), were not incorporated into the controlled drawings, despite the effort by the licensee for timely incorporation of drawing ABNs. Specific examples were:
Drawing Drawing Number Rev. N Outstanding ABN(s)
H-17786 8 84-528 H-17787 12 83-602; 84-473; 86-162 H-17791 6 84-528 H-17792 6 84-528; 85-069 H-17801 13 87-164 H-17802 20 82-164; 84-418 H-17803 19 82-164 H-17804 11 82-164; 86-143 H-17805 7 82-164; 86-164, -282 H-17806 23 84-528; 85-611; 86-040, -162, -168, -352 H-17810 12 84-528; 86-162 H-17811 12 84-5?8; 86-162 H-17815 6 83-433; 85-526 The licensee is investigating the effectiveness of their program to incorporate drawing ABN Drawing errors surveillance found by were:
activities, the insp(ector, whileH-16276, a). Drawing reviewing maintenance Re and 16 with ABNs 85-605, Sup.3 and 86-140 did not reference drawing H-16274, Rev. 0 with ABNs 86-140 and 86-359 for the fission products menitoring system; and (b).
 
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internal motor control center wiring centers (MCCs) wiring pin numbers on H-17069 Rev. 6, were not in agreement with the pin numbers referenced in figure 1 of H-17068, Rev. No violations or deviations were identifie . ESF System Walkdown (71710)
The inspectors routinely conduct partial walkdowns of ESF systems. Valve and breaker / switch lineups and equipment conditions were randomly verified both locally and in the centrol room to verify that the lineups were in accordance with licensee requirements for operability and equipment material conditions were satisfactor The control room ventilation system, which would provide environmental habitability during a radiological accident, was walkdown by the inspecto Two violations were identified. The first violation was for an inadequate procedure that resulted in a failure to establish a surveillance volumetric flow rate required by Unit-2 TS 4.7. The second violation involved exceeding surveillance frequencies of the control room filter train required by Unit-1 and Unit-2 TSs. These violations were discussed in paragraph Also found during the walkdown were:
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40C 1R24-5002 actual frame numbers were different from those listed in the system lineup procedure, 34S0-241-001-1, Revision 0, Data Package 2. This procedure was in agreement with drawings: H-17068, Pevision 8; H-17069, Revision 6; and H-17073, Revision Air handling units A, B, and C (1Z41-B003A, -8003B, and -8003C) were each listed with a four position switch in 3450-241-001-1, Revision 0, Data Package 4. These switches in the control room were actually switches with three positions - off/run/ emergency run. The actual switches agreed with drawing H-17068, Revision . Reportable Occurrences (90712 & 92700)
A number of Licensee Event Reports (LERs) were reviewed for potential generic impact, to detect trends, and to determine whether corrective actions appeared appropriate. Events which were reported immediately were also reviewed as they occurred to determine that Technical Specifications were being met and the public health and safety were of utmost consideratio The following LERs are closed b sed on the TS surveillance frequency violation cited in this report, 50-321,366/86-28-02:
Unit-1: 86-002 (Rev. 1), 86-004, and 86-02 Unit-2: 86-004 and 86-01 _
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10. Unit-1 Main Steam Isolation Logic (92701)
The Unit-1 main steam isolation logic was verified to be tested from a high radiation isolation sienal to the closure of the main steam isolation valves (MSIVs), because of a' regional re The elementary diagrams for the reactor protection system (IC71-) ques and for the primary containment isolation system (IA71-) were used in this determination. Also, the associated functional tests for this logic were checked (i.e., 57SV-D11-001-1, Revision 0, and 34SV-B21-001-1, Revision 0) and found to be within the surveillance frequencie No violations or deviations were identified.
 
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Revision as of 10:07, 4 December 2021

Ack Receipt Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-321/86-28, 50-321/86-33.50-366/86-28 & 50-366/86-33.Addl Info on Violation B Re Surveillance Due Dates Requested in 30 Days
ML20210E347
Person / Time
Site: Hatch  Southern Nuclear icon.png
Issue date: 01/12/1987
From: Grace J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: John Miller
GEORGIA POWER CO.
References
NUDOCS 8702100285
Download: ML20210E347 (4)


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C JAN 121987 Georgia /owerCompany ATTN: VMr. J. H. Miller, J President P. O. Box 4545 Atlanta, GA 30302 Gentlemen:

SUBJECT: NRC INSPECTION REPORT NOS. 50-321/86-28, 50-321/86-33, 50-366/86-28, AND 50-366/86-33 Thank you for your response of December 12, 1986, to our Notice of Violation issued on November 7, 1986, concerning activities conducted at your Hatch facility under NRC License Nos. OPR-57 and NPF-5. We are ualuating your response and would like more information concerning activities at Hatc In your response to Violations A and B, you state that the events "had no actual or potential safety consequences." We believe your position is not correct since the violations do involve potential safety consequences. The Unit I and Unit 2 Technical Specifications (TS) basis states that the TS requirements in this area ersure "the calculated doses would be less than the allowable levels stated in Criterion 19 of the General Design Criteria for Nuclear Power Plants, Appendix A to 10 CFR Part 50." Criterion 19 requires that a control room shall be provided from which actions can be taken to maintain the reactor in a safe condition under accident conditions and adequate radiation protection shall be provided to permit . access and occupancy of the control room under accident conditions. Failing to verify the operability of the main control room ventilation system in accordance with the TS as described in Violations A and B does involve potential safety consequences since actions to mitigate the effects of an accident may be impaired due to a lack of control room habitabilit Violation A Response In your response to Violation A, you imply the system was found to be satisfactory when the surveillance test was performed on September 26, 1986. We believe the actual as-found system flow was out of specification and had to be adjusted to be within the TS limit Also in your response to Violation A, you do not address the basic problem of not providing adequate detail in your procedure to ensure compliance with TS requirements. This problem was also evident in the Unit 1 Emergency Diesel Generator (EDG) day tank (volume) conversion problem discussed in Inspection Report 86-3 Inspection Report 86-33 requested that you discuss the cause and corrective actions relating to the Unit 1 EDG day tank (volume) conversion problem. Your response addressed the immediate corrective actions but did not provide any explanations as to the cause of the problem. The corrective actions did not 8702100285 870112 PDR ADOCK 05000321 G PDR g Il l

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, u Georgia Power Company 2 JAN 12 B87 address the more basic problem of inadequate procedures and failure to follow procedures. For example, how has this procedure been performed in the past since personnel could not verify the day tank level using the guage, and what actions will be taken to minimize these types of procedural deficiencies in other instructions?

Violation B Response In your response to Violation B, you state that personnel error contributed to the violation and surveillance "due dates" were incorrectly assigned based upon the operating cycle completion date. We would like more detail on the nature of the personnel error and on any procedures you may have to provide guidance in scheduling surveillances which were in existence at that time or are in place at this tim You stated that I&C personnel documented satisfactory performance of the surveillance test on December 6, 1985. At the time of the inspection, this documentation was not available. The resident inspectors will verify the documentation you state exists in the follow-up of this violatio Also in your response to Violation B, you discuss how frequency " changes" are independently verified since the strengthening of the program in May 1985. You also state that since the surveillance test in question has been performed within the required frequency since the changes in 1985, these previous changes will preclude this occurrence. It is not clear to us that the missed surveillances addressed in Violation B occurred due to frequency " changes." In your description of the reason for Violation B, you assign personnel error and Unit 1/ Unit 2 TS differences, but no mention is made of problems due to frequency changes. It does not appear that the changes made in May 1985 constituted corrective steps for Violation Also under corrective steps taken, you state you now schedule surveillance due dates based upon the previous "due" date of the surveillance and not " solely" upon the operating cycle completion date. This implies that you still use the operating cycle completion dates in some way to arrive at the surveillance due dates and we would like more information on how the due date is scheduled. Also, it appears that scheduling a surveillance due date based on the previous due date may lead to further violations of the specified frequencies. If a surveillance test is performed earlier than the due date and the next test is scheduled based on the due date instead of the actual performance date, then the required frequency will be exceeded if the 125 percent allowable interval is used. It appears that it would be more appropriate to schedule the next surveillance test based on the actual performance dat Under corrective steps which will be taken to prevent recurrence, you state "No further corrective steps are necessary beyond the performance of the procedure at its next due date in order to be in compliance with the 3.25 times 18-month surveillance interval." This addresses the next surveillance but does not ensure future tests will be scheduled within the TS required 3.25 times the specified interval for this or other surveillance test In summary, we would like additional information in the following area . What is the justification for considering the violations to have no potential safety consequences?

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. 0 Georgia Power Company 3 JAN 121987 Was the as-found flowrate on September 26, 1986, outside the TS required flowrate? Will your Procedure Upgrade Program (PUP) or other programs ensure that procedures can be performed to meet TS requirements and contain adequate detail to prevent occurrences like Violation A and the EDG day tank level problem? What was the cause of the EDG day tank level problem (i.e., had the gauge been replaced recently, procedure changed, etc.)? 1 How has this procedure been performed in the past, since personnel could not verify the day tank level using the gauge? Have there been and are there any procedures which provide guidance in scheduling surveillances? What are the details of personnel error involved with Violation A? { How does the May 1985 change to the Technical Specification surveillance scheduling program revision process constitute a corrective step for Violation B (i.e., was this violation due to a frequency change)? Are surveillance due dates scheduled using operating cycle completion dates?

If so, what means are in place for not exceeding the TS required frequency?

10. .How will you prevent exceeding the TS required frequency using previous due dates vice actual completion dates to schedule the next surveillance tests?

11. How will you prevent exceeding the 3.25 times the surveillance interval for future surveillance tests in general?

Please provide the above information within 30 days of receipt of this lette In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Feaeral Regulations, a copy of this letter will be placed in the NRC Public Document Roo The responses directed by this letter are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-51 Should you have any questions concerning this letter, please contact u

Sincerely, Original signed by/

J. Nelson Grace J. Nelson Grace Regional Administrator cc: (See page 4)

e Georgia Power Company 4 JAN 121987 cc: J. P. O'Reilly, Senior Vice President Nuclear Operations

. T. Beckham, Vice President, Plant Hatch

. C. Nix, Site Operations General

/ Manager V A). Fraser, Acting Site QA Supervisor vi.. Gucwa, Manager, Nuclear Safety and Licensing bec. NRC Resident Inspector V Hugh S. Jordan, Executive Secretary Document Control Desk-Strce of Georgia RII-GJenkins 01 /

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