IR 05000321/1986039

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-321/86-39 & 50-366/86-39 & Request That Violation Be Reduced to Severity Level V.Violation Stands as Issued.Evaluation Encl

ML20215B200
Person / Time
Site:	Hatch
Issue date:	05/29/1987
From:	Gibson A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	James O'Reilly GEORGIA POWER CO.
References
NUDOCS 8706170254
Download: ML20215B200 (4)

Text

,. MAY 2 91987 l

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orgia Power Company TTN: Mr. James P. O'Reilly Senior Vice President-Nuclear Operations '

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P. O. Box 4545 Atlanta, GA 30302 Gentlemen:

SUBJECT: REPORT NOS. 50-321/86-39 AND 50-366/86-39 )

Thank you for your response of March 9, 1987, to our Notice of Violation issued on February 6,1987, concerning activities conducted at your Hatch facility under NRC License No. NPF-5. We have evaluated your response and found that it meets the requirements of 10 CFR 2.201. We will examine the implementation of your corrective actions during future inspection In your response you admit the violation but request that the violation be reduced to a severity level V or entirely withdraw We have evaluated your request to mitigate the cited event and have concluded, on the basis identified in the enclosure to this letter, that the violation stands as issue Should you have any questions concerning this letter, please contact the Project Section Chie

Sincerely, f

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i Albert F. Gibson, Director Division of Reactor Safety Enclosure:

Evaluation of Request to Mitigate Violation c w/ encl:

. T. Beckham, Vice President, Plant Hatch

. C. Nix, Site Operations General Manager

. Fraser, Acting Site QA Supervisor L. Gucwa, Manager, Nuclear Safety and Licensing bec w/ enc 1: (See page 2)  !

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ENCLOSURE

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' EVALUATION OF REQUEST'TO MITIGATE VIOLATION

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The NRC ienforcement policy as delineated 10 CFR 2, Appendix C,

Section V. (C.V.A) does provide for mitigation . of violations of the ~ regulatory

. requirements under certain circumstances. While~the policy provides the NRC an

. option to L mitigate' a . violation which- meets the -specified conditions in Section V. A. , -it. 'further states that licensees are held responsible for .the Lacts of- their employees and for events which within reasonable quality tassurance' or management controls could be avoide The decision Lto mitigate or-' issue a violation will be made by this office based on: review of the circumstance involved in an event. -Review of the

. circumstances. surrounding- this event indicate several weaknesses i implementation of ' your programs to control safety-related activities as

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follows:

, . Quality of Procedures Written instructions or procedures to implement control of activities-

.to ensure determination of the "as found" leak rate through the Maintenance- Work Order '(MW0) system were not available when our ;

inspector was onsite. While we recognize the MWO . system as an 1 established control system, early in the outage, the instructions a p ' issued through the MWO system were not adequate to prevent personnel errors which resulted-in the violatio jl . Training  ;

Training or instructions to the personnel responsible for performing the MW0 s were not sufficient to prevent the removal of the equipment !

hatches prior'to a leak rate measurement. We believe that a. thorough understanding by these personnel of the safety significance of the v

"as found" leak rate and their individual responsibility in ensuring that-this measurement was' completed prior to maintenance could have prevented the premature removal of the equipment hatche . Timeliness Implementation of the control process through the MWO system was established late relative to the beginning of outage work. In the the MWO did not contain the instruction ;

case of the isolation to determine the-leakvalve,ior rate pr to maintenance.

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Enclosure 2

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We consider these discrepancies to involve elements of the quality assurance, administrative and management control programs. While these problems are not severe enough to indicate programmatic breakdown, they do indicate insufficient attention to the details necessary to accomplish

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the control of a safety-related activity. It is our conclusion.that the violation involved' errors which could reasonably have been prevented within the purview of your established quality assurance and management control program Since the plant was in cold shutdown, the violation did not result in an immediate' concern for the safety of the plant. The result, however, was a loss of information needed to assess the reliability of the containment t isolation system. We consider the demonstration of safety system '

reliability important to safet We have determined that the level IV violation is justified as issue In regard to the applicability of the violation, our records indicate that the Notice of Violation (NOV) was directed to Docket No. 50-366, License No. NPF-5. Further, in the first paragra violation is identified as related to the Unit 2 "phasoffound" the NOV, the containment :

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