ML20214K287

Ack Receipt of Describing Steps Taken to Correct Violations Noted in Insp Repts 50-321/86-22 & 50-366/86-22. Util Request for Withdrawal of Violation a Denied.Violation D Withdrawn

ML20214K287
Person / Time
Site:	Hatch
Issue date:	05/14/1987
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	James O'Reilly GEORGIA POWER CO.
References
NUDOCS 8705280395
Download: ML20214K287 (8)

See also: IR 05000321/1986022

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May 14, 1987

orgia Power Company

TTN: Mr. James P. O'Reilly

Senior Vice President-Nuclear

Operations

P. O. Box 4545

Atlanta, GA 30302

Gentlemen:

SUBJECT: REPORT NOS. 50-321/86-22 AND 50-366/86-22

Thank you for your response of November 17, 1986, to our Notice of Violation

issued on October 17, 1986, concerning activities conducted at your Hatch

facility. We have evaluated your response and found that it meets the

requirements of 10 CFR 2.201. We will examine the implementation of your

actions to correct Violations A, B, and C during future inspections.

After careful consideration of your request that Violation A be withdrawn,

we have concluded, for the reasons presented in the enclosure to this letter,

that the violations occurred as stated in the Notice of Violation. As

described in the enclosure, the NRC has decided to downgrade Violation C

from Severity Level IV to V due to limited safety significance. Additionally,

Violation D is considered licensee identified and will be withdrawn.

Should you have any questions concerning this letter, please contact us.

Sincerely,

(Original signed by A. F. Gibson for)

J. Nelson Grace

Regional Administrator

Enclosure:

Staff Assessment of Licensee

Response

cc w/ enc 1: (See page 2)

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8705280395 870514

PDR ADOCK 05000321

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Georgia Power Company 2 May 14, 1987

f.c w/ encl:

VJ. T. Beckham, Vice President,

/ Nuclear Operation

VH. C. Nix, Site Operations

General Manager

/A. Fraser, Acting Site

QA Supervisor

,/ L. Gucwa, Manager, Nuclear

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Safety and Licensing

bec w/ encl:

RC Resident Inspector

Hugh S. Jordan, Executive Secretary

-Document Control Desk

State of Georgia

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ENCLOSURE

STAFF ASSESSMENT OF LICENSEE RESPONSE

Restatement of Violation A

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10 CFR 50, Appendix B, Criterion V, and the licensee's accepted QA program

(HNP-2, FSAR-17, Section 17.2.5) require that activities affecting quality

I shall be prescribed by documented procedures of a type appropriate to the

circumstances and shall be accomplished in accordance with these procedures.

Hatch procedure 50AC-MNT-001-05, Maintenance Program, requires that

deficiencies or nonconforming equipment noted during maintenance activities

shall be documented and controlled in accordance with 10AC-MGR-004-0,.

Deficiency Control System, and documented on the maintenance work order (MWO)

in " Actual Work Performed" (Block 27). If it is necessary to change the scope

of work during maintenance activities, an MWO will be written to cover the

change.

Hatch Procedure 10AC-MGR-004-05 also requires that a Deficiency Report be

written for deficiencies on nonconforming equipment identified during

maintenance activities.

Contrary to the above:

- The HPCI turbine failed to meet acceptance criteria under maintenance work

order (MW0) No.1-86-3998 on April 30, 1986, and the licensee failed to

write a new MWO to cover an expansion in scope of the maintenance

activities.

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A procedural deficiency was identified during the calibration of a

turbidimeter under MWO 1-84-4872 on May 31, 1986, and the licensee failed

to initiate a Deficiency Report to document the deficiency and ensure

prompt corrective action.

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An investigation of the failure of a fuel pool cooling pump to start

conducted under MWO 1-86-3426 on April 10, 1986, determined a discrepancy ,

between actual and rated full load current. No Deficiency Report was

written on corrective action taken.

Summary of Licensee's Response

The licensee argues that although the events occurred, there were no actual or

potential safety consequences. The licensee stated that the involved plant

personnel erred in not initiating the required MWO to cover changes in

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work scope and that deficiency reports (DRs) were not initiated as required

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because personnel did not clearly understand when a DR was required or who was

responsible for initiating the DR because the DR procedure was not sufficiently

J clear in those areas.

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Enclosure 2

The licensee indicated that Deficiency Report No. 1-86-1201 was written on

November 7, 1986, to address the cited instances and that control of work scope

authorized by a particular MWO would be re-emphasized with the Maintenance

Department in training meetings by December 10, 1986. The licensee states that

prior to the NRC inspection, site Quality Assurance (QA) had identified

inadequacies in the Deficiency Control System procedure (10AC-MGR-004-05). In

addition to resolving the QA concerns, the licensee was revising the procedure

to make it easier for plant personnel to understand when a DR must be initiated

and by whom. Part of this corrective action would be the appropriate training

of plant personnel on the procedure revision. The procedure was scheduled to

be implemented by December 26, 1986.

The licensee requested that Violation "A" be downgraded to an Inspector

Followup Item based on the fact that procedure 10AC-MGR-004-0S was in the

process of revision at the time of the citation due to a licensee identified

problem. The licensee contends that the corrective action for the licensee

identified item would have prevented the cited violation.

NRC Evaluation

For a violation to be considered licensee identified, it must have been

identified by the licensee; fit in a Severity Level IV or V category; be

reported if required; and most importantly, it should not be a violation that

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could reasonably be expected to have been prevented by the licensee's

corrective action for a previous violation.

Contrary to the above requirements, the corrective actions stated in the

licensee's response, i.e., training of maintenance personnel on control of

work scope and the revision of procedure 10AC-MGR-004-0S did not occur until

December 10 and 26, 1986, respectively. The three examples cited in the

violation occurred in April and May 1986, and were not prevented by the j

corrective actions implemented in December.

In addition, a similar violation was cited on December 26, 1984,

(50-321,366/84-46-02), and the corrective actions implemented appear neither

timely nor adequate. The most recent event involving accidental release of

spent fuel pool water appears to be a further indication of a generic failure

of the corrective action program to ensure effective corrective action for

deficiencies identified during maintenance activities.

NRC Conclusion

For the above reasons, the NRC staff denies the licensee's request to downgrade

the violation to an Inspector Followup Item. The three examples cited in the ,

violation occurred approximately six months prior to the implemented corrective I

actions, and do not meet the requirements of Part 2, Appendix C, for licensee

identified violations.

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Enclosure 3

Restatement of Violation 8

NRC Confirmatory Order 7590-01, dated July 10, 1981, required implementation

of NUREG-0737 Item I.C.5, Establishment of Procedures for Feedback of

Operating Experience to Plant Staff. Paragraph 7 of Item I.C.5 requires

that the feedback program functions effectively at all levels.

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Hatch procedure 30-AC-0PS-003, Plant Operations, Section 4.2.3, requires that

the Engineering Department conduct an audit of the functioning of the Operating

i Experience Feedback Program at all levels on a biennial frequency.

Contrary to the above, audits of the functioning of the Operating Experience

Feedback Program at all levels have not been performed and documented by the

Engineering Department.

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This is a Severity Level IV violation (Supplement II).

Summary of Licensee's Response

The licensee noted that it is subsection 8.11.3.4 of 30AC-0PS-003-0S which

requires the biennial audit of the Operating Experience Feedback Program. The

licensee stated that due to personnel oversight, Engineering Department

procedures or instructions were not prepared and approved to perfonn the

,- required audit. The licensee noted that the August 1986, INP0 evaluation

identified (number OE.1-1) that the effectiveness of the existing Operating

Experience Feedback Program was not periodically assessed. A procedure was

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being drafted to establish the criteria for the audit. The licensee committed

to implement a procedure for the Operating Experience Program review by

February 28, 1987. The licensee argues, however, that although the event

occurred, there were no actual or potential safety consequences.

NRC Evaluation

The NRC does not agree with the licensee's statement that the violation had no l

actual or potential safety consequences. The NRC staff noted that in April of ,

1 1985, the licensee was cited for a failure to provide operational experience I

feedback training to maintenance personnel (321, 366/85-07-03). The licensee's i

responses indicated that maintenance personnel would be added to the procedure l

governing operational feedback training (HNP-911), and that operating l

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experience feedback training would be provided to maintenance personnel. l

During the current inspection, over a year later, it was determined that this )

required training had still not been implemented for maintenance personnel. In '

addition, the failure to perform the audits of the functioning of the program

at all levels, as cited above, resulted in this deficiency continuing for an

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extended period of time, and in less than timely corrective action to the 1985 1

violation.  ;

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Enclosure 4

NRC Conclusion

The NRC considers that the licensee's statement that the violation had no

actual or potential safety consequences was not appropriate. The implementa-

tion of program features which assure quality and the prompt correction of

deficiencies are considered essential to plant safety.

Restatement of Violation C

10 CFR 50, Appendix B, Criterion V, and the licensee's accepted QA program

(HNP-2, FSAR-17, Section 17.2.5) require that activities affecting quality

shall be prescribed by procedures of a type appropriate to the circumstances

and shall be accomplished in accordance with these procedures.

Hatch administrative control procedure 50AC-MNT-001-0S, Maintenance Program,

Step 8.6.2, requires that: the results of all inspections and tests performed

shall be documented and further action based on results and the documentation

will become part of the MW0 package.

Contrary to -the above, the licensee failed to document the results of the

preliminary leak rate test associated with MW0s 1-86-5083 and 1-86-5084

concerning repairs on drywell vent valves 1T48-F319 and IT48-F320.

Summary of Licensee's Response

The licensee stated that the cause of the violation was attributed to

i unclear procedural wording that exceeds the intent of the procedure. The

licensee also argues the following points. The procedure was not

intended to transform diagnostic tests into formal tests for which documenta-

tion was required. It was a standard practice for the local leak rate test

(LLRT) personnel to perform a preliminary diagnostic test after valve repair

and reinstallation prior to completing reassembly (i.e., installation and

hookup of valve operator). This diagnostic check was intended to minimize

both labor and radiation exposure by early identification of problems, prior to

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formal LLRT. In the cited case, the diagnostic test was performed subsequent

! to the repair of valves 1T48-F319 and 1T48-F320. Excessive leakage was

apparent, and the valves were removed, repaired and reinstalled as part of the

process of correcting the observed leakage. The fact that a diagnostic test

was performed was not noted on the MWO continuation; thus, the inspector, as

noted in the inspection report, could not determine why the valves had been

removed.

The licensee stated that on November 3,1986, a memo was issued requiring that l

diagnostic tests be noted on an MWO continuation sheet. The licensee concluded ,

that the Maintenance Program procedure (50AC-MNT-001-0S) was over inclusive and l

stated that it would be revised to differentiate between the documentation of

required tests and those which are being performed for diagnostic or other

purposes. The licensee committed to complete this revision by January 10, 1987.

, With regard to Violation "C", the licensee argued that the violation had minor,

if any, safety significance. The licensee requested that, consistent with

the Commission's Enforcement Policy (10 CFR Part 2, App. 2), that the cited

Violation be recategorized as a Severity Level V. The licensee stated that the

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Enclosure 5

literal words of adrinistrative control procedure 50AC-MNT-001-0S were over

inclusive, requirirg diagnostic steps if characterized as a " test" to be

documented. The licensee committed to correct the administrative control

procedure so that only tests which are used to determine operability or to

meet operability criteria are documented. The licensee argued, however, that

diagnostic tests, such as the one identified by the inspection report, are

akin to visual observations of conditions and are not intended to be formally

documented.

NRC Evalut. tion

The NRC staff does not agree with the licensee's statement that formal

documentation would be limited to only tests that determine operability

or meet operability criteria. The American National Standard (ANS) -

3.2/N18.7-1976, which the licensee is committed to in their Quality Assurance

Program (HNP-2, FSAR-17, Appendix A.33), Section 5.2.7, Maintenance and

Modification, requires that means for assuring quality of maintenance and

modification activities (for example, inspections, measurements, tests,

welding, heat treatment, cleaning, nondestructive examination and worker

qualification in accordance with applicable codes and standards) and measures

to document the performance thereof shall be established. ANS-3.2/N18.7-1976,

defines inspections as examination, observation or measurement to determine

the conformance of materials, supplies, components, parts, appurtenances,

systems, personnel performance, procedures, processes or structures to

predetermined requirements. Additionally, the standard defines testing as

performance of those steps necessary to determine that systems or components

function in accordance with predetermined specifications.

As per the committed standard, tests, inspections, observations and/or as the

licensee states diagnostic tests are means for assuring quality'of maintenance

and require documentation.

NRC Conclusion

The NRC accepts the licensee's statement that this single event has minor

safety significance, therefore, the severity level will be changed to V.

Restatement of Violation D

10 CFR 50, Appendix B, Criterion XII, and the licensee's accepted QA program

(HNP-2, FSAR-17, Section 17.2.12) require that measures shall be established to

assure that tools, gauges, instruments, and other measuring and testing devices

used in activities affecting quality are properly controlled, calibrated, and

adjusted at specified periods to maintain accuracy within necessary limits.

Contrary to the above, the licensee failed to assure that torque multiplier

number 391A268517 was properly calibrated or adjusted to maintain accuracy

within necessary limits when used in conjunction with MW0s 1-86-5083 and

1-86-5084. l

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Enclosure 6

Summary of Licensee's Response

The licensee denied the violation. The licensee argued that calibration of

torque multipliers is an issue which had been previously identified by the

licensee as a result of ongoing evaluations related to valve maintenance and

was being resolved at the time of the inspection. The licensee stated that

corrective steps included the review of torquing practices at other plants and

issuance, on November 6,1986, of a Standing Order requiring the use of direct

reading torque indicators with torque multipliers or, when a direct reading

indicator cannot be used, a calibrated torque multiplier or other engineering

means for confinning proper torque.

In addition, a general maintenance procedure on torquing (51GM-MNT-033-05) had

been prepared and was in the review, approval, and validation process. The

licensee stated that this procedure contained requirements similar to those in

the above Standing Order. The procedure was scheduled to be issued by

December 10, 1986.

NRC Evaluation

At the time of the inspection, the week of July 28, 1986, the licensee did not

indicate or provide any ongoing evaluation related to the use and/or calibra-

tion of torque multipliers. If the evaluation was ongoing, the continued

use of non-calibrated test equipment (torque multipliers) until November 6,

1986, a three-month period, appears to be marginal for timely corrective actions.

However, the NRC accepts the licensee's statement that the item was licensee

identified.

NRC Conclusion

For the above reasons, the NRC staff concludes that the violation will be

withdrawn. Our records will be adjusted to reflect the withdrawal.

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