ML20212Q669

Responds to NRC 870306 Ltr Re Violations Noted in Insp Repts 50-321/87-02 & 50-366/87-02.Violations Re Failure to Perform Integrated Testing of Drywell Pneumatic Sys to Demonstrate Operability Denied for Listed Reasons

ML20212Q669
Person / Time
Site:	Hatch
Issue date:	04/13/1987
From:	Gucwa L GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
1270C, SL-2272, NUDOCS 8704240004
Download: ML20212Q669 (5)

Text

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Georgia Power Company l 333 Piedmont Avenus

/Jianta, G:orgia 30308 T4lephone 404 526-6526

, Maihng Address:

Fbst C,ffice Box 4545 Atlanta, Georgia 30302 Georgia Power L T. Gucwa the southem ettnc system Manager Nuclear Safety and Licensing SL-2272 1270C X7GJ17-H120 April 13, 1987 U.S. Nuclear Regulatory Commission ATTN

Document Control Desk Hashington, D.C. 20555 PLANT HATCH - UNITS 1 AND 2 OPERATING LICENSE NOS. DPR-57, NPF-5 INSPECTION REPORT NOS. 50-321/87-02 AND 50-366/87-02 Gentlemen:

Pursuant to the provisions of 10 CFR Section 2.201, Georgia Power Company is providing the enclosed response to the Notice of Violation associated with inspections conducted at Plant Hatch during the period January 24 - February 20, 1987. NRC Inspection Report Nos. 50-321/87-02 and 50-366/87-02 (transmitted by letter of March 6, 1987) identified an apparent failure to adequately test certain pneumatic systems.

Enclosure 1 is a reproduction of the Notice of Violation, and Enclosure 2 is Georgia Power Company's response. If you should have any questions in this regard, please contact us at any time.

Sincerely, f&=

L. T. Gucwa

Enclosures:

1. NRC Notice of Violation

2. Georgia Power Company Response MJB/lc c: Georoia Power Comoany U.S. Nuclear Regulatory Commission Mr. J. P. O'Reilly Dr. J. N. Grace, Regional Mr. J. T. Beckham, Jr. Administrator GO-NORMS Mr. P. Holmes-Ray, Senior Resident I Inspector-Hatch 8704240004 870413 PDR ADOCK 05000321 0{

G PDR l

t Georgia Pon'er A ENCLOSURE 1 )

NOTICE OF VIOLATION GEORGIA POWER COMPANY PLANT HATCH - UNITS 1 AND 2 LICENSE NOS. DPR-57, NPF-5 INSPECTION REPORT NOS. 50-321/87-02 AND 50-366/87-02 MARCH 6, 1987 YIOLATION 50-321/87-02-01 Unit-1 Technical Specification (TS) 6.8.1.a requires written procedures shall be established, implemented, and maintained covering the activities referenced for applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978.

Appendix "A", Section 8.b of Regulatory Guide 1.33, Revision 2, February 1978, requires that specific procedures for surveillance test (i.e., functional testing) should be written concerning containment isolation functions.

Unit-1 TS 1.0 definition 0 "A logic system functional test means a test of all relays and contacts of a logic circuit from sensor to activated device to insure that components are operable per design intent. Where practicable, action will go to completion; e.g., pumps will be started and valves opened."

Contrary to the above, as of February 20. 1987, no procedures ~were established to verify the activated devices for the following cases:

1. There was no verification of the automatic actuation of the valves (e.g., 1PS2-F875, -F876, -F877, and -F878) to ensure the transfer of non-interruptable service air from the -plant instrument air' system to the nitrogen inerting system, upon loss of instrument air. The non-interruptable service air supplied a number of primary containment isolation valves specified in TS Table 3.7-1 (e.g., IP33-F002, -F003,

-F011, and -F014).

2. The integrated operation of the drywell pneumatic system was not tested, although portions of this system (e.g., flow transmitter and timer) were tested. There was no verification of the automatic actuation of the drywell pneumatic system isolation valves (e.g., 1P70-F004, -F005,

-F066, and -F067) in the event of a continuous high flow for greater than 10 minutes indicating a drywell pneumatic downstream header rupture.

This is a Severity Level V violation (Supplement I).

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GeorgiaPower A ENCLOSURE 2 RESPONSE TO NOTICE OF VIOLATION GEORGIA P0HER COMPANY PLANT HATCH - UNITS 1 AND 2 LICENSE NOS. DPR-57, NPF-5 INSPECTION REPORT NOS. 50-321/87-02 AND 50-366/87-02 MARCH 6, 1987 RESPONSE TO VIOLATION 50-321/87-02-01 Admission or Denial of alleaed violation:

For ease of consideration the response is split into the constituent cases cited.

Case 1:

The proposed violation concerning the failure to verify the automatic transfer from instrument air to the nitrogen inerting system upon loss of instrument air is respectfully denied for the following reasons:

a. The plant instrument air system is designed and operated in accordance with the system description provided in Section 10.11 of the Unit One Final Safety Analysis Report (FSAR). As stated in the FSAR, the service and instrument air receiver capacity is adequate to supply instrument air to vital equipment for a period not less than 10 minutes in the event of air compressor failure. Vital components, including valves listed in the proposed violation, are also provided with air accumulators sized for a minimum of five evolutions of the valve. .

b. The crosstie between the instrument air system and the nitrogen system is provided as a backup but is not required to ensure proper primary containment valve operation in the event of a design basis accident-and concurrent air compressor failure.

c. The reference to Regulatory Guide 1.33 in the proposed violation is not appropriate in that the 1PS2 valves listed in the violation do not perform a primary containment isolation function. Furthermore, the IP52 valves are not listed in Table 3.7-l ~ of the. Unit One Technical Specifications. We believe that the 1P33 system valves listed in the proposed violation are fully and properly tested in accordance with Technical Specifications.

d. Since the IPS2 valves listed are not required for safe unit operation and/or shutdown and are not Technical Specification related, a reference to Unit One Technical Specification 1.0 definition 0 is not appropriate.

1270C E2-1 4/13/87 700775

4eorgiaPowerd ENCLOSURE 2

[r RESPONSE TO NOTICE OF VIOLATION i

Case 2:

.The proposed violation concerning the . failure to perform integratedz testing of the drywell pneumatic system to demonstrate operability (isolation-valves IP70-F004, -F005, -F066, and -F067) is respectfully denied for the ,

following reasons:

a. While the: valves are in a location close to. the containment, and therefore can be used to isolate the Primary Containment, they are ' not part of the Primary Containment Isolation System (PCIS). As such, when the PCIS receives an isolation signal (corresponding to any of the PCIS '

valve Groups 1 through - 5) the referenced P70. valves do not- close or -

isolate the Primary Containment. The valves ~ are boundary valves to {

primary containment and as such are tested per Table 3.7-4 of the Unit-One Technical Specifications. Valves that do perform an. automatic Primary Containment isolation function' are defined .i n the Uni t One .

Technical Specifications Section 3.7.D, Table 3.7-1. This table l clarifies hich valves are to be tested as part of the PCIS. The 'l surveillance requirements for the PCIS valves are listed in - Section 4.7.D of .the Unit One Technical Specifications _ and none of the valves in question are listed in Table 3.7-1.. Also, these valves do not fall in

' the category covered by Section 8.b.2.b of Regulatory Guide 1.33, Rev 2.

in that the IP70 valves listed,in the Notice of Violation do not perform an automatic primary containment isolation . function.

, It is important to note that safety related components in; the drywell

that require pneumatics for operation are equipped with ~ accumulators to mitigate the effects of a downstream rupture. The system is a seismic category I structure. It is also worth noting that the design' of the

system is such that the pressure is always . higher outside containment than inside. Therefore, any leakage, given a rupture,

would - be into containment.

b. The system logic cited in the violation is in place to cause isolation

of the drywell pneumatics in the event that a rupture of the downstream i

process piping should occur. The safety function of -the drywell pneumatics is to provide motive power to various valves. Accordingly valves P70-F004, F005, F066, and F067 are designed to remain open post LOCA (i .e. , no_t i sol ate) . The headers were split to provide additional-redundancy of drywell pneumatic supply. The addition of the cited isolation logic was part of prudent engineering design and not ' because of regulatory requirement.

1270C E2-2 4/13/87 700775

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Georgia power ENCLOSURE 2 RESPONSE TO NOTICE OF VIOLATION If a downstream rupture of the process piping is assumed to occur, and the P70 logic failed to isolate the header, there are other indications available to indicate to the operators that the valves need to be shut.

For example, the pressure switch for the drywell pneumatics header alarms in the Main Control Room. The operations personnel could take manual actions and close the valves by using the remote manual operation circuitry. This circuitry is independent and is tested to ensure proper functioning.

c. The isolation logic for the P70 system contains timers which are set for 10 minutes. This period of time, which is consistent with that historically allowed by the NRC for operator action, would enable the operators to-take corrective actions to mitigate the consequences of the process pipe. rupture. The indicators which display in the Main Control Room would alert the operations personnel that a downstream rupture occurred and to isolate the line by remote manual means. There is no safety basis for the timer.

d. The automatic isolation funct',n of the valves was demonstrated under Design Change Request 81-lll's Functional Test. The valves are Deriodically tested using a normal surveillance procedure. The valves are proven operable once a quarter under Procedure 34SV-SUV-008-lS, Ser tion 7.1.1. Although no testing, except local leak rate and stroke tiue, is required per Hatch Unit One Technical Specifications or Regulatory Guide 1.33, the individual testing of the valves and their associated instrumentation is an indicat:on of good operating practice.

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1270C E2-3 4/13/87 j

TC3775