ML20214A227

Submits Results of Evaluation of Util 861231 Response to Violations Noted in Insp Repts 50-321/86-30 & 50-366/86-30. Request to Downgrade Violation A,Example 1 Denied.Response to Violation A,Examples 1,2 & 3 Requested within 30 Days

ML20214A227
Person / Time
Site:	Hatch
Issue date:	05/04/1987
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	James O'Reilly GEORGIA POWER CO.
References
NUDOCS 8705190336
Download: ML20214A227 (9)

See also: IR 05000321/1986030

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May 4, 1987

Docket Nos. 50-321, 50-366

License Nos. DPR-57, NPF-5

Gporgia Power Company

v4TTN: Mr. James P. O'Reilly

Senior Vice President-

Nuclear Operations

P. O. Box 4545

Atlanta, GA 30302

Gentlemen:

SUBJECT: NRC INSPECTION REPORT NOS. 50-321/86-30 AND 50-366/86-30

As discussed in our letter of February 3,1987, you.* response of December 31,

1986, to our Notice of Violation issued on December 1,1986, concernirg activi-

ties conducted at your Hatch facility, has been evaluated. The results of our

evaluation are provided below.

After careful consideration of the bases for your request to downgrade

Violation A, example 1, we have concluded, for the reasons presented in the

enclosure to this letter, that this request is denied. Note that your responso

did not adequately address the corrective actions over the control of special

procedures and the date when full compliance will be achieved. We have also

evaluated your denial of Violation A, examples 2 and 3, and have concluded, for

the reasons presented in the enclosure to this letter, that the violations

occurred as stated in the Notico of Violation.

Your response to Violation B admitted the violation but requested withdrawal of

the violation. Af ter careful consideration of the bases for your request for

withdrawal, we have concluded, for the reasons presented in the enclosure to

this letter, that the violation occurred as stated in the Notice of Violation.

Therefore, in accordance with 10 CFR 2.201(a), please submit to this office

within 30 days of the date of this letter a written statement describing steps

which have been taken to correct Violation A, examples 1, 2, and 3, and

Violation 0 and the results achieved, corrective steps which will be taken to

avoid further violations, and the date when full compliance will be achieved.

The responses directed by this letter and its enclosure are not subject to the

clearance procedures of the Office of Management and Budget as required by the

Paperwork Reduction Act of 1980, PL 96-511.

0705190336 070D04

PDH ALUCK 0D000321

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Georgia Power Company 2 May 4, 1987

We appreciate your cooperation in this matter.

Sincerely,

C W '"At t w ~-

1. 0fi C::

J. Nelson Grace

Regional Administrator

Enclosure:

Staff Evaluation of Licensee

Response to Inspection Report

50-321/86-30 and 50-366/86-30

gc w/ encl:

W . T. Beckham, Vice President.

stI.PlantHatch

C. Nix, Site Operations General

Manager

/A. Fraser, Acting Site QA Supervisor

vl. Gucwa, Manager, Nuclear Safety

and Licensing

Xc w/encI:

RC Resident Inspector

pHughS. Jordan,ExecutiveSecretary

Document Control Desk

State of Georgia

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SDStadler:ht MS1ymfock CAJu11an os T tson GRJep ns LReyes ,)p ,

04/g/87 04/'),/87 04/j/87 04/ 2./87 04/3/87 04/6/87 04//f /87

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3

ENCLOSURE

STAFF ASSESSMENT OF LICENSEE'S RESPONSE

Restatement of Violation A. Example 1

Technical Saecification 6.8.1.a requires the licensee to establish, implement,

and maintain written procedures covering the applicable activities in

Appendix A of Regulatory Guide 1.33, Revision 2. February 1978. Appendix A

of Regulatory Guide 1.33 recommends establishment of procedures to control

contamination and for the performance of safety-related maintenance.

Technical Specification 6.8.1.c requires the Itcasee to establish and

implement procedures for the conduct of surveillance and test activities of

safety-related equipment.

Contrary to the above,

1. The licensee failed to provide adequate procedures to control test i

activities on the 2C emergency diesel generator on Monday, October 6,

and Wednesday October 8, 1986.

Summary of Licensee's Response

The licensee stated that Violation A, Example 1, occurred, but not as stated,

and requested that the violation be downgraded from a Severity Level IV to a

Severity Level V violation. The licensee stated that the special purpose

procedure, 52SP-100386-!E-1-25, Diesel Generator 2C Low Speed Run, was

developed to provide instructions for performing a low speed run of the 2C

diesel generator in order to " break-in" a newly installed turbocharger and that

the procedure was intended to be performed in conjunction with 345V R43-001-25

Diesel Generator Manual Start. The licensee argued that contrary to statements

in the inspection report, procedure 52SP-100386-!E-1-2S was not performed to

meet testing or surveillance requirP,itts of the plant Technical Specification

and, therefore, was not required by Technical Specification 6.8.1.c. The

licensee stated that the procedure was reviewed and approved in accordance with

10AC-MGR-003-05, Rev. 5, which required maintenance department manager approval

and Plant Review Daard review.

The ifcensee agreed that procedure 52SP-100386 !E-1-25 did not include all

necessary prerequisites for. conducting a low speed run of the 2C diesel genera-

tor and that the procedure writer and the technical reviewer did not identify

the discrepancies. Also, the licensee stated that the pre-test brief, as

recuired by AG-MGR-21-0306N, Evolution Pre-Test Orief Requirements, did not

ad(ress the inadequacies of Rev. O of the special purpose procedure or identify '

and resolve misconceptions inheront in Rev. 1 of this special purpose procedure.

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Enclosure 2

The licensee expressed a strong belief that Example 1 was not a Severity

Level IV violation, i.e., failure to meet regulatory requirements that have

more than minor safety or environmental significance, and that the limited

safety significance of Example 1 of the violation was such that it warranted

being downgraded to a Severity Level V.

NRC Evaluation

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

Specification 6.8.1.c applies only to the testing or surveillance requirements

of the plant Technical Specifications. Technical Specification 6.8.1.c

requires the establishment and implementation of procedures for test activities

of all safety-related equipment. This requirement is not limited to surveil-

lance test activities required by Technical Specifications. Based on the

licensee's comments, the NRC staff believes that the licensee should examine

its appItcation of Technical Specification 6.8.1.c and confirm in the response

to this letter that procedures are established and implemented for the cor. duct

of surveillance and test activities of safety-related equipment.

The test in question was a special test of an emergency diesel generator

following major maintenance. The diesel generator is safety-related. The

special test of 2C diesel generator was first attempted on Monday, October 6,

1986, but contradictions between the special test and operating procedures

resulted in a delay. These procedure conflicts and the resulting operator

confusion should have been resolved prior to the test attempt and in the

pre-test briefing. The test )rocedure was revised by the licensee. PNSC

reviewed and approved the rev'sion, and the test was rescheduled two days

later. The licensee's response to the violation admits that both the revised

test procedure and the pre-test briefing were deficient. During the second

test, the inspectors observed the following procedure and operator knowledge

deficiencies:

- The vendor directed operators to depress the voltage trip button and then

to reset it at full RPMs. This was done to prevent overheating of the

field at low RPMs, but was not in the procedure and was not covered in the

pre-test briefing.

- The special procedure contained a caution statement to closely monitor the

cooling water pressure because the low pressure trip had been defeated.

The procedure did not specify a minimum acceptable cooling water pressure,

and the operator had not been briefed on a limit.

- The diesel generator oil level was incorrectly measured prior to the start t

of the test ar.d at 800 RPMs was discovered to be approximately 100 gallons

low. This resulted in a two-hour shutdown to add oil.

- The normal operating procedure contained a caution statement against

operating a diesel generator at low loads for exter 'ad periods of time.

Although this special test required extended diesel operation at reduced

RPHs and loads, the special procedure did not contain this caution, and

the operators were unaware whether the caution was applicable.

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l Enclosure 3

1

The above deficiencies in the revised procedure and associated pre-test

briefings had at least a potential to result in a degradation of the diesel's

performance which would not be readily detec able in operability testing. The

l procedure and pre-test briefing should have been adequate for the first test

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dttempt, and most certainly should have been resolved prior to the second

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attempt. The testing of safety-related equipment under vendors' direction does

not relieve management of the responsibility for ensuring continued integrity

l cf that :"luipment.

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HRC Conclusion

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For the above reasons, the NRC staff denies the licensee's request for down-

1. grade of Violation A, Example 1, from a Severity Level IV to a Severity

i Level V.

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Restatement of Violation A, Example 2

Technical Specification 6.8.1.a requires the licensee to establit.h. implement,

and maintain written procedures covering the applicable activities in

i Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A

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of Regulatory Guide 1.33 recomends establishment of procedures to control

contamination and for the performance of safety-related maintenance.

Plant Procedure 62RP-RAD-017-0 Release Surveys for Trash and Materials Leaving

Operating Duildings, requires that the Health Physics Technician at C-52 is

responsible for ensuring that all persons exiting the control building use the

monitors upon exit.

Contrary to the above,

2. The requirement that personnel use the monitors when exiting the control

building and that the HP technician ensure this is accomplished was not

met in that on October 9,1986, a contractor was observed exiting the RCA

at Control Point C-52 without using the monitor.

l Sumary of Licensee's Response

The licensee stated that the ins)ection report contained insufficient infor-

mation to confirm or deny the alleged violation and therefore, denied the

violation. The licensee argued that under certain circumstances, it was

clearly permissible to bypass the monitor at portal C-52 without frisking. The

licensee further stated that if the contractor in question had received a

contamination alarm while frisking and had been refrisked by Health Physics and

releasedt that the individual could leave the area without refrisking.

The licensee contended that as far as they could determine, the NRC inspector

did not take action to stop the violation or the subject individual after the

event occurred and Health Physics supervision was not notified of the alleged

violation, and therefore, was not able to investigate at or near the time of

the event,

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Enclosure 4

NRC Evaluation

The inspector informed the three Health Physics technicians present at the C-52

portal of the occurrence immediately. The contractor in question had already

exited the area and could not be located by the inspector. The technicians

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stated that they had not noticed the occurrence, which is a violation of Plant

Procedure 62RP-RAD-017-0. This procedure requires that the technician at C-52

ensure that all persons exiting the control building use the monitors upon

i exit.

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The technicians further stated that all personnel exiting the controlled area

must be frisked prior to exit. It appears to the inspector that the technicians

on duty at the control point would have been aware of the scenario described

in the licensee's response, if it had occurred. It was clear to the ins,ector

that the technicians on duty were not aware of the contractor not fris .ing

,

prior to exit. Additionally, even though the inspector could identify the

l contract finn that employed the individual, the technicians failed to initiate

j any action to identify the individual involved to prevent recurrence.

NRC Conc 7usion

For the above reasons, the NRC staff concludes that the violation occurred as

stated.

Restaterient of Violation A. Example 3

Technical Specification 6.8.1.a requires the licensee to estaolish, implement

and maintain written procedures covering the applicable activities in ,

Appendix A of Regulatory Guide 1.33, Revision 2. February 1978. Appendix A of l

Regulatory Guide 1.33 reconinends establishment of procedures to control ,

contamination and for the performance of safety related maintenancu.

1

Preventive Maintenance Procedure 52PM-MNT 005-05, Revision 3. Limitorque

Valve Operator Inspection, step 7.6.6.13, states in part, perform limit switch

adjustment in accordance with 52GM-MNT-017-05 Linitorque Valve Operator Setup

and Test. Procedure 52GM-HNT-017-05 was replaced by Procedurn 52GM-MEL-022-05

on February 1986. Procedure 52GM-MEL-022-05 contains the limit switch

adjustment instruction.

Contrary to the above.

3. In August 1986, for Maintenance Work Orders 2 86-2136, 2 86-2137 and

2 86-2154, the licensee failed to perform the required limit switch

adjustments in accordance with Preventive Maintenance Procedure

52PM MNT-005 05.

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Enclosure 5

Sunmary of Licensee's Response

The licensee denied the violation. The licensee admitted that as stated in the

Notice of Violation, limit switch adjustments were not made in accordance with

I 52GM-MNT-017-05. Limitorque Valve Operator Setup and Test, as set forth in

i step 7.6.6.13 of Rev. 3 of 52PM-MNT-005-05, Limitorque Valve Operator Inspec-

l tion. The licensee argued however that, even though step 7.6.6.13 states

"perfom limit switch adjustments in accordance with 52GM-MNT 017-OS ...", the

intent of the procedural step was to require limit switch adjustment only if

necessary. The licensee maintained that Maintenance personnel had deterrained

that limit switch adjustment was not necessary since a satisfactory functional

test was performed per 62PM-MNT-005-OS to verify proper limit switch operation

and therefore, the intent of the procedural requirement had been met.

The licensee also noted that the Hatch Procedures Upgrade Program (PUP) wot;ld

,

result in development of a large number of very detailed procadures. The

l licensee maintained that these procedures would be thoroughly validated (as

recuired by the PUP) to ensure they are technically adequato, user friendly.

l anc completely incorporate all regulatory licensing requirenents. The licensee

stated that Georgia Power is totally consnitted to obtaining and following

excellent procedures; however, major improvement efforts were seen as a source i

of a relatively large number of noncompliance issues, which the licenseu '

contended had inappropriate and negative implications on their performance,

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l The licensee stated that procedure 52PM MNT-005-05 was revised on October 29,

1986, in order to clarify further the procedural requirement for perfoming

limit switch adjustments and that the procedure now requires that "if limit  !

switches do not nuko and break as requured, limit switch adjustnents must be

made per approved plant procedure."

NRC Evaluation

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The NRC staff has carefully reviewed the licensee's response and has concluded

that the licensee did not prnvide any information that was not already

considered in determining the violation. The licensee stated that Maintenance

personnel detemined that limit switch adjustment was not necessary sinco a .

satisfactory functional test was perforned per 52PM-MNf 005 05 to verify proper

limit switch operation. The functional test the licensee cited does not

fulfill the same function as step 7.6.6.13 of Procedure 52PM MNT-005 05, '

Revision 3. Step 7.6.6.13 requires the limit switch to be adjusted by using

procedure 52GM MEL 022 05. This procedure takes certain neasurements that the

licensee's functional test does not requiro. The procedure verifies that the ,

rotor operates prior to 1/8 inch stem travel, in the open and closed direc-

tions, and if not, it requires adjustment. It also requires the documentation

and observation of the internittent gear shaf t's direction of rotation.

Proceduru $2GM MEL 022 05 also his a precaution on electrical saf ety that

Procedure 52PM MNT 005 05 dccs nn contain. Both proceduros require the -

valves' closing and opening times be measured, but 62GM MEL 022 05, requires

the test be run three tihes, where the other procedure only requires the timing

to be run once. Additionally, 5 CGM MEL 022 05 has instructions on how to

adjust the rotors if the valve ooes not pass the timing test. Both procedures

were lacking adequato acceptance criteria for valve closing / opening timing,

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Enclosure 6

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The licensee also states, through the Procedure Upgrade Program, that the

procedures will be thoroughly validated to ensure they are technically

adequate, user friendly, and Coc.pletely incorporate all regulatory licensing

requirements. Procedure 52PM-MNT-005-05. Rev. 3, which was cited in the

violation, was not a PUP procedure; however, Rev. 4 was an upgrade procedure

and it also required the limit switch adjustnents per Procedure 52GM-MEL-022-05,

step 7.5.2.14 As the licensee stated, these procedures were validated to

ensure technical adequacy, and the Plant Hatch validation process must have

determined that limit switch adjustments per Procedure 52GM MEL-022-05 were

required to ensure proper valve operations.

NRC_ Conclusion

For the above reasons, the fiRC staff concludes that the violation occurred as

stated. ,

! Re'.tatement of Violation D

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Unit 1 Technical Specifications 3.7,0.1 and 4.7.0.1 and Unit 2 Technical

Specifications 3.6.3 and 4.6.3.3 require that primary containnent isolation

valves listed bu operable, and that the isolation times shall be demonstrated

to be within the required limits.

Unit 2 Technical Specification 4.0.5 requires that inservice testing of ASME

Code Class 1, 2, and 3 valves shall be perforned in accordance with Section XI

of the ASME Duiler and Pressure Vessel Code except where specific written

relief has been granted by the Conmission pursuant to 10 CFR 50.55a(g)(6)(1).

ASHC Section XI defines stroke time as the tine interval from initiat1on of the

actuating signal to the end of the actuating cycle. The E. 1. Hatch Pump and

Valve Test Plan also defines full-stroku time as that tine interval from

initiation of the actuating signal to the end of the actuating cycle.

Contrary to the above, the licensee does nut stroke tine test power operated

valves from initiation of the actuating signal to the end of the actuating

cycle as required by Technical Specifications and ASME Section XI, and the

licensee has not received specific written relief from the requirements of the

ASME Code that requires stroke time testing from initiation of the actuating

,

signal to the end of the actuating cycle. ,

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l Sumary of Licensee's Response

The licensee admitted that the event, occurred; however, the licensee stated

that tho event had no safety consequences and requested withdrawal of the

violation. The licensee argued that the contribution of unclear Code require-

i nwnts coupled with a conscious, good faith of fort to comply with a reasonable

interpretation of those requirements would make the imposition of a violation

in this uniquo circumstance an unfair application of f4RC's Enforcenent Policy  ;

(10 CFR 2 App, C). The licensee bulievel that since it had attempted to

interpret and resolve the Code requiren'ents on stroke time testing and had

concluded that light to-light timing measurenents were permissible, that at the  !

timo of the alleged violation the Code connitnent as presently construed by the

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Enclosure 7

NRC was not a legally binding requirement. The licensee stated that viewed

relative to Code interpretations prior to issuance of the Notice of Violation,

GPC's interpretation of Code requirements conflicted with that of the NRC;

,

i.e., the " commitment" was subject to different interpretations; and upon NRC's

l specific notification, GPC innediately adopted the NRC interpretation.

NRC Evaluation

The licensee does not stroke time test power operated valves as required by

Technical Specifications and ASME Section XI. The licensee stated in their

response that the violation was the result of a misinterpretation of the ASME

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Code requirements. The inspector conside-s the licensee's initial interpreta-

tion to be in the non-conservative direction in that the time required tor a

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l valve to stroke using the " light-to-light" method will almost always be less

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than the time from the initiation of the actuating signal to the end of the

l actuating cycle, as required by ASME Section XI. This misinterpretation

was initially identified by the licensee in a Quality Assurance Audit in

November 1984, anu again by the f;RC in July 1986, as documented in Inspection

Report No. 50-321,366/86-22. It does not appear to the NRC staff that the

licensee took any prompt corrective action to resolve the issue until a

l violation was imminent.

l NRC Conclusion -

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l For the above reasons, the NRC staff concludes that the violation occurred as

stated,

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