IR 05000321/1986028

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

ML20215L089
Person / Time
Site:	Hatch
Issue date:	10/17/1986
From:	Holmesray P, Ignatonis A, Nejelt G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20215L078	List: IR 05000321/1986028 ML20215L075 ML20215L085
References
50-321-86-28, 50-366-86-28, NUDOCS 8610280462
Download: ML20215L089 (9)

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UNITED STATES

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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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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).

of the control Licensee Action on Previous Enforcement Matters (92702)

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:

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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

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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)

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

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(ESF) systems were confirmed operabl verifying the following: Accessible valve flow path aligrment, power supply

' 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

'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 ABNs85-605, Sup.3 and 86-140 did not reference drawing H-16274, Rev. 0 with ABNs86-140 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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