ML20084H100

Responds to NRC Re SALP Repts 50-321/84-01, 50-366/84-01,50-424/84-01 & 50-425/84-01.Occurrences Contributing to Low Ratings in Maint,Operations & QA Areas Clarified

ML20084H100
Person / Time
Site:	Hatch, Vogtle, 05000000
Issue date:	04/05/1984
From:	Beckham J GEORGIA POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20084H079	List: ML20084H100
References
NED-84-178, NUDOCS 8405070447
Download: ML20084H100 (6)

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Georgia Power J. T. Beckham, Jr.

Rll " ## #A" v,m em 4.- ma n, n.m wm, nuc o c * * " NED-84-178 April 5, 1984 U. S. Nuclear Regulatory Cmmission

REFERENCE:

Office of Inspection and Enforc s ent RII: JPO Region II - Suite 2900 50-321/50-366 101 Marietta Street, NW 50-424/50-425 Atlanta, Georgia 30303 IER 84-01 SALP A'ITENTION: Mr. J e es P. O'Reilly GERFLEMEN:

Your letter of March 6,1984, transitted the Systaatic Assessment of Licensee Performance (SALP) Board Report for Georgia Power's nuclear progrm. We have reviewed that report and have the following coments concerning your evaluation.

In its introduction, the SALP report is described as "an integrated NRC staff effort to collect available observations of licensee performance on a periodic basis and evaluate performance based on these observations." We believe your evaluation of our facilities focused primarily on negative aspects of our perfomance. By not providing a balanced coverage of all our actions, an erroneous impression may be given to the public. We suggest the public would be provided a more balanced perception if a more cmprehensive picture of what occurred during the reporting period were included.

Further, a discussion of the actual safety significance of any its reported in the SALP should be provided.

In reviewing the SALP report for Plant Hatch activity, there were four occurences which primarily contributed to the low ratings in the -

maintenance, operations, and quality assurance areas. Your review of these occurences pointed out many of the problems encountered by these departments; however, in providing your analysis you smetimes neglected reporting many of GPC's corrective actions. In an effort to clarify the record and present the total picture, each of four occurrences is listed in the attachnent to this letter, along with a brief statment of the key events, the relevent dates, and a notation indicating whether or not - the information was included in the SALP report.

See of the recent organizational changes at Plant Hatch were mentioned but insufficient attention was paid to the effect of those changes. It is also significant to note that not all of - the positions in the .new organization were filled for the entire evaluation period. 'Itere have - also been changes in the OA organization which have strengthened its role in plant activities.

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l GeorgiaPower d U. S. Nuclear Regulatory Cmunission Office of Inspection and Enforcenent Atlanta, Georgia April 5, 1984 Page 'IWo In reviewing the SALP report for Plant Vogtle activity, it should be noted that the NRC's guidance for subnittals allows for incorporation of material by reference. 'Ihis fact justifies the frequent references to the Vogtle Final Safety Analysis Report used in the Vogtle Envirorsnental Report. It should also be noted that the Vogtle Vice President, the Vogtle Plant Manager, and the Vogtle Site CA Supervisor were not included in the initial NRC distribution of the SALP report.

While we disagree with certain aspects of the methodology and sane of the findings and implications of the SALP report, we appreciate this opportunity to attenpt to correct the public perception. As stated in our letter of March 15, 1984, we do not see the need for a public meeting between our staffs on this subject. If you have further questions, please contact this office.

.Very truly yours, p  :

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J. T. Beckhan, Jr.

Attachnent MJB xc: D. O. Foster G. Bockhold H. C. Nix, Jr.

Senior Resident Inspectors 700775

I' GeorgiaPower d Attachnent to April 5, 1984 letter to Region II WEID OVERLAY EVENT DNIE SALP NRC found steps 19, 20 and 23 had been 1-19 Yes signed off without steps 17,18, and '

21 being signed off GPC had not followed HNP-34 1-19 Yes Personnel were counseled 2-16 No All steps in procedure were cmpleted 2-16 No Procedure was technically correct all All No the time 7007F5 -

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. Georgia Powerkh MISPOSITIONED VALVES EVENP DATE SALP Violations for improper valve alignnents 11-2-82 Yes 2-18-83 Yes 2-23-83 Yes 5-5-83 Yes Drafted administrative control systen 9-30-83 No for locked valves:

tracks all changes in locked valve position conducts audit of 1/3 of the valves monthly 1

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GeorgiaPower d ROD MANIPUIATION l

EVENT DA'IE SALP 1

Consensus decision for initial rod movments 7-14 Yes Proper procedure cmpliance after rod out of 7-14 No squence Personnel reoved frm duty 7-14 No Plant managment conducted training session 7-14 No Managment investigation 7-14 No Standing Orders issued 7-15 No Shift Duty presentations 7-16 No STA/ Operator counseled '7-18 No Briefing to all supervisors and above 7-27 No Rod movment procedure revised 8-4 No simulator training in lessons learned 9-30 Yes Special FSAR analysis training 9-30 No STA role training 9-30 No Philosophy of Operations in training 9-30 Yes 4

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F 1 GeorgiaPower d CABLE TRAY EVENP DATE SALP NRC Resident raised cable tray issue 2-15 Yes OB/QC involvment began 2-25 No Site managment meeting for corrective action 3-2 No Bechtel and Southern Services notified 3-3 No Site work started to repair cable trays 3-4 No Initial GPC inspector training cmpleted 3-6 No Initial evaluation of discrepancy 3-16 No Quality Assesment Tem formed 3-17 -No Additional Inspectors training empleted 3-20 No Cable tray restoration project organization 3-23 No formed New administrative controls for all maintenanco 3-31 No activities impleented:

Forman/ contractors emplete forms Forman/ contractors walkdown systs Special cable tray review task force 4-21 No NRC reviewed program and acknowledged 5-11 No improvements NRC violation and civil penalty 6-2 Yes All accessible safety probles corrected ' 8-1 Yes Drafted new Deficiency Report which helps in 8-31 No prmpt evaluation Lessons learned in training 9 No other maintenance and modifications 9-30 No progres reviewed Quality Assessment Tem findings 10-5 No 700775