ML20057E058

Responds to NRC Re Violations Noted in Insp Rept 50-366/93-13.C/As:procedure Will Be Used to Correct set-up of Actuators for Valves During Next Outage of Sufficient Duration

ML20057E058
Person / Time
Site:	Hatch
Issue date:	09/28/1993
From:	Beckham J GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9310070213
Download: ML20057E058 (4)

Text

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. , Georgia Power Company

/ 40 invemets Center Parkway

• Post Offee Box 1295 Birmingham. Alabama 35201 Telephone 205 877 7279

. L J. T. Beckham, Jr. Georeia O Power Vice Presdent - Nuclear Hatch Proyect -

Ve Southein tM:lic SWem September 28, 1993 Docket No. 50-366 HL-3469 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Edwin I. Hatch Nuclear Plant - Unit 2 Reply to a Notice of Violation Gentlemen:

In response to your letter dated August 30,1993 and in accordance with the requirements of 10 CFR 2.201, Georgia Power Company (GPC) is providing the enclosed response to the Notice of Violation associated with Inspection Report 93-13. In the enclosure, a transcription of the NRC violation precedes GPC's response.

Sincerely,

' 7bb a

. T. Beckham, Jr.

JKB/cr 1

Enclosure:

Violation 93-13-01 and GPC Response I

cc: Georzia Power Company Mr. H. L. Sumner, General Manager - Nuclear Plant NORMS l

U.S. Nuclear Regulatorv Commission. Washineton. D.C.

l Mr. K. Jabbour, Licensing Project Manager - Hatch  !

U.S. Nuclear Regulatory Commission. Region 11 Mr. S. D. Ebneter, Regional Administrator Mr. L. D. Wert, Senior Resident Inspector - Hatch l

l 060033 I

NV 9310070213 930928 I 5 hDR ADOCK 05000366 I' k

PDR (f

l Enclosure Edwin I. Hatch Nuclear Plant - Unit 2 f Violation 93-13-01 and GPC Response t

i Violation 93-13-01 Hatch Unit 2 Technical Specification 6.8.1.a requires that written procedures be established, and maintained as recommended in Appendix "A" of Regulatory Guide 1.33, i Revision 2, February 1978.

Section 9 of Regulatory Guide 1.33 recommends procedures for maintenance activities. ,

Implicit in these requirements is that the procedures are adequate.

Contrary to the above, there was inadequate procedural guidance for maintenance activities .

t on two Unit 2 Primary Containment Isolation Valves,2B31-F019 and 2B31-F020. There were no specific written instructions or guidance explaining how the maintenance activities should be conducted or that the valve actuator should be adjusted following maintenance activities. Also, there was no procedural guidance delineating valve actuator adjustment t acceptance criteria to ensure the valves would close as required. As a result, the valve i actuators were not properly adjusted to ensure valve closure for all reactor pressure t conditions. [

This is a Severity Level IV violation (Supplement 1).

1 RESPONSE TO VIOLATION 93-13-01 Admission or denial of the violation:

The event occurred as described in the Notice of Violation.

Reason for the violation:

This violation was caused by less than adequate procedural controls. Specifically, a procedure did not exist to set-up the type of actuator used on valves 2B31-F019 and 2B31-F020. Maintenance activities previously performed on valves 2B31-F019 and 2B31-F020 during the fall 1992 refueling outage used procedure 52CM-MME-Oll-OS, Gate and Globe Valve Repair. However, this procedure was developed as a generic procedure and did not provide specific setup requirements for these valves. Consequently, the valve actuators were not adjusted to close against full reactor pressure, as required by their reactor coolant pressure boundary isolation design function, following maintenance activities in October 1992.

HL-3469 E-1

1 Enclosure Viofation 93-13-01 and GPC Response l

Corrective steps which have been taken and the results achieved-  :

As a result of this event, the following corrective actions were taken:

1. Valves 2B31-F019 and 2B31-F020 were declared inoperable on 7/21/93, and as a conservative measure, valve 2B31-F020 was deactivated and secured in the closed .

position by use of a gagging device.  !

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2. A review of other reactor coolant pressure boundary solation valves was performed.

Only two other isolation valves with the same type of actuators as valves 2B31-F019 and 2B31-F020 were found. These were Unit i valves IB31-F019 and IB31-F020.

As a conservative measure, these valves were declared inoperable, and valve IB31-F020 was deactivated and secured in the closed position by use of a gagging l desice.

3. Procedure 52CM-MME-035-OS, " Fisher Diaphragm Actuator Type 667," has been developed for setting up actuators of the make and model used on isolation valves IB31-F019, IB31-F020, 2B31-F019, and 2B31-F020. The procedure has been approved for validation as part of the normal procedure validation process per administrative control procedure 10AC-MGR-003-OS, " Preparation and Control of Procedures." The procedure will be used to correct the set-up of the actuators for i valves 2B31-F019 and 2B31-F020 during the next outage of suflicient duration. The procedure will be issued effective following its validation and the incorporation of any changes found necessary.

l Valves IB31-F019 and IB31-F020 were closed as a conservative action. Prior to returning them to service, a leakage test will be performed to ensure each valve is capable of closing against full reactor pressure. This will require opening one valve at a time in order to check the leakage past the closed valve. Should one or both valves fail the leakage test, the valves will be closed, and valve IB31-F020 will be deactivated and re-gagged as required by the Unit 1 Technical Specifications. If necessary, their actuator set-up will then be corrected using procedure

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52CM-MME-035-OS during the next outage of suflicient duration.  !

Corrective stens which will be taken to avoid further violations:

I No further corrective actions are necessary.

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Enclosure -  !

Viofation 93-13-01 and GPC Response Date when full comoliance will be achieved: i Full compliance was achieved at 2035 CDT on July 21,1993 when valve 2B31-F020 was declared inoperable, deactivated, and secured in the closed position by use of a gagging i device as required by the Unit 2 Technical Specifications.

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