ML20069E091

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Responds to NRC Re Violation Noted in IE Insp Repts 50-321/82-38 & 50-366/82-36.Corrective Actions: Qualifications of Personnel Conducting Type C Leak Tests, Per HNP-1-3952-E,reviewed & Found Acceptable
ML20069E091
Person / Time
Site: Hatch  Southern Nuclear icon.png
Issue date: 01/26/1983
From: Gucwa L
GEORGIA POWER CO.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20069E083 List:
References
NED-83-057, NED-83-57, NUDOCS 8303210464
Download: ML20069E091 (2)


Text

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REFERENCE:

Office of Inspection and Enforcement RII: JPO Region II - Suite 2900 Inspection Report Nos.

101 Marietta Street, NW 50-321/82-38 Atlanta, Georgia 30303 50-366/82-36 A'ITENTION: Mr. James P. O'Reilly GENTLEMEN:

The following information is subnitted in response to I&E Inspection Report 50-321/82-38 and 50-366/82-36 concerning the inspection conducted by Mr. Frank Jape on November 16-19, 1982:

VIOIATION:

Technical Specification 6.8.1.C requires that licensee establish, implement and maintain written procedures which will adequately accomplish surveillance and test activities of safety related equipnent.

Technical Specification 6.8.2 requires that the procedures of 6.8.1.C will be reviewed by the PRB and approved by the plant manager prior to implementation and reviewed periodically.

Contrary to the above, HNP-1-3952-E, Revision 13, does not identify all valve positions associated with Type C leak rate tests.

Also, an uncontrolled supplementary document, which is not a part of nor referenced in HNP-1-3952-E, is used to assist in identifying Type C test valve alignments.

This is a Severity Level IV violation.

RESPONSE

Admission or denial of alleged violation:

The violation occurred as stated.

Reason for violation:

A.

It was felt that listing leak rate test boundary valves in the procedure in conjunction with qualified personnel performing the tests was adequate to insure implementation of the leak rate testing program.

B.

Since the uncontrolled supplementary document was used by qualified personnel in conjunction with controlled P&ID's (Piping and instrument Diagrams), it was felt that requirements were being adhered to.

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Region II - Suite 2900 January 26, 1983 Page Two RESPONSE: (Continued) ~

Corrective steps which have been taken and the results achieved:

In order to evaluate the validity of Type C leak rate tests performed in accordance with HNP-1-3952-E, the qualifications of personnel who performed these tests have been reviewed and found to be acceptable.

Corrective steps which will be taken to avoid future violations:

A.

The Unit 1 and Unit 2 leak rate test procedures, HNP-1-3952-E and HNP-2-3952-E " Primary Containment Periodic Type B

&' C Leakage Test", will be revised to prevent any possible problems in the future.

The revised procedures will address the following: Valve positions for both the valve (s) being tested. and any required blocking valve (s), venting requirements, and instrument error. The Ieak Rate Test Log will be placed under the control of the records management department.

B.

The revised procedures, HNP-1-3952-E and HNP-2-3952-E will contain sufficient detailed information to perform Inak Rate Testing.

Use of the supplementary document will be discontinued; however, some of the information currently contained in it will be incorporated into the aforementioned procedure revisions.

Date when full empliance will be achieved:

A procedure revision to bring the Unit 1 procedure into full compliance will be submitted to the Plant Review Board (PRB) by March 1, 1983, and the Unit 2 procedure revision will be sutnitted to the PRB by April 1,1983.

If you have any questions or need further information, please contact this office.

Very truly yours, L. T. Gucwa Chief Nuclear Engineer SCE/mb xc:

J. T. Beckham, Jr.

l H. C. Nix, Jr.

l Senior Resident Inspector I

p roons

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