IR 05000366/1983023
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UNITE 3 ST ATES d(II
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NUCLEAR REGULATORY COMMIS$10N
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g 101 M ARIETTA STREET. N.W.
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ATt.ANTA. GEORGI A 30303
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i JAN 6 1984 s
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Georgia Pcwer Comoany
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Mr. R. J. Kelly Executive Vice Presicent P.O. Box 454S
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Atlanta, GA 30302 Gentlemen:
SUBJECT:
CORRECTION TO PRCDOSED IvDCSITICN CC CIVIL CENALTIES:.EA S3-96 IMPROPER SHUT 00WN (REFERENCE: -INSPECTICN REDORT NO. 50-366/83-23)
This refers to :ne Notice of Violation and Proposed Imposition of Civil
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Penalties, issuec on December 27, 1983, basec u:on tne findings of an.NRC special ins:ection.
Tne inscection examinec the circumitances associatec with
- ne improper snutcewn of Hatcn, Unit 2, on July 14, 1983.
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Due to an administrative oversight page 2 of the transmittal letter contained an acditional sentence wnicn coes not certain to tnis event. A-correctec page is enclosed for insertion into ne original letter. We regret any inconven-ience tnis may nave causec.
Snould you nave any questiens concerning nis lette, we will be glad to ciscuss trem with you.
Sincerely,
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James P. C'Reilly Regional Aaminist-ator
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Enclosures:
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Proposed Im:asition of Civil
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EA 83-36 Imorocer
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Shutdown, Correctec Cage 2
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Proposed Imposition of Civil Penalties:
EA 83-E3, Imorocer Snutdown, Original Page 2, cated Decemoer 27, 1983 cc w/encis:
J. T Eeckham, Vice P-esicent and General Manager-Nuclear Generation H. C. Nix, Site General Manager C. E. Selflower Site QA Sucervisor r
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M DBS85-478 PDR l
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ENCLOSURE 1
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(Corrected Copy)
JAN 6 1984
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Georgia Power Company-2-
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To emphasize the level of unacceptability of the manner in wnich tne reactor was controlled on July,14, 1983, and after consultation with the Director of the Office of Insoection anc Enforcement, I have been authori:ed to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalties in the
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amount of One Hundred Thousand Dollars basec upon the findings of the first d
inspection.
Inree separate violations were icentified and a separate civil penalty could have been assessed for eacn.
Hewever, since all tnree violations stemmed from the same fundamental problem, the violations have
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been classifiec together as a Severity Level II problem (Supolement I)
cursuant to the NRC Enforcement Policy, 10 CFR Part 2, Appendix C, and a single civil penalty is proposed.
The base penalty of 564,000 nas been escalated to $100,000 because of the. seriousness of this event. the numoer of Tecnnical Specificatiens that were violated, and tne number of licensed operators anc supervisors involved.
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You are required to respond to the Notice and should follow the instructions _
specifiec :nerein when preparing your response.
The secuence of events tnat occurrec on July 14, 1933 gives rise to a numoer of cuestions wnich the NRC
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celieves must be acdressed by the Georgia P0wer Company.
First, has the Georgia Power Comoany's policy of " safety first" been compromised by improper
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consideration by individual mecers of tne Plant Hatch staff of " keeping the plant running" without proper considecation of overall plant safety?
Second, nas the Georgia Power Company's policy of strict adherence to approved operating procedures teen compromised at Plant Hatch by indivicual supervisors and managers and has an effective system of audits been implemented to assure compliance with
- ne oclicy? Thirc. is each operations supervisor fully aware of his/her incividual espcnsibili ies for making cecisions?
Fourth, is the role and the t
autnority of tne snift technical acviser clear to tnem anc to each operations
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suoervisor? Anc finally, is each licensec operator aware of the importance of acnerence to Technical Specifications anc knowledgeable of aoproved
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intercretations of those Technical Specifications?
Your resconse to tne attacnec Notice of Violation and Proposed Imposition of Civil Penalties should adcress, in cetail, eacn of these cuestions with carticular emonasis on assuring good vertical communications betwean Plant Patch in Saxley, Georgia, and the
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corocrate offices in Atlanta, Georgia.
It is furtner recuested tnat you
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crovice sufficient information on these specific matters so tnat we may conclude that your corrective actions will e effective over tne long run.
Your reply to this letter, &nd the results of future insoections, will be considerec' in determining wnet9er furtner action is aepropriate.
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In accordance with 10 CFR 2.790 of the NAC's " Rules of 0-actice", Dart 2,
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title 10, Code of Federal Regulations, a copy of tnis letter and tne Notice o'
Violation will be placed in tne NRC's P.olic Occument Room.
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ENCLOSUPE 2
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(Original Copy)
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DEC 37 Igg 3
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Georgia Power Comoany-2-To emphasize the fevel of unacceptability of the manner in which the reactor was controlled on July 14, 1983, and after consultation with the Director of
- ne Office of Inspection and Enforcement, I have een autnorized to issue tne enclosed Notice of Violation and Proposed Imcosition of Civil Penalties in tne amount of One Hundred Thousanc Dollars based upon tne findings of the first insoection.
Three separate violations were identified and a separate civil cenalty could have been assessed for eacn.
However, since all three viciations stemmec from tne same fundamental orcolem, the violations have
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ceen classified together as a Severity Level II proolem (Sucplement I)
pursuant to the NRC En.forcement Policy, 10 CFR Dar 2, Appencix C, and a single civil penalty is proposed.
The base penalty of $64,000 has been escalated to S100,000 because of the seriousness of this event, the numoer of Tecnnical Specifications that were violated, anc tne numcer of licensed ocerators and supervisors involved.
You are recuired to respond to the Notice and should follow the instructions saecifiec :nerein when crecaring your resconse.
The secuence of events tnat occurrec on July 14, 1983 gives rise to a numoer of cuestions wnich the NRC believes must be addressed by the Georgia Power Company.
First, has the
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Georgia Power Company's policy of " safety first" been compromised by improper consiceration by individual memoers of the Plant Haten staff of " keeping the plant running" without proper consideration of overall plant safety?
Second, nas the Georgia Power Comoany's policy of strict acherence to approved operating
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procecures oeen compromised at Plant Haten by incividual supervisors and managers anc has an effective system of aucits ceen imolemented to assure compliance witn s-
- ne colicy?
Third, is eacn operations suoervisor fully aware of his/her
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incivicual resconsibilities for making decisions?
Fourtn, is the role and the autnority of the snift technical adviser clear to them and to each operations sucervisor? And finally, is each licensec ocerator aware of the importance of ache-ence to Technical Specifications anc knowledgeacle of coproved
'nterpretations of tnose Tecnnical Soeci.fications?
Your resconse to the attacnec Notice of Violation and Proposec Imcosition of Civil Penalties should adcress, in detail, eacn of these cuestions witn carticular emanasis on assuring gooc
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vertical communications between Plant Haten in Baxley, Georgia, and the corporate offices in. Atlanta, Georgia.
It is furtner recuestec. nat you crovice sufficient information on :nese saecific matters so snat we may concluce snat your corrective actions will be effective over tne long run.
Your reply to tnis letter, and ne results of future inscections, will be consictred in determining wne:ner furtner action is approcriate.
In accordance with 10 CFR 2.790 of the NRC's Rules of Practice", Dar: 2, Title 10, Code of Federal Regulations, a copy.cf :nis letter anc :ne Notice of Violation will be placed in the NRC's Public Occument Room.
To protec: :ne privacy of the individuals involved, tne Letters of Reprimand will not ce olaced in the Public Occument Room it this time.
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Gocrg'a P:*e' w_
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Attarta Gec ;a 30303
Te ecrere 404 526J020 va+rg Acc'e55 P s: C"ce Sci 4545
Aranta Gecr;a 30302 **
Georgia Power
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vce P escert 39c Geae'ai Vara;er
%c: ear Geee<ation January 25, 1984
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Director, Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Wasnington, D.C. 20555 NRC DOCKET 50-366
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. OPERATING LICENSE NPF-5
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EDWIN I. HATCH NUCLEAR PLANT UNIT 2
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RESPONSE TO ENFORCEMENT ACTION 83-86
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Attention:
Mr. Richard DeYoung, Director
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Gentlemen:
Pursuant to the provisions of 10 CFR 2.201 Georgia Power Company (GPC)
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submits this response.to the Notice of Violation and Proposed Imposition of Civil Penalties dated December 27, 1983 (the Notice).
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We wish to emphasize that although three violations were cited, they arose out of one circumstance which involved the improper manipulation of control rods with the single oojective of reducing power to avoid a reactor
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shutcown transient.
Each violation cites a
different Technical Specification which was violated as a result of the single event described l
in the Notice.
The Nuclear Regulatory Commission (NRC) evaluated these l
violations collectively when arriving at the proposed civil penalty.
We,
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therefore, wish to respond to the violations collectively.
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Enclosed is full payment of the proposed civil penalty in the amount of
$100,000.00.
'Therefore, this response does not constitute a formal reply under the provisions of 10 CFR 2.205.
However, Georgia Power Company does informally request that the NRC reconsider the amount of the civil penalty and reduce the amount of the penalty on the basis of the following considerations:
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U. S. Nuclear Regulatory Comission Office of Inspection and. Enforcement January 25, 1984 Page Two
(a)
The Civil penalty snould be no more than the base penalty of
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$64,000.00 under the factors of the enforcement policy, 10 CFR Part 2, Appendix C.
The NRC escalated the penalty to $100,000.00 based on thr.ee reasons:
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the seriousness of the event, (ii) the
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number of Technical Specifications that were violated, and (iii)
the number of personnel involved.
None of these factors are among the five factors identified in Appendix C for adjusting the base i
penalty.
The seriousness of the event is already reflected in the base penalty of the classification (i.e., plant operations) and'
severity level it represents.
With respect to the number of
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i Technical Specifications and personnel involved, the Notice "
previously stated that all violations stensned from the same
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fundamental problem and, therefore, under Appendix C a single
unescalated application of the base penalty is the appropriate j
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amount despite the latter two reasons given for escalation.
(b) The enforcement policy provides for the reduction of the civil penalty by up to 50% based on unusually prompt and extensive corrective action.
Actions taken by GPC to control and prevent recurrence of such events fully support the intent of GPC to
operate Plant Hatch in a safe manner.
GPC promptly evaluated the event and its related root causes and implemented corrective actions in such a manner as to improve operator training and reactor safety.
These actions support a reduction of the civil penalty.
GPC believes that the corrective actions described in this response to.the Notice are certainly timely and comprehensive, and show a significant degree of licensee initiative.
VIOLATION:
A special inspection conducted at Hatch Unit 2 on July 14 and 15, 1983, disclosed that while Unit 2 was being returned to service, a problem was experienced with main condenser vacuum.
This problem required a reduction in reactor power to avoid a reactor shutdown.
The on-shif t operators and
their supervisors recognized that the normal method of reducing power would not achieve a sufficiently timely power reduction to. avoid a scram.
These individuals, i
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GeorgiaPower A
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V. S. Nuclear Regulatory Commission Office of Inspection and Enforcement January 25, 1984 Page Three
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apparently strongly influenced by advice from two shif t technical advisors, made a " consensus decision" to achieve the necessary rapid power reduction by bypassing both the Rod Worth Minimizer and the Rod Sequence Controller and by selectively scramming individual control rods, without an approved procedure, from the Scram Time Test Panel which is out of sight of, and out of normal voice communications with, the reactor control console.
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" consensus decision" and the resulting actions resulted in a control rod configuration that had not oeen analyzed from a reactor safety viewpoint.
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To emphasize the need to adhere to facility operations and administrative,
procedures, and to upgrade plant management control systems relating to licensed personnel, shift technical advisers, and supervisor's decision-making responsibilities, NRC proposes to impose a civil penalty in
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the amount of $100,000 for the matter of the improper reactor shutdown event on July 14, 1983.
In accordance with the General Policy and Procedure for NRC Enforcement Actions,10 CFR Part 2, as amended, the violations and the associated civil penalties are set forth below:
A.
Technical Specification 6.8.1 states that procedures shall be written, approved and implemented for reactor operations.
Contrary to the above, on July 14, 1983, control rod manipulations were conducted in violation of written and approved procedures, resulting in t
control rod patterns outside those analyzed for the Rod Drop Accident described in FSAR chapter 15.1.3.8.
These manipulations were improperly accomplished by scramming control rods from the scram time test panel (2Hil-P610) and inserting control rods using the Emergency In' switen instead of the approved procedural method of inserting control rods in
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notch control from the main control panel (2H11-P603).
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l Examples of procedures which were not followed include:
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Procedure, HNP-2-34, " Rules for Performing Procedures", requires
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that verbatim compliance is mandatory (Paragraph 13.2) and that, if an approved procedure cannot be performed as written, stop and
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change the procedure.
On July 14, 1983, Procedures HNP-2-9402 and HNP-2-9207 were not being followed verbatim nor was the event
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stopped, and the procedures were not changed.
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-U. S. Nuclear Regulatory Consnission Office of Inspection and Enforcement
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January 25, 1984
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Page Four
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2.
Procedure, HNP-2-9402, " Control Rod Scram Testing", requires, in
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step E.17, return of the scramed rod to its initial position prior
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to scramming the next rod.
On July 14, 1983, the rods scramed I
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from the time test panel (2H11-P610) were not being returned to j
their initial position prior.to scramming the next rod.
3.
Procedure, HNP-2-9207, " Control Rod Movement", Paragraph 0.4 and l
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Data Sheet 1 requires notch control for rods identified with an asterisk.
This asterisk was on all rod groups moved during the'
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scram.was initiated, and these movements were not conducted by -
notch. control.
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4.
Procedure, HNP-2-9207,
" Control Rod Movement",
Paragraph E.5 requires that rod movement be stopped if proper operation of the i
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Rod Sequence Control System (RSCS) is not confirmed.
On July 14, t
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1983, rod movement was continued even though the RSCS was circumvented and therefore inoperative.
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B.
Technical Specification 3.1.4.1 requires that Rod Worth Minimizer (RWM)
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I to be operable or a second licensed operator or other qualified member of the technical staff to be present at the reactor console to verify
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compliacce with the prescribed control rod pattern.
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l Contrary to the above, on July 14, 1983, af ter bypassing the RWM, a
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second person did not verify compliance with the prescribed rod
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As a consequence, the rod insert *on sequence was violated as e
j evidenced by Control Rod 42-39 at notch 12 versus the required notch 48.
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C.
Technical Specification 3.l.4.1 requires that the Rod Sequence Control
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I System (RSCS) be operable in Operation Condition I when thermal power is
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below 20%.
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Contrary to the above, on July 14, 1983, while in Operation Condition,
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with thermal power below 20%, the RSCS was not operational in that is
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was not performing its intended function of. notch control.
The required l
notch control was circumvented by use of the Emergency In Switch and the i
scram switches on the scram time test panel.
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U. S. Nuclear Regulatory Commission Office of Inspection an'd Enforcement January 25, 1984
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RESPONSE:
Admission or Denial of the Alleged Violation:
The violation dio occur.
While tne violation occurred within the general context of the violation as stated, personnel and operators involveo in the events always felt they were
operating within the bounds of approved procedures.
Reason for Violation:
Operating personnel failed to adequately follow
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proceoures.
Personnel used group discussion to make a " consensus decision" regarding action to De taken for reducing reactor power.
In f act, these,
actions did not comply with the
" intent" and
" scope" of existing procecures.
However, personnel and operators were not aware that actions
taken were "outside" of analyzed conditions.
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I Georgia Power Company performed an indepth critique of this incident imediately following the ev:'nt and an additional evaluation the following
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day with the personnel involved.
The results of those critiques and actions
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taken as well as the impact of the events, are provided as follows:
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A.
Description of Event:
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1.
Unit 2 was being maintained at approximately 150 MWE during startup
from a refueling outage.
Scram time testing and air ejector i
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trouble shooting had been in progress.
Condenser vacuum suddenly I
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began decreasing and the turbine was quickly unloaded and tripped.
i The operator began rapidly inserting rods to reduce power level as
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vacuum continued to decrease.
It became apparent to the control i
i room staff that unless power could be quickly decreased to within
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the limit of the mechanical vacuum pump so that it could be placed i
in service, vacuum would soon reach the reactor feed pump low i
vacuum trip point resulting in a loss of feedwater flow to the
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vessel, causing a reactor transient and possibly a challenge to a safety system.
The cause of the vacuum decrease was not known.
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The reactor core isolation cooling (RCIC) system was inoperative at
the time and the high pressure coolant injection (HPCI) system was
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operable, as allowed by Technical Specifications.
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i U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement January 25, 1984 Page Six
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B.
Operator Actions Taken:
1.
In order to reduce reactor power witn the fastest possible control rod insertion rate, the rod worth minimizer (RWM) was bypassed, as allowed by Technical Specifications.
A second operator was'
assigned to verify rod movements as required.
It is now clear, however, that the functional requirement of the Technical Specification was not being met.
Rod movement was being made from the front panel of the operating console at this time.
Operators started the insertion of control rods to reduce power due to the vacuum problem.
2.
At one point the insertion of control rods was made by the use of the Emergency In (Rod In) switch to reduce reactor power.
The use of tnis switch did not meet the intent of Emergency In use and did result in the Rod Sequence Control System (RSCS) not being used to control rod movement by noten control below 20% of power as required.
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When the operators reached groups of control rods that were of low
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rod worth (low effect on reactor power) in the rod insertion sequence, a shift technical advisor (STA) suggested that instead of manually inserting those control roos, that they could be scramed i
(rapid insertion), resulting in a quicker insertion rate and
reactor power level decrease.
It was noted that the control rod scram time test panel was set up to do this as a part of normal startup testing requirements.
While such action is allowed witn the reactor at power, it is only allowed for one control rod to be scramed, then returned to its original position before the next rod is tested.
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U. S. Nuclear Regulatory Comission Office of Inspection arid Enforcement January 25, 1984 Page Seven
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4.
A collective discussion between the licensed operators in the control room resulted in a decision to proceed in that manner in
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order to prevent loss of the reactor feed pump.
Vacuum at the time l
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was approximately 1/2 inch above trip point.
It was at this point control rod movement activities were prescribed to be completed in j
a manner contrary to procedures and requirements.
Personnel t
involved failed to be aware that such control rod movement was not approved by existing procedures because the ' control rod that. was, scramed was not to be returned to its original position before the
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next rod was scramed.
Involved personnel did not address the concern of conducting an operation outside of the bounds of ~
analyzed conditions.
Because of the ' failure to address such concerns, a possible " control rod drop accident" condition was not
considered.
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5.
After the decision to scram control rods to effect rapid reactor power reduction was made, a plant operator continued to insert rods at the reactor panel while two additional operators proceeded to
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the scram timing panel with the rod sequence sheets' to '.nsert roos
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with the individual scram switches.
When the front panel operator observed rods going in, he stopped inserting and verifieo further insertions from the scram panel.
Personnel involved believed these actions complied with the two person verification requirements for rod movement with the RWM system bypassed.
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6.
After rod insertion in this manner, it was found that one rod was in an "out of sequence" position at notch 12.
The vacuum pump was placed in service and vacuum stabilized at a low level.
Because of
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the out of sequence condition, the reactor was manually scramed
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(shutdown) as required by rod movement procedures.
7.
Although their actions were incorrect, the involved plant operators j
actions.were reasoned through and deliberate.
During the critique the involved personnel became aware 'of the f actors that had led
them to incorrect conclusions.
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It should be obvious from the above discussion that the operator actions l
were not performed to provide for the generation of electric power, because the turbine was already disconnected, but were done in the interest of
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reactor safety.
The actions taken were intended to avoid or limit a
transient on the reactor.
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GeorgiaPower A o
V. S. Nuclear Regulatory Commission Office of Inspection and Enforcement January 25, 1984 Page Eight
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C.
Impact of Events
1.
The intent of the operators to reduce reactor power for existing conditions was in itself proper, but the means of doing 50 were not
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within approved procedures or analysis.
The bypassing of th'e RWM and the assignment of a second operator to'
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verify. rod movement was in itself proper, but the failures to,
maintain this double verification and the movement of control rods from two different locations at the time of rod movement from the scram time test panel did not meet requirements.
3.
The use of the scram time test panel to scrc.m more tnan one control rod was improper and not within analyzed conditions as was the use of the emergency in switch, but had limited impact due to the low worth of the rods involved.
4.
While not mitigating the seriousness of the events and the possible effects had other high worth rods been involved, the health and safety of the public were not affected by these events.
Corrective Steps Which Have Been Taken and Results Acnieved:
The following corrective actions were taken.as the result of these events:
1. The Unit 2 reactor was placed in cold shutoown.
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U. S. Nuclear Regulatory Comission Office of Inspection and Enforcement January 25, 1984 Page Nine
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2. Individuals involved with the event were removed from licensed duties
[0perations Superintendent, Operations Supervisor on Shift (050S), Reactor Operator, Shift Technical Advisor (STA)].
Individuals were traired in the significance of the event and were allowed to assume licensed duties only after review by plant management.
3. Plant management conducted a session with Operations Supervisors to emphasize GPC's connitment to following procedures and to operation
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within analyzed regions.
The role of the OSOS in management of the
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plant was clarified.
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4. Results of the management investigation and proposed corrective actions were discussed with USNRC Region II personnel and their concurrence was
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obtained for Unit 2 restart.
5. Standing orders were issued for the control of the following activities:
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A.
Operation of emergency rod in switch.
(This has since been placed
in procedures HNP-l&2-9207.)
B.
Rod worth minimizer bypass controls.
(This has since been placed in procedures HNP-l&2-9207.)
C.
Requirement for Plant Manager approval of SRO procedure changes.
(This has since been placed in procedure HNP-9.)
6. Licensed operators and STA's were briefed on shift duties and detailed discussions were held in the following areas:
A.
Description of.the July 14 event; 8.
Lessons learned from the event; C.
Operational pnilosophy; D.
Corrective actions to be taken for this event; E.
The need to avoid " consensus decisions".
7. Involved operating and STA personnel were counseled by GPC Power i
Generation Management.
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U. S. Nuclear Regulatory Comission Office of Inspection and. Enforcement January 25, 1984 Page Ten 8. Supervisors and above viewed a GPC Power Generation presentation made by Mr.
J.
T.
Beckham, Jr.,
Vice President and General Manager Nuclear Generation, on this event.
9. HNP-l&2-9207, Rod Movement Procedures, were revised to clarify the use of emergency rod in switch and bypassing of rod worth minimizer.
10. HNP-l&2-9402, Scram Time Testing Procedures, were reviewed in detail to-assure they did not require revision.
"
11. Training was provided in the following areas:
.A.
A control room management course was presented to licensed operations'
supervisory personnel, SR0's, and selected Site Management personnel.
B.
A special seminar and discussion of the NRC position regarding plant operations were presented by Mr. Paul Bemis of the USNRC.
This presentation was presented to licensed personnel and other site personnel.
C.
The manager of the Core Analysis section of Southern Company Services presented a lecture on Final Safety Analysis Report (FSAR)
transient and accident analyses, procedure compliance, and the consequences of operations outside of analyzed areas.
This was presented to licensed control room supervisors.
D.
Site personnel were retrained in procedure compliance through the use of Departmental Directives.
E.
GPC site personnel attended a taped lecture by H.
C. Nix, Plant Hatch General Manager, on operating philosophy and procedure compliance.
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GeorgiaPower b
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U. S. Nuclear Regulatory Comission Office of Inspection and Enforcement January 25, 1984 Page Eleven Corrective Steps Which Will Be Taken to Avoid Future Violations:
In
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aadition to steps already listec, the following ongoing actions have been taken:
1.
Simulator training now stresses the lessons learned from this event.
2.
Special "FSAR Analyzed Regions of Operation" topics are now being presented to licensed' operators and STA's in training classes.
3.
Training for STA's now stresses the role of the STA in the control room -and Reactor Engineer duties for overview and s tandback -
approach.
4.
The following training is planned to re-emphasize periodically the attitudes desired in the operation of the plant:
A.
Long Term (Repetitive) Seminars - The Georgia Power philosophy of operation of Plcnt Hatch will be presented to licensed personnel and site mangement personnel who may be involved in decision making activities regarding the day-to-day operation of Plant Haten.
This will be done as a forum to provide for the free exchange of thoughts in the specific areas of: 1) why group decisions are not appropriate for operation: 2) system operation outside of the intent of existing procedures; 3)
operation outside of procedures; and 4)
lines of responsibility and authority in the control room during periods of non-routine operation.
Other items whicn may be identified in the future can be added to assure that the desired operational philosophy is instilled in the appropriate personnel.
This forum will be conducted on a schedule such that affected personnel are re-exposed to the desired attitudes on an annual ~ basis.
B.
Notable industry personnel will also be utilized in seminars on a long term basis.
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l GeorgiaPower d
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U. S. Nuclear Regulatory Comission
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l Office of Inspection an'd. Enforcement January 25, 1984 Page Twelve
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C.
As part of the long term training the subject' of plant
operating philosophy will be in new employee training and annual retraining.
'
5.
There are presently several ~ activities performed-by site management to monitor and evaluate shift activities on an on-going basis.
The General Manager and Deputy General Manager, as well as the Operations Manager, make random audits of shif t operations.
This is complemented by the Duty Officer who generally observes night shift turnover activities and by management audits that require an assessment of backshift activities once per week.
During outages, -
different members of management are assigned to.the back shifts for audits and/or coordination functions.
QA performs back shift audits periodically.
'
Date When Full Comaliance Will Be Achieved:
Compliance with requirements was acnievec on July 14, 1983, with the conclusion of the Unit 2 reactor snutdown.
By August 31, 1983, full compliance with long-term actions
>
comitted to in our July 18, 1983 response to this event was achieved.
Special Concerns:
Those special concerns and questions expressed in the Proposed Imposition of Civil Penalties Notice have been addressed as follows:
j j
1.
Has tne Georgia Power Company's (GPC) policy of " safety first" been compromised by improper plant
" running" witnout proper
,
l consideration of overall plant safety?
It nas always been GPC's l
policy to operate and maintain the Plant Hatch reactors in a safe l
manner.
While decisions made regarding the July 14, 1983, events were incorrect, they were never made with the intent, nor knowledge, to compromise safety.
Those actions taken are isolated events and are contrary to the general operating policy of both GPC and its operators.
To assure full understanding of the GPC policy,
actions listed in the " Corrective Steps Which Have Been Taken"
'
l section of this response were completed.
Additionally, site l
personnel were presented an August 22, 1983, memo from J.H. Miller, I
President, that defines the right, obligations and requirements with respect to providing for the safety of and' standards of performance for all Plant Hatch personnel.
Also, as a rasult of this event, QA has increased the frequency of their operations i
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U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement January 25, 1984 Page Thirteen
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The QA Department participates in a rotation program which audits.
currently includes a licensed (SRO) power generation engineer to better facilitate their audit process.
Safety Review Board members are receiving additional classroom and simulator training in order to better assess the operation of the plant in their reviews and audits.
These actions reflect GPC's and its operators' policy to always place safety first.
2.
Has the GPC's policy of strict adherence to approved operating procedures been compromised at Plant Haten by individual,
supervisors and managers and has an effective system of audits been implemented to assure compliance witn policy?
As stated, GPC believes that the actions carried out in the course of the July 14, 1983 events were taken with the mistaken belief that existing procedures allowed these actions.
Managers, Superintendents and Supervisors have been reminded.of the need to monitor plant activities and to assure procedure compliance.
The existing procedure "Self Audit" program has been re-emphasized to all site departments to improve the quality of procedures.
Procedure self-audits will assure that existing procedures are reviewed on a timely basis and should result in improved procedures.
3.
Is each operatior.s supervisor fully aware of his/her individual responsioilities for making cecisions?
Ine additional training steps, counseling and presentations discussed in the " Corrective Steps Which Have Been Taken" section of this response have assureo that supervisors have been fully trained and understand their responsibilities.
4.
Is the role and the authority of the shif t technical advisor (STA)
clear to them and to each operations supervisor?
As part of an on-going program, training for STA's now stresses the role of the STA in the control room.
STA's and operations supervisors understand the role and authority of STA's.
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U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement
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January 25, 1984 Page Fourteen
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5.
Is each licensed operator aware of the importance of adherence to Techntcal Specifications and knowledgeable of approved interpretations of those specifications?
Licensed personnel and
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STA's were provided a copy of the failure to follow Rod Movement Procedures as related to the July 14, 1983 event.
This was-
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presented in Departmental. Directive 0-83-14.
With the additional
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training completed to date, licensed operators are fully aware of -
the importance of complying with Technical Specifications and the GPC policy for such compliance and fully understand the intent and l
interpretation of these specifications.
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i Additional Improvements
!
In addition to-our response in accordance with 10 CFR 2.201 and in addition to the Special Concerns expressed by the NRC in their Proposed Imposition of Civil Penalties Notice, GPC has made other general plant f
operations and management improvements since the July 14, 1983 event.
Some j
of these are-l A.
A program to hold formal shift meetings at the start of each shift
'
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has been implemented.
These meetings address concerns with the
!
operation of the units and proposed actions to resolve problem
areas.
B.
A new position of a supervisor whose function is to control
'
maintenance activities during outages has been added to relieve the
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Shift Supervisors from the paper work duties, of. maintenance
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activities.
This action allows full attention to be directed
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towards current unit operations.
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GeorgiaPower A
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U. S. Nuclear Regulatory Commission Office of Inspection add Enforcement January 25, 1984 Page Fifteen
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C.
An improved interface between departments has been achieved, resulting in better support of the Operations Department by other departments.
This interf ace results in maintenance and engineering support being provided directly to Operations at the time of operational needs rather than an after the fact support.
Further, it defines the responsibility of the Operations Supervisor and the
support to be given him.
D.
The daily work schedule meeting has been moved to 8:30 a.m. rather than the 2:00 p.m. meeting time.
This results in problems with
'
unit operations being addressed in a
more timely manner.
<
Resolution of problems are proposed and carried out with the full
,
support of all departments.
i i
E.
Selected superintendents now attend the work schedule meetings.
This results in more fully supervised problem resolutions.
F.
Department informational meetings are now held monthly.
These meetings have improved communications between departments,
.
resulting in more active involvement between tha departments.
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Training efforts and operating philosophy are passed on to all i
levels of plant personnel.
These actions have resulted in a better awareness by.all personnel which leads to safe plant operations.
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G.
Managers are becoming more involved in the day to day operations of the plant, resulting in better supervision of plant operations and
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activities.
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U. S. Nuclear Regulatory Comission Office of Inspection and Enforcement
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January 24, 1984 Page Sixteen l
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i Georgia Power Company recognizes and concurs with the NRC's concerns as j
3at forth in the Notice and in the enforcement conferences.
We have i
responded ano intena to continue to respond to this event in a manner which l
will ensure that safety will be the foremost concern of all involved with i
Plant Hatch.
We believe the actions documented in this letter evidence such
a prompt and extensive response.
As previously noted, Georgia Power Company
.i s enclosing payment of the proposed civil penalty.
However, for the
!
reasons previously given, and cased on the actions presented herein, we
!
respectfully request tnat NRC reconsider and reduce the civil penalty.
'
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J. T. Beckham,- Jr. states that he is Vice President of Georgia Power Company ~
!
ano is authorized to execute this oath on behalf of Georgia Power Company, i
and that to the best of his knowledge and belief the facts set forth in this
'
letter are true.
!
i GEORGIA POWER COMPANY
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By:
J. T. Beckham, Jr.
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Sworn to and subscribed before me this 25tn day of January, 1984.
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Notary Public* * * * 0**'8" h # *
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.e,.u~wcc Eerus Aus,2A ten *
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Enclosure
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H. C. Nix, Jr.
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i Senior Resident Inspector
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J. P. O'Reilly, (NRC-Region II)
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Io UNITED STATES f
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NUCLEAR REGULATORY COMMISSION i
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WASHINGTON, D. C. 20955
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,sg 3 ; 4 g l
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i Docket No. 50-366 i
License No. NPF-5 l
EA 83-86
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Georgia Power Company i
ATTN: Mr. R. J. Kelly Executive Vice President
i P.O. Box 4545
'
Atlanta, GA 30302 Gentlemen:
'
This letter acknowledges receipt of your letter dated January 25, 1984 and your check in the amount of $100,000 as payment in full for the civil penalty
~
proposed by the NRC on December 27, 1983.
In that letter, you admitted that the violations described in the Notice of j
Violation occurred, but also requested that the NRC reduce the penalty to no more than $64,000.
The NRC has carefully evaluated your response and
-
'detennined that reduction of the fine is not warranted.
Your primary argument is that you should be assessed no more than the base penalty of $64,000 for c Severity Level II violation because the reasons given
for escalating the penalty to $100,000 are not among the five factors identified in 10 CFR Part 2, Appendix C for adjusting the base penalty.
Although the NRC
,
l relies primarily on the five factors to determine whether a base penalty should j
be escalated, the NRC has discretion under Appendix C to escalate a penalty for other reasons, when appropriate.
,
In this particular case, several violations of your technical specifications i
occurred.
Each violation could have been considered separately and a separate civil penalty assessed for each.
However, to focus on the fundamental under-
.
l lying causes of the event, the violations were grouped into one problem area.
l Because of the circumstances of this event, including the fact that several
licensed personnel collectively decided to take actions not covered by approved procedures that resulted in violation of several technical specifications, I
the NRC'used its discretion to escalate the base civil penalty for this problem to emphasize the significance of the event.
The use of such discretion was
,
i appropriate under the circumstances. Had you not taken extensive, prompt
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corrective action, an even stronger enforcement sanction would have been taken j
for this very significant violation.
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PES 14 984-2-Georgia Power Company Accordingly, I find no basis for reducing the penalty.
Your corrective actions will be examined during future inspections.
Sincerely,
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Richard C Young, irector Office of nspection and Enforcement.
cc:
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J. T. Beckham, Vice President and
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General Manager-Nuclear Generation H. C. Nix, Site General Manager
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C. E. Belflower, Site QA Supervisor
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02/09/84 766 DATA FOR HATCH 1 - 85000321 PAGE I DATA SELECTED BY ENDING INSPEC. DATE JAN 1,
1982 10 FEBRUARY 10, 1984
.--------------
L-------------------------------------------------------------------------------a DOCKET TO FROM FIND-DEVIATION /
SEVERITY CEPORT DATE DATE INGS SEVERITY SUPPLEMENT TEXT
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - <
050003218201 011582 011282
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050003218203 012982 012882
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0500032'8204.021182 020882
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FAILURE 10 FOLLOW APPROVED PHYSICAL SECURITY PLAN
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003218207 022682 022282
5
ENVIRONMENTAL TECllNICAL SPECIFICATION 5.6 REQUIRES DETAILED WRITTLH PROCEDURES, INCLUDING APPLICABLE Clf ECK LISTS AND INSTRUCTIONS, SIIALL BE PREPARED A ND FOLLOWED FOR ALL ACTIVITIES INVOLVED IN IMPLEME NTING THE ENVIROHf1LNTAL TECHNICAL SPECIFICATIONS.
LICENSEE PROCEDURE HilP-7650 REQUIRES ALL DATA AND RESULTS GENERATED AT THE PLANT SITE BE REVIEWED I N A TIMELY MANNER.
CONTRARY TO Tile ABOVE, L IC EllSE E PROCEDURE HHP-7650 WAS NOT ADilERED TO IN THAT NU MEPOUS DATA SHEETS WERE NOT REVIEWED FOR ONE AND T
-
WD MONTHS.
IN ONE CASE A REVIEW OF A DATA SHEET W AS NOT MADE FOR ONE YEAR.
050003218208 031982 030282
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050003218209 030182 012182
5 I
10CFR50, APPENDIX B, CRITERION V. REQUIRES ACTIVIT IES AFFECTING QUALITY SHALL BE PRESCRIBED BY DOCUM ENTED INSTRUCTIONS, PROCEDURES, OR DRAHINGS, OF A TYPE APPROPRIATE TO THE CIRCUMSTANCES AND SilALL BE ACCOMPLISHED IN ACCORDANCE WITH THESE INSTRUCTION
.
S. PROCEDURES, OR DRAWINGS.
PLANT PROCEDURE HHP-8
-
22, MATERIAL INSPECTION REQUEST, STEP 6.1.A REQUIR-ES A TWO PART QC HOLD TAG BE ATTACHED TO MATERIAL -
~
TO BE INSPECTED.
CONTRARY TO THE ABOVE. OH JANUAR
-
Y 21, 1982, QC HOLD TAGS WERE NOT ATTACHED AS REQU
IRED TO APPROXIMATELY 100 SPARE JOHNSON PUMP PARTS
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IN THE WAREHOUSE.
050003218209 030182 012182
D PARAGRAPH 3.4.5.2 0F THE FINAL SAFETY ANALYSIS REP
~
ORT STATES THAT THE WITHDRAWAL SPEED CONTROL VALVE IS SET TO GIVE A CONTROL ROD A SIIIM HITHDRAWAL SP i~'
EED OF 3 INCllES PER SECOND.
TIIIS WITilDRAUAL SPEED CORRESPONDS TO A NOMINAL FULL CORE WIlllDRAIJAL TIM E OF 48 SECONDS.
CONTRARY TO THE ABOVE. IllE UNI T
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n?/09/84 766. DATA FOR H'.TCil 1 - 0500032t PAGE 2 DATA SELECTED BY ENDING INSPEC. DATE JAN,to 1982 TO FEBRUARY 10. 1984
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DOCKET TO FROM FIND-DEVIATION /
SEVERITY REPORT DATE DATE IrlGS SEVERITY SUPPLEMENT TEXT
+ ________________________________________________________________________________________________________________________________
030003218209 030182 012182
D WAS STARTED UP ON JilHE 4 1981 FOLLOIlillG A REFUEL ING OUT AGE WITH EIGili CONTROL ROD DRIVE WIll!DRAWAL TIMES OUTSIDE OF Tile ACCEPTANCE BAND OF 40-60 SEC ONDS.
050003218209 030182 012882
5 t
TECllHIPSL SPECIFICATION 6.8.1 REQUIRES THAT WRITTE N PRDCLDURES SilALL BE ESIABLISilED. IMPLEMENTED AND MAINTAINED COVERING lilE APPLICAPLE PROCEDilRES REC OMMENDED IN APPEtIDIX "A" 0F REGUIATORY GUIDE 1.33.
REVISION 2. FEDRUARY 1978 AND SURVEILLAtlCE AND TE ST ACTIVITIES OF SAFETY-RELATED EQUIPMENT.
CONTRA RY TO THE ABOVE. Otl JUNE 14. 1981 PL Atli PROCEDURE IINP-8 01 WAS NOT FOL LO!!ED IN Til A T A NCitC0tlFORt1AtlCE REPORI WAS NOT ISSULD WilEta EIGili CONIROL ROD ORIV E MECHANISMS WERE UtlABLE 10 SATIsrY TifE ACCEPTANCE CRITERIA STATED IN lit 4P-1-9404. CollT ROL ROD DRIVE TIMING.
C0tITRARY 10 tile ABOVE TEClillICAL SPECIFICA TION. PLANT PROCEDURE llNP-2-3410. SURVEILLAf4CE Or illE RCIC STEAM LINE DEL T A P INSTRUMLNTS. LIAS fl0T P RDPERLY MAltlTAINED OR REVIEWED IN Til A T AN IllCORREC T +142 IllCH VALVE EXISTED IN STEP F.2.0 0F THE PRO CEDURE FOR SET TING TifE RCIC flIGil STEAM FLOW ISOL AT 10tl SETPOINT FOR THE INBOARD ISOLATION VALVE.
CON TRARY TO THE ABOVE TECilNICAL SPECIFICATI0tl. PLANT PROCEDURE HNP-820. PLANT RECORDS MANAGEIIENT. PARAG RAPil E.2 WAS NOT FOLLOWED 2N TilAT PLANT RECORDS ON CONTROL ROD DRIVE TESTS WERE NOT FORWARDED TO Tile DOCUMENT CONTROL SECTION SUBSEQUENT TO C0f1PLETION OF CONTROL ROD TESTING OH JUNE 14.
1981 ON FEPRU ARY 2.
1982. THE RECORDS OF OtILY 15 0F 137 RODS TE STED WERE IN DOCUMEllT ATION.
Tile REMAINING RECORDS WLRE LOCATED IN AN EllGINEER'S DESK DRAWER.
050003218210 031282 031082
5
TECHNICAL SPECIFICATION SECTION 6.8.1.F REQUIRES W RITTEN PROCEDURES TO BE ESTABLISHED. IMPLEi1ENTED A
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HD MAINTAINED COVERING THE FIRE PROTECT 10tl PROGRAM
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It1PL LMEN T A T ION.
(1) ON MARCH 12. 1982. WITil UtIIT t IN OPERATION. TilREE WELDING PERMITS WERE FOUllD IN UNIT 1 WilICil WERE ISSUED FOR MORE TilAN OtIE SHIF T.
TilIS IS CONTRARY 10 GEORGI A PO!!ER C0f1 Patly PROC EDURE HHP-555. CONTROL OF IGNITION SOURCES. SECTIO N E.4.
(2) ON MARCil 12. 1982. THE UNIT f REACTOR BUILDING llVAC EQUIPf1ENT ROOM COHTAINED AN ACCUMULA TIDH OF COMBUSTIBLE MATERIAL CONSISTING OF CONTAt1I HATED FILTERS. NEW FILTERS. CARDBOARD DOXES. AHD M ISCELL ANEOUS DEBRIS WilICil Ilin NOT BEEN REVIEllED BY
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42/09/84 766 CATA FC2 HATCH I - 85000329 PAGE 3 CATA SELECTED BY LHDING INSPEC. DATE JAN*t. 1982 TO IEDRUARY 10. 1984
DOCKEI TO FROM FIND-DEVIATION /
SEVERITY REPORT DATE DAIE INGS SEvZRITY SUPPLEMENT TEXT
__-_________._______________________________.______....._____________._____. _______ ___________________________.. _________.
050003218210 031282 031082
5
THE SENIOR REGULATORY SPECIALISI AND A-SIORAGE PE Rit!I HAD HOT BEEH ISSUED.
IllIS IS CONTRA 2Y 10 GEO RGIA POWER C0f1PANY'S PROCEDURE HHP-559. CONTROL OF TRANSIEPIT COMBUSIIBLES. SECTION F.
050003218211 040282 032982
5
TECllHICAL SPECIFICATION 6.8.1 REQUIRES TilAT WRITTE N PROCEDURES BE ESTABLISil[D. It1PLEMEllTED AND MAINI AIllED COVERING THE APPLICABLE PROCEPURES RECOMMEllD ED IN APPENDIX "A" 0F REGULATORY GUIDE 1.33.
REGU LATORY GUIDE 1.33. ArPi tIDIX " A" SI AT ES IN P AR T THA T RADIATIDH PROIECTION PROCEDURES SIIOULD BE PROVID ED.
PROCEDUPE litIP-8005. REVISIDH 12. SECTION I. R ADI ATION OCCUPREllCE REPORTS. PARAGRAPH 1.(B)(2) RE QUIRFS ACTION TO BE TAKEN TO EtISURE illE F.EPORIED E VENT DOES HOT RfCUR.
CONICARY TO IllE ABOVE. RADIA TIDH PROTECTI0tl PROCEDilRES HERE HDT EST ABL ISilED. I MPLEMENTED AND MAINTAltIED IN IHAT TllE ACT IDH DESIG MATED TO CORRtCI MISUSE OF PERSOHHEL DOSIt1ETRY BY AN IIIDIVIDUAL OH NOVLtinER 3.
1981. LIAS HDT PERFORM ED.
SPICIIICALLY. Tile PRESCRIBED HOT IFIC AT IOtt OF AlL Er1PLOYEES OH OCCURRENCE REPORT 81-19A WAS NOT P ER F ORf1E D.
050003218212 032082 030282
5
TECHNICAL SPECIFICATION 6.8.1 PEQUIRES TilAT PROCED URES CONTROLLING THE OPERATION OF SAFETY-RELATED S YSTEMS BE IMPLEMENTED. PLANT PROCEDURE flHP-t-stt7 RilR SERVICE WATER. DATA PACKAGE I.
REQUIRES filAT
.
Tile NOTOR COOLING WATER SHUTOFF VALVES BE LOCKED DPEH AtID THE STATUS OF THE VALVES BE DOUBLE VERIFI ED.
CONTRARY TO THE ABOVE. ON PIARCll I,
1982. Tile MOTOR COOLING WATER IHLET VALVE FOR "A" RESIDUAL H
-
EAT REMOVAL (RHR) SERVICE WATER PUf1P WAS IOUtID BY Tile INSPECTOR HOT LOCKED OPEH AS REQUIRED BY IHE H
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HP-t-Itt7 PROCEDURE (THE VALVE WAS LATER DEIERMINE
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050003218213' 050482 042882
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FAILURE 10 CONTROL ACCESS TO THE PROTECTED AREA.
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.-..-......--....---------......----------.....--........-.......--.......----..-----................--....:
DOCKET TO FROM FIND-DEVIATION /
SEVIRITY REPORT DAIE DAIE INGS SEVERllY SUPPLEMENT TEXT
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TECHNICAL SPECIFICATION 3.10.8 REQUIRES Ill A T FUEL SilALL NOT BE LOADED INIO IllE RIACTOR CORE UNL ESS A LL CONTROL RODS ARE fillLY INSE RIED.
CONTRARY 10 i HE ABOVE, AND AS RIPORIED BY lilE IICENSIE, FUEL WA S LOADE D INIO IllE CORE Will10UI AL L C0tilROL RODS FU
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LLY INSERIED ON IMO OCCASIGHS: 1) IllLN T Y TWO (22)
IllEL BUNDL ES WERE L OADE D ON 5/16/32 !!!IN CONTROL R
,
OD 10-2 3 IllillDR Alltl.
?) IMO (2) IUIL BullDLES WERE LOADED ON 5/11/82 ti!Ill CONIROL ROD 10-31 Wi lllDR AWri i
s l
t 0%#003218220 062182 052682
4
FAlttlRE TO MAINTAIN COOLING WATER ISOLATION VALVE l
IN A LOCKED DPIN CONDITION ON ID PtANI SERVICE WAT fR PUTIP. Al IllE lill AV E SIRUCIllRE.
Ilf!S IS A REPEA T OF SIrllLAR li[r1 IN RIPORI 8?-12.
!
050003218221 070982 070832
-
-
-
050003218222 072282 071882
-
-
-
050003218223 072382 072182
-
-
-
050003218224 073082 072682
4
FAILURE TO PROVIDE QA INDOCTRINATION TO ALL HON QA PERSOHNEL AllD F AILURE 10 PROVIDE SPECI ALIZED INST RUCTION 10 PLANI OPERATOR $, MAINTENANCE PERSONHIt.
TEST PERSONNEL, QC AND HEAlill PHYSICS PERSOHilEl I N illIIR AREAS OF QA PROGRAM IMPlll1ENI ATION AS REQU IRED BY 10CFR50. APPENDIX B, CRITIRIO!1 II AllD IllE
'
IICENSEE'S ACCEPIED QA PROGRAM.
FAILURE TO PROVIDE A SCHEDULID PRErtANHID LECillRE SIRIES BASED ON EVALUAIION OF AHHU * t. b!R i l ii tt tICIN
'
.
SED OPERATOR EXAMINATIDH AS REQUIRID BY 10CfR$5. A PPENDIX A.
-
.I 103218225 072682 062282
4
FAILURE OF PLANT LICENSED OPERATOR TO CONTROL PLAN
,
i PRLSSURE PRIOR TO SRV LIF11NG ON A SCRAM U11H MS
,
'
IV CLOSilRE.
- FAILtlRE TO POST FIRE MATCHES FOR AN EXTENDED PERTO D IN ACCORDANCE Willi IECHNICAL SPECIFIC ATION RLQUI REMENIS WilEN INADEQUATE FIRE BARRIERS 140RE FOUtID T 0 EXIST.
0500032t8226 081382 080982
-
-
-
i 050003218227 081982 081C82
-
-
-
-
g I
i i
.
,
,
.-
-
i
,
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f
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_. - - _ _, --.
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_
_
_
12/09/84 766 DATA FOR HATCH I - 05000321-PAGF 5 DATA SELECTFD BY filDING INSPEC. DATE JAN to 1982 10 FlBRUARY 10.
1994
'
---__....__.___________........_______________ ___...__......._ ~.___________ ______............____....--_____.__--.---_-_-
DOCKET TO FRON F illD-DEVIATIDH/
SEVERTTY REPORT DAIE DATE INGS SEVERIIY SUPPLEMENT TEXT
-. -. _........ _ _ _ _ _.. _ _ _... _ _ _. _ _ _ _ _ _.... _ _ _ _ _ _ _.... _ _ _ _ _. _ _ _.. _ _ _ _......... _ - - _ _ _ _ _ _ _. - - - - -... _ - - _ _ _ _ _.... - _....... - _ _. - -..
050003218228 082782 072782
-
-
-
050003218229 090382 083082
-
-
-
050003218230 100182 092882
-
-
-
050003218231 092382 092082
-
-
-
050003218232 092882 082882
5 I
FAILURE TO FOLLOW IIPCI SURVEILL ANCE PROCEDURE.
HP CI FUttP DISCilARGE VALVE WAS CYCLED AT POWER RATilER IHAN IN C0l D SilUID0t?ti C0tIDI T IDHS.
FAILURE OF L ICEllSEE Pl.RSOHilEl 10 PROPERLY FRISK Wil EN ENIE RlHG IllE CutilRut R O uti.
INSPEC10R FOUllD FRI SKER itti?NED Of F AtlD tlHPLUGGI D.
f AILURE 10 fl0TIFY llRC WilllIll i I;DilR AS REQUIRED BY 50.72 ON IHOPERARLE SRGi SYSTIMS PH UNIT 1 AND EC CS ACTtlAlIDHS O!I litali 2 (it!O ( X Attr t ES ).
050003218233 102982 102582
-
-
-
050003218234 110582 110182
-
-
-
050003288235 102882 092882
-
-
-
050003218236 120682 183082
4
ENVI R0llMEN T AL TECliHIC AL SPECIFIC ATION 5.3.2.2 REQU IRES TilAT AUDITS OF FACILIIY ACTIVITIfS SilALL BE P ERIORt1ED AT LEAST ONCE A YEAR UNDER THE COGNIZAtlCE OF Tile SRB 10 ENSURE CONFORf1AtlCE OF I ACIIITY OPER ATIDH OF ALL PROVISIDHS OF Tile ENVIROHttENI AL T E CllN ICAL SPECIFICATIONS (ETS).
EIS-3.2. TAntt 3.2-1 SPECIFIES Tile PERFORMANCE OF AN ANALYilCAt FROCRAM
,
.
CONIRARY TO IllE ABOVE. AUDITS OF Tile All A L Y I I C A L PROGRAt1 WFRE HOT PERFORMED IN 1980. 1981. AND 198
-
2.
TilROUGH DECEMBER 6.
1982.
.s0003218236. 120682 183082
D OCOM-IN A LETTER DATED DECEMBER 30, 1982. HRC REGI ON II ISSUED A HOTICE OF VIOLATION TO THE GEORGIA P0t4ER COMPANY.
Tile fl0! ICE IDENTIFIED A VIOLATI0tl 0F ENVIR0tittENT AL TECilNICAL SPECIFICATI0H S.3.2.2.
DISCLOSED DURING tlRC INSPECTION HOS. 50-321/81-24
' '
APID 50-366/88-24 FOR ll AVING F AILED 10 C0tibt!CI AUD ITS OF ITS ANALYIICAL PROGRAM.
GEORGIA Poller C0ffP ANY RESPONDED 10 IllE HRC CII ATION IN A LETTER DATE D DECEllBER 30. 1988 DESCRIBING CERTAIN CORRECTIVE AND PREVENTIVE ACTI0tt TAKEN OR PiAHHED.
Tile FOLL OWillG STATEMENT WAS INCLUDED IN THIS LETTER:
BY A
.
.
'
.-
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. *
I
- -
_
_
-_ -
02/09/84 766 DATA FOR llAICH t - 05000321 PAGE 6 DATA SELECTED BY ENDING INSPEC. DAIE JAN 1 1982 10 FEBRUARY 10 1984 I
DOCKET
FROM FIND-DEVIATION /
SEVERITY REPORT DATE DATE INGS SEVERITY SUPPLEMENT TEXT
050003218236 120682 113082
D PRIL 1.
1982. GEORGIA POWER COMPANY Witt DEVELOP A PROGRAM 10 PROVIDE IOR AHHUAL QA AUDIIS OF CONTRA CTOR ACTIVITIES RELATED TO file ENVIROHitLNT AL MONIT ORING.
IMPLEllENTATION OF 19115 PROGR AN Wit t BEGIN IN APRIL 1982.
C0fflRARY 10 illF ADOVE. AS OF DECEM BER 6.
1982. IllE L ICEllSF E H AD k. " DE VEL OPED A PROG RAM TO PROVIDE FOR Afill0AL QA AUDITS OF CONTRACTOR ACIIVITIES RELATED 10 illE ENVIROHilEN T AL MUNI TORIllG
.
I 050003218237 198982 111682
-
-
-
,
0003218238 191982 111682
4 I
CONTRARY TO TECIINICAL SPFCIFICATIONS 6.8.1.C AND 6
.8.2.
THE SURVEILLANCE IISI PROCEDURE HHP-1-3952-E REV. 13. FOR IYri
"C" LLfr RATE lESTS DID NOT CO
,
HTAIN DETAILED VALVE POSIIIDHS FOR ALL TEST CONNEC TIONS. VENT V AL VES. DRAIN VALVES AND BLOCK VALVLS ASSOCIATED Willt LIAK RAIE TESTS.
A SUPPLIMENTARY DOCUttENT WAS USED 10 ASSIST IN DriERMINING VALVE ALIGNMENTS WitICil 15 NOT A PART OF file APPROVED T E ST PR3CEDURE.
050003218239 192082 102882
-
-
-
050003218240 111982 111582
-
-
-
i 050003288241 121682 121382
S
CCNTRARY 10 TECHNICAL SPECIFICATION 6.8.2. PROCEDU RE CllANGES WERE NOT APPROVED. IS$tlED AtlD CONTROLLE D IN ACCORDANCE WITH PLANT PROCEDURE.
fiHP-9 IN TN
AT ON DECEMBER 14, 1982. AN UNAPPROVED. UllCONTR0tt ED CilAllGE 10 PLAMI PROCEDURE HNP-6914 WAS BEING US ED FOR QUALIFICATION OF CLASS I PIPE WELDERS.
'
l
- %0003218242 171582 121382
4
CONTRARY TO IOCFR50 APPENDIX "B" CRITERION XVI A HD I. AND THE ACCEPTED QA PROGRAM (FSAR 17.2.16 AN D 17.2.1). Tile QA DEPARTMENT DOES NOT EFFECTIVELY
.
ASSURE CONFORI1ANCE 10 QUALITY STANDARDS IN INAT IT
,
DOES NOT ASSLIRE PR0f?PT CORRECTION OF CONDIIIONS A
-
DVERSE TO QUALIIY.
SPECIFICALLY ONE IILM WIRTTEN IN 1978. TWO ITEMS WRITTEN IN 1979. SEVEN ITEMS WR
~
ITTEN IN 1980 AtID SEVEN ITEMS WRiiTEN IN 1981 STIL L REMAIN OPEN.
AlL TilESE ITEMS WERE IDENTIFIED BY THEIR QA AUDIT SYSTEM.
CONTRARY TO 10CFR50. APPENDIX "B". CRITERION V.
TN E ACCEFIED QA PROGRAM (FSAR 17.2.5) AND LICENSEE P ROCEDURES QA-05-06 AND QA-05-01 SIX AUDIT FINDING
.
-
.
.
'
.
.
_ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _
_
_
_
17/07/84 766 DATA FOR HATCH I - 05000328 PAGE 7 DATA SELECTED BY fHDING INSPEC. DATE JAN't, 1982 TO ItBRUARY 10, 1984 i
DOCKET TO FRON FIND-DEVIATION /
SEVERITY REPORT DATE DATE INGS SEVERIIY SUPPLEMEHi TEXl
.------------------..-----...-------------- -------------------------------------------------------------.--------.---
050003288242 121582 121382
4
5 WERE NOT RESPONDED TO WilllIN THE REQUIRED 30 DAY TIftE PERIOD.
050003218242 121582 121382
5
COHIRARY TO THE ACCEPTED QA PROGRANS, ENDORSEMENT OF ANSI N 45.2.23, THE LICENSEE DID HOT UPDATE QU AllFICATIGHS OF 4 0F 5 LEAD AUDITORS AHHUALLY.
050003218243 121982 112082
-
-
-
050003218244 121082 120682
-
-
-
052003218301 012183 011883
4
COHTRARY 10 TECHNICAL SPECIFICATION 6.8.1.A. PROCE DURES FOR REPAIR OF RICIRC AND RilR PIPING WERE NOT F0tt0WED IN Ill A T (t) ON JANUARY 18.
1983. HUNEROU S PIECES OF.035" DIAf1EIER STAINIISS WILDING flATER IAL UP 10 APPROXINATIL Y 50 Fi. IH L EllGill HERE L EF T SCAITERED OVER IllE DRYWLLl AFTER C0f;Pltil0N OF WE LD REPAIRS, (2) OH JANUARY 19. 1983, STEPS 17, 18 AND 21 0F PROCEDURE IINP-t-10874 flAD Hiti DEEN SIGNE D OFF.
STEPS 19, 20 AHD 23 IIAD 10 BE SIGilED OFF, AND (3) ON JANUARY 19. 1933. PT IllSPECT I0li il AD BEE N PERFORMED IN ACCORDANCE WITil SCS PROCEDURE II/F/V-600 AND UT WAS BEING PERFORf1ED IN ACCORDAtiCE WITH Lf1T PROCEDURE UT-38 IN LIEU OF file FROCEDURES REQ UIRED BY llHP-t-1017'e.
050003218302 012183 122082
-
-
'-
050003218303 020383 012983
-
-
-
050003218304 021183 020783
5 i
CONTRARY 10 10CFR50.72(A)(1). THE LICENSEE DID HOT
.
H0ilFY Tile HRC OPERATIONS CENTER W!illIN OHE HOUR FDL L0tJING A LIQUID RELEASE OF I-131 FROM CilENICAL
'
WASTE SAf1PLE T ASK "A"'WilICH EXCEEDED TECHHICAL SPE
._
CIFICATIDHS AND 10CFR20, APPEllDIX
"B",
TABLE II. C
-
OltfMH 2.
LIMITS.
illE RELEASE CONCENTR ATIDH HAS 8.
'
5Xto-7 MICRDCtlRIES PER MILLILITER; THE Lif11T IS 3.
OXIO-7 NICROCURIES PER MILLILITER.
A 30-DAY LE!i W AS SUBMiliED AS REQUIRED BY TECllHICAL SPECIFICATI0 HS.
050003218305 022583 022283
-
-
-
050003218306 103182 070181 t
-
-
-
s
-
022683 012283
4
CONTRARY TO TECllHICAL SPECIFICATION 6.8.1, OH FEBR
.050003218307
.
.
.-
-
- - -
__
_ _ _ _ _ _ _. _. _
_
_
_.
.
_
._ _
02/09/84 766 DATA FOR HATCH I - 0500032t PAGE 8 DATA SELECTED BY [HDING INSPEC. DATE JAN 1 1982 10 FEBRUARY 10, 1984 t
DOCKET
FROM FIND-DEVIATION /
SEVERITY REPORI DATE DATE INGS SEVERITY SUPPLEMENT TEXT------- ----------------------------
- - - - - - - - - - - - - - - - - - - - -... - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - I O R D I S C O V E R E D i ll A T : 1 050003218307 022683 012283
4
UARY 23. 1983. Tile INSPEC PROCEDURE HilP-1-1500. WAS H01 BEING PROPERLY IMPL
EMENTED IN THAT:
A.
ADJUSTABLE WREHCllES ABOUT (1
'
0 IHCHES IN LENGTH) WERE AT T ACllED 10 Tile KEYS OF K EY LOCK SWITCilES C61-534A 8 B IN SUCil A WAY AS 10 HOL D THE SWI TCllLS AGAIHST THE SPRING REitlRN.
THIS
,
'
ACTION OVERRIDES A IIIGil REACTOR PRESSURE (840 PSI
.) SilUI TING SIGilAL 10 illE 2" VElli VALVES li48-F340 8 li48-F341.
IINP-t-1500 IN Ho WAY AUlil0RIZES THF
=
ACTION OF USIllG A FIECilANICAL OVERRIDE ON THE KEY LOCK SWITCHES.
B.
illE SilIFT FOREMAN'S (HOW KNOWN AS SilIFT SUPERVISOR) PERMISSION WAS HOT OBTAINED PRIOR TO OVERRIDE Willi SWIICllES C61-534 A 8 8 AS RE QUI RED BY llHP-t- 150 0. SECII0ll G HOIE.
2.
PROCEDU RE llNP-34. RULES FOR PIRTOPMING PROCEDURES. WAS HO T BEING IMPLEMElliED TH Ill A T :
A.
PARAGRAPH B.2.,
STATES TilAI VERSAliM COMPLIANCE IS MANDAIORY.
HHP-t-8500 WAS HOT BEING PERFORMED VERB ATIM AS ST ATED ABOVE.
B.
PARAGRAPH B.3.. STATES THAT IF THE PR
,
OCEDURE-CAN HDT BC PERIORMED AS WRITIEH STOP AND C HANGE THE PROCEDifRE.
IIHP-I-1500 WAS t10T STOPPED 0 R CHANGED SUCH Ill A T VERBATIM Cot 1PLIANCE COULD BE M ET.
C.
PARAGRAPH B.4..
STATES TO HOTITY YOUR Int 1 EDIATE SUPERVISOR OF ANY PROCEDURE PROBLEMS.
THIS WAS NOT DONE IN THAT THE SHIFT SUPERVISOR DID HOT KNOW ABOUT THE UHAUTHORIZED USE OF MECHANICAL OVE RRIDE OR THAT THE OVERRIDE WAS IN PROGRESS.
3.
P PROCEDURE HNP-9. WAS HOT IMPLEMENTED IN THAT HO SR 0 CHANGE NOR PRB REVIEW OF A PROCEDURE CllANGE WAS OBTAINED AS REQUIRED BY HHP-9.
Tile USE OF Tile WRE HCHES TO OVERRIDE SPRING FORCE ON SWITCilES CONSTIT
-
UTES AH UNAUTHORIZrD PROCEDURE CHANGE.
4.
PROCED URE HHP-1-1500 WAS HO PROPERLY MAINTAINED IN THAT
"
THE SECTION G HOTE. STATED THAT THE SWITCHES C6I-3 54A 8 B WERE TO OVERRIDE A LOCA SIGHAL.
IllESE SWI l
-
ICHES 00 HOT OVERRIDE A LOCA SIGNAL.
...
,
050003218307 022683 012283
5 i
CONTRARY TO TECllHICAL SPECIFICATION 6.8.1 AND HHP-t-1917, ON FEBRUARY 18, 1982. Tile DIVISION II MANU AL ISOLATI0H VALVE WAS FOUND BY THE INSPECTOR TO B
-
E UNLOCKED AND OH FEBRUARY 24. 1982. ALL FOUR (2 P ER LOOP) RHR SERVICE WATER STRAINERS WERE FOUND BY THE INSPECTOR TO BE OH LINE.
,
050003218308 032583 031483
-
-
-
-?
-
~
-
.-
.
.
+
.
-
-
-
-
.
______- _ _.-_.-____.
_
_ _ _ -
.
_
8?/09/84 766 DATA FOR HAicit t - 05000328 PAGE 9 DATA SELECTED BY ENDING INSPEC. DATE JAN*t, 1982 TO FEBRUARY 10, 1904
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ' _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
DOCKET
FROM FIND-DEVIATIDH/
SEVERITY REPORT DATE DATE IHGS SEVERITY SUPPLEMENT TEXT
.-_______________________________________________________________________________________________________________________________
050003218309 032583 031483
3
10CFR50, APPINDIX
"B".
CRITERIA V, X AtID XVIII, AS IMPLEMENTED BY llAICll'S SAR SECTIDd 17.2.5, 17.2.1 0 AND 17.2.88, REQUIRE ACTIVITIES AFFECIING QUALIT Y ARE PRESCRIBED BY DOClliit HIED IllSIRUCT IDHS, ACIIV ITIES CONCERillflG SAFEIV-RILATED SYSitttS BE INSPECT ED TD VERIFY CutlFORMAllCE Willt DOCUt11HTED INSTRUCTI OtiS AND DRAWillGS. AllD AUDIIS ARE TO BE PERFORMED i 0 VERIFY C0t1PLI AtICE Willi APPL IC AB1E REGUL ATIONS AN D LICENSE REQUIRIMLills.
CONIPARY 10 IHE ABOVE, Til E APMINISTR AT IVE AtID (1Atl AGl:RI AL CutliROL SYST Ells IN EFFECT IN Tile ARIAS OF PROCEDURES INSPECTI0llS, AH D AUDITS WITil REGARD TO RESTORATION OF CABLE TRAY SYSTEMS 10 DESIGli STAtlDARDS AFIER RIPAIRS AND/OR M ODIFICATIDHS ARE IHADTQUAIE IN IllAT MAtlY CABL E TRA Y DISCRIPAHCIES (50011 AS. CABLE TRAY COVERS ret 10VE D. KADWUOL AND FIRE STOPS IN TRAY SYSifftS RItt0VED, AND CABLE TRAY 1101 D DOMH CL At1PS MADE IllL I I E C T I V E )
EXIST IllROUGil Olli IIIE Pt A H i.
TilESE ADMINISTRAIIV E AND MANAGERIAL C0t41ROL SYSTEMS IIAVE Brtli IHEFFEC TIVE IH ill A l DOCUttillT AT ION FOR TRACKING PURPOSES A HD SUBS [00ENT RESOLUTIDH FOR THESE CABLE TRAY DISC REPAtlCIES DO NOT EXIST.
050003218310- 032683, 022783
-
-
-
'
050003218311 041583 041183
-
-
-
050003218312 042883 042483
4 I
FAILURE TO IDENTIFY INDIVIDUALS ENTERING Tile PA, U HAUTHORIZED INDIVIDUALS WITHIM TIIE PA AND ESCORT U HARLE TO MAINTAIN CONTACT.
050003218313 042383- 032683
4 i
FAILURE TO TAKE C0dTROL ROOM VENTIL ATION SYSifM FI LIER BFD SAMPLED AS REQUIRED BY T ECllH I C A L SPECIFIC
"
ATIOHS 4.12.A.2.A.
~
050003218314.'050583 042683
-
-
~
050003218315 052083 G42483
4
'1 CONTRARY TO TECilHICAL SPECIFICATIONS 6.8.1 PROCED URES HHP-t-ft17 8 llNP-1-3358, WERE NOT PROPERLY IM PLEMENTED IN TilAI VALVE X42-F073D (SEAL WATER 10 "
D" RHR SERVICE WAILR PUMP) AND VALVE 243-F300C (IS DLATIDH 10 CABtE SPREADING ROOM SPRIHKLER MULTIMAT IC VALVE) WERE HOI LOCKFD IN POSIT'0H AS RE0llIRED BY THE RESPECTIVE PROCEDURES.
~
050E032t8316 060883 060683
-
-
,
.
,
=
,
.
-
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,-
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02/09/84 766 DATA FOR HAICH 1 - 05000321 PAGE le DATA SELECTED BY ENDING INSPEC. DATE JAN to 1982 10 FEB3UARY 10.
1984 i
DOCKET TO FRott FIND-DEVIATION /
SEVERITY REPORI DATE DATE INGS SEVERIIY SUPPLEMENT TEXT
-.________________...._______..._________.._______ ___________......__....___.....___.__..___________.__..__________.____.
050003218317 052783 052383
4
10CFR20.301 SPECIFIES AUlll0RIZED METil0DS FOR DISP OSAL OF IICENSED MAILRI AL APID FR0llIBIIS DISPOSAL 8 Y DIHER MEAHS.
ONE Allill0RIZFD TIEll10D IS BY 1RANSF ER TO AN AUill0RIZED RECIPIEHi PURSUANT TO illE SPEC IFIC LICENSE REQUIREt1EHIS OF THE RECIPIENT.
CONTR ARY TO it!E ABOVE, OH MARCH 22, 1983. THE LICENSEE DISPOSED OF HINE, HINEIV-SIX CUBIC FOOT METAL E0XE
,
S OF C0t1PACTED RADIDACTIVE WASTE, BY TRANSFER FOR LAND BURIAL TO Clllil-HilCL E AR SYSIEt15, IHC., WlIG5E S 0U111 CAROLINA LICEllSE (HO. 097) DOES NOT AUTil0RIZE RECEIPT OF LIQllID llASTE FOR LAND BURIAL.
OllE BOX ( IINP - 8 3-3 21 ) Colli Altl[D APPROXIt1AT EL Y F IVE QUARis OF FREE ST ANDIllG L IQUID.
050003218318 062083 052083
-
-
-
050003218319 070883 070583
-
-
~
050003218320 072083 062183
-
-
~
050003218321 081283 080883
'4
10CFR20.20t(B) REQUIRES Tile LICENSEE TO PERFORM SU RVEYS AS HECESSARY 10 DEMONSTRATE COMPLIANCE WITH 10CFR20.106 WilICil LIMITS Tile RELEASE OF RADIDACTIV ITY IH UHRESTRICTED AREAS TO C0llCENTRATI0lls IN APP ENDIX B.
TABLE II AND TO EVALUATE TIIE EXTENT OF RA DIATION llAZARDS THAT MAY BE PPESENT.
CONTRARY TO illE ABOVE, FAILURE TO PROPERLY EVALUATE AHD TAKE C ORRECTIVE ACTION IN REGARD 10 A SYSTEMATIC CollCENT
-
RATIONS IN GROUHDtIA T ER S AMPLES COL LECT E D DURItiG AN AUGUST 1982 sat 1PLING OF MOHITORING WELLS.
ill!S F
-
ALLURE RESULTED IN AN OVERSIATEMEHi 0F TRIT IUll 00tl ENTRATIDHS IN Tile GROUND WATER.
'
~
40003218322 081083 081083
-
-
050003218323 080583 080283
-
-
-
'
050003218324 081983 081783
-
-
-
- 050003218326 093083 092681
-
-
~
050003218327 093083 082083
-
-
~
030003218328 093083 092683
-
-
'
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.
.
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.
_
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__
,
. _ - - _.
m/09/84 766 DATA FOR HATCH t - 05000321 PAGE 11 DATA SELECTED BY ENDING IHSPEC. DATE JAN 1 1982 TO FEBRUARY 10. 1984
...-----------------------------------------------------------------------------------------------
DOCKET TO FROM FIND-DEVIATION /
SEVERITY REPORT DATE DAIE INGS SEVERITY SUPPLEMENT TEXT
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
050003218329 101483 101183
-
-
-
050093218330 103183 100183
4
FAILURE TO SET FIRE WATCHES WHEN PORTIONS OF THE F IRE PROTECTION SYSTEM WAS INOPERABLE AS REQUIRED 8 Y TECHNICAL SPECIFICATIONS 3.13.1 ACTIDH I FOR UNI T 1,AND 3.7.6.2 ACIIDH 2 FOR UNIT 2.
050003218331 111883 181483
-
-
-
050003218333 120183 182983
-
-
-
050003218335 121683 182183
-
-
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02/09/84 766 DATA FOR HATCH 2 - 05000366-PAGE 1 DATA SELECTED BY ENDING INSPEC. DATE J,A N 1 1982 TO FEBRUARY 10.
1984
l--------------------------------------------------------------------------------
DOCKET TO FROM FIND-DEVIATION /
SEVERITY REPORT DATE DATE INGS SEVERITY SUPPLEMENT TEXT
n 050003668201 011582 011282
-
-
-
050003668202 012082 122181
-
-
-
050003668203 012982 012882
-
-
-
,
050003668204 021182 020882
-
-
-
050003668205 021282 020882
5
FAILURE TO FOLLOW APPROVED PHYSICAL SECURITY PLAN 050003668206 021282 021182
-
-
-
10003668207 022682 022282
5
ENVIRONMENTAL TECllHICAL SPECIFICATION 5.6 REQUIRES DETAILED WRITTEM PROCEDURES, INCLUDING APPLICABLE CHECK LISTS AHD INSTRUCTIONS, Sil AL L BE PREPARED A HD FOLLOWED FOR ALL ACTIVITIES INVOLVED IN IMPLEME HTING Tile ENVIR0titlENT AL TECllHICAL SPECIFICATI0HS.
LICENSEE PROCEDURE HHP-7650 REQUIRES ALL 9ATA AND RESULTS GENERATED AT THE PLANT SITE BE REVIEllED I NA tit 1ELY MAHHER.
CONTRARY TO THE ABOVE, LICEllSE E PROCEDURE HHP-7650 WAS NOT ADHERED TO IN THAT HU MEROUS DATA SHEETS WERE HOT REVIEWED FOR ONE AND T WO MONTHS.
lH ONE LASE A REVIEW OF A UAla SilEET W AS HDT MADE FOR ONE YEAR.
050003668208 031982 030282
5
CONTRARY TO CRITERION V 0F APPENDIX B 10 10CFR50.
ACTIVITIES AFFECTING QUALITY WERE HOT ACCOMPLISHED Ih' ACCORDANCE WITH DOCUMENTED PROCECURES APID DRAW INGS IN THAT THE CB8I WELDING QA SUPERVISOR HAD SI GHED OFF THE FITUP OH WELD B-4 ON DRAWING RS6 AND OHE MEMBER OF THE JOINT WAS CUT SQUARE IN LIEU OF Tile REQUIRED 15 DEGREE LEVEL IN VIOLATION OF CB8I QA MANUAL, SECTIDH 8, PARAGRAPH 8.5.3.
-
10003668209 030182 012182
5
10CFR50, APPENDIX B. CRITERI0H V, REQUIRES ACTIVIT
IES AFFECTING QUALITY SHALL BE PRESCRIBED BY DOCUM
.
ENTED IHSTRUCTIDHS. PROCEDURES OR DRAWINGS. OF A T YPE APPROPRIATE TO THE CIRCUMSTANCES AtID SHALL 8E ACCOMPLISHED IN ACCORDANCE WITH THESE IllSTRUCTIONS PROCEDURES OR DRAWINGS. PLANT PROCEDURE llHP-822
,
, MATERIAL INSPECTIDH REQUEST, STEP 6.1.A REQUIRES
~
A TWO PART QC HOLD TAG BE ATTACHED TO MATERIAL TO BE INSPECTED.
CONTRARY TO THE ABOVE. OH JANUARY
1982, QC HOLD TAGS WERE NOT ATTACllED AS REQUIR ED TO APPROXIMATELY 100 SPARE JOHHSON PUMP PARTS I H THE WAREll0USE.
,
~
-
.
s.
l
.
,
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g
- -
--
_ _ _ _ _ - _ _ _ _ _
02/09/84 766 DATA F02 HATCH 2 - 05000366 PAdE 2
DATA SELECTED BY ENDING IHSPEC. DATE JAN 1,
1882 10 FEBRUARY 10, 1984
---.......-....................................l................................................................................
DOCKET TO FROM F IliD-DEVIATIOH/
SEVERITY REPORT DATE DATE INGS SEVERITY SUPPLEMENT TEXT
?
i i
-
-
-
-
--~~~------"
----------- -~~~----- ECGsiEit iFECIFiciii5s s i!i--EEiGiiEE isii Giiii
~~isiiiiiiiii-~~iiiiii--iiiiii----5 Ett PRUCEDURES SHALL BE ESTABLISilED. IMPLEMENTED AH D MAItii AltiED COVERIfiG TiiE APPLICADLE PROCEDURES RE COMr1 ENDED IN APPLHDIX "A" 0F REGULATORY GUIDE 1.33 REVISIDH 2.
FEBRUARY 1978 AND SURVEILLANCE AHD T
,
EST ACTIVITIES OF SAFETY-RELATED EQUIPMEHi.
CONTR ARY TO THE ABOVE TECilllICAL SPECIFICATI0ll, PLANT PR OCEDURE HHP-2-3410, SURVEILLANCE Or Tile RCIC STEAM LINE DELTA P IHSTRUMEHIS, WAS HOT PROPERLY MAINTA IHED OR REVIEWED IN T il A T AN INCORRECT +142 IHCil VA LVE EXISTED IH STEP F.2.0 0F Tile PROCEDURE FOR SET TING Tile RCIC HIGIl STEAM FLOW ISOLATION SETPOINT F OR Tile INDOARD ISOLATI0H VALVE.
050003668209 030182 012182
4
TECllHICAL SPECIFICATI0H 3.3.2, REQUIRES TilAT Tile I SOLATION ACTUATIDH Ills T RUMElli A T IDH Cll ANNEL S IN TAB LE 3.3.2-1 BE OPLRADLE WITH TRIP SEIPOINIS CONSIST EHT WITH Tile VALVES Sil0HH IN T ABLE 3.3.2-2.
IF H0 T OPERABLE, Tile CII AllilEL MUST BE RESTORED 10 OPERAB L E ST ATUS WI TilIN 2 Il0URS OR Till AFFECT ED SYST El1 IS ISOLATED.
C0ll T R AR Y TO Tile A80VE, Tile ISOLATION A CTUATIDH INSTRUMEHTATION SETPOIHi FOR Tile HIGil STE AM FLOW ISOLATION SIGHAL OF illE RCIC INBDARD ISOLA TION VALVE WAS HOT SET GREATER THAH OR EQUAL TO 30 0% OF RATED FLOW AS REQUIRED BY TABLE 3.3.2-2 ITEM S.A.
THE SYSTEM WAS HOT ISOLATED AHD DECLARED IN OPERABLE AS REQUIRED BY TABLE 3.3.2-2 ITEM 5.A.
T 1815 CONDITION HAD EXISTED WITH THE LICENSEE'S KNOW LEDGE FOR APPROXIMATELY TWO AND ONE HALD YEARS UNT IL PROPERLY ADJUSTED OH JANUARY 11, 1982.
CONTRAR Y TO Tile ABOVE TECHH{ CAL SPECIFICATION, Tile ISOLAT ION ACTUATION SETP0lHT FOR Tile RCIC IllBOARD SYSTEM LINE ISCLATION VALVE WAS ERROMEOUSLY SET TO A MOM
-
CONSERVATIVE VALVE OH JANUARY 28, 1982 DUE TO file LICENSEE'S FAILURE TO PROPERLY IMPLEMENT A CilAHGE
TO PROCEDURE HHP-2-3410. RCIC STEAM LIHE DELTA P I HSTRUMEHT FUNCTIONAL TEST AHD CALIBRATIOH.
TECilHICAL SPECIFICATION 6.9.t.8.I. REQUIRES WilEH P ERFORMAtICE OF C0f1P0HENTS REQUIRES REMEDI AL ACTION OR CORRECTIVE NEASURES TO PREVENT OPERATIDH IN A M AHilER LESS CONSERVATIVE THAN ASSUMED IN Tile ACCIDE
-
HT AHALYSES, SAFEIY ANALYSIS REPORT OR T ECilHI C A L 5 PECIFICATION BASES Til A T IT BE REPORTED TO Tile REGI OHAL OFFICE WITHIH 24 fl0URS.
CONTRARY TO Tile ABOV E,
Tile EXISTENCE OF A NON-CONSERVATIVE SETTIllG FOR THE RCIC INBOARD STEAM LINE ISOLATION VALVE TRIP
~
..
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.
I
..
.
-.
-
.-
- -. ---._
--...
. -.
02/09/84 766 DATA FOR HATCH 2 - 05000366 PAGE 3 DATA SELECTED BY ENDING INSPEC. DATE JAN 1,.1982 TO FEBRUARY 10, 1984 J-------...........-........................--......--.....----...-----.......
. - -... -.... -.. - -............ -............. - -
DOCKET TO FROM FIND-DEVIATION /
SEVERITY REPORT DATE DATE INGS SEVERITY SUPPLEMENT TEXT
---..-- ------........-.........--......-.................................................................... -..............
050003668209 030182 012182
4
SEiPOINT WAS NOT REPORTED PROMPTLY TO THE REGIONAL OFFICE WITHIN 24 HOURS AS REQUIRED WHEN IT WAS DI SCOVERED IN THE FALL OF 1979 AND AGAIN DH JANUARY 11, 1982 (TWO EXAMPLES).
050003668210 031282 031082
-
-
-
,
050003668211 040282 032982
5
TECHNICAL SPECIFICATION 6.8.1, REQUIRES THAT WRITT EN PROCEDURES BE ESTABLISHED, IMPLEMLHTED AND MAIN TAINED COVERING THE APPLICABLE PROCEDURES RECOMMEN DED IN APPENDIX "A" OF REGULATORY GUIDE 1.33.
REG ULATORY GUIDE 1.33, APPENDIX
"A" STATES IN PART TH AT RADIATION PROTECTION PROCEDURES SHOULD BE PROVI DED.
PROCEDURE HHP-8005, REVISION 12, SECTION I, RADIATION OCCURREHCE REPORTS, PARAGRAPH I.(B)(2) R EQUIRES ACTION TO BE TAKEN TO ENSURE THE REPORTED
'
EVENT DOES NOT RECUR.
CONTRARY TO THE ABOVE, RADI ATIDH PROTECTION PROCEDURES WERE NOT ESTABLISHED, IMPLEMENTED AND MAINTAINED IN THAT THE ACTIDH DESI GNATED TO CORPECT MISUSE OF PERSONNEL DOSIMETRY BY AN INDIVIDUAL ON MOVE!1 DER 3, 1981, WAS NOT PERFOR MED.
SPECIFICALLY, THE PRESCRIBED NOTIFICATION OF ALL EMPLOYEES ON OCCURRENCE REPORT 81-19A WAS NOT PERFORMED.
050003668212 032082 030282
-
-
-
050003662213 0504A2 042882
-
-
-
,
050003668214 042082 032182'
-
-
-
050003668215 050582 050482
3
FAILURE TO CONTROL ACCESS TO THE PROTECTED AREA.
i 050003668216 060482 060182
-
-
-
. 0003668217- 051382 041982
-
-
-
,
050003668219 052582 042182
-
-
.
! - 050C03668220 062182 052682
4
FAILURE TO REC 9GNIZE LCO CONDITION ON
"A" RESIDUAL HEAT REMOVAL TRAIN AND HALT FUEL LOADING IN ACCOR DANCE WITH TECHNICAL SPECIFICATION 3.9.12.A.
050003668221 072382 072182
-
-
-
050,003668222 073082 072682
4 I
FAILURE TO PROVIDE QA INDOCTRINATION TO ALL MON QA
.
-
-
.
...
.
'
.
i mm-erw e v--
,
.--4m-
,
c.
- --
-,,. - - - -
-, -
_ _ _ _ _ _ _ - _ _ - - _ - _ _ _ _ _ __
02/09/84 766 DATA FOR HATCH 2 - 05000366 PAGE 4 DATA SELECTED BY ENDING INSPEC. DATE JAM 1,
1982 TO FEBRUARY 10, 1984
'
....----------------------------------------------------------------------------------e DOCKET TO FROM FIND-DEVIATIDH/
SEVERITY REPORT DATE DATE INGS SEVERITY SUPPLEMENT TEXT
<
050003668222 073082 072682
4
PERSOHHEL AND FAILURE TO PROVIDE SPECIALIZED INST RUCTION TO PLANT OPERATORS, MAINTENANCE PERSOHNEL, TEST PERSONNEL, QC AND HEALTH PHYSICS PERSOHHEL I H THEIR AREAS OF QA PROGRAM IMPLEMENTATION AS REQU IRED BY 10CFRS0, APPENDIX B, CRITERION II AND THE LICENSEE'S ACCEPTED QA PROGRAM.
FAILURE TO PROVIDE A SCHEDULED PREPLANNED LECTURE
,
SERIES BASED OH EVALUATION OF AHHUAL WRITTEN LICEH SED OPERATOR EXAMINATION AS REQUIRED BY 10CFR55, A PPENDIX A.
050003668223 072282 071882
-
-
-
.
c_J003668224 072682 062282
4
FAILURE TO POST F TE WATCHES FOR AN EXTENDED PERIO D IN ACCORDANCE WITH TECHNICAL SPECIFICATION REQUI REMENTS WHEN INADEQUATE FIRE BARRIERS WERE FOUND T 0 EXIST.
050003668225 081382 080982
-
-
-
050003668226 082782 072782
-
-
-
050003668227 090382 083082
-
-
-
050003668228 100182 092882
-
-
-
050003668229 092382 092082
-
-
-
050003668230 092882 082882
5
FAILURE OF LICENSEE PERSOHHEL TO PROPERLY FRISK WH EN ENTERING THE CONTROL ROOM.
INSPECTOR FOUND FRI l
SKER TURNED OFF AND UHPLUGGED.
FAILURE TO NOTIFY MRC WITHIH 1 HOUR AS REQUIRED BY 50.72 DN IHOPERABLE SBGT SYSTEMS ON UNIT 1 AND EC
-
CS ACTUATIDHS OH UNIT 2 (TWO EXAMPLES).
- us00036682317 102982 102582
-
-
-
050003668232 110582 110182
-
-
-
050003668233 102882 092882
4
IHADEQUATE SURVEILLANCE PROCEDURES.
LOGIC TESTS 0 J~
H HPCI, RCIC, ADS, RPS, SBGT, CS, PCIS AND C0HTAIN MENT PURGE AND INERTING SYSTEMS WERE FOUND HOT TO BE C0t1PLETE FROM SENSOR TO ACTIVATED DEVICE AS REQ UIRED BY TECHNICAL SPECIFICATIONS.
050,003668234 120682 113082
4
ENVIRONMENTAL TECHNICAL SPECIFICATION 5.3.2.2 REQU
.
..
s
I
_ _ _ _
__
._
_
02/09/84 766 DATA F02 HATCH 2 - 05000366 PAGE 5 DATA SELECTED BY ENDING INSPEC. DATE 4AH 1,
1982 TO FEBRUARY 10, 1984
..---------------
L.----------_-_-----_
.....---------------------------------------------------- u DOCKET TO FROM FIND-DEVIATION /
SEVERITY REPORT DATE DATE INGS SEVERITY SUPPLEMEMT TEXT
__----_-__------_----------------------____--____------------------------------------------------__----a 050003668234 120682 113082
4
IRES THAT AUDITS OF FACILITY ACTIVITIES SHALL BE P ERFORMED AT LEAST ONCE A YEAR UNDER Tile COGNIZANCE OF THE SRB TO ENSURE CONFORMANCE OF FACILITY OPER ATION OF ALL PROVISIDHS OF Tile ENVIRONMENTAL TECHN ICAL SPECIFICATI0HS (ETS).
ETS-3.2. TABLE 3.2-1, SPECIFIES Tile PERFORMANCE OF AN ANALYTICAL PP0 GRAM CONTRARY TO Tile ABOVE, AUDITS OF Tile ANALYTICAL
. PROGRAM WERE NOT PERFORNED IN 1980, 1981 AND 198 2.
TilROUGH DECEt1BER 6, 1982.
050003668234 120682 113082
D OCOM-IN A LETTER DATED DECEMBER 30, 1982, HRC REGI ON II ISSUED A HOTICE OF VIOLATION TO Tile GEORGIA POWER COMPANY.
THE HOTICE IDENTIFIED A VIOLATION OF ENVIRollMENT AL TECilHICAL SPECIFICATION 5.3.2.2, DISCLUSED DURING HRC INSPECTION HOS. 50-321/81-24 AND 50-366/81-24, FOR llAVING FAILED TO COHOUCT AUD ITS OF ITS ANALYTICAL PROGRAM.
GEORGIA POI.!ER COMP ANY RESPONDED TO Tile HRC CITATION IN A LETTER DATE D DECEMBER 30, 1981 DESCRIBING CERTAIN CORRECTIVE AND PREVENTIVE ACTION TAKEH OR PLAHHED.
Tile FOLL OWIHG SIATEMENT WAS IHCLUDED IN THIS LETTER:
BY A PRIL 1,
1982. GEORGIA POWER C0f1PANY WILL DEVELOP A PROGRAM TO PROVIDE FOR ANNUAL QA AUDITS OF CONTRA CTOR ACTIVITIES RELATED TO THE ENVIROHt1 ENTAL MONIT ORING.
IMPLEMENTATION OF THIS PROGRAM WILL BEGIN l
IN APRIL 1982.
CONTRARY TO Tile ABOVE, AS OF DECEM BER 6, 1982, THE LICENSEE HAD HDT DEVELOPED A PROG RAM TO PROVIDE FOR AHHUAL QA AUDITS OF CONTRACTOR ACTIVITIES RELATED TO THE ENVIRONMENTAL MONITORING
.
050003668235 111982 111682
-
-
-
050003668236 11'1982 111682
-
-
-
500036682}7 112082 102882
5
FAILURE TO FOLLOW PROCEDURE.
VALVE LINEUP FOR RHR SERVICE WATER STRAINER VALVES 2E11-F1168 AND 2E11-F 117B b!AS IMPROPER IN THAT BOTH VALVES Sil0ULD HAV
'
E BEEN LOCKED SilUT BUT F1168 WAS UNLOCKED AND F117 B WAS OPEH.
-
050003668238 111982 111582
-
-
-
050003668239 121082 120682
-
-
-
l 050003668240 121582 121382
4
CONTRARY TO 10CFR50, APPENDIX
"B", CRITERION XVI A
-
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~
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.
-_______- - _
l 02/09/84 766 DATA FOR HATCH 2 - 05000366 PAGE 6 l
DATA SELECTED BY ENDING IHSPEC. DATE j
JAN 1,
1982 TO FEBRUARY 10, 1984
'
l
DOCKET TO FROM FIND-DEVIATION /
SEVERITY REPORT DATE DATE INGS SEVERITY SUPPLEMENT TEXT
_----------------------_---------------------------------------------------------------------------------------c 050003668240 121582 121382
4 t
HD I, AND THE ACCEPTED QA PROGRAM (FSAR 17.2.16 AN D 17.2.1), THE QA DEPARTMENT DOES NOT EFFECTIVELY ASSURE CONFORMANCE 10 QUALITY STANDARDS IN THAT IT DOES NOT ASSURE PROMPT CORRECTION OF CONDITIONS A DVERSE TO QUALITY.
SPECIFICALLY ONE ITEM WIRTTEN IN 1978, TWO ITEMS WRITTEN IN 1979, SEVEN ITElls WR ITTEN IN 1980 AND SEVEN ITEMS WRITTEN IN 1981 STIL L REMAIN OPEH.
ALL THESE ITEMS WERE IDENTIFIED BY THEIR QA AUDIT SYSTEM.
CONTRARY TO 10CFR50, APPENDIX
"B",
CRITERION V.
TN E ACCEPTED QA PROGRAM (FSAR 17.2.5) AND LICENSEE P ROCEDURES QA-05-06 AND QA-05-01, SIX AUDIT FINDING S WERE Hni RESPONDED TO WITHIN THE REQUIRED 30 DAY TIME PERIOD.
050003668240 121582 121382
5 t
CONTRARY TO THE ACCEPTED QA PROGRAMS, ENDORSEMENT OF ANSI N 45.2.23. Tile LICENSEE DID NOT UPDATE QU ALIFICATIONS OF 4 0F 5 LEAD AUDITORS ANNUALLY.
050003668241 121982 112082
-
-
-
050003668301 012183 011883
-
-
-
050003668302 012183 122082
5
IMPROPER REPORTING OF LOW FIRE SUPPRESSION WATER S YSTEM TANK LEVELS.
THE REQUIRED 24 Il0UR T EL EPil0H E REPORT OF TECHNICAL SFECIFICATION 3.7.6.1 WAS NOT MADE WilEN FIRE SUPPRESSION WATER SYSTEM TANKS FEL L BELOW TECHNICAL SPECIFICATION LIMITS.
050003668303 020383 012983
-
-
-
050003668304 021183 020783
5
CONTRARY TO 10CFR50.72(A)(1), THE LICENSEE DID NOT
-
NOTIFY THE NRC OPERATIONS CENTER WITHIN ONE HOUR FOLLOWING A LIQUID RELEASE OF I-131 FROM CHEMICAL
,
WASTE SAMPLE TASK "A" WHICH EXCEEDED TECHNICAL SPE
-
CIFICATIDHS AND 10CFR20, APPENDIX
"B",
TABLE II, C DLUMN 2, LINITS.
THE RELEASE CONCENTRATION WAS 8.
5X10-7 MICR0 CURIES PER MILLILITER: THE LIMIT IS 3.
0X10-7 MICR0 CURIES PER MILLILITER.
A 30-DAY LER W
-
AS SUBMITTED AS REQUIRED BY TECllNICAL SPECIFICATI0 NS.
050003668305 022583 022283
-
-
-
050003668306 103182 070181
-
-
-
-
.
...
e
+
.
e
_ _ _ _ _
_.
_
._
_.
.
_ _ _
_
._ _
_
02/09/84 766 DATA FOR HATCH 2 - 05000366 PAGE 7 DATA SELECTED BY ENDING INSPEC. DATE JAN 1,
1982 TO FEBRUARY 10, 1984 i
DOCKET TO FROM FIND-DEVIATION /
SEVERITY REPORT DATE DATE INGS SEVERITY SUPPLEMENT-TEXT
;
050003668307 022683 012283
-
-
-
050003668308 032583 031483
4
10CFR50, APPENDIX
"B",
CRITERI0H V, AS IMPLEMENTED BY FSAR SECTION 1/.2.5, REQUIRES THE LICENSEE TO ACCOMPLISH ACTIVITIES AFFECTING QUALITY IN ACCORDA NCE WITH PRESCRIBED PROCEDURES. CONTRARY TO THE A BOVE, THE LICENSEE DID HDT REVISE PROCEDURE HHP-2-3801, REV. 17, IN ACCORDANCE WITH THE REQUIREMENTS OF THE PRESCRIBED PROCEDURE, PROCEDURE HHP-9.
PR OCEDURE WRITING, USE AND CONTROL", REQUIRED THAT A LL REVISIDHS TO A PROCEDURE BE ENTERED OH A "PROCE DURE REVISION REQUEST FORM" INDICATING THE REASON FOR THE PROPOSED CHANGE.
HOWEVER, STAHDBY DIESEL SERVICE WATER PUMP VIBRATION ACCEPTANCE CRITERIA N ERE CHANGED IN PROCEDURE HHP-2-3801, REV. 17 WITH OUT ENTERING THE REASON ON A PROCEDURE REVISION RE QUEST FORM.
050003668309 332583 031483
3
10CFR50, APPENDIX
"B",
CRITERIA V, X AND XVIII AS
,
IMPLEMENTED BY HATCH'S SAR SECTION 17.2.5, 17.2.1 l
0 AND 17.2.18. REQUIRE ACTIVITIES AFFECTING QUALIT Y ARE PRESCRIBED BY DOCUMENTED INSTRUCTIONS, ACTIV ITIES CONCERNING SAFETY-RELATED SYSTEMS BE INSPECT ED 10 VERIFY CONFORMANCE WITH DOCUMENTED INSTRUCTI ONS AND DRAWINGS, AND AUDITS ARE TO BE PERFORMED T U VERIFY COMPLIANCE WITH APPLICABLE REGULATIONS AN D LICENSE REQUIREMENTS. CONTRARY TO THE ABOVE, TH E ADMINISTRATIVE AND MANAGERIAL CONTROL SYSTEMS IN EFFECT IN THE AREAS OF PROCEDURES INSPECTIONS, AN D AUDITS WITH REGARD TO RESTORATION OF CABLE TRAY
,
SYSTEMS TO DESIGH STANDARDS AFTER REPAIRS AND/0R M
,
,
ODIFICATIONS ARE INADEQUATE IN THAT MAHY CADLE TRA Y DISCREPANCIES (SUCH AS, CABLE TRAY COVERS REMOVE
-
D. KA0 WOOL AND FIRE' STOPS IN TRAY SYSTEMS REMOVED, AND CABLE TRAY HOLD DOWN CLAMPS MADE INEFFECTIVE)
~. ' '
EXIST THROUGH OUT THE PLANT.
THESE ADMINISTRATIV E AND MANAGERIAL CONTROL SYSTEMS HAVE BEEN INEFFEC
,
TIVE IN THAT DOCUMENTATION FOR TRACKING PURPOSES A ND SUBSEQUENT RESOLUTION FOR THESE CABLE TRAY DISC
_
REPANCIES DO HOT EXIST.
050003668310 032683 022783
-
-
-
050003668311 041583 041183
-
-
-
U50003668312 042883 042483
4
FAILURE TO IDENTIFY INDIVIDUALS ENTERING THE PA, U
.
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-.
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. -
. -
- - _.
-.
-
-
02/09/84 766 DATA FOR HATCH 2 - 05000366 PAGE 8 DATA SELECTED BY ENDING INSPEC. DATE JAN 1,
1982 TO FEBRUARY 10, 1984
--_____________-____-________________-_________J_____-______________________________________-_______-___________.__________-__
DOCKET TO FROM FIND-DEVIATION /
SEVERITY REPORT DATE DATE Ih0S SEVERITY SUPPLEMENT TEXT
_ _ - - _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ - _ _ _ _ _ _ _ _ _. - _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _
050003668312 042883 042483
4
NAUTHORIZED INDIVIDUALS WITHIH THE PA AND ESCORT U HABLE TO MAINTAIN CONTACT.
050003668313 042383 032683
-
-
-
-
-
-
050003668314 0S0583 042683
050003668315 052083 042483
-
-
-
050003663316 060883 060683
5
TECHNICAL SPECIFICATION 6.8.1.C, REQUIRES THAT PRO CEDURES BE IMPLEMENTED FOR SURVEILLANCE OF SAFETY-RELATED EQUIPMENT.
PARAGRAPH G OF THE APPLICABLE PROCEDURE FOR IECHNICAL SPECIFICATION REQUIREMENTS 4.4.8, REQUIRES IN PART THAT, FOR FLAW INDICATION S FOUND DURING INSERVICE INSPECTION AHD REPORTED 0 H AN INDICATION HOTIFICATIDH FORM, SUFFICIENT HOND ESTRUCTIVE TEST EXPERTISE ADEQUATELY RESOLVE HECES SARY REFAIR WORK TO ELIt11 HATE THE FLAW INDICATION OR PROVE IHSIGHIFICANT THE SOURCE OF THE INDICATI0 H.
CONTRARY TO Tile ADOVE, ON APRIL 28, 1982, PROC EDURE HHP-904 WAS NOT PROPERLY IMPLEt1ENTED IN THAT THE LIQUID PENETRANT INSPECTION FOR WELD 2 Ell-1RH-20-RS-1BC/2G21-1RWCU-6D-1 WAS ACCEPTED WITHOUT HE CESSARY REPAIR WORK TO ELIMINATE OR PROVE INSIGNIF ICANT ROUGH CONDITIONS IN THE WELD EDGES WHICH HEL D EXCESS PEHETRANT POSSIBLY MASKING SIGHIFICANT TH DICATIONS.
050003668317 052783 052383;
4
10CFR20.301, SPECIFIES AUTHORIZED METHODS FOR DISP DSAL OF LICENSED MATERIAL AND PROHIBITS DISPOSAL 8 Y OTHER MEANS.
ONE AUTHORIZED METHOD IS BY TRANSF ER TO AN AUTHORIZED RECIPIENT PURSUANT TO THE SPEC
.
IFIC LICENSE REQUIREMENTS OF THE RECIPIENT.
CONTR
'
ARY TO THE ABOVE, ON MARCH 22, 1983 THE LICENSEE
-
DISPOSED OF HIHE. HINETY-SIX CUBIC FOOT METAL BOXE S OF COMPACTED RADI0 ACTIVE WASTE, BY TRANSFER FOR
.-
LAND BURIAL TO CHEM-HUCLEAR SYSTEMS, INC., WHOSE S OUTH CAROLINA LICENSE (HO. 097) DOES NOT AUTHORIZE RECEIPT OF LIQUID WASTE FOR LAND BURIAL. ONE BOX (HHP-83-321) CONTAINED APPROXIMATELY FIVE QUARTS OF FREE STANDING LIQUID.
~
050003668318 062083 052083
-
-
~
050003668319 070883 070583
-
-
-
t
-
- . *
I
.
,
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-.. - -.
, - -
,
,, -. -.
, --,., - -
--
, - - -
,., -,.,,, - -,
02/09/84 766 DATA FOR HATCH 2 - 05000366 PAGE 9 DATA SELECTED BY ENDIHG IHSPEC. DATE JAN 1,
1982 TO FEBRUARY 10, 1984
.-
l--------------------------------------------------------------------------------
DOCKET TO FROM FIND-DEVI A',*IDH/
SEVERITY REPORT DATE DATE INGS SEVERTTY SUPPLEMENT TEXT
.
050003668320 07?O83 062183
5
10CFR50, APPENDIX B, CRITERION V, AS IMPLEMENTED B Y THE HATCH UNIT 2 FSAR, PARAGRAPH 17.2.5 REQUIRES TilAT ACTIVITIES ATFFcTING QUALITY SIIALL BE ACCOMP LISHED IN ACCORDANCE WITil DOCUMENTED INSTRUCTIDHS, PROCEDURES, OR DRAWINGS.
ADDITIONALLY, HATCH UNI T 2 FSAR, PARAGRAPH 8.3.1.5 AHD HATCil UNIT 2 PROCE DURE HHP-6921 REQUIRE TilAT ELECTRICAL CABLES BE CO LOR CODED AT APPROXIMATELY 10 FOOT INTERVALS.
CON TRARY TO THE.ABOVE, PROCEDURES WERE HOT FOLLOWED I N TilAT SEVERAL CABLES LOCATED IN WEST CABLEWAY TRA YS, HUMBERS ESS-I 2flB5297 AND 8, AND ESS-I 2ABA7-0 1 2343 NOT COLOR CODED.
.0003668322 081283 080883
4
10CFR20.201(B) REQUIRES THE LICENSEE TD PERFORM SU RVEYS AS HECESSARY TO DEMONSTRATE COMPLIANCE WITH 10CFR20.106 WHICH LIMITS Tile RELEASE OF RADIDACTIV ITY IN UHRESTRICTED AREAS TO COHCENTRATIONS IN APP ENDIX B.
TABLE II AND TO EVALUATE THE EXTENT OF RA DIATION HAZARDS TilAT MAY BE PRESENT.
CONTRARY TO THE ABOVE, FAILURE TO PROPERLY EVALUATE AND TAKE C ORRrCTIVE ACTION IN REGARD TO A SYSTEMATIC COHCENT RATIONS IN GROUNDWATER SAMPLES COLLECTED DURING AH AUGUST 1982 SAMPLING OF MOHITORING WELLS.
THIS F AILURE RESULTED IN AH OVERSTATEHENT OF TRITIUM CON ENTRATI0HS IN THE GROUND WATER.
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TECHHICAL SPECIFICATION 6.8.1 STATES TilAT PROCEDUR ES SHALL BE WRITTEH, APPROVED AND IMPLEMENTED FOR REACTOR OPERATIONS.
CONTRARY TO THE ABOVE, ON JUL Y 14, 1983, CONTROL ROD MAHIPULATIDHS WERE CONDUCT ED IN VIOLAITON OF WRITTEM AND APPROVED PROCtDURES RESULTING IN CONTROL ROD PATTERHS OUTSIDE THOSE
,
ANALYZED FOR THE ROD DROP ACCIDENT DESCRIBED IN FS
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AR CHAPTER 15.1.38.
THESE MAHIPULATIDHS WERE IMPR
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OPERLY ACCOMPLISilED BY SCRAMMING CONTROL RODS FROM THE SCRAM TIME TEST PAHEL (2H11-P610) AHD INSERTI HG CONTROL RODS USING THE EMERGENCY IN SWITCil INST EAD OF THE APPROVED PROCEDURAL METHOD OF IHSERTING CONTROL RODS IN HOTCH CONTROL FORM Tile MAIN CONTR
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TECHHICAL SPECIFICATION 3.1.4.1 REQUIRES THE ROD W ORTH MINIMIZER ( RWf t ) TO BE OPERABLE OR A SECOND LI CENSED OPERATOR OR OTilER QUALIFIED MEMBER OF THE T ECHHICAL STAFF TO BE PRESENT AT THE REACTOR CONSOL E TO VERIFY COMPLI ANCE WITil THE PRESCRIBED COHTROL ROD PATTERN.
CONTRARY TO THE ABOVE, OH JULY 14, o
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1982 TO FEBRUARY 10, 1984
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1983, AFTER BYPASSING THE RWN. A SECOND PERSON DID HDT VERIFY COMPLIANCE WITH THE PRESCRIBED ROD PAT TERN.
AS A C0HSEQUENCE, Tile ROD INSERTION SEQUEHC E WAS VIOLATED AS EVIDENCED BY CONTROL ROD 42-39 A T HOTCH 12 VERSUS THE REQUIRED HOTCH 48.
TECHNICAL SPECIFICATI0H 3.1.4.2 REQUIRES THAT THE ROD SEQUENCE CONTROL SYSTEM (RSCS) BE OPERABLE IN OPERATION CONDITION 1 WilEH TilERMAL POWER IS BELOW 20%.
CONTRARY TO THE ABOVE, OH JULY 14, 1983. Will LE IN OPERATION CONDITION 1.
WITH THERMAL POWER BE LOW 20%. THE RSCS WAS NOT OPERATIDHAL IH THAT IT W AS NOT PERF0PMING ITS INTENDED FUNCTION OF HOTCH C OHTROL.
THE REQUIRED HOTCH COHTROL WAS CIRCUMVENT ED BY USE OF Tile EMERGEHCY IN SWITCH AND TifE SCRAM SWITCHES OH Tile SCRAM TIME TEST PANEL.
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TECHNICAL SPECIFICATION 6.5.1.6.A REQUIRES THAT TH E PLANT REVIEW BOARD (PRB) SHALL BE RESPONSIBLE F0 R REVIEW OF ALL PROCEDURES REQUIRED BY TECllHICAL 5 PECIFICATIDH 6.8 AHD CHANGES THERETO.
TECHNICAL S PECIFICATIDH 4.5.2 REQUIRES THAT THE AUTOMATIC DEP RESSURIZING SYSTEM (ADS) SHALL BE DEMONSTRATED OPE RABLE BY MANUALLY OPENING EACH ADS VALVE AND OBSER VING THAT EITHER; (1) THE CONTROL VALVE OR BYPASS VALVE POSITIDH RESPONDS ACCORDINGLY, OR (2) Tif ER E
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IS A CORRESPDHDEHCE CHANGE IN THE MEASURED STEAM F LOW.
CONTRARY TO THE ABOVE, FROM APRIL 1,
1982, U
HTIL JULY 8, 1983, THE TECHNICAL SPECIFICATION REQ UIRED METHOD FOR ADS OPERATION VERIFICATION WAS HO T USED. THE PROCEDURE DID PROVE OPERABILITY BY TAI LPIPE PRESSURE SENSORS TO INDICATE OPENING OF THE RELIEF VALVE; HOWEVER. THE TECHNICAL SPECIFICATION S DO HOT RECOGHIZE THIS METHOD. ON APRIL 1,
1982,
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THE PRB APPROVED A CHANGE TO PROCEDURE HHP-2-3901 (REV. 7) THAT DELETED THE TECHNICAL SPECIFICATION REQUIRED METHOD FOR ADS OPERABILITY VERIFICATION AND SUBSTITUTED ANOTHER METHOD FOR VERIFICATI0H.
ON SEPTEMBER 7, 1982 (REV. 8), AUGUST 10, 1982 (RE
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V.
9), OCTOBER 4, 1982 (REV. 10), AND OH JUNE 14, 1983 (REV. If, A GENERAL REVISIDH OF THE PROCEDURE
).
THE PRB APPROVED THE PROCEDURE WITHOUT THE REQU IRED METHOD OF ADS VERIFICATION.
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