ML20029A138
| ML20029A138 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 01/28/1991 |
| From: | Hairston W ALABAMA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9102040208 | |
| Download: ML20029A138 (3) | |
Text
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Alabama Power Company 40 inverness Conter Parkway Psst Othce Box 1295 Birmingham, Alabama 3S201 Jetephone 205 6f>8MB1 W. G. Hairston, til sg,,vgll;g;"t January 28, 1991 AlabamaPower tre sann m<rnc symm Docket Nos. 50-348 50-364 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Vashington, D. C. 20555
SUBJECT:
Reply to a Notice of Violation J. M. Farley Nuclear Plant NRC Inspection of November 10 - December 29, 1990 RE:
Inspection Report Nos. 50-348/90-33 and 50-364/90-33 Gentlemen This letter refers to the violation cited in the subject inspection report.
The violation states:
Technical Specification 6.8.1 requires that applicable written procedures recommended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, 1978 shall be established, implemented and maintained.
- Procedure FNP-2-SOP-1.11, Mid-Loop Operations, Revision 3, Section 3.12, required that the reactor vessel head be fully de-tensioned and
. stud nuts loosened at least 0.17Linch deflection, or the pressurizer manvay removed, or at least one pressurizer safety valve removed to
. prevent RCS pressurization in the event of a loss of core cooling.
Contrary to the above, on December 9, 1990, operating and maintenance procedures were inadequate to ensure that specified reactor coolant system (RCS) vents were maintained while the RCS vas in "mid-loop" operations.
After placing the reactor head on the reactor vessel, maintenance personnel proceeded to install--the reactor vessel head stud nuts;and washer hand tight without informing reactor control operators or any assurance that the venting requirements of operating _
procedure FNP-2-SOP-1.11, Rev. 3 vere met.
Even though FNP-2-SOP-1.11 provided operational-guidance for the placement of stud nuts in a position which allowed for head deflection and subsequent RCS venting, the procedure was inadequate in that it-failed to provide specific guidance, to both' operations and maintenance. personnel to ensure that the nuts were looseiied at least 0.17 inches deflection.
In: addition, the corresponding mechanical maintenance procedure, HP-1.0, used by maintenance personnel for installing the vessel head, failed to make provisions for recommended placement of the stud nuts as prescribed by FNP-2-SOP-1.11.
This is a severity Level IV violation (Supplement I).
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.o Nuclear Regulatory Commission ATTN: Document Control Desk Page 2 Admission or Denial The above violation occurred as described in the subject reports.
Reason for Violation This violation vas caused by personnel error.
The personnel responsible for incorporating Generic Letter 88-17 requirements into plant procedures failed to identify that the maintenance procedure for reactor vessel stud nut installation needed to be revised.
Corrective Action Taken and Results Achieved 1.
Containment closure was established.
2.
personnel backed off the reactor vessel stud nuts.
Corrective Steps To Avoid Further Violations 1.
Personnel responsible for identification of procedures needing revision due to Generic Letter 88-17 have been counseled.
2.
Maintenance procedures have been changed to provide guidance on restrictions related to performance of activities during reduced inventory operation.
3.
Operations procedures have been changed to require frequent checks of-required conditions for reduced inventory conditions and to require the use of administrative controls as much as possible to prevent conditions from being changed once established.
4.
Operations procedures have been changed to address the requirements necessary after reactor head reinstallation.
5.
All commitments made in response to Generic Letter 88-17 have been reviewed and it has been determined that existing procedures and administrative controls are adequate for implementation of mid-loop requirements.
Date of Full Compliance ty 22, 1991
.-m.
1 o
i Nuclear Regulatory Commission ATTNt Document Control Desk Page 3 i
Affirmation I affirm that this response is true and complete to the best of my knowledge, information, and belief.
The information contained in this letter is not
+onsidered to be of a proprietary nature.
Respectfully submitted, AL/sBAMA POVER COMPANY j). 0 lluA$O~ TC V. C. Ilairston, III VGil.III/IlllVtmnf 22.18 cel Mr. S. D. Ebneter Mr. S. T. Iloffman Mr. G. I'. Maxwell
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