ML20050A436

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Responds to NRC Re Violations Noted in IE Insp Repts 50-348/81-29 & 50-364/81-32.Corrective Actions: Personnel Reinstructed Re Closing Air Header Cross Connect Valves & Procedures Revised
ML20050A436
Person / Time
Site: Farley  
Issue date: 03/18/1982
From: Clayton F
ALABAMA POWER CO.
To: Kellogg P
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20050A424 List:
References
NUDOCS 8204010289
Download: ML20050A436 (5)


Text

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Milling Address Alabama Power Company 600 North 18th Street Post Office Box 2641 Dirmingham. Alabama 35291 Telephone 205 783-6081 F. L Clayton, Jr.

b Senior Vice President c0 Mabama POWCT

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,L (tw> southern ole ctrC system March 18, 1982 Docket No. 50-348 Docket No. 50-364 Mr. Paul J. Kellog U. S. Nuclear Regulatory Commission Region II Suite 3100 101 Ma rietta St reet, N.W.

Atlanta, GA 30303

Dear Mr. Kellogg:

RE:

Joseph M.

Farley Nuclear Plant NRC Inspection of November 16-December 15,1981 50-348/81-29 50-364/81-32 This letter refers to the violations in the subject inspection report and the correction dated February 22, 1982 which states:

"As a result of the inspection conducted on November 16 -

December 15, 1981, and in accordarce with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violations were identified.

A.

Technical Specification 3.8.1.1.6 requires that two diesel generator sets be operable when the unit is on Mode 1.

Contrary to the above, one diesel generator was inoperable when Unit 2 was in Mode 1.

On December 10, at 10:00 p.m.,

diesel generator 2C failed to start during a Unit I refueling sur-veillance test.

Both of the air receivers were found isolated from the air start motors.

In-vestigations indicated that the air receivers were isolated due to a valving error about 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to discovery.

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l Mr. P. J. Kellogg March 18, 1982 Page Two This violation is applicable to Unit 2 only.

This is a Severity Level IV Violation (Supplement I.D.2).

B.

Technical Specification 6.8 requires that written procedures shall be established and implemented.

System Operating Procedure No. 16.3, " Steam Gen-erator Filling and Draining", requires that a system check out of steam generator level instru-mentation be performed to verify instruments to be in service and operable and a vent path be provided to prevent overpressurizing prior to filling the steam generators.

Administrative Procedure No. 16

" Conduct of Operation - Opera-tions Group", requires that the Reactor Operators Log contain entries describing significant events.

Contrary to the above, Plant Operating Procedures and Administrative Procedures were not followed in that:

On December 9, 1981 steam generators 1-B and 1-C were overfilled due to the steam gen-erator level instrumentation being isolated and inoperable; a vent path was not provided which resulted in pressurizing the steam generator to the point of lifting the power operated relief valve; and the reactor operator's log did not contain entries describing the above event.

This violation is applicable to Unit 1 only.

This is a Severity Level V Violation (Supplement I.E.).

A.

With regard to the first violation, the following information is submitted:

Admission or Denial i

The violation occurred as described in the subject report.

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Mr. P. J. Kellogg i

March 18, 1982 Page Three Reason for Violation Personnel error.

On 12-8-81 an Equipment Operator was instructed by the Shift Supervisor to close the air header cross connect valves.

These valves are in close proximity to the air start valve isolation valves and the Equipment Operator apparently closed the wrong set of valves.

Corrective Steps Taken to Avoid Further Violations This incident has been discussed with all operations crews.

The air start isolation valves and air receiver header isolation valves have been locked in the open position on all emergency diesels.

The appropriate procedures have been revised to indicate that these valves are to be locked open.

Corrective Steps Taken and Results Achieved See above.

Date of Full Compliance All corrective action was completed January 1, 1982.

B.

With regard to the second violation the following information is submitted:

Admission or Denial The violation occurred as described in the subject report.

Reason for Violation Personnel error and procedural inadequacy.

The event occurred during an outage and the root valves to the level instrumentation being used had been tagged shut for a separate unrelated modification.

The procedure (SOP 16.3) did not

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Mr.

P. J. Kellogg March 18, 1982 Page Four provide specific instructions for checking root and block valve status or for installing and verifying operability of the temporary level in-dication system being used for the evolution that was in progress.

Changes in level indication that occurred while filling the generator led personnel to believe the indication was oper-able.

Instead of specifically requiring a vent path to be open, the procedure contained a " note" to open a vent path if necessary to maintain pressure <25 psig.

Log entries were not made due to personnel error in interpreting what events should be logged.

Corrective Actions Taken and Results Achieved An operations memo has been issued discussing un-satisfactory trends and the need for attention to detail.

This memo has been discussed with each Operating crew emphasizing the lessons learned from this incident.

The procedures for steam generator filling and draining (FNP-1-S0P-16.3 and FNP-2-SOP-16.3) have been revised to ensure that a vent path exists while filling the steam generators.

A procedure will be written t o provide instruc-tions on the installation of tygon tubing on the steam generators for use as level indication and will include instructions f or veri fying the accuracy of the indication.

Log entry practices have been discussed with the personnel involved.

Corrective Actions Taken to Avoid Further Violations See above.

Date of Full Compliance All corrective action will be completed by March 30, 1982.

o Mr. P. J. Kellogg March 18, 1982 Page Five i

Affirmation With regard to the above two violations, I affirm F

that this response is true and correct to the best of my knowledge, information and belief.

The information contained in this letter is not con-sidered to be of a proprietary nature.

Yours very truly, j

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