ML20058P758

Notice of Violation from Insp on 930923-1025.Violation Noted:Planner for Work Package Did Not List Removal of A/C Panel as Required Per Step 7.5.1

ML20058P758
Person / Time
Site:	Farley
Issue date:	12/01/1993
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20058P756	List: ML20058P752 ML20058P758
References
50-348-93-26, 50-364-93-26, EA-93-265, NUDOCS 9312270261
Download: ML20058P758 (4)

Text

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ENCLOSURE ,

t NOTICE OF VIOLATION Southern Nuclear Operating Company Docket Nos.: 50-348, 50-364 t Farley Plant License Nos.: NPF-2, NPF-8 -

Units 1 and 2 EA 93-265 During a Nuclear Regulatcry Commission (NRC) inspection. conducted on September 23 through October 25, 1993, a violation of NRC requirements was identified. In accordance with " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:

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.

Regulatory Guide 1.33 requires procedures for the conduct of operations, equipment control and thgging, and maintenance.

1. Administrative Procedure AP-85, Conduct of_0perations - Electrical Maintenance Group, Revision 0, Step 7.5.1, states, in part, that a complete and concise description of work shall be provided and -

this should include the identification of all parts that are removed.

2. Administrative Procedure FNP-0-AP-52, Equipment Status Control and Maintenance Authorization, Revision 21;

a. Step 6.1 states, in part, that job planners will provide job sequence planning which will include applicable procedures and identification of limiting conditions of operations.

b. Step 7.4.2 states, in part, that a determination of limiting conditions for operation is required in the preparation of maintenance work requests.

c. Step 7.5.17 states, in part, that the designated group supervisor responsible for accomplishment of work will review the maintenance work request for correct information and work sequence.

d. Step 7.7.1 states that the maintenance individual performing the work shall follow the specified work sequence. If, during the conduct of maintenance, the worker finds that the work sequence does not adequately delineate the activities which must be performed to accomplish the maintenance, the work sequence _shall be revised and "reapproved".

9312270261 931201 '

PDR ADOCM 05000348 G PDR

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Southern Nuclear Operating Company 2 Docket Nos.: 50-348,'50-364 Farley Plant License Nos.: NPF-2, NPF-8 .

Units 1 and 2 EA 93-265

3. Administrative Procedure, FNP-0-AP-14, Safety Clearance and .

Tagging, Revision 13;

a. Step 7.8.1 states, in part, that the preparer of the tag order will carefully evaluate the work to be performed and that the preparer will develop positioning actions to assure proper isolation.

b. Step 7.11 states, in part, that the reviewer of the tag order will use the same process as the preparer to determine the adequacy of the technical content within the order.

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c. Step 7.14 states, in part, that the tagging official will carefully review the tag order to assure that execution of the order is acceptable with regard to its effect on plant  ;

status.

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d. Step 7.21 states, in part, that the approval authority will carefully review the tag order to assure that execution of the order is acceptable with regard to its effect on plant status.

4. Maintenance Procedure FNP-0-M-64, Writers Guide for Maintenance Procedures, Revision 3;

a. " Referencing" section, states, in part, that procedures should be written so steps can be performed without obtaining additional information from persons / documents.

b. " Component Identification" section, states, in part, that in-plant components should be identified in the procedure when the subject component is used infrequently, has poor access, or is not labeled.

Contrary to the above:  ;

a. On September 23, the shift supervisor received and approved a deficient maintenance work request (MWR) for repairs to the "A" train control room air conditioning (A/C) system. . The planner for the work package did not list the removal of the A/C panel. as required per Step 7.5.1. of Procedure AP-85, nor did he give proper consideration to maintaining the control room pressurization boundary per Steps 6.1 and 7.4.2 of Procedure FNP-0-AP-52. Additionally,.the craft supervisor did not do an appropriate review of the MWR per Step 7.5.17, and the craft personnel performing the work performed work not specified in the MWR when the A/C panel was removed rather than seek help and a revised MWR per Step 7.7.1. This inadequately planned, unauthorized removal of the A/C panel ~ and the existence of open

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Southern Nuclear Operating Company 3 Docket Nos.: 50-348, 50-364 Farley Plant License Nos.: NPF-2, NPF-8 Units 1 and 2 EA 93-265 fire dampers resulted in a breach of the control room pressurization boundary for approximately 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.  ;

b. On September 23, while performing M0 VATS testing of isolation valve (Q2P16MOV31308), isolation valve (Q2P16MOV3130A) was erroneously stroked shut due to the subject M0 VATS testing procedure data sheet which identified the wrong plant component (valve Q2P16MOV3130A) for the installation of jumper cables.

Procedure FNP-0-M-64 requires that maintenance procedures correctly identify in-plant components and be written so steps can be performed without obtaining additional information from other persons or documents. This event was caused by an engineer who incorrectly transcribed the wrong valve number from plant drawings to the M0 VATS testing procedure data sheet which was a work sequence not requiring independent ~ review.

c. On October 5, a modified tag order for tag-out No. 93-2531-2 was '

prepared and three reviewing Senior Reactor Operator licensed personnel failed to assure that the development and execution of that order was acceptable with regard to its effect on plant '

status as required by Procedure FNP-0-AP-14, Steps 7.8.1, 7.11, 7.14, and 7.21. Consequently, this discrepant order resulted in an improper valve lineup that isolated component cooling water flow to the in-service "2A" spent fuel pool (SFP) heat exchanger allowing the SFP temperature to rise about 40 degrees F in a 3-hour period before being found and corrected.

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

Pursuant to the provision of 10 CFR 2.201, Southern Nuclear Operating Company is hereby required to submit a written statement or explanation to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector at the Farley Nuclear Plant within 30 days of the date of .

the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for ,

each violation: (1) the reason for the violation, or if contested, the basis- '

for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.

If an adequate reply is not received within the time specified in this Notice, an Order or Demand for Information may be issued to show cause why the t

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Southern Nuclear Operating Company 4 Docket Nos.: 50-348, 50-364 Farley Plant License Nos.: NPF-2, NPF-8 Units 1 and 2 EA 93-265 license should not be modified, suspended, or revoked, or why such other '

action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response. time. ,

t Dated at Atlanta, Georgia this 1st day of December 1993 b

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