ML20083A480
| ML20083A480 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 05/02/1995 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9505110011 | |
| Download: ML20083A480 (5) | |
Text
yp Post Othee Box 1295
' Birmingem. Alabama 35201 Telephono (205) 868 5131 -
SOuthem Nudear Operating Company o,.. uor.r
. Vice President Farley Project the southem electnc System May 2, 1995 10 CFR 2.201 Docket Numbers: 50-348 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Joseph M. Farley Nuclear Plant Reply to the Notice of Violation (VIO) l NRC Insocction Report Nos. 50-348/95-05 and 50-364/95-05 l
Ladies and Gentlemen-As requested by your letter dated April 6,1995, this letter responds to Notice of Violation 50-348/95-05-02," Failure to Maintain and Establish Fire Watches." The Southern Nuclear Operating Company (SNC) response to VIO 50-348/95-05-02 is provided in the Attachment.
Ifyou have any questions, please advise.
Respectfully submitted, f
)]Wk s Dave Morey-ATTACIIMENT DPil/CLT 95-05. DOC SWORN TO AND SUBSCRIBED BEFORE ME '
TlilSMtd DAY OF N[dd 1995
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cc:
Mr. S. D. Ebneter
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Mr. B. L. Siegel N[/1td ;
[L Mr. T. M. Ross Notary Publig A
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9505110011 950502 PDR ADOCK 05000348 g
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e ATTACHMENT RESPONSE TO VIO 50-348/95-05-02
m RESPONSE TO VIO 50-348/95 05-02 7
VIO 50-348/95-05-02 states the following:
Technical Specification 6.8.1.f requires written procedures shall be established, implemented, and maintained for the Fire Protection Program. FNP-AP-39, Fire Patrols and Watches, requires that whenever any portion ofinstalled fire protection equipment and instrumentation is inoperable, the Shift Supervisor and Fire Protection Administrator will establish fire watches in accordance with the Final Safety Analysis Report.
Contrary to the above, the licensee identified the following three separate examples of when fire suppression equipment and barriers were disabled without establishing and/or maintaining an i
. adequate fire watch:
- 1. On February 20,1995, following completion of a battery charger load test, fire watches were '
released; however, a fire protection system clapper valve had been left isolated. The isolated clapper valve was discovered on February 22,1995.
- 2. On November 4,1994, following completion of a routine surveillance test of the service water intake structure high pressure carbon dioxide system for the IL 4160 VAC switchgear, fire watches were released; however, the main bank solenoid valve was lefl disconnected. This condition was discovered November 6,1994.
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- 3. On January 22,1995, during high pressure water cleaning of the Unit 1 service water piping to the control room air conditioner, several system spool pieces were removed. This.
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cfrectively breached the associated fire barrier penetrations. Fire watches were not established during these activities.
Admission or Denial The violation occurred as described in the Notice of Violation.
Heason for Violation
- 1. Personnel error in that the responsible individuals failed to recognize that the system was isolated when the required fire watches were removed.
- 2. Personnel error in that the workers failed to reconnect the main solenoid valve to the CO2 cylinders following the test.
- 3. Procedural inadequacy in that the planning sequence failed to identify the pipe openings as potential fire barrier breaches. Further, the fire protection program administrative procedure provided no guidance on breaches of piping in regards to fire barriers.
Page 1 of 3 4
RESPONSE TO VIO 50-348/95-05-02 Corrective Stens Taken and Results Achieved
- 1. Upon discovery, fire watches were immediately re-established, the system unisolated and fire watches later secured.
- 2. Upon discovery, the main bank of CO2 for the IL 4160 VAC switchgear was declared inoperable and the required fire watch was established. The reserve bank of CO2 was placed in service and the fire watch was secured. Later, the main CO2 bank solenoid valve was reconnected and the system returned to normal operational status.
- 3. Upon discovery, fire watches were immediately established and blind flanges were installed on all pipe openings not actively being cleaned.
Also, as a result of three " missed fire watch" events within three months, a root cause investigation on the event involving the isolated fire protection system clapper valve was i
expanded into a " broadness review." The broadness review evaluated events reponed via FNP heident Reports which identified missed fire watches between 1/1/90 and 2/28/95. No positive
.orrelation between missed fire watch events and equipment type, personnel involved, outage events, or other causative factors could be established.
Corrective Steps to Avoid Further Violations
- 1. A. Personnelinvolved were coached on the need to utilize self-checking to ensure their actions are accurate.
B. FNP-1/2-STP-914 has been revised to notify the Shift Supervisor that the charger is available for service and the isolated fire zone should be untagged, unisolated and returned to service. Also, the procedures have been revised to require the system to be isolated and tagged vice isolated.
C. This event will be discussed with Operations personnel and self-checking will be
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emphasized. Also, the tagging requirement of the fire protection program administrative procedure will be stressed to all personnel responsible for removing clappers from service.
D. The Fire Protection LCO Status Sheets of the fire protection program administrative procedure have been revised to require indication of the method used for removing a system from service.
- 2. A. Individuals involved were coached on the importance of checking their work and using the STAR principle.
B. FNP-0-FSP-56 has been revised to require that both the main and reserve solenoid valves be reconnected following test completion with a separate signoff for each valve.
C. Fire Suneillance Procedures (FSP) involving the testing of fire protection equipment will be reviewed and revised as necessary to ensure equipment is properly removed from senice and restored to operable status prior to test completion.
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RESPONSE TO VIO 58-348/954542
- 3. A. The fire protection program administrative procedure has been revised to provide guidance for the effects of pipe openings on fire barriers and the associated fire watch requirements.
J B. This event will be reviewed with FNP personnel re.,ponsible for work planrdng and review. Responsible personnel will be instmeted n evaluate work which may result in the disassembly or incomplete assembly of systems /conmnents that might impact the operability of fire barriers. This information will be included, as appropriate, in the planning of the work order.
Date of Full Comoliance June 30,1995 Page 3 of 3