ML20083F882

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Responds to NRC Re Violations Noted in IE Insp Repts 50-348/83-26 & 50-364/83-24.Corrective Actions: Procedure FNP-O-AP-16 Revised to Require Locking Device Be Removed Prior to Verifying Open Position of Locked Valve
ML20083F882
Person / Time
Site: Farley  
Issue date: 12/07/1983
From: Clayton F
ALABAMA POWER CO.
To: Robert Lewis
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20083F788 List:
References
NUDOCS 8401050606
Download: ML20083F882 (3)


Text

Malling Addr:ss Ala%me Power Company 600 North 18th Street g,, ', ',,". p -

Post Off ce Box 2641 Birmingsam. Alabama 35291

..../

Telephcne 205 783-6081 F. L Clayton. Jr.

Renier Vice President

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  • O1 rP Flintr,dge Duilding M8anla POW'Cf the scuttym s4 cmc sp*em December 7, 1983 Docket No. 50-348 Docket No. 50-364 Mr. R. C. Lewis U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.

Suite 3100 Atlar.ta, GA 30303

SUBJECT:

J. M. Farley Nuclear Plant NRC Inspection of September 11, 1983 - October 10, 1983 RE: Report No. 50-348/P3-26 Report No. 50-364/83-24

Dear Mr. Lewis:

This letter refers to the violations in the subject inspection reports which state:

"As a result of the routine inspection conducted on September 11 -

October 10, 1983, and in accordance with the NRC Enforcement Policy, 47 FR 9987 (March 9,1982), the following violations were identified.

A.

Technical Specifications Section 3.6.2.2.b requires that "two spray additive eductors capable of adding NaOH solution from the chemical additive tank to a contain-nent spray system pump flow to be operable in Modes 1, 2, 3 and 4.

With the spray additive system inoperable, restore the system to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least hot standby within the next six hours..."

Contrary to the above, on September 19, 1983, Unit 2 in cold shutdown (Mode 5), the licensee found containment spray loop 2A eductor supply valve No. V019A locked in the closed position.

This rendered the "A"

train of this system inoperable. The licensee did not have docu-mentation to verify that the valve had been closed after 8401050606 831216 PDR ADOCK 05000348 G

PDR

Mr. R. C. Lewis December 7, 1983 Page Two the reactor reached Mode 5.

The last procedural opera-tion of the valve was on August 21, 1983, at the conclu-sion of surveillance testing while the reactor was in Mode 1.

Therefore, the above limiting condition for operation was exceeded.

The "B"

train of the spray additive system was operable and capable of performing its intended safety function."

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

Reason for Violation This violation was caused by procedural inadequacy in that the exist-ing procedure allowed verification of the locked open position by noving the valve in the closed direction without removing the locking mechanism.

Investigation revealed that this method could lead to an incorrect conclu-sion about valve position for reach rod operated valves.

Corrective Actions Taken and Results Achieved Since the unit was in Mode 5 (valve not required to be locked open),

the correct valve position was documented and shutdown operations con-tinued.

An extensive investigation was conducted to determine the cause of the improper position.

Corrective Steps Taken to Avoid Further Violation _s_

FNP-0-AP-16 (Conduct of Operations - Operations Group) was revised to require that the locking device be removed prior to verifying the open position of a locked valve. All Operations personnel were trained on this change. These actions were completed by 10/13/83 l

Date of Full Compliance September 19, 1983.

"B. Technical Specification 6.8.1.c requires that written procedures shall be established, implemented, and nain-2 tained covering surveillance and test activities of i-safety related equipment.

Contrary to the above, a necessary Temporary Change Notice (TCN) was not incorporated in FNP-2-STP-21.1, Main Steam Line Isolation and Bypass Valve Inservice Test on June 4,1983.

Thus, the procedure as written was inadequate."

Mr. R. C. Lewis December 7,1983 Page-Three Admission or Denial The above violation occurred as described in the subject report.

Reason for Violation This violation was caused by personnel error in that FNP-2-STP-21.1 (Main Steam Line Isolation and Bypass Valve Inservice Test) had not been revised to allow verification of valve novement by local observation.

4 Corrective Actions Taken and Results Achieved FNP-2-STP-21.1 was revised to allow local observation as a method of verifying valve movement.

The appropriate personnel have been counseled concerning this violation.

Corrective Steps Taken to Avoid Further Violations See above.

- Date of Full Compliance June 23, 1983.

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 considered to be of a proprietary nature, j

Your s very truly,

p. L. Clayton, Jr.#&.zkr FLCJ r/KWM:nac/G-21 xc: File l

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