ML20085G314
| ML20085G314 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 10/14/1991 |
| From: | Hairston W ALABAMA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9110240256 | |
| Download: ML20085G314 (4) | |
Text
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October 14, 1991 AltibtiliitiPower Docket Hos. 50-348
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$0-364 10 CFR 2.201 Director, Office of Enforcement V. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, C' 20555 Joseph M. Farley Nuclear Plant Reply to Notice of Violation Report Number 50-348, 364/91-17-01 (LfL10intqtion of JulyJ3 _JulyEE1 Gentlemen:
This letter refers to the violations cited in the subject inspection report.
The violations state:
1.
Violations Assessed a Civil Penalty A.
Technical Specification 3.7.1.2 requires that at least three independent steam generator auxiliary feedwater pumps and associated manual actuation switch in the control room and flow paths shall be OPERABLE with:
1.
Two auxiliary feedwater pumps, each capable of being powered from separate emergency busses, and 2.
One auxiliary feedwater pump capable of being powered from an OPERABLE steam supply system.
This is applicable in Modes 1, 2, and 3.
Technical Specification 3.0.4 prohibits entry into an operational mode unless the conditions of the limiting Condition for 0)erations are met without reliance on the provisions of tie ACTION requirement of the Technical Specification.
Contrary to the above on May 17, 1991, the recirculation bypass valve on the Unit I turbine driven auxiliary feedwater pump was placed in the open position which qhgMI rendered the system flow path inoperable.
On May 18, 1991,
% (hijn Unit 1 entered Mode 2, and on May 19, 1991, entered Hodo 1 A.
while the flowpath was inoperable.
N B.
Technical Specification 6.8.1.1 requires that written 0
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procedures shall be established, implemented and maintained p
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covering the applicable procedures in Appendix A. Regulatory b
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9110240256 911014 PDR ADOCK 03000343 Q
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's. Nuclear Regulatory Commission Page 2 Guide 1.33, Revition 2, february 1978.
Appendix A includes administrative procedures that specify the authorities and responsibilities for safe operation and shutdown.
Adnon utrative Procedure fNP-0-AP-16, Revision 21, Conduct of Operations - Operating Group, Section 6.4, requires the Shift foreman Operations (SFO) to initiate a Limiting Condition for Operatiot. (LCO) form for any LCO which cannot be met during his shift.
Contrary to the above, no LC0 form was issued on valve AFW Q1N23V008 on May 17, 1991, when it was unlocked and placed in the open position while performing 1-STP-256.18A, Turbine Driven Auxiliary feedwater Pump (10Af WP) Response Time Test.
Opening valve Q1N23V008 rendered the TDAfWP flowpath inoperable.
As a consequence, the LCO for Technical Specification 3.7.1.2 was not met.
Vic1ations t, and B have been categorized in the aggregate as a Severity Level 111 problem (Supplement 1).
Civil Penalty - $25,000 (assessed equally between both violations)
- 11. Violation Not Assessed a Civil Penalty Technical Specification 6.8.1.1 requires that written procedures shall be established, implemented and maintained covering the applicable procedures in Appendix A Regulatory Guide 1.33, Revision 2, february 1978.
Appendix A includes procedures for surveillance and test activities of safety-related equipment.
Administrative Procedure FNP-0-50P-0, Revision 30, General Instructions to Operations Personnel, Section 7.1.10, requires the Operations Shift Supervisor to periodically audit the locked valve and key checkout sheets.
Firley Site Operations Memorandum 82-05, dated July 8, 1982, requires this audit to be performed each Honday on night shift.
Contrary to the above, the revicw of the locked valve and key checkout sheets and the audit cover sheet required by FNP-0-SOP-0 was conducted on liay 2, 1991, and not conducted again until May 21, 1991, which was 19 days later.
This is a Severity Level IV violation (Supplement 1).
Mats 11on_E_Dr111itl The above violations occurred as described in the subject report,
U. S. Nuclear Regulatory Commisaion page 3 Reason for Viulallon Violation I.A was caused by procedural inadequacy. The procedure step requesting the valve to be closed and locked was signed off by Maintenance as being complete even though the valve was not closed.
This occurred since the Maintenance procedure did not require an Operations sign-off for an Operations task.
Violation 1.8 was caused by aersonnel error.
The Shilt Supervisor involved failed to ensure the proper LCO status sheet was generated.
Violation 11 was also caused by personnel error in that a locked valve audit was not performed weekly.
Corrective Action Taken and Results Achieved Regarding Violations 1.A and 1.B upon discovery Q1N23VC08 was closed and locked and a plant incident Report was initiated.
Regarding Violation 11, an audit of the locked valve and key checkout log was conducted on May 21, 1991.
Corrective Steos to Avoid further Vkhtfons Regarding Violation I.A. all plant procedures were revuwed for cases where a group other than the primary performing group is required to perform a procedure step. Any procedures found in this posture were evaluated as to the need for a specific sign-off from the group completing the task. Also, appropriate writers guide (s) were revised to include guidance for evaluating new procedures which may require a specific sign-off from another group.
Regarding Violation I.B, the need to ensure pro)er completion of LC0 status sheets for an LC0 condition identified on his sitft has been stressed to the Shift Supervisor involved.
Regarding Violation II, the importance of ensuring prompt performance of locked valve and key checkout log audits has been emphasized to all Shift Supervisors.
Eate of full igmoliance September 15, 1991
U. S. Nuclear Regulatory Comtnission Page 4 Affirmm119s I affirm that this response is true end complete to the best of my knowledge, information, and belief.
The informaticn contained in this letter is not considered to be of a proprietary nature.
Respectfully submitteo.
ALABAMA POWER COMPANY t0, L l} u 7 L ;L, i
W. G. Hairston, 111 WGH, !!!/BHW: map 1108 SWORN TO AND SUBSCRIBED BEFORE ME
Enclosure:
$25,000 Check i
\\h~DAYOFht".
, 1991 THIS
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cc: Mr. S. D. Ebneter f
J]ht ( hwlilicj'f}')h-Mr. S. T. Hoffman Mr. G. F. Maxwell ary Pu My Commission Expires: 1PIgfh 1
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