ML20099E775
| ML20099E775 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 08/05/1992 |
| From: | Woodard J SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9208110111 | |
| Download: ML20099E775 (7) | |
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Southern Nxlear Operating Company Pont Offce Box 1?95 D rrangham, /Jabama 35201 Tek-phane 205 BGS5086 m
South >m Nuclear Operating Company 3 o. wooo,,
vce Presu$ent the couthem eie: toc system rarcy project 10 CFR 2.201 10 CFR 2, App. C August 5, 1992
. Docket No. 50-364 U. S. Nuclear Regulatery Commission ATTN: Document Control Desk Washington, D. C. 20555 Joseph M. Farley Nuclear Plant - Unit 2 Reply To Notices of Violation and Deviation Report Numbers 50-348/92-19 and 50-364/92-19 Violation Number 50-364/92-19-01 Deviation Number 50-364/92-19-02 NRC Inspec_ tion of May 18 - June 29. 1992 Gentlemen:
This letter refers to the violation and deviation cited in the subject inspection report. Attachment 1 provides the Southern Nuclear Operating Company (SNC) response to violation number 50-364/92-19-01, and Attachment 2 provides the SNC response to deviation number 50-364/92-19-02.
Respectfully submitted, A hAL\\
. Woodard DRC: map nrc92-19\\ rem-5.jdw Attachments cc: Mr. S. D. Ebneter Mr. S. T. Hoffman Mr. G. F. Maxwell V[oSt10111 920805
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a ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION 1
REPORT NUMBERS 50-348/92-19 AND 50-364/92-19 VIOLATION NUMBER 50-364/92-19-01 g
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' U. S. Nuclear Regulatory Commission Page 1 The violation states:
Technical Specification 6.6.1 requires that applicable written procedures recommended in Appendix A of Regulatory Guide (RG) 1.33 Revision 2,1978 shall be established, implemented and maintained.
Procedure FNP-0-AP-52, f.quipment Status Control and Maintenance Authorization, Rev.18, Section 7.5.6 requires delineation of work sequence activities by the inclusion of steps in a written work request and Section 7.7.1 further states that maintenance performed shall follow the work sequence specified.
Procedere FNP-0-AP-85, Electrical Mcintenance Group Conduct of Operations, Rev. O, Section 9.0 notes that the individual will confirm that he is at the correct piece of equipment prior to beginning maintenance. The section states that to i coid inadvertent isolation or incorrect maintenance, it is the responsioility of all maintenance personnel to ensure that equipment being worked on is properly identified. If not, it is their duty to report such discrepar.cies to their foreman.
Contrary to the above, during performance of rod control powe-fuse inspection and replacement activities on May 26, 1992, a plant electrician failed to perform step number two of the original work sequente; "... regardless of their condition, replace these fuses."
He also failed to seek clarification of the task from his foreman or the shift supervisor when he had difficulty in identifying the correct panel for fuse replacer N. Because of these f ailures, the rod control system stationary gripper coil power supply was de-energized, associated control rods dropped into the core and the Unit 2 reactor automatically tripped due to a high negative flux rate.
This is a Severity Level IV violation (Supplement 1).
Admission or Denial The violation occurred as described in the subject report,
' Reason for Violation The violation was caused by personnel error in that:
1.
The Maintenance Foreman did not adequately plan the work request. The planning sequence did not specify that the movable coil disconnect fuses were the only fuses to be changed. It was not noted in the work request that there were three disconnects for each cabinet.
U. S. Nuclear Regulatory Commission Page 2 Feason for violation (continued) 2.
The Maintenance Foreman did not cor. duct an adequate pre-job briefing. The journeyman was not cautioned about the stationary coil disconnett.
3.
The Shift Foreman and Shift Supervisor did not adequately review the work prior. to releasing _- the work order for_ implementation, in that the r
journeyman was not cautioned or questioned about the specific equipment to be worked.
4.
The journeyman failed to use the proper level of caution in carrying out
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the job. Eun though the work request made no mention f three disconnects, he proceeded to theck the fuses in all three and. opened the-o
-stationary disconnect without questioning the apparent discrepancy.
- Corrective Steos Taken and Results Achieved To alleviate the adverse condition, the work request was replanned and all
. power aupply fuses in each of the three disconnects were replaced for all
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four CROM cabinets.
Corrective Steos Taken to Avoid Further Violations 1.
All' personnel involved received discipline in the form of coaching and/or oral reminders.
2.
Permanent-labels have been placed on all the disconnects for each CRDM
- cabinet on both units to-identify their functions. - Additionally, warning labels were placed on the stationary gripper disconnects explaining that a reactor trip will result from opening the disconnect.
3.
Electrical Maintenance and Daily Planning personnel have been trained on this event.
4.
Electrical Maintenance personnel are receiving specialized instruction in the rod-control _ system during -the current session of retraining.
- 5.
This event will be discussed during the next session of. operations licensed, operaticns non-licensed,: and maintenance annual retraining.
Date 'of Full C.oapliance-September-21, 1992-
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s ATTACHMENT 2 REPLY T0 fl0TICE OF DEVIATION REPORT NUMBERS 50-348/92-19 AND 50-364/92-19 DEVIATION NUMBER 50-364/92-19-02 T
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' O. S. fluclear Regulatory Commission Page 1 The deviation states:
By letter dated February 20, 1992, Southern fluclear Operating Company, Inc. (SitC), requested approval of an amendment io the J.fi.
Farley fluclear Plant, Unit 2, Technical Specifications, to permit use of interim steam generator tube plugging criteria (IPC). In Attachment I to the letter, Stic made the following commitment:
"A sample rotating pancake coil (RPC) inspection of 100 tube support plate intersections will be performed. All intersections with bobbin dent voltage exceeding 5 volts will be inspected."
On April 1, 1992, the f4RC issued Amendment flo. 87 to f acility Operating License fio. f1PF-8, approving the use of IPC for Unit 2 for one cycle. Ir a Safety Evaluation supporting issuance of the amendment, the f4RC staff evaluated the commitment to inspect bobbin dent voltages exceeding 5 volts with an RPC. This commitment formed part of the basi' on which the staff found the amendment request acceptable.
Contrary to St<C's commitment, in implementing the IPC during the last Unit' 2 refueling outage, all intersections with bobbin dent f
voltages exceeding 5 volts were ngi inspected by a RPC. One dent voltage of 7.02V in steam generator "2A",
tube "R40C37", and located at intersection "STSPC", was not inspected with the coil.
Therefore, SilC did not comply with all commitments made for implementation of the IPC.
Reason for Deviation This deviation was caused by cognitive personnel error. When the Unit 2 eighth refueling outage eddy. current database was updated wich additional information, the list of intersections with boobin dent voltages exceeding 5 volts, which is generated from the eddy curren+ databrse, was not also updated.
Specific Actions Taken A-10 CFR 50.59 evaluation of the issue was reviewed and approved by the Plant i
Operations Review Committee (PORC) on June 19,1992. The 50.59 evaluation concicded that no safety or technical concerns were applicable for the missed inspection of the one support plate dent for the following reasons:
167-of 168 Unit 2 steam generator tube support plate intersections with bobbin. dent voltages greater than 5 volts were RPC inspected. Since no axial or circumferential cracking was found at these dented intersections, it is highly unlikely that any flaw exists at the missed intersection.
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L U. S. Nuclear Regulatory Commission Page 2 Soecific Actions Taken (continued)-
An axial flaw-amplitude of 1 volt to 1.5 volts would be expected to be detected by bobbin inspection in a 7 volts dent. Analysis of the bobbin data for-this intersection found no flaw signal present.
Historically, no circumferential indications at dented tube support plates have been identified above the fifth hat leg tube support plate. Thus, no circumferential indications would be expected on the cold leg.
Also, the'NRC was verbally notified of the missed inspection.-
Corrective Steos to Avoid Further Deviations Additional procedural guidance will be-prepared for eddy current data management. This guidance will include an enhancement in the verification process by the eddy current contractor and Si1C personnel.
Date Corrective Action Will be Completed September 25,_1992
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