ML20113D194
| ML20113D194 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 06/27/1996 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9607030059 | |
| Download: ML20113D194 (4) | |
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Southtrn Nucitar Op rating Company e
Post Omes Box 1295 4
Birmingham, Alabama 35201 Tdiphone (205) 868-5131 i
L Southern Nudear Operating Company o.v. uor.y l
Vice President l
Farley Project the Southem electoc system June 27, 1996
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Docket No.: 50-364 10 CFR 2.201 U. S. Nuclear Regulatory Commission l
ATTN. Document Control Desk l
Washington,DC 20555 l
l Joseph M. Farley Nuclear Plant - Unit 2 Reply to a Notice of Violation
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NRC Inspection Report Numbers 50-348/%-03 and 50-364/96-03 l
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L,adies and Gentlemen:
By letter dated May 29,1996, the NRC notified Southern Nuclear that violation VIO 50-i 364/96-03-03, Steam Generator Tube Flaws Within F* Distance, had occurred at Farley Nuclear Plant, Unit 2. The response to the Notice of Violation is attached.
l Confirmation I affirm that the response is true and complete to the best of my knowledge, information, and belief.
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Respectfully submitted, l
f 2W l
Dave Morey WAS/citmovltr. doc
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Attachment
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Mr. S. D. Ebneter, Region II Administrator Mr. B. L. Siegel, NRR Senior Project Manager
- Mr. T. M. Ross, FNP Sr. Resident Inspector 1 )
9607030059 960627 PDR ADOCK 05000364 G
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ATTACHMENT Resoonse to VIO-50-364/96-03-03 l
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RESPONSE TO VIO 50-364/96-03-03 NRC Violation VIO 50-364/96-03-03, " Steam Generator Tube Flaws Within F* Distance" states the following:
"During an NRC inspection conducted on March 17 through April 27, 1996, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
l fechnical Specification Limiting Condition for Operation 3.4.6 requires each steam generator to be operable during Modes I through 4. De applicable Action Statement precludes increasing l
T above 200 degrees Fahrenheit with an inoperable steam generator.
Surveillance g
l Requirement 4.4.6 prescribes the inservice inspection requirements for deman tfatmg steam l
generator operability, which includes plugging or repairing all tubes with indic=W degradations l
within the F* Distance.
l Contrary to the above, during the last two Unit 2 refueling outages the licensee did not properly apply the F* Distance acceptance criteria for steam generator tube operability defmed by Technical Specification Surveillance Requirement 4.4.6.4. Following the steam generator eddy l
j current inspections conducted during its most recent tenth refueling outage, the unit entered Mode 4 on April 21,1995 with six inoperable tubes. Each of these tubes had indications of degradation within the F* Distance that were not discovered until April 22,1996. Unit 2 T, was above 200 degrees Fahrenheit during this entire period of time.
This is a Severity Level IV violation (Supplement I)."
Admission or Denial This event was discovered because of questions asked during a pilot INPO Steam Generator evaluation.
FNP management informed the NRC of the potential problem during the NRC inspection referenced above.
The violation occurred as described in the Notice of Violation.
Reason for Violation The reason for this violation was an madequate surveillance test procedure used to verify Technical Specification compliance of the Steam Generator inspection program performed by the vendor. The procedure was inidequve in that it did not contain the acceptance criteria against which an evaluation of acceptability slmld have been made for F* tube determmation. Contributing causes to this event were that instructions provided to data analysts and data managers were not subject to a formal review and approval process, and advances in steam generator tube flaw location technology were not re-evaluated to the l
original Technical Specification acceptance criteria intent.
Corrective Stens Taken and Results Achieved
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Ee Unit 2 SG inspection data from U2 RIO for tubes de=ign=H as F* has been reanalyzed with the j
appropriate reference point for the measurement for the upper point for the F* distance and utilizing the upper crack tip as the lower reference point. As a result of utilizing the RPC capability for identifying the location of the upper tip of the flaw, concurrent with utilizing the bobbin coil capability for determining the location of the bottom of the roll transition, it was concluded that 6 steam generator tubes had been left in i
service following the U2RF10 - Spring 1995 outage which should have been repaired or plugged.
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a RESPONSE TO VIO 50-364/96-03-03
.r These 6 steam generator tubes were also reanalyzed for the tubes' ability to meet established industry L*
criterion (not included in FNP's Technical Specification). As discussed in a telephone-conference with the NRC staff on April 22, 1996, enforcement discretion was requested and approved to allow continued operation of FNP Unit 2 within the relevant L* parameters bounded by the 6 steam generator tubes. The details of the six steam generator tube deficiencies are documented in Southern Nuclear Company's Request for Enforcement Discretion correspondence dated April 23,1996.
i Corrective Steps That Will Be Taken to Avoid Further Violation The surveillance test procedure used to verify Technical Specification compliance of the Steam Generator inspection program will be revised to delineate Steam Generator inspection program Technical Specification acceptance criteria. The instmetions utilized by the data analysts and data managers will be formalized with a review and approval process. A broadness review is in progress to review FNP's safety-related vendor services used to support safety-related activities.
l Date of Full Compliance September 30,1996.
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