ML20113H509
| ML20113H509 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 07/28/1992 |
| From: | Woodard J SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9208040131 | |
| Download: ML20113H509 (6) | |
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Docket Nos. 50-348 50-364 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C.
20555 Joseph M. Farley Nuclear Plant Reply to Notice of Violation Report Number 50-348, 364/92-16 Item Numbers 50-348, 364/92-16-01, 92-16-02 NRC Inspection May 18 - 22. 1992 1
Gentlemen:
This letter refers to two violations cited in the subject inspection report.
The first violation states:
10 CFR 50 Appendix B, Criterion 111 and the Licensee's accepted Operations Quality Assurance Program, FNP-FSAR-17. Se(' ion 17.2.3, Design Controls, require that measures shall be establ.shed to assure that applicable regulatory requirements and design basis are correctly translated into specifications, drawings, procedures and instructions.
Contrary to the above, on January 10, 1989, Production Change Request No. B-89-1-558E was approved for replacing installed 96-145 psig rar.ge springs with 146-220 psig range springs in various pressure relief valves in the Component Cooling Water and Service Water Systems.
Production Change Notice No. B-89-1-5586 was developed for (1) implementing the requested plant modifications and (2) providing design basis information concerning setpoint tolerance for incorporation in the Setpoint Index Drawing No. B-175968.
The pressure relief valves-springs were replaced in September 1989 and kawing No. B-175968 was never revised to include the required setpoint tolerances.
This is a Severity Level IV violation (Supplement 1).
The second violation states:
10 CFR 50, Appendix B, Criterion 111 sintes in part that design control measures snall provide for checking the adequacy of design, such as by the performance of a suitable test program.
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U. S. Nuclear Regulatory Commission Page two L:.cing diesel generator (D/G) surveillance testing on Oc'1ber 25, 1991, it was found that when only Unit 2 service water (SW) was aligned to the IC D/G, adequate SW flow was not achieved for the design basis condition where the SW temperature was greater than 96 degrees fahrenheit.
The required design SW flow rate from Unit 2 only to D/G IC is 950 gpm.
The SW flow rate achieved during the test was 640 gpm.
Revision 28 to PCN 887-2-4106, which was implemented during the 1992 Unit 2 refueling outage, involved replacing a section of existing carbon steel piping in the SW return line from the IC D/G with stainless steel piping.
Contrary to the above, Unit 2 was restarted after the refueling outage and returned to power operation without adequate post modification testing being specified or performed to determine if the required SW design flow rate could be achieved when only Unit 2 SW was aligned to the 1C D/G.
Th's is a Severity Level IV violation (Supplement 1)
See Attachment I for the SNC response to the first violation and Attachment 11 for the SNC response to the second violation.
C.gnfirmation I affirm that this response is true and complete to the best of my I
knowledge, information, and belief.
The information contained in this letter is not considered to be of a proprietary nature.
Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY
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'J. D. Woodard JDW/CDC: map 2879 cc: Mr. S. D. Ebneter Mr. S. T. Hoffman Mr...G. f. Maxwell
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ATTACilMENT I A mission or Denial j
The violation occurred ac described in the subject report.
Reason for Violatiqn The violation was caused by procedural inadequacy to ensure that updated design information is correctly incorporated into the Setpoint index Drawing following implementation of plcnt modifications.
The Setpoint Index Drawing (B-175968) is produced as a report from the FNP Computer Information Management System setpoint index database which is updated to reflect curront design inforintion following completion of all plant modifications, in this case, the computer setpoint index database was in f act updated to include the relief valve setpoint tolerance, however, the hard copy report format for the Setpoint Index Drawing did not include a field for tolerance.
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'w_ Action 1aken an_datstli.s Aehieyed The report format for the Setpoint Index Drawing has been revised to include a tolerance field. A revised index will be issued by October 1, 1992.
Correcity.g_11eos to Avot.d further Violations The procedure for updating the computer setpoint index will be modified to require a verification that all design information provided by the designer following completion of a plant modification is accurately and fully reflected on the Setpoint Index Drawing.
The report format for the Setpoint Index Drawing will be reviewed and amended, if neces:ary, to ensure that all appropriate information fields are included.
DJte of Full (cmpliance October 1, 1992
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ATTACllMENT !!
1 admistion or Denial The violeilon occurred as described in the subject report.
8p.ison for Violation The violation was caused by personnel error in that all significant information concerning the SW piping to the IC diesel generator (i.e.,
reduced flow discovered by flow testing) was not made available for the determination of the required post modification testing.
In this particular case, a post modification test should have been performed to ensure that re) lacing a section of pipe in the SW return line from the IC D/G resolved t1e reduced flow condition identified by the test conjucted in October 1991.
[.qrr.cs11ye Action Taken and Results Achieved Appropriate plant engineering personnel have been re-ir ucted on the importance of clearly identifying all significant inf' don concerning problems which result in modifications to ensure that,
, modification testing is adequate to address all concerns. A flow tes through the replaced piping has been performed with satisfactory results.
Corrective Stens to Avoid Further Violations Plant procedures will be revised to strengthen the requirements to document the complete problem and to perform post modification testing which demonstrates correction of the problem.
Date of Full ComnLiatcq October 1, 1992 d
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