ML20117M928
| ML20117M928 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 09/12/1996 |
| From: | Woodard J SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9609180228 | |
| Download: ML20117M928 (3) | |
Text
l Southern Nuclear Operiting Company Post Offic) Box 1295 I
i Birminghtm. Alabams 35201
, T4LIphone (205) 868-5086 Q
L L
Southern Nudear Operating Company j
J. D. woodard Executive Vice President i
the Southem electnc system j
September 12, 1996 Docket Nos.:
50-348 10 CFR 2.201 l
50-364 l
i U. S. Nuclear Regulatory Commission j
ATTN: Document Control Desk l
. Washington, DC 20555 l
Joseph M. Farley Nuclear Plant Reply to a Notice of Violation NRC Inspection Report Numbers 50-348/96-06 and 50-364/96-06 i
Ladies and Gentlemen:
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j As requested by your transmittal dated August 16,1996, this letter responds to VIO 50-348, 364/96-06-01, " Failure to Perform Surveillance Test of SI Handswitch Input to RTS." The l
Southern Nuclear Operating Company (SNC) response to this violation is provided in the Attachment to this letter.
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Confirmation I
I affirm that the response is true and complete to the best of my knowledge, information, and belief.
i Respectfully submitted, l
-A J. D. Woodard I
EFB/citinov96-06. doc l
Attachment i
l cc: Mr. S. D. Ebneter, Region II Administrator
[
Mr. J. I. Zimmeiman, NRR Project Manager J
Mr. T. M. Ross, FNP Sr. Resident Inspector if
/-
'I 9609180228 960V12 L
n PDR ADOCK 05000348 0
PDR J
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RESPONSE TO VIO 50-348,364/%-06-01 VIO 50-348,364/96-06-01, " Failure to Perform Suweillance Test of SI Handswitch Input to l
RTS" states:
Technical Specification (TS) Limiting Condition for Operation (LCO) 3.3.1 requires the reactor trip instrumentation of Table 3.3-1 to be operable. Table 3.3-1 requires a
- minimum of two operable channels of Safety Injection (SI) Input from the Engineered Safety Feature (ESF) Actuation System during plant operation in Modes 1 and 2. TS l-Table 4.3-1 requires reactor trip system channel functional tests of the manual SI input from ESF at least every 18 months.
TS 4 0.3 states that failure to perform a surveillance requirement within the specified intenal shall constitute a failure to meet the LCO Operability requirements.
V Contrary to the above, the licensee determined that the 18 month surveillance test for the Unit 1 and 2 manual SI handswitch inputs to the reactor trip system had not been performed since initial preoperational startup testing conducted prior to achieving commercial operation in 1977 and 1981, respectively.
This is a Severity Level IV violation (Supplement I).
Admission or Denial The violation occurred as described in the Notice of Violation.
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Reason for Violation l
The cause of the missed surveillance was cognitive personnel error which resulted in a failure L
to ensure the surveillance test procedure was adequate for testing of the manual SI input into L
the reactor trip circuitry.
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Corrective Stens Taken and Results Achieved l
l This situation was discoveied during FNP's review of Generic Letter (GL) 96-01, " Testing of L
Safety-Related Logic Circuits." During the review, no current procedure cculd be found that L
periodically tests the manual SI ESF input to the reactor trip system. It was determined upon review of the specific procedures referenced by the surveillance tracking master list that the j
procedures do not completely test the circuit. Specifically, the internal manual SI handswitch contacts that input to the reactor trip breaker shunt trip coils to cause the reactor trip breakers to open have not been tested. Although this feature was tested in pre-operational tesdng, i
i surveillance procedures developed during plant initial startup did not address testing of these particular contacts. Additional details are discussed in LER 50-348,364/96-04.
i Procedures have been revised to test the manual SI input into the reactor trip system and testing will be performed prior to Mode 2 entry following the next unit shutdown.
RESPONSE TO VIO 50-348,364/96-06-01 l
1 Corrective Steps That Will Be Taken to Avoid Further Violation i
INP has performed a broadness review of missed Technical Specification surveillance's identified from 1993 to present to determine the root cause contributors. Based on the l
broadness review the largest contributor was associated with failing to properly execute activities. In addition, inadequate preparation contributed to several events. However, the events associated with inadequate preparation were either unique in nature or within the scope j
defined by GL 96-01.
Therefore, the lessons learned of the broadness review concerning the improper execution of activities will be discussed with appropriate plant personnel.
l In addition, FNP's review of GL 96-01 is continuing to verify adequate testing of safety-related logic circuits.
7 Date of Full Compliance l
March 31,1997.
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