ML20132C318
| ML20132C318 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 09/17/1985 |
| From: | Mcdonald R ALABAMA POWER CO. |
| To: | Verrelli D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8509270002 | |
| Download: ML20132C318 (3) | |
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Mamng Address Atacama Power Company 600 North 18th Street Post Office Box 2641 Birmingham. Alabama 35291 Telephone 205 7834090 R. P. Mcdonald n
c 5 g F 23 /1 g. 2 8 Senior Vice President
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AlabaniaPower Fhntridge Building enar wa m,
September 17, 1985-Docket No. 50-348 s
Docket No. 50-364 Mr. D. M. Verrelli U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
Suite 3100 Atlanta, GA 30323
SUBJECT:
J. M. Farley Nuclear Plant NRC Inspection of July 10 - 12, 1985 RE.:
Report Numbers.50-348/85-30 50-364/85-30
Dear Mr. Verrelli:
This letter-refers to the violation cited in the subject inspection report which states:
"The following violation was identified during an inspection conducted on July 10 - 12, 1985. The Severity Level was assigned in accordance with the NRC Enforcement ' Policy (10 CFR Part 2, Appendix C).
10 CFR 50, Appendix B, Criterion V, and the accepted QA program (FSAR 17.2.5) collectively require that activities affecting quality shall be prescribed by documented procedures and shall be accomplished in accordance with these procedures. Administrative Procedure FNP-0-AP-63, Conduct of Operation - System Performance Group, Revision 1~ requires surveillance test evaluation. -The accepted QA program commits to ANSI N18.71972,' Administrative Controls for Nuclear Power Plants. Section 6.2.2 requires that test results be evaluated to determine whether the individual tests demonstrate that the plant can
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be operated safely and as designed. Section 4.2.2 of FNP-0-AP-63 implements the evaluation requirement.
8509270002 850917 PDR ADOCK 05000348.
O PDR ll0 ZE01
Mr. D. M. V rralli September 17, 1985 Page Two Contrary to the above, surveillance test evaluations were not always being performed. A review of 165 completed surveillance tests selected by the licensee and the NRC inspector for multiple types of safety-related pumps indicated that evaluations had not been performed for 35 of those tests.
This is a Severity Level IV violation (Supplement I)."
Admission or Denial Alabama Power denies the alleged violation.
The violation is invalid because the cited deficiency involves a Company requirement that is not also a license requirement. This Company requirement is for additional reviews and evaluations of selected, previously reviewed surveillance test results. Specifically, the 35 tests cited had been satisfactorily completed and the results reviewed as required by our Administrative Procedure FNP-0-AP-5 Completed reviews of these 35 test results satisfied all of the following: FNP-0-AP-5; general license requirements such as 10CFR50 Appendix B; our accepted QA program (FSAR 17.2.5); the criteria of ANSI N 18.7 1972; and all licensing commitments.
We have numerous Company requirements that go beyond regulatory requirements. The one cited is specified in our Administrative Procedure FNP-0-AP-63, paragraph 4.2.2.
Principally, it involves independent trending of certain parameters from selected surveillance test data. There is no license requirement for this additional level of review and analysis.
Alabama Power Company also denies the assigned level of the alleged violation.
The " Severity Level _ IV" assignment made from Supplement I to 10CFR Part 2, Appendix C does not correlate to any of the examples listed in Section~D.
Reason for Violation Not Applicable Corrective Action Taken and Results Achieved Not Applicable Corrective Steps Taken to Avoid Further Violations Not Applicable
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. Mr. D. M. Verralli September 17, 1985 Page Three-Date of Full Compliance Not Applicable Affi rmation -
I affirm that this response is true and complete to the best of my knowledge, information and belief.
The information contained in this letter is not considered to be of a proprietary nature.
Yours very trul,
b R. P. Mcdonald RPM: sam cc:
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