ML20137S644
| ML20137S644 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 04/10/1997 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9704150202 | |
| Download: ML20137S644 (4) | |
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Dave Mirey S:uthern Nucitar Vice President Op: rating Comping
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Fartey Project P.O. Box 1295 1
Birmingham. Alabama 35201 Tel 205.992.5131 April 10, 1997 SOUTHERN COMPANY Energy ro Serve YourWorld" Docket No.:
50-348 10 CFR 2.201 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 1
Washington, DC 20555 Joseph M. Farley Nuclear Plant - Unit 1 l
1 Reply To a Notice Of Violation (VIO)
NRC Inspection Report Number 50-348/97-01
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Ladies and Gentlemen.
i As requested by your transmittal dated March 17,1997, this letter responds to VIO 50-348,97,-
01, " Failure to Follow PRF Operability Test Procedure."
The Southem Nuclear Operating Company (SNC) response is provided in the enclosure.
Confirmation i
I aflirm that the response is true and complete to the best of my knowledge, information, and belief.
l Respectfully submitted, f
l%
Dave Morey EFB/maf nov97-011. doc i
Enclosure cc:
Mr. L. A. Reyes, Region 11 Administrator Mr. J.1. 7.immerman, NRR Project Manager f6O fl I Mr. T. M. Ross,' Plant Sr. Resident Inspector 150115 9704150202 970410 ADOCK0500g8 PDR a
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ENCLOSURE Response to VIO 50-348,97-01-01
" Failure to Follow PRF Operability Test Procedure"
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RESPONSE TO NOV 53-348/97-01-01 VIO 50-348,97-01-01, " Failure to Follow PRF Operability Test Procedure" states the following:
Technical Specification (TS) 6.8.1.a requires that applicable written procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978, shall be established, implemented, and maintained. Regulatory Guide 1.33, Appendix A, Section 8.b recommends specific procedures for surveillance tests listed in the TS.
FNP-1-STP-124.0, Penetration Room Filtration Performance Test, Revision 11, implements the testing requirements ofTS surveillance requirement 4.7.8.b.i FNP.1-STP-124.0, step 5.0, describes the " Precautions and Limitations" and step 6.0 describes the " Initial Conditions" for the surveillance.
FNP-1-STP-124.0, step 5.4, states " Prior to performing visual inspection of a filtration unit insure that the associated filtration unit fans are de-energized and tagged to prevent starting."
FNP-1-STP-124.0, step 7.4, states in part, " Perform a visual inspection of the applicable components of the system to be tested... The inspection check list of Data Package STP-124.0A and
, are to be used for performing the inspection and indicating items found j
satisfactorily checked."
Contrary to the above, on January 25, 1997, the test engineer failed to comply with the procedural requirements of FNP-1-STP-124.0 during performance testing of the Unit 1 Penetration Room Filtration system Train A. 'lhe following are specific examples:
1.
The engineer had signed off step 7.4 as complete even though the internal sisual inspection of Data Package STP-124.0A had not been performed.
2.
The system was not tagged out as required by step 5.4 prior to performing the sisual inspection.
3.
The engineer did not sign off steps 5.0 (All precautions and limitations have been read and understood ) and 6.0 (All initial conditions are satisfied) prior to commencing the test.
This is a Severity Level IV violation (Supplement 1).
1 Admission or Denial The violation occurred as described in the Notice of Violation.
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4 RESPONSE TO NOV 50-348/97-01-01 Reason for Violation Re reason for the violation was personnel error in that the test engineer failed to follow the test procedure and the test engineer's supervisor failed to discuss his expectations concerning procedural adherence. A contributing factor was that the test engineer had not taken the time to adequately prepare j
himself for the test. This resulted in an over reliance by the test engineer on the vendor to ensure adequate test performance. The vendor, while knowledgeable about the test and the design requirements of the system, was not familiar with plant specific procedural requirements.
In addition, there were portions of the test procedure that were unclear and could have led other test engineers to misinterpret test requirements.
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d Corrective Steps Taken and Results Achieved On February 6,1997, the revised version of FNT-1-STP-124.0 was satisfactorily re-performed on the Unit 1, Train A, PRF system.
Corrective Steps That Will Be Taken to Avoid Further Violation Appropriate disciplinary measures have been taken with the supervisor and engineer involved with this occurrence. In addition, coaching has been performed for Engineering Support Department personnel on the lessons learned from this occurrence and on the expectations for test procedure performance.
The PRF surveillance procedures have been revised to provide clarification to the data sheets and procedure sections to minimize the possibility of personnel error in the execution of the procedures.
A broadness review will be conducted on a plant wide basis concerning failure to follow proce, dure.
Date of Full Compliance June 1,1997 E-2