ML20138G575
| ML20138G575 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 12/23/1996 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9701020057 | |
| Download: ML20138G575 (3) | |
Text
1, Dave Mor:y Southern Nuclear 4
V(e President
. Operating Company Farley Project R0. Box 1295 Birmingham, Alabama 35201 Tel 205 992.5131 SOUTHERN December. 23, 1996 COMPANY Docket Nos.:
50-348 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Joseph M. Farley Nuclear Plant Supplemental Response To a Notice Of Violation (VIO) j NRC Insocction Report Numbers50-348S6-10 and 50/364/96-10
)
Ladies and Gentlemen:
J Southern Nuclear Operating Company (SNC) committed to provide to the NRC a supplemental re-sponse to VIO 50-348,364S6-10-01 by December 24,1996 to address the additional long term cor-rective actions regarding the programmatic aspects of pipe support discrepancies. The NRC also re-quested that the supplemental response discuss additional examples of support discrepancies identified in Paragraph El.2 ofInspection Report 50-348S6-09 and 50-364S6-09.
This supplemental response is enclosed.
)
1 Confirmation I affirm that the response is true and complete to the best of my knowledge, information, and belief.
1 Respectfully submitted,
$N b'bt' Dave Morey DHJ:maf VIOSUP-1. doc l
Enclosures cc:
Mr. S. D. Ebneter, Region II Administrator Mr. J. I. Zimmerman, NRR Project Manager Mr. T. M. Ross, Plant Sr. Resident Inspector I
TGOI
/
9701020057 961223 PDR ADOCK 05000348 G
ENCLOSURE SUPPLEMENTAL RESPONSE TO VIO 50-348, 364/96-10-01
" FAILURE TO CONSTRUCT AND MAINTAIN AN 'AS-BUILT' SAMPLE LINE IN ACCORDANCE Wml CONFIGURATION CONTROL PROCEDURES AND DRAWINGS" l
I. Additional Information Requested by NRC in Inspection Reports 50-348/96--09 and 50-364/96-09.
NRC Inspection Reports 50-348/96-09 and 50-364/96-09, dated November 8,1996, requested that the sup-plemental response discuss the additional examples of support discrepancies identified in Paragraph El.2 of the inspection report.
i II. Long Term Action for VIO 50-348,364/96-10-01:
In the SNC response to VIO 50-348,364/96-10-01, dated October 25,1996, Part B of the response concerned an event discussed in Inspection Report 50-348/364-96-07. Southern Nuclear stated the following under " Corrective Steps That will be Taken to Avoid Further Violations"-
Long Term Action:
Additional long term corrective actions are being planned. Southern Nuclear Opera +ing Company (SNC) is de-veloping a corrective action plan to address the programmatic aspects of this violation response. SNC will provide this plan as a supplemental response to this violation within 60 days.
Supplemental Response I. Additional Information Requested by NRC in Inspection Reports 50-348/96-09 and 50-364/96-09:
He additional examples of support discrepancies identified in Paragraph El.2 of these Inspection Reports have been evaluated. In each case, the discrepancy did not impact the component's ability to perform its intended func-tion. Investigation indicates that the five identified discrepancies were a result of personnel error. Three discrepan-cies were a result of failure to update drawings to reflect as-built conditions during initial installation. He remain-ing two discrepaccies occurred recently and resulted from failure to follow installation procedures. During the Unit 2 eleventh refueling outage,47 additional supports were inspected and compared to the drawings and no unaccept-able conditions were identified. Although welding discrepancies have been recently identified, most occurred dur-ing original installation and they do not impact the support's ability to perform its intended function. Therefore, we have confidence in our existing structural welding inspection program.
To address these errors, the following corrective measures will be taken:
1.
Support drawings will be updated to reflect as-built conditions for the three discrepancies.
2.
Maintenance, modification, and design engineering group staffs will be coached on management's expec-tations of following procedures.
These corrective measures will be completed by January 24,1997 E1
s Enclosure Supplemental Response to VIO 50-348,364S6-10-01 II. Long Term Action for VIO 50-348,364/96-10-01; Supplemental Response:
To address the specific concerns identified, the following corrective measures will be completed by March 1,1997:
Design procedures will be revised to require a field inspection of all piping supports on which the loading will be incrd by a design change. His inspection will verify drawing accuracy. Once verified, reinspection for.
subsequent design changes affecting the same piping supports will not be required.
Support drawings will be updated to reflect the results of this field verification effort.
Design proco.m,or obtaining pipe support information will be enhanced to more clearly direct the designer to the proper iniamation.
To increase our confidence in the programs recently questioned by the NRC, Southern Nuclear Company plans to perform a self assessment of the structural welding program, fire protection program, and our piping support pro-gram. %ese program reviews will be similar to the self assessments (SSSAs) performed on thineen safety systems between 1989 and 1995, We are in the initial planning stages of these program assessments and will have a pro-gram scope and preliminary implementation schedule developed by April 30,1997.
SNC performed self assessments (SSSAs) on thirteen Farley Nuclear Plant safety related systems between 1989 and 1995(cach FNP unit was assessed) with further assessments planned. He following systems were included in the original scope; e Control Room Ventilation e Senice Water Residual Heat Removal e
e Reactor Protection.
Safety Related Electrical Distribution Auxiliary Feedwater e
Instrument Air e
Post Accident Sampling e
Ceisg==t Cooling
- Containment isolation Containment Spray e
e Chemical and Volume Control ne SSSAs were performed to ensure design assumptions were reflected in site procedures and to ensure design and plant operations are consistent. He assessments were performed by independent teams ofindividuals with multiple areas of expenise, including design engineering and operations, who performed an in-depth resiew of system design, maintenance, testing, and operation.
E-2