ML20141E822

Response to NRC Re Violations Noted in Insp Repts 50-348/85-40 & 50-364/85-40.Corrective Actions:Maint Work Requests 113930-113934 Re Feedwater Flow Valves Will Be Worked at Next Refueling for Unit 1 Estimated for Fall 1986

ML20141E822
Person / Time
Site:	Farley
Issue date:	12/31/1985
From:	Mcdonald R ALABAMA POWER CO.
To:	Verrelli D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20141E819	List: ML20141E815 ML20141E822
References
NUDOCS 8601080346
Download: ML20141E822 (5)

Text

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. Mailing Address Alabama Power 4 Company 600 Morth 18th Street Post Office Box 2641 Birmingham Alabama 35291 Telephone 205 78340%

R. P. Mcdonald Senior Vice President Flintridge Building gggg gg

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December 31, 1985 Docket No. 50-348 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 September 30 - October 4, 1985 RE: Report Numbers 50-348/85-40 50-364/85-40

Dear Mr. Verrelli:

This letter refers to the violation cited in the subject inspection reports which state:

"The following violation was identified during an inspection conducted on September 30 - October 4, 1985. The Severity Levels were ' assigned in accordance with the NRC Enforcement Policy (10CFR Part 2, Appendix C).

10CFR 50, Appendix B, Criterion V, states that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Contrary to the above, the licensee failed to accomplish activities affecting quality in accordance with prescribed procedures or drawings,_ in that:

a. The limit switch junction box and main control board indication for six feedwater flow control valves were not wired pursuant to prescribed wiring drawings. Furthermore, the licensee failed'to cnrrect these deficiencies on two occasions when sufficient information was available to identify the wiring errors, (1) following the 1984 refueling outage performance of FNP-1-256.15, Loss of Offsite Power-Response Time Test, and (2) during maintenance activitie's performed on May 18, 1985.

PDR a

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Mr. D. M. Verrelli December 31, 1985 Page Two

b. Maintenance work' request numbers 113930, 113931, 113932, 113933, and 113934, issued to correct wiring deficiencies in five feedwater flow control valves on May 31, 1985, did not require the placement of deficiency tags pursuant to procedure FNP-0-AP-52, Equipment Status Control'and Maintenance Authorization.

c. Maintenance work request (MWR) number 114481, issued to trouble shoot and repair as necessary the problems with electrical penetration B037 which had caused shutdown bank 'B' rods E-11 and L-11 to drop on June 23, 1985, was not completed pursuant to procedure FNP-0-AP-52, Equipment Status Control and Maintenance Authorization as follows:

(1) The MWR failed to document the use of approved procedures, technical manuals, or drawings for the determination ~ and retermination of the affected cables.

(2) The failure description block number 18 of the MWR, which provides data for failure trending and analysis, was not completed.

(3) Inspection requirement block r. umber 25 of the MWR was not annotated to indicate required inspections for the maintenance activity.

(4) Nuclear Plant Reliability Data (NPRD) reportable block number 30 was not annotated to indicate if the identified equipment failure was NPRD reportable,

d. Procedure FNP-0-MP-67.0, Continuity' Checks of Control Rod Drive Mechanism (CRDM) Cables and Coils, does not specify vendor supplied coil temperature prerequisites, resulting in the procedure being used on June 23, 1985, to verify resistances for the ' coils of rods E-11 and L-11 containing inadequate acceptance criteria.

This is a Severity Level IV violation (Supplement I)."

Admission or Denial The above violation occurred as described in the subject report.

Reason for Violation

a. The first part of the violation occurred as follows:

During a Unit 1 response time test data review in 1984 for the feedwater flow control valves, I&C personnel identified that the

Mr. D. M. Verrelli December 31, 1985 Page Three closure times for these valves appearad to be too short. Work requests were initiated to resolve this problem. During the 1985 refueling outage, the first of these work requests was worked and a wiring error in the limit switch contact, which 'is used only for I&C response time testing, was identified and corrected. On the next shift'(May 18,1985) the Shift Supervisor determined that the valves were closing properly since proper closing times had been recently verified. The work requests for the remaining valves were functionally accepted. The following week, I&C personnel determined that the previously identified deficiencies still existed and initiated new work requests to correct the limit switch wiring; however, at this time Unit I had returned to power operation and the work could not be perforned,

b. The se' c ond part of the violation was caused by personnel error in that shift personnel . erroneously determined that no deficiency stickers were necessary. because the deficiencies had no operational impact and these valves are located in an area which has limited access during power operation.

c. The third part of the violation was caused by personnel error in that some of the blocks on the MWR were not completed according to procedure and in that the work sequence on the MWR was not' revised to include the necessary steps for repairs after the problem was identified. Instead, the revised work sequence was approved verbally by maintenance supervision and plant management personnel.

d. .The fourth part of the violation was caused by personnel error in that the planner referenced an inappropriate procedure for the existing

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plant conditions.

Corrective Action ~Taken and Results Achieved

a. MWR's 113930, 113931, 113932, 113933, and 113934 had already been written prior to the NRC Inspection. These MWR's will be worked at the next refueling. for Unit 1, estimated Fall,1986.

b. Deficiency stickers have been placed as required.

c. Incomplete blocks on MWR 114481 have been-completed as necessary.

d. At the time of occurrence, the vendor was contacted and the hot CRDM resistance readings were determined to be acceptable. No further action is required.

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Mr. D.'M. Verrelli December 31, 1985 Page Four.

Corrective Steps Taken to Avoid Further Violations

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Operations, maintenance and planning personnel involved in this event will be retrained in the accomplishment of activities affecting~ quality using prescribed procedures and drawings and in completing paperwork properly.

In addition, the~ referenced procedure will be expanded to include steps and acceptance criteria for hot CRDM conditions.

Date of Full Compliance

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December 31, 1986 Affirmation I affirm that this response is true and complete to the .best of my knowledge, information, and belief. The information contained in this

~1etter is not considered to be of a proprietary nature.-

Yours very tru R. P. Mcdonald RPM: sam cc: File

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bc: Mr. J. M. Farle9 Mr. W. O. Whitt Mr. W. G. Hairston, III Mr. J. W. McGowan Mr. J. D. Woodard (A4.02)

Mr. W. H. Bradford Mr. William Ware Mr. Jim Brantley fir. Mike Galle Binder Copy File: 91A3.27