ML20148C299
| ML20148C299 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 03/16/1988 |
| From: | Mcdonald R ALABAMA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NT-88-0118, NT-88-118, NUDOCS 8803220327 | |
| Download: ML20148C299 (3) | |
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Alibama Power Company NT 88-0118 600 Nortt.18th Street Post office Box 2641 Birmingham. Alabama 35291-0400 Telephone 205 250-1835 m
R. P. Mc Donald l
Senior Vice President Alabama Power the southem ela:trC system March 16, 1988 U. S. Nuclear Regulatory Comission Attention: Docurrent Control Des,.
Washington, D. C. 20555
SUBJECT:
J. M. Farley Nuclear Plant NRC Inspection of December 2-4, 1987 RE:
Report Numbers 50-348/87-35-01 50-364/87-35-01
Dear Sir:
This letter refers to the violation cited in the subject inspection reports which state:
"During the Nuclear Regulatory Comission (NRC) inspection conducted on December 2 - 4, 1987, a violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the violation is listed below:
Technical Specification 6.8.1 requires that written procedures be i
implemented covering the activities recomended in Appendix A of Regulatory Guide 1.33, Revision 2, 1978. Regulatory Guide 1.33, Appendix A includes administrative procedures for procedural adherence and maintenance procedures.
FNP-0-AP-6, Procedure Adherence, and FNP-0-AP-16, Conduct of Operations, I
require adhetence to all plant procedures except under emergency conditions, where adherence to the procedures will create an undue hazard l
to personnel, equipment, or public health and safety, or under a l
temporary procedure change.
FNP-0-AP-57, Preservice and Inservice l
Inspections, and FNP-0-AP-5, surveillance Program Administrative Control, require tests to be performed in accordance with plant procedures.
l FNP-0-AP-52, Equipment Status Control and Maintenance Authorization, and l
FNP-0-AP-5, Surveillance Program Administrative Control, require that
(
directions be provided for the restoration of equipnent and systems to service.
\\
(,0 8803220327 880316 1l R
ADOCK 05000348 G
l U. S. Nuclear Regulatory Conunission March 16, 1988 Page 2 Contrary to the above, on November 27, 1987:
Operations personnel marked initial condition 3.2 of surveillance test procedure (STP) ENP-2-STP-ll.6, Residual Heat Removal (RHR) Inservice Test, as not applicable (NA). We licensee departed from the test procedure initial condition which would have required taking "A" RHR train out of service and closing the "A" RHR pump suction isolation valves. This departure occurred under non-emergency plant conditions and was not processed as a temporary procedure change. As a result of the NA cn initial condition 3.2, the valve testing was not performed in recordance with the approved test procedure.
Additionally, the licensee failed to provide instructions for the fill and vent of that portion of the RHR "A" train p ping between valves 8811A and 8812A prior to its return to service.
This is a Severity Level IV violation (Supplement I)."
Admission or Denial h e above violation occurred as described in the subject reports.
Reason for Violation The first part of the violation was caused by personnel error in that the Shift Supervisor marked an initial condition of EWP-2-STP-ll.6 NA without proper procedural guidance or writing a temporary procedure change. A contributing cause is that no procedura'l guidance ex.sted previously for performing only a portion of an STP. We second part of the above violation was caused by personnel error in that upon completion of local leak rate testing, the volume between valves 8811A and 8812A was not filled and vented prior to its return to service.
Corrective Action Taken and Results Achieved he normal pressurizer level was restored. The A train RHR system was inspected to ensure that the suspected pressure surge had not resulted in damage to components in the system. The system walkdown determined that no damage had occurred.
Corrective Steps Taken to Avoid Further Violations f
The Shift Supervisor involved in this event was counseled. Procedural guidance for performing only a portion of an STP has been provided to plant personnel through changes to FNP-0-AP-5.
FNP-1/2-STP-627, Local Leak Rate Testing of Containment Penetrations, has been changed to ensure that systems that were drained are filled and vented upon completion of local leak rate l
testing.
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U. S. Nuclear Regulatory Conmission March 16, 1988-Page 3 Date of Full Compliance March 10, 1988-Affirmation I affirm that this response is true and complete to the best of my knowledge, information, and belief. 'Ihe information contained in this letter is not considered to be of a proprietary nature.
Y rs e
- truly, I,
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J R.
. Mcdonald RPM /emb cc:
Mr. L. B. Long Dr. J. N. Grace Mr. E. A. Reeves Mr. W. H. Bradford
.