ML20148E645
| ML20148E645 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 05/28/1997 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-348-97-03, 50-348-97-3, 50-364-97-03, 50-364-97-3, NUDOCS 9706030207 | |
| Download: ML20148E645 (6) | |
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0;ve M; rey Southern Nuclear Vice President Operating Company Farley Prcject R0 Box 1795 Birmingham, Alabama 35201 Tel 205.992.5131 SOUTHERN May 28,1997 l
Energy eo ServeYour%ld*
Docket Nos.:
50-348 10 CFR 2.201 50-364 U.S. Nuclear Regulatory Commission ATfN: Document Control Desk Washington, DC 20555 Joseph M. Farley Nuclear Plant i
Reply To a Notice Of Violation (VIO)
J NRC Inspection Report Number 50-348.364/97-03 Ladies and Gentlemen:
r As requested by your transmittal dated April 28,1997, this letter responds to VIO 50-348,364/97-03-01, " Multiple Examples Of Failure To Follow Procedure."
i The Southern Nuclear Operating Company (SNC) response is provided in the enclosure.
_Csnfirmation I affirm that the response is true and complete to the best of my knowledge, inforntation, and belief.
l Respectfully submitted, (0 b$ftl Dave Morey l
WAS/ cit: nov97031. doc i
Enclosure cc:
Mr. L. A. Reyes, Region II Administrator Mr. J. I. Zimmerman, NRR Project Manager Mr. T. M. Ross, Plant Sr. Resident Inspector i
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ENCLOSURE Response to VIO 50-348,364/97-03-01
" Multiple Examples Of Failure To Follow Procedure" i
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RESPONSE TO VIO 50-348,364/97-03-01 I
VIO 50-348,364/97-03-01," Multiple Examples Of Failure To Follow Procedure" states:
Technical Specification (TS) 6.8.1.a requires that applicable written procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, dated Febmary 1978, shall be established, implemented and maintained. Regulatory Guide 1.33, Appendix A, Section 8 recommends specific procedures for surveillance testing and calibrations; and Section 2 recommends operating procedures for plant shutdown and cooldown. TS 6.8.1.e also requires written procedures be established and implemented for Emergency Plan implementation.
Administrative Procedure (AP) FNP-0-AP-6, " Procedure Adherence," Revision 2, states that safety-related procedures shall be followed. Desiations from plant procedures shall not be permitted except for emergencies and temporary changes documented in accordance with FNP <
AP-1, " Development, Review, and Approval of Plant Procedures," Revision 34.
Emergency Plan implementing Procedure (ElP) FNP-0-EIP-16.0, " Emergency Equipment and Supplies," Revision 31 requires periodic inventory verification of emergency equipment and supplies.
FNP-0-GMP-1, Preventative Maintenance Procedure, Revision 17, Section 6.1, required any changes to preventative maintenance (PM) to be approved. Work Authorization WOO 470336/7 contained PM data sheets which required the diesel fuel oil day tank room float switch level checks to be repeated three times per switch.
A caution statement prior to step 5.21 of Unit Operating Procedure (UOP) FNP-1-UOP-2.2,
" Shutdown of Unit From Hot Standby to Cold Shutdown," Revision 45, required residual heat removal (RHR) pump discharge to charging pump suction valve breders to be open prior to entering Mode 4.
Step 8.12 of Surveillance Test Procedure (STP) FNP-1-STP-158, " Reactor Coolant System Pressure Isolation Valve Leak Test," Revinicn 15, required the initial system valve lineup to be restored after completing the check valve bac). leakage of step 9.3.
Contrary to the above the following failures to follow procedures were identified:
On February 27,1997, the licensee discovered that numerous inventory checklists verifying emergency equipment and supplies were not being performed.
On February 27, 1997, an Instrumentation and Controls technician only performed the calibration check of each IB Emergency Diesel Generator (EDG) fuel oil day tank float switches once while the PM checklist required to be perfonned three times. This change to the PM was not approved.
On March 15, 1997, operators entered Mode 4 without opening RHR pump discharge to charging pump suction valve breakers.
On March 16,1997, a test engineer failed to restore initial system valve lineup per step 8.12 of STP FNP-1-STP-158, prior to commencing the next check valve back leakage test of step 9.4.
This is a Severity Level IV violation (Supplement 1).
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RESPONSE TO VIO 50-348,364/97-03-01 i
Admission or Denial The violation occurred as described in the Notice of Violation.
Reason for Violation The following are the four instances of failure to follow procedure addressed in the violation:
- 1) Emergency Plan checklists 1
The cause of this event was willful disregard for procedural adherence in that the' individual chose not to perform the procedure.
- 2) Float switches calibration test l
The cause of this event was personnel error in that the technician performing the test did not adhere to i
the instructions on the PM Data Sheet. The technician made the incorrect assumption that the instruction to perform the test three separate times was not required if the as found data was within the acceptable tolerance and no adjustments were necessary.
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- 3) Failure to open power supply breakers as required j
i The cause of this event was personnel error in that Operations personnel failed to adequately review the j
i operating procedure prior to Mode 4 entry. Contributing to this event was inadequate procedural 4
guidance in that the Caution statement for the Mode 4 entry requirement was placed at a point in the procedure such that Mode 4 could be entered prior to reaching that point in the proa se.
- 4) Failure to restore initial system valve lineup as specified by procedure The cause of this event was personnel error. The test engineer incorrectly assumed that initial valve lineups only had to be restored following the completion of all testing when, in fact, it was required to be performed at the completion of each test.
Corrective Steps Taken and Results Achieved
- 1) The checklists that were assigned to the EP Technician were re-perfonned by other personnel. The majority, including any that were considered to be high priority, were performed on 2-28-97. The remainder of the checklists were completed on 3-3-97 and 3-4-97. Some discrepancies were noted, but there were sufficient supplies to implement the Emergency Plan.
- 2) A determination was made by Maintenance Group management that the single calibration check of the float switch satisfied the minimum calibration requirements.
- 3) Immediate corrective actions consisted of verifying closed the MOVs and locking open the power supply breakers for the RHR discharge to charging pump suction MOVs 8706A and 8706B within 6 minutes of entering Mode.4.
- 4) The operator repositioned MOV 8888B to restore additional cooling flow te the RCS and the mispositioned valves were realigned.
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RESPONSE TO VIO 50-348,364/97-03-01 1
Corrective Steps That Will Be Taken to Avoid Further Violation
- 1) The individual involved in implementing the checklists has received appropriate disciplinary action in accordance with company policy.
- 2) The individual involved in the calibration check was coached on expectations for procedural adherence. Emphasis has been placed on strict procedural adherence during the Maintenance Manager's meetings with the maintenance teams. The Maintenance Group has also instituted a program wherein Maintenance management will periodically observe selected jobs / tasks. During these observations the requirement for procedural adherence will continue to be reinforced.
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- 3) To prevent recurrence, Operations personnel involved in this event were coached on procedural adherence. Operations startup and shutdown procedures were revised to more clearly provide criteria to be satisfied prior to mode changes and to require Shift Supervisor authorization prior to a mode change.
- 4) Corrective actions consisted of disciplinary action for the individual involved and a " stand-down" meeting with Engineering Support personnel to discuss the incident with special emphasis placed on the requirement for procedural adherence in addition, a comprehensive review of the test procedures for Unit I and Unit 2 was conducted by the Operations and Engineering Support j
Groups. The test procedures (FNP-1/2-STP-158) will be revised to more clearly designate the pre-test and post-test valve positions required for each test.
In the cover letter of the Inspection Report, a concern was expressed that this is a repeat violation and that previous corrective actions taken to address procedural compliance violations had not been completely effective.
l A broadness review, which included the additional examples of failure to follow procedures identified in
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Inspection Report 50-348/97-03 and 50-364/97-03, was recently conducted to determine the root cause of the failure to follow procedures. The results of this review were compared to results from a similar j
broadness review which was conducted in 1995.
The 1995 broadness review to address procedural adherence identified problems in 4 areas:
I e Not performing a step when there is no allowance for non-performance identified within the procedure i
or no provision for identifying the step as not applicable 1
= Not signing off each step as it is performed when the procedure does not specify that this is allowed
. Not performirg steps in the designated sequence when the procedure does not specify that this is allowed
. Pert' rming actions that are not in direct compliance with the procedure as written o
.The results of the current broadness review indicates the 1995 corrective actions were effective in mitigating two of the problem areas:
. Not signing ofreach step as it is perfonned when the procedure does not specify that this is allowed e Not performing steps in the designated sequence when the procedure does not specify that this is allowed E-3
RESPONSE TO VIO 50-348,364/97-03-01 1
Corrective actions for the following areas do not appear to have been as successful as desired:
- Not performing a step when there is no allowance for non-performance identified within the procedure or no provision for idcatifying the step as not applicable
. Performing actions that are not in direct compliance with the procedure as written The following additional corrective actions will be taken to address the generic concerns with procedural adherence at FNP:
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. The current broadness review has determined categories of procedural non4:ompliance. To ensure l
that the underlying cause of the non-compliances is understood, inteniews will be conducted with
.l various plant personnel.
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. It is recognized that total elimination of procedural adherence errors cannot be achieved. Therefore, in order to better identify when adverse trends of procedural adherence require corrective actions, the FNP trending program will have some threshold action levels added to have the problems evaluated from a cumulative or aggregate aspect.
l Date of Full Compliance August 31,1997 c
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