ML20148J519
| ML20148J519 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 03/21/1988 |
| From: | Mcdonald R ALABAMA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NT-88-0134, NT-88-134, NUDOCS 8803300300 | |
| Download: ML20148J519 (4) | |
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4 Alabsma Power Company 600 North 18th str$et Post Offu:e Box 2641 Birmingham, Alabama 35291-0400
. Telephone 205 250-1835 m
R. P. Mc Donald Alabama Power senior Vice President the southem ekctnc sptem March 21, 1988 Docket No. 50-348 Docket No, 50-364 U. S. Nuclear Regulatory Comission Attention: Document Control Desk Washington, D. C. 20555
SUBJECT:
Reply to a Notice of Violation J. M. Farley Nuclear Plant NRC Inspection of January 12 - February 10, 1988 RE:
Report Number 50-348/88-03 50-364/88-03
Dear Sir:
his letter refers to the violations cited in the subject inspection reports which state:
"During the Nuclear Regulatory Comission (NRC) inspection conducted on January 12 - February 10, 1988 violations of NRC requirements were identified. he violations involved procedural violations and a violation of fire protection Technical Specification 3.7.11.2.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Acticns," 10 CFR Part 2, Appendix C (1986), the violation is cited below:
Technical Specification 6.8.1 requires that applicable written procedures A.
recomended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2,1978 shall be established, implemented and maintained.
Contrary to the above, the following examples of deficient procedural implementation or adequacy were noted.
1.
Procedure 1-SOP-8.1, High Head Safety Injection System, check list 1-SOP-8.lA, requires breaker FA-M4 in Motor Control Center (MCC) 1A, f:)r boron injection surge tank heater, to be in the closed position.
During power cperation on January 20, 1988 breaker FA-M4 was in the open position.
2.
Procedure 2-SOP-24, Service Water System, check list 2-SOP-24.0A requires breaker HKL-J3 in MCC 1K, cooling and lubrication strainer During to Train A service water pumps, to be in the closed posti. ion.
power operation on January 27, 1988 Breaker HKL-J3 was in the open position.
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U. S. Nuclear Regulatory Commission March 21, 1988 Page 2 3.
Procedure 1-SOP-24, Service Water System, check list 1-SOP-24.0A requires breaker HKL-K4 in MCC 1K, for cooling and lubrication strainer to the Train A service water pumps, to be in the closed position. During power operation en January 27, 1988 Breaker HKL-K4 was in the open position.
4.
Procedure 2-SOP-50.6, Liquid Waste Processing System Miscellaneous Sump Pump and Retaining Basin Operation, check list 2-SOP-50.6A, I
requires breaker HCC-D5 in MCC 2CC, to sump pump N2WO9505B-N forDuring safety related valve pit 2VB-2, to be in the closed position.
power operation on January 27, 1988 Breaker HCC-D5 was in the open
- position, 5.
Technical Specification surveillance requirement 4.7.4 requires that f
the service water system be demonstrated operable by verifying that each accessible valve (manual, power operated or automatic) in the flow path, servicing safety related equipnent that is not locked, sealed or otherwise secured in position, is in its correct position at least once per 31 days.
During p]wer operation on February 5,1988 the service water lube and cooling water piping systems on Unit 1 and Unit 2 were not included in mP-1-2-STP-24.5, Service Water Flow Path verification.
h is is a Severity Level IV Violation (Supplement I).
Technical Specification 3.7.11.2 requires the fire suppression system B.
(spray and/or sprinkler system) be operable whenever the equipment in the The Action statement states protected areas is required to be operable.
that, with one or more of the above required spray and/or sprinkler systems inoperable, within one hour establish a continuoas fire watch with backup fire suppression equipment for those areas in which redundant systems or components could be damaged; for other areas, establish an heurly fJre watch patrol.
Contrary to the above, on January 19-20, 1988 the required fire watches were not initiated. Unit 1 fire suppression system was inoperable for approximately 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> when the fire protection panel switch was inadvertently placed in the over ride position. he fire detection system remained operable.
W is is a Severity Level IV Violation (Supplement I)."
Admission or Denial he above violations occurred as described in the subject reports.
Reason for Violations This violation was caused by personnel error in that the breakers A.
mentioned in Items 1-4 were opened without prcper documentation or
U. S. Nuclear Regulatory Commission March 21, 1988 l
Page 3 controls, in violation of the applicable system operating procedure alignment requirements.
Item 5 was also caused by personnel error in that when the Service Water Flow Path Verification Procedure was developed, the Service Water lutrication and cooling system was not considered to be part of the Service Water main flow path verification.
In retrospect, after the inspector pointed out the deficiency, it was recognized that the lubrication and cooling should be part of the flow path verification.
B.
As discussed in LER 88-002-00 Unit 1 (Docket Number 05000348), this violation was caused by personnel error in that an individual failed to ensure that the switch was in the correct position. A contributing factor to the event was that the key switch was faulty. We master override switch is key-operated.
It should allow the key to be removed only when in the normal position. However, the key switch malfunctioned and enabled the key to be removed from the o/erride position.
Another contributing cause was that the control room fire protection system trouble alarm, which originates from the fire protection Pyrotronics panel trouble alarm, was defeated. The trouble alarm was annunciating continuously due to trouble in a smoke detector circuit. A maintenance work request had been originated to correct this problem.
When the master override switch is in the override position, a trouble alarm is generated. However, since the trouble alarm was already alarming, no annunciation resulted from the switch being left in override.
Therefore, the control room operators could not have been aware that the switch was in the override position.
Corrective Action Taken and Results Achieved A.
he breakers were closed in accordance with system operating procedure guidance. Electrical system breaker checklists were performed on both units. Also, a Service Water flow path position verification was performed on the lubrication and cooling valves and all of them were found to be in the correct position.
B.
We override switch was reset, returning the Pyrotronics panel to normal.
Corrective Steps to Avoid Further Violations A.
A formal operation memorandum is being sent to Operations, Electrical Maintenance, and Instrumentation and Controls personnel to re-instruct them that repositioning breakers should not be done without proper documentation, i.e., utilizing a maintenance work request, tagging operations order, or approved procedure. Procedures FNP-1/2-STP-24.5, Service Water Flow Path Verification, are being changed to include the Service Water lubrication and cooling valves in the flow path.
B.
he system operator involved has been counseled concerning this event.
W e problem with the smoke detector system which caused the system trouble alarm to annunciate has been repaired. We master override switch will be repaired.
[ A-s U. S. Nuclear Regulatory Connission March 21, 1988 Page 4 Date of Full Compliance April 29, 1988 Affirmation I affirm that this response is true and complete to the best of my knowledge, information, and belief. The information contained in this letter is not considered to be of a proprietary nature.
Yours ve
- ruly,
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[.P. Mcdonald RPM:emb cc Mr. L. B. Long Dr. J. N. Grace Mr. E. A. Reeves Mr. W. H. Bradford i
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