ML20151L855

Responds to Violations Noted in Insp Repts 50-348/88-20 & 50-364/88-20 on 880516-20 & 0606-10.Corrective Actions: FNP-1/2-STP-9.0 Revised to Include Correct Constant

ML20151L855
Person / Time
Site:	Farley
Issue date:	07/28/1988
From:	Hairston W ALABAMA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NT-88-0356, NT-88-356, NUDOCS 8808040162
Download: ML20151L855 (3)

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NT 88-0356

.- Arabima Pcwer company 600 North 18th Street Post Off<.e Box 2641 Birmingham, Alabama 352910400

= Telephone 205 250-1837 W. G. Hairston,111 Senior Vice President Nixiear Operatons the southem electrc system July 28, 1988 Docket No. 50-348 Docket No. 50-364 U. S. Nuclear Regulatory Comission Attention: Docunent Control Desk Washington, D. C. 20555

SUBJECT:

Reply to a Notice of Violation J. M. Farley Nuclear Plant NRC Inspection of May 16 - 20 and June 6 - 10, 1988 RE: Report Number 50-348/88-20-03 50-364/88-20-03

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 May )

16-20 and June 6-10, 1988, a violation of NRC requirements was identified. In j l accordance with the "General Statement of Policy and Procedure for NRC i Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violation is listed below:

Technical Specification 6.8.1.C requires written procedures for surveillance activities. Technical Specification 4.4.7.2.1.d requires a reactor coolant system water inventory balance at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Technical Specification 3.4.7.2.b limits the unidentified leakage from the reactor coolant system to 1 gallon per minute.

Contrary to the above, procedure FNP-1/2-STP-9.0, used to perform the reactor coolant system water inventory balance, was not capable of performing that required surveillance reliably. An error in the constant used to equate changes in pressurizer level was such that j a one-percent increase in level would lead to under calculating the unidentified leakage by 0.5 to 1.0 gpm, a significant part of the total allowance.

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

' ' I 8808040162 880728 PDR ADOCK 05000348 Q PDC ,

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U. S. Nuclear Regulatory Commission  ;

July 28, 1988 j Page 2  ;

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

Reason for Violation This violation was caused by personnel error.

Corrective Action Taken and Results Achieved It was immediately verified that the existing reactor coolant system (RCS) leak rate was within Technical Specification limits.

Corrective Steps To Avoid Further Violations FNP-1/2-STP-9.0 was revised to include the correct constant.

Date of Full Compliance June 15, 1988 Comment The only time the RCS leak rate calculation was not conservative was when pressa Azer level was allowed to increase during a leak rate determination.

In the majority of cases, leak rate calculations at Farley Nuclear Plant have been performed with constant pressurizer level. The Pressurizer Level Control System normally maintains a constant level whether or not leakage exists. In the event of a significant leak, the pressurizer level would have dropped. In this case, the procedure would have led to a conservative over-estimation of the leak rate.

Subsequent to the violation cited in Report Numbers 50-348(364)/88-20-03, during a review of the revised FNP-2-STP-9.0 procedure results, the NRC resident inspector questioned the accuracy and methodology used to account for the water leaked to the BIT surge tank. He believes that this is another ,

example of violation 50-348(364)/88-20-03. This concern is being evaluated.

This concern is only applicable to Unit 2 due to the design differences in the BIT bypass valve piping. FNP-2-STP-9 will be modified as necessary to ensure a correct and accurate methodology for calculating RCS leakage.

l This action will be complete by August 5, 1988.

Affirmation I affirm tnat this response is true and complete to the best of my knowledge, 1

• U. S, Nuclear Regulatory Comission July 28, 1988

-Page 3 information, and belief. The information contained in this letter is not considered to be of a proprietary nature.

Yours very truly, id,h. N #W W. G. Hairston, III WGH:emb cc: Mr. L. B. Long Dr. J. N. Grace Mr. E. A. Reeves Mr. W. H. Bradford i

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