ML20151T692

Responds to Violations Noted in Insp Repts 50-348/88-19 & 50-364/88-19.Corrective Actions:All Cover Plates & Flanges on Unit 1 post-accident Containment Venting Filter Unit Inspected & Tightened

ML20151T692
Person / Time
Site:	Farley
Issue date:	08/04/1988
From:	Hairston W ALABAMA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NT-88-0375, NT-88-375, NUDOCS 8808160447
Download: ML20151T692 (4)

Text

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. . NT 88-0375.

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Alabama PowerCompany 600 North 18th Street Post office Box 2641 Birmingham, Alabama 352914400 f~ Telephone 205 250-1837 W. G. Hairston, Ill Senior Vice President Nuclear Operations the sNhern elecinc system -

August 4, 1988 Docket No. 50-348 Docket No. 50-364 I

U. S. Nuclear Regulatory Commission Attention: Document Control Derk Washington, D. C. 20555

SUBJECT:

Reply to a Notice of Violation J. M. Farley Nuclear Plant NRC Inspection of May 11 - June 10, 1988 RE: Report Number 50-348/88-19 50-364/88-19

Dear Sir:

This letter refers to the violations cited in the subject inspection reports which state; "During the Nuclear Regulatory Comission -(NRC) inspection conducted on May 11 - June 10, 1988 violations of NRC requirements were .dentified.

The violations involve the failure to: adequately inspect and maintain safet.y related equipment; conduct an adequate 10 CFR Sc,59 Safety Evaluation, and, 'ailure to follow procedures. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violations are cited below:

A. 10 CFR 50 Appendix B Criterion X states in p:.rt that a program for inspection of activities affecting quality shall be er'ablished and executed to verify conformance with documented ir.4tructier.s and drawings for accomplishing the activity.

Farley's Operations Quality Assurance Policy Manual, chapter 10, states in part that inspectionr., shall be performed to insure quality of safety related activities with inspections performed j in accordance with documented instructions and check lists to assure substandard items do not remain undetected.

Contrary to the a.;ove, adequate inspections to verify operability of the Unit 1 post accident containment ventilation filter unit were not performed in that on May 9,1988, five of eight bolts  !

to the carbon fill port coverplate and two of four bolts to a l blank flange were found loose, j i

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U. S. Nuclear Pegulatory Cordission August 4, 1988^

.Page 2 h is is a Severity Level'IV violation (Supplement 1).

B. 10 CFR 50.59 authorizes the licensee to make changes in the-facility as described in the safety analysis report unless the  !

change involves a change in the technical specifications or an unreviewed safety question.

Contrary to the above, during the 1988 Unit 1 refueling outage, the licensee replaced the individual battery powered emergency light units inside Unit 1 containment with an emergency lighting system supplied from two redundant uninterruptible power supply units which are located outside containment. However, the licensee failed to perform an adequate evaluation to determine if this change resulted in a change to the safety analysis report.

The new emergency lighting system for the Unit 1 containment is an improvement over the previously installed system but does not conform to the system description in the Fiaal Safety Analysis Report (FSAR) .

This is a Severity Level IV violation (supplement 1).

C. Technical Specification 6.8.1 requires that applicable w itten procedures recomended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, 1078 shall be' established, implement (sic.) and maintained.

Procedure O-SHP-122, Storage and Handling of Compressed Gas Orlinders, requires gas cylinders to be firmly. secured with wall brackets, chains, rope or other adequate restraints.

Contrary to the above, on May 28, 1988, one span gas oxyg a cylinder at Unit 1 hydrogen recombiner and three span gas cylinder >. at Unit 2 hydrogen recombiner were not secured to prevent mechanical damage.

These cylinders were too large for the available storage racks and were not secured in place.

This is a Severity Level IV violation (Supplement 1)."

Admission or Denial A. W e above violatica occurred as described in the subject reports.

4 B. The above violation occurred as described in the subject reports.

However, based on the fact that, as stated in the violation, "the new emergency lighting system R the Unit 1 containment is an improvement

U. S. Nuclear' Regulatory Commission August 4, 1988 Page 3 over the previously installed system," the Severity Level IV classifica-tion' (i.e., a matter that has more than minor safety or environrental significance) is not appropriate. The proper classification would'be Severity Level V (i.e., violations that have minor safety or environ-mental .-ignificance).

C. The above violation occurred as described in the subject reports.

Reasons for Violations A. This violation was caused by an inadequate preventive maintenance procedure in that the instructions in FNP-0-GMP-15.0, General Inspection of CVI Filter Units, did not address the inspection of the bolts that were found loose.

B. This violation was caused by personnel error in that the safety evaluation did not indicate that a change to the FSAR was required.

C. This violation was caused by personnel error in that the cylinders were not secured as required.

erective Action Taken and Results Achieved A. All cover plates and flanges on the Unit One post accident containment venting filter unit were inspected and tightened. The cover plates and flanges on the Unit Two system were also inspected and found to be properly secured.

B. A revised safety evaluation was obtained and reviewed by the Plant Operations Review Committ'e.

C. The cylinders were immediately secured.

Corrective Steps To Avoid Further Violations A. FNP-0-C+1P-15.0 was revised to add a statement to inspect all bolts to ensure tightness.

B. The personnel involved have been counseled on the requirement to ensure that the safety evaluations developed by design organizations for design changes are valid.

C. Instrument = tion and Controls personnel have been retrained in proper t.andling of gas cylinders per FNP-0-SHP-122.

U. S. Nuclear Regulatory Comission .

August 4, 1988 ~

Page 4 Datet of Full Compliance A. - July 20, 1988 B. July 14, 1988 i

C. July 13, 1988 Affirmation ,

I affirm that this responso is true and complete.to the best of my knowledge, inforraation, and belief. The information contained in this letter is not ,

considered to be of a proprietary nature.

Yours very truly,

~

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W. G. Hairston, III WGH/emb cc: Mr. L. B. Long Dr. J. N. Grace Mr. E. A. Reeves Mr. W. H. Bradford .

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