ML20195H822
| ML20195H822 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 06/15/1988 |
| From: | Hairston W ALABAMA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NT-88-0292, NT-88-292, NUDOCS 8806290001 | |
| Download: ML20195H822 (6) | |
Text
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9 NT 88 0292 a
Alabama Powor Company
. s00 Morth 18th Stroot Post ottee Box 2641 Birmingham. Atabama 352914400 Tekphone 205 250-1837 W. G. Hehilon. HI I
Vice President Neclear Generatien AlabamaPower frv scVNrn ekictre systern June 15, 1988 Docket Nos. 50-348 l
50-3C4 U. S. Nuclear Regulatory Comission Attention: Document Control Desk Washington, D. C. 20555
SUBJECT:
Reply to a Notice of Violation J. M. Earley Nuclear Plant NRC Inspaction of February 22 - 26 and March 7 - 11, 1988 RE:
Report Number 50-348/88-05-01 50-364/88-05-01
Dear Sir:
This letter refers to the violation cited in the subject inspection reports which state:
"During the Nuclear Regulatory Comission (NRC) inspection ecnducted on February 22-26 and March 7-11, 1988, a violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Pro-cedure for NRC Enforcement Actions," 10 CrR Part 2, Appendix C (1988), the violation is listed below:
10 CTR 50, Appendix B, Criterion V states, in part, that activities affecting quality shall be prescribed by documented instructions and shall be accomplished in accordance with these instructions.
10 CrR 50, Appendix B, Criterion XVI, requires, in part, that measures shall be established to assure that conditions adverse to quality are promptly corrected.
Procedure FNP-0-AP-15, Maintenance conduct of operations, Rev. 9, indicates that quality will be controlled, in part, by Supervisor Check Points. Step 6.2 of TNP-0-AP-15 states that the Supervisor Check Point will be denoted by the letter "S" in the left hand margin of the procedure and that the Maintenance Foreman responsible for the accomplishment of the task must verify the activity.
Procedute TNP-0-AP-04, Control of Plant Documents and Records, Revision 12, specifies requirements for controlling plant docuinents and records.
Contrary to the above, the licensee failed to follow procedures and failed to prevent deficient conditions from reoccurring in the following cases:
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". S. Nuclear Regulatory Comission June 15, 1988 Page 2 1.
Although ne-0-AP-15 required the Maintenance Foreman to sign designated check points, the licensee failed to follow n4P-0-AP-15 as identified ja the SAER audito listed below and failed to take 1
adequate corrrctive action to prevent deficient Supervisor Check Point sign offs from reoccurring during the performance of maintenance activities, A May 16, 1986, Safety Audit and Engineering Review (SAER) Group audit report indicated that a Maintenance Toreman allowed nonsupervisory personnel tc sign "S" points during the performance of ne-0-STP-616, Control Room Emergency Ventilation System Heater Test. A June 30, 1986, SAER audit report indicated that day shift Maintenance personnel signed "S" points for night shift work. An SAER audit dated December 12, 1986, indicated that the "S" point for cleaning and testing reactor trip breakers was signed by a journeyman. An 1AER audit dated March 25, 1987, indicated that ne-0-GMP-52.3, Replacement of Individual Battery cells in Existing Batteries, was not followed in that a Maintenance Foreman did not sign an "S" point. A May 26, 1987, SAER audit indicated that an "S" point in procedure ne-0-MP-53.2, Lif ting of Main Turbine HP Rotor, was signed off as complete the day before the step was performed.
2.
Although ne-0-AP-04 required control of documentation and reports, the licensee failed to ensure administrative instructions were followed and failed to take adequate corrective action to prevent the deficient conditions from reoccurring as r.o'ed below. On March 8, 1988*, an incorrect revision of ne-0-AP-14 *c.s noted in the Materials Warehouse, Plant Manager's office and Maintenance Supervisor's office. Also, the Control Room contained incorrect revisions for procedures ne-0-ECP-000, ne-2-ARP-1.2 (Part B),
ne-2-ARP-1.2 (Part G) and drawing D20007. Previous SAER audit finding n@-NC-62-86/9(18) had identified a problem with document control. An internal licensee letter indicated that the corrective i
action was completed on Jrne 25, 1987. During a subsequent STIR audit (Audit Report No. 87-14 dated July 30, 198'/), the SAER determined that the corrective action **as inadequate in that four i
additional procedures that were in use in the control room were found to have incorrect revisions.
This is a Severity Level IV violation (Supplement I)."
Admission or Denial
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The ateve violation occurred as described in the subject reports.
- The records at Alabama Power Company indicate this occurred during the i
week of February 22, 1988 vice March 8, 1988.
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U. S. Nuclear Regulatory Commission June 15, 1988 Page 3
Background
1.
A.
On March 22, 1986, the electrician performing FNP-0-STP-616 in-correctly signed a supervisor checkpoint to verify that a jumper had been removed. The cause of the deficiency was attributed to personnel error. The corrective action was to retrain personnel on procedural requirements.
B.
On May 2, 1986, during the performance of the five-year inspection of the 2C reactor coolant pump motor, the work copy of FNP-0-MP-61.2 was contaminated and destroyed before a duplicate was made. This resulted in the steps being signed at a later date than when the work was completed. The cause of the deficiency was attributed to personnel error. The corrective action was to retrain personnel on procedural requirements.
C.
From May 10 - 13, 1985, during the performance of a preventive maintenance task to inspect, clean, and test reactor trip breaker switchgear, an electrician incorrectly signed supervisor checkpoints.
The cause of the deficiency was attributed to inattention to detail and lack of instruction. The corrective action was to continue to retrain personnel in attention to detail.
D.
From April 18, 1986 through May 2,1986, supervisory personnel failed to sign supervisor checkpoints during the performance of FNP-0-GMP-52.3.
The cause of the deficiency was attributed to personnel error. The corrective action was to continue to retrain personnel on procedural adherence and attention to detail.
E.
On April 22, 1987, FNP-0-MP-53.2 was being performed to remove the spare high pressure turbine rotor from the turbine building. The equipment was checked out and inspected, and adjustments were made to perform the lift. The steps in the procedure were completed and signed off through step 5.3.
The next day when work continued, the work supe:vidor noticed that the lifting beam yokes were in the low pressure rotor position and repositioned them to lift the high pressure rotor. The work supervisor did not sign step 5.3 again because he felt that his signature on April 22, 1987 was satisfactory.
The cause of the deficiency was attributed to personnel error with procedurcl inadequacy as a contributing factor. The corrective action was to discuss this event with all Mechanical Maintenance supervisory personnel and to revise FNP-0-MP-53.2 to clarify the procedure and to include an additional supervisory signoff in step 5.5.
2.
A.
SAER noncompliance FNP-NC-62-86/9(18) was written in May 1986.
This noncompliance was for untimely distribution of a revision to a controlled document which resulted in acceptance of data based on incorrect criteria. Corrective action included an evaluation showing that the tests results were acceptable and a revision to FNP-0-AP-4, Control of Plant Documents, which clarified distribution requirements.
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l U. S. Nuclear Regulatory Commission June 15, 1988 Page 4 In addition, emphasis was placed on prompt distribution of revisions and changes to controlled documents. Corrective action was reported complete on June 30, 1987 and re-audited and closed by SAER in November, 1987.
B.
In July, 1986, SAER issued noncompliance FNP-NC-76-86/12(21) against the Operations Group for using incorrect revisions of controlled procedures.
Four examples were cited. Wo were for untimely distribution of revisions to controlled documents by Document Control and the other two were filing errors by the Operations personnel assigned to update procedure files. Corrective action included promptly updating procedures and reinstructing Operations personnel on requirements for updating controlled procedures.
In addition, the corrective action specified for noncompliance mP-NC-62-86/9(18) concerning clarification of distribution of procedures was re-stated for FNP-NC-76-86/12(21).
In July, 1987, SAER conducted an Operations STP audit and reconfirmed C.
nonccmpliance FNP-NC-76-86/12(21) for inadequate corrective action.
Four examples of incorrect procedure revisions were noted. All four involved filing errors by Operations personnel. Another Corrective Action Report (CAR 1388) was submitted in August, 1987. Corrective actions included counseling personnel responsible for the filing errors, reducing the number of copies retained by Operations, relocating files to make updating less confusing and-periodically auditing files to verify correct revision. SAER audited the corrective action and closed the noncompliance in November, 1987.
Temporary change notice 8C to FNP-0-AP-14 was transmitted by Document D.
Control on February 10, 1988 to all holders of controlled copies.
When the inspector audited the files, he noted that several holders had not incorporated this TCN into the controlled copy in their possession.
Transmittals not signed and returned to Document Control within 14 days are flagged to the Document Control Supervisor for disposition.
A reminder is forwarded to holders of deliquent transmittals for action. The followup would have identified the fact that copies of FNP-0-AP-14 had not been updated.
Temporary change 4A to FNP-2-ECP-0.0 and Revision 4 to ENP-1-ECP-0.0 l
E.
were transmitted to holders on February 9, 1988. Transmittals for the copies in question were signed acknowledging receipt on February 10, 1988 and returned to Document Control. When the inspector audited the files, the changes had not bcen incorporated into the controlled copies.
F.
Revision 7 to FNP-2-ARP-1.2 was transmitted to holders of controlled copies on February 15, 1988. The transmittal for the copy in question was signed acknowledging receipt on February 15', 1988 and retu med to Document Control. When the inspector audited the files, the copies had not been incorporated into the controlled copy.
I U. S. Nuclear Regulatory Commission June 15, 1988 Page 5 G.
Revisions to drawings are provided to FNP in three forms: Mylars, 35mm aperture cards, and laminated prints for operation's critical drawings. The Mylar of Revision 21 to D-200007 was received by Document Control on February 10, 1988 and blueline copies transmitted to holders of control:ed copies on February 10, 1988. The laminated print was transmitted to Docunent Control from Southern Company Services on February 4,1988 but was not received by the plant.
When the inspector audited the files, it was determined that the laminated print of D-200007 was Revision 20. The laminated print contained all the proper postings of outstanding PCN's as required by procedure.
Reason for Violation 1.
The first part of this violation was caured by personnel error in that maintenance personnel failed to sign off designated checkpoints properly.
A contributing factor was procedural deficiencies.
2.
The second part of this violation was caused by personnel error in that personnel failed to incorporate approved changes into controlled documents.
Corrective Action Taken and Results Achieved 1.
Maintenance personnel were trained on proper methods of inspection and procedural compliance. The applicable procedures were changed to eliminate the problem areas.
2.
The document deficiencies were promptly corrected and activities that could have been affected by these documents were reviewed. No adverse conditions were found.
Corrective Steps To Avoid Further Violations 1.
Electrical and Mechanical Maintenance personnel are being retrained each year on certain plant procedures which include the requirements of FNP-0-AP-15, attention to detail, and procedural adherence.
Instrumenta-tion and Controls (I&C) personnel receive annual training on inspection and signoff requirements, attention to detail, and procedural adherence per FNP-0-AP-51.
Farley Nuclear Plant is in the process of revising all Electrical, Mechanical and I&C maintenance procedures in accordance with the new Writers Guide for Maintenance Procedures, FNP-0-M-64.
This writers guide gives instructions on how to specify quality control inspections and establishes a consistent designated checkpoint format for all three maintenance groups.
2.
Individuals responsible for controlled copy files will be reinstructed in proper performance of their duties. Additionally, a transmittal receipt acknowledgement system will be implemented for controlled
U. S. Nuclear Regulatory Commission June 15, 1988 Page 6 drawings received from offsite sources.
Date of Full Compliance All corrective steps except revision of all Electrical, Mechanical and I & C maintenance procedures will be completed by November 1, 1988. Revision of all maintenance procedures will be completed by June 1, 1990.
Affirmation I affirm that th,is 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 very r ly,
)D p
W. G. Hairston, III
/g WGH:emb cc:
Mr. L. B. Long Dr. J. N. Grace Mr. E. A. Reeves Mr. W. H. Bradford