ML20197B500

Responds to NRC Re Violations Noted in Insp Repts 50-348/97-11 & 50-364/97-11.Corrective Actions:Plant Procedures Have Been Written Which Will Test V002 D,F & H in Reverse Direction

ML20197B500
Person / Time
Site:	Farley
Issue date:	12/17/1997
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-348-97-11, 50-364-97-11, NUDOCS 9712230394
Download: ML20197B500 (20)

Text

' Siuthera Nuclear Dave Morey W

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Birmi'gham A!abama 35201 Tel 205 992.5131 ---

c SOUTHE.RN co Energy to Serve YourWorld" Deceniber 17,1997 10 CFR 2.201 Docket Numbess: 50-348 50-364 U. S. Nuclear Regalatory Commission ATTN: Docur,ent Control Desk -

Washington, DC 20555 -

Joseph M. Farley Nuclear Plant Reply To a Notice Of Violation NRC lataerrued lawi= R_aanrt Numhars 50-348.364/97-11 Ladies and Gentlemen:

As rorwd by your transmit *al dated Novanber 17,1997, this later responds to the Notice of Violat, smaacimaad with NRC integrated Inspection Report Numbers 50-348,364/97-11. '!his letter addresses vialatiana (VIOs) 50-348,364/97-11 02 through 50 348,364/97-11-07.

The Southern Nuclear Operstmg Company (SNC) responses arc provided in six enclosures.

Enclosures 1 through 6 include the responses to VIOs 97-11-02 through -07 mspectively.

While your inspection report identified areas for improvemem, we are encouraged by t!e following:

Our Wety system self-ass usment prognun is a positive initiative.

Cur engmeering staff demonstrated adequate knowledge of the systems examined.

• - Our conclusions with your confirmation that the two systems myiewed are capable of performing their intended function and have adequate design margins.

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Our configuration control processes, self-assessment program, wxt our knowledgeable engineering

- staff, combined with the miniraal safety significance of the violaticas, demonstrate that we have the necessary controls, programs and persrael to ensure a high level of safety,

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U. S. Nuclear Regulatory Commission Page 2 -

Should you have any g#

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PMlly submitted, SOUmERN NUCLEAR OPERATING COMPMtY -

93 7 Dave Morey 4

GCW/dtc:nov97-Il

Enclosures:

1. P m to VIO 9711-02

.2.- Respoese to VIO 97-11-03

- 3. Responsa to YlO 91-11-04

4. Response to VIO 97-1105

5. Response to VIO 971106 6.- Response to VIO 9711-07 cc:

Mr. L. A. Reyes, Region 11 M=iaierator Mr. J.1. Zirnmerman, NRR Project Manager -

Mr. T. M. Ross, Plant Smior Resident Inspector P

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ENCLOSURE 1"

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VIO S0-348,364/9711.

FAILURE TO PERFORM ADEQUATE 1ST OF TDAFW CHECK VALVES ON CESSATION OR REVERSAL OF FLOW 4'

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ENCLOSURE 1 VIO 50 348,364/9711-02," Failure to Perform Adequate IST ofTDAFW Check Valves on Cessation or Reversal of Flow," states the following:

Technical Specification Section 4.0.5 requires insenice testing of American Society of Mechanical Engineers (ASME) Code Classes 1, 2, and 3 pumps and valves in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda

%c licensee is committed to insenice testmg in accordance with the 1983 Edition of the Code and Summer 1983 Addenda Section XI, Subsection IWV-3522 of the ASME Boiler and Pressure Vessel Code requires valves whose function is to prevent reverse tiow to be tested in a manner that praves that the disk travels to the seat promptly on cessation or reversal of flow.

Contrary to the above, neither the turbine-driven auxiliary feedwster pump discharge check valve V003 nor check valves V002D, F, and 11, were revern flow tested in a manner that proves that the disk tr.wels to the seat on cessation or reversal of flow. Either check valve V003 or check valves V002D, F, and H were required to perform a safety function in the closed position.

This is a severity level !V siolation.

Admission or Denial The violation occurrai as described in the Noti of Viola 9m.

Reason for Violation he cause of the adverse condition was personnel error in that the those individuals responsible for scoping made an incorrect assumption and interpretation of the ASME Code.

Corrective Steos Taken and Results Achieved 1.

A review of oth:r Suntillance Test Procedures showed that V003 was operable based on the results of the forward flow testing of the MDAFW check valves. Also, V003 on Units 1 and 2 were disassembled and inspected with seisfactory results.

2.

Plant procedures have been written which will test V002 D, F & H in the reverse direction. The Insenice Test Plans for Unit I and Unit 2 have been revisec* to include the reverse flow testing.

3.

• Ib Unit I test per the new Unit I procedure was completed satisfactorily during the 14th Refueling Outage. The Unit 2 test per the new Unit 2 procedure will be performed during the Unit 2,12th Refueling Outage in the spring of 1998.

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- ENCLOSURE 1

. Correctiw.Sigy That Will Be T=L-To Avoid Further Violation Personnel involved with IST scoping decisions haw been trained as to the nood for accuracy and compicscoess required for IST scoping.

Date of Full CamaH== -

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ENCLOStmE 2.

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~ VIO 50-348,364/9711-03 :

-- TDAFW BATTERY INSTAT LA110N AND CHECK' VALVE TEST DEFICIENCIES P

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ENCLOSURE 2 VIO 50-348 364/97-1103, 'TDAFW Battery Installation and Check Valve Test Deficiencies," states the 4

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10 CFR Part 50, Appendix B, Critenon V, Instrtetions, Procedures, and Drawings, states, in part, that activities affecting quality be prescribed by and performed in accordance with instrucaiane, procedures or drawings which include appropriate acceptance critoria for _

detennining the activity is satisfactorily accomplished.

3 Contraty to the above, as of March 14,1997, the following were identifuxi-1.

'Ihe Unit 2 Turbine Driven Auxiliary Foodwater (TDAFW) pump battery structural and electrical component installations were not installed in accordance with drawings and instructions (7597 20-E10.9 29, Revision 1, U265645A, Revision 2, and U263212, Revision D).

I 2.

The surveillance procedure for verifying the forward flow for chock valve V003 did not provide appropriate rce criteria for determining that the activity was satisfactorily accomplished. Specifically, the acceptance criterion of 625 l

gallons per minute (gpm) full design flow specified for TDAFW pump check valve V003 in Surveillance Test Procedure (STP) FNP-1(2)-STP-22.13 was incorrect,

- because the acceptance criterion did not consider the flow through the minimum flow line.

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'This is a Severity Level IV Violatior..

Adnii==h or Denini

'Ihe violation occurred as described in the Notice of Violation.

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Reason for Violation i

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The reason for this violation was personnel error in that the TDAFW pump battery structural and l

electrical can,-*= were not installed in accordance with approved drawings and instructions.

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- The reason for this violation was personnel error in that the individual writing the surveillance test proceduru selected a wrong point to measure discharge flow.

Conective Stens Taken and Results Achieved 1.

- Differences between the actual installation and design drawings were evaluated. 'Ihe evaluation concluded that the battery rack and the installed batteries will perform properly under seismic conditions.

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ENCLOSURE 2 2.

A re /iew of previously performed surveillance tests showed that the discharge check valve exceeded its minimum flow requirements and therefore was acceptable. Surveillance Test Procedures for forward flow testing were revised to incorporate the proper flow measuring point and therefore provide correct acceptance criteria for Ql/2N23V003. nc Unit I procedure was completed satisfactorily during the last refueling outage. The Unit 2 procedure will be perfonned during the upcoming Unit 2,12th Refueling Outage in the spring of 1998.

Corredive Steos Rat Will Be Taken To Avoid Further Violation -

1.1 To maintain proper configuration control, the Unit 2 TDAFW Battery rack and the design drawing,s will be made to gre by the end of the Unit 2 outage in the spring of 1998.

1.2 Individuals responsible for plant modifications v.ill be informed as to the necessity of assuring that field installations and drawings agree.

1.3 Other safety related battery installations will be inspected tc, assure that the ficid installation matches the design drawings.

2.0 Fersonnel involved with J ST procedure development have been informed as to the need for accuracy and completeness required for IST procedure content.

Date of Full Comoliance June 15,1998 l

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ENCLOSURE 3 7

VIO 50-348,364/971104 FAILURE TO IMPLEMENT A TEST PROGRAM FOR SERVICE TESTING OF THE TDAFW BATTERY E3-1

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$ VIO 50-348,364/97 Il-04,." Failure to implement a Test Program for Service Testing of the TDAFW sattery," statee the folkwing.

'10 CFR Part 50, Appandix B, Criterion XI, Test Controls,~ states,'in part,- that a test.

program shall be establinhad to ensure that all testag required to demonstrate structures, systems,'and ec..peren will perform ' satisfactory is identified and perfwmed-in awd r.cc with written test procedures Technical Speci6 cation 6.8.1.s requires that applicable wntien procedures rex =;=-N in Appendix A of Regal Wy Guide 1.33, Rwision 2,~ 1978, shall be established, impicmmted and : =Wai=~i Appendix A, Section - 8.b of Regulatory Guide - 1.33 iw---- =.ds surveillance test procedures for the Auxiliary Feedwater System Contrary to the above, as of March 14, 1997, no. surveillance test' procedures were established for the turbine-driven auxiliary feedwater pump Class IE battery to ensure tint c

the battery will perform satisfactorily !n senice to the required battery duty cycle in accedance with dt. sign br. is requirements.

This is a Severity Level IV Violation (Supplement I).

Adnussion or Denial j

The violation c:cu red in that an 18 month interval service test was not performed However, the following maintenance, inspectons and testa were performed on these batteries which demonstrates their adequacy:

1. Weekly battery inspection

2. Quarterlybatteryinspection

3. Yearly battery equalization 4.18 month general battery cleaning

5. 54 month UPS battery performance test Reason for Violation Personnel error in that the scope of testmg established for the TDAFW batteries did not include a service test.

corre.:tive Stens Ta6 =ad R~ nits k%ed s

- An==== ment oflack of service testin;; as a pr**ial degraded or non<onformmg condition was completedos April 17,.1997. 'Ih: results of the operability==== ment demonstrated that the TDAFW

UPS Bat'. cries are fully capable of performing their intended design funct on

? A Unit 1 Electrical Maintenance Procedure was issued and the first Unit I test has been completed isatisfrrtorily.

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ENCLOSURE 3 l -

A Unit 2 Elect;ical Maintmance Procedure has been written and is scheduled to be perfonged during the u,v.om ng Unit 2 outage in the Spring of 1998.

Corrutive Stens hat Will Be Taker. To Avoid Further Vialati9n

. %is evcnt will be discussed with applicable Maintenance staff personnel to ensure adequate testing is specified.

Date of Full CitDaliansa June 15,1998

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ENCLOSURE 4 VIO 50-348,364/9711-05 DESIGN CONTROL MEASURES DID NOT ENSURE THAT CALCULATIONS WERE VERIFIED AND CONTROLLED 9

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i VIO 50-348,364/97-11-05, " Design Control Measures did not Ensure that Calculabons Were Verified and Controlled," states'the following-10 CFR Part 50, Ap-N B, Criterion 111, Design Control, states, in part, that the design control measures shall provide for verifying or cwuas the adequacy of the design.;

L"'s Operations Quality Assurance Program, UFSAR 17.2.3.1, states that design control measures will comply with the requiranants of American National Standard Institute'(ANSI) N45.2.11 1974. It further states that the design control system shall include a method of adequately venfymg the deign.

Farley Support Procedure GO-M-1, " Designer laterface Document," Revision 3,

' states that calculations or analyses performed as a part of engmeenng support activities for FNP shall cor. form to the requirements of Section 4.2 of ANSI N45.2.ll-1974. In addition, procedure GO-M-1 states that existing calculations should be reviewed to determine if the calculation must be revised.

l ANSI N45.2.1I states that design analyses shall be' performed in a planned, controlled and correct manner. In addition, the design activities shall be prescribed

. and accomplished in accordance with procedu es which }srovides adequate cWhias or verifying the results of the activity.

Contrary to the above, on March 14,1997, 1.

The design control measures did not ensure that calculations or analyses were verified and controlled adequately to ensure original plant design basis documentation is maintained current and to prevent inappropriate use of the existing calculations for the followmg examples:

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Calculation 38.06, "Deternune flow rate through pipe break in CCW system," Revision 0, concerning the Component Cooling Water (CCW) surge tank low-low level setpoint, supersedes Calculation 35.5, " Evaluation of CCW Surge Tank Level hpaia*," Revision 0, yet Calculation 35.5 was shown as active -

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Calculation 34.5, " Component Coohng Water System NPSH (ES No. 90-1820)," Revision 0, was affected by Calculation 39.3, "CCW Surge Tank Analytical Limit for Level ScToint," Revision l

0, but Calculation 34.5 was not revised accordingly, c.

Calculation 25.3, "Over pressurization of AFW Piping During Overspeed Testag," Revision 0, determined that an unacceptable piping pressure could develop in the event of turbine overspeed of

= 125% of rated speed. 'This calculation was not revised to reflect the acceptable overspeed setpoint of 115% of rated speed nor was -

- a new calculation prepared to supersede Calculation 25.3 when design inadiEr=*iaa PCN B-88-1-5003, " Change 0,erspeed Trip

-Sett ng for TDAFW Pump," Revision I was implemer.tui.

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ENCLOSURE 4 d.

Calculation E-144, "Deternunation of Battery Capacity Margins for Adequacy of Voltage at Safety-Related Components for Various lead Profiles," Revision 2, reflected a new battery installation but calculation E-42, " Steady-State DG Loading Calculation for LOSP, Si and SBO," Revision 8, which used calculation E-144 as an input, was not revised accordingly.

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Calculation 40.02, " Verification of AFW Flow Bases," Revision 3 (Unit 1), and the equivalent calculation for Unit 2 (38.04) provide design-basis information for the AFW system; yet Calculation 35.04, " Auxiliary Feodwr.ter System Head Curves (ES 90-1831)," Revision 0, which provides similar information, was not referenced or revised to indicate that it did not contain design-basis information.

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Calculation SC-96-1211-002, "CCW heat Exchanger Maintenance Repairs," Revision 1, states that it is judged that the increase in weight resulting from tie CCW heat exchanger modifications will not affect the acceptability of the foundatioa anchorage's. However, the calculation for the anchorage's was not revised nor was the increase 5 heat exchanger weight reflected in the appropriate calculation.

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Design control measures were not properly implemented to verify or check the adequacy of the design basis differential pressures specified for CCW motor operated vr.hms (MOVs). Specifically, differential pressures identified in Design Basis Document, U418109, Revision A for CCW system contamment isolation valves MOV 3046,3052, and 3182 were non-conservative as the effect of post Loss of Coolant Accident (LOCA) contamment pressure was not considered.

This is a Severity Level IV Violation.

Admission or Denial The violation occurred as described in the Notice of Violadon.

Reason for Violation In the case of 1.a, the violation occurred due to procedural inadequacy in that Bechte.1 procedures did not require that superseded calculations be transmitted to QA record stora;.e.

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la the case of 1.b, the violation occurred due to personnel error in that personnel preparmg calculation 34.5 failed to obtain the necessary level of detail to verify that design inputs were appropriate and m*hed those of calculation 39.3.

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ENCLOSURE 4:

In the case of 1.c, the violation occurred due to personnel error in that personnel failed to incorporate the acceptability orlowering a setpoint, which was the result of a design change, into calculation 25.3, Since calculation 25.3 was conservative in that the overspeed condition was lowered from 125% to 115%, it was doesnod unnecessary to revise calculaton 25.3 as it is bounded by the new overspeed setpoint.

- In the case of Ld, the volation occurred dr.e to personnel error in that personnel failed to reference the changes from calculatim E144 vhis is used as input into c=bl=*a E42, even though revision 2 had no impact on the retuit 8 of calculation E-42. Therefore, a change to calculation E-42 to reflect a reference to calculat6.i E 144 revisioa 2 was deemed u-==ry.

4 In the case of 1.e, the violation occurred du to personnel error in that personnel failed to arumtate -

l calculation 35.04 in order to designate that it did not contain design basis information, in the case of 1.f, the violation occurred due to personnel error in that a judgment regarding an incremental weight increase of the CCW heat exchangers resulting from a design change wm not incorporated into calculation SC-%-1211002.

In the case of 2, the violation occurred due to personnel error in that non-conservative differential pressures were uad as input in the documentation ot':clected CCW MOVs. The differential pressures used did not consider a CCW line break irside containment caused by other high energy line breaks. ' It was deemed to be unlikely that such breaks would result in a consequential failure

- of these CCW lines. However, no formal evaluation was developed to docununt this position.

Corrective Steos Taken and Results Achieved I.a.

The calculation index was revised to show calculation 35.05 as superseded by calculation 38.06.

1.b l Calculation 34.5 was revb ed to incorporate a postulated pipe break that resulted in an.

additional 4 inches lower tank level as described in calculation 39.3. The calculation has also been revised to mference calculation 39.3.

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_ Calculation 25.3 was revised; however, to summarize the previously developed documentation used to evaluate the 115 percent overspeed condition.

1.d Calculation E-42 was revised to reference revision 2 of calculation E144.

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Calculaten 35.04 was revised to annotate it did not contain design basis infornation.-

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Calculation SC-96-1211-002 was revised Changes to re.ated documentation were submitted.

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MOV Design-Basis Document and related documentation were revised to include the more conservative differential pressures taking into account a line break coincident with post LOCA containment pressures.

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ENCLOSURE 4 The calculation index has been reviewed for accuracy to ensure superseded calculations are properly identifat in the index.

Corrective Steos That Will Be Taken To Aygid Furtler Violatifs Design personnel will be re-tramed in the proper use of the calculation index, the effect of cumulative changes, the use of calculation change notices and incorporation of consen ative assumptions.

Existing design basis calculations contamed in the index will be assessM by March 1,1998, in order to ot.tline a program which addresses the relationship between calculations. The program resulting from this outline will be implemented by December 31,1999.

Date of Full Comolianen December 31,1999 E4-5

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VIO 50-348,364/9711-06 INADEQUATE CORRECTIVE ACTION TO RESOLVE DIFFERENCES BETWEEN CCW SYSTEM P&ID'S AND OPERATING PROCEDURES E5-1 a

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ENCLOSURE 5 VIO 50-348,364/97-11-06, W *a Corrective Action To Resolve Differeaces Between CCW System

.? AIDS And Operatag Procedures," states the following:

10 CFR Part 50, Appendix B, Criterion XVI states that conditions adverse to quality such as malfvactionn and deviations be promptly identified and corrected Contrary to the above, as of March 14, 1997, the lionsee failed to promptly correct several differences between CCW system piping and mstrument drawings D-205002, -

Sheet 1, Revision' 21; Sheet 2, Revision 10; and Sheet 3, Revision 2 and standard operating procedures (SOPS) FNP-1(2)-SOP-23.0A, "Cn=& Cooling Wa:cr Systein,"

Revision 5, and FNP 2-SOP-2.lA, " Chemical and Volume Control System," Revision 8,-

concerning the exisence of caps on vents and drain lines. Differences between piping and

' instrumentation drawings (P&lDs) and procedures were previously xkrified in the licensee's CCW system self-assessment in 1990, but no corrective action was identified by the licensee.

This is a Severity I evel IV Violation.

Admineinn or Daaial The violation occurrod in that all identif.ed corrective actions were not implemented. However, appropriate corrective actions were identified.

Famana for Wlatina

%e cause of this adverse condition is personnel error in that plant personnel failed to revise procedures affected by the As Built Noti 5 cation (ABN) issued in response to the drawing discrepancies.

Corrective Steos Taken and Results Achieved Unit I and Unit 2 CCW system P&lDs have been revised to show appropriate vents and drams capped.

De system operating procedure valve checklists which include the CCW valves were updated to match the drawings and a field verification of the accessible valves was performed after the syim:m operating procedures were implemented.-

Corrective Stens nat Will Be Taken To Avoid Further Violation Operations' personnel responsible for the review of design changes for impact on plant procedures have been informed of this event.

l Date of Full Comoliance l'-y= +-d 12,' 1997 E5-2

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VIO 50 348,364/97-1107

' AUXILIARY BUILDING BATTERY SURVEILLANCE TEST CRITERIA INCONSISTENTWITH TS 4

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ENCLOSURE 6 VIO 50-348,364/97 13-07, " Auxiliary Building Battery Surveillance Test Criteria Inconsistent With TS,

states *.he following-10 CFR 50.36(c)(3), Technical Specifrathe, Surveillance Requirements, states, in part, that surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quahty of systems and cu..p.ts is maintained, and that limiting conditions for operation will be met.

Contrary to the above, as of March 14,1997, the Auxiliary Building, Dircu Current (DC)

Distribution technical specification (TS) surveillance requirement (4.8.2.3.2.C.5), battery capacity aAcr a service test, was ia-d~=* to ensure that limiting conditions for operation.

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' Specifically, the battery surveillance requirement specified in TS Section 4.8.2.3.2.c.5 was less conservative than the design voltages specified in calculation 07597-E144. Battery operation at the TS allowed voltage would not have met the design requirement for supplying adequate voltage for all safety-related components.

His is a Severity LevelIV violation Mmi.=6 or Dani=1 ne violation occurred as described in the Notice of Violation.

Reason for Violation De reason for this violation was personnel error in that a 50.59 screening had an inadequate review.- 1.

was incorrectly concluded that the change to the design basis was not a change to Technical Specifications.

Corrective Steos Taken and Results Achieved Technical Specification changes have been drafted for submittal to the NRC by January 31,1997.

~ Corrective Steos hat Will Be Taken To Avoid Further Violatiqn Design Organizations within Southern Company Senices and Bechtel along with individuals at FNP qualified to perform 50.59 cvaluations will be given the details of this violation Emphasis will be given to perform %* reviews during 50.59 screenmgs.

Date of Full ComoliaDGG December 31,- 1998 assuming NRC approval by this date.

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