ML20199F569
| ML20199F569 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 11/14/1997 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-348-97-09, 50-348-97-9, 50-364-97-09, 50-364-97-9, NUDOCS 9711240266 | |
| Download: ML20199F569 (4) | |
Text
' Dave Morey Southern Nuclear Vice Pr;Udent Operating Company Farley Proy;ct P0. Box 1295-Baminghant Alabarna 35201 Tel 205 992.513i SOUTHERN h COMPANY Novanber 14, 1997 Ernerg ro Scrve Your%rld" Docket Nos.: '50 348 10 CFR 2.201 50 364 U.S. Nuclear Regulatory Commission ATrN: Document Control Desk Washington, DC - 20555 Joseph M. Farley Neclear Plant Reply To a Notice Of Violation (VIO)
NB.C. _Irincetion Report Number 50-348.364/97-09 Ladies and Gentlemen:
As icquested by your transmittal dated October 20,1997, this letter responds to VIO 50-348, 364/97-09 01," Failure to Demonstrate Performance of 22 Maintenance Rule Scoped Systems."
He Southem Nuclear Operating Company (SNC) response is provided in the enclosure.
Respectfully submitted, gy'Yl
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Dave Morey WAS/ cit; nov97091. doc Enclosure cc:
Mr. L A. Reyes, Region 11 Administrator Mr. J.1. Zimmerman, NRR Project Manager Mr. T. M. Ross, Plant Sr. Resident inspector
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ENCLOSURE Response to VIO 50 348,364/97-09-01 "failVKja.Dr0Eulfale Perforrlaticraf_223]airitcDancs_BDlg.SIcecdEnjana" l
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RESPONSE TO VIO 50 348,364/97-09-01 VIO 50-348,364/97-09 01," Failure to Demonstrate Performance of 22 Maintenance Rule Scoped Systems" states:
10 CFR 50.65(a)(1) requires, in part, the holders of an operating beense shall monitor the performance or condition of stsuctures, systems and components (SSCs), as defined by 10 CFR 50.65(b), against licensee-established oals, in a manner suflicieat to provide s
reasonable assurance that such SSCs are capable of fulfilling their intended ftmetions.
When the performance or condition of a SSCs does not meet established goals, appropriate corrective action shall be taken.
10 CFR 50.65(a)(2):equires, in part, that monitoring as 3pecified in 10 CFR 50.6S(a)(1) is not required where it has been demonstrated that the performance or condition of an SSC is being effectively controlled through the performance of appropiiate preventive maintenance, such that the SSC remains capable of performing its intended function.
Contrary to the above 10 CFR 50 65(a)(2) was not adequately iraplemented, i t that:
- 1. From July 10,1996, the time that the licensee elected to not monitor the performance or condition of 15 high safety significaat SSCs within the scope of 10 CFR 50.65 against licensee established goals pursuant to requirements of Section (a) (1), to June 13,1997, the licensee had not demonstrated that the per6rmance of the 15 SSCs had been efTectively controlled through the pe formance of argropriate preventive niaintenance.
Speci0cally the licensee failed to establish availability performance measures for the 15 high safety significant SSCs as the means to demonstrate that the performance or condition of the SSCs was being effectively controlled through the performance of appropriate preventive maintenance.
- 2. On June 13, 1497, fbr each of the 15 SSCs (in paragraph 1, above) and seven other SSCs, the licensee established an availability preventive maintenance measure to demonstrate that the performance or condition of the 22 SSCs was being elTectively controlled through the conduct of appropriate preventive maintenance such that they remained capable of perfbrming their intended function.
Ilowever, as of September 12, 1997, the licensee had not implemented these measures and thus had failed to demonstrate that the performance or condition of the 22 SSCs was being effectively controlled such that they remained capable of performing their intended ftmetion pursuant to the requirements of 10 CFit 50.65(a)(2)
This is a Severity Level IV violation (Supptement 1)
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HESPONSE TO VIO 50-348,364/97 09-01 Admission or Denial The violation occurred as described in the Notice of Violation.
Menson for Violation i
Personnel error in that the original scoping did not adequately interpret the requirements of 10CFR$0.65(b) and failed to include all required SSCs.
Implementation of the new SSCs was not timely due to personnel error. Additionally, the v
implementation procedure lacked guidance on the time frame to complete program updates.
I This allowed personnel to incorrectly assign a lower priority to the historical review and tracking requirements.
Corrective Steps Taken and Results Achieved I. The 22 SSCs were added to the Maintenance Rule scopc on June 13,1997.
- 2. The 3 year historical data review and Al vs. A2 determination will be completed for the new SSCs added to scope.
- 3. Farley Nuclear Plant (FNP) site procedure " Guidelines for Scheduling of On Line Maintenance" has been revised to include required SSCs for availability tracking, to specify tracking methods, and to include the speciFn fe:tions from the FNP site procedure " Performance Criteiin for Systems Under the Scope of the Maintenance Rule".
- 4. Avsilability tracking on the new SSCs has been implemented.
Corrective Stens That Will He Taken to Avoid Further Violation
- 1. FNP site procedure "FNP Maintenance Rule Site Implementation Manual" has been revised to clearly derme the program update process and specify a time frame of 60 days for determination of Al vs. A2 aller adding SSCs to the Maintenance Ru% scope. This Manual was also revised to ensure that following the revision of the implanenting 4
procedure for availability tracking (FNP site procedure " Guidelines for Scheduling of On-Line Maintenance"), the subsequent tracking will be verified to accurately reflect the changes made.
- 2. ?ctsonnelinvolved with impiementing the Maintenance Rule program have been instructed on ;5e necessity of proper scoping determinations, and timely and thorough incorporations of changes to the Maintenance Rule scope.
Date of Full Compliance January 10,1998 E2
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