ML20209C647

Responds to Violations Noted in Insp Rept 50-348/86-29 on 861211-870110.Corrective Actions:Automatic Isolation Capability of RHR Sys Restored to Fully Operable Status on 861120

ML20209C647
Person / Time
Site:	Farley
Issue date:	04/23/1987
From:	Mcdonald R ALABAMA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NT-87-0179, NT-87-179, NUDOCS 8704290038
Download: ML20209C647 (5)

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NT 87.0179 600 North 18th Street o

Post Offr a Bo a 2641 8

Dirmingham Alabama 3 2'J10400 reicpnone 20s 2so Inn L

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Alabama Power

n., w,n,,, u mnm April 23, 1987 U. S. Nucioar Regulatory Comission Attention: Document Control Desk Washington, D. C. 20555

SUBJECT:

J. ti. Farley Nuclear Plant NRC Inspection of December 11, 1986 - January 10, 1907 RE:

Report Number 50-340/06-29

Dear Sir:

This letter refers to the violations cited in the subject inspection report which statoss l

"During the Nuclear Itogulatory Comission (NRC) inspection conducted on December 11, 1906 - January 10, 1907, violations of tmC requirements weto identified. %o violations involved procedural and Technical Specification violations which wore identified by tio licensco and reported to the imC.

In accordance with the "Goneral Statomont of Policy and Proceduto for imC Enforcement Actions," 10 CFR Part 2, Apgwndix C (1906), the violations are listed below:

A.

Technical Specification 6.0.1.a requires that proceduros bo established, implomonted, and maintained covering the activition referenced in Ap[mndix "A" of Regulatory Guido 1.33, Revision 2, 1970.

Section 1 of Poguintory Guido 1.33, Apgmndix "A", Revision 2, 1070, requires that administrativo procedutos bo established for equigenent control.

1.

Administrativo Proceduto AP-52, Equipment Status Control and liaintenanco Authorization, requires that work bo performed in accordanco with the speciflod work sequence on the itaintenance Work Hornost (tM1) and that any changes to the iMt must im reviewed anc approved by the group supervisor.

Contrary to the above, on Octoler 13, 1906, technicians ottonoounly installed electrient ju.ngmts on the Posidual llont itemoval System inolation circuitry that was not in accordanco with the s[mcified work sequence on the iMits.

This chango in the IM1 work r,cquenco was not reviewod arkt approved by the group supervicor.

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U. S. Nuclear Regulatory Commission April 23, 1987 Page 2 l

2.

Administrative Procedure AP-31, Quality Control Measures, requires that the first line supervisor (foreman) have the primary responsibility for controlling the quality of work being performed by those over whom he has supervisory re-sponsiaility.

It also requires the group supervisor to have the primary responsibility for identifying problems of quality within his area of responsibility, for taking appropriate immediate corrective action for correcting quality problems, and for taking further corrective action to eliminate or reduce the probability of recurrence.

Contrary to the above, on Octotar 13 and 30, 1986, the foreman and group supervisor responsible for activities of work related to MWRs 141322, 141323, and 141324 failed to control the quality of work performed, to identify a problem of quality (the improper installation of the jumpers on the Residual Heat Removal System isolation circuitry), and to take appropriate correctivo action to correct the problem.

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

D.

Technical Specification 3.5.3 requires one Emergency Core cooling System (ECCS) subsystem to bo operable while the Unit is in Mode 4.

Action Statement a of this Technical Specification states that if no ECCS subsystem is operable because of the inoperability of either the centrifugal charging pump or the flow path from the refueling water storage tank, the licensee is required to restore at least one ECCS subsystem to operable status within one hour or be in Cold shutdown withln the next 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> if at least one Residual lleat Removal loop is operable.

Technical Specification 3.5.2 requires two independent ECCS subsystems to be operaale while the Unit is in Modos 1, 2, or 3.

Technical Specification 3.0.3 requires that when a Limiting Conditions, for Operation (LCO) is not mot, except as provided in Action requirements, that within one hour action shall bo initiated to place the unit in a Modo in which the sp elfication does not apply by placing it, as applicable, in at least llot Standby within the next six 1eurs, at least llot Shutdown within the following six hours, and at least Cold Shutdown within the subsequent twenty-four hours.

Technical Specification 3.0.4 prohibits entry into an operational Modo unless the conditions of the LCOs are mot without the reliance on provisions contained in the Action requirements.

contrary to the above, at 4:40 p.m. on November 17, 1986, the unit oporating mode was changed from Modo 5 to 4 whilo dependent upon l

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U.S.NuclearRehlatoryCommission April 23, 1987 Page 3 Action Statement a of Technical Specification 3.5.3, and at 11:44 p.m.

on November 18, 1986 the unit was changed to Mode 3 while both ECCS subsystem flow paths were not operable. 'Ihe Residual Heat Removal System loop suction valve's automatic isolation feature was defeated by electrical jumpers. On November 17, 1986, action was not taken l

to replace one ECCS subsystem to operability within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or to place the unit in Cold shutdown within the next 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />. From November I

18 to 3:42 a.m. on November 20, 1986, action was not taken to place l

the unit in a mode in which Specification 3.5.2 did not apply.

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

Admission or Denial The above violations occurred as described in the subject report with the following exceptions:

The Notice of Violations states that Action Statement a of technical Specification 3.5.3 was violated. Action Statement a refers to inoperability of the chargin pump or the flowpath from the refueling water storage tank; this equ pment was operable. Action Statement b of Technical Specification 3.5., which refers to the Residual Heat Removal (RHR) system, is the applicable statement.

Further the ECCS subsystem for Mode 4 was fully capable of its emergency core cooling function being technically inoperable only because the auto-isolation feature was inoperable. Mode 4 was entered from Mode 5 at 4:40 p.m. on November 17, 1986 thereby exceeding Technical Specification 3.0.4.

Once Mode 4 was entered the applicable action statement of specification 3.5.3 part b, was met. Technical Specification 3.0.4 was again exceeded when at 11:44 p.m. on November 18, 1986 the unit's mode was changed from Mode 4 to Mode 3 with both ECCS subsystems technically inoperable because the automatic isolation ca ability was inoperable. The ECCS capability was i

i not actually affected and aoth trains were fully capable of fulfilling l

their emergency function. Then after entering Mode 3, Technical Specification 3.0.3 was not met. On November 18, not November 17, action was not taken to restore one ECCS subsystem to operable status within the allowable time restraints imposed by the Technical Specifications. The unit remained in Mode 3 for 27 hours3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br /> and 50 minutes and hence under Technical Specification 3.0.3 for that length of time. Once Mode 4 was again entered on November 20, 1906 at 3:42 a.m., Technical Specification 3.0.3 was no longer offective and the unit again fell under Technical S p0*r. This action statement was met.elfication 3.5.3 action b, which prohibited heat 3a Roanon for Violati_ons A.

This violation was caused by personnel error in that the personnel who 1

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U. S. Nuclear Regulatory Comission April 23, 1987 Page 4 defeated the automatic isolation capability performed work outside the planning of the Maintenance Work Requests (MWRs) without having the MWRs replanned or providing adequate documentation. Therefore, no formal mechanism was intact to ensure that the system was fully restored and operable.

Technical Specifications were unknowingly violated because o p rations B.

esonnel were not c y izant of the automatic isolation capability ing inoperable until 11-20-86 at 1421.

Corrective Action Taken and Results Achieved A.

None required.

B.

At 1648 on 11-20-06, the automatic isolation capbility of the Residual Heat Removal System was restored to fully operable status.

Corrective Steps Taken to Avoid rurther Violations A.

1) Instrumentation and Controls (I&C) personnel have been reinstructed to have the MWR work sequence changed and approved when the scope of the planning is to be exceeded.

2)

I&C Foremen have been reinstructed to verify that the work performed is documented. They will also be reinstructed to investigate questionable events such as undocumented jumpers. The I&C Supervisor has been reinstructed on his responsibility for quality por FNP-O-AP-31.

In addition, the procedure for voiding official Test copies will be revised.

B.

Procedures will be modified to require an ins p ction of the Solid State Protection System for jumpers following refueling outages prior to entering Mode 4.

Date of rull Compliance A.

May 30, 1987 B.

May 1, 1987 Affir_mation I affirm that this response is true and complete to the best of my knowledge, information, and belief. The information contained in this

l U. S. Nuclear Regulatory Commission April 23, 1987 Page 5 f

letter is not considered to be of a proprietary nature.

Yours very trul,,

27's ' s :'

R. P. Mcdonald RPM:emb cc: Mr. L. B. Long Dr. J. N. Grace Mr. E. A. Reeves Mr. W. H. Bradford i

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