ML20212Q033
| ML20212Q033 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 08/14/1986 |
| From: | Mcdonald R ALABAMA POWER CO. |
| To: | Verrelli D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NT-86-0374, NT-86-374, NUDOCS 8609030378 | |
| Download: ML20212Q033 (4) | |
Text
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NT 86-0374 teiling Address Altbama Powir Compsny
- 600 North 18th Street
? \\,. h Post othee Box 2641 Birmingham, Alabarna 35291 Telephone 205 783-6C90 R. P. Mcdonald Senior Vice President Flintridge Building AlabamaPbwer 1% soutrementr:c sas:cm August 14, 1986 Docket No. 50-348 Docket No. 50-364 Mr. D. M. Verrelli U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W.
Suite 3100 Atlanta, Georgia 30323
SUBJECT:
J. M. Farley Nuclear. Plant NRC Inspection of April 11 - May 10 and June 3, 1986 RE:
Report Number 50-348/86-10 Report Number 50-364/86-10
Dear Mr. Verrelli:
h is letter refers to the violations cited in the subject inspection reports which state:
"During the Nuclear Regulatory Comission (NRC) inspection conducted on April 11 - May 10 and June 3, 1986, violations of NRC requirements were identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcament Actions," 10 CFR Part 2, Appendix C (1986), the violations are listed below:
I.A.
TS 3.5.2.d required in Modes 1, 2, and 3 two operable independent Emergency Core Cooling System (ECCS) subsystems with each subsystem having capability to transfer suction to the containment sump during the recirculation phase of operation.
It further requires that with one ECCS subsystem inoperable, restore the inoperable subsystem to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Contrary to the above, from 10:00 a.m. on April 25, 1986 to 9:45 a.m. on April 29, 1986, a period of approximately 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />, with the plant in Mode 1, Unit 1 ECCS subsystem "B" Train RHR pump suction was not capable of being transferred to the containment sump. %e inoperable subsystem was not restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, and the unit was not placed in hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> or hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
8609030378 860814 PDR ADOCK 05000348 G
PDR g ol'D
Mr. D. M. Virrelli August 14, 1986 Page 2 B.
TS 6.8.1 requires that applicable written procedures recomunended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, 1978 shall be established, implemented, and maintained. RG 1.33, Appendix A, Section 9.2, requires that maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
Administrative Procedure (AP) 14, " Safety Clearance and Tagging,"
Section 6.1.2.3 requires that the Unit Shift Supervisor review tagging' orders and signify his review and approval. These orders shall be executed by the Designated Operator in accordance with AP-14, Section 6.1.3.2.
AP-16, " Conduct of Operations - Operations Group," Section 4.2 states that a proper shift relief includes informing control room personnel of the status of the plant. AP-16, Appendix B, requires that annunciators, indicators, switch positions, and position indicator lamps shall be observed for correctness and off-normt1 conditions and shall be discussed with the off-going operator.
Contrary to the above, on April 25, 1986, a Shift Foreman Inspector (SFI) who was not the Designated Operator attempted to rehang a tag on Unit 2's motor operated valve (MOV) 8811-B's breaker FV-B5.
%e SFI mistakenly hung the tag on the Unit 1 MOV 8811-B's breaker EV-B5, noticed the breaker was not open as the tag indicated, opened the breaker without proper tagging orders, and rendered certain functions of the Unit 1 Emergency Core Cooling System's (ECCS) subsystem inoperable. In addition, from April 25, 1986 at 10 a.m. until April 29, 1986 at 9:45 a.m.,
during whien time J2 shift reliefs occurred, Unit 1 control room personnel ~did not observe the absence of indicating lights for Mov 8811-3 during shift change walkdowns.
his is a Severity Level III problem (Supplement I).
II.
TS 3.7.12 requires that all fire barrier penetrations in the fire zone boundaries protecting safety-related areas shall be functional. With one or more fire barriers inoperable, a continuous fire watch shall be established or the operability of fira detectors on at least one side of the barrier shall be verified and an hourly fire watch patrol initiated.
Coatrary to the above, on April 29, 1986, at 9:30 a.m., fire door No. 2406, the Hot Machine Shop entrance to Unit 2, was found blocked open by a rubber hose without a continuous fire watch posted nor was the operability of fire detectors on at least one side of the door verified operable or an hourly fire watch patrol initiated.
This is a Severity Level IV violation (Supplement I)."
l 1
F' Mr. D. M. V;rrolli August 14, 1986 Page 3 Admission or Denial
%e above violations occurred as described in the subject report.
Reason for Violation he above violations were caused by personnel error.
Corrective Action Taken and Results Achieved 1)
The hold tag was removed and the Unit 1 breaker was closed at 1017 on 4-29-86 returning the train to operable status. The hold tag was replaced on the Unit 2 breaker at 1055 on 4-29-86.
2)
The hose was removed from the fire door.
Corrective Steps Taken to Avoid Further Violations 1)
To prevent recurrence of this event, the SFI who mispositioned the breaker was disciplined for negligent performance of duties which were in direct violation of plant procedures. A documented formal comunication was made to all operations Department personnel and all licensed personnel detailing this event, listing conclusions and lessons learned and specifying actions to be performed by each person in order to preclude such mistakes. A formal comunication was made to all plant personnel discussing this event and a group of other recent events involving personnel errors. The comunication emphasized the need for increased awareness and proper attention in the performance of their jobs. Main control board verification procedures have been developed and implemented to facilitate rapid and reliable detection of such errors. The identity of Unit 1 and Unit 2 entrances has been enhanced by color coding and prominent labeling with the unit numbers.
2)
The individuals involved in this event have been counseled.
Mechanical maintenance personnel will be retrained on the procedural require m nts when disabling fire doors.
Date of Full Compliance 1)
May 28, 1986 2)
September 1, 1986
Mr. D. M. V;rr2111 August 14, 1986 Page 4 In addition, the NRC inspection report letter states, "We note that you have issued several incident reports and licensee event reports in 1985 and 1986 involving work on the wrong unit or wrong train, safety-related tagging errors, and work order errors, and we are concerned that this situation has developed in such a way that significant Technical Specification violation occurred. Consequently, 1
your response should describe those particular actions taken or planned for i g roving your performance in this area."
Actions which have been taken by FNP to i g rove performance in this area incluaes:
1)
Each employee performance appraisal includes a specific appraisal of the employee's professionalism in the use of plans and i
procedures. Each employee formally reviews written appraisal.
%usly, the importance of properly utilizing pl.'_ns and procedures to avoid errors is personally emphasized to each employee at least annually.
( mid was initiated to be effective no later than January 1, 1986.)
2)
Performance monitoring has been developed and placed in use to trend items such as inadvertent inoperability of safety featurer and un-planned actuations of safety systems. We monitoring is designed such that deficiencies in planning, procedures and personnel errors are linked with resultant plant performance in order that appropriate and timely corrective action can be initiated and/or evaluated.
(his was initiated in February 1986.)
3)
Each docu:aented incident involving personnel error is investigated individually. corrective action is tar.en in eeh case at required.
his corrective action includes counseling 3r retraining Gie appropriate individuals and changing the appropriate procedures.
(his has been in effect for longer than one year.)
Affirmation I affirm that this response is true and complete to the best of my knowledge, info m tion, and belief. %e information contained in this letter is not considered to be of a proprietary nature.
Yours very t b
R. P. Mcdonald RPM:emb
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