ML20235Q662
| ML20235Q662 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 09/29/1987 |
| From: | Mcdonald R ALABAMA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NT-87-0418, NT-87-418, NUDOCS 8710070660 | |
| Download: ML20235Q662 (3) | |
Text
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NI 87 0418 Alabama Power Company 600 North 18th Street
, Post Clffice Box 2641 Birmingham, Alabama 35291-0400 Telephono 205 250-1835 A
R. P. Mcdonald Alabama Power Senior Vice President the southem electnc system September 29, 1987 Docket No. 50-348 Docket No. 50-364 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555
SUBJECT:
J. M. Farley Nuclear Plant NRC Inspection of July 10 - August 18, 1987 RE:
Report Number 50-348/87-17 50-364/87-17
Dear Sir:
This letter refers to the violation cited in the subject inspection reports which state:
"During the Nuclear Regulatory Commission (NRC) inspection conducted July 10 through August 18, 1987, a violation of NRC requirements was identified.
The violation involved a failure to establish, implement and maintain procedures required by Technical Specification Section 6.8.1.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violation is listed below:
Technical Specification 6.8.1 requires that applicable written procedures recommended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, 1978 shall be established, implemented and maintained. The following are examples of this procedural violation.
1.
Amendment No. 62 to the Unit 2 Technical Specification, issued April 10, 1987, deleted Table 3.8-1, Containment Penetration Conductor Overcurrent Protective Devices, from the Technical Specifications. Technical Specification Bases Section 3/4.8.3 states that the tabulation of the required containment penetration conductor overcurrent protection devices are contained in plant procedures which are controlled in accordance with 10 CFR 50.59.
l Contrary to the above, as of July 27, 1987 procedures were l
not established and implemented for identification of the required containment penetration conductor overcurrent protective devices which are within the scope of Technical Specification bection 3.8.3.1.
8710070660 870929
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'U..S. Nuclear Regulatory Commission L
September 29, 1987 Page 2 2.
Procedure FNP-1-STP-33.08, Solid State Protection System Train B Operability Test, Section'4.5, states that all steps of this test must be completed in the prescribed sequence. Section 5.7.11 of this procedure requires that the reactor trip breaker and bypass breaker counter numbers l
be recorded in the reactor trip breaker surveillance test l
data book under the correct breaker serial number and verify the counter has increased since last data entry.
This data entry step is the next sequence following the operator's reading and recording of the cycle counter reading.
Contrary to the above, on July 24, 1987, while performing surveillance 1-STP-33.0B, the operator failed to follow the procedure sequence. The trip breaker and bypass trip breaker counter numbers were not entered into the surveillance test data book to verify that counter numbers had increased since last data entry until after completion of the procedure, i.e. following procedure step 5.7.16.
3.
Administrative Procedure No. 52, " Equipment Status Control and Maintenance Authorization", states in section 7.5.9 that proper test and restoration steps shall be completed prior to functional acceptance of the work request.
Contrary to the above, post maintenance testing was inadequate for functional acceptance of Maintenance Work Request (MWR) 111291 dated 7-11-85 in that a wiring error on 2C diesel generator control circuitry caused the 2C diesel generator to not have non-essential engine protection (NEEP) when aligned to 2B battery.
This is a Severity Level IV violation (Supplement I)."
Admission or Denial The above violation occurred as described in the subject reports.
Reason for Violation The above violation.was caused by:
1.
Personnel error in that the procedure tabulating the required containment penetration conductor overcurrent protection devices was not issued until July 30, 1987.
I 2.
Personnel error in that the plant operator failed to follow the procedure in the prescribed sequence.
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-[.U..S. Nuclear'RegulatoryCommission
-: September 29, 1987 Page.3.
3.
Procedural deficiency in that the post-modification test procedure failedito detect a wiring error.
Corrective Action Taken and Results Achieved 1
. l. Th'e procedure tabulating the required containment penetration
. conductor overcurrent protective devices has been issued.
2.
No adverse effect was created by this procedure step being performed out of sequence.
- 3..The wiring error was corrected.
Corrective Action Steps Taken to Avoid Further Violations
- 1. - Document Control will issue the Technical Specification amendments to the Operations-Manager upon receipt from the NRC. The operations Manager will review the amendments to ensure accuracy and determine what actions are required by the various plant groups. The Operations Manager will identify the required actions to other managers via Document Control. Document Control will track these actions to ensure that the actions are performed within the required time frame.
2.
The plant operator involved in this event has been counseled concerning proper procedural compliaace. Operations shift personnel have been retrained on performing surveillance tests in the required sequence. The procedure (FNP-1-STP-33.0B) has been revised to allow recording of the counter number at a later step.
3.
Plant-Modifications personnel responsible for testing have been instruct-ed to provide for adequate testing of circuitry for future modifications.
Date of Full Compliance September' 16, 1987 1
Affirmation i
I affirm that this 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 tr y,
kll NDl /
/
R. P. Mcdonald j
RPM:emb cc:
Mr. L. B. Long Dr. J. N. Grace Mr. E. A. Reeves Mr. W. H. Bradford n