ML20236F479
| ML20236F479 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 06/28/1987 |
| From: | Mcdonald R ALABAMA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| RTR-REGGD-01.033 NT-87-0328, NUDOCS 8708030360 | |
| Download: ML20236F479 (3) | |
Text
. _ _ _ _
f 'AlabamEPower Company -
NT 87-0328 600. North 18th Street 4.
Post office Box 2641
,. Birmingham, Alabama 352914400
. Telephone 205 250-1835 i
R. P. Mcdonald p
senior vice president-Alabama Power the southom electnc system June 28, 1987-
. Docket No. 50-348 Docket No. 50-364
(
U. S. Nuclear Regulatory Conunission
. Attention: Document Control Desk E'
Washington, D. C. 20555
SUBJECT:
J. M. Farley Nuclear Plant NRC Inspection of May 18 - June 12, 1987 RE:
Report Number 50-348/87-13-01 50-364/87-13-01
Dear Sir:
This letter refers to the violation cited in the subject inspection reports which state:
"During the Nuclear Regulatory Commission (NRC) inspection conducted on May 181-June 12, 1987, a violation of NRC requirements was identified.
The violation' involved two examples of failure to establish procedures for control of test and other equipment. 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.a requires that applicable written procedures recommended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, 1978 be established and implemented. RG 1.33 specifies procedures for equipment control.
Administrative Procedure (AP) 52, Equipment. Control and Mainte-nance Authorization, section 7.5.9 requires that proper test i
and restoration be completed prior to functional acceptance of the work request and that a verification of valve lineup be performed prior to return to service.
Contrary to the above:
4 1.
On May 8, 1987, at approximately 12:30 p.m. the 1B residual
[
heat removal pump room cooler was returned to service without i
the required functional acceptance testing and valve lineup u ing performed which led to the inlet and outlet cooling water valves being left closed until 11:05 p.m. on May 10, 1987.
This also resulted in the total out of service time exceeding the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> permitted by TS 3.5.2 Action Statement a.
h50kh g C
vori o
U. S. Nuclear Regulatory Cotuission June 28, 1987 Page 2 2.
The licensee failed to establish and implement a procedure establishing requirements for control of test and other equipnent in safety related areas in that certain safety related areas contained testing equipment for electrical breaker testing, lifting devices for rod control MG sets and ladders. None of the equipment was secured to prevent
}
damage to safety related equipment in case of a seismic event.
This is a Severity Level IV violation (Supplement I).
Admission or Denial 1.
The first part of the above violation occurred as described in the subject reports.
2.
Alabama Power Company objects to the secord part of the above violation because it is believed that no violation of Regulatory Guide 1.33 occurred. Paragraph 8.a of Regulatory Guide 1.33 states:
" Procedures of a type appropriate to the circumstances should be provided to ensure that tools, gauges, instruments, controls and other measuring and testing devices are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy.
Specific examples of such equipment to be calibrated and tested are readout instruments, interlock permissive and prohibit circuits, alarm devices, sensors, signal conditioners, controls, protective circuits, and laboratory equipment."
l 1
Alabama Power Company believes that:
The intent of Regulatory Guide 1.33 with regard to equipment a.
control is that procedures be developed to control the calibration and use of test equipment. However, it is not the intent of the Regulatory Guide to require that unattended equipment be secured.
b.
There are no NRC criteria regarding the storage of portable equipment when not in use.
Reason for Violation 1.
The first part of the above violation was caused by personnel error.
The Shift Supervisor and Shift Foreman Inspecting who functionally accepted the applicable Maintenance Work Request did not ensure that functional acceptance included a verification that all the valves within the boundary of the Tagging operations order were properly repositioned as required by FNP-O-AP-52 (Equipment Status Control and Maintenance Authorization).
i b
l!
i
..ge
- D+
! U. S. Nuclear-Regulatory Commission
' July 28,'1987-
- Page'3-i
/2'. 'Not Applicable.
Corrective Action Taken and Results Achieved 1.
The affected RHR pump room cooler valves were opened immediately to meet the required functional acceptance testing and' restoration.:
2.
Unattended and unsecured test equipment, lifting devices and ladders wereLremoved frem the identified safety related areas.
Corrective Steps Taken to Avoid P_rther Violations 1.
The Shift Supervisor and Shift Foreman Inspecting-have been counseled concerning this event. Also, this event'will be discussed with appropriate Operations personnel.
2; No action is required.
Date of Full Compliance August 31, 1987.
)
Affirmation
.I affirm that this response is true and complete to the best of my
--knowledge, information,'and belief. The information contained in this i
. letter is not considered to be of a proprietary nature.
Yours very t y,
.R. P. Mcdonald RPM:emb'-
r icc:
Mr. L. B. Long Dr. J. N. Grace Mr. E. A. Reeves
(
Mr. W. H. Bradford-l l
.- -- ]