ML20236W544
| ML20236W544 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 07/31/1998 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-348-98-03, 50-348-98-3, 50-364-98-03, 50-364-98-3, NUDOCS 9808060052 | |
| Download: ML20236W544 (8) | |
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0;ve Morey Southern Nuclear Vice Presid;nt Op: rating Company Farley r'roject P.O. Box 1295 Birmingham. Alabama 35201 f'
Tel 205.992.5131 July 31, 1998 SOUTHERN h COMPANY Energy to Serve YourWorld*
Docket Nos.:
50-348 10 CFR 2.201 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk -
Washington, DC 20555 Joseph M. Farley Nuclear Plant Reply To A Notice Of Violation VIO 50-348,364/98-03-06
" Inadequate Corrective Actions For MCR Ventilation System" And VIO 50-348,364/98-03-07 "Faihire To Promptiv Terminate Security Access" Ladies and Gentlemen:
As requested by NRC inspection report dated July 1,1998, this letter responds to VIO 50-348,364/98-03-06, " Inadequate Corrective Actions for MCR Ventilation System" and VIO 50-348,364/98-03-07,
" Failure to Promptly Terminate Security Access." The Southem Nuclear Operating Company (SNC) responses are provided in the enclosures.
There is one new NRC commitment associated with VIO 30-348,364/98-03-06. A review will be performed of the FSD/SSSA database for other systems to verify other open items were appropriately closed out. This will be completed by November 30,1998. Nothing else in this letter should be considered as a formal NRC commitment.
If you have any questions, please advise.
Respectfully submitted, Dave Morey 4
v c. ~ L. a n EWC/maf:nov3-7R4. doc i
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Mr. L. A. Reyes, Region 11 Administrator Mr. J. I. Zimmerman, NRR Project Manager Mr. T. M. Ross, Plant Sr. Resident inspector 9808060052 980731 PDR ADOCK 05000348 G
ENCLOSUREI VIO 50-348,364/98-03-06, "Inadeguate Corrective. Actions for MCR Ventilation System" l
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l SNC Response to VIO 50-348,364/98-03-06,
" Inadequate Corrective Actions for MCR Ventilation System" VIO 50-348,364/98-03-06," Inadequate Corrective Actions for MCR Ventilation System" states:
10 CFR Part 50, Appendix B, Criterion'XVI; Updated Final Safety
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Analysis Report, Section 17.2; and the J. M. Farley Plant Operations E
- Quality Assurance Policy Manual, Chapter 16, require that the licensee take measures to assure that conditions adverse to quality are promptly identified and corrected. Such measures are to be taken to assure that -
the cause of the condition is determined and corrective actions are taken to preclude repetition.
Contrary to the above, several conditions adverse to quality associated with the Control Room Ventilation System (CRVS) were not promptly
_j corrected. They were inappropriately closed out in mid-1995 to early l
1996 beinre adequate corrective actions were completed. The licensee l
se-opened these issues in late 1997 to implement additional corrective j
l' actions needed to resolve them. 'Ihe conditions adverse to quality not adequately corrected were:
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' (1)
The control room exhaust isolation dampers were left open instead of closed, contrary to the original design basis (Open -
Item CRV-007).
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Areas adjacent to the MCR could be pressurized to greater j
than the MCR pressure and thereby allow unfiltered air inkakage into the MCR greater than assumed by the design 1
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calculation (Open item CRV-010).
j (3)
MCR pressure testing did not adequately verify the MCR l
boundary integrity and therefore the administrative limit used l"
to define allowable bmaches was insufficient to ensure Technical Specification compliance (Open item CRV-019),
i-This is a Severity Level IV violation (Supplement I).
Asimission or Denial The violation occurred as described in the Notice of Violation.
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' Reason for Violation The causes of the adverse conditions are explained below:
(1) la the case of CRV-007, in 1995 it was incorrectly deemed appropriate to rely on operator action to ensure control room integrity. Subsequently, it was identified that relying on ope.c*or action was inappropriate and the dampers were clo::ed.
(2)
' In the case of CRV-010, there are only two areas adjacent to 'the MCR that could be pressurized to greater than the MCR pressure
- (the west sije of the control room floor and the control room wall adjacent to the TSC) and thereby allow unfiltered air inleakage into the MCR greater than assumed in design calculations. The Resolution Coordinator incorrectly closed the open item before verifying that the corrective actions were completed. This action circumvented the verification process.
'(3)
In the case of CRV-019, the MCR pressure testing did verify that the MCR could be pressurized as designed, but did not verify that the MCR could be pressurized to.the designed minimum pressure if an. opening the size of the administrative limit existed.'
' Based on the above situations, there does not appear to be a programmatic weakness; however, this will be reassessed after the review described in
" Corrective Steps That Will Be Taken To Avoid Further Violation"is completed.
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- Corrective Steos Taken and Results Achieved (1)
The system operating procedure has been revised and administrative centrols established to ensure the control room exhaust isolation dampers are operated within the design basis, (2)
Procedures have been revised to implement the reconunended compensatory measures during a breach of the west side of the control room floor or the control room wall adjacent to the TSC.
(3)
_ 'Ihe MCR pressure test has been changed to quantify the allowable boundary breach to ensure the administrative limit is met.
(4).
- The current Resolution Coordirutor, who has primary responsibility for closing open items, was re-instructed on the necessity of ensuring all L
actions have been satisfactorily completed and documented prior to l
closing open itenu.
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Corrective Stcos That Will Be Taken To Avoid Further Violation A review will be'perfoimed of the FSD/SSSA database for other systems to verify other open items were appropriately closed out. Additional corrective actions may be taken as a result of the resiew.
Date of Full Compliance FNP was in full compliance as of July 24,1998; all planned corrective actions will be completed by November 30,1998.
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l ENCLOSUREII VIO 50-348,364/98-03-07,
" Failure to Promotiv Terminat; Security Access"
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SNC Response to VIO 50-348,364/98-03-07, l
" Failure to Promptly Terminate Security Access" VIO 50-348,364/98-03-07, " Failure to Promptly Terminate Security Access" states:
Technical Specification 6.8.1.f requires written procedures be established, implemented, and maintained for the Security i'
Program.
FNP-0-AP-42, " Access Control," Revision 26, requires that individuals be removed from the appropriate access list inunediately upon termination of need.
Procedure FNP-0-SP-11, " Badging Procedures," Revision 13, states that changes in personnel access requirements caused by termination of employees will bc reported immediately to the Security Site Manager. The necessary action will be taken to remove the individual from access.
Contrary to the above, during Spring 1998, procedures were not implemented in that the licensee failed to remove eight individuals l
from the appropriate access list immediately upon termination of need. None of the eight individuals entered either the protected or any vital areas after termination.
This is a Severity Level IV violation (Supplement III).
Admission or Denial l
The violation occurred as described in the Notice of Violation.
Reason for Violation The cause of this event is personnel error in that contractor staff /nenagement and SNC service administrators were cogmzant of the need to immediately notify Security in the event of a termination for cause; however, contractor stafr/ management and SNC service administrators were not cognizant of the need to immediately notify Security for routine employment changes that resulted in the end of a need for access.
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Corrective Steps Taken and Results Achieved 1)
- Ihe access privileges of the eight individuals cited had been revoked prior to discovery of the condition. A broadness review for similar problems with access termination was performed. No similar problems were found.
2)
Members of site contractor management have been verbally instructed to I
notify security staff when access is no longer required by no later than the end of the following business day. A memo was sent to FNP Service Administrators from the Manager of Administration stating that they were responsible for ensuring the contractors meet the notification requirement.
3)
FNP-0-AP-42, " Access Control," was revised to state that when an individual's need for access is no longer required, Security is to be l
notified no later than the end of the following business day.
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FNP-0-SP-11, " Badging Procedure," was also revised to state that when l
an individual's need for access is no longer required, Security is to be l
notified no later than the end of the following business day.
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5)
The Service Administrator checklist, " Summary of Generic Requirements j
for Onsite Senices,"(Figure 3 of FFP-0-QCP-10) was revised to reflect the notification requirement.
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Corrective Steps That Will Be Taken To Avoid Further Violation All planned corrective actions have been completed.
Date of Full Compliance l
j FNP was in thll compliance as of July 8,1998.
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