ML20246J013
| ML20246J013 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 08/30/1989 |
| From: | Hairston W ALABAMA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8909050018 | |
| Download: ML20246J013 (4) | |
Text
_ _ - _ _ _ _
. Al:.b:ma Power comptny 40 Inverness czntir Parkway Post Office Box 1295 Birmingham, Alabama 35201 Telephone 205 866 5581 l
W. G. Hairston, Ill Senior Vice President Nuclear Operations -
AlabamaPower the southem electnc system August 30, 1989 10 CFR 2 Docket Nos. 50-348-50-364 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555
SUBJECT:
Reply to a Notice of Violation
.J. M. Farley Nuclear Plant NRC Inspection of April 24-27 and May 8-12, 1989 RE:
Report Numbers 50-348/89-10 and 50-364/89-10 Gentlemen:
This letter refers to the violation cited in the subject inspection reports which state:
"During the Nuclear Regulatory Commission (NRC) inspection conducted on April 24-27 and May 8-12, 1989, a violation of NRC requirements was identified.
In accordance with the ' General Statement of Policy and Procedure for NRC Enforcement Actions,' 10 CFR Part 2, Appendix C, 53 Fed. Reg. 40019 (October-13, 1988), 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. RG 1.33, Appendix A, specifies proceduLes for 1) Procedure Adherence and Temporary Change Method, and 2) Procedures for Performing Maintenance.
Contrary to the above, NRC identified four examples described below where procedures were not followed or an adequate procedure wac not established.
a) On November 7, 1987, a Temporary Change Notice (TCN) was processed to Maintenance Procedure FNP-0-MP-28.116 which deleted the require-ment to calibrate safety-related D.C. circuit breakers. As a result, the circuit breakers were not calibrated for several years, some The change was not properly conducted in since plant startup.
compliance with procedure FNP-0-AP-1, Development Review and Approval of Plant Procedures in'that the change was an intent change but was not approved by the proper level of management prior to implementation.
b) On May 10, 1989, NRC observed maintenance work on the' Unit 2 turbine driven auxiliary feedwater pump using procedure FNP-0-MP-7.1.
Two steps were signed off as complete when in fact these steps were not and should not have been performed. The erroneous steps should have been deleted by procedure revision.
%0f 8909050018 890830 PDR ADOCK 05000348 PDC g
I(
m L-s
. Nuclear Regulatory Commission August 30, 1989 ~
1 Page 2 c) -on April ~ 25, 1989, NRC identified'that the orifice plate for flow element (FE) 949.was installed backwards. %e licensee subsequently identified four other orifice plates that were installed backwards in
.other plant systems.- Maintenance procedures'were not established to ensure that orifice plates are. installed in the correct direction.
d) On May 11, 1989,- NRC observed in-shop welding repairs on a fire door.
We welding procedure CSM-10 specified for the job called'for too high amperage'and hence too high heat for the thin metal being welded. 'The welder was using reduced heat and made the repair correctly but no effort was made to change the procedure or seek enother procedure.
Rese.four. examples' collectively represent a violation for failure to establish and implement procedures.
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 This violation was caused by:
a)
Personnel error in that the change made to the procedure was not recognized as a change of intent and thus did not receive the level of approval required by FNP-0-AP-1.
b).
Personnel error in that:
1) h e procedure was not changed prior to the assembly of the seal package.
2)
Two steps of the procedure were signed off as being completed when some of the assembly work was not performed.
c)
Inadequate procedure in-that no procedure was established covering the installation of flow orifices following maintenance.
'd)
Personnel error in that:
1)
An inappropriate procedure was specified for use. The welder did not recognize that the procedure was inappropriate and made no effort to have the procedure changed.
2)
The welder failed to review the specified procedure prior to beginning work and failed to verify that the current he was using was within the allowed range of the procedure.
4 f
o________
Nuclear Regulatory Commission August 30, 1989 Page 3 Corrective Action Taken and Results Achieved a)
Revision 5 to FNP-0-MP-28.116, issued in January of 1988, reinstated the test and verification of the DC breakers. Further corrective action was taken in May 1989, when all of the Unit 2 and all but three of the Unit 1 DC circuit breakers were calibrated. The remaining Unit 1 breakers will be calibrated during the Unit 1 ninth refueling outage. The designer has reviewed the "as-found" Unit 2 calibration data and determined that all breakers would have performed their intended design function. An evaluation of the Unit 1 breakers is in progress and will be completed when the "as-found" calibration data are obtained for the final three breakers, b)
FNP-0-MP-7.1, Disassembly, Inspection and Reassembly of Auxiliary Feedwater Pumps, was changed on May 11, 1989 to delete the steps regarding the installation of the secondary seal parts.
c)
An inspection program was initiated in May ]989, to examine orifices for proper installation. Examinations are being conducted on a sampling basis to ensure proper installation with a 95% confidence level. To date, 194 orifices have been inspected. Four were found installed incorrectly. Three orifices on Unit 2 that were installed reversed have been evaluated and corrected. One Unit 1 orifice that was reversed, NIN23FE3229B, auxiliary feedwater to IB steam generator, cannot be worked at power. An evaluation was performed on the effects of having the auxiliary feedwater flow to "B" steam generator orifice installed backwards. It concluded that the reverse installation of the flow orifice was not safety significant. The orifice inspection program is still in progress with additional sampling to be conducted during the upcoming Unit 1 ninth refueling outage.
d)
It was determined that the repair that was performed on the fire door was of good quality and no corrective action was required prior to restoring the door to service.
Corrective Steps To Avoid Further violations a)
A special training session will be conducted by the Maintenance Manager for all maintenance personnel on the subject of procedural compliance. Part of this training will emphasize the need for recognizing when a temporary change to a procedure involves a change of intent in order to ensure that the appropriate level of authority approves changes prior to implementation. The training will include instruction on the proper conipletion of Nuclear Safety Evaluation Checklists, b)
A special training session will be conducted by the Maintenance Manager for all maintenance personnel on the subject of procedural compliance. This training will emphasize the need for maintenance L
Nuclear Regulatory Comission August 30, 1989 Page 4 personnel to review procedures closely so that proper signoffs can be made for work actually performed. This training will stress the importance of taking the time to change procedures when necessary prior to performing work.
c)
Work planners will be instructed to ensure that they include orientation directions in the work sequence when they plan work requests involving flow orifices. Additionally, the Mechanical Maintenance Supervisor will train all mechanical maintenance personnel on proper installation of flow orifices. A maintenance procedure is being developed which will provide directions on the proper installation of flow orifices.
d)
A special training session will be conducted by the Maintenance Manager for all maintenance personnel on the subject of procedural compliance. This training will stress the role of supervisory personnel in specifying the correct procedure when required and the need for maintenance personnel to review and understand work packages prior to comencing work.
The welding foremen will be instructed to ensure that they specify the appropriate process for each weld job. All APCo welders will be instructed to examine each specified process closely to verify that they can comply with it; and if necessary, have it changed. This instruction will emphasize the need to check the amperages, particularly when using a foot-pedal since the foot-pedal could reduce the amperage below the specified band.
Date of Full Compliance a) November 7, 1989 b) September 13, 1989 c) November 7, 1989 d) September 13, 1989 Affirmation 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.
Respectfully submitted,
{h.>h. fh W.G.lairston,III "V
WGH,III:emb/4.47 cc:
Mr. S. D. Ebneter Mr. E. A. Reeves Mr. G. F. Maxwell
_- _--._--- ___-_ - -- _- _ _ ___ ______ - -__-_-_-_-_--___ _ __ _