ML20247E915
| ML20247E915 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 05/18/1989 |
| From: | Hairston W ALABAMA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8905260372 | |
| Download: ML20247E915 (4) | |
Text
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' Nabama Power Company
- ' 40 inverness Center Parkway
' Post Office Box 1295 Birmingham, Alabama 35201
. Telephone 205 868-5581 W. G. Hairston, til --
Senior Vice President Nuclear Operations gggg the southem electnc system May 18, 1989 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 March 11 - April 10, 1989 RE:
Report Numbers 50-348/89-07 50-364/89-07
Dear Sir:
This letter refers to the violation cited in the subject inspection reports which states:
i (NRC) inspection conducted on
."During the Nuclear Regulatory Commiss ona violation of NRC requirements was identified.
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March 11 - April 10,.1989 The violation involved failure to follow procedures.
In accordance with the
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" General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C (1986), the violation is cited 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.
Procedure FNP-0-AP-52, Equipment Status Control and Maintenance Authorization, Section 7.5.9 states that the releasing authority is responsible for ensuring that proper test and restoration steps are Fire completed prior to functional acceptance of any work request.
protection systems are listed in Appendix III Table III of AP-52 as systems which require verification of lineup to be y rformed prior to return to service.
Prcredure FNP-0-AP-16, Conduct of Operation - Operations Group, Section 6.5 states that shift log sheets are utilized by operating personnel to provide a method for recording system and equipment operating data and characteristics during performance of their assigned duties.
The Auxilinry Building Rover Log (R Type G7.31, Rev. 8) sheets 1 and 4 require the Units 1 and 2 fire protection panels on 121' elevation of Note 5 in the the auxiliary building to be inspected every four hours.
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.3 4-U. S. Nuclear Regulatory Commission-
._ May 18, 1989 Page 2
- q log directs.the rover watch to notify the shift foreman of all systems in override.
Contrary to the above, the procedure requirements were not met in that:
1.
' Fire protection panel for system FSP-2A-59,139' elevation - West corridor, was placed in override position on February 24 at 8:30 a.m.
to perform cleaning and calibration of the system smoke detectors, but.was not. restored to service upon completion of the maintenance oc'.ivities at approximately 2:30 p.m.
The system was left in override d ich rendered the sprinkler system for. zone FSP-2A-59 inoperable.
The continuous fire watches or hourly fire watch patrols to meet the action statement of Technical Specification 3.7.11.2 were established at 8:30 a.m. but were removed at 2:30 p.m. on February
- 24. The releasing authority, which was the operations group, failed to verify system operability upon returning the system to service.
The appropriate fire watches were not provided between approximately-a 3:00 p.m. on_ February 24 and 7:30 p.m. on February 25.
2.
The system operators, assigned the auxiliary building rover watch position, failed to identify and document that fire protection system FSP-2A-59 was in the override position on all rounds conducted between approximately 8:30 a.m. on February 24 through 4:00 p.m. on February:
. 25. The panel was in override and.the sprinkler systems were inoperable during this period.
This is a Severity Level IV Violation (Supplement I)."
Admission"or Denial.
The above violation occurred as described in the subject reports.
Reasons for Violation This violation was caused by:
1.
Personnel error in that the Shift Foreman signed off the system restoration based on an assumption and not on fact.
2.
Personnel error in that two system operators did an inadequate check of the panel. A third system operator did not perform his duties because he assumed that the system was supposed to be in override.
One contributing cause of this event was that the indicator light is a small orange bulb surrounded by a red background making it necessary to perform more t
than a cursory review to identify that it is illuminated.
Another contributing cause of this event was that the procedure for performing 1
cleaning and calibration of system smoke detectors did not require that the l '.
system be taken out of the override position when the maintenance was completed.
e' U.'S. Nuclear Regulatory Commission May 18 Page 3,1989 Corrective Action Taken and Results Achieved The required fire watch was established until the system was returned to service.
Corrective Steps To Avoid Further Violations 1.
The personnel involved have been counseled regarding their inadequate verifications.
2.
A memo was issued to all Operations personnel instructing them on this incident and the lessons learned from these evento.
3.
On-shift licensed personnel have been instructed on human performance and the factors that influence behavior, using the draft INPO Good Practice on this subject.
4.
A contrasting background will be provided for the orange bulb to make it easier to identify.
5.
A step to require the system to be taken out of override will be added to the appropriate procedure.
6.
The program in which upper plant management interviews personnel who are involved in selected incidents of personnel error will be continued. This program will continue to stress to employees, management's commitment to adherence to procedure and attention to detail, and the fact that personnel-cannot make decisions and document actions based on assumptions.
Steps will be taken to heighten employees' awareness of how errors can be 7.
made if decisions are based on assumptions. This will be done through discussions at plant meetings and briefings.
Date of Pull Compliance August 31, 1989 Additional Information Requested in the Notice of Violation This violation is identified as being similar to violations contained in the Notices sent to Alabama Power by NRC letters dated February 25 and September 16, 1988. Because "similar violations", as described in the NRC Enforcement Policy, are of significant concern to the NRC, it was requested that the root cause of this problem be identified. As a part of our response on October 26, 1988, it was indicated that a program would be developed in which upper plant management will interview personnel who are involved in selected incidents of personnel These interviews have determined that in the case of this violation and error.
Errors are of other incidents of personnel error, there is a common root cause.
being made due to some personnel having a mind set and attitude of expecting all actions which should have been performed by others to have been completed
U. S. Nuclear Eegulatory Commission May 18, 1989 Page 4 properly. These individuals are then doing less than adequate crifications to ensure that procedures are properly performed and that requirt actions are accomplished.
This attitude of assuming that actions have been accomplished without verifying them has caused errors in various plant groups.
It should be pointed out that the cause of problems with procedural compliance has changed over the years at FNP.
In the early 1980's, procedures were not as adequate as they should have been and people did not follow them as well as they should have. This was corrected by placing more attention on writing procedures which better reflected equipment operation.
The next cause of procedural adherence problems was that with these better procedures, people would follow them except when they thought that they knew the intent well enough to justify deviations. The corrective action for rSis has been to heighten employees' awareness of the importance of procedural adherence through discussions at plant meetings and briefings. An increased awareness of the importance of procedural adherence has been achieved and is evidenced by the number of procedure changes initiated by procedure users to allow strict procedural adherence.
The current problem stems from the reliance on others to have done their job properly and the individual's not doing adequate self-checks with a questioning attitude to ensure each action is actually accomplished as required.
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, hl T
W. G. Hairston, III WGH:emb/89-0156 cc:
Mr. S. D. Ebneter Mr. E. A. Reeves Mr. G. F. Maxwell I
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