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Category:CORRESPONDENCE-LETTERS
MONTHYEARL-99-035, Forwards non-proprietary & Proprietary Versions of Farley Units 1 & 2 LBB Calculation Results Due to SG Replacement & SG Snubber Elimination Programs, Used to Support SG Replacement Project.Proprietary Encl Withheld1999-10-18018 October 1999 Forwards non-proprietary & Proprietary Versions of Farley Units 1 & 2 LBB Calculation Results Due to SG Replacement & SG Snubber Elimination Programs, Used to Support SG Replacement Project.Proprietary Encl Withheld ML20217G0801999-10-0707 October 1999 Informs That on 990930,staff Conducted mid-cycle PPR of Farley & Did Not Identify Any Areas in Which Performance Warranted More than Core Insp Program.Nrc Will Conduct Regional Insps Associated with SG Removal & Installation ML20217P0661999-10-0606 October 1999 Requests Withholding of Proprietary Rept NSD-SAE-ESI-99-389, Farley Units 1 & 2 LBB Calculation Results Due to SG Replacement & SG Snubber Elimination Programs ML20217B1891999-10-0404 October 1999 Submits Clarification Re Development of Basis for Determining Limiting Internal Pressure Loads Re Review of NRC SE for Cycle 16 Extension Request.Util Intends to Use Guidelines When Evaluating SG Tube Structural Integrity ML20212J8391999-09-30030 September 1999 Forwards RAI Re Request for Amends to Ts.Addl Info Needed to Complete Review to Verify That Proposed TS Are Consistent with & Validate Design Basis Analysis.Request Discussed with H Mahan on 990930.Info Needed within 10 Days of This Ltr ML20212J8801999-09-30030 September 1999 Discusses GL 98-01,suppl 1, Y2K Readiness of Computer Sys at Npps. Util 980731,990607 & 03 Ltrs Provided Requested Info in Subj Gl.Nrc Considers Subj GL to Be Closed for Unit 1 L-99-032, Responds to NRC Re Adequacy of Kaowool Fire Retardant Fire Barriers in Use at Jfnp,Units 1 & 21999-09-23023 September 1999 Responds to NRC Re Adequacy of Kaowool Fire Retardant Fire Barriers in Use at Jfnp,Units 1 & 2 L-99-034, Forwards Comments on Draft Current Tech Specs Discussion of Change Tables for Jm Farley Nuclear Plant.Units 1 & 21999-09-23023 September 1999 Forwards Comments on Draft Current Tech Specs Discussion of Change Tables for Jm Farley Nuclear Plant.Units 1 & 2 ML20212F8861999-09-23023 September 1999 Forwards Revised Relief Request Number 32 for NRC Approval. Approval Requested by 991231 to Support Activities to Be Performed During Unit 1 Refueling Outage Scheduled for Spring of 2000 ML20212E7031999-09-23023 September 1999 Responds to GL 98-01, Year 2000 Readiness of Computer Sys at Npps. Util Requested to Submit Plans & Schedules for Resolving Y2K-related Issues ML20212F1111999-09-21021 September 1999 Discusses Closeout of GL 97-06, Degradation of Steam Generator Internals ML20212C2351999-09-16016 September 1999 Submits Corrected Info Concerning Snoc Response to NRC GL 99-02, Lab Testing of Nuclear-Grade Activated Charcoal ML20212D0101999-09-15015 September 1999 Informs That Submittal of clean-typed Copy of ITS & ITS Bases Will Be Delayed.Delay Due to Need for Resolution of Two Issues Raised by NRC staff.Clean-typed Copy of ITS Will Be Submitted within 4 Wks Following Resolution of Issues ML20212C4641999-09-13013 September 1999 Forwards Info Requested in Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams L-99-031, Informs NRC That Review of MOV Testing Frequency & Changes Made to Frequency of MOV Testing Has Been Completed1999-09-13013 September 1999 Informs NRC That Review of MOV Testing Frequency & Changes Made to Frequency of MOV Testing Has Been Completed ML20212C8041999-09-10010 September 1999 Responds to to D Rathbun Requesting Review of J Sherman Re Y2K Compliance.Latest NRC Status Rept on Y2K Activities Encl ML20212D4581999-09-10010 September 1999 Responds to to D Rathbun,Requesting Review of J Sherman Expressing Concerns That Plant & Other Nuclear Plants Not Yet Y2K Compliant ML20212A6951999-09-0909 September 1999 Requests That Licensees Affected by Kaowool Fire Barriers Take Issue on Voluntary Initiative & Propose Approach for Resolving Subj Issues.Staff Plans to Meet with Licensees to Discuss Listed Topics ML20212A8341999-09-0909 September 1999 Requests That Licensees Affected by Kaowool Fire Barriers Take Issue on Voluntary Initiative & Propose Approach for Resolving Subj Issues.Staff Plans to Meet with Licensees to Discuss Listed Topics ML20211N8041999-09-0808 September 1999 Informs That on 990930 NRC Issued GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Condition, to Holders of Nuclear Plant Operating Licenses ML20211N4301999-09-0808 September 1999 Discusses Proposed Meeting to Discuss Kaowool Fire Barriers. Staff Requesting That Affected Licensees Take Issue on Voluntary Initative & Propose Approach for Resolving Issues ML20212C0071999-09-0202 September 1999 Forwards Insp Repts 50-348/99-05 & 50-364/99-05 on 990627- 0807.No Violations Noted.Licensee Conduct of Activities at Farley Plant Facilities Generally Characterized by safety-conscious Operations & Sound Engineering ML20211Q4801999-09-0101 September 1999 Informs That on 990812-13,Region II Hosted Training Managers Conference on Recent Changes to Operator Licensing Program. List of Attendees,Copy of Slide Presentations & List of Questions Received from Participants Encl ML20211K2131999-08-31031 August 1999 Informs That Snoc Has Conducted Review of Reactor Vessel Integrity Database,Version 2 (RVID2) & Conclude That Latest Data Submitted for Farley Units Has Not Been Incorporated Into RVID2 ML20211K4101999-08-31031 August 1999 Resubmits Relief Requests Q1P16-RR-V-5 & Q2P16-RR-V-5 That Seek to Group V661 Valves from Each Unit Into Sample Disassembly & Insp Group,Per 990525 Telcon with NRC L-99-030, Forwards SNC Review Comments on Draft SE & marked-up Copy of Draft SE Incorporating SNC Comments Re Proposed Conversion to ITS1999-08-30030 August 1999 Forwards SNC Review Comments on Draft SE & marked-up Copy of Draft SE Incorporating SNC Comments Re Proposed Conversion to ITS ML20211G6851999-08-26026 August 1999 Informs That During Insp,Technical Issues Associated with Design,Installation & fire-resistive Performance of Kaowool Raceway fire-barriers Installed at Farley Nuclear Plant Were Identified L-99-029, Forwards Revised Response to Chapter 3.1 RAI Requested in 990726 Conference Call,Rai Response Related to Beyond Scope Issue for Chapter 3.5 Requested by Conference Call on 990805 & RAI Response to Chapter 3.8 Requested on 990615 & 07271999-08-19019 August 1999 Forwards Revised Response to Chapter 3.1 RAI Requested in 990726 Conference Call,Rai Response Related to Beyond Scope Issue for Chapter 3.5 Requested by Conference Call on 990805 & RAI Response to Chapter 3.8 Requested on 990615 & 0727 ML20211B9431999-08-17017 August 1999 Forwards Fitness for Duty Performance Data for six-month Reporting Period 990101-990630,IAW 10CFR26.71(d).Rept Covers Employees at Jm Farley Nuclear Plant & Southern Nuclear Corporate Headquarters ML20211B9211999-08-17017 August 1999 Responds to NRC Re Violations Noted in Insp Rept 50-348/99-09 & 50-364/99-09.Corrective Actions:Security Response Plan Was Revised to Address Vulnerabilities Identified During NRC Insp ML20210R5101999-08-12012 August 1999 Forwards Revised Page 6 to 990430 LAR to Operate Farley Nuclear Plant,Unit 1,for Cycle 16 Only,Based on risk- Informed Approach for Evaluation of SG Tube Structural Integrity,As Result of Staff Comments ML20212C8141999-08-0909 August 1999 Forwards Correspondence Received from Jm Sherman.Requests Review of Info Re Established Policies & Procedures ML20210T2021999-08-0606 August 1999 Forwards Draft SE Accepting Licensee Proposed Conversion of Plant,Units 1 & 2 Current TSs to Its.Its Based on Listed Documents ML20210Q4641999-08-0505 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Authorized Representative of Facility Must Submit Ltr to La Reyes,As Listed,With List of Individuals to Take exam,30 Days Before Exam Date ML20210J8341999-07-30030 July 1999 Forwards Second Request for Addl Info Re Util 990430 Amend Request to Allow Util to Operate Unit 1,for Cycle 16 Based on risk-informed Probability of SG Tube Rupture & Nominal accident-induced primary-to-second Leakage ML20210G4901999-07-30030 July 1999 Responds to GL 99-02, Laboratory Testing of Nuclear-Grade Activated Charcoal, Issued 990603.Ltr Contains NRC License Commitment to Utilize ASTM D3803-1989 with Efficiency Acceptance Criteria Utilizing Safety Factor of 2 L-99-028, Responds to NRC 990730 RAI Re 990423 OL Change Request to Allow for Risk Informed Approach for Evaluation of SG Tube Structural Integrity as Described by NEI 97-06, SG Program Guidelines1999-07-30030 July 1999 Responds to NRC 990730 RAI Re 990423 OL Change Request to Allow for Risk Informed Approach for Evaluation of SG Tube Structural Integrity as Described by NEI 97-06, SG Program Guidelines L-99-027, Addresses Clarifications to Selected Responses to Chapter 3.8 RAI Requested in NRC Conference Call on 990624, Resolution of Open Issue Related to Containment Purge in Chapter 3.6 & Response Related to Chapter 3.51999-07-27027 July 1999 Addresses Clarifications to Selected Responses to Chapter 3.8 RAI Requested in NRC Conference Call on 990624, Resolution of Open Issue Related to Containment Purge in Chapter 3.6 & Response Related to Chapter 3.5 ML20210G8181999-07-26026 July 1999 Forwards Insp Repts 50-348/99-04 & 50-364/99-04 on 990516- 0626.One Violation Identified & Being Treated as Noncited Violation IR 05000348/19990091999-07-23023 July 1999 Discusses Insp Repts 50-348/99-09 & 50-364/99-09 on 990308- 10 & Forwards Notice of Violation Re Failure to Intercept Adversary During Drills,Contrary to 10CFR73 & Physical Security Plan Requirements ML20210E4071999-07-22022 July 1999 Responds to NRC 990702 RAI Re Change Request to Allow for Risk Informed Approach for Evaluation of SG Tube Structural Integrity as Described in NEI 97-06, SG Program Guidelines L-99-026, Forwards Response to NRC 990702 RAI Re SG Replacement Related TS Change Request Submitted 981201.Ltr Contains No New Commitments1999-07-19019 July 1999 Forwards Response to NRC 990702 RAI Re SG Replacement Related TS Change Request Submitted 981201.Ltr Contains No New Commitments L-99-264, Responds to NRC 990603 Administrative Ltr 99-02, Operating Licensing Action Estimates, for Fy 2000 & 20011999-07-13013 July 1999 Responds to NRC 990603 Administrative Ltr 99-02, Operating Licensing Action Estimates, for Fy 2000 & 2001 ML20209H4721999-07-13013 July 1999 Responds to NRC 990603 Administrative Ltr 99-02, Operating Licensing Action Estimates, for Fy 2000 & 2001 ML20196J6191999-07-0202 July 1999 Forwards Final Dam Audit Rept of 981008 of Category 1 Cooling Water Storage Pond Dam.Requests Response within 120 Days of Date of Ltr 05000364/LER-1999-001, Forwards LER 99-001-00 Re Reactor Trip Due to Loss of Condenser Vacuum Steam Dump Drain Line Failure.Commitments Made by Licensee,Listed1999-07-0202 July 1999 Forwards LER 99-001-00 Re Reactor Trip Due to Loss of Condenser Vacuum Steam Dump Drain Line Failure.Commitments Made by Licensee,Listed ML20196J7471999-07-0202 July 1999 Forwards RAI Re Cycle 16 Extension Request.Response Requested within 30 Days of Date of Ltr ML20196J5781999-07-0202 July 1999 Forwards RAI Re 981201 & s Requesting Amend to TS Associated with Replacing Existing Westinghouse Model 51 SG with Westinghouse Model 54F Generators.Respond within 30 Days of Ltr Date ML20196J6571999-07-0202 July 1999 Discusses Closure to TAC MA0543 & MA0544 Re GL 92-01 Rev 1, Suppl 1,RV Structural Integrity.Nrc Has Revised Rvid & Releasing It as Rvid,Version 2 as Result of Review of Responses ML20196J3591999-06-30030 June 1999 Forwards SE of TR WCAP-14750, RCS Flow Verification Using Elbow Taps at Westinghouse 3-Loop Pwrs 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARL-99-035, Forwards non-proprietary & Proprietary Versions of Farley Units 1 & 2 LBB Calculation Results Due to SG Replacement & SG Snubber Elimination Programs, Used to Support SG Replacement Project.Proprietary Encl Withheld1999-10-18018 October 1999 Forwards non-proprietary & Proprietary Versions of Farley Units 1 & 2 LBB Calculation Results Due to SG Replacement & SG Snubber Elimination Programs, Used to Support SG Replacement Project.Proprietary Encl Withheld ML20217P0661999-10-0606 October 1999 Requests Withholding of Proprietary Rept NSD-SAE-ESI-99-389, Farley Units 1 & 2 LBB Calculation Results Due to SG Replacement & SG Snubber Elimination Programs ML20217B1891999-10-0404 October 1999 Submits Clarification Re Development of Basis for Determining Limiting Internal Pressure Loads Re Review of NRC SE for Cycle 16 Extension Request.Util Intends to Use Guidelines When Evaluating SG Tube Structural Integrity L-99-034, Forwards Comments on Draft Current Tech Specs Discussion of Change Tables for Jm Farley Nuclear Plant.Units 1 & 21999-09-23023 September 1999 Forwards Comments on Draft Current Tech Specs Discussion of Change Tables for Jm Farley Nuclear Plant.Units 1 & 2 L-99-032, Responds to NRC Re Adequacy of Kaowool Fire Retardant Fire Barriers in Use at Jfnp,Units 1 & 21999-09-23023 September 1999 Responds to NRC Re Adequacy of Kaowool Fire Retardant Fire Barriers in Use at Jfnp,Units 1 & 2 ML20212F8861999-09-23023 September 1999 Forwards Revised Relief Request Number 32 for NRC Approval. Approval Requested by 991231 to Support Activities to Be Performed During Unit 1 Refueling Outage Scheduled for Spring of 2000 ML20212C2351999-09-16016 September 1999 Submits Corrected Info Concerning Snoc Response to NRC GL 99-02, Lab Testing of Nuclear-Grade Activated Charcoal ML20212D0101999-09-15015 September 1999 Informs That Submittal of clean-typed Copy of ITS & ITS Bases Will Be Delayed.Delay Due to Need for Resolution of Two Issues Raised by NRC staff.Clean-typed Copy of ITS Will Be Submitted within 4 Wks Following Resolution of Issues L-99-031, Informs NRC That Review of MOV Testing Frequency & Changes Made to Frequency of MOV Testing Has Been Completed1999-09-13013 September 1999 Informs NRC That Review of MOV Testing Frequency & Changes Made to Frequency of MOV Testing Has Been Completed ML20212C4641999-09-13013 September 1999 Forwards Info Requested in Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams ML20211K2131999-08-31031 August 1999 Informs That Snoc Has Conducted Review of Reactor Vessel Integrity Database,Version 2 (RVID2) & Conclude That Latest Data Submitted for Farley Units Has Not Been Incorporated Into RVID2 ML20211K4101999-08-31031 August 1999 Resubmits Relief Requests Q1P16-RR-V-5 & Q2P16-RR-V-5 That Seek to Group V661 Valves from Each Unit Into Sample Disassembly & Insp Group,Per 990525 Telcon with NRC L-99-030, Forwards SNC Review Comments on Draft SE & marked-up Copy of Draft SE Incorporating SNC Comments Re Proposed Conversion to ITS1999-08-30030 August 1999 Forwards SNC Review Comments on Draft SE & marked-up Copy of Draft SE Incorporating SNC Comments Re Proposed Conversion to ITS L-99-029, Forwards Revised Response to Chapter 3.1 RAI Requested in 990726 Conference Call,Rai Response Related to Beyond Scope Issue for Chapter 3.5 Requested by Conference Call on 990805 & RAI Response to Chapter 3.8 Requested on 990615 & 07271999-08-19019 August 1999 Forwards Revised Response to Chapter 3.1 RAI Requested in 990726 Conference Call,Rai Response Related to Beyond Scope Issue for Chapter 3.5 Requested by Conference Call on 990805 & RAI Response to Chapter 3.8 Requested on 990615 & 0727 ML20211B9431999-08-17017 August 1999 Forwards Fitness for Duty Performance Data for six-month Reporting Period 990101-990630,IAW 10CFR26.71(d).Rept Covers Employees at Jm Farley Nuclear Plant & Southern Nuclear Corporate Headquarters ML20211B9211999-08-17017 August 1999 Responds to NRC Re Violations Noted in Insp Rept 50-348/99-09 & 50-364/99-09.Corrective Actions:Security Response Plan Was Revised to Address Vulnerabilities Identified During NRC Insp ML20210R5101999-08-12012 August 1999 Forwards Revised Page 6 to 990430 LAR to Operate Farley Nuclear Plant,Unit 1,for Cycle 16 Only,Based on risk- Informed Approach for Evaluation of SG Tube Structural Integrity,As Result of Staff Comments ML20212C8141999-08-0909 August 1999 Forwards Correspondence Received from Jm Sherman.Requests Review of Info Re Established Policies & Procedures ML20210G4901999-07-30030 July 1999 Responds to GL 99-02, Laboratory Testing of Nuclear-Grade Activated Charcoal, Issued 990603.Ltr Contains NRC License Commitment to Utilize ASTM D3803-1989 with Efficiency Acceptance Criteria Utilizing Safety Factor of 2 L-99-028, Responds to NRC 990730 RAI Re 990423 OL Change Request to Allow for Risk Informed Approach for Evaluation of SG Tube Structural Integrity as Described by NEI 97-06, SG Program Guidelines1999-07-30030 July 1999 Responds to NRC 990730 RAI Re 990423 OL Change Request to Allow for Risk Informed Approach for Evaluation of SG Tube Structural Integrity as Described by NEI 97-06, SG Program Guidelines L-99-027, Addresses Clarifications to Selected Responses to Chapter 3.8 RAI Requested in NRC Conference Call on 990624, Resolution of Open Issue Related to Containment Purge in Chapter 3.6 & Response Related to Chapter 3.51999-07-27027 July 1999 Addresses Clarifications to Selected Responses to Chapter 3.8 RAI Requested in NRC Conference Call on 990624, Resolution of Open Issue Related to Containment Purge in Chapter 3.6 & Response Related to Chapter 3.5 ML20210E4071999-07-22022 July 1999 Responds to NRC 990702 RAI Re Change Request to Allow for Risk Informed Approach for Evaluation of SG Tube Structural Integrity as Described in NEI 97-06, SG Program Guidelines L-99-026, Forwards Response to NRC 990702 RAI Re SG Replacement Related TS Change Request Submitted 981201.Ltr Contains No New Commitments1999-07-19019 July 1999 Forwards Response to NRC 990702 RAI Re SG Replacement Related TS Change Request Submitted 981201.Ltr Contains No New Commitments L-99-264, Responds to NRC 990603 Administrative Ltr 99-02, Operating Licensing Action Estimates, for Fy 2000 & 20011999-07-13013 July 1999 Responds to NRC 990603 Administrative Ltr 99-02, Operating Licensing Action Estimates, for Fy 2000 & 2001 ML20209H4721999-07-13013 July 1999 Responds to NRC 990603 Administrative Ltr 99-02, Operating Licensing Action Estimates, for Fy 2000 & 2001 05000364/LER-1999-001, Forwards LER 99-001-00 Re Reactor Trip Due to Loss of Condenser Vacuum Steam Dump Drain Line Failure.Commitments Made by Licensee,Listed1999-07-0202 July 1999 Forwards LER 99-001-00 Re Reactor Trip Due to Loss of Condenser Vacuum Steam Dump Drain Line Failure.Commitments Made by Licensee,Listed L-99-024, Responds to NRC RAI Re Conversion to ITS for Chapters 3.4, 3.5,3.6,3.7,3.9 & 5.0,per 990419-20 Meetings with NRC1999-06-30030 June 1999 Responds to NRC RAI Re Conversion to ITS for Chapters 3.4, 3.5,3.6,3.7,3.9 & 5.0,per 990419-20 Meetings with NRC L-99-025, Forwards Rev 2 to Jfnp Security plan,FNP-0-M-99,IAW 10CFR50.4(b)(4).Attachment 1 Contains Summary of Changes & Amended Security Plan Pages.Encl Withheld from Public Disclosure Per 10CFR73.211999-06-30030 June 1999 Forwards Rev 2 to Jfnp Security plan,FNP-0-M-99,IAW 10CFR50.4(b)(4).Attachment 1 Contains Summary of Changes & Amended Security Plan Pages.Encl Withheld from Public Disclosure Per 10CFR73.21 ML20196J8631999-06-30030 June 1999 Submits Correction to Errors Contained in to NRC Re TS Changes Re Control Room,Penetration Room & Containment Purge Filtration Systems & Radiation Monitoring Instrumentation.Errors Do Not Require Rev of SA L-99-249, Submits Correction to Errors Contained in to NRC Re TS Changes Re Control Room,Penetration Room & Containment Purge Filtration Systems & Radiation Monitoring Instrumentation.Errors Do Not Require Rev of SA1999-06-30030 June 1999 Submits Correction to Errors Contained in to NRC Re TS Changes Re Control Room,Penetration Room & Containment Purge Filtration Systems & Radiation Monitoring Instrumentation.Errors Do Not Require Rev of SA L-99-224, Submits Rev to Unit 2 SG Tube voltage-based Repair Criteria Data Rept.Ltr Contains No Commitments1999-06-0707 June 1999 Submits Rev to Unit 2 SG Tube voltage-based Repair Criteria Data Rept.Ltr Contains No Commitments ML20195F1731999-06-0707 June 1999 Forwards Proprietary & non-proprietary Responses to NRC RAIs Re W TR WCAP-14750, RCS Flow Verification Using Elbow Taps at W 3-Loop Pwrs. W Proprietary Notice,Affidavit & Copyright Notice,Encl.Proprietary Info Withheld L-99-217, Forwards Proprietary & non-proprietary Responses to NRC RAIs Re W TR WCAP-14750, RCS Flow Verification Using Elbow Taps at W 3-Loop Pwrs. W Proprietary Notice,Affidavit & Copyright Notice,Encl.Proprietary Info Withheld1999-06-0707 June 1999 Forwards Proprietary & non-proprietary Responses to NRC RAIs Re W TR WCAP-14750, RCS Flow Verification Using Elbow Taps at W 3-Loop Pwrs. W Proprietary Notice,Affidavit & Copyright Notice,Encl.Proprietary Info Withheld L-99-225, Responds to GL 98-01, Yr 2000 Readiness of Computer Sys at Nuclear Power Plants1999-06-0707 June 1999 Responds to GL 98-01, Yr 2000 Readiness of Computer Sys at Nuclear Power Plants ML20195F0621999-06-0707 June 1999 Submits Rev to Unit 2 SG Tube voltage-based Repair Criteria Data Rept.Ltr Contains No Commitments ML20195E9581999-06-0707 June 1999 Responds to GL 98-01, Yr 2000 Readiness of Computer Sys at Nuclear Power Plants ML20195C6941999-05-28028 May 1999 Forwards Response to NRC RAI Re GL 96-05 for Farley Nuclear Plant.Farley Is Committing to Implement Phase 3 of JOG Program L-99-021, Forwards Response to RAI Re Conversion to ITSs for Chapter 3.3.Attachment II Includes Proposed Revs to Previously Submitted LAR Re Rais,Grouped by RAI number.Clean-typed Copies of Affected ITS Pages Not Included1999-05-28028 May 1999 Forwards Response to RAI Re Conversion to ITSs for Chapter 3.3.Attachment II Includes Proposed Revs to Previously Submitted LAR Re Rais,Grouped by RAI number.Clean-typed Copies of Affected ITS Pages Not Included L-99-203, Forwards Response to NRC RAI Re GL 96-05 for Farley Nuclear Plant.Farley Is Committing to Implement Phase 3 of JOG Program1999-05-28028 May 1999 Forwards Response to NRC RAI Re GL 96-05 for Farley Nuclear Plant.Farley Is Committing to Implement Phase 3 of JOG Program ML20195F2101999-05-24024 May 1999 Requests That Farley Nuclear Plant Proprietary Responses to NRC RAI Re W WCAP-14750, RCS Flow Verification Using Elbow Taps at W 3-Loop Pwrs, Be Withheld from Public Disclosure Per 10CFR2.790 L-99-180, Forwards Responses to NRC RAI Questions for Chapter 3.8 of Ts.Proposed Revs to TS Previously Submitted with LAR Related to RAI1999-04-30030 April 1999 Forwards Responses to NRC RAI Questions for Chapter 3.8 of Ts.Proposed Revs to TS Previously Submitted with LAR Related to RAI ML20206F4321999-04-30030 April 1999 Forwards Responses to NRC RAI Questions for Chapter 3.8 of Ts.Proposed Revs to TS Previously Submitted with LAR Related to RAI L-99-017, Forwards Responses to NRC RAI Questions for Chapters 3.1, 3.2,3.5,3.7 & 3.9 of Ts.Attached Pages Include Proposed Revs Previously Submitted LAR to Rais,Grouped by Chapters & RAI Numbers1999-04-30030 April 1999 Forwards Responses to NRC RAI Questions for Chapters 3.1, 3.2,3.5,3.7 & 3.9 of Ts.Attached Pages Include Proposed Revs Previously Submitted LAR to Rais,Grouped by Chapters & RAI Numbers ML20206C8021999-04-26026 April 1999 Forwards 1998 Annual Rept, for Alabama Power Co.Encls Contain Financial Statements for 1998,unaudited Financial Statements for Quarter Ending 990331 & Cash Flow Projections for 990101-991231 05000348/LER-1998-007, Forwards SG-99-04-001, Farley-1:Final Cycle 16 Freespan ODSCC Operational Assessment, as Committed to in Licensee & LER 98-007-00.Util Is Revising Plant Administrative SG Operating Leakage Requirements as Listed1999-04-23023 April 1999 Forwards SG-99-04-001, Farley-1:Final Cycle 16 Freespan ODSCC Operational Assessment, as Committed to in Licensee & LER 98-007-00.Util Is Revising Plant Administrative SG Operating Leakage Requirements as Listed L-99-015, Forwards Rev 1 to Jfnp Security plan,FNP-O-M-99,resulting from Implementation of Biometrics Sys.Changes Incorporate Changes Previously Submitted to NRC as Rev 28 by Licensee .Encl Withheld,Per 10CFR73.211999-04-21021 April 1999 Forwards Rev 1 to Jfnp Security plan,FNP-O-M-99,resulting from Implementation of Biometrics Sys.Changes Incorporate Changes Previously Submitted to NRC as Rev 28 by Licensee .Encl Withheld,Per 10CFR73.21 ML20206B4391999-04-21021 April 1999 Forwards Corrected ITS Markup Pages to Replace Pages in 981201 License Amend Requests for SG Replacement L-99-172, Forwards FNP Annual Radioactive Effluent Release Rept for 1998, IAW TSs Sections 6.9.1.8 & 6.9.1.9.Changes to ODCM Revs 16,17 & 18 Are Encl,Iaw TS Section 6.14.21999-04-21021 April 1999 Forwards FNP Annual Radioactive Effluent Release Rept for 1998, IAW TSs Sections 6.9.1.8 & 6.9.1.9.Changes to ODCM Revs 16,17 & 18 Are Encl,Iaw TS Section 6.14.2 ML20205S9501999-04-21021 April 1999 Forwards FNP Annual Radioactive Effluent Release Rept for 1998, IAW TSs Sections 6.9.1.8 & 6.9.1.9.Changes to ODCM Revs 16,17 & 18 Are Encl,Iaw TS Section 6.14.2 ML20205R0431999-04-13013 April 1999 Forwards Correction to 960212 GL 95-07 180 Day Response. Level 3 Evaluation for Pressure Locking Utilized Analytical Models.Encl Page Has Been Amended to Correct Error 1999-09-23
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D ve Mirey S:uth+,rn Nucint Vice President 0 pirating Comp:ny f arley Project P.O. Box 1295
, Birmingham. Alabama 35201 4 Tel 205.932.5131 SOUTHERN May 28, 1997 COMPANY Enery to Serve YourWorld" Docket Nos.: 50-348 10 CFR 2.201 50-364 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk l Washington, DC 20555 Joseph M. Farley Nuclear Plant Reply To a Notice Of Violation (VIO)
NRC Insnection Report Number 50-348.364/97-04 Ladies and Gentlemen:
l As requested by your transmittal EA 97-130, dated May 6,1997, this letter responds to the following violations:
EA 97-130 VIO 01014," Procedural Inadequacies With Regard to Operation of the t Penetration Room Filtration System."
EA 97-130 VIO 02014, " Failure to Comply With Specific Sections of ANSI N510-1980 in Surveillance Testing of Technical Specification Ventilation Systems."
EA 97-130 VIO 03014, " Failure to identify the Degraded Penetration Room Boundary."
EA 97-130 VIO 04014 " Fuel Movement Within the Spent Fuel Pool Without Meeting Penetration Room Filtration System Technical Specification Requirements."
The Southern Nuclear Operating Company (SNC) responses are provided in the enclosures.
Confirmation I affirm that the responses are true and complete to the best of my knowledge, information, and belief.
Respectfully submitted, l
f NW Dave Morey WAS/ cit: nov97130. doc I
Enclosures 0 I
cc: Mr. L. A. Reyes, Region II Administrator l lllH lIll Mr. J. I. Zimmerman, NRR Project Manager l'll! ,1113,1 I l) 111,NilHlHNI Illiffs,Illlli,Il l
l Mr. T. M. Ross, Plant Sr. Resident inspector 9706040349 970528 PDR ADOCK 05000348-G PDR
l
. ' l 1
i 1
l ENCLOSURE 1 l
Response to EA 97-130 VIO 01014
" Procedural Inadequacies With Regard to Operation of the Penetration Room Filtration System" i
RESPONSE TO EA 97-130 VIO 01014 EA 97-130 VIO 01014, 'Frocedural In Jequacies With Regard to Operation of the Penetration Room Filtration System" states:
A. 10 CFR Part 50, Appendix B, Criterion V, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the above, prior to March 14, 1997, the licensee failed to prescribe documented instructions or procedures to implement the following activities affecting quality with regard to operation of the penetration room filtration (PRF) system:
- 1. Procedural steps to monitor penetratica room-to-atmosphere negative pressure were not prescribed in emergency operating procedures. Monitoring penetration room-to-atmosphere negative pressure is an activity affecting quality in that a negative pressure is required to meet the intended safety function of the system during emergency conditions as described in Final Safety Analysis Report (FSAR) Section 6.2.3.1.2.
FSAR Section 6.2.3.1.2 states, in part, that a function of the PRF system is to maintain a slightly negative pressure within the penetration room and that this negative pressure ensures inleakage to the penetration room, preventing exfiltration of radioactivity to the environment. For example, Step 3 of FNP-1/2-ESP-1.1, Si Termination, directs securing one train of the PRF system (if actuated), but does not direct monitoring the l remaining PRF system train to ensure that it maintains adequate negative penetration room-to-atmosphere differential pressute.
- 2. Prueedural steps to govern operation of the PRF system during recirculation operations were not provided in normal operating, testing, or emergency operating procedures.
Recirculation operation is an activity affecting quality in that instructions for system alignment, testing and emergency operation are needed to implement multipass filtration oflong term containment leakage. Multipass filtration is a function ef the PRF system as described in FSAR Section 6.2 3.2.2. For example, FNP-1/2-STP4124.0, Penetra: ion Room Filtration Performance Test, (STP-124.0), Step 6.3, states that the Penetration Room Filtration System Train to be tested is aligned per FNP-1/2-SOP-l 60.0,(SOP-60.0), Penetration Room Filtration System. However SOP-60.0 does not defme cystem configurations or provide operator guidance for aligtiment for l
l surveillance tests or post-loss of coolant accident (LOCA) system operation in the "recirc mode." STP-124.0 was also inadequate in that Step 7.5 directed operations to start the PRF system train to be tested and align it in the recirculation mode, but did not contain steps that define the recirculation mode or the configuration of the system for the recirculation mode.
- 3. Procedural steps were not prescribed to ensure that the test described in STP-124.0 was run in the sequence required by TS 4.7.8.b.l(a). The sequence of the visual inspection of the PRF system, the Dioctyl-phthalate (DOP) test, and the activated carbon adsorber section leak test is an activity affecting quality in tlat conducting the visual inspection after the DOP or carbon adsorber leak test cm mvahdate the integrity of the PRF system established in the DOP test and the carbm udsorber leak test. Technical Specification (TS) 4.7.8, Penetration Room Filtration System, part b.l(a), states that a El-1 l
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RESPONSE TO EA 97-130 VIO 01014 visual inspection of the penetration room filtration system shall be made before cach DOP test or activated carbon adsorber section leak test in accordance with Section 5 of ANSI N510-1980. As a result, during performance of STP-124.0 on January 25, 1997, the visual inspection of the penetration room filtration system was not conducted prior to the HEPA filter and charcoal filter leak tests as required by TS 4.7.8.b.l(a).
- 4. STP-124.0 did not provide adequate steps to ensure that the test readings of the air flow through the PRF system, as described in Step 7.6 of STP-124.0, were consistently recorded. Obtaining accurate readings of the air flow through the PRF system is an activity affecting quality in that accurate air flow readings are required to determine whether the system meets TS surveillance requirement (SR) 4.7.8. TS SR 4.7.8, Penetration Room Filtration System, part b.3, requires, at least once per 18 months or during other specified conditions, verifying the PRF system flow rate of 5000 cfm +
10% during system operation when tested in accordance with Section 8 of ANSI N510-1980. As a result, several data packages which documented 1995 performances of the flow tests for STP-124.0 had discrepancies in the manner in which the air flow test data was recorded. The discrepancies included transposition errors which resulted in using the incorrect duct size for the calculations.
This is a Severity Level IV violatien (Supplement I).
Admission or Denial
- The violation occurted as described in the Notice of Violation.
i Reason l'or Violation
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I EA 97-130 VIO 01014, item 1:
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- The cause was procedural inadequacy in that FNP's procedures did not provide instructions to i monitor penetration room to atmosphere differential pressure to ensure an adequate negative
!i pressure was maintained.
l EA 97-130 V10 01014, item 2:
.s l The cause was procedural inadequacy in that FNP's surveillance and operating procedures did not j address the steps to define the recirculation mode of PRF.
L i EA 97-130 VIO 01014, item 3:
4 i The cause was procedural inadequacy in that FNP's PRF surveillance test procedure, FNP-1/2-STP-124.0 (STP-124.0), did not clearly specify that the visual inspection of the PRF must be performed prior to the dioctly-phthalate (DOP) test and the charcoal adsorber leak test as required by the FNP Technical Specification.
EA 97-130 VIO 01014, item 4:
The cause was procedural inadequacy in that FNP's surveillance test procedure (STP-124.0) did not provide adequate guidance for recording the system flows. A contributing cause was the duct flow measuring points were not labeled in the field to identify the three system flow paths.
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l Corrective Steps Taken and Results Achieved EA 97-130 VIO 01014, item 1:
An actual condition requiring Phase B actuation has not occurred at FNP. Therefore, no adverse consequences were caused by the procedural inadequacies.
EA 97-130 VIO 01014, Jtem 2- 1 l \
'ne design basis of the PRF system is to maintain the penetration room areas under a negative ,
pressure while operating in the exhaust mode. No credit is taken in accident analyses for I recirculation filtration. Herefore, no adverse condition existed.
EA 97-130 VIO 01014, item 3:
The Unit 1 A Train PRF surveillance test (STP-124.0) was successfully re-performed on February 6,1997.
EA 97-130 VIO 01014, item 4:
FNP recalculated the transposed data and detennined that three of the errors still met the TS acceptance criteria of PRF system flow. The recalculation of the fourth data transposition error, which occurred on December 1,1992, shawed a PRF system flow rate in excess of the TS acceptance criteria upper limit. This excess flow rate was evaluated and it was determined that the original design included sufTicient flow rate margin to maintain the required filter residence time and efficiency with the excess flow rate. In addition, the previous and subsequent tests to the December 1,1992 test were completed satisfactorily and no maintenance that would have afTected i the PRF system flow was performed during that time, i Corrective Steps That Will Be Taken to Avoid Further Violation EA 97-130 VIO 01014, Item 1:
The procedure for Penetration Room Filtration, FNP-1/2-SOP-60.0, was revised to verify an adequate negative pressure when there is any change to the system configuration. Both Units 1 and 2 Emergency Response Procedures were revised to direct the operator to FNP-l/2-SOP-60.0 for PRF operation during an accident. To ensure continued monitoring of the differential pressure, the readings were added to the hourly ECCS logs. These logs are required by EEP-1, " Loss of
, Reactor or Secondary Coolant."
l Emergency operating procedures which secure systems during an accident will be reviewed to l
detennine if guidance is provided in the emergency operating procedures to monitor parameters which could be afTected by securing the system.
EA 97-130 VIO 01014, item 2:
The PRF performance test surveillance procedures were revised to instruct Operations to place the PRF tiain to be tested in operation per FNP-1/2-SOP-60.0. Also, the PRF performance test surveillance procedures were revised to require verification that the system has entered the LOCA recirculation mode by verifying that the recirculation damper has modulated open. FNP-1/2-SOP-60.0 was revised to align the PRF system in the recirculation mode during a LOCA. Both Units 1 El-3 l
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RESPONSE TO EA 97-130 VIO 01014 ,
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.and 2 Emergency Response Procedures were revised to direct the operator to FNP-1/2-SOP-60.0 ;
for PRF operation during an accident. Additionally, surveillance test procedures FNP-1/2-STP- l 20.0, Penetration Room Filtration System Train A(B) Qu'arterly Operability and Valve Inservice !
Test. and FNP-1/2-STP-20.2, Penetration Room Filtration System Train A(B) Monthly Operability Test, wre revised to test the system in the recirculation mode of operation, i EA 97-130 VIO 01014, Jtem 3:
I The PRF surveillance test procedures (STP-124.0) were revised to clarify that the visual inspection shall be performed prior to the DOP and charcoal adsorber leak tests. Also, the Control Room I Emergency Filtration System and Containment Purge Exhaust Filter System surveillance test :
procedures will be enhanced to clarify that the visual inspection shall be performed prior to the l l DOP and charcoal adsorber leak tests. !
Also, the Control Room Emergency Filtration System and the Containment Purge Exhaust Filter j System surveillance test procedures will be enhanced to clarify that the visual inspection must be performed prior to the DOP and charcoal adsorber leak tests.
EA 97-130 VIO 01014, Jtem 4: !
FNP revised the PRF surveillance test procedure (STP-124.0) to clarify the data sheets to be used for recording the system flow data. FNP also applied labels to the PRF test ports to clearly Mentify the function of each test port. The Control Room Emergency Filtration System surveillance test procedure has also been revised to clarify the data sheets used for recording system flow data. I l
Date of Full Compliance June 30,1997 l I i
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i ENCLOSURE 2 .
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Response to EA 97-130 VIO 02014
" Failure to Comply With Specific Sections of ANSI N510-1980 in '
Surveillance Testine of Technical Snecification Ventilation Systems" I
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RESPONSE TO EA 97-130 VIO 02014 EA 97-130 VIO 02014, 'Faih.re to Comply With Specific Sections of ANSI N510-1980 in Surveillance Testing of Technical Specification Ventilation Systems" states: ;
B. TS surveillance requirement (SR) 4.7.8, Penetration Room Filtration System, part b.3, requires, at least once per 18 months or during other specified conditions, verifying the PRF system flow rate of 5000 cfm + 10% during system operation when tested in accordance with Section 8 of ANSI N510-1980.
ANSI N510-1980, Testing of Nuclear Air-Cleaning Systems, Section 8.3.1, Airflow Capacity Test, steps 8.3.1.6 and 8.3.1.7, describe performing " dirty filter" flow tests as part of the ;
Section 8 airflow capacity test. i TS SR 4.7.8.b.l.a requires a visual inspection of PRF system filters in accordance with Section 5 of ANSI N510-1980 every 18 months; and TS SR 4.7.8.d.3 requires PRF system heater testing in accordance with Section 14 of ANSI N510-1980 cvery 18 months.
TS SR 4.7.7.1, Control Room Emergency Filtration System (CREFS), requires visual filter inspections in accordance with Section 5 of ANSI N510-1980, system flow verifications in accordance with Section 8 of ANSI N510-1980, and pressurization system heater testing in accordance with Section 14 of ANSI N510-1980 cvery 18 months. ,
TS SR 4.9.14 requires a visual inspection of the Containment Purge exhaust filter in accordance with Section 5 of ANSI N510-1980 every 18 months.
Contrary to the above, between plant licensing and January 28,1997, the licensee failed to test PRF system operation in accordance with Section 8 of ANSI N510-1980. Specifically, system flow rate testing did not include " dirty filter" flow tests as described by ANSI N510-1980, Section 8. In addition, on February 23,1997, the licensee determined that surveillance testing to demonstrate compliance with TS Surveillance Requirements 4.7.7.1,4.7.8, and 4.9.14 was inadequate in that Section 8 " dirty filter" testing for CREFS, and other parts of ANSI N510-
'1980 Sections 5 and 14 for CREFS, the PRF system, and Containment Purge exhaust, were not included in their surveillance test program.
This is a Severity Level IV violation (Supplement I).
Admission or Denial The violation occurred as described in the Notice of Violation.
Reason for Violation The cause of the inadequate surveillance testing of ESF ventilation systems was cognitive personnel error in that, during 1984, when the FNP TS were revised to incorporate the latest industry standard tes*ing sequirements, FNP personnel incorrectly concluded that the standards were provided for technical guidance as opposed to verbatim requirements.
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' RESPONSE TO EA 97-130 VIO 02014 l QLrrective Steps Taken and Results Achieved .
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! FNP performed detailed evaluations of the incomplete performance of ANSI N510-1980, sections 5, 8
- and 14, using the guidance provided in GL 91-18 as a guideline for nonconforming conditions FNP i determined that the systems were operable per GL 91-18 but were in a nonconforming condition due to .I
{ ' the incomplete performance of some visual inspections and the dirty filter tests. The Control Room )
3 Emergency Filtration / Pressurization System, Penetration Room Filtration System, and Containment l Purge Exhaust Filter System are capable of performing their specified functions without completion of all ANSI N510-1980 testing and inspection requirements.
Although these systems were able to perform their specified functions, both trains of the Control Room )
Emergency Filtration / Pressurization System and both trains of the Penetration Room Filtration System j on Units I and 2 were declared inoperable due to surveillance not being completed. The Containment !
Purge Exhaust Filter System was not affected at this time due to both units being in a mode in which the Containment Purge Exhaust Filter System was not required to be operable. With both trains of the Control Room Emergency Filtration / Pressurization System and the Penetration Room Filtration System inoperable, FNP entered TS 3.0.3 for both units. NRC granted enforcement discretion and TS 3.0.3 '
was exited.
l FNP took prompt action to resolve this issue by submitting a technical specification amendment request and performing additional testing and inspections, where possible, to satisfy the literal requirements of ANSI N510-1980 sections 5,8 and 14. ;
. Corrective Steps That Will Be Taken to Avoid Further Violation FNP received the technical specification amendment, issued May 1,1997,- and revised appropriate procedures relating to the Control lloom Emergency Filtration, Penetration Room Filtration, and Containment Purge Exhaust Filter syctems to comply with the technical specification amendment. FNP is currently in compliance with the TS amendment.
Date of Full Compliance May 23,1997 E2-2 i l
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1 ENCLOSURE 3 Response to EA 97-130 VIO 03014
" Failure to Identify the Decraded Penetration Room Boundary" P
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RESPONSE TO EA 97-130 VIO 03014 l
l EA 97-130 VIO 03014, " Failure to Identify the Degraded Penetration Room Boundary" states:
C. 10 CFR 50, Appendix B, Criterion XVI, and the J. M. Farley Plant Operations Quality Assurance Policy Manual, states, in part, that measures shall be established to assure that l conditions adverse to quality are promptly identified and corrected. In the case of significant l conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
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! FSAR section 6.2.3.1.2 describes the criteria used to determine PRF system design flow rates.
It states, "The exhaust flow rate is equivalent to the penetration room boundary inleakage; i.e.,
the sum of all possible inleakages when a pressure of -1.5 in. wg [ inches water gauge] is maintained within the penetration room boundary " Furthermore, it states, "for estimating the exhaust fan capacity, it has been conservatively assumed that, with a -1.5 inches wg pressure, the inicakage is 100 percent of the penetration room volume per day. This inleakage is equivalent to 250 scfm "
FSAR section 6.2.3.3.2, states, "The penetration rooms are maintained at a pressure of-0.5 to -
1.5 in. wg with only the exhaust fan operating. If the recirculation fan were to remain in operation in the exhaust mode, the pressure in the penetration rooms could be maintained at -3.0 in. wg."
FNP-1/2-STP-20.0, Penetration Room Filtration System Train A(B) Operability Test, Page 5, Note, described desired system performance of the PRF system upon switchover from the pure exhau3t mode to recirculation operation including system operation with the recirculation fan in operation in the exhaust mode. The Note directs operators, that if the PRF system does not function in the manner described in the Note, to investigate and initiate corrective action if corrective action is required.
Contrary to the above, as of January 25,1997, the licensee had failed to establish measures to assure that a significant condition adverse to quality was promptly identified and corrected.
Specifically, the licensee failed to identify that the penetration room boundary had degraded such that inleakage was greater than 4000 scfm on Unit I and greater than 2000 scfm on Unit 2, which was in excess of the 250 scfm described in the FSAR. As a result, neither unit's PRF system was capable of maintaining -0.5 to -1.5 inches wg with only the exhaust fan running and Unit I could not maintain -3.0 inches wg in the penetration rooms with the recirculation fan also in the exhaust mode as described in FSAR Section 6.2.3.3.2. Furthermore, the licensee failed to obtain necessary data in the configurations described in STP-20.0 to determine if system performance warranted an investigation and initiation of corrective action.
This is a Severity Level IV violation (Supplement I).
Admission or Denial The violation occurred as described in the Notice of Violation.
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RESPONSE TO EA 97-130 VIO 03014
' Reason for Violation The cause of the failure to recognize and correct the degraded Penetration Room boundary was procedural inadequacy. The applicable surveillance test procedures did not specifically require the
, verification of adequate Penetration Room negative pressure as an acceptance criteria. A Note in these i procedures was intended to accomplish the serification of adequate negative pressure but investigation
. determined that this Note was being consistently misapplied such that degradation of the Penetration Room boundary was not being identified.
I Corrective Steps Taken and Results Achieved Repairs have been performed on the boundaries of both Unit's Penetration Rooms which has :
significantly reduced the air inleakage.
l i Corrective Steps That Will Be Taken to Avoid Further Violation .
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Th- PRF surveillance procedures for both Units have been changed to require verification of adequate negative pressure in the Penetration Rooms in the modes of operation described in the FSAR. This j
. verification is now a signoff requirement. Guidance is also provided to initiate corrective action ifit is ;
determined that the Penetration Room boundaiy has degraded. j i
Operations personnel will be trained on the procedural requirements to verify proper negative pressure
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in the Penetration Room and to initiate corrective action if the Penetration Room boundary has 1 degraded.
Date of Full Compliance l
June 30,1997 i
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l ENCLOSURE 4 1
Response to EA 97-130 VIO 04014 I
" Fuel Movement Within the Spent Fuel Pool Without Meeting Penetration Room Filtration System Technical Snecification Requirements" l l
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.j l RESPONSE TO EA 97-130 VIO 04014 l EA 97-130 VIO 04014, " Fuel Movement Within the Spent Fuel Pool Without Meeting Penetration Room Filtration System Technical Specification Requirements" states:
l D. TS 3.9.13 requires that two indepen'eut pene+ ration room filtration systems (Specification ,
3.7.8) shall be OPERABLE and aligned to the spent fuel pool room during crane operation with loads, over the fuel in the spent fuel pit and during fuel movement within the spent fuel pit.
l Contrary to the above, on October 31,1996, the licensee performed fuel movement within the j
- Unit 2 spent fuel pit with the A train Penetration Room Filtration (PRF) system inoperable and I the B train PRF not aligned to the spent fuel pool room.
This is a Severity Level IV violation (Supplement 1).
Admission or Denial The violation occurred as described in the Notice of Violation. ;
Reason for Violation i l
l The cause of this event was cognitive personnel error in that SNC personnel incorrectly interpreted l TS requirements by the misapplication of TS 3/4.8.1.2 to TS 3/4.9.13. !
I Corrective Steps Taken and Results Achieved 1
SNC promptly revised their interpretation of the Technical Specifications to comply with the NRC l position. The 1997 Unit I outage was planned to comply with the new interpretation.
1 l Corrective Steps That Will Be Taken to Avoid Further Violation I
Future refuchng outages will be planned and implemented consistent with the current interpretation of the TS requirements for PRF operability in Modes 5 & 6.
- Date of Full Compliance March 6,1997 2 1
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