ML20055D100

Responds to Violations Noted in Insp Repts 50-348/90-12 & 50-364/90-12 on 900411-0510.Corrective Actions:Electrolyte Level Raised in Lights Identified by Inspector to Have Low Electrolyte Level

ML20055D100
Person / Time
Site:	Farley
Issue date:	06/26/1990
From:	Hairston W GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9007030214
Download: ML20055D100 (3)

Text

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.*,- t*= Alab:ma Power Company-40 inverress Centtr Parkw:y e" ' Post Office Box 1205  :

- Dirmin0 ham, Alabama 35201 - "

' Telephone 205 068 5581 1

W. G. Hairston,111 ,

Senior Vice President #

Nuclear Operations

~ /\labama Pbwer the southem ekctnc system June 26, 1990

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E Docket Nos. 50-348

• l 50-364

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U. S. Nuclear Regulatory Commission

' Attention: Document Control Desk

,- Washington, D. C. 20555 1

SUBJECT:

Reply to the Notice of Violation -

J. M. Farley Nuclear Plant NRC Inspection of L-- April 11 - May 10, 1990 RE: Report Numbers 50-348/90-12 and 50-364/90-12 Gentlemen:

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I E This letter refers to'the violation cited in the subject inspection reports -l which states:

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~" Technical Specification 6.6.1 requires that applicable written procedures 1 i - recomended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2,1978 and )

Fire Protection Program implementation shall be established, implemented, and maintained. -Section 9 of RG 1.33 specifies that maintenance that.can affect- q' the performance of safety-related equipment should be properly. performed in  ;

t ~accordance with procedures or drawings appropriate to the circumstances. (

L FSAR Section 9B.6 states that periodic inspections and tests of etaergency j' lighting system are performed to assure that this equipment will perform L satisfactorily to meet its design intent. FSAR Table 9B'7 states that emergency lighting (except containment) will be tested annually. l Contrary to the above, these requirements were not met in that:

(a) The emergency DC lighting for the control room complex supplied from the station batteries is tested at 18 month interval in if eu of annually.

(b) The procedures for maintaining emergency ligh' ting, 1/2-EMP-1381.01, do not'specify the 8-hour individual self.-contained battery pack emergency lighting units to receive the vendor required 2-hour or 8-hour operability tests. Also the procedures do not specify that the battery cells have their levels checked on the monthly frequency, required by the vendor's manual. As a result, ; least 10% of the 8-hour individual self-contained battery packs were found to have low electrolyte levels and one was fo nd not to remain illuminated, when -

inspected, b 9007030214 900626 PDR ADOCK 05000348 gp(

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U. S. Nuclear Regulatory Commission June 26, 1990 Page 2  ;

W is is a Severity Level IV violation (supplement 1)."

Admission or Denial

-(a). Alabama Power Company denies this part of the violation concerning annual testing of control roan DC lighting..

(b) Alabama. Power Company admits that the testing of the self contained  :

battery p6cks was not sufficient to ensure that the emergency lights:

would perform properly.; However, Alabama Power Company does not 1 consider the inclusion of all vendor recommendations into procedures as a requirement of RG 1.33.

Reason,for Denial (Part (a)]

(a) FSAR Section 9B.6.1 states that Table 9B-7 presents a typical list of fire surveillance procedures. Item 40.0 of this table is " Emergency lighting (except containment) .- annually." This item was included in the table to demonstrate that battery pack emergency lights are tested in conjunction with Appendix R. This t'esting is performed at '

FNP by procedures FNP-1/2-EMP-1381.01.

The control room emergency lights are not oattery pack lights, rather they are powered from the 125 volt vital O.C. buses. The emergency lighting for the control room is describt:d in nection 9.5.3.3 of the FSAR.

No testing requirements are delineated la the PTAR for the control room-emergency lights, howevar, testing of these lights is performed '

by FNP-1-STP-150.10.1 This test has been performed at least every 18.

months and has been demonstrated, since 1982, to have been sufficient to confirm the-adequacy of this surveillance interval. i L

Reason for Violation [Part;(b))

(b) Personnel error - The frequency and r, cope of the testing was not adequate.

Corrective Action Taken and Aesults Achieved i

(a) ' . Not applicable. '

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(b) The electrolyte level has been raised in those lights identified by the [

4 inspecter to have low electrolyte level. The inoperable light identified s by the inspector has been repaired. 'Other Appendix R erurgency light a battery packs will be inspected for proper electrolyte level by August 31, 1990.

,C,orrective Steps To, Avoid Further Violatiens ,

(a) Not applicable.

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(b) The preventive maintenance program for Appendix R emergency lights will ,

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U. S. Nuclear Regulatory Corraission June 26, 1990 Page 3 E

be evaluated to ensure the frequency and scope of the testing performed is adequate to maintain the emergency lights in an operable condition.

Date of Full Compliance August 31, 1990 Affirmation I affirm that this response is true and complete to tne best of my knowledge, informa' ion and belief. The information contained in this letter is not considered to be of a proprietary nature.

Respectfully submitted, ALABAMA POWER COMPAtW tt .s /S. 1 h W. G. Hairston, III WGHiemb-5.17 cc: Mr. S. D. Ebneter Mr. S. T. Hoffman Mr. G. F. Maxwell 5

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