ML20059B214
| ML20059B214 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 12/21/1993 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-REGGD-01.033, RTR-REGGD-1.033 NUDOCS 9401040035 | |
| Download: ML20059B214 (8) | |
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Soutnem Nuclear Operatng Company Post Off ce Box 1295 i Birmingham, A!acama 35201 i Telephone (205) 860-5131 l L '
oo. uor.y Southem Nudear Operating Company ~
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December 21, 1993 Docket Nos.: 50-348 10CFR2.201 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 (NO")
NRC Inspection Report Nos. 50-348/93-26 and 50-364/93-26 Gentlemen:
This letter responds to the violation (NOV-50-[348/364]/93-26-01) as cited in the subject NRC inspection report. The violation therein states:
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 mnintained. Regulatory Guide 1.33 requires procedures for the conduct of operations, equipment control and tagging, and maintenance.
- 1. Administrative Procedure AP-85, Conduct of Operations - Electrical Maintenance Group, Revision 0, Step 7.5.1, states,in part, that a complete and concise description of work shall be provided and this should include the identification of all parts that are removed.
- 2. Administrative Procedure FNP-0-AP-52 Equipment Status Control and Maintenance Authorization, Revision 21;
- a. Step 6.1 states,in part, that job planners will provide job sequence planning which will include applicable procedures and identification oflimiting conditions of operations. -
- b. Step 7.4.2 states,in part, that a determination oflimiting conditions for operation is required in the preparation of maintenance work requests. ;
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9401040035 931221 E
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U.S. Nuclear Regulatory Commission Page 2
- c. Step 7.5.17 states,in part, that the designated group supervisor responsible for accomplishment of work will review the maintenance work request for correct information and work sequence.
- d. Step 7.7.1 states that the maintenance individual performing the work shall follow ,
the specified work sequence. If, during the conduct of maintenance, the worker finds that the work sequence does not adequately delineate the activities -
which must be performed to accomplish the maintenance, the work sequence shall -
be revised and "reapproved".
- 3. Administrative Procedure, FNP-0-AP-14, Safety Clearance and Tagging, Revision 13;
- a. Step 7.8.1 states,in part, that the preparer of the tag order will carefully evaluate the work to be performed and that the preparer will develop positioning actions to assure proper isolation.
- h. Step 7.11 states, in part, that the reviewer of the tag order will use the same process as the preparer to determine the adequacy of the technical content within the order.
- c. Step 7.14 states,in part, that the tagging ofTicial will carefully review the tag order to assure that execution of the order is acceptable with regard to its effect on plant status.
- d. Step 7.21 states,in part, that the approval authority will carefully review the tag order to assure that execution of the order is acceptable with regard to its elTect on plant status.
- 4. Maintenance Procedure FNP-0-M-64, Writers Guide for Maintenance Procedures, Revision 3;
- a. " Referencing" section, states,in part, that procedures should be written so steps can
, be performed without obtaining additionalinformation from persons / documents. 1
- b. " Component Identification" section, states,in part, that in-plant components should be identitled in the procedure when the subject component is used -
b; frequently, has poor access, or is not labeled.
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l U.S. Nuclear Regulatory Commission Page 3 Contrary to the above:
- a. On September 23, the shift supervisor received and approved a deficient maintenance work request (MWR) for repairs to the "A" train control room air conditioning (A/C) system. The planner for the work package did not list the I
removal of the A/C panel as required per Step 7.5.1 of Procedure AP-85, nor did he give proper consideration to maintaining the control room pressurization boundary per Steps 6.1 and 7.4.2 of Procedure FNP-0-AP-52. Additionally, the craft .
j supervisor did not do an appropriate review of the MWR per Step 7.5.17, and the craft personnel pederming the work performed work not specified in the MWR when the A/C panel was removed rather than seek help and a revised MWR per Step 7.7.1. This inadequately planned, unauthorized removal of the A/C panel and the existence of open fire dampers resulted in a breach of the control room pressurization boundary for approximately 46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br />.
- b. On September 23, while performing MOVATS testing ofisolation valve (Q2P16MOV3130B), isolation valve (Q2P16MOV3130A) was erroneously stroked shut due to the subject MOVATS testing procedure data sheet which identified the wrong plant component (valve Q2P16MOV3130A) for the installation of jumper cables. Procedure FNP-0-M-64 requires that maintenance procedures correctly identify in-plant components and be written so steps can be performed without obtaining additionalinformation from other personal or documents. This event was caused by an engineer who incorrectly transcribed the wrong valve number from plant drawings to the MOVATS testing procedure data sheet which was a work sequence not requiring independent review.
- c. On October 5, a modified tag order for tag-out No. 93-2531-2 was prepared and three reviewing Senior Reactor Operator licensed personnel failed to assure that the development and execution of that order was acceptable with regard to its effect on plant status as required by Procedure FNP-0-AP-14, Steps 7.8.1,7.11,7.14, and 7.21. Consequently, this discrepant order resulted in an improper valve lineup that ,
isolated component coolbg water flow to the in-service "2A" spent fuel pool (SFP) heat exchanger allowing the SFP temperature to rise about 40 degrees F in a 3-hour period before being found and corrected.
This is a Severity LevelIV violation (Supplement I)
The Southern Nuclear Operating Company (SNC) response to this notice of violation (NOV)is provided in the Attachment to this letter and addresses each of the three referenced events.
I f U.S. Nuclear Regulatory Commission Page 4 1
Confirmation I affirm that the response is true and complete to the best of my knowledge, information and belief.
Respectfully submitted, SOUTHERN N'UCLEAR OPERATING COMPANY Q 4L;> ' i Dave Morey s t REM /sar:93-26. DOC Attachment cc: Mr. S. D. Ebneter Mr. B. L. Siegel Mr. T. M. Ross 6 Y
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' Reply to a Notice of. Violation I
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. 1 Reply to a Notice of Violation Admission or Denial The violation occ irred as described in Inspection Report 93-26 for each of the three specific events.
Reason for Violatiog Each of the three specific events will be discussed individually. 1 i A. CONTROL ROOM PRESSURIZATION CAPABILITY Personnel error was the cause in that planning did not identify the interference (panels) which had to be removed to work on the condenser. Therefore, the effect of removing the interference was not evaluated as it should have been. B. SERVICE WATER TO 2A CCW ISOLATION VALVE (MOV 3130A) Personnel error was the cause in that incorrect termination point data was transferred from the drawing to the data sheet. The review / approval of the work package did not catch the preparer's error. C. SPENT FUEL POOL COOLING The shift supervision did not confirm which CCW Heat Exchanger was on service. The tagging order was incorrectly prepared and improperly reviewed. Inadequate communications between supervision and the plant operators was a contributor in that the specific heat exchanger to be isolated was not discussed. Corrective Action Taken and Results Achieved Each of the three specific events will be discussed individually. A. CONTROL ROOM PRESSURIZATION CAPABILITY l Work on the condenser was stopped and the panels were re-installed in approximately 30 minutes. This restored the integrity of the Control Room.
- ... q Attachment Page 2 B. SERVICE WATER TO 2A CCW. ISOLATION VALVE (MOV 3130A) .)
Within approximately 3 minutes, Control Room personnel had been notified, the jumpers were removed, and the MOV 3130A valve was reopened. Closing of MOV 3130A had no adverse effect on plant equipment because it was on the off-service heat exchanger. C. SPENT FUEL POOL COOLING The lack of SFP cooling was identified when the main Control Room alarm for high SFP temperature annunciated at 130 F. In addition, personnel in the SFP area notified the Control Room that the SFP area seemed brJ and the humidity was high. The tagging order was cleared and the cooling alignment was returned to normal. Corrective Steps to Avoid Further Violations Each of the three specific events will be discussed individually. A. CONTRO:. ROOM PRESSURIZATION CAPABILITY 91anning was strengthened for the control room pressurization system by including opplicable information in the component data base which is used for identifying work onstraints. I l The A/C unit housing was labeled to identify it as a Control Room pressure boundary. I Planners were re-instructed to identify interference removal and consider the effects of the l removal in the planning of job sequences. A meeting was held with FNP and contractor supervisors to discuss the event, causes, and lessons learned. A summary of the event was provided, and then discussed with their personnel in individual work groups. B. SERVICE WATER TO 2A CCW ISOLATION VALVE (MOV 3130A) l This event was discussed with personnel involved as well as the entire ! . .intenance
!- Department.
Work on MOVs was stopped until the event was discussed with the personnel involved. In addition, other outage MOV work packages were reviewed prior to continuing work.
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J _ Attachment Page 3 ' This event was determined to be isolated; however, the procedure for MOV testing was revised as an enhancement. t Li A meeting was held with FNP and contractor supervisors to discuss the event, causes, and . lessons learned. A summary of the event was provided, and then discussed with their personnel in individual work groups. C. SPENT FUEL POOL COOLING The supervisory personnel involved were removed from shift duties. The personnel were - disciplined, retrained, and had to pass an exam prior to being returned to normal shift duties. A meeting was held with FNP and contractor Lupervisors to discuss the event, causes, and - lessons learned. A summary of the event was provided, and then discussed with their personnel in individual work groups. GENERAL ACTIONS TO REDUCE PERSONNEL ERRORS To strengthen efforts at reducing personnel errors, the following actions will be taken: , Broaden focus of the STAR Program to emphasize the preparation ans planning aspects of work such as the procedure writer, the planner, and personnel that piepare tagging orders. Reinforce management up ' aons to employees so that decisions will be made in alignment with these expectations. Re-evaluate established barriers for prevention of errors to ensure that the original purpose of the STAR program is still being met. Improve the feedback between the planners and the implementing individuals so that any problems with MWR planning can be corrected to minimize future challenges to the Control Room, or the workers. Date of Full Compliance All corrective actions stated above have been completed with the exception of those listed under Co_rrective Steps to Avoid Further Vichtions. " General Actions to Reduce Personnel Errors." These actions will be corepleted by Jul t -),1994. ,
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