ML20071C394

Responds to Violations Noted in IE Insp Rept 50-364/82-25. Corrective Actions:Locked Valves Verified by Physical Valve Movement & Valve Verification Instruction Validated

ML20071C394
Person / Time
Site:	Farley
Issue date:	02/22/1983
From:	Clayton F ALABAMA POWER CO.
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8303020027
Download: ML20071C394 (6)

Text

-

c-Ma:Hng Address j

. Alibama Power Company 600 North 18th Street

- Post Office Box 2641 Birmingham, Alabama 35291

• Telephone 205 783-6081 F. L Clayton, Jr.

Nn"Ad But g AlalX1llla POWCf rm aranewrc m m February 22, 1983 Docket No. 50-364 Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D. C. 20555

SUBJECT:

J. M. Farley Nuclear Plant NRC Inspection Of October 28 - November 2, 1982 RE: Report No. 50-364/82-25

Dear Sir:

This letter is submitted in response to the violation in the subject inspection report which states: "On October 28, 1982, the licensee notified the NRC Senior Resident Inspector at the Farley Nuclear Plant and NRC Region II that the containment spray header isolation valves in each of the two supply headers had been found by the licensee to be improperly locked in the closed position.

On October 28 - November 2, 1982, the Senior Resident Inspector conducted a special inspection to determine the facts relating to the incident. The inspection revealed that the valves probably had been closed since the startup of Unit 2 on May 5,1981.

The inspection findings indicate that because of an unusually long valve stem on the containment spray header isolation valves, operations personnel mistakenly believed the valves to be open when they were visually checked for correct positioning. The failure to confirm valve position and reliance on valve appearance indicates a failure to exercise the meticulous attention to detail which the NRC expects of its licensees. Therefore, the Nuclear Regulatory Commission proposes to impose a civil penalty in the amount of Forty Thousand Dollars for this matter. In accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C, 47 FR 9987, March 9, 1982), and pursuant to Section 234 of the Atomic Energy Act of 1954, as amended ("Act"), 42 U.S.C. 2282, PL 96-295, and 10 CFR 2.205, the particular violation and associated civil penalty is set forth below:

O h 0 TCr'Y

. Report No. 50-364/82-25 February 22, 1983 Page 2 Technical Specification 3.0.4 states that entry into an operational mode shall not be made unless limiting conditions for operation have been satisfied without recours.e to action statements.

Technical Specification 3.6.2.1 states that two independent containment spray systems shall be operable when the reactor is in Modes 1, 2, 3 and 4. Contrary to the above, on at least one occasion between May 5,1981 and October 22, 1982, the licensee entered an operational mode, and operated the reactor, without having satisfied the limiting condition for operation requiring operability of two independent containment spray systems. During this period, closed isolation valves in the containment spray header rendered both systems inoperable."

I. Admission or Denial The above vionation occurred as described in the subject report.

II. Reason for Violation The violation cited in the NRC Inspection Repurt was the result of a procedural inadequacy in combination with the valves not being in conformance with design drawings. The subject valves had been closed during the final days of startup testing, prior to initial fuel loading. The valves were closed at this time as a precaution against inadvertent spray actuottan during final testing. Subsequently, position verification of locked open valves consisted of visual verification that the valve stem was fully extended anri verification that the locking device was securely locked and in good condition. Contrary to the design drawings indicating that the valve stem would be flush with the handwheel when the valve is closed; the valve stem extended approximately six (6) inches above the handwheel when in the closed position. Therefore, when visual verification of these valves were made, the valves appeared to be in the o,)en position and were noted as such.

III. Corrective Actions Taken and Results Achieved The following corrective measures have been or will be taken in conjunction with this event.

1) Verified by physical movement that the corresponding valves on Unit I were locked open. (Completed 10/28/82)

2) Verified all other accessible locked valves by physical valve movement. (Completed 10/28/82)

3) Provided temporary change to procedure to require verifying valve position of locked valves es follows:

o .

Report No. 50-364/82-25 February 22, 1983 Page 3 Locked Closed - Attempt to move handwheel or operator in the closed direction. If valve is in the correct position, no motion will occur. If unable to move the operator because of the locking device, remove the locking device and attempt to move the operator in the closed direction.

Re-install the locking device and verify that it is securely locked and in good condition.

If the locking device was unlocked a second verification of the locking device installation is required.

Locked Open - Attempt to move handwheel or operator in the closed position only enough to verify valve movement. The handwheel or operator should turn, indicating the valve is open. Return valve to original position. If unable to move the operator due to the locking device, remove the locking device and attempt to move the operator, or handwheel in the closed direction only enough to verify valve movement. Return valve to original position. Re-install the locking device and verify that it is securely locked in good condition. If the locking device was unlocked, a second verification of the locking device installation is required.

A fourth step in the verification sequence has been added for locked valves in which the locking device is verified to be properly secured and locked if the valve was unlocked to verify position. (Completed 10/28/82) l

4) Conducted extensive investigation to determine all possible opportunities for this valve to be operated.

(Completed 11/5/82) l 5) Conducted investigation to determine why the valve stem was l

longer than the design drawing specifications.

l (Completed 11/18/82)

6) Performed design change to modify valve stem length so that it is flush with valve operator when the valve is shut.

(Completed 11/18/82)

7) Performed validation of valve verification instruction.

(Completed 12/28/82)

8) Validation findings have been incorporated into valve verification instructions and will te approved 3/1/83.

heport No. 50-364/82-25 February 22,-1983 ~

Page 4

9) Developed training for Operations Personnel to insure that they have increased awareness and a feel for pitfalls.with valve operations. - (Completed 12/28/82)

IV. Corrective Steps Taken to Avoid Further Violations See Item III.

V. Date of Full Compliance Immediate corrective action to achieve compliance was completed October 28, 1982. Followup corrective action to ensure continued compliance will be completed by March 1,1983.

Affirmation With regard to the above violation, I affirm that this response is-true and correct to the best _ of my knowledge, information and belief.

The information contained in this letter is not considered to be of a proprietary nature.

Enclosed is payment of the proposed civil penalty in the form of a check to-the Treasurer of. the United States for Forty Thousand Dollars

($40,000).

Sincerely yours, I

l . L. Clayton, gir.

FLCJr/KWM:cb Enclosure

, xc: Director, RII l File

Stock

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Form Ii14\.

October 196' y I

oc s Tide 7. G AO Manut in4-io6

' BILL FOR COLLECTION Bill No.

U. S. I!uclear Reoulatory Condission Date Feb. ,20.1933 (Department or Establishment and Bureau or Omce)

Washinator,. DC 20555 (Address)

PA YER:

Alabama Power Company.

P.O. Box 2641 This sitt shoute 6< retura<a by <A<

Birmingham,.AL 33291 -

pa><r wieA Als r<=itrau<.

SEE INSTRilCTIONS BELOIV.

Date DESCRIPTION "U **

Quantity amount Cost Per ,

2/2G/03 Received from Docket !!o. 50-3G4 payment $40,000 .00 for CP dated February 2, 1983

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A.\lOUNT DUE Tills BILL, S 40,00G.00 This is not a receipt INSTilUCTIONS Trniter of pas ment of the alxnr bill may be made in cash. Uniini States postal money order, express monev order, bank draft. or check, to the othre indicaird. Such tender, when in ans other form than rash, shoulti he draw n to the order of the Department or Establishment an i llurrau or ( >itu r imiiratnl alan c.

Rn ripts will be issued in all raars w here " rash" is rre ened, azul only utmn requc>i w hen remittance is in any other form. If tender of pas ment of thn hill is usher than i ash or l'nited Stairs postal mones order, the rn ript shall not hn ome an acquittance until such tender has been . lcared and the amount rn ris ed hv the 1)cpartment or F.stabinhment anil Ilureau or Ollie r indicated above.

Fadure to rn ene a rn npt lor a iash pavment shoubt im promptiv reported hv the pascr to the chief asiministrative officer of the burrau or at:rm v menin.ned ahin r.

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.... CIVIL .PENALTY: EA-82-137 REPORT NO. 50-364/82-25 BEVERC% JONES i R00s.S-300 ,' , ,

FLINTRIDGE Bt>I,hDING 1

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I WE HEREWITH TEN ChMbK_ IN FULL PAYMENT OF YOUR INVOIC E S LISTED HEREON OR OTHER CLAIMS DESCRIBED HEREON EN.

DORSEMENT CF AT M A D CHECK IS SUFFICIENT R EC ElPT. IF AMOUNT IS INCORRECT. PLEASE R ETU RN STATEMENT WITH CHECK ATTACHED.

DETACH CHECK BEFORE DEPOSITING.

l l AlanurA POWER COMPANY

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