IR 05000348/1982008
| ML20054K185 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 04/22/1982 |
| From: | Robert Lewis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Mcdonald R ALABAMA POWER CO. |
| Shared Package | |
| ML20054K168 | List: |
| References | |
| NUDOCS 8207010276 | |
| Download: ML20054K185 (10) | |
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.1# NUCLEAR REGULATORY COMMISSION REGION ll 101 MARIETTA ST., N.W., SUITE 3100 g*****,/ ATLANTA, GEORGIA 30303 APR 2 21982 '
Alabama Power Company
..,c ATTN: Mr. R. P. Mcdonald ,.
Vice President-Nuclear Generation . P. O. Box 2641 Birmingham, AL 35291 Gentlemen: Subject: Report Nos 8 M d 50-364/82-07 Systemmatic Assessment of Licensee Performance (SALP) Board Report for Your Farley Plants - The NRC SALP Board met on September 10, 1981 to evaluate the performance of the subject facilities for the period July 1, 1980 through June 30, 198 The results of this meeting are documented in the enclosed SALP Board Report. This , evaluation was discussed with you at your offices in Birmingham on September 30, 198 The performance of your facilities was evaluated in the following functional areas: plant operations; refueling operations; maintenance; surveillance and inservice testing; personnel, training and plant procedures; fire protection and housekeeping; design changes and modifications; radiation protection, radioactive waste management and transportation; environmental protection, emergency pre-paredness; security and safeguards; audits, reviews, and committee activities; QA; administrative, and records; and corrective actions and reporting. Unit 2 was also evaluated in the areas of plant operations preparation; fuel loading preparation; preoperational testing; electrical systems; and preservice in-spectio The SALP Board evaluation process consists of categorizing performance in each functional are The categories which we have used to evaluate the performance of your facilities are defined in section II of the enclosed SALP Board repor As you are aware, the NRC has changed the policy for the conduct of the SALP program based on our experiences and the recently implemented reorganization which emphasizes the regionalization of the NRC staf This report is the product of the revised policy. It was prepared in the transition period between the old and the new SALP programs and accordingly is different from last years' SALP Report and will be dif t t, ent f rom future SALP Report . 8207010276 820618 PDR ADOCK 05000348 P PDR
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b d Alabama Power Company 3 Comments which you may submit at your option, are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-51 Should you have any questions concerning this letter, we will be glad to discuss them with yo
Sincerely, R. C. Lewis, Director, Division of Project and Resident Programs Region II SALP Board Chairman cc w/ enc 1: W. G. Hairston, III, Plant Manager cc w/o encl: W. O. Whitt, Executive Vice President F. L. Clayton, Jr. , Senior Vice President J. W. McGowan, Manager-Safety Audit and Engineering Review H. O. Thrash, General Manager-Nuclear Generation 0. D. Kingsley, Jr. , Manager, Nuclear Engineering and Technical Services W. C. Carr, Supervisor-Safety Audit
.and Engineering Review bcc w/ encl:
NRC Resident Inspector E. Reeves, Division of Licensing, 4 Operating Reactors Branch 1, NRR i Document Management Branch State of Alabama . RII l
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U. S. NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE BOARD REPORT ALABAMA POWER COMPANY FARLEY NUCLEAR PLANT UNITS 1 AND 2 DOCKET NUMBERS 50-348 AND 50-364 JULY 1,1980 THROUGH JUNE 30, 1981 INSPECTION REPORT NUMBERS 50-348/82-08 50-364/82-07 w
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. - . . INTRODUCTION A formal licensee performance assessment program has been _ implemented in accordance with the commitments of Task I.B.2 of NUREG-0660, Volume 1, "NRC Action Plan Developed as a Result of the TMI-2 Accident" This program, the Systematic Assessment of Licensee Performance (SALP) is applicable to all power reactors with operating licenses or construction permits (herein after referred to as licensees). The SALP program is an integrated NRC staff effort to collect available observations of licensee performance on an >
annual basis and evaluate performance based on these observations. - Positive and negative attributes of licensee performance are considered. Emphasis is placed upon understanding the reasons for a licensee's performance in important functional areas, and sharing this understanding with the license The SALP process is oriented toward furthering NRC's under-standing of the manner in which: (1) the licensee directs, guides, and provides resources for assuring plant safety; and (2) such resources are used and applie The integrated SALP assessment is intended to be sufficiently diagnostic to provide meaningful guidance to the license The SALP program supplements the normal regulatory processes used to ensure compliance with NRC rules and regulation II. CRITERIA Licensee performance is assessed in selected functional areas depending on whether the facility has been in the construction, preoperational, or operating phase during the SALP review period. Functional areas encompass-the spectrum of regulatory programs and represent significant nuclear safety and environmental activities. Certain functional areas may not be assessed because of little or no licensee activities in these areas, or lack of meaningful NRC observation One or more of the following evaluation criteria were used to assess each functional area:
. Management involvement in assuring quality . Approach to the resolution of technical issues from a safety standpoint . Responsiveness to NRC initiatives . Enforcement history Reporting and analysis of reportable events . Staffir.g (including management) . Training effectiveness and qualification The SALP Board has categorized functional area performance at one of three performance levels. These levels are defined as follows:
Category 1: Reduced NRC attention may be appropriat Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or construction is being achieve _ _ _ _ _ _
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Category 2: NRC attention should be maintained at normal level Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that satisfactory performance with respect to
- operational safety or construction is being achieve Category 3
- Both NRC and licensee attention should be increased.
i Licensee management attention or involvement is acceptable and considers nuclear safety,. but weaknesses are evident; licensee resources appear to be strained or not effectively used such that " minimally satisfactory performance with respect to operational safety or construction is being achieved.
. The functional area being evaluated may have some attributes that would
- place the evaluation in Category 1, and others that would place it in either Category 2 or 3. The final rating for each functional area is a composite
- of the attributes tempered with the judgement of NRC management as to the significance of individual item III. SUMMARY OF RESULTS i
i Overall Utility Evaluation The Farley facilities are well managed and well supported by the corporate structure. No significant weaknesses have been identifie The licensee has been responsive to NRC concerns, and the licensee's , organization appears safety oriented. Middle and upper level manage-ment capabilities (including support from Southern Company Services, Inc.) are very strong area . Overall Facility Evaluation !' Strengths were noted in the critical areas of plant operations, radiation protection, radioactive waste management, transportation, environmental protection and quality assuranc No significant weak-nesses were noted. Other strengths included maintenance, audits, reviews, committee activities, administration, records, corrective actions, reporting, plant operations preparation, surveillance, and preoperational testin Facility Performance - Farley 1 and 2 i- Tabulation of ratings for each functional area j Operations (Units 1 and 2) l Plant Operations - Category 1 4 Refueling Operations - Category 2 Maintenance - Category 1 l Surveillance and Inservice Testing - Category 2 Personnel, Training, and Plant Procedures - Category 2 l .
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3 Fire Protection and Housekeeping - Category 2 Design Changes and Modifications - Category 2 Radiation Protection, Radioactive Waste Management and Transportation - Category 1 Environmental Protection - Category 1 1 Emergency Preparedness - Category 2 1 Security and Safeguards - Category 2 1 Audits, Reviews, and Committee Activities - Category 1 1 Administrative, QA and Records - Category 1 1 Corrective Actions and Reporting - Category 1 Preoperational Testing (Unit 2) 1 Plant Operations Preparation - Category 1 1 Fuel Loading Preparation - Category 2 1 Surveillance and Preoperational Testing - Category 1 Construction (Unit 2) 1 Electrical Systems - Category 2 1 Preservice Inspection - Category 2 SALP Board Members: R. C. Lewis, Director, Division of Projects and Resident Programs (DPRP) (Chairman) P. J. Kellogg, Chief, Reactor Projects Branch 2, DPRP C. E. Murphy, Chief, Engineering Inspection Branch, Division of Engineering and Technical Programs E, SALP Board Attendees: R. D. Martin, Deputy Regional Administator, Region II V. L. Brownlee, Chief, Reactor Projects Section 2B, DPRP W. H. Bradford, Senior Resident Inspector, Farley D. S. Price, Acting Chief, Operational Support Section, Division of Emergency Planning and Operational Support E. Reeves, Project Manager, Division of Licensing, Operating Reactors Branch No.1, Office of Nuclear Reactor Regulation IV. PERFORMANCE ANALYSIS Functional Areas Plant Operations Analysis Day to day inspection coverage was provided by resident inspectors on Unit 1 and (subsequent to initial criticality) l l-
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on Unit Two violations were -identified in this area as follows:
(1) Severity Level V violation for failing to follow established shift turn-over procedures by not turning over significant deficiencies to the oncoming shif (2) Deficiency for failing to. follow established procedures-by not completing corrections, as required, to surveil-lance test procedure These violations appear to be isolated and do not indicate an adverse trend of licensee performance in the are The licensee's knowledge of regulations, guides, standards and generic issues has been good. Additionally, the utility has been strict in its interpretation of these guide Licensee technical competence appears . excellent, especially in the senior nuclear management area. They .are well prepared at meetings with the NRC, their staff generally being able to make immediate commitments or state the utility's position in a given are The . licensee has a positive nuclear safety attitude and has had no significant administrative, management control, or material problems. The material or equipment problems that have been identified were minor and non-repetitive in nature and were dealt with in a timely manne There were no l Severity Level I, _ II or III violations, and only a few
- violations of lesser severity level. Of these, none were i assessed as evidence of a programmatic breakdow Conclusion - Category 1 Board Comments The board concurs with the ratin . Refueling Operations Analysis Refueling activities on Unit 1 were observed by the resident inspectors. There were no material or equipment problems and no violations were identified. The performance and attitude of the refueling contractor and licensee were comparable to refueling programs of other licensee .. -. ._ . . . _ _ .- ~. .- - . . .- .. .
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, Conclusion - Category 2 ] Board Comments ] The board concurs with the ratin . Maintenance Analysis I Day to day inspection coverage was performed by the resident inspectors. One inspection by a region based inspector was conducted during the evaluation perio There were no violations identified.
) The licensee has a positive nuclear safety attitude and has j developed a viable preventive and corrective maintenance program. The material or equipment problems that have been . identified have generally been minor and non repetitive in ! nature and were dealt with in a timely manner.
, Conclusion - Category 1
! Board Comments
The board concurs with the rating.
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. Surveillance and Inservice Testing 1 Analysis Day to day inspection coverage has been performed by the resident inspectors within the evaluation period for Units 1 and 2. There were no violations identifie Four inspec-
' tions were performed by regional inspectors. One concerned inservice inspection and three concerned the Containment Building Tendon Surveillance Progra One problem was identified in the licensee's Tendon Surveil-
, lance Program. No violations or deviations resulted although ;
the problem was discussed at a management meeting held on l October 7, 1980. Subsequent to this meeting, Licensee Event , Reports 80-58, and 80-58, revision 1, were issued which
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detailed the actions taken to correct the problem, consisting primarily of a more detailed tendon inspection program, f Conclusion - Category 2
' Board Comments The board concurs with the ratin , _. _ . . . _ . - . . . . . . - , _ . - . - . . . - - .
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i f '5. Personnel, Training and Plant Procedures . Analysis , Three inspections have been performed during the evaluation period by resident inspector Two- inspections were per-i formed on Unit I and one inspection was performed on Unit-2 . Region based inspectors also had findings in this area. .The
violations are r.atagorized as follows:
(1) Severity Level V violation for deviating from plant procedures without prior documentation and approva (2) Severity Level V violation for failure to follow established procedures in processing maintenance work requests.
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(3) Severity Level V violation for inadequate test pro-1 cedures which did not identify the cross-tied service J
water lube and cooling water piping.
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(4) Deficiency for failure to develop and implement ' a
. formal, on the job training program for chemistry and health physics technicians, failure to establish administrative controls' to preclude radioactive materials introduction into the demineralized water system by improper use of temporary connections, and inadequate development of criteria for crediting l experience for chemistry and health physics technician ! l These violations involved several organizational elements and I do not appear to indicate an adverse performance trend in the i areas.
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- The licensee's training program is rated very highly by NR Conclusion - Although the training program was rated very highly, overall performance in this area was in Category 2
, Board Comments The board concurs with the rating.
i 6. Fire Protection and Housekeeping 4 Analysis l Four inspections were conducted in these areas by regional based inspectors. Additionally, the areas were periodically monitored by resident inspectors. Fire protection admini-strative controls were reviewed and found to conform to NRC I l
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guidelines. Adherence to these guidelines was satisfactory.
' During this inspection period the licensee implemented extensive modifications to the fire protection system. Two violations and two deviations were identified in the area: '
(1) Severity Level V violation for smoking in "No smoking" ; area (2) Infraction for personnel not having received all of.the '
- required fire brigade training, being routinely assigned
! to the plant fire brigad (3) Deviation for failure to install the fire dampers in the
- ventilation ducts in accordance with the manufacturer's
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installation requirenent (4) Deviation for failure to install part of the fire protection modifications under a QA progra The licensee failed to submit a timely-request for exemption from meeting Appendix R (Fire Protection Rule). Addition-ally, the licensee has requested a waiver on the installation i of a sprinkler system and is reevaluating fire door instal-lations to determine if some doors need to be replaced or
- commitments to the NRC' revise ! Conclusion - Category 2
! Board Comments
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The board concurs with the rating.
, Design Changes and Modifications Analysis Four inspections were performed during the evaluation period.
4 The resident inspectors conducted one inspection and region ! based inspectors conducted three inspections. Two violations , were identified:
(1) Severity Level IV Violation concerning operating with the lube and cooling water system to the service water pumps cross-tied to A and B trains. Under certain
- conditions this would render the independent service water trains inoperable to perform their specified functions. This was a construction piping error-and was
identified and reported by the licensee.
! (2) Infraction for lack of adequate procedures to control l work activities for preparation and review of the i- ,
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masonry wall as-built drawing During preparation of the response to IEB 80-11 (Unit 1) and an NRR Design Information Request for Data on Masonry Wall (Unit 2), the licensee determined that the masonry walls were not constructed in accordance with the requirements shown on the design drawing This was reported to the NRC in a Licensee Event Report. The licensee's actions to correct the problems were well organized and implemented in a timely manner. The repair work was accomplished under a rigorous QC inspection program. The original construction of the masonry walls was not required under the QC progra A modification was performed on the reactor containment purge and ventilation system during which the licensee recognized a potential safety problem with the system and took steps to correct the problem. Such action was considered commendable and in the best interest of safet Conclusion - Category 2 Board Comments The board concurs with the ratin . _ Radiation Protection, Radioactive Waste Management and Transporta-tion Analysis Seven inspections, including one Health Physics Appraisal, were performed during the evaluation period. No violations were identified during the inspection The Health Physics Appraisal Team identified weaknesses in !'. on-the-job training; qualification of chemistry and health ! physics technicians; development of criteria for crediting experience received by health physics support personnel towards meeting the experience requirements for technicians; and in administrative controls to assure that radioactive material is not inadvertently introduced into the plant's demineralized water system. The licensee has a strong, well managed radiation protection
- program with a corporate management that is responsive to the j radiation protection needs of the facility.
. Conclusion - Category 1 ! Board Comments
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The board concurs with the ratin . Environmental Protection Analysis One inspection in the area of confirmatory measurements was performed during the appraisal period. One deficiency was identified: Deficiency for failure to follow established procedures which required that chemical and radiochemical pro-cedures be written to prescribe the nature and frequency of sampling and analysis and that these procedures specify laboratory instructions and calibration of laboratory equipmen The deficiency was minor and did not suggest problems in the overall chemistry or radiochemistry program The licensee had a positive nuclear safety attitude, in this are Responses to NRC concerns were thorough and timely, and _ material and equipment problems were only minor and non-repetitive in nature and were dealt with in a timely manne Conclusion - Category 1 Board Comments The' board concurs with the ratin . Emergency Preparedness Analysis Three inspections were conducted during the evaluation period; two were preoperational of Unit 2, and one was an evaluation of a full-scale emergency exercise. No violations were identifie 'The Emergency Notification System installation was not completed by the required date of July 1,1980. Completion was occurred in September, 198 The State of Alabama's Radiological Emergency Response Plan has been approved for , the Farley site.
i , Conclusion - Category 2 i ,
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. 10 Board Comments The board concurs with the ratin . Security and Safeguards Analysis During the appraisal period four inspections were conducted in the security and safeguards areas. Additional observa-tions were conducted by resident inspectors during normal plant tours. One infraction and one level V violation were identifie The licensee's site security management is enhanced by a corporate management program with apparent security emphasis. The licensee provides prompt and res-ponsive corrective action on identified item Conclusion - Category 2 Board Comments The board concurs with the ratin . Audits, Review and Committee Activities Analysis Three inspections, were performed in these areas by the resident inspector and one inspection by the Performance Appraisal Section (PAS).. The PAS inspection was limited in scope to specific safety related components. One deficiency was identified: Deficiency involving the failure to follow the estab-lished RT procedure in that the film density through the area of interest was greater than 30*; of the density through the penetramete Previous inspections have shown the licensee's performance to be very good in these . area The inspections performed during this review period, though limited in scope, have given no indication that the licensee's program has degrade Conclusion - Category 1 Board Comments The board concurs with the ratin .' .
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13. Administrative, QA and Records Analysis These areas were reviewed during two inspections, one by the PAS and one by regional inspectors. Both of these inspec-tions were limited in scope to specific safety related components. There were no adverse findings in the areas that were reviewe Previous inspections have shown the licensee's performance to be very good in these areas. The inspections performed during this review period, though limited in scope, have given no indication that the licensee's program has degrade Conclusion - Category 1 Board Comments The board concurs with the ratin . Corrective Actions and Reporting Analysis There were eighteen violations identified in all functional areas during the evaluation perio The corrective actions taken in each functional area by the licensee appear to be responsive, timely, and adequate. The licensee is responsive in advising the commission on reportable matters and is diligent in contacting the resident inspector on significant information and event The licensee has made several submittals and responses to NRR during the evaluation period and has relied heavily on the NSSS-vendor for inputs. One problem area concerns a recent submittal for a change to the Unit 1 Technical Specifications which would cause them to conform to the Unit 2 Technical Specifications ar.d which did not conform to a prior agreement with the licensee's staff. The quality of the submittal left unanswered questions which will require some expedited NRR reviews to resolv The licensee is timely in responding to NRR and places considerable effort in providing complete responses. In many instances they exceed staff requirements in their submittal The licensee also reacts very quickly to satisfy NRC require-ments. The licensee is ahead of most licensee's in correct-ing long standing open items. They keep the FSAR updated to reflect the currently approved desig Responses to TMI issues have also been timel . .
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. 12 Conclusion - Category 1 Board Comments The board concurs with the ratin . Plant Operations Preparation (Unit 2) Analysis The resider.t inspectors have inspected the licensee on a day to day basis during the evaluation period. These inspections cover the preoperational stage through the startup testing stage of the uni These inspections were made to determine that the licensee had fulfilled the requirements and commitments necessary to load fuel, perform low power tests, start up tests and to bring the unit to power operations. Region based inspectors conducted three inspections concerning fire protection and procedures review. No violations 'were identifie Related problems are discussed in area 6, abov Conclusion - Category 1 Board Comments The board concurs with the ratin . Fuel Loading Preparation (Unit 2) Analysis Fuel loading activities were observed by the resident inspectors. There were no material or equipment problems and no violations were identifie Conclusion - Category 2 Board Comments The board concurs with the ratin . Surveillance and Preoperational Testing (Unit 2) Analysis The resident inspectors have inspected Unit 2 preoperational testing on a continuing basis during the evaluation perio Region based inspectors have conducted six inspections which
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1 included preservice surveillance inspections as well. as inspections on various construction function Two violations were identified and are categorized as follows:
(1) Infraction for a failure to follow established pro-cedures in not making corrections to a preoperational test procedure as require (2) Deficiency for failure to follow established procedures by not inspecting and eliminating or minimizing leaks prior to the official leak test (Containment Integrated Leak Rate Test).
The licensee's Thermal Expansion and Vibration Testing, Initial Fuel Loading, Initial Criticality and Low Power Testing programs were all considered good. In each case procedures were thorough, tests were controlled and proceeded ' i in an orderly manner, and the licensee was cooperative in addressing NRC concerns. Several procedural problems noted i by the NRC in the Integrated Leak Rate Testing (ILRT) pro-cedures were corrected prior to the test and later applied to Unit 1 ILRT procedures.
> The licensee has displayed a positive nuclear safety attitude and has developed viable surveillance and preoperational testing programs. Problems identified in these areas were minor, non-repetitive in nature, and were dealt with in a timely manner. There were no Severity Level -I, II, or III violations, and few violations of lower classification. None of these were assessed as evidence of a programmatic break-dow Conclusion - Category 1 Board Comments The board concurs with the ratin Additional Areas of Evaluations i Although Farley 2 was in an operations, startup testing, or preservice inspection phase during this period, some construction phase inspection activity was also performed. The following two areas, electrical systems, and preservice inspection are analyzed because of this activit Other construction areas were either not inspected or had no significant , findings.
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18. Electrical Systems (Unit 2) Analysis Two inspections were conducted in this area during this evaluation perio One inspection was performed prior to issuance of the operating license. This inspection was on instrumentation components and systems and instrumentation cables and termination No violations or deviations were identified during this inspectio The second inspection concerned IEB 79-01B and NUREG 0588,
" Environmental Qualification of Class IE Electrical Equip-ment." An examination was made ' of installed equipment and data was obtained to verify the licensee's response to these documents. The data was also forwarded to the Equipment Qualification Branch of NRR as an aid in the review of the licensee's IEB 79-01B and NUREG 0588 responses and in the preparation of the associated Safety Evaluation Repor No violations or deviations were identified during this inspec-tion, Conclusion - Category 2 Board Comments The board concurs with the ratin . Preservice Inspection (Unit 2) Analysis I
Three inspections were performed in the area of preservice inspection (PSI). One noncompliance was identified: Infraction concerning inadequate procedures for control of the preservice and inservice inspection programs to
- insure proper evaluation and disposition of inspection
! result At the time of the infraction the licensee was in the process of reorganizing the PSI /ISI organization and the procedure for control of PSI /ISI was being revised. As a result of the infraction, additional changes were made which strengthened the licensee's program of evaluation and disposition of inspection result Conclusion - Category 2 Board Comments
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The board concurs with the ratin SUPPORTING DATA AND SUMMARIES Reports Data LER's: Unit 1 - 89 Unit 2 - 29 Significant LERs are discussed in the performance analysis section. Causally linked events included two on Unit 1 concerning diesel generator failures to start due to mode selector switches being in the wrong position; four on Unit I concerning the loss of off-site power sequencer failing to meet time requirements for pickup; and four on Unit 2 concerning diesel generator sequencer failing to meet time requirements for load sheddin A large number of LERs on Unit 2 were due to component failures, and occurred during startup operations which was expected. The ratio of management to personnel caused events is relatively low indicating good management practice . Construction Deficiency Reports - 2 (Unit 2 only) Part 21 Reports - 0 Licensee Activities A Unit I refueling outage occurred during the period November,1980 through March, 198 Initial criticality of Unit 2 was May 8,198 Significant modifications were made to the Unit 1 low pressure turbines, Unit 1 and 2 Service Water Emergency Recirculation system, and the Unit I and 2 masonry wall Inspection Activities The routine inspection program was performed during the review perio . A Health Physics Team Appraisal was conducted in December,198 Investigations and Allegations Review No major investigative activities occurred during the review perio Escalated Enforcement Actions No escalated enforcement actions occurred during the review perio Management Conferences Held During Appraisal Period A conference was held in August,1980 to discuss IEB 79-02 and 79-14.
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A conference was held on October 7,1980 to discuss problems associated with the Containment Building Tendon Surveillance Progra A conference was held on October 15, 1980 to discuss the previous SALP finding :
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