IR 05000348/1989015
| ML19325D784 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 10/05/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19325D783 | List: |
| References | |
| 50-348-89-15, 50-364-89-15, NUDOCS 8910260138 | |
| Download: ML19325D784 (28) | |
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INTERIM SALP REPORT
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U. S. NUCLEAR REGULATORY COMMISSION
REGION II
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
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INSPECTION REPORT NUMBER 50-348/89-15 AND 50-364/89 15 ALABAMA POWER COMPANY
JOSEPH M. FARLEY UNITS 1 AND 2 April 1, 1988 - July 31, 1989 8910260138 891005 ~
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SUMMARY OF RESULTS Both of the Farley units were operated in an overall safe manner during
this assessment period.
Strengths were identified in the areas of plant operations, radiological controls, maint; nance / surveillance, security ar.d safety assessment / quality verification.
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Functional areas considered to be acceptable were as follows:
emergency protredness, and engineering / technical support.
Durtny the previous SALP period, management attention was requested to be f
i focused on improving performance in procedural compliance. Although i
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management attention was directed to this area during this SALP period,
procedural compliance continues to be a concern.
Performance in the functional area of plant operations continued to be a
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strength. All of the reactor trips (3) during this SALP period resulted
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from activities on the secondary plant.
However, the results of requali-
L fication exams may be a precursor to a declining trerd.
Late in the SALP period, a concern was identified involving the large
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avhunt of overtime used during outage periods by operations and maintenance.
This issue is currently under NRC review.
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Details of our evaluations of each of these functional areas are in Section IV of this report.
Overview
The specific assigned ratings for the last rating period and the current i
period are shown in the following table.
This table reflects the new lis ;ing of functional areas. Those areas shown in parenthesis were the
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functional areas evaluated during the previous SALP period.
In some cases, more than one functional area of the previous period are now combined into a new functional area. That is the reason for more than one rating being shown in the previous period.
Rating Last Period Rating This Period Functional Area 8/1/86 - 3/31/88 4/1/88 - 7/31/89 Plant Operations 1/1
(Operations and Fire Protection)
Radiological Controls
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Maintenance / Surveillance 2/2
2 Security and Safeguards
1 Engineering / Technical Support 2/2/1
(Engineering, Training and Outages)
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Safety Assessment /0uality 2/3
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L Verification (Quality l
Programs and Licensing)
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III. CRITERIA
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Licensee performance is assessed in the functional areas shown above.
L Functional areas normally re;. resent areas significant to nuclear safety L
and the environment.
Special areas may be added to highlight significant observations, o
The evaluation criteria which were used, as applicable, to assess each functional area are described in detail in NRC Manual Chapter 0516. This chapter is in the Public Document Room files.
Therefore, these criteria are not repeated here, but will be presented in detail at the public meeting to be held with licensee management on October 30, 1989.
However, the NRC is not limited to these criteria and others may have been used where appropriate.
On the basis of the NRC assessment, each functional area evaluated is rated according to three performance categcries.
The definitions of these performance categories are shown here only because of some changes in the NRC Manual Chapter noted above. These new performance categories are defined as follows:
1.
Category 1.
Licensee management ettention and involvement are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially exceeding regulatory requirements.
Licensee resources are ample and effectively used so that a high level of plant and personnel performance is being achieved.
Reduced NRC attention may be appropriate.
2.
Category 2.
Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are good.
The licensee has attained a level of performance above that needed to meet regulatory requirements.
Licensee resources are adequate and reasonably allocated so that good plant and personnel performance is being achieved.
NRC attention may be maintained at normal levels.
3.
Category 3.
Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are not sufficient. The licensee's performar,ce does not significantly exceed
that needed te meet minimal regulatory requirements.
Licensee i
resources appear to be strained or not ef fectively used.
NRC attention should be increased above normal levels.
The SALP Board included an appraisal of the performance trend of certain functional areas where considered necessary.
Performance trenas are used when both a definite trend of performance within the evaluation period is i
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noted and the Board believes that continuation of the trend may result in a change of performance level The trend, if used.is defined as:
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L Improving:
Licensee performance was determined to be improving near the
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close of the assessment period.
l Declining:
Licensee performance was determined to be declining near the close of the assessment period and the licensee had not taken meaningful steps to address this pattern.
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IV, PERFORMANCE ANALYSIS i
A.
PLANT OPERATIONS
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1.
Analysis This functional area addresses the control and performance of activities directly related to operating the units.
This area includes activities involved with monitoring plant conditions, system lineups, normal operations, response to transient and
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i off-normal conditions, control manipulation, control room
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professionalism, plant housekeeping, equipment conditions, fire protection and interfacing activities that support plant operations.
This assessment is based on routine inspections conducted by the NRC staff and a special team fire protection inspection.
The performance of the operating staff continues to be a strength. The operators are professional, dedicated and conscientious employees.
This contributes to long plant run times and few ope ator errors.
The total number of trips declined from 7 r actor trips during the previous SALP period to 3 reactor trips d. ring this period, and all 3 reactor trips resulted from activities on the secondary plant (para, V.G).
None of the trips were attributed to operator errors.
Unit 2 completed a continuous power run of 453 days during this assessment period which established a world record for a Westinghouse Fv/R unit.
The operations group is staffed with five shifts per unit.
Each shift has two shift supervisors (SR0s), two shift foremen operating, two shift foremen inspecting, one shift support supervisor, six reactor operators, nine system operators and one shift aide.
Thus, the normal shift staff exceeds the minimum staff requirements of the Technical Specification (TS).
These personnel are equally divided between the two units. Approxi-m6tely one half of the shift supervisors and two thirds of the shift foremen are qualified shift technical advisors and have a technical or engineering degree.
The operations staff has had a low turnover rate which has resulted in a high experience level.
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The operations staff works a nominal forty hour work week of eight hours per day when both units are operating.
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during a refueling outage on either unit the crews of both units
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are scheduled to work twelve hour shifts.
During the Unit 2 refueling outage, NRC identified instances in which some operations employees were permitted to work their off days apparently due to insufficient management oversight. This resulted in some operators working more than seven consecutive days without a day off. A management meeting was conducted on
July 31, 1989, to discuss this concern.
Resoktion of our concerns on the use of overtime will be addres ed during the l
next assessment period.
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Shift supervisors were in control of activities and demonstrated confidence in the performance of supervisory duties.
The control room crews worked well together and generally trained together as a crew. The administrative burden for the shift supervisors was reduced by assigning more responsibilities to the shift supervisor-support and shift foreman inspecting positions.
The operators maintained a professional demeanor and their responses to alarms were generally taken without delay. An example of the operators performance occurred on February 1, 1989. On this date Unit 1 experienced an unexpected main turbine generator load rejection which resulted in a decrease of electrical power from 860 MW to 240 MW.. The operators took manual control of the main turbine generator and were able to
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stabilize the plant and prevent a reactor trip.
However operator performance was marginal during the requalificatton er.ams as discussed in section IV.F.
Notwithstanding, three t
violations for failure to follow procedures vere cited during this period.
The licensee's supervisory staff are knowledgeable and proficient in day-to-day operations. Major operational decisions are made at a management level adequate to assure appropriate supervisory involvement. All operational plant managers and the plant general manager hold current senior reactor operator licenses.
Plant operations are conducted in a conservative manner to ensure plant safety.
Good management control and interface was noted at plant status and refueling outage meetings.
Operations management conducted routine plant and control room tours and.nitiated employee interface meetings to improve communications and expedite problem resolution.
Overall control of plant operations was well planned with established and realistic priorities.
Corporate interest and oversight were evident from the site visits and plant tours by senior managemen Iy t'
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l The Itcensee's internal incident report system was effective in
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identifying plant discrepancies, personnel errors and events that affected the plant which could have had safety significance.
The shift supervisor is responsible for
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initiating incident reports.
Those persons that identified the discrepancies or were involved in the events, provided descriptions of each situation for evaluation. The events are evaluated by the appropriate work group and reviewed by plant
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management to determine the action necessary to correct and prevent future occurrence.
This program has contributed to the low number of repetitive events.
Administrative controls to ensure control room professionalism
I were established and are effective.
Access to the at-the-control area is limited and well controlled.
Control room drawings are easily accessible, accurate, legible, and in very good physical condition with a Mylar protective coating.
However, some plant change notices were not readily available, t.
Operator logs are legible, complete, and identified normal conditions, off-normal conditions, special tests and events.
Preshif t briefings are conducted and shift turnover forms are used by all operators. Watchstanders and duty technician assignments are posted in the control room.
Key controls for operator access to spaces and equipment are well organized.
During this assessment period, the licensee upgraded the emergency operating procedures to conform to the Westinghouse Owners Group guidelines.
Following the previous SALP assessment, the licensee initiated the following corrective action on problems and weak areas identified in the previous SALP, 1) an interim policy has been established which requires room coolers to be considered as attendant equipment; 2) communications at midshift relief and turnovers have improved; 3) the fire protection workload on the shift supervisor has been reduced by improved scheduling and by providing additional work assignments to the shift foreman; 4) a quarterly audit of all operation's controlled documents verifies that these documents are maintained up-to-date; 5) an ongoing program was initiated to assure that all valves, components and equipment have identification tags which conform to the plant's
As-Built" drawings; 6) a program was initiated to provide identification signs at the entrance to each room identifying
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the principal equipment, components, valves and instrumentation in the room is about 40 percent complete; 7) the licensee's hold-tag program has improved; 8) an evaluation is in process to determine which remote valve operators are actually required to permit tagouts of the charging pumps, and if design changes are needed to permit these valves to be easily repositioned; and 9)
a program to trend incident reports was initiated and is effective in root cause evaluation of various event I
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L During the assessment period, plant housekeeping declined from its previous high cleaniness levels. Near the end of the SALP period more emphasis was placed on housekeeping and improvemer.ts
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were noted.
Improved lighting in certain areas would contribute L
to more effective observation of equipment performance.
A review of the fire protection program demonstrated that plant fire protection features were inservice and functional.
Control of transient combustihie and flammable materials in safety related areas of the plant was considered good.
However, a i
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deviation was cited for a designated combustible storage area i
found to not be separated from safe shutdown areas by an
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approved fire wall. Drills and training of fire brigade members t
were conducted within the required frequency,
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The operations group has effectively implemented the fire
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protection program to assure compliance with open flame permits, i
fire watches and testing of fire protection equipment.
In response to an NRC initiative, an extensive testing program was
developed to ensure that fire dampers can close under air flow l
conditions in HVAC systems.
This program has resulted in the
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upgrade of approximately 30 dampers.
Each damper is to be t
retested every five years.
I In September 1988, a special team inspection was conducted to assess the licensee's fire protection functional configuration i
management program.
This inspection verified that the licensee I
has maintained the 10 CFR 50 Appendix R post fire safe shutdown
capability and that the program was adequate. Strengths included
a thorough Appendix R design change review, licensee
responsiveness to NRC initiatives, and inclusion of Appendix R
considerations in the routine fire brigade training and drills.
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Four of the five violations identified in the area of Plant
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Operations involved procedural adherence problems.
One deviation was also identified.
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Performance Ratina - Category 1 3.
Recommendations The Board recognizes the continued strong performance in the area of plant operations, but is concerned that the results of the requalification exams administered in June 1989 may be i
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ind4cative of declining operator performance.
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B.
RADIOLOGICAL CONTROLS
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This functional area consists of evaluation of activities I
related directly to radiological controls including occupational radiation protection, radioactive materials and contamination controls, radiological surveys and monitoring, and ALARA programs.
Other activities which are evaluated include those
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related to radioactive waste management, radiological effluent control and monitoring, offsite dose calculations, radiological environmental monitoring, confirmatory measurements, and transportation of radioactive materials.
The licensee's health physics (HP) and radwaste staffing levels were adequate to support routine and outage operations. During i
the eu,sessment period no contract HP technicians were used to augment radiological controls for routine operations. The knowledge and experience level of the HP staff was good.
The overall quality assurance measures applied during routine preventive maintenance on survey equipment by the HP staff was considered a program strength.
The initial HP training and retraining program for the technicians and HP foremen was considered good.
The licensee's general employee training in radiation protection was clear and well defined.
During the previous SALP period, concerns were identified about communications during the EP exercise, and subsequently, the licensee improved emergency training by establishing h training program for HP on-call managers.
Positive management support and involvement in matters related to radiation protection were demonstrated by the procurement of a standup whole body counter.
Positive control of high radiation exclusion areas was improved by installing lockable fences or devices at corrective action for itsues identified during the previous SALP period.
In addition, access routes to the auxiliary building radiation control area are being modified to improve access control. Management has increased the emphasis on accountability of supervisors for dose reduction.
During the evaluation period, it was noted that the radiation protection program received strong support from other plant departments.
In 1988 the licensee's collective dose per reactor unit was 276 person-rem which reduced the 3 year collective dose average to 335 person-rem per reactor unit.
The primary contributor to the reduction in dose during this assessment period was the increased use of shielding in containment during outages.
Significant decreases in dose rates were also observed during reactor head work, and reactor cavity decontamination due to the new reactor head shield. A factor which aided in personnel dose management was the improved processihg time for thermoluminescent dosimeters (TLDs).
Currently TLDs are processed in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and for special cases, such as, for those i
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L persons working in dose intensive areas, the TLDs can be e
processed in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
The collective dose during this L
assessment period was 751 person-rem and resulted from refueling j'
outages for both reactor units, t
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The licensee has a number of initiatives underway to limit and reduce dose rates within the plant including several modifica-l tions which are being made to reduce gas migration, evaluation
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of the replacement of primary system filters with smaller mesh filters to reduce the particulates in the reactor coolant system i
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(RCS), and raising the pH of the RCS.
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Improvements were noted in the reduction of personnel contamina-
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tions.
The licensee had a goal of less than 200 personnel k
contamination events in 1989.
To date there have been 20 skin contaminations and 22 clothing contaminations.
The licensee had effectively used a warning ticket system to improve awarencss of poor radiological work practices and other radiological deficiencies.
The reduction in the incidents of personnel contamination events is attributed to effective use of warning systems and more supervisory involvement.
At the beginning of the last assessment period, the contaminated area of the radiologically controlled area (RCA) was 23 percent.
At the end of the assessment period and the beginning of this assessment period, the contaminated area of the RCA was reduced to 11 percent.
At the end of this assessment period, the contaminated area of the plant had been reduced further to 7 percent.
The licensee attributed the reduction in contaminated are of the RCA to an aggressive leak identification / containment and repair program.
Management support for radiation protection issues was good.
The licensee experienced two violations of regulatory requirements during this SALP assessment period. The first event involved the use of a small amount of by-product material.
Both Health Physics and plant management took timely and aggressive corrective actions to prevent recurrence of similar events. The second event involved a person violating station HP requirements for entry into a high radiation area.
To correct the problem, the licensee is requiring that for any waiver or change of station HP requirements, HP issue an authorization number and document the change.
For both events described above, licensee management took prompt corrective actions.
The licensee has applied several improvements to reduce the generation of radwaste. More emphasis has been put into place to improve waste sorting, to reduce or eliminate the use of polyethylene and PVC, to decontaminate equipment to releasable levels, and to improve oil filtration of radwaste products.
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l An annual confirmatory measurements comparison conducted in August 1988, showed agreements for Tritium, Strontium-89, and
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t Strontium-90, and disagreement for Iron-55.
This continued a i
trend of inaccurate Iron-55 analyses dating back to 1984.
As a result of these inaccurate analyses, the lir,ensee had contracted i
with a vendor to supply a new Iron-55 analyses procedure, and
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had verified the accuracy of this procedure against known i
standards.
NRC supplied spiked samples were shipped to the licensee during the end of July 1989 with analysis results still
pending, j
t Projected offsite radiation doses were a small fraction of the permissible ALARA limits established by 10 CFR Part 50, Appendix
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gaseous releases were reported during 1988 or the first half of 1989.
This was a significant improvement over 1987 during which
there were 5' abnormal releases.
The effluent release data is
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summarized in the-Effluent Summary Table found in Section V,H of
this report.
l Two violations were identified in this area.
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Performance Rating - Category 1
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3.
Recommendations - None
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C.
MAINTENANCE / SURVEILLANCE l
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Analysi s f
i This functional area includes evaluation of activities related
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to diagnostic, predictive, preventive and corrective maintenance of plant structures, systems and components. Activities related i
to procurement, control and storage of components, qualification
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controls and installation of plant modifications were also evaluated. The conduct of surveillance testing activities as
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well as all inservice inspection and testing activities was evaluated. This assessment is based on the special maintenance
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team inspections conducted in April and May 1989 and also based i
on routine resident inspections throughout the SALP period.
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The maintenance organization is adequately staffed with experienced personnel at both the supervisor and journeyman
level and appears dedicated with high morale and low personnel
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turnover rate.
The maintenance staff is supplementSd with
contractors and vendor personnel and their technical support was evident by their direct input for important maintenance
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decisions concerning accumult.or check valve work.
Front line i
management involvement in maintenance activities is a routine practice at Farley as evidenced by sign-off requirements for the
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foreman in maintenance procedures.
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during the review of the maintenance training program and inspection of the instrument and control calibration shops and
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the machine shops.
These areas were frmnd to be well equipped
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l and spacious enough to accomplish a wide variety of maintenance activities.
The training for foremen and journeymen are well i
planned using established acceptance standards and procedures.
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The licensee overtime practices for the maintenance staff were
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found excessive and less restrictive than NRC guidance intended
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This is similar to the situation discussed in Section IV.A.
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The predictive maintenance program included the use of vibration
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analysis on safety and non-safety related equipment, oil
analysis, temperatLre monitoring, infrared analysis on
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electrical equipment and the motor operated valve analysis and i
test system (MOVATS) to determine if there was a need for equipment maintenance.
Also, the licensee is participating in an EPRI program evaluating an improved radiographic testing technique for locating microbiological induced corrosion (MIC)
on piping, without requiring the removal of the piping insulation.
The overall planning and scheduling of maintenance activities were good.
Management involvement in maintenance planning and practices were evident.
The daily planning meetings were observed to be used effectively in communicating station maintenance activities and in prioritizing work.
During the previous SALP assessment, the licensee completed a self-assessment program of the maintenance activities and identified a need to upgrade maintenance procedures.
Personnel were assigned the task of writing new procedures and revising the existing procedures to upgrade the maintenance procedures.
The procedure upgrade program (PUP) indicates an improvement in procedure quality, scope and technical detail when compared to
the old maintenance procedures.
However, potential weaknesses identified in the PUP program are a lack of a procedure validation requirement, minimal engineering involvement and minimal reverification of TS compliance prior to procedure issuance.
The PUP program is approximately 60 percent complete with a schedule to complete this effort during the second quarter 1990.
The operations department provided three SR0s on a permanent basis and one SRO who was on temporary assignment for the daily planning group. The review of daily work activities by these operators is an added maintenance strength in assuring that plant equipment or systems are tested or worked on without jeopardizing plant safety or violating TS requirements.
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A program for TS required surveillances was satisfactorily ('
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assessment period. One weakness was identified with the reactor
L coolant system leakage measurement procedure being
nonconservative.
The surveillance procedure was immediately i
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Surve111ances for snubbers and pipe i
l-supports / restraints were conducted with well written procedures,
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adequate preplanning, and resolution of discrepancies identified i
during testing.
l The inservice inspection program (!$1) is being effectively
implemented.
Independent eddy current data verification was
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made and found to be in good agreement with the licensee's
results. The licensee was responsive to NRC identified
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t deficiencies in nondestructive examinations procedure and made
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corrections to the,e procedures.
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t Post-refueling startup activitiis were reviewed for Unit 1,
Cycle 9. The procedures used for criticality were found to j
provide a good level of technical detail and guidance.
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assessment of core physics data collected during the startup f
agreed with the predicted performance criteria.
The licensee
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continues to maintain a sound approach to post-refueling startup
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activities, t-Management has taken several steps to strengthen the motor l
operated valve (MOV) program as evident by the appointment of a
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full time program coordinator and a new training program for t
foremen and electrical craftsmen on MOV operation and r
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maintenance.
The licensee is currently planning to extend the MOVATS' testing and torque switch setting program beyond NRC t
Bulletin 85-03 valves to include all safety-related valves and
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i valves requiring equipment qualification certification.
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Weaknesses identified in the MOV program included no trending of i
MOV failures, and changes in thrust or torque switch settings.
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Prompt action was taken to have plant drawings changed to show
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proper wiring arrangement for the motor brake on MOVs after NRC
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identification of the issue.
The PVE program is apppoximately
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60% complete with completion due to the second quarter 1990.
Strengths were observed during this period when the licensee i
installed changes to the Units 1 and 2 digital electro hydraulic turbine control systems and when the radiochemistry laboratory
computer system was installed.
The work for both of these
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changes was well planned and carefully scheduled.
The preliminary preparations and final installations were completed
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without any major problems.
Upon completion of the installations the equipment was inspected, tested and placed into service.
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The special maintenance inspection identified several additional
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strengths in the maintenance area as well as concerns and weak j
areas.
The strengths included:
good maintenance implementation by mechanical maintenance and instrument and control personnel; t
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well organized maintenance shops and facilities; a good training
program; good spare parts and material control; a competent
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staff with high morale and active foremen involvement; and a
good program for asiatic clam control in raw water systems.
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Areas identified as weak or as concerns included:
sparse use of f
inspection hold points; slow responses in handling industry issuts; need for more guidance for post maintenahce testing; and
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l excessive overtime by maintenance personnel during outages.
NRC l
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identified that DC circuit breaker calibration had not been done
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for several years. A concern was ic'entified that maintenance workers do not have a strong regard for the requirement to work in accordance with approved procedures.
Four examples of this concern were cited as a violation during the maintenance team
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inspection. Overall the results of the special maintenance inspection identified that the maintenance program was being satisfactorily implemented but that certain programmatic aspects of the program were not well documented.
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The previous SALP identified a number of weak areas.
The licensee has initiated corrective action on many of these items but weakness still exists on several items. These items are as follows:
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The PM program has been improved, and the backlog has been reduced from 400 to less than 40 work authorizations since the last SALP.
The backlog is currently being tracked by the plant monthly performance indicator system.
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To improve the service water system performance, the
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maintenance organization implemented a chemical treatment program, room cooler performance testing, periodic monitoring of heat exchanger parameters and bi-weekly area inspections.
The chemical treating program has effectively t
controlled biofouling and asiatic clams.
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A lack of control concerning the installation and removal i
of electrical jumpers bas been resolved by the issuance of a jumper control procedure which provides better administrative control of jumpers, d.
Root cause analysis for equipment and component failures continues to be a weakness in that the effectiveness of root cause analysis and the trending of equipment failures is impaired by the lack of detailed maintenance work request (MWR) failure /cause code information. Multiple examples of placing "NA", " unknown" or selecting a failure /cause code that does not apply to the circumstances
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t were noted in completed MWRs.
Lack of trending of
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i equipment failures continues to be a weakness.
Examples of
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repetitive failure rate of electrical breakers to close or
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open on demand or the breaker closing spring failing to
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charge were noted. Trending or specific analysis of these
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problems was not evident.
The licensee recognizes these
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problems and has initiated a plan to improve the overall
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site trending methods.
In addition, the licerisee has
t increased management attention to root cause analysis as evidenced by INPO training for several maintenance personnel.
Four violations were identified in this area.
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2.
Performance Ratino - Category 1
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3.
Recommendations - None
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D.
EMERGENCY PREPARE 0 NESS 1.
Analysis This functional area includes evaluation of activities related i
to the establishment and implementation of the emergency plan and implementing procedures. These activities include onsite
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Ud offsite plan development and coordination, support and
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training of onsite and offsite emergency response organizations,
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licensee performance during emergency exercises and actual
emergencies, and administration and implementation of the i
emergency plan during exercises and actual events.
Performance
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is also evaluated in event notification, dose assessment, radiological exposure control, recovery, protective actions, and
interactions between onsite and offsite emergency response organizations during exercises and actual events.
This assessment is based on observations made by the NRC staff throughout the period.
Included were observations made during the annual emergency preparedness exercise held in November 1988, and one routine emergency preparedness inspection.
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addition, two Radiological Emergency Plan (REP) revisions were reviewed during the assessment period.
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Observation and critique of the exercise indicated that the REP and Implementing Procedures were adequately implemented by the licensee.
The licensee's response to simulated emergency events during the 1988 emergency preparedness exercise demonstrated a capability to effectively implement their Emergency Plan and to i
respond to an emergency event.
Several areas for improvement were identified by the licensee and NRC.
The licensee committed to corrective actions consistent with regulatory criteria and guidance and has followed up on these findings in a responsive manner.
Areas noted for improvement were: management and
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control of the Technical $4pport Center (TSC) and Emergency
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Operations facility (EOF) during facility activation, staff f
training in the use of seismic instrumentation, use of dedicated communicators in implementing offsite notifications, awareness of plant staff to emergency declaration and plant status during
emergency conditions, and prevention of uncontrolled reentry during emergency events,
The adequacy of licensee corrective actions will be evaluated
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during the next Farley exercise, in conjunction with the
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exercise observation, a detailed review and evaluation of the
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licensee's dose assessment program was performed, This
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evaluation disclosed the unavailability of required I
documentation of the basis for factors used in calibrating the mid-range and high-range noble gas channels of the plant vent stack monitor. Acceptable documentation was subsequently
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provided and this unresolved item is now closed,
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During the february 1989 inspection, the following elements of i
emergency response were determined to be acceptable:
The rep and implementing procedures; emergency facilities, equipment, instrumentation, and supplies; organization and management control of the program; training of plant staff; and the annual independent audit of the plant and corporate emergency preparedness programs. Overall during this SALP period, the licensee continued to demonstrate the capability to fully implement the critical aspects of emergency preparedness during simulated or actual emergency events.
Durina the prior SALP
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l period, FEMA identified a finding that the alert and notification system installed around the Farley Nuclear Station
did not satisfy the requirements of NUREG-0654/ FEMA-REP-1 and
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FEMA 43.
The licensee successfully demonstrated the operability of this system during a test conducted on September 22, 1987, as documented in a FEMA approval letter to the State of Alabama dated February 1, 1988.
The following program strengths were noted during the SALP period:
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Training has been reemphasized in the various site
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organizations as it relates to implementing the REP.
The licensee recently acquired a state-of-the-art digital
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paging system and has implemented its use for all personnel who are to be paged during an emergency.
The licensee has upgraded communications by linking the TSC
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and the EOF computers with state and county agencies, This improvement eliminated having to communicate through use of the telephone FAX system.
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A program has been implemented to review and evaluate
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meterological data. This program includes weekly surveillance and data review in addition to testing,
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The licensee maintains a current listing of all emergency
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planning items which have corrective action not yet
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This list is frequently updated and has been very useful in tracking open items.
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No violations or deviations were identified.
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2.
performance Rating - Category 2
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3.
Recommendations - None E.
SECURITY AND SAFEGUARDS 1.
Analysis This functional area evaluates the adequacy of the security program to provide protection for plant vital systems and equipment.
The scope of this assessment includes all licensee activities associated with the security plan and implementing procedures, management effectiveness, security audit program, records and reports, testing and maintenance, access control,
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physical barriers, detection and assessment, armed response,
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alarm stations, power supnly, communications, and compensatory measures for degraded security systems and equipment.
Authority and responsibilities associated with the security organization were clearly delineated and effective.
In January 1989, a change in the Security Superintendent resulted from retirement of the previous individual.
This management change
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did not affect the continued professional perf0rmance of the security force.
The site's proprietary security force is adequately staffed and appropriately trained and equipped. The
licensee has provided the security force with acequate procedures.
Security plan changes have been submitted on a timely basis and licensee records are complete and adequately maintained. An exception was the safeguards amendment problems noted in Section G below.
The licensee's safeguards event
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reports have been prompt and completo.
The licensee's independent security program audit covered various aspects of the site security program.
However, the thoroughness and familiarity with the applicable regulations on the part of the auditors was marginal.
The audit report made references to nonapplicable parts of 10 CFR (73.40, 73.45 and 73.46).
Therefore, we question the qualifications of personnel who performed the audit and the validity of the audit findings.
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The licensee has expended extensive resources in upgrading the protected area barrier, and the protected area perimeter y
detection aids and assessment hardware.
Licensee management
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L attention is evident in this effort which began in April 1988.
Fall implementation is scheduled for the first quarter in 1990.
This upgrade construction project is part of the licensee response to the Regulatory Effectiveness Review conducted during
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a previous rating period.
The completion of this project should improve the security / safeguards effectiveness.
The licensee has experienced few security related violations,
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which is indicative of the quality of the training program, the professionalism and high morale of the security force.
Of the two violations cited during this reporting period, both were related to failure to follow or comply with the Security Plan and procedures.
Two noncited violations were also noted during this period. Analysis indicates that the root cause of the violation was that the Security Plan needs a major rewrite for clarification.
During the assessment period, an inspection was conducted in the area of material control and accountability (MCA).
The licensee had esteblished, maintained and followed written MCA procedures for controlling and accounting for fuel and non-fuel special nuclear materials (SNM).
These procedures include receipt, storage, shipment, internal transfer, inventory and inventory burn-up calculations, recordkeeping and reporting.
The licensee adequately tracks and accounts for SNM onsite, including items containing less than one gram U-235.
The licensee had properly documented and reported the required inventory change reports and material balance information. They maintained an adequate staff well familiarized in their assigned functions.
Violations or deviations were not identified in the MCA area.
Two violations were identified in this area.
2.
Performance Ratino - Category I r
3.
Recommendations - None F.
ENGINEERING / TECHNICAL SUPPORT 1.
Analysis The Engineering / Technical Support functional area addresses the adequacy of engineering and technical support for all plant activities.
It includes licensee activities associated with plant modifications, technical support provided for operations, maintenance, testing and surveillance, training, and configuration management.
This evaluation is based on routine i
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i and special inspections conducted by the NRC in this area and
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related functional areas, j
The performance of the engineering organization on major design changes and technical support activities was adequate; with one
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i exception involving a 10 CFR 50.59 evaluation.
Review of major
modifiestions during routine inspections indicated generally adequate implementation of design regulatory requirements and
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commitments.
The engineering organization's timely and i
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comprehensive evaluation of the steam generator tube plug degradation issue at Farley following a steam generator plug event at another nuclear plant, demonstrated effective management involvement in the coordination between the onsite
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and offsite engineering organizatiuns.
The installation of the secondary main steam line radiation detection system was an
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additional example of a properly developed and implemented
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modification. The exception to this generally adequate performance was an inadequate 10 CFR 50.59 evaluation for a containment emergency lighting design change which resulted in a violation.
This violation indicated a deficiency in procedural guidance for performance of these evaluations.
The triennial
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postfire safe shutdown inspection identified that the design
program adequately implemented Appendix R and post fire shutdown
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issues in the design program.
i Meetings between the NRC and plant management on various
technical issues throughout the assessment period demonstrated i
management's effective involvement in the plant technical
activity. Based on these meetings and observations of job performance of these managers, it is apparent that a clear
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understanding of the technical issues is usually demonstrated,
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approaches taken to resolve technical issues are sound in almost all cases, and involvement of the management and Plant t
i Operations Review Committee are routinely very effective.
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Therefore, management has maintained a thorough understanding of technical issues and demonstrated sound resolution of technical problems. An example of management's clear understanding of
technical issues was demonstrated by the action taken to
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complete the anticipated transients without scram (ATWS) rule,
10 CFR 50.62 requirements.
The ATWS mitigating actuating i
circuitry has been installed and operable on Unit 1 since the
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end of the eighth refueling outage (May 1988) and on Unit 2 since the end of the fif th refueling outage (December 1987).
These installations clearly meet 10 CFR 50.62 requirements and are a notable safety enhancement.
Technical support for the plant staff was adequate and was provided primarily by the corporate engineering organization and
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vendors.
Two engineers were added to the onsite maintenance staff.
The plant staff effectively utilizes vendor representatives to provide technical assistance on specific i
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activities involving safety related components. Westinghouse l
and Bechtel maintain Farley designated engineers to assist with
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onsite design activity.
The small onsite engineering staff was adequately supplemented by corporate and vendor engineering
resources, when needed.
The quality of engineering and technical support was less evident on minor design change activity and daily plant support.
The interface between the plant staff and corporate engineering
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staff is not procedurally defined.
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In December 1988, the licensee's operations training program was
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reaccredited by the National Academy for Nuclear Training.
The licensee recently began rotating some operating personnel through the site training staff to improve training feedback i
from the operators. The licensee's training manager served as an evaluator on the IAEA visit to France in November 1988.
This demonstrated a licenses management committment to industry
initiatives.
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A requalification examination administered by the NRC during the i
assessment period indicated marginal effectiveness of the Farley requalification program. Two crews of seven and five of 22 t
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individual operators tested failed this exam.
Four generic concerns were identified during this exam.
These concerns were:
improper use of emergency operating procedures, improper determination of emergency event classification, improper application of Technical Specification limiting conditions for operation, and improper verification and performance of emergency operating procedures' immediate operator actions.
These items were addressed in a management meeting with the NRC.
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i One initial licensing examination was conducted during this assessment period. Three of three reactor operators passed while three of four senior reactor operators passed. No generic weaknesses were noted during this examination.
Overall, the licensee's training program is effective.
One violation and one deviation were identified in this area.
2.
Performance Ratira - Category 2 l
3.
Recommendations - None
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G.
SAFETY ASSESSMENT / QUALITY VERIFICATION
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1.
Analysis This functional area includes a review of licensee l
implementation of safety policies, activities related to license an.endments, exemption and relief requests; responses to generic
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letters, bulletins, and information notices; and resolution of L
TMI items and other regulatory initatives. Also included were reviews of licensee resolution of safety issues, 10 CFR 50.59 L
reviews, 10 CFR 21 assessments, safety review committee and self assessment activities, industry's operational experience, root cause analysis of plant events, use of feedback from quality assurance, and self assessment programs.
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In general, the licensee's responses to bulletins and generic
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letters (GL) have been timely, sound and thorough.
The
engineering evaluations were generally adequate; however, they were not as consistently technically adequate or as complete as during the past reviews.
As an example, the licensee's response to GL 88-17 " Loss of Decay Heat Removal" was timely, but lacked technical detail and will be subject to further audit.
During reviews of GL 82-28, " Instrumentation for Detection of
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Inadequate Core Cooling," the staff noted that the licensee exhibited a general understanding of issues and performed adequate engineering evaluations.
The licensee's original submittals related to miscellaneous safeguards amendments were lacking several commitments that were required prior to our approval of the revised security plan.
Several subsequent revisions were needed before the licensee provided adequate detailed information necessary for the approval of the plan. The resolution of those safeguards issued delayed completion of this review.
Except for the above, the licensee's submittals were usually thorough, accurate, and timely.
The licensee exercised good judgement in requesting only those amendments which were necessary.
Resolutions of staff concerns were timely, complete, and required little follow-up.
The licensee was receptive to staff comments and responded quickly to staff requests for information when needed to complete a licensing action.
However, in the case of a final report needed by our staff to assist in generic resolution of Bulletin 88-08, the licensee's late submittal of that report delayed the technical review of this issue.
Better commitment tracking or management attention could have prevented this delay.
The licensee has continually exhibited foresight in their approach to significant technical licensing issues.
As an example, since 1986 the licensee has performed eddy current tests of the incore detector thimble tubes to detect potential tube leaks caused by the tube thinning.
Their program resulted in early detection of problems for which corrective action was initiated.
These actions preceded NRC Bulletin 88-09.
As a result, the licensee's response to Bulletin 88-09 was technically sound, thorough and consistent with the bulletin l
request.
An example of excellent licensee response to NRC
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I initiatives was the action taken to complete the ATWS rule, 10 CFR 50.62, requirements.
For more details of this effort see
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i Section IV.F above, i
The licensee demonstrated a strong safety attitude in its approach to resolving the problem identified by the North Anna steam generator tube failure event. They acted promptly and responsibly to resolve the issue for Unit 2.
The Unit I resolution involved an acceptable justification for continued operation until final repairs can be made during the
l September 1989, refueling outage.
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The licensee recognized a general need for root cause identification, and made such training available.
Personnel who
obtained this training effectively applied these methods in processing plant incident reports.
In May of 1989, the licensee conducted a Self Initiated Safety
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Assessment (S$$A) on the service water syst<n, The evaluation was established to allow the licensee to determine if the plant needs improvement in the system configuration.
The results of the SSSA have not yet been finalized.
However, the preliminary findings identified areas in need of improvement.
Evaluations will continue into the next SALP period.
Several problems have been experienced with GE type HFA relays.
For these reasons, and subsequent to the issuance of NRC Information Notice No. 88-69, Movable Contact Finger Binding in HFA Relays Manufactured by GE, the licensee staff and representatives from GE developed procedures to outline a means
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to test, adjust or replace the relays.
Implementing this procedure on all of the site GE type HFA relays has increased relay reliability.
The licensee's installation of the main steam leak monitoring system was one of the design modifications which was completed during the 1989 Unit 2 refueling outage.
The installation of an N-16 gamma detection radiation system is an important initiative taken by the licensee to detect a steam generator (S/G) tube leak.
This system is much more sensitive to changes in S/G tube leakage, and allows a more timely implementation of the appropriate emergency procedures.
The LERs submitted by the licensee during this assessment period adequately described the major aspects of each event, including
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component or system failures that contributed to the event and the significant corrective actions taken or planned to prevent recurrence.
The reports were thorough, detailed, fairly well written and easy to understand.
The root causes of the events were identified.
Improvements in root cause analysis are being emphasized by licensee management.
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L Many of the LERs presented the event information in an organized i
pattern with separate headings and specific information in each section that led to a clear understanding of the event
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information.
Previous similar occurrences were properly referenced in the LERs, as applicable.
The updated LERs when needed were adequate.
l During the maintenance team inspection, the peer inspection i
. program was identified as an area which had need for improvement. The specific weak areas included:
the need for i
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more visual inspection points, need for more QC involvement in
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evaluating peer inspection, and need for yearly eye exams for i
peer inspectors who conduct visual inspections, f
The Safety Audit and Engineering Review Group (SAER) has a new audit tracking system.
Also the SAER audits are directed to
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emphasize more performance based evaluations of site activities.
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The new system includes evaluating various actvities during
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normal and backshift hours.
Improvements have been made to
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control and track corrective actions.
These improvements have
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shortened the time period between the initial identification of an audit finding and final satisfactory resolution.
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No violations or deviations were identified.
2.
Performance Rating - Category 1 3.
Recommendations - None V.
SUPPORTING DATA AND SUMMARIES
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A.
Escalated Enforcement Action
i 1.
Civil Penalties Severity Level III violation issued on August 15, 1988, for extensive environmental qualification deficiencies which indicated a programmatic breakdown of the environmental qualification program.
(5450,000 Civil Penalty) The licensee has denied the Notice of Violation and this is under review.
2.
Orders March 28, 1989 - Order Imposing Civil Penalty in the amount of
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$75,000 for failure to determine system operability of the high head safety injection system.
The licensee has requested a hearing on this issue.
B.
Management Conferences l
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May 5, 1988 Enforcement conference on hydrogen gas
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accumulation in the high head safety injection
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system l
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,l July 7, 1988 SALP meeting with licensee at Farley site t
December 19, 1988 Management meeting in Birmingham, AL to discuss i
Southern Company restructuring l
May 10, 1989 P. Mcdonald meeting with J. Taylor to discuss
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July 31, 1989 Management meeting at Region II to discus f
training and use of overtime issues l
C.
Confirmation of Action Letters
t None
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i D.
Review of Licensee Event Reports (LERs)
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Ouring the assessment period 12 LERs for Unit I and Unit 2 were l
r analyzed._ The licensee submitted a total of 22 special reports for
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both units (which were given LER numbers) to report fire protection l
t discrepancies.
The distribution of these events, excluding special reports, by cause as determined by the NRC staff was as follows:
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Cause Unit 1 Unit 2 Total Component failure
1
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Design
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Construction, fabrication, or
0
installation i
Personnel i
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operating activity
2
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maintenance activity
2
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test / calibration activity
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other
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Total
5
l E.
Licensing Activities
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Sionificant Issues l
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- ATWS Rule 10 CFR 50.62
- NUREG-0737 Item II.F.2
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- Exemption for Inservice Testing program on Unit 2 (3/31/88)
- Exemption for Property Insurance Rule (9/29/89)
- Antitrust Settlement Agreement (7/89)
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12' Amendments Issued l
The most significant of which were:
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- Inadequate Core Cooling Instrumentatin (NUREG-0737 Item II.F.2) (5/4/89)
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- Extend Operating License Expiration Dates (5/19/89)
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- Revised Physical Security Plan per 10 CFR 73.55 (5/27/88)
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- Remove Organizatonal Charts for GL 88-06(7/8/88)
- Delete Reactor Vessel Specimen Withdrawal Schedule (8/22/88)
17SafetyEvaluationsissued(NotassociatedwithAmendmentrequests)
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The most significant of which were:
- Compliance with ATWS Rule 10 CFR 50.62 (10/31/88)
- Response to Generic Letter 88-17 (5/25/89 open issues)
i Meeting s_
- Three Licensing Schedule Reviews at Site
- Project Manager Site Visits
- Fire Protection Inspection (9/88)
- Full Scale Emergency Drill (11/88)
- Unit 2 Refueling Outage for Cycle 7 (4/89)
- Maintenance Team Exit and Quarterly Visit (6/89)
NRC Bulletins and Generic Letter _s Responses to Bulletins were received and considered closed for the
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following:
88-01, 88-02 (Unit 2 only), 88-03, 88-06, and 88-09.
r Responses to Bulletins 88-04, 88-05, 88-08, 88-10, 88-11 and 89-01 are under review.
Responses to Generic Letters 88-05 and 88-06 were received and are considered closed.
Responses to Generic Letters 88-14, 88-17, 89-06 anj 89-08 are under review.
F.
Enforcement Activity
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NO. OF DEVIATIDNS AND VIC! ATIONS IN EACH FUNCTIONAL SEVERITY LEVEL AREA Dev.
V IV III II I
1/2 1/2 1/2 1/2 1/2 1/2 Plant Operations 1/0 2/5 Radiological Controls 2/2 Maintenance Surveillance 4/3 Emergency Preparedness e
l Security 1/1 1/1 L
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Engineering / Technical 1/1 1/0 i
Support t
Safety Assessment / Quality
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Verification
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TOTAL 2/1 1/1 10/11 i
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Unit I r
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i On October 21, 1988, with the unit operating at 100 percent power, the reactor tripped due to a turbine trip.
The turbine trip was
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caused by personnel error while troubleshooting the main turbine
speed input channel #2 of the digital electro-hydraulic control
L system.
(LER 88-21)
l Unit 2
I On May 5, 1989, with the unit operating at approximately 35 percent
' power, the reactor tripped due to lo-lo steam generator level.
The
lo-lo steam generator level occurred because the 2A steam generator
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feed pump tripped due to a loose electrical connector on the 2A SGFP
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thrust bearing wear device. The connector apparently was not fully
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tightened following maintenance performed during the refueling l
outage.
(LER 89-07)
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On May 27, 1989, with the unit operating at 88 percent power with a i
three percent per Sour power increase in progress, the reactor
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tripped due to a turbine trip.
The turbine trip resulted from a i
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generator trip caused by an excitation loss due to overheating of the
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- 9 main turbine bearing. The #9 bearing f ailed due to cor. tract r
personnel neglecting to install an insulating washer on one of the
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four bolts on a bearing oil line flange.
(LER 89-08)
l H.
Effluent Summary for Farley Nuclear Plant
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l Activity Released (curies)
1986 1987 1988 1.
Gaseous Effluents I
I Fission and Activation Products 3.12E+3 2.02E+3 1.55E+3
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l Iodina and Particulates 2.15E-3 5.30E-4 1.60E-3
2.
Liquid Effluents
Fission and Activation Products 1.85E-1 9.72E-2 1.65E-1
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Tritium 1.34E+3 1.14E+3 1.27E+3
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