IR 05000348/1993015

Insp Repts 50-348/93-15 & 50-364/93-15 on 930628 & 0712-13. No Violations or Deviations Noted.Major Areas Inspected: Engineering Mods,Design Changes & Technical Support Activities

ML20056D130
Person / Time
Site:	Farley
Issue date:	07/29/1993
From:	Hunt M, Julian C, Kleinsorge W, Whitener H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20056D127	List: IR 05000348/1993015 ML20056D126
References
50-348-93-15, 50-364-93-15, NUDOCS 9308050020
Download: ML20056D130 (16)

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UNITEo STATES

/pn arc \ NUCLEAR REGULATORY COMMISSION p* $ REGION 11 i

$ 2, 101 MARIETTA STREET. N.W., SUITE 2930 "

7n 4j ATLANTA, GEORGIA 303230199

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Report Nos.: 50-348/93-15 and 50-364/93-15 l l

Licensee: Southern Nuclear Operating Company, In ;

600 North 18th Street Birmingham, AL 35291-0400  ;

Docket Nos.: 50-348 and 50-364 License Nos.: NPF-2 and NPF-8 Facility Name: Farley 1 and 2 -

InspectionConducte/

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ne: 28, 1993 and July 12-13, 1993 Inspector: M o ., > y - 2 7, /9ff g 4 4 0.jiunt ,

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//Re9ctor Injp j i f /-*/ - 27 ll$j Wf/P or/In Klein'~rge p'y Date' Signed j he Ct C# e

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(? C LyWhitener f C - Date Signed ,

eactor InspectoF

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Approved by: 4 , //#db N2 Caudle A. Julian, Acting dection Chief 7TDO Date Signed Test Programs Section j Engineering Branch  ;

Division of Reactor Safety

SUMMARY Scope:

This routine, announced inspection was conducted in the areas of engineering i modifications, design changes, and technical support activities. The inspec-  ;

tion was conducted at the site and at the corporate office I Result In thr areas inspected, no violations or deviations were identified. The i modif , cations and design changes reviewed were well planned and documente The 10 CFR 50.59 safety evaluations were adequate. The licensee's process for prioritizing and scheduling modifications activities appeared to be based on sound , judgement with the emphasis on personnel / nuclear safety considered first. This licensee had an engineering staff on site to support and coordi-nate the requested change packages as well as the scheduling of the perfor-mance of the modifications during the operation of the units and during the 9308050020 930729 PDR ADOCK 05000348 G PDR I

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outages. The staff was knowledgeable and took ownership of work assigned to them. It was noted that while engineering backlog is well managed it does contain several items that have been closed by other actions but still appear as items to be completed. A signature / initial identification sheet, which would be an aid to future verification of data, was not maintained. The i licensee engineering and technical support functions were found to be fully adequate to produce future modification documents if the conditions found :

during this inspection are maintaine '

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REPORT DETAILS  !

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I Persons Contacted l

Licensee Employees  :

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• C. Barefield, Generating Plant Engineering (GPE)  !

• Bayne, Supervisor, Safety Audit and Engineering Review (SAER) !

• J. Brantley, Supervisor, GPE ,

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• C. Buck, Manager, Technical Support

• S. Casey, Supervisor, System Support M. Coleman, Manager, General Plant Engineering ,

H. Erbskorn, Maintenance Supervisor, Unit 2 1'

• J. Fitzgerald, Coordinator, Contract Support

1. J. Fridrichsen, Senior Project Engineer ,

• S. Fulmer, Superintendent, Operations Support  !

J. Hancock, Maintenance Superintendent, Unit 1 l

• R. Hill, General Manager -

C. Hillman, Supervisor Plant Security -

1. D. Jones, Mgr. Engineering, Nuclear Engineering & Licensing (NEL) >

H. Lawson, Senior General Clerk i

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1. J. McGowan, Manager, SAER  :

1. D. McKinney, Manager, NEL  !

M. Mitchell, Superintendent, Health Physics j

1. B. Moore, Manager, Licensing l

• J. Osterholtz, Assistant General Manager Plant Support l

• R. Rogers, Supervisor, Computer Services ,

• W. Warren, Technical Training Supervisor .

• B. Yance, Manager, System Performance i Other licensee employees contacted during this inspection included engineers, operators, mechanics, security force members, technicians, !

and administrative personne j Other Organizations

1. D. Lloyd, Project Design Manager, Southern Company Services NRC Resident Inspector

• G. Maxwell, Senior Resident Inspector

• Attended the July 2,1993, Exit Meeting at the Site

1. Attended the July 13, 1993, Exit Meeting at Corporate Offices Engineering and Technical Support (37550)

The inspectors reviewed program procedures and selected records, observed work activities, and conducted interviews with licensee and contractor personnel as indicated below to evaluate the licensee's Engi-neering and Technical Support (E&TS) activities, particularly with respect to the effectiveness of the engineering organization in the

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2 performance of routine and reactive site activities, including the identification and resolution of technical issues and problems, Design Changes and Modifications The inspectors selected 11 Plant Change Notices (PCN) for review to evaluate various activities that are required for the completion of a plant modification or redesign. The PCNs were examined to determine that, if needed, the operating procedures were revised; training was given if required; the changes were supported by a 10 CFR 50.59 safety analysis; and the changes received proper review. Each completed PCN package reviewed contained documents indicating that the post modification testing had been performed and a document indicating that the affected drawings had been revised. These actions are required by FNP ,

Administrative Procedure FNP-0-AP-8, " Design Modification !

Control," which establishes the requirements for the design change program at the site. The corporate office staff is provided guidance for authorizing, obtaining, and evaluating engineering support from technical organizations that perform services for FNP, by Engineering Support Procedure No. G0-NG-34 and Design Change and Design Control Procedure No. GO-NG-ll. The NRC reviews were conducted to verify that the various requirements of the site and the corporate offices' procedures had been accomplishe Listed below are the PCNs reviewed for the various aspects discussed abov PCNs Reviewed PCN Title Identification S87-2-4106 Replacement of Service Water Branch Header Piping with Stainless Steel S88-2-5180 Unit 2 Motor Operated Valve Open Torque Switch Bypass Limit Switch 588-1-5436 Low Voltage Switchyard - Fire Protection Valve ,

House Feeder Upgrade B90-2-6578 DF08 and DF13 DC Control Circuit Voltage Mar-gin Improvement B90-2-6580 DG 08 and DG 13 DC Control Circuit Voltage Margin Improvement B91-2-7688 Control Room Annunciators-Black Board Concept ,

B90-2-6797 Replacement of Hot Shutdown Panel Local-Remote Switches B88-2-5260 RTD Bypass Eliminations

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PCNs Reviewed PCN Title Identification B90-0-7068 Relocation of Unit 1 Loads from Shared IP Motor Control Center j

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B92-1-7906 Replacement of Type TE MCCB for 125 V DC Con-trol Power -

B92-1-8312 1A and IB RX CAV H2 DILUTION FAN Agastat Timer Setting c

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The inspectors selected five PCNs for review of certain physical aspects of the completed modifications. The results of these i walkdowns are listed belo PCN B90-0-7068 was developed to rewire five Unit 1 motor-operated valves (MOVs) from a shared motor control center (MCC) to Unit 1 l MCC IT. The inspectors verified that the labelling for the j assigned MCC board was changed to reflect the addition of these new loads. Verification was made that the control room had the ;

proper data to identify the relocated power feeds for the MOV i Seismic evaluations had been performed for the new vertical l sections that had been added to MCC IT to accommodate the l additional breakers neede PCN 891-2-7688 was developed to modify the annunciation status of four different alarms that were in the activated state during normal operation. These alarms were lighted on the annunciator ,

panels during normal operation and were a distraction for the j operators. The inspector discussed the results of the PCN with l the operators on duty during the walkdown and determined that they l were knowledgeable of the modification and were satisfied with the ,

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PCN 588-1-5436 involved the replacement of power feeder cable to the Unit 1 Fire Protection Valve House located in the Low Voltage switchyard to decrease the voltage drop to the equipment installed in this location. The inspector verified that the new cables and conduits hao been installed and properly identified as documented on the installation document PCN B90-2-6797 was developed to replace some physically small

" LOCAL-REMOTE" switches on Hot Shutdown Panel. The additional weight of the larger replacement SMB switches required a seismic

, analysis of the panel which was performed and documented. The results were documented and the field changes note l The inspectors conducted a walkdown inspection of selected l replacement piping runs installed in accordance with PCN

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S87-2-4106, " Replacement of Service Water Branch Header Piping With Stainless Steel." The observations were compared with the isometric drawings indicated belo Q-2-P-16-(B87-2-4106)-W0#20526 Q-2-P-16-(B87-2-4106)-W0#20527 Q-2-P-16-(B87-2-4106)-W0#20533 Q-2-P-16-(B87-2-4106)-W0#20534

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The inspectors reviewed the calculations for PCNs B90-2-6580, B90-2-6578, and S88-1-5436 which involved the upgrading of electrical circuits to improve power distribution. The assumptions appeared to be conservative and based on good engineering judgement. The proper reviews had been performe The inspectors noted that, in many instances, initials were '

required for acknowledgement of a review or action. There did not ,

appear to be a signature list on file to identify the initials / signatures for the individuals who have signoff responsibility for various permanent records. Discussions with licensee personnel at the site and corporate offices revealed that no licensee requirement existed, but they agreed that such a list would provide information that would be helpful in the future. A l signature list may be develope In addition to the review of routine design change and .

modification packages, the inspectors reviewed six PCNs at the !

plant and at the corporate offices to evaluate the effectiveness of the licensee's design change process, involving external design :

organizations, Southern Nuclear Operating Company and the ,

Production Modification Department, in resolving emerging !

technical problems in short turn-around situations to meet plant i operating needs. Aspects evaluated included communications .

between the engineering groups, operability and safety impact I evaluations,10 CFR 50.59 reviews and timeliness of respons Listed below are the PCNs evaluated for the elements discussed ,

abov l PCNs Evaluated PCN Title Turn-Around Time Identification B 92-1-8341 Removal of Shock Absorbers Prompt from Refueling Upende l B 93-2-8533 Modify Pipe Plug to Eliminate Prompt

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Interference with Pipe Whip Restraint P 92-1-8387 Cap a Service Waterline to the Acceptable Chlorination Building

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S 89-1-5677 Replacement of Leeds & Northrup Extended ;

B0P Control System j S 92-2-8123 Reactor Make-Up Water Storage Prompt )

Tank Diaphragm Removal / Replacement i i

S 91-0-7659 Removal of Air Dryer and After- Acceptable _

Coolers on 1-2A and 10 Diesel

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Air Start System PCN S 89-1-5677 involved replacement of the obsolete B0P control system with a Westinghouse microprocessor system. Due to the -l'

extent of instrument change-out, the modification was performed in twelve stages of implementation. At each of the twelve stages, a safety evaluation was performe PCN S 91-0-7659 involved repair of leaks in the diesel 1-2A and IC air start system B air dryers and aftercoolers. When repair parts were not readily available, a revision was made to the PCN to evaluate the operation of the B air receiver and air start system with the air dryer and after-cooler removed from the system and replaced with a run of stainless steel piping. The PCN contained verification of diesel ,

operability from the vendor for this mode of operation and an i extensive engineering study to evaluate a corrosion-retarding !

chemical cleaning process to be performed each 90 days until !

replacement of the air dryer aftercooler. The inspectors '

concluded that good communications have been established between design organizations, vendors, and licensee engineering group Operability evaluation, safety impact evaluation and 10 CFR 50.59 reviews were adequately performed by the design organization and reviewed for acceptability by the licensee's corporate and site :

engineering. When necessary, issuance of PCNs was prompt to )

support plant need l b. Engineering Backlog The engineering backlog at the Farley plant consists of the following: (1) Production Change Requests (PCRs) with no design issued and which are not included on the Work List; (2) PCRs with no design issued but which are included on the Work List for the completion of the design; (3) Production Change Notices (PCNs)

with the design issued but which are not included on the Work List; (4) PCNs with the design issued and which are included on the Work List (prioritized, scheduled and included on the Work l List awaiting implementation); (5) active Engineering l Studies / Requests for Engineering Assistance (ES/REA); and l (6) inactive ES/REAs. Prioritization and scheduling of PCRs, PCNs, ESs, and REAs are collegially determined in regularly scheduled cross departmental meeting To evaluate the engineering backlog, the inspectors reviewed

. procedures, interviewed licensee personnel, and examined selected engineering documents as des;ribed belo ,

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Engineering Backlog No. of items by Year in Current Backlog 170 -

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I 4ies i 'fes 1 'e'es I 'de1 1 4 sea O Unscreduled PCAs + Scheduled PCAs o Unscheduled PCNs a Scheduled PCNs x Active ES/ AEAs v inective ES/ AEAs Figure Procedures Reviewed l Identification Revision Title GO-NG-11 15 Farley Project - Nuclear Support FNP-0-AP-8 18 Design Modification Control 2-5-92 FNP-0-AP-88 0 Nuclear Safety Evaluation ,

02-1-91 {

Relative to the procedure review discussed above the inspectors noted the following:

o The managing of the engineering backlog (prioritization and ,

scheduling) is not well documente i The licensee has 111 PCRs in which no design has been issued, and l which are not on the Work List. There are 318 FCRs in which the I design has not been issued but which are included on the Work List I for the completion of the design. The age of PCR backlog items is  !

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shown in Figure Figure 1 depicts the number of work items initiated each year that remain in the current backlog. To evaluate the age and appropriateness of the PCR backlog, the inspectors examined the following PCR packages.

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PCR Packages w/o Design & Not on Work List Examined Identification Title

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B 80-1-0845 Centrifugal Charging Pump Venting B 81-1-1098 Spent Fuel Handling Tool Storage Rack B 85-2-3322 CCW Flow Indicators PCR Packages w/o Design & Included on Work List Examined Identification Title  !

79-1-0340 Quadrant Power Tilt Ratio Measurement 84-2-2915 Replacement Carbon Steel Service Water 85-2-3332 Component Cooling Pump Room Coolers PDIs i

The licensee has 150 PCNs in which the design has been issued but are not included on the Work List, and 64 PCNs in which the design has been issued and are included on the Work List (prioritized, scheduled and included on the Work List awaiting implementation).

The PCN backlog over time is shown in Figure 1. To evaluate the age and appropriateness of the PCN backlog, the inspectors examined the following PCN package PCN Packages w/ Design & Not on Work List Examined PCN Title Identification S 79-1-0473 Radiation Monitor R14 8 80-1-0880 Nitrogen Pressurization System For Electri-cal Penetrations B 84-2-2535 Containment Pressure Isolation Valve Leak Test PCN Packages w/ Design & Included on Work List Examined PCN Title Identification S 80-1-0761 Fire Protection in Document Control File Room B 85-2-3325 Auxiliary Feedwater Pump Room Coolers PDI's ;

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PCN Packages w/ Design & Included on Work List Examined PCN Title Identification B 86-1-3805 Pressure Drop across the Electrical Penetra-tion Room - C Air Handling Unit Filter and Coil The licensee has identified approximately 155 PCNs, with completed design actions, as candidates for voiding based on a cost benefit analysis. These 155 PCNs are unscheduled. To date, the licensee site staff has recommended to void approximately 90 of the 155 PCN From the 90 PCNs which the site staff has recommended be voided, the inspectors selected the below-indicated PCNs for independent review to assess the basis for voidin .

Void-Recommended PCN Packages Examined PCN Title Identification 86-0-3693 Central and Secondary Alarm Station Intru-Admi sion Detection Alarm System Panels 79-1-0310 Main Control Board Annunciators Op Reactor Coolant Pump #2 Seal Leakoff Lines Op Flow Indication 80-1-0632 Aux. Feedwater Pump Bearing Temp. Indication Op Cover for Shield Wall around RWST and RMWST Op RCP #2 Seal Leakoff Flow Indications Op Control Room Gaitronics Op Containment Pressure Isolation Valve Leak SP Test 86-0-3690 Remote Fire Protection Annunciator Upgrade Tec Shielding of Penetration #34-100-47 Tec Shielding of Penetration #38-121-26 Tec .

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Void-Recommended PCN Packages Examined i PCN Title Identification (

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89-1-5942 Containment Smoke Detectors i Tec ]

The licensee indicated that all of the 155 unscheduled PCNs were t prioritized as Priority 9 - Operational Improvements, or Priority !

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10 - Convenience Improvements. Based on the above sample, the l

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inspectors concurred that the site recommendation to void the 90 unscheduled PCNs was appropriate. The remaining 65 PCNs are still I under consideratio l l

Engineering Studies (ES) and Request for Engineering Assistance :

(REA) ,

l The licensee has 246 active ES/REAs and 43 inactive ES/REA. The ,

age of the ES/REA backlog items is shown in Figure 1. To evaluate

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the age and appropriateness of the PCN backlog, the inspectors ,

examined the following ES/REA package Active ES/ REA Packages Examined l ES/REA Title Identification '

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86-0641 Maintain Second Ten Year ISI Sketches 88-1071 ISI Drawing Update - Unit 2

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90-1784 Service Water Heat Exchanger Performance l Testing  ;

Inactive ES/REA Packages Examined l

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ES/REA Title Identification 'J

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91-2107 Safety Analysis of Service Water  ;

92-2252 Auxiliary Feedwater Pump Testing l

92-2325 Unit 1 ISI Boundary Diagrams - Review, Up- l date, and Issue i The licensee estimated that the Farley plant has approximately 520 )

unimplemented PCNs. Of the 520, there are approximately 340 PCNs prioritized, scheduled and included in the Work List awaiting implementation, and 155 unscheduled PCNs. Of the approximately i 340 prioritized and scheduled PCNs at this time, 87 are scheduled 1

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for 1993 work periods,111 are scheduled for 1994 work periods, 107 for 1995 work periods, and 29 for 1996 work period l

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By interview and independent review of selected records, the inspectors determined that the engineering backlog is well controlled. The licensee does track the engineering backlog; however, the inspectors found no evidence that they trended the data. It should be noted that several of the packages that the i inspectors examined had been closed or had become moot due to i other licensee actions. Thus, the actual engineering backlog is ,

smaller than that believed by the licensee. The licensee '

indicated that they would review the engineering backlog and delete the completed and closed items as well as those items made '

moot by other actions in order to obtain a more accurate )

assessment of the backlo ; Engineering Support ,

The inspectors reviewed the activities of the engineering i disciplines at the site to determine the effectiveness of l

technical support given the various plant departments / section l The major engineering activities such as modifications, redesign, and problem solutions are coordinated by the corporate engineering group located in the company's main offices. The Generating Plant !

I Engineering group located at the site performs minor engineering j services, but along with the corporate engineering staff, performs '

a project management function for the interface between the plant and the various contracted engineering organizations that perform I the modifications, redesigns, and engineering studies activities for the license I The inspectors conducted interviews with various supervisors from l the security, health physics, operations, and mechanical maintenance departments to gain an understanding of the amount and extent of engineering support requested and received from the on-site and corporate engineering groups. Each individual representing a department or section informed the inspectors that they had received adequate support and felt that the requests for plant changes or modifications submitted by their department were J being evaluated in a timely manner and justification for delay or !

cancellation of a request was adequately supported by both plant and engineering managemen '

The inspectors reviewed a list of plant change requests submitted by the plant security section and the health physics section which were pending, partially completed, or denied. Discussions with l each of the- section representatives did not reveal any major

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concern regarding the screening of the PCRs. The inspectors considered the changes requested for each department to be l justified after the complete change request was described by ;

licensee personnel.

l Of the 12 PCRs submitted by the security section, 3 were deniad; 2 were approved but were not on the work scheduled; 2 were scheduled for outages in 1996; 2 had been completed; I had been scheduled l

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during 1993; 1 required delivery of parts; and I was being reviewed by the plant administration manage The health physics section had 7 open PCRs, 2 of which were cancelled because the cost of the modification would exceed the dose saving. I was incorporated into another plant change notice;

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and 4 were scheduled for an outage in 199 Discussions with maintenance personnel indicated that the site organization had a maintenance engineering group which supported l most maintenance activities. However, it was pointed out to the inspectors that the maintenance group could request assistance

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l from the corporate maintenance support group or the on-site j l engineering group. The licensee representatives stressed that the support received from these groups was prompt and very helpfu The operations personnel interviewed indicated that the support received from the various engineering organizations was effective l

and timel In addition to interviews with plant personnel, the inspectors reviewed a number of various plant records to evaluate the involvement of on-site engineering groups in support of daily plant activities. The types of documents reviewed for the various j engineering groups are characterized below:

. Production Modification Department Expedited PCRs to obtain rapid design assistance for short turn-around situation j

. Maintenance Engineering Support Group Problem Evaluation Reports which consist of problem identification, evaluation, conclusion and recommended resolution l

. Maintenance Case History Files which consist of problem identification, evaluation, action taken, and result . System Performance Engineering  ;

Summary listing of emerging technical problems where testing l was performed to identify the nature and extent of the i proble i l l

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. Problem Evaluation Reports Pertaining largely to pump and valve testing, these reports contained problem identification, ASME requirement applicability, actions or additional testing, and conclusion . Procurement j Material Evaluation Forms from June 1993 activitie . Plant Incident Reports

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Six plant incident reports were selected and reviewe ;

From review of the above documentation, the inspectors concluded that on-site engineering groups are strongly involved in support of plant day-to-day activities and '

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resolution of emerging technical problem i d. Self Assessment While in the corporate offices, the inspectors reviewed seven  ;

audit reports which documented QA audits performed by the SAER  ;

group. The inspectors selected audits of engineering contractors

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that had performed, or were performing, engineering services for l the licensee at the corporate offices. The audits were conducted i in accordance with the requirements of the following procedures:

f SAER Administrative Procedure No. 6, " Audit Implementation," which provides the guidance for preparation, conduct, and reporting of I audits. It requires a written plan, checklists, and defines the ,

various rating levels of finding '

SAER Work Procedure No. 22, " Nuclear Support," which gives the l guidance for conduct of audits of QA activities performed by  !

Nuclear Support Sectio i SAER Work Procedure No. 23, " Auditing of On-site and Off-site Vendor Services," which gives the guidance for auditing vendor '

groups as related to FNP.

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The findings in the audits were well documented and supported with adequate data, required responses as necessary, and were performed and documented in a timely manner. The findings were rated in accordance with procedure requirements and also used the applicable criteria of 10 CFR Part 50, Appendix B; ANSI N45.2-1977 and relevant supplemental standards; and 10 CFR 50.59 as the basis for findings and rating l i

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l The licensee has established additional methods to monitor the i I technical adequacy and quality of design outputs, such as the !

Technical Adequacy Review Board (TARB) and the Design Adequacy !

Review Committee (DARC). These two review groups provide an :

independent review of selected design packages by a multi- !

discipline panel of design specialists and managers. Selected design packages are distributed to the review panel prior. to panel

, meetings. At the meetings, the designer presents the design package and the panel discusses their comments as to the accuracy ,

completeness and quality of the design output. Another self assessment performed by the licensee is the review and analysis of the revisions (changes) to design packages issued for the previous ,

year. For 1992, the analysis showed that there were 813 revisions l on 120 PCNs. This analysis prompted the licensee to establish design review meetings at 10, 50 and 90% of design completio The intent of these meetings is to ensure that the designers understand clearly the customer's needs and obtain early input into the design proces i The inspectors reviewed selected meeting minutes from the TARB, ,

DARC, and the 10/50/90% review meetings. From this review, the )

inspectors concluded that the licensee has established self I assessment techniques for monitoring the quality of design outpu Within the areas inspected, no violations or deviations were identifie l l Exit Interview ,

The inspection scope and results were summarized on July 2 and July 13, 1993, with those persons indicated in paragraph 1. The inspec- ,

tors described the areas inspected. Although reviewed during this inspection, proprietary information is not contained in this report. No dissenting comments were received from the license t Acronyms and Initialisms

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ASME -

American Society of Mechanical Engineers l Aux -

Auxiliary l CCW -

Component Cooling Water DARC -

Design Adequacy Revicw Committee E&TS -

Engineering and Technical Support ES -

Engineering Study FNP -

Farley Nuclear Plant GPE -

Generating Plant Engineering ISI -

Inservice Inspection MCC -

Motor Control Center L MOV -

Motor Operated Valve

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Acronyms and Initialisms NEL -

Nuclear Engineering & Licensing ,

NPF -

Nuclear Power Facility i NRC -

Nuclear Regulatory Commission Professional Engineer '

PCN -

Production Change Notice PCR -

Production Change Request ;

PDI -

Differential Pressure Indicator -

RCP -

Reactor Coolant Pump  :

REA -

Request for Engineering Assistant RMWST -

Refueling Makeup Water Storage Tank ;

RWST -

Refueling Water Storage Tank .

SAER -

Safety Audit and Engineering Review !

TARB -

Technical Adequacy Review Board l

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