ML19261B933

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IE Insp Rept 50-364/78-20 on 781211-14.Noncompliance Noted: Lack of Written Procedures Defining Responsibilities for Preservice Insp
ML19261B933
Person / Time
Site: Farley Southern Nuclear icon.png
Issue date: 01/05/1979
From: Conlon T, Crowley B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19261B927 List:
References
50-364-78-20, NUDOCS 7903070557
Download: ML19261B933 (6)


See also: IR 05000364/1978020

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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Report No.: 50-364/78-20

Docket No.: 50-364

License No.:

CPPR-86

Category: A2

Licensee: Alabama Power Company

Post Office Box 2641

Birmingham, Alabama 35291

Facility Name: Joseph M. farley Plant, Unit 2

Inspection at: Ashford, Alabama

Inspection conducted: December 11-14, 1978

Inspector:

B. R. Crowley

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Reviewed b

M;Y M _/

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T. E. Conlon, Chief

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Engineering Support Section No. 2

Reactor Construction and Engineering

Support Branch

Inspection Summary

Inspection on December 11-14, 1978 (Report No. 50-364/78-20)

Areas Inspected:

Pre-service inspection program, procedures and inspection

activities; housekeeping. This inspection involved 30 inspector-hours on-site

by one NRC inspector.

Results: Of the four areas inspected, no apparent items of noncompliance or

deviations were identified in three areas, one apparent item of noncompliance

(deficiency-lack of written procedures defining responsibilities for PSI,

Details, paragraph 5 was identified in one area).

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RII Rpt. No. 50-364/78-20

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DETAILS

Prepared by:

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B.~R. Crowley, Metallurgical (Engineer

Date

Engineering Support Section No. 2

Reactor Construction and Engineering

Support Branch

Dates of Inspection: December 11-14, 1978

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Reviewed by r

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T. E. Conlon,' Chief

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Engineering Support Section No. 2

Reactor Construction and Engineering

Support Branch

1.

Persons Contacted

Alabama Power Company (APCO)

a.

  • J. D. Woodard, Assistant Plant Manager

D. Morey, Maintenance Supervisor

  • D. L. Vines, Level III Examiner

M. Brown, Engineer

  • F. A. Wurster, Operations QA Engineer
  • D. L. Cox, Operations QA Engineer

b.

Contractor Organizations

(1) Southern Company Services (SCS)

  • T. B. Caudle, Pre-Service /In-Service Coordinator

(2) Westinghouse Electric Corporation, Nuclear Energy

Systems, Nuclear Services Division (W-NSD)

  • L. W. Lunden, Site Coordinator

J. E. Duvall, Shift Supervisor

(3) Zetec, Inc.

T. S. Beiers, Level IIA Examiner

  • Denotes those present at the exit interview.

2.

Lic_ensee Action on Previous Inspection Findings

Actions on previous findings were not examined during this inspection.

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3.

Unresolved Items

No unresolved items were identified during this inspection.

4.

Independent Inspection Effort

A general walk-through inspection of the reactor building was made.

General housekeeping and overall construction activities were observed.

In the areas inspected, no items of noncompliance or deviations were

identified.

5.

Pre-Service Inspection - Review of Program

The inspector reviewed the licensee's pre-service inspection (PSI)

program in the areas of program approval and QA program requirements,

including organizational structure and audit requirements.

Except for

the steam generator Eddy Current tube inspection, the applicable code

for the PSI is the ASME Boiler and Pressure Vessel Code,Section XI,

1974 Edition, with addenda through the Summer of 1975, as required by

paragraph 5.2.8 of ' .e FSAR.

The applicable code for the steam generator tube Eddy Current

inspection is Appendix IV to the Summer of 1976, addenda to Section XI.

The documents reviewed included:

" Westinghouse Examination Program for Pre-Service Inspection for

a.

Class 1 and 2 Components FNP-78-1362", and APC0 approval letter

dated November 30, 1978

Note

Program was not complete - sketches had only been issued for some

Class 2 lines

b.

" Westinghouse Examination Program for Pre-Service Eddy Current

Inspection of Steam Generators FNP-78-1364" and APC0 approval

letter dated November 30, 1978

c.

W-NSD procedure OPR-610-3, Revision 0

d.

W-NSD procedure MRS 2.4.2 GEN-18, Revision 0

e.

W-NSD "QA Program Plan", NSD-PA-001, Revision 3

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f.

APC0 Operating Quality Assurance (OPC) Administrative Procedures:

(1) OQA-AP-01, Revision 8

(2) OQA-AP-05, Revision 2

(3) 0QA-AP-06, Revision 4

(4) OQA-AP-07, Revision 8

(5) 0QA-AP-10, Revision 10

(6) OQA-AP-09, Revision 8

(7) 0QA-AP-11, Revision 11

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APC0 OQC Work Procedures:

(1) 0QA-WP-23, Revision 0

(2)

DQA-WP-29, Revision 0

During review of the licensee's program for the control of PSI, the

inspector found that certain of the licensee's organizational responsi-

bilities are not adequately defined by written procedures.

There is no

procedure defining who has the overall responsibility for pre-service

inspection. The pre-service /in-service coordinator, who works for SCS,

performs certain review and approval recommendation functions as well

as overall coordination and surveillance. None of his responsibilities

to the pre-service /in-service program are defined by procedure. An

APCO Level III examiner also performs certain review and approval

recommendations as well as surveillance during inspections. His respon-

sibilities are not defined by written procedures.

Discussions with

APC0 indicate that the Operations Maintenance Supervisor has the overall

responsibility for pre-service /in-service inspection. However, this

responsibility is not delineated in writing nor is his interface with

the above personnel or the pre-servica/in-service contractor described

by procedure. This lack of written definition of pre-service responsi-

bilities appears to be in noncompliance with Criterion I of Appendix B

to 10 CFR 50, which states in part, "The authority cd duties of persons

and organizations performing activities affecting the safety-related

functions of structures, systems and components shall be clearly esta-

blished and delineated in writing.

These activities include both the

performing functions of attaining quality objectives and the quality

assurance functions." At the exit interview, the licensee stated that

he considered that all authority and responsibilities were adequately

defined in APC0 administrative procedures - AP-1, Section 10; AP-3, Sec-

tions 5.1.2 and 5.6.5; and AP-15, Section 2.6.

The inspector reviewed

the aforementioned procedures and concluded that the personnel responsi-

bilities for PSI are not adequately defined in writing.

Therefore, this

is a deficiency and is identified as item 364/78-20-01.

In the areas inspected, no items of noncompliance, except as noted in

the above paragraph, or deviation were identified.

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6.

_ Pre-Service Inspection - Review of Procedures

The inspector reviewed the pre-service inspection procedures indicated

below relative to Eddy Current inspection of steam generation tubes to

determine whether the procedures were consistent with regulatory require-

ments and licensee commitments. See paragraph 5 above for the applicable

code.

The following procedures were reviewed:

W-NSD Procedure MRS 2.4.2 GEN-18, Revision 0, " Eddy Current Inspec-

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tion of Steam Generator Tubing - Pre-Service and In-Service"

Technical Supplement No. 1, Revision 2 to Procedure MRS 2.4.2

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GEN-18, " Steam Generator Tubing Inspection for Tube Wall Degradation -

Detection and Quantification"

These procedures were reviewed in the areas of:

Procedure approval, requirements for qualification of NDE

a.

personnel and procedure scope.

b.

Procedure technical content relative to; specification of two

channel examination unit and indication equipment, establishment

of criteria for maximum sensitivity, description of examination

method, description of calibration method and sequence, descrip-

tion of calibration block, and reference to acceptance standards,

Compilation of required records such as examination results and

c.

data sheets, tapes, equipment data, calibration data sheets and

calibration block data.

In the areas reviewed, no items of noncompliance or deviations were

identified.

7.

Pre-Service Inspection - Observation of Work and Work Activities

The inspector observed the pre-service activities described below

relative to steam generator tube Eddy Current inspection to determine

whether these activities were being performed in accordance with regula-

tory requirements and licensee procedures.

See paragraphs 5 and 6

above

r the applicable code and procedures.

Personnel qualification records for three Level I and three Level II

a.

examiners were reviewed.

b.

In process Eddy Current examinations, including the calibration

sequence, was observed for tubes C15-R6, C15-R7, C15-R8, C15-R9,

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C15-R10 and C15-R11 on the inlet side and tubes C83-R25, C83-R26,

C83-R28, C83-R29 and C83-R30 on the outlet side of steam generator

"A".

The inspection was compared with the applicable procedures

in the following areas:

(1) Program and procedures being followed

(2) Personnel familiar with examination methods

(3) Administrative controls for examination execution, altera-

tions and records

(4) Reference points clearly defined for future inspections

(5) Use of two channel examination equipment

(6) Use of maximum sensitivity as required

(7) Calibration requirements

(8) Percentage of tube coverage during examination

(9) Acceptance criteria

In the areas inspected, no items of noncompliance or deviations

were identified.

8.

Exit Interview

The inspector met with licensee representatives denoted in paragraph I

at the conclusion of the inspection and summarized the scope and

findings of the inspection.

The inspection included housekeeping and

pre-service inspection program, procedures and activities.

The

noncompliance of paragraph 5 was discussed and the licensee stated that

at this time they did not agree with the noncompliance.