ML20005E314
| ML20005E314 | |
| Person / Time | |
|---|---|
| Site: | Farley |
| Issue date: | 12/19/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20005E312 | List: |
| References | |
| 50-348-89-15, 50-364-89-15, NUDOCS 9001050049 | |
| Download: ML20005E314 (36) | |
See also: IR 05000348/1989015
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ENCLOSURE 2
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ERRATA SHEET
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Interim Report Reads
Final- Report Reads
coversheet
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Interim SALP Report
Final SALP Report-
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17
44-50-
The licensee's independent
Paragraph deleted
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security program audit....
. In-- addition toithe changes noted above, the summary statenent, " INDEPENDENT
AUDIT OF SECURITY PROGRAM DEEMED MARGINAL," which was included as a line item
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in the functional area SALP slides presented on October 30, 1989, is deleted to
reflect the change above (Enclosure 3).
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36-40
However, in the case of....
Lines 36-40 deleted
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ENCLOSURE
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-INTERIM SALP REPORT
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U. S.
CyARREGULATORYCOMMISSION'
kGION11
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SYSTEMATIC ASSESSMENT OF LI NSEE. PERFORMANCE
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-INSPECTION REPORT NUMB
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50-348/89-15 AND 50-364/89-15
ALABAMA #0WER COMPANY-
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JOSEPH M. FARLEY UNITS 1 AND 2
April 1,1988 - July 31,1989
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ENCLOSURE
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FINAL SALP REPORT
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U. S. NUCLEAR REGULATORY COMMISSION
REGION II
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SYSTEMATIC-ASSESSMENT OF LICENSEE PERF0RMANCE
INSPECTION REPORT NUMBER
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-50-348/89-15 AND 50-364/89-15
ALABAMA POWER COMPANY
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JOSEPH M. FARLEY UNITS 1 AND 2
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April 1.1988 - July 31.1989
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A program has been implemented to review and evaluate
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meterological data. This program includes weekly
surveillence and data review in addition to testing.
The. licensee maintains a current listing of all emergency
planning items which have cor.ective action not yet
,
completed.
This list is frequently updated and has been
eryv useful in tracking open items.
,
No viol tions or deviations were identified.
2.
Performanct Ratino - Category 2
3.
Recommendat
s - None
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E.
SECURITY AND SAFEGU
S
1.
Analysis
Th1s functional? area valuates the adequacy of the security
program to provide pro
ion for plant vital systems and
equipment. The scope o
is assessment includes all licensee-
activities associated wit
e security plan and implementing
c
procedures, management eff
veness. security audit program,
d maintenance, access control,
records and reports testin
y$ assessment armed response.
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physical barriers, detection
--alarm stations, power supply,
unications, and compensatory
measures for degraded security s stems and equipment.
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' Authority and responsibilities as's iated with the security
organization were clearly delineate and effective.
In January
,
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1989, a change in the Security Superi
endent resulted from
retirement of the previous individual.
This management change
did not affect the continued professiona performance of.the
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security force. The site's proprietary s urity force is
adequately staffed and appropriately traine and equipped. The
licensee has provided the security force wit adequate
procedures.
Security plan changes have been
bmitted-on a
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timely basis and licensee records are complete nd adequately
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maintained. An exception was the safeguards ame ment problems
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noteo in Section G below. The licensee's safegua s event
reports have been prompt and complete.
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The licensee's independent security program audit cove ed
various aspects of the site security program. However, the
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thoroughness and familiarity with the applicable regulat ns on
the part of the auditors was marginhl. The audit report m de
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references to nonapplicable parts of 10 CFR (73.40, 73.45 a
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73.46). Therefore, we question the cualifications of person 1
who performed the audit and the validity of the audit findings
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A program has been implemented to review and evaluate
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wterological data. This program includes weekly
. surveillance and data review.in addition to testing.
The licensee maintains a current listing of all emergency
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planning iteins which have corrective action not yet
i
completed. This list is frequently updated and has been
very useful in tracking open items.
'No violations or deviations were identified.
2.
Performance Rating - Category 2
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Recomendations - None
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E.
SECURITY AND SAFEGUARDS
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1.
Analysis
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This functional area evaluates the adequacy of the security
program to provide protection for plant vital systems and
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equipment. The scope of this assessment includes all licensee
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activities associated with the security plan and implementing
procedures. management _ effectiveness, security audit program,
records and-reports, testing and maintenance, access' control,
physical barriers, detection and assessment, armed. response,
alarm stations, power supply, 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
L
1989, a change in the Security Superintendent resulted from
retirement of the previous individual.
This management change
did not affect the continued professional performance of the
p
security force. ' The site's proprietary security force is
adequately staffed and appropriately trained and equipped. The
licensee has provided the security force with adequate
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procedures. Security plan changes have been submitted on a
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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
reports have been prompt and complete.
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tiers, bulletins, and information notices; and resolution of
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items and other regulatory initatives'. Also included were
rey ews of licensee resolution of safety issues,10 CFR 50.59
revi
s,10 CFR 21. assessments, safety review committee and self
asses ent activities, industry's operational experience, root
cause a alysis of plant events, use of feedback from quality
,
assuranc , and self assessment programs.
In. general, the licensee's responses to bulletins and generic-
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letters (GL) have been timely, sound and thorough.
The.
engineering e luations were generally adequate; however, they-
were not as co istently technically adequate or as complete as "
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during the past eviews.
As an example, the licensee's response
to GL 88-17 " Loss of Decay Heat Removal" was timely, but lacked
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technical detail a d will be subject to further audit.
During
reviews of GL 82-28, 'binstrumentation for Detection of
Inadequate Core Cool h"thestaffnotedthatthelicensee
- exhibited a general u.n e$ standing of issues and performed
adequate engineering ev gations,
,
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The licensee's original s
ittals related to miscellaneous
safeguards amendments were
king several commitments that were
required prior to our approv
of the revised security plan.
Several subsequent revisions
re needed before the licensee
provided adequate detailed inf mation necessary for the
approval of the plan.
The resol tion of'those safeguards issued
delayed completion of this review
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Except for the above, the licensee's submittals were usually-
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thorough, accurate, and timely. The
icensee exercised good
judgement in requesting only those ame ments-which were
necessary.
Resolutions of staff concer
were timely, complete,
and required little follow-up.
The licen ee was receptive to
,
staff comments and responded quickly to st ff requests for
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information when needed to complete-a licen ing action.
However, in the case of a final report neede by our staff to
assist in generic resolution of Bulletin 88-0
the licensee's
late submittal of that report delayed the techn cal review of
this issue. Better commitment tracking or manag
ent attention
could have prevented this delay.
The licensee has continually exhibited foresight in heir
approach to significant technical licensing issues.
an
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example, since 1986 the licensee has performed eddy cu ent
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tests of the incore detector thimble tubes to detect pot ntial
tube leaks caused by the tube thinning. Their program re ulted
in early detection of problems for which corrective action as
initiated. These actions preceded NRC Bulletin 88-09.
As
result, the licensee's response to Bulletin 88-09 was
technically sound, thorough and consistent with the bulletin
request. An example of excellent licensee response to NRC
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letters, bulletins, and information notices; and resolution of
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TMI items and other regulatory initatives. Also_-included ware
reviews of licensee resolution of safety issues, 10 CFR 50.6
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,
e'
In general, the licensee's responses to bulletins and generic
'~
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
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.
-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
request. An example of excellent licensee response to NRC
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ENCLOSURE 3
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EXITED STATES
XECLEAR REGELATORY
COMMISSION
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LICENSEE PERFORMAXCE
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ALABAMA POWER
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COMPANY
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SALP PERIOD
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OCTOBER 30,1989
D0THAN, ALABAMA
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REGION H ORGANIZATION
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DIVISION OF REACTOR PROJECTS
ORGANIZATION
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DM90N OF
REACTOR PROJECTS
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DEPUTY
C. HEHL
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REACTOR PROJECTS
REACTOR PROJECTS
REACTOR PROJECTS
BRANCH N0.1
BRANCH N0, 2
BRANCH N0. 3
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NRR ORGANIZATION
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OR.
THOWAS L IAIREY
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ASSOC. DIRECTOR FOR
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PROJECTS
INSPECTION &
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J. PARTLOW
TECHNICAL ASSESSWENT
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DIV. OF REM 4011
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DMSION OF
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COMANCHE PEAK
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SALP PROGRAM
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REVISIOXS
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MAJOR CHANGES TO THE
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SALP PROGRAM CONSIST OF...
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- Redef"n t on of Funct o.nal Areas
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- Reduct on "n Number o" Separate
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Tunct"onal Areas
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"wo New Functional Areas
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- Eng"neering/Techn"ca
Support
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- Sa"ety Assessment / Quality Ver"f" cation
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- A" tributes Acdressing -uman Performance
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and Se f-Assessmen"
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- Emphas"s on Analysis
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PERFORMANCE AXALYSIS AREAS
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FOR OPERATIXG REACTORS
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A. PLANT OPERATIONS
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B. RADIOLOGICAL CONTROLS
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C. MAINTENANCE / SURVEILLANCE
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E. SECURITY
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F. ENGINEERING / TECHNICAL SUPPORT
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G. SAFETY ASSESSMENT / QUALITY VERIFICATION
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ENGINEERING / TECHNICAL
SUPPORT
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The purpose of this func<:ional area
is <:o address tie adequacy of :echnical
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and engineering suppor: for all plant
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activities.
It includes all Ucensee
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Activities associated wit, the design
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of plant modifications; engineering and
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technical sunort for opera': ions, outages,
maintenance, <:esting, surveillance; and
arocurement ac:ivities;
- raining; anc
configuration manocement 'inc uding
maintaining cesign bases and margins).
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SAFETY ASSESSMENT / QUALITY VERIFICATIO
The purpose of this funtional area is to address the
technical odequacy and completeness of the licensee's
opproach toward a variety of activities associated with
the implementation of licensee safety policies and
licensee octivities related to amendment requests, exemption
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requests, relief requests, response to generic letters,
bulletins, and information notices and resolution of TWI
items and other regulatory initiatives,
it also includes
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licensee activities related to the resolution of safety
issues,10 CFR 50.59 reviews,10 CFR 21 ossessments, safety
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committee omd self-assessment activities, analysis of
industry's operational experience, root cause onolyses of
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plant events, use of feedback from plant quality assurance /
quality control (QA/QC) reviews, and participadon in self-
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improvement programs,
it includes the effectiveness of the
licensee's quality verification function in identifying
substandord or onomalous performance in monitoring the
overall performance of the plant.
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PERFCRMANCE RATING CATEGCRIES
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- HPANDD DECUSSION DffENT
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- RDEFINITION OF THE CATBG0RES
TO CIARIFY TIHER MEANINC
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AREA PERFORMANCE
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CMGW 1
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UCENSEE MANAGEMENT ATTENTION AND INVOLVEMENT
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ARE READlLY EVIDENT AND PLACE EMPHASIS ON SUPERIOR
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PERFORMANCE OF NUCLEAR SAFETY OR-SAFEGUARDS
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ACTNTIES, WITH THE RESULTING PERFORMANCE SUB-
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STANTIALLY EXCEEDING REGULATORY REQUIREMENTS.
UCENSEE
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RESOURCES ARE AMPLE AND EFFECTNELY USED SO 1 HAT
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A HIGH LEVEL OF PLANT AND PERSONNEL PERFORMANCE IS
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BEING ACHEIVED.
REDUCED NRC ATTENTION MAY BE
APPROPRIATE.
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AREA PERFORMAXCE
CA7EGORY2
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UCENSEE MANAGEMENT ATTENTION AND INVOLVEMENT
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IN THE PERFORMANCE OF NUClf.AR SAFE 1Y OR SAFEGUARDS
ACTMTIES ARE GOOD.
THE UCENSEE HAS ATTAINED A
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LEVEL 0F PERFORMANCE ABOVE THAT NEEDED TO MEET
REGULATORY REQUIREMENTS,
UCENSEE RESOURCES ARE-
ADEQUATE AND REASONABLY ALLOCATED S0 THAT GOOD PLANT
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AND PERSONNEL PERFORMANCE IS BEING ACHEWED.
NRC
ATTENTION MAY BE MAINTAINED AT NORMAL LEVELS.
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AREA PERFORMANCE
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CMGORY J
UCENSEE MANAGEMENT ATTENTION AND INVOLVEMENT
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IN THE PERFORMANCE OF NUCLEAR SAETY OR SAEGUARDS
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ACTMTIES ARE NOT SUFFICIENT.
THE UCENSEE'S
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PERFORMANCE DOES NOT SIGNIFICANRY EXCEED THAT NEEDED
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TO MEET MINIMAL REGULATORY REQUIREMENTS.
UCENSEE
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RESOURCES APPEAR TO BE STRAINED OR NOT EFFECINELY
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USED.
NRC ATTENTION SHOULD BE INCREASED AB0VE
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NORMAL LEVELS,
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EVAILATIOX CRITERIA
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1. MANAGEMENT INVOLVEMENT IN ASSURING QUALITY
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2. APPROACH TO RESOLUTION OF TECHNICAL ISSUES
FROM A SAFETY STANDPOINT
3. RESPONSIVENESS TO NRC INITIATIVES
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4. . ENFORCEMENT HISTORY
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5. REPORTING AND ANALYSIS OF REPORTABLE EVENTS
6. STAFFING (INCLUDING MANAGEMENT)
7. TRAINING EFFECTIVENESS AND QUALIFICATION.
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VIOLATION SUMMARY
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OPERATIONS PHASE VI0l& BONS /0PERATING REACTOR
APet 1, im ihmish an.Y 31,1989
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PLANT OPERATIONS - CATEGORY l
I
CORPORATE OVERSITE EVIDENT BY FREQUENT VISITS AND PLANT
TOURS BY SENIOR MANAGEMENT
REDUCTION IN NUMBER OF REACTOR TRIPS FOR THIS SALP CYCLE
i
OPERATIONS STAFF IS PROFESSIONAL, DEDICATED AND EXPERIENCED
!
'
EFFECTIVE OPERATOR RESPONSE TO 0FF NORMAL CON 0!TIONS AND
PLANT TRANSIENTS
s
. INTERNAL INCIDENT RESPONSE SYSTEM IS EFFECTIVE AND
CONTRIBUTES TO LOW REPETITIVE EVENTS
[
'
PLANT CLEANLINESS CONSIDERED AVERAGE AND NEEDS IMPROVEMENT
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PROCEDURE COMPLIANCE IS A CONCERN
DEPARTURE FROM INTENT OF NRC GUIDANCE ON OVERTIME IS
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A CONCERN
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MANAGEMENT SUPPORT AND INVOLVEMENT IN RADIATION PROTECTION
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WERE EVIDENT
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KNOWLEDGE AND EXPERIENCE LEVEL OF HEALTH PHYSICS STAFF WERE
EXCELLENT
\\
REDUCTION IN CONTAMINATED AREA AND PERSONNEL EXPOSURES A
STRENGTH
SPIKED SAMPLE ANALYSIS COMPARISONS SHOWED EXCELLENT
AGREEMENT EXCEPT FOR FE-55
INITIATIVES TO REDUCE RADWASTE IS A PLUS BUT NEED CONTINUED
EMPHASIS
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SIGNIFICANT REDUCTION IN THE NUMBER OF ABNORMAL GASEOUS OR
LIQUID RELEASES
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ORGANIZATION PROVIDED
EFFECTIVE
SUPPORT
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P
TO OPERATIONS
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MANAGEMENT INVOLVEMENT AND ALLOCATION OF RESOURCES EVIDENT
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INITIATIVES IN PREDICTIVE MAINTENANCE PROGRAM EVIDENT
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SELF INITIATED PROCEDURE UPGRADE PROGRAM NOTED
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EFFECTIVE DAILY PLANNING GROUP
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WEAKNESS
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ABILITY TO ADEQUATELY IMPLEMENT KEY ELEMENTS OF EMERGENCY
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PLAN DEMONSTRATED
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IMPROVEMENT IN ALERT AND NOTIFICATION SYSTEM NOTED
-
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SECURITY - CATEGORY 1
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SECURITY FORCE IS PROFESSIONAL, DEDICATED AND EXPERIENCED
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SECURITY STAFF-IS WELL TRAINED
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FEW SECURITY ENFORCEMENT ISSUES
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MCA PROGRAM IS EXCELLENT
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MANAGEMENT INVOLVEMENT AND UNDERSTANDING OF TECNNICAL ISSVES
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WAS EVIDENT
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USE OF VENDOR TECHNICAL ASSISTANCE TO SUPPORT FLANT
OPERATIONS WAS EFFECTIVE
CORPORATE ENGINEERING SUPPORT ON MAJOR DESIGN ISSVES IS TIMELY
,
AND EFFECTIVE
,
ENGINEERING SUPPORT ON MINOR DESIGN CHANGES AND DAILY PLANT
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SAFETY ASSESSMENT / QUALITY VERIFICATI0,N - CATEGORY 1
MANAGEMENT, ENGINEERING AND PLANT OPERATIONS INVOLVEMENT IN
RESOLUTION OF SAFETY ISSUES WAS EVIDENT
i
LICENSEE EXHIBITED AGGRESSIVE APPROACH TO SIGNIFICANT
TECHNICAL ISSUES AND NRC INITIATIVES
,
NEED FOR ROOT CAUSE ANALYSIS TRAINING RECOGNIZED
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SELF INITIATED SAFETY SYSTEMS ASSESSMENTS
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RESPONSE TO NRC BULLETINS AND GENERIC LETTERS USUALLY TIMELY
AND COMPLETE
LER SUBMITTALS ARE COMPLETE AND WELL ORGANIZED
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PEER REVIEW PROGRAM WLAKNESSES IDENTIFIED
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APPARENT
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RADIOLOGICAL CONTROLS CONSIDERED A STRENGTH
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MAINTENANCE / SURVEILLANCE PROGRAM VIEWED AS A STRENGTH
,
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EMERGENCY PREPAREDNESS NEEDS ATTENTION TO LICENSEE- AND NRC
IDENTIFIED WEAKNESSES
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-SECURITY' PROGRAM IS STRONG BUT MAJOR PLAN REWRITE
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IS HEEDED
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5.(EQUALIFICATION PROGRAM NEEDS ATTENTION
.
5hFETY ASSESSMENT / QUALITY VERIFICATION ACTIVITIES WERE
EFFECTIVE
,
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' e' '
ENCLOSURE 4
.- r
Alabents Power Company .
- .--
. 40 Ingmoes Cemet Pertwey -
~
Poet Offee tem its6
Birmingham. Alabome 36701
W ohe 306 see 6661
W. 9. Meissten, ill
sener ve presteeni
AlabamaPbwer
Nuclett Operateene .
N '0**msectres m
November 27, 1989
l
Docket Mos. 50-348
50-364
<
U. S; Nuclear Regulatory Commission
l -
ATTN Document.C'~a* ml Desk
L
Vashington, D. C. 20.'S
Gentlemen
'
L
-Joseph M. Parley Nuclear Plant Units 1 and 2.
'
NRC Inspection Report Nos. 50-348/89-15 ard 50-364/89-15
By letter dated October 5,1989, the NRC forwarded the results of the
Systematic Assessment of Licensee' Performance (SALP) Board evaluation of
Parley Nuclear Plant for 1989. Alabama Power Company has reviewed this
report and provides comments in an attachment to this letter.
.
Alabama Power Company appreciates the opportunity to provide comments on
"
the SALP report and requests that these comments be considered in the NRC's
final conclusion. In addition to the attached comments, Alabama Power Company
requests that comments and discussions from the October 30, 1989 meeting be
,
taken into consideration for final disposition of the SALP report.
'
If you have any questions, please advise.-
Respectfully submitted,
!
st
I
.
r
L
VGH,TTI/BHVimi 10.58
Atcschment
cci Mt ., S. D. Ebneter
Mr. E. A. Reevet,
l
t'r. G. F. Maxwell
.,
._
- _ .
.
-
-
-
-
-
-
-
_
_ _ - _ - . . . . . . .
. . .
6
,a'
f
-O
Attachsent
<
1989 SALP Commenta
NRC Inspection Report Nos.
50-348/89-15 and 50-364/89-15
No.
Referonee
Comment
1.
Page 17
The report indicates concern by the NRC
.(Section IV.E.1)
regarding the audits performed within
the security-area because the security audit
checklists reference 10CFR73 40, 73.45 and
73.46 which are not applicable for PNP. The
NRC then concludes that the qualifications of-
the auditors and validity of the audit
findings are in question.
'The conclusion reached is apparently based
solely on this single issue. APCo questions
this conclusion based on the following:
1. The comment regarding the
qualifications of APCo auditors was
not presented at the exit meeting.or
in Inspection Report 89-18, which
initially posed the issue of sections-
73.40,-73.45, and 73.46.
2. The three checklist items represent-
less-than 3 percent of the more than
105 checklist items assessed during
.
the security audit reviewed.
'
3. None of the findings included in the
final audit report were indicated as
being non-valid.
4. No specific findings related to
inadequate qualification of an suditor
have been presented.
. ..
t
. - - - . - - . . - . - . - . - - - . - .
, .
s,
pg.[ '
l
4
.
.o
a
>
Page-f-
-
1
c
~ No .
Reference
Comment
,
<
1. (Continued)
Finally, with specific regard to the
three sections in question (10CPR73.40, 73.45
and 73.46), APCo recognises the potential for
'
nonapplicability of at least some of these
i
sections. The-criteria of 10CFR73.20 would-
currently exempt. PNP from the requirements of
73.45 and 73.46 given the current amount of
strategic nuclear fuel maintained on site.
However, APCo is' currently of the opinion that
10CFR73.40 does in faet apply eince 10CPR73 55
,
is referenced and should be audited.- It is
definitely not clear how this approach.
..
represents a lack of qualifications on the
,
part of the FNP audit staff or casts doubt on-
-the validity of the audit findings.
2.-
Page 21
The report states that APCo's late submittel
a
(section IV.G.1)-
of a report relating to the cracked RER
pipe at FNP needed by the NRC to assist in
generic resolution of Bull ^ tin 88-00, delayed
the NRC's technical reviev~of this issue.
-t
,
No formal requests by the NRC or commitments
by APCo were made to submit this report. APCo
does not understand how the NRC can: cite this
'
issue as a defielency.- APCo provided this
report to the NRC immediately after receipt
I
from Vestinghouse. APCo cooperated completely
i,
l '
vere actively involved with the efforts being
with the NRC on this issue.- NRC-personnel
taken by APCo to evaluate and resolve this
issue.
p
r
UCR,III/BNVand 11.39
l-
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