ML20005E314

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Eratta to Final SALP Repts 50-348/89-15 & 50-364/89-15 for Apr 1988 - Jul 1989
ML20005E314
Person / Time
Site: Farley  Southern Nuclear icon.png
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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Page

Line

Interim Report Reads

Final- Report Reads

coversheet

2

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

"

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'

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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

,

-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

{

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

!

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

i

--

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

.

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,

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

L

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

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-

i

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,

,

9-

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

I

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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ALABAMA POWER

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OCTOBER 30,1989

D0THAN, ALABAMA

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SALP PROGRAM

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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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Tunct"onal Areas

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Eng"neering/Techn"ca

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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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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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D. EMERGENCY PREPAREDNESS

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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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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

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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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APRIL 1,1988 through JULY 31,1989

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OPERATIONS PHASE VI0l& BONS /0PERATING REACTOR

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PLANT OPERATIONS - CATEGORY l

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OPERATIONS STAFF IS PROFESSIONAL, DEDICATED AND EXPERIENCED

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EFFECTIVE OPERATOR RESPONSE TO 0FF NORMAL CON 0!TIONS AND

PLANT TRANSIENTS

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WERE EVIDENT

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EXCELLENT

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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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EFFECTIVE DAILY PLANNING GROUP

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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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WAS EVIDENT

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AND EFFECTIVE

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SAFETY ASSESSMENT / QUALITY VERIFICATI0,N - CATEGORY 1

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RESOLUTION OF SAFETY ISSUES WAS EVIDENT

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LICENSEE EXHIBITED AGGRESSIVE APPROACH TO SIGNIFICANT

TECHNICAL ISSUES AND NRC INITIATIVES

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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

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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

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5hFETY ASSESSMENT / QUALITY VERIFICATION ACTIVITIES WERE

EFFECTIVE

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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'

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-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-

p-

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