ML20118A145

Staff Exhibit S-82,consisting of 831202 Memo Re Composite Audit Rept 83/19 for Plant

ML20118A145
Person / Time
Site:	Farley
Issue date:	05/18/1992
From:	Mcgowan J ALABAMA POWER CO.
To:
References
CIVP-S-082, CIVP-S-82, NUDOCS 9208030142
Download: ML20118A145 (6)

Text

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Cottcsponsonce Q-(!Il/h 6l/8l9 2-AlabD41!)POWCf O

c..~ m a Joseph M. Farley Nuclear Pirnt M -2 m 3 Composite Audit Report No. 63/19 December 2, 1983

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SAER File:

A35.94.1 Log:

83-417 J. W. McGowan 1

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m Safety Audit &

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Mr. R. P. Mcdonald Engineeiing Review Mr. W. G. Mirston, III Attached are reports of SAER audits recently ecnducted at the Farley Nuclear Plant.

A schedule of Routine and four-Month Interval SAER audits to be conducted within the next four (4) months anti 6 schedule of SAER audits to be performed of f site are also ett sched.

l The following is informaWn concerning the attached audit reports:

Activities Or Auditor Dr Audit Report Date Areas Audited

, Type Audit Team Leader 11-15-83 Environmental Spot R. V. Badham Qualification Program 11-17-83 Plant Changes and Routine W. G. Ware Nodifications 11-21-83 Unit !! lurbine Vendor R. V. Badham Generator Maintenance conducted by Westinghouse 12-2-83 Four. Month Interval Routine G. M. Grove

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. W. McGow&n.

DAJ:sh Attachments xc + Attachments:

Mr. W. O. Whitt Mr. F. L. Clayton, Jr.

Mr. H. O. Thrash Mr. W. G. Ware (SSAER Record)

Mr. G. M. Grove Mr. D. A. Johnson 9200030142 920510 PDR ADOCK 05000348 O

PDR

B irt Date November 1$. 1983 h,e 1 of 4 7

ALABAMA POWER COMPANY JOSEPl! M. FARLEY NUCLEAR PLANT O-REPC97 OP SAER AUDIT 4.

Audit Description Organization Audited:

Farley Nuclear Plant Staff t

General Area Audited:

Environmental Qualification Program 0.*casion of Audit:

Spot Date(s) of Audit:

October 20 - November 1$, 1983 Audit Team Leaders-R. V. Badham i

Principal Sections Individual Audited Organization of Audit Auditor (s)

Representatives 1.

Pre-audit W. G. Ware W. G. Hairston, 111 Conference R. V. Badham J. D. koodard R. G. Berryhill L. W. Enfinger 2.

Conduct of R. V. Badhsm R. G. Berryhill O

^=dit a r c' v

t w t=ri i r W. R. Sampson L. M. Stinson J. B. Hudspeth

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L. Huey J. Scales 3.

Post-audit W. G. Ware J. D. Woodard Conference J. F. Cheney R. G. Berryhill W. R. Sampson L. W. Enfinger D. N. Morey L. M. Stinson B.

Noncompliances FNP-NC-47-83/19(8)

FNP-0-ETP-4108 par. 2.3' requires that NITS will forward the Environmental Qualification Report Evaluat. ion (EQRE), CEVS, appropriate calculations evaluation summaries and vendor test reports" to the Systems Perforreance Superintendent for storage in Document Control.

Contrary to this, the EQREs are not in Document Control and several of the test reports refer-

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enced-in Appendix III are not available.

NOTE:

Per Paragraphs ('

and (j) of 10CFR50.49, it appen.s these recordt, are regt*i wd to be maintained in auditable form.

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,rt Dato: Nove:ber 15, 1983 F. j 2 of 4 I'NP-N C 83 /19 ( B )

The OQAPM, par. 3.5.2 requires in part, "The following are to be accom-piished and recorded for each... design change...Completior of drawing, technical manual...and other documentation changes as applicable."

Contrary to thin, a review of instruction books and vendor drawings for two systems (Teedwater Control and Containment Cooling and Purge) listed in the Master 1.ist (Appendix 1 of ETP-4108) which have had numerous changes to install environmentally qualifiet equipment revealed that in no case had the vendor drawings or instruction books been re-vised to reflect the new equipment.

Discussion: A review of some of the PCNs that implemented these changes revealed that in no case had instruction books or vendor drawings been identified as requiring changes.

The PM program for this environmentally qualified equipment requires that appropriate vendor service manuals (TNi-0*ETP-4108 par 3.1.2) be referenced for the performance of PM tasks.

Although the appropriatt vendor drawings and instruction books are refer-enced in the PM Program in no case where a design change had occurred did those references reflect the current equipment installed.

TNP-NC-49-83/19(8),

10CTR50.49(d) requires that "The licensee shall prepare a list of electric equipment important to safety".

10CTR50.49(a) requires "Each holder of..a license...shall establish a program for [ environ-mentally) qualifying electrical equipment." Contrary to this, Section O,

C of ApCo's letter to the NRC dated May 20, 1983 which was written to comply with those requirements incorrectly identifies Containment Cooler Tan Motors (TPNS #Q1E12M001B, C & D) as Type P.

These motors are Type M/YE which is not an approved Model based on the Acceptable Test Reports List.

NOTE:

Section C of the above letter has been incorporated into TNP-0-ElP-4108 as Appendices 1 and II.

C.

Cocene nt s 1.

Several of the Acceptable Test Reports in Document Control do not reference the specific equipment for which they are tpproved.

2.

A definition should be provided for "Date Installed" as used in the Component Maintenance and Replacement Schedule." It appears that the date the applicable Unit returned to service after an outage (or initial startup) is being used for this date. The actual installation date for the specific item of equipment is not being used.

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R 3rt Date Novenbar. 15, 1983

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Comments Con't O

3.

1he fo11owin. errors ere neted in rxP-0-t1P-4108 Rev. o:

a.

Par. 3.1.6 assigns the Maintenance Planners who write MVRs to thes Maintenance Group.

b.

No Model number it. listed on the Acceptable Test Reper's List for Limitorque NOVA.

c.

Unit 1 - Haster List has numerous model number errors for the reedwater Control System (C-22).

d.

An inco: rect installation date for the limit switches on system i

P15.

e.

Par. 2.3 references a Figure 1 and 2.

These figures are missing from the ptocedure.

Also Figures 3 and 4 are missing.

4.

FNP-0 ETP-4108 which tras issued on 10/20/83 has not received a i

cross-discip1foary review although various plant groups are assigned respois &,11 ties therein. Also, it does not appear that personnel imW ementing this procedure have received traf. ting.

5.

Based on two sys ems reviewed there are several discrepancies between the Haster List and Ccmponert Maintenance and Replacement Schedule as-regards model number tor a particular TPNS number.

6.

Limit switches Q1P13e.S2866B and 2867B-(per the Component Hafntenance and Replacement Schedule) are on the Haster List as 2866D and 2867D.

This same discrepancy occurs on Unit 11.

7.

Although 10CTR50.49(j) requires that documentation be maintained in auditable form for the entire period during which the covered item is installed or stored for future use no RTYPE or retention time has been designated for these environniental records.

D.

Reaudit Results 1.

Open concompliances:

N/A, Tirst Audit 2.

Closed noncompliances:

N/A, First /.udit 3.

Reconfirmed noncomplian,cs.

N/A, First Audit E.

Summary 1.

Identifications of last equivalent audit: N/A, First Audit.

2.

Number of noncompliances last audit: N/A. This audit: 3_.

port Date: November 15,-1983 sage 4 of 4 e

i E.

Summa ry Con't 3.

Trend since last equivalent audit in significance of individual noncompliances:

N/A, first Audit.

4.

Auditor's evaluation of the effectiveness of the OQA program elements audited: As noted in the above findings, the Envitsament:1 Qualification Program does not yet fully comply with the requirements of 10CTR50.49.

r in its present state of development the program does not provide assur-ar.cc that the environmental qualification cf equipment will be maintained ',

throughout the life of the plant.

T.

Recommendations None r

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' Audit Team Leader O

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