ML20127L199
| ML20127L199 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 03/29/1985 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20127L181 | List: |
| References | |
| 50-348-85-06, 50-348-85-6, 50-364-85-06, 50-364-85-6, NUDOCS 8506270793 | |
| Download: ML20127L199 (22) | |
See also: IR 05000348/1985006
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ENCLOSURE
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SALP BOARD REPORT
U.S. NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
INSPECTION
REPORT NUMBERS
50-348/85-06, 50-364/85-0G
Alabama Power Company
Joseph M. Farley Units 1 and 2
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August 1, 1983 through December 31, 1984
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I.
INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect available observations and data on a
periodic basis and to evaluate licensee performance based upon this informa-
tion.
SALP is supplemental to normal regulatory processes used to ensure
compliance with NRC rules and regulations.
SALP is intended to be suffi-
ciently diagnostic to provide a rational basis for allocating NRC resources
and to provide meaningful guidance to the licensee's management to promote
the quality and safety of plant construction and operation.
An NRC SALP Board, composed of the staff members listed below, met on
February 20, 1985, to review the collection of performance observations and
data and to assess the licensee performance in accordance with the guidance
in NRC Manual Chapter 0516. " Systematic Assessment of Licensee Derformance."
A summary of the guidance and evaluation criteria is provided in Section !!
of this report.
This report is the SALP Board's assessment of the licensee's safety perfor-
mance for the J. M. Farley facility for the period August 1,1983 through
December 31, 1984.
SALP Board for the J. M. Farley facility:
R. D. Walker, Director, Division of Reactor Projects (DRP), Region !!
(RII) (Chairman)
P. R. Bemis, Director, Division of Reactor Safety, R!!
K. P. Barr, Acting for the Director, Olvision of Radiation Safety and
Safeguards, RI!
D. M. Verre111, Chief, Projects Branch 1, DRP, RI!
0. D. Parr, Chief, Auxiliary Systems Branch, Division of Systems
Integration, Office of Nuclear Reactor Regulation (NRR)
Attendees at SALP Board Meeting:
K. D. Landis, Chief, Technical Support Staff (TSS), ORP, RI!
W. Bradford, Senior Resident inspector, J. M. Farley, DRP, RI!
D. S. Price, Reactor Inspector, TSS, DRP, RI!
T. C. MacArthur, Radiation Specialist, TSS, DRP, R!!
E. Reeves, Project Manager, Operating Reactors Branch 1, Division of
Licensing, NRR
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CRITERIA
Licensee performance is assessed in certain functional areas depending upon
whether the facility has been in the construction, preoperational, or
operating phase. Each functional area normally represents an area which is
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significant to nuclear safety and the environment, and which is a normal
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programmatic area.
Some functional areas may not be assessed because of
little or no licensee activities or lack of meaningful observations.
Special areas may be added to highlight significant observations.
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One or more of the following evaluation criteria were used to assess each
functional area:
A.
Management involvement and control in assuring quality
B.
Approach to the resolution of technical issues from a safety standpoint
C.
Responsiveness to NRC initiatives
D.
Enforcement history
E.
Reporting and analysis of reportable events
F.
Staffing (including management)
G.
Training effectiveness and qualification
However, the SALP Board is not limited to these criteria and others may have
been used where appropriate.
Based upon the SALP Eoard assessment, each functional area evaluated is
classified into one of the three performance categories. The definitions of
these performance categories are:
Category 1:
Reduced NRC attention may be appropriate. Licensee management
attention and involvement are aggressive and oriented toward nuclear safety;
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licensee resources are ample and effectively used so that a high level of
performance with respect to operational safety or construction is being
achieved.
Category 2:
NRC attention should be maintained at normal levels. Licensee
management attention and involvement are evident and are concerned with
nuclear safety; licensee resources are adequate and are reasonably effective
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so that satisfactory performance with respect to operational safety or
construction is being achieved.
Category _3:
Both NRC and licensee attention should be increased. Licensee
management attention or involvement is acceptable and considers nuclear
safety, but weaknesses are evident; licensee resources appear to be strained
or not ef fectively used so that minimally satisfactory performance with
respect to operational safety or construction is being achieved.
The SALP Board has also categorized the performance trend over the course of
the SAlp assessment period.
The trend is meant to describe the general or
prevailing tendency (the performance gradient) during the SALP period. This
categorization is not a comparison between the current and previous SALP
ratings.
It is a determination of the performance trend during the current
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SALP period irrespective of performance during previous SALP periods. The
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categorization process involves a review of performance which occurred
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during the course of that period.
The performance trends are defined as
follows:
Improving:
Licensee performance has generally improved over the course of
the SALP assessment period.
Constant:
Licensee performance has remained essentially constant over the
course of the SALP assessment period.
Dec1tning:
Licensee performance has generally declined over the course of
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the SALP assessment period.
III. SUMMARY OF RESULTS
Overall Facility Performance
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The Farley facility is managed by well qualified and experienced personnel.
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Senior plant managers hold active senior reactor operator licenses and the
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site is supported by a corporate organization that is composed of personnel
who have extensive backgrounds in nuclear plant management and operations.
The licensee remains responsive to NRC concerns and the organization is
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safety oriented.
Strengths were identified in the areas of plant
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operations, radiological controls, maintenance, fire protection, emergency
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proparedness, refueling, training, and licensing activities.
No weakness
were identified,
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Trend During
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August 1, 1982 -
August 1, 1983 -
Latest
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Functional Area
July 31, 1983
December 31, 1984
SAlp Period _
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Plant Operations
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Constant
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Radiological Controls
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Constant
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Maintenance
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Constant
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Surveillance
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2
Constant
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Fire Protection
Not Evaluated
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Constant
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2
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Improving
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Security
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2
Constant
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Refueling
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Constant
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Training
Not Evaluated
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Constant
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Quality Programs and
Administrative Controls
Affecting Quality
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2
Constant
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Licensing Activities
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Constant
IV.
PERFORMANCE ANALYSIS
A.
Plant Operations
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1.
Analysis
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During the assessment period, inspections of plant operations were
performed by the resident and regional inspection staffs.
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The licensee had a positive nuclear safety attitude and exhibited
no significant administrative, management control, or material
problems. The licensee's supervisoiy staff was knowledgeable and
proficient in day-to-day plant operations.
Plant evolutions
appeared to be well planned with established and realistic prior-
ities,
The licensee was quick to take corrective action when
problems or violations were identified by NRC.
The licensee has
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also demonstrated concern for items identified by the internal
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audit group. Corrective actions in these areas were prompt.
The
licensee's knowledge of regulations, guides, standards and generic
issues was good, and interpretations of these documents and
associated issues were conservative.
Licensee technical competence was well founded both in technical
matters and general plant operations. The plant staff responded
to plant trips and other operational events during this review
period in a professional and competent manner.
Daily conduct of
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business in the control room was performed in a professional
manner. Access to the control room was controlled and limited to
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personnel conducting business in the control room.
Radios and
reading material not directly related to plant operation were not
allowed in the control room or plant. Housekeeping in the control
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room and throughout the plant was good.
The licensee was well prepared at meetings with NRC.
The
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licensee's staff was generally able to make immediate commitments
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or state the utility's position in a given area.
The qualifications of plant management exceeded NRC requirements.
Senior plant managers, with one exception, held senior reactor
operator licenses.
Plant management was oriented towards safety
and efficiency. This was demonstrated by the close supervision of
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plant operations.
The plant was well managed with conscientious
and capable personnel,
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Licensee on-site evaluations were routinely performed to address,
assess and correct reportable events.
Licensee Event Reports
(LERs), in general, contained adequate descriptions of the occur-
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rences. The entries were correct and the coding agreed with the
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information in the narrative description.
Similar occurrences
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were adequately referenced, and the licensee provided supplemental
information when required.
The violations listed below were not considered to indicate signi-
ficant programmatic deficiencies.
Four violations, identified
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below as a, b, d and e, were the result of procedural problems.
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Violation c was the result of a personnel error.
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Five violations were identified during this assessment period as
follows:
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a.
Severity Level !V violation for inoperable containment spray
loop 2A eductor from the chemical addition tank.
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b.
Severity Level IV violation for failure to return the Unit 1
containment sump wide range level indicators to operable
status after calibration as a result of an inadequate
procedure.
c.
Severity Level IV violation for exceeding Technical Speci-
fication cooldown rate on the reactor coolant system,
d.
Severity Level V violation for two examples of inadequate
procedures involving the 28 battery charger room cooler and
the emergency diesel generator fuel oil day tank level
indicator,
e.
Severity Level V violation for two examples of inadequate
procedures involving a recirculation stop valve on the
containment spray system and a spray additive tank recir-
colating stop valve.
2.
Conclusion
Category:
1
Tre.4d Ouring This Period:
Constant
3.
Boar 1 Recommendations
Licensee management attention was aggressive in this area.
Becauro of the number of violations identified in this area, the
Board does not recommend that NRC staff resources applied to the
routine inspection program be reduced.
B.
Radiological Controls
1.
Analysis
During the assessment period, inspections of radiological controls
were conducted by the regional and resident inspection staffs.
The licensee's health physics staffing level was appropriate and
compared well to other utilities having a facility of similar
size. An adequate number of ANSI qualified Itcensee and contract
health physics technicians were available to support routine and
outage operations.
The performance of the health physics staff in support of routine
operation and outage was good. No substantive issues were identi-
fied in this area.
Exposure control was ef fective during outages.
The 11censeo
provided appropriate shielding and included planning for ALARA
considerations. There was good management involvement and support
of health physics. The facility man-rom totals for calenjar years
1983 and 1984 were 956 and 901, respectively.
These values are
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less than the average of 1184 man-rem for a two-unit pressurized
water reactor facility.
The Radiation Work Permit (RWP) program was revised during the
evaluation period.
Previously, RWPs were written to cover a very
broad scope of work. This resulted in RWPs which were difficult
to read and understand.
Tne revised RWP program corrected these
problems.
Earlier in the SALP period, the licensee's contamination monitor-
ing program for individuals at the facility relied substantially
on fixed detector monitoring booths rather than personal frisking.
The friskers in the plant were used for quick scans. This prac-
tice was revised later in the SALP period and acceptable whole
body personnel frisking techniques were required.
A June 1984
violation involving two personnel who left a contaminated area
without frisking may have resulted from the reduced emphasis on
frisking.
During calendar years 1983 and 1984, the licensee disposed of a
typical quantity of solid radioactive waste for a two-unit PWR
facility:
17,941 and 16,156 cubic feet, for Units 1 and 2
respectively.
A confirmatory measurements inspection was conducted and utilized
comparative analyses between the licensee and Region !! facil-
ittes.
Results were in agreement except for selected gaseous and
liquid effluent split samples and Sr-90 and Fe-55 in spiked
samples.
Systematically high noble gas results and disagreements
for I-133, Sr-90 and Fe-55 results for liquid ef fluents demon-
strated the need for licensee evaluation of methodology and
procedures utilized in these analyses.
The need for corrective
action was identified to prevent spurious alarming of the liquid
waste effluent monitor. A previously identified item, verifica-
tion of gas calibrations utilizing gaseous sources, was not
completed.
Licensee response to previous items, excluding eval-
uation of gas calibrations, was timely and adequate.
All other
aspects of the radwaste affluent, and radiological and chemical
confirmatory measurements programs were adequate.
The J. M. Farley radiological control program continued to be well
managed and effective.
It reflected a high level of plant and
corporate management attention and support.
Two violations were identified during this assessment period
a.
$overity Level IV violation for improperly using respirator
protection factors for a respirator that personnel had not
been fitted, tested or trained to wear.
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b.
Severity Level IV violation for three examples of failure to
comply with procedures involving failure to evaluate discre-
pancies between thermoluminescence dosimeters and pocket
dosimeters, failure to perfore required maintenance on
breathing air systems and faihre of individuals leaving a
contamination control zone to frisk.
2.
Conclusion
Category:
1
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Trend During This Period:
Constant
3.
Board Recommendations
Licensee resources in this area were ample. The Board recommends
that NRC staff resources applied to the routine inspection program
be reduced.
C.
Maintenance
1.
Analysis
During this assessment period, inspections of facility maintenance
were performed by the resident and regional inspection staffs.
Two inspections involved repair of steam generator feedwater line
cracking, and one inspection involved repair of steam generator
tube leaks.
Design change and maintenance programs were conducted in an
acceptable manner.
For both programs, the necessary work reviews
were thorough and technically sound; procedures and plans were
followed; conditions requiring corrective action were resolved in
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a timely and effective fashion; and records were adequately
maintained and retrievable.
The licensee's maintenance training
and qualification programs were excellent.
They are addressed
' further in the training functional area of this report.
The
licensee also had an adequate system for tracking and correcting
NRC identified items.
The licensee was responsive to NRC concerns and conducted evalua-
tions to identify and correct, if required, activities related to
maintenance which appeared to be contrary to the prescribed
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function of equipment.
An example of this was the licensee's
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action in contacting the Atwood Morrill Company when problems were
found with the main steam isolation valves.
Other examples of
management initiative taken to correct an operating problem were
evidenced during the split pin modification on Unit 1 and with
problems associated with the diesel
generators.
Licensee
responses to maintenance related and NRC issues were typically
viable and acceptable.
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The licensee displayed a positive nuclear safety attitude and
developed viable preventive and corrective maintenance programs.
' Maintenance activities exhibited evidence of adequate planning
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with established priorities. Maintenance procedures and policies
were followed by the maintenance staff, except as noted in the
violations listed below.
Five violations were the result of
procedural problems.
Five violations were identified during this assessment period.
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a.
Severity Level IV violation for failure to ensure that
purchased services conformed to procurement documents.
b.
Severity Level V violation for failure to follow approved
procedures by not controlling the 2A and 2B containment air
cooler fan annunciator links.
c.
Severity Level V violation for failure to implement pro-
cedures for the control of maintenance activities,
d.
Severity Level V violation for failure to ensure that equip-
ment requiring calibration was labeled and a broken torque
wrench was controlled,
e.
Severity Level V violation for failure to accomplish special
welding processes in accordance with applicable criteria.
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2.
Conclusion
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Category:
1
Trend During This Period:
Constant
3.
Board Recommendations
Licensee management in this area was dedicated to nuclear safety.
The quality of the maintenance training program and use of
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laboratory " hands-on" traintr7 significantly contributed to the
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licensee's performance in this area. The Board does not recommend
a change in inspection resources applied to the routine program in
this area..
D.
Surveillance
1.
Analysis
During the assessment period, inspections of the operational
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surve'11ance program were performed by the resident and regional
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inspection staffs.
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Routine plant surveillance related activities appeared to be
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planned and well defined. The Itcensee continuously upgraded the
surveillance program,
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Review of surveillance activities was performed by prescribed
licensee reviewers who were qualified to perform these activities.
Review of surveillance records revealed that they were readily
available, complete, and adequately maintained. On-site evalua-
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tions were routinely performed to address, assess and correct
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surveillance concerns.
The licensee's on-site corporate Quality
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Assurance organization was heavily involved in the surveillance
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program.
The licensee was responsive to NRC concerns and conducted investi-
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gations to identify and correct, if required, activities related
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to the surveillance program.
Licensee Management involvement in Inservice Inspection (ISI) and
Inservice Testing (IST) activities was adequate. Decision making
was usually at a level that assured adequate review.
Corporate
management was involved in site activities, and reviews were
timely, thorough and technically sound.
Records were complete,
well maintained, and readily available.
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The licensee successfully completed the containment Integrated
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Leakrate Testing (!LRT) on Unit I during this evaluation period.
A 24-hour ILRT followed by a 4-hour verification test was
performed on Unit 1 in the period April 12-14, 1984
The test
was witnessed by NRC and no significant problems were encountered.
The Itcensee's test report, submitted July 13, 1984, was reviewed
by NRC. The report contained appropriate test results to support
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the successful computation of the Type A test. The report did not
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include Type B and Type C "as-found" leakage rates. The licensee
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has this data available on site and stated that this information
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would be incorporated in future test reports.
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During this assessment period there was one trip on Unit 2 which
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involved maintenance test personnel. All other unplanned reactor
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shutdowns were by operations personnel,
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Licensee response to NRC initiatives was timely and there were few
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long-standirig regulatory issues attributable to the licensee.
Understanding of technical issues was apparent with timely reso-
lution. Viable, sound and thorough responses were offered.
Nine violations were identified during this assessment period.
These violations represent 17 examples of procedural problems.
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a.
Severity Level IV violation for four examples of failure to
implement surveillance and operating procedures.
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b.
Severity Level IV violation for four examples of procedure
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violations,
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c.
Severity Level V violation for failure to establish measures
for control of the battery hydrometer standard.
d.
Severity Level V violation for failure to calibrate ultra-
sonic testing instruments in accordance with procedures.
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e.
Severity Level V violation for failure to incorporate a
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temporary change notice into a procedure,
f.
Severity Level V violation for an inadequate procedure.
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g.
Severity Level V violation for three examples of failure to
control special processes.
h.
Severity Level V violation for failure to specify intervals
for calibration of certain instruments used in safety-related
activities.
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Severity Level V violation for failure to establish an
adequate surveillance procedure.
2.
Conclusion
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Category:
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Trend During This Period: Constant
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3.
Board Recommendations
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Performance in this area demonstrated the surveillance program was
adequate; however, the licensee should place emphasis on ensuring
that applicable procedures are technically adequate, properly
approved and followed.
E.
Fire Protection
1.
Analysis
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During the assessment period, inspections of the fire protection /
prevention program were performed by the resident and regional
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staffs. The licensee's procedures to implement the fire protec-
tion program were reviewed and found to have met the NRC guide-
lines and requirements.
Procedures were provided to accomplish
all surveillance requirements of the fire protection Technical
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Specifications, except that several of the Unit 1 fire detectors
were omitted from the surveillance procedures; a number of fire
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protection shut off valves were omitted from the annual valve
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cycle test program; and the manual carbon dioxide hose reels in
the auxiliary butiding were omitted from the carbon dioxide
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surve111ance program.
These items were identified below as
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violation a.
A review of the completed test surveillance records
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indicated that, other than the above identified violation, the
fire protection systems were being satisfactorily tested and
maintained.
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Implementation of the fire protection program was accomplished by
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a well qualified fire protection staff.
A high quality fire
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brigade training program was provided by the licensee to assure
that each brigade member was adequately trained for any type plant
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fire. Procedures were provided to assure that a sufficient number
of qualified brigade members were available on site.
General
plant housekeeping was consistently found to be good.
Fire
protection systems were well maintained.
However, during this
assessment period, one of the fire pumps was required to be oper-
ated continuously due to leaks in the underground fire protection
piping system which exceeded the capacity of the small jockey
pump. This also resulted in portions of the plant fire alarm
system being placed out of order to silence the fire pump running
alarm.
However, the licensee had implemented the appropriate
action statements of the Technical Specifications. Subsequently,
the licensee installed a larger size jockey pump, and restored the
fire pumps and fire alarm system to normal automatic operation.
The NRC also found several auxiliary building vertical cable trays
without the required fire stops. This was identified as violation
b below.
Management's involvement and control of the fire prctection
program elements were adequate. Identified problems were promptly
reported to the NRC and corrected.
Response to NRC initiatives
was generally timely.
Major fire protection violations have not
been identified.
Staf fing and training of the fire protection
program were adequate.
Two violations were identified during this assessment period:
a.
Severity Level V violation for failure to establish and
implement test procedures,
b.
Severity Level V violation for failure to provide the
required fire stops in vertical cable tray runs of over 20
feet.
2.
Conclusion
Category:
1
Trend Ouring This Period:
Constant
3.
Board Recommendation
A high level of performance was achieved in this area. The Board
does not recommend a change in inspection resources applied to the
routine program in this area,
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F.
1.
Analysis
During the assessment period, inspections of emergency prepared-
ness were performed by the regional and resident inspection
staffs.
These included observation of a full-scale and small-
scale exercise, and routine inspections addressing emergency
responses and related implementing procedures.
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Routine inspections and exercise observations disclosed no signi-
ficant problems in the emergency preparedness organization or
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staffing.
The corporate emergency planning organization was
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adequately staffed and provided support to the plant. Key posi-
tions in the corporate and plant emergency response planning
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organization were filled.
Corporate management was strongly
committed to an effective emergency response program and senior
corporate officials were directly involved in the annual exer-
cises, drills, and followup critiques.
The licensee has been
responsive to the NRC initiatives on emergency preparedness
issues.
Personnel assigned to the emergency preparedness organizations
were adequately trained in required areas of emergency response.
Training records of shift supervisors documented that required
familiarization training was conducted in accordance with the
emergency plans and implementing procedures.
Individuals were
cognizant of their responsibilities and authorities, and under-
stood their assigned duties and functions during routine opera-
tions and simulated radiological emergency situations.
The following essential elements for emergency response were
determined to be acceptable:
Emergency Classification; Communi-
cations; Public Information; Shift Staffing and Augmentation;
Emergency Response Training; Dose Projection and Assessment;
Emergency Worker Protection; Post Accident Measurements and
Instrumentation; Changes to the Emergency Preparedness Programs;
and Annual Quality Assurance Audits of Corporate and Plant Emer-
gency Planning Programs. The exercises demonstrated that the plan
and required procedures could be effectively implemented by the
licensee's staf f, although several areas for improvement were
noted by the NRC and the licensee.
No violations were identified regarding the emergency preparedness
program plan, or procedures for their implementation; however, six
items requiring licensee attention were identified during the
assessment period. Four items related to stack particulate sample
tubing, and the adequacy of the inventory of operable high range
radiation survey meters available under postulated accident
conditions.
Two items were identified which addressed clarifica-
tion of protective action decision making and the licensee
actively pursued the resolution to these items. The licensee has
been responsive to NRC initiatives, responses were sound, and
assigned deadlines were consistently met.
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No violations were identified during this assessment period.
2.
Conclusion
Category:
1
Trend During This Period:
Improving
3.
Board Recommendations
Licensee management involvement in this area was aggressive. The
Board noted that the drill scenario weakness addressed in the
previous SALP had been corrected.
Because performance in this
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area has only recently been determined to be at a Category 1
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level, the Board does not recommend a change in inspection
resources applied to the routine program.
G.
Security and Safeguards
1.
Analysis
During the assessment period, inspections were conducted by the
resident and regional inspection staffs. The licensee's approach
to the resolution of technical issues was characterized by viable
and thorough reviews, resulting
~1 n sound and conservative
judgements.
Responsiveness to NRC initiatives was adequate when
problems of regulatory. concerns were identified.
One safeguards
event was reported to the NRC during the assessment period which
resulted in an enforcement conference relative to inadequate
supervision of security response drills. Authority and responsi-
bilities associated with . security organization positions were
identified, an'd the safiquards taaining and qualification program
was fully implemented with dedicated resnurces from.the corporate
office and the site.
-
1
Continuing problems exist in establjshing [and maintaining
an
operational, intrusion detection and surveillance-system. Delays,
originally attributed to the vendor, hecessitated the licensee's
use of compnnsatory action for more than four years.
The violatioris' described below were the //esult of security manage-
ment!s failuse to review resphnse drill scenarios prior to imple-
mertation, but are riot indicative of a?significant breakdown in
the security program.
^
_
,
,
^
~ Three vioiatior.s were identified during. the assessment period:
a.
Severf ty Level IV violation for failure' to control the access
of' a non-designated vphicle enteriiig the protected area.
s
s
b.
Se, verity Ievel'IV violation for failure to control the access
of an inoividual entaring the protected area without his
security bange.
,
' ' -
-
s
.
- Iu
'g
k
4
_ _ _ _
_ _ - _
_ -
_
_ _ _ _ _ - _ . _ _ _ _ - - - _ - _
-
_ _ .
..
.
.
.
.
,
14
c.
Severity Level V violation for failure to conduct an adequate
response force drill.
I
2.
Conclusion
Category:
2
I
Trend During This Period:
Constant
3.
Board Recommendation
Management attention in this area was evident. Aggressive manage-
ment action is required to correct security equipment failures
which cannot be permanently corrected by 'the vendors.
The Board
does not recommend a change in inspection resources applied to the
routine program in this area.
1
H.
Refueling
l
1.
Analysis
During the assessment period, inspections of refueling activities
on Unit 1 and Unit 2 were performed by the resident and regional
inspection staffs. There were no equipment or material problems.
The licensee followed management approved refueling procedures.
The procedures were enhanced by monitoring up-to-date fuel status
boards inside and outside containment.
The licensee's safety
audit engineer review group performed audits during the refueling
period.
The licensee scheduled and followed the refueling outage
with the aid of flow and critical path charts. At the conclusion
of each refueling outage the licensee conducted a complete review
of completed work.
Problem areas were identified and analyzed.
Special attention was given to these areas for future refueling
outage scheduling.
Surveillance tests performed after refueling to support restart of
the reactor were adequate and acceptably performed. Test person-
nel and their immediate supervisors were knowledgeable of test
-
content and intent.
Unit 1 spent fuel storage racks were modified during this assess-
ment period. The original racks were replaced with high density
,
units increasing the unit spent fuel storage capacity to 1407
assemblies. Unit 2 spent fuel racks were modified prior to the
first refueling outage.
Two violations were associated with Unit 1 spent fuel storage rack
modifications.
These violations are listed in the maintenance
functional area (violations a and d).
Violation a involved the
control of purchased services; violation d involved the control of
calibrated equipment.
- _ _ _ _ _ - _ _
_ _ _ _ _ - .
-
._. .
. - _ .-
.
.
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15
2.
Conclusion
Category:
1
Trend During This Period:
Constant
3.
Board Recommendations
Licensee resources appeared to be ample in this area. The effi-
ciency of outage management indicated good prior planning by the
licensee.
The Board does not recommend a change in inspection
resources applied to the routine inspection program in this area.
I.
Training
1.
Analysis
During the assessment period, inspections were conducted by the
resident and regional
inspection staffs.
General employee,
reactor operator, senior reactor operator, and licensed operator
requalification training was conducted in the new training center.
The training was effectively implemented. The training staff was
well trained and qualified.
During the assessment period, two licensing examination site
visits were made. Ten Senior Reactor Operator (SRO), six Reactor
Operator (RO) and one Instruction Certification (IC) candidates
were examined. Nine of the SR0 candidates, five of the R0 candi-
dates, and the IC candidate passed the examinations and were
licensed by the NRC. No areas of generic weakness were noted in
the candidates examined.
The maintenance training and qualification program appeared to be
a contributing factor in the quality of work preparation and
adherence to procedures.
The new training facility provided
'
facilities for classroom instruction in the various aspects of
maintenance as well as plant systems.
Practical " hands-on"
training was accomplished in the various laboratory training
facilities.
The plant specific simulator is in operation 16 to 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> each
day for requalification and initial license training.
The training staff consists of 42 persons which includes support
personnel.
The staff is made up of a training Director (SRO),
Sector Supervisor (SRO), five instructors (SRO), and five contract
instructors who have been certified by NRC.
Specialized instruction is taught by non-licensed instructors who
are proficient in their field such as diesel generators, turbo
generators, chemistry, and maintenance related topics.
- _
.
.__ - .
._ _
__
.- . _ _ _ _ _ _ - . . .
.
.
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16
Non-licensed personnel training consists of 21 weeks of classroom
and laboratory training for instrumentation and control techni-
cians, electricians, and mechanics.
This training continues
through plant scheduled outages and there is annual retraining.
All of the above personnel must pass the annual retraining exami-
nation.
No violations were identified during this assessment period.
2.
Conclusion
Category:
1
Trend During This Period:
Constant
3.
Board Recommendations
Management involvement in this area was aggressive.
The Board
does not recommend a change in inspection resources applied to the
routine program in this area.
J.
Quality Programs and Administrative Controls Affecting Quality
1.
Analysis
-
During the assessment period, inspections in Quality Programs and
Administrative Controls Affecting Quality were conducted by the
resident and regional inspection staffs.
Interviews with licensee
personnel indicated that the quality assurance program was ade-
quately stated and understood.
Frequent corporate and site
communication was evident and indicated that corporate quality
assurance management was actively involved in site activities. A
review of audits was conducted by NRC and auditing activities were
determined to be complete and thorough.
Audit findings were
resolved within a reasonable time. Quality assurance records were
well maintained and available for review.
Key staff positions had been identified and authorities and
responsibilities for these positions were delineated in proce-
dures.
Staffing was adequate.
The Plant Operations Review Committee performed its Technical
Specification (TS) on-site review functions adequately, meeting
quorum and qualification requirements.
Although this committee
performed the required reviews, appropriate management controls
were not always established to assure adequate completion of
safety-related activities as indicated by the violations listed
below.
Violations b and c involve failure to perform written
safety evaluations required by 10 CFR 50.59 to assure that pro-
posed actions did not involve an unreviewed safety question or a
change to the Technical Specification. Violations a and d involve
failure to control systems and components as required by the
accepted quality assurance program.
.
.
.
17
Four violations were identified during this assessment period:
a.
Severity Level IV violation for failure to control the
operation of the Unit 2 service water valve for the diesel
generators.
b.
Severity Level IV violation for failure to perform a written
safety evaluation prior to transferring water from the spent
fuel pool to the fuel transfer canal through the use of a
submersible pump.
c.
Severity Level IV violation for failure to perform a written
safety evaluation prior to installing temporary equipment.
d.
Severity Level IV violation for failure to control activities
affecting quality.
2.
Conclusion
Category:
2
Trend During This Period:
Constant
3.
Board Recommendations
Licensee resources applied to this area were reasonably effective.
The Board does not recommend a change in inspection resources
applied to the routine program.
K.
Licensing Activities
1.
Analysis
Performance in the area of licensing activities continued to
demonstrate a high level of management involvement and control in
assuring quality. Corporate management had a keen awareness of
operating performance as evidenced by the appointment of the
Senior Vice President for nuclear matters, and by the dividing of
Assistant Plant Manager responsibilities for operations and
administration into two separate management positions.
Farley
Unit 2 continued to evidence operational control of quality
activities as evidenced by a cumulative capacity factor of approx-
imately 84 percent (net) for the first three operating cycles
including the first two refueling outages.
The third operating
cycle for Unit 2 concluded January 4,1985, shortly after the end
of this evaluation period.
Pursuant to the change to 10 CFR 50.91, effective May 6, 1984, 62
licensee requests were noticed, 50 license amendments were issued,
and no public comments were received.
Licensee planning and prioritizing of requests for license amend-
ments have continued to improve. Several meetings were held with
__
.
.
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18
licensee management early in the assessment period to obtain a
mutual understanding of priorities and schedules to enable both
licensee staff and Commission staff to utilize resources in a more
effective manner.
On the basis of this action, significant
1mprovements were realized as evidenced by the reduction in
licensing backlog of 31 actions even with an increase in the
number of license requests in 1984.
The licensee's continued
cooperation in the periodic review meetings for all licensing
actions in 1984 has been excellent. Improved licensee management
attention to scheduling and prioritizing of licensee requests for
Commission staff actions has been demonstrated.
Many safety-
related reviews were completed on a mutually acceptable schedule
without impacting the licensee's site operation.
An example of specific licensing actions where the licensee's
close management involvement was evidericed was in the environ-
mental qualification of electrical equipment.
The submittal
included well stated, controlled, and explicit procedures for the
control of equipment qualification activities.
It was also
significant that all the electrical equipment importarit to safety
at the licensee's site had been qualified. No additional detailed
justifications for continued operation were required.
The licensee's approach to the resolution of technical issues has
included increased interaction with the NRC staff.
Frequent
visits, management discussions, and meetings have resulted in
-
clearer understandings of safety issues.
Sound technical ap-
proaches were taken by the licensee's technical staff toward their
resolution. Conservatism was exhibited in relation to significant
safety issues on a routine basis. Thoroughness in the approach to
the technical issues has been demonstrated by the number and
complexity of the licensing actions completed during this period
as discussed above.
Consistently sound technical justification has been provided by
the licensee for deviations from staff guidance. In the case of
extending the allowable time to perform maintenance on movable
control rods, the licensee noted a negative impact on safety with
the existing shutdown requirements.
Following extensive review
among licensee site personnel, Westinghouse vendor personnel and
licensee corporate personnel, a meeting was held with the Commis-
sion staff. At the meeting, the technical issue was resolved from
a safety point of view.
Subsequently, a license change was
approved eliminating the restrictions which the Commission had
imposed.
The day-to-day communications between the licensee and
NRC staff have also been beneficial to both organizations in the
processing of licensing actions and minimizing the need for
additional information.
The initial submittals and responses to NRC requests for informa-
tion consistently met the projected schedules or a sound justi-
fication and a revised schedule were provided.
The positive
attitude of the licensee's technical staff in responding to NRC
. _ .
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.
.
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19
requests concerning safety issues consistently helped in achieving
timely resolutions of safety issues in the licensing area.
The licensee continued to maintain an adequate licensing staff as
reflected in the timely responses and in the quality of the
submittals relating to licensing actions. In addition, the senior
management changes, including the senior vice presidant position
and the two assistant plant managers, should enhance the quality
and timeliness of the licensee's submittals.
2.
Conclusion
Category:
1
Trend During This Period:
Constant
3.
Board Recommendations
A high level of performance in this area was achieved.
V.
SUPPORTING DATA AND SUMMARIES
A.
Licensee Activities
During the assessment period, refueling outages were conducted on both
units and several modifications common to both units were completed.
The reactor trip breakers were modified such that an automatic trip
signal energizes the reactor trip breaker shunt trip coils as well as
deenergizes the associated undervoltage coils.
In addition, human
factors engineering modifications were completed which upgraded the
control room floor plan and operating areas. The J. M. Farley Nuclear
plant training center and plant specific simulator were completed.
During the Unit I refueling outage from February 10, 1983 to April 23,
1983, feedwater pipe to nozzle cracks were found on all three steam
generators. Interim corrective repairs were performed prior to restart
with final corrective action under evaluation.
The licensee replaced
reheater moisture separator tube bundles and chevrons, and feedwater
heaters 3A, 3B, 4A and 4B to eliminate copper for steam generator
protection. During this outage, the licensee also completed instal-
lation of a reactor vessel head vent system and performed the five year
In September 1984, the licensee modified the Unit 1 spent fuel storage
racks.
The original racks were replaced with high density units
increasing the unit spent fuel storage capacity to 1407 assemblies.
At the close of this evaluation period, Unit I had completed in excess
of 250 days of continuous operation.
Unit 2 shut down for refueling on September 16, 1983, and returned to
power on October 27, 1983.
During the outage, the installation of a
reactor vessel head vent system was completed, and modifications to the
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_
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20
main steam isolation valves were performed.
Following restart from
this outage the unit completed 280 days of continuous online operation.
The unit was shut down on August 31, 1984, due to re-analysis of steam
generator eddy current test results which required plugging of two
tubes. The unit was restarted on September 18, 1984.
The Institute of Nuclear Power Operations (INPO) conducted one evalua-
tion during this assessment period. Additionally, the Accreditation
Board of the Institute of Nuclear Power Operations accredited Alabama
Power Company for the operations training programs taught at Farley
Nuclear Plant during this assessment
System operator training (non-licensed)
Operator license training (licensed)
License upgrade training (licensed)
Shift technical adviser training (non-licensed)
Shift supervisor training (licensed)
Licensed retraining (licensed)
8.
Inspection Activities
During the assessment period, routine inspections were performed at the
J. M. Farley facility. Areas inspected included, but were not limited
I
to, facility operations, radiation protection / radiological controls,
surveillance activities, maintenance activities, fire protection,
-
emergency preparedness, security and safeguards, refueling activities,
inservice inspection and quality assurance.
C.
Licensing Activities
The assessment on licensing activities was based on the following
licensing actions:
Fire Protection Exemption Granted (two)
Radioidine Protection Factor Exemption Granted
Inservice Testing Relief for Check Valve Tests Granted (three)
Inservice Inspection Additional Reliefs Granted (four)
ISI Scheduled Extensions Granted (two)
Equipment Qualification (EQ) Schedule Extensions Granted (two)
Emergency TS Authorized (one)
License Amendments Issued (forty-nine).
Signifir qt amendments included:
Deletion of Turbine Overspeed Valve Tests from Technical Specifi-
cations
Deletion of River Water System and Change Diesel Generator Loads
from Technical Specifications
Auto Actuation of Shunt Trip
Environmental Qualification of Electrical Equipment
Alternate Shutdown System Design Review - Appendix R
._ . _ .
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21
Masonry Walls (IEB 80-11) - Unit 1
NUREG-0737 Technical Specifications - Generic Letters (GLs) 82-16
and 83-37
Change to Emergency Preparedness Audit Frequency (GL 82-17)
Update Charcoal Filter Tests in Technical Specifications
Removal of Snubber Tables from Technical Specifications (GL 84-13)
Fuel Enrichment Technical Specifications
Upgrade Meteorological Tower Technical Specifications
Four One-Time Technical Specification Changes (three precluded
shutdowns)
Mew Primary Isolation Valve Leakage Criteria Technical Specifi-
cations
Delete 8-Hour Work Day from Technical Specifications
Reactor Coolant System High Point Vents
Confirmatory Order Supplement 1 to NUREG-0737
D.
Investigation and Allegations Review
There were no significant investigations or allegation activities
during the assessment period.
E.
Escalated Enforcement Actions
1.
Civil Penalties
None
-
2.
Orders (Those relating to enforcement)
None
F.
Management Conferences Held During Appraisal Period
l
A Management Meeting was held at the J. M. Farley site on January 12,
1984, to discuss the application of 10 CFR 50.48 and 10 CFR 50 Appen-
dix R (Fire Protection).
An enforcement conference was held at the J.
M.
Farley site on
October 30, 1984, to discuss inadeouate supervision of a security
response drill.
,
l
G.
Review of Licensee Event Reports and 10 CFR 21 Reports submitted by the
Licensee
During the assessment period, there were 73 LERs reported for Unit 1
and 46 LERs reported for Unit 2.
The distribution of these events by
cause, as determined by the NRC staff, was as follows:
Cause
Unit 1
Unit 2
Component Failure
34
15
Design
3
1
a
,
22
Construction, Fabrication, or
Installation
3
0
Personnel
Operating Activity
3
11
-
Maintenance Activity
6
2
-
Test / Calibration Activity
7
3
-
Other
1
1
-
Out of Calibration
4
5
Other
12
8
TOTAL
73
46
H.
Inspection Activity and Enforcement
FUNCTIONAL
NO. OF VIOLATIONS IN EACH SEVERITY LEVEL
AREA
V
IV
III
II
I
Plant Operations
2
3
Radiological Controls
2
Maintenance
4
1
Surveillance
7
2
Fire Protection
2
Security
1
2
Refueling
Training
Quality Program and
Administrative Controls
4
Affecting Quality
.
TOTAL
16
14