ML20133C451
| ML20133C451 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 10/01/1985 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Mcdonald R ALABAMA POWER CO. |
| References | |
| NUDOCS 8510070365 | |
| Download: ML20133C451 (6) | |
See also: IR 05000348/1985025
Text
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October 1,1985
labama Power Company
TTN: Mr. R. P. Mcdonald
Senior Vice President-Nuclear Generation
P. O. Box 2641
Birmingham, AL 35291
Gentlemen:
SUBJECT:
REPORT NOS. 50-348/85-25 AND 50-364/85-25
Thank you for your response of August 16, 1985, to our Notice of Violation issued
on July 18, 1985, concerning activities conducted at your Farley facility. With
regard to Violation 1, parts b and c. Violation 2, part a, and Violation 4, we
have concluded, for the reasons presented in the enclosure to this letter, that
the violations occurred as stated in the Notice of Violation.
Therefore,.in
accordance with the requirements of 10 CFR 2.201, and within 30 days of the date
of this letter, please resubmit your response to the Notice of Violation.
With regard to Violation 1, part a, we are reviewing this matter further and will
respond to this item at a later date.
With regard to Violation 2, part b, we agree with your position and have deleted
this part of the violation from our records.
With regard to Violation 3, we have concluded for the reasons presented in the
enclosure to this letter that your proposed corrective action to avoid further
violations is unacceptable.
Therefore, in'accordance with the requirements of
10 CFR 2.201, and within 30 days of the date of this notice, please resubmit
your response to the Notice of Violation.
With regard to your denial that Violations 1, 2, and 4 are properly designated as
Severity Level IV, we have concluded, for the reasons presented in the enclosure
to this letter, that the proper severity levels were designated.
We appreciate your cooperation in this matter.
Sincerely,
(Original signed by JNGrace)
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J. Nelson Grace
Regional Administrator
Enclosure:
(See Page 2)
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Alabama Power Company
2
October 1,1985
Enclosure:
Staff Evaluation of Licensee Response
Dated August 16, 1985
. O. Whitt, Executive Vice President
f.D.Woodard,PlantManager
W. G. Hairston, III, Manager
Nuclear Engineering and Technical
/. Support
J
W. McGowan, Manager-Safety Audit
/ and Engineering Review
JH. O. Thrash, Manager, Nuclear
/ Operations and Administration
W. G. Ware, Supervisor-Safety Audit
and Engineering Review
cc w/ enc 1:
RC Resident Inspector
E. Reeves, Project Manager, NRR
Document Control Desk
State of Alabama
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ENCLOSURE
STAFF EVALUATION'0F LICENSEE RESPONSE.
DATED AUGUST 16, 1985
Our assessment of your reasons for denial of the violation is as follows:
1.b. You make the following statement in your denial:
Alabama Power Company does not agree that failure to document
evaluations of mechanical test equipment is a violation of the cited
requirements, since ANSI N45.2.4-1972 is not applicable to mechanical
test equipment.
FNP-0-AP-15 does require that an evaluation be
performed when mechanical test equipment is found out of tolerance;
however, there is no requirement to document this evaluation. We agree
that FNP-0-AP-15 can and will be improved by adding and implementing a
requirement to document evaluations.
We agree with your statement that ANSI N45.2.4-1972 does not specifically
apply to mechanical test equipment.
However, you are also committed to
Regulatory Guide 1.28 which endorses ANSI N45.2-1971.
This standard
(Section 13) clearly applies to mechanical equipment and states the same
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requirement to evaluate previous test results when measuring and test
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equipment (M&TE) is found out of calibration.
You should also note that
the citation was for failure to evaluate, not failure to document.
Your
response addresses only documentation.
Additionally, when directly
questioned by the inspector, Farley plant personnel stated that evaluations
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were rarely perfomed and never documented.
1.c You make the following statement in your denial:
No ANSI standard requires that a time interval be established for
performing these evaluations.
Alabama Power Company does not consider
that lack of formal definition of "promptly" regarding test equipment
evaluation is a violation of regulatory requirements.
A plant review
of all test instruments over the first 5 months of 1985 revealed that
the average time for review was 29 days. We concur that an enhancement
of the program would be a definition of "promptly" which we will
incorporate into our procedures.
We agree that ANSI standards do not prescribe the establishment of a time
limit for evaluations.
However, it is our position that the safety impli -
cations of this issue merit the application of 10 CFR 50, Appendix B,
Criterion XVI, and the accepted QA program requiring measures be established
to assure that conditions adverse to quality are promptly identified and
corrected.
Measures do not exist to assure promptness.
We do not concur
with your implication that completion times have been acceptable.
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Enclosure
2
October 1,1985
You make the following statement in your denial:
Additionally, Alabama Power Company would deny that the alleged
violation is properly designated as Severity Level IV.
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Failure to perform evaluations, to document those evaluations, and to
establish measures to assure conditions adverse to quality are promptly
corrected constitutes a failure to meet regulatory requirements that has
more than minor safety significance.
In conclusion, it is our position that Violations 1.b and 1.c occurred and
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that the proper severity level was assigned.
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2.a You make the following statement in your denial:
The violation states that measures have not been established to assure
that suitable environmental conditions are provided for measuring and
test equipment calibration.
Adequate measures do exist for providing
and controlling environmental conditions in the I&C laboratory;
however, these conditions are not verified and recorded prior to
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calibration of each individual instrument.
Moreover, the inspection
report does not identify an occurrence where the existing level of
adninistrative controls resulted in improper calibrations.
After a
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detailed review, the inspector indicated on page 11 of the inspection
report that the I&C laboratory humidity had remained within the most
limiting test instrument calibration environmental condition for almost
every day during the past year.
We agree that hardware measures (air conditioning, heater, dehumidifiers,
etc.), exist, but the violation was specifically against the failure to
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provide programmatic measures to assure proper environmental controls.
It
is evident that a systennatic assessment of the environmental sensitivities
of shop standards and test equipment has never been accomplished.
We did
state that test conditions were almost always met for Fluke digital multi-
meters, but this was not intended to imply that the same conclusion applies
to all other pieces of test equipment you currently own or may purchase in
the future.
.
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You make the following statement in your denial:
Additionally, Alabama Power Company would deny that the alleged
violation is properly designated as Severity Level IV.
Failure to establish suitably controlled conditions for performing
activities affecting quality constitutes a failure to meet regulatory
requirements that has more than minor safety significance.
In conclusion, it is our position that Violation 2.a occurred and that the
proper severity level was assigned.
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Enclosure
3
October 1,1985
3.
You make the following statement regarding steps to avoid further
violations:
FNP-0-AP-11 will be revised to document evaluation of calibration
interval changes, when such changes are indicated by test equipment
being found out of calibration.
Your response states that interval changes will be documented, but does not
describe a method of trend or failure analysis to determine when such a
change in calibration frequency is warranted.
Your current method of
historical calibration recordkeeping does not provide the means to perform
this analysis.
4.
You make the following statement in your denial:
FN-0-AP-11, Section 4.8 states,
" Storage
4.8.1
Test equipment will be stored in the Calibration Lab or in
such secure locations as the responsible foreman may direct.
4.8.2 /
Storage location environment shall be maintained such that
test equipment accuracy to specifications will be maintained.
4.8.3
Daily access to test equipment will generally be limited to
those personnel assigned to the Calibration Lab for cali-
bration and test equipment checkout activities."
Nothing in the above cited requirement requires any access controls in
addition to those which currently exist.
The subject measuring and
test equipment is physically located for storage in the I&C Calibration
Laboratory wherein a check-out log is maintained. The laboratory is an
enclosed room, not continuously manned at all times, but opens into the
maintenance and storeroom area which is manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. Addi-
tionally, the access to the maintenance and storeroom areas as well as
the laboratory itself is in the Owner Controlled Area with access
controlled by Central Security Control.
Neither 10 CFR 50 Appendix B
Criterion XII nor FNP-0-AP-11 Section 4.8 contains any additional re-
quirements for more stringent access control, nor are any warranted.
Our contention is that you have failed to follow your own procedure.
Section 4.8.3 of FNP-0-AP-11 states that " daily access to test equipment
will generally be limited to those personnel assigned to the calibration lab
for calibration and test equipment checkout activities."
There was no
evidence during the inspection that access was ever restricted for anyone
who could gain access to the Owner Controlled Area. The two NRC inspectors
walked in and were unnoticed for 10 minutes. There was no evidence that any
security was provided by personnel in the maintenance and storeroom areas.
Access to the laboratory is actually by a hallway leading to these areas and
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does not require passage through the maintenance and storeroom area.
The
security issue is therefore twofold.
First, unescorted visitors or
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Enclosure
4
October 1,1985
contractor personnel could tamper with shop standard = or test equipment.
Second, Farley personnel could use test equipment at any time without
ensuring that the usage is properly documented.
You make the following statement in your denial:
Additionally, Alabama Power Company would deny that the alleged
violation is properly designated as Severity Level IV.
Failure to provide security for shop standards and positive accountability
for test standards constitutes a failure to meet regulatory requirements
that has more than minor safety significance.
In conclusion, it is our position that Violation 4 occurred and that the
proper severity level was assigned.
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