ML20237D004

Requests That Encl Comments Re Inaccuracies of NRC 871103 Notice of Violation & Proposed Imposition of Civil Penalties Be Given Due Consideration.Util Believes Inaccuracies Resulted in Severity Level III Assessment

ML20237D004
Person / Time
Site:	Farley
Issue date:	12/17/1987
From:	Mcdonald R ALABAMA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), NRC OFFICE OF ENFORCEMENT (OE)
References
NUDOCS 8712220309
Download: ML20237D004 (12)

Text

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Alabama Power Company 600 North 18th Street Post Office Box 2641 dirmingham, Alabama 35291-0400 Telephone 205 250-1835 m

S nio V ce President Alabania Power December 17, 1987 Ure southern ekttre systern I

Docket Nos. 50-348 50-364 Director, Office of Enforcement U. S. fluclear Regulatory Commi.:sion ATTH: Document Control Desk Washington, DC 20555 Gentlemen:

Joseph M. Farley Huclear Plant Units - 1 and 2 July 27, 1987 Inspection Report Inaccuracies By letter dated December 17, 1987, Alaban,a Power Company provided its response to the November 3,1987 NRC tlotice of Violation and Proposed Imposition of Civil Penalties (NOV). This NOV is based on information presented in a July 27, 1987 Inspection Report. The Inspection Report contains inaccuracies which have been documented and commented upon in the enclosure to this letter. Alabama Power Company believes that these inaccuracies contributed to the context of the NRC's findings which resulted in the assessment of a Severity Level III Violation. It is therefore requested that due consideration be given to the comments contained in the enclosure to this letter during your evaluation of our response to the November 3,1987 fl0V.

If you have any questions, please advise.

Respectfully ubmitted, b

R. P. ftcDonald RPM /J AR : ds t-T. S .7 Enclosure cc: fir. L. B. Long Dr. J. N. Grace Mr. S. A. Varga g Mr. E. A. Reeves go ttr. W. H. Bradford 8712220309 871217 PDR ADOCK 05000348.

O PDR

ENCLOSURE JULY 27,1987 INSPECTION REPORT INACCURACIES PARA./

DOCUMENT PAGE ITEM COMMENTS

1. Cover Latter 1 3 The assertion that the two control room fire dampers were inoperable is incorrect.

Alabama Power Company considers these dampers to have been operable; thus, no reporting was required.

VETIP is a program, not a " source" as the NRC appears to imply. Since 1984, vendor information has been processed via this program. The NRC statement that information was received " fortuitously" is thus inappropriate. Indeed, the NRC acknowledges, in the same sentence, that no instances were found in which information had not been received. '

"The Alabama Power Company vendor interface program appears to lack the rigor and formality necessary to achieve its intent."

There does not appear to be sufficient support to justify this statement.

"These findings ... indicate a lack of systematic attention to detail." There does not appear to be sufficient support to justify this statement.

2. Potential 1 1 Six instances of inadequate corrective action Enforcement are stated; however, only five are detailed.

Findings

3. Potential 1 2 There were 6 circuit breckers installed in Enforcement safety-related MCCs not 9 as cocumented by Findings the NRC. The statement that no testing or analyses were performed to qualify the  ;

breakers is not correct. Both testing and '

analysis were performed by Satin American and its subcontractor to qualify the use of the breakers in 600V applications. Neither Ecotech nor Satin American performed any seismic qualification tests for these breakers on the basis that the breakers provided by Satin American were like-for-like replacements of the original breakers and the use of the replacement breakers would not

Enclosure July 27, 1987 Inspection Report Inaccuracies Page 2 PARA./

DOCUMENT PAGE ITEM COMMENTS

3. Potential 1 2 degrade the seismic characteristics of the Enforcement (cont'd) MCCs in which they are placed. Satin Findings American's subcontractor performed similarity analyses and other evaluations in the dedication of the breakers. Satin American performed a dielectric voltage-withstand test on each breaker, a calibration test on one breaker of each amperage rating and a short circuit test on the smallest and largest amperage rating of both the magnetic trip only breakers and the thermal-magnetic trip breakers. Additionally, Alabama Power Company performed trip tests on each breaker prior to installation.

The use of the word " questionable" with regards to seismic qualification is inappropriate since, at the time of installat' , Alabama Power Company had no reason to .Jestion the qualification.

4. Potential 2 4 The statement that the two dampers were Enforcement non-functional is incorrect. Alabama Power Findings Company did not consider the dampers to be non-functional solely on the basis that they would not close with air flow. Procedures existed to shut off the air handling unit (a.h.u.) from the control room upon indication of fire (smoke entering the control roo;a, alarm in the control room, etc.). With the a.h.u. shut off, the dampers had been demonstrated to close and perform their function. The design to have a damper close with air flow was not a requirement but an enhancement. Nothing precluded manual action to shut off the a.h.u. Accordingly, an LC0 was not declared and a special report was not required to be submitted.

- Enclosure July 27,1987 Inspection Report Inaccuracies Page 3 PARA./

DOC'JMENT PAGE ITEM COMMENTS _

5. Report 2 Results See item 4 above for comments regarding the fire dampers.

It is stated that Alabama Power Company failed to report 15 potentially cracked battery cells as inoperable. In this particular case, two battery cells of the 15 were replaced immediately and the remaining cells were replaced as recommended by the manufacturer. Upon replacement, the potentially cracked cells were stored in the  :

Turbine Building Battery Room for approximately two months and then transported by truck to the Farley Nuclear Plant salvage yard and manually unloaded. This resulted in several of the cells being dropped from the truck by personnel. The cells remained in the salvage yard from June 1986 until June ,

1987 at which time four of the cells, I including one of the worst cells were shipped to an independent testing laboratory for seismic testing. These four cells subsequently passed the seismic test and were therefore proven to be capable of withstanding a seismic event even after being exposed to the weather and being unprotected for over a year. Al so, electrical operability never appeared to have been an issue. No evidence of leakage from the cracks was observed prior to, during, and I subsequent to the seismic test.

The lack of a formal process to contact key vendors is still an open item with Alabama j Power Company for Section 2.2.2 of Generic Letter 83-28. The NRC position was stated in 1 the SER to Alabama Power Company for Section 2.2.2 dated December 15, 1986. Alabama Power Company has noted its disagreement with the NRC position and on March 17, 1987 f ormally notified the NRC of such. This is one of several instances in the Report (we note this as an example) in which the NRC appears to have applied the provisions of Section 2.2.2. Alabama Power Company intends to j continue working with the NRC Staff to I resolve this open issue.  !

Enclosure July 27,1987 Inspection Report Inaccuracies Page 4 PARA./

DOCUMENT PAGE ITEM COMMENTS

6. Report 6 3 The Nuclear Support Group screens appropriate vendor information, both controlled and uncontrolled, as described in Nuclear Generation procedures.

7. Report 7 1 Contrary to what was stated, UVTI is processed by the Farley Nuclear Plant and ,

Nuclear Maintenance Support Staff when  !

received. As it is unsolicited, it could enter at any point; therefore, by definition, UVTI has no designated recipient. l

8. Report 7 4 The critique of the Fad ey Nuclear Plant NRC Information Notice tracking system is without basis. No substantiation is provided that ,

the tracking system inspected was inadequate '

in any respect.  !

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9. Report 8 2 The only new vendor technical information received through these contacts was from '

Target Rock. The information from Target s l Rock had not been issued to the industry 3 because it was still being evaluated by l Target Rock. Other contacts concerned procurement questions and obtaining '

documentation or verification of previous actions, etc. s s "Many of these problems could have been s resolved at an earlier date if a :.ure ,

rigorous vendor interface program !wd been establi shed. " There doeihnot appear; to be f sufficient support to justify th!s statetent.

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Enclosure July 27, 1987 Inspection Report Inaccuracies Page 5 PARA./

DOCUMENT PAGE ITEM COMMENTS

10. Report 9 3 The NRC inspectors were not the motivating force as suggested here, rather the Farley Nuclear Plant Staff were the ones who suggested that the inspector see the valves. I

11. Report 9 5 It should also be noted here that although the key had slipped 3/4", approximately 2 1/4" remained engaged.

12. Report 10 1 The criticism of the Farley Nuclear Plant only inspecting butterfly valves is misleading since these valves have been found to be the only type valve at Farley Nuclear Plant involved.

13. ' Report 10 (2)4 The citation that Farley Nuclear Plant failed to inspect Anchor / Darling check valves in other safety-related systems is misleading since no affected valves were located in

, other safety-related systems.

14. eport ,

12 5 Problems in determining the status of several S

of these reports resulted from the fact that

n. '

the reports were issued prior to Generic

'N Letter 83-28 or the Farley Nuclear Plant 1 VETIP. These items were found to be

' satisfactorily addressed and completed.

1 Therefore, difficulties in determining the status of these reports had nothing to do with vendor interface; rather, it took more 4

time to retrieve documentation of actions for these reports than was required to obtain documentation for reports being tracked as a part of VETIP.

"The licensee's difficulties in determining what changes affected their equipment and the s status of these changes provide an example of the problems which can arise from a less than rigorous vendor interf ace program." There does not appear to be sufficient support to justify this statement.

Enclosure July 27, 1987 Inspection Report Inaccuracies Page 6 PARA./

DOCUMENT PAGE ITEM COMMENTS

15. Report 16 (10)4 "On the basis of the data presented during the inspection, the licensee's review of this issue was not based on sufficient technical information to accomplish its intent." There does not appear to be sufficient support to justify this statement.

16. Report 17 2 The NRC's listing of paint and the subsequent removal of such paint with a solvent is conjecture only. Testing conducted by two independent laboratories on samples taken from the cell has failed to positively identify any trace of solvent. The test results did indicate that latex paint was present on one of the samples. The battery manufacturer, however, has verbally informed j Alabama Power Company that latex paint would not cause the cell to crack. The test results also indicated that one of the samples contained cracks which could have been caused by chemical crazing. However, the source or cause of the chemical crazing could not be determined. In addition, test results from another sample indicated that the cracks could have been initiated by stress.

17. Report 17 4 Four of the 15 potentially cracked battery cells, even after rough handling and exposure to the elements, passed a shake test for seismic qualification and thus should not be classified as degraded.

18. Report 18 (12)1 See item 5 above.

19. Report 18 (12)2 The statement that the dampers failed to operate as required by system design is not correct. The dampers are required to isolate a fire from spreading to adjacent plant areas. The design does not require them to

Enclosure .

July 27.1987 :nspection Report Inaccuracies

..Page 7 PARA./

DOCUMENT PAGE ITEM COMMENTS

19. Report 18 (12)2 close against flow. It is considered good (cont'd) engineering design either to have the . dampers close against air flow or to have the air flow automatically shut off during a fire so that the dampers can close and perform their function. Alabama Power Company has not identified any requirement which would not be met by manual action to shut off the air flow so the dampers could close. Additionally, Alabama Power Company has a procedure which has been in place since September 9,1980 that covers the manual shutdown of the control room' air handling unit in the event of the indication of fire.

20. Report 19 1. This section is not applicable. The dampers were not declared non-functional until the issue was raised during the audit, at which time they were conservatively declared inoperable.

21. Report 19 2 There does not appear to be sufficient support to justify the statement that the operators might not be able to make_ a timely response, especially in light of the procedural guidance that was available.

22. Report 19 3 The correct MWR Number is 48429, not 48439.

23. Report 20 (13) Contrary to what was stated, the date of the evaluation cover letter sheet and the letter representing the disposition are the same.

Contrary to the NRC statement, Alabama Power Company considered this to be a significant safety concern as indica >d by the actions taken. These actions to 4- place prior to the establishment of the Farley Nuclear Plant VETIP. After the program was established, TB 83-04 was screened "not significant" because all actions had already been completed as l- documented in the screening. Therefore, there was no inappropriate action.

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Enclosure July 27,1987 Inspection Report Inaccuracies Page 8 l

PARA./

DOCUMENT PAGE ITEM COMMENTS

24. Report 20 (14)2 Farley Nuclear Plant currently employs a systematic documentation of receipt, evaluation and remedial actions taken as a result of Part 21 notifications. Since the Eberline Report was issued prior to issuance of Generic Letter 83-28, it is incorrect to imply that the Farley Nuclear Plant VETIP is deficient in this resp 6Ct.

25. Report 21 (16)3 The Part 21 burden in this case should be placed on the supplier, not on Alabama Power Company. Since Farley Nuclear Plant was not affected by this report, Pacific Scientific was not required to notify Farley Nuclear Plant, per Part 21. Farley Nuclear Plant action to verify that the report was not applicable to Farley Nuclear Plant went beyond the requirements of Part 21.

Furthermore, this is the only (not "another")

example provided of " indirect" receipt of information.

26. Report 21 E The lack of a contracted program does not make Alabama Power Company's program informal. Alabama Power Company s program has been shown to be adequate. No requirement exists for all vendors of key components to be contacted frequently or contracted with to establish a basis for notification.

These statements are based solely on the provisions of Generic Letter 83-28 and do not address the success or failure of the Farley Nuclear Plant VETIP. The NRC in Paragraph 3 of the July 27, 1987 letter stated "no instances were found where Alabama Power Company failed to receive information".

Since no case could be found where Farley Nuclear Plant did not receive information, no weakness exists.

Despite NRC implications, no new technical i information was received during this audit except the Target Rock Report which had not been issued to the industry.

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Enclosure July 27, 1987 Inspection Report Inaccuracies Page 9 PARA./

DOCUMENT PAGE ITEM COMMENTS

27. Report 22 1 Terry Turbine information was not received from a second hand source. It was received from Bechtel, Alabama Power Company's Architect Engineer.

28. Report 22 2 "The evaluation of vendor information is weak and in some cases untimely, as evidenced by the less-then-rigorous [ sic] evaluations performed ... The weak evaluations contributed to subsequent problems in these areas." There does not appear to be sufficient support to justify this statement.

29. Report 22 2&3 Colt SIL A-2 was properly evaluated but not completely implemented. Other Colt issues were not reported by Colt, despite formal vendor contact. The inference from this report is that this issue was closed; however, this issue was considered open by Alabama Power Company, l Corrective action for the Eberline issue was complete, but documentation was inadequate.

This issue was pre-VETIP.

30. Report 22 3 "This problem may have been aggravated by the '

lack of formal identification of incoming Part 21 notifications..." There does not appear to be sufficient support to justify this statement.

31. Report 23 1 The program implemented by Alabama Power Company for safety-related systems was submitted to the NRC by letter dated February 15, 1984. This program was discussed in detail during the audit. At no time did Alabama Power Company imply that it decided not to implement the program as described in the February 15, 1984 letter.

- . Enclosure July 27, 1987 Inspection Report Inaccuracies Page 10 PARA./

DOCUMENT PAGE ITEM COMMEllTS

32. Report 24 C.1 Alabama Power Company actually purchased 206 safety-related breakers, not 200 as stated in  ;

this report. l

The statement that there was no basis and no testing to show the acceptability of the breakers in 600VAC systems is not correct. '

Alabama Power Company had a basis that l included testing and analysis.

With regard to the approval of Satin American as a source, an audit was subsequently performed which verified Satin American to be an acceptable source. The prior approval of  !

Satin American as a supplier based on a i review of their QA manual is an acceptable j action.

The NRC is suggesting that a requirement exists to perform the following tests:

overload at rated voltage, overcurrent trip, rated load and endurance. To maintain a UL listing of the breakers, these tests would be required. Alabama Power Company did not intend to obtain a UL listing of these breakers at 600V. Additionally, Alabama 1 Power Company is not aware of any regulatory requirement to maintain a 600V UL listing of these breakers. In order to have obtained the 480V UL listing, all of these tests must have been satisfactorily completed. The dedication process of the breakers demonstrated similarity and did not require UL approval. The tests performed were additional assurance.

33. Report 24 C.2 The statement that no testing, auditing or inspection was performed to determine the ef fect of manufacturing changes is misleading. Refer to Item 3, above.

-Entlosure July 27,1987 inspection Report Inaccuracies  !

Page 11 1

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PARA./ i DOCUMENT PAGE ITEM COMMENTS I i

34. Report 25 1 Three of the nine breakers noted by the NRC  !

to have been installed in safety-related MCCs were not installed in safety-related MCCs.

These breakers were installed in non )

safety-related MCCs IC, 2E and 2M at i locations FCLO3, FEE 3 and FMH2.

The statement that the breakers were removed or disconnected because acceptability questions "could not be resolved" would more accurately read "could not be immediately resol ved" . Once the NRC questioned the qualification of the breakers, Alabama Power Company immediately removed the breakers from service solely for the purpose of resolving any potential operability questions. The current wording fails to give credit to the commitment tn safety by Farley Nuclear Plant.

35. Report 28 1 Results of testing that confirmed operability were provided to the NRC prior to the issuance of this report; however, the results '

of these tests were not incorporated into the report.

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