IR 05000348/1986014: Difference between revisions

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{{Adams
{{Adams
| number = ML20203P227
| number = ML20207T494
| issue date = 07/31/1986
| issue date = 02/25/1987
| title = SALP Repts 50-348/86-14 & 50-364/86-14 for Jan 1985 - Jul 1986
| title = Errata to SALP Repts 50-348/86-14 & 50-364/86-14
| author name =  
| author name =  
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Line 10: Line 10:
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-348-86-14, 50-364-86-14, NUDOCS 8610270255
| case reference number = RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.4, TASK-TM
| package number = ML20203P223
| document report number = 50-348-86-14, 50-364-86-14, NUDOCS 8703240071
| package number = ML20207T462
| document type = SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 33
| page count = 9
}}
}}


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ENCLOSURE SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION
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February 25, 1987 ENCLOSURE APPENDIX TO ALABAMA POWER COMPANY FARLEY FACILITY SALP BOARD REPORT NOS. 50-348/86-14; 50-364/86-14 (DATED OCTOBER 16,1986)
==REGION II==
    .
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION  _
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REPORT NUMBERS 50-348/86-14, 50-364/86-14 Alabama Power Company Joseph M. Farley Units 1 and 2 January 1, 1985 through July 31, 1986 l
l l-l l-8703240071 870225 PDR 0 ADOCK 05000348 PDR L-
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8610270255 861022 PDR ADOCK 05000348 G PDR l
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. 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 information. SALP is supplemental to normal regulatory processes used to ensure compliance with NRC rules and regulations. SALP is intended to be sufficiently 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 operatio An NRC SALP Board, composed of the staff members listed below, met on October 2,1986, to review the collection of performance observations and data to assess the licensee performance in accordance with the guidance in NRC Manual- Chapter 0516, " Systematic Assessment of Licensee Performance." A summary of the guidance and evaluation criteria is provided in Section II of ~
this repor This report is the SALP Board's assessment of the licensee's safety performance for the J. M. Farley facility for the period January 1,1985 through July 31, 198 SALP Board for the J. M. Farley facility:
L. A. Reyes, Deputy Director, Division of Reactor Projects (DRP), Region II (RII) (Chairman) F. Gibson, Director, Division of Reactor Safety, RII Stohr, Director, Division of Radiation Safety and Safeguards, RII Verrelli, Chief, Projects Branch 2, DRP, RII Rubenstein, Director, Directorate 2, PWR-A Division, NRR Bradford, Senior Resident Inspector, Farley, DRP, RII E. A. Reeves, Project Manager, Directorate 2, PWR-A Division, NRR Attendees at SALP Board Meeting:
K. D. Landis, Chief, Technical Support Staff (TSS), DRP, RII i
H. C. Dance, Chief, Project Section 2B, DRP, RII L. P. Modenos, Project Engineer, Project Section 28, DRP, RII B. R. Bonser, Resident Inspector, Farley, DRP, RII II. CRITERIA
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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 significant to nuclear safety and the environment, and which is a normal
: programmatic area. Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observation 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; however, the SALP Board is not limited to these criteria
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and others may have been used where appropriat Management involvement in assuring quality Approach to the resolution of technical issues from a safety standpoint    !
i Responsiveness to NRC initiatives
! Enforcement history Operational and construction events (including response to, analysis of, and corrective actions for)
' Staffing (including management)
l Training and qualification effectiveness
!  Based upon the SALP Board assessment, each functional area evaluated is classified into one of the three performance categories. The definitions of
;  these performance categories ar'e:
}  Category 1:  Reduced NRC attention may be appropriat Licensee
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management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so
:  that a high level of performance with respect to operational safety or l  construction is being achiev'ed.
!
!  Category 2:  NRC attention should be maintained at normal levels.
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Licensee management attention and involvement are evident and are
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concerned with nuclear safety; licensee resources are adequate and are reasonably effective so that satisfactory performance with resoect to    ,
j-  operational safety or construction is being achieve I Category 3:  Both NRC and licensee attention should be increase !
Licensee management attention or involvement is acceptable and i  considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used so that minimally satisfactory performance with respect to operational safety or construction is being achieve The functional area being evaluated may have some attributes that would
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place the evaluation in Category 1, and others that would place it in either Category 2 or 3. The final rating for each functional area is a composite    ,
of the attributes tempered with the judgement of NRC management as to the j  significance of individual items.
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The SALP Board may also include an appraisal of the performance trend of a functional are This performance trend will only be used when both a definite trend of performance within the evaluation period is discernable and the Board believes that continuation of the trend may result in a change of performance level. The trend, if used, is defined as:
Improving: Licensee performance was determined to be improving near the close of the assessment perio Declining: Licensee performance was determined to be declining near the close of the assessment perio No trends were noted by the Board for this perio III. SUMMARY OF RESULTS Overall Facility Performance The Farley facility is well managed by qualified and experienced personne Senior plant managers hold active senior reactor operator licenses and the site is supported by a corporate organization that is composed of personnel who have extensive backgrounds in nuclear plant management and operation The licensee remains responsive to NRC concerns and the organization is safety criented. Strengths were identified in the areas of plant operations, surveillance, radiological controls, maintenance, fire protection, outages, and licensing activitie The Farley Nuclear Plant was effectively managed and continues to achieve a satisfactory level of operational safety. The licensee has strong programs in all aspects of plant operatio However, the weakness noted in the last SALP evaluation of procedure adherence is an area requiring continuing management attentio The licensee has initiated corrective action which appears to be effective. This is evidenced by a decrease in procedure violations in the surveillance area. However, violation of failure to follow procedure led to a Level III violation that rendered a train of the Residual Heat Removal System incapable of fulfilling its design functio Even though this condition was indicated on the main control board, it was not detected for 96 hour During the SALP pariod the Farley plant had high availability, fewer ,
than average number of reactor trips, few inadvertent ESF actuations, efficient operational and hardware response to the events that have occurred, prompt and thorough reporting of events when required, and low occupational radiation exposure The licensee recognized the potential plant-specific and generic consequences of the tendon failure problem and acted responsibly in reporting and resolving the even .
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The licensee has set high standards for cleanliness, radioactive wast control, general plant operations, and maintenance. The licensee is dedicated to long run time and short refueling outages. Unit l's longest run time was 321 days. This occurred during Cycle 6 from April 25, 1984 to March 13, 198 Nucleonics Week 1985 ranking of commercial reactors b'ased on cumulative capacity factor ranked Farley Unit 2 as #1 in the nation and #15 in world rankin B The performance categories fnr the current and previous SALP period in each functional area are as follows:
August 1, 1983 - January 1, 1985-Functional Area  December 31, 1984 July 31, 1986 Plant Operations  1  1 Radiological Controls  1  1 Maintenance  1  1 Surveillance  2  1 Fire Protection  1  1 Emergency Preparedness 1  2 Security  _
2  2 Outages-(includes refueling) 1  1 Quality Programs and  2  2 Administrative Controls Affecting Quality Licensing Activities  1  1 Training  1  2 IV. Performance Analysis Plant Operations Analysis During this assessment period, inspections were performed by the resident and regional inspection staffs. The licensee had a positive-nuclear safety attitude and exhibited no significant administrative, management control or material problems. The licensee's supervisory staff was knowledgeable and proficient in day-to-day plant operation Major operational decisions were made at a management level adequate to assure appropriate supervisory involvement. Plant operations were generally conducted in a conservative manner to ensure plant safet Overall control of plant operations was satisfactory and was well planned with established and realistic priorities. The licensee was quick to take corrective action when problems or violations were identified by NRC. The licensee has demonstrated responsiveness for items identified by the internal audit group. Corrective actions in
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February 25, 1987 Meeting Summary A meeting was held on October 21, 1986, at the Farley site to discuss the SALP Board Report for the Farley facilit Licensee Attendees W. O. Whitt, Executive Vice President R. P. Mcdonald, Senior Vice President
          ,
l W. G. Hairston, General Manager - Nuclear Support    !
J. D. Woodard, General Manager - Nuclear Plant    i D. N. Morey, Assistant General Plant Manager G. W. Shipman, Assistant General Plant Manager J. W. McGowan, Manager, Safety Audit Engineering Review (SAER)
R. D. Hill, Operations Manager L. A. Ward, Maintenance Manager L. M. Stinson, Plant Modifications Manager L. Enfinger, Administrative Manager
          .
          '
R. B. Wiggins, Supervisor of Operator Training J. K. Osterholtz, Supervisor - SAER NRC Attendees M. L. Ernst, Deputy Regional Administrator, Region II L. A. Reyes, Deputy Director, Division.of Reactor Projects (DRP)
H. C. Dance, Chief, Reactor Projects Section 18, DRP E. A. Reeves, Farley Project Manager, Office of Nuclear Reactor Regulation W. H. Bradford, Senior Resident Inspector, Farley B. R. Bonser, Resident Inspector, Farley I Errata Sheet - Farley SALP h  Line  Now Reads  Should Read 9 Last Line No change in NRC's reduced  No change in the inspection resources are  NRC's inspection recommende resources are t
recommende Basis for Change: The statement implies that the inspection program had been previously reduced. However, the Radiological area inspection program had not been reduce Although violation (a)... Although violation (e)
Basis for Change: To correct typographical erro ...nine apparent violations  ...eight apparent violations...
Basis for Change: To correct administrative error.


these areas were promp The licensee has demonstrated a thorough knowledge of regulations, guides, standards and generic issues and interpretations of these documents and associated issues were conservativ Licensee technical competence was well founded both in technical matters and general plant operation The plant staff responded to plant trips and other operational events during this review period in a professional and competent manne Daily conduct of business in the control room was performed in a professional manner. Access to the control room was controlled and limited to personnel conducting business. Radios and reading material not directly related to plant operation are not allowed in the control room or plant. Housekeeping throughout the plant was well maintaine The licensee was well prepared at meetings with NRC. The licensee's staff was able to make immediate commitments or state the utility's position in a given area, especially in the enforcement conference held at the Region on June 3, 198 The qualifications of ~ plant management exceeded NRC requirement Most senior plant managers hold senior reactor operator license Plant management was oriented towards safety and efficienc This was demonstrated by the close supervision of plant operations. The plant was well managed with conscientious and capable personne Licensee onsite evaluations were routinely performed to address, assess and correct reportable event An evaluation of the content and quality of a representative sample of Licensee Event Reports (LERs) was performed by the NRC using a refinement of the basic methodology presented in NUREG/CR-417 The results indicate that Farley has an overall average LER score of 7.8 out of possible 10 points, compared to a current industry average of 7.9. The principle weakness identified in the LERs, in terms of safety significance, involve the requirements to provide a safety assessment and to adequately identify failed components in the text. A strong point for the Farley LERs is that the requirement to provide the failure mode, mechanism, and effect of each failed component was satisfied for all applicable LER Seven reactor trips from power operation occurred on Unit 1 during the assessment period. Six trips were caused by equipment. failures and one by personnel error when a technician accidentally bumped a cable on a main feed pump which broke a wire and caused the pump to trip. Unit 1 trip rate was about 0.72 trips per 1000 hours of operation compared to a national average of 1.4 Unit 2 had eight trips from power operation and one trip during start-up at low power level . Five trips were caused by equipment failure, one from personnel error, one by lightning, and one at low reactor power level from low electro-hydraulic fluid pressure at the steam generator feed pum Unit 2 trip rate was about 0.88 trips per 1000 hours of operation.
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Reactor trips are described in Section . . - . . _ _.
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Seven violations were identi fie The plant staff is normally observant of Limiting Conditions for Operation (LCOs) and was generally conservative in its application of action statement requirement However, violations (a) and (b), listed below involved failure to
Both liquid and gaseous effluents were within regulatory limits or e
. follow procedures that resulted in improper system alignmen Violations (c), (d), (e), (f) and (g) involved procedural inadequacies and operator failure to comply with procedure Procedural violations indicates a lack of strict adherence in following procedure !
' quantities of radioactive material released and for dose to the maximally exposed individual. For 1985 releases, .the a imum
The licensee has initiated strong corrective action to instill in all personnel that plant procedures must be rigidly followe The elimination of personnel errors has beccme a pointed objective of
   ' calculated total body dose to a member of the public was 0.03 ren from liquid releases and 0.13 mrem from gaseous effluents. Thes calculated doses represented 0.12 percent and 0.52 percent of the 40 R 190 Itait of 25 mrea/ year. There were two unplanned gaseous role ses and one unplanned liquid release during the evaluation perio . The Itquid release was ' the result of leakage from the Componen Cooling Water-System into.the Service Water System. The gaseous r eases were caused by inadvertent venting of the Hydrogen Recombine System into the
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supervision. This is being accomplished by corrective action directed toward the employee as well as publication of personnel errors committed by the various work groups in the plan The personnel errors are displayed on closed circuit TV monitors located throughout
;  the plant and are tabulated and credited to the appropriate work l  groups. This process, though in the. early stages, has already shown positive result Severity Level III violation without civil penalty for violating
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regulatory requirements in that procedures and technical specifications (TS) were not adhered to which caused ECCS subsystem "B" train of RHR to be incapable of transferring pump
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suction to the containment sump during the recirculation phase of
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operation (348/86-10). Severity Level IV violation for not placing an inoperable Unit 2 power range channel in the tripped condition within one hour as required by TS (364/85-11). Severity Level IV violation for failure to update control room reference drawings to conform to as built status, failure to
!  adhere to requirements of a p'rocedure, and inadequate procedure j  (348,364/86-13).
 
i Severity Level IV violation for failure to have a continuous fire watch posted when a fire door was blocked open by a rubber hose
,  (364/86-10). Severity Level V violation for failure to adhere to the requirements of a procedure (348, 364/85-11).
 
i Severity Level V violation for failure to have an adequate
!  procedure to set the flow rate for the control room chlorine   '
detector (348/84-32).
 
t Severity Level V violation when a fire damper penetration was not functional due to a telephone cord blocking the closure of the damper (364/86-11).
 
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7 Conclusion Category: 1 Board Recommendations No changes in the NRC's reduced inspection resources are recommende Radiological Controls Analysis During this assessment period, inspections were performed by resident and regional inspection staff This included confirmatory measurements using Region II mobile laborator The licensee's health physics and chemistry staffing levels were appropriate and compared well to other utilities having a facility of similar siz An adequate number of ANSI qualified licensee and contract health physics technicians and of qualified chemistry technicians were available to support routine and outage operation Key positions in the radwaste management program and environmental surveillance programs were filled with qualified staf Two strengths of the health physics program were the quality of the health physics technicians and the experience level of the site health physics staf The staff has a low turnover rate and an effective training progra .The performance of the health physics and chemistry staff in support of routine operations and outages was good. No substantive issues were identified in this are Management support and involvement in matters related to radiation protection, radwaste control and chemistry was adequat Health physics management was involved sufficiently early in outage preparations to permit adequate planning. The station health physicist and plant chemist received the support of other plant managers in implementing the radiation protection and chemical control program Resolution of technical issues by the health physics and chemistry staff was generally adequate and responses to NRC initiatives were conducted in an effective and acceptable manne Audits performed by the corporate staff of the health physics, radwaste, environmental and chemistry programs were of sufficient scop and depth to identify problems and adverse trend Appropriate corrective actions were taken and documented. Audits performed by the site audit organization are discussed in Section I . _ .    . . . - .
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;    The licensee's radiation work permit and respiratory protection programs were found to be satisfactory. Control of contamination and radioactive materials within the facility was generally adequate. From January 1985 to July 1986, the amount of contaminated area decreased from approximately 24,398 to 23,626 square feet which represents 20%
Auxiliary Building. The design that vented the R Sump Vent into the Component Cooling Water Heat Exchanger Room wa corrected. The total activity for unplanned releases was 0.006 cur es for ifquid and 1 curies for gas. Unit 2 had no unplanned releases during this assessment perio In the area of plant chemistry the steam enerators had,:fn prior years of operation, accumulated significant amounts of iron-copper oxide
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percent of the radiologically controlled area of the plant. In 1985,
!    there was a 33 percent decrease in the number of clothing and skin
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contamination incidents when compared to 198 During 1985, the licensee's cumulative exposure was 400 man-rem per uni This compares favorable to the national average exposure of 425 man-rem per unit observed at similar PWR facilities. This lower than average collective dose results from the aggressive exposure control program established and implemented by the license During 1985, the licensee disposed of 8,730 cubic feet of solid i    radioactive waste per unit containing 410 curie This is less than the national average of 11,650 cubic feet per unit shipped by other utilities with similar facilities. This low amount is due primarily to a dedicated solid waste reduction program. A covered radioactive waste
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transfer facility is under construction to upgrade the outside bulk l    loading area and reduce exposure of waste handling personnel.
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In the area of radiological confirmatory measurements, the licensee i
participated in the NRC's spiked sample program. .The licensee has had consistent problems with the FE-55 analysis for the past three years, indicative of a weakness in the radiological measurements program; however, the 1986 spiked sample results showed agreement with known concentration of Fe-55, but only after reanalysis by the license The licensee submitted the required radiological effluent and environmental reports during the evaluation perio Radioactive r
gaseous effluents for 1985, for Units 1 and 2 combined, were 2,368
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curies of noble gases, 6.0E-4 curies of halogens (including I-131),
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5.0E-5 curies of mixed fission product and irradiation product
sludge as well as potentially corr tve species (e.g, chloride, sulfate) that were present as " hide t return." Consequently, several days were required during startup ter each lengthy outage to achieve the desired level of chemistry ontrol. During the last two fuel cycles of each unit the licens had achieved stable plant operation and a high level of chemistry ontrol while making progress in removing both sludge and reducing t e effects of hideout from the steam generators. In an effort t eliminate the detrimental effect of copper as a corroding element, he licensee had replaced all copper heat exchanger tubes in th condensate /feedwater train. In addition, inleakage of air conde er cooling water through the condenser had been effectively eliminate . All elements of the chemistry program had been-upgraded to impleme the recommendations of the Steam Generator Owners
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particulates, and 470 curies of tritium. Alpha-emitting particulates
_ Group.
!    aerosols were-not detected. The 1985 Region II averages for a two unit site (based on 21 operating PWRs) were 10,360 curies of noble gases, 0.12 curies of halogens and 190 curies of tritium. Radioactive liquid i    effluents for the two unit site totalled 0.071 curies of mixed fission i
and irradiation products, 1,105 curies of tritium and 2.0E-4 curies of long-lived alpha emitters released in 2.1 E7 gallons of liquia plant effluent The 1985 Region II averages for a two unit site were 2.7
. curies of mixed fission products, 840 curies of tritium and 2.2E-4 curies of alpha emitters. The licensee's releases were less than the average annual releases reported by 21 Region II plants of similar size
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and type for 1985, with the exception of tritium.


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Two violationyv ere identified for failure to assure that radioactive material shi d for burial was without free standing liquid.
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, Sever y Level IV violation for failure to assure that radioactive
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! mate al shipments for burial were without free standing liquids ( , 364/85-34).
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b. , everity Level IV violation for failure to have adequate
Both liquid and gaseous effluents were within regulatory limits for quantities of radioactive material released and for dose to the maximally exposed individua For 1985 releases, the maximum
  + procedures to preclude shipping radioactive material for burial i
, calculated total body dose to a member of the public was 0.03 mrem from liquid releases and 0.13 mrem from gaseous effluents. These calculated
4 with free stanuing liquids (348, 364/85-34).
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doses represented 0.12 percent and 0.52 percent of-the 40 CFR 190 limit
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of 25 mrem / year. There were two unplanned gaseous releases and one unplanned liquid release during the evaluation perio The liquid release was the result of leakage from the Component Cooling Water System into the Service Water System. The gaseous releases were caused by inadvertent venting of the Hydrogen Recombiner System into the Auxiliary Building. The design that vented the RHR Sump Vent into the
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Component Cooling Water Heat Exchanger Room was corrected. The total activity for unplanned releases was 0.006 curies for liquid and 11.5
: curies for ga Unit 2 had no unplanned releases during this assessment perio In the area of plant ' chemistry the steam generators had, in prior years of operation, accumulated significant amounts of iron-copper oxide


  < sludge as well as potentially corrosive species (e.g, chloride,
L 4 Conclusion - .


sulfate) that were present as " hideout return." Consequently, several days were required during startup after each lengthy outage to achieve the desired level of chemi stry control . During the last two fuel cycles of each unit the licensee had achieved stable plant operation and a high level of chemistry control while making progress in removing
'' Category 1 Board Recommendations:
; both sludge and reducing the effects of hideout from the steam generators. In an effort to eliminate the detrimental effect of copper
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as a corroding element, the licensee had replaced all copper heat exchanger tubes in the condensate /feedwater trai In addition, inleakage of air condenser cooling water through the condenser had been effectively eliminated. All elements of the chemistry program had been upgraded to implement the recommendations of the Steam Generator Owners Group.
No change in the NRC's reduced inspection resources are recommended.


! Two violations were identified for failure to assure that radioactive material shipped for burial was without free standing liqui Severity Level IV violation for failure to assure that radioactive
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material shipments for burial were without free standing liquids (348,364/85-34).


, Severity Level IV violation for failure to have adequate l procedures ' to preclude shipping radioactive material for burial
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:  with free standing liquids (348, 364/85-34). Conclusion Category 1
; Board Recommendations:
:
No change in the NRC's reduced inspection resources are recommende . ..
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C. Maintenance Analysis During this assessment period, inspections were conducted by the resident and regional inspection staff The maintenance program continued to be strong. Management involvement in maintenance planning and practices were eviden First line supervisors and maintenance personnel indicated a high awareness for procedural adherence. This is indicative of the positive nuclear safety attitude in the preventive and corrective maintenance program The licensee's approach to the resolution of technical issues continues to be soun The licensee's maintenance program was well controlled by specific procedure The personnel participating in activities affecting equipment on the Q-list were aware of the quality assurance (QA)
Both liquid and gaseous effluents-were within regulatory limits for quantities of radioactive material released and for dose to the maximally exposed individual. For 1985 releases, the maximum calculated total body dose to a member of the public was 0.03 mrem from liquid releases and 0.13 mrem from gaseous' effluents. These calculated-doses-represented 0.12 percent and 0.52 percent of the 40 CFR 190 limit of 25 ares / yea There were two unplanned gaseous releases and one unplanned liquid release during the evaluation period. The liquid release was the result of leakage from the Component Cooling Water System into the Service Water Syste The gaseous releases were caused by inadvertent venting of the Hydrogen Recombiner System into the Auxiliary Building. The design that vented the RHR Sump Vent into the Component Cooling Water Heat Exchanger Room was corrected. The total activity for unplanned releases was 0.006 curies for liquid and 1 curies for ga Unit 2 had no unplanned releases during this assessment perio In the area of plant chemistry the steem generators had, in prior years of operation, accumulated significant amounts of iron-copper oxide sludge as well as potentially corrosive species (e.g, chloride, sulfate) that were present as " hideout. return." Consequently, several days were required during startup after each lengthy outage to achieve the desired level of chemistry contro During the last two fuel cycles of each unit the licensee had achieved stable plant operation and a high level of chemistry control while making progress in removing both sludge and reducing the. effects of hideout from the steam generators. In an effort to eliminate the detrimental effect of copper as a corroding element, the licensee had replaced all copper heat exchanger tubes in the condensate /feedwater train. In addition, inleakage of air condenser cooling water through the condenser had been effectively eliminated. All elements of the chemistry program had been upgraded to implement the recommendations of the Steam Generator Owners Grou Two' violations were-identified for failure to assure that radioactive material shipped for burial was without free standing liqui Severity Level IV violation for failure to assure that radioactive material shipments for burial were without free standing liquids (348,364/85-34). Severity Level IV violation for failure to have adequate procedures to preclude shipping radioactive material for burial with free standing liquids (348, 364/85-34). Conclusion Category 1 Board Recommendations:
controls. The craft personnel performing maintenance and surveillances were knowledgeable of maintenance procedures and plant equipmen Maintenance Work Request (MWR) packages had the required reviews and approvals prior to the start of the work. The MWR indicates the proper Q-list classification, work was completed and inspected as required, and post-maintenance testing was conducte Use of the Nuclear Plant Reliability Data System (NPRDS) has increased the licensee's awareness of potential plant problems. Upgrades in the Computer Historical and Maintenance Program System (CHAMPS) and implementation of data verification has improved the data base used for maintenance planning and schedulin Staffing increases added maintenance planners who provided better scheduling and coordination of the activities of each maintenance disciplin During a regional maintenance inspection, instances of breakdowns in the corrective maintenance process occurred. One event included the licensee's failure to properly conduct corrective maintenance activities involving wiring errors associated with the feedwater flow control valve A second particular concern was the licensee's inadequate processing of the maintenance work request on a failed electrical penetration which had caused a forced outag These instances indicate that under some circumstances, a less than meticulous attention to detail has been directed towards corrective maintenance activitie A special inspection conducted to evaluate the licensee's actions in response to Generic Letter 83-28 revealed that maintenance activity and post-maintenance testing were adequate to ensure reactor trip system reliabilit ,aa: o _- J.-5 4
No change in the NRC's inspection resources are recommende _ . . _ . . , _ _ _ _ __ _ . . .
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Once identified, equipment and-components received adequate preventive maintenance. However, inadequacies were identified in the scope of the preventive maintenance program .which included the failure to incor-porate compressed air system pressure switches and inverter circuit breaker The licensee utilizes a predictive maintenance analysis which includes oil and vibration analysis on mechanical equipment and infrared analysis on electrical equipmen These techniques have enabled the licensee to predict degrading trends in equipment performance and effect repairs before equipment failure occur The licensee was responsive to NRC concerns and conducted evaluations to identify and correct, if required, activities related to maintenance which appeared to be contrary to the prescribed function of equipmen This is exemplified by the licensee's action in the investigation and repair of Unit 2 containment building post-tensioning system and modification to the Atwood Morrill Company main steam isolation valves on Unit ? in which the valve shafts were modified. Unit I will be modified during the next refueling outag Six. violations were identified. Five of these resulted from not following existing procedures and drawings as noted below. One involved independent in process inspection Severity Level IV violation for not performing independent in process inspection for Class 1 and 2 pipe welds (348/85-33). Severity Level IV. violation for failure to wire feedwater control valve in accordance with the work request and complete maintenance prescribed procedures or drawings (343/85-40). Severity Level V violation for failure to follow prescribed procedures for Class 2 pipe support spring hangers in that the support settings were not recorded and verified (348/85-33). Severity Level V violation for failure to install spacers between the cells of the service water batteries and the uninterruptible power supply batteries as required by sendor drawings (348, 364/85-20). Severity Level V violation for having combustible liquids unattended in the hot machine shop (348/85-24).
 
i Severity Level V violation for having combustible liquids unattended in the hot machine shop (348, 364/86-11).
: Conclusion l
; Category 1
:
,
  ..- _ . _ ,- . ~ , _ _ __ , ,,--, - - - ,, ,,,.,_ - ....- ,_,4 . ~ - - - . , , - - , --
 
. ..
  .
  .
12 Board Reccmmendations Due to the findings identified during. a team inspection, the Board recommends that the routine inspection program be conducted in the maintenance are D. Surveillance Analysis During the assessment period, inspections were performed by the resident and regional inspection staffs. These included activities related to inservice inspection and testing: surveillance, containment building tendons, and containment intergrated leak rate testin Routine plant surveillance related activities appeared to be planned and well define The licensee has continuously upgraded the surveillance progra Review of surveillance activities was performed by prescribed licensee reviewers who were qualified to perform these activitie Review of surveillance records revealed that they were readily available, complete, and adequately maintaine Onsite evaluations were routinely performed to address, assess and correct surveillance concerns. The licensee's nnsite corporate QA organization was heavily involved in the surveillance progra Licensee response to NRC initiatives was timely and there were few long-standing regulato ry issues attributable to the license ,
Understanding of technical issues was apparent with timely resolutio '
Viable, sound and thorough responses were offere Licensee management involvement in Inservice Inspection and Inservice Testing 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 soun Records were complete, well maintained, and readily availabl The surveillance procedures reviewed, tests that were witnessed, and examinations of test results, revealed that the licensee's surveillance procedures were technically adequate and satisfactorily execute Inspection of the snubber surveillance - program-identified a problem with the visual inspection procedur The licensee agreed to . revise their procedure to eliminate any confusion with the TS requirement The snubber surveillance records were complete, well maintained, legible, and retrievable.
,
;
;
!
i
. ..
.
.


:The four violations identified are not considered to indicate significant programmatic deficiencies. Violations (a) and (d) involved procedure violations. Violations (b) and (c) concerned control of measuring and test equipmen Severity Level IV violation for not conducting a review of a completed surveillance test procedure within the time frame specified by an administrative procedure (364/85-44). Severity Level V violation for changing the work sequence from that which was specified on the Maintenance Work Request without appropriate review and approval (348/85-17). Severity Level V violation for not establishing suitable environmental conditions for calibration of measuring and test equipment (348,364/85-25). Severity Level V violation for not establishing adequate measures to assure that measuring and testing devices are calibrated with sufficient frequency to assure accuracy (348, 364/85-25). Conclusion Category 1 Board Recommendations No change in the NRC's reduced inspection resources are recommende Fire Protection Analysis
_ . Severity' Level' V violation for failure to have one chargin pump in the boron injection flow path _ operable as required by T chnical Specificati.on during Unit I refueling-operations (348/85- 0).
      '
During this assessment period, inspections were performed by the resident and regional inspection staffs. A special team inspection was conducted of the licensee's fire protection / prevention program reevaluation of 1985 with respect to compliance with 10 CFR - 50 Appendix R, Sections III.G., III.L., and II On November 19, 1985, the Commission granted exemptions to 10 CFR 50  -
      .
Appendix R at the licensee's request for 33 of 49 specific fire areas of Unit 2 and areas shared with Unit The remaining requests for exemptions for 16 fire areas are under Commission review. Additional justification have been provided by the licens In addition, exemptions for 27 specific fire areas of Unit 1 were requested by the licensee. The exemption resulted from the licensee's fire program reevaluation noted above. As of July 31, 1986, Commission action remains open for these 27 fire areas on Unit >
b
  . y -w ym .r--- -,-,--,--#,.w.-ve,---..,=,-,w- .--,mm


  . ..
' Severity Level V violation for performing reactor re video inspection without a procedure to govern the activit (364/85-04). Severity Level V violation for failure to fully implement fuel handling procedure sequence' in releasing the t  fastener during new fuel receipt and inspection (364/85-43). Conclusion Category 1 Board Recommendations
.
'
No changes in the NRC's reduced inspecti n resources are recommended.


  .
. Quality Programs and Administration ntrols Affecting Quality Analysis
The licensee has issued the appropriate alternative shutdown procedure for a fire in the cable spreading room and control roo This procedure was found to meet Appendix R, Section III.L. requirement With respect to Section III.G., Fire Protection of Safe Shutdown Capabilities, the fixed fire protection extinguishing systems, fire / smoke detection systems, one hour raceway fire barrier enclosures, and fire area three hour fire barrier boundaries were found to be in Service. In addition, these permanent plant fire protection features were found to be adequate with respect to maintaining one train of systems necessary to achieve and maintain hot standby free from fire damag The inspectors also found the reactor coolant pump oil collection system design to meet the seismic and oil collection requirements of Section II The licensee identified, analyzed and reported fire prevention events and discrepancies as required by license condition or technical specification These reports were reviewed and found to be satisfactor In general, the management involvement and control in assuring quality in the fire protection program is evident as demonstrated by the completeness of the engineering analysis associated with the inple-mentation of the Appendix R requirement The licensee's apprcach to resolution of technical fire protection issues indicates a clear understanding of the issues. The responsiveness to NRC initiatives are technically sound and thorough in almost all case Licensee identified fire protection related events or discrepancies are properly analyzed, promptly reported and effective corrective actions take The previous SALP report refers to a well qualified staff and high quality training progra No violations of deviations were identifie . Conclusion Category 1 Board Recommendations:
'
No changes in the NRC's reduced inspection resources are recommende Emergency Preparedness Analysis During the assessment period, inspections were performed by resident and regional inspection staffs. These included observation of a small scale emergency preparedness exercise in September 198 .
During the assessment perio'  d , inspections were conducted by the resident and regional inspec on staffs. The following areas were
 
    -
.
. ..
.
 
Inspections disclosed that the licensee had adequate emergency preparedness organization and staffing at the plant and corporate level. Corporate management appeared committed to an effective emergency response progra Senior corporate officials were directly involved in the annual emergency exercise, drills, and followup critique The following essential elements of emergency response were determined to be acceptable: emergency detection and classification; protective action decision making, except as discussed below; shift staffing and augmentation; training, except as indicated below; dose calculation and assessment; public information; annual quality assurance audits of plant and corporate emergency preparedness programs; changes to emergency plan and implementing procedures; coordination of offsite agencies; identification of weaknesses during drills and exercise The exercise demonstrated that the emergency plan and respective procedures could be implemented, although one violation involving notification of emergencies within 15 minutes was note Three of the four weaknesses identified were identified by the licensee. The licensee failed to follow the format agreed upon between the states and the licensee in making initial offsite notificatio During the exercisc, no protective actions were taken onsite during and following the simulated plume passage. Onsite communications needed improvement in that the Recovery Manager was not informed of the Emergency Director's reclassification of the Site Area emergency to an Alert until 16 minutes after the reclassification had been announced to offsite officials. Also, one plant procedure did not clearly define the use of plant personnel in the dose assessment group. The licensee committed to resolve the above exercise weaknesse The violation noted is not indicative of a programmatic breakdow Severity Level IV violation for failure to provide the capability and ' procedures for notification of offsite State and local agencies within 15 minutes following emergency declarations (348, 364/85-37). Conclusion Category 2 Board Recommendations:
No change in the NRC's reduced inspection resources are recommende .
e
 
  ._ .  . - . . - -  . - - . . . _ _ _ - - . - _ . _- . . . _ _ - - .. = - - _ . . .-
  ,
  ,
  . ..
reviewed by the regional taff: licensee actions on previous
  .
[  enforcement matters, qu ity assurance / quality control (QA/QC)
  !.
'
administration, audits, ocument control, and licensee actions on previously identified i pection findings.


;
3  Interviews with lice ee personnel indicated that the QA program was e  adequately stated d understoo Frequent site communication was
. Security and Safeguards Analysis During the assessment period, inspections were conducted by the i    resident and regional inspection staffs. A Regulatory Effectiveness    ;
<
Review (RER) was also conducted. Although the RER report was not    ]
'  evident and indi ted .that corporate QA management was actively involved in ons activitie s Key staff p tions had been identified and authorities and respon-sibilities r these positions were procedurally delineated. Staffing was adequa e. During this assessment period, two senior reactor
issued during the rating period, the licensee has taken actions to compensate for a potential safeguards vulnerability identified during    l
'
'
the RER. Further, the licensee has established a program for upgrade
operatort were assigned to the audit staff. Their addition provided
,
, depth additional expertise to operational auditing activitie r  y Aud * performed by onsite QA personnel are basically compliance au4 s. Audits were written by the licensee in a professional and a pt manner. Although violation (a) was identified in this area, the
and/o'r replacement of physical security hardware identified as inadequate in the RER. Additionally, the licensee is using members of the security force as compensatory measures for RER identified safeguards inadequacies and concerns until completion of hardware j:    upgrade / replacemen Procedures have been placed in effect by the j    licensee to correct other procedural problems identified by the RER.
.
 
4 olation was administrative in nature. Audits and their responses
;  & ere completed i n- a timely manner, compreTiensive checklists were 4 utili:ed, and all audit findings were reviewed by the Senior Vice
'
'
The licensee is working with the Division of Safeguards, NMSS, in order to resolve other issues arising from the RE Authority and responsibilities associated with the security organi-
President. However, the site internal audit organization lacked
.!    zation were cleariy delineated and appeared to be effective. The site
;  sufficient expertise in the area of health physics to perform meaningful evaluations.
>
organization is adequately staffed and appropriately trained and j-    equipped. The facility guard Training and Qualification Plan is i    implemented on a continuing basis at all levels of the security i
organization using the onsite training staff supplemented by corporate specialist Changes to the licensee's Physical Security Plan were submitted on a timely basis under the provisions of 10 CFR 50.54(p).
:    The licensee's independent security program audit covers all aspects of
!    the site security program and the program auditors seem well acquainted with the prsgra t
.!    Three violations were identified. The violations appear to have been
;
caused by a lack of effective program oversight rather than guard force inadequacy, Severity Level IV violation for failure to protect vital. equipment with two physical barriers (348, 364/85-08).
: Severity Level IV. violation for several protected area perimeter
  ;      inadequacies: several protected area gates were not protected by
;      an intrusion detection system, the security fence was not secured
;      at the bottom, and a portion of the microwave system was inadequate (348, 364/85-08).


I
;    ,-
' Severity Level V violation for inadequate security procedures (348,364/85-08).
.. . - - . - - . -


i,
_
{
f
-_ - - , - . - , . . . . . , . . . . - _ - _ _ . - - . _ _ - . - - - _ _ . _ - - _ _ - _ - - . - . - .    . - -
 
_ _ .  . . _ _ _ __ -.- _ . . _ _ - _ _ _ . _ ._
          -  _
i
: . ..
  .
  .
I
:
l Conclusion-
Category . Board Recommendations:
Management attention should be directed to the prompt resolution of the RER findings. No changes to the NRC's inspection resources are recommende Outages      +
i i    Analysis During the assessment period, inspections were performed by the resident and regional inspection staff The regional staff. also
!    reviewed the design change program, inservice inspections of safety-
. related components and associated piping, supports, and snubbers; j    inservice testing of pumps and valves; welding and nondestructive testin Unit I had one refueling outage from April 6,1985 to J  - 4, 198 Two refueling outages were performed on Unit 2, January b, '985~to l    March 3, 1985 and April 5, 1986 to May 29, 198 Major act. .ities
-
conducted during these refueling outage consisted of:
'        ~ The Anti-vibration bars (AVB's) in Unit 1_ steam genera * ,r 1B, and i    Unit 2 steam generators 2A and 2B were replaced wi a modified
'
AYB's to reduce tube wear.
i An extensive inspection and repair program was completed on the
!-    containment building tendons of_ Units 1 and 2. See also Section IV.J. of this report.
I
; The high pressure turbine rotor, blade rings and nozzle blocks were replaced.
i All feedwater heaters on both units have been replaced with
!    heaters having stainless steel tube bundles.
I i Eddy current testing of steam generator tubes and tube removal on
;    Unit 2.
!
! Local leak rate testing and containment integrated leak rate j    testing on Unit 2.
i l Unit 2 reactor vessel level monitoring system installation.
I
!
!
L
!
!.
L
. _ . - - - _ _ . - _ _ , . _ _ _ _ . . . . _  . _ _ _ _ - . _ _ _ _ _ _ - - _ -
_ _ _
, . .  . . .  -  . . .-_ ~ .- ..
. .
  .
  .
 
19 Severity Le' vel V violation for failure to have one charging pump in the boron injection flow path operable as required by Technical Specification during Unit I refueling operations (348/85-20). Severity Level V violation for performing. reactor core video inspection without a procedure to govern the activity (364/85-04). Severity Level V violation for failure to fully implement fuel handling procedure sequence in releasing the top fastener during new fuel receipt and inspection'(364/85-43). Conclusion Category 1- Board Recommendations
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 a  review group performed audits during the refueling period. The licensee scheduled and followed the refueling outage with the aid of
No changes in the NRC's reduced inspection resources are recommende Quality Programs and Administration Controls Affecting Quality Analysis During .the assessment period, inspections were conducted by the resident and regional inspection staffs. The following areas were
^
  . reviewed by the regional staff: licensee actions on previous enforcement matters, quality assurance / quality control (QA/QC)
'
administration, audits, document control, and licensee actions on previously identified inspection finding Interviews with licensee personnel indicated that the QA program was adequately stated and understood. Frequent site communication was evident and indicated that corporate QA management v3s actively involved in onsite activitie Key staff positions had been identified and authorities and respon-sibilities for these positions were procedurally delineated. Staffing was adequate. During this assessment period, two senior reactor operators were assigned to the audit staff. Their addition provided depth and additional expertise to operational auditing activitie Audits performed by onsite QA personnel are basically compliance audits. Audits were written by the licensee in a professional and adept manne Although violation (e) was identified in this area, the violation was administrative in nature. Audits and their responses were completed in a timely manner, comprehensive checklists were utilized, and all audit findings were reviewed by the Senior Vice Presiden However, the site internal audit organization lacked sufficient expertise in the area of health physics to perform meaningful evaluation ,
flow and critical path charts. At the conclusion of each refueling outage . the licensee conducted a complete review of completed work.
F
 
      ,, ..
. Problem areas were identified and analyzed. Special attention was given to these areas for future refueling outage schedulin The licensee's overall control and planning for refueling outages results in a well planned and controlled evolution. All work is planned with regard to scope, repair parts and work procedures.
 
!  Planning for the next refueling cutage starts at the conclusion of the
'
present outag There are in the order of 70 to 100 modifications performed on each unit during a refueling outage with each refueling
,
outage typically scheduled for six weeks. Extensive operator training
  '
is conducted to familiarize personnel with plant modification The licensee's interface and control of contractors during refueling -
l outages has become stronge This is primarily due to business meetings which the licensee has set up with the contractors prior.to '
the start of the work. This accounts for the licensee having better
'
control and understandi.ngs with the contractor.
 
j  Licensee management involvement in inservice inspection activities 1  appeared to be adequate and decision making was at a level that assured I  adequate management review. Records were complete, well maintained,
,
and available. Procedure and policies were occasionally violated as j  evidenced by the violations listed below.
 
Six violations were identified. Violation (a) involved inadequate
>  activities performed by a contractor quality control inspecto Violations (b), (c), and (d) involved failure to comply with Technical
'
'
Specifications requirements. Violations (e) and (f) involved procedure violations. These violations, while not indicative of a programmatic l  problem, indicate procedural adherence problems.
:
' Severity Level IV violation for failure to follow the inspection plan for inspection of steam generator welds (348/85-22). Severity Level IV violation for failure to adhere to the requirement of a procedure which violated Unit 1 containment
;  integrity by having both inner and outer doors of the containment auxiliary hatch open during refueling operation (348/85-20). Severity Level IV violation for failure to adhere to procedure requirements which caused the loss of both Unit 1 RHR trains for
;  52 minutes during a refueling outage (348/85-20).
 
I
,~ . - - . - - . .- _._ - -,-- , . . _ . . . _ - - . _ . ~ _ _ , .
 
. ..
  .
  .
19 Severity Level V violation for failure to have one charging pump in the boron injection flow path operable as required by Technical Specification during Unit 1 refueling operations (348/85-20). Severity Level V violation for performing reactor - core video inspection without a procedure to govern the activity (364/85-04). Severity Level V violation for failure to fully implement fuel handling procedure sequence in releasing the top fastener during new fuel receipt and inspection (364/85-43). Conclusion Category 1 Board Recommendations No changes in the NRC's reduced inspection resources are recommende I. Quality Programs and Administration Controls Affecting Quality Analysis During the assessment period, inspections -were conducted by the resident and regional inspection staffs. The following areas were reviewed by the regional staff: licensee actions on previous enforcement matters, quality assurance / quality control (QA/QC)
administration, audits, document control, and licensee actions on previously identified inspection finding Interviews with licensee personnel indicated that the QA program was e adequately stated and understood. Frequent site communication was evident and indicated that corporate QA management was actively involved in onsite activitie Key staff positions had been identified and authorities and respon-sibilities for these positions were procedurally delineated. Staffing was adequate. During this assessment period, two senior reactor
; operators were assigned to -the audit staf Their addition provided depth and additional expertise to operational auditing activities.
l Audits performed by onsite QA personnel are basically compliance audit Audits were written by the licensee in a professional and adept manner. Although violation (a) was identified in this area, the
; violation was administrative in nature. Audits and their responses t were completed in a timely manner, comprehensive checklists were
'
utilized, and all audit findings were reviewed by the Senior Vice
!
President. However, the site internal audit organization lacked sufficient expertise in the area of health physics to perform
} meaningful evaluation . _  __ . . - -
;
. ..
  .
  .


,
  (4 of 10) failure for R0s. February 1986 results yielded no failur s for two SR0s and two R0s. July 1986 results yielded an overall fa ure rate of 40% (4 of 10) for SR0s and no failure for one R0. Are of generic weakness noted during the candidate's operating exami tions were as follows:
The audits examined contained two types of findings, noncompliance and
  *
'
  *
comment The noncompliances were licensee identified violations of
Difficulties in classifying emergency plan levels
;  regulatory and site procedural requirements. Comments appeared to be used by the audit group to identify weaknesses in the site's methods or procedures to management. Of the comments examined by the NRC, some of those appeared to be in grey areas which were not strictly defined by regulation; a subset of those comments appeared to be borderline
  *
:  noncomplianc Overall, the comment concept is acceptable for its feedback potential.
Inadequate use of procedures during simulator exams Inability to diagnose minor malfunctions and abnor al situations
 
  *
*
on simulator exams Incensistent use of abnormal operating procedure During inspection (85-15) conducted in March 19 5, nine apparent violations were identified; however, as a resul of the current NRC policy statement and agreement with INPO on tra ing and qualification of nuclear power plant personnel, these appa nt violations are being
Based on the samples selected by the inspectors,. the process of-releasing'and controlling documents for the purpose of maintenance and operation of the plant was effective. Aside from some minor filing problems at the user level, the document control program met regulatory requirements and also met requirements that site personnel had placed
,
,
on the system.
carried as unresolved items. The followin summary describes the corrective actions taken by the licens  with regard to these unresolved items. (It should be noted th the NRC has not reinspected these items but is taking steps to d termine whether appropriate corrective actions have been taken.)


.
(a) In December 1984, the Accredi ation Board of the Institute of Nuclear power Operations (IN ) awarded Farley accreditation for several training programs neluding Operator License, License Upgrade, and Shift Superv sor Training. One of the unresolved items pertains to Farl 's failure to implement the INPO accredited SRO Upgrade raining program. The licensee has stated this training is now  ecifically addressed in procedures and is implemented in their rogra .
'
  (b) The licensee cond cts the annual procedure review simultaneously with control ma pulations. This practice has not ensured that all procedures are reviewed, or that a procedure is utilized in its entirety, s required by 10 CFR 55, Appendix A, 3.d. The licensee st ted current training specifically addresses this matter. 4
The procurement of safety-related equipment and services and the receipt, storage, and handling of materials met regulatory require-
    +
. ment Procurement documents were complete, accurate, and equipment storage areas were well organized and clean. The licensee constructed a new warehouse which is capable of containing all safety-related parts
  (c) Since c mpletion of the initial training in mitigating core damage in Ma of 1981, replacement licensed operators have not received thg, quivalent training pursuant to NUREG 0737, II.B.4, nor had
!
'
and equipment under one roof in an environmentally controlled atmospher The licensee has been responsive to NRC concerns as evidenced by successfully taking corrective actions for previously identified enforcement matter Two previously identified -inspection findings were also reviewed and although they could not be closed, corrective
; action was ongoin The special tests and experiments program was adequate; however, a violation was identified because one special test package was not
,
,
reviewed by the plant manager prior to implementatio The apparent
t training been specifically conducted as part of licensee ualification training. Additionally, the licensee had failed
!  root cause of this problem was that site procedures had not - been updated to raflect this technical specification requiremen Records
  + o provide mitigating core damage training b all I&C technicians
:  for this program were readily retrievabl Safety evaluations were
  * as committed to in their letter dated February 9,  198 The Itcensee has stated that current trainifig is now provided to these
'
thorough and technically adequate.


.
  [ individual (d) In the area of operational feedback experience, it was noted that the distribution of pertinent information to the individual mechanics and I&C technicians was informal, uncontrolled, and not
'
. _ _ _ _ _ _ _ _ . . -
The Quality Program and Administrative Controls Affecting Quality section of this SALP report includes an assessment of the licensee's ability to identify and correct his problems. As such, each specific SALP functional area provides input for judging QA program effective-ness. As previously mentioned in this report, the licensee takes pride in the'c plant as evidenced by standards set for cleanliness, radwaste
_ _ _ . _ _ _ - - --- - - - - - - - - - - - - - - - - - - - - -
>  co itrol, general plant operations, and maintenanc These attributes reflect positively on QA program effectiveness. However, the problems addressed in Section K, Training and Qualification Effectiveness pertaining to wrong unit / wrong train reflects negatively on the QA program effectiveness. _ _ _ , ._ _ ___ _ _ - . . _ _ _ . _  __


  . ..
  . . - - _ .  - -. . . - . .
-
& -
l
.,


Five violations were identifie Violation -(d) resulted when site procedures were not updated to the technical _ specification require-ment Severity Level IV violation for failure to establish measures to verify correct item replacement which allowed incorrect fusible links to be installed in 2B and 2C containment air. coolers (364/85-05). Severity Lavel IV violation for failure to have a procedure reviewed independently of the group that wrote the procedure (348, 364/85-34). Severity Level V violation for failure to perform evaluations on test equipment and prompt assessment of safety significance for measuring and test devices found out of tolerance (348, 364/85-25). Severity Level V violation for failure to have measures established to assure that the plant manager approves tests and experiments prior to implementation (343, 364/85-32). Severity Level V violation for failure to list persons contacted during the audit (348,'364/85-21). Conclusion Category 2 Board Recommendations No cha'nges to the.NRC's inspection resources are recommende J. Licensing Activities Analysis Performance in the area of licensing continues to demonstrate a high level of management involvement in assuring quality in licensing activitie Corporate management is frequently involved in site activitie This attribute was most certainly . evidenced by the-containment tendon problem on Unit 2 described belo During the third refueling outage on Unit 2, a degraded vertical tendon was found during preparation for the containment building integrated leak rate tes Licensee senior management organized and directed an aggressive program of inspection and repair of -the tendons because of an uncertainty in the licensing basis for the containment structural . . - - . __ . .
. ..
.
.
.
  (4 of 10) failure for R0s. February 1986 results yielded no failures for two SR0s and two R0 July 1986 results yielded an overall failure rate of 40% (4 of 10) for SR0s and no failure for one RO. Areas of generic weakness noted during the candidate's operating examinations-
  -were as follows:
  *
  *
Difficulties in classifying emergency plan. levels
  *
Inadequate use of procedures during simulator exams
Inability to diagnose minor malfunctions and abnormal situations
  *
on simulator exams Inconsistent use of abnormal operating procedures
'          ,
'  During inspection -(85-15) conducted in March 1985, eight apparent violations were~ identified; however, as a result of the current NRC -
policy statement and _ agreement with INPO on training and qualification of nuclear power plant personnel, these apparent violations are being carried as unresolved items. The following summary describes the
'  corrective actions taken by the licensee with regard to these unresolved item (It should be noted that the NRC has not reinspected these items but is taking steps to determine whether ' appropriate corrective actions have been taken.)


integrit Licensee management briefed the Commission staff on the proposed action plan during a meeting on February 7, 1985, in Bethesda, i Maryland. Later, on March 1,1985, licensee management again briefed
(a) In December 1984, the Accreditation Board of the Institute of Nuclear Power Operations (INPO) awarded Farley accreditation for
,
'  several training programs including Operator License, License Upgrade, and - Shift Supervisor Trainin One of the unresolved items pertains to Farley's failure to implement the INPO accredited SRO Upgrade Training progra The licensee has stated this training is now specifically addressed in procedures and is implemented in their progra (b) _ The licensee conducts the annual procedure review simultaneously with control manipulation This practice has not ensured that all procedures are reviewed, or that a procedure is utilized in l  its entirety as required by 10 CFR 55, Appendix A, 3.d. The licensee stated current training specifically addresses this matte (c) Since completion of the initial training in mitigating core damage in May of 1981, replacement licensed operators have not received i
the Commission staff on the inspection and repair program for Unit The initial repair phase was completed on Unit 2 in April 1985,-and on
the equivalent training pursuant to NUREG 0737, II.B.4, nor had I
'
the training been specifically conducted as part of licensee requalification training. Additionally, the licensee had failed
'
to provide mitigating core damage training to all I&C technicians
*
*
Unit 1 in June 1985. Followup licensee actions have been identified by
as committed to in their letter dated February 9,1981. The licensee has stated that current training is now provided to these individual (d) In the area of operational feedback experience, it was noted that  '
; the licensee to assure continued reactor containment- building i
structural integrity. Structural integrity was maintained-at all times during the entire test and. repair program.
 
; Licensee planning and prioritizing methods for license amendment
; requests has continued in a satisfactory manner as during the previous
-
assessment period. Meetings were held at the Farley site in June,1985, and at the licensee's headquarters in January 1986, between the Operating Reactors Project Manager and the licensee's staff, for discussions of licensing priorities and schedules. These meetings were
, fruitful, resulting in a clearer understanding of the licensee's requests as well as Commission initiated licensing action The licensee provides quarterly updates in the form of a " Status of Licensing Items" which is a helpful too These updates show consistent evidence of the licensee's planning and assignment of
, licensing priorities.
 
,
,
! The licensee usually demonstrates a clear understanding and approach to
'
,
the distribution of pertinent information to the individual mechanics and I&C technicians was informal, uncontrolled, and not i
resolution of technical issues. The example, noted above, relating to the resolution of the containment tendon anchor failures shows how the
!-
..
- - - - - . ------.,, .---,,-- - --...-- _-----.-.- ----- - --_----
licensee solved a very complex technical problem in a timely manner.


l However, for another technical issue relating to the analyses provided 4 by the licensee to support changes to the heatup/cooldown curves for each unit, a weakness was eviden In the Unit 2 application for changes to the curves, the NRC staff noted that the licensee's submittals were not technically sound and did not exhibit conservatism when considering safety significance. A reanalysis was required for the Unit 2 submittal.
_
: The responses to NRC initiatives are generally timel During our review of licensee requests for 76 specific fire protection exemptions, i the licensee revised their submittals as requested for 21 exemption i
          -
'
requests to document additional fire protection commitments. Their proposals to resolve our concerns were viable, technically sound, and are being accepte In the licensing support activity, the licensee has increased the number of qualified senior reactor operators on the corporate nuclear support staff. These trained and qualified managers, associated with licensing support, provide a positive contribution in understanding
  .
  .
operations and in coordinating license amendment evaluations with the l NRC staff.
.,         .
:
February 25, 1987 I
:
          '
,
  ,_.~r-r .-m., ,_.--m- --r,,,---,,,-,,,.-.m,o.,, ,-_e,..-----.--.c2-e-
 
    . _ - _ . .- . . -- . -. . . -.
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;
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           .
I
III. Licensee Comments:
:  The licensee's staff for licensing actions is quite adequate.
Licensee comments to the SALP Board Report were provided in the letter from Alabama Power Company to Dr. J. Nelson Grace dated November 20, 1986, and are attache ,
1 M
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          ,
g 1


j  Operations qualified personnel are integrated into the corporate levels
        \
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    , , _ _ - _ _ , . - -- - - - - , - - e- ' --~ ~ ~ ~ ' " ' ' ' ' ~ ~ ~ ~ ~ ~ ' ' * * '
        '
          '


of licensee management. This is a positive factor which enhances the
- . . ,    , . - - -
;. licensee's ability at the corporate level to evaluate licensing matters which frequently involve operation One violation was identified, j
W { Y
i  * A violation of anti-trust licensing condition No. F.2 initiated an
*
  '
NN.bama Power Company 400 North 19th St eet Post Offee Som 261 I  / Barre;rgham. Alabama 352910400 Te'e:.wone 2o5 25o 183s
enforcement action to require complianc The violation was i   issued pursuant to 10 CFR 2.206 against both Units 1 and 2.
~    ~ }a'v'
      "* ' S A 9 ' 0 " -
  / - T.. P. Mcoone.'A AlabamaPower
  ,   Sensor Vice President    the southern eWrc sm


; Conclusion
86-426
!
Category 1 Board Recommendations
!  Non Training and Qualification Effectiveness
, Analysis During the assessment period, inspections were conducted by the resident and regional staff Inspections included three licensing examination site visits and a two week training assessment.


.
   ,
;   Farley's training center consists of lecture rooms, maintenance labs,
November 20, 1986
!  and a site specific simulato This versatile and professional j  facility provides an atmosphere conducive to the proper training of
'
'
licensed operators and plant staff. The site specific simulator has become a valuable tool in replacement and requalification licensed l
s Dr. J. Nelson Grace Regional' Administration U. S. Nu:. lear Regulatory Commission, Region II
operator training.. The instructors appear to be quite proficient and
  , 101 Marietta Street, N. ,
!   abreast of the latest plant modifications. Commensurate with the plant i
Atlants, GA 30322
modifications is a procedure which keeps the simulator updated to i   reflect current plant layout hardware and operating parameter Licensed operators felt that the simulator was an important aspect of
  '
'
  < subject: Report No. 50-348/86-14 50-364/86-14
l (   their training.
  '
        '
-
  :Cear Dr. Grace:
Tne comments herein concern the SALP Board Report provided by your letter of
]  October 16, 198 .
  ,  Commer.t 1 i  The subject repor.t contains.g,qnflicting conclusions concerning the quality of licensee conducted audits. In the area of health physics. In the last caragraph on page 7 of the subject report it states, " Audits performed by the corporate staff of the health physics, radwaste, environmental and l   cheNistry' programs were of sufficient scope and depth to identify problems
!
and adverse trends." Conversely, in the last paragraph on page 19, it is stated, " Audits and their responses were completed in a timely manner,
,
comprehensive checklists were utilized and all audit finfings were reviewed i   by, the Senior Vice President. However, the site internal audit organization l
Tacked sufficient expertise in the area of health physics to perform
,
meaningful evaluations." Since the " site internal audit organization" is,
!  in fact, an:on-site independent organization reporting only to off-site management, the so-called " corporate staff" and the " site internal audit
   ,  organization" are one and the same grou .. .~
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l l   The licensing examinations for replacement and upgrade operators were l  administered in January and August of 1985 and February and July of 198 In spite of the excellent training facilities noted above, examination results have yielded a failure rate which is above the industry averag January 1985 examination results yielded a 3 694 (5 of 14) failure for SR0s and 40?; (2 of 5) failure for R0s.
      -  . ._ - _ -- -. .__ _ _ .
 
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August 1985 results yielded a 67?s (4 of 6) failure for SR0s and a 40?s
  -Dr. J. Nelson Grate-Page 2 November 20, 1986      ,
  , - - . - - - ___ - -.-_- ,  - - , - - . - .   . - - _ . _ , . _ - _ .
          '
 
Ouring the period of the SALP, the site audit staff consisted of individual personnel with significant health physics training, experience, and   *
. .. 1
background. Below is a listing of the such personnel:
Name  Date Assigned Special Qualifications W. D. Oldfield July 1984-July 31,1986 Navy Nuclear Trained Officer /
Nuclear Engineering Degree W. H. Warren  September 1984-July 31,1986 SR0/ Masters Degree-Physics / Health  ,
Physics Training  ;
T. P. Davis  .0ctober 1984-July 31,1986 Navy Nuclear  !
Trained Officer  '
,  R. R. Martin  April 1985-July 31,1986 SRO J. K. Osterholtz  January 1986-July 31,1986 SRO/ Nuclear Engineering Degree V. L. Murphy  February 1986-July 31,1986 SRO M. D. Pilcher  May 1986-July 31,1986  SRO Trained-
          '
;  J. E. Fridrichsen  June 1986-July 31,1986 SR0/ Nuclear Engineering Degree
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.
          '
Of the eight personnel identified above, two members of the staff were
'
nuclear trained officers in the U. S. Navy, and received training and experience in health physics as part of the Navy nuclear program. Three have nuclear engineering degrees which included several hours of formal  -
training in the health physics area. Five have Senior Reactor Operator licenses which includes formal training on health physics as part of the SR0 training program and refresher training during the requalification progra Another has completed SR0 training. One of %3se listed has a masters degree in Physics and has had formal trafMng in the arga of health physics. In addition, this person hn re ke? as a'Radlo-Chemistry.


(4 of 10) failure for R0 February 1986 results yielded no failures for two SR0s and two R0s. July 1986 results yielded an overall failure rate of 40% (4 of.10) for SR0s and no failure for one R0. Areas of generic weakness noted during the candidate's operating examinations were as follows:
,
*
laboratory technician at Farle .
Difficulties in-classifying emergency plan levels Inadequate use of procedures during simulator exams Inability to diagnose minor malfunctions and abnormal situations on simulator exams
i l  The conclusion on page 19 stating, "However, the site internal audit l  organization lacked sufficient expertise in the area of health physics- to j  perform meaningful evaluations." is erroneous in that that group is not i  internal to thP site management. Furthermore, the conclusion is inadequately supported as indicated above. It is recomended that this sentence in the SALP Report be delete .
*
    '
Inconsistent use of abnormal operating procedures During inspection (85-15) conducted in March 1985, nine apparent violations were identified; however, as a result of the current NRC policy statement and agreement with INPO on training and qualification of nuclear power plant personnel, these apparent violations are being carried as unresolved items. The following summary describes the corrective actions taken by the licensee with regard to these unresolved items. (It should be noted that the NRC has not reinspected these items but is taking steps to determine whether appropriate correctiv.e actions have been taken.)
Comment 2  -
On page 24 of the report, it is stated that "During Inspection (85-15)
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(a) In December 1984, the Accreditation Board of the Institute of Nuclear Power Operations (INPO) awarded Farley accreditation for several training programs including Operator License, License Upgrade, an'd Shif t Supervisor Trainin One of the unresolved items. pertains to Farley's failure to implement the INPO accredited SRO Upgrade Training program. The licensee has stated this training is now specifically addressed in procedures and is implemented in their progra (b) The licensee conducts the annual procedure review simultaneously with control manipulations. This practice has not ensured that all procedures are reviewed, or that a procedure is utilized in its entirety as required by 10 CFR 55, Appendix A, 3.d. The licensee stated current training specifically addresses this matte (c) Since completion of the initial training in mitigating core damage in May of 1981, replacement licensed operators have not received the equivalent training pursuant to NUREG 0737, II.B.4, nor had the training been specifically conducted as part of licensee requalification training. Additionally, the licensee had failed to provide nitigating core damage training to all I&C technicians as committed to in their letter dated February 9, 198 The licensee has stated that current training is now provided to these individual (d) In the area of operational feedback experience, it was noted that the distribution of pertinent information to the individual mechanics and I&C technicians was informal, uncontrolled, and not
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Dr. J. Nelson Grace Page 3 November 20, 1986 conducted in March 1985, nine apparent violations were identified. However,   ,
documented. Operational experience was not incorporated into the training and retraining programs for mechanics or I&C technician The licensee has stated that more operational feedback experience is being incorporated in their training and is being documente (e) Operational feedback experience provided in operator requali-fication training was in the form of reading the event reports verbatim to the students which leaves the interpretation of the event and its applicability to Farley Nuclear Station to the studen The importance of this lack of operational feedback experience training is best exemplified when reviewed in conjunction with the number of wrong unit / wrong train and tagging event errors occurring at Farley as documented in their internal incident report It should be noted that while a majority of these incidents are minor in nature, several have caused entry into limiting conditions of operatio (f) In addition certain other unresolved items not described in detail are listed herein for completeness:  1) require vendor licensed operator instructors teaching SRO/R0 requalification to have a NRC SRO certification or license, attend requalification lectures, and take the annual requalification examination; 2) establish training program for quality control inspectors; 3) provide management training to STA candidates; 4) provide General Employee Training to members of plant management. The licensee has stated these items have been adaressed and correcte No violations or deviations were issue . Conclusion Category 2 Board Recommendation No changes to the NRC's inspe, tion resources are recommende V. Support Data and Summaries Licensee Activities During the assessment period, the licensee conducted major activities during the one refueling outage for Unit 1 and two refueling outages for Unit 2. The anti vibration bars for steam generators 1B, 2A and 2B were replaced. The licensee detected, evaluated and repaired as required the containment building tendons; replaced the high pressure turbine rotor, blade and nozzle blocks; and replaced all feedwater
as a result of the current NRC policy statement and agreement with INP0 on training and qualification of nuclear power plant personnel, these apparent violations are being carried as unresolved items."
  . - - - - - _ - - _-_- - - _. - , _ _  . l
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1 l
heaters for both unit In Unit 2, the licensee conducted eddy current testing of steam generators; installed the reactor vessel level monitoring system; and conducted containment local and integrated leak rate testin INP0 conducted an operations evaluation during June 1986 and an accreditation visit during July 198 B. Inspection Activities During the assessment period, routine inspections were performed at the J. M. Farley facility by the resident and regional inspection staff A special team inspection was conducted by the fire protection /
prevention program as described in Section IV.E, above. A small scale emergency preparedness exercise was conducted (Section IV.B.). Three licensing examination site visits, a two week training assessment, and a supplementary reactive inspection following the RHR inoperability were conducted as described in Section I C. Licensing Activities UNIT 1/ UNIT 2 TITLE OF AMENDMENT  DATE
--/48  Heatup Cooldown Curves  01/22/85 Capsule U Schedule Only 57/49  Reporting Requirements (GL 83-43) 02/19/85 58/--  Heatup/Cooldown Curves to 7EFPY 05/02/85 59/E0  Update Surveillance for DC Batteries 05/25/85 60/51  Organizational Changes  01/27/86 61/52  QPTR Changes to Allow Full Core Map 03/14/86 62/53  Turbine Trip Before Latching 04/15/86 63/54  Deletion of Shutdown for Cumulative 04/16/86 Iodine
__/55  Heatup/Cooldown Curves for 8EFPY 04/21/86
__/56  Deletion of Fuel Rod Height  04/22/86 64/57  Deletion of Rod Bow Penalty  06/16/86
    -. _ ..


EXEMPTIONS GRANTED Appendix R, 33 Technical Exemptions from Section II /19/85 (Unit 2 and shared Unit 1 areas)
Despite Alabama hwer Company's efforts to resolve these " apparent" violations with the NRC for a period of 16 months, .they were included in the SALP report. Alabama mwer Company does not believe that any of the
ORDERS ISSUED Confirmatory Order - Additional Commitment on Scheduling 07/25/85 Final Emergency Response Capability RELIEFS GRANTED ISI Relief from ASME Code for Reactor Vessel Ligaments, 12/27/85 and for Reactor Coolant Pump Interior and Flange Areas ISI Relief from ASME Code for Certain Valve Body Welds 06/19/86 and Internal Pressure Boundary Surfaces D. Investigation and Allegations Review There is currently one significant investigation in progress. This investigation is being conducted by the Office of Investigation E. Enforcement History During this SALP period, 57 inspec tions resulted in one antitrust, 12 Unit 1 and 11 Unit 2 Severity Level IV violations, and 14 Unit 1 and 12 Unit 2 Severity Level V violations. One Severity Level III violation was identified. The Sevgrity Level III violation is related to one train of the RHR system on Unit 1 being unable of transferring pump suction to the containment sump during recirculation phas Control board operators failed to assure operability during 12 shifts of turnover operations. During an enforcement conference at Region II on June 3, 1986, the licensee reviewed the details of the even Because of self identification and prompt and extensive corrective action the Severity Level III violation was issued without a civil penalt F. Management Conferences Held During Appraisal Period Farley 2 Containment Tendon Field Anchor Failures Resulting in IN 85-10 - 2/7/85 and 3/1/85 Project Manager Meeting at Licensee Offices to Review 1986 Licensing Schedules - 1/15-16/86 Project Manager Site Visits:
  " apparent" violations were actual violations and, in any case, Alabama power Company believes that upgrading or clarifying actions have been completed in all case It is recommended that all references to the " apparent" violations and unresolved items resulting' from the March 1985 inspection (85-15) be deleted from the SALP repor
Commissioner Asselstine's site visit 1/23-25/85 SALP Review Meeting with Licensee  4/10-12/85 Quarterly PM Visit and Tendon Review 6/22-27/85 Appendix R Fire Protection Audit  8/21-26/85 Regulatory Effectiveness Review Audit 2/5-7/86
_ . .
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Sincerely yours t
        /
R. P. Mcdonald Senior Vice President
          '
R PM/JWM:rb D- .
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28 Enforcement Conference at Region II relating to the RHR valve being inoperable - 6/3/86 G. Operational Events During this 19 month period, the licensee reported 42 non-security events to the NRC Operations Center to comply with 10 CFR 50.72 requirement Ten events involved losses of Emergency Response Capabilities such as failures of communications or meteorological equipment. One involved damage to a fuel assembly during installation and one involved failures of the containment vertical tendon field anchor Review of the 10 CFR 50.72 reports for these events indicates appropriate hardware and operator response subsequent to scrams, prompt and clear reporting by the licensee, and appropriate repairs prior to returning to power. None of the events involved a radiation releas Eleven events involved human error, three by operators and eight by technicians. With the exception of the vertical tendon failures (See Section IV.J), none of the events were considered to be significant, especially in terms of being generic, recurring, or precursory in natur During the SALP period, Farley 1 exhibited nigh availability. In 1985 the reported reactor availability was 84.3?; and for the first 6 months of 1986 the availability was 98.8*4. The 1985 figure includes a 51-day refueling outage. During the same period, Farley 2 exhibited slightly above-average availability. In 1985, the reported reactor availability for Unit 2 was 77.8%. For the first 6 months of 1986 the availability was 72.2?s, yielding an overall average for both units during the reporting period of about 82.5?;, or 14?; above the 1985 national average for availability, 68.5? H. Review of Licensee Event Reports and 10 CFR 21 Reports submitted by the Licensee During the assessment period, there were 27 LERs reported for Unit 1 and 22 LERs reported for Unit 2. The distribution of the first 44 events analyzed by cause, as determined by the NRC staff, was as follows:
      -. .
 
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    - - -
Cause  Unit 1 Unit 2 Component Failure  4  8 Design  4  1 Construction, Fabrication, or 4  1 Installation Personnel
we +y---y w- w e-w:--w---, -, ,,wv,,. e, ,--y=-w,,-w- n---..,,-,--., , .,,, --ww.,,,-,,-.v,w--= - -
- Operating Activity  6  4
- Maintenance Activity  2  2
- Test / Calibration Activity 2  2
- Other  2  -
Out of Calibration  - -
Other  1  1 TOTAL  25  19 I. Inspection Activity and Enforcement-
  .
FUNCTIONAL  NO. OF VIOLATIONS IN EACH SEVERITY LEVEL AREA  V IV III II I Unit N /2 1/2 1/2 1/2 1/2 Plant Operations  2/2 1/3 1/0 Radiological Controls 0/0 2/2 Maintenance  4/2 2/0 Surveillance  3/2 0/1 Fire Protection  0/0 0/0 Emergency Preparedness 0/0 1/1 Security  1/1 2/2 Outages  1/2 3/0 Quality Program and 3/3 1/2 Administrative Controls Affecting Quality Licensing  *
Training TOTAL  14/12 12/11 1/0
*0ne violation with no s eve r i t.- level issued against licensee activities of anti-trust licensing condition No. J. Reactor Trips Unit 1 3/13/85 Reactor trip due to low-low water levels in steam generators (SGs) 18 and IC. This was caused by closure of the turbine governor and intercept valves due to spurious actuation of a limit switch on a main steam isolation valve (MSIV). The
 
. ..
 
limit switch on the MSIV was replace Additionally, operations personnel now verify the proper MSIV limit switch positions prior to each unit start-u /08/85 Reactor trip occurv ed due to underfrequency on the reactor coolant pump (RCD) electrical buse The underfrequency condition occurred because the RCP bus power sources had not been realigned prior to tripping the main turbine. The event was caused by personnel error and procedural inadequac Subsequently, corrective actions were taken which included personnel counseling and revisions to appropriate plant procedure /23/85 Reactor trip occurred due to an electrical short between two control rod drive system cables which were routed through the same containment electrical penetratio The cables have been repaired and reroute Additionally, all CRDM
; penetration modules are undergoing replacement with an improved module manufactured by Conex (Unit 1, 7th refueling outage (R.O.) and Unit 2, done in 4th R.0).
 
07/17/85 Reactor trip occurred due to low-low SG level following a trip of the 18 steam generator feed pump (SGFP). The SGFP tripped when a technician accidentally bumped a cable and broke a connection on a wire leading to the SGFP thrust bearing wire protective unit. The broken wire caused the protection unit to indicate excessive thrust bearing wea Discussions are underway to either reroute or provide conduit for the above cabl /28/86 A reactor trip occurred as a result of dropped control ro A short existed in the containment electrical penetration for the control rod stationary and movable grippers and caused the control rod to dro The cable was rerouted to spare terminals in the penetration. All CRDM penetration modules are undergoing replacement with an improved module manu-factured by Cona /18/86 A main turbine trip occurred due to ruptured diaphragm of an automatic stop oil / hydraulic system interface valv The ruptured diaphragm caused the turbine auto stop pressure to decrease to the trip setpoint resulting in a turbine tri Replacement of the diaphragm is to be included as a preventative maintenance item for subsequent refueling outage /02/86 Unit 1 tripped from 99*; reactor power on a negative rate tri The trip was caused by a short in control rod F14 stationary gripper coil circuit in the containment pene-tration, resulting in blown fuses and control rod F14
_ ._, _ _ _ _ _ _
 
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dropping into the core. All systems functioned as designe The cabling for control rod F14 stationary gripper coil circuit was - rerouted through spare conductors in the same penetratio Unit 2 03/28/85 Reactor trip due to 2A SG low-low level caused by the loss of B main feed pump control. This was due to a printed circuit card being removed incorrectly from the 28 SGFP control cabine The event was caused by personnel erro Appropriate personnel were counseled in the importance of exercising caution while performing maintenance on operating equipmen /30/85 Reactor trip due to low-low level in 2A SG following the loss of SGFP 2 During instrument calibration, an isolation valve leaked causing the SGFP to trip due to an incorrectly indicated low vacuum condition. The isolation valves was replace /15/85 Reactor trip occurred due to the loss of power in two rod control system power cabinets. This was caused by lightnin To eliminate the potential for future failures of this nature, surge arrestors were installed on the auxiliary power supplies to each CRDM power cabinet during Unit 2 4th Arrestors will be installed durir.g Unit 1 7th /17/85 Reactor trip occurred due to low-low level in the 2C SG following a SGFP and main turbine trip caused by high level in the 2A SG. The high SG level occurred due to a main feedwater regulating valve which apparently failed to respond in manual control. Trouble-shooting of the control circuit did not identify a problem. Operations personnel were counseled in the importance of monitoring / maintaining SG levels in manua /02/85 Reactor trip occurred due to over-temperature-delta temperature (OTDT). This event was caused by the failure of the IB inverter while one channel of OTDT had been placed in test for maintenance with the bistable in the tripped condition. A faulty ferroresonant transformer in inverter 2B was replace The inverter was returned to servic /17/86 A turbine trip was initiated manually following the loss of both steam generator feedwater pumps (SGFP). This resulted in a reactor trip. A short in the SGFP circuit control panel resulted in the loss of the redundant power supplies which serve both SGFP _ _ _ - _ _ _ _ _ _ _  _ .- _-- _ _ --
_ _ . __ , - _ _ _ _ .
 
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05/13/86 During start-up from the Unit 2 Cycle IV refueling outage, while performing test with the turbine generator at 1800 RPM, feed flow from the steam generator feed pump went low due to electro hydraulic (EH) fluid low pressure. This caused a low-low level in the steam generators, resulting in a reactor tri Apparently the low EH pressure was due to a faulty turbine valve actuator. These actuators are to be replaced at each refueling outage as preventive maintenanc /08/86 A reactor trip occurred when both motor generator (MG) sets malfunctioned. This allowed all control rods to fall in the core resulting in a high negative flux rate causing the reactor trip breakers to ope .>
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Revision as of 19:29, 11 January 2021

Errata to SALP Repts 50-348/86-14 & 50-364/86-14
ML20207T494
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 02/25/1987
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20207T462 List:
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.4, TASK-TM 50-348-86-14, 50-364-86-14, NUDOCS 8703240071
Download: ML20207T494 (9)
v • d • e


Text

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February 25, 1987 ENCLOSURE APPENDIX TO ALABAMA POWER COMPANY FARLEY FACILITY SALP BOARD REPORT NOS. 50-348/86-14; 50-364/86-14 (DATED OCTOBER 16,1986)

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l l-l l-8703240071 870225 PDR 0 ADOCK 05000348 PDR L-

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February 25, 1987 Meeting Summary A meeting was held on October 21, 1986, at the Farley site to discuss the SALP Board Report for the Farley facilit Licensee Attendees W. O. Whitt, Executive Vice President R. P. Mcdonald, Senior Vice President

,

l W. G. Hairston, General Manager - Nuclear Support  !

J. D. Woodard, General Manager - Nuclear Plant i D. N. Morey, Assistant General Plant Manager G. W. Shipman, Assistant General Plant Manager J. W. McGowan, Manager, Safety Audit Engineering Review (SAER)

R. D. Hill, Operations Manager L. A. Ward, Maintenance Manager L. M. Stinson, Plant Modifications Manager L. Enfinger, Administrative Manager

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R. B. Wiggins, Supervisor of Operator Training J. K. Osterholtz, Supervisor - SAER NRC Attendees M. L. Ernst, Deputy Regional Administrator, Region II L. A. Reyes, Deputy Director, Division.of Reactor Projects (DRP)

H. C. Dance, Chief, Reactor Projects Section 18, DRP E. A. Reeves, Farley Project Manager, Office of Nuclear Reactor Regulation W. H. Bradford, Senior Resident Inspector, Farley B. R. Bonser, Resident Inspector, Farley I Errata Sheet - Farley SALP h Line Now Reads Should Read 9 Last Line No change in NRC's reduced No change in the inspection resources are NRC's inspection recommende resources are t

recommende Basis for Change: The statement implies that the inspection program had been previously reduced. However, the Radiological area inspection program had not been reduce Although violation (a)... Although violation (e)

Basis for Change: To correct typographical erro ...nine apparent violations ...eight apparent violations...

Basis for Change: To correct administrative error.

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.____ __ . _ _ . - _ . _ . _ . . . . . _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _

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Both liquid and gaseous effluents were within regulatory limits or e

' quantities of radioactive material released and for dose to the maximally exposed individual. For 1985 releases, .the a imum

' calculated total body dose to a member of the public was 0.03 ren from liquid releases and 0.13 mrem from gaseous effluents. Thes calculated doses represented 0.12 percent and 0.52 percent of the 40 R 190 Itait of 25 mrea/ year. There were two unplanned gaseous role ses and one unplanned liquid release during the evaluation perio . The Itquid release was ' the result of leakage from the Componen Cooling Water-System into.the Service Water System. The gaseous r eases were caused by inadvertent venting of the Hydrogen Recombine System into the

Auxiliary Building. The design that vented the R Sump Vent into the Component Cooling Water Heat Exchanger Room wa corrected. The total activity for unplanned releases was 0.006 cur es for ifquid and 1 curies for gas. Unit 2 had no unplanned releases during this assessment perio In the area of plant chemistry the steam enerators had,:fn prior years of operation, accumulated significant amounts of iron-copper oxide

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sludge as well as potentially corr tve species (e.g, chloride, sulfate) that were present as " hide t return." Consequently, several days were required during startup ter each lengthy outage to achieve the desired level of chemistry ontrol. During the last two fuel cycles of each unit the licens had achieved stable plant operation and a high level of chemistry ontrol while making progress in removing both sludge and reducing t e effects of hideout from the steam generators. In an effort t eliminate the detrimental effect of copper as a corroding element, he licensee had replaced all copper heat exchanger tubes in th condensate /feedwater train. In addition, inleakage of air conde er cooling water through the condenser had been effectively eliminate . All elements of the chemistry program had been-upgraded to impleme the recommendations of the Steam Generator Owners

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_ Group.

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Two violationyv ere identified for failure to assure that radioactive material shi d for burial was without free standing liquid.

, Sever y Level IV violation for failure to assure that radioactive

! mate al shipments for burial were without free standing liquids ( , 364/85-34).

b. , everity Level IV violation for failure to have adequate

+ procedures to preclude shipping radioactive material for burial i

4 with free stanuing liquids (348, 364/85-34).

L 4 Conclusion - .

Category 1 Board Recommendations:

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No change in the NRC's reduced inspection resources are recommended.

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Both liquid and gaseous effluents-were within regulatory limits for quantities of radioactive material released and for dose to the maximally exposed individual. For 1985 releases, the maximum calculated total body dose to a member of the public was 0.03 mrem from liquid releases and 0.13 mrem from gaseous' effluents. These calculated-doses-represented 0.12 percent and 0.52 percent of the 40 CFR 190 limit of 25 ares / yea There were two unplanned gaseous releases and one unplanned liquid release during the evaluation period. The liquid release was the result of leakage from the Component Cooling Water System into the Service Water Syste The gaseous releases were caused by inadvertent venting of the Hydrogen Recombiner System into the Auxiliary Building. The design that vented the RHR Sump Vent into the Component Cooling Water Heat Exchanger Room was corrected. The total activity for unplanned releases was 0.006 curies for liquid and 1 curies for ga Unit 2 had no unplanned releases during this assessment perio In the area of plant chemistry the steem generators had, in prior years of operation, accumulated significant amounts of iron-copper oxide sludge as well as potentially corrosive species (e.g, chloride, sulfate) that were present as " hideout. return." Consequently, several days were required during startup after each lengthy outage to achieve the desired level of chemistry contro During the last two fuel cycles of each unit the licensee had achieved stable plant operation and a high level of chemistry control while making progress in removing both sludge and reducing the. effects of hideout from the steam generators. In an effort to eliminate the detrimental effect of copper as a corroding element, the licensee had replaced all copper heat exchanger tubes in the condensate /feedwater train. In addition, inleakage of air condenser cooling water through the condenser had been effectively eliminated. All elements of the chemistry program had been upgraded to implement the recommendations of the Steam Generator Owners Grou Two' violations were-identified for failure to assure that radioactive material shipped for burial was without free standing liqui Severity Level IV violation for failure to assure that radioactive material shipments for burial were without free standing liquids (348,364/85-34). Severity Level IV violation for failure to have adequate procedures to preclude shipping radioactive material for burial with free standing liquids (348, 364/85-34). Conclusion Category 1 Board Recommendations:

No change in the NRC's inspection resources are recommende _ . . _ . . , _ _ _ _ __ _ . . .

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_ . Severity' Level' V violation for failure to have one chargin pump in the boron injection flow path _ operable as required by T chnical Specificati.on during Unit I refueling-operations (348/85- 0).

' Severity Level V violation for performing reactor re video inspection without a procedure to govern the activit (364/85-04). Severity Level V violation for failure to fully implement fuel handling procedure sequence' in releasing the t fastener during new fuel receipt and inspection (364/85-43). Conclusion Category 1 Board Recommendations

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No changes in the NRC's reduced inspecti n resources are recommended.

. Quality Programs and Administration ntrols Affecting Quality Analysis

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During the assessment perio' d , inspections were conducted by the resident and regional inspec on staffs. The following areas were

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reviewed by the regional taff: licensee actions on previous

[ enforcement matters, qu ity assurance / quality control (QA/QC)

'

administration, audits, ocument control, and licensee actions on previously identified i pection findings.

3 Interviews with lice ee personnel indicated that the QA program was e adequately stated d understoo Frequent site communication was

<

' evident and indi ted .that corporate QA management was actively involved in ons activitie s Key staff p tions had been identified and authorities and respon-sibilities r these positions were procedurally delineated. Staffing was adequa e. During this assessment period, two senior reactor

'

operatort were assigned to the audit staff. Their addition provided

, depth additional expertise to operational auditing activitie r y Aud * performed by onsite QA personnel are basically compliance au4 s. Audits were written by the licensee in a professional and a pt manner. Although violation (a) was identified in this area, the

.

4 olation was administrative in nature. Audits and their responses

& ere completed i n- a timely manner, compreTiensive checklists were 4 utili
ed, and all audit findings were reviewed by the Senior Vice

'

President. However, the site internal audit organization lacked

sufficient expertise in the area of health physics to perform meaningful evaluations.
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19 Severity Le' vel V violation for failure to have one charging pump in the boron injection flow path operable as required by Technical Specification during Unit I refueling operations (348/85-20). Severity Level V violation for performing. reactor core video inspection without a procedure to govern the activity (364/85-04). Severity Level V violation for failure to fully implement fuel handling procedure sequence in releasing the top fastener during new fuel receipt and inspection'(364/85-43). Conclusion Category 1- Board Recommendations

~

No changes in the NRC's reduced inspection resources are recommende Quality Programs and Administration Controls Affecting Quality Analysis During .the assessment period, inspections were conducted by the resident and regional inspection staffs. The following areas were

. reviewed by the regional staff: licensee actions on previous enforcement matters, quality assurance / quality control (QA/QC)

administration, audits, document control, and licensee actions on previously identified inspection finding Interviews with licensee personnel indicated that the QA program was adequately stated and understood. Frequent site communication was evident and indicated that corporate QA management v3s actively involved in onsite activitie Key staff positions had been identified and authorities and respon-sibilities for these positions were procedurally delineated. Staffing was adequate. During this assessment period, two senior reactor operators were assigned to the audit staff. Their addition provided depth and additional expertise to operational auditing activitie Audits performed by onsite QA personnel are basically compliance audits. Audits were written by the licensee in a professional and adept manne Although violation (e) was identified in this area, the violation was administrative in nature. Audits and their responses were completed in a timely manner, comprehensive checklists were utilized, and all audit findings were reviewed by the Senior Vice Presiden However, the site internal audit organization lacked sufficient expertise in the area of health physics to perform meaningful evaluation ,

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(4 of 10) failure for R0s. February 1986 results yielded no failur s for two SR0s and two R0s. July 1986 results yielded an overall fa ure rate of 40% (4 of 10) for SR0s and no failure for one R0. Are of generic weakness noted during the candidate's operating exami tions were as follows:

Difficulties in classifying emergency plan levels

Inadequate use of procedures during simulator exams Inability to diagnose minor malfunctions and abnor al situations

on simulator exams Incensistent use of abnormal operating procedure During inspection (85-15) conducted in March 19 5, nine apparent violations were identified; however, as a resul of the current NRC policy statement and agreement with INPO on tra ing and qualification of nuclear power plant personnel, these appa nt violations are being

,

carried as unresolved items. The followin summary describes the corrective actions taken by the licens with regard to these unresolved items. (It should be noted th the NRC has not reinspected these items but is taking steps to d termine whether appropriate corrective actions have been taken.)

(a) In December 1984, the Accredi ation Board of the Institute of Nuclear power Operations (IN ) awarded Farley accreditation for several training programs neluding Operator License, License Upgrade, and Shift Superv sor Training. One of the unresolved items pertains to Farl 's failure to implement the INPO accredited SRO Upgrade raining program. The licensee has stated this training is now ecifically addressed in procedures and is implemented in their rogra .

(b) The licensee cond cts the annual procedure review simultaneously with control ma pulations. This practice has not ensured that all procedures are reviewed, or that a procedure is utilized in its entirety, s required by 10 CFR 55, Appendix A, 3.d. The licensee st ted current training specifically addresses this matter. 4

+

(c) Since c mpletion of the initial training in mitigating core damage in Ma of 1981, replacement licensed operators have not received thg, quivalent training pursuant to NUREG 0737, II.B.4, nor had

,

t training been specifically conducted as part of licensee ualification training. Additionally, the licensee had failed

+ o provide mitigating core damage training b all I&C technicians

  • as committed to in their letter dated February 9, 198 The Itcensee has stated that current trainifig is now provided to these

[ individual (d) In the area of operational feedback experience, it was noted that the distribution of pertinent information to the individual mechanics and I&C technicians was informal, uncontrolled, and not

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_ _ _ . _ _ _ - - --- - - - - - - - - - - - - - - - - - - - - -

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& -

.,

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(4 of 10) failure for R0s. February 1986 results yielded no failures for two SR0s and two R0 July 1986 results yielded an overall failure rate of 40% (4 of 10) for SR0s and no failure for one RO. Areas of generic weakness noted during the candidate's operating examinations-

-were as follows:

Difficulties in classifying emergency plan. levels

Inadequate use of procedures during simulator exams

Inability to diagnose minor malfunctions and abnormal situations

on simulator exams Inconsistent use of abnormal operating procedures

' ,

' During inspection -(85-15) conducted in March 1985, eight apparent violations were~ identified; however, as a result of the current NRC -

policy statement and _ agreement with INPO on training and qualification of nuclear power plant personnel, these apparent violations are being carried as unresolved items. The following summary describes the

' corrective actions taken by the licensee with regard to these unresolved item (It should be noted that the NRC has not reinspected these items but is taking steps to determine whether ' appropriate corrective actions have been taken.)

(a) In December 1984, the Accreditation Board of the Institute of Nuclear Power Operations (INPO) awarded Farley accreditation for

' several training programs including Operator License, License Upgrade, and - Shift Supervisor Trainin One of the unresolved items pertains to Farley's failure to implement the INPO accredited SRO Upgrade Training progra The licensee has stated this training is now specifically addressed in procedures and is implemented in their progra (b) _ The licensee conducts the annual procedure review simultaneously with control manipulation This practice has not ensured that all procedures are reviewed, or that a procedure is utilized in l its entirety as required by 10 CFR 55, Appendix A, 3.d. The licensee stated current training specifically addresses this matte (c) Since completion of the initial training in mitigating core damage in May of 1981, replacement licensed operators have not received i

the equivalent training pursuant to NUREG 0737, II.B.4, nor had I

the training been specifically conducted as part of licensee requalification training. Additionally, the licensee had failed

'

to provide mitigating core damage training to all I&C technicians

as committed to in their letter dated February 9,1981. The licensee has stated that current training is now provided to these individual (d) In the area of operational feedback experience, it was noted that '

,

'

the distribution of pertinent information to the individual mechanics and I&C technicians was informal, uncontrolled, and not i

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February 25, 1987 I

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III. Licensee Comments:

Licensee comments to the SALP Board Report were provided in the letter from Alabama Power Company to Dr. J. Nelson Grace dated November 20, 1986, and are attache ,

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W { Y

NN.bama Power Company 400 North 19th St eet Post Offee Som 261 I / Barre;rgham. Alabama 352910400 Te'e:.wone 2o5 25o 183s

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"* ' S A 9 ' 0 " -

/ - T.. P. Mcoone.'A AlabamaPower

, Sensor Vice President the southern eWrc sm

86-426

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November 20, 1986

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s Dr. J. Nelson Grace Regional' Administration U. S. Nu:. lear Regulatory Commission, Region II

, 101 Marietta Street, N. ,

Atlants, GA 30322

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< subject: Report No. 50-348/86-14 50-364/86-14

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Cear Dr. Grace:

Tne comments herein concern the SALP Board Report provided by your letter of

] October 16, 198 .

, Commer.t 1 i The subject repor.t contains.g,qnflicting conclusions concerning the quality of licensee conducted audits. In the area of health physics. In the last caragraph on page 7 of the subject report it states, " Audits performed by the corporate staff of the health physics, radwaste, environmental and l cheNistry' programs were of sufficient scope and depth to identify problems

!

and adverse trends." Conversely, in the last paragraph on page 19, it is stated, " Audits and their responses were completed in a timely manner,

,

comprehensive checklists were utilized and all audit finfings were reviewed i by, the Senior Vice President. However, the site internal audit organization l

Tacked sufficient expertise in the area of health physics to perform

,

meaningful evaluations." Since the " site internal audit organization" is,

! in fact, an:on-site independent organization reporting only to off-site management, the so-called " corporate staff" and the " site internal audit

, organization" are one and the same grou .. .~

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D.'

-Dr. J. Nelson Grate-Page 2 November 20, 1986 ,

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Ouring the period of the SALP, the site audit staff consisted of individual personnel with significant health physics training, experience, and *

background. Below is a listing of the such personnel:

Name Date Assigned Special Qualifications W. D. Oldfield July 1984-July 31,1986 Navy Nuclear Trained Officer /

Nuclear Engineering Degree W. H. Warren September 1984-July 31,1986 SR0/ Masters Degree-Physics / Health ,

Physics Training  ;

T. P. Davis .0ctober 1984-July 31,1986 Navy Nuclear  !

Trained Officer '

, R. R. Martin April 1985-July 31,1986 SRO J. K. Osterholtz January 1986-July 31,1986 SRO/ Nuclear Engineering Degree V. L. Murphy February 1986-July 31,1986 SRO M. D. Pilcher May 1986-July 31,1986 SRO Trained-

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J. E. Fridrichsen June 1986-July 31,1986 SR0/ Nuclear Engineering Degree

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Of the eight personnel identified above, two members of the staff were

'

nuclear trained officers in the U. S. Navy, and received training and experience in health physics as part of the Navy nuclear program. Three have nuclear engineering degrees which included several hours of formal -

training in the health physics area. Five have Senior Reactor Operator licenses which includes formal training on health physics as part of the SR0 training program and refresher training during the requalification progra Another has completed SR0 training. One of %3se listed has a masters degree in Physics and has had formal trafMng in the arga of health physics. In addition, this person hn re ke? as a'Radlo-Chemistry.

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laboratory technician at Farle .

i l The conclusion on page 19 stating, "However, the site internal audit l organization lacked sufficient expertise in the area of health physics- to j perform meaningful evaluations." is erroneous in that that group is not i internal to thP site management. Furthermore, the conclusion is inadequately supported as indicated above. It is recomended that this sentence in the SALP Report be delete .

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Comment 2 -

On page 24 of the report, it is stated that "During Inspection (85-15)

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Dr. J. Nelson Grace Page 3 November 20, 1986 conducted in March 1985, nine apparent violations were identified. However, ,

as a result of the current NRC policy statement and agreement with INP0 on training and qualification of nuclear power plant personnel, these apparent violations are being carried as unresolved items."

Despite Alabama hwer Company's efforts to resolve these " apparent" violations with the NRC for a period of 16 months, .they were included in the SALP report. Alabama mwer Company does not believe that any of the

" apparent" violations were actual violations and, in any case, Alabama power Company believes that upgrading or clarifying actions have been completed in all case It is recommended that all references to the " apparent" violations and unresolved items resulting' from the March 1985 inspection (85-15) be deleted from the SALP repor

Sincerely yours t

/

R. P. Mcdonald Senior Vice President

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R PM/JWM:rb D- .

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