IR 05000348/1986014

Errata to SALP Repts 50-348/86-14 & 50-364/86-14

ML20207T494
Person / Time
Site:	Farley
Issue date:	02/25/1987
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20207T462	List: ML20207T461 ML20207T494
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)

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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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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

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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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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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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).

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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)

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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

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' 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

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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

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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

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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

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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

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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

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(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

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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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(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

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' 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

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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 '

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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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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

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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

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

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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

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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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-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

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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

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R. P. Mcdonald Senior Vice President

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