ML20207T494

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)

See also: IR 05000348/1986014

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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February 25, 1987

I. Meeting Summary

A. A meeting was held on October 21, 1986, at the Farley site to discuss

the SALP Board Report for the Farley facility.

B. Licensee Attendees

W. O. Whitt, Executive Vice President

R. P. Mcdonald, Senior Vice President

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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

C. 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

II. 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

recommended. resources are

t

recommended.

Basis for Change: The statement implies that the inspection program had

been previously reduced. However, the Radiological area

inspection program had not been reduced.

19 32 Although violation (a)... Although violation (e)

Basis for Change: To correct typographical error.

24 11 ...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

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' 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

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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 11.5

curies for gas. Unit 2 had no unplanned releases during this

assessment period.

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.

, a. 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

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

L 4 2. Conclusion - .

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Category 1

3. 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 / year. 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 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

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 gas. Unit 2 had no unplanned releases during this

assessment period.

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 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

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

Group.

Two' violations were-identified for failure to assure that radioactive

material shipped for burial was without free standing liquid.

a. Severity Level IV violation for failure to assure that radioactive

material shipments for burial were without free standing liquids

(348,364/85-34).

b. 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).

2. Conclusion

Category 1

3. Board Recommendations:

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

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d. . 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).

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e. Severity Level V violation for performing reactor re video

inspection without a procedure to govern the activit (364/85-04).

f. 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).

2. Conclusion

Category 1

3. Board Recommendations

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

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I. Quality Programs and Administration ntrols Affecting Quality

1. 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 understood. Frequent site communication was

<

' evident and indi ted .that corporate QA management was actively

involved in ons activities.

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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 activities.

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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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d. 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).

e. Severity Level V violation for performing. reactor core video

inspection without a procedure to govern the activity (364/85-04).

f. 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).

2. Conclusion

Category 1-

3. Board Recommendations

~

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

I. Quality Programs and Administration Controls Affecting Quality

1. 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 findings.

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 activities.

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 activities.

Audits performed by onsite QA personnel are basically compliance

audits. Audits were written by the licensee in a professional and

adept manner. 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

President. However, the site internal audit organization lacked

sufficient expertise in the area of health physics to perform

meaningful evaluations.

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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 rogram.

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(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, 1981. The

Itcensee has stated that current trainifig is now provided to these

4

[ individuals.

(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 R0s. 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

4

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 items. (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 Training. 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 program.

(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

l its entirety as required by 10 CFR 55, Appendix A, 3.d. The

licensee stated current training specifically addresses this

matter.

(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

individuals.

(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

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February 25, 1987

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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 attached.

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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

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86-426

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November 20, 1986

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Dr. J. Nelson Grace

Regional' Administration

U. S. Nu:. lear Regulatory Commission, Region II

, 101 Marietta Street, N. W.

,

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, 1986. .

, 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,

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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

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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 group.

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-Dr. J. Nelson Grate-

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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 program.

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 Farley.

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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 deleted.

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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 cases.

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 report.

Sincerely yours t

/

R. P. Mcdonald

Senior Vice President

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