Text

Insp Repts 50-348/85-21 & 50-364/85-21 on 850415-19. Violation Noted:Failure to List Persons Contacted During Auditing
	ML20127L120
Person / Time
Site:	Farley
Issue date:	05/13/1985
From:	Belisle G, Upright C; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20127L085	List: ML20127L081; ML20127L120;
References
	50-348-85-21, 50-364-85-21, NUDOCS 8506270752
	Download: ML20127L120 (14)
	v • d • e

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c,n mtog UNIVED STATES

Do NUCLEAR REGULATORY COMMISSION

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Report Nos.: 50-348/85-21 and 50-364/85-21

Licensee: Alabama Power Company

600 North 18th Street

Birmingham, AL 35291

Docket Nos.: 50-348 and 50-364 License Nos.: NPF-2 and NPF-8

Facility Name: Farley Nuclear Plant

Inspection Conducted: April 15 - 19, 1985

Inspector: /M [/ [ r' fF

Qstegigned

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G.A.BelisTeg/' /

Accompanying Personnel: J. H. Moorman, III, Region II

M. A. Scott, Re ion II

Approved by: /#g [M u x__// c [ $ 8 j~

C. M. Upright,jf6ctiojt/ Chief D6te S'igned

Division of Redctor 66fety

SUMMARY

Scope: This routine, unannounced inspection entailed 110 inspector-hours on site

in the areas of licensee actions on previous enforcement matters, QA program

review, QA administration, audits, document control, and licensee action on

previously identified inspection findings.

Results: One violation was identified - Failure to list persons contacted during

auditing,

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

R. Badham, Safety Audit and Engineering Review (SAER) Staff

R. Coleman, Systems Performance Supervisor

J. Hudspeth, Document Control Supervisor *

R. Marlow, Technical Supervisor

C. Nesbitt, Technical Superintendent

C. Nichols, SAER Staff

W. Oldfield, SAER Staff

W. Shipman, Assistant Plant Manager, Support Services

W. Ware, Supervisor, SAER Staff

W. Warren, SAER Staff

J. Woodard, Plant Manager

NRC Resident Inspector

W.-Bradford, Senior Resident Inspector

Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on April 19, 1985, with

those persons indicated in paragraph 1 above. The inspector described the

areas inspected and discussed in detail the inspection findings listed

below.

Violation - Failure to List Persons Contacted During Auditing, para-

graph 6a.

Inspector Followup Item - Cheater Bar Usage, paragraph 6.b

Inspector Followup Item - 10 CFR 21 Requirements, paragraph 6.c.

The licensee did not identify as proprietary any of the material provided to

or reviewed by the inspector during this inspection.

3. Licensee Action on Previous Enforcement Matters

(Closed) Severity Level V Violation (348/83-13-03, 364/83-11-03): Failure

To Issue Audits Within Technical Specification (TS) Time Limits

The licensee response dated July 6, 1983, was considered acceptable by

Region II. The inspector reviewed Composite Audit Report No. 83/5 issued

May 17, 1983. The inspector reviewed SAER-AP-06, Audit Implementation,

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Revision 9. The inspector reviewed audits as discussed in paragraph 6 of

this report. All audits reviewed have been issued within TS required time

frames. The inspector reviewed training records for the auditing staff.

Specific training related to this violation was conducted June 15, 1983.

The inspector concluded the licensee had determined the full extent of the

violation, taken action to correct current conditions, and developed

corrective actions needed to preclude recurrence of similar problems.

Corrective actions stated in the licensee response have been implemented.

4. QA Program Review (35701)

Reference: 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear

Power Plants and Fuel Reprocessing Plants

The inspector reviewed the licensee QA Program required by the above

reference and verified that these activities were conducted in accordance

with regulatory requirements. The following criteria were used during this

review to assess overall acceptability of the established program:

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Personnel responsible for preparing implementing procedure understand

the significance of changes to these procedures.

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Licensee procedures are in conformance with the QA Program.

The procedures discussed throughout this report were reviewed to verify

conformance with the QA Program. The inspectors reviewed QA Program imple-

mentation as a part of the inspection. Each specific area is detailed in

other paragraphs of this report. Problem areas, if identified, are detailed

in the specific area inspected.

Within this area, no violations or deviations were identified.

5. QA Administration (35751)

References: (a) 10 CFR 50, Appendix B, Quality Assurance Criteria for

Nuclear Power Plants and Fuel Reprocessing Plants

(b) Technical Specifications, Section 6

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The inspector reviewed the licensee QA administri. tion program required by

references (a) and (b) and verified that these activities were conducted in

accordance with regulatory requirements and Technical Specifications. The

following criteria were used during this review to determine the overall

acceptability of the established program:

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QA documents clearly identify those structures, systems, componentsju

documents, and activities to which the QA program applies.

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Procedures and responsibilities have been established for making

changes to QA program documents.

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Administrative controls have been established for QA procedures which

assure procedure review and approval prior to implementation, control

of changes and revisions, and control of distribution and recall.

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Responsibilities have been established to assure overall review of QA

program effectiveness.

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Methods exist to modify the QA program to provide increased emphasis on

identified problem areas.

The following documents were reviewed to verify that these criteria had been

incorporated into licensee administrative procedures for QA administration

activities:

FSAR Chapter 17.2 Operations Quality Assurance Program (0QAP)

FSAR Chapter 17.3 Joseph M. Farley Nuclear Plant Quality Assurance

Q-List

FSAR Chapter 17.2.19 Operations Quality Assurance Policy Implementation

Li st

00APM Chapter 1 Operations Quality Assurance Program, Revision 22

0QAPM Chapter 2 Organization, Revision 22

OQAPM Chapter 5 Instructions, Procedures, and Drawings, Revision 22

0QAPM Chapter 6 Document Control, Revision 22

0QAPM Chapter 16 Corrective Action, Revision 20

0QAPM Chapter 17 Records, Revision 22

0QAPM Chapter 18 Audits, Revision 22

OQAOM Chapter 19 Training, Revision 22

0QAPM Appendix A Q-List, Revision 20

4- SAER-AP-02 Development and Implementation of Procedural

Guidance, Revision 9

SAER-AP-03 Control of Guidance Documents, Revision 9

SAER-AP-10 Reviews and Evaluation, Revision 8

SAER-AP-11 Summaries and Analysis of Audit Results, Revision 8

FNP-0-AP-4 Control of Plant Documents and Records, Revision 7

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The inspector reviewed auditing activities as discussed in paragraph 6.

Corrective action was reviewed as part of auditing activities. An overall

review of QA activities was also conducted as part of auditing activities.

Within this area, no violations or deviations were identified.

6. Audits (40702 and 40704)

References: (a) 10 CFR 50, Appendix B, Quality Assurance Criteria for

Nuclear Power Plants, and Fuel Reprocessing Plants

(b) ANSI N45.2.12-1974, Requirements for Auditing of Quality

Assurance Programs for Nuclear Power Plants

(c) Regulatory Guide 1.146, Qualification of Qcality

Assurance Program Audit Personnel for Nuclear Power

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Plants

(d) ANSI N45.2.23-1978, Qualification of Quality Assurance

Program Audit Personnel for Nuclear Power Plant

(e) Regulatory Guide 1.33, Quality Assurance Program

Requirements (Operation),

(f) ANSI N18.7-1972, Administrative Controls and Quality

Assurance for the Operational Phase of Nuclear Power

Plants

(g) Technical Specifications, Section 6

The inspector reviewed the licensee audit program required by references (a)

through (g) to verify that the program had been established in accordance

with regulatory requirements, industry guides and standards, and Technical

Specifications. The following criteria were used during this review to

determine the overall acceptability of the established program:

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The audit program scope was defined consistent with Technical Specifi-

cations and QA program requirements.

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Responsibilities were assigned in writing for overall management of the

audit program.

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Methods were defined for taking corrective action on deficiencies

identified during audits.

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The audited organization was required to respond in writing to audit

findings.

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Distribution requirements were defined for audit reports and corrective

action responses.

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Checklists were required to be used in performing audits.

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Measures were established to assure that QA audit personnel met minimum

education, experience, and qualification requirements for the audited

activity.

The documents listed below were reviewed to verify that these criteria had

been incorporated into the auditing program:

FSAR Chapter 17.2 Operations Quality Assurance Program (0QAP)

0QAPM Chapter 2 Organization, Revision 22

0QAPM Chapter 16 Corrective Action, Revision 22

0QAPM Chapter 18 Audits, Revision 22

0QAPM Chapter 19 Training, Revision 22

SAER-AP-05 Audit Coverage Planning, Revision 8

SAER-AP-06 Audit Implementation, Revision 9

SAER-AP-07 Qualification and Training, Revision 8

SAER-AP-09 Corrective Action, Revision 9

SAER-AP-10 Reviews and Evaluations, Revision 8

SAER-AP-11 Summaries and Analysis of Audit Results, Revision 8

FNP-0-AP-7 Corrective Action, Revision 8

GO-NG 10 Corrective Action, Revision 2

The inspector reviewed audit schedules for 1983, 1984, and 1985. The

inspector verified the following Technical Specification (TS) audit

frequencies:

TS Audit Area

6.5.2.8.b Plant Staff Training and Qualifications

6.5.2.8.c Corrective Actions

6.5.2.8.d Emergency Plan

6.5.2.8.e Security Plan

6.5.2.8.k Radiological Plan

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The inspector verified that audit areas conducted met those required by

10 CFR 50 Appendix B. The inspector reviewed ten SAER personnel qualif t-

cations. Eight SAER personnel were qualified lead auditors. Two SAER

personnel were senior reactor operator (SRO) licensed. The inspector

reviewed the following audit checklists:

Maintenance Surveillance Test May 7-18, 1984

Procedure (STP) Schedule

Maintenance May 14-25, 1984

Operations January 3-20, 1984

Radiological Control May 13-31, 1984

Plant Administrqtion April 4-22, 1983,

and April 5-19, 1984

Environmental Qualification October 20-24, 1983

Program

Chemistry September 9 -

October 5, 1984

The inspector reviewed corrective action reports associated with audit

noncompliances.

The inspector reviewed a proposed agenda for the Nuclear Operations Review

Board (NORB) meeting conducted on March 27, 1985. This agenda included a

section which detailed the following SAER activities:

Previous Quarter Audits

Next Quarter Qudits

Previous Quarter Offsite Audits

Next Quarter Offsite Audits

Corrective Action Status

Audit Finding Resume

The agenda also included NRC inspection findings resume and a compliance

index for NORB Charter, Section 9- SAER auditing requirements. The

inspector reviewed NORB meeting No. 85-1 minutes, conducted March 27, 1985,

and issued April 8, 1985. The NORB did not have any recommendations

relative to SAER activities. The inspector also reviewed the 1984 and 1985

Joint Utility Management Audit (JUMA) results. These audits were conducted

to review SAER activities. Findings identified during these audits were

either corrected (1984) or under evaluation (1985).

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To verify audit program implementation, the inspector reviewed the following

1984 and 1985 audits:

Composite Audit Report No. 85-05 Issued March 19, 1985

Integrated and Local Leak Rate January 9 - March 6, 1985

Testing - Unit 2

1985 Unit 2 Refueling January 7 - March 6, 1985

Composite Audit Report No. 85-04 Issued March 5, 1985

Plant Operations January 7 - February 14, 1985

Conformance to 10 CFR 50.59* December 11, 1984 - February 14, 1985

Unit 2 Feedwater Replacement * January 22 - February 14, 1985

Unit 2 Turbine Generator February 2 - February 15, 1985

Maintenance Inspection

FNP Emergency Program January 7 - February 14, 1985

Composite Audit Report No. 85-03 Issued February 21, 1985

Unit 2 Turbine Generator January 22 - February 1, 1985

Maintenance / Inspection

Composite Audit Report No. 85-02 Issued February 4,1985

Unit 2 Feedwater Heater Replacement * January 14-21, 1983

Unit 2 Turbine Generator January 7-21, 1985

Maintenance / Inspection

Composite Audit Report No. 84/25 Issued January 14, 1985

ESF - Containment Isolation System * November 20 - December 21, 1984

Composite Audit Report No. 84/09 Issued April 11, 1984

Corrective Actions - Results March 5 - April 3, 1984

Feedwater Reducer Replacement * March 21-27, 1984

I&C STPs February 28 - April 3, 1984

Corrective Action & SSAER Activities March 26-30, 1984

Composite Audit Report No. 84/08 Issued April 4, 1984

Unit 1 Turbine - General Inspection March 2-22, 1984

Feedwater Reducer Replacement * March 6-27, 1984

Composite Audit Report No. 84/07 Issued March 23, 1984

Material Control February 8 - March 16, 1984

Composite Audit Report No. 84/06 Issued March 19, 1984

Unit 1 Feedwater Heater Replacement * March 2-8, 1984

FNP Staff January 1 - February 28, 1984

Environmental Monitoring January 20 - March 7, 1984

Environmental Monitoring January 30 - March 7, 1984

Surveillance Testing

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, Composite Audit Report No. 84/05 Issued March 8, 1984

Unit 1 Turbine-Generator Inspection February 24 - March 1, 1984

Unit 1 Feedwater Heater Replacement * February 24 - March 1, 1984

Procurement of Materials and January 23 - March 1, 1984

Services

Composite Audit Report No. 84/04 Issued March 8, 1984

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Plant Operations January 3 - February 22, 1984

Unit 1 Turbine-Generator Inspection February 17-23, 1984

Unit 1 Feedwater Heater Replacement * February 17-23, 1984

Composite Audit Report No. 84/02 Issued February 10, 1984

Procurement of Nuclear January 12-30, 1984

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Instrumentation from CP&L*

Valve Repair of Body to Bonnet January 23, 1984

Steam Leak *

Composite Audit Report No. 84/01 Issued January 12, 1984

Quality Control December 5,1983 - January 5,1984

Spot Audits - A review of a singular activity, usually of very limited

scope.

The licensee identifies audit observations by two methods, noncompliance or

comments. A noncompliance is an auditor's determination that a condition

does not meet specific, cited, minimum quality requirements. A comment is

an auditor's statement which serves to call attention to, explain, amplify,

or otherwise comment on matters relevant to the audit. Comments may include

auditor opinions about conditions or actions which may not meet specific

minimum quality requirements. The inspector reviewed noncompliances and

comments for the audits previously listed and questioned four auditors about

what constitutes noncompliances and comments and how these items are closed.

Within this area, one violation and two inspector followup items were

identified and are discussed in the following paragraphs.

a. Failure to List Persons Contacted During Auditing

The accepted QA program commits to reference (b). This standard states

in Sections 4.4 and 4.4.3 that an audit report shall be written which

provides persons contacted during auditing activities. In reviewing

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audits, the inspector identified that in certain audits the licensee

identifies supervisory personnel and then includes a general statement

regarding other personnel. Examples include the following, but tnese

examples are not all inclusive:

Audit Audited Organization

.! Report No. Audit Date Representatives

, 84/10 3/28 - 4/03/84 Various Technicians

i 4/04 - 4/11/84 Various Technicians

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84/09 3/05 - 4/03/84 Various Supervisory Personnel

3/21 - 3/27/84 Various Tecnnicians

3/26 - 3/20/84 SSAER Staff

84/08 3/06 - 3/27/84 Various NNI Personnel

84/07 2/8 - 3/16/84 Various Others

84/02 1/23/84 Various FURMANITE

Maintenance Men

Discussions were conducted with auditing personnel regarding this

method of documenting personnel contacted during audits. This method

is .not allowable based on the accepted QA program commitments. This

failure to identi fy persons contacted during auditing activities

constitutes a violation (348, 364/85-15-01).

b. Cheater Bar Usage

Audit Report FNP-NC-60-83/21 issued December 20, 1983, identified

nonconformance FNP-NC-63-83/21(8) which wcs also indicated in

Corrective Action Report number 845. The nonconformance was based on

cheater bars having been used as operator aids for manipulation of

manual valves without documented policy or procedure. The nonconform-

ance was contrary to 10 CFR 50, Appendix B, Criterion V. On

February 13, 1984, the Vice President responded to the noncompliance

via a noncompliance status / routing sheet which indicated that a design

review would be made on the proposed cheater bar usage before imple-

mentation as an approved procedure and that a brief description on how

this issue had been handled to assure that designed strengths of valve,

piping, and supports were not exceeded. APC0 requested Bechtel Power

Corporation (BPC) technical support in evaluating cheater bar usage on

January 9, 1984. On February 28, 1984, BPC sent a letter to the

licensee with responses of five valve vendors who had supplied valves

to the site. The letter concluded that cheater bars should not be used

to close manual valves. Velan, one of the five valve vendors,

responded as follows:

Velan, on its own, does not recommend the use of cheater bars on

tha handwheels of gate and globe valves.

It is recognized that the use of cheater bars is widespread in the

industry.

If cheater bars are indeed used, then it is the responsibility of

the utility to lay down precise guidelines for their use so that

jobsite personnel do not overload the valves, which could result

in serious damage and impair the operability of the valves

involved.

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Intracompany correspondence dated May 25, 1984, to the Plant Manager

indicated that the use of cheater bars is wide spread in the industry

and that site procedure FNP-0-SOP-0, General Instructions to Operations

Personnel, had been revised to give guidance concerning the use of

mechanical advantage (cheater bars) to operate valves.

The procedure. indicates that there is an unspecified valve group which

can have additional force applied during operation without an eva-

luation. The procedure does not differentiate between safety related

and non safety-related valves. The procedure does not specify valve

examination (disassembly, inspection repair, and reassembly) after over

torquing, nor does it specify torque parameters for a given valve type.

The procedure does not define the evaluation, nor does it specify who

is to perform the evaluation.

At the time . of, the inspection, the SAER staff who generated the

nonconformance were preparing the quarterly audit status report which

will be sent to the corporate office for review. The SAER staff

indicated the cheater bar nonconformance would be an open action item

in the report. Due to the safety implications of this issue and until

satisfactory closure of the nonconformance occurs, this item is

identified as an inspector followup item 348, 364/85-21-02.

c. 10 CFR 21 Requirements

The inspector reviewed Administrative Procedure AP-62, Evaluation of

Defects and Noncompliances Potentially Reportable Under 10 CFR Part 21,

a revision one draft of AP-62, and other event reporting procedures.

These procedures indicated a number of areas which may create problems.

AP-57, Preservice and Inservice Inspections, requires a Part 21

reportability determination of nondestructive test evaluations and

inservice test reports which are not reflected in AP-62. Existing site

procedures do not evaluate nonconformances for Part 21 reportability.

Site procedures do not delineate the two- and five-day limits for

reporting a Part 21 condition nor do they provide a discussion of what

constitutes the evaluation period under Part 21. Licensing personnel

indicated that the corporate office, Nuclear Engineering and Technical

Support, determined reporting limits and made evaluations under

Part 21, which could create problems if a Part 21 condition is

identified on site. Licensing personnel indicated that the draft of

AP-62 would be amended in the above indicated areas. Until AP-62 is

amended, this item is identified as inspector followup item 348,

364/85-21-03.

7. Document Control Program (39702)

References: (a) 10 CFR 50, Appendix B, Quality Assurance Criteria for

Nuclear Power Plants and Fuel Reprocessing Plants

(b) Regulatory Guide 1.28, Quality Assurance Requirements

(Design and Construction)

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(c) ANSI N45.2 - 1971, Quality Assurance Requirements for

Nuclear Power Plants

(d) Regulatory Guide 1.33, Quality Assurance Program

Requirements (Operations)

(e) ANSI 18.7 - 1972, Administrative Controls for Nuclear

Power Plants

(f) Technical Specifications, Section 6

The inspector reviewed the licensee document control program required by

references (a) through (f) to verify that the program had been established

in accordance with regulatory requirements, industry guides and standards,

and Technical Specifications. The following criteria were used during this

review to determine the overall acceptability of the established program:

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The document control program was defined in consistence with QA program

requirements.

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Responsibilities were assigned in writing for overall management of the

document control program.

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Administrative controls were established for the control of drawings,

including piping and instrumentation diagrams.

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Master indices were required for drawings, manuals, Technical Specifi-

cation, FSARs, and procedures.

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Methods were established for the issuance, distribution, and review of

controlled documents.

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Methods were established to incorporate Technical Specification changes

into appropriate procedures, instructions, and drawings.

The documents listed below were reviewed to verify that these criteria had

been incorporated into the document control program:

FSAR Chapter 13.5 Plant Procedures

FSAR Chapter 17.2 Operations Quality Assurance Program

OQAPM Chapter 5 Instructions, Procedures, and Drawings,

Revision 22

OQAPM Chapter 6 Document Control, Revision 22

FNP-0-AP-1 Development, Review, and Approval of

Plant Procedures, Revision 16

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FNP-0-AP-4 Control of Plant Documents and Records,

Revision 8

The inspector verified that adequate controls exist and are being imple-

mented. Master copies of all plant documents and drawings are maintained in

Central Files. Controlled copies of documents and drawings are issued to

certain personnel and maintained in satellite files. A master index which

indicates the latest revision or pending revision to a particular document

is maintained in a manual filing system. The Control Document Distribution

Program (CDD), a computer based system, is used to track changes to a

document, individuals responsible for controlled copies, and distribution of

changes to controlled copies. The CDD is used to provide those persons

responsible for controlled copies a list of controlled documents and the

latest revision that they should have. A reply is required from the holders

of controlled copies verifying that their files are complete and current.

This is accomplished, as a minimum, on an annual basis. The inspector

reviewed selected controlled documents and drawings to verify that the

latest revision had been incorporated at the following locations:

Control Room

Mechanical Maintenance Shop

I&C Shop

Plant Modification Department

All files were current with the exception of two temporary changes missing

from the Mechanical Maintenance Shop. These temporary changes were added to

the applicable procedures during the inspection. There appears to be

isolated examples, consequently a violation is not warranted. Central

Files also issues and tracks Restricted Use Copies. These copies are issued

on a job basis and restricted in use to a specific Shop Work Order, Work

Request, or Work Authorization. When issued, the document is stamped as a

restricted use copy and given an expiration date. A record is maintained of

who is issued a restricted use copy and it's expiration date. This allows

document control personnel to assure that procedures in use during mainten-

ance are changed if necessary.

Within this area, no violations or deviations were identified.

8. Licensee Action On Previously Identified Inspection Findings (92701)

a. (Closed) Inspector Followup Item 348/83-13-04, 364/83-11-04: Appoint-

ment of Provisionally Qualified Lead Auditors

The inspector reviewed SAER-AP-07, Qualification and Training,

Revision 8. This procedure has been revised and provisional lead

auditor qualification is not longer allowed.

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b. (Closed) Inspector Followup Item 348/83-13-05, 364/83-11-05: Followup

to Procedure Changes

The inspector reviewed FNP-0-AP-8, Design Modification Control,

Revision 10. This procedure delineates controls for updating plant

procedures upon design modification completion.

c. (Closed) Inspector Followup Item 348/83-13-06, 364/83-11-06: Drawing

Discrepancies

A drawing review was conducted. Drawings were observed at various

locations as described in paragraph 7. Correct drawings were

identified at all locations.

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ML20127L120

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