ML20154F950
| ML20154F950 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 08/26/1988 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20154F508 | List: |
| References | |
| 50-348-88-04, 50-348-88-4, 50-364-88-04, 50-364-88-4, NUDOCS 8809200192 | |
| Download: ML20154F950 (35) | |
See also: IR 05000348/1988004
Text
'
.
,
.
August 26, 1988
ENCLOSURE 1
APPENDIX TO ALABAMA POWER COMPANY
FARLEY NUCLEAR PLANT
SALP BOARD REPORT NOS. 50-348/88-04; 50-364/88-04
(DATED JUNE 8, 1988)
8809200192 000907
gDR ADOCK 050 g 8
. .. .
s. . _ . .
.
'
.
,
'
s
.
August 26, 1988
I. Meeting Summary
A. A meeting was held on July 7,1988, at the Farley site to discuss the
SALP- Board Report for the Farley facility.
B. Licensee Attendees
1
B. M. Guthrie. Executive Vice-President
R. P. Mcdonald, Executive Vice President
W. G. Hairston, III, Senior Vice President - Nuclear Operations
J. D. Woodard, Vice President - Nuclear Generation
D. N. Morey, General Manager - Nuclear Plant
G. W. Shipman, Assistant General Plant.Manaccr
J.W.McGowan, Manager,SafetyAuditEngineeringReview(SAER)
'
J. E. Garlington, Manager Engineering & Licensing
C. D. Nesbitt, Technical Manager
S. Fulmer, Supervisor SAER
R. B. Wiggins, Supervisor of Operator Training
. J. K. Osterholtz, Manager - Operations
T. D. Arute, Shift Supervisor
R. L. Swif t. Shift Supervisor
C. NRC Attendees
M. L. Ernst Deputy Regional Administrator, Region 11
j A. F. Gibson, Director, Division of Reactor Safety
C. W. Hehl, Deputy Director, Division of Reactor Projects (DRP)
'
- H. C. Dance, Chief, Reactor Projects Section 18, DRP
, E. G. Adensam, Project Director, Project Directorate 11-1, l
Office of Nuclear Reactor Regulation (NRR) I
,
E. A. Reeves, Senior Project Manager, PD 11-1, NRR j
j F. Herr, Deputy Director, OIA '
->
N. Perkins, Auditor, OIA
j W. H. Bradford, Senior Resident Inspector, Farley
W. H. Miller, Resident Inspector, Farley l
9
,
l
- !
l
l
. . .. - - -
-
-
,
'
- .
i
,
II. Errata' Sheet - Farley SALP
Page Line Now Reads Should Read
11 8 .... received a violation for .... received an apparent
for failure ....for counting ' violation for failure ....
gaseous samples for counting gaseous
samples. Subsequent to
the issuance of the report
the licensee has denied
this violation. The NRC
is reviewing this matter. ,
Basis for change: To give a more accurate description of the apparent violation r
which is being contested.
12 c However, g(neral corrosion However, hundreds of pounds
. .. . carbor stee , piping of iron and ....
(See corrected page)
Basis for ch:nt.- To properl/ addrecs the facts in regard to steam generator and <
secondary . tide chendcal treatment.
29 6 Category: .? Category: 1
,
Basis for change: To correct aoministra;ive error ,
Unit 1 Unit 2 Unit 1 Unit 2
37 31 8 6
37 32 7 3 6 2
37 36 1 0
'
Basis for change: To correct administrative error.
III. Licensee Comments
Licensee comments submitted in response to the SALP Board report are attached.
.
i
I
i
' -
.
i
,
11
A confirmatory measurements inspection indicated that the
licensee's counting results met the established HRC criterion
for comparing counting results except that a negative bia was
observed for a 14cc vial gas sample from the waste gas ecay
tank. This bias was attributed to sample preparation te niques
because the bias was consistent for the four detector for all
isotopes. During an inspection in March 1988, the icensee
received a violation for failure to make attenuation corrections
for self absorption of gamma photons in a solid pol mer standard
which was used for calibrating the detectors r counting
gaseous samples. Count room equipment was, in general, not
state-of-the-art since it was procured in th early 1970s.
I However, the licensee has ordered new equip ent and expects
l onsite delivery by the latter half of 1988.
A simulated liquid waste sample which c tained H-3, Sr-89,
Sr-90 and Fe-55 was provided to Alabama ower Company in May
1987 by the NRC. The licensee's result compared favorably with
the NRC established criterion for com ring analytical results.
Liquid and gaseous radioactive e fluents were within the
Technical Specification limits and in compliance with 40 CFR 190
limits for radiation dose and r dioactivity concentration in
effluents. Fission and activ ion products in the gaseous
l effluents for 1987 were 35% 1 wer than in 1986. Also, 1987
'
values for gaseous iodines a particulates were 75% lower than
1986 values. In general, seous ef fluents for Farley Unit I
have been steadily decli44 9 since 1982 when Farley experienced
.
problems with failed 1. Radioactivity in the liquid
effluents was 47% lower S n 1987 as compared to 1986. Tritium in
liquid effluents has, .ained essentially constant for the past
,
three years. Gross pha radioactivity in the liquid ef fluent
I was essentially b cY round, 2E-5 curies (C1) per year. Annual
effluent releaseg mmaries for 1985-1987 can be found in
Section V.K. l
l
,
'
The licensee ported a total of five non-routine releases
(three liquid releases and two gaseous releases) during 1987.
The gaseous eleases occurred on Unit 2 and totalled 8.7 E-6 Ci. !
- These mont red, planned releases were caused by steam generator l
pressure 1se cleaning and steam generator helium leak testing.
The non- outine liquid releases occurred on Unit 1, and a total
i of 4.65 E-5 Ci were released. Two of the releases were due to a
l Refuel ng Water Storage Tank barrier penetration leak, and a
l thir release was caused by a leak in the pumping equipment on l
l the eactor Makeup Water Storage Tank. j
1 '
l
I
l
l
. _ _ - - - _ _ _ - - _ _ _ _ _ __
'
I
'
.
,
.
11 50-348;364/88-04
Corrected 8/26/88
A confirmatory measurements inspection indicated that the licensee's
counting results met the established NRC criterion for comparing counting
results except that a negative bias was observed for a 14cc vial gas
sample from the waste gas decay tank. This bias was attributed to sample
preparation techniques because the bias was consistent for the four
detectors for all isotopes. During an inspection in March 1988, the
licensee received an apparent violation for failure to make attenuation
corrections for self absorption of gama photons in a solid polymer
standard which was used for calibrating the detectors for counting gaseous
samples. Subsequent to the issuance of the report, the licensee has
denied this violation. The NRC is reviewing tt is matter. Count room
equipment was, in general, not state-of-the-art since it was procured in
the early 1970s. However, the licensee has ordered new equipment and
expects onsite delivery by the latter half of 1988.
A simulated liquid waste sample which contained H-3, Sr-89, Sr-90 and
Fe-55 was provided to Alabama Power Company in May 1987 by the NRC. The
licensee's results compared favorably with the NRC established criterion
for comparing analytical results.
Liquid and gaseous radioactive effluents were within the Technical
Specification limits and in compliance with 40 CFR 190 limits for
radiation dose and radioactivity concentration in effluents. Fission and
activation products in the gaseous effluents for 1987 were 35% lower than
in 1986. Also, 1987 values for gaseous iodines and particulates were 75%
lower than 1986 values. In general, gaseous effluents for Farley Unit 1
have been steadily declining since 1982 when Farley experienced problems
with failed fuel, Radioactivity in the liquid effluents was 47% lower in
1987 as compared to 1986. Tritium in liquid effluents has remained
essentially constant for the past three years. Gross alpha radioactivity
in the liquid effluent was essentially background, 2E-5 curies (Ci) per
year. Annual effluent release sumaries for 1985-1987 can be found in
Section V.K.
The licensee reported a total of five non-routine releases (three liquid
releases and two gaseous releases) during 1987. The gaseous releases l
occurred on Unit 2 and totalled 8.7 E-6 Cl. These monitored, planned ;
releases were caused by steam generator pressure pulse cleaning and steam
generator helium leak testing. The non-routine liquid releases occurred
on Unit 1, and a total of 8.65 E-5 Ci were released. Two of the releases
were due to a Refueling Water Storage Tank barrier penetration leak, and a
third release was caused by a leak in the pumping equipment on the Reactor
Makeup Water Storage Tank.
l
l
N
.
-
.
.
12
Radiation doses to the maximally expnsed offsite individual from
liquid and gaseous effluents for 1987 were calcula ed to be
0.16 mrem to the whole body and 0.17 mrem to the er ical organ.
These values were consistent with previous annual se estimates
and below 40 CFR 190 limits.
The licensee continued to meet the criteria f good chemistry
control established by the Steam Generator ners Group and
Westinghouse. However, general corrosion o carbon steel pipe
throughout the secondary coolant system co inued to result in
hundreds of pounds of "sludge" being tra ported to the steam
generators. Since this sludge had al ady initiated tube
denting, the licensee continued to add oric acid as well as AVT
control chemicals (ammonta and hydra ne) to the feedwater.
This action, in turn, complicated e pH control needed to
prevent general corrosion and pipe inning. Consequently, the
licensee planned to take two majo steps to provide additional
protection to the steam generato s. During refueling outages
(October 1987 and April 1988) t steam generators were cleaned
by a pressure pulse technique in an effort to remove solid
iron-copper oxides from tube- ube sheet crevices and from the
secondary sides of the st am generator tubes. Secondly,
beginning in the next fuel cycles, morpholine will be substi-
tuted for ammonia for pH ntrol in an effort to maintain higher
pH conditions in the gr n steel piping.
Six violations were ntified as follows:
a. Severity Le III violation with three examples:
(1) failureg adequately control access to a high
radiation q (2) failure to follow procedures, and
(3) failudp)r a,to adequately instruct individuals working in
or freque ing a restricted area (348, 364/88-02). '
b. Severit Level IV violation for failure to assure that a
recipi nt was authorized to receive radioactive material
(348,364/86-26). l
1
'
c. Se rity Level IV violation for failure to comply with 00T l
r ulations applicable to the transportation of radioactive '
aterial (348, 364/86-26).
d. Severity Level IV violation for failure to follow the
requirements of a radiation work permit (348, 364/87-28).
e. Severity Level IV violation for failure to maintain records
of survey when local instrumentation was out of service
(364/87-29).
- . ._. _
l
'
.
'.
12 50-348;364/88-04
Corrected 8/26/88
Radiation doses to the maximally exposed offsite individual from liquid
and gaseous effluents for 1987 were calculated to be 0.16 mrem to the
whole body and 0.17 mrem to the critical organ. These values were
consistent with previous annual dose estimates and below 40 CFR 190
limits.
The licensee continued to meet the criteria for good chemistry control
established by the Steam Generator Owners Group and Westinghouse.
However, hundreds of pounds of iron and copper oxide ' sludge' have been
transported to the steam generators each fuel cycle as the result of
general corrosion of carbon steel pipe throughout the secondary coolant
system. Also, iron oxide deposit have been formed in the tube-tube support
regions of the steam generators and indications of cracks have been
observed in tubes, in Unit 2, at these elevations. During the last
refueling outage the steam generators were subjected to a
' pressure-pulse' cleaning in an effort to remove these restriction. The
licensee continued to add boric acid to the secondary coolant to prevent
tube denting. This is consistent with the Owners Group guidelines. The
licensee planned to augment AVT chemistry control by also adding morpho-
line in an effort to establish less acidic conditions throughout the
secondary coolant system and thereby reduce erosion / corrosion.
Six violations were identified as follows:
a. Severity Level III violation with three examples: (1) failure to
adequately control access to a high radiation area, (2) failure to
follow procedures, and (3) failure to adequately instruct individuals
working in or frequenting a restricted area (348, 364/88-02).
b. Severity Level IV violation for failure to assure that a recipient
was authorized to receive radioactive material (348, 364/86-26).
c. Severity level IV violation for failure to comply with DOT
regulations applicable to the transportation of radioactive material
(348,364/86-26).
d. Severity Level IV violation for failure to follow the requirements of
a radiation work permit (348, 364/87-28).
e. Severity Level IV violation for failure to maintain records of survey
when local instrumentation was out of service (364/87-29).
_ _ _ _ _ _ - _ _ _ _
-
. 1
.
29
licensing activity. Thus, many operation's relate questions
from the NRC staff for information surveys or for information
related to event occurrences are answered without n additional-
burden to the plant operations staff.
2. , Conclusions
Category: 2
3. Recommendations
None
K. Training and Qualification Effectiveness
1. Analysis
During the assessment period, spections were conducted by the
resident and regional staf . Inspections included two
licensing examination site isits and one requalifications
program evaluation. Assess ent of training effectiveness were
also made during the OPA n ted previously.
The resident inspectors have had numerous occasions to ect
the training received y licensed and non-licensed per el.
The inspectors h e observed simulator training and ave
reviewed the 1 ed operator requalification training
material. The i ectors have observed and reviewed certain
hands-on train at the training center and have reviewed
instruction mp ial for non-licensed personnel. The training
center is st M of-the-art. The instructors are considered to
be very pro (f ient and well qualified in their positions. The
training pr rams which are prescribed for each craf t are a
required a continuing training evolution. Each program is an
indepth c erage of all required work evolutions. Each training
phase re ired craftsmen to successfully complete an examination
on that ortion of the training. .The observed training has been
profes ional, comprehensive and well received by personnel .
Addi onally, the ten program areas of training for plant
per nnel have been accreditsd by INPO. I
i
T e majority of the operators interviewed during the OPA
ndicated that both initial and requalification training were
adequate and had improved substantially over the last two years.
Interviews also indicated that the practice of operating crews
attending roqualification and simulator training as a crew
enhanced the interface and teamwork within the crew. Simulator
training was highly praised and operators indicated that plant
specific events and emergency operating procedures (EOPs) were
1
l
<
.
- - - _ _ _ _ _ _ _ _ _ _ _ _ _
.
. I
29 50-348;364/88-04
Corrected 8/26/88
.
licensing activity. Thus, many operation's related questions
from the NRC staff for information surveys or for information
related to event occurrences are answered without an additional
burden to the plant operations staff.
2. . Conclusions
Category: 1
3. Recommendations
None
K. Training and Qualification Effectiveness
1. Analysis
During the assessment period, inspections were conducted by the
resident and regional staffs. Inspections included two
licensing examination site visits and one requalifications
program evaluation. Assessment of training ef fectiveness were
also made during the OPA noted previously.
The resident inspectors have had numerous occasions to inspect
the training received by licensed and non-licensed personnel.
The inspectors have observed simulator training and have
reviewed the licensed operator requalification training
material. The inspectors have observed and reviewed certain
hands-on training at the training center and have reviewed
instruction material for non-licensed personnel. The training
center is state-of-the-art. The instructors are considered to
be very proficient and well qualified in their positions. The
training programs which are prescribed for each craf t are a
required and continuing training evolution. Each program is an
indepth coverage of all required work evolutions. Each training
phase required craftsmen to successfully complete an examination
on that portion of the training. .The observed training has been
prafessional, comprehensive and well received by personnel.
Additionally, the ten program areas of training for plant
personnel have been accredited by INPO. l
The majority of the operators interviewed during the CPA
indicated that both initial and requalification training were i
adequate and had improved substantially over the last two years.
Interviews also indicated that the practice of operating crews
attending requalification and simulator training as a crew
enhanced the interface .nd teamwork within the crew. Simulator
training was highly praised and operators indicated that plant
specific events and emergency operating procedures (EOPs) were
.
,
.
.
37
,
.
detailed, well written and easy to understand. The narrative
sections typically included specific details of the event such as
valve identification numbert, model numbers, number of operable
redundant systems, the date of completion of repair .to provide a
good understanding of the event.
LERs presented the event information in an organ ed pattern with
separating headings and specific information in e h section that led
,
to a clear understanding of the event informati . Previous s' .ar
l
occurrences were properly referenced in the LE as applicable
The licensee updated some LERs during the sessment period. The
l updated LERs provided new information and e portion of the report
l that was revised was denoted by a vertica line in the right hand
i margin so the new information could eas y be determined by the
reader.
The licensee submitted several report and updates on a voluntary
basis during the assessment period, s stated on page 10 of NUREG-
1022, licensees are encouraged to re ort any event that does not meet
reporting criteria if the licensee Jelieves that the event might be
of safety significance, might be o generic interest or concern, or
contains a lesson to be learned.
l A review of LERs does not i eneral indicate any trend that the
plants are subject to rec ng problems. Recently the licensee
has developed a program rend personnel errors and repetitive
equipment failures. The team noted that all corrective actions
taken were not listed i .he LER and therefore, were not always
correct. Licensee eva ions did not always show that the root
cause was trended or p Jed.
l The distribution of th events analyzed by cause by the licensee were
l as follows:
!
Cause Unit 1 Unit 2
Component Failur 8 5
Design / 7 3
Construction, brication, or
Installatio 6 2
Personnel
- Operat4n etivity 5 1
- Maintena ce Activity 4 4
- Test /Ca ibration Activity 3 4
l -
Other 6 -
Out of alibration - -
1
Other 3 -
r TOTA- 39 17
Si TOTAL 56 , l
t
L
.
'
,
..
.
37 50-348;364/88-04
Corrected 8/26/88
detailed, well written and easy to understand. The narrative
sections typically included specific details of the event such as
valve identification numbers, model numbers, number of operable
redundant systems, the date of completion of repairs to provide a
good understanding of the event.
LERs presented the event information in an organized pattern with
separating headings and specific information in each section that led
to a clear understanding of the event information. Previous similar
occurrences were properly referenced in the LERs as applicable.
The licensee updated some LERs during the assessment period. The
updated LERs provided new information and the portion of the report
that was revised was denoted by a vertical line in the right hand
margin so the new information could easily be determined by the
reader.
The licensee submitted several reports and updates on a voluntary
basis during the assessment period. As stated on page 10 of NUREG-
1022, licensees are encouraged to report any event that does not meet
reporting criteria if the licensee believes that the event might be
of safety significance, might be of generic interest or concern, or
contains a lesson to be learned.
A review of LERs does not in general indicate any trend that the
plants are subject to recurring problems. Recently the licensee
has developed a program to trend personnel errors <ind repetitive
equipment failures. The OPA team noted that all cor.aective actions
taken were not listed in the LER and therefore, were not always
correct. Licensee evaluations did not always show that the root
cause was trended or pursued.
The distribution of the events analyzed by cause by the licensee were
as follows:
Cause Unit 1 Unit 2
Component Failure 6 5
Design 6 2
Construction, Fabrication, or
Installation 6 2
1
'
Personnel
- Operating Activity 5 0 l
- Maintenance Activity 4 4
- Test / Calibration Activity 3 4 ,
-
Other 6 -
Out of Calibration - - *
Other 3 -
TOTAL 39 17
SITE TOTAL 56
i
..
.
~
- -
~
ase J
EXITED STATES
X1~C:1 EAR 33G1~1ATORY
go . o
. ..
VV...w.. swsw
gg,aw V ..
SYSTEMATIC ASSESSMENT
- LICENSE 3 PERFORMANCE
i
'SA 3
)
'
~
\
E N?
-
--
.
.
,.
,: i
. . . -
.
A1ABAYA
~
30WE3 j
f
COMPANY
i
AUGUST 1,1986 - MARCH 31,1988
l
l
7AL3Y 'JXITS :. & 2
.
JULY 7,1986
- DOTHAN, ALABAMA
i
l
~-~
__
.
-- ---- --
W- - -
SL? ?30G3AE 03J3C":V3S -
!
i
'
I
. V 3 ROVE CENSEE 3ER 0RVA\CE
l 2. 3 70V JE A 3AS S 70 R A__0CA-~ 0 s
Or \ RC R SOURCES
..
'
3. V 3 ROVE \ RC REGUE0RY 3ROGRAV
<
--
.. _n -~.. . _ . .
-
- '
. . -- - .. -
.
(
- - - - -
-
.
-
_.
_
..
, glo
p
s
in b ahlI -
a -
QI d e5
I
U
' si l$ ig
N !
6
=
le
%
l I! Il" hl! s,5
1
x
% e e
3 ** !
h *? 4 "
3 a
'gl
' l
( - .
,
l
. _
.
DIVISION OF REACTOR PROJECTS .
ORGANIZATION .
.
i' DIVISION OF
s
REACTOR PROJECTS TECHNICAL SUPPORT STAFF
-
'
CHIEF K. LANDIS
DIR. L. REYES
I I I
l REACTOR PROJECTS REACTOR PROJECTS REACTOR PROJECTS
BRANCH NO. 1 BRANCH NO. 2 BRANCH NO. 3
- \- i
j CHIEF D. VERRELLI CHIEF B. WILSON CHIEF V. BROWNLEE 5
PftOJECT3 SECTION PROJECT 3 SECTION PROJECTS SSSTION
NO.1A NO. 2A NO. 3A ,
i OHIEF P. FREDRICKSON -
CHIEF J. CRLENJAK CHIEF T. PEE 3tJS
l .
,
BRUNSWICK CRYSTAL RIVER CATAWBA
HARRIS ST. LUCIE McGUIRE
l ROSINSON TURKEY POINT OCONEE
l .
- PROJ1iECTS SECTION PROJECT 5 SECTION PROJECTS BSCTION
]
NO.1B _N O . 2 3, MA N
i CHIEF H. DANCE CHIEF F. CANTRELL CHIEF M. 30NKULZ
l
,
J"" NORTH ANNA HATCH
s
SURRY VOGTLE
- -- . . - . - - ._. _ _ _ _ - _
_ _ _ _ _ _ _ _ _ _ _ _ ___ - - - - - __ __ _ _ _ _. _-_ _ _ . 'i
_ . - _ _ _ _ _ _
_ _ . . - _ . .- -. _ _ _ _ _ _ _ -
.
'
-
~.
NRR ORGANIZATION .
j OFFICE OF
NUCLEAR REACTOR
REGULATION PROGRAM MANAGEMENT,
-
POUCY DEVELOPMENT,
& ANAL. M ST M
DIR. THOM#.3 E. MURLEY ,
.
I I
1
ASSOC. DIRECTOR FOR
4
ASSOC. DIRECTOR INSPECTION &
! FOR PROJECTS TECHNICAL ASSESSMENT
I
l l
<
.
-
i
i DIV. OF ENGINEERING
- DEVISION OF AND SYSTEM
, MACTOR PROJECTS I/II TECHNOLOGY
,
5. VARGA. DIR. I/Il
j E. ADENSAM. DIR 11-1 'i
i E. REEVES. PROJ. MGR. DiV. OF
l
FN , OPERATIONAL EVENTS
,
l ASSESSMENT
I
!
'
DIV. OF REACTOR
1 INSPECTION AND
l DIV. OF REACTOR SAFEGUARDS
i PROJECTS Ill/tv/V
i
AND 3rECIAL PROJEGTS
! ou. or maniAnon
ensnrenow me l
l menemcv enErasumuzasl
l
! or . -
N
k *"""**"'"""
. x
)
i
-
,
, .. -
_ _ _ _ _ _ _ -
PERFORMANCE ANALYSIS AREAS
,
FOR OPERATING REACTORS
,
.
1. PLANT OPERATIONS
2. RADIOLOGICAL CONTROLS
,
3. MAINTENANCE
4. SURVEILLANCE
'
5. FIRE PROTECTION
'
6. EMERGENCY PREPARE 0 NESS
>
'
!
7. SECURITY
'
j 8. OUTAGES !
1
9. QUAUTY PROGRAMS
10. UCENSING ACTMTIES
j
11. TRAINING
1
12. ENGINEERING SUPPORT j
N .-_ _ .- .
,
.-_.-_______..,.,,_..__,_,__,,_.__,,.___,__,r.__,,_,_.._____._,_____,______,,.__m_
O
.:' .
!' AREA PERFORMAXCE
,
CMEGORY 1 i
j
!
REDUCED NRC ATTENTION MAY BE APPROPRIATE. j
LICENSEE MANACEMENT ATTENTION AND INVOLVEMENT
ARE AGGRESSIVE AND ORIENTED TOWARD NUCLEAR
SAFETY; LICENSEE RESOURCES ARE AMPLE AND
EFFECTIVELY USED SUCH THAT A HlGH LEVEL OF ,
i
PERFORMANCE WITH RESPECT TO OPERATIONAL
i
!
SAFETt OR CONSTRUCTION IS BEING ACHIEVED.
l
1
-
'
l
~
m..-- .
..,-n,-
,
_ .
,, e
.. .
. . . .
AREA PERFORMANCE ~d-
CATEGORY 2
.
NRC ATTENTION SHOULD BE MAINTAINED AT NORMAL
LEVELS. LICENSEE MANAGEMENT ATTENTION AND
-
INVOLVEMENT ARE EVIDENT AND ARE CONCERNED WITH
i
NUCLEAR SAFET(; LICENSEE RESOURCES ARE ADEQUATE
!
.
AND ARE REASONABLY EFFECTIVE SUCH THAT SATISFACTORY
PERFORMANCE WITH RESPECT TO OPERATIONAL SAFET( OR l
CONSTRUCTION IS BEING ACHIEVED.
.
W ,e
e
_. _ _ _ _____ ____ _
- --
. _ . . . _ . .
,
l.. .:s.. .
-.. --.
-
l-
AREA PERFORMANCE
,
l
CATEGORY J
BOTH NRC AND LICENSEE ATTENTION SHOULD BE
INCREASED. UCENSEE MANAGEMENT ATTEi4Tl0N OR
INVOLVEMENT IS ACCEPTABLE AND CONSIDERS NUCLEAR
S/fETf, BUT WEAKNESSSES ARE EVIDENT; LICENSEE
RESOURCES APPEAR TO BE STRAINED OR NOT EFFECTIVELY
USED, SUCH THAT A MINIMALLY SATISFACTORY PERFORMANCE
l
WITH RESPECT TO OPERATIONAL SAFET( OR CONSTRUCTION ,
1
IS BEING ACHIEVED. ;
,,
- __- - _ .
... _ _ _ . . __ __
u_ ,
,
__ -
_ _ - . _
g
..
EVATLATION CRITERIA
1. MANAGEMENT INVOLVEMENT IN ASSURING QUALITY
2. APPROACH TO RESOLUTION OF TECHNICAL ISSUES
FROM A SAFETY STANDPOINT
3. RESPONSIVENESS TO NRC INITIATIVES
4. ENFORCEMENT HISTORY
l
5. REPORTING AND ANALYSIS OF REPORTABLE EVENTS
.
6. STAFFING (INCLUDING MANAGEMENT)
7. TRAINING EFFECflVENESS AND QUAUFICATION
' >
-
.
_
,
- . . .
. _ _ - _ _ . . . .
- 1
- - - - --
.
- .
- .
.
Q
V0E0s SM VARY
AUGUST 1,1986 - MARCH 31,1988
,
I M E N V D q
,
,
FARLEY 1 0 0 3 19l 4 1
FARLEY 2 0 0 3 17 5 1
REGION ll AVE. 0 0 3 23 6 <1
.
1
'
!
!
i
i
l Severity Level IV violation involving containment
penetrations (86-25) was denied. NRC reviewing.
i
.l
\
-
.. .- ___
i
- _ _ - _
- . _ _ _ - - - - _ - - _ _. _ -- _ . __ . . - _ ..
'
-
OPERATIONS PHASE OLATION ERATING REACTOR
"" LEGEND
R 11 AVE
"
- -
E rum .
E umm
. .
N
30 "
] a a +
,
_ _ , , _ _
.
_ _ _ _ -
7,,. --
. - . _
-_
z
'
ALLEGATIONS PER ETILITY/S""3
AL' GUST 31, 1986 through WARCH 31,1988 '
""
LEGEND .
g. .
bMME.
FAALEY
a-
,i
b unums
9
$2 . ,
!
- ;
g ..
< ,. :
'. .
'
- *
x
15-
!z
, O
"
10
s. - ,
'
" "
- - -
a . . . . i
GPC FPL CPL M AVSEM YEP FPC DUKE SCE APC
< _
UTUTY
.- .
_ _ . _ _ _ _ _ _ _ _
-
.
i
- -
,..
.
AV33AG3 NEY333 07 3x "3L3S l
A30V3 :.5% ?W3. / :.000 : ;
CI'XCA:a -:rs.
JUGUST 1,1986 through MARCH 31,1988 \
3 ,.
l
"" .43
<
.. .39 l
i .
, ,.
.
.
! o
.
o .m -
t
'
O
v--
<
x .m .
.17
! m
'
b .16" ' ' '
y ..
- 1--
'
I
. .
,
,(__
'
FARLIYf1 FARLIYl2 NArt. AVE
_
._ -
i
!
_ _ _ _ _ _ - _ _ _ - _ _- - - - - , . , . - . . . - _ _ _ . _ _ _ . . . . - ~
'I
- - - - - - - - ~ -
. . _ _
~
_ 53S 35R u \
l
1986 "hrough 1988
'
~
LEGEND l
NAT'l. AVE.
'
U" FARLEY :
PlM TYPE
l
l ,.
g 3e
,
t
32
l, g 3,
l
' " "
28
27
o y ;
a
. .
'
.
$
to -
!
I o. -
i
ll
t uc TE . - . . - - _ .
I - - .
-
.
.
.
'
-.
, , ,
.
I
l
FARLEY LERs
l (3 _A \ ~)
- AUGUST 1,1986 through MARCH 31, 1988
!
l
l*
,
i
,
RERSOME.
i 446.45
,
l
! . . . . - -
... . . .;
! OTHER 5.44
,
l 28.6% /
l .
19.6%
'
j : E: . ..'.
. . L ONbT.
,
'
COMP. F.NLURE
I
I
I
i
1
l
i
'
,
l
! I
'
i
_
_ .
'
i
- ,
'
I
__ . _- . -. _
_
s' * . _ _.._ _ _. _ ..- _
'
~A R _EY __ r Rs i
AUGUST 1,1984 through WARCH 31, 1988 l
""
LEGEND
i 56 !
! === , l
l EEi PERSONNEL (other) = 4 l
1 'l
"'
PERSONNEL (test / col) = 7 l
l ...
. ,
l +:': PERSONNEL (maintenance) = 8
- -
1 PERSONNEL (operating) = 5 l
E N l
'
y '
0TER = 3
0, . COMPONENT FAILURE = 11
et
'
s
3 26 ,
.. .. DESIGN / CONST. = 16 l
,
. 2
- ' 2
i$ =$
.
. .
.. .
I
'
l
l
l
i
'
t' --
1
e . : :
- ( Pulli PERSONND.
_ - _
-
l
!
! 1
.:
_ ,. . .
.
.
k
i FARLEY LERs 1
(PERSONNEL)
! AUGUST 1,1986 through MARCH 31, 1988
i
I
- MAINTENANCE
j 30.8% !'
!
! TEST /CALIB.
l 26.9%
l ,
l I
J
l
i
! OTHER
>
OPERATIONS 23.1% ;
'
19.2%
'
i
.i
PERSOHt$EL j
l '
N
! l
- _ - - _ _ _ _ . . _ _ .
.- - - - - -
..
- .NC~~ 0\A_ AREA CbV3AR SO\
_
.
CYC_E V
"" LEGEND
g
f b CATEGORY 1 ,
"~
- M
f CATEGORY 2 j
PJ CATEGORYi 3
f e
,,.
[7 / 7
0 f f~ f
t' h - h -
$
?u.j1 /
)1
/
-
1
g
-
l1
~
fit )i ! l j'I
-
6 ')1 i lf I
- . K!Jr!4
___
,
'
l RAD CON SURY FIRE PROT
__-_f.
.
.. ..
,
,. .- .
' r
. \C~ 0N A_ AREA COV 3AR SO\
'
,
70 R REG O s TAC _~ES
l CYC_E V
+
i
'
""
{ LEGEND
CATEGORY 1 t-
- CATEGORY 2
b) CATEGORY 3
// // // /
h 7
w
.
o
7 I/ II
/z
.
- d- // /' l
! ! $ $ l
'
4 il p 4 -
o o o o
l
SEC OUTMES QP UC 11tNG ENGR SUP
!
( FUNCTIONAL AREA j
- - _ - _
_
- . _ - _ _ - _ - , - _ _ -
<
J..- -- .
__
Q
'n v
1
- '
.
- ; -
~
g
.
at 1.1. i J iJ ij se .
t
.
!
l i
.
-
.- ;
,
CA TEGORY 1 AREJS
.
I
.
'
. 3 As" OPERATIONS
_
2. RA310_0GICAL CONTRO_S :
~
I
3. RE 3ROTEC" ON
L. 0_"AG ES
<
5. JCEsS sG
i
1
~
- - - - - , _ _ , _ . _ _ _,
_ _ _ - . . . - - - - - _ _ .. .- __._.- _-__ - - __ _ _
-
= .
3
,
u F RLE.
u
CJTEGORY 2 AREAS -.
'
!
i
! 1. MAINTENANCE
i
- 2. SURVEILLANCE
j 4. SECURITY ;
) 5. QUALITY PRCGRAMS :
l 6. TRAIN NG
l
1
7. ENGINEER NG SUPPCRT
I
'
'
. .__ _-
l
8
. _ _ _ _ - - _ . . _ _ _ - - - . _ - - _ - - _ - --__
f-- -_.
j
n ,4 A\ n T ru
.. m r
n L .n. L' .stN U L
C/TEGORY 3 ARE/S
NONE .
.
!
-
.
_ . - _ . .
-.-.
i
,
- ENCLOSURE 2
e *
.
- Mabama Peer Company
600 North 18th Street '
Post O'f.ce Sci 2641
Birm.ngham. Mabama 35291 o400
Te ephone 205 2501837 .*T*
...J'
k0
h'
W G. Heiteten.lH I'
sen<or vice Pres. dent
Nxlea? Operat.ons ,
the SOJhern egCfrC system
August 2, 1988 ,
.
Docket Nos. 50-348
50-364
U. S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Vashington, DC 20555 ,
.
Gentlemen
Joseph M. Farley Nuclear Plant Units 1 and 2
NRC Inspection Report Nos. 50-348/88-04 and 50-364/88-04
By letter dated June 8, 1988, the NRC forwarded the results of the
Systematic Assessment of Licensee Performance (SALP) Board evaluation of
Farley Nuclear Plant for 1988. Alabama Power Company has reviewed this
report and provides comments in an attachment to this letter. ,
Alabama Power Company appreciates the opportunity to provide comments on the ,
SALP report and requests that these comments be considered in the NRC's !
final conclusion. In addition to the attached comments. Alabama Power ;
company requests that comments and discussions from the July 7, 1988 meeting i
be taken into consideration for final disposition of the SALP report. ;
If you have any questions, please advise.
I
Respectfully submitted, ,
'
(~. .
k V .,G. Hairston, III l
O
VGH,III/BHVidst-V8.3 /
Attachments
cci Mr. L. B. Long f
Dr. J. N. Grace /
Mr. E. A. Reeves
Mr. V. H. Bradford
Yj'f
n e ,, e a ,.9 l
1 Q Q-( [ k Q p .p
1
;
o
-
e ,
'
1988 SALP Comments
NRC Inspection Report No.
50-348/88-04 and 50-364/88-04
No. Reference Comment
_
l. Page 12, 2nd 1 This paragraph contains several factual errors
(Section IV.B.1) in regard to steam generator and secondary
side chemical treatmentt
The report states, "Since this sludge
had already initiated tube denting,
...
" Sludge has not been shown to
cause tube denting. Crevice hideout
and the resultant crevice pH and
corrosion cause denting. Boric acid
soaks and online addition was
preventatively initiated on Unit 1 due
to support plate crevice corrosion (a
precursor of dentiaii. The same
treatment was initiated on Unit 2 due
to stress corrosion cracking occurring
at support plate intersections
(nondenting related). Tube deformation
has not been substantiated at FNP1 or
FNP2 (approximately 8 tubes in 2A steam
generator have que:tionable
indications. The ether tubes are not in
question). Neither FNP unit has had a
problem with eddy current test probe
passage due to restrictions which vould
be caused by denting.
The report states that the addition of
boric acid "complicated the pH control
needed to prevent general corrosion and
pipe thinning." Boron decreases
secondary pH slightly but does not
cause pH control problems.
The report states, "Consequently, the
licensee planned to take two anjor
steps to provide additional protection
to the steam generators. ...beginning
in the next fuel cycles, morpholine
vill be substituted for ammonia for pH
control in an effort to maintain higher
pH conditions in the carbon steel
piping."
The decision to add morpholine was not
based on inadequate or complicated pH
control but rather on the reduction of
erosion / corrosion and of steam
generator sludge loading that vould be
provided by using morpholine as a
secondary pH elevating additive.
.
)
o
o .
-
1988 SALP Comments
NRC Inspection Report No.
50-348/88-04 and 50-364/88-04
Page 2
,No . Reference Comment
2. Page 12, 2nd 1 Morpholine has been added at 4-10 ppm, not
(Section IV.B.1) substituted for ammonia, in Unit 2 Cycle 6 and
Unit 1 Cycle 9. Note that ammonia fr.om
decomposition of hydrazine is the dominant
determinant in steam generator pH control.
3. Page 15 2nd 1 The deviation for failure to control clams in
,
(Section IV.C.1) service water is not indicative of the
l progress that has been made since August 1,
1986. Extensive testing during the SALP
period has resulted in the development of an
,
effective methodology which is environmentally
I acceptable.
l
l
l 4. Page 26, 2nd 1 In discussing problems identified in
'
(Section IV.I.1) environmental qualification and procurement
control, the report states, "The licensee has
been slov to acknowledge and correct some of
these problems." APCo disagrees with this
conclusion. Where it could be demonstrated
that problems existed, APCo's corrective
action vas taken in a timely manner. It vould
appear that APCo's efforts to explore
inspection findings as tc their validity has
been interpreted as slov acknowledgment and
l
corrective action.
l
5. Page 26, 4th 1 The report states, "In January 1988. the
(Section IV.I.1) proposal to install a vent on the 2B charging
pump suction line van canceled." No proposal
was canceled. A design change was voided as a
i
result of concerns over the adequacy of the
l
proposed design to vent the accumulated
hydrogen and the fact that operational
practices had been adopted to prevent adverse
,
I
l affects to the 2B pump.
The report further states, "The licensee had
been avare of this problem since 1979 but had
not instituted permanent corrective action
other than running or venting the pump."
Contrat u_ this assertion, APCo was not aware
of the(total problem since 1979. This
incorrec erception on the part of the Staff
I was discussed at length in the enforcement
conference.
l
l
l
.'
+
'
- *
. l988 SALP C:mm:nts
NRC Inspection Report No.
50-348/88-04 and 50-364/88-04
Page 3
No. Reference Comment
6. Page 32, 1st & 2nd 1 The report draws conclusions regarding the
(Section IV.L.1) environmental qualification program which APCo
disagrees sith. Whereas the SALP is not an
appropriate forum to thoroughly discuss the
difference of opinions on environmental
qualification, the following concerns are
highlighted:
1. The report states that inspections
found the environmental qualification
program to be carginal during the
early development stages. To the
contrary, correspondence and the NRC
SER seem to indicate the
environmental qualification program
was satisfactory in the early
development stages.
2. The report states that inadequate
staffing was a contributor to
environmental qualification
deficiencies. APCo does not agree
that inadequate staffing was
provided.
3. The report cites "extensive use of
unqualified tseminal blocks in
instrument circuits inside
containment". The issue'on terminal
blocks has bewn thoroughly discussed.
APCo has maintained the blocks vere
qualified but the issue regarding
instrument inaccuracy could not be
resolved until the blocks vere
replaced with qualified splices,
4. It is inappropriate to cite the issue
of upgrade of equipment qualification
in accordance with 10 CFR 50.49(1) in
the SALP report. This issue resulted
from misunderstanding and
miscommunication on behalf of both
APCo and the NRC. It is not
indicative of a programmatic
breakdown in engineering support.
w __ _ _