IR 05000348/1985032

Insp Repts 50-348/85-32 & 50-364/85-32 on 850729-0802. Violation Noted:Failure to Include Measures in FNP-0-AP-8 to Assure That Minor Departure from Design Meets Existing Regulatory Requirements

ML20132B043
Person / Time
Site:	Farley
Issue date:	09/16/1985
From:	Belisle A, Casey Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20132B015	List: IR 05000348/1985032 ML20132B011 ML20132B031 ML20132B043
References
50-348-85-32, 50-364-85-32, NUDOCS 8509260088
Preceding documents:	ML20205F953 (6 November 1985)
Download: ML20132B043 (12)

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4 KEco UNITED STATES

,o NUCLEAR REGULATORY COMMISSION

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j 101 MARIETTA STREET, ATLANTA, GEORGI A 30323

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Report No /85-32 and 50-364/85-32 Licensee: Alabama Power Company 600 North 18th Street Birmingham, AL 35291 Docket No and 50-364 License Nos.: NPF-2 and NPF-8 Facility Name: Farley 1 and 2 Inspection Conducted: July 29 - August 2, 1985 In spector_: e_ , ')46 /

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Accompanying Personnel: R. Moore, Region II

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Approved by

A. BeYisle, Actinfs[hief 4 -[ f-/d -O

'Date Signed

Quality , Assurance Programs Section j Division of Reactor Safety SUMMARY Scope

This routine, unannounced inspection entailed 73.5 inspector-hours on site in the areas of design control program, test and experiments program, and quality assurance / quality control (QA/QC) administration progra Results: Two violations were identified - Design' . Changes caused by Plant Activities / Work Items and Special Test Program Noncompiiance with Technical Specification (TS).

t 8509260000 850920 PDR ADOCK 05000340 0 PDR I

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REPORT DETAILS Persons Contacted Licensee Employees R. Badham, SAER Engineer

• C. Buck, Design S~upport Supervisor W. Coggins, FDS Supervisor PMD

• R. Coleman, Systems Performance Supervisor G. Dykes, lead Electrical Engineer PMD

• D. Morey, APM-0PS

• C. Nesbitt, Technical Superintendent C. Sheehan, General Plant Engineer (GPE-3)

W. Shores, Power Plant Specialist / Technician

• M. Stinson, Plant Modification Supervisor.

• L. Ward, Maintenance Superintendent

• W. Ware, SAER Supervisor

• G. Waymire, General Plant Engineer (GPE-1)

R. Winkler, Supervisor, Modification, Evaluation and Testing Section

• J. Woodward, APCO-Plant Manager NRC Resident In'spectors

• Bradford

• B. Bonser

• Attended exit interview Exit Interview The inspection scope and findings were summarized .on August 2,1985, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection findings listed below. Dissenting comments were received from the licensee regarding the two violations identified during this inspectio Violat:on, Design Changes Caused By Plant Activities / Work Items, paragrapS Violation, Spec'al Test Program Noncompliance With TS, paragraph Inspector Folicwup Item, Section Instructions for the Plant Modifica-tion and Maintenance Support Group, paragraph The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio , .- , ,

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3. Licensee Action on Previous Enforcement Matters This subject was not addres. sed in the inspectio . Design Changes (37702)

References: (a) 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, Criterion III

(b) Regulatory Guide 1.64, Quality Assuranc'e Requirements for the Design of Nuclear Power Plants, Revision 1 (c) ANSI N45.2.11-1974, Quality Assurance Requirements for

, the Design of Nuclear Power Plants (d) Regulatory cuide 1.33, Quality Assurance Requirements (Operations), November 1972 (e) ANSI N18.7-1972, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (f) 10 CFR 50.59, Changes, Tests and Experiments (g) . Technical Specifications, Section 6.5, Review and Audit The int.pector reviewed the licensee. design change program required by references (a) through (g) to determine if these activities were conducted in accordance with regulatory requirements, industry guides and standards, and Technical Specifications. The following criteria were used during the review to assess the overall acceptability of the establ'ished program:

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Were procedures established to control design changes which include assu ance that a proposed change does not involve an unreviewed safety question or a change in Technical Specifications as required by 10 CFR 50.59?

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Were procedures and responsibilities for design control established including ~ responsibilities and methods for conducting safety evaluations?

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Were administrative controls for design document control established for the following:

Controlling changes to approved design change documents, Controlling or recalling obsolete design change documents such as revised drawings and modification procedures,

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l Release and distribution of approved design change documents? l

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Were administrative controls and responsibilities 'establi shed commensurate with the time frame for implementation to assure that design changes will be incorporated into:

Plant procedures, Operator training programs, Plant drawings to reflect implemented design changes and modifications?

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Did design controls require that implementation will be in accordance with approved procedures?

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Did design controls require assigning responsibility for identifying post-modification testing requirements and acceptance criteria in approved test procedures and for evaluation of test results?

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Did procedures assign responsibility and delineate the method for reporting design changes to the NRC in accordance with 10 CFR 50.59?

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Did controls require review and approval of temporary modifications in accordance with Section 6 of the TS and 10 CFR 50.59?

The documents listed below were reviewed to determine if these criteria had ~

been incorporated into the licensee design change program:

FSAR Chapter 17.2) d esign Control Operations Quality Assurance Manual '

Design Control, Chapter 3 Corrective Action, Chapter 16 FNP-0-AP-8, Design Modification Control, Revision 10 FNP-0-AP-7, Corrective Action Reporting, Revision 8 GO-NG-11, Procedure for Design Change and Design Control, dated December 11, 1984 GO-NG-10, Corrective Action, dated November 5, 1984 FNP-0-AP-13, Control of Temporary Alteration, Revision 1 FNP-0-AP-52, Equipment Status Control and Maintenance Authorization,

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The inspector interviewed licensee onsite Safety Audit and Engineering Review (SAER) staff to determine their involvement in the performance of audits in the functional area of plant modifications. The following audit reports were reviewed by the inspector: }

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Report of SAER Audit dated October 16, 1984: General area audited, Plant Modifications; Date(s) of audit, September 7 - Octaber 15, 198 Report of SAER Audit dated November 17, 1983: General a ea audited, Plant Changes and Modifications; Date(s) of Audit, September 6 -

November 15, 198 The audit cor ducted September 7 - October 15, 1984, identified two items of noncompliance in the Minor Departure from Design Program. The first concerned failure of the Plant Operating Review Committee (PORC) to review ,

the Minor Departure Recommended Disposition and Safety Evaluation Checklist within the established 90 days of implementation approva The second addressed the failure of the implementation superintendents to verify completion of the approved disposition of design changes implemented under the Minor Departure from Design Program, within one year of the imple-mentation approval date. The inspector was informed by licensee personnel that corrective action had been initiated for these audit noncompliance The licensee es'tablished a plant Modification and Maintenance Support (PMD)

group on sit Administrative procedure FNP-0-AP-70, Conduct of Operations - Plant Modifications and Maintenance, is the controlling

, procedure for activities conducted by this group. This procedure describes the organizational structure, organizational responsibilities, administra-tive controls and personnel qualifications for the PMD Group staff member The following are among the responsibilities assigned to this group:

Production Change Request (PCR) Review;

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Minor Departure from Design Review; Production Change Notice (PCN), Review and Engineering Evaluation; Plant Staff Design Development; Functional Testing of Design Change The inspector conducted interviews with . selected staff members of the PMD group to ascertain their involvement in the design program, and their understanding of the program requirements as delineated in administrative procedure FNP-0-AP-8. In response to the inspector's inquiry, staff members stated that their involvement in the Minor Departure from Design Program consisted of the post-implementation design review. All staff members were knowledgeable of the design modification controls contained in FNP-0-AP- The Supervisor-PMD had prepared draft copies of section instructions intended to provide detailed guidance not contained in FNP-0-AP-8 to staff

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members in the performance of their dutie The inspector reviewed these draft copie The following PCNs were examined to verify that selected elements.of the design change program were being implemented as specified by procedures:

PCN Number BS1-2-2168, Charging Pump Auto Start, Revision 3 PCN Number BS3-2449, Alternate Shutdown Capability - Appendix R, Revision 15 PCN Number 984-1-2784, Defeated the Signal Which Starts Diesel Generators 1C and 2C on Low Pond Level, Rev'ision 0 PCN Number B33-1421, Added Shunt Trip Attachments to the Reactor Trip Breakers, Revision 0 The inspector verified that the following requirements were incorporated in the documentation associated with each PCN package:

The design change request was reviewed and approved as require Design input requirements were specified, reviewed, and approve Independent design verifications were performed as require Post-modification acceptance tests were performed as required and designated acceptance criteria were me Any changes to the [ design documents were properly reviewed and approve ,

Design reviews required by Technical Specifications were performe Plant drawings were updated to reflect the design change or modifica-tio Plant procedures were updated to reflect the design change The training organization was made aware of the modification Administrative procedure FNP-0-AP-8 paragraph 16.0, delineates the programmatic controls for the processing of any activity / work item which is a change from approved design documents. These activities are p.rocessed as Minor Departures from Design and may either be permanent or temporary. The following criteria are evaluated by the responsible plant supervisor to determine if a Minor Departure fron Design activity will be temporar The activity / work does not change the basic function of the structure, system or component involve *

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The activity / work complies with recognized industry standards and good engineering practice The activity / work will not cause degradation of performance require-ments such as capacity, response times, et The activity / work will not require a change to the Plant TS To determine if a change can be implemented as a permanent Minor Departure from Design, the plant supervisor evaluates the following additional criteria:

The activity / work must comply with plant design and installation specificatio The activity / work must comply with codes, standards or regulatory requirements applicable to the original plant desig Within this area one violation and one inspector followup item were identified and are discussed in the following paragraph Design Changes Caused by Plant Activities / Work Items Technical' Specification 6.5.3.1.b. requires'that proposed modifications to plant nuclear safety-related structures, systems, and components be approved prior to implementation-by the plant manager. The accepted QA program, FSAR Chapter 17.2.3, requires that design changes and modifications during plant operations be handled in a manner which will comply with the requirements of ANSI N45.2.1 Paragraph 8.0 of this standard requires that design changes be subjected to design control measures commensurate with those applied to the original desig The minor departure from design program is intended for processing plant work / activities which results in changes to design document These changes can be permanent or temporary as previously discusse According to FNP-0-AP-8, the cognizant plant supervisor approves Minor Departure from Design requests prior to implementation. This request is also r.eviewed within 90 days of implementation by the Plant Operations Review Committee to determine if an unreviewed safety

. question exists because of the implemented design change. After the Minor Departure from Design is implemented, a review is performed by the PMD grou Existing administrative controls for Minor Departure from Design do not require:

Prior implementation approval by the plant manager, Design changes (Minor Departure from Design) be subject to those measures commensu' rate with those applied to the original design,

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Scope of activities under which a Minor Departure from Design can be used, Requirements for post-implementation functional tests and test acceptance criteri The failure to include measures to assure that a Minor Departure from design meets existing regulatory requirements is identitled as violation 348/85-32-01 and 364/85-32-0 Section Instructions for the Plant Modification and Maintcnance Support (PMD) Group The licensee has established a PMD Group onsite with responsibilities in the PCR/PCN program area. Administrative procedure FM 0-AP-8 is the controlling procedure for design modification control and delineates the program requirements of the PCR/PCN progra The licensee has identified a need to supplement the administrative controls delineated in FNP-0-AP-8 with section instructions, intended to provide guidence to PMD staff members in the performance of their duties. The inspector reviewed unapproved ciraft copies of section instructions. Until the licensee incorporates the section instructions into the P,CR/PCN program, this is identified as Inspector Followup Item 348/85-32-03 and 364/85-32-0 . Test and Experiments Program (37703)

References; (a) 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants

.(b) 10 CFR Part 50.59, Changes, _ Tests and Experiments (c) Technical Specification, Section 6.5, Review and Audit (d) Regulatory Guide 1.33, Quality Assurance Requirements (Operations) November 1972 (e) ANSI N18.7-1972, Administrative Controls and Quality Assurance for the Operational Phase' of Nuclear Power Plants The inspector reviewed the licensee test and experiment program required by references (a) thro' ugh (e) to determine- if the program was in conformance with regulatory requirements and i t.dustry guides and standards. The following criteria were used during this review to assess the overall acceptability of the established program:

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Was a formal method established to handle all requests or proposals for conducting plant tests involving safety-related components?

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Were provisions made to assure that all tests will be performed in accordance with approved written procedures?

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Were responsibilities assigned for reviewing and approving test procedures?

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Was a formal system, including assignment of responsibility, established to assure that all proposed tests will be reviewed to determine whether they are as described in the FSAR?

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Were responsibilities assigned to assure that a written safety evaluation required by 10 CFR 50.59 will be developed for each test to assure that it does not involve an unreviewed safety question or a change in Technical Specifications?

The documents listed below were reviewed to determine if these criteria had been incorporated into the licensee test and experiments progra FSAR Chapter 17.2.11, Test Control Operations Quality Assurance Manual Instructions Procedures, Drawings, Chapter 5 Test Control, Chapter 11 FNP-0-AP-24, Test Control, Revision 2 FNP-0-AP-1, Development,. Review, and Approval of Plant Procedures, Revision 7 FNP-0-AP-3, Plant Organization and Responsibility, Revision 6

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FSAR Chapter 14.0, Initial Tests and Operations l FSAR Chapter 13.5, Plant Procedures

~The inspector reviewed the licensee test and experiment program documents to assess the program scope and content. The inspector determined that a test program had been established to assure that all testing required to

. -demonstrate satisfactory operation of in-se.rvice critical .sy s tems ,

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structures, and components had been identified and that these tests were performed in accordance with approved written procedures. The inspector also verified that written safety evaluations required by 10 CFR -50.59 were developed fer tests to assure that unreviewed safety questions or changes to TS do not exis _ _

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Audits conducted by the SAER staff were reviewed by the inspector to verify the degree of involvement of the staff in this functional are The following are the specific audits reviewed:

Report of SAER Audit. dated April 26, 1983: General Area Audited, Test Control; Da.tes of Audit, March 9 - April 7, 1983 Report of SAER Audit dated April 30, 1984: General Area Audited, Test Control; Dates of Audit, March 26 - April 27, 1984 Report of SAEP Audit dated April 14, 1985: General Area Audited, Test Control; Dates of Audit, February 25 - April 2,198 The licensee annual operating report required by 10 CFR 50.59, transmitted by letter dated March 29, 1985, from R. P. Mcdonald to Dr. J. N. Grace, Administrator, U.S.N.R.C. . was used as the basis for selecting completed test packages for review. The following test packages were reviewed to verify conformance with written procedures:

FNP-1-ETP-134, Performance of Service Water Flow Verification Test,

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Revision 0 FNP-1-STP ,3 Reactor Trip Breaker Train B Operability Test, Revision FNP-1-ETP-4140, 1B Component Cooling Water Heat Exchanger Leak Detection, Revision Within this area, one violation was identified. Pursuant to the review of the above test packages the inspector identified that one special test package, FNP-1-ETP-4140, was performed without the plant manager's approva This does not meet TS 6.5.3.1.c requirements in that proposed tests and experiments which affect plant . nuclear safety and are not addressed in the FSAR are required to be approved by the plant manager before implementatio Licensee management sta'.ed that this test was erroneously classified on the Procedure Request Form as a special test, consequently, approval by the plant manager was not require Hov,ever, further investigation by the inspector identified the apparent root cause of the problem to be a deficiency in procedure FNP-0-AP- Paragraph 5.4.1 of this procedure defines which documents require the plant manager's approval. This paragraph does not establish measures to ensure that the requirements of TS Section 6.5.3.1.c are implemente Special tests are defined in 10 CFR 50.59. as tests which impact nuclear safety and which are not described in the safety analysis report. The TS requires that special tests be approved by the plant manager before implementation. The licensee controlling procedure for the development, review and approval of plant procedures does not establish measures to l

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ensure that the requirements of the TS are implemente This failure to establish measures to ensure approval of special tests by the plant manager before implementation as required by the TS is identified as violation 384/85-32-02 and 364/85-32-02, QA/QC Administration (35751)

References: (a) 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power plants and Fuel Reprocessing Plants (b) Regul ato ry Guide 1.28, Quality Assurance Program Requirements (Design and Construction)

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(c) ANSI N45.2-1971, Quality Assurance Program Requirements for Nuclear Power Plants

(d) Technical Specifications, Section 6, Administrative Controls The inspector reviewed the licensee QA/QC administration program required by References (a) through (d) to determine if QA/QC administration requirements were conducted in accordance with regulatory requirements, industry guides or standards, and Technical Specification The following criteria were used for this review:

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Did QA program documents clearly identified those structures, systems, components, documents, and activities to which the QA program applies?

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Were procedures and responsibilities established for making changes to QA program documents?

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Did the licensee establish administrative controls for QA/QC procedures which assure procedure review and approval prior to .

implementation, control of changes and revisions, and methods and control for distribution and recall?

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Were responsibilities established to assure overall review of the effectiveness of the QA program?

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Did methods exist to modify the QA program to provide increased emphasis on identified problem areas?

The documents listed below were reviewed to determine if these criteria had been incorporated into QA/QC' administration activities:

FSAR Chapter 17.3, Quality Assurance Q-Lis,t

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FNP-0-AP-31, Quality Control Measures, Revision 7 l

Operations Quality Assurance Manual, Revision 22 l

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SAER-AP-02, Development and Implementation of Procedural Guidance,

Revision 9 SAER-AP-03, Control of Guidance Documents, Revision 9 SAER-AP-09, Corrective Action, Revision 9 SAER-AP-11, Summaries and Analysis of Audit Results, Revision 9 Composite Audit Report No. 85-07, 4-month Interval, March 29, 1985

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Within this area, no violations or deviations were identified.

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