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NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
|Download: ML20132B043 (12)|
See also: IR 05000729/2008002
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4 KEco UNITED STATES
,o NUCLEAR REGULATORY COMMISSION
,y .n REGION li
j 101 MARIETTA STREET, N.W.
2 ATLANTA, GEORGI A 30323
Report Nos. 50-348/85-32 and 50-364/85-32
Licensee: Alabama Power Company
600 North 18th Street
Birmingham, AL 35291
Facility Name: Farley 1 and 2
Inspection Conducted: July 29 - August 2, 1985
In spector_: e_ , ')46 /
Accompanying Personnel: R. Moore, Region II
- Approved by
A. BeYisle, Actinfs[hief
4 -[ f-/d -O
- Quality , Assurance Programs Section
j Division of Reactor Safety
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 program.
Results: Two violations were identified - Design' . Changes caused by Plant
Activities / Work Items and Special Test Program Noncompiiance with Technical
PDR ADOCK 05000340
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1. Persons Contacted
R. Badham, SAER Engineer
- C. Buck, Design S~upport Supervisor
- 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
- W. Bradford
- B. Bonser
- Attended exit interview
2. 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 inspection.
Violat:on, Design Changes Caused By Plant Activities / Work Items,
Violation, Spec'al Test Program Noncompliance With TS, paragraph 5.
Inspector Folicwup Item, Section Instructions for the Plant Modifica-
tion and Maintenance Support Group, paragraph 4.b.
The licensee did not identify as proprietary any of the materials provided
to or reviewed by the inspectors during this inspection.
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3. Licensee Action on Previous Enforcement Matters
This subject was not addres. sed in the inspection.
4. Design Changes (37702)
References: (a) 10 CFR 50, Appendix B, Quality Assurance Criteria for
Nuclear Power Plants and Fuel Reprocessing Plants,
(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
(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:
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
Were procedures and responsibilities for design control established
including ~ responsibilities and methods for conducting safety
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,
Release and distribution of approved design change documents? l
Were administrative controls and responsibilities 'establi shed
commensurate with the time frame for implementation to assure that
design changes will be incorporated into:
Operator training programs,
Plant drawings to reflect implemented design changes and
Did design controls require that implementation will be in accordance
with approved procedures?
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?
Did procedures assign responsibility and delineate the method for
reporting design changes to the NRC in accordance with 10 CFR 50.59?
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,
[ Revision 6
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: }
Report of SAER Audit dated October 16, 1984: General area audited,
Plant Modifications; Date(s) of audit, September 7 - Octaber 15, 1984.
Report of SAER Audit dated November 17, 1983: General a ea audited,
Plant Changes and Modifications; Date(s) of Audit, September 6 -
November 15, 1983.
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 approval. 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 noncompliances.
The licensee es'tablished a plant Modification and Maintenance Support (PMD)
group on site. 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 members.
The following are among the responsibilities assigned to this group:
Production Change Request (PCR) Review;
Minor Departure from Design Review;
Production Change Notice (PCN), Review and Engineering Evaluation;
Plant Staff Design Development;
Functional Testing of Design Changes.
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-8.
The Supervisor-PMD had prepared draft copies of section instructions
intended to provide detailed guidance not contained in FNP-0-AP-8 to staff
members in the performance of their duties. The inspector reviewed these
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,
PCN Number 984-1-2784, Defeated the Signal Which Starts Diesel
Generators 1C and 2C on Low Pond Level, Rev'ision 0
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 required.
Design input requirements were specified, reviewed, and approved.
Independent design verifications were performed as required.
Post-modification acceptance tests were performed as required and
designated acceptance criteria were met.
Any changes to the [ design documents were properly reviewed and
Design reviews required by Technical Specifications were performed.
Plant drawings were updated to reflect the design change or modifica-
Plant procedures were updated to reflect the design changes.
The training organization was made aware of the modifications.
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 temporary.
The activity / work does not change the basic function of the structure,
system or component involved.
The activity / work complies with recognized industry standards and good
The activity / work will not cause degradation of performance require-
ments such as capacity, response times, etc.
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
The activity / work must comply with plant design and installation
The activity / work must comply with codes, standards or regulatory
requirements applicable to the original plant design.
Within this area one violation and one inspector followup item were
identified and are discussed in the following paragraphs.
a. Design Changes Caused by Plant Activities / Work Items
Technical' Specification 18.104.22.168.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 N45.2.11. Paragraph 8.0 of this
standard requires that design changes be subjected to design control
measures commensurate with those applied to the original design.
The minor departure from design program is intended for processing
plant work / activities which results in changes to design documents.
These changes can be permanent or temporary as previously discussed.
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 group.
Existing administrative controls for Minor Departure from Design do not
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,
Scope of activities under which a Minor Departure from Design can
Requirements for post-implementation functional tests and test
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 364/85-32-01.
b. Section Instructions for the Plant Modification and Maintcnance Support
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 program. 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 364/85-32-03.
5. 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
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:
Was a formal method established to handle all requests or proposals for
conducting plant tests involving safety-related components?
Were provisions made to assure that all tests will be performed in
accordance with approved written procedures?
Were responsibilities assigned for reviewing and approving test
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?
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 program.
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,
FNP-0-AP-3, Plant Organization and Responsibility, Revision 6
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 ,
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 exist.
Audits conducted by the SAER staff were reviewed by the inspector to verify
the degree of involvement of the staff in this functional area. 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 2,1985.
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,
FNP-1-STP ,33.2 Reactor Trip Breaker Train B Operability Test,
FNP-1-ETP-4140, 1B Component Cooling Water Heat Exchanger Leak
Detection, Revision 0.
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 approval.
This does not meet TS 22.214.171.124.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 implementation.
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 required.
Hov,ever, further investigation by the inspector identified the apparent root
cause of the problem to be a deficiency in procedure FNP-0-AP-1.
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 126.96.36.199.c are implemented.
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
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ensure that the requirements of the TS are implemented. 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,
6. 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)
(c) ANSI N45.2-1971, Quality Assurance Program Requirements
for Nuclear Power Plants
(d) Technical Specifications, Section 6, Administrative
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 Specifications. The following criteria were
used for this review:
Did QA program documents clearly identified those structures, systems,
components, documents, and activities to which the QA program applies?
Were procedures and responsibilities established for making changes to
QA program documents?
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?
Were responsibilities established to assure overall review of the
effectiveness of the QA program?
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
FNP-0-AP-31, Quality Control Measures, Revision 7
Operations Quality Assurance Manual, Revision 22
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SAER-AP-02, Development and Implementation of Procedural Guidance,
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
Within this area, no violations or deviations were identified.
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