ML20132B043

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
Download: ML20132B043 (12)

See also: IR 05000729/2008002

Text

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4 KEco UNITED STATES

,o NUCLEAR REGULATORY COMMISSION

,y .n REGION li

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j 101 MARIETTA STREET, N.W.

2 ATLANTA, GEORGI A 30323

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Report Nos. 50-348/85-32 and 50-364/85-32

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 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 program.

Results: Two violations were identified - Design' . Changes caused by Plant

Activities / Work Items and Special Test Program Noncompiiance with Technical

Specification (TS).

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8509260000 850920

PDR ADOCK 05000340

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REPORT DETAILS

1. 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

• 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,

paragrapS 4.a.

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,

Criterion III

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(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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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,

[ Revision 6

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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, 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;

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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 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

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members in the performance of their duties. The inspector reviewed these

draft copies.

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 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

approved.

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Design reviews required by Technical Specifications were performed.

Plant drawings were updated to reflect the design change or modifica-

tion.

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.

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The activity / work complies with recognized industry standards and good

engineering practices.

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

criteria:

The activity / work must comply with plant design and installation

specification.

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 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 N45.2.11. 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

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 criteria.

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

(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 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

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 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,

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 exist.

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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 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,

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Revision 0

FNP-1-STP ,33.2 Reactor Trip Breaker Train B Operability Test,

Revision 5.

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 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 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 6.5.3.1.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)

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

for Nuclear Power Plants

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(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 Specifications. 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

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Operations Quality Assurance Manual, Revision 22

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

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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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