IR 05000313/1972013
| ML19320A093 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 01/10/1973 |
| From: | Kidd M, Murphy C, Warnick R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19320A080 | List: |
| References | |
| 50-313-72-13, NUDOCS 8004140701 | |
| Download: ML19320A093 (23) | |
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ATOMIC ENERGY COMMIS510N
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DIRECTORATE OF REGULATCRY C?Z3ATIC::S
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404s 9as.asos ATLA NT A, GEC AGI A 30303 RO Inspection Report No. 50-313/72-13 l
Licensee: Arkansas Power and Light Company i
Sixth and Pine Strt2ts Pine Bluff, Arkansas 71601 Facility Name: Arkansas Nuclear One, Unit 1
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Docket No.:
50-313 License No.:
CPPR-57 Category:
B1 Location: Russellville, Arkansas Type of License: B&W, PWR, 880 Mwe Type of Inspection: Routine, Unannounced Dates of Inspection: Novenber 28 through December 1, 1972 s
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d Dates of Previous Inspection: Octob'er 16-19, 1972 Inspector-In-Charge:
M. S. Kidd, Reactor Inspector Facilities Test and Startup Branch Accompanying. Inspectors: None
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Other Accompanying Personnel: None Principal Inspector:
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R. F. Warnick, Reactor Inspector Facilitie Test and Startup Branch r/.I.
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Reviewed By:
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s C. E. Murphy,L Acting Chief Date
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Facilities Test and Startup Branch 8004140 70(
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RC Inspection Report No. 50-313/72-13-2-
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SUMHARY OF FINDINGS I.
Enforcement Action A.
Violations 1.
Section 1.6.7.1.b.1 of the Final Safety Analysis Report (FSAR) states, in part, that during the phase of the preoperational test program in which procedures are developed, "... Completed test specifications and test procedures are reviewed by members of the Test Working Group (TWG). After their review and approval, they are submitted to AP&L for final review and approval..
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Contrary to this requirement, ths inspector determined through review of test procedure approval records and
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l discussions with licensee personnel, that test procedure
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TP 400-03, "A-C Power Systems Energization Procedure,"
approved May 3, 1972, was not reviewed and approved by the TWG.
(See Details, paragraph 3)
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B.
Safety Items N ne o
II.
Licensee Action on Previous 1v Identified Enforcement Matters A.
Violations
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1.
Conduct.of Preoperational Tests Without an Approved Admin-istrative Plan Covering the Activities.
(See R0 letter of
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October 19, 1972, Enclosure 1, Item 1.)
A reply (November 17, 1972) to the letter has been received. The Plan For Preoperational Testing, OP 1004.09, was approved September 25, 1972.
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This matter is considered resolved.
(See Details, paragraph 4.e.)
2.
Approval of a Test Procedure Containing Acceptance Criteria not in Agreement with FSAR Values.
(See R0 letter of October 19, 1972, Enclosure 1, Item 2.)
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R0 Rpt. No. 50-313/72-13-3-
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A reply (November 17, 1972) to the letter has been received. Also, the specific acceptance criteria for core flood tank level alarms were revised per FSAR Amendment 31, dated November 15, 1972, such that those in test procedure 201.03, " Core Flooding System Functional Test," are now more conservative than the FSAR values.
This item is' resolved.
(See Details, paragraph 4.f.)
3.
Failure to Maintain Documentation which Accurately Reflects the Construction and Test Status of Equipment.
(See RO letter of October 19, 1972, Enclosure 1, Item 3.)
This item will be reviewed further during subsequent inspections.
(See Details, parsgraph 4.g)
4.
Lack of Participation by the Station Test Coordinator (STC)
in the Development of Test Procedures.
(See R0 letter of October 19, 1972, Enclosure 1, Item 4.)
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A reply (November 17, 1972) has been received. Amendment 31
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to the FSAR (November 15, 1972) now reflects the fact that the STC does not ' develop the test procedure. This specific matrTr is resolved.
(See Details, paragraph 4.h.)
5.
Environmental Monitoring Program Differing from F3AR Description.
(See RO letter of December 8, 1972, Item 1.)
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Evaluation of corrective action on this matter has not been completed by the inspector.
B.
Safety Items
l There are no previously identified safety items.
III.
New Unresolved Items
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None IV.
Status of Previous 1v 2eported Unresolved Items A.
Administrative Control Procedure Coverage Three of the five comments covering administrative controls documented in R0 Report No. 50-313/72-5,Section II, paragraph 3, Ws d
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have been incorporated in the Plan for Preoperational Testing (Plan) and are therefore resolved. The other two comments will be discussed further.
(See Details, paragraph 4.a.)
B.
Onsite Training Program for Licensed and Unlicensed Personnel Implementation of the training program for licensed and un-licensed personnel, discussed in RO Report No. 50-313/72-6,Section II, paragraph 2, has not been completed.
This matter will be reviewed during subsequent inspections.
(See Details, paragraph 5)
C.
Staffing Commitments Not Yet Met This unresolved item was initially discussed in R0 Report No. 50-313/72-6,Section II, paragraph 3.
Progress on staffing has not been made; however, this matter will remain open.
(See Details, paragraph 2.b.)
s D.
Incorporation of all Safety Related Equipment in the FSAR Q-List
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This unresolved item identified in RO Report No. 50-313/72-9,Section II, paragraph 3, was discussed.
No resolution has been made.
(See Details, paragraph 4.1.)
E.
Lack of Documentation of the STC's Prerequisite Duties in t' ass Conduct of Tests
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This unresolved item was initially discussed in R0 Report No.
50-313/72-9,Section III, paragraph 3.a.
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Licensee personnel have devised a plan for documenting the performance of these duties. More evaluation will be required.
(See Details, paragraph 4.j.)
F.
Jumper and Bypass Control and Authorization
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Specific areas of concern discussed in RO Report No. 50-313/72-9,Section III, paragraph 3.d., have been resolved by inclusion of additional information in the Plan.
(See Details, paragraph 4.k.)
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ROReportNo[ 50-313/72-13 5-
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G.
Administration of Test Program - Conflict Between FSAR and Plan Amendment 31 (November 15, 1972) to the FSAR resolved this problem which was initially identified in RO Report No.
50-313/72-9,Section III, paragraph 3.6.
(See Details, paragraph 4.1.)
H.
Definition of Ch'anges to Test Procedures Comments on this matter documented in RO Report No. 50-313/72-9,
Section III, paragraph 3.e, have been resolved by a new revision to the Plan.
(See Details, paragraph 4.m.)
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- I.
Preparation of Test Procedures to Cover Tests in Guide for j
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Planning of Preoperational Test Programs This matter, identified in RO Report No. 50-313/72-9,Section IV,
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paragraph 4, will be discussed further.
(See Details, paragraph 4.n.)
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Review of Test Procedures for Inclusion of FSAR Requirements
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l This unresolved item was initially discussed in R0 Report No.
50-313/72-10, Details I, paragraph 4.
More discussion will be required.
(See Details, paragraph 4.o.)
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V.
Unusual Occurrences
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None VI.
Other Significant Findings A.
Troject Status Licensee personnel estimate the construction of Unit 1 to be 91% complete.
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Portions of the following additional systems have been turned over to AP&L since the previous inspection:
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Computer and Control Rooms Air Conditioning System
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Reactor Building Spray System Steam Generators Main Steam System Reheat Steam System Lube Oil System Main Turbine Electro-Hydraulic Controls
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RO Rpt. No., 50-313/72-13-6-s_s
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The total number of systems which are considered completely
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released (60% or greater)1/ from construction for testing now stands at 28.
Those which have been partially released (greater than 2% but less than 60%)l/ number 25.
No releases have been made on the remaining 16 systems.
Significant turnovers have been made by construction on those systems identified in previous reports as having been partially
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released.
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B.
Organizational and Personnel Changes 1.
Safety Review Committee (SRC)
The organization of the SRC has been restructured. Changes are reflected in Amendment 31 (November 15, 1972) to the FSAR.
(See Details, paragraph 2.a.)
2.
Personnel
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s An additional aux 1111ary operator has been hired. Three waste control operators are now needed to complete FSAR
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staffing requirements.
(See Details, paragraph 2.b.)
VII. Management Interview
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A.
A management interview was held at the conclusion of the
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inspection on December 1, 1972. Attendees included:
Arkansas Power and Light Company (AP&L)
J. W. Anderson - Plant Superintendent G. H. Millet - Assistant Plant Superintendent B. A. Terwilliger_ - Operations Supervisor C. A. Halbert.- Technical Support Engineer N. A. Moore - Chief Quality Assurance Coordinator D. N. Bennett - Quality Control Engine'er
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T. H. Cogburn - Procedure Administrator R. R. Culp - Test Administrator Bechtel Corporation (Bechtel)
R. J. Glover - Supervising Startup Engineer t
's 1/ Definitions used by Bechtel's Startup Group.
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RO Rpt. No. 50-313/72-13-7-B.
The following subjects were discussed:
1.
Enforcement Items The item under Enforcement Action was discussed in detail.
(See Details, paragraph 3)
I 2.
Previously Identified Enforcement Items
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l The inspector. stated that the following previously identified enforcement matters had been resolved during the inspection:
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a.
Conduct of Preoperational Tests Without an Approved Administrative Plan Covering the Activities (See Details, paragraph 4.e.)
b.
Approval of a Test Procedure Containing Acceptance Criteria not in Agreement with FSAR Values (See Details, paragraph 4.f.)
g c.
Lack of Participation by the STC in the Development of Test Procedures (See Details, paragraph 4.h.)
3.
Previously Identified Unresolved Items The inspector stated the following previously identified unresolved items had also been resolved during the inspection:
a.
Three of five comments on Administrative Controls Procedure Coverage (See Details, paragraph 4.a'.)
b.
Jumper and Bypass Control and Authorization (See Details, paragraph 4.k.)
c.
Administration of Test Program - Conflict Between FSAR and Plan (See Details, paragraph 4.1.)
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d.
Definition of Changes to Test Procedures (See Details, paragraph 4.m.)
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4.
Resolution of Comments on Procedure for Controlling the
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Preoperational Test Program (Plan)
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The inspector stated that comments on the Plan discussed in
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RO Report No. 50-313/72-6,Section II, paragraph 4, have been resolved by the latest revision to the Plan.
(See Details, paragraph 4.b.)
5.
Method of Handling Administrative, Joerating, Test, and Maintenance Procedures
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11e inspector stated that AP&L's system for handling procedures
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.has improved.
(See Details, paragraph 4.c.)
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6.
Spare Parts Program
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The inspector stated that his review of AP&L's reaudit of the spare parts program indicated that procedure OP 1004.05,
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"Q-List Spare Parts Quality Control Procedure," should be clarified to allow ordering spare parts without sending i
T specifications with each order if the vendor already has the latest specifications.
A licensee representative stated that heir intention in l
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writing the procedure was to si'_
31s and that the proce-
l dure would be revised.
(Sae Details, paragraph 4.d.)
7.
Comments on Test Procedures
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The inspector stated that he had reviewed three approved
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test procedures and had given detailed comments to AP&L's Test Administrator.
Each procedure needed more provisions for documentation of personnel performing procedural steps or documentation of data taken.
Specifically, TP 400-03,
"AC Pover Systems Energization Procedure," does not provide for recording data read.
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j A licensee representetive stated that the energization
procedure was of the type in which documentation of readings
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is not required.
(See Details, paragraph 3)
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RO Report'No. 50-313/72-13-9-8.
Personnel Training The inspector stated that he had reviewed the onsite j
training program and was disappointed that the formal training sessions that had been planned had not been completed. He also stated that current plans, if implemented, should provide the necessary training.
Licensee representatives expressed confidence in the
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adequacy of this training program as planned.
(See Details, paragraph 5)
9.
Staffing The inspector stated that this matter would be followed until staffing commitments are met.
A licensee representative stated that AP&L is interviewing applicants for the three waste control operator positions yet to be filled.
(See Details, paragraph 2.b.)
10.
Failure to Maintain Documentation which Accurately Reflects The Construction and Test Status of Eauipment
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The inspector stated that his review of this previously identified enforcement matter disclosed that some corrective action had been taken but chat more discussions will be l
necessary.
(See Details, paragraph 4.g.)
l 11.
Incorporation cf all Safety Related Equipment in the FSAR Q-List l
The inspector stated that this previously identified un-
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resolved item will require more discussions.
(See Details,
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paragraph 4.1.)
12. -Documentation of STC's Prerequisite Duties in the Conduct
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of Tests The insp2ctor acknowledged AP&L's proposals to resolve this previcusly identified problem and stated that this matter will be resolved upon inclusion of the proposals in the Plan and implementation of them.
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R0 Rpt. No. 50-313/72-13-10-
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m A licensee representative stated that the proposed method i
of documentation would be incorporated into the Plan.
(See Details, paragraph 4.j.)
13. Preparation of Test Procedures to Cover Tests in Guide for Planning of Preoperational Test Programs The inspector stated that more discussions will be needed
on certain of the test procedures which had been previously identified.
Licensee representatives expressed a desire to discuss thes'e further during the next inspection.
(See Details, paragraph 4 n.)
14. Differences in the Environmental Monitoring Program and Description in the FSAR
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The inspector acknowledged that Amendment 31 to the FSA" included revisions to the description of the environmental monitoring program which were designed to correctly describe the program.
In response to questions as to the resciution of this enforcement matter, the inspector statue hat evaluation
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of the amendment and response to the notice of violation has not been completed.
15. Review of Test Procedures for Inclusion of FSAR Requirenents a
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The inspector stated that this previously identified unre-solved item would require more discussion, particularly in regard to the scope of reviews performed by B&W and Bechtel.
(See Details, paragraph 4.o.)
t-16. Need for Procedures The inspector requested that he be provided copies of the following procedures as soon as they are approved.
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These copies would be returned to AP&L as soon as the inspector's reviews were completed.
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a.
Core loading procedure,
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Preoperational test procedure for leak detectiIon b.
system (s) which measure primary leakage, Ob
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RO Report No. 50-313/72-13-11-l c.
Power ascension test procedure covering shutdown from outside the control room, and j
d.
Power ascension test procedure for loss of offsite power.
i A licenses representative indicated that the above procedures
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would be provided.
(See Details, paragraph 6)
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R0 Report No. 50-313/72-13-12-
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/7, DETAILS Prepared By:
.4 ( c M. S. Kidd, Reactor
', Yate
Inspector, Facilities Test and Startup Branch Dates of Inspection: November 28 -
December 1, 1972 Reviewed By:
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C. E. Ifurphy, pttinJf-
/ Da'te Chief, Facilitids Test and Startup Branch 1.
Individuals contacted were the same as those listed as attendees to the Management Interview.
(See Section VI)
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2.
Organizational and Personnel changes a.
Safety Review Committee (SRC)
The following changes in the organization of the SRC are reflected in FSAR Amendment 31 (November 15, 1972).
(1) The Manager of Production Design and Construction has been replaced by the Director of Power Production on the committee.
Also, the Design and Construction Project Engineer has been added as a member.
(2) Members of the committee who are from the plant staff are now nonvoting. Also, alternate members (substitutes) are nonvoting.
b.
Personnel An additional auxiliary operator hr been hired, bringing the total to the required number of four. L.ree vaste control operators are -
now needed to meet FSAR staffing requirements. This item will be discussed in future inspections.
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R0 Rpt. No. 50-313/72-13-13-
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3.
Review of Test Procedures I
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Three approved preoperational test procedures were reviewed and resulting detailed comments given to the Test Administr2 tor.
Comments and responses l
are summarized below for each procedure.
a.
TP 400-03, "AC Power System Energization Procedure"
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(1) The procedure had not been reviewed by the TWG or SRC. Lack j
of review by the TWG is in violar'.on of the requirements of Section 1~.6.7.1.b.1 of the FSAR.
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(2) The procedure does not provide for documentation of data read-
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during the test.
(3) The procedure is lacking in acceptance criteria.
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(4) Step 5.5.2(b) refers co a " connected load." This should be defined. The inspector asked if this were intended to satisfy the loading of vital buses from normal power sources. Licensee representatives were of the opinion that the load testing would i
be done by another procedure, TP 410-24, " Emergency Diesel Generator
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Preoperational Test."
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In response to comments.1, 2, and 3, licensee representatives
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stated that this procedure had not been treated as a test pro-
cedure because it was a normal energization-type procedure and i
involved no safety related equipment.
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The inspector stated that since the procedure had been included in AP&L's listing of test procedures and had been identified
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distribution test in the Guide for the Planning of Preoperational
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Test Programs (VI, A), it must be reviewed by the TWG. Also, i
since the power distribution system which supplies vital a.c.,
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buses is tested in this procedure, it should be considered as
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safety related.
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A licensee representative informed the inspector by telephone
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on December'8, 1972, that the TWG had reviewed and approved
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TP 400.03 on that date. This matter will be reviewed during the next inspection.
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b.
TP 330-02, "CRD Control System Operational Test" (1) This procedure should make provisions for more documentation by
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the person (s) performing the test in Sections 3.1, 5.4, 6.1, 6.2, and 7.1.
(2) Instructions to notify the Shift Supervisor before starting work should be added to Section 5.
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Concerning comment (2), a licensee employee stated that most pro-cedures now contain this type of statement.
TP 330-03, "CRD Mechanism Functional Test" c.
(1) Comments (1) and (2) for TP 330-02 apply to this procedure also.
(2) Verification that each mechanis'm remained latched with one phase energized should be added to the list of specific acceptance criteria since this check is one of the purposes fN of the procedure. A licensee employee indicated agreement (/)
with this comment.
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4.
Review of Preoperational (Preop) Testing Pregram a.
Administrative Control Procedure Coverage
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Three of the comments concerning administrative controls documented
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in RO Report No. 50-313/72-5,Section II, paragraph 3, have been re-solved as follows:
(1) Comment: An administrative control procedure for the test pro -
gram had not been written.
Resolution: The Plan for Preoperational Test (Plan), OP 1004.09, has been written and approved.
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(2) Comment: There was no procedure covering lifted leads and jumpers.
Resolution: Control of lifted leads, jumpers and bypasses is covered in the Plan.
(3) Comment: There was no procedura describing control of defi-ciencies in procedures or equipment.
Resolution: These concerns have also been covered in the Pir.n.
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Comments concerning the Bechtel Startup Manual and system flushing procedures. require more evaluation and will be discussed again during the next inspection.
b.
Comment on the Plan Comments on the Plan documented in R0 Report No. 50-313/72-6,Section II, paragraph 4, have been resolved as follows:
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(1) - Comment : The procedure did not cover lifte1 leads or jumpers.
Resolution: The Plan now covers the use of lifted leads, jumpers, and bypasses.
(2) Comment: Test results should be properly reduced to meaning-ful and understandable form and be compared to previously determined performance standards or limits.
Resolution: Words similar to the comme.nt itself are included in the Plan.
(3) Comment: The plan should require that tests be rerun if system modifications are made or if results are felt to be unreliable.
Also the Plan shocid describe who will determine whether or not it is necessary to repeat a test and who will evaluate the results to verify adequacy of corrective actions.
Resolution: The Plan now assigns the above responsibilites to the TWG.
(4) Comment: Additional information should be provided for certain
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of the prerequisite STC duties in Section 6.1 of the Plan.
Resolution: Clarifying information has been added to the Plan.
(5). Comment: Additional Instructions should be given concerning the chronological log and what information is to be recorded.
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Resolution: Additional information on the chronological log has been included in the Plan. Specific types of information to be, recorded on this log have not been defined but the plan
does state, "This log will be in sufficient detail so that l
the events occuring during the test can be reconstructed and evaluated after the test."
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RG Rpt. No. 50-313/72-13-16-c.
Lack of an Approval Method for Ha'ndling Administrative. Operating 2
_
Test and Maintenance Procedures This area of concern was initially discussed during the July 1972 inspection.
(See R0 Report No. 50-313/72-6,Section II, paragraph 5)
.
Instructions for development, review, approval and use of test
.
procedures is now covered by the Plan, the latest revision of which was approved November 8,1972. Other procedures are covered by OP 1005.02, " Handling of Administrative, Operating and Maintenance Procedures."
This matter is considered resolved, d.
Spare Parts Program AP&L's audit of the spare parts program was discussed in R0 Report No.
50-313/72-6,Section II, paragraph 5.
The reaudit of this area performed October 6, 1972, revealed that deficiencies had been cor-rected. The inspector's study of the reaudit revealed that procedure OP 1004.05, "Q-List Spare Parts Quality Control Procedure," should be rewritten to allow ordering spare parts without sending specifica-tions with each order if the vender already has the latest specifications.
The procedure as now written requires that specifications be sent with every order. The inspector was informed that this was not
,
the ic* ant of the procedure and that the procedure would be revised to clarify this point.
This matter is resolved.
e.
Conduct of Tests Without an Approved Plan f
A rough version of the Plan was approved September 25, 1972.
An updated and improved revision was approved November 8, 1972.
~
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This previously identified enforcement matter is resolved.
'
!
f.
Approval'of a Test Procedure Cont-ining Acceptance Criteria Not in Agreement with FSAR Values
'
Differences in act.ptance criteria in 2P 201.03, " Core Flooding System Functional Test," and the FSAR description of the test were discussed in R0 Report No. 50-313/72-9,Section III, paragraph 2.
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RO Rpt. No. 50-313/72-13-17-
.
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.i-l The FSAR description of alarms tests (pg.13-3) now lists the
!
!
acceptance criteria for alarm actuation as the setpoint plus or minus 2%, such that the criteria in the rest procedure are now more restrictive than the FSAR. The FSAR change was made in
,
l Amendment 31, dated November 15, 1972.
This enforcement matter is considered resolved.
.
g.
Failure to Maintain Documentation which Accurately Reflects the Construction and Test Status of Equipment e
This item of noncompliance was discussed in RO Report No. 50-313/72-9,Section III, paragraph 1.
The inspector's review of corrective action taken revealed that the problems found in the release package for System No. 80, "Non-Nuclear Instrumentation," such as improperly
.
marked drawings, had been corrected. However, the problem of con-
'
flicting documentation in the package for System No. 56, " Integrated Control System," still existed.
(
This subject was discussed at the management interview and will be (
discussed further during the next inspection.
i h.
Lack of Participation by the STC in the Development of Test
Procedures
!
{
This violation of FSAR requirements was identified in RO Report No.
'
!
50-313/72-9,Section II, paragraph 3.
Originally, it was planned i
that the station staff and Bechtel STC's would develop the test
'
procedures. However, it was necessary to have this function per-
.
formed by others due to manpower and scheduling problems. All of
,
the ' test procedures are being written by B&W and Bechtel home
"
j office-type personnel.
,
'
FSAR Amendment 31 reflects the fac. that the STC does not write test procedures. This matter is considered resolved.
During discussions concerning input which the STC might have to a '
procedure if he finds it inadequate, the inspector was informed
.
that the precess of making minor and major revisions to a procedure as described in the Plan would be, and in fact, have been used to incorporate suggested improvements by the STC.
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R0 Rpt. No.'50-313/72-13-18-1.
Incorporation of All Safety Related Equipment in the FSAR Q-List This unresolved item was initially discussed in RO Report No.
50-313/72-9,Section II, paragraph 4.
The subject was discussed during this inspection but no resolution wcs made.
It will be discuased further during subsequent inspections.
j. Lack of Documentation of the STC's Prerequisite Duties in the Conduct of Tests
.
This item, discussed in R0 Report No. 50-313/72-9,Section III, para-
,
graph 3, was reviewed. AP&L plans to document performance of those duties such as checking that construction on the system is complete i
and the system has been properly tagged and released from construc-tion by including a checklist signed by the STC in the test procc-dure package. Also instructions for accomplishing the documenta-tion will be included in the Pl'2n.
,
This: matter will be resolved with incorporation of instructions in the Plan and implementation of the documentation.
k.
Jumper and Bypass control add Authorization l
The version of the Plan approved November 8, 1972, now states that t
jumpers and bypcasco may be used only with the approval of the Shift Supervisor. Also, a separate ' 2mper and bypass log will ba
'
maintained - for each test. The log will be posted in the control room until all jumpers and/or bypasses have been removed.
This item is resolved.
1.
Administration of Test Prc :-3 - Confligt Between FSAR and the-
Plan
!
I As discussed in RO Rep.ct No. 50-313/72-9,Section III, paragraph 3.c,
,
l the FSAR stated that the TWG would coordinate activities during
'
l preparation and review of test procedures where as the Plan l
assigned this function to the Test Administrator. Amendment 31 to i
l the FSAR resolved this discrepancy.
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Definition of Changes to Test Procedures
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The Plan now includes additions to a test as a major change to a procedure.
This item is resolved.
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R0 Rpt. No. 50-313/72-13-19-
.
.
n.
Preparation of Test Procedures to Cover Tests Listed in the Guide for the Planning of Preocerational Testing Programs As discussed in RO Report No. 50-313/72-9,Section IV, paragraph 4, there were nine tests for which AP&L had not identified test procedures to RO:II. The status of those tests are as follows:
(1) Emergency Coolin'g Systems - Demonstration That Boron Con-centration Can Be Properly Maintained, Adequate Samoling Techniques, Etc.
The inspector was informed that these tests are probably per-
.
formed in procedures already identified.
(2) In-Core Monitor System - Preinstallation Tests
.
.
This is covered by TP 302.02, "Incore Monitoring System Post-Installation Electrical Test."
(3) Steam Generator Pressure Relief Valves s s
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These valves will be tested per IP 600.30, " Steam Generator Relief Valve Test."
(4), Turbine control and Bypass Valves These will be tested using TP 320.02., "ICS Open Loop Calibra-tion," isd TP 280.03, " Main Turbine EH Cont. Acceptance Test."
(5) Loss of Instrument Air AP&L feels this system is not aafety reisted and thus this test is not required. This item will be discussed further.
(6) Vital Bus Full Load Test
'
The inspector was informed that load testing of these buses from the diese) generators would be demonstrated with TP 410.24,
" Emergency Diesel Generator System Preop Test."
The procedure has not been written and there was some question as to whether
-
this procedure will load test the vital buses under normal power.
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These tests will be discussed further during subsequent inspections.
'
(7) Evacuation Signal Tests rs f
The inspector was informed that a procedure will be written s
l for this test.
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R0 Rpt. No. 50-313/72-13-20-
,
(8) Hydrogen Removal System Status same as (7) above.
(9) Containment and Auxiliary Structures Filter Tests
!
The inspector was informed that the vendor will perform tests on the as-installed filters. The exact nature of those tests has not been determined. This will be discussed further.
,
i Review of Test Procedures for Inclusion of FSAR Requirements o.
AP&L proposals for performing this review were discussed in RO Report No 50-313/72-10, Details I, paragraph 4.
The inspector was informed during this inspectien. that the methcd now being used consists of verification by B&W and Bechtel thatA they have performed the review for each procedure they write.
form is signed by the procedure writer which states, "To the best of my knowledge this document ir in agreement with all quantitative values (instrument set points,..anks volumes, etc.) and limitations listed in the Arkansas Nuclear FSAR. Exceptions a2d corrective action, if any, are listed below."
~
'
t In view of the fact that this review is extremely limited in scope, this subject remains unresolved and will be discussed further.
.
5.
Training The onsite training program is directed by the Operations Supervisor with the assistance of the B&W Site Training Supervisor. Licensee representatives stated that the AP&L Production Department Training Coordinator, T. Green, would be assigned to the site in January 1973 to help administer the training program.
The formal training sessions described in RO P.eport No. 50-313/72-6,
,
'Section II, paragraph 2, have not been completed due to lack of man.
.
'
At that time, it was planned that the shif t supervisors would power.
teach the classes,- but it was found that they first had to be trained extensively.
The following paragraphs contain a synopsis of what has been accomplished and what is planned for operations and nonoperations-type people as described to the inspector.
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RO Rpt. N9 50-313/72-13-21-a.
Operations
The operations group has been on a rotating six-shif t schedule since
'
September 2,1972. Four shifts are used for shift coverage, one for day relief and training, and, the sixth for training only. Thus each shift receives at least five days of training every six weeks.
I Licensee representatives estimate that the relief and/or training shif t has been assigned to training greater than 50% of the time
while on tht! shift. Also, they indicated that the shifts working from 4:00 p.m. until midnight and from midnight until 8:00 a.m.
spend most of their time walking through systems or performing i
other training related functions. These shifts are currently invol-ved in tagging valves on most of the plant systems. Plans are to l
have them stencil piping once lagging has been installed.
,
,
The inspector was informed that plans are to assign half of the
'
operations crew to training in February 1973, leaving the other half for shift coverage.
4 A training folder has now been established for each individual to l
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be licensed. The folder encompasses 58 systems and delineates
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detailed information of which each man should be knowledgeable. The l
- l 58 systems will be split up among the shif t supervisors who will train extensively on those systems and then be responsible for testing individuals on those systems. When an individual feels that he is familiar with a line item in the folder,. he initials and dates that item. After he has completed all line items for a given system, the shift supervisor responsible tests him on the
.
system.
If the supervisor feels that the individual has sufficient knowledge, he then initials and dates the line items in the folder.
Plans are to give formal exams r'or each system.
b.
Nonoperations
-
Approximately 657 man-hours hav.been spent by 30 persons attending
-- -
,
lectures on basic nuclear eneory.
-
I (1) A ten-hour orientation program is being planned for adminis-trative personnel to include:
. (a) Basic Nuclear Theory - 1 Hour (b) Power Plant Systems - 1 Hour (c) Basic Health Physics - 6 Hours ('~'h (d) Health Physics Procedures - 1 Hour s~ ?
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i R0 Rpt. No. 50-313/72-13-13-y 3.
Review of Test Procedures i
Three approved preoperational test procedures were reviewed and resulting detailed comments given to the Test Administrator.
Comments and responses are summarized below for each procedure.
a.
TP 400-03, "AC Power System Energization Procedure"
.
(1) The procedure had not been reviewed by the TWG or SRC. Lack of review by the TWG is in violation of the requirements of Section l'.6.7.1.b.1 of the FSAR.
(2) The procedure does not provide for documentation of data read-
,
during the test.
(3) The procedure is lacking in acceptance criteria.
(4) Step 5.5.2(b) refers to a " connected load." This should be defined. The inspector asked if this were intended to satisfy the loading of vital buses from normal power sources. Licensee representatives were of the opinion that the load testing would
'
i be done by another procedure, TP 410-24, " Emergency Diesc1 Generator
'
Precperational. Test."
In response to ecuments 1, 2, and 3, licensee representatives
stated that this procedure bad not been treated as a test pro-
<
l cedure because it was a normal energization-type procedure and involved no safety related equipment.
The inspector stated that since the procedure had been included in AP&L's listing of test procedures and had been identifiet!
.
j by Bechtel as the one which would perform the normal power
distribution test in the Guide for the Planning of Preoperational
,
l Test Programs (VI, A), it must be reviewed by the TWG.
Also, i
since the power distribution system which supplies vital a.c.,
'
btmes is tested in this procedure, it should be considered as j
safety related.
i A licensee representative informed the inspector by telephone on December 8, 1972, that the TWG had reviewed and approved
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TP 400.03 on that date. This matter will be reviewed during
-
the next inspection.
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RO Rpt. No. 50-313/72-13-14-
.
b.
TP 330-02, "CRD Control System Operational Test" (1) This procedure should make provisions for more documentation by the person (s) performing the test in Sections 3.1, 5.4, 6.1, 6.2, and 7.1.
(2) Instructions to notify the Shift Supervisor before starting work should be added to Section 5.
Concerning comment (2), a licensee employee stated that most pro-cedures now contain this type of statement.
TP 330-03, "CRD Mechanism Functional Test" c.
(1) Comments (1) and (2) for TP 330-02 apply to this procedure also.
~
(2) Verification that each mechanism remained latched with one phase energized should be added to the list of specific acceptance criteria since this check is one of the purposes C
of the procedure. A licensee employee indicated agreement with this comment.
4.
Review of Preoperational (Preop) Testing Program a.
Administrative Control Procedure Coverage
.
Three of the comments concerning administrative controls documented in RO Report No. 50-313/72-5,Section II, paragraph 3, have been re-solved as follows:
(1) Comment: An administrative control procedure for the test pro-gram had not been written.
'
Resolution:
The Plan for Preoperational Test (Plan), OP 1004.09, has been written and approved.
-
(2) Comment: There was no procedure covering lifted leads and jumpers.
Resolution:
Control of liftea leads, jumpers and bypasses is covered in the Plan.
(3i Comment: There was no procedure describing control of defi-ciencies in procedures or equipment.
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Recolution:
Ihese concerns have also been covered in the Plan.
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RO Rpt. No. 50-313/72-13 -
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Comments concerning the Bechtel Startup Manual and system flushing procedures require more evaluation and will be discussed again during the next inspection.
b.
Comment on the Plan Comments on the Plan documented in R0 Report No. 50-313/72-6,Section II, paragraph 4, have been resolved as follows:
.
(1) Comment: The procedure did not cover lifted leads or jumpers.
Resolution:
The Plan now covers the use of lifted leads, jumpers, and bypasses.
(2) Comment: Test results should be properly reduced to meaning-ful and understandable form and be compared to previously i
.
determined performance standards or limits.
'
'
Resolution: Words similar to the comment itself are included in the Plan.
)
(3) Comment: The plan should' require that tests be rerun if system modifications are made or if results are felt to be unreliable.
Also the Plan should describe who will determine whether or not it is necessary to repeat a test and who will evaluate the results to verify adequacy of corrective actions.
Resolution:
The Plan now assi'gns the above responsibilites to the TWG.
(4) Comment: Additional information should be provided for certain
'
of the prerequisite STC duties in Section 6.1 of the Plan.
Resolution: Clarifying information has been added to the Plan.
'
(5). Comment: Additional Instructions should be given concerning the chronological log and what information is to be recorded.
.
Resolution:
Additional information on the chronological log has been included in the Plan.
Specific types of information to be. recorded on this log have not been defined but the plan does state, "This log will be in sufficient detail so that the events occuring during the test can be reconstructed and J
evaluated after the test."
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R0 Rpt. No. 50-313/72-13-16-
,
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c.
Lack of an Approval Method for Handling Administrativ,e, Operating.
Test and Maintenance Procedures
'
This area of concern was initially discussed during the July 1972 i
inspection.
(See RO Report No. 50-313/72-6,Section II, paragraph 5)
l Instructions for development, review, approval and use of test
.
.
procedures is now covered by the Plan, the latest revision of which t
was approved November 8, 1972. Other procedures are covered by 0F 1005.02, " Handling of Administrative, Operating and Maintenance Procedures."
This matter is considered resolved.
d.
Spara Parts Program
'
AP&L's audit of the spara parts program was discussed in R0 Report No.
50-313/72-6 Section II, paragraph 5.
The reaudit of this area
c performed October 6, 1972, revealed that deficiencies had been cor-rected. The inspector's study of the reaudit revealed that procedure OP 1004.05, "Q-List Spare Parts Quality Control Procedure," should be rewritten to allow ordering spare parts without sending specifica-tions with each order if the vendor already has the latest specifications.:
The procedure as now written requires that specifications be sent with every order. The inspector was informed that this was not
,
the intent of the procedure and that the procedure would be revised
,
to clarify this. point.
l This matter is resolved.
e.
Conduct of Tests Without an Approved Plan
A rough version of the Plan was approved September 25, 1972.
An' updated ard improved revision was approved November 8, 1972.
,
l This previously identified enforcament matter is resolved.
'
f f.
Approval of a Test Procedure Containing Acceptance Criteria Not I
in Agreement with TSAR Values
>
l Differences in acceptance criteria in TP 201.03, " Core Flooding
,
l System Functional Test," and the FSAR description of the test were discussed in RO Report No. 50-313/72-9,Section III, paragraph 2.
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30 Rpt. No. 50-313/72-13-17-
,
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The FSAR description of alarms tests (pg.13-3) now lists the
i acceptance criteria for alarm actuation as the setpoint plus or minus 27., such that the criteria in the test procedure are now
more restrictive than the FSAR. The FSAR change was made in
'
j
!
Amendment 31, dated November 15, 1972.
This enforcement matter is coesidered resolved.
!
g.
Failure to Maintain Documentation which Accurately Reflects the i
Construct _1on and Test Status of Equipment This item of noncompliance was discussed in RO Report No. 50-313/72-9,Section III, paragraph 1.
The luspector's review of corrective action taken revealed that the problems found in the release package
for System No. 80, "Non-Nuclear Instrumentation," such as improperly
<
.
marked drawings, had been corrected. However, the problem of con-
.
,
flicting documentation in the package for System No. 56, " Integrated
Control System," still existed.
This subject was discussed at the management interview and will be
!
discussed further during the next inspection.
!
l h.
Lack of Participation by the STC in the-Development of Test Procedures
.
l This violation of FSAR requirements was identified in RO Report No.
!
50-313/72-9,Section II, paragraph 3.
Originally, it was planned I
that the station staff and Bechtel STC's would develop the test
'
procedures. However, it was necessary to have this function per-formed by others due to manpower and scheduling problams. All of the ' test procedures ars being written by B&W and Bechtel home j
office-type personnel.
FSAR Amendment 31 reflects the fact that the STC does not write
'
test procedures. This matter is considered resolved.
During discussions concerning input which the STC might have to a '
procedure if he finds it inadequate, the inspector was informed
'
that the process of making minor and major revisions to a procedure as described in the Plan would be, and in fact, have been used to incorporate suggested improvements by the STC.
!
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RO Rpt. No. 50-313/72-13-18-1.
Incorporation of All Safety Related Eouipment in the FSAR Q-List i
This unresolved item was initially discussed in R0 Report No.
50-313/72-9,Section II, paragraph 4.
The subject was discussed during this inspection but no resolution was made.
It will be
,.
discussed further during subsequent inspections.
j. Lack of Documentation of the STC's Prerequisite Duties in the Conduct of Tests This item, discussed in RO Report No. 50-313/72-9,Section III, para-graph 3,~ was reviewed. AP&L plans to document performance of those duties such as checking that construction on the system is complete and the system has been properly tagged and released from construc-tion by including a checklist signed by the STC in the test proce-dure package. Also instruc. ions for accomplishing the documenta-tion will be included in the Plan.
This matter will be resolved with incorporation of instructions in the Plan and implementation of the documentation.
k.
Jumper and Bvpass Control add Authorization The version of the Plan approved November 8, 1972, now states that
,
jumpers and bypassco may be used only with the approval of the i
l Shift Supervisor. Also, a separate jumper and bypass log will ba maintained for each test.
The log will be posted in the control l
room until all jumpers and/or bypasses have been removed.
i
This item is resolved.
'
Administration of Test Program - Conflict Between FSAR and the-
!
Plan I.
As discussed in R0 Report No. 50-313/72-9, Sectiou III, paragraph 3.c, the FSAR stated that the TWG would coordinate activities during
'
preparation and review of test procedures where as the Plan
!
assigned this function to the Test Administrator. Amendment 31 to the FSAR resolved this discrepancy.
i
Definition of Changes to Test Procedures m,
l t
l The Plan now includes additions to a test as a major change to a l
procedure.
(S
-
This item is resolved.
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RO Rpt. No. 50-313/72-13-19-t
.
-
l n.
Preparation of Test Procedures to Cover Tests Listed in the Guide
'
for the Planning of-Precoerational Testing Programs As discussed in RO Report No. 50-313/72-9,Section IV, paragra t ",
there were nine tests for which AP&L had not identified test
~~
procedures to RO:II. The status of those tests are as follows:
i (1) Emergency Cooling Systems - Demonstration That Boron Can-centration Can Be Procerly Maintained, Adequate Samoling
'
Techniques, Etc.
The inspector was informed that these tests are probably per-
.
formed in procedures already identified.
(2) In-Core Monitor System - Preinsta11ation Tests
.
.
This is covered by TP 302.02, "Incore Monitoring System Post-Installation Electrical Test."
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(3) Steam Generator Pressure Relief Valves
\\
These valves will be tested per TP 600.30, " Steam Generator l
Relief Valve Test."
!
(4) Turbine Control and Bypass Valves i
fThese will be tested using TP 320.02., "ICS Open Loop Calibra-tion," and TP 280.03, " Main Turbine EH Cont. Acceptance Test."
,
(5) Ioss of Instrument Air
,
AP&L feels this system is not safety relsted and thus this test is not required. This item will be discussed further.
(6), Vital Bus Full Load Test
'
i The inspector was informed that load testing of these buses from the diesel generators would be demonstrated with TP 410.24,
,
" Emergency Diesel Generator System Preop Test."
The procedure
,
has not been written and there was some question as to whether
!
this procedure will load test the vital buses under normal power.
These tests will be discussed further during subsequent
'
-
inspections.
,
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(7) Evacuacion Signal Tests The inspector was informed that a procedure will be written for this test.
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RO Rpt. No. 50-313/72-13-20-(8) Hydrogen Removal System i
Status same as (7) above.
(9) Containment and Auxiliary Structures Filter Tests The inspector was informed that the vendor will perform tests on the as-installed filters. The exact nature of those tests
,
has not been determined. This will be discussed further.
,
.
Review of Test Procedures for Inclusion of FSAR Requirements I
o.
,
AP&L proposals for performing this review were discussed in RO Report No 50-313/72-10, Details I, paragraph 4.
l The inspector was informed during this inspection that the method now being used consists of verification by B&W and Bechtel that
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A they have performed the review for each procedure they write.
form is signed by-the procedure writer which states, "To the best
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.of my knowledge this document is in agreement with t ' quantitative
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values (instrument set points, tanks volumes, etc.) aad limitations listed in the Arkansas Nuclear FSAR. Exceptions and corrective ac' tion, if any, are listed below."
In view of the fact that this review is extremely limited in scope, this subject remains unresolved and will be discussed further.
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Training
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The onsite training program is directed by the Operations Supervisor e
with the assistance of the B&W Site Training Supervisor.
Licensee
representatives stated that the AF&L Production Department Training Coordinator,. T. Green, would be assigned to the site in January 1973
to help administer the training program.
The formal training sessions described in RO Report No. 50-313/72-6,
,
'Section II, paragraph 2, have not been completed due to lack of man.
At that time, it was planned that the shift supervisors would power.
teach the classes, but it was found that they first had to be trained extensively.
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The following paragraphs contain a synopsis of what has been accomplished and what is planned for operations and nonoperations-type people as described to the inspector.
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R0 Rpt. N. 50-313/72-13-21-
a.
Operations The operations group has been on a rotating six-shif t schedule since September 2,1972.
Four shifts are used for shift coverage, one for day relief and training, and, the sixth for training only. Thus each shift-receives at least five days of training every six weeks.
Licensee representatives estimate that the relief and/or training shif t has been assigned to training greater than 50% of the time
while on that shift. Also, they indicated that the shifts working from 4:00 p.m. until midnight and from midnight until 8:00 a.m.
spend most of their time walking through systems or performing other training.related functions. These shifts are currently invol-ved in tagging valves on most of the plant systems.
Plans are to have them stencil piping once lagging has been installed.
The inspector was informed that plans are to assign half of the operations crew to training in February 1973, leaving the othet..alf for shif t coverage.
A training folder has now been established "ar each individual to i
be licensed.
The folder encompasses 58 sy c zu and delineates detailed information of which each man shouxd be knowledgeable. The 58 systems will be split up among the shift supervisors who will tra'in extensively on those systems and then be responsible for testing individuals on those systems.
When an individual feels that he is familiar with a line item in the folder, he initials and dates that item. After he has templeted all line items for a given system, the shift supervisor responsible tests him on the system.
If the supervisor feels that the individual has sufficient knowledge, he then initials and dates the line items in the folder.
Plans are to give formal exams for each system.
b.
Nonoperations Approximately 657 man-hours have been spent by 30 persons attending
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lectures on basic nuclear theory.
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(1) A ten-hour orientation program is being planned for adminis-trative personnel to include:
(a) Basic Nuclear Theory - 1 Hour (b) Power Plant Systems - 1 Hour (c) Basic Health Physics - 6 Hours
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\\s (d) Health Physics Procedures - 1 Hour
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The AEC - Its Regulations and Relationship With AP&L -
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1 Hour (2) An eighty-hour course is planned for maintenance personnel which will include:
a.
Basic Nuclear Theory - 10 Hours b.
Power Plant S'ystems - 20 Hours c.
Health Physics - 50 Hours Written examinations are planned in each of the above areas.
This subject was discussed at the management interview and will be followed during. subsequent inspections.
6.
Request for Procedures The inspector requested that he be loaned copies of these procedures O
as they are approved.
They would be returned to AP&L upon completion of the inspector's review.
a.
Core Loading Procedure b.
Preoperational Test Procedure for Leak Detection Systems Which Mea.sure Primary System Leakage Power Ascension Test Procedure for Shutdown From Outside the c.
Control Room d.
Power Ascension Test Procedure for Loss of Offsite Power
The inspector was informed that these procedures have been identified
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but not written and that they will be provided as soon..as they. are approved.
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7.
Status of Procedures Licensee personnel provided the inspector with the following information regarding the status of preoperational test procedures.
No. Identified No. Written No. Approved N
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Bechtel
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Total 134
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RO Rpt. No.,50-313/72-13-23-
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8.
Barton Differential - Pressure (D/P) Cells The inspector informed licensee personnel that problems have been encountered with certain Barton D/P cells at other nuclear facilities.
Licensee personnel were requested to determine if they use the particular models in question, and if so, provide RO with information regarding their plans in dealing with this potential problem.
Licensee personnel agreed to research the subject and give the inspector their findings at a la:er date.
9.
Potential Design Deficiencies The inspector informed licensee personnel of the situation found at other facilities wherein a standby pump in a safety system could not be started because a redundant pump in the system had been deenergized and racked out.
The inspector asked if there were any possibility of defeating engineered safety features by racking out a power breaker at Arkansas Nuclear One.
Licensee personnel
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indicated that this possibility would be investigated and the inspector advised of the findings.
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Arkansas Power and Light Company Arkansas Nuclear One, Unit 1 g
RO Inspection Report No. 50-313/72-13 JAN 121973
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cc:
J. B. Henderson, RO l
J. G. Keppler, RO
' ' ).0:HQ (5)
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DR Central Files Regulatory Standards (3)
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Directorate of Licensing (13)
- PDR
- Local PDR
- NSIC
- DTIE, OR
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- To be dispatched at a later date.
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