IR 05000313/1973017
| ML19319E421 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/30/1973 |
| From: | Burke D, Kidd M, Murphy C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| References | |
| 50-313-73-17, NUDOCS 8004100701 | |
| Download: ML19319E421 (27) | |
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UNITED STATES O
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AT LANT A GEoRot A 30303 RO Inspection Report No. 50-313/73-17 i
Licensee: Arkansas Power and Light Company Sixth and Pine Streets Pine Bluff, Arkansas 71601 Facility Name: Arkansas Nuclear One, Unit 1 Docket No.:
50-313 License No.:
CPPR-5 7 Category:
B1 Location: Rusaallville, Arkansas Type of Licensa: B&W, EWR, 2568 Mwt Type of Inspection: Routine, Unannounced Dates of Inspection: November 6-13, 1973
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Dates of Previous Inspection:
Principal Inspector:
M. S. Kidd, Reactor Inspector Facilities Test and Startup Branch Accompanying Inspectors:
D. J. Burke, Reactor Inspector Facilities Test and Startup Branch
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T. N. F eps, Reactor Inspector Facilities Test and Startup Branch K. W. Whitt, Reactor Inspector
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Facilities Test and Startup Branch Other Accompanying Personnel:
C. E. Murphy, Chief, Facilities Test
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and Startup Branch Principal Inspector: D
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M. S.1(1'dd, Reactor Inspector Date
.Facilit e Test and Startup Branch Reviewed by:[
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C. E. Murphy,(Chf.uf, pd'cilities Test and Startup Branch
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I RO Rpt. No. 50- J/73-17-2-
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v SUMMARY OF FINDINGS I.
Enforcement Action A.
Violations The following violation is considered to be of Category II severity:
Contrary to Criterion XI of Appendix B to 10 CFR 50, certain prerequisites were not completed prior to the start of the containment integrated leak rate test.
(Details IV, paragraph 2)
B.
Safety Items None II.
Licensee' Action on Previously Identified Enforcement Matters A.
Violations Documentation Within Test Procedures Corrective action has been completed on the lack of documentation g
within certain test procedures discussed in R0 Report No. 50-313/73-12,
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Details I, paragraph 2.
This matter is considered resolved.
(Details I, paragraph 3)
B.
Safety Items There were no previoncly identified safety items.
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III. New Unresolved Items
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73-17/1 Pressurizer Electromaenetic Relief Valve During a general review of thin walled valves, it was determined that the pressurizer electromagnetic relief valve (PSV-lG00) may not be capable of withstanding postulated stresses.
(Details I, paragraph 4)
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73-17/2 Emergency Operating Procedures Generic comments on all emergency procedures and comments on specific procedures were given to licensee personnel.
Most of the procedures are to be revised.
(Details III, paragraph 2)
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T 73-17/3 Operational Test Program
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Several procedures which will accomplish operational testing required by Technical Specifications and Safety Guide (SG) 33 have not been identified or written.
(Details III, paragraph 3)
IV.
Status of Previously Reported Unresolved Items 72-9/1 Incorporation of Safety Related Equipment in the FSAR Q List Not inspected.
72-9/3 Preparation of Test Procedures to Cover Tests in " Guide for the Planning of Preoperational Test Programs" Procedures to test pneumatic valves under loss of air conditions and to test the audibility of the evacuation alarm have been written but not approved. This item remains open.
(Details I, paragraph 8)
73-3/1 Completion of Radiological Waste Disposal Systems I
Not inspected, d
73-5/2 _Corc Flood System Flow Rate Test Plans have been made to perform a flow rate test on this system but details of the test have not been developed.
This item remains open.
(Details I, paragraph 9)-
i 73-7/1 QA Program For Operations
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i Comments on the QA program for operations document 1004.15 have been resolved.
(Details I, paragraph 10)
73-8/1 Procedural Coverage Per Safety Guide 33 The development of certain annunciator alarm procedures, operational test procedures, and procedures for chemical and radiation control is not yet complete.
(Details I, paragraph 11)
73-10/1 Administrative Controls Manual This document has been revised to incorporate RO comments,
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but the new revision has not yet been approved.
(Details
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I, paragraph 12)
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RO Rpt. Ns. 50-3'1/73-17-4-
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73-10/2 Primary System Relief Valves
,j Actions to be taken in the event of malfunction of pressurizer relief valves are given in emergency procedure 1202.29,
" Pressurizer System Failure." This item is considered resolved.
(Details I, paragraph 13)
73-10/3 Emergency Diesel Generator Tests Full load tests on vital a.c. busses have been completed and documented. This item is resolved.
(Details I, paragraph 14)
73-10/5 Cascous and Clean Radwaste Systems Test Procedures
'Not inspected.
73-10/6 Respiratory Protection Program and Procedures Not inspected.
73-10/7 Repte antative Sampling of Gaseous Wastes Not inspected.
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73-12/1 Administrative Controls for Maintenance Activities Appropriate procedures have been revised to better define g -
controls fo maintenance. This item is considered resolved.
(Details I, paragraph 15)
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73-12/2 Diesel Generator Trips Evaluation of corrective actions to prevent diesel generator voltage and frequency spil ing and subsequent damage has not been completed by RO.
This item remains open.
(Details I,
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paragraph 16)
73-12/3 control Rod Trip Test Not inspected.
73-14/1 Integrated Engineered Safeguards Test Previous comments on TP 310.03 have been resolved, therefore this item is closed.
(Details I, paragraph 17)
73-14/2 Initial Core Load Procedure RO comments on a draft of OP 1502.04 were discussed. Licensee representatives expect the procedure to be in final form within a month.
(Details I, paragraph 18)
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R0 Rpt. Ns. 50 3/73-17-5-O 73-14/3 Leak Testing r the Personnel Hatch
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Leak testing requirements for the personnel hatch pta technical specifications are less restrictive than those of Appendix J to 10 CFR 50.
This item remains open.
(Details I, paragraph-19)
V.
Unusual Occurrences EJactrical Inverter Malfunction i
on September 28, 1973, an inverter which supplies a station vital a.c. bus malfunctioned due to a control power wire burning open due to an improperly crimped lug connection. Details are given in a licensee report per 10 CFR 50.55(e) dated October 31, 1973, entitled " Inverter Malfunction." (Details I, paragraph 6)
VI.
Other Significant Findings Project Status AP&L has changed its estimated core load date from January 21, 1974, to March 2, 1974. Reasons for the delay include late delivery of certain nuclear grade 7alves, the rework of reactor coolant pump anti-reversing clutches,1-and the modifications to the low pressure injection system to improve core reflood capability.
i Of the 131' tests to be performed prior to core loading, 31 have been 100% completed and the results of 15 of those have been endorsed.
VII. Management Interview Management interviews were held November 9 and 13, 1973, to discuss the findings of the inspection. The following licensee representatives
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attended:
Arkansas Power and Light Company (AP&L)
J. W. Angprson - Plant Superintendent B. Bake r-T. Baker /
Shift Supervisor
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Chemical and Radiation Protection Engineer T. H. Cogburn - Nuclear Engineer
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R. R. Culp - Test Administrator C. A. Halbert - Technical Support Engineer 1/ See R0 Report No. 50-313/73-14, Details I, paragraph 8.
2/ Attended only the November 13, 1973, meeting.
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RO Rpt. No. 50-313/73-17-6-
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G. H. Miller - Assistant Plant Superintendent li. A. Moore - Chief Quality Assurance Coordinator J. A. Orlicek - Quality Control Engineer M. H. Sheibhag - Procedure Administrator B. A. Terwilliger1/ - Operations Supervisor The violation in Section I was discussed. Details are given in Details IV, paragraph 2.
The new unresolved items in Section III were discussed. Details are given in Details I, paragraph 4 and Details III, paragraphs 2 and 3.
The status of previously identified unrasolved items listed in Section IV were also discussed. The inspector stated that the items concerning the quality assurance program for operations, the ee.fety and relief valves, emergency diesel generator tests, and administrative controls for maintenance were considered re-solved. Detailed information on the previously identified unre-solved items are given in Details I, paragraphs 8 through 19.
The startup test program and, ocedures, maintenance procedures, and review of preoperational est results and systems operating procedures were discussed. More information is given in Details II, paragraph 2 through 5.
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1/ Attended only the November 9,1973, meeting.
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RO Report No. 50-313/73'17 I-l DETAILS I Prepared by:
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Date Reactor Inspector Facilities Test & Startup Branch *
Dates of Inspection: November 6-13, 1973 Reviewed by:_[ /! M /
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'C.E.Murplh,fhieff
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Facilities, Test & Startup Branch
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1.
Individuals Contacted Arkansas Power & Light Company (AP&L)
J. W. Anderson - Plant Superintendent B. Baker - Shift Supervisor T. Baker - Chemical & Radiation Protection Engineer
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T. H. Cogburn - Nuclear Enrineer
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R. R. Culp - Test Administrator T. Holcomb - Assistan. Plant Operator H. Hollis - Administrative Assistant J. McWilliams - Assistant Plant Operator G. H. Miller - Assistant Plant Superintendent N. A. Moore - Chief Quality Assurance Coordinator i
M. H. Shanbhag - Procedure Administrator B. A. Terwilliger - Operations Supervisor
Bechtel Corooration (Bechtel)
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l J. W. Jamieson - Startup Engineer, Electrical 2.
Personnel Changes AP&L has added a nuclear safety consultant to their Safety Review Committee (SRC).
Dr. C. G. Chezem, Manager, Nuclear Actitities Department, Middle South Services, Incorporated, has joined the SRC in this role. Biographic information on Dr. Chezem is contained in Appendix Al of the Unit 1 FSAR.
3.
Documentation within Test Procedures
. This enforcement item was originally discussed in RO Report No.
50-313/73-12, Details I.
During the current inspection, discussions v
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with' licensee personnel and review of procedures involved revealed
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that corrective cetion had been completed. Corrective action in-cluded development of a report on the individual problems which i
were attached to each procedure. The report discussed the reason why the lack of documentation occurred, a description of corrective
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action taken, action taken to prec1ttC2 repetition, and an endorse-ment that ne adverse effects on this or other tests had occurred.
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Preventive actions include the addition of spaces for initials and dates beside major steps within test procedures in all procedures released for testing after August 17, 1973.
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The inspector stated that he had no further questions and stated during the management interview that this item was considered resolved.
4.
Pressurizer Electromagnetic Relief Valve
The inspector asked licensee representatives if they were aware of-l RO questions regarding validity of the stress analysis performed on valves identical to the pressurizer electromagnetic relief valve (PSV-1000) manufactured by Dresser Industries. Licensee representatives stated that they were aware of the potential problem and that the problem was being evaluated. The inspector stated during the man::gement interview that this matter would be carried as an un-resolved item.
5.
Station General Operating Procedures
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The inspector reviewed the following general procedures and dis-
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cussed his comments with licensee personnel:
1102.02, "Plar.i; Startup" 1102.04, " Power Operation"-
1102.05, " Operation at Hot Sttndby" 1102.06, " Reactor Trip Recovery" 1102.08, " Approach To Criticality" 1102.10, " Plant Shutdown and Cooldown" The inspector was informed that these procedures were currently being reviewed and revised by licensee personnel.
The inspector stated that he had reviewed the procedures and compared them with the guidelines in ANS 3.2, " Standards for Administrative Controls for Nuclear Power Plants." Three general comments on the procedures were given. Most of the procedures need checklists. More details such as specific valve numbers, breaker numbers, and more detailed-instruction is needed. References to other general procedures i
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RO Rpt. Ns. 50-313/73-17 I-3
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s and to systems operating procedures are needed. The inspector noted
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that these general comments applied to all the above procedures except 1102.05, on which he had no comments. Detailed comments on the other procedures were also discussed. Licensee personnel indicated agree-
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ment with the comments and stated that the procedures would be re-written by January 1, 1974. This position was reaffirmed during the management interview.
6.
Inverter Malfunction A licensee report dated October 31, 1973, entitled " Inverter Malfunction" describes the malfunction of an inverter due to loose wiring connections.
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The loose connections were determined to be a warranty problem and
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were corrected under the supervision of a representative of Solid State Controls, Incorporated, the manufacturer. All other inverters were checked and loose connecticns corrected in the same manner.
The inspector informed licensee personnel that this problem and i
others, as discussed in paragraph 16 of this Details section, would be reviewed further.
7.
Civil Disturbances The inspector discussed provisions for personnel action in the
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event of a civil disturbance. He reviewed two industrial security
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plan implementing procedures, 1204.04," Bomb Threat Procedure" and 1204.05, " Civil Disturbance Procedure", and stated that he had no questions or comments on those procedures.
8.
Preparation of Test Procedures i
This unresolved item was last discussed in RO Report No. 50-313/73-14, Details I, paragraph 9.
During the current inspection, the inspector i
was informed that test procedures for testing of pneumatic valves
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under loss of air conditions and for testing the evacuation alarm were being written.
This item remains open.
9.
Core Flood System Flow Rate Test This unresolved item was initially discussed in R0 Report No.
50-313/73-5, Details I, paragraph 11.
Licensee personnel have made provisione in the testing schedule for this test, but stated that the-details of the test are not available yet.
The inspector
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stated that this item would remain open.
10.
Quality Assurance For Operations -
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This unreolved item was initially discussed in RO Report No. 50-313/73-7,
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Details I, paragraph 7.
Comments on 1004.15, the QA for operations document, have been resolved in revision 1, which has now been approved. The inspector stated that this unresolved item is considered closed.
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The inspector stated that he had reviewed procedure 1004.11,
" Handling, Storing, and Shipping of Q-List Equipment" and that he had no comments on that procedure.
11. Procedural Coverage Per Safety Guide (SG) 33 The status of procedures to be written to meet the requirements of SG 33 was discussed in RO Report No. 50-313/73-14, Details I, paragraph 12.
The following represents the status of those procedures as of the current inspection:
a.
Administrative Procedures i
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i (1) Security and visitor control is defined by the industrial security plan.
(2) Authorities for safe operation and shutdown of the plant are covered in 1005.01, " Administrative Controls Manual."
(3) A schedule for surveillance testing has been 62veloped and is defined in 1004.12, " Operational Test Control."
(4) Access to containment is covered in 1602.35, "ANO Radiation Protection Manual."
(5) Recall of standby personnel has been covered by issuance of a special order.
Discussions revealed that all administrative procedures
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required by SG 33 have now been developed.
b.
Alarm and Abnormal Procedures The inspector was informed that development of annunicator response procedures was in progress. The inspector stated that these procedures must be developed prior to licensing.
Licensee personnel stated that they should be developed and ready for review for approval by January 1,1974.
c.
Emergency Operating Procedures
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Discussions with licensee representatives revealed that all identifiable expected transients are covered by emergency, O
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operating, abnormal, or alarm procedures.
In discussing partial loss of power and inability to drive i
control rods, it.censee personnel stated that coverage for these conditions were being added to 1202.02, " Blackout" and 1203.03,
"CRD Malfunction Action," respectively.
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d.
Control of Radioactivity and Chemical and Radiochemical Control Procedures Discussions revealed that perhaps not all procedures required in these areas have been identified. The inspector stated that this group of procedures would be discussed further.
e.
Maintenance Procedures Review of procedures available indicated that all those required by SG 33 have been written.
The above procedures were discussed in the management intervf.s, at which time the inspector stated that this item regarding procedures needed to meet the intent of SG 33 would remain open.
12. Administrative Controls Manual a
This item was initially discussed in R0 Report No. 50-313/73-10, Details I, paragraph 6.
The manual has been revised to reflect RO comments, but has not been reapproved. The inspector stated during the management interview that this unresolved item would remain open pending approval of the latest revision. A licensee representative stated that the manual would be approved within one week.
13. P_rimary System Relief Valves r
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This item was discussed in RO Report No. 73-10, Details I, paragraph 8.
Malfunction of pressurizer relief valves is now covered by 1202.29,
" Pressurizer System Failure." The inspector stated during the management interview that he had no further questions on this item.
14. Emergency Diesel Generator Test As of the current inspection, the only question still open on this previously identified unresolved item was the full load testing of vital a.c. busses. This testing was discussed with licensee representatives who provided documentation that loading from normal power sources was accomplished in test procedure 400.03, "AC Power O
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Systems Energizatien," and from emergency power sources in test
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procedure 310.03, " Integrated Engineered Safeguards Test."
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inspector stated during the management interview that he had no further questions on this item.
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15. Administrativi Controls for Maintenance Activities r
This unresolved item was initially discussed in RO Report No. 50-313/73-12, Details I, paragraph 3.
Procedures 1004.13 and 1005.01 have been revised-to incorporate those comments discussed in the referenced report. The inspector stated that he had no further question on this
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16. Diesel Generator Trips Less of power to vital busses due to a trip of DG No. 1 because of i-voltage and frequency spiking was described in RO Report No. 50-313/73-12, i
Summary of Findings, paragraph V.
A final report per 10 CFR 50.55 (e) dated October 31, 1973, entitled " Loss of Power to Vital Busses"
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has been received. This item was discussed during the current inspection.
Not all corrective actions had been completed. The inspector stated that this item would remain open.
I 17. Integrated Engineered Safeguards Test RO comments on TP 310.03 were discussed in Report No. 50-313/73-14, Details I, paragraph 3.
Review of the approved procedure during the current inspection revealed that the comments documented in the referenced report have been resolved by revisions to the test
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procedure.
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l The inspector stated during the management interview that this unresolved item was considered closed.
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l 18. Initial-Core Load Procedure
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50-313/73-14,
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This unresolved item was initially discussed in RO Report No.
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-Details I, paragraph 4.
In addition to the comments documented in the l
referenced report, the following areas of concern were discussed; a.
RO's position is that the minimum count rata of 1 count per i
second as given in the procedure should be changed to a
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minimum of 2 counts per second.
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The training which the fuel handlers will have received should be defined and discussed.
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The fuel handlers should be given physical examinations or by c.
other means the determination made that the health of each is of such quality to give reasonable assurance that his, duties can be completed efficiently and safely.
A licensee representative stated that these comments would be studied and that the response to them would be available during the inspector's next visit to the site. He also st2ted that the procedure was being revised and should be in the final form within one month. The inspector stated during the management interview that this unresolvad item would remain open.
19. Personnel Air Lock Leak Testing This unresolved item was initially identified in R0 Report No. 50-313/73-14, Details I, paragraph 5.
The Unit 1 Technical Specifications regarding testing of the personnel hatch outer doo-seals are less restrictive than Appendix J to 10 CFR 50.
In discussing this matter during the current inspection, licensee personnel stated that no action had been taken on the Technical Specifications but that it was under study.
The inspector stated during the management interview that it would remain open.
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RO Rpt. No. 50-313/73-17 II-l
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DETAILS II Prepared by:.
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// ' 9!/3 K. W. Whitt Date Reactor Inspector Facilities Test and Startup
Branch Dates of Inspection: November 6-9, 1973 a
Reviewed by:,
sf/M r C. E.' Murphy,yChigf^
/ Date
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Facilities Test and Startup Branch e
1. Individuals Contacted j
Arkansas Power and Light Company (AP&L)
J. W. Anderson - Plant Superintendent T. H. Cogburn - Nuclear Engineer
R. R. Culp - Test Administrator C. A. Ha'1ert - Technical Support Engineer T. M. Martin - Maintenance Supervisor G. H. Miller - Assistant Plant Superintendent
M. H. Shanbhag - Procedure Administrator B. A. Terwilliger - Operations Supervisor
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Bechtel Corporation (Bechtel)
R. Sreekakula - Station Test Coordinator 2. Startup Testing
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Test Program -
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The licensee's program for initial startup and power ascension
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testing was compared with the requirements as outlined in AEC Guide for the Planning of Initial Startup Programs. The t.:sts identified-appear to adequately satisfy the requirements of the Guide. The inspector has no further questions concerning this matter.
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b.
Procedure Review Two detailed startup procedures were reviewed. Questions which resulted from the review were discussed with licensee site personnel and satisfactorily resolved. The procedures were:
TP 800.14. "Turbinc/ Reactor Trip Test" TP 800.11 " Core Power Distribution" 3. Maintenance Procedures a. Procedure Identification
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The procedures identified by the licensee for performance of maintenance was compared with the requirements of Section I of Appendix A to Safety Guide 33, Quality Assurance Program Requirements (Operation). Procedure requirements have been identified for all the items listed. Procedure numbers have been assigned for the majority. The inspector has no further questions in this area.
b.
Procedure Review Three maintenance procedures were reviewed and the following s_-
general comments were discussed with a licensee representative.
Comment 1: The procedures reviewed have not been provided with signoff spaces for initial conditions and procedures steps. Further, signoff spaces have not been pr'ovided for verification of procedure completion.
Licent,'e Response: A checklist or procedure signoff
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spaces will be provided for safety related procedures and spaces for verification by management that the procedures have been satisfactorily completed will be
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added.
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Comment 2: The procedures provide for testing of systems or components following maintenance, but no data sheets
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have been supplied for recording the test results.
Licensee Response: Data sheets will be added for recording the necessary data and will require data review and approval.
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RO Rpt. No. 50-313, s-17 II-3 V
Comment 3: The purpose of some of the procedures states that the procedures define the preparations required to perform maintenance inspection and/or repairs and post maintenance testing, but say nothing about the instructions for performing the maintenance. The body of the procedure does provide instructions for performance of the appropriate maintenance.
Licensee Response:
In some cases, the purposes are not properly stated. They will be corrected as appropriate.
4. Review of Preoperational Test Results The results of five preoperational tests were reviewed. Two comments on TP 256.18, " Instrument and Service Air System,"
were discussed with licensee personnel. The Comments were.as follows:
Comment 1: The second entry of the station test cooedinator's (STC) log identifies a failure of compressor cooling water which delayed the test. This occurrence was not recorded as a discrepancy or test deficiency and the method of correcting the trouble was not indicated.
/N Licensee Response: There was no actual failure of the (
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compressor cooling water. When test preparations were being completed, it was learned that the compressor cooling water system had not been sufficiently prepared to perform its normal function. The test was, therefore, delayed until the cooling water could be properly prepared to supply water for the cooling of the compressors.
ga Upon being questioned about the adaquacy of explanation of this occurrance in the STC log, a licensee representative i
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agreed that the log needed to be written in more detail and indicated that steps would be taken to require better explanations of significant occurrences.
The inspector agrees that this occurrence as clarified by the STC need not be classified as a test deficiency. More complete descriptions of entries in the STC log should prevent i
such ambiguity in the future. This item is considered closed.
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Comment 2: The entry in the STC log made at 1600 on February 15, 1973, st:tes that the alarm buzzer is too small to be heard in the compressor room. This condition was not identified as a test deficiency and no explanation was given about the corrective action.
Licenaee Response: This condition was inadequately described in the STC log. The alarm did sound, but it was not sufficiently loud to be heard clearly over the noise of the compressor room.
The alarm is not a part of the system design and is not required for system operation. This is not considered to be a deficiency.
An effort will be made to have more information and descriptive
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comments recorded in the log.
- Af ter evaluating the circumstances concerning this item, the inspector agrees with the licensee conclusion that it was not a test deficiency. The problem appears to be more closely related to poor logging practices. These practices should be improved by the licensee commitment to strive for better logs which was reaffirmed at the management interiview. The inspector noted an explanatory entry that had been added to the STC log to clarify the actual condition in this specific case. This item is considered closed.
No comments resulted from the review of the other four procedures.
These procedures-were:
TP 220.04. " Spent Fuel Cooling System Instrumentation Preoperational Calibration" TP 300.01,."RCS Temperature Instrumentation Preoperational Calibration" TP 200.01, " Reactor Internals Vent Valves Inspection Test"
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TP 200.16, " Pressurizer Level Verification" 5. Systems Ope 4 ting Procedures Seven systems operating procedures were reviewed which completes the initial review of this category of' procedure. The following general comments were discussed with the appropriate management representatives in a meeting at the beginnina of the inspection.
Comment 1: Many of the operating procedures are also being used for-the performance of surveillance testing. Surveillance test procedures should be provided with spaces for verification of prerequisites and major procedure steps, proper. data sheets, and appropriate signoff spaces for review and approval of test results.
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Licensee Re +7nse: Where surveillance testing is performed in accordance with operat*ng procedures, signoff spaces will be provided for prereo -
os and major procedure steps or check-lists will be attached to the procedure for this purpose. Proper data sheets will be incorporated into the procedure and spaces will be provided for signoff by the data taker and by a reviewer
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and for approval by the appropriate supervisor.
The inspector noted that the procedures that were being rewritten and issued as new revisions were already incorporating all the commitments stated above. This item is considered closed.
Comment 2: The operating procedures that are used for normal plant operation on an infrequent basis should be provided,
with signoff spaces in the procedures to verify proper action or a checklist should be attached to the procedure to fulfill this function.
Licensee Response: Checklists are being developed to use for this purpose.
The specific comments on the various procedures reviewed were discussed with licensee personnel during the course of the inspection. A summary of the comments follows:
a.
OP 1103.05, " Pressurizer Operation" Comment:
In section 6.2.8, the steam bubble is formed in the pressurizer at a pressure of 30 to 50 psig. The vents are closed, the spray system is valved out, the electromatic relief valve is isolated, and the pressurizer heaters are on.
No methou of controlling the pressure
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has been specified. What prevents the system pressure from continiously rising?
Licensee Response: Part of the procedure has been omitted.
The procedure will be changed to require the pressurizer heaters to be turned off after the bubble is formed and the pressure will be manually controlled by turning the heaters on and off as necessary.
b.
OP 1103.13, " Reactor Coolant System Leak Detection" Comment 1: It does not appear that this procedure requires a record of the reactor building semp level be kept. Since the reactor building sump inventory is one method of detecting I
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reactor. coolant system leakage, a record should be maintained.
Lic<nsee Response: A reading of the reactor building sump level will be taken each sh'.ft and recorded on a log sheet.
This item is considered closed.
Comment 2: The check for leakage is done over a 30 minute period and performed once per day. Is this 30 minutes considered long enough to obtain results sufficient to satisfy the technical specifications?
Licensee Response: This aspect of the procedure will be reviewed and will probably be changed to require a minimum of 30 minutes.
It is recognized that better results can be obtained over a longer period.
This item is considered closed.
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OP 1104.04, "DiiR System Operation" Coument:
The intent of section 13.0 is not clear. A
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description of a test has been provided and initial conditions
.have been specified, but no instructions have been provided
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for the performances of'the test.
Licensee Response: The instruction portion of the procedure was inadvertantly left.out. The procedure has been rewritten to include the instructions that were'omitted.
The inspector noted that the ommitted instructions had been incorporated into a new revision of the procedure. This
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item is considered closed..
d.
OP 1104.05, " Reactor Building Sprav System Operation"
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The inspector had no specific comments on this procedure.
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OP 1104.06, " Spent Fuel Cooling System" g.
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OP 1105.03, " Engineered Safeguards Actuation' Systems" The inspector.ht:d no specific comments on this procedure.
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OP 1106.06, " Emergency Feedwater Pump Operation" Comment:
It is not clear what is' required to be verified in section 6.2.1.
Licensee Response: The required operation of valves CV-2800 and 2802 has been omitted. A review will be made
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. to determine the desired position of the valves and the
- necessary chance will be made to the procedure.
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DETAILS III Prepared by: [
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./ 2 s, /.. /?i D. J. Burke Date Reactor Inspector Dates of Inspection: November 6-13, 1973
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Reviewed by:
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'C. E. Murplyr, EhiefM Aats Facilities Test and Startup Branch 1. Individuals Contacted
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Arkansas Power and Light Company (AP&L)
P. Almond - Reactor Technician T. Baker - Chemical and Radiation Protection Engineer
J. L. Orlicek - Quality Control Engineer D. R. Sikes - Results Engineer M. H. Shanbhag - Procedure Administrator B. A. Terwilliger - Operations Supervisor Two Shift Supervisors
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Two Plant Operators
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2. Emergency Operating Procedures a.
General Comments
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Each emergency t crating procedure and a few abnormal operating-procedures were reviewed during this inspection and our comments were discussed with licensee personnel. The inspectors commented
that during their pro-edure review, a few areas of weakness
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appeared throughout the procedures. These were addressed as generic type comments for review and would apply to all the emergency procedures in general. The generic comments included:
(1) A lack of detail in the procedures: Valve numbers,
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i breaker numbers and locations, water levels, flow rates, etc., should be spelled out to assist the operators. After a few years of steady-state operations, these emergency system details may be necessary.
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(2) A need to reference other emergency and/or aperating procedures more frequently to provide detailed instructions for the operators. Many systems or operations are complex enough to require this.
It should be standard practice to reference the reactor trip or recovery procedures by numoer (1202.04 and 1102.06).
(3) A lack of detail or direction for establishing the final conditions after the emergency. The procedures should define whether the unit should be in hot standby, hot shutdown, cold shutdown, etc., and should reference procedures and approvals required to establish these conditions. These decisions cannot be left to the operators.
Several specific examples of each generic type comment were preaented as illustrations for the licensee. A licensee representative stated that all the emergency procedures were undergoing review and that these comments would be considered and/or incorporated. During a tour of the facility, the inspectors spoke with a few shift supervisors and plant
N operators to obtain their understanding of what " verify" (in
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the energency procedures) means to them. They described, to the inspectors satisfaction, that " verify" requires manual actuation of a system if the automatic acutation fails. This is spelled out in the Administrative Controls Manual, 1005.01.
b.
Specific Comments 1202.02, " Blackout" - the licensee reaffirmed his intentions to consider degraded power sources as required in Safety Guide 33.
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1202.07, " Loss of Boron (Moderator Dilution)" - the inspector commented that in Section IV with the reactor vessel head off, a decreas< in boron concentration or increase in neutron f1'tx level should constitute sufficient grounds for an immediate local (RB) cvacuation order.
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1202.11, "High Activity in Reactor Coolant" - the inspector
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recommended that the licensee generate a correlation between the Process Radiation Monitors and Failed Fuel Recorder and the Technical Specification RCS activity limits so the instruments or alarms can inform the operators if the limits are exceeded, and if the reactor must be shut down.
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RO Rpt. No. 50-313/73-17 III-3 iN If a gross failure occurs, it is not sufficient to reduce reactor power by 50% call the chemist, and wait for an analysis before shutting down.
1202.18, " Emergency Shutdown" - the licensee stated tha he will review the procedure and provide typical examples of conditions which regt. ire shutdown.
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1202.33, " Emergency Ope ration of NSS" - the inspector recommended that the title of this procedure be changed to the usual Inaccesrability or Forced Evacuation of the Control Room. The licensce agreed.
1203.03, " Control Rod Drive Malfunction Action" - the inspector stated that if AP&L does not generate a procedure to
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deal with the inability to drive the control rods, this emergency must be covered under a section of 1203.03.
During the exit management interview, the licensee reaffirmed his intentions to review all the emergency procedures and to consider our specific comments and recommendations. The emergency procedures will be carried r~s as an unresolted item.
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3. Surveillance Test Program Procedures a.
" Operational Test Control", 1004.12 establishes a test control program to assure that AP&L's technical specification surveillance requirements are met.
As per Safety Guide 33 and ANSI 18.7, the inspectors recommended that the licensee reference, in 1004.12, the implementing procedures that are required for each test, inspection, calibration, etc., listed in the technical specifications.
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These procedures should spell out how to perform the tests, the precautions and limitations, acceptance criteria and approvals that apply, the sections responsible for the work, and the signoffs and filing procedures required.
At this point in time, the licensee could not identify certain procedures for implementing all the technical specification surveillance sampling or testing required.
A licensee representative stated that the implementing procedures will be provided and that 1004.12 will reference the procedures as part of the surveillance test program.
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b.
Procedure Comments:
In reviewing 1004.12 and the impicmenting or reference procedt.res, the inspector observed that AP&L's philosophy is to let operations handle the daily or shif t checks while engineering performs the longer term testing or calibration required. A few procedures, such as the " Core Flooding System Operating Procedure", 1104.01, have sampling sections in the operating procedure to spell out the precautions, sampling techniques, valve line-ups and volumes required, and the personnel involved. However, many of the sampling techniques and responsiblities of other systems are yet to be defined. As of this inspection (November 8, 1973),
approximotely 12 different surveillance test and inspection procedurc have been generated, and although intensive work is contini.ing, much remains to be done. In addition, the recent chaiges to the technical specification will necessitate further reiiew of the dozen or so procedures that have been approved. AP&L has assured the inspectora that they are aware of the surveillance test requirements and are working to fulfill their commitments. The surveillance procedures will be carried as an unresolved item.
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DETAILS IV Prepared by:
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Date Facilities Test and Startup Branch Dates of Inspection: Novemb.er 6-13, 1973 Reviewed by:,
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~C.E. Murphy,Chieff
/ Date Facilitics Test and Startup Branch 1.
Persons Contacted Arkansas Power and Light Company (AP&L)
J. W. Anderson - Plant Superintendent R. R. Culp - Test Administrator J. L. Orlicek - Quality Control Engineer D. G. Sikes - Results Engineer Bechtel Corporation (Bechtel)
g J. Przybys - Station Test Coordinator G. Cranston - Startup Engineer V. Nikolaeff - Startup Engineer 2.
Local Leak Rate Testing The inspector reviewed documentation of local leak rate tests required as prercquisites to the Integrated Leak Rate Test (ILRT).
It was found that ten of the local leak tests were not run due to equipment
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not being available for testing.
i-10 CFR 50, Appendix B, Criterion KI requires, in part, that test pro-cedures shall include provisions for assuring that all prerequisites for the given tuat have been met.
Criterion VI requires, in part, that measures shall be established to assure that documents including changes, are reviewed and approved by authorized personnel.
AN0's administrative procedure 1004.09, " Record of Revisions and Approval to Station Procedures," requires that a major modification may be made only on approval of the station superintendent or his designated represenective.
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Major changea are defined, in part, as "... changes that result in a deletion of any part of the procedure which was an intent of the original approved procedure."
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Contrary to the above, the ten prerequisite tests that were not run were not handled as major changes and no approval by the plant superintendent was documented.
i An addendum to the procedure was prepared and the plant superintendent approved it before the inspector left the site.
3.
Instrumentation calibration The inspector asked AP&L's results engineer to retrieve the instru-mentation records for ILRT instrumentation. These records were produced for the following types of instrumentation used:
Pressure sensors and indicators Dewpoint temperature sensors and indicators Drybulb te err. cure sensors and indicators Flow meters Barometer fg The inspector questioned the adequacy of the manufacturer's letter f
y certifying the accuracy of the barometer used. A phone call to the manufacturer provided. additional information for resolution of the question.
4.
ILRT Test Procedure Review The test procedure was reviewed before this inspection and several items were discussed with the test administrator during the inspection.
The most significant of these items involved the method to be used for monitoring the quality of pressurizing air. The method involved
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blowing air from a point downstream from the air cooler out of a
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drain valve through a piece of cloth to check for moisture. The inspector indicated that this method appeared to be weak.
5.
Reduced Pressure (N 30 Psig) ILRT Pressurization was started at 3:17 a.m. on November 8,1973, with 5 diesel driven air compressors - (N 5200 cfm). Pressurization was stopped at 14 psig for a 1-hour soak period and a leak check was then conducted. Pressurization was continued at 3:26 p.m.
At 11:00 p.m., 30 psig was approached, n
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At this pressure, the dewpoint temperature sensors were operating arratically indicating the possibility of saturated air inside the containment. The containr.ent was then depressurized to 14 psig and a containmut entry was conducted. Based on the dewpoint
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sensor vendor's recomendation, the sensors were removed from.the containment, cleaned and recalibrated. After the ILRT, the dewpoint sensors will be returned to the vendor for a calibration check.
The sensors were then reinstalled and the containment repressurized from 14 psig to 30 psig. The atmospheric humidity was lower than before so dryer air was pumped into the containment. The dew cells seemed to be functioning properly so the 30 psig ILRT was conducted for 8-3/4 hours with a verification test of 4-1/2 hours following.
6.
Design Pressure (% 59 Psig) Test i
Pressurization was continued at 10:50 p.m. on November 10, 1973, to increase containment pressure from 30 psig to 115% of design pressure for the structural integrity test. A concrete inspection was conducted at 50 psig and pressurization was con..inued to 68 psig.
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This r_sximum pressure w.cs reached at 11:05 p.m. on November 11, 1973.
After this test, pressure was reduced to 59 psig at 4:40 a.m. on November 12, 1973.
The design pressure rest was completed at 7:00 p.m. on November 12,
1973, and a 7-hour verification test was then conducted.
7.
ILRT Test Results-
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The reduced pressure test yielded an integrated leak rate of 0.0292 compared to a value of 0.106 for 75% of the allowable.
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The design pressure test leak rate was.0815 compared to.150 for 75% of the ma::imum allowable.
These leak rates were preliminary values and may vary slightly from the final values.
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Arkansas Power and Light Company DEC 3 1973 Arkansas Nuclear One, Unit 1 i
I RO Inspection Report No. 50-313/73-17 i
i cc w/ enc 1:
3. D. Thornburg, RO
-'. RO:HQ (5)
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DR Central Files Regulatory Standards (3)
Directorate of Licensing (13)
cc encl. only:
- PDR
- Local PDR
- NSIC
- DTIE, OR
- State
- To be dispatched at a later date.
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