IR 05000313/1977003
| ML19309D794 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 03/03/1977 |
| From: | Gagliardo J, Randy Hall, Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19309D779 | List: |
| References | |
| 50-313-77-03, 50-313-77-3, NUDOCS 8004110673 | |
| Download: ML19309D794 (18) | |
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O-O U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
IE Inspection Report No. 50-313/77-03 Docket No. 50-313 Licensee:
Arkansas Power & Light Co.
License No. DPR-51 Sixth & Pire Streets Pine Bluff, Arkansas 71601.
Category C Facility:
Arkansas Nuclear One, Unit 1 Location:
Russellville, Arkansas Type of Licensee:
B&W, PWR, 2568 Mwt Type of Inspection:
Routine, Announced Dates of Inspection:
February 10-11 and 15-18,1977 Dates of Previous Inspection: January 17-21, 1977 O
Principal Inspector:
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@g,/[woJ <>
J/5/77 0.~E. Gaglia'rdo, Reactor Inspector Date Reactor Operations and Nuclear Support Br.
r!:
3/J[72 n ec R. E. Hall, Chief. Engineering D&te'
Support Section Ibb?
R. A. Hermann, Reactor Inspector, D~att!
Engineering Support Section
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Date p. B. Rosenberg, Resetor Inspector, Engineering Support Section Reviewed By:
<t. dict.,1')
3/3f77 O
'G. L. Madsen, Chief, Reacror Operations and Date
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C Nuclear Support Branch J
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-2-SUMMARY OF FINDINGS
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I.
Enforcement Action A.
Violations None B.
Infractions None C.
Deficiencies Contrary to 10 CFR 50, Appendix C, Criterion XVII and Sectior, 11.4.2 of the licensee's QA Program Manual, Attachment F of Procedure 1502.03 (Preparation for Refueling) which was completed on or about February 14, 1977 was not dated and the data sheet for Procedure 1304.28, which was completed on or about February 2,1977, was not dated or signed.
(DETAILS I, paragraph 4.b)
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II.
Licensee's Action on Previously Identified Enforcement Matters Not inspected.
III.
Design Changes
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None IV.
Unusual Occurrences None V.
Other Significant Findings A.
Current Findings 1.
Deviations None 2.
Unresolved Items a.
Use of ASME Code Case 1698 The licensee plans to request NRR permission to implement ASME Code Case 1696 which excludes the use of transfer methods for in-service inspection.
(DETAILSII, paragraph 3.b)
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LRT of Isolation Valves from the Back Side Documents which show the acceptability of leak rate testing (LRT) of valves from the reverse direction of accident pressure were not available on the site for the inspector's review.
(DETAILS III, paragraph 4)
c.
Large Leak Rate Measurements The limitations of the licensee's test equipment prevented
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him from measuring (the excessive leakage from Penetration No. 51 (Type C).
DETAILS III, paragraph 5)
d.
Halogen and Sulfur Content of UT Couplant l
Additional information is needed to certify the Halogen and Sulfur content of the UT Couplant used in the in-service inspections.
(DETAILS II, paragraph 3.c)
l B.
Status of Previously Reported Items 1.
Deviations Not inspected.
2.
Unresolved Items 77-01 V.A.2.a (7701-1) Procedure Control - Local LRT Procedure OP-1304.23 had been revised to resolve several of the previously identified concerns, but several additional discrepancies were identified. This item remains open.
(DETAILS III, paragraph 3)
77-01 V.A.2.b (7701-2) In-Service Inspection Program Prior to beginning the current in-service inspection, the 10-year program was reviewed and approved, procedure OP 1304.58 was revised and a QA audit checklist was prepared.
This item is closed.
(DETAILS II, paragraph 3.a)
VI.
Management Interview
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A.
Entrance Interview An entrance interview was held with Mr. J. W. Anderson on February 10 1977 and with Mr. G. H. Miller on February 15, 1977.
The inspectors
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outlined the scope of the inspection, the documents they wished to O
review, the activities to be witnessed and the licensee personnel to V
be interviewed.
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Exit Interview Exit interviews were held on the site on February 11,1977 and again on February 18, 1977 at the conclusion of each segment of the inspection. Mr. J. W. Anderson and members of his staff were present at each of the exit interviews.
During each of the above exit interviews, the inspectors reviewed the I
actual scope of the inspection and discussed their findings which are summarized above.
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~ DETAILS I Inspector:
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'J. E. Gagliardo, Reactor Inspector Reactor Operations & Nuclear Support Branch 1.
Persons Contacted Arkansas Power & Light Company (AP&L)
J. A. Albers, Plant Operator B. L. Baker, Assistant Maintenance Supervisor C. L. Beardon, Plant Operator 0. W. Cypret, Production Engineer G. M. DuPriest, Shift Supervisor R. T. Elder, Assistant Instrumentation & Control Supervisor F. B. Foster, Production Engineer P. W. Jacobs, Production Engineer P. Jones, Instrumentation & Control Supervisor A. G. Mansell, Production Engineer T. M. Martin, Supervisor Plant Maintenance J. E. Maxwell, Shift Supervisor O
S. S. Strausner, Quality Control Inspector B. A. Terwilliger, Supervisor Plant Operations Fagan Company J. L. Salkeld, Electrical Foreman 2.
Plant Status At the time of this inspection the reactor was in cold shutdown with the core in the process of being defueled for refueling and for the performance of maintenance activities scheduled for the outage.
The licensee's plans included a complete defueling of the reactor so that each fuel assembly arts which may have been left in could be inspected for possible loose p(April 1976) of the holder tube for the system as a result of the failure the vessel surveillance specimens.
3.
Preparation for Refueling During the previous inspection, the inspector reviewed the licensee's preparations for the then forthcoming refueling outage.
The ins 1ector found that the licensee had not yet issued the procedure for the fuel landling.
During this inspection the inspector reviewed procedure 1502.04, Revision No. 6 (Refueling Shuffle), which was issued on February 9,1977 and b
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-6-O received PRC review and approval on February 8, 1977.
This procedure covers the complete unloading of the reactor, the inspection of the bottom of each assembly and the subsequent refueling.
No discrepancies were found.
4.
Refueling Activities The objective of this inspection effort was to detennine if the pre-refueling activities which are required by the Technical Specifications (TS) had been completed and if the ongoing refueling activities were being conducted in accordance with the TS and/or approved procedure.
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a.
Scope of Inspection (1)
Pre-Fuel Handling Activities The inspector reviewed the records of selected surveillance tests, job orders and valve checklists to verify that surveillance test-ing involving the following pre-fueling activities had been completed:
(a) Containment integrity established (b) Refueling machine operation and indexing (c) Ventilation requirements on the fuel storage area (d) Rafueling interlocks (e)
Calibration checks of the neutron (Source Range) monitors (f)
Refueling deck radiation monitors (g) Comunication systems (h) Cooling capability for stored fuel (1) Boron concentration of coolant (j) Crane testing (2)
Fuel Handling Activities The inspectors verified by the review of records and by direct observation that the following conditions were satisfied and that
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the identified activities were being conducted in accordance with the TS and/or approved procedures:
(a)
Core monitoring during refueling operations was in accordance with TS.
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Containment integrity during refueling operations was in accordance with TS.
(c)
Fuel handling was conducted in accordance with the approved procedures.
(d)
Fuel accountability methods were in accordance with the established procedures.
(e) Core internals, leads, vessel studs and nuts, etc., were stored to protect against damage.
(f) Housekeeping on refueling deck and refueling bridge was being maintained to prevent the introduction of foreign material into the vessel cavity.
(g)
Cavity water level was in accordance with TS.
(h)
Baron concentration was in accordance with the TS.
(i) The individuals directing fuel handling activities held a senior operator license and were present directly supervising fuel handlers when work was being performed that could affect the reactivity of the reactor.
(j) A licensed operator was present in the control room and in constant direct comunication with a member of the fuel handling crew when work was being performed that could affect the reactivity of the reactor.
(k)
Radiological controls had been established to minimize the exposure of personnel involved in the fuel handling and to prevent the spread of contamination.
b.
Inspection Findings The records which were reviewed by the inspector confimed the licensee's completion of all required prerequisites for the fuel handling, but the inspector found two discrepancies in this area.
The main fuel bridge is checked out for general operability and for verification of its interlocks by completing Attachment F of Operating procedure 1502.03
'(Test Copy" of this attachment.
Preparation for Refueling).
The inspector reviewed the signed off This document had been completed and had been signed (on or about February 15,1977) by the operator perfoming the checks and by the -hift supervisor. The attachment was not dated to indicate when the document had been completed. The shift supervisor said that Attachment F was completed on February 14 prior to the fuel handling.
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-8-V The area radiation monitors (RE 8009 and RE 8017) which are required by the TS to be operable during fuel handling are functionally checked monthly and calibrated quarterly. The inspector reviewed
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the records of the last calibration and functional test which are documented under Procedure 1304.28.
The completed records did not,
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however, contain the name of the data taker or the date when the tests were run. A licensee representative said that the calibration tests were performed early in the outage (on or about February 2, 1977) before the in-core detectors were withdrawn from the vessel.
Criterion XVII of Appendix B to 10 CFR 50 requires in part that:
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" Inspection and test records shall, as a minimum, identify
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the inspector or data recorder, the type of observation, l
the results, the acceptaMlity, and the action taken in
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connection with any deficiencies noted."
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This requirement is further amplified by Section 11.4.2 of the licensee's Quality Assurance Manual for Operations which states in part:
" Records of test results shall include at least the following:
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Identity of part of material, system, structure, or O
component under test.
"2) Date of test.
"3) Data taken.
"4) Name and signature of individual performing test.
"5) Test results and conclusions."
The inspector noted that the failure to, sign and/or date the above test documents is an apparent item of noncompliance against the above requirements.
A licensee representative said that he did not agree with the inspector.
He said that the test document does not become a quality record until it is reviewed and signed by the supervisor and that the above documents had not been reviewed.
The inspector noted, however, that Section 1.4 of ANSI Standard N45.2.9 (to which the licensee is comitted by his QA Manual) states in part that "For the purposes of this standard, a document is considered a quality assurance record when the document has been completed."
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-9-mU The licensee corrected the above cited documentation discrepancies on February 18, 1977. The Plant Superintendent also issued a inemorandum (JWA-3297) on February 18, 1977 which informed all plant personnel of the cited discrepancies and instructed them to insure that test documents are signed and dated as soon as possible after completion.
Since the licensee had corrected the discrepancies and had taken action to prevent recurrence, the licensee was not requested to respond to this item of noncompliance.
The inspector observed the movement of eight fuel assemblies during the day and evening shifts. All fuel handling operations were conducted under the direct supervision of an operator or a
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shift supervisor holding a senior operators license.
The operators of the refueling machine were licensed operators, but had not received formal refresher training on the operation of the machine.
A copy of the procedures for the fuel handling were maintained by the operator who was supervising the fuel transfers.
No discrepancies i
were noted.
A fuel status board was being maintained in the control room by the licensed operator stationed there and in direct comunications with the fuel handlers. The fuel accountability records (Attachment D of procedu-e 1502.04) were being maintained in the control room by the operat v and on the refueling deck by the shift supervisor. No O
discrepa~ ies were noted.
The inspector toured the containment building (on two occasions to2) ve
(1) observe the maintenance of housekeeping;
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internals and vessel studs and nuts were properly stored, and (3) verify that radiological controls were satisfactory.
The house-keeping and the storage of vital equipment was good, and the licensee's radiological controls were good.
The inspector interviewed the licensee's maintenance supervisor concerning the tests perfomed on the Reactor Building polar crane
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prior to its use and the program for training and certifying crane operators.
The licensee has no formal program for testing the crane or for training and certifying its operators. The crane is given an operational check-out prior to its use and the crane operators are completely checked out on the crane and the signals used for crane operations, but no formal programs for training and certification have been developed.
5.
Maintenance Activities During Refueling
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The objective of this portion of the inspection was to determine if the major maintenance activities which have been scheduled for the refueling outage will be conducted using approved procedures, and were being conducted p
by qualified personnel in accordance with the approved procedures.
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Scope of Inspection The inspector examined the outage schedule which had been developed by the licensee and selected the following major maintenance activities for review:
Inspection (Monthly, Quarterly and Annual) of Diesel Generators
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Test of Main Steam Safety Valves
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Installation of New 011 Cooler on the Diesel Generators
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Test of Presst izer Safety Valves
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Inspection of Hydraulic Shock Suppressors
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Repair of Startup Transformer Buses
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Emergency Feedwater System Modifications
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Seismic Monitor Modifications
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RCS Overpressurization Protection Modification
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The inspector asked for a copy of the procedure to be used for each of the above activities.
The procedures which were provided were reviewed to verify that they contained the following features (if applicable):
(1) Administrative approvals for removing the system from service and returning it to service.
(2)
Check-off lists.
(3) Hold points for inspection / audit and sign-off by QA or other quality verification personnel.
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(4) Control measures to prevent the entry of foreign material into the system.
(5) Provisions for testing following maintenance.
(6) Provisions for assuring that system valves, breakers, etc., are aligned for normal service after the maintenance is completed.
(7) Provisions for removal of jumpers which may be required.
(8) Responsibility for reporting to licensee management details concerning design or construction related deficiencies Ot identified during maintenance.
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The inspector also witnessed the following maintenance activitics to verify that they were being perfonned in accordance with the approved procedures and by qualified individuals:
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Inspection of Diesel Generators (D/G's)
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Installation of New 011 Cooler on D/G's
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Repair of Startup Transformer Buses l
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l b.
Inspection Findings Some of the maintenance activities which were reviewed had not yet i
been scheduled for completion, but the maintenance procedures for all but one of the activities had been completed.
These procedures did provide for administrative approval to release the system for the maintenance and the procedures contained checklists or special data sheets for recording the progress of the maintenance.
The reviewed procedures did not contain the features listed in a(3),
a(4),a(5)anda(8)above.
Certain of these features were not applicable to all of the procedures, but several of the procedures had an apparent need for some of these features.
The inspector expressed concern in this area to the plant management who agreed to O
look into the matter.
They also noted that the post maintenance testing requirements would be identified on the appropriate job order or work permit after the maintenance has been completed.
The maintenance activities which were observed were being condt.cted in accordance with the approved procedures.
The inspector found t. tat QC inspections were not being performed and/or documented during the maintenance activity but would be performed when the maintenance was completed. The inspector questioned whether this practice would assure that the system or component internals were correctly assembled, lubricated and cleaned.
Licensee representatives said that the QC inspection, following the maintenance and the post maintenance tests, would identify any problems associated with the inspector's area of concern.
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50-313/77-03 DETAILS II Accompanying Inspector:
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R. A. Hermann, Rea(tor Inspector Engineering Support Section Reviewed By:
R. E. Hall, Chief Engineering Support Section 1.
Persons Contacted Arkansas Power & Light Compa.y (AP&L)
J. W. Anderson, Plant Superintendent G. Miller, Assistant Plant Superintendent C. Shively, Performance Engineer L. Alexander, QC Engineer L. Humphrey, QA Engineer S. Strausner, QC Inspector F. Foster, Production Engineer Babcock & Wilcox Coastruction Company (B&W)
R. Nelson, Field Quality Representative G. Terning, Group Leader G. Abell, Eddy Current Coordinator A. Gladney, Data Base Operator J. Moran, UT Examiner, Level I N. Ferreira, UT Examiner, Level II K. Filarsky, UT Examiner, Level I V. Brown, PT Examiner, Level II C. Thompson, PT Examiner, Level II 2.
Scope of Inspection The scope of this inspection included: review of the program, review of the procedures, observation of work and review of data for in-service inspection, and review of status of the surveillance for stainless steel piping systems in which stress corrosion cracking had been previously identified.
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3.
In-Service Inspection (ISI)
a.
Unresolved Item - 7701-2 Review and Approval of 10-Year In-Service Ins]ection Program, Revision to Operating Procedure, and Preparation of QA Surveillance Checklists
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Operating Procedure 1304.58, Rev. 2 "In-Service Inspection," was reviewed and approved by the Plant Safety Comittee on January 25, 1977 and approved by the Plant Superintendent on January 27, 1977.
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The Babcock & Wilcox Construction Company In-Service Inspection
(ISI) Manual for ANO-1 is incorporated by reference in Procedure a
OP-1304.58, Rev. 2.
The ISI Manual was also approved separately by the Plant Superintendent.
QC coverage of B&W by AP&L QC is provided by reference in Procedure OP-1304.58 of Procedure OP-1004.17, "On-Site Vendor Control." AP&L QA had prepared a QA Surveillance Checklist for audit of the activity.
This item is closed.
b.
Review of Procedures Five procedures, ISI-130,120, 401,104 and 105, were reviewed for approvals and found to be approved by the B&W Level III Examiner and by AP&L by virtue of the Plant Superintendent's approval of the
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B&W Program.
The NDE procedures listed above require qualification to the requirements of SNT-TC-1 A.
Nine samples of scheduled examinations from the ISI schedule were checked against the require-ments of ASME BP&V Code,Section XI,1971, Sumer 1972 Addenda, Tables15-251 and 261, and were found to provide the examinations required by ASME Code and Technical Specification requirements.
Ultrasonic procedure ISI-130, Rev. 2 " Ultrasonic Examination of Vessel Welds," was inspected and found consistent with the require-ments of the ASME BP&V Code,1971 edition, including Sumer 1972 Addenda,Section XI, IS-213.2 and Section III, Appendix IX, IX-3400, with the exception that transfer methods were not used.
Transfer methods were also not used in any other ultrasonic examination procedures.
Calibration blocks were fabricated from material for which the examination was performed or from material which was metallurgically and chemically similar.
The licensee has requasted approval of ASME Code Case 1698 from NRR which permits waiver of the transfer method. This item is considered unresolved pending NRR approval of the code case usage.
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Liquid penetrant procedure, ISI-240, Rev.1, " Penetrant Examination of Weld and Base Metal Including Studs, Nuts and Washers," was inspected and found consistent with the requirements of ASME Code, 1971 edition, including Sumer 1972 Addenda,Section III, Appendix IX-3600.
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O Eddy current procedure, ISI-401, Rev. 5, " Eddy Current Examination
of OTSG Tubing," was inspected and found consistent with the requirements of Regulatory Guide 1.83.
With the exception of the unresolved item concerned with the transfer
method, no discrepancies were noted during this part of the inspection.
c.
Observation of Work
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The inspector reviewad the qualifications of three Level I, II and III NDE personnel to SNT-TC-1A requirements and found them consistent
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with the requirements.
In addition, the calibration and inspection of approximately 30 pieces of nondestructive test equipment were inspected and found consistent with the appropriate requirements.
In addition, the inspector witnessed the operation of the computer data base system used to verify personnel certification, equipment calibration, consumable materials and the examination results in terms of proper procedural calibration standards and ASME Code acceptance criteria.
During the inspection of consumable materials, a question arose with regard to the certification of Hamikler ultrasonic couplants, batches 668 and 1711.
The couplant certifications stated the halogen content to be less than 50 ppm and the sulfur content to be less than 75 ppm. However, the B&W QA control procedure requires the tests to be perfonned to ASTM-D-129 and ASTM-D-808 with O
acceptable results expressed as less than 1% of the residue. The B&W Field Quality Representative was unable to provide information if couplant met the requirements. Therefore, this item is considered unresolved.
The inspector witnessed the penetrant examinations of Welds DLA2-6 (Figure 4.6.184) and DLA2-6 (Figure 4.6.179) and found the examination i
conducted in accordance with PT procedure ISI-240, Rev. 1.
No reportable defects were found during the examination. The calibration
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(out) for the 00 and 45o ultrasonic testing (UT) and calibration (in)
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for the 600 ultrasonic testing of weld 1A2-discharge line, Figure 4.4.40, in accordance with procedure ISI-120, Rev. 2, was observed by the inspector and found to follow the procedure.
The inspector
discussed the testing with the NDE examiners and found them cognizant of the coverage and scanning requirements.
The inspector witnessed the eddy current examination for defects and wall thinning of tube 73-3 located at o = 58.140, e = 181.60 and the calibration of the eddy current test equipment per procedure ISI-401, Rev. 5, and found the work conducted in accordance with the procedure.
The inspector met with the B&W Eddy Current Coordinator and reviewed the defect data for tubes 34-13 thru 34-16 and the wall thinning data for tubes 29-92 thru 29-95.
Defect examination was conducted at a
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O frequency of 400 KHZ and wall thinning examination at 25 XHZ.
Eddy current examination was found consistent with the require-ment of Regulatory Guide 1.83, "In-Service Inspection of Pressurized Water Reactor Steam Generator Tubes."
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With the exception of the unresolved item regarding UT couplant certification, no discrepancies were noted during this part of the inspection.
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d.
Review of Records The inspector reviewed the B&W In-Service Inspection Manual and found eight inspections scheduled for this 10-year inspection interval. Approximately 30 scheduled examinations were reviewed and found consistent with Tables15-251 and IS-261 of the ASME BP&V Code,1971 edition, Sumer 1972 Addenda,Section XI.
From the schedule, it appears the frequency of examination will meet the minimum 25% requirement for the 40 month interval.
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The following NDE data were inspected:
Figure Description 4.6.33 B Side Core Flood Drain Line - Weld CF4-60
1.3.2 Closure Head to Flange Circle Seam - WH-7 4.1.4 1A1 Suction Line - Pipe to Safe End
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4.1.20 1A2 Discharge Line S/E to Elbow 4.4.11 1A1 Suction Line Circle Seam The records contain:
(1)
Examination data sheets (2)
Equipment data (3)
Calibration Data Sheets (4)
Evaluation Data (5)
Extent of Examination (6) Deviation Notes (7)
Finding (all were free of reportable indications)
(8)
NDE Consumable Material Identification II-4 k
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The records reviewed were consistent with the requirements of ASME BP&V Code,1971 edition, Sumer 1972 Addenda,Section XI.
Data evaluation was conducted in accordance with ISI-64 Rev. 8 and ISI-65, Rev. 2.
All data were reviewed by Level II, SNT-TC-1 A qualified inspector as well as by the Field Quality Representative and the computer system discussed in paragraph 3.c.
No discrepancies were noted during this part of the inspection.
4.
Surveillance of Decay Heat and Reactor Building Spray Piping The inspector discussed with the AP&L Performance Engineer and Assistant Plant Superintendent the status of the surveillance program which the licensee submitted as corrective action for Abnormal Occurrence Report No. 50-313/74-11C, dated October 31, 1975.
The inspector was infomed that radiography of the piping was almost completed and no cracking had been identified in the referenced schedule 10 stainless steel piping systems to date; however, pitting was found in approximately 50% of welds in the heat affected zones.
Sections of 10 inch piping from heat 800201 in the sprey and decay heat piping were removed and will be submitted to Southwest Research Laboratory for analysis.
In addition, a segment of schedule 10, 304 stainless steel piping which had also pitted in the weld heat affected zone was removed for analysis.
The licensee's representatives indicated the most severe pits were thoucht to be approximately 0.020 inch diameter by 0.080 inch deep.
Investigation b
by the licensee of the corrosive attack of these systems is continuing and will be further evaluated during future inspections.
No discrepancies were noted during this phase of the inspection.
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5d-313/77-03 (3 O
DETAILS III Y
CAY Accompanying Inspector:
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gA. B. Rosenberg, R(actor Inspector Engineering Support Section Reviewed by:
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R. E. Hall, Chief, Engifieering Support Section 1.
Persons Contacted l
Arkansas Power and Light Company (AP&L)
R. T. Elder, Assistant Instrument and Control Supervisor R. L. Turner, Assistant Instrument and Control Supervisor D. C. Trimble. Training Coordinator L. Alexander, QC Engineer S. S. Strausner, QC Inspector
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2.
Scope of Inspection Os The scope of this inspection included observation and review of records related to local leak rate testing of containment penetrations and isolation valves.
Status of a previously identified unresolved item relative to the local leak rate testing procedure was also reviewed.
3.
Procedure Control -- Local Leak Rate Testing (7701-1)
The local leak rato test Procedure OP-1304.23, Rev. 2 was reviewed for conformance to 10 CFR 50, Appendix J requirements.
Revision 2 of Pro-cedure OP-1304.23 clarified some previously identified items of concern including venting of the low pressure side of the valves being tested.
Although the previously identified concern relating to normal closure
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of isolation valves was discussed in the procedure, preliminary exercising of valves was not soecifically 5t?;'uded.
Several other concerns with Revision 2 discussed with licensee representatives were: pressure testing between the doors of the personnel and emergency locks is not described clearly enough, in the revised procedure, to perform the test; the pressure decay test does not provide for isolating the air supply prior to performing the test; and there is no requirement to record special means (e.g., assisting valve closure or special equipment to measure large leak rates) if used to effect test completion.
Unresolved item 7701-1 will remain open pending resolution of the above
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items by revision or temporary change to Procedure OP-1304.23.
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Local Leak Rate Test Records The surveillance test intervals were reviewed on the test log for all type "C" (isolation valves) tests performed since the issuance of the station Operating License. Test intervals were also reviewed for the following type "B" (penetrations) tests: electrical penetrations; and personnel and emergency locks (but not the associated door seals).
Surveillance test intervals reviewed were in accordance with 10 CFR 50, Appendix J and Technical Specification (TS) requirements.
The review of Procedure OP-1304.23, Revision 2 indicated twenty-four (24)
penetrations where type "C" tests are performed with about forty-three (43)
valves to be tested in the reverse direction from accident pressure. When requested, the licensee could not provide on-site documentation to verify
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that testing of the valves in a different direction would provide equivalent or more conservative results as required by 10 CFR 50, Appendix J, para-graph III.C.1.
The NRC inspector was informed that the licensee's licensing
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representative knowledgeable in 10 CFR 50, Appendix J requirements was out of town and not available for an interview during this inspection.
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l This matter will remain unresolved pending the results of the NRC review of documents showing the acceptability of testing specific types of valves in the reverse direction.
l 5.
Observation of Testing The inspector observed an attempted type "C" local leak rate test at penetration #51. The leak rate for valve CV-6202 at this penetration was too large to be measured with the test equipment.
The NRC inspector was informed the station did not have the necessary equipment to quantify a leak of that size.
It could not be determined how the reporting require-ment of 10 CFR 50, Appendix J, Section V.B.3 would be met without quantify-ing the as-found condition for the type "C" test.
During observation of the test, the NRC inspector noted that the techni-cians performing the work followed the procedure in-so-far as the test was completed. When the test could not be completed, the technicians determined the likely cause to be a faulty hydraulic actuator, then discontinued the test to seek further guidance.
The training records of the two technicians observed performing the testing were reviewed and found to be current and in accordance with station policy. The pressure gage used for the test was observed by
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the calibration sticker to be within its calibration interval.
The matter relating to measuring large leak rates will remain unresolved until the licensee developes a means of quantifying large leak rates.
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