IR 05000313/1977020
| ML19320A123 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/22/1977 |
| From: | Gagliardo J, Johnson E, Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19320A115 | List: |
| References | |
| 50-313-77-20, 50-368-77-24, NUDOCS 8004140722 | |
| Download: ML19320A123 (13) | |
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N U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Report Nos. 50-313/77-20; 50-368/77-24 Docket No. 50-313 License No. DPR-51 50-368 Construction Permit No. CPPR-89 Licensee:
Arkansas Power & Light Company P. O. Box 551 Little Rock, Arkansas 72203 Facility Name: Arkansas Nuclear One, Units 1 and 2 Inspection At: ANO Site, Russellville, Arkansas Inspection Conducted:
November 2-4, 1977 b
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Inspectors:
J E. Gagliardo, Reactor Inspector Date z
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E. H. Johnson, Reactor Inspector Date Ns d%&
n/w/M R. G. Spangley, Reactor Inspector Dfte /
s Approved By:
Y Mcub a/zz/71 G. L. Madsen, Chief, Reactor Operations and Date
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Nuclear Support Branch Inspection Sumary l
Inspection on November 2-4, 1977 (Report Nos. 50-313/77-20; 50-368/77-24)
Areas Inspected: Routine, announced inspection involving the review of
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test program status; fire prevention / protection controls including the implementation of same; review of preoperational test results including the applicant's evaluation of same; valve controls for the shutdown cooling
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system; Unit 2 jumper and bypass log including the identification of jumpers / bypasses; preventative maintenance activities by the Unit 2 Startup Organization; Unit 2 spent fuel poolwall surveillance; review of preoperational test procedures; battery service test procedure review and (]
test witnessing; and followup of previously identified matters. The J
inspection involved 61 inspector-hours on-site by three (3) NRC inspectors.
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l Results: Of the cen (10) areas inspected, no items of noncompliance or i
One deviatior from an deviations tare identified in.nine (9)(areas. paragraph 3) in one area.
applicant's comitment was identified
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-3-s DETAILS
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1.
Persons Contacted Arkansas Power & Light Company Employees L. Alexander, Quality Control Engineer
- J. R. Anderson, Assistant Production Startup Supervisor J. W. Anderson, Superintendent of Power Plant B. A. Baker, Assistant Operations Supervisor T. L. Bell, Shift Supervisor
- D. N. Bennett, Production Startup Supervisor T. H. Cogburn, Nuclear Engineer
- E. C. Ewing, Assistant Production Startup Supervisor F. B. Foster, Production Engineer
- L. W. Humphrey, Quality Assurance Engineer E. B. Hyatt, Reactor Engineer G. H. Miller, Assistant Plant Superintendent N. A. Moore, Project Manager 3. A. Terwilliger, Supervisor Plant Operations W. W. Washburn, Startup Engineer D. Williams, Production Engineer Bechtel Employees E. Heinz, Startup Engineer W. Parrish, Startup Engineer R. E. Riggs, Startup Engineer E. P. Steinig, Startup Engineer
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Combustion Engineering Employees L. Arnold, Startup Engineer i
- Indicates those attending the exit interview.
2.
Status of Preoperational Test Program At the time of this inspection, the applicant had completed the initial
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testing defined by seventy-eight (78) of the one hundred and eighty-six (186) procedures in the preoperational test program. All but seventeen (17) of the 186 test procedures have been approved for
execution. Seventeen (17) of the eighty-seven (87) startup test procedures had been approved for execution. Twenty-seven (27) of the post fuel load test procedures had been approved by the Test Working
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Group but had not been approved by the Plant Safety Committee.
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Followup on Previously' Identified Findings-(Closed) Noncompliance Item (Infraction 2, Inspection Report 368/77-20): Jumper and bypass log discrepancies. The inspector verified that the applicant had satisfactorily completed his i'
committed corrective action (see paragraph 7). This item is closed.
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(Closed) Deviation (Deviation A, Inspection Report 50-368/77-11):
Q-List and engineering drawing revisions not reviewed in accordance with FSAR. The applicant issued Amendment 43 to the FSAR which corrected this item by redefining the applicant's review require-uents in the FSAR. During inspection 77-20, the inspector expressed concern that the amended FSAR required the applicant's review of only P&ID's and no other safety related engineering drawings. This issue was referred to NRC/IE management for resolution. NRC/IE management noted that since the applicant's AE and NSSS are perform-ing the reviews required by 10 CFR 50, Appendix B, and since the applicant maintains the responsibility for the overall performance
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of the AE and NSSS activities under Criterion I of Appendix B, no
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objection was raised against the amendment. This item is closed.
(Closed) Deviation (Deviation B, Inspection Report 50-313/77-10):
Performance of preventative maintenance items for ANO, Unit 1.
The licensee has determined that the preventative maintenance'(PM) items O
missed prior to July 1977 were not required or desired and that those PM items missed since July 1977 have not been necessary. The. licensee notes that they do not have a manpower problem associated with the performanca of safety related PM items. This item is closed.
(0 pen) Deviation (Deviation C, Inspection Report 368/77-11 and unnumbered Deviation, Inspection Report 368/77-16): Failure to issue operating procedures within the time schedule commitments of the FSAR.
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During inspection 77-11, the inspector found that the applicant had not issued all of his operating, emergency and maintenance procedures as required by FSAR Section 13.5.2.
This item was identified as
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Deviation C, and more fully documented in paragraph 16 of Inspection Report 77-11. The inspector noted in this report that the Plant Superintendent acknowledged the above fact and indicated that a
major staff effort was ongoing to complete these procedures. At that time the Plant Superintendent, in a letter dated July 2, 1977 1/,
formally committed to a completion schedule indicating full compliance to the above FSAR commitment by July 30, 1977. As a result of this,
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the inspector indicated that no formal reply was required for the
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above deviation.
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1/ Letter, JWA-2-349, J. W. Anderson (AP&L) to J. Gagliardo (NRC/IE),
dtd 6/2/77.
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U As a result of follow-up action during inspection 77-16, the inspector again found that the applicant had not completed the e
issuance of the above procedures by the comitted July 30, 1977 date.
In paragraph 10 of inspection report 77-16, the inspector noted that this was an apparent deviation from the applicant's
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comitment stated in the June 2 letter.
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In reply to the above deviation, the Plant Superintendent responded
with a letter dated September 2, 1977 2f indicating the new date of compliance to be October 15, 1977, with the exception of eight procedures that would not be approved by this date for various
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extenuating circumstances.
Further correspondence from the AP&L Manager of Licensing dated September 8, 1977 3/ indicated an.
additional exception in that procedure QC 100T.01 would not be approved by October 15 but would be rewritten and in the review
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process by November 1,1977.. The applicant's formal reply 4/ to the deviation in inspection report 77-16 references the September 2 letter and also indicates the date of October 15, 1977 ar the compliance date. This date was further modified in a letter from the Plant Superintendent dated October 17,19775/ in which he stated:
"My JWA-2-411 of September 2,1977, informed you that
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our Unit Two Procedures would be prepared by October 15,
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1977.
"All identified pir.nt procedures with the exception of those noted in Enclosure l-have been prepared.
There are still approximately 125 procedures in the review and
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approval process that could be supplied to you at this time in their inapproved form. These procedures are being processed through their review and approval process and i
will be approved as soon as possible, but anticipate they will be complete by 1 Nov.,1977."
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At the time of this inspection the applicant had not yet completed the issuance of approximately ninety-three (93) of his operating, emergency and maintenance procedures. Furthermore, QC procedure 1004.01 had not been rewritten because of delay in the receipt of input from the applicant's engineering organization. The above discrepancies constitute an apparent deviation (Deviation A) from the applicant's latest comitment stated in the October 17 letter.
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2/ Letter, JWA-2-411, J. W. Anderson (AP&L) to J. Gagliardo (NRC/IE),
dtd 9/2/77.
3/ Letter 2-097-11, D. A. Rueter (AP&L) to G. L. Madsen (NRC/IE), dtd 9/8/77.
TJ Letter, 2-097-18, D. A. Rueter (AP&L) to G. L. Madsen (NRC/IE), dtd 9/21/77.
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j5 Letter, JWA-2-479, J. W. Anderson (AP&L) to J. Gagliardo (NRC/IE),
dtd 10/17/77.
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-6-(Closed) Unresolved Item (368/7711-1): Requirement for a timely
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response to QA audit findings.
Revision 4 to the NRC approved Quality Assurance Manual requires, in Section 18.5.1.2, that
"When a written response is requested, the audited organization
is responsible for providing the written response in a timely
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manner. This item is closed.
(0 pen) Unresolved Item (368/7711-5): Procedures covering the control of ignition sources. The inspector again reviewed this area. An applicant representative noted that no such procedures have been issued and that they(do not plar M issue any unless specifically i
required to do so.
see paragw n 4). This item remains unresolved.
(0 pen) Unresolved Item (368/7720-2): Ventilation power supplies for electrical switchgear room 2091. The applicant's AE has proposed the installation of additional ventilation fans in each of the inverter rooms which will be supplied by the redundant essential power source. An applicant representative said that this proposal had been approved by the applicant, but he could not locate the letter. This item remains open.
(Closed) Unresolved Item (368/7721-1): Missing sheet in Unit 2 jumper and bypass log. The applicant was successful in retrieving
the missing log sheet. This item is closed.
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M (Closed) Open Item (Paragraph 2.b, Inspection Report 368/77-07):
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Discrepancies in preoperational test procedure 2.064.02.
The discrepancies were corrected in Addendum 5 to the test procedure.
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This item is elosed.
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(Closed) Open Item (Paragraph 9 Inspection Report 368/77-09): Control of Safeguards Pumps when powered through bus tie breakers.
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applicant has issued Revision 1 to operating procedure 2202.05 which describes the special precautions and techniques required for this
evolution. This item is closed.
(0 pen) Open Item (Paragraph 3.c, Inspection Report 368/77-16):
Examination of reactor vessel' internals for indication of vibration.
The inspector reviewed the results of the liquid penetrant examination of the Core Barrel to Flange girth weld which was perfomed on May 24, 1977. This item will remain open until the
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inspector has reviewed the results of the inspections perfomed
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l after hot functional testing.
(0 pen)OpenItem(Paragraph 8,InspectionReport 368/77-20): DC
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Switchgear Room '/entilation. The applicant had submitted a request to his AE to evaluate the adequacy of the ventilation in the switch-gear rooms. This item remains open.
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. I (Closed) Open Item (Paragraph 5.b, Inspection Report 368/77-20):
Test deficiencies in preoperational test procedure 2.064.08. The identified deficiencies were identified and corrected in Deficiency Report No. 2 to Procedure 2.064.08. This item is closed.
(Closed) Open Item (Paragraph 12, Inspection Report 368/77-21):
Posting of Notices of Violation and responses thereto. The applicant had revised Section 7.4 of Administrative Procedure 1005.01 to assign the responsibility for the above posting to the Quality Control Engineer. This item is closed.
(Closed) Open Item (Paragraph 4 Inspection Report 368/77-09) and paragraph 3, Inspection Report 368/77-20): The Operating Staff Training Program was to be modified to include a description of the training provided to engineering and supervisory personnel and to include training in the areas of administrative procedures and plant systems for other than operators. The inspector reviewed amendment number one, dated October 14, 1977, to the ANO Training Plan and determined that each of the above items had been included in the amendment. This item is closed.
(Closed) Open Item (Paragraph 8, Inspection Report 368/77-09): The draft Startup Procedure 2.083.01, entitled Main Steam Safety System and Safety Relief Valves, did not comply with the testing comitment in FSAR chapter 14.1-34ppp. The inspector reviewed the arsproved O
procedure 2.083.01 and determined that the above testing commitment is included in the procedure. This item is closed.
4.
Fire Prevention / Protection The objective of this inspection effort was to determine if the applicant had developed and implemented a fire protection program for Unit 2 which was consistent with the guidance of Regulatory Guide 1.120 and Branch Technical Position 9.5-1.
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Administrative controls which include:
(1) Work (maintenance, modification and construction) control procedures (2) Design Control Procedures (3) Emergency Procedures
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(4)QualityAssuranceSurveillanceProcedures
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Facility Inspections c.
Fire Drills f
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Tour of the control room, cable spreading room, electrical switchgear rooms and numerous areas of the auxiliary building.
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The inspector. found that the applicant had no work control procedures which require special authorization for activities involving welding
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cutting, grinding or other ignition sources.
The applicant also had no written procedure which would require a suitably trained and equipped firewatch to monitor activities
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involving the use of ignition sources. The applicant also had no written procedures (or policies) on the control of combustibles in safety related areas.
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The applicant has quality assurance audit procedures for auditing maintenance procedures, but he had no procedures which require periodic audit of work authorizations for construction, modification and maintenance activities to verify that operating personnel are controlling and authorizing all such activities. There wve also
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no requirements for a QA verification of ignition source controls or a verification that cable penetration seals which are installed, replaced or modified contain no flammable materials.
The applicant is in the process of modifying his administrative procedure for design change controls (see paragraph 3). An applicant representative said that he had not planned to include in this procedure a requirement for reviewing all replacement cable pene-
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tration seals to assure flammable materials are not used. He said
that the procedure does require conformance to all applicable codes and specifications and that specifications do exist for penetration i
seals which contain no flamables.
l The inspector found that the applicant's emergency procedures did not provide instructions on the strategies to be used for fighting
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fires in safety related areas. There were also no formal require-ments for conducting fire drills in safety related areas on any e
established frequency.
Fire drills have been conducted concurrent with the general emergency drills conducted semi-annually under their emergency plan. The fire drills, however, were not conducted in safety related areas of the plant.
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The inspector toured the Unit 2 control room, cable spreading room and other areas of the auxiliary building in the company of an applicant representative. Several discrepancies were noted and
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pointed out to the applicant representative. The most significant
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discrepancy involved the use of untreated wooden ladders and scaffolding in safety related areas.
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It is noted that this inspection was performed concurrent with a fire protection review conducted by two representatives of NRC/NRR. Their review did not provide a basis for the above noted discrepancies, O
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-9-but was. intended to determine the applicant's conformance to the supplemental guidance to Appendix A of Branch Technical Position 9.5-1.
As a result of this NRR review, the applicant may be requested to develop additional controls in the area of fire prevention / protection.
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The above discrepancies have been identified as an unresolved item (368/7724-1).
5.
Preoperational Test Results Review The objective of this inspection effort was to continue the review of completed preoperational test results. This review includes the verification of: review of results by the applicant; resolution of test. deficiencies; and for selected tests on independent evaluation of the test raw data and acceptability of test results.
The following. tests were reviewed:
Test Number Title 2.033.02 Management Holdup Rooms H&V 2.033.04 Shutdown Heat Exchanger Rooms H&V 2.033.11 Ventilation Equipment Room Heaters 2.035.02 Intake structure H&V 2.044.01 Condensate System
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l 2.049.01 Shutdown Cooling
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No items of noncompliance or deviations were noted in this area of inspection. The following items were identified and brought to
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the attention of the applicant. These items will remain open for
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review during a future inspection.
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/'.l Preoperational test procedure 2.049.01 indicates that the appropriate acceptance criteria for the shutdown cooling pumps is 4500 + 400 gpm.
j Section 9.3.6.3.G of the FSAR, which is the safety evaluat 6n of the f shutdown cooling system, indicates that a minimum flow of 4500'gpm'
for each pump.was considered in the evaluation. The completed test indicates that the required 4500 gpm flow was achieved, however, based on the acceptance criteria of the test, a minimum flow of 4100
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i gpm would have been acceptable. The inspector indicated to the applicant that the continued review of test procedures should include an assurance that the FSAR design values and system acceptance criteria
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were being met. The inspector indicated that all system startup.
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engineers should be made aware of this so that there would be assurance that the appropriate acceptance criteria were specified in test
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In this same test procedure, flow indicating controller FIC 5091 was
used as the instrument to measure shutdown cooling flow. However,
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there was no indication in this test procedure that this instrument i
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W-10-had been calibrated. A review of test procedure 2.053.01 indicated
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that this instrument had been calibrated prior to the perfomance of procedure 2.049.01. The inspector indicated that each test procedure should provide enough information, cf itself, in the way of prerequisites or performance steps that the test can stand alone.
In this instance, test 2.049.01 would be considered invalid if test 2.053.01 for some reason had been delayed and thus instrument FIC 5091 had not been calibrated prior to perfoming test 2.049.01.
An applicant representative indicated that an entry will be made on the test endorsement record for test 2.049.01 to indicate the calibration of FIC 5091.
There were no further questions in this area.
6.
Shutdown Cooling System Valve Control During the performance of preoperational test 2.049.01 it was noted that the local control switchas (mounted on the motor control center)
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for several of the shutdown cooling valves did not operate the valve if the control roon: switch was in a contrary position. Startup Field Report 410 was issued to correct this problem. This field report-indicated that as the logic drawings for these valves did not show a local control valve switch, the installed local control switches were to be removed.
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The valves.are 2CV5084-1, 2CV5086-1 and 2CV5038-1. All are in the shutdown cooling system suction line, and the two former valves are located inside the containment.
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Section 7.4.1.5 of the FSAR discusses the requirements for instrumen-tation and controls necessary for plant shutdown from outside of the control room. This section indicates that a capability to achieve
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cold shutdown is available. FSAR Section 7.4.1.5.2 indicates that local control of certain shutdown cooling system valves will be
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necessary to assure that the plant can be placed into cold shutdown.
Since two of the three valves are inside containment, it is not
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clear that these valves could be censidered as locally operable.
This item was discussed with the applicant and it was indicated
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that it would be left open for further inspection. However, based
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on a review of the FSAR, this item is now designated as unresolved (UnresolvedItem 368/7724-2).
7.
-Jumper and Bypass Log -
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During inspection 50-368/77-20, the inspector had identified an item
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of noncompliance involving the jumper and bypass log. The corrective actions for this item, forwarded to the Region IV office by the
. licensee _6f, indicated that the log discrepancies had been corrected and-that a training ' session had been conducted for all personnel regarding the proper maintenance of the jumper and bypass log.
_ 6f AP&L letter, D. A. Rueter to E. M. Howard, NRC, dtd 10/26/77.
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f-11-O During this inspection, the inspector reviewed the jumper and bypass log to determine that the noted discrepancies had been
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completed and that the log was properly maintained. The following five jumper log items were selected to verify that appropriate
' leads were lifted / installed and tagged as necessary:
- System Item Description
9 Battery Charger 2032
32 Load Center 2B5
215 Lifted Lead in 2C40 14'
FI5 5200 in 2C 4 removed
20 Relay 2 Ell for #1 DG
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The inspector also reviewed the applicant's training file for the trairdng of members of the startup group and verified that training had been conducted on October 3,1977 for 33 members of the startup group.
The inspector had no further questions in this area.
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Preventive Maintenance Program The inspector reviewed the program that the applicant has in place to ensure that equipment turned over from construction and which O
has undergone testing is properly maintained to ensure that test results are not voided. The following components were examined under this review: high pressure safety injection pumps (HPSI);
low pressure safety injection pumps (LPSI); and station batteries.
The manufacturer's technical manuals for the above components were
reviewed to determine the recomended preventive maintenance actions for each. The actual program in use was discussed with the cognizant system engineer.
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The following items were noted in this review. The program of preventive maintenance checks for the station batteries, although not specified by written instruction, appears to be in keeping with the manufacturer's recomendations. No such preventive maintenance program, formal or informal, exists for the high pressure or low i
pressure safety injection pumps.
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The manufacturer's technical manual for the motors of these pumps indicates that the motor is to be considered in temporary storage
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whenever it is installed but greater than 30 days will elapse between runs. During temporary storage, the manufacturer indicates the
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following preventive maintenance items be accomplished: (1) energize
the spece heaters; (2) fill the oil reservoir to the proper level; and (3) rotate the. pump several revolutions each month.
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O According to a representative of the applicant, the HPSI and LPSI i
pump motors have space heaters that are automatically energized whenever the pump is shutdown, and all motors with oil bath bearings are checked for proper oil level prior to startup. However,
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no provision is made to ensure that the pump and motor are turned over at the required interval.
l This item was discussed with a representative of the applicant at the exit interview who indicated that it would be reviewed. The
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inspector indicated that at present no items of noncompliance or deviations were noted in this area. However, this area would remain open for further inspection to ensure that the validity of the preoperational testing of safety related components was not negated by the failure to perform the required preventive maintenance checks following turnover from construction.
9.
Surveillance of Spent Fuel Pool Walls By letter dated July 1,19767/, the applicant fomarded a revised report (dated May 14,1976) concerning the repair of the spent fuel pool walls and concerns over stress levels generated in the pool walls, notably at the corners. The report indicates that the
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applicant will establish a surveillance program to map any cracks in the pool walls to determine any abnormal stress patterns. The inspector discussed this program with a member of the applicant's
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staff who was aware of the requirement and indicated that such e program would be in place by the time of the first refueling outage.
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I The inspector had no further questions in this area and indicated that this item would be fomarded to the Office of Nuclear Reactor
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Regulation for possible inclusion in the facility Technical Specifi-cation surveillance requirements.
10.
Review and Witness of the plant Protection System Preoperational Test 1-The inspector began a review of procedure 2.058.01, entitled " Plant Protection System," prior to his -intended witnessing the performance of the test. The test performance had been postponed pending the
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arrival of replacement parts. The review of the procedure is continuing. No questions have been identified to date, 11. Battery Service Test
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During inspection 77-07, the inspector reviewed the results of the
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test discharge of the station batteries under preoperational test procedure 2.002.01. - The results of this test indicated that the
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capacity of the batteries was somewhat less than their rated capacity. The inspector has comunicated this problem to NRC/NRR representatives who have indicated that the batteries would be considered acceptable if they pass the service test.
O 7f AP&L letter from W. T. Cavanaugh to E. M. Howard, NRC, dtd 7/1/76.
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Prior to inspection 77-21, the inspector and other Region IV inspectors had conducted an in-office review of the Battery Service Test procedure (2.002.02).
Coments resulting from this review were discussed with an applicant representative during inspection 77-21.
During this inspection, the inspector reviewed Addendum 1 through 9 to procedure 2.002.02 which had been issued to resolve the inspector's concerns.
The applicant began the battery service tests while the inspector was on-site. The inspector witnessed the testing activities on battery 2011. Test crew requirements appeared to be adequate and the crew was using the appropriate revision of the approved procedures. All of the prerequisites had been met and documented.
The inspector noted that the applicant had not been able to locate the calibration records for the DC Shunt in the test load bank.
This item remains open.
12.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance or deviations. Two unresolved items were identified during this inspection as follows:
r Description Paragraph
'd 368/7724-1 Fire Prevention / Protection Controls
368/7724-2 Shutdown Cooling System Valve Controls
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13.
Exit Interview
The inspectors met with applicant representatives (denoted in para-graph 1) at the ANO site on November 4, 1977. The inspectors discussed
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the scope of the inspection and summarized the inspection findings
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which are detailed in this report.
The Production Startup Supervisor announced that the Unit 2 fuel load date had been moved back to February 28, 1978.
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