IR 05000313/1981006
| ML20004D024 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 04/09/1981 |
| From: | Boardman J, Randy Hall, Hunnicutt D, Jaudon J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20004D022 | List: |
| References | |
| 50-313-81-06, 50-313-81-6, 50-368-81-05, 50-368-81-5, IEB-80-11, NUDOCS 8106080178 | |
| Download: ML20004D024 (15) | |
Text
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h U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Report Nos:
50-313/81-06 License Nos. DPR-51 50-368/81-05 NPF-6 Licensee:
Arkansas Power and Light Company Post Office Box 551 Little Rock, Arkansas 72203 F&cility Name:
Arkansas Nuclear One (ANO), Units 1 and 2 Inspection at:
ANO Site, Russellville, Arkansas Inspection conducted:
March 2-13, 1981
Inspectors:
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J.f,R. Boarcman, Reactor Inspector, Systems and Date Technical Section (P'aragraphs 1 & 4)
w'M 8/
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J./P. [Jaud
, Reactor Inspector, Systems anc
'0(te T(chnical ection (Paragrap s 1, 2 & 5)
b97: 21 Lw W9/B/
D. M. Hunnicutt, Chief, Reactor Projects Section No. 2 Date (Paragraphs 1 & 3)
Approved by:
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R. E. ~Hafl, Chisf, Systems and Technical Section
/Dag.e l3 h 3A~:-m" N/W2/
D. M. Hunnicutt, Chief, Reactor Projects Section No. 2 '/Date
?10608D17%
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~ Inspection Summary:
Inspection conducted during the period of March 2-13, 1981, (Report Nos. 50-313/
81-06 ar.d 50-368/81-05)-
Areas Inspected:
Routine, unannounced inspectien including, follow up on
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previous violations, unresolved and open items (paragraph 2); follow up on IE Bulletin 80-11 (paragraph 3); and surveillance (paragraph 4).
The inspection included 95 hours0.0011 days <br />0.0264 hours <br />1.570767e-4 weeks <br />3.61475e-5 months <br /> on site by three NRC inspectors.
Results:
In the three areas inspected, one apparent violation (failure to follow a procedural requirement on training) was identified in one area, and three apparent violations (failure to comply with Technical Specifications - two instances related to different Technical Specifications and a third instance related to failurs to follow a procedural requirement concerning surveillance)
were identified.
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DETAILS 1.
Persons Contacted Arkansac Power and Light Company i
- J. A. Albers, Planning and Scheduling Supervisor
- T. L. Bell, Operations Superintendent, Unit 2
- B. C. Burchard, Assistant Health Physics Supervisor C. Cole, Planning and Scheduling Coordinator J. Constantin, Training Coordinator, Unit 2
- G. DuPriest; Planning and Scheduling Coordinator E. C. Ewing, Supr rintendent Plant Engineering G. Fisher, Radio Chemistry Supervisor J. Garnett,' Material Management Supervisor G. M. Goodson, Civil Engineer C. Halbert, Mechanical Engineering Supervisor A. Halverson, Assistant Office Services Supervisor R. Hargrove, Training Coordinator L. Howard, Production Engineer, Mechanical
- L. W. Humphrey, Plant Administrative Manager
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- P. Jones, I&C Superintendent
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J. Lamb, Safety and Fire Prevention Coordinator J. McWilliams, Operations Superintendent, Unit 2
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- G. H. Miller, Engineering and Technical Support Manager
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O. Moore, Fechanical Maintenance Training Coordinator
- J. P. O'Han.on, General Manager, ANO V. Pettus, Michanical Maintenance Superintendent l
W. F. Poskey, Electrical Maintenance Supervisor l
- R. Roderick, t'uman Resources Supervisor l
- E. L. Sanders, Maintenance Manager l
- L. W. Schemp, ianager, Nuclear Quality Control l
C. N. Shivelt, Plant Performance Supervisor i
J. R. Summers, Training Coordinator, Unit 1 I
- D. Snellings, Technical Analysis Superintendent B. A. Terwill.ger, QA Superintendent
- J. Vandergrif t, Training and Counseling Supervisor
- Indicates prasence at exit interview conducted March 6, 1981.
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- Indicates presence at exit interview conducted March 13, 1981.
l The NRC inspectors also contacted other plant personnel including clerical, administrative and maintenance personnel.
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Licensee, Action on Previous Inspection Findings l
(Closed) Violation (noncompliance) (313/7916-05; 368/7914-04):
Training
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program inadequacies and failure to implement the training program.
The training program implementation failures included:
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a.
No documented on-the-job training (0JT) for selected maintenance group personnel.
b.
No. technical training for a selected maintenance mechanic.
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No Quality Assurance indoctrination for two employees.
d.
No systems training for four maintenance personnel.
The licensee's actions in response to this item were inspected in July 1980 and documented in IE Inspection Report No. 80-12.
In part, IE Inspection Report noted that the licensee had failed to begin systems training in the first quarter of 1980 as committed to in the licensee's response to the original violation.
IE Inspection Report No. 80-12 also noted that the licensee had not yet promulgated Procedure 1000.15 entitled,
" Station Training Program," which described the overall training program-and establisht general requirements and methods for conducting training.
Additionally, tne Licensee's Procedure 1023.01, entitled, " Training Program Implementation," had not been promulgated, and training was being conducted for both units under a memorandum for Unit 1 (G. H. Miller memorandum, dated August 4, 1980).
During this inspection, the NRC inspector found that the licensee had issued Procedures 1000.15 and 1023.01.
Procedure 1023.01 had since evolved into an additional 22 procedures (1023.03 through 1023.24) for the implementation of various aspects of the training program.
The NRC inspector also found that the requirement for on-the-job training (0JT) records was defined in Licensee Procedure 1023.05, Revision 0 (December 7, 1980), "On-the-Job Training Program."
Four individual 0JT records were reviewed and found to be maintained in accordance with procedures.
Training records reviewed indicated that systems training, a two and one half day ind.
-ination course, was being given to all licensee employees at the ANO sice as was initial Quality Assurance indoctrination.'
The NRC inspector reviewed 15 individual training' records selected at random.
From this review, the NRC inspector concluded that maintenance personnel were being given appropriate technical training.
This item is closed.
(Closed) Violation (noncompliance) (313/7915-05):
Requalification program requirements not met.
The specifics of this item included a failure of the licensee to give three required requalification lectures and failure to complete the annual performance evaluation of a licensed operator.
Additionally, the licensee, in his response to the initial item, had committed to develop an " Evaluation Status Log" to track until corrected deficiencies such as those listed above.
The NRC inspector found that the licensee had implemented a requalification training program (Procedure 1023.08) and that an " Evaluation and Status Log" was being maintained for the qualification training of Senior Reactor Operators and Reactor Operators on each unit.
Both of these logs met the licensee's procedural requirements (1023.08) but were in differenc format.
From the log for each unit, it was established that required attendance at requalification lectures was tracked, as were the completion and filing of annual evaluations.
This item L
is closed.
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(Closed) Violation (noncompliance) (313/8012-01; 368/8012-01):
Failure to take prompt and effective corrective action for violations 313/7916-05; 368/7914-04 and 313/7915-05, which were.related to training.
The NRC inspector found that the licensee had taken specific corrective actions for these items as described in preceding paragraphs of this section.
Additionally, it was determined that other violations, unresolved and open items related to_ training as described in.the following paragraphs had been corrected, clarified or completed as appropriate and as committed by the licensee in the following letters:
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a.
W. C. Cavanaugh II, letter 1-080 - 10/2-080-10 of August 13, 1980, to Karl V. Seyfrit.
b.
W. C. Cavanaugh III letter 1-110-12 2-110-18 of November 12, 1980, to V. Stello This item is closed.
(Closed) Open Item (313/8012-02; 368/8012-02):
Licensee's procurement procedures did not provide for technical review of replacement specifica-tions of safety-related meterial.
The licensee's Quality Control Manual allowed any member of the plant staff to originate a requisition for safety-related material.
The requisition originator was assigned responsi-bil'ity for providing specifications on the requisition which were equiva-lent to or better than original procurement.
The item was open pending promulgation of licensee procedures
.o provide for a technical review of reqvisitions in order to assure '. hat procurement specifications were adequate and met the criteria of "aquivalent or better than original pro-curement."
Licensee Procedure 1000.10, Revision 0 (January 11, 1980),
" Control of Procurement," assigned, in paragraph 5.6.1, the Plant Engineering Superintendent the responsibility to establish baseline quality requirements in accordance with design specifications for each.
requisition.
Three recent requisitions were reviewed and found to contain a completed technical review.
This item is closed.
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(Closed) Open Item (313/8012-03; 368/8012-03):
Licensee implementation of procedures to provide a preplanned and scheduled requalification training program which meets the requirements of 10 CFR Part 55, Appendix A.
The NRC inspector reviewed Licensee's Procedure 1023.08, Revision 1 (January 8, 1981), " Operations Training Program."
This procedure required a requalification training program which met the requirements of 10 CFR Part 55, Appendix A.
Review of the " Evaluation and Status Log" maintained by the Training Coordinator responsible for licensed operator training on each unit indicated that training for licensed operators was scheduled and conducted in a preplanned manner.
The NRC inspector noted that the Training Coordinators for Units 1 and 2 were maintaining their respect'<e " Evaluation and Status Logs" in differing format, although the format used in bo % cases met the requirements of Procedure 1023.08.
The licensee's training representatives stated that this was the result of instituting the logs before Procedure 1023.08 was issued in final form.
The licensee's training representative also stated that both " Evaluation and Status Logs" would be maintained in identical I
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format for the 1981-82 requalification training cycle.
This item
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(Closed) Violation (noncompliance) (313/8012-04; 368/8012-04):
Licensee failed to provide requalification training in all subjects identified as weak and failed to re-examine operators at the conclusion of that train-ing which was given in subjects identified as weak.
Review of " Evaluation and Status Logs" for Units 1 and 2 showed the weak subjects were identified for each operator as a resu*t of the 1980 annual requalification examina-tion, that retraining lectures in the appropriate subjects had been given to required individuals, and that re examinations were given after the retraining.
This retraining was conducted in accordance with the Licensee's Procedure 1023.08.
This item is closed.
(Closed) Open Item (313/8012-05; 368/8012-05):
Licensee to implement a training program which includes guidance in the area of requalification lesson plans.
The NRC inspector found that the Licensee's Procedure 1023.03, " Standards for Training Documents," contained specific guidance on the preparation, approval and use of lesson plans and was applicable to requalification training.
Interviews with the Training Coordinators responsible for requalification training on each unit indicated that they were cognizant of the requirements of Procedure 1023.03.
The inspector reviewed two completed lesson plans and one in draft.
This itam is closed.
(Closed) Open Item (313/8012-06; 368/8012-06):
Licensee will review and resolve the potential for requalification examination compromises resulting from giving a single examination (per unit) over a prolonged period.
The NRC inspector found that, for each unit, the licensee had scheduled annual requalification examinations to be given in a period of less than a week vice the previous practice of giving this examination over a period of two to four months.
This item is closed.
(Closed) Unresolved Item (313/8012-08; 368/8012-08):
Licensee was unable to retrieve readily the records of reactivity control manipolations.
The NRC inspector reviewed the training records of two licensed' operators for each unit and found that these records now contained appropriate records of reactivity manipulations.
Licensee Procedure 1023.08, Revision 1 (January 8, 1981), " Operations Training Program," delineates 27 specific evaluations considered to be reactivity control manipulations.
The NRC inspector reviewed the Unit 1 " Evaluation and Status Log" in which the Training Coordinator maintained a matrix of operators versus types of reactivity control manipulations in order to track the completion of required manipulations and the filing of substantiating records.
This item is closed.
(Closed) Unresolved Item (313/8012-09; 368/8012-09):
Licensee failed to retrieve readily the records of annual evaluations of Senior Reactor Operators (SR0s) and Reactor Operators (30s).
The NRC inspector found that each Training Coordinator maintained a matrix for SR0s and R0s qualified on i
their respectiva units and the date of the last evaluation of each operator.
These matrices indicated that the licensee operators had been appraised of their latest evaluation.
Fourteen annual operator evaluations selected at random were reviewed by the NRC inspector.
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licensee had apparently met the regulatory requirements for annual
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, evaluations and the Training Coordinator was able to retrieve supporting records, the NRC inspector found that evaluations reviewed did not provide as much information or detail as was apparently available, thereby limiting the effectiveness of the evaluations.
The NRC inspector discussed his concern in this area with the licensee's senior on site representative.
This item is closed.
(Closed) Open Item (313/8012-10; 368/8012-10):
Licensee failed to -
retrieve readily the records of training on facility design changes.
The NRC inspector found that the licensee was maintaining records of training conducted on facility design changes and that these records were retrievable.
Discussion with the Resident NRC inspector revealed that'the Resident-Inspector had monitored'some recent Unit 1 training lectures regarding design changes accomplished during the refueling outage of Janaury - March 1981.
This item is closed.
(Closed) Violation (noncompliance) (313/8012-11; 368/8012-11):
Licensee failed to conduct fire brigade training at the frequency required by-Technical Specifications.
Technical Specifications for Unit 1 require that fire brigade training be conducted for Unit 1 "six times a year."
For Unit 2, the Technical Specification requirement for fire brigade training is " quarterly." The NRC inspector found that the licensee had contracted to have professional instruction given to the fire brigade for each unit on a weekly basis - each Thursday afternoon.
Thus, because of normal shift rotation, each member of each unit's fire brigade would receive training every four to six weeks, depending upon the number of shifts.
This rate of fire brigade training exceeded the Technical Specification requirements.
The NRC inspector also found that a Training Coordinator was assigned to track fire brigade training.
The NRC inspector noted records of fire drills conducted October 15 and December 19, 1980,
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and February 25, 1981.
The NRC inspector noted that, although fire brigade training had been conducted weekly, there had been no 'participa-tion by Unit 1 operators during January or February 1981.
Licensee representatives stated that this had been a matter of temporary expediency during the Unit 1 refueling outage and that training for Unit 1 personnel would be recommenced immediately so that the Technical Specification training requirement of six times a year for Unit 1 would be met.
The-NRC inspector noted that some Unit 1 personnel did attend the fire brigade training session conducted on March 12, 1981.
Licensee management stated that in meeting the Unit 1 Technical Specification requirement of conducting training six times a year, it was their intent not to exceed a quarter between training sessions.
This item is closed.
(Closed) Open Item (313/8012-12; 368/8012-12):
Licensee to implement training which establishes minimum training requirements regarding adminis-trative procedures.
Licensee's Procedure 1023.07, Revision 0 (December 7,
.1980), " General Employee Training Program," implements the requirements of AilSI 18.1, Section 5.5 regarding training in administrative procedures, thus meeting the Technical Specification requirement, paragraph 6.4.1.
.The NRC inspector found that this training was documented in 13 training records selected at random and checked.
This item is closed.
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(Closed) Unresolved Item (313/8012-13; 368/801E-13):
10 CFR Part 50, Appendix B, Criterion II requires that all personnel working in areas affecting quality shall receive indoctrination and training to assure that suitable proficiency in quality related activities is achieved and
. maintained.
Section 2.7 of the licensee's QA Manual for operations required initial QA indoctrination training but was silent to periodic retraining.
This item was referred to NRC management for resolution.
The NRC inspector found that the licensee, since inspection 80-12 was conducted, had established the requirement for annual QA reindoctrination training in Procedure 1023.07, Revision 0 (December 7, 1980).
Since this
.is considered to fulfill the requirements of 10 CFR Part 50, Appendix B, Criterion II, this item is closed with regard to the licensee.
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-(Closed) Violation (noncompliance) (313/8012-14; 368/8012-14):
Licensee failed to document requalification training and nonlicensed training in such a manner that training records were identifiable and retrievable.
The NRC inspector found that the licensee had revamped his method of maintaining training records.
The method currently used is:
a.
Training record summaries are maintained in a computer data basa.
These summaries, which are by individual, contain a short title of each segment of training received, the date of,.the training, and the microfilm address of the actual records, b.
The training data base may also be addressed by training subject to show when specific training was given to individuals.
c.
The training data base summaries were available on hard ccpy printout or could be reviewed on a terminal in the training office.
It was noted that the data display terminal was programmatically limited to 20 pages for each individual but that hard copy printouts provided a complete summary of each individal's training.
d.
Training and qualification related records (e.g., annual evaluations)
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for licensed operators are also stored in this data base and the
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microfilm records.
e.
The training microfilm records are maintained on reels which receive special handling and are not available to all members of the plant staff as are many other microfilm records.
This prevents unwarranted disclosure of personal information in training and qualification
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related files and serves to protect examination materials from compromise.
Licensee representatives also informed the NRC inspector of improved programming for the training data base.
The improved programs were designed to provide useful summaries such as " null" listings (i.e., lists I
of personnel currently employed at ANO who had not received specified training) and training expiration warning.
The improved programming
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was scheduled for implementation by April 1,1981.
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The NRC inspector also found that individual Training Coordinators maintained working files to track training in progress under their cognizance and to provide a summary of required training, when it was completed, and when it was verified as on microfilm and in the computer data base.
The NRC inspector verified 79 record items on the microfilm records from addresses found in the data base during the course of the inspection.
This item is closed.
During the review of records related to operator requalification, the NRC inspector noted that several licensed operators had not completed a review of abnormal and emergency' procedures in more than a year.
This review is required by Licensee's Procedure 1023.08 to be conducted twice by each operator and this requirement is applicable by Licensee Procedure 1023.08 to all licensed personnel, whether or not they normally stand watch on a reactor.
For Unit 1, one licensed operator had last completed the required review in November 1979; another operator had not completed a review since November 1978; and two operators had not completed reviews since May 1978.
For Unit 2, one operator had not completed a review since November 1979, and another operator had last completed the required-review in February 1980.
10 CFR Part 50, Appendix B, Criterion V requires that " activities affecting quality shall be prescribed by documented instruct. ions, procedures or drawings... and shall be accomplished in acc'ordartce with these instructions, procedures or drawings."
The failure of four operators licensed on Unit 1 and two operators licensed on Unit 2 to carryout one of the licensee's procedural requirements for maintenance of qualification is an apparent violation of 10 CFR Part 50, Appendix B, Critericn V.
The NRC inspector noted that none of the personnel who had not coalpleted the review of abnormal and emergency operating procedures were normally utilized by the licensee as watchstanders.
(313/8016-01; 368/8105-01)
3.
Licensee Actions Related to IE Bulletin No. 80-11
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a.
Requirements IE Temporary Instruction (TI) 2515/37, dated July 3, 1980, requires that the licensee's actions related to the design of masonry (concrete block) walls in the proximity of safety related systems or h wing attachments from safety-related syst us (IE Bulietin No. 80-11, dated May 8, 1980) be verified by on-site inspection.
The NRC inspector reviewed the licensee's responses to IE Bulletin No. 80-11, dated July 3,1980, with attachnients and January 29, 1981, with attachments.
The NRC inspector verified that the licensee's corrective actions, calculations, and evaluations of safety-related concrete masonry walls and/or safety-rela' ad equipment and systems associated with the concrete walls met the design and functional adequacy required by IE Bulletin No. 80-11.
The NRC inspector verified that these concrete masonry walls met
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their respective intended functions by discussion with a civil engineer, who was cognizant in this area; by visual inspection of representative walls selected by the inspector; and by review of licensee calculations and the assumptions used in the calcula-tions and evaluations.
b.
Licensee's Evaluation Methods
The licensee used applicable building design codes as stated in'
ANO-1 FSAR, Volume II, Section 5.5.2, pages 5-49 and 5-50; ANO-1 FSAR, Volume III, Appendix 5. A., pages 5. A-1 through 5. A-5; and ANO-2 FSAR, Volume II, Sections 2.8.4.2 through 3.8.4.6 (pages 3.8-38 through 3.8-45) and present state-of-the-art techniques.
The loads and load combinations, the material properties, the design allowables, and the methods of calculations were acceptable in that these parameters were taken from the applicable FSAR and governing codes.
Assumptions used appeared to be conservative (Example:
the collar joint shear strength for mortar was assumed to be zero for the calculations and evaluations).
c.
General Discussion The NRC inspector performed a visual inspection (examination) of representative concrete masonry walls to determine whether the licensee had evaluated all concrete masonry walls which support Seismic Category I pipes, Seismic Category I attachments other than pipes, or are in the proximity to safety-related systems.
Licensee's plan views of each elevation level for Unit No.1 indicated a total of 75 concrete masonry walls met this classifica-tion.
A total of 104 concrete masonry walls met this classification in Unit No. 2.
The NRC inspector Niected ten representative concrete masonry wal's I
from the plan views for Unit No. 1 and fifteen fer Unit No. 2.
A visual inspection of each of these twenty-five concrete masonry walls was performed to verify that each of these walls had been evaluated by the licensee, as required by IE Bulletin No. 80-11.
The NRC inspector's detailed inspection verified that the licensee had met all d Bulletin No. 80-11 requirements related to these twenty-five concrete masonry walls.
From the inspection results (examinations)
of the twenty-five walls out of a total of 179 concrete mnonry walls, it appears that the licensee met the requirements of IE BG letin No. 80-11.
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Insoection (Examination)
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The NRC inspector selected the concrete masonry block walls listed below for inspection and determined that none of the selected walls should have a significant adverse effect on safety-related systeins or components (electrical, piping, HVAC, or instrumentation)
during a postualted OBE or a DBE.
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Unit No.
Wall No.
System Discussion
4-8-58 Proximity to safety-relatea systems
4-B-186
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4-B-187_
Chilled water Seismic Category I pipes (chilled water piping attached)
6-B-35 Proximity to safety-related system
6-B-36 Proximity to safety related system Seismic Category I attachments other
4-B-202
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than pipes
4-B-210 Proximity to safety-related system
4-B-196 Proximity to safety-related system
4-B-212 Proximity to safety-related system
6-B-39 Proximity to safety-related system
23-B-17 Proximity to safety-related system
23-B-19 Proximity to safety-related system
24-B-82 Keyed joint Proximity to safety-realted system
24-B-59 Proximity to safety-related system
24-8-80 Proximity to safety-related system
24-B-54 Proximity to safety-related system
24-B-232 Proximity to safety-related system
24-B-234 Scismic CC1 F - Freon 12 Room (ventilation Category I att$cked)
pipes
24-B-223 Seismic Attachments Other Than Pipe Category I (electrical (electrical)
23-B-3 Proximity to safety-related system
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Unit No.
Wall No.
System Discussion
24-B-217 LER 81-02 Atachments other than piping issued on (electrical)
2/2/81 report-ed additional
' bracing (verified by inspection)
24-B-218 LER 81-02 Attachments other than piping issued on (electrical)
2/2/81 reported additional.
bracing (verified by inspection)
26-B-53 Attachments other than piping (electrical)
26-B-54 Attachments other than piping (electrical)
4.
Licensee Surveillance Program for Unit 1 The NRC inspector reviewed the licensee's surveillance program for conformance with regulatory requirements and implementing procedures and instructions.
The NRC inspector noted and discussed with licensee representatives the following cases of apparent violations of their regulatory requirements and with their approved procedures and instruc-tions.
a.
The NRC inspector reviewed approved Licensee Procedure 1104.32, Revision 2, Supplement II, " Control Room Emergency Ventilation and Isolation Test." This procedure doet not include the requirement delineated in Section 4.10.2 of the Technical Specifications regarding the time required for the ventilation dampers to isolate
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the Control Room upon receipt of a high radiation signal.
A review of the records of the performance of the last three surveil-lance tests performed on March 18, 1977, February 21, 1978, and October.9, 1980, verified that accomplishment of this requirement had not been documented.
Technical Specification surveillance requirement 4.10.2 states:
"At intervals not to exceed 18 months, automatic initiation of the Control Room emergency air conditioning and isolation system shall be dcmonstrated to meet the requirements of Specification 3.9.'
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Cubsection 3.9.1.f of Specification 3.9 states:
"The dampers shall isolate the control room within ten seconds after receipt of a high radiation signal."
Approved Licensee Procedure 1004.12A, Revision 6, Change 2, Attachment B, lists Licensee Procedure 1104.34 as the applicable document for accomplishment of Technical Specification 4.10.2.
The apparent failure of licensee personnel to document the requirement to demonstrate that the Control Room Emergency isolation dampers isolate the Control Room within ten seconds after receipt of a high radiation signal co s titutes an apparent violation of Technial Specification 4.10.2.
(313/8106-02)
b.
The NRC inspector reviewed the licensee's surveillance program utilizing approved Procedure 1004.12A, Revision 6, Change 2,
" Operational Test Control," with the follering findings:
1)
Procedure 1004.12A, paragraph 3.1.1, states:
"All surveillance calibration, checks, inspections, tests requir4d by Section 4 of the Technical Specifications
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are specified on the Master Test Control List."
(This list is Attachment A to Procedure 1004.12A)
In fact, many surveillances required by Section 4 of the Technical Specifications are found in Attachment B to Procedure 1004.12A which is " Unit 1 Reactor Plant Equipment Tests and Frequency List."
2)
The procedure apparently being~used by the licensee for accomplishment of the integrated engineered safeguards system test is Procedure 1305.06, Revision 0, " Integrated E.S. System Test," approved February 28, 1981.
Approved Procedure 1004.12A, Revision 6, Change 2, Attachment B lists Procedure 1304.08, " Integrated Engineered Safeguards System Test," as being the applicable approved procedure.
During the inspection, the NRC inspector cbtained, from the licensee's Document Services, copies of approved valid Procedures 1304.08, Revision 3 and 1305.06, Revision 0.
The NRC inspector could find no approved procedure specifying the use of Procedure 1305.06, Revision 0.
Procedure 1004.12A is apparently in the process of being replaced by two new procedures as follows:
1000.09, Revision 1, " Surveillance Test Program Control,"
(This procedure was approved Janaury 14, 1981), and 1001.09 (unissued), " Master Test Control List."
Since these procedures are expected to be used in canjunction L
with each other, existing approved Procedure 1004.12A, Revision 6, Change 2 still appears applicable until
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Procedure 1001.09 is issued and Procedure 1004.12A is deleted.
Discussions with licensee personnel indicated that they apparently were using an unapproved " Master Test Control List" from unissued Procedure 1001.09 rather than the attachments
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to approved Procedure 1004.12A, Revision 6, Change 2.
3)
As discus'.ed in paragraph 2) above, at the time of the inspection apparently two approved procedures were issued and in effect covering the Integrated Engineered Safeguards System Test; i.e.,
1304.08, Revision 3, and 1305.06, Revision 0.
This situation apparently resulted from the failure of licensee personnel to comply with the requirements of approved Procedure 1000.06, Revision 2, " Procedure Review, Approval and Revision Control for safety-related procedures.
These requirements included an independent review and task the reviewer to " complete Form 1013.02M, ' Deletion to Station Procedure,' if this procedure supersedes any other procedure."
Licensee personnel could not produce evidence that a Form 1013.02M had been completed and issued in this case.
Licensee Procedures 1004.12A, Revision 6, Change 2 and 1000.06, Revision 2 implement the requirements of Criterion V of 10 CFR Part 50, Appendix B, which requires that the licensee activities affecting quality shall be prescribed by documented procedures and instructions and shall be accomplished in accordance with these instructions.
Failure of licensee personnel to comply with the requirements of Procedures 1004.12A and 1000.06 constitutes an apparent violation of 10 CFR Part 50, Appendix B, Criterion V.
(313/8106-03)
c.
The NRC inspector reviewed the licensees procedures for, and documenta-tion of, surveillances for the Penetration Room Ventilation System covered by Technical Specification 4.11.
Based on documentation provided by licensee personnel, surveillances required by Specifica-tions 4.11.1 relative to pressure drop across the combined HEPA filters and charcoal absorbers and 4.11.4a relative to DOP, halogenated hydrocarbon, etc., tests were accomplished on or about August 31, 1977, April 24, 1979, and Janaury 19, 1581.
Technical Specifications 4.11.1 and 4.11.4a each require accomplish-ment of the sioject tests "at intervals not to exceed 18 months."
In the case of surveillance tests to both specifications, the last two intervals exceeded 18 months.
Apparent failure of licensee personnel to comply with the require-ment of Technical Specification,4.11 constitutes a violation.
(313/8601-04)
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d.
~The NRC inspector reviewed implementing procedures and documentation of accomplishment of Technical Specification for surveillance of.
the hydrogen purge system.
The Technical Specification and procedure for calibration of the hydrogen analyzer are Technical Specification 4.12.4 and Procedure 1304.30, Revtsion 4.
Records of
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accomplishment available to the NRC inspector innicated that the last calibration of the units-was performed between April 5 and 19, 1979.
Technical -Specification 4.17. 4 requires that the-" hydrogen concentra-tion instruments shall be calibrated once every 18 months with proper consideration to moisture effect." Attachment B to approved Procedure 1004.12A, Revision 6, Change 2, " Hydrogen Purge Analysis and Flow Ind' cation Instrument Surveillance," issued to implement the require-ments of 10 CFR Part 50, Criterion V further limits the calibration interval to " intervals not to exceed 18 months."
Failure of licensee personnel to comply with the calibration interval specified in Procedure 1004.12A constitutes another example of an apparent violation of procedures and 10 CFR Part 50, Criterion V as stated in pargraph 4.c. above.
(313/8106-03)
5.
Exit Interview Exit interviews were conducted March 6 and 13, 1981, with Mr. J. P.
O'Hanlon, General Manager, ANO and other members of the ANO staff denoted in paragraph 1.
At these meetings, the scope of the inspection and the findings were summarized.
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