IR 05000313/1982033
| ML20028G095 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 01/06/1983 |
| From: | Johnson W, Mccrory S, Murphy M, Stewart R, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20028G076 | List: |
| References | |
| 50-313-82-33, 50-368-82-33, NUDOCS 8302070391 | |
| Download: ML20028G095 (10) | |
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APPENDIX B U.
S.' NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: 50-313/82-33 50-368/82-33
Dockets: 50-313 Licenses: DPR-51 50-368 NPF-6 Licensee:
Arkansas Power and Light Compa1y Post Office Box 551 Little Rock, Arkansas 72203 i
Facility Name:
Arkansas Nuclear One (ANO), Units 1 and 2 Inspection At:
ANO Site, Russellville, Arkansas Inspection Conducted:
November 15-19, 1982
Inspectors:
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.7 M. E. Murphy, Reactor /Insp'ector Date'
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Reactor Project Section C (Paragraphs 1, 2, 4, 5, 7, 8)
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fy R. C. Stewart, Reactor Inspector Date Reactor Project Section A (Paragraphs 1, 6, 8)
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p,y S. L. McCrory, Reactor, Inspector Date Reactor Project Section A (Paragraphs 1, 2, 3, 8)
Reviewed:
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'l. F. Westerman, Chief /
Date Reactor Project Section A Approved:
[fb dN3 W. D. dilfhnson, Chief D5 te'
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Reactor Project Section C 8302070391 830118 PDR ADOCK 05000313 G
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Inspection Summary Inspection Conducted November 15-19, 1982 (Report 50-313/82-33)
Areas Inspected:
Routine, unannounced inspection of personnel qualification,
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design changes and modifications, maintenance and maintenance program, and fire protection / prevention program implementation.
The inspection involved 43 inspector-hours by three NRC inspectors.
Results:
Within the five areas inspected, one apparent violation (failure of the plant safety committee to investigate a licensee identified Technical Specification violation paragraph 3) was identified.
Inspection Conducted November 15-19, 1982 (Report 50-368/82-33)
Areas Inspected:
Routine, unannounced inspection of personnel qualification, design changes and modifications, maintenance and maintenance program, and fire protection / prevention program implementation.
The inspection involved 53 inspector-hours by three NRC inspectors.
Results: Within the five areas inspected, two apparent violations (failure of l
the plant safety committee to investigate a licensee identified Technical Specification violation paragraph 3; and failure to maintain penetration fire barriers functional paragraph 4) were identified.
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-3-Details 1.
Persons Contacted Arkansas Power and Light Company
- 0. Brown, Engineer
- L. Dugger, Special Projects Manager
- E. Ewing, Engineering Manager
- L. Humphrey, Administrative Manager J. Lamb, Safety and fire Protection Coordinator
- J. Levine, General Manager
- J. McWilliams, Operations Superintendent, Unit 1
- E. Sanders, Maintenance Manager G. Storey, Safety and Fire Protection Coordinator The NRC inspectors also contacted other plant personnel including adminis-trative, clerical, document and drawing control, and engineering personnel.
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- Denotes presence at the exit interview conducted November 19, 1982.
2.
Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (8133-1; 8132-1).
This item was unresolved pending interpretation by the Office of Nuclear Reactor Regulation of the intent of Branch Technical Position 9.5-1 concerning the number of fire drills to be conducted per year.
Subsequently, the licensee committed to the performance of four fire drills per year for each shift fire brigade.
A review of the records of fire drills to date for 1982 confirms that the licensee is meeting the commitment.
This item is closed.
(Closed) Open Item (8132-01).
This item was open pending issue and review of supporting procedures for the design control program.
These procedures I
have been issued and design change packages are now reviewed by a safety and fire protection coordinator for fire hazards involved during the modification work and the effect of the proposed modifications on the fire hazards analysis.
This item is closed.
(Closed) Open Item (8132-02). This item was open for review of the licensee's action concerning the two added fire suppression deluge systems which were not yet operational and were isolated causing the closed supervised inlet valves to send a continuous trouble alarm condition to the control alarm panel.
One system is now in operation and its inlet valve is open.
The second system is still isolated, but the circuitry in
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-4-this alarm system allows a ring through on any new incoming trouble condition and, therefore, the alarm is still functional.
This item is closed.
(Closed) Open Item (8132-03).
This item was open for evaluation of the licensee's fire brigade training program with respect to specific fire brigade leader training.
Evaluation of drills and questioning of indi-viduals new shows that the training program prepares any brigade member to assume the duties of fire brigade leader.
This item is closed.
(Closed) Open Item (8201-04).
Inspection Report 82-01, paragraph 9, PSC Review of Technical Specification Violations.
This item is superseded by the violation cited in this inspection report (313/8233-01; 368/8233-01).
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This item is closed.
3.
Personnel Qualification Program (Units 1 & 2)
The NRC inspector verified that the licensee has established in writing the minimum educational, experience or qualification requirements for the following types of positions:
Principal operating staff First level supervision Onsite technical engineering staff.
The licenrae's requirements for the above positions are found in the FSAR, Technical Specifications (referring to ANSI N18.1-1971, and Reg. Guide 1.8, 1975), ANO Procedures 1004.04 (QC personnel) and 1023.02 (Employment and Placement), the Quality Assurance Manual (QAP-8), and Non Bargaining Position Descriptions.
These documents satisfactorily identify qualification requirements and assign responsibility to appropriate personnel to ensure qualifications are met.
l The NRC inspector reviewed the personnel files of 10 managers and supervisors subject to the qualification requirements of ANSI N18.1-1971.
As a result of this review, it was discovered that the present maintenance l
manager was originally assigned to the position in September 1980 without l
the required one year of experience at a nuclear power plant.
The NRC l
resident inspector stated that the licensee had issued nonconformance report (NCR) 81-007-0 on January 23, 1981, addressing the violation.
Upon review of the NCR, it was noted that it addressed only the specific case of the maintenance manager and provided no corrective action to prevent recurrence.
(It should be noted that Procedure 1023.02 had been approved
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-5-and issued several months before the selection of a new maintenance manager.
This procedure provided specific direction in step 6.2.7 to ensure compliance with ANSI N18.1-1971).
The NCR, in effect, reported a violation of Technical Specification 6.3.1.
Per Technical Specifica-tion 6.5.1.6.e, all reported violations of Technical Specifications are to be investigated by the Plant Safety Committee (PSC) and a written report of action taken submitted.
The NCR appeared to have been reviewed only by a QC engineer.
Review of the PSC meeting minutes for January and February of 1981 indicated no PSC review of the Technical Specification violation reported by NCR 81-007-0.
A NRC inspector had expressed concern to licensee management personnel as early as January 1982 that the present system for identifying and investi-gating Technical Specification violations was inadequate especially for those reported by NCR's.
This concern was expressed in open item 8201-04 from NRC Inspection Report 50-313/8201; 50-368/8201.
The failure of the PSC to investigate the NCR 81 007-0 reported violation was discussed with licensee management personnel in light of the previous open inspection item.
ANO management indicated that the Technical Specification violation review system was presently being revised to help correct the deficiencies which led to this apparent violation of Technical Specification 6.5.1.6.e.
(313/8233-01, 368/8233-01).
4.
Fire Protection / Prevention Program Implementation The objective of this inspection was to ascertain if the licensee is implementing a program for fire protection and prevention that is in conformance with regulatory requirements, commitments in the fire protection plan. and industry guides and standards.
The following elements of the ANO fire protection / prevention program were included in this inspection:
a.
Control of combustible materials in safety-related areas; b.
General station housekeeping and housekeeping during maintenance and modification; c.
Fire brigade and fire protection equipment, functional, and properly maintained; d.
Surveillance testing of the fire protection system; and e.
Fire brigade training and fire drills.
The NRC inspector reviewed the licensee procedures listed below to determine the extent to which regulatory requirements and commitments were reflected in internal procedures:
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-6-Title No./Rev./Date Fire Brigade Organizatien and Responsibility 1015.007/2/11-30-81 Control of Combustibles 1053.001/11/11-5-82 Control of Ignition Sources 1053.002/2/7-22-82 Safety and Fire Prevention Inspection 1053.003/3/8-27-82 Fire Plan / Fire Brigade Training Program 1063.020/0/7-22-82 Capacity Testing of Fire Water Pumps P-6A and P-6B 1409.18/0/7-16-80 During this review, the NRC inspector found that Procedure 1015.07 referred to a procedure number 1023.20 as the fire plan / fire brigade training program.
The latest procedure index and the actual issued procedure under this title is 1063.020.
This was brought to the licensee's attention and it will be corrected.
The NRC inspector also found that Procedure 1015.007 adequately defines, describes, and establishes responsibilities of the
" Fire Brigade," but then says that when the " Fire Team" arrives at the scene, the " Fire Team" assumes control.
This was discussed with the j
licensee's representative and the NRC inspector found that Pro-l cedure 1903.041, " Duties of Emergency Fire Team," defines, describes, and establishes responsibilities and authority of the " Fire Team."
The NRC inspector recommended that this procedure be referenced in, and that the
" Fire Team" and its interrelationship with the " Fire Brigade" be clearly defined by, Procedure 1015.007.
Selected results of surveillance testing of fire protection systems were reviewed by the NRC inspector to determine that the testing was conducted at the intervals required, and the results were satisfactory.
This sampling covered tests on the operation of the diesel driven and electric fire pumps, fire system valve position verifications, fire system flushes, fire pump performance tests, annual fire system valve cycling, and fire hose station testing and hydro.
No items of noncompliance or deviations
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were noted in this area of the inspection.
The NRC inspector conducted a tour of the accessible areas of the station to determine if the fire protection systems were installed and operational as required, and to assure that station housekeeping and conditions were adequate to reduce fire hazard potential.
Since Unit I was in the early stages of a refueling outage and numerous areas were prepared or being prepared for maintenance work, the NRC inspector noted that housekeeping conditions were adequate.
Curing this tour, an unsealed penetration through Uni'. 2 fire barrier wall above fire door 268 in fire zone 21090 was identified.
The licensee took prompt action to post a fire watch and get the penetration sealed.
This
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is an apparent violation of Technical Specification paragraph 3.7.11.
(50-368/8233-02)
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Also, while conducting the facility tour, the NRC inspector reviewed the licensee's position on open item 8132-02 and determined that this item could be closed.
However, the NRC inspector discovered that the automatic feature of the deluge system installed as fire suppression for fire zone 21361 was inoperable since the inlet isolation valve to the automatic valve was shut.
This sytem was installed as committed in NUREG 0223,
" Fire Protection Safety Evaluation Report," paragraph 3.11, Table 3.1, Item 3.11, and paragraph 5.16.
This was discussed with the licensee and their position is that since this system was installed, it was determined that the delivered water volume would exceed the existing drainage capacity and lead to the flow of potentially contaminated water into uncontrolled facility spaces.
The licensee has submitted a request for exemption in this specific area in a letter to the Office of Nuclear Reactor Regulation, dated November 11, 1982.
This letter, however, does not address the immediate concern over the
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apparent lack of automatic protection for this fire zone and there does not appear to be any documentation describing or establishing a backup mode of protection.
This condition is a prime example of the licensee's uncertain position with regard to his present status le fire protection /
prevention commitments.
The licensee has a 4-to 5 year accumulation of correspondence and licensing actions as a result of his attempt to comply with the recommended impror?ments in fire protection programs.
The licensee has started a program to consolidate and clarify the overall status of the fire protection / prevention program.
This will be an un-resolved item pending NRC action on this request and a clear program description for fire protection / prevention by the licensee.
(Unresolved Item 368/8233-03)
5.
Maintenance and Maintenance Program The NRC inspector reviewed the licensee's maintenance activities and maintenance program by selectively reviewing administrative procedures, quality control procedures, completed job orders, and records to determine that:
l a.
Written procedures have been established for initiating requests for l
routine and emergency maintenance.
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Criteria and responsibilities have been established for review and
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approval of all ma ntenance requests, for designating the activity as I
safety /nonsafety-related, for work inspection, for identification of appropriate inspection hold points, and for performing functional testing of structures, systems, or components following maintenance work.
c.
Work control procedures require special authorization for activities involving welding, open flame, or other ignition sources and that
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-8-they take cognizance of nearby flammable material, cable trays, or critical process equipment.
d.
Work control procedures require a fire watch, with capability for communication with the control room, if an activity with fire potential is to be performed in the proximity of flammable material, cable trays, or vital process equipment.
e.
During maintenance on safety-related systems, all license limiting corditions for operation were met.
f.
Maintenance activities on safety-related systems were properly approved, performed, inspected, tested, and documented.
g.
Reporting requirements for the selected maintenance activities had been met, if applicable.
The following procedures and job orders were reviewed to determine that the preceding criteria and requirements were met:
Procedures Title Number Revision Date i
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Control of Maintenance 1000.024
9-11-82
Quality Control Program 1000.023
4-15-82
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Preventive Maintenance Program 1001.004
3-18-82
Quality Control Program Implementation 1004.001
1-04-82 Conduct of Maintenance 1025.003
10-14-82 Job Orders i
Unit 1 35823 B Battery Bank for Diesel Fire Pump
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06266 Repair of SG-A Primary Manway Leak i
32794 RCP "C" Seal Replacement
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30949 Sealing of Fire Barrier Penetrations j
30269 Control Valve CV-3807 Failed to Open During Surveillance Cycling 30256 Diesel Generator Fuel Oil Transfer Pump Level Switch Malfunction i
28554 Standby H Purge System Failed Surveillance Test p
06990 Primary Makeup Pumps P-36A and P-36C Unit 2 33301 SG-8 Primary Manway Leakage 21077 PI for CEA #67 (CEAC #1) Malfunction 31970 Breaker Tripping for Battery Chargers 2031 & 2034 32057 (Ditto)
29108 (Ditto)
32017 Containment Atmosphere Rad Monitor Pumps 2RITS-8231-1 and 2 Inoperable 32237 Modification of Main Feedwater Isolation Valves 2CV-1024-1 and 2CV-1074-1
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-9-26646 EFP Discharge Control Valve 2CV-1075 Leak 27252 Repair Cracked Weld in Pressure Sensing Line for RCP Middle Seal
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27234 Repair Charging Pump 2P-36A There were no violations or deviations in this area of the inspection.
6.
Design, Design Changes, and Modification Review During this inspection, the NRC inspector conducted a review of Design Change Package (DCP) Records that reflect design changes completed on ANO, Unit 2, to ascertain that the changes were done in accordance with approved ANO procedures; APL-TOP-1A, " Quality Assurance Manual-Operations"; AND Technical Specifications; regulatory guides; 10 CFR 50.59; and applicable ANSI standards.
The NRC inspector made a random selection of "Q"-listed DCP's from the
" Design Change Package Log" which were indicated as being complete.
DCP's selected were as follows; DCP#80-2020, Installation of Key Operated Hand Switch DCP#80-D-2061, Emergency Diesel Generator Modification for Torsiograph Test DCP#80-2037, Valve Reset Features, Main Steam & Feedwater Isolation Valves DCP#80-2106, Modifications to Charging Pump Discharge Lines DCP#80-2115, Isolation Valves Upstream of 2SV-1585-2 and 2SV-1589-2 DCP#80-2201, Replace Electrical Trip Ball Valves DCP#81-2057, Mechanical Seals Emergency Feedwater Pumps ANO Procedure 1000.13, " Control of Station Modifications," Revision 8, i
dated August 31, 1982, and the approximate 20 referenced procedures were utilized by the NRC inspector during the review.
During this inspection, only four of the seven DCP's were partially reviewed by the NRC inspector, therefore, a followup review will be conducted during a subsequent site inspection.
7.
Unresolved Items An unresolved item is a matter about which more information is required in order to ascertain whether it is an acceptable item, a violation, or a deviation.
One unresolved item is discussed in paragraph 4 of this report (exemption from fire suppression in a fire zone, disabling of automatic
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feature of fire suppression system, and clarification of licensee's present status of fire prevention / protection program).
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8.
Exit Interview
An exit interview was conducted November 19, 1982, with those personnel denoted in paragraph 1 of this report.
At this exit interview, the NRC inspectors summarized the scope and findings of the inspection.
The
Senior Resident Inspector was present at the interview.
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