IR 05000313/1986032

Insp Repts 50-313/86-32 & 50-368/86-32 on 860929-1003 & 1014-17.No Violations or Deviations Noted.Unresolved Items Identified.Major Areas Inspected:Design Changes & Mods, Inservice Insps & IE Bulletin 85-003 Followup

ML20212E696
Person / Time
Site:	Arkansas Nuclear
Issue date:	11/26/1986
From:	Bess J, Ireland R, Norman D, Greg Pick NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20212E648	List: IR 05000313/1986032 ML20212E643
References
50-313-86-32, 50-368-86-32, IEB-85-003, NUDOCS 8701050405
Download: ML20212E696 (13)

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-313/86-32 Licenses: DPR-51 50-368/86-32 NPF-6 Dockets: 50-313 50-368 Licensee: Arkansas Power & Light Company P. O. Box 551 Little Rock, Arkansas 72203 Facility Name: Arkansas Nuclear One, Units 1 and 2 Inspection At: Russellville, Arkansas Inspection Conducted: September 29 through October 3, 1986 and October 14-17, 1986 Inspectors: [ % ~m ///f6"/gf D. E. Norman, Reactor Inspector, Engineering Date Section, Reactor Safety Branch

% . f. M dhu 8 g E. Bess, Reactor Inspector, Engineering Date i Section, Reactor Safety Branch i

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A9xJQ G. A. Pick, Reactor Inspector, Operations HMn Date

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Section, Reactor Safety Branch j Approved: sbf>( ///A.l N

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l R. E. Ireland, Chief, Engineering Section Da'te Reactor Safety Branch l

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Inspection Summary Inspection Conducted September 29 through October 3,1986, and October 14-17, 1986 (Report 50-313/86-32; 50-368/86-32)

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Areas Inspected: Routine, unannounced inspection of design changes and modifications, inservice inspections, EQ inspection followup, IEB 85-03 followup, and followup on an allegation related to an over torque-condition of Limitorque operator Results: Within the areas inspected, no violations or deviations were identified. One unresolved item is identified in paragraph 2.e.(1) and one unresolved item is identified in paragraph 2.e.(2) of this report.

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DETAILS Persons Contacted Arh.isas Power and Light Company (AP&L)

+J. Levine, Site Director

+*D. Howard, Special Projects Manager M. Durst, Project Engineering Superintendent H. Jones, Plant Modification Manager

+*D. Lomax, Plant. Licensing Supervisor

• S. Quennoz, General Manager, Plant Operations R. Lane, Engineering Manager .

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Ewing, General Manager, Plant Support

• P. Campbell, Licensing Engineer

• Williams, Engineering Supervisor B. McCord, QC Supervisor-

+*G. Provencher,-QA Supervisor i *G. Woerner, Nuclear Engineer

• Stroud, Project Engineering Supervisor

• D. Horton, QA Superintendent

+*L. Humphrey, General. Manager Nuclear Quality  !

• J. McWilliams, Maintenance Manager G. Davis, Plant Performance Engineer

B. Hinton, Unit 2 Operations Technical Support Engineer

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V. Bhardwaj, Electrical Engineer i G. Dobbs, Electrical Engineering Supervisor J. Taylor-Brown, QC Superintendent NRC

i- - +* Johnson, Senior Resident Inspector

+*C. Harbuck, Resident Inspector c

+*D. Norman, Reactor Inspector l' *J. Bess, Reactor Inspector

• Pick, Reactor Inspector

• Denotes those present at the exit interview on October 2, 198 + Denotes those present at the exit interview on-0ctober 17, 1986.

I Inspection Semmary

- IE Bulletin 85-03 (Unit 2)

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IE Bulletin 85-03, " Motor Operated Valve Common Mode Failure During Plant Transients Due to Improper Switch Settings," was issued as a result of several' events during which MOVs failed on demand due to improper switch settings. The bulletin requested that MOVs in

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certain systems be tested for operational readiness, and that licensees develop and implement a program to ensure that valve operator switches are selected, set, and maintained properly to accommodate maximum differential pressure expected during both opening and closing of the valve for both normal and abnormal events within the design basis. Submittals requested by the bulletin were made to-the NRC on May 14, 1986, and additional submittals of information requested by the NRC were made on October 1, 198 Followup of the licensee's actions with respect to the bulletin was made by performing the following inspections:

(1) Procedures Review - Procedure No. 1409.56, Revision 1, dated June 6,1986, " Motor Operated Valves IEB 85-03 Program, EQ Inspection and PM Work Plan," implements provisions of the licensee's IEB 85-03 program discussed in the submittal to NR Essential elements of the program are also implemented by Procedure No. 1403.31 dated June 9, 1986, " Testing of Motor Operated Valves Using MOVATS 2100," and Procedure 1403.160, Revision 7, dated September 16,1986, "Limitorque Motor-0perated Valve SMB-000 Maintenance," (Procedures exist for each Limitorque operator series; however, the SMB-000 procedure was sampled as a typical procedure). Pertinent aspects for proper setting of the switches which were covered by the procedures include:

specific procedure for determining switch settings, clarification that torque bypass switch settings are based on valve stem movement rather than disk / gate movement, and setting of torque switches at valve mid-stroke position and belleville spring in a relaxed conditio The licensee has implemented a program to ensure reliable operation of MOVs utilizing the Motor Operated Valve Analysis and Test System (M0 VATS), a system which permits testing, adjusting, and setting of limit and torque switches which are part of the controls for an M0V. MOVATS is a portable signature-analysis device designed for field use. Parameters obtained by the system include:

axial motion of the worm gear,

actuation of torque and limit switches and bypass switches, and

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The. scope of the M0 VATS program includes, MOVs meeting IEB 85-03 criteria plus MOVs within the IST program, equipment qualification (EQ) program, and PM program of ANO Unit 1 and Unit '

(2) Haidware Inspection - ANO - Unit 2 was operating during this inspection; therefore, no hardware inspections were' performe Inspections were performed-by the NRC for Unit 1 and results are being reported by the NRC resident inspector in NRC Inspection Report 50-313/86-33; 50-368/86-3 (3) Data Review - IEB 85-03 reported that valves failed to operate because torque bypass switches had not been set to remain closed long enough to provide the necessary bypass function on valve opening with differential pressure conditions across the valv Switches were reportedly set for 5 percent of full strok ANO procedure sets the bypass switch for 95 percent of full stroke (valve stem travel) on Unit-2 and while a review of test data identified 19 operators with settings less than 95 percent, no operators were identified with settings low enough to cause a

. premature trip of the bypass switch. Therefore, no valves were found to be nonoperable because of switch setting No violations or deviations were identifie Allegation Followup (Unit 2) (4-86-A-088)

An allegation was received in Region IV from a caller who expressed a concern that, during M0 VATS testing, several Limitorque valve

. operators had as-found torque values which exceeded manufacturer 4' recommendations and that in order to prevent delay in returning

_ Unit 2 to operations mode, NDE inspections recommended for the 4 over-thrust operators may not have been pern rme M0 VATS test data for Unit 2 were reviewed by the NRC inspector, and-it was noted that as-found thrust values for 14 valve operators had exceeded the limits set by the licensee. Design limits provided by

the manufacturer had been lowered 10 percent by the licensee to account for measurement uncertainties. As-left data also showed

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certain valve operators with values above the limits. The higher

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values were required in order for these valve operators to perform

their intended valve operator functions.

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The NRC inspector reviewed Report of Abnormal Conditions (RAC) for valve operators which had exceeded design limits; however, disposition had not been completed on the RAC forms. The NRC

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inspector then requested that the basis for determining operability be provided, with supporting documentation from the valve operator manufacturer. The information provided showed that operability of each over-torqued valve operator was based on one of the following:

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(1) Correspondence from Limitorque which stated that the maximum allowable thrust (point at which valve operators torque out)

should not exceed published design ratings. Final thrust due to inertia may exceed the maximum rating by 10 percent or les (The published rating is interpreted to mean the maximum torque switch setting.)

(2) Correspondence from Limitorque which stated that, for a maximum of 100 cycles, torque switches may be set to trip at a value equal to or less than 110 percent of the thrust rating. The final thrust due to inertia should not exceed the rating by more than 20 percen (3) Telephone conversation record between Limitorque and the licensee in which Limitorque stated that NDE should be used to examine the condition of valve operators whose as-found setpoints exceeded the rating of the operators. Certain locations on the operators to be inspected were discussed in the recor Item 1 above was used to establish a design baseline for torque switch settings and maximum thrust (inertial thrust) to which as-found or as-left settings were compared. Item 3 was used to disposition those operators which had exceeded limits set by Item The licensee performed NDE on one valve operator of each model for which the as-found setpoint exceeded the limit. The valve operators inspected were 2CV-4740-2, with the maximum as-found torque for model SMB-00 (37.9 percent above rating), and 2CV-5127-1, with the maximum as-found torque for model SMB-000 (24.3 percent above rating). No adverse indications were found by the NDE inspectio Item 2 was used to disposition valve operators whose as-left setpoints exceeded those permitted by Item 1, in order for the valve operator to perform its intended function. Valve operators in this category must be limited to 100 cycles of operation at the higher settin It was not clear at the time of the exit meeting whether at the end of 100 cycles a valve operator would be replaced or whether it could be inspected by NDE and returned to service. This should be clarified by the licensee in plant procedures a.; discussed belo Based on Limitorque correspondence discussed above, it is the NRC inspector's conclusion that the licensee is complying with Limitorque approved torque values. However, the concern expressed by the alleger was valid, since permitted torque values in use by the licensee are considerably higher than values published by the operator manufacturer which are included in ANO Unit 2 procedure Acceptance criteria for operator torque values method of counting overtorque cycles, corrective action required after exceeding 100 cycles, method of NDE inspectioa, and other relevant details should be included in maintenance procedures. Pending update of these procedures, this is considered an open item (313/8632-01; 368/8632-01).

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c. Design Changes The purpose of this inspection was to review the licensee's design changes and ascertain if modifications were in conformance with the requirements of the Technical Specifications (TS) and 10 CFR 50.5 The NRC inspector reviewed documentation and drawings pertaining to Design Change Packages (DCPs) 82-1111 and 82-1111A. The purpose of this design change is to expand the Class 1E 120V instrument AC system. The documentation reviewed is listed below:

DCP Functional Design Description, dated December 4, 1985 Circuit and Raceway Schedule Change Request, Drawing No. E-69, Revision 4, DCN-45 Safety or Environmental Determination Form-202, F9 Controlled Design Documents - Form 202, F4 FSAR Paragraphs and/or Figures Requiring Revisions Design Evaluation Questions Emergency Diesel Generator #1 and #2 Auto Connected Load Assessment Calculation Sheet No. 82D-1111-01 Protective Design Coordination Study - Calculation No. 84E0033-49A, Panel Y3 Main Breaker

Protective Device Coordination Study - Calculation No. 84E0083-498, Panel Y4 Main Breaker Protective Device Coordination Study - Calculation No. 820-1111-08, Breaker No. 52/634 Protective Device Coordination Study - Calculation No. 84E0083-29A, Breaker No. 52/534 Protective Device Coordination Study - Calculation No. 820-1111-07, Relay Settings for MCC B57 and 865 and Y3 and Y4 Panel Breakers Construction Work Permit (CWP) #82-1111/719094-1, dated October 20, 1985 Construction Work Permit (CWP) #82-1111/719094-2, dated January 7, 1986 Construction Work Permit (CWP) #82-1111/719092-2, dated January 7, 1986

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Construction Work Permit (CWP) #82-1111/709315.3, dated January 7,1986

Construction Work Permit (CWP) #82-1111/719092-1, dated January 7, 1986 In the areas reviewed, the documents reflected the following:

(1) The design changes were controlled by established procedure (2). The design changes were reviewed and approved in accordance with Technical Specifications and established QA/QC control No violations or deviations were identifie d. Inservice Inspection (ISI) (Unit 1)

(1) ISI Program (For Weld Inspection)

The NRC inspector reviewed Procedure 1032.07, Revision 4, "ISI

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Program Requirements (concerning pressure retaining welds)," and discussed the program with the ISI coordinator. This procedure contained the following items: (a) defined authorities and responsibilities of the individuals involved with final evaluation and acceptance of ISI results, (b) provisions for making revisions to the ISI Program Plan contained in the Unit 1 Technical Manual as originally approved by NRR, (c) described what records were to be maintained, and how they were to be maintained, (d) described ANO and contractor requirements, (e) described storage and maintenance requirements for calibration blocks, and (f) provisions for determination of whether Design Change Packages (DCP) or other plant changes involving weld packages modified the ISI Program Pla The ISI Program Plan contained in the Unit 1 Technical Manual met the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI, 1980 Edition and addenda through Winter 1981. The NRC inspector verified that the plan had been reviewed by the onsite safety review committee and the Authorized Nuclear Inservice Inspector (ANII). The plan included inspection items (welds),

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code categories, examination schedule, examination method, calibration standard requirements, and drawings indicating system classification differences and weld position (2) Procedure Review The licensee had contracted with Babcock & Wilcox (B&W) to conduct the ISI work on ANO Unit 1.

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The NRC inspector reviewed the B&W procedures concerned with various forms of nondestructive examination (NDE), the qualifications of the personnel assigned to utilize the procedures, and the certification sheets for the materials and equipment utilized by B& The procedures that were reviewed established methods of recording and evaluating test results. The examination extent and technique was adequately described and in conformance with the ASME Code Section The procedures, listed below, reviewed in this area, met the requirements of ASME Code,Section XI and had been reviewed by licensee personnel and the ANI ISI-50, Revision 9, " Technical Procedure Describing Surface Requirements of Welds, Adjacent Base Metal, and Components for Nondestructive Examination" ISI-120, Revision 25, " Ultrasonic Examination of Piping and Vessel Welds Joining Similar and Dissimilar Materials" ISI-240, Revision 20, " Penetrant Examination of Welds and Base Materials, Including Studs and Nuts" ISI-270, Revision 18, " Wet or Dry Methods of Magnetic Particle Examinations of Welds, Studs, Bolts, and Pump Motor Flywheels" 151-350, Revision 20, " Visual Examination of Welds and Surface Conditions"

[ 15I-362, Revision 11, " Identification and Layout of Welds and System Components" (3) Repair, Replacement Program l The NRC inspector reviewed the licensee's Repair / Replacement Program for ISI. The licensee had incorporated the Repair / Replacement Program into the current job order syste The Repair / Replacement Program was described in Attachment 14 to administrative Procedure 1000.37, Revision 8, " Administrative Control of Welding." The program was described in the welding procedure since repairs usually involve some welding. The program consisted of the procedures listed below:

1000.13, Revision 11, " Control of Station Modifications,"

dated September 25, 198 .24, Revision 18, " Control of Maintenance," dated August 14, 198 , . .

1000.37, Revision 8, " Administrative Control of Welding,"

dated January 29, 198 .03, Revision 14, " Conduct of Maintenance," dated April 22, 198 .02, Revision 8, " Installation Technical Support,"

dated Decemoer 10, 198 .06, Revision 7, " Procurement Technical Assistance,"

dated July 16, 198 .002, " Evaluation of Sealants and Compounds for Leak Repairs," dated December 6, 198 .02, " Construction Management Organization and Responsibilities," dated February 25, 198 The procedures made provisions for entering the following information: (a) NDE method which identified a flaw, (b) welding procedure to be used to repair the flaw, (c) flaw removed method, (d) heat treatment requirements, (e) NDE method to be used for inspecting the repair, and (f) placement of hold points for QC or the ANI Provisions were also made to verify that replacement items met the applicable edition of the Construction Code. Engineering was required to evaluate replacement suitability prior to replacement; and justification for not requiring a code stamp in certain instances is provided in accordance with established guidelines. Preservice inspection is performed prior to return to service, if required, in order to establish a new baseline for NDE. The program met the applicable sections of ASME Code Section XI.

l (4) Quality Control (QC)

(a) QC Coverage of Contractor ISI Activities

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The NRC inspector verified through discussions with the QC l Inspection Supervisor and review of Quality Control l Surveillance Findings (QCSF) listed below that there was l adequate surveillance of B&W ISI activitie QCSF 86-591 P ,20-018, 20-022, and 20-025

_ QCSF 86-621 UT PZR Circumferential l QCSF 86-636 UT 06-004 RCP "A" to Cold Leg QCSF 86-637 PT 19-016 QCSF 86-649 Rx Coolant Pump i

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11-(b) Work Observ'ation The NRC inspector observed a manual ultrasonic examination of a non-code weld, covered by the ISI Program Flan, on a main steam line to Elbow (X0.5.4,.MS Pipe to Ell, #6 Zone 100) per B&W Procedure ISI-120, Revision 2 The certification of the technicians performing the work-met the American Society for Nondestructive Testing Recommended Practice and the requirements of SNT-TC-1A, June 198 The technicians were knowledgeable of equipment operation and the examination method utilized. The equipment was certified and calibrated and the indications were properly evaluate No violations or deviations were identifie e. EQ Inspection-Followup (1) Limitorque Valve Orerators Walkdown - At the time of the NRC team EQ inspection * luly 1986, the Limitorque valve operator walkdown inspecti . still in progress by the licensee; therefore, walkdown packages, including actions taken to correct deficiencies, were not available for review. These packages were sampled during this inspection. All action taken by the licensee appeared to be appropriat Thermal aging of heat sensitive components within the Limitorque operators was based on the service temperature to which the operators are exposed. During the EQ team inspection, it was determined that thrust switch compartment heaters at ANO were apparently energized during plant operation. Since any'

temperature rise in the compartments could possibly accelerate aging of. heat sensitive items, the licensee was requested to provide any information which showed that the heaters had been considered in aging analyses. This information was not provided during this inspection; therefore, the licensee was requested to provide test data or-analysis which will show the effects of torque switch compartment heaters on aging of valve operator heat sensitive materials. (Unresolved item 313/8632-02; 368/8632-02.)

(2) Okonite Splices -During routine inspection of Unit 1, an NRC inspector viewed a taped splice in a Limitorque operator motor lead which was later identified as an Okonite splice (NRC Inspection Report 313/86-33). While at the corporate office, the.NRC inspector reviewed data which provided the basis for the Okonite splice qualification. Splice model T-95 had been qualified for a harsh environment, equivalent to an inside

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containment environment, by Okonite test report NDRN-3,

-Revision 1, June 30, 1982, and Revision 2, February 16, 198 The licensee stated that the splice was used to replace blind barrel crimp lugs provided in Limitorque operator motor leads which had braided jackets. The configuration of the cable does not permit the stripping of the braid for installation of a Raychem splic It was stated in the Okonite test report that the splice was tested on cables without jackets; therefore, it appears that the splice qualification does not comply with

. provisions of 10 CFR 50.49(f)(1) which permits testing an identified item under identical conditions or under similar conditions with a supporting analysis to show that the equipment to be qualified is acceptable. Because of the differences in the type of cable on which the splice was tested and installed (unjacketed.vs. braided jacket), it was requested that_the licensee provide supporting analysis to show that the splice is qualified in the installed cor. figuration. Of concern is the possibility of an electrical short circuit in the event the jacket absorbs moistur (Unresolved item 313/8632-03; 368/8632-03)

f. Periodic Diesel Generator (DG) Inspection (Unit 1)

Paragraph 4.6 of the Technical Specifications (TS) requires that each DG be inspected every 18 month Implementation of this requirement was verified by the NRC inspector by reviewing procedures and documentation of tasks completed or to be completed during the outage. Procedure 1402.066, Revision 4, which had been partially completed for DG B was reviewed to verify work which had been completed. There were seven temporary changes attached to the procedure. No work was in process during this inspection. During this review, names of personnel performing DG maintenance were identified and their qualification records reviewed to verify proper qualificatio Licensee ~ inspection of DG A had not started at the time of this inspection. In addition to the TS required inspection, one power pack from the DG will be disassembled and inspected for evidence of premature wear. 'This'is being done as a followup to previous licensee observations. Results of DG A inspection by the licensee will be reviewed by NRC during a subsequent inspection (0 pen item 313/8632-04).

No violations or deviations were identifie g. Containment Local Leak Rate Testing (LLRT)

(1) Procedure Review The NRC inspector reviewed I&C Procedure 1304.23, Revision 9, which_ implements the TS requirements outlined in

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paragraph 4.4.1.2, for reactor building penetration LLRT, except for two personnel access penetrations, and the reactor building ventilation penetration which are performed under I&C Procedure 1304.020. The review provided verification that requirements of the TS and 10 CFR 50, Appendix J, were properly implemente (2) Test Witnessing As-found testing had been perfcrmed by the licensee prior to this inspection. Testing will be repeated on those valves which were tested during M0 VATS and on valves or penetrations which required maintenance because of excessive leakage found during as-found testin No testing was in process during this inspection since M0 VATS testing had not been complete (3) Instrumentation Calibration data sheets were reviewed for two Wallace and Tiernan pressure gages and for the Cronus LED type stop watch which were used in the LLRT. Each instrument had been calibrated within the established time period and complied with the acceptable accuracy requirement (4) Test Results Leakage rates for several valves.were found to exceed permissible rates established in I&C Procedure 1304.2 Form 1000.0516, " List of Equipment Found to be Out of Tolerance," had been completed, however, disposition of the condition will not be completed until after completion of the MOVATS testin TS limits had not been exceeded; therefore, Limiting Conditions for Operation had not been entered. Final test results of the as-left tests will be reviewed by the NRC inspector during a subsequent inspection (0 pen item 313/8632-05).

No violations cr deviations were identifie . Exit Interview The NRC inspectors met with the licensee representatives denoted in paragraph 1 and Messrs. W. D. Johnson, NRC Senior Resident Inspector, and C. C. Harbuck, NRC Resident Inspector, on October 2 and 17, 1986, and summarized the scope and findings of the inspection.