IR 05000313/1987023
| ML20236J593 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 10/20/1987 |
| From: | Boardman J, Correia R, Haag R, Hawkins F, Johnson W, Maclean P, Walker H, Weiss S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20236J575 | List: |
| References | |
| 50-313-87-23, 50-368-87-23, NUDOCS 8711060184 | |
| Download: ML20236J593 (14) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Report No.
50-313/87-23 Docket No..
50-313 License No. DPR-51 50-368/87-23 50-368 NPF-6 j
Licensee:
Arkansas Power & Light Company P. O. Box 551 Little Rock, Arkansas 72203 Facility:
Arkansas Nuclear One (ANO), Units 1 and 2 Inspection At:
ANO Site, Russellville, Arkansas, August 10-21, 1987 Inspectors:
Q
/0!/5!B7
&s e R. P. Correia, Quality Operations Engineer (Date)
NRR (Team Leader)
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.h 0wol /n to/6/67 J. Boardman, ReactorOlnspector (Date)
Region IV
{l m An..
!*bsl67 R. Haag, Reactor I[jf pector (Date)
Region IV
$rv lobfl83 nw W. Johnson, Senior Rgaident Inspector (Date)
Region IV h, n~
Ju to Y 7
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P. Maclean, Reactor $nspector (Date)
Region III bevd Mv
/0 i[d7 H. A. Walker, Reacto(/ Inspector (Date)
Region III
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Reviewed By:
/0//6/87
/.pproved By:
S. H. Weiss, Chief, Quality Assurance Branch (Bote)
8711060184 871105 PDR ADOCK O5000313 G
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i This special announced inspection at Arkansas Nuclear One (AN0) assessed the effectiveness of the licensee's quality verification organizations'
contribution to the identification, solution, and prevention of safety
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significant technical deficiencies in plant systems and operations. Also, line management's response to the identified deficiencies was assessed to
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determine if the deficiencies were being acted on promptly and completely.
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These assessments included the Nuclear Quality functions and the Plant Safety Committee. The four areas reviewed durina the inspection included (1) plant modificationsofsystemsandcomponents,(2) maintenance,(3) plant operations, and (4) corrective actions. The details and results of each of these reviews follow.
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FLANT MODIFICATIONS This part of the inspection focused on the licensee's system of design changes and modifications to plant systems and components, including their installation and implementation. The involvement of the quality verification organization in monitoring this process and the effectiveness of management
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in dealing with safety-significant deficiencies was also reviewed.
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The design change process has recently undergone major changes at ANO, and some of these changes have not yet been fully implemented. These changes were initiated at the direction of AP&L upper management in response to deficiencies that existed in the design change process. The major areas of change noted during the inspection are (1) formation of a projects engineering group at ANO with the primary responsibility of modification installation, (2) standardizing and updating the design change format, and (3) various changes and improvement in the quality verification organization.
The inspector also noted several significant changes that the Nuclear Quality organization has undergone:
(1) the addition of personnel with technical expertise to perform reviews and audits, (2) Quality Control (QC) perfonning indepth reviews of selected Design Change Packages (DCP) during the review
' cycle at ANO, and (3) remov Sg Quality Assurance (QA) from the formal in-line DCP review cycle at Little Rock General Office (LRG0) and thus allowing QA to concentrate on selected areas of concern during their review.
LRG0 QA recently initiated a monthly report covering DCP review which will identify recurring discrepancies. An example of expanded QC involvement in an area of past poor performance dealt with the reactor coolant pump seals in unit 2.
Past performance has shown these seals to be very unreliable with replacement often required between outages. QC involvement has been increased to include 100% receipt inspection of new seals and additional inspection points during the seal installation. This, along with several other changes in the seal design and installation procedure, has increased seal reliability.
The following DCPs were reviewed during the inspection:
(1) 84-10140 Hotleg Level Taps Installation (2) 84-2022BReplaceStationBatteries(andRack)
(3) 86-1118 Rs. place CV-1300 and 1301 (4) 86-1099 Reactor Coolant Pump Seal Modification (5) 86-1010 Reactor Coolant Pump Seal Modification
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(6) 86-1022 Decay Heat Valves DH-14A and'B Vent Modification
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(7) 84-2052 Safety Injection Tank Discharge Valve Limit Switch Replacement Generally, the content of the DCPs provided sufficient information to the ANO project engineers to allow installation of the modification; however, the organization and level of detail of information varied greatly between the-DCPs.. Adequate review and engineering involvement was observed in the various stages of DCP development including the extent in which vendor provided design changes are reviewed and questioned. :These DCPs receive, i
basically the same degree of review by both engineering and QA as DCPs.
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originated at LRG0.
Licensee management has also emphasized the importance of interaction between LRGO and AN0 engineering both prior to issuing DCPs and during implementation.
The inspector was concerned with several~ parts of the new DCP process.
In the past, ANO project engineers would review any calculations included with
the DCP. However, under the new format, the project engineer only' receives
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the calculation coversheet for the DCP being reviewed. The inspector.was concerned that the projdct engineers at ANO would rot be familiar with the design content of the DCP to ensure that'any changes to the DCP would not invalidate initial calculation' assumptions. ' Management at ANO was reviewing
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this particular change to the DCP format at the conclusion of the inspection.
The inspector identified two concerns witile reviewing DCPs that had not been
previously identified. The first was related to DCP 84-1014D.
It called for j
pipe taps at various elevations in.the Unit-1 reactor coolant pipina (RCP)'
hotleg for the hotleg level indication system.
BabcockandWilcox(B&W),who.
performed the initial design work on the level indication system, ultra-
sonically tested (UT) the tap locations for possible defects in the. base metal prior to actual drilling. At one tap location, a -laminar indication was discovered and the tap was relocated away from the indication. When
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questioned about the evaluation of the laminar indication,'ANO staff involved l
with the DCP could not establish that the indication had been evaluated as-
.i required by ASME Section XI. Article IWR-3000.
Subsequently, during the
inspection, the laminar indication was evaluated and found to be acceptable.
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The second concern dealt with DCP 86-1118.
It called for replacement of the Unit 1 motor operated valves (MOV) CV-1300 and 1301 which are located in the recirculation line for the make-up (high-pressure injection) pumps. During preparation for motor operated valve analysis and testing (MOVAT), it was determined that these valves were not compatible with the thrust developed by the motor operator and, therefore, required replacement..Also, a new support bracket for seismic restraint was required for the'new valve. Henry Vogt Machine Company, the valve vendor, supplied the calculation for the support bracket. One of the specified socket head cap screws to be.used in attaching the support bracket to the valve adaptor flange could not be
obtained. During discussions between ANO staff and Henry Vogt engineering, it was determined a' longer screw could be used in substitution and the material could be either carbon steel or stainless steel. A review of the.
support bracket calculation indicated that the required fastener was to be made of alloy steel with a minimum tensile strength of 190,000 psi and yield strength of 170,000 psi. There was no evidence'in the DCP that these
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requirements were ever specified. During the inspection, ANO engineering was d
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investigating this issue to determine what type fastener was used and the possibility of revising the calculation to reflect the existing fastener; however, no action hed been completed.
In summary, the inspectors determined that the current design change process at ANO, which is unoergoing major changes, is generally adequate to ensure proper installation and implementation of plant modifications. The quality verification organizations are actively involved with the plant modification process, including design reviews and in-process installation oversight.
In addition, QC and QA involvement extends beyond the required compliance review
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and goes into areas of prior poor performance and areas susceptible to problems. The present Nuclear Quality (NQ) staff possess the expertise i
required to perform technical overview of areas important to safety.
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However, the inspectors' concerns identified with the RCP hotleg taps and the i
substituted bolts used on the seismic valve support indicate that close l
attention to governing code and design requirements must be maintained, especially during modification, installation and any in-process field changes j
which may be required. While the quality verification organizations aave responsibility for assuring quality, engineering line management is primarily responsible for making sure that plant modifications are performed correctly.
MAINTENANCE The inspector performed a review of maintenance related activities where problems have occurred to assess the involvement of the NQ and plant engineering organizations in identifying safety-significant technical problems and seeking effective corrective actions to prevent recurrence.
Licensee Event Report (LER) No. 50-368/86-014-00 reported a failure of the Unit 2 No. 2 emergency diesel generator (EDG) because a fuel strainer clogged with sludge and other products resulting from the chemical changes in diesel fuel during storage. At the time that the Unit 2 No. 2 EDG became inoperable, the degraded fuel apparently met the requirements of Technical Specification (TS) 4.8.1.1.2.b for compliance with the American Society for Testing and Materials (ASTM) specifications related to distillate fuels used for EDGs (D975-74, Table 1). ASTM D975 is generally used as an EOG fuel operability standard in the TS's and addresses the fuel's viscosity and water and sediment content when sampled in accordance with ASTM-D270-b5. However, significant EDG fuel quality and degradation factors, such as " gum," are not addressed in or measured by ASTM D975. This concern includes numerous fuel quality factors specified by several EDG engine manufacturers in EDC technical manuals. Also related to fuel quality, Unit 1 EDGs (GM Electro-Motive Division Model 645E4B diesel engines) are supplied with in-line, simplex fuel and lubricating oil filters.
If during EDG operation a filter becomes clogged the unit is rendered inoperable. The inspector is concerned that the EDGs may not remain operable and perform a FS?.R design basis operational run with degraded fuel and the resulting complications.
LER No. 50-368/86-012 reported an inoperable Unit 2 pressurizer code safety valve because a relief setting was set higher than Technical Specification allowables. The licensee's review and evaluation of this event was in process during this inspection. The licensee is also performing a design review of all Unit 1 pressurizer code safety valves to identify similar
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problems. During a review of the licensee's' evaluation'of the Unit 1 valves, the inspector identified that there was no analysis available of the valve body-bonnet bolted joint. The licensee stated that Babcock and Wilcox (B&W),
the Nuclear Steam System Supplier (NSSS) for Unit 1, had stated that no documented' design review was performed because the governing revision of the
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American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPVC) for these valves did not require a review for bolted piping component joints that were 4 inches in diameter and smaller. The inspector is concerned that reactor coolant boundary bolted joints of this type may not have had appropriate analysis to determine that they are capable of withstanding dynamic loads, d
LER No. 50-368/87-003 reported a Unit 2 pressurizer heater rupture resulting in several reactor coolant pressure boundary leaks.. The leaks were j
subsequently repaired by Combustion Engineering and the licensee's action to
prevent recurrence was to obtain replacement heaters from General Electric.
However, LER No. 50-368/87-006 reported an un-isolable reactor coolant system pressure boundary leak caused by failure to identify a defective seal weld'
made during pressurizer heater repairs. At the time.of this. inspection, the licensee had begun an evaluation and acceptance of Combustion Engineering's root cause determination and actions to prevent recurrence.
Further NRC j
review of this matter is required.
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Because these three previously discussed LER's dealt with the licensee's use of vendors, the inspection reviewed the vendor evaluation program.. This program consists of two elements:
(1)'avendorauditprogramwhichperforms and (pliance based programmatic audit of vendors approximately every 3 years, a com 2) a vendor surveillance program which is a performance based program that establishes surveillance based on importance to plant safety and operation, complexity and uniqueness, requirement for special processes,-
ability to verify compliance / acceptability at ANO, and vendor history.
Properly implemented, the vendor surveillance: program should ensure that vendor performance is acceptable. The licensee's audits of vendors supplying.
safety-related equipment and services.-such as B&W and Combustion Engineering, must focus on technical, safety-significant items and be in
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sufficient depth to ensure that plant safety is not compromised.
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QA Audit report No. QAP-11-86, dated November 7,1986, identified loose' inlet
adapter bolts on the Unit 2 EDG turbocharger. The engineering response to this finding was that loosening of the bolts would not affect normal EDG j
operation since bolts on the other end of the adapter would hold it in place.
The analysis did not address the turbocharger's seismic qualification with these bolts being loose or missing to ensure EDG operability during seismic events as required by the FSAR.
Reports of Abnormal Condition (RAC) No's. 2-85-314 and 2-85-316 identified a l
leak in EDG 2K4B's copper fuel oil supply line. The condition posed a potential fire hazard and corrective action was to repair the pin-hole. leak using a silver-braze. The inspector requested the evaluation and analysis of the defect and subsequent repair. The licensee did not identify a procedure, brazer qualification, approved brazing rod, or acceptance criteria for the rc M.. i,s a result, the licensee proposed to replace the line with one supplied by the original-manufacturer or to replace'it with a flexible
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lineasrequestedbyPlantEngineering'ActionRequest(PEAR)No. 85-3815.
Neither of these actions had been accomplished at the time of this inspection.
It was also noted by the NRC inspector that QC personnel had identified that the RACs had been closed without either root cause determination or description of action to prevent recurrence.-
RAC No. 2-86-043 identified a stuck EDG fuel injector shich resulted in fuel being by-passed to the fuel drain line which is routed to the dirty oil drain tank. This caused the dirty oil drain tank to overflow and create a fire hazard. During inspection of the fuel drain line, a threaded pipe' fitting was removed, found to be stripped, and was reinstalled. The licensee could not provide a use-as-is justification of the stripped fitting which should
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have included a seismic analysis to ensure EDG operability during a seismic event.
In summary, the inspector's review of maintenance activities focused on Nuclear Quality's and Plant Engineering's ability to identify and resolve problems in this area. The problems associated with thel diesel fuel degradation and resulting strainer clogging appear to have been-adequately resolved. However, the inspector is concerned with possible generic issues related to the effects of gumming of the fuel and clogging of Unit l's fuel and lubrication filters which could cause the diesels to become inoperable.
Other items reviewed by the inspector indicate that thorough root cause
analysis and corrective actions to ensure that effected equipment will meet their safety-related functions may not have been performed completely. The qualification of repairs-to the diesel fuel lines, the loose bolts on the EDG.
turbocharger and the apparent unqualified brazing repair to a diesel ' fuel line are examples where more thorough root cause analysis and attention to
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detail were warranted.
In general, the team determined that more attention to problems associated with maintenance by the Nuclear Quality and Plant Engineering Organizations is necessary to ensure that their verification activities are performance-oriented and technically sound and provide reasonable assurance that FSAR and
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technical specification requirements are not overlooked or compromised.
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PLANT OPERATIONS The inspector evaluated the activities of the licensee's NQ organization relating to oversight of facility operations. This evaluation was performed through direct observation of activities, interviews with personnel,'and
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reviews of procedures and documentation.
The inspector also reviewed the
internal audits and performance monitoring programs implemented by the operations department.
The NQ organization remains cogni: ant of current plant activities and problems and provides their input into these areas through two sources:
the QA superintendent's membership on the Plant Safety Committee,'and (2)(1)
attendance by a QA and/or QC representative at.the daily management planning meetings.
In. addition, a QA supervisor attends the monthly meetings of the
offsite Safety Review Committee to brief that. committee on NQ findings and :
concerns.
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The NQ organization provides oversight of operations through the ANO '
observation program, the QA.inte nal. surveillance: program,. Technical Specification audits, and the QA audit of operations and surveillance activities. These areas are discussed below:
1.
The ANO observation program consists of QA observation'oflseveral areasi which include operations, surveillance testing, chemistry, health physics, and QC observation of maintenance activities. - 'In.this program, minor findings and recommendations are handled informally through discussions with the line supervisor unless similar discrepancies are identified in subsequent observations. At such time, the department-manager is notified of the discrepancies..The inspector noted that observations are conducted by: appropriately qualified personnel,.
including one QA auditor who maintains 'a current reactor' operator license. From a review of~the records of past observations, the inspector concluded that this program provides a valuable, performance-oriented oversight of operational activities.
From July 1986 until March 1987, several monthly observations were conducted in each area. However,rin March 1987 the frequency of observations was reduced from every month to.every third' month. The'
inspector also noted that very few of the observations'were performed during times other than the day shift. To enhance the effectiveness of the program, the inspection team recommended that~ licensee managements consider performing operations observations more frequently, including increased observations during the back shifts.
The inspector also noted cases where a QA' auditor designated a finding.
as potentially significant, but the-evaluation of-significance was ~not performed by the responsible organization as quickly.as expected.. For example, a QA surveillance perfonned on May 12, 1987, found that.the.
hinged power supply / fuse panel in the back of. one.of the Unit 2 plant'
protection system cabinets was secured by' only.one'or.two of 14. screws.
Surveillance Finding Report (SFR) No. 461-documented this problem on May_14, 1987. A Plant Engineering Action Request-(PEAR)~.87-1857, dated i
June 10, 1987, requested an engineering review to determine the. number, of fasteners required to maintain the cabinet's seismic qualification.-
Although some screws were' missing, licensee representatives; stated that!
the existing screws in all four-cabinets were1 tightened on. or about.
June 5, 1987. The PEAR response was provided by-engineering on June 11, 1987. However, a plant management memorandum to QA dated June 30, 1987, requested an extension to complete the response for SFR 461, indictting.
that more time was needed to complete the engineering evaluation--
requested by the PEAR.. Evaluation of.the.as-found condition. -
determination of deportability, and replacement of the missing' screws had not been completed as.of August 20,1987...This' type.of practice could lead to delayed -resolution oft significant' deficiencies and ini delayed evaluation of their.. deportability..
The. inspector also witnessed the s' surveillance: test and lube oil additions.
operation of a Unit 1. emergency diesel generator.-(EDG).- Licensee QAJandL Q_C personnel also? observing the test pointed'out'that the unloaded run!
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time while adding lube oil to the EDG appeared to'.'be excessive in that the EDG was started and allowed tolrun while preparations were being made to add lube' oil to the crankcase.: This time span was approximately 10 minutes. The governing test procedure used precautioned operators.
against running the EDG unloaded for excessive time periods. Although
. excessive unloaded run times was not defined, the operators agreed-that
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this item should be clarif.ied.
2.
The QA internal surveillance program involves observation by QA'
personnel of ongoing surveillance tests and other related activities.
Normally two of these surveillance are performed each week. The-inspector reviewed the QA internal surveillance reports for activities
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monitored in 1987 and concluded that this program provides a-very good mechanism for QA oversight of ongoing activities, including the-
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surveillance testing program. The program appears.to be very flexible i
in that it can be tailored to concentrate on activities in areas of.
f concern.
For example, as a result of findings-under this program, the licensee is performing much-needed improvements in its planti equipmentc
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lubrication program-
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The QA Technical Specification (TS) audit program invo'1ves a review by QA personnel of TS limiting conditions' for operation, safety limits, and '
H related surveillance requirements. Normally,'one audit is performed on each unit each month. The selected TS sections are' varied to cover all applicable TS sections within a five-year period. The inspector-reviewed the results of these audits conducted'in 1966 and 1987. They-were performance-oriented by assuring that procedures being implemented fully met the intent of the TS requirements, as well as'being-in
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compliance with them.
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The QA audit of operations and surveillance is an annua'l programmatic audit. The last such audit was performed by two QA_. auditors with the technical assistance from two operations specialists.
In addition, the.
QC organization provides oversight of the surveillance. testing program.
- through surveillance perfonned by QC inspectors.. These are performed at a frequency of about'one'per month and. involve observation of-an ongoing surveillance test.' This_ program has resulted in several significant findings and observations.
For' example, a QC surveillance of the station battery discharge'. test identified that.the calculated-test current was in error and required extensive,re-evaluation to determine acceptability of the test.
The inspector's review of QA audits of the operational departments revealed that the audited organization's responses'to QA findings were.
observed to be generally quite adequate, but frequently the written response was not returned to QA by the' established due date.. This has resulted in some inefficiency because of the exchange-of memoranda:
requesting and granting extensions. The inspector was informed by the
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licensee.that an automatic escalation procedure was being developed to address this problem.
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The inspector also reviewed the internal audits and performance monitoring
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programs implemented by the operations department. The operations department q
performs internal reviews and audits in areas such as drawing and procedure i
revision status, hold and caution card control, and temporary modification
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control. They have also implemented a performance monitoring program which is intended to provide an assessment by senior reactor operators of actual watchstanding practices.
Perfomance observations are four hours in length and are being performed at a rate of 24 per unit per year. This intra-departmental improvement program provides management with observations on ways to improve procedures, and serves to upgrade and standardize watchstanding practices.
AP&L has a goal of improving the use of the NQ group as a~ management tool in identifying deficiencies and potential problems to prevent'them from becoming a regulatory violation or an operational concern. To implement this goal, the NQ group reviews each violation issued by the NRC to establish whether the problem had been previously identified by NQ, and if not, why not. Audit and inspection modules are being revised as necessary to enable NQ personnel j
to detect similar items. As an exampl instituted under the QA internal surve.e of this program's implementation, QA illance program, a walkdown of systems
containing manual valves required to be locked. -This was done after being notified of an NRC violation involving an unlocked manual valve which was supposed to be locked.
The NRC inspector concluded that NQ personnel were well qualified and
. competent in the observed areas, and that technical specialists were used to supplement audit teams. The NQ oversight of plant operations and
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surveillance is considered to be at a level which should be adeouate to enable management to detect serious problems in this area. However, increased management attention is necessary to assure that NQ findings i
are promptly evaluated and resolved.
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CORRECTIVE ACTIONS i
The inspectors reviewed several deficiency.repo'rts to assess whether the
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quality verification organizations were identifying safety-significant, technical issues and seeking prompt and complete solutions. Closures of-corrective actions were also examined to assess whether they were based on superficial reviews or on effective evaluations that would prevent recurrence of similar problems. Additional information was obtained by discussions with licensee personnel, and by reviewing actions in progress to
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resolve identified quality problems. The results of these reviews and other related inspection activities follow.
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The inspectors reviewed ANO plant procedures germane to corrective-actions for identified plant deficiencies. A Significant Event Review Committee exists to investigate high level events and to ensure that
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action is taken to prevent recurrence. This level of significance appears to be near the reactor trip event: level. Licensee personnel stated that eight problems had been investigated by.this committee during the last year..The items reviewed involved reactor trips or.
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operational transients that could possibly have caused a trip. The inspectors also reviewed a number of open and closed Reports' of Abnormal
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Co'ndition (RAC) and Nonconformance Reports (NCR) to determine if.
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adequate action was taken. Reviews of;these reports are discussed.
separately as follows:
a.
RACs contain information on deficiencies or problems that require.
an evaluation for deportability with required action responsibility; designated to a cognizant individual.. After all ' actions have been completed by the assigned individual, the Plant Safety Committee (PSC) reviews:the RAC prior to' closing.- In many~ cases the.
inspector ~ determined that theLactions taken were adequate.;
However, some closed RACs were noted as not'having the root cause
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or other required actions ~ adequately addressed. 'In some cases,-
further investigation indicated that action was-taken to address'.
the root cause although it 'was' not documented or referenced'on the L
RAC.
In others, no objective evidence could be found to indicate.
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further action other than the action documented'on the RAC.. This'-
issue was discussed with licensee personnel. and they indicated that efforts were already underway to address it.'
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NCRs are written'by QC on deficiencies:or problems where reviewsL for deportability are not considered necessary. :However. 'in some cases the inspectors noted that the same type of problems were.
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addressed on both RACs and NCRs.
Reviews of NCRs,' audit finding
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reports, and surveillance: finding reports for deportability and
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adequate corrective actions are performed by cognizant supervision in the area of the deficiency.
In reviewing NCRs'the inspectors made the following observations:
l (1) The inspectors noted that several NCRs were written in 1986
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and.1987 on by-passed QC hold' points mostly involved with welding. Action to' address the cause was not evident from a j
review of the NCRs. During discussion.s with QC personnel.-the-inspectors were informed that QC was very much aware of the problem and corrective action had.been taken. The inspectors:
reviewed a memorandum written.to QC: personnel from plant
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management calling their attention tolthe; hold point problem with instruction that QC inspectors look for by-passed hold.
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points anytime they reviewed work in progress. -In addition,
i licensee personnel stated that the matter had also been-
discussed with craft personnel. The' inspectors noted that seven NCRs written in 1987'on by-passed hold points:were written on work performed during the recent refueling. outages.
(2) The inspectors also noted that several.NCRs were written'on-inadequate material: control. Most of:these involved the use
of nonsafety-related parts or components.in safety-related k
equipment.
Five NCRs:a.nd.four.RACs were written on thisttype of problem in 1987. 'The root"cause did not appear to have ~
been' determined'and no effective action taken to correct this:
recurring problem.. In one NCR' package reviewed,'thecroot cause'for-the use of the incorrect parts was. determined to be.-
a the; failure of QC to verify that the correct'part was used..l W
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This root cause determination was inappropriate since it did not address the failure of the maintenance organization to hn'
properly identify and obtain the correct part.
c.
Conditions which could result in a Licensee Event Report to the NRC are documented on RACs. The RAC' receives a formal deportability review by the PSC and is always required to be written when this review is needed or desired. Cognizant supervisory personnel perform an informal deportability review on NCRs and other documents used to record quality problems'..An RAC is written if supervisory personnel feel the deficiency on the NCR is reportable or if a formal review for deportability is desired.
The inspectors noted that in many RACs the final determination of deportability was not completed until months after the incident occurred and the RAC was written. Licensee personnel stated that 30 days were allowed for reporting the incident once it had been determined to be reportable. This statement conflicts with 10 CFR 50.73whichstatesthataLicenseeEventReport(LER)isrequired to be submitted "within 30 days after the discovery of the event."
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As an example, the inspectors noted that RAC No. RAC-1-86265 was written October 13. 1986, when seismic pipe supports were discovered missing from the Unit 1 emergency feedwater system.
Further evaluation for deportability was requested and engineering determined on February 11, 1987, that the system would not have functioned in the event of-an earthquake without the missing' pipe supports. This item was reported to the NRC on LER No. 50-313/
87-001-00 on April 28, 1987, more than six months after the discovery of the missing supports, d.
There are two trending systems in place at ANO. One trends RACs, the other trends NCRs and other quality related reports. These two systems are discussed as follows:
RACs are trended utilizing a computerized system to provide
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information for a quarterly report which covers an 18 month period.
Two RACs issued during the 18 month period on the same item
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constitutes input for a trend. Most trended RACs are closed RACs
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since equipment identification numbers (i.e., tag numbers) which are required data for trending are not normally designated when a RAC is first issued. This can result in a substantial delay in treading quality problems. Recently, a key word search capability was established allowing access to RACs involving selected key
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words so they can be evaluated for generic trends.
L Four quarterly RAC trend reports were reviewed by the inspcetors.
The report issued for the third quarter of 1986 indicated repetitive equipment failures due to moisture accumulation in the Unit I containment penetration room ventilation system's sensing lines. Moisture had accumulated apparently as a result of problems with the system's connections to the hydrogen purge system. The licensee's corrective action was to purge the sensing lines. But no "urther action was taken despite previous repetitive occurrences.
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The licensee's root cause analysis did not address how moisture was R'
getting from the hydrogen purge system to the sensing lines, b'
During the 1987, refueling outage, the hydrogen purge system was
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replaced with hydrogen recombiners; however, continued moisture problems with the containment penetration room ventilation system
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sensing lines have been identified. The containment penetration
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' room. ventilation system problems were recently assigned to
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engineering as an action item and are being tracked for action and
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resolution.
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.The quality deficiency trending system trends ten different types of reports which are used to document quality problems. For example, some of these reports include NCRs, RACs, audit finding reports, surveillance finding reports, and licensee event reports.
Summary trend reports are issued quarterly and cover the previous four quarters.
The report contains a considerable amount of detailed information such as graphs, document listings and a summary. There are no requirements in place at AN0 to issue
- requests for action when trends are. detected. Any actions taken are per individual initiative by staff who are on distribution for the report. For example, the Quality Deficiency Trending Report issued May 31, 1987, for the first quarter of 1987' indicated a problem with an increasing trend in personnel errors. There was no
. evidence of action by management or others to reverse the trend.
When asked about this matter, licensee personnel stated that
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management was aware of this personnel error trend, and it was not necessary to initiate additional action or assign additional personnel.to this matter.
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Neither of the two trending systems have a method for identifying, tracking, and following-up to resolve undesirable trends. Also, i
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trends. Although improvements are being made in the trending programs =, the licensee does not appear to be using them effectively i
as a management-tool to ensure safe and reliable plant operations.
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The inspectors reviewed the QA corrective action audit reports of audits conducted in 1985 and 1986.
In addition to the QA audits of corrective action performed twice a year, corrective action is also reviewed during audits of other activities, such as maintenance and operations.
' Audit Qf.P-10-85, conducted in the second half of 1985, resulted in 15 observations / recommendations for improvement of the corrective action system. Two of tne licensee's observations noted by the inspectors are as follows:
(1) lack of timeliness in the initial review of RACs to determine deportability ?.o the NRC and the lack of control and tracking of RACs to ensure that nine are misplaced, and (2) an untimely completion of actions to prevent recurrence and the final review of RACs for adequate corrective action. Audit findings hcVe also led to an ongoing effort to establish a simplified and effective corrective action program. The inst,ectors were informed by licensee personnel that the new program should be developed and implemented by January 198 _, _ - - - - - -
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The identification of these concerns by'the QA' organization indicates tht; conditions are being identified which could lead to11nadequate'or.
untimely correction of conditions adverse to plant safety. Licensee
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' efforts to improve the corrective action program have been noted;
I however, timeliness in determining reportabilityito the hRC and
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completion of actions to prevent recurrence of adverse conditions can be
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further improved. The inspectors determined that continued management attention and emphasis should be placed in these areas.-
j Exit Interview 1The inspectors met with the licensee's representatives (listed in Appendix A)
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on August 21, 1987. The purpose, scope, and results of the inspection'were.
discussed.
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APPENDIX A
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l PERSONS CONTACTED
- Arkansas Power and Liaht
T. Gene. Campbell, Vice President, Nuclear Operations
- J. Levine, Executive Di. rector, Site Nuclear Operations
- *W. Cottle, Acting General Manager. Nuclear ' Quality
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- S. Quennoz, General Manager, Plant.0perations
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C D. Howard, Special Projects Manager
- D. Lomax, Plant Licensing Supervisor
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P. Michalk, Licensing Engineer H.'Greene, QA Superintendent
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. J.: Taylor-Brown, QC Superintendent
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- W.'McCord,QC' Supervisor
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- M. Durst. Project Engineering Superintendent
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- W. Jones, Manager, Plant Modifications
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- E. Ewing, General Manager, Plant Support-
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- B. Eaton, Menager. Mechanical Engineering
- D. Graham.. Supervisor, QC Engineering
'*R. Lane, Manager, Engineering Department
- C. Taylor,l0perations Tech. Support R. Howerton, Civil Engineering - General Engineering B. Converse Operatinns Assessment Superintendent.
j S. McGregor, Engineering Services Supervisor
l J. McWilliams, Maintenance Manager K..Coates, Maintenance
D. :Eichenberger, Maintenance
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R. Barnes. Electrical Engineering
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R. Rothwell,'I&C Engineering
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M. Pendergrass, Engineering M. Tull, Licensing l
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- F. Hawkins, Chief, Quality Operations Section, NRR
- G. Dick, Licensing Project Manager, NRR i
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- R. Ireland, Chief, Engineering Section, Region IV Other licensee employees contacted included operators, engineers, i
technicians, mechanics, and office personnel f
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- Denotes those attending the exit meeting on August 21, 1987.
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AP&LC/NP5
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