IR 05000313/1987026
| ML20234C036 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 12/22/1987 |
| From: | Boardman J, Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20234B957 | List: |
| References | |
| 50-313-87-26, 50-368-87-26, GL-83-28, IEB-79-02, IEB-79-14, IEB-79-2, NUDOCS 8801060084 | |
| Download: ML20234C036 (8) | |
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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-313/87-26 Operating Licenses: DPR-51 50-368/87-26 NPF-6
Dockets:
50-313 50-368 Licensee: Arkansas Power & Light Company (AP&L)
P.O. Box 551 Little P,ock, Arkanses 72203 Fecility Name: Arkansas Nuclear One (AN0), Units 1 and 2 Inspection At:
Russellville, Arkansas Inspection Conducted:
October 19-23, 1987 t t/w[F7
Inspector:
J.,q Boardman, Reactor Inspector, Operational Date
@gramsSection,DivisionofReactorSafety M
'Y' '// /
Approved:
e W.C.SeidleQChief,OperationalPrograms Date Section, Division of Reactor Safety l
Inspection Summary l
Inspection Conducted October 19-23, 1987 (Report 50-313/87-26; 50-368/87-26)
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Areas Inspected:
Routine, announced inspection of the licensee's corrective
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action program.
Results: Within the area inspected, no violations or deviations were identified.
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'8801060084 871229 PDR ADOCK 05000313
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DETAILS 1.
Persons Contacted Licensee
- J. Levine, Executive Director, AN0 Site Operations
- E. Ewing, General Manager, Plant Support
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- D. Howard, Special Projects Manager
- P. Michalk, Plant Licensing Engineer
- D. Lomax, Plant Licensing Supervisor
- H. Jones, Plant Modifications Manager
- R. Lane, Engineering Manager Superintendent
- J. Taylor-Brown, QC Superintendent
- B. Converse, Operations Assessment Superintendent-
- H. Greene, QA Superintendent
- J. McWilliams, Manager, Maintenance
- R. Wewers, Work Control Center Manager
- B. Durst, Project Engineering Superintendent NRC
- C. C. Harbuck, Resident Inspector
- Denotes attendance at exit interview.
The NRC inspector also held discussions with other station and corporate I
personnel.
2.
Licensee Corrective Action Program - Followup of Previous Findings This inspection is a continuation of a performance oriented review of the licensee's corrective action program and a followup of Unresolved Item 313;368/8720-03, which remains unresolved.
I a.
Licensee-Identified Corrective Action System Deficiencies The licensee's audit of the AN0 Corrective Action System (Audit QAP-10-85, Licensee Memorandum SQA-2231, dated March 21,1986)
identified 15 areas of weakness.
Significant corrective action program weaknesses identified in this I
audit included the fact that, while numerous documents such as Job
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Orders (J0s), Plant Engineering Action Requests (PEARS) Engineering L
Action Requests (EARS), and Material Deficiency Reports (MDRs) are i
used to report nonconformances in lieu of the use of Nonconformance Reports (NCRs) and Reports of Abnormal Condition (RACs), only NCRs and the RACs require a determination of cause of an unacceptable condition and action to prevent recurrence.
It was also noted that
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maintenance work documents may include a cause code, but licensee procedures do not require utilization of this data.
A followup licensee memorandum of June 16, 1986 (G. Provencher to J. Levine) regarding the ANC Corrective Action System Audit provided requirements that should be included in an effective Corrective Action Program, namely:
(1) Measures to assure that all safety-related failures, malfunctions, deficiencies, deviations, defective material /
equipment, nonconformances, and any other abnormal occurrences /
conditions are promptly identified to appropriate levels of ranagement for review and disposition (2) Measures to assure prompt determination and implementation of corr.
'm action including action to prevent or reduce the possi*n lity of recurrence (3) Decisions affecting safety being made at the proper level of
responsibility and with the necessary technical advice and review (4) Clear definition of what is to be considered a "significant condition adverse to safety" (5) Determination of root cause(s) for those discrepancies /
abnormalities evaluated to be "significant conditions adverse to safety" (6) Followup verification of the proper implementation of corrective action commitments by person (s) who are technically competent in the area under consideration and without direct responsibility for performing or supervising the corrective action activities
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(7) Documentation of the identified discrepancies / abnormalities, root cause determinations (where applicable), corrective action taken including any action to preclude repetition, and verification of corrective action implementation i
(8)
Independent review of "significant conditions," including the following types of discrepancies:
(a) Violations of applicable codes, regulations, orders, Technical Specifications, license requirements, or internal procedures having safety significance (b) Significant operating abnormalities or deviations from the normal / expected performance of plant safety-related equipment.
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'4 The NRC inspector noted'that'there had-been a-Safety Review Committee (SRC) representative on'the Corrective Action Audit..It-was also noted.that the l_icensee's QA manager makes monthly reports of open audit findings to the SRC.
However, it was!not until-January 1987 that'the open findings of this audit were made an SRC Action Item.
The licensee had hired a consultant.to review the complete corrective action system.- The consultant's report was not available during the inspection. Because of_the long time _ periods involved in addressing the corrective' action audit open items, the NRC inspector could not conclude that the licensee's commitment to improving corrective actions has been effective.
b.
Inadequacies In Overall AN0 Corrective Action System (1), Generic Inadequacies Paragraph 2.d of this report is the list of sN0 procedures provided by the licensee as defining, scoping, and implementing L
the.ANO corrective action program.
The NRC inspector's_ review of these procedures, and interviews with licensee personnel, confirmed the licensee-identified weaknesses discussed in paragraph 2.a.
Of particular significance, as identified by the licensee,-is that corrective action is administered'in a piecemeal fashion through several diverse and independent reporting documents without an administrative overview or centralized coordinating
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function.
The following is the estimated average annual volume of ANO documents relating to corrective action:
Estimated Document Annual Type Volume RAC 600 NCR 130 MDR 450 PEAR 400)
EAR 1000 J0 (Corrective Maintenance)
7200 AN0 presently reviews-an estimated 730 corrective action type documents (60 RACs and 130 NCRs) annually, but does not review an estimated 12,650 documents (450 MDRs, 4000 PEARS, 1000 EARS, and.7200 J0s) that deal with component and component part'
failures, or with problems requiring engineering resolution.
While all 12,650 documents do not cover safety-related
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equipment, ANSI N18.7-1975, Section 5.2.11, to which the licensee is committed, requires that the licensee's corrective action program cover " conditions adverse to plant safety." This scope includes Balance of Plant (B0P) structures, systems, and components that can adversely affect plant safety. The fact that AN0 reviews only 5.5 percent of all documents, which identify conditions potentially requiring corrective action, highlights a significant weakness in the overall corrective action program.
(2) Specific Inadequacies The lack of effective ANO corrective action measures is exemplified by the failure of ANO, Unit 1 Reactor Building Cooling Fan Assembly VSFM-1A on June 2, 1977, (Reportable Occurrence Report No. 50-313/77-13) from inadequate preventive maintenance lubrication; and the subsequent failure on August 31, 1987, of the ANO, Unit 1 Train "C" High Pressure Injection Makeup Pump assembly from inadequate preventive maintenance lubrication.
In both cases vendor-specified lubrication was not performed.
If the 1977 event had resulted in effective root cause determination and corrective action to prevent recurrence, then vendor-specified preventive maintenance lubrication would have been implemented at ANO and the 1987 event should not have occurred.
c.
Proactive Licensee Accomplishments Although the NRC insoector confirmed the licensee's self-identified
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weaknesses in the licensee's corrective action program, the licensee has identified major management areas for improvement.
However, these programs do not address the fundamental weaknesses in the licensee's corrective action program. The licensee has, or is, implementing meaningful programs to eliminate potential problems and weaknesses as discussed below.
(1) Corrective Action Data Bases The licensee realized the need for valid, correlatable data and for computer-based analysis. The Station Information Management System (SIMS) program was purchased and extensively revised by the licensee to make it site specific.
This revision effort included the development of a system with human factor considerations.
The licensee's Material Management Information System (MMIS) is another example of a corrective action data
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base implemented by the licensee.
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(2) Restructure of the Design Control / Plant Modification Management System The licensee performed an extensive. analysis of the effectiveness of the design control and plant modification process, and has accomplished a major restructuring to enhance these management areas.
(3) Preventive Maintenance Improvement Program Arkansas Power & Light Company has' initiated an indepth, formal program for incorporating into maintenance procedures appropriate vendor technical information (VTI) obtained in response to NRC Generic letter 83-28.
Substantive implementation of this program has experienced several delays, with the latest date being July 1988.
(4) Isometric Drawing Update Program The licensee has recently begun a major effort on safety-related piping -systems and associated pipe supports which will verify accuracy of piping isometric drawings and hanger sketches. This effort consists of the following functions:
the consolidation of existing versions of piping isometrics (original mylars, field revisions, stress isometrics and IE Bulletins 79-02 and 79-14 walkdown documentation)
merging all information on one drawing
verification of these consolidated isometric drawings and
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associateo hanger sketches through field walkdowns identifying and resolving discrepancies and updating drawings to reflect actual as-built configurations i
NOTE:
Pipe support baseplate bolting shall be inspected to the extent that this hardware is brought into view during the course
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of the project.
(5) Material Deficiency Inspection Program The licensee has initiated an inspection program for obvious nonconformances such as missing nuts from hangers and fluid
leaks.
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(6) Verification of Design Requirements for Bolted Joints An element of a facility's design base is the integrity of
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bolted joints, especially under postulated dynamic loads. The
licensee has instituted a comprehensive program to assure the
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l integrity of bolted joints.
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d.
Significant Licensee Corrective Action Programs Procedures Keterenced in Report Paragraph 2.b
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Procedure Date Designation Title Revision Effective 1000.2 Plant Safety Committee (PSC)
07/01/87 Program 1000.7 Deviations and Nonconformances
03/14/86-1000.08 NRC Reporting and Communications
06/01/87 1000.09 Surveillance Test Program Control
01/28/87 1000.13 Control of Station Modifications
11/07/86 1000.23 Quality Control Program
03/09/87 1000.24 Control of Maintenance
06/22/87 1000.25 Radiological Safety Infraction /
01/07/87 Condition Report 1000.29 Operations Assessment Program
11/06/86 1000.38 Significant Review Program
01/07/87 1000.56 Trending Program
10/27/86 1001.07 Work Control Center Maintenance
01/19/87 History 1004.01 Quality Control Program
10/08/85 Implementation 1010.01 AN0 SCRAM Reduction Program
03/25/87 1015.01 Conduct of Operation
01/22/87 1015.03 Operations Log Taking
07/19/85 1015.01 Operations Equipment Trending
06/01/87 Program 1015.12 Operations Performance
11/10/86 Monitoring Program 1025.002 Maintenance Department
05/01/86 Organization and l
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Responsibilities i
1025.03 Conduct of Maintenance
06/26/87 1025.04 Maintenance Surveillance
01/12/87 Trending Program 1025.10 Maintenance History
07/14/86 Administrative Program 1032.09 Performance Analysis of
01/01/87 Equipment and Systems 1052.05 Reporting NPDES Violations
07/09/84 1052.011 Steam Generator Chemistry Trend
10/22/86 Monitoring 1102.06 Reactor Trip Recovery
12/04/86 1409.42 Isometric Drawing Update
07/29/87
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1622.014 Investigation of High or Unusual
02/18/87 Exposures 3.
Exit Interview The NRC inspector met with licensee representatives (denoted in paragraph 1) on October 23, 1987, to summarize the scope and findings of inspection activities. The NRC resident inspector was present.
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