IR 05000313/1987039

Insp Repts 50-313/87-39 & 50-368/87-39 on 871201-880119.No Violations Noted.Deviation Noted.Major Areas Inspected: Operational Safety Verification,Surveillance & Followup on NRC Bulletins,Lers & Previously Identified Items

ML20147H308
Person / Time
Site:	Arkansas Nuclear
Issue date:	03/01/1988
From:	Craig Harbuck, Harrell P, Johnson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20147H224	List: IR 05000313/1987039 ML20147H220 ML20147H263
References
50-313-87-39, 50-368-87-39, IEB-87-002, IEB-87-2, NUDOCS 8803080452
Download: ML20147H308 (21)

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APPENDIX B U.:S. NUCLEAR REGULATORY COMl11SSION

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REGION IV

Inspection Report: -50-313/87-39 -

Licenses: DPR-51 50-368/87-39 NPF-6

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. Dockets: 50-313 50-368

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_ Licensee: Arkansas Power & Light Company P. O. Box 551 Little Rock, Arkansas 72203

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Facility Name: ArkansasNuclearOne(ANO), Units 1and2

[ Inspection At: AN0 Site, Russellville, Arkarisas-Inspection Conducted: December 1, 1987, through January,.19, 1988

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Inspectors: ////) w //30/88 I W.'E'.Johnsg,SeniorResidentReactor Dhte ' .

Inspector V ,

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- C. Harbuck, Resident Reactor Inspector

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P. fi. Hirrell, Actin (Thief. Project

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Section A Division df Reactor Projects P

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2-Y Inspection Summary Inspection Conducted December 1, 1987, through January 19, 1988 (Report 50-313/87-39)

Areas Inspected: Routine, unannounced inspection including operational safety verification, maintenance, surveillance, NRC Bulletin followup, followup on previously identified items, and followup on Licensee Event keport Results: .Within the six areas inspected, no violations or deviations were identifie Inspection Conducted December 1, 1987, through January 19, 1988 (Report 50-368/87-39) ,

Areas Inspected: Routine, unannounced inspection of areas including operational safety verification, maintenance, and surveillance, NRC Bulletin followup, followup on previously identified items, and followup on LERs, Results: Within the six areas inspected, one deviation (failure to provide supplements to LERs, paragraph 7) was identifie ;

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' DETAILS Persons Contacted J. Levine, Executive Director,'AN0 Site Operations

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A. Armstrong, Maintenance Coordinator B. Baker,' Plant Modifications Manager A. Cox.-Unit 1 Operations Superintendent E. Ewing, General Manager, Technical Support B. Garrison Operations Technical Support J. GoBell, Hechanical Maintenance Engineer L. Gulick, Unit 2 Operations Superintendsat C. Halbert, Engineering Supervisor G. Helmick,. Planning and Scheduling Supervisor H. Hollis, Security Superintendent-80. Howard, Special Projects Manager

• L. Humphrey, General Manager, Nuclear Quality

• R. Lane, Engineering Manager

• 0. Lomax, Plant Licensing Supervisor A. McGregor, Engineering Services Supervisor

• J. McWilliams, Maintenar.ce Manager B. Michalk, Engineer

• P. Michalk, Licensing Engineer V. Pettus, Mechanical Maintenance Superintendent

• S. Quennoz, General Manager, Plant Operations t P. Restivo, B&W Field Services Engineer R. Rispoli, Fire Protection Engineer P. Rogers, Special Projects Coordinator S. Strasner, Quality Control Engineer C. Taylor, Unit 2 Operations Technical Support Supervisor L. Taylor, Special Projects Coorttinator J. Taylor-Brown, Quality Control Superintendent

• J. Vandergrift, Operations Manager

• Present at exit intervie The NRC inspectors also contacted other plant personnel, including operators, technicians, and administrative personne . Operational Safety Verificaticn (Units 1 and 2)

The NRC inspectors observed control room operations, reviewed applicable logs, and conducted discussions with control room operators. The NRC inspectors verified the operability of selected emergency systems, reviewed tagout records. and ensured that maintenance requests had been initiated for equipment in need of maintenance. The NRC inspectors made spot checks to verify that the physical security plan was being implemented. The NRC in:pectors verified implementation of radiation protection controls during observation of plant activities.

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The NRC inspectors toured accessibl o- a units to observe plant-

- equipment conditions, including pot .c hazards, fluid leaks, and excessive vibration. The NRC int , ,o observed plant housekeeping and cleanliness conditinns during ,ur The NRC inspectors walked down the accessible portions of the following; Unit 1 systems to verify operability:

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. DC power

. . High pressu e injection

. Low pressure injection

. ' Service ^ water

. Emergency feedwater

. AC power

. Power conversion For each of.these systems an abbreviated walkdown was performed. This walkdown included those components whose failure has been determined to contribute to risk of core melt in a probabilistic risk analysi All components were found to be properly aligned.' No discrepancies which would affect component operability were identifie During a tour of the Unit 1 intake structure, it was observed that one of the four batteries for the diesel engine driven fire pump P6B had been leaking acid. However, there did not appear to be an immediate effect on

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operability. The battery was replaced under Job Grder 746024. It was also noted that floor drainage in the P6B pump room appeared inadequate as evidenced by standing water in much of the room. This housekeeping concern had no affect on plant safet During tours of the Unit 1 upper north piping penetration room, the NRC inspector noted the following items:

. A steel, plywood, and glass board for mounting a piping and instrumentation diagram (P&ID) was attached, with the use of four C-clamps, to two pipe supports for the supply and return lines of the

postaccident containment atmosphere sampling syste Although these supports were nonseismic restraints, the licensee, during this inspection period, was unable to provide an engineering evaluation which approved this installation. The board was detached from the supports pending resolutio . Also noted was a missing screw from the limit switch cover of containment atmosphere postaccident sampling system supply isolation solenoid Valve SV-7512. The licensee was informed and Job Request 793163 was issued to install a new scre . Leakage past the seat nf manual drain Valve SW-1033, as indicated by a small leak past the threads of the pipe cap just below the valve, was observed. This deficiency had already been identified by the licensee and outage Job Order 745660 had been written to replace the J

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valve. The NRC inspector-also noted that the packing gland was not tightened down. This was corrected promptly by the licensee ~ Job Request 795208 was also issued to stop the leakage past the pipe cap in the interim. Valve SW-1033 is located in the service water _ supply-to reactor building cooling coils VCC-2C and VCC-20. The leak had no adverse affect on system operabilit During a tour of the "A" decay heat vault in Unit 1, Valve DH-14064 was

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noted as having minor seat leakage, as evidenced by boric acid crystal buildup on the open discharge piping above the valve. The-valve-is th normally closed isolation for a local pressure gage on the supr 5 line to the "A" reactor building spray pump and the "A". decay heat pump from the reactor building sump. The pressure gage was not installed. The licensee issued Job Order 744808 to repair the valv The NRC inspector followed up on a previously undocumented item noted on November 16, 1987. The NRC inspector had reviewed Temporary Modification (TM) 1-87021 which installed a blank flange to stop a leak on reactor coolant pump (RCP) P328 upper seal cavity sensing lin The temporary modification was completed November 15, 198 A comment on the TM sheet indicated that the upper cavity pressure alarm should be deleted from scan while the TM was in effect. On November 16, 1987, the NRC inspector pointed out to.the shift supervisor that this had been done incorrectly since the seal cavity pressure common annunciator window (RCP Seals Press Gi/Lo) was still lighted. As this alarm annunciator has no reflash capability, the pressure alarms for the other RCP seal cavities were effectively nonfunctional. The problem was promptly corrected by the licensee. The licensee determined the cause of this problem to have been personnel error. A memorandum was issued on January 8, 1988, to establish a clear policy regarding what alarm functions may be altered by operations personne These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under Technical Specifications, the Code of Federal Regulations, and licensee administrative procedure No violations or deviations were identifie . Monthly Surveillance Observation (Units 1 and 2)

The NRC inspector observed the surveillance testing required by Technical Specifications on the electrical equipment room emergency cooling system (VCH-4A) (Procedure 1104.27, Attachment 2) and verified that testing was performed in accordance with adequate procedures, test instrumentation was calibrated, limiting conditions for operation were met, removal and restoration of the affected components were accomplished, test results conformed with Technical Specification and procedure requirements, test results were reviewed by personnel other than the individual directing the test, and any deficiencies identified during the testing were properly reviewed and resolved by appropriate management persoi d .

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The NRC' inspector also witnessed portions of the following test activities:

.. Overspeed trip' test on diesel engine for Fire Water Pump P6B (Procedure 1104.32, Supplement XI)

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.- Check of engineered. safety feature electrical distribution (Procedure'2107.01, Supplement 4)

.. hpacity flow test of Diesel Firewater Pump P6B (Procedure 1103.21, Supplement X)

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. Emergency Diesel Generator 2K48 monthly test (Procedure 2104.36, Supplement 2). The NRC inspector noted that smoke leaked from the exhaust manifolds for the initial 15 minutes.of operation and caused a smoke detector overhead to alarm. Oil was also observed to drip from the exhaust manifolds during this time. These observations have been noted numerous times in.the past, on both Unit 2 diesel generators, and outstanding job orders exist to correct these problems. However, they have never been identified as adversely affecting the operation of the diesel generators. Previous attempts to prevent leakage from the exhaust manifolds have failed. During the course of the present cycle, the NRC inspectors have observed an increasing of the leakage. _ Licensee efforts to correct the problem !

will continue to be monitored. During the test, the NRC inspector

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also noted that the. flange, connection of the turbocharger outlet to the air box duct was missing a bolt. This resulted in an air leak

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past the flange. The operability of the diesel was apparently not affected by this air leak. The bolt is to be replaced under Job -

Order 74663 ;

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. Emergency Diesel Generator K4B monthly test (Procedure 1104.36, Supplement 2) ,

No violations or deviations were identified.

. 4. Monthly Maintenance Observation (Units 1 and 2)

Station maintenance activities for the safety-relsted systems and components listed below were observed in order to ascertain whether they

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were conducted in accordance with approved procedures, Regulatory Guides, .

and industry codes or standards and in conformance with Technical  !

Specification l

The following items were considered during this review: the limiting conditions for operation were met while components or systems were removed from service, approvals were obtained prior to initiating the work, activities were accomplished using approved procedures and were inspected

. as applicable, functional testing and/or calibrations were performed prior to returning components or systems to service, quality control records were maintained, activities were accomplished by qualified personnel,  ;

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parts and materials used were properly certified, radiological controls were implemented, and fire prevention cor;trols were implemente Work requests were reviewed to determine status of outstanding jobs and to ensure that priority is assigned to safety-related equipment maintenance which may affect system performanc The following maintenance activities were observed:

. Troubleshoot breaker for CV-2620 to determine cause for tripping (Job Order 747080). This breaker (01514) had tripped during performance of Procedure 1304.147. It supplies power to the isolation valve in the emergency feedwater line from Emergency Feedwater Pump P7A to Steam Generator B. The licensee prepared Report of Abnormal Condition 1-87-220 for evaluation of this problem. While the breaker was out of service, the licensee posted a dedicated operator at the valve for manual operation of the valve if necessary. The NRC inspector verified that this dedicated operator was alert, knew his assignment, and had communications with the control roo . Diesel Firewater Pump P68 surveillance inspection (Job Order 744166, Procedure 1306.27). This job consisted of performing preventive maintenance on the diesel engine to satisfy Technical Specification requirements and vendor maintenance recommendation Replacement of oil and fuel filters, belts, a leaking turbocharger, and verification of the overspeed trip setting were among the items complete . Preventive maintenance inspections and tests of vital AC Inverters Y-11 and Y-25 (Procedure 1307.02, Job Orders 533302 and 533298).

. Hydrostatic pressure drop test on makeup pump room Unit Cooler VUC-7A following replacement of the cooling coils (Job Order 744350, Plant Engineering Action Requests 87-8289 and 87-8338). The basis for the hydrostatic test was ASME Section XI, Winter '81 Addenda, Article IWA 5244, for buried components. A pressure drop test had to be done because two welds within the test boundary were embedded in a wall. The test gage used was calibrated and pressure was observed to be maintained for the 4-hour period required. A licensee quality control inspector was present. No formal procedure was written for this simple tes Instead a combination of instructions listed in the details section of the job order by the work control center, marked up drawings showing the hydrostatic test boundaries, an engineering test specification and data sheet, and operations assistance were used to control and document the test. The lack of formal procedures for performing component level hydrostatic tests was discussed with the licensee. Having previously recognized a need to improve the administrative controls associated with this category of hydrostatic testing, the licensee is preparing a plant administrative procedure to define responsibilities in this area for the engineering, maintenance, and operations departments and the Work Control Center. This procedure will provide the basis for

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t departmental implementation procedures where deemed appropriat For tracking purposes, the conduct of component level hydrostatic tests is designated as an open item (313/8739-01).-

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. Repair of level indicator 2LI-1133B, the B steam generator level [

indication'which is used during local control of the emergency feedwater isolation contrcl valves during an alternate shutdown (Procedure 2304.111,-Job Order 4704).

. Corrective maintenance to restore proper operation of the A charging ,

pump seal water system (Job Order 747536). The quarter-inch tubing . t of the seal water system of the charging pump had become plugged with

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paraffin and what is thought to be fibers or debris still present

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. from past failures of the old design plunger packin The new design packing utilizes a paraffin impregnated ring for starting lubrication  ;

and was installed under Design Change 87-0857 in August 198 ~

When a check valve in the pump failed to open recently, the packing

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apparently overheated, melting the paraffin which then entered the '

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return line of the' seal water system. A smaller amount of paraffin buildup in the seal water lines of the other two charging pumps was j

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also found by the licensee, apparently the result of routine operation. Since installing the new packing, the licensee has noted

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marked improvement in the packing life compared to the old desig However, continued improvements in the design are being sought and tested. Currently, under a temporary change to the applicable l maintenance procedure (Procedure 2402.032), the paraffin impregnated  ;

ring has been replaced with a graphite impregnated ring in the A~ -

charging pump packing. The intent is to prevent paraffin intrusion '

into the seal water system. The licensee has also changed the method l of operating the seal water system for all three charging pump The ,

sea 1 water pump is now run continuously when a pump is idle as well j

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as when operating.- The NRC inspector found that the licensee appeared to have adequate control of the modification and testing of  !

the packing of the charging pumps. This effert will continue to be ,

followed by the NRC inspector i No violations or deviations were identifie ! Followup of NRC Compliance Bulletin No. 87-02: Fastener Testing To Determine Conformance With Applicable Material Specifications The purpose of this part of the report is to document NRC participation in [

the licensee's sample selection as required by the Bulleti ;

The NRC inspector observed a licensee quality control engineer and a f Babcock & Wilcox Field Services engineer draw bolt, stud, and nut samples r from existing Q and non-Q stock located in the licensee's warehouse on l January 15 and 16, 198 !

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the sample selection list and found it to be consistent with the  :

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guidelines of the Bulleti Specifically, sample selection was based on the following points:

. Bolts and studs with the following chemical and mechanical properties were selected:

Material Type Number of Samples Unit 1 Unit 2 g Non-Q Q Non-Q SA 453 gr 660 1 2 2 0 SA 193 gr 87 1 1 1 2 A325 Type I 1 0 0 0 SAE J429 gr 5 1 2 0 1 SA 193 gr B8M Type 316 1 0 0 0 A307 gr B 0 2 0 2 SAE J429 gr 8 0 0 2 0

. Typical nuts for the fasteners chosen were selected, with particular attention given to a specification of A-194, as follows:

Material Type Number of Samples Unit 1 Unit 2 Q Non-Q- Q Non-Q SA-194 gr 8M Type 316 2 2 4 1 SA-194 gr 2H 3 1 1 2 A307 gr B 0 2 0 2

. Q samples were required to have documentation showing traceability from the bolting manufacturer, to the licensee's storage locatio Additionally, Q samples were required to have a certificate of compliance from the manufacturer or vendo Care was taken to choose samples which had clear markings to facilitate identification should problems be foun Some non-Q samples had no markings. The actual sampling was simplified because the licensee has always stored fasteners by purchase order as well as by size and specificatio . All samples were clearly tagged with a unique number and individually segregated in plastic bags for shipment to the testing laborator . Sample sizes ranged from 1/2 to 1-1/4 inches in diameter and 2-1/2 to

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12 inches in length. Both bolts and studs were selected (9 studs and l 11 bolts).

. The sample selection was not based on ',n plant usage. However, after sample selection, usage was determined to be either structural or

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pressure boundary. The sample selection was done using computer l generated inventory lists.

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The NRC inspector reviewed the testing instructions provided to the testing laboratory, Westmoreland Mechanical Testing and Research Compan The instructions were part of Babcock & Wilcox (B&W) Technical Document 19-1171114-01 entitled "Fastener Testing Requirements For Compliance With NRC Bulletin 87-02," approved January 15, 1988. The instructions were appropriate to the specification, grade, and class of the fastener Types of tests were as follows:

Chemical Mechanical Composition Properties Hardness Q - Bolts and Studs X X X Q - Nuts X X Non-Q Bolts, Studs, and Nuts X X The licensee stated that Westmoreland was approyect by B& B&W is on the licensee's qualified vendor lis No violations or deviations were identifie . Followup on Previously Identified Items (Units 1 and 2) (Closed) Violation 313/86-01(II.A): Failure to assure that design controls vare properly performe . Item II.A.1.a (Unresolved Item 313/8601-04): The consequences of high energy line breaks on emergency feedwater components were not addresse The licensee's letter of July 30, 1987, provided additional response to this item. This letter described the evaluations performed concerning a break of the 4-inch steam supply piping to the emergency feedwater turbine, effects of high energy line breaks on new targets related to the emergency feedwater upgrade, and a break of the 8-inch lines to the atmospheric dump valves. This item is close . Item II.A.1.b (Unresolved Item 313/8601-04): The determination as to whether safety-related room cooling was needed when both emergency feedwater pumps were operating was not performe The licensee's letter of July 30, 1987, provided additional response on this item. This letter discussed the results of an analysis which demonstrated that room cooling is not needed to maintain the operability of components in the emergency feedwater pump room when both pumps are runnin This item is close (Closed) Violation 313/8621-01: Etaluations were inadequate to meet the requirements of 10 CFR Part 50.5 . _ - _ . -_ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

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The review performed in NRC Inspection 50-313/87-36 in followup o unresoived item 313/8601-01 was sufficient to form a basis for closure of this ite This item is close ! (Closed) Open Item 313/8017-03: Reactor b0ilding purge alarm i setpoi nt.- ,

The licensee has issued Procedure 1104.21, "Eberline Radiation Monitoring System." This procedure provides instructions for  ;

operators to adjust.the Eberline monitor (SPING) setpoints before and after~a teactor building purge. It also provides guidance on required actions if an alarm is received on the monitors. Training L on the use c' this-new procedure is being provided in the current-requalification training cycle. Procedure 1104.33 has been revised to provide instructions for operators to reset the setpoint of RE-7400 after a reactor building purge. The licensee has evaluated a -

release which was performed from the Unit I reactor building to determine whether the Xenon-133 calibration of RE-7400 produced a '

useful and realistic alarm setpoint. This evaluation concluded that  !

the alarm setpoints were appropriate for both the RE-7400 and SPING j monitors. This item is close ; (Closed) Violation 368/8523-01: Failure to maintain fire doors shu Local' audible alarms have been installed on the four fire doors which had been causing the most problems. An' alarm bell rings continuously l whenever these doors are open. This, together with increased ,

awareness of plant personnel of fire door closure requirements, has improved performance in the area of keeping fire doors shut. The  ;

waste control operators also check fire door status during their '

rounds and make log entries on fire door status once or twice per  !

shift. This item is close , (Closed) Violation 313/8527-01; 368/8528-01: Procedures for control i room ventilation were inadequat This item was reviewed in NRC Inspection Report 50-313,368/87-18. The f

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only items open at that time were discrepancies in Procedure 1104.34 in Sections 7.2 and 3.6.2. Revision 15 of this procedure was  !

approved on August 16, 1987. This revision corrected the discrepancies. This item is closed,

' (Closed) Open Item 368/8528-06: Control room air flow drawings had errors, (

The identified errors on Drawing M-2263, Sheet 2 have been corrected (Revisions 21 and 22). The licensee has revised Procedures 1000.13 and 1032.02 to implement a policy of keeping these drawings and (

others in the M-200 through 299 and M-2200 through 2299 series up to }

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g. (Closed) Violation 313/8705-01: Only one makeup pump room cooler was

operating.

- The licensee has revised Supplements II, III, and IV of

_ Procedure 1104.02 to specify the required operating status of makeup

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pump room coolers at the end of a surveillance test. The waste m control operator's log has been revised to record the status of these y coolers once per shift. Procedure 1015.11. "Operations Department

! Procedure Revision Control," has been revised to specify guidelines e for determining the need for operator training in procedure I revisions. It also provides methods for administering procedure

! revision training. This item is close h. (Closed) Violation 313/8718-01: Failure to station a dedicated operator during a surveillance test as required.

E The motor in the operator for CV-2870 has been replaced with a jg qualified motor and the operator has been functionally tested under g Job Order 724687. Procedure 1106.06 has been revised to delete the

, requirement for stationing a dedicated operator at this valve when it r is open. This item is closed.

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i. (Closed) Violation 368/8722 01: Failure to perform a safety

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evaluation for operation of the containment atmospheric monitoring system, e

g Procedure 2104.33 has been revised to include a new Section 8, r "Periodic Containment Building Depressurization." This change L received a 10 CFR 50.59 safety evaluation and was approved on P August 5, 1987. The licensee has reviewed other operating activities

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their regular meetings. Procedure 1015.01 has been revised to provide guidance on the requirement for having a procedure in hand when performing certain types of operations activitie This item is e close J. (Closed) Open Item 313/8730-02: Revise makeup pump maintenance procedure.

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r Revision 4 of Procedure 1402.0M, "Primary Makeup Pumps (P36A, B & C)

Inspection / Repair," was approved on November 20, 1987. The NRC

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= inspector reviewed this procedure and noted that Attachment 1 provides detailed instructions for disassembling and reassembling the

= pump couplings. This item is close k. (Closed) Violation 313/8713-01: Improper temporary modification to Condensate Storage Tank T-41 The licensee has revised Procedure No. 1000.28, "Temporary Modification Control," to provide additional guidance on what

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1 constitutes a_ temporary modification (Revision 8, October 28,1987).

The licensee has issued a new procedure-(No. 6030.01, "Installatio Plan"). Section 6.7 of this procedure (Revision 1,' November 16, _

1987) includes a formalized process for turning over modified systems from-engineering to operations. Procedure No. 1409.63 was established on May 13, 1987, to provide a' method for using.the degasification' system piping for filling.T-418 while bypassing the degasification towers. This item is close . (Closed) Open Item 313;368/8640-01:

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Clarification of procedural guidance to_ Quality Control (QC) Inspectors for using. deficiency >

reporting document The NRC inspector concluded that the concerns of this open item have been resolved based on a review of the current procedural guidance for the use of the'various types of deficiency reporting documents and tnrough discussions with the QA General Manager and the QC Superintendent. This conclusion is based on the following discussio (1) The two previous site QC organizations and their governing procedures (1004.01 for Plant QC and 1004.18 for Plant Modifications QC) have been replaced. There is now a single QC organization or section under the QC Superintendent. This section is divided into three groups, each with a QC Superviso These groups are QC Engineering, QC Modifications, and QC Maintenance. The QC section operates under a series of QC Operating (QCO) procedures. Those pertaining to discrepancy documentation guidance for QC inspection activities are: *

QC0-2 QC Document Review QCO-6 Welding Inspection QC0-8 Maintenance and Modification QC Inspections QC0-9 QC Discrepancy Identification and Corrective Action System (2) QC modification and maintenance inspection activities are ,

generally performed in accordance with QC Inspection Instructions (QCIIs) rd documented with a QC Inspection Record (QCIR). The QLIIs, prepared by the QC Engineering group, are performed by the QC maintenance or modification grou Normally, a discreprncy found during the conduct of a QC inspection activity is documented with a QC Finding Report (QCFR).

(3) The four pertinent types of deficiency reporting documents available for use h,v QC personnel and the guidance for their use are as follows:

(a) Quality Control Finding Report (QCFR).

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As noted above, this;is used to' document' discrepancie g <found during~the: conduct of'a QC inspection activity. This includes'.most modification and maintenance inspection-activitie The,.use of a QCFR'.is. defined in Procedures

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QC0-8 and QC0-9.-

(b) Nonconformance Report (NCR).

Thisisusedtodocumentdiscrehanciesspecificallylimitea to the categories listed belo Its use is govern a by Procedure 1000.07 "Deviations and Nonconformances,' and also Procedures QCO-6, QCO-8, and QC0- Section 5.14 of QC0-6 states that an NCR is used to

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-document discrepancies found on a completed weld previously accepted by a welding inspecto .Section 5.14.1 of QCO-6 specifies five types o discrepancies that should cause an nCR to be writte Section 5.4 of QCO-8 states that discrepancies-

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identified during _in-proce'ss welning 'or nondestructive-examination (NDE) art not documented with an NCR, but are noted in the remarks section of the applicable welding /NDE inspection document. The QC Inspector.must desc)ibe the discrepancy, state if

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rejectable, and initial and date the entr The welding /NDE inspection document noted above is governed by.the licensee's 1092.XX series procedures, and is used to' document QC inspection activity in this

area in lie'u of the.QC Inspection Record (QCIR).

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Section 5.1'.3.of QC0-91 states that an NCR-would be used to ini.tiate corrective action-for a plant

= discrepancy noted.by a QC Inspector not directly involved in inspection or, surveillance work, the same as;other plant ~ personnel woul Section 6.1 of Procedure 1000.07, states general requirements for when to write an NCR. Since the identification of the concerns of this open item, this procedure has been revise The guidance of this procedure is consistent with the QCO-6, 8, and 9 procedure In summary, a QC Inspector would use an NCR to document noninspection-related deficiencies or welding deficiencies identified on a previously completed a.nd tested wel (c) Report of Abnormal Conditions (RAC).

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- 'Thisl document is governed by Procedure'1000.0d'"NR Reporting ~and Communications." 'A RAC may be initiated b any individual in lieu of.an NCR if'it is suspected that, the deficiency is reportable as defined by.10 CFR-Parts 50.7? and 50.73. This includes a QC Inspector.not directly liavolved in a QCII. directed inspection activity. However,

.QC0-8,'Section 5.1.2, states that when a significant condition adverse to. safety is identified, then a RAC is used apparently in addition to a.QCFR, if it is' determined to be a potentially reportable occurrence by the,QC Superintenden ~In summary, then, a-QC inspector may initiate a RAC for a deficiency found other than while performing _a QCII, but a QCFR could result in a RAC if so determined by QC managemen (d) Document Discrep'ancy. Notice (DDN).

Procedure QC0-2, Section 5.3 states a DDN is used to identify and document resolution of documentation discrepancies-found-during QC Engineer review of quality records during the^ initiation or closeout proces Section 5.1.5 of QCO-2 states that the'DDN is not intended to-replace:the NCR or RAC for problems within the scope of-the procedure governing those document Types of documents that are included in these reviews are:

Design' Change Packages (DCPs) -

DCP Implementing / Testing Procedures Maintenance Workplans Licensee Administrative Procedures Job Orders.

Modification Installation Procedures Weld Packages ASME-Section XI Repair Packages l (4) The licensee appears to have an adequate training program for QC

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pe sonnel regarding the administrative controls for documenting i- deficiencies. This training covers the QC Operating Procedures ( thoroughly. Additionally, contractor QC personnel are subjected to a screening and indoctrination process prior to being ,

approved to perform QC inspection activitie Based on the above, L.', s open item is considered close . Followup On Licensee Event Reports (LERs) Units 1 and 2 The purpose of this part of the inspection was to determine whether the licensee has taken the corrective actions stated in the LER and whether the-response to each event was adequate and met regulatory requirements,

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-16 license conditions, and commitments. The NRC. inspectors-reviewed the

following LERs. 'Those marked with an asterisk-(*) are considered close Remarks regarding each follow:

-Unit 1 Unit 2 85-001-00- 84-022-00 86-001-00- *85-002-00 86-002-01 *85-007-00 ,

'86-006-00 *86-011-00

• 87-004-00 86-012-00

• 86-014-00

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• 87-007-00

• 87-001-00

• 87-002-00

-*87-004-00 Unit 1-Lit:9cce Event Reports (1) -(Oben) LER 85-001-00, Steam Driven Emergency Feedwater Pump .

(P7A) Inoperable.-

-The NRC inspector noted that a supplemental report originally

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planned for submittal by~8/1/85,-had not yet been issued. Two items were noted which should be addressed by the licensee in the supplemental report:

. A' complete scenario of the events should be provide On deficiency was not discussed in the original report. This was the miswiring of the pump turbine speed controller which was believed to be the cause for the pump failing the

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first attempted surveillance test on January 6,198 . The future corrective action of licensee management addressing the identified weaknesses in design package review should be discussed in the context of recent improvements in the plant modifications process.

l This LER remains open pending NRC review of the supplemental repor (2) (0 pen) LER 86-001-00, Emergency Diesel Generator K4A Failur The NRC inspector reviewed Revision 1 of the licensee's Investigation Report of this event dated January 1986. This report contained nine recommendations. The LER listed only five of these as potential corrective actions. Also, the licensee committed to submit a supplemental report on January 7, 1987, but has yet to do so. This LER remains open pending NRC review of the supplemental report and determination of the adequacy of the corrective actions described therei ..

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s-(3) (0 pen) LER 86-006-00, Boric Acid Corrosion of Carbon Steel High Pressure Irjection Nozzle ar.d Reactor. Coolant System Cold Le . Pipin '

'The NRC inspector.found that the root cause had been determined and.that the corrective actions:taken appeared adequat Records of inspections conducted to identify additional boric-acid leaks and the program for performing periodic inspections were reviewed. Locations designated _for. inspection appeared to be comprehensive. However, a. concern was identified regarding the licensee's judgment of-when to take action to stop small leaks. This concern is based on the_recent example of the leakage from the "B" once-through steam generator lower primary inspection port hand hole. Some evidence of leakage had been identified there in a November 1986 inspection, but action to repair it was delayed until the October.1987 midcycle outage, when the leakage was found to have increased and to have caused minor damage-to stud hole threads. This concern was addressed in NRC Inspection Report 50-313/87-3 The NRC inspector verified that the following two corrective-actions had been accomplished. One was the modification of operating procedures regarding the required act.ons upon identification of boric acid leaks (Procedure-1102.01, Attachment G, and 2102.01, Attachment D). -The other was a design modification on the high pressure injection'llne insulation,~such as below Valve t!U-45A to deflect any future leakage from the valve outside the insulatio However, the NRC inspector determined that another corrective action had not been accomplished yet. This was the performance of a detailed stress analysis for the repaired nozzle to further qualify extended operation. Pending completion of this stress analysis by the licensee, this LER remains ope (5) (Closed) LER E7-004-00, Reactor Trip and Emergency Feedwater Actuation During Power Ascension Due To Main Feedwater (MFW)

Pump Control System Problems.

! The NRC inspector verified that the corrective actions stated in the report had been complete Installation of signal limiters in the integrated control system to eliminate a negative voltage

, being supplied to the Lovejoy MFW pump turbine control systems

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was verified by reviewing Field Change No. 19 to Design n Change 86-1002. Plant startup Procedure 1102.02 was reviewed to I

verify it contained ~ operator guidance'to keep the MFW pump in manual control until 20 percent power is reached. This LER is considered close (6) (Closed) LER 87-007-00, Single Failure Design Criteria Not Met l For The Standby Penetration Room Ventilation System.

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18. The. installation of'the design. change and the successful post.nodification testing were. observed by the NRC inspector This LER is considered closed, h b. Us.il 2 Licensee Event Reports

, (1) (0 pen).LER 84-022-00, Loss of'Two of Three Reactor Coolant System Leakage Detection System The NRC inspector found that the only preventive corrective action completed in response to this event was directed at reducing the ambient temperature in~the' upper north piping penetration room (UNPPR) so that the sample pump overload relays for Containment Atmosphere Monitoring System (CAMS) Unit 2, RITS-8271-2, would not trip erroneously. The insulation on the

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main feedwater piping was replaced with nonencapsulated insulation during the last' refueling outage, 2RS, under Design Change 84-0-204 Additional actions proposed were the installation of temperature compensated thermal overloads in both CAMS units and the addition of chill water cooling coils in the ventilation supply to the UNPPR. These actions are apparently still under consideration by the license The NRC inspector noted that the licensee committed to submit a supplemental report by May 15, 1985, but has yet to do se. This LER remains open pending review of the supplemental report by the NR (2) (Closed) LER 85-002-00, Refueling Water Tank (RWT) Level Transmitters Inoperable Due To Freezin As documented in NRC Inspection Report 50-368/85-25, the licensee's corrm t.1ve action to improve the freeze protection of RWT level transmitters was verified completed under Design Change 85-2127. Since that time no additional freezing problems with these transmitters have occurred. This LER is considered closed. It should be noted that the licensee committed to submit a supplemental report on August 30, 1985, but has yet to do s (3) (Closed) LER 85-007-00, Fire Door Not Functional As Fire Barrie The NRC inspector reviewed the lic'ensee's Mechanical Periodic Test Procedure 1306.005, "Fire Door Inspection Procedure,"

Revision 6, effective date of December 18, 1987.. and found that it neither addressed the frequency of inspection nor designated which fire doors were high usage. However, through discussions with the licensee it was determined that all fire doors are

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f inspected levery 6 months'as'an interim measure until further evaluation is-completed. .This evaluation, Safety Review

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Committee-Action Item 87-1303, is to update. fire door specifications in general and to include additional requirements for high use doors. Based on the interim 6-month inspection interval this-LER is considered closed. A supplemental _ report originally planned for submittal on September 16, 1985,-has not been issued ye (4) (Closed) LER 86-011-00, Reactor Trip On High Reactor Coolant

~ System Pressure Due To Turbine Trip The NRC inspector reviewed the licensee's' maintenance procedure for the moisture separator reheater drain tank level control valves 2CV-0417'and 2CV-0418, Procedure 2402.86, Revision 0, effective date' June 25, 1987. The procedure appeared to be detailed, comprehensive, and adequate to direct prope maintenance on these control valves'. This LER is close (5) (0 pen) LER 86-012-00, Inoperable Pressurizer Code Safety Relief-Valves (2PSV-4632 and'4634)

The NRC inspector found that the licensee had been unable to identify with. certainty the root cause of the low safety valvo lift pressures. ' Followup' actions planned include the

. modification of the' pipe supports' adjacent to_the valves under

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DCP 87-2041 during the next refueling-outage, 2R6. It is _

thought-that the present design of the supports has contributed to the persistent leakage problem with these valves, and that this leakage has contributed to lowering the lift pressure of the valve The licensee committed to submit a supplemental report by January 30, 1987, but has yet to do so. This LER remains open pending resolution of the code safety valve leakage problem and review of the supplemental report by the NR (6) (Closed) LER 86-014-00, Emergency Diesel Generator Failure Due to Fuel Supply System Fouling as a Result of Fuel Oil Degradatio The NRC inspector found that the licensee has made significant improvements in the maintenance of diesel fuel oil. These improvements were:

. Monthly sampling of day tanks for solids and water (Procedures 1618.028 and 2618.028)

. Receipt sampling of new diesel fuel oil prior to off-load (Procedure 1618.035) to include verification of the flash point (Procedure 1104.23)

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. ' Monthly sampling of the underground storage tanks from a

• low point on the tank outlet. for sediment, sludge, and water (Procedures 1618.010 and 2618.005)

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. Draining and cleaning of the day tanks.and underground E storage tanks every 18_ months, at least through the 'nex refueling outages (2R6 and 1R8) (Procedures 1402.066 and-2402.028)

. Addition of fuel preservative to the above~ ground storage tank,.the underground storage tanks, and the Emergenc Operating Facility diesel storage tank-(Work Plan 1409.09)~

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Also included wasit h'e filtering of the fuel in the.above ground and underground storage tanks each refueling outag Consideration-is being given'to modifying the fuel oil system.s that' recirculation piping and filters are permanently installe Presently, temporary hoses and filters must be use Ba' sed on 'the ab'ove', tilis LER is- considered closed. However, a supplemental report originally planned for submittal on January 30, 1987, has yet to be issue .

(7) (Closed) LER 87-001-00, Breach of' Fire Barriers Caused by-Personnel Error While Performing. Plant Modificatio The NRC inspector reviewed the: lesson plan and attendance records-for the training of plant modifications personnel

.regarding this event. Tle training emphasized how to identify a breach in a fire barrier and the required actions if a breach occurs. Additionally, a discussion of this event has been permanently included in the' orientation training for contractor personnel. This LER is close (8) (Closed) LER 87-002-00,~ Degraded Plant Fire Barriers Due to Installation of Improper Seal Material in Seismic Gap Separating Adjacent Building The NRC inspector verified that the seismic gap between the Unit 1 and 2 auxiliary and turbine buildings had been sealed properly with fire retardant putty under Design Change 87-2030, through reviewing the applicable documentation and visually inspecting the gap at several locations. The NRC inspector also verified that all locations where the gap was sealed were ,

assigned unique fire barrier penetration numbers, and that these

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penetrations were being incorporated into the licensee's fire barrier inspection program, Procedure 2405.16, and the Fire

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Barrier Penetration Log. The log is generally updated more frequently than the procedure and is used to supplement the penetration list of the procedure by the person assigned to inspect a particular fire barrie The NRC inspector found that

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. Technical-Specification cyclic inspection requirement. .;This 'LER -

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is' considered closed.'

- * (9) (Closed) LER;87-004-00, Subcritical Reactor Trip During Plant Cooldown'Due to Personnel Error and Procedural Inadequac The NRC inspector verified that plant cooldown Procedure 2102.10 had.been revised to' require closing-the containment main

.feedwater isolation valves to the steam generators at the

- beginning of.a plant cooldown. This LER is closed.

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As noted in the previous remarks for the LERs liste'd below, supplemental reports. committed to by the licensee have not been submitted and are:-

overdue. The due date specified by the licensee on the LER is also-provide '

Unit-1 Due Date Unit 2 Due-Date 85-001-00 August 1985 84-022-00 'May.1985 86-001-00 July 1987 '85-002-00 August 198 _007-00 September 1985 86_012-00 January _1987 86-014-00 January 1987 The failure of the licensee to submit LER supplemental reports as committed to when the initial LER was submitted is an apparent deviation. (313,368/8739-01) Exit Interview The NRC Resident Inspector met with Mr. S. M. Quennoz, General Manager, Plant Operations and other members of the AP&L staff at the end of inspection. At this meeting,.the inspector summarized the scope of the inspection and the findings.

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