IR 05000313/1989037
| ML19332D903 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/22/1989 |
| From: | Paulk C, Stetka T, Wagner P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19332D901 | List: |
| References | |
| 50-313-89-37, 50-368-89-37, NUDOCS 8912060020 | |
| Preceding documents: |
|
| Download: ML19332D903 (18) | |
Text
{{#Wiki_filter:FM, i ..u.
, q' i # ' w u4
m - , , , , ~~ - ) Q (,8 }%. ' ' . ' ' ' ,j- , &;f.
^ '
' , A.
' ' R,.y[ - . >;(F.
~. ' , ] t gplA11p i &; ' [ ^ ' JAPPENDIX , " - " . u.
, , ' p ' Q.J.
.. C. .. ,
~ >
-
. , 'll.S. NUCLEAR' REGULATORY-COMMISSION'
y + , 1.cNr1 i+ REGIONi!V- .
g, ,'y.
'
'- ,, , . . (.} t
- '. 2 r
, , , , E NRC Inspection Report: 50-313/89-37L ~~ ~ NPF-6- ' ' Sy: zm. ~ F 50-368/89-371 . Operating 1 Licenses: DPR-51' ' ,q.
c - a t, . , ,g-y , = >- . p , . "b . - t +
, ,' " Dockets: -50-313 'b
- P
' ' '50.-368 ']w .my n.
.L ' i.
, r.
.
t Licensee: lArkansasPowerALightCompany; . - ' X ..,. P.O. Box _551- . . ' - - 'Little' Rock', Arkansas-l72203-i: f, y > t
~ , < y . FacilithName: Arkansas' Nuclear.0ne (ANO), Units 1'and'2 , , [. . Inspe'ction At:: ' Russellville Arkansas (Onsite), and' Arlington, Texas .(NRCRegion.IV) ' o InspecE1onCondu'cted:.0ctober'16-2b,andOctober'30through' November 3,1989.. l- _.' (Onsite).-October 23-27,01989 11n NRC Region IV) r.
, r . . -. . Inspectors: meId.- //-E2 89
l, P. J. Wagner,. Reactor Inspector Plant Systems Date Se'ction.; Division'of Reactor Safety ' ' 1-l ' s //-22-e9 , r; ' h' C.,(. 3aulk, Reactor Inspector, Plant Systems .Dete '! ! Section, Division of Reactor Safety q K '< , v.. > ..s,- l //d22/M ! x-Approved:/ I AN - T. F. Stetka, Chief, Plant Systems Section Date' / ' . Division of Reactor Safety
i , (,
Inspection Summary l inspection Conducted October'16 through November 3, 1989 (Report 50-313/89-37; ) " 50-368/89-37)- c, Areas 4 Inspected: Routine, unannounced inspection of the licensee's programs j to: (1) control design changes to the facility (Unit'2 only), (2) comply with t.he provisions of 10 CFR 50.62 related to protection from anticipated - 89i206CO2d 891130 , ADOCK OSOOrg3 ' PDR .. a . , s '
,, _ g
rp$ l %l = - c, y r = --l' 7 m _.
'" ^ ~ ' .,l* . ,-.. Y . $p MV, /o: s ' - , , , _ ijk ', ~, ,.n
y ~ g ce, , , ' U> % ' s
4. >. . .. . i
- transients without scram (ATWS) (Unit 2 only), (3) maintain and. calibrate.
instrumentation (Unit 2 only), sand (4) ensure proper installation of heat' l ' E.
shrinkeble tubing 1(both units).- The' inspectors also evaluated licensee action's ".n c(10 CFR;Part 21 Reports)y reported-items and vendor problem notifications- 'in response to previousl 4+ 'for both units.
vv V Results: HWithin the areas inspected.;no violations-were identified. A number-r of potential problems.and; inspector concerns,were, however.idiscussed with ' , licensee personnel.
, The inspectors 'were' hindered during the first week of:onsite inspection 1by.an W apparent lack of coordination among licensee organizations;but were able.to; cosmlete most of the scheduled ~ activities. An example of this problem,- E . discussed in' paragraph 5.a. related to instrumentation personnel not being-aware of how TechnicalsSpecification calibration requirements were being- ' fulfilled x The inspectors found the format and. in most cases, the-technical- ~ content of the instrumentation related procedures reviewed to be adequate.
. .
- The inspectors found most of the' design changes that'were being-implemented to-be thorough and well planned but questioned the. adequacy of the evaluation for r
. ' one change being implemented on the Unit 2 emergency diesel generators (see a-paragraph 4.d)...The inspectors' questioning of the diesel generator modification:resulted in a. commitment by the licensee to restore the circuitry ~ .to the original condition and to pursue a formal change process in the future.
, " The inspectors.also noted that'most of these changes had been initiated a
- number ofl years ago but-had not received final engineering approval until
. l' irecently.
The inspectors also discussed the timeliness and technical ' adequacy of the j 4S , licensee's' program to respond to vendor identified problems reported under
' 10 CFR Part 21. The inspectors were concerned that no apparent acti6n had been J .-taken to provide assurance that problems with current transformers did not .J _ B-exist at A_N0-2, even though the unit was in a shutdown. condition and the i recommende'd inspection could be quickly and easily performed. The licensee had informed NRC Region IV personnel of its intent to evaluate the ANO Part 21' Program 'priorf to this inspection.
]3 , .! I > ! - ,
b
, . Y ! , \\$ i
g y.
- .. w- , . . - , , % > . -..? ; '
' (, .- ' '4 ~ a j , ^l * -3- -
y ' ' l
' j , , t.
DETAILS.
, w_, g a v
' ' . - 1.. Persons Contacted - ,. g' ic (
- AP&L
, P R. Barnes, Supervisor, Design Engineering - a <N. Carns, Director, Nuclear Operations- ' ' % T - J. Fisicaro, Manager, Licensing . ,
' '
- J. Jacks,' Nuclear Safety ard Licensing Specialist
, , ,
- < *G. Jones, General, Manager, Engineering.
- R._ King, Supervisor,' Licensing-
. , ~ D. Lomax, Plant Licensing Supervisor s1
- E. Rogers, Maintenance Engineering Superintendent
,
- J. Taylor-Brown, Quality Control /Ouality Engineering Superintendent
/ . M. Tull, Project Engineer
- J. Vandergrift. Director Nuclear Operations..( Acting)
'.J;.Waxenfelter, Unit 2 Maintenance Manager , . NRC-R. Haag, Resident inspector, ANO '
- C. Johnson, Reactor: Inspector, Region IV
,
- W. McNeill.. Reactor: Inspector, Region IV C. Poslusny, Project Manager, ANO, Unit.2
- T..Stetka.Section Chief, Region IV'
C. Warren, Senior Resident. Inspector, ANO
- The above personnel attended the exit meeting held on November 3, 1989.
The NRC' inspectors contacted and interviewed numerous other AP&L personnel during=the inspection.
2.
Followup on Previously Reported Items - Units 1 and 2 a.
10 CFR Part 21 Reports (36100) (1)- (0 pen) 88-07; " Gamma-Metrics Cable Assemblies" By letter dated May 10, 1988, Gamma-Metrics informed the NRC and g' affected. licensees of possible problems with solder connections on cable assemblies installed as part of neutron flux monitoring systems at various nuclear power plants. The vendor identified solder joint leakage problems that could result in the' failure ~ > of the neutron flux monitoring system during a design basis accident.- Since ANO was identified as a customer that was being informed of the problem in the letter dated May 10, 1988, the inspectors reviewed the actions that had been taken in response to this issue.
s
- -. - -. .
' .. , . . .,. [~'3.. g g;, m . ' y . ,,
. . > . , '~ ,, p_ s 4.
, ~ x y
,, I ' ' , - , p , , N,' N The. licensee had' com'pleted the necessary tests and! repairs;on the., i '
- >
Unit 1~ cables during the previous refueling outage. 7The work ' ,, , .'was' completed under Job Order (J0) 766870. The Unite 2 work was > being conducted under JO 796400'during.this inspection period.
' < _ [ l f lThis report will remain open pending a future'NRC inspection to <
- ' , W 'overify that the required repairs had been completed on Unit 2
I, , ' ,
- prio'r to its return to service following the ongoing refueling..
. '
- A" , outage.
.1 '
, , ' ' ' -(2)i (0 pen) 89-05; "ABB Power Distribution, Inc.. Current .. , ' ' Transformer (CT) Encapsulate Material"' ,2pr
4 ' ,? By letter-dated April'17, 1989; ABB infonnedLthe NRC and D ~ affected licensees.that ~ problems had been identified with the . epoxy-anhydride compound used to encapsulate electrical ' ' ' "' components.- The compound had been identified as. softening or reverting back to a liquid state'in some installations; however, t , vendor testing was. unable to predict the frequency of these' occurrences. Therefore, ABB recommended that electrical components encapsulated in this compound be inspected at-approximately~18 month intervalsito ensure that'the reversion
- process _(which is slow but irreversible) had not started.
i
. The licensee initiated Condition Report (CR) - C-89-067 for this . -problem on May: 12, 1989. This CR called for a preventive - " maintenance inspection program to be developed by December 31, ., , 1989. The inspector questioned why no physical observation " t efforts to assess the reported condition were being implemented during the ongoing Unit 2 refueling outage and was informed that some inspections.had been conducted but had not been documented.
This report will remain open pending NRC verification that an acceptable CT encapsulating material inspection program has been implemented.
~ '(3) (0 pen) 88-10; " Safety Grade Relays" > By letter dated August 5. 1988, Combustion Engineering, Inc., . informed the NRC and affected licensees of potential problems
with electrical relays provided by Potter & Brumfield, Inc. The , motor driven relays (MDRs) had been found to fail.to return the b L contacts to the normally open position when power was removed I from the operating mechanism. The problem had been traced to internal mechanical binding which the relay's spring force was
-insufficient to overcome.
L l The licensee initiated CR-2-89-017 on January 11, 1989, and L CR-C-89-021 on February 6, 1989, to evaluate the MDR problem.
L At ANO, both 28VDC and 125VDC relays were being evaluated. The ' corrective action evaluation in CR-C-89-021 recommended the , replacement of the 125VDC MDRs during the ongoing refueling l' :
1 -., , . . -. - - - - -.. - - - -. ..... . -. -
>' w .. , ' } '._ t)f; ' ' .,q_ . - ',y - ' ' < , , . , , , '
.
- i .' y , , . outage for Unit 2.(2R7)'and=the next' refueling outage for Unit.1: "! '(IR9).. These corrective actions, however, were being
reevaluated and final documentation was not available.
- ') n '. !This report will, remain open pending future NRC review of.the ' licensee's implemented corrective actions for,all affected MDRs.. %
' (4) 1(0 pen)-88-19;;"Melami'ne Torque Switches'in Limitorque Operators"
,, , , L
Duringrairecent'NRC Diagnostic: Team Evaluation conducted duringi
'" August and September 1989, a concern was. raised over the- + ,( licensee's handling of a Part 21 report-issued by the Limitorque ' .K . Corporation for valve operators.
Limitorque issued the report - in' November 1988, and.the licensee completed an evaluation in - April 1989. When the Diagnostic-Team questioned'the adequacy of' / the-evaluationi the licensee undertook another evaluation and ' , performed testing' that was -recommended in the Part 21 report.
- ' ' The licen_see's difficulty in identifying which valve operators
. - were affected was: attributed to-having ineffective walkdown data. The_ lic'ensee. completed the reevaluation on November 1, 1989. The evaluation identified;the potentially affected valve operators,' described the testing:that was performed, and
discussed the future ' actions that'would be. taken for those valve . operators'inside the Unit 1 containment,
, a - The. reevaluation' determine'd that there was no safety impact.in ' " continuingJto< operate Unit I until the mid-cycle shutdown outage s
scheduled for;the end of November 1989. Corrective actions for
Unit.2:were'to be completed pr.ior to startup from the ongoing - refueling outage. The licensee committed to completing the inspection and necessary repairs to the Unit 1 valve operators 9-prior to startup after the mid-cycle outage. -This inspection and necessary repairs to the valve, operators was delineated in
the engineering evaluation submitted for NRC review by letter J dated November 1, 1989.
, . L 'During discussions on this subject, AP3L agreed that there may be-short comings in the AND Part 21 program and had previously l- , l ' informed NRC Region IV personnel of its intent to perform an ' I assessment of possible improvements.
' This report will remain open pending inspection of the completed .J' corrective actions of Units 1 and 2.
The inspectors discussed their general observations of the Part 21 l program with AP&L management personnel during the inspection and at , , the exit meeting held on November 3, 1989.
Since the purpose of the l' Part 21 notifications is to inform licensees of problems identified at other facilities, the inspectors stated that they did not consider the AP&L program was taking full advantage of the information provided.
The inspectors noted that there had been no licensee . - - - - - - - - - .
Q?;dm ' 7:4 ' y ~ , 'J _
" - , , ' 51 f
- 3
, N ' , , ' Q: .
z , m
,
,
6 - ,- y , V b;
, -.- N @, document'ed inspections conducted, since being notified, to detemine" ,g J ' if-- the CT problem existed at AN0'and that the licens'ee's operability, , - determinations for the MDRs had been based solely on the absence of ' ' , ,* cfailures at ANO.
i ~ >
< , . , ' LTheproblemswiththeLimitorqueLvalveoperators-hadbeenthesubject
- .of discussions prior to this' inspection;between AP&L and'NRC
. . - Region IV personnel..As a: result of those discussions,.AP&L- ~ ^ L ^ expressed its intent to ree' aluate the ANO.Part 21 program,:to v (: '. implement changes ~as needed, and to ensure that.previously closed: s , Part 21 reports had received an acceptable level of consideration.
' p a , , y No violations or deviations were identified, p . ~ b.
Previous Inspection Findings :(92701 and'92702)
7 g , (1) ;(Closed)' Violation'50-313, 368/8805-04 Inadequate l Procedures:. c Y- ' The licensee was found to have inadequate procedures to maintain.
. . the' qualification status of the containment building fan motors.
, , A The specific issues involved the procedure for repair of electrical insulation, lubrication, and repair / replacement of y ,
-
- motor bearings,
,, c y , " The licensee-removed references from the procedures relating.to "
s A;the repair of the motor windings; any motors that require 9' '
- "
windi_ng. repair are to.be sent-to the manufacturer. The issue of ..." lubricants'was. adequately addressed in Procedure 25.007, "E0 ' Listed Equipment's Approved Lubricants," Revision 3.
The issue . of bearing lubrication and repair / replacement was adequately addressed in Procedures 1025.017 " Lubrication Changeout," i ' . , f . Revision 0; 1403.008, " Unit 1 Containment Cooling FanLInspection - and Repair," Revision 5; and, 2403.005, " Containment Cooling c '
Fans," Revision 5.
This item is considered to be closed, + jE (2) (0 pen)OpenItem 50-313,368/8829-05 Nylon Crimp Connectors in Limitorque Dual Voltage Motor Operators L The issue of the crimped connectors was identified during the ! 1986 Equipment Oualification (EO) inspection at AN0 (NRC Inspection Report 50-313/86-23,50-368/86-24). At that time, adequate documentation to support the qualification of the ,,. splices was not available in the AN0 E0 files.' E " L The licensee contended that these connectors were only for l' > mechanical protection and therefore were not required to be qualified for exposure to moisture. However, moisture intrusion > into the valve operator switch compartments continues to be a valid concern and has been addressed in various Limitorque ~ ! reports. The licensee agreed to replace the crimped connectors with a qualified replacement.
Ia l
.. . - - - - .- ..
f{{y* g. m.q' ' G w ~~" Y " r - , > , &Q- ? n , , y - . .. , -u s . . 7.; , , ' o~ , -) , . y )
- '
,In order to verify that'the. nylon' connectors._had been replaced.
' , the_ inspectors requested the documentation;for those repairs _ The: licensee provided information for Unit'1,'which showed that- , the connectors.had been replacedlunder various work packages. A
review of the work packages indicated.that the connectors were-w replaced with tape = splices in November 1988.' Theitape splices'that replaced the crimped connectors were _ [ " required'to be qualified in-accordance with 10 CFR 50.49(1).
, , The qualification of the taped splice: configuration was also the ' J ,
topic of_ Violation 50-313. 368/8829-02. The licensee has-C a- ~ _ responded to this violation; however, subsequent inspection of . o eb
.the corrective. actions'has not yet been performed. During-
i this inspection, the licensee was informed;that it did not " appear that the taped splices were fin-a qualified configuration.
- The licensee.connitted to further evaluate the taped splice ' ) issue and inform the NRC prior to the scheduled November 1989' ' ' . , -o'utage of Unit 1-as'to what actions will be taken on this > , , '
- c z
matter._ ,
. + ! ~This item will remain open and will be reinspected during a-
- future' inspection in conjunction with the followup actions for
% TYiolation 50-313,368/8829-02.
' ' ._ , m 1(3) (0 pen)'Open Item 50-368/8829-04 Bunker Ramo Electrical
I, ' Penetration Assembly (EPA)'Oualifii:ation-The-ANO E0 file did not contain adequate documentation to m support qualification of the'EPAs. The information was .available but had not been incorporated:into the qualification file. The. licensee has subsequently included calculations in ' the file to derive:the insulation resistance (IR) values to ' support qualification. The licensee has also obtained a test
- '
report that would qualify the EPAs to'10 CFR 50.49 standards, but had not incorporated the information into the file.
This iter will remain open pending review of the E0 file to verify that the new infonnation had been incorporated.
3.
Compliance with 10 CFR 50.62 - Unit 2 (25020)
The NRC published 10 CFR 50.62, " Requirements for Reduction of Risk from Anticipated Transients Without Scram (ATWS) Events for Light-water Cooled Nuclear Power Plants" in June 1984. This regulation provided the technical-and scheduler requirements to be implemented by the licensees to provide protection from ATWS events.
Further guidance was provided in NRC Generic Letter 85-06, "0A Guidance for ATWS Equipment That is Not Safety ' Related," dated April 16, 1985. The AP&L request for partial exemption from'the requirements of 10 CFR 50.62 for ANO-2 was denied by the NRC in letter dated February 16, 1989. The licensee was also found in violation , f . . .. m . ~ ~
wv g,- j - . }4"'n . , s
' . y '-, ;.e y ,'
J 1: .' < s , ,
' ' y,- . + ,, . , ^ ' -8-
-*
'
,-
'been implemented during.the previous: refueling outage)..
.
'
By letter dated June 21. 1989, the NRC provided-a Safety Evaluation of the two portions of the ATWS protection being implemented during this
<
refueling outage and reiterated that the third portion should also be
-
',
. implemented,: independent of the staff's review, as required by the
'
>
regulations.
' . ' ' 'The three' systems being proposed'for compliance with 10 CFR 50.62 at AN0-2' consist of. a diverse reactor scram system '(DSS), a diverse initiation of'a ,~ turbine trip)(DTT), and a diverse actuation of the auxiliary feedwater
system-(DAFW.
The first two of these s this-inspection', the otherL(DAFW)ystems were being implemented.
' - . , T duringx was being delayed until a > subsequent' outage. The licensee discussed this implementation schedule in " their June 14, 1989, response to the Notice of Violation dated May 15, 1989 (50-368/8910-03). The inspectors reviewed the Safety Evaluation and' L"* ' the-licensee's" letter dated September 25, 1989, which clarified the AP&L ,' position on several points made in the safety evaluation. The inspectors- . also reviewed the implementing Design Change Package (DCP) 85-2073,
Revision:3. This large DCP contained documents and drawings related to , -the specific design characteristics of the DSS and contained step-by-step ,
- installation instructions. The inspectors'also verified the installation r
of the' involved hardware. A listing of the pertinent drawings is J ' included in Attachment 1.
The DSS being implemented at AN0-2 included the installation of four new pressure transmitters to monitor pressurizer pressure and provide trip > signals if.the pressure increased above the regular reactor. trip , system:(RTS)setpoint. The transmitters were being piped to existing pressurizer taps and were powered from a separate power supply. The a instrument trip signals were then compared by microprocessors to provide a 2 outlof 4 trip logic. The processor output trip signals were sent to newly installed electrical contactors on the cutput of each of the control element drive mechanism (CEDM) motorigenerators. These motor generator sets provide the CEDM power, and opening of the new contactors would deenergize the CEDM buses,'thereby causing a reactor scram. Sinc'. the new ,' components, their power supplies, and cabling were independent of the RTS, an independent means of causing a-reactor scram was being provided. The-inspectors noted, however, that the system was not safety-related nor L single' failure protected.. These provisions are not required by the-regulation., The DTT function was being provided at ANO-2 by utilizing existing equipment. The CEDM busses have undervoltage relays which provide a trip signal to the main turbine trip circuitry.
Since the DSS provides a diverse means of deenergizing the CEDM busses and causing the attached undervoltage relays to trip, the licens'ee reasoned that a diverse means of turbine trip was inherently provided.
NRC acceptance of this AP&L design was provided in the June 21, 1989, safety evaluation.
ll ' . .
[ { /*, - '
i .' l^ , , w .w. - . . tn ~ . ., - W- '; . f I e ' .g.: j , ' ,1
Y' ' .During the inspectors' detailed review of the DSS evaluations and' j
' drawings, the inspectors made the following observations: ' ' Most of.the final engineering and evaluation sign-offs for this 1985
era DCP were completed 1n 1989, the DCP. therefore. reflected-recent - ~ , technical support activities.
, eThe DCP~was complete and thor _ough as evidenced by the inclusion of = , consideration of factorstsuch'as' fire zone hazards' analyses, cable
tray seismic and heat rise evaluations, installation details, testing { and operating directions and a failure mode effects analysis ~ evaluation.
- A number of minor problems' were identified with some vendor provided'
E drawings.. The licensee agreed.to evaluate the drawir.gs and make the necessaryLcorrections as-part of the DCP closeout process.
LThe inspectors rev.iewed the draft procedures for the daily and monthly _ checks of the systems. These,were evaluated to be acceptable after corrections.have been made to the monthly test as a result of a walk-through of the-test. The 18 month surveillance test had not been - > written at the time of. the inspection and was;not available for review.
These' procedures will be written and implemented prior to their next - required performance.
InspectorFollowupItem(368/8937-01): Evaluate the procedures being ~ developed for testing and calibrating the DSS and DTT systems.. , 4.:. Design Changes - Unit 2 (37700) The inspectors reviewed someio'f the Design Change Packages (DCPs) which , ' 'were.being implemented during the in progress refueling outage and made " ' the following observations: ., a.
DCP 83-2173 " Breaker 2A308/2A408 Interlock" . An Engineering Action Request was written on August 30, 1983 because ' it was possible to manually close the Emergency Diesel __ < Generator (EDG) output circuit breaker if the synchronizing meter? switch was positioned to select that breaker even if 'the EDG was not , running. The resolution proposed by AP&L engineering on February 1.,
1985, was to add a synchronize check relay in the remote manual , operating circuit for both the normal and emergency supplies to the .i affected busses (2A3 and 2A4). This relay would ensure that the voltages on both sides of the breaker to be closed were in the proper phase and magnitude before allowing the breaker to closed. The " inspectors found the proposed modification to be acceptable and found ' the work package to provide clear and easily understood instructions.
The inspectors also verified that the modification had no impact on the automatic operation of the circuit breakers.
m - _ _ .
,, _ ._ , _ -_ . .s _ . , ' _; p ll-l +
- -
+ O : (' k ' . , ' 1 (e.
. i
. t u
- -
U' ' ,-10, j i ' f ( .; x r - , , - , ' - b., DCP 85-2073'"ATWS Diverse Scram System" " $ > This~ DCP.was discussed in paragraph 3, above.- f , c.- DCP 85-2075 "CPC-System Pemanent lie-Ins'" ' , "
This;DCP was the final in a series.of 6 DCPs which replaced the Core - Protection Calculators--(CPCs) with newer, more.useful units..The DCP < Lalso replaced the isolation ldevkes to. separate the Class IE' circuits ' , from. the nonsafety-related circuits, with: fiber optic isolators. _ The inspectors found this DCP to be well written in that it provided . n
~ clear instructions on-how and why the modification was being.
" _ implemented._ The completeness of the licensee's evaluation was evidenced by:the reference to procedures which.would need to be revised-to: reflect the new hardware.and byithe consideration of_ , factors lsuch as; fire protection and the percentage of cable tray fil1 'resulting from the addition of new cables installed'for this modification.. Although the DCP indicated that a Technical Specification (TS) change would be' required, there was no indication that a license amendment'
application had been submitted for NRC consideration. When
questioned, licensee representatives provided a copy of APAL's '- i June 13, 1989, application.
'g < g J ~d.
DCP 85-2134 " Deletion of SIAS Bypass on EDG Fail To Start and SIAS + Trip on Unit Auxiliary Breakers" , " This DCP had been initiated by: the licensee to provide the Emergency ' , Diesel l Generators (EDG) with the capability of saving starting air n-
following a failure to start on receipt of a safety injection- ~ '
- actuation signal (SIAS).
In addition,- the DCP stated that anoth'er ' ' change would prevent an inadvertent reactor trip caused'by a spurious - ~ I '
SIAS trip of the unit auxiliary transformer (UAT) supply breakers.- p The inspectors' review of the portion of the'DCP to remove SIAS ! , contacts:from the UAT supply breakers found it to be acceptable; the s review of the removal of the SIAS block of the EDG failure to start circuitry did, however, raise concerns.
'_ LThe inspectors'noted that included in a September 14, 1975, NRC ' " request for additional information, the licensee had been informed ' ' that their response to a prior staff position related to the bypass' of certain trips in the EDG circuitry was incomplete and r unacceptable. The licensee was directed at that time to either u P bypass, or provide redundant protection for, among others, the EDG failure to start circuitry when a SIAS was present. The licensee had installed the required bypass prior to plant licensing but was in the process of removing that bypass via this DCP. The inspectors noted that Technical Specification (TS) 4.8.1.1.2.c.8c requires the licensee to simulate a loss of offsite power in conjunction with a SIAS and verify "that all diesel generator trips, except engine .
%;* '
' ~l%
~R ' %w s .
fe
' ' + ? p .
. Nf
- 6,,O[
,', N,: y ' ' (O'
., ,, _ , { ) - -, _. " -11- , , s > ,- ' ' ,{ J +. , - overspeed,' lube oil pressure, and. generator differential, are' : ,% automatically; bypassed upon a SafetytInjection Actuation Signal."' ' < , " The inspectors were:infonwd.by licensee personnel that it was AP&Lis-j ,. interpretation that the failure-to-start s'hutdown= resulting from the y t timing circuitry was notta diesel generat'or trip but rather a failure ': m' y ,. to start ands therefore..no TS change.:was required to allow the ' .
- modification tc-the EDG start circuitry. 9-
The11nspectors'wcre also concerned that the' timing relays, which;had " =previously been configured in.a parallel circuit that was bypassed by
_ , : a SIAS' signals were being-reconfigured into a series circuit but.
a-would retain'the soproximately 10 second.setpoint. While this.
, configuration would require both relays.to:" time-out" to produce a d ' , shutdown and thereby provided some degree of redundancy-and . reliability, the DCP-did not provide adequate assurance-that the existing;setpoint was conservative for all accident conditions.
The inspectors' discussed the above-concerns with appropriate licensee.
personnel.and pointed out'the inconsistcncies in.the USAR related to , the EDG starting air requirements. As a result of those discussions and further evaluations AP&L engineering personnel committed to- ' restore the SIAS bypass.of-the failure to start trip ' prior to.
resumption of reactor operations and to pursue a formal licensing + change in the future. The inspectors found this commitment to - -adequately resolve their concerns: and will-verify the licensee's factions in a future. inspection.
~ , - Inspector Followu) Item (368/8937-02): Evaluate licensee actions to restore the SIAS >ypass in the Unit 2 EDG start circuitry.
, ' 5.' Instrument Maintenance and Calibration - Unit 2 (62704 and 56700) >> E-The inspectors evaluated whether the corrective and preventive.
- maintenance (PM) activities and:the calibration activities relative to
' , , instrumentation components'and systems were being conducted in accordance y with approvec; procedures and instructions. The inspectors evaluated these procedures and instructions to detennine if they were in conformance with , . license requirements. technical specifications, regulatory guides, ll licensee commitments..and, industry codes and standards conunitted to by the L licensee. The inspectors selected several systems and instruments for review; these included Remote Shutdown Monitoring, Core Protect 4cn Calculator System, Pressurizer Pressure, Reactor Coolant Temperature.
L Steam Generator Level and Pressure, and Condensate Storage Tank Level instruments. The procedures for these instruments were revie~ed and are ^ listed in Attachment 2.
The procedures were generally acceptable; however, some concerns were identified and are discussed below, f The inspectors reviewed completed records and verified that the required calibrations andfmaintenance were being scheduled and performed as required.' As ot October 5,1989, there were only 15 PMs that were past L - l-i ! ' .. .
y. Ky,- [ .y ff ~ '
, \\h 1 ' > - m ,
m s . . ,
- , f ( I'
- , l:. * ' p .= q, "u < - ..' .p ; ,l ,, e
, + , g(x _zg.
e> ' ' - n , t;.f c' '. &- -; ' { -12- ?
., , e . p+, - ;- -
, p
q n ' 'a , d.; '. 'due,'and'many 6f these~were the-result of the plant stat'us at the time ' . . < , 9 4b.
- they_were; scheduled.
No; concerns were identified with the scheduling and , '
performance of.PMs.
' ' t , , m, t . . . . ' j a.
Temperature' Monitoring Instruments 'e ' s. . _. . 4@ .. While reviewing the' Reactor-Coolant Temperature Instrumentation i ',~ Surveillance Test:(2304.118), the-inspectors noted that the only. , - n
- tests required for the temperature' sensors (Steps 7.10,-7.15, 7.20,
- ~ and 7.26 of Procedure 2304.118) were the measurement of the 'i resistance of each of the two elements in each instrument. The d , ., -resistances were then used to determine temperatures from the
a ' N calibration table in the procedure and the two temperatures were '
-compared:to determine the operability of the temperature element.
F eThe temperature of the. process being monitored was not determined.
P This determination was necessary to evaluate if the resistance ' readings were consistent with that required for the subject temperature.
' The inspectors reviewed additional procedures and noted.similar requirements'for other RTDs. The inspectors determined that the3 Technical Specification (TS) definition offa calibration requires that the sensing' elements (i.e;, the RTDs) be subjected to known-values such that an instrument channel can be adjusted (calibrated) , from the point.of measurement. This calibration would ensure that < the instrument channel would be within the prescribed range.and
- accuracy. requirements.and that an RTD drift did not occur. Since
- these~ proc _edures did not apply a known value.(temperature):to the
< -RTDs and. require the output of the RTDs to be. compared to that known ' , " value -it'did not appear'that the licensee was properly calibrating the RTDs. The inspectors discussed this concern with licensee personnel _during the first week. of onsite inspection.
. The inspectors asked I&C personnel if any isothermal cross-calibration 'of,the RTDs were performed and were informed by these personnel that they were not aware.of such a practice. The inspectors stated that s they considered this to be an important item that needed to be . resolved when the inspectors returned for the final week of the inspection.
! During the entrance meeting for the final week of the inspection, the 'importance of receiving information on the calibration of RTDs was again stressed. The licensee did not provide any information on this v ' - topic until the next to last day of the inspection. At this time, ' the licensee determined that a cross-calibration check was performed !' at isothermal conditions during startup testing after each refueling ! (# outage. The procedures for performing these cross-calibrations were f 1302.013, " Sequence for Physics Testing Following Refueling," and, M .2302.036, " Process Variable Intercomparison," for Units 1 and 2, respectively. These procedures were reviewed and found to be ' acceptable.
y ,- 1[ , '? s "l .},,1,- - _ .
pg QQ:g;Yy; e , %Q Q,;y~j; , , . ~
., - ii[ p. 3 ( , , , ' ;p - _ . .. i, .r: e \\ '
- C (
-13- ,9 -
. .
. Level T'ransmitter Replacement , b.
" During the first week of the onsite inspection, the inspectors
- -
, .. attempted to observe instrument maintenance / calibration in progress ~' but 'were hindered by a lack of an extended (5 day) schedule, which was , n .never made available.
' ,> - . The inspectors witnessed the replacement of a wide range steam-generator level transmitter (2LT-1079-1) that had been determined to.
be inoperable during its calibration. The licensee' replaced'the 4; ' lower.section (diaphragm) of the detector and the internal 'electrcnics (printed circuit boards) leaving the upper housing ' ' attached to the electrical conduit seal assembly (ECSA). The . licensee explained that this was done because of the difficulty of-Lremoving and' replacing the ECSA. The inspectors also examined the ' splice of'the ECSA leads to the ficid< cable with heat shrinkable tubing, which'was located in a junction box and found it to be s ~ ' acceptable.
< .,. .The removal and installation of the transmitter was performed under 'JobOrder(J0)798228 and the calibration under J0 789246. The inspectors verified.that all test equipment was in calibration and that the serial numbers were' logged on the J0 form for tracking purposes. The inspectors noted that the appropriate procedures were
followed.and had no questions.related to this activity.
During the review of' the Procedure 2304.119. " Pressurizer Level Instrumentation Surveillance,"' utilized for the above calibration.
R' the inspectors questioned the scaling factors used to convert the measured-differential pressure (DP)Linto an indicated water level. A l' review of additional level transmitter calibration procedures , disclosed a number of variations in.how the scaling formulae were . derived and used.
Factors which need to be accounted for in DP level ,: L measuring devices include the height of the water column and its l density, the effects of any vapor column weight on either column, and , any offsets in the elevation of'the instrument relative to the lower level tap. The inspectors discussed this concern with licensee personnel and verified that any level error resulting from present ? formulae would be of little significance (see the following paragraph i-foranexample).
In addition, the licensee showed the inspectors a J' new manual being developed for ANO. The inspectors reviewed the " Instrument Loop Error Analysis and Setpoint Methodology Manual" ' Revision A (Draft), and noted that Section 8.1 on level measurement
- >
provided clear guidance on how a scaling formula should be derived.
+ e s The inspectors.had no further questions on this subject.
, -c.
Reference Leg Addition g L i During the review of design changes being implemented on Unit 2, the inspectors noted that an additional reference leg was being added to the volume control tank. The licensee implemented DCP-85-2132 in E - ? 7.}. >
^ ~ g m ' l
- <
, , w v.
. m . . { cy ? &; ' # - -14-r , %
, ,
- '
< ~ 1/j _ ' order to provide separate: reference legs-for both level transmitters.
yAs, This would avoid having a: recurrence of past level indicating-mMp'roblemslwith the' two level indications because of a connon reference r - 11egt The-inspectors reviewed the DCP'and found it acceptable-but had ' a problem with the scaling 1 formula being' utilized _in' calibration . Procedure 2304.011. " Volume Control Tank Instrument Surveillance ,' Test'."' * 'i - ' > . , 'Theformulapresented'inthe'procidurAwasacknowledgedbylicensee "' personnel to only.be adequate for,the 100 percent or full tank' , conditione The correction factors which were' provided in the- , procedure weres:however, determined to produce acceptable results.
The licensee agreed to correct the formula error in the procedure and.
~ - ' thereby resolved the inspector's concern.- d.
Conclusions ,
- '
The inspectors experienced a number oftdelays in conducting their activities = because of an apparent lack of timely emphasis on;the ilicensee's part~for_ support to the NRC. This perception was based on the inability of the ANO. organization to ensure that the correct . personnel were involved in answering the inspectors' concerns and in providing information. The cooperation aspect was discussed with AP&L management and a definite improvement was noted-during the- .. o second. week of: onsite' inspection. - ' r The, inspectors also noted that there appeared to be'little F coordination between the various AP&L organizations.
This - observation was-based on the lack of I&C personnel knowledge of how the Technical Specification calibration requirements for RTDs were j implemented and how the scaling factors were derived. The inspectors were frequently required-to go f rom one contact to another in order to' receive a complete. answer to=a question.
No violations or deviations were identified.
, ' ' (25017) 6.
Heat Shrinkable Tubing - Units 1 and 2 The inspectors' evaluated the adequacy of the heat shrinkable tubing (HST) installed at'ANO.. The inspection was conducted in accordance with , Temporary Instruction 2500/17.
The evaluation consisted of the review of l
procedures and-installation records, and the physical examination of ' . existing selected HST installations. The inspectors also witnessed the installation of HST over six splices in Unit 2.
l The inspectors reviewed the applicable HST installation procedures listed in Attachment 2 and compared the instructions to the mcterial manufacturer . instructions. The inspectors found the splice range and length , application guides to be consistent with manufacturer requirements and the step-by-step instructions to be clear and easy to follow.
il L f' . I
y;
- p
- * -
, . .5 : .. ; , ., . .
- T-
. , , - , f .~ . ... . The inspectors performed physical examinations of the splices to ensure" . < ,that:' the tubing was-flully shrunk onto the electrical cable; sealing wos . ' assured by the appearance of a visible adhesive bead at'the ends of the
tubitig indicating that the adhesive-had melted and flowed; and the tubing- > Lexhibited a smooth and glossy appearance indicating the proper use of the cJ1 heat source to cause shrinkage. The inspectors ~.found all of-the existing
G installations lto meet the-procedural requirements and to be acceptable.
' < The installations in progress witnessed by the inspectors were also ~ '
, acceptable.
' < .- s . ' <- 3' :
. [, J' No. violatioris or deviations were identified.- ,
~ s7.
Exit Interview- (30703)- ' + , - " , s.
> . _ The inspectors' met with Mr. J. Vandergrift, Acting Director, Nuclear ! > Operations, and other members of the AP&L. staff identified in paragraph 1 /.i - - ' dt the end of the inspection. At this meeting, the inspectors suanarized . the scope and findings-of the inspection and discussed the consnitments-documented in paragraphs 2.a.(4), 2.b.(2), and'4.d. : The licensee ' s '* ' l acknowledged the inspection findings and agreed with the inspectors' statement Of the AP&L commitments. -The licensee did not identify as proprietary any of~the material provided to, or reviewed by, the inspectors during this inspection.
r i
s -,
^' . . . . . .
y - . l-( j,', ' - "' - 6 m,. . - . . , ..
L i v ' ATTACHMENT 1 q ' r
' LIST OF DRAWINGS REVIEWED < + , ,, , , DRAWING NO.; SHEETS REVISION TITLE ' , g . u ' ' i.- E-21923 1-3-5-1 RPS MG Sets Schematics 'f E-2193,4
4-1 Reactor Trip Schematic - r: E-2482 '
9-1 Computer Digital Inputs ' < , 'E-2693
2-1-RPS Connection Diagram ' ' *~ E-2703i
N-1 DSS Pressurizer Procedure g ., , ' Schematic-P E-2014.
4&5
-Interconnection Diagrams
M-2001 .M2-25 2-1 Reactor Trip Switchgear. . L' g" APL-199346-001' 1-18 N-1 Pressure Transmitter Details' _ APL-199346-002 1-3 N-1 DSS Schematics-APL-199380-001 N-1 DSS Functional Diagram o APL-199380-002 N-1 DSS Functional Diagram-APL-199380-003.
N-1: DSS Functional Diagram APL-199380-004 N-1 DSS Functional Digram - APL-199380-005-1-4 N-1 DSS Wiring Diagrams.
APL-199380-006 - N-1 DSS Power Distribution APL-199380-007 N-1 DSS Termination Cabinet APL-199380-008 N-1 DSS Equipment Arrangement -
! \\ > < . ,1.
f.[. e I l , ' , <, ; e
' - W
- q
, , ,, V.
9.,; , $m ..' ,, , p , , 7 ' ATTACHMENT 2 " , ,LISTOFPROCEDURESREV!EWF2
Station' Administrative Prof.edres '-1000.009.1"SurveillanceTestProgramControl," Revision 20,'datedJube 21, 1989 J ' 9;.- [ 1000.056, " Trending Program," Revision 1. June 25, 1988; , . -1025.006 " Equipment Dualification (EO) Maintenance Program,". Revision _15, > _ August 11, 1985 y . ,
L "'1025.007.."E0 listed Equipment's Approved Lubricants," Revision 3, August'6', ' , ,,1987: ' . " '1025.017 " Lubrication Changeout Procedure,", Revision 0, October-14, 1987~ , , Unit'2 Operating Procedures 2104.036, " Emergency' Diesel Generator Operations." Revision 29, October 13, ' ' 1989 .
2202.01.," Emergency Oeprations Procedures " Revision 6, June 29, 1989 ~ ~ - 2304.008, "RCP Speed Sensing' System Calibration," Revision-2, January 30,-1985 '
-2304.009. "VCT Lev'e1' Transmitter Reference Leg Verification," Revision 3, March 27, 1989 L2304.011 " Volume Control Tank Inst. Surveillance Test," Revision 10, ,
- March 27, 1989
, 2304.021, " Pressurizer Pressure Instrumentation Surveillance Test," Revision 9, December 5, 1987 , , 2304.041, " Plant Protection System Channel A Calibration," Revision 9.
. June 13. 1986 ' 2304.042, " Plant Protection System Channel 8 Calibration," Revision 9, May 1, 1986 - 2304.057, " Wide Range Steam Generator Level Instrumentation," Revision 0, May 13, 1989 2304.118, " Reactor Coolant Temperature Instrumentation Surveillance Test," Revision 8 July.18, 1986 g, 2304.119. " Pressurizer level Instrumentation Surveillance Test," Revision 12, ' July-9, 1989 2304.120, " Condensate Storage Tank Level Inst.," Revision 4, July 21, 1988 , , , . a .
- p.
y - - -
mx - m.
, , .,a, - , , ,,
- ,
,, , "gy ;,& ,, ' + . < .. . _L' ' , . l ..: D yi.
' y. y - , , ~.ig .j..
- s;
'4 y e .y ~
' "y- ,, . ., _ , ' ' 1* . . . .3 . . . ~ 2304.122, " Steam Generator. Level Instruments,": Revision 5. June 20,'1986 s . e is s , , . Y - - -
- +
. p , 2307.009,;" Pressurizer' Proportional Heater Checkout." Revision'4 June 3. -1988 , . i. . 2312.007, "CEAC 'to CPC,0ptical Isolator Surveillance Test " Revision 0,
- 4
.. .~ .. June 16. 1 86 , - Electrical Maintenance Procedures ' ' , 1307.013. "SequenceLfor Physics Testing.Following Refueling," Revision 10.- November 9 -1988
,
,. . 11403.008, " Unit 1 Containment Cooling Fan Inspection'and Repair,". Revision' 5b l ~ February 3,,1989
. i' ' 1403LO64;3" Unit l1!and II Cable End Cap Installation for "0" Listed Cable in ... 1, . Stores ur in Plant," Revision 6,' February 24, 1988-
, , ^ . ... . ' ]. a1403.,093; "Insta11a' tion of Raychem Kits,"' Revision 0, January 20, 1988 r> , N.
t;. ^i [E36;"ProcessVariable'Intercomparison," Revision _4,1 April 28,1958 - . - . e 2302 ' ' .;i u.
. . . ,. . . . c 7~~' A 2403.005,z"Contatnment Cooling Fans," Revision 5. July 27, 1988 . lL i ?;
. y - '.
.+. , , i ., v
' \\ . - m _ y ' g, o - h q,AT ' ' < > , I r f.
"s Q I1 c%. s . .% 6 :_
4
4 e }}