IR 05000313/1990010

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Insp Repts 50-313/90-10 & 50-368/90-10 on 900514-0601.No Violations or Deviations Noted.Major Areas Inspected: Licensee Engineering & Technical Support Capabilities Re Svc Water Sys
ML20055D168
Person / Time
Site: Arkansas Nuclear  Entergy icon.png
Issue date: 06/21/1990
From: Barnes I, Wagner P
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20055D167 List:
References
50-313-90-10, 50-368-90-10, NUDOCS 9007050075
Download: ML20055D168 (27)


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APPENDIX L i U.S. NUCLEAR REGULATORY COMMISSION I o REGION IV j

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NRC Inspection Report: 50-313/90-10 Operating Licenses: DPR-51 50-368/90-10 NPF-6 i

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F Dockets: 50-313  !

50-368 L - Licensee: Arkansas Nuclear One

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p.0. Box 551 Little Rock, Arkansas 72203 Facility Name: ArkansasNuclearOne(ANC), Units 1and2 Inspection At: ANO, Russellville, Arkansas - May 14 through 18, 1990

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NRC Region IV Offices - May 21 through 25, 1990, and

c ANO, Russellville, Arkansas - May 29 through June 1, 1990

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Inspectors: L. E11ershaw, Reactor Inspector, Region IV

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, L. Gilbert, Reactor Inspector, Region IV R. Haag, Resident Inspector, AN0*

SAIC Contractor Personnel: M. Ebert*

J. Haller*

m . * Inspection conducted during May 14 through 18, 1990, onl Lead-Inspector:

h.O.W %M P. C. Wagner, Rekttor Inspector, Plant fo/2l[9c Date

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Systems Section, Division of Reactor Safety

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- Approved:: wo ' bl/90

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l. Barnes, Chief Materials and Quality Date programs Section, Division of Reactor Safety Inspection Summary

_ Inspection Conducted May 14 through June 1,1990-(Report 50-313/90-10; 50-368/90-10)

Areas Inspected:. An announced inspection of the licensee's engineering and Tdchnical support capabilities related to the service water (SW) systems for ANO, Units 1 and 2. The inspectors evaluated the functional capability of the SW systems to determine if the existing systems would satisfy their design

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s requirements. The inspectors also reviewed historical SW system information to evalpate the adequacy of the licensee's operations, maintenance and technical support program Results: Within the areas inspected, no violations or deviations were identified. The inspectors identified a number of areas which will require followup inspection of the licensee's planned corrective actions. The i inspectors concluded that the proposed implementation of most of the new

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programs and of the corrective actions that require followup inspections are positive steps in improving plant safety at ANO. The inspectors were concerned, however, about the weaknesses identified regarding coordination L between the engineering organization and the other plant organizations. This concern was based on the slow implementation of recommendations from engineering

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to operations concerning procedure revisions (discussed in paragraph 3.2.2) and component testing (discussed in paragraph 3.2.4).

The inspectors noted several programs in the initial stages of implementation that are intended to currect the types of weaknesses identified in this and previous NRC inspections (in particular the Diagnostic Team inspection conducted from August 21 through September 15,1989). The inspectors concluded that, collectively, these improvement programs, if aggressively implemented, should result in strengthening the operation of ANO Units 1 and The programs reviewed by the inspectors included:

The Backlog Elimination Project, which should relieve some burden from plant engineering groups so that they can concentrate on current issues and problems;

The System Engineer Program, which if staffed by qualified personnel, should provide a more integrated and responsive approach to the resolution of developing issues; and,

The Service Water Integrity Plan (SWlP),.which should enhance service water system performance by correcting problems and providing improvements to installed components. (The inspectors noted that there are additional requirementswhichhavenotbeenincorporatedintotheSWIP[e,g, radiation monitorflushingprovisions.seeparagraph3.3.8)).

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DETAILS MRSONSCONTACTED AP&L t

C. Adams, Site Biologist D. Boyd, Nuclear Safety and Licensing Specialist

  • A. Cox, System Engineering, Manager, Unit 1 '

G. Dobbs, Supervisor, Electrical and Instrument and Controls (E&lC) Engineering :

  • B. Eaton, Manager, Design Engineering  !
  • R. Edington, Unit 2 Operations Manager '
  • E. Ewing, Jeneral Manager, Technical Support and Assessment i
  • R. French, Plant Manager, Unit 2 +
  • J.'Fisicaro, Manager, Licensing B. Greeson, Superintendent of Structural Analysis R. Howerton,' Manager, Engineering Support ,
  • H. Huff Supervisor, Design Engineering  ;
  • L. Humphrey, General Manager, Nuclear Quality
  • J. Jacks, Nuclear Safety and Licensing Specialist
  • G. Jones, General Manager - Engineering R. Jones,. Supervisor, Nuclear Chemistry i
  • R. King, Supervisor, Plant Licensing
  • J. Kowalewski, System Engineer
  • D. Mims, System Engineering Manager, Unit 2
  • T. Ott, Supervisor, Design Engineering C. Turk, Manager, Nuclear Engineering ,
  • J. Vandergrif t, plant Manager '- Unit 1

' A. Wrape, III. Electrical /l&C Engineering Design Manbger

  • J. Yelverton, Director, Nuclear Operations-NRC

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  • I. Barnes, Section Chief, Region IV
  • L. Callan, Director, Division of Reactor Saf ety, Region IV -
  • D. Garrison, Reactor Inspector, Region IV

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  • R. Haag, Resident inspector, ANO
  • R. Mullikin, Project Engineer, Region IV ,
  • C Warren, Senior Resident Inspector, ANO +
  • Indicates personnel who attended the exit interview conducted on June 1, 199 The inspectors also contacted and interviewed other AP&L operations and '

engineering personnel during the course of the inspection. Status meetings were conducted daily during the periods of onsite inspectio . BACKGROUND NRC has recognized ongoing problems with service water (SW) systems at a number of facilities. The types of problems that have been encountered in SW systems

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-4 have been communicated to all licensees. These generic comunications included: NRC Bulletin 81-03, which addressed flow blockage problems

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identified in 1980 at ANO caused by biological fouling; Generic Letter 89-13, which compiled previous industry information and recommended corrective actions; and Information Notice No. 90-26, which discussed inadequate SW flow to_ room coolers at another nuclear f acilit Specific concernr. with the SW systems at ANO, Units 1 and 2, were documented in aDiagnosticEvaluationTeam(DET)inspectionreportdatedDecember 21, 198 The'DET inspection, which was conducted during August and September 1989, evaluated overall plant operations and addressed a number of the licensee's programs and policies. During the DET evaluation of the licensee's design and engineering support capabilities, some general engineering program weaknesses were identified. The DET raised concerns about the functional capabilities of the SW systems as examples of weaknesses in the engineering progra AP&L had previously recognized that problems existed with the ANO SW systems and established a service water integrity plan (SWIP) in 1986. The SWIP

, provided the framework for the licensee's actions to verify the continued l operability of the SW systems and provided a schedule for improvement :

Because of the concerns over the functional capabilities of the SW systems at ANO, Units 1 and 2, the inspectors performed an in-depth evaluation of various i aspects of the systems. The evaluations included not only the specific issues >

raised in the DET inspection and NRC generic communications, but also the ANO design aspects of operational and maintenance information. The inspectors also evaluated the engineering support for ANO and some of the engineering program weaknesses identified by the DET. A listing of the documents that were reviewed is contained in the Attachment to this repor . SERVICEWATERSYSTEMSEVALUATIONS(92701)

The inspectors evaluated the SW systems to ensure that the design requirements would be met under normal and accident conditions. The inspectors reviewed .

pastoperationalandmaintenancehistories,designchangesandmodifications, SWIP comitments and schedules, and the licensee s actions taken in response to previous NRC inspection findings and generic correspondence related to SW

, systems. These inspection activities are discussed in the following l paragraphs.

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3.1 Generic Letter 89-13 By letter dated July 18, 1989, " Service Water S Safety-Related Equipment (Generic Lett~ #9-13)ystem

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" NRC requested Affecting all nuclear

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power plant licensees to commit to certain tests and evaluations of SW systems.

l Ap&L- discussed cM SW programs for ANO, Units 1 and 2. in response to the five recommendations conidned i 3eneric Letter (GL) 89-13, by letter dated l January 26, 1990. NRC acceptance of the Ap&L response was provided by letter dated May 2, 1990. NRC acceptance of the AP&L response contained one exception related to the control of aquatic life in the emergency cooling pond (ECP).

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!' . r The inspectors reviewed the actions taken and planned by AP& to fulfill the commitments made to the NRC and observed the followin .1.1 Biofoulina Control Recommendation I of GL 89-13 addressed the need to implement and maintain an ongoing program of surveillance and control to reduce significantly the incidence of flow blockage problems resulting from biofouling. Further, the GL stated that initial activities should be completed before plant startup following_the first refueling outage beginning 9 months or more after the date of the GL. AP&L stated that a biof ouling control program was established in response to prohlems identified at ANO in 1980. The program includes inspecting and cleaning the SW intake struttures each refueling outage, chlorination the SW systems to prevent biofouling, periodic flushing of normally stagnant portions of the SW systems, and verification of minimum flow to the safety-related heat exchangers cooled by SW. The inspectors were informed that the chlorination program was established to help prevent both microbiological induced corrosion and macrobiological fouling. 1he system chlorination is accomplished by adding gaseous chlorine at the SW intake structures. The program appeared to have been successful, as evidenced by the~

absence _of macrobiological foulin TheTechnicalSpecifications(TS)forbothunitsrequirethatchlorinationbe performed at least once every 14 days when the water temperature is between 60*F and 80'F. AP&L attempts to have centinuous chlorination (up to 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> per' day) of the SW system Procedure 1052.007, " Secondary Chemistry Monitoring," required chlorination analysis each shift when the system was operating continuously, or, once per week when not in continuous operatio Thedischargelimitswereestablishedas0.2partspermillion(PPM) total-

. residual chlorine at the discharge canal outlet for Unit 1, and 0.5 PPM free available chlorine at the cooling tower blowdown for Unit 2. The sampling frequency and discharge limits were consistent with those allowed by the National Pollution Discharge Elimination System (NPDES) Permit No f,R 0001392 l dated August 26, 1988. Review of the Service Water Continuous Chlorination l '

. Analysis Reports dating back to October 8,1989, revealed that when the system l was in continuous operation, an analysis was performed each shif t. There were times, however, when the system was not in operation, and this was denoted on

- the for e The inspectors also observed that Procedure 1104.13. " Unit 1 and Unit 2 Chlorination System Operation," required chlorination in the amount to achieve a'" desired" chlorine concentration of 0.3 PPM to 0.5 PPM in the SW system, and

, that the sampling frequency was to be once per shift. The records showed that sampling was being performed as required. The actual samples were being taken at the intermediate cooling water (ICW) heat exchangers in Unit 1, and at the component cooling water (CCW) heat exchanger in Unit 2. The measured amounts of free chlorine were sometimes greater or less than the " desired" limits. The ICW and CCW heat exchangers are at a location which is approximately equivalent to the midpoint of the SW system flow loops. It was also noted that the Updated Safety Analysis Reports (USARs) for both units listed an allowable limit of 0.1 PPM at the system discharge. While this is a more conservative l

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limit than either the TSs or NPDES permit, the inspectors questioned the  !

incensistency between the procedures, TSs, and USARs. The inspectors were i provided a copy of a licensing change request dated January 30, 1990, which resolved the inconsistencie Based on the apparent lack of macrobiological fouling in the SW system since initiation of the chlorination program, the inspectors determined that AP&L has '

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maintained adequate control over its implementation. One problem related to biofouling control is, however, discussed in paragraph 3. .1.2 System Testing

Recommendation 11 of GL 89-13 addressed the need for conducting an initial test program and a periodic retest program to verify the heat transfer capability of all safety-related heat exchangers cooled by an open-cycle SW system. The j initial tests should be completed before plant startup following the first i refueling outage beginning 9 months or more after the date of the GL, AP&L's response included a " heat transfer" method, a " thermal effectiveness" method, and a." periodic maintenance" method. AP&L also stated that in order to perform either the heat transfer or thermal effectiveness methods, additional l permanently installed and portable test instrumentation would be require AP&L committed to purchase and install all necessary instrumentation so that the thermal performance measurements would be completed for Unit 2 prior to restart after refueling outage 2R8, currently scheduled for spring 1991, and f or Unit 1, prior to restart af ter refueling outage IR10, currently scheduled

~for spring 199 The inspectors were informed that AP&L was planning to chemically clean and inspect the entire Unit 1 SW system during refueling outage IR9, currently scheduled for the fall 1990, except for the decay heat room coolers VUCIA, -B,.

-C, and -D. These coolers have galvanized tube sheets which preclude chemical L cleaning; instead,' they will be thermally tested. In addition to chemical I cleaning and inspection, the following coolers will also be thermally tested:

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makeup pump room coolers VUC7A, -B, and -C; reactor building coolers VCC2A, -B,

-C, and -D; decay heat removal heat exchangers E35A and -B; and emergency diesel generator coolers E20A1, -A2, -B1, and -B The inspectors reviewed the licensee's analyses which showed that the emergency switchgear room coolers and the high pressure injection (HPI) pump seal /cil coolers were not required for safe shutdown or accident responses. These analyses were considered to be thorough and provided adequate justification to support the conclusions. . The licensee's GL response originally stated that charging pump room coolers 2VUC-7A, -B, and -C would also not require testing;

=however, after further review, the licensee has determined that these coolers will require thermal performance testin The licensee's response to Recommendation 11 also designated certain other Unit 2 heat exchangers as not requiring testing. While these heat exchangers are part of the SW system boundary, no credit was taken for tneir heat transfer capacity in the reactor shutdown or accident analyses. The licensee, I >

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-7-therefore, reasoned that no thermal performance testing of those heat exchangers was require AP&L's response to the GL further stated that retest procedures would be developed based on the initial test program documents and results. The retest methodology will include periodic maintenance, heat transfer testing, and/or ,

thermal effectiveness testing of the appropriate heat exchangers and cooler .

The frequency of retest will be determined from the initial test dat .

3.1.3 System inspections and Evaluations  ;

Recommendation III of GL 39-13 addressed degradation control by establishing a '4 routine inspection and maintenance program for open-cycle SW system piping and components. AP&L's response discussed the periodic performance of r.ondestructive examinations, including ultrasonic examination mapping of pipe wall thickness, visual examination of a sample of heat exchangers and valves, and remote video camera inspections of the epoxy coating on the inside of the ECP return line. The licensee's actions in response to pipe wall thickness measurements are discussed in paragraph 3. As stated above, the NRC determined that additional action would be required to control the population of fish or other aquatic life in the ECP. The DET inspection identified that the design-basis documentation for the ECP was deficient because of the lack of provisiens for the control or monitoring of aquatic life in the ECP. Therefore, by letter dated May 2, 1990, the NRC recommended that AP&L evaluate the aquatic life population and determine long-term corrective actions to monitor and control the population of life in the ECP in order to meet the intent of Recommendation 111 of the GL full AP&L was requested to commit to a biological sampling procedure within 60 days of receipt of the NRC letter. As of this inspection, Ap&L had not yet responded; however, actions had been taken to address the issue, as discussed in paragraph 3. .1.4 As-Built Verification Recommendation IV of GL 89-13 addressed an as-built verification that should be completed before plant startup following the first refueling outage beginning 9 months or more after the date of the generic letter, to assure that the SW systems are in compliance with the licensing basis documentation. AP&L's response stated that the as-built configuration of the SW system would be verified by physical walkdown and that an analysis of single failure mechanisms would be completed to assure the as-built configurations were consistent with the appropriate single failure licensing basis. This effort will be completed priortorestartaftertheninthrefuelingoutageforUnit1(IR9)andthe eight refueling outage for Unit 2 (2R8).

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3.1.5' Procedures and Maintenance Recommendation V of GL 89-13 required a confirmation that maintenance

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practices, operating and emergency procedures, and training associated with the SW systems were a lquate to ensure that the systems would function as intende AP&L's response sw.ted that the required reviews would be completed prior to restart following the eighth refueling outage for Unit 2 (2R8) and the ninth refueling outage for Unit 1 (1R9). Any actions identified as being required as: !

a result of the reviews would be completed prior to restart following the tenth refueling outage for Unit 1 (1R10) and the ninth refueling outage for Unit 2(2R9).

The~ inspectors will follow the completion of the required reviews and other actions as required during the routine inspection of Generic Letter 89-13 implementatio .2 Previous Inspection Findings [

The inspectors reviewed each of the SW system concerns documented in the DET inspection report in order to evaluate the licensee's corrective actions. The-inspectors also reviewed other components that were related to the componente j

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of concern to the DET. The inspectors made the following observations during these reviews, 3.2.1 Service Water Structure Ventilation The DET determined that the ventilation system for the Unit 1 SW structure motors. The licensee's might not provide adequate cooling for the SW pump (LOOP) condition had assumed a

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cooling calculations for a loss of offsite power ,

natural convection flow through building openings. The openings, however, did not exist. The licensee took immediate corrective actions to provide the required openings as documented on Condition Report (CR) 1-89-45 The inspectors reviewed the project scoping report (PSR) which was initiated in 198T to evaluate the Unit 1 and Unit 2 SW structure's ventilation requirement The PSR was expanded in 1988 to include heating as well as cooling l considerations. Following the DET observations that the originally designed l' ventilation opening had not been provided, the scope of the PSR was again expanded. The inspectors found the PSR to be fragmented and to lack continuity -

L for the resolution of the issues. The inspectors did note, however, that the subject of heating and ventilation of the Unit 1 SW intake structure was included in the licensee's Service Water Integrity Plan (SWIP). The SWIP had a l -recommended design completion of 1990/1991 and construction completion in 199 The inspectors found the licensee's actions acceptable as an interim correction; permanent actions will be evaluated when completed, i InspectorFollowupItem(313/9010-01): Review long-term correction for Unit 1 l SW structure ventilation under a LOOP condition.

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. .2.2 Service Water System Operating Procedures The DET identified a number of shortcomings in the operating procedures for the SW systems. The shortcomings included inadequate instructions for limiting single failure vulnerabilities resulting from valve mispositioning, valve power supply problems and for ensuring motor manufacturer operating limitations were not exceeded. Some of the DET concerns were corrected during that inspection; the inspectors evaluated the status of the remaining concern The DET determined that the Unit 1 SW operating procedure (OP 1104.29) did not instruct the operators to ali auxiliary cooling water (ACW)gn the power system for the single to the electrical powerisolation valve source that to the was providing the motive power to the pump supplying ACW flow. The DET was concerned that a loss of' power of the electrical train not supplying the ACW system pump, when the power for the ACW isolation valve was improperly aligned, could result in a single failure situation. The inspectors reviewed Revision 33 of OP 1104.29 and noted that the required changes had been incorporate The DET also determined that the Unit 1 SW pump motor manufacturer's recomended starting restrictions were not included in the operating instructions. The inspectors questioned the status of this issue and reviewed an April 26, 1990, memorandum from AP&L Design Engineering to ANO Operations Standards. The memorandum recommended that limitations similar to those contained in the Unit 2 SW system operating procedure (OP 2104.29)be incorporated into the Unit 1 procedure. The inspectors were initially informed that the procedure would be revised prior to September 15, 1990. The licensee reconsidered the schedule and revised the procedure during the inspection period. The inspectors reviewed Revision 34 of OP 1104.29, dated May 23, 1990,

. and found it acceptabl .2.3 Service Water System Waterharmer Events 44 The DET reviewed a study performed by the licensee on previous Unit 2 SW waterhamer events and questioned the adequacy of the evaluation. The licensee committed to reassess the waterhamer phenomenon and to take any required

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The inspectors reviewed an evaluation performed by an AP&L contractor in May 1990. This scoping report concluded that the potential for significant j waterhamer existed in the SW system of both Units due to the large elevation !

differences in the systems. To determine the magnitude of the forces involved, 4 more detailed hydraulic modeling needed to be perfored. The licensee indicated that the resultant waterhamer forces will be calculated and compared to the forces generated by a design basis seismic event to verify that the SW system would remain operable. Should the waterhamer forces exceed the design seismic forces, the-licensee is comitted to implement necessary modification I These comitments are included in the SWIP. The inspec. tors found this approach to be appropriate, provided the physical condition of the SW system was adequately maintained. The inspectors reviewed portions of the licensee's SWIP

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to determine if sufficient monitoring of the system's mechanical strength needed to sustain a waterhammer event was required. The inspectors concluded that if the SWIP is carried out as delineated in the licensee's correspondence memorandum ANO-90-2-00397 dated April 11, 1990, sufficient monitoring would be achieved. A further discussion of the piping system integrity program is contained in paragraph 3. $ '- Followup Item (368/9010-01): Review the detailed hydraulic analysis and any necessary long-term corrective actions for SW system waterhammer event .2.4 Service Water Bay Level Instrumentation The DET raised concerns relative to the Unit 2 SW bay level instrumentatio The DET determined that the non-Class IE level instruments did not have the range to cover the levels that were likely to be experienced following an accident, in addition, the DET was concerned that the failure of the non-Class IE traveling screen system could result in a common mode f ailure of all three SW pumps. The inspectors discussed these concerns with licensee personnel and were informed that two engineering action requests (EARS) had been initiated to evaluate corrective action The inspectors noted that EAR 89-391 was initiated on September 12, 1989, to request the installation of ultrasonic level indication systems for the Unit 2 SW bays. The EAR stated that the SW bay level was not a parameter required to be monitored by Regulatory Guide 1.97, " Instrumentation for Light Water Cooled Huclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident." The inspectors were informed that the SW system pressure and valve position indications were the approved instrumentation for postaccident monitoring of the system. The inspectors discussed the status of the AP&L engineering review of the EAR and were inforw d that the evaluation was scheduled to begin in 2 or 3 months.

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The inspectors further discussed the advisability of having reliable and I

accurate indication of the SW bay levels available for early operator action should problems occur. The inspectors were informed that the licensee l considered it necessary to have a unique combination of events before the l existing Unit 2 SW bay level instruments would be inadequate. The events were a loss of offsite power resulting in a loss of air to the bubbler mechanism, a significant SW system flow demand, and a large population of fish being trapped on the intake screen j l'

The inspectors also reviewed the draft PSR for EAR 90-018 which was initiated to evaluate enhancements to the traveling screen differential pressure (dp)

alarm circuitry. The licensee was in the process of determining a better ,

method to alert the control room personnel of potential problems at the SW j bay The inspectors reviewed the operating procedures related to problems at the SW i bays - A0P 1203.12H for SW bay level alarm corrective actions and A0P 1203.25 for loss of the Dardanelle Reservoir corrective actions. The procedures

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O-11-directed the operators to take manual actions at various water levels in the SW ,

bays and included instructions to swap the SW pump suction to the emergency cooling pond (ECP) if the required level of SW pump submergence could not be maintained, i

The inspectors noted that new level instrumentation had been installed in each i of the Unit 1 SW bays during the previous refueling outage (IR8). The licensee had installed an ultrasonic level indicating system with local indication and control room alarm. The systems were neither Class 1E nor quality related but were powered from a reliable power supply. The inspectors reviewed the design change package (DCP B6-1006) and noted design engineering recommendations for system testing. The recommendations included a 6-month functional test and a refueling cycle calibration of the systems. The inspectors were informed that the need for calibration procedures had been recognized and was being tracked as part of Condition Report CR 1-88-394, and that the maintenance review of the DCP during final closecut would establish the requirements for the 6-month -

functional tes InspectorFollowupItem(313/9010-02;368/9010-02): The implementation of testing and calibration requirements for SW bay level instruments and the implementation of improved level instrumentation for Unit 2 SW bay levels requires followup inspection activit .2.5 Aquatic Life in the Emergency Cooling Pond (ECP)

The ECP is an alternate source of water for the SW system which can be used if the normal water supply is unavailable. Discussions with the SW system engineer and the supervisor of nuclear chemistry revealed that the ECP had not been used during normal plant shutdowns since approximately 1983 and that it >

had not been included in the water chemistry control program. The inspectors were informed that the ECP is only used when it is necessary to flush the ECP supply line prior to testing the SW syste The DET identified a potential for the ECP intake screens becoming clogged due to fish kills caused by elevated temperatures. This issue of aquatic life in the ECP was briefly discussed in paragraph 3. As a result of the concern identified by the DET, AP&L initiated Condition Report CR-C-89-090 dated August 25, 1989, which addressed the need to develop and implement a program to eradicate fish and plant life from the ECP. Special Work Plan No. 1409.180, " Eradication of Fish From the ANO Emergency Cooling Pond," was implemented on October 23, 1989, and resulted in the eradication of approximately 1600 pounds of fish. The special work plan is scheduled to be implemented again in August 1990, to provide the data necessary to evaluate how quickly.the ECP is being repopulated and to establish the frequency for periodically implementing the special work pla The inspectors found these actions to be acceptabl ,

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3.2.6 Unit 2 SW Pump Snap Ring Failures The DET noted that repeated failures of the impeller snap rings on the SW pumps had occurred. The snap rings transmit the thrust load from the pump impe11ers to the shaft. Failure of the rings had severely impacted pump performance and had resulted in the pumps being inoperable. The snap ring failures, which had been occurring since 1981, were not resolved by changes in the snap ring ,

material. After the failure of snap rings in two SW pumps in 1988, the licensee replaced the snap rings in all three SW pumps. The licensee also instituted a replacement schedule of 14 months to ensure that the snap rings would be replaced prior to a corrosion induced failur The inspectors reviewed the results of the snap ring re)lacement conducted in early 1990. While obvious corrosion of the snap rings 1ad occurred, it appeared that they were still capable of maintaining proper impeller orientation. .The inspectors reviewed the licensee's evaluation of the snap rings that had the most severe corrosion. The evaluation verified that adequate thrust loading capacity was available. The evaluation also included a discussion of the corrosion mechanism that caused the failures, a review of historical failures, the manufacturer's performance data and conservative assumptions involving operability requirements. The inspectors found the evaluation to be acceptabl The inspectors also reviewed the PSR which addressed operability and reliability problems associated with the Units 1 and 2 SW pumps. The PSR evaluated several long-term and repeated problems that had contributed to the poor performance of pumps. The PSR recomendations included replacing the l carbon steel snap rings with different retaining devices and changing the pump impeller material from bronze to stainless steel for improved wear resistanc The inspectors f ound these recommendations to be appropriate in addressing past SW pump problem . improved SW pump reliability was a recommended action item in the nonoutage portion of the SWIP. The licensee's interim action for the sna issue (i.e., the replacement of the snap rings every 14 months)p ring failure provided assurance of continued pump operability. However, these actions require significant maintenance resources while the completion of permanent repairs should allow a redirection of maintenance work to other needed areas.

l 3.2.7 Air Operated Valves (A0Vs)  !

The DET identified a problem with the design bases information for the containment cooler SW outlet valves (CW 3814 and CV 3815). The DET also found the licensee's actions in response to !!RC guidance contained in Generic Letter 88-14, " Instrument Air Supply System Problems Affecting Safety-Related Equipment," to be inadequat The inspectors reviewed PSR 90-1032, which addressed the operability and design

. concerns for the SW A0Vs. The PSR was written in response to Condition Report CR-1-89-0480, and was approved on liay 22, 1990. The PSR listed the following issues for review:

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L " Evaluate the basis behind thirty minute sustained closure testing per E procedure 1104.33 and corrective action requirements to resolve past failures to meet this thirty minute requiremen *

" Evaluate valve operability and maintenance concerns for CV-3814 and CV-3815 associated with their apparent failure to open against down stream pressure without first opening their respective upstream block valves.

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,- " Evaluate the lack of design basis documentation for the existing accumulators and their reserve air / stroke cycle capacity."

The inspectors noted that provisions for testing the leak tightness of the instrument air supply isolation valves had not been included in the recommended modifications. The inspectors discussed the existing and proposed configurations with licensee personnel and were informed that a contract to perform the actual engineering for the required modifications should be awarded in the near future. The inspectors' questions about the operability of these valves in their present configuration had been addressed in NRC Inspection Report 50-313/90-05; 50-368/90-0 ;

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The inspectors also verified that the SW system operating procedure (1104.29) !

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had been revised to have the cooler inlet valves normally opened to provide' J assurance that the outlet valves coulti be opened when required. The inspectors .

noted however that the piping and instrumentation diagram (P&lD-M-210

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Revision 76) still depicted these valves (CV3812 and CV3813) as normally close The inspect'o rs also questioned what actions were being taken by AP&L to ensure J that all A0Vs would properly perform their design safety functions. Th inspectors were informed that, in addition to the actions taken in response to Generic Letter 88-14, a new program, "The Engineering Improvement Program for Air Operated Valves,".had been added to the ANO Business Plan. This program contained the following three tasks: v

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- Define the population of safety-related A0Vs by February 1,1991; 1 .

m - *' Develop program documents, definition of scope of evaluations, and budget / schedule estimates by August 1, 1991; and

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Develop design basis evaluations and data bases assuring consistency with Design Configuration Documentation by December 31, 199 The completion of the above activities should provide assurance of the operability of the safety-related A0Vs and will be evaluated as part of the inspector followup to Generic Letter 88-14. The inspectors stated that the proposed schedule appeared to be quite long considering the potential for problems similar to those related to CY3814 and CV3815 existing on critical A0Vs. The appropriateness of the licensees priorities in assigning resources to this area will be reviewed as part of the ongoing NRC management assessment of the ANO integrated schedule included in the ANO Business Pla :

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-14-3.3 Additional Assessment In order to evaluate the status and functional capabilities of the SW systems more fully, the inspectors reviewed the licensee's improvement programs and performed additional functional evaluations. As mentioned earlier, the inspectors reviewed the licensee's Service Water Integrity Plan (SWIP) to evaluate its effects on system functionality. The inspectors also evaluated the following areas that were considered relevant to the SW systems ability to perform their safety function . Service Water Pump Motor Control Logic l The inspectort reviewed Condition Report CR-1-89-490 which cddresset the potential for two Unit 1 SW pumps motors being powered from one diosel generator. The resolution of this concern involved a revision tr Operating <

Procedure 1104.29 to remove the option to run all three SW pump motors simultaneously, except when changing the pumps in operation. Further, the automatic sequence starting timers for the two 5 seconds, while the third (or installed spare) primary pump pump timer wasmotors set at were set at 7 seconds.- The circuitry interlocks would thereby prevent the automatic starting of the third pump, provided both primary pumps had started upon initiation of the diesel generator's automatic loading sequences. The corrective action response indicated that similar sequence timing and interlocking were applied to the Unit 2 SW pump controls. The sequence starting timers for the Unit 2 primary pump motors were set for 4.5 seconds and the installed spare or swing pump motor timer was set for 6 second The inspectors concluded that the potential problem of the SW pump motors starting concurrently had been adequately resolve .3.2 Service Water Pump Motor Terminal Voltage The inspectors noted that Specification APL-E-2434 for large motors, which would included the SW pump motors, indicated that the motors were to be capable of starting and accelerating their loads at 80 percent of the rated terminal voltage. Based on this requirement, the inspectors questioned licensee personnel regarding potential degraded voltage conditions. The licensee personnel advised that, based on their calculations and the bus undervoltage relay settings, adequate SW pump motor starting terminal voltage (80 percent or better)wasassured. Further, the inspectors were informed that a study of i Unit 2 diesel generator performance indicated acceptable SW pump motor starting i terminal voltage. Licensee personnel also stated that a similar study was j planned in late 1990 for Unit 1. The inspectors found these actions to be l acceptabl .3.3 Service Water System Motor Operated Valve Terminal Voltage The inspectors noted that Specification APL-E-2103 for motor operated values (M0Vs)statedthatthemotoroperatorsshallhavesufficienttorqueto opea or close their valves with 80 percent terminal voltage. The inspectors were advised that a program had been initiated to demonstrate that the SW

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system MOVs would perform satisfactorily with 80 percent motor terminal voltage. Documentation related to the program included procedure 1409.56, Calculation 900-1044-01, and Calculation V-CV-2806-00. A tabulation of the involved SW system valves indicated that approximately 24 out of 89 valves had not, as yet, been teste In addition to the documentation discussed above, the inspectors reviewed Calculation 90E-0017-01 and Letter EIC-90-074 which addressed SW system MOV available terminal voltage under worst case conditions. The calculation analyzed voltage conditions for MOV CV-3643 and determined that the minimum .

-terminal voltage would be 415 volts (90 percent of nameplate rating). The licensee considered CV-3643 to be typical of the SW system discharge valves and concluded that the terminal voltage for the other MOVs would not deviate more than 3 percent from the calculated 415 volts or to 403 volts minimum. The inspectors found the results and methodology used in the reviewed documentation to be acceptabl The inspectors also reviewed the licensee's December 28, 1989, reply to Generic Letter 89-10. " Safety-Related Motor Operated Va?ve Testing and Surveillance."

The licensee's reply appeared to be responsive to the NRC concerns, but excluded " weir gate" operators from the scope of involved MOVs. The inspectors -

questioned if all of the 89 safety-related SW system MOVs would be included in the Generic Letter 89-10 testing program. The it.cpectors were informed that a final decision on which MOVs would be included would be made by the June 28, ,

1990,' commitment date. The inspectors were told, however, that the SW " sluice gate" operators were excluded from the Generic Letter 89-10 testing program in accordance with the ANO reply. The inspectors questioned that decision and .

were informed-that a similar position had been taken by the Babcock and Wilcox OwnersGroup(B&WOG)becauseofpastperformanceofthosetypesofoperator The inspectors reviewed a letter from the B&WOG tc the Nuclear Management and Resources Council (NUMARC) dated December 11, 1989. The letter was in support of the positions taken in the NUMARC letter to the NRC dated November 17, 198 The letter stated a position that:

"The failure history of dampers and weir valves has not been sufficient to warrant their inclusion into the scope of the GL as the NRC interpretations have indicated. These devices are not included in piping systems and should not be included simply because they have motor-operators."

The inspectors discussed the validity of the AP&L position to exclude the SW sluice gate operators in light of the failure history of those operators at ANO. The inspectors will follow the testing of MOVs and the sluice gate operators as followup to Generic Letter 89-10.

, The inspectors also evaluated the status of Inspector Followup item 368/8940-05, which documented the failure of a SW sluice gate to operate:

During the Unit 2 SW system flow test conducted in October 1989, as part of refueling outage 2R7, two lake side sluice gates for the SW intake structure failed to open. The failures were attributed to high loading of the motor

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-16-i operators during initial opening of the gate. Since a torque switch bypass had not been installed in either operator, the torque switch actuated due to the high initial loading and deenergized the motor. operator. Plant Change (PC) 89-0097 was developed to install a torque switch bypass in each of

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the three lake side sluice gate motor operatt<rs and the three emergency cooling pond side sluice gate motor operators. The PC was deferred from the original .;

outage schedule, and the work had not been rescheduled. Subsequently, licensee personnel informed the inspectors that the installation of the torque switch bypasses and additional maintenance items would be performed as maintenance resources were available. Based on the current status of the corrective ,

actions the inspectors determined that the licensee had not exhibited timely resolutIonforthisissue. Therefore, IFl 368/8940-05 will remain open pending t

completion of the PC for the sluice gate motor operator '

3.3.4 Protection Coordination The inspectors evaluated the electrical system protective devices related to SW system components in order to assess the coordination of the devices. The ;

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inspectors' review of Calculation 84E-0083-001, including coordination curves A111-1 A302-1, A303-1, A309-1 and B512-1, indicated that protection device coo-dination, using the results developed, would provide satisfactory protection for the 4160. volt and 480 volt systems Class 1E buses, conductors, and loads. Further, considering the time-current characteristics of the '

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various protective devices used, unnecessary interruption of unfaulted buses and loads would be minimized by the isolation of a short circuit or overloa The inspectors.noted, during a limited walkdown to observe protective device i settings and applications, that the overload elements used in some SW MOV reversing starters did not agree with those listed in Calculation 84E-0083-00 The licensee explained that the 84E calculation was amended by Calculation 89E-0100-01 which reflected the installed overload element Calculation 89E-0100-01 was performed to verify that the existing overload elements were adequate following the DET finding that a modification of the overload elements had not been fully implemented. The licensee stated that the overload elements specified by Calculation 84E-0083-001 would enhance the ,

protection of their loads and would be installed at a later dat The inspectors evaluated the actions AP&L had implemented to preclude a recurrence of problems with electrical protective devices. The inspectors reviewed Design Engineer Directive (DED) T-266 dated May 10, 1989. This DED established the position of Calculation Coordinator to ensure the proper implementation of protective devices, in addition, the inspectors were informed that AP&L had initiated a setpoint documentation package requirement for any setpoint change. The inspectors determined that the implementation of

'these programs should result in a documented basis for each setpoin .3.5 Pump Performance Requirements The inspectors reviewed the SW sections of the USAR for Unit 1 and Unit 2 orior to the inspection to gain an understanding of the systems. The inspectors noted that Section 9.3.2.1 of the Unit 1 USAR stated that the required

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submergence for the SW pumps was 3.9 feet. The USAR also stated that a submergence of 8.9 feet was available at the projected low inke level. The z inspectors also noted, however, that Figure 9-21 of the Unit 1 USAR indicated that the required net positive suction head (NPSH) for the SW pumps was approximately 13 feet when providing normal flows. The inspectors assumed that the NPSH curve reflected the actual feet of submergence required and asked licensee personnel to explain this apparent conflict during the entrance meeting conducted on May 14, 1990. The inspectors were concerned about the apparent disagreement in the information in the USAR and the apparent lack of verifiable information about the required NPS AP&L personnel investigated the information and contacted the pump manufacturer for additional details. During a telephone conversation on May 24, 1990, the inspectors were informed that Fairbanks-Morse Company (the pump manufacturer)

personnel had informed AP&L that the required NPSH for the Unit 1 SW pumps was 31 feet (absolute) when the flow was 6300 gpm, which was met essentially by zero submergence. Thus, the submergence requirement to avoid vortexing was the limiting condition. The appropriate pump performance curves were provided to AP&L and subsequently shared with the inspectors. The inspectors reviewed the information gathered by the licensee and found it acceptable in resolving the NPSH concern The inspectors also discussed the status of correcting and updating the Unit 1 USAR related to the SW system. The inspectors were informed that a USAR change package was in preparation and that the NPSH issue and other SW system issues would be clarifie i i

3.3.6 Service Water piping Degradation The licensee informed the inspectors that essentially all of the smaller (6 inches and less) diameter, carbon steel piping, had been replaced with stainless steel material because of corrosion product buildup and blockage problems. The inspectors reviewed the design changes that replaced the carbon steel SW piping with stainless steel material and verified that the design changes had been completed by reviewing the closeout tracking report. The inspectors also verified that the appropriate piping and instrument drawings (P&lDs) had been revised to incorporate the changed material designator in the piping line number In response to Generic Letter 89-13, the licensee had stated that periodic ultrasonic thickness mapping on SW piping was an ongoing program of the SWI The inspectors, therefore, reviewed the ongoing program for monitoring and trending pipe wall thinning and pitting in the SW system. The requirements for the performance of the examination and the analysis of the results had been incorporated into Procedure 1309.014. Since 1983, a total of 44 locations in the SW system piping of Units 1 ar 2 had been monitored for wall thinning and pitting. _ The system engineer for the SW systems had designated 12 of the 44 locations for continued trending by sampling the same location on c specific SW pipe at least every 3 years. The locations selected as trending samples included four locations on safety-related piping in Unit 1, six locations on l

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safety-related piping in Unit 2, and two locations on nonsafety-related pipin The acceptance criteria for minimum wall thickness specified in Procedure 1309.014 included a conservative 3-year corrosion allowance. The inspectors found the licensee's ongoing program for periodic ultrasonic thickness mapping of the SW piping systems to have been satisfactorily implemente . In-service Testing of Pumps and Valves

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The licensee's response to Generic Letter 89-13 stated that, " pump performance is measured in accordance with ASME Section XI in-service testing requirements for SW Pumps P4A, -B, -C, and 2P4A, -B, -C. Tests are performed in accordance with procedures on a quarterly basis and on a monthly basis, as appropriate."

In order to accurately measure the output flow of the SW pumps, the licensee installed flow measur kg equipment in the SW piping of both units and initiated in-service testing. The inspectors found the in-service testing (IST) of the pumps and valves in the SW system for both units to be consistent with the requirements of the ASME Code Section XI and the guidance provided in Generic Letter 89-04 for developing acceptable IST program The testing specified in Procedure 1092.32 for the Unit 1 SW pumps and valves ;

was performed at least quarterly and documented as required in Surveillance '

Procedure 1104.29. The testing specified in Procedure 1092.33 for the Unit 2 SW pumps was performed at least monthly while in service, and documented as required in Surveillance Procedure 2104.29. The monthly testing frequency for the Unit 2 SW pumps was changed to quarterly on March 26, 1990, based on the requirements.of the 1986 Edition of Section XI of the ASME Code that was used for the Second, 10-Year, IST Program. The inspectors reviewed 19 IST surveillance tests (8 for Unit I and 11 for Unit 2) completed during 1990 for the SW systems. Of the 19 surveillance tests performed, only one test for each unit resulted in the SW pump being declared inoperable. All other test results were acceptable. Based on this review, the inspectors determined that the IST surveillance testing was consistent with the-IST program requiren.ents spedied for each unit. The results of the surveillance tests were included in the IST trending report dated April 9, 1990. The inspectors identified no program or test deficiencies during the inspection, i 3.3.8 Service Water System Testing The inspectors reviewed the testing requirements for the SW systems of both- '

units. The normal flow testing was scheduled for refueling outage interval l The licensee conducted tests to determine the flow through each of the '

safety-related heat exchangers with the system aligned for postaccident conditions. The inspectors reviewed the test procedures for Unit 1 (1309.013)

and Unit 2(2311.002), the results from the tests performed during the last l

,.~ refueling outage of each unit (IR8 and 2R7), and the licensee's evaluation of {

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The inspectors also evaluated the status of Inspector Followup Item 368/9002-03, !

which documented exceeding the flow limits for a Unit 2 SW pump, while performing '

a SW system flow test in accordance with Procedure 2305.019, the 14,000 gpm e

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pump flow limit was exceeded. Table 9.2.-3, " Service Water Pump Data," in the Unit 2 USAR documented the pump runout flow rate as 14,000 gpm. During the test, the highest measured flow was 14,309 gpm. The licensee stated the 14,000 gpm limit was derived from a schedule for SW flow demands which tabulated 13,136 gpm as the high loop flow for the most limiting SW demand condition Basti on the certified pump test report which provided data that the pump adeqt.ately performed for flows up to 20,000 gpm, the licensee stated that the 14,003 gpm limit was not correc After further review, the licensee identified a mode of operation that could result in SW flows as high as 15,855 gpm for single loop flow and 29,637 for two loop flow. Condition Report CR-2-90-219 was written to address this issu While this higher flow rate was still within the acceptable pump flow capacity, the licensee noted that certain calculations, design. basis documents, and instrument setpoints must be revised to reflect the potential for a higher flow rate. The inspectors reviewed the CR evaluation of the higher SW flow rate effects on system operation. While the evaluation resolved the immediate issue of system operability, the additional items discussed above need to be addressed for final resolution of this issue. Therefore, IFl 368/9002-03 will remain open pending review of the licensee's revised flow calculations and the implementation of any necessary setpoint change The inspectors also reviewed the detailed evaluation written for the Unit 2 4 testing (" Service Water Flow Test Evaluation," Report 89R-2004-01). Any heat !

exchangers that were determined to have less than the flow assumed in the analysis were either cleaned and retested to verify the assumed flow or were justified as operable with less than the assumed flow. The licensee's evaluation contained corrections for ir.strument error and adjusted the flow rates for potential pump degradation, potential strainer plugging, and potential service water flow paths not included in the test, prior to determining the adequacy of flow for the upcoming fuel cycle. The inspectors considered the development of the formal test evaluation document for the Unit 2 tests to be a licensee strengt The licensee's response to Generic Letter 89-13 committed to the biweekly verification of minimum flow requirements for the reactor building coolers (VCC-2A, -2B, -20, and -2D) for Unit I and the containment coolers (2VCC-2A, -2B, -20, and -20) for Unit 2. The inspectors verified that

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the biweekly flow testing of the SW to the coolers was completed by reviewing l

the records of 16 surveillance procedures that were performed during 1990. The inspectors also reviewed the procedure for the 31 day test required by the TSs to demonstrate proper operation of each reactor building cooling unit. The inspector verified that the monthly tests had been performed by reviewing 19 completed surveillance test records. The inspectors identified to program or test deficiencies during the revie The inspectors also performed a limited review of licensee's calculations for the SW system heat loads during accident and normal shutdown conditions. No :

inadequacies were identified during the revie l

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-20-The Noticeinsp(ectors reviewed IN) No. 88-37 dated the Junelicensee's 14, 1988.response to NRC Information This IN addressed flow blockage of cooling water to safety system components due to biofouling. AP&L initiated Action Tracking Form, Reference No. OCNA068823 on June 29, 1988, which requested a review of IN 88-37 for applicability to ANO. A results report written on January 5, 1989, stated that biofouling could occur and not be detected due to stagnant water in portions of the system piping which are not routinely flushed or flow tested. The report determined that the supply and return lines to Unit 2 radiation monitors 2RE1453, -1456, -1525, -1519-1, and-1515-2 were not included in the routine flow testing or flushing program The report recommended that flow testing of those radiation monitors be

' incorporated into a revision of the flow test procedure. The report further stated that these actions, among others, should be added to the SWIP action plan for refueling outage 2R7. Subsequently, during 2R7, the monitors were flow tested and, while flow degradation was noted, the radiation monitors were considered to be operabl On April 25, 1990, a flow test performed on radiation monitor 2RE1525 found I that virtually zero flow was occurring on the upstream side of the monito The licensee initiated Condition Report CR-2-90-0203 on April 25, 1990. During implementation of corrective actions, a small flow was re-established by velocity flushing the line with demineralized water, and a 1/2-inch, live Asiatic clam was flusned out. Initial licensee evaluation indicated that the probable cause, based on SW system history, was the occlusion of the 3/4 inch ,

diameter carbon steci connecting nipple from the orifice flange on the SW header to the stainless steel radiation element piping. The occlusion was due to microbiological 1y induced corrosion involving iron and manganese bacteri These bacteria had been detected in SW samples taken during 2R7. AP&L's review of the Service Water Continuous Chlorination Analysis Reports revealed that the Unit 2 SW chlorination system had been isolated during a portion of the 1989 fall spawning season for Asiatic clams. Apparently the clam larva entered the system and became isolated in the monitor during the time the chlorination system was not operatin During this time, rapid occlusion occurred, such that when chlorination resumed, the clam larva was not subjected to chlorine and ras allowed to mature into an adult clam. While this was considered an isolated event, there were clearly generic implications. To verify that the radiation monitors were now included in the 6 month flushing program, the inspectors reviewed the current SWIP, dated April 3, 1990. The inspectors could not recognize this requirement in the SWIp, and requested assistance from the SW system engineer. The SW system engineer's review confirmed that, in spite of the fact that the monitors had twice been flushed on a 6 month schedule, there was no mention of this '

requirement in the SWIP. The inspectors did, however, verify that a requirement to measure the flow through the radiation monitors was included in the SW flow test, Procedure 2311.002, Revision Inspector Followu) Item (368/9010-04): Verify continued proper implementation of SW system flusiing activitie !

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4 DESIGN AND ENGINEERING SUPPORT (3770M Since many of the issues and concerns related to the SW systems had involved the engineering and design engineering functions, and since the DET had raised a number of engineering support concerns, the inspectors performed some general assessments in this functional are s

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4.1 Design Information Availability The inspectors were provided a significant amount of design information related to the inspection of the SW systems. The majority of the information was provided in a timely manner and the involved personnel appeared to be knowledgeable of the content. There were, however, a couple of instances in which the design information could not be readily retrieved or was not correc ihe apparent difficulty in verifying the NPSH requirements for the SW pumps was discussed in paragraph 3.3.2; the problem with the originally provided information on electrical coordination was discussed in paragraph 3.3.1. The inspectors were informed that the completion of ongoing programs to restructure the design bases documents (Design Configuration Document Program) together with ongoing programs to verify the as-built configurations, sheuld correct the types of problems encountere .2 . System Engineer Program The inspectors were assisted during the inspection of the SW systems by the assigned AP&L system engineer. The SW system engineer was very knowledgeab'e of the SW systems' history, status, and proposed improvements. This knowledge and the ability to promptly provide requested information enabled the inspectors to complete a significant evaluation effor The inspectors, therefore, evaluatea the impicmentation of the system engineer program. The inspectors were informed that a restructuring was presently underway to reestablish a system engineer organization. The proposed '

organization would have a System Engineer Manager for each Unit with four -

Supervising Engineers reporting to each Manager. The organization would include 30 persons per Unit. The Managers for System Engineering hase been appointed and met with the inspectors to discuss the program statu The licensee is scheduled to have the system engineer organization "in-place" by October 1990. In addition to the manager for each Unit, 34 engineers who will serve as systems engineers had been selected. These 34 engineers had been assigned to AHO as plant engineers or reactor engineers. The inspectors were informed that training requirements for system engineer positions were being developed. The inspectors discussed the advantages of having qualified system engineers and recommended that the licensee continue with the implementation of the program which should prove to be a strength for the facilit .3 Backlog Elimination Project A significant backlog of engineering work exists at ANO. This problem was recognized by the DET and by the licensee. In an effort to relieve the s

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backlog, AP&L established an Engineering Backlog Elimination Project. The stated objective of the Project was to: " Reduce the engineering backlog to a manageable level by dispositioning items systematically connensurate with their safety significance." The Project goals are the resolution of 50 percent of all old items within one year, with the remaining 50 percent resolved within three years. Monthly goals have been established to schedule the completion of the approximately 1,900 backlog items by May 1993.

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The inspectors reviewed the Project Plan and discussed the Project with involved licensee personnel. Briefly stated, the Project Plan calls for the backlog items to be evaluated for safety significance and operability as an initial screening; duplicated or unnecessary items will be closed without action and the remainder will then be classified and prioritized. The inspectors were informed that the Project was staffed by four experienced AP&L engineers with assistance provided by an 18 person contracted engineering grou The inspectors found the Engineering Backlog Elimination Project to be a well conceived and much needed program. The implementation of the Project should

. relieve:some burden on the other AP&L engineering groups so that more time can be devoted to present-time issue The inspectors also reviewed the status of the backlog of Condition Reports (CRs). The existing condition reporting system was implemented in May 1988, in response to weaknesses identified in the earlier programs. NRC Inspection Report 50-313/89-17; 50-368/89-17, documented the implementation of the present systems as of April 1989. The inspectors reviewed a tabulation of the CRs that were opened, dispositioned, and closed, on a monthly basis since the system was implemented. The number of CRs opened showed a significant increase during refueling outage periods, as would be expected. The increase in the number of CRs closed usually lagged the increase in those opened, which s:ould also be expected. . The inspectors noted that a total of 2799 CRs had been written with a total of 780 remaining open. The inspectors also noted that the average number of CRs remaining open had been essentially constant over the past 12 months, but had been over 900 during the time of the DET inspectio While the total of 780 open CRs for a two Unit site may be larger than desirable, the inspectors did not find this workload to be unmanageable. The inspectors were informed that actions were planned to also reduce the number of

- open CRs. This further reduction in backlog should also improve engineering efficienc . EXIT INTERVIEW (30703)

The-inspectors met with Mr. J. Yelverton and other members of the AP&L staff identified in paragraph 1 at the conclusion of the inspection. At this meeting, the inspectors summarized the scope and findings of the inspectio The licensee did not identify as proprietary any of the material provided to, or reviewed by, the inspectors during this inspectio ,

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ATTACHMENT List of Documents Reviewed I- ' Procedures:

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y Number Revision Subject 1052.002, 17_ Chemistry and Environmental Administrative Procedure 1052.007 11 Secondary Chemistry Monitoring N 1092.032- 1 ASME Code Section XI Inservice Testing Program,, '

Unit I t-

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1092.033- 'l ASME Code Section XI Inservice Testing Program, Unit 2 1104.13 9' Unit I and Unit 2 Chlorination System Operation-liO4.29 33 and 34 SW System Operation 1104.33, 40 Reactor Building Ventilation 1203.12H 24 Annunciator K09 Corrective Actions 1203.25-~ 9- Natural Emergencies - Loss of Dardanelle Reservoir 1306.019 '2 Emergency Cooling Pond Sounding 1309.13 1- SW Flow Test 1309.014 1 Service Water Piping Thickness Evaluation t 1406.57 1 Corrective Actions for Excessive Sluice Gate-Leakage in a DBA Situation 1409.56- 3 MOV IEB 85-03 Program 1409.110, -0 SWP for-SW Bay Level Indicator-1409.180 0 Eradiction of Fish From the ANO Emegency Cooling Pond 1413.05: 0 SW Discharge Header Pressure Calibration 1413.93 0 Unit 1 Reactor Building Cooling Units SW Flow Indication Calibration 1618.029- 1 Sampling Unit 1 Service Water i j

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2104.29 32- SW System Operation 2104.33 26 Containment Cooling Fan & Containment Cooler 14 Day Test 2305.05 11 Containment Isolation & Mist. Yalves Stroke Test

& Position Verification 2305.19~ 2 SW Pumps Flow Test

'2311.02 6 SW Flow Test

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r Drawings ES 14 Single Line Meter & Relay Diagram, 4160 Volt System, Eng'd Safeg'd E Single Line Meter & Relay Diagram, 480 Volt Load '

Centers, Engineered Safeguard & Main Supply ,

EIS 34 Single Line Diagram, 480 Volt Motor Control Centers B51 & BS2 E16= 34 Single Line Diagram, 480 Volt Motor Control Centers B55'8 B56 E18 46 Single Line Diagram, 480 Volt Motor Control Centers B61 & B62 E-76-1 9 4160 Volt Circuit Breaker Schematic  ;

E-76-2 7- 4160 Volt Circuit Brcaker Schematic E-275 17 P1 SW Pumps A & C Schematic E-275-2 N-1 SW Bay Level Annunciator Schematic

.E-276-1 20 SW Pump B Schematic-E-276-2 1. T1 SW Pump B Disconnect Switch Schematic E-276-3 0. T1 SW Pump B Disconnect Switch Schematic

'E-277- 4 SW-Pumps A & C Discharge MOVs Schematic

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E-278 4 SW Pump B Discharge MOV Schematic E-279-1 10 SW Pumps Crossover MOVs Schematic

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a E-270-2- ;3 .SW Pumps Crossover MOVs Schematic

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E-2005 141 Single Line Meter'&' Relay' Diagram,:4160 Volt '

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System Eng'd Safety Features'

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E-2008 16 Single Line Meter & Relay Diagram 480 Volt Load

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Centers, Engineered Safety features & Main

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~FSK-M-1009 1 Service Water Composite - Unit: FSK-M-4005-1 3 Service Water Composite;- Unit 6

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FSK-M-4005-2- 10- Service Water Compo' site -_ Unit 2 M-209-1 59 Unit 1 Intake Structure Equipment M-209-2- li Unit 1 Intake Structure Equipment  !

-M-210 .76 . U ni t '. lirl P&lD

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J M-2210-1 55 Unit 2 SW P&ID M-2210 -2 55' b it 2 SW P&ID 1 M-2210-3 52 Unit 2 SW P&lD

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therDocuments ,

A111-1, Reve 0 Att014.16KV BKR. Alli Phase Relays +j A302-1, Rev. 01 Atl014.16KV Motor SW PP4A Phase Relays

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A303-1, Rev. Atl014.16KV Motor SW PP4B Phase Relays j

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A309-1,: Rev. 0 AN014.16KV Bkr. A309 Phase Relays  !

P, -B512-1, Rev. AN01 480V Load Center B5 bl ,

TM"S590X.0010 Technical Manual for STI controls Ultrasonic cw Level Monitor '

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-hN0-89-04907 Service Water Integrity Plan, dated May 12, 1989 ANO-90-05038 Inservice Testing Trending, dated April 9, 1990

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AN0-90-2-00397 Service Water Integrity Program Description, I dated April 11. 1990 i

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< AP&L Contract Log L-020G Recommendations for the Service Water Systems APL-E-2103, Rev. 2 Technical Specifications for Valve Motor Operators for the Arkan.as Nuclear _One Plant, e Units 1 & 2

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[APL-E-2434 Rev. O Technical Specification for Large Alternating Current Motors, 250 Horsepower and Larger for the Arkansas Power and Light Company, Arkansas--

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Nuclear One, Units 1 & 2 855-0002-01 ANO-2 DG Loading. Calculation, dated November 11 ,

P. ' -1989 e 87E-0056-01 -ECP Heat Load Evaluation, dated December 23, 1986 89RL2004-01, Rev. 1 Engineer _ing Report - Service Water Flow Test '

Evaluation ICAN108809 AP&L Resubmittal of the Second 10-Year Inservice Testing Program for Unit 1, dated October 20, 1988 1CANO39006 AP&L 1990, Evaluation of Reactor Building' _ _ !

+1 Coolers-Service Water Isolation Valve for: Unit 1,- !

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dated March 2 <

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ICAN10890 AP&L Response to Generic Letter 89-04, dated j

, October 27, 1989 '

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'2CAN019005 AP&L Second 10-Year Inservice Testing Program o > Submittal for Unit 2, dated January 12, 1990'

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. l56600-H-101B- Specification for Shop Fabricated Carbon and' 4 Rev.'l Austenitic Stainless Steel Piping for  !

Conventional Steam and Service Piping for Arkansas Power & Light Company, Arkansas 4 Huclear One

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t '84E-0083-001, Rev. 3 General Criteria for Safety Buses, Plant ProtectionStudy--(Unit 1)

, 900-1044-01, Rev. O MOV Sizing Calculations for Valve CV 3820 NN' ' '

90E-0017-01,.Rev. 0 CV 3643 Starting Terminal Voltage Under Worst Case Conditions

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V-CV-2806-00, Rev. 2 -Minimum and Maximum HOV Thrust / Torque Data, HF CV-2806 o

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Arkansas Nuclear One " Unit II ASME Section XI Pump and Valve Test Program Upgrade to the 1986 Code Edition," Revision 0

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- .DCPs Completed During 1R8
y / DCP 86-1009, " Install Flow Spools in SW System to Measure Flow Rate to Decay Heat Removal Heat Exchangers"

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DCP 87-1013, " Replace Certain Piping and Valves in SW System with Stainless  !

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Steel .

DCP 87-1014. " Replace Certain Piping and Valves in SW System with Stainless-  !

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DCP 87-1016, " Replace Lube Oil Coolers for Primary Hakeup Pumps with Stainless Steel Coolers"

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'DCP 88-1031, " Modify SW Hanger HBD-14-H11" DCP 87-1042, " Install Flange Pair to SW Discharge Nozzle at the Emergercy Cooling Pond"

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DCPs Completed During 2R7 c DCP 86-D-2051, " Modify 4 SW Hangers"

' DCP 86-2110A, " Replace certain Piping and Valves in SW System with Stainless '=

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Steel and Modify Flow Orifice 2FO-1504 for Measuring Flow to/from Emergency i

_ Diesel Generator Jacket Cooling Heat Exchanger" DCP.'88-2105, " Install Flow Measurement Instrumentation to SW Supply Header #2" DCP 88-2066, " Modification to Motor Operator on 14 SW Valves"

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' DCP 88-2092, " Replace 12 Carbon Steel Valves in SW System with Stainless Steel l

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Valves" ,

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DCP 89-2021, " Change the Spring Pack in the Motor Operator on SW Supply Valve 2CV-0711-1 for Emergency Feedwater Pump 2P-7A" DCP 89-6001, " Modification to Motor Operator on 4 SW Valves"

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