ML19210E588
| ML19210E588 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 10/23/1979 |
| From: | Johnson W, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19210E582 | List: |
| References | |
| 50-313-79-21, 50-368-79-20, NUDOCS 7912050342 | |
| Download: ML19210E588 (11) | |
See also: IR 05000313/1979021
Text
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U. S. NUCLEAR REGULATORY C0miISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Report Nos. 50-313/79-21
50-368/79-20
Docket No.
50-313
License No. DPR-51
50-368
License No. NPF-6
Licensee: Arkansas Power and Light Company
P. O. Box 551
Little Rock, Arkansas
72203
Facility Name: Arkansas Nuclear One (ANd , Units 1 and 2
Inspection At: ANO Site, Russellville, Arkansas
Inspection Conducted: September 9 - October 5,1979
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Inspector:
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5T. D. Johnson, Resident Reactor Insp' ctor
Date
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Approved B :
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T. F. Westerman, Chief, Reactor Projects Section
Date
Inspection Summary
Inspection conducted during period of September 9 - October 5,1979
(Report No. 50-313/79-21)
Areas Inspected: Routine, announced inspection of the QA/QC Administrative
Program, licensee actions taken in response to IEB 79-04, licensee actions
taken in response to IEB 79-14, licensee actions taken in response to IEB 79-05C,
and follow-up on open items. The inspection involved 56 inspector-hours on-site
by the NRC resident inspector.
Results: Within the five areas inspected, one item of noncompliance was
identified.
(Deficiency - outdated Q-Lists, paragraph 3)
Inspection conducted during period of September 9 - October 5,1979
(Report No. 50-368/79-20).
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Areas Inspected: Routine, announced inspection of the QA/QC Administrative
Program, licensee actions taken in response to IEB 79-04, licensee actions
taken in response to IEB 79-14, and testing associated with investigating the
hot leg temperature anomaly. The inspection involved 33 inspector-hours on-site
by the NRC resident inspector.
Results: Within the four areas inspected, no items of noncompliance were
identified.
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DETAILS
1.
Persons Contacted
a.
AP&L Personnel
J. P. O'Hanlon, ANO General Manager
G. H. Miller, Engineering & Technical Support Manager
B. A. Baker, Operations Superintendent
T. N. Cogburn, Nuclear Eagineer
E. C. Ewing, Production Startup Supervisor
B. A. Terwilliger, Operations and Maintenance Manager
M. Stroud, Electrical Maintenance Supervisor
J. McWilliams, Assistant. Operations Superintendent
J. Vandergrift, Training Supervisor
T. Green, Training Coordinator
D. Trimble, Licensing Manager
C. Shively, Plant Performance Engineer
R. Lane, Manager, Mechanical Engineering
M. Clary, Production Engineer
L. Humphry, Manager, QA
R. Bata, QA Engineer
J. Anderson, Acting QC Supervisor
D. Snellings, Technical Analysis Superintendent
B. Ideker, Licensing Engineer
b.
Bechtel Personnel
R. Redford, Resident Engineer
C. Beardsley, Lead Mechanical Engineer
R. Jurcik, Assistant Field Engineer
R. Cameron, Field Project Engineer
The inspector also contacted other plant personnel, including operators,
technicians and administrative personnel.
2.
Inspector Follow-up on Previously Identified Items (Unit 1)
(Closed) Open Item 313/79-09-05 (Inspection Report 79-09):
Emergency
The licensee has installed and tested flow indicators for the EFW system.
Other modifications to the EFW system will be reviewed as a part of the
follow-up to IEB 79-05 long-term action items.
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(Closed) Open Item 313/79-10-05 (Inspection Report 79-10): P7B discharge
line support inoperable.
The licensee ~nas repaired this pipe support.
(Closed) Open Item 313/79-10-03 (Inspection Report 79-10): Yellow and
magenta tape on floor around the emergency feedwater pumps.
The tape in question has been removed.
3.
QA/QC Administration Program (Unit 1 and 2)
a.
Q-List
Section 2.6 of the licensee's Quality Assurance Manual for Operations
identifies the Q-List as a design document which specifically identi-
fies those systems, structures and components whose failure could
cause of uncontrolled release of radioactivity, or those essential
for safe shutdown and the immediate and long-term operation following
a Loss of Coolant Accident. The Q-List provides for applicatio.1 of QA
Program requirement to specific systems, structures and componeats.
The AP&L procedure which controls changes to the Q-List is GCP-300
" Nuclear Licensing Document Control." Revision 0 of this oroe ;ure
was issued on June 8, 1979. The distribution and control aspects of
this procedure with respect to the Unit 1 Q-List have not yet been
fully implemented. The latest revision to the Unit 1 Q-List is
Amendment 15 of February 1979. The inspector examined the Unit 1
Q-Lists held by three AP&L staff members on site. The revisions held
are listed below:
(1) Revision 8 of December 1974
(2) Revision 11 of February 1978
(3) Undated version, possible original
Section 4.4.7.2 of GCP 300 requires that each designated person having
a copy of the Q-List shall ensure that his Q-List is kept up to date
with all amendments. This is an apparent item of noncompliance.
(313/79-21-01)
b.
QA Procedures
AP&L procedure QAA-10 " Control of AP&L QA Manuals" is the established
administrative control procedure for QA procedures.
It provides
for review and approval of procedures prior to implementation;
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methods and procedures for procedure revisions; and methods and
controls for distribution of procedures.
c.
QC Procedures
QCP 1004.21 " Handling of Procedures" and QCP 1004.22 " Document
Control" are the established administrative control procedures for
QC procedures. QCP 1004.21 provides for review and approval of
~ rocedures prior to implementation and methods and procedures for
procedure revisions. QCP 1004.22 provides methods and controls
for distribution of procedures.
d.
Overall Review of QA Program Effectiveness
Section 2.8 of the licensee's Quality Assurance Manual for Operations
assigns responsibility to the Manager of Quality Assurance for an
annual review of the QA Program to detenmine the effectiveness and
proper implementation of the program. The licensee has been perform-
ing this function by means of a QA Manager review of the annual
Quality Assurance General' Audit (AN0-14).
Following discussions
during a recent NRC Performance Appraisal Team inspection, the QA
Hanager is developing additional means of performing this function.
This new system; when developed, should enable the licensee to better
identify areas which need improvement and to provide increased
emphasis in those areas.
(0 pen Item 313/79-21-02; 368/79-20-01)
4.
Follow-up on IE Bulletin 79-04 (Units 1 & 2)
IE Bulletin 79-04, entitled " Incorrect Weights for Swing Check Valves
Manufactured by Velan Engineering Corporation" was issued on March 30,
1979. The licensee's response to this bulletin was dated April 27, 1979.
Thi' response indicated that conservative valve weights were used in
the piping analysis for all Seimic Category I piping systems in which
3 or 4 inch Velan swing check valves are installed. The inspector
reviewed this response and had no further questions on this matter.
5.
Follow-up on IE Bullatin 79-14 (Unit 1)
IEB 79-14 was issued on July 2, 1979, revised on July 18, 1979 and supple-
mented on August 35, 1979. This bulletin is entitled, " Seismic Stress
Analysis for As-Built Safety-Related Piping Systems," and requested that
licensees take certain actions to verify that seismic analysis are applica-
ble to as-built plants. During this inspection period the inspector
reviewed the licensee's activities with respect to this bulletin.
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a.
Development of Inspection Elements
The inspector reviewed the organization and the qualifications of the
persons who developed the inspection elements to in used in
verifying that the seismic analysis input infora tion conforms to
the actual configuration of safety-related systems. Work Plan M . 86
was developed by the licensee and its contractor to control the
field inspection required by the Bulletin. The inspector reviewed
the Work Plan and interviewed several persons who provided input to
the development of the Work Plan.
The Work Plan appeared to be
adequate for its intended function. The licensee's response to item 1
of the Bulletin was dated 8/1/79.
The inspector also reviewed the documentation of the licensee's
inspection of the piping and hangers associated with isometic drawing
17-MU-25.
The inspection appeared to have been performed in
accordance with the requirements of the Work Plan.
b.
Inspection of Accessible and Norinally Inaccessible Piping
During a previous inspection, the inspector observed in part the
licensee's physical inspection of piping systems in both accessible
areas and in normally inaccessible areas. The licensee's letter of
August 13, 1979 reported the completion of the required inspections and
provided a schedule for completion of the detailed review and analysis
of the inspection data. The inspector independently inspected the
piping and hangers associated with isometric drawing 17-MU-25 and
compared his findings to those of the licensee. The inspector
found that one hanger (MU-222) had a nut missing. The licensee
initiated action to have the nut replaced. The inspector's other
observations compared favorably with those of the licensee's
inspection team, but the inspector found that not all of the licensee
inspection team's findings had been transferred to the fabrication
isometric drawing and forwarded to the stress engineers for analysis.
The line segment inspected has attachments including one inch sensing
lines from two flow elements which were not shown on che fabrication
isometric. The configuration of these attachments was promptly
forwarded to the contractor's stress engineers for analysis after
the inspector pointed out the discrepancy.
In order to determine
whether this was a common problem or an isolated instance, the
licensee's Manager of Engineering and Technical Support agreed to have
a representative sample of inspection packages reviewed again. This
review would include the following elements:
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Whether any pipe supports were described as inaccessible and
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were not inspected.
Comparison of narked up field copy of the isometric with the
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revised sepia forwarded to the stress engineers.
Review of piping and instrumentation drawings to assure that all
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attachments were noted on the fabrict. tion isometric.
In addition, the final revised drawings are to be rei.urned to the
site for review against the marked up field copy of the isometric.
This item is considered unresolved pending the inspector's review of
the above actions.
(313/79-21-03)
c.
Nonconformance Evaluations
The licensee's letter of September 14, 1979 provided, for accessible
systems, a list of isometrics in which all nonconformances were found
to be within established tolerances or were judged to be acceptable
by the initial engineering evaluation. This letter also provided a
list of isometrics for accessible systems where nonconformances were
found to be out,of established tolerances but were judged to be
acceptable by the initial engineering evaluation.
This group of
isometrics will require additional analysis, the re::ults of which are
to be provided by the licensee by October 12, 1979.
Similar submittals
for inaccessible piping are to be made by the licensee by November 12,
1979 and December 13, 1979.
d.
Correction of Nonconformances
The licensee's letter of August 31, 1979 reported that required
corrective actior. had been taken on all nonconformances judged to
affect system operability in the initial engineering evaluations.
This submittal included a listing of the required corrective action
on such nonconformances.
e.
Improvement of yuality Assurance
The licensee provided a schedule for updating stress isometrics in his
letter of August 31, 1979. This drawing revision effort is scheduled
to be complete by November 12, 1979. The licensee issued a new
procedure on July 12, 1979 to control the design change process.
This procedure, entitled " Design Process Procedure" is procedure
number 202 of the Generation and Construction Department Procedures.
This procedure contains steps which should assure that future modifi-
cations of piping systems and their supports will be reflected in a
C nely manner in design documents and the seismic analysis. This
procedure covers design change activities performed at the general
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office, but not those performed by the engineering staff on site.
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A similar procedure, covering on-site activities was in the review
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process at the time of this inspection.
(0 pen item 313/79-21-04;
368/79-20-02)
The inspector will complete his review of the licensee's activities
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in response to IEB 79-14 during a future inspection. No items
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of noncompliance or deviations were identified.
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6.
Follow-up on IE Bulletin 79-l4 (Unit 2)
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The licensee's response to this hulletin for Unit 2 was dated August 1,
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1979. This response outlined field control and verification measures
which were used for Unit 2 during the construction and startup phases and
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stated that these measures assure that the as-built configurations of all
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safety-related piping have valid and up-to-date seismic analysis.
Based
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on the informa, ion provided in this letter, the licensee proposed to
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perform no inspection on additional verification for Unit 2.
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The inspector selected one segment of piping and reviewed site records to
verify that sufficient documentation was available to demonstrate that the
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inspection elements of IEB 79-14 had been inspected and documented. The
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isometric drawing selected was 2CCB-15-2. The following related records
were reviewco:
%
Field As-Built Isometric
2CCB-15-2 Revision 5 (F-17)
As-Built Isometric
2CCB-15-2 Revision 6
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Field Inspection Checklists
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Spool 2CCB-15-2-2
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Spool 2CCB-15-2-1A
Spool 2CCB-15-2-1
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Flued Heads 2CCB-15-2-2P25
Hanger 2CCB-15-H9
Hanger 2CCB-15-H8
Hanger 2CCB-15-H7
Hanger 2CCB-15-H6
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Hanger 2CCD-15-H5
Hanger 2CCB-15-H4
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Field Inspection Reports Hanger Drawings
.,
H5-1509 Revision 2 (F-1)
H5-1508 Revision 0 (F-1)
H5-1507 Revision 2
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H5-1506 Revision 3
HS-1506 Revision 4
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H5-1505 Revision 1
H5-1505 Revision 2
H5-1504 Revision 2 (F-2)
Pipe Support / Restraint Installation Review Form P129, Drawing M2687
Sheet 95 Hanger Design Information Package.
No discrepancies were identified. Based on the records reviewed, it
appears that adequate documentation exists to support licensee's verifi-
cation process.
7.
Follow-up on IE Bulletin 79-05C (Unit 1)
IE Bulletin 79-05C was issued on July 26, 1979. This bulletin required
that the licensee take certain actions to alleviate the concern over
delayed tripping of the reactor coolant pumps after a Loss of Caolant
Accident (LOCA).
The licensee's letter of August 29, 1979, provided responses to shert-term
action items 1 through 4 of the bulletin and provided a schedule for
response to short-term action item number 5 and to the long-term action
item. The licensee's letter of September 14, 1979, provided additional
analysis as requested by the NRC staff.
The inspector had previously verified that licensee's action in response
to short-term action item number 1.
During this inspection period, the
inspector reviewed the licensee's emergency procedures for conformance
to the Babcock and Wilcox guidelines for operator actions. The observed
differences are summarized below.
a.
Immediate Trip of Reactor Coolant Pumps
The B&W guidelines state, "Upon automatic actuation of the ESFAS due
to low reactor coolant system pressure, RC pump operation shall be
promptly terminated." The guidelines further state that, "If the
ESFAS has been initiated on low RC pressure, termination RC pump oper-
ation takes precedence over all other immediaf_e actions."
AP&L Emergency Procedure (EP) 1202.06, " Loss of Coolant /RC Pressure,"
Section 1 " Rupture:
Leakage Greater than HPI Capacity," contains
an immediate action step to trip all operating RCP's.
However, the
first immediate action of this procedure is to verify reactor and
EP 1202.06,Section II, " Rupture within HPI Capacity," contains an
immediate action step to trip all operating RCP's if E.S. automatic
actuation occurs at any time during the transient. However, three
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other immediate actions are listed before this one. These steps
involve closing the letdown cooler inlet valves, isolating the
electromatic relief valve, and tripping the reactor and turbina
generator if pressurizer level is not restored or RCS pressure
does not recover aft.er letdown and ERV isolation.
b.
Steam Generator Level to be Maintained for Natural Circulation
The B&W guidelines recommend that SG level be maintained at 95%
on the operating range level indication following RCP trip to ensure
establishment of natural circulation.
EP 1202.06 and 1202.14 (Loss of laactor Coolant Flow - RCP Trip)
require that SG 1evels be raised to between 50% and 95% on the
operating range level indication following RCP trip.
c.
RCP Operating During Overcooling Transients
The B&W guidelines state that the immediate actions for both over-
cooling and small break transients are the same, including tripping of
the RC pumps.
The guidelines use the low pressure EFAO actuation as
a criterion for tripping the RCP's and describe this criterion as a
clear, simple and early indication that a small LOCA may be in progress.
This requires no decision process or monitoring by the operator to
determine whether tripping the RCP's is necessary.
The licensee's emergency procedures 1202.06 and 1202.24 (Steam
Supply System Rupture Procedure) distinguish between a LOCA and an
overcooling event in the symptoms sections of the procedures. There-
fore, the operator is not directed to trip the RCP's in response to
an EFAS actuation which has been determined to be caused by an over-
cooling event.
In procedure 1202.24 the operator is directed to stop
RCP's as necessary to achieve single pump operation in the unaffected
loop if EFAS has been actuated.
The inspector discussed these differences with licensee representatives.
They believe that their procedures are superior to the B&W guidelines in
these areas and allow better control of the plant during transients while
meeting the requirements of IE Bulletin 79-05C. The inspector informed
the licensee representatives that he would refer the differences to NRC
Headquarters for resolution. This is an open item.
(313/79-21-05)
8.
Hot Leg Temperature Anomaly (Unit 2)
In June 1979, the licensee identified anomalous behavior in the
temperature indications from the resistance temperature detectors (RTDs)
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in the reactor coolant system (RCS) hot legs. At50%powerghetwo
RTD's on the west side of the two hot legs indicate about 3 F higher
than the two RTD's on the east side. This temperature difference appears
to be proportional to power level. Occasionally the relationship
reverses momentarily such that the east RTD's read higher than the west
RTD's.
These transients are non periodic and their duration and
frequency of occurrence appear to be random. The reversals in one hot
leg appear to be independent of those in the other hot leg.
The licensee and Combustion Engineering have performed extensive testing
to evaluate the anomaly. They have reached a conclusion that the temperature
differential is due to lateral stratification in the region between the
core outlet and RTD locations in the hot 1 cgs, and that the flow asymmetries
have two meta-stable states in each loop. Random events are believed to
trigger a temporary shift to the less stable state.
In order to verify that the condition is not being caused by some abnormal
condition in the reactor vessel internals, the licensee is performing
an inspection of the internals. The licensee is concurrently performing
a design change to minimize the effect of the temperature reversals on the
Core Protection Calculators. After the internals inspection and design
change installation,.the licensee plans to perform extensive restart testing
and then to continue normal power ascension.
The inspector has observed portions of the testing performed to date and
he attended a presentation F ven to NRC/NRR on October 4, 1979, by the
i
licensee and his contractor. The inspector will continue to observe
portions of the inspection and testing related to this phenoma. No items
of noncompliance or deficiencies have been identified.
).
Exit Interviews
Exit interviews were conducted at the end of various segments of this
inspection with Mr. J. P. O'Hanlon (Plant General Manager) and other
members of the AP&L staff.
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