ML19326B755
| ML19326B755 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 10/18/1977 |
| From: | Gagliardo J, Madsen G, Spangler R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19326B724 | List: |
| References | |
| 50-313-77-16, 50-368-77-31, NUDOCS 8004170583 | |
| Download: ML19326B755 (12) | |
See also: IR 05000313/1977016
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U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
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Report Nos. 50-313/77-16; 50-368/77-21
Docket No. 50-313
License No. DPR-51
50-368
Construction Permit No. CPPR-89
Licensee:
Arkansas Power & Light Company
P. O. Box 551
Little Rock, Arkansas 72203
Fa ility Name: Arkansas Nuclear One, Units 1 and 2
Itspection At: AN0 Site, Russellville, Arkansas and Corporate Offices in
Little Rock, Arkansas
Inspection Conducted: September 26-29 and October 7-8, 1977
Inspectors:
N 4r D h
/o/q/7 7
'J7 E. Gagliardo, Reactor Inspector
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R. G. Spangler, Reactor Insphctor (Intern)
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Approved By:
W4
/o /&/ 27
fi. L. Madsen, Chief, Reactor Operations and
Date
Nuclear Support Branch
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Inspection Summary
Inspection on September 26-29 and October 7-8, 1977 (Report No. 50-313/77-16;
50-367/77-21)
Areas Inspected: Routine unannounced inspection involving the review of test
program status, fuel receipt inspection, witness of secondary hydrostatic
testing activities, Unit 2 jumper and bypass log, TWG activities, startup
punchlist, comitments on overpressure protection, Unit 2 operations orders,
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testing of spent fuel pool k.11 deficiency, posting requirements and followup
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on previously identified matters. The inspection involved 57 inspector-hours
on-sitebytwo(2)NRCinspectorsand12 inspector-hoursintheCorporate
offices by two (2) NRC inspectors.
Results: Of the eleven (11) areas inspected, no items of noncompliance or
deviations were identified in seven (7) areas. One apparent item of noncom-
pliance (infraction - failure to follow a Startup Administrative Procedure,
paragraphs 4, 5 and 8) was identified in three (3) of the remaining areas.
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One deviation from an applicant's commitment was identified (paragraph 3) in
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one area.
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DETAILS
1.
Persons Contacted
Arkansas Power & Light Company Employees
L. Alexander, Qttality Cont.ol Engineer
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P. H. Almonds, Reactor Engineer
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L. W. Anderson, Engineering Records Clerk
- J. R. Anderson, Assistant Production Startup ; spervisor
J. W. Anderson, Superintendent of Power Plant
B. A. Baker, Assistant Operations Supervisor
- B. Bata, QA Engineer
T. L. Bell, Shift Supervisor
- 0. N. Bennett, Production Startup Supervisor
R. A. Brumfield, Production Engineer
T. H. Cogburn, Nuclear Engineer
- E. C. Ewing, Assistant Production Startup Supervisor
F. B. Foster, Production Engineer
A. W. Huebner, QA Engineer
E. B. Hyatt, Reactor Engineer
G. Mansell, Production Engineer
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G. H. Miller, Assistant Plant Superintendent
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- N. A. Moore, QA Manager
D. A. Rueter, Licensing Manager
D. F. Spond, QA Engineer
- S. S. Strasner, Quality Control Inspector
B. A. Terwilliger, Supervisor Plant Operations
D. Trimble, Training Coordinator
W. W. Washburn, Startup Engineer
Bechtel Employees
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W..E. McMahon, Senior Startup Engineer
Combustion Engineering Employees
V. P. Roy, QA Engineer
- Indicates those attending the exit interview
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2.
Status of Preoperational Test Program
At the time of this inspection, the applicant'had completed the initial
testing defined by seventy-one (71) of the one hundred and eighty-six
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-(186) procedures in the preoperational test program. All but
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twenty-three (23) of the 186 test procedures have been approved for
execution.. Eighteen (18) of the fifty-one (51) startup test procedures
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had been approved for execution.
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' 3.
Followup on Previously Identified Findings
(0 pen) Noncompliance (Infraction 1,InspectionReport 50-313/77-10;
50-368/77-11): Failure of SRC to conduct 'an audit of the operator
requalification program. The inspector found that the revisions to
SRC Charter and SRC General Plant Audit Guidelines had been made as
noted in the applicant's -response letter 1/. The inspector noted,
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however, that the above guidance was very general and may not provide
sufficient detailed guidance to prevent recurrence of this type of
noncompliance. Applicant representative said that they would discuss
the inspector's concerns with the committee during the next comittee
meeting. This item remains open.
(0 pen) Noncom
50-313/77-10;
50-368/77-11)pliance (Infraction 2.a, Inspection ReportFailure to use vendor
as required by QC Procedure 1004.05. The inspector verified that:
a.
Procedure 1004.05 had been revised by ANO site QC personnel
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to include a requirement that the originator of a purchase
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requisition for Q-List material verify that the vendar is
on the approved vendors list;
b.
that corporate QA had conducted an audit to locate all
purchases made from nonqualified vr Jors;
c.
that a system had been initiated requiring corporate QA to
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review all ANO purchase requisitions to verify that only
approved vendors are used. This review will be
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incorporated into a revision to NSP 2-10 and will be
included in procedures being developed by AP&L Purchasing
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Department.
This iten will remain open pending a review of the revised NSP 2-10
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and the purchasing procedures.
(0 pen) Noncompliance (Infraction 2.b, Inspection Report 50-313/77-10;
50-368/77-11): Failure to follow manufacturer storage requirements
for Q-List spare parts.
In his response letter 2/ the licensee
stated, "All motors stored in the ANO Storeroom Tiave been segregated
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and placed in a " hold" status. Before release for. installation, each
motor shall be inspected by a qualified level I inspector. The ANO
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Maintenance Supervisor is developing a system by which each stored
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Q-List item requiring special attention during storage shall be
identified and maintained in such a manner that the item is not
degraded. We believe this system will be in effect by August 15, 1977."
jl Letter D. A. Rueter (AP&L) to G. L. Madsen (NRC/IE), dated 9/1/77.
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2/ Ibid
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The inspector found that only three Q-List motors were in the
" hold" area and the remainder were on the storage shelves. A
licensee representative said that all of the Q-List motors had been
placed in the " hold" area after the noncompliance item was identified.
He said that they were inspectd by the Electrical Foreman and
returned to the storage shelves. The inspector could find no
documented evidence of the licensee's purported activities. The
inspector also found that the Maintenance Supervisor had not yet
developed the committed system for controlling Q-List items requir-
ing special attention.
In a subsequent telephone conversation with
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the Superintendent of the Power Plant, the inspector was informed
that the above activities would be cornpleted and documented by
December 1,1977. This item has been identified as a Deviation
from the licensee's above stated comitments.
'(Closed) Open Item (Paragraph 2.b, Inspection Report 77-07):
Discrepancies in Preoperational Test Procedure 2.024.03. The
inspector-identified discrepancies were corrected in the latest
revisions to procedures 2.024.03 and 2.024.01 and 02. This item
is closed.
(0 pen) Open Item (Paragraph 4, Inspection Report 77-11): SRC Audits
of TS Conformance. Applicant representative discussed wit'n the
inspector a program for auditing TS conformance which they planned
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to submit to the SRC during its next meeting.
This item remains
open.
(0 pen) Open Item (Paragraph 5, Inspection Report 77-11): Periodic
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Review of Drawing Indices. The applicant has no program which
establishes responsibilities for the periodic review of the Unit 2
drawing index (register). The applicant's Engineering Record Clerk
currently reviews the Unit 1 register as drawing revisions are
entered into the system. She does not, however, have a formal
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requirement (procedure, written instructions, etc.) to perform this
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review. This item remains open.
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(Closed) Open Item (Paragraph 5, Inspection Report 77-11): Tracking
of Drawing Changes. The applicant has no formal means_ of tracking
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drawing ~ changes through to the submittal of an FSAR amendment. An
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applicant representative noted that all FSAR amendments are reviewed
by AP&L management prior to submittal and that their AE (Bechtel)
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provides the above controls for tracking drawing changes. This item
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Is' closed.
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(0 pen) Open Item (Paragraph 3.b, Inspection Report 77-19): Discrepancies
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in HFT Procedures. The discrepancies in HFT procedure 2.600.01 have
been corm:ted. Several discrepancies remain in procedures 2.600.03
and 2.600.13. This item remains open.
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(0 pen) Open Item (Paragraph 3.c, Inspection Report 77-16):
Inspection
of Reactor Internals for Vibration Analysis. The inspector reviewed
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the photographs that had been taken of the vessel internals during
the baseline inspection. The NDE examination results were not
available for review. A representative of the applicant said that
the dye penetrant examination had been performed and that he would
locate the examination results for the inspector's review during a
fature inspection. This item remains open.
(0 pen) Open Item (Paragraph 9, Inspection Report 77-20): Training
and Certification of Fuel Handling Equipment Operators and Crane
Operators. The applicant's Training Coordinator informed the
inspector that two lectures would be given to prospective operators
of the fuel handling bridge and transfer devices by the operator who
had written the operating precedures for this equipment. The Training
Coordinator said that no on-the-job training had been performed. He
noted, however, that during the checkout and indexing of the fuel
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handling equipment all operators will participate in the operation and
this on-the-job training would be documented.
Those operators who
have completed this training will be certified by management. He
stated that similar training and certifications will be used for the
containment building crane operators. This item remains open.
4.
Fuel Assembly Receipt Inspection
The inspector continued to review the applicant's activities related
to the receipt and inspection of new fuel for Unit 2.
The review
included a verification that:
a.
Requirements of the SNM license and comitments in the
application had been included in the receipt and inspection
procedures.
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b.
The inspection procedure includes examinations for the types
of fuel damage and the poison pin location discrepancies
recently experienced at other facilities.
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c.
Receipt and inspection activities are in conformance with the
above procedures.
d.
The fuel is protected after inspection to maintain it in a
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clean condition until ready for use.
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e.
Inspection records reflect satisfactory performance of the
inspection and conformance to the acceptance criteria.
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The inspector had previously discussed with applicant representa-
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tives the recent experiences at other facilities concerning fuel
assembly damage during shipment and the discovery of improperly
located poison pins. Applicant representatives had not planned
originally to inspect the fuel assemblies for these anomolies but
after the above discussions they agreed to do so. The inspector
verified that the applicant was performing these additional
inspection activ' ties to assure that the above anomolies were not
present. The t :pector found, however, that the applicant had not
amended his inspection procedure to require these additional
inspections and thus was not documenting these additional inspections.
The inspector discussed his concern in this area with the Superinten-
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dent of the Power Plant. The superintendent stated that there were
no regulatory requirements for perfoming the additiont.1 inspections
and thus they would cease the performance of the addittonal inspections.
He indicated that they would perfom only those inspections which
are required by their approved inspection procedures.
The inspector also identified another problem relative to the fuel
inspection. Section 10 (Inspection) of the applicant's NRC approved
Quality Assurance Manual (QAM) for Operations establishes inspection
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requirements for quality related activities such as the receipt of
Q-List materials, parts or components (Section -10.1.3.4).
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Section 10.3.1 of the QAM states in part:
"To accomplish inspections, written procedures, instructions,
diagrams, foms and checklists shall be provided which as a
minimum contain the following:
"1)
Qualitative and quantitative acceptance criteria.
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"2)
Identification of those individuals responsible for
performing the inspection operation.
"3)
A description of the method of inspection examination,
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measurement or test of material or product process
necessary to be performed to assure quality.
"4)
Identification of any special tools, equipment or skills
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required."
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The inspector found that the fuel inspection procedure (2503.01) did
contain appropriate acceptance criteria but it did not identify those
individuals responsible for performing the inspection, the method of
inspection / measurement and the special tools required. to verify confor-
mance to the acceptance criteria.
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Section 10.4.1 of the QAM states in part:
" Personnel qualified to perform inspections are normally the
Quality control Engineer, the onsite quality control staff and
the quality assurance inspectors. Personnel qualified to
perform inspections shall meet the following requirements:
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"2)
Have satisfactorily completed the qualification require-
ments as specified in the procedure for qualification
and certification of quality control personnel (QCP
1004.20),or
"3)
Be currently qualified and so designated on a list of
qualified inspectors approved by the Quality Control
Engineer or the Manager of Quality Assurance."
The applicant's Nuclear Engineer and the Reactor Engineers who are
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pertarming the fuel inspections had not been qualified and certified
as required above.
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Criterion V of Appendix B to 10 CFR 50 requires in part that,
" Activities affecting quality shall be prescribed by documented
instructions, procedures, or drawings, of a type appropriate to the
circumstances and shall be accomplished in accordance with these
instructions, procedures, or drawings . . . ."
The applicant's failure to adhere to the above requirements of the
QAM constitutes an apparent item of noncompliance with the 10 CFR 50,
Appendix B requirement listed above.
No other discrepancies were found in this area.
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5.
Witness of Secondary Hydro
The inspector had planned to witness the performance of the hydrostatic
test on the steam generators and cc..necting secondary piping during this
inspection. A number of inadvertent delays were experienced due to
valve leakage and water chemistry problems. The inspector terminated
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his inspection effort on the afternoon of Saturday, October 8.
The
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hydro was completed on Sunday evening, October 9.
During the inspection the inspector performed the following inspection
activities :
a.
Reviewed the approved hydro procedure (2.400.01)
b.
Verified that test prerequisites had been met and documented
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Reviewed the calibration records of the special test gauges
to be used
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Verified the line up of selected valves and the installation.
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of special apparatus and hydro pumps
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Verified that selected sections of piping which were not
included in the boundaries of this test had been previously
hydroed under other procedures
Several discrepancies were identified during this inspection effort
and are discussed below.
Step 7.2.16 of the approved procedure stated, " Install stainless steel
tubing from 2EFW-2011 A to 2SGS-1015B and 2EFW-30llB to 2SGS-10658."
These lines bypass the emergency feedwater check valves EFW9A and 98
to insure that hydro pressure is sensed on the emergency feedwater
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lines upstream of the check valves. The inspector noted in reviewing
this step, that according to the referenced drawing (Bechtel Drawing
MT206, also Figure 10.2-3 in the FSAR), one of the valves in each of
the above pairs was inside the containment building and the other
valves were outside of containment. The inspector notr' +. hat this
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step had been signed off on the " official copy" of the test procedure
and asked to see this installation.
It was found that the stainless
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steel jumper lines had been installed around check valves EFW9A and
98 but had not bet.n connected to the valves indicated in step 7.2.16.
Paragraph 4.2.1 of Startup Administrative Procedure (SAP) 2-12 states
in part, " Administrative errors such as typo's, wrong valve numbers,
wrong section numbers, wrong reference numbers, etc.-which do not
change the technical content of the procedure may be corrected by the
test director.
Correction is donc by lining out, writing the
correction and initialling and dating the correction."
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The applicant's failure to document and approve the change in step
7.2.16 of procedure 2.400.01 as required above is an apparent item of
noncompliance against the requirement of 10 CFR 50, Appendix B,
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Criterion V, as detailed in paragraph 4 of this report.
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The inspector also found that the drawing M-2206 (FSAR Figure 10.2-3)
did not show the "as-built" configuration of the steam generator
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piping. The actual drain lines used to bypass the EFW9A and 9B check
valves are not accurately shown on the drawincj. One of the drain lines
used on the B" steam generator is not shown on the drawing and both
of the drain lines used on the "A" steam generator are shown on the
same side of the check valve which is not correct. An applicant
representative took note of the error and said that a drawing change
would be requested. This item remains open.
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6.
Jumper and Bypass Log
The inspector reviewed the applicant's use of jumpers, bypasses and
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temporary system modifications to verify that activities in this
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area conform to the requirements of the applicant's Startup Admin-
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istrative Procedure (SAP) 2-9.
The inspector also reviewed the status
of the jumper and bypass discrepancies which had been cited as an
item of noncorg,i .ance in Inspection Report 77-20.
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To verify conformance with SAP 2-9 in the placement of jumpers and the
marking of same, the inspector selected two systems and personally
examined each of the open jumpers and lifted leads for these systems.
Two minor discrepancies were noted and were corrected by applicant
representatives.
Most of the discrepancies cited in Inspection Report 77-20 had been
corrected. An applicant representative was unable to locate the log
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sheet for one of the systems. He said that the sheet may have been
removed by a startup engineer after all of the jumpers had been
removed and closed out. He said that he would locate the sheet and
return it to the log book. This item remains unresolved (Unresolved
Item 7721-1).
7.
Test Working Group (TWG) Activities
The inspector reviewed the minutes and reviewed sheets for TWG meet-
ings and reviewed activities in September 1977. No discrepancies
were identified.
8.
Review of the Startup Group's Punchlist
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The inspector reviewed the AP&L startup group's punchlist to determine
that it contained the items specified in SAP 2-7 (Resolution of System
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Problems), Revision 1 dated September 29, 1976. Several startup field
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reports (SFR), startup work reports (SWR), and turnover release
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exception lists were selected and compared against the punchlist
entries. All SFR's and SWR's selected had corresponding punchlist
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entries. Although paragraph 4.3.3.2 of SAP 2-7, Release Exceptions,
specifies that each release exception identified in the turnover package
will be placed on the punchlist., the following open release exceptions
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were not found on the punchlist.
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List ID
Item #
Item
658-1-M
3
Complete large pipe hangers
per attached list.
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658-1-M
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Complete small pipe hangers
per attached list.
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List ID
Item #
Item
658-1-M
10
Install motor operators on
2CV-4697-2 and 2CV-4698-1.
658-1-S/C
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Complete Installation of
2T-1.
Paragraph 4.3 of Startup Administrative Procedure (SAP) 2-7, Resolution
of System Problems, states in part, "In order to provide a convenient
means of identifying outstanding work items, a punchlist form will be
prepared and maintained / sample forms shown in Appendix D to the
proceduref." Furthermore, paragraph 4.3.3.2, Release Exceptions, of
SAP 2-7 states:
"Upon system turnover each release exception identified in
the turnover package will be placed on the punchlist. As
additional construction or vendor problems are identified
and agreed to by Construction as valid release exceptions
they will be placed on the release exception list. Then
these will also be placed on the punchlist. This will be
done to centralize all items on one list.
Resolution of
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construction deficiencies shall be in accordance with
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Section 4.4 of this procedure."
The applicant's failure to place the above release exceptions on the
punchlist as required by SAP 2-7 is an apparent item of noncompliance
against Criterion V of 10 CFR 50, Appendix B, as detailed in paragraph
4.
9.
Review of Applicant's Corsaitments Regarding Low Temperature Over-
Pressurizatior
The inspector reviewed the following operating procedures:
2102.02
Plant Startup
2102.05
Operation at Hot Standby
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2l02.10
Plant Shutdown and Cooldown
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The inspector also reviewed other associated operating procedures to
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determine if these procedures fully implement the interim measures
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comitted to by the applicant in a letter to the Director of Nuclear
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Reactor Regulation, dated August 18, 1977. The commit.nents had not
yet been implementad. An applicant representative stated that the
above procedures are being reviewed and that the comitments would
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be reflected in the revised procedures. This item is open pending a
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review of the revised procedures.
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10.
Review of Unit 2 Operations Orders
The inspector reviewed the operations order to AP&L operators for
Unit 2 systems under the direct control of AP&L startup. The
operations order book is organized by startup system number and
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contains instructions -to the operators which are entered by the
system startup engineer.
During a discussion with the. applicant's
startup management, the inspectors expressed.the concern that there
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appears to be no review of this book by startup management. This
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dilution of management responsibility can contribute to confusion
. in that no clear lines of comunication exist between startup
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management and operations personnel.
In addition, the segmented
organization of the Startup Systems Instruction Book can lead to
operational conflicts between systems that may be in other than
normal configurations, and to a lack of cross-referenced entries
under all affected startup systems. For example, the licensee
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currently has a requirement to maintain a minimum of 900F reactor
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vessel head temperature.
Initially, this was done by utilizing a
low pressure safety injection (LPSI) pump to add heat to the
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reactor coolant system as required. This requirement and these
instructions were entered only under the LPSI system (number 51)
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in the Startup System Instruction Book.
In view of this, the
applicant's startup management agreed to periodically review the
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Startup System Instruction Book to ensure adequate entries and lack
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of intersystem conflicts.
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11.
Spent Fuel Pool Wall Deficiency
The inspector reviewed the report of the tests to verify the
structural integrity of the spent fuel pool. These tests were
conducted in October 1976 as a result of the applicant's comitment 3/
to the Comission. The applicant had performed all of the comitted-
testing and no significant discrepancies were noted.
In the above letter, the applicant made the following long-term surveil-
lance comitment:
"For a long-term survey an extended mapping program
will be carried out starting with the first refueling." The inspector
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could find no evidence that responsibilities had been assigned to
schedule and perform this surveillance. This item remains unresolved
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(Unresolved Item 7721-2).
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12.
Posting Requirements
During the review of noncompliance follow up (paragraph 3), the
inspector found that the licensee had not issued instructions or
assigned responsibilities to assure that applicable items of noncom-
pliance and responses thereto are posted in accordance with 10 CFR 19.
A licensee representative said that administrative procedures would
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be developed to correct this discrepancy. This item remains open.
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3] . Letter W. Cavanaugh (AP&L) to J. F. Stolz (NRC/NRR), dated 7/1/76
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13.
Exit Interview
The inspectors met with licensee representatives (denoted in
paragraph 1) at the ANO site and again at the Little Rock Corporate
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Offices on September 28 and 29,1977, respectively.
The findings
as detailed above were discussed with the licensee representatives.
The findings relating to the October 7-8 portion of the inspection
were discussed with Mr. D. Bennett and Mr. J. Anderson on October 11
and 12, 1977.
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