ML20031G641
| ML20031G641 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 09/30/1981 |
| From: | Callan L, Hunnicutt D, Johnson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20031G639 | List: |
| References | |
| 50-313-81-25, 50-368-81-24, NUDOCS 8110230414 | |
| Download: ML20031G641 (10) | |
See also: IR 05000313/1981025
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APPENDIX B
U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMEllT
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REGION IV
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Dockets:
50-313/81-25
License:
50-368/81-24
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Licensee:
Arkansas Power and Light Company
Post Office Box 551
Little Rock, Arkansas 72203
Facility Name:
Arkansas Nuclear One (AN0), Units-1 and 2
Inspection at:
AND Site, Russellville, Arkansas
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Inspection Conducted: July 22-August 21, 1981
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Inspectors:
7'[ [)
CA
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9-Fo-3 i
W. D. Johns'on, Senior Resident Reactor Inspector
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4-30-31
L. J. Caihn, Resident Reactor Inspector.
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Approved:
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9 9 0-Bl
D. M. Hunnicutt, Chief, Reactor Projects Section 2
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Inspection Sunaary
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Inspection conducted during period of July 22-August 21, 1981
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(Report 50-313/81-25)
Areas Inspected:
Routine, announced inspection including operational safety
verification, surveillance, maintenance, follow-up on previously identified
items, and follow-up on IE Circulars.
The inspection involved 124 inspector hours on site by two NRC inspectors.
Results:
Within the five areas inspected, no violations or deviations
were identified.
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PDR ADOCK 05000
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Inspection conducted during period of July 22-August 21, 1981
Report 50-368/81-24)
Areas Inspected:
Routine, announced inspection including operational safety
verification, surveillance, maintenance, follow-up on previously identified
items, and follow-up on IE Circulars.
The inspection involved 120 inspector hours on site by two NRC inspectors.
Rasults: Within the five areas inspected, three apparent violations were
Identified in two areas (Failure to submit Licensee Event Report, paragraph 2;
inoperable penetration fire barrier, paragraph 3; and inoperable control
room ventilation intake duct monitor, paragraph 3).
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DETAILS SECTION
1.
Persons Contacted
J. P. O'Hanlon, ANO General Manager
G. H. Miller, Engineering & Technical Support Manager
B. A. Baker, Operations Manager
T. N. Cogburn, Plant Analysis Superintendent
E. C. Ewing, Plant Engineering Superintendent
L. Sanders, Maintenance Manager
J. McWilliams, Unit 1 Operations Superintendent
J. Albers, Planning and Scheduling Supervisor
D. D. Snellings, Technical Analysis Superintendent
M. J. Bolanis, Health Physics Superintendent
L. J. Dugger, Special Projects Manager
L. Taylor, Operations Technical Engineer
R. Tucker, Electrical Maintenance Superintendent
L. Humphrey, Administration Manager
J. Lamb, Safety and Fire Protection Coordinator
J. C. Garrett, Materials Management Supervisor
B. Hampton, Stores Supervisor
L. Schempp, Manager of Nuclear Quality Control
B. Beckham, QC Inspector
B. West, I&C Supervisor
C. Cole, Planning and Scheduling Coordinator
The inspectors also contacted other plant personnel, including operators,
technicians and administrative personnel.
2.
Follow-up on Previously Identified Items (Units 1 & 2)
(Closed) Unresolved Item 368/8120-01:
The effect of missed surveillance
on system operability.
The licensee continues to take the position that the failure to perform
a surveillance requirement within the specified time interval does not
affect the OPERABILITY requirements for a Limiting Condition for
Operation (LCO).
As a result of this position, the licensee did not
submit to the Director of NRC Region IV within thirty days a written
report describing the conditions discovered on June 26, 1981, that
led to operation in a degraded mode permitted by LCO 3.8.2.5, Con-
tainment Penetration Conductor Overcurrent Protective Devices.
Specifically, on June 26, 1981, the licensee determined that
Surveillance Requirement 4.8.2.5a had not been performed since
September 12, 1978, and, therefore, had not been performed in
the specified time interval (every 18 months).
In accordance with
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Technical Specification 4.0.3, which states, in part, that "Per-
formance of a Surveillance Requirement within the specified time
interval shall constitute compliance with OPERABILITY require-
ments for a Limiting Condition for Operation . . .
the affected
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containment penetration conductor overcurrent protective devices
then became technically inoperable until Surveillance Requirement 4.8.2.5a was successfully completed on June 27, 1981.
The licensee's
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failure to submit, as required by Technical Specification 6.9.1.9b, a
written report within thirty days to the Director of NRC Region IV
describing this event constitutes an apparent violation (368/8124-02).
(0 pen) Open Item 313/8111-02; 368/8110-04:
Updating plant drawings
following design changes.
In March 1981, the inspector expressed concern to ANO management that
plant operation could be adversely affected if important plant
drawings are not maintained current to show actual system status.
Due
to the delay in updating plant drawings following design changes,
Operations Department personnel have found it necessary to append
informal sketches reflecting the as-built systems to plant drawings.
Although copies of DCP's are protided to the Control Room, it is a
time consuming research task to review the necessary DCP's and
integrate the information contained in several DCP's into a form
useful for plant operation.
The licensee was encouraged to develop
a system which would ensure that plant drawings are updated in a
timely manner following design changes.
This condition still exists.
Many of the design changes which wire
completed on Unit 1 during the first quarter of 1981 are not yet
closed out and reflected in plant drawings.
The licensee's response
to violation 313/8111-01 included a commitment to place the drawing
revision process under the control of Plant Engineering instead of
the Corporate Office with a goal of improving the timeliness and
control of the drawing revision process.
The estimated completion
date for this change was given as December 31, 1981.
Section 5.5.2 of the Arkansas Power & Light Quality Assurance Manual
for Operations states, " Applicable instructions, procedures and
drawings shall be reviewed and revised, as necessary, following any
modifications to the plant." The NRC inspector's position is that
updated drawings shall be issued and available to operations
personnel at the time that a modified safety related system is
turned over to the Operations Department following installation of
a design change.
The licensee has underway a project to close old Design Change Packages
with the assistance of a contractor.
The licensee is urged to complete
this project in a timely manner and to develop a system to implement
the above position.
This item remains open and has been reclassified
as an unresolved item pending appropriate licensee action.
3.
Operational Safety Verification (Units 1 and 2)
The NRC inspectors observed control room operations, reviewed applica-
ble logs and conducted discussions with control room operators.
The
inspectors verified the operability of selected emergency systems,
re/iewed tagout records and verified proper return to service of
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affected components.
Tours of accessible areas of the units were
conducted to observe plant equipment conditions, including potential
fire hazards, fluid leaks, and excessive vibrations and to verify that
maintenance requests had been initiated for equipment in need of
maintenance.
The inspectors, by observation and direct interview,
verified that the physical s:curity plan was being implemented in
accordance with the security plan.
The inspectors observed plant housekeeping / cleanliness conditions and
verified implementation of radiation protection controls.
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inspector walked down the accessible portions of the " RED" Engineered
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Safeguards Electrical Distribution System for Unit 2, the Unit 1
"A" High Pressure Injection, and the Unit 2 "A" diesel generator
fuel oil and air start s.vstems to verify operability.
The inspector
also witnessed portions of the radioactive waste system controls
associated with radwaste shipments and barreling.
These reviews and observations were conducted to verify that facility
operations were in conformance with the requirements estaclished
under Technical Specifications, 10 CFR, and administrative procedures.
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During a tour of the Unit 2 Auxiliary Building, the NRC inspector noted
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that the removal of a ventilation exhaust fan from above the southwest
corner of the ceiling for the North Engineered Safeguards Switchgear
Room (which contains Engineered Safeguards electrical bus 2A3) exposed
an approximate 2 ft. x 2 ft. hole through the ceiling.
The inspector
further noted that paper trash and other debris had been discarded
into the opening from above so that a significant amount of flammable
trash had collected in the various safety-related cable trays below
the opening.
Since the ceiling to the North Engineered Safeguards
Switchgear Room comprises part of the penetration fire barrier for
that safety-related area, the licensee ;s required by Unit 2
Technical Sepcification 3.7.11 to station a continuous fire watch
cn at least one side of the nonfunctional penetration within an
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hour.
Contrary to the above, although the hole in the southwest
corner of the ceiling of the North Engineered Safeguards Switchgear
Room had existed for at least one day, the NRC inspector found
that no fire watch was stationed at 1400 on August 11, 1981.
This
is an apparent violation (368/8124-01).
Constant Air Monitors
The NRC inspector noted during various tours of the Unit 1 and 2
Auxiliary Buildings that the costant air montiors (CAMS) were not
being adequately maintained.
One of the CAMS (NMC 009 located on
the 335' level in the Unit 2 Auxiliary Building) was found to be
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inoperable on July 31, 1981, and appeared to have been almost
continuously inoperable since about the end of May 1981.
Problems
relating to inadequate care and maintenance of CAMS were identified
in paragraph 4.5.6 of a NRC Health Physics appraisal conducted during
the period October 27 - November 7, 1980 (Docket Nos. 50-313/80-20 and
50-368/80-20), and since then the licensee has developed and imple-
mented Procedure 1602.22, " Operation of NMC Continuous Air Monitor."
However, it appears that the CAM maintenance program requires additional
improvement in order to attain adequate reliability and operability
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of these units.
This item will remain open pending the inspector's
determination that the CAMS are being adequately maintained (313/8125-01;
368/8124-03).
Fire Detection Systems
The in pector is concerned about the present status of the Unit 1 and
Unit 2 Fire Detection Systems, specifically with respect to the system's
ability to meet the operability requirements of Technical Specification 3.5.5 for Unit 1 and 3.3.3.8 for Unit 2.
In the case of the Unit 1
Fire Detection System, the inspector's concern stems from the chronic
electrical problems the system has experienced during the past few
months. Although it appears to the inspector that the actual heat
and smoke detectors associated with the system are indeed operable
and will alarm in the control room as required, the concern is
that these electrical problems have resulted in a large number
(almost continuous) of spurious system " trouble" indications
on the control room indicating panel that have the potential to
mask an actual " trouble" condition and could thereby prevent
an operator from diagnosing a true inoperability condition.
In
the case of the Unit 2 Fire Detection System, the inspector's
concern is that due to the fact that a new, more complex system
is in the final stages of installation while the previous system
was recently phased out, the majority of the licensed operators
in the control room are unsure of the new system's status, are
not adequately trained on the operating characteristics of the
new system, and, in the inspector's opinion, would have difficulty
assessing an incoming alarm.
This matter regarding the operability
of the Unit 1 and Unit 2 Fire Detection Systems will remain un-
resolved pending further inspector review (313/8125-02; 368/8124-04).
Control Room Ventilation Intake Duct Monitor
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Unit 2 Technical Soecification Table 3.3-6 requires that the control
room ventilation intake duct monitor (2RITS-8750-1) be operable during
all operating modes. The applicable action statement states, "With
the number of channels OPERABLE less than required by the Minimum
Channels OPERABLE requirement, within one hour initiate and maintain
operation of the control room emergency ventilation system in the
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recirculation mode of operation."
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On July 27, 1981, at 0750 hours0.00868 days <br />0.208 hours <br />0.00124 weeks <br />2.85375e-4 months <br />, the NRC inspector found 2RITS-8750-1
inoperable (in the test mode with indication failed low) and the control
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room emergency ventilation system was not in the recirculation mode
of operation.
The operators on duty were not aware of the status of
this instrument until it was pointed out by the inspector.
Upon
.being informed, the plant operator placed the instrument in service.
It was not known when the instrument had been taken out of service.
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This is an apparent violation of Technical Specification requirements
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(368/8124-05).
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Heat Tracing Channel Alarms
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The NRC inspector observed that numerous channels of system heat
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tracing were in alarm and could not be cleared by the operators.
The
Operations Superintendent stated that he would submit a Plant-
Engineering Analysis Request in an attempt to identify and correct the
problems contributing to this condition.
This is an open item
(313/8125-04; 368/8124-07).
4.
Monthly Surveillance Observation (Units 1 and 2)
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The NRC inspectors observed the Technical Specification required monthly
surveillance testing on the Unit 2 "A"
Diesel Generator (2104.36 Supple-
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ment I) and verified that testing was performed in accordance with adequate
procedures, that test instrumertation was calibrated, that Limiting Condi-
tions for Operation were met, that removal and restoration of ti.e affected
components were accomplished, that test results conformed with Technical
Specifications and procedure requirements and were reviewed by personnel
other than the individual directing the test, and that any deficiencies
identified during the testing were properly reviewed and resolved by
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appropriate management personnel.
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The NRC inspector also witnessed portions of the following test activities:
Calibration of Unit 2 Hydrogen Analyzers (2304.029).
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Monthly surveillance on Unit 1 Reactor Protective System Channel "B"
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(1304.38).
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Unit 1 Reactor Building Hydrogen Purge Standby System Station monthly
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surveillance (1104.33 Supplement II).
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The NRC inspector reviewed surveillance te.it records for tests performed in
accordance with the requirements of Unit 2 lechnical Specifications 4.6.4.1
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and 4.6.4.2.
The test procedures included:
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2104.44, Supplement 1
2104.44, Supplement 2
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2104.44, Supplement 3
2104.44, Supplement 4
2304.62
2304.31
2304.29
These are surveillance tests performed on the electric hydrogen recombiners
and on the hydrogen analyzers.
Technical Specification 4.6.4.1 requires
that the two hydrogen analyzers be calibrated once per 92 days on a STAGGERED
TEST BASIS.
The NRC inspector found that up until March 1981, the calibra-
tion had been performed once per six months on a STAGGERED TEST BASIS.
In
March 1981, the test program was altered to perform this calibration at
the required interval.
The licensee had identified this apparent Techni-
cal Specification violation during the first refueling outage and Report
of Abnormal Condition (RAC) No. 81071 was prepared by the licensee.
Since the licensee identified and corrected this apparent Technical
Specification violation, it will not be cited by the NRC.
The NRC
inspector noted that Technical Specification 4.6.4.lb requires tha use
of a 4% hydrogen sample gas in the calibration of the hydrogen analyzers.
The licensee should propose a change to this specification to account
for the increased range (0 - 10%) of the new hydrogen analyzers which were
installed earlier this year.
This is an open item (368/8024-06).
No
other violations or deviations were identified.
5.
Monthly Maintenance Observation (Units 1 and 2)
Station maintenance activities of safety-related systems and components
listed below were observed / reviewed to ascertain that they were conducted
in accordance with approved procedures, regulatory guides and industry
codes or standards and in conformance with technical specification.
The following items were considered during this review:
The Limiting
Conditions for Operation were met while components or systems were
removed from service; approvals were obtained prior to initiating the
work; activities were accomplished using approved procedures and were
inspected as applicable; functional testing and/or calibrations were
performed prior to returning components or systems to service; quality
control records were maintained; activities were accomplished by qualified
personnel; parts and materials used were properly certified; radiologi-
cal controls were implemented; and fire prevention controls were imple-
mented.
Work requests were reviewed to determine status of outstanding jobs
and to assure that priority is assigned to safety-related equipment
maintenance which may affect system performance.
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The following maintenance activities were observed / reviewed:
Repair of lower primary manway on "A" OSTG (J0-1191)
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Repair and replace lower manway on "A" 0TSG (J0-06266)
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Repair 2P36C (J0-15160 on July 22, 1981, and J0 1635 August 7,
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1981)
Machine standpipe from B Reactor Coolant Pump Seal (J0-6255)
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Repack 2P36A (J0-15172)
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Following completion of maintenance on the Unit 2 "A" charging pump,
the NRC inspector verified that this system had been returned to
service properly.
In conjunction with the Unit 1 OTSG manway replacement job, the NRC
inspector inspected the licensee's stock of spare primary and secondary
manway gaskets.
The following table lists the gaskets found in stock:
Purchase Order
AP&L Stock No.
No. in Stock
No. Rings
27084
580064
6
14
16437
580064
1
22
27084
580066
2
19
16437
580066
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07960
580066
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AP&L Stock No. 580064 is for primary manway gaskets and 580066 is for
secondary manway gaskets.
The gaskets in stock are identified by
paper tags attached to the gaskets or inside the plastic bag con-
taining the gasket.
The licensee's procedure fer replacement of a
primary manway cover 1402.30, points out the difficulty in differentiat-
ing between primary and secondary manway gaskets and states that primary
gaskets may be identified by counting the rings (should be 20-24).
Babcock and Wilcox drawing 135040E states that primary manway gaskets
and the gaskets in stock do not have metal identification tags. The
NRC inspector discussed the problem of identification of primary manway
gaskets and the apparent discrepancy in the identification of the gas-
kets now in stock with the Material Management Supervisor and the Stores
Supervisor.
The Stores Supervisor agreed to seek resolution through
submission of a Plant Engineering Analysis Request and a Nonconforman;e
Report.
This is an open item (313/8125-03).
No violations or deviations were identified.
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6.
IE Circular Followup (Units 1 and 2)
For the IE Circulars listed below the NRC inspector verified that the
Circular was received by the licensee management, that a review for
applicability was performed, and that if the circular were applicable
to the facility, appropriate corrective actions were taken or were
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scheduled to be taken.
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80-18
10 CFR 50.59 Safety Evaluations for Changes to Radioactive
Waste Treatment Systems
80-21
Regulation of Refueling Crews
80-23
Potential Defects in Beloit Power Systems Emergency Generators
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81-04
Role of Shift Technical Advisors and Importance of Reporting
Operational Events
81-06
Potential Deficiency Affecting Certain Foxboro 10 to 50
Milliampere Transmitters
81-08
Foundation Materials
No violations or deviations were identified.
7.
Unresolved Items (Units 1 and 2)
Unresolved items are matters about which more information is required in
order to ascertain whether they are acceptable items, items of noncom-
pliance, or deviations.
Unresolved items disclosed during the inspec-
tion are discussed in paragraphs 2 and 3.
8.
Exit Interview
The NRC inspectors met with Mr. J. P. O'Hanlon (Plant General Manager)
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and other members of the AP&L staff at the end of various segments of
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this inspection.
At these meetings, the inspectors summarized the
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scope of the inspection and the findings.
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