ML20041D497
| ML20041D497 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 01/26/1982 |
| From: | Boardman J, Randy Hall, Murphy M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20041D476 | List: |
| References | |
| 50-313-81-34, 50-368-81-34, NUDOCS 8203050358 | |
| Download: ML20041D497 (6) | |
See also: IR 05000313/1981034
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APPENDIX B
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Report:
50-313/81-34
50-368/81-34
Dockets:
50-313
Licenses:
50-368
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: AN0 Site, Russellville, Arkansas, and
Corporate Offices, Little Rock, Arkansas
Inspection Conducted:
December 14-17, 1981
Inspectors:
/ [
'/2 4'/f'.
u' WW
J. ))/ Boardman, Reactor Inspector, Systems and Technical
Date'
section (Paragraphs 1, 2, 3, 4, 5, 6, 8, & 9)
/Is b 2
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M. E. Murphy ( Reactor UHpector, Systems and Technical
Gath
Section (Paragraphs 2, 4, 6, & 7)
Approved:
/[u,fu
R. E. Hall, Chief, Systems and Technical Section
Datt
Inspection Summary
Inspection Conducted on December 14-17, 1981 (Report 50-313/81-34; 50-368/81-34)
Areas Inspected:
Routine, unannounced inspection of the licensee's Quality
Assurance program, audit program implementation, maintenance program, implemen-
tation of inservice inspection, and follow up on previously identified items.
The inspection involved 50 inspector-hours by two NRC inspectors.
Results: Within the five areas inspected, no violations were identified in
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four areas, and one apparent violation was identified in the fifth area
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(violation - failure to perform surveillance within prescribed frequency -
paragraph 5).
8203050358 820201
PDR ADOCK 05000313
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DETAILS
1.
Persons Contacted
J. Albers, Planning and Scheduling Supervisor
- L. J. Dugger, Manager Special Projects, AN0
E. C. Ewing, Plant Engineering Superintendent
H. T. Greene, QA Supervisor Nuclear (LR)
+D. G. Horton, Manager, Quality Assurance
- L. O. Howard, Engineer, M.E. Department
- L. W. Humphrey, Plant Administrative Manager
- J. M. Levine, Engineering and Technical Support Manager
- J. P. O'Hanlon, ANO General Manager
G. D. Provencher, QA Supervisor Nuclear, ANO
- E. L. Sanders, Maintenance Manager
- L. W. Schempp, Manager, Nuclear Quality Control
S. Strasner, Quality Control Supt.rvisor
+D. Trimble, Manager Licensing
J. H. Draggs, Bechtel Power Corporation
The NRC inspectors also contacted other licensee employees, including
administrative, quality assurance, clerical, and maintenance personnel.
- Denotes those attending the exit interview on December 16, 1981.
+ Denotes those attending the exit interview on December 17, 1981.
2.
Licensee Action on Previous Inspection Findings
(Closed) Unresolved Item (313/8120-01; 368/8119-01):
The licensee had
not implemented a program of shelf life identification and control.
Licensee material identification was not in sufficient detail to permit
the licensee to identify shelf life requirements.
The licensee has
revised Form 1000.llA, " Conditions of Acceptance," to require the seller
to identify shelf life items and expiration date.
This item is cloced.
3.
Audit Program Implementation
On December 15,16, and 17, the NRC inspector reviewed 11 audits conducted
by the licensee during 1981 and audit training and qualification records.
The audits were conducted by trained personnel not having direct responsi-
bility for the areas audited. Audited organizations responded in writing
to audit findings and follow-up actions included reaudit.
No discrepancies
were found in auditor training and qualification.
The NRC inspector re-
viewed licensee implementation of audit requirements of the licensee's
Technical Specifications, Section 6.5.2.8.
The licensee performs no
separate audit of results of all actions taken to correct deficiences, but
includes this attribute in each audit as the means of complying with this
Technical Specification requirement.
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Of the 23 audits contained in the licensee's 1981 Quality Assurance Audit
Plan, 14 were more than 30 days late.
The QA Manager stated that he had
approved these delays.
Some of these delays were the result of the late
issue of the new related Quality Assurance procedures.
The NPC inspector
is concerned that this situation, if not corrected by adequate manpower
assigned to auditing, can lead to superficial auditing or failure to per-
form necessary audits.
Five of the 23 audits scheduled for 1981 were
not performed, but were rescheduled to 1982.
Pending resolution of this
situation, this will be considered an open item.
(313/8134-04; 368/8134-03)
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No violations or deviations were identified in this area.
4.
Quality Assurance Program
On December 14, 15, and 16, the NRC inspector reviewed licensee Quality
Assurance Procedures and Quality Assurance Administrative Procedures
issued as new procedures or revised since the last inspection.
Also, the
Middle South Services Audit Report of the licensee's Quality Assurance
Program was reviewed. No violations or deviations were identified.
The
NRC inspector was concerned that the Quality Assurance Manager was not
reviewing all AN0 Master Plant Manual - Administrative Procedures to
assure that Quality Assurance program commitments are met as required by
the licensee's Quality Assurance Manual Operations, APL-TP01A, Revision 5,
dated October 10, 1980.
This situation had been identified by the licen-
see's QA organization which had requested, by memorandum SQA-1008, dated
August 27, 1981, that ANO site QA be included in PSC review of procedures
prior to issue.
Pending institution of a documented system of QA review
of ANO administratlve procedures and QA documentation of the acceptability
of previously issued AN0 administrative procedures, this is considered an
unresolved item.
(313/8134-02; 368/8134-01)
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5.
Licensee Inservice Inspection (ISI) Program
One NRC inspector performed an inspection to determine compliance of the
licensee's inservice inspection program with licensee Techncial Specifica-
tion (T/5) Sections 4.2.2, 4.2.7, and 4.2.8 for ANO, Unit 1.
During the
inspection, an unresolved item from IE Inspection 50-313/78-03 was rein-
spected.
Technical Specification 4.2.2 requires inspection of one RC inlet nozzle
and one core flood nozzle at approximately 3-1/3 years of the 10 year
inspection interval.
During the previous inspection, the licensee had
indicated that a Technical Specification change request to NRR was being
requested to change this requirement.
The licensee, by a letter, dated October 19,.1977, requested a waiver to
this' Technical Specification requirement as well as selected ASME Code
requirements.
As an alternate to this required inspection, the licensee
proposed to " examine 100% of both outlet nozzles by the end of the first
third of the interval from the nozzle bore."
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NRC inspection report 50-313/78-03, paragraph 4.a of an inspection con-
ducted February 7-10, 1978, states, "During review of a selection of
weld examinations scheduled for the current outage (ISI Program Plan
Outage No. 2) it was determined that comparison of the inspection plans
for category D, group 1.4 revealed that there were no plans to examine
one Reactor Coolant Inlet nozzle, and one Core Flood nozzle.
Section 4.2.2 of the Technical Specification requires examination of
one of each of these nozzles after 3-1/3 years of the inspection inter-
val (T/S 4. allows a -25% tolerance on this surveillance interval).
The currently approved ISI Plan schedules these inspections for Outage 8,
which is near the end of the current ISI 10 year interval.
It was also
determined that the T/S specified that inspections of Reactor Coolant
Outlet nozzles should have been scheduled at the 6-2/3 year point in the
inspection interval.
Instead these nozzles were scheduled for inspection
at the 3-1/3 year point, and were not subsequently scheduled later in the
inspection interval.
By letter dated October 19, 1977, a change to the
Technical Specifications has been proposed by AP&L to the NRC; however,
it has not been approved.
This item is considered unresolved pending
expiration of the tolerance on the surveillance interval, or approval
of a T/S change to 41ete the current requirements."
Jn a letter, dated April 20, 1978, the NRC granted interim relief from
ASME Section XI inservice inspection (testing) requirements.
This
letter specifically stated that the licensee was " authorized to, and
should proceed to, implement your proposed program (except where your
current Technical Specifications are more restrictive)." This letter
further states, "During the period between the date that the require-
ments of 10 CFR 50.55a(g) become effective for your facility and the
date we complete our detailed review of your submittal you must comply
with both your existing Technical Specifications and your proposed
inservice inspectica and testing program.
In the event conflicting
requirments arise for some components, you must comply with the more
restrictive requirements (e.g., shorter inspection intervals, increased
number of parameters measured).
In other words, the granting of this
relief from '%E Code requirements should not be interpreted to give you
relief from any of the requirements in your existing Technical Specifi-
cations."
During refueling Outage 2, the licensee inspected only two reactor vessel
outlet nozzles as proposed in licensee letter, dated October 19, 1977.
The NRC letter, dated April 20, 1978, had stated that the licensee "must
comply with both your existing Technical Specifications and your proposed
inservice inspection and testing program." The licensee was able to
examine only 80% of both outlet nozzles in lieu of 100% as proposed in
licensee letter, dated October 19, 1977.
As a result, the licensee issued
a letter, dated January 10, 1979, modifying their request for waiver in
their October 19, 1977, letter to " examine 80% of both outlet nozzles
by the end of the first third of the interval from the nozzle bore,"
in lieu of the 100% examination originally proposed.
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In this letter, the licensee neither identified the fact that they
were not complying with both existing Technical Specifications and
their proposed inservice inspection and testing program as required
by the NRC letter, dated April 20, 1978, nor again requested a waiver
of existing Technical Specification requirements or final approval of
their original proposal.
NRC, by letter, dated March 8, 1979, approved tne requested reduction
in the Code inspection requirements from 100% to 80L
That this was
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all NRC granted is evident, both in the Safety Evaluation ard the Notice
in the Code of Federal Regulations, which are the bases for the approval.
Approval of the proposed change to the licensae's Technical Specifications
has not been granted by the Office of Nuclear Reactor Regulation.
In a' letter, dated September 13, 1978, NRC requested additional infor-
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mation concerning the licensee's October 19, 1977, letter and specifi-
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cally the core flood nozzle safe end welds.
This letter was answered
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in part by meetings held on November 15 and 16,1978, and in part by
licensee letter, dated December 15, 1978.
These facts verify that at
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this time the licensee was aware that a waiver of the requirements of
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Unit 1 Technical Specification 4.2.2 had not been granted.
Failure of licensee personnel to perform inservice inspection of one
reactor vessel inlet nozzle and one core flood nozzle at approximately
3-1/3 years in the inspection period as required by Technical Specification 4.2.2 constitutes a violation.
This closes the unresolved
item in inspection report 78-03.
(313/8134-01)
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6.
Maintenance
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The NRC inspector reviewed the licensee's maintenance program by
selectively examining administrative procedures, Quality Control proce-
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dures, completed job orders, and records to determine:
a.
That, during maintenance on safety-related systems, all license
limiting conditions for operation were met.
b.
That maintenance activities on safety related systems were properly
approved, performed, inspected, tested, and documented.
c.
That reporting requirements for the selected maintenance activities
had been met, if applicable.
The following maintenance activities were-reviewed:
Job Order 1-5507-80-3
C/0 and repair HPI CV-1227
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Job Order 1-5507-80-4
Check HPI CV-1227
Job Order 13508
C/0 Pump P7A overspeed trip
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Job Order 16065
Repair Pump P7A overspeed trip
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A review of the licensee's computer listing of active and backlog job
orders indicated that an excessive backlog had developed.
Subsequent
discussion with licensee representatives revealed that, in their opinion,
this backlog was due to a recent outage and was being worked off.
The
NRC inspector voiced a concern that the licensee appears to be diluting
his own priority rating system since a number of priority one jobs were
aged from one week to seven months, and that completion of this work did
not appear to rate the urgency assigned to priority one as defined by
the licensee's own procedure.
This condition could lead to the loss of
urgency that should properly be associated with corrective maintenance
on safety-related systems and equipment.
The licensee stated that a
revision to the maintenance procedure, presently being processed, should
solve this problem.
No violations or deviations were identified in this area.
7.
C_cmponent Cyclic or Transient Limits (Data / Records)
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During review of the licensee's Unit 2 " Record of Significant RCS Operating
Transients" for the third quarter of 1981, dated October 12, 1981, it was
apparent that-two events were not included in the cumulative number of
The two events were turbine trips with delayed reactor trips
that occurred on April 7, 1980, and June 24, 1980.
Further records review
disclosed that they were included in both the reactor trip from 100% and
loss of reactor coolant flow at 100% categories.
Paragraph 5.2.1.5 of the FSAR defines design transients and Technical
Specifications, paragraph 5.7 cites Table 5.7-1 for component cyclic or
transient limits.
Subsequent discussions with plant personnel revealed
that definitions presently applied for classification of events are not
adequate and do, in fact, require clarification.
The licensee has
committed to define in sufficient detail the transient types to allow
correct categorization of the events.
The NRC inspector did not have
adequate time to review Unit 1 procedures and records. The NRC inspector
has determined that this item will remain as an unresolved item for both
units pending further action by the licensee.
(313/8134-03; 368/8134-02)
8.
Unresolved tems
Unresolved i hms are matters about which more information is required in
order to ascartain whether they are acceptable items, violations, or
deviations.
Unresolved items are discussed in paragraphs 4 and 7 of this
report (Quality Assurance Review of ANO Administrative Procedures and
Component Cyclic or Transient Limits (Data / Records)).
9.
Exit Interview
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Exit' interviews were conducted on December 16 and 17, 1981, with those
Arkansas Power and Light Company personnel denoted .in paragraph I of
this report.
At these meetings, the scope of the inspection and the
findings were summarized.
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