ML20154S161

Insp Repts 50-313/88-26 & 50-368/88-26 on 880815-0902.No Violations Noted.Major Areas Inspected:Program for Design Changes & Mods,Reactor Coolant Pump Pressure Sensing Line Failure & Inservice Insp Activities

ML20154S161
Person / Time
Site:	Arkansas Nuclear
Issue date:	09/27/1988
From:	Barnes I, Ellershaw L, Gilbert L, Renee Taylor NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20154S148	List: ML20154S145 ML20154S158 ML20154S161
References
50-313-88-26, 50-368-88-26, NUDOCS 8810040457
Download: ML20154S161 (17)

See also: IR 05000313/1988026

Text

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APPENDIX B  !

U.S. NUCLEAR REGULATORY C0m !SS10N

REGION IV

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NRC Inspection Report: 50-313/88-26 Operating Licenses: OPR-51

50-368/88-26 NPF-6 ,

Dockets: 50-313 i

50-368 l

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Licensee: Arkansas Power & Light Company (AP&L)

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Facility Name: ArkansasNuclearOne(ANO), Units 1and2 [

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Inspection At: ANO, Russellville, Arkansas {

Inspection Conducted: August 15 through September 2, 1988

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Inspectors: 9 19

. E. Ellershaw, Reactor Inspector, Materials D4te  ;

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and Quality Programs Section, Division of

Reactor Safety

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1. 1. U. GMbert', Reactor Inspector, Materials Fate / i

and Quality Programs Section, Division of

Reactor Safety g

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. G. Taylor, Reactor Inspector, Materials and

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and Qt/ality Programs Section Division of

Reactor Safety i

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Approved: he nas JAt/sr >

s. Barnes, Chief, Materials and Quality Date i

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Programs Section. Division of Reactor Safety [

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Inspection Surrriary

Inspection Conducted August 15 through September 2, 1988 (Report 50-313/88-26;

368/88-26)

Areas Inspected: Routine, unannounced inspection including the program for

design changes and modifications; design changes and modifications - reactor

coolant pump pressure sensing line failure; inservice inspection activities for

Unit 1; selection of welding and nondestructive examination processes in

design change activities; and an annual review of the quality assurance

program including audits, the control of procurement, and receipt, storage,

I and handling of components and materials.

Results: Within the eight areas inspected, four violations (failure to revise

procedures to reflect the abolishment of an organization performing design

change functions, paragraph 2; failure to submit a relief request to the NRC

when required, paragraph 4.a; failure to have a procedure for conduct of QA/QC

receiving inspections, paragraph 6; and failure to have a qualification file

for an auditor of record, paragraph 7) were identified.

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DETAILS

1. Persons Contacted

APAL Personnel

f*J. M. Levine Executive Director, Nuclear Operations

• L. W. Humphrey, General Manager, Nutlear Quality (NQA)

1. • R. D. Lane, Plant Engineering Manager

• R. Wewers, Work Control Center

• J. Connors, Modifications Group

1. • D. B. Lomax, Plant Licensing Supervisor

1. • P. L. Michalk, Plant Licensing

1. • H. T. Greene, QA Superintendent

• G. T. Jones, General Manager, Design Engineering

W. A. Faton, Manager of Mechanical, Civil and Structural Design

ingineering

i G. D. Provencher, QA Audit and Surveillance Group Supervisor

W. Michalk, Plant Engineer

J. M. Ray, QA Engineer

1. D. R. Howard, Licensing Manager

1. J. '.. Taylor-Brown, Quality Control (QC)/ Quality Engineering (QE)

Superintendent

1. B. A. Baker, Manager Plant Modifications

i E. C. Ewing, General Manager Plant Support

1. W. M. Butzlaff, QA Engineering Supervisor .

D. R. Payne, inservice Inspection Coordinator F

M. W. Hall, Welding Engineer  ;

G. M. Goodson, Supervisor Project Engineering

B. M. Durst, Superintendent of Project Engineering

NRC Personnel

• R. C. Haag, Resident inspector i

1. W. D. Johnson, Senior Pesident Inspector

The NRC inspectors also interviewed other licensee and contractor

personnel during the inspection.

• Denotes those persons that attended the exit interview on August 19,

1988.

1. Denotes those persons that attended the exit interview on Septeaber 2, !

1988.  !

2. Design Changes and Modifications Program (37702)

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The purpose of this area of the inspection was to ascertain whether the

licensee is implementing a QA program for the control of design changes

and modifications that is in conformance with NRC requirements and the  ;

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consnitments contained in the Safety Analysis Reports for the AN0

facilities. The appare'It primary document that broadly defines the

overall program is Generation and Transmission Major Program Number 20

"ANO Plant Modifications Manual." Appendix C to this document provides an

activities flow chart that begins with problem identification and culminates

in implementation of a Design Change Package (OCP). The flow chart

indicates that five different organizations within the licensee's overall

nuclear organization are involved in one or more aspects of the program.

The implementing procedures that flow from the program manual indicate

that the engineering group could be either Little Pcc.k General Office

Engineering or Plant Engineering, the latter group veing located onsite. t

The NRC insr tor initially identified eight procedures in the engineering

area " or 'de substantial detail on how the program is to be implemented.

The ).. ~n9 procedures were reviewed in detail by the NRC inspector:

o Procedure 1000.103, "Plant Modification Process Procedure,"

Revision 2, dated September 23, 1987

o Procedure 1032.01, "Plant Engineering Action Requests and Plant

Changes," Revision 9, dated November 16, 1987 ,

o Procedure 6000.10 "Design Control Process," Revision 0, dated

April 15, 1987

, o Procedure 6010.001, "DCP Developement," Revision 0, dated

November 16, 1987

o Procedure 6000.20 "Design Document Control," Revision 3, dated

August 25, 1988

o Procedure 6000.30. "Control of Installation," Revision 1, dated

July 24, 1988

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o Procedure 6030.01, "Installation Plan," Revision 2, dated July 23,

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o Procedure 6030.002, "Field Change Request (FCR) Preparation and

Control " Revision 3, dated August 16, 1988

o Procedure 6030.100, "Modification Implementation Procedure Program,"

Revision 0, dated December 7, 1987

The above procedures also reference a number of other procedures,  ;'

generally in relation to departments other than engineering

1 that are involved in the design change and modification processes. The

NRC inspector reviewed the following of the many referenced procedures in

less detail since they largely ar, eared to involve an organization

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entitled Nuclear Services that h w little apparent involvement in the

generati9n of enginaering requirements for plant changes: ,

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o GTEP-201, "Design Change Initiation and Control," Revision 16

o GTEP-202, "Design Process Procedure," Revision 10

o GTEP-203, "Document Preparation, Change and Review," Revision 7

o GTEP-204, "Design Deficiency / Corrective Actlon," Revision 6

The flow chart and the procedures indicate a very complex program that

requires many checks and balances by several different groups. Several of

the checks and balances are utilized to assure that any given change is

warranted, will be safe, and is feasible. Other checks involve financial

considerations and scheduling. It appeared during the initial review that

the Nuclear Services organization played a very substantial part in the

overall program. During discussions of the complexity of the program with

the NRC Senior Resident Inspector, the NRC inspector learned that the

Nuclear Services organization had been abolished early in 1988. An

interview with the General Manager of Design Engineering established that

Nuclear Servires had been abolished during a major reorganization in which

nuclear related engineering activities were transferred from the

Generation and Transmission Engineering group to a Nuclear Operations

group. The reorganization was said to have been undertaken because

nuclear related engineering actions were not provided with sufficient

priority in the earlier organization. The General Manager indicated that

the functions and responsibilities of the Nuclear Services group had been

reassigned to other groups. He further stated that it is intended that

the procedures for design change and modification control will be revised

and streamlined at a future time, such as by the end of 1989. The NRC

inspector was provided with copy of a memorandum dated March 11, 1988,

which stated that it was an update of the summary of disposition of

Nuclear Service functions due to the reorganization. It was not

determined during any subsequent discussions just what was being updated

nor did the reassigned functions in an attachment to the memorandum

directly connect with any identified existing procedure. Since the

procedures for control of design changes and modifications were complex

and difficult to follow as they existed before the reorganization, the

situation has been compounded by the reassignment of functional activities

inherent within the procedures by memoranda that are not relatable to

the procedures. The NRC inspector would note that output product of the

design change process, the DCPs, appear to be quality products that are

consistent with NRC requirements. It appears that the licensee has

violated the intent of Criteria 1, II, and V of Appendix B to 10 CFR

Part 50 by failing to revise the procedures listed above, as a minimum,

when the reorganization mentioned earlier took place. (313/8826-01;

368/8826-01)

3. Design Changes and Modifications - Reactor Coolant Pump Pressure Sensing

Lint Failure (37700)

The purpose of this area of the inspection was to verify that the licensee

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has properly reviewed and analyzed a series of design changes implemented

during the period of August 1-15, 1988, with due consideration to the

requirements of 10 CFR 50.59. The design changes involved were related to

an incident that occurred on or about August 1, 1988, in which a small

instrument line originating on the Reactor Coolant Pump "A" seal cartridge

in Unit 2 severed. Following the severance, reactor coolant leakage of an

estimated 40 gallons per minute occurred, but was fully contained within

the reactor building.

The following is a brief description of the principal piping and tubing

associated with the reactor pump seal provided to assist in understanding

the balance of the information provided herein. Each of the four reactor

coolant pumps is provided with a seal cartridge secured to the pump casing

through which passes the prime mover shaft connection to the pump

impeller. Each cartridge has four external connections that do or could

see full reactor operating pressure of 2250 psig. Each of the four

connections has a 1/4-inch orifice within the seal casing to restrict any

coolant outflow in the event that one of the connecting lines should fail.

The 1/4-inch orifice will restrict any such unintended outflow to a

calculated 37 gallons per minute at full reactor operating pressure. Each

of the connections to a cartridge is made of 3/4 inch, schedule 160

stainless steel pipe. The highest normal pressure connection is

associated with seal injection inlet water which is provided only during

initial filling and venting of the reactor. The pressure involved is

whatever the reactor pressure is at a given stage of system startup. The

next two lines, which operate at approximately 2/3 and 1/3 of reactor

pressure respectively, provide a means of sensing the pressure between the

seal stages to allow the operators to assess the performance of each

stage. These particular lines leave the cartridge as indicated above but

are then reduced to 3/8-inch tubing for the balance of their runs to their

respective instruments. The final line is a controlled bleedoff line

which normally operates in the 50 to 100 psig range at about one gallon

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per minute flow.

The line which severed was one of the two pressure sensing lines from pump

"A" cartridge. The severance occurred in the 3/8-inch tubing immediately

adjacent to a fillet weld securing the tubing to the pipe through an

adapter. A licensee metallurgist reported that, in his opinion, the

l appearance of the metals was typical of vibration induced fatigue failure.

Licensee 'iata indicated a long history of problems with the above

connecting lines to the seal cartridges, beginning shortly after the

original startup of ANO-2 facility. It was noted that pump "D" had never

experienced any of the reported problems. The balance of the problems

l ere primarily shared between the "A" and "B" pumps except for the

repetitive cracked welds in the seal injection line to the "C" pump.

Priar to the recent incident outlined above, none of the problems had

resulted in severance of either a pipe or tube and generally involved

cracked welds in the 3/4-inch piping or at the junction weld to the

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The licensee apparently had determined that the only reasonable course of

action in response to the above incident would be to attempt to absorb tne

vibration in the lines and tubing to some degree, since he could not

eliminate the vibration at its source. Such vibrations are inherent to

varying degrees with large rotating machinery such as the pumps. Toward

that end, the licensee generated three Plant Change (PC) documents and a

DCP to make modifications to various lines either in the configuration of

line or in the supports'of the lines. The NRC inspector reviewed each of

the changes, as listed below, to assure that the changes met NRC

requirements.

o PC 88-2538: This change affected two sensing lines on the "A" pump

and one on the "B" pump. The changes essentially involve the

installation of an 18 inch, four turn coil of tubing in place of the

previous tubing configuration. One end of the tubing coil is clamped

to a structural, nonvibrating beam with the other end connected to

the associated pipe through a compression type tubing adapter, as

opposed to previously used welded connection.

o PC 88-2608: This change affected the remaining sensing line on the

"B" pump. The licensee history data indicated that the line in

question generally had experienced problems at a tubing bend

innediately adjacent to the tube-to-pipe transition with distress of

the tubing in the bend or at the weld. The modification installed a

pipe elbow to replace the tubing i 1d. The now straight tubing was

again connected to the pipe via a ,ompression fitting. The tubing

run was also rerouted to provide the ability to absorb the vibration

as well as the thermal movement of the pump assembly,

o PC 88-2666: This change was made to a pipe support on one of the

3/4-inch lines on the "A" pump that was observed to be restricting

thermal movement of the pump assembly.

o DCP 88-2083: This change affected the supports for the seal

injection line to "C" pump that had experienced repetitive cracked

welds. The support scheme was changed to provide more support to the

vent valve arrangement near the middle of the pipe run. The cracks

which had been experienced were at the welds of the tee branch in the

line where the vent valve arrangement attaches.

In addition to the above engineering changes, the licensee, through his

maintenance procedures, applied weld overlays on 37 fillet welds in the

3/4-inch lines on all four pumps. The overlays were applied to those

welds, based on engineering inspection, that had configurations that

increased the concentration of stresses at the weld too interface with the

pipe. Typical would be the case were some weld convexity exists which

provides a sharper angled interface. The licensee, in conjunction with

, personnel from the NUTECH Corporation and Wylie Laboratories, instrumented

selected lines in "C" and "0" pumps to obtain information on the frequency

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estimates of the probable life of vibrating components. The test data

indicated stress levels and frequencies such that lines would have a

predicted life of approximately 20 years. The tests were made after the

support modifications to the "C" pump line that had the previously mentioned

failure history.

The NRC inspector questioned the use of the compression type tubing

fittings in the engineering changes applied to the "A" and 'B" pumps since

industry experience with such fittings in locations of vibration has not

been acceptable. One of the principal manufacturers has cautioned against

the use of their product in such environments. The licensee provided the

NRC inspector with data from the Parker Hannifin Corporation which indicated

that their brand of fittings known as Parker-CPI were more suitable than

fillet welded connections and other brands of compression fittings in

regard to acceptance of vibration due to the design of the ferrule system

inside the fitting. The licensee's engineer stated that he had

substantial telephonic comunication with Parker Hannifin engineers who had

indicated good broad industry experience with the fittings in vibrating

environments. The licensee also had documentation of a vibration test

performed for Parker Hannifin utilizing a simulation of several different

tubing sizes and materials in typical installations. The mockup was

placed on a vibration table and cycled at different amplitudes and

frequencies for approximately 5 million cycles. The test report indicated

. that where copper tubing was used the simulations failed, but those

installed with stainless steel tubing in the size involved at ANO

survived the test. The NRC inspector did note that the tubing used in the

test was of a lighter wall and was not carrying a pressure during the test

consistent with the application at ANO. The design change documentation

did not include an evaluation of the effect these differences might have

on the life of the fittings.

The NRC inspector also questioned the use of the tube coil arrangement,

since the Bechtel standard design drawing from which they were derived

indicated that the coils were one of the standard methods for accepting

thermal movements without overstressing the components. The standard

drawings, however, made no trention of their tolerance to vibrational loads.

The NRC inspector interviewed a plant engineer that was identified as

having had a major role in the installation of the above changes. The

engineer offered that he had observed the behavior of the coils with the

pumps running and was confident that the coils would absorb the vibration

for at least a substantial period of time. The engineer stated that both

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the coils and the compression fittings were only expected to last until

the next refueling outage for the unit. The present plan of the licensee

is to replace all of the lines at that time with high pressure flexible

hoses, which by experience at other nuclear power stations, has been

shown to be a successful solution to the vibration problem with the

reactor coolant pumps. The licensee's Executive Director of Operations

confirmed that the information obtained from the engineer was correct.

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The NRC inspector did not identify any violations of NRC requirements

(since the facility design basis and Technical Specifications are

unchanged), or deviations from the licensee's commitments during the

inspection of the above activities. J

4. Inservice Inspection l

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a. Review of Program (73051) l

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The NRC inspector reviewed the licensee's program pertaining to the l

inservice inspection (ISI) of Unit 1 for the second 10-year interval.  ;

NRC approved the second 10-year ISI plan on January 13, 1986, for the  ;

interval of December 19, 1984, to December 19, 1994. The following  ;

documents were reviewed for conformance with the requirements of l

10 CFR Part 50a(g) and ASME Boiler and Pressure Vessel Code,  ;

Section XI, 1980 Edition and Addenda through Winter 1981: i

l o ISI Program Requirements Procedure No. 1092.25, Revision 1

o ISI Technical Manual for Arkansas Nuclear One-Unit 1. Volume 2,

Revision 4

To verify confonnance with the examination requirements specified in

the ISI Technical Manual examination plan, the NRC inspector reviewed

the records of ultrasonic examinations perfonned on the reactor

vessel head to flange weld. The extent of the examination was

clarified by the examination records. The NRC inspector noted that a

limited examination was reported for ultrasonic examination of the

vessel head-to-flange weld. The weld, as reported in Examination 02-001

for the second 10-year interval, could not be ultrasonically examined

from at least one direction as required by paragraph T-441.5 of

Section V of the Code. Examination 02-001 reported that the percentage

of examination performed was 50 percent because of obstruction from

lifting lugs, superstructure, and flange configuration. These same

limitations were reported for the ultrasonic examination of this weld

during the first 10-year interval. The licensee indicated that

limited examinations were not submitted as relief requests, even

though it was determined that conformance with certain code requirements

was impractical. This is an apparent violation of 10 CFR Part

50.55a(g)(5)(iii) for failure to obtain relief from NRC where the

licensee has determined that conformance with certain code

requirements is impractical. (313/8826-02)

b. Review of Procedures (73052)

The NRC inspector reviewed the following Babcock & Wilcox (the

contractor performing the ISI) procedures:

o Administrative Procedure for the Written Practice of Personnel

Qualification in Liquid Penetrant Examination,151-22

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o. Administrative Procedure for Processing Nondestructive

Examination Data, ISI-69, Revision 16

o Technical Procedure for Sulfur Content Analysis, 151-55,

Revision 3

o Technical Procedure for Halogen Content Analysis, 151-56,

Revision 2

o Ultrasonic Examination of Piping and Vessel Welds Joining

Similar and Dissimilar Materials, 151-120 Revision 25

o Ultrasonic Examination of Vessel Welds and Nozzle Inside Radius

Sections, 151-130, Revision 24

o Penetrant Examination of Welds and Base Materials, including

Studs and Nuts, 151-240, Revision 20

o Wet or Dry Method of Magnetic Particle Examination of Welds,

Studs, Bolts, and Pump Motor Flywheels, ISI-270, Revision 21

In the areas reviewed, the procedures were consistent with the

requirements specified in Section XI of the ASME Boiler and Pressure

Vessel Code.

5. Welding and Nondestructive Testing Activities Related to Plant

Modifications (55050, 57060, 57070, and 57090)

The NRC inspector selected the following design change packages for review

for the purpose of determining whether proper considerations had been

applied to the selection of welding processes and nondestructive

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examination of welds to be made during plant modifications:

o Design Change Packages

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DCP 85-1022, ANO-1 Containment Sump Drain Valve and Operator

Replacement

DCP 87-1101, CV-1221, Letdown Isolation Valve Replacement

DCP 86-1106, Pressurizer Spray Line Modification

l DCP 87-D-1013, Service Water System-Piping and Valve Replacement

The following welding and nondestructive examination procedures were

identified within the above packages for use in field work associated with

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the modifications:

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o Welding Procedures (55050)

WPS P8-T-Ag, Revision 6

WPS P8-AT-Ag, Revision 5

o Nondestructive Examination Procedures (67060, 57070 and 57090)

ANO Volumetric United States Testing Examination, Procedure

No. 1402.172 Revision 0

ANO Surface United States Testing Examination, Procedure

No. 1402.171, Revision 0

Within the design change packages reviewed, the welding and nondestructive

processes and procedures selected were appropriate for the modifications

involved. Each procedure was consistent with the requirements of ASME

Code Section IX for welding and Section V for nondestructive examination.

No violations or deviations were identified.

6. Annual Quality Assurance Program Review (35701)

The purpose of this area of the inspection was to verify that the o,1 going

implementation of the QA program is in conformance with Technical

Specifications, regulatory requirements, and comitments and inductry

standards.

The licensee's quality program description is contained is the QA Manual

Operations which forms a part of the Updated Safety Analysis Raoorts for

both Units 1 and 2 by reference. Revisions to the QA Manual Operations

are submitted on an approximately annual basis for NRC review and approval.

The current docketed revision is Revision 9. The NRC inspector obtained a

copy of Revision 8 for the purpose of determining the extent and nature of

the changes made in Revision 9, as indicated by the change bar indicators,

and whether the changes had been reflected in the licensee's implementing

procedures. This review indicated that nearly all of the changes had

occurred as a result of the creation of the position of Executive Director

of Nuclear Operations. The NRC inspector then reviewed licensee's various

QA/QC procedures to determine the extent and nature of changes made to the

implementing procedures since the previous annual review during August 1987

(IR 50-313/87-23;368/87-23). This review established that a total of 28

procedures had been revised during the past year. The NRC inspector

reviewed all of the revisions except for 12 procedures which are detailed ,

procedures for the conduct of audits in specific areas. Several of the

audit procedures were subsequently reviewed during the inspection of the

licensee's audit program as discussed below. Most of the changed procedures

were revised to reflect minor titular changes both in the QA/QC and other

organizations. The most significant changes are briefly discussed as

follows:

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.o NQA-10. "Deficiency Trending," revised to add a second level of action

where trends of little safety significance are identified in audits

and inspections,

o QAO-5, "Vendor / Contract Surveillance," revised to add surveillance of

onsite contractor activities,

o QA0-10. "Corrective Action," revised to formalize a management

escalation process for QA/QC findings.

The NRC inspector noted during the review that Procedure QCO-5, "Purchase

P.ecuisition Review, Receipt inspection, and Independent Material Test," was

incicated has having been deleted from the program on or about July 21,

1988. Further examination indicated that the procedure had been replaced

by Procedures QA0-2, "QA Review of Procedures and Documents," and QA0-11

"Receipt Inspection and Independent Testing." It was found, however, that

the latter procedure had, as of the end of this inspection, not been

issued nor was it clearly established when it would be, since it is

understood that administrative issues are involved that are holding up

approval. It is understood that the reason for the cancellation of

QCO-5 was the reassignment of the entire function from the QC group

to the QA group. Based on an interview with the involved personnel, it

appears that the same personnel are currently doing the same functions in

the same manner as they had before the cancellation. The licensee has,

however, apparently been in violation of Criterion V of Appendix B to

10 CFR Part 50 for a period of approximately 5 weeks since it did not have

an approved procedure issued for the performance of the QA/QC receiving

inspection activities. (313/8826-03;368/8826-03)

The NRC inspector also reviewed the qualification records for persons that

had replaced other persons as supervisors since the last inspection.

These were the positions of:

o Quality Assurance Superintendent

o Quality Control Engineering Supervisor

o Quality Control Inspection Supervisor-Modifications

o Quality Assurance Supervisor-1.RGO

l Each of the incumbents were found to be well qualified based on Regulatory

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Guide (RG)1.58,"QualificationofNuclearPowerPlantInspection,

Examination, and Testing Personnel."

Except as noted, no violations or deviations were identified in this area

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7. Audit Program Review and Audit Program Implementation (40702 and

40704)

The purpose of this area of inspection was to ascertain whether the '

licensee has developed and is implementing a quality assurance program

relating to audits of activities that is in conformance with the Technical

Specifications, regulatory requirements, and commitments in the Safety

Analysis Reports for Units 1 and 2.

The NRC inspector reviewed the following documents in relation to the

licensee's audit program:

o Unit 1 Technical Specification, Amendment 99, and Unit 2 Technical i

Specf.fication, Amendment 73. Paragraph 6.5.2.8 of both documents ,

l defines those elements of operational activities that are to be '

I audited and at what frequency.

o Section 18.00, "Audits," Revision 8, of the Quality Assurance Manual

Operations

o Procedure QAO-9, "Internal QA Surveillance," Revision 2, dated

July 26, 1988

o Procedure QAO-6, "Internal Audits," Revision 3, dated July 11, 1988

o Procedure NQA-2, "Indoctrination and Training of Nuclear Quality

Personnel," Revision 0, dated April 20, 1987

o Procedure QAO-1, "QA Personnel Qualification, Certification and

Training," Revision 1, dated April 15, 1988

The procedures identified above outline a broad audit program which

involves the formal audits as identified in the Technical Specifications

and a surveillance program with the QA personnel observing actual ongoing

work activities in a planned, systematic manner. The surveillances, when

coupled with the formal audits, should provide a complete picture of the

compliance of any given activity with the requirements for that activity.

The formal audit program is based on RG 1.144, "Auditing of Quality

Assurance Programs for Nuclear Power Plants. The requirements for the

qualifications of personnel are based on RG 1.146, "Qualification of

Quality Assurance Audit Personnel for Nuclear Power Plants."

The NRC inspector selected six records of audits performed during the past

year. The audit reports as identified below were reviewed in conjunction

with the applicable audit procedure which is the audit report number less

the year suffix:

o Audit QAP-180-88, "Unit 2 Instrumentation," conducted June 16 through

July 8, 1988

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o Audit QAP-4-87, "Training," conducted April 27 through August 19, 1987

o Audit QAP-6-87, "Procurement / Materials Control," conducted March 17

through July 1, 1987

o Audit QAP-15-87, "Control of Measuring and Test Equipment," conducted

July 22 through December 15, 1987

o Audit QAP-18H-88, "Unit 2 Tech. Spec. Audit," conducted January 21

through April 22, 1988

o Audit QAP-10-88, "Corrective Action," conducted June 29 through July 26,

1988

Each of the audits resulted in either Audit Findings (AFRs) or audit

recommendations or both. The former are findings which identify that some

element of a requirement has not been complied with, while the latter are

auditor observations that some element stands in need of improvement.

Most of the AFRs and recommendations had been acted upon within the time

frames requested by QA. The NRC inspector did note that two AFRs from

QAP-4-87 were still open nearly a year after they were issued. AFR 506

reported that management required Position Task Analyses for certain

positions had not been issued, while AFR 507 reported that training

requirements for persons in supervisory Health-Physics aositions were not

being conducted as required. The delays in responding lad been requested

and approved in both cases.

During the review of the audit reports, the NRC inspector noted the

identification of the auditors involved in each audit. Nine auditors in

all were involved. The NRC inspector reviewed the auditor qualification

files on eight of the auditors and found that all had experience, education,

and training sufficient to meet the requirements of Procedure QA0-1 and

RG 1.146 as either a lead auditor or as an auditor. The file for the

ninth person could not be located by the licensee and therefore no

assessment of that persons qualifications could be made. The failure to

have a training and qualifications file for an auditor is an apparent

violation of Criterion XVII of Appendix B to 10 CFR Part 50. (313/8826-04;

368/8826-04)

8. Procurement Program (38701)

The NRC inspector reviewed the following documents to verify that

administrative controls exist and that they provide measures to assure

that necessary technical and quality requirements are includcd in

procurement documents for safety-related items or services. The documents

were also reviewed to verify that controls exist for the selection,

approval, and use of vendors. These documents were further reviewed to

assure that responsibilities for implementing the established measures

were delineated in writing.

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Title Document No. Revision Date

Arkansas Nuclear One Unit 1

Updated Safety Analysis

Report. Section 1.6 Amend. 4 10/15/86

QA Manual Operations Section 4.0 9 7/22/87

Nuclear Procurement ESP-213 0 3/30/86

Control of Procurement 1000.00 14 9/22/87 i

Control of Procurment

Process (for Plant

Modifications) 6000.50 1 11/5/87

Purchase Requisition

Preparation & Control 1000.11 23 1/28/88

Procurement Technical

Assistance 1032.006 10 2/22/88

Plant Engineering Action

Requests and Plant

Changes 1032.01 9 10/1/87

To assess the implementation of these documents, the NRC inspector

selected the following purchase orders and components, and verified that

documented evidence was available to support the conformance of th6 items

to the requiremonts of the procurement documents. It should be noted that

all of these items had been procured for implementation of design

changes / modifications scheduled to be performed during the current outage

of Unit 1. All of the design changes / modifications are controlled by

' DCPs of which two were reviewed by the NRC inspector (DCPs 87-1013 and

87-1042) and are noted with the applicable items listed below. These

packages were reviewed to assure that: (1) all required approvals had

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been obtained; (2) responsibilities had been established to implement the

DCP; (3) detailed descriptions of the changes were delineated; (4) affected

drawings and pending DCPs which might affect the design changes were

- identified;(5)designbases, considerations,andcalculationswere

l' addressed and performed, and (6) the methodology was consistent and

appeared to be proper.

Purchase Component Quantity

Order No. Ordered

20544 Durametallic Cartridge

Mechanical Seals 6

Gland Studs 16

Gland Nuts 6

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49957 Synchronism Check Relays 5

179774- 1/8 inch weld rod, SFA 5.27 100 pounds

175232 6-inch SA-312 Pipe 20 lin. ft. OCP 87-1013

4-inch SA-312 Pipe- 220 lin. ft. "

3-inch SA-312 Pipe 340 lin. ft.

"

4-inch SA-403 45' -

"

Elbows 4

3/4-inch SA-182 90 "

Elbows 2

"

3/4-inch SA-182 Tees 5

.1 1/2-inch SA-182 Coupling 2

"

,

4-inch X 3-inch X 3/4-inch " '

SA-182 Sockolet 9

"

3-inch SA-102 Flanae 10

6-inch X 6 inch X l-inch "

SA-403 Tees 1

180746 4-inch X 4-inch X 2-inch A-403

Tees 5 DCP 87-1013

' 181670 1 1/8-inch X 5 3/4-inch

SA-193 Studs 36 DCP 87-1042

"

1 1/8-inch Hex Nuts 72

'

179832 Timing Relays 5

The procurement dates for the above items occurred between May 2, 1986, and

August 15, 1988. While some of the controlling procedures were revised

subsequent to the procurement dates, this had no impact in terms of

performance relative to these purchases. For the above items, the NRC

inspector reviewed all purchase requisitions, purchase orders, and any

applicable revisions for QA review and approval, and verified that

technical requirements were either contained in the text of the document

or referenced. It was also verified that these documents did impose

10 CFR Part 21 and either Appendix B to 10 CFR Part 50 or Subarticle

NCA-3800 of Section III of the ASME Code. The NRC inspector verified

that, with the exception of items on Purchase Order 181670 above which had

not been received, all required supplier documentation had been received [

and that, as a minimum, it complied with the requirements of the purchase '

order. In addition, a review of all material manufacturers certified

material test reports was perfonned of those components listed for

Purchase Orders 179774, 175232, and 180746 above. The qualification  :

package required for the components under Purchase Order 179832 was ,

- reviewed. This information, which included test data sheets, showed that

the components had been environmentally qualified in accordance with

IEEE 323-1974 and seismically qualified in accordance with IEEE 344-1975. t

The NRC inspector verified that the manufacturers from whom these procurements l

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had been made were on the Qualified Vendors List. The procurement program

was found to be effective with respect to meeting the committed

objectives, and no violations or deviations were identified during review

of this area.

9. Receipt, Storage, and Handling of Equipment and Materials Program (38702)

The NRC inspector reviewed the following documents in order to verify that

administrative controls exist, and that they provide measures to assure

that received materials will be examined for conformance with requirements

specified in the procurement documents. The documents were reviewed to

verify that acceptance criteria and responsibilities were clearly

established and that requirements for documenting the performance of

receipt inspections were delineated.

Title Document No. Revision Date

Arkansas Nuclear One

Unit 1 Updated Safety

Analysis Report Section 1.6 Amend. 4 10/15/86

QA Manual Operations Section 7.0 9 7/22/87

Receipt Inspection 1033.01 19 12/21/87

In order to assess the implementation of the program, the NRC inspector

reviewed all applicable receiving inspection documentation associated with

the components identified in paragraph 8 above, except for Purchase

Order 181670, which had not been received. The reviewed documentation

consisted of material receiving reports, receipt inspection instructions,

item acceptance instructions, and recei All of the

documents identify the specific item (s)pt inspection

, the purchase reports.

order number, the

attributes to be inspected and their acceptability, the inspector, and the

date on which the inspector signed the inspection report. With exception

of Purchase Order 181670 (not received), ant the 6-inch pipe on order 175232

(issued for installation), the NRC inspector was able to observe the

storage and identification maintenance of one or more of all of the other

listed components. Material / component issue slips existed for all of the

components which had been issued for installation. The program for

receiving inspection and storage appears to be effective with respect to

meeting the comitted objectives, and no violations or deviations were

identified during review of this area.

10. Exit Interview

'! e NRC inspectors met with the licensee personnel identified in

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paragraph 1 on August 19 and September 2, 1988, to discuss the scope and

findings of the inspection.