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Insp Repts 50-313/86-17 & 50-368/86-18 on 860519-23. Violation Noted:Failure to Have Procedures Requiring Implementation of Vendor Technical Info,Maint Procedures or Engineering Approval to Omit Vendor Technical Info
	ML20203F454
Person / Time
Site:	Arkansas Nuclear
Issue date:	07/09/1986
From:	Boardman J, Hunnicutt D; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	;
Shared Package
ML20203F425	List: ML20203F418; ML20203F437; ML20203F454;
References
	50-313-86-17, 50-368-86-18, NUDOCS 8607310077
	Download: ML20203F454 (9)
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APPENDIX B

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV ,

NRC Inspection Report: 50-313/86-17 Licenses: DPR-51

50-368/86-18 NPF-6

Dockets: 50-313

50-368

Licensee: Arkansas Power and Light

P.O. Box 551

Little Rock, Arkansas 72203

Facility Name: Arkansas Nuclear One (AN0) Units 1 and 2

Inspection at: ANO Site, Russellville, Arkansas

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Inspection Conducted: May 19-23, 986

Inspectors:

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,>rA2A N 7/9 96

J. jt. Boardrhan, Reactor Inspector Dat'e /

Operations Section, Reactor Safety

Branch

Consultants: Luther H. Jores, EG&G

Howard Stromberg, EG&G

Dean Summers, EG&G

Approved By: dhfiunnicutt, Chief,

D.M.

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Operations

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Section, Reactor Safety Branch

Inspection Summary

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Inspection Conducted May 19-2'3, 1986 (Report No. 50-313/86-17; 50-368/86-18

Areas Inspected: A Region IV team inspected licensee maintenance activities

including maintenance program, maintenance program implementation,

instrumentation and control (I&C) maintenance, and electrical maintenance.

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Results: Of the four areas inspected, one violation was identified (failure to

have procedures requiring the implementation of available, reviewed Vendor

Technical Information (VTI), maintenance procedures, or a documented

engineering review and approval to omit the VTI - see paragraph 3).

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DETAILS

1. Persons Contacted

J. M. Levine, Director Site Nuclear Operations

E. C. Ewing, General Manager Plant Support

S. M. Quennoz, General Manager Plant Operations

L. W. Humphrey, General Manager Nuclear Quality

C. N. Shively, Plant Engineering Superintendent

E. Rice, Electrical Supervisor

R. Ashcrcft, Electrical Supervisor

D. B. Lomax, Plant Licensing Supervisor

R. Lane, Manager Engineering

H. Carpenter, I&C Supervisor

J. Roberson, I&C Supervisor

D. A. Saunders, Mechanical Engineering Supervisor

S. J. Remer, Work Control Center Engineer

D. N. Bennett, Plant Engineer

C, A. Halbert, Mechanical Engineering Supervisor

J. Holt, EQ Engineer

J. P. Hale, Modification Management (Bechtel)

D. Provencher, Quality Engineering Supervisor

J. George, Engineering

G. Hewerts, Maintenance History

T. Coggins, Plant Engineering

J. C. Garrett, Materials Management Superintendent

R. West, T&C Supervisor

M. K. Bishop, Coordinator, Project Group

P. L. Campbell, Plant Licensing Engineer

M. C. Cole, Surveillance Test Coordinator

R. M. Cooper, QA Engineer

P. Jones, I&C Superintendent

R. J. Huggins, Supervisor, Project Group

R. M. McFarland, QC Supervisor

W. C. McCord, QC Supervisor

R. J. Rousselle, QC Engineering Supervisor

E. Riddle, PM Coordinator

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L. W. Schempp, QC Superintendent

I D. C. Whiting, Mechanical Maintenance Supervisor

V. Pettus, Mechanical Maintenance Superintendent

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R. Simmons, Planning and Scheduling Supervisor

M. Browning, Mechanical Maintenance Engineer

S. Yancey, Mechanical Maintenance Supervisor

G. Teter, Operations

t M. Hambright, Assistant Stores Supervisor

The NRC inspector also interviewed additional licensee personnel during

the inspection.

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2. Licensee Maintenance Program

The NRC inspector reviewed the licensee's maintenance program. The

results of the review are documented below,

a. Quality Control Hold Points

A concern was noted. Currently, there are 46 procedures which have

QC hold points out of a total of 907 safety-related maintenance

procedures. This is 5.1 percent of the safety-related procedures

sampled. Compared to other plants inspected, this is a low

percentage. Cognizant QC personnel were interviewed. They indicated

that an additional 54 procedures had been revised to include QC. hold

points. Also, 80 other procedures remain to be reviewed to determine

the need for hold points. The review of these 80 procedures

completes a 100 percent review of all safety-related procedures for

QC involvement.

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The licensee provided a computer printout of safety-related job

orders. There were 1615 job orders on the printout. Two hundred

sixty-four of these required QC involvement. This provides 16.3

percent coverage of safety-related job orders.

Interviews with QC personnel revealed that a QC surveillance program

existed which contains schedules, checklists and reports. The

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schedules require QC surveillance of maintenance and surveillance

l tests each month.

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b. Review Scope

The following areas were reviewed to ensure compliance with

applicable regulations, and committed codes and standards.

Welding program.

QC and NDE inspection. .

Administrative and lower tier procedures.

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Cleanliness and Housekeeping procedures.

Technical Specification change implementation.

Preventive maintenance program controls.

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! No violations or deviations were identified.

c. Procedural Inadequacies

The NRC inspector reviewed licensee procedures to verify the

incorporation of Vendor Technical Information (VTI) which is

available on site, separate from programs to accomplish a response to

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NRC Generic Letter 83-28, Section 2.2.2. The example selected was

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the mechanical emergency feed water pump Terry turbine.

l The NRC inspector could find no PM procedures for manufacturer

specified PM, such as the annual replaceriant of oil filter elements,

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retorquing of turbine bolting, or the 5-year complete internal

inspection. There was no documentation that these PM's have been

performed. In the case of oil filter elements, licensee, material

control and warehousing, personnel identified that no elements were

on site until 1984, and none of the elements on site had been issued.

The NRC inspector further determined that no licensee procedure

existed requiring incorporation of available VTI in appropriate

Ticensee administrative or PMs, or documented engineering analysis

why vendor identified PM was not required. In the case of Terry

turbine PM, VTI had been on site since plant start-up for Unit 2, and

since turbine replacement in 1984 for Unit 1. The NRC inspector did

not review licensee PM versus manufacturer identified PM on the

original Unit 1 Terry turbine to determine its a effect on the

turbine's relatively short service life. Licensee Procedure 2402.46,

Revision 1, Change PC-1, dated March 12, 1986, ZK3 EFW Pump Turbine

Disassembly Inspection and Reassembly "did not specify the use of any

of the vendor specified casing joint sealing compounds, nor could

licensee personnel identify that these compounds have ever been

available. A revision or i.his procedure was in review when the NRC

inspector was on site, but it did not require the use of vendor

specified sealants, nor did the licensee provide documentation of the

acceptability of sealants previously used or proposed for use.

Numerous other PMs with periodicities from quarterly to 5 years were

specified by Terry turbine, but have no ANO documentation of

accomplishment.

Failure to have procedures for configuration control of licensee

maintenance procedures to ensure use of available vendor identified

(. PM, or a documented engineering review and, where necessary, a plant

safety committee review, of why vendor identified maintenance is not

necessary, is a violation of Unit 1 Technical Specification 6.8.la.

This technical specification requires written procedures to be

established, maintained and implemented covering applicable

procedures recommended in Regulatory Guide 1.33, dated November 1972.

Section I of Regulatory Guide 1.33 covers procedures for performing

maintenance; Unit 2 Technical Specification, Section 6.8.la, requires

procedures governing maintenance. Section 5.2.3 of the Arkansas

Power and Light Quality Assurance Manual - Operations requires that

l procedures which affect quality shall include measures to document

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the activity being performed. (50-313/8617-01); (50-368/8618-01).

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l 3. Licensee Maintenance Program Implementation

The NRC inspector chose two Job Orders for a review of the licensee's

i maintenance program implementation. Both job orders covered preventive

maintenance (PM) on safety-related items. One job order was for the

Service Water Pump, 2P-4C, and one for the emergency diesel generator

starting air compressors.

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a. Service Water Pump Maintenance

The preventive maintenance on the Service ~ Water Pump, Job

Order 711288, implementing Procedure 2402.34, Revision 4, dated

October 17,1985, " Breakdown and Repairs on the Service Water Pumps

2P-4A, B, and C," consisted of disasse:nbly, measurement of clearances

at several critical points, replacement of worn parts and reassembly.

The procedure was long (26 pages) and detailed. Some major components

were replaced because of excessive clearances caused by wear.

' All critical-measurements were made by the mechanics with tNeir line

supervisor present. The supervisor was required to sign off on each

measurement, and to determine if critical parts would be replaced.

No QC hold point or sign off was required.

During the reassembly portion of- the procedure, there were twelve

occasions where torquing of bolts was required. In one case, QC was

required to witness and sign off on any one of nine and in another

case was required to sign off on any one of three times bolt torquing

was required.

Vibration testing and other surveillance testing was performed on the

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Service Water Pump after the PM was completed.

The NRC inspector reviewed a list of all job orders on the ANO Unit 1-

and Unit 2 Service Water Pumps (P-4A, B and C and 2P-4A, B and C)

during the period January 1, 1979, to present. The information, a

computer run, listed job order, date completed,'a brief description

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of the work performed, the equipment affected,= the mechanic's name

i and the document location.

The inspector scrted the information by pump, by date, and by work

[ performed in an effort to discover maintenance trends, equipment with

significant corrective maintenance, and preventive maintenance. The

descriptive data was too brief, to determine the root cause of

' failures or to identify preventive maintenance.

l No discrepancies were identified.

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l The NRC inspector checked-the vendor data in the maintenance library

and compared the critical clearances and alignment tolerances with l

i- those called out in the procedures. In all cases, the clearances and

. tolerances were identical in the two docun.ents.

The training schedule for the mechanics was checked. Four of the

twenty-two mechanics were in training at the time and the schedule in

! the foreman's office showed that this is normal.

The planning and scheduling group supervisor was interviewed,

especially concerning the service water pump preventive maintenance.

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They had prepared another PM package on emergency service water pump

, 2P-4A which was identical to Job Order 71128.

The assistant stores supervisor was interviewed and a review was made

of the condition of the spare parts and inventory control for service

l water pumps and the emergency diesel starting compressor.

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A mechanical maintenance staff engineer was interviewed on the status

of root cause analysis. A program had been started where the

i. maintenance history on each piece of equipment scheduled for work was

reviewed and a list of all work done on that equipment during the

previous year was compiled. The information was routed through the

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maintenance superintendent to the maintenance engineer, who had the

responsibility to determine if a root cause could be identified. No

procedure covering this action has been issued.

There is a concern that the remaining tasks relating to root cause

analysis were not being accomplished.

b. Emergency Diesels Starting Air Compressors

i The preventive maintenance on the emergency diesel generator starting

compressor (Job Order 712462, implementing Procedure 1402.5

i Revision 2, dated September 21,1985, " Emergency Diesels Starting Air

Compressors"), was inspected. Work was done in the mechanical shop

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area. Work was proceeding slowly because some parts on order had not

been received.

A review of the procedure showed that it was located in the work

area, sign off of the procedure steps was current, and that all parts

l were clean and protected. The three micrometers being used were in

i calibration, were the proper size and type for the application, and

were identified in the procedure. The mechanical foreman was in the

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area actively supervising the work.

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l No violations or deviations were identified.

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4. Licensee Instrumentation Maintenance

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j The NRC inspector reviewed the licensee's Instrument and Control (I&C)

i maintenance program. Maintenance history, . calibration records,

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qualification records, procedures, work item tracking forms, and

j maintenance work request forms were reviewed.

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,- The following members of the I&C maintenance organization were interviewed

l to determine their areas of responsibility, function and qualification:

I&C supervisors and technicians.

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Four completed maintenance packages were reviewed: J0 54553, JO 17028,

JO 40587, and J0 12482. During the review, one concern was identified.

JD 54553 was a maintenance package covering the replacement of 2FT-5034-1,

a HPSI flow transmitter. This job order identified DCP 83 2103 as being

the controlling document for transmitter replacement. DCP 83-2103 was

located and reviewed.

DCP 83-2103 is a modification package produced to control replacement of a

number of Rosemount 1153D transmitters to meet commitments made in

response to 18E Bulletin 79-01B. During DCP 83-2103 review, it was found

that a procedure (2408.004, Revision 0) had been used to calibrate the

instruments. The procedure had acceptance criteria which had been changed

during performance. Signatures for closure of the procedure were made on

December 3, 1983. However, an official revision to the acceptance

criteria was not made until December 5,1983. The licensee reviewed the

discrepancy and found the changes to be satisfactory. An explanation

could not be provided because the modification was made so long ago that

the exact sequerce of events was unclear. The date difference was not

considered to be a concern. The acceptance criteria were reviewed and the

changes made were found to be small. They appeared to be changes required

to make adjustments for a new instrument.

One concern was that the DCP package was located on an engineer's desk

awaiting closecut, even though the work had been completed approximately

3.5 years earlier. The extent of unclosed DCPs was researched. It was

found that in June 1985, a project was undertaken to close out open DCPs.

By March 1986, a total of 337 DCPs had been submitted to Drafting for

drawing changes. Forty-eight were still to be reviewed by Plant

Engineering.

The licensee was questioned about the length of time DCPs remained open.

The response was that some packages had been open for more than 5 years.

The length of time between package generation and closure does not ensure

that problems or discrepancies can be adequately resolved, as was seen in

DCP 83-2103.

Two work activities in process were witnessed to determine if technicians

were following the correct maintenance procedures. Performance of two

surveillance procedures (1304.147, EFIC Channel C Test and 1304.39,

Reactor Protection System Channel C Test) were observed. One concern was

identified. During performance of 1304.39, step 7.5.19, it is necessary

to compare voltages on E IN 2 and Av Flux C & D Amp. Scaled Output. If

the difference was greater than .080 VDC, the CRD Control Panel and

Reactor Demand Panel were required to be in " Manual" before the Power

Range Test Switch was turned to " Auto." When voltage was less than .080

volts difference, the switch shifted quickly before the voltage changed

out of tolerance. The technicians were questioned and it was identified

that the voltages fluctuated. The technicians also indicated that, should

the Power Range Test Switch be shifted while out of tolerance, a plant

perturbation could result. The technicians were questioned further about

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how they knew it existed, as the procedure did not identify the

sensitivity of this step. The licensee stated that all personnel

performing this procedure were aware of the ccndition and had received

training on it.

I&C supervision were interviewed. They indicated that they were aware of

this condition. The interview identified that it was possible that

I&C personnel other than those normally performing the procedure could be

called upon to do so. It was indicated that it could be a long time

between performance by these individuals.

The concern, based on the above discussions, is that personnel unfamiliar

with performing this procedure could shift the Power Range Test Switia

when the voltage differential was too great. There was no warning to the

operator in the procedure, so proper operation depended on the memory of

the technician.

There were two areas identified during the course of the inspection as

requiring further review, safety-related equipment, maintenance intervals,

and Rosemount Models 1153 and 1154 0-ring replacement procedures. The

licensee was interviewed to ensure that required maintenance was performed

prior to qualification of safety-related equipment being voided.

Discussions with the licensee identified that all preventive maintenance

scheduling has a 25 percent past due grace time before the maintenance is

considered delinquent. This discrepancy had been identified by the

licensee prior to the inspection. The licensee showed that this

requirement had been addressed durin The

licensee had revised one procedure (g the EQ Committee meetings.1000.09, " Su

Control"), which was in the control review process, and was in the process

of revising another procedure (1025.06, ANO EQ). These procedures were

being revised to require maintenance to be performed at the required

frequency. In addition to these procedures, the licensee committed to

review and revise surveillance scheduling and EQ Data Record Summary

Sheets, as required. Based on the licensee's commitments, procedure

revisions and the knowledge that they identified the problem prior to

inspection, this concern appeared to be adequately addressed.

The second area requiring further review was 0-ring replacement on

Rosemount 1153 and 1154 transmitters. Not all equipment procedures

required 0-rings to be greased in accordance with Rosemount

i recommendations. The inspector found 22 procedures were in,this category.

l The procedures were being revised. The licensee indicated that he had .

l identified this concern, and was controlling and correcting it.

No violations or deviations were identified.

5. Licensee Electrical Maintenance Observation

The NRC inspector reviewed the licensee's electrical maintenance program.

Maintenance history, work item tracking forms, maintenance work requests,

qualification records, document control procedures and replacement part

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records were obtained and reviewed. The following functional members of

the electrical maintenance organization were interviewed to determine

their areas of responsibility, function and qualification: Electrical

supervisors and technicians.

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Work activities associated with two maintenance activities were witnessed

by an NRC inspector to determine if technicians were following the

appropriate maintenance procedures. Performance of two surveillance

procedures (1307.03, " Diesel Generator Protective Relaying Starting

Interlocks and Circuitry" and 1307.03, " Supplement 1, Diesel Fire Pump

Battery Banks Weekly") were observed.

One concern was identified during preventive maintenance review. The

concern deals with design life for Agastat Series * time delay relays. In

order to maintain qualification the manufacturer r ires the relay to be

replaced every 10 years. The licensee is to reseat 1 and address this

problem. Since these relays can not yet be 10 yeargold, a hardware

problem has not occurred. ,

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No violations or deviations were identified.

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6. Exit Interview

The inspector met with licensee representatives on May 23, 1986, and -

sunnarized the scope and findings of the inspection activities. The

Senior Resident inspector was present at the exit interview.

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ML20203F454

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