ML20126C057

Insp Repts 50-313/85-07 & 50-368/85-07 on 850401-30. Violation Noted:Failure to Follow Requirements for Radiologically Posted Area & Install Fire Door

ML20126C057
Person / Time
Site:	Arkansas Nuclear
Issue date:	06/07/1985
From:	Harrell P, Johnson W, Martin L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20126C009	List: IR 05000313/1985007 ML20126C005 ML20126C041
References
50-313-85-07, 50-313-85-7, 50-368-85-07, 50-368-85-7, GL-83-28, NUDOCS 8506140296
Download: ML20126C057 (18)

See also: IR 05000368/1985007

Text

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APPENDIX B

U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-313/85-07 Licenses: DPR-51

50-368/85-07 NPF-6

Dockets: 50-313

50-368

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

P. O. Box 551

Little Rock, Arkansas 72203

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

Inspection At: AN0 Site, Russellville, Arkansas

Inspection Conducted: April 1-30,1985

Inspectors: [J/ S//3/gf

W.~0. )1[nson, Senior Resident Date '

ReactoF Inspector

(pars. 2, 3, 4, 5, 6, 7, 8, 9,

10, 12 13)

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5-10- % 6

P. HF Harrell, Resident Reactor Date

Inspector

(pars. 2, 3, 4, 5, 6, 7, 8, 9,

10, 11, 12)

Approved: - #M/ff

L.*E. Martin,C)tief,Re5ctor D6J4

Project Section 2A'

8506140296 850610

PDR ADOCK 05000313

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Inspection Summary

Inspection Conducted April 1-30, 1985 (Report 50-313/85-07)

Areas Inspected: Routine, unannounced inspection including operational safety

verification, maintenance, surveillance, followup on previously identified

. items, followup on IE information notices, emergency preparedness exercise, and

followup on Generic Letter (GL) 83-28.

The inspection involved 98 inspector-hours (including 10 backshift hours)

onsite by two NRC inspectors.

Results: Within the seven areas inspected, no violations were identified.

Inspection Summary

Inspection-Conducted April 1-30, 1985 (Report 50-368/85-07)

Areas Inspected: Routine, unannounced inspection including operational safety

verification, maintenance, surveillance, followup on previously identified

items, followup on licensee event reports (LERs), followup on IE information

- notices, spent fuel pool activities, emergency preparedness exercise, followup

on GL 83-28, facility modifications, refueling activities, and pipe support and

restraint systems.

The inspection involved 145 inspector-hours (including 21 backshift hours)

onsite by.two NRC inspectors.

Results: Within the 12 areas inspected, two violations were identified

(failure to follow requirements for a radiologically posted area, paragraph 8,

and failure to install a fire door (FD) in accordance with an approved plant

design change, paragraph 5).

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DETAILS

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1. - Persons Contacted ' F

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JJLevine,ANOGeneralManageri

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• B.; Baker, Operations: Manager' _

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B. Bata, Quality Assurance (QA) Engineer

R.'Blankenship~," Nuclear Engineer

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.M. Bolanis, Health Physics. Superintendent

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'L. Bramblett, Plant Performance En'gineer

~D.-Brown,' Electrical: Engineer ' ,

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> M. Browning, . Maintenance Engineer. A. i

• P : Campbell , - Licensing Engineero ,1

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• T.;Cogburn, Special~ Projects Manager .

', M. Cooper,' QA Inspector .

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B. Converse,-Plant Performance Supervisor = '

iD.DCrabtree, Mechanical Engineer. ' 4

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s L; Dugger, Acting I&C. Maintenance Superintendent

i *E.~ Ewing', Engineering & Technical Support Manager

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G. Fiser, Radiochemistry Superviso'r- -

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M. Frala, Assistant' Radiochemistry Supervisor

> B. Garrison, Operations Technical Supporti; '

t L. Gulick Unit 2 Operations' Superintendent 1 s_.

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c D. Hamblen,. Quality. Control _(QC) Engineer -

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R. Hargrove, Unit 2 Lead Trainer-,

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. -H. Hollis, Security Coordinator ' '

• L.- Humphrey, Administrative Manager

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• H.' Jones, Field Construction Manager

1 P.- Kearney, Mechanical Engineer

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J. Lamb,:-Safety and Fire Protection Coordinator "

• D. Lomax, Licen'ing s Supervisor

• J. Marshall,'ANO Project Manager

B. McCord, QC Inspector

W. McKelvy,. Assistant Radiochemistry Supervisor

J. McWilliams, Unit 1 Operations Superintendent

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• J. Montgomery, Human Resources Supervisor

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R. Moore, Pianning and Scheduling Coordinator

J. Orlicek, Field Engineering Supervisor

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• M. Pendergrass, Acting Engineering & Technical Support Manager

-V. Pettus, Mechanical Maintenance Superintendent '

R. Pool,' Assistant Radiochemistry Supervisor

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• D._Provencher, Quality-Engineering Supervisor' ~

J. Ray, QC Engineer-

P. Rogers, Plant Licensing Engineer ,

• L.. Sanders, Maintenance Manager

• L. Sch~empp, Nuclear QC Manager

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Shively, Plant Engineering Superintendent

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' *G. Storey, Safety and Fire Protection Coordinator

S. Strasner, QC Supervisor '

M.,Stroud,~ Electrical Engineer

C. : Taylor, Operations Technical : Support

L. Taylor, Operations Technical Engineer

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B. Terwilliger, Operations Assessment Supervisor

R. Tucker, Electrical Maintenance Superintendent

D. Wagner, Health Physics Supervisor-

• R. Wewers, Work Control Center Manager

• Present at exit interview.

The inspectors.also contacted other.p'lant personnel, including operato'rs,

technicians, and administrative personnel.

2. Followup on Previously Identified Items (Units 1 and 2)

(0 pen) 0 pen Item 313/8017-03: Reactor building purge alarm setpoint.

' The NRC inspector obi;erved a portion of the Unit 1 reactor

building purge conducted'on April 11,'1985,.under permit 1GR 85-20.

Although the Technical Specification gaseous release rate limits

were not approached.or exceeded during this purge, observations

during the purge and subsequent discussions with operations and

radiochemistry personnel indicate that improvements are needed

in the procedures used for conducting a reactor building purge.

Problem areas identified included:

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. . The alarm setpoint calculated for RE-7400 was 'about.46 times

as high as the highest actual count rate observed during

the purge.

. The special particulate iodine noble gas (SPING) monitor

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alarm setpoint was about a factor of nine lower than the

calculated concentration-in the reactor building prior to.

the purge.

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. The SPING monitor alarm setpoint was written on the reactor

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building purge gaseous. release permit in'the space provided

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for the RE-7400 alarm setpoint.

, . Sample flow to RE-7400 was not lined.up initially, as.

indicated by this instrument's lack of response during the

first segment of- the purge. ,

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. iThe purge was secured during the.first segment due to

confusion _and concern over the meaning of the SPING monitor

alarm which was activated.

. Dual calculations performed as required by concurrently

, applicable old_and new Technical Specifications contributed

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. 'The post release permit update was recalculated following '

identification of a computer input error in which reactor- '

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.. Thecomputer;generat$dprereleasepermitdidnot'flagthe ..

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([ In discussions with the NRC inspector, operations-and

radiochemistry personnel stated that they would review and

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' . revise the procedures associated with. reactor building purge '

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releases. This item remains open. ,

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(Closed),10 pen. Item 368/8206-01: Reactor coolant pump (RCP) seal sensing >

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line supports.

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'  : ;The licensee has' inspected the RCP seal pre'ssure sensing lines

and supports and implemented DCP 83-2011 to reduce the problem

,of leaks in:these lines. This DCP removed unnecessary lengths

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- of piping, added supports where necessary, and replaced some

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' C piping with tubing. During outage 2R4, the licensee inspected ,

the seal injection and controlled bleedoff lines and developed a  !

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i design change to upgrade'the supports on these lines.

V .DCP 84-2084 was partially implemented during the' outage. These .

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' inspections, evaluations, and design changes were intended to'

reduce or eliminate leaks such as those reported in

LERs 82-017/03L-0, 83-023/03L-0, and 83-039/03L-0. '

(Closed) 'Open Item 368/8212-06: Smoke and heat detectors in containment.  ;

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.+ :The NRC inspector toured the Unit 2 containment and verified

that heat and smoke collectors were installed over the heat and.

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smoke detectors in the containment,.as required by the Unit 2

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= Fire Protection Safety Evaluation Report.

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-(Closed) Open Item 313/8304-03; 368/8304-03: Control of maintenance to [

ensure' interferences are reinstalled upon completion of work ,

activities.

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,iThe licensee has; established a program'in-Procedures'1025.03,

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J'! Conduct of Maintenance" and 1000.24, " Control of Maintenance,";

to ensure that interferences are reinstalled upon' completion of.

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work~ activities. .The program requires that a'new job order (J0)

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be written for interferences thati require removal if not within

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(Closed) UnresolvedItem,313/8304-04;368/8'304-04:

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Utilization of

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-quality control (QC).

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During followup of t'his item, the NRC inspector reviewed l

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Administrative Procedures 1000.23, " Quality Control. Program,"

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'and'1004.01, " Quality Control Program Implementation." In

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addition,--. discussions were held ~with personnel at.various levels

in the.ilcensee's organization. Since this unresolved item was

identified, several changes and improvements have been made to

. increase ~the efficiency and effectiveness of QC personnel at the

plant site.' These changes include:

. The~ addition of QC engineer positions and a QC engineer

supervisor;

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. Assignment of a.QC engineer to the Work Control Center;,

. -Assignment of a-QC inspector to the receipt ins'pection *

. function;

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. Utilization of QC engineers for review of J0s and DCPs and

, designation of QC hold points;

. EUtilization of a'dditional contract QC inspectors during

h outage periods to enlarge the scope of activities which are

inspected;

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y ' . Establishment of the construction management QC group.for

inspection of construction and installation activities and

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". More frequent use of QC hold points in J0s and procedures;

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,1  : .f Improved availability and visibility of QC inspectors in A e / '

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1  ;.(Closed 'Open Item 313/8331-01; 368/8331-01: ' Completion of a fire

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protection / prevention program consolidation and clarification-of- .

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i- The licensee has1 issued a set of manuals that consolidate the

): information related~to fire protection.for Units 1 and 2. These

E Fire Protection Program Manuals are issued and maintained by the

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AP&L, licensing group. .The manuals will be updated,.as

necessary, to provide the latest information for the fire

protection program.

(Closed) Open Item 313/8331-02; 358/8331-02: Indiscriminate fire

> ' suppression system activation.

The licensee has revised Procedure 1903.22 to delete the

statement that any plant personnel may activate sprinkler or

deluge , systems in the event of a fire, prior to the arrival of

the fire brigade. Procedure 1903.22 now states that system

> activation will only be performed per the direction of the fire

brigade captain.

'(Closed)' Unresolved Item 313/8331-03; 368/8331-03: Fire brigade

' participation tracking system.

The NRC. inspector reviewed the records maintained for -

participation in fire brigade training. .The records maintained .

by the licensee include individual participation in fire brigade

drills, practice sessions, and classroom instruction. The NRC

inspector also reviewed the quarterly training department memos

that list individuals qualified as fire brigade members.

(Closed) Violation 313/8429-04: Procedure change conflicting with

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Technical Specification requirements.

The licensee's corrective action in' response to this violation

included procedure revision to eliminate the conflict with

Technical Specifications and placing administrative restrictions

on changing procedures without going through the revision

process.

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(Closed) Violation 368/8431-01: Control of combustibles.

The NRC inspector reviewed the corrective actions taken with

respect to this violation. The licensee's corrective actions

included the immediate posting of a fire watch in the affected

. area, improved documentation of periodic fire / safety

inspections, and presor,tation of a training program for those

individuals primarily responsible for housekeeping. In

addition, discussions are presented during general employec

training and subsequent yearly retraining in the areas of

control of combustibles, ignition sources, and fire barriers.

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3. LicenseeEventReport(LER) Followup (U, nit}2)

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Through direct observation, discussions with. licensee' personnel, and

review of records, the following Unit 2 event' reports were reviewed to '

determine that reportability requirements were fulfilled, inmediate

e corrective action was accomplished, and corrective action to prevent-

recurrence has been accomplished in accordance with Technical

-Specifications.

82-017/03L'-0 'RCP seal pressure sensing line leak

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83-023/03L-0 RCP seal pressure sensing line leak

83-039/03L-0 RCP seal pressure sensing line leak

84-004-00 Reactor trip on low steam generator level

84-008-00 Reactor trip on-low steam generator-level

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84-011-00 Reactor trip on high steam generator level

84-014-00 Reactor trip on high steam' generator level

84-020-00 Reactor trip on high steam generator level

84-021-00 Reactor trip on high steam generator level

84-028-00 Reactor' trip on low steam generator level

The three LERs concerning ' leaks'in RCP seal pressure sensing lines are

discussed in paragraph 2 of_this. report in conjunction with Open

Item 368/8206-01.

LERs 84-004-00, 84-008-00, and 84-021-00 relate to high'and low steam

generator (S/G) level actuated reactor trips during low feedwater flow

operations. To minimize the number of trips due to this cause, the.

licensee is installing low flow range indication during the current outage

-(2R4). This' indication is provided to assist the operator in controlling

S/G levels during low flow operations. LERs 84-011-00, 84-014-00,

84-020-00, and.84-028-00 relate to reactor trips due to high or low S/G

levels due to equipment malfunction or procedural inadequacies. In each

case, the equipment was repaired and/or. modified or procedure changes

were issued to prevent recurrence. To minimize the number of reactor

trips due to S/G levels, the licensee proposed a Technical Specification

change to reduce the low S/G level trip setpoint from 46 pcecent to

23 percent. This request was approved by the NRC in Amendment 65 to the

' Unit 2 Technical Specifications on April 30, 1985J

No violations or deviations were identified.

4. Followup on IE Information Notices (Units 1 and 2)

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The NRC, inspector reviewed the licensee actions with respect to IE

information notices' issued during 1984. The review included verification

that all notices issued during 1984 had been received by the licensee,

were distributed to appropriate personnel for an applicability review, and

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that; appropriate corrective actions had been taken or were scheduled to be

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The licensee has received and reviewed all 1984 information notices. The j

NRC inspector. reviewed the corrective actions taken by the licensee, and

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it appears-that the corrective actions were appropriate. The NRC

inspector also reviewed a sampling of the implementation of the corrective.

- actions to verify the action taken was in accordance with the results of

2 the documented review.

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IE Information Notice 84-06, " Steam Binding of Auxiliary Feedwater Pumps,"

' was issued on January 25, 1984. The NRC inspector reviewed the licensee's i

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response'to this issue in more detail in response to a request from the

NRC Office of Inspection and Enforcement. The licensee had reviewed this

issue and performed appropriate corrective action as outlined below:

. Emergency feedwater (EFW) piping is monitored twice per shift by

touch on Unit 1 and once per shift by pyrometer on Unit 2 to detect

back leakage as indicated by a piping temperature increase.

. The Unit 1 EFW operating procedure was revised to check for check

valve back leakage prior to the monthly test of each pump.

. The Unit 2 EFW operating procedure was revised to ensure seating of

the check valves by cycling the stop valves after stopping the pumps

during the monthly tests.

. The EFW operating procedures for both units were revised to provide

guidance on detecting and correcting EFW pump steam binding.

No violations or deviations were identified.

5. Operational Safety Verification (Units 1 and 2)

The NRC inspectors observed control room operations, reviewed applicable

logs, and conducted discussions with control room operators. The

inspectors verified the operability of selected emergency systems,

reviewed tagout records, and verified proper return-to-service of affected

components. Tours of accessible areas of the units were conducted to

observe plant equipment conditions, including potential fire hazards,

fluid leaks, and excessive vibration. In addition, the inspectors ensured

that maintenance requests had been initiated for equipment in need of

maintenance. The inspectors, by observation and direct interview,

verified that the physical security plan was being implemented in

accordance with the station security plan.

During a tour of the Unit 1 auxiliary building, the NRC inspector noted

that NRC-required FD 19 was not shut as it should be. FD 19 is located

between the EFW pump and south piping penetration rooms. The NRC

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inspector noted that the door was being held open by ventilation air flow.

The door is designed not to latch shut because the door also serves as a

vent path in the event of a high energy line break (HELB) in the south

piping penetration room. The door is normally held shut by an automatic

door closer. Flame and smoke detectors on either side of the fire barrier

were operational as required by Technical Specifications. This item is

unresolved pending a licensee evaluation of how to maintain the door in

the shut position so the effectiveness of FD 19 to contain a fire within

an affected location will not be decreased. (313/8507-01)

During a tour of the Unit 2 auxiliary building, the NRC inspector noted

that FD 210 was being held shut by a latch. FD 210 should not be held

shut because it provides a vent path for an HELB in the lower south piping

penetration room. The NRC inspector reviewed DCP 83-D-2030 and found that

the design change required a door be installed that met the requirements

of 10 CFR Part 50, Appendix R and for an HELB in the penetration room. In

order to meet both requirements, DCP 83-D-2030 provided instructions for

FD 210 to be installed with a door closer to ensure the door remained

shut, but without a latching mechanism so the door would open in the event

of an HELB. The DCP and associated J0 were signed off as completed even

though FD 210 was not installed in accordance with the DCP requirements.

This is an apparent violation. (368/8507-01)

In addition to the required response for the above violation, the licensee

is requested to include a written evaluation of the effect of the latched

door on the HELB analysis for the lower south piping penetration room. A

review of this item will be included in the NRC inspector's followup

inspection of the violation.

The NRC inspectors observed plant housekeeping / cleanliness conditions and

verified implementation of radiation protection controls. The NRC

inspectors walked down the accessible portions of the Unit I high pressure

injection system. The walkdown was performed using Procedure 1104.02 and

Drawing M-231. During the walkdown, minor discrepancies of an editorial

nature were noted. The discrepancies were identified to licensee

personnel.

These reviews and observations were conducted to verify that facility

operations were in conformance with the requirements established under

Technical Specifications,10 CFR, and administrative procedures.

6. Monthly Surveillance Observation (Units 1 and 2)

The NRC inspec.t.rs observed the Technical Specification required

surveillance testing on the Unit 2 emergency diesel generator

(Procedure 2104.36, Supplement II) and verified that testing was performed

in accordance with adequate procedures, that test instrumentation was

calibrated, that limiting conditions for operation were met, that removal

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and resto' ration of-the affected components were accomplished, that test

<results. conformed with Technical Specifications and procedure

requirements, that test results were reviewed by personnel other than the

individual directing the test,,and that any deficiencies identified during

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the testing were properly reviewed and resolved by' appropriate management

personnel.

The inspectors also witnessed portions of the following test activities:

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. Unit 2 class 1E battery charger (2032) load test (Procedure 2403.53)

. Unit 1 low pressure injection pump monthly test (Procedure 1104.04,

4 Supplement I)

. Unit 2 visual inspection of mechanical snubbers (Procedure 1406.36)

. Unit 2 functional testing of mechanical snubbers (Procedure 1406.40) >

. Unit 2 engineered safeguards features relay testing (JO 71748)

No violations or deviations were identified.

7. Monthly Maintenance Observation (Units 1 and 2)

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Station maintenance activities of safety-related systems and components

listed below were observed to ascertain that they were conducted in

accordance with approved procedures, Regulatory Guides, and industry codes

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or standards; and in conformance with Technical Specifications.

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; QC records were maintained;

activities were accomplished by qualified personnel; parts and materials

used were properly certified; radiological controls were implemented; and

fire prevention controls were implemented,

i Work requests were reviewed to determine status of outstanding jobs and to

ensure that priority is assigned to safety-related equipment maintenance

which may affect system performance.

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The following maintenance activities were observed: ,

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. Unit 2 control element assembly extension shaft removal

(Procedure 2401.17)

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..- Unit 2 S/G tubesheet cleaning (Procedure 2402.98)

. Replacement of insulation on motor leads for the high pressure

injection pump.(JO 84217)

. Removal and replacement of Unit 2 mechanical snubbers (JO 79534)

. Tightening of a loose nut on service water support for Unit 2

containment cooling' unit (JO 73025)

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i . Replacement of the mechanical seal on Unit 2 low' pressure safety

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injecti_on pump (JO 76038)

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. Cleaning of Unit 2 RCP oil drain lines (JO 81998)

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LNo v'iolations or deviations were identified. .

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, '8. LSpent'FuelhoolActivities(Unit 2)

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IDuring this refueling outage (2R4), the licensee offloaded all fuel ^;

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assembli_es from the core into the spent fuel pool. This was done to

. perform shoulder gap measurements on selected fuel assemblies, remove

control element assemblies (CEA) from spent fuel assemblies into new fuel '

assemblies,'and replace spent fuel assemblies with new fuel assemblies. '

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The' NRC -inspectors observed spent fuel pool activities to verify that

operations'were being conducted in accordance with Procedures.2409.43,

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"CEA Movement Utilizing CE Equipment"; 2503.01, " Refueling Shuffle"; and

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2503.03, " Operation of Fuel Handling Equipment." No problems were noted

with the mechanics of handling fuel assemblies in the spent fuel pool..

During observation of operation of the~ spent fuel pool bridge, the NRC

inspectors noted that the HP area entrance requirements for portions of

the bridge stated that beta protection was required. However, an

individual operating the CEA handling tool within the posted area was not

using the HP-required beta protection (i.e., glasses or goggles). This is

an apparent procedural ~ violation involving failure to comply with the

posted area entrance requirements. (368/8507-02)

9. Emergency Preparedness Exercise Observation (Units 1 and 2)

The NRC inspectors observed the licensee's annual emergency preparedness

exercise held on April 24-25, 1985. The inspectors were located in the

Unit 2 control room and in the technical support center where they

performed observation and participation activities. A detailed discussion

of the NRC' findings during the exercise is provided in NRC Inspection

Report 50-313/85-10; 50-368/85-10.

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10. Facility Modifications (Unit 2)

Y . The NRC inspectors reviewed two design changes performed on Unit 2 systems

during the current outage (2R4). The DCPs reviewed were DCP 83-2006,

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" Service Water Pump Disconnect Switches and Cable Reroute," and

DCP 84-2018, " Service Water Valve Replacement." The following items were

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verified for these DCPs:

. The changes were reviewed and approved by the licensee in

accordance with 10 CFR Part 50.59 and with licensee procedures.

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. The implementation of the DCPs was controlled by established

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procedures.

. Following implementation, the modified systems were tested in

accordance with approved test procedures.

. The necessary changes to operating procedures were being approved and

were scheduled for implementation prior to plant heatup.

. Operator training on the DCPs was conducted.

. Changes to piping and instrumentation drawings were scheduled to be

issued prior to plant heatup.

. Ignition source permits were issued when required.

. For DCP 83-2006, the licensee had reviewed and approved the seismic

qualification report for the new disconnect switch cabinets.

. Field change notices to the DCPs were used to document and control

design revisions found to be needed after DCP implementation was

started.

. Checks were performed at various times during installation to verify

that the change was being performed in accordance with the DCP.

No violations or deviations were identified.

11. Near-Term Inspection Followup to GL 83-28 (Units 1 anJ 2)

GL 83-28, " Required Actions Based on Generic Implication of Salem ATWS

t Events," was issued by the NRC on July 8, 1983. GL 83-28 required each

licensee to address the near- and long-term programs associated with post-

trip review, equipment classification, vendor interface, and maintenance

programs for safety-related components within safety-related systems.

This inspection addressed the near-term programs currently in effect at

ANO. The long-term programs, currently being reviewed by the NRC Office

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i after issuance of safety evaluation reports. Each of the four areas

reviewed during this near. term inspection are discussed below.

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a. The area of posttrip review wa's discussed in NRC Inspection

Report 50-313/84-18; 50-368/84-18.

b. .The purpose of equipment classification area of this inspection was

to verify that the licensee has established a program for use in-

identification of components as safety-related; that the program is

adequately described in appropriate procedures, drawings, and

instructions; and that the program is being '

implemented in daily

plant activities.

The NRC inspector performed the following activities for this area of

the inspection.

. Reviewed the appropriate procedures to verify that an equipment

classification program has been established that conforms to the

licensee's response to GL 83-28, codes, standards, the AP&L QA

Manual-Operations, and the safety analysis reports.

. . Reviewed procurement, maintenance, and' modification activities

to verify these activities were being performed in accordance

with the controlling procedures established for program

implementation.

. Verified that audit, training, and nonconformance programs were

established and implemented for activitles associated with

equipment classification.

c. The purpose of-the vendor interface area of this inspection was to

verify that the licensee has established and is implementing a

program to ensure vendor information is complete, current, and

controlled, and that the vendor information has been-included in the

licensee's test and maintenance procedures.

The NRC inspector performed the following activities for this area of

the inspection.

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. Reviewed vendor technical manuals for selected plant components

and verified the test guidance and maintenance information ,

provided had been incorporated into the appropriate procedures.

.$ Reviewed the technical manuals for Units 1 and 2 reactor trip .

,' breakers (RTBs) and appropriate procedures to verify information '

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contained in the procedures was accurate and detailed enough to '

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. provide adequate instructions for the technicians performing RTB

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maintenance and testing.

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. Verified that RTB modifications recommended by the vendor had ,

been completed.'

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. Verified that the licensee is trending online and maintenance

data for the RTBs.

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d. The purpose of the maintenance area of this inspection was to verify

that the licensee is implementing a postmaintenance testing program

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for safety-related components to ensure operability after maintenance '

activities have been completed.

, . . .' -The NRC inspector performed the following activities related to this

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4 area of the inspection. ,

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Verified that_a program has been established that requires post-

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maintenance testing and that the program establishes the

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responsibilities for review and approval of maintenance, for,

3' , l . designation as to whether or not it is a safety-related

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maintenance activity,'and for the performance of the maintenance

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. Verifled through the review of maintenance documentation on

selected plant components that the program is bc' a properly

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implemented and that postmaintenance testing is performed prior

to returning the component to service.

. Observed plant maintenance activities to verify that maintenance

<: . is performed in accordance with procedures and instructions.

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. Verified procedural requirements exist that test the

silicon-controlled rectifiers for the reactor trip system.

. Verified that procedures require testing of the manual and

automatic trip functions of the RTBs.

No violations or deviations were identified.

12. Refueling Activities (Unit 2)

The NRC inspectors reviewed procedures and observed licensee activities to

determine whether refueling activities were conducted as required by the

Technical Specifications and in accordance with approved procedures. ,The

following items were included in this inspection:

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. The Technical Specification prerequisites were met prior to fuel

,han'd ling.

. Periodic equipment testing and boron sampling required by the

Technical Specifications were conducted.

. Fuel handling operations in the reactor building and in the spent

fuel pool were being conducted in accordance with approved

procedures.

. Containment integrity was maintained as required.

. Housekeeping practices in the refueling cavity and in the spent fuel

area were appropriate. The discrepancies involving loose items on

the refueling bridge identified during the recent Unit I refueling

were not repeated during this refueling.

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. Technical Specification and procedural requirements regarding

staffing during refueling operations were satisfied.

No violations or deviations were-identified.

13. Pipe Support and Restraint Systems (Unit 2)

The NRC inspector reviewed the licensee's procedures and activities

relating to the inspection and testing of mechanical snubbers in

accordance with Technical Specification 3/4.7.8. Procedures reviewed

included:

Number Revision Title

1406.36 1 Mechanical Snubber Visual Inspection

per VT-3

1406.37 1 Mechanical Snubber Visual Inspection

per VT-4

1406.38 1 Mechanical Snubber Removal and

Reinstallation.

1406.40 1 Mechanical Snubber Testing - Pacific

Scientific (PSA) Snubbers

1406.41 1 Disassembly, Cleaning, Inspection, and

Reassembly of PSA Mechanical Snubbers

The licensee contracted with Wyle Laboratories for performance of

mechanical snubber inspection and testing during outage 2R4. The NRC

inspector made observations of these activities and noted the following

items:

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. The AP&L QA department had reviewed the calibration documentation and

verified that the testing machines and associated instruments were

calibrated.

. AP&L QA had also reviewed the qualification status of testing and

inspection personnel.

. QC for testing and inspection activities was provided by Wyle under-

the.Wyle QA Manual.

.- The snubber inspections observed were performed in accordance with

approved procedures by experienced personnel.

. Deficiencies identified during inspections were documented and

tracked to resolution.

. Functional test acceptance criteria were in conformance with

Technical Specification 4.7.8.e.

. A mechanism was in place to ensure the performance of a failure

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analysis and an engineering evaluation of the effect on systems and

components for each snubber which failed to meet the functional test

acceptance criteria.

l . Due to.the number of failures identified, the licensee elected to

. perform a functional test on each mechanical snubber. At the end of

this inspection period, the licensee's failure analyses and

component / system operability engineering evaluations were not yet

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complete. The NRC inspector will review the results of these

analyses and evaluations during the next inspection period.

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. Preservice operability testing and preservice inspections were

performed on repaired, replacement, and new snubbers as required by

Technical Specification 4.7.8.g.

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functional testing machines daily.

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. . Test data was recorded for review, evaluation, and retention.

No violations or deviations were identified.

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14. JinresolvedItem

- An unresolved item is one about which more information is required to

determine whether the item is acceptable cr is a violation. One

unresolved item is discussed in this report as indicated below:

l' Paragraph Subject

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The NRC inspectors met with'Mr. T.:.Cogburn and other members of the AP&L-

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staff'at the end of this inspection. At'this meeting, the inspectors

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summar,1 zed the scope of the inspection and the findings.

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