2CAN089706, Forwards Response to NRC Ltr Re Violations Noted in Insp Rept 50-368/97-04 on 970608-0719.Corrective Actions: 10CFR50.59 Evaluation Was Completed on 960805

Forwards Response to NRC Ltr Re Violations Noted in Insp Rept 50-368/97-04 on 970608-0719.Corrective Actions: 10CFR50.59 Evaluation Was Completed on 960805

ML20217R253
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/28/1997
From:	Mims D ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
2CAN089706, 2CAN89706, 50-368-97-04, 50-368-97-4, NUDOCS 9709040372
Download: ML20217R253 (5)

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1448 SR 333 Rs.seMic, AR 72801 1d 501858-5000 August 28,1997 10CFR2.201 2CAN089706 U. S. Nuclear Regulatory Commission Document Control Desk, OPI-17 Washington, DC 20555

Subject:

Arkansas Nuclear One - Unit 2 Docket No. 50-368

, License No. NPF-6 Response To Inspection Report l

50-368/97-04 l

Gentlemen:

Pursuant to the provisions of 10CFR2.201, attached is the response to the Notice of Violation (NOV) regarding a failure to properly determine the need for a 10CFR50.59 Evaluation.

Should you have any questions or comments, please call me at 501-858-4601.

Very truly yours, 4dc.v4,.c Dwight C. Mims Director, Nuclear Safety DCM/mkg Attachment l

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, mm n-pppppum!g 9709040372 970828 PDR ADOCK 05000368 G PDR I

. U. S. NRC

. August 28,1997 2CAN089706 cc: Mr. Ellis W. Merschoff Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064

NRC Senior Resident Inspector Arkansas Nuclear One P.O. Box 310 London, AR 72847 Mr. George Kalman NRR Project Manager Region IV/ANO-1 & 2 U.S. Nuclear Regulatory Commission NRR Mail Stop 13-H-3 One White Flint North 11555 Rockville Pike Rockville, MD 20852 i

,- Attachment to 2CAN089706 Page1of3 NOTICE OF VIOLATION During an NRC inspection conducted on June 8 through July 19,1997, one violation of NRC requirements was identified. In accordance ~with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

A. 10 CFR Part 50.59(b)(1) states, in part, that the licensee shall maintain records of changes in the facility and of changes in procedures made pursuant to this section, to the extent that these changes constitute changes in the facility as

! described in the Safety Analysis Report (SAR) or to the extent that they L constitute changes in procedures as described in the SAR. These records must

! include a written safety evaluation which provides the bases for the determination that the change, test, or experiment does not involve an unreviewed safety question.

t Contrary to the above, the licensee failed to perform a safety evaluation prior to revising Procedure 2102.002, " Plant Heatup," on July 10,1997. This revision to return the trip setpoint for the logarithmic power level - high to so.75 percent of rated thermal power was based on an analytical setpoint of 4 percent and I constituted a change in the facility as described in SAR paragraph 15.1.1, which describes a 2 percent analytical setpoint. This change was- not evaluated to determine if the change involved an unreviewed safety question.

This is a Severity Level IV violation (Supplement 1) (Violation 50-368/9704-02).

Response to Notice Of Violation 368/9704-02  ;

i

. (1) Reason for the violation:

The Arkansas Nuclear One (ANO) 10CFR50.59 review program consists of the processes designated as "10CFR50.59 Determination" and "10CFR50.59 Evaluation". A " Determination" is used to screen whether a fully documented

" Evaluation" of a proposed change to the facility description is necessary. _ ANO failed to perform a 10CFR50.59 Evaluation for a revision to the plant heatup procedure due to an inadequate determination of how the technical basis for revising the procedure was directly linked to a change in analytical assumption values contained in the SAR.

In early 1996, anoth r nuclear power facility identified that calibration uncertainties inherent with low power operations of ABB Combustion Engineering (ABB-CE) designed NSSS systems could result in a discrepancy between the high logarithmic l

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,,- Attachment to

"' 2CAN089706 Page 2 of 3

- - power trip setpoint and the analytical setpoint contained in facility safety analyses.

The high logarithmic power trip function is credited as a design and operational safety femure at low power levels only (from $10"% to 2% rated power), while the logarithmic channel instrument calibration is routinely performed at 100% power.

The calibration methodology could have resulted in the actual power level in the core being higher than the analytical setpoint. ANO issued a condition report to

, document and evaluate a possible error in the uncertainties used to establish the logarithmic power channel trip setpoints.

l As an interim corrective action, a temporary change to the plant heatup procedure i was approved based upon AEB-CE recommendations. The revision lowered the 0.75% rated power trip setpoint by a factor of ten to compensate for decalibration uncertainties.- The 10CFR50.59 Determination performed for the interim procedure change was properly documented in accordance with the ANO review program.

' A subsequent engineering evaluation conducted as a result of the condition report revealed the original 0.75% rated power setpoint value was acceptable. However, the analytical setpoint value was revised from 2% to 4% of rated power.

Based on the above evaluation, the plant heatup procedure was revised to re-estabfsh the original setpoint value. The 10CFR50.59 Determination and procedure change for returning the setpoint to 0.75% power failed to include a thorough review of how the condition report evaluation (which specifically addressed the 2 %

analytical limit being changed to 4%) impacted the SAR.

The reason the violation occurred was personnel error. The individuals who performed the 10CFR50.59 Determination and revised the procedure believed they were only returning the trip setpoint to the original condition. They failed to recognize the change in analysis for the procedure revision impacted the SAR. This oversight precluded the development of a 10CFR50.59 Evaluation and SAR change.

(2) Corrective steos that have been taken and the results achieved:

A 10CFR50.59 Evaluation was completed on August, 5,1996. The evaluation determined the change to the SAR value was not an unreviewed safety question.

The events surrounding this viola.' ion were discussed with the individuals who performed the 10CFR50.59 Determination and procedure change which returned the setpoint to 0.75% rated power.

- (3) Corrective steos that will be taken to avoid further violations:

A licensing document change request to revise the SAR description of the setpoint-and supporting analysis has been approved and will be included in the next SAR-update scheduled for December 9,1997.

, Attachment to 2CAN089706

• l Page 3 of 3 I

The events surrounding this violation will be discussed with certified 10CFR50.59 reviewers by October 31,1997.

Lessons learned regarding issuance of initial analyses will be discussed with appropriate engineering personnel during Engineering Support Personnel (ESP) training which will be completed by October 31,1997.

ANO-1 and ANO-2 operations and maintenance procedure writers will be reminded that they must have a clear understanding of the effect of procedure changes upon the SAR or have engineering input prior to proceeding with the changes. This notification will be completed by October 31,1997.

(4) Date when full comoliance will be achieved:

Full compliance was achieved on August 5,1996, when ANO completed the 10CFR50.59 Evaluation of the change to the SAR.

In response to an Entergy Assessment of the ANO 10CFR50.59 review program, performed prior to the identification of this violation, an additional review and signature requirement for 10CFR50.59 Determinations has been incorporated into the ANO 10CFR50.59 review program. This enhancement was described in the NRC inspection report; however, it is not considered a commitment in response to this violation.

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