ML20151P369
| ML20151P369 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 08/01/1988 |
| From: | Bundy H, Murphy M, Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17222A807 | List: |
| References | |
| 50-313-88-22, 50-368-88-22, NUDOCS 8808100007 | |
| Download: ML20151P369 (9) | |
See also: IR 05000313/1988022
Text
,
.
APPENDIX B
U.S. NUCLEAR REGULATORf COMMISSION
REGION IV
NRC Inspection Report:
50-313/88-22
Operating Licenses: DPR-51
50-368/88-22
Docket:
50-313
50-368
.
Licensee:
Arkansas Power & Light Company (AP&L)
P.O. Box 551
Little Rock, Arkansas 72203
Facility Name:
Arkansas Nuclear One (AN0), Units 1 and 2
Inspection At:
Inspection Conducted:
July 11-15, 1988
l
-
A 46
f!///7
Inspectors:
H. F. Bundt,ivision of Reactor Safety
Reactor Ipspector, Test Programs
Date'
Section, D
f
W
TV
. . -
M. E.' Murphy, fresctor/ Ins @ actor Safety
tor, Test Programs
D6te~
Section, Division of Re
Accompanying
Personnel:
R. V. Azua, Reactor Inspector, Test Programs
Section, Division of Reacter Safety
'
/
Approved:
"
(#
W. C. Seidle) Chief, Test Programs Section
Date
Division of Reactor Safety
ggSS2%B88ES$8SNP
Q
"
,
>
.
2
!
Inspection Summary
'
i
inspection Conducted July 11-15, 1988 (Report 50-313/88-22; 50-368/88-22)
Areas Inspected:
Routine, unannounced inspection of the licensee's Cycle 7
,
startup testing for Unit 2 and surveillance procedures and records for both
Unit 1 and Unit 2.
Results:
The licensee's startup testing appeared to generally be in
conformance with NRC requirements and licensee procedures.
However, two
apparent violations were identified (failure to evaluate and document power
ascension test results and failure to have a controlling procedure for power
ascension testing appropriate to the circumstances, paragrapli 2).
The
surveillance procedures and records reviewed appeared to satisfy all
requirements. However, a downtrend in the quality of the microfilm was
observed (paragraph 3).
!
ll
<
l
l
!
4
i
i
i
i
!
"
1
'
,
-
--
---
_-
.
.-
.
, ..
- - ,
.
-,
"
.,
.
1
3
1
DETAILS
1.
Persons Contacted
]
- J. M. Levine, Executtve Director, Nuclear Operations
L. Humphrey, General Manager, Nuclear Quality
- R. Wewers, Manager, Work Control Center
- G. Kendrick, Instrumentation and Control Superintendent
- C
Shively, Plant Engineering Superintendent
- H. Smith, Reactor Engineering Superintendent
,
D. Lomax, Plant Licensing Supervisor
- P. Michalk, Licensing Specialist
NRC
- R. Haag, Resident Inspector
The NRC inspectors also interviewed other licensee personnel during the
inspection.
.
- Denotes those attending the exit interview on July 15, 1988.
2.
Startup Testing - Refueling (72700)
The purpose of this part of the inspection was to verify that Unit 2
startup testing following Refueling Outage 2R6 (beginning of Cycle 7) was
in accordance with NRC requirements, vendor requirements, and licensee
procedures,
in conjunction with this, it was verified that test results
met acceptance criteria, and deficiencies were resolved in a timely
manner. Because the startup had been completed, neithet manipulations nor
data taking were observed. The NRC inspectors performed a walkdown of the
pennanent data acquisition systems.
Pursuant to the above objectives, the
NRC inspectors reviewed the following documents and associated data:
Cycle 7 Reload Analysis Report dated March 17, 1988
Reactor Engineering Procedure (REP) 2302.021, Revision 10, Change 4,
"Sequence for low Power Physics Testing Following Refueling"
REP 2302.034 Revision 7, Change 2, "Power Ascension Testing
Controlling Procedure"
Operattoris Procedure (0P) 2102.02, Revision 26, "Plant Startup"
The above procedures appeared to be the overall controlling and sequencing
documents for startup.
They assured timely data collection and analysis
to verify subsequent reactor operation would be within predicted core
physics parameters. Overall sequencing and control procedures for post-
.
..
.-_ .
. - --_
V
'
.
4
refueling reactor startup are a comon industry practice. The data
generally appeared to be acceptable.
However, two discrepancies
,
identified in the data for REP 2302.034 are discussed below.
One discrepancy involved the failure to initial Step 8.38 in REP 2302.034,
which was verification that all test acceptance criteria applicable to
,
i
the 100 percent power test plateau had been met.
This step had not been
}
initialed as of July 15, 1988.
Prerequisite to this initial were
required signatures on Attachment A, of REP 2302.034 by the reactor
i
i
engineering supervisor and another individual, attesting to satisfaction
of 100 percent power level acceptance criteria.
These signatures had not
been entered.
Licensee management stated that all 100 percent power
i
level acceptance criteria had been verified as having-been met in the
subtier procedures listed in Attachment A.
The NRC inspectors verified
that satisfaction of acceptance criteria had been verified by the
licansee. The REP 2302.034 chronological log, refler ed that the final
startup test was completed, and that Unit 2 began routine Cycle 7
operation on June 4, 1988. However, a formal determination that all
1
requirements of the startup testing program had been satisfied, which
)
would have been signified by completion of REP 2302.034 as discussed
above, was not made. This is an apparent violation of 10 CFR 50 Appendix B,
Criterion XI, "Test Control," which require. documentation of satisfaction
of all test requirements prior to placing a tystem in service.
(368/S822-01)
Another discrepancy in REP 2302.034 involved a conflict between Limit 5.5
!
and procedure Step 8.4.
Limit 5.5 stated that power ascension to less
than 30 percent of rated thermal power, shall be less than 3 percent per
hour. Step 8.4 stated that the power ascension rate should be about
3 percent per hour, but not more than 5 percent per hour. However, it
also directed the power increase to be in accordance with OP 2102.04,
"Power Operation," which required a rate of less than 3 percent per hour
,
i
as stated in Limit 5.5.
The NRC inspector confirmed with the Reactor
l
Engineering Superintendent that Limit 5.5 was valid. He was also infonned
that the actual rate of increase was less than 3 percent per hour because
'
of familiarity of reactor engineering and operations personnel with the
limit and compliance with OP 2102.04. However, the error in Step 8.4 of
REP 2302.034 could have caused a violation of Limit 5.5 and thereby
constituted an apparent violation of 10 CFR 50, Appendix B, Criterion V,
,
!
"Instructions, Procedures, and Drawings," in that the procedure was
i
inappropriate for the circumstances.
(368/8822-02)
It was also noted
i
'
that in performing REP 2302.034, the licensee failed to identify and,
'
therefore, to initiate a procedure change to correct this procedure
anomaly.
In addition to specific reactor physics tests discussed in detail below,
,
the NRC inspectors reviewed data for the following measurements / tests:
)
REP 2302.022, Revision 6. "Initial Criticality Following Refueling"
REP 2302.036, Revision 4 "Process Variable Intercomparison"
'
l
i
-
I
-
-
-
-
-
-
- -
-
-
--
_
__
,
e
S
.
I
REP 2302.044, Revision S "Hot Functional Data Collection"
'
,
A general NRC inspector observation concerning the data discussed above,
as well as the following subparagraphs, involved changes.
It is a
customary industry practice to initial and date changes in data.
However,
it was observed that the changes in the data reviewed were initialed but
not dated. This made it difficult to follow the sequence of testing in
some instances.
,
a.
Surveillance of Core Power Distribution Limits
(61702)
i
The results of REP 2302.039, "Core Power Distribution Following
Refueling," were reviewed by the NRC inspectors.
These results were
'
compared with predicted values to determine that there were no major
deviations. Additionally, the NRC inspectors reviewed documents to
,
ascertain that the latest revision to the licensee's data analysis
code, "CECORE," had been reviewed and approved by the Office of
Nuclear Reutor Regulation (NRR) prior to being used for the test.
l
b.
Calibration of Nuclear Instrementation Systems
(61705)
i
The test results for the following procedures were checked by the NRC
a
inspectors, to verify that they were reviewed, approved, and
j
documented in accordance with the licensee's administrative control
procedures,
i
i
REP-2302.001, Incore Detector Channel Check
REP-2302.100 Excore Instrument Channel A (C) Test ( .102)
REP-2304.104, Excore Instrument Channel A Calibration
REP-2304.146, Startup Channels 1 and 2 Calibration
The NRC inspector observed, while reviewing RE-2304.104, that
Section 6.13 stated "out-of-tolerance events shall be listed on
Attschment 2 "List of Equipment Found Out-of-Tolerance." Contrary
to this requirement, several identified "out-of-tolerance" events
'
were not listed.
This was a violation of the licensee's procedure.
It was also observed that the licensee's Quality Control (QC)
department identified the omission and had already returned the
,
procedure to the appropriate department for correction.
In addition
,
AP&L management had initiated corrective measures, beginning with the
generation of an internal Memorandum AN0-88-06347, dated June 20,
4
1988, which addressed errors and omissions that were identified by
q
the QC department. The memorandum called for a greater attention to
detail by the people performing the tests an improved review
process, which included increased participation from supervision.
The
,
!
NRC inspectors concluded that the licensee should be given credit for
!
self-identification of this apparent violation per 10 CFR 2.201.
NRC
'
inspectors will monitor the licensee's progress in this area during
j
subsequent inspections.
i
l
- -
- - -
.
,,
.
._
.
.
.-
-
-
-- -
.
.
6
,
I
c.
Core Thermal Power Evaluation (61706)
REP-2302.035, "Nuclear Thermal Power Calculation," was reviewed by
the NRC inspector to determine the correctness of the licensee's core
thermal power calculations.
This was done by independently
calculating the core thermal power using the licensee's procedure for
manual calculations. The independent calculations revealed no
discrepancies.
d.
Determination of Reactor Shutdown Margin (61707)
4
The results for REP-2302.28 "Determination of Critical Baron
Concentration and Inverse Boron Worth," and OP-2103.015 "Reactivity
,
Balance Calculation," were reviewed for agreement between the cvsrall
core reactivity balance and the predicted values for surveillance
tests performed in the last six months.
The NRC inspectors also
checked and verified that the licenfee had reviewed all data supplied
by the fuel vendor that is used in the shutdown margin determination.
i
e.
Isothermal and Moderator Temperature Coefficient Determination
I
(61708)
The results for REP-2302.026, "Isothermal Temperature Coefficient
Determination," were reviewed by the NRC inspectors to ensure that
4
the Isothermal Temperature Coefficient (ITC) was calculated correctly
and was within the limits established in the Techr,1 cal
Specifications (TS) and the limits predicted by the vendor.
NRC
inspectors also verified that the actual plant conditions established
during the test were the same as those assumed in the analytical
predictions.
!
f.
Total Power Coefficient of Reactivity (61709)
!
i
.i
The REP 2302.009 Revicion 13. "Moderator Temperature
!
Coefficient (MTC) at Power," data were reviewed to confinn
conformence to the Cycle 7 Reload Analysis Report and compliance with
the TS. Acceptance criteria were satisfied and no deficiencies were
^
noted.
g.
Control Rod Worth Measurements
161710)
The results for Procedure REP-2302.003, "Detennination of CEA Group
)
Worth by Exchange" were reviewed by the NRC inspectors to determine
that '.he values obtained for control rod bank worths were within the
i
acceptance criteria generated from analytical predictions of core
reactivity and control rod neutron absorption characteristics. There
were no deficiencies noted.
I
j
i
i
1
l
-
-
- -
- -
7,
_.
._
.__
_
_
.
_
.
.
_ _ . .
.
-
.
.
4
l
7
!
l
0.
Surv_eillance Procedures and Records
(IP 61700)
.
The purpose of the inspection was to review the licensee's surveillance of
-
safety-telated systems and components to determine that they are being
'
conducted in accordance with approved procedures, as required by the TS.
.
The NRC inspector reviewed Procedures 1000.09, "Surveillance Test Program
Control," Revision 18 dated May 19, 1980. and 1001.009, "Master Test
Control List," Revision 13, dated April 18, 1988. These are the
i
administrative procedures for the surveillance program and provide for
t
definition of terms, assignment of responsibilities and general guidance
for conducting the program. This covers planning, scheduling, and
followup for late surveillances.
4
'
The following completed surveillance tests were reviewed by the NRC
i
inspector.
This review also covered the text of each procedure to verify
-
that the technical content met the TS requirements and that the procedure
4
was clearly written and usable by the performing personnel:
4
'
Unit 1
No.
Title
Rev.
Date
1304.27
Process Radiation Monitoring System
4
05/25/86
Calibration
i
.
3
1304.61
Stack Flow Instrumentation Calibration
1
03/29/86
,
i
1802.06
In-Pl:,ce Leak Testing of Ventilation Systems
Containing HEPA & Carbon Filters
7
05/28/87
1
.
1304.12
Borated Water Storage Tank Level and
Temperature Instrumentation Surveillance
11
02/03/88
i
Test
1306.12
Borated Water Storage Tank Visual Inspection
1
09/26/86
i
1304.06
Condansate Storage Tank Level Instrument
i
Surveillance Test
0
08/07/86
1
j
1104.36
Emergency Diesel Generator Operation
24
03/05/87
!
1304.145
EFIC Channal A Monthly Test
3
03/04/87
)
.
1304.37
Unit 1 Reactor Protection System Channel A
J
Test
15
02/26/88
i'
1306.19
Emergency Cooling Pond Sounding
2
11/06/87
1105.05
EFIC Functional Test
10
10/23/86
.
j
1305.15
Fire Damper Surveillance Test
0
07/17/86
1
3
.
.
.
-
-
-
-
.
-
.
,
.
8
1306.05
Fire Door Inspection Procedure
6
12/18/87
1304.20
Reactor Building Access and Ventilation
Leak Rate Testing
3
10/03/86
1104.05 Sup.3
R. B. Spray Pump P-35A Quarterly Test
22
01/04/88
1305.06
Integrated ES System Test
8
12/05/86
1403.151
Relay Calibration for DGI Diesel Generatar
1
05/29/86
1107.01 Sup.5 Electrical Systems Operation
28
08/25/87
Unit 2
No.
Title
Rev.
Date
2104.36 Sup.S Diesel Generator 2DGI 18-month
Operational Test
26
10/02/87
2104.36 Sup.4 Diesel Generator 2DG2 18-month
Operation Test
26
10/02/87
2104.36 Sup.5 Diesel Generator Fuel Oil Transfer Pump
Crossover Test
24
11/12/86
2309.01
Emergency Diesel Generator Load Verification
0
05/03/85
2107.01 Sup.2 Monthly Unit II Auxiliary Transformer
Checks
24
09/08/87
2304.64
Boric Acid Tank Instrumentation
3
10/31/85
2105.018
CEA Position Lng
10
N/D
2105.09 APP.A CEA Excercise Test
6
12/09/86
2104.05 Sup.1 2P-35A Monthly Test
24
11/25/87
(Containment Spray System)
2104.05 Sup.2 2P-35B Monthly Test
24
11/25/87
1
2403.23
2012 Quarterly Surveillance
6
01/14/88
(station battery)
2403.24
2011 Quarterly Surveillance
6
10/15/87
2106.06 Sup.1 Emergency Feedwater System
Operations Monthly 2P7A Test
24
11/03/87
2106.06 Sup.2 Emergency Feedwater System Operation
'
Monthly 2P78 Test
24
11/03/87
-
.
, , ,
-
_
_.
.
.
9
2305.03
ESF System Response Time Test
5
03/04/88
2307.12
Fire Detection Ins.rumentation Operability
11
11/13/86
1306.15
Fire Hose Station Testing and Hydro Test
8
03/27/87
1308.01
Fire Extinguisher Equipment Inspection
10
03/12/88
,
2304.001
HPST Flow and Pressure Instrumentation
3
02/19/86
2104.39 Suo.1 HPSI System Operation
18
10/16/8F
2104.39 Sup.2 HPSI System Operation
18
10/16/86
2104.39 Sup.3 HPSI System Operation
18
10/16/86
2403.24
2011 Quarterly Surveillance
6
10/15/87
(station b:.i tery)
This review verified that each surveillance test procedure included
prerequisites, preparations and acceptance criteria.
Instructions were
included after each surveillance test to ensure systems or components were
restored to operation.
~
The review also verified that completed tests had been reviewed as
required by plant administrative procedures, surveillance tests were
performed within the time frequencies specified by the TS, and
appropriate action was taken for any item failing the acceptance criteria.
During review of the numerous microfilmed records required by this
.
inspection, the NRC inspector observed an apparent downtrend in the
quality o'f the microfilm.
Documents were found filmel. upside-down,
reversed, and double imaged. The NRC inspector informed licensee
representatives of the observations and the need for a review of the
adequacy of quality control for records.
No violations or deviations were identified.
4.
Exit Interview
The NRC inspectors met with the licensee representatives denoted in
paragraph 1 on July 15, 1988, and summarized the scope and findings of
this inspection. The licensee did not identify as proprietary any of the
materiais provided to, or reviewed by, the inspectors during this
inspection.
. - .