ML20151P369

Insp Repts 50-313/88-22 & 50-368/88-22 on 880711-15. Violations Noted.Major Areas Inspected:Cycle 7 Startup Testing for Unit 2 & Surveillance Procedures & Records for Both Facilities

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: ML20151P365 ML20151P369
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 NPF-6

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: ANO, Russellville, Arkansas

Inspection Conducted: July 11-15, 1988

l -

Inspectors: A 46

Reactor Ipspector, Test Programs

f!///7

Date'

H.Section,

F. Bundt,ivision

D of Reactor Safety

M.

f . . -

tor, Test Programs

W

D6te~

TV

E.' Murphy,

Section, fresctor/

Division of Re Ins @ actor Safety

Accompanying

Personnel: R. V. Azua, Reactor Inspector, Test Programs

Section, Division of Reacter Safety

'

/

Approved: "

(# l

W. C. Seidle) Chief, Test Programs Section Date

Division of Reactor Safety

l

l

1

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

!  ;

1

4

i

i

i

i

!

"

l

'

1

, - --

--- _-

. .- . , .. - - , .

-,

"

.,

. 1

3 1

I

I

DETAILS l

1

1. Persons Contacted ]

AP&L

• J. M. Levine, Executtve Director, Nuclear Operations I

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 l

• P. Michalk, Licensing Specialist

NRC l

• R. Haag, Resident Inspector

The NRC inspectors also interviewed other licensee personnel during the

inspection. .

l

• Denotes those attending the exit interview on July 15, 1988.  ;

1

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 l

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

i the 100 percent power test plateau had been met. This step had not been 1

} 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 l

of 100 percent power level acceptance criteria. These signatures had not I

been entered. Licensee management stated that all 100 percent power i

level acceptance criteria had been verified as having-been met in the l

subtier procedures listed in Attachment A. The NRC inspectors verified I

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 i

hour. Step 8.4 stated that the power ascension rate should be about l

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'

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

a The test results for the following procedures were checked by the NRC

inspectors, to verify that they were reviewed, approved, and

j documented in accordance with the licensee's administrative control

i procedures,

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 l

'

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

4 generation of an internal Memorandum AN0-88-06347, dated June 20,

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 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

4 Determination," were reviewed by the NRC inspectors to ensure that

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

i

that '.he values obtained for control rod bank worths were within the

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

7

l

!

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

i

Control List," Revision 13, dated April 18, 1988. These are the

t administrative procedures for the surveillance program and provide for

definition of terms, assignment of responsibilities and general guidance

for conducting the program. This covers planning, scheduling, and

4 followup for late surveillances.

'

The following completed surveillance tests were reviewed by the NRC i

inspector. This review also covered the text of each procedure to verify -

4 that the technical content met the TS requirements and that the procedure

4

was clearly written and usable by the performing personnel:

'

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

1

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

1

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.

. - .