IR 05000313/1997004

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-313/97-04 & 50-368/97-04.Corrective Actions Will Be Reviewed During Future Insp

ML20216E334
Person / Time
Site:	Arkansas Nuclear
Issue date:	09/05/1997
From:	Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Hutchinson C ENTERGY OPERATIONS, INC.
References
50-313-97-04, 50-313-97-4, 50-368-97-04, 50-368-97-4, NUDOCS 9709100150
Download: ML20216E334 (4)

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ARLINGdEP. - 5 1997 T E xA5 760114064 C. Randy Hutchinson, Vice President t Operations

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Arkansas Nuclear One

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Entergy Operations, Inc.

1448 S.R. 333 Russellville, Arkansas 72801 0907 SUBJECT: NRC INSPECTION REPORT 50 313/97 f14; 50 368/97 04 l

Dear Mr. Hutchinson:

Thank you for your letter of August 28,1997, regarding the referenced Notice of j Violation for failure to properly determine the need for a Safety Evaluation for changes to

the analytical basis of the trip setpoint for the logarithmic power high level, as required by 10 CFR 50.59. We will review the implementation of your corrective actions during a

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future inspection to determine that full compliance has been achieved and will be j- maintained.

Sincerely,

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, Director ivision Re ctor Projects Docket Nos.: 50 313 50 368 '

t License Nos.: DPR 51 NPF 6 f

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Executive Vice President

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Entergy Operations, Inc.

P.O. Box 31995

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Entergy Operations, Inc. 2-Vice President Operations Support Entergy Operations, Inc.

P.O. Box 31995 -

Jackson, Mississippl 39286 Manager, Washington Nuclear Operations ABB Combustion Engineering Nuclear Power 12300 Twinbrook Parkway, Suite 330 Rockville, Maryland 20852 County Judge of Pope County Pope County Courthouse Russellville, Arkansas- 72801

- Winston & Strawn 1400 L Street, N.W.

Washington, D.C. 20005 3502 David D. Snellings, Jr., Director Division of Radiation Control and Emergency Management )

Arkansas Department of Health 4815 West Markham Street, Mail Slot 30 Little Rock, Arkansas 72205 3867 Manager Rockville Nuclear Licensing Framatome Technologies

- 1700 Rockville Pike, Suite 525 Rockville, Maryland 20852

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Regional Administrator Resident inspector  ;

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DOCUMENT NAME: _ R:\_ANO\AN704AK.KMK To receive copy of document, ind6cate in box: "C" * Copy wthout enclosures "E" * Copy with enclosures "N" = No copy RIV:DRP/C C:DT/p D:DRP ,. j {/ )

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Entergy Operations, Inc. 3-SEP - 51997 M$iMM$U bec distrib. by RIV:

Regional Administrator Resident inspector DRP Director MIS System Branch Chief (DRP/C) RIV File Project Engineer (DRP/C) DRS PSB Branch Chief (DRP\TSS)

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DOCUMENT NAME: R:\_ANO\AN704AK.KMK To receive copy of document. Indicate in box: "C" * Copy without enclosures "E" * Copy with enclosures *N" * No copy l RIV:DRP/C C:DT/p D:DRP ,, jy lCSMarschall;df Gtt1\ EECbnins TPGwynn/;,j l9/c{ /97 9/.5/97 9/) /97 f/

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Tei$31 f!$ 5X0 August 28,1997 ^

~ J Lg 10CFR2.201 2CAN089706 -A i U. S. Nucleu Regulatory Conunission Document Control Desk, OPl-17 Washington, DC 20555

Subject: Arkansas Nuclear One - Unit 2 Docket No. 50-368  !

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License No. NPF 6 Response To Inspection Report 50-368/97-04 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.

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

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Very tmly yours,

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Dwight C. Mims Director, Nuclear Safety

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DCM/mkg Attachment  :

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, , August 28,1997 2CAN089706

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cc: - Mr, Ellis W. Merschoff Regional Administrator

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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

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

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

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section, to the extent that these changes constitute changes in the facility as i

described in the Safety Analysis Report (SA.R) or to the extent that they i

constituto changes in procedures as described in the SAR. These records must include a %1itten safety evaluation which provides the bases for the determination that the change, test, or experiment does not involve an unreviewed safety question.

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 retum the trip setpoint for the logarithmic power level - high to s0.75 percent of '

rated thermal power was based on an analytical setpoint of 4 percent and 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.

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

Response to Notice Of Violation 368/9704-02 (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 resising the procedure was directly linked to a change in analytical assumption values contained in the SAR.

In early 1996, another 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 logarittunic i

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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 feature 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 logaritlunic power chumel trip setpoints.

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As an interim corrective action, a temporary change to the plant heatup procedure was approved based upon ABB-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 peformed for the interim procedure change wat 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% ofrated power, Based on the above eva!uation, the plant heatup procedure was revised to re-establish 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 %

analyticallimit 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 bsen taken and the results achieved:

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

The events surrounding this violation were discussed with the individuals who perfonned the 10CFR50.59 Determination and procedure change which returned the setpoint to 0.75% rated power, (3) Corrective stens 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.

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

Lessons learned regarding issuance of initial analyses will be discussed with appropriate engineering personnel during ungineering Suppon 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 efEct 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 enmpliance will be achievet 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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