ML20236J028

Forwards Draft Safety Evaluation of Auxiliary Feedwater Sys (Generic Issue 124) Re ANO-2.Preliminary Findings Discussed at 870610 Public Meeting,Still Being Reviewed

ML20236J028
Person / Time
Site:	Arkansas Nuclear
Issue date:	07/31/1987
From:	Richard Lee Office of Nuclear Reactor Regulation
To:	Tison Campbell ARKANSAS POWER & LIGHT CO.
References
REF-GTECI-124, REF-GTECI-NI, TASK-124, TASK-OR NUDOCS 8708060022
Download: ML20236J028 (68)

Text

{{#Wiki_filter:i July 31, 1987 j 5 - Docket No. 50-368 i Mr. T. Gene Campbell i Vice President, Nuclear i Operations Arkansas Power and Light Company P. O. Box 551 Little Rock, Arkansas 72203

Dear Mr. Campbell:

Enclosed for your information is a draft report identifying staff preliminary findings concerning the ANO-2 Emergency Feedwater System (EFWS) as part of our efforts under GI-124, Auxiliary Feedwater System Reliability. These preliminary findings, which were discussed with members of your staff at a public meeting held on June 10, 1987 at the NRC office in Bethesda, Maryland, are still being reviewed by the NRC staff. Accordingly, these preliminary findings do not constitute NRC requirements at this time. The enclosed draft report is being issued at this time for the sole purpose of facilitating our dialogue concerning ] the reliability of the ANO-2 EFWS. If you have any questions or comments concerning this letter, please contact us. I I I Sincerely, j i l'5f Robert S. Lee, Project Manager Project Directorate - IV Division of Reactor Projects - III, IV, V and Special Projects l l

Enclosure:

l As stated i 1 cc w/ enclosure: l See next page j DISTRIBUTION Docket File' NRC PDR Local PDR PD4 Reading F. Schroeder J. Calvo P. Noonan R. Lee OGC-Bethesda E. Jordan J. Partlow ACRS (10) PD4 Plant File R 4 PM PD4/D S W NRR/ SAD 'Ee. JCalvo AThadani 7/3 /87 7/3l/87 7 /87 8708060022 870731 1 DR ADOCK 050 0 l t

.j Mr. T. Gene Campbell Arkansas Nuclear One Arkansas Power & Light Company Unit No. 2 cc: Mr. J. Ted Enos, Manager Mr. - Charlie B. Brinkman, Manager Nuclear. Engineering and Licensing Washington Nuclear Operations Arkansas Power and Light Company C-E Power Systems 3 P. O. Box 551 7910 Woodmont Avenue i Little Rock, Arkansas 72203 Suite 1310 Bethesda, Maryland 208?.4 Mr. James M. Levine, Director l Site Nuclear Operations 'I Arkansas Nuclear One P. O. Box 608 Russellville, Arkansas 72801 Nicholas S. Reynolds, Esq. ) Bishop, Liberman, Cook, Purcell & Reynolds 1200 Seventeenth Street, N.W. 1 Suite 700 Washington, D.C. 20036 1 Regional Administrator, Region IV U.S. Nuclear' Regulatory Commission Office of Executive Director for Operations 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 l Senior Resident Inspector U.S. Nuclear Regulatory Commission l P. O. Box 2090 l Russellville, Arkansas 72801 1 Ms. Greta Dieus, Director Division of Environmental Health Protection Arkansas Department of Health 4815 West Markam Street Little Rock, Arkansas 72201 l 4 Mr. Robert B. Borsum i Babcock & Wilcox 3 Nuclear Power Generation Division Suite 220 7910 Woodmont Avenue Bethesda, Maryland 20814

e 9 .w.._..--. ..._.s.-...- - w..A -- - e T s k, b 2d 'd{ l SAFETY EVALUATION OF THE AUXILIARY FEEDWATER SYSTEM (GENERIC ISSUE NO. 124) WITH RESPECT TO ARKANSAS NUCLEAR ONE GENERATING PLANT UNIT 2 k ~ T:7 bane i 2

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. 22 cR d------ F w --0 '4 4' s.. r p3 ,,s. l Table of Contents' A. Executive Summary and conclusions ii B. Introduction 1 C. ' Resolution Approach 2 ' D. Evaluations D.1 Design'and Configuration '4 D.2 Maintenance, Surveillance and Testing 10 1 D. 3 Emergency Operating Procedures 17 D.4 Instrumentation and Control 23 i i D.5 System Walkdown 32 D.6 Training 41 0.7 Operating Experience and Reliability Analysis 44 Appendix A - References 50 Appendix B - Individuals involved in the AFW System Review 52 l I i 1 a 4 -i-

\\ j ...a.. i ~ Arkansas Nuclear One, Unit 2 - Auxiliary Feedwater l System Reliability Assessment A. Executive Summary and Conclusions l This report contains the staff's assessment of the Auxiliary Feedwater System ] l (AFWS) overall reliability for Arkansas Nuclear One, Unit 2 (ANO-2). This I review was performed in connection with the resolution of Generic Issue (GI-124), ) l " Auxiliary Feedwater System Reliability," which addresses the AFWS reliability. l Reliability analyses for AFWSs indicated that many plants fell in the high l reliability range. However, several plants fell in the. lower reliability. j ranges. Some licensees for this latter group of plants implemented sufficient I modifications to increase their AFWS reliabilities to an acceptable range. However, AFWS reliability for seven plants, including ANO-2, remained questionable. The six other plants include ANO-1, Crystal River, Ft. Calhoun, l Prairie Island, Units 1 and 2, and Rancho Seco. The review of the Prairie Island plants under GI-124'has been completed.* j i I The objective of this task is to determine whether the AFWS of each of the j subject seven plants is sufficiently reliable and to document any j findings for further licensee or staff action. Although the staff believes the AFWS reliability in particular and the plant safety and overall' reliability in general are functions of time and should be -l continuously monitored, an audit of certain plant features and operations can provide significant insights. Therefore, the resolution approach adopted by by the AFWS review team relied on an audit of several plant features that l directly or indirectly affect the availability and reliability of the AFW l system. These variables include design configurations; maintenance, surveillance and testing procedures and practices; operating procedures; personnel training; system layout; instrumentation and control; and environ-ment and accessibility for operator recovery actions following potential l malfunctions. The AFWS review team auci.i.. conducted for the above plant Letter from G. Lear, NRC to D. Musolf, Northern States Power, November 25, 1986. -ii-

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4: ) DRjfT i ! features is not intended to replace other systematic staff reviews of any l .these variables but merely assesses their effects on-the overall AFWS ] reliability and availability. 'The resolution effort also included the review of the plant post-TMI modifications. ) l A five person review team reviewed documents and conducted interviews with a maintenance, operations, engineering,.and training personnel and management. j The team review included a three day plant site visit, and pre-visit and. post-visit reviews. j l i Upon completion of the above described review and after resolving the staff j concerns listed below, the review team concludes that the ANO-2 Auxiliary Feedwater System is adequately designed, properly maintained, and well operated. The staff also concludes that the AFW system design, maintenance, and operation adequately consider other staff generic concerns raised within GI-124 (i.e., GI-68 with respect to environmental qualifications of the motor driven AFW pump, GI-93 with respect to steam binding of the AFW pumps, GI-122.1.a, b, and c with respect to isolation valve failure, and interruption and recovery of AFW flow, GI-122.2 with respect tt initiation of feed and bleed, and GI-125.II.1.b with respect to single failure protection of existing AFW systems). Based on staff review and observations and based on the licensee's statements, we conclude that the licensee is actively pursuing improvements in the AFW I system rel.iability and availability. The licensee's statistical anal' sis y conducted for the last six year period for the ANO-2 AFWS-related failures shows a rapidly decreasing failure rate trend with no significant failures since 1983. This indicates a substantial improvement in equipment performance. As discussed later, the majority of equipment failures over a five year period from 1981 through 1985 was determined to be readily recoverable at the equipment location. Therefore, the staff believes that ease of access to various AFWS equipment is of paramount importance to the overall system reliability and availability. Ease of access includes factors like normal and emergency lighting, adequate communications, clear and legible equipment identification, and availability of tools ~that may be necessary to exercise this equipment. These issues are discussed in detail in Section D.S. -iii-I

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?^- -1 'Although significant improvements in valve performance has resulted over the last few years, the licensee's adoption of the MOVATS* methodology for val 1 setpoint setting (see Section D.2.2) is expected to further improve valve performance. The licensee's emergency operating procedures (EOPs) explicitly and clearly instruct the operators, if the AFW flow cannot be established, to attempt to reestablish'the MFW flow or, if.that'is unsuccessful, to rely on the condensate J pump flow. The E0Ps provide guidance and precautions about-degraded modes of I equipment operations if necessary. If all MFW and AFW are not readily recoverable, the FOPS instruct the operator to initiate the " feed and bleed" mode of decay heat removal. The staff has certain concerns with the " feed and bleed" capability, operability requirements, and emergency operation (see Section D.3). The ANO-2 " feed and bleed" system does however provide redundant flow paths with a dedicated 3-inch. diameter line with two motor operated valves in series and a parallel path with two low temperature overpressure protection valves. This size flow path is sufficient to depressurize the reactor coolant system to allow the high head safety injection pumps flow in the reactor vessel for core cooling. The valves have not been demonstrated to be qualified to close under feed and bleed conditions. i i As discussed in Section D.7, the plant's rate of unanticipated automatic reactor scrams is high (5 per year in'1986), however, it has been steadily decreasing. 4 Also, the fa'ilure rate of its two emergency diesel generators has been relatively low. The latest systematic assessment of licensee performance (SALP) rating for ANO-2 covered the period of July 1985 through December 1986, and was 1, 2, and 2 for operation, maintenance, and surveillance', respectively. A SALP rating of I calls for reduced NRC attention, and indicates that the licensee managenent attention and involvement are aggressive and oriented toward nuclear safety. A SALP rating of 2 calls for normal levels of NRC attention, and indicates that the licensee management attention and involvement are evident and concerned with nuclear safety. Based on the above, the staff concludes.that, upon adequate conside:; tion of staff concerns, which are summarized below, the ANO-2 AFW system and alternate MOVATS = Motor Operated Valve Testing System -iv-O >.;.w e e

i .u.a._. .. :,.w. - - - c. u 1.c 2,. s m - n.~ l 1 means of decay heat rImoval and their support systems are well designed, l instrumented, maintained, and operated, and that the licensee has adequate E0Ps, and training program as pertinent to the AFW system. The staff, therefore, concludes that, upon addressing the following concerns, the ANO-2 AFWS is sufficiently reliable. I l 1 These concerns are: j 1. The licensee should justify, using a reliability analysis based on plant-specific operating experience, whether the closed position of the first AFWS discharge valve in each discharge line is optimum for safety (See Section D.1.2). .i l 2. The licensee should propose appropriate Technical Specifications for the pressurizer vent valves and low temperature overpressure protection valves (Section D.3.2). { 3. The licensee should confirm whether one low temperature overpressure protection valve is sufficient for decay heat removal via " feed and bleed" (Section D.3.2). 4. What constitutes " abnormal" in the E0P should be adequately discussed during training (Section D.3.2). 5. Clear instructions as to whether or not to use certain key equipment should be included at the appropriate steps in the Inadequate Core Cooling section of the E0P (Section D.3.2). 6. The licensee should specify in the operator training the length of time, I after loss of all feedwater conditions are reached, in which feed and bleed cooling will be effective (Section D.3.2). 7. The licensee should verify the basis for the environmental qualification of the AFW valves, and remove discrepancies in referencing Q-listed valves (Section D.5.2). 8. The licensee should maintain'all available communication means, including the public announcement (PA) system in a ready and operable condition (Section D.5.2). _v. 3 1 l

s m._ o m m. ,... c. - -s.www~eea.+muaam>U N wh "'- - 4' 9. The licensee should improve normal and emergency ac lighting, and esemgancyg de lighting, in the vicinity of the AFW pump rooms (Section D.5.2). 10. The 11censee should maintain the cleanliness of the AFWS equipment and its surroundings (Section D.5.2).

11. The licensee should relocate and orient (as appropriate) the AFW discharge I

i piping temperature, pressure, and turbine speed gauges to be readily ) visible (Section D.5.2). 12. The licensee should ensure the integrity of all equipment supports in the AFW system (Section D.5.2). l 4

13. The licensee should complete the retagging program for the AFW system

) (Section D.5.2). } l I

14. The licensee should develop a " maximum time to access" from the control

{ room, for each piece'of AFWS equipment that may potentially be manually exercised during emergency decay heat removal, and for the atmospheric _ f dump valves (Section D.5.3). { {

15. The licensee should pursue its trip reduction program to decrease the unscheduled automatic reactor trip r1tte (Section D.7.2).

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16. The licensee should complete its AFWS reliability analysis and implement changes that provide significant improvements to the system reliability based on that analysis (Section D.7.2).

The lic'ensee should provide an alternate method of providing water to the 17. steam generators such as a connection to the auxiliary feedwater system at Unit 1. The operability of this source of water should be required by the plant's Technical Specifications (Section D.7.3). J

18. The licensee should emphasize, in its operator

• training program, the graveness of not initiating the " feed and bleed" where a genuine total loss of feedwater is suspected. Training on recognition and mitigation of such an event should also be emphasized (Section D.7.2).

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e Arkansas Nuclear One, Unit 2 - Auxiliary Feedwater ' j System Reliability Assessment 1 i B. Introduction This rep' ort contains the staff's assessment of the Auxiliary Feedwater System (AFWS) reliability of Arkansas Nuclear One, Unit 2 (ANO-2)'. This is being I done in connection with the resolution of Generic Issue (GI) 124. GI-124, " Auxiliary Feedwater System Reliability," addresses the reliability of AFWSs. Reliability analyses

• for AFWSs indicated that many plants fell in the high reliability range. However, several plants fell in the lower reliability ranges. Licensees for some of these plants implemented sufficient modifi-i cations to increase their AFWS reliability to an acceptable range. However, the reliability of the AFWSs for seven plants, including ANO-2, remained questionable. The six other plants are ANO-1, Crystal River, Ft. Calhoun, J

Prairie Island, Units 1 and 2, and Rancho Seco. ') The objective of this task is to determine whether the AFWS of each of the subject seven plants is sufficiently reliable and tn document any recommendations for further licensee or staff actions. This report presents the resolution approach and evaluation philosophy in Section C, and detailed evaluations in Section D. The summary and conclusions are presented in Section A of this report. Appendix A contains the references. l Appendix B lists the names of the NRC and licensee personnel who participated in this task.

• NUREG-0611, and NUREG-0635, Generic Evaluation of Fr ter Transients and Small Break LOCA in Westinghouse and CE Designed Pla.,

respectively, and NRC memoranda from A. Thadani to 0. Parr dated October 17, 1983, October 23, 1983, and November 9, 1984. I i i E-________--_------- -J

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1 C. Resolution Approach The staff believes that a high degree of availability and reliability for the AFWS can only be achieved if such a system is adequately designed, properly maintained and well operated. Proper maintenance and operating practices help reduce component failures. These pract' ices are enhanced by good training ~ programs for the maintenance and operations personnel. Geod training programs I also help the operations personnel understand the system's capabilities and its l l l importance to safety. System understanding reduces failure due to maloperation l of' equipment and improves the likelihood of recovery in case of unanticipated ) component failures. The staff believes that assessment of the above variables should provide a .j significant indication of the degree of reliability of the AFWS. Therefore, the resolution approach adopted by the staff. relied on'an. audit of several plant variables that directly or indirectly affect the availability and I reliability of the AFW system. The main items of this task include the Vollowing: 1 l 1. Consideration of relevant information pertaining to the AFWS and support systems capability and reliability (e.g., Systems Descriptions, Piping and' Instrumentation Diagrams, Logic Diagrams, Safety Analyses. Reports, AFWS Reliability Analyses, INPO Reports, AEOD and IE Reports, and staff Safety i Evaluation Reports). I l 2. Evaluation of plant operating experience with emphasis on the degree of failure repetitiveness and the rate of unanticipated automatic scrams. 3. Evaluation of the AFWS maintenance, surveillance and testing, backlog of maintenance work requests, and ability for failure root-cause identification. l l 4. Evaluation of the clarity and accuracy of the AFWS-related Emergency Operating r.ocedures, with emphasis on ease of recovery from faulted conditions, accessibility of equipment and adequacy of instrumentation and controls. j ~2- )

-.'s ,._-s m., a..w a,m... m m a.m,. w.:.. ~.~. - m ] .m 5. Evaluation of the licensee's. training programs for maintenance, operations and engineering personnel. 6. Apprais'ai of the system layout, accessibility, indication and control, environment during an accident, and cleanliness, etc. I l 7. Consideration of alternate plant features to maintain adequate core cooling if main and auxiliary feedwater systems became inoperable. 8. Review of the plant post-TMI modifications. The AFWS review team audit of the above plant variables is not intended to replace other systematic staff reviews of any of these variables but, merely ) assesses their effects on the overall AFWS reliability and availability. The licensee is developing an AFWS reliability. analysis which was provided to the staff in draft form. The staff has made a preliminary review of the analysis, which is discussed in Section D.7. The seismic qualification review

• in response to Generic Letter 81-14, Seismic.

i Resistance of AFW Systems, was previously performed by the staff. That review ] determined "that the emergency feedwater system has sufficient seismic l capability to withstand a safe shutdown earthquake and accomplish its safety I function." The Appendix R fire protection staff review of AND-2 is'still'in progress. In performing this AFW reliability evaluation the staff conducted reviews of licensee-supplied documents at the NRC Headquarters, reviews of additional 1 documents at the plant site, and numerous interviews with the maintenance, operations, engineering, and. training personnel.and management. Memorandum from L. S. Rubenstein,.to G. C. Lainas, " Arkansas Nuclear One, Unit 2: Seismic Qualification of the Emergency Feedwater System", MPA C-14, dated June 18, 1984. i 9 y a e .e. . = = +.. .+,,..,4.ty j

x..:.a w. maw x >. rw a 1 m.. :- m.n.: e k 1 DRAFT The AFWS review team consisted of four multidiscipline team members and a team leader. The team effort included three day plant site visit, and pre-visit and post-visit reviews. The names and organizations of the NRC and licensee l participants are listed in Appendix B. D. 1 Desion and Configuration D.1.1 Approach The staff conducted a review of the design and configuration of the Arkansas Nuclear One - Unit 2 (ANO-2) auxiliary feedwater (AFW) system (in this report the phrases " auxiliary feedwater" and '! emergency feedwater" are used interchangeably). The staff reviewed the system descriptions in the updated FSAR, together with pertinent drawings and figures (Reference 1), and the Technical Specifications (Reference 2). The staff also reviewed the following for additional informa-tion: NUREG-0635 (Reference 3); and Status and Safety Analysis Reports for TMI Action Plan NUREG-0737 (Reference 4). The staff also conducted E comparison of the ANO-2 AFWS design with the Criteria of Standard Review Plan Section 10.4.9. A walkdown of the AFW system was conducted by the staff to determine the degree of ANO-2 compliance with applicable criteria and drawings. D.1.2 Evaluation ANO-2 is a CE designed 2815 MW(t) reactor, with two U-tube steam generators, two MFW trains, each with a turbine-driven pump, and with three motorwiriven condensate pumps. The reactor is also equipped with three high head safety injection pumps with a shut-off head ef 1450 psia. The pressurizer has two low-setpoint safety valves.each with two motor operated isolation valves (low temperature overpressure protection system) and a 3-inch vent valve .t arrangement for use in the " feed and bleef mode of decay heat removal. The reactor is located in a large dry reinforced concrete containment. The plant is provided with two 100% capacity diesel generators for shutdown cooling if offsite power is lost. - ..._m..- m._-..____-_

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=- _ a The ANO-2 AFW system is a two-train system. One train contains a centrifugal pump driven by an electri' motor (2P7B) and the other train contains.a steam l turbine driven pump (2P7A). Diversity in pump drivers eliminates common mode f failures in the AFWS motive power. The AFW system configuration is shown'in ' Figure 1-1. The pumps, 2P7A and 2P78, are identical. At rated flow, each pump is capable of providing 575 gpm of water, which is sufficient for rem'oving decay heat loads of 3 percent of rated thermal power. The plant is also equipped with a steam bypass system. Each of the plant's two steam lines is' equipped with an atmospheric steam dump valve (ADV) upstreem of the main steam isolation valve (MSIV). This arrangement'makes the dump valves operable even if the MSIVs are closed. Each ADV is capable of removing about 11% of rated steam flow. I The AFW pumps are horizontal, multi-stage pumps with horizontally split cases,- using double volutes at each stage and impe11ers. arranged in opposed groups for hydraulic balancing. The steam turbine driver (for 2P7A) is a single stage, solid wheel, non-condensing, horizontal, split case Te,rry turbine unit. It is oesigned for variable speed operation and is equipped with an electrohydraulic actuator for speed control, an overspeed trip mechanism, and an integral trip throttle ) valve. It is also designed for rapid starting and will operate with steam generator pressures ranging from 1,100. psia to 60 psia. -Steam can be supplied to the turbine driver from either or both steam headers.- The steam supply lines are insulated to minimir.e condensation. Also steam traps are installed on the turbine steam supply lines to continuously remove any condensate. The j turbine exhausts to the atmosphere. Cooling water for the turbine oil cooler i is piped from the pump suction line rather than from the pump. recirculation line. This is because the pressure available at the suction provides adequate j cooling water flow through.the cooler. Pump and motor bearings do not require auxiliary cooling. The electric motor driver is capable of' accelerating the pump to rated speed 1 within 4.5 seconds with 80 percent voltage and within 2.4 seconds at full voltage. The motor can be powered from normal, preferred, or emergency power j sources. l ,o pne sey 4 e- 'W > v -as eerssans enu s se .s. e e

..a:.... -...i, w. w & a ~ - = - 4 ud. u The AFWS is used for plant startup. Below five percent full power, normal suction for the AFWS pumps is the startup and blowdown dsmineralizer effluent, with provisions for trarisfer to the in-use condensate storage tank or, if j off-site power and the condensate storage tank are unavailable, to the Service-Water System (SWS). Above five percent full power, AFWS suction is shifted to the condensate storage tanks (CSTs), and the startup and blowdown demineralized source is isolated by ciasing valve 2CV-0706. The plant is provided with a 200,000 gallon capacity CST with a Technical Specification minimum value of 160,000 gallons. There is also 100,000 gallons of water available from a swing CST, which is shared by both ANO units, and can be manually lined up to either unit. The two redundant and independent 6-inch SWS lines provide an assured source of water in the case of failure of the Seismic Category 2 condensate supply line. The condensate supply line is furnished with two motor operated isolation valves, 2CV-0795 and 2CV-0789, and two pressure switches 2PIS-0795 and 2PIS-0789. The service water linas are each provided with a non-return check valve and motor operated isolation valves: 2CV-0711 and 2CV-0716. The normal pressure in the condensate line is about 10 psig. If the pressure drops to 7 (+1,-0) psig, local and control room alarms will be actuated. If the pressure drops to 5 (+1,-0) psig during an emergency operation, the pressure switches will automatically close the condensate line isolation valves, 2CV-0795 and 2CV-0789, and will simultaneously open the SWS valves 2CV-0711 and 2CV-0716. ~ The AFW pump discharge lines are provided with cross-connected flushing lines with normally closed block valves (see Figure 1-1). These flushing lines are provided in order to meet feedwater quality requirements. An air operated ) valve on each flush line is automatically closed if eme ger.cy operation of the AFWS is initiated. A pump minimum ficw recirculation line is.provided from each pump discharge bypassing the air operated flush valves. Each minimum flow line is provided with an orifice and one common globe valve for limit'ing and regulating the flow while providing a normally open flow path to ensure that each pump has a minimum flow of 50 gpm. The AFWS discharge piping a. valving arrangement, shown in Figure 1-1, is designed to allow either pump to supply cooling water to either or both steam generators. Each supply line to each steam generator is provided with, en

o a .=. m. :a.u a nu =a. mm .a.; h redundant control valves, in accordance with the single failure criteria, to ensure isolation of any faulted steam generator, and feeding of the intact steam generator as rt. quired during emergency operation of the auxiliary feedwater system following a postulated main steam or feedwater line break. l Each discharge line has a closed MOV, an open MOV, and two check valves. In addition to the check valves the closed MOVs provide an additional barrier to hot water backleakage and potential AFW pump steam binding. The closed MOVs, thus, help avoid the steam binding problem. However, these valves must open successfully in order for the AFWS to serve its safety function. The likelihood of these valves' failure to open is directly related to the adequacy of their maintenance. Given two operable check valves in series and a discharge temperature check every shift (see Section D.5, 'Walkdown) the AFWS review team believes that the risk associated with the normally closed MOVs failing to open on demand outweighs the gains with respect to steam binding. The licensee should justify, using a reliability analysis based on plant-specific operating experience, whether the current standby valve i positions (four discharge valves normally closed) are optimum for safety. Feecing of the steam generators during non-emergency cooldown is by means of the electric motor driven pump and power operated control valves 2CV-1025 i and 2CV-1075. It is also possible to use the steam turbine driven pump by l adjusting the variable speed control. The steam supply line feeding the steam ~ turbine driver provides an assured source of steam to the turbine, even when the main steam isolation valves are closed. The steam admission valves l 2CV-1000 and 2CV-1050 are normally open. When an AFWS actuation signal is l l received, bypass valve 2SV-0205-2 and the turbine cooling water solenoid I valve 2SV-0317-2 will open, and the turbine will reach idle speed, allowing f l the turbine governor hydraulic system to pressurize. Fifteen seconds later, I the main steam valve 2CV-0340-2 will open, 2SV-0205-2 will close, and the i i turbine speed comes under the governor control. Upon receipt of the automatic actuation signal the four closed discharge MOVs receive signal's to open if their respective steam generators are intact. l . I .n i L_..

. s ! ,m.:Eunw.W.O'm aa%.D & . ~.,., 1 : w i b During plant startup, the AcWS is placed in operation until sufficient steam 1s available to run the main feedwater pump turbine' drivers and the condensate and -1 feedwater system is placed in operation. -This, in effect, is a full flow test of the AFWS before it is put in the automatic standby mode. During hot standby and hot shutdown, the AFWS is placed,in operation to ^ maintain steam generator level. The average feedwater flow requirement in. this case is about 320 gpm, which is within.the rated capacity of a single AFW pump (575 gpm). i During normal cooldown, the AFWS is placed in operation to maintain steam generator level during decay heat removal operation unti.1. the RCS temperature j is brought down to about 350*F, at which time decay heat removal is switched over to the Shutdown Cooling System (SCS). The operation of the AFWS in this mode lasts about 3.4 hours at an average flow of 510 gpm. l Thelicenseenotedthatitistheirintenttosharethenew,partiaWS tornado protected, CST (originally installed for ANO-1 use) with ANO-2 and to eliminate the automatic switchover to the service water system. While the new CST will provide additional water inventory, this arrangement will also minimize inadvertent admission of-low quality service water into the steam ) generators because of~ spurious signals as has occurred in the past. The AFW pumps start automatically on a steam generator low level signal. However, if the low level signal occurs because of a break in the steam line or the feedwater line as would be evident by low pressure in one steam generator, the closed MOVs do not receive a signal to open and the open MOVs receive a i signal to close for the steam generator with the lower pressure. The essential valves in the turbine driven pump system are all powered from a de source since this system is required to operate in~the absence of all ac power. This includes all motor and solenoid operated valves at the suction and dischange sides of the pump, with the exception of steam supply valves 2CV-1000, and 2CV-1050, and condensate supply valve 2CV P')7. These valves. are ac operated, but are normally open and do not. change positions upon AFW' actuation. .g. F p-m 4 g-e not.4mp ' *>-

e . :.sm... - 2o +6 r-ha.' a Ad-U M&"h '" ,.c DEFT In the event of a complete loss of the AFW system, other methods are available 'to remove the decay heat, including (1) use of the condensate pumps, and (2) " feed and bleed." These decay heat removal methods are discussed in detail in Section D.3, Emergency Operating Procedures, of this report. l l D.1.3 Conclusion I On the basis of this evaluation we conclude that the AFW system in'the ANO-2 nuclear power plant complies with the applicable criteria of Section 10.4.9 of 1 the Standard Review Plan, including single failure considerations (this also 1 1 l addresses staff concerns raised in GI-125.II.1.b, with respect to single d failure protection for existing AFW systems), and including the guidelines of NUREG-0737, Item II.E.1.1. The staff notes that'use of the condensate 1 pumps and the " feed and bleed" capability are effective _means of decay heat removal and enhance the plant's overall capability of decay heat removal. D.2 Maintenance, Surveillance and Testina M j 1 J D.2.1 goroach ) The reliability of a system depends to a large extent on the maintenance I programs applied to such a system. The adequacy of system maintenance will be reflected by component failure rates during operation, surveillance and testing. ) The AFWS evaluation team performed a detailed audit of the AFWS-related maintenance and surveillance procedures and surveillance results. Members of the team interviewed maintenance and operations personnel and management on I the practices and organization of the maintenance programs. Training of the maintenance and operations personnel was also explored, and is further 1 discussed in Section D.6, Training. 1 1 1 4

m.?:a.Ga.,..e . :.~ a a.maa. sue:L.a2 uw ua r.sw 2 - .o.. r a ANO-2 is one of several plants for which the NRC staff evaluated the maintenance program practices. T.he staff completed its evaluation report, " Technical Letter Report, Site Survey of Arkansas Nuclear One Unit-2 Maintenance Program and Practices," and issued it in June 1986. This technical letter is provided in NUREG-1212 (Reference 5). In this reference the staff presents its evaluation of five areas at ANO-2. These are: Organization and Administration, Facilities and Equipment, Technical Procedures, Personnel, and Work Control. NUREG-1212 lists.the ANO-2 maintenance program as " Good and Improving." The NUREG lists several significant observations. The ones most relevant to the subject of this report are listed below: (1) Maintenance Department Work Control - This included a description of the newly implemented Work Control Center (WCC), and f.he Station Information Management System (SMIS), both of which are improvements over previous practice. The WCC and SIMS are discussed below. 4 (2) The use of procedures and setting of formal management goals were found to be good and highly developed. (3) Maintenance backlog due to material shortages was rare. (4) Component labelling for ANO-2 was not started at the time of staff review. The potential for mislabelling of equipment'was expressed as a staff concern. (5) ANO-2 was reasonably staffed to minimize maintenance backlog. (6) There was a formal training program in place. This is discussed in detail in Section D.6, Training. This section and Section D.6, Training, of this report supplement NUREG-1212 as it pertains to the ANO-2 AFWS. The AFWS review team endorses the NUREG-1212 findit.,: as supplemented by this report. e

-f---~="-" ~ "~ ~ u,; c. a.. .az: D.2.2 Evaluation The ANO-Unit 2 maintenance program is basically composed of two parts. The first part is the periodic maintenance (or, preventive maintenance), and surveillance and testing. These are identified in the plant operating proce-dures, maintenance procedures, and Technical Specifications. These assure that the AFW system and its support systems are kept operable and capable of reliably performing their intended function. The second part of the maintenance program is the corrective' maintenance. The responsibility of any plant worker is to spot potential system or component failures and report them. The maintenance program revolves around the work control _ center (WCC).- This system processes, monitors, and controls the maintenance job until it is completed. The process works as follows (refer to Figure 2-1 for job order flow path): When a problem is suspected a job request is initiated. The job request identifies the component by number, the problem (how the component' failed), the location, and any other pertinent information. The job request then goes to the " schedulers" in the WCC. The " schedulers" check whether the job has already been identified. If the job has not been previously identified, the job request-is then forwarded to the " planner."~ The " planner" screens the problem, at the component location if necessary, evaluates any previous events involving the component, and writes a job order. The job order fully-describes the component, the work to be done, and other pertinent information. The " planner" also assigns the job priority to one of the following categories: A. Emergency B. Priority 1 - to be done quickly C. Priority 2 - to be done within 2 days D. Priority 3 - to be done within 3 weeks Priority 2 and 3 may be done during refueling outage depending on the job. +7

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j o a f u.s 3., w.:a aa. m. m. .n. a x h m u 6 - =_ a The " planner" then returns the job order back to'the " schedulers" to sch the. job and coordinate the' work with " health physics," the parts expediter, and the cutage schedule for the plant. The package.is'then sent to the. craft superintendent for assignment to a craftsman to perform the work. The crafts-man performs the work in accordance with the job order and reports the status of the work back to the " schedulers" at. th'e end of each shift. When the job is ~ i completed'the paperwork is returned to the " planner" for review and evalvation' I of the-job order and the work. -Finally it is sent to the " work closing" group which is responsible for updating the maintenance history. This group evaluates the job order for correctness, completes a failure report which may be input in the nuclear plant reliability data system (NPRDS), and updates the .f '1 component maintenance data base. This data base is an important.part of the station information management system (SIMS). The " work closing" group then forwards the paperwork to " records." 1 A root cause analysis is performed throughout this process. The job requester does a preliminary root cause analysis when the job is requested. The planner l continues the root cause analysis by evaluating the job and the maintenance and failure history of the component in the preparation of the job order. The _] craft superintendent contributes to the root cause analysis when he receives ? ( the job order package which includes a repetitive failure printout on the component. The root cause analysis program'also includes evaluation of' ^-) unplanned trips and transients by the significant events review committee (SERC), and evaluation of reportable abnormal conditions (RACs) and licensee e event reports (LERs). Since the group of people evaluating a component failure may change from failure to failure, the staff finds that no one particular person is responsible for the AFWS operation or failure evaluations. This means that the root cause analysis for AFWS failures may rely on t.he general knowledge and expertise of the person or persons who' happen to review the failure. However, ) the newly operational SIMS data base provides a promising tool for failure trending analysis which is a significant factor in root cause determination and l i analysis. The SIMS data base, however, has been in operation for less than a l l

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,..a m.: :.r. -.. . ~... year and equipment histories are not being entered into the system retroactively. Therefore, the benefits gained from such a system in root cause analysis may be more apparent as equipment data accumulates. The usefulness of t'he SIMS data base for this purpose will depend to a large degree on the accuracy and amount-of detail of the equipment history that is entered in the system and subse-- quently retrieved for use. The review team believes that as the SIMS data base increases, and if the system is properly used for failure trending l l analysis, a significant increase in AFWS reliability and availability will result. l j l The evaluation tecm has'the following additional observations on the maintenance, surveillance and testing program: I 1. All maintenance personnel hired by the plant start at the entry level and must go through the Arkansas Power and Light Company (AP&L-the owner of Arkansas Nuclear One plants) training program. This assures uniformity in training of maintenance personnel and their knowledge of the systems and procedures. 2. If a job is unfamiliar or new, a pre-job meeting is held by the maintenance crew to discuss the procedures required and any special instructions. In addition, for a design change, the work package would specify any additional or specific training necessary for the job. These are positive features in the maintenance practices. 3. The licensee stated that the rate of maintenance staff turnover is low (between 3 - 6% per year). In previous years this rate has been high. The change is attributed to an aggressive program to retain plant workers which includes hiring more local people, training, competitive salaries and job security. The staff believes that a reduction in staff turnover rate leads to an expertise enrichment, which in turn leads to enhancing systems availability. i 4. Plant officials take pride in their high rate of ear'y reporting of incipient failures. The plant has a mandatory preventive maintenance I program for safety related equipment which goes beyond the normal technical specification' requirements.. >+se a s ee, es >e

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I ..w.L. a. ~..... -. - -. a m.eu. : .Ls~ - "-- ~ 1 5. The periodic maintenance procedures, surveillance procedures and j system operating procedures for the AFWS and its components were of ~ sufficient detail to properly complete the task. However, the staff found some discrepancies'in procedures for similar components. l Examples of these discrepancies include: cautionary notes, equipment { and parts needed for certain tasks, incomplete procedure statements, ) and undefined setpoints or tolerances existed in one procedure but not in another. These items were brought to the attention of the licensee who explained that he was in the process of revising all of the procedures and that this revision would be completed by the end of 1987. The licensee also explained that some discrepancies may be j due to the fact that different people revise different sections for similar equipment. The procedures revision includes: (a) making the procedural steps shorter and simpler (e.g., one action per step); (b) revising the format and content; (c) checking the procedure against the component technical manual to assure accuracy; and (d) including in the maintenance procedure a requirement that the first line supervisor go over the procedure with the craftsman prior to commencing work. 6. In response to IE Bulletin 85-03, with respect to motor-operated valve (MOV) limit, torque, and bypass switch setting, the licensee is j undertaking an aggressive program in testing and calibrating its valves (many with full operating AP across the valves) using the motor operated valve analysis and test system (MOVATS) methodology. In this methodology, measurement of changes in the electric current required to operate the valve motors during the valve travel are interpreted to indicate the various stresses on the valve motor, valve stem, and valve seats or ;,ates. These electric current measurements can also be used for early detection of degrading valve conditions (e.g., insufficient valve lubrication, broken stem threads,etc.). The AFWS review team believes that the licensee's approach and commitment to valve testing and calibration adequately address thc mncerns raised by GI-122.1.a. and c with respect to MOV failures and AFW flow interruption. This approach by the licensee enhances the reliability of the MOVs when called upon to operate, e n,e _._u----

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to IE Bulletin 85-03 with respect to motor oper,ated valve settings i.s i still under staff review at the time of this report writing. 7. Thelicensee'statedthatthefindingsintheANO, Unit 1safet.y system functional inspection (SSFI) report (Reference 6) relevant to ANO, Unit 2 have been implemented. Examples of the SSFI report findings included:' inadequate torque switch, and torque switch bypass settings; valves that were required to be periodically tested were not tested; controlled design documents and drawings contained j errors and omissions. The AFWS review team notes, however, that the l ANO-2 FSAR continues to have errors and discrepancies. D.2.3 Conclusions The staff review of the ANO-2 maintenance, surveillance and testing was somewhat limited due to the major procedure revision effort currently underway. The staff reviewed the latest revisions of selected AFWS procedures and relied 1 mainly on the licensee's statements in describing the procedure revision ~ effort. Based on our review of the maintenance, surveillance and testing, and based on the licensee's statements, and the status of the procedures revision effort, j the AFWS review team notes that the licensee appreciates the significance of I -important maintenance-related elements like' work control, failure trending, root cause determination, and record keeping. The AFWS review team, therefore, j expects that upon revision completion, the maintenance and surveillance program will enhance the AFWS reliability. D.3 Emeroency Operatino Procedures I D.3.1 Approach i l The staff reviewed the emergency operating procedures which included the' l overall emergency procedures and the abnormal operating procedures relating to the~AFW system (References 7, 8). The AFWS review team's objective was to-i determine whether these procedures can easily be followed and understood and. ]

. w h c,.ur b._u ....... a w w. a. e u 4...e.. ~ m1 m - - - ~ .1 e t whether they enhance the plant's overall capability to remove decay heat under emergency conditions. The licensee conducted a limited simulator demonstration of a loss of feedwater event. D.3.2 Evaluation The ANO-2 Nuclear Power Plant emargency operating procedure (EOP), E0P 2202.01, deals with various accident conditions. The conditions which initiate use of E0P 2202.01 include' automatic or manual reactor trip or indications of a steam generator tube rupture. The reactor may be tripped manually when an operator senses a condition that may damage the plant or pose injury to personnel. The operator may also trip the plant because of a failure of the reactor protection system (RPS) to function when reaching any of its setpoints. When responding to an emergency condition the operator proceeds to the proper. section in E0P 2202.01, either " Reactor Trip" or " Steam Generator Tube Rupture Within Charging Pump Capacity" wherein further directions are provided for recovery from these conditions. The reactor tr'ip section may direct the operator to other sections as appropriate. The other E0P sections are contained in the same document and include: 1. Degraded Power, 2.

Blackout, 3.

Overcooling, 4. Main Steam Isolation, 5. Safety Injection Actuation, 6. Steam Generator Tube Rupture Within Charging Pump Capacity, 7. Steam Generator Tube Rupture Greater than Charging Pump Capacity, 8. Inadequate Core Cooling, and 9. Emergency Reactivity Control. Any section may then refer to other sections or to other actions required in the recovery process. All of these sections refer to the operation of the AFW system, either directly in the section, or indirert1v by referring the operator to another section. l '4 P i se - eneo e pa gy a se'p 9m 4*' r e g

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o w11eauwn=u;.u x. - - 2 The licensee uses'a " Procedures Writers Guide" for reference when writing a procedure. The procedure ~ is then independently reviewed for completeness and accuracy. Procedure validation is the') i[erformedusingoneormoreofthe following tools: (a) round-table' discussion by experienced operators; (b). procedure walk-through; and (c) actually conducting the procedure. Before the procedure is implemented it must be reviewed by the Plant Safety Committee. The emergency procedures for ANO Unit 2 also include abnormal operating procedures which deal with events of lesser severity than does E0P 2202.01. Those which deal with the emergency feedwater system include 2203.12D (Annunciator 2K04), 2203.12F (Annunicator 2K06), 2203.12G (Annunciator 2K07), ) and 2203.13 (Natural Circulation Cooldown), Reference 8. When specific windows in the annunciator are activated,.the operator reverts to the appropriate abnormal operating procedure to find the instructions to clear the fault. The review team has the following observations: 1. At the beginning of the procedure there is a procedure entry conditions (PEC) list that clearly defines when that procedure is entered and lists the RPS setpoints. The operator is instructed to manually trip the reactor if any of the RPS setpoints is exceeded, and automatic trip had not occurred. The PEC list is followed by an immediate actions list. This list is a reminder to the operator of the expected ranges of plant parameters. We find that providing these lists at the front of the E0P is a very useful practice. l 2. The E0P section dealing with degraded power provides useful estimates of the condensate water requirements at different times following a loss of offsite power. Also, useful instructions are provided to monitor the emergency diesel generator fuel oil inventory, and economize the station batteries loading. 3. Ust fel notes, cautions, and directions are frequently used throughout the E0P. These alert the operator that under certain degraded conditions control room inc' t.ations may be inaccurate, explain certain anticipated l e g,,i y, e ee ' + em=m h

'. 6*v on?J ats a i a.i Th""Ah (W -' ~ - + ' O. her SNEa OC " - i 't equipment performance, and instruct the operator on how to reset and operate equipment under degraded conditions, if necessary. 4. The E0P clearly indicates that if the AFW flow cannot be established the operator should attempt to restore the main feedwater (MFW) flow. These instructions are provided in several locations of the E0P. Additional guidance and precautions are provided to the operator so that he may start the MFW pumps under degraded conditions, if necessary. Reminders are also provided that the MFW pumps may be run as long as sufficient steam exists in the steam generators. If starting the MFW pumps is unsuccessful the operator is instructed to attempt establishing the condensate pump flow. If that, in turn, fails the operator is clearly } instructed to " feed and bleed." This is accomplished by manually ] initiating the safety injection, verifying maximum safety injection and I charging pump flow, then opening the emergency core cooling system (ECCS) vent valves on top of the pressurizer. If the vent valves fail to open the operator is instructed to open the low temperature overpressure protection (LTOP) valves and the pressurizer and reactor vessel high point vent valves. The vent valves will reduce the reactor pressure sufficiently to l allow the high head safety injection (HHSI) flow into,the reactor vessel. These valves are schematically shown in Figure 3-1. i 5. The licensee stated that the ECCS vent valves have been full Ap tested using the MOVATS methodology (See Section D.2). The licensee stated that l the motor torque capability and the torque switch bypass settings for the l l l LTOP valves are such that these valves can open against the full system differential pressure. However, the staff notes that neither the vent valves nor the LTOP valves are in the plant's Technical Specifications (TS). Therefore, the licensee should propose for staff review appropriate Technical Specifications for,these v'alves. 1 l 6. Each of two HHSI pumps will deliver 320 gpm at about 1250 psig. A third, l l similar capacity HHSI pump is on standby and can be started manually if 1 one of the operable pumps becomes unavailable. In addition, each of thraa , l t 1 g e e-ei=ese, me e e menas,ep== gm 4

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4 - l 1 . y-. ~.:.w.w. :.:waa..a w:.aaw.-o.w.:.; c A = [ =- a safety grade, charging pumps can deliver ~44 gpm at pressures up to 2300 psia. Two of the' changing pumps are required to be operable by the j plant's TS when the reactor is operating. Only one safety injection pump .is sufficient to remove decay heat.' Since a single failure of the vent valve 4740-2 can disable the vent path and an LTOP valve (see Figure 3-1), the licensee is requested to verify whether-one LTOP valve.is capable of full' decay heat removal via " feed and bleed". The ANO-2 " feed and bleed" system is unique in that'it provides a I dedicated 3-inch diameter flow path with two' series motor: operated valves. The review team believes that, upon verification of the LTOP. valve 1 capt.bility, the ANO-2 " feed and bleed" system constitutes an adequate i alternate decay heat removal means, and therefore supplements the AFWS in-I decay heat removal. i 7. At the end of the E0P there are useful figures and appendices that may be j used for quick reference during an emergency. However, the AFW review team also has the following additional observations: 1 8. We noted some minor apparent inconsistencies between similar steps in the E0P. 9. In several locations of the E0P the operator is directed to do certain actions.if a parameter was " abnormal." Further guidance, in the E0P, to what is " abnormal" may help avoid costly mistakes under emergency circumstances. What constitutes " abnormal" should be adequately discussed during training.

10. TheinadequatecorecoolingsectionoftheE0P(Step 2.C,MFW), instructs 1

the operator to attempt to start the motor driven AFW pump (2P7B). No instruction addresses the turbine driven AFW pump (2P7A). Clear- . instruction as to whether or not to,use 2P7A should be included. t ~22, +g * *

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l Q.um.. ..:w wuM.Msk:en kiM k - ) DMFT l 11. During our review the licensee calculated a 1.0-2 specific steam f I generator dryout time of about 19 minutes, and hot leg saturation time of I about 52 minutes using CEPAC, a PC-based CESEC (a CE transient code). The I licensee also stated that the " feed and bleed" mode of decay heat removal will be effective if it is started anytime up to hot leg saturation time. However, since there is a natural tendency for the operator to resist l initiating " feed and bleed," (F&B) which is, in effect, a small break LOCA, the licensee should specify in the operator training material a time limit window after the F&B condition is reached (the E0P specifies this as T tS60 F and increasing). The operator must initiate the F&B before c this time limit has expired or if T rises excessively, whichever occurs c first, or the risk for core uncovery and possible fuel failure will be too great. Guidance for what constitutes excessive rise of T should be j c provided in the training program. The review team believes that the above measures will also resolve staff concerns raised by GI-122.2, with respect to initiation of feed and bleed. l } D.3.3 Conclusion 1 I i The AFWS review team found that, with the exception of the above observations, J the ANO-2 emergency operating procedure is generally well organized and provides { clear instructions, notes, cautions, and directions. Therefore, the review l team concludes that, provided the above staff concerns are resolved, the ANO-2 l 1 j emergency operating procedure enhances the AFWS and alternate systems reliability and the overall plant capability for decay heat removal. l D. 4 Instrumentation and Control D.4.1 Approach l The review team audited the instrumentation and control circuits for the Auxiliary Feedwater System (AFWS). As part of that audit we conducted a walkdown of the as built system and compared it to the design in the following areas: 1. Review electrical instrumentation and control system drawings for conformance to IEEE Standard 279 (i.e., Independence, Single Failure, Automatic and Manual Initiation) and NUREG-0737, Item II.E.1.2. 1 u__._____

4 -;:-......-~:..,.:-... - -- - -~-- L a.am".a.xr " 'uaa M = j R gy 2. Verify from the control room and drawings that the operator has indicati~on~ ~ - for normal and abnormal conditions (LOMF, LOOP) in accordance with the Emergency Procedures and Regulatory Guide 1.97, " Instrumentation for Light ~ l Water Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident." D.4.2 Evaluation ANO-2 has a Class 1E Auxiliary Feedwater (AFW) system consisting of one turbine driven pump (2P7A), one motor driven pump (2P78), and two independent trains, each capable of supplying water to either of the two steam generators as shown in Figure 1-1. Each pump train has two parallel flow paths to allow a given j pump to feed one or both steam generators. Each flow path in turn'has two electrically operated valves in series. The first valves in the electric motor driven pump trains are normally closed and are used for feed flow control. The second valves are normally open. The first valves and the motor driven pump are powered from Class 1E, diesel generator backed power supplies (power train I-RED). The second valves are powered from the redundant Class ~~ 1E, diesel generator backed powe,r supplies (power train II-GREEN). The turbine driven train also has two parallel paths from the pump-discharge and each path has two valves in series. The first set of valves (normally closed) are powered from the Class IE DC power system (power train II-GREEN). The second set of valves are normally open and are powered from the. redundant DC power system (power train I-RED). The turbine steam admission and control valves are powered from a Class IE battery backed DC system. The turbine driven train is independent of AC power. Therefore, upon loss of all AC and a demand for AFW system, the turbine driven train can supply water to the steam generators. J I

o ,.,.. --,.m _,._ m. cA.:w l.md " 4. s,; __.,...m. The normal water source for the AFW system is the 200,000 gallon (with a Technical Specification minimum value of 160,000 gallons), non-seismic condensate storage tank (CST). There is another 100.000 gallon swing CST j that is shared between the two ANO units. The secondary source of water is the Seismic Category-1 service water system (SWS) whose supply is either the emergency cooling pond or the Dardanelle Reservoir. The AFW system is designed so that the supply is automatically shifted from normal to secondary on low AFW pump suction pressure (5 psig). i The instrumentation and control power supplies to suppert the AND-2 con-figuration consists of a two train system each associated with a separate diesel generator. Each train provides power to a 480V motor control center (MCC) vital bus. The redundant MCC provides the AC power for valve control in the motor driven pump train. The DC power for the turbine driven train comes l from redundant DC buses each having its own battery charger. There is a third standby battery charger which can be switched by operator action to replace either normal battery charger. The initiation signals and circuits are part of the Engineered Safety Features Actuation System (ESFAS). The ESFAS consists of sensors, logic and actuation circuits which monitor steam generator water level and pressure. If these parameters reach preselected setpoints, an emergency feedwater actuation signal (EFAS) is initiated. The EFAS is initiated to Steam Generator 1 either 4 by a low steam generator water level coincident with no low pressure trip present on Steam Generator 1, or by a low steam generator water level coincident with a differential pressure between the two steam generators with the higher pressure in Steam Generator 1. The EFAS for Steam Generator 2 is identical to that of Steam Generator 1. The actuation signals are derived from j 2-out-of-4 coincidence logic measurement channels. Each of the four channels j have a 120-volt uninterruptable AC power supply system which consists of four inverters and four distribution panels. Each inverter has three sources of power:

1) the normal Class 1E MCC source, 2) the battery bank as the backup source, and 3) a second Class 1E MCC as the emergency standby sources..

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l b Ja._,. awmr : mauw en 1 nm.; e, m When an actuation signal is received from the EFAS, both pumps will start and simultaneously all valves in the discharge lines will open, unless there is a steam or feedwater line break, then the EFAS logic will open only the valves leading to the intact steam generator. There is a time delay of 90 seconds after the EFAS signal and before the motor driven pump can start. This starting delay ensures that the turbine' has accelerated to full speed and under governor control to preclude drawing suction pressure excessively low (cavitation point) which could cause the turbine pump to overspeed and '.. ;p. Based on our review of the AFWS, we conclude that the system is designed with due consideration of safe failure modes if conditions such as system disconnection or loss of power are experienced. Therefore, we find that the AFWS satisfies the requirements of GDC-23, " Protection System Failure Modes." We also conclude that the design provides the necessary instrumentation to sense accident conditions and anticipated operational occurrences. This instrumentation as designed will actuate the AFWS. Therefore, we find that the AFW system satisfies the requirements of GDC 20, " Protection System Function." ANO-2 instrumentation provides information for the operator's use during all modes of normal operation, including operational transients, and enables the operator to verify safety system performance following an accident and manually perform required safety functions. The information includes indications, l records (for level, pressure and flow), status lights for pumps, valve position 1 indication, annunciators and alarms. Table 4-1 lists the information available l at the control room. Table 4-2 lists information available at the equipment locations. The scope of our review audit included tables of system variables and component states to be indicated, functional diagrams, electrical drawings, emergency procedures and submittals on conformance to R.G. 1.97 (Reference 9). Since l the arrangement,' clarity, and layout of control room instrumentation is adequately addressed by the staff in the Detailed Control Room Design Review (DCRDR) as required by NUREG-0737, the review team dici not actively pursue that aspect of the control room instrumentation. However, the team had .26-

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a 4 concerns about the locations, orientation, and clarity, especially under emergency lighting conditions, of the instrumentation at the equipment locations. These concerns are discussed in Section D.5, System Walkdow'n. D.4.3 Conclusion Based on document reviews, licensee statements, and direct observations the 'FWS review team determined that adequate _ independence between trains was provided such that any single failure of components in a train will not prevent the other train from completing its safety function. In addition it was demonstrated that the automatic and manual' initiation signals and circuits for the AFWS also comply with the single failure criterion. Based on our audit we conclude that the ANO-2 AFWS can perform its intended function, and that it conforms to the design basis requirements for IEEE Standard 279, 1971. We also conclude that the information available to the operator includes appropriate variables and that their range is consistent wittCthe guidelines identified in R.G. 1.97. Therefore, we find that the information systems satisfy the requirements of GDC-13, " Instrumentation and Control" for monitoring variables and systems over their anticipated ranges for normal i operation, anticipated operational occurrences, and accident conditions. With the exception of staff concerns identified in Section D.5 of this r'eport, the AFWS review team concludes that the ANO-2 Instrumentation and control provisions are adequate and enhance the AFW system reliability. i ) . 3 ~27~ e

4 x G., :s % - ~.n, .s- <t-L4(,*.* te.W A1,.1L1dhYSCSh)YA * -l :- -W:* :QhN "O %t.y. Chi. 1 ~ \\ Table 4-1 AFWS Information Available to the Operator in the Control Room-J 2P7A Steam Driven Pump Indication Lube Oil Temp 50*-250'F Speed (2K03)- 0-5000 RPM Discharge Press 0-2000 PSIG 2P7A+S/G B Flow 0-750 GPM 2P7A+S/G A Flow 0-750 GPM Main Steam Pressure to 2P7A 0-2000 PSIG 2P7A Controls (With Indication) Steam Bypass Valve Position Open/ Closed 2K03 Seal Water Open/ Closed ') Steam Supply Valve Open/ Closed .] Main Steam to Turb. Open/ Closed l Main Steam to Turb. Open/ Closed 2K03 Speed Controller "Dailed" Speed Output Signal 0-100% 2P7A+S/G.#alve-1026 Open/ Closed i 2P7A+S/G Talve-1037 Open/ Closed 2P7A+S/G B Valve-1076 Open/ Closed .a 2P7A+S/G B Valve-1039 Open/ Closed j Condensate to 2P7A Open/ Closed Service Water to 2P7A Open/ Closed Room Cooler Service Water Open/ Closed 2VUC 6A Room Cooler On/Off 2P7A Annunciators Turbine Overspeed Trip i Suction Pressure Low Discharge Pressure High/ Low A S/G Flow High/ Low B S/G Flow High/ Low Service Water Pressure Low Lube Oil Temp. High/ Low EFAS Overriden 2P7B Electric Driven Pump 2P7B Discharge Pressure 0-2000 PSIG 2P78+SG A Flow 0-750 GPM 2P78+SG B Flow 0-750 GPM

4 a u.. .a 1 n:.x m:.:a m ?. w.....:..:,,..a =Jiwa,a kk M GMr.n. >. j.u.;: A+ -,: MSW U' Table 4-1 (Continued) 2P7B Controls With Indication Indication 2P7B+SG A Valve-1038 .Open/ Closed 2P7B+SG B Valve-1036 Open/ Closed 2P78+SG A Modulative Valve 1025 Open/ Closed and 0-100% Open. 2P78+SO B Flodulative Valve-1075 Open/ Closed and 0-100% Open Condensate to 2P78 Open/ Closed Service Water to 2P7B Open/ Closed 2P7B Start Switch-On/Off/ Springs Charged EFW Flush Valve A Open/ Closed .EFW Flush Valve B Open/ Closed. SG A/SG.B Wide Range Level 20-460" Room Cooler Service Water Open/ Closed 2VUC-6B Room Cooler On/Off' 2P7B Annunciators. 2P78 Overlo3d Breaker Trip Suetion Pressure Low Discharge Pressure High/ Low A'S/G Flow High/ Low B S/G Flow High/ Low Service Water Pressure High/ Low .e Additional Instrumentation (Water Sources) Service water Header #2 Pressure 0-200 PSIG Service Water Header #1 Pressure 0-200 PSIG CST A/B Level 0-100% Q-CST Level 0-100% Additional Instrumentation (Steam Generators) S/G Narrow Range Level (4 Channels Per Generator) 0-100%~ S/G Narrow Range Level (2 Channels Per Generator) 0-100% S/G Wide Range Level (2 Channels Per Generator) 20"-460" S/G Pressure (4 Channels Per Generator) 0-1200 PSIG-5/G Narrow Range Level 0-100%: S/G Pressure 0-3200 PSIG

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...c.... & .s.- -. + < v6 --~ t ~~ D.5 System Walkdown . g) mfQ g D.5.1 Approach A key part of the staff's site visit to ANO, Unit-2 was an AFWS walkdown. The walkdown afforded the staff the opportunity to examine the as-built system configuration, specific components, and potential undesirable interactions. The system walkdown had two ' main objectives, one was to confirm that the-installed system conformed to the staff's understanding of the system design basis as identified in previous evaluations, and to determine if the system may be subject to common mode failure mechanisms or hazards (e.g., flooding, fire, missiles, suction strainers, etc.). The other main objective was to examine the ease of operator access to vital equipment for performing necessary recovery actions. This includes assessment of emergency local lighting, communications and other factors (e.g.,. cleanliness equipment' labeling, use of locking devises, posting of simple instructions at1 equipment locations, etc.). The walkdown covered the entire piping and. component layout from the condensate storage tanks, through the pumps to the containment penetration and included the turbine driven AFW pump steam supply lines; switchgear,-and the instrumentation and control. D.5.2 Evaluation The system walkdown, in addition to confirming the "as built". configuration of the system, was also used to determine the location of the AFW system motor operated valves (MOVs). Determining the AFW system valve locations was important in verifying whether the valves had been properly qualified, that is environmentally qualified and Q-listed.. Prior to the site visit the staff reviewed the limitorque motor operated valve maintenance procedures (procedure numbers 1403.160 for model SMB-000 and 1403.161 for model SMB-00, Reference 10), which identified whether a valve was environmentally qualified or Q-listed. Based on this review and the walkdown the staff determined that the AFWS motor. operated valves listed in Table 5-1 were either not environmentally qualified,. not Q-listed, or both. The status of these valves was discussed with the licensee.. .g, 4-

1 O .ch'~J :aL'~4Lhea Gd3SL\\s2 N * " rn.4 G C..ai.....:..-.. o .. w .w.. ':. Y ~ .e. DR/7 FortheQ-listingofvalvesonTable5-1,thelicenseestatedthatallAb system MOVs were qualified. The licensee also stated that the component Q-list but not the maintenance procedures (1403.160 and 1403.161), is the co'ntrolling factor in determining whether a valve is qualified (Q-Listed). The staff inspected the Q-List and verified that valves 2CV-0711-2 and 2CV-1025-1~were on the list. In order to avoid discrepancies and confusion, the licensee j should update procedures 1403.160 and 1403.161, and other similar procedures,. to conform to the Q-List. 1 I Fcr the environmental qualification of valves on Table 5-1, the licensee stated that an analysis was performed in 1977 to-determine temperature conditions in the AFW pump rooms following a unit cooler' failure. For the worst case d condition in the turbine driven AFW pump room, the temperature after three hours operation would approach 115*F. Based on this analysis it was determined that j f the valves did not need to be environmentally qualified. The analysis was not available for the AFWS team review. Thus, the staff could not verify.the assumptions used, initial conditions or other pertinent parameters, which could ] have an effect on the room temperature. The licensee stated that this analysis ) was performed prior to plant fire protection modifications (fire doors have f subsequently been installed on pump room entrances). These modifications could j have an impact on the analysis. The licensee was requested'to reverify his I analysis and the adequacy of the environmental qualification of these valves. Part of the system walkdown included an evaluation of the plant communication and lighting systems in the AFWS rooms. The communication system for this area consists of a telephone system, the plant public announcement (PA) system, and hand-held radios. The AFWS review team noticed a broken handset on the PA system located in the hallway outside the AFW pump rooms. Although the telephone system and hand-held radios act as redundant communication means, the staff urges the licensee to maintain all available communication means, including the PA system, in a ready and operable condition. The lighting system for this area consists of the normal and emergency AC fluorescent fixtures, and battery pack lighting. ' The lighting was found to be inadequate particularly during the postulated station blackout scenario when, g

2 -, c. .m..d w.e. ..+.si a s w di n G k e + ua;s..m. ,-.c. -n._a Table 5 1 "NOT QUALIFIED" AFW MOTOR OPERATED VALVES Not Not Valve Identification Description EQed 0-Listed 2CV-0789-1 Pump 2P-7B Condensate Suction MOV X 2CV-0795-2 Pump 2P-7A Condensate Suction MOV X 2CV-0711-2 Pump 2P-7A Service Water Suction MOV X X 1 1 2CV-0716-l' Pump 2P-78 Service Water Suction MOV X 2CV-1529-1 Service Water to AFW Room 2P7A unit ' l cooler MOV' X 2CV-1532-1 Service Water to AFW Room 2P7B unit' cooler MOV~ X 2CV-1025-1 Pump 2P-7B Discharge to SG-A_ X control valve .i i 34

4 e ht i. L5.:.i....- ys is. L- ' < ~ = ' ' * - ' S'? E~ N b proper operation of the turbine driven AFW pump is imperative. The emergency DC lighting for the turbine driven AFW pump room is )owered from the battery pack located in the motor driven AFW pump room. A battery failure due to an accident could result in no lighting in either room. The-review team noted that the hallway leading to the two AFW pump rooms was dark with potentially i hazardous stairway steps especially under stressful emergency conditions. The review team did not observe any normal or emergency AC lighting in the hallway. As a part of the system walkdown, the staff reviewed the emergency lighting i diagram for the AFW pump rooms area (see Figure 5-1) and the surveillance procedure that is performed quarterly on the emergency lighting (Ref. 11). A I review of the surveillance procedure and the system walkdown showed that the aiming of the emergency lighting may not be correct to provide adequate illumination to perform manual actions. This is particularly true for the l turbine driven pump room. Since this room is crowded and access to most valves is difficult, even under normal conditions, adequate illumination is necessary. According to Table 1 of Reference 11 the lighting in this room is aimed toward tne west wall (the opposite wall from where the lights are mounted). This would not provide adequate illumination for the trip and throttle valve, the local control panel, or the condensate water supply valve, 2CV-0795-2. The I trip and throttle valve is located north of the lights, and behind some pipes when seen from the location of the lights. The local control panel faces the west wall and may receive an inadequate amount of indirect lighting by reflection. The condensate water supply valve 2CV-0795-2 is located in the southwest area of the room and may receive an inadequate amount of indirect lighting. It is the AFWS review team's assessment that the lighting (especially emergency DC lighting).is inadequate for the turbine driven AFW pump room as well as the turbine and motor pump control panels, and valves. The review team requests that the licensee ensures the adequacy of normal and emergency AC lighting, and the adequacy and aiming of emergency DC lighting. The review team did not observe or check the emergency lighting intensity but notes that the illumination level should be a minimum of 10 foot-candles at the work station to conform to the NRC's criteria for station lighting (NUREG-0700j. h_____-_-___________________ ___________a

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R 9 'l a. x u.: awn.w.n.c.c.. : w w.. ..=...,. =. x-m ea:r.bes& k un hw. - ~ 3 The evaluation team has the following additional observations: I '1. During the AFW system walkdown the staff noted that the degree of equipment j i and structural cleanliness was less than desirable. -That is possibly amplified by the dark colors of the walls and floors. In one case, in order to read a nameplate on a valve limitorque a thick coating of dust and dirt had to be removed from the label. Dust and dirt may contribute to malfunctions of equipment with low tolerance moving parts, or electrical relays and contacts. The malfunctions of the latter may also ~ be compounded by moisture. 2. The review team noted that operator access to AFWS_ equipment for normal surveillance, or for emergency remedial actions is generally poor. This problem would.be more pronounced during stressful conditions, or poor lighting (in case of station blackout). Examples of this are shown in Figures 5-2, 5-3, and 5-4. Emergency remedial actions may be greatly hampered by poor access to equipment, especially if compounded by poor emergency lighting. Therefore, ease of access is of vital importance (see D.3.2 for available time discussion). 3. To guard against AFW pump steam binding due to hot water back-leakage through the pump discharge piping the licensee checks the discharge piping temperature locally once every shift. In order to achieve that, an operator has to climb over equipment or under piping to'get to the far corner of the room and possibly lean over other equipment to see the temperature gauge. This is shown in Figures 5-5, 5-6, and 5-7. Although this once-a-shift task addresses staff concerns raised in GI-93 with respect to pump steam binding due to hot water backleakage, the current location of the temperature gauge increases the potential of equipment malfunction due to an operator inadvertently stepping on, or bumping o into such equipment. In addition, this may increase the possibility of personnel injury. The licensee is requested to move the AFW discharge piping temperature display closer to the room entrance so that the operator may avoid entering the too. =very shift if the only objective is to take the temperature reading. The licensee stated that ANO-2 has not had any backleakage steam binding events.

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.w.: m m.w. ....a: .:.c4 me.a: m ..v w m %a:-.r.& " a s.w. \\ j 4. The review team noted that at least one pipe support was loose such that, if sufficient force was exerted on that pipe, a pipe crack may develop. Figure 5-7 shows a loose pipe support in the turbine driven AFW pump ~ room. This pipe is located in a tight passage way where it may be q 1eaned against by an operator attempting to carry out the surveillance j procedure described in item 3 above. The licensee is requested to ensure the ] integrity of all equipment supports in the AFW system, a'nd improve its i surveillance program to sustain such integrity. 5. Under certain emergency conditions the only means of decay heat removal is I through injecting water in the steam generators by manually and slowly starting the turbine driven AFW pump using the trip and throttle valve-(TTV). In that process the operator needs to monitor the discharge press,ure and possibly the turbine tachometer in order to ensure proper f pump operation. However,.the pressure gauge and tachometer are not directly visible from the TTV location. This may necessitate pump j starting in several stages if one operator is assigned this task, since such operator will have to manipulate the TTV then move to check the readings of the gauges. Alternately, the task may require two operators. The review team feels that this is' an important (last resort ir case of station blackout) remedial recovery action that can be made much easier by properly locating the necessary gauges so that they can be clearly seen from the TTV location. The gauges should be clearly visible-under the postulated station blackout lighting conditions. Therefore, the staff suggests that the licensee move and' reorient the abov'e gauges, j considering the proper emergency DC lighting, so that recovery action's by the operator may be easily carried out, j 6. The review team noted that equipment identification (e.g., labelling) is j generally not adequate. While some equipment was clearly marked, most I.i labels or nameplates were not easily legible. The licensee stated that a retagging program is underway to improve equipment identification. The licensee also stated that the ANO-2 inside-of-containment retagging has j been completed, and that the AFW system will soon be retagged. The AFWS team notes that after the system is retagged, verifying that the correct tag is attached to the intended equipment is an equally,important task. ),

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-w .a-. -....a 7. The review team noted that the licensee used adequate locking dev1cEs n manual valves in their standby mode (see Figure 5-8). The licensee stated that all manual valves that, if not properly aligned, can divert or block the AFW f1'ow are. secured in their standby position by chains and locks. The keys to these locks are readily available to the control room operator. The licensee has a procedure for a pre-heatup valve position alignment (Reference 12), which includes physically checking the_ locking chains to ensure that they are not cut. By procedure the licensee also ) performs a pre-heatup valve position verification which specifica11y instructs that the verification be done by an individual different from that who did the alignment check. The review team finds this independent ] verification useful in assuring system readiness. The licensee ~also j stated that by procedures the steam trap valves are ensured to be i unisolated before plant startup, and the steam lines purged by steam via steam trap bypass valves every shift to further ensure no condensate in j the lines. I 8. The review team noted that the licensee posts some system piping and instrumentation diagrams (P& ids) locally at the equipment location._ While ) the team did not check the accuracy of the P& ids or whether they are'of ] current revision, it is the team's opinion that this is a very useful { practice that tends to reduce confusion and improve equipment identification. The review team also noted that the licensee is currently revising the turbine driven AFW pump overspeed trip reset and manual j control procedures (Reference 13). The licensee stated that he intends to post exhibits A, B, and C of that procedure at the turbine driven pump room for quick reference. With proper consideration of equipment location and lignting, the review team finds that posting of these simple exhibits can be very helpful during any potential recovery actions. 9. The AFW pumps are located in separate isolated rooms such that a postulated steam line break in the 2P7A pump room will not adversely affect the motor operator of pump 2P78 in the next room. This pump arrangement addresses staff concerns raised in GI-68 with respev. 'o AFW motor operator environmental qualifications following a steam line break in a pump room.. a

& : dd uiG A.u k. h e:. .'r, .% 2. k.. SMkd sune".' ukesMsim- "I'U E -aw as.-- D.5.3 Conclusion MR i Upon its review the AFWS review team found that the "as built" configuration of the ANO-2 AFWS.is consistent with the design documentation. The staff, however, had several concerns as discussed in the evaluation section above. Based on discussions with the staff the licensee indicated that it is already taking certain steps to address some of the staff concerns. Of the several staff concerns raised above, one is of particular significance. This concern is over the ease of access to equipment to carry out manual remedial actions under emergency conditions. Since the plant's capability to safely mitigate transients and accidents depends to a large degree on the operator's ability to perform various recovery actions, some of which may be outside the control room, it is the staff's opinion that ease of access to the AFW system equipment is of paramount importance. Therefore, the staff requests that the licensee develop a " maximum time to access," (MTA) from the control room to each piece of the AFWS equipment that may potentially be exercised during the course of an event. Also, since the atmospheric dump valves are key equipment that may b'e used in combination with the AFWS for decay heat removal, an MTA should be developed for these valves. The MTA should be introduced in the operator training program, and actual practice.be performed by all operators as a part of that training. MTA training should be introduced in the same context as the " time window" concept discussed in Section D.3, Emergency 1 Operating Procedures. In developing the MTA, the licensee should consider-potentially adverse environments (e.g., elevated temperatures due to lack of ventilation from station blackout) and emergency lighting conditions. The licensee should also ensure the availability of.necessary tools (e.g., ladders or wrenches) that may be used to operate various pieces of AFWS equipment. The MTA should be determined as the maximum time for an operator to reach a particular piece of equipment and be able to start operating it. After operating the equipment the AFW flow should be resumed to the steam generators before their water levels reach the zero level mark. This will help the plant avoid temporary loss of the secondary heat sink. 46 ,w = v

4 .:.w. w.u ..n su w.a x m.a.s.> - u~xkau a m Ma.Md uxu' "s' Nf @)m." The AFWS review team concludes that, provided the licensee adequately addresses staff concerns discussed in this section and in Section D.5.2 above, the AFW system as installed, instrumented, and operated addresses staff concerns raised in GI-68 with respect to AFW motor operator environmental qualifications following a steam line break in a pump room, in GI-122.1.b, and c with respect to AFW interruption and recovery, and in GI-124 in that it is conducive to safe and reliable operation during accident or transient conditions. D.6 Trainino D.6.1 Approach The AFW team reviewed the training program to establish an understanding of the licensee's commitment to maintain and enhance the proficiency level of its maintenance, operations and engineering staffs with respect to normal, and emergency operation the AFW system. The team review consisted mainly of inter-views with training instructors and staff members. The team also inspected some training documentation. This review does not address the completeness of the training program and should not be considered as an acceptance review. ~ D.6.2 Evaluation Prior to being hired by Arkansas Power and Light Company (AP&L) the prospective maintenance employee is screened for aptitude and trainability. In addition the prospective employee's educational background must include one or more of the following: Vocational-Technical School, Technical School, or college. The utility assigns new hires as entry level trainees. A person would have to be exceptionally qualified to be hired above an entry level position. Newly hired maintenance personnel must'take the AP&L training program. This program consists of five years of both schooling and on-the-job (0JT) training. The program also includes continuing training and refresher courses. The training program, however, is not strictly geared to the AFWS but in general to all plant systens and equipment., e

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.. ~. -. j b The entry level personnel undergoes four months of training after he is hi ed. During these four months, he attends a company-owned offsite training school. This school introduces the trainee to the basic courses (mathematics, mechanics, thermodynamics, pumps, controls, etc.). The entry level personnel has the-option of " testing out" or qualifying for the individual courses. To " test out," the trainee takes a test in the course subject matter; if he passes ~ ] the test, he gets credit for that course and does not have tn take the course. l Some of these courses have been transferred to the onsite training facility. Upon completion of the entry-level training course, the trainee becomes an apprentice trainee and selects an area of specialization: rigger, steam fitter / welder, electrician, mechanic, etc. i The apprentice trainee undergoes four years of training. During these four years, he attends a company-owned on-site training school, which provides the trainee with basic-skills training for the specific craft he has chosen. This training provides some hands-on experience in disassembling and reassembling equipment similar to that found at the plant. The balance of the four years is ] spent at the plant as on-the-job training. The on-the-job training consists of a check-off list of typical jobs and duties which the apprentice trainee must complete prior to advancing to the next level. The check-off list starts out with general items and becomes more specialized as one progresses. Upon completion of the apprentice trainee program, the trainee becomes a journeyman. The journeyman course includes required schooling and on-the-job training over a minimum one year period. Upon completion of the program the journeyman becomes a mechanic, electrician, etc. Both the apprentice trainee and the journeyman courses are INPO certified, and take full advantage of manufacturer material. In addition to the formal training courses, the ANO Unit 2 Maintenance Training Department has a continuing / refresher training program. This program allots approximately 25% of the total yearly man hours for continuing education during. a refueling outage year, and 15% to 20% during a non-reft.Png outage year. The program makes use of plant training facilities, company training facilities. .e.w_.we ..e m..v m m,-m e

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~uma w...w jI and manufacturer training programs. Its purpose is to maintain and enhance the skills of the maintenance personnel. The licensee informed the review team that part of the new parts and component procurement process will be to negotiate the inclusion of vendor training (maintenance and troubleshooting) as part of the purchase contract. By inspection of training documentation, interviews, and a_ partial walkdown of the training facility, the review team found the maintenance training program to be thorough and detailed. It makes extensive use of manufacturer uaterials, technica' bulletins, sales brochures, technic &l manuals and demonstration w modele, as well as on-the-job training, j j Since cperator licensing is a regulated activity and has been extensively i considered by the NRC, the evaluation team spent a minimum amount of time in I the operator training area. AND Unit 2 management emphasized the licensee's commitment to training, and stated that it encouraged the plant engineers.and plant superintendents to maintain their reactor operator (RO), and senior reactor operator'(SRO) I licenses current. A few select individuals in this group were required by company policy to maintain current licenses. However, due to the amount of required training, testing, and rerving on control roem shifts (approximately 25% -30% of the yearly man hours), it was stated that it was difficult for many ex-R0s and ex-SR0s to maintain the license and perform there assigned regular duties. Thus, many of these individuals allow their licenses to lapse. The j staff does not encourage this approach since it lessens the level of awareness of plant operation and systems interrelations. D.6.3 Conclusions ) ] The evaluation team finitt, that the licensee's comitment and implementation of the training programs as discussed above promotes good understanding of plant operation in general, and in particular may enhance the licensee's' ability to minimize syster malfunctions and improve the likelihood of recovery once a malfunction takes place. The evaluation team, therefore, concludes that

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MJAW ^ ~ " * " AMFT subject to resolving staff concerns raised in Section D.5, and other sections, the AND Unit-2 training program contributes to and enhances the plants capability for decay heat removal. 1 D.7 Operatina Experience and Reliability Analysis D.7.1 Approach The staff reviewed several documents including the Licensee Event Reports (LERs) and Nuclear Plant Reliability Data System (NPRDS) files pertinent to ANO-2 (References 14 and 15). The staff also discussed with the licensee the licensee's statistical analysis relative to equipment failures. D.7.2 Evaluation The staff searched the LER and NPRDS files for the period of 1981.Ahrough 1985 for data pertinent to the AND-2 AFW System (References 14 and 15). d he search revealed a substantial number of discharge valve failures and several failures in suction valves, steam admission valves to the turbine drives for the AFW pump, turbine driven pump overspeed, and pump packing. The licensee replaced some of the discharge valves, and stated that the rate of valve failures has significantly decreased. Some valve failures continued to occur as of late 1985, the period covered by this data search. In nine instances the failures disabled or degraded an AFW train. However, all of these were readily recoverable by an operator at the equipment location. Discharge valve q failures partially disabled an AFW train. These failures were all readily recoverable at the equipment location. Only one instance was found that is a precursor to a nonrecoverable AFW train failure. That was an excessive packing leakage which resulted in the pump bearing oil being contaminated by the leaking water. The licensee conducted a statistical analysis for ANO-2 AFW train failures and component failures for the period of 1980 through 1986. This analysis shows a rapidly decreasing failure rate trend (e.g., from 16 single train failures in 1980, to 8 failures in 1981, to zero in 1982 and subsequent years). For other _44 e + 4

4 e - r:w a ....v u..... x rw.wae.amma Le,m + - -wa - a.. _.. r, I component failures, the licensee shows a sin.ilar trend, from 20 fin 1980, to zero j in 1983 and later.) The staff believes that this trend in reduced number of failures is significant, and is indicative of a substantial licensee effort to ) improve equipment performance. Most of the equipment failures are recoverable given an easy access route and sufficient time before reactor coolant system degradation (See Sections D.3 and D.5 for discussion of time available for j action, and of equipment accessibility). Since reactor scrams place the plant in a condition where decay heat must be removed, such scrams constitute potential challenges to the AFW system. The licensee's operating experience relative to unscheduled automatic reactor scrams and associated challenges to the AFWS, shows a promising trend. Although AND-2 had a scram rate of 24* scrams / year in 1981 the rate has generally declined since then to 5 scrams / year in 1986. The plant had 8 unanticipated scrams in 1985. This is about double the national average for that year (4.3 scrams / plant year, Reference 16). However, the' licensee appears .o be committed to re$ ting the plant scram rate through its trip reduction program. The trip reduction program is directed at minimizing the causes for reactor trips. e.g., reactor protection (including the core protection calculator) anomalies, main feedwater upsets, and turbine generator control malfunctions. If the above improvement rate continues, much reduction in the challenge rate of the AFWS will result. A survey of the failure rate history of.the emergency diesel generators (DGs) on all operating nuclear power plants in the period of 1983 through 1985 (Reference 17) shows that ANO-2 emergency diesel generators have an average failure rate of 0.016 and 0.02 failures per demand, and meet the reliability criterion identified in the proposed Regulatory Guide. " Station' Blackout." This Regulatory Guide has been issued for comment and identifies a DG reliability acceptance criter. ion of no more than 0.025 failures / demand for the ANO-2 diesel generator configuration.

• The licensee a'ttributed most of the scrams to the CE core protection calculetor (CPC), which is currently being improved..

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~:- 4 flMFT The licensee has performed an AFWS reliability analysis. Although this analysis was provided to the staff in a draft form it came too late to be thoroughly reviewed. However, below is a summary of the licensee's analysis. After performing a benchmark analysis against the NUREG-0635 (Reference 3) results, the licensee conducted two additional analyses using the same model but with different failure rate data. These analyses are referred.to as j " Bayesian Update" and "Best Estimate" analyses. The results are provided below for the loss of feedwater (LOFW) and the loss of offsite power (LOOP) events. LOFW LOOP Benchmark Analysis 1.1E-3 2.2E-3 Bayesian Update 9.9E-4." '2.1E-3 Best Estimate 6.3E-5 3.3E-4 The failure rate data used for the benchmark analysis is the same as that used for the NUREG-0635 analysis. The failure rate data used for the Bayesian Update analysis was obtained by combining plant-specific data with-industry generic data. The failure rate data used for the Best Estimate analysis was obtained from the generic data base and additional modeling assumptions. The above analyses do not account for: (a) operator action to recover faulted conditions or to use alternate equipment; (b) support system failures (other 3 than ac power); (c) AFWS failure due to control system faults; or (d) common cause contributors to system unreliability. Consideration of these factors could affect the reliability estimate in different ways. The AFWS review team places significant weight on each of the above factors and suggests that the licensee complete its reliability analyses. The licensee should consider implementing those' measures identified in the aqalyses that will enhance the AFWS reliability. The above estimated AFWS reliabilities may be combined with the frequencies of the LOFW or LOOP to arrive at an estimate of the expected frequency of AFWS failure when it is needed for decay heat removal. ANO-2 has experienced 12 10FW events in the period of 1981 through 1986. While this is a high rate of k I 1 ] I L b

'e l a.,.; :n> < 6:a. 2:..&M n:v AGM.* MhuhM& ' " ' ^ occurrence the licensee stated that all events were readily r ~ h el e.

Also, the rate of LOFW decreased steadily from 5 events in 1981 to no events in 1986.

j The plant experienced no LOOP events during the same period. In order to estimate the frequency of failure of AFWS when needed the staff assumed a j frequency of 0.646 non-recoverable LOFW events per reactor year. This was estimated by Duke Power Company for Oconee, Unit 3 (Reference 18) and is believed to be a reasonable estimate for other plants. In the following calculations the plant-specific bayesian update results were used. I 1 Number of AFWS failures when needed= { 0.646 (LOFW events / year) x 25.4 (years-assumed remaining operation life)* J x 9.9E-4 (failure / demand)= 0.016 Therefore, there is a 1.6% chance that during the remaining life of the plant it will experience a total loss of main and auxiliary.feedwater. In a case of total loss of feedwater the operator must successfully initiate the " feed and f bleed" mode of decay heat renioval or risk fuel failure and radioactive releases. The staff estimstes the risk to the public as a result of total loss of main feedwater and auxiliary feedwater systems to be 1480 person-rems. If the AFWS and back-up systems reliability is increased to 1E-4 failures / demand as per the Standard Review Plan Section 10.4.9, Auxiliary Feedwater. System, risk to the public would be decreased By 1330 person-rems. In light of this risk reduction the staff believes that the licensee should provide an alternate source of water to the steam generators such that the reliability of decay heat 1 1 removal means may be enhanced. The staff believes that the addition of the l alternate means of water delivery to the steam generators will enhance the AFWS reliability to the 1E-4 failures / demand criterion. Furthermore, the licensee should emphasize, in its operator training program, the graveness of not initiating " feed and bleed" if a total loss of feedwater is suspected. Traihing on rer.gnition and mitigation of such an event should also be emphasized. l 1 80% of the remaining calendar plant life of 31.7 year -47' 1 a

4 .OJ mw'f.ah.ML 'sM.Lt.iVM. 4 "M e.e. A d i "i Wina@MWucs ituMdit Mis Ausddam a2.IEth: 'MJ Ewde <e - -+4-- D.7.3 Conclusion Based on staff review and observations, and based on the licensee's statements we conclude that the licensee is actively pursuing improvements in the AFW system reliability and availability. The licensee's statistical analysis conducted for the last six years for the ANO-2 AFWS-related failures shows a rapidly decreasing failure rate trend with no significant failures since 1983. This indicates a substantial improvement in equipment performance. As discussed above the majority of equipment failures, over a five year period from 1981 through 1985, was determined to be readily recoverable at the equipment location. Therefore, the staff believes that ease of access to various AFWS equipment is of paramount importance to the overall system reliability and availability. Ease of access requires adequate normal and emergency lighting, adequate communications, clear and legible equipment identification, and availability of tools that may be necessary to operate such equipment. These issues are discussed in detail in Section D.5'above. Although significant improvement in valve performance has resulted over the last few years, the licensee's adoption of the MOVATs methodology for valve setpoint setting (see Section D.2.2) is expected to further improve these valves performance. The licensee's E0Ps explicitly and clearly instruct the operators, if the AFW flow can not be established, to attempt to reestablish the MFW flow or, if that is unsuccessful, to rely on the condensate pump flow. The E0P sections provide guidance and precautions about degraded modes of equipment operations, if necessary. If all MFW and AFW are not readily recoverable, the E0Ps instruct the operator to initiai.e the " feed and bleed" mode of decay heat removal. Although the staff nas certain concerns with " feed and bleed" capability, operability requirements, and emergency operation (see Section D 3.3 above), the staff believes that #NO-2 " feed and bleed" system with its 3-inch flow path with two motor operated valves in series, enhance the decay heat removal capability. This flow path 1- = sufficiently large to depressurize the reactor coolant system to allow flow from the high head safety injection pumps. However, while this provides additional capability for decay heat removal the -overall decay heat removal system reliability remains less than adequately. Therefore, the staff believes that an alternate method of providing of water to. e = .A

~ 9 .,.o..sw w..r. x x..uwa m v.s m.m ~= ~ UPW.wT the steam generators is needed so'that the overall decay heat. removal system reliability may be enhanced. The alternate water source for ANO-2 could use existing equipment such as the motor driven AFW pump at ANO-1. The discharge of this pump could be connected with the ANO-2 steam generators with an adequate size pipe and a valve arrangement that will enable operators to direct the flow of this pump to either unit 1 or unit 2 as necessary. This valve arrangement could be operated manually. However, the operability of the pump and the manual valves should be required by the plant Technical Specifications. As discussed above, the plant's rate of unanticipated automatic reactor scrams is high, however, it is steadily decreasing. Also the licensee has had a relatively low failure rate of its two emergency diesel generators. Based on the above, the staff concludes that, upon resolution of staff concerns, which are summarized in Section A of this report, the AND-2 AFW system and alternate means of decay heat removal are well designed, inst umented, maintained, and operated, and that the licensee has adequate E0Ps,. and training program as pertinent to the AFW system. The~ staff, ther2 fore, concludes that, upon resolving concerns raised in this report, the ANO-2 AFWS is sufficiently reliable. i b. i ) ---_._----------_-------------,m---

v ......~.._. _... m ,..... ~.. - -...-~..w~-----~~~-u-%*e-~"---' 4 Appendix A ( References 1. ANO-2 FSAR Section 9.2.1, Service Water System; 10.3, Main Steam Supply System, 10.4.9, Emergency Feedwater System 2. Plant Technical Specifications Section 3.7.1.2, 3.7.1.3, 3.8.1.1 3. NUREG-0635, " Generic Evaluation of Feedwater Transients and Small Breaks Loss of Coolant Accidents in CE Designed Plants" Section X.1, pages X-2 through X-15, ANO-2 Emergency Feedwater System. 4. ANO-2, II-E.1.1 Safety Analysis Reports dated November 10, 1980, May 12, 1981, February 3, 1982, March 25, 1982, and November 18, 1983. 5. NUREG-1212, " Status of Maintenance in the U.S. Nuclear Power Industry 1985," Volume 2, June 1986 6. Inspection Report No. 50-?13/86-01, Safety System Functional Inspection of ANO, Unit 1 AFWS, dated March 31, 1986 7. Emergency Operating Procedure, E0P 2202.01, Rev. 2 8. Annunicators 2K04, 2K05, 2K06, and 2K07 Corrective Actions 9. Drawings audited for conformance to IEEE Standard 279 and NUREG-0737 Item II.E.1.2. Title DWG. No. Station Single Line Diagram E-2001 Single Line Relay Diagram E-2002 Single Line Relay Diagram (6900 Volt) E-2003 Sing 12 Line Relay Diagram (4160 Volt) E-2004 Single Line Relay Diagram ESF E-2005 (4160 Volt) Low Voltage Safety System E-2006 Single Line Relay Diagram (480 Volt)~ E-2008 Schematic Diagram (125 Volt DC) E-2085 Functional Logic Diagram EFWS E-2403 Functional Logic Diagram Aux Cooling E-2406 . Water Main Steam (P&ID) M2202 Condensate & Feedwater (P&ID) M2204 I Steam Generator Secondary System (P&ID) M2206. e,...

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-9 m a Dg'.er D Title DWG No. EFW Turbine MOVs 2CV-1000-1 & E2295 i 2CV-1050-2 EFW Pump Suction MOVs E2296 EFW Discharge Valves E2300 EFW Condensate Suction MOVs E2301 . Emergency Power Supply for Control E2420 Room AC System EFW Turbine Driver Steam Isolation E2443 Valves

10. Maintenance Procedures 1403.160 for model SMB-000, 'anci 1403.161.for model SMB-00 I

i 11. System Operating Procedure 2107.04, "DC Electrical System Operation, Supplement VI" 12. Plant Pre-heatup and Pre-critical Checklist 2102.01, Rev. 23. j 13. Emergency Feedwater System Operating Procedure OP 2106.06, Exhbits A, 2P7A Turbine Overspeed Trip Reset; B. Drawing; and C, Manual Control of 2P7A. 14. F. Hebdon to T. Speis, Preliminary Review of AFW Related.LERs, April 18, 1986. 15. F. Hebdon to T. Speis, Review of AFW Related LER and NPRDs Data, July 25, 1986. 16. INP0 86-012, " Unplanned Automatic' Scrams in U.S. Electric Generating Units J in 1985," April 1986.

17. NSAC-108, "The Reliability of Emergency Diesel Generators at U.S. Nuclear Power Plants in 1983 through 1985," September 1986.

18. NSAC-60, "A Probabilistic Risk Assessment of Oconee Unit 3," June 1984. ~i a -e e.w e -.e

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. n.. .;;. _. m. -.. a - - -... -. ~e " " - ~ = h -- i Appendix B Individuals involved in the AFW System Review .1 NRC Personnel i AFWS Evalua' tion Team Paul Norian, Team Leader, NRR Sammy Diab, Task Manager, NRR Norman Wagner, NRR Robert Giardina, NRR. r Joseph Joyce, NRR Robert Lee, ANO-2 Licensing Project Manager I Charles Harbuck, Resident Inspector, Region IV Willim Johnson,-Senior Resident Inspector, Region IV Arkansas Power and Licht (AP&L) Personnel Ted Enos, Manager of Nuclear Engineering and Licensing, AP&L Charles Turk, Supervisor of Nuclear Engineering, AP&L Bill Converse, Supervisor of Plant Performance, AP&L Kurt Taylor, Supervisor of Operational Technical Support, AP&L e Jason Remer, Maintenance History Supervisor, AP&L Kenny Coates, Mechanical Maintenance Supervisor, AP&L Larry Taylor, Plant Licensing Engineering, AP&L Jerry Peter, Operational Technical Support, AP&L David McKenny, Reactor Operator, AP&L Randal Golden, Senior Reactor Operator, AP&L f Bill Craddock, Reliability Analysis Group, AP&L 1 3, .. - ~.,,. -s ..*a . ~ ~ .>v.-*<- .-~.ee m.- i

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