View source for 0CAN069203, Provides Corrections to Inaccuracies in 800131 Response to NRC Ltr Re Facility EFW Sys.Discusses Other Actions Taken

{{Adams
| number = ML20101F374
| issue date = 06/19/1992
| title = Provides Corrections to Inaccuracies in 800131 Response to NRC Ltr Re Facility EFW Sys.Discusses Other Actions Taken
| author name = Fisicaro J
| author affiliation = ENTERGY OPERATIONS, INC.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000313, 05000368
| license number = 
| contact person = 
| document report number = 0CAN069203, CAN69203, NUDOCS 9206240425
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 3
}}

=Text=
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c"t <er o n' o a iac-s- Enterg l
Operations l
June 19, 1992 OCAN069203 U. S. Nuclear Regulatory Commission Document Control Desk Mail Station F1-137                                                                                                                              _
Washington, DC 20555

==Subject:==
Arkansas Nuclear One - Units 1 & 2 Docket No. 50-313 & 50-368 License No. DPR-51 & NPF-6 Correction of NRC Currespondence for the Emergency Feedweter System Centlement By {{letter dated|date=January 31, 1980|text=letter dated January 31, 1980}} (2CAN018024), Entergy Operations provided the responses to the staff recommendations of NRC Letter dated November 6, 1979 (2N-70-197) regarding the Arkansas Nuclear One, Unit 2 (ANO-2)
Emergency Feedwater (EFW) System.                                                      Entergy Operations has identified two aspects of our January 31, 1980 response which were not completely accurate.         As discussed with the ANO-1 NRR Project Manager and other members of the NRR staff, this letter is being submitted to correct these inaccuracles and to discuss other actions taken es a result of this finding.
Enclosure       1   of   the November                                          6,                1979   NRC letter,  item      X.1.3.1, recommendation 05-6, stated that:
                           "The licensee shculd propose Technical Specifications to assure that prior to plant startup following an extended cold shutdown, a flow test would be performed to verify the normal flow path from the primary AFW system water source to the steam generators.                                                               The flow test should be conducted with AFW system valves in their normal alignment."
Our January 31,        1980 response for ANO-2 ststed that because the motor driven EFW pump was used to supply feedwater to the steam generators during startup, this assured the normal flow path of the "B" EFW train from the primary EFV system water source to the st eam generators. This statement inferred that the recommendation would always be met for this train of EFW:
therefore, no Technical Specifications were needed. During plant startups 6en the motor driven En' pump is used to feed the steam generators, the 1
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l U. S. NRC June 19, 1992 Page 2 suction source for the EW pump is (M Startup and Blowdown (SU/BD) system effluent. Tho primary EW hyst mn wat e r source is the condensate storage tank (CST), not the SUiB0 ef fluent,        u ter startup, the EW pump suction nource in transferred to the 37.          bsed on the information provided, no Technical Specification ch g er wm proposed for the "B"                                EW train.
Technical Specification changes addressini; the reconenendation for the                          "A" EEN system train were submitteu, approved by the Staff, and implemented by issuance of Amendment liSO to the ANO-2 Technical Specifications in December of 1983. Although the requirement to perform a flow test for the "B" Er system train does not exist in the Technical Specifications, currently the "B" EW train flow path is procedurally verified by testing during each cold shutdown prior to heatup and has been since the requirements of                                 J Amendment 50 were implemented into plant procedures.                                                   '
Enclosure 1 of the November           6,     1979   NRC Ictter,            item             X.1.3.2, reconenendation 4, stated that:
                 " Licensees with plants which require local manual realigrunent of valves to conduct. periodic tests on one AFV system train, and there is only one remaining AW train available for operation should propose Technical Specifications to provide that a dedicated individual who it in congnunication ult h the control room, be stationed at the manual                            1 valves. Upon instruction f rom the control room, this operator would realign the valves in the AFV system train from the test mode to its operational alignment."
Our response for ANO-2 to this recommendation provided in {{letter dated|date=January 31, 1980|text=letter dated January 31, 1980}} stated that local manual realignment of valves was not required during the performance of EEN system periodic tests.                           Ilowever, a review of the EW system surveillance procedure in use in 1980 indicated dat realignment of a manual valve was necessary in order to test the "A" EW train.      Currently, dur 'ng the "A" train EW pump test., an operator is
          -stationed locally and is in communication with the control room to realign
          .the manual valve (2E W-11B) upon instruction from the control room.
Subsequent to our 1980 response, the "B" train EFV pump test was revised to also require manual valve realignment during testing.                However, testing procedures were not revised to require stationing an operator locally.
Also, ANO-2 has subsequently installed a third auxiliary feedwater pump                               ,
which is now an alternate and preferred method of feeding the steam generators during plant startup instead of using the      "B" train EW pump.
Upon _ discovery of these discrepancies, a Condition Report was written in order to address t.hese concerns.        The corrective actions were:                         (1) to review t.he entire {{letter dated|date=January 31, 1980|text=January 31, 1980 letter}} for accuracy. (2) to revise the ANO-2     EFV   system  operating   procedure to station an operator in communication with the control room to operate the necessary manual _ valves that are realigned during EN t rain testing, (3) to perform a Technical Specification change evaluation for ANO-2, and (4) to conduct a review for applicability to ANO-1.

U. S. NRC June 19, 1992 Page 3 The following addresses the corrective actions taken:
(1)              In further review of our January 31, 1980 response to . X.1. 3. 2 recommendation 1 we stated that "Should the pressure at either of these switches drop to 7 (+1.-0) psig. from its normal 10 psig. local and control room alarms will be actuated."                                     This statement is being corrected to indicat.e that the normal suction pressure for the EFW pumps is approximately 25 psig with only control room alarms being actuated on low suction pressure. This correction does not change any of the conclusions reached in our response to the F-                                                    request.
(2) The Emergency Feedwater _ System Operations procedure was revised to locally maintain an operator in communication with the control room to                                                          l realign the manual valve (2EFW-6) that could render the "B" train of EFW inoperable during EFV system testing.
(3)              Since procedural controls _ are currently in place and due to the fact that the EFW system design consists of two trains of EFW and one t. rain of AFW, no Technical Specification changes for ANO-2 are considered necessary to address the concern of the November 6 1979 NRC letter.
Enclosure 1 item X.1.3.2 recommendation 4.                                      The need for Technical Specifications requiring the aurveillance of the "B" EFW system train was discussed with the- ANO-1 NRR Project Manager and a reviewer f rom the P1 art Systems Branch of NRR.                                       It was concluded that since procedural requirements exist for this surveillance and all position changeable valves in this train are located outside of the containment which are verified to be in their correct position once every 31 days por Specification 4. 7.1.2.a.3 that. no additional specifications are required to address the concern of item X.1.3.1 recommendation GS-6.
(4) The review for applicability to ANO-1 of the November 6 1979 NRC letter.                         Enclosure 1               Item X.1.3.1  recommendation GS-6 and item X.1.3.2                            recommendation 4            Indicated thats a) local manual valve realignment.is not necessary in order to test the ANO-1 EFW tr. ins, and b) prior to a plant startup_ following a refueling ;hutdown. a combination of EFW system tests are performed that verify the nnmal flow path f rom the CST (primary EFW system water source) to the steam generators.
If you have any further questions, please do net hesitate to contact me or                                                                      ;
my staff.
                                     .Very truly yours, pu                                h5W James J. Fisicaro l                                       Director, l.icensing JJF/NBM/sjf l-l l
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      ,-      U. S. NRC June 10, 1992
          ,   Page 4 cca   Mr. Robert Martin U. S. Nucicar Regulatory Commission Region IV 611 Ryan PJaza Drive. Suite 400 Arlingt>n, TX 76011-8064 NRC Scr; or Resident Inspector Arkansar Nuclear One - ANO-1 & 2 Number 1 Nuclear Plant Road Russellville, AR 72801 Mr. Thomas W. Alexion                        -
FRR Project Manager, Region IV/ANO-1 U. S. Nuclear Regulatory Commission NRR Mail Stop 13-11-3 One White Flint North 11555 Rockville Pike Rockville, Maryland 20852 Ms. Sherl Peterson NRR Project Manager, Region IV/ANO-2 U. S. Nuclear Regulatory Commission NRR Mail Stop 13-11-3 One White Filnt North 115$5 Rockville Pike Rockville, Maryland 20852 m    ' ' '}}