ML20246C874

Insp Repts 50-313/89-23 & 50-368/89-23 on 890605-14.No Violations Noted.Major Areas Inspected:Licensee Actions to Prevent & Respond to Loss of Dhr,Per Generic Ltr 88-17

ML20246C874
Person / Time
Site:	Arkansas Nuclear
Issue date:	07/06/1989
From:	Ray Azua, Bundy H, Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20246C861	List: ML20246C859 ML20246C868 ML20246C874
References
50-313-89-23, 50-368-89-23, GL-88-17, NUDOCS 8907110172
Download: ML20246C874 (13)

See also: IR 05000313/1989023

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APPENDIX B

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U.S. NUCLEAR REGULA10RY COMMISSION

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REGION IV

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NRC' Inspection Report: 50-313/89-23

Operating Licenses: DRP-51

50-368/89-23

NPF-6

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Dockets: 50-313-

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50-368

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Licensee: Arkansas Power & Light Company (AP&L)

P.O. Box 551

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-Little Rock, Arkansas 72203

Facility Name: Arkansas Nuclear One'(AN0), Units 1 and 2

Inspection At: ANO, Russe 11v111e, Arkansas

Inspection Conducted: June 5-14, 1989

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Inspectors:

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7/C/d7

H. F. Bundy, Reactor inspector, Test Programs

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Section, Division,of Reactor Safety

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('t- V - AzuarRestlor, Ir spector. Test Programs

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'Section, Difision of Reactor Safety

Accompanying

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Personnel:

W. C. Seidle, Chief, Test Programs Section

Division of Reactor Safety,. June 8-9, 1989

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Approved:

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C. Seidle, Chief. Test Programs Section

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Division of Reactor Safety

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8907110172 890706

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ADOCK 05000313

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Inspection Sumary

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Inspection Conducted June 5-14, 1989 (Report 50-313/89-23; 50-368/89-23)

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' Areas inspected: Routine, unannounced inspection of licensee actions to

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prevent and, if necessary,' respond to loss of decay heat removal (DHR) as

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described in Generic Letter (GL) 88-17. -

Unit 1 Results-(Report 50-313/89-23): The licensee appeared to have implemented

the recommendations for expeditious actions contained in GL 88-17 except for

resolution of the issues concerning two reliable, independent reactor coolant

system (RCS) level instruments and testing of the RCS level instruments.

These issues.are being tracked as Unresolved Items 313/8923-01 and -03.

The licensee's 90-day response to GL 8b-17 (programmed' enhancements) led the

NRC inspector to believe that the licensee was taking credit for instruments

sensing water level in the RCS."A" and "B" hot legs as the two independent

RCS level instruments. The NRC inspector learned from internal memoranda,

which were later substantiated by a letter from the licensee to the NRC, that

the two independent RCS level:1nstruments were considered to be the "B" loop

wide and narrow range instruments._ The licensee's failure to provide an

accurate and complete 90-day response is an apparent violation of 10 CFR 50.9

(313/8923-04). A question concerning clarification of procedural requirements

for the independent sources of RCS inventory makeup is being tracked as Unresolved

Item 313/8923-02. The licensee comitted, in the 90-day response to GL 88-17,

to install variable setpoint alanns for low decay heat removal flow, high core

exit temperature (CET) indications, and RCS low level in the spring 1990

outage. The licensee indicated that the design for these installations had not

been completed. Other programmed enhancements appeared to have been implemented.

Details concerning the items identified for NRC inspector followup are discussed

in paragraph 2.1.

Unit 2 Results (Report 50-368/89-23): The licens?e's expeditious actions

pursuant to GL 88-17, as committed to in the 60-day response, appeared to have

been implemented. The programmed enhancements committed to in the 90-day

response appeared to have been completed with the following exceptions:

Design and installation of:

an alternate RCS level instrument

a high CET alarm

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variable setpoint low DHR flow alarm

No violations or deviations were identified.

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DETAILS

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1.0 Persons Contacted

AP8L

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• N. S. Carns, Director, Nuclear' Operations

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• G.'T, Jones, General Manager Engineering

E. Ewing.. General Manager, Plant Support

W... Perks. Training Manager

• R. Lane, Manager, ANO Engineering

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• A. J. Wrage III, Manager, EIC Design Engineering

D. Williams, Project Manager, Nuclear Industry Support

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-*J. D. Vandergrift Operations Manager

• D. B. Lomax,, Plant Licensing SupervH or

E. Wentz, Operations Training Supervisor, Unit 1

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• A. B.- McGregor, ' Superintendent; Engineering Services

G. H. Kendrick, Superintendent, Instrumentation and Controls

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• J. Taylor-Brown.: Superintendent, Quality Control

W. Cottingham, Supervisor, EIC Design Engineering

• C. P. Zimmerman, Operations Technical Supervisor, Unit 1

• R. Thornton, Licensing.

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• G. R. D'Auroy, Operations Technical' Engineer, Unit 2

G. V. Woolf Operations Technical Engineer,' Unit 2

NRC

• W. D. Johnson, Senior Resident Inspector

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• R. Haag, Resident Inspector

The NRC inspectors also interviewed other licensee employees during the

inspection.

• Denotes those attending the exit interview on June 9, 1989.

2.0 Licensee Actions to Prevent and Respond to Loss of DHR (TI 2515/101)

The purpose of,this inspection was to verify licensee actions to prevent

and, if necessary, to respond to loss of DHR during operations with the

reactor coolant system (RCS) partially drained. Licensee actions were in

response to recommendations contained in GL 88-17. " Loss of Decay Heat

Removal." Recommendations were made by GL 88-17 in two categories:

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expeditious actions which should be implemented prior to operating in

a reduced inventory condition, and

programmed enhancerrents which should be developed in parallel with

the expeditious actions and may replace, supplement, or add to the

expeditious actions.

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,For purposes of future reference, the recommendations are briefly

paraphrasedbelow(toavoidconfusion,thenumbersareidenticalto

similar items contained in GL 88-17):

' Expeditious Actions

(1) Discuss related events and lessons learned with appropriate. plant

personnel. Provide training shortly before entering a reduced

inventory condition.

(2)

Implement procedures and administrative controls for containment

closure in the event of loss of DHR event. This should be

accomplished:

(a) prior to entering a reduced RCS inventory condition for Nuclear

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Steam Supply Systems (NSSSs) supplied by Combustion

Engineering (CE) or Westinghouse; and

(b) prior to entt. ring an'RCS condition wherein the water level is

lower than 4 inches below the top of the flow area of the hot

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legs at the junction of the hot legs to the reactor vessel (RV)

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for NSSSs supplied by' Babcock and Wilcox (B&W), and should apply

whenever operating in those conditions.

If such procedures and

administrative controls are not operational, then either do not

enter the applicable condition or maintain a closed containment.-

(3) ' Provide at least two independent, continuous temperature indications

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that are representative of the core exit conditions whenever the RCS

is in mid-loop condition and the RV head is located on top of the.RV.

(4) Provide at least two independent, continuous RCS water-level

indications whenever the RCS is in a reduced inventory condition.

Indications should be periodically checked and recorded by an

operator or automatically and continuously monitored and alarmed.

(5) Implement procedures and administrative controls that generally avoid

operations that deliberately or knowingly lead to perturbations to

the RCS and/or to systems that are necessary to maintain the RCS in a

stable and controlled condition while that RCS is in a reduced

inventory condition.

If avoidance of perturbations is impossible,

compensatory measures should be taken.

(6) Provide at least two available or operable means of adding inventory

to the RCS that'are in addition to pumps that are a part of the

normal DHR systems.

(7) For CE unit, implement procedures and administrative controls that

reasonably assure inat both hot legs are not blocked simultaneously

by nozzle dams unless a vent path is provided that is large enough to

prevent pressurization of the upper plenum of the RV.

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(8) Not applicable to ANO.

(Applies to units with loop stop valves.)

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Programmed Enhancements

(1) Instrementatior

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Provide reliable indication of parameters that describe the state of

the RCS and the performance of systems normally used to cool the RCS

for both normal and accident conditions. At a minimum, provide the

following in the control room (CR):

(a) two independent RCS level indications;

(b) at least two independent temperature measurements representative

of the core exit whenever the RV head is located on top of the

RV;

(c) the capability of continuously monitoring DHR system performance

whenever a DHR system is being used for cooling the RCS; and

(d) visible and audible indications of abnormal conditions in

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temperature, level, and DHR performance.

(2) Procedures

Develop and implement procedures that cover reduced inventory

operation and that provide an adequate basis of entry into a reduced

inventory condition. These include:

(a) procedures that cover normal operation of the NSSS, the

containment, and supporting systems under conditions for which

cooling would normally be provided by DHR systems;

(b) procedures that cover emergency, abnormal, off-normal, or the

equivalent operation of the NSSS, the containment, and

supporting systems if an off-normal condition occurs while

operating under conditions for which cooling would normally be

provided by DHR systems; and

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(c) administrative controls that support and supplement the

procedures in items (a), (b), and all other actions identified

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in this communication, as appropriate.

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(3) Equipment

(a) provide equipment of high reliability for cooling the RCS and

avoiding loss of RCS cooling;

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(b) maintain equipment available to mitigate loss of DHR or loss of

RCS inventory should they occur including at least cr.e high

pressure injection pump and one other system, each sufficient to

keep the core covered; and

(c) provide adequate equipment for personnel communications

involving activities related to the RCS or systems necessary to

maintain the RCS in a stable and controlled condition.

(4) Analyses

Conduct analyses to supplement existing information and develop a

basis for procedures, instrumentation installation and response, and

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equipment /NSSS interactions and response.

(5) Technical Specifications (TS)

TS, that restrict or limit the safety benefit of the actions

identified in this letter, should be identified and appropriate

changes should be submitted.

(6) RCS Perturbations

Reexamine Item (5) of expeditious actions and refine operations as

necessary to reasonably minimize the likelihocd of loss of DHR.

Connents on the licensees actions in response to GL 88-17 are provided for

each unit below. Attachment 1 is a tabulation of documents reviewed by

the-NRC inspector which related to Unit 1.

The asterisked documents also

applied to Unit 2.

Attachment 2 is a list of documents reviewed by the

KRC inspector relative to Unit 2 actions only.

2.1 Ur.it 1

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The NRC inspector reviewed lesson plans and class attendance records which

indicated that training responsive to Expeditious Action (1) had been

conducted.

Simulator training on DHR abnormal operations had been

conducted in late sunner 1988. A considerable number of events and

lessor.s learned were included in the lesson plans as well as revised

operations procedures which were generally responsive to GL 88-17

expeditious actions. The NRC inspector noted that most of the training

wasconductedusingprocedureswithnumeroustemporarychang)es.

For

example. 0AP 1015.02, Revision 8 (Attachment 1. Document 16 had been

inserted in the shift turnover book, but no formal training had been

conducted. The NRC inspector noted no substantive differences between it

and the earlier version with temporary changes.

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The NRC inspector reviewed a lesson plan and attendance records for an

expedited course covering the technical aspects of AP&L's 60-day response

to GL 88-17.

It was presented, in February 1989, to all operations and

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maintenance personnel in anticipation of RCS draindown for steam generator

tube plugging and/or reactor coolant pump seal work.

It covered the

salient points of GL 88-17. The basic format was incorporated into

Course AA-21002-020 and included in the requalification training program.

The same materia.s were also included in Course AA-51002-020 on May 23,

1989, and incorporated in the operator training program. The requirements

of Expeditious Action (1) appear to have been satisfied.

With regard to Expeditious Action (2)(b), the licensee did not address

implementation of procedures and administrative controls for containment

closure in the event of loss of DHP. As an alternative, requirements were

placed in 0AP 1015.02 and (0P) 1103.11 (Attachment 1. Documents 16 and 17)

to maintain RCS Level greater than or equal to 371 feet 2 inches. The

licensee determined that this would be above the area which is 4 inches

below the top of the flow area of the hot leg and, therefore, containment

closure requirements would not apply.

From a sketch supplied by the

licensee, the NRC inspector calculated 4 inches below the top of the hot

leg to be 370 feet 8 inches. As discussed below in an internal memorandum

(Attachment 1, Document 9), the licensee established that the only reliable,

continuous level indications are "B" hot leg wide and narrow range level

instruments. The NRC inspector interpreted this memorandum to indicate

that, under the most favorable conditions, the wide range instrument

accuracy limitation is 9 inches. Therefore, the licensee would have to

rely on a single level instrument ("B" loop - narrow range) to preclude

operation at a prohibited low level. This issue will be tracked as

Unresolved Item 313/8923-01, pending further study by the licensee and

review by the NRC.

With regard to Expeditious Action (3) and Programmed Enhancement (1)(b),

Unit I has 32 bottom entry CETs.

Procedure OAP 1015.02 required monitoring

a CET from each train in a reduced inventory condition and recording the

readings. Also, the inadequate core cooling (ICC) display on C19 as well

as the safety parameter display system (SPDS) decay heat screen provided

continuous monitoring.

With regard to Expeditious Action (5) and Programmed Enhancement (6),

Attachment B in 0AP 1015.02 provided a list of components which should not

have been taken out-of-service in a reduced inventory mode. The procedure

required that there be compensatory measures if one of these components

was required to be out-of-service.

With regard to Expeditious Action (6) and Programmed Enhancement (3), a

memorandum referencing Calculation 89-1005-03 (Attachment 1. Documents 8

and 21) states that the reactor building (RB) spray pumps satisfy the

second available means of adding inventory to the RCS. They were required

to be operable in a reduced inventory condition toaether with high pressure

injection (HPI) pumps by 0AP 1015.02. 0AP 1015.0 also specified the

components in two of four DHR systems which muet be operable. Various

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other equipment alignments for DHR were also specified by this procedure.

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With regard to Programmed Enhancements (1)(c) and (d), the dedicated SPDS

display for DHR system monitoring appeared to satisfy GL 88-17

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recommendations. The licensee has implemented an SPDS DHR diagnostic

display, which provides trends of DHR flow and DHR pump suction and

discharge pressure. The low flow alarm setpoint was lowered to provide a

meaningful alarm for all drained down conditions. There was also a DHR

pump trip alarm. The licensee committed, in the 90-day response, to install

variable setpoint alarms for low DHR flow, high CET indications, and low

RCS level in the spring 1990 outage. Because no plans for the variable

setpoint alarms were available, these items will be included in a future

NRC inspection prior to closecut of Temporary Instruction (TI) 2515/101.

With regard to Programmed Enhancement (2), it appeared licensee procedures

and administrative controls generally supported GL 88-17 changes which had

been implemented. 'Some of the procedure changes were temporary and further

procedure revision will be required. The HPI and RB spray pumps were

included as'a part of the lineups in 0AP 1015.02; Procedure A0P 1203.28

(Attachment 1, Document 18) did not appear to support use of these pumps

for inventory makeup. This discrepancy will be tracked as Unresolved

Item 313/8923-02 pending further discussion between the licensee and NRC

on procevoral requirements for using independent inventory makeup pumps.

As discussed below, the licensee elected to use instruments having a

common tap for the liquid leg as the two independent RCS level indicators.

However, there were no test or surveillance procedures to assure valid

level measurements by each instrument as discussed in Section 3.1.2.1 of

Enclosure 2 to GL 88-17. As pointed out in the enclosure, there have been

instances where difficulties with blockage of the liquid connection have

invalidated level indications. Discussions with the licensee indicated

that potential blockage of the tap had not been analyzed. The need for

test procedures to assure that the RCS coolant level instruments will

perform satisfactorily is an unresolved item (313/8923-03) pending further

licensee clarification and NRC review.

With the exceptions discussed herein, it appeared that the licensee had

performed appropriate analyses in accordance with Programmed

Enhancement (4). Specifically, the NRC inspector reviewed the analyses

for RCS pressurization and associated required makeup capability and times

to boiling and core uncovery af ter loss of DHR (Attachment 1, Documents 8,

11, and 21).

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The NRC inspector did not evaluate TS changes that might be required. The

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licensee indicated that TS change evaluation, for DHR considerations, is

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in progress. This item will be inspected during a future inspection

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prior to closure of T1 2515/101.

In attempting to establish the licensee's compliance with commitments made

in the 60- and 90-day responses to GL 88-17 (Attachment 1, Documents 4

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and 10, respectively) relative to Expeditious Action (4) and Programmed

Enhancement (1)(a), the NRC inspector discovered contradictory statements.

Specifically, in discussing "two independent continuous RCS water level

indications," the following statement was made in the 60-day response:

"AN0-1 presently has hot leg level indication for both RCS loops . . . ."

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Similarly, in discussing two reliable independent RCS level indications in

the 90-day response, it was stated, "As described in our 60-day response,

ANO-1 presently has two independent RCS level indications (Hot Leg Level

. Monitoring System)." Because of the reference back to the 60-day

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response, the NRC inspector assumed that the hot leg level monitors for

the two loops constituted the two reliable, independent, continuous RCS'

water level indications. However, upon further research, the NRC

inspector discovered the following statement in an internal memorandum

(Attachment 1. Document 7) which was issued 6 weeks prior to the 90-day

response:

"Two independent and continuous indications of RCS level must be

maintained when RCS level is less than 375'. This will be satisfied

by using the ICC level displays. The B Loop narrow range display and

the B Loop wide range display should be used. The A Loop instruments

have a flow induced error which causes them to read lower than actual

and are therefore not reliable indications of actual level. They may

however be useful for indicating trends. . . ."

This information was confirmed in a second internal memorandum issued

2 weeks later (Attachment 1. Document 9).

During followup with the licensee, it was confirmed that it was their

present intent to consider the "B"

loop narrow range display and the

"B" loop wide range display to be the two independent RCS water level

indications. This was formally confirmed by a letter to the.NRC

(Attachment 1, Document 12). The NRC inspector noted that readings for

"B" RCS level only are required by 0AP 1015.02. The information concerning

the two independent RCS level indications, provided in the 90-day response,

was considered by the NRC inspector to be incomplete and inaccurate

regarding which level indications were to be used and, therefore, is an

apparent violation of 10 CFR 50.9 (313/8923-04).

Further study of licensee memoranda, by the NRC inspector, led to the

conclusion that "B" loop wide and narrow range level instruments may not

constitute reliable, independent instruments within the intent of GL 88-17

because of suspected inaccuracy (of the wide range instrument as discussed

above. An internal memorandum Attachment 1, Document 3) contains the

following statement:

"Also tb wide range ICC level transmitter errors will preclude the

use of these instruments to assess level requirements."

A later memorandum (Attachment 1, Document b) raises further questions

concerning the adequacy of wide and narrow range level instrumentation by

the following statement:

"In reviewing the six programmed enhancements recommended in GL 88-17

it appears that the following additional improvements should be

provided:

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Improve the reliability of the hot' leg level transmitters.- (May

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, require-a means'to maintain reference legs filled and

investigate transmitter failures.)"

The'NRC: inspector 'did not-locate engineering dispositions to these

. suggestions. The RCS waterilevel instrument independence and

reliability issues will be tracked in conjunction with Unresolved-

, Item 313/8923-01 discussed.above.

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,Theilicenste's intended actions in response to GL 88-17, as contained in

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the 60 .and'9_0-day responses (Attachment 1,. Documents 4 and 10), were

!found to be adequate with respect to Unit 2.

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-To ascertain ~ completion.of the expeditious actions tabulated above, the

' NRC inspector revJewed the documents. listed in Attachment 2.

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appeared to have implemented all expeditious actions as stated in the

60-day' response,

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F,th regard to programmed enhancements as stated in the 90-day response,

the licensee's procedures and programs generally appeared sufficient.

However, it was observed that the licensee was taking credit for a.tygon

tube system as the second method of RCS-level indication. As stated in

GL 88-17, the tygon tube system is only acceptable in the short-term. The

licensee committed to install an alternate RCS level indication system no

later than the 1991 (2R8) refueling outage.

There were no violations or deviations relating to Unit 2 identified.

3.0 Exit Interview

The NRC inspectors met with the licensee representatives denoted in

paragraph 1.0 on June 9, 1989, and summarized the scope and preliminary

findings of this inspection. Also, the Region IV Chief Test Programs.

Section, and other Region IV Reactor Pifety Division inspectors discussed

with the AP&L General Manager - Plant Support, Region IV concerns

involving the accuracy of the wide range RCS level indication during a

telephone-conversation on June 14, 1989. The licensee did not identify,

as proprietary, any of the materials provided to, or reviewed by, the NRC

inspectors during this inspection.

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ATTACHMENT 1

UNIT 1 RELATED DOCUMENTS REVIEWED

• 1.

Memorandum LIC-118-49, Licensing to Distribution, " Action Assignments from

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November 23, 1988 Meeting on GL 88-17 Response," dated November 30, 1988

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Memorandum LIC-128-18, Licensing to Distribution, " December 14, 1988

Meeting on GL 88-17," dated December 19, 1988

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Memorandum ANO-88-2-00942, Operations to Licensing, "AN0 Action Assignments

from November 23, 1988 Meeting on GL 88-17 Response," dated December 29,

1988

• 4.

Letter OCAN018901, AP&L to NRC, "GL 88-17 (Loss of DHR) 60-day Response,"

dated January 5, 1989

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Memorandum ANO-89-00477, Operations to Licensing, "AND Action Assignments

from November 23, 1988 Meeting on GL 88-17 Response," dated January 12,

1989

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Memorandum ANO-89-01361, Unit 1 Operations to Work Control Center, " Decay

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Heat Removal Equipment List," dated February 1, 1989

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Memorandum AN0-89-01364, Unit 1 Operations Superintendent to Shift

Supervisors,, "DHR Operations During Draindown Operations," dated February 1,

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8.

Memorandum AN0-89-01491, Unit 1 Operations Superintendent to File, "RCS

Makeup Capability Using Reactor Building Spray Pumps," dated February 1,

1989

9.

Memorandum EIC-89-061, Engineering to Unit 1 Operations, " GL 88-17

Instrument Loop Error Calculations for ANO-1 Hotleg Level Instruments,"

dated February 14, 1989

• 10.

Letter 0CAN038908, AP&L to-HRC, "GL 88-17 90-day Response," dated

March 14, 1989

11. Memorandum, Engineering to ANO Unit 1 Operations, "ANO-1 Times to

Boiling and Core Uncovery Af ter Loss of DHR," dated June 5,1989 at Little

Rock

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12. Letter ICAN068907, AP&L to NRC, " Clarification of GL 88-17 Response

Regarding Independent RCS Level Instrumentation," dated June 12, 1989

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13. Memorandum RER-89-00194, " Schedule for Training on DHR Sys;em as Required

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by GL 88-17"

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14. Simulator Practice Guide, "DHR Abnormal Operations"

15. Case Study INP0 88-018, " Material for a Case Study on Loss of Decay Heat

Removal," dated September 1988

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-16.. Operations Administrative Procedure (OAP)'- 1015.02, Revision 8 "DHR and

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LTOPSystem: Control," App {ovedMay10,;1989

-17. ,RCS Operating Procedure (0P) 1103.11, Revision 9, Waporary: Change 3.-

'" Draining-and Nitrogen 81anketing of the RCS," Approved May;17, 1989

'18.JAbnormalOp'eratingProcedure(AOP) 1203.28 Revision 5, " Loss of Decay

. Heat Removal System,".jApproved.,0ctober 13. 1988

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19. AOP)1203.121, Revision;25, " Annunciator.K10 Corrective Action.(B-2)"

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A0P'1203.12J,.. Revision:25 " Annunciator K11 Corrective Action.-(A-1, A-3,

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21. Calculation 89-1005-03,"ANO-1 Loss-of-DHRRCSPressurizatibn~ Estimates,"

. Approved February,4, 1989

22.. Response to L82-1246,. Unit l' Operations

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'23.: Lesson Plan,' Course AA-51002-020. "DHR," dated May 23, 1989

• Documents which also relate to ANO, Unit 2.

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ATTACHMENT 2

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UNIT 2 RELATED DOCUMENTS REVIEWED

1.

Mechanical Maintenance Procedure 2402.026, Revision 6. " Unit II Equipment

Hatch Opening, Closing, and Maintenance," dated April 28, 1989

2.

Maintenance Administrative Procedure 1025.003, Revision 29, " Conduct of

Maintenance," dated April 22, 1989

3.

Abnormal Operating Procedures (A0P) 22CA.12G, Revision 15,

" Annunciator 2K07 Corrective Action," dated January 27, 1988

1

4.

A0P 2203.29, Revision 2, " Loss of Flow or Inventory While on Shutdown

Cooling," draft

5.

A0P 2203.22 Revision 2. " Loss of Service Water," dated August 21, 1987

6.

Reactor Coolant System Operating Procedure 2103.11, Revision 11, " Draining

the RCS," dated April 19, 1989

7.

Operations Administrative Procedure 1015.08, Revision 2 " Unit 2 Shutdown

Cooling System Maintenance Control," dated November 28, 1983

8.

Unit II Simulator Exercise Guide AA52011-010 Revision 0, " Shutdown

Cooling Operations (Steady State)," dated May 26, 1987

9.

Unit II Simulator Malfunction Scenario 13, Revision 0, "A. LPSI Pump

>

Failure

8. SDC System Leak

C. Loss of Service Water to SDC Heat

-

Exchanger," dated July 23, 1987

10. Plant Operations Procedure 2102.10 Revision 20. " Plant Shutdown and

Cooldown," dated May 26, 1989

11. Training Course AA22002-54/AA52002-042, " Shutdown Cooling Concerns," dated

February 22, 1989

12. Memorandum ANO-88-2-00887, Operations Manager to Supervisor Technical

Operations, "ANO Unit 2 Loss of Shutdown Cooling Necessary Actions," dated

November 29, 1988

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