IR 05000313/1991004

Insp Repts 50-313/91-04 & 50-368/91-04 on 910204-08.Major Areas Inspected:Licensee Implementation of Sys to Mitigate ATWS on Unit 1

ML20217B343
Person / Time
Site:	Arkansas Nuclear
Issue date:	02/28/1991
From:	Stetka T, Vickrey R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20217B339	List: IR 05000313/1991004 ML20217B338
References
50-313-91-04, 50-313-91-4, 50-368-91-04, 50-368-91-4, NUDOCS 9103120063
Download: ML20217B343 (6)

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APPENDIX U.S. NUCLEAR REGULATORY C0tittlSS10N

REGION IV

NRC Inspection Report: 50-313/91-04 Operating Licenses: DPR-61 50-368/91-04 NPF-6 Dockets: 50-313 50-368 Licensee: Entergy Operations, In Route 3, Box 137G Russellville, Arkansas 72801 facility Nene: Arkansas Nuclear One (ANO), Units 1 and 2 Inspection At: ANO, Russellville, Arkansas Inspection Conducted: February 4-8, 1991

Inspector: / - .

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R. B. Vickrey, F,epctor Inspector, Plant Date Systems'Section, Division of Reactor Safety Approved: 6 2 Q T. 3. Stetka, Chief, Plant Systems Section ~ Da t'e Division of Reactor Safety i

t Inspection Sumary _

Inspection Conducted February.4-8,.1991-(Repor.t.50-313/91-04)

Areas Inspected: Routine, unannounced inspection of the licensee's implementation of a system to mitigate an Anticipated Transient Without Scram (ATWS) on Unit Results: Within the areas inspected, one violation was identified (paragraph 2).

The violation involved the failure to follw the procedural requirements related to the review of all results of work procedures prior to the modification package being accepted for operational us The inspector determired that the diverse scram system (DSS) met the licensee's commitments to the provision of 10 CFR Part 50.6 Licensee personnel were cooperative during the inspection and were receptive to the inspector's concern .20063 91oso4

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-2-Inspection Conducted February 4-8, 1991 (Report 50-368/91-04)

Areas Inspected: No inspection of Unit 2 was conducte Results: tiot applicabl !

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DETAILS j

.i l '. PERSONS CONTAC_E_TD S@.

• D. Body, Licensing Specialist

• V. Bond, Electrical ~ Engineer / Design Engineering

• M. Cooper,-Licensing, Entergy.0perations

• J. Fisicaro,. Manager, Licensing

• L. Humphrey,- General llanager,~ Quality

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• J. McWilliams, Manager, Modifications

-*T. Ott, Electrical Engineer / Design Engineering

• R. Sessons. Operations A. Spencer, Engineer, Modifications

• J. Vandergrift. Plant flanager, Unit 1

• T. Wilkins, I&C Maintenance

• J. Yelverton, Director, Operations NRC'

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~*L. Smith, Resident inspector

• Denotes attendance at exit interview conducted February 8,199 The inspector contacted other licensee-personnel during the inspectio . ' COMPLI ANCE WITH.10.CFR 50.62 c- UNIT--L . (20020)

The'NRC published 10 CFR 50.62, " Requirements for Reduction of Risk from Anticipated Transients Without Scram (ATHS) Events for Light-Water Cooled-Huclear Power Plants"_ in June 1984. This regulation provided the technical and schedular requirements to be implemented by the licensees to provide protection-from.ATWS events. Further. guidance was provided in NRC Generic Letter 85-06,

"QA Guidance for ATWS Equiprent That is hot Safety Related," dated April 16, 1985'.

.By letter dated September 18, 1989, the NRC provided a Safety Evaluation of the ATWS protectinn that was in'plemented during the 1990 refueling outag 'The systems proposed for compliance-with 10 CFR 50.62 at #NO 1 consisted of a diverse scram system (DSS) and an ATWS Mitigation System Actuation Circuitry (AMSAC). The AMSAC and the DSS are a part of-a computer based ATWS system called the Diverse Reactor Overpressure Prevention System (DROPS).

'Although not required to comply with the ATHS Rule (10 CFR 50.62), the licensee also installed an Automatic Turbine Trip that actue.ted on a DSS Reactor Tri This additional trip feature, which is redundant to the APSAC turbine trip, is considered to be a syster0 design enhancement. The inspector reviewed the

_ Safety Evaluation and the implementing Design Change Package (DCP) 85-1042, Revision This large DCP contains documents and drawings related to the

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-4-instructions. The inspector also verified the installation of the involved hardware and reviewed associated installation work packeges, operating procedures, and operator trainin The DROPS installed at ANO 1 is a two channel logic system which monitors plant process parameters and compares them to preselected trip values to determine if conditions exist that are indicative of an ATWS ever The nonitored parameters are diverse and independent from those which are used by the reactor protection system (RPS). The parameters monitored are Wloe Range Reactor Coolant System (RCS) Pressure, Linear Reactor Power, and Main Feedwater (HFW) Flow for Loop A and Loop The DROPS generates a DSS reactor trip when the Wide Range RCS Pressure exceeds its setpoint of 2430 psig. Each DSS channel trip will remove 24 VDC power f rom one of two Contro' "od Drive Control System (CP,0CS) prograrmable controller channels for conti . , rod groups 5, 6, and 7 and the auxiliary rod group. Los'

of both programable controller channels is required to trip the reactor, thus providing the 2-out-of-2 logi The AMSAC turbine trip and eirergency feedwater (EFW) initiation signals are generated when MFW flow is less than 15 percent in both loops and when reactor power is greater than 45 percent. The turbine trip signals are surced in the existing turbine trip circuitry. Upon receipt of both DROPS channel signals, the auto-stop oil trip solenoid and the auto-stop backup trip solenoid will energize. Either of these solenoids will trip the turbine. The sumation of the two DROPS channel signals provides for a 2-out-of-2 logic actuation. The EFW initiation signals are sent to the emergency feedwater initiation and control (EFIC) System with DROPS Channel 1 actuating the Anticipatory Trip of EFIC Channel A and DROPS Channel 2 actuating the Anticipatory Trip of EFIC Channel D. Actuation of EFIC Channels A and D will result in full EFW initiatio The DR0pS includes a battery backup module for each channel which would provide a minimum of 15 minutes of continued operation in the event of a loss of the 120 VAC power sourc The DROPS may be tested at power by the use of front panel controls. The system test can remove the process inputs and internally simulate the input The setpoints and the trip signals can be monitored at the front panel for verification during testing. Since the DROPS is a 2-out-of-2 logic system, both channels are disabled while testing to avoid spurious operation. Channel testing and bypassing is alarmed in the Control Roo During the inspector's detailec review of the licensee's compliance with ATHS rule 10 CFR 50.62, the inspector made the 1ollowing observations:

o Comprehensive training lesson plans were developed ano administered to operations personnel in a timely manner, i

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o Most of the final engineering and evaluation sign-offs for this 1985 era DCP were completed in 1990. The DCP, therefore, reflected recent technical

support activitie o The DCP was complete and thorough as evidenced by the inclusion of consideration of factors such as fire zone hazards analyses, cable tray seismic and heat rise evaluations, installation details, testing and operating directions and a f ailure mode effects analysis evaluatio o Operating procedures had been revised or developed to provide instructions for operation and interface requirement The licensee had not developed procedures or established the frequency for system testing. Since the system was already'in operation, the inspector questioned the licensee to determine the planned system testing frequency. The licensee informed the inspector that quarterly testing and 18 month calibrations would be conducted. The licensee planned to' develop the Warterly test by March 15, 1991, to meet with a projected performance due date of April 6, 1991. The 18 month calibration will be written and implemented prior to its first required performance. The development and implementation of these test procedures are considered to be an Inspector Followup Ite Inspector Followup Item (313/9104-01): Evaluate the procedures being developed for testing and calibrating the syste During the inspector's review of completed Installation Plan Job Orders, an item of concern was brought to the attention of the licensee. The concern involved an apparent c,uestionable data verification and review that was related to completed Work Plan 1409.231,' Revision 1, Change 1, " Unit 1 DROPS Calibration,"

which had been performed under Job Order 814271. The inspector noted that in Section 8.4 ANALOG INPUT CALIBRATION CHANNEL TWO, Subsection 8.2.2 BATTERY PACK VOLTAGE INPUT, that Steps .14, .15, and .17 had recorded values of less than half of those recorded in Section 8.2 for channel one, and that the recorded values did not meet the tolerance that had been verified in Step .1 The inspector also noted that the work plan review signature spaces for the modifications engineer and the senior startup engineer had not been signe 'AND Procedure 6030.200, Revision 1, " Administration of Post-Modification Testing," Section 5.5.4, states in effect that the Senior Startup Engineer is responsible 1or the review and approval of all results of Work Plans prior to a Hodification Package being accepted for operational use. The failure to sign the work plan review indicated that the senior startup engineer had not approved ;

the work plan results prior to the modification package being accepted for operational us In response to the above identified concern, the licensee promptly initiated Condition Report 1-91-0055 so that this finding would receive prompt assessment.

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The licensee determined that the meter calibration (which only affected the '

battery voltage indication) in question was for indication only and did not affect operability. The licensee also determined that an annunciator alarm was available to ensure that proper battery backup voltage was available. The licensee's planned corrective actions included verification that the calibretion

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-6-of the digital display per Steps 8.4.T.14 through .18 was accomplished as required and that the necessary reviews and sign-off s were completed on the work plans. The condition report also identified that this finding involved several procedure violations, use of an out-of-specification meter, and improper review of a work plan. These conditions were assigned to a " Responsible Nanager" for cause determination and corrective action implementation in accordance with the condition report implementing procedure. The inspector reviewed several other work plans in the DCP installation plan and found no other areas of concern. This finding is considered to be an apparent violation in which appropriate corrective action was initiated prior to the end of the inspection. Since this appeared to be an isolated occurrence in an otherwise centro 11ed process, the enforcement oiscretion of Section V.A. of the NRC's Enforcement Policy has been met. Therefore, no Notice of Violation is being issued for this violatio Notwithstanding the problem involving the implementation of Procedure 6030.200 and development of procedures for system testing, the inspector found the DSS system _to-be acceptable in fulfilling 10 CFR Part 50.62 requirements and the licensee's commitment . EXIT INTERVIEW The inspector summarized the scope and findings of the inspection during the exit interview conducted on February 8,1991, with the personnel ider,tified in paragraph 1. The licensee acknowledged the inspector's comments and provided the commitment dates for procedure development and implementation. Although some proprietary documents were reviewed by the inspector, no proprietary documents were removed from the f acility, and no proprietary information is contained in this report.

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