ML20141E962

Insp Rept 50-416/86-06 on 860310-14.Violation Noted:Power Decreased Below Low Power Alarm Point to 23% Power W/O Establishing Rod Sequence Required by Rod Pattern Control Sys

ML20141E962
Person / Time
Site:	Grand Gulf
Issue date:	04/07/1986
From:	Burnett P, Jape F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20141E917	List: ML20141E912 ML20141E942 ML20141E962
References
50-416-86-06, 50-416-86-6, NUDOCS 8604220431
Download: ML20141E962 (6)

See also: IR 05000416/1986006

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UNITED STATES

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N' OLEAR REGULATORY COMMISSION

[.N REGION 11

101 MARIETTA STREET, N.W.'

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Report No.: 50-416/86-06

Licensee: Mississippi Power and Light Company

Jackson, MS 39205

Docket No.: 50-416 License No.: NPF-29

.- Facility Name: Grand Gulf

Inspection Conducted: March 10 - 14, 1986

Inspector:

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Approved by: At W W

F. Jape, Section Chief

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g/ Date Signed

Engineering Branch

Division of Reactor Safety

SUMMARY

Scope: This routine, unannounced inspection entailed 32 inspector-hours on site

inspecting the areas of review of startup test results, review of reactor

operations, review of core performance monitoring, and followup of outstanding

items.

Results: One violation was identified: Failure to follow an operating

procedure - paragraph 6.

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8604220431 860410

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

• J. E. Cross, Site Director

• C, R. Hutchinson, General Manager

R. F. Rogers, Assistant to the General Manager

• D. G. Cupstid, Technical Support Superintendent

• L. F. Daughtery, Compliance Superintendent

• J. D. Bailey, Compliance Coordinator

M. J. Wright, Manager, Plant Operations

J. L. Robertson, Operations Superintendent

Other licensee employees contacted included a shift technical advisor,

engineers, and office personnel.

NRC Resident Inspectors

• R. C. Butcher, Senior Resident Inspector

• J. L. Caldwell, Resident Inspector

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on March 14,1986, with

those persons indicated in paragraph 1 above. The inspector described the

areas inspected and discussed in detail the inspection findings. No

dissenting comments were received from the licensee. The licensee did not

identify as proprietary any of the materials provided to or reviewed by the

inspectors during this inspection.

The following new items were identified:

VIO 416/86-06-01: Failure to follow an operating procedure - paragraph 6.

UNR 416/86-06-02: Define the allowed applications of rod position bypass

switches - paragraph 6.

3. Licensee Action on Previous Enforcement Matters

This subject was not addressed in the inspection.

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4. Unresolved Items

Unresolved items are matters about which more information is required to

determine whether they are acceptable or may involve violations or

deviations. One new unresolved item identified during this inspection is

discussed in paragraph 6.

5. Review of Startup Test Results (72532)

The inspector reviewed the following completed startup tests for

completeness, and followup of test exceptions by the licensee:

a. 1-000-SU-23-06 (Revision 2), Feedwater System, test results were

submitted for review on October 18, 1985, and the results accepted by

the general plant manager on November 4, 1985. Four open test

exceptions, all level 2 acceptance criteria, existed at the time of

closure and were to be tracked by the Plateau Procedure - Full Power.

b. 1-B21-50-26-06 (Revision 3), Relief Valves, was submitted for results

review on September 6,1985, and accepted by the plant manager on

October 3, 1985. There were no open test exceptions at the time of

acceptance.

c. 1-M51-SU-72-06 (Revision 1), Drywell Cooling System, was submitted on

September 10, 1985, and the results accepted on February 6, 1986.

d. 1-000-SU-99-FP (Revision 2), Plateau Procedure - Full Power, was used

to all track test exceptions that existed at the start of full power

testing as well as those generated during the full power test program.

All test exceptions had been cleared by February 7,1986, at which time

the procedure was submitted for review. The results were accepted by

the general plant manager on February 12, 1986.

Following discussions with licensee personnel, the inspector had no

questions on the procedures reviewed. Within the areas inspected, no

violations or deviations were identified.

6. ReviewofPlantOperations(71707)

On March 2, 1986, unit power was reduced rapidly in response to a condenser

tube leak. The initial reduction was by reducing forced flow to about 40%

of rated. Subsequent reduction was by inserting rods. The rods selected

for insertion were not those that would return the rod pattern to that

enforced by the rod pattern control system (RPCS). Consequently, when flow

was reduced to the extent that there was an automatic transfer to the low '

frequency motor generator, power dropped below the low-power setpoint

(LPSP), and further rod motion was inhibited by the RPCS,

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The LPSP was set conservatively, at about 23% rated thermal power (RTP),

insteau cf the 20% RTP required by technical specifications. Hence power,

as recorded in the log kept by the shift technical advisor (STA), did not

drop below 22% RTP, or into the power regime of concern for the rod drop

accident for which RPCS enforcement of rod pattern is essential for safe

operation.

Nevertheless, the Integrated Operating Instruction, Power Operation

(03-1-01-2, Revision 2), in step 6.15, requires that the rod pattern, or

sequence, required by the RPCS be established prior to decreasing power

below 25% RTP, the low power alarm point (LPAP). This requirement is also

addressed in a note following step 4.4.1.e of System Operating Instruction

(501), Rod Control and Information System (04-1-01-C11-2, Revision 4).

Failure to comply with these procedural requirements has been identified as

an apparent violation of Technical Specification 6.8.1.b, VIO 416/86-06-01:

Failure to follow an operating procedure.

Further rod motion was prevented by the RPCS because eight rods were out of

sequence. Four symmetrically-located rods were fully withdrawn, at notch

48, and should have been fully inserted to notch 00. Another four symmetric

rods were fully inserted and should have been at notch 04. To return the

rods to their in-sequence position the licensee bypassed them in the RPCS,

by using the rod position bypass switches, as provided for in section 5.1 of

SOI 04-1-01-C11-2. The bypassing was done serially, only one rod was

bypassed at one time, starting with the out rods, each was fully inserted,

and ending with withdrawing the in rods to notch 04.

In reviewing the FSAR, the inspector could find only one reference to the

rod position bypass switches, and that was in section 7.6.1.7.3.1, " Bypass

of the RPCS". That discussion addresses only the bypassing of failed rods

to fully insert them. No mention is made of other applications of the rod

position bypass switches. Technical Specification 3.1.4.2, action b,

addresses use of the bypass switches as discussed in the FSAR. In addition,

the following Technical Specifications authorize use of the rod position

bypass switches under narrowly defined conditions:

3.1.3.4 - action a.2,

3.1.3.5 - action a.3,

3.10.2.

None of these specifications addresses the application of the rod

position bypass switches as used by the licensee on March 2, 1986. The

issue of allowed use of the rod position bypass switches will be referred to

the Office of Nuclear Reactor Regulation (NRR) for resolution. It will be

tracked as UNR 416/86-06-02: Define the allowed applications of the rod

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position bypass switches.

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In addition to the procedures cited above, the following procedures that

were or appeared to be germane to this issue were reviewed:

a. 03-1-01-002, Power Operations,

b. 01-S-06-002, Conduct of Operations,

c. 01-S-06-006, Fuel Management and Control,

d. 01-S-06-017, Responsibilities and Authorities of Shift Technical

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Advisors,

09-S-01-6, Engineering Personnel Qualification and Certification, and

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f. 09-S-02-400, Control Rod Sequences and Movement Control .

7. Core Performance Monitoring (61702, 61703, 61704, 61706)

The following procedures used in core performance monitoring were reviewed

for technical content and adherence to technical specification surveillance

requirements:

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a. 09-S-02-1 (Revision 5), Core Heat Balance Power Range, provides a

manual method of calculating thermal power when the process computer,

or the program 00-3, is not available. The equations include all the

necessary inputs for an acceptable calculation.

l b. 09-S-02-18 (Revision 6), APRM Calibration to Core Thermal Power, is

! used when the average power range monitors (APRMs) are not required to

read other than actual core thermal power.

I c. 06-RE-SB13-V-0017 (Revision 23), Reactivity Anomalies, addresses the

surveillance requirements of Technical Specification 4. Review of the

records of completed procedures confirmed that it had been performed

with acceptable frequency between April and December 1985.

d. 06-RE-1C51-0-0001 (Revision 22), Local Power Range Monitor Calibration,

was performed with acceptable frequency between February and August

1985. More recent records were in the process of being microfilmed.

l and were not readily accessible for review.

e. 06-RE-SC11-V-0402 (Revision 24), Control Rod Scram Testing, was

reviewed for technical content only, and was fou.^d to be acceptable.

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f. 06-RE-1J11-V-001 (Revision 27), Power Distributior Limits Verification,

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satisfies the surveillance requirements of Technicti Specifications 4.

Station records confirmed that the surveillance hail been performed with

acceptable frequency from October through Decembe.1985.

No violations or deviations were identified during this review of

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procedures,

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8. ReviewofOutstandingItems(92701)

(Closed)UNR 416/86-01-01: Review of level 1 acceptance criteria failures. -

The licensee has reviewed all test exceptions taken against level 1 test

acceptance criteria and documented that review in memo to file 86/0363.

That review demonstrated that all test exceptions had been accepted by NRR

review, closed by successful retest, or passed new criteria generated within

the limits allowed by the test description in the FSAR.

At the exit interview, the inspector raised the issue that some of the new

criteria had been acceptably generated on the basis of steam line tempera-

tures currently existing at full power, but, if improvements in plant

operation or efficiency raised steam line temperature, an untested condi-

tion, with respect to thermal expansion, would exist for the steam lines.

The licensee acknowledged the potential, but argued that the prospect for

increasing steam line temperature was slim. They stated that control and

review of plant modifications would identify the untested condition.

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