0CAN039504, Responds to Violations Noted in Insp Repts 50-313/94-04 & 50-368/94-10 on 941127-950107.Corrective Actions:Containment Sump Isolation Valves Stroke Timed in Closed Direction & SAR Table 6.2-26 Will Be Revised

Responds to Violations Noted in Insp Repts 50-313/94-04 & 50-368/94-10 on 941127-950107.Corrective Actions:Containment Sump Isolation Valves Stroke Timed in Closed Direction & SAR Table 6.2-26 Will Be Revised

ML20080T487
Person / Time
Site:	Arkansas Nuclear
Issue date:	03/08/1995
From:	Mims D ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
0CAN039504, CAN39504, NUDOCS 9503130353
Download: ML20080T487 (10)

Text

y. .c ,

, q 9:ll "*'#"'

E ===- ENTERGY L"Is %~" 1

,4 fkesdhde. AR 72801 : il-Tel501858 5000  ;

y :1

['

l March 8' 1995

, l

~ OCAN039504 i:

o~ ' j.

U. S. Nuclear Regulatory Commission i

' Document Control Desk .

M 'l

Mail Station PI-137 Washington, DC 20555 l

?

Subject:

Arkansas Nuclear One-Units i and 2 Docket Nos. 50-313 and 50-368 l License Nos. DPR-51 and NPF-6 -l Response to Inspection Report -

50-313/94-10;50-368/94-10 e 1

Gentlemen:

-l >

T

- Pursuant to' the provisions of 10CFR 2.201, attached is the response to the violation identified _j during the inspection of activities associated with the labeling of radioactive material q

(50-313/9410-04; 50-368/9410-04). Arkansas Nuclear One (ANO) recognizes that we w: ire'not j  ;

'in compliance with the radioactive material labeling procedures; however, in some cases these. (!

procedures exceed the regulatory requirements for 10CFR Past 20.' ANO plans to perform a I review of the radioactive material labeling program to ensure that procedure controls are i effectively and efficiently implemented to satisfy the regulatory requirements. and ANO management expectations.

l l

Regarding.' violation. 50-368/9410-02, ANO ' acknowledges - that' Safety Analysis Report l Table 6.2-26 is inaccurate and may create confusion regarding the required functions of the  !

containment sump ' isolation valves. However, based on our review of the applicable information, ;j

, we have concluded that the containment sump isolation valves do not have ~a required safety l function to close relative to accident mitigation. Therefore, ANO believes that stroke timing the j valve in the closed direction is not a regulatory or licensing basis requirement and we do not agree l

. that a violation has occurred. The results of our review and the basis for the our position are 1 contained in the response to the violation included in the attachment to this letter. j

~q ,

Should you have questions or comments, please call me at 501-858-4601. l i

Very truly yours, 8 M /d %

Dwight C. Mims )

i Director, Licensmg 4 A {\O 9503130353 950308 f

[ ]

l PDR ADOCK 05000313 Q PM  ;

f j 1

,. ~, ....

_ ,, .n

~; , ' A- .

~

~ . .g I 1U. S. NRC L ,

March 8,'1995) .

.., . ~i A:P

OCAN039504 PAGE 2i

.3

, r. .;  ;

.DCM/AJG/RHS

. . .i

Attachments ':

a l

d cc: Mr. Leonard J. Callan i Regional Administrator ii U. S. Nuclear Regulatory Commission .

RegionIV 611 Ryan Plaza Drive, Suite 400 - 1 Arlington, TX 76011-8064 .E

.ii NRC Senior Resident Inspector '

l

' Arkansas Nuclear One 1448 S. R. 333 l '

Russellville, AR72801 ja Mr. George Kalman '

NRR Project Manager Region IV/ANO-1 & 2 l U. S. Nuclear Regulatory Commission i NRR Mail Stop 13-H-3 One White Flint North l t

11555 Rockville Pike - I

. Rockville, MD 20852 i

]

i i

-I ii 2

9 I

l

h

j

~

' ~

S Attachment to 4

OCAN039504 '

Page 1 of 8 ,

NOTICE OF VIOLATION During an NRC inspection conducted on November 27, 1994, through January 7,1995, two violations of NRC requirements were identified. In accordance with the " General Statement of '

Policy and Procedure for NRC Enforcement Actions," 10CFR Part 2, Appendix C, the violations are listed below:

' A. Technical Specification 4.0'.5.a.2 requires that inservice testing of American Society'off Mechanical Engineers (ASME) Code. Class 1, 2, or 3 valves shall be performed in -

accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable -

Addenda as required by 10 CFR 50.55a(g).

10 CFR 50.55a(g)(2) allows testing of valves in accordance with. ASME Section XI, Division 1, with the addenda in effect 6 mc,nths prior to date ofissuance of the construction permit or with subsequent addenda through the 1988 Addenda and editions through the 1989 Edition.

The licensee selected the 1986 Edition of ASME Section XI as the basis for their inservice testing program.

ASME Boiler and Pressure Vessel Code Section_ XI,1986 Edition, Article IWV-1100,

" Scope" states that this Subsection provides the rules and requirements for inservice testing to assess operational readiness of certain Class 1, 2, and 3 valves which are required to perform a specific function in shutting down a reactor to the cold shutdown condition, in mitigating the consequences of an accident, or in providing overpressure protection. Article .

IWV-3412, " Exercising Procedure," requires the owner to exercise valves to the position required to fulfill their function. Further, Article IWV-3413, " Power Operated Valves,"

requires the owner to specify the limiting value of full-stroke time of each power-operated valve.

Safety Analysis Report, Section 6.2.2.3.1, states that two isolation valves have Lbeen provided in each containment sump recirculation line to provide redundant means of halting flow from the sump to areas outside of containment in the event excessive leakage develops on the recirculation system due to component deterioration.

Contrary to the above, on December 20,1994, the inspector discovered that the licensee had not established a procedure for exercising Containment Sump Isolation. Valves 2CV-5647-1,2CV-5648-2,2CV-5649-1, and 2CV-5650-2 in the closed direction, nor did the licensee specify the limiting value of the full-stroke time in the closed direction.

This is a Severity Level IV violation (Supplement I) (50-368/9410-02).

4

y ,

3 ,

-1 y: wn}

d*'- c.0CAN039504'- '

1

~

l . P'a gs 2 of, 8 :

j O g

Af ' R esnonse to violation 50-368/9410-02

]  :

p (1) Baain for diaan'ino the viol =*ian:

}  ;

'The notice of violation is based, in part, on information contidw,d in the ' Arkansas Nuclear j One-Unit 2 (ANO-2) Safety Analysis Report (SAR). SAR Table 6.2-26,' " Containment i Penetration Barriers," lists'the ' maximum closure time for the containment sump isolation.

d valves as 25 seconds. In addition, SAR Section 6.2.2.3.1 states that two isolation valves have:  !

been provided in each recirculation line to provide redundant means _of halting flow from the 1  :

i i sump to areas outside the containment in the event excessive leakage develops'inithe recirculation system due to component deterioration. The inspector concluded, based on this : 1 information, that the containment sump isolation valves have a required function to close related to accident mitigation and that the valves were required to be stroke time tested in the closed direction in the Inservice Testing (IST) program.

1 Arkansas Nuclear One (ANO) acknowledges that a discrepancy exists in SAR Table 6.2-26 j which creates confusion as to the required function (s) of the containment sump isolation i valves. The column labeled " Maximum Closure Time," which contains the stroke time for the -  !

isolation valves, was originally labeled " Operation Time (Sec)." The column heading was mistakenly changed in a ~SAR amendment submitted in 1992. This error was not detected i

j during the SAR change review process. The table does correctly list the accident position for L the valves as open and the isolation signal to be a Recirculation Actuation Signal (RAS). The ~ j containment sump isolation valves receive an open signal upon receipt of a RAS to allow Emergency Core Cooling System (ECCS) suction from the containment sump upon depletion

]  ;

of the Refueling Water Tank inventory. j The statement in Section 6.2.2.3.1 referenced above is accurate in that the sump isolation j valves could be used to isolate' piping outside containment, if n===~y. However, l containment sump isolation valve closure is not the analyzed method of mitigating component ' l deterioration post Loss of Coolant Accident (LOCA). This statement is the essence of our  ;

position, and is amplified below.  :!

1 The violation is also based in part on the response to Question 104 contained in the minutes of l the public meetings on Generic Letter 89-04. The response states, "the term ' accident' is used 1 by the Commission to describe a broad range of possible adverse events at a nuclear power  ;

plant. Therefore, although most of the accidents of concern to IST'are addressed in the -

accident analysis chapter, licensees should be aware that there may be other accident analyses jl in the FSAR [ Final Safety Analysis Report] that need to be considerec " The notice of j violation states, "The inspector concluded that a significant leak from a deteriorating .;

component, while the recirculation system operated in the recirculation mode,'was an' adverse l event. The inspector considered that potential component degradation included pump seal 1 failure, a valve packing failure, or a pipe break in the high pressure safety injection room, even i though this event was not included as a Chapter 15 design bases accident."  !

l I

i 1

g -

m

,l

^

m- '  ? Attachment tol OCAN039504 Page 3 of 8:

The information contained in Table 6.2-26 relative to maximum closure time and the ,

statement in Section 6.2.2.3.1 of the SAR do not constitute an " accident analysis"las  ;

discussed in this question response. Based on guidance contained in NUREG-0138 and -l similar guidance contained.in ANSI N658-1976 (Single _ Failure Criteria for PWR Fluid. l Systems), ANO does not consider an ECCS pipe break post LOCA to be a credible scenario.1 j NUREG-0138 (November 1976) in addressing passive failures following a Loss-of-Coolant  !

- Accident (Issue 7) concluded that, " calculations of the performance oflong-term recirculation L systems after a LOCA must consider limited leakage due to the failure of components such asL  !

. an ECCS pump or valve seal. The probability of a larger break in ECCS piping, subsequent to?  ;

the original large LOCA pipe break, is considered to be sufficiently low that it need not be' j postulated." -

j

~

Section 6.2.2.3.1 of the SAR discusses the mitigation of component deterioration post LOCA.  !

It states, " Leakage of the containment sump fluid _to areas outside the containment due to -!

component deterioration in the recirculation piping from the sump to the CSS [Containnent -

Spray System] pumps will be confmed to one of the three watertight ESF [ Engineered SafetyL Feature] pump rooms. Excessive leakage into the pump rooms will be detected by a multiple contact detector located in each pump room, which will cause alarms to sound in the control  !

room at successively higher room water levels. Appropriate operator action will then be taken j to isolate the source of the leakage." Component deterioration was also evaluated by 'ANO j and the NRC and is discussed in Supplement 2 tc, the Safety Evaluation Report (SER) for the  !

ANO-2 FSAR. A pump seal failure was analyzed rince it would probably be the most limiting -

component deterioration event. A conservative leak rate of 50 gpm was assumed in the

j NRC's analysis. The SER states, "While there is no reason to believe that a major failure of a ;j pump seal is a likely event, the possibility of such a failure during long-term post-loss-of-' l coolant accident cooling has been considered as an event that should be accommodated by  ;

design." The NRC analysis concluded that the doses resulting from the postulated leakage of post LOCA recirculation water, when added to the direct leakage LOCA doses,' results in .  ;

total doses that are within the guidelines of 10CFR 100 providing ANO's accident recovery j procedures include requirements to isolate the ESF pump rooms within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a loss-of- l coolant accident. The adequacy of ANO's accident recovery procedures with respect to this. j issue was the subject of an Unresolved Item (URI 368/9410-03) which is included in this' a Inspection Report. Information provided to the ANO Resident Inspector subsequent to the .l issuance of the URI resulted in closure of the item.- _l Although ANO does not stroke time test the containment sump isolation valves in the closed  :

direction, they are verified to close once per quarter when the valves are timed in the open i direction, as required during surveillance's by the IST Program. In addition, the valves are l included in the Generic Letter 89-10 requhed Motor-Operated Valve (MOV) Program, and as 'l such, are assured of performance to meet the design basis of the system. j i

I L__. __' _ . _ _ _ _ _ _ _ _ - _ _ _ _ . _ - , - , -

m. -

p c -

' Attachment to i

. OCANO39504L Lc lPage 4 of 8

~ 'In summary, ANO does not believe that the containment sump isolation valves have a r function'to close related to accident mitigation and therefore does not. agree that they are required to be stroke timed in the closed direction. This position is not intended to convey

. that the valves do not have an important closure function, which we believe is recognized and assured; but rather that the inclusion of the valves in the Inservice Testing Program for stroke timing the valves in the closed direction is not required. ANO believes that the testing which is currently _ performed on the valves, which is in accordance with NRC' regulations, is -

adequate to prove their operational readiness in both the open and close directions.

(2) Conective steps that have been taken and the results achieved:

On December 15, 1994, in response to the NRC senior resident inspector's concern, the containment sump' isolation valves were stroke timed in the closed direction. The four containment sump valves closed in less than 25 seconds.

(3) Corrective steps that will be taken to avoid further violations:

SAR Table 6.2-26 will be revised to clarify the conflicting information. The revised table will be included in the next ANO-2 SAR update which. is scheduled to be submitted by May 6,1996.

(4) Date when full comoliance will be achieved:

Based on the conclusion that the containment sump isolation valves are not required to be stroke time tested in the closed direction, ANO believes it is in full compliance with the requirements for containment sump valve testing.

3 * :n 3 E ^ J Attachment tbj OCANO39504: 1

~

Page 5 of Sl .i NOTICE OF VIOLATION- I Bj '10 CFR 20.1904(a) requires that the licensee shall ensure that each container oflicensed material bears a durable, clearly visible label bearing the radiation symbol and the words .

" CAUTION, RADIOACTIVE MATERIAL" or. " DANGER, RADIOACTIVE - l MATERIAL." The label must also' provide sufficient information (such as the radioactive - l nuclide(s) present, an estimate of the quantity..of radioactivity, the date for which:the. l 4 activity is estimated, radiation levels, kinds of materials, and mass enrichment) to' permit j individuals. from handling or using-the containers, or working in the vicinity of the .

containers, to take precautions to avoid, or minimize exposures. .

1. Contrary to the above, on D-mbr 30, 1994,- the inspector identiSed three- [;

radioactive material tags with conflicting information placed on a yellow storage'- -i

-cask located in the low level radioactive waste building. The yellow cask  ;

contained a contaminated carbon steelliner filled with concrete. 1

\

2. Contrary to the above, on December 30,1994, the inspector discovered'that the '

licen:;ee failed to maintain a radioactive material tag' affixed to a Nupak cask  !

containing radioactive resin located in the low level radioactive waste building._ ~

3. Contrary to the above, on December 30,- 1994, the inspector discovered that the -j licensee failed to affix a radioactive material tag to one of two bags containing'  ;

contaminated and ' potentially contaminated - anti-contaminationL clothing. In - 1' addition, the licensee stored the bags in an untagged radioactive low specific-activity storage bm.

4. Contrary to the abose, on December 31,1994, the inspector discovered that the i

individual containers for the Super-Particulate lodine and Noble Gas Monitors 5, 7, 8, and 9 check sources, which held 0.5 microcuries of Strontium-90 and Yttrium-90, had illegible radioactive material stickers.  !

d

5. Contrary to the above, on December 31, 1994, the inspector - discovered a ' I radioactive material tag not affixed to a temporary high efficiency particulate air vacuum containing potentially radioactive material located in the Unit 2 lower i south piping penetration room. 1 1

These examples represent a Severity Level IV violation (Supplement IV) (50-313/9410-04;-

50-368/9410-04).  ;

)

- .e- e, .w sq-- -

gi.+-m ,~

y y' G  ;

• /Atischment'to

. OCAN039504

- Page 6 of 8 - a B. Response to violation '50-313/9410-04: 50-368/9410-04 ~

(1) Reason for the violation:  !

. During December 30-31,1994,' the inspector noted five examples of a failure to ensure that containers of licensed material were labeled as required by' 10CFR 20.1904. Arkansas i Nuclear One (ANO) findings include the following: j Examples 1 and2: 1 The inspector noted three radioactive material (RAM) tags on a yellow storage cask and a ,

missing radioactive' material tag on an adjacent Nupak cask in the new low level radioactive waste storage building (LLRWSB). The Nupak cask (14D-2.0) is used during resin . ,

transfers and dewatering activities and the yellow cask (50 cubic feet) had a liner filled with-concrete.

On December 20,1994, the Nupak cask was used to complete a resin transfer and following'  ;

completion of the activities a RAM tag was attached to the Nupak cask. The following day l the Nupak cask was moved to the new LLRWSB and the information on the RAM tag was <

verified, surveys of the Nupak cask were completed, and the area was verified to be -

properly posted. ':

On December 30,1994, the NRC inspector noted that the requimd RAM tag was missing -  !

from the Nupak cask. The missing RAM tag was found on top of an adjacent yellow cask.

Additionally, the adjacent yellow cask had two different tags attached 1800 apart, for a total ,

of three RAM tags on the yellow cask. Radiation protection supervision and Health Physics ,

(HP) technicians tour the new LLRWSB daily and did not note the discrepancies until notified by the inspector.

Regarding the two different tags attached 1800 apart on the adjacent yellow cask, the two different RAM tags were dated August 14,1991, and June 25,1992. ANO believes that the 1991 RAM tag was attached when the yellow cask was empty, and the 1992 RAM tag was _

attached when the cask liner was filled with concrete because the first tag was obscured from sight.

Example 3:

The inspector noted that a laundry bin in the new LLRWSB had a missing RAM tag.-

Additionally, the bin contained two bags of used laundry of which one bag was missing a RAM tag. Normally the laundry bin has a RAM tag attached to the outside of the bin which eliminates the need to tag each bag placed in the bin and the RAM tag is then updated as the bin contents change. Radiation protection personnel reviewed the previous monthly area inspection reports to determine if the laundry bin discrepancy had been previously identified.

The laundry bin RAM tag discrepancy was not reported, but the review indicated that the event occurred after December 13,1994.

i I

l l

l 1

1;g n

- Q -

t cM

• Attachment to-- i V  : OCANO39504 -

. Page 7 of 8 ;

,- y

[ ( ^

• Example # . .  ;

j The inspector noted that RAM labels'were marginally visible on the super particulate iodine

noble gas (SPING) monitors 5, 7, 8 and 9 check source containers.' The condition had been j lpreviously identified by radiation protection personnel during the Fall and Wm' ter of 1994. j

- Additionally, a Quality Assurance (QA) audit also noted the marginally visible RAM labels j in a January' 5,1995, Condition Report. j Example 3:

The inspector noted that a RAM tag was no longer attached to a temporary high efficiency -

particulate-air (HEPA) fdter unit. Additionally, the tape attached to the RAM tag obscured

]

the three-bladed radiation symbol and the word " CAUTION." The use' of tape' is an-  ;

acceptable means of attaching.a RAM tag to radioactive material,; but the required -!

information must be visible and the tag securely attached. The' tape was' removed and a ty-wrap used to securely attach the RAM tag to the HEPA filter unit.'

The root cause of the labeling deficiencies is inattention to detail for radioactive material 1 labeling by radiation protection management personnel and HP technicians. Additionally, d

. adequate management attention and emphasis were not placed on timely correction of the - i SPING labeling problems.

i The lack of communication and appropriate follow-up to the labeling deficiencies also j contributed to the condition. Additionally, the source custodians were provided insufficient ~!

guidance regarding the radiation source accountability program. j

- (2) Corrective stens that have been taken and the results achievedi The RAM tag discrepancies on the Nupak cask and the laundry bin were corrected when the - j j

HP technicians ~were notified the day of the inspection. The yellow cask old RAM tags were removed and replaced with an updated tag on the day of them' spection. '

1 On the day of the inspection, the inadequate HEPA filter unit RAM tag was corrected by d attaching the RAM tag with a ty-wrap. j q

On January 7,1995, the HP source custodian sent a memorandum to each source custodian  :

that outlined the expectation for conducting a source inventory to ensure that each source had -l a RAM label that was clearly visible, properly attached, and completed.  ;

l On January 11,1995, the source RAM labeling for SPING 5, 7, 8, and 9.was corrected.x In 'l

. addition, the source containers for the remaining SPING monitors were inspected and are in .

compliance with procedure requirements.

1 l

. j

.i l

I

'i

= ._ _ . . _

y -

,c., ~.i .

w'Et Attachment to s-

' 1 f  ; OCANO39504 :j Page 8 of 8

]

j

~

Idn February 17,1995, the ANO turbine buildings,~ auxilia y buildings, Arkansas Nuclear.Onk Unit 1 (ANO-1) reactor building,' and radioactive waste storage buildings were law to? j verify that the RAM tagging and labeling met the required implementation procedures.'

M .

-i By March 3,1995, this condition"and individual responsibilities.wereidiscussed with the -  !

radiation protection personnel during crew briefs.J Emphasis was placed on'the requirements 1 M

forilabeling licensed ' material to ensure that labels are visible, properly attached, and .- i completed.- I (3) Corrective stens that will be taken to avoid further violations: ,j l: Guidance for source custodians will be developed to enhance the source =es=*=hility ,

e program. The enhancement will include instructions for the source custodians to follow when a concern or. problem is identified and provide a' point of contact within the' radiation .

protection department to resolve questions. The enhawmA guidance is scheduled tolbe  :

completed by April 30,1995.

,7y Prior to the next Arkansas Nuclear _ One-Unit 2 (ANO-2) refueling. outage (2R11), a .j surveillance of the radiation protection labeling and tagging program will be conducted.to _ i determine the effectiveness of the program. The survey results will be used to determine if 1 additional corrective actions are necessary.' ANO-2 refueling outage 2Rll is' scheduled to-begin Fall 1995.

]

l l

'Ihe lessons learned regarding the RAM labeling and tagging concerns of this condition will be '  !

incorporated into the contractor HP technician pre-outage training lesson plans. This is  ;

scheduled to be completed prior to the next ANO-2 refueling outage 2R11.

l A review of the ANO radioactive materiallabeling program will be performed to ensure that the procedural controls are effectively and efficiently implemented to satisfy the' regulatory 9 requirements and ANO management expectations. Revisions to ANO ' radioactive material  !

labeling procedures will be considered after evaluating the results of the review. .

t

' b (4) Date when full compliance will be achieved:  ;

Full compliance was achieved during January 1995, when the RAM tag and. label  !

n discrepancies were corrected. Actions to reduce the potential for future violation will be -

, accomplished on April 30,1995, when the source custodian guidance is complete. '

.i 4

i V i l

. _ .__ .. u _ _ _ _ _ _ _ _ _ .-