IR 05000313/1989023

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-313/89-23 & 50-368/89-23

ML20246E278
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/17/1989
From:	Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Campbell G ARKANSAS POWER & LIGHT CO.
References
NUDOCS 8908290057
Download: ML20246E278 (2)

Text

m . . -. .

. . . .. .

,

-

,

-

.

-

.

, ,

'

~

' - '

.,,.

' .( ).[*> ' ,

, >. , .

. .; *; .

,

M IT R

, .

,

In Reply Refer To:

'

Do'ckets: 50-313/89-23 g)J ,

'50-368/89-23

• Arkansas Power & Light Company

'

ATTN: .Mr. Gene Campbell Vice President.. Nuclear Operations.

P.O. Box 551 o Little Rock. Arkansas- 72203

. Gentlemen:

1 .

.

.

Thank;you. for your. letter of August 7,1989, in response to our letter and

.

Notice of Violation dated July 6, 1989. We have reviewed your reply and find it responsive.to the concerns raised in our Notice'of Vioiation. We will' review the implementation 'of your corrective actions during a future. inspection toL g

detemine thatdull compliance has been achieved and will be maintained.

- .

Sincerely,

';

^

ging signed By *

'

,

. y 3. I; Milhom ,

James L. Milboan, Director

.

Division'of Reactor Projects #

+

1" -

'

cc: .

'

Arkansas Nuclear One .

'

,

- . ATTN; .N. S.:Carns, Director Nuclear Operations

$' P10.! Box 608 Russellville, Arkansas 72801

' Arkansas Radiation Control Program Director J

r l

l -- ,

,

RIV:TP .C:TPS AD!DFS ---

i DJ RP

.HBundy/lb y WCSeidie & don Milhoan 'i'

'

f ///r/89 '

'

f//p/89 g//f/89

/{!/89 8908290057 DR 890817 ADOCK 05000313

'{

_ PDC I

.

I o ---

..

.:,_', *

i Arkansas Power & Light Company 2 bec to DMB'(IE01)-

bec distrib by RIV:

RRI R. D. Martin, RA RPB-DRSS . SectionChief(DRP/A)

Lisa Shea, RM/ALF- RIV File DRP MIS System RSTS Operator Project Engineer (DRP/A)

DRS F. C. Seidle-H. Bundy. R. V. Azua C. Harbuck, NRR Project Manager (MS: 13-D-18)

C. Poslusny, NRR Project Manager (MS: 13-D-18)

.

i l

- _ _ - - _

r

'

._

ARKANSAS POWER & LIGHT COMPANY -- -

P. O. BOX 551/LITTLE ROCK. ARKANSAS 72203/(501) 377 3525 T. GENE CAMPBCLL Vice Preticent . Nuclea' August 7, 1989 BCAN088908 Mr. J. L. Milhoan, Director

,

Division of Reactor Projec+.s

[

U. S. Nuclear Regulatory Commission i Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 SUBJECT: Arkansas Nuclear One - Units 1 & 2 Docket N2s. 50-313 and 50-368 License Nos. DPR-S1 and NPF-6 Response to Inspection Report 50-313/89-23 and 50-368/89-23

Dear Mr. Milhoan:

Pursuant to the provisions of 10CFR2.201, a rerponse to the violation identified in the subject inspection report is submitted.

Sincerely

.

A/ ' v/

'

T. G. Cam ell TGC:ft Enc.'isure cc: w/ enc 1: U. S. Nuclear Regulatory Commission Docuinent Control Desk Mail Station P1-137 Washington, DC 20555 x 1 f p fc4P W _ .., _ .. , _ 1... 1~ RoI

- - - - - _

i

~

• .

.'

i Notice of Violation Failure to Provide an Accurate and Complete Response 10CFR Part 50.9 requires, in part, that information required by the Commission's regulations shall be complete and accurate in all material respects. Generic Letter 88-17 requested information regarding decay heat removal when at reduced reactor water level, including the means to measure water level.

Contrary to the above, the licensee failed to provide complete and accurate information concerning the two independent reactor coolant system level indications in letters dated January 5, 1989, and March 14, 1989, in response to Generic Letter 88-17.

This is Severity Level IV violation. (Supplement VII) (313/8923-04).

Response to Violation 313/8923-04 (1) The reason for the violation if admittid:

AP&L does admit the violation described above. It was certainly not AP&L's intent to provide incomplete or inaccurate information to the NRC Staff, and we regret that our submittals to the NRC in response to Generic Letter 88-17 were confusing. However, for the reasons discussed below, AP&L believes that it did attempt in good faith to provide complete and accurate information in response to Generic Letter 88-17. We appreciate this opportunity to clarify ;

our actions on this matter.

The misunderstanding from which this Nctice of Violation stems relates to the two independent reactor coolant system (RCS)

level indications credited with meeting Expeditious Action (4) and l Programmed Enhancement O )(a) or Generic Letter 88-17 for Arkansas Nuclear One facility (ANO-1). The NRC Region IV personnel who inspected the plant for compliance with Generic Letter 88-17 believe that certain statements made in AP&L's required ninety-day response to Generic Let'.er 88-17 concerning the two independent RCS level indications were incomplete and inaccurate with respect to which level indications were to be used.

Generic Letter 88-17's recommended Expeditious Action (4) directs l that the licensee " provide at least two independent, continuous ,

RCS water level indications whenever the RCS is in a reduced l'

inventory condition." It also recommends periodic checking, recording and monitoring of water level indications. NRC licensees were asked to include a description of the actions taken te implement each of the recommended expeditious actions identified in their sixty-day response to Generic Letter 88-17. l AP&L's sixty-day response to Generic Letter 88-17's recommended Expeditious Action (4), submitted January 5, 1989 (0CANB18901),

stated that plant operation logs were being " revised as required to provide for periodic recording and checks of at least two independent, continuous RCS water level indication during DHR operations." It further stated that:

i

_

'

o. . . .

-

ANO-1 presently has hot leg level indication for both RCS loops, ANO-2 has refueling level indication, and both units have temporary tygon tubing level. The procedures governing RCS draining are also being revised to require at least two independent, continuous RCS water level indications available before draining below reduced inventory levels.

Our sixty-day response further stated that "A description of the ANO-1 Hot Leg Level Monitoring System was provided in our ICC Monitoring System Final Design Description dated September 17, 1986 (1CAN098609), and supplemented by subsequent related submittals."

AP&L's ihtent in providing this information was to document the various types of RCS level indication instrumentation available, and, further, to indicate the periodic monitoring and recording requirements were being implemented in response to Expeditious Action (4). It was not AP&L's intention to specify in this passage which of the various RCS level indications were being credited with meeting the recommendation for "two independent, continuous RCS water level indications."

In its subsequent ninety-day response to Generic Letter 88-17, submitted March 14, 1989 (0CAN038908), AP&L discussed its response to each of the six recommended programmed enhancements to be developed in conjunction with the recommended expeditious actions.

In response to Programmed Enhancement (1)(a), which recommc7ded that a minimum of two independent RCS level indications be provided in the control room, AP&L stated with respect to ANO-1 that: "As described in our sixty-day response, ANO-1 presently has two independent RCS level indications (Hot Leg Level Monitoring System)." The intent of this sentence was simply to inform the NRC that AN0-1 does have two independent RCS level indications, as recommended by Generic Letter 88-17. It was not AP&L's intention in either its sixty-day or its ninety-day response to dedicate eny two specific instruments of those available as meeting those requirements. However, we acknowledge that our failure to specify which instruments were being credited constituted an incomplete response in that regard.

Based on the lack of specificity in the AP&L responses, the NRC inspector understandably interpreted the reference to AP&L's sixty-day two loops ' constituted the two reliable, independent, continuou; response to RCS water level indications. He therefore assumed that AP&L was taking credit for instruments sensing water level in the RCS "A" and "B" hot legs as the independent RCS level instruments. (The inspector subsequently learned from AP&L internal memoranda that the two independer.t RCS level instruments were considered to be the "B" loop wide and narrow range instruments. This was corroborated by our June 12, 1989 letter (ICAN068907) to NRC in which we clarified our earlier Generic Letter 88-17 responses with respect to independent RCS level instrumentation.)

_ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _

- _ - - - _ _ _ _ _ _ _ ._ _

!

'

J3 . , ~'

.

.

.)

,

The confusion created by this aspect of AP&L's sixty- and ninety- )

day responses resulted not from any intent on AP&L's part to j

'

provide incomplete or inaccurate information, but, rather, from AP&L's failure to provide a sufficiently clear and unequivocal submittal to the NRC. :l (2) The corrective steps which have been taken and the results

- achieved

AP&L is well aware of its obligation under 10CFR50.9 to provide ;

'

complete and accurate information to the NRC, and strives for completeness and accuracy in its communications with the Commission. In responding to Generic Letter 88-17, AP&L intended in good' faith to meet.its S 50.9 obligation. However, AP&L understands that the aforementioned statements in our sixty-and ninety-day responses to that generic letter were not sufficiently c. lear and therefore, led to the misunderstanding. AP&L immediately addressed the perceived problems by clarifying the situation in conversations with the NRC inspector. This information was subsequently confirmed and documented by our letter to the NRC dated June 12, 1989 (ICAN068987).

Additionally, AP&L provided further information in our letter of July 6, 1989 (8CAN078953) on the capability of the "B" loop level instruments to reliably and accurately provide RCS level

' indication during drain down and reduced inventory DHR operation.

AP&L's licensing and other key personnel have been reminded of the specific obligations codified by 10CFR50.9. In addition, the need for precision and completeness in any correspondence and i communication with the 'IRC has been re-emphasized.

(3) The corrective steps which will be taken to avoid further

~

violations:

AP&L presently has no further corrective actions planned to specifically address thii, violation. However, formal training i

to sensitize employees with respect to 10CFR50.9 is being planned.

j. AP&L believes that those actions already taken with respect to

'

this violation, along with an increased vigilance to assure that information submitted to the NRC is not misleading or confusing, will help to avoid similar violations in the future.

(4) The date when full compliance will be achieved:

AP&L has clarified the record with respect to its position on Generic Letter 88-17. This was confirmed in our letter dated June 12, 1989, to the NRC. Therefore, full compliance with '.

10CFR50.9 has been established.

i