ML19309B733

Responds to NRC 800208 Ltr Re Violations Noted in IE Insp Rept 50-368/80-02.Corrective Actions:Personnel Reminded to Follow Through W/Procedure Change Even When Proposed Change Has Been Approved Ahead of Time

ML19309B733
Person / Time
Site:	Arkansas Nuclear, Zimmer
Issue date:	03/06/1980
From:	Trimble D ARKANSAS POWER & LIGHT CO.
To:	Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML19309B726	List: ML19309B733
References
2-030-03, 2-30-3, NUDOCS 8004070118
Download: ML19309B733 (2)

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ARKANSAS POWER & LIGHT COMPANY POST OFFICE box 551 UTTLE ROCK ARKANSAS 72203 (501) 371-4000 March 6, 1980 2-030-03 Mr. G. L. Madsen, Chief Reactor Operations & Nuclear Support Office of Inspection & Enforcement

.U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

Subject:

Arkansas Nuclear One - Unit 2 Docket No. 50-368 License No. NPF-6 Response to IE Inspection Report No. 50-368/80-02 (File: 2-0232)

Gentlemen:

In response to the subject report, the following is pr'ovided.

NOTICE OF VIOLATION Based on the results of an NRC inspection conducted during the period of December 22, 1979 through January 21, 1980, it appears that certain of your activities were not conducted in full compliance with NRC regulations and the conditions of your license, as indicated below:

Technical Specification 6.8.1 requires that " Written procedures shall be established, implemented, and maintained covering ....

a. The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33. As required in paragraph 1 of Appendix "A" to Regulatory Guide 1.33, Administrative Procedure 1005.01,

" Administrative Controls Manual", has been established. Section 5.9 of this procedure states in part, " Procedures in the Master Plant Manual are to be followed exactly and completely, provided that by so doing an immediate hazard to personnel or plant equip-ment is not created."

Procedure 2.800.01, " Power Ascension Test", Appendix 00, step 2.3 states, " Prior to the trip of a CEA, the CEAC's shall be removed from service in order to avoid adverse CEAC penalty factor effects which may cause a reactor trip during the testing. The CEAC's shall be reinstated to service immediately following return of the dropped CEA back to the fully withdrawn position."

. veusea vioot.e sours uriuries svsTev 800.4070118

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2-030-03 March 6, 1980 l

Step 7.11 states, "Following the return of the dropped CEA to the fully withdrawn position, perform Attachment DD-2 when the COLSS Azimuthal Tilt (CV9008) has decreased below 0.04," and Attachment DD-2, step 5.0 states, " Return all CEAC's to operation and take all CPC channels out of CEAN0P per OP 2105.01, unless further testing requires them to remain in CEANOP".

Contrary to the above, in January, 1980, the licensee failed to return the CEAC's to operation after returning the dropped CEA to the fully withdrawn position and after COLSS Azimulthal Tilt decreased below 0.04. Further testing did not require the CEAC's to remain in CEAN0P.

This is an infraction. (50-368/80-02-01)

' RESPONSE During the preparation for the dropped CEA test, TP 2.800.01 Appendix DD, the procedure was reviewed by the AP&L Plant Analysis Superintendent, the AP&L Shift Supervisor, the Startup Test Director and the C-E Chief Test Engineer. This review concluded that since the dropped CEA test consisted of two dropped rods back to back, it was unnecessary and in fact undesir-able to reinstate the CEAC's to operable status between drops. The amount of time delay between the drops was expected to be (and indeed was) rela-tively short, and restoring the CEAC's to operable would have required dis-connecting test equipment and then immediately thereafter reconnecting it for the second rod drop.

Unfortunately, the review was not documented and no procedure change was made until after the first drop had been completed. A procedure change was initiated before the second drop was conducted, but not before the NRC resident inspector had noted the discrepancy.

Since further testing did require the CPC's to remain in CEAN0P (CEAC's not operable), this change was desirable. Failure to correct the procedure was an administrative oversight which we do not believe constitutes a ser-ious concern. The Test Director and Assistant Test Directors were reminded to follow through with a procedure change even when the proposed change has been reviewed by all necessary parties ahead of time. We do not believe further corrective action is required, especially since the ANO-2 test program is essentially complete and the parties who are primarily respon-sible for making such procedure changes are not permanent staff members.

Very truly yours, ydpg M David C. Trimble N d'g Manager, Licensing DCT: MAS:skm cc: Mr. W. D. Johnson U. S. Nuclear Regulatory Comm.

P. O. Box 2090 Russellville, AR 72801 4