ML19326B487
| ML19326B487 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 06/22/1977 |
| From: | Rueter D ARKANSAS POWER & LIGHT CO. |
| To: | Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML19326B479 | List: |
| References | |
| 1-067-15, 1-67-15, NUDOCS 8004150825 | |
| Download: ML19326B487 (3) | |
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M GLPIN G O t.l l L O A R b< A N S A S ARK ANS AS PdWER & LIGHT COMPANY DC.SCX SS1 LarrLE ACCK. ARM ANSAS 72203.(5011371 4000 June 22, 1977 1-067-15 14r. G. L. thdsen, Chief Reactor Operations & Nuclear Support Branch Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011
Subject:
Arkansas Nuclear One-Unit 1 Docket No. 50-313 License No. OPR-51 IE Inspection Report No. 50-313/77-08
('N (File: 0232)
Gen tlemen:
The subject inspection report identified two infractions concerning Technical Specification 6.8.1(e) and a deviation from a Regulatory' Guide.
As applicable, our response includes: (1) corrective steps which have been taken and results achieved; (2) correcti, steps which will be taken to avoid further non-compliance; and (3) ".n: date when full compliance will be achieved.
The NRC position on the -.cd items and coresponding AP&L response are provided below.
I.
NRC Position Based on the results of the NRC inspection conducted on April 25-27, 1977, it appears that certain of your activities were not conducted in full
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compliance with NRC requirements as indicated below:
Technical Specification 6.8.1(e) requires that detailed written procedures shall be prepared and adhered to for the implementation of your Emergency Plans, l
1 A.
Contrary to the above, a first aid room was not located near the Unit 2 controlled access entrance as stated in Section 4.3.2.a of your Emergency Plan.
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This is an infraction.
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- 1 Mr. G. L. fiadstn Juna 22, 1977 1-067-15 m
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B.
Contrary to the above, periodic annual reviews with local gmups were not held between flarch 4,1975 and April 27, 1977, for seven (7) of the 17 support groups listed in the Emergency Plan as stated in Secticn 5.4 of your Emergency Plan.
This is an infraction.
AP&L Response A.
The Arkansas Nuclear One Emergency Plan is a comprehensive plan designed to accomodate both units on the site.
During the devel-opment of the plan the need for a first aid room was recognized, but no location for such a room was available in ANO-1 structures.
As a result, the room was located in ANO-2 which was not as far along in construction.
It was understood during the NRC's review of the plan prior to its approval that the first aid room would not be available for use until ANO-2 went into operation. Since #10-2 is still not in operation, we should not be found in violation of our Emergency Plan due to the lack of availability of this first aid mom. Tne room will be provided in ANO-2 as shown on Figure 1.2-5 (near intersection of column lines C2 and 5) of the N40-2 Final Safety Analysis Report and will be in use prior to the initial p
fuel loading of ANO-2.
B.
In reviewing our Emergency training records, we find that documentary evidence of the 1976 Annual Reviews with local support agencies is available in our files.
A joint Annual Review with local support agencies and the annual emergency drill were conducted concurmntly on March 3,1976. The Annual Review documentation was filed as part of emergency drill package.
We have conducted our 1977 Annual Review with the local support agencies.
In our files, documentation supporting our recent Annual Review with local agencies is available for your examination.
II. NRC Position Based on the results of an NRC inspection conducted during the period April 25-27,1977, it appears that one of your activities was not conducted iri conformance with the NRC Regulatory Guido as indicated below:
Contrary to Section 8-l.2 of Reg. Guide 1.101, the annual emergency drill conducted on December 31, 1976, did not test the following essential aspects of your Ecergency Plan.
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- Mr. G. L. Madsen
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Junn 22,1977 1-067-15 i
C 1.
Establishing and conducting drill activities from the Emergency Control Center and the Emergency Control Office.
2.
Conducting a drill that included participation with off-site support agencies.
3.
Testing the off-site notification call list.
4.
Evaluating the release of radioactive';naterial of sufficient magni-tude that would require appropriate off-site emergency, action.
This is a deviation.
AP&L Rescon&
Regulatory Guide 1.101 was issued after the development and approval of the ANO Emergency Plan and as such it was not used in the development of the plan and we have made no committment to comply with that guide.
Also, Regulatory Guide 1.101 is directed at plans under development, not those already implemented, and hence is not really applicable to the ANO Emergency Plan. We will, however, consider the elements indentified in the NRC findings for future drills.
We also wish to make the following comments on this item as requested p
by the transmittal letter for the subject inspection report.
The purpose of the emergency drill is to exercise and assess the effec-tiveness of the emergency plan.
It is our intent to test various facets of the emergency plan, on a priority basis, throughout the lifetime of the plant. Whereas, the timing for exercising essential emergency
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plan elements will depend on the scope of our planned emergency drill, we are not required nor committed to include all essential elements of the Emergency Plan in a given emergency drill.
Very truly yours,
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Donald A. Rueter Manager, Licensing DAR:tw IU
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