ML19326B565
| ML19326B565 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 05/11/1976 |
| From: | Cavanaugh W ARKANSAS POWER & LIGHT CO. |
| To: | Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML19326B558 | List: |
| References | |
| NUDOCS 8004160348 | |
| Download: ML19326B565 (3) | |
Text
'
ty W
[
CErm.~g H EL PING B Li t L O ARKo.NSAS U
.l ARK ANS AS POWER & LIGHT COMPANY STH & LOUISlANA STREETS. LITTLE ROCK. AAKANSAS 72203 *(500 371-4000 May 11, 1976 Reactor Construction and Operations Branch United States Nuclear Regulatory Commission Office of Inspection and Enforcement Region IV 611 Ryan Drive, Suite 1000 Arlington, Texas 76012 Attention:
Mr. G. L. Madsen
Subject:
Arkansas Power.4 Light Company Arkansas Nuclear One-Unit One Docket No. 50-313, License No. DPR-51 IE Inspection Report No. 50-313/76-05 Gentlemen:
The subject inspection identified three violations of the Arkansas Nuclear One-Unit One Technical ~ Specification and one violation of 10CFR50.59.
Our response to each violation is given below:
1.
NRC Position Technical Specification 6.7 requires in part that procedures be prepared, approved and adhered to for preventive or corrective maintenance opera-tions involving nuclear safety of the facility. Contrary to the above, procedures were not followed in the control of hold cards as required by procedure 1004.19, Hold, Caution and QC Tagging Procedure. This item is an infraction.
AP6L Response It is our position that the Hold Card which was not accounted for in accordance witi.1 QCP 1004.19, Hold, Caution and QC Tagging Procedure, is an isolated case; however, the card has been removed and disposed. As -
1 affirmative action plant personnel removing hold' cards have been made aware of the requirements -of QCP 1004.19.
It is our belief that we, at j
this time, are in compliance with QCP 1004.19.
0 V
4 80041603yg
O
~
p 2.-
NRC Position Technical Specification 6.7.3 requires that temporary changes to safety-related operating procedures which do not involve a change of intent be approved by two members of the plant staff, at least one of whom shall be a shift wupervisor.
Contrary to the above requirement, two temporary changes to operating procedures for safety-related systems, temporary change 1 to procedure 1104.03, revision 4, " Chemical Addition," and temporary change 2 to procedure 1103.06, revision 1, " Reactor Coolant Pump Operation," were in effect but had been approved by only one plant staff member. 'this item is an infraction.
APSL Response Temporary change 1 to procedure 1104.03, revisim 4, " Chemical Addition," has been reviewed and approved by the plant cuperintendent and temporary
- change 2 to procedure 1103.06, revision 1, has been 1
superseded by revision 2 of procedure 1103.06.
In order to avoid other noncompliances of this type, temporary changes will not be distributed until the proper endorsements are provided on the temporary change form. Full compliance will be achieved upon the resolution of section 3.c.6 (Details) of USNRC IE Inspection Report No. 50-313/76-05.
3.
hRC Position 10 CFR 50.59(b) requires in part that the licensee. maintain records of changes to procedures as described in the safety analysis report and that such records shall include a written safety evaluation which provides the bases for the detemination that the change does not constitute an unreviewed safety question.
Contrary to the above requirement, no written safety evaluation to provide the bases for -
j determination that the change did not constitute an unreviewed safety question were maintained for three changes to procedures des-j cribed in the FSAR, procedures 1102.06, revision 2, " Reactor Trip Recovery," 1202.32, revision 2, " Loss of Decay Heat Removal," and 1203.03, revision 3, "CRD Malfunction Action." "Ihis item is a deficiency.
j AP6L Response i
It is our contention that we are not in violation of 10CFR50.59(b).
In 10CFR50.59(b) states, "The licensee shall maintain records of
- part, changes in the facility and~of changes in procedures made pursuant to this section, to the extent that such changes constitute changes in the facility as described in the safety analysis report or constitute changes in procedures as described in the safety analysis report i
Tnese records shall include a written safety evaluation which provides bases for the determination that the change, test or experiment does not involve an unreviewed safety question."
U 4
r
..---m-
nr. ta, t.. aacsan 3-May 11, 1976 7
It is our position that we have not changed the purpose of procedures 1102.06, revision 2, " Reactor Trip Recovery," 1202.32, revision 2,
- " Loss of Decay Heat Removal," and 1203.03, revision 3, "CRD Malfunc-tion Action" as described in the Final Safety' Analysis Report.
The three procedures in which we were cited as being in violation of 10CFR50.59(b) were the latest revisions of those procedures. The purpose for revising procedures 1202.32, rev.1, 1203.03', rev. 2, and 1102.06, rev. -1 was to incorporate technical specification changes, provide clarity, reduce the unnecessary overlapping of procedures, and provide continuity between the FSAR, Tech.- Specs.,and procedures.
The PSC has reviewed the questioned procedure as part of its Master Plant Manual review in accordance with procedure 1005.01, " Administrative Control Manual," and section 6.4 of the Tech. Specs.
We contend that 10CFR50.59(b) does not require that all changes to procedures which are identified or listed in the FSAR have written evaluations.which provides bases for the determination that the change
~
does not involve an unreviewed safety question. Therefore, it is our belief that it is the specific nature of the change which detemines the need for a written safety evaluation, and that the PSC, in its review, is responsible for identifying the need for written evaluations in accordance with 10CFR50.59(b).
}
4.
NRC Position
~)
Technical Specification 6.7 requires in part that detailed written i
procedures, covering emergency and off-nomal conditiens shall be prepared,. approved and adhered to for all systems and components involving nuclear safety. Contrary to the above, procedur'es were not provided for the action to be taken in the e' vent of dropping a group of rods in the regulating or safety groups.,This item is a deficiency.
AP6L Response It is our position that the events of dropped rod groups experienced at ANO-1 be considered an isolated case and the assigned cause was attributed to a design deficiency. A new design has been implemented which will remotely reduce the probability that a rachet trip of the nature experienced will occur again.
lhe cognizant or group supervisor shall be responsible for detemining
' l tha need for and development of detailed written procedures covering l
emerg'.ncy and off-nomal conditions, in accordance with QCP 1004.21.
3 V6ry truly yours, w$
O
- William Cavanaugh III Manager, Nuclear Services WC:ay'
,a e.
v r
--w
.