ML19336A422

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Forwards Response to 800829 Request to re-evaluate & Describe Actions to Be Taken Re IE Info Notice 80-06, Notification of Significant Events. Util Notification Requirement Expanded
ML19336A422
Person / Time
Site: Arkansas Nuclear  Entergy icon.png
Issue date: 09/18/1980
From: Trimble D
ARKANSAS POWER & LIGHT CO.
To: Madsen G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
1-090-14, 1-90-14, 2-090-21, 2-90-21, IEIN-80-06, IEIN-80-6, NUDOCS 8010230081
Download: ML19336A422 (5)


Text

TO DAC:ADM:

C"nTRAL FILES PCR.:HQ LPDR TIC--

NSIC ARKANSAS POWER & LIGHT COMPANY POST OFFICE BOX 551 UTTLE ROCK. ARKANSAS 72203 (501)371-4000 STATE September 18, 1980 1-090-14 2-090-21 Mr. G. L. Madsen, Chief Reactor Operations & Nuclear Support Office of Inspection & Enforcement U.S. Nuclear Regulatory Commissior.

Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

Subject:

Arkansas Nuclear One - Units 1 & 2 Docket Nos. 50-313 & 50-368 License Nos. DPR-51 & NPF-6 IE Information Notice No. 80-06 (File:

151C.1, 2-1510.1)

Gentlemen:

Pursuant to your request of August 29, 1980, to re-evaluate and describe the actions or reporting requirements that Arknsas Power & Light Company intends to take to meet the intent of the subject notice, the attached responses are provided.

Very truly yours, MNb David C. Trimble Manager, Licensing DCT:DVH:nak Attachments l

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Item A Subsequent to your letter, a supplement to IE Information Notice No. 80-06, " Notification of Significant Events," was issued.

This Information Notice provides additional clarification as to what should be reported in accordance with 10 CFR 50.72, paragraph a, item (1). The Information Notice states in part that initiating events or conditions that place the facility in a Notification of Unurual Event status as defined in NUREG 0610 are those re-quiring notification.

According to the guidance in NUREG 0610, the notification of unusual events requires augmentation of on-site resources and not staffing of the Technical Support Center.

NUR2G 0610 specifies that the Technical Support Center be activated under an " Alert" status, which includes events that are of a more serious nature. Therefore, it appears that the AP&L threshold for reporting events pursuant to this item is too narrow and should be expanded.

Response

The notification requirement has been revised to state that "any event requiring initiation of any section of the ANO Emergency Plan which places the plant in a Notification of Unusual Event or more degraded status."

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Item B Your interpretation regarding 10 CFR 50.72, paragraph a, item (3),

is not consistent with your identification of events which may be reportable in accordance with the item.

Loss of service water, steam leaks, EHC failures, and other similar events that are covered by your plant procedures should be reported.

Response

It has been our intent to report any event that resulted in the plant not being in a controlled or expected condition while operating or shutdown, including those events addressed by proce-3 dure. The clarification provided in our June 11, 1980, letter d

j was to state our opinion that the intent of item (3) is to include significant events not reported under items (1), (5), (6) or (7) such as loss of neutron flux indication, loss of DHR system, less of service water, excessive cooldown rates or boron dilution events when shutdown or loss of instrument power while critical (and not resulting in a plant trip), major steam leaks (such as turbine bypass valve or secondary relief valve failures), loss of RCS pressure control die to pressurizer heater failures, loss of secondary pressure control, which are addressed by procedure as well as situations not addressed by plant procedures, or l

situations where no means exist to monitor or control any major NSS parameter.

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Item D Your interpretation regarding 10 CFR 50.72, paragraph a, item (7),

is not consistent with the clarification provided in the Supplement to IE Information Notice No. 80-06 as to what should be reported under item (7). All ESF actuations or reactor trips, regardless of the significance of the initiating condition, except those that resulted from or that are part of the planned sequence of surveillance testing or normal operation, should be reported.

Response

4 Any event resulting in manual or automatic actuation of Engineered Safety Features, including the Reactor Protection System will be reported. Actuation of Engineered Safety Features including the Reactor Protection System which results from and are part of the planned sequence during surveillance testing does not constitute an event reportable under this item.

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Item E Your interpretation regarding 10 CFR 50.72, paragraph a, item (8),

appears to be consistent with present requirements as related to instantaneous stack release limits and their reporting as defined in Appendix B, Table II, Column 1, of 10 CFR Part 20 for gaseous releases. However, we found no information related to your intended reporting requirements for unanticipated liquid releases.

Response

It is our intent to report any accidental, unplanned, or uncontrolled radioactive release of liquids or gases which results in any hourly average concentration at the site boundary in excess of l

10 CFR 20, Appendix B, Table II, Columns 1 and 2, limits.

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