ML19341D143
| ML19341D143 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 12/09/1980 |
| From: | Trimble D ARKANSAS POWER & LIGHT CO. |
| To: | Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML19341D138 | List: |
| References | |
| 1-120-04, 1-120-4, 2-120-10, NUDOCS 8103041034 | |
| Download: ML19341D143 (4) | |
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ARKANSAS POWER & LIGHT COMPANY PCST CFF!CE BCx 551 UTTLE ROCK, ARKANSAS 72203 (501)371-.2000 December 9, 1980 1-120-04 2-120-10 Mr. K. V. Seyfrit, Director Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011
SUBJECT:
Arkansas Nuclear One - Units 1 & 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Response to Inspection Reports 50-313/80-21 and 50-368/80-21 (File:
0232, 2-0232)
Gentlemen:
In response to the Items of Noncompliance included in the subject report, the following is provided.
NOTICE OF VIOLATION Based on the results of an NRC inspection conducted during the period of September 22 - October 21, 1980, and in accordance with the Interim Enforce-ment Policy, 45 FR 66754 (October 7,1980), the following violations were identified:
Table 4.4.4 of Technical Specification 3.4.8 statn, in part, that an
" Isotopic Analysis for Iodine including I-131, I-133, and I-135" be taken "... between 2 and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> following a THERMAL POWER change exceeding 15 percent of the RATED THERMAL POWER within a one hour period."
Contrary to the above, on August 23, 1980, the required isotopic analysis for Iodine was not made within 2 to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after thermal power changes exceeding 15 percent of the rated thermal power with-in a one hour period.
Specifically, on August 23, 1980, between 0000 (midnignt) and 0100 (1:00 AM-CDT) hours power was increased by 18 percent, between 0100 (1:00 AM) and 0200 (2:00 AM) hours power was increased by 18 percent, and between 0200 (2:00 AM) and 0300 (3:00 AM) hours power was increased by 24 percent; however, the 810304103'[
MEM8EA MtCCLE SCUTH UT'UTIES SYSTEM
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Mr. K. V. Seyfrit
. December 9, 1980 required isotopic analysis for iodine was not made until 1050 (10:50 AM) hours.
This'is a Severity Level V Violation. (Supplement I.E.) (368/80-21-01).
RESPONSE
This violation has been reviewed by all Unit Two licensed personnel.
The power distribution and burn-up log has been changed to flag sampling operations requirements if power changes of >15% per hour have occurred.
Full compliance has been achieved.
NOTICE OF VIOLATION Technical Specification 6.8.1 requires that, " Written procedures shall be established, implemented, and maintained covering... a. The applicable procedures recommended in Appendix "A" Regulatory Guide 1.33."
A.
Operating Procedure 2102.02, " Plant Startup," has been established in accordance with this Technical Specification.
Step 13.9 in procedure 2102.02 requires, in part, that valve 2CV-0706 (the Startup and Slowdown Deminerilizer. supply to the Emergency Feed-water Pumps) be shut.
In addition, a plant operator is required to initial the procedural step indicating its completior..
Contrary to the above, on October 15, 1980, valve 2CV-0706 remained open for approximately 45 minutes after step 13.9 of procedure 2102.02 had been initialed complete.
During this 45 minute period, several other procedural steps had subsequently been completed as powe'r escalation continued.
B.
Operating Procedure 2102.01, Attachment E, " Category E Valve Position Verification," has been established in accordance with this Technical Specification.
Attachment E of Operating Procedure 2102.01 requires that manual valve 2SW-17C be lockeo open.
This valve is in the service water return line from the seal ard bearing coolers for the "C" high pressure safety in-jection pump.
Contrary to tne above, on Octooer 16, 1980, the NRC inspector found l
that valve 25W-17C was open as required, but was not locked.
this is a Severity Level V Violation (Supplement I.E.) (368/80-21-04 and 05)
RESPONSE
(Item A) 2SW-17C was immediately locked open.
On October 17, 1980, all other
" category E" manual valves were verified locked in their required positions.
Additional controls over all " category E" manual valves have been added to
7 Mr.' K. V. Seyfrit
- December 9, 1980 the conduct of operations administrative procedure which should substan-tially reduce the probability of recurrence.
(Item B) The primary cause of the event was determined.to be an excessive number of specific operations included in a single procedure step.
In order to minimize the probability of recurrence, the-startup procedure has been revised to separate out those multiple operations into single, specific steps.
Full compliance has been achieved.
'l NOTICE OF VIOLATION Criterion V.of 10 CFR 50, Appendix B, states that activities affecting quality shall be prescribed by documented instructions and shall be accom-plished in accordance with these instructions.
The licensee has adopted a Quality Assurance Program to meet the require-ments of 10 CFR 50, Appendix B, which includes a Quality Assurance Manual.
Section 5.5.2 of the Arkansas Power and Light Company Quality Assurance Manual - Operations (Rev. 4) states, " Applicable instructions, procedures and drawings shall be reviewed, and revised as necessary, following any modifications to tne plant."
Contrary to the above, the applicable procedures and drawings were not revised following the performance of Design Change package 79-2036 per-formed under BWR 2-9095-79-9.
This design change was completed in Novem-ber 1979.
It added a two-inch manual valve in the "C" high pressure safety injection pump recirculation line.
This is a Severity Level V Violation.
(Supplement I.E.) (368/80-21-06).
RESPONSE
The drawings have been revised to indicate that the DCP is pending (i.e.,
that a DCP is in progress).
At the time of initiation of the design change and SWR, no controls were in effect for the identification of design changes wnicn were in progress.
Procedares are in effect now which flag the status of in-progress design changes on DCP's by marking the drawings to indicate a change is-in progress and by making available in the control room details of the design change for review by Operations and Maintenance personnel.
An inspection will be conducted of design changes issued prior to imole-mentation of the present design control procedures to ensure that plant drawings properly reflect the current status of all design changes on ANO-2. A similar review has previously been conducted for ANO-1. We expect this review to be complete by January 1, 1981.
Mr. K. V. Seyfrit
' December 9, 1980 NOTICE OF VIOLATION Technical Specification 3.5.2 requires, when in Modes 1, 2, and 3, that two
- independent Emergency Core Cooling Systems (ECCS) subsystems shall be 0PERABLE with each subsystem including one operable high pressure safety injection (HPSI) pumo. _ Technical Specification 1.6 defines 0PERABLE with the following statement:
"A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function (s).
Implicit in this definition shall be the assumption that all necessary attendant instrumentation, controls, normal and emergency electrical power sources, cooling or seal water, lubri-cation or other auxiliary. equipment that.are required for the system, subsystem, train, component or device to perform its function (s) are also capable of performing their related support function (s)."
Contrary to the above, on October 15, 1980, only the "A" HPSI pump was oper-able with the unit operating in Mode 1.
The "B" HPSI pump was out of service for maintenance and the operability of the "C" HPSI pump was degraded due to a removed access panel from 2VUC 118, one of the air cooling units for the "C" HPSI pump room. With the access panel removed, air flow would bypass the unit's service water cooling coils and the ability of the cooling unit to perform its design function following a Design Basis Accident becomes questionable.
This is a Severity Level IV Violation.
(Supplement I.D.3) (368/80-21-07).
i
RESPONSE
The access panel was immediately installed on 2VUC 118.
The cause of the violation was insufficient procedural guidelines for the transfer of respon-sibilities for maintenance activities from one work group to another work group.
Procedures will be revised to acdrest the transfer of responsibil-ities to prevent recurrence.
Full compliance will be achieved oy Decem-ber 31, 1980.
Very truly yours, l wst id
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David C. Trimble
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Manager, Licensing DCT:GAC pw cc: Mr. Victor Stello, Jr., Director Office of Inspection and Enforcement j-U. S. Nuclear Regulatory Commission l
Washington, D. C.
20555 l
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