ML19347F621
| ML19347F621 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 04/01/1981 |
| From: | Trimble D ARKANSAS POWER & LIGHT CO. |
| To: | Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML19347F618 | List: |
| References | |
| IR-0481-01, IR-481-1, NUDOCS 8105220128 | |
| Download: ML19347F621 (4) | |
Text
I ARKANSAS POWER & LIGHT COMPANY POST OFRCE BOX 551 UTTLE ROCK, ARKANSAS 72203 (501) 371-4000 April 1, 1981 1R-0481-01 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 'l Docket No. 50-313 License No. DPR-51 Response to Inspection Report 50-313/81-05 (File:
0232)
Gentlemen:
We have reviewed the subject report.
Attached is our response to this
Very truly yours, b& $-
David C. Trimble Manager, Licensing DCT:GAC:sl n'b cc:
Mr. Victor Stello, Jr., Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D. C.
20555 8105220 fy 7 MEMBEA M100LE SOUTH UT1UTIES SYSTEM
STATE OF ARKANSAO
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) SS COUNTY OF PULASKI
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I, DAVID C. TRIMBLE, being duly sworn, subscribe to and say that I am i
the Manager of the Licensing Section, for Arkansas Power & Light Company; that I have full authority to execute this oath; that I have read the foregoing letter 1R-0481-01 and know the contents thereof; and that to the best of my knowledge, information and belief the statements made in it are true.
O f.
M OAVID C. TRIMBLi SUBSCRIBED AND SWORN TO before me, a Notary Public in and for the County and State aoove named, this
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day of
, 1981.
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-La NOTARY PUBLIC MY COMMISSION EXPIRES:
My Commission Expires 9/1/81 y
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APPENDIX A Nr" ICE OF VIOLATION As a result of the inspection conducted on February 23-25, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violation was identified:
Failure to Provide Suitably Controllec Environmental Conditions I
Criterion II of Appendix B to 10 CFR Part 50 requires that activities affecting quality be accomplished under suitably controlled conditions; in addition, Criterion XI of Appendix B to 10 CFR Part 50 requires that tests be performed under suitable environmental conditions.
Appendix H, " Access Control", of Engineering Test Procedure No. 1309.09,
" Integrated Leak Rate Test", Revirion 0, requires that access to the data acquisition and processing area be restricted during certain ILRT phases.
I-Contrary to the above:
On February 24, 1981, at 8:30 p.m. and again on February 25, 1981, at 12:30 a.m., the IE inspector observed that the access control to the data acquisition and processing area did not result in suitably controlled environmental conditions, in that:
1.
Ongoing installation of firestop material adjacent to the Data Acqui-sition System (DAS) resulted in a heavy congestion of personnel, pneumatic lines and ladders in an area where construction activities could have damaged equipment being used for the integrated leakage rate test.
2.
Ongoing floor sweeping adjacent to the DAS resulted in the generation of a cloud of dust which degraded the environment of the scanning, measuring and recording equipment and had the potential to affect the reliability of data being obtained during the integrated leakage rate test.
These observations represent activities which did not, in this case, impact the integrated leakage rate test, but which represent a failure to adequately control the access by construction forces into an area where the activities had the potential to adversely impact the test.
This is a severity Level VI violation (Supplement I, paragraph F). (313/81-05-01) 4
RESPONSE
AP&L does not agree that these circumstances constituted a violation by failing to provide a suitably controlled environmental condition.
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Access to the Data Acquisition System (DAS) was restricted in accordance with Appendix B, " Access Control", of Procedure 1309.09, " Integrated Leak Rate Test", Revision 0.
These restrictions were correctly implemented by terminating the installation of fire stops even though the potential for damaging the test equipment from this work was remote.
Since the DAS con-sists of sealed electronic and mechanical components, the dust generated by floor sweeping and other normal housekeeping activities does not effect performance of the DAS equipment.
It should also be noted that one of the requirements in the conduct of the Integrated Leak Rate Test is to establish a known leakage to verify test acceptability.
The successful completion of this test, which was acknow-ledged by the inspector, demonstrated that the DAS equipment was not affected by the environment and therefore, access was adequately restric-ted.
If an adverse environment had existed and did in fact have an effect on the DAS equipment, the test conducted with the known leakage would not have been acceptable and the test would have had to be repeated, thus eliminating any minor safety or environmental concern.
In summary, since the known leakage test verified test acceptability, DAS operability, and DAS calibration, AP&L strongly disagrees with your deter-mination that a violation existed because there was no safety or environ-mental safety concern (severity Level VI violation) (Supplement I, para-graph F).
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