ML20003J191
| ML20003J191 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 04/08/1981 |
| From: | Trimble D ARKANSAS POWER & LIGHT CO. |
| To: | Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20003J190 | List: |
| References | |
| GR-0481-07, GR-481-7, NUDOCS 8105110002 | |
| Download: ML20003J191 (4) | |
Text
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O ARKANSAS POWER & LIGHT COMPANY POST CFFICE BOX 551 UTTLE RCCK. ARKANSAS 72203 (501) 371-4000 April 8,1981 GR-0481-07 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 - Units 1 & 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Response to Inspection Reports 50-313/81-03 and 50-368/81-03 (File:
0232, 2-0232)
Gentlemen:
We have received the Items of Noncompliance included in the subject reports.
Attached is our response to the following " Notice of Vio-lation".
Very truly yours, b
David C. Trimble Manager, Licensing DCT:GAC:si cc:
Mr. Victor Stello, Jr., Director Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission Washington, D. C.
20555 8105110D @
MEMBER MICCLE SCUTN UTTUTTES SYSTEM
STATE OF ARKANSAS
)
) SS COUNTY OF PULASKI
)
I, DAVID C. TRIMBLE, being duly sworn, subscribe to and say that I am 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 GR-0481-07 and know the contents thereof; and that to the best of my knowledge, information and belief the statements made in it are true.
DAVID C. TRIMBLE SUBSCRIBED AND SWORN TO before me, a Notary Public in and for the County d
and State above named, this 7
day of n ryaf y /
, 1981.
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80 MY COMMISSION EXPIRES:
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NOTICE OF VIOLATION Based on the results of an NRC inspection conducted during the period of January 22 - February 21, 1981, and in accordance with the Interim En-forcement Policy, 45 FR 66754 (October 7,1980), the following violations were identified:
1.
Technical Specification 2.2.1 " Reactor Trip Setpoints" states, in part:
"With a reactor protective instrumentation setpoint less conservative than the value shown in the Allowable Values column of Table 2.2-1, declare the channel inoperable and apply the applicable ACTION state-ment requirement of Specification 3.3.1.1 until the channel is restored to OPERABLE status with its trip adjusted consistent with the Trip Set-point value."
Technical Specification 3.3.1.1 states, in part:
"Each reactor protec-tive instrumentation channel shall be demonstrated OPERABLE by the per-formance of the CHANNEL CHECK, CHANNEL CALIBRATION and CHANNEL FUNC-TIONAL TEST operations for the MODES and at the frequencies shown in Table 4.3-1."
Contrary to the above, during the period of January 1980 through January 1981, the licensee did not demonstrate that each reactor protective in-strument channel was OPERABLE for the MODES and at the frequencies shown in Table 4.3-1 of Technical Specification 3.3.1.1.
Specifically, during the period of January 1980 through January 1981, the licensee did not compare the reactor trip setpoints with the Allowable Values of Table 2.2-1 of Technical Specification 2.2.1 when performing the CHANNEL CALI-BRATION and CHANNEL FUNCTIONAL TEST operations on the reactor protective instrumentation channels.
This constitutes a Severity Level V Violation.
(Supplement I.E.)
(368/8103-01)
RESPONSE
The CHANNEL FUNCTIONAL TEST procedures were revised on February 26, 1981, incorporating requirements to assure the "as found" conditions were com-pared with the " Allowable Values".
A review of functional tests per-formed since f nitial fuel loading was conducted, and one setpoint was found exceeding the " Allowable Value" (LER 358/81-011).
Recognizing that this deficiency may apply to other instrumentation systems with Technical Specification setpoints, trip points and/or allowable values, applicable procedures will be revised prior to use.
Full compliance will be achieved on July 1, 1981.
2.
10 CFR 20.201(b) " Surveys" states:
"Each licensee shall make or cause to be made such surveys as may be necessary for him to comply with the regulations in this part."
Contrary to the above, the licensee failed to evaluate the radiation l
levels associated with the high radiation area at the 317' level of the Unit 2 auxiliary building.
Specifically, an entry was made into this u
, area (317' level) by an NRC inspector and a health physics technician on January 29, 1981.
The escort allowed access to the high radiation area without adequate knowledge of the radiological hazards in the area and without the possession of a radiation survey instrument to determine the radiological hazards.
This-constitutes a Severity Level IV Violation.
(Supplement IV.D.1)
(368/8103-02)
RESPONSE
While an entry was made into a posted high radiation area by an NRC inspector and a Health Physics Technician, it should be noted that the individuals did not enter a specific high radiation area.
Health Physics Technicians were counseled on proper procedures and prerequi-sites for entering high radiation areas on January 30, 1981.
Adai-tionally, a memorandum was issued by the Health Physics Supervisor on February 25, 1981, which prescribes Health Physics personnel restric-tions for providing escort into high radiation areas.
To further assist in assuring compliance, a statement of policy defining a Health Physics escort and specifying responsibilities was issued on March 9, 1981.
Full compliance has been achieved.
3.
Criterion V to Appendix B of 10 CFR states:
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings.
Small pipe isometric drawing 2HBC-92-2 shows the location of six seis-mic Class I critical pipe hangers for line number 2HBC-92-2."
Contrary to the above, on January 30, 1981, one of the required pipe supports was not installed on line 2HBC-92-2.
This line is in the loop I service water return line from 2VUC-2A, a switchgear room cooler.
l This is a Severity Level IV Violation.
(Supplement I.D.3) (358/8103-03)
RESPONSE
The missing hanger was replaced on January 31, 1981.
An evaluation l
verified that design loads would not have been exceeded in the event of a DBA with the above identified hanger missing.
An investigation has not revealed when the hanger was removed or the reasons for removal; however, we believe the hanger was probably removed prior to the imple-mentation of the revised administrative and quality control procedures i
which were implemented on November 1, 1980.
The increased control of maintenance activities established in the revista procedures should prevent recurrence.
Full compliance has been achieved.
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