ML20004B223

Responds to NRC 810414 Ltr Re Violations Noted in IE Insp Repts 50-313/81-08 & 50-368/81-07.Corrective Actions:Revised Procedure to Establish Controls for Performing Radiation Surveys & Documenting Results

ML20004B223
Person / Time
Site:	Arkansas Nuclear
Issue date:	05/08/1981
From:	Trimble D ARKANSAS POWER & LIGHT CO.
To:	Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20004B211	List: ML20004B223
References
0CAN058102, CAN58102, NUDOCS 8105270409
Download: ML20004B223 (5)

Text

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l ARKANSAS POWER & LIGHT COMPANY PCST CFFICE BCX 551 UTTLE PCCX, ARKANSAS 72203 (5011371-4000 May 8,1981 OCAN058102 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. OPR-51 and NPF-6 Response to Inspection Reports 50-313/80-08 and 50-368/81-07 (File: 0232, 2-0232)

Gentlemen:

We have reviewed the Items of Noncompliance included in the subject reports. Attached is our response to the following " Notice of Violation".

Very truly yours,

.Odys,/8.I David C. Trimble Manager, Licensing DCT:GAC:s1 cc:

$%Mr. Victor Stello, Jr., Director Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission Washington, D. C. 20555 i

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8105270NOh __

STATE OF ARKANSAS )

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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 Letter No. OCAN053102 and know the contents thereof; and that to the best of my knowledge, information and belief the statements made in it are true.

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0 AVID C. TRIMBLE l

SUBSCRIBED AND S'iORN T0 before me, a Notary Public in and for the County and State above named, this 711L day of F# w , 1981.

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7 MRM suiAY J1BLIC W

MY COMMISSION EXPIRES:

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NOTICE,OF VIOLATION Based on the results of an NRC inspection conducted during the period of February 22 through March 21, 1981, and in accordance with the Interim Enforcement Policy 45 FR 66754 (October 7, 1980), the following violations were identified:

1. 10 CFR 20.401(b) states, in part, "Each licensee shall maintain records in the same units used in this part, showing the results of surveys requirea by 20.201(b). . . ."

10 CFR 20.201(b) states, "Each licensee : hall make or cause to be made such surveys as may be necessary Lr him to comply with the regulations in this part."

Radiation Protection Procedure 1602.18, Smear Sampling, has been established by the licensee to partially implement the requiremert!

of 10 CFR 20.201(b).

Step 6.0 in this procedure states, in part, " Monthly smears taken during the Reactor Auxiliary Building Survey will be counted for alpha radiation."

Contrary to the above, although the licensee maintains that the re-quired alpha surveys were conductoi for January 1981, the licensee was unable to retrieve a record - -he alpha smears performed in the Unit No.1 and Unit No. 2 Ree er Auxiliary Buildings for the month of January 1981.

This constitutes a Severity Level V Violation (Supplement IV.E.2)

(313/8108-01; 368/8107-01).

RFSPONSE:

Alpha surveys were conducted in January 1981, however, the survey results were misplaced and have not been located. Statements by Health Physics personr.el performing the surveys attest to the fact that the surveys were conducted.

To prevent recurrence of this violation, Procedure 1602.68, " Control of Routir.e HP Operations", has been revised which establishes appro-priate controls for performing radiation surveys and documenting survey results.

! Procedure training will be completed by May 15, 1981, at wnich time full compliance will be achieved.

2. 10 CFR 20.203(c) equires that each high radiation area shall be con-l spicuously posted with a sign or signs bearing the radiation caution symbol and the words: CAUTION (or DANGER) HIGH RADIATION AREA.

l 10 CFR.202(b)(3) defines "High Radiation Area" as, "any area, acces-sible to personnel, in which there exists radiation originating in whole or in part within licensed material at such levels that a major i

portion of the body could receive in any one hour a dose in excess of ISO millirem."

. _ _ . . _ . . ~ _. -

Contrary to the above, on March 3, 1981, the inspector identified a high radiation area near the bottoir of the "B" Core Flood Tank in the Unit No. 1 Reactor Building which was not posted as a high radi-ation area.

This constitutes a Severity Level IV Violation (Supplement IV.".1)

(313/8108-02).

RESPONSE

Based on radiation surveys performed prior to March 3, 1981, the radiological posting in the "B" Core Flood Tank area was downgraded to a " radiation area". During the fillira of the reactor coolant system an apparent crud bu.ildep created a hotspot resulting in a high radiation area; however, the radiological posting was not up-graded until the high radiation area was identified by the inspector.

Health Physics personnel surveyed and posted the area a "high radia-i tion area".

To prevent recurrence of this violation, areas defined as fluctuating high radiation areas shall remain posted as a "high radiation area" unless othervise approved by the Health Physics Supervisor.

Full compliance will be achieved by June 1, 1981.

3. Unit No. 2 Technical Specification 6.8.1 requires that, " Written pro-cedures shall be established, implemented, and maintained covering .

. . a. The applicable procedures recommended in Appendix "A" Regula-tory Guide 1.33."

Plant procedure 2104.39, "HPSI System Operation", has been established in accordance with this Technical Specification.

Step 2.11.2 in Supplement I, "2P-89A Montnly Test", to procedure 2104.39 requires that service water flow to the ' A' High Pressure Safety Injection (HPSI) pump cooler be verified by opening a vent valve, 25W-1067, on the service water discharge pipe from the cooler.

Contrary to the above, on February 4, 1981, step 2.11.2 in Supplement I to procedure 2104.39 was initialed as having been completed although Unit No. 2 vent valve, 25W-1067, was later determined not to have been installed on that date.

This constitutes a Severity Level V Violation (Supplement I.E.)

(368/8107-04).

RESPONSE

Procedure 2104.39, HPSI System Operation, was revised on March 4,1981.

A personnel error resulted in a step being initialed as having been completed although it was later determined that valve 2SW-1067 had not been installed. Operations personnel have been instructed that proce-dure steps will not be initialed complete until actually performed.

The operator has been counselled ::oncerning this incident and the proper use of procedures.

Full compliance has been achieved.

4. Unit No. 2 Technical Specification 6.8.1 requires that, " Written proce-dures shall be established, implemented, and maintaired covering . . .

f. Fire Protection Program implementation."

Plant procedure 1053.01, " Control of Combustibles", has been established in accordanca with this Technical Specification.

Step 6.2.2 and Attachment 2 of this procedure prohibit storage of com-bustibles in Zone 2073-00, (access area, pump area, tank room, etc.,

Elevation 354) in the Unit No. 2 Auxiliary Building.

Contrary to the above. on February 24. 1981, two oxygen bottles and an acetylene bottle were stored on Elevation 354 in the Auxiliary Building.

This constitutes a Severity Level V Violation (Supplement I.E.)

(368/8107-02).

RESPONSE

The oxygen and acetylene bottles which were stored by contract personnel were removed from the affected area on February 24, 1981. To prevent further violations the affected contract personnel have been indoctri-nated in the requirements for control of combustibles.

Full ccmpliance has been achieved.

5. Unit No. 2 Technical Specification Table 4.3-4 requires that a montnly channel check be performed on Triaxial Time-History Accelerograph ACS-8002.

Contrary to the above, t'he inspector found that, although this instru-

! ment has been calibrated quartarly, no monthly channel checks were per-l formed on ACS-8002 during the period of January 1980 through February 1931.

This constitutes 2 Severity Level IV Violation (Supplement I.O.2)

(368/8107-03).

RESPONSE

Due to a personnel error the surveillance procedure did not require a monthly channel check. The surveillance procedure was revised to re-quire the monthly channel check and was performed on March 3, 1981.

Full compliance has been achieved.

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