ML20056A021

Ack Receipt of 890307 & s Informing NRC of Steps Taken to Correct Violation Noted in Insp Repts 50-313/88-47 & 50-368/88-47

ML20056A021
Person / Time
Site:	Arkansas Nuclear
Issue date:	07/30/1990
From:	Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Carns N ENTERGY OPERATIONS, INC.
References
NUDOCS 9008030089
Download: ML20056A021 (3)

See also: IR 05000313/1988047

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In.' Reply Refer To: I

. Dockets:- 50-313/88-47 1

g,; 50-368/88-47-

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Entergy Operations, Inc. 3

ATTH: Neil S.- Carns, Vice President '

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' Operations, Arkansas-Huclear One

.

P.00 Box 551 ,

i Little Rock, Arkansas? 72203 .

Gentlemen: i

-Thank you' for your letters of March 7,1989, .and July 20,1990, in

9 response to our letters and Notice of Violation dated February 7,1989,

April 11; 1989, 'and June 22, 1990.' We have reviewed your reply and find it

[

. responsive to the concerns raised in our Notice of Violation. We will review [

the.-implementation of 'your corrective . actions during a future inspection to

-determine.that full compliance has been achieved and will be maintained.

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1: Sincerely.-

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1 Original Signed By: .!

. Samuel J. Collins '~

p Samuel J. Collins Director.

p Division of Reactor Projects

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cc:

Entergy Operations, Inc. . ,

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-ATTN: Donald'C Hintz, Executive. ]

LVice President '

P.O. Box 31995

Jackson, Mississippi 39286 1

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Entergy Operations, Inc.

ATTN: . Gerald.W. Muench, Vice President a'

Operations Support .

-P.O. Box 31995.

Jackson, Mississippi 39286

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r Wise, Carter, Child & Caraway

i- ATTN: Robert B. McGehee, Esq.

P.O. Box 651 1

Jackson, Mississippi 39205 1

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Arkansas' Nuclear One ~

- ATTH: Early Ewing, General Manager

P, Technical Support and Assessment

T, Route 3, Box 137G

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W Arkansas' Nuclear One

- ATTH: Jerry Yelverton, Director l

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n3 ATTH: Mr.. Tom W. Nickels

'f Route 3, Box 137G

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Combustion Engineering, Inc.

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L_ ~ ATTN: Charles'B.,Brinkman, Manager ,

jN Washington _ Nuclear Operations l

u 12300 Twinbrook Parkway, Suite 330

, Rockyille, Maryland 20852- .

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' Honorable Joe W. Phillips

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l County Judge of. Pope County ,

O - Pope County Courthouse- .l

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Russellville,-Arkansas 72801

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0 -, ' - Bishop Cook, Purcell; & Reynolds

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. Arkansas Department of Health l

. ATTN:- Ms. Grets Dicus, Director

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Division of Environmental Health:

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4815 West Markam Street l

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Little. Rock, Arkansas 72201 j

' Babcock & Wilcox

, Nuclear Power Generation Division ,~

ATTN:' Mr. Robert B. Borsum

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1700 Rockville Pike, Suite 525

Rockville, Maryland 20852

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l3 U.S. Nuclear Regulatory Commission

L ATTN: Senior Resident Inspector

H 1 Nuclear Plant Road

Russellville, Arkansas 72801

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U.S. Nuclear Regulatory Comission i

ATTN:, Regional Administrator, Region IV -l

2 - 611 Ryan. Plaza Prive, Suite 1000

Arlington, Texas =76011

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ARKANSAS POWER & LIGHT COMPANY'

March 7, 1989

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SCAN 038901

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L. J. Cellan, _ Director

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Division of Reactor Projects '

MAR I 31939

U.- S. Nuclear Regulatory Commission

Region IV '---------.._

611 Ryan Plaza Drive, Suite 1000 -

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Arlington, Texas 76011 --

SUBJECT: Arkansas Nuclear One - Units 1 and 2

Docket Nos. 50-313/50-368

License Nos. DPR-51 and NPF-6

Response to Inspection Report

50-313/88-47 and 50-368/88-47

.

Dear Mr. Callan:

'

AP&L has reviewed the violation cited in the subject inspection

report. As discussed between Mr. Dwight Chamberlain of your staff

and Mr. Don Lomax of my staff March 6, 1989, we are unable to respond

, to the violation-as it is currently written for reasons stated in the

l enclosure. We request you review our concerns and provide additional

bases clarifying the violation or consider rescinding the violation.

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Very t.uly yours,-

.

M. Levine

xecutive Director

, Nuclear Operations

JML: PLM: vgh

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cc w/ enc 1: U. S. Nuclear Regulatory Commission

Document Control Desk

Mail Station P1-137

Washington, D. C. 20555

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Enclosure.to SCAN 838981

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M 7,-1989:

Page 1 of 3 i

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Notice of Violation

Failure to Perform a Type C (eakage Rate Test on Containment Isolation l

Valve Pursuant to 10 CFR Part'E, Appendix J j

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-10 CFR Part 50, Section 50.54(0) requires that the primary reactor I

containment shall be subject to the requirements of 10 CFR Part 50, ,

' Appendix J.

Appendix J requires that periodic leak testing of the systems

penetrating the primary containment be conducted.

Contrary to the above, the inside containment isolation Check Valve

CS-26, associated with containment penetration P39, was found on

December 15, 1988, to have not been subject to applicable Appendix J

Type C testing.

This is a Severity Level IV violation. (Supplentent I)(313/8847-05)

AP&L's Concerns With Violation 313/8847-05 as Written

'10CFR, Part 50, Appendix J, Primary Reactor Containment Leakage

Testing for Water-cooled Power Reactors,Section II.H. defines " Type

C Tests" as follows:

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"

... tests intended to measure containment isolation valve

leakage rates. The containment isolation valves included are ,

those that:

1. Provide a direct connection between the inside and outside

atmospheres of the primary reactor containment under

normal operation, such as purge and ventilation,. vacuum

relief, and instrument valves;

2. Are required to close automatically upon receipt of a

containment isolation signal in response to controls

intended to effect containment-isolation;

3. Are required to operate intermittently under post accident.

conditions; and

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4. Are in main steam and feedwater piping and other systems

which~ penetrate containment of direct-cycle boiling water

power reactors."

- NRC guidance for 10CFR50.54, dated 4/1/77, indicates that licensees

can limit Type'C testing to those valves as defined by Paragraph

.II.H of Appendix J. .

Additionally, ANO-1 Technical Specification 4.4.1.2.1, items e, f,

and g provide which reactor building isolation valves are within the

. scope of local leak rate tests as follows:

"e. Reactor building isolation valves which provide a direct .

connection with the inside atmosphere of the reactor

building.

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a- inclosure to DCAN#38981

i . . __ March 7, 1989

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f. Reactor ~ building isolation' valves which in the event of

valve leakage on valve malfunction upon a reactor building.

isolation signal, may_ extend (outside of the reactor

building) the boundary of the leakage-limiting barrier of-

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the reactor primary containment beyond that included

during the conduct of the tests required by specification j

4.4.1.1-(includes instrument valves in lines connected to  !

L 'the reactor coolant pressure boundary). 4

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g. Reactor building isolation valves in engineered safety '

systems penetrating the reactor building which, under 4

, post-accident conditions,- are required to close following i

the termination of the safety function." l

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i As AP&L has interpreted the Type C (Local Leak Rate) testing  !

-requirements per 10CFR, Part 50, Appendix J, and the ANO-1 Technical

Specification, the subject check valve CS-26 is not subject to Type

C testing. Valve CS-26 does not provide a direct connection to

containment atmosphere, does not receive a containment isolation -j

signal, is not required to operate intermittently under post

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accident conditions, is not in a BWR system penetrating containment, i

and is not in an engineered' safety system subject to TS item "g"  ;

above.= This interpretation has been supported by NRC concurrence and  ;

issuance of ANO-2 Technical Specifications Table 3.6-1, Containment i

Isolation Valves, which denotes check valve 2CVC-78, (the corresponding l

p check valve on ANO-2 penetration 2P39) as not subject to Type C leakage i

testing. This position.resulted from a series of ANO-2 initial  !

licensing questions and ansvers as follows: -

March 19, 1976 Draft Technical Specification included

Table 3.6-l' ,

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October 29, 1976 NRC letter requested a list of containment

isolation valves and justification for each

not subjected to. Type C leakage rate testing

(Question 042.32)

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January 11, 1977 AP&L responded to questions including ,

Question 042.32

November 11, 1977 NRC's letter requested additional

information regarding compliance to

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Appendix J, stating that the response to

Question 042.32 was unacceptable because it ;i

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was the NRC's position that check valves would

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operate intermittently and were therefore

subject to Type C testing per paragraph

!, II.H.3 of Appendix J.

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February 10, 1978 AP&L responded with~a list of check. valves

and which ones were considered to operate

intermittently. For 2CVC-78, the position ,

was that it does not operate intermittently 1

and ... "THEREFORE WAS NOT. SUBJECT TO TYPE C'

TESTING." (Note that this was presented as

an interpretation as highlighted in the

responding document, and not as a request

for exemption.')

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' June 29, 1978 AP&L provided additional information which-

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discussed systems with'outside valves

locally tested, with inside valves subject-

to Type A testing.

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July 14,-1978 ANO-2 TS issued stating 2CVC-78 was not

subject.to. Type C testing.  !

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August'1978~ ANO-2 SER, Supplement l,.... " concluded

that the proposed: reactor containment leakage

p testing program complies with the requirements

of Appendix J to 10CFR Part 50 with one exception" '

... (the exception related to containment

airlocks - an exemption from 10CFR50 Appendix J

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was received in Amendment I to the ANO-2 license),

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November 6, 1978 NRC's " Summary of Meeting on Containment

Leakage Testing" which. occurred June 20,

1978, stating that the staff concluded that

the program complies with Appendix J as-

stated in Supplement 2 to the ANO-2 Safety

Evaluation Report issued August 1978.

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Based on our previous interpretation of 10CFR50, Appendix J, and

concurrence by the NRC for a comparable design, AP&L believes-it-is

presently complying with regulatory requirements and that no exemption

for not Type C' testing CS-26 is required as stated in the Inspection

Report.

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BCAN079011 'E-"~~"--*~~

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U. S. Nuclear Regulatory Commission

Document Control Desk

Mail Station PI-137

Washington, D. C. 20555

SUBJECT: Arkansas Nuclear One - Units 1 and 2 .f

Docket Nos. 50-313/50-368 1

t-- License-Nos. DPR-51 and NPF-6

Additional Response to Inspection Report

50-313/88-47; 50-368/88-47  ;

l- Gentlemen:

Thank you for the clarification of notice of violation 313/8847-05 which

you provided in your letter. dated June 22,1990(OCNA069018). After review

.of the NRC Staff position and other associated dccuments, it is evident

_ , that containment isolation ~ valve CS-26 does require Type C (local leak

'. rate) testing per-the-requirements of 10CFR Part 50, Appendix J. I

Accordingly, an additional response to the violation is provided pursuant i

to the provisions of 10CFR2.201.

Very truly yours,

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E. C. Ewing

(

General Manager,-

Assessment

ECE/DWB/sgw

Attachment

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cc: Regional Administrator '

Region IV

611 Ryan Plaza Drive, Suite 1000

Arlington, Texas 76011

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My 20,1990

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Artice of Violation '

Ta11ure to perform a TV)e C leakage Rate Test on Containment Isolation

.gsive Pursuant to 10 CF3 Part 50. Appendix J

39 CFR Part 50, Section 50.54(0) requires that the primary reactor

zaatainment shall be subject to the requirements of 10 CFR Part 50,

. Appendix J. 1

Appendix J requires that periodic leak testing of the systems penetrating

the primary containment be conducted. '

tontrary to the above, the inside containment isolation Check Valve CS-26, ,

associated with containment penetration P39, was found on December 15, I

MIB, to have not been subject to applicable Appendix J Type C testing. l

'

His is a Severity Level IV violation. (SupplementI)(313/8847-05)

1. The reason for the violation:

. AN0's interpretation of 10CFR50 Appendix J and the ANO-1 Technical

L Specifications concluded that Type C testing was not required for-

CS-26 because the valve did not meet the criteria for valves that are

subject to Type C testing per paragraph II.H of Appendix J and ANO-1

Technical Specification 4.4.1.2.1, item e, f, and g, therefore, the ,

valve was not Type C (Local Leak Rate) tested. -This interpretation

was incorrect, in light of the Staff position that check valve CS-26

is required to close automatically upon receipt of a containment

isolation signal in response to controls _ intended to effect

containment isolation". Given this interpretation, check valve CS-26

does require Type C testing and failure to do so violated the

requirements of 10CFR50 Appendix J.

L Corrective steps which have been taken and the results: ,

a

In response to the identified concern, a. special Work Plan was

developed and CS-26 was local leak rate tested on February 16,-1989.

The As-Found LLRT resulted in a 650 acem (absolute cubic centimeters

per minute) leakage rate. Maintenance was performed on CS-26 and an

As-Left LLRT was performed with a resultant 4.199 accm leakage rate.

The 650 accm As-Found leakage-rate, when added to the total known Type

B & C leakages (1497.972 accm at the time) resulted in a total leakage

rate of 2147.972 accm. This, total does not approach the ANO-1

Technical-Specification limit for the total B & C leakage of 44,023

l accm and, therefore, was not safety significant.

It should be noted that this violation was identified in December

1988. In February 1989, LLRT of all the ANO-1 containment isolation

check valves was completed. The total leakage from the check valves

was added to the total known Type B & C leakage rate. The total Type

B & C leakage, including the check valve leakages, was determined to

be 9848.195 accm, which is well below the Technical Specification

limit of 44,023 accm.

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July 20,1990

Page 2.

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Additionally, during the ANO-2 seventh refueling outages (Fall 1989),

all the ANO-2 containment isolation check valves were tested per ANO-2

LLRT procedure 2305.17 for information only.- The leakage rates of all-

containment isolation check valves were included as part'of the Type B

& C total of 2845.199 accm, which is well below the ANO-2 Technical

Specification limit of 20,990 accm.

[ 3. The corrective steps which will be taken to prevent recurrence:

The ANO-1 Type C test procedure 1305.18 will be revised to include

M , local leak rate testing of CS-26 along with all other containment-

isolation check valves that are a part of a Type C testable

m- penetration.

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Additionally, the corresponding ANO-2 containment isolation check a

valves will be included in the ANO-2 Type C test procedure 2305.17. J

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Also, a Technical Specification change request will be submitted to

delete the exemption for Type C testing thess ANO-2 containment

isolation check valves,

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4.- The date of full compliance

ANO-1 Local Leak Rate Test procedure 1305.18 will be' revised to

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include local leak rate testing of containment isolation check valves

by October 1,1990, which is prior to the next scheduled ANO-1

-refueling outage. ,

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ANO-2 Local Leak Rate Testing procedure 2503.17 will be revised to

, include local leak rate testing of containment isolation check valves

L. by February 1,1990, which is prior to the next scheduled ANO-2

refueling outage.

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The ANO-2 Technical Specifications change request will be' submitted by

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October 30, 1990.

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