ML20126C416
| ML20126C416 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 06/10/1985 |
| From: | Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Jeffery Griffin ARKANSAS POWER & LIGHT CO. |
| Shared Package | |
| ML20126C420 | List: |
| References | |
| NUDOCS 8506140413 | |
| Download: ML20126C416 (6) | |
See also: IR 05000313/1984029
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In Reply Refer To:
JUN H 1985
Dockets:
50-313/84-29
50-368/84-29
Arkansas Power & Light Company
ATTN: John M. Griffin,
Senior Vice President -
Energy Supply
P. O. Box 551
Little Rock, Arkansas 72203
Gentlemen:
Thank you for your letters, dated December 27, 1984 and April 4, 1985, in
response to our letters, dated November 27, 1984 and March 5, 1985.
Your responses were discussed on May 7, 1985, in a meeting of our resident
inspectors with Mr. Lomax and other members of your staff.
In your letter dated December 27, 1984, you stated that although the plant
Safety Analysis Reports (SARs) mentian that solid cable tray covers are used
where minimum separation distances for fire protection are not satisfied, the
current fire hazards analysis submitted to the NRC in accordance with 10 CFR Part 50, Appendix R, takes no credit for the tray covers.
It should be noted that the separation requirements of Appendix R are based'on
large exposure fires while the separation requirements stated in your SARs are
based on fires initiated by faults and failures internal to the electrical
equipment or circuits, as is discussed in Regulatory Guide 1.75.
Also, the
separation criteria of Appendix R apply only to the electrical cabling required
for systems used for safe plant shutdown, while Regulatory Guide 1.75 and your
SARs contain separation criteria which are applicable to all redundant Class 1E
electrical cables.
Your letter of April 4, 1985, stated that AP&L has decided to delete or revise
portions of the Conduit and Cable Tray Notes and Details for clarification.
Prior to deleting your design requirements for cable tray covers and other
barriers, you should ensure that the separation criteria of your SARs are met
without reliance upon these barriers.
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We have no further questions at this time and will review your corrective
action during a future inspection.
Sincerely,
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aortgtnal signed Bys
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D. R. HUNTER'"
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D. R. Hunter, Chief
Reactor Projects Branch 2
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cc:
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.J. M. Levine, General Manager
Arkansas Nuclear One
P. O. Box 608
Russellville, Arkansas 72801
Arkansas Radiation Control Program Director
bec to DMB (IE01)
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- Resident Inspector
R. D. Martin, RA
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- D. Weiss,LFMB(AR-2015)
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R. Denise, DRS8P
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ARKANSAS POWER & LIGHT COMPANY
POST OFFICE BOX 551 UTTLE ROCK. ARKANSAS 72203 (501)3714000
December 27, 1984
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Mr. Richard P. Denise, Director
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and Engineering Programs
U. S. Nuclear Regulatory Commission
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Region IV
611 Ryan Plaza Drive, Suite 1000
Arlington, TX 76011
SUBJECT:
Arkansas Nuclear One - Units 1 & 2
Docket Nos. 50-313 and 50-368
Response to Inspection Reports
50-313/84-29 and 50-368/84-29
Gentlemen:
The subject inspection reports have been reviewed.
A response to the
" Notice of Violation" is attached.
Very truly yours,
J. Ted Enos
Manager, Licensing
JTE:RJS:ds
Attachment
cc:
Mr. Norman M. Haller, Director
Office of Management & Program Analysis
U. S. Nuclear Regulatory Commission
Washington, DC 20555
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Mr. Richard C. DeYoung
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Office of Inspection and Enforcement
3,
U. S. Nuclear Regulatory Commission
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Washington, DC 20555
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Based on the results of an NRC inspection conducted during the period of
October 1-31, 1984, and in accordance with the NRC Enforcement Policy
(10 CFR, Part 2, Appendix C), 47 FR 8583, dated March 8, 1984, the following
violatioris were identified:
A.
Failure to Maintain Cable Tray Installations as Required by
Design Drawings (Units 1 and 2)
10 CFR Part 50 Appendix B, Criterion V required hat " Activities
affectingqualItyshallbeprescribedbydocumentedinstructions,
procedures, or drawings, of a type appropriate to the
circumstances and shall be accomplished in accordance with these
instructions, procedures, or drawings."
Electrical Drawings E-59 and E-2059, " Conduit and Cable Tray Notes
and Details" state:
All solid bottom instrument trays shall have covers for their
full length.
Solid covers shall be provided on vertical t-ays for a
minimum of 6 feet above the floor level.
Tray bottom covers shall be affixed flush to the outside of
tray side rail.
Tray top covers shall be held in place by means of stainless
steel cover connection clips or equal.
Contrary to the above, cable tray installation for trays ER302,
ER303, and FJ016 for Unit 1, and trays EB129 EC261, EC212. EJ210,
CJ304, DC456 0C279,andEB129forUnit2falltomeetoneormore
of the installation requirements stated above.
This is Severity level IV Violation.
(SupplementI)(313/8429-01;
368/8429-01)
RESPONSE
The cable trays identified by the inspector as having installation
deficiencies were walked-down and job orders were issued for
correcting the discrepancies between design requirements and
actual installation.
Repairs of the Unit 2 cable trays have boon
completed.
Additional walk-downs of Unit I cable trays were
performed to identify other cable tray cover deficiencies
associated with the present refueling outage work activities.
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Discrepancies noted by the inspector and the walk-down effort will
be corrected by the end of the Unit 1 outage.
A management
directive was issued to maintenance supervision requiring
implementation of practices to prevent further degradation
resulting from maintenance activities.
An evaluation of the
requirements for cable tray covers has been conducted.
Although
the plant FSARs mention that solid covers are used where minimum
separation distances for fire protection are not satisfied, the
current Fire Hazards Analysis (0CAN08404) submitted to NRC in
accordance with 10CFR 50.48 (Appendix R) takes no credit for the
tray covers.
Therefore, tray covers do not fulfill a safety
function but should be maintained to facilitate good housekeeping.
Housekeeping inspections in the future will in':rease the focus on
cable tray covers to insure that they are promptly replaced
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following maintenance or modifications. We are presently in full
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compliance.
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B.
Failure to Adequately Maintain the Refueling Shuffle Procedure (Unit 1)
Technical Specification 6.8.1 states, in part, " Written procedures
shall be established, impicmented, and maintained covering . . .
Refueling Operations . . . ."
Procedure 1502.04, " Refueling Shuffle," has been established in
accordance with this Technical Specification.
Technical Specification 3.8.7 states, " Isolation valves in lines
containing automatic containment isolation valves shall be operable, or
at least one shall be closed." This specification is applicable during
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refuelin0 operations.
Contrary to the above, on October 31, 1984, the NRC inspector found
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that the licensee had issued a change to Procedure 1502.04 on
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October 28, 1984, adding the following note:
"If one automatic
isolation valve is failed open, the other valve in that line must be
closed or capable of automatic actuation."
In that this discrepancy
was identified and corrected prior to commencement of refueling
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operations, Technical Specification 3.8.7 was not violated.
This is a Severity Level IV Violation.
(Supplement I) (313/8429-04)
RESPONSE
The procedure discrepancy was corrected prior to commencement of
refueling operations and full compilance has been achieved as noted in
the violation.
To prevent recurrence, an Operations Department
directive was issued to all Senior Reactor Operators (SRO) who, by
virtue of their SRO licenso, have interim approval authority for
proceduro changes.
Proceduro revisions to safety-related operating
procedures are to be made usino a temporary or permanent change only
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when absolutely necessary to complete or allow a required operation or
when the procedure is clearly in error, and only with concurrence of
the Operations Manager, Operations Superintendent of the affected unit,
or a permanent Operations Technical Staff SRO.
Minor procedure
discrepancies or desired improvements will be accomplished by revision
which requires Plant Safety Committee and General Manager approval
. prior to implementation.
C.
Failure to Adhere to the Requirements of the Refueling Shuffle
. Procedure (Unit 1)
Technical Specification 6.8.1 states, in part, " Written procedures
shall be established, implemented, and maintained covering . . .
Refueling Operations . . . ."
Procedure 1502.04, " Refueling Shuffle,"'has been established in
accordance with this Technical. Specification. Section 4.7 of this
procedure states, " Access to the Reactor Building fuel handling area
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and elevations above and adjacent to the fuel transfer canal shall be
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limited to personnel required to support the refueling effort or
maintenance of required systems.
Measures shall be established to
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prevent loose objects or foreign material from entering the above clean.
area.
Tools shall be secured by lanyards prior to entry into the clean
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area."
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Contrary to the above, on October 31, 1984, the NRC inspectors found
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several loose objects and tools, including nuts, bolts, and a wrench on
the fuel handling bridges.
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This is a Severity Level V Violation.
(Supplement I) (313/8429-05)
RESPONSE
Corrective action was taken by the Shift Supervisor on duty at the time
the items were identified by the inspectors.
The Unit I refueling
Outage Manager and the Nuclear Support Supervisor ensured that the
bridges were clear of all unsecured items during fuel movement.
Full
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compliance was achieved immediately and maintained for the duration of
the shuffle.
Re-enforcement of the necessity of controlling loose
material in the vicinity of the refueling canal will be emphasized with
refueling personnel prior to fuel handling operations during future
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refueling outages.
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