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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-313/96-06 & 50-368/96-06 on 961112
	ML20133J206
Person / Time
Site:	Arkansas Nuclear
Issue date:	01/14/1997
From:	Dyer J; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Hutchinson C; ENTERGY OPERATIONS, INC.
References
	NUDOCS 9701170438
	Download: ML20133J206 (4)
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C. Randy Hutchinson, Vice President

Operations

Arkansas Nuclear One

Entergy Operations, Inc.

1448 S.R. 333

Russellville, Arkansas 72801-0967

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SU8 JECT: NRC INSPECTION REPORT 50-313/96-06:50-368/96-06

Thank you for your letter of December 12,1996,in response to our letter and '

Notice of Violation dated November 12,1996. We have reviewed your reply and find it I

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

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implementation of your corrective actions during a future inspection to determine that full

compliance has been achieved and will be maintained.

Sincerely,

C

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J. . Dyer, Director

Division of Reactor Projects q

Docket Nos.: 50-313

50-368

License Nos.: DPR-51

NPF-6

cc:

Executive Vice President

& Chief Operating Officer

Entergy Operations, Inc.

P.O. Box 31995

Jackson, Mississippi 39286-1995

Vice President

Operations Support

Entergy Operations, Inc.

P.O. Box 31995

Jackson, Mississippi 39286 '

9701170438 970114

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Entergy Operations, Inc. -2-

Manager, Washington Nuclear Operations

ABB Combustion Engineering Nuclear

Power

12300 Twinbrook Parkway, Suite 330

Rockville, Maryland 20852

County Judge of Pope County

Pope County Courthouse

Russellville, Arkansas 72801

Winston & Strawn

1400 L Street, N.W.

Washington, D.C. 20005-3502

Bernard Bevill, Acting Director

Division of Radiation Control and

Emergency Management i

Arkansas Department of Health

4815 West Markham Street, Slot 30

Little Rock, Arkansas 72205-3867

Manager

Rockville Nuclear Licensing

Framatone Technologies

1700 Rockville Pike, Suite 525

Rockville, Maryland 20852 ;

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bec distrib. by RIV:

L. J. Callan Resident Inspector

DRP Director MIS System

Branch Chief (DRP/C) RIV File

Project Engineer (DRP/C) DRS-PSB

Branch Chief (DRP\TSS) Leah Tremper (OC/LFDCB, MS: TWFN 9E10)

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DOCUMENT NAME: R:\_ANO\AN606AK.KMK

To receive copy of document, indicate in box: "C" = Copy wohout enclosures "E" = Copy with enclosures "N" = No copy

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Branch Chief (DRP/C) RIV File

Project Engineer (DRP/C) DRS-PSB

, Branch Chief (DRP\TSS) Leah Tremper (OC/LFDCB, MS: TWFN 9E10)

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Entsrgy oporttions,Inc.

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To 501 B58-5000

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December 12,1996

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OCAN129602

U. S. Nuclear Regulatory Commission

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Document Control Desk !

Mail Station P1-137

Washington, DC 20555 M1'0

Subject: Arkansas Nuclear One - Units 1 and 2

Docket Nos. 50-313 and 50-368

License Nos. DPR-51 and NPF-6 .

Response To Inspection Report

50-313/% -06;50-368/96-06

Gentlemen:

Pursuant to the provisions of 10CFR2.201, attached is the response to the notice of violations

identified during the inspection activities associated with a Reactor Coolant System level

perturbation and a hydrogen burn during welding activities.

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Should you have any questions or comments, please call me at 501-858-4601.

Very truly yours,

W4

Dwight C. Mims

Director, Licensing

DCM/ajs

Attachments

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- U. S. NRC

' December 12,1996

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cc: Mr. Leonard J. Callan

Regional Administrator

U. S. Nuclear Regulatory Commission

RegionIV

611 Ryan Plaza Drive, Suite 400

Arlington, TX 76011-8064

NRC Senior Resident Inspector

Arkansas Nuclear One

1448 S. R. 333

Russellville, AR72801

Mr. George Kalman

NRR Project Manager Region IV/ANO-1 & 2

U. S. Nuclear Regulatory Commission

NRR Mail Stop 13-H-3

One White Flint North

11555 Rockville Pike

Rockville, MD 20852

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Attachment to

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OCAN12960't

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! NOTICE OF VIOLATION

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! During an NRC inspection conducted on August 18 through September 28,1996, two

! violations of NRC requirements were identi6ed. In accordance with the "Gerwal

i Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the

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violations are listed below:

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A. Technical Specification 6.8.1.a states, in past, that written procedures be established,

l implemented, and maintained covering the applicable procedures reconunended in

! Appendix A of Regulatory Guide 1.33, November 1972.

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j Paragraph H.2.a.1 of Regulatory Guide 1.33, November 1972, states that speci6c

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procedures should be written for containment leak rate tests. Procedure 1305.018,

Revision 9, " Local Leak Rate Testing - C," is the procedure for testing containment

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penetrations. Step 10.2.5 of Procedure 1305.018 states to " vent and drain the system

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j inside the local leak rate test (LLRT) boundaries in accordance with radiological work

l permit requirements." Penetration 14 is the letdown line penetration through

L containment and the LLRT boundary is between the first outside valve CV-1221 and

! the two parallel inside valves CV-1214 and CV-1216.

Contrary to the above, Penetration 14 was not vented and drained within the LLRT

f boundaries, but wu vented and drained into the Reactor Coolant System, which

resulted in the introduction of air into the Reactor Coolant System during reduced ,

inventory and caused a level indication change.

This is a Severity Level IV violation (Supplement I) (Violation 50-313/9606-01).

B. Unit 1 Technical Specification 6.8.1.f states, in part, that written procedures shall be

established, implemented, and maintained covering fire ' protection program <

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implementation.

Appendix 9A.4 of the Unit 1 Safety Analysis Report describes that the ANO Fire

Protection Program is controlled and maintained by various plant procedures that

include, but are not limited to, maintenance procedures for control ofignition sources.

Step 5.1.1 of Procedure 1003.006, Revision 3, " Control of Ignition Sources," states

that it is the responsibility of the cognizant supervisor for maintenance activities to

determine the fire and explosion precautions necessary for the performance of safe

work.

Contrary to the above, on September 21,1996, the licensee did not determine the fire

and explosion precautions necessary for safe work in that welding was performed on

a pressurizer relief valve tailpipe without having sampled and purged the line of

hydrogen. As a result, a hydrogen burn occurred.

This is a Severity Level IV violation (Supplement I) (Violation 50-313/9606-02).

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Response to Notice Of Violation 313/9606-01 !

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(1) Beason for the violation: i

Following a hot spot flush of the letdown coolers on September 18,19% Unit 1

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operations personnel were draining the letdown line in preparation for a local leak rate

test. During this evolution, Unit I was in reduced inventory with Reactor Coolant >

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System (RCS) level steady at 371.5 feet and about 80% complete with the draining of

the RCS cold legs. The core side of the RCS was no longer hydraulically coupled to l

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the cold legs and, therefore, no longer hydraulically coupled to the reactor building

drain header. The same drain was being used to remove water from the primary side

of the Once Through Steam Generator (OTSG) and to remove water used in

hot spot flush of the letdown coolers.

performing the previous

(See attached drawing 1)

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In order to ensure complete venting and draining of the letdown penetration,

pressurized service air was used as a motive force. During the evolution, control room

operators observed an unexpected RCS level increase of approximately 0.7 feet.

When the operations personnel draining the letdown line became aware of the RCS

level increase, they immediately secured service air and informed the control room.

The RCS level rise stopped when the service air was secured and quickly returned to

its previous value. The elapsed time from the start of the RCS level rise to RCS level

stable at its previous value of 371.5 feet was approximately ten minutes. ,

Air introduced into the cold leg from the letdown line collected in the air volume

between the top of the water level and the Reactor Coolant Pump (RCP) seal. Water

in the cold leg between the RCP and the reactor vessel acted as a seal between the

RCP and the head vents. This allowed for venting of the introduced air to occur only

from the RCP seal vent. The volume of air tlat this vent path could pass was

insufficient in comparison to the amount of air bdng introduced inte the system;

therefore, the buildup of air pressure below the RCP seal vent displaced a small

amount of water from the cold leg into the reactor vessel. This displaced water caused

the reactor vessel level indication to increase approximately 0.7 feet. (See attached

drawing 2)

The cause of this event was that an adequate assessment of the vent capabilities of the

RCS cold legs in association with the high volumes of service air being introduced into

the RCS via the letdown system was not performed. Additionally, the lack of a

procedure for draining systems connected to the RCS contributed to this event.

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0CAN129602

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(2) Corrective steos that have been taken and the results achieved:

Service air was secured immediately upon identification ofit as the cause of the RCS

levelincrease.

Unit 1 Operations Manager briefed operations personnel on the details and causes of

the event during shiA turnover meetings following the occurr'ence.

(3) Corrective steos that will be taken to avoid further violations:

The Unit 1 and Unit 2 Operations Managers will discuss this event with Operations

Department personnel prior to the next refueling outages which are currently

scheduled for the Spring of 1998 for Unit 1 and the Spring of 1997 for Unit 2.

Ensuring proper and adequate venting prior to manipulating RCS level and utilizing

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caution when performing an evolution on an RCS interconnected system during

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draindown conditions will be stressed.

A procedure for draining systems that are or may be interconnected to the RCS will be

developed by February 28,1998.

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(4) Date when full comoliance will be achieved: ,

Full compliance was achieved on September 18,1996 when the introduction of service

air was secured and the RCS level returned to its previous value.

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Response to Notice Of Violation 313/9606-02

i (1) R**=an for the violation:

On September 21,1996 while welding a cap on a recently cut one-inch pipe, a loud

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noise was heard by personnel working in the Unit 1 Reactor Building. The noise is

believed to have been caused by a small hydrogen burn in the Pressurizer Code Safety

Valve ten-inch discharge line to the Quench Tank. The one-inch line is connected to

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the top center of a horizontal run of the ten-inch discharge piping making it a potential

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high point location. It is believed that a small amount of hydrogen, came out of

solution from the primary coolant in the Quench Tank, and migrated to the or.e-inch

capped line.

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The presence of hydrogen gas was considered during the pre-job brief. However, the

decision was made not to sample for combustible gasses prior to welding because it

was determined that hydrogen gas should not collect since the RCS had been

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previously degassed, purged, vented, and was open to the atmosphere. It was also

] believed that sampling for combustibles after cutting the pipe was unnecessary since

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1 hydrogen, if present, would be vented when the pipe was cut.

While completing the Ignition Source Permit, the personnel involved with this job

' failed to identify that the work being performed involved welding on enclosed

j equipment. Examples of enclosed equipment, as identified by the Ignition Source

Permit, included tanks, containers, ducts, dust collectors, etc. Because piping was not

included in the list of examples it was not considered enclosed equipment. Moreover,

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this section of the form was viewed as being applicable only when work was i

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performed from within enclosed equipment.

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The cause of this event was welding operations unknowingly conducted in the

presence of a combustible hydrogen level. Knowledge of the hydrogen level present in

the tank and the line prior to the start of welding is necessary to determine the exact

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' origin of the hydrogen. It is believed that hydrogen came out of solution in the

primary coolant present in the Quench Tank and concentrated at the newly capped

vent. A combustible gas sample was not obtained from the Quench Tank prior to

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performing the welding. However, had the personnel involved with this job

recognized that hydrogen may continue to be expelled following depressurization and

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degassification of the RCS, the need for purging of the Quench Tank and associated

i piping would have been more apparent.

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i (2) Corrective steos that have been taken and the results achieved:

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Work was stopped in the area and a walkdown was conducted to verify conditions

1 were safe.

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The Quench Tank and associated piping were purged with nitrogen and combustible

gas samples were obtained Sunples obtained during the purge indicated hydrogen

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levels as high as 3.6%. Upon completion of purging the hydrogen level was

insignificant.

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The incident was discussed with supervisory personnel at shift outage meetings. ,

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Supervisors of personnel responsible for welding were directed to more closely

scrutinize welding packages for proper identification of work conditions.

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Work groups involved in the planning, conduct, approval, supervision, or monitoring i

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of activities involving spark / heat generating evolutions were alerted to the hazards

and potential generation of hydrogen in systems associated with the Reactor Coolant

System.

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Walkdowns of the Quench Tank and affected piping were performed. The rupture

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disk on the tank was examined and found intact. It was concluded by the evidence of

this event that the design limits for the Quench Tank were :mt exceeded and that the

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tank's ability to perform its intended function was unaffected by this event.

A walkdown of the pressurizer code safety valve discharge piping, supports, guides,

and snubbers was also performed. The results of this evaluation indicated no damage

resulted from this event.

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(3) Corrective steos that will be taken to avoid further violatigg

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A warning statement will be added to the Ignition Source Permit (Form 1003.006A) to

identify that any spark / heat generating work on any system associated with the RCS or

any system where potential for combustible gasses is present requires special attention.

Additionally, piping will be identified as an example of enclosed equipment. This

procedure revision will be completed by January 15,1997.

The cause and lessons teamed from this event will be reviewed in pre-outage briefings

prior to the start of the next refueling outages for both Unit I and Unit 2 which are l

currently scheduled for the Spr!ng cf 1998 and 1997, respectively.

The cause and lessons learned fron, this event will be incorporated into contract

welder training presented prior to each refueling outage by April 1,1997. 1

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The cause and lessons learned from this event will be reviewed with maintenance

personnel qualified to perform welding at ANO by April 1,1997.

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(4) Date when full comoliance will be achieved:

Full compliance was achieved on September 22,1996 when the Quench Tank and

associated piping were purged, vented, and sampled.

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i Drawing 1- Drain down in progress; water level stable in

reactor core; cold leg level going down; cold

j leg drain water and letdown system flush

water going to reactor building drain header.

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Drawing 2 Drain down in progress; air assisted draining

ofletdown system in progress; air goes into

cold leg RCP area; RCP seal vent can not

vent all the air, and pressure builds up in

this area; water level rises in reactor core to

372.2'.

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ML20133J206

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