ML20137A214
| ML20137A214 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/01/1985 |
| From: | Enos J ARKANSAS POWER & LIGHT CO. |
| To: | Denise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20137A196 | List: |
| References | |
| NUDOCS 8601140242 | |
| Download: ML20137A214 (4) | |
Text
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ARKANSAS POWER & LIGHT COMPANY POST OFFICE BOX 551 UTTLE ROCK, ARKANSAS 72203 (501) 371-4000 November 1, 1985 Yh OCAN118506 NOV l 8 985 j l; Mr. Richard P. Denise, Director M
n Division of Reactor Safety and Projects E
~3 U. S. Nuclear Regulatory Commission 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 License Nos. DPR-51 and NPF-6 Inspection Reports 50-313/85-22 and 50-368/85-23 Gentlemen:
The subject inspection reports have been reviewed.
Responses to the Notices of Violation are attached.
Very truly yours,
$lp IM!**>
J. Ted E s Manager, Licensing JTE/MCS/sg Attachment cc:
Mr. Richard C. DeYoung Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Norman M. Haller, Director Office of Management & Program Analysis U. S. Nuclear Regulatory Commission Washington, DC 20555 8601140242 860110 ADOCK050g3 PDR
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Unit 1 Technical Specification 4.20.1.b requires that the fire protection water system shall be demonstrated operable by verifying each valve in 'the flow path that is not sealed, is in its correct
-position at least once per 31 days.
~ Auxiliary System Operating Procedure 1104.32, " Fire Protection Systems Operation," has been established to implement this Technical Specification requirement.
Supplements IIIa and IIIc to Procedure 1104.32 provide a list of valves whose position is to be checked each month to verify system operability.
Contrary to the above, valves FS-121 and FS-122, isolation valves in the fire water supply to the Unit 1 emergency diesel generator fuel oil tank vault, were not sealed nor were the valves listed on Supplements IIIa or IIIc.
Consequently, the valves were not verified to be in their correct position each 31 days as required by Technical Specifications.
This is a Severity Level IV violation (Supplement I.D) (313/8522-01).
! Response As cited in'the inspection report and subsequent notice of violation, the NRC inspectors noted that valves FS-121 and FS-122, isolation valves in the fire water supply to the Unit 1 emergency diesel generator fuel oil tank vaults, were not sealed nor were the valves verified to be in their correct position each 31 days as required by Technical Specifications.
The Unit 1 Technical Specification 4.20.1.b requires;
'The fire protection water system shall be demonstrated operable...at least once per 31 days by verifying that each valve (manual, power operated or automatic which is not locked, sealed or otherwise secured in its correct position) in the flow path is in its correct position;"
AP&L does recognize that.a monthly inspection of fire suppression valves should be performed and documented and, therefore, has added these valves to the monthly alignment verification. We do not concur that the Technical Specification was violated. When the inspectors identified that AP&L had failed to include these valves in the monthly' verification, the determination that these valves were "otherwise secured" through valve position electrical supervision (tamper switches) with remote alarm and annunciation in the control room was
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not communicated to the Inspectors.
Because the position is monitored continuously through the use of tamper switches, the requirement of the Technical Specification has been met.
Regulatory guidance is provided that further supports this determination.
Appendix A to Branch Technical Position APCSB 9.5-1, " Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior to July 1, 1976," states the following:
All valves in the fire water systems should be electrically supervised.
The electrical supervisor signal should indicate in the control room and other appropriate command locations (See NFPA 26, " Supervision of Valves"). When electrical supervision of fire protection valves is not practicable, an adequate management supervision program should be provided.
Such a program should include locking valves open with strict key control; tamper proof seals; and periodic, visual check of all valves.
NFPA-26 states in Chapter 1-1.2 that "one, or a combination of, the following methods of valve supervision is considered essential to ensure that the valves in a fire protection system are open." The methods referred to are delineated in Chapter 6, Methods of Supervision.
These are as follows:
central station supervisory alarm service; local alarm service which will cause the sounding cf an audible alarm signal at a constantly attended point; locking valves open; sealing of valves; and notification systems.
NFPA-13A, Inspection, Testing, and Maintenance of Sprinkler Systems, paragraph 2-7.1.3, states that "each control valve in the sprinkler-system should be secured in its normal or open position by means of a seal lock or tamper switch."
We conclude that the valves were "otherwise secured" as required by the Technical Specifications and in a manner consistent with the guidance of BTP 9.5-1 and NFPA-26 and 13A.
Therefore, AP&L does not agree that a violation of technical specification 4.20.1.b has occurred.
B.
Unit 2 Technical Specification 3.7.11 states, "All penetration fire barriers protecting safety-related areas shall be functional."
?
Contrary to the above, the NRC inspectors found fire doors 186 and 210 not fully shut on August 14, 1985, and August 16, 1985, respectively.
This is a Severity Level IV violation (Supplement I.D) (368/8523-01).
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Response
The cause for the fire door 186 failing to close automatically was that the closure mechanism was broken.
The closure mechanism on fire door 186 was repaired and adjusted and positive closure verified.
This was completed September 3, 1985.
The cause of fire door 210 failing to close automatically was an air flow imbalance that occurs when ventilation system changes occur. The existing door closure on fire door 210 was replaced with a stronger closure and adjusted for maximum closing force.
This was completed October 29, 1985.
AP&L is reviewing the problem of maintaining fire doors closed.
Several options have been considered.
The first option to be implemented on a trial basis will be the use of local audible alarms.
Based upon the results of this modification other options may be
- pursued, i