ML20206M617
| ML20206M617 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/17/1988 |
| From: | Tison Campbell ARKANSAS POWER & LIGHT CO. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-53FR36795, RULE-PR-26 53FR36795-00327, 53FR36795-327, NUDOCS 8812010155 | |
| Download: ML20206M617 (8) | |
Text
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tc.' 22 P 3 :23 P. O. BOX 551/LITTLE ROCK, ARKANSAS 72203/(501) 377 3525 T. GENE CAMFBELL November 17, 1988 T[r; Vice President. Nuclear Mr. Samuel J. Chilk Secretary U.S. Nuclear Regulatory Comnission Washington, DC 20555 Attention:
Docketing and Service Branch
Subject:
Proposed Rule - Fitness For Duty Program 53FR36795 (September 22, 1988)
Request for Comments
Dear Mr. Chilk:
Arkansas Power & Light Company (AP&L) is pleased to respond to the Nuclear Regulatory Commission's proposed rulemaking on Fitness-For-Dut f Programs.
AP&L has reviewed the proposed rule and generally supports the adoption of a regulation on fitness-for-duty.
However, the proposed rule has the potential to reduce the effectiveness of our current program.
For this reason, we have been involved in the review conducted by the Nuclear Management and Resources Council (NUMARC) and fully endorse the cortcent s on the proposed rule filed by NL' MARC on November 18, 1988.
Based on our experience, an effective Fitness-For-Duty Program must include alcohol testing provisions for random testing and must establish cutoff levels significantly lower than those established by the Department of Health and Human Servicts (DMHS).
Further, an effective program must include a rapid review of results.
All porttive results must result in the loss of unescorted access until an appropriate review of the circumstances has been conducted.
AP&L believes that a rule which incorporates the suggested NUMARC changes will rectify the inconsistencies and shortcomings in the existing industry programs ano will establish uniform standards to promote the public health and safety.
A properly written NRC regulation would preempt any state or local requirements or restrictions that could impede the continued implementation of our Fitness-For Duty Program.
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Mr. Samuel J. Chilk 2
iovember 17, 1988 Arkansas Power & Light Company appreciates the opportunity to coment on the proposed rulemaking on Fitness-For-Duty Programs.
Sincerely, d
.nb T. Gene Campbell TCC:jlt Document Control Desk U.S. Nuclear Regulatory Comission Washington, DC 20555 f
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ARKANSAS NUCLEAR ONE - UNIT 1 N0ZZLE LOAD ISSUE DE.INE OF PRESENTATION PURPOSE OF MEETING T3 R0 VIDE STATUS OF OPERABILITY EVALUATIONS ON ANO-1 ::.ZLES AND BASIS OF THE EVALUATIONS 0VERVIEl!
ACCEPTANCE CRITERIA EQUIPMENT CATEGORIES STATU.~. OF UNIT 1 N0ZZLE EVALUATIONS CONCLUSIONS
OVERVILW LISTING OF N0ZZLES BASED ON REVIEW 0F SAFETY RELATED EQUIPMEflT DATA BASES TOTAL N0ZZLES LISTED 236 84 ARE SMALL BORE AND 5 ARE NON-0 DEVELOPED ACCEPTANCE CRITERIA FOR THE PURPOSE OF DETERMINING OPERABILITY OF ALL N0ZZLES GEllERATED INDIVIDUAL CALCULATIONS TO DOCUMENT THE EVALUATIONS OF EACH N0ZZLE, CALCULATIONS REVIEEED IN ACCORDANCE WITH OUR DESIGN PROGRAM.
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ACCEPTANCE CRITERIA MEETS VEND 0R ALLOWABLES A COMPARIS0N OF PIPING INDUCED LOADS FROM PIPING STRESS ANALYSIS AGAINST DOCUMENTED VENDOR ALLOWABLES MEETS EMPERICALLY DEVELOPED CRITERIA (DESIGN GUIDLINES)
COMPARISON OF PIPING INDUCED LOADS FROM PIPING STRESS ANALYSIS AGAINST DESIGN GUIDELINE VALUES GUIDELINES DEVELOPED BY BECHTE'. POWER CORPORATION TO DETERMINE ACCEPTABILITY OF PIPING LOADS ON N0ZZLES VALUES USED AS ALLOWABLES ARE SH0FN TO BE CONSERVATIVE BASED ON B0UNDING ANALYSIS AP8L CALCULATIONS THAT VERIFY ACCEPTABILITY OF PIPING LOADS ON N0ZZLES NOTE --
SMALL BORE N0ZZLES WERE EXCLUDED FROM FURlHER EVALUATION AFTER VERIFICATION AS SMALL BORE BECAUSE OF THE CONSERVATIVE DESIGN PRACTICES UTILIZED IN ROUTING AND SUPPORTING SMALL B0PE PIPING
EQUIPMENT CATEGORIES OF ANO-1 N0ZZLES 69 PUMPS 42 HEAT EXCHANGERS 60 TANKS 35 HVAC 16 NSSS 14 MiSCELIANE00S 236 TOTAL L
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STATUS OF ANO-1 N0ZZLE EVALUATION 236 N0ZZLES IN SCOPE OF EVALUATION 0F TOTAL NUMBER, Elf ARE SMALL DORE 118 N0ZZLES DETERMINED OPERABLE BY VENDOR ALLOWABLES 111 N0ZZLES DETERMINED OPERABLE BY DESIGN GUIDELINES 15 N0ZZLES DETERMINED OPERABLE BY AP8L CALCULATION / EVALUATION 5 ARE NON-0 i
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CONCLUSIONS CONCLUSIONS ARE THAT NO OPERABILITY CONCERNS EXIST 1
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