ML20206S175
| ML20206S175 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 08/29/1986 |
| From: | Enos J ARKANSAS POWER & LIGHT CO. |
| To: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20206S159 | List: |
| References | |
| 0CAN088613, CAN88613, NUDOCS 8609220100 | |
| Download: ML20206S175 (5) | |
Text
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ARKANSAS POWER & LIGHT COMPANY POST OFRCE BOX 551 UTTLE ROCK. ARKANSAS 72203 (501) 3714000 August 29, 1986
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z Mr. J. E. Gagliardo, Chief Reactor Projects Branch 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 Response to Inspection Report 50-313/86-15 and 50-368/86-15
Dear Mr. Gagliardo:
The subject report has been reviewed.
A response to the Notice of Violation is attached.
Very truly yours, f
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J. Te. Enos, Manager Nu 1 ar Engineering and Licensing JTE: RJS:lw Attachment 8609220100 e60916 PDR ADOCK 05000313 G
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-4 During an NRC inspection conducted during the period May 1-31, 1986, violations of the NRC requirements were identified.
The violations involved failure to lock a manual valve in position as required, failure to have adequate controls over the installation of temporary scaffolds in the vicinity of safety-related equipment, and lack of calibration data that would demonstrate the accuracy of measurement of the admixture liquid dispenser being utilized at the concrete supplier's facility.
The specific finding and AP&L's response to each are listed below.
A.
Unit 2 Technical Specification (TS) 6.8.1 requires, in part, that written procedures shall be established, implemented, and maintained i
covering... a.
The applicable procedures recommended in Section 3 of Appendix A of Regulatory Guide 1.33 that instructions for PWR systems such as the Containment Spray System should be prepared and followed.
Operating Procedure 2104.05, " Containment Spray System," Attach' ment A, provided a valve lineup for the containment spray system and specified that the two manual valves in the sodium hydroxide tank 3-inch drain line be locked closed.
Contrary to the above, on May 23, 1986, the NRC inspectors found that one of the two valves, 2BS-1016, was not locked in position.
Both valves were closed, and 2BS-1015 was locked closed, as required.
l This is a Severity Level IV violation.
(Supplement I.E.) (368/8615-07)
Response
Operations made an attempt to determine when and why the lock and chain were removed from 285-1016. The previous valve lineup performed following the last refueling outage on May 5, 1985, indicates that the valve was locked-closed as required.
Operational evolutions were reviewed to determine if the valves would have been used for draining the sodium hydroxide tank.
Partial draining was accomplished, but a smaller, more easily accessed drain line was used.
There was no condition identified that' would have required opening this valve.
However, inadvertent opening would not have resulted in draining the sodium hydroxide tank as the series valve, 2BS-1015, was locked in the closed position.
Intentional draining of the tank by personnel other than operators would be brought to operators attention by the tank low-level alarm or the tank level indication on the front panel in the control room which is routinely monitored.
AP&L has categorized locked-in position manual valves which could be mispositioned or misoperated, preventing fulfillment of safety system functions', as Category E valves per Article IWV-2110 of ASME Boiler and Pressure Vessel Code 1974 Edition and Addenda through Summer 1975.
The valve positions are verified in accordance with IWV-3700, Inservice Test, Category E Valves, as required by ANO-2 Technical Specification 4.0.5.
However, not all manual valves that AP&L administrative 1y controls by locking are classified as Category E valves.
For these valves, no procedural controls existed which verified the locked status on a routine
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basis.
Valve 2BS-1016 fell into this category and, therefore, was not g
periodically verified to be locked-in position.
As a result of the inspector finding the valve out of the position required by the valve lineup in Procedure 2104.05, Operations has developed, for incorporation into the Operations Department procedures writers' guide, new criteria and controls for manual valve positioning.
The new criteria will ensure control is provided commensurate with the valve's safety function.
These controls will include the use of padlocks, lockwire, caps, blank flanges, special tags and the removal of handwheels as appropriate. As part of the plant labeling program development, valves will be assessed on an individual basis as to the type of position controls to be applied.
Based on our evaluation of the sodium hydroxide drain line, valves 2BS-1016 and 2B5-1015 were determined to be of the type to be controlled by the installation of a blank flange.
Action has been initiated to install this blank flange on the line.
The procedure valve lineup was revised to change the required position from " locked-closed" to " closed".
As the valve was already in the closed position, compliance was achieved with the procedure revision effective July 25, 1986.
B.
Criterion II of Appendix B to 10 CFR Part 50 and Section 2.4 of the approved Arkansas Power and Light Quality Assurance Manual - Operations (AP&L QAM), requires that activities affecting quality shall be accomplished under suitably controlled conditions.
Criterion V of Appendix B to 10 CFR Part 50 and Section 5 of the AP&L QAM requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings.
Contrary to the above, the controls for erection of scaffolding was less than adequate in that, on May 23, 1986, the NRC inspector found that temporary scaffolds had been installed in the Unit 2 auxiliary building in the vicinity of the 'A' containment spray pump with one end of the scaffolds being supported by Seismic Category I piping. Also, on May 28, 1986, the NRC inspector found that scaffold supports were wired to four Seismic Category I pipes in the same area.
This is a Severity Level IV violation.
(Supplement I.D) (368/8615-08)
Response
The scaffolding had been installed, as noted by the inspector, without adequate control for the plant mode of operation.
Normally, scaffolding would be used extensively during a refueling mode of operation and would have little or no impact potential on safety related, seismically qualified systems or equipment.
However, at the time of this observation, AP&L was in the process of performing activities in preparation for the refueling outage which began the second week of June, 1986.
The scaffolding may have been installed in preparation of work planned for this area without considering that the plant was not yet in the refueling mode of operation.
When the inspector expressed his concern about the scaffolding installed on seismic piping, the Shift Supervisors were provided guidance by the Operations Manager on releasing job orders for scaffolding erection until proper controls could be established.
. s f-g A form, Scaffolding Erection and Approvals, was developed which provides criteria for consideration prior to scaffolding erection.
It is to be reviewed and signed by the Craft Supervisor, and Engineering Supervisor and Safety / Fire Specialist, if applicable.
This form is included as part of the j
job order requiring scaffolding.
It will be a part of the Control of l
Maintenance procedure.
Additionally, the OSHA tags have been modified to include a date and a carpenter's or craft foreman's signature.
This will make it possible to determine when scaffolding is erected and the person responsible for the installation.
These controls, which are currently being incorporated into the ANO procedures, should ensure proper precautions are taken to avoid adversely affecting the operability of safety-related equipment when scaffolding is utilized.
The procedure revisions will be accomplished by September 15, 1986. The effectiveness of these controls will be evaluated over the next several months.
Adjustment in the program will be made as necessary.
C.
Criterion XII of Appendix B to 10 CFR Part 50, states that " measures shall be established to assure that tools, gages, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specific periods to maintain accuracy within necessary limits."
Section 12 of the Arkansas Power & Light Quality Assurance Manual -
Operations states, in part, " Measuring and test equipment is to be properly controlled, calibrated and adjusted at specific intervals or pr r to use to assure the necessary accuracy of calibrated equipment National Ready Mixed Concrete Association (NRMCA), Certification of Ready Mixed Concrete Production Facilities, checklist item number 2.4.3 states; "Each volumetric dispenser provided with accurately calibrated container in which the admixtures may be collected when it is desired to check the accuracy of measurement as indicated in 2.5.4" AP&L Specification, APL-C-2401, dated November 15, 1985, Section 9.4.3.b. states, that the Batch Plant inspector shall perform at random, a general and visual inspection of Concrete Supplier's facility for handling and storage of materials, batching equipment and truck mixers (ex., calibration of scales, scales and dispensers synchronization, truck mixer blade wear, etc.) using the NRMCA checklist as a guide.
Contrary to the above, the licensee could not provide documented evidence that the volumetric admixture dispenser, utilized at the concrete supplier's facility, was calibrated as prescribed by NRMCA, paragraphs 2.4.3 and 2.5.4, nor evidence of inspection requirements performed as stipulated in AP&L specification APL-C-2401, Section 9.4.3(b).
This is a Severity Level V violation.
(Supplement I.E) (313/8615-01; 368/8615-01)
I
t
Response
g In AP&L's contract with the concrete supplier, NRMCA certification was a requirement.
A copy of this certification dated November 26, 1985 was provided to AP&L.
Specification APL-C-2401, Section 9.2.1, provides requirements for inspection of the concrete batch plant facilities and equipment.
It states that inspection shall not be necessary if the concrete supplier holds a current NRMCA Certification.
Therefore, the inspections described in APL-C-2401, Section 9.4.3(b) did not constitute requirements.
AP&L, as allowed by the specification, relied cn the NRMCA certification of the concrete supplier.
The NRMCA certification checklist indicated that the requirements of Paragraphs 2.4.3 and 2.5.4 were met. This checklist was completed by a registered professional engineer as specified by the certification.
However, when the admixture dispenser calibration could not be documented, an inspection and calibration program was conducted.
The admixture dispensers were found to be within the required tolerance of the NRMCA checklist when checked by AP&L and calibrated by a consulting engineering firm.
This provided for compliance with the NRMCA certification requirements.
The concrete supplier, although unable to provide documentation of calibration, indicated that the dispensers were regularly checked and maintained by a trained factory technician during the period from November, 1985 to May, 1986.
AP&L conducted field tests on the quality of the concrete prior to use.
These measures demonstrated that the concrete utilized in production met specifications and was acceptable.
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