ML20245K782
| ML20245K782 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 04/25/1989 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Campbell G ARKANSAS POWER & LIGHT CO. |
| References | |
| NUDOCS 8905050171 | |
| Download: ML20245K782 (2) | |
See also: IR 05000313/1989002
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In Reply Refer To:
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Dockets: 50-313/89-02
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50-368/89-02
Arkansas Power & Light Company
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ATTN: Mr. Gene Campbell
Vice President, Nuclear
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Operations
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P.O. Box 551
Little Rock, Arkansas 72203
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Gentlemen:
Thank you for your letter of April 7,1989, in response to our letter and
' Notice of Violation dated March 9,1989. We have reviewed your reply to
Violation 313/8902-01; 368/8902-01 and find it responsive to the concerns
raised in our Notice of Violation. We also find that your response to that
portion of Violation 313/8902-02; 368/8902-02 that discusses the late submittal
of licensee event reports and the nonreporting of control room emergency
vent 11ation' system actuations to be responsive to our concerns. We will review
the implementation of your corrective actions during a future inspection to
determine that full compliance has been achieved and will be maintained.
With regard to the nonreporting of emergency diesel generator failures that was
also the subject of Violation 313/8902-02; 368/8902-02, we understand that you
will be submitting your response to this portion of the violation by May 5,
1989..
Sincerely,
Original Signed By,
A ght O. C hnmberkk
L. J. Callan, Director
Division of Reactor Projects
cc:
Arkansas Nuclear One
ATTN:
J. M. Levine, Executive
Director, Nuclear Operations
P.O. Box 608
Russellville, Arkansas 72801
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Arkansas Radiation Control Program Director
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ARKANSAS POWER & LIGHT COMPANP----
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April 7, 1989
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BCAN048901
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L. J. Callan, Director
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Division of Reactor Projects
U. S. Nuclear Regulatory Commission
Region IV
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611 Ryan Plaza Drive, Suite 1000
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Arlington, Texas 76011
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SUBJECT:
Arkansas Nuclear One - Units 1 and 2
Docket Nas. 50-313/50-368 -
Licenso ..os.
Response to Inspection Report
50-313/89-02 and 50-368/89-02
Dear Mr. Callan:
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Pursuant to the provisions of 10CFR2.201, a response to violation
313-368/8902-01 and partial response to violation 313-368/8902-02,
identified in the subject inspection report (OCNA038909), are submitted.
Per conversation between Mr. Dwight Chamberlain of your staff and
Mr. Don Lomax of my staff on April 5, 1989, a response to that
portion of violation 313-368/8902-02 concerning Unit 2 Emergency
Diesel Generator (EDG) 2K4B failure reporting requirements is not
being provided at this time.
This portion of the violation response
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was agreed to be submitted following a future meeting of our staff
to discuss reporting of EDG failures specifically and other reporting
requirements in general.
Very trul yours,
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M. Levine
xecutive Director,
luclear Operations
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enclosure
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U. S. Nuclear Regulatory Commission
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Wnshington, D.C.
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Enclosure to BCAN048901
April 7, 1989
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Page 1 of 5
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A.
10CFR Part 2.201 states, in part, "The notice of violation will
concisely state the alleged violation and will require that the
licensee or any other person submit, within twenty'(20) days of
the date of the notice of other specified time, a written
explanation or statement in reply including:
"
....
Recent notices of violation issued to Arkansas Power & Light
Company have required a written statement or explanation within
30 days of the date of the letter transmitting the notice.
Contrary to the above, during January 1-31, 1989, the NRC
inspector identified three examples of failure to provide a
response to a notice of violation within the required time.
These examples involve the late responses to the notices of
violation in NRC Inspection Reports 50-313/88-25, 50-368/88-25;
50-313/88-26, 50-368/88-26; and 50-313/88'29, 50-368/88-29.
This is a Severity Level IV violation.
(Supplement I)
(313;368/8902-01)
Response to Violation 313-368/8902-01
In responding to this violation, a response to that portion of
violation 313-368/8902-02, which addressed late submittal of
Licensee Event Reports (LERs), is also provided due to the
commonality of cause', and corrective actions.
The specific
portion of violatior, 313-368/8902-02 to be discussed in this
response 1s:
10CFR Part 50.73(a) states, in part, " ... nuclear power
plant (licensee) shall submit a Licensee Event Report (LER)
for any event of the type described in this paragraph
within 30 days after discovery of the event .... "
1. The NRC Inspector identified ten Unit 1 and six Unit 2
LERs issued in 1988 that failed to comply with the 30
day reporting requirement.
(1) The reason for the violation, if admitted:
AP&L does admit the violations as stated above. The reasons the
inspection report responses, i.e., NOV responses, and LERs were
not submitted within 30 days of the date of the NOV transmittal
letter and 30 days of the date of discovery of a reportable event,
respectively, are primarily due to the following:
- staff workload at the time the submittals were required,
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- failure to adequately track the status of the submittals, and
- failure to provide timely notification to the NRC of pending
late submittals,
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Enclosure to SCAN 048901
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April 7, 1989-
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It was noted in the inspection report that each of.the late
violation responies were for reports issued in the last 4
months of 1988.
During this same time period (as discussed
in a management meeting between AP&L and NRC on April 3, 1989,
in Region IV offices) Arkansas Nuclear One experie'nced a
significant increase in the number of events requiring LERS.
Due to staff workloads associated with a Unit I refueling out-
age and subsequent forced outages on both Unit 1 and Unit 2
during these 4 months, station personnel were not able to meet
necessary time tables in providing input for preparation of
the NOV responses and LERs.
Additionally, during this same time period, an effort was also
underway to submit overdue updates to previously issued LERs
[ reference NRC Inspection Report 87-39 (OCNA038803), deviation
313-368/8739-01].
These additional reports further impacted
station personnels' ability to meet necessary time tables for
preparation of the NOV responses and LER submittals.
Compounding.
the above problems was a temporary shortage of personnel in the
group which is responsible for the coordination of preparation
and submittal of NOV responses and LERs.
Also, the status of the NOV response and LER submittals was not
effectively tracked. Manual tracking methods for these submittals
were not adequate to deal with the significant volume increase
in LERs, as previously discussed, such that the problem of the
growing number of pending submittals was n'ot quickly recognized
as being significant.
Finally, following identification of these problems, personnel
did not recognize the significance of not discussing these issues
with NRC and requesting appropriate due date extensions.
(2) The corrective steps which have been taken and the results
achieved:
The following actions have been taken to address the LERs which
are overdue for submittal.
Currently, no NOV responses are over-
due.
- NRC Region IV was informed in December 1988 (0CAN128802) and
updated in March 1989 (0CAN038912) with a status and schedule
for submittal of overdue LERs.
- Within the group responsible for the coordination of preparation
and submittal of NOV responses and LERs, additional contractor
staff was retained and full permanent staffing of the group will
be completed in April 1989. These efforts should facilitate
the submittal of currently overdue LERs and improve on the
timeliness of submittal of future NOV responses and LERs.
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Enclosure to 0CAN048901
April 7, 1989
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- A mechanism has been implemented to keep management informed
on the status of reportable events and violation responses.
This will assist in ensuring NRC notification of impending
late NOV responses or LERs requiring appropriate. requests
for extension of submittal dates.
(3'
The corrective steps which will be taken to avoid further
violations:
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The following guidance has been provided to the group responsible
for the coordination of preparation and submittal of NOV response
and LER submittals.
- If circumstances preclude timeliness of responses to NOVs, NRC
will be informed and appropriate extensions of submittal dates
will be requested.
- Unless an extension has been requested f' rom NRC, best available
information will be provided for initial LER submittal within
the 30 day reporting requirement and an LER update will be
provided when final information is available.
Additionally, from a station viewpoint, we will be looking at the
processes for preparation, review, and support to ensure timely
responses to NOVs and timely reporting of events.
(4) The date when full compliance will be achieved:
Regarding NOV responses, compliance was achieved by January 27, 1989.
The response to Inspection Report 313-368/88-25 was submitted on
December 30, 1988 (0CAN128813).
The response to Inspection Report
10, 1989 (0CAN018905). The
was submitted on January /88-29 was submitted on
313-368/88-26
response to Inspection Report 313-368
January 27, 1989 (0CANB18906).
Regarding LERs, a schedule for submittal of overdue reports was
provided to NRC Region IV on March 20, 1989 (0CAN038912), which
provided for submittal of the currently remaining overdue LERs by
May 11, 1989.
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Enclosure to BCAN048901
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April 7, 1989
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10CFR Part 50.73(a) states, in part, "... nuclear power plant
(licensee) shall submit a Licensee Event Report (LER) for any
event of the type described in this paragraph within 30 days
after the discovery of the event....)"
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10CFR Part 50.73(a)(2) states,.in part, "The licensee shall
report: ... (iv) Any event or condition that results in manual
or automatic actuation of any Engineered Safety Feature (ESF)
10CFR Part 50.72(b)(2) states, in part, "... the licensee shall
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notify the NRC as soon as practical and in all cases, within 4
hours of the occurrence of any of the following: ...(ii) Any
event or condition that results in manual or automatic
actuation of any Engineered Safety Feature (ESF)."
Unit 2 Technical Specification 4.8.1.1.3 states, in part, "All
diesel generator failures, valid or non-valid, shall be reported
to the commission pursuant to Specification 6.9.1."
Contrary to the above, during January 1-31, 1989, the NRC
inspector identified three examples of failure to comply with
the above referenced reporting requirements.
These examples
are as follows:
1.
The NRC inspector identified ten Unit 1 and six Unit
2 LERs issued in 1988 that faile'd to comply with the
30 day reporting requirement.
2.
The NRC inspector identified six automatic actuations
of the control room emergency ventilation system
(an ESF system) in 1988.
These events were not
reported to the NRC via 4-hour reports or LERs.
3.
The NRC inspector identified three failures of Unit 2
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Emergency Diesel Generator 2K4B in 1988.
These
events were not reported to the NRC.
This is a Severity Level IV violation.
(Supplement I) (313;368/8902-02)
Response to Violation 313-368/8902-02
The response to Item 1 of this violation was provided in the response
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to violation 313-368/8902-01 above.
A response to Item 2 of this violation
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is provided below.
Per conversation between Mr. Dwight Chamberlain of
NRC Region IV and Mr. Don Lomax of AP&L on April 5, 1989, a response to
Item 3 of this violation is not being provided at this time.
It was
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agreed that this portion of the violation response will be submitted
following a future meeting between NRC Region IV and AP&L to specifically
discuss Item 3 and other reporting requirements in general.
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Enclosure to SCAN 048901
' April 7,.1989
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(1) The reason for the violation, if admitted:
AP&L does admit Item 2 of the violation as stated above. The
reason for the failure to report actuations of the. control room-
emergency ventilation system (CREVS) is that AP&L had interpreted
the regulations incorrectly for ESF systems that do not actuate
on an ESF signal.
The CREVS does not receive an ESF actuation signal.
It actuates
on detection of chlorine gas or radiation as monitored by system
detectors.
AP&L had interpreted the reportin
10CFR50.72(b)(2)(ii) and 10CFR50.73(a)(2)(iv)g requirements of
as referring only to
system actuations from an ESF signal, automatic or manual. The
CREVS is identified as an ESF system by the ANO-2 Safety Analysis
Report based on the design function of the system for post-accident
conditions.
By correctly interpreting the 10CFR50.72 and 10CFR50.73
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sections as referring to actuations of ESF systems, whether actuated
by an ESF signal or not, the actuations of the CREVS should have
been reported.
(2) The corrective steps which have been taken and the results achieved:
To address the reporting of actuations of the CREVS, Operations has
been directed to initiate a report documenting an actuation, i.e., a
Condition Report, and to accomplish the reporting of actuations of
the ESF systems defined by the Safety Analysis Reports in accordance
with the requirements of 10CFR50.72.
Issuance of a Condition Report
documenting actuations and identifying deportability per 10CFR50.72
requirements will ensure reporting with the identical requirements of
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10CFR50.73 in accordance with station procedures.
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(3) The corrective steps which will be taken to avoid further violations:
The corrective actions described above will ensure correct reporting
in the future.
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(4) The date when full compliance will be achieved:
Full compliance with the reporting requirements was achieved
February 17, 1989, with the issuance of guidance directing CREVS
actuations be identified and reported as reportable events.
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