ML20246L943
| ML20246L943 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 07/11/1989 |
| From: | Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Campbell G ARKANSAS POWER & LIGHT CO. |
| References | |
| NUDOCS 8907190032 | |
| Download: ML20246L943 (1) | |
See also: IR 05000313/1989010
Text
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- Dockets:- 50-313/89-10-
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Ark'ansas Power & Light Company
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. ATTN:D Mr. Gene., Campbell
.Vice President, Nuclear-
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P.O. Box 551~
Little Rock,' Arkansas'.72203
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- Gentlemen:
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Thank you for your' letter of June 14,-1989, in response to our letter and:
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Ne!. ice of Violation dated May 15,.1989. We have reviewed your reply and find
it responsive to the concerns raised in our Nbtice of Violation. We will
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review the implementation of your corrective actions during a future inspection
to determine that full' compliance has been achieved and will be maintained.
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Sincerely,
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James L. Milhoan, Director
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Division of Reactor Projects
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! Arkansas Nuclear.0ne
ATTN:
N. S. Carns, Director
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Nuclear Operations
P.O. Box 608-
Russellv111e', Arkansas .72801
Arkansas Radiation Control Program Director
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ARKANSAS POWER & LIGHT COMPANY
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J. L. Milhoan, Director
Division of Reactor Projects
U. S. Nuclear Regulatory Commission
Region IV
611 Ryan Plaza Drive, Suite 1000
Arlington, Texas 76011
SUBJECT:
Arkansas Nuclear One - Units 1 and 2
Dccket Nos. 50-313/50-368
License Nos. DPR-5l. and NPF-6
Response to Inspec fon Report
50-313/89-10 and 50-368/89-10
Dear Mr. Milhoan:
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Pursuant to the provisions of 10CFR2.201, a response to the violations
identified in the subject inspection report is submitted.
Very truly yours,
E. C. Ewing
General Manager
Plant Support
CEC:PLM:djm
attachment
cc w/att: U. S. Nuclear Regulatory Commission
Document Control Desk
Mail Station P1-137
Washington, C.C.
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Unit 1, TS 6.8.1 requires that written procedures be established,
implemented, and maintained covering the. activities recommended
in Appendix A of Regulatory Guide 1;33, November 1972.
Appendix
.A, Item 8.b(1)(j) requires procedures for the surveillance tests,
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inspections, and calibrations of the emergency core cooling
- system. . Plant Test Procedure (PTP) 1304.013, Revision 8, "HPI/LPI
and Reactor Building Spray Flow Inst. Surv. Red Channel," has
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been. established in accordance with this TS aquirement.
Section 8.7 of PTP 1304.013 provides instructions for the
calibration of Transmitter PDT-1401 which provides a flow signal
for Train A of the low pressure injection and decay heat removal
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. systems. These instructions require isolation and venting of the
transmitter prior to actual calibration.
Contrary to the above, on March 14, 1989, Transmitter PDT-1402
was inadvertently isolated when the work instructions directed
that Transmitter PDT-1401 be calibrated.
This action caused the
loss of decay heat removal flow indication and the subsequent
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securing of the decay heat removal pump by the operators due to
loss of indicated flow.
This is a Severity Level IV violation. '(Supplement I)(313/8910-02)
Resporse to Violation 313/8910-02
(1) The reason for the violation if admitted:
AP&L does admit the violation occerred as stated.
The incorrect
actions resulted from a personnel error by the Instrumentation
.and Controls technician who failed to accurately verify the
instrument tag number prior to isolating the component.
.A
contributing cause was an error in the maintenance surveillance
procedure which specified the location of PDT-1401 as the "B"
decay heat vault rather than the correct location of the "A"
decay heat vault.
(2) The corrective steps which ham been taken and the results achieved:
When the incorrect transmitter was isolated and flow indication
was lost, decay heat flow was secured.
Operations contacted the
technician who immediately unisolated PDT-1402, restoring flow
indication for the "B"
train cf decay heat.
Associated
maintenance activities were discontinued until the problem was
investigated and resolved.
Decay heat flow was restored within 13
,
minutes from the time it was secured by Operations.
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(3) The corrective steps'which will be taken to avoid further violations:
To prevent'further violations,;the surveillance procedure has-
been changed to indicate the cc rrect location of PDT-1401 as the
"A" decay heat vault. .. Additionally, Maintenance Supervisors.were
advised of the circumstances of the event and were requested to
review the event with their groups, stressing attention to
detail.
These reviews have been conducted. We believe these
. actions will preclude similar violations in the future.
(4) The date when' full compliance will be achieved:
Full compliance was achieved immediately following the event
March 14, 1989.
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Att: chm:nt to BCAN068903
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Juna 14, 1989
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10CFR50.62 states in Section (d) that an implementation schedule
is required from licensee to indicate " final implementation" by
the second refueling outage after July 26, 1984, or, if
justified, a later date should be mutually agreed upon by the
Commission and the licensee.
The second refueling outage
implementation deadline was extended to the third refueling
outage for ANO-2 in a March 2, 1987, letter from the Office of
Nuclear Reactor Regulation (NRR) ANO, Unit 2, Project Manager to
Mr. T. G. Campbell.
Cor,trary to the above, the third refueling outage for ANO-2
following the July 26, 1984, date, 2R6, was completed in May of
1988, and no ATWS related equipment was installed by that date.
Further, no request for scheduler extension had been requested
by AP&L or approved by the NRC.
This is a Severity Level IV violation.
(Supplement I)(368/8910-03)
Response to Violation 368/8910-03
Since before the publication of the Final Rule on Anticipated Transients
Without Scram (ATWS) in July of 1984, the Arkansas Power & Light Company
(AP&L) has actively participated in the Comoustion Engineering Owner's Group
(CEOG) effort to satisfactorily resolve the ATWS concerns as they relate to
Arkansas Nuclear One, Unit 2 (ANO-2).
These efforts were directed at
participating in the development of an effective and reasonable regulation
during the initial rule making and subsequently, following issuance of the
final rule, at appropriately satisfying the technical requirements to
implement the ATWS rule (10CFR50.62) on ANO-2.
Appropriate ATWS modifications for ANO-2 and its sister CE plants (San
Onofre Nuclear Generating Station 2 and 3 (SONGS 2 and 3), and Waterford Unit 3)
have presented a unique set of problems due to the integrated Plant
Protection System (PPS) design on these units which make it difficult and
expensive to achieve diversity between Emergency Feedwater (EFW) control
and Reactor Trip System (RTS) control to the extent considered by the Staff
to be a necessary requirement of the ATWS rule. The CEOG has submitted two
generic topical reports, CEN-315 and CEN-349, which have addressed the
safety benefits to be gained from complete diverse actuation of EFW versus
the cost to engineer, and install a system to accomplish this requirement.
The results have been an almost negligible imp'rovement in safety with an
accompanying cost that is quite significant.
Following the submittal of CEN-315 and 349, the NRC, in correspondence dated
January 11, 1988, from Mr. George Knighton to Messrs. Kenneth P. Baskin and
James C. Holcomb, provided the Staff evaluation of these documents and
concluded that sufficient EFW and RTS diversity did not exist for ANO-2,
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SONGS 2&3 and Waterfurd 3.
That correspondence further directed these plants
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Attachment to SCAN 068903
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Juns 14, 1989
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to either provide the required independence and diversity for these systems
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.or request an exemption.
In regard to the last option, ti.:. correspondence
contained Staff guidance for such an exemption request.
Following the subject written guidance as well as verbal direction received
during meetings with the Staff, AP&L as well as the other affected CEOG
members submitted requests for exemption from the portion of the ATWS rule
which required diverse and independent means to actuate EFW.
That request
was subsequently denied, in the case of ANO-2 by correspondence dated
February 16, 1989 (2CNA028903).
Additional meetings with the Staff have led to efforts by the CEOG to
reevaluate other design options, besides the one discussed in the exemption
request, to determine if a less costly solution c.mid be found to achieve
an acceptable level of diversity between EFW and Ris.
The CEOG has
proposed an alternate design (although this design contains some areas of
concern) to the staff and it is being evaluated at this time.
It has been
the position of AP&L, in accordance witn the CEOG, that the only design
option that fully complies with 10CFR50.62 in all aspects is a fully
redundant, Class IE EFW system such as was~ discussed in our request for
partial exemption (November 3, 1988, 2CAN118801).
As has been stated
earlier, that design is quite costly (3-5 million dollars) and the
supporting analysis indicates that the incremental safety improvement in
installing such a system is quite small (49 X 10~7 severe ATWS events
per reactor year).
The resulting value/ impact ratio (VIR) is comparable to
that discussed in the Statements of Consideration to the Final Rule which
related to the addition of extra safety valves on CE units, but was rejected
by the Commission because of the unfavorable VIR.
Further progress on a resolution of this issue is pending the results of
the Staff raview of the CEOG's alternate design proposal which is presently
underway.
(1) The reason for the violation if admitted:
AP&L admits that a violation of NRC regulations occurred.
The original ANO-2 ATWS implementation schedule called for the
required modification to be installed by the second refueling outage
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following the date of the Final Rule.
In the case of ANO-2 this
would have been our fifth refueling outage (2R5).
AP&L recognized
very early that such a schedule could not be met and therefore .otified
the Commission in our correspondence of October 15, 1985 (2CAN148508),
that our schedule would be extended to 2R6.
As the review of the second CE topical (CEN-349), continued, it becanne
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clear that our 2R6 implementation schedule could not be completed.
Internal correspondence prior to the end of 2R6 indicates that the
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need to extend the implementation of ANO-2 ATWS modifications was
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recognized as necessary.
At this point, AP&L failed to formally
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request, on the ANO-2 docket, an extension for ATWS modifications
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beyond 2R6.
AP&L believes that the discussions on going with the
Staff during this period addressed the status of ATWS implementation
on ANO-2, nonetheless, that changing status was not documented by
correspondence.
Further confusion with regard to the ATWS modifications
implementation date was introduced by our November 3, 1988, exemption
request which incorrectly identified 2R7 as the third refueling
outage following the date of the Final Rule.
This fact was discussed
previously in AP&L's March 29, 1989, response to the exemption denial
(2CAN038910).
(2) The corrective jteps which have been taken and the results achieved:
(3) The corrective steps which will be taken to avoid further violations:
The corrective steps which have been taken are twofold.
First, the
Commission has been informed in the correspondence referenced above
(2CAN038910) of the status regarding implementation on ANO-2 of
10CFR50.62 required modifications.
Secondly, we have reviewed our
commitment tracking system to verify that these ATWS milestones,
such as AP&L's commitment in our previously referenced correspondence
to install our Diverse Scram System (DDS) and Diverse Turbine Trip
(DTT) function during 2R7, are correctly identified and tracked.
Likewise, once the EFW actuation diversity issue is resolved, any
required plant modifications that result from.that action will be
tracked until implemented and closed out.
To prevent future violations with regard to implementation schedule,
an additional tracking system entry has been made with a date of
approximately six months prior to the start of refueling outage 2R8 to
flag EFW actuation modifications.
That tracking entry requires
the review of the status of these modifications relative to their
implementation during 2R8 and subsequent notification of the Commission
if that schedule cannot be met for any reason.
(4) The date when full compliance will be achieved:
As stated previously, AP&L will install the Diverse Scram System (DDS)
and Diverse Turbine Trip (DTT) functions during our seventh refueling
outage (2R7) currently scheduled to begin in September, 1989.
The
schedule for implementation of the remaining ATWS requirement, diverse
and independent means to actuate EFW, cannot be determined at this
time.
The actual schedule (2R8 or later) is a function of the
complexity of the final acceptable design solution which will not
likely be known for several months.
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