ML20247L623

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Ack Receipt of in Response to Violations Noted in Insps 50-313/88-35 & 50-368/88-35.Addl Info Re Steps Taken to Preclude Recurrence of Valve Misalignments Associated W/Containment Integrated Leak Rate Test Needed
ML20247L623
Person / Time
Site: Arkansas Nuclear  Entergy icon.png
Issue date: 05/23/1989
From: Callan L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Campbell G
ARKANSAS POWER & LIGHT CO.
References
NUDOCS 8906020222
Download: ML20247L623 (2)


See also: IR 05000313/1988035

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_In Reply Refer To:

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Dockets: ~ 50-313/88-35

50-368/88-35

Arkansas Power & Light Company

ATTN:

Mr. Gene Campbell

Vice President. Nuclear

Operations

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P.O. Box 551

Little Rock, Arkansas 72203

Gentlemen:

Thank you for your letter of_ April 25, 1989, in response to our' letter and the

attached Notice of Violation dated March 28, 1989. As a result of our review,

we find that additional information is needed, as discussed with your Mr. Don

-Lomax during a telephone call with our Messrs. W. Seidle and R. Azua on May 17,

1989.

Specifically, in the area of corrective steps, which will be taken to

avoid further violations, it was noted that all of the corrective steps needed

to preclude recurrence of valve misalignments associated with a CILRT were not

identified.

Please provide the supplemental information within 30 days of the date of this

letter.

Sincerely.

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Callan, Director

Division'of Reactor Projects

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Arkansas Nuclear One

ATTN:

J. M. Levine, Executive

Director, Nuclear Operations

P.O. Box 608

Russellville, Arkansas 72801

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L. J. Callan, Director

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U. S. Nuclear Regulatory Commission

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Arlington, Texas 76011

SUBJECT:

Arkansas Nuclear One - Units 1 and 2

Docket Nos. 50-313/50-368

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License Nos. DPR-51 and NPF-6

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Response to Inspection Report

50-313/88-35 and 50-368/88-35

Dear Mr. Callan:

Pursuant to the provisions of 10CFR2.201, a response to the

violation identified in the subject inspection report is submitted.

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Very truly yours,

t.-th, & 1 %

J. M. Levine

Executive Director,

Nuclear Operations

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U. S. Nuclear Regulatory Commission

Document Control Desk

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OCAN048905

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April 25, 1989

Page 2 of 3

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Notice of Violation

Technical Specification 6.8.1 requires that written procedures be

established and implemented for surveillance and test activities of

safety-related equipment.

Procedure.1092.030, Revision 0, " Integrated Leak Rate Test," has

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been established in accordance with this Technical Specification.

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Appendix B of this procedure requires that the manually operated,

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Instrument Cooling Water System Valve ICW-32 be placed in the open

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position, and that valve positions be independently verified.

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Contrary to the above, on November 2. 1988, the NRC inspector found

Valve ICW-32 to be in tha closed position.

The valve tag called for

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the valve to be in the open position, as cpecified by Appendix B to

Procedure 1092.030.

Initials had been entered on the valve position

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table in Appendix B to document that the "open". position for Valve

ICW-32 had been independently verified.

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This is a Severity Level IV violation.

(Supplement I)

(50-313/88-35-01)

Response to Violation 50-313/88-35-01

(1)' The reason for the violation if admitted:

As discussed in an enforcement conference held at NRC Region IV

~ January 23, 1989, AP&L does admit the violation occurred as

stated above.

As a result of a valve misalignment which occurred during

performance of the ANO-2 CILRT in April 1988 (reference violation

368/8811-01), the AND-1 CILRT procedure had been revised, prior

to use in November 1988, to include independent verification of

valve' positions.

These procedural controls were adequate to

ensure valve ICW-2 was correctly positioned and verified in

accordance with the procedure during the initial CILRT alignment

on November 1, 1988.

However, AP&L believes that ICW-32 was

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subsequently closed during attempts to stop water leakage in the

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area, which was interfering with work activities in the reactor

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building, due to a personnel error and inadequate knowledge of

the controls related to valve manipulations during performance

of the containment integrated leak rate test (CILRT).

(2) The corrective steps which have been taken and the results

achieved:

Immediate actions following identification of the mispositioned

valve, ICW-32, were to correctly align it in the CILRT

position (open) and to verify the position of other valves in the

reactor building prior to proceeding with the CILRT.

No

other mispositioned valves were identified.

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.OCAN048905

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' April 25, 1989

Page 3'of 3

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(3) The corrective steps which will be taken to avoid further

violations:

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As. discussed above, a valve misalignment had previously occurred

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during the April 1988 performance of the ANO-2 CILRT.

Based on

this occurrence, the AND-1 CILRT procedure had been revised

prior to the performance of the test November 1988.

The CILRT

procedure.for ANO-2 is being revised to include an independent

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verification of valve position. This revision will be completed

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prior to the next CILRT on ANO-2.

This action should ensure

that the initial CILRT alignment is performed correctly.

Additionally, to address the personnel error that is believed

'to have resulted in the mispositioning of ICW-32 following

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initial CILRT alignments, training will be provided to appropriate

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personnel to include a discussion of the requirements associated

with CILRT tags and controls for performance of the test.

Also,

the CILRT tags will be revised to include warnings on both sides

to require Shift Supervisor's approval prior to changing the

position of a CILRT tagged valve or another warning / tagging

method' implemented as deemed appropriate.

(4) The date when full compliance will be achieved:

Full compliance was achieved November 3, 1988, following

realignment of ICW-32 and reverification of other valve positions.

.The future actions will be completed prior to the next CILRT

performed for the respective unit.

The test for ANO-1 should

occur in late 1991 or early 1992.

The ANO-2 test should occur

mid-1991.

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