IR 05000313/1986022

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-313/86-22 & 50-368/86-23.Addl Info Re Procedure 1104.29 Requested

ML20213E509
Person / Time
Site:	Arkansas Nuclear
Issue date:	11/07/1986
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Campbell G ARKANSAS POWER & LIGHT CO.
References
NUDOCS 8611130197
Download: ML20213E509 (2)

Text

F-

- e o N0Y ?M i

In Reply Refer To:

Dockets: 50-313/86-22 50-368/86-23 Arkansas Power & Light Company ,

ATTN: Mr. Gene Campbell Vice President, Nuclear Operations P. O. Box 551 Little Rock, Arkansas 72203 . ,,' ,

.

Gentlemen: ,

..-

.

Thank you for your letter of October 10, 1986, in response to our letter and the attached Notice of Violation dated August 21, 1986. As a re'sult.

of our review, we find-that additional information, as discussed,with your ~

Mr. Levine (during a meeting on November 5,1986) is needed. Specifically,' we continue to believe that your failure to adequately maintain Procedure 1104.29, is a violation of Technical Specification 6.8.1.a. You are required to provide a written response to this apparent violation stating: (a) the corrective steps which have been taken and the results achieved, (b) the corrective steps which will be taken to' avoid further violations, and (c) the date when full compliance will be achieved. <

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

Sincerely, Odginal Signed By J. J. E. Gagliardo, Chief Reactor Projects Branch cc:

J. M. Levine, Director Site Nuclear Operations Arkansas Nuclear One P. O.~ Box 608 Russellville, Arkansas 72801 Arkansas Radiation Control Program Director RIV:RP8/k C:RPB' C:RPB3 MEMurphy:cs Q RHun er JEGagliardo 11/f786 11 86 11/g /86 D i I weme G

_-_-- _-

-

. a .

Arkansas Power & Light Company -2-bec to DMB (IE01)

bcc distrib. by RIV:

RPB RRI R. D. Martin, RA R&SPB Section Chief (RPB/B) D. Weiss, LFMB (AR-2015)

RIV DRSP RSB MIS System RSTS Operator RSB M. Murphy, RIV i

o - - _ - - _ _

. . .

Q

.

ARKANSAS POWER & LIGHT COMPANY POST OFFICE BOX 551 LITTLE ROCK. ARKANSAS 72203 (501)371-4000 October 10, 1986 r-----=-- 1

'

-

i {'[it 6 .

I LCT 2 71986

]$i $,I OCAN198606

,_

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 Reports 50-313/86-22 and 50-368/86-23

Dear Mr. Gagliardo:

The subject response has been reviewed. Responses to the Notica of Violation are attached.

Very truly yours,

.

J. Ted Enos, Manager Nuclear Engineering and Licensing JTE:RJS:ji Attachment '

g. [$(p MEMBEA MICOLE SOUTH UTiuTIES SYSTEM

_ _

. . .

O

-

NOTICE OF VIOLATION During an NRC inspection conducted during the period July 1-31, 1986, violations of the NRC requirements were identified. The violations involved failure to properly maintain an operating procedure and failure to obey a radiological posting. The violations and responses are listed below:

A. Unit 1 Technical Specification 6.8.1.a requires, in part, that written procedures shall be established, implemented and maintained covering activities recommended in Appendix "A" of Regulatory Guide 1.33, November 1972.

Paragraph C of this appendix recommends having written procedures for operation of the service water system.

Operating Procedure 1104.29, " Service Water and Auxiliary Cooling System," has been established in accordance with this Technical Specification.

Contrary to the above, Procedure 1104.29 was not adequately maintained by the licensee. During a system walkdown, the NRC inspectors found that five manual valves listed in Attachment A of Procedure 1104.29,

" Valve Lineup for SW and ACW Systems," are not installed in the plant.

These valves had been noted as not installed in January 1985, by licensee operators conducting a system alignment using Revision 16 of Procedure 1104.29, but they were still listed in Revision 22 of this procedure dated July 3, 1986.

This is a Severity Level IV violation. (Supplement I.D) (313/8622-01)

RESPONSE TO VIOLATION 313/8622-01 The inspector indicates these five valves were noted as not installed on the valve lineup exception sheet for Procedure 1104.29 system alignment in January 1985. He concludes that, because these remain in the current revision, the procedure has been inadequately maintained. This conclusion apparently does not consider the procedural guidance for the use of the valve lineup exception sheets. Section 9.5 of Procedure 1015.01, " Conduct of Operations," delineates requirements for valve lineups. This section requires that these exception sheets be maintained with the system lineup sheets. It specifically indicates that exceptions do not require procedure changes unless such exceptions affect required safety system alignments.

The subject valves were in no way affecting the service water system function and would not have required immediate ravision. This would have been evaluated by the Shift Supervisor prior to completion of plant startup.

The valve lineup exception sheets are not the primary means of maintaining system valve lineups in procedures. They are especially not relied on for addition or deletion of valves to the 1;neups. The review of design changes provides the primary source of information for procedure changes. Following the refueling outage ending in January 1985, valve lineup exceptions of minor significance did not result in immediate procedure changes. A major

. - . . -- . . __- _ . - . , _ - _ - . . - . .- . _ . - . .- .

.

..

.

J

i.

,

equipment walkdown and labeling verification effort was in progress and was i

expected to be completed prior to the next refueling outage. As part of this program, several sources of information are being utilized by the Operations Technical Support Group to revise procedures.

AP&L fails to recognize how the continued inclusion of these five valves on the valve lineup is indicative of inadequately maintaining a procedure. The i

system alignment was accomplished and correct actions for exceptions were j taken as required by the Conduct of Operations procedure. A valve lineup serves to prepare for system operation. Critical manual valve alignments are performed by the Category E valve lineup specified in Procedure 1102.01,

" Plant Preheatup and Precritical Checklist," and are independently verified.

l Maintaining correct position is ensured by locking these valves. This valve l alignment was accomplished prior to heatup following the refueling outage.

l The five va?ves of concern were not Category E valves. The inclusion of these valves in the valve lineup caused no performance errors and

! compromised no system function. Therefore, AP&L does not concur that a

'

violation of Technical Specification 6.8.1.a has occurred.

,

! B. Unit 2 Technical Specification 6.11 requires, in part, that procedures

, for personnel radiation protection shall be prepared and adhered to for

all operations involving personnel radiation exposure.

Licensee Procedure 1000.31, " Radiation Protection Manual,"

. Section 9.3.8, Paragraph C under " General Radiation Protection Rules" l requires all personnel to comply with pJsted area entrance requirements.

l

,' The pressure vessel head stud cleaning tent was posted " airborne area, respiratory protection required" for entry.

Contrary to the above, on July 9, 1986, two licensee contract i maintenance personr.al entered the tent without respiratory protection.

i j This is a Severity Level V violation. (Supplement I.D) (368/8623-01)

!

l RESPONSE TO VIOLATION 368/8623-01 I

The contractors who performed the reactor vessel stud cleaning were l counseled subsequent to the incident. They indicated that they had been

,

anxious to complete the job and inappropriately entered the tent before j donning respirators. They had assumed that with the machine not running, i the tent was not an airborne area. While earlier sampling had indicated no

{ airborne contaminates, the posting had not been removed and should not have l- been disregarded. No similar incidents occurred during the completion of l the job. Immediate actions achieved compliance.

-

!

The outage health physics controls and the contractor training were reviewed j by the Maintenance Manager and determined to be adequate. The circumstances

of the specific incident indicate it was an isolated case involving the

! contractors providing cleaning services for reactor vessel studs. No

{ further action was deemed necessary.

i

!

i i

!

!__--..,__._._.___..._ _ ._ _. . _ _