IR 05000313/1986022: Difference between revisions

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{{Adams
{{Adams
| number = ML20206M877
| number = ML20213E509
| issue date = 08/20/1986
| issue date = 11/07/1986
| title = Insp Repts 50-313/86-22 & 50-368/86-23 on 860701-31. Violations Noted:Svc Water Sys Alignment Procedure Inadequately Maintained & Radiological Posting Disobeyed
| title = Ack Receipt of 861010 Ltr 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
| author name = Harbuck C, Hunter D, Johnson W
| author name = Gagliardo J
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| addressee name =  
| addressee name = Campbell G
| addressee affiliation =  
| addressee affiliation = ARKANSAS POWER & LIGHT CO.
| docket = 05000313, 05000368
| docket = 05000313, 05000368
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-313-86-22, 50-368-86-23, NUDOCS 8608260006
| document report number = NUDOCS 8611130197
| package number = ML20206M866
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 2
| page count = 9
}}
}}


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=Text=
=Text=
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    . . .
- e o N0Y ?M i
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In Reply Refer To:
APPENDIX B U. S. NUCLEAR REGULATORY CONilSSION
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.


==REGION IV==
of our review, we find-that additional information, as discussed,with your ~
NRC Inspection Report: 50-313/86-22  Licenses: DPR-51 50-368/86-23  NPF-6 Dockets: 50-313
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.    <
  .50-368 Licensee: Arkansas Power & Light Company (AP&L)
Please provide the supplemental information within 30 days of the date of this letter.
P. O. Box 551 Little Rock, Arkansas 72203 Facility Name: Arkansas Nuclear One (AN0), Units 1 and 2 Inspection At: ANO Site, Russellville, Arkansas Inspection Conducted: July 1-31,.1986
 
      ,
Sincerely, Odginal Signed By J. J. E. Gagliardo, Chief Reactor Projects Branch cc:
Inspectors: ///D  f[i/ #6 W.D.Jpson,SeniorResident  Dhte'
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
Reactor Inspector (pars. 1, 4, 5, 6, 8)
 
_f / lb C. C. Harbuck, Resident Reactor Date Inspector (pars. 1, 2, 3, 4, 5, 6, 7, 8)
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  }p}  3 1. - 9i Approved: e f. R.Viunter, Reactor Projects Date '
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Section B, Reactor Projects Branch
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ARKANSAS POWER & LIGHT COMPANY POST OFFICE BOX 551 LITTLE ROCK. ARKANSAS 72203 (501)371-4000 October 10, 1986  r-----=--  1
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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
_ _
 
. . .
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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.


I'  -. .,
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.
V
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  ~
    -2-Inspectior Summary Inspection Conducted July 1-31, 1986 (Report 50-313/86-22)
Areas Inspected: Routine, unannounced inspection including operational safety verification, maintenance, surveillance, followup on an open item, and followup on a violatio Results: Within the five areas inspected, one violation was identified (failure to adequately maintain the service water system alignment procedure, paragraph 4).


Inspection Summary Inspection Conducted July 1-31, 1986 (Report 50-368/86-23)
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
Areas Inspected: Routine, unannounced inspection including operational safety verification, maintenance, surveillance, followup on a Licensee Event Report, and inservice hydrostatic test observatio Results: Within the five areas inspected, one violation was identified (failure to obey a radiological posting, paragraph 4).


. - . . -- . . __- _ . - . , _ - _ - . . - . .- . _ . - . .- .
  .
  .
  -3-DETAILS Persons Contacted
  ..
  *J. Levine, Director of Site Nuclear Operations R. Ashcraft, Electrical Maintenance Supervisor
*B. Baker, Operations Manager
*P. Campbell, Licensing Engineer A. Cox, Operations Technical Support Supervisor G. D'Aunoy, Operations Technical Support E. Ewing, General Manager Technical Support G. Fiser, Radiochemistry Supervisor L. Gulick, Unit 2 Operations Superintendent H. Hollis, Security Coordinator D. Horton, Quality Assurance Manager
*D. Howard, Manager, Special Projects
*L. Humphrey, General Manager, Nuclear Quality D. Johnson, Licensing Engineer
*H. Jones, Manager, Plant Modifications J. Lamb, Safety and Fire Protection Coordinator
*D. Lomax, Licensing Supervisor
*R. Lane, Manager, Engineering B. Lovett, Electrical Maintenance Engineer J. McWilliams, Maintenance Manager
*J. Orlicek, Field Engineering Supervisor V. Pettus, Mechanical Maintenance Superintendent D. Provencher, Quality Engineering Supervisor
*S. Quennoz, General Manager, Plant Operations
,P. Rogers, Plant Licensing Engineer C. Shively, Plant Engineering Superintendent R. Simmons, Planning and Scheduling Supervisor C. Taylor, Operations Technical Support Supervisor B. Terwilliger, Consultant R. Tucker, Electrical Maintenance Superintendent
;*D. Wagner, Assistant Health Physics Superintendent
*R. Wewers, Work Control Center Manager
  .
  .
G. Wrightam, I&C Supervisor S. Yancy, Mechanical Maintenance Supervisor
J
*C. Zimmerman, Operations Technical Support
 
*Present at exit intervie The inspectors also contacted other plant personnel, including operators, technicians, and administrative personne . Followup on Previously Identified Items (Unit 1)
i.
(Closed) Violation (313/8602-01): Failure to follow a quality control procedure in seismic support inspectio ,
.
  -
,. ty-4-
-The NRC inspector verified that the specific support deficiencies identified on support 3EFW-116-H20 had either been corrected or evaluated as being adequate by the licensee. Programatically, the licensee has established an independent QA/QC organization within the plant modifications group. Independent inspection of seismic support installation, including concrete expansion anchor bolts, is assigned to this organization. In the case identified by the violation, an independent inspection was not require Further licensee corrective actions for this item were also taken in response to open item (313/8602-03), and are described below. Based on the actions'noted above and the observations and reviews noted below, this item is close (Closed) Open Item (313/8602-03): Control of seismic support installatio The NRC inspector reviewed the following recently issued licensee supplemental instructions (sis):
. SI-C-2406-2, "Non-structural Baseplate and Penetration Grout"
. SI-C-2408-1, " Concrete Expansion Anchors" These sis clarify the requirements of the associated AP&L construction Technical Specifications (TSs), C-2406 and C-2408. The NRC inspector found that they provided adequate guidance to construction craftsmen to ensure compliance with the TS The NRC inspector witnessed anchor bolt . installation and inspection for DCP 84A-2022B, specifically the placement and torquing of anchor bolts for the 2011 battery rack baseplate The NRC inspector also inspected seismic support installations for the Unit 2 EFW suction piping from the seismically qualified condensate storage tank being built. No problems were note Based on these reviews, observations, and inspections, the NRC inspector concluded that the licensee's control of seismic support installation now appears to be adequate. This item is close . Licensee Event Report (LER) Followup (Unit 2)
Through discussions with licensee personnel and review of records, the following event report was reviewed to determine that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence has been accomplished in accordance with Technical Specification Unit 2 LER No. 86-004-00 reported an automatic reactor trip due to an inadvertent trip of a reactor coolant pump (RCP) breake P"      l
, .
    -5-The licensee determined that the root cause of this event was a design flaw in the RCP breaker indicating circuit on panel 2C-80 (the remote shutdown panel). The design used a full voltage light bulb (125 Vdc) for the breaker indicating lamp, which was wired in series with the breaker trip solenoid. The resistance of the light bulb was used to limit current below that which would actuate the solenoid. In this instance, the replacement light bulb was shorted. When installed in the socket its low resistance allowed a current able to actuate the solenoi The licensee completed plant change No. 86-1733 which modified the indication _ circuits of all four RCP breakers at panel 2C-80. This new design installed a step down or ballast resistor integral to the lamp socket and switched to a lower voltage light bulb. Thus, even with a bulb short circuit, the trip solenoid will not have sufficient current to actuat The licensee was identifying similar circuits and evaluating the need for any modifications. This effort was two-fold: The operation departments for both units were tasked to identify the uses of all full voltage light bulbs in their respective plants, and a consultant had been contracted to perfoirm a review of breaker circuits used at ANO to identify similar circuit designs. This effort will take some time to complet '
Based on the above corrective actions, this event report is close No violations or deviations were identifie . Operational Safety Verification (Units 1 and 2)
The NRC inspectors observed control room operations, reviewed applicable
~ logs, and conducted discussions with control room operators. The inspectors verified the operability of selected emergency systems, reviewed tagcut records, verified proper return to service of affected components, and ensured that maintenance requests had been initiated for equipment in need of maintenance. The inspectors made spot checks to verify that the physical security plan was being implemented in accordance with the station security plan. The inspectors verified implementation of radiation protection controls during observation of plant activitie One problem was identified in this are During a routine tour of the Unit 2 reactor building, the NRC inspector observed two of four contract maintenance workers enter a posted airborne radiologically controlled area (reactor vessel head stud cleaning tent)
with no respiratory protection. The NRC inspector reported this observation to a health physics (HP) technician who verified that the posting was still authorized. The HP technician then directed the workers to remain outside the tent and notified the shift HP supervisor. The subsequuet licensee investigation (Radiological Safety Infraction / Condition '
Report) found that the airborne activity in the tent had been below the limit requiring respiratory protection. This was based on an air sample L


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equipment walkdown and labeling verification effort was in progress and was i
    -6-about an hour before the incident. However, the maintenance workers did not know the results of that sample at the time. Since they had just returned from a work break and the work had been secured in the tent for a ,
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.
while, they assumed, based on previous experience with that job, that the area was safe. Licensee Procedure 1000.31, " Radiation Protection Manual,"
requires that all personnel comply with posted area entrance requirement This is an apparent violatio (368/8623-01)
The NRC inspectors toured accessible areas of the units to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibration. The inspectors also observed plant housekeeping and cleanliness conditions during the tour It was noted that housekeeping in Unit 2 needed improvemen Licensee management had noted a similar concern and had initiated corrective actio The NRC inspectors walked down the accessible portions of the Unit 1 service water system. The walkdown was performed using Procedure 1104.29 and Drawings M-210, M-209, and M-221. No system alignment discrepancies were identified. The NRC inspectors noted that five valves (LO-8030A, SW-609A, SW-6098, SW-607A, and SW-607B) were listed in Attachment A,
" Valve Lineup _for SW and ACW Systems," of Revision 22 of Procedure 1104.29, but the valves were not installed in the plan These valves were not shown on system drawing The NRC inspector reviewed the latest valve lineup for this system in the Unit 1 control roo This valve lineup was performed in January 1985, using Revision 16 of Procedure 1104.29. .The operators had completed Form 1015.01B,
" Valve / Breaker Lineup Exception Sheet," and attached it to the completed valve lineup sheets. _This form listed the above five valves and several others as "Does not exist." The licensee's failure to correct the service water valve lineup list in a subsequent procedure revision is an apparent violation of Technical Specification 6. (313/8622-01)
The NR'C inspector witnessed portions of the Unit 2 fuel reloading both from the reactor building refueling bridge and the spent fuel pool are No problems were note During a tour of the Unit 2 auxiliary building, upper south piping penetration room, the NRC inspector noted that the packing gland nuts were loose on valve 2BS-5614, the service air to 'B' train of the building spray system manual isolation. The licensee was informed, and the problem was corrected under Job Order 71604 These reviews and observations were conducted to verify that selected facility operations were in conformance with the requirements established under Technical Specifications, 10 CFR, and administrative procedure . Monthly Surveillance Observation (Units 1 and 2)
The NRC inspector observed the Technical Specification required quarterly surveillance testing on the Unit 1 high pressure injection pump P36C (Procedure 1104.02, Supplement III), and verified that testing was


m ,
*
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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
w, t
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,
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    -7-performed in accordance with an adequate procedure, test instrumentation was< calibrated, limiting conditions for operation were met, removal and restoration of the affected componests were accomplished, test results conformed with Technical Specifications and procedure requirements, test results were reviewed by personnel other than the individual directing the test, and any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne The inspector also witnessed portions of the following test activities:
  . Monthly test of charging pump 2P36A (Procedure 2104.02 Supplement 1)
  . Reactor protection system channel 'B' monthly test (Procedure' 1304.38, J0 714862)
  . Loop B hot leg temperature (RTD) response time testing (Unit 2)
  (Procedure 4710.31)
  . Quarterly source check of process radiation monitor RE-4830 (Procedure 1304.26, J0 716263)
No violations or deviations were identifie . Monthly Maintenance Observation (Units 1 and 2)
Station maintenance activities of safety-related systems and components listed below were observed to ascertain that they were conducted in accordance with approved procedures, Regulatory Guides, and industry codes or standards; and in conformance with Technical Specification The following items were considered during this review: the limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and fire prevention controls were implemente Work requests were reviewed to determine status of outstanding jobs and to ensure that priority is assigned to safety-related equipment maintenance which may affect system performanc The following maintenance activities were observed:
  . Replacement of Potter-Brumfield MOR relay for 2SV-5021-1 (Work Plan 2409.05)
  . Provision of new vent path for upper south piping penetration room for high energy line break (JO 714058) (DCP 85-D-1072)
  ,
    . . , , . _ , y m_ , _ _ _ _ _ __ _ . . - _ . _ _ .


, .. .
   " Plant Preheatup and Precritical Checklist," and are independently verified.
    -8-
. Battery bank replacement (JO 714021)
. Battery charger repair (2031) (JO 715042)
r
. Post-maintenance test of die'sel generator (JO 707883)
  (Procedure 2306.05)
. Repair of valve 2CV-4921-1 (JO 708269) (Procedure 2402.103)
. Testing operation of valve 2CV-5650-2 using MOVATS (JO 711394)
   (Procedure 1403.31)
. Unit 2 emergency diesel generator 'A', 18-month electrical preventive maintenance (Procedure 2403.07) (JO 708147)
. Heat shrink insulation installation on cable splices for 'B' steam generator temperature sensors (RTDs) (DCP 85-2039, Reactor trip /EFW actuation bypass) (JO 710164)
. Electrolyte recirculation of battery 2011 following service discharge (Procedure 2403.27) (JO 2403.27)
. Calibration of pressurizer pressure transmitter 2PT-4601-3 (Procedure 2304.43)
. Replacement of low pressure safety injection system flow transmitter pipe tap and isolation valve 2SI-5091A (DCP 85-2158) (JO 711112)
No violations or deviations were identifie . Hydrostatic Test Observation (Unit 2)
The purpose of this part of the inspection was to verify that the
~ licensee's inservice hydrostatic test procedures were adequate and that-the tests were being conducted in accordance with the procedures and i Section XI of the.ASME Cod The NRC inspector reviewed the followir.g procedures:
.2409.104 " Hydro $taticTestoftheLowPressureSafetyInjection (LPSI) System" 2409.91 " Hydrostatic Test of the Engineered Safety Features (ESF)
Pump Recircs and Train A ESF Suction Piping"
, It appeared that the procedures met the requirements of Articles IWB-5000 and IWC-5000 of Section XI of the ASME Code, and were adequate to perform the hydrostatic test The NRC inspector verified that the following items were considered:
l j


w -
l Maintaining correct position is ensured by locking these valves. This valve l alignment was accomplished prior to heatup following the refueling outage.
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  . correct determination of the required test pressure (especially at pipe class transition points)
  . duration of test required
  . correct test boundary identification and valve lineup
  . proper location of test pressure gages (including accounting for elevation corrections where needed)
  . establishment of boundary valve leakage drain paths for overpressure protection
  . adequate test equipment (pump, relief valves, test gages, hoses, etc.)


. requirement for a QC inspector with an authorized nuclear inservice inspector (ANII) to perform final system walkdown at test pressure The NRC inspector reviewed the data for Procedure 2409.91 (LPSI). No problems were identifie The NRC_ inspector witnessed the performance of Procedure 2409.91, Section A, Refueling Water Tank recirculation header, Section C, 'A'
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
Engineered Safety Features (ESF) Pump Suctions, and Section D, ESF Pump recirculation pipin Several valves were noted to have minor packing
! compromised no system function. Therefore, AP&L does not concur that a
  . leakage or seat leakage. These were identified for repair by the test engineer. No weld or piping leakage was observed. The NRC inspector concluded that these tests had been performed in accordance with the procedur No violations or deviations were identifie . Exit Interview The NRC inspectors met with Mr. J. M. Levine, Director, Site Nuclear
'
'
Operations, and other members of the AP&L staff at the end of this inspection. At this meeting, the inspectors summarized the scope of the inspection and the finding .
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
l
  '
,' The pressure vessel head stud cleaning tent was posted " airborne area, respiratory protection required" for entry.
  .
 
  '> 4
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.
 
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Revision as of 03:52, 20 January 2021

Ack Receipt of 861010 Ltr 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  Entergy icon.png
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

_-_-- _-

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. 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

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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

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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

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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

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violation of Technical Specification 6.8.1.a has occurred.

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! 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.

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,' 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)

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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

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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.

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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.

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