0CAN079011, Suppls Response to Violations Noted in Insp Repts 50-313/88-47 & 50-368/88-47 Re Isolation Valve CS-26. Corrective Actions:Special Work Plan Developed & Valve Cs-26 Local Leak Rate Tested on 900216

Suppls Response to Violations Noted in Insp Repts 50-313/88-47 & 50-368/88-47 Re Isolation Valve CS-26. Corrective Actions:Special Work Plan Developed & Valve Cs-26 Local Leak Rate Tested on 900216

ML20055G858
Person / Time
Site:	Arkansas Nuclear
Issue date:	07/20/1990
From:	Ewing E ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
0CAN079011, CAN79011, NUDOCS 9007240242
Download: ML20055G858 (3)

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, Entergy Operctions,Inc.

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OCAN079011' l

, U. S. Nuclear Regulatory Commission

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-Document Control Desk

Mail" Station PI-137-

/ Washington, D. C. 20555 l SUBJECTi ' Arkansas Nuclear One - Units 1 and 2 l

, -Docket Nos. 50-313/50-368 >

= License Nos. DPR-51 and NPF-6

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, Additional Response to Inspection Report 313/88-47; 50-368/88-47 Gentlemen: ,  !

Thank youtfor'the clarification of notice of violation 313/8847-05'which you provided in your letter dated June 22, 1990 (OCNA069018). .After review -

, of the-NRC Staff position:and other associated documents, it is evident  :

-that-containment isolation valve CS-26 does rcquire Type C (local leak' .!

rate) testi.ng per the requirement.. af 10CIR Part 50, Appendix J.

TAccordingly, an additional response to the violation is provided pursuant- 1' to the' provisions of_100FP'.201.

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.Very truly yours, l t-i

.E. C. Ewing  !

m General Manager, '

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.ECE/DWB/sgw 1 "l Attachment'-

Regional Administrator

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cc:- i Region IV 611 Ryan Plaza Drive, Suite 1000 i

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,x Page l' j Notice of Violation Failure to Perform a^ Type C leakage Rate Test on Containment Isolation Valve Pursuant to 10-CFR Part 50. Appendix J

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10 CFR Part 50, Section'50.54(0) requires that the primary reactor.

T containment'shall:be subject to the requirements of:10 CFR Part 50, Appendix J.

Appendix'J requires that periodic leak testihg of the systems penetrating the primary containment be conducted.

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k Contrary to the above, the inside containment isolation Check Valve CS-26,.

associated with containment penetration P39, was found on December 15, 1988, to have not been subject to applicable Appendix J Type C testing.

This is.a Severity Level IV violation. (SupplementI)(313/8847-05)

1. The reason for the violation:

AN0's interp .tation of 10CFR50 Appendix J and the ANO-1 Technical Specifications concluded that Type C testing was not required for-CS-26 because the valve did not meet the criteria for valves that are subject to Type C' testing per paragraph II.H of Appendix J and ANO-1 Technical Specificatior. 4.4.1.2.1, item e, f, and g, therefore, the valve was not Type C (Local Leak Rate) tested. This interpretation was incorrect,- in light of'the Staff position that check valve CS-26 is " required to close automatically upon receipt of a containment 4 isolation signal;in response to controls intended to effect containment isolation". Given this interpretation, check valve CS-26 e 'does-require Type C testing and failure to do so violated the i requirements of 10CFR50 Appendix J.

Corrective steps which have been taken and the results;

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2.

In response to the identified concern, a special Work Plan was developed and CS-26 was local leak rate tested on February 16, 1989.

The As-Found LLRT resulted in a 650 acem (absolute cubic cer.timeters per minute) leakage rate. Maintenance was performed on CS-26 and an As-Left LLRT was performed with a resultant 4.199 accm leakage rate.

The 650 accm As-Found leakage rate, when added to the total known Type B & C leakages (1497.972 accm at the time) resulted in a total leckage rate.of 2147.972 accm. This total does not approach the ANO-1 Technical Specification limit for the total B & C leakage of 44,023 1

accm and, therefore, was not stfety significant.

It.should be noted that this violation was identified in December 1988. In February 1989, LLRT of all the ANO-1 containment isolation check valves was completed. The total leakage from the check valves was added to the total known Type B & C leakage rate. The total Type B & C leakage, including the check valve leakages, was determined ~.o be 9848.195 acem, which is well below the Technical Specification limit of 44,023 accm.

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= Additionally, during the ANO-2 seventh refueling outages (Fall 1989),

all the' ANO-2 containment isolation check valves were tested per ANO-2 LLRT-procedure 2305.17 for information only. The leakage rates of.all; containment isolation check valves were included as part of the Type B

& C total of 2845.199 accm,-which is well below the ANO-2 Technical

Specification limit of 20,990'accm.

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3. L The corrective steps which will be taken to prevent recurrence:

The ANO-1 Type C test procedure 1305.18 will.be revised to include

-local leak rate testing of CS-26 along with all other containment isolation check valves that are a part of a; Type C testable penetration.

Additionally. the corresponding ANO-2 containment isolation check valves will be included in the ANO-2 Type C test procedure 2305.17.,

Also, a' Technical Specification change request will be submitted tot delete the exemption _for. Type C testing-these ANO-2 containment 1 isolation check valves.

4. -The'date of full compliance

.ANO-1 Local Leak Rate Test procedure 1305.18 will be revised to include -local leak rate testing of- containment isolation check valves by October-1, 1990, which is prior to the next scheduled ANO-1

-refueling: outage.

ANO-2 Local Leak Rate. Testing procedure 2503.17 will be revised to nelude local leak rate testing of containment isolation check valves y February 1,1990, which is prior to the next scheduled ANO-2 refueling outage.

The ANO-2 Technical Specifications change requee ,11 be submitted by 0ctober 30, 1990.

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