ML20078E998
| ML20078E998 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/04/1994 |
| From: | Mims D ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9411150122 | |
| Download: ML20078E998 (3) | |
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Td 501d%3100 November 4,1994 1CAN119404 U. S. Nuclear Regulatory Commission Document Control Desk Mail Station PI-137 Washington, DC 20555
Subject:
Arknas Nuclear One - Unit 1 & 2 Docket No. 50-313 and 50-368 License No. DPR-51 and NPF-6 Extension on Response to Inspection Report 50-313/94-07;50-368/94-07 Gentlemen:
The NRC inspection conducted between July 24 through September 3,1994, identified a violation (313/9407-01) of NRC requirements. The violation cited Arkansas Nuclear One (ANO) for a failure to comply with Unit 1 Technical Specification (TS) 3.6.5. The TS states, in part, that prior to criticality following a refueling shutdown, a check shall be made to confirm that all manual reactor building isolation valves which should be closed are closed and locked, as required. The violation stated that the main feedwater vent valves FW-1038 and FW-1049, located on the main feedwater process lines that penetrate the reactor building through penetrations P-3 and P-4, should have been locked closed per general design criteria (GDC) 57.
During the week of September 12,1994, ANO informally provided to the NRC a position paper on Containment Isolation Boundaries and Connections for Testing that addressed the cited i
valves as administratively controlled containment integrity barriers. As part of an ongoing effort to resolve the issue, ANO informally surveyed actions taken by other utilities regarding test, vent, and drain valves for containment isolation and compliance with the general design criteria. The survey indicated a range ofinterpretations as to the application of the general design criteria to the test, vent, and drain valves. Further, in trying to research the identified concern, additional issues have surfaced along with our original questions which we have not been able to resolve to our satisfaction. A primary issue is understanding the rationale for assuming that GDC 57 is applicable to vent and drain valves on the main steam system between the containment and the main steam isolation valves. These penetration lines contain main steam traps and main steam i
safety valves that are not automatic isolation valves and are not capable of remote operation.
l Ikepuse of remaining ambiguity regarding GDC 57 application in such cases and the results from a4U02]
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U. S. NRC November 4,1994 1CAN119404 PAGE 2 the informal survey that indicate significant variation in the industry handling of related issues, ANO would like to better understand the issue before responding to the violation. Therefore, ANO requests an extension for responding to violation 313/9407-01 until December 16,1994.
ANO has been active in addressing this issue and the extension will allow time to further research applications of the general design criteria and evaluate industry practices. Additionally, the extension will provide an opportunity for further interaction between the NRC and ANO to resolve the issue of applicability of the general design criteria governing isolation valves for reactor building penetrations to test, vent, and drain valves. Currently, ANO has taken actions to lock closed the valves cited in the violation. We have also locked other closed manual valves located outside the reactor building that may be subject to a similar interpretation of GDC 57.
The extension was discussed with Mr. Gregory Pick, Project Branch D, NRC Region IV on November 3,1994.
Should you have questions or comments, please call me at 501-858-4601.
Very truly yours, bjfC'71Q Dwight C. Mims Director, Licensing DCM/AJG Attachment 1
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. Attachment to ICANI19404 Page1of1 cc:
Mr. Leonard J. Callan l
Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Arkansas Nuclear One 1448 S. R. 333 Russellville, AR 72801 -
Mr. George Kalman NRR Project Manager Region IV/ANO-1 & 2 U. S, Nuclear Regulatory Commission NRR Mail Stop 13-H-3 One White Flint North 11555 Rockvil!e Pike Rockville, MD 20852 i
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