0CAN098605, Responds to Violations Noted in Insp Repts 50-313/86-21 & 50-368/86-22.Corrective Actions:Policy Document,Detailing Implementation of 10CFR50.59 Review Process W/Supporting Training Program,Developed

Responds to Violations Noted in Insp Repts 50-313/86-21 & 50-368/86-22.Corrective Actions:Policy Document,Detailing Implementation of 10CFR50.59 Review Process W/Supporting Training Program,Developed

ML20214T924
Person / Time
Site:	Arkansas Nuclear
Issue date:	09/10/1986
From:	Enos J ARKANSAS POWER & LIGHT CO.
To:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
0CAN098605, CAN98605, NUDOCS 8609300441
Download: ML20214T924 (7)

Text

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ARKANSAS POWER & LIGHT COMPANY POST OFFICE BOX 551 UTTLE ROCK, ARKANSAS 72203 (501)371-4000 September 10, 1986 2@SDWM  %

BCAN098605 S@23E Mr. J. E. Gagliardo, Chief -

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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 Report 50-313/86-21 and 50-368/86-22

Dear Mr. Gagliardo:

The subject report has been reviewed. A response to the Notice of Violation is attached.

Very truly yo rs, fAw J. Tg os, Manager Nuclda Engineering and Licensing JTE/RJS/sg Attachment 13 /

06093OO4h PDR ADO hO PDR 0\

Y' t h133/% MEMBER MIDDLE SOUTH UTIUTIES SYSTEM

p s s NOTICE OF VIOLATION During an NRC inspection conducted during the period June 1-30, 1986, violations of the NRC requirements were identified. The violations involved failure to follow a post-maintenance procedure and failure to document safety eva'luations as required by 10 CFR 50.59. The specific findings and

' Arkansas Power and Light's response to each violation are listed below.

A. Unit 2 Technical Specification 6.8.1.C requires,'in part, that written procedures shall be established, implemented, and maintained for test activities of safety related equipment.

Procedure 2403.53, " Unit 2 Class IE Battery Charger Load' Test," has been established in'accordance with this requirement. This procedure requires that battery charger 2D34 be connected to DC Bus 2001 or 2D02 during its load test.

Contrary to the above, on June 27, 1986,- battery charger 2D34 was being tested following maintenance without using the lineup specified by the procedure. The battery charger was not connected to.either DC bus, and the power leads from the battery charger to DC Bus 2D02 were lifted. A temporary procedure change to permit this lineup had not been initiated.

This is a Severity' Level IV Violation. (Supplement I.D.)

(50-368/8622-02)=

RESPONSE

The technician who performed the load test had been troubleshooting the battery charger and had lifted the power leads to the charger output breaker to ensure that it was not tied to the bus. No caution tags were attached as would have been appropriate for jumper and lifted leads. When the test was performed, he assumed that he could run the test with the chargar off-line

based on the breaker from 2D34 to 2002 being open for troubleshooting.

However, he failed to recognize that a temporary procedure change should i have been accomplished prior to performing the test-in this configuration.

l The test, as performed, did accomplish its purpose.

! Because the test is an 18-month' surveillance and will normally be performed

-with the battery charger disconnected from the DC buses, the procedure has been revised to reflect this configuration. As there was confusion I

concerning the need for a temporary change to the procedure, training for the technicians on adherence to procedures has been conducted.

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[ l B. 10CFR50.59(b) requires the licensee to maintain records including written safety evaluations which provide the bases for the determination that changes to the facility, changes to procedures, and tests or experiments do not involve an unreviewed safety question.

Contrary to the above, for one test procedure and five design change packages reviewed, there were.no written safety evaluations which provided the bases for the determination that no unreviewed safety questions were involved.

This is a Severity Level IV Violation. (Supplement I.D.)

(50-313/8621-01)

RESPONSE

As pointed out in the body of the inspection report, AP&L is in the process of improving the quality of the 10CFR50.59 evaluations associated with design and procedure changes which affect the Safety Analysis Reports (SARs) and for those tests and experiments not described in the SARs. This program was internally initiated in response to management's desire to improve both the quality and documentation of the evaluations. To date, significant progress has been made towards the implementation of this program. While we agree our current program can be improved, as evidenced by the implementation of the above described program, we do not believe our current practices are in violation of 10CFR50.59.

As was cited, 10CFR50.59 requires a written safety evaluation be documented in support of the no unreviewed safety question determination. AP&L contends that written safety evaluations were provided for each of the modifications reviewed as a part of NRC's inspection. In each case the three questions from 10CFR50.59, which determine if the proposed

' modification constituted an unreviewed safety question, were addressed through the use of a standard form. A brief written basis for the appropriate answers to these questions was also provided. The answers along with their written bases are a summary of the evaluations contained in the design or procedure change package and constitute a written safety evaluation. One of the intents of our improvement program is to have the reviewer consolidate all pertinent evaluations in the form of a single comprehensive 10CFR50.59 evaluation.

The procedure reviewed by the inspector and cited in the violation, involved a post modification test of the emergency feedwater motor-driven pump to verify its performance following major modifications to the system. As the equipment was not required by the Operating License to be in service (the plant was in cold shutdown) it could be argued that a 10CFR50.59 evaluation was not required. However, an unreviewed safety question determination was performed for the original issue of the procedure. This determination included the three questions which address the criteria for an unreviewed safety question per 10CFR50.59.a.2. A basis for determination was provided as follows:

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"This test is being performed to verify performance of pump P7B after completion of modifications to the EFW system affecting P7B. The test is being performed with the RCS in a cold shutdown condition and does not place the RCS in an unsafe condition. No special test exceptions to the Technical Specifications are required.

Modifications to the EFW system are described in DCP-80-1083 and its amendments. During performance testing, normal plant safety procedures and technical specifications will be in effect."

A subsequent change to the test procedure described above was reviewed by the inspector and cited in the violation. The procedure modification did not change the intent of the test method; therefore, the unreviewed safety question determination was not revised.

Concerning the five design changes, each one included a Safety or Environmental Determination Form (202F9) as required by the Design Process Procedure. This form provides a basis as to why an unreviewed safety question does not exist, both using a checklist which addresses the criteria involving an unreviewed safety questions of 10CFR50.59.a.2, and a written justification. It also includes a section for document references applicable to specific questions. AP&L contends that this form meets the requirements of 10CFR50.59.b for maintaining records of written safety evaluations which provide the bases for the determination that the changes do not involve unreviewed safety questions. Below is a description of the safety evaluation for each of the five DCPs:

1. 81-1080A, Modification of Diesel Generator Voltage Shutdown Device -

This amendment to DCP-81-1080, which also included a safety determination, provided the. mechanical design portion to accomplish the change. The change supplies a means for taking manual action which will enable start of the emergency diesel generators in the event of a complete station blackout (loss of AC and DC power). This amendment did not degrade the ability of any system to perform its intended function.

2. 83-1007, Provide Disconnect Switch for "B" Service Water Pump - The three questions for an unreviewed safety question determination are answered, and a written justification for the answers is provided. This

identifies the change as addition of a power switching center, cable reroutes, and fire barrier wraps to address Appendix R concerns relating to service water pumps. No other changes were made by this DCP. Seismic concerns, missile source potential, and water spray or flooding protection of the power switching center were discussed.

3. 83-1012, Provide Isolation Device for Pressurizer ERV Block Valve - The three questions for an unreviewed safety question determination are answered, and a written justification for the answers is provided. .The DCP improves the plant safety by adding provisions for separation of the block valve remote controls to upgrade its reliability. This is related to Appendix R. Applicable FSAR sections are referenced.

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4. 83-1107, Acoustic Valve Monitoring System Replacement - The three questions for an unreviewed safety question determination are answered, and a written justification for the answers is provided. The modification replaced the line drivers and associated cabling in the acoustical valve monitoring system with environmentally qualified amplifiers and splices. This.did not degrade the ability of the system to directly indicate and alarm the position of the safety relief valves.

5. 83-1170, LPI Flow Indication, HPI Flow Indication, Containment Spray Flow - The three questions for an unreviewed safety question determination are answered, and a written justification for the answers is provided. The instrumentation loops replaced are for monitoring purposes and are Seismic Class 1 as required.

Though these justifications are brief they summarize why an unreviewed safety question is not created by the n.odification. The specifics as to how the modification is accomplished and how the interrelated considerations'are addressed are detailed in other sections of the design change package. Very thorough descriptions are included in all five of.the DCPs reviewed by the inspector. These support the safety evaluation, and the complete design change package records are maintained as required by 10CFR50.59.b.

AP&L is unaware of any guidance documents published by the NRC which specify the format or content of a written safety evaluation. This aspect of AP&L's operation has been reviewed by the NRC on numerous occasions in the past (See attached summary of previous inspection findings.). In each case our program has been found to be in compliance with 10CFR50.59.

As previously discussed with you and your staff, AP&L had identified internally the desirability of enhancements to the 10CFR50.59 review process. A policy document detailing AP&L's intended implementation.of this regulation has been developed along with a supporting training program.

Initial training for selected personnel was begun in August of this year.

This program includes guidance on the format and extent of supporting documentation.

While this program is expected to result in significant improvements in our 10CFR50.59 review process and improve the consistency of accompanying documentation, we believe our current program is in compliance with regulations in this regard.

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f ATTACHMENT

- 313/8317, 368/8317 - The results of the overall design control program / interface review and the results of the review of fifteen DCPs were that " established procedures provide for review and approval of design changes consistent with the review and approval of the original design as required by Regulatory Guide 1.64 (ANSI N45.2.11) and also provide for a safety evaluation as required by 10 CFR Part 50.59 to determine if prior NRC approval is required." The report indicated that for the documents examined, procedural requirements for 10CFR50.59 were being implemented.

- 313/8415, 368/8415 - The purpose of this inspection was to verify that design changes and modifications were in conformance with the requirements of the Technical Specifications, industry guides, and 10CFR50.59. A total of seven DCPs and three design control procedures were reviewed. There was no indication that the requirements of 10CFR50.59 were not being met.

- 313/8507, 368/8507 - Two design changes were reviewed. It was verified that these DCPs "were reviewed and approved by the licensee in accordance with 10CFR Part 50.59 and with licensee procedures."

- 313/8516, 368/8517 "An inspection was conducted to verify that the licensee's overall plant procedures are in accordance with regulatory requirements" and included a review of the procedure control program as well as thirteen operating procedures. The procedure control program delineates the 10CFR50.59 applicability and unreviewed safety question determination requirements.

- 313/8522, 368/8523 "The NRC Inspector performed a review of the design change program. This review was performed to verify that design changes were made in accordance with Technical Specifications, industry guides and standards, 10CFR, and plant procedures." Sixteen safety-related and a sampling of non-Q DCPs were reviewed. One of these DCPs 1080, Emergency Diesel Generator Field Winding Shutdown Shorting, - is one of the DCPs reviewed in the scope of the cited violation. The safety-related DCPs were reviewed to assure that " review and approval was in accordance with the requirements of 10CFR Part 50.59 and the reviews were technically adequate."

The NRC Inspector also reviewed plant procedures to verify that procedures properly implemented the requirements of the Technical Specifications, 10 CFR, industry codes and standards, and the QA Manual and identified no problems in this area.

- 313/8523, 368/8524 - Nine DCPs were reviewed to assure that " review and approval was in accordance with the requirements of 10CFR Part 50.59 and the reviews were technically adequate." No problems.in this area were noted.

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- 313/8611, 368/8611 "During this inspection, the NRC inspector conducted a review of the licensee's design change and modification program to determine whether the licensee is implementing a QA program relating to the control of design changes and modifications that are in conformance with regulatory requirements, commitments in the application, and industry guides and standards." The findings indicated that "the AP&L design changes and modifications program appears to provide the essential design change requirements as specified by regulatory requirements, commitments by the licensee, approved licensee procedures and industry guides and standards."