IR 05000313/1986016

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-313/86-16 & 50-368/86-16

ML20210C518
Person / Time
Site:	Arkansas Nuclear
Issue date:	09/16/1986
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Campbell G ARKANSAS POWER & LIGHT CO.
References
NUDOCS 8609180356
Download: ML20210C518 (2)

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i SEP 16 EE ( In Reply Refer-To:

Dockets: 50-313/86-16 50-368/86-16 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 August 15, 1986, in response to our letter and Notice of Violation dated July 16, 1986. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.

Sincerely,

Nnal Signed byp 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 bec: (see next page)~

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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 Responseto{andspection 50-313/86-16 Reports 50-368/86-16

Dear Mr. Gagliardo:

Pursuant to the provisions of 10CFR2.201, the subject reports have been reviewed. A response to the Notice of Violation is enclosed.

Very truly yours, si(< f p mw -

J. Ted Enos, Manager C7 Nuclear, Engineering and Licensing JTE/RJS/sg Enciosure

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Notice of Violation Failure to Implement Current Procedures ANO Units 1 and 2 Technical Specifications 6.10 and 6.11 respectively, require, in part, that " Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure."

Contrary to the above, the NRC inspector determined on flay 21, 1986 that an obsolete procedure was being used for the setup and operation of a personnel thermolumines ent dosimetry reader.

This is a Severity Level IV violation. (Supplement I) (313/8616-01 and 368/8616-01).

Response This violation resulted primarily due to utilizing a secondary work station located remotely from the primary dosimetry work station as a result of overcrowding in the area. The dosimetry supervisor maintains a set of procedures related to his area of responsibility and had received.the procedure change to the dosimetry reader procedure and instructed a technician to incorporate the change into the required reading for the technicians, believing that this would alert the appropriate personnel that a form change had occurred. These actions had not been accomplished by the time of the inspection. Forms at the primary work station were correct because technicians at that station routinely obtained copies of forms from Document Control located in close proximity. However, at the secondary work station, there is no controlled form file to utilize and forms were copies from existing forms resulting in continued use of an out-of-date form. The secondary work station has obtained copies of the correct revision of the procedure and forms and is in full compliance.

AP&L has methods of procedure distribution control that were available to the dosimetry supervisor and technicians that would have informed them that a procedure or a form had been revised. These methods were utilized in part through assignment of a set of procedures to the dosimetry supervisor. In order to prevent recurrence of similar violations, a second set of procedures has been assigned to the dosimetry supervisor to be located at the secondary work station. Additionally, both the primary and secondary work stations will be on distribution for appropriate forms used in the performance of their work. This will ensure that any revision to a form is brought to their attention within a few days of the revision date which is an acceptable time limit for procedure distribution other than control room copies. This incident is believed to be an isolated occurrence due to the use of a secondary work station and is not applicable to other plant groups.

e fe, Regarding the severity level of the violation, AP&L takes exception to categorizing this as severity level IV. The procedure revision was of minor significance involvic.g the addition of a space to record informational data.

The previous procedure revision recorded six data points (two sets of three values). This data was averaged to determine two mean values which were recorded on the data sheet. The procedure revision provided a space to record the total of the two sets of three values prior to calculating the mean values. This revision in no way changed the calibration process or results and sufficient information was already contained on the data sheets to reproduce the additional calculational values recorded. AP&L believes this violation to be insignificant with regard to safety or environmental significance utilizing the criteria of 10CFR2, Appendix C, and requests this violation be categorized appropriately as a severity level V violation.