IR 05000313/1986018

Ack Receipt of 860829 & 870311 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-313/86-18 & 50-368/86-19

ML20205K884
Person / Time
Site:	Arkansas Nuclear
Issue date:	03/27/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Campbell G ARKANSAS POWER & LIGHT CO.
Shared Package
ML20205K887	List: 0CAN038707, Responds to NRC Re Suppl Info for Insp Repts 50-313/86-18 & 50-368/86-19 on 860725.Concerns Re Deficiencies Found in Procedures Discussed W/Staff & Improvements to Procedural Requirements Program Underway IR 05000313/1986018 ML20205K884
References
NUDOCS 8704020061
Preceding documents:	ML20207N244 (9 January 1987)
Download: ML20205K884 (1)

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EAR 2 71987 -

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! In Reply Refer To:

Dockets:- 50-313/86-18

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50-368/86-19

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Arkansas Power & Light Company l ATTN: Mr. Gene Campbell Vice President, Nuclear l Operations P. O. Box 551 Little Rock, Arkansas 72203 Gentlemen:

Thank you for your letters of August 29, 1986, and March 11, 1987, in response to our letters and Notice of Violation dated July 25, 1986, and January 9,1987. 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.

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Sincerely, I

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Orlz?nd sivua 2, '

J. E. Gca!!ardo ,

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 bectoDMB(IE01) $$40jDobk!OS$313 O PDR , .

bec distrib. by RIV:

RPB RRI R. D. Martin, RA R&SPB SectionChief(RPB/B) D. Weiss, RM/ALF-RIV DRSP RSB MIS System RSTS Operator Project Inspector R. Hall .

PI C:RPBh C:RPB -

h ME urphy cs QRHunter JEGagl do / I

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3/77/87 3A7/87 3/4187 ,

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AAKANSAS POWER & UGHT COMPANY

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POST OFFICE BOX 551 UTTLE ROCK. ARKANSAS 72203 (501) 3714000 ,.

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August 29, 1986

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50l@20W2W SCAN 088614 fJj SEP -81506 fj Mr. J. E. Gagliardo, Chief L 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 j-

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License Nos. DPR-51 and NPF-6

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Response to Inspect.on Report 50-313/86-18 and 50-368/86-19

Dear Mr. Gagliardo:

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

Very truly yo s, f f^- ~

y J. T os, Manager Nuc)ea Engineering and Licensing JTE:RJS:lw Attachment

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NOTICE OF VIOLAT10N ,

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DuringanNRCinspectionconductedduringtheperiodMa/h31,N986, M .J#V, ' I

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violations of the NRC requiremamts were identified. Th.: violations involved pM ! ,,'j failure to lock a manual valve. in position as requirsd ', fe'flure to heee adequate controls over the installation of temporsry sc /fsids in the j

vicinity of safety-related eq',ipment, and 'f ack o/ calibrt. tion data tha*. g/[, g l.

would demonstrate the accuracy of measurement'of,the admixture liquW l' dispenser being utilued at the concrete supplier's facility. The specific finaings and AP&L's rasponse to each are listed below. ..

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. t; A. 10 CFR 50, Appendix B.0triterion-V Mates, in part, "ActiviUes affecting quality shall be prescrited by documented instructions, ,

procedures, ... of a type appropriat'e to the circumstances and shall be ,,

accomplished in 'accordance with thesa instructions;jreteJures. ... ANO /

procedures 1000.04, " Procedural Program Requirements," Movisiod 20, jnd -

- 1000.06, " Procedure Review, Approval, and Revision' Control," Revis hn ,l'  !

l 22, implemented these requirements.. '

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t pary to the above, c .*,usber of deficiencies were foundin ver fus i procedures which could result in perfn mence errors. The following are 1  ;

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y i 1. The last sentence in paragraph 5.2.2 of roceduce 1000.09,?

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_;,,,. " Surveillance Test Program Control " is prammatically inc'or m.t ,

j and should be considered for deletion. Paragraph 6.2,3 conttins ,

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the accurate statement. Additionally, paragraphs.6.2.6 and 6f.l '

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} referred to nonexistent procedutas. i

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2. Pages 22.end 24 of Attachovnt 2 te procedure 1022.06, "ASME Codo >

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Section'XI. Insoryice Testing Program Unit 1," were incorrect? ,

The correct informativ. (pa{e 24) was not included. , ,  ;

l 3. Paragraphs 2.0, 3.0, and 3.3 of p?ocedure 1032.07, ."ISI Program f ,\ \ i'\. '

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Requirements," do+it net referent.w',oracedure'1022.tfr (Unit 2) even '

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though procedute IM2.07 was writ, ten for3oth unit's. 5. l \

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l 4. Forms 1000.068 ar.d 1000.06C in prore' dure 1000.06 ,"hscedure i I Review, Approval,, and Revision CoM,rol," scntained wording in the ,

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10 CFR 50.59 applicability, felock that stated, in part; involves a change to a itest or experiment" insted of " involves ) tset or I l

i 1, experiment" which would be consistent Mth the 'lar.2ual,e in 10 CFR i j 50.59,  ; I f

l 5. Question 2 in Form 1000.06E read, in part, "vould the ,r,coposed i procedure change ... ." which does not addren the fan tlat

! 10 CFR 50.59 applies to both proposed prossdures and t.harges. -

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i This is a Severity Level V violatlon. F

! 368/8619-02)  ;

(Supplement ) 1.E)

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8. 10 CFR 50.59(b) states, in part, "The licensee shall maintain records o

of changes in the facility and of changes in procedures made pursuant to this section ... The licensee shall furnish ... annually or at such shorter intervals as may be specified in the licensee, a report containing a brief description of such changes, tests, and experiments, including a summary of the safety evaluation of each."

i Contrary to the above, the licensee failed to submit a report of activities for the years 1984 and 1985.

This is a Severity Level V violation (supplement I.E.) (313/8618-01; 368/8619-01)

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RESPONSE The preparation of the 1984 10CFR50.59 report was more extensive than in the

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past to ensure that the report contained more detailed summaries of the activities performed under the guidance of this regulation. This effort required additional coordination between Licensing and the groups who performed the safety evaluations. However, the result was a more accurate reflection of the activities that occurred during 1984. Additionally, both l the 244 and IR6 refueling outages began in 1984, during which an unusually large number of design changes, processed under the provisions of

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10CFR50.59, were implemented.

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The 1984 Summary Report has now been completed and was issued to the NRC July 15, 1986 (OCAN078604). The 1985 report, which will also contain the more detailed summaries, is currently being prepared for issuance by September 18, 1986.

In recognition of the problem of timely submittals and in an effort to make

. program improvements while maintaining the quality of the reports. AP&L is currently undertaking corrective action to develop a more efficient and systematic means of compiling 10CFR50.59 Summary Reports to avoid such delays. Actions include additional staff guidance on tracking, compiling and reporting 50.59 affected changes. These actions should ensure timely reporting in the future.

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RESPONSE The specific examples cited in the violation are discussed below:

1. The specific paragraphs of the administrative procedure 1500.09,

" Surveillance Test Program Control," noted in the violation are provided below:

"6.2.2 Surveillance tests that are the scheduling responsibility of WCC are controlled by this procedure. This includes most tests with a test frequency of once per week or longer. Those tests of shorter frequency are scheduled by responsible departments should be controlled by departmental procedures."

"G. 2. 3 Surveillance tests that must be performed more than once per week are scheduled by the responsible department and should be governed by departmental procedures."

The last sentence of paragraph 6.2.2 lacks the word "and" to be grammatically correct and will be revised accordingly. As noted in the violation, " Paragraph 6.2.3 contains the accurate statement." AP&L

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contends that no performance error would have resulted as procedures

7.- are utilized as complete documents and the noted paragraphs would not

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be taken out of context of the complete procedure.

The nonexistent procedures cited in the violation, specifically paragraph 6.2.6 which references procedure 1015.06, "ASME Code Section XI Operational Readiness Testing," and paragraph 6.2.8 which references procedure 1005.01, "M&TE Calibration Program," do in fact exist but have been assigned different numbers under a reorganization of administrative procedures. Paragraghs 6.2.6 and 6.2.8 will be revised to reference the appropriate procedure numbers. AP&L does not have an automatic system that identifies all cross referenced procedures. Several methods do exist for a user to correctly locate cross referenced procedures. As an example, the procedure tab in the station procedure manual for procedure 1015.06 contains a form which informs the user of this procedure's deletion and references the i appropriate replacement procedure number. Additionally the ANO Document Control System contains the information needed to establish the chronolagy of procedure issuance, deletion,' renumbering, etc., to establish necessary cross referencing. AP&L co'n tends that the needed procedure cross referencing updates cited, though desirable from an ease of use perspective, would not have resulted in performance errors.

2. As noted in the Inspection Report, a reproduction error was made during procedure 1022.06, "ASME Code Section XI Inservice Testing Program ANO-1," copying for distribution. The data contained on page 24 of the l procedure was a duplication of the data contained on page 23 of the t- proceduro. This error was made when the data pages were reduced onto the procedure form pages. Page 23 contained the correct data. The correct data for procedure page 24 of the current revision has now been distributed. This administrative procedure provides an overall I

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description of the ANO-1 Inservice Testing Program and does not control pump and valve testing. Actual in-service testing of pumps and valves is performed utilizing plant operating procedures; therefore, AP&L i contends this error would not have resulted in a performance error of the testing program. ..

3. Procedure 1022.07, "ASME Code Section XI Inservice Testing Program ANO-2," was originally issued on August 24, 1985. The current revision of 1032.07, "ISI Program Requirements," was effective August 1, 1985. Therefore, procedure 1022.07 was not issued prior to the last revision of 1032.07. The noted paragraphs of procedure 1032.07 cited in violation as not containing a reference to procedure 1022.07 were

paragraphs 2.0, 3.0 and 3.2. Paragraph 2.0 of procedure 1032.07 l details the scope of the procedure, specifically that "The pump and l valve test program to meet Section XI of the ASME Code is not addressed

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by this procedure, but rather is covered by procedure 1022.06 ...."

Paragraph (section) 3.0 of procedure 1032.07 details the references used to develop procedure 1032.07 in paragraph 3.1 and related ANO administrative procedures in paragraph 3.3. Procedure 1032.07 paragraph 3.2 does not require a reference to procedure 1022.07.

Procedure 1022.07 is not required for implementation of procedure 1032.07. Appropriate references to procedure 1022.07 will be added to procedure 1032.07. AP&L contends that the omission of the references to procedure 1022.07 would not have resulted in a performance error of

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.,- i t- the Inservice Inspection Program requirements. Additionally, procedure 1

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1032.07 is an administrative procedure which describes the program and is not a performance procedure.

4. Form 1000.068, Procedure / Work Plan Request, is designed to provide a description of the purpose or reason for procedure development or procedure revisions. It also documents the review and approval process as delineated in procedure 1000.06. Form 1000.06C, Temporary Procedure Change Request, is designed as a method for temporary changes to procedures. It is not applicable to original procedure development.

The 10CFR50.59 applicability section of these two forms is formatted to determine if an unreviewed safety question evaluation is required by use of the following questions:

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Involves a change to a procedure described in the FSAR YES NO

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Involves a change t, ' test or experiment not described in the FSAR YES NO

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Involves a change that affects compliance with the Technical

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'YES NO I These forms are utilized for original procedure review but are primarily structured for procedure changes. The wording of these three I questions reflect this structure, and this should be recognized by the l

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procedure reviewers. For an incident in which a new procedure is developed to perform a test or experiment not the FSAR and the procedure writer misinterprets the question, the review process would identify the error and return the procedure to the writer. This process, by its basic design, would prevent performance errors from resulting in approval procedure without the proper evaluation for an j unreviewed safety question, f 5. Form 1000.06E, Unreviewed Safety Question Determination, is designed to document an evaluation of a procedure or a procedure change for an unreviewed safety question. The form consists of seven yes or no questions which directly paraphrase the guioance of 10CFR50.59.a.2.

Each question begins with the phrase "Would the proposed procedure or change" except that in question 2 the word "or" has been inadvertently omitted. Because the questions are applicable in the same sense to a procedure or procedure change as directed by procedure 1000.06, the procedure writer should answer the question appropriately. In fact, without the word "or" in the question, for a new procedure a yes or no answer would not be applicable. AP&L contends that this would not result in a performance error and that even if it was misinterpreted by the procedure developer, the review process would prevent a performance error from resulting in an approved procedure with an inadequate evaluation.

]S-' As the Inspector only speculated that performance errors could have resulted and did not substantiate this inference in the scope of the inspection, AP&L does not agree that a violation of 10CFR50, Appendix 8, Criterion V has occurred.

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