IR 05000313/1988036
| ML20246J155 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 05/10/1989 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Campbell G ARKANSAS POWER & LIGHT CO. |
| References | |
| NUDOCS 8905170002 | |
| Download: ML20246J155 (2) | |
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L, In Reply Refer To:
' Dockets:
50-313/88-36 L
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L 50-368/88-36'
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Arkansas Power & Light Company i
. ATTN: Mrc Gene; Campbell Vjca Pr?sident,' Nuclear Operations P.O. Box 551-Little Rock, Arkansas 727.03
Gentlemen:
Thank.you.for your letter of March 10,1989,-in response.to our letter and
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Notice of Vichtion dated February 10,1989. 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
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dete.rrine that full. compliance has been achieved and will be maintained.
Sincerely,
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Original SJgned By L. J. Callan L. J. Callan, Director Division of_ Reactor Projects cc:
' Arkansas Nuclear One ATTN:
J. M. Levine, Executive Director, Nuclear Operations P.O. Box 608 Russellville, Arkansas 72801 j
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Arkansas Radiction Control Program Director bec'w/ attachment:
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R. D. Martin, RA-RPB-DRSS Section Chief (DRP/A)
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ARKANSAS POWER & LIGHT COMPANY !
March 10, 1989 (! ( ~~~~ ~' ~ '
lL ! MAR i 31989
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BCAN038902 L
J. Callan, Directcr Divisi-on of Reactor Projec'cs
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U. S. Nuclear Regulatory Connittian Region IV 611 Ryan Plaza Drive, Sui'.e 1000 Arlington, Texas 76011 SUBJECT:
Arbntas Nuclear One - Units 1 and 2 Decket Nos. 50'313/50-368
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Licente Nos. DPR-51 and NPF-6 q
Respoi.se to Inspection Report
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50-313/88-35 and 50-368/68-36 Dur Mr. Callan:
Pursuant to the prmisions of 10CFR2.201, a response to the violations identified in the subject inspection report is subraitted.
Very truly yours,
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evine xecutive Director uclear Operations JML: PLM:vgh enclosure i
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U. S. Nuclear Regulatory Commission f
Docuinent Control Desk Washington, D. C.
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Enclosure to BCAN038902
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March 10, 1989
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Page 3 of 3
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Radioactive Material Transportation Part 71.5(a) of 10 CFR requires that each licensee who transports licensed material outside the confines of its plant shall comply with the applicable requ'irements of tne Department of Transportation (D0T) regulations appropriate to the mode of transport in 49 CFR Parts 170 through 189.
Part 173.425(b)(1) of 49 CFR requires that material mut,t be packaged in strong, tight packages so that there will be no leakage of radioactive inaterial under conditions normally incident to transport.
Contrary to the above, on November 3, 1988, the licensee made a shipment of licensed radioactive material in a package that was not a strong tight packages This is a Severity Level IV violation.
(Supplement V) (313/8836-03; 368/8836-03)
Response to Violation 313/8836-03; 368/8836-03 (1) ]_he reason for the violation if admitted:
AP&L does admit that the violaticn occurred as stated abcve.
The reason that the packags was not properly secured for tunsport is personnel error in that the Radwaste Supervisor did not follow procedural requirements for assuring proper packaging.
(2) The corrective steps which have oeen taken and the results achieved:
The Radwaste Supervisor was verbally reprimanded and counselled concerning his responsibilities and the failure to assure proper securing of the package.
Additionally, the violation was discussed with the radwaste staff in a meeting subsequent to the event.
The controlling procedure wss reviewed and determined to be adequate for assuring proper packaging if followed by responsible personnel.
(3) The corrective steps which will be taken to avoid further violations:
I We believe that the actions taken as described aboye will prevent g
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further violations in this area.
t (4) The date when full compliance will be achieved:
Full compliance was acnieved November 7, 1988, when the package was received by the reactor services facility.
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Enclosure to dCAN038952
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March 10, 1989
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(3) The corrective steps which will be taken to avoid further violations:
With the actions taken as described above, the tracking and controlling of job orders with outstanding ilocument Discrepancy Notices, while undar the control cf the Nuclear Quality department, should be adequate to prevent further violations in this area.
The records management procedure indicates that each department manager has the responsibility to ensure that documents generated by his section are transmitted to Records for record retention.
Documents in review are the responsibility of each department manager; therefore, each department ic responsible for tracking and controlling documents while being reviewed by his department. We have not identified a generic concern with lost records in other departments; however, a memorandum will be issued by March 31,
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1989, to all department managers providing the details of this violation and the &ctions taken by the Nuclear Quality department.
(4) The date when full compliance will be achieved:
The procedure revision for QC0-2 was approved November 30, 1988, and the improved tr&cking was implemented, achieving full compliance.
Additional Information AP&L has corcerns with the violation as written, based on Regulatory Guide (RG) 1.88 and ANSI N45.2 with regard to the requirements of procedure QCO-2.
These concerns, as presented below, were previously discussed with Mr. Dennis V,elley of your staff and members of rry Plant Licensing staff on February 22 and 24, 1989.
Specifically, AP&L believes the refereces to control of records in accordance with RG 1.88 and ANSI N45.2.9 are inappropriate for citing a violation against implementing procedure QC0-2.
This procedure is an internal departmental procedure which prov$ des guidance to the Quality Engineering Group for review of documents and is not intended to address document control applications.
Plant administrative procedure " Records Management" describes the application of the requirements of R3 1.88 and ANSI N.45.2.9.
However, even in accordar.ce with this procedere, documents in the process of being reviewed are not considered to be subject to the requirements of RG 1.88 and ANSI N45.2.9.
The portion of procedure QCO-2 addressed in the violation related to the closeout review of job orders.
Tho job orders with outstanding Document Deficiency Notices against them were still under review and, therefore, not subject to the requirements of RG 1.88 and ANSI N.45. _
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- Enclosure to SCAN 038902
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Contrcl of Job Order Review Process Part 50, Appendix B, Criterion V states, in part, that " Activities affecting quality shall be prescribed by documented instructions, procedures, cr drawings, of a type' appropriate to the circumstances."
Chapter 17.1.1 of the approved quality assurance plan requires that i
the control of records be in accordance with Regulatory Guide 1.88, Revision 2 of October 1976, which endorses ANSI N45.2.9-1974.
Contrary to the above, the implementing procedure QC0-2-QE, " Document Review," does not address the tracking and controlling of job orders with outstanding document deficiency notices written against them.
This is a Severity Level IV violation (Supplement I) (313/8836-04; 368/0836-04)
Response to Violation 313/8836-04; 368/8836-04 (1) The reason for the violation if admitted:
Although AP&L has concerns with the violation as written, which are discussed in an Additional Information Section following this response, AP&L does admit that process weaknesses in completed work documentation control resulted in a violation.
Specifically, that permanent plant I
records (e.g., certain job orders) required to be maintained by Technical Specification are apparently lost.
Regarding the job order packages reviewed during the inspection, several of these had been outstanding for an inordinate length of time, and, in fact, two of the job orders could not be located during the inspection (and have subsequently not been located and are apparently lost).
As such, a weakness did exist in procedure QCO-2 with regard to tracking and controlling job orders returned to the work groups for correction of document deficiencies.
The reason this weakness existed was that procedure QC0-2 did not contain provisions for formal transfer of the
documents to the work groups and did not contain provisions for a formal review of the status of the job orders with outstanding Document
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Discrepancy Notices.
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(2) The corrective steps which have been taken and the results achieved:
A procedure revision for QC0-2 has been issued which provides a more extensive method of tracking and controlling job order packages with outstanding document review discrepancies.
A list of outstanding documents is maintained and reviewed periodically to identify the job order packages and the time period each has been outstanding.
Memorandums are to be issued to departments when the packages have been outstanding for over 60 days, and are subject to higher levels of management for resolution.
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