ML19257B757
| ML19257B757 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/13/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19257B751 | List: |
| References | |
| 50-313-79-16, 50-368-79-14, NUDOCS 8001180264 | |
| Download: ML19257B757 (3) | |
Text
,
ENCLOSURE 1 NOTICE OF VIOLATION Arkansas Power and Light Company License Nos. DPR-51
& NFP-6 Based on the results of the NRC inspection conducted on July 30 through August 10, 1979, it appears that certain of your activities were not in full compliance with NRC requirements as indicated below.
These items have been categorized as described in our correspondence to you dated December 31, 1974.
A.
10 CFR 50, Appendix B, Criteria V, Instructions, Procedures, and Drawings, and Section 5 of the Quality Assurance Topical Report (APL-TOP-1A, Rev. 4) requires that activities affecting quality be prescribed by documented procedures and accomplished in accordance with those procedures.
The licensee's procedure controlling the issuance and revision of drawings, Procedure 1004.23, Drawing Document Control, required in Paragraph 4.5 that " Drawings shall be revised and issued indicating as a minimum all system changes which have been made which affect system alignments or procedures.
Such drawings should be issued and distributed even though changes may not be complete by at least seven days prior to placing the altered system into service.
If system changes are incomplete, these affected portions of such drawings will have notations to that effect."
Contrary to that procedure, a Unit 1 safety related as-built drawing, M-231, was not revised and issued following the implementation of Design Change Request 79-1001, Small Break ECCS Redesign.
This change involved the addition of several valves and new piping on the combined makeup and high pressure injection system.
The change resulted in both a procedure revision and a new system alignment.
Installation and acceptance testing was completed in May 1979.
Subsequent to this modification the plant was operated.
This is an infraction.
B.
Unit i Technical Specification (TS) 6.4.1 and Unit 2 TS 6.4.1 requires the licensee to maintain a retraining and replacement training program for the facility staff which meets or exceeds the requirements and recomm ndations of Section 5.5 of ANSI N18.1-1971.
Section 5.5 of ANSI N18.1-1971 states that a training progra. shall be established which maintains the proficiency of the operating organization through periodic exercises, instructions, reviews, and special training sessions.
It further states that the program should provide means for evaluating the effectiveness of the training program.
Contrary to the above:
1.
The licensee had not implemented (maintained) the ANO Training Plan as described in the following:
1769 352-8001180 f
.1h
a.
Training records of selected Maintenance Group personnel contained no documentation of on-the-job training.
b.
A maintenance mechanic employed with the licensee since January, 1979 had received no technical training lectures.
c.
A health physics technician and a maintenance mechanic had not received the required Quality Assurance Indoctrination.
d.
The training records of four Maintenance Group individuals did not document the required systems training.
2.
The Training Plan contained no retraining requirements for any of the following:
a.
The Maintenance Group b.
The Technical Support Group c.
Auxiliary Operators d.
QC Engineers and Inspectors e.
Engineers f.
Supervisors 3.
The Training Plan did not provide means for evaluating the effectiveness of the training program.
This is an infraction.
C.
Unit 1 TS 3.1.1.3A states that the reactor shall not remain critical unless both pressurizer code safety valves are operable.
Contrary to the above, the reactor was operated subsequent to the March 24, 1978 testing of code safety valve PSV-1002 which was left with a setpoint in excess of that given in the Bases of TS 3.1 and in the acceptance cri-teria in the test procedure.
This is an infraction.
D.
Unit 1 and Unit 2 TS 6.5.2.7a requires the Safety Review Committee (SRC) to review the safety evaluations for changes to equipment or systems completed under the provisions of 10 CFR 50.59 and to verify that such actions did not constitute an unreviewed safety question.
Additionally, Unit 1 and Unit 2 TS 6.5.2.1 requires the SRC to perform the above described review independently.
Contrary to the above, independent reviews had not been performed.
The Manager of Licensing had in-line responsibility for preparing the initial 10 CFR 50.59 review on design changes and was assigned to perform the SRC independent review of the same evaluations.
This is an infraction.
1769 353
E.
Unit 2 TS 6.5.2.8.b requires SRC audits to enceupass the performance, mining, and qualifications of the entire unit staff once a year.
Contrary to the above, the SRC did not audit non-licensed training.
This is an infraction.
F.
Unit 1 TS 6.5.1.7.1.b and Unit 2 TS 6.5.1.7.b requires the Plant Safety Committee (PSC) to render determinations in writing with regard to whether or not procedures reviewed in accordance with Unit 1 and Unit 2 TS 6.5.1.6.a constitute an unreviewed safety question.
Contrary to the above, the PSC did not make written safety evaluations or render determinations in writing with regard to whether or not the proce-dures reviewed constituted an unreviewed safety question.
This is an infraction.
G.
10 CFR 19.12 requires that the licensee shall instruct employees in their responsibility to promptly report to the licensee any condition which may result in a violation of regulatory requirements or unnecessary exposure to radiation or radioactive material.
Contrary to the above, the licensee had not instructed its employees as required.
This is a deficiency.
1769 354
.... -. -.