ML19273B892

Responds to NRC 790602 Order to Review Safety Procedures & Methods for Development.Appropriate Steps Will Be Taken to Ensure Personnel Adherence to Proper Procedures & Avoid Bypassing Procedures Excluded in 790602 RO

ML19273B892
Person / Time
Site:	Arkansas Nuclear
Issue date:	06/12/1979
From:	Cavanaugh W ARKANSAS POWER & LIGHT CO.
To:	Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
1-069-7, 1-69-7, NUDOCS 7906180468
Download: ML19273B892 (3)

Text

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ARKANSAS POWER & LIGHT COMPANY POST OFFICE BOX 551 UTTLE ROCK. ARKANSAS 72203 (501) 371-4422 June 12, 1979 -

WILUAM CAVANAUGH lli Vice Presdent Generation & Constructaan 1-069-7 Victor Stello, Jr., Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Caamission Washington, D. C. 20555

Subject:

Arkansas Nuclear One - Unit 1 Docket No. 50-313 License No. DPR-51 Response to June 2, 1979 Order (File: 1510)

Gentlemen:

As required by your June 2,1979 order we have reviewed applicable existing procedures and our method of developing procedures. Also, as would be expected, we have reviewed the circumstances of the June 2, 1979 occurrence and are looking at additional ways to prevent a recur-rence.

The Plant Safety Canmittee (PSC) met the afternoon of June 2,1979 to review the incident, determine the cause, and determine corrective action.

It was determined then that the procedure used for testing of the main feedwater check valves was deficient and that the operator had added a step to the procedure without the proper review. The confusion resulting fran the change in shifts was discussed.

The Safety Review Canmittee (SRC) met June 3,1979 to discuss actions taken by the plant staff related to the incident of the day before. The SRC concurred with the plant staff's evaluation of the incident. They also worked with the plant staff to develop guidelines for evaluating and modifying procedures as required by your June 2,1979 order.

Specific actions taken in response to the items listed in Section III of your June 2,1979 order are as follows.

ITEM (1)

The licensee shall evaluate and modify as appropriate its methods for the development, review and approval of procedures for a.ll modes of plant operation.

2354 090 7006180 968 MEMBEA MlOOLE SOUTH UTILITIES SYSTEM

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1-0 69-7 Mr. Victor Stello, Jr. June 12, 1979

RESPONSE

The Plant Safety Committee and General Manager reviewed the methods for the development, review and approval of procedures. Plant pro-cedures contain the following steps for the development of procedures and procedure changes:

1. Any individual can identify the need for a procedure or procedure change to a group supervisor. The group supervisor evaluates this request and assigns an individual to write the procedure or procedure change.

2. The procedure writer develops the new procedure following formats specified in plant procedures.

3. The procedure writer forwards the procedure to a member of the plant staff who independently reviews the procedure.

4. The group supervisor reviews the procedure and insures the procedure compl'ies with FSAR and technical specification requi remen ts. The group supervisor also insures that a safety evaluation is attached when required.

5. The Plant Safety. Committee reviews the procedure.

6. The Manager of Quality Assurance and Safety Review Committee review the procedure if applicable.

7. When all reviews are complete and comments are resolved the plant General Manager then approves the procedure.

The above steps are deemed adequate to insure that procedures and procedure revisions are properly reviewed before issuance.

ITEM (2)

The licensee shall evaluate existing procedures to assure that such procedures include all actions necessary for safety; and,

RESPONSE

In their meeting of June 4,1979, the PSC formed a procedure review group whose purpose was to evaluate existing procedures and propose any changes necessary to insure all actions required for safe operation would be followed. The procedure review effort in-cluded all procedur es that are similar to the procedure bypassed Saturday morning, including surveillance procedures, controlling procedures, and any procedures reflecting philosophy or design changes. In reviewing these procedures the following guidelines were used:

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1-067-7 Mr. Victor Stello, Jr. June 12,1979

1. A step for all required actions.

2. Single evolution per step. ,

3. Verify prerequisites are explicit and satisfy the condition' necessary to perfonn the evolution (i.e., step, supplement or su rveilla nce) .

4. Verify no other safety systems are overridden or bypessed by the performance of that procedure except for the system in-vol ved.

5. Incorporate proposed Technical Specifications.

A list of the procedures reviewed are included in the June 4,1979 PSC minutes. Changes to the subject procedures judged necessary by the PSC will be incorporated prior to startup.

ITEM (3)

The licensee shall take a'ppropriate steps to assure that all plant personnel adhere to approved procedures and do not add unauthorized steps to any procedures.

RESPONSE

A standing order has been issued which provides specific direction in all aspects related to procedure adherence. All plant operations and maintenance personnel will be trained as to the importance of complying with this order.

We believe that the above actions will assure that the conditions in the order were met.

Ve,ry truly yours,,

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,.- j' /

y 4%. / a ~ -1, William Cavanaugh III WC/ CSP /vb Attachment cc: Mr. G. L. Madsen, Chief Reactor Operations & Nuclear Support Branch Office Of inspection & Enforcement Region IV U. S. Nuclear Regulatory Commission 92CA U7cno9 611 Ryan Plaza Drive, Suite 1000 CJJ7 Arlington, Texas 76011 I