ML20043E499

Provides Supplemental Response to Violations Noted in Insp Repts 50-313/89-02 & 50-368/89-02.Corrective Actions:Listed Program Enhancements Being Implemented to LER Process to Provide Timely Determinations of Condition Rept

ML20043E499
Person / Time
Site:	Arkansas Nuclear
Issue date:	06/05/1990
From:	Ewing E ARKANSAS POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
0CAN069008, CAN69008, NUDOCS 9006130057
Download: ML20043E499 (5)

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• ' ~ ~~ noute 3, Box 137 G RusselMile, AR 72801 Tel 501964 3100 June 5, 1990 BCAN069008 U. S. Nuclear Regulatory Commission Document Control Desk Mail Station P1-137 t Washington, D. C. 20555  ;

Subject:

Arkansas Nuclear One - Units 1 and 2 i Docket Nos. 50-313/50-368 License Nos. DPR-51 and NPF-6 Supplemental Response to-Inspection Report 50-313/89-02; 50-368/89-02 Gentlemen:

As requested in Inspection Report 50-313/89-22; 50-368/89-22 dated September 14, 1989, the attached information provides additional actions ,

regarding controls for processing identified Licensee Event Reports (LERs) to prevent further recurrence of Inspection Report violation 50-313/8902-02; 50-368/8902-02. Arkansas Power and Light Company has implemented several improvements regarding its Licensee Event Reporting (LER) process. Further assessment ~of the program has resulted in additional enhancements provided in the attachment. .We will continue to review the-LER process to determine if further improvements are necessary.

In addition, Attachment 2 provides revised completion dates for previous commitments provided in response to NRC Inspection Report 50-313/89-22; 50-368/89-22, Violation A. The new dates are consistent with the ANO Business Plan schedules regarding the Operations and Maintenance procedures upgrade programs.

If further information is required, please contact Mr. J. Fisicaro at (501) 964-3228.

Very truly yours, E. C. wing s General Manager, Technical Support /f and Assessment /[

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. Sam Collins, Director .

Division of Reactor Projects .

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Page 1 -

June 5, 1990 LICENSEE EVENT REPORT IMPROVEMENTS Arkansas Power & Light's (AP&L) April 7,1989, response to Inspection Report 50-313/89-02 and 50-368/89-02 identified the following corrective actions:

(1) addition of contractor staff as an interim measure to reduce overdue Licensee Event Reports (LERs) and provide permanent staffing responsible for preparation of LERs, (2) established a mechanism to keep management informed of the status of reportable events, and (3) established additional internal guidance to request appropriate extensions to submittal dates and also '

supplements if submitted LERs did not contain all the required information at the time of submittal.

In a subsequent July 6, 1989, letter documenting discussions in a June 16, 1989, NRC meeting with AP&L, the following additional actions were summarized:

1) The need for a more rigorous up-front operability determination was identified. A new operability determination procedure was implemented  !

and the shift operations supervisor now documents the basis of his operability determination.

2) The Plant Safety Committee LER reviews were moved to a postsubmittal review rather than presubmittal, to preclude unnecessary delays.

3) AP&L Management is made aware of Condition Report (CR) resolution progress by a periodically distributed status report on a) overdue action, b) open operability /reportability reports and c) assessment reports to the Safety Review Committee.

4) A biweekly report is issued to management listing outstanding LERs with respective due dates and expected submittal dates.

5) If AP&L is not able to meet the required reporting requirement, this fact will be communicated to the NRC along with AP&L's proposed schedule for submittal.

A review was performed of the LER process from the identification or discovery of an event or condition through the reportability determination and submittal of the LER to the NRC. The following additional program enhancements are being implemented to provide timely determinations of CR reportability and submittals of LERs pursuant to 10CFR50.73:

1) Reportable CRs are assigned to the responsible manager during the daily plant meeting to ensure information accurately and completely describes the event and root cause evaluations are assigned. This places ownership for root cause evaluations and identification of corrective actions.

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U. S!- NRC?

, Attachment 11 Page 2 June 5, 1990

2) Station Procedure 1000.104, " Condition Reporting and-Corrective Actions," has been revised.to enhance procedural controls for CR reportability determinations and for documentation of information

. required for reportability determination and LER preparation.- The -

revision includes complete and timely measures to support LER sub-mittals to the NRC. These measures are consistent with AP&L's philosophy of performing comprehensive reportability and operability determinations.

3) Initial root cause evaluations and proposed correction actions from the responsible departments are now being required within a timely.

period (i.e., approximately 14 days) fror J 4 occurrence of a reportable event or discovery of a potentially repor -e condition.

4) long lead times (e.g., 3 to 9 months) to obtain required information and perform reportability determinations will not be acceptable. It is recognized that some issues are complex and require a reasonable time to evaluate. However, immediate evaluation will be performed using available information within a reasonable period of. time. Engineering judgement may be required to support reportability determination in a-timely manner such that an LER can be submitted within 30 days follow--

ing the' discovery of a potentially reportable condition. This may result in certain reportable conditions submitted as LERs being retracted based on subsequent further evaluation.

Collectively, these measures have enhanced the LER process.

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l U. S. NRC

, ' Attachment 2 Page 1 June 5, 1990 OPERATIONS AND MAINTENANCE PROCEDURES UPGRADE PROGRAM In AP&L's response to' 50-368/89-22, Violation A, dates for the completion of the Operations and Maintenance procedure upgrade programs were provided.

On March 14, 1990, the ANO Business Plan was submitted which provided-revised completion dates for the Operations procedure upgrade program and the' Maintenance procedure upgrade program.

Item C.11.a addressed the Operations upgrade program with a completion 3 date of July 31, 1991. Item C.11.b addressed the Maintenance upgrade  ;

program with a completion date of November 30, 1990. l 1

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