ML20084P982

Responds to NRC Ltr Re Violations & Deviations Noted in IE Insp Repts 50-313/83-34 & 50-368/83-34.Corrective Actions:Temporary Contractor Released from Duty & All HP Instrument Checked for Current Calibr

ML20084P982
Person / Time
Site:	Arkansas Nuclear
Issue date:	03/20/1984
From:	John Marshall ARKANSAS POWER & LIGHT CO.
To:	Denise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
0CAN038406, CAN38406, NUDOCS 8405210053
Download: ML20084P982 (7)

Text

P ARKANSAS POWER & LIGHT COMPANY POST OFFICE BOX 551 LITTLE ROCK. ARKANSAS 72203 (501) 371-4000 March 20, 1984 F' [M OWR 3 BCAN038406 }Ji f

t ! MAR 2 21984 Mr. Richard P. Denise, Director I 'p Division of Resident Reactor Projects -

and Engineering Programs U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Dsive, Suite 1000 Arlington, TX 7C011

SUBJECT:

Arkansas Nuclear One - Units 1 & 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Response to Inspection Reports 50-313/83-34 & 50-368/83-34 Gentlemen:

We have reviewed the subject inspection reports. Responses to the " Notice of Violation" and the " Notice of Deviation" are attachad. As discussed with Mr. Johnson of your staff, transmittal of this response was delayed due to an administrative oversight.

Very truly yours, r

li ohn R. Marshall Manager, Licensing JRM:RJS:sc Attachment cc: Mr. Richard C. DeYoung Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Norman M. Haller, Director Office of Management & Program Analysis U. S. Nuclear Regulatory Commission Washington, DC 20555 8405210053 840320 PDR ADOCK 05000313  %

U PDR ,

MEMSER MIDOLE SOUTH UTIUTIES SYSTEM

)

y,i  ;.L

-i' +

NOTICE OF VIOLATION Based on the results of an NRC inspection conducted during the period of m December 1-31, 1983, and in accordance with the NRC Enforcement Policy

_(10 CFR'Part 2 Appendix C),.47 FR 9987, dated March 9, 1982, the following violations were identified:

A. 'Use of a Radiation Monitoring Instrument That Was Not Calibrated -

Units 1 and 2 10CFR50, Appendix B, Criterion V requires that " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be L accomplished in accordance with these instructions, procedures, or

drawings."

Radiation Protection Procedure 1632.01, Revision 2. " Portable Survey and Monitoring Instruments," has been established in accordance with Criterion V.

Section 5.3 of Procedure 1632.01 requires that portable radiation monitoring instruments, such as the- Eberline Model RM-14 ("frisker"), -

be inspected prior to use by health physics personnel to ensure that

-the. instruments have a valid (in-date) calibration sticker.

Contrary to the above, on December 7,1983, an Eberline Model RM-14 portable radiation monitoring instrument, identified as instrument RMPC 046, was put in use at the controlled act.ess exit area of the

! Unit 1 auxiliary building without having a valid calibration sticker.

The calibration sticker indicated that the instrument was last calibrated on April 28, 1983, and was due to be recalibrated on October 21, 1983.- .

This is Severity Level 'V Violation. (Supplement IV) (313/8334-01; 358/8334-01) l

RESPONSE

In response to Item A, "Use of a Radiation Monitoring Instrument That Was Not Cal'arated," the following corrective steps were taken. The instrument was immediately removed from controlled access and tagged as out of service. The instrument was recalibrated and found to be

satisfactory without adjustment. All other HP instruments in use were checked for current calibration - all were satisfactory. l To avoid further violation, the responsible individual for checking out  !

the instrument who was a temporary contractor, was released from duty the same day'as the occurrence. During the normal pre-shift information meeting the following day, HP personnel (including contractors) were informed of the incident and of the consequences.

The documentation of the incident was placed in the HP required L reading. The date of full compliance achievement was January '16,1984.

(

P y 4.

B. Use of Test Equipment That Did Not Have a Current Calibration - Unit 2 Unit 2 Technt.:al. Specification 6.8.1 requires that, " Written procedures shall be established, implemented, and maintained covering... a.' The applicable procedures recommended in Appendix A of Regulatory Guide 1.33...."

Instrumentation and Control P.riodic Test Procedure 2304.115, Revision 4 " Reactor Protective System Response Time Test Channel D,"

has been established in accordance with this Technical Specification.

Step 5.2 of Procedure 2304.115 requires that personnel performing the test verify that the test equipment calibration dates are current prior to their use.

Contrary to the above, on December 7, 1983, the NRC inspector observed

'that a visicorder being used to perform reactor protective system response time testing on channel 'D', in accordance with Procedure 2304.115, did not have a current calibration. The visicorder is required to be calibrated prior to use ("on demand"), but was last calibrated on February 15, 1980.

This is a Severity Level V Violation. (Supplement I) (368/8334-02)

RESPONSE

Procedure 2304.115 is a Responsa Time Test procedure for Unit II RPS Channel "0". While performing this procedure a visicorder was used for the purpose of recording response times for various functions. This procedure, like other I&C procedures, requires verification that all test equipment is in current calibration. These recorders are normally not kept calibrated. Rather, they are marked with a " Calibrate on Demand" sticker in accordance with Procedure 1035.05, "M&TE Calibration and Repair." Therefore, it is necessary for the user to insure calibration prior to use.

There are two methods used for calibration of recorders. One is to calibrate the recorder after it is setup for the test utilizing the beginning and/or end of the test record as a record of calibration.

The other method is to bench calibrate the recorder before putting it in service. The most preferred method depends on the type of recorder and the test function. For time measurement the recorder is usually bench calibrated.

Contrary to this requirement the recorder in use (REC-011) was not in current calibration. The date due for recalibration was February 15, 1981.

Through an oversight, the first test of Procedure 2304.115', Controlled Copy #102, Job Order 54370, was conducted in December 1983 using this

! recorder. When discovered that this recorder was out of calibration, it was removed from service and returned to the calibration laboratory.

The recorder was then calibrated and returned to service for completion of the test. The recorder was found to be in calibration.

T .- ;--

h .

T', x.. - . -

'The failure in Item B.was a case of overlooking the "Out of

' Calibration" condition of the recorder. All persons involved are aware of the requirements. Each has been reminded of this requirement and the ' seriousness of this situation.

These apparent violations will be discussed with each Technician before Specifically, we will retrain the Technicians and April 1, 1984.

Supervisors in the use of Test Equipment relating to the acceptability of MTE and in the need for records keeping. A training record will be

-made.of this' retraining.

C.- Failure to Follow Procedures for Recording of Measuring and Test Equipment (MTE) Identification Number - Unit 2 Unit 2 Technical Specification 6.8.1 requires that, " Written procedures shall be established,-implemented, and maintained covering ... a. The applicable procedures recommended in Appendix A of Regulatory Guide 1.33...."

Plant Administrative Procedure 1000.14, Revision 6, " Control of MTE L and Standards," hn oeen established in accordance with this Technical Specification.

Step 6.2.4 of Procedure 1000,14 requires that, "The MTE identification-r number shall be recorded on the job order, surveillance test data

. sheet, procedure, etc., to establis:t traceability."

Contrary to the above, the reactor protective system response time test-for channel 'C' was performed on November 8, 1982, in accordance with Procedure 2304.114, but the MTE identification number for the visicorder required by Step 3.1 of this procedure was not recorded on any associated test documentation.

This is a Severity Level V Violation. (Supplement I) (368/8334-03)

RESPONSE

While reviewing previous records, the inspector found Procedure 2304.114 Controlled Copy #102, Job Order 29994 on file for record of Unit II RPS Channel "C" Response' Time Test for the 2R-2 Surveillance Test.

This document-did not indicate that a recorder was used. The record is normally entered on page one of the procedure.

Recorder traces were attached to the procedure and the technician that performed the test verified that he had used REC-013. ~his recorder was in current calibration at the time of the test. The recorder was calibrated September 18, 1982 and used between that date and November 8, 1982.

After this discovery the plant records were updated to reflect this information. Page one of-the procedure, from microfilm was updated by

the !&C Supervisor and turned in to Data Entry for recording.

l

p .,

The failure in Item C was that of failing to make a complete record of the Test Equipment used. As described in Iten B, each individual was

. reminded of the requirements and necessity for compliance.

This apparent violation will be discussed with each Tech.iician before April 1, 1984. Specifically, we will retrain the Technicians and Supervisors in the use of Test Equipment relating to the acceptability of M&TE and in the need for records keeping. A training record will be made of this retraining.

e o

a :. .

h.?

NOTICE OF DEVIATION L  ! Based on'the'results.of an NRC inspection conducted during the period of

-December 1-31,-1983, and in accordance with NRC Enforcement Policy (10 CFR Part 2,LAppendix C),-47 FR 9987, dated March 9, 1982, the following

deviation was identified:

Failure to Meet'a Commitment Relative to Reactor Trip Breaker Maintenance EBy a letter dated April 5, 1983, the NRC Office of Nuclear Reactor Regulation issued to the licensee a Safety Evaluation Report (SER) concerning.the Unit 1 reactor trip breakers (RTBs).Section III.E of this SER documents contain commitments the licensee made relative to improving the maintenance procedures for the RTBs. One such commitment requires that if any out-of-tolerance conditions are found during maintenance on the RTBs, a review of the conditions of' failure by the quality assurance and

. engineering; staffs would be provided.

-In' deviation from the above, a review of the conditions of failure by the quality assurance and engineering staffs was not provided for the approximately eighteen out-of-tnle:rance conditions that were found while performing maintenance on the RTBs (Procedure 1405.17) during the period

~

November 5-11,?1983. '(313/8334-02)

RESPONSE

With regard to the Unit 1 Reactor Trip Breaker (RTB) procedures in question, the procedure packages have been'provided-to engineering for-review as of-February 15,'1984.' The packages were in use until February 1, 1984 for

. reference in completing Reports of Abnormal Conditions (RACs) associated with theLperformance of the procedures. With the Unit 2 outage demands and RAC loading imposed on the Electrical Maintenance group the procedures could not be reviewed during December 1983, due to manpower constraints.

They were-reviewed'during January 1984, in conjunction with'the RAC's generated during surveillance of the Unit 2 Reactor Trip Breakers. The RAC's provide a preliminary assessment of the impact of-the out of specification conditions. The Unit 1 procedures have been submitted to Engineering. It was felt that initially this ." bulk" transmittal would be most effective in accounting for the records and establishing the Engineering Review Program.

To prevent recurrence, the restoration and close out sections' for both the

. Unit 1 and Unit 2~ breaker PM procedures.have been changed to assure the records are provided to Engineering and Quality Arsurance (Quality Control),'

PC-1 to 1405.17,-Rev. 3, was incorporated December 8, 1983.

PC-2 to 2405.17,'Rev. 3, was incorporated December 9, 1983.

The mechanism is now in place to insure that out of tolerance indications

-are provided to Engineering and Quality Assurance (represented by ANO Quality Control Dept.) personnel for review. Engineering review is in progress and is considering these 18 out-of-tolerance indications along with

w .

findings from other PMs on the breakers. Engineering evaluation on these PM

' findings'is expected to be complete by April 1,-1984. Quality Assurance -

evaluation is expected to be complete by April 15, 1984.-

1'l e

I f

_ _ _ - _ - _ _ _ _ _ - _ _ _ . _ - - - - - - _ _ _ - - - - - - _ _ _ - - _ _ _ - - - . - _ - - _ . . - _ _ _ - - - _ _ _ _ _ . _ _ . _ . . . . - . . . . _ - - - - . - _ _ _ _ - _ - _ _ - _ - _ _ _ - .