ML20106A669

Responds to NRC Re Violations Noted in Insp Repts 50-313/84-15 & 50-368/84-15.Corrective Actions: Administrative Procedures for Control of Design Changes Will Be Modified to Provide More Detailed Instructions

ML20106A669
Person / Time
Site:	Arkansas Nuclear
Issue date:	07/06/1984
From:	John Marshall ARKANSAS POWER & LIGHT CO.
To:	Denise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20106A664	List: ML20106A669
References
0CAN078403, CAN78403, NUDOCS 8502110333
Download: ML20106A669 (3)

Text

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ARKANSAS POWER & LIGHT COMPANY POST OFFICE BOX 551 LITTLE ROCK. ARKANSAS 72203 (501)3714000 July 6,1984 m

OCAN078403 g@@h Mr. Richard P. Denise, Director M l2O Division of Resident Reactor Projects and Engineering Programs f ,

l U. S. Nuclear Regulatory Commission "

Region IV -

611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011

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 50-313/84-15 and 50-368/84-15 bentlemen':

The subject inspection reports have been reviewed. A response to the

" Notice of Violation" is attached.

Very truly yours, John R. Marshall Manager, Licensing JRM:RJS:ac Attachment l cc: Mr. Norman M. Haller, Director Office of Management & Program Analysis U. S. Nuclear Regulatory Commission j Washington, DC 20555 Mr. Richard C. DcYoung

• Office of Inspection and Enforcement

( U. S. Nuclear Regulatory Commission Washington, DC 20555 8502110333 840719 PDR ADOCK 05000 0

, MEMBEA MOOLE SOUTH UTILITIES SYSTEM t _ _

NOTICE OF VIOLATION Based on the results of an NRC inspection conducted during the period of May 14-18, 1984, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C), 49 FR 8583, dated March 8, 1984, the following violation was

. identified:

Failure To Provide Adequate Design Control Measures 10 CFR Part 50, Appendix B, Criterion III, states in part: "The design control measures shall provide for verifying or checking the adequacy

.of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program. . . . Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design. . . ."

Arkansas Power and Light Company Quality Assurance Program for Operations, TOP-1A, Revision 5, dated October 10, 1980, invokes ANSI N45.2.11-1974. ANSI N45.2.11-1974, states in part: " Measures shall be applied to verify the adequacy of design. . . . The results of design verification efforts shall be clearly documented, with-the identification of the verifier clearly indicated thereon, and filed. .

.. The responsible design organization shall identify and document the particular design verification methods to be used."

Contrary to the above, administrative procedures for the control of design changes do not provide the necessary instructions to satisfy these specific requirements.

This is a Severity Level IV Violation. (Supplement ID)

(50-313/8415-01; 60-368/8415-01)

Response

ANSI N45.2.11-1974, paragraph 6.3, states the following:

"The responsible design organization shall identify and document the particular design verification methods to be used. Acceptable verif-ication methods include but are not limited to:

1. Design reviews

2. Alternate calculations

3. Qualification testing "

After reviewing the violation, ANSI N45.2.11 and ANO administrative procedures AP&L has concluded that administrative' procedure 1032.01, Design Control, as currently written, provides for design verification

1 1

by the design review method. Cuidelines for this review technique are l provided in paragraph 6.2.11 of procedure 1032.01 and include: 1) ,

verification that the items specified in the Design Evaluation Questions I (Attachment 3.of 1032.01) have been properly addressed; 2) verification i of completeness; and 3) verification of technical accuracy. Design Evaluation Questions are based on guidelines provided in ANSI N45.2.11-1974, paragraphs 3.2 and 6.3.1. Those items not specifically conveyed as questions are inherently addressed in the process of responding to the question set or in the verification of completeness and technical accuracy in the review process. This design verification method is specified for all DCPs by the Design Control procedure. The independent reviewer's signature signifies that an independent design review as specified in the procedure was performad. Design verification by other means such as alternate calculations or qualification testing is supplemental to the design review process. Since guidelines currently exist to verify the adequacy of designs in accordance with ANSI N45.2.11-1974 and 10 CFR Part 50 Appendix B, it is not clear that procedural changes to address this aspect are necescary.

However, as indicated in the violation, there does appear to be a weakness in ANO design control procedures regarding documentation of the results of design verification efforts. Specifically our review indicates that more detailed guidance and documentation of the independent review process are in order. Presently, a Design Process Review by an AP&L task force is underway which is expected to result in several changes in the AP&L design change process. A thorough evaluation of the requirements and desired results of the independent review phase of the design process is being included in this project.

For the interim period, prior to completion of the Design Process Review , AN0 administrative procedure (s) for the control of design changes, will be modified to provide more detailed instructions to improve the consistency and documentation of the independent review.

It is anticipated that the necessary changes can be implemented by September 14, 1984.

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