ML20154S158

Notice of Violation from Insp on 880815-0902.Violations Noted:Licensee Abolished Organization Entitled Nuclear Svcs Involved in Design Change Program W/O Revising Procedures Prescribing That Organizations Functions

ML20154S158
Person / Time
Site:	Arkansas Nuclear
Issue date:	09/27/1988
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20154S148	List: ML20154S145 ML20154S158 ML20154S161
References
50-313-88-26, 50-368-88-26, NUDOCS 8810040456
Download: ML20154S158 (3)

Text

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APPENDIX A ,

NOTICE OF VIOLATION Arkansas Power & Light Company (APAL) Dockets: 50-313 i Arkansas Nuclear One, Units 1 and 2 50-368 Licenses: DPR-51 NPF-6 i i

During an NRC inspection conducted August 15 through September 2, 1988, violations of NRC requirements were identified. The violations involved I failure to appropriately revise procedures for control of design changes and  ;

modifications after abolishment of an involved organization; failure to obtain f relief from the NRC when conformance to inservice inspection requirements is i impractical; failure to have appropriate procedures in effect for conduct of receiving inspections; and failure to have records of qualification of an auditor. In accordance with the "General Statement of Policy and Procedure i for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violations ,

are listed below:

A. Failure to Revise Procedures to Reflect a Major Reorganization '

i Criterion I of Appendix B to 10 CFR Part 50 requires, in part, that the licensee shall establish the authority and duties of persons and organizations performing activities affecting safety-related functions.

Criterion II requires, in part, that the organizations participating in the quality assurance program and their designated functions be identified.

Criterion V requires that activities affecting quality be documented in ,

instructions, procedures, or drawings and that that these activities shall  !

be accomplished in accordance with these instructions, procedures, or  ;

drawings, j i The Quality Assurance Manual Operations, Revision 9, implements all of the  !

above requirements.

Contrary to the above, on or about January 4,1988, the licensee abolished  !

an organization entitled Nuclear Services that had been substantially involved in the design change program without revising the procedures {

prescribing that organizations functions. As a minimum, the following  !

licensee procedures are involved: l

o Procedure 6000.10. "Design Change Requests " Revision 0, dated [

i April 15, 1987 I

o Procedure 6010.001, "DCP Developement," Revision 0, dated November 16, [

1987  ;

o Procedure GTEP-201, "Design Change Initiation and Control,"

Revision 16 l J

1 [

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- - - - - . - - - ~_ _ _ _ _ __ _.-_ _ _ _ ___-.-_._ _...-_________,____a

2 o Procedure 1032.01, "Plant Engineering Action Requests," Revision 9, dated November 16, 1987 This is a Severity Level IV violation. (SupplementI)(313/8826-01:

368/8826-01)

B. Failure to Obtain Relief From NRC Where the Licensee Has Detemined That Conformance With Certain Code Requirements is Impractical.

10 CFR Part 50.55a(a)(g)(iii) requires that, if the licensee has detemined that conformance with certain code requirerrents is impractical for its facility, the licensee shall notify the Comission and submit information to support the determinations.

Contrary to the above, AP&L did not notify the Comission that the Unit 1 reactor vessel head to flange weld could not be volumetrically examined as required by paragraph IWP,-2500 of Section XI of the ASME Boiler and Pressure Vessel Code, 1980 Edition and Addenda through Winter 1981. The ultrasonic examination of the above weld performed on November 19,1986, and reported in Examination 02-001, could not be scanned from at least one direction as required by paragraph T-441.5 of Section V of the ASME Code.

Examination 02-001 reported that the percent of examination perfomed was 50 percent because of obstruction from lifting lugs, superstructure, and flange configuration.

This is a Severity Level IV violation. (Supplement 1)(313/8826-02)

C. Failure to Have a Procedure for Performing Quality Assurance (OA)/

Quality Control (QC) Receiving Inspection Functions Criterion V of Appendix B to 10 CFR Part 50 as implemented by the licensee QA Manual Operations Revision 9, requires that activities affecting quality shall be prescribed by instructions, procedures, or drawings appropriate to the circumstances end that these activities be accomplished in accordance with these instructions, procedures, or drawings.

Contrary to the above, the licensee deleted Procer'ure 0C0-5, "Purchase Requisition Review, Receipt Inspection, and independent Material Test," on about July 21, 1988, with the intention of replacing it with Procedures QA0-2, "QA Review for Procedures and Documents," and QAO-11.

"Receipt inspection and Independent Testing." As of the conclusion of the inspection on September 2, 1988, a date for issue of Procedure QAO-11, had not been established.

This is a Severity Level V violation. (Supplement !)(313/8826-03; 368/8826-03)

3 D. Failure to Maintain Records of Auditor Qualification Criterion XVII of Appendix B to 10 CFR Part 50 requires that records shall be maintained that include the qualifications of personnel performing audits and similar quality related activities.

Licensee Procedure NQA-2 implements the above by requiring that records be established and maintained which document the education and past experience of all QA personnel.

Contrary to the above, records were not available with respect to the education or experience of an auditor who performed, in part.

Audit QAP-18H-88 during the period of January 21 through April 22, 1988.

This is a Severity Level V violation. (SupplementI)(313/8826-04; 368/8826-04) r Pursuant to the provisions of 10 CFR 2.201, Arkansas Power & Light Company is hereby required to submit a written statement or explanation to this Office within 30 days of the date of the letter transmitting this Notice. This reply, should include for each violation: (1) the reason for the violations if admitted (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.

Dated at Arlington, Texas, this yJt( day of /x t 1988