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Insp Repts 50-313/86-18 & 50-368/86-19 on 860609-13. Violation Noted:Failure to Submit 10CFR50.59(b) Annual Rept & Failure to Maintain Adequate Procedures for Tests & Experiments
	ML20203F401
Person / Time
Site:	Arkansas Nuclear
Issue date:	07/11/1986
From:	Hunter D, Murphy M; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	;
Shared Package
ML20203F366	List: ML20203F361; ML20203F376; ML20203F401;
References
	50-313-86-18, 50-368-86-19, NUDOCS 8607310060
	Download: ML20203F401 (7)
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APPENDIX B

U.S. NUCLEAR REGULATORY COMISSION

REGION IV

NRC Inspection Report: 50-313/86-18 Licenses: DPR-51

50-368/86-19 NPF-6

Dockets: 50-313

50-368

Licensee: ArkansasPower&LightCompany

P. O. Box 551

Little Rock, Arkansas . 72203

Facility Name: Arkansas Nuclear One, Units 1 and 2

Inspection At: Russellville, Arkansas

Inspection Conducted: June 9-13, 1986

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Inspector: 7 oFC

4. E. Murpffy', P(4jecfg9 Inspector, Projects Date '

Section B, Reactor Projects Branch

- Approved: O/

D. R. Ifunter, Chief, Projects Section B,

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Date

Reactor Projects Branch

Inspection Summary

Inspection Conducted June 9-13, 1986 (Report 50-313/86-18)

Areas Inspected: Routine, unannounced inspection of organization and

administration, tests and experiments program, and surveillance test and

calibration control program.

Results: Within the three areas inspected, two apparent violations were i

identified (failure to submit 50.59(b) annual report; failure to maintain I

procedure adequacy, paragraphs 3 and 4).

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Inspection Summary

Inspection Conducted June 9-13, 1986 (Report 50-368/86-19)

Areas Inspected: Routine, unannounced inspection of organization and

administration, tests and experiments program, and surveillance test and

calibration control program.

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Results: Within the three areas inspected, two apparent violations were

identified'(failure to submit 50.59(b) annual report; failure to maintain

procedure adequacy, paragraphs 3 and 4).

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DETAILS

1. Persons Contacted

B. Baker, Operations Manager

P. Campbell, Plant Licensing Engineer

C. Cole, Surveillance Test Coordinator

J. Dilworth, I&C Scheduler

E. Ewing, General Manager, Plant Support

D. Howard, Special Projects Manager

L. Humphrey, General Manager, Nuclear Quality

G. Kendrick, I&C Planner

R. Lane, Engineering Manager

J. Levine, Site Director, ANO

D. Lomax, Plant Licensing Supervisor

J. McWilliams, Maintenance Manager

D. Payne, ISI Coordinator

D. Provencher, Site QA Superintendent

S. Quennoz, General Manager, Operations and Maintenance

J. Remer, Maintenance History Supervisor

Denotes present at the exit interview.

2. Organization and Administration

This inspection was to detennine whether changes made to the licensee's

onsite organization are in conformance with the requirements of the

Technical Specifications and the licensee's use of overtime is in

conformance with regulatory requirements.

The licensee is presently in the transition period of a major

reorganization. The last organization changes were approved in Technical

Specification Amendment 82 for Unit 1 and Amendment 52 for Unit 2, both

dated February 1, 1984. The NRC inspector reviewed the requests for

Technical Specification changes submitted in December 1985, to support the

latest reorganization. These requests have been noticed to the federal

register, they have been signed but had not been mailed at the time of

this inspection.

Proposed membership changes in the plant safety committee and the safety

review comittee will not be implemented until the approved Technical

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Specification amendments are received. Most of the new positions created

by the reorganization have been filled. This was accomplished by internal

promotion or reassignment, with the exception of the position of General

Manager, Operations and Maintenance which was filled by a new hire. The

NRC inspector reviewed the qualifications and experience of the individual

selected for this position, and found that they meet and exceed the

regulatory requirements. The NRC inspector also confirmed that the

licensee's personnel department holds documentation validating the

qualifications and experience.

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The NRC inspector reviewed procedure 1015.01, " Conduct of Operations,"

Revision 25, dated June 3,1986, and "ANO Overtime Policy," Revision 2,

dated February 1, 1984. The policy document provides the form for

documenting overtime deviations. A review of some recently completed

forms confirmed that the intent of overtime control is being met.

No violations or deviations were identified.

3. Tests and Experiments Program

This inspection was to determine that the licensee is implementing a

program to control tests and experiments that is in conformance with

regulatory requirements.

It was found that the licensee does not have a specific procedure to

control tests and experiments. The NRC inspector determined that the

program is contained in the following procedures:

1000.04, " Procedural Program Requirements," Revision 20, dated

December 18, 1985.

1000.06, " Procedure Review, Approval, and Revision Control,"

Revision 22, dated December 12, 1985.

1000.02, " Plant Safety Committee (PSC) Operation," Revision 8, dated

June 18, 1985.

1000.08, "NRC Reporting and Communications," Revision 20, dated

November 15, 1984.

The review of these procedures verified that a method has been established

to identify tests and experiments involving safety-related components,

systems or structures, or modes of operation different from those

described in the FSAR; provisions have been made to assure that tests and

experiments will be performed in accordance with approved written

procedures; responsibilities have been assigned for reviewing and

approving test and experimental procedures; a system has been established

to assure that all proposed tests and experiments will be reviewed to

determine whether they are described in the FSAR; responsibilities have

been assigned to assure that a written safety evaluation pursuant to

10 CFR 50.59 will be developed for each test or experiment not described

in the FSAR to assure that it does not involve an unreviewed safety

question or a change in the Technical Specifications; responsibility has

been assigned .to assure that all tests and experiments conducted pursuant

to 10 CFR 50.59 will be formally reported to the NRC in a timely manner.

The NRC inspector requested a copy of the last report submitted in

compliance with 10 CFR 50.59(b). A licensee representative informed the

NRC inspector that the last report was submitted in December 1984, and

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covered activities through 1983 only. The licensee is presently preparing

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a report that will cover activities for the years 1984 and 1985. Failure

to submit an annual report as required by 10 CFR 50.59(b) is an apparent

violation. (313/8618-01;368/8619-01)

During the procedure review, the NRC inspector identified specific

deficiencies in procedure 1000.06. This procedure provided forms for the

user in determining whether or not a safety evaluation would be required

and in determination of unreviewed safety questions.

The specific deficiencies identified were:

d. Forms 1000.06B and 1000.6C stated, in part, " involves a change to a

test or experiment not described in the FSAR." A more appropriate

statement that addresses the requirements of 10 CFR 50.59 would be

" involves a test or experiment not described in the FSAR."

b. Question 2 on Form 1000.06E stated, in part, "would the proposed

procedure change increase the consequences of an accident analyzed

in the FSAR?" A more accurate statement that address the

requirements of 10 CFR 50.59 would be "would the proposed procedure

or change increase the consequences of an accident analyzed in the

FSAR?"

4. Surveillance Testing and Calibration Control Program

This inspection was to determine that the licensee has programs for

control and evaluation of surveillance testing, calibration, and

inspection required by the Technical Specifications; inservice inspection

and testing of pumps and valves as required by 10 CFR 50.55a(g); and,

calibration of safety-related instrumentation not specifically controlled

by Technical Specifications.

The NRC inspector reviewed the following licensee procedures:

Procedure 1000.09, " Surveillance Test Program Control," Revision 14,

dated August 30, 1985.

Procedure 1000.14, " Control of M&TE and Standards," Revision 8, dated

February 27, 1986.

Procedure 1022.06, "ASME Code Section XI Inservice Testing Program

Unit 1," Revision 6, dated April 17, 1986.

Procedure 1022.07, "ASME Code Section XI Inservice Testing Program

Unit 2," Revision 2, dated April 17, 1986.

Procedure 1032.07, "lSI Program Requirements," Revision 5, dated

August 1, 1985.

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Procedure 1035.05, "M&TE Calibration and Repair," Revision 5, dated

February 27, 1986.

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Procedure 1035.06, "AN0 Master M&TE List," Revision 6, ' dated

February 27, 1986.

This review determined that the. licensee's surveillance testing and

calibration control program incorporated the following elements:

A master schedule for surveillance testing, calibration, and.

inservice testing and inspection. This schedule includes frequency,

responsibility,'and status. ,

Responsibility for master schedule updates.

Formal requirements for conduct of tesks, calibrations, and

inspections in accordance with approved procedures which include

acceptance criteria.

Methods and responsibilities for review and evaluation of test,

calibration and inspection data and for dispositioning deficiencies,

malfunctions, etc. Verification is made and documented that LC0

requirements are satisfied.

Responsibility is assigned to assure schedules are satisfied.

Provisions for updating the master schedule to reflect Technical

Specification or license revisions.

Calibration of safety-related components not identified in Technical

Specifications are included in the surveillance test master schedule.

During this review, the NRC inspector noted several deficiencies in these

procedures that could lead to misinterpretation, missed inservice testing

and/or inservice inspection requirements. Specific deficiencies are:

a. The last sentence of paragraph 6.2.2 of procedure 1000.09 is

grammatically incorrect and should be deleted. This error could

cause the responsibilities for scheduling surveillance testing to be .

misinterpreted. The correct wording is already contained in

paragraph 6.2.3. It was also noted that paragraph 6.2.6 and 6.2.8

referred to nonexistent procedures.

b. The following reproduction errors in procedure 1022.06 should be

corrected and the missing page of components incorporated. In

Attachment 2 of the procedure, pages 23 and 24 are the same except

.page 23 is Revision 6 and page 24 is Revision 5. The correct

revision of page 24 is missing. These changes are needed to ensure

that all required components are identified in the inservice

inspection program. ,

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c. Procedure 1032.07 should be corrected to include reference to both

procedures 1022.06 (Unit 1) and 1022.07 (Unit 2). Paragraphs 2.0,

3.0, and 3.3 of 1032.07 currently refer only to procedure 1022.06.

These deficiencies along with those discussed in paragraph 3 of this

report indicate a degradation in the quality of the procedure review and

approval program for ANO. Failure to ensure that documents / procedures,

including changes, are adequately reviewed for adequacy in accordance

with established AN0 procedures is a violation of 10 CFR 50, Appendix B,

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Criterion V. (313/8618-02; 368/8619-02)

5. Exit Meeting

An exit interview was conducted March 21, 1986, with those personnel

denoted in paragraph 1 of this report. The senior resident inspector also

attended this exit meeting. At this exit interview, the NRC inspector

summarized the scope and findings of the inspection.

ML20203F401

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