ML20203F401
| 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: |
| References | |
| 50-313-86-18, 50-368-86-19, NUDOCS 8607310060 | |
| Download: ML20203F401 (7) | |
See also: IR 05000313/1986018
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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
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:
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4. E. Murpffy', P(4jecfg9 Inspector, Projects
Date
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Section B, Reactor Projects Branch
- Approved:
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7//<A
D. R. Ifunter, Chief, Projects Section B,
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
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identified (failure to submit 50.59(b) annual report; failure to maintain
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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
Specification amendments are received. Most of the new positions created
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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
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
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February 27, 1986.
Procedure 1035.06, "AN0 Master M&TE List," Revision 6, ' dated
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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.
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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
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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,
Criterion V.
(313/8618-02; 368/8619-02)
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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.