ML20207N244
| ML20207N244 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 01/09/1987 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Campbell G ARKANSAS POWER & LIGHT CO. |
| References | |
| NUDOCS 8701140073 | |
| Download: ML20207N244 (2) | |
See also: IR 05000313/1986018
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JAN
9 1987
In Reply Refer To:
Dockets: 50-313/86-18
50-368/86-19
Arkansas Power & Light Company
ATTN: Mr. Gene Campbell
Vice President, Nuclear
Operations
P. O. Box 551
Little Rock, Arkansas
72203
Gentlemen:
Thank you for your letter of August 29, 1986, in response to our letter and
Notice of Violation dated July 25, 1986. We have reviewed your reply and have
identified some major concerns that need to be addressed.
Our first concern is in regard to the structure or make up of the response.
The opening paragraph under the section entitled, " Notice of Violation " is in
actuality the opening paragraph from the Notice of Violation (NOV) in NRC
Inspection Report 50-313:368/86-15 issued on July 23, 1986, and not from our
July 25, 1986, report. The violation that you have categorized as Violation A
is, in fact, Violation B in the NOV of our July 25, 1986, report, and the
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violation that you have categorized as Violation B is our Violation A.
As a result of our review of your response to Violation B (categorized as
Violation A in your response), we find that additional information, as discussed
with your Mr. D. Lomax (during a meeting with the NRC resident inspector on
December 22,1986) is needed.
The area of concern addressed by this violation
was the number of deficiencies found in the procedures reviewed which place the
adequacy of your procedure review program and the overall quality of your
procedures in question.
Your response focused on the specifics of the examples
of deficiencies and not on the cause of the deficiencies. Your response should
address the root cause of the procedural deficiencies and your actions to
correct the cause and prevent recurrence.
We find that the response to Violation A (categorized as Violation B in your
response) is responsive to the concerns raised in our Notice of Violation. We
will review the implementation of your corrective actions during a future
inspection to determine that full compliance has been achieved and will be
maintained,
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We would, again, retnind you of the context of the four questions to be answered
in the response to a violation that are contained in the last paragraph of each
Please provide the supplescental information for Violation B
within 30 days of the date of this letter.
Sincerely,
Od bd r 5 9 ny
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J.E.Cc,y.vda
J. E. Gagliardo, Chief
Reactor Projects Branch
CC:
J. H. Levine, Director
Site Nuclear Operations
Arkansas Nuclear One
P. O. Box 608
Russellville, Arkansas
72801
Arkansas Radiation Control Program Director
bectoDMD(IE01)
bec distrib. by RIV:
RPB
RRI
R. D. Martin, RA
R&SPB
Section Chief (RPD/B)
D. Weiss, RM/ALF
RIV
DRSP
RSB
HIS System
RSTS Operator
Project Inspector
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ARKANSAS POWER & LIGHT COMPANY
POST OFFICE BOX 551 UTTLE ROCK. ARKANSAS 72203 (501) 3716
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August 29, 1986
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Mr. J. E. Gagliardo, Chief
,
Reactor Projects Branch
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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
Response to Inspection Report
50-313/86-18 and 50-368/86-19
Dear Mr. Gagliardo:
The subject report has been reviewed.
A response to the Notice of Violation
is attached.
Very truly yo
s,
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J. T
os, Manager
Nuclea Engineering and Licensing
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Attachment
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MEMSER MiOOLE SOUTH UTILITIES system
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During an NRC inspection conducted during.the period May 1-31, 1986,
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violations of the NRC requirements were 1Jentified.
The violations involved-
failure to lock a manual valve in positian as required, failure to have
p
adequate controls over the installation of temporary scaffolds in the
p/
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vicinity of safety-related equipment, and lack of calibration data that
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would demonstrate the accuracy of measurement of the admixture liquid
dispenser being utilized at the concrete supplier's facility.
The specific
findings and AP&L's response to each are listed below.
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A.
10 CFR 50, Appendix B. Criterion V states, in part, " Activities
affecting quality shall be prescribed by documented instructions,
procedures, ... of a type appropriate to the circumstances and shall be
accomplished in accordance with these instructions, procedures, ... ANO
procedures 1000.04, " Procedural Program Requirements," Revision 20, and
1000.06, " Procedure Review, Approval, and Revision Control," Revision
22, implemented these requirements.
Contrary to the above, a number of deficiencies were found in various
procedures which could result in performance errors.
The following are
examples:
1.
The last sentence in paragraph 6.2.2 of procedure 1000.09,
" Surveillance Test Program Control," is grammatically incorrect
and should be considered for deletion.
Paragraph 6.2.3 contains
the accurate statement.
Additionally, paragraphs 6.2.6 and 6.2.8
referred to nonexistent procedures.
2.
Pages 23 and 24 of Attachment 2 to procedure 1022.06, "ASME Code
Section XI, Inservice Testing Program Unit 1," were incorrect.
The correct information (page 24) was not included.
3.
Paragraphs 2.0, 3.0, and 3.3 of procedure 1032.07, "ISI Program
Requirements," does not reference procedure 1022.07 (Unit 2) even
though procedure 1032.07 was written for both units.
4.
Forms 1000.06B and 1000.06C in procedure 1000.06, " Procedure
Review, Approval, and Revision Control," contained wording in the
10 CFR 50.59 applicability block that stated, in part, " involves a
change to a test or experiment" instead of " involves a test or
experiment" which would be consistent with the language ia 10 CFR 50.59.
5.
Question 2 in Form 1000.06E read, in part, "would the proposed
procedure change ... ." which does not address the fact that
10 CFR 50.59 applies to both proposed procedures and changes.
This is a Severity Level V violation.
(Supplement 1.E) (313/8618-02;
368/8619-02)
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RESPONSE
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The specific examples cited in the violation are discussed below:
1.
The specific paragraphs of the administrative procedure 1000.09,
" Surveillance Test Program Control," noted in the violation are
provided below:
"6.2.2
Surveillance tests that are the scheduling responsibility
of WCC are controlled by this procedure. This includes
most tests with a test frequency of once per week or
longer. Those tests of shorter frequency are scheduled by
responsible departments should be controlled by
departmental procedures."
"6.2.3
Surveillance tests that must be performed more than once
per week are scheduled by the responsible department and
should be governed by departmental procedures."
The last sentence of paragraph 6.2.2 lacks the word "and" to be
grammatically correct and will be revised accordingly. As noted in the
violation, " Paragraph 6.2.3 contains the accurate statement." AP&L
contends that no performance error would have resulted as procedures
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are utilized as complete documents and the noted paragraphs would not
be taken out of context of the complete procedure.
The nonexistent procedures cited in the violation, specifically
paragraph 6.2.6 which references procedure 1015.06, "ASME Code Section
XI Operational Readiness Testing," and paragraph 6.2.8 which
references procedure 1005.01, "M&TE Calibration Program," do in fact
exist but have been assigned different numbers under a reorganization
of administrative procedures. Paragraghs 6.2.6 and 6.2.8 will be
revised to referenct the appropriate procedure numbers. AP&L does not
have an automatic system that identifies all cross referenced
procedures. Several methods do exist for a user to correctly locate
cross referenced procedures. As an example, the procedure tab in the
station procedure manual for procedure 1015.06 contains a form which
informs the user of this procedure's deletion and references the
appropriate replacement procedure number. Additionally the ANO Document
Control System contains the information needed to establish the
chronology of procedure issuance, deletion, renumbering, etc., to
establish necessary cross referencing. AP&L contends that the needed
procedure cross referencing updates cited, though desirable from an
ease of use perspective, would not have resulted in performance errors.
2.
As noted in the Inspection Report, a reproduction error was made during
procedure 1022.06, "ASME Code Section XI Inservice Testing Program
ANO-1," copying for distribution. The data contained on page 24 of the
procedure was a duplication of the data contained on page 23 of the
procedure. This error was made when tne data pages were reducad onto
the procedure form pages. Page 23 contained the correct data. The
correct data for procedure page 24 of the current revision has now been
distributed. This administrative procedure provides an overall
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description of the ANO-1 Inservice Testing Program at:d does not control
pump and valve testing. Actual in-service testing of pumps and valves
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is performed utilizing plant operating procedures; therefore, AP&L
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contends this error would not have resulted in a performance error of
the testing program.
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3.
Procedure 1022.07, "ASME Code Section XI Inservice Testing Program
ANO-2," was originally issued on August 24, 1985.
The current
revision of 1032.07, "ISI Program Requirements," was effective August
1, 1985.
Therefore, procedure 1022.07 was not issued prior to the last
revision of 1032.07.
The noted paragraphs of procedure 1032.07 cited
in violation as not containing a reference to procedure 1022.07 were
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paragraphs 2.0, 3.0 and 3.2.
Paragraph 2.0 of procedure 1032.07
details the scope of the procedure, specifically that "The pump and
valve test program to meet Section XI of the ASME Code is not addressed
by this procedure, but rather is covered by procedure 1022.06 ...."
Paragraph (section) 3.0 of procedure 1032.07 details the references
used to develop procedure 1032.07 in paragraph 3.1 and related ANO
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administrative procedures in paragraph 3.3.
Procedure 1032.07
paragraph 3.2 does not require a reference to procedure 1022.07.
Procedure 1022.07 is not required for implerentation of procedure
1032.07.
Appropriate references to procedure 1022.07 will be added to
procedure 1032.07.
AP&L contends that the omission of the references
to procedure 1022.07 would not have resulted in a performance error of
the Inservice Inspection Program requirements.
Additionally, procedure
1032.07 is an administrative procedure which describes the program and
is not a performance procedure.
4.
Form 1000.06B, Procedure / Work Plan Request, is designed to provide a
description of the purpose or reason for procedure development or
procedure revisions.
It also documents the review and approval process
as delineated in procedure 1000.06.
Form 1000.06C, Temporary Procedure
Change Request, is designed as a method for temporary changes to
procedures.
It is not applicable to original procedure development.
The 10CFR50.59 applicability section of these two forms is formatted to
determine if an unreviewed safety question evaluation is required by
use of the following questions:
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Involves a change to a procedure described in the FSAR
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YES
NO
Involves a change to a test or experiment not described in the
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YES
NO
Involves a change that affects compliance with the Technical
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NO
These forms are utilized for original procedure review but are
primarily structured for procedure changes.
The wording of these three
questions reflect this structure, and this should be recognized by the
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procedure reviewers.
For an incident in which a new procedura is
developed to perform a test or experiment not the FSAR and the
procedure writer misinterprets the question, the review process would
identify the error and return the procedure to the writer.
This
process, by its basic design, would prevent performance errors from
resulting in approval procedure without the proper evaluation for an
unreviewed safety question.
5.
Form 1000.06E, Unreviewed Safety Question Determination, is designed to
document an evaluation of a procedure or a procedure change for an
unreviewed safety question.
The form consists of seven yes or no
questions which directly paraphrase the guidance of 10CFR50.59.a.2.
Each question begins with the phrase "Would the proposed procedure or
change" except that in question 2 the word "or" has been inadvertently
omitted.
Because the questions are applicable in the same sense to a
procedure or procedure change as directed by procedure 1000.06, the
procedure writer should answer the question appropriately.
In fact,
without the word "or" in the question, for a new procedure a yes or no
answer would not be applicable. AP&L contends that this would not
result in a performance error and that even if it was misinterpreted by
the procedure developer, the review process would prevent a performance
error from resulting in an approved procedure with an inadequate
evaluation.
As the Inspector only speculated that performance errors could have resulted
and did not substantiate this inference in the scope of the inspection, AP&L
does not agree that a violation of 10CFR50, Appendix B, Criterion V has
occurred.
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8.
10 CFR 50.59(b) states, in part, "The licensee shall maintain records
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of changes in the facility and of changes in procedures made pursuant
to this section ... The licensee shall furnish ... annually or at such
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shorter intervals as may be specified in the licensee, a report
containing a brief description of such changes, tests, and experiments,
including a summary of the safety evaluation of each."
Contrary to the above, the licensee failed to submit a report of
activities for the years 1984 and 1985.
This is a Severity Level V violation (Supplement I.E.) (313/8618-01;
368/8619-01)
RESPONSE
The preparation of the 198410CFR50.59 report was more extensive than in the
past to ensure that the report contained more detailed summaries of the
activities performed under the guidance of this regulation.
This effort
required additional coordination between Licensing and the groups who
performed the safety evaluations.
However, the result was a more accurate
reflection of the activities that occurred during 1984.
Additionally, both
the 2R4 and 1R6 refueling outages began in 1984, during which an unusually
large number of design changes, processed under the provisions of
10CFR50.59, were implemented.
The 1984 Summary Report has now been completed and was issued to the NRC
July 15, 1986 (0CAN078604). The 1985 report, which will also contain the
more detailed summaries, is currently being prepared for issuance by
September 18, 1986.
In recognition of the problem of timely submittals and in an effort to make
program improvements while maintaining the quality of the reports, AP&L is
currently undertaking corrective action to develop a more efficient and
systematic means of compiling 10CFR50.59 Summary Reports to avoid such
delays. Actions include additional staff guidance on tracking, compiling
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and reporting 50.59 affected changes. These actions should ensure timely
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reporting in the future.
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