ML20210R839
| ML20210R839 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 02/10/1987 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Campbell G ARKANSAS POWER & LIGHT CO. |
| References | |
| NUDOCS 8702170509 | |
| Download: ML20210R839 (1) | |
See also: IR 05000313/1986025
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Ia Reply R:;f;r To:
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Dock:;ts: . 50-313/86-25-
50-368/86-26
FEBIOlig
Arkansas Power & Light Company
ATTN: Mr. Gene Cam:'oell
Vice President, Nuclear
Operations
P. O. Box 551
Little Rock, Arkansas
72203
Gentlemen:
Thank you for your letter of January 21, 1987, in response to our letter
and Notice of Violation dated October 6,1986. We have reviewed your reply and
find it 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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Sincerely,
Orichal Shned By
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.J. E. Gagliardo, Chief
Reactor Projects Branch
cc:
J. M. Levine, Director
Site Nuclear Operations
Arkansas Nuclear One
P. O. Box 608
Russellville, Arkansas
72801
Arkansas Radiation Control Program Director
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ARKANSAS POWER & LIGHT COMPANY
POST OFFICE BOX 551 UTTLE ROCK. ARKANSAS 72203 (501)371-4000
January 21, 1987
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Mr. J. E. Gagliardo, Chief
Reactor Pro.iects Branch
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U. S. Nuclear Regulatory Commission
Region IV
611 Ryan Plaza Drive, Suite 1000
Arlington, TX 76011
SUBJECT: Arkansas Nuclaar One - Units 1 & 2
Docket Nos. 50-313 and 50-368
Response to Inspection Report
50-313/86-25 and 50-368/86-26
Dear Mr. Gagliardo:
In accordance with 10CFR2.201, attached is the response to Violation B of
the subject inspection report.
Violation A has been resolved, and no
response was required, as noted in Appendix A of your October 6, 1986
letter.
Very truly yours,
. Ted Enos, Manager
Nuclear Engineering and Licensing
JTE/RJS/sg
Attachment
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MEMDEA MiOOLE SOUTH UTsuTIES SYSTEM
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During an NRC inspection conducted on July 28 through August 1,1986,
violations of the NRC requirements were identified. The violations involved
inadequate quality assurance records associated with Category I structural
concrete production and failure to conduct independent monitoring of
contractor activities during inservice inspections that were performed on
Unit 2 components.
In accordance with the " General Statement of Policy and
Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986),
the violations are listed be'.uw:
ISI Implementation
Criteria IX of Appendix B to 10CFR50 states, in part, that " measures shall
be established to assure that special processes, including nondestructive
testing, are controlled and accomplished in accordance with applicable
codes, specifications, and criteria";
i.e., procedures.
Section 9.5 of the AP&L Quality Assurance Manual Operations reouires that
the " Performance of special processes in accordance with applicable codes,
standards, specifications and plant procedures is verified by Quality
Control personnel through their surveillance and inspection activities..."
Quality Assurance Procedure QAP-7, Revision 1, " Site Contractor Control",
paragraph 5.7.2(d), included a question concerning AN0 quality control (QC)
monitoring of site contractor activities in accordance with Procedure
1000.012.
ANO Procedure 1000.012, Revision 7, " Control of Site Contrac+ ors", paragraph
6.6.15, required AP&L QC to provide inspection and/or surveillance of
contractor work activities.
Contrary to the above, the licensee representative stated that although
surveillances were conducted during other contractor ISI activities, ANO QC
had not performed surveillances and/or inspected Combustion Engineering ISI
inspection activities.
This is a Severity Level IV violation (Supplement II) (368/8626-02).
Response to Violation
AP&L quality control surveillance was not provided for the CE ISI activities
due to our understanding of the QA/QC services to be provided by CE under
the terms of their contract. AP&L Quality Control surveillances were
focused on other contractor activities including inservice inspections of
the steam generators by eddy current testing and inspections of hydraulic
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Measures were taken to assure that the CE ISI activities were " controlled
and accomplished by qualified personnel using qualified procedures in
accordance with applicable codes, standards, specifications, cri.teria, and
other special requirements." AP&L has an ISI coordinator who maintains the
ISI Program. His review of the NDE contractor's procedures, personnel
qualifications, equipment and material certifications was documented on the
- Certification Review Report. Quality Control review was performed as
required by the ISI Program and was documented on this report form as well.
Additionally, Combustion Engineering's quality assurance program is
periodically audited by AP&L Quality Assurance. For these reasons, AP&L is
of the opinion that the CE ISI activities ~ performed were of acceptable
quality, that the personnel perfonning the activities were adeouately
qualified, and that the equipment utilized was acceptable. Regulations do
not specifically require AP&L Quality Control inspections or surveillances
of special processes when such activities are performed under an approved
contractor Quality Assurance program. However, AP&L agrees it is prudent to
provide selected AP&L Quality Control inspections or surveillances for an
activity of this magnitude and safety significance.
The AP&L procedures referenced in the violation do not specify the extent of
QC coverage of special processes including ISI activities.
To define more
clearly the role and involvement of QC in ISI as well as other contractor
work activities, the following plant procedures are being
reviewed / developed:
(a) AP&L's procedure for control of site contractors will place
responsibility upon the QC Superintendent to determine specific
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monitoring requirements for applicable contracts 'to ascertain
procedural compliance; and will require the contract coordinator to
notify QC whenever specific work involving those monitoring
requirements is initiated.
(b) AP&L's procedure for contract administration will include notification
to QC of contracts initiated and notification to QC by the contractor
prior to beginning work on site.
(c) AP&L's procedure for the implementation of our Quality Control program
will require the ISI group to notify QC prior to performing
refueling / outage ISI activities.
(d) ~AP&L's procedure which specifies ISI Program requirements will require
the ISI coordinator to notify QC whenever an ISI contractor is to
commence NDE work.
The procedural changes will remove the ambiguity of the present procedure
requirements. Completion of these revisions is expected by 1/31/87, and
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thereby, will assure full compliance prior to future outages requiring ISI
activities.
Quality Control has provided coverage on a percentage of the NDE work
activities performed by the AN0-1 NDE contractor during the IR7 refueling
outage.