ML20205K884

Ack Receipt of 860829 & s Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-313/86-18 & 50-368/86-19

ML20205K884
Person / Time
Site:	Arkansas Nuclear
Issue date:	03/27/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Campbell G ARKANSAS POWER & LIGHT CO.
Shared Package
ML20205K887	List: 0CAN038707, Responds to NRC Re Suppl Info for Insp Repts 50-313/86-18 & 50-368/86-19 on 860725.Concerns Re Deficiencies Found in Procedures Discussed W/Staff & Improvements to Procedural Requirements Program Underway IR 05000313/1986018 ML20205K884
References
NUDOCS 8704020061
Download: ML20205K884 (1)

See also: IR 05000313/1986018

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EAR 2 71987 -

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! In Reply Refer To:

Dockets:- 50-313/86-18

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50-368/86-19

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Arkansas Power & Light Company

l ATTN: Mr. Gene Campbell

Vice President, Nuclear

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P. O. Box 551

Little Rock, Arkansas 72203

Gentlemen:

Thank you for your letters of August 29, 1986, and March 11, 1987, in

response to our letters and Notice of Violation dated July 25, 1986, and

January 9,1987. 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, I

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Orlz?nd sivua 2, '

J. E. Gca!!ardo ,

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

bectoDMB(IE01) $$40jDobk!OS$313

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bec distrib. by RIV:

RPB RRI R. D. Martin, RA

R&SPB SectionChief(RPB/B) D. Weiss, RM/ALF-

RIV DRSP RSB

MIS System RSTS Operator Project Inspector

R. Hall .

PI C:RPBh C:RPB -

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ME urphy cs QRHunter JEGagl do / I

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3/77/87 3A7/87 3/4187 ,

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AAKANSAS POWER & UGHT COMPANY

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POST OFFICE BOX 551 UTTLE ROCK. ARKANSAS 72203 (501) 3714000 ,.

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August 29, 1986

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50l@20W2W

SCAN 088614

fJj SEP -81506 fj

Mr. J. E. Gagliardo, Chief L

Reactor Projects Branch

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

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License Nos. DPR-51 and NPF-6

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Response to Inspect.on 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,

f f^- ~

y J. T os, Manager

Nuc)ea Engineering and Licensing

JTE:RJS:lw

Attachment

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NOTICE OF VIOLAT10N ,

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DuringanNRCinspectionconductedduringtheperiodMa/h31,N986,

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violations of the NRC requiremamts were identified. Th.: violations involved pM ! ,,'j

failure to lock a manual valve. in position as requirsd ', fe'flure to heee

adequate controls over the installation of temporsry sc /fsids in the

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vicinity of safety-related eq',ipment, and 'f ack o/ calibrt. tion data tha*. g/[, g

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would demonstrate the accuracy of measurement'of,the admixture liquW

l' dispenser being utilued at the concrete supplier's facility. The specific

finaings and AP&L's rasponse to each are listed below. ..

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A. 10 CFR 50, Appendix B.0triterion-V Mates, in part, "ActiviUes

affecting quality shall be prescrited by documented instructions, ,

procedures, ... of a type appropriat'e to the circumstances and shall be ,,

accomplished in 'accordance with thesa instructions;jreteJures. ... ANO /

procedures 1000.04, " Procedural Program Requirements," Movisiod 20, jnd -

- 1000.06, " Procedure Review, Approval, and Revision' Control," Revis hn ,l'  !

l 22, implemented these requirements.. '

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t pary to the above, c .*,usber of deficiencies were foundin ver fus

i procedures which could result in perfn mence errors. The following are 1  ;

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i 1. The last sentence in paragraph 5.2.2 of roceduce 1000.09,?

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_;,,,. " Surveillance Test Program Control " is prammatically inc'or m.t ,

j and should be considered for deletion. Paragraph 6.2,3 conttins ,

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the accurate statement. Additionally, paragraphs.6.2.6 and 6f.l '

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} referred to nonexistent procedutas. i

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2. Pages 22.end 24 of Attachovnt 2 te procedure 1022.06, "ASME Codo >

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Section'XI. Insoryice Testing Program Unit 1," were incorrect? ,

The correct informativ. (pa{e 24) was not included. , ,  ;

l 3. Paragraphs 2.0, 3.0, and 3.3 of p?ocedure 1032.07, ."ISI Program

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Requirements," do+it net referent.w',oracedure'1022.tfr (Unit 2) even '

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though procedute IM2.07 was writ, ten for3oth unit's. 5. l \

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l 4. Forms 1000.068 ar.d 1000.06C in prore' dure 1000.06 ,"hscedure i I

Review, Approval,, and Revision CoM,rol," scntained wording in the ,

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10 CFR 50.59 applicability, felock that stated, in part; involves a

change to a itest or experiment" insted of " involves ) tset or I

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1, experiment" which would be consistent Mth the 'lar.2ual,e in 10 CFR i

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l 5. Question 2 in Form 1000.06E read, in part, "vould the ,r,coposed

i procedure change ... ." which does not addren the fan tlat

! 10 CFR 50.59 applies to both proposed prossdures and t.harges. -

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i This is a Severity Level V violatlon. F

! 368/8619-02)  ;

(Supplement ) 1.E)

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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

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."

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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)

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RESPONSE

The preparation of the 1984 10CFR50.59 report was more extensive than in the

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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

l the 244 and IR6 refueling outages began in 1984, during which an unusually

large number of design changes, processed under the provisions of

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10CFR50.59, were implemented.

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The 1984 Summary Report has now been completed and was issued to the NRC

July 15, 1986 (OCAN078604). 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

and reporting 50.59 affected changes. These actions should ensure timely

reporting in the future.

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RESPONSE

The specific examples cited in the violation are discussed below:

1. The specific paragraphs of the administrative procedure 1500.09,

" 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."

"G. 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

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contends that no performance error would have resulted as procedures

7.- are utilized as complete documents and the noted paragraphs would not

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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 reference 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 i

appropriate replacement procedure number. Additionally the ANO Document

Control System contains the information needed to establish the

chronolagy of procedure issuance, deletion,' renumbering, etc., to

establish necessary cross referencing. AP&L co'n tends 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

l procedure was a duplication of the data contained on page 23 of the

t- proceduro. This error was made when the data pages were reduced 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 I

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description of the ANO-1 Inservice Testing Program and does not control

pump and valve testing. Actual in-service testing of pumps and valves

is performed utilizing plant operating procedures; therefore, AP&L

i contends this error would not have resulted in a performance error of

the testing program. ..

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

paragraphs 2.0, 3.0 and 3.2. Paragraph 2.0 of procedure 1032.07

l details the scope of the procedure, specifically that "The pump and

l valve test program to meet Section XI of the ASME Code is not addressed

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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

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 implementation 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

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t- the Inservice Inspection Program requirements. Additionally, procedure 1

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1032.07 is an administrative procedure which describes the program and

is not a performance procedure.

4. Form 1000.068, 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

YES NO

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Involves a change t, ' test or experiment not described in the

FSAR

YES NO

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Involves a change that affects compliance with the Technical

• Specification i

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'YES NO I

These forms are utilized for original procedure review but are

primarily structured for procedure changes. The wording of these three I

questions reflect this structure, and this should be recognized by the

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procedure reviewers. For an incident in which a new procedure 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

j unreviewed safety question,

f 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 guioance 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.

]S-' 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 8, Criterion V has

occurred.

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