05000368/LER-1990-001, :on 900126,identified That Required Visual Insps of Containment Bldg After Entry Made Not Documented as Being Performed.Caused by Inadequate Procedural Guidance. Administrative Controls to Be Established

:on 900126,identified That Required Visual Insps of Containment Bldg After Entry Made Not Documented as Being Performed.Caused by Inadequate Procedural Guidance. Administrative Controls to Be Established

ML20011F731
Person / Time
Site:	Arkansas Nuclear
Issue date:	02/23/1990
From:	Ewing E, Millar D ARKANSAS POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
2CAN029007, 2CAN29007, LER-90-001, LER-90-1, NUDOCS 9003070330
Download: ML20011F731 (4)

LER-1990-001, on 900126,identified That Required Visual Insps of Containment Bldg After Entry Made Not Documented as Being Performed.Caused by Inadequate Procedural Guidance. Administrative Controls to Be Established

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(1) 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2) 10 CFR 50.73(a)(2)(ii)
3681990001R00 - NRC Website

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Arkansas Power & Ught Company.

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Arkansas Near One RoJe S. Da 137 G Russenedie, AR 70N)1 Tel 501964 3100 i

February 26, 1990 r

2CAN629007 p

U. S. Nuclear Regulatory Commission Document Control Desk Mail Station P1-137 Washington, D. C.

20555

$UBJECT:

Arkansas Nuclear One - Unit 2 Docket No. 50-368 i

b License No. NPF-6 License Event Report No. 50-368/90-001-00 l

Gentlemen:

In accordance with 10CFR50.73(a)(2)(1)(B), attached is the subject report concerning inadequate procedural guidance.

This condition resulted in the failure to perform a visual inspection as required by Technical Specification 4.5.2.c.2.

The visual inspection verifies that no loose debris is present in the affected areas of the containment building after entry when containment integrity is established.

Very truly yours, E. C. Ewing General Manager, Technical Support and Assetsment ECE/0M/sgw attac'.iment cc:

Regional Administrator Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 INP0 Records Center 1500 Circle 75 Parkway Atlanta, GA 30339-3064 11l 900307o33o 900223 D

PDR ADOCK 05000368 tb R-prge An Entergy Compaw E:

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Fom 1062.01A NRC Form 366 U.S. Nuclear Regulatory Comeission (9 83)

Approved OMB No. 3150-0104 Expires: 8/31/85 LICENSEE EVENT REPORT (L E R)

FACILITY NAMI (1)

Arkansas huclear One, Unit Two jDDCLET NUPSER (2) (PAGE (3) 10151010!01 31 61 81110Fl013 TITLE (4) Insoequate Procedural Guidance Resultto in Failure to Perform a Visuai Inspection as Required by Technical Specifications of Affected Areas in Containment After a Containment Entry when containsient Integrity was Established

~IVENT DATE (5)

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REPORT DATL (7)

OTHFR FAC] LIT]E5 INVOLVED (8) l Monthi Day,1 l lJequntiell ikevision l

l Year Year i Nunter Number ' Month Day ' Year l

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Technical Specifications require that a visual inspection of the effected areas of the containment building be performed after an entry is made while containment integrity is established. The intent of the inspection is to ensure there is no loose debris lef t in the containment building which could collect in the containment building sump and cause restriction of pump suctions during LOCA conditions.

On January 26, 1990, it was identified that the required inspections had not been documented as being perfomed. The failure to document the completion of the surveillance requirement had existed since plant construction. Current ANO administrative housekeeping procedures direct employees to remove any tools, equipment, materials, trash or debris upon completion of a work activity. Therefore, the controls were in place to minimize debris or other materials when a work activity was completed in

. containment. No significant safety concerns have been identified. The root cause of this event was inadequate procedural guidance. The form used to perform containment building visual inspections was a part of the plant heatup procedure and no guidance was given in other procedures to use the form at times when containment building entries were made with containment integrity established. Administrative controls will be established to ensure a visual inspection is performed as required by Technical Specifications. This event is reportable pursuant to 10CFR$0.73(a)(2)(1)(B).

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Fom 1062.01B NRC f ore 366A U.S. Nuclear Regulatory Commission (9-83)

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LICENSE: EVENT REPORT (LER) TEXT CONTINUATION

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LYear Number humber i 10151010101 31 61 81 91 0 01 01 1 01 0101210F1013 ItK1 (If more space is requitec, use t.acitional NRC Form 3664's) (17)

A.

Plant Status i

At the time of occurrence of this event Arkansas Nuclear One, Unit Two (AND-2) was operating at 100 percent of rated thersal power in Mode 1 (Power Operation). Reactor Coolant System (RC5) [AB) pressure was approximately 2250 psia and RCS temperature about 580 degrees Fahrenheit.

8,

Event Description

Following the completion of a containment building entry when containment building integrity is established, Technicel Specification 4.5.2.c.2 requires that a visual inspection be performed, lhe intent of this inspection is to verify that no loose debris is present in the containment butiding which could be transported to the containment building sump and cause restriction of the pump suctions (i.e., High Pressure Safety Injection (HPSI) [BQJ or Low Pressure Safety injection r

(LPSI) [BP) or Containment Spray (CS) [BE) pumps) during Loss of Coolant Accident (LOCA) conditions, i

The inspection should be performed in the areas of the containment building where loose debris may t -

be present as a result of a maintenance activity which was performed. On January 26, 1990, while reviewing Technical Specification 3.5.2 (Emergency Core Cooling System (ECCS) subsystems) and the associated surveillance requirements, as part of the operations requalification traiaing program, it was discovered that the requirements of Technjcal Specification 4.5.2.c.2 were not being documented as having been performed. Although, visual inspections of the containment building have not been documented, the operators have routinely performed inspections as a good operating practice, however, not to comply with Technical Specifications. The failure to properly document the performance of this surveillance requirement has existed since plant construction.

C.

Safety Significance

The primary concern related to this condition was the potential for loose debris collecting in the containment building sump which could cause restriction of pump suctions during LOCA conditions.

l Prior to a plant bestup following a refueling outage or a maintenance outage, a containment building visual inspection is performed by the operations staff. The purpose of the inspection is i

to ensure the containment building and the containment building sump suction lines are free of debris and other areas of the building are pruperly prepared for heatup. The visual inspection performed as part of the plant heatup is documented on a fem included in an ANO operations procedure used only during plant heatups. An ANO plant administrative procedure, governing plant housekeeping practices, provides guidance to employees regarding their responsibilities. The procedure states that it is the responsibility of each individual to ensure he removes any tools,

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equipment, materials, trash or debris upon completion of hit work activity. Since a visual inspection is perforsed prior to a plant heatup which verifles that the entire containment building is free of debris, only the work area would t e of concern wha 7 an entry is made with I

containment integrity established. Current practices based on the plan 6 housekeeping procedure provide a level of assurance that the affected area of the contoineent building is left in a clean

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condition upon containment 6xit. Therefore, as a result of this condition, no significant safety concerns exist.

L D.

Root Cause l

The root cause of this event was procedural inadequacy. During the initial review of Technical Specification surveillence requirements a fors was created to perform a visual inspection of the containment building. The fore was incorporated in a procedure which was used only during plant heatups. When a containment building entry was made with containment building integrity established there was no procedural guidance to use the existing fore or to direct the operator to the plant heatup procedure. The lack of procedural guidance resulted in a failure to properly document and verify that a visual inspection of the affected area in the containment building had been performed when containment integrity was established.

E.

Basis for Reportability

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Technical Specification 4.0.3 states that the failure to perform a surveillance requirement within the specified time interval shall constitute a failure to meet the operability requirements for a Limiting Condition for Operation. Since it has not been documented that a visual inspection of the affected areas in the containment building has been performed when a containment building entry was made and containment building integrity established, the operability requirements for the ECCS subsystems were technically not satisfied. Therefore, this event is reportable pursuant to 10CFR50.73(a)(2)(1)(B), operation prohibited by Technical Specifications.

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LICENSEE fvtNT REPORT (LER) TEXT CONTIN 0ATION FACILITY R4ME (1) lDOCKEl NUMBER (2) l

.ER WOMBER (6) l PAGE (3) l l

l lJequentiall l Revision l Arkansas Nuclear One, Unit Two l

l Yearl Number Number l 10151010101 31 61 81 IT 01--

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Di ol013lOr1013 TEK1 (If more space is required, use additional NRC Fore 366A's) (17)

F.

Corrective Actions

Additionel administrative controls will be established to ensure a visual inspection of the affected areas

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in the containment building is performed at the completion of a containment building entry when containment integrity is established. This should ensure that the surveillance is properly performed and documented 4A required. The procedure revision will be completed by April 15, 1990.

G.

Additional Infore.ation Previously reported events in which inadequate procedural guidance resulted in the failure to perform a required Technical Specification surveillance were reported in LERs 50-313/89 032-00, 50-313/89-033-00 and 50 368/86-015-00.

Energy Industry Identification System (EII$) codes are identified in the text 4s [XX).

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