1CAN039007, Responds to NRC Re Results of Programmatic Audit of Facility Safety & Performance Improvement Program During Wk of 890909.Memo Transmitted to B&W to Correct Typo on 890928.Transient Reduction Program Encl
| ML20012C865 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 03/13/1990 |
| From: | James Fisicaro ARKANSAS POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20012C866 | List: |
| References | |
| 1CAN039007, 1CAN39007, TAC-68199, NUDOCS 9003260022 | |
| Download: ML20012C865 (5) | |
Text
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March 13, 1990 1
1CAN039007 U.- S. Nuclear Regulatory Commission Document Control Desk
. Mail' Station P1-137 Washington, DC 20555
Subject:
Arkansas Nuclear One - Unit 1 Docket No. 50-313 License No. DPR-51 Safety and Performance Improvement Program Programatic Audit (TAC No. 68199)
Gentlemen:
During'the week of September 9,1989, the NRC Staff conducted a programatic audit of the Arkansas Nuclear One (ANO) - Unit 1 Safety and Performance Improvement Program (SPIP). Your letter of January 16,1990(ICNA019002)
_provided the results of that audit. The purpose of this audit was to determine the adequacy of AN0's program to implement the Babcock & Wilcox
-Owners Group (BWOG) SPIP technical recommendations.
Included in the audit was a review of the dispositioning of-selected recommendations (from incorporation into the Recommendation Tracking-System to final closecut).
The scope of this review included' recommendations that have been
-implemented, are in the process of being implemented, or have been deemed not applicable to ANO-1.
At the exit meeting and in the audit report, the NRC Inspectors had the following favorable comments on our_ program.
1.
The Transient Reduction Program (TRP) procedure clearly defines responsibilities. AN0 personnel were knowledgeab'a with respect Q
to their duties and responsibilities.
m
'2.
There is evidence of good communications among the per;onnel mE8 involved in the TRP process. Transfer of the TRP Coordinator 580-position to the site shows good emphasis by AP&L on the importance oo of the program. The fact that the procedure is being changed to R8_
reflect this shows that the procedure is a living doc e nt.
cD 3.
Packages for the Transient Reduction Program Recommendations (TRs) 88-are complete and auditable.
Documentation included in these packages is good. Actions necessary to implement a recommendation e
appeared to adequately address the intent and basis of the
'88 recommendation.
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4.
That the TRs are tracked on a database is a good practice, as it provides timely and concise reports.
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,l-U.S. NRC-Page 2 March 13, 1990 5.
That the Management Review Group (MRG) team is from all areas of-ANO organization shows good management concern.
6.
From the closeouts of TRs reviewed, it is obvious that management-participation in the closeout process is not jut a " rubber-stamp."
7.
The application of the SPIP program to ANO Unit Two, a Combustion Engineering Plant, shows favorable management receipt of the program.
Additionally the Staff identified several concerns during the Audit.
ANO has taken corrective action to resolve the NRC identified issues as follows:
NRC Concern When the schedule for implementation slips, the SPIP item does not receive a higher priority during the subsequent outage.
Formal documentation on schedule slippage may be needed throughout the review process. A formal justification for schedule delays may be needed.
The staff has requested a copy of the revised procedure showing changes to address this issue.
ANO Response AN0 has addressed the issue of schedule slippage by revising the Transient Reduction Program Document to require additional management review before due dates can be changed. Extensions of due dates are now required to be justified in writing to the Transient Reduction Program Coordinator. This will ensure that the extension is not only documented, but also is based on conscientious decisio, rather than oversight. Thus management attention will be focused on overdue items when extensions are reviewed by the MRG. Additionally, the revised Program Document provides updated job titles as a result of recent ANO reorganization, and clarification of responsibilities. The revised Program Document is attached for your information.
NRC Concern TR-015-MFW (evaluation to determine if a MFW pump low suction pressure
. trip is needed) had an error in the BWOG RTS report. The RTS stated that a 2/3 logic was installed to closeout this recommendation whereas a 2/2 logic was actually installed in the plant.
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U.S.,NRC
- Page 3 March 13, 1990 AND Response:
Memorandum ANO-89-08990 was transmitted to Babcock & Wilcox on September 28, 1989 to correct this error.
This was a typographical error in the original BWOG RTS report.
NRC Concern TR-048-MSS (evaluation of the turbine bypass and atmospheric dump valve preventative maintenance programs) was prematurely categorized as C/0.
The closeout memo identified the Preventative Maintenance Engineering Evaluation Group requirements for an adequate preventative maintenance procedure. However, the procedure was not developed and not addressed in the site training, operations, or maintenance programs.
AN0 Response:
The AN0 Management Review Group (MRG) has reopened and reviewed this TR a second time. After review of this issue, the MRG agreed that Preventative Maintenance (PM) items should be closed on a case by case basis. With changes to our program, closure of a PM item would require completion of the following:
an engineering evaluation, revision of i
the associated procedure, and actual scheduling of the maintenance activity. This will apply to not only this specific PM item, but to others as well. This specific item has been reope?ed to ensure a complete resolution.
NRC Concern 7
TR-181-0PS (Instrument and Display to Access AT0G Parameters) - The staff was concerned as to whether this item was reviewed again in response to the Safety Evaluations (SEs) issued for the Emergency Operating Procedure and Detailed Control Room Design Review.
ANO Response:
To ensure these SEs and other licensing issues are included in the TRP, the Vice President, Nuclear has added a Licensing representative to the MRG. This addition will strengthen the expertise of the MRG by providing direct input into the resolution of TRs of applicable regulatory responses made by ANO.
l
U.S. NRC Page 4 March 13, 1990 NRC Concern TR-066-MFW (evaluation to ensure that a single electrical failure will not cause a loss of both feedwater trains) and TR-179-MFW (identification of areas to enhance the reliability of main feedwater and condensate control) both.had an Engineering Action Request (EAR) currently in effect. However, no action had been taken to resolve these recommendations for nearly 2 years. ANO stated it was concerned over the cost benefit of a complete main feedwater and condensate failure modes and effects analysis (FMEA) and requested additional guidance from the BWOG. This guidance, clarification of recommendation scope, and intent, was not provided until February 1989.
Even though not timely, action on these recomendations-had been reactivated in accordance with a redirection memo of May 3, 1989.
AN0 Response:
Timely resolution of issues is addressed in the revised Program Document. This review requires accountability for schedule slippage at any point in the review process. Any extension of the due date requires justification in writing to the Transient Reduction Program Coordinator.
In order to provide further improvements in the Transient Reduction Program, AP&L plans to place the program under the auspices of the Plant Managers during 1990. This will serve to place increased emphasis on timeliness of corrective actions and ensure corrective actions are specific to each unit.
Should you or your staff have questions in regard to AN0's Transient Reduction Program, please do not hesitate to call.
Very truly yours,
. }.h" Jam J. Fisicaro Manager, Licensing JJF/ CWT /1w Attachment
,o U.S. NRC Page 5-March 13, 1990 cc:
Mr. Robert Martin U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 NRC Senior Resident Inspector Arkansas Nuclear One - ANO-1 & 2 Number 1, Nuclear Plant Road Russellville, AR 72801 Mr. Thomas Alexion NRR Project Manager, Region IV/ANO-1 U. S. Nuclear Regulatory Commission NRR Mail Stop 13-D-18 One White Flint North 11555 Rockville Pike Rockville Maryland 20852 Mr. Chester Poslusny NRR Project Manager, Region IV/AN0-2 U. S. Nuclear Regulatory Commission NRR Mail Stop 13-D-18 One White Flint North 11555 Rockville Pike Rockville, Maryland 20852