IR 05000313/1981026
| ML20010H971 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 08/31/1981 |
| From: | Callan L, Randy Hall, Hunnicutt D, Jaudon J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20010H967 | List: |
| References | |
| 50-313-81-26, 50-368-81-25, NUDOCS 8109290458 | |
| Download: ML20010H971 (10) | |
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APPENDIX U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF IiiSPECTION AND ENFORCEMENT l
REGION IV
Report:
50-313/81-26 License:
DPR-51 l
50-368/81-25 NPF-6 J
Licensee:
Arkansas Power and Light Company Post Office Box 551 Little Rcck, Arkansas 72203 Facility Name:
Arkansas Nuclear One (ANO), Units 1 and 2 Inspection at:
AN0 Site, Russellville, Arkansas and at Little Rock General Office (LRGO), Little Rock, Arkansas Inspection Conducted: August 3-7 and 18-20, 1981 Inspectors:
W j f. P. Jaudon, Reactor Inspector, Systems and D&te d'
Technical Section (paragraphs 1-7)
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L. J. Callan, Reactor Resident Inspector, Reactor Date/
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Projects Section 2 (paragraphs 1, 2, 6 and 7)
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Approved:
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~R E. Hall, Chief, Systems and Technical Section
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sbAM Nukw&
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D. M. Hunnicutt, Chief, Reactor Projec-ts Section 2 Dhte Inspection Summary:
Inspection Conducted on August 3-7 and 18-20, 1981 (Report 50-313/81-26; 50-368/81-25)
Areas Inspected:
Routine, unannounced inspection of operator requalification training non-operator training, safety review committee and off-site support.
The inspection involved 60 inspector-hours by two NRC inspectors.
Results: Within the four areas inspected, no violations or deviations were identified.
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8109290458 910904
DR ADOCK 05000
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DETAILS 1.
Persons Contacted B. Austin, Assistant Office Services Supervisor
- B. Baker, Operations Manager M. Bishop, Office Services Supervisor J. Constantin, Training Coordinator, Unit 2 L. Duggar, Special Projects Manager T. Green, Training Coordinator J. Griffin, Assistant Vice President, Nuclear Operations
- D. Horton, "anager Quality Assurance
- L. Humphrey, Administrative Marager R. Lane, Manager Mechanical Engineering
- J. O'Hanlon, General Manager
- M. Pendergrass, Director Generation Engineering
- R. Roderick, Human Resources Supervisor J. Simmons, Training Coordinator, Unit 1
- J. Vandergrift, Trainino and Counseling Supervisor J.Waid,TrainingCoordinator R. Wardlaw, Drafting Supervisor The NRC inspectors also contacted other plant personnel including administrative, clerical, engineering and maintenance personnel.
- Denotes presence at the exit interview conducted August 7, 1981.
- Denotes presence at the exit interview conducted August 20, 1981.
2.
Operator Requalification Training The NRC inspectors reviewed the licensee's operator requalification training program.
The requirements for the requalification training program are delineated in license Procedure 1023.08 Revision 1 (February 12, 1981) " Operations Training Program." The NRC inspector found that Procedure 1023.08 implemented the requirements of 10 CFR 55, Appendix A.
10 CFR 55, Appendix A provides two methods for determining the scope of the annual requalification training program.
These methods are:
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a.
" Annual written examinations which determine areas in which retrainine is needed to upgrade licensed operator and senior operator Knowledge."
b.
" Systematic observation and evaluation of the performance and competency of licensed operators and senior operators by supervisors and/or training staff members..."
The NRC inspectors found that the annual examination foi Unit 1 operators had not identified any areas for licensed operators or senior operators
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who normally stood watchs in which additional training was required.
The NRC inspectors determined that the annual evaluations for Unit 1 operators also did not identify any areas in which additional train-ing was required. The evaluations were found to be brief and limited to evaluations such as, " operator performs satisfactorily," and
"(Name) performed his duties as Shift Supervisor very well." The NRC inspectors expressed concern to licensee maergement that, although the literal requirements of 10 CFR 55, Appendix A and Procedure 1023.08 were apparently being met, the intent of these requirements hsd not been met. Licensee representatives stated that they had in the past identified specific areas and/or individuals requiring additional training but that these deficiencies had been rem ~iied by prompt retraining. Licensee representatives also infonneo the NRC inspectors that the evaluation methodology was being re-written in order to improve it.
For Unit 2, the NRC inspectors found that a similar situation existed with regard to evaluations. The Unit 2 annual examination results were under evaluation by the licensee; as a result, the retraining schedule for 1981-82 had only been promulgated for the first six months of the retraining cycle and included only heat transfer, fluid flow, thermodynamics and mitigation of accidents involving a degraded core. The entire retraining schedule for Unit 1 had been promulgated but included only the subjects delineated above.
The NRC inspector reviewed the annual exam results for Unit 2 licensed operators and senior operators. These results identified five individuals with one or two areas of weakness each but no clear pattern of genaral weakness was evident. The NRC inspector then reviewed the examination results using ar. " acceptable score" on the examination increased by five percent. With this higher threshold it was now apparent that there were three areas in which a pattern of general weakness existed.
In a subsequent interview with a licensee repre-sentative responsible for Unit 2 training, the NRC inspector found that the same areas were quickly ider6tified by the licensee repre-sentative as areas of relative weakness.
The licensee's requalification training program for 1981-82 is con-sidered to be an unresolved item pending completion of revision of the evaluation methods and promulgation cf complete schedules for operator and senior operator retraining (50-313/8126/01; 50-368-8125-01).
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The NRC inspectors noted that both units were on a four section shift i
rotation. Licensee representatives indicated that this resulted in having to conduct all training _ on an overtime basis.
The NRC ir.spectors found that among licensec efforts to train and to qualify additional operators was one program which starts with
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high school graduates and after seven and a half years, would produce personnel who were qualified as Senior Reactor Operators.
The first class in this program is now underway and has completed approximately six months of training.
The NRC inspectors found that the licensee's actions to correct other specific problems noted during the July 1980 inspection (50-313/80-12 and 50-368/80-12) with requalification training
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appeared effective in that similar problems were not found during this inspection. The NRC inspectors were informed by licensee representatives that the licensee had contracted to build a Unit I similator and that study of a Unit 2 timulator was underway.
There were no violations or deviations identified in this area of the inspection.
3.
Trairing The NRC inspector reviewed the licensee's program for training nori-licensed personnel. This review was divided into the following specific areas: procedurt.s; general employee training; on-the-job training; training facilities and staff; and training records.
a.
Proce.dores The NRC inspector found that the licensee had issued procedures to cover each aspect of training. These procedures are listed in Appendix A to this report. Review of some of these procedures led the inspector to cenclude that the licensee had a compre-hensive and interlocking set of procedures to ecver all aspects of training. There were no violations or deviations found in this area of the inspection.
b.
General Employee Training The NRC inspector reviewed licensee Procedure 1023.07 Revision 0 (December 10, 1980) " General Employee Training Program." This procedure assigns responsibilities for General Employee Training (GET) and requires each new employee to receive training in.
General Employee Security Emergency Plan Health Physics Indoctrir.ation QA/QC Indoctrination Fire and Industrial Safety Plant Systems Job-Related Procedures (appropriate 'o the employee's job)
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The NRC inspector noted that this Procedure 1023.07 requires all employees to receive the presentation of " Instruction Concerning Prenatal Radiation Sposure" (i.e., Regulatory Guide 8.13).
Licensee representatives stated that this precludes the possibility of having a male worker become a (temporary) supervisor without benefit of this indoctrination. The NRC inspector noted that Procedure 1023.07 required annual retraining in security, emergency plan, radiation protecticn (for those employees whose duties required entry into radiological areas), QA/QC and fire and industrial. The NRC inspector reviewed selected GET records and inteviewed employu. No violations or deviations were identified in this area of the inspection.
c.
On-the-Job Training The NRC inspector reviewed license Procedure 1023.05 Revision 1 (July 23, 1981) "On-the-Job Training Program." The inspector noted that in each area of maintenance or technical support the licensee had defined four achievement levels for each task or
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Job area. The NRC inspector found that the on-the-job training (0JT) records were maintainea by line supervisors for each individual and that these were reviewed at two week intervals by training coordinators in additicn to the responsible super-visors. Licensee training representatives stated that in addition to verifying compliance with procedural requirements, the checks of 0JT records provided a means of identifying areas in which training was required. The NRC inspector established by interview that craftsmen were aware of their 0JT records and that they believed these records were being updated to reflect individual training / qualification progress. There were no violations or deviations identified in this area of the inspection.
d.
Training Facilities and Staff The NRC inspector noted that the licensee had provided facilities at the Emergency Response Center, which is approximately six tenths of a mile from the site.
This new training location has office space for the training staff, an auditorium (which may be sub-divided into two smaller auditoriums), a library, computer terminals, and extensive classroom and laboratory /
workshop facilities.
The NRC inspector noted that the on-site training staff was twelve people plu'. two clerical assistants.
Licensee representatives stated that additionally there were some eight full time consultants in direct support of training. Licensee representatives informed the NRC inspector that the manpover allowance for the training staff had recently been increased to 29 (with a further increase to 33 authorized). The NRC inspector noted that the ratio of site employees to training staff had
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been u proximately 66 to 1 in July 1980. The ratio at the time of this inspection was 27 to 1.
The projected ratio, when training was fully staffed (and assuming some growth in licensee site strength) was estimated to become less than 20 employees per each member of the training staff. The inspector concluded from the facilities and staffing level (actual and projected) that the licensee's previously stated commitments to training were being implemented.
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Training Records The NRC inspector noted that the licensee was microfilming all training records.
It was also determined that the licensee used a computer system to identify training given to individuals and to provide the microfilm address of specific trainig records.
The NRC inspector checked approximately 120 computer entries and the corresponding microfilm records.
From this check, the inspector concluded that the training records system was being used to maintain records and did provide accurate and rapid recovery of stored data. At the time of the inspection, the licensee was in the process of making modular program updates and improvements, which licensee representatives stated were to improve reccrd retrieval and to facilitate the management of stored data.
There were no violations or deviations identified in this area of the inspection.
4.
Safety Review Committes The NRC inspector reviewed the licensee's implementation of the Technical Specifications requirement for the Safety Review Committee (SRC). This review included procedures, meeting minutes, and audit schedules and reports. The SRC is operated in accordance with the " Safety Review Committee Manual," Revision 1 (May 1981). This manual had been approved by the SRC Chairman and provided a cetailed instruction for the composition and operation af the SRC and supporting functions (e.g., SRC secretary). The NRC inspector determined that this manual was consistent with and encompassed all of the SRC related requirements of the Technical Specifications. By review of SRC minutes, the NRC inspector determined that the SRC had a formal, scheduled meeting each month. This monthly meeting was held alternately at the general offices in Little Rock and at the facility site in Russellville.
The minutes also indicated that additional meetings were held between the scheduled monthly meetings to discuss specific, urgent topics.
The NRC inspector noted that at these unscheduled neetings, the licensee used conference calls to tie together the SRC members at the site with those at the general office. During an interview, a licensee represcritative informed the NRC inspector that these conference calls
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were not a " telephone poll" but were the gathering of SRC members at two locations and then tying the locations together by speaker phone so that maximum member participation could be achieved for an urgent meeting.
The NRC inspector noted that SRC meeting agenda a A supporting docu-mentation, which was often vohrainous, were filed in one month's meeting record, while the approved minutes were filed with the records of the following scheduled meeting. Thus, to review the complete record of a meeting, the records of two monthly meetings were required. Although this record system appeared to be some-what cumbersome, the NRC inspector was able to trace the review and action taken by the SRC on several examples selected.
The NRC inspector found that the licensee had implemented the Technical Specification audit requirements of the SRC by integrating these requirements into the Quality / surance audit plan. All detailed audits were then conducted by Quality Assurance (QA) personnel. The NRC inspector did find that in some instances a member of the SRC with special expertise had either reviewed or made input to a QA audit check list. The SRC received all QA audits and documented this review in the SRC minutes. Additionally, the SRC conducted four management audits annually. These management audits, which were conducted by SRC members, were essentially overview audits. The NRC inspector noted that the licensee's methodolgy for implementing the requirement for SRC cognizance over specified audits seemed to be at variance with the AN0 " Quality Assurance Manual" (APL-TCPIA Revision 5), which in paragraph 18.1 states, " Quality Assurance section performs audits of these activities except for those activities identified in Section 6.5.2 of the Technical Specifications, which are performed by the Safety Review Committee... " A licensee representative stated that a revision of the ANO Quality Assurance Manual which would correct paragraph 18.1 to reflect the audit philosphy in effect would be pre-pared during the last quarter of 1981 and forwarded to the NRC during the first quarter of 1982.
There were no violations or deviations identified in this area of the inspection.
5.
Off-Site Support The NRC inspector reviewed the licensee's program to support Arkansas Nuclear One (ANO) with quality assurance, engineering and technical personnel.
The NRC inspector found that the licensee had increased the manning authorization for nuclear quality assurance personnel from 7 to 10 billets during the last year. Actual manning had increased from 6 to 9 over the same period. A licensee representative stated that there had also been an increase in the manning authorization for
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non-nuclear quality assurance personnel. The licensee representa-tive further stated that this increase in quality assurance manning was the result increased quality assurance responsibilities resulting from implementation of Revision 5 of the " Quality Assurance Manual,"
the increased scope of auditing (paragraph 4, above), and a management decision to make increased use of quality assurance as a management tool. The NRC inspector found that quality assurance personnel met the requirements of ANSI 18.1 (1971) and that the licensee maintained a training program for them with supporting records.
The NRC inspector determined that the manning authorization for gene-ration engineering was 49, an increase of 9 over 1980; a further increase was contemplated for 1982. The licensee maintains separate engineering staffs at all generating facilities. Although the genera-tion engineering staff r.omina11y supported all of the licensee's generation facilities, the NRC inspector was told during interviews with all levels of the licensee's staff that approximately 90% of the generation engineering time and effort was expended in support of ANO. The NRC inspector found that the licensee had maintained an in-house professional development program of two hours a week for generation er.gineering engineers; recently, the licensee had conducted " code training" (ASME, Sections III and XI) for the engineers.
Engineers interviewed indicated that they made frequent visits to AN0 and the liaison with the plant staff was good.
The Drafting support for all facilities operated by the licensee, consists of a supervisor, seven draftsmen and two clerks at the time of the inspection. These personnel are in addition to the i
engineering staff. A problem with the timeliness of drawing update
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had already been identified in IE Report 50-313/81-11; 50-368/81-10.
At the time of this inspection, the NRC inspector found that the backlog was at least 500 man-hours. Licensee representatives stated that the volume of drawing update / revision was such that the backltag had remained nearly constant over a long time period.
It was further stated that all of the mylar masters for ANO drawings would be trans-ferred to the ANO site, and drawing revisions would be made on site in order to reduce turnaround time. The inspector noted that the
" drawing vault" in Little Rock did not appear to meet the require-ments for a vault as delineated in NEPA~ codes. Licensee representa-tives agreed with the inspector's observation but said that the official drawings were the microfilm records ir> the AN0 records
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vault.
There were no violations or deviations identified in this area of the inspection.
6.
Unresolved Items
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An unresolved item is a matter about which more information is required in order to ascertain whether or not it is an acceptable item, violation, or deviation. An unresolved item is discussed in paragraph 2 of this report (requalification training schedule and operator evaluations).
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7.
Exit Interview An exit interview was conducted August 7,1981 with Mr. J. i'. O'Hanlon and other Arkansas Power and Light personnel denoted in paragraph 1 of this report. A second exit interview was conducted August 20, 1981 with Mr. M. Pendergrass and Mr. D. Horton. At these meetings, the scope of the inspection and the findings were summarized.
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APPENDIX A Number Ti tle 1000.15 Station Training Program 1023.01 Station Training 1023.03 Star.dsrds for Training Documents 1023.04 Training Evaluation / Test Control 1023.05 On-the-Job Training Program 1023.06 Trainer / Instructor Training Program 1023.07 General Employee Training Program 1023.08 Operation Training Program 1023.09 Instrument and Controls Program 1023.10 Mechanical Maintenance Training Program 1023.11 Electrical Maintenance Training Program 1023.12 Chemist Training Program 1023.13 Radiochemist Training Program 1023.14 Health Physics Training Program 1023.15 Materials Management Training Program 1023.16 Office Services Training Program 1023.17 Security Force Training Program 1023.18 Professional / Technical Training Program 1023.19 Supervisory / Management Training Program 1023.20 Fire Plan / Fire Brigade Training Program 1023.21 Emergency Plan Training Program 1023.22 Quality Control Training Prograr 1023.23 Duty Emergency Coordinator Training Program 1073.24 Shift Technical Advisor Training Program