IR 05000313/1988037
| ML20206L702 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/22/1988 |
| From: | Barnes I, Renee Taylor NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20206L699 | List: |
| References | |
| 50-313-88-37, 50-368-88-37, NUDOCS 8811300160 | |
| Download: ML20206L702 (9) | |
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APPENDIX
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U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspecticn Report: 50-313/88-37 Operating Licenses: OPR-51 f
50-368/88-37 NPF-6 I
Dockets:
50-313 l
50-368 l
Licensee: Arkansas Power & Light Company (AP&L)
f Facility Name: ArkansasNuclearOne(ANO),' Units 1and2 Inspection At: ANO, Russellville, and the AP&L General Offices, i
Little Rock, Arkansas
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i Inspection Conducted: October 17 through November 4,1988 d
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( W G. Taylo, Reactor Inspector, Materiah_.
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j Inspector:
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and Quali y Programs Section, Division of Reactor Safety I
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Approved:
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. Batnes/C ef, Mattrials and Quality Date
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Programt Section, Division of Reactor Safety t
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I Inspection Sumary j
Inspection Conducted October 17 through November 4,1988 (Report 50-313/88-37;
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50-368/88-37)
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j Areas Inspected:
Routine, unannounced inspection involving licensee capability for self-assessment and compliance with the respective operating license i
Technical Specification requirements as they pertain to functions of the Plant
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Safety Committee and the Safety Review Comittee.
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Results: The licensee's cmmnittees do assess the effect of procedure changes i
and proposed modifications on safety of plant operations as required by the
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Technical Specifications. 'There was-little indication that the committees go
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further than required by the Specifications in the area of self-assessment.
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The licensee has recently established and proceduralized a program for review l
and analysis of both exterior and interior events for effect on safety.
The program should be evaluated for effectiveness during a future inspection.
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The licensee has also attempted to address NRC conce ns regarding root cause j
analysis of Identified deficient conditions but again, the program is of recent
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origin and should be evaluated by the NRC in a future inspection.
l There were indications that operability assessments made by the applicable
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plant shift supervisor after discovery of a deficiency may not be conservative i
in some cases.
There were no indications that an effactive second evaluation
was made of the shift supervisors' initial determination.
No violations or deviations were identified by the NRC inspector during this
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area of the inspection.
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DETAILS
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1.
Licensee Personnel Contacted AP8L
- fJ. M. Levine, Executive Director, Nuclear Operations 8E. C. Ewing, General Manager Plant Support
- fH. T. Green, Quality Assurance Superintendent
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- D. B. Lomax Supervisor, Plant Licensing
- fP. L. Michalk, Licensing Specialist l
- R. D. Lane,' Manager, Plant Engineeriitg I
- D. R. Howard, Manager, Licensing
- A. B. McGregor Superintendent, Engineering Services
- W. E. Converse, Superintendent. Operations Assessment
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fJ. L. Taylor-Brown, Quality Control / Quality Engineering Superintendent
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- D. D. Snelling, Corporate Health Physicist, Nuclear Oversight Department
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NRC Persontiel Contacted
- L. E. Ellershaw, Reactor Inspector, Region IV
- R. C. Har.o, Resident inspector.
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- W. D. Johnson, Senior Resident Inspector The NRC inspector also interviewed other licensee personnel during the i
inspection.
- Denotes those persons attending the exit interview on October 21, 1988.
- Denotes those pertons attending the exit interview on Novs ter 3, 1988.
2.
Evaluation of Licensee Self-Assessment Capability (40500)
The purpose of this inspection was to evaluate the effectiveness of the o
licensee's s91f-assessment programs and to verify that the activities of the licensee's onsite and offsite review committees comply with the respective facility Technical Specifications (TS).
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The NRC inspector initially reviewed the Licensee Event Reports (LERs) for
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both units from the beginning of 1987 to the date of the inspection and the most recent NRC SALP report for the ANO facilities.
The purpose of l
the review was to detertnine if there are apparent areas of weakness in the licensee's operations.
The SALP report indicated that there was a weakness in the licensee's investigation of root causes of identified
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deficiencies and a weakness in the comunications between engineering and the plant m3intenance organizations. The NRC inspector did not identify
any other weakness trends in the relatively limited data available.
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a a.
Committee Activities (1) Plant Safety Comittee:
The NRC inspector reviewed the TS for both units in regard to composition and required functions for the onsite review comittee.
This comittee is referred to as the Plant Safety Comittee in both specifications.
The specified composition of the comittee is as follows:
Chairman:
General Manager, Plant Support Member:
Operations Manager Member:
Maintenance Manager Member:
Training Manager Member:
Plant Licensing Supervisor Member:
Engineering Manager Member:
Quality Assurance Superintendent Member:
Reactor Engineering Superinter4 dent Member:
. Health Phy.;ics Superintendent Member:
Nuclear Software Expert (only required to attend when changes to computer software is on the agenda)
The Executive Director, ANO Site Operations has designated one or more alternates foi each of the persons who presently occupy the above positions.
The alternates are generally persons
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subordinate to the designated individual in the same department.
l The NRC inspector reviewed the qualifications of the present incumbents of the above positions in relation to ANSI 18.1-1971, l
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"Selection and Training nf Nuclear Power Plant Personnel." Each
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incumbent was found to have a combination of experience and l
education that equals or exceeds the requirements of the l
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The TS state that the Plant Safety Comittee is responsible for review of the following documents:
I All procedures and revisions thereto required by
Section 6.8 of the TS.
All proposed tests and experiments that affect nuclear
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safety.
All proposed changes to the Appendix "A" TS.
- All proposed changes or modifications to plant systems that
affect nuclear safety.
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Investigate all violations of the TS including the
preparation and forwarding of reports covering evaluation and recomendations to prevent recurrence to the Executive Director, ANO Operations, and that Chairman of the Safety Peview Comittee.
Review all Reportable Occurrences requiring 24-hour
notification of the Comission.
The NRC inspector attended a scheduled meeting of the Plant Safety Comittee on October 18, 1988. The meeting was attended by six dJsignated members of the comittee and the primary alternates for two others. The TS stipulates that a quorum consists of the Chairman, or his designated alternate, and four members including alternates, although no more than two alternates shall have a vote in the comittee deliberai; ions.
Each attendee arrived at the meeting room with an astimated 15 inches of documents scheduled for comittee consideration.
The meeting wcs adjourned after 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of deliberation with about 12 inches of docuw!nts not considered. The NRC inspector was impressed by the attention given each item by each member of the comittee. Appropriate, pointed questions were raisad on seversi items ind, in ore case, an individual presenting additional info mation on a procedural change was instructed to reword the change to make the procedure clearer prior to further consideration by the comittee at a future meeting. The NRC inspector also reviewed the minutes of previous Plant Safety Comittee meetings and found that they reflected a similar meeting attendance and agenda as the meeting obrcerved. The NRC inspector also found that the canittee has meetings at a frequency well in excess of the monthly mee'.ing stated by the TS as being minimum.
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l June 1988, the comittee met four times on an essentially weekly schedule and met an additional five times in unscheduled "special" meetir.g5 to give consideration to specific issues. During August 1988, there were eight scheduled and five unscheduled meetings.
Based on a review of the minutes of earlier meetings and observation of the meeting as described above, the NRC inspector judged that the Plant Safety Comittee is functioning as required by the TS.
The NRC inspector also concluded that consideration should be given by licensee to propose revised TS requirements such that the Plant Safety Committee would be permitted to delegate some of the procedural change review and approval work load to subcomittees, as has been approved for sorce other plants.
(2) Safety Review Comittee:
The NRC inspector reviewed the minutes of the Safety Review Comittee, which is the higher level "offsite" comittee required by the TS. The functions of the Safety Review Comittee are as follcws:
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Review safety evaluations for (a) changes to procedures,
equipment or systems, and (b) any tests or experiments completed under the pre,ision of 10 CFR 50.59, to verify that such actions did wot constitute an unreviewed safety question.
Review proposed changes to procedures, equipment or systems which involve ta unreviewed safety question.
- Review proposed tests or experiments which (qvolve an unreviewed safety question.
Review proposed changes to facility TS.
- Review violations of endes, regulations, orders, TS,
license requiremerts, or of internal procedures or instructions having nuclear safety significance.
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Review significant operating abnormalities or deviations
from normal and expected performance of unit equipment that
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affect nuclear safety.
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Review events rer,uiring 24-hour written notification to the
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Commission.
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Review all recognized indications of an unanticipated l
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deficiency in some asoect of design or operation of L
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structures, systems, or corrponents that could affect
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Review reports and meetings minutes of the Plant Safety
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Comi ttee.
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t Review proposed changes to the Offsite Dose Calculation
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Manual and the Process Control Program.
i Be cognizant of audits perfomed in essentially all areas
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j of plant operations by the nuclear assurance organization.
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The facility TS requires that the licensee Vice President,
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Nuclear Operations designate the committee chairman, an
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alternate to the chaiman, and the remainder of the committee
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i membership. The TS also requires that the membcrs have a
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collective expertise in several areas involving nuclear t
t activities. The Vice President, Nuclear Operations has, in l
Revision 8 of the Safety Review Comittee charter dated January 13, 1988, desigt.ated himself as the chairman of the i
comittee with the Executive Director, ANO Operations designated as alternate chairman.
The charter also designates the other l
members of the comittee by position title. The Chairman and j
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- the comittee secretary are responsible for assuring that each appointee has the qualifications to sit on the comittee and that the comittee as a whole has the collective qualifications required by the TS.
The charter also establishes three subcomittees as follows to assist the main comittee:
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. Quality Assurance Audit Subcomittee with six members Safety Evaluation Subcomittee with five members Plant Safety Comittee Oversight Subcomittee with five members The NRC inspector reviewed the minutes of all of the subcomittee mectings that have taken place since they were created by the charter revision. These minutes indicate that the subcomittees maic a significant contribution to the
functioning of the main cocrittte in that their deliberations are focused on one area and the time is taken to give full consideration to that area.
The NRC Senior Resident Inspector
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Indicated that he had recently attended a Quality Assurance Audit Subcomittee meeting and was impressed by the pointed
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discussions which took place.
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The minutes of the main Safety Review Comittee reflect that they have met at a frequency greater than required by the TS
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arid that each meeting was atterded by membership in excess of
that required for a quorum.
Review of the resuires of the participants indicate that they fulfill the requireunts in regard to expertise.
The NRC inspector did not have an opportunity to observe a l
meeting of the Safety Review Comittee during the course of the
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inspection.
The NRC inspector considers that the Safety Review Comittee has fulfilled the requirements of the TS in regard to its functions
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and corrposition during the period reviewed.
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No violations or deviations were identified in this area of the inspection.
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Other Self-Assessment Activities
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The licensee has established a group within the plant support staff titled AMO Operations Assessment Section headed by a superintendent.
The designated functions of the group as described by Licensee Procedure 1000.29 Revision 11. "Operations Assessment Program,"
closely follows the requirements established 'uy the NRC for an Independent Safety Engineering Group (ISEG) at facilities licensed after the Three Mile Island (TMI) accident.
Since both ANO licenses
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were issued prior to THI, an ISEG is not required at AN0; however, AP&L apparently established the group approximately 2 years ago on a voluntary basis following INP0 recomendations.
Input data for assessment activities largely arrive from two sources.
One source is reports of events coming into the group from external organizations such as INPO, other nuclear plants, and the NRC.
The other source is "Condition Reports" which is the licensee's methed of internally identifying, reviewing, and reporting of conditions considered to be adverse to safety and probably requiring corrective action. Licensee Procedure 1000.104, Revision 1, dated May 26, 1988,
' Condition Reporting and Corrective Actions" addresses the current reporting system.
This system replaced an earlier system involving
"Reports of Abnormal Conditions (RACs)."
The present system involves the identification of a condition, preparation of a report, and imediate review of the report by the finder's supervisor and the affected plant shift supervisor for reportability and operability considerations. Having made these determinations, the shift supervisor takes whatever imediate action he deems necessary and forwards the report to Licensing for an overview of the reportability decision and to Operations Assessment.
The finder's supervisor is also responsible for forwarding the report to his department manager for review and assignment of corrective action for the finding.
The supervisor of the In-House Events Analysis sub-unit in Operations Assessment reviews the reported condition for significance, and if the condition is considered significant, initiates a root cause analysis of the problem.
Significance is determined using a 16 point checklist to assist the logic process.
The NRC inspector obtained a computer printout of all Condition Reports written during August 1988.
The tabulation indicated that 55 and 60 reports had been initiated on Units 1 and 2, respectively. Of the 55 for Unit 1, the Operations Assessment grcup considered that two were "significant" while on Unit 2, four were so categorized.
The NRC inspector interviewed the supervisor of the In-House Events Analysis sub-unit tn obtain a better understanding of the logic proceis in detennining significance. Of the six events classified as significant, the supervisor had arrived at the conclusion on the basis of excessive recurrence in three cases, an excessive personnel radiation exposure in one case, and TS violations in two cases.
At the suggestion of the NRC Senior Resident inspector, the NRC inspector questioned the logic on one other reported condition not considered significant since, as described in the computer summary and in the Condition Report, the condition appeared to raise a plant operability question.
Review of the In-House Events Analysis group's file for the condition report indicated that the supervisor had not challenged the earlier decisior, by the shif t supervisor that plant operability was not affected, and since the condition did not seem to
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i fit any of the 26 checklist items, the reported condition was not i
considered significant. Since the Senior Resident Inspector wds
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following up on the issue, the NRC inspector did not pursue the matter i
further.
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l Insufficient time was available for the NRC inspector to review the i
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Operations Assessments group implementation of the exterior events
review program.
The effectiveness of this program will be reviewed
during a future inspection.
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No violations or deviations were identified by the NRC inspector
during this area of the inspection,
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c.
Conclusions (
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The licensee's comittees do assess the effect of procedure changes l
and proposed modifications on safety of plant operations.
l The licensee has attempted to address an NRC concern regarding root i
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cause analysis of identified deficient conditions. This effort
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should be evaluated in a future inspection for effectiveness.
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The licence has established and proceduralized a program for review l
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l and analysis 6f both exterior and interior events for effect on i
j safety.
The program is of sufficiently recent origin that only a
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l'mited assessment of effectiveness could be made. The NRC inspector
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j doas have reservaties about the above program in the area of
opurabflity assessments where there appears to be no effective second j
ievel evaluation unless requested by the first level evaluator, the j
shift sepervisor. This 3ituation may arise from the use of a i
j checklist logic system that is at once prescriptive but with
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i individual items in the list broadly defined; and from relatively
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i inexperienced personnel pe forming the assessment.
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3.
Exit Interview
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The NRC inspector met with persons identified in paragraph 1 on October 21 i
I and November 3, 1988, to discuss the findings and conclusions reached i
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during the inspection. No informatioi was presented to the NRC inspector
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