IR 05000313/1990001
| ML20059N478 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 10/04/1990 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Carns N ENTERGY OPERATIONS, INC. |
| References | |
| NUDOCS 9010160028 | |
| Download: ML20059N478 (3) | |
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l In Reply Refer To:
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Dockets: 50-313/90-01-50-368/90-01 Entergy Operations, Inc.
ATTN: Neil S. Carns, Vice President Operations, Arkansas Nuclear One P.O. Box $51 Little Rock, Arkansas 72203 Gentlemen:
Thank you for your letter of September 14. 1990 (OCAN099002 your previous correspondence of April 20,1990,(OCAN04901?))relatedtoin followup to validation of nonlicensed operator (NLO) staffing.. We have reviewed your validation efforts and results and find your actions responsive to our concerns.-
As mentioned in our previous correspondence, we will review the implementation of your corrective actions during a future inspection.
Sincerely
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OdginalSigtsiBy:
TImmesP.Gwynn-Samuel J. Collins, Director Division of Reactor Projects CC:
Entergy Operations, Inc.
ATTN: Donald C. Hintz, Executive Vice-President & Chief Operating Officer P.O. Box 31995 Jackson, Mississippi 39286 Entergy Operations, Inc.
ATTN: Gerald W. Muench; Vice President
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Operations Support.
P.O. Box 31995 Jackson, Mississippi 39286~
Wise, Carter, Child & Caraway ATTH: Robert B. McGehee, Esq.
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P.O. Box 651
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Jackson, Mississippi,39205 i
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TMckernon/cjg
.JGagliardo LJCa11 angio l5 L$JCollins
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90101 _66028 901004 4'%
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Entergy Operations, Inc.
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Arkensas Nuclear One ATTN: Early Ewing, General Manager
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Technical Support and Assessment Route 3, 00x 137G i
Russellville, Arkansas 72801 J
Arkansas Nuclear One ATTN:. Jerry Yelverton, Director j
Nuclear Operations
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Route 3. Box 137G j
Russellville, Arkansas 72801
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Arkansas Nuclear One
ATTN: fir. Tom W. Nickels
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Route 3, Box 137G
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Russellville, Arkansas 72801
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Cowbustion Engineering, Inc..
ATTH: Charles B. Brinkman, Manager Washington Nuclear Operations
12300 Twinbrook Parkway. Suite 330
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Rockville, Maryland 20852 j
Honorable Joe W. Phillips County Judge of Pope County Pope County Courthouse
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Russellville, Arkansas 72801 l
Bishop, Cook, Purcell & Reynolds
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ATTN: Nicholas S. Reynolds, Esq.
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1400 L Street, N.W.
Washington, D.C.
20005-3502 i
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ATTH: Ms. Greta Dicus Director Division of Environmental Health
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Protection
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4015 West Markam Street Little Rock, Arkansas 72201 Babcock & Wilcox
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Nuclear. Power Generation Division-
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ATTN: Mr. Robert B. Borsum 1700 Rockville Pike, Suite 525 Rockville, Maryland 20852 U.S. Nuclear Regulatory Commission ATTN: -Senior Resident inspector 1 Nuclear Plant Road l
Russellville, Arkansas 72801
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Entergy Operations, Inc.
-3-U.S. Nuclear Regulatory Connission ATTN: Regional Administrator, Region IV 611 Ryan Pleza Drive, Suite 1000 Arlington, Texas 76011 bectoDHB(IE01).
bec distrib. by RIV:
R. D. Martin Resident Inspector DRSS-FRPS SectionChief(DRP/A)
Lisa Shea, RM/ALF RIV File DRP HIS System RSTS Operator ProjectEngineer'(DRP/A)
DP,5-T. Alexion NRR Project Manager'(HS:
13-E-21))
C.Posiusny,HRRProjectManager(MS:
13-D-18 T. McKernon J. Gagliardo
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t September 14, 1990 SCANf99002
U. S.' Nuclear Regulatory Commission I
Document Control Desk
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Mail Station P1-137~
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Washington, D. C.
20555
$UBJECT: Arkansas Nuclear One - Units 1 and 2 l
Docket Nos. 50 313/50-368'
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License Nos. OPR 51 and NPF-6 Validation of Non Licensed Operator' Staffing
Inspection Report 50-313/90-01; 50-368/90 01 l
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Gentlemen:
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As discussed in our letter of. April 20, 1990 (8CAN649812), a validation.of'
non-licensed operator (NLO). staffing has been performed on Units 1 and 2.
This.validationwasr.erformedtoensurethatArkansasNuclearOne(AN0)has.
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sufficient NLO staffing to properly execute the required actions of the Emergency Operating Procedures (E0ps).
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To perform the validation for Units 1 and 2, three scenarios were chosen-
which required use of the Emergency Operating Procedures and which had been j
identified as potentially challenging to.the non-licensed operators.::The
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local operator actions in each E04 section'were evaluated to determine the i
E0P section that would be the most burdensome for.the non-1icensed
operators. ;The scenarios used were verified to include the E0P sections:
identified. The "most limiting" event (for both Units 1 and 2) was.a loss
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of off-site power with emergency feedwater initially unavailable.. The other two scenarios performed were a steam line break inside containment-
and a steam line break downstream of the main.' steam isolation valves..
These scenarios were chosen because previous validations of the E0P had
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raised a concern about. the ability of the NLDs to perform required actions I
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under these circumstances.
The verification'and validation (V&V): process used for.the staffing f
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validation.was a revised process-developed after the E0P. audit by the NRC
had been performed. This V&V process was developed with the assistance of-a subject matter expert in the area of human factors and human; performance.
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U. 5. NRC
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Psge 2
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September 14, 1990 i
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The validation for Unit 2 was done using.the control room simulator and-
i walkthroughs in the plant..The scenarios were conducted with two different
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control. room operating crews. An observation team in the simulator kept a
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record of the actions required of the non-licensed operators during the j
event and the time at which the actions were needed. Walkthroughs were i
performed in the plant of the actions to be completed by the NL0s and the.
i time required to complete the actions was recorded on local action'
i verification forms..
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-UnitsoneandTwowere(Localactionverification.walkthroughsforboth
' performed by non-licensed operators working the i
support shift at the time the walkthroughs were done.) -A comparison was
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made between.the time required to complete each. task and the scenario time
when the task was needed. Based on tifs review, the actions required of I
non-licensed operators can. successfully be performed by two operators.=
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However, a staffing level of three.4L0s will be maintained to. allow for-i differing levels of expertise among tn* NL0s and possible complications during a transient.
'i A similar validation was performed for Unit I using the.same three i
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t scenarios conducted with one operating crew on the.co'itrol room simulator.
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The local action verification.walkthroughs had been performed prior to the
simulator sessions. As the drills were run on the simulator, the control.
room operators requested actions of the NL0s as needed and the observers i
kept track of the time the actions were. requested.- That NLO was not.
i allowed to be used again for another action untti the required time had elapsed for the first action to be completed. The observers assumed the j
l normal shift complement of three non-licensed operators. Based on these
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drills, the actions required of the NL0s by the E0P can successfully be l
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l performed by three operators. ' Although a review of the data indicated that
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the actions required could have been performed adequately by two oporators, i
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three NL0s per shift will be maintained to allow for differing levels of l
expertise among the NL0s and possible complications during,a transient.
-l Based on the results of the validations, changes to both units'. Technical Specifications will be requested to require staffing three non-licensed j
operators per shift. These change recuests will be submitted by February
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28, 1991, in accordance with the schecule included in our letter of April
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20, 1990.
In the interim, three NL0s p' r shift are currently required by
e procedure,
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To~ provide additional assurance that NL0s are prepared to perform actions
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recuired by the E0P, the Unit 2 Operations Manager issued in July 1990 an
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adcendum to the Auxiliary Operator qualification card which specifically i
included performance tasks required by the E0P. Waste Control Operator
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tasks are also included in the addendum. Qualified non-licensed personne1'
L are being required to complete the addendum. This includes operators in
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the current Reactor Operators license class' qualified Waste Control
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l Operators and qualified Auxiliary Operators.
Personnel presently in~
training to become qualified Auxiliary Operators have added this addendum
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to their qualification cards and must complete performance or simulation of
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the tasks prior to qualification as an Auxiliary Operator.
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Page 3 September 14, 1990 l
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This addendum will ensure that Auxiliary Operators are qualified to perform
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the tasks required by the E0P of not only the Auxiliary Operator.but also
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the Waste Control Operator should it become necessary during the course of
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.a transient.
Unit 1 NLO training includes actions required by the E0P.
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The verification and validation (V&V) process as revised includes
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verification of local actions and of adequate staffing to perform these.
i actions.; As part of the V&V of the upgraded ANO-2 E0P (upgrade to CEN-152
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guidelines) and of. the upgraded ANO-1 E0P, a 100 percent validation will be
performed of actions required,to be performed outside the Control Room.
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The adequacy of non-licensed staf fing will' be reassessed at ~ that time.
l Based on the results-of the validations performed, we have concluded that the current level of three.NLos per. shift is adequate to meet the demands
of'operettens under the E0P and to ' ensure' the continued health and safety of the public.
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Very truly yours,
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.W./e1verton
L Director, Operations JWY/JDJ/sgw
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Regional Administrator a
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- U.gion IV-S. Nuclear Regulatory Commission 611 Ryan Plaza' Drive, Suite 1000 Arlington, Texas 76011
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