IR 05000313/1990001

Ack Receipt of 900420 & 0914 Ltrs Re Validation of Nonlicensed Operator Staffing Per Insp Repts 50-313/90-01 & 50-368/90-01

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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OCT -4 m l

In Reply Refer To: .

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Dockets: 50-313/90-01-50-368/90-01 Entergy Operations, In 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 inspectio Sincerel OdginalSigtsiBy:

TImmesP.Gwynn-Samuel J. Collins, Director Division of Reactor Projects CC:

Entergy Operations, In ATTN: Donald C. Hintz, Executive Vice-President & Chief Operating Officer P.O. Box 31995 Jackson, Mississippi 39286 Entergy Operations, In ATTN: Gerald W. Muench; Vice President -

Operations Suppor P.O. Box 31995 Jackson, Mississippi 39286~

Wise, Carter, Child & Caraway ATTH: Robert B. McGehee, Es '

P.O. Box 651 .,

Jackson, Mississippi ,39205 i

• RIV:RI:0PS *C:0PS D:DR$- D:DRP I

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TMckernon/cjg .JGagliardo LJCa11 angio l5 L$JCollins  ;

/ /90 / /90 (0/4/90 f /o/') /90 - l

• Previously concurred

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90101 _66028 ee901004 ,

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Entergy Operations, In !

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Arkensas Nuclear One ATTN: Early Ewing, General Manager '

Technical Support and Assessment Route 3, 00x 137G i Russellville, Arkansas 72801 J l

Arkansas Nuclear One 1 ATTN: . Jerry Yelverton, Director j Nuclear Operations '

Route 3. Box 137G j Russellville, Arkansas 72801 )

Arkansas Nuclear One  ;

ATTN: fir. Tom W. Nickels  !

Route 3, Box 137G ,

Russellville, Arkansas 72801 '

Cowbustion Engineering, Inc. .

ATTH: Charles B. Brinkman, Manager Washington Nuclear Operations  :'

12300 Twinbrook Parkway. Suite 330 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 ,

ATTN: Nicholas S. Reynolds, Es '

1400 L Street, Washington, i Arkansas Department of Health ,

ATTH: Ms. Greta Dicus Director Division of Environmental Health .

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Protection 4015 West Markam Street Little Rock, Arkansas 72201 Babcock & Wilcox )

Nuclear. Power Generation Division- . ;

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 Russellville, Arkansas 72801  !

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Entergy Operations, In 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:

C.Posiusny,HRRProjectManager(MS: 13-E-21))

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  !

Mail Station P1-137~ - 1 Washington, D. C. 20555

$UBJECT: Arkansas Nuclear One - Units 1 and 2 l'

Docket Nos. 50 313/50-368' .

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: i

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As discussed in our letter of. April 20, 1990 (8CAN649812), a validation.of'

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non-licensed operator (NLO). staffing has been performed on Units 1 and This.validationwasr.erformedtoensurethatArkansasNuclearOne(AN0)ha j!

sufficient NLO staffing to properly execute the required actions of the Emergency Operating Procedures (E0ps). . t l \

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 >

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 valve .

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These scenarios were chosen because previous validations of the E0P had raised a concern about. the ability of the NLDs to perform required actions I under these circumstance '

The verification'and validation (V&V): process used for.the staffing

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f validation.was a revised process-developed after the E0P. audit by the NRC 4 :

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; performanc *

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September 14, 1990 i

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i The validation for Unit 2 was done using.the control room simulator and-  :

walkthroughs in the plant. .The scenarios were conducted with two different  !

' control. room operating crews. An observation team in the simulator kept a  !

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 th i time required to complete the actions was recorded on local action' i verification forms. .

-UnitsoneandTwowere(Localactionverification.walkthroughsforboth

' performed by non-licensed operators working the

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support shift at the time the walkthroughs were done.) -A comparison was made between.the time required to complete each . task and the scenario time 1 when the task was needed. Based on tifs review, the actions required of I non-licensed operators can. successfully be performed by two operators.= '

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 transien 'i i

A similar validation was performed for Unit I using the.same three t scenarios conducted with one operating crew on the.co'itrol room simulato .

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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 contro 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 -

drills, the actions required of the NL0s by the E0P can successfully be

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l 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, '

three NL0s per shift will be maintained to allow for differing levels of l expertise among the NL0s and possible complications during,a transien l Based on the results of the validations, changes to both units'. Technical j Specifications will be requested to require staffing three non-licensed  ;

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 20, 1990. In the interim, three NL0s p' e r shift are currently required by

procedure, .:

To~ provide additional assurance that NL0s are prepared to perform actions ~'

recuired by the E0P, the Unit 2 Operations Manager issued in July 1990 an adcendum to the Auxiliary Operator qualification card which specifically .

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included performance tasks required by the E0P. Waste Control Operator  !

L tasks are also included in the addendum. Qualified non-licensed personne1'

are being required to complete the addendum. This includes operators in * '

the current Reactor Operators license class' qualified Waste Control

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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 Operato +

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Page 3 September 14, 1990 l t

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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 '

the Waste Control Operator should it become necessary during the course of

.a transient. Unit 1 NLO training includes actions required by the E0 ,

l The verification and validation (V&V) process as revised includes  !

verification of local actions and of adequate staffing to perform thes i actions.; As part of the V&V of the upgraded ANO-2 E0P (upgrade to CEN-152  !

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 tim 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 1 of'operettens of the public.under the E0P and to ' ensure' the continued health and safety

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Very truly yours, +

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! .W./e1verton L

Director, Operations JWY/JDJ/sgw '

ec: Regional Administrator a Re  ;

U.gion IV-S. Nuclear Regulatory Commission 611 Ryan Plaza' Drive, Suite 1000 Arlington, Texas 76011  :

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