ML19241B837

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Forwards IE Info Notice 79-15, Deficient Procedures. No Action Required
ML19241B837
Person / Time
Site: 05000484
Issue date: 06/07/1979
From: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Dienhart A
NORTHERN STATES POWER CO.
References
NUDOCS 7907240435
Download: ML19241B837 (1)


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NUCLEAR REGULATORY COMMISSION

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%...<.. p JUN 7 1979 Docket No. 50-484 Northern States Power Company ATTN:

Mr. A. V. Dienhart Vice President - Tyrone Energy Park 100 North Barstow Street Eau Claire, WI 54701 Gentlemen:

This Information Notice is provided as an early notification of a possibly significant matter.

It is expected that recipients will review the infor-mation for possible applicability to their facilities.

No specific action or response is requested at this time.

If further NRC evaluations so indi-cate, an IE Circular, Bulletin, or NRR Generic Letter will be issued to recommend or request specific licensee actions.

If you have questions regarding the matter, please contact the Director of the appropriate h7C Regional Office.

Sincerely, N/

O 1 James G. Keppler /;

Director

Enclosure:

IE Information Notice No. 79-15 cc w/ encl:

Central Files Director, NRR/DPM Director, NRR/ DOR PDR Local PDR NSIC TIC Regions I & IV g

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79072404ss 467 306

U.S. NUCLEAR REGULATORY COMMISSICS OFFICE OF, INSPECTION AND ENFORCEMENT REGION III Jcne 7, 1979 IL Infor=ation Notice No. 79-15 DEFICII'C PRCCZDURES Su= nary C June 2, 1979, at Arkansas Nuclear One - Unit 1, while observing conditions in the control room, an NRC ins,ector discovered an cperational deficiency

' stem re=aining isclated that could have resul*ed in the emergency feedwate e

during subsequent power operation.

Description of Circu= stances On June 2 while Arkansas N.iear One - Unit I was preparing for startup, an NRC inspector in the control roe = found that during a surveillance test of the cain feedwater check valves, the controls cf the e=ergency feed-water system were positioned so that the system could not aucc=atically respond if needed. The NRC inspector found that the test procedure being used by the licensed operators did not include, as it should have, instruc-tiens either to bypass the e=ergency feedwater system or to return it to nor=al.

The plant operators, without approved procedures covering this aspect of the test, bypassed the controls that would have started the feedwater system automatically. Lacking a procedural requirement to re-turn the system to nor=al, there was no assurance that emergency fendwater would be provided automatically if needed.

Folleving the Three Mile Island accident, the NRC required that operators be trained to initiate pro =ptly the emergency feedwater syste =anually if it does not ce=e on automatically. Thus, while no i==ediate safety hazard existed at the Arkansas Unit 1 plant because of the i= proper action, the NRC staff is concerned about the potential safety hazard of leaving the emergency feedwater syste= in the bypassed condition, about the possibility that other procedures at the Arkansas plcnt may be deficient and about the fact that the operators deviated fre= procedures in perfor=ing the surveillance test.

Arkansas Pcwer and Light Company has returned the plant to cold shutdcwn.

The June 2, 1979, NRC Crder confir=ed the requirement for a cold shutd 3m until the Ce==ission staf f is satisfied with the utility's =ethod of con-trolling the develop =ent of operating procedures, the adequacy of existing procedures, and until there is assurance that operators will not deviate from those procedures.

467 307

IE Infor=ation Notice No.j79-15 June 7, 1979 Page 2 of 3 The need for including the actions of operaters and other staff =e=bers in the safety related precedures of nuclear power plants is identified in the Technical Specific;ciens and in Appendix B to 10 CFR Part 50, Criterion V.,

Instructions, Procedures, and Drawings:

I

" Activities af f ecting quality shall be prescribed by docu=ented instructions, procedures, or drawings, of a type appropriate to the circu= stances and shall be acce=plished in accordance with these instructions, procedures, or drawings. Instructions, procedures or drawings shall include appropriate quantitative or qualitative acceptance criteria for deter =ining that i=portant activities have been satisfactorily accc=plished."

Further, Regulatory Guide 1.33, " Quality Aasurance Progra= hequi; =ents (Operatien)", endorsus A=erican National Standard ANSI N18.7-1976,

" Administrative Centrols and Quality Assurar e for the Operational Phase of Nuclear Yewer Plants", which provic., extensive guidance en preparation, contants and use of procedures. This standard reiterates the Appendix B state =ent in section 5.3, " Preparation of Instructions and Procedures", and further states:

"These procedures shall provide an approved preplanned =ethod of conducting operations. Procedures shall be prepared and approved prier to i=ple=entation..."

NRC thus requires that anticipsted actions involving safety related equip =ent be planned and prescribed in written procedures. Therefore, steps should have been included in the test procedures to cover all actions.

Recognizing that e=ergency conditions do not always follow an expected course of events. ANSI N18.7 in Section 5.39, "E=ergency Procedures",

states:

"Since e=e gencies may not follow anticipated patterns, the pro-cedures should provide sufficient flexibility to accoc=odate variations."

NRC recognizes that unforeseen conditiens may be encountered that require quick action and judgement and could invclve deviations frc= established procedures for the safety of the public. These deviations should be documented and reviewed after-the-fact and procedures fer= ally changed if necessary.

While circunstances in an e=ergency can cictate the need to depart frr=

procedures, such action cannot be justified en a reutine basis. Rote folleving of deficient procedures is not preper. When a questien en procedural require =ents arises, the licensee's ta=perary change precedure should be used whereby the catter should be referred i==ediately to the prope; authorities for resolution and appropriate changes made if needed.

Departures fre= procedures, either additions or deletions, cannot be allowed for any routine situation.

467 308

IE Infor=ation Notice h.,79-15 June 7, 1979 Page 3 of 3 Each licensee should review his procedures and ad=inistrate.e controls for procedures to assure that methods and procedures exist to control safety related actions. Enclosed is a copy cf the Order issued to Arkansas Pcwer and Light Corpany.

This Infor=ation Notice provides details of a significant occurrence.

No written response is required.

If you desire additional information regarding this matter, contact the Director of the appropriate NRC Regional Office.

Enclosures:

1.

Order Issued to Arkansas Power and Light Company 2.

List of IE Information Notices Issued in 1979 467 307

LS TIO STATES OF AMERI A NUCLEAR REGULATORY CCMMISSICN In the Matter of

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ARyANSAS POWE.R AND LIGHT CCMPANY

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Docket No. 50-313 (Arkansas Nuclear One - Unit No. 1)

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ORDER I.

The Arkansas Power and Light Company (the " licensee") is the holder of Facility Operating License No. DPR-51 (the " license") which authcrizes operation of the Arkansas Nuclear One Unit No. 1 (the " facility") at steady reactor power levels not in excess of 2568 =egawatts ther=al (rated power). The license was issued en May 21, 1974, and has an expiration date of Dece=ber 6, 2008. The facility censists of a Babecek and Wilecx designed pressurized water. 'cter (PWR), located at the licensee 's site in Pope County, Ar'. ansa,.

II.

In the course of authorizec return to power from a ec1.d shucdevn condition, operators deviated frc= the established but apparently deficient pro-cedure for routine surveill nce test of the check valves in the =ain feedwater system. The pr efure was deficient because it did not specify that operators bypass -ud rccurn the e=ergency feedwater system to normal. The plant staff bypassed the controls to aute=atically start EFS by placing the control evitches in a pcsition that would defeat e=ergency feedwater. Ty plant was in a hot shutdown condition pre-paring for startup and the operators apparently took thir action because pu= ping of e=ergency feedwater for this test would be undesirable and unnecessary. Lacking a procedural require =ent to return these switches te normal there was ne assurance that emergency feedwater would be provided autecatically, if needed, later during power eperatien. In view of these circu= stances, which were discovered by an NRC inspecter, the f acility shculd be te=porarily placed in a cold shutdown cendition.

In a telephone conversation en June 2, 1979, the licensee Vice President, Mr. Willia = Cavanaugh, III, agreed to i==ediately proceed to a cold shutdewn condition and te re=ain in that condition until confirmation by the Acting Directer, Office of Inspection and Enforce =ent, that the conditices fer startup set out in Part III belev, have been satisfied.

It is desirable to confir= by order the licensee's agreement to proceed to cold shutdevn.

7 ". Q 46I Ji

r III.

In light of Part II above, IT IS HERISY ORDERID TRAT, purcuant to 10 CFR Parts 2 and 50, the licensee shall proceed to, and re=ain in, a celd shut-devn condition and shal' St rastart until the Acting Director, Office of Inspection and Inforce=<

Sac confir:ed in writing, that the following actiens have been satisf orily acr.ceplished:

(1) the licensee shall evalua:e and codify as appropriate it; methods for the development, review and approval of pro-cedures for all modes of plant operation; (2) the licensee shall evaluate existing procedures to assure that such procedures include all Actions necessary for safety; and, (3) the licensee shall take appropriate steps to assure that all plant personnel adhere to approved procedures and do not add unauthorized steps to any procedures.

FOR TEI NL' CLEAR RECT.1ATORY CC.WISSION John G. Davis Acting Director Office of Inspection and Enforcement Dated at Bethesda. F.aryland this day of June, 1979.

467 3i1

IE Infor=ation Notice No. 79-15 June 7, 1979 LISTING OF IE INFORMATION NOTICES ISSUED IN 1979 Information Subject Date issued To Notice No.

Issued 79-01 Bergen-Patersen Hydraulic 2/2/79 All power reactor Shock and Sway Arrestor facilities with an OL or a CP 79-02 Atte=pted Extortion -

2/2/79 All Fuel Facilities Low Enriched Uraniu=

79-03 Li=1 torque Valve Geared 2/9/79 All power reactor Limit Switch Lubricant facilities with an OL or a C7 73-04 Degradation of 2/16/79 All power reactor Engineered facilities with an Safety Features OL or a CP 79-05 Use of I= proper Materials 3/21/79 All power reactor in Safety-Related Co=penents facilities with an OL or CP 79-06 Stress Analysis of 3/23/79 All Holders of Safety-Related Piping Reactor OL or CP 79-07 Rupture of Radwaste Tanks 3/26/79 All power reactor facilities with an OL or CP 79-08 Interconnection of 3/28/79 All power reac.or Conta=inated Syste=s with facilities with an Service Air Systems Used OL and Pu Processing As the Source of Breathing fuel facilities Air 79-09 Spill of Radioactively 3/30/79 All power reactor Contz=1nated Resin facilities with an OL 79-10 Nonconfor=ing Pipe 4/16/79 All power reactor Support Struts facilities with a CP Enclosure Page 1 of 2 7

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IE Infor=ation Notice No.#79-15 June 7, 1979 LISTING Ogy!]Pg0h NOTICES e

r Issued To jgegn Subject ggjewd 79-11 Lower Reactor Vessel Head 5/7/79 All Holders of Head Insulation Support Reactor OL or a CP Problem 79-12 Atte=pted Damage to New 5/10/79 All Fuel Facilities Fuel Asse=blies research reactors, and Power Reacters with an OL, or CP 79-13 Indication of Low k'ater 5/29/79 All Holders of Level in the Oyster Creek OL or CP Reactor 79-14 NRC Pesition of Electrical 6/11/79 All Po.er Reactor Cable Support Systems facilities with a CP and Applicants Enclosure Page 2 of 2 467 3i3