ML19343B461
| ML19343B461 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/21/1980 |
| From: | Trimble D ARKANSAS POWER & LIGHT CO. |
| To: | Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML19343B459 | List: |
| References | |
| 1-110-24, 2-110-32, NUDOCS 8012240038 | |
| Download: ML19343B461 (7) | |
Text
Y ARKANSAS POWER & LIGHT CCMPANY PCST CFFICE BCX 551 UTTLE ROCK. ARKANSAS 72203 (501) 371-4000 November 21, 1980 1-110-24 2-110-32
~.. __.
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.,w Mr. K. V. Seyfrit, Director Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011
Subject:
Arkansas Nuclear One - Units 1 & 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Response to Inspection Reports 50-313/80-17 and 50-368/80-17 (File:
0232, 2-0232)
Gentlemen:
In response to the Items of Noncompliance included in the subject report, the following is provided.
NOTICE OF VIOLATION Based on the results of an NRC inspection conducted during the period of August 22 - September 21, 1980, it appears that certain of your activities were not conducted in full compliance with NRC regulations and the condi-tions of your license (NPF-6), as indicated below:
Technical Specification 3.6.2.3 states, "Two independent containment cooling groups shall be OPERABLE with two cooling units in one group and at least one cooling unit in the second group." This Limiting Condition for Oper-ation is applicable in Modes 1, 2 3 and 4 Action statement b. of Technical Specification 3.6.2.3 requires that "With two groups of the above required containment cooling units inoperable and both contain-ment spray systems OPERABLE, restore at least one group of cooling units to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Restore both above required groups of cooling units to OPERABLE status within 7 days of initial loss or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />" 8 0 3 2' 2 4 00 M MEMBEA MCCLE SOUTH UT1UTIES SYSTEM
Mr. K. V. Seyfr M November 21e 1980 i
Contrary to the above, the licensee operated Unit 2 in three of the four applicable Modes for reactor operations (Modes 1, 2 and 3) from August 20, 1980 through Septem-ber 3, 1980, with two groups of the containment cooling units inoperable.
This resulted in exceeding all of the permissable elapsed time limits specified in Technical Specification 3.6.2.3.
This is an infraction (368/80-17-01).
RESPONSE
A review of the failure of the administrative controls which allowed operation in an out-of-spec, condition for 14 days was initiated by the plant staff on the afternoon of 9/3/80.
A special inspection of this incident was performed by members of the offsite nuclear review group.
The failures occurred both on the part of the shift supervisor analyzing the test and the Assistant Operations Superintendent per-forming the second, independent data review.
The cause of the failures of both individuals who were involved appear to be very similar in nature:
1)
Being " pre-conditioned" to expect the "No" in surveillance proce-dure step 3.3.1 to be circled because of the blank flange instal-lation on 2VCC-2A S.W. coils.
2)
Inattentiveness to detail during review ;aused by haste.
1 In both individual's cases, only the surveillance test section 3.0 " Test Acceptance Criteria" was reviewed in detail; the preceding two pages (steps utilized to perform the test) were reviewed for completeness only (i.e., all slots filled in and initialled) which resulted in no review on their part of the actual flow rate data.
A review of all other surveillances in the Unit 2 Assistant Operations Superintendent's files (approximately 80 separate tests) indicated no l
other out-of-spec. data.
The individuals involved have been thoroughly counselled.
Specific coun-selling included the necessity for increased alertness, attentativeness i
to detail, and necessity for temporary procedure criteria changes versus i
l case-by-case evaluations of out-of-tolerance conditions.
Procedure formats have been reviewed to ensure all required data and criteria are readily and easily discernable.
Measures to reduce the time demands on the Shift Supervisors have been taken by the addition of the Shift Administrative Assistant to the plant staff.
These individuals will provide reduction in the Shift Supervisor's administrative work load and will add another check of surveillance para-meters.
l Corrective action has been completed.
The Shift Administrative Assistants (SAA) have been hired and are in a training program.
The SAA's are sche-j duled to start performing duties on shift on January 1, 1981.
l t
Mr. K. V. Seyfrit November 21, 1980 NOTICE OF VIOLATION Appendix B of the Technical Specifications, Section 2.2.3.a., requires that a series of calculations be performed to determine the maximum time for each containment building purge duration.
On September 4, 1980, calculations established a maximum purge time of 10 minutes 44 seconds as recorded on Permit GR 80-46.
Contrary to the above requirements, the containment building was purged on September 4, 1980, without knowledge of the start time of the purge.
The purge time probably exceeded 10 minutes and 44 seconds and an additional amount of purge time would have occurred, except that the Senior Resident Inspector called the lack of purge time monitoring to the attention of operating personnel.
This is an infraction (368/80-17-02).
RESPONSE
This incident was promptly investigated by the plant staff.
In addition, members of tne offsite nuclear review group performed a special inspection of this incident.
The predominant administrative / personal errors were determined to be:
1)
Not exercising sound operating judgement to immediately terminate the purge alignment on fan failure.
2)
Lack of appreciation for the timing precision required during inter-mittant purge steps to preclude exceeding offsite dose limits.
3)
Lack of adequate communication and coordination on shift.
4)
The involvement of the Shift Supervisor in specific operations func-tions (acting as an operator) to the point of losing overview capa-bility.
5)
Lack of adequate notification from the I&C Department personnel to the control room of removing required equipment from service.
6)
Less human factor consideration used ia formatting release procedure than desirable.
7)
Distracting effect and loss of concentration due to close scrutiny of operators by NRC inspectors.
Corrective actions to reduce the likelihood of recurrence are:
1)
The operator having the most significant contribution to this event (the Shift Supervisor) has been thoroughly counselled regarding the following items:
a.
His responsibility to maintain a proper over-view for proper coordination and control of all operations and not to become totally involved with any specific operation.
Mr. K. V. Seyfrit November 21, 1980 b.
His responsibility to assure that important routine tasks con-tinue to receive full concentration of the operators and him-self.
c.
The vital importance of maintaining precise timing of purging operations and the results of exceeding purge times.
2)
Additionally, the entire operating staff has been apprised of this event, and the necessity for close cooperaticn and awareness, atten-tiveness to detail and methods to minimize personal susceptibility to intimidating effects of close NRC scrutiny.
The purge release procedure has been reviewed and is being revised to provide a better method of formating, proper depth and adequacy of cautioning state-ments.
3)
Specific counseling with instrument technicians who were involved with the isolated stack flow transmitter has been performed. Train-ing with all the I&C technicians reviewing this event, the effects of isolating equipment without proper clearance, and the necessity to follow proper procedures when performing maintenance has been conducted.
Corrective action will be completed by December 1, 1980 when the revised purge release procedure will be issued.
NOTICE OF DEFICIENCY Technical Specification 6.9.1.9 requires, in part, that a completed copy of a licensee event report form be submitted by the licensee to the Nu-clear Regulatory Commission within thirty days of the occurrence of any event that results in "... conditions leading to operation in a degraded mode permitted by a limiting condition for operation or plar.t shutdown required by a limiting condition for operation".
Technical Specification 3.7.1.2 requires that two emergency feedwater pumps be operable, with one of the pumps being a turbine driven pump (2P7A) powered from the steam supply system while in Mode 1 operation.
Contrary to the above, the turbine driven emergency feed pump (2P7A) was discovered to be inoperable while testing it in Mode 1 operation on July 23, 1980, and licensee failed to submit a licensee event report (LER) form reporting this failure to the Nuclear Regulatory Commission.
This is a deficiency (368/80-17-03).
RESPONSE
The failure of the turbine driven emergency feedwater pump (2P7A) which occurred on July 23, 1980, was the result of incorrect installation of test equipment during testing to determine reliability of the subject equipment.
Since the failure (an overspeed trip) occurred during the test, was corrected prior to completion of the test, and was not a valid failure, the ANO staff determined the event to be non-reportable.
This determination was a conscious decision after discussion of this incident by the AN0 Plant Safety Commission (PSC) and the ANO General Manager and was based upon AN0's interpretation of Regulatory Guide 1.16.
Although we believe that the reportability of this event is subject to interpretation, AP&L will submit an updated licensee event report to document this failure.
This deficiency has been reviewed by the PSC.
Mr. K. V. S:yfrit November 21, 1980 Corrective action will be completed by December 1, 1980, when a licensee event report will be submitted to document this failure.
ACTIONSTOIMPROVEOVERALLCONTROLOFLICENfdDACTIVITIES Your letter also asked us to described the actions we have taken or plan to take to correct the broad deficiencies in implementation of AP&L's Quality Assurance Program.
Quality assurance requirements have been established for the design and construction of AP&L nuclear plants to assure that regulatory require-ments and licensino commitments, codes and standards are correctly trans-lated into the as-built plant.
It is the objective of this program to establish quality assurance requirements to ensure that activities such as operating, testing, refueling, repairing, maintaining and modifying the plant are conducted in accordance with good engineering practices.
To meet this objective, a Quality Assurance Program for Operation Appli-cable to AP&L Nuclear Plants has been established by Arkansas Power &
Light Company.
The Program, identified as Quality Assurance for Opera-tions, provides criteria to be applied to the operational phase of the plant.
The program controls those phases, as applicable, for the design, procurement, manufacturing and fabrication, installation, reoair, main-tenance or changes made to existing plant structures, components and systems that prevent or mitigate the consequences of a postulated acci-dent which may cause undue risk to the health and safety of the public.
It assures that the necessary operational safeguards are applied in accordance with the criteria for safe, efficient and reliable operation.
The program is an outgrowth of the principle that quality assurance ema-nates from each individual contributor, and that management is responsi-ble for creating an awareness of quality.
A review of the Quality Assurance Program was recent:y completed by an outside, independent consulting firm.
Based on the recommendaticns of this review, the QA Section has reorganized and has authorization to increase its staff by four (4) people for the nuclear program.
Two (2) of these individuals will be located at ANO.
In addition, we are in the process of revising the QA Administrative Procedures (QAA's) and the Quality Assurance Procedures (QAP's/AN0's) to provide more definitive procedures for implementation of the AP&L Quality Assurance Program. The QA Section has expanded its audit program to include those audits previ-ously performed by the Corporate Safety Review Committee and to conduct more surveillance of in process activities at ANO.
These specifications will provide significant improvement in assuring implementation of the AP&L Quality Assurance Program.
AP&L has implemented a number of organizational changes which we feel will improve our overall operation.
We have restructured our corporate organi-zation to create a separate Nuclear Operations Department within Generation and Construction.
Previously, Nuclear Operations was a section within the Generation Operations Department.
The new Nuclear Operations Department has a Nuclear Services Section which will provide dedicated support to AN0
)
and will function to coordinate the corporate office support for ANO.
In addition, the corporate Plant Maintenance and Availability Engineering Section has been directed to make AN0 its top priority and is now working on programs directed at improving the quality and effectiveness of the ANO management system and operation.
l
Mr. K. V. Seyfrit November 21, 1980 The ANO organization has also been modified to ensure improved management controls.
The Operations and Maintenance Department has been separated into an Operations Department and a Maintenance Department.
This change was required to ensure more detailed management control over these two key areas of nuclear plant operation.
We have also created a Special Projects Group reporting to the General Manager.
This group will be responsible for resolution and implementation of ongoing projects as determined by the Gen-eral Manager which will relieve this workload from the line managers and permit them to better control their areas of responsibility.
The Manager of Special Projects will be the chairman of the onsite Plant Safety Com-mittee.
We have also created an Operations Assessment Group on the ANO staff which will provide a detailed review of plant operations and review the operating experience of other nuclear units.
We have just recently increased and reorganized the staffs of the QA and QC groups based on an evaluation by an outside consultant. These changes will permit these groups to provide more and improved audits and inspections of our licensed activ-ities.
Management will continue to take action to resolve the problems identified by the Quality Program.
We have significantly increased the level of management involvement and review of our nuclear activities.
The Vice President, Generation and Construction and Director, Nuclear Operations have been onsite for one or two days almost every week since mid-September of 1980 and have been deeply involved in specific areas of licensed activities, including:
Training, Health Physics, Operations, and Maintenance.
We expect to continue this level of involvement as necessary to ensure adequate atten-tion and control.
We have conducted detailed monthly briefings to the AP&L Chief Executive Officer and his key executive staff members of the ongoing activities at ANO.
To date, two of these briefings have been conducted at ANO.
We are also providing periodic reports to the AP&L Board of Directors to ensure they are aware of activities impacting the safety and operation of ANO.
AP&L has initiated a number of specific programs intended to improve the overall management and control of ANO.
Our August 13, 1980 letter to Mr. Seyfrit, described the Position Task Analysis (PTA) program which will certainly result in better definition of position responsibilities and more appropriate training programs.
A Task Management System is also underway which is performing a detailed review of each of the functional areas at ANO.
The purpose of this review is to evaluate the activities of each group, ensure adequate systems are available to permit the efficient util-ization of existing manpower and to evaluate the need for additional man-power.
AP&L is also in the process of implementing a new relational data base management information system.
This system, when complete, will pro-vide a powerful tool to assist AP&L management in the control of our nu-clear activities. The new computer for this system will be on site before the end of this year and operational by May 31, 1981.
We have brought in outside, independent consultants to review certain areas of our operation and identify our weak and problem areas.
Areas that have received this review include Health Physics, Training, Quality Assurance and Quality Control.
Specific action programs have been initiated as a result of each of these reviews.
We have increased our audits and inspections of the AN0 Security System and have authorized additional I&C tecMicians who will be dedicated to supporting the Security System.
Until we can fill our authorized I&C
Mr. K. V. Seyfrit November 21, 1980 positions, we have obtained the services of a vendor to provide I&C tech-nicians to provide the necessary support.
We have also increased the use of special audits by the Corporate Safety Review Committee to provide detailed investigation of deficient areas of ANO operation.
We are in the process of implementing an entire new set of Administrative Procedures at ANO.
These new procedures are written to reflect the recent revision to the AP&L Quality Assurance program.
These procedures provide significant improvement in the quantity and quality of direction provided to the ANO staff on the conduct of business at ANO.
AP&L is deeply committed to the safe, efficient operation of its nuclear units.
In order to ensure this, we are dedicated to providing the tools and resources necessary to adequately manage and control our activities.
I believe that previously identified programs are a positive step in that direction and that the level of management attention focused on ANO will ensure a continuing program of identification and correction of weakness and problem areas.
We certainly hope that this letter provides a clear and complete overview of the actions we have taken and are continuing to take to upgrade the level and quality of our management controls of licensed activities at ANO.
If you have any additional questions or concerns, we would be more than willing to discuss them with you.
Very truly yours, OM0 David C. Trimble Manager, Licensing DCT:GAC:sl cc:
Mr. Victor Stello, Jr., Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D. C.
20555
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