ML20028F353
| ML20028F353 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/24/1982 |
| From: | Jaudon J, Johnson E, Johnson W, Lanik G, Showe S, Showe S, Trammell C, Willis C, Young R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20028F352 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 50-313-82-29, 50-368-82-27, IEB-79-06B, IEB-79-09, IEB-79-11, IEB-79-13, IEB-79-18, IEB-79-19, IEB-79-23, IEB-79-24, IEB-79-25, IEB-79-28, IEB-79-6B, IEB-79-9, IEB-80-05, IEB-80-10, IEB-80-11, IEB-80-12, IEB-80-15, IEB-80-16, IEB-80-18, IEB-80-20, IEB-80-24, IEB-80-5, IEB-81-01, IEB-81-02, IEB-81-1, IEB-81-2, NUDOCS 8302010258 | |
| Download: ML20028F353 (14) | |
See also: IR 05000313/1982029
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U. S. NUCLEAR REGULATORY C0t#1ISSION
REGION IV
NRC Inspection Report:
50-313/82-29
50-368/82-27
Dockets:
50-313
Licenses:
50-368
Licensee: Arkansas Power and Light Company
Post Office Box 551
Little Rock, Arkansas
72203
Facility Name:
Arkansas Nuclear One (ANO), Units 1 and 2
Inspection At:
ANO Site, Russellville, Arkansas
Inspection Conducted:
September 7-17, 1982
Team Leader:
E. H. Johnson, Director of Enforcement, Region IV
Date
Team Members:
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Jf.P.CJapon, React'orInspector,ReactorProjects
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C. M. Trammell, Project Manager, Nuclear Reactor
Date
Regulation
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% C. A. Willis, Leader, Section B, Effluent Treatment
Date
Systems Branch, Nuclear Reactor Regulation
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S. K. Showe, Chief, PWR Technology Branch, NRC
Date
Reactor Training Center
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G. F. Lanik, Senior Reactor Systems Engineer, Office
Date
of Inspection and Enforcement
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R. M. Young, Reactor Systems Engineer, Office of
Date
Inspection and Enforcement
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Approved:
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W. D.[Johngon, $hief, Reinctor Project Section C
Date
Inspection Summary
Inspection conducted September 7-17. 1982 (Report 50-313/82-29, 50-368/82-27)
Areas Inspected:
Special, announced inspection to review and verify that
licensee actions taken, and commitments made,'in response to NRC
communications were carried out as indicated.
Four categories of NRC
documents, which normally require actions or commitments by licensees', were
covered by this review:
IE Bulletins, NRC Inspection Reports, NUREG-0737
items, and NRR Generic Letters.
NRC communications and corresponding
licensee responses, since April 1979, were included in thir. review. .A total of
112 man-hours was spent by six NRC staff members in reviewing NRC and licensee
correspondence in-office to identify specific commitments. An additional 246
man-hours were spent onsite in verifying that these commitments had been
completed as indicated in licensee correspondence to the NRC.
Results:
No items of noncompliance or deviations were identified to the
licensee as a result of this special review effort.
Certain items of concern
were identified which could result in future enforcement actions.
These items
were discussed with the licensee and are noted in the following paragraphs.
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DETAILS
1.
Persons Contacted
Arkansas Power and Light Company
B. Baker, Operations Minager
M. Bishop, Office Services Supervisor
W. Cavanaugh III, Senior Vice President - Energy Supply
L. Duggar, Manager, Special Projects
J. Enos, Licensing Supervisor
E. Ewing, Manager, Engineering and Technical Support
J. Griffin, Assistant Vice President, Nuclear Operations
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D. Hardin, Manager, Quality Assurance
D. Howard, Licensing Supervisor
L. Humphrey, Plant Administration Manager
J. Levine, General Manager, ANO
J. Marshall, Manager of Licensing
D. Moggenberg, Special Projects Coordinator
D. Rueter, Director, Technical and Environmental Services
L. Sanders, Maintenance Manager
L. Schempp, Manager, Nuclear Quality Control
J. Vandergrift, Training Superintendent
The NRC team also contacted other plant personnel including
administrative, clerical, document control, engineering, and operations
personnel.
2.
Re,ason for the Special NRC Review
In March 1980, the NRC issued IE Bulletin 80-06 which required the
licensee to review Engineered Safety Feature (ESF) schematics to
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determine if the components would return to an unacceptable state upon
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reset of the ESF signal.
Following this review, the IEB required that-
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testing be performed to verify that the installed controls were consistent -
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with the schematics.
In a letter dated June 18, 1980, submitted under oath
in accordance with 10 CFR 50.54(f), the licensee indicated that all required
testing had been accomplished on both units.
During NRC inspection 50-368/82-05, it was determined that the testing on
Liitt ? had not been completed.
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Because of the direct safety significance of this event, the NRC is
consider *ng escalated enforcement action for the misinformation
communicated to the NRC.
In reviewing the facts of the event, and the licensee's past compliance
history, several items wherein commitments were not completed as
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specified in the licensee's correspondence to the NRC were identified.
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As a result of this, it was decided that an immediate review of licensee
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communications with the NRC should be undertaken to determine whether'
other instances of misleading'information being sent to the NRC had
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occurred.
This review, to cover the time frame from April 1979 to the
present, was to include the major categories of NRC correspondence with
licensee's that required actions or commitments.
These communications
are:
IE Bulletin responses, NUREG-0737 " Clarification of TMI Action Plan
Requirements" responses, responses to NRR generic letters, and responses
to NRC inspection reports.
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A review team consisting of persons from Region IV, IE, and NRR was
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selected to conduct this review.
3.
Review Methodology
During the week of September 7-10, 1982, the review team selected
specific licensee commitments which had been made in response to IE
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Bulletins, NRC Inspection Reports, NUREG-0737 items, and NRR Generic
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Letters.
These specific commitments were found by analyzing licensee
correspondence to identify clearly auditable actions that the licensee
had either stated were completed or would be completed at a future date.
The team was divided into three subgroups for the analysis of
commitments.
One subgroup reviewed both IE Bulletin responses and NRC
Inspection responses, while the other subgroups concentrated on
NUREG-0737 item responses and NRR Generic Letter responses, respectively.
During the week of September 13-17, 1982, the team visited the ANO site.
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While onsite, team members reviewed objective evidence to determine the
status of commitments. This objective evidence included procedures,
letters, internal memoranda, design change packages, completed
surveillances and other tests, drawings, and the sighting of installed
equipment.
Discussions were also held with the Resident Reactor-
Inspectors.
The licensee was informed of the special team site visit on September 9,
1982.
Details of the inspection were not provided until September 13,
1982, when the team was onsite.
The licensee provided members of his
staff to support each subgroup by assisting in gatherin; the large volume
of requested records.
The scope of the review was essentially all items within the selected
area except those on which there had already been extensive followup
(e.g., a special inspection) or for which no member of the team had the
required expertise (e.g., radiographic interpretation).
In the case of
findings for NRC Inspection reports, the licensee's corrective action for
these items receives individual and detciled followup by NRC inspectors;
therefore, in the context of this special review, only recurring problems
were selected.
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Although the review covered a broad sampling.of commitment categories
over a significant period of time, the special-review group did not
attempt to verify the technical adequacy of the licensee's responses or
commitments.
The review focused, ir, stead, on whether these commitments,
had been carried out a;. indicated.
For NUREG-0737 items,.where responses
or commitments were plant specific, ANO-2 was selected as the plant for
review,
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A list of all items reviewed is contained in the table. ~ The' following
sections summarize tts review.
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Review of NRR Generic Letters
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The scope of this review effort was NRR Generic Letters'sent to AP&L
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during the period from April 1979 to the present.
A total' of 12 Generic :
Letters containing 22 commitments or required actions was reviewed.
Letters associated with requirements subsequently incorporated into
NUREG-0737 ware not reviewed since these were tia subject of seperate
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review.
No items of material misinformation or failure to carry out a commitment
as described were discovered during this portion of the review.
One item requiring additional followup by the review team _was discovered,-
and was resolved to the satisfaction of the review team that it did not
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constitute material misinformation.
In the licensee's letter to D. G. Eisenhut dated October 21, 1982,
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responding to Generic Letter 81-04, AP&L indicated that station procedures
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have provisions for the isolation of reactor coolant system letdown and
seal return. The purpose of this procedural _ step would be to-reduce
inventory loss from the reactor coolant system.
Because the seal return
1.ne on ANO-2 contains a relief valve, which would lift if the seal-
return line were isolated, thus allowing continued inventory loss,
the licensee did not put procedural steps in the ANO-2 procedures requiring
isolation of the seal return during a station blackout. 'Instead, an
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analysis was performed cf the ANO-2 reactor coolant system during a station
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blackout to assure that pressurizer level, a measure of system inventory,
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remained at an acceptable level, taking into account the loss through
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seal leakoff. This analysis demonstrated that pressurizer level would
remain in the operating range throeghout the event.
The special review team had no further questions on this matter.
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5.
Review of NUREG-0737 Items
The scope of this review effort was the licensee's responses to
NUREG-0737 items. Where responses were plant specific, the followup and
inspection of objective evidence to determine the correctness of the
response concentrated on ANO-2.
This review included 33 seperate items
with a total of 84 commitments or actions contained in AF&L responses.
No items of material misinformation were discovered.
Three items requiring additional followup to resolve were noted and are
discussed below:
a.
NUREG-0737 II.B.2, Plant Shielding
In partial response to this item, the licensee proposed in a letter
dated March 31, 1980, to have automatic isolation of letdown and
seal return flow in the event of high radiation levels.
In
addition, a warning step was to be included in the decay heat
removal procedures for ANO-1 to ensure that operators were aware of
the potential impact of using these systems, if radiation levels were
high.
In a letter dated October 27, 1980, the licensee stated that
all plant shielding items were complete, except a procedure change to
assure manual isolation of letdown and seal return when radiation
levels were high.
Although not explicitly spelled out in this
letter, the licensee had dropped the idea of'providing automatic
interlocks to isolate seal return and letdown, and would instead
rely on manual isolation.
In a letter dated December 31, 1980, the licensee addressed the
issue of how the procedural steps for isolation of seal: return and
letdown would be accoiaplished.
The letter stated that the only way
that the letdown and seal return lines could become so heavily
contaminated, as to constitute a problem for access around the
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volume control tanks, would be under conditions of inadequate core
cooling.
The letter continued that the appropriate operator response
would be contained in the Inadequate Core Cooling Operator Guidelines
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which were being prepared for another NUREG-0737 item.
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In a letter dated November 30, 1981, the licensee furnished the NRC
the reasons for the apparent differences in the letters of March 31
and October 27, 1980. This letter indicated that the idea of
automatic isolation had been abandoned in favor of manual
isolation.
The letter further states that the position relative to
item II.B.2 remains as spelled out in the letter of December 31, 1980.
At the time of the special review, these guidelines were still in
preparation.
The November 30, 1981, letter further states that the other procedural
changes (without being specific) as noted in nrevious letters (without
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specifying which letters) had been completed.
An NRC Region IV
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. inspection of June 21-25, 1982, had idertified that station
procedures for Unit Two did not contain steps requiring the: isolation
of letdown and seal return under accident conditions involving core
damage. A careful review of the letters dated March 31, 1980,
October 27, 1980, and December 31, 1980, by Region IV personnel
determined that the isolation of letdown and seal return was to be
accounted for in a review of the Inadequate Core Cooling Operator
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Guidelines and that the procedure that was actually deficient was
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the Unit One decay heat removal procedure which lacked a warning
statement to caution operators if. activity levels were high.
As a
result of this deficiency a Notice of Deviation was issued (NRC
Report 50-313/82-14, 50-368/82-11).
At the time of the special review, it was learned that both Unit One
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and Two decay heat removal procedures, were revised on September 8,
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1982, to include the required cautions.
In addition, the emergency
procedure for high activity in the reactor coolant system for both
units was revised on the same day to provide caution notes to
operators concerning the use of decay heat removal.
The NRC special review team had no further questions on this matter,
b.
NUREG-0737 Item II.B.3.-Post-Accident Sampling System (PASS)
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In a letter dated March 9, 1982, AP&L stated that, notwithstanding
the problems encountered with the boron analysis equipment, it would
not prevent use of the PASS in an emergency.
In a ?etter dated
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May 7, 1982, AP&L stated that "the ANO . . . PASS is now installed-
and capable of obtaining a sample of primary coolant for ANO-1 and
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ANO-2."
On May 19, 1982, during an emergency drill, manual block valves
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located in the lower level of the Auxiliary Building were closed.
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They were closed because of a solenoid valve failure downstream.
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Under the specific assumptions of the drill (a highly radioactive
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water leak into Auxiliary Building), access to the valves to reopen
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and take a PASS sample would have been very difficult.
These developments led to a letter from Region IV to AP&L dated
June 4, 1982, asking AP&L to review its prior statements regarding
PASS operability.
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AP&L responded in a letter dated June 18, 1982, indicating that
although some difficulties were being experienced with the on-line
analysis equipment, the system was capable of drawing a sample.
The
letter outlined the status of the PASS system.
Region IV is responding to this letter.
The special review team had no further question on this matter.
c.
NUREG-0737. Item II.F.1.2, Handling Highly Radioactive Samples
In a letter dated November 30, 1981, AP&L stated that the procedures
for removal, transportation, and analysis of sample filters that
could be highly radioactive were being developed and would be
completed by June 1, 1982.
The review team discovered that only low
level samples from normal operations were addressed in procedures
and not the highly radioactive samples, as stipulated.
The review team determined that the necessary procsdures were being
developed when the above letter was written.
Development stopped,
however, when an erroneous calculation (discovered later by the
review team member) indicated that the equipment that had been
purchased could not cope with the radioactive source term that was
specified in NUREG-0737.
AP&L personnel had discussed this matter
with the NRC staff who indicated that the equipment was satisfactory.
Evidently, AP&L concluded that they need not be prepared to handle
high level samples.
When this was discussed with the licensee during the review, this
misunderstanding was acknowledged, and it was indicated to the NRC
review team member that the required procedures would be developed
as soon as possible.
In turn, the NRC review team member agreed to
provide additional information concerning the NRC's position on this
matter.
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The lack of these procedures is ameliorated by the ' interim method'
of post-accident sampling developed under NUREG-0578.
This method
is capable of providing a gaseous effluent sample until the long
cange procedures of Item II.F.1.2 nre ready.
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There were no further questions on this item.
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6.
Retiew of IE Bulletin Responses and Responses to NRC Inspection Reports
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The scope of this review effort was the licensee's responses to IE
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Bulletins and NRC inspection reports.
As in other areas, the review of
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objective evidence to determine the accuracy of the licensee's responses,
concentrated on, but was not limited to ANO-2.
A total of 32 commitments
or required actions were included in this area of the review.
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No items of material misinformation were" discovered in this area of the
review.
One item was noted wherein the licensee failed to carry out a committed
activity as indicated.
This item will be the subject of a Notice of
Deviation.
Item 6 of IEB 79-19 required licensees to develop a training program for
all personnel involved in radioactive waste handling, packaging, and
transport.
In the licensee's letter dated November 30, 1979, the NRC was-
informed that this program would be in place by July 1980.
In
November 1979, the licensee contracted to have this training program, and
the other related actions required by this IEB, prepared.
In the spring
of 1980, the contractor delivered the first parts of the prepared program
(not including the training program).
In October 1980, the contractor
informed the licensee that the June 1980 contract date had been missed
for the delivery of the training program, since the two contractor employees
who were solely responsible for writing it, had left the company.
At about this same time, the f.N0 manager, who had been assigned
responsibility for following this project, left the site.
Apparently, no
turnover was made on this commitment and the contractor did not pursue
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the matter of completing the training program.
During 1981, the licensee's training department, independent of the
requirements of IEB 79-19, prepared a radwaste training program that
meets some, but not all of the elements in the IEB.
This program has
already been implemented.
The review team had no other questions in this area.
7.
Conclusions
Based on the broad sample of commitments selected and reviewed, the
following conclusions were reached by the NRC special review team:
a.
No new items of material misinformation were discovered.
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There does not appear to be a deliberate attempt to not carry out
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commitments.
c.
There have been failures to identify specific commitments made, and
to track them to ccmpletion.
d.
The licensee's audit mechanisms apparently have not been effective
in identifying the failure to complete commitments either in the
specific instances noted above or as a general failing.
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e.
Internal licensee communications regarding NRC responses and the
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tracking of commitments, in the past, have been poor.
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Exit Interview
There was no formal exit interview conducted as the overall conclusions-
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had not been reached by the review team at the completion of the site
visit.
9.
Additional Inforuation
During the site visit, the NRC review team leader was briefed on the
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licensee's plans, both immediate and long range, to improve
communications among the licensee's organizational units and with the
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NRC, and to improve the tracking of commitments.
Tnis program has been
described in more detail in the licensee's letter dated September 29,
1982, to the NRC Region IV Regional Administrator.
The steps outlined in
this letter are generally responsive to the conclusions of the special
review team.
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TABLE 1
LICENSEE COMMITMENTS REVIEWED
NUREG-0737 " Clarification of TMI Action Plan Requirements"
NUREG-0737 Item
Subject
I . A.1.1
Shift Technical Advisor - Training
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I.A.1.3
Shift Manning
I.C.1
Inadequate Core Cooling Procedures
I.C.5
Feedback of Operating Experience
I.C.6
Verify correct Performance of Operating.
Activities
II.B.1
RCS Vents
II.B.2
Plant Shielding
II.B.3
Post-Accident Sampling
II.B.4
Training of Mitigating Core Damage
II.D.1
Relief and Safety Valve Testing
II.E.1.1
AFW System Evaluation
II.E.1.2
AFW Auto Start and Flow indication
II.E.4.2.5
Containment Pressure Setpoint
II.E.4.2.6
Containment Isolation - Purge Valves
II.E.4.2.7
Containment Isolation - Radiation
Signal
II.F.1.1
Noble Gas Monitor
II.F.1.2
Iodine /Particular Sampling
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NUREG-0737 Item
Subject
II.F.1.3
Containment Hi-range monitor
II.F.1.4
Containment Pressure
II.F.1.5
Containment Waste Level
II.F.1.6
Containment Hydrogen
II.F.2
Instrumentation for Detection of
Inadequate Core Cooling
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II.K.2.13
Thermal-Mechanical Report
II.K.2.17
Voiding in the Reactor Coolant System
II.K.2.19
Sequential Auxiliary Feedwater Flow
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II.K.3.3
Report on Safety / Relief Valve Failures
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II.K.3.5
Automatic Trip of RCP During a LOCA
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II.K.3.17
ECC System Outages
II.K.3.25
Power on Pump Seals
II.K.3.30
Small Break LOCA Methods
III.A.1.2
Upgrade Emergency Support Facilities
III.D.3.3
Inplant Radiation Monitoring
III.D.3.4
Within these 33 line items, a total of 84 commitments or statements were verified.
NRR Generic Letters
Letter Date or Number
Subject
September 21, 1979
Followup of Multiple Equipment Failures
and Surveillance Testing Errors
October 17, 1979
Lessons Learned from Release at North
Anna
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November 9, 1979
Fuel Clad Swelling
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February 23, 1980
Containment Isolation Valves
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Letter Date or Number
Subject
June 11, 1980
Decay Heat Technical Specifications
July 31, 1980
Staffing Requirements
December 15, 1980
FSAR Update
81-04
Station Blackout
81-14
Seismic Qualification of Auxiliary Feed
81-19
Thermal Shock to Reactor Pressure Vessel
81-21.
Natural Circulation Cooldown
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81-28
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Steam Generator Overfill
Within these 12 generic letters, a total of 22 commitments or statments were
verified.
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IE Bulletins-
Bulletin
Subject
79-06B
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TMI Issues
79-09
GE Circuit Breakers
79-13
Cracking in Feedwater System Piping
79-11
Westinghouse Relays
79-18
Audibility of Evacuation Alarr.s
79-19
Radioactive Waste Management
79-23
Diesel Generator Field Exciter
Transformer
79-24
Frozen Lines
79-25
Westinghouse Relays
79-28
Namco Switches
80-05
Vacuum Conditon in Tanks
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80-10
Contamination of Nonradioactive System
80-11
Masonry Wall Design
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Bulletin
Subject
80-12
Decay Heat Removal Operability
80-15
Possible Loss of Emergency
Notification System
80-16
Rosemount Pressure Transmitters
80-18
Minimum Flow Through Centrifugal
Charging Pumps
80-24
Flooding of Containment Sump
80-20
Westinghouse Switches
81-01
Mechanical Snubbers
81-02
Failure of Gate Values to Close
Against Differential
Of the 21 IEB's contained in this review, a total of 29 specific commitments
or statements.
NRC Inspection Reports
Item
50-313/80-03, 50-368/80-03
50-313/80-05
50-313/80-06, 50-368/80-06
50-313/80-10, 50-368/80-10
50-313/80-15, 50-368/80-15
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