ML20055H951

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-313/90-01 & 50-368/90-01

ML20055H951
Person / Time
Site:	Arkansas Nuclear
Issue date:	07/23/1990
From:	Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Carns N ENTERGY OPERATIONS, INC.
References
NUDOCS 9007310192
Download: ML20055H951 (3)

See also: IR 05000313/1990001

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In Reply Refer To:

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Dockets: 50-313/90-01

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50-368/90-01

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Entergy. Operations..Inc.

ATTN: Neil S. Carns, Vice President

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. Nuclear. Arkansas Nuclear One

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Route 3 Box 1376

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Russellville, Arkansas 7?B01

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Gentlemen:

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Thank you for your letter of July 6 1990, in response to our letter and

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Notice of Violation dated June'4 1990. We have reviewed your reply and find

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itresponsivetotheconcernsralsedinourNoticeofViolation. With regard

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to staffing level of non-licensed operators, we acknowled9e your validation

efforts as mentioned in your letter and as previously discussed between your

staff and Region IV management on June 14, 1990. We look fomard to receiving

your. correspondence documenting the validation of the required staffing levels.

We will review the implementation of your corrective actions during a future

inspection to detemine that full compliance has been achieved and will be

raintained.

.

Sincerely,

Original Signed By:

Samuel J. Collins

Samuel J. Collins, Director

Division of Reactor Projects

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CC:

Entergy Operations, Inc.

ATTN: . Donald C. Hintz, Executive-

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Vice President

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P.O. Box 31995

Jackson, Mississippi 39286

Entergy 0perations, Inc.

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ATTH:; Gerald W..Muerch.-Vice President

. Operations Support

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P.O. Box 31995

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Jackson, Mississippi 39286

Wise, Carter, Child & Caraway

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ATTH: Robert B..McGehee, E'q.

P.O. Box 651-

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ATTH: Early Ewing, General Manager

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P.O.-Box 608

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Russellville, Arkansas 72801

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Arkansas Nuclear One

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ATTN: Jerry Yelverton, Director

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Route 3 Box.137G'-

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Russellville, Arkansas 72801

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Arkansas Nuclear One

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ATTH: Mr. Tom W.' Nickels

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Russellville Arkansas, 72801

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Combustion Engineering, Inc.

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ATTN: . Charles B.:Brinkman, Manager

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Washington Nuclear Operations

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'12300 Twinbrook Parkway, Suite 330

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Rockville, Maryland - 20852

Honorable Joe W. D ': lips

= County Judge of' Pops County.

Pope _ County. Courthouse

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Russellville Arkansas' 72801

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Bishop Cook, Purcell & Reynolds

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ATTN: Nicholas S. Reynolds. Esq.

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4815. West Markam Street

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Nuclear Power Generation' Division

ATTN:

Mr.. Robert B. Borsum

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U.S. Nuclear Regulatory Connission

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U.S. Nuclear Regulatory Commission

ATTN: Regional Administrator, Region IV

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JUL l 71990

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July 6, 1990

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SCAN 879987.

U. S. Nuclear Regulatory Commission

Document Control Desk

. Mail Station P1-137

Washington, D. C.

20555

SUBJECT:

Arkansas Nuclear One - Units I and 2

Docket No. 50-313/50-358

License No. DPR-51 and NPF 6

Response to Inspection Report

50-313/90-01, 50-368/90-01

Gentlemen:

,

Pursuant to 10CFR2.201, attached is the response to the violation identified.

in the sub, ject inspection report concerning the failure to adequately establish

and maintain the ANO-2 Emergency Operating Procedure (EOP).

The inspection report

also requested that we address the MC's concern regarding the lack of timeliness

of our response to previous assessments of the ANO-2 E0P. This is discussed in

a separate addendum to the violation response.

As discussed with Mr. Tom

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Westerman of the NRC Region IV staff, the due date of this reponse was

extended one day.

Although the existing E0P does contain inadequacies, we have concluded

independently of the NRC inspection team's assessment that the' skills and

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knowledge of our operators is such that safe operation of the plant is ensured.

The current E0P, coupled with the operators' expertise, is sufficient to

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operate and inaintain the plant in a safe condition should a transient occur

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which necessitated use of the E0P.

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The management of ANO.is fully appreciative of the significance of this

violation.

Concerns regarding the adequacy of the ANO-2 E0P had been raised

prior to the . inspection and an E0P upgrade had been included in the AND

Business Plan.

Considerable efforts and resources are dedicated to providing

an interim revision to the ANO-2 E0P and to upgrading the E0P to procedures.

based on the Combustion Engineering Owners Group Generic Guidelines Document-

. CEN-152. The end result of this effort will be a quality E0P well supported

by a verification and validation process, the E0P writers guide, the operator

training program, and a documented method of applying the CEN-152 generic

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guidelines to our specific plant.

Consistent with Generic Letter 82-33, ANO

will be developing a procedures generation package for NRC review.

Our goal

is to achieve. excellence in plant operations at ANO, and the ANO-2 E0P

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upgradeisviewedasavita13tepinachievingthatgoal.

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July 6, 1990

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Very truly yours,

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J. W.

lverton

Dire or, Operations

JWY/JDJ/sgw

Attachment

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Regional Administrator

Region IV

U. S. Nuclear Regulatory Commission

611 Ryan Piara Drive, suite 1000

Arlington,' Texas 76011

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Failure to Establish and Maintain Appropriate Plant Pracedures

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Unit 2 Technical Specification 6.8.1 requires that " written procedures be

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established, implemented, and maintained " covering a list of activities

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including the applicable procedures recommended in Appendix A of Regulatory

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Guide 1.33, November 1972. Appendix A to Regulatory Guide 1.33, November

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1972 lists typical safety-related activities such as combating emergencies

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(Section F) which should be covered by written proceduos.

Licensee

Procedure E0P 2202.01, " Emergency Operating Procedure." had been

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promulgated as the procedure for combating operational emergencies.

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1.

Failure to Establish Appropriate Plant Procedures

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Contrary to the above, the licensee did not establish procedures for

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certain aspects of operational emergencies.

Specifically, Procedure E0P

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2202.01 did .,ot appropriately establish the process to achieve plant

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recovery for certain operational emergi ncies, nor did it adequately

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consider multiple failures as stipulate 1 in NUREG-0737, Item I.C.1, and

implemented by the order of December l'/,1982, pursuant to 10CFR50.54(f).

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The following examples ' pertain:

While responding to a simulated reactor coolant system leak using *

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a.

Procedure E0P 2202.01, Section 9.0 SIAS (safety injection

actuation signal), recovery actions could not be completed

because the procedure did not provide guidance for natural

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circulation cooldown in the saturated condition with partial

voids. The recoverability of pressurizer level and subsequent

subcooled margin was assumed, but no procedure was provided in

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the event these conditions could not be achieved,

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b.

While responding to a simulated inadequate core cooling event

following a feed line rupture, the emergency core cooling system

(ECCS) was to be used to establish cooling in accordance with

Procedure E0P 2202.01, Section 12.8.

When emergency feedwater

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was restored, the E0P gave no guidance for securing ECCS cooling

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and continuing recovery using emergency feedwater.

Further, the

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long-term recovery actions using the ECCS took the plant to the

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cold shutdown condition.

Shutdown cooling was achit'ed using

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Operating Procedure (0P) 2104.04, " Shutdown Cooling System,"

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without terminating the vent release path,

For simulated steam line break inside containment concurrent

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with a tube rupture in the same steam generator, main steam

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isolation signal, recovery could not be completed using Procedure

E0P 2202.01, Section 8.0.

The E0P failed to account for the

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inability to recover pressurizer saturated condition.

The

procedure also failed to provide for an evaluation of a tube

rupture and did not direct the operator to proceed to either

Section 10.0, " Steam Generator Tube Rupture Greater Than Charging

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Pump Capacity," or Section 11.0, " Inadequate Core Cooling." In

addition, the recovery actions specified in Section 8.0 of the

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procedure would havervorsened recovery by increasing the loss of

reactor coolant and containment radiation levels.

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d.

While responding to a simulated steam generator tube rupture

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(with coolant loss greater than char

compounded by a blackout condition, ging capacity) that was

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recovery could not be made

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using the E0P as structured.

Section 11.0 of Procedure E0P

2202.01 provided guidance for the tube rupture, but made no

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provision for handling the blackout condition. Therefore, plant

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conditions could be worsened and core integrity could be challenged

unless experienced operators intervened to compensate for the E0P

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. inadequacy.

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2.

Failure to Maintain Appropriate Plant Procedures

Contrary to the above, the licensee failed to maintain certain aspects of

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the plant procedure for combating operational emergencies.

Specifically,

Procedure E0P 2202.01 had not been adequately verified and validated as

demonstrated by the following examples:

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a.

The verification and validation (V&V) process failed to ensure

that previously identified technical issues, such as the use of

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the reactor Vessel level monitoring system (NUREG-0737 II.F.2),

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void formations in the reactor coolant system, and the verification

of adequate safety injection flow, had been incorporated in the g. '

E0Ps.

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b.

The V&V process failed to include sufficient plant walkthroughs

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to identify safety hazards that could nesgate in plant recovery

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evolutions..

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c.

The V&V process failed to provide for complete and comprehensive

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feedback to management to ensure that inadequate conditions, such

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as resource allocation, were corrected.

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d.

The V&V process failed to ensure that the E0Ps were modified

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following the installation of the diverse scram system and the

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control room annunciator upgrade modifications installed during

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refueling outage 2R7 (October 1989).

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The above examples constitute a Severity Level IV violation.

(Supplement 1)

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(368/9001-01)

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1.

The reason for the violation:

The violation is cited in two parts:

failure to establish appropriate

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procedures and the failure to maintain appropriate procedures.

The ANO-2 Emergency Operating Procedure (EOP) in its current format was

established as a result of the ANO TMI-2 Response Program, an internal

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action program initiated prior to the issuance of NUREG-0737.

Both the

Babcock & Wilcox Owners Group (BWOG) and the Combustion Engineering

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Owners Group (CEOG) were developing technical guidelines for use in

writing E0Ps.

However, the CEOG made the decision initially to use

event specific optimal recovery guidelines rather than a symptom-based

approach.

The BWOG Abnormal Transient Operating Guidelines (ATOG) was

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using a symptom-based approach which was also plant specific.-

This

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philsophy was in line with the direction which ANO-2 wanted to take in

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developing the E0P.

(The ATOG document was subsequently reviewed and

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accepted by the NRC in a safety evaluation, Generic Letter 83-31, dated

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September 19,1983.) Therefore, the decision was made to base the

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AND-2 E0P on plant-specific guidelines using input from ATOG.

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accordance with Generic Letter 82-33, " Supplement I to NUREC-0737 -

Requirements for Emergency Response Capability," ANO-2 developed plant-

5pecific guidelines which were submitted for NRC review by our letter. *

dated December 5 1984 (2CAN128483).

Since ANO-2 was the only CE rnit

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not to use generic technical guidelines, it was difficult to perform an

effective comparison for methods of compliance with generic recommendations.

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Also, due to a lack of effective management involvement, the use of

plant-specific guidelines tended to insulate the ANO-2 E0P effort from

improvements occurring in the industry with tho'CE0G guidelines and in

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the areas of human factors and human performance,-verification and

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validation, and E0P development and revision,

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Rrwiing the failure to appropriately maintain the E0P, the violation

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specifically states that the E0P had not been adequately verified and

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validated.

The verification and validation (V&V) process was developed

in house without fully utilizing oxisting industry expertise.

The V&V

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process slso had.not been revised to conform to.the guidance in NUREG-0899

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and NUREG-1358. Specific weaknesses in the process included (1)-the

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failure to perform complete walkdowns of the procedure which included

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actions outside the control room, (2) the resolution of validation

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comments or concerns by the individual who originated the comment, and

(3)-lack of a multidiscipline review of revisions.- Also,.the resolution

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process did not ensure proper feedback of concerns to management.

The cause of the violation was a lack of effective management involvement

to ensure that the ANO-2 E0P effort kept pace with industry standards.

Although the current E0P requires improvement, ANO management is

confident that the operators are fully capable of performing the

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actions required to maintain the plant in a safe condition during a

transient.

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2.

T_he corrective steps which have been taken and the results achieved:

As discussed in our letter of April 20, 1990 (SCAN 849812), several

actions have been taken to upgrade the existing ANO-2 E0P.

These

actions will result in an adequate procedures generation package to

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ensure the proper maintenance of the ANO-2 E0P. Actions have also been

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taken to ensure the operators' continued ability to use the existing

E0P.

The E0P action plan includes the following:

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The ANO Business Plan item C.11.c, " Procedure Upgrade - Emergency

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Operating," has been revised.to include the detailed E0P action plan

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submitted in our letter of April 20, 1990.

Discussions have been held with the operating crews by the Operations

Manager on operating philosophy using the existing E0P.

Strategies for

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coping with inadequacies in the procedure were presented.

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An experienced and knowledgeable senior Shift Operations Supervisor

from'ANO 2 has been assigned through December 1990 to assist in-

simulator training.

This action provides more uniform and consistent

training to sustain operator performance and helps standardize

acceptable approaches _to handling plant transients which may not be *

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completely bounded by instructions in the E0P.

Also, time on the

simulator during the training week has been increased-for each crew

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from approximately 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per week to approximately.16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> per week.

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In addition, E0P lesson plans will be written for each specific tab

of the E0P.

These lesson plans will incorporate changes being made

by the interim E0P revisions.and will address certain elements of

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CEN-152.

Training to the revised lesson plans is scheduled to

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begin during August-1990 in preparation for implementation of the

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interim E0P revision.

Suggestions for improvements to training will-

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' continue to be made using the Training Evaluation-Action Request forms.

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A self-assessment of the ANO-2 E0P was performed.

Previous assessments

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conducted by Combustion Engineering and various contractors (e.g.,

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human factors subject matter expert) were reviewed as well as the NRC's

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findings from the E0P inspection.

No concerns were identified of such

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safety significance to warrant immediate corrective actions.

The review

also included the thirty-eight procedure improvement forms submitted by

operators on the ANO-2 E0P since the inspection.

Items were identified

which could appropriately be addressed in a planned interim revision to

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the E0P (discussed below).

The remaining items will be resolved by the

upgrade of the E0P to the CEN-152 guidelines.

The V&V process has been upgraded with the assistance of a subject

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matter expert in the area of human performance and human factors.

The revised V&V process has been verified against the appropriate

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NUREG guidelines. This process now includes multidisciplinary reviews

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of E0P revi, ions and will provide comprehensive feedback of concerns to

operations management.

The upgraded V&V process was available by June

30, 1990, and will be used to implement the interim revision to the E0P

and the planned upgrade to the ^S152 guidelines.

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As'a conservative measure during the inspection, staffing of

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non-licensed operators per crew was increased to ensure that a

sufficient number of operators would be available to implement the

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E0P.

Required staffing levels have been validated, and the results of

the validation will be provided in separate correspondence.

An interim revisiom to the ANO-2 E0P has been initiated which will

address many identified concerns, such as inclusion of more contingency

actions, incorporation of certain human factors enhancements, inclusion

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of the Reactor Vessel level Monitoring System and the Diverse Scram

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System, and further direction concerning actions to mitigate / combat RCS

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- voiding. This revision, scheduled to be implemented October 15, 1990,

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will also include the thirty-eight items identified by the operators on

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procedure improvement forms to date,

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CEN-152 is being used as the basis document in the development of an

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upgraded E0P.

(This action had been initiated prior to the inspection.)

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The upgraded E0P will be i olemented by December 31, 1991.

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A separate Writ'ers Guide specific to the E0P was developed with the

assistance of a subject matter expert in the area of human performance

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and human factors.

The Writers Guide was available by June 30, 1990,

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and is l'eing used to write tha upgraded E0P.

This guide provides

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specifi requirements for E0P writers to use during E0P development

and revisient

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The technical deficiencies cited in the violation have been evaluated

for either inclusion in the interim revision to the E0P or resolution .

- during the CEN-152 upgrade.

The interim revision to the E0P will

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include use of the. Reactor Vessel Level Monitoring System and instructions

for cooling steam generators if voiding is suspected.

This will assist

operators in dealing with a natural circulation cooldown in a saturated

condition. The upgrade of the E0P will fully address this concern in

the functional >ecovery E0P.

The interim revision will also include

instructions to closir the ECCS vent valves should the steam generators

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become available during an inadequate core cooling (ICC) event.

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Long

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term recovery actions from an ICC will be addressed in the upgraded

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E0P. The other two examples cited involved response to multiple

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failure scenarios and will be resolved by the upgrade to CEN-152.

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The examples of V&V process-deficiencies cited in the second part of

the violation have been resolved by (1) particfpation in the CEN-152

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maintenance program, which will help ensure inclusion of technical

issues in the future, and (2) the upgrade to the V&V process, which now

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requires in plant walkdowns of E0P changes, simulator validations

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to NVREG-0899 guidelines and multidiscipline reviews by operations,

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engineering, and training.

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Management involvement has increased in this area.

The E0P action

plan is included in the ANO Business Plan.

The Nuclear Operations

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Standards group is focused on procedure preparation and includes'a

project lead specifically dedicated to the ANO-2 E0P.

Also, operations

management has recently become unit specific up through the plant

manager, allowing increased upper management involvement.

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3.

The corrective steps which will be taken to prevent recurrence,

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The improved V&V process and the scheduled interim E0P revisio) and

up rade of the E0P to CEN-152 will ensure the proper establishment and

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ma ntenance of this procedure.

To increase the effectiveness of Quality Assurance (QA) audits of.the

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E0Ps, both Unit I and. Unit 2, a separate, " stand alone" audit of selected

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E0Ps and Abnormal Operating Procedures (AOPs) is being developed. . Outside

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technical assistance will be used to further enhance the assessment

capabilities of the audit team.

These actions illi increase the breadth

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and depth of QA audits of the E0Ps and provide further assurance that the

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E0Ps are being properly maintained. The 1990 audit of E0Ps and AOPs is

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currently scheduled to begin in September.

Additionally, changes to the

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V&V process and the procedure writers guide are reviewed by QA and QA

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will be reviewing sections of the upgraded E0P as they are distributed for-

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comment prior to implementation.

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4.

The date of full compliance:

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The-interim revision to the current E0P will be implemented upon

completion of operator training by October 15, 1990.

The CEN-152 E0P

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upgrade and operator training will be completed and fu'ily implemented

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by December 31, 1991.

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U.S. NRC'

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. .9

' ' . ; ~. Attachment

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' July 6, 1990

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Page 7

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ADDENDUM

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Inspection Report 50-313/90-01; 50-368/90-01 requested that hNO address the

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NRC's concern regarding the lack of timeliness in our response to previous

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assessments of our E0P performed by consultants and by 1.he NtC with the

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ANO-1 E0P inspection.

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Comments had been previously received from evaluations performed by the

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Institute of Nuclear Power Operations (INPO) and CE.

Both of these evaluations

were based on the guidelines in CEN-152 and many of the comments were not

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properly evaluated for generde applicability to the ANO-2 plant-specific E0P '

. guidelines.

The results of the Nke inspection conducted on ANO-1 were

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reviewed by ANO-2 personnel.

Because the comments tended to be technical

comments specific to the ANO-1 E0P, ANO management did not adequately-review

these technical coments for any common applicability to the ANO-2 E0P.

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Based on AN0's reviews of these comments and the lack of adequate review

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for ANO-2 applicability, we concluded that management involvement was

inadequate during the decision-making process to address these comments.

The December 21, 1989, Diagnostic Evaluation Team Report identified the

i.ame type of concerns with management involvement.

In our response to the

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DET report dated March 14, 1990, these concerns were addressed.

In particular,.

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the strengthening of the organization by recruiting mananment. personnel with

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outside nuclear industry experience and by unitizing pir.nt functions will

help ensure that management will be adequately involver'. in future E0P

efforts.

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As a result of ANO management's review of the ANO-2 FOP, a concern regarding

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the adequacy of the ANO-2 E0P had been raised during the fall of 1989.

This had resulted ~in the formation of the E0P committee to review issues

concerning the ANO-2 E0P, and the decision had been made in February 1990-

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to convert the E0P to a document based on the guidelines in CEN-152.

ANO

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agrees.that the timeliness of this action was less than adequate and believes

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the current management stfucture is more involved in daily decisions, which

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'will enable Tnore appropriate responses should similar situations arise in

the future.

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