ML20235U615
| ML20235U615 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 12/20/1988 |
| From: | Tison Campbell ARKANSAS POWER & LIGHT CO. |
| To: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20235U614 | List: |
| References | |
| 0CAN128803, CAN128803, NUDOCS 8903090286 | |
| Download: ML20235U615 (21) | |
Text
ATTACHMENT 3 AAKANSAS POWER & LIGHT COMPANY P. O. BOX 551/LITTLE ROCK, ARKANSAS 72203/(501) 377 3525 December 20, 1988 T. GENE CAMPBELL l
voce Presiderit - Nucleat DCAN128803 Robert D. Martin Regional Administrator U. S. Nuclear Regulatory Comission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011
SUBJECT:
Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313/50-368 License Nos. DPR-51 and NPF-6 Response to Report of Systematic Assessment of Licensee Performance
Dear Mr. Martin:
~
Arkansas Power and Light Co. (AP&L) has reviewed the NRC report,of Systematic Assessment of Licensee Performance (SALP) of September 16, 1988(0CNA098807), report number 50-313/87-41, 50-268/87-41, for Arkansas Nuclear One, Units 1 and 2.
A management meeting was held October 21, 1988, to review the results of the SALP report, with NRC 1
and AP&L Management providing comments.
Section I of the attachment l
to this letter addresses the general comments discussed in the report and at the subsequent management meeting. This letter serves to address the recommendations for each functional area of the SALP report for areas rated Category 2 as requested in the SALP report.
Also included are the areas rated Category 1.
The functional areas are discussed in Section II.
AP&L is committed to continued improvements in performance and we believe the SALP report reflects this commitment. We appreciate the exchange of information provided by the SALP process and will utilize the information in our efforts to achieve excellence in the management and operation of Arkansas Nuclear One.
8903090286 890301 Very truly yours, PDR ADOCK 05000313
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T. G. Camp ell TGC: den Attachment cc w/att: U. S. Nuclear Regulatory Commission Document Control Desk Washinntnn. 0.C.
20555
Attachment to SCAN 128853 ATTACIMENT 3 DecGmber 20, 1988 Page 1 I.
Introduction The Systematic Assessment of Licensee Performance (SALP) program provides Management with the NRC's assessment of performance in each functional area.
Recommendations for improvement are also included.
Each of the recommendations by functional areas is discussed in Section II.
Strengths Several strong areas and specific strengths were noted by the NRC.
The areas of Plant Operations, Radiological Controls, and Emergency Preparedness were performance Category 1, indicating superior performance.
Training and Fire Protection were also noted as excellent areas within the functional area of Engineering and Technical Support.
Management attention and involvement resulting in improvement in the area of Security were noted, as well as significant programmatic improvements in the Maintenance / Surveillance area.
Specific strengths identified were the college degree program for Operations personnel, the effective plant transient reduction program, the substantial reduction in the volume of radioactive waste generated, and the aggressive action taken to reduce the contaminated area of the plant.
AP&L will continue to effectively implement these programs for future strong performance.
Weaknesses Weaknesses that relate to more than one functional area were noted in root cause evaluations and narrow corrective actions.
The new Condition Reporting System was developed and implemented durir.g the SALP period to address these weaknesses.
For the approximate six months that this program has been implemented, it appears to be effective in broadening the scope of corrective actions.
Further l
evaluation of the effectiveness will be assessed over time.
The weakness concerning ineffective interdepartmental communications between Engineering and Maintenance will be addressed, in part, by the implementation of the Systems Engineering concept which will be phased in over the current SALP period.
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Attach = nt to BCAN128803 j
D:cember 20, 1988 Page 2 II.
Specific Functional Areas A.
Plant Operations Performance Category 1 Recommended Licensee Actions:
Licensee management is encouraged to continue improvement l
efforts in this functional area, including:
Reduction of nuisance alarms.
Reduction of the backlog of deficiencies indicated by the high number of deficiency tags in the control rooms.
Aggressive pursuit of resolution of deficiencies identified by operators.
Revision and improvements of plant and system cperating procedures.
Re,sponse Deficiency Tags and Nuisance Alarms The Work Control and Operations Departments have established a periodic review of Control Room deficiency tags and nuisance alarms.
A weekly printout is utilized to alert work schedulers of a Control Room deficiency to ensure prompt repair.
Deficiencies related to job orders on hold for material or for Engineering input are also identified.
Completion of the Annunciator Upgrade Project will address human factors concerns, including the elimination of nuisance annunciators.
Operations Procedures An Operations Procedure Upgrade Program was undertaken in June 1987 to rewrite emergency, abnormal, and system procedures.
Expected completion is mid-1990.
The AP&L-developed Operations Procedure Writer's Guide and Operations Procedure Format and Content f
procedures have been recommended by INP0 to other utilities.
l Other Improvements An Operator Degree Program was established in the Spring 1987.
The degree, Bachelor of Science in Physical Science (Nuclear), was developed jointly by AP&L and Arkansas Tech University (ATU).
The degree is plant operations / engineering oriented and is a catalog degree program provided by ATU.
Control room operational standards were published in March 1988 to augment the Conduct of Operations Procedure and to standardize operations between units and among shifts.
The standards are used by Training as criteria for evaluating operating crew simulator sessions.
The standards include guidelines on professional appearance and conduct, communication, attentiveness to duty, and teamwork.
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Attachment to 0CAN128803 December 20, 1988 Page 3 A Professional Nuclear Operator Code was developed by an operator-selected committee and issued in May 1988.
The code represents an acknowledgement by the operators of their responsibility to the public, the company, and the nuclear industry for the safe and reliable operation of the station.
The code is displayed in the plant and the simulators.
An Operations department performance monitoring program w6s initiated to self-assess attention to detail.
Shift Supervisors monitor other crews performance and provide constructive feedback and recommendations for improvement.
A control room design review surface enhancements program was completed.
Control panels have been enhanced by human factors improvements including better labeling, color coding, and system boundary lines.
An Operations Support Facility was built on the control room level of the turbine building to reduce congestion in the control room.
The initial Shift Technical Advisor (STA) training program resulted in seven of twelve STAS receiving a Senior Reactor Operator license.
An aggressive Reactor Trip Reduction Program has proven effective in reducing the number of unplanned automatic SCRAMS.
Operating records for both units were broken in 1987 by new highs in availability and production with a combined net generation of over eleven million megawatt hours.
Attachment to SCAN 128803 December 20, 1988 Page 4 B.
Radiological Controls Performance Category 1 Recommended Licensee Actions:
The licensee should continue to make improvements in the existing program.
Supervisory attention should be increased in the detailed conduct of day-to-day operation of the occupational radiation safety program.
Response
Supervisory Attention AP&L has increased supervisory attention in day-to-day activities through additional tours of work areas by supervisors, and increased involvement in the review of radiation work perrnits and review of personnel exposures.
ALARA AP&L established an ALARA Goals Program in early 1987 to establish annual ALARA goals.
The group includes work disciplines from several areas.
Additionally, an ALARA Program Management Review Committee was formed in June 1988 to perform ALARA oversight, review significant radiological events, and to develop solutions to programmatic problems.
The Health Physics (HP) Specialist ALARA Program Coordinator has been assigned the additional support of HP technicians - one for daily support and two for outage support during plant shutdowns.
A dedicated HP Specialist, supplemented with two HP technicians during outage periods, evaluates root causes of personnel contaminations.
Repetitive incidents are identified by computerized tracking and reporting of contaminations.
The corporate Health Physics eversight function has been expanded to include an HP Specialist located on-site and an additional engineer for the corporate staff.
Free Release Program AP&L's Free-Release Program for the reactor auxiliary building has resulted in a significant reduction of contaminated areas.
The reduction achieved is as follows:
- ANO-1:
23,500 square feet (from 35,000 square feet to 11,500 square feet)
- ANO-2:
19,250 square feet (from 27,000 square feet to 7,750 square feet)
Total Reduction:
42,750 square feet.
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Attachment to SCAN 128803 December 20, 1988 Page 5 Radwaste Reduction An aggressive radioactive waste reduction program has resulted in declines in waste generation each year since 1985.
Dry compactible and noncompatible radioactive waste generated is currently sent off-site for processing and packaging or decontamination, resulting in a volume reduction approaching a 10-to-1 ratio.
Other Improvements To improve HP access control and work activities within containment, a reactor building alternate entry facility was utilized during the 1988 refueling outages.
This resulted in improved access control to containment.
A computerized Radiation Exposure Management System was implemented at the end of 1987.
This system tracks and reports personnel exposure, improving'TLD processing, personnel access and dose control, and Radiation Work Permit generation.
AN0's on-site dosimetry program for personnel exposure monitoring was NVLAP accredited in January 1988.
To further improve personnel monitoring, high efficiency personnel contamination monitors have been installed at the radiological controlled access exit for the Auxiliary Building and at the Reactor Building exit during refueling outages.
Additionally, these type of monitors are being located at the old and new radwaste storage buildings.
The ANO whole body count processing has been upgraded to permit on-site evaluation of the whole body counts.
Attachment to BCAN128803 Decemb:r 20, 1988 Page 6 C.
Maintenance / Surveillance Performance Category 2 Recommended Licensee Action:
Licensee management should continue its emphasis on upgrading performance in the maintenance and surveillance areas.
The licensee should continue upgrading maintenance and surveillance 1
procedures to a standardized format including appropriate human i
factor considerations.
During this process, consideration should be given to system testing to prove functional capability in addition to meeting technical specification requirements.
Response
AP&L has made significant improvements in the maintenance and surveillance areas as the developmental phase of several long-term programs has shifted into the implementation phase.
These programs include the Maintenance Procedure Upgrade Program, the Preventive Maintenance Improvement Program, and the Vendor Technical Manual Program.
Various other changes on a smaller scale have contributed to overall improvements in maintenance and surveillance.
Procedures The Maintenance Procedure Upgrade Program has been in place approximately two years.
A Maintenance Procedures Writer's Guide is the basic component of this program.
It provides guidelines for developing and upgrading the quality of the maintenance and surveillance procedures including human factors aspects.
All procedures are expected to be in accordance with these guidelines by the end of 1989.
At present, over six hundred maintenance procedures have been completely revised and approximately two hundred new procedures have been developed.
Preventive Maintenance Program The Preventive Maintenance Improvements Program (PMIP) consists of a detailed preventive maintenance engineering evaluation for safety related and important balance-of plant equipment using the updated vendor technical manuals, additional information obtained from vendors for plant specific components, and operating experience.
Preventive Maintenance procedures are developed based on this information and in accordance with the guidelines of the writer's guide.
Over three hundred procedures have been identified with approximately one-half being developed into repetitive task instruction procedures to-date.
A dedicated group of engineers and technical writers support this program.
The PM activities performed in the 1988 ANO-1
)
refueling outage utilized these procedures.
Scheduling for PM activities is being incorporated into the Station Information Management System database.
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'Attachmznt to BCAN128803 Dectmber 20, 1988 Page.7 Maintenance Personnel Training The maintenance training program has been expanded to upgrade the quality and knowledge of maintenance personnel.
A Maintenance Training Advisory Committee was established to provide recommendations concerning training. A Maintenance Qualification Oral Board process has been implemented to evaluate maintenance personnel and the training effectiveness.
An On-The-Job Training Program provides opportunities for maintenance personnel to learn new skills.
Oversight A Corporate Oversight Program has been instituted for maintenance goal development and trending of performance indicators. Areas where goals are not met are identified and assistance in resolving goal variances is provided.
A Maintenance Oversight Team consisting of representatives from Maintenance, Work Control Center, ard Nuclear Oversight meets regularly to review trends and discuss necessary actions.
Scheduling Improvements in scheduling have been attained through daily planning meetings, establishment of a five-day rolling schedule, craft coordination, and second-shift scheduling support.
Schedule delays are identified and trended by Schedule Deviation Reports which have been effective in minimizing the impact of delays.
Surveillance l
Surveillance activities are performed by several groups including l
Maintenance, Operations, Engineering Support, and Reactor Engineering.
Each group develops procedures to ensure compliance with Technical Specification surveillance requirements.
In certain instances, AP&L has identified that the functional capability of systems or components has not been adequately demonstrated.
As instances are identified, actions are taken to address deficiencies l
by special testing or changes in test methods.
The two examples discussed in the SALP report were ANO-2 controi element assembly drop-time testing and ANO-1 penetration room ventilation system (PRVS) testing.
The first example was resolved during the SALP period.
The second example was resolved during the ANO-1 refueling outage (November 1988) by performance of the PRVS 18-month Operations Surveillance lest Procedure with additional monitoring of l
system parameters.
The Operations Department is reviewing their surveillance testing program to assess that functional capability of systems and components are adequately demonstrated to ensure operability of safety-related systems.
Recent developments in the area of surveillance include implementation of an Operations Trending Program which trends plant equipment parameters such as pump pressures, valve stroke times, and motor vibration.
This program is in addition to the ASME Section XI trending program maintained by Engineering Services.
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1 Attachment to 9CAN128883 Dscember 20, 1988 j
Page 8 A check valve inspe: tion program that also' augments ASME Section XI.
was implemented January 1988.
A corrosion and erosion monitoring program to detect pipe wall thinning has been developed and initially implemented. This program uses the EPRI "CHEC" computer code and engineering evaluations based on flow velocity, piping configuration, and water chemistry to identify areas for inspection.
Attachment to BCAN128803 December 20, 1988 Page 9 D.
Emergency Preparedness Performance Category 1 Recommended Licensee Actions:
l The present level of management attention to the implementation of the emergency preparedness program should be maintained.
Response
Management AP&L continues to maintain the emergency preparedness program at a high level.
An Emergency Planning Steering Committee with multi-discipline membership meets monthly for program reviews.
This committee ensures that changes to the Emergency Plan or implementing procedures have been reviewed against 10CFR50.54(q) and NUREG-0654, evaluates exercise and drill results, and identifies training needs and requirements for emergency response personnel.
Annual Exercise Prior to the 1988 exercise, the Emergency Action Levels for classification of an emergency event were revised to an expanded set of event evaluation guidelines.
NUREG-0654 was used as a basis for the development of these guidelines.
The ANO-1 control room simulator was used in the exercise, adding a high degree of realism for the operating crew and providing for a better evaluation of Operations personnel response to emergency conditions simulated during the exercise.
Both the ANO-1 and ANO-2 simulators are used during routine operator requalification training, including training on the use of the Emergency Plan.
The AN0 Emergency Planning Exercise Evaluation Process is used to assess weaknesses identified during the annual exercise.
An Emergency Exercise Critique Organization is used to formally evaluate the performance of the Emergency Response Organization (ERO) during the annual exercise.
Five ERO qualified lead evaluators and 20 to 25 additional evaluators observe all aspects of the ERO activation and operation.
A formal Exercise Critique Board with senior management participation meets following the ERO exercise.
Dose Assessment The current dose assessment systcm is being phased out by an improved system.
The Dose Assessment Team Training Program provides 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of training per year for all team members, including practical drills.
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Attachment to SCAN 128803
-Dece ber 20, 1988.
Page.10 E.
Security Performance Category 2 Recommended Licensee Actions:
The licensee should probe the root causes of security violations and audit findings for broad implications.
Determinations should provide guidance to adjust security policy and procedures.
Corporate and high level site management oversight should continue until a high level of security awareness is pervasive throughout the ANO facility.
Response
Incident Reporting The AND Security Incident Reporting procedure was revised in May 1987 to include or to improve documented consideration of deportability and of necessary compensatory measures, to document prompt review by AP&L management, and to. document the cause and corrective actions taken.
Training on the new requirements was provided to Security personnel, May 1987.
The. incident reporting system. improvements should also improve the identification of-root causes and the broad implications of events.
Conditions involving security have been incorporated into the new Condition Reporting' System.
Procedures An earlier weakness in compensatory measures resulted in a review of guidance in this area.
Changes were made in procedures, and training on compensatory measures determinations was conducted in August 1987.
Management Oversight Corporate and site management continue to support the Security organization in achieving a high level of awareness of security requirements for all personnel at ANO.
A policy outlining the compliance expectations and disciplinary guidelines for failure to comply with security rules and regulations was issued in February 1987.
Subsequent reviews of the loggable and reportable security events indicate generally effective results.
Training on specific responsibilities was provided to Shift Operations Supervisors and Senior Reactor Operators in August 1987.
Guidance on breaching barriers was issued in March 1988 to AP&L and contractor supervisors requiring Security Department approval prior to making a breach.
Security administrative procedures were revised July 1987 to more clearly define management and supervisory responsibilities.
Training on these revisions was completed in August 1987.
Attachment to 9CAN128803 Deccmber 20, 1988
-Page 11 Other Improvements Additional support of the Security organization has been provided during this SALP period. A Nuclear Security Specialist position in the corporate security group was filled September 1987.
The site.
AP&L Security organization was fully staffed May 1987 with the hiring of a Security Supervisor, Compliance.
The membership of'the Security Advisory Committee was expanded to strengthen the role of the group.
Additional members include the following:
General Manager, Plant Support (Vice Chairman)
Nuclear Security Specialist (Secretary)
Quality Assurance Superintendent Plant engineering Superintendent Project Engineering Superintendent I&C Maintenance Superintendent Manager, EI&C Design Engineering Licensing Specialist Improvements to the security systems made during the SALP period include upgrades to the security computer, installation of additional closed-circuit television cameras, enclosing the emergency security diesel generator as a vital area, and installation of floor-to-ceiling turnstiles at the entrance and exit for t.he protected area and at the normal personnel entrance and exit for t?e radiologically controlled access area.
A Perimeter Security System Improvement Project has been initiated to accomplish a comprehensive integrated enhancement of the perimeter security system and its support systems.
This included consolidation of design requirements into a Design Basis Document for the perimeter security system.
An Action Plan to implement the project has also been developed which anticipates completion of the entire project in 1989.
A comprehensive Fitness-for-Duty Program is in place that includes written policies, chemical testing prior to badging, ongoing random testing, and an Employee Assistance Program.
QA conducted an initial audit of the program utilizing a Technical Specialist (PhD in Toxicology).
The lead auditor attended a " Drug Abuse in the Workplace" seminar at the University of Delaware to prepare for the audit.
Both on-site and off-site Laboratory facilities were reviewed during the audit.
Att:chment to SCAN 128883 Diccmber.20, 1988 Page 12.
F.
Engineering and Technical Support Performance Category 2 Recommended Licensee Actions:
Licensee management is encouraged to continue the improvements evidenced in the design of plant modifications areas.
Management needs to review the engineering and technical support areas to determine the root cause for the weaknesses in these areas and whether recent improvements.will correct identified problems.
Response
Plant Modification Process AP&L fully implemented.the revised plant modification process during this SALP period.
The process was utilized for both ANO-1 and ANO-2 1988 refueling outages. The revised modification procedures contain specific' instructions for consideration of the following during the design process:
Impact on normal and emergency operation modes.
Technical Specification requirements System / component redundancy and diversity.
Operational requirements for surveillance testing to verify design basis and operation restraints.
Failure modes and effects.
Single failure criteria.
SAR accident analysis assumptions.
Post-modification testing.
Human factors (includes a checklist for each change to control room panels or. control room).
Special maintenance requirements.
Accessibility for maintenance.
Spare parts.
Special measurement and testing equipment.
Component database information.
An expanded training program for Design Engineers was implemented in January 1987.
Subject areas include technical and professional development courses, failure modes and effects analysis, ASME Code training, piping design, and design analysis.
Design Engineering Supervisors have been trained and certified as instructors.
Reorganization of Design Engineering occurred during this SALP period.
It is now a part of the Nuclear Operations organization.
It includes a Nuclear Safety Analysis group along with the engineering disciplines.
The consolidation of design disciplines has reduced the number of managers and increased the number of Senior Lead Engineers.
Attachment to SCAN 128803 December 20, 1988 Page 13 Engineering program.s initiated during this SALP period include Probabilistic Risk Assessments of ANO-1 and ANO-2, Safety Systems Functional Inspection Self-Assessment, Design Bases Documentation Consolidation, computer-aided drafting, Industry Experience Feedback Program for Design Engineering, and the Isometric Update Project.
Other design change control improvements made during this SALP period include the following:
Plant Modifications provides a single point of responsibility for a design change package after receipt on-site through closecut.
Turnover from Modifications to Operations is formalized.
Critical drawings (P& ids, electrical schematics) are updated prior to declaring system operable.
Increased plant personnel involvement early in the design phase to address issues and develop alternatives.
Each DCP has a summary section documenting the design bases of the change.
Lead Engineer responsibilities have been expanded.
Independent reviews have been added to the DCP process.
Design documents quality and content have been improved.
10CFR50.59 training and certifications were implemented.
The procedural guidelines have been expanded.
Modifications work schedule integrated into overall plant
)
schedule.
Post-modifications testing guidelines are being developed.
Formal test procedures are included in DCPs.
Single tracking system for DCP status.
Field change control process has been revised such that concurrence by Design Engineering is required for each change.
Configuration Control In the area of configuration control, safety system walkdowns were initiated August 1987.
These walkdowns are structured to identify discrepancies in the condition of plant equipment.
A " Systems Engineering" concept is being implemented in Plant Engineering, which should provide a communication link between Maintenance and Engineering.
A system engineer will be cognizant of maintenance activities on the assigned system (s).
Baseline Quality Requirements and Procurement Technical Support Program enhancements have been made to ensure replacement parts maintain the original quality of components.
Design Documents The accuracy of drawings has been improved by the reduction of drawing changes and DCP closecut backlog.
Significant reductions of the backlogs in closeout of DCPs, PEARS, and drawing changes were accomplished during this SALP period.
The initial backlog of DCPs (320) has been closed.
Currently only approximately 25 DCPs are backlogged.
All safety related P& ids have been revised.
The PEAR backlog is currently being reduced.
Attachment to BCAN128803 D:cember 20, 1988 Page 14 Other Engineering and Technical Support Improvements The Station Priority Review Committee has been established to prioritize all new design projects, studies, and major capital expenditures. 'ihe committee contains representatives from the station and corporate staffs to provide a prioritization of modifications, focusing on resolution of repetitive equipment problems, scram reduction, safety system availability, plant availability and performance, radiation exposure and radwaste reduction, personnel safety, regulatory commitments. A sixteen level priority ranking is used based on category, significance, urgency, and cost benefits.
A piping Isometric Drawing Upgrade Project was initiated in 1987.
This project includes seismic piping and is structured to identify seismic support deficiencies (missing anchor bolts, nuts, washers, etc.) during piping walkdowns.
A dedicated Outage Management group has been established within the Work Control Center as of January 1987.
The group consists of an Outage Superintendent and four plant operators (two from Unit 1 Operations and two from Unit 2 Operations).
The group schedules all maintenance, modificati.ons and support group activities for the outage.
The group develops detailed Outage Handbooks for the preparation, implementation, and critique of each outage.
The group provides status to management on progress toward outage planning milestones.
The group identifies and resolves potential outage problems.
The group provides overall management control of activities during outage periods.
The group coordinates post-outage critiques and tracks action item completion.
l A component level Q-list has been developed as a dataset of SIMS.
The classification of components will assure that procurement of spare parts, maintenance activities, and design considerations are l
adequately addressed at a component level.
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l Attachment to BCAN128803 l
Decemb:r 20, 1988 l
Page 15 l
A Lubrication Project for safety-related rotating equipment is in the final phase of development.
The project will result in a single source of information for lubrication identification and quantity used for each component. The system is a dataset of SIMS as an expansion of the equipment database.
Many of the programs that have been implemented directly support plant Maintenance.
Additional technical positions within the Maintenance department, which were authorized and partly staffed during this SALP period, will provide engineering support within Maintenance.
Fire Protection In the area of Fire Protection, a comprehensive Fire Protection Program Manual was issued in 1986 and is revised annually.
Pre-fire plans were added in 1987 which provide information to fire brigade and support personnel for response to a fire in any area of the plant (access routes, hazards lighting, fire protection features, fire fighting strategies, and special precautions).
Responsibility for fire protection was transferred to the on-site plant Engineering Manager in the Fall of 1987.
A supervisor was assigned in March 1988 with a staff of approximately five personnel.
Design installation verification performed as part of the design change process improvements requires that revisions to the penetration seal log to identify penetration number and seal details be included in the closecut of the DCP.
Safe shutdown capability assessment provisions are addressed in the design process procedures.
A Fire Protection Review by a Fire Protection Specialist was added to the design change process in September 1987.
This review is performed to determine if a fire barrier will be penetrated as part of the DCP.
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Attachment to BCAN128803 Decembsr 20, 1988 Page 16 Training In the area of Training, all training programs have been accredited by INPO and the overall program was admitted to the National Academy for Nuclear Training in April 1987.
Reaccreditation for Non-licensed Operator, Reactor Operator, Senior Reactor Operator / Shift Supervisor, Continuing Training for Licensed Personnel, and Shift Technical Advisor Training Programs was obtained in January, 1988.
The Operator License exam scccess rate remains high and continues to strengthen the Operations organization.
Both ANO simulators are operational and are being used for training.
The ANO-2 simulator certification was submitted to the NRC in December 1987 (one of the.first in the industry).- Certification of the ANO-2 simulator
.is expected to be submitted to the NRC by the end of 1988.
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Attachment to OCAN128803 Diccmb:r 20, 1988 Page 17 G.
Safety Assessment / Quality Verification Performance Category 2 Recommended Licensee Actions:
Licensee management should assess the effectiveness of the newly i< sued condition report program.
Management should evaluate increasing the level of QA surveillance activity.
Management involvement in licensing activities should be increased to insure adequate levels of staffing and technical resources are assigned to assure high quality responses to NRC initiatives.
The licensee should evaluate the policies for prioritizing regulatory and safety issues to avoid unjustified delays in responding to longer term issues.
Response
Condition Reporting System AP&L believes that the Condition Reporting System, which was implemented in May 1988, will prove its effectiveness over time.
It simplifies the identification and oversight of events through consolidation of numerous previous systems which had no centralized overview.
This provides management with a more comprehensive report on unsatisfactory conditions and provides a mechanism for identifying trends.
The system has provisions to require prioritization of conditions.
A significance determination of each condition is performed.
The system also provides an improved documentation process for corrective actions and root cause determinations.
Initial training on the condition reporting system was given to the entire nuclear operations staff.
Ongoing training is also provided to describe revisions to the system.
A dedicated group, In-House Events Analysis, manages the process and provides technical support for review of identified conditions.
A recent change to the system allows for management review of each condition report the first working day following initiation.
Condition reports determined to be inappropriate are administratively cancelled by the management review committee.
This committee also determines the appropriate department to be responsible for the condition report corrective actica assignments.
AP&L Quality Assurance is currently conducting an audit of the Condition Reporting Program.
QA Surveillance Activity QA group involvement in surveillance activities has been increased including performing surveillance of audited areas as well as periodic witnessing of selected Technical Specification required surveillance tests.
In 1987, there were a total of 101 surveillance performed
m w4 Attachment to SCAN 128883 02cembsr 20, 1988 Page 18 by QA personnel with only a few of those conducted on cackshifts.
As of December 15, 1988, in excess of 280 QA surveillance have been conducted with approximately 20% being performed on backshifts.
The selected Technical Specification surveillance tests are also reviewed to assess that the functional requirements as described in the Safety Analysis Reports are demonstrated by the testing performed.
QA surveillance results of the area to be audited are utilized as supplemental information during the audit process to provide a broader base of performance input from which to assess the audit area.
Licensing Management involvement in the licensing activities discussed in the SALP report was reviewed by AP&L.
It was determined that improvements in the timeliness of responding to issues could be improved through enhanced communication with the NRC.
As a result, AP&L's Licensing staff has initiated regularly scheduled meetings with NRC Project Managers. A list of outstanding items for both units has been developed with the NRC Project Manager for ANO-1.
Recently, the vacant position for the NRC Project Manager for ANO-2 was filled and periodic review will also be scheduled with the ANO-2 Project Manager.
This should also contribute to improving communication further and expediting resolution of outstanding items.
The results of these periodic reviews will be utilized by AP&L Management to help assure appropriate priorities are assigned to work efforts necessary to resolve open items such as those noted in the report.
We have also reviewed the specific items noted in the SALP report.
This review indicated a need to constantly document, via letters, any unanticipated schedule slippages. We will strive to assure technically sound submittals are made in a timely manner.
In those cases where original schedules must be changed, this will be discussed in advance with the applicable Project Manager and subsequently documented by letter.
These actions should adequately address the concerns discussed in the SALP report, and improvements should be notable in future SALP periods.
Other Improvements Other improvements in the area of Safety Assessment and Quality Verification occurred during this SALP period.
These include the improved program for performing 10CFR50.59 reviews which was implemented in June 1987.
The program was based on a policy document developed and approved under the director of the corporate and plant safety review committees.
Personnel performing safety evaluations are trained, tested, and certified and meet qualification requirements in accordance with the policy.
Requalification is required every two years.
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Attachm:nt to BCAN128803 Dsccmber 20, 1988 Page 19 A computerized Licensing Document Research System was implemented in November 1987.
The system provides work and phrase search capability of Licensing Basis Documents by corporate and plant staff certified 10CFR50.59 reviewers to utilize in performance of 10CFR50.59 evaluations.
Documents currently available include Safety Analysis Reports, Operating Licenses, Technical Specifications (TS), Original Safety Evaluations, TS and OL Safety Evaluation Reports, The Emergency Plan, and the Quality Assurance Manual for Operations.
Future documents anticipated to be made available on the LDRS System include NRC Correspondence and design related documents.
A Safety Analysis Report Upgrade Project was initiated to revise the SARs for both units to reflect facility changes that have not been adequately addressed, to provide greater detail, and to. correct conflicting information. The revised SARs were issued in October 1988.
The four major objectives of the project were as follows:
Improve the 50.59 safety evaluation process Provide consistency of descriptions within the SAR Improve grammatical content and overall quality of the SAR Add appropriate NRC commitments that fall within 50.59 reviews to the SAR Discrepancies that are identified as potentially sericus were reviewed expeditiously.
Proposed changes were reviewed by the Plant Safety Committee (PSC) and Safety Review Committee (SRC).
Safety evaluations were verified or performed for all of the changes.
The greater detail in the SAR will expedite the review process for future facility changes.
Changes to the SRC organization and operation have been implemented to increase the effectiveness of the committee.
Increased senior management participation including chairmanship by Vice President, Nuclear.
Outside consulting expertise added to membership.
Charter revisions take better advantage of subcommittee activities and input from Nuclear Quality.
The SRC reviews that are supplemental to required activities provide a self-assessment function in the areas listed below through reports given at meetings.
QA Audit Program Findings Report l
Identifies significant findings and items indicative of programmatic concerns.
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Attachment to SCAN 128803 DIc"mb2r 20,:1988 Page 20 Relates to the committee concerns on the timeliness of corrective actions and responses to audit findings.
SRC reviews the overdue responses and the reasons for delay.
Radiation Protection Report Provides.the status of the Radiation Protection goals (exposure, radwaste reduction, etc.) and explanations of the exceptions.
Operations Assessment Report o'
Lists Key indicators of performance Describes trends in condition reporting and industry events of particular interest to ANO
. Goals and Objectives Report Indicates progress in meeting Nuclear Operations goals.
Emphasizes exceptions to goals and corrective actions.
QA Audit Program Subcommittee Report Review of audit reports.
Assesses effectiveness of QA Program PSC Oversight Reports Assesses effectiveness of the PSC to ensure License requirements are met.
The Chairman of the SRC may appoint ad hoc subcommittees to review specific projects and provide an independent assessment as deemed necessary.
Examples of issues reviewed by previous ad hoc subcommittees include Service Water, Containment Isolation, and ANO-1 Cycle 9 Reload Report.
PSC improvements include General Manager, Plant Support serving as chairman with the In-House Events Analysis Group reporting to him to provide additional support for PSC review activities.
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