IR 05000313/1993007

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-313/93-07 & 50-368/93-07

ML20059D072
Person / Time
Site:	Arkansas Nuclear
Issue date:	10/26/1993
From:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Yelverton J ENTERGY OPERATIONS, INC.
References
NUDOCS 9311020126
Download: ML20059D072 (5)

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OCT 2 61993 Dockets: 50-313 50-368 Licenses: DPR-51 NPF-6

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Entergy Operations, In ATTN: J. W. Yelverton, Vice President Operations, Arkansas Nuclear One Route 3, Box 137G Russellville, Arkansas 72801 SUBJECT: NRC INSPECTION REPORT 50-313/93-07; 50-368/93-07 Thank you for your letter of October 8,1993, in response to our letter and Notice of Violation dated September 10, 1993. We have reviewed your reply  ;

and find it responsive to the concerns raised in our Notice of Violatio We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine

Sincerely, L / ,, *y c

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A. Bill Beae ,Di 'Jject Division of Reac or ojec s cc:

Entergy Operations, In ATTN: Harry W. Keiser, Executive Vice President & Chief Operating Officer P.O. Box 31995  !

Jackson, Mississippi 39286-1995 Entergy Operations, In I ATTN: John R. McGaha, Vice President Operations Support P.O. Box 31995 Jackson, Mississippi 39286

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Entergy Operations, In ATTN: James J. Fisicaro -

Director, Licensing '

Route 3, Box 137G Russellville, Arkansas 72801 Entergy Operations, In '

ATTN: Michael B. Sellman, General Manager, Plant Operations Route 3, Box 137G Russellville, Arkansas 72801 ,

Honorable C. Doug Luningham County Judge of Pope County Pope County Courthouse  !

Russellville, Arkansas 72801 Winston & Strawn ATIN: Nicholas S. Reynolds, Es ,

1400 L Street, Washington, ,

Arkansas Department of Health- "

ATTN: Ms. Greta Dicus, Director Division of Radiation Control and Emergency Management 4815 West Markham Street Little Rock, Arkansas 72201-3867 B&W Nuclear Technologies .

ATTN: Robert B. Borsum Licensing Representative 1700 Rockville Pike, Suite 525 Rockville, Maryland 20852 Admiral Kinnaird R. McKee, USN (Ret)

214 South Morris Street ,

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===ENTERGY " 3 * '3m Recide. AR 72801 Tel501 % 4 8888 Jerry W. Yelverton W.e Prescent Owifm A'53 October 8,1993 2CAN109301 U. S. Nuclear Regulatory Commission Document Control Desk Mail Station PI-137 Washington, DC 20555 Subject: Arkansas Nuclear One - Unit 2 Docket No. 50-368 License No. NPF-6 Response To Inspection Report 30-313/93-07; 50-368/93-07 Gentlemen:

Pursuant to the provisions of 10CFR2.201, attached is the response to the violation identified during the inspection of activities associated with Unit 2 reactor coolant samplin Very truly yours, t/ W

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October 8,1993

. 2CAN109301 Page 2

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cc: Mr. James L. Milhoan Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Arkansas Nuclear One - ANO-1 & 2 Number 1, Nuclear Plant Road Russellville, AR 72801 Mr. Roby B. Bevan, J NRR Project Manager Region IV/ANO-1 U. S. Nuclear Regulatory Commission NRR Mail Stop 13-H-3 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. Thomas W. Alexion NRR Project Manager, Region IV/ANO-2 U. S. Nuclear Regulatory Commission NRR Mail Stop 13-H-3 One White Flint North 11555 Rockville Pike Rockville, MD 20852 ,

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NOTICE OF VIOLATION During an NRC inspection conducted on July 11 through August 21,1993, one violation

of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below: ~ Unit 2 Technical Specification 6.8.1.a required, ia part, " Written procedures shall be established, implemented, and maintained covering . . surveillance and test activities of safety related equipment."

Procedure 2607.001, Revision 9, Permanent Change 1, " Unit II Reactor Coolant System Sampling," was established to accomplish Technical Specification Surveillance Requirements 4.4.7 and 4.4.8. Section 9.1.3 specified one method for obtaining a liquid sample from the reactor coolant system hot leg. Procedure 1052.023, Revision 3, " Conduct of Chemistry," required that "Where there is an approved procedure that covers an activity, that activity shall be performed in accordance with the provisions of the applicable procedure . . . . When not directly referencing the procedure, the chemist is still responsible for performing the task as specified by the procedure."

Contrary to the above, while obtaining a liquid sample from the reactor coolant system hot leg, the chemist failed to adhere to the requirements of Procedure 2607.001, " Unit II Reactor Coolant System Sampling," Section 9. Specifically, the chemist performed the procedural steps out of sequence, which resulted in inability to open a solenoid valve to the post accident sampling syste ,

Further, the chemist initially established an improper flush rate (approximately 0.75 i

gallons per minute vice the required 1-1.5 gallons per minute) by throttling a valve not specified for this purpose in the procedur This is a Severity Level IV violation (Supplement I) (368/9307-01). {

Resonse to violation 368/9307-01

(1) Reason for the violation i On August 18,1993, reactor coolant system (RCS) sampling was performed by a chemist qualified on the task. During the performance of the initial valve lineup, the chemist aligned the system in a sequence other than that described in the sampling procedure. Valves 2SV-5842 - the post accident sampling system (PASS) sample line from the RCS,2PS-55 - the RCS sample cooler outlet, and 2SV-4665 - the hot leg sample valve were operated out of sequence. The RCS .

sample flow rate had not been verified by the chemist. The flow rate was 0.75 ;

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Attachment to

. 2CAN109301 s Page 2 of 4 lpm, rather than the required 1.0-1.51pm flow rate. The flow rate was adjusted by a second chemist to the required flow rate. The valves used to make this adjustment were appropriate, but were labeled incorrectl The lack of procedure adherence in this event did not cause the sampling and analysis to be inaccurate or incomplete. Independent reviews of the sample results are performed by other chemists and a supervisor to ensure that deviations from expected results are explained. The results of this RCS sample were within the expected concentration The chemist involved in this condition believed his qualification and experience to be such that direct procedural reference was not required. The decision to not have a procedure in hand for direct reference was based on the complexity of the task, the repetitive or routine nature of the task, the importance of the task with respect to safety, and the sign-off requirements. RCS sampling is required at least five days per week and is one of the commonly performed samples in the laboratory. Routine performance of the task may have caused some degree of overconfidence in the need for the procedure to be in hand when performing tne tas At the time of this condition, the Chemistry Job Observation Program specified procedural compliance as one of five broad areas to be evaluated during an observation. A review of the observations performed during 1993 showed that this activity was observed on three separate occasions. One of these observations produced a procedure improvement form (PIF) for revision to the procedure related to the valve lineup, one contained a comment about the valve lineup but did not generate a PIF and the third identified no deviations. All three observations listed the procedural compliance as satisfactory. This indicated a lack of consistent understanding and interpretation of the chemistry requirements for procedural compliance. Since the observations were noted to be satisfactory, the message communicated to the chemists was that their performance was acceptabl The root cause for this condition has been determined to be lack of consistent interpretation / understanding of the requirements for chemistry procedural compliance and the communication of the improper standard to the chemists through the Job Observation Progra Two contributing causes have also been identified:

1) The decision to not use the procedures for direct reference caused the needed procedure changes to go unidentified. The number of procedures not upgraded to the Procedure Writer's Guide format, incorporating proper human factoring techniques, impeded the work of the chemists and contributed to the reliance on memory and OJT rather than procedur l

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. 2CAN109301 o Page 3 of 4 2) The Chemistry Job Observation Program was not effective in identifying this condition. No mechanism existed to properly cross check the decision of the chemist as to whether or not a procedure was required for direct referenc No written standard set of guidelines had been issued for the observation While the program did provide documented review of task performance and provided corrective actions for many identified items, the lack of standardized review criteria did not provide consistent monitorin (2) Can.ective steps taken and the results achieved A memorandum dated August 20,1993 was immediately provided to all chemistry personnel to emphasize management's performance expectations at the supervisory and craft levels regarding procedural adherenc Chemistry management conducted crew briefings to discuss lessons learned from this event and management's expectations concerning procedural implementation and adherenc The individual involved in this condition has been counsele Procedure 1052.023, " Conduct of Chemistry" has been revised to clarify management's expectations regarding procedural complianc The Chemistry Supervisor's Desk Guide has been revised to include expectations on chemist and supervisory performance standards in regard to procedural adherenc The Chemistry Job Observation Program has been strengthened to provide feedback to chemistry management for satisfying performance expectations. A set of guidelines forjob observations has been developed and includes objectives for procedure compliance, work practices, safety practices, material condition, and radiation worker practice Procedure 2607.001, " Unit 11 Reactor Coolant Sampling" has been reviewed. This review identified several valves in the sample system that were incorrectly labele The labeling on these valves has been correcte Lesson Plan AZ10070-010, " Introduction to Nuclear Chemistry" has been revised to include additional information regarding procedure use and adherenc f

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, Page 4 of 4 (3) Corrective steps which will bg_taken to avoid further violations Complete core on-the-job training (OJT) card review to identify the basic knowledge requirements for improved training consistency when qualifying chemists. This review will be completed by October 31,199 A review of frequently performed chemistry procedures is being conducted to ensure the appropriate level of detail exists. This review will be completed by October 31,199 The Chemistry Superintendent will continue to conduct crew meetings during each continuing training cycle and participate in shift turnover meetings in order to communicate management expectations in this and other areas. As an enhancement to the Job Observation Program, a requirement will be added to have the individual performing the observation contact the Chemistry Superintendent to determine if there is a need for a special emphasi Human factor enhancements will be installed to flow gauges and pressure indicators in the primary and secondary sample rooms. These enhancements are expected to be installed by December 31,1993 A complete enhancement of all Chemistry Department procedures is being conducted. This upgrade is expected to be completed by March 31,199 (4) Date when full compliance will be achieved Full compliance was achieved when chemistry management provided written expectations regarding procedure use and adherence to all chemistry personne This action was supplemented by revising the " Conduct of Chemistry" procedure to clarify management's expectations concerning procedural compliance and conducting crew meetings involving each oncoming crew prior to their returning to work. Lessons learned were reviewed and written guidance was distributed regarding the expectations for procedural complianc P

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m NRC CORRESPONDENCE DISTRIBUTION SPECTIONS (INCOMING AND OUTGOING) -

ANO-DCC- ADMIN /5 BEMENT, R. S. - RERTC '

- BURSKI, R. F. - WGSB309

. DEhrrON, D. R.~- GSB/3C EATON, W. A. - GSB/2C

. ENSLEY,'J. - ENTERGY SERVICES B-23 FISICARO, J. J. - GSB/lC FITE, C. .B. - TSB/2 i

HOWERTON, R. W. - GSB/2W

. HUGHEY, W. K. - ECH/660 HUMPHREY, L. W. - TSB/2 JAMES, D. E. - GSB/lC -;

Li LABONTE W. T. - ECH/30 I

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-

LANE, R. D. - GSB/2E -

LAUGHLIN, L W. - WSSB415 -

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MEISNER, M. J. GGNS/SSB/NS&RA PSC ADMIN ASSISTANT- ADMIN /3 'i TURK, C. H. - GSB/3W "

- WALDRON, D. S. - GSB/IE-I WRAPE, A. J. - GSB/3E

• MARTIN, ROBERT '

NSPECTIONS (OUTGOING ONLY)

SENIOR NRC RESIDENT INSPECTOR - ADMIN /l (WITilOUT ATTACilM ENTS)

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• ALEXION, THOMAS - NRC 'I

• BEVAN, ROBY - NRC '

• DICUS, GRETA  ;

• GRABER, LYLE  !

• MCGEHEE ESQ., ROBER *

• MCKEE. ADMIRAL K. ., * MILHOAN, L15 NRCi 8

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• REYNOLDS, NICHOLAS - WINSTON & STRAWN

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REVISED 07/16/93 1

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